The percentage of Ultra High-Net-Worth Individuals (UHNWIs) in Europe who are becoming more worried about the impact ofclimate change. (source: Statista)
Companies in the top quartile for both gender and ethnic diversity are 12% more likely to outperform all other companies in the data set. (source: McKinsey)
51% of respondents expect sustainable investing returns to exceed those of traditional investments. (source: Yahoo Finance)
DOWNLOAD OUR ESG REPORT
Sitting at the crossroads of private banking, asset management and insurance, the Wealth Assurance sector plays a central and active role in clearly defining, integrating, and using ESG criteria.
84%
12%
51%
LEARN MORE
35%
35% of HNWs’ portfolios are expected to be in environmental investing by 2025. (source: International Adviser)
Our approach to ESG & responsibilities
Citizenship
Strategic areas of focus and SDG alignment
Sustainability
Our sustainability journey
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. Lombard International Group entities are also committed to make sustainable investment options available to its clients and partners in order to allow for options which correspond to their ESG preference. Discover how.
read MORE
READ MORE
Our commitment in practice: case studies
Environment
Social
Governance
©2022 Lombard International Group
LEGAL About this report Legal disclaimer Cookie Policy Privacy Statement ESG: SFDR disclosures
Lombard International Group 52 Lime Street London EC3M 7AF United Kingdom Tel: +44 20 3928 7759
VISIT lombardinternational.com ESG Investment Guidelines
Contact US
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
THE GLOBAL WEALTH LANDSCAPE AND ESG
follow
CONTACT
OUR ESG APPROACH
Investment mandate and external fund selection in Europe
Investment exclusions in Europe
Awareness of ESG options and clear pathways to reflect ESG directives in the U.S. and Bermuda
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 as a global organisation, and as a group of citizens, to ensure that we sustainably achieve and meet our corporate ambitions with responsibility and accountability. 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
The figure Bloomberg Intelligence predicts that Global ESG assets are on track to exceed by 2025. (source: Bloomberg)
tn
$53
The figure that Bloomberg Intelligence predicts that Global ESG assets are on track to exceed by 2025. (source: Bloomberg)
The percentage of Ultra High-Net-Worth Individuals (UHNWIs) in Europe who are becoming more worried about the impact of climate change. (source: Statista)
51% of respondents expect sustainable investing returns to exceed those of traditional investments and about 69% are seeking advice on increasing their portfolio allocation. (source: Yahoo Finance)
35% of HNWs’ portfolio are expected to be in environmental investing by 2025. (source: International Adviser)
The amount committed to by a group of 9 philanthropic foundations to finance the protection of 30% of land and sea by the end of the decade. (source: The Associated Press)
bn
$5
The amount added to the global debt mountain in 2020 by the pandemic response. (source: Institute of International Finance)
$24
Private capital on hand to fund the green transition to net zero emissions by 2050. (source: Bloomberg)
$130
30
The factor by which the richest 1% of the population would need to reduce their emissions in the next decade, in order to keep within the 1.5°C limit on global heating set out in the Paris agreement. (source: www.rapidtransition.org)
30%
At COP26, 100 countries committed to a 30% cut in methane emissions by 2030. (source: European Commission)
The global wealth landscape and ESG
The estimated profits from forced labor annually across the globe. (source: International Labor Organization)
$150
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 thought leadership, 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, reserving 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, developing customised solutions that meet their nonfinancial goals and aspirations.
We use ESG principles to guide our responsibilities and approach in helping to protect and preserve resources, assets, and communities for future generations. As a leading provider of cross-border wealth, estate, and succession planning solutions, we are in a privileged leadership position to use our geographically diversed 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 create 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 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.
Funding emergency social and/or environmental relief projects beyond our strategic areas of focus.
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 Group entities offer a high degree of investment flexibility. Being able to define and select their own investment strategy, policyholders can proactively integrate their ESG priorities into the investment options linked to their policy. Lombard International Group entities are committed to make sustainable investment options available to policyholders in order to allow for options which correspond to the policyholder’s ESG preference. While our commitment spans our internationally diversed footprint, we are mindful that the specific requirements, customs and regulations of the many jurisdictions where we operate across the globe require a flexible approach to implementation. Approaches which allow for the creation of efficient, diversified and sustainable investment portfolios may therefore vary between Lombard International Group entities, depending on their domiciles and the markets they serve.
Partnering with a leading provider of ESG data, we are proactively looking at making available sustainability ratings of many listed investment options, allowing clients to select among those investments that best align to both their financial and non-financial goals. Those clients for whom discretionary asset managers oversee investments in insurance dedicated managed accounts are invited to express their ESG priorities through customized investment policy statements. These investment policy statements are flexible tools and can be flexed to direct investments towards or away from certain asset classes or sectors (i.e. if a portfolio should include green/sustainable characteristics or if a portfolio should exclude certain controversial sectors).
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.
European issued Unit-Linked investment products offer a high degree of investment flexibility and the policyholder can integrate individual ESG priorities through the selection of the investment mandate. For a large number of our European solutions, the policyholder can directly select external investment funds to be linked to their policy from fund lists we make available. To allow policyholders to select external funds with sustainable characteristics or objectives we will integrate into our fund lists investment funds to which Article 8 or Article 9 of the SFDR (Sustainable Finance Disclosure Regulation) applies.
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.
European issued Unit-Linked investment products offer a high degree of investment flexibility and the policyholder can integrate individual ESG priorities through the selection of the investment mandate. For a large number of our European solutions, the policyholder can directly select external investment funds to be linked to their policy from fund lists we make available. To allow policyholders to select external funds with sustainable characteristics or objectives which we will integrate into our fund lists investment funds to which Article 8 or Article 9 of the SFDR (Sustainable Finance Disclosure Regulation) applies.
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.
Meaningfully addressing the excessive use of energy and goods is fundamental to successfully pursuing a carbon neutral strategy. We have been proactive on this topic for several years now. As an example, the car sharing pool in our Luxembourg head office is fully electric. Such steps have allowed us to reduce our CO2 emissions from 900 kg of CO2 per year to 336 kg of CO2 – a 62% reduction. Since 2015, the Luxembourg Head office has been fully powered by 100% renewable energy, produced by hydro-electric power, as certified by Enovos, the Luxembourgish energy provider.
Case study: Luxembourg office, on the road to carbon neutrality
case studies
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. Since 2015, Lombard International Assurance’s Luxembourg head office has continuously reduced its energy consumption by more than 20%, by becoming more energy aware, replacing IT equipment with certified Energy Star Kit and by installing automatic switch off lighting and IT equipment where possible. This has culminated in a total reduction of 232,470 kg CO2 (between 2015 and 2020). 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 50% since 2019.
Vital to the positive evolution of our society is the building of a better, kinder and more sustainable economy and social environment for the future. We are proud to support the education and engagement of Philadelphia’s youth in need via our longstanding charitable partnership with the Community Partnership School (CPS), in North Central Philadelphia. CPS is an innovative, independent elementary school that that provides affordable, high-quality education to children from low-income backgrounds. The school has small class sizes with a 7:1 student to teacher ratio, state-of-the-art technology, and takes a hands-on approach to learning. CPS was founded in 2006 in North Central Philadelphia. Over the last 5 years, our U.S.-based colleagues have committed an outstanding 200+ volunteering hours, $250,000 in sponsorships and donations, donated 100+ books and school supplies, and organised 27 events to raise funds for CPS. In 2020, we continued to support CPS via a Group-wide initiative to fund and send school supplies to equip and prepare the youth for both in-classroom and at-home learning and a series of fundraising initiatives throughout the year.
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: Community Partnership School (CPS)
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: Wealth Assurance Report
An example of how we monitor the state of our industry and listen to our stakeholders’ needs and requirements to constantly evolve our business conduct. We believe we can play a role within the broader sense of governance around the progression and evolution of our industry. Launched in September 2020, our inaugural European Wealth Assurance survey was developed as an initiative to collect feedback from wealth professionals based in 12 European jurisdictions. The survey was sent to over 16,000 European partners including private bankers, independent wealth and financial advisers, insurance brokers, family officers, independent asset managers and tax lawyers. Composed of 24 questions and translated into 7 languages, the survey was tailor designed, in association with Accenture Luxembourg, to extract the most relevant information and feedback from wealth professionals to understand how they consider and use Wealth Assurance as part of their wealth planning tool kit, across different markets. The survey had an excellent response rate, with 677 respondents from across 12 different jurisdictions. The top 5 geographical locations where the responses originated were Luxembourg (21%), Switzerland (15%), France (14%), Italy (13.8%) and Germany (9.4%), which corresponds to Lombard International Assurance’s geographic footprint, adding further value to the survey results. After in-depth quantitative and qualitative analysis of the survey results, Lombard International Assurance produced its first ever Wealth Assurance Report hosted on a specially created minisite, presenting the key insights and survey findings. Interest in this report from the industry is evidenced by the amount of visits and downloads. As of October 2021, the mini website has been visited 1704 times with 4698 pageviews and 401 downloads, numbers which continue increasing. The range of findings and insights presented in the Wealth Assurance Report has supported Lombard International Assurance’s development of a future-focused strategy and led to operational changes to better serve the company’s partners and clients, and importantly, anticipate their future needs. Key finding from the report were that increasing regulation, the pressing digital revolution, and the upcoming transfer of wealth across generations are the fundamental challenges and opportunities highlighted by wealth professionals based across Europe. Notably, 75% of respondents expect a high level of digitalisation over the coming years. Lombard International Assurance’s Wealth Assurance Report has proven to be a pivotal project for the company in terms of positioning Lombard International Assurance as forerunner in generating industry insights and using partner feedback to make targeted changes to continually improve the company’s service offering. A similar U.S. edition will be published in 2022.
LEARN MORE ABOUT THIS INITIATIVE
OUR COMMITMENT IN PRACTICE
LEARN MORE ABOUT OUR CHARITABLE INITIATIVES
Meaningfully addressing the excessive use of energy and goods is fundamental to successfully pursuing a carbon neutral strategy. We have been proactive on this topic for several years now. As an example, the car sharing pool in our Luxembourg head office is fully electric. Such steps have allowed us to reduce our CO2 emissions from 900 kg of CO2 per year to 336 kg of CO2 – a 62% reduction. Since 2015, the Luxembourg Head office has been fully powered by 100% renewable energy, produced by hydro-electric power, as certified by Enovos, the Luxembourgish energy provider. 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. Since 2015, Lombard International Assurance’s Luxembourg head office has continuously reduced its energy consumption by more than 20%, by becoming more energy aware, replacing IT equipment with certified Energy Star Kit and by installing automatic switch off lighting and IT equipment where possible. This has culminated in a total reduction of 232,470 kg CO2 (between 2015 and 2020). 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 50% 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
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.
Cookies policy
- Strictly necessary cookies: these cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies, services you have asked for cannot be provided. - Performance cookies: these cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works. - Functionality cookies: these cookies allow the website to remember choices you make (such as language or the region you are in) and provide enhanced, more personalised features. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. - Marketing cookies: We use third party cookies to provide you with more personalised and relevant content. Our analytics also help collect and compile information like the number of visitors to the site, where visitors have come to the site from and the pages they visited. These cookies don't collect information that identifies a visitor. They cookies are not passing personally identifiable information to any external vendor or supplier, but are used for internal purposes only.
In addition to the above cookies, we also use Google Analytics to help collect and compile information like the number of visitors to the site, where visitors have come to the site from and the pages they visited. Visit Google’s site for an overview of privacy at Google and information on how to opt out of the Google Analytics cookie. Where this site allows such cookies to be set or you access other websites from this site using the links provided, the operators of these websites will use cookies in accordance with their own cookies policy, which may differ from ours. We do not use cookies to store any personal information that could be read or understood by others. For more information on how we collect and use information that is identifiable to you, please refer to our Privacy Disclaimer. By continuing to use this website without disabling cookies, you consent to the placement of cookies on your computer in accordance with the terms of this policy. If you do not wish to accept cookies from this site please either disable cookies or refrain from using this site. Please note that by disabling cookies in your browser settings this site may not function correctly. For more information on Cookies in general and on how to manage and disable them, please refer to the following website: www.allaboutcookies.org
This website uses Cookies. Cookies are small text files that may be placed on your browser when visiting our website. Cookies allow your browser to remember some specific information which the web server can later retrieve and use. When you quit your browser, some cookies are stored in your computer’s memory, while some expire or disappear. Cookies are used on our website primarily to improve your online experience. This website uses the following types of Cookies:
Privacy Statement
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 Statement 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 document 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 2021 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. All information, data and examples in this document reflect activities undertaken during the 2021 fiscal year (1 January 2021 – 31 December 2021), unless stated otherwise.
