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Meridiano Seguros, Company Policies

Our policies are the pillars on which the Meridiano Insurance Strategy is based, and they include the general guidelines and specifications for each process in accordance with the ASV Group's global strategy:

Meridiano's Commercial Policy

INTRODUCTION

Policy may be defined as the set of activities, and more specifically their orientation, that are carried out to achieve a general or long-term objective.

The commercial policy can be considered to be the set of principles used to guide the Company towards a certain way of acting before the public and to increase the number of risks insured in a satisfactory way for its general policy, through the appropriate use of commercial activity.

A commercial policy will only produce satisfactory results if it is flexible enough to adapt to whatever is most fitting and possible at any given moment.

Therefore, an effective commercial policy will have the following characteristics:

  • Coordination with general policy objectives.
  • Projection over time.
  • Adaptation to the personal and material resources available to the company.
  • Flexibility to adapt to specific systems at any given time.

POLICY

Next, Meridiano's commercial policy is defined as the set of rules that will stipulate the actions to be taken in the area of customer relations, production, maintenance of the policyholder portfolio, customer service and product design.

It must regulate prices, commercial attributions and in general the supply of products, as well as the way that different agents in the network behave, so that the commercial organisation functions effectively and achieves the company’s goals in a way that is aligned with its values, mission and vision.

Lastly, it defines questions such as the image of the people who make up the commercial network and who represent the company to customers.

On dealings with customers in producing and maintaining the portfolio:

  • We must be transparent, analysing the customer's needs and offering those guarantees and cover that best meet those needs.
  • We must explain clearly and openly how the different prices available work and advise customers on the price that is best suited to their domestic economy and necessary benefits for each family unit.
  • We must explain the basic aspects of each guarantee contracted, both in terms of price and cover and exclusions.
  • We will offer each customer different payment methods so that they can choose the one that best suits their needs.
  • We cannot force the sale of policies to reach targets or with possible commissions in mind.
  • Policies must be arranged in accordance with the company's internal requirements and rules, which must be explained to each customer if necessary.
  • We will make the necessary use of the commercial functions, discounts and other tools which influence the price and the company's profitability and which are specific to each operation, considering them as exceptions to the rule.
  • We shall advise customers on taking out and maintaining the policy and when the claim benefit is payable.
  • The quality of the sale will be determined by parameters such as the fall in new business, portfolio, average premium and premium due in general terms.

About the image we must convey:

  • We have to project a sense of trust with the customer on our first contact, and always get across our values and mission.
  • We have to train the commercial network in technical and commercial products, contract and claims regulations and customer orientation as basic principles for dealing with the customer.
  • Out of respect to our customers, we must appear before them in the most appropriate attire, taking good care of our hygiene, and adopting the standard rules of courtesy and politeness in this type of relationship.
  • The sales network personnel must be recruited in an exhaustive and professional way to guarantee the quality of sales and the loyalty of the network a posteriori.
  • Each person in the network must have clearly defined functions and be evaluated on a regular basis.

About products and competition:

  • We must constantly gather information about our competitors’ products, guarantees and pricing to make such data available for marketing.
  • We will advise the customer on our products, explaining their benefits from the insurance point of view and, a posteriori, on the benefit.
  • We will not try to sell our products by discrediting our competitors.

Policyholder Protection Policy

INTRODUCTION

As provided for under Law 44/2002, of 22 November, on Financial System Reform Measures, by Order ECO/734/2004, of 11 March, on customer service departments and services and customer ombudsman of financial institutions, and other regulations for modification and implementation, Meridiano Seguros is equipped with a Customer Service Department and, on a voluntary basis, an Ombudsman for Policyholders and Beneficiaries, with the aim of dealing with all claims and complaints submitted by individuals or legal entities that may be considered to be users of the company.

APPLICABLE LEGISLATION

The following legislation applies to the policyholder protection process:

  • Act 44/2002, of 22 November, on measures to reform the financial system.
  • ORDER ECO/734/2004, of 11 March, on the customer service departments and services and the policyholder's ombudsman that regulate these aspects.
  • Royal Legislative Decree 1/2007, of 16 April, approving the reworded text of the General Consumer and User Defence Act and other complementary laws.
  • Law 26/2006, of 17 July, on the intermediation of private insurance and reinsurance.
  • Act 2/2011, of 4 October, on the sustainable economy.
  • ECC/2502/2012, of 16 November, which regulates the procedure for lodging complaints with the claims services of the Bank of Spain, the National Securities Market Commission and the Directorate General for Insurance and Pension Funds.
  • Act 20/2015, of 14 July, on the organisation, supervision and solvency of insurance and reinsurance companies.

PURPOSES TO BE ACHIEVED IN POLICYHOLDER PROTECTION:

Convey professionalism, responsibility and concern for quality to policyholders by paying proper attention to requests for information, complaints and claims received.

Seek to comply with regulations on transparency and protection of the Policyholder and with the commitments undertaken by the company.

BASIC PRINCIPLES WHICH APPLY TO POLICYHOLDER PROTECTION:

  • The Customer Service Department will act autonomously and independently from the organisation's commercial or operational services.
  • The department will be equipped with all the human, material, technical and organisational resources required to discharge the duties assigned to it.
  • Decisions will be notified to the interested parties in writing or by electronic or digital means, provided that they allow the documents to be read, printed and stored and comply with the requirements set out in Act 59/2003, of 19 December, on electronic signatures.
  • Claims and complaints may be filed at any office or branch office, at the headquarters of Seguros Meridiano and/or with the Policyholder Service Department.
  • The Policyholder Service Department will periodically submit a report to the General Management on the actions carried out, as well as the needs detected during the performance of its activity.
  • The Policyholder Service Department will inform the General Management of any actions carried out by the company itself that may be irregular or that should be reviewed, to promote continuous improvement within the organisation.

Contracting Policy

INTRODUCTION

The underwriting policy must abide by the following guidelines:

  • Underwriting must be within the insurance risk tolerance limits established for each industry sector as specified in the technical note for each product.
  • It must fulfil the risk underwriting process in force at all times.
  • Insurance contracts must be arranged in such a way that they exactly reflect the conditions accepted and valued in the underwriting process.
  • The company must avail itself of appropriate documentation, formally established, as a solid base for the future management of the insured risk.
  • The quality of policyholders and policyholders data must meet the company’s requirements to guarantee that the risk is adequately underwritten.
  • The acceptance of the risk implies that the company guarantees the coverage of the insured risks.

BASIC PRINCIPLES OF THE CONTRACTING POLICY:

Meridiano's underwriting policy has the following basic principles:

  • The established business rules and underwriting standards must be observed.
  • Such business rules and underwriting standards shall be in place to ensure that underwriting risks are kept within risk tolerance limits. They will also be subject to the underwriting risk management procedure defined by the Company as part of its risk management policy.
  • The formalisation of the policy is the first process the company carries out with the new policyholder. Therefore, the information signed in the insurance contracts must be transparent and include the scope of the cover and guarantees covered by it.
  • The policy application form must be filled in truthfully, and the Issuer and the policyholder must verify all the data and answers required because they are used as the basis for the underwriting decision.
  • Formal aspects are essential for the company to adequately safeguard its rights and interests in the future.
  • The general interests of the Company must be observed at all times, and non-detrimental decisions must be taken after an overall analysis of each transaction.
  • The acceptance of exceptions must comply with the Company’s powers, authorisations and limits map, and must be justified in the file.
  • General Management will have to resolve any conflicts of interest between the Commercial Department and the Underwriting Department.

Claims Policy

INTRODUCTION

Benefits are the form in which the commitments which are the object of the insurer's activity are materialised. They are the ultimate object of insurance activity.

In the case of claims, the benefits policy is aimed at ensuring:

  • That the benefits are provided or paid in accordance with the technical structure and obligations undertaken in the insurance contracts in force.
  • That the benefits are dealt with using an excellent service and, if applicable, payment is made in the form, term, amount and to whom it may concern as established in the contract.
  • That the compensation policy shall be subject to the provisions of current legislation on insurance and/or to the general conditions of the policies.
  • Policyholders’ and insured persons’ data must be up to date, accurate and good quality.

BASIC PRINCIPLES OF THE CLAIMS POLICY:

Meridiano's claim benefit policy has the following basic principles:

  • The Company will pay for the covered benefits based on the provisions of current contracts.
  • Claims must be dealt with/paid for with sufficient speed. The utmost diligence will be applied in obtaining the information and documentation necessary to deal with the claim, in making the corresponding payments and in providing the insured service itself.
  • The information given to the policyholder/insured party regarding the management of claims shall be truthful in all cases.
  • The policyholder/insured party has the right to complete advice on the claim and the process following its admission.
  • The company must adapt its procedures at all times to ensure that the claim is resolved as swiftly as possible for the beneficiaries.
  • The acceptance of exceptions must comply with the Company’s powers, authorisations and limits map, and must be justified in the file.
  • A complaint procedure is available to customers if they are not satisfied with the service or payment made.
  • The general interests of the Company must be observed at all times, and non-detrimental decisions must be taken after an overall analysis of each transaction.
  • The claims declared with insurance cover will be settled according to the limits established in each of the contracts for each of the guarantees and/or coverage.
  • General Management will have to resolve any conflicts of interest between the Commercial Department and the Claims Department.

Policyholder Assistance Policy

POLICYHOLDER ASSISTANCE POLICY:

  • The Company must always be ready to assist the insured party when a claim occurs. Smooth communications with the insured party are required when processing a claim.
  • First-rate suppliers must be available to guarantee the provision of the insured service, periodically evaluating the quality offered by them and making the necessary changes.
  • Insofar as it is possible, the customer must have a positive experience when processing claims and in resolving any possible problems which may arise in the process.

Financial Investments Policy

INTRODUCTION

This document has been prepared with the aim of establishing the financial investment policy under Directive 2009/138/EC of the European Parliament and of the Council of 25 November 2009 on the taking-up and pursuit of the business of Insurance and Reinsurance (hereinafter, Solvency II), specifically in accordance with the provisions of Articles 44 and 132 to 134 of Solvency II, and in accordance with the regulatory framework issued by the Ministry of Economy and Finance, which, through the Regulation on the Organisation and Supervision of Private Insurance (hereinafter, ROSSP), approved by Royal Decree 2486/1998, of November 8, and subsequently amended by Royal Decree 239/2007, of February 16, in its Article 25, includes the requirements on the control of the investment policy that are used as the general legal framework for the contents of this document.

The Administrative Body of Meridiano is responsible for deciding upon and approving the company's financial investment policy.

PRINCIPLES ON STRATEGY IN MANAGEMENT AND CONTROL OF RISKS IN INVESTMENTS:

For the introduction above, the Administrative Body has set out the following guidelines or principles which form the general structure of the investment policy:

  • The financial investments in Meridiano's portfolio, as a general principle, will be subject to the provisions of the ROSSP of 1998, the Solvency II Directive and other regulations applicable to the management of financial investments. The Administrative Body must expressly authorise any other investments that are not included within these parameters.
  • The Administrative Body expressly prohibits investment in derivative instruments or structured financial assets.
  • Only assets and rights issued by entities with a registered office in a European Union member country may be materialised. Subject to prior authorisation by the Administrative Body, investments may be made in the other countries belonging to the Organisation for Economic Cooperation and Development (OECD). These assets should also be subject to the rules on the organisation, discipline and trading of regulated markets within the OECD.
  • The minimum annual return required of the financial investment portfolio must be equal to or higher than the technical interest rate set out in the technical bases of the policies, and at least be higher than the maximum interest rate to be used in calculating the life insurance provision published annually by Directorate General of Insurance and Pension Funds for the portfolio affected by deaths.
  • All the investments must be formalised appropriately, maintaining at all times control over the ownership and deposit of the same.
  • The Group's financial department is responsible for managing financial investments on the basis of the policies set out, always within the limits and with the authorisations established.
  • Proper reporting systems must be implemented as a measure of compliance and adequate control. The Meridiano Administrative Body will be informed annually of the state of the investment portfolio and the target portfolio to be reached based on the expected behaviour of the liabilities, the markets’ performance and the identified risks, and other questions.
  • Investments will be valued periodically in accordance with the criteria recognised in the market and approved by the auditors.
  • The Administrative Body must approve of the granting of loans and the provision of guarantees on assets.
  • At least once every two years, the composition of the portfolio will be analysed and restructured, if necessary, based on the investment risk management strategy.
  • In general, efforts will be made to optimise the capital requirements arising from the risks associated with financial investments.
  • Risks associated with Meridiano's financial investments are managed to establish the necessary mechanisms to control exposure to them and develop measures to mitigate their impact.
  • The Company has identified the following risks of financial instruments, and manages them according to the details below:

Credit risk:

The guidelines established in the investment policy are prudent, overweighting positions in financial instruments issued by public bodies and entities of recognised solvency belonging to OECD member states.

Another aim to be pursued with the current policy is to have adequate diversification about issuing entities.

For investments in fixed-income and equity securities, diversification criteria by business sector and maximum risk limits per issuer must be applied about the total amount of technical provisions.

Investment management decisions must be aimed at maintaining a high credit quality in the Meridiano portfolio.

The Company will analyse the maximum possible loss on the increase in default levels on a recurring basis using a methodology based on the S&P or similar matrix or similar ones.

Liquidity risk:

Fixed-income and equity securities in which it invests must be traded mainly on the secondary markets on which it is listed.

Information relating to cash forecasts based on the investment plan and the company's current business is taken into account to have an excellent level of liquidity and in light of other profitability criteria.

Market risk:

The main indicators used to measure this risk are modified duration, for the bond portfolio, and the volatility indices at different time horizons for equities.

Market conditions and risks permitting, the duration of the fixed-income portfolio should be as close as possible to the length of the associated liabilities.

For the purposes of market risk, investments should be materialised in a way that is correlated with the representative indexes in which they are listed, seeking securities with a recognised dividend distribution policy that provides Meridiano with an adequate return in line with the exposure to the risk admitted.

Invariably, the quantitative limits on assets and exposures, including off-balance sheet exposures, that must be created to help the company achieve the level of security, quality, liquidity, profitability and availability that it wishes to attain for its portfolio, as set out in this policy, shall be reviewed periodically and shall form part of the investment process as an annex thereto.

The Internal Control and Risk Management Committee is the body responsible for supervising and reporting to the Administrative Body in compliance with the investment policy and risk control under the provisions of article 110 bis of the ROSSP.

ASV Group Occupational Hazard Prevention Policy

OCCUPATIONAL HAZARD PREVENTION POLICY:

ASV Group defines its “Occupational Hazard Prevention Policy” based on the fundamental principle of protecting the life, integrity and health of all workers, both its own and those of its partners and suppliers.

The Occupational Hazard Prevention Policy considers the following aspects:

1. Integration of occupational risk prevention in the organisation and execution of productive activities.

2. Organisation of adequate human and technical resources for occupational hazard prevention in the Group.

3. Assessment of the risks present in the professional activities, to eliminate such risks, and failing that, to adopt the prevention or protection measures to control them.

4. Planning of preventive actions to avoid or control risks by establishing deadlines, responsibilities, means, methods and costs.

5. Training and information for employees on the policy, objectives and risks arising from their work and on their prevention and protection measures.

6. Regularly monitoring of the health status of employees according to the risks of their job position.

7. Provision of adequate work equipment to ensure that the work is carried out safely.

8. Analysis of emergency situations to take the necessary measures for first aid, fire-fighting and evacuation of workers.

9. Coordination of business activities with service providers and customers visiting our facilities.

10. Control of preventive effectiveness through the review of working conditions.

ASV Group Advertising, Corporate Information and Public Relations Policy

GENERAL CHARACTERISTICS OF MARKETING POLICIES:

To be used as a guide or orientation to Marketing strategies, tactics and actions

To be aligned with the Strategic Plan.

To be related to the values of the Group, to complement and reinforce them.

ADVERTISING, CORPORATE INFORMATION AND PUBLIC RELATIONS POLICY:

Advertising:

  • Advertising provided shall not discriminate on the basis of sex, religion or ethnic origin.
  • Advertising will be carried out in accordance with the marketing plan, which in turn will be aligned with the strategic plan of the Organisation.
  • Advertising will be targeted at the general market or a target audience, but will never denigrate other segments of the population.
  • There will be no misleading or deceptive advertising that could create a sense that we might be failing to fulfil our commitments to our customers.
  • There will be no unfair advertising, either against substitute products or competitors.
  • Advertising will primarily seek to enhance the high-quality image of the products and/or increase the visibility of the different brands within the Group.
  • No allusions should be made to any dramatic consequences a person may face from not acquiring our products, such as the feeling of fear or helplessness in any given situation.
  • The advertising provided shall not use superstitious arguments or arguments which fail to meet health or environmental standards, nor explicit scenes of sexual or violent contento.
  • As a general rule, no advertising or merchandising elements will be bought from companies owned by or linked to the company's employees and their families, unless the Organisation clearly stands to benefit.
  • The legislation in force in each country regarding advertising regulations, in addition to related laws authorising advertising to be stored in the company's databases (for example, the Personal Data Protection Law in Spain), will always be fulfilled

Corporate Information:

Corporate Information is defined as all the information published about the Organisation regardless of the medium used. Thus, corporate information will be considered to be, for example, a Press Release issued on the publication of invoicing data, an article on a product or a comparison of rates between our product and our competitors.

The corporate information to be published will always be “accurate” and rigorously prepared. The necessary departments will be asked to assist in creating and cross-checking this information. The corporate information will always be expressed using “modest” claims, and the company will not falsely claim to be market leaders, although it does not need to conceal its strong points either. We will attempt to use Corporate Communication to enhance the image of the quality of our Organisation, regarding Image, and of our products. The quality of the products and services will be a basic goal, since it will allow us to reward our clients, in those moments when they need it (if a claim happens) for the trust they have placed in us.

In corporate communications, we will always remember that the group contains different economic activities which the Communication must be aligned with, with their particular characteristics.

The corporate information will not contain comparisons with our competitors or their products intended to detract from them.

Public Relations:

Public Relations will be carried out on the basis of safeguarding the commitments towards our clients and the privacy of their data, as well as our commitment towards forging trusting, stable and solid bonds with our customers.

The relationship with the Organisation will be established through fulfilling basic ethical criteria and promoting the values of the Family, Environment care and compliance with Human Rights. The relationship with our Competitors will be based on the criteria of respect, humility and sincerity.

The Code of Conduct of the Organisation will always be respected.

ASV Group People Management Policy

At Grupo ASV we know that people are the basis for success and future growth. Therefore, we want to have employees who are trained, motivated and involved with the company's culture and project. Hence, the following People Management principles are used:

  • Attracting, choosing and retaining people with the qualities and skills necessary to meet the strategic objectives and get behind the values of the ASV Group.
  • Recruiting people systematically and effectively, making use of good recruitment practices in this area.
  • Helping new employees to settle in and be integrated within the organisation.
  • Encouraging internal promotion. Giving priority to internal promotion as far as possible, based on the values of performance, professional skills, development potential and commitment to both the values and the business project.
  • Investing in improving our teams’ professional and management skills.
  • Regularly assessing all employees performance with the aim of aligning their activity with the company's objectives and identifying opportunities for their professional development.
  • Competitive and fair pay, recognising each employee’s contribution and level of performance.
  • Developing an organisational culture focused on the team, the customer and a passionate approach to work, to promote a leadership style to help make this culture a reality.

ASV Group Remuneration Policy

The remuneration policy of ASV Group is governed by the Principles of Uniformity and Coherence

Uniformity means that there are no major differences between members of the same group or professional category. ASV Group sees this uniformity from the perspective of fairness, not equality.

Employees who do not perform management and responsibility functions are subject to the salary tables included in each of the applicable collective bargaining agreements. The rest of the people in the Organisation are paid according to the level of management and responsibility of their position. However, employees who show their commitment to ASV Group can be rewarded with the variable remuneration policies that can be put in place for each line of business.

Coherence for ASV Group means giving a leading role in all jobs to pay based on results achieved. The major challenge for people in charge of people management lies in identifying the right mix of fixed and variable remuneration.

ASV Group Environmental Policy

SCOPE:

This environmental policy applies to the entire organisation and is implemented with the utmost stringency in those centres that have a certified environmental management system (ISO 14001), as they necessarily have goals to reduce the impact of the activity on the environment and must comply strictly with all environmental legislation and regulations.

RESPONSIBILITIES:

The Operations Department is responsible for compliance with environmental legislation and for reducing the environmental footprint of the ASV Group's activity.

To this end, the Operations Department defines the master plan for reducing the environmental impact for at least three years. It proposes measures to reduce electricity, water, diesel, natural gas and propane consumption, both for new openings and for existing installations and fleet.

The Operations department is also responsible for raising awareness in ASV Group employees about how our activity impacts on the environment and how good environmental habits contribute to minimising that impact. It develops and communicates the necessary good practice guides at all times aimed at achieving this goal.

The General Management of the ASV Group aims for this policy to be divulged, understood and shared by all employees and that it be made available to the general public.

POLICY:

The Environment Policy is the framework within which the activities of the ASV Group are carried out, and is based on the following principles:

  • Compliance with applicable environmental legislation, with particular emphasis on air, water, waste and noise laws, to ensure that activities are carried out in accordance with these requirements and others that the ASV Group can subscribe to.
  • Continuous improvement in pollution prevention systems.
  • We are aware of how our activities impact on the environment and health due to the use of resources in our facilities, such as gas, electricity, water and diesel oil, the waste generated (both non-hazardous and hazardous waste), and the possible effects on the atmosphere arising from our business activities. Hence, we have developed pollution prevention and control procedures, both during the normal development of activities and in the event of accidents, and we promote the use of the best available techniques (BAT) from an environmental standpoint.
  • Compliance with the environmental targets set and regular internal and external audits of certified environmental management systems.

ASV Group Accounting Policy

INTRODUCTION:

This document sets out the accounting policy defined by the Group's directors applicable to the ASV Group and its component companies.

The main activity carried out by the Accounting Department, integrated into the Finance Department, is to carry out all those actions necessary to prepare the financial statements that, in compliance with the applicable regulations, reflect the real economic and financial situation of the companies that make up the ASV Group.

The Finance Department reports directly to the Chief Executive Officer. This department is responsible for carrying out the following tasks:

  • Organising, managing and controlling the accounting system. It must establish common accounting criteria and other matters.
  • Registering economic facts in the accounts.
  • Controlling cash flow and its correct accounting.
  • Perform bank reconciliations and other controls associated with accounting processes.
  • Controlling and managing accounts receivable and payable.
  • Carrying out the closing of accounts, issuing the financial statements monthly and the annual financial statements every year.
  • Preparing and presenting financial and economic reports to the various external and internal stakeholders.
  • Preparing and submitting the documentation relating to the taxes to which the ASV Group is subject.
  • Overseeing compliance with external and internal accounting and tax regulations.
  • Filing and storing of the supporting documentation of the accounting records.

PURPOSES TO BE ACHIEVED IN ACCOUNTING MANAGEMENT:

  • Prepare and provide reliable information to the market on the economic and financial situation of the companies comprising the ASV Group and the consolidated Group.
  • Draw up and provide accounting-financial information to the Management for it to plan its management and make decisions.

BASIC PRINCIPLES WHICH APPLY TO ACCOUNTING MANAGEMENT:

All the financial information of the ASV Group must be gathered in accordance with the guidelines established in the accounting plans and other legislation in force at all times and applicable to the ASV Group companies.

  • There must be a record/supporting documentation of accounting entries.
  • There must be a computerised accounting management system adapted to the needs of the ASV Group to ensure that information is consistent and uniform.
  • All necessary controls should be carried out to ensure the integrity and correct valuation of all information managed in the accounting process.
  • The principles and procedures applied to the various Group companies must, as far as possible and whenever permitted by applicable law, be common.

Directors and Key Personnel Suitability Policy

OBJECT AND LEGAL FRAMEWORK:

The purpose of this document is for this Administrative Body (AB) to establish the Policy on the Suitability of Directors and Key Personnel of Meridiano (the Company). The Policy defines the procedures that will guarantee that all persons who effectively manage the Company or perform key meet fit and proper requirements.

Being fit is defined as an adequate professional qualification, competence and experience that is consistent with healthy and prudent management.

Being proper is defined as the good reputation and integrity of the people who run the Company.

The present policy is defined under the current legal framework of insurance activity, taking into account the following regulations, articles and guidelines:

  • Directive 2009/138/EC, Article 42 - Fit and proper requirements for persons who effectively run the undertaking or have other key functions.
  • Delegated Regulation 2015/35/EC, which implements Directive 2009/138/EC, in particular Articles 258(1)(c) and 258(1)(d) and 273-Fit and Proper Requirements.
  • The EIOPA Guidelines on the EIOPA-CP-13/08 Governance System, in particular, Guidelines:
    • 11-Fit Requirements.
    • 12-Proper Requirements.
    • 13-Fit and proper policies and procedures.

This policy applies to the members of the AB, Senior Management and the people who manage the Key Risk Management, Actuarial, Compliance and Internal Audit Functions. In other words, it will apply to all persons who effectively manage the Company.

FIT AND PROPER REQUIREMENTS:

This Policy on the Suitability of Directors and Key Personnel will ensure the fitness of the persons who effectively manage the Company and of those who perform the Key Functions, including the members of the AB, and, taking into account the individual obligations of each person, will ensure an adequate diversity of qualifications, knowledge and experience.

FIT AND PROPER REQUIREMENTS OF AB MEMBERS:

AB members must collectively have the necessary qualifications, competence, aptitudes and professional experience in the relevant areas of activity to manage and supervise the Company effectively and professionally, and to perform the tasks assigned to them on a case-by-case basis. The company will ensure that the members of the AB and the senior management collectively demonstrate appropriate qualifications, experience and knowledge at least on insurance and financial markets, business strategy and business model, governance system, financial and actuarial analysis and knowledge of the regulatory framework.

COMMUNICATION TO THE SUPERVISORY BODY:

The Company shall notify the Supervisory Authority promptly of information concerning all persons who effectively direct the business or are responsible for other functions which are essential for assessing the fit and proper nature of such persons.

The supervisory authorities shall also be notified of any change in the identity of the persons who effectively direct the company or are responsible for other key functions, together with all the information necessary to assess whether any new persons appointed to the company's management meet fit and proper requirements.

Likewise, the Supervisory Authority shall be informed if any of the persons performing a Key Function have been replaced because they no longer comply with the aforementioned fit and proper requirements.

FIT AND PROPER ASSESSMENT:

The Company has defined the following procedure to assess the fit and proper requirements of the persons who manage the Bank and perform key functions, both at the time they are appointed to a specific position and during the discharge of their duties.

The assessment procedure shall provide for an initial review at the time of appointment to the position, as well as a periodic review every five years of the following factors:

  • The assessment of a person's fitness, which shall include an assessment of his or her formal and professional qualifications, knowledge and experience relevant to the insurance sector, other financial sectors or other activities. It shall take into account the duties assigned to that person and, where appropriate, his or her professional experience in the fields of insurance, finance, accounting, actuarial and management.
  • An assessment of a person's proper requirements shall cover his or her honesty and financial solvency based on reliable information concerning his or her reputation, personal conduct and professional conduct, including any criminal, financial and supervisory aspects relevant to the assessment.

REASSESSMENT OF FIT AND PROPER REQUIREMENTS:

If there is any sign to suggest any of the members of the AB or the Senior Management does not meet any of the fit and proper requirements, then a new process to assess such fit and proper requirements should be initiated.

EXTERNALISATION OF KEY FUNCTIONS:

If Key Functions are externalised, the company will ensure that the persons employed by the service providers meet the fit and proper requirements..

The person appointed by the Company that will have general responsibility for the externalised key function must meet the fit and proper requirements, as set out in the Activities and/or Key Functions Externalisation Policy.

RESPONSIBILITIES:

The Legal Compliance Officer will verify compliance with this policy.

REPORTS AND CONTINUOUS CHECKING:

The Compliance Officer shall prepare an Annual Report on the degree of compliance with this policy.

Internal Audit, within its scope of action, will assess the different controls established to verify compliance with this policy and will review the Report on the Suitability of Directors and Key Personnel.

POLICY REVIEW AND AMENDMENT:

This policy will be reviewed at least annually by the Legal Compliance Officer.

The AB will have to approve of any changes to this document.

Corporate Social Responsibility Policy

SCOPE

The policies expressed in this section apply to the Corporate Social Responsibility actions carried out by Grupo ASV Servicios Funerarios and Seguros Meridiano, as well as those which, together, may be considered as part of the group of companies (the ASV Group).

All actions that the ASV Group companies carry out for the benefit of the Company, beyond those intrinsically contained in their usual business, are considered to be Corporate Social Responsibility.

OBJECT OF CORPORATE SOCIAL RESPONSIBILITY

The purpose of the ASV Group's Corporate Social Responsibility is to promote and divulge the Organisation's responsible behaviour towards its stakeholders.

CORPORATE SOCIAL RESPONSIBILITY POLICY:

CCorporate Social Responsibility is governed by management guidelines, which any branch of the ASV Group will use to ensure it can carry out and promote socially responsible behaviour, regardless of the way in which the business activity is performed, in alignment with the company's corporate strategy, and with its Mission, Vision and Values.

Guidelines:

The main guidelines of the Corporate Social Responsibility Policy are described as follows:

  • To accompany and support all the families who place their trust in the ASV Group, genuinely pursuing their peace of mind and other benefits.
  • To play an active role in the Company, promoting relevant initiatives in our spheres of influence.
  • To encourage the sense of pride and engagement of our employees through the purpose pursued with the social actions carried out by the Group

Execution and Control:

The implementation of corporate social responsibility actions will be based on the Corporate Social Responsibility Plan, drawn up by the marketing department. This Plan will comprise initiatives and actions aimed at forging bonds with communities, institutions, people and the environment. All actions in this plan will abide by the policy expressed in this document.