Report - COP Prototype

2022 Communication on Progress

Grupo Sancor Seguros

Published date

June 23, 2022

No. of questions

Supplemental files

GEG-PLC-001 Reglamento para conducir negocios con el Sector Público.pdf

CEO Statement

Signed

Governance

Policies and Responsibilities

1. Does the Board / highest governance body or most senior executive of the company:

Issue an annual statement about the relevance of sustainable development to the company

Issue an annual statement that addresses impacts on both people and the environment

Issue an annual statement highlighting a zero tolerance for corruption

Sign off on organizational sustainability targets

Supervise Environmental, Social, and Governance reporting

Regularly review potential risks related to the business model

None of the above

2. Does the company have a publicly stated commitment regarding the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a commitment within 2 years	Yes, and the commitment is focused on our own operations	Yes, and the commitment includes our own operations and the value chain	Yes, and the commitment includes our own operations and the value chain along with communities and society
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

https://corporate-site-content.gruposancorseguros.com/GSS/Libraries/politica-ddhh-grupo-sancor-seguros20210609112717029.pdf https://www.sancorseguros.com.ar/prevencion-lavado-activos https://corporate-site-content.gruposancorseguros.com/GSS/Libraries/codigo-etica2019073010380516420200527025426890.pdf

3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

	No, this is not a current priority	No, but we plan to have a code of conduct within two years	Yes, focused on employee conduct	Yes, focused on employees and suppliers	Yes, focused on employees, suppliers, and other business relationships
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

	No one is specifically responsible for this topic	Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)	Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)	Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights	Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Páginas del reporte 23; 43; 156 y 157. https://corporate-site-content.gruposancorseguros.com/GSS/Reports/Documents/gssreporte2020-202120220113023424248.pdf

5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

	No formal structure	Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)	Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)	Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)	Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Optional comment

Páginas del reporte 23; 43; 154; 156 y 157. https://corporate-site-content.gruposancorseguros.com/GSS/Reports/Documents/gssreporte2020-202120220113023424248.pdf

Prevention

6. Does the company have a process or processes to assess risk?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

6.1. During the assessment of risk, which business relationships are reviewed?

	A few suppliers or business relationships [approximately less than 25 %]	Several suppliers / business relationships (i.e., first tier or other high priority) [approx. 25 - 50 %]	Most suppliers / relevant business relationships [approx. 51 - 99 %]	All suppliers / relevant business relationships outside the supply chain
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

	No, this is not a current priority	No, but we are planning to develop one in the next two years	Yes, related to our own operations	Yes, related to our own operations and entire value chain and other business relationships
Human rights risks
Labour rights risks
Environmental risks
Corruption risks

Concerns and grievance mechanisms

8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

No, this is not a current priority

No, but we plan to within two years

Yes, we have an informal process (e.g., through supervisors, others)

Yes, we have a formal process

8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

	No	Yes
Is the process communicated to all employees/workers in local languages?
Is the process available to non-employees (e.g., contractors, vendors, suppliers)?
Is the process confidential (e.g., whistleblowing process)?
Are there processes in place to avoid retaliation?
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other (Please provide additional information)

9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

	No process to enable remedy to stakeholders	Remedy available to some stakeholders (i.e., some geographies, employees only)	Remedy is available to all affected stakeholders	Remedy is available to all stakeholders, and suppliers are expected to have similar policies
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Lessons

10. How does the company capture lessons regarding each of the following sustainability topics?

	No lessons are regularly captured	Conducts root cause analyses/investigation of major incidents	Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly	Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs
Human Rights
Labour Rights / Decent Work
Environment
Anti-Corruption

Executive Pay

11. Is executive pay linked to performance on one or more of the following sustainability topics?

Board Composition

12. Percentage of individuals within the company’s Board / highest governance body by:

	Number/Percentage	Not applicable (Please provide additional information)
Total number of board members (#)	22
Male (%)	91
Female (%)	9
Non-binary (%)	0
Under 30 years old (%)	0
30-50 years old (%)	18
Above 50 years old (%)	82
From minority or vulnerable groups (%)	0
Executive (%)	0
Independent (%)	100

Optional comment

Sancor Seguros es una cooperativa por lo que los números y porcentajes corresponden al Consejo de Administración de la misma

Data Assurance

14. Is the information disclosed in this questionnaire assured by a third-party?

No assurance for any metrics

Limited assurance for minority of metrics (e.g., GHG emissions only)

Verificación externa de Bureau Veritas

Limited assurance for majority of metrics

Reasonable assurance for minority of metrics

Reasonable assurance for majority of metrics

Other (Please provide additional information)

Human Rights

Commitment

2. Does the company have a policy commitment in relation to the following human rights issues?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy
Rights of women and/or girls
https://corporate-site-content.gruposancorseguros.com/GSS/Libraries/politica-ddhh-grupo-sancor-seguros20210609112717029.pdf
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
https://corporate-site-content.gruposancorseguros.com/GSS/Libraries/politica-ddhh-grupo-sancor-seguros20210609112717029.pdf
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

2.1. For each human rights policy, is it:

	Aligned with international human rights standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving human rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of expression
Digital security / privacy
Rights of women and/or girls
Access to culture
Rights of indigenous peoples
Free, prior and informed consent
Rights of refugees and migrants
Access to water and sanitation

Prevention

3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing /mitigating the risks/impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

5. Who receives training for the following human rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

Response

7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Rights of women and/or girls
Freedom of expression
Rights of refugees and migrants
Digital security / privacy
Ver nota 38 en pág 134 del Reporte de Sustentabilidad : https://corporate-site-content.gruposancorseguros.com/GSS/Reports/Documents/gssreporte2020-202120220113023424248.pdf
Rights of indigenous peoples
Access to culture
Free, prior and informed consent
Access to water and sanitation

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

A implementar: Línea Ética Avances en la incorporación de temas de DDHH en la Matriz de Riesgos Ampliación de la Matriz de Riesgos Operacionales a otros tipos de riesgos

Labour

Commitment

1. Does the company have a policy commitment in relation to the following labour rights principles?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
https://corporate-site-content.gruposancorseguros.com/GSS/Libraries/codigo-etica2019073010380516420200527025426890.pdf
Forced labour
https://corporate-site-content.gruposancorseguros.com/GSS/Libraries/codigo-etica2019073010380516420200527025426890.pdf
Child labour
https://corporate-site-content.gruposancorseguros.com/GSS/Libraries/codigo-etica2019073010380516420200527025426890.pdf
Non-discrimination in respect of employment and occupation
https://corporate-site-content.gruposancorseguros.com/GSS/Libraries/codigo-etica2019073010380516420200527025426890.pdf
Occupational safety and health
https://corporate-site-content.gruposancorseguros.com/GSS/Libraries/codigo-etica2019073010380516420200527025426890.pdf
Working conditions (wages, working hours)
https://corporate-site-content.gruposancorseguros.com/GSS/Libraries/codigo-etica2019073010380516420200527025426890.pdf

1.1. For each labour rights policy, is it:

	Aligned with international labour standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving labour rights expertise from inside and outside the company?	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks /impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

4. Who receives training for the following labour rights issues?

	No training provided	Select employees	All employees	Contractors	Direct suppliers of the organization	Indirect suppliers of the organization	Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Optional comment

En las opciones donde se seleccionó "empleados selectos" nos referimos a los colaboradores cuando ingresan a la empresa

5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Occupational safety and health
Working conditions (wages, working hours)

Performance

6. What is the percentage of employees covered under collective bargaining agreements?

	Percent of employees (%)	Unknown
Employees covered under collective bargaining (%)	95

7. What is the percentage of employees in a trade union or other workers' organization?

	Percent of employees (%)	Unknown	Not applicable (Please provide additional information)
Employees in a trade union or on a worker committee (%)	71

8. In the course of the reporting period, what was the percentage of women in:

	Percent of women (%)	Unknown
Senior leadership level position	12
Non-executive board	9

9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

	Salary ratio (%)	Unknown	Choose to not disclose
Women / Men (%)

Optional comment

No existen criterios de medición / comparación que permitan detectar casos

10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

	Frequency of injury	Unknown	Choose to not disclose
Frequency of injury

Optional comment

La empresa utiliza otras metodologías de cálculo de lesiones: Índice de Incidencia de Accidentes; días perdidos or accidente laboral y días perdidos por accidente laboral/ por hombre.

11. In the course of the reporting period, what was the company’s incident rate?

	Incident rate	Unknown	Choose to not disclose
Incident rate	6.2

Optional comment

Response and Reporting

12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Freedom of association and the effective recognition of the right to collective bargaining
Nota 29 pág 130 del Reporte de Sustentabilidad https://corporate-site-content.gruposancorseguros.com/GSS/Reports/Documents/gssreporte2020-202120220113023424248.pdf
Forced labour
Nota 31 Pág 131 del Reporte de Sustentabilidad: https://corporate-site-content.gruposancorseguros.com/GSS/Reports/Documents/gssreporte2020-202120220113023424248.pdf
Child labour
Nota 30 Página 131 del Reporte de Sustentabilidad https://corporate-site-content.gruposancorseguros.com/GSS/Reports/Documents/gssreporte2020-202120220113023424248.pdf
Non-discrimination in respect of employment and occupation
Occupational safety and health
Página 53 y 56 del Reporte de Sustentabilidad https://corporate-site-content.gruposancorseguros.com/GSS/Reports/Documents/gssreporte2020-202120220113023424248.pdf
Working conditions (wages, working hours)
Página 130 Nota 27 en Reporte de Sustentabilidad: https://corporate-site-content.gruposancorseguros.com/GSS/Reports/Documents/gssreporte2020-202120220113023424248.pdf

Optional comment

Para el período de Reporte no se registraron impactos negativos en Derechos Laborales que justificaran una acción de remediación.

13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

Capacitación en sesgos cognitivos; en el código de ética; en prevención de incendios Brigadistas en las Unidades de Negocio Implementación de Línea ética para denuncias. Ver páginas de Reporte de Sustentabilidad 2020 - 2021: 37 a 40, 78 a 80, 138. https://corporate-site-content.gruposancorseguros.com/GSS/Reports/Documents/gssreporte2020-202120220113023424248.pdf

Environment

Commitment

1. Does the company have a formal policy on the following environmental topics?

	No, and we have no plans to develop a policy	No, but we plan to in the next two years	Yes, included within a broader policy	Yes, articulated as a stand-alone policy	Not applicable (Please provide additional information)
Climate Action
2016
Water
No está definido como tema material
Oceans
No está definido como tema material
Forests / Biodiversity / Land Use
No está definido como tema material
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
2020
Energy & Resource Use
2016

Optional comment

Páginas 103 a 115 https://corporate-site-content.gruposancorseguros.com/GSS/Reports/Documents/gssreporte2020-202120220113023424248.pdf

1.1. For each environmental policy, is it:

	Aligned with international environmental standards?	Publicly available?	Approved at most senior level of the company?	Applied to the company’s own operations?	Applied to the company’s supply chain and/or other business relationships?	Developed involving environmental expertise from inside and outside the company?	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Prevention

2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

	No engagement on this topic	To better understand the risks/ impacts in question	To discuss potential ways to prevent or mitigate the risks/ impacts in question	To agree on a way to prevent/ mitigate the risks/ impacts in question	To assess progress in preventing/ mitigating the risks/ impacts in question	To collaborate in the prevention/ mitigation of the risks/ impacts in question	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

Páginas 103 a 115 https://corporate-site-content.gruposancorseguros.com/GSS/Reports/Documents/gssreporte2020-202120220113023424248.pdf

3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

	Provided internal training/ capacity building for the direct workforce	Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)	Conducting an audit process and/or corrective action plan	Collective Action with peers or other stakeholders to address the issue	Collaboration with governmental or regulatory bodies	Other (Please provide additional information)	No action within reporting period
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

	No monitoring of progress	Review issues on ad-hoc basis	Set annual targets/ goals, track progress over time (internal programs only)	Set annual targets/ goals, track progress over time (internal and external programs)	Other (Please provide additional information)
Climate Action
Water
Oceans
Forests / Biodiversity / Land Use
Air Pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & Resource Use

Optional comment

Páginas 103 a 115 https://corporate-site-content.gruposancorseguros.com/GSS/Reports/Documents/gssreporte2020-202120220113023424248.pdf

5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

	Yes	No	Choose to not disclose	Not applicable (Please provide additional information)
Climate Action
Para el período del Reporte no se registraron impactos negativos en el ambiente que justificaran una acción de remediación.
Water
Para el período del Reporte no se registraron impactos negativos en el ambiente que justificaran una acción de remediación.
Oceans
Para el período del Reporte no se registraron impactos negativos en el ambiente que justificaran una acción de remediación.
Forests / Biodiversity / Land Use
Para el período del Reporte no se registraron impactos negativos en el ambiente que justificaran una acción de remediación.
Air Pollution
Para el período del Reporte no se registraron impactos negativos en el ambiente que justificaran una acción de remediación.
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Para el período del Reporte no se registraron impactos negativos en el ambiente que justificaran una acción de remediación.
Energy & Resource Use
Para el período del Reporte no se registraron impactos negativos en el ambiente que justificaran una acción de remediación.

Optional comment

Para el período del Reporte no se registraron impactos negativos en el ambiente que justificaran una acción de remediación.

Climate Action

6. What were the company’s gross global greenhouse gas emissions for the reporting period?

Scope 1 Emissions

Full

None

No aplica para la industria

Emissions (tCO2e)

Scope 2 Emissions

Full

None

Emissions (tCO2e)

1416.27

Scope 3 Emissions

Full

Partial

None

Emissions (tCO2e)

7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

Percent of revenue (%)

Unknown

Not applicable (Please provide additional information)

8. Has the organization acted to support climate change adaptation and resilience?

We have taken action to increase organization-wide resilience to climate change

We have taken action to increase resilience in our supply chains

We have taken action to increase resilience in the communities in which we operate

We have provided funding for climate change adaptation and resilience initiatives and projects

We have not taken actions to build climate change resilience in the reporting period

Other (Please provide additional information)

Tecnología y mecanismos de suscripción para seguros vinculados a riesgos climáticos (huracán, tornados, inundaciones, granizo; incendio)

Unknown

Energy / Resource Use

9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

% of total energy consumption

Unknown

Technology

10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

Percent of total revenue (%)

Unknown

Not applicable (Please provide additional information)

Overall Environment

21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

Ver páginas 102 a 114 y 218 a 231 del Reporte de Sustentabilidad: https://corporate-site-content.gruposancorseguros.com/GSS/Reports/Documents/gssreporte2020-202120220113023424248.pdf

Anti-corruption

Commitment

1. Does the company have an anti-corruption compliance programme?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes

https://corporate-site-content.gruposancorseguros.com/GSS/Libraries/codigo-etica2019073010380516420200527025426890.pdf https://www.sancorseguros.com.ar/prevencion-lavado-activos https://www.sancorseguros.com.ar/prevencion-fraude

2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

No, and we have no plans to develop a policy

No, but we plan to in the next two years

Yes, included within a broader policy

Yes, articulated as a stand-alone policy

Optional comment

https://corporate-site-content.gruposancorseguros.com/GSS/Libraries/codigo-etica2019073010380516420200527025426890.pdf

Prevention

3. Who receives training on anti-corruption and integrity?

Optional comment

Se realizan capacitaciones a empleados y Productores Asesores de Seguros (canal de ventas). Páginas 41 y 42 del Reporte de Sustentabilidad https://corporate-site-content.gruposancorseguros.com/GSS/Reports/Documents/gssreporte2020-202120220113023424248.pdf

3.1. How often is such training provided?

	One time only	Every year	Every two or more years	We do not collect this data
All employees
Select employees
Contractors
Direct suppliers of the organization
Other – such as partners, clients, etc.
Indirect suppliers of the organization

4. Does the company monitor its anti-corruption compliance programme?

No, we do not monitor the anti-corruption compliance programme

Review issues on ad-hoc basis

Yes, through internal employee self-evaluations

Yes, through automated controls monitoring

Yes, through external independent monitoring

Yes, through other mechanisms

Optional comment

Controles automatizados para el caso de Prevención de Lavado de Activos; y con controles ad-hoc para Antifraude y otros temas de anticorrupción.

Response and Reporting

5. Please report the company's total number and nature of incidents of corruption during the reporting year.

	Number of incident(s)	Unknown	Choose to not disclose
Confirmed during the current year, but related to previous years	0
Página 138 del Reporte de Sustentabilidad https://corporate-site-content.gruposancorseguros.com/GSS/Reports/Documents/gssreporte2020-202120220113023424248.pdf
Confirmed during the current year, and related to this year	0
Página 138 del Reporte de Sustentabilidad https://corporate-site-content.gruposancorseguros.com/GSS/Reports/Documents/gssreporte2020-202120220113023424248.pdf

6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

Initial case assessment

Internal investigation

Review by risk / ethics committee

Review by board of directors

External audit / review

Other (please provide additional information)

Not applicable/no incidents in the reporting period

7. Does your company engage in Collective Action against corruption?

No, it is not an immediate business priority

No, but we plan to in the next two years

Yes (please explain)

Para el caso de Antifraude se trabaja colectivamente con otras aseguradoras y entes reguladores del Estado. Asimismo formamos parte de un programa de anticoruipción coordinado por la Cámara de Comercio Alemana, Alliance for Integrity y Pacto Global.

8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

Investigaciones ad hoc en conjunto con otras aseguradoras en caso de fraudes. Código de Ética; Comité de ética y Programa de Integridad. Participación en task force sobre integridad y cmpliance. Y en programa de Alliance for Integrity