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Our standards will not achieve anything if we do not put them into practice. So we enable our businesses to monitor their application of the standards of business conduct policy through the work of compliance officers and internal audits. This is particularly important with our sales agents, who are required to uphold Aviva’s high standards at all times. Customer complaints of mis-selling or fraud are treated very seriously and, following investigation, have led to disciplinary action where necessary, including termination of employment.
We also use other, additional approaches, such as including the standards of business conduct in our performance management systems. Our Irish business, Hibernian, appreciates that the way people do their jobs is as important as getting the jobs done, so people’s goals include objectives such as treating others with respect. In Aviva’s head office, the Aviva values are a key part of each employee’s performance appraisal. Similarly, employees at our Turkish life assurance business are assessed against the company’s values as are staff at our Dutch business.
Some of our businesses, including those in Italy, Canada and the USA, require employees to acknowledge in writing that they have read, understood and agree with Aviva’s standards of business conduct. In Canada and the USA, this is required on an annual basis.
Our global employee survey is another important monitoring tool, which includes questions relating to our standards. In 2006, 80% of our employees around the world considered that their managers behaved “consistently with the values of Integrity, Performance, Progressiveness and Teamwork”.
Some of our businesses have established committees specifically to monitor adherence to the standards of business conduct. In Italy, for example, the committee members include two independent non-executive directors, two members of the audit committee and an independent member.
Finally, despite our best efforts to work to the highest ethical standards, we know that we need to provide whistleblowing tools that actively encourage staff to report any malpractice. While most of the allegations that require investigation are raised with internal management by employees, a 24-hour independently run malpractice reporting service – Safecall – also operates in many of our businesses worldwide. This is managed by a central financial crime team. Additional whistleblowing tools have also been set up in some businesses, including in India, where an e-mail address was set up for employees to share their views in confidence.
