The objective of a.s.r.'s business conduct policies and corporate culture is to ensure that all employees act with due care and integrity, fostering a positive work environment and maintaining the trust of customers, shareholders and society. The a.s.r. Code of Conduct forms a guideline for the actions and decisions of its employees, and it helps employees to perform their duties properly. It also forms the guideline for how colleagues interact with each other, how a.s.r. serves its customers and how a.s.r. takes responsibility for the environment. By embedding these principles in the corporate culture, a.s.r. aims to create a responsible organisation that contributes positively to society.

The following table presents a comprehensive overview of the material impacts, risks and opportunities identified, along with the corresponding policies, actions, targets and metrics. The purpose of this table is to highlight the linkages and dependencies among these elements.

6.4.1.1Governance

The role of the administrative, management and supervisory bodies

See section 5.1 for the role of the administrative, management and supervisory bodies.

6.4.1.2Managing impacts, risks, and opportunities

Description of the processes to identify and assess material impacts, risks and opportunities

a.s.r.’s approach to determining its material impacts, risks and opportunities is described in section 6.1.4.

6.4.1.3Policies

Business conduct policies and corporate culture 15.217.1

The foundation of a.s.r.'s corporate culture is encapsulated in “The Story of a.s.r.,” which provides a shared perspective, fosters connection, and serves as a compass for actions. a.s.r. expects everyone at a.s.r. to operate based on three core values:

1. We are helpful. We consider the needs of our clients and advisors at every step, understanding their requirements. We coordinate meticulously and honour our commitments;

2. We think ahead. We prepare thoroughly. We listen attentively, offering appropriate solutions based on our expertise, experience, and dedication;

3. We achieve results. We are precise in both content and process, take responsibility, and complete what we start. Together, we achieve the desired outcomes.

Additionally, a.s.r. expects all employees to demonstrate courage and personal leadership. a.s.r.'s interactions reflect this approach:

1. We share dilemmas and make them open to discussion;

2. Diversity, equity, and inclusion are key to mutual understanding and respect;

3. We give each other space for dialogue and reflection and dare to challenge each other, even when something isn't going well;

4. Our frameworks are defined and clear. We place responsibility as low in the organisation as possible;

5. We say what we do and do what we say.

The a.s.r. Code of Conduct is a cornerstone of the corporate culture, guiding the actions and decisions of employees. It emphasises compliance with laws and sector agreements, respect for each other, fair treatment of customers, and responsible handling of company property and data. The Code of Conduct also addresses the importance of avoiding conflicts of interest and acting ethically and responsibly. It is part of every employee's employment contract and applies to anyone working for a.s.r.

All employees take an oath or make a solemn affirmation when they start as employees at a.s.r. This involves, for example, declaring that they will act with integrity and due care. See section 5.5.3. for more information about the Code of Conduct.

a.s.r. has taken a number of control measures to prevent, identify and combat unethical behaviour, including combating corruption and bribery. Examples of control measures include integrity screening carried out by the Security Affairs department prior to hiring new employees as well as in-employment screening. This integrity screening also extends to contracting parties. This screening is conducted to minimise the risk of a.s.r. working with individuals or entities that could harm its integrity.

a.s.r. has a policy to prevent, recognise, report, investigate and adequately deal with unethical behaviour (including fraud, conflicts of interest and bribery and corruption). With regard to unethical conduct a.s.r. applies a zero-tolerance policy.

a.s.r. has established robust mechanisms for reporting non-compliance and incidents. The Security Affairs department is responsible for investigating reports of behaviour lacking integrity, operating independently of the management chain. Regular reports on investigations are discussed with the CEO, and serious violations are communicated to the MB, risk committees and regulators.

Asset Management 15.115.3

Asset Management recognises the materiality of two key impacts in its investment strategy, both falling under the subtopic of corporate culture. Asset Management believes that a strong and aligned corporate culture can drive better long-term decision-making, increase employee satisfaction and ultimately improve financial performance at investee companies. Poor corporate governance practices, such as perverse incentive structures or ill-equipped leadership, can often lead to poor short-term management of environmental and social issues. For these reasons, corporate governance, which includes corporate culture, is part of the Policy on Responsible Investments.

As part of its biannual screening process, Asset Management evaluates corporate governance practices within its investment portfolio. This evaluation includes assessing key corporate culture indicators such as the establishment of sound management structures, employee relations, diversity, equity and inclusion. In addition, when making investment decisions, Asset Management considers how well companies perform on key corporate culture criteria. Examples of these criteria are i) effectively communicating with employees about matters affecting their work and employment conditions and ii) promoting diversity within their organisation.

Suppliers in the upstream value chain 16.1

a.s.r. is continuously considering improvements in its relationships with suppliers in the upstream value chain to enhance the selection process with regard to social and environmental criteria. Compliance with environmental, human rights and labour rights standards is reviewed during the monitoring of suppliers. 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 value chains. a.s.r. has a Supplier Code of Conduct for the centralised procurement, which includes expectations regarding compliance with working conditions and human rights principles, and other relevant standards. The Supplier Code of Conduct provides clarity about key principles in the field of sustainable procurement.

The total procurement of a.s.r. is sourced from various channels, including the central procurement stream via the Procurement department, which handles operational expenditures, and the decentralised procurement streams, which are related to specific products and services expenditures. Decentralised procurement streams occur within Real Estate, Health, P&C, Individual life and Funeral, and Disability.

P&C, Real Estate and Individual life and Funeral

P&C, Real Estate and Individual life and Funeral have decentralised procurement but adhere to central policies.

Disability 

Disability manages its supplier relationships and impacts on the value chain through agreements aimed at improving service quality and reducing claims costs. All suppliers are based in the Netherlands and comply with Dutch regulations, focusing on service procurement. Disability periodically discusses operational matters with its partners but has not yet considered social and environmental criteria in supplier selection.

Providers in Disability’s value chain help insured employers with employee reintegration. Disability negotiates with providers to secure the best price-quality ratio, benefiting employers by reducing costs. Employers remain responsible for reintegration but can opt to use Disability’s services. Both employers and Disability benefit from successful reintegration, as it lowers claims costs and premiums.

Disability’s occupational health service providers, provide occupational health services included in some of Disability’s absenteeism products. These partners help employers comply with Dutch laws on workplace safety and health, and the Gatekeeper Improvement Act, which aims to expedite the return of sick employees to work. Disability simplifies this process by offering insurances for absenteeism that can automatically including these services.

Health 

Procurement is partially centralised. For the decentralised procurement, the following agreements apply: a.s.r. procures healthcare services from providers, adhering to its duty of care, which mandates that insurers ensure sufficient, accessible and high-quality care within a reasonable distance. Due to the limited availability of healthcare services, a high contracting rate is pursued. ESG impacts are not strict evaluation criteria. Within the industry association, insurers collectively determine ESG requirements, which are detailed in the sustainability section of the procurement policy. a.s.r. follows this policy.

Distribution and services entities

Robidus and Corins have their own procurement policies. The procurement and supplier policy primarily focuses on information security and does not include oversight of suppliers’ compliance with human rights and labour standards this will be a focus point for 2025. 

TKP

TKP currently lacks a dedicated sustainability policy for supplier selection but aims fair working conditions through its Procurement and Outsourcing Policy. While there is no formal system for evaluating sustainability criteria, TKP is increasingly considering social and environmental factors in new supplier relationships. TKP’s supplier questionnaire asks about Corporate Social Responsibility (CSR) policies and social return contributions, though these are not yet fully integrated into decision-making.

TKP acknowledges the importance of managing social and environmental risks in the value chain and is exploring ways to enhance risk management processes. TKP’s Procurement and Outsourcing Policy aims fair labour conditions through supplier remuneration standards, and TKP aims to broaden this approach.

Ensuring timely payments 16.1

a.s.r. is aware that late payments can have a significant impact on its suppliers and outsourcing partners, especially for SMEs. In light of this, a.s.r. upholds a strong commitment to ensure timely and efficient payment practices. A standard payment term of 30 days, as stated in the general purchasing terms and conditions, is uniformly adhered to within the procurement processes of a.s.r. The distribution and services entities also adhere to the standard payment term of 30 days except for Corins which maintains a 14 day payment term.

The procurement processes ensure that invoices are paid within 30 days of receipt. If an invoice is received before the products have been delivered in their entirety, a.s.r. will pay the invoice within 30 days of full delivery, as stated in the general purchasing terms and conditions.

This standard payment term is consistently adhered to, without making a distinction between suppliers, whether they are SMEs or established suppliers, and regardless of the invoice amount. All incoming invoices, both centralised and decentralised, are processed and paid timely upon approval.

Prevention and detection of corruption and bribery 15.217.2

a.s.r. has implemented a policy to prevent, detect, report, investigate and adequately handle unethical behaviour, including fraud, conflicts of interest, corruption and bribery. a.s.r. maintains a zero-tolerance policy towards unethical behaviour. This policy is outlined in the Code of Conduct and the Anti-corruption Policy and is in line with UN Guiding Principles on business and human rights.

This Anti-corruption policy complements the rules of conduct of a.s.r. and should be read in conjunction with related a.s.r. policies. Particularly with the Incentives Policy, the Outside business activities Policy, the Sponsorship and Donation Policy and the Group Policy on Conflicts of Interest.

The Anti-corruption Policy applies to all employees who perform work for a.s.r. under a contract of employment, or those who perform work for or on behalf of a.s.r. other than as an employee. (hereinafter: a.s.r. employees).

Receiving or providing incentives may compromise the integrity of a.s.r. and its employees. For this reason, employees are encouraged to exercise restraint when accepting or offering gifts and invitations (incentives). An incentive is not permitted if it might have an impact on conduct. All incentives must always be reported to Compliance. Receiving cash is not allowed. An incentive must comply with the principles set out in the Incentives Policy. These principles include that the incentive must fit within the statutory framework, be in line with public opinion, social views, not be excessive, be explainable, be proper in light of the business conducted and must be in the best interest of the customer. Similarly, when an employee offers a gift or invites a business contact to an event, for instance, this could influence the judgement of the recipient and may therefore harm the reputation of a.s.r. When offering a gift, the employee must report this beforehand.

Reporting incidents

All a.s.r. employees must report unethical behaviour, including suspicions and attempts of bribery or other forms of corruption and bribery, to their manager and/or the Compliance Officer. Employees can also report an integrity incident through the Reporting Point. It may happen that an employee cannot reasonably bring a wrongdoing to attention through the regular route. In that case, the employee may make use of the Whistleblower Scheme. Employees who make a report in good faith of what they believe to be a violation of this policy will be protected from retaliation in accordance with the Whistleblower Scheme.

The Investigation department is responsible for investigating reports of unethical behaviour by employees, intermediaries and contract parties. Incidents may involve fraud, theft, corruption and bribery, conflicts of interest, discrimination and inappropriate behaviour. The Security Affairs department operates independently of the management chain. Each quarter, Investigations department reports on the investigations conducted regarding unethical behaviour by employees, intermediaries and contract parties. This report is discussed with the CEO. The MB, a.s.r. risk committees and regulators are informed of any serious violations.

Awareness

To ensure that the Code of Conduct and related behavioural rules are well-known and understood, a.s.r. conducts various initiatives annually. These include training sessions, presentations and the voluntary use of the Gamification training tool to enhance knowledge on topics such as the Code of Conduct and, Customer Due Diligence (CDD) and information security. The effectiveness of these programmes is evaluated annually.

The central awareness initiatives are intended for 100% of all employees, without specifically defining high-risk functions. All employees, including the MB of a.s.r., may encounter risks surrounding corruption and bribery and other risks regarding conflicts of interest in the board sense (including outside business activities and incentives). Therefore, all staff of a.s.r. receive a training about this topic.

Employees are encouraged to engage in dialogue about integrity issues to collectively find good solutions. Additionally, training and presentations are conducted within the various product lines and staff functions.

In 2024, a multidisciplinary central awareness programme was established to structurally promote awareness in areas such as the Code of Conduct, privacy, IT security and CDD starting in 2025.

See section 5.5.4 for more information.

Actions and Targets

At present, a.s.r. does not have specific actions and targets set for business conduct. These will be addressed and prioritised upon for 2025. For reporting year 2024, no sufficient time and resources were available. However, a.s.r. remains committed to continuously improve governance practices and risk management processes. The approach includes monitoring emerging risks and adapting strategies accordingly.

Maintaining a strong governance framework and robust risk management processes is essential for the long-term success of the organisation. a.s.r. will continue to review and enhance policies and practices to ensure they meet the evolving needs of stakeholders and the CSRD requirements in 2025.

6.4.1.4Metrics

See section 6.5.5.1 for CSRD reporting policies.

At a.s.r., no distinction is made between roles with higher risks of corruption and bribery, as these risks can affect any employee. Therefore, training on conflicts of interest, including corruption and bribery, is mandatory for all staff. 93% of employees have completed the required training programmes. While training is mandatory, there may be colleagues who don't complete the training due to absence.

See section 6.5.5.2 for CSRD reporting policies.

In the reporting period, there were no recorded incidents of violations related to anti-corruption and anti-bribery laws. Consequently, there were no convictions or fines imposed.

See section 6.5.5.3 for CSRD reporting policies.

a.s.r. upholds a strong commitment to ensure timely and efficient payment practices. Its procurement processes uniformly adhere to a standard payment term of 30 days. a.s.r. adheres to this standard consistently, without making a distinction between suppliers, whether they are SMEs or established suppliers, and regardless of invoice amount. All incoming invoices, both centralised and decentralised, are processed and paid timely upon approval.

On average, invoices are paid within nine days from the start of the contractual or statutory payment term. This prompt payment schedule reflects a.s.r.'s dedication to maintaining healthy and reliable relationships with its suppliers and partners. Additionally, 99% of a.s.r.'s payments are aligned with standard payment terms of 30 days and there are no outstanding legal proceedings related to late payment. The remaining 1% of payments paid beyond the payment term are for instance related to incorrect data on the invoices or incorrect addressing to wrong departments.