Topdanmark wants to be part of a professional, decent and trustworthy business environment. Therefore, we do not accept corruption or bribery from our employees in the contact with customers, suppliers or other business partners.

Our assessment is that the biggest risk of corruption and bribery is related to presents and events relating to customers, suppliers and other business partners. However, we also assess the risk to be generally low.

We trust that our employees use their common sense and judgement in their contact with customers, suppliers and other business partners. Also relating to presents and events.

To support this, we have formulated a policy and a set of guidelines on how the Group’s employees are to receive and donate presents, as well as how they can organise and participate in events. The objective of the policy is to prevent and avoid that business decisions can be affected by individual and/or non-business considerations and interests.

The world economy is affected by money that is illegally acquired and used for illegitimate purposes. Large amounts of money are laundered every year, posing a threat to the global economy and its security.  The financial service companies as life and non-life insurance companies tend to be favoured channels through which illicit money is laundered.

The risk of money laundering and terrorist financing is more significant in Topdanmark Livsforsikring than in the Topdanmark non-life insurance business. However, generally the risk is low.

Topdanmark Livsforsikring has implemented an anti-money laundering (AML) policy and procedures for the entire company designed to comply with laws and legislation regarding anti-money laundering. This also includes counter-terrorism financing. Please note, that there are no legal requirements for Topdanmark Forsikring.

We have an AML Officer who is responsible for compliance with relevant legislation and instructions. The AML Officer is also responsible for monitoring money laundering activities as well as to report on risks, implemented measures and internal control to the Executive Board on a quarterly basis.  The AML Officer works with Internal Audit.

We apply an overall risk assessment when evaluating the risk of money laundering and terrorist financing. The assessment takes into account the risk factors that relate to customers, geographic areas, products, transactions and distribution channels. The risk assessment is reviewed regularly.

We have risk-based procedures for identification and verification. In addition, we have KYC (Know Your Customer) procedures and enhanced due diligence for those customers representing a higher risk, and identification of beneficial owners.

All customers are categorised in accordance with their risk potential regarding money laundering and terrorist financing. We also have a process for identification of politically exposed persons as well as internal procedures for observing suspicious transactions and activities to ensure that the procedures are complied with in practice.

Our assessment of the risk of money laundering and terrorist financing in Topdanmark is that the risk is low. This is supported by an assessment carried out by the Danish FSA on the general risk of money laundering and terrorist financing in the pensions industry in Denmark which concludes that the risk is low.

In accordance with the Danish Anti-Money Laundry Regulation, we have processes for notifying the Danish authorities in the event of suspicious transactions that cannot be rebutted.  Topdanmark’s Compliance department controls and assess whether our procedures are efficient and whether the notification of authorities is sufficient.

Furthermore, Topdanmark has an e-learning programme on risk-based money laundering. The programme is mandatory for all new employees at Topdanmark Livsforsikring, and mandatory for all employees at Topdanmark Livsforsikring working with life insurance products.