System of governance

This question has been rejected because the issue it deals with is already addressed in EIOPA Guidelines on System of Governance:  -    1.16: “The guidelines apply to both individual undertakings and mutatis mutandis at group level. Additionally, for groups the group specific Guidelines apply”. -    Guideline 65 - 1.118: “The participating insurance or reinsurance undertaking, the insurance holding company or the mixed financial holding company should set adequate internal governance requirements across the group appropriate to the structure, business model and risks of the group and of its related entities, and should consider the appropriate structure and organization for risk management at group level, setting a clear allocation of responsibilities at all entities that are part of the group.” In the example described, if the parent undertaking of the group is an insurance holding company, guideline 36 applies mutatis mutandis to this insurance holding company and it should develop the capital management policy for the group.