SFDR

The following website disclosures will help you understand our approach to sustainability as part of its business operations.

The purpose of the Sustainable Finance Disclosure Regulation (Regulation EU 2019/2088, “SFDR”) is to strengthen protection for, and improve disclosures to, end investors in respect of the integration of sustainability risks in investment decision-making and advisory processes.

SFDR first came into effect on 10th March 2021 and introduces mandatory reporting requirements for in-scope firms. Whilst Monument Insurance Group Limited (“MIGL” and hereafter referred to as “Monument”) is not subject to SFDR, the disclosures that follow address the SFDR requirements for the relevant in-scope companies within Monument.

As at December 2025, the following companies within Monument were considered to have some SFDR requirements:

• Monument Life Insurance Ireland DAC (“MLIDAC”)
• Monument Assurance Belgium (“MAB”)¹
• Monument Assurance Luxembourg (“MAL)

EU SFDR defines a Sustainability Risk as an environmental, social or governance event or condition that, if it occurs, could cause a negative material impact on the value of the investment.

Article 3

Monument has a Group Sustainability Policy, that has been approved by the appropriate governance committees throughout the Group including but not limited to the Monument Risk and Compliance Committee (“RCC”). This Policy is reviewed at least annually.

The Group Sustainability Policy sets out principles and requirements for the identification, measurement, management, monitoring and reporting of sustainability risks, including Environmental, Social and Governance (“ESG”) considerations. These principles are applied to the Monument Investment Strategy² and Monument’s Group Investment Policy.

Monument’s Group Investment Policy recognises the importance of and incorporates within, the relevant regulatory requirements regarding ESG standards.

Responsibility for investment decisions depends on the nature of the insurance product but we seek to ensure that the financial protection we provide to our customers does not have an unacceptable social or environmental impact. When implementing Monument’s Investment Strategy2 we mitigate this through monitoring and limiting our exposure to assets which are not perceived negatively from an ESG perspective.

For non-linked business³ the Group’s asset management is outsourced and ESG requirements are considered both in the hiring of the Investment managers and established within each mandate. Formal monitoring of positions, compliance with limits and oversight with respect to ESG is undertaken by the appropriate governance committees throughout the Group including but not limited to the Group Investment Committee on a quarterly basis.

Monument does not directly take into consideration the adverse impact of investment decisions on sustainability factors as part of their core investment strategy, but the majority for the traded fixed income portfolios externally managed PAIs (Principal Adverse Impacts) are included within the MSCI ratings that are monitored by the group.

Monument as an insurance consolidator manages a mixture of liabilities and investments, Monument will inherent investments which from the offset are not designed to be Article 7 or Article 9 ESG products. We will not be seeking to become an Article 7 or 8 ESG product provider

With respect to certain unit-linked policies, and portfolio bonds in particular, investment decisions may be taken by the policyholder, and this may be on the basis of advice provided to the policyholder by an independent investment adviser. Where Monument does not control, or has relatively limited control over, the investment decisions, then sustainability risks are best taken into account by the policyholder, on advice from their own investment adviser as appropriate.

Article 4 and Article 6A Products

Monument as outlined above, do not offer ESG financial products. These products fall within the Article 6A –“Uncategorised ESG products”. These product may contain some underlying ESG products but they form less than 10% of the overall product, which indicates we do not intend to be an ESG Firm.

Monument will seek to validate with the relevant asset manager at least annually that the product categorisation has not changed through the standard due diligence process.

Article 5

Monument follows a remuneration policy that complies with its relevant regulatory requirements in Bermuda and in the EU under the Solvency II Regime. There is currently no specific link to sustainability risk in Monument’s Group Remuneration Policy.