QBE is committed to addressing financial crime risks across all levels of the organisation by aligning with relevant laws, regulations, and international standards. This includes fostering a culture of high ethical standards and supporting our employees, executive leadership, and members of governance forums in aligning with the principles and minimum requirements set out in the Group Financial Crime Framework (“Framework”).
QBE’s Framework establishes the minimum standards required to manage relevant financial crime risks, which supports QBE’s compliance with applicable laws and regulations pertaining to sanctions, money laundering, terrorism financing, bribery, and corruption. This Framework applies to all QBE employees, business entities, and subsidiaries.
We employ a risk-based approach to enhance the effectiveness of our Framework, tailoring requirements and designing controls according to the specific risks faced by QBE. This approach ensures that controls and measures are proportionate to the level of risk identified. We maintain an appropriate organisational structure, including training, resources, technology, processes, and procedures to fulfil the requirements of this Framework.
Sanctions Compliance
QBE does not undertake or facilitate any activity that violates applicable sanctions laws and regulations. Where a transaction involves a person or entity subject to sanctions—directly or indirectly—QBE obtains appropriate licences from the relevant authority, where required, prior to processing.
QBE employees are required to refer any sanctions risks to the Compliance team and conduct due diligence prior to writing business, engaging third-party service providers, or making payments. Additionally, all QBE employees must attend relevant sanctions training sessions. QBE ensures compliance is maintained and appropriate licenses obtained, including for cross-jurisdictional transactions or business.
Anti-Money Laundering and Counter Terrorism Financing
QBE is committed to preventing money laundering and the financing of terrorism by identifying, assessing, and managing associated risks. This includes conducting appropriate due diligence on employees, clients, and third parties, and investigating and reporting suspicious transactions and activities in line with applicable laws and regulations.
Anti-Bribery and Corruption
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 or corruption.
Political and charitable donations and contributions must not be used or given the appearance of being used for any illegal or improper purposes. In addition, under QBE’s Group Gifts and Entertainment Policy and Group Conflicts of Interest Policy, QBE employees must report any gifts and entertainment or conflicts of interests, as required.
Any actual, potential, or suspected issues of bribery or corruption must be reported to the Compliance team, or via the Ethics Hotline, which supports anonymous reporting and reporting by non-QBE employees. QBE employees will receive mandatory training, with additional risk-based training as needed.