Swedbank Insurance works to influence and support the companies we invest in to become more sustainable. This is done through a selected asset manager, Swedbank Robur, to whom we set specific requirements regarding their sustainability work. In this way, we live up to the purpose of the pension assets: to invest them in the way that is in the best long-term interest of the policyholder. Swedbank Robur’s vision is to become a world leader in sustainable value creation. Swedbank Försäkring’s traditional pension insurance capital is managed to be in line with the Paris Agreement 2025 and carbon neutral 2040. This is achieved by investing the capital in Swedbank Robur, which manages with that climate goal. Swedbank Insurance works with three overall methods to manage the main negative impacts on sustainability factors: selecting, deselecting and influencing. The traditional pension portfolio is highly sustainable. 100% of the fund capital is invested in funds that are classified as light green or dark green under the EU’s Sustainable Finance Disclosure Regulation (SFDR). Swedbank Försäkring has chosen not to classify our traditional pension insurance according to SFDR as the insurance is not open for new subscription. Traditional pension insurance includes Swedbank Robur’s funds:

• Swedbank Robur Access Edge Emerging Markets
• Swedbank Robur Climate Bond
• Swedbank Robur Climate Impact
• Swedbank Robur Interest Fund Short
• Swedbank Robur Bond
• Swedbank Robur Transition Global
• Swedbank Robur Sweden
• Swedbank Robur Bond Long Inst

In our fund insurance policies, which are classified in accordance with the EU regulations, it is our ambition that all eligible funds should be classified as sustainable, i.e. either “promote environmental or social characteristics” or have “sustainable investments as a goal”. However, as the EU’s sustainability regulations are new and under development, we see a need to be more flexible initially. One reason is that not all asset classes are covered by the regulations. It can therefore be difficult to reclassify certain funds. The fund management companies are also actively working on classifying their products, which means that a fund that is currently unclassified may be classified in the foreseeable future. Against this background, we accept for the time being that our classified insurance policies also include funds that are not classified. A prerequisite, however, is that this can be justified based on our sustainability guidelines. We regularly review and check that all funds offered under our insurance policies comply with our requirements.

All of the entrance solutions we offer consist of funds that “promote environmental or social characteristics” or have “sustainable investment as a goal”.

When the fund was launched in September 2023, Swedbank Försäkring acted as an anchor investor.

Climate Bond is an actively managed bond fund that invests mainly in sustainable bonds with a focus on climate, such as sustainable energy, environmental conservation and climate change mitigation. The focus is on bonds issued with the aim of achieving a sustainable society in line with the UN’s Sustainable Development Goals with a focus on climate. The fund continuously analyses how the investments affect emissions, water and biodiversity, among other things. The fund also ensures that the holdings do not seriously and systematically violate international norms or conventions. The fund has sustainable investment as its objective and is classified as dark green under the SFDR.

When the fund was launched in September 2021, Swedbank Försäkring acted as an anchor investor.

Climate Impact is an actively managed equity fund with a quantitative management approach that invests globally in companies that, through their products, services and activities, according to the fund management company’s assessment, contribute to meeting the UN’s global development goals regarding sustainable energy (7) and combating climate change (13). The goals aim to ensure that everyone has access to reliable, sustainable and modern energy at an affordable cost and to take action to combat climate change and its consequences. The fund is classified as dark green under SFDR.

When the fund was launched in November 2019, Swedbank Försäkring acted as an anchor investor.

The fund is an index-linked fund with a clear sustainability focus, where up to 10 per cent of the fund will be invested in so-called impact companies that, for example, directly contribute to the transition to a renewable energy system. The fund selects companies based on quantitative sustainability measures, which consist of a weighted sustainability score and a defined climate strategy. This takes into account each company’s work in the areas of environment, social aspects and corporate governance, the companies’ greenhouse gas emissions and the companies’ contribution to the UN’s Sustainable Development Goals. In addition, the fund focuses on reducing the carbon footprint over time, on investments in climate promotion and on systematic rewarding of companies that actively work to reduce climate risks and have an evidence-based objective to reduce their greenhouse gas emissions. The fund is classified as light green under SFDR.

When the fund was launched in October 2020, Swedbank Försäkring acted as an anchor investor.

The fund is a special fund that invests mainly in covered bonds and bonds issued by governments, municipalities and supranational organisations. Sustainability and climate work is an integral part of the investment strategy, to manage sustainability and climate risks and to promote environmental and social characteristics. The sustainable investments in the fund aim to contribute to the achievement of the UN’s Sustainable Development Goals. The Fund aims to invest at least 50% of the Fund’s assets in investments aligned with environmental or social characteristics, of which at least 5% are considered sustainable investments. The fund is classified as light green under SFDR.

All fund insurance policies offered by Swedbank Försäkring promote environmental or social characteristics, i.e. they are classified as light green insurance products. Fund insurance is insurance where paid-in capital is invested in securities funds. As our fund insurance policies consist of underlying funds, we work to set sustainability requirements for fund management companies and fund managers and to offer our customers a wide range of sustainable funds so that customers can make active sustainable choices themselves.

Swedbank Försäkring’s fund insurance policies promote environmental or social characteristics, but do not aim for sustainable investments. However, within the framework of our fund insurance policies, our customers can choose funds that make sustainable investments.

Our fund insurance policies always include at least 80 per cent selectable funds that are light green or dark green. All of the entrance solutions we offer consist of funds that “promote environmental or social characteristics” (light green funds) or have “sustainable investment as a target” (dark green funds).

As an insurance company, we set sustainability requirements for fund managers through our due diligence process. Once a fund has been approved in the due diligence process, we will regularly check the fund and the fund management company to ensure that the established requirements are met.

Swedbank Försäkring believes that fund management companies should have a climate strategy with clear goals to help reduce climate-related risks and/or enable the transition to low-fossil solutions. Fund managers should also refrain from investing in companies that systematically violate international norms and sustainability conventions.

We also believe that the Fund manager should exclude investments linked to certain products as follows: Companies that produce, modernise, maintain or distribute products specifically designed for cluster bombs, anti-personnel mines, chemical or biological weapons or nuclear weapons.

Further exclusions should be made by the Fund manager in respect of investments related to companies whose main revenues come from controversial sectors such as weapons, fossil fuels, tobacco, alcohol, cannabis, pornography and commercial gambling.

Swedbank Försäkring works to ensure that funds/fund management companies within fund insurance undertake the following:

PRI: Fund management companies should have signed PRI (Principles for Responsible Investment). In line with PRI, the fund manager will work to integrate sustainability (ESG) issues into investment and decision-making processes.

Swedbank Försäkring regularly reviews and checks that fund managers and fund management companies comply with our requirements. If a fund/fund management company does not comply with Swedbank Försäkring’s sustainability requirements, the fund/fund management company may still be approved. However, Swedbank Försäkring will monitor how the fund/fund management company handles the requirement and if no changes occur and there is no intention to implement a change, the fund will be removed/replaced within two years.

We have an ongoing and transparent dialogue with our stakeholders to ensure that they understand Swedbank Försäkring’s efforts, challenges and ambitions. The dialogues are also important for us to understand our stakeholders’ expectations of us.

Swedbank Insurance reports regularly to internal and external stakeholders on sustainability-related issues.

For information about what a specific fund uses as a method for measuring how environmental or social characteristics or sustainability as a target are achieved, which data sources are used and limitations regarding the methods or data sources used, see information under the respective fund’s link at swedbank.se/fondlista. If an index value has been selected as a reference value for a fund, you can also find this information under the respective fund’s link at swedbank.se/fondlista.

This information was published on 21 December 2022 and relates to all our newly taken out fund insurance policies.

Our fund insurance policies promote environmental or social characteristics, but do not have sustainable investment as an objective.

In our fund insurance policies, we do not commit to a minimum proportion of investments in sustainable investments. However, within the framework of our fund insurance policies, our customers can choose funds that make sustainable investments. For more information on how a specific fund does not cause significant harm to any of the sustainable investment objectives, see the information under the respective fund’s link at swedbank.se/fondlista.

All of our fund insurance policies promote environmental or social characteristics by at least 80 per cent of eligible funds promoting one of these characteristics or having sustainability as a goal.

It is through active fund selection that our customers can influence how their pension capital is invested for a sustainable future. The range and classification of funds may change over time, but current information can be found in the fund list at swedbank.se/fondlista. There is also a description of the environmental or social characteristics promoted by the funds or their sustainability objectives in the respective fund’s information brochure.

As an insurance company, we can have a positive impact by setting sustainability requirements for fund management companies and fund managers and by creating the conditions for our customers to make sustainable choices.

We believe that fund management companies should have a climate strategy with clear targets to help reduce climate-related risks and/or enable the transition to low-fossil solutions. Fund managers should also refrain from investing in companies that systematically violate international norms and sustainability conventions. We also believe that the Fund manager should exclude investments linked to certain products as follows:

Companies that produce, modernise, maintain or distribute products specifically designed for cluster bombs, anti-personnel mines, chemical or biological weapons or nuclear weapons.

Further exclusions should be made by the Fund manager in respect of investments related to companies whose main revenues come from controversial sectors such as weapons, fossil fuels, tobacco, alcohol, cannabis, pornography and commercial gambling. The accepted level of turnover from such products shall be less than five per cent.

Once a fund has been approved in the due diligence process, the fund and the fund management company must be checked regularly to ensure that the established requirements are met.

If a fund/fund management company does not meet Swedbank Försäkring’s sustainability requirements, the fund/fund management company may still be approved and dialogue is initiated to ensure that the company meets the sustainability requirements. If there are no changes and there is no intention to implement a change, the fund should be removed/replaced within two years.

Swedbank Insurance works to ensure that funds/fund management companies within fund insurance have good governance. Therefore, funds/fund management companies should commit to the following:

PRI: Fund management companies should have signed PRI (Principles for Responsible Investment). In line with PRI, the fund manager will work to integrate sustainability (ESG) issues into investment and decision-making processes.

Active ownership: Fund managers should act as active owners. Within the equity asset class, this can primarily be done by exercising active ownership both before and during annual general meetings via ongoing dialogues with the company’s Board of Directors and management and cooperation with other shareholders. In the ownership process, engagement and dialogue must take place with companies where a lack of sustainability and/or corporate governance has been identified.

Within the fixed income asset class, we believe that ESG investing is not only about fund managers engaging with issuers who already demonstrate an integrated approach to ESG, but also engaging with those who want to improve their own initiatives and are willing to work with lenders to achieve their objectives. We believe that ESG analysis in fixed income portfolios has the potential to deliver attractive long-term returns while having a positive impact.

For a description of the investment strategy and the policy to assess good governance practices for each fund, see information under the respective fund’s link at swedbank.se/fondlista.

For information about a specific fund, see the information under the respective fund’s link at swedbank.se/fondlista.

In our fund insurance policies, customers invest in underlying funds. We work continuously to set sustainability requirements for fund management companies and fund managers and to offer our customers a wide range of sustainable funds so that customers can make active sustainable choices themselves. We have an ongoing and transparent dialogue with our stakeholders to ensure they understand our ambitions. We regularly review and check that fund managers and fund management companies comply with our requirements.

For a description of environmental and social characteristics promoted by each fund, or the respective fund’s sustainability goals, and how this is followed up, see information under the respective fund’s link at swedbank.se/fondlista.

For information about what a specific fund uses as a method for measuring how environmental or social characteristics are achieved, or how the sustainability goals are achieved, see information under the respective fund’s link at swedbank.se/fondlista. It also contains the funds’ annual reports, which are available no later than four months from the end of the financial year.

For information about what a specific fund uses for data sources to assess environmental or social characteristics that the fund promotes, or their sustainability goals, the measures taken to ensure data quality, how data is processed and the proportion of data that is estimated, see information under the respective fund’s link at swedbank.se/fondlista.

For information about what restrictions a specific fund has with regard to the methods used or restrictions on the data sources used, and how such restrictions affect or do not affect the fulfilment of the environmental or social characteristics that the funds promote or their sustainability goals, see information under the respective fund’s link at swedbank.se/fondlista.

As an insurance company, we set sustainability requirements for fund managers through our due diligence process. Once a fund has been approved in the due diligence process, we will regularly check the fund and the fund management company to ensure that the established requirements are met.

Analysis of the underlying funds’ sustainability work in our products is carried out by Swedbank Insurance’s fund analysts and sustainability team together with Swedbank’s fund analysis team. A number of data points are collected annually in order to be able to analyse the fund management companies and their funds’ sustainability work in order to assess whether the funds meet the sustainability requirements that we set for funds in our fund range.

The analysis scores sustainability parameters in several analysis areas. The level of sustainability in the funds and companies thus affects the score for the different areas analysed (e.g. team, process, philosophy, fund management company, etc.) and becomes part of the overall rating of the analysed fund.

We regularly review and check that fund managers and fund management companies comply with our requirements. If a fund/fund management company does not comply with Swedbank Försäkring’s sustainability requirements, the fund/fund management company may still be approved. However, Swedbank Försäkring will monitor how the fund/fund management company handles the requirement and if no changes occur and there is no intention to implement a change, the fund will be removed/replaced within two years.

Swedbank Insurance reports regularly to internal and external stakeholders on sustainability-related issues.

For a description of the due diligence carried out on the funds’ underlying assets, see information under the respective fund’s link at swedbank.se/fondlista.

As our fund insurance policies consist of underlying funds, this means that our advocacy work is aimed at the fund management companies and fund managers, which in turn set sustainability requirements for individual companies.

We have an ongoing and transparent dialogue with our stakeholders to ensure that they understand Swedbank Försäkring’s efforts, challenges and ambitions. The dialogues are also important for us to understand our stakeholders’ expectations of us. We advocate active ownership and require fund managers to act as active owners. Within the equity asset class, this can primarily be done by exercising active ownership both before and during annual general meetings via ongoing dialogues with the company’s Board of Directors and management and cooperation with other shareholders. In the ownership process, engagement and dialogue must take place with companies where a lack of sustainability and/or corporate governance has been identified.

Within the fixed income asset class, we believe that ESG investing is not only about fund managers engaging with issuers who already demonstrate an integrated approach to ESG, but also engaging with those who want to improve their own initiatives and are willing to work with lenders to achieve their objectives. We believe that ESG analysis in fixed income portfolios has the potential to deliver attractive long-term returns while having a positive impact.

For a description of “Strategies for engagement” regarding the funds’ underlying assets, see information under the respective fund’s link at swedbank.se/fondlista.

If an index value has been selected as a reference value for a fund, you can find the information under the respective fund’s link at swedbank.se/fondlista.

Spare Parts Kit

Swedbank Försäkring’s employees have fixed remuneration, which includes pension benefits and other benefits that together constitute their total remuneration. In addition, there is the possibility of a smaller amount of variable remuneration.

Fixed remuneration

Fixed remuneration constitutes the main remuneration in Swedbank Försäkring. It is based on the nature and responsibility of the employee’s role, individual performance and market conditions. Pension benefits are offered in accordance with collective agreements.

Variable compensation

Variable remuneration is based on relevant, predetermined and measurable criteria established with the aim of increasing Swedbank Försäkring’s long-term value. Remuneration is primarily based on a common risk-adjusted profit measure in the Swedbank Group. Both current and future risks are taken into account, as are actual costs of capital and liquidity. A multi-year perspective is applied to ensure long-term sustainable profit taking into account underlying business cycles and risks at the time of disbursement.

As Swedbank strives for a values-based corporate culture, the individual performance criteria include a performance part with desired results as well as a behavioural part to ensure that individual behaviours are in line with Swedbank’s values (Open, Simple and Caring).

Risk management and sustainability

Healthy risk-taking is part of our business strategy. Remuneration should counteract excessive risk-taking and encourage employees to deliver sustainable results in line with strategic objectives and to manage risks in a healthy and effective manner.

We integrate ethical, social, environmental and economic considerations into all our business decisions, operations and business development. Within Swedbank Insurance’s Performance Development process, individual performance criteria are set with the aim of contributing to and supporting Swedbank Insurance’s overall strategic direction, where sustainability is an important part.

Furthermore, sustainability risks are integrated into our remuneration practices by including qualitative individual performance criteria as the basis for allocating variable remuneration to all employees, such as compliance with our values and the application of deferral periods and variable remuneration disbursement in the form of financial instruments. Non-compliance with external or internal rules and regulations or deficiencies in risk management are such circumstances that are considered inconsistent with Swedbank Försäkring’s values.

Governance

Our remuneration policy sets out the basis and principles for remuneration within Swedbank Försäkring. Swedbank Försäkring’s Board of Directors’ decision to adopt the remuneration policy is preceded by and based on an analysis of the risks associated with our remuneration system and policy. Remuneration to the CEO and other senior executives is paid in accordance with the Board’s decision.