• 3-3
  • E1-2

Information disclosed based on Commission Delegated Regulation (EU) 2021/2178 of 6 July 2021 supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council by specifying the content and presentation of information to be disclosed by undertakings subject to Articles 19a or 29a of Directive 2013/34/EU concerning environmentally sustainable economic activities, and specifying the methodology to comply with that disclosure obligation.

The EU taxonomy includes a list of economic activities with significant environmental impacts. For each of the activities identified in the EU Taxonomy, technical screening criteria have been prepared, i.e. conditions that an economic activity must meet to be considered environmentally sustainable.

Non-life insurance and reinsurance activities are defined in the EU Taxonomy as activities that support climate change adaptation* . In order for non-life insurance and reinsurance activities to be considered environmentally sustainable, they must meet the technical screening criteria (set forth in Commission Delegated Regulation (EU) 2021/2139 of 4 June 2021 supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council, together with delegated acts and supplementary regulations) for determining the conditions under which an economic activity qualifies as contributing substantially to climate change adaptation, causing no significant harm to any of the other environmental objectives, and operating in accordance with the principle of minimum safeguards. Pursuant to Article 8 of the EU Taxonomy, every company that is required to publish non-financial information pursuant to Article 19a or 29a of Directive 2013/34/EU of the European Parliament and of the Counci** , zwill be required to include in its non-financial statement or consolidated non-financial statement information on how and to what extent its economic activities relate to economic activity that qualifies as sustainable.

According to Article 10 of Delegated Regulation 2021/2178 of the European Parliament and of the Council*** (“Delegated Act”) stating more precisely Article 8 of the Taxonomy in the context of financial undertakings doing their reporting, they are obligated to present qualitative and quantitative disclosures for PZU and PZU Group in 2024 in respect of 2023.

*Definition of enabling activities according to the EU Taxonomy (Article 16 of Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020) – “An economic activity should qualify as contributing substantially to one or more of the environmental objectives set out in this Regulation where it directly enables other activities to make a substantial contribution to one or more of those objectives. Such enabling activities should not lead to a lock-in of assets that undermine long-term environmental goals, considering the economic lifetime of those assets, and should have a substantial positive environmental impact, on the basis of life-cycle considerations.”

**Directive 2013/34/EU of the European Parliament and of the Council of 26 June 2013 on the annual financial statements, consolidated financial statements and related reports of certain types of undertakings, amending Directive 2006/43/EC of the European Parliament and of the Council and repealing Council Directives 78/660/EEC and 83/349/EEC

*** Commission Delegated Regulation (EU) 2021/2178 of 6 July 2021 supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council by specifying the content and presentation of information to be disclosed by undertakings subject to Articles 19a or 29a of Directive 2013/34/EU concerning environmentally sustainable economic activities, and specifying the methodology to comply with that disclosure obligation

Quantitative disclosures for PZU

PZU  

Substantial contribution to climate change adaptation

 

DNSH (Do No Significant Harm)
Economic activities (1) Absolute premiums, year 2023
(3)
Proportion of premiums, year 2023
(4)
Proportion of premiums, year t -1
(5)
Climate change mitigation (7) Water and marine resources (8) Circular economy (9) Pollution (10) Biodiversity and ecosystems (11) Minimum safeguards
(12)
  PLN % % Y/N Y/N Y/N Y/N Y/N Y/N
A.1. Non-life insurance and reinsurance underwriting Taxonomy-aligned activities (environmentally sustainable) 896,631,293 5.54% N/A Y N/A N/A N/A N/A Y
A.1.1 Of which reinsured 220,508,747 1.36% N/A Y N/A N/A N/A N/A Y
A.1.2 Of which stemming from reinsurance activity 33,436,483 0.21% N/A Y N/A N/A N/A N/A Y
A.1.2.1 Of which reinsured (retrocession) 22,312,791 0.14% N/A Y N/A N/A N/A N/A Y
A.2. Non-life insurance and reinsurance underwriting Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) 7,359,732,527 45.47% N/A  

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

B. Non-life insurance and reinsurance underwriting Taxonomy-non-eligible activities 7,931,134,923  49% N/A
Total (A.1 + A.2 + B) 16,187,498,743 100% N/A

Quantitative disclosures for PZU Group

PZU Substantial contribution to climate change adaptation DNSH (the “do no significant harm” principle)
Economic activities (1) Absolute premiums, year 2023 (3) Proportion of premiums, year 2023 (4) Proportion of premiums, year t -1
(5)
Climate change mitigation (7) Water and marine resources (8) Circular economy (9) Pollution (10) Biodiversity and ecosystems (11) Minimum safeguards (12)
  PLN % % Y/N Y/N Y/N Y/N Y/N Y/N
A.1. Non-life insurance and reinsurance underwriting Taxonomy-aligned activities (environmentally sustainable) 935,783,674 4.72% N/A Y N/A N/A N/A N/A Y
A.1.1 Of which reinsured 248,479,120 1.25% N/A Y N/A N/A N/A N/A Y
A.1.2 Of which stemming from reinsurance activity 0 0.00% N/A Y N/A N/A N/A N/A Y
A.1.2.1 Of which reinsured (retrocession) 0 0.00% N/A Y N/A N/A N/A N/A Y
A.2. Non-life insurance and reinsurance underwriting Taxonomy-eligible but not environmentally sustainable activities (not Taxonomy-aligned activities) 8,971,009,295 45.26% N/A  

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

B. Non-life insurance and reinsurance underwriting Taxonomy-non-eligible activities 9,912,429,209 50.01%  

N/A

Total (A.1 + A.2 + B) 19,819,222,178 100% N/A

Contextual information in support of the quantitative indicators including the scope of assets and activities covered by the KPIs, information on data sources and limitation, and explanations of the nature and objectives of Taxonomyaligned economic activities and the evolution of the Taxonomyaligned economic activities over time, starting from the second year of implementation, distinguishing between business-related and methodological and data-related elements

Indicators pertaining to insurance activity

According to the requirements set forth in the Delegated Act, the second group of indicators for insurance undertakings should specify what proportion of overall activity in the scope of insurance other than life insurance is activity in the scope of insurance other than life insurance related to adaptation to climate change, run in accordance with the conditions specified in Delegated Regulation 2021/2139.

In order to determine the proportion of Taxonomyaligned activities and to calculate the ratios in a way that provides full information, the PZU Group prepared a methodology based on the Delegated Regulation and conducted a review of all insurance products belonging to the non-life insurance product lines (Group II) indicated in the Delegated Regulation. Based on the review, those that provide insurance cover for the occurrence of climate-related risks listed in Appendix A to Annex II to the Delegated Regulation were singled out. Analysis was then carried out for these products in accordance with the technical screening criteria for insurance activities. Products aligned with the EU Taxonomy were considered to be those that meet all the required criteria.

As required by the Delegated Regulation, insurance companies are using state-of-the-art techniques to model climate risks.

In PZU, climate risks and extreme climatic events are analyzed under the calculations covered by the standard formula (flood, hurricane), as well as under ORSA (flood, fire for the largest exposures in forested areas including agricultural fields). Under ORSA, PZU SA conducts stress tests, as well as sensitivity analyses that include stress scenarios based on four NGFS scenarios. The mandatory ORSA projections also consider the impact of climate risks on PZU SA’s solvency position in the short-term 3-year perspective (a perspective consistent with business planning).

In addition, PZU has an advanced flooding risk model that was developed in cooperation with the IMGW. The model uses hydraulic modeling to propagate water surges across Poland. PZU applies this model to its insurance activities related to the taxonomy products it offers. The flooding risk model is used in business processes in particular in the underwriting process for corporate clients, as well as in the pricing process for consumers and small and medium-sized enterprises for insurance in the line of fire and other property damage and supporting risk transfer solutions within the meaning of the EU Taxonomy.

According to the requirements of the Delegated Regulation, in the scope of products that are related to climate risks, the insurance companies have to:

  • analyze clients’ interest in protection from climate risks and address them accordingly in product offerings;
  • apply preferential pricing terms for clients that encourage them to reduce or prevent the effects of climate risks. Such incentives can be, for example, discounts for certain client activities;
  • inform clients of the possible benefits of reducing or preventing the effects of climate risks; • educate clients on actions they could take to mitigate or prevent climate risks.

In PZU, products in the following lines were considered to be aligned with the EU Taxonomy:

  • 7 – Insurance against fire and other property losses;
  • 11 – Assistance insurance.

Insurance against fire and other property losses for businesses and consumers protect against climate risks. Under their terms, corporate and clients and SMEs can get a discount for fire protections, and SME clients and consumers can also get a discount for flood protections. In the case of corporate insurance, an individual risk assessment is made, in which all factors are taken into account, including any adaptive and preventive measures. For SME client and consumer insurance, discounts are included in the product’s tariff design. In all of the aforementioned types of insurance, clients in the sales and service process receive compendia or information with advice on how to get insurance against climate risks and their impact on the price or insurance cover. Compendia are also published at www.pzu.pl under the product tabs and the sustainability tab. These types of insurance are also accompanied by the possibility of purchasing additional risk transfer insurance as defined by the EU Taxonomy. For example, clients who choose to use PZU Dom can also extend insurance cover to, for example, the garage and other non-residential buildings in the event that the fire brigade floods the building during firefighting, and for home assistance such as hotel stays in the event of a fortuitous event, including those related to climate risks. For all of the products described above, PZU explores client interest in climate risk protection during the product development and sales process.

There is a declaration on the PZU website regarding the sharing of data with public administrations, as required by the EU Taxonomy https://www.pzu.pl/grupa-pzu/zrownowazony-rozwoj/taksonomia-ue.

In accordance with the requirements of the EU Taxonomy, PZU reports that it has a procedure for handling large-scale claims. “Crisis management procedure in claims handling” applies to mass property damage resulting from, among other things: flooding, hurricane, flood, heavy rain, hail, snow, lightning surge, effects of winterkill, drought and earthquake.

This procedure provides additional resources for largescale incidents to ensure a high level of claims handling in terms of quality and timeliness. This procedure applies to all taxonomic products and complements the high standards of claims handling.

In accordance with the requirements of the EU Taxonomy, the principle of “Do No Significant Harm” is included in the premium calculation. Client activities related to the “extraction, storage, transportation or production of fossil fuels” and the insurance of “vehicles, property or other assets for such purposes” were identified on the basis of the Polish Classification of Business Activity (PKD), and in a few cases at the contract level. Insurance against such activities is excluded from the calculation of taxonomic indicators.

PZU calculates insurance taxonomic indicators only on the basis of products that meet all the requirements of the EU Taxonomy, taking into account exclusions related to the “Do No Significant Harm” principle. According to the European Commission’s publication of a preliminary interpretation regarding the implementation of Article 8 of the EU Taxonomy in the context of the disclosures required by the Disclosure Delegated Act, dated 21 December 2023, only the portion of the premium that covers climate risks was included in the calculation. This portion was estimated for each taxonomic product based on the share of damages that result from climate risks in all damages over the past 10 years.

Taxonomy analysis of reinsurance activities was limited to intragroup activities. PZU does not have relevant data for non-group activities.

The PZU Group’s potentially taxonomic activities are mainly reinsured against fire and other property damage. In addition, close cooperation between the insurer and reinsurer on climate risk modeling ensures that risk modeling and product requirements are met. The intragroup activities assume that reinsurance of premium from products that meet all the requirements of the EU Taxonomy is also the basis for meeting the product criteria of the EU Taxonomy for reinsurance. The data sharing declaration published on PZU’s website also includes data on its reinsurance activities. PZU also confirms the handling of claims in reinsurance in accordance with the requirements of the EU Taxonomy.

To depict the picture of the PZU Group as fully as possible in accordance with the Taxonomy, the indicators were calculated in two approaches: the standalone approach for PZU and the consolidated approach for the entire PZU Group, i.e. for all PZU Group companies that do business in non-life insurance: PZU, LINK4, TUW PZUW, Lietuvos Draudimas, PZU Branch in Estonia, AAS Balta and PrJSC IC PZU Ukraine. In both cases gross written premium is understood to refer to direct and indirect business. The calculations take into account the principles of consolidation, particularly exclusions between Group companies.

PZU has prepared guidelines for interpreting the EU Taxonomy for insurance, reinsurance, investment activities and meeting the principle of minimum safeguards. In 2023, TUW PZUW met all the requirements of the EU Taxonomy and was included in the consolidated Taxonomy-aligned activities indicator for the PZU Group. TUW PZUW meets the criteria for risk modeling according to the Taxonomy, products and client communication, as well as claims handling. TUW PZUW also has a special procedure for handling claims on a massive scale and has declared data sharing. TUW PZUW also meets the principle of minimum safeguards by, among other things, implementing a human rights due diligence process.

  • E1-4

Description of compliance with Regulation (EU) 2020/852 (“Taxonomy”) in a financial company’s business strategy, product design processes and cooperation with clients and business partners

The PZU Group Strategy in 2021-2024 “Potential and Growth” incorporates sustainable development factors indicating that the measure of the PZU Group’s success is embodied not just by its financial performance but above all by generating that performance in a sustainable manner.

PZU SA and PZU Życie SA also adopted the ESG Strategy “Balanced Growth” in 2021-2024 defining the approach to management, expected performance and the future prospects in a manner that reflects the financial, social, environmental and managerial context in PZU’s business.

The PZU Group’s ambitions related to sustainable development have been specified in three pillars directly relating to the three ESG factors:

#Trusted Partner in green transformation (E)
#Better quality of life (S)
#Responsible organization (G)

One of the benefits ensuing from adopting both strategies is the ability to prepare PZU effectively to implement new legal regulations pertaining to ESG, including the EU Taxonomy. The EU taxonomy was directly cited in the ESG Strategy “Balanced Growth as one of the regulatory components pertaining to sustainable development on which the activities of both companies will be predicated. The strategies did not describe the objectives referring directly to the Taxonomy; however, the Taxonomy was noted as the regulatory basis for the further operation of the companies.

The PZU Group places great emphasis on reducing the adverse impact exerted by its business activity on the climate and environment and is also striving to anticipate the impact of climate change on its business. It supports the sustainable transition of the economy relying on business analyses, domestic and international legal regulations and the guidelines of institutions such as the UN, EU and the Organization for Economic Cooperation and Development.

Discharging the obligations stemming from the Taxonomy is rooted in the first – environmental pillar of the ESG Strategy: #Trusted Partner in green transformation. PZU Group appreciates that it is necessary to switch to a low emission economy to stop climate change.

  • product area (PZU Group developing an insurance offer supporting energy and climate transition);
  • investment area (responsible investor supporting sustainable transition);
  • operating activity (green organization operating on the basis of sustainable decision-making and governance processes).

PZU relies on product solutions taking into consideration evolving environmental needs. The PZU Group appreciates that it is necessary to switch to a low emission economy to stop climate change. That is why businesses investing in renewable energy sources can utilize products and services that will support decarbonization: among others, low emission transport, environmentally-friendly photovoltaic installations, heat pumps, small and large wind farms. When designing products, PZU considers ESG elements resulting from amendments to the Insurance Distribution Directive or the EU Taxonomy.

Sustainable development issues are also important in relations with the PZU Group’s clients and have been defined in the business strategy. The PZU Group supports environmental protection initiatives. It also wants to support entities that are undergoing an energy transition by taking the following into account:

  • financial market participants – the PZU Group is extending the offering of mutual funds to include ESG factors, it is also developing a long-term strategy to develop its sustainable portfolio and it is consistently expanding its investments in the green sectors;
  • retail clients – the PZU Group is developing its sustainable insurance offer customized to their individual needs;
  • corporate clients – the PZU Group supports entities undertaking measures conducive to sustainable energy transition and conducts ESG assessments of key corporate clients;
  • non-governmental organizations – the PZU Group wants to be a partner in social, economic and climate activities.