QBE is committed to ensuring compliance with the requirements of sanctions laws and regulations in the jurisdictions in which it operates.
QBE’s Group Sanctions Policy (“Policy”) establishes the group minimum standards for QBE’s risk management of and compliance with applicable sanctions laws and regulations. The Policy applies to all QBE employees, officers, directors and QBE controlled entities. This Policy also applies to agents or third parties who act on QBE’s behalf, where agents or third parties do not have a sanctions compliance program in place.
Under the Policy:
- QBE will not undertake or facilitate any activity that would directly or indirectly violate any applicable relevant sanctions laws and regulations.
- If QBE has a relationship with an entity who subsequently becomes a ‘sanctioned party’, the business arrangement be suspended or terminated, and no further payments made to, or received from such persons or entities.
- QBE employees are required to refer any sanctions risks to the QBE Compliance team and conduct sanctions due diligence prior to writing business, engaging third party service providers and making payments, as required
- QBE employees are required to attend and participate in relevant sanctions training sessions.
- QBE will ensure compliance is maintained and appropriate licences obtained, including where cross jurisdictional transactions or business may occur (seeking relevant internal divisional compliance or legal advice).
Under the Policy, all QBE employees are not permitted to conduct business with/involving:
- Designated persons’ (e.g., involved in or connected to certain activities, including global terrorism, or drug-trafficking);
- Sanctioned individuals, sanctioned governments, sanctioned nationals, and/ or sanctioned private entities;
- Any entity that has 50% or more ownership by sanctioned persons directly or indirectly; and
- Any unlawful transactions in relation to a ransomware claim which would facilitate a payment to a sanctioned party.
- Third parties who are a sanctioned party under any applicable laws, regulations, or regimes.