Code of Conduct

Zurich’s Code of Conduct articulates the key rules of conduct by which we abide to help ensure that we conduct our business activities in accordance with the highest ethical, legal and professional standard.  We work to earn the trust of our stakeholders every day by behaving ethically and responsibly.  Our Code applies to all employees of Zurich, its subsidiaries and affiliates worldwide.

Complaints Handling

Zurich  is committed to ensuring effective and fair Complaints Handling that meets the expectations of Consumers, Customers, Complainants and other relevant stakeholders. Our Complaints Handling Policy establishes the principles, framework, and minimum standards that govern the receipt, handling, and resolution of Complaints within the Zurich Life & Investments Business of the group of Zurich companies operating within Australia (Zurich).

Anti-Bribery and Anti Corruption Policy

Zurich is committed to fair and responsible business practices which prohibit certain conflicts of interest and all forms of bribery and corruption.

Zurich employees are expected to avoid any business conduct that could have the appearance of improper influence and must therefore:

• Ensure that all gifts, entertainment and other advantages, either given or received, in connection with business activities are appropriate, and moderate in terms of value, frequency and quantity.
• These items must all be recorded in the Gifts and Entertainment Register at the time of occurrence
• Ensure that all political, charitable and similar contributions comply with applicable laws and the requirements of Zurich's policy. Such contributions must not be used for any illegal or improper purpose.
  

 Employees must not give or receive gifts, entertainment or other advantages that:

• Are cash payments or cash equivalents.
• Could create the appearance of obtaining or retaining an improper business or personal benefit or undue government action.
• Could cause a prohibited conflict of interest for either party.

Anti-Money Laundering / Counter Terrorist Financing

Zurich is committed to the international fight against money laundering and the financing of terrorism and requires that all applicable economic and trade sanctions are observed.

Conflict of Interests

All employees of Zurich are expected to act without a conflict of interest. Where potential, perceived, or actual conflicts of interest arise, Zurich expects disclosures and mitigating actions to be adequate and effective.

A conflict of interest arises when an employee’s own personal interest (financial, social, political or otherwise), activity or relationship influences (or has the potential to influence) the interests of Zurich and business decisions.

Our Conflicts of Interest Policy sets out the Australian regulatory requirements for managing conflicts of interest and specifically conflicts of duty (collectively referred to as (‘Conflicts’) that arise when:

a) there is a clash between a personal interest and duty to the company;

b) an individual has competing duties to another party (for example to a customer) or to another company (even if the company is another Zurich entity).

Personal Investment Trading

Zurich promotes ethical and professional standards of conduct and behavior amongst all its employees. In keeping with our professional standards, employees must place the interests of Zurich and its clients ahead of their own interests when performing their duties. This extends to Zurich employees who engage in Personal Investment Trading.

Improper conduct with respect to investment trading in Australia can result in significant corporate and personal penalties for individuals and organisations alike. It may result in criminal liability for deliberate misconduct, for breaches of a financial services law, or for criminal conduct. This Policy outlines standards and rules for employees who engage in Personal Investment Trading.