Reporting breach of the law
Zurich is committed to being one of the most responsible and impactful businesses in the world. We know that we can only achieve this ambition by complying with all applicable laws, regulations and internal requirements and by living up to our values.
In line with Zurich's Code of Conduct, Zurich Insurance Company Ltd (SA) Oddzial w Polsce is therefore committed to providing employees and other reporting persons with the ability to confidentially report breaches of the law in good faith. Zurich is further committed to ensuring that reported breaches are promptly and properly investigated and that appropriate measures are taken in response. At Zurich we do not tolerate retaliation against any reporting person or a person who participates in any investigation in good faith.
Should you, as a former employee or other person who came in contact with our Zurich Branch in Poland through work-related activities, for example as a service-provider, distributor, supplier or business partner, come across information about acts or omissions which breach the law, Zurich encourages you to speak up.
When to report
Zurich encourages you to speak up and report any conduct that you, in good faith, believe is in violation of any laws. Even if you are not directly involved in a situation but you have a suspicion that something is not right, you are encouraged to speak up and not look the other way. Providing evidence of wrongdoing will often assist an investigation but it is not required in order to report a concern. Even if you only have a suspicion of wrongdoing, you may still report it, provided you do so in good faith.
How to report
You can report your concerns using either Zurich Ethics Line or external reporting channels:
The Zurich Ethics Line
The Zurich Ethics Line (ZEL) is an independent third-party provider managed by NAVEX Global. NAVEX Global employs trained operators to receive reports (via phone call or web form) at any hour of the day and every day of the year.
After receiving a report, NAVEX Global notifies Zurich, and the concern is reviewed and evaluated, and assigned as required to the appropriate local function for investigation.
Ethics line web form: https://secure.ethicspoint.eu/domain/media/en/gui/102164/index.html
Face-to-face: If you rather report your concern personally in a physical meeting with the Local Zurich Compliance Officer or/and Legal Counsel, you may request it via Zurich Ethics Line and it will be arranged within 7 days.
External reporting channels:
The European Commission, as well as some bodies, offices and agencies of the Union, such as the European Anti-Fraud Office (OLAF), the European Maritime Safety Agency (EMSA), the European Aviation Safety Agency (EASA), the European Security and Markets Authority (ESMA) and the European Medicines Agency (EMA), have in place external reporting channels and procedures for receiving reports of breaches falling within the scope of the European Union Law.
Reporting anonymously
If you choose to withhold your identity from the report, investigators may be unable to ask you any additional follow-up questions, which could limit the scope of the investigation. However, you may still choose to report your concern anonymously. The reporting persons will be given a reporting key which enables them to respond anonymously to any questions or comments the investigator has posed. If you report your concern in this manner, you should periodically call the hotline or check the website for any updates.
Investigations
Zurich is committed to investigating reported concerns in an objective, timely, thorough and professional manner, consistent with all local laws and regulations, and in a way that will gather the facts necessary to allow for a reasonable assessment of the concerns raised. A triage committee composed of Legal Counsel and Local Compliance Officer verifies the initial report and assigns further required investigators involved in the process depending on the nature of the case. The lead investigator will contact the reporting person not later than 7 days after the submission of the initial report in order to confirm the receipt of the report and will continue the communication with the reporting person throughout the investigation process until the final conclusion will be reached. The feedback on the outcome of the investigation will be provided to the reporting person no later than 3 months from the acknowledgment of receipt of the initial report.
Zurich’s no retaliation policy
Zurich does not tolerate retaliation against any employee or other reporting persons who report a concern in good faith. Protection against retaliation is also extended to those who participate in an investigation in good faith (e.g. witnesses) or provide information/evidence in the course of any investigation.
Retaliation includes direct or indirect intimidation, threats, harassment, suspension, lay-off, discrimination or other similar conduct against a reporting person, witness or investigator as a result of a report and/or investigation, as well as recommendation, encouragement or condonation of such conduct.