INTERAMERICAN

INTERAMERICAN, as a member of the ACHMEA Group, has as its permanent goal to be the most reliable insurer in the Greek and international market. The Integrity and Anti-Fraud Policy was drafted at ACHMEA in order for the parent company to comply with international business integrity law, which has been tightened since the financial crisis. It is a coherent approach to the relevant tasks of Risk Management and Regulatory Compliance. The Board of Directors of ACHMEA and the International Affairs Division have called for the immediate implementation of the Policy, with the aim of realizing the ambition to make ACHMEA the most reliable insurer, but also as a result of discussions with the Dutch Supervisory Authority.

 The Management of INTERAMERICAN has fully adopted the initiatives regarding the implementation of the Policy. Its implementation supports the goal of INTERAMERICAN to improve performance in the relevant Corporate Social Responsibility indicators and to demonstrate robust Corporate Governance in the context of the implementation of Solvency II.

The policy concerns and applies (direct or indirect) to all stakeholders of the organization (shareholder, customers, employees, suppliers, partners, supervisory authority, etc.)

The Management of INTERAMERICAN fully adopted the initiatives regarding the implementation of the Policy in 2017

The new Policy was drafted at ACHMEA in order for the parent company to comply with international business integrity law, which has been tightened since the financial crisis. It is a coherent approach to the relevant tasks of Risk Management and Regulatory Compliance.
The Board of Directors of ACHMEA and the International Affairs Division (DI) have called for the immediate implementation of the Policy, with the aim of realizing the ambition to make ACHMEA the most reliable insurer, but also as a result of discussions with the Dutch Supervisory Authority. The Management of INTERAMERICAN has fully adopted the initiatives regarding the implementation of the Policy. Its implementation supports the goal of INTERAMERICAN to improve performance in the relevant Corporate Social Responsibility indicators and to demonstrate robust Corporate Governance in the context of the implementation of Solvency II.

The risk categories recognized in this Policy are as follows:

Money Laundering / Terrorist Financing
 Violation of International Sanctions Rules
Corruption (Bribery, Conflict of Interest)
Internal and External Fraud
 Tax evasion
 Market manipulation
 Information Systems Security
 Personal data breach
 Socially unacceptable behavior (Application of Code of Ethics and Ethics)
 Events
The policy was implemented as any relevant Policy, according to the corporate governance system of INTERAMERICAN, which - as in any company in the financial system - adopts the "three lines of defense" (three lines of defense), as follows:

Administration: Business "translation" of Policy into procedures and practices.
Risk Management and Regulatory Compliance: Management support to establish procedures, perform Integrity Risk Analysis on a regular basis. Carrying out audits regarding the implementation of the agreed procedures.
Internal Audit: an independent role, to provide Management with assurance on the proper planning and efficiency of procedures.
The main axes of the Policy are:

The Implementation of a Zero Tolerance Policy on Fraud and Corruption.
Execution of Strategic Risk Analysis (SIRA) on an annual basis.

Dutch Supervisory Authority, Bank of Greece

The issue of fighting corruption by definition concerns all employees in the company. The policy implementation actions are the responsibility of the Regulatory Compliance and Risk Management Directorates.

The implementation of good corporate governance practices is a product of cooperation of all Departments, Directorates and Companies of the Organization.

Greece

INTERAMERICAN has developed policies and procedures in order to ensure its credibility and prestige in every field of the Organization's business activities. The selection of the appropriate principles and practices of corporate governance and, consequently, the protection of the interests of all participants of the Company is a commitment of the Management.

INTERAMERICAN does not accept any form of corruption, "facilitation payments", conflict of interest or bribery (hereinafter referred to as "corruption"). This principle is essential in order to give meaning to the goals of INTERAMERICAN to achieve a corporate culture of transparency and integrity, as well as to always put the best interests of the customer first.

The implementation of appropriate corporate governance principles and practices ensures not only effective management, but also the adequacy of risk control and management mechanisms, as well as the validity of the information provided regarding INTERAMERICAN strategy and results in all areas of social its responsibility.

The following statement reflects the Company's approach and the benefits it expects from the issue of business integrity:

INTERAMERICAN does not accept any form of corruption, "facilitation payments", conflict of interest or bribery (hereinafter referred to as "corruption"). This principle is essential in order to give meaning to the goals of INTERAMERICAN to achieve a corporate culture of transparency and integrity, as well as to always put the best interests of the customer first.