MEMORIA DEL EJERCICIO ECONÓMICO FINANCIERO 2012 / 2013

El Seguro Ambiental Obligatorio (SAO) recibió fuertes respaldos institucionales y judiciales durante el cuarto ejercicio de la Cámara Argentina de Aseguradoras de Riesgo Ambiental (CAARA), comprendido entre el 1° de mayo de 2012 y el 30 de abril de 2013.

Durante el ejercicio que se comenta el sistema del SAO resultó jerarquizado porque el cumplimiento de la exigibilidad se mantuvo en crecimiento y se afirmó el criterio de que el instrumento que lo representa es un aporte incuestionable a los mejores esfuerzos de la sociedad para desarrollar una política de Estado que favorezca la sustentabilidad ambiental al servicio del Art. 41 de la Constitución Nacional, que consagra el derecho de los habitantes de la Argentina a un ambiente sano y la obligación de las actividades productivas de preservarlo y recomponer los daños que le ocasionen.

También resultó fortalecido porque su volumen de negocios continuó en expansión al registrar a la finalización del ejercicio garantías totales extendidas por las empresas que integran el sistema por $ 12.582.530.837, a un promedio de $ 1.766.465 por póliza, mientras que la proyección de garantías al fin de 2013 se ubica en torno a $ 13.195.500.160, lo cual representa un incremento de 4,87%.

CAARA continuó a lo largo del período desplegando una intensa actividad de divulgación, promoción y defensa del sistema, destacándose el rol que desempeñó con sus aportes al Plan Nacional Estratégico de Seguros (PlaNes) 2012-2020, anunciado como una política de Estado por la Superintendencia de Seguros de la Nación.

Los objetivos de CAARA, como se ha expresado en documentos anteriores, son principalmente propender a la jerarquización de la actividad, por caso promoviendo la creación de una normativa jurídica integral del sector; colaborando y prestando asesoramiento técnico adecuado a los organismos oficiales con competencia en la actividad; promoviendo la complementación e integración con otros organismos y entidades, públicas o privadas vinculadas con la conservación del ambiente y representando a la actividad ante los sectores público y privado en todo acto que fuera necesario.

La acción de CAARA se orienta a las autoridades de aplicación, de control, a los sujetos obligados, a autoridades nacionales, provinciales y municipales; al interior del propio sector asegurador; a estudios jurídicos, en fin, a la comunidad toda.

El SAO rige en todo el territorio nacional desde el año 2008, cuando en arreglo con lo dispuesto en el mencionado Art 41 de la Constitución Nacional y en el Art. 22 de la Ley Nacional de Ambiente N° 25.675 fueron dictadas las normas regulatorias que le dan sustento y fue aprobada la denominada Póliza de Caución por Riesgo de Daño Ambiental de Incidencia Colectiva, que es a la fecha de la publicación de esta Memoria el único instrumento que permite cumplir con la ley a los sujetos comprendidos en la obligación.

La normativa en la que se apoyó el instrumento contractual del seguro se basó en lo aprobado por la Unidad de Evaluación de Riesgos Ambientales, por la Comisión Asesora en Garantías Financieras Ambientales, la Secretaría de Ambiente y Desarrollo Sustentable (SAyDS), la Superintendencia de Seguros de la Nación (SSN), y oportunamente ratificado por la Resolución Conjunta Nº 945/11 y 66/11 de la SAyDS y la Secretaría de Finanzas de la Nación, respectivamente. La SAyDS es el organismo competente en materia medio ambiente y la SSN en el de seguros.

Luego, provincias y municipios tienen facultades en sus jurisdicciones para establecer la forma de implementar la exigibilidad y fijar obligaciones adicionales. Las distintas jurisdicciones cuentan así con diversas herramientas sancionatorias, tales como multas, no otorgamiento, no renovación o suspensión de habilitaciones que refuerzan su capacidad en el ejercicio de la exigibilidad.

El interés asegurable de este seguro –que hasta la fecha consiste en una caución- es el de la comunidad. Las aseguradoras garantizan que los tomadores de la póliza se harán responsables de la remediación de los daños de incidencia colectivas producidos al suelo o al agua, relacionados con su actividad y previstos en la póliza de caución. El beneficio, en consecuencia, es para la sociedad toda y tanto la justicia como los organismos públicos –en particular la SAyDS y la Secretaría de Finanzas- rechazaron de plano los recursos planteados en contra del SAO

Es de destacar que en la actualidad, además del Seguro Ambiental Obligatorio (SAO), que es el único que cumple con la exigencia de la Ley N° 25675, existen otras coberturas que permiten la transferencia del riesgo del sujeto obligado a ese seguro obligatorio, son los casos del “Seguro de Recomposición de Daño Ambiental” (resarcitorio; la aseguradora asume el riesgo de los costos de remediación de siniestros por daños ambientales de incidencia colectiva producidos al agua o al suelo; el asegurado decide el monto del capital que requiera asegurar, y tiene una franquicia establecida a su cargo)y el “Seguro de Responsabilidad Civil por Contaminación” (.la aseguradora asiste al contratante de la cobertura, ante un reclamo, en el resultado económico del mismo).

En consecuencia, hoy no puede reprocharse a la actividad aseguradora el hecho de que asista a una obligación a favor de la comunidad sin atender la exposición del riesgo ambiental de los sujetos obligados por su actividad contaminante. Lo señalado ha significado un avance importante en esa especie de pack ambiental.

En ese contexto comentado el mercado del SAO ha ido avanzando en la exigibilidad y concreción y dando respuesta eficiente tanto al tomador (el contratante) como al asegurado (el Estado). De aquellos trabajos surgió un instrumento básicamente orientado a cumplir con la garantía a favor de la comunidad de que los pasivos ambientales de incidencia colectiva contemplados en la cobertura, emergentes de la acción productiva del tomador de la póliza, serían remediados por el propio tomador.

Un motivo preponderante en el avance del cumplimiento de la obligación es que se están garantizando y preservando los organismos requirentes, que son aquellos que bajo la tutela de la autoridad de la Secretaría de Ambiente y Desarrollo Sustentable (SAyDS) de la Nación se constituyen en autoridad de aplicación y control de la obligación. Es que la Ley y su normativa conexa (consultar en www.caara.com.ar) establecieron presupuestos básicos para el funcionamiento del sistema pero a la vez otorgaron a las distintas jurisdicciones provinciales y municipales la facultad de fijar normas complementarias antes de emprender la exigibilidad.

Así, la aplicación de la Ley se ha estado verificando en forma paulatina en todo el territorio nacional. En muchos casos los mecanismos previstos para la exigibilidad han sido inicialmente débiles y fue la Justicia la encargada de hacer cumplir la obligación.

Por el volumen de actividad industrial y de habitantes de sus jurisdicciones, los principales organismos requirentes –independientemente de la propia SAyDS- son la Autoridad de Cuenca Matanza Riachuelo (ACUMAR), el Organismo Provincial para el Desarrollo Sostenible (OPDS) de la Provincia de Buenos Aires y la Agencia de Protección Ambiental de la Ciudad de Buenos Aires.

Estos organismos tienen poder de requerir el cumplimiento de la obligación a todos los sujetos que en su jurisdicción estén comprendidos en los alcances de la reglamentación de la Ley N° 25675 (Anexo II de la Resolución Nº 177/2007 de la SAyDS y sus modificatorias) que presenten un Nivel de Complejidad Ambiental (NCA) de 14,5 puntos o más, según la fórmula polinómica pertinente, y de aplicar sanciones.

El ACUMAR es un organismo interjurisdiccional de derecho público, creado en noviembre de 2006 por la Ley Nacional N° 26.168, integrado por la Nación, la Provincia de Buenos Aires y la Ciudad de Buenos Aires que tiene competencia en los municipios ubicados en el área que cubre la superficie de la cuenca de los mencionados Rio Matanza y Riachuelo: Lanús, Avellaneda, Lomas de Zamora, Esteban Echeverría, La Matanza, Ezeiza, Cañuelas, Almirante Brown, Morón, Merlo, Marcos Paz, Presidente Perón, San Vicente y General las Heras.

La Cuenca, con más de 5 millones de habitantes, está cubierta por una intensa red industrial generadora de desechos de todo tipo que a lo largo de los años, con una actitud desaprensiva, sin ninguna mirada puesta en el futuro y ante la pasividad de las autoridades, ha convertido a las aguas y a la región toda en un pestilente foco de insalubridad que fue motivo de un resonante fallo de la Corte Suprema de Justicia de la Nación en la denominada causa “MENDOZA BEATRIZ SILVIA Y OTROS C/ESTADO NACIONAL Y OTROS S/DAÑOS Y PERJUICIOS (Daños derivados de la contaminación ambiental del Río Matanza-Riachuelo)” que ante la magnitud inusitada a escala mundial de la contaminación de la región, determinó, entre otras cosas, la responsabilidad que le corresponde al Estado Nacional, a la Provincia de Buenos Aires y a la Ciudad de Buenos Aires en materia de prevención y recomposición del daño ambiental existente en la Cuenca, y asignó responsabilidades para llevar adelante las acciones y las obras de saneamiento, el plazo de cumplimiento. Esa región es hoy, por razones obvias, la de mayor concentración de pólizas del SAO en el orden nacional.

En el ámbito de la Provincia de Buenos Aires, el poder de administración y de policía ha sido delegado en el Organismo Provincial para el Desarrollo Sostenible (OPDS) que dispone de un aceitado sistema de controladores, mientras que en la Ciudad de Buenos Aires a los mismos efectos fue creada la Agencia de Protección Ambiental Buenos Aires.

Sistema pujante

Por su elevada concentración industrial e índice demográfico, en la jurisdicción de la ACUMAR se concentra 48,17% de las garantías extendidas ($ 6.122.790.029) con un promedio por póliza de $ 1.784.550; la OPDS el 27,75% con $ 3.491.880.934 pero con una garantía promedio mayor, de $ 2.944.250.

Una apertura por sector económico muestra que la minería, como consecuencia de la magnitud del alcance de sus emprendimientos, es el mayor asegurado en montos de garantías, con 37% de ellas, seguida por la producción primaria, con 22%; el transporte, por la cobertura de sus establecimientos de apoyo, con 14% y la construcción, con 12%.

Un aspecto central de la trascendencia del SAO como herramienta de la política ambiental, es la obligación que tienen las empresas antes de contratar la póliza de realizar una evaluación de la Situación Ambiental Inicial (SAI) al momento de la vigencia de la cobertura. El SAI revela los pasivos ambientales existentes en el lugar que va a ser motivo de la garantía y contribuye al establecimiento de la prima de riesgo. El contratante se obliga a remediar los pasivos determinados en el SAI, lo cual implica que inmediatamente se inicia un proceso de reversión de los pasivos revelados.

No en vano el Presidente de la Corte Suprema de Justicia, Dr. Ricardo Lorenzetti, al hablar en el acto de la presentación de la primera póliza de seguro ambiental obligatorio, comentó que la legislación “al incorporar la obligación de prevención del daño ambiental, la de recomposición y el resarcimiento, genera algo importante que aquí está muy claramente definido, que es la noción de riesgo. Las que antes eran externalidades negativas que pagaba la sociedad –dijo- comienzan a través de estas obligaciones a internalizarse. Esto que ha estudiado muy bien el análisis económico, obliga a aquellos que tienen alguna responsabilidad en la contaminación a internalizar estos actos de acuerdo a la legislación vigente en nuestro país y hoy diríamos en casi todo el mundo”. Más honda aún ha sido la apelación de S.S. el Papa Francisco, cuando llamó a ser “custodios de la Creación, del designio de Dios inscrito en la naturaleza, guardianes del otro, del medio ambiente”.

Marco económico
Durante el año 2012 el sector asegurador se desempeñó en el marco de una desaceleración de la economía en la Argentina, caracterizada por un escenario de elevada inflación, aumento del gasto público y de la emisión monetaria, déficit fiscal y fuerte retraso cambiario que, combinado con las restricciones impuestas por el gobierno al acceso a la compra de divisas, favoreció la generación de un mercado informal de cambios donde en el último trimestre aumentó vertiginosamente la brecha entre el valor del dólar oficial y el del paralelo, lo cual se acentuó en el primer cuatrimestre de 2013. Asimismo se evidenció un contexto de mayor injerencia estatal en las actividades y decisiones del sector privado y una alta conflictividad institucional entre poderes del Estado y, también, entre el gobierno y sectores empresariales y sindicales. En el último trimestre de 2012 se registraron en la Ciudad de Buenos Aires y numerosas localidades del interior del país, dos masivas protestas contra las políticas del gobierno nacional y el primer paro general declarado, por lo menos en una década, por las organizaciones sindicales mayoritarias.

De acuerdo con el Instituto Nacional de Estadísticas y Censos (INDEC), en 2012 el PBI aumentó 1,9%, aunque consultoras privadas estimaron ese número índice entre 0 y 1%. Gran parte del crecimiento respondió a arrastre del año 2011. Asimismo, el INDEC informó que el Indice de Precios al Consumidor (IPC), por el que mide la inflación, aumentó 10,8%, mientras que para el consenso de las consultoras privadas y de organismos públicos provinciales la inflación se ubicó en torno a 25%. Las tarifas de los servicios públicos regulados aumentaron 14,3%, la tasa más alta desde el año 2007. Las estadísticas oficiales son relativizadas desde enero de ese año, cuando el gobierno introdujo cambios metodológicos en las mediciones del INDEC. Desde entonces se acumuló una diferencia de alrededor de 165 puntos porcentuales entre la inflación oficial, de 65%, y la calculada por otras fuentes confiables, que llega a 230%. La discrepancia comprende a otros indicadores económicos y sociales, cuyo patrón es el IPC.

El sector asegurador
La contribución del sector asegurador a la economía nacional durante el período fue de 3% de PBI, lo cual muestra una aceleración de esta tasa de participación en los últimos tres años.

Según estadísticas divulgadas por la Superintendencia de Seguros de la Nación (SSN), la producción del ejercicio económico 2012 alcanzó a casi 60 mil millones de pesos, incrementándose en 17% respecto a 2011, de los cuales más de 80% corresponden a los Seguros Patrimoniales, y el resto a los Seguros de Personas.

Los ramos de mayor participación fueron Automotores y Riesgos del Trabajo, que en forma conjunta representaron más de 60% de la producción del mercado y 88% de los Seguros Patrimoniales. En los Seguros de Personas, las primas se concentraron en Vida Colectivo (60%); esto es, 12% del conjunto del mercado.

El gasto promedio en seguros, medido a través de la prima per cápita, continuó creciendo, superando los $ 1.400, lo que representa 16 % más que el año anterior.

Al cierre del ejercicio el Activo alcanzó a casi a $ 93 mil millones mientras que el Pasivo superó los $ 74 mil millones, determinándose un Patrimonio Neto de más de $ 18 mil millones. Las Inversiones representan casi las tres cuartas partes del Activo, llegando a $ 67.700 millones y manteniendo la estructura de los últimos años.

Como resultado de la repatriación de capitales dispuesta por el gobierno nacional para el sector, las colocaciones en el mercado local para el cierre económico llegaron a 98% y solamente un residuo de 2% permaneció en el exterior. Se repatriaron, en términos reales, más de $ 8 mil millones.

Las Deudas constituyen uno de los componentes más significativos de los Pasivos, presentando un incremento para el año 2012 cercano a 15% que se observa atenuado en los últimos años. El componente principal son las Deudas con Asegurados, que representan más del 73% del total.

El Resultado del Ejercicio presentó saldos positivos por séptimo año consecutivo, alcanzando casi a $ 4 mil millones. Si bien, se registraron pérdidas en el Resultado Técnico durante toda la década, han sido compensadas por Ganancias Financieras, que mantuvieron una tendencia alcista de toda la serie y superaron los 7.800 millones de pesos. Las ganancias por Rentas representan el 88% del Resultado Financiero.

El SAO se exige en nuevas jurisdicciones

Como se ha dicho, la ley y la normativa regulatoria facultan a las jurisdicciones a dictar medidas complementarias de los presupuestos básicos establecidos en aquellas antes de disponer la exigibilidad. Finalizando el ejercicio anterior las provincias de La Rioja y Catamarca dispusieron mediante sendas resoluciones reglamentar la exigibilidad del SAO, pero tales medidas recién entraron en vigencia durante el ejercicio bajo consideración, al ser publicadas en los respectivos boletines oficiales provinciales. En tanto la provincia de Córdoba lo hizo el 21 de diciembre de 2012, mediante la publicación del Decreto 1130 en el Boletín Oficial provincial.

En el decreto mencionado se precisa que Córdoba sólo aceptará pólizas emitidas por compañías de seguro que hayan sido aprobadas por la Superintendencia de Seguros de la Nación (SSN), con la previa Conformidad Ambiental de la Secretaría de Ambiente y Desarrollo Sustentable de la Nación (SAyDS) en virtud de haber acreditado capacidad de realizar acciones de recomposición, mediante contratos con empresas inscriptas en el Registro Nacional de Generadores y Operadores de Residuos Peligrosos.

La exigencia en la provincia fue determinada como requisito para obtener o renovar licencias, habilitaciones, permisos e inscripciones que otorga la Secretaría de Ambiente provincial, a los titulares de establecimientos cuyo Nivel de Complejidad Ambiental (NCA) es mayor a 14,5 puntos según la fórmula polinómica y a los que así se lo solicite la autoridad ambiental por razones sitio-específicas. También ordenó la exigencia de contratar el SAO, en un plazo de 90 días, a los establecimientos con licencia ambiental vigente.

De tal forma, al cierre del ejercicio bajo consideración, además de los mencionados distritos de Córdoba, La Rioja y Catamarca, ya tienen plenamente vigente la exigibilidad, la Ciudad de Buenos Aires, la Provincia de Buenos Aires, la Administración de la Cuenca Matanza Riachuelo (ACUMAR) y las provincias de Chaco, Chubut, y Tierra del Fuego. Asimismo durante el ejercicio, el gobierno de la provincia del Chubut dispuso exigir el SAO a las empresas industriales de hidrocarburos alcanzadas por la obligación, según surge del Decreto 91/13, publicado el 13 de febrero en el Boletín Oficial de la Provincia, que reglamenta la Ley de Hidrocarburos Nº 102 de la provincia del Chubut.

La ACUMAR creó los registros de pólizas del SAO y de incidentes ambientales

Al comenzar el ejercicio bajo comentario, la Administración de la Cuenca Matanza Riachuelo (ACUMAR) creó los registros de Pólizas de Seguro Ambiental y de Contingencias Ambientales, para asentar todas las pólizas del SAO presentadas al organismo por titulares de establecimientos radicados en el ámbito de la Cuenca Matanza Riachuelo, así como los incidentes y contingencias ambientales denunciados ante esa Autoridad.

En su Art. 2º la Resolución ACUMAR Nº 661/12 establece la obligación de los titulares de los establecimientos radicados en la Cuenca con Categorías 2 ó 3, de denunciar ante la ACUMAR “cualquier incidente o contingencia que se produzca en su establecimiento, y que fuera susceptible de producir un daño ambiental de incidencia colectiva, en un plazo no mayor a 24 horas de producido el hecho”. La obligación se extiende también a su asegurador.

Esta Resolución difiere de la normativa regulatoria del SAO en tanto por un lado esta última indica que todo siniestro que pueda producir daño ambiental debe ser denunciado, incluyendo los de responsabilidad de los establecimientos de Categorías 1 y 2, y, por otro, limita a 24 horas el plazo para denunciar desde “producido” el hecho, mientras que en la normativa nacional regulatoria del SAO (Res. Conj. Nº 98/2007 y 1973/2007) “el criterio adoptado según la experiencia comparada en la materia y de acuerdo con el tipo de daño a cubrir, es el de dar cobertura a todo hecho accidental cuya primera manifestación o descubrimiento se presente durante la vigencia de la póliza, prescindiendo de la determinación de ocurrencia del daño”.

La Res. 661/12 dispone además que el incumplimiento de las nuevas obligaciones de denunciar el incidente en plazo y forma, y ejecutar acciones para minimizar el daño ambiental, hará pasible al titular del establecimiento de la sanción de multa.

Otras actuaciones que tuvo CAARA a lo largo del ejercicio, señalando solo aquellas más relevantes:

EMBATES CONTRA EL SISTEMA

Desde la misma instauración del sistema, el SAO debió sortear múltiples e injustificados reproches y recursos de poderosos sectores que fueron uno a uno desbaratados, tanto por la interpretación de la autoridad administrativa como de la judicial y con la intervención muy activa de la propia CAARA.

En los cuatro años de vigencia del sistema fundacional, CAARA debió realizar una vasta tarea institucional y de docencia para explicar a un mercado reticente que el espíritu del nuevo seguro era garantizar a favor de la sociedad, de la comunidad, del Estado, que especialmente los empresarios privados se harían responsables de remediar los daños ambientales de incidencia colectiva que ocasionaran con su accionar. Como quedó dicho, la docencia se extendió hacia autoridades de organismos públicos nacionales, provinciales y municipales en los cuales la normativa descargó la responsabilidad de producir normas complementarias a los presupuestos básicos.

Dada la reticencia comentada y el retardo en el dictado de las normas complementarias, en muchos casos la exigibilidad se demoró notoriamente o bien nunca fue puesta en vigencia. Asimismo, en jurisdicciones donde ha estado vigente, la norma no fue acompañada de una acción firme destinada a asegurar su cumplimiento. En ocasiones ha sido la Justicia la encargada de disponer el cumplimiento de la obligación.

Una cautelar impide a una compañía emitir pólizas de caución ambiental

Tal como se relató en la Memoria anterior, en la causa 55/2012 el Juzgado Federal en lo Contencioso Administrativo Nº 2 de Formosa, dispuso mediante una medida cautelar suspender las Providencias de la Secretaría de Ambiente y Desarrollo Sustentable (SAyDS) y el Proveído de la Superintendencia de Seguros de la Nación por los cuales se había habilitado a Alba Compañía de Seguros a operar en el mercado de la Póliza de Seguro de Caución por Daño Ambiental de Incidencia Colectiva, y ordenar a esta compañía “abstenerse de emitir y comercializar” el referido instrumento. La medida fue dispuesta atendiendo a un reclamo de tratamiento ilegitimo y preferencial, en violación de la garantía constitucional de la igualdad en afectación de derechos previamente reconocidos, a raíz de que Alba no cumplió el requisito de acreditar la capacidad técnica y operativa suficiente para atender y eventualmente remediar de forma inmediata los efectos de un siniestro ambiental de incidencia colectiva que garantiza la póliza

Como consecuencia de ello, en abril de 2012 la SSN informó al sector que por resolución judicial le ha sido ordenada “la prohibición de emisión y comercialización de pólizas ambientales a todas las compañías aseguradoras que no hubieran acreditado debidamente su capacidad remediadora”.

En general, las acciones contra el SAO fueron encabezadas por lobbies industriales que no reconocen la generosidad y carácter solidario y comunitario del espíritu del andamiaje legal del sistema, movilizados por una persistente acción inspirada por asesores profesionales cuyo real propósito era desbaratar la herramienta de gestión ambiental instrumentada para intentar imponer otros recursos financieros no pensados esencialmente con el interés asegurable de proteger al Estado, los bienes comunes o el interés general, como si se hizo con la póliza vigente.

Decreto y Resolución suspendidos por una cautelar

El último gran embate, que contribuyó a un estado de verdadera confusión en el mercado, fue el dictado mediante el Decreto del Poder Ejecutivo de la Nación (PEN) 1638/12, publicado en el Boletín Oficial el 11 de septiembre de 2011, mediante el cual se derogaban parcialmente las normas reglamentarias del SAO, y la Resolución Nº 37.160 de la SSN, que aprobaba con carácter general las nuevas condiciones de las dos pólizas que iban a regir en lo sucesivo, con opción del sujeto obligado a la contratación. Las nuevas pólizas eran “El seguro Obligatorio de Caución” y el “Seguro Obligatorio de Responsabilidad por Daño Ambiental de Incidencia Colectiva”. Ambas, medidas fueron preventivamente dejadas en suspenso por la Justicia, quedando por tanto plenamente vigente la normativa original.

Sin un texto que fundamente y explique, esto es, que contenga el espíritu que justifique las medidas, el PEN y la SSN dispusieron cambios fundamentales en el sistema de seguro ambiental obligatorio cuya normativa general fundacional, como se ha dicho, había sido resultado de una minuciosa tarea interdisciplinaria.

Las normas ahora suspendidas, en contraste con el espíritu original del SAO, transformaban una herramienta de gestión ambiental de carácter remediador en una mera póliza indemnizatoria, apuntado sólo al financiamiento de la reparación del daño ocasionado contemplado en la póliza, apartando, a la vez, al Organismo de Control Ambiental de su participación en la definición de los temas esenciales que hacen a la materia de su competencia.

Si bien es cierto que las condiciones que establecía la SSN en sus alternativas favorecían a las aseguradoras al eliminar el daño gradual del alcance de la cobertura o hacer aplicable exclusiones diversas, a la vez determinaban que los nuevos instrumentos no fueran de utilidad al fin originario, que era la garantía al Estado.

El principal cambio que implicaba la reforma suspendida era que mientras en el sistema original se apunta a remediar los daños ante el incumplimiento del sujeto obligado, dando certidumbre a la reparación mediante la exigencia a las aseguradoras de contar con la capacidad suficiente para cumplir con lo que establecía la póliza, la normativa suspendida no exigía esta condición sino sólo el financiamiento del pago del siniestro.

Otro cambio sustantivo era el desplazamiento de la SAyDS de las funciones que le competían, que consistían en establecer y revisar periódicamente los rubros de actividades riesgosas, la categorización de industrias y actividades de servicio según el Nivel de Contaminación Ambiental, y el Monto Mínimo Asegurable de Entidad Suficiente en la materia. Todo ello pasaba a la órbita administrativa de la Jefatura de Gabinete de Ministros, de la cual depende la SAyDS.

De tal forma, la SSN quedaba como único organismo encargado de elaborar y aprobar los planes de seguros correspondientes para dar cumplimiento a lo previsto en el artículo 22 de la LGA, como es su competencia específica. Es que, al derogarse la Resolución 35168, se eliminaba la necesidad de contar con la “Conformidad Ambiental” de la SAyDS como requisito previo a la aprobación de las pólizas ambientales por parte de la SSN.

En tanto la SSN a través de la Res 37160 creaba dos pólizas para optar por una para el cumplimiento de la obligación legal de asegurar, cuando la obligación en el sistema original es una sola, contenida en una única norma (el referido Art. 22 de la Ley 25675), y sin que se le reconociera legitimación a la voluntad del sujeto obligado para determinar el alcance de la cobertura que debía tomar.

Otro cambio importante era que se convertía en obligatoria y con carácter de declaración jurada la presentación del SAI ante la autoridad competente que el sujeto obligado al seguro debe realizar al momento de contratar la póliza a fin de relevar el riesgo y detectar daños preexistentes y que es un documento confidencial entre el tomador y la aseguradora. Asimismo, en la determinación de la situación ambiental inicial (SAI) art. 4º del Anexo, se pone ahora en cabeza del asegurador la función de fijar las metodologías para la determinación del SAI.

En el seguro de caución suspendido se establecía como “Causas imputables al tomador por daños ambientales” a los hechos “ocurridos de manera accidental y realizados durante el ejercicio normal y habitual de su actividad riesgosa, que deriven en un daño ambiental de incidencia colectiva”, incorporando así un concepto novedoso y confuso por cuanto si bien refiere a la responsabilidad ambiental del tomador del seguro, introduce una causal de exención de responsabilidad no prevista por la LGA, por lo que la póliza podría ser tachada de no cumplir con la ley.

Restringía además la cobertura a actos, hechos u omisiones del tomador/asegurado (según la póliza que se trate) o de sus dependientes, ocurridos de manera imprevista y accidental, dejando sin cobertura hechos no accidentales, como por ejemplo sabotajes, culpa grave, dolo y corrosión o desgaste natural en el tiempo. Limitación que se hace extensiva a los dependientes del tomador/asegurado contrario al art. 31 de LGA.

Seguro de Responsabilidad

Una apreciación de carácter general en la definición de este seguro, ahora suspendido, sería que de la redacción de los artículos 2°) Riesgo Cubierto, 7°) Denuncias de Acontecimientos y Siniestros – Cargas del Asegurado y 8°) Verificación del Siniestro, se interpreta que se trataría de una póliza indemnizatoria frente a la ocurrencia de un hecho que configure un siniestro cubierto, es decir de daño directo. No se requería como condición precedente el reclamo de un tercero ni había indicación de procedimiento alguno a seguir frente a una demanda civil o penal. En consecuencia, este seguro no era una póliza encuadrable de Responsabilidad Civil, al no funcionar como tal.

El Art. 9º, “Pago del Siniestro”, no definía cómo se determinaba si procedía o no el pago: si fuera mediante probanzas en juicio, se opone a lo dispuesto por Decreto. 1638, artículo 7º, donde dice que “una vez autorizadas las tareas de recomposición, el asegurador hará efectivas las sumas de dinero necesarias para solventarlas”.

Por último, y aún admitiendo que la normativa suspendida contenía aspectos que favorecían a las aseguradoras, en la redacción del Decreto 1638/12 al cual refiere la Resolución 37160, no había sido tomado en cuenta el “Principio de no Regresión” del derecho ambiental, que plantea la no revisión de avances ambientales que impliquen un retroceso en materia de protección y estándares ambientales por considerárselos, de alguna forma, derechos adquiridos a favor de la comunidad.

Fallos judiciales

El Juzgado Contencioso Administrativo Federal Nº 9, a cargo del Dr. Pablo G. Cayssials, en la causa caratulada “Fundación Medio Ambiente c/ EN –PEN- Dto. 1638/12 –SSN-Resol 37160 s/ proceso de conocimiento”, hizo lugar a la demanda de la parte actora y dictó una medida cautelar mediante la cual suspendió los efectos del Decreto y la Resolución mencionados, ampliando así una cautelar dictada anteriormente en autos “Fundación Medio Ambiente c/ EN –Secretaría de Ambiente y DS y otros s/proceso de conocimiento”, (causa 1892/12). Los efectos de las medidas cautelares regirán hasta que sea dictada sentencia definitiva o se modifiquen las circunstancias que la determinaron.

En la medida cautelar dictada por el Juzgado Federal 9 se ordenó que antes de antes de aprobar la emisión o comercialización de pólizas de Seguro Ambiental Obligatorio (SAO) en los términos del Artículo 22 de la Ley General de Ambiente N° 25.675, se requiera la conformidad ambiental otorgada por la Secretaría de Ambiente y Desarrollo Sustentable de la Nación (SAyDS) y se acredite la capacidad técnica para remediar, mediante contratos suscriptos con operadores debidamente habilitados. El fallo repuso, en consecuencia, las Resoluciones Nº SAyDS 178/07 y SF 12/07, SAyDS 1973/07 y SF 98/07, y SSN 35.168/10 que forman parte del andamiaje constitutivo del SAO así como a la “Póliza de Caución por Riesgo de Daño Ambiental de Incidencia Colectiva – Garantía de Remediación”, que fue aprobada por la SSN mediante el Proveído 108126 del año 2008. A consecuencia de la citada disposición judicial, esta póliza continuará siendo el único instrumento válido para cumplir con la obligación emanada del Art. 22 de la Ley 25.675.

En los considerandos de la cautelar, el juez señala que adopta la medida por observar que “se encuentran en juego derechos y garantías constitucionales de todos los habitantes de la Nación, como son el derecho a gozar de ‘un ambiente sano, equilibrado, apto para el desarrollo humano y para que las actividades productivas satisfagan las necesidades presentes sin comprometer las de las generaciones futuras, teniendo el deber de preservarlo’. Máxime, cuando la Ley Fundamental expresamente consagra que ‘El daño ambiental generará prioritariamente la obligación de de recomponer’ y que ‘las autoridades proveerán a la protección de este derecho, (…) a la preservación del patrimonio natural (…) y de la diversidad biológica’” (Art. 41 de la Constitución Nacional)”.

Afirma el juez que “sin perjuicio de lo determinado por la autoridad de aplicación, si el seguro por daño ambiental de incidencia colectiva tiene por objeto primordial garantizar la recomposición del daño, no cabe más que concluir” que el Decreto 1638/12, publicado en el Boletín oficial el 11 de septiembre, y la Resolución SSN 37.160 “en tanto disponen cláusulas limitativas del riesgo y excluyen a la SAyDS de la aprobación de las pólizas, cuando es obligación y tarea primordial de esta su aprobación, así como la determinación del monto mínimo asegurable, vulneran el espíritu que la ley de medio ambiente y la Constitución Nacional intentan resguardar”-

Advierte después el magistrado que “si en materia ambiental se debe evitar –primero- que se contamine y, si ello ocurre, por ser inevitable, o por dolo o por culpa, se debe remediar el ambiente para volver –en tanto ello sea posible- al estado anterior, siendo la última opción, en caso que la remediación fuese imposible, proceder a la indemnización (conf. Art. 28 Ley 25.675 y CSJN In re: ‘Mendoza, Beatriz Silvia’ -o causa del Riachuelo-), debe primordialmente ponerse de relieve la importancia del cumplimiento ‘sine quanon’ de los requisitos contenidos en la normativa aplicable a la emisión de las referidas pólizas”.

Por último el juez dijo que dicta la medida cautelar por “vislumbrar el peligro que configuraría la circulación en el mercado asegurador de instrumentos que no alcancen a cubrir los mínimos legales exigidos por la legislación aplicable a la materia”.

Con posterioridad al cierre del ejercicio la Sala II de la Cámara Nacional de Apelaciones en lo Contencioso Administrativo Federal rechazó la apelación interpuesta por el PEN y confirmó la medida cautelar que dejó en suspenso los efectos del Decreto 1638/12 y de la Resolución SSN 37160/12 a la que había hecho lugar el juez de primera instancia.

La Cámara, integrada por los jueces Dres. Luis M. Márquez, Jose Luis López Castiñeira y Sergio Gustavo Fernandez, sostuvo que “ni una resolución ministerial ni un simple decreto del Poder Ejecutivo podrían limitar válidamente los alcances del seguro previsto en el artículo en el artículo 22 de la Ley General del Ambiente y que debe garantizar la obligación consagrada en el artículo 28 de la mencionada ley, es decir, el restablecimiento irrestricto del daño ambiental de incidencia colectiva al estado anterior a su producción”

El juez de primera instancia había ordenado “a la Superintendencia de Seguros de la Nación que adopte los procedimientos necesarios para requerir, previo a la emisión o comercialización de pólizas -en los términos del art. 22 de la Ley General del Ambiente- la conformidad ambiental otorgada por la SAyDS, y que se haya acreditado la capacidad técnica para remediar, mediante contratos suscriptos con operadores debidamente habilitados, conforme lo establecido en el régimen vigente, hasta el dictado del decreto cuya suspensión se resuelve”.

En ese sentido la Cámara opinó que “si la cobertura obligatoria exige -en los términos previstos por la normativa sustancial- asegurar el cumplimiento del deber de restablecimiento, no parece coherente con el diseño del sistema, un régimen de seguro que a través de las condiciones generales de las pólizas por emitirse, omita prever y establecer en cabeza del asegurador, la obligación de adoptar las medidas necesarias y conducentes para satisfacer aquél deber de prevención y remediación, mediante la contratación de aquéllas entidades que por su organización empresarial, especialización profesional e implementación de los medios materiales y humanos pertinentes, se encuentren en condiciones de llevar adelante las acciones concretas que sean necesarias y apropiadas para arribar a dicho resultado.-

Asimismo el tribunal de alzada consideró que las normativas impugnadas, que incluían cláusulas limitativas del riesgo y excluían a la Secretaria de Ambiente y Desarrollo Sustentable de la aprobación de las pólizas “cuando es obligación y tarea primordial de ésta su aprobación, así como la determinación del monto mínimo asegurable”, vulneran el espíritu que la ley de medio ambiente y la Constitución Nacional intentan resguardar.

Por otra parte, el fallo de Cámara señala que el juez de primera había destacado el peligro que configuraría la circulación en el mercado asegurador de instrumentos que no alcancen a cubrir los mínimos legales exigidos por la legislación aplicable en la materia.

Transporte de sustancias y residuos peligrosos

Una nueva emergencia judicial atraviesa el sistema del SAO desde el final del ejercicio bajo comentario. El 27 de febrero fue dictada la Resolución SAyDS 177/2013 mediante la cual se define la forma de obtener el Monto Mínimo de Entidad Suficiente (MMES) para fijar el capital asegurado exigible al transporte, vial y ferroviario de materiales, sustancias, mercancías y residuos peligrosos, haciendo funcional lo resuelto normativamente en su oportunidad cuando se encuadró a esta actividad en la categoría 3 y por tanto sujeto obligado a contratar el SAO. En la misma medida, publicada el 6 de marzo en el Boletín oficial, se dispuso elevar el Factor de Correlación –que integra tanto la fórmula polinómica de determinación del MMES para las instalaciones fijas como la correspondiente al transporte de materiales, sustancias, mercancías y residuos peligrosos-, llevándolo de 400 a 800, valor que será actualizado anualmente. La Resolución mencionada no alteró elemento técnico o contractual alguno que requiriera de modificaciones en los instrumentos en utilización.

No obstante, una vez concluido el ejercicio, en el mes de mayo, la SAyDS, mediante Resolución 600/2013 suspendió por 90 días la aplicación del artículo 3° de la Res. 17713 mencionada anteriormente que había creado la formula por la cual se hacía posible cubrir el transporte de sustancias y residuos peligrosos. Tal suspensión se adoptó en virtud de que la SSN consideró que el SAO merece algún tipo de ajuste a las particularidades propias de la actividad de transporte y por tanto se debería ajustar la redacción del articulado para la póliza en cuestión a fin de que brinde cobertura a esta actividad.

Es de hacer notar que la suspensión de la Resolución deja sin cobertura al propio Estado en un segmento tan sensible como es el del transporte aludido, cuando los instrumentos contractuales le son aplicables.

Escollos anteriores

Como se relató en la memoria anterior, la acción pertinaz en contra del SAO había tenido un hito en un recurso administrativo interpuesto por la Unión Industrial Argentina (UIA) con 130 empresas y organizaciones adherentes, el cual fue rechazado en todos sus términos por el Estado nacional mediante una Resolución Conjunta de las Secretarías de Finanzas y Ambiente y Desarrollo Sustentable (Nros. 66/2011 y N° 945/2011, respectivamente) que declararon agotada la vía administrativa, y que si bien había dejado abierta la vía judicial, los industriales no realizaron presentaciones en esa instancia.

La presentación de los industriales había apuntado contra el Anexo “Pautas Básicas para las Condiciones Contractuales de las Pólizas de Seguro de Daño Ambiental de Incidencia Colectiva” de la Resolución Conjunta de las Secretarías de Ambiente y Desarrollo Sustentable (SAyDS) y de Finanzas de la Nación N° 98/2007 y 1973/2007, en un reclamo que resumió todos los cuestionamientos que tanto las empresas como sus asesores jurídicos fueron manifestando contra el SAO. Las respuestas de los organismos públicos desnudaron en aquella ocasión carencia de sustento del asesoramiento que recibieron las empresas y la UIA.

Casi en simultáneo, un fallo judicial ordenó a la empresa YPF S.A. contratar el SAO para sus cuatro plantas de la Cuenca Matanza-Riachuelo, conforme a lo exigido por la Ley N° 25.675, Art. 22, y a lo reglamentado en la Resolución Conjunta 98/2007 y 1973/2007, precisamente la que había sido cuestionada por la UIA.

ACTIVIDADES DE CAARA

Participación en el PlaNes 2012-2020

CAARA tuvo durante el año 2012 un papel destacado en la elaboración del Plan Estratégico Nacional del Seguro (PlaNES) 2012-2020. El presidente de la Cámara, Sr. Jorge E. Furlan; el entonces vicepresidente, Sr. Gustavo Roldán, y la Asesora Jurídica Ambiental, Dra. Silvia Raninqueo, fueron invitados por la SSN a participar el 10 de mayo de la primera de una serie de reuniones y talleres en el marco del inicio del proceso “participativo”, de “construcción colectiva” del PlaNeS 2012-2020, proyectado por el Gobierno para incrementar la producción del seguro a nivel nacional, mejorar la prestación del servicio a los asegurados y colaborar con el desarrollo nacional. Con posterioridad, otros directivos de empresas asociadas a la Cámara también participaron de estas reuniones.

CAARA fue integrada al “Foro Económico Asegurador (Cámaras Aseguradoras y Reaseguradoras)” donde presentó una serie de consideraciones y aportes al borrador inicial del Plan, los que mayormente fueron aceptados por la SSN. Entre esas propuestas se de CAARA el Plan incluyó:

– En general, la variable ambiental como parte del desarrollo sostenible a alcanzar a través de la actividad aseguradora.

– Como otros objetivos del Fin Estratégico Social del Plan (fin que “incluye objetivos referidos sobre todo a la importancia del desarrollo de una cultura aseguradora. Contempla los derechos y responsabilidades de los actores y establece la necesidad de una mejora continua de la actividad para la generación del bienestar general (generación de empleo, aumento de la productividad laboral, excelencia en la prestación del servicio, reducción de la siniestralidad, inclusión social, desarrollo con sustentabilidad ambiental, entre otros): “Impulsar desde el Estado estrategias orientadas a la transferencia de riesgos de proyectos con alto impacto social, y en particular, a la internalización de los costos negativos por parte de los responsables de actividades ambientalmente riesgosas” y también: “Impulsar la responsabilidad social empresaria como herramienta clave del modelo de gestión de las aseguradoras, generadora de mejoras competitivas y gestionadora de riesgos, contribuyendo al mejoramiento económico, social y ambiental, que permita alcanzar un desarrollo sostenible y un valor agregado de la actividad.”

Carta al Superintendente de Seguros

Con motivo de declaraciones periodísticas del presidente de la SSN, Lic. Juan A. Bontempo, sobre el sistema del seguro ambiental obligatorio y el Decreto nº 1638/2012 formuladas el 15 de septiembre al programa Tiempo de Seguros, en las que hizo claras referencias a CAARA, el presidente de la Cámara, le remitió una carta en la que le formuló precisiones sobre los alcances y objetivos de la misma.

Señalo que “es cierto, y motivo de orgullo de sus fundadores y pioneros, que CAARA es la única entidad que congrega a compañías aseguradoras que se han interesado sobre el desarrollo del tema. Sin embargo –agregó-, lejos de focalizar en un sólo instrumento, como Usted manifiesta, los objetivos de CAARA son, principalmente, propender a la jerarquización de la actividad del seguro ambiental, por caso, colaborando y prestando asesoramiento técnico adecuado a los organismos oficiales con competencia en la actividad aseguradora o ambiental; promover la complementación e integración con otros organismos y entidades, públicas o privadas, vinculadas a la conservación del ambiente; y representar a la actividad ante los sectores público y privado en todo acto que fuera necesario”.

Seguidamente le informó que “CAARA ha desarrollado sus gestiones hasta la actualidad sin limitarse a la cobertura aprobada oportunamente en el ramo caución, sino que, además, ha contribuido con su apoyo técnico a la implementación de otras pólizas, en ese caso facultativas y no aplicables para cumplir con el artículo 22 de la Ley 25675, que difunden sus aseguradoras afiliadas en los ramos de la responsabilidad civil o riesgos varios” y le aseguró que “CAARA dará acogida favorable a todo instrumento de seguro ambiental y a toda empresa, cámara o integrante del sector interesado genuinamente en participar y enriquecer nuestra actividad, que claramente no se limita a un solo instrumento, aunque debe reconocerse que la aludida caución ha sido el primero que cumplió con la exigencia de la mencionada ley, demostrando claramente su virtuosismo en los casos en los que ha sido activado, sin decir de su enorme contribución, efectiva y potencial, a la reducción de la grave situación nacional en materia de pasivos ambientales”.

No obstante, se reconoció que “a lo largo de sus más de tres años de existencia, CAARA ha combatido enérgicamente algunas pretensiones de convertir en instrumento del seguro ambiental obligatorio a herramientas financieras y comerciales que nada tienen que ver con la actividad aseguradora y que han estado siendo promocionadas por consultoras y otro tipo de organizadores de negocios utilizando como argumento la descalificación de la caución, instrumento este de largo predicamento en el ámbito del seguro. La firmeza puesta en esta defensa –enfatizó por último- puede confundir al observador y hacerle interpretar que CAARA es una entidad sesgada a un solo producto”.

Respuesta a AACREA

En mayo de 2012 el Presidente de CAARA, respondió a una serie de consultas de la Asociación Argentina de Consorcios Regionales de Experimentación Agrícola (AACREA) en relación con los riesgos ambientales de las actividades desarrolladas por las empresas que integran esa institución (dedicadas a la cría de ganado extensivo e intensivo -feed lots-, tambos, cultivos extensivos) y su cobertura por el SAO.

Disertación en Chubut

El Sr. Hildo Cuffia, miembro de la compañía asociada Prudencia Seguros, asumiendo el carácter de representante ante CAARA, tuvo a su cargo una exposición explicativa en la Jornada de Capacitación sobre “Seguro Ambiental Obligatorio y Responsabilidad Social Empresaria” organizada por el Ministerio de Ambiente y Control del Desarrollo Sustentable de la Provincia del Chubut.

Reunión con funcionarios cordobeses

Autoridades de CAARA recibieron el 4 de octubre a asesores de la Municipalidad de Córdoba para asesorarlos sobre el SAO y su reglamentación. Participó de la reunión el Sr Fernando Orta, de TPC, aseguradora que integra la Cámara.

Exposición en Tucumán

La Asesora Jurídica Ambiental de CAARA, Dra. Silvia Raninqueo, disertó en la Jornada “Industria y Eficiencia Ambiental en el NOA”, realizada el 1° de octubre de 2012 en San Miguel de Tucumán. La exposición fue titulada “Seguro Ambiental Obligatorio: marco regulatorio, origen y exigibilidad”.

Aclaración a comercializadores de hidrocarburos

Con la firma del presidente de CAARA, Sr. Furlan, el 12 de marzo de 2013 le fue remitida una nota al Presidente de la Confederación de Entidades del Comercio de Hidrocarburos y Afines de la República Argentina, Sr. Oscar Díaz, en relación con declaraciones periodísticas sobre el SAO formuladas por su asesor legal, Dr. Francisco Berdaguer, en las que mencionaba que este instrumento estaba suspendido a consecuencia del Decreto. 1638/12 y la Res. SSN 37160. El Sr. Furlan ofreció el asesoramiento de CAARA a fin de profundizar sobre la aplicación y el desarrollo alcanzado por el SAO en el país.

Se recordó que han recobrado vigencia las resoluciones originarias que dieron autorización al SAO. Y es acorde a tal situación jurídica que las compañías aseguradoras que integran nuestra Cámara se encuentran hoy operando en el mercado de la caución obligatoria”.

Intensa gestión de divulgación

Asimismo fue muy intensa la actividad de CAARA durante todo el año destinada a evacuar consultas de particulares (representantes técnicos de empresas alcanzadas por el SAO, en general) y productores de seguros en relación a la cobertura del SAO, personalmente, por vía telefónica o por mail. También fue muy activa la participación de la Cámara en la escena pública, especialmente sectorial, a través de artículos periodísticos y reportajes en medios especializados y generalistas, tanto gráficos como radiales, televisivos y digitales. Asimismo se continuó con la edición del Newsletter oficial SAO.mag, en el que periódicamente se dan cuenta de las actividades de CAARA, se publican informaciones sectoriales y novedades de interés público.

Asamblea ordinaria de Asociados año 2012.

En la sesión celebrada el 31 de agosto de 2012, la Asamblea Ordinaria de Asociados de la Cámara Argentina de Aseguradoras de Riesgo Ambiental (CAARA) realizó la elección de los miembros de su Comisión Directiva para los siguientes dos años, por vencimiento de los mandatos, y aprobó el Balance General y la Memoria del Ejercicio 2011/2012, cerrado el día 30 de abril.

El máximo organismo estatutario de la Cámara reeligió como Presidente al Sr. Jorge E. Furlan, de Prudencia Compañía Argentina de Seguros Generales S.A., como vicepresidente a la Sra. Ana Cosiansi, de Nación Seguros S.A.; como secretario al Sr. Gustavo D. Roldán, de Testimonio Compañía de Seguros S.A., y como tesorero a la Sra. Silvia Adriana Wickman de NGN S.A., en tanto fue elegida Revisora de Cuentas la Dra. Noemí Pellegri

En el curso de la Asamblea, desarrollada en la sede de la entidad, el presidente, Sr. Furlan, comentó acerca de la evolución del mercado asegurador en su conjunto y en particular de la exigibilidad del seguro ambiental y de las novedades normativas producidas durante el ejercicio informado, señalando que el sistema registró un “gran impulso”, tal como se menciona en el texto de la Memoria.

Entre sus consideraciones generales merece destacarse, las puntualizaciones realizadas en cuanto al resultado de la gestión de divulgación llevada a cabo por CAARA, la eficiente gestión de las empresas que actúan en el rubro para atender los requerimientos, la mayor concientización de los sujetos obligados, la actuación de la Justicia, así como de las medidas regulatorias y administrativas de distintas jurisdicciones y la incorporación de nuevos distritos al sistema.

En el período comentado se consolidó asimismo el reconocimiento y la jerarquización adquirida por CAARA como referente sectorial, lo cual quedó evidenciado por la participación que se le ha asignado a la Institución en diversos eventos, y, en forma especial, la convocatoria que le formuló la Superintendencia de Seguros de la Nación (SSN) a ser parte del proceso participativo para la elaboración del “Plan Nacional Estratégico del Seguros 2012-2020”.

CAARA fue constituida con el objetivo de asumir la representación, promoción y defensa de la actividad aseguradora ambiental en todas las formas que resultan de la legislación, y de las empresas que la integran o actúan en la materia.

Nuevo socio adherente y renuncia de socio activo.

Por otra parte, durante el ejercicio comentado la empresa Arg Group S.A. se incorporó como Socio Adherente de CAARA. Arg Group interviene en la intermediación de seguros y resaseguros a nivel internacional. Desde sus inicios participó activamente en el desarrollo de la actividad aseguradora de aviación, por entonces embrionaria de la Argentina, para constituirse en uno de los referentes del mercado de reaseguros internacional.

Por otra parte, Nación Seguros, notificó fehacientemente su desafiliación a CAARA con fecha 11/10/2012. sin invocar la causa de su decisión, y, asimismo, también se desafecto a la Dra. Ana Cosiansi del cargo de Vicepresidente de la Cámara, teniendo en cuenta que Nación Seguros informo que con fecha 24/08/2012 la citada renunció a esa Empresa.

Balance Económico Financiero del ejercicio 2012/2013

El Balance del ejercicio económico financiero cerrado el 30 de abril del año 2013 busco que los aportes de las asociadas activas cubrieran los costos generales de la Cámara. Con tal motivo, los ingresos se corresponden con las erogaciones realizadas y ciertos gastos reflejan disminuciones en los montos respecto del ejercicio anterior y este tiene que ver con el hecho de que las asociadas activas tomaron a su cargo los mismos como el rubro de alquileres o el de los gastos en difusión, publicaciones, viajes o atenciones a terceros.

Por lo señalado, el resultado deficitario de $ 17.791,17 se corresponde con las amortizaciones de los bienes de uso que alcanzan a $ 20.906,91.

El informe del Auditor es favorable a la exposición presentada al señalar que los Estados reflejan razonablemente la situación patrimonial.

Buenos Aires, 30 de agosto de 2013.

4.118 Comments

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  5. 贅沢品の販売に関しては中国で勢いの話題はすでに話減速時間。また、すべての十年に一度の政権交代に敏感な時期も、関係者の間に贅沢な贈り物の行為は収斂。
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  6. 会見のゲストが含まれます:ロレックス最高経営責任者官迈ヤルノ(Bruno Meier)さん、国家体育総局にボールが運動管理センターの主任、中国ゴルフ協会副会長兼秘書長张小宁さん、中国ゴルフ協会副会長王立伟さん、上海市体育局副局長陈一平さん、上海市体育局競争処処長崔一宁さん、R&Aアジア太平洋区総監多米尼兄・ヴォル(Dominic Wall)さん、アメリカPGA選手権国際事務常務副総裁Ty Votawさんや身をロレックス巡茶」の世界トップ選手梁文冲。
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  7. 本紙の取材で川の説明では、インターネットの発展につれて、ますます多くの人が、たとえば若い一族や新型ホワイトカラーなど、習慣やネットショッピングのほうが好きで、この部の需要を満たすために、シチズン在中の公式サイトが登場したオンライン注文;また、シチズンの製品種類豊富で、どんどん新品発表が、いくつかの二、三線市場で、時には店頭販売の種類も豊富ではないし、オンライン注文を満たすことができるこの一部の消费者の個性化の需要。
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  8. 12ヶ月前、アカザのコーニングはメルボルン運転フェラーリ初もぎ取る大会冠。ウブロスーパーコピー今年から見れば、オーストラリアの全体の2008フォーミュラ1シーズンは、4位のタグホイヤー大使得意満面にかけているタグホイヤーの代表。
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  9. スイス時計レーダー表(RADO)が再び注目を全天下の神仙仲間たちのために永遠の愛情のタイムマシン、ホワイトデーを前に出しD-Star限定モデルのRattrapanteダブルカウントダウン追い針自動時計は、今年はあなたに恋人の最も貴重な限定時計。スーパーコピークリスチャンディオールまた、レーダー表にもオススメの古典シリーズを満たすために、人々の多様な選択情。完璧丸いボックスダイヤル皓星シリーズは、復古婦美の楕円型ケースは操守愛情の最優秀時間の。そして薄型セラミック腕時計は、軽薄で時計を伝えて二人の世界の愛は無限。ホワイトデーに間もなく到来して、レーダー表がもたらすあなたに時々刻々至情愛するでしょう!
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  10. 購入した5万匹ガス針表、過酷な戦争環境をより強調ガス針表卓越した品質、後はガス針表軍の必要な装備の一つとして。ウブロコピーガス針表の夜光機能がより随一、発光時間が長く、発光効果も深く各国軍尊重の重要な原因の一つ。
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  11. ボル表(アジア)上海で冠亚時計城の南京西路店で開かれている2009バーゼル鑑賞サロンでは、この中国の消費者に正式に推薦その年度腕時計の新しいデザイン。エルメススーパーコピー今回の露出計5つのシリーズは、2009年にリリースした新しい係デザインだけでなく、全シリーズの汽灯技術普及を続け、更に発揮2009年国際腕時計の設計風潮。
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  12. また、ロレックス支持を高協と世界トップゴルフ大会機構の連絡、:サン・アンドリュースロイヤル古いゴルフクラブ(R&A)、アメリカPGA、女子プロゴルフ協会(LPGA)、アメリカゴルフ協会(USGA)、ヨーロッパツアー(Europeanツアー)、アメリカ名人戦(ザMaters)靑少年、アメリカゴルフ協会(AJGA)、PGAツアー(PGAツアー)を賛助中国ゴルフ協会と世界級のゴルフ大会組織と協力を含むエビアンマスターズ(Evianマスターズ)とエビアン靑少年マスターズ(ジュニアEvianマスターズ)。中国のゴルファーの訓练プロジェクトや靑少年の育成プロジェクトをロレックスの支持を得る。ロレックス_スーパーコピー時計サン・アンドリュースロイヤル古いゴルフクラブ(R&A)(美、カナダ、墨のほかにゴルフ競技の管理担当機関)に出版された『ゴルフルール』(RulesオブGolf)と言われるロブ運動の権威の典籍、本の中国語版の出版をロレックスまでの独占賛助。また、同項の戦略的協力のパートナー関係を深めると同じくきっと気ままなその後ロレックス国内トップゴルフ競技の関係を含む:例えば、ボルボオープン(Volvoチャイナの)、アジアアマチュア选手権(アジアンAmateur Championships)と世界選手権- HSBC选手権(WGC HSBC WorldGolf Championships)
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  13. 父親になる男より感性。職場でもビジネスが忙しくて、心の中は常に牽掛――も子どもに与えたい多くの愛と付き添って、子どもの成長を楽しむ喜び。シチズン純黒版スーパー空の鷹JY8009-55E腕時計、身の人の親のエリートの事を提供するともっと正確な時間管理を楽しむスーパーコピーブルガリ 時計。シチズン技術を採用し、その光エコ・ドライブ電波吸収、いかなる光源に転化する運動エネルギーを時計運転すれば、光がエネルギーさえすれば、受信電波が自動補正時間、永遠にない誤差。スーパー空の鷹の特徴はそれより多く局受信標準時電波が、世界的に29タイムゾーン43都市より正確な時間によると、30分の時差を示しても、君がいるヨーロッパ、アメリカ、中国も日本所在都市名を選んで、現地時間の標準が自動受信電波が、正確に切り替えて現地時間。また、スーパー空の鷹はのJIS1型耐磁性能、衝突検出機能と指針修正機能、より正確にも挑戦させて恐れない、完璧な表現は一貫して、異郷の時間、方便用時計、れ、クロノカウントダウン、カウントダウン・充電喚起など多彩な機能に男はさらに対応父の後の新しい生活をよりを楽しみと幸福な人生旅;ORIS時計コピー人間化の現地時間騒ぎ響と異郷の時間が機能を問わず、父親たちの何処かで、いつでも注意しても、彼らについて子供のいかなる時間の詳細。
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  14. 梁文冲と张连伟先月引き受ける美の中国の精鋭試合冠軍、あとでHSBC選手権とUBS香港公開戦もよい発揮。梁文冲彼の良い表現を通して、ドバイ・ワールド選手権陣に入った、同時に彼はアジアツアー賞金ランキングでも位。梁文冲「私と兄さえ偉数年来ずっと外徴戦で、我々は、すべての中国のもっと良い未来がある。ワールドカップは私と兄めったに協力のチャンス。HUBLOT時計コピー現在、中国の最高水準を代表しました。しかし同時に、私たちも希望未来多く靑少年を超えて私達の選手。私はこれも二人が見たくないこと。私をとても大事にしても偉兄貴パートナーごとに1つの機会に、私は私たちの中国靑少年に良い模範を確立して、私たちの良い成績を励まして進む。」
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