1. Introduction
Resolution Life Group Holdings Ltd, together with Resolution Life Group Holdings LP and their 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: 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, including the United Nations Principles for Responsible Investment (“UNPRI”) and the United Nations Global Compact. Resolution Life is evaluating the implications of adopting both standards and anticipates it will become a signatory to both as of H1 2021.
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.
3.3 UN Global Compact
The UN Global Compact is a non-binding United Nations pact to encourage businesses worldwide to adopt sustainable and socially responsible policies, and to report on their implementation. The Global Compact provides a universal language for corporate responsibility and provides a framework to guide all businesses regardless of size, complexity or location. Please see Appendix A.
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 report to the Resolution Life ESG Committee on ESG matters on an annual basis. This report will list KPIs and evidence how ESG Principles were implemented on a practical level.
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 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 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 Framework
Resolution Life implements ESG in two key areas:
- in its acquisition of life insurance assets; and
- in its business operations and culture.
6.3 Mergers & Acquisitions activity
When evaluating new life insurance acquisitions, ESG considerations form part of our evaluation process. Resolution Life will include diligence information on the proposed acquisition, and this information, including MSCI ESG data (or an equivalent), will be included in board packs.
6.4 Exclusionary Screening
Pursuant to Resolution Life’s governing documents, we are restricted to investing in the life insurance industry.
6.5 Asset Management
We aim for the Business Platforms to invest our customer’s premiums consistently with this policy. We prefer asset managers who have processes and policies in place to meet our ESG requirements. Asset managers are required to provide quarterly reports on ESG metrics to the Business Platforms.
6.6 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 carbon footprint for all its business travel;
- to identify opportunities to reduce energy and water usage;
- 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.
7. Governance
7.1 The ESG Committee
The Resolution Life ESG Committee (the ESG Committee) is the “owner” of this policy and comprises of senior executives from across Resolution Life’s business. It meets quarterly and more regularly when needed.
7.2 Who monitors ESG metrics?
The ESG Committee will review Resolution Life’s performance in complying with this policy and in particular will:
- review quarterly reports from the Business Platforms on their investment portfolios and ESG
- review the use of ESG information on acquisition opportunities, and how issues identified via due diligence have been addressed
- if applicable and appropriate, review the outcome of annual reports prepared to comply with UNPRI and the UN Global Compact
- make recommendations on improvements which can be made and monitor implementation where agreed.
8. Reporting
8.1 Public Reporting
UNPRI
As a signatory to the UNPRI, we will be obligated to file an annual report which will be available to the public on the UNPRI website and our own website.
UN Global Compact
As a signatory/member we will be required to publish an annual ‘Communication on Progress’ publicly on our website and on the UN Global Compact website.
8.2 Internal Reporting
The ESG Committee will report to the Board on an annual basis, using information gathered from the Platforms and Asset Managers. UNPRI and UN Global Compact annual reports will also be shared with Resolution Life’s stakeholders and investors upon request and will be available on the Resolution Life website.
9. Training
Annual training on ESG matters will be provided to all staff
10. Assurance
This policy will be reviewed and revised as necessary annually by the ESG Committee.
Issued by: General Counsel
Date approved: 10th March 2021
Date for next review: March 2022