SFDR

The purpose of the Sustainable Finance Disclosure Regulation (Regulation EU 2019/2088, “EU SFDR”) is to strengthen protection for, and improve disclosures to, end investors in respect of the integration of sustainability risks in investment decision-making and advisory processes.

EU SFDR defines a Sustainability Risk as an environmental, social or governance event or condition that, if it occurs, could cause a negative material impact on the value of the investment.

Article 3

Monument Re has a group Sustainability Risk Policy, that has been approved by the Monument Re Limited Board and is reviewed at least annually.

The Sustainability Risk Policy sets out principles and requirements for the identification, measurement, management, monitoring and reporting of sustainability risks, including Environmental, Social and Governance (“ESG”) considerations. The Company’s Investment Policy operationalises the principles of the Sustainability Risk Policy with respect to the ESG parameters to which the Company must adhere in terms of its investments.

Responsibility for investment decisions depends on the nature of the insurance product. With respect to traditional savings and non-profit insurance business, asset management is typically outsourced to external asset managers. Those asset managers must adhere to the Company’s investment policy including ESG limits. With respect to certain unit-linked policies, and portfolio bonds in particular, investment decisions may be taken by the policyholder, and this may be on the basis of advice provided to the policyholder by an investment adviser. Where the Company does not control, or has relatively limited control over, the investment decisions, then sustainability risks are best taken into account by the policyholder, on advice from their investment adviser as appropriate.

Article 4

The Company does not currently consider principal adverse impacts of investment decisions on sustainability factors. The Company does not yet have access to sufficient data to enable such an impact analysis to be conducted. Monument Re group intends to invest further to enhance its access to comprehensive ESG data.

Article 5

The Company follows a remuneration policy that incorporates and promotes sound and effective risk management linked to risk-adjusted performance. There is currently no specific link to sustainability risk in the Company’s remuneration policy.