Annual Report 2022
Human rights

As an organisation, a.s.r. has an impact on society and hence can also have an impact on human rights. a.s.r. aims, among other things, to make a positive contribution to making society more sustainable by respecting and protecting human rights and preventing or reducing the (potential) risks of human rights violations.

In 2022, a.s.r. further developed and implemented a human rights policy . This policy specifies:

  • Which international conventions and guidelines a.s.r. subscribes to and respects;

  • How a.s.r. accounts for its responsibility to respect human rights;

  • How a.s.r. deals with human rights in its various roles of investor, insurance and financial products and services provider, procurer and employer;

  • a.s.r.’s expectations relating to its employees, business and other relevant parties;

  • How (potential) human rights violations can be reported.


For a.s.r., the greatest potential negative impacts on human rights reside in its investment portfolio, which is why human rights are one of the key priorities in its responsible investment policy. All of a.s.r.’s existing and new investments are monitored for ESG criteria based on its Socially Responsible Investment (SRI) policy, which includes criteria for human and labour rights. Countries and companies that fail to comply with this are excluded. Companies committing systematic and/or gross violations of human rights, or those that do not respect fundamental coventions from the International Labour Organisation (ILO), are excluded or else an engagement dialogue is initiated to give them the chance to improve and comply. In 2022, dialogues were held on living wage in the food sector, human rights surrounding the EACOP project in Uganda and the Uyghur situation in China.

Business customers

In the acceptance process for new business customers, a.s.r. assesses (potential) risks in the sphere of human rights violations. In the Customer Due Diligence policy, human rights violations are a ground for exclusion. An additional assessment of ESG risks, including human rights risks, takes place, if required, as part of the Sustainable Insurance Policy. In 2022, no customers were refused on the basis of human rights or labour rights violations.

Retail customers

In the first months of 2022, a.s.r. performed an impact analysis to gauge the extent to which its products and services could have a negative impact on human rights. a.s.r. offers financial products and services in the Dutch market, and not abroad, with the aim of sharing risks and building wealth for later. Compared, for example, to a company in the manufacturing industry, the chain of a.s.r.'s products and services is short, less complex and local, which leads to a limited amount of risks. Human rights risks has become even more prominent in view of the economic situation in 2022. To mitigate this, a.s.r. has become a signatory to the Ethical manifesto (Ethisch manifest) and implemented the Protocol for payment arrears (Protocol bij betalingsachterstanden) of the Verbond van Verzekeraars. It has also joined the Dutch creditors coalition (Schuldeiserscoalitie) and the Dutch debt relief route (Nederlandse Schuldhulproute). See section 3.1.2 for more information.

One risk highlighted by the impact analysis was that a.s.r. could inadvertently fail to uphold the right to equal treatment. a.s.r. therefore drew more attention to this issue internally in 2022 and re-emphasised that it does not make unlawful distinctions on the basis of gender, age, beliefs, background or sexual orientation in its services to customers. By applying the Ethical Framework for data-driven applications for insurers, a.s.r. has reduced the risk of unjustified bias, exclusion and discrimination in core processes such as its underwriting policy, premium-setting, fraud policy and claims handling. The prevention of exclusion and discrimination is also the starting point in non-data-driven decision-making and processes and in communication with (potential) customers.


a.s.r. has tightened its procurement process, including in the area of human rights. Compliance with human rights and labour rights standards is reviewed during selection and monitoring. This information is used as input for annual, strategic discussions with suppliers. a.s.r. requires suppliers to be diligent in their own business activities and supply chain. In 2022, a.s.r. developed a Supplier Code of Conduct which includes expectations governing compliance with human rights standards. 


As an employer, a.s.r. also respects the right to equal treatment and non-discrimination. At a.s.r., everyone is welcome and treated equally, through awareness of diversity in relation to gender, age, religious conviction, physical and mental capacity, background and sexual orientation. Through its Diversity, Equity and Inclusion policy, a.s.r. strives for a workforce that is a representative reflection of society. The a.s.r. code of conduct pays explicit attention to a safe and pleasant working environment, non-discrimination and inclusion. In 2022, a.s.r. launched several initiatives to promote diversity, equity and inclusion within the organisation. The Diversity and Inclusion module of the Denison Scan measures progress on this theme annually. In 2022, a.s.r. was among the top 25% of companies taking part in this module. More information can be found in sections 3.3.2 and 4.8.3 of this Annual Report.

a.s.r. uses various channels to gain insight into workplace safety, such as the annual Vitality Scan, panel discussions following the Risk Inventory and Evaluation (RI&E), eMood and the Denison Scan. Employees who experience undesirable behaviour such as bullying or discrimination can contact their manager, the HR advisor or the Vitality specialist, external confidential advisors and/or the Grievances Committee. An external confidential advisor was contacted 21 times in 2022 (2021: 14). There were no (0) complaints submitted to the Grievances Committee (2021: 0).

War victims in Ukraine

In February 2022, Russia began its invasion of Ukraine. a.s.r. sympathises with the population and with the victims of the war. a.s.r. colleagues were given the opportunity to donate to the victims by converting their earned Gamification points into a monetary amount.

During the national initiative "Together in action for Ukraine", the EB - on behalf of all colleagues - topped up the amount and donated 250,000 to help the Ukrainian people.

In the meantime, a.s.r. reviewed its activities in Russia. As Russia was excluded as a country since 2007, a.s.r. has no insurance activities and direct investments in Russia.

Earthquakes Türkiye and Syria

In February 2023, a series of catastrophical earthquakes took place in Türkiye and Syria. a.s.r. deeply feels for the victims and with family members who live and work here and have lost or are worried about their loved ones. a.s.r. colleagues were also directly or indirectly impacted by the earthquakes. It was clear that, as a company, a.s.r. wanted to offer help where it could.

a.s.r. employees were given the option to convert points earned during Gamification in a monetary donation. In anticipation of the final outcome of the campaign, the EB donated on behalf of a.s.r. 100,000 to the victims two days after the disaster.

The total amount donated by a.s.r. employees via the Gamification campaign was 58,650. On behalf of a.s.r., the EB doubled the amount, resulting into an additional donation of 17,300 in March 2023.