The percentage of European institutional investors planning to increase their allocations to ESG products over the next two years. (source: PWC)
The proportion of European financial services institutions reporting on gender balance across the workforce. (source: EY)
Projected ESG European Assets under Management (AuM) by 2026. (source: PWC)
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Empowering individuals and families to forge lasting legacies is our ongoing commitment to sustainability
84%
60%
$25.7
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10%
The amount by which regulatory and compliance costs have increased due to ESG. (source: PWC)
Our approach to ESG & responsibilities
Citizenship
Strategic areas of focus and SDG alignment
Sustainability
Our sustainability journey
Lombard International Assurance is committed to make sustainable investment options available to policyholders in order to allow for opportunities which correspond to the policyholder’s ESG preference. Discover how.
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Our commitment in practice: case studies
Environment
Social
Governance
©2023 Lombard International Group
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Lombard International Group 58 Grosvenor Street London, W1K 3JB United Kingdom Tel: +44 20 3928 7759
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EXPLORE HOME 1. THE GLOBAL WEALTH LANDSCAPE AND ESG 2. OUR APPROACH TO ESG 3. OUR SUSTAINABILITY JOURNEY 4. OUR COMMITMENT IN PRACTICE
THE GLOBAL WEALTH LANDSCAPE AND ESG
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CONTACT
OUR ESG APPROACH
Investment mandate and external fund selection
Investment exclusions
The heightened focus on sustainability is truly encouraging HNW individuals and family to re-examine where their wealth is being invested, reconsider the ‘purpose’ of their wealth and align their assets with their non-financial goals and aspirations.
We Make Legacy Count
Sitting at the heart of ESG stewardship
Here is a selection of recent findings on ESG and sustainability, relevant to our sector. These figures are regularly updated and come from highly regarded surveys and reports in the wealth management industry.
It is our collective responsibility to ensure that we achieve and meet our corporate ambitions with responsibility and accountability. As part of this push, we are integrating ESG principles into our business operations, services, and products. Discover how.
Learn more on how we put ESG principles in motion at Lombard International Group.
1. THE GLOBAL WEALTH LANDSCAPE AND ESG
2. OUR APPROACH TO ESG
3. OUR SUSTAINABILITY JOURNEY
4. OUR COMMITMENT IN PRACTICE
5. NEWSROOM
LEGAL About this report Legal disclaimer Cookie Policy Privacy notice ESG: SFDR disclosures
trn
Projected ESG European Assets under Management (AuM) by 2026. (source: PWC Asset and wealth management revolution)
The percentage of European institutional investors planning to increase their allocations to ESG products over the next two years. (source: PWC Asset and wealth management revolution)
21.5%
The percentage of total global AuM expected to be invested in ESG assets in less than 5 years. (source: PWC)
40%
The satisfaction rate among European Wealth clients when it comes to sustainable investments (ESG). (source: EY Global Wealth Research Report)
The proportion of European financial services institutions reporting on gender balance across the workforce. (source: EY Sustainable Index 2022)
The proportion of institutions in Europe and the Asia-Pacific region that offer green products, compared to only 20% in North America. (source: EY Sustainability Index 2022)
70%
The percentage of European financial services institutions that have linked executive members’ compensation to sustainability targets, compared to only three in 10 in North America and the Asia-Pacific region. (source: EY Sustainability Index 2022)
The reduction in emissions needed every year in order to reach net zero by 2050. (source: UN)
7.6%
94%
The percentage of Europeans who say that protecting the environment is important to them personally. (source: Attitudes of Europeans towards the environment, 2020)
The global wealth landscape and ESG
In 2021, 80% of financial services institutions had a policy on up-skilling and re-skilling employees, up from 62% in 2018. (source: EY Sustainability Index 2022)
80%
Private wealth has a positive impact on the world in which we live. Here are some recent highlights and findings from the Wealth Management industry.
CITIZENSHIP
OUR APPROACH TO ESG
We believe in making a meaningful difference today to safeguard a sustainable future for the economy, environment, and society of tomorrow.
Strongly connected to our values, corporate citizenship is our approach to having a positive impact in the communities in which we work and operate. We are motivated by the footprint we leave behind and believe in making our corporate legacy count. Our measure of success is to see long-term value in our philanthropic partnerships and projects. Our donations, charitable partnerships and volunteering initiatives address key environmental and social issues aligned with the UN’s Sustainable Development Goals (SDG), whilst maximising colleague engagement, our impact, and community prosperity. We develop charitable partnerships and citizenship programming that go beyond simply committing to financial donations. Our approach includes inspiring and mobilising colleagues, providing community giving and engagement opportunities and leveraging appropriate business capabilities, including technology, tools, or skill-based volunteerism. We engage and encourage our colleagues to be catalysts of change to build relationships across the firm, boost our organisational culture and reinforce our SPIRIT values.
1. EDUCATION
Strategic areas of focus and alignment with the UN's Sustainable Development Goals (SDG)
Ensuring quality and inclusive education for all and promoting lifelong learning.
2. Environment
Achieving economic growth and sustainable development by reducing our ecological footprint by changing the way we produce and consume goods and resources.
Protecting, restoring and promoting sustainable use of terrestrial ecosystems, sustainably managing forests, combating desertification, and halting and reversing land degradation and halting biodiversity loss.
3. Diversity & Inclusion
Achieving gender equality and empowering all women and girls.
Empower and promote the social, economic and political inclusion of all irrespective of age, sex, sexual orientation, disability, race, ethnicity, origin, religion or economic or other status.
We aim to help our clients to navigate their desired level of ESG integration
As a leading provider of cross-border wealth, estate, and succession planning solutions, we are in a privileged leadership position to use our geographically diverse breadth, expertise, and experience to be a source for good and support our clients and partners in investing their wealth ethically and sustainably. We work in tandem with our clients’ trusted advisors and asset managers with the objective of providing HNW individuals, families or institutions with wealth planning solutions that can enable efficient, sustainable, and diversified investment portfolios, which over the long term can have relevant ESG-related principles clearly defined, measured, and reported. We aim to help our partners to support their clients in navigating their desired level of ESG integration, developing customised Lombard International Group solutions that meet their non-financial goals and aspirations. We think long term and are geared towards delivering against our growth objectives in a sustainable manner.
Funding emergency social and/or environmental relief projects beyond our strategic areas of focus.
As a leading provider of cross-border wealth, estate, and succession planning solutions, we are in a privileged leadership position to use our geographically diverse breadth, expertise, and experience to be a source for good and support our clients and partners in investing their wealth ethically and sustainably. We work in tandem with our clients’ trusted advisors and asset managers with the objective of providing HNW individuals, families or institutions with wealth planning solutions that can enable efficient, sustainable, and diversified investment portfolios, which over the long term can have relevant ESG-related principles clearly defined, measured, and reported. We aim to help our clients to navigate our partners to support their clients in navigating their desired level of ESG integration, developing customised solutions that meet their non-financial goals and aspirations. We think long term and are geared towards delivering against our growth objectives in a sustainable manner.
Discretionary Donation
Discretionary Donations
We are committed to incorporating ESG factors into our strategy and operations in order to contribute towards implementing the UN 2030 Agenda for Sustainable Development.
Most products designed by Lombard International Assurance, the Luxembourg-headquartered insurance carrier of Lombard International Group, offer a high degree of investment flexibility. Policyholders can integrate their ESG priorities into the investment options linked to their policy. Lombard International Assurance is committed to make sustainable investment options available to policyholders in order to allow for opportunities which correspond to the policyholder’s ESG preference. While our commitment spans our internationally diverse footprint, we are mindful that the specific requirements, customs and regulations of the many jurisdictions where we operate require a flexible approach to implementation. Approaches which allow for the creation of efficient, diversified and sustainable investment portfolios may therefore vary over time and depending on the markets we serve.
Although not involved in the asset selection process, Lombard International Assurance (as legal owner of the underlying assets held within the life policies issued by the Company) has published its ESG Investment Guidelines and related Investment Exclusion List in 2022. In April 2023, Lombard International Assurance has refined the scope of its ESG Investment Exclusion List which no longer applies to discretionary managed Internal Dedicated Funds (IDFs) and Specialised Insurance Funds (SAFs).
Investment exclusions in Europe
All appointed investment managers of Internal Collective Funds (ICFs) must however comply with the exclusion list. Financial instruments issued by issuers violating the UN Global Compact Principles or having involvement into Controversial Weapons are excluded from the investment universe of ICFs. Additionally, ICFs may not invest into investment funds with an investment share of more than 10% in issuers with Controversial Weapons involvement. The UN Global Compact defines 10 principles that include positions on human rights, labour, environment and anti-corruption. The values represented through these principles are shared by Lombard International Group. External investment funds included in the fund lists we make available to policyholders for selection must not have an investment share of more than 10% in issuers with Controversial Weapons involvement.
OUR SUSTAINABILITY JOURNEY
Although not involved in the asset selection process, the Luxembourg and Guernsey based entities of Lombard International Group (as legal owner of the underlying assets held within the life policies issued by these entities) have published an Investment Exclusion List. Lombard International has requested that all appointed investment managers and self-managing policyholders respect this exclusion list. The Investment Exclusion List contains issuers violating the UN Global Compact Principles or having controversial weapons involvement. The UN Global Compact defines 10 principles that include positions on human rights, labour, environment and anti-corruption. The values represented through these principles are shared by Lombard International Group. By the end of the second quarter 2022, we will seek to avoid accepting any new investments into financial instruments issued by issuers contained on the Exclusion List. Additionally, we will seek to avoid accepting any investment funds with assets under management above 10% in issuers with controversial weapons involvement. With positions which were purchased prior to 30 June 2022, we will encourage these to be sold by the appointed investment managers or self-managing clients by 30 September 2023. The issuer and investment fund information contained in our Exclusion List is provided by a leading ESG data provider.
Partnering with a leading provider of investment fund data, we are proactively looking at providing sustainability information on external investment funds included in the fund lists we make available, allowing policyholders and their advisers to choose among those options that best match their financial goals and sustainability preferences. Policyholders for whom appointed discretionary asset managers manage an account linked to their policy are invited to express their ESG priorities as part of their investment strategy and according to their investment profile. Policyholders can choose between a standardised or customised investment strategies to meet their ESG preferences.
We firmly believe that by working to protect the planet today, we can pass on a more sustainable, healthier, and greener tomorrow. By practicing recycling and waste management, encouraging and supporting our employees in adopting greener behaviours, and by supporting conservation projects that preserve and restore habitats, we are making our actions count.
Since 2015, the Luxembourg office has been fully powered by 100% renewable energy, produced by hydro-electric power, as certified by Enovos, the Luxembourgish energy provider. The car sharing pool in our Luxembourg office is also fully electric. The Luxembourg office building has been certified ‘very good’ by BREEAM, the world’s leading sustainability assessment method and its ‘Energy Passport Certificate’ was awarded ‘very good’ by Luxembourgish Authorities.
Case study: On the road to carbon neutrality
case studies
Lombard International Group entities, including the distribution entities in Paris, London and Munich, as well as Lombard International Assurance’s head office in Luxembourg and Lombard International Assurance’s branch offices in Brussels and Milan, are continuously striving to reduce their energy consumption. In 2022, we have reduced the number of neon lights in use at our Luxembourg office building by 50%. Since 2019, which we take as a pre-Covid reference year, our Green House Gas (GHG) emissions (scope 1 & 2) have been reduced by -48.7% (based on contract values) passing from 758 MTCO2e to 389 MTCO2e. This represents a -56.5% reduction in MTCO2 net emissions per employee. Although our hot water and heating system consumption has increased by +21.87% since 2019 due to a higher number of employees in our offices and to climate variations, our overall energy consumption has decreased by -5.77%. This also includes the energy consumption from outsourced data centres. Looking at our electricity consumption alone, our GHG footprint (scope 1 & 2) has been reduced by -79.72% since 2019. As we continue to invest in technology and video conferencing systems, we encourage our employees to reduce the number of business trips. Since 2019, we have seen a 40% reduction in our flight kilometres.
As part of its annual flagship event in France, Lombard International Group launched a new concept in 2022 called “La Collab”, where we invited our key partners to an exclusive charity event. For this inaugural edition, we were honoured to hear from Olivier Goy, a well-known French entrepreneur and amateur photographer, who is affected by Amyotrophic Lateral Sclerosis (ALS / Maladie de Charcot). Olivier Goy spoke of his disability and advocated for better understanding and recognition of the realities of this disease. Lombard International Group organised a private auction with a selection of 5 photographs by Olivier Goy, which raised over €10,000 for the Brain Institute (Institut du Cerveau) in Paris, which is very active in advancing research into ALS.
People are the definitive key to our success and only together we can truly make legacy count. This is why we believe in mutual growth and are committed to investing in our employees as well as our communities.
Case study: Institut du Cerveau
Lombard International Group entities operate under a comprehensive and solid corporate governance structure which defines responsibilities, risk appetite and ensures independent oversight and control.
Case study: Supply chain oversight and requirements
To better understand our key suppliers’ approach to ESG and ensure that our respective agendas are aligned, we launched a specific online questionnaire in September 2022, aimed at capturing key information on where each stand with regards to ESG integration into their own businesses. Consisting of 15 questions, the questionnaire initially focused on our top 20 suppliers, who represent c. 60% of our supply chain total cost volume. With a 90% completion rate, key findings from the survey evidenced that: > 63% of respondents said they publish an annual ESG report. > 100% of respondents said they have policies and procedures in place to comply with applicable privacy laws, including the EU Global Data Protection Regulation (“GDPR”) and data security requirements. > 84% of respondents said their company have at least one senior-level employee responsible for ESG/CSR > 84% of respondents said their company has formalized specific targets related to its environmental impact. > 84% of respondents said their company have a written Diversity & Inclusion policy > 100% of respondents said their company requires its significant partners to comply with applicable anti-corruption, labour, human rights, environmental and/or health and safety laws or policies. Our outsourcing providers are subject to the same duties that are applicable to our business regarding the security and the confidentiality of our client’s information and data.
OUR COMMITMENT IN PRACTICE
Since 2015, the Luxembourg office has been fully powered by 100% renewable energy, produced by hydro-electric power, as certified by Enovos, the Luxembourgish energy provider. The car sharing pool in our Luxembourg office is also fully electric. The Luxembourg office building has been certified ‘very good’ by BREEAM, the world’s leading sustainability assessment method and its ‘Energy Passport Certificate’ was awarded ‘very good’ by Luxembourgish Authorities. As part of the IMS 0% Plastics Pledge that we signed, we are working towards reducing single-use plastics in the office. In-house catering facilities stopped the use of plastic cutlery and we have reduced plastic consumption in office supplies (binders, pencils, etc.) by more than half since 2019. Lombard International Group entities, including the distribution entities in Paris, London and Munich, as well as Lombard International Assurance’s head office in Luxembourg and Lombard International Assurance’s branch offices in Brussels and Milan, are continuously striving to reduce their energy consumption. In 2022, we have reduced the number of neon lights in use at our Luxembourg office building by 50%. Since 2019, which we take as a pre-Covid reference year, our Green House Gas (GHG) emissions (scope 1 & 2) have been reduced by -48.7% (based on contract values) passing from 758 MTCO2e to 389 MTCO2e. This represents a -56.5% reduction in MTCO2 net emissions per employee. Although our hot water and heating system consumption has increased by +21.87% since 2019 due to a higher number of employees in our offices and to climate variations, our overall energy consumption has decreased by -5.77%. This also includes the energy consumption from outsourced data centres. Looking at our electricity consumption alone, our GHG footprint (scope 1 & 2) has been reduced by -79.72% since 2019. As we continue to invest in technology and video conferencing systems, we encourage our employees to reduce the number of business trips. Since 2019, we have seen a 40% reduction in our flight kilometres.
63% of respondents said they publish an annual ESG report. 100% of respondents said they have policies and procedures in place to comply with applicable privacy laws, including the EU Global Data Protection Regulation (“GDPR”) and data security requirements. 84% of respondents said their company have at least one senior-level employee responsible for ESG/CSR 84% of respondents said their company has formalized specific targets related to its environmental impact. 84% of respondents said their company have a written Diversity & Inclusion policy 100% of respondents said their company requires its significant partners to comply with applicable anti-corruption, labour, human rights, environmental and/or health and safety laws or policies.
Our outsourcing providers are subject to the same duties that are applicable to our business regarding the security and the confidentiality of our client’s information and data.
As part of the IMS 0% Plastics Pledge that we signed, we are working towards reducing single-use plastics in the office. In-house catering facilities stopped the use of plastic cutlery and we have reduced plastic consumption in office supplies (binders, pencils, etc.) by more than half since 2019.
Newsroom
NEWSROOM
Lombard International Assurance supports Stëmm vun der Strooss in their Caddy 2. project
Lombard International partners with reforestation non-profit One Tree Planted to plant 10,000 trees
03 February 2022
14 December 2021
10 November 2021
Parallels in purpose bind growth of ESG and Wealth Assurance solutions
Lombard International Group plants 550 trees in commemoration of the company’s 30-year anniversary
05 November 2021
20 July 2021
The Wealth Assurance sector must seize the opportunity to sit at the heart of ESG stewardship
06 August 2021
Lombard International Group reaffirms its support to Médecins Sans Frontières (MSF)
ESG at Lombard International Group, Episode 2 with Andreas Meier, CIO Europe
09 June 2021
05 July 2021
ESG at Lombard International Group, Episode 3 with Maria Cristina Boscolo Berto, Director
21 June 2021
ESG at Lombard International Group, Episode 4 with Filippo Mancini, Wealth Planner
NEWS
VIDEOS
19 May 2021
Lombard International Group launches its Inclusion Action Pledge on Luxembourg Diversity Day
ESG at Lombard International Group, Episode 1 with Stuart Parkinson, Group CEO
28 May 2021
21 February 2022
Our Citizenship Footprint
13 July 2021
Grand Dossier Paperjam (in French) Pour faciliter l’investissement ESG with Florent Albert, Managing Director Europe & Group CFO
EXPLORE HOME 1. THE GLOBAL WEALTH LANDSCAPE AND ESG 2. OUR APPROACH TO ESG 3. OUR SUSTAINABILITY JOURNEY 4. OUR COMMITMENT IN PRACTICE 5. NEWSROOM
©2022 Lombard International Group
Legal disclaimer
The content of this website is intended solely to provide general guidance to the reader of these pages on the services offered by Lombard International Group. The information contained within these pages is not intended as an offer to sell or solicitation for the purchase or sale of any life assurance product. Neither is the information intended to constitute any form of legal, fiscal or investment advice or recommendation and it should therefore be used only in conjunction with appropriate professional advice obtained from a suitable qualified professional source. Lombard International Group does not warrant, represent or guarantee that the information contained within these pages is complete, accurate or up-to-date. Lombard International Group expressly disclaims all liability to any person in respect of anything, or the consequences of anything, done or omitted to be done wholly or partly in reliance upon the whole or any part of the contents of the Lombard International Group website. On this website you may be offered automatic links to other websites. Following such links to off-site web pages is entirely at the risk of the user. Lombard International Group does not endorse or accept any responsibility for off-site web page content, nor the products or services offered through them. Access to off-site web pages is entirely at the risk of the person accessing such information. Lombard International Group does not represent or warrant that that access to off-site web pages will be uninterrupted, that there will be no delays, failures, errors or omissions or loss of transmitted information, that no viruses or other contaminating or destructive properties will be transmitted or that no damage will occur to your computer system. The information, material and content provided in these pages may be changed at any time without notice. The Lombard International Group website is not intended for any person in any jurisdiction where, by reason of that person’s nationality, residence or otherwise, the publication or availability of the Lombard International Group website is prohibited. When registering, you declare accepting that your personal data obtained by Lombard International Group can be used for marketing and prospecting needs. You can ask for this information to be communicated to you and to be corrected, if necessary, by applying in writing to Lombard International Group. The laws on intellectual property are applicable to the content of this website. It is strictly prohibited to copy, transfer, distribute, modify or register all or part of the content, illustration, layout, look and feel, logos and trademark of this website, in whatever form. All rights are reserved. The information supplied on these pages is subject to the laws of the Grand Duchy of Luxembourg.
LEGAL About this report Legal disclaimer Cookie Policy Privacy NOTICE ESG: SFDR disclosures
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Privacy NOTICE
At Lombard International Group, we take personal data protection seriously and we are dedicated to protecting the confidentiality and privacy of information entrusted to us. This Privacy Notice provides information on the processing of personal data by Lombard International Group with its offices at 4, rue Lou Hemmer, L-1748 Luxembourg, Grand Duchy of Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B37604. At Lombard International Group, we collect such Personal data mainly by requesting it directly from the persons whose personal data we process. In some limited circumstances, personal data may come from others sources, mainly in the case of anti-money laundering research. Personal data includes any information by which you may be directly or indirectly identified which may be held on paper, electronically or otherwise. This Privacy Notice sets out:
- To whom this Privacy Notice applies
This Privacy Notice is applicable to the processing of all personal data of our customers and other persons interested in our products, our suppliers, service providers and professional partners (e.g. intermediaries, banks and investment managers), and prospects.
To whom does this privacy notice apply?
Lombard International Group may collect and process your personal data (including but not limited to the following categories of data: identification data, contact details, medical and health data, professional data, financial and tax information, health information, AML (Anti-Money Laundering) and CTF (Counter-Terrorist Financing) related data, voice recordings, computer device data such as IP address and logon details) for the following purposes:
For which purposes do we process your personal data?
- The processing is necessary in view of entering into or for the performance of a contract (e.g. insurance policy, service agreement); - The processing is necessary for compliance with a legal obligation (e.g. disclosure to government institutions or supervisory authorities, AML/CTF checks); - The processing is necessary for the purpose of the legitimate interests of the company (e.g. call recording to limit corporate liability when clarifying instructions over the phone). - The processing is necessary to respond to your query(ies) submitted via our website contact form, email or any other means.
We may ask for your written consent before processing your personal data for a purpose other than those listed above. If you have given your consent for the processing of your personal data, you have the right to withdraw this consent at any time, without affecting the lawfulness of the processing based on consent before withdrawal. We will not use your personal data for direct marketing purposes without your explicit prior consent. If, at any time, you decide not to receive any commercial or promotional information from us, you may, without having to provide any justification, opt-out of any direct marketing campaigns and oppose to the future processing of your personal data for such purposes by sending an email to the attention of our Marketing and Communication departments at communications-eu@lombardinternational.com.
Your personal data can be retained for different periods of time, depending on the purposes of the processing and category of personal data, however it will always be retained in compliance with the applicable laws and/or regulations.
How long will we keep your personal data?
1.1 Access to your personal data by our employees Your personal data is available on a need to know basis within Lombard International Group, and can only be accessed by the employees of the relevant internal departments to the extent necessary to fulfil their respective tasks and responsibilities. Our employees process your personal data in accordance with our policies and procedures to ensure an adequate level of security. 1.2 Access to your personal data by third parties Depending on the purpose for the processing of your personal data, third parties may have access to your personal data when this is necessary for the provisioning of their products or services to Lombard International Group These third parties may be other group companies, banks, insurance companies, head-hunters/recruitment agencies, IT suppliers, service suppliers, financial, tax or legal advisors, auditors, IT forensic experts, partners or a regulatory or government body. If your personal data is transferred to a recipient in a country that does not provide an adequate level of protection of personal data, Lombard International Group will transfer your personal data in compliance with the applicable laws (including Luxembourg professional secrecy law), as well as on the basis of appropriate and suitable safeguards such as EU Standard Contractual Clauses with these third parties. 1.3 Sub-processing of your Personal Data Lombard International Group may use external providers (data processors) to process your personal data on its behalf. Lombard International Assurance S.A. shall only use processors providing sufficient guarantees to implement appropriate technical and organisational measures in such a manner that processing will meet the requirements of the General Data Protection Regulation and ensure the protection of your privacy. As data controller, Lombard International Group will ensure that processors act under its authority and only process personal data insofar as strictly necessary for the performance of the services contracted.
Who has access to your personal data?
Protecting your privacy is very important to us. Lombard International Group has taken adequate safeguards to ensure the confidentiality and security of your personal data by implementing appropriate technical, physical and organisational measures to protect personal data against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorised disclosure or access, and against all other forms of unlawful processing (including, but not limited to unnecessary collection) or further processing. Lombard International Group is ISO/IEC 27001 certified.
How do we secure your personal data?
You have certain rights regarding your personal data. You may exercise your right to request access to or rectification of and, as the case may be, erasure of any Personal Data relating to you, or to object to processing, or restriction of processing, as well as your right to data portability, in compliance with applicable data protection law, by sending a signed request form with a copy of your ID card, passport or other proof of identity to the attention of our Data Protection Officer (whose details are mentioned below).
How can you exercise your rights?
If you have any questions related to your personal data or you have concerns regarding the way in which your personal data is processed by Lombard International Group, please contact our Data Protection Officer at dataprivacy@lombardinternational.com or by post at the address of the company. You can find more information about the privacy legislation on the website of the Luxembourgish Data Protection Authority (CNPD) at www.cnpd.public.lu. We are committed to working with you to obtain a fair resolution of any concern about privacy. If, however, you believe that we do not comply with the applicable privacy rules, you have the right to lodge a complaint with the Luxembourg supervisory authority, the Commission Nationale de la Protection des Données, using the form available on the website: https://cnpd.public.lu/en/particuliers/faire-valoir/formulaire-plainte.html; or any other competent EEA data protection authority.
Who can you contact?
- The purposes for which we may process your personal data
- How long we will keep your personal data
- Who has access to your personal data
- How can you exercise your rights
- How we protect your personal data
- How you can contact us
ESG: SFDR disclosures
Disclosure of information about policies on the integration of sustainability risks in investment decision-making process and investment advice (Article 3)
The Environmental, Social and Governance Policy (the “ESG Policy”) of Lombard International Assurance S.A. (the “Company”) defines the Company's sustainability principles and targets. Lombard International Assurance S.A. is committed to contribute towards implementing the UN 2030 Agenda for Sustainable Development and in particular, comply with the EU implementation measures on Sustainable Development. For this purpose, the Company has rolled-out and implemented a number of initiatives which e.g. protect our environment, reduce inequalities or support health of employees over the last years. A strong governance structure is protecting the interests of the Company's clients, employees and stakeholders and helps the Company to implement its sustainability strategy. As Lombard International Assurance S.A. is not managing assets the Company's ESG Policy does not define how sustainability risks are integrated in the investment decision-making process. Where Lombard International Assurance S.A. is acting as Insurance Distributor it does not consider sustainability risks in its advice and for this reason the Company's ESG policy does not define how sustainability risks are integrated in insurance or investment advice.
Disclosure on due-diligence policies with respect to principal adverse impacts of investment decisions on sustainability factors OR where adverse impacts are not considered, explanation why this is not the case (Article 4)
Lombard International Assurance S.A. provides a range of unit-linked insurance products. The investment parameters for those solutions and the principles of their underlying asset allocation are determined by the Insurer in accordance with its own investment policy, Luxembourg law and, often, insurance law and taxation in policyholders’ countries of residence. However, investment decisions are ultimately taken either by independent investment managers appointed by Lombard International Assurance S.A. or (in certain) countries by, or with the confirmation of, policyholders themselves, who may in turn receive investment advice. As such, it is the independent investment manager, investment adviser or, if this is the case, policyholder who is best placed to integrate sustainability risk into investment decision making and assess the principal adverse impacts of investment decisions on sustainability factors and risks on investment returns. For the same reasons, neither Lombard International Assurance S.A. as a financial market participant nor the unit-linked insurance products issued by Lombard International Assurance S.A. consider the adverse impacts of investment decisions on sustainability factors. Likewise, Lombard International Assurance S.A., when acting as Insurance Distributor, does not consider the adverse impacts of investment decisions on sustainability factors in the insurance advice carried out.
Remuneration policy statement (Article 5)
Remuneration Policy
Introduction Lombard International Assurance (the “Company”) established a Remuneration Policy in accordance with the applicable regulatory requirements. Reviewed on an annual basis or when deemed necessary it applies to all staff members. Its purpose is to define the principles and guidelines to establish and maintains equal, controlled and compliant remuneration practices that are designed to prevent (1) non-sustainable business decisions, (2) decisions in conflict with the Company and its clients’ interests, (3) risk-taking outside of risk appetite, (4) fines from the regulator(s), (5) financial loss and/or (6) demotivation of staff members. The Board of Directors, in order to exercise its responsibilities regarding remuneration, delegates the oversight of the execution of this policy to the Remuneration Committee (RemCo). The Company’s aim is to provide fair remuneration that contributes to attracting and retaining people while incentivising and rewarding them via variable remuneration for the successful delivery of the Company’s strategy and business priorities. The mechanisms of this remuneration should, in compliance with applicable regulatory requirements and best market practice (i) discourage risk taking beyond defined risk appetite (ii) prevent non-sustainable decision making and (iii) avoid situations of conflict of interest.
A sustainable remuneration framework
The Company’s remuneration framework is designed to:
Ensure that remuneration is appropriate and linked to the role of the individual. Rewards the overall delivery of the business strategy, achievement of financial results and long term growth and sustainability. Aims at paying fair base pay, based on market practice, and at recognising and rewarding collective and individual performance via variable remuneration. Encourages sound corporate governance and a strict compliance with internal rules and procedures. Does not reward excessive risk-taking outside of confirmed risk appetite. Considers the principle of proportionality in defining the remuneration principles in such a way as to take into account the internal organisation and the nature, the scale and the complexity of the risks inherent to the business
Specific provision for Material Risk Takers
The Company identifies, on an annual basis, all employees whose work is deemed to have a major influence on the overall risk profile of the Company. A suitable compensation structure is designed and subject to deferral rules.
Claw back mechanism
The RemCo may decide, at any time within 3 years of the date of a Bonus allocation that the Employee who has been allocated that Bonus shall be subject to claw back of the related Bonus allocation, if such claw back is justified in relation to one or several of the following circumstances:
any act of fraud or other intentional infringement of penal law caused by the Employee or of which the Employee had knowledge of but failed to prevent and/or flag to the board of the Company as appropriate; any circumstances caused through wilful misconduct and/or gross negligence by the Employee, or of which the Employee had knowledge of but failed to prevent and/or flag to the board of the Company as appropriate, that has (or would have if made public) a significant impact on the reputation of the Company; or a material misstatement of the Company’s financial results, caused by or of which the Employee had knowledge, and which had been considered in the Bonus determination.
Inducement Policy
Lombard International Assurance (the “Company”) established an Inducement Policy (the “Policy”) in accordance with the applicable regulatory requirements. Inducements mean any fee, commission, or any non-monetary benefit provided by or to an intermediary or insurance undertaking in connection with the distribution of an insurance-based investment product or an ancillary service, to or by any third party except the customer or a person on behalf of the customer. Inducements do not include fees paid by the customer or internal payments to employees of insurance distributors. The Policy defines that inducements and inducement schemes paid or received must not lead to a detrimental impact on the quality of the service provided to customers and prevent the insurance intermediary or insurance undertaking from complying with their obligation to act honestly, fairly and professionally and in accordance with the best interests of its customers. The Policy defines clear criteria in order to assess whether an inducement can have a detrimental impact on the services provided to the client. On a regular basis all identified inducements are reviewed and assessed. Any inducement which is likely to have a detrimental impact on the services provided to the client are escalated to the company’s Compliance Department in order to implement mitigating actions. Lombard International Assurance S.A. does not make investment decisions in respect of the assets underlying its life insurance policies, nor does it consider sustainability risks in its insurance advice as assets will exclusively be selected by independent investment managers appointed by Lombard International Assurance S.A. or (in certain) countries by, or with the confirmation of, policyholders themselves, who may in turn receive investment advice. As a consequence, this Inducement Policy does not take into account the integration of sustainability risks in the investment or insurance advice.
ABOUT THIS REPORT
This website on our ESG approach includes information about Lombard International Group (referred to as “the Group”, “we”, “us” or “our” in this Report). We specified where a section relates to a specific entity of the Group. It provides an overview of our priorities, key performance indicators and highlights from 2022 on ESG factors relevant to our industry/markets. A first step as the business seeks to further develop and solidify its climate targets and roadmap across the geographical footprint of its physical offices, future reports will be updated to take these factors into account. All information, data and examples on this website reflect activities undertaken during the 2022 fiscal year (1 January 2022 – 31 December 2022), unless stated otherwise.
