Tackling illegal practices

In its role as a preventor, MMA takes action internally to tackle illegal practices of all kinds, primarily by raising awareness and training its employees.

Raising awareness about anti-money laundering and combating the financing of terrorism (AML/CFT)

AML/CFT regulations are a key concern for the insurance industry, with the requirement to recognise the main abuses concerning:

• Money laundering, which consists of making money seem lawful when it is actually obtained from illegal activity;
• Terrorist financing, which consists of providing funds that may be used to fund terrorist activity.

In the light of these risks, insurance companies have a number of essential duties, such as categorising risks of money laundering and terrorist financing, and identifying “sensitive” persons or unusual transactions.

Within this framework, Group employees are made aware of AML/CFT and freezing of assets. Specific procedures are in place to ensure it complies with regulations. These are provided for the people concerned and made available to employees via intranet sites, reviewed each year and updated if there any changes in regulations or the categorisation of risks within the Group.

Covéa’s AML/CFT policy is based on several principles, including:

• Clear identification of employees involved in AML/CFT (Head of Compliance, AML/CFT managers and Tracfin correspondents);
• A set of operating procedures for entering into business relationships and complying with know-your-customer procedures for politically exposed persons (PEPs);
• Identifying individuals whose assets have been frozen;
• Monitoring suspicious transactions and applying surveillance measures throughout the business relationship;
• More in-depth examination of risky situations and reporting suspicious activity to Tracfin;
• Categorisation of AML/CFT risks to identify and assess areas of risk relating to the Group’s activities;
• Training staff on all these measures to comply with AML/CFT regulations and freezing of assets;
• Internal controls to check that these measures are effectively implemented within the Group.

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.

Anti-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 (gifts, invitations, recruitment of a family member, etc.) in return for a specific action.

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:

• Mapping the risk of exposure to corruption;
• An anti-corruption code of conduct, as an appendix to the rules of procedure;
• Disciplinary measures to penalise employees for breaching the code of conduct;
• A register of gifts and invitations;
• An internal whistleblowing system to report any breaches of the code of conduct to the Group’s whistleblowing officer;
• A dedicated training programme to raise awareness among managers and train employees who are most exposed to the risk of corruption;
• Anti-corruption accounting controls;
• Measures to assess and check that anti-corruption measures are working properly.

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

Duty of care

MMA is part of Covéa’s duty of care plan, which 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