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					FINAL                                                                                          Preliminary considerations                       1


According to § 1-4 of the Helsinki Protocol, this "Protocol must be seen as an enabling protocol. The competent supervisory authorities
take upon themselves to put in all reasonable efforts to co-operate in order to exercise the supplementary supervision.” The Helsinki
Protocol contains only very general principles that were developed in more precise recommendations in the "Guidelines on CoCos" and
the "Guidelines on Information Exchange between Lead Supervisors and other competent authorities". The Review Panel,
therefore, assesses the compliance with these 2 Guidelines.
Following the ECOFIN Roadmap of 4 December 2007 as well as the Council Conclusions on the EU supervisory framework and financial
stability arrangements of 14 May 2008, CEBS and CEIOPS drafted 10 Common Principles for Colleges of Supervisors (CEIOPS-SEC-
54/08/CEBS 2008 124) that were sent to the political level in June 2008 and published on the CEIOPS website end of January 2009.



The 10 Common Principles (the Principles) are an addition to the guidelines under the Helsinki protocol. CEIOPS anticipates revising
the guidelines in 2009 in order to incorporate these additions from the Principles. These additions, however, will not result in major
changes in the guidelines;only some requirements will change from “may” to “shall”. The Review panel will assess both the
implementation of the Helsinki guidelines as well as the Principles. Given the recent date of publication of the 10 Common Principles not all
CoCos have yet finalised the implementation of the 10 Principles. CEIOPS' Members Meeting of March 2009 decided that benchmarking of
the compliance will be done on the basis of the 10 Common Principles, given the current focus on the organisation of supervisory colleges

Regarding the Principles the wording “Colleges of Supervisors” refers for the purpose of this review to “Coordination Committees”.

Parallel to this process, the Principles as well as the Helsinki guidelines form the basis of the CEIOPS advice for the Level 2 implementing
measures on Colleges of Supervisors under Solvency II. This advice will be published for consultation in July this year.


In view of the proportionality principle please make clear in your comments the context in which your answer is provided.

Answers should be provided for insurance groups listed on the Helsinki List.



MS: Member State
MSCA: Member State Competent Authority
CA: Competent Authority
LS: Lead Supervisor
CoCos: Coordination Committees




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FINAL                                                                                                                                Guidelines for replying



Each question should be answered by Y, N, NA or NC:
   Y: if the requirement is in general complied with for actual cases (to be explained in COMMENTS)
   N: if the requirement is in general not complied with for the majority of actual cases (to be explained in COMMENTS)
   NA (NOT APPLICABLE): if the requirement is not relevant for the authority and therefore a case could not occur (to be explained in COMMENTS)
   NC (NO CASES): if there are no actual cases yet or no experience with the respective requirement (to be explained in COMMENTS)


If existing, the national IMPLEMENTING MEASURES* related to the specific protocol requirement should be given:
   - the reference (title, date, ...) and relevant articles of the law, secondary regulation, circulars, ...
   - a link to the website or a copy of the implementing measures should be provided (Please provide these copies as an attachment to your reply
   and indicate clearly to which question they belong)

Each answer should be commented (COMMENTS**), taking following general guidelines into consideration:
   if Y:    Are requirements always complied with? If not, why and what is the % and the number of cases which were not complied with.
   if N:    Why is this requirement not complied with ? Please identify the reasons why and the possible remedies.
   if NA:   Why is this requirement not relevant for your authority ? Please explain why a case could never occur in your jurisdiction.
   if NC:   Why are there no actual cases up till now ? What are your expectations with regard to the emergence of actual cases (how
            many and in what timeframe) ?
   for all: How does your organisational structure (procedures, dedicated team, ...) ensure the compliance of the requirement, whether
            or not an actual case has already occurred ?
   for      In the column 'GUIDANCE FOR COMMENTS' you will find requests for specific comments. Please provide your answer to these
   some: questions in the column 'COMMENTS'. If specific data is requested such as number of cases, an average timing etc.. please provide the
            figures in the columns 'DATA'.

 * See articles 22 to 27 of the Methodology for Peer Review:
   22.If a supervisory provision or practice has been applied, either in full or partially, the CEIOPS Member must provide information on the national
   implementing measures, including policies, procedures and other practices implemented, considering that peer review aims at compliance and
   convergence in practice, not just from a legal perspective.
   23.National implementing measures may include laws (i.e. acts of Parliament) and regulations (i.e. decrees of ministries or rule books of CEIOPS
   Members), guidelines and circulars of CEIOPS Members (provided that non-compliance with these guidelines and circulars should trigger
   enforcement action by the CEIOPS Member concerned), rules of self-regulatory organisations, such as industry associations (where applied by a
   significant part of the industry in a specific Member State and provided that non-compliance with those rules triggers enforcement action by the
   self-regulatory organisation concerned or by the CEIOPS Member), and relevant case law. Internal procedures followed by CEIOPS Members that
   do not trigger enforcement action are also classified as implementing measures for these purposes.

   24.If a national implementing measure is considered by the relevant CEIOPS Member as going beyond the ‘requirements’ of the supervisory
   provision or practice subject to peer review, this fact should be stated.
   25.Any derogation from a national implementing measure or any possibility for issuing a waiver from the ‘requirement’ should be stated explicitly,
   together with the rationale for any such exemption, and should be taken into account in the self-assessment.
   26.If a national implementing measure is not in force but has already been formally adopted, and there is a concrete date of its coming into force
   within a reasonable period of time after the peer review exercise has started, it must be assessed as if it had been in force at the time of the self-
   assessment. The Review Panel will establish what is a ‘reasonable period of time’.
   27.If a national implementing measure relating to the supervisory provision or practice subject to peer review is in the process of being drawn up,
   this fact has to be stated, provided that the implementing measure is already in a concrete stage (e.g. a proposal to Parliament or publication of a
   consultation paper).


** See articles 21 and 28 of the Methodology for Peer Review:
   21.If a supervisory provision or practice is not applicable, the CEIOPS Member must state the reason for its nonapplicability. In such cases, the
   supervisory provision or practice will be classified as ‘not applicable ’.
   28.If a supervisory provision or practice has not been fully applied, the CEIOPS Member must state, at a minimum, the reason for the non-full
   application, and, if applicable, the action taken so far to achieve full application, and the proposed timing of full application.




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FINAL                                                                                                                           Questionnaire HP - Info Xchange                                                                                                                              3



Helsinki Protocol
Guidelines on Information Exchange between lead supervisors and other competent authorities
              Articles                                                  Assessment criteria                                No Questions                                           Guidance for comments                Answers (See guidelines for replying)                                 Benchmarks
              and relevant paragraphs                                                                                                                                                                                  Your reply    Implementing Comments                Fully applied
                                                                                                                                                                                                                                     measures
1.           3. A communication strategy should be developed under the           Regarding the development of a            1   Have you already initiated the development of a Please describe how you define                                     Until now the           if a positive
Communicat auspices of the lead supervisor, in full consultation with other      communication strategy.                       communication strategy for each of the key      "key" groups and please                                            ISP has not             answer to 1 and
ion strategy competent authorities. The strategy should coordinate at a minimum                                                groups of which your authority is lead          provide us with a list of key                                      assumed the             2
             the gathering and the dissemination of information. It should have                                                supervisor?                                     groups in your jurisdiction (See                                   position of lead
             regard to defining by whom and to whom information should be                                                                                                      Annex 1). This list will be                                        supervisor for
             disseminated, be it between other competent authorities and the                                                                                                   treated as confidential and will                                   any cross-
             lead supervisor or bi- or multi-laterally between other competent                                                                                                 hence not be made public).                   NC                    border group.
             authorities. In particular, supervisors should ensure insofar as
             possible under relevant national legislation that:                                                                                                                   If you are not a lead supervisor
             • the lead supervisor has unfettered access to all relevant                                                                                                          for any cross-border group
             information;                                                                                                                                                         please answer "NA: not
             • essential information and, if deemed useful, relevant information                                                                                                  applicable".
             is provided to all supervisors at an appropriate level and
             • no undue limitations are imposed on spontaneous communication                                               2   Have you initiated the development of a            Are you prepared to develop in
             between supervisors.                                                                                              communication strategy for each of the other       the future communication
                                                                                                                               groups?                                            strategies for all the other
              The process may naturally lead to an asymmetric flow of                                                                                                             groups?                                   NC
              information.                                                                                                                                                        Please describe your
                                                                                                                                                                                  preparedness.
              Principle 7: The Colleges of Supervisors provide an efficient
                                                                                      The Colleges of Supervisors shall    3   As a Lead Supervisor have you set a template                                                                                               if a positive
              platform for the gathering and dessimination of relevant or
                                                                                      ensure, subject to confidentiality       or any other standard format to gather                                                                                                     answer to 3 or 4
              essential information in going concern and emergercy situations,                                                                                                                                              NC
                                                                                      provisions, all relevant                 information from host supervisors?
              developing a common understanding of the risk profile of the Group,
                                                                                      information needed for the
              achieving coordination of supervisory review and risk assessment at
                                                                                      supervision of the Group is          4   As a Lead Supervisor have you chosen a case
              Group level as well as establishing supervisory plans for the
                                                                                      collected and disseminated in a          by case approach where the information asked
              mitigation of risks at Group level.
                                                                                      timely manner to the relevant            for, depends on the group?
                                                                                      supervisory authorities, (...)
                                                                                                                                                                                                                            NC




2. Relevant 6. ‘Relevant information,’ is understood to mean information that is      It is not up to the lead supervisor 5    As a Host Supervisor,
information relevant to the performance of another supervisor’s obligations.          to consider which information is         a) Do you consider that the information
            Supervisors in each Coordination Committee should agree on the            relevant or not; According § 4 & 6       disseminated by the Lead Supervisor is
            scope of relevant information to be communicated, and may                 "relevant information" is the            sufficient for performing efficiently your                                                   Y
            consider specifying the content, format, and the manner in which          information which is deemed to           supervision on the subsidiaries incorporated in
            information will be exchanged (e.g. contacts, regular conference          be necessary by the host                 your jurisdictions?
            calls, regular meetings, written agreements etc). Supervisors             supervisor.
            requesting information should state clearly the purpose for which                                                  b) In the positive to question 5 a), do you as                                                                     Whenever specific
                                                                                                                               host MSCA nevertheless request relevant                                                      Y                     information is
            the information is requested. This will help to assess relevance.
                                                                                                                               information for specific needs?                                                                                    needed

              7. The lead supervisor shall provide other competent authorities                                                 c) In the negative to question 5 a), do you as
              with all relevant information. In determining the extent of relevant                                             host supervisor, inform the lead supervisors
              information, the importance of the subsidiaries within the financial                                             about what you consider as relevant                                                          NA
              system of the Member                                                                                             information?
              States where they are authorized should be taken into account. If
                                                                                                                           6   As a Host Supervisor,
              structural changes in a group entail the involvement of new or the
              exclusion of existing supervisors, the lead supervisor will monitor a                                            a) In the positive of 5 b) or 5 c) do you consider As host supervisor do you                                                               if yes to 6 c
              proper handover and an effective continuation of the cooperative                                                 the same information as relevant for all the       motivate your requests to the             N
              process.                                                                                                         groups?                                            lead supervisor according the
                                                                                                                                                                                  specific situation of the insurer:
                                                                                                                               b) In the positive of 5 b) or 5 c) did you chose a                                                                 The information
                                                                                                                                                                                   □ place on the market,                                         requested depends
                                                                                                                               case by case approach where the information
                                                                                                                                                                                   □ financial position of the                                    mainly on the
                                                                                                                               asked for, depends of the group?                                                             Y                     financial position of
                                                                                                                                                                                  group,
                                                                                                                                                                                                                                                  the group and risk
                                                                                                                                                                                   □ risk exposure,                                               exposure.
                                                                                                                                                                                   □ other information
                                                                                                                               c) In the positive of 6 a) or 6 b), do you state   ………………………….)
                                                                                                                               clearly the purpose of the individual request of
                                                                                                                               information?                                                                                 Y


                                                                                                                           7   As a lead supervisor, do you provide the                                                                                                   if yes to 7
                                                                                                                               information the host MSCA considers relevant?                                                NC

                                                                                                                           8   Did the Co-Co agree on the scope of relevant
                                                                                                                               information to be communicated?                                                              Y




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FINAL                                                                                 Questionnaire HP - Info Xchange   4




                                            for programming - please do not touch !
No     Benchmarks                           Y        N      NA       NC
     Partially applied      Not applied


1    if a positive answer   if a negative
     to 1 and a negative    answer to 1
     answer to 2




2




3                           if a negative
                            answer to 3
                            and 4

4




5




6
                            if no to 6 c




7                           if no to 7



8




5a63f0ca-0c1d-4e8d-893e-3555f0b8d72b.xls
FINAL                                                                                                                                Questionnaire HP - Cocos                                                                                                                               5



Helsinki Protocol
Guidelines for Coordination Committees in the Context of Supplementary Supervision as Defined by the Insurance Groups Directive (98/78/EC).
              Articles                                                                  Assessment criteria                 No   Questions                                           Guidance for comments               Answers (See guidelines for replying)                            Benchmarks
              and relevant paragraphs                                                                                                                                                                                    Your reply    Implementing Comments              Fully applied
                                                                                                                                                                                                                                       measures
2.1.          Guideline article 2.1:                                              Each supervisor has to ensure             1    Did you for each undertaking in your jurisdiction                                                                                        if yes
Members of    There is one CoCo for each and every insurance group operating in   that for each undertaking in its               belonging to a group operating in more than one
the CoCo      more than one EEA-country.                                          jurisdiction belonging to a group              EEA -country identify a CoCo?
                                                                                  that is operating in more than
              The CoCo members are representatives of the Insurance               one country a CoCo exists (of                                                                                                                Y
              Supervisory Authorities in the Member States in which the Group     course one expects the
              has undertakings, and would normally be responsible for the day-to- proportionality principle to be
              day supervision of the Group in their state.                        applied).
                                                                                        Each supervisor should be           2    Do you ensure that you are represented in all       Is the representative                                          The representative    if yes
                                                                                                                                                                                                                                                    is responsible for
                                                                                        represented in a CoCo for an             CoCos you should be?                                responsible for the day-to-day
                                                                                                                                                                                                                                                    the day-to-day
                                                                                        undertaking in its jurisdiction                                                              supervision of the undertaking                                 supervision of the
                                                                                        belonging to a group that is                                                                 part of the group?                        Y                    undertaking part of
                                                                                        operating in more than one                                                                                                                                  the group.
                                                                                        Member State.
                                                                                        Each CoCo lead supervisors          3    For all Groups for which you are the lead                                                                                                if yes
                                                                                        should invite the supervisors of         supervisor, did you invite representatives of
                                                                                        all member states in which the           the supervisory authorities from every member                                                NC
                                                                                        Group has undertakings.                  state in which the group has undertakings to be
                                                                                                                                 part of the CoCo?
              Principle 1:                                                              If deemed necessary, supervisors 4       As lead supervisor, did you assess the              Please describe your                                                                 if yes
              The supervisors of the Member States involved in the                      of                                       relevancy of inviting supervisors of branches ?     assessment criteria.
              supervision of any of the relevant activities of a cross-border           systemically relevant branches
              insurance group, banking group or a financial conglomerate,               should be invited to the College.
              hereinafter called a “Group” shall form a “College” (College of           The host supervisors of significant                                                                                                   NC
              supervisors).                                                             branches may be invited to join
                                                                                        the College.


2.2.          Guideline article 2.2:                                                    Where groups are part of a        5      For those cross-border insurance groups where       Please describe how (e.g. info                                                       if yes
Supplement    The IGD states that with regard to financial conglomerates, the           financial conglomerate the lead          you are the lead supervisor and that are part       exchange, invitation to the
ary           CoCo will cooperate with authorities responsible for the supervision      supervisor has to ensure that the        of a financial conglomerate, do you involve the     CoCo meeting, supervisory
supervision   of other financial sectors, in order to ensure more efficient solo-plus   coco cooperates with the                 other supervisors responsible for the supervision   work plan, joint inspections, ..)
              supervision.                                                              authorities responsible for the          of the other sectors in the work of the CoCos?
                                                                                        supervision of the other sectors.
              Principle 2:                                                                                                                                                                                                    NC
              The College of supervisors shall provide an effective and flexible
              permanent forum for cooperation and coordination among the
              authorities responsible for and involved in the supervision of the
              Group. Where appropriate, Colleges may cooperate with other
              authorities.

              Guideline article 2.2.                                                    The organization of a CoCo           6   Are the CoCos in which you participate              What channels are used for the                                 Mainly mail,
              Rather than face-to-face meetings, it may prove sufficient to             should be proportionate to the           proportionate to the organization, nature, scale    exchange of information?                                       telco anda face-
              exchange information by other channels, including the use of the          organization, nature, scale and          and complexity of the insurance group and do        Please tick:                                                   to-face
              telephone conference, video conference, email and letter. The CoCo        complexity of the insurance group        they reflect the activities, risks and legal         □ telco                                                       meetings
              may find it advantageous to arrange face-to-face meetings for more        and to the assessment of the             structure of the group?                              □ videoconference
              complex groups, for an initial meeting, or for extraordinary              groups´ soundness. The CoCo                                                                   □ mail
              circumstance (e.g., crisis)                                               should reflect the activities, risks                                                          □ letter
                                                                                        and the legal structure of the                                                                □ face-to-face meetings                  Y
              Principle 3:                                                              insurance group.
              The organization of the Colleges of Supervisors is proportionate to                                                                                                    In which circumstances are
              the organization, nature, scale and complexity of the Group and to                                                                                                     these used ?
              the assessment of the Group’s soundness, and reflects the
              activities, risks and the legal structure of the Group.


              Principle 9:                                                              Common on-site inspections and 7         Regarding supervisory on-site inspections :
              The Colleges of supervisors shall have on their regular agenda,           joint examinations are important.
                                                                                                                                 a) Are these regularly planned and coordinated                                                                     Not until now,   if yes to a, b,
              planning and coordination of supervisory on-site inspections,
                                                                                                                                 within the CoCo ?                                                                                                  but they are     or c
              including joint supervisory examinations, and the findings of such                                                                                                                                              NC
                                                                                                                                                                                                                                                    starting to be
              visits will be shared by the Group Supervisor/Consolidated
                                                                                                                                                                                                                                                    planned.
              Supervisor/Coordinator with the other supervisors in the College of                                                b) Do these include joint inspections ?             In how many joint inspections                                  The on site
              supervisors according to their respective needs and subject to                                                                                                         did you participate and in what                                inspections that
              confidentiality provisions.                                                                                                                                            capacity (lead/host) ?                                         are being
                                                                                                                                                                                                                              NC                    planned will
                                                                                                                                                                                                                                                    include joint
                                                                                                                                                                                                                                                    inspections.




5a63f0ca-0c1d-4e8d-893e-3555f0b8d72b.xls
              Principle 9:                                                        Common on-site inspections and 7
              The Colleges of supervisors shall have on their regular agenda,     joint examinations are important.
                                                                                                                                                                                                                                                          if yes to a, b,
              planning and coordination of supervisory on-site inspections,
FINAL                                                                                                               Questionnaire HP - Cocos                                                                                                              or c                6
              including joint supervisory examinations, and the findings of such
              visits will be shared by the Group Supervisor/Consolidated
              Supervisor/Coordinator with the other supervisors in the College of
Helsinki Protocol
              supervisors according to their respective needs and subject to
Guidelines for Coordination Committees in the Context of Supplementary Supervision as Defined by the Insurance Groups Directive (98/78/EC).
              confidentiality provisions.
              Articles                                                                 Assessment criteria               No    Questions                                          Guidance for comments           Answers (See guidelines for replying)                     Benchmarks
              and relevant paragraphs                                                                                                                                                                             Your reply    Implementing Comments     Fully applied
                                                                                                                                                                                                                                measures
2.1.          Guideline article 2.1:                                                                                           c) Are findings of such visits shared with other
Members of    There is one CoCo for each and every insurance group operating in                                                supervisors in the CoCo, if needed?                                                     NC
the CoCo      more than one EEA-country.
2.3. Key      Guideline article 2.3:                                                   A CoCo should appoint a Lead      8     Did the CoCos in which you participate appoint a
              The CoCo members are representatives of the Insurance
coordinator   It may be useful for the CoCo to agree on one or more supervisors        Supervisor that coordinates the         Lead Supervisor?                                                                         Y
              Supervisory Authorities in the Member States in which the Group
and lead      acting as Key Coordinator(s), whose role will be to coordinate the       activities of the CoCo and
              has undertakings, and would normally be responsible for the day-to-
supervisors   activities necessary to carry out the supplementary supervision.         organizes and chairs the CoCo     9     As a lead supervisor did you                                                                                               if yes to a and
              day supervision of the Group in their state.
              The CoCo may decide that a Lead Supervisor shall have a key role in      meeting.                                                                                                                                                           b
              pulling together relevant information, analyzing it, and                                                         a) initiate the cooperation process ?
              disseminating his or her conclusions to the other members of the                                                                                                                                         NC
              CoCo.
                                                                                                                               b) chair the meeting of the CoCo ?
            Principle 6:
            The Group Supervisor (for an Insurance Group) or Consolidating
            Supervisor (for a Banking Group) or the Coordinator (for a Financial
            Conglomerate), shall initiate the cooperation process, chair the                                                                                                                                           NC
            meeting of the College of supervisors, and be responsible for
            designing a work programme for the supervision of the Group,
            which shall be approved by the College of Supervisors.
3.          Guideline article 3:                                                       The lead supervisor is responsible 10   Q1: For all CoCos where you are the lead                                                                                   if yes to 10.1
Preparation Prior to the meeting, the Lead Supervisor/Key Coordinator should           for (1) sending out a statement of      supervisor, do you send a statement of the                                                                                 and 10.2
for         set out a clear statement of the expected outcomes of the meeting          expected outcomes before the            expected outcomes of a CoCo meeting to the                                              NC
meetings    and send this for comment to all participants.                             meeting and (2) sending this out        CoCo members?
                                                                                       for comments before finalizing
                                                                                                                               Q2: For all CoCos where you are the lead           Did you receive many
                                                                                       the statement of expected
                                                                                                                               supervisor do you request comments from all        comments on the statements
                                                                                       outcomes.                                                                                                                       NC
                                                                                                                               CoCo members on the statement of expected          you sent out and how often do
                                                                                                                               outcomes before finalizing it?                     you comment on statements
              Guideline article 3:                                                     (1) the agenda for CoCos should 11      Q1: For all CoCos where you are the lead           received? weeks/working days
                                                                                                                                                                                  How many                                                                if yes to 11.1
              An agenda of the meeting, sent out 2-3 weeks in advance, should          be send out at least 2 weeks            supervisor, do you send out an agenda at least in advance do you usually send           NC                                 and 11.2.a, b,
              clearly state which issues are going to be discussed, why these          before the meeting and (2) the          two weeks in advance of the meeting            the agenda?                                                                 c
              items are being discussed and what will be expected from the other       agenda should clearly state which       Q2: Do the agendas clearly state:                  Please comment on nature of
              members during the discussion (e.g. roundtable).                         issues are going to be discussed,                                                          the agenda and other
                                                                                       why these items are being               a) which issues are going to be discussed?
                                                                                                                                                                                  documents distributed.               NA
                                                                                       discussed and what will be
                                                                                       expected from the other
                                                                                       members during the discussion           b) why these items are being discussed?
                                                                                       (e.g. roundtable).                                                                                                              NA

                                                                                                                               c) what will be expected from the other
                                                                                                                               members during the discussion?                                                          NA

              Guideline article 3:                                                     The minutes/a summary of a      12      For all CoCos where you are the lead supervisor, How many weeks/working days                                               if yes
              Minutes/a summary of the last meeting should be agreed upon a            CoCo meeting should be sent and         do you send out draft minutes/a draft summary after the last meeting do you
              few weeks after the meeting, to ensure that all points raised have       agreed upon a few weeks after           of the last meeting for agreement by written     usually send out the minutes?          NC
              been followed up and addressed.                                          the meeting by all CoCo                 procedure upon a few weeks after the last
                                                                                       members.                                meeting?
              Guideline article 3:                                                     During each CoCo meeting there 13       For all CoCos where you are the lead supervisor                                                                            if yes
              [S]upervisors should always have a separate and closed session for       should be separate closed session       do you organise a separate and closed session
              internal discussions, without the insurance group being present.         for internal discussion.                for internal discussions without the insurance                                          NC
                                                                                                                               group being present?
              Guideline article 3:                                                     All CoCo members should be able 14      For all CoCos where you are the lead supervisor,                                                                           if yes
              The Key-Coordinator/Lead Supervisor should endeavour to ensure           to read and understand all              do you endeavour to ensure that reports or
              that reports or other information is submitted in, or translated to, a   reports and other information           other information is provided in a language                                             NC
              language understood by all members in the CoCo of that insurance         that is discussed within the CoCo.      understood by all members in the CoCo?
              group.

4.1.          Guideline article 4.1:                                                   All CoCos should have a written   15    Is the basis for cooperation in both regular and                                                                           if yes
Agreements    The CoCo may wish to lay down any arrangements on                        multilateral agreement in place         crisis situations in the CoCos in which you
within the    supplementary supervision in written multilateral agreements,            that addresses both regular and         participate laid down in a written agreement?
CoCo          which should address both regular and emergency situations,              emergency situations.
              including dealing with potential conflicts of interest.
                                                                                                                                                                                                                       N
              Principle 5:
              The Colleges of supervisors shall have agreements in place, laying
              out the basis for the cooperation between the involved authorities
              and the practical organisation of the supervisory activities of the
              Group on a on-going basis and in a crisis situation, including
              engagement with Cross Border Stability Groups.



5a63f0ca-0c1d-4e8d-893e-3555f0b8d72b.xls
4.1.
Agreements
within the
FINAL                                                                                                                               Questionnaire HP - Cocos                                                                                                                                7
CoCo


Helsinki Protocol
Guidelines for Coordination Committees in the Context of Supplementary Supervision as Defined by the Insurance Groups Directive (98/78/EC).
              Articles                                                               Assessment criteria                   No   Questions                                          Guidance for comments              Answers (See guidelines for replying)                               Benchmarks
              and relevant paragraphs                                                                                                                                                                                 Your reply    Implementing Comments                Fully applied
                                                                                                                                                                                                                                    measures
2.1.          Guideline article 2.1:                                                 All CoCos should have a working       16   As a LS, did you design a a working plan for the                                                                                         if yes
Members of    There is one CoCo for each and every insurance group operating in
              Guideline article 4.1:                                                 plan for the supervision of the            CoCos in which you participate?
the CoCo      more than use may be the agreement of a working plan, indicating
              Of further one EEA-country.                                            group. A woking plan could
              frequency and form of meetings, how to share information on a          indicate the frequency and form
              The CoCo members are representatives of the Insurance
              continuous basis, etc.                                                 of meetings, the way to shar
              Supervisory Authorities in the Member States in which the Group        einformation on a continuous
              has undertakings, and would normally be responsible for the day-to-
              Principle 6:                                                           basis, etc..                                                                                                                          NC
              day supervision of the (for an in their state.
              The Group Supervisor Group Insurance Group) or Consolidating
              Supervisor (for a Banking Group) or the Coordinator (for a Financial
              Conglomerate), shall initiate the cooperation process, chair the
              meeting of the College of Supervisors, and be responsible for
              designing a work programme for the supervision of the Group,
              which shall be approved by the College of Supervisors.
4.2. Crisis   Guideline article 4.2:                                                 (1) A CoCo should analyse             17   Q1: Did all CoCos in which you participate         (confidential): list the CoCos                                None of the COCOs       if yes to 17.1
                                                                                                                                                                                                                                                 in which we
situations    [T]o be fully prepared for any action that may be required, the CoCo   beforehand any crisis situation            analyse beforehand any crisis situation that may that you think have fulfilled this                                                      and 17.2
                                                                                                                                                                                                                                                 participate have
              should analyse beforehand any crisis situation that may arise and      that may arise including any               arise including any potential confict of interest? requirement and those which                                   fulfilled this
                                                                                                                                                                                                                           N
              any potential conflicts of interest. Furthermore, the CoCo should      potential conflict of interest and                                                            did not                                                       requirement.
              agree on a specific emergency plan, including cooperation and          (2) the CoCo should have an
              coordination in these kinds of situations.                             emergency plan ready in case
                                                                                     there is a crisis within the group.        Q2: Do all CoCos in which you participate have
                                                                                                                                an emergency plan?                                                                         N

              Guideline article 4.2:                                                 Supervisory authorities shall          18 Q1: Do you consult the supervisors in the CoCo      How do you determine                                          The portuguese          if yes
                                                                                                                                                                                                                                                 subsidiaries usually
              A crisis situation may be identified for an undertaking within an      consult with each other prior to          prior to making any important decision that         "important"?
                                                                                                                                                                                                                                                 have not a
              insurance group by one Supervisory Authority. The supervisor           making any important decisions            might affect the group as a whole, or other         How do you assess the impact                                  significant impact in
              responsible for the “solo” supervision of the insurance undertaking    that might affect the Group as a          entities within the group ?                         on the group or the other               NA
                                                                                                                                                                                                                                                 the group as a
              shall take the appropriate measures and inform the other members       whole, or other entities within the                                                           entities ?                                                    whole, because of
              of the CoCo on a timely basis, and if possible beforehand of the       Group.                                                                                                                                                      their dimention.

              measures taken.
                                                                                                                                Q2: If you identify a crisis situation as                                                                                                if yes to Q2 a
                                                                                     However, in a crisis situation, the
                                                                                                                                supervisory authority of an undertaking                                                                                                  and b
              Principle 8:                                                           supervisory responsible should
                                                                                                                                belonging to an insurance group:
              The Colleges of supervisors promote harmonization of approaches        take appropriate measures and
              and coordinates input to major supervisory decisions taken by          inform all CoCo members on a
              individual authorities as far as possible and practicable, and draw    timely basis, and if possible              a) Do you inform the CoCo on a timely basis?                                                Y
              their conclusions where appropriate.                                   beforehand of the measures                 b) Do you inform the CoCo beforehand of the
                                                                                     taken.                                     measures taken, if possible?
                                                                                                                                                                                                                            Y



              Guideline article 4.2:                                                 In crisis situations CoCos should 19       Did the CoCos in which you participate agree on Please elaborate on the specific                                                         if yes
              In a crisis situation some of the available information on the         have and use alternative forms of          alternative forms of communication for crisis   means used.
              insurance group could be commercially or market sensitive. The         information in order to safeguard          situations?                                                                                N
              CoCo should consider alternative forms of communication, avoiding      the confidentiality of information
              use of email transmission.                                             that is exchanged.




5a63f0ca-0c1d-4e8d-893e-3555f0b8d72b.xls
FINAL                                                                                                                                 Questionnaire HP - Cocos                                                                                                                        8



Helsinki Protocol
Guidelines for Coordination Committees in the Context of Supplementary Supervision as Defined by the Insurance Groups Directive (98/78/EC).
                Articles                                                                 Assessment criteria                 No   Questions                                             Guidance for comments              Answers (See guidelines for replying)                    Benchmarks
                and relevant paragraphs                                                                                                                                                                                    Your reply    Implementing Comments     Fully applied
                                                                                                                                                                                                                                         measures
2.1. Internal
4.4.            Guideline article 2.1:
                                    4.4:                                                 The Lead supervisor should        20     Q1: As Lead Supervisor, do you ensure that                                                                                       if yes to 20.1
Members of
Control         There is one CoCo for each and every insurance group operating in
                It is recommended that within the internal control and risk              ensure that the CcCo has a clear         the CoCos assess the control and risk                                                         NC                                 and 20.2
the CoCo
mechanisms      more than one EEA-country. CoCo should look at the specific group-
                management framework, the                                                picture of the control and risk          management framework of the group?
and risk        relevant risks in more detail, including for example the reinsurance     management framework at group
                The CoCo distribution channels used in the the Insurance                                                          Q2: As Lead Supervisor, do you ensure that
managemen       program, members are representatives of different countries, the         level in order to be aware of the
                                                                                                                                  the CoCos assess specific group-relevant risks
t processes     Supervisorypolicies applied or Member States in which the audit
                investment Authorities in the the extent to which internal Group         specific group-relevant risks.
                has undertakings,plan applicable at group responsible for the day-to-                                             in more detail?
                follows and audit and would normally be level.
                day supervision of the Group in their state.                             Involved supervisors shall, where
                Principle 7:                                                             appropriate, contribute their
                The Colleges of Supervisors provide an efficient platform for the        information and assessments of
                gathering and dissemination of relevant or essential information in      their supervised entities to the
                going concern and emergency situations, developing a common              overall assessment of risks and
                understanding of the risk profile of the Group, achieving                financial soundness of the Group                                                                                                       NC
                coordination of supervisory review and risk assessment at Group          by the Lead supervisor to be
                level as well as establishing supervisory plans for the mitigation of    addressed in the CoCo and will be
                risks at Group level.                                                    vice versa informed on the
                                                                                         results.
                Principle 10:
                Within the College of supervisors, the supervisors review and
                evaluate risks to which the group and its entities are or might be
                exposed to ensure a prospective supervision and foster early-
                Guideline article 4.4:                                                   Lead supervisors are responsible 21      As LS, do you ensure that the CoCos look at                                                                                      if yes
                The CoCo should furthermore be looking at how the management             for the CoCo to ensure that the          how the management information systems
                information systems contribute in giving the management and the          management and board of an               contribute in giving the management and the
                                                                                                                                                                                                                                NC
                board a reliable and global view of the real situation of the Group as   insurance group have a good              board a reliable and global view of the real
                a whole.                                                                 picture of the real situation of the     situation of the Group as a whole?
                                                                                         group.
                The CoCo should also be reassured that clear lines of responsibilities Lead supervisors should ensure        22   As LS, do you ensure that the CoCo assesses                                                                                      if yes
                should exist in the different areas and entities within the Group.     that the CoCo assesses whether             the existence of clear lines of responsibilities in
                                                                                       there are clear lines of                   the different areas and entities within the
                Principle 7:                                                           responsibilities within the                Group?
                The Colleges of Supervisors provide an efficient platform for the      insurance group.
                gathering and dissemination of relevant or essential information in                                                                                                                                             NC
                going concern and emergency situations, developing a common
                understanding of the risk profile of the Group, achieving
                coordination of supervisory review and risk assessment at Group
                level as well as establishing supervisory plans for the mitigation of
                risks at Group level.

                Guideline article 4.4:                                               For every meeting the lead          23       As LS, do you include an assessment of the                                                                                       if yes
                To ensure an efficient process, the papers submitted to the CoCo     supervisor should provide all                overall standard of corporate governance within
                members ahead of a meeting should include the Lead Supervisors´      CoCo members with an                         the Group into the papers submitted to the                                                    NC
                assessment of the overall standard of corporate governance within    assessment of the overall                    CoCo members ahead of the meeting?
                the Group.                                                           standard of corporate governance
                                                                                     in the group.
4.5. Capital    Guideline article 4.5:                                               (1) A CoCo should consider the      24       Q1: As LS, do you ensure that the CoCos               What do you consider as                                                    if yes to 24.1
                The CoCo should consider different aspects of the capital available  different aspects of the capital             consider different aspects of the capital             different aspects of the capital        NC                                 and 24.2
                to the Group as a whole and to the different undertakings within the available to the Group as a whole            available to the Group as a whole?                    available?
                Group.                                                               and (2) to the different                     Q2: As LS, do you ensure that the CoCos
                                                                                     undertakings within the Group. It            consider different aspects of the capital
                Principle 10:                                                        is lead supervisors’ responsibility          available to the different undertakings within
                Within the College of supervisors, the supervisors review and        to ensure that the CoCos                     the Group?                                                                                    NC
                evaluate risks to which the group and its entities are or might be   undertake those tasks.
                exposed to ensure a prospective supervision and foster early-
                warning of major risks to the extent possible.
4.6.            Guideline article 4.6:                                               In order to avoid double reporting 25        Q1: Did you within the CoCo coordinate/map            Please indicate what method                                                if yes to 25.1
Solvency        To facilitate the avoidance of double-reporting by the insurance     the CoCo should coordinate/map               the reporting requirements of each Member             you used.                                Y                                 and 25.2
                group, the CoCo should coordinate/map the reporting requirements the reporting requirements of                    State participating?
                of each Member State participating in the CoCo and hence agree       each Member State participating              Q2: Did you within the CoCo agree from which
                from which undertaking within the insurance group an Adjusted        and agree from which                         undertaking within the group an Adjusted
                Solvency Margin should be required. In principle, the method used    undertaking within the group an              Solvency Margin should be required?
                will be the compulsory one in the country where the head office is   Adjusted Solvency Margin should                                                                                                             Y
                located.                                                             be required.




5a63f0ca-0c1d-4e8d-893e-3555f0b8d72b.xls
4.6.
FINAL                                                                                                                          Questionnaire HP - Cocos                                                                                                                    9
Solvency


Helsinki Protocol
Guidelines for Coordination Committees in the Context of Supplementary Supervision as Defined by the Insurance Groups Directive (98/78/EC).
              Articles                                                              Assessment criteria               No    Questions                                         Guidance for comments   Answers (See guidelines for replying)                              Benchmarks
              and relevant paragraphs                                                                                                                                                                 Your reply    Implementing Comments               Fully applied
                                                                                                                                                                                                                    measures
2.1.          Guideline article 2.1: of reporting, the request for information
              In order to ease burden                                               In order to ease the burden of     26   As LS, do you ensure that all requests for                                                                                  if yes
Members of    There is one CoCo for each andcoordinated through theoperating in
              regarding the Group should be every insurance group Lead              reporting requests for information      information regarding the Group are coordinated
the CoCo      more than one EEA-country. while information requested from one
              Supervisor/Key Coordinator,                                           regarding the Group should be           by you?
              supervisor regarding an entity under its direct supervision may be    coordinated through the LS and
              The CoCo members are representatives of the Insurance
              handled by that supervisor.                                           information from one supervisor                                                                                        NC
              Supervisory Authorities in the Member States in which the Group       regarding an entity under its
              has undertakings, and would normally be responsible for the day-to-   direct supervision may be
              day supervision of the Group in their state.                          handled by that supervisor.

4.7. Intra  Guideline article 4.7:                                                  A CoCo should pay attention to     27   As LS, do you ensure that the CoCos pay                                                                                     if yes
Group       Attention should be given to how entities within the Group control      the way in which an insurance           attention to how entities within the Group
Transaction their own Intra Group Transactions.                                     group controls its own intra group      control their own Intra Group Transactions?
s                                                                                   transactions. It is lead
            Principle 10:                                                           supervisors’ responsibility to                                                                                         NC
            Within the College of supervisors, the supervisors review and           ensure that the CoCos undertake
            evaluate risks to which the group and its entities are or might be      those tasks.
            exposed to ensure a prospective supervision and foster early-
            warning of major risks to the extent possible.
              Guideline article 4.7:                                                A CoCo should be able to monitor 28     If you are a lead supervisor:                                                                                               if yes to 28.1
              Trends should be noted – e.g – are Intra Group Transactions more      trends such as (1) whether Intra        Q1: Do the CoCos for which you are the lead                                                                                 and 28.2
              frequent at particular times of the year, or between particular       Group Transactions are more             supervisor monitor trends such as whether Intra
                                                                                                                                                                                                           NC
              entities? How many loans may a company have or how much of the        frequent at particular times of the     Group Transactions are more frequent at
              loan must be repaid before further loans are                          year or whether Intra Group             particular times of the year or more frequent
              refused?                                                              transactions are more frequent          between particular entities?
                                                                                    between particular entities and         Q2: As a competent authority, do you provide
                                                                                    (2) how many loans a company            the CoCo with the information needed to
                                                                                    may have or how much of the             monitor trends such as whether Intra Group                                     NC
                                                                                    loan must be repaid before              Transactions are more frequent at particular
                                                                                    further loans are acceptable. It is     times of the year.
                                                                                    lead supervisors’ responsibility to     If you are not a lead supervisor:                                                                    We provide the intra   if yes to 28.3
                                                                                    ensure that the CoCos undertake         Q3: As a competent authority, do you provide                                                         group transactions
                                                                                    those tasks. Competent                                                                                                                       information that
                                                                                                                            the CoCo with the information needed to                                                              allows the treatment
                                                                                    authorities should provide the          monitor trends such as whether Intra Group                                                           in order to obtain
                                                                                    required information to the CoCo.                                                                                       Y
                                                                                                                            Transactions are more frequent at particular                                                         and monitor those
                                                                                                                            times of the year.                                                                                   trends.




5a63f0ca-0c1d-4e8d-893e-3555f0b8d72b.xls
FINAL                                                                                                                                  Questionnaire HP - Cocos                                                                                                                             10



Helsinki Protocol
Guidelines for Coordination Committees in the Context of Supplementary Supervision as Defined by the Insurance Groups Directive (98/78/EC).
              Articles                                                                  Assessment criteria                   No   Questions                                             Guidance for comments            Answers (See guidelines for replying)                            Benchmarks
              and relevant paragraphs                                                                                                                                                                                     Your reply    Implementing Comments           Fully applied
                                                                                                                                                                                                                                        measures
2.1.          Guideline article 2.1:
                                  4.7:                                                  The CoCo should determine which 29         Q1: Did the CoCo determine which transactions                                                                     But in some        if yes to 29.1
Members of    There is one CoCothe reporting of ‘significant’ transactions. There
              The IGD refers to for each and every insurance group operating in         transactions are significant for           are significant for the insurance group, taking                                                                   groups different   and 29.2
the CoCo      more than one EEA-country. precise meaning of ‘significant ‘in
              are differences regarding the                                             the insurance group, taking into           into account the specific risk profile of that                                               Y                    criteria may be
              national legislation of Member States, and furthermore ‘significant’      account the specific risk profile of       group?                                                                                                            used to assess
                                                                                                                                                                                                                                                     significance.
              The vary from one grouprepresentatives of the Insurance and the
              will CoCo members are to another. For the supervisors                     that group.
                                                                                                                                   Q2: Did the CoCo discuss the structure and
              Supervisory be very helpfulthe know what management thethe
              CoCo it can Authorities in to Member States in which of Group
                                                                                                                                   interconnection of the group in the light of the
              has undertakings, and would normally be responsible for the day-to-
              undertakings or the Group has determined as being ‘significant’.          The structure and interconnection
                                                                                                                                   potential risks resulting from transactions and
              day supervisiondetermination in their state.
              Ultimately, the of the Group of which transactions are significant        of the group should be discussed
                                                                                                                                   the resulting level of exposures?
              for the Group will be the responsibility of the CoCo, taking into         in the light of the potential risks
              account the specific risk profile of that Group.                          resulting from transactions and
                                                                                        the resulting level of exposures.
              The structure and interconnection of the Group should be discussed
                                                                                                                                                                                                                                Y
              in the light of the potential risks resulting from transactions and the
              resulting level of exposures.

              Principle 4:
              When forming the College of supervisors, the involved Supervisors
              shall communicate to each other their assessment of their
              respective supervised entity’s significance and risks for the Group
              and systemic relevance for local financial markets, and take into
              Guideline article 4.7:                                                    The lead supervisor should         30      As a LS do you ensure that the concerns raised                                                                                       if yes
              Concerns raised by members on Intra Group Transaction-issues              provide the opportunity to discuss         by the solo supervision on Intra Group
              resulting from “solo supervision” should be discussed;                    Intra Group Transactions                   Transactions are discussed and analysed?                                                    NC
                                                                                        resulting from “solo supervision”.
              Guideline article 4.7:                                                    If measures are taken by an      31        If you are a lead supervisor:                                                                                                        if yes to 31.1,
              Measures taken by the individual competent authorities towards an         individual competent authority             Q1: For all CoCo’s where you are the lead                                                                                            31.2 and 31.3
              undertaking of the insurance group regarding Intra Group                  towards an undertaking of the              supervisor, are measures taken by individual                                                                                         a
                                                                                                                                                                                                                               NC
              Transactions should be discussed and, where appropriate,                  insurance group regarding Intra            members of the CoCo´s in which you participate
              coordinated;                                                              Group Transactions this                    regarding Intra Group Transactions discussed in the
                                                                                        supervisory action should (1) be           CoCo?
              Principle 8:                                                              discussed by the CoCo and (2) be           Q2: For all CoCo’s where you are the lead
              The Colleges of supervisors promote harmonization of                      coordinated by the CoCo where              supervisor, are measures taken by individual
              approaches and coordinates input to major supervisory decisions           appropriate.                               members of the CoCo´s in which you participate                                              NC
              taken by individual authorities as far as possible and practicable,                                                  regarding Intra Group Transactions, where
              and draw their conclusions where appropriate.                             Supervisory authorities shall              appropriate, coordinated?
                                                                                        consult with each other prior to           Q3: Do you inform the CoCo of any supervisory
                                                                                        making any important decisions             actions regarding Intra Group Transactions:
                                                                                        that might affect the Group as a
                                                                                        whole, or other entities within the
                                                                                                                                   a) prior to taking the action ?
                                                                                        Group.
                                                                                                                                                                                                                               NC

                                                                                                                                   b) as soon as possible ?                              Please add the avergare timing
                                                                                                                                                                                         to inform                             NC

                                                                                                                                   If you are not a lead supervisor:                                                                                                    if yes to 31.4 a
                                                                                                                                   Q4: Do you inform the CoCo of any supervisory
                                                                                                                                   actions regarding Intra Group Transactions:


                                                                                                                                   a) prior to taking the action ?
                                                                                                                                                                                                                               NC

                                                                                                                                   b) as soon as possible ?                              Please add the avergare timing
                                                                                                                                                                                         to inform                             NC




5a63f0ca-0c1d-4e8d-893e-3555f0b8d72b.xls
             FINAL                                                                       Questionnaire HP - Cocos   11




ed by the Insurance Groups Directive (98/78/EC).
                                               for programming - please do not touch !
            No       Benchmarks                         Y   N   NA       NC
                  Partially applied Not applied

            1                         if no




            2                         if no




            3                         if no




            4                         if no




            5                         if no




            6




            7
                                      if no to a, b
                                      and c




             5a63f0ca-0c1d-4e8d-893e-3555f0b8d72b.xls
            7
                                      if no to a, b
             FINAL                    and c                                              Questionnaire HP - Cocos   12




ed by the Insurance Groups Directive (98/78/EC).
                                               for programming - please do not touch !
            No       Benchmarks                         Y   N   NA       NC
                  Partially applied Not applied

            1



            8


            9                         if no to a or b




            10    if yes to 10.1 and if no to 10.1
                  no to 10.2




            11    if yes to 11.1 and if no to 11.1
                  11.2.a             or 11.2.a




            12                        if no




            13                        if no




            14                        if no




            15                        if no




             5a63f0ca-0c1d-4e8d-893e-3555f0b8d72b.xls
             FINAL                                                                       Questionnaire HP - Cocos   13




ed by the Insurance Groups Directive (98/78/EC).
                                               for programming - please do not touch !
            No       Benchmarks                         Y   N   NA       NC
                   Partially applied Not applied

            1
            16                        if no




            17                        if no to 17.1
                                      or 17.2




              18                      if no




                                      if no to Q2 a
                                      or b




            19                        if no




             5a63f0ca-0c1d-4e8d-893e-3555f0b8d72b.xls
             FINAL                                                                       Questionnaire HP - Cocos   14




ed by the Insurance Groups Directive (98/78/EC).
                                               for programming - please do not touch !
            No       Benchmarks                         Y   N   NA       NC
                  Partially applied Not applied

            1
            20                        if no to 20.1
                                      or 20.2




            21                        if no




            22                        if no




            23                        if no




            24                        if no to 24.1
                                      or 24.2




            25                        if no to 25.1
                                      or 25.2




             5a63f0ca-0c1d-4e8d-893e-3555f0b8d72b.xls
             FINAL                                                                       Questionnaire HP - Cocos   15




ed by the Insurance Groups Directive (98/78/EC).
                                               for programming - please do not touch !
            No       Benchmarks                         Y   N   NA       NC
                  Partially applied Not applied

            1
            26                        if no




            27                        if no




            28                        if no to 28.1
                                      or 28.2




                                      if no to 28.3




             5a63f0ca-0c1d-4e8d-893e-3555f0b8d72b.xls
             FINAL                                                                       Questionnaire HP - Cocos   16




ed by the Insurance Groups Directive (98/78/EC).
                                               for programming - please do not touch !
            No       Benchmarks                         Y   N   NA       NC
                  Partially applied Not applied

            1
            29                        if no to 29.1
                                      or 29.2




            30                        if no




            31    if yes to 31.1 ,    if no to 31.1 ,
                  31.2 and 31.3 b     31.2 or 31.3 b




                  if yes to 31.4 b    if no to 31.4 b




             5a63f0ca-0c1d-4e8d-893e-3555f0b8d72b.xls

				
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