STRATEGIC PLAN 2014-2016
1. INTRODUCTORY NOTE 3 2. ORGANISATIONAL IDENTITY 5 2.1. MISSION 5 2.2. VISION 5 2.3. VALUES 5 3. ISP RESPONSIBILITIES 6 3.1. ISP DUTIES 6 3.2. ISP POWERS 6 4. STRATEGIC PLAN FOR 2014-2016 8 4.1. STRATEGIC OBJECTIVES 9 4.2. STRATEGIC PRIORITIES AND ACTIVITIES 10 5. MONITORING 28 Strategic Plan 2014-2016 2/27
1. INTRODUCTORY NOTE The challenges the insurance and pension funds sector will be facing in the near future, as a result of the particularly difficult national and international context, require a clear response by the Supervisory Authority, as regards priorities of its action plan, to ensure the good functioning of the market and to contribute to the protection of policyholders, insured persons, members and beneficiaries. The activity of this Supervisory Authority during the last two years took place in a context of strong economic difficulties and heavy financial instability. Within this context, it is worth referring the efforts made by insurance and reinsurance companies, intermediaries and pension funds managers to overcome such difficulties by maintaining comfortable levels of financial soundness and significantly contributing to the development of the country. For the next three years, the insurance sector will also be facing very important challenges which will definitely require complete dedication of all employees of this Supervisory Authority. This way, it will be possible to create adequate conditions for the different market players to enjoy the benefits of a financially solid sector involved in the economic and social aspects of the country. As regards the micro-prudential supervisory area, the ISP will maintain a close and careful relationship with all operators and will also encourage the creation of governance mechanisms based on solid internal control and risk management systems allowing such operators to adequately and effectively manage the different types of risks. The macro-prudential sector will be supervised through the implementation of measures which will allow for the identification and monitoring of potential systemic risks and for the adequate relationship between macro- and micro-prudential perspectives. In spite of the repeated postponements, as regards the implementation of Solvency II, EIOPA issued some guidelines which establish a Member States preparation regime to be implemented from 2014. Therefore, it is crucial to give priority to the needed projects, both at the level of operators and internally at the ISP. Strategic Plan 2014-2016 3/27
During this triennium, the review of the current regulatory pension funds regime will be carried out in a way to provide it with a risk-oriented perspective similar to what is being observed in the insurance market. As regards the mediation sector, the European Commission is currently preparing the amendments to the Community Directive concerning insurance mediation (IMD II), which will imply its transposition to the national legal framework as well as the adaptation to the actual regulatory instruments. Consumers protection will be reinforced with the aim of developing initiatives that will contribute to increase know-how in the insurance and pension funds area. The ISP will carry on working on financial education together with the other national financial supervisory authorities, thus contributing to a more informed society. Compliance with the important mission assigned to the ISP will only be well-succeeded if all employees engage themselves in reaching the strategic objectives mentioned below. For such reason, the ISP considers it is important to strongly focus on the retention and motivation of highly qualified technical staff, what increasingly reveals a strong challenge within the actual economic and financial context. We believe that, in spite of all possible difficulties, the ISP employees will continue to display the usual high professionalism and dedication as they continue to pursue the established objectives and strategies defined for the following triennium. José Figueiredo Almaça President of Instituto de Seguros de Portugal Strategic Plan 2014-2016 4/27
2. ORGANISATIONAL IDENTITY 2.1. Mission The mission of Instituto de Seguros de Portugal (ISP) is to ensure the good functioning of the insurance and pension funds market in Portugal and to contribute to the protection of policyholders, insured persons, members and beneficiaries. ISP mission is ensured by the promotion of a solid financial stability of all institutions under its supervisory, as well as by the maintenance of high conduct levels by the operators (insurance and reinsurance companies, pension fund managers and mediators). With such a framework, ISP has been positioning itself in a way to keep the insurance and pension funds market efficient, fair, safe and stable. 2.2. Vision ISP aims to be a modern, professional, active and efficient organisation in order to effectively contribute to the consumer s confidence in the insurance and pension funds sector. For such purpose and in accordance with its regulatory and supervisory project, ISP introduces the principles of best practices established or recognised in the ambit of the main international organisations in the regulation and supervision of the insurance and pension funds sector and actively follows and acts in fora relevant both at national and international levels. 2.3. Values ISP is governed by certain values which guide the definition and implementation of its strategies, namely: The primacy of public interest; Protecting the interest of insurance and pension funds consumers; Independent and responsible actions; Acting with integrity, consistency and transparency; Operating in an efficient and effective and socially responsible manner. Strategic Plan 2014-2016 5/27
3. ISP RESPONSIBILITIES Firstly, the ISP Strategic Plan is based on duties and powers which are assigned to it, according to the Statute, published by Decree-Law n.º289/2001, of 13 November. 3.1. ISP Duties ISP is considered a competent institution, which employs highly qualified professionals, who ensure their responsibilities in accordance with the criteria based on professional excellence and high sense of ethics, with an independent administrative and financing organisation which uses the means and processes available in an efficient and effective manner taking into consideration the compliance with its duties and obligations. With the view of fulfilling its mission, nº 1 of Article 4 of ISP Statute establishes the following: to regulate, supervise and monitor the insurance, reinsurance and pension funds mediation activities as well as complementary and other activities related thereto; to assist the Government and the Ministry of Finance whenever required, or on its own initiative, on defining the guidelines to be developed for insurance sector policy purposes. Related and complementary activities of the insurance, reinsurance, insurance mediation as well as fund pension activities are hereby included; to develop and control the implementation of such policy; to cooperate with other competent authorities from other States in the areas of their competence, in particular, with the authorities of the European Union State Members; to cooperate with other national authorities in the areas of their competence and, in particular, with the other financial supervisory authorities; to manage the funds legally granted to ISP. 3.2. ISP Powers For the purpose of execution of the duties assigned to the ISP, the ISP Statute also defines its powers, which essentially lie on the following domains: Regulatory policy; Authorisations and registration; Prudential and market conduct Supervision; Enforcement; Funds management; Institutional and international relationships; Studies and analysis about the insurance and pension funds sector; Statistics about the insurance and pension funds sector; ISP resources management. Strategic Plan 2014-2016 6/27
4. STRATEGIC PLAN FOR 2014 2016 ISP Strategic Plan is, necessarily, composed by the previously described components. In fact, it is intended to respond to the institutional identity of such supervisory authority, which is described in its mission, vision and values as well as to the duties and powers arising from the Statute. Such interconnection between the various strands may be summarized in the scheme below: Figure 1 ISP Strategic Plan Framework Strategic Plan 2014 2016 7/27
4.1. Strategic objectives ISP s strategic objectives for 2014-2016 are the following: 1. To ensure the definition and compliance with adequate governance patterns and strong financial levels by the operators 2. To ensure the implementation of high conduct patterns by the operators 3. To ensure the effective and efficient transition to the Solvency II regime 4. To enhance the analysis at a macro-economic level by reinforcing the monitoring and risk assessment mechanisms that may possibly affect the financial stability of the sector 5. To contribute to the balanced development of the relevant legal regimes within the insurance and pension funds market intervention 6. To enhance insurance and pension funds consumers protection by promoting transparency, simplicity and fairness in what regards marketed products and services 7. To consolidate the inter-institutional cooperation strategy 8. To be provided with sufficient, qualified and motivated human resources 9. To maximise the efficient use of the available global resources considering the best practices of social responsibility 10. To efficiently manage autonomous funds assigned to the ISP Strategic Plan 2014-2016 8/27
4.2. Strategic priorities and activities In order to comply with the strategic objectives referred to above, these objectives are subdivided into strategic priorities and activities. Objective 1 To ensure the definition and compliance with adequate governance patterns and strong financial levels by the operators. Strategy 1.1 To supervise operators both at the individual and group levels, preferably acting in a preventive manner To continue to strongly focus on communication considering the governance structures involved in the supervisory process board members, statutory auditors, responsible actuary - as essential elements for evaluating the supervised entities risk profile To consolidate the proximity of the action plan strategy, namely by strengthening on-site inspections To reinforce the disclosure of information related to the financial supervisory process of insurance and pension funds companies To strengthen the policy for disclosing opinions related to the practical application of the financial legislation and regulation applicable to insurance companies, insurance and pension funds intermediaries To enhance the prospective analysis of the insurance companies financial situation by means of standardisation, as well as by the definition of market benchmarks To strengthen the assessment of practices regarding insurance companies management as regards the contracts where the risk is supported by the policyholder To reinforce monitoring regarding the development of insurance companies technical operation, namely in main insurance areas and specially in those where risks can be translated in long-term responsibilities, in order to ensure that underwriting, pricing and reserving policies are duly adequate and sufficient To participate in the supervision of European insurance groups with presence in Portugal under colleges of supervision To enhance specific inspections towards both the new emerging risks and the economic and financial situation environment Strategic Plan 2014-2016 9/27
To deepen the supervisory process of insurance management companies with head office out of the European Union and which control insurance companies with head office in Portugal Reinforce supervisory activities focused on subjects taught at insurance mediation courses Strategy 1.2 To improve the supervisory process based on the risks taken by operators. To consolidate supervisory systems and instruments related to risk assessment to which insurance companies and pension funds are exposed, in order to identify their risk profile and to define supervisory priorities To develop specific prudential supervisory systems and instruments for the contracts where risk is supported by the policyholder To prepare technical studies in order to establish a standardised set of stress tests regarding the most relevant risks for ISP reporting purposes To recast the pension funds solvency regime in accordance with the European Union developments in order to make it more flexible, consistent with the underlying economic reality and sensible to the incurred risks To ensure that the supervisory process complies with the requirements established by the international rules issued by the International Association of Insurance Supervisors (IAIS), namely, standards used when assessing the Financial Sector Assessment Program of the International Monetary Fund (FSAP-IMF) assessments Strategy 1.3 To consolidate supervisory strategies of the operators governance models. To deepen the evaluation of governance mechanisms of insurance companies and fund pension managers, in particular as regards management systems for implemented risks. To concentrate fit and proper requirements needed from members of management and audit boards of insurance companies, pension funds managers and insurance intermediaries Strategic Plan 2014-2016 10/27
To enhance the qualification analysis and professional experience required from members of management and audit bodies as well as from top directors of insurance companies and fund pension managers, individually considered and duly put into context in the whole of the governing bodies which they are part of To improve the assessment of conditions to guarantee a healthy and prudent management by insurance companies, pension funds managers and insurance brokers To deepen assessment procedures of possible conflict of interest situations as regards pension fund managers by insurance companies and insurance brokers Strategy 1.4 To deepen and improve the supervisory process for providing financial reporting to the market by the operators. To strengthen the process of reviewing the financial reporting to the market by insurance companies based on the Chart of Accounts and on the development of International Accounting Standards To consolidate the supervisory model of the pension funds financial reporting regime To consolidate the supervisory model of the insurance brokers and reinsurance intermediaries financial reporting regime Objective 2 To ensure the implementation of high conduct patterns by the operators. Strategy 2.1 To reinforce the market conduct on-site supervision process. To reinforce supervisory activities as regards compliance with legislation and regulations applicable to insurance, pension funds management and insurance mediation activities, in particular in the significantly more important areas for the good functioning of the market, as well as for the protection of policyholders, insured persons and beneficiaries To reinforce Mystery Client direct supervisory activities whenever justified by the matters analysed Strategic Plan 2014-2016 11/27
To deepen the impact of recommendations or guidelines issued by ISP to operators Strategy 2.2 To reinforce operators activity off-site monitoring as regards market conduct supervision. To monitor the actual implementation of Codes of Conduct by insurance companies To develop and improve monitoring of the implementation, by several operators, of adequate procedures in order to prevent and fight money laundering and terrorism financing, considering the GAFI s new recommendations and the 4 th round of mutual evaluations To improve monitoring of insurance, pension funds and insurance mediation advertising, mainly in what regards to digital media To improve operation monitoring as regards the Complaints Management function as well as Customer Ombudsmen To develop monitoring of the operators compliance with the disclosure duties To assess operators websites and monitor the procedures implemented by such operators as regards insurance and pension funds distance marketing To improve mechanisms and procedures that allow for the identification and registration of unfair commercial practices in the insurance and pension funds market To continue with cross-sectional analysis by means of enquiries to operators, thus favouring the use of automatic methodologies for collecting and handling information To continue to monitor compliance with the duties established in the non-discrimination regime on the grounds on gender, deficiency and/or increased health risk To enhance monitoring of motor claims settlements and reliability of the information obtained, namely by cross-checking the available information To enhance supervisory procedures regarding the monitoring of Life insurance products made available in the market, namely by means of a new sales marketing notification system considering the need for information, standardisation of its reporting and control of notification duties To maintain the monitoring of the insurance intermediaries activity, namely in what regards the fulfilment with the conditions related to the pursuit of the activity, as well as permanent maintenance of the access requirements thereto Strategic Plan 2014-2016 12/27
To promote greater requirements by pension funds managers as regards collective memberships to open pension funds and contracts associated with pension funds which are not subject to ISP authorisation To act at the level of EU insurance companies, which operate under freedom to provide services in Portugal concerning the compliance with the conditions of general interest imposed by Portuguese Law Strategy 2.3 To enhance ISP disclosure of opinions on the practical and concrete application of legislation concerning market conduct. To continue disclosing the opinions resulting from the application of the legal regime of the insurance contract and other legislation and regulation applicable to insurance, pension funds and insurance mediation activities To ensure the updating and structuring of opinions at the ISP website aiming at making its research easier and more accessible To enhance the disclosure of studies, opinions and interpretative guidelines of the legislation applicable to the various classes aiming at harmonising behaviours and conducts of the different operators Strategy 2.4 Analysis of information requests and complaints presented by individuals and official entities as regards the exercise of the insurance, mediation and pension funds managers activities To guarantee the existence of operational conditions in order to respond to citizens and official entities, either national or international, in a clear and effective manner. To considering the analysis of complaints, identify possible signs of conducts which do not comply with the legal and regulatory framework or with good practices To ensure statistic processing of matters presented by citizens through clarification requests or complaints so that it will be possible to include such information in accordance with the definition of priorities of market conduct supervision To ensure regulatory conditions strictly needed for the promotion of market solutions development aiming at minimising possible conflicts in the insurance and pension funds sector Strategic Plan 2014-2016 13/27
Objective 3 To ensure an effective and efficient transition to the Solvency II regime. Strategy 3.1 To adopt the legislation and regulation which transpose Solvency II, as well as other additional provisions, to the national legal system. To transpose the Solvency II Directive to the national legal system To actively participate in discussions on the project of the European Commission Delegated Acts which establishes the measures for implementing the Solvency II regime as well as monitor its translation To participate in an active and leading way about draft technical rules and regulatory technical standards, as well as about the guidelines to be issued by the European Insurance and Occupational Pensions Authority (EIOPA) in line with the essential features of the regime and also monitor its development and translation To ensure the coordination with EIOPA as regards compliance with the European guidelines by the operators To adopt the current regulation and recommendations to the new solvency regime To promote the necessary legal and regulatory amendments to the implementation of EIOPA guidelines as regards the partial and interim application of the Solvency II regime, which includes the areas of internal models pre-order, of governance system, of prospective risk self-assessment and of the submission of information Strategy 3.2 To ensure ISP s preparation for the implementation of the Solvency II regime. To carry out the comparative analysis between the supervisory process requirements in the Solvency II context and ISP current reality, by identifying areas of improvement Strategic Plan 2014-2016 14/27
To develop and implement the ISP s Integrated Risk-Assessment System (SIR), which allows to identify the risk profile for each insurance company, the insurance companies hierarchy in terms of such profile, as well as the definition of supervisory priorities To adapt technologies and information systems in order to meet the requirements of the new solvency regime To implement mechanisms and procedures which allow to confirm the quantitative requirements established by the Solvency II regime, namely in what regards technical provisions calculation according to economic principles and the solvency capital requirement To develop and implement procedures and analysis and validation methodologies of internal models for insurance companies solvency purposes Develop and implement procedures and analysis methodologies complying with the governance system requirements as well as with risk and solvency self-assessment To adapt the supervisory process to the new information reporting model Strategy 3.3 To monitor the implementation of the Solvency II regime by insurance companies. To enhance communication between insurance companies board members and the ISP as regards strategies and particular preparation plans for the Solvency II regime To reassess quantitative impacts of the Solvency II regime on the Portuguese market considering, in particular, the developments observed in terms of quantitative requirements (Pillar 1) based on impact analysis exercises to be performed in the market To enhance global analysis and individual feedback as regards methodologies and assumptions used for technical provisions calculation based on economic principles To continue with the pre-order process and establish the formal approval process for internal models, thus ensuring that the development and implementation for solvency capital requirement purposes is conducted on a solid basis. to monitor implementation, by insurance companies, of the risk and solvency selfassessment process To adapt the insurance companies governance supervisory strategies to the Solvency II regime, in particular in what regards the fit and proper requirements assessment required for insurance companies management and audit bodies Strategic Plan 2014-2016 15/27
Objective 4 To enhance analysis at a macro-economic level by reinforcing monitoring and risk assessement mechanisms with the potential to affect the financial stability of the sector. Strategy 4.1 To monitor global macro-economic and financial developments, anticipating and acting in an adequate manner in the presence of the emerging risks that may possibly affect the financial stability of the sector as well as vulnerabilities in the financial soundness levels of national operators. To formalise the contingency plan which guides ISP activities in a crisis context, namely in what regards adequate and timely information provided by operators. To reinforce macro-prudential analysis, namely by means of the implementation of a risk and instruments panel, indicators and mechanisms allowing for the early identification of risks that may possibly affect the financial stability of the sector To prepare and release the bi-annual risk analysis report on the insurance and pension funds sector To perform, at a national level, stress tests to be defined by EIOPA as well as other activities that may be established for the national market in order to measure the soundness and resistance of the insurance and pension funds sector To guarantee an adequate connection between macro and micro-prudential angles by reinforcing supervision in a top-down approach. Strategy 4.2 To develop initiatives within the business continuity management with the aim to assess the response capacity not only at an individual level but also at a market level, considering a generalised operational disruption situation. To development of a benchmarking concerning business continuity management, which will allow to gauge the operators resilience and technological and operational recovery capacity, after an event resulting in an operational disruption To promote the strengthening of the operators response capacity as regards operational contingency scenarios by disclosing a set of good practices for the business continuity management in the insurance activity Strategic Plan 2014-2016 16/27
To plan and perform a simulation exercise of an operational disruption event which may globally affect the market, thus enhancing the assessment of the business continuity management implementation level by operators as well as the suitability of business approaches and procedures that may allow the continuity of business in contingency situations of operational nature Objective 5 To contribute to the balanced development of the relevant legal regimes within the ISP duties. Strategy 5.1 To analyse and propose solutions which may, at a national level, contribute to the balance between consumers rights, mutuality protection, innovation and market competitiveness as well as stability at a macro-economic level. to ensure successive assessments of the introduction of new legislation, regulation or recommendations in order to determine the corresponding effective impact and to justify any possible amendment or review To prepare legal or regulatory proposals, taking into account the results arising from successive assessments already carried out, namely as regards the legal regime setting up and running on pension funds and respective management entities, as well as the motor liability insurance legal regime To monitor, together with the Government, the legal process concerning ISP initiatives. To use soft law mechanisms (i.e. recommendations) to promote a wider market discipline in the areas under the ISP supervision, namely in the cases in which the weighting of the regulatory instrument to be used does not justify a standard-setting intervention To carry out the necessary studies to justify possible legal initiatives for the reorganisation and winding-up of insurance companies, in convergence with regulatory developments concerning bank resolution To analyse insurance and pension funds market trends in order to check relevant developments in terms of financial innovation which may imply the need for a specific regulatory intervention To analyse and classify tying situations (compulsorily associated sales) and other unfair commercial practices in order to create a typology that may be considered as a reference for operators, consumers and the supervisory authority Strategic Plan 2014-2016 17/27
Strategy 5.2 To monitor legal works at the European level with impact on ISP duties. To monitor works regarding the development of guarantee funds in insurance business To monitor discussions regarding the establishment of a cross-sectional regime for the financial products sold at a retail level To monitor the development of discussions as regards the insurance mediation Directive review To monitor works to be reviewed by the professional pension funds Directive To monitor discussions regarding the Directive for the implementation of a principle of equal treatment between people regardless of religion or faith, disability, age or sexual orientation Strategy 5.3 To consolidate regulations in the various ISP intervention areas. To consolidate the existing regulation in accordance with the legal and regulatory reform associated with the Solvency II regime To guarantee that consolidation of the legislation and regulation in force complies with the requirements established under international rules issued by IAIS (standards used in FSAP- IMF assessments) To consolidate dispersed regulation in order to promote accessibility and legal certainty To develop an unofficial code for the legal acts applicable to activities supervised by the ISP, those codes being organised by subjects considering the various regulation levels (legal, regulatory, recommendations and guidelines), in order to favour accessibility and to contribute to literacy in these areas Objective 6 To enhance insurance consumers protection by promoting transparency, simplicity and fairness as regards marketed products and services. Strategic Plan 2014-2016 18/27
Strategy 6.1 To contribute to an enhanced financial education, as well as to the creation of a risk perception and mitigation culture by consumers. to recognise the importance of insurance in society as well as that of savings as the best way to ensure the maintenance of adequate income levels during retirement To develop initiatives, among the general public which promote the role of insurance and pension funds in the economic development as well as in the pooling of risks To monitor actions to be developed by EIOPA as regards consumers protection and to ensure the disclosure of such actions to final recipients To actively participate in the implementation of the National Financial education Plan, within the Working Group created by the National Council of Financial Supervisors Strategy 6.2 To provide consumers with clear, relevant and impartial information on costs and risks, benefits of the products of the insurance and pension funds sector To organise general information activities about insurance and pension funds products and risks associated thereto, in a language accessible to the common consumer. To publish information aimed at informing consumers on the their rights in the ambit insurance and pension funds and mediation business regimes and whenever there is a number of complaints suggesting clarification on insurance in general or on specific insurance classes To promote initiatives to clarify consumers on the products marketed by the insurance and pension funds sector To monitor and adapt the Consumers Portal (if needed) as a communication platform with general public, and provide all possible instruments deemed useful To develop active collaboration initiatives with consumer protection agencies To ensure a high quality Public Service Centre not only at a face-to-face level at the ISP facilities but also when other means of contact are used Strategic Plan 2014-2016 19/27
Strategy 6.3 To improve technical know-how of the insurance and pension funds sector with specific professional groups. To promote cooperation between institutions of different education levels in order to ensure the disclosure of different types of risks assumed everyday by people and companies as well as of the role of the different types of insurance in their mitigation To maintain protocol policies with education institutions as well as the promotion of academic awards for the relevant works in the insurance and pension funds areas To celebrate cooperation agreements with education institutions with the aim to ensure curricula programmes adequate to the legal and regulatory framework in force and also to promote specific contents of the insurance and pension funds sector To strengthen the production of publications of technical nature by the ISP Objective 7 To consolidate inter-institutional cooperation strategy. Strategy 7.1 To optimise interaction with entities participating in the regulatory process with impact on areas supervised by the ISP To provide statutorily previewed assistance to the Government and Ministry of Finance, in order to guarantee a high quality and duly appropriate support in accordance with the mandate assigned to the ISP and preserving the organisational and operational independence recognised thereto Considering its mission, to maximise effective and timely cooperation with the Permanent Representation of Portugal at the European Union REPER, in the context of community legal files associated with the insurance and pension funds market To enhance collaboration with the Planning, Strategy, Evaluation and International Relations Office (GPEARI) of the Ministry of Finance in the context of the areas supervised by ISP Strategic Plan 2014-2016 20/27
Strategy 7.2 To actively participate in cooperation and coordination structures as regards the supervision of the national financial system. To consider the National Council of Financial Supervisors (CNSF), to contribute to the enhancement of the cooperation between financial system supervisory authorities To participate at the National Financial Stability Committee (CNEF) by effectively contributing to the pursuit of its mission To actively participate in the projects/works of the National Council for Audit Supervision (CNSA) To guarantee the representation of ISP at the CNSA Permanent Secretariat To involve associations of the sector and/or other interested parties in the regulatory processes Strategy 7.3 To actively participate in the cooperation and collaboration structures as regards regulation and supervision at an international level To contribute to the good functioning of the European System of Financial Supervisors To actively participate on the various activities of the European System of Financial Supervisors, namely as member of the EIOPA s Board of Supervisors and of the ESRB s General Council through ISP representation in the main existing fora To actively participate in the most relevant working groups within EIOPA, improving the exchange between national regulatory experience and supervisory, and community developments in areas of common interest, particularly focused on the implementation of the Solvency II regime To ensure the adequate ISP performance in what regards its participation in EIOPA To actively participate in ESRB working groups To monitor evolution of IAIS works, namely in what regards the development of standards used for the FSAP-IMF assessment and the Common Framework for the Supervision of Internationally Active Insurance Groups (ComFrame) To ensure participation at the Insurance and Private Pensions Committee for the Organisation and Cooperation and for the Economic Development Strategic Plan 2014-2016 21/27
To monitor the progress of the work conducted by the International Organisation of Pension Supervisors (IOPS) Strategy 7.4 To maintain international cooperation with Portuguese-speaking countries. To favour solid cooperation activities that may contribute to the promotion of the local insurance and pension funds market, as well as to the development of the corresponding regulation and supervision To guarantee the performance of the functions assigned to the Secretariat of the Lusophone Insurance Supervisors Association, to cooperate in the Annual Conference and to participate at the General Assembly Strategy 7.5 To maintain international cooperation with Iberoamerica. Objective 8 To have sufficient, qualified and motivated human resources. Strategy 8.1 To ensure that ISP has sufficient and adequate personnel to carry out its mission and responsibilities. To consolidate hiring policies, namely by establishing criteria that allow for the valuing of competencies and of the merit of the people to be hired To plan a detailed personnel s mobility policy which may contribute to the dynamism of the organisation and to the reinforcement of communication and interaction between the various structures To promote the hiring process of the personnel essential for the achievements of the ISP objectives, namely in what regards the increasingly needs imposed by the transition resulting from the Solvency II regime Strategic Plan 2014-2016 22/27
To continue to encourage internships that would allow to form a group of technicians/experts with adequate skills in the insurance and pension funds area Strategy 8.2 To ensure the increasing qualification of ISP personnel through an adequate and detailed planning and choice of training activities to be implemented. To annually define and disclose a training plan considering the ISP human resources needs, as well as market trends To identify, in due time and in a proactive way, the need for additional training and/or restructuring the ones already in place To increase the knowledge sharing process between the different organisational units Strategy 8.3 To guarantee the motivation of the ISP personnel. To introduce the best of human capital management practices, namely by improving career plans that lead to professional development and contribute to the reinforcement of the employees motivation To improve processes and working methodologies, promoting communication between the different organisational units and encouraging the sharing of knowledge To cultivate team work in order to increase cohesion levels among employees To promote an organisational culture valuing technical competence and effective performance To promote an involvement culture of the existing organisational units and of active participation of all hierarchical levels for the achievement of the strategy defined for the ISP To consider the existing performance evaluation system, to enhance the weighting assigned to technical competencies and to dedication by developing initiatives of professional recognition of employees To promote the involvement of ISP employees in social responsibility and solidarity initiatives Strategic Plan 2014-2016 23/27
To continue to support the activities of ISP s Casa de Pessoal which is considered an aggregating element of ISP values Objective 9 To guarantee the efficient and responsible use of the available resources. Strategy 9.1 To promote the effective use of resources and monitor the development of information systems by means of an adequate and effective management of financial and material ISP resources. To maintain policies for the acquisition of goods and services guided by principles of efficiency, fairness and social responsibility To promote dematerialisation of document and information management circuits, thus favouring electronic information management and improving its organisation and filing To strengthen the use of ISP external web portals as privileged channels for the sharing of information and facilitators of the supervisory and communication processes consistency with supervised entities To consolidate the use of the ISP Intranet site as promoter of inter-departmental collaboration, support to internal processes and as knowledge repository To favour the ISP Internet site, including the Consumer s Portal as a fundamental tool for external communication and by reinforcing its quality, current updating and ease of use To promote tools and technologies with the view of improving institutional performance Strategy 9.2 To guide the operational management and the development of systems architecture by complying with good practices. To develop IT governance/management models in order to increase quality levels in the provision of services in line with the best practices To strengthen the use of standardised information systems security rules not only for risk mitigation and resolution but also for security management process itself Strategic Plan 2014-2016 24/27
To develop and implement an information security policy, cross-sectional to the ISP and to implement information security/sensitivity management mechanisms by defining levels of access and of authorisation to information handling and management Strategy 9.3 To strengthen the structuring of the ISP risk management and internal control systems. To create an integrated risk management and internal control system and develop a crosssectional action plan across the whole organisation To implement a sound management culture based on the incurred risks and reporting practices in accordance with the regulatory provisions in force To duly document the main ISP internal processes, including controls implemented in those processes considered critical To annually prepare a report which should contain information regarding the compliance policies and internal ISP processes, as well as recommendations about possible aspects to be improved and developed To develop initiatives with ISP employees aiming at reinforcing their perception of the importance of the Plan for Prevention of Risks of Corruption and Related Infractions To ensure the maintenance and updating of the Business Continuity Plan by performing regular tests to the support systems Objective 10 To effectively manage the autonomous funds assigned to ISP. Strategy 10.1 To guarantee the maintenance of the certification for the Quality Management System for autonomous funds. To implement a sound management culture based on incurred risks and reporting practices in accordance with the regulatory provisions in force. To comply with the certification requirements of the Quality Management System Strategic Plan 2014-2016 25/27
To improve those aspects that may possibly have been pointed out in the previous certification procedures Strategy 10.2 To accurately manage financial resources allocated to the autonomous funds. To ensure compliance with the rules for granting indemnities within the autonomous funds business To improve effectiveness as regards claims management Strategic Plan 2014-2016 26/27
5. MONITORING The objectives, strategies and business plans herein defined will lead to Annual Business Plans. Apart from the activities referred to above, such plans assign initial and conclusion terms to those activities as well as the organisational units responsible for such activities. The implementation of the Business Plan is monitored on a quarterly basis. The reports associated thereto provide the performance level of such activities and allow, where appropriate, its reassessment not only in terms of timing but also in terms of the resources involved thereto. Strategic Plan 2014-2016 27/27