The outsourcing disclosures required under § 156 (1)(1) in conjunction with § 109 VAG are discussed in more detail below.
For VIG Holding, it was decided to outsource IT services to Group-internal and external IT service providers. Outsourcing agreements that had been approved by the supervisory authority existed in 2022 with IBM Austria (Internationale Büromaschinen Gesellschaft m.b.H.) and the internal Group IT system provider twinformatics GmbH, both headquartered in Austria. The outsourcing agreement with IBM was terminated as a result of the assumption of all related services by twinformatics with effect from 28 February 2023. twinformatics GmbH has also assumed full responsibility for all IT services (with the exception of those listed in the following paragraph) for the Austrian VIG insurance companies and concludes any sub-outsourcing required for this purpose while observing statutory and regulatory requirements and after consulting with the VIG insurance companies.
From 1 March 2023, IT services in the VIG Group will also be provided by VIG IT-Digital Solutions GmbH (“VIG IT-DS”). VIG IT-DS was founded by VIG Holding in order to further reinforce the alignment of IT services to be provided Group-wide and to have these services provided by a company that focuses on these services. Meanwhile, an outsourcing agreement approved by the Austrian Financial Market Authority (FMA) was concluded with VIG IT-DS. This agreement sets out the ultimate responsibility of VIG IT-DS (with twinformatics as a key sub-service provider) for all VIG solutions (SAP NewGL, IFRS 9/17, ReadSoft and some smaller supporting applications). In addition to these outsourcing agreements, VIG Holding has not outsourced any critical or important functions or business activities.
Throughout the insurance companies of VIG Group, outsourcing took place in the following areas in particular:
- IT (in particular the operation and maintenance of operating modules, computing centre operation, application development services, data storage)
- Claims handling
The four governance functions were individually outsourced by the operating insurance companies of the VIG Insurance Group, in particular the internal audit and actuarial functions and related activities, and in few cases the risk management and compliance functions.
While governance functions in VIG Insurance Group were predominantly outsourced to other Group companies, critical or important activities in the IT and claims handling areas were outsourced both inside and outside the Group.
The notification of local supervisory authorities about the outsourcing of critical or important functions or activities or the approval of such outsourcing by these authorities was done by the companies concerned in accordance with applicable national legal requirements.