8.3.2Minimum disclosure requirements
8.3.2.1MDR - Policies
E1
| Policy | Scope of policy | Relevant IRO | Accountable for implementation | Relevant third-party standards/initiatives (if applicable) |
| The Environmental Policy Statement of Facilities | a.s.r.'s office locations | 2.2 | Management team of Facilities | Paris Proof standard |
| Policy on responsible investments | Assets under management of Asset Management | 2.1, 2.2, 2.3, 2.4 | Management team of Asset Management | Paris Agreement |
| ESG Policy of Real Estate | Assets under management of Real Estate | 1.1, 1.2, 2.1, 2.2, 2.3 | Management team of Real Estate | n/a |
| Mortgages Transition Plan | Mortgages | 1.1, 1.2, 2.1, 2.2, 2.4 | Management team of Mortgages | n/a |
| Policy on Sustainable Insurance | Non-life & Life insurance products and services. | 1.1, 1.2, 1.3, 2.1, 2.2, 2.3, 2.4 | Management teams of P&C, Income, Health, Pensions, Life Individual and Funeral | Paris Agreement |
| Procurement policy of Health | Healthcare sector in the Netherlands. | 2.2 | Management team of Health | Green Deal Sustainable Healthcare (GDDZ 3.0) |
| Further agreements | Procurement | 2.1, 2.2 | Management team of Procurement | |
| Code of Conduct for suppliers | Procurement | 2.1, 2.2 | Management team of Procurement | n/a |
| Outsourcing policy | Procurement | 2.1, 2.2 | Management team of Procurement | n/a |
| Procurement policy of IT | IT | 2.2 | Management team of IT | n/a |
E2
| Policy | Scope of policy | Relevant IRO | Accountable for implementation | Relevant third-party standards/initiatives (if applicable) |
| Procurement policy of Health | Health | 2.2 | Management team of Health | Green Deal Sustainable Healthcare Chain approach to pharmaceutical residues from water |
E4
| Policy | Scope of policy | Relevant IRO | Accountable for implementation | Relevant third-party standards/initiatives (if applicable) |
| Policy on Responsible Investments | Assets under management of Asset Management | 3.2, 4.1, 4.3 | Management team of Asset Management | UN Global Compact EU regulation UNESCO biosphere reserves, CITES convention UN CBD Marine Stewardship Council and its Chain of Custody standards and aquaculture Stewardship Council certification Finance for Biodiversity pledge TNFD framework of the United Nations Environment Programme Finance Initiative (UNEP FI) |
| Real Estate Biodiversity Framework | Assets under management of Real Estate | 3.1, 3.2, 3.3, 4.2, 4.3 | Management team of Real Estate | Finance for Biodiversity pledge TNFD framework of the United Nations Environment Programme Finance Initiative (UNEP FI) |
| Policy on Sustainable Insurance | Non-life and Life insurance products and services. | 3.2, 4.1, 4.3 | Management teams of P&C, Income, Health, Pensions, Life Individual and Funeral | TNFD framework of the United Nations Environment Programme Finance Initiative (UNEP FI) |
E5
| Policy | Scope of policy | Relevant IRO | Accountable for implementation | Relevant third-party standards/initiatives (if applicable) |
| ESG Policy of Real estate | Assets under management of Real Estate | 5.1, 6.1 | Management team of Real Estate | n/a |
| Policy on Sustainable Insurance | P&C | 5.2, 7.2 | Management team of P&C | Erkend Duurzaam and Groen Gedaan |
| Procurement policy of Health | Health | 5.2, 7.2 | Management team of Health | Green Deal Sustainable Healthcare (GDDZ) 3.0. |
S1
| Policy | Scope of policy | Relevant IRO | Accountable for implementation | Relevant third-party standards/initiatives (if applicable) |
| Code of Conduct | All employees of a.s.r. | 8.1, 8.2, 9.1, 10.1, 10.2, 10.3 | HR & Compliance | None |
| Collective Labour Agreement | All employees of a.s.r. | 8.1, 8.2, 9.1, 10.1 | HR & Compliance | None |
| Human rights Policy | All employees of a.s.r. | 8.1, 8.2, 10.1, 10.2, 10.3 | HR & Compliance | None |
| Remuneration Policy | All employees of a.s.r. | 8.1, 8.2, 10.1, 10.2, 10.3 | HR & Compliance | None |
| Diversity, Equity and Inclusion Policy | All employees of a.s.r. | 8.1, 8.2, 10.1, 10.2, 10.3 | HR & Compliance | Talent to the Top mentoring programme TNO’s Corporate Social Responsibility Performance ladder |
| Whistleblower Policy | All employees of a.s.r. | 8.1, 8.2, 9.1, 10.1, 10.2, 10.3 | HR & Compliance | Dutch Whistleblower Protection Act |
| Unwanted Behaviour Complaint Procedure | All employees of a.s.r. | 8.1, 8.2, | HR & Compliance | None |
| General Complaints Procedure Regulations | All employees of a.s.r. | 8.1, 8.2, 10.1, 10.2, 10.3 | HR & Compliance | None |
| The Other Plan 2024-2026 | All employees of a.s.r. | 8.2 | HR & Compliance | None |
| Privacy Policy | All employees of a.s.r. | 9.1 | HR & Compliance | None |
| Health and Safety Policy Plan | All employees of a.s.r. | 8.1 | HR & Compliance | None |
| Data Retention Policy | All employees of a.s.r. | 9.1 | HR & Compliance | None |
| General Data Protection Regulation | a.s.r and its subsidiaries | 9.1 | HR & Compliance | General Data Protection Regulation (GDPR) |
S2
| Policy | Scope of policy | Relevant IRO | Accountable for implementation | Relevant third-party standards/initiatives (if applicable) |
| Policy on Responsible Investments | Assets under management of Asset Management | 11.1 | Management team of Asset Management | OECD Guidelines for Multinational Enterprises OECD Watch National Contact Points database Business & Human Rights Recourse Centre allegations and litigations database |
| Human rights Policy | a.s.r. | 11.1 | Team Sustainability | UN Guiding principles |
S4
| Policy | Scope of policy | Relevant IRO | Accountable for implementation | Relevant third-party standards/initiatives (if applicable) |
| Policy on Sustainable Insurance | Non-life and Life insurance products and services. | 12.1, 12.2 | Management teams of P&C, Income, Health, Pensions, Life Individual and Funeral | None |
| Privacy policy | Personal data handled by a.s.r. | 12.1, 12.2, 12.3 | Privacy expert, Legal, Compliance en BRM | Data Protection Impact Assessment |
| Data Retention policy | All data processed by a.s.r. | 12.1, 12.2, 12.3 | Compliance, Enterprise Risk Management (ERM) | None |
| Customer due diligence policy | New customers of a.s.r. | 12.1, 12.2 | Management teams of P&C, Income, Health, Pensions, Life Individual and Funeral | None |
| Communication policy | All communication of a.s.r. | 12.1, 12.2 | Corporate Communication | None |
| Policy for involving and informing clients | Clients of a.s.r. health | 12.1, 12.2 | Health | - IZA - GALA - WOZO - TAZ - Universal Declaration of Human Rights - UN Global Compact - UN Guiding Principles on Business and Human Rights, - OECD Guidelines for Multinational Enterprises |
| Whistleblower policy | Consumers of a.s.r. | 12.1, 12.2 | Compliance | None |
| Product Approval and Review Process policy | Products and Services a.s.r. actively offers, as well as existing (including non selling) products and services | 13.1, 13.2 | PARP committee | None |
| Responsible mortgage lending management policy | Mortgages | 14.1 | Management team of Mortgages | None |
G1
| Policy | Scope of policy | Relevant IRO | Accountable for implementation | Relevant third-party standards/initiatives (if applicable) |
| Code of Conduct | All employees of a.s.r. | 15.1, 15.2, 17.1 | Investigations department, Security Affairs, CEO & MB | UN Guiding Princples on business and human rights. |
| Policy on Responsible Investments | Assets under management of Asset Management | 15.1, 15.3 | Management team of Asset Management | None |
| Supplier Code of Conduct | all suppliers of a.s.r. | 16.1 | Procurement | None |
| Procurement and supplier policy | All suppliers of Robidus & Corins | 16.1 | Management teams of Robidus and Corins | None |
| Procurement Policy of Health | Health (healthcare providers, in particular pharmacists, hospitals and mental health providers) | 16.1 | Management team of Health | None |
| Procurement and Outsourcing policy | TKP | 16.1 | Management team of TKP | None |
| Anti-corruption Policy | all employees of a.s.r. | 17.1 | Compliance | UN Guiding Principles on business and human rights. |
| Incentives Policy | all employees of a.s.r. | 17.1 | Compliance | None |
| Outside business activities Policy | all employees of a.s.r. | 17.1 | Compliance | None |
| Sponsorship and Donation Policy | all employees of a.s.r. | 17.1 | Compliance | None |
| Group Policy on Conflicts of Interest | all employees of a.s.r. | 17.1 | Compliance | None |
| Whistleblower policy | all employees of a.s.r. | 17.1 | Compliance | None |
| Customer Due Diligence policy | a.s.r and its subsidiaries | 17.1 | Management teams of P&C, Income, Health, Pensions, Life Individual and Funeral | None |
8.3.2.2MDR - Actions
Time horizon of below actions are continuous, unless stated otherwise in the description of the action in Section 6. Affected stakeholder groups, when applicable, are stated in the description of the action in Section 6.
E1
| Action | Product line, staff function, and/or other | Value chain scope (upstream/own operations/downstream) |
| Assess adaptation solutions for highly exposed assets | Mortgages | Downstream |
| Increase climate adaptive thinking for residential homes | Mortgages | Downstream |
| Develop products which incentivise prevention measures | P&C | Downstream |
| Make impact investments | Asset management, Real estate, Mortgages | Upstream, downstream |
| Participate in industry collaborations | Asset management | Upstream, downstream |
| Invest in renewable energy | Real estate | Upstream, downstream |
| Increase on-site renewable energy generation | Real estate | Upstream, downstream |
| Engage through sustainable living platform/partner network | Mortgages | Upstream, downstream |
| Make renewable energy initiatives insurable | P&C | Upstream, downstream |
| Develop products | P&C | Upstream, downstream |
| Engage through various platforms | P&C | Upstream, downstream |
| Use renewable energy | Facilities | Upstream, own operations, downstream |
| Purchase market-based green electricity | Facilities | Upstream, own operations, downstream |
| Promote eco-friendly transportation/hybrid working | Facilities | Upstream, own operations, downstream |
| Extend use of hardware | Facilities | Upstream, own operations, downstream |
| Exclude investments in certain activities/sectors | Asset management | Downstream |
| Carry out active ownership | Asset management | Downstream |
| Minimise energy consumption | Real estate | Downstream |
| Reduce environmental impact | Real estate | Downstream |
| Increase on-site renewable energy generation | Real estate | Downstream |
| Offer specific mortgage products/opt-in mortgage offers. | Mortgages | Downstream |
| Apply underwriting criteria | P&C | Downstream |
| Refer to certified repairers | P&C | Downstream |
| Stimulate to reduce GHG emissions | Health | Downstream |
| Stimulate to provide mobility plan | Health | Downstream |
| Stimulate to design framework for real estate action | Health | Downstream |
| Stimulate to produce GHG roadmaps. | Health | Downstream |
| Develop products | Life individual and Funeral | Downstream |
| engage with network | Life individual and Funeral | Downstream |
| support the development of industry-wide GHG calculation methodology. | Life individual and Funeral | Downstream |
E2
| Action | Product line, staff function, and/or other | Value chain scope (upstream/own operations/downstream) |
| Stimulate healthcare providers to prevent impact. | healthcare providers, specifically pharmacists, | Upstream |
| Raise awareness among insured. | Insured cliënts | Downstream |
| Make sustainability part of the preference policy for medication. | healthcare providers, specifically pharmacists, | Upstream |
E4
| Action | Product line, staff function, and/or other | Value chain scope (upstream/own operations/downstream) |
| Contribute to restoration | Real estate | Downstream |
| broaden knowledge | Real estate | Downstream |
| offer products | Real estate | Downstream |
| Carry out active ownership | Asset management | Upstream, downstream |
| use biodiversity criteria | Asset management | Upstream, downstream |
| Collaborate | Asset management | Upstream, downstream |
| carry out impact investment | Asset management | Upstream, downstream |
| Promote material use. | P&C | Upstream, downstream |
| Apply underwriting criteria | P&C | Upstream, downstream |
| Make renewable energy initiatives insurable | P&C | Upstream, downstream |
| Engage and participate | | Upstream, downstream |
| Identify high-potential assets to enhance the potential ecological value in the portfolio. | Real estate | Downstream |
| Take nature related risks into consideration in Real Estate management. | Real estate | Downstream |
E5
| Action | Product line, staff function, and/or other | Value chain scope (upstream/own operations/downstream) |
| Introduce circular building principles in ESG strategy and policy | Real estate | Upstream |
| Refer customers to have damage repaired by certified companies | P&C | Upstream |
| Encourage healthcare providers to reduce the use of raw materials when purchasing aids | Health | Upstream |
| Promote the use of recycled parts among car repair shops | P&C | Downstream |
| Make recycling activities insurable through Corins | Corins | Downstream |
| Facilitate waste seperation and perform a waste scan of the residual waste | Facilities | Upstrea, own operations, downstream |
| Research criteria for sustainable procurement among health insurers to prevent waste | Health | Upstrea, own operations, downstream |
| Promote the reuse of materials | Real estate | Upstream, downstream |
S1
| Action | Scope of actions (e.g. product line/staff function/other) | Value chain scope (upstream/own operations/downstream) |
| Provide training that contribute to more diversity, equality and inclusion. | HR | Own operations |
| a.s.r. has established a Talent Committee and Recruitment & Selection Committee to promote the advancement of female talent. | HR | Own operations |
S2
| Action | Scope of actions (e.g. product line/staff function/other) | Value chain scope (upstream/own operations/downstream) |
| Asset management conducts human rights risk assessments frequently. | Asset management | Own operations |
| Asset Management screens bi-annually its investment portfolio. | Asset management | Own operations |
| Real estate conducts human rights risk assessments every three years | Real estate | Own operations |
S4
| Action | Scope of actions (e.g. product line/staff function/other) | Value chain scope (upstream/own operations/downstream) |
| Employees are trained in accessibility, which is integrated into design, development, and editorial processes. | HR, Compliance | Own operations, downstream |
| Digital environments are tested, and experts assess accessibility, with user feedback included. | Compliance | Own operations, downstream |
| Conduct tenant satisfaction surveys. | Real estate | Own operations, downstream |
| Health launched Gezond.nl, Thuisfysio, Welshop, and promotes a healthy lifestyle to reduce healthcare burden. | Health | Own operations, downstream |