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017
CORPORATE GOVERNANCE MANAGEMENT Chap. 1
Compliance system
The companies of the AMB Generali Group con-
duct their business activities in a responsible manner
and in compliance with legal provisions. A sustain-
able compliance in the AMB Generali Group creates
trust on the part of the capital market and customers.
Therefore the Board of Management of AMB Generali
maintains binding compliance programmes for all com-
panies of the AMB Generali Group. These guidelines
support employees in their task of fulfilling increasingly
demanding legal requirements.
For that purpose the AMB Generali Group has
adopted the Ethical Code of the international Generali
Group. With the Ethical Code, the AMB Generali Group
gives itself a general guideline for its relationships with
customers, shareholders, employees, contractual part-
ners as well as public institutions and the press. In this
context, the Ethical Code is committed to essential
principles such as correctness, honesty, impartiality
and professionalism.
The framework provided by the Ethical Code
is defined in more detail by the Code of Conduct
of the AMB Generali Group. The Code of Conduct
comprises specific rules of conduct for the employ-
ees, in particular with regard to issues such as confi-
dentiality, acceptance and granting of gifts, business
transactions with employees, the four-eye principle
and conflicts of interest. This strengthens the trust
of customers, partners, employees and the public in
a fair and ethical conduct of the company and of all
employees.
To implement these rules of conduct, regular
training is provided across the Group. In addition, so-
called compliance officers have been appointed in all
major Group companies. They are the contacts in all
compliance issues and report regularly to the respon-
sible management bodies.
In addition to these general rules of conduct, a
Group-wide programme has been established to pro-
vide for the observance of anti-trust rules by indicat-
ing precise guidelines for all employees of the AMB
Generali Group. On the basis of a Group-wide net-
work of compliance officers and by regular training
courses for employees in sensitive areas it is ensured
that the guidelines are implemented equally across
the Group and that infringements of anti-trust law are
avoided. Furthermore the Board of Management of
AMB Generali, in cooperation with the compliance
officer, makes certain that the rules of the Securities
Trading Act are observed in the AMB Generali Group
by distributing state-of-the-art guidelines for security
compliance across the Group.