General disclosures

The following overview presents the material impacts and risks identified for this topical standard, as well as the associated Group-level and Holding-level policies or guidelines with reference to the corresponding section in the report. A concept (relevant) for all of the following impacts and risks in ESRS G1 “Business conduct” is the VIG Code of Business Ethics. VIG’s approach, especially in connection with the sub-topic “Corruption and bribery”, is in line with principle ten of the UN Global Compact (“Businesses should work against corruption in all its forms, including extortion and bribery”).

Information is provided in ESRS 2 MDR‑P “Policies adopted to manage material sustainability matters”. Additional corporate policies relevant to specific material impacts or risks are also listed in the table below.

**ESRS G1 Business conduct (plus company-specific disclosure) – Material impacts, opportunities and risks**
G1 Sub-topic	Category	Material impacts, risks, opportunities	Actions	Strategies and concepts (see MDR-P)
Corporate culture	Risk	Financial loss due to inadequate IT security measures	Encryption techniques; Risk assessments; Cyber Defence Centre; Employee training; Monitoring of IT systems	Information security
Corporate culture	Risk	Reputational damage leading to financial loss resulting from conducting business with companies that have inadequate business practices	Integration of environmental, social, governance and human rights aspects into investment processes; Minimum safeguards screening in underwriting	Asset management; International sanctions; Minimum safeguards screening in underwriting
Corporate culture; Protection of whistleblowers; Corruption and bribery	Risk	Financial loss resulting from non-compliance with regulatory requirements	Training measures relating to business conduct; Whistleblowing systems	Code of Business Ethics; Compliance Management System; Prevention of money laundering and terrorist financing; International sanctions; Conflicts of interest; Procurement principles; Data protection
Political influence and lobbying activities	Actual positive impact	Contributing to the political and regulatory agenda through political engagement, mainly through memberships	Memberships in insurance associations and industry associations independent of specific sectors; Compliance with the European Transparency Register	Code of Business Ethics
Company-specific disclosure	Actual positive impact	Environmental, social, cultural and other commitments reflect the company’s stakeholder engagement	Sponsoring and donations; Social Active Day	Sustainability programme

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