-
2-25
Risk associated with inadequate design and implementation of solutions in the area of crime prevention and failure to implement them correctly
The PZU Group has special security procedures in place in the area of counteracting crime. The PZU Group designates a single owner of the insurance fraud prevention, who is responsible for the entire process, monitoring its quality and effectiveness, as well as for adhering to the prevailing procedures.
Security Procedure in counteracting crime in PZU SA and PZU Życie SA.
PZU and PZU Życie have in place the Fraud prevention Security Procedure. The procedure includes:
- disclosing security incidents and insurance fraud committed to the detriment of the company;
- prevention and prophylactic activities;
- security risk management.
The area of counteracting crime contains the Team for Insurance Fraud Prevention (ZPPU) and the Team for Security Incident Management (ZZIB). The Team for Insurance Fraud Prevention fulfills tasks in the area of analyses of fraud prevention and operational activities undertaken to investigate the actual course of a given fraud event. The Team for Security Incident Management fulfills tasks in the area of counteracting in-house crime. In discharging these tasks both Teams are supported by the Fraud Management System (FMS) – the most advanced system on the Polish market that profiles internal and external fraud, supports their analysis and provides for smooth and effective case workflow.
FMS GRI System
The Fraud Management System (FMS), which typifies internal and external fraud, operates in the area of claims arising within the insurance groups defined in Section II, as well as within PZU’s internal processes for the substantive and technical handling of claims and benefits. It is a comprehensive IT tool based on SAS solutions, providing a hybrid approach by using multiple combined techniques in operational and management processes. The source data are insurance policies, claims, subject and object data and data from external sources (OI UFG).
The main benefits of FMS at PZU:
- Reduction of losses from improper payments by being able to effectively detect fraud before compensation and benefits are paid, including automatic typing of fraud at the time of claim registration;
- Reduction of the rate of so-called “false typing” and saving resources needed to verify misidentified cases;
- Improved efficiency of investigators and analysts due to the use of case management tools (WorkFlow).
- Monitoring the quality and effectiveness of the fraud risk management process based on the reporting of key assessment indicators.
| Number of insurance crime incidents handed over to law enforcement agencies | 2021 | 2022 |
| PZU Group, including: | 250 | 190 |
| – PZU | 184 | 136 |
| – PZU Życie | 20 | 13 |
Regulations in subsidiaries
In TUW PZUW, the “Procedure for fighting crime in TUW Polski Zakład Ubezpieczeń Wzajemnych” formalizes the process of identification,
management and protection of the company against crime, in particular insurance crime and fraud.
TFI PZU has implemented “Rules and Regulations for Counteracting and Disclosing Manipulations in Financial Instruments in the Activity of
Towarzystwo Funduszy Inwestycyjnych PZU SA”. The “Procedure for Counteracting Money Laundering and Terrorism Financing” is also in force there. It is used in the company’s internal relations and in external relations to which the company is a party. The “Code of Best Practices of Institutional Investors” prepared and approved by the Chamber of Fund and Asset Management is also in force in the company. This code provides the company with a great deal of support in defining the rules, moral and ethical standards and due diligence levels in TFI PZU’s relationships with other institutional investors, its clients and issuers of financial instruments. TFI PZU’s adoption of this code also attests to the application of best investment practices in the company.
Regulations in subsidiaries – banks
Alior Bank has a centralized process for managing credit fraud risk that includes providing opinions on new products and processes, automated anti-fraud strategies, central reference databases, issuing opinions against granted financings, creating guidelines for bankers and analysts to recognize fraud, and monitoring active banking products.
Bank Pekao has in place a Fraud Management Process regulation which introduces the Official Instructions entitled Fraud Management Process in Bank Polska Kasa Opieki. The Official Instructions define the following:
- what a fraud is and what fraud categories may affect the bank in the course of its activity;
- who (which organizational unit in the bank and which employee of the unit) is obligated to take action in the event of fraud;
- how specifically fraud should be prevented (catalog of activities to be performed).
In addition, there are defined obligations and powers of the Financial Security Office in the Bank Pekao’s Security Department, which performs the tasks associated with central coordination of prevention of financial crime in the bank.
Management – The Fraud Management Process and the Official Instruction imposed on each bank employee the obligations and powers associated with prevention of financial crime threatening the organization and the bank’s clients.