Other initiatives
Combating money laundering, terrorism and fraud
A shared requirement
As a financial intermediary, we are deeply involved in the fight against money laundering, the funding of terrorism and fraud. Our business model, in which a lot of transactions are performed by intermediaries, has shaped the related controls. The tasks entrusted by the Group to intermediaries are described in the distribution agreements between CNP Assurances and its partners.
Dedicated teams
Supported by 20 employees, a specific unit is dedicated to these controls at CNP Assurances, and any employee can check the Group-wide anti-money laundering procedures on the Intranet. Similar arrangements are in place in all subsidiaries, in compliance with local constraints and the principles adopted by the Group.
Specific training
Training programmes are carried out regularly in subsidiaries with support from the corporate Risk Management department. Newcomers and employees who have changed jobs are systematically trained at CNP Assurances (115 employees in 2015), as well as at CNP UniCredit Vita and CNP TI. Moreover, an e-learning module developed in partnership with the French Federation of Insurance Companies and several major insurers, taken in 2014 by CNP Assurances employees in accordance with their exposure profile, was rolled out in 2015 to partners offering high-end products.
Ethics and anti-corruption measures
All subsidiaries provide ethical guidelines through their standard operating procedures, charters or codes.
Codes for all entities
Procedures are in place to guarantee the traceability of all fund transfers, to prevent corruption.
Updated and expanded in 2010, the CNP Assurances code of conduct sets out standard operating procedures. It is posted on the Intranet and features in the Employee Orientation Guide for new hires. All employees were reminded of the rules governing corporate gifts and benefits, which are listed in the code of conduct, as well as in that of the Cypriot subsidiary. All other entities in the Group also have guidelines, specifications and regulations. The launch of Caixa Seguradora’s new code of ethics at the end of 2015 was an opportunity for employees to make an official commitment by signing the document.
Some more exposed professions have specific codes:
- The CNP Assurances code of conduct includes rules on conflicts of interest and gifts, and an ethical purchasing guide provides practical guidance on applying the 2006 purchasing code of ethics in key situations encountered by the Company’s buyers;
- Similarly, a specific code of ethics spells out standards for sales representatives of the Amétis network, while the Compliance unit verifies that they comply with the regulations applicable to insurance sales.
None of the Group’s entities makes donations to political parties. In countries where such donations are not illegal, subsidiaries, such as CNP Assurances Compañia de Seguros, specifically prohibit them in their code of ethics.
In Italy, a specialised committee of internal and external legal experts is tasked with monitoring the implementation of the organisational model for the fight against corruption and illegal behaviour, approved annually by the Board of Directors.
Targeted training
In France, training based on the code of conduct was dispensed two years ago to all managers with supervisory roles, who then trained their staff with the help of a video and a booklet.
The relevant employees of CNP Cyprus Insurance Holdings and the network receive annual training on developments in know‑your‑customer and acceptance procedures.
A clear set of procedures governing the management of financial assets
This ethical vigilance also applies to CNP Assurances’ asset management, particularly for government bonds where the country’s position in the Transparency International index is one of three exclusionary criteria.
At CNP Assurances, the fight against corruption extends to purchasing, and purchasing contracts include a standard CSR clause requiring suppliers to commit to combating corruption, including on the part of their own suppliers and subcontractors.
Corporate income tax
The CNP Assurances Group is primarily made up of insurance companies and companies that provide services to individuals, as well as a number of financial investment vehicles.
Corporate income tax payments
| 2015 (in € millions) | France | Latin America | Europe excluding France | Total |
|---|---|---|---|---|
| Corporate income tax | (370) | (315) | (23) | (708) |
In addition, the Group’s insurance companies in France paid more than €1 billion in taxes on behalf of policyholders.
Exclusion of sensitive countries
CNP Assurances formalised its policy of excluding offshore financial centres at the end of 2014. In line with its commitment as a responsible insurer and investor, and its status as a public company, CNP Assurances has drawn up a list of prohibited countries covering all of its activities, extending the exclusion beyond the list of countries prohibited as part of the fight against money laundering, terrorist financing and non-cooperation in tax matters to include countries identified as tax havens based on the Tax Justice Network indices, as well as those posing serious problems with regard to democracy, human rights and corruption, as determined by Freedom House and Transparency International.
All operations in these countries are excluded, and purchases are prohibited across all asset segments.
A compliance review of the assets in these countries has been performed, and the results were presented to the Board of Directors in early 2015. The volumes involved were limited by virtue of the fact that most of the principles have been in place for a long time. The divestment of the remaining assets is planned by 2017.