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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. PZU and PZU Życie have in place the Crime Prevention Security Procedure. It encompasses the following: • 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 Crime 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 Security Incident Management Team performs tasks in the area of violations of internal procedures and incidents that may be crimes committed by PZU employees or associates. In discharging these tasks both Teams are supported by the Fraud Management System (FMS) – the most advanced system on the Polish market that profiles potential fraud, supports its analysis and provides for smooth and effective case workflow.
FMS System
The Fraud Management System (FMS), which profiles internal and external fraud, operates in the area of claims arising within personal and property insurance, 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 (UFG information center).
- reduction of losses from undue payments thanks to effective detection of fraud before compensation and benefits are paid, including automatic profiling of fraud at the time of claim registration;
- reduction of the rate of so-called “false profiling” 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 | 2022 | 2023 |
|---|---|---|
| PZU Group, including: | 190 | 161 |
| PZU | 136 | 113 |
| PZU Życie | 13 | 10 |
Regulations in selected subsidiaries
In TUW PZUW, the “Procedure for preventing crime in TUW Polski Zakład Ubezpieczeń Wzajemnych” formalizes the process of the company’s identification, management of and protection against crime, in particular insurance crime and fraud.
TFI PZU has implemented “Rules and Regulations for Preventing and Disclosing Manipulations in Financial Instruments in the Activity of Towarzystwo Funduszy Inwestycyjnych PZU SA”. 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 the code also attests to the application of best investment practices in the company.
The Baltic companies have „Financial Crime Prevention / Crime Risk Management Policies” in place. They specify the company’s minimum requirements for managing risks related to external and internal fraud and other financial crimes against the company, as well as money laundering and terrorist financing
Regulations in subsidiaries – banks
Alior Bank has an Alior Bank Group Security Policy in place. It defines the basic principles of the security system at Alior Bank and provides the basis for developing security policies, detailed requirements, processes and procedures. It is a document that overrides the bank’s other internal regulations related to security. The documents apply to all persons employed by the bank, regardless of the basis of employment, as well as apply to employees of third parties cooperating with the bank to the extent specified in the contracts.
The 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 financing provided, 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;
- which organizational unit in the bank and which employee of the unit is required to take action in the event of fraud;
- how specifically fraud should be prevented (catalog of activities to be performed).
The Fraud Management Process and the Official Instructions impose on each bank employee the obligations and powers associated with prevention of financial crime threatening the organization and the bank’s clients.