Information on conflicts of interest at SWICA

1. General

SWICA Healthcare Organisation (SWICA Group, referred to below as SWICA) takes appropriate organisational precautions to avoid conflicts of interest that may arise in the provision of insurance services or to exclude the possibility of policyholders being disadvantaged through conflicts of interest. If such disadvantage to policyholders cannot be excluded, this must be disclosed before the insurance is purchased.

SWICA thus endeavours to organise its business activities in such a way that it always deals with potential conflicts of interest in accordance with legal and regulatory provisions and on the basis of the rules of conduct set out in SWICA's internal code of conduct. Accordingly, SWICA makes every effort to identify conflicts of interest and, where possible, to avoid them. If a conflict of interest is unavoidable, SWICA will be transparent and disclose it.

Below, we explain how SWICA deals with conflicts of interest and describe some of the measures implemented.

2. Types of conflict of interest

Conflicts of interest can occur in many scenarios, for example between:

SWICA and its customers
SWICA and its employees
various departments within SWICA
SWICA and third parties with which SWICA has a contractual relationship

Situations that have the potential to create conflicts of interest include:

where payments are received from third parties (e.g. in connection with the sale of third-party products)
where payments are made to third parties (such as brokers)
where employees receive performance-based pay
where employees accept gifts and/or hospitality from customers or suppliers
personal relationships between employees and persons connected to them (customers or suppliers, for example)
other activities of employees (such as second jobs, membership of boards of directors, associations and other bodies)
where employees hold a stake in another health insurer or broker

3. How SWICA deals with conflicts of interest

SWICA takes all appropriate precautions to identify conflicts of interest at the earliest possible opportunity and, wherever possible, to avoid or mitigate them, as it is not always possible to exclude them altogether.

In this context, SWICA has established organisational measures and processes to identify and manage potential or actual conflicts of interest, whereby possible conflicts of interest are already limited by the following measures to such an extent that they have no tangible impact on the individual customer. Where conflicts of interest cannot be avoided completely, SWICA has procedures and controls to minimise them.

The following specific measures and precautions have been implemented for certain types of conflicts of interests:

Information barriers

SWICA has a set of rules with minimum standards to ensure that confidential information is handled correctly. Access to such information is provided on a "need-to-know" basis, which means it can only be accessed by people who can demonstrate a legitimate interest for doing so.

Payments to and from third parties

SWICA may pay or receive sales commission or other benefits in kind for the provision of insurance services. SWICA follows the rules of the Swiss Insurance Brokers Association (SIBA) or the provisions of the sectoral agreement for the agency sector (BVV) in relation to such payments.

Remuneration

Performance-based pay may affect the way employees behave. SWICA has a salary policy that avoids perverse incentives for its staff and thereby prevents irresponsible conduct and breaches of internal and external rules.

Gifts, hospitality and other benefits

Conflicts of interest can also arise if SWICA employees grant or accept any benefits. SWICA has clear policies in place to deal with such situations. The granting and acceptance of benefits for unlawful or improper behaviour or for inappropriate relationship management is absolutely prohibited. Cases of bribery and corruption are rigorously investigated and penalised.

External activities

SWICA has processes to systematically identify, regulate or completely avoid conflicts of interest that may arise in connection with external activities (such as second jobs, or membership of boards of directors, associations or other bodies).

Procurement

There is also potential for conflicts of interest in business dealings between SWICA and its suppliers. Here too, SWICA has rules and processes to ensure that such conflicts are managed properly.

Conflicts of interest that cannot be avoided and that disadvantage our customers will be disclosed by SWICA to the persons concerned. Such disclosure may be in person, in contracts or contractual provisions, in product information or on SWICA's website (www.swica.ch).

4. Additional measures put in place by SWICA

A compliance culture of integrity and ethical behaviour within SWICA is essential to ensure that conflicts of interest are managed correctly. SWICA therefore has a department that ensures all employees receive information and training on the correct way to handle such conflicts.

This department is always available to support employees and it documents all identified conflicts of interest together with the measures and decisions taken.

5. Breaches and sanctions

In accordance with SWICA's code of conduct, failure to comply with the rules set out here may lead to sanctions (ranging from a warning through to dismissal) against the employees concerned. The imposition and scope of such sanctions is determined by the frequency and severity of the violation. Employees found to be in breach of the rules can also expect claims for damages, fines or other penalties if regulatory or civil law action is brought against SWICA.