Group Sanctions Policy Summary

QBE is committed to ensuring compliance with economic and trade sanctions ("sanctions") laws in the countries in which it operates. 

QBE’s Group Sanctions Policy (“Policy”) establishes the approach, principles and requirements essential for managing compliance with global and local laws and their requirements. The Policy applies to all employees, contractors, directors, agents, QBE’s controlled entities and QBE’s joint ventures, where appropriate. 

Third parties, including those who underwrite or handle claims on behalf of QBE, must adopt an approach to sanctions that ensures compliance with global and local sanctions laws.

Key Obligations 

Under the Policy, QBE: 

  • Will comply with the requirements of sanctions regimes of the jurisdictions in which it operates or seeks to operate. This includes not undertaking any activity with any geography or person subject to sanctions that is in violation of any applicable laws.
  • Requires its agents and third parties not to engage in or facilitate any business activity that would lead QBE to breach any applicable sanctions obligations in jurisdictions in which it operates.
  • Requires all employees to refer any sanctions risk to the Compliance team.
  • Won’t undertake any activity that facilitates a violation of sanctions or that directly or indirectly circumvents an applicable sanctions prohibition.
  • Will ensure compliance is maintained, especially where cross jurisdiction transactions or business may occur (seeking divisional compliance or legal advice before engaging).
  • Will forego any business that breaches any applicable sanctions regime in jurisdictions in which it operates or seeks to operate.