DGIEU Whistleblowing Policy

0. About this policy

   Domestic & General Insurance Europe AG (“DGIEU”) are committed to conducting business to the highest standards with honesty and integrity at all times and we take pride in putting customers first, having a strong controls, and doing the right thing. The staff of DGIEU have an important part to play in ensuring we deliver on this commitment.

   
   

   All organisations face the risk of unknowingly harbouring illegal or unethical conduct, and staff are often the first to notice when someone in a company is doing something illegal or improper. However, staff may feel worried about voicing their concerns. DGIEU is committed to creating a culture of openness and accountability in order to prevent such situations occurring and to address them when they do occur to ensure we continue to protect our business, our people and our customers. This Policy applies to all individuals working for DGIEU branches or its subsidiaries, including employees, whether temporary or permanent and whether on part-time or full-time contracts. It also applies to consultants, agency staff and contractors working for DGIEU. All such persons are referred to in this Policy as “staff”.

   
   

   DGIEU is authorised by BaFin, the Federal Financial Supervisory Authority in Germany.

   
   

   This whistleblowing policy (“Policy”) forms part of DGIEU’s system of internal control and governance and is a regulatory requirement.

   
   

   This Policy is not contractual and does not form part of any employee's contract of employment. DGIEU may vary or amend this Policy at its discretion and may apply it as far as practicable in the circumstances.

   
   

1. Who does this policy apply to?

   This Policy applies to all individuals working for DGIEU and its subsidiaries or branches, including employees, whether temporary or permanent and whether on part-time or fixed-term contracts, as well as to trainees, volunteers, and those whose employment relationship has ended or has not yet begun. Moreover, it also applies to shareholders, persons belonging to administrative, management or supervisory body of DGIEU, including non-executive members. Finally, it also applies to consultants, agency staff, contractors and providers working for DGIEU. All such persons are referred to in this Policy as “staff”. All third-party partners, suppliers, outsourced providers, and appointed representatives of DGIEU should have regard to the Policy and are required to conduct themselves in a manner that is consistent with the requirements of this Policy.

   
   

   To support the whistleblowing process, DGIEU has implemented a global whistleblowing system where personalised and anonymous reports can be submitted through a secure external portal.

   
   

   The policy is not intended to cover complaints about action planned or taken by DGIEU which has placed, or could place, an individual at a particular disadvantage in respect of their employment. If an individual wishes to raise such a complaint, they should refer such complaint to their local human resources department.

   
   

2. Aims of this policy

   The aims of this Policy are to: (i) encourage DGIEU staff members to report suspected and observed wrongdoing or misconduct in DGIEU’s business as soon as possible, in the knowledge that concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected; (ii) ensure that DGIEU staff are confident that they can raise genuine concerns without the fear of reprisals, victimisation, discrimination or disadvantage, even if they turn out to be mistaken; and (iii) provide DGIEU staff with guidance as to how to raise and report their concerns.

   
   

3. What is whistleblowing?

   This Policy applies to the disclosure of a concern which an individual reasonably believes suggests that wrongdoing or misconduct has been committed, is being committed, or is likely to be committed. Such wrongdoing, illegal activity, or substantial breaches our policies and values may include but is not limited to:

   1. 1. fraud, criminal or negligent activity or actions or omissions which could constitute a serious or very serious administrative offence, unethical or dishonest behaviour;

      2. failure to comply with any local or EU legal, statutory or professional obligation or regulatory requirements that apply to D&G and its business;

      3. damage to the environment;

      4. bribery, corruption, financial fraud, theft, embezzlement, money laundering/ illegal payments and terrorist financing sanctions and embargo violations or financial mismanagement;

      5. inappropriate selling practices or other conduct or behaviour likely to damage DGIEU’s business, reputation or financial standing;

      6. incorrect financial reporting, invoicing and accounting;

      7. facilitation of tax evasion;

      8. unauthorised disclosure of confidential information or violations of D&G data protection and information security standards;

      9. discrimination, harassment, bullying and related offences;

      10. miscarriage of justice;

      11. a material breach of DGIEU’s policies and procedures; and

      12. the deliberate concealment of any of the above matters.

   2. A “whistleblower” is an individual who raises a genuine concern in relation to any of the above.

   3. This Policy should not be used for complaints relating to personal circumstances, for example, matters relating to career progression, remuneration and awards, working patterns or workloads or a staff member’s employment rights. In these cases, DGIEU’s normal procedures should be used through engagement and escalation to line management or responsible HR contacts. In addition, customer complaints will not normally give rise to a disclosure under this Policy unless the matter relates to those outlined in paragraph 3.1 of this Policy.

   4. This Policy may neither be used for complaints that have been already addressed and unadmitted by an internal channel, complaints about interpersonal conflicts, and complaints containing public information or rumours.

   5. If a member of staff is unsure whether something is within the scope of this Policy, they should seek advice from their line manager or the Whistleblowing Officer or local Compliance Managers, whose contact details are at the end of this Policy, who will advise accordingly.

   6. Reports that are false and made with the intention of malicious intent or consequences will be treated under D&G’s disciplinary measures.




4. Raising a whistleblowing concern

   1. DGIEU hopes that in many cases staff will be able to raise any concerns with their line manager. Staff may tell them in person or put the matter in writing if they prefer. They may be able to agree a way of resolving a staff member’s concern quickly and effectively.

   2. Where the matter is more serious, or a whistleblower feels that their line manager has not addressed their concern, or a whistleblower prefers not to raise it with them for any reason (including if the matter concerns the whistleblower’s line manager), the whistleblower should submit a report, using D&G’s global whistleblowing system “BKMS” (system link set out in the Contacts section of this Policy) or request a meeting with the Whistleblowing Officer as established in the whistleblowing procedure.

   3. The whistleblower can either submit a personalised or an anonymous report. Even when submitted anonymously, the whistleblower can still communicate with the investigating Whistleblowing Officer by setting up and using a secured post-box solution within the BKMS system.

   4. Whistleblowing reports can be submitted 24/7 in English, German, Spanish, Italian, and French. Both the system and the data centre where it is hosted are certified and comply to the highest standards of data protection and information security.




5. Investigation and Outcome

   1. Once a whistleblower has raised a concern, DGIEU is committed to carrying out an initial assessment to determine the validity and scope of the investigation. DGIEU has developed this internal procedure that regulates the entire life cycle of the complaint, from its initial communication to its resolution, with the aim of verifying the veracity of the reports, the correct gathering of evidence and guaranteeing the rights of the whistleblower and the reported person.




6. Confidentiality

   1. The identity of the whistleblower shall be confidential and may not be disclosed without them express consent to any person other than the personnel competent to receive and handle whistleblower ́s reports, with the exception established by the EU law or local regulations in the context of investigations carried out by the authorities or during judicial proceedings.

   2. DGIEU hopes that staff will feel able to voice whistleblowing concerns openly under this Policy. However, if a member of staff wants to raise their concern anonymously, the global whistleblowing system allows the whistleblower to keep every step of the report anonymous through encryption and other security measures in the system. The whistleblower can opt to remain anonymous throughout the reporting process and will be reminded to not submit any information that can be traced back to them.

   3. DGIEU does not encourage staff to make disclosures anonymously. However, staff who are concerned about revealing their identity should use the secured reporting process above. Where an anonymous disclosure is made, proper investigation may be more difficult or impossible if no secured post-box is set up and DGIEU cannot obtain further information from the member of staff. It may also be more difficult to establish whether any allegations are credible or to provide feedback.




7. External disclosures

   1. The aim of this Policy is to provide an internal mechanism for reporting, investigating, and remedying any wrongdoing or misconduct within DGIEU. In cases where the breach can be effectively addressed internally and the whistleblower does not fear reprisal, the internal mecharnism for reporting is encouraged.

   2. The law recognises that employees are free to choose to report whistleblowing cases internally or externally and in some circumstances, for example where the disclosure goes to the heart of the effectiveness of the whistleblowing process, it may be more appropriate for staff to report their concerns to an external regulatory body such as the External Reporting Office of the Confederation at the Federal Office and Justice, and BaFin for Germany, the Spanish National or the Autonomous Communities Whistleblowing Authorities, the Italian Anti-corruption authority (ANAC) or to external reporting office instead of DGIEU. Members of staff are not required to make a disclosure to DGIEU or go through DGIEU’s internal processes before reporting a matter to an external regulator or external reporting office or make a subsequent disclosure to DGIEU. In addition, it is possible to report internally and to the regulator or external reporting office, either simultaneously or consecutively. If a member of staff wishes to make a disclosure to a regulator or external reporting office, the relevant contact details of the regional authorities are set out in the Contacts section of this Policy.

   3. Whistleblowing concerns usually relate to the conduct of staff, but they may sometimes relate to the actions of a third party, such as a contractor, an OEM provider, a customer, or a service provider. In some circumstances, the law will protect you if you raise the matter with the third party directly. However, we encourage you to report such concerns internally first. You should contact your line manager or one of the Whistleblowing Officers for guidance.

   The whistleblowing system is also accessible to clients and external business partners of DGIEU and they are invited to report to us harmful conduct or malpractice at DGIEU. Their reports are subject to the same level of confidentiality and whistleblower protection as reports submitted by internal employees.




8. Support

   1. DGIEU will support anyone raising a genuine concern and, even if it turns out to be mistaken, the whistleblower will not suffer any detrimental treatment as a result of raising a concern in good faith. If a whistleblower believes that they have been subjected to detrimental treatment at work as a result of raising concerns under this Policy, they should inform their line manager or a Whistleblowing Officer immediately.

   2. You must not threaten, retaliate against, or otherwise victimise whistleblowers in any way nor obstruct a report or attempt to obstruct a report. If you are involved in such conduct, you may be subject to disciplinary action.

   3. In addition to the matters set out in this Policy, the EU Whistleblowing Directive (“2019/1937”)and the EU member states’ laws transposing this Directive such as the Spanish Whistleblowing law (Ley 2/2023, de 20 de febrero, reguladora de la protección de las personas que informen sobre infracciones normativas y de lucha contra la corrupción), the Italian Law on Whistleblowing (Legislative Decree 10th of March 2023 n. 24), the German Whistleblowing law (Gesetz für einen besseren Schutz hinweisgebender Personen sowie zu Umsetzung der Richtlinie zum Schutz von Personen, die Verstöße gegen das Unionsrecht melde) provide protection for someone if they are harmed or dismissed as a result of making a qualifying disclosure about a firm or individual. In particular, if a worker makes an allegation in the public interest and with reasonable belief, even if it turns out to be untrue, no action will be taken against them, and they will be protected from adverse consequences. This protection also extends to persons who, within DGIEU, assist the whistleblower in the whistleblowing process, persons who are related to the whistleblower and who may suffer retaliation, such as co-workers or relatives of the whistleblower, or other companies for whom the whistleblower may work or has any other employment relationship or in which the whistleblower has a significant shareholding.

   4. The reported persons affected by the concern raised by the whistleblower shall have the right to the presumption of innocence and honour, the right to receive information and defence and the right to protection, as well as the right to confidentiality.

   5. For further information about external regulators please refer to:

      1. EU Directive 2019/1937:
         https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019L1937
      2. Spanish Whistleblowing Law:
         https://boe.es/buscar/act.php?id=BOE-A-2023-4513
      3. Italian Whistleblowing Law:
         https://www.gazzettaufficiale.it/eli/id/2023/03/15/23G00032/sg



9. Responsibility for this policy

   1. DGIEU’Management Board has overall responsibility for this Policy and the Whistleblowing Officer is accountable for overseeing the implementation and reviewing effectiveness of this Policy and actions taken in response to concerns raised under this Policy.

   2. The Whistleblowing Officer and Compliance Managers have day-to-day operational responsibility for this Policy and must ensure that all line managers and other staff who may deal with concerns or investigations under this Policy receive regular and appropriate training.

   3. The DGIEU Management Board will monitor this Policy and review it on an annual basis.




10. Contact details

    Link to DGIEU’s Whistleblowing System

    
    

    1. Link to DGIEU’s Whistleblowing System
       DGIEU’s Whistleblowing System	https://www.bkms-system.com/domesticandgeneral

    2. Internal Contact Details
       DGIEU Whistleblowing Officer	Telephone: +49 (0)151 72308465 Email: benjamin.metzner@domesticandgeneral.com
       Germany and Austria	Telephone: +49 (0) 611 308 78 79 Email: lena.kisselbach@domesticandgeneral.com
       France, Belgium and Netherlands	Telephone: +34 673 771 865 Email: aicha.ferdi@domesticandgeneral.com
       Spain and Portugal	Telephone: +34 900 827 437 Email: marta.ruizpages@domesticandgeneral.com
       Italy	Position currently in recruiting, to be updated once candidate is identified and onboarded

    3. External Contact Details
       Germany	BaFin Telephone: 0228 / 4108 – 2355 Email: hinweisgeberstelle@bafin.de Whistleblowing System: https://www.bkms-system.net/bkwebanon/report/clientInfo?cin=2BaF6&c=-1&language=ger Write to: Bundesanstalt für Finanzdienstleistungsaufsicht, Hinweisgeberstelle, Graurheindorfer Straße 108, 53117 Bonn Further information can be found at: https://www.bkms-system.net/bkwebanon/report/clientInfo?cin=2BaF6&c=-1&language=eng Federal external reporting office Telephone: +49 228 99 410-40 Write to: Bundesamt für Justiz 53094 Bonn Further information can be found at: https://www.bundesjustizamt.de/DE/DasBfJ/Kontakt/Rechtsverkehr/Rechtsverkehr.html
       Spain	Spanish National and Autonomous Communities Whistleblowing Authorities (Pending incorporation)
       Italy	Anti-Corruption Authority (A) Telephone: 800 -89 69 36 / +39 06 62289571 Email: protocollo@pec.anticorruzione.it Write to: Autorità Nazionale Anticorruzione c/o Palazzo Sciarra, Via Minghetti, 10 00187 Roma C.F. 97584460584 Further information can be found at: https://www.anticorruzione.it/