1. Overview

Policy/Standard Owner:RLGH General Counsel
Approved by:RLGH Board of Directors and Insurance Entity Boards of Directors
Effective:November 20, 2024

What you need to know:

The purpose of this policy is to set out the Sustainability Principles (“the Principles”) across Resolution Life Group Holdings Ltd (“RLGH”), including all insurance entities, subsidiaries, and service companies - collectively across RLGH, “Resolution Life” or the “Company”), describe how we will implement our Principles and outline the global sustainability standards to which we aim to adhere.

OverviewThis document sets forth key definitions, principles and Minimum Standards for RLGH’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.
ObjectiveThe purpose of this Policy is to establish group-wide principles and outline the global sustainability Minimum Standards to which we aim to adhere across the Company.
Context/Relevant Authority:This Policy covers a wide range of sustainability principles and goals that we aim to adhere to. It does not specifically cover climate risk as that is managed through our risk management framework by the risk and investment risk functions.

In developing our Sustainability Policy, we have considered a range of international standards to guide our approach. We have a commitment to continuously monitor the evolving regulatory landscape from both a global and local perspective to ensure our business operations are in line with current standards. This policy provides guidance on the United Nations-supported Principles for Responsible Investment (“PRI”) and the Task Force on Climate-Related Financial Disclosures (“TCFD”). Where local statutory rules or laws prohibit the application of this Policy, local regulation will prevail. Such occurrences must be reported to both the General Counsel in writing.
Scope:This Policy applies to RLGH and all Insurance Entities, subsidiaries and service companies.  The Policy will be adopted locally by the respective Board of Directors.  For new entities, an appropriate transition schedule will be agreed upon on a case-by-case basis.
Review Cycle:Annual

2. Introduction

RLGH, together with Resolution Life Group Holdings LP and their respective subsidiaries, service companies and Insurance Entities (“Resolution Life”), collectively referred to as “the Company,” has a responsibility to manage material environmental and social issues in its investments, operations and supply chains. If sustainability matters are not managed adequately, they can escalate into material reputational and financial risks.

This Policy sets out Resolution Life’s group-wide obligations and commitments to environmental and social responsibility and good corporate governance, to our policyholders, companies we work with, our people, our regulators, our investors, and the communities in which we operate.

3. 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”).

Legal Entities in Scope

RLGH LtdResolution Life Group Holdings Ltd (Bermuda) (“Holding Company”)
Other RLGH Holding CompaniesAny other entity which currently or in the future forms part of the Resolution Life Group Holding Companies (collectively “HoldCos”)
Resolution Re Ltd.Resolution Re Ltd. (Bermuda) + Resolution Re Finance (Bermuda) Ltd. (“RRFB”) + Subs
Resolution Life USRLUSIH + Subs [Security Life of Denver and its direct / indirect subsidiaries and holding companies]
Resolution Life AustralasiaNOHC + Subs [Resolution Life Australasia and its direct / indirect subsidiaries and holding companies]
All other subsidiaries of RLGH LtdAll subsidiaries and service companies to follow the general principles and Minimum Standards as set out in this Policy

4. 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 business
  • 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 will take actions consistent with its status as a signatory to the PRI.
  • Resolution Life will consider recommendations of TCFD
  • Resolution Life is committed to minimising the material environmental and social impacts of our operations.

5. Framework

5.1 Why is sustainability 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.

5.2 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.

5.3 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 seeks 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.

5.4 Business Operations and Culture

Company-wide, Resolution Life will:

  • raise sustainability awareness in the context of our business with employees, investors, asset managers, service providers and other stakeholders through internal training, communications 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 as a business, with particular focus on vendor management
  • 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;
  • 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 as a business, with a particular focus on vendor management
  • 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 and partnerships.

6. Reporting

6.1 External Reporting

In developing our Sustainability 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.

6.1.1 PRI

As a signatory to PRI, we are obliged to file an annual report which will be available to the public on the PRI website from start of 2025 (details outlined in Appendix A).

6.1.2 Sustainability Report

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

6.2 Internal Reporting

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

7. Policy Minimum Standards

The Minimum Standards noted below are in place to appropriately manage Insurance Risk within the Company.

#Why /Purpose
(rationale / outcome(s))		What are the Minimum Standards
(Action(s), step(s))		When
(Frequency / time of year)		Responsibility
(Who & Where)
1Resolution Life understands where its sustainability practices can be improved, both in terms of design and implementation
  • The controls provide reasonable assurance that Resolution Life understands where it can improve its sustainability practices.
  • These controls must include the population of quarterly sustainability scorecards by all business Insurance Entities and its subsequent reporting to an appropriate governance forum. Furthermore, an update must be provided to the Board Risk Committee on sustainability activities over the previous quarter.
  • Quarterly
  • Insurance Entity Sustainability SMEs present to Management Sustainability Committee ("MSC")
  • Update to be provided to the Board Risk Committee
Resolution Life complies with PRI disclosure requirements
  • The controls provide reasonable assurance that Resolution Life complies with PRI disclosure requirements.
    These controls must include the review by senior management of Resolution Life disclosure and the submission of the annual PRI disclosure.
  • Annual
  • Investments Team & Sustainability Lead populate disclosure and
    Chief Investments Officer to review and sign off
3Resolution Life demonstrates to external stakeholders that it understands its sustainability exposures.
  • The controls provide reasonable assurance that Resolution Life can demonstrate to external stakeholders that it understands its sustainability exposures. These controls must include the review by senior management of Resolution Life's draft Sustainability Report and its subsequent publication.
  • Annual
  • Sustainability Lead to report
  • General Counsel to review and sign off report

8. Roles and Responsibilities

RLGH Board of Directors (the “RLGH Board”)
  • The RLGH Ltd Board of Directors retains overall responsibility for governance of the Company’s Sustainability Policy.
  • Annually reviews and will approve any material changes to this Policy.
RLGH Management Sustainability Committee (“MSC”)
  • The MSC is responsible for the maintenance and consistent implementation of this Policy across Resolution Life. This Policy should be formally reviewed by the MSC on at least an annual basis and following any significant incident or changes in business structure or operational approach.
  • In particular, the MSC will:
    • review quarterly global sustainability scorecards;
    • review the use of sustainability information on acquisition opportunities, and how issues identified via due diligence have been addressed;
    • review the outcome of annual reports prepared to comply with PRI;
    • make recommendations on improvements which can be made and monitor implementation where agreed; and
    • review the annual Sustainability Report.
RLGH Board Risk Committee (“BRC”)
  • The BRC will review and sign-off updates to the Policy
Insurance Entities’ Chief Executive Officer
  • Business Insurance Entities are required to monitor and comply with the Company minimum standards, attesting to their compliance annually as part of the general attestation process for Company policies. Any identified gaps should be addressed with a remediation plan to ensure gaps are closed within an agreed timeframe (maximum of one year for new acquisitions).
RLGH General Counsel
  • RLGH General Counsel will own this Policy

9.Policy Compliance

Compliance with this Policy is mandatory. Where local statutory rules or laws prohibit the application of this Policy, local regulation will prevail and be appropriately disclosed. To the extent professional standards require deviation from this Policy, the professional standards should prevail and the deviation appropriately disclosed.

Reporting: Significant instances or events of non-compliance with this Policy will be reported to the MSC. Where gaps exist, an exception must be sought and granted, or a remediation plan to close the gaps within an agreed timeframe must be documented.

Exception Process: The General Counsel must approve any exceptions to this Policy. Requests for any exceptions must be appropriately documented and presented to the MSC. Requests for material exceptions must additionally be presented to the BRC for approval.


Remediation: The General Counsel must approve any remediation plans and timelines should these be mandated. The MSC must be informed of any remediation plans and timelines where they were mandated as part of the exception process.

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: 20 November 2024
Date for next review: 19 November 2025