EXAMPLE PAGE - ANNUAL REPORT - THE SWEDISH CLUB - Flipbook - Sida 43
SUSTAINABILITY
focus has been placed on the
circumstances created by the COVID-19
pandemic and its impact on employee wellbeing. Social gatherings via digital means
and socially distanced walking activities
outdoors have been well attended to and
helped maintain a social context during the
special circumstances created by the
COVID-19 pandemic. Activity challenges
have been held in various of the Clubs
offices, encouraging a healthier lifestyle. By
way of example, a number of the
Gothenburg employees gathered to walk or
run 10 kilometres in September, instead of
the cancelled Gothenburg Half marathon, in
which the Club usually arranges
participation.
for compensating their seafarers for workrelated illness and injuries under applicable
contracts, law and convention limits when
serving on insured ships.
Human rights
The Club has zero tolerance towards
corruption and bribery. The Club applies the
UK Bribery act as a benchmark for its
employee policy, which is more stringent
than the equivalent Swedish legislation that
would otherwise have applied (in general).
An annual sign-off procedure was
introduced in 2020 and also performed in
2021, whereby all employees read and sign
off on their understanding of the Club’s
Ethical Directive, among other policy
documents.
Sound business behaviour and compliance
with internal and external regulations are
ultimately dependent on the acts of the
individual employee. This includes
safeguarding the values mentioned in this
sustainability report.
The Club has several channels through
which employees can alert management
about any abuses or wrongdoing. Annual
risk workshops are held under the auspices
of the risk management function. These
workshops aim to target operational risks,
including fraud, malicious damage,
employment practices, business practices,
workplace safety and public safety. In
addition, the Club has two web-based
applications where risks and incidents –
“near misses” - in the line organisation- are
registered.
The findings are compiled and presented to
management and the Club’s board on an
annual basis. Furthermore, the Club has a
whistle-blower policy that enables
employees to submit complaints on a
confidential basis, through an external law
firm, regarding non-compliance, any illegal
or unethical activity, or any other abusive or
erroneous behaviour, which has an adverse
impact on any individual, the Club, its
members, other stakeholders or the
environment.
The Club’s work in identifying and mitigating
risks includes several tools used for
safeguarding respect for human rights
regarding both the Club’s employees and
the Club’s business associates. The P&I
insurance provided by the Club contains
elements for enabling due compensation to
be reimbursed by the Club to its members
The Club’s Board has decided to extend the
P&I insurance to include financial security,
required under the Maritime Labour
Convention, for repatriating seafarers as
well as up to four months' wages, in case
the seafarers are abandoned by their
employer on a ship entered with the Club for
P&I risks. This was done in response to a
request put forward by the International
Labour Organization.
Combatting corruption
To combat corruption, the Club uses a
market-leading screening tool provided by
World-Check whereby all the Club’s
members and insured vessels are screened
on a monthly basis. The screening includes
global sanctions lists, global enforcement
and warning lists, global politically exposed
(PEP) lists and global state-owned entity
lists (SOE).
The screening also includes corporate
managers who are directly or indirectly
connected to or associated with an
embargoed country or entity which carries
related or other risk-relevant information.
Swedish Anti-Money Laundering Act, it has
voluntarily introduced a number of
measures to enhance its routines for antimoney laundering and countering the
financing of terrorism.
The Club has continued and refined its work
during the year using an AIS tracking
system, enabling it to carry out more indepth due diligence on vessels' trading
patterns and ownership structures to
combat illicit trade. Compliance data and
automated screening against sanctions list
have been integrated into the Club’s
compliance and risk assessment tools to
enable early identification of risk factors.
The Club utilises compliance data from IHS
MIRS to assess prospective and existing
members before entry into the Club and
throughout the insurance relationship.
Automated backstops based on sanctions
lists were incorporated into the Club’s
insurance and payments systems in 2021
to further enhance the anti-money
laundering activities. These measures help
mitigate the risk of inadvertently providing
insurance cover for illicit activities as well as
to mitigate the risk of the Club inadvertently
facilitating money laundering.
It is noteworthy that illegal acts, as a matter
of Swedish law, are uninsurable as being
contrary to public policy and good
insurance practice. As an example, to
enhance this fact, the Club’s Rules for P&I
insurance expressly excludes liabilities
arising from unlawful trade.
Finally, all the Club’s Board members,
members of the management group and
personnel responsible for the Club’s central
functions (actuary, risk managers, internal
audit and compliance) are subject to an
equivalent screening process to ensure that
regulatory fit and proper standards are met
for these individuals.
World-Check also draws on hundreds of
thousands of credible media sources to
monitor all the categories above. It is also
used to identify and maintain a lot of
profiles related to individuals convicted of
one or more of the predicate offences as
defined by the Financial Action Task Force
(FATF). The purpose of the screening is to
avoid the Club doing business with
inappropriate companies or individuals.
In 2021 the Club continued to enhance its
“know your client” routines through which
its membership is reviewed. While the Club,
being a non-life insurer, is not subject to the
THE SWEDISH CLUB ANNUAL REPORT 2021
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