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Swiss Re Ltd

PRI reporting framework 2020

Export Public Responses

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage

New selection options have been added to this indicator. Please review your prefilled responses carefully.

01.1. Indicate if you have an investment policy that covers your responsible investment approach.

01.2. Indicate the components/types and coverage of your policy.

Select all that apply

Policy components/types

Coverage by AUM

01.3. Indicate if the investment policy covers any of the following

01.4. Describe your organisation’s investment principles and overall investment strategy, interpretation of fiduciary (or equivalent) duties,and how they consider ESG factors and real economy impact.

The Swiss Re Responsible Investment Policy, as well as the Swiss Re Voting and Engagement Policy, are both part of the Asset Management Responsible Investment Framework. The Asset Management Responsible Investment Framework is aligned with Swiss Re's commitment to sustainability and the Group Code of Conduct that sets out Swiss Re Group's commitment as a sustainable company. Responsible investing is covered in the Asset Management Policy.

The overall responsibility for sustainable investing lies with the Group Chief Investment Officer who signs off investment decisions, and is advised by the Asset Management Investment Committee. Swiss Re’s Head Responsible Investing develops and coordinates the implementation of the ESG strategy within the unit. The ESG Advisory Board reports on responsible investment activities, and develops and reviews improvement ideas.

This structure ensures that the approach to responsible investing is tailored to investment unit specific processes and focus areas, and is therefore relevant as part of these day-to-day activities. The objective is that responsible investing remains an integral part of the activities of all investment professionals. These activities are in turn coordinated with Treasury, Group Risk Management with the support of the Financial, the Market and the Sustainability Risk Management team.

01.5. Provide a brief description of the key elements, any variations or exceptions to your investment policy that covers your responsible investment approach. [Optional]

The Swiss Re Responsible Investment Policy and the Swiss Re Voting and Engagement Policy are an integral part of Swiss Re's overall governance framework. These documents are embedded in the Swiss Re Asset Management governance and guidelines that define our approach to responsible investing, specifies roles and responsibilities in the organisation, implementation, and monitoring of ESG criteria in the Group’s investment portfolio.

Swiss Re's Sustainable Business Risk Framework is a Group-wide management instrument to tackle environmental, social and governance risks in its core business. The framework is based on the overarching principles of respecting human rights and protecting the environment, encapsulated in two umbrella policies that are valid for all our business transactions (re/insurance as well as investments). In addition, these overarching principles are complemented by eight sectors or issues in which we perceive major sustainability risks: defence industry; oil and gas (including oil sands and hydraulic fracturing); coal; mining; dams; animal testing; forestry, pulp & paper and oil palm; and nuclear weapons proliferation.

Each of the two umbrella policies and eight sector guidelines of the framework contains criteria and qualitative standards, which define precisely when a transaction may present a "sustainability risk". We assess such transactions through our Sustainable Business Risk (SBR) process, which consists of two due diligence mechanisms - the SBR online assessment tool and the SBR referral tool.

This is a due diligence assessment carried out by Swiss Re's in-house experts to identify potential environmental, social or ethical risks, and to establish whether the principles expressed in Swiss Re's Group Code of Conduct, standards, policies and guidelines may be breached. The assessment results in a recommendation to undertake the transaction, to undertake the transaction subject to certain conditions or to abstain from undertaking the transaction.

In 2019, our underwriters continued to use the online SBR assessment tool to carry out sustainability checks. Based on the introduction of a new policy on thermal coal in 2018 the number of transactions submitted by our underwriters to the SBR referral tool has remained high: In 2019, they referred 238 transactions to our sustainability experts for further assessments. Of the transactions referred in 2019, we issued negative recommendations in 37 cases and positive recommendations with conditions in 42 cases.

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01.6. Additional information [Optional].


SG 01 CC. Climate risk (Private)

SG 02. Publicly available RI policy or guidance documents


02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.






02.2. Indicate if any of your investment policy components are publicly available. Provide URL and an attachment of the document.




02.3. Additional information [Optional].

Swiss Re's Sustainable Business Risk Framework is an advanced risk management instrument specifically designed to identify, assess and tackle potentially negative effects of our transactions on local communities, workforces and the environment. This framework applies to all our business transactions in re/insurance as well as investments, to the extent that we can influence their various aspects. The Sustainable Business Risk Framework comprises the following elements:

Two umbrella policies on human rights and environmental protection plus eight specific guidelines on sensitive sectors or issues;
The Sustainable Business Risk (SBR) process comprising an online assessment tool and a referral tool – due diligence mechanisms to assess our business transactions;
Company and country exclusions

Sustainable Business Risk Framework:


SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

Conflict of interest may arise where Swiss Re Group invests in a company with which we are also engaged in a business relationship, or where we hold both bonds and shares in the same company. Swiss Re Group aims to reduce these conflicts for example by refraining from voting or by following Swiss Re Group's guidelines for the management of conflict of interest.

Swiss Re Group is committed to ensure transparency regarding its management of unavoidable conflicts of interest which should be addressed appropriately (e.g. abstain from voting).

Conflict of interest situations in the context of the exercise of voting rights will be reported to the relevant Legal & Compliance Officer.

In the situation of a conflict of interest, Swiss Re Legal & Compliance will provide advice. Voting recommendations and a detailed report may be made available to the ESG Advisory Board for their review as well as to the relevant investment committee.

03.3. Additional information. [Optional]

Swiss Re considers that investment management is a core driver in its value creation. The strategic mandate given to Asset Management comprises the prudent management of the assets generated through (re-)insurance activities.

Asset Management integrates ESG criteria along the investment process as a key element of long-term sustainable economic returns.

Asset Management has developed a stable, consistent and transparent investment process to manage the Group's assets in a prudent way with a core focus on asset-liability management. In this context, no material conflict of interest issue has been identified between responsible investment activities and the investment process.

The ESG Advisory Board consists of representatives from all investment units, legal, compliance and risk management to manage conflicting issues when they arise or escalate to senior management when required.

SG 04. Identifying incidents occurring within portfolios

04.1. Indicate if your organisation has a process for identifying and managing incidents that occur within investee entities.

04.2. Describe your process on managing incidents

Swiss Re Asset Management applies exclusion lists based on likely and/or already occurred incidents related to the respective countries or companies. The lists are updated on a quarterly basis and Asset Management screens its portfolio on a daily basis.

Exclusions on the list are either part of the group-wide company exclusion list (as described in SG 02) or are not fully compliant with international norms defined by global conventions (e.g. the UN Global Compact).

In case an incident occurs on an investment Swiss Re Asset Management holds, the case will be raised through the established process. Specific options to address the issue and relevant remedies are evaluated on a case-by-case basis.