1. Introduction

Resolution Life Group Holdings Ltd and the respective subsidiaries (“Resolution Life”) understands it has a responsibility to manage material environmental and social issues in its investments, operations and supply chains. If Environmental, Social and Governance (“ESG”) matters are not managed adequately, they can escalate into material reputational and financial risks.

This policy sets out Resolution Life’s obligations and commitments to environmental and social responsibility and good corporate governance, to our investors, our employees, and the communities in which we operate.

This document complements Resolution Life’s other policies including: Responsible Investment Policy, Code of Conduct, Workplace Health & Safety Policy, Equal Opportunities and Dignity at Work Policy, Modern Slavery Statement and Procurement Policy/Supplier Code of Practice.

2. Purpose

The purpose of this policy is to set out Resolution Life’s ESG principles (“the Principles”), describe how we will implement our principles and outline the global ESG standards which we aim to adhere to.

3. Relevant rules and regulations

3.1 Global ESG Standards

In developing our ESG policy, we have considered a range of international standards to guide our approach. We have a commitment to continuously monitor the evolving risk and regulatory landscape from both a global and local perspective to ensure our business operations are in line with current standards.

3.2 UNPRI

The Principles for Responsible Investment is a United Nations-supported initiative which promotes ESG being incorporated into investment decisions, ownership and asset management. Through its network of signatories, the UNPRI encourages investors to use responsible investment to enhance returns and better manage risks.

On 22 September 2022, Resolution Life became a signatory to the UNPRI, demonstrating Resolution Life’s commitment to responsible investing while building a more sustainable financial system. As part of our signatory status Resolution Life will continue to develop our Responsible Investment Policy which describes the principles and requirements for responsible investment across all subsidiaries of the Resolution Life Group and serves to integrate ESG analysis into our asset management processes and requirements.

3.3 Task Force on Climate-Related Financial Disclosures

The Task Force on Climate-Related Financial Disclosures (TCFD) was created in 2015 by the Financial Stability Board to develop consistent climate-related financial risk disclosures for use by companies, banks, and investors in providing information to stakeholders. In developing our ESG Policy, we have considered the

TCFD’s recommended framework for climate related disclosures. Resolution Life will consider the metrics of the TCFD when preparing its annual report and other specific ESG related reporting.

4. Scope and Application

4.1 Scope

This policy applies to Resolution Life and all persons working for Resolution Life, including permanent employees, officers, contractors, secondees, interns, directors or otherwise (“Employees”).

4.2 Application

Minimum requirements for Business Platforms

To establish an ESG policy adopting the Principles listed in this policy in a manner appropriate to the size and scope of their specific business models.

A commitment to local best practice for corporate governance, consistent with Group requirements.

To attend and report to the Group Management ESG Committee and provide inputs to the RLGH Board Risk Committee.

5. Principles

  • Resolution Life is committed to addressing material environmental and social risks and opportunities across our business.
  • Resolution Life recognises climate change as a significant issue for society, the economy and our
  • Resolution Life is committed to being a “good corporate citizen”, community engagement, and supporting community geared social initiatives (for example, charitable donations, employee volunteer programs).
  • Resolution Life sets its policies to comply, at minimum, with legislation in the local areas in which we operate, including legislation regarding responsible investment, health and safety, labour, human rights and environmental management.
  • Resolution Life is committed to minimising the material environmental and social impacts of our operations.

6. Framework

6.1 Why is ESG important to our business?

We seek to be a good corporate citizen, and a strong approach to ESG is important for our reputation, our ability to attract investors, our customers and our relationship with employees and regulators, and the communities in which we operate.

6.2 Mergers & Acquisitions activity

When evaluating new life insurance acquisitions, ESG considerations may form part of our evaluation process. Resolution Life will include diligence information on the proposed acquisition, and this information, will be included in board packs.

We also ensure that we comply with the Sustainable Finance Disclosure Regulation (“SFDR”) requirements, disclosing how ESG factors are integrated at an entity and product level, for any M&A activity.

6.3 Asset Management

Resolution Life understands it has a responsibility to manage material ESG issues within its investments. If ESG matters are not managed adequately, they can become material investment and / or reputational risks.

Resolution Life has a Group Responsible Investment Policy which establishes the principles and minimum standards for responsible investment within Resolution Life and the framework and controls for managing any associated risks. Consistent with Resolution Life’s fiduciary duties to our policyholders, cedants and investors, this Policy is intended to protect and enhance the value of our investments in the long term. As such, the incorporation of ESG factors in the investment process and in improving the companies in which we invest is a part of our strategic priorities. These factors include (non-exhaustively); climate change, pollution, human rights, modern slavery, employee relations, executive pay, board independence, conflicts of interest, clarity of organisational structure, delegation of authority, advocacy and corporate giving. As a long-term investor, we believe that the goal of any company should be to generate and deliver sustainable long-term financial value, which will be helped by having long-term owners to whom the company is accountable and by having owners that are clear about their expectations.

Specific categories of investments/ risk identified in our Group Responsible Investment Policy include:

  • seeking to exclude investments in tobacco and controversial weapons; and
  • expecting our investment managers to tilt portfolio weights towards companies with a stronger performance in climate protection (however our preference is that our investment managers do not screen out assets solely based on their carbon emission credentials).

Resolution Life seek to review our core asset managers via an annual ESG Questionnaire. We expect our managers to take into consideration ESG factors during the investment process, engage with companies on ESG matters and provide ESG reporting. We look to identify year-on-year progress in these areas through the information collected annually.

6.4 Business Operations and Culture

As a Group we:

  • raise ESG awareness in the context of our business with employees, investors, asset managers, service providers and other stakeholders through internal training and discussions on ESG issues;
  • provide good employment conditions, a safe and healthy workplace, and promote employee satisfaction through work from home and flexible working schemes;
  • strive for diversity within our workforce and in particular at management and Board level;
  • strive for diversity within the asset managers and investment managers we work with;
  • provide equal opportunities and protection against any discrimination;
  • strive to promote a healthy work-life balance to employees;
  • aim to reduce our carbon footprint of business travel;
  • identify opportunities to reduce energy and water usage;
  • offset or reduce carbon emissions where we are able to in a safe and sustainable manner;
  • promote good governance, including via conflict of interest policies and restrictions on gifts and entertainment as well as adhering to policies preventing corruption and bribery;
  • guard against risk of modern slavery and human trafficking issues and have a modern slavery policy;
  • view child and forced labour as unacceptable; and
  • support local charities through donations

7. Governance

7.1 The Management ESG Committee & RLGH Board Risk Committee

The Resolution Life Management ESG Committee (the MESGC) is the “owner” of this policy which is comprised of senior executives from across Resolution Life’s global business. It meets quarterly and more regularly when needed.

The Management ESG Committee makes recommendations to the RLGH Board Risk Committee for endorsement.

7.2 Who monitors ESG metrics?

The MESGC will review Resolution Life’s performance in complying with this policy and in particular will:

  • review quarterly ESG scorecards from the Business Platforms;
  • review the use of ESG information on acquisition opportunities, and how issues identified via due diligence have been addressed;
  • review the outcome of annual reports prepared to comply with UNPRI;
  • make recommendations on improvements which can be made and monitor implementation where agreed; and
  • review the annual Sustainability Report.

8. Reporting

8.1 External Reporting

UNPRI

As a signatory to PRI, we are obliged to file an annual report which will be available to the public on the UNPRI website and our own website from 2024

Sustainability Report

We will release a global Sustainability Report on an annual basis that will report on progress towards our ESG targets.

8.2 Internal Reporting

The Management ESG Committee will report to the RLGH Board Risk Committee at each meeting. On an annual basis, the RLGH Board Risk Committee will receive a copy of UNPRI reporting, Asset Management questionnaires and the Sustainability report.

9. Training

Annual training on ESG matters is provided to all staff.

10. Assurance

This policy will be reviewed and revised as necessary annually by the Management ESG Committee and endorsed by the RLGH Board Risk Committee.

Issued by: General Counsel
Date approved: 26 April 2023
Date for next review: 19 November 2024