TSC Annual Report 2024 final - Flipbook - Page 39
Managing Director Report
ESG
Combatting Corruption & UN
Goal 16 – Peace, Justice and
Strong Institutions
Zero-tolerance Towards Corruption and Bribery
The Club has zero tolerance towards corruption and bribery. The Club
applies the UK Bribery Act 2010 as a benchmark for its employee policy.
This is generally more stringent than the equivalent Swedish legislation
that would otherwise apply. An annual sign-off procedure was introduced
in 2020 and also performed in 2024, whereby all employees read and sign
off on their understanding of the Club’s Ethical Directive, among other
policy documents.
Screening of Members and Vessels
To combat corruption, the Club uses a market-leading screening tool
provided by World-Check whereby all the Club’s members and insured
vessels are screened monthly.
The screening includes global sanctions lists, global enforcement and
warning lists, global politically exposed (PEP) lists and global state-owned
entity lists (SOE).
The screening also includes corporate managers who are directly or
indirectly connected to, or associated with, an embargoed country or
entity.
World-Check also draws on hundreds of thousands of credible media
sources to monitor all the categories above. It is also used to identify and
maintain many pro昀椀les related to individuals convicted of one or more
predicate offences as de昀椀ned by the Financial Action Task Force (FATF).
The purpose of the screening is to prevent the Club from doing business
with inappropriate companies or individuals.
Know Your Client (KYC)
In 2024, the Club continued to enhance its “know your client” routines
through which its membership is reviewed. While the Club, being a non-life
insurer, is not subject to the Swedish Anti-Money Laundering Act, it has
voluntarily introduced a number of measures to enhance its routines for
anti-money laundering and countering the 昀椀nancing of terrorism.
Vessel Tracking & Sanctions Screening
During the year, the Club has continued and re昀椀ned its work using an AIS
tracking system, enabling it to conduct more in-depth due diligence on
vessels’ trading patterns and ownership structures to combat illicit trade.
Compliance data and automated screening against sanctions lists have
been integrated into the Club’s compliance and risk assessment tools to
enable early identi昀椀cation of risk factors. The Club utilises compliance
data from IHS MIRS to assess prospective and existing members before
entry into the Club and throughout the insurance relationship. Based on
sanctions lists, automated backstops were incorporated into the Club’s
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