Risk management
G4-2Liberty Seguros is exposed to certain key risks that may affect its strategic and financial objectives to a greater or lesser extent, as follows:
- Insurance risk: the Company has specific acceptance and pricing criteria for each line of business, thus minimizing anti-selection risk and ensuring appropriate levels of competitiveness and profitability for the risks carried. Appropriate pricing for the main lines of business is ensured by the Actuarial Department and underwriting units, which also develop pricing models and policies.
- Market and liquidity risks: in order to mitigate financial risks associated with its investment portfolio, the Company actively manages assets and liabilities with a conservative asset allocation strategy favoring mostly government bonds and high liquidity private securities.
- Credit risk: Liberty’s strict credit risk policy for acquisitions of financial assets is based on the criterion of investing in sound institutions in the “AA” - “B +” risk rating range.
- Operational risk: the risk management structure takes an integrated view of operational risks in order to identify, assess, treat and monitor them. The effectiveness is objectively assessed by the Company’s Internal Audit.
Liberty manages risks both qualitatively and quantitatively by fulfilling the capital requirement criteria issued by the National Council for Private Insurance (CNSP in Portuguese) and the Private Insurance Superintendence (SUSEP in Portuguese, an entity attached to the Ministry of Finance). Liberty’s strategy consists of maximizing the Company’s capital by diversifying operations across different branches of insurance and sales channels and by continuously improving pricing processes.
Compliance
Liberty Seguros’ structured Compliance Program includes training and communication material to educate staff and foster compliance principles for all employees. The program follows Liberty Mutual’s Compliance guidelines and is constantly updated to align with business requirements and Brazilian legislation such as the Anti-Corruption Law or the Clean Company Law of 2013.
Since 2013, the Company’s Compliance area has been working to minimize ethical risks or any legal issues by maintaining internal anti-money laundering and anti-corruption controls and rules, among other initiatives. Acceptance processes for risks and claims are mapped in accordance with the regulations, rules and legal provisions defined by SUSEP and CNSP and by applicable legislation. Annual updates are processed and all risks detected are monitored on a quarterly basis.
The Company also has anti-corruption and due-diligence procedures in place for service providers. The process includes an assessment of third party risks and adoption of procedures depending on their risk ratings.

Code of Ethics and Anti-Corruption Policy G4-56
As the Company’s key compliance document, Liberty Seguros’ Code of Ethics and Corporate Conduct establishes honesty, integrity and “doing the right thing” as the Company’s guiding principles. In this respect, employees are required to fill out a questionnaire every year to ensure their awareness of the document’s guidelines. The questionnaire also provides an opportunity to report any conflict of interest. The findings that emerge from this process are analyzed by the Ethics Committee, which then issues recommendations. Reports of this nature and other ethical complaints related to situations involving violation of the code of ethics may also be reported by telephone or e-mail through the Company’s confidential Compliance Helpline channel, which is managed by Liberty Mutual in the United States, but is also equipped to provide responses in Portuguese.
There are also mandatory training events to underline Liberty Mutual’s anti-corruption policy guidelines and ensure that employees are aware of them. Additionally, in the course of 2016, the Company ran global communication campaigns for compliance that focused on the Code of Ethics, customer data privacy, and the receipt of presents or gifts.