This section outlines a.s.r.'s commitment to addressing the material impacts, risks, and opportunities associated with workers in its value chain, focusing on key areas such as Asset Management and Real Estate. Moreover, the material impacts for a.s.r. health basic and a.s.r. health supplementary are not material for a.s.r. group and are disclosed separately in subsection 6.3.2.4. For more information, see section 6.1.4.5.

For Asset Management and Real Estate, the primary concerns are forced labour and child labour. These issues are prevalent in high-risk countries where labour laws may be less stringent, leading to significant negative impacts on workers' rights and well-being. a.s.r. is dedicated to implementing robust policies and actions to mitigate these risks, ensuring that a.s.r.'s investments do not contribute to such practices.

a.s.r.'s approach to managing these impacts involves regular human rights risk assessments, stakeholder engagements, and the implementation of comprehensive policies aligned with international standards such as the UN Guiding Principles on Business and Human Rights. By fostering positive changes and addressing systemic issues, a.s.r. strives to create a more equitable and sustainable value chain for all value chain workers involved.

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

6.3.2.1Managing impacts, risks, and opportunities

Interests and views of stakeholders

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

Asset Management and Real Estate is committed to include all value chain workers likely to be materially impacted by its operations, products, services, and business relationships in its disclosures. This includes workers on-site who are not part of the own workforce, those in the upstream and downstream value chains, and particularly vulnerable groups. The material impacts for Asset Management and Real Estate are forced labour and child labour.

a.s.r. identifies significant risks of forced labour and child labour in (value chains) of portfolio companies, particularly in specific geographic areas and sectors. a.s.r. distinguishes between systemic issues and individual incidents.

Positive impacts include initiatives like updated purchasing practices and capacity-building for value chain workers, aimed at job creation and skill enhancement.

Regular human rights risk assessments helps a.s.r. to manage material risks and opportunities related to value chain workers. Engagement with companies in high-risk sectors aims to drive positive changes, particularly in consumer goods, finance, and IT.

a.s.r. understands that workers with specific characteristics or in certain contexts may be at greater risk of harm. This understanding informs a.s.r.'s risk management and engagement strategies.

6.3.2.2Policies and actions

Policies

a.s.r. endorses and respects the basic principles of human rights, recognising that they are universal, interdependent and indivisible. a.s.r. adheres to international standards such as the International Bill of Human Rights and the UN Guiding Principles on Business and Human Rights (UNGPs), which apply to all companies, including investors. Human rights are very important for a.s.r. and can be found in the Sustainability Strategy and the Policy on Responsible Investments which oversees all assets under the management of Asset Management. Concerns about negative impacts on human rights caused by activities of a.s.r. or its business partners can be directed to Human Rights Reporting Point. As outlined in the Human Rights Policy, a.s.r. will take responsibility and provide adequate compensation in the event of human rights violations resulting from its activities or within its value chain.

Policy on Responsible Investments 11.1

The Policy on Responsible Investments outlines the vision of Asset Management regarding responsible investing. Asset Management aims to create positive impact through investments that contribute to a better world. This includes minimising negative effects and maximising positive effects on environmental, social, and governance (ESG) issues. Asset Management recognises that human rights violations by companies are often a result of systemic issues that cannot be resolved immediately. Asset Management is committed to adhering to the six human rights due diligence steps in line with the OECD Guidelines for Multinational Enterprises and the UNGPs. Similar expectations are held for companies in the investment portfolio as for business partners.

The governance structure of the Policy on Responsible Investments is detailed, including the roles of the MB, the ESG Committee, and other relevant bodies. The MB is ultimately responsible for the development and implementation of the policy, while the ESG Committee oversees compliance and progress on ESG objectives. The Policy on Responsible Investments emphasises the importance of transparency and periodic reporting on the progress and results of the sustainability policy. Asset Management regularly publishes reports and updates to inform stakeholders about the impact of its investments.

Asset Management frequently conducts an analysis of human rights risks within its investment portfolio. Asset Management bases its methodology on guidance from the UN Principles for Responsible Investment and uses information from ESG data providers and additional sources such as the OECD Watch National Contact Points database and the Business & Human Rights Resource Centre allegations and litigations database. From these data sources, information on company performance and controversies related to human rights is extracted. The analysis includes only companies that are part of the Asset Management investment portfolio. To validate the results of the analysis, Asset Management frequently meets with specialists and stakeholders.

Human Rights Policy 11.1

a.s.r. respects and protects human rights in its various roles:

• Investor: a.s.r. screens investments for human rights compliance and excludes companies that violate these rights.

• Provider of Insurance and Financial Products: a.s.r. safeguards customer privacy, promotes equal treatment, and avoids discrimination in its products and services.

• Purchaser: a.s.r. expects suppliers to respect and endorse human rights, and requires them to sign the Code of Conduct.

• Employer: a.s.r. strives for an inclusive culture and a safe working environment, and regularly trains employees on the Code of Conduct.

The Human Rights Policy of a.s.r. emphasises the commitment to respecting and protecting human rights. This policy is integrated into a.s.r.'s strategy and core activities, aiming to make a positive contribution to the sustainability of society and to minimise negative impacts. The governance structure of a.s.r. includes various roles and responsibilities, such as the MB, which approves and annually evaluates the human rights policy. Additionally, there are specific teams and committees that oversee compliance and progress of the policy. The policy emphasises the importance of transparency and accountability. a.s.r. regularly reports on the impact of its activities on human rights and the results of its policy in Annual Reports, engagement reports, and other publications.

Real Estate is active in the real estate market as an investor on behalf of institutional investors and as an investment manager. Real Estate is invested – directly and indirectly – in real estate and infrastructure assets whilst managing these assets and portfolios on behalf of its institutional client base. For its clients, Real Estate acquires, sells, redevelops and manages property portfolios on a discretionary basis. Real Estate invests on a separate account basis for external clients, including other a.s.r. entities. In doing so, it acknowledges the risk of being associated with negative impacts on human rights, including value chain workers. As part of a.s.r., Real Estate is committed to the a.s.r. human rights policy. The human rights policy is an integral part of Real Estate's ESG vision, which emphasises the well-being and social equality of people in its value chain.

Engaging with value chain workers 11.1

Asset Management

In Asset Management's most recent human rights risk analysis, three sectors with significant risks were identified:

• Consumer discretionary and staples

• Finance

• IT.

Within these three sectors, Asset Management identified the issues that are most occurring in the portfolio by analysing controversy reports, supplemented with other qualitative data sources. In the analysis, Asset Management took into consideration the potential likelihood and severity (based on scope, scale and irremediability).

Asset Management does not directly engage with value chain workers. Asset Management engages with representatives of workers, such as trade unions and NGOs, and with investee companies themselves. Asset Management's decisions on which investee companies to engage with are prompted by the human rights risk analysis and controversies that are reported as a result of the biannual screening.

Real Estate

Real Estate primarily invests (directly) in the Dutch real estate market and has limited exposure (and therefore limited influence) to real estate investments in high-risk countries. As such, Real Estate does not engage with value chain workers about impacts.

Raising concerns

General

a.s.r. is committed to maintaining an open and ethical culture where concerns about potential misconduct or irregularities can be reported safely and confidentially. The whistleblower policy is designed to facilitate the reporting of such concerns, ensuring they are addressed appropriately to uphold the integrity and reputation of the organisation. Importantly, this policy is not only available to current and former employees but also extends to third parties, allowing them to report any suspected wrongdoing. For more information about the whistleblower policy, see section 6.3.1.2 and 6.4.1.3.

Asset Management

Asset Management avoids investing in companies that do not meet a.s.r.'s minimum standards or are involved in activities that cause significant harm to people. In connection to this, Asset Management defined a number of exclusion rules relating to controversial behaviour on which its investments are screened twice per year. Examples of these exclusion rules are companies with severe (and repeated) controversies relating to human and labour rights, these include forced labour and child labour. All exclusion rules and screening criteria can be found in the Policy on Responsible Investments and detailed screening criteria. Asset Management may decide to engage with a company prior to deciding to exclude it from its investable universe.

In the Policy on Responsible Investments, Asset Management explicitly mentions human right risks and describes this as a priority area for its engagement activities. Asset Management believes that constructive and collaborative engagement is the most effective way to drive positive change in the companies, but Asset Management is also prepared to take stronger action if necessary. Of which excluding companies from the investable universe and divesting a.s.r.'s holding is the strongest. For the complete engagement escalation framework, see the section on 'Actions' below.

In general, asset managers with diverse portfolios have limited remediation possibilities. Workers at investee companies, including value chain workers, could in theory raise their concerns via a.s.r.’s Human Rights Reporting Point, but the likelihood of this occurring in practice is very low, and it has not occurred to date. On the other hand, a.s.r. engages with companies on human rights topics such as forced and child labour, and in these engagements, a.s.r. often urges investee companies to put in place channels to raise concerns and processes to remediate negative impact.

Real Estate

Real Estate aims to prevent negative impacts on value chain workers by operating a due diligence process in line with the OECD Guidelines for Multinational Enterprises. A due diligence process is, among other things, operated to identify risks relating to human rights including labour rights, with a view to ceasing, preventing or mitigating those risks. Part of this process involves periodically conducting a human rights risk analysis to assess potential impact of human rights risks. Following the most recent analysis, it has been assessed that forced labour and child labour are themes (amongst others) that could potentially have a significant negative impact on the value chain.

For example, in order to mitigate the risk of involvement in forced labour and child labour within operations, various processes and activities have been implemented, including:

• Screening relations in advance, in collaboration with CDD Desk. Relations involved in human rights violations are generally excluded.

• Enforcing the Code of Conduct with certain material suppliers as part of the contract documents. The code mandates that human rights, labour rights, environmental standards, and anti-bribery and corruption standards are followed.

• Establishing purchasing conditions that obligate suppliers to comply with all legal regulations, including those related to employee rights and working conditions.

• Setting additional ESG-related conditions in contracts and maintaining a risk-based approach. When potential risks are considered to be higher, such as when investing in solar parks, more extensive due diligence is conducted.

Value chain workers are able to raise concerns by using the Human Rights Reporting Points described earlier under Policies – General. Where processes to prevent or mitigate are not adequate to remediate the negative impacts, Real Estate considers how to provide for or cooperate in remediation on a case-by-case basis taking into consideration the relation of the Real Estate activities and the negative impact.

Actions

According to the human rights policy, a human rights risk assessment must be conducted at least once every three years. This assessment may prompt adjustments to the policy. Policy adjustments may also occur as a result of incidents. Team Sustainability is responsible for the Human Rights Policy and for the periodic human right risk assessment.

Asset Management 11.1

Asset Management also considers its ability to effect change and the leverage that Asset Management holds with companies in these sectors. Engagement on forced labour, particularly in the IT sector, was prioritised due to its prevalence in the value chains of electronics manufacturers, often located in high-risk countries such as China and Malaysia. The complexity of these value chains poses challenges to transparency and standard enforcement.

Where Asset Management encounters insufficient progress with its engagements, the organisation can make use of a number of tools that collectively form the engagement escalation framework. In order of increasing strength, these tools include:

• Voting in support of a.s.r.’s engagements;

• Pre-disclosing a.s.r.’s voting intentions;

• (Co-)filing shareholder resolutions;

• Divesting a.s.r.’s holdings.

There is consensus among investors that it is difficult to measure the effectiveness of engagement. Although engagements sometimes lead to positive outcomes, it is difficult to prove the one-to-one relationship between the engagement efforts and the changes at the companies engaged. Therefore, a.s.r. is unable to quantify the effectiveness of actions taken. 

With regard to the investment portfolio, during its bi-annual screening process Asset Management frequently screens its investment portfolio for very severe and repeated incidents, including human rights violations such as forced and child labour. Screening outcomes are followed up by mitigation measures as described in Asset Management's Policy on Responsible Investments. To inform this screening process, Asset Management uses data from external data suppliers. 

Specific datapoints on severe forced and child labour cases are currently not available at the external data suppliers, and as a consequence, Asset Management cannot currently precisely determine the number of severe incidents of child and forced labour at investee companies. Data quality and availability is however expected to improve in the coming years. Asset Management will continue to engage with data providers on the availability and the quality of human rights related data, including data on forced labour and child labour.

Real Estate 11.1

Real Estate is committed to prevent human rights violations and excludes relations that are involved in human rights violations where possible. If human rights violations are detected, Real Estate considers the violation on a case-by-case basis and generally aims to discontinue the relation when possible. However, Real Estate recognises that ending the relationship with the party involved is not always the best solution to mitigate the impact of the violation.

During 2024, no human rights violations have been reported to Real Estate. There is consensus in the market that it is difficult to measure the effectiveness of preventive and/or mitigating measures taken. Therefore, Real Estate is unable to quantify the effectiveness of actions taken.

6.3.2.3Targets and metrics

Targets

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

As it is difficult to prove the one-to-one relationship between the measures taken by a.s.r., there is currently no target related to forced labour and/or child labour and no metrics will be disclosed. The monitoring of the effectiveness of the measures takes place through the current management reports and will be further optimised going forward.

6.3.2.4Working conditions

Working conditions is not deemed material for a.s.r. but is material for Health. For more information see section 6.1.2 and 6.1.4.5. Healthcare workers often face high work pressure, irregular shifts, and physically and mentally demanding tasks, which can lead to health issues and increased absenteeism. Health is committed to improving these conditions through various initiatives aimed at enhancing job satisfaction and reducing the administrative burden on healthcare providers.

The following table presents a comprehensive overview of the material impact along with the corresponding policies, actions and targets.

Policies

Procurement Policy

In the healthcare sector, joint agreements are in place to mitigate the negative impact on healthcare workers. In the Integrated Care Agreement (Integraal Zorgakkoord - IZA), parties have made agreements regarding the use of non-salaried staff. These agreements are aimed at promoting good employment practices and making salaried employment more attractive, also aimed at reducing the workload for salaried staff.

Health insurers strive to reduce administrative burden and labour-saving care through digitalisation and innovation. Additionally, through the Future-Proof Labour Market Care & Welfare (Toekomstbestendige Arbeidsmarkt Zorg & Welzijn - TAZ) programme, health insurers aim to increase job satisfaction and reduce staff turnover, enhance (sustainable) employability, reduce absenteeism and make salaried employment more attractive. The implementation of the IZA and the TAZ programme is a shared responsibility of several system parties as well as healthcare providers, insurers and care offices. The third party agreements, TAZ and IZA were put together in consultation with all parties in the field under the direction of the Ministry of Health, Welfare and Sport, taking into account the interests of employees working for Dutch healthcare providers. Both agreements are publicly available via the government's internet pages.

The IZA agreements are incorporated into the procurement policies of Health. As a result, employees of contracted healthcare providers are in scope of these policies. The management team of Health is accountable for the implementation of the policy.

Engaging with value chain workers

By offering health insurance, a.s.r. provides its customers with access to healthcare services. However, facilitating the use of these services indirectly impacts the health and safety of healthcare workers. These workers face high work pressure (working time), irregular shifts (work-life balance), inadequate wages, and physically and mentally demanding tasks. This can lead to health issues, causing the workers to eventually take sick leave.

As a result, staff shortages at healthcare providers can reduce access to healthcare services, potentially preventing all insured individuals from receiving the necessary care. This affects access to care see section 6.3.3.2.

Health insurers must balance two interests: keeping healthcare affordable to ensure access to care and striving for good working conditions for employees of care providers. These interests can conflict when improving working conditions leads to higher costs. However, many causes of work pressure or absenteeism do not have a financial origin (i.e. irregular shifts or mentally demanding tasks). These considerations are made at the administrative level and in consultation with the Ministry of Health, Welfare and Sport, the Dutch Healthcare Authority, professional associations, trade associations and trade unions.

Actions

To reduce administrative pressure, health insurers test all new regulations against the principle of 'sensible and radically simple'. Sensible refers to what contributes to affordability, accessibility and quality of care. Radically simply means choosing the simplest possible solutions for professionals that enhance professional autonomy, craftsmanship and job satisfaction, while decreasing administrative burden.

In the context of labour-saving care, health insurers make substantively appropriate agreements in their contracts with care providers about the supply and use of user-friendly hybrid care.

Health insurers strive to improve the labour market. They lobby for national policy to promote the labour market and actively participate in national programmes and consultation structures, such as within general practitioner care in the Action Plan Work Pressure in the evening, night and weekend shifts (Avond Nacht en Weekenddiensten - ANW). Additionally, health insurers set standards via joint purchasing conditions and stimulate the mutual sharing of promising initiatives to bring these initiatives to the attention of healthcare providers.

In addition to this joint effort in the healthcare sector, Health launched its own initiative in 2024: an inspiring gathering for contracted community nursing and home care (Verpleeg-en Verzorgingshuizen en Thuiszorg - VVT) providers about sustainable employability. The VVT sector faces major challenges in terms of personnel. The aim of the gathering was to inspire healthcare providers and provide practical tools to improve job satisfaction and combat absenteeism. About 30 healthcare providers attended the meeting. During the gathering, the theme of sustainable employability was illuminated from different angles by various speakers.

Target

a.s.r. acknowledges that no specific targets have been set regarding working conditions at this time. This matter will be further investigated and evaluated going forward. The aim is to develop appropriate policies and targets in the future to improve and ensure working conditions.