Tackling illegal practices

As part of its duty to prevent illegal activity, MMA takes action internally to combat illegal practices of all types, first and foremost by informing and training employees.

Anti-money laundering and countering the financing of terrorism (AML/CFT) and asset freezing are central to risk management for insurance companies, and are one of the main ways we prevent illegal activity.

• Money laundering is making money appear lawful when it is actually a direct or indirect proceed of crime.
• Financing of terrorism is providing money that may be used to finance terrorist activity.
• The freezing of assets and other international sanctions (Office of Foreign Asset Control: OFAC) is an obligation to detect designated individuals, and for the AML/CFT and Business Ethics teams to implement the procedures laid down in the legislation.

The AML/CFT regulatory framework set out in the French Monetary and Financial Code requires obliged entities to formulate and implement a policy tailored to the ML/TF risks to which they are exposed. 

In the face of these risks, insurance companies are required at an early stage, as they process transactions, to detect people that may be involved in these offences or crimes.

To achieve this, the Covéa Group has an obligation to use specific procedures to provide employees with information about AML/CFT and asset-freezing. These procedures are communicated to the people concerned and made available via the intranets. They are updated annually and also in response to any event that may materially affect the assessment of the risks of money laundering or terrorist financing, such as:

• Changes to legislation
• The publication of FATF recommendations or ML/TF risk analyses (at European, national or industry level)
• The launch of a new product range
• Significant changes to distribution channels/commercial practices
• The creation or acquisition of an entity that impacts the nature of the risks facing the group.

Covéa’s AML/CFT policy is based around a number of principles, including:

• Appropriate resources (human, financial and material) assigned to AML/CFT and asset-freezing within the group
• => Clear identification and knowledge within Covéa of the relevant contacts, in particular the head of AML/CFT and asset-freezing policy implementation, employees responsible for liaising with local financial intelligence units and making declarations to them, and employees tasked with processing the daily notifications generated by the asset-freezing system,
• A set of role-based operational procedures that is updated, approved and distributed,
• An AML/CFT risk classification to identify and evaluate at-risk areas within the group’s activities,
• Appropriate, up-to-date KYC (know your customer) information,
• A system to detect and monitor “sensitive” individuals (those whose assets have been frozen, politically exposed persons [PEPs] and people living in a third country presenting an AML/CFT or terrorism risk),
• Suspicious transaction monitoring and implementation of due diligence measures throughout the business relationship,
• More in-depth examination of at-risk situations and reports of suspicious activity filed with Tracfin,
• An annual training and information policy for employees and partners
  In 2023, an e-learning programme was launched for all staff exposed to AML/CFT risks, structured as two modules: 
  • - “Knowledge update”
  • - “New entrants” 

For the “Life”, “Non-life” and “Life/Non-life” sectors

When each new campaign begins, AML/CFT information is made available in Workplace for other staff,

• A ban on cash payments and specific due diligence procedures for payment methods that do not provide payer and payee traceability,
• A permanent and periodic control framework.

As an example, an e-learning programme was offered to all staff and networks exposed to AML/CFT risk in 2022 to update their knowledge.

Fighting corruption

Under France’s Sapin II law, major groups are required to have a procedure in place for preventing and detecting corruption. 
By definition, corruption involves two people: the corruptor, who obtains an undue advantage (confidential information, signing of a contract, etc.), and the corrupted, who benefits from an undue advantage (gift, hospitality, recruitment of a family member, etc.) in return for specific action in the course of their role.

To comply with this requirement, Covéa has a zero-tolerance policy on corruption. In accordance with the Sapin II law, the Group has a prevention programme that entails in particular:

• A map of the risks of exposure to corruption,
• An anti-corruption code of conduct, as an appendix to the company rules,
• A disciplinary policy under which employees can be penalised for breaking this code,
• A gifts and hospitality register,
• An internal whistleblowing system to report any breaches of the code of conduct to the Group’s whistleblowing officer,
• A training programme to raise awareness among executives and train employees most exposed to the risk of corruption,
• Anti-corruption accounting controls,
• Measures to assess the anti-corruption policy and ensure that it is working properly.

In 2022, 84% of MMA IARD SA’s managers(1) completed the e-learning module to learn how to identify forms of corruption, understand the Group’s anti-corruption procedures, know how to react and evaluate their knowledge.

Due diligence

MMA is part of Covéa’s duty of care plan. This plan lists all the risks associated with the Group’s activities in relation to human rights (abolition of child labour, non-discriminatory employment practices, freedom of association, etc.), health and safety (public health, occupational accident prevention, etc.) and protecting the environment (combating pollution, etc.).

To this end, an internal whistleblowing system is in place for all employees to report anything relating to these risks with regard to the Group’s operations or those of its suppliers and subcontractors, by means of a secure platform.
.

(1) Non-financial performance statement – MMA IARD SA – 2022