Whistleblowing policy notice

Swiss Life’s business activities are based on ethical and moral values.
If any violation of applicable laws and regulations is suspected, you can report it through the reporting channels described below.

The whistleblowing procedure described below is not a complaints handling procedure.
Complaints involving a personal disadvantage in the context of a business relationship with the insurer should be addressed via the following link: Complaints handling Swiss Life Global Solutions (swisslife-global.com).

Reporting channels and types of information to be reported

Whistleblowing reporting channels are established for reporting information about breaches that have been obtained in a professional context. Breaches are generally defined as any act or omission which is either unlawful or contrary to the object or the purpose of Luxembourg law and/or the directly applicable provisions of European law.

The reporting channels are intended for reporting of breaches by the following persons:

• All Swiss Life employees;
• Persons having self-employed status;
• Shareholders and persons belonging to the administrative, management or supervisory body of the organisation, including non-executive members, as well as volunteers and paid or unpaid trainees; and
• Suppliers, contractors and subcontractors of the organisation. 

All information concerning the following matters may be reported (non-exhaustive list): 

• Violation of corporate governance rules;
• Embezzlement;
• Violation of privacy and personal data, and security of network and information systems;
• Fraud and misconduct in respect of accounting;
• Breaches of internal rules and guidelines;
• Bribery and financial crime including fraud;
• Money laundering and terrorist financing.

Internal reporting channel

All eligible persons as listed above will have access to our internal reporting channel and be able to report a breach anonymously.

For Luxembourg:
Swiss Life (Luxembourg) S.A.
6, rue Eugène Ruppert
L-2453 Luxembourg
Grand-Duchy of Luxembourg

Online form for Luxembourg: swisslifeluxembourg.whistlelink.com

For Liechtenstein:
Swiss Life (Liechtenstein) AG
Industriestrasse 56
FL-9491 Ruggell
Principality of Liechtenstein

Online form for Liechtenstein: swisslifeliechtenstein.whistlelink.com

The whistleblower can always submit the escalation directly to the Chief Compliance Officer by writing a letter to Swiss Life (Luxembourg) S.A., 6, rue Eugène Ruppert, L-2453 Luxembourg, Grand-Duchy of Luxembourg.

External reporting channel

The following authorities provide an external reporting channel that can be used either as a first step in communication or as an escalation after internal reporting. We encourage however people to privilege the use of internal reporting channel in the first instance.

• The Commissariat aux Assurances (CAA) for any breaches related to Swiss Life (Luxembourg) S.A.
• The Finanzmarktaufsicht (FMA) for any breaches related to Swiss Life (Liechtenstein) AG.

On the CAA website, instructions on how to report are described in detail under the following link https://www.caa.lu/fr/whistleblowing. 

On the FMA website, instructions on how to report are described in detail under the following link https://www.fma-li.li/en/client-protection/whistleblowing.html.

Legal protection of the reporting person

All information received in connection with  whistleblowing report is treated confidentially.

Any eligible person, acting in good faith and in line with the requirements of the applicable law, is protected from any form of retaliation (suspension, lay-off, dismissal or equivalent action, discrimination, harassment, etc.).

Conversely, the protective mechanisms do not apply to persons who deliberately provide false or misleading information.

Please refer to the Law of 16 May 2023 transposing Directive (EU) 2019/1937 of the European Parliament of the Council of 23 October 2019 on the protection of persons who report violations of Union law.

Data protection

We will hold the information you provide to us confidential and secure and use it to help us to handle and process your whistleblowing disclosure. This will specifically enable Swiss Life to consider and investigate whistleblowing disclosures.

The legal basis we rely on to process your personal data is Article 6(1)(c) of the GDPR, which allows us to process personal data where this is necessary to fulfil a legal obligation.  If the information you provide to us in connection with your report contains special category data about yourself, such as information about your
health, religion or ethnicity, we rely on Article 6(1)(a) of the GDPR to process this data, which means that you give your consent for Swiss Life to process these special categories of data.

The Data we will collect from you is name, phone number and email unless your reporting is anonymous.

We recognise that the personal information in a whistleblowing report can relate to the whistleblower(s), the accused, witnesses or other individuals mentioned. We rely on Article 6 (1) (f) of the GDPR as our lawful basis for processing this personal data, which is related to the legitimate interest pursued by Swiss Life.

The information will be shared internally with Swiss Life employees in the relevant departments so that we can process, investigate and respond to your disclosure. Internal access to the information processed as part of the investigation will only be granted to those individuals who need to have access to the information. Our aim is to ensure as far as possible the confidentiality of the information received and to protect the identity of the whistleblower and all other persons involved.

Please also note that Swiss Life uses the service provider Whisltlink a web-based reporting platform provided by Whistleblowing Solutions AB. As a data processor, Whistleblowing Solutions AB may receive and have access to some of the data provided in the whistleblowing report and they will not transfer personal data outside of the European Union /EEA.

Further information on how Swiss Life processes personal data can be found in our Privacy Policy (Privacy notice Swiss Life Global Solutions (swisslife-global.com).