Disclosure Requirement G1-4 – Incidents of corruption or bribery
No convictions or fines were reported in the reporting year in connection with violations of anti-corruption and anti-bribery laws, and consequently no additional actions were taken.
Disclosure Requirement G1-5 – Political influence and lobbying activities
As an insurance group, VIG operates in a highly regulated environment and aims to contribute to the further development of this legal framework. VIG does this indirectly, particularly through memberships in insurance associations or sector-independent industry associations. The European Affairs department at VIG Holding is the competence centre for these activities. The aim is to contribute to practical, market-oriented and effective regulation through industry expertise and practical knowledge. In addition, European Affairs supports the members of the Managing Board and the first management level below the Board in interpreting regulatory developments to ensure they are considered in the strategy and business activities of the Group in a timely manner and in line with the company’s interests. The employees of this department are subject to the Code of Business Ethics and take into account the business strategy, which includes the sustainability programme, and the Code of Conduct of the European Transparency Register in their day-to-day work. Responsibility for the European Affairs department lies with the Deputy Chairman of VIG Holding Managing Board.
VIG does not make any contributions, including donations and sponsorship payments, to political parties or individuals affiliated with them. This principle is also enshrined in the Code of Business Ethics.
In the 2025 reporting year, VIG dealt in particular with the following changes:
Prudential regulation (Solvency II Review, Insurance Recovery and Resolution Directive, IRRD, Insurance Capital Standards, ICS);
Sustainability regulation (in particular the first Omnibus package, review of the Sustainable Finance Disclosure Regulation, SFDR, Greenwashing, European System for Natural Catastrophe Risk Management, Affordable Housing Plan);
Regulation in the retail customer business (Retail Investment Strategy, RIS, Savings and Investment Union, SIU, Anti-Money Laundering, AML, End of Life Vehicle Regulation, ELV); and
Digitalisation (in particular the Digital Operational Resilience Act, DORA, Artificial Intelligence Act, AI Act, European Health Data Space, EHDS).
For all EU initiatives, a practical, market-oriented and effective design of the new requirements was pursued, including through public consultations.
VIG Holding is registered in the European Transparency Register (see transparency-register.europa.eu/; VIG’s Transparency Register number is 720555724263-16). In contrast to the scope of application of the European Transparency Register, the scope of application of this ESRS report also includes the representation of interests at national level and in third countries. In the reporting year, as in the previous year, there were no further registrations in transparency registers in VIG (2024: none).
Group-wide expenditures for compulsory memberships in insurance associations or sector-independent industry associations increased in the reporting year to EUR 5.9 million compared to the previous year (2024: EUR 5.4 million), while those for voluntary memberships increased to EUR 6.3 million (2024: EUR 5.5 million). The increase is mainly due to four factors: inflation-related value adjustments; earnings-based contribution regulations that lead to higher contributions in the event of an improvement in earnings; improvements in the documentation quality of membership fees; and an increase in memberships. Contributions in the form of benefits in kind, through the provision of personnel resources, were recorded based on estimates (e.g. recording of the session hours and multiplication by the average hourly rate) and amounted to around EUR 244,900 (2024: EUR 183,800). The increase of 33% compared to the previous reporting year is due, among other things, to the continuous optimisation of the calculation method. The expenditures incurred in the reporting year for the use of external intermediaries to support lobbying activities amounted to EUR 141,800.
In the two years prior to being appointed to the Managing Board or Supervisory Board, no members held a comparable position in public administration, including regulators, during the reporting year.