QBE is committed to ensuring compliance with the requirements of anti-bribery and corruption laws and regulations in the jurisdictions in which it operates.
QBE’s Group Anti-Bribery and Corruption Policy (“Policy”) establishes the group minimum standards for QBE’s risk management and compliance with applicable anti-bribery and corruption laws and regulations. The Policy applies to all QBE employees, officers, directors, and QBE controlled entities.
Under the Policy:
- QBE will forgo any business that breaches or may breach anti-bribery and corruption laws.
- QBE employees are not permitted to give, offer, promise, accept, request, or authorise a bribe, whether directly or indirectly, or engage in or be an accessory to bribery, corruption, or corrupt practices.
- QBE employees are prohibited from making or supporting any facilitation payments (payments not openly publicised or advertised, and typically made directly or through an intermediary for personal gain). QBE will not reimburse any facilitation payments and will report such payments to local law enforcement as required.
- QBE employees will receive mandatory training with additional risk-based training provided as needed.
- All third parties engaged by QBE must refrain from engaging in or facilitating any business activities which could lead to an actual or potential breach of the Policy or applicable anti-bribery and corruption laws and regulations.
- QBE employees must ensure that third party remuneration (including contingent commissions) strictly aligns with customers’ interests and does not create incentives that could result in any conflicts of interest or encourage unnecessary or biased transactions.
- QBE Employees are required to report actual, potential, or suspected issues of bribery or corruption to the Compliance team, or via the Ethics Hotline which also supports reporting by non-QBE employees and anonymous reporting.