Zero tolerance to Fraud

Zavarovalnica Triglav has adopted a zero tolerance fraud policy, clearly demonstrating its commitment to proactively safeguard the honest, responsible and legitimate operations of the Company. The anti-fraud policy is based on three pillars: prevention, detection and fraud investigation. In this regard, Zavarovalnica Triglav is drawing on the established good practice of modern corporations and operating in compliance with the guidelines of international organisations, such as the ACFE and the IAIS. The three pillars of defense against fraud extend to all of the Company’s work processes and enable Triglav to tackle fraud in the entire range of its business operations.

Tasks in relation to fraud are carried out by the Fraud Prevention, Detection and Investigation Department (FPDID), organised as a headquarters department directly accountable to the Management Board. The FPDID manages the entire spectrum of fraud, which can be divided into specific forms related to the following types of conduct:

- asset misappropriations

- corruption

- fraudulent statements.

• asset misappropriation (e.g., embezzlement, larceny, skimming, insurance fraud, insider trading, disclosure and unauthorised acquisition of trade secrets, unauthorised use of another’s trademark or design);
  

• corruption (e.g., conflict of interest, bribes, acceptance or giving of gifts);
  
  

• fraudulent statements (e.g., forgery or destruction of documents, evasion of financial obligations).
  

Implementation of an advanced anti-fraud IT solution

Zavarovalnica Triglav is in the process of implementing an IT solution package for the prevention, detection and investigation of fraud. Similar solutions are used by organisations around the world for efficient detection and analysis of criminal offences, including insurance fraud as well as other criminal offences committed by individuals or criminal organisations.

Establishment of a fraud prevention, detection and investigation system in triglav Group

The Management Board has adopted a Fraud Prevention, Detection and Investigation System Implementation Plan for Triglav Group. The plan puts special emphasis on Triglav Group insurance companies abroad, in which headquarter departments for fraud prevention, detection and investigation modeled on the parent company will be established by the end of the first quarter of 2012. This will be the first step towards an organised and more effective fight against fraud at Triglav Group.

Employee participation in managing fraud

More than 1,000 employees in Zavarovalnica Triglav participate in the training in prevention and detection of fraud. Training is of crucial importance for raising employee awareness of the damaging consequences of fraud and for establishing and nurturing a zero tolerance culture in relation to fraud.