To: the General Meeting of Shareholders and the Supervisory Board of ASR Nederland N.V.
Our opinion on specified non-financial indicators
We have performed a reasonable assurance engagement on the data for the key performance indicators: Relational Net Promoter Score (NPS-r), Sustainable reputation, Impact investments, Carbon footprint of portfolio for own account in % reduction compared to baseline year 2015 , Employee Engagement and 23, by management selected, HR related indicators which are specifically indicated as part of reasonable assurance with an asterisk (*) in chapter '6 Non-financial statements' (hereafter: ‘the specified non-financial indicators’) as included in the 2023 Annual Report (hereafter: ‘the annual report’) of ASR Nederland N.V. (hereafter ‘the Group’ or ‘ASR Nederland N.V.’) based in Utrecht, the Netherlands.
In our opinion, the specified non-financial indicators in the accompanying annual report are presented fairly, in all material respects in accordance with the applicable criteria as included in the section ‘Criteria’.
Our qualified conclusion on non-financial information
Furthermore, we have performed a limited assurance engagement on the non-financial information in the chapters:
‘2 Business and strategy’;
‘3 How a.s.r. operates’;
‘4 Business performance’;
‘6 Non-financial statements’ (excluding chapter ‘6.2.4 Taxonomy regulation’)
‘8.1 About this report’;
‘8.3 Materiality analysis and stakeholder dialogue’;
‘9.3 GRI content index’;
‘9.4 TCFD recommendations’; and
‘9.5 TNFD recommendations’.
(hereafter: ‘the non-financial information’) as included in the annual report of ASR Nederland N.V. based in Utrecht, the Netherlands.
Based on the procedures performed and the assurance information obtained, nothing has come to our attention, except for the possible effects of the matter described under ‘Basis for our opinion and qualified conclusion’ section of our report, that causes us to believe that the non-financial information in the accompanying annual report does not present fairly, in all material respects:
the policy with regard to sustainability matters; and
the business operations, events and achievements in that area in 2023
in accordance with the applicable criteria as included in the section ‘Criteria’.
In this assurance report, where we refer to the non-financial information, this includes the specified non-financial indicators as well, unless stated otherwise.
Basis for our opinion and qualified conclusion
For the calculation of the ‘insurance related emissions’ related to the insurance policies under control of mandated agents channels significant assumptions are used. We refer to management’s disclosure in chapter ‘8.1 About this report’ of the annual report. As mentioned by ASR Nederland N.V., the division over the sectors (in percentages) for ‘business’ in the provincial channel has been used as a proxy for determining the share per sector in the mandated agents channel. The same applies to make/model/fuel/mileage of private passenger cars. For these assumptions ASR Nederland N.V. has not been able to provide sufficient appropriate assurance evidence to substantiate the reasonableness of these assumptions. Therefore we have not been able to perform sufficient appropriate assurance procedures.
We performed our reasonable assurance engagement on the specified non-financial indicators and our limited assurance engagement on the non-financial information in accordance with Dutch law, including Dutch Standard 3810N ‘Assurance-opdrachten inzake duurzaamheidsverslaggeving’ (Assurance engagements relating to sustainability reporting). Our responsibilities under this standard are further described in the section ‘Our responsibilities for the assurance engagement on the non-financial information and specified non-financial indicators’ section of our report.
We are independent of ASR Nederland N.V. in accordance with the ‘Verordening inzake de onafhankelijkheid van accountants bij assurance-opdrachten’ (ViO, Code of Ethics for Professional Accountants, a regulation with respect to independence). Furthermore, we have complied with the ‘Verordening gedrags- en beroepsregels accountants’ (VGBA, Dutch Code of Ethics for Professional Accountants).
We believe the assurance evidence we have obtained is sufficient and appropriate to provide a basis for our opinion and conclusion.
Criteria
The criteria applied for the preparation of the specified non-financial indicators and the non-financial information are the GRI Sustainability Reporting Standards (GRI Standards) as listed in the GRI Content Index (chapter ‘9.3 GRI content index’) and the criteria supplementally applied as disclosed in chapter ‘8.1 About this report’ and ‘ 9.1 Glossary’ of the annual report.
The specified non-financial indicators and the non-financial information is prepared in accordance with the GRI Standards.
The comparability of specified non-financial indicators and the non-financial information between entities and over time may be affected by the absence of an uniform practice on which to draw, to evaluate and measure this information. This allows for the application of different, but acceptable, measurement techniques.
Consequently, the specified non-financial indicators and the non-financial information needs to be read and understood together with the criteria applied.
Materiality
Based on our professional judgement we determined materiality levels for each relevant part of the sustainability matter. When evaluating our materiality levels, we have taken into account quantitative and qualitative aspects as well as the relevance of information for both stakeholders and the company.
We agreed with the Supervisory Board that misstatements which are identified during the assurance engagement and which in our view must be reported on quantitative or qualitative grounds, would be reported to them.
Key assurance matter with respect to the specified non-financial indicators
Key assurance matters are those matters that, in our professional judgement, were of most significance in our assurance engagement on the specified non-financial indicators. We have communicated the key assurance matters to the Supervisory Board. The key assurance matters are not a comprehensive reflection of all matters discussed.
These matters were addressed in the context of our assurance engagement on the specified non-financial indicators as a whole and in forming our opinion thereon, and we do not provide a separate opinion on these matters.
The non-financial indicator on ASR Nederland N.V.’s reduction of the carbon footprint of portfolio for own account was determined to be a key assurance matter as the assessment is inherently subject to assumptions and management judgement due to data quality limitations of external sources, whereas the assessment of other important non-financial indicators require such judgement to a lesser extent.
Reduction of the carbon footprint of portfolio for own account
Description
ASR Nederland N.V. reports on the reduction of the carbon footprint of portfolio for own account. This is a non-financial target regarding the carbon footprint that shows the percentage of the scope 1 and 2 CO2-eq reduction of ASR Nederland N.V.'s internally managed assets under management (AuM) for the own account of ASR Nederland N.V., relative to the baseline year 2015. The reduction of the carbon footprint of portfolio for own account was significant to our reasonable assurance engagement, because:
we identified that it is as a material indicator for ASR Nederland N.V. to report on the environmental impact of its activities, and
the carbon footprint data used for reporting is inherently subject to assumptions and judgement due to data quality limitations.
Our response
We obtained an understanding of the reporting process, the applicable definitions and reporting criteria and we have evaluated the design and implementation of relevant internal controls. We inquired ASR Nederland N.V.’s staff members involved in the reporting process for the carbon
footprint of portfolio for own account to understand the application of the definitions and reporting criteria and we challenged the underlying evidence, such as the reliability of data used and expert opinions on methodologies used for the estimates of carbon emissions. Finally, we assessed whether the reporting criteria, assumptions, definitions and data quality are adequately disclosed in the annual report.
Our observation
We consider that the definitions and criteria for the carbon footprint of portfolio for own account as described in ASR Nederland N.V.’s reporting criteria, as disclosed in the section ‘Carbon footprint of portfolio for own account’ included in chapter ‘8.1 About this report’ of the annual report are appropriately applied and that the assumptions are adequately explained, including information on the data quality of the carbon footprint. We also consider the disclosure on the reduction of the carbon footprint of portfolio for own account as being adequate.
Emphasis of matter
We draw attention to page 7 and 8 on the ‘ Integration Aegon Nederland N.V.’ of the annual report, which describes the exclusion of the non-financial information related to Aegon activities from the assurance scope of non-financial information.
Our opinion and conclusion are not modified in respect of this matter.
Limitations to the scope of our assurance engagement
The non-financial information includes prospective information such as ambitions, strategy, plans, expectations, estimates and risk assessments. Prospective information relates to events and actions that have not yet occurred and may never occur. We do not provide assurance on the assumptions and achievability of prospective information.
The references to external sources or websites in the non-financial information are not part of the non-financial information as included in the scope of our assurance engagement. We therefore do not provide assurance on this information.
Our opinion and conclusion is not modified in respect to these matters.
Responsibilities of the Executive Board and Supervisory Board for the non-financial information and specified non-financial indicators
The Executive Board is responsible for the preparation and fair presentation of the non-financial information in accordance with the criteria as included in the section ‘Criteria’, including the identification of stakeholders and the definition of material matters. The Executive Board is also responsible for selecting and applying the criteria and for determining that these criteria are suitable for the legitimate information needs of stakeholders, considering applicable law and regulations related to reporting. The choices made by the Executive Board regarding the scope of the non-financial information and the reporting policy are summarized in the chapter ‘8.1 About this report’ of the annual report.
Furthermore, the Executive Board is responsible for such internal control as it determines is necessary to enable the preparation of the non-financial information that is free from material misstatement, whether due to fraud or error.
The Supervisory Board is responsible for overseeing the non-financial reporting process of ASR Nederland N.V.
Our responsibilities for the assurance engagement on the non-financial information and specified non-financial indicators
Our responsibility is to plan and perform the assurance engagement in a manner that allows us to obtain sufficient and appropriate assurance evidence for our opinion and conclusion.
Our reasonable assurance engagement on the non-financial indicators has been performed with a high, but not absolute, level of assurance, which means we may not have detected all material misstatements, whether due to fraud or error.
Our limited assurance engagement on the non-financial information is aimed to obtain a limited level of assurance to determine the plausibility of that non-financial information. The procedures vary in nature and timing from, and are less in extent, than for a reasonable assurance engagement. The level of assurance obtained in a limited assurance engagement is substantially less than the assurance that is obtained when a reasonable assurance engagement is performed.
We apply the ‘Nadere Voorschriften Kwaliteitssystemen’ (NVKS, Regulations for quality management systems) and accordingly maintain a comprehensive system of quality management including documented policies and procedures regarding compliance with ethical requirements, professional standards and applicable legal and regulatory requirements.
Our reasonable and limited assurance engagement included among others:
Performing an analysis of the external environment and obtaining an understanding of relevant non-financial or sustainability themes and issues, and the characteristics of the company;
Evaluating the appropriateness of the criteria applied, their consistent application and related disclosures in the specified non-financial indicators and the non-financial information. This includes the evaluation of the company’s materiality assessment and the reasonableness of estimates made by the Executive Board;
Obtaining a general an understanding of the internal control environment, the reporting processes, the information systems and the company’s risk assessment process relevant to the preparation of the specified non-financial indicators and the non-financial information.
Identifying areas of the specified non-financial indicators and the non-financial information where misleading or unbalanced information or a material misstatement, whether due to fraud or error, is likely to arise.
Designing and performing further assurance procedures aimed at determining the plausibility of the specified non-financial indicators and the non-financial information responsive to this risk analysis. These procedures consisted amongst others of:
Obtaining inquiries from management and/or relevant staff at corporate level responsible for the sustainability strategy, policy and results;
Obtaining inquiries from relevant staff responsible for providing the information for, carrying out internal control procedures on, and consolidating the data in the specified non-financial indicators and the non-financial information;
Obtaining assurance evidence that the specified non-financial indicators and the non-financial information reconciles with underlying records of the company;
Reviewing, on a limited test basis, relevant internal and external documentation;
Considering the data and trends.
Reconciling the relevant specified non-financial indicators and the financial information with the financial statements;
Reading the information in the annual report which is not included in the scope of our assurance engagement to identify material inconsistencies, if any, with the specified non-financial indicators and the non-financial information;
Considering the overall presentation and balanced content of the specified non-financial indicators and the non-financial information;
Considering whether the specified non-financial indicators and the non-financial information as a whole, including the sustainability matters and disclosures, is clearly and adequately disclosed in accordance with applicable criteria.
Additionally, our reasonable assurance engagement on the specified non-financial indicators included, among others:
Obtaining an understanding of internal control relevant to the reasonable assurance engagement in order to design assurance procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the company’s internal control;
Designing and performing further assurance procedures on the data supporting the specified non-financial indicators, such as sampling and validating data with appropriate supporting evidence.
We communicate with the Supervisory Board regarding, among other matters, the planned scope and timing of the assurance engagement and significant findings that we identify during our assurance engagement.
From the matters communicated with the Supervisory Board we determine the key assurance matters: those matters that were of most significance in the assurance engagement on the non-financial information. We describe these matters in our assurance report unless law or regulation precludes public disclosure about the matter or when, in extremely rare circumstances, not mentioning it is in the public interest.
Utrecht, 2 April 2024
KPMG Accountants N.V.
A.J.H. Reijns RA