MASAK Compliance Policy

MASAK Compliance Policy

Prevention of Laundering Proceeds of Crime and Combating Financing of Terrorism

According to local law, laundering of the proceeds derived from crime by using financial systems and to be used for terrorism financing is considered crimes.

Main function of financial intelligence units (FIU) operating in many countries in today's world is to prevention of money laundering and combating financing of terrorism. In our country, this role is conducted by Financial Crimes Investigation Board (MASAK), which operates under the Ministry of Treasury. Many financial institutions, including our company are defined as “obliged” according to law, regulation and communiqués came into force by MASAK to prevent money laundering and combating financing of terrorism and in this context, many requirements are structured for obliged companies and its employees for effective risk management.

You can reach the legislation on main principles, obligations and penalties that have to comply by our Company and our employees at the following address:

https://en.hmb.gov.tr/fcib-national-legistation

Knowing our customers, business partners and suppliers and getting information about them are the part of AvivaSA’ risk management framework. Our company has established measures to prevent the use of products and services offered to customers for financial crimes, such as money laundering and terrorist financing, in accordance with current risk management policies. In this sense, the necessary identification and verification processes are implemented in accordance with MASAK legislation and our shareholders -Aviva Group and Sabancı Holding- policies. In addition, actions are taken such as not establishing a business relationship with risky people and organizations or enhanced due diligence, not conducting risky transactions requested by employees or third parties and evaluating legal reporting obligations in suspicious transactions.

The examples given below are considered as suspicious transactions.

  • Cases where identification and verification cannot be made or adequate information about the purpose of the business relationship cannot be obtained in accordance with applicable laws, regulations, Company policies and procedures,
  • Cases that arise suspicion in the adequacy and accuracy of the previously obtained customer identification data and consequently, the identification and verification cannot be made according to the applicable laws and regulations as well as Company policies and procedures,
  • The persons that want to make contracts under a different name by concealing their true identity, and that avoid filling the application and information forms and give misleading and unverifiable information; and those who do not want to sign the life insurance disclosure form, and persons of organizations listed under watch and prohibited lists,
  • Those who act reluctant in providing information which normally everyone is required to provide, those who provide very little or incorrect information, those who submit documents suspected of being fake; those who want to make contract on behalf of anonymous or imaginary persons,
  • The persons that desire to take out a policy by coming to the sales office in person, particularly in life insurance policies; and those who ask quite persistent questions regarding the details of coverages such as disability, etc.,
  • Those who make misleading statements concerning their financial status; the persons who are under suspicion that the insurance coverage they request is not appropriate with the stated purpose/income
  • Those who are listed in the sanction persons lists prepared by international organizations and institutions that contain persons that support laundering of crime revenues and terrorism financing
Programs and Practices Carried Out in Our Company to Prevention of Laundering Proceeds of Crime and Combating Financing of Terrorism

Manage the risk of financial crimes and to comply with the legislation, the following activities are carried out in summary by the Regulatory Compliance and Financial Crime Management:

  • Establishing and implementing Corporate Policy and procedures for the prevention of laundering proceeds of crime and financing of terrorism,
  • Reporting suspicious transactions determined within the scope of the suspicious transaction reporting obligation to MASAK,
  • Keeping the information and documents for the specified periods in accordance with the Regulation on Measures Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism,
  • Periodic assessment of customer, product, service risks; evaluation of the risks of products, services and service channels to be put into practice,
  • Implementing trainings by employees and intermediaries to adopt an anti-laundering of crime revenues and the fight against terrorist financing expressed by the Corporate Policy, to create awareness about insurance transactions,
  • Monitoring international embargo lists and performing periodic checks,
  • Monitoring the effectiveness of controls implemented by other departments to prevent money laundering and combating terrorism financing.
AvivaSA Financial Crimes Risk Appetite Framework

According to the risk appetite framework adopted by AvivaSA Board of Directors, AvivaSA has a responsibility to protect customers, shareholders and the society from financial crimes.

AvivaSA has zero tolerance for fraud, bribery and corruption

Intentional or repeated breaches of law, regulation or policy related to financial crime.

Recognizing that financial crime risk events of this nature will occur, AvivaSA will tolerate accidental breaches with a limited extend.

Conducting business relationship with customers and related parties or counterparties from special risk rated countries without an allowable exception.

AvivaSA has limited appetite for conducting business in, involving, with, or on behalf of, customers and counterparties based in or from special risk rated special risk countries.

Acts of intentional facilitation of tax evasion by employees, representatives or other persons associated to AvivaSA.

AvivaSA seeks a continually improving trend in managing this risk and ensures any accidental or intentional risk events of this type are reported and investigate.

Acts of bribery and corruption by an employee or person associated with AvivaSA. This would include:

  • Active bribery (giving bribe or inducement)
  • Passive bribery (receiving bribe or inducement)
  • Facilitation payments or inducements to or from public officials by an employee or representative of AvivaSA.
AvivaSA has limited appetite for gifts, hospitality or entertainment received or offered by an employee or representative

Intentionally accepting assets suspected of criminal income without legal entitlement.

AvivaSA has zero tolerance for conducting business with prohibited customer or segments. AvivaSA has limited tolerance for conducting business with restricted customer or segments.

Acts of fraud or dishonesty perpetrated by employees, directors or representatives of AvivaSA.

AvivaSA has no appetite for acts of fraud or dishonesty directed against or enabled through AvivaSA by customers, suppliers, distributors and third parties (including those with no business relationship).

AvivaSA seeks a continually improving trend on instances of fraud loss or acts of dishonesty.

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