The role of administrative, management and supervisory bodies

The Risk Committee, the Audit Committee and the Organisation and Remuneration Committee consist of members of the Board. The Chair of the Board has broad expertise of sustainable development from several sectors, and has completed several courses and certifications in sustainability. Several members of the board have completed Gjensidige's sustainability course in 2022 and 2023. Many of the board members have also completed other courses and have experience of sustainability work through directorships in other companies. We believe that the board has sufficient sustainability competencies.

Board Structure and Responsibilities

THE NOMINATION COMMITTEE: Responsible for ensuring that the board has the necessary expertise and experience

THE BOARD: Adopts sustainability goals and strategy (management responsibility), and follows up the status of measures and their effect (supervisory responsibility), and is responsible for everything that is dealt with in the subcommittees.

THE AUDIT COMMITTEE: Reviews quarterly sustainability report, internal control over non-financial reporting, sets materiality threshold and reviews the double materiality analysis. The committee determines the process for processing the annual report, including the sustainability report, and pre-processes the report for decision by the board.

THE RISK COMMITTEE: Reviews proposals for sustainability targets, discusses identified influences, risks and opportunities, and ensures that risk appetite includes sustainability topics and risk exposure.

THE ORGANISATION AND REMUNERATION COMMITTEE: Prepares the scorecard for the CEO, where the operationalization of several sustainability topics occurs and is measured. The Committee shall provide advice on matters relating to remuneration, and annually discuss with the CEO principles and specific frameworks for determining the remuneration of other senior executives.

CEO: Responsible for delivering on the goals set by the board, and setting sustainability goals downwards in the organization through the scorecards of the executive vice presidents

EVPS AND MANAGING DIRECTORS OF SUBSIDIARIES: Executive vice presidents and executives of subsidiaries implements sub-goals and action plans to deliver on the sustainability goals.

Board Composition

Gjensidige's Board has ten members, of whom seven are elected by the shareholders and three are elected by and from among the company's employees. The shareholder-elected board members are elected for one year at a time by the General Meeting, on the recommendation of the Nomination Committee. The composition of the Board is in accordance with the requirements set out in the Articles of Association with regard to competence, gender, age and geographical affiliation. The employee representatives are elected for two years at a time.

The members of the Board have expertise in finance, insurance, law, technology, digital business, innovation, international business, the public sector and management. They have held senior positions in companies operating in all the countries in which Gjensidige operates. They also have varied expertise in sustainability, and most have completed Gjensidige's sustainability seminar.

Throughout 2024 the board has been presented quarterly sustainability reports with a focus on stats for goal attainment, effects and new measures. The board has broad sustainability experience, and has completed courses and certifications. We have prepared a double materiality assessment that has been discussed by the sub committees of the board throughout the year.

Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies

Throughout 2024 the board has been presented quarterly sustainability reports with a focus on stats for goal attainment, effects and new measures. The board has broad sustainability experience, and has completed courses and certifications. We have prepared a double materiality assessment that has been discussed by the sub committees of the board throughout the year.

The Board has overall responsibility for ensuring that the Group is managed responsibly, including responsibility for strategy, finances, the environment, social conditions and compliance with laws and regulations. This includes ensuring that the work on risk management and internal control is organised, documented and reported on in an expedient manner.

Committee Responsibilities

THE AUDIT COMMITTEE: Reviews quarterly sustainability report, internal control over non-financial reporting, sets materiality threshold and reviews the double materiality analysis. The committee determines the process for processing the annual report, including the sustainability report, and pre-processes the report for decision by the board.

THE RISK COMMITTEE: Reviews proposals for sustainability targets, discusses identified influences, risks and opportunities, and ensures that risk appetite includes sustainability topics and risk exposure.

THE ORGANISATION AND REMUNERATION COMMITTEE: Prepares the scorecard for the CEO, where the operationalization of several sustainability topics occurs and is measured. The Committee shall provide advice on matters relating to remuneration, and annually discuss with the CEO principles and specific frameworks for determining the remuneration of other senior executives.

Integration of sustainability-related performance in incentive schemes

THE ORGANISATION AND REMUNERATION COMMITTEE: Prepares the scorecard for the CEO, where the operationalization of several sustainability topics occurs and is measured. The Committee shall provide advice on matters relating to remuneration, and annually discuss with the CEO principles and specific frameworks for determining the remuneration of other senior executives.

CEO: Responsible for delivering on the goals set by the board, and setting sustainability goals downwards in the organization through the scorecards of the executive vice presidents

EVPS AND MANAGING DIRECTORS OF SUBSIDIARIES: Executive vice presidents and executives of subsidiaries implements sub-goals and action plans to deliver on the sustainability goals.

The remuneration of executive personnel is linked to value creation over time, reflects responsibilities and expertise and is based on measurable outcomes. The level of goal attainment influences the payment of bonuses to executive personnel and collective bonuses to all employees. Customer satisfaction goals and other sustainability-related performance metrics are incorporated into these measurement frameworks.

Statement on due diligence

We are dependent on the trust of our surroundings to carry out our social mission. A comprehensive understanding of risk, with clear roles and responsibilities, is essential in our corporate governance.

Our Code of Conduct shall ensure that all employees act in a way that maintains trust in the Company. All Gjensidige's activities must stand up to public scrutiny.

Gjensidige's governance structure includes The General Meeting as the Company's supreme governing body, with an independent nomination committee that nominates members to the Board. The Board has overall responsibility for ensuring that the Group is managed responsibly, including responsibility for strategy, finances, the environment, social conditions and compliance with laws and regulations. This includes ensuring that the work on risk management and internal control is organised, documented and reported on in an expedient manner.

Our business is conducted within the framework of our strategy, our ethical principles and strict compliance with laws and regulations in the countries in which we operate. Sustainability is integrated into the strategy and our core processes.

Throughout our history, we have demonstrated social responsibility. This responsibility comes from our role as one of the Nordic region's largest insurance companies, where we have helped our customers by providing advice on damage prevention and been there when the damage was done. Among other things, this means requiring sustainable deliveries from our suppliers in their claims process. Sustainability is an integrated part our business model.

Going forward, Gjensidige will attend to this social responsibility by contributing to a sustainable society, in relation to both our insurance and investment activities. The following factors are particularly important in our sustainability work: GHG emissions and climate change adaptation of our products, circular economy, and how we can ensure that we develop expertise on risks related to the green transition so that we can help mitigate risk.

We define sustainability in line with the UN Sustainable Development Goals. This means that Gjensidige's activities will ensure a balance between climate and the environment, social conditions, good corporate governance and finances. Gjensidige's sustainability work focuses on four areas: a safer society, sustainable claims handling and responsible investments, and order in our own house. Ambitions and action plans will underpin our transition plan towards 2050.

Risk management and internal controls over sustainability reporting

THE AUDIT COMMITTEE: Reviews quarterly sustainability report, internal control over non-financial reporting, sets materiality threshold and reviews the double materiality analysis. The committee determines the process for processing the annual report, including the sustainability report, and pre-processes the report for decision by the board.

THE RISK COMMITTEE: Reviews proposals for sustainability targets, discusses identified influences, risks and opportunities, and ensures that risk appetite includes sustainability topics and risk exposure.

We are dependent on the trust of our surroundings to carry out our social mission. A comprehensive understanding of risk, with clear roles and responsibilities, is essential in our corporate governance.

The governance structure is described in more detail in our statement on corporate governance at gjensidige.com, in Note 3 to the accounts and in the Pillar 3 report.

The Board has overall responsibility for ensuring that the Group is managed responsibly, including responsibility for strategy, finances, the environment, social conditions and compliance with laws and regulations. This includes ensuring that the work on risk management and internal control is organised, documented and reported on in an expedient manner.

Identified climate risks and opportunities are assessed at least once a year and are included in our ORSA process. The assessments are based on when they are expected to materialise (short, medium or long term) and based on both a qualitative and (when possible) quantitative impact assessment.

Our definition of short (<1 year), medium (1-5 years) and long term (>5 years) is in line with the requirements of the ESRS, except for climate risk. We have continued our long-standing work on climate risk and have chosen to use the same timeline as before. For climate risk assessments, short term means 0–3 years, medium term 3–10 years and long term more than 10 years.

Strategy, business model and value chain

Our Mission, Vision and Values

OUR MISSION: We safeguard life, health and assets.

OUR VISION: We shall know the customer best and care the most.

OUR POSITION: Gjensidige is the insurance company that leads the way and finds new ways to create a sense of security.

OUR CORE VALUES:

• CREATING A SENSE OF SECURITY: Security is achieved by leaving room for error, showing trust, openness, and listening to, seeing and supporting each other. Security creates the space to challenge and takes us further. A secure setting gives us courage.
• APPLYING NEW THINKING: New thinking is about being inquisitive and being willing to do things better, be they big or small. Share your own thoughts and ideas and actively engage in those of others. New ideas lead to learning, create dynamics, challenge us and take us one step further.
• GOING FOR IT: Dare to go for it. Demonstrate determination and finish in style. Go for it! That's how we face the future head-on.

Business Model

Gjensidige creates value by carrying risk for customers and compensating losses that arise. One of our core competencies is thus assessing risk. Throughout our history, it has been natural for us to focus on preventing damage, and we advise customers and society at large on how to avoid or limit losses.

Our business model can be described through five core processes, in line with the UN Principles for Sustainable Insurance (UN PSI):

1. RISK ASSESSMENT AND MANAGEMENT: We need to understand the risk we take on and set the right price to cover future compensation for losses that may and will occur. We must also have sufficient capital to meet our obligations. Risk assessment is therefore a core competence in general insurance. We use this expertise to advise customers and society at large on damage prevention.

2. PRODUCTS AND SERVICES: We develop and offer insurance that covers customers' need for peace of mind, and develop related services for, among other things, damage prevention and claims processing. We generally distinguish between property and liability insurance, often called general insurance, and accident and health insurance.

3. DISTRIBUTION AND SALES: Our customer service centres account for most of our distribution, but we also sell insurance through partners, agents and brokers. All our sales representatives and advisers are well trained and certified in accordance with industry standards. We have an established culture of deep customer orientation and seek to foster long-term customer relationships.

4. CLAIMS HANDLING: Our customers shall receive the correct claims settlement as soon as possible after a loss has occurred. We increasingly use automated processes to achieve quick and precise settlements, while our experienced and competent claims handlers process complex cases. We keep accounts of GHG emissions from claims handling and work systematically on circular solutions to reduce emissions.

5. RESPONSIBLE INVESTMENTS: We manage substantial capital assets to ensure that we are able to meet our obligations to customers and other stakeholders at all times. The capital is managed with low risk exposure and with as high a return as the risk profile allows. We comply with internationally recognised principles for responsible investments, and have adopted a target of net zero emissions for the portfolios by 2050.

Strategic Focus Areas

Our overarching ambition is to be a leading general insurance company in the Nordic region. We will achieve this through continued profitable growth driven by three strategic focus areas:

1. Strong customer orientation throughout the value chain
2. Being the best at general insurance
3. Being an attractive alliance partner in larger ecosystems

Value Creation

We create peace of mind for customers, and through knowledge sharing, we contribute to security for society as a whole. We offer competence-based jobs that make high demands of, and create good opportunities for, skills development for our employees and room for a good work-life balance. We help finance society through direct and indirect taxes, and we aim to deliver a competitive return to our owners.

Factor Inputs

Our factor inputs are mainly skilled labour, technology, data and capital. Throughout our more than 200 years of history, we have built in-depth expertise in all our core processes, and we have developed one of Norway's best known brands regardless of industry. Outside Norway, the brand name is in a challenger position.

The Nordic Region as Home Market

We have defined the Nordic region as our geographical home market. We continue to see attractive long-term growth opportunities in this market, where we will continue to seek growth in general insurance, our core area of activity. The Nordic general insurance markets are among the most well-developed, profitable and digitally advanced in Europe.

Sustainability Integration

Sustainability is integrated into the strategy and our core processes. Our business is conducted within the framework of our strategy, our ethical principles and strict compliance with laws and regulations in the countries in which we operate. We mainly perform all core processes ourselves.

Throughout our history, we have demonstrated social responsibility. This responsibility comes from our role as one of the Nordic region's largest insurance companies, where we have helped our customers by providing advice on damage prevention and been there when the damage was done.

Going forward, Gjensidige will attend to this social responsibility by contributing to a sustainable society, in relation to both our insurance and investment activities. Gjensidige's sustainability work focuses on four areas: a safer society, sustainable claims handling and responsible investments, and order in our own house.

Interests and views of stakeholders

Customer orientation is essential to Gjensidige and permeates the entire organisation. We shall deliver the best customer experience and solutions for a safer tomorrow. Real customer orientation requires an established culture in which advisory services, sales, claims handling, products, services and systems development form integral elements.

We are concerned with understanding developments in society and being relevant in our customers' lives. Possible consequences of climate and environmental challenges, demographic changes and changed health needs are examples of areas we explore.

Good customer experiences over time have created strong trust in Gjensidige as a brand. Our ambition is to create the best customer experiences in our industry. We call this the Gjensidige Experience, which reflects our vision and our strong customer orientation culture.

We have very satisfied customers and high customer loyalty, especially in Norway, where we have the strongest reputation in the financial sector and one of the strongest regardless of sector.

Satisfaction with the Company and our customer advisers is measured on a continuous basis, and improvement measures are initiated based on feedback from customers. We have defined clear goals for customer satisfaction. The level of goal attainment influences the payment of bonuses to executive personnel and collective bonuses to all employees.

Customer Dividend - Unique Advantage

Every year since Gjensidige was listed on Oslo Børs, general insurance customers in Norway have received a customer dividend. Over the years, they have received around NOK 30 billion, corresponding to between 11 and 16 per cent of their annual insurance premium. The background for the customer dividend model is that Gjensidige was established as a company owned by customers. Today, the customers' interests are safeguarded by Gjensidigestiftelsen, the largest shareholder in Gjensidige.

Employee Engagement

Employee engagement is measured on a regular basis to identify challenges we need to address. As an organisation, we must be able to meet changing needs and requirements, deal with challenges effectively, at the same time as we make courageous choices and get things done. We are also open to new ideas and solutions and adapt to new ways of working.

We are ambitious and always focus on people. Attracting and retaining a diverse and competent workforce is essential to be able to mirror customers and provide the best customer experiences. Gjensidige offers a secure workplace, good development and learning opportunities and room to be who you are.

Supplier Engagement

All suppliers must sign the Supplier Code of Conduct. We work systematically with our value chain to ensure sustainable deliveries from our suppliers in their claims process.

Society and Communities

We contribute to security for society as a whole through knowledge sharing and damage prevention advice. We help finance society through direct and indirect taxes. We are a member of Skift – Business Climate Leaders – which is a solutions-oriented network for climate-conscious companies in Norway. We are also working with research institutions to gain more knowledge about how wilder and wetter weather will impact us and our customers.

Investor Relations

We will make sure that financial market participants have an adequate basis for assessing the Group's value through simultaneous access to the same correct, clear and relevant information at all times. Each quarter, we meet with investors and analysts to discuss our results and business operations.

Material impacts, risks and opportunities and their interaction with strategy and business model

The material sustainability topics for Gjensidige, based on the double materiality assessment, include:

Environmental Topics:

• Climate change (E1): More frequent weather-related events, greater attention to the consequences of climate change give rise to a need for more sustainable insurance solutions. Climate change adaptation and damage prevention are important responsibilities.
• Pollution (E2): Material for addressing environmental impacts from operations and value chain.
• Water and marine resources (E3): Relevant due to water-related claims and environmental impacts.
• Biodiversity and ecosystems (E4): Important for long-term risk assessment and environmental responsibility.
• Resource use and circular economy (E5): Critical for sustainable claims handling and reducing environmental impact.

Social Topics:

• Own workforce (S1): Essential for attracting and retaining diverse and competent workforce to mirror customers and provide best customer experiences.
• Workers in the value chain (S2): Important for ensuring sustainable deliveries from suppliers in claims processes.
• Affected communities (S3): Relevant through our role in contributing to security for society as a whole.
• Consumers and end-users (S4): Central to our customer orientation and creating the best customer experiences.

Governance Topics:

• Business conduct (G1): Fundamental to maintaining trust and ensuring all activities stand up to public scrutiny.

Strategic Integration

These material topics are integrated into our strategy through:

Customer Orientation: We prioritise supplying a wide range of solutions where products are fairly standardised and demand is stable, with direct customer contact to create peace of mind and develop customer relationships.

Risk Management: Our core competence in risk assessment is used not only for pricing but also for advising customers and society on damage prevention, particularly related to climate change.

Operational Excellence: Efficiency through automated processes, circular solutions in claims handling, and sustainable investment practices.

Sustainability Focus Areas:

1. A safer society: Contributing to damage prevention and climate adaptation
2. Sustainable claims handling: Reducing GHG emissions and promoting circular economy
3. Responsible investments: Net zero emissions target by 2050
4. Order in our own house: Ensuring sustainable operations and good governance

Interaction with Business Model

The material sustainability topics interact with our five core processes:

1. Risk Assessment: Climate change creates new risks requiring updated assessment methods
2. Products and Services: Development of sustainable insurance products and damage prevention services
3. Distribution and Sales: Customer education on sustainability and climate adaptation
4. Claims Handling: Implementation of circular solutions and emission reduction measures
5. Investments: Integration of ESG criteria and climate risk assessment

Time Horizons

Risks and opportunities are assessed using different time horizons:

• Short term (<1 year for general topics; 0-3 years for climate)
• Medium term (1-5 years for general topics; 3-10 years for climate)
• Long term (>5 years for general topics; >10 years for climate)

Identified climate risks and opportunities are assessed at least once a year and are included in our ORSA process, based on both qualitative and (when possible) quantitative impact assessments.

Description of the processes to identify and assess material impacts, risks and opportunities

We have prepared a double materiality assessment that has been discussed by the sub committees of the board throughout the year. The Audit Committee sets materiality threshold and reviews the double materiality analysis.

Identified climate risks and opportunities are assessed at least once a year and are included in our ORSA process. The assessments are based on when they are expected to materialise (short, medium or long term) and based on both a qualitative and (when possible) quantitative impact assessment.

Our definition of short (<1 year), medium (1-5 years) and long term (>5 years) is in line with the requirements of the ESRS, except for climate risk. We have continued our long-standing work on climate risk and have chosen to use the same timeline as before. For climate risk assessments, short term means 0–3 years, medium term 3–10 years and long term more than 10 years.

New and Emerging Risks Analysis

The risk situation is complex and constantly changing. New and emerging risks typically develop over time, often as a result of changes in climate, the political or social situation, or technological development.

The main purpose of the analysis is to identify and monitor such potential risks, and the consequences these may have for the Company. This will allow necessary measures and adaptations to be implemented at an early stage.

We have established a comprehensive approach to emerging risks as part of our risk management framework. We identify and analyse a broad range of new and emerging risks and consider their potential impact on the Company. Risks we consider material and/or about which we have limited knowledge are given priority and analysed in more detail.

Emerging Risks Categories Analysed:

TECHNOLOGY:

• Cyber threats
• Nanotechnology
• Autonomous vehicles
• Digital currency
• Quantum computing
• Loss of critical infrastructure

THE ENVIRONMENT:

• Plastics and microplastics
• Physical risk (climate)
• Gene technology
• Resource scarcity
• Biodiversity

SOCIAL/CUSTOMER BEHAVIOUR:

• Transition risk (climate)
• Sharing economy
• Mental health
• Socioeconomic inequality

FINANCIAL/POLITICAL/REGULATORY:

• Disruption in the supply chain
• Class action
• Rising debt levels
• Geopolitical conflict

Risk Assessment Process

THE RISK COMMITTEE: Reviews proposals for sustainability targets, discusses identified influences, risks and opportunities, and ensures that risk appetite includes sustainability topics and risk exposure.

We are dependent on the trust of our surroundings to carry out our social mission. A comprehensive understanding of risk, with clear roles and responsibilities, is essential in our corporate governance.

The risk assessments consider both the impact on the business (inside-out perspective) and the impact from external factors on our business (outside-in perspective), in line with the double materiality principle.

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

The material sustainability topics for Gjensidige, based on the double materiality assessment, include:

Cross-cutting Standards:

• ESRS 1: General Requirements
• ESRS 2: General Disclosures

Environmental Standards:

• ESRS E1: Climate change
• ESRS E2: Pollution
• ESRS E3: Water and marine resources
• ESRS E4: Biodiversity and ecosystems
• ESRS E5: Resource use and circular economy

Social Standards:

• ESRS S1: Own workforce
• ESRS S2: Workers in the value chain
• ESRS S3: Affected communities
• ESRS S4: Consumers and end-users

Governance Standards:

• ESRS G1: Business conduct

All these topics are covered in the sustainability statement. The scope of consolidation for the sustainability report is in accordance with Gjensidige Forsikring Group's consolidated accounts. For our Baltic subsidiary ADB Gjensidige, we have assumed that we have operational control, which means that it is included in the sustainability report even though it is presented in the financial statements as a discontinued operation.

In addition to our own business, the sustainability report also includes upstream and downstream activities. We have conducted a value chain assessment that describes our own activities as well as upstream and downstream activities.

In our assessments of upstream and downstream activities, we have, as far as possible, used the same goals, metrics and methods as in our operational and financial follow-up. Every year, we evaluate whether we can improve our processes to collect relevant data in the value chain and improve our reporting.

Transition plan for climate change mitigation

Overall commitment and scope

At Gjensidige, we have committed to reaching net-zero emissions by 2050 for our own operations, our claims handling and our investment portfolios. By net-zero emissions we aim at reducing all GHG emissions towards zero and compensate emissions not possible to eliminate with known technologies with measures for carbon removal and storage.

Our transition plan is a continuation of the climate targets adopted by the Board that were launched in 2021 and reviewed and confirmed in 2024. Gjensidige's transition plan is divided into three main focus areas, with emission reductions that support limiting global warming to 1.5°C in line with the Paris Agreement.

The scope of consolidation for the sustainability report is in accordance with Gjensidige Forsikring Group's consolidated accounts. For our Baltic subsidiary ADB Gjensidige, we have assumed that we have operational control, which means that it is included in the sustainability report even though it is presented in the financial statements as a discontinued operation.

Target years for net zero / carbon neutral

Net zero emissions by 2050 for:

• Own operations (Scope 1 and 2)
• Claims handling (Scope 3, categories 1 and 5)
• Investment portfolios (Scope 3, category 15)

Scope 1, 2, 3 reduction milestones with baseline years

Own operations (Scope 1 and Scope 2):

• Base year: 2019
• Target: Emissions from own operations will be reduced by 90 per cent by 2030
• Residual emissions must be carbon offset

Claims handling (Scope 3, categories 1 and 5):

• Base year: 2019
• Target: Emissions from claims handling are to be reduced by 55 per cent by 2050, measured in intensity

Investment portfolios (Scope 3, category 15):

• Base year: 2022
• Target: We will adapt our investment portfolios to global net zero emissions by 2050

GHG emission reduction targets by milestone year

Alignment with 1.5°C / SBTi validation status

We have established methods to ensure a science-based approach to the targets. In autumn 2024, we submitted the targets for validation according to the SBTi's near-term framework for financial institutions.

The submitted target follows SBTi's Near Term Framework (version 2.0) and includes an emissions-weighted Portfolio Coverage target for equity and fixed-income investments where we include Scope 1, Scope 2 and Scope 3 emissions. Real estate investments are covered by an emission intensity target based on the Sectoral Decarbonization Approach.

We have submitted a Near Term target to the SBTi. The target follows version 2.0 of the SBTi framework, which was published after the project we participated in. The target is awaiting SBTi approval.

As the only Nordic insurance company, we agreed to take part in a pilot project under the auspices of the SBTi to test the framework in practice and set science-based climate targets for 2030, 2040 and 2050.

Key levers / decarbonization pillars

Own operations

Decarbonisation levers:

• Scope 1: Transition to new technology and electric cars
• Scope 2: Energy efficiency measures
• Scope 2: Purchase of guarantees of origin for renewable energy
• Carbon credits

Measures implemented in 2024:

• Changed rules for company cars: GHG emissions cannot exceed 130 grams/km and all new company cars in Norway must be electric (helped reduce emissions by 6 per cent from 2019)
• Purchase Guarantees of origin to ensure the use of renewable electricity (helped reduce GHG emissions by 4,261 tonnes and 91 per cent from 2019)
• Minimised the need for travel by enabling employees to work from home and by deploying excellent videoconferencing facilities (helped reduce GHG emissions by 1,030 and 55 per cent)
• Renewed Eco-Lighthouse certification for head office and one GMG office

Planned new measures:

• Ensure that all company cars and REDGO's roadside assistance vehicles are electric
• Implement further energy efficiency measures in offices
• Ensure electricity bought is renewable through use of Guarantees of origin
• Offset purchase of non-renewable district heating with carbon credits
• Consider need to change travel policy to reduce flights

Claims handling

Measures implemented in 2024:

• Established pilot project for customers to confirm use of equivalent parts in vehicle repairs
• Partnership with Fell Tech for monitoring water leaks to reduce water damage (reached approximately 7,000 customers)
• Pilot project with Pro Inspection in Denmark using drones for thermographic scanning of solar panels
• New weather forecasting system in Sweden based on SMHI's weather forecast
• Pilot project in Denmark for safe charging of lithium batteries
• Partnership with CarBucks in Denmark to encourage repair of minor damage instead of replacing with new parts

Planned new measures:

• Implement several damage prevention measures with analytical approach to reduce frequency claims
• Consider giving customers incentives to implement damage prevention measures
• Work with suppliers to increase repair rates and adopt new technology for new repair methods
• Promote increased reuse/recycling in connection with damage repairs
• Improve communication with customers about reuse and recycling quality and safety

Investment portfolios

Measures implemented in 2024:

• Participated in two pilot projects under auspices of SBTi (Near-Term framework update and net-zero emissions framework)
• Established pension profiles with purpose of sustainable investments (NOK 1.6 billion as of 31.12.2024, around 2.5% of capital in deposit profiles)
• Made sustainable profiles automatically available to all employees of corporate clients at no extra cost

Planned new measures:

• Implement several measures including portfolio allocation, dialogue with managers and companies, and conduct contribution and scenario analyses

Insurance portfolio

Measures implemented in 2024:

• Conducted initial emission analysis based on guidance from Partnership for Carbon Accounting Financials (PCAF)
• Changed underwriting policy in 2023 so we will not insure coal, oil or gas extraction going forward

Planned new measures:

• Monitor development of framework for setting targets for insured emissions
• Complete mapping work to enable Board to adopt insured emissions targets
• Ensure dialogue and cooperation with major customers and industry to establish best practices

Climate change adaptation

Measures implemented in 2024:

• Aligned insurance terms for seven insurance products with EU taxonomy incentives for climate change adaptation
• Agreement with Mitigrate for climate change adaptation measures for properties using technology to simulate effective measures
• Continued collaboration with Norwegian Computing Centre with new analysis on consequences of torrential rain
• Contributed expertise and claims statistics to several research projects
• Hosted two debates at Climate Festival in Denmark

Planned new measures:

• Continue to align insurance products with EU taxonomy criteria
• Continue to share knowledge and data with authorities and research projects
• Continue collaborating with industry organisations on climate change adaptation measures
• Monitor new technologies and adopt solutions relevant to climate adapt products

Target related to climate change adaptation

The operational target adopted by the Board in 2021 is for 80 per cent of our insurance revenue to be aligned with the non-life insurance criteria in the EU taxonomy by 2026.

CapEx / investment commitments

Not specifically disclosed in monetary terms. The company states that operational costs and capital costs associated with the transition plan are analyzed, and that climate and nature-related risks and opportunities are considered in all parts of business to ensure adaptation of products, correct pricing of risks, good claims settlement, and in the ORSA process to meet capital adequacy requirements.

Dependencies and uncertainty factors

Reducing all relevant GHG emissions to net zero will be demanding, and we are prepared to face challenges and dilemmas in the process. This applies to how we balance considerations for returns from our investments while stimulating low and zero-emission solutions, and how we prevent and remedy claims with the smallest possible footprint on climate and nature.

We recognise that the SBTi framework and other relevant frameworks will undergo further development and make new requirements and challenges of us, while also offering many opportunities. This will entail seeing climate and nature-related risks more in context, and increasing the need for insight and effective trade-offs.

The way forward is based on the assumptions we are able to make today. The figures are associated with considerable uncertainty, but they indicate which main measures will help us achieve our goals.

Uncertainties include:

• When technology will be robust enough for rescue vehicles is uncertain
• Developments in both number of claims and repair methods used affect GHG emissions for claims
• Investment portfolio aimed at companies that have adopted climate goals that underpin our ambition of net zero emissions by 2050

Governance

The transition plan is an integral part of Gjensidige's corporate governance and defines clear responsibilities and roles for the Board, senior group management and employees.

The Board has adopted the Group's overall strategy and sustainability goals on which the transition plan is based. The Board and senior group management will be involved in the development, revision and updating of goals along the way and in the actual implementation. They will monitor progress on the transition plan through established quarterly reporting to ensure that measures are integrated into the company's activities.

The status of the climate transition has been discussed by the Board in 2024.

Financial impacts of climate change are also taken into account in the solvency assessment process (ORSA) and in scenario testing.

Use of carbon credits / removals

For own operations (Scope 1 and 2): Residual emissions must be carbon offset after achieving 90% reduction by 2030.

The company states: "By net-zero emissions we aim at reducing all GHG emissions towards zero and compensate emissions not possible to eliminate with known technologies with measures for carbon removal and storage."

We are committed to purchasing guarantees of origin, and the residual emissions will be carbon offset. We follow up on this quarterly and report the status to the Board every quarter.

We will offset the purchase of non-renewable district heating with carbon credits, preferably in combination with carbon removal and social factors.

Current emissions status (2024)

Note: Category 15 Investments base year is 2022 and applies to scope 1 and scope 2. The value in 2022 was 451,919 tonnes CO2e. Scope 3 is not included in these figures but amounts to 2,948,282 tonnes of CO2e in 2024.

Policies related to climate change mitigation and adaptation

Gjensidige does not disclose a specific named policy dedicated to climate change mitigation and adaptation in the provided excerpts. However, the company has established comprehensive climate-related commitments and governance structures that function as policy frameworks:

Climate Commitments and Transition Plan

Scope:

• Own operations (Scope 1 and 2)
• Investment portfolios (Scope 3)
• Claims handling
• Insurance products incorporating climate change adaptation

Governance and oversight:

• The Board has adopted the Group's overall strategy and sustainability goals on which the transition plan is based
• The Board and senior group management are involved in the development, revision and updating of goals
• Progress monitored through established quarterly reporting to the Board
• The Board discussed the status of the climate transition in 2024

Key commitments and principles:

• Net-zero emissions by 2050 for own operations, claims handling and investment portfolios
• 90% reduction in Scope 1 and 2 emissions by 2030 (from 2019 baseline)
• Alignment with 1.5°C Paris Agreement target
• Science-based approach following SBTi framework (submitted for validation in autumn 2024)
• Climate targets adopted by the Board in 2021, reviewed and confirmed in 2024
• Target to incorporate climate change adaptation into insurance products (adopted by the Board)
• Underwriting policy changed in 2023 to exclude insurance of coal, oil or gas extraction

Implementation and monitoring:

• Climate accounts disclosed quarterly
• Quarterly status reporting to the Board as part of sustainability reporting
• Financial impacts considered in solvency assessment process (ORSA) and scenario testing
• Science-based methods established to ensure target achievement

Investment Portfolio Alignment

Scope:

• All investment portfolios

Key principles:

• Investment portfolios to be adapted to global net zero emissions by 2050
• Internal framework for managers and individual companies based on science-based targets
• Portfolio allocation decisions, dialogue with managers and companies, contribution and scenario analyses

Links to international frameworks:

• Submitted targets for validation according to SBTi's near-term framework for financial institutions (autumn 2024)
• Participated in SBTi pilot project for Financial Institutions Net-Zero Standard (FINZ)
• Use of PCAF (Partnership for Carbon Accounting Financials) guidance for emissions analysis

The company's climate approach is integrated into its corporate governance and strategy rather than articulated as a standalone policy document.

Actions and resources in relation to climate change policies

Decarbonisation measures, own operations

Target: Emissions from Scope 1 and Scope 2 should be reduced by 90% by the end of 2030. Residual emissions will be carbon offset. Quarterly monitoring and reporting to the Board.

Actions taken and effects generated:

• Company car policy changes: GHG emissions cannot exceed 130 grams/km and all new company cars in Norway must be electric. This has helped reduce emissions by 6% from 2019. The figures include an increase due to newly purchased tow trucks in GMG/REDGO; without them, emissions would have been halved.

• Purchase of Guarantees of Origin: To ensure the use of renewable electricity. This has helped reduce GHG emissions by 4,261 tonnes and 91% from 2019.

• Minimised travel needs: By enabling employees to work from home and deploying excellent videoconferencing facilities in all locations. This has helped reduce GHG emissions by 1,030 tonnes and 55%.

Actions to achieve net zero emissions by 2050:

• Requiring all company cars and REDGO's own/leased recovery vehicles, as far as technologically possible, to be electric
• Continuing efforts to reduce energy consumption, considering further energy efficiency measures in offices and ensuring that electricity bought is renewable through the use of certificates of origin
• Committed to purchasing guarantees of origin to ensure electricity consumption is renewable
• Offsetting all residual emissions by purchasing carbon credits, preferably in combination with carbon removal and social factors

Scope: Own operations

Time horizon: 90% reduction by 2030; net zero by 2050

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Decarbonisation measures, claims handling

Target: Emissions from claims handling shall be reduced by 55% annually by year end 2030, measured in carbon intensity. Quarterly monitoring as part of sustainability reporting to the Board.

Actions taken and effects generated:

• Overall achievement: Reduced greenhouse gas emissions by 861 tonnes since 2019, and reduced intensity by 41%, which is 11% better than the target for 2024.

• Requirements for suppliers: Set requirements for and worked with suppliers to increase the proportion of equivalent car parts and identify new repair methods. This has contributed to an increase in the repair rate for bodywork. The effect is estimated to have reduced greenhouse gas emissions by approximately 900 tonnes of CO2 equivalents.

• Improved conversion factors: The effect of improved fossil emissions in applied conversion factors constitutes a reduction in greenhouse gas emissions of approximately 5,000 tonnes CO2 equivalents.

Challenges: The number of frequency claims has increased since 2019 despite improved communication with customers, concrete damage prevention advice and increased prices. The estimated effect is approximately 25% more frequency damage for motor vehicles, which has a negative impact on climate accounts in absolute figures.

Actions to achieve net zero emissions by 2050:

• Implementing more damage prevention measures where it has the greatest effect and contribute to reducing the number of frequency claims
• Increasing use of equivalent car parts and increased reuse of building materials

Scope: Downstream value chain (claims handling)

Time horizon: 55% intensity reduction by 2030; net zero by 2050

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Decarbonisation measures, investment portfolios

Target: Align investment portfolios with the target of global net zero emissions by 2050. All companies in the investment portfolio are expected to set emission reduction targets. Internal framework aims for 100% of the portfolio's financed emissions to be covered by credible emission reduction plans or have achieved sufficient emission reductions by 2030.

Actions taken and effects generated:

• SBTi engagement: Committed to SBTi in 2022 and submitted a short-term target for validation in 2024. Participated in two pilot projects in 2024:

  • January: Updating of the Near Term Framework from version 1.1 to 2.0
  • August-October: Version 0.1 draft of the Net Zero framework
  • November: Submitted an investment target for approval by SBTi

• Internal framework adoption: Adopted internal framework for monitoring portfolio alignment in 2021 based on methods developed by SBTi.

Actions to achieve net zero emissions in investment portfolios:

• Portfolio allocation to ensure on track with methodology for investments in companies that have adopted science-based targets
• Engaging in dialogue with managers and companies
• Conducting contribution and scenario analyses in the event of significant changes in allocations

Resources allocated:

• Payment for licences to access necessary data to estimate GHG emissions in own operations, claims handling, insured emissions and the investment portfolio
• Estimated operating expenses of approximately NOK 10 million including data licences, initiative memberships, and operational costs related to achieving net zero in own operations

Scope: Downstream value chain (investments)

Time horizon: 100% portfolio coverage by 2030; net zero by 2050

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Carbon credits and GHG removal projects

Actions: Since 2019, compensating for residual emissions from own operations by supporting emission reduction projects that also take social responsibility.

Specific projects in 2024:

• WADI by CIC and CEMAsys (Gold Standard VER): Project provides safe drinking water and reduces greenhouse gas emissions by replacing boiling water with a clean and sustainable disinfection method. Location: India.

• Fossagrim (ISO-14064-2): Carbon sequestration and storage in forests and soils. Location: Norway.

• Down to Earth (Carbon Standards International, CSI): Carbon sequestration through biochar in arable land. Location: Norway.

2024 carbon credits:

Quality standards: Gold Standard VER (92%), ISO-14064-2 (6%), Carbon Standard International CSI (2%)

Scope: Own operations (residual emissions)

Time horizon: Ongoing until 2050

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Policies supporting climate action

Insurance risk policy: Gas, oil and coal extraction (brown energy) are excluded from the risk appetite.

Responsible investment policy: Companies whose activities and strategies do not comply with the Paris Agreement must be considered excluded unless other influence efforts succeed. No investments in companies on watchlist.

Procurement policy: All suppliers required to sign Supplier Code of Conduct obliging compliance with UN Global Compact principles 7, 8, and 9 on environmental responsibility.

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Resource allocation summary

Financial resources (operational costs):

• Estimated operating expenses approximately NOK 10 million for data, licences, initiatives, and achieving net zero in own operations
• 1,765 tonnes CO2e carbon credits purchased in 2024

Non-financial resources:

• External assistance for evaluation of GHG reduction and CCS projects
• Partnerships: SBTi commitment, Fossagrim, Down to Earth, WADI by CIC, CEMAsys
• Quarterly monitoring and Board reporting mechanisms

Capital costs: Note on electric roadside assistance vehicles - current market not mature; monitoring technological developments. No specific capex estimate provided for REDGO vehicle transition.

Targets related to climate change mitigation and adaptation

Overall targets

The Board has adopted emission targets that support the Paris Agreement's 1.5°C target and the target of net zero emissions by 2050.

The targets can be summarized as follows:

• Own operations (Scope 1 and Scope 2): Emissions from own operations will be reduced by 90 per cent by 2030, with 2019 as the base year. Residual emissions must be carbon offset.

• Claims handling (Scope 3, categories 1 and 5): Emissions from claims handling are to be reduced by 55 per cent by 2050, measured in intensity, with 2019 as the base year.

• Investment portfolios (Scope 3, category 15): We will adapt our investment portfolios to global net zero emissions by 2050.

Detailed GHG emission reduction targets

Scope 1 & 2 reduction target percentage

• 90% reduction by 2030 (maintained through 2050)

Scope 3 Claims handling reduction target percentage

• 2030: 55%
• 2035: 69%
• 2040: 78%
• 2045: 85%
• 2050: 89%

Intensity target - Claims handling

Investment portfolio targets

The submitted target follows SBTi's Near Term Framework (version 2.0) and includes an emissions-weighted Portfolio Coverage target for equity and fixed-income investments where we include Scope 1, Scope 2 and Scope 3 emissions. Real estate investments are covered by an emission intensity target based on the Sectoral Decarbonization Approach.

Internal framework target: 100% of the portfolio's financed emissions to be covered by credible emission reduction plans or have achieved sufficient emission reductions by 2030.

EU Taxonomy alignment target

Operational target: 80 per cent of insurance revenue to be aligned with the non-life insurance criteria in the EU taxonomy by 2026.

Progress to date (2024)

Science-based validation

• Gjensidige committed to SBTi in 2022
• Climate targets submitted for validation by the SBTi in autumn of 2024
• Target follows SBTi's Near Term Framework (version 2.0) for financial institutions
• Target awaiting SBTi approval as of reporting date

Energy consumption and mix

Scope and methodology:
Energy consumption is based on actual consumption for electricity and district heating. Certificates of origin are purchased for the Group's electricity consumption. Conversion factors sourced from DEFRA (2024) for general calculations; electricity factors from NVE (Norway) and IEA/AIB for other locations.

Energy intensity:
Not disclosed in revenue-normalized terms for this disclosure requirement.

Renewable share: 76.3% (2024)

Gross Scopes 1, 2, 3 and Total GHG emissions

Total GHG emissions and intensity

Gjensidige reports GHG emissions based on operational control. All companies under operational control as of end-2024 are included. Conversion codes from DEFRA (2024) are used; for electricity, NVE is used. Outside Norway, location-based electricity factors are from IEA and market-based factors from AIB. ADB Gjensidige (Baltics) is included in consolidated figures despite being presented as discontinued operations in financial statements.

GHG emissions (tCO₂e)

Scope 1 GHG emissions

Based on mileage for owned and leased cars.

Scope 2 GHG emissions

Based on actual energy consumption (electricity and district heating). Guarantees of origin have been purchased for the Group's electricity consumption.

Scope 3 GHG emissions

¹ Category 15 Investments base year is 2022 (451,919 tCO₂e) and applies to Scope 1 and Scope 2 only. Scope 3 from investments is not included in the above figures but amounts to 2,948,282 tCO₂e in 2024. Target: adapt investment portfolios to global net zero emissions by 2050. For detailed emission intensity and financed emissions, see separate investments table.

Notes on material Scope 3 categories:

• Category 1 (Purchased goods and services - Claims handling) and Category 5 (Waste generated in operations): GHG emissions estimated based on a model for material consumption and waste for frequency claims (Motor and Property). Material consumption is converted into CO₂e using conversion factors (DEFRA) for different material types. Waste from claims handling is included; waste from own operations is minimal. Target: 55% reduction by 2030 (measured in intensity, base year 2019).
• Category 6 (Business travel): Air travel by employees based on Berg Hansen portal. Mileage allowance, train, taxi, bus not included but under consideration for 2025.
• Category 7 (Employee commuting): Estimated employee journeys to and from work.
• Category 15 (Investments): Base year 2022. Reported separately for the investment portfolio. Scope 3 from investments (financed emissions downstream value chain) is 2,948,282 tCO₂e in 2024 but not included in total Scope 3 above.

Categories not applicable or not material:

• Category 4 (Upstream transportation and distribution): Not separately reported.
• Category 8 (Upstream leased assets): Not applicable.
• Category 9 (Downstream transportation and distribution): Not applicable.
• Category 10 (Processing of sold products): Not applicable (multi-channel distribution covered in other categories; no physical products sold).
• Category 11 (Use of sold products): Not applicable (no physical products sold; GHG emissions related to claims included in Categories 1 and 5).
• Category 12 (End-of-life treatment of sold products): Not applicable (no physical products sold).
• Category 13 (Downstream leased assets): Not separately reported.

GHG emission intensity

Intensity metrics are calculated per net revenue (general insurance) or per FTE (own operations) or per MNOK in sales revenues (investments, WACI).

Denominator values:

• Insurance revenue (MNOK): 35,031 (2023), 38,883 (2024), +11%
• Insurance revenue from general insurance incl. Baltics (MNOK): 36,207 (2023), 40,208 (2024), +11%
• Insurance revenue from general insurance excl. Baltics (MNOK): 34,568 (2023), 38,359 (2024), +11%

Energy consumption and mix (MWh)

Biogenic CO₂ emissions

Not separately disclosed.

Regulated emissions (e.g. EU ETS)

Not disclosed.

Anticipated financial effects from material physical and transition risks and potential climate-related opportunities

Phase-in exemption statement

We have chosen the opportunity to phase in the disclosure requirement.

Disclosure requirements assessed as material with phase-in applied

The following E1-9 disclosure requirements are assessed as material but the company is applying the phase-in exemption:

Financial impacts considered in risk assessment

Financial impacts of climate change are taken into account in the solvency assessment process (ORSA) and in scenario testing.

Scenario analysis conducted

We have conducted scenario analyses to understand climate change – and its impacts – in the short, medium and long term. In our work on the transition plan, we have looked at what actions we can take to contribute to reduced emissions, as well as climate change adaptation measures.

Actions and resources related to pollution

GHG removals and GHG mitigation projects financed through carbon credits

Action description: Since 2019, the company has compensated for residual emissions from own operations by supporting emission reduction projects that also take social responsibility. The company will continue to offset known residual emissions with carbon credits until 2050, preferably in projects that reduce emissions, remove and store carbon, as well as cover social conditions.

Scope: Own operations (offsetting residual emissions)

Time horizon: Long-term (ongoing since 2019, continuing until 2050 net zero target)

Key programmes:

• Fossagrim (ISO-14064-2): Carbon removal project contributing to removing atmospheric greenhouse gases and preservation of forests
• Down to Earth (Carbon Standards International, CSI): Carbon removal project ensuring arable land receives more nutrients through biochar
• WADI by CIC and CEMAsys (Gold Standard VER): Provides safe drinking water and reduces greenhouse gas emissions by replacing boiling water with clean and sustainable disinfection method. Projects located in Norway and India.

Resources allocated:

• In 2023, carried out thorough review of various alternatives with external assistance to ensure documentation of quality and reduce corruption risk
• Follow-up evaluation conducted in 2024
• Carbon credits purchased for actual emissions in current year (not for future emissions)

Outcomes/KPIs:

Link to policy/target: Contributes to net zero emissions goal by 2050, aligned with SBTi recommendations. Also contributes to nature-based solutions for mitigating nature-related risk and climate risk.

Resource use and circular economy

Action description: In claims handling, the company looks at value chains to find solutions that contribute to less resource use. Close correlation between measures to reduce GHG emissions and measures to boost the circular economy.

Scope: Value chain (claims handling purchasing of goods and services)

Outcomes/KPIs (reported metrics):

• 16,212 tonnes of claims handling materials
• 22,918 tonnes of waste from claims handling
• 19% repair share of bodywork in Norway

Pollution of air, water and soil

ESRS E2-4 (data-point 28) is assessed as Not material by Gjensidige Forsikring.

The company has determined that the amount of each pollutant listed in Annex II of the EPRTR Regulation (European Pollutant Release and Transfer Register) emitted to air, water and soil is not material to its operations.

No quantified emissions data to air, water, or soil are disclosed.

Policies related to water and marine resources

Gjensidige Forsikring has assessed ESRS E3-1 (Water and marine resources) and all related disclosure requirements, including disclosure requirement 13 (Dedicated policy) and disclosure requirement 14 (Sustainable oceans and seas), as not material.

The company has not disclosed any specific policies related to water and marine resources in the sustainability statement excerpts provided.

Water consumption

Gjensidige Forsikring has assessed water consumption as not material.

The following E3-4 data points are explicitly listed as not material:

• ESRS E3-4, 28 c): Total water recycled and reused - Not material
• ESRS E3-4, 29: Total water consumption in m³ per net revenue on own operations - Not material

Additionally, broader water and marine resources topics are assessed as not material:

• ESRS E3-1, 9: Water and marine resources - Not material
• ESRS E3-1, 13: Dedicated policy - Not material
• ESRS E3-1, 14: Sustainable oceans and seas - Not material

No quantitative water consumption, withdrawal, discharge, or water stress data is disclosed.

Policies related to biodiversity and ecosystems

Gjensidige Forsikring has assessed the following E4-2 policy-related disclosure requirements as not material:

• Sustainable land/agriculture practices or policies (ESRS E4-2, 24 b)
• Sustainable oceans/seas practices or policies (ESRS E4-2, 24 c)
• Policies to address deforestation (ESRS E4-2, 24 d)

The company has not disclosed any specific policies related to biodiversity and ecosystems. The materiality assessment indicates that these policy areas are not considered material to the company's operations.

Targets related to circular economy

The document index references E5-3 (Targets related to resource use and circular economy) on page 115, but the provided excerpts do not contain the actual content from that page. Only the table of contents is shown, which indicates that E5-3 disclosure exists in the report but is not included in the excerpts provided.

No specific targets, target values, baseline years, target years, or other target-related information can be extracted from the available excerpts.

ESRS E5-4 Resource Inflows

Gjensidige discloses resource inflows related to its material consumption from claims handling activities. The company has developed models to calculate material consumption in complex processes involving many suppliers and partners, focusing on the most common claims for motor and property insurance.

Material Consumption from Claims Handling

The following table presents total material consumption from claims handling for frequency claims:

Total material consumption increased from 12,685 tonnes in 2019 to 16,212 tonnes in 2024, representing a 28% increase (3,526 tonnes). Materials such as plasterboard, chemicals, wood and glass in particular showed the largest percentage changes from the 2019 baseline.

Methodology

The calculation of total material consumption does not provide an exact figure, but based on a materiality assessment, the company believes it gives the best estimate of current resource use. Cash settlements are generally held outside the model as the company has no control over customer spending decisions.

Motor Claims Material Consumption

For motor vehicles, the following materials are included:

• Glass
• Steel
• Aluminium
• Plastic
• Batteries
• Reuse of car parts based on estimates
• Use of new car parts generates equivalent recyclable waste
• Scrap waste based on recycling of materials such as glass, aluminium and steel

Vehicle write-offs are settled in cash. Based on the official registration system (TFF), the company assumes 22% of written-off cars are replaced by new cars (28% in 2019).

Property Claims Material Consumption

Fire damage assumptions include:

• Replacing floors and walls
• Cleaning and painting surfaces
• Electronics
• Waste corresponding to consumption of new materials

Water damage assumptions include:

• Plain kitchen cabinet fronts
• Parquet flooring
• Repair as a result of water seeping through the floor
• Waste corresponding to consumption of new materials

Materials included in property claims accounts:

• Wood
• Plasterboard
• Insulation
• Paint
• Plastic
• Electronics

Reuse and Circular Economy Measures

The company tracks reuse of equivalent car parts and repair rates as part of its circular economy efforts:

Reuse of equivalent car parts:

• Norway: 3% (2024), up from 1% (2019)
• Sweden: 9% (2024), down from 13% (2019)
• Denmark: 5% (2024), up from 3% (2019)
• Lithuania (Baltics): 41% (2024)

Repair rate (bodywork):

• Norway: 19% (consistent 2019-2024)
• Sweden: 19% (consistent 2019-2024)
• Denmark: 23% (2024)
• Lithuania (Baltics): 13% (2024)

Waste

Gjensidige's waste reporting focuses on waste generated through their claims handling activities rather than operational waste:

Waste from Claims Handling:

• Model for estimating GHG emissions associated with Motor and Property frequency claims provides estimates starting from materials and waste
• Waste is converted into greenhouse gas emissions using conversion factors
• Defined targets for reducing GHG emissions from claims handling by 55% annually by year-end 2030, measured in carbon intensity
• Reduced greenhouse gas emissions by 861 tonnes since 2019
• Reduced intensity by 41%, which is 11% better than the target for 2024

Waste Management Approach:

• Focus on waste reduction through damage prevention measures to reduce number of frequency claims
• Promote reduction of waste through group-wide procurement policy
• Require sustainable deliveries from suppliers and partners
• Work to increase repair rates rather than replacement, reducing waste generation
• Target of achieving net zero emissions in claims handling by 2050 includes focus on waste reduction
• Estimated effect of increased repair and reuse: reduction of 4,000-8,000 tonnes GHG emissions

Operational Waste:

• The company requires suppliers to increase waste sorting levels
• Achieve BREEAM In-Use certification for all active properties (includes waste management criteria)
• No quantitative disclosure of total operational waste generated, hazardous vs non-hazardous split, or waste diversion rates for own operations

The reporting focuses on waste prevention and indirect waste through claims rather than comprehensive operational waste metrics.

Policies related to own workforce

Gjensidige has several policies related to its own workforce, based on the 10 UN Global Compact Principles, the UN Convention on Human Rights, ILO international standards on human and labour rights, the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines on Responsible Business Conduct.

Code of Conduct

Scope: Applies to Gjensidige Forsikring ASA and its subsidiaries. All employees must comply with the Code of Conduct.

Governance: Adopted by the CEO. The Executive Vice President of People & Communication owns the policy and the Executive Vice President of Employee Responsibility has management responsibility.

Key content: The Code of Conduct ensures that all employees act in a way that maintains trust in the Company. All activities must stand up to public scrutiny. It forms the basis for good corporate culture, correct behaviour and a good reputation. Employees must act with due care, honesty and objectivity, and must refrain from doing anything that could undermine people's trust in the Group.

Public availability: Available on the Company's website at gjensidige.com.

International standards: Based on high ethical standards and corporate governance in accordance with best practice. Part of the Company's commitment to the 10 UN Global Compact Principles.

Monitoring: Notification channels have been established for reporting and following up incidents. ESG risk (sustainability risk) is integrated into Gjensidige's risk management framework. The risk of criminal offences and violations is monitored as part of the internal control system.

Corporate governance policy

Scope: Applies to the entire Gjensidige Forsikring ASA organisation and subsidiaries.

Governance: Adopted by the Board. The CEO has overall responsibility for following up the policy in the organisation.

Key content: Ensures that employees fulfil their responsibilities and tasks. Includes a separate section on adequate wages and training and skills development. Gjensidige employs a learning and development model in which skills are developed by practising day-to-day tasks, based on organised tuition and training. All frontline customer service staff must be certified. The pay policy is to offer employees competitive, but not leading pay conditions. Wage growth is based on central negotiations and local negotiations with trade unions. Fixed basic salary is the main element of overall remuneration, with variable remuneration based on both qualitative and quantitative goals. Compliance with external and internal regulations, including the Code of Conduct and values, is a prerequisite for payment.

Monitoring: The Board has overall responsibility for ensuring that the Group is managed responsibly, including responsibility for strategy, finances, the environment, social conditions and compliance with laws and regulations.

Inclusion, diversity and belonging policy

Scope: Applies to Gjensidige Forsikring ASA and its subsidiaries.

Governance: The Executive Vice President of People & Communication has overall responsibility for this in the organisation.

Key content: Provides a framework for efforts to attract, identify, develop and include broad diversity among employees. Work on diversity should be about drawing on each other's differences, acknowledging employees' knowledge, skills and strengths, regardless of potential grounds for discrimination such as gender, pregnancy, leave of absence for childbirth or adoption, care responsibilities, ethnicity, religion, beliefs, functional impairment, sexual orientation, gender identity and gender expression. A corporate culture marked by diversity, inclusion and belonging will make Gjensidige a more attractive and responsible employer.

Note: The policy does not include specific strategies to combat differential treatment and discrimination. The Company states it will focus on this in 2025.

Personnel Handbook and HSE Handbook

Scope: Apply to employees. REDGO has its own Personnel Handbook and HSE Handbook.

Key content: Describe matters related to pay, holidays, leave and other rights, and health, safety and the environment for employees.

Note: Gjensidige does not have a specific policy for work-life balance and health and safety, but these topics are covered in dedicated handbooks.

Sustainability policy

Scope: Applies to Gjensidige Forsikring ASA and its subsidiaries.

Governance: Adopted by the CEO. The Executive Vice President of Analysis, Product and Price owns the policy and the Group's sustainability department monitors compliance.

Key content: Sets out principles and guidelines for how the Company should address social factors, including human and labour rights, and corporate governance in all activities. The policy refers to the 10 UN Global Compact principles, the UN Convention on Human Rights, the ILO's basic standards for human and labour rights, the UN Guiding Principles for Business and Human Rights and the OECD Guidelines for Responsible Business, the UN Principles for Sustainable Insurance (UN PSI), and the UN Principles for Responsible Investment (UN PRI).

International standards: Compliance with the above ensures that human and labour rights are respected throughout the Group and in the value chain.

Monitoring: The policy provides an important framework for identifying and mitigating incidents and actions against the impacts and risks described.

Policy for handling irregularities and malpractices, including corruption

Scope: Applies to Gjensidige Forsikring ASA and its subsidiaries.

Governance: Adopted by the CEO. The Chief Risk Officer owns the policy and the head of SIU (Internal Investigation Unit) has management responsibility.

Key content: Describes the procedures for and who is responsible for following up and dealing with irregularities and malpractices, including corruption. Ensures that such matters are investigated in an ethical, objective, uniform and satisfactory manner in accordance with the law and internal guidelines. There is an increased risk of corruption and bribery in areas that involve contact with customers, suppliers and partners.

Monitoring: The Company has zero tolerance for corruption. Notification channels have been established in all countries where Gjensidige operates for reporting irregularities, malpractices, corruption, money laundering etc. Reports can be made anonymously through an external notification channel (portal.mittvarsel.no). Reports are dealt with by the Internal Investigation Unit. Quarterly reports on irregularities and malpractices are submitted to the Board.

Policy for the processing of personal data

Scope: Applies to the entire Gjensidige Forsikring ASA organisation and its subsidiaries.

Governance: Adopted by the CEO. The Chief Compliance Officer owns the policy and the Data Protection Officer in Norway has management responsibility.

Key content: Sets out detailed requirements for the processing of personal data, and ensures compliance with the applicable data protection rules. Personal data shall only be processed if there is a legal basis for such processing.

Operational risk policy

Scope: Applies to the entire Gjensidige Forsikring ASA organisation and subsidiaries.

Governance: Adopted by the Board. The CEO owns the policy and has management responsibility.

Key content: Defines information security as an operational risk. Operational risk management is part of the company's overall risk management and forms an integral part of the Group's corporate governance. Establishes requirements and principles for the management of operational risk, including for areas that represent a higher operational risk, such as information security.

Information security and resilience policy

Scope: Applies to the entire Gjensidige Forsikring ASA organisation and subsidiaries.

Governance: Adopted by the Board. The CEO is responsible for information security in Gjensidige. Group Security is a second-line function led by the Chief Security Officer, who supports and assists the CEO in the exercise of this responsibility.

Key content: Defines information security and principles for resilience as part of Gjensidige's framework for risk management of information and communication technology (ICT). The goal is to protect Gjensidige's information assets and ensure that the risk management related to information security is of a high standard and in accordance with the applicable regulations.

Artificial Intelligence policy

Scope: Applies to the entire Gjensidige Forsikring ASA organisation and subsidiaries.

Governance: Adopted by the CEO. The Executive Vice President of Analysis, Product and Price owns the policy and the AI Risk Officer has management responsibility.

Key content: Sets out the overall requirements and principles for work on artificial intelligence. Ensures that Gjensidige uses artificial intelligence in a trust-based and ethical manner, and that the Company complies with the applicable internal and external requirements. Based on the principles of proportionality, fairness and non-discrimination, transparency and explainability, human oversight, data governance and documentation, robustness and performance.

Taking action on material impacts on own workforce

Skills Development and Career Progression

Internal job portal

• Aimed at making employees aware of potential career paths, while meeting the Company's need for critical and necessary skills
• Mainly relevant in the insurance profession and technology
• Conducts training programmes with external training and work placements

Internal mentoring programme

• Helps build skills, leadership and the desired culture through the use of role models
• Participants are selected talents aiming for a career among the organisation's discipline or managerial staff
• Mentors are experienced managers or experts
• Contributes to exchange of experience, sharing of best practices and networking across divisions and countries

Training relating to different roles and job categories with certification schemes

Gjensidige Customer and Brand School

• Held many courses and training programmes throughout the year
• Enables employees to develop their skills
• All advisors go through a comprehensive certification programme to meet customer needs in a structured manner

Internship scheme

• Students gain relevant work experience by working part time, in 20% of a full-time position for a whole academic year
• In 2024: 15 interns in different departments in the Group

Graduate programme

• Runs for one year
• Helps promote Gjensidige as an attractive employer while contributing to innovation and networking across the organisation

Gjensidige Day

• 60 students given an opportunity to learn more about the company

Presence at recruitment events

• Present at over 30 different events during the year

Denmark student employment

• Employed more than 130 student assistants working between 50 and 100 hours a month during the year
• In 2024, organised a joint event for the whole student group to enable them to build networks and learn about potential career opportunities after graduation

Health and Well-being

Webinars on health and well-being at work

• Women's health was a particular focus area in 2024

Activities to enhance inclusive corporate culture

• Marked World Mental Health Day
• Marked International Women's Day
• Marked Pride

Diversity and Inclusion

Women in Finance Charter endorsement

• Undertaken to set internal targets for management and specialist-level gender balance
• Goal attainment is linked to managers' variable remuneration

Diversity Charter Denmark

• Signed charter and support their vision to increase the proportion of women and diversity in technology

LGBT+ network participation

Collaboration with Seema

• Leading expert group in the Nordic region
• To gain better understanding of diversity management as a competitive advantage

Diversity-focused webinars

• Held for employees

Diversity awareness initiatives

• Multi-religious holiday calendar published
• Glossary of LGBT terms ('Skeiv fra A-Å')
• Suggestions for relevant podcasts
• Ramadan facilitation reminders sent to managers

Diversity in recruitment processes

• Thorough review of necessary skills (both professional and personal) with focus on diversity and team composition
• Replaced ordinary application letters with job-specific screening questions
• Introduced skills-based second-round interviews as a rule
• Norwegian language lessons offered to prevent lack of language skills standing in the way of hiring qualified candidates
• Prepared checklist for use in recruitment

Diversity measurement and monitoring

• Measure gender balance in management teams
• Employee surveys as management tools to map and work systematically on diversity
• Reputation and customer surveys

Employee Engagement

Regular employee engagement measurement

• Measured on a regular basis to identify challenges to address
• Monitoring under category 'Self-determination' for work-life balance

Expected Outcomes / Targets

The following targets are set (applying to Gjensidige Forsikring ASA, Gjensidige Business Services AB, Gjensidige Pensjonsforsikring AS and Gjensidige Mobility Group AS):

Characteristics of non-employees in the undertaking's own workforce

Non-employees in own workforce

Gjensidige reports non-employee workers in its own workforce, broken down by type:

Methodology

The numbers appear to be reported as headcount. The company distinguishes between two categories of non-employee workers: self-employed people and employment activities (which likely refers to agency workers or similar temporary arrangements).

Collective bargaining coverage and social dialogue

Collective bargaining coverage

A large proportion of Gjensidige's employees are covered by collective agreements that are negotiated between the unions and the undertaking.

All employees have full freedom of association, and trade unions are free to recruit members from among the staff. The undertaking supports freedom of association and recognises the importance of employees joining trade unions to safeguard their rights.

Goal: The minimum wage must follow the collective agreements in the industry.

Progress: No salaries is below the agreed minimum wage in the collective bargaining agreements for 2024.

Works councils and employee representation

Gjensidige has a structured cooperation with employee representatives, who meet regularly with the senior group management. The cooperation between the undertaking's management and the employees' trade unions is systematic and good, and it is based on a well-established structure with regular meetings.

Working Environment Committee (AMU): Four AMU meetings are held each year. The committee includes both employer and employee representatives and is involved in the planning and organisation of HSE work.

Works Council (SU): Four Works Council meetings are held each year. The Works Council discusses material changes planned in the organisation and measures relating to employment and working conditions for large groups of employees. The employee representatives take part in appointment processes and in the annual local salary process.

Diversity and equality committee: In accordance with the Basic Agreement between Finance Norway and the Finance Sector Union, a diversity and equality committee has been appointed with an equal number of representatives from the employee and the employer side.

Under Norwegian law, employees of the Group are entitled to be represented on the Company's governing bodies. Employee representatives are elected by and from among the employees.

The undertaking's management maintains a close dialogue with union representatives in connection with restructuring processes. The undertaking regularly invites employee representatives to informal meetings, and they also have arenas for engaging with relevant members of the senior group management. Union representatives are paid by the undertaking.

International frameworks

Gjensidige recognises the International Labour Organization (ILO) and OECD conventions and supports their promotion of decent work based on social justice and internationally recognised labour rights.

Diversity metrics

Gender distribution at top management level

Note: For Gjensidige Forsikring ASA, senior management is defined as the CEO, group management and managers who report directly to the group management. For subsidiaries, senior management is defined as the enterprise's general manager and managers who report directly to the general manager.

Gender distribution on the Board

Age band distribution of total workforce

Adequate wages

Benchmark used

Gjensidige benchmarks adequate wages against collective bargaining agreements in the industry, not a living wage standard.

Goal stated: "The minimum wage must follow the collective agreements in the industry."

Progress reported (2024): "No salaries is below the agreed minimum wage in the collective bargaining agreements for 2024."

Coverage and scope

The disclosure covers own employees in Norway, Sweden, and Denmark (the reporting focuses on Gjensidige Forsikring ASA, Gjensidige Bank ASA, Gjensidige Pensjon og Sparing Holding AS, Gjensidige Business Services AB, Gjensidige Pensjonsforsikring AS and Gjensidige Mobility Group AS).

100% compliance is reported: no employee salary falls below the agreed minimum wage in collective agreements.

Other wage-related measures

Gjensidige describes several measures to ensure competitive wages:

• Structured wage processes to offer competitive salaries
• Separate procedures for increasing salaries of employees on parental leave to ensure they do not lose out on wage growth
• Overtime pay for work beyond agreed hours, or flexitime accumulation
• Thorough training of managers to ensure well-organised wage processes

The company notes that "the last few years have been characterised by relatively high price growth, high interest rates and low unemployment" and aims to "ensure a reasonable wage growth that counteracts the risk of staff turnover."

Value chain

Gjensidige identifies adequate wages as a material topic for workers in the value chain. The company states it "may procure goods and services from suppliers who exploit employees" and notes potential negative impacts including "lower margins for suppliers, which can lead to lower wages for their employees and social dumping." However, no specific living wage benchmark, assessment coverage, or targets are disclosed for value chain workers.

Methodology

No living wage calculation methodology is disclosed. The benchmark is compliance with collective bargaining agreement minimum wages, not a living wage standard that covers basic living needs for workers and their families.

Social protection

Family-related leave coverage

All Gjensidige employees are entitled to family-related leave in accordance with national law and/or collective agreements. Such leave includes maternity leave, paternity leave, parental leave and care leave.

Percentage of employees who took family-related leave:

Wage protection during parental leave

Gjensidige has separate procedures for increasing the salaries of employees who take parental leave to ensure they do not lose out in relation to wage growth.

Additional social protection measures

Work-life balance and health support:

• Summer-time scheme in Norway with shorter working hours (average 36.75 hours/week) during May-September for non-shift workers
• Part-time schemes in Denmark for senior employees and parents with maintained pension earnings
• Overtime pay or flexitime accumulation for work beyond agreed hours
• Annual flu vaccines offered to employees
• Psychological assistance offered to ensure employee well-being and health
• Active company sports clubs and training facilities at several offices
• Templates prepared for managers to use in dialogue with employees regarding pregnancy, parental leave and sickness absence

Country-specific schemes

Denmark:

• Part-time schemes for senior employees without losing pension earnings
• Part-time schemes for parents without losing pension earnings
• Additional administrative days off beyond statutory/contractual holidays

Norway:

• Summer-time scheme (shorter hours May-September)
• Additional administrative days off beyond statutory/contractual holidays

Training and skills development metrics

Average training hours per employee

Performance and career development reviews

Methodology notes

The number of full-time equivalents (FTE) is calculated by summing up the number of working hours for full-time and part-time employees, and dividing by the standard number of working hours for an entire position. At Gjensidige, standard working hours are 36.75 hours per week (40 hours winter/35 hours summer). The number includes permanent and temporary employees, as well as employees without guaranteed working hours.

Key policies and initiatives

Gjensidige employs a learning and development model in which skills are developed by practicing day-to-day tasks, based on organised tuition and training. All frontline customer service staff must be certified.

The company has established the Gjensidige Academy with the goal of developing a unique management and skills culture. Strategic partnerships exist with BI Norwegian Business School and the Norwegian School of Economics (NHH). Various training programmes are offered aimed at making employees aware of potential career paths while meeting the Company's need for critical skills.

Gjensidige has an internal mentoring programme that helps build skills, leadership and the desired culture through the use of role models.

Goal: 100 per cent implementation of compulsory courses related to IT security and money laundering.

Progress: Of compulsory courses distributed to employees in 2024, 88 per cent have passed. The company is continuously working on increasing the implementation rate to reach the goal.

Health and safety metrics

Coverage of health and safety management system

100% of own workforce is covered by the undertaking's occupational health and safety management system based on statutory requirements and/or recognised standards or guidelines.

Health and safety metrics

Notes on fatalities and scope

There have been no deaths as a result of work-related injuries or ill health, neither for the company's own workforce nor for other employees working in Gjensidige's locations.

The number of days lost increased by 110 days in 2024, mainly due to work-related accidents such as falls and lifting injuries. All accidents are taken seriously and followed up as part of HSE work, with measures implemented to prevent similar accidents from happening in the future.

The metrics cover employees registered in the individual undertakings' HR systems. The company has exercised the option of phasing in disclosure requirements that apply to non-employees, with the exception of headcount tables.

Work-life balance metrics

Employees entitled to and taking family-related leave

All Gjensidige employees are entitled to family-related leave in accordance with national law and/or collective agreements. Such leave includes maternity leave, paternity leave, parental leave and care leave.

Work arrangements and flexible working policies

The company reports the following measures to support work-life balance:

• Summer-time scheme in Norway with shorter working hours (36.75 hours average per week) during May to September
• Part-time schemes for senior employees and parents in Denmark
• Additional administrative days off beyond statutory/contractual holidays in all countries
• Flexible working arrangements and overtime compensation or flexitime accumulation
• Blended learning opportunities to reduce travel

Work-life balance monitoring

Gjensidige tracks work-life balance through employee surveys under the category "Self-determination", with a score of 8.9 in December 2024 (an increase of 0.1 points from 2023).

Note: The disclosure provides the percentage of employees who took family-related leave but does not specify the percentage of employees entitled to such leave (all employees are stated to be entitled). Return-to-work rates after parental leave are not disclosed.

Compensation metrics (ESRS S1-16)

Pay gap

The pay gap between women and men shows a positive development since last year and is on a par with the pay gap in the financial industry in general. The main reason for the pay gap is partly due to the fact that there are still more men than women in senior management, which contributes to pulling up the average salary of men.

The work to ensure equal pay for equal work is important to us. We have mapped why there are differences in pay in certain groups, and the differences are mainly related to differences in experience, education and how difficult it is to recruit for the positions. We will continue to analyse this material to ensure that we do not have discriminatory elements in our remuneration policy.

Remuneration ratio

Methodology

The annual total remuneration ratio for the highest paid person in relation to the median value of annual total remuneration for all employees is calculated by dividing the salary of the highest paid person in the entire Group by a weighted average of the median salary minus the highest salary, for all employees in the entire Group.

Incidents, complaints and severe human rights impacts

According to the ESRS disclosure index:

The company has assessed incidents of discrimination and non-respect of UN Guiding Principles on Business and Human Rights and OECD Guidelines as not material for reporting purposes. No quantitative metrics for incidents, complaints, severe human rights impacts, or fines/sanctions related to S1-17 are disclosed.

Policies related to value chain workers

Gjensidige has established policies to address workers' rights in its value chain, particularly through supplier requirements and responsible investment practices.

Procurement Policy

Scope: Applies to Gjensidige Forsikring ASA and subsidiaries

Governance:

• Adopted by the CEO
• Chief Procurement Officer is responsible for following up compliance

Key content:

• Sets requirements and defines roles and responsibilities in the procurement process
• Ensures appropriate assessments of risks related to compliance with human rights as described in the UN Global Compact principles and labour rights (ILO) in accordance with the Transparency Act
• All suppliers must sign a Supplier Code of Conduct (available on website)

Links to international standards:

• UN Global Compact principles (minimum requirement)
• ILO labour rights
• UN Guiding Principles on Business and Human Rights (referenced in context of Transparency Act)

Public availability: Supplier Code of Conduct is available on the company website

Supplier Code of Conduct

Scope: All suppliers

Key content: Suppliers confirm they will:

• Ensure that guidelines relating to internationally recognised principles for human and labour rights are complied with and make the same requirements of their sub-suppliers
• Ensure products delivered are of high environmental quality, comply with the precautionary principle, and implement environmental technology as far as possible
• Comply with ethical requirements, including anti-corruption

Links to international standards:

• 10 UN Global Compact principles (minimum requirement)
• Internationally recognised principles for human and labour rights

Public availability: Available on the company website

Monitoring:

• Companies providing services in connection with claims payments for damaged buildings in Norway must be certified in Startbank
• Startbank requires suppliers to document how they work on HSE, pay and working conditions, and insurance schemes for employees
• For other procurement categories, the internal procurement organisation performs similar controls
• Follow-up of results in dialogue with suppliers

Policy for Nature and Biodiversity

Scope: Value chain considerations

Governance:

• The area of responsibility Analysis, Product and Price owns the policy
• Group's sustainability department monitors compliance

Key content:

• Establishes principles for addressing potential negative impacts on the natural environment in the value chain
• Contributes to reducing nature-related risk through goals and measures that limit use of materials and reduce waste
• Encourages reuse and ensures resources used are renewable
• Minimum requirement is compliance with the 10 UN Global Compact principles to protect the environment
• Requires highest possible repair rate, reuse of equivalent parts in replacements, partial repairs for property damage, and stringent recycling requirements

Links to international standards:

• 10 UN Global Compact principles (environmental principles)

Monitoring:

• Results are followed up in dialogue with suppliers
• Stringent requirements of suppliers' waste management and measures to ensure maximum recycling

Policy for Responsible Investments

Scope: Applies to Gjensidige Forsikring ASA and its subsidiaries

Governance:

• Adopted by the CEO based on principles established by the Board

Key content:

• Ensures investments achieve the highest possible long-term return while respecting ethical and environmental principles
• Asset management based on ensuring minimum requirements for human and labour rights are met
• Companies with material violations not handled in a trustworthy manner will be excluded from investments
• Those responsible for asset management must analyse sustainability-related issues, including human and employee rights, in connection with all decisions

Links to international standards:

• 10 UN Global Compact Principles
• OECD Guidelines for Multinational Enterprises
• UN Guiding Principles on Business and Human Rights
• UN PRI recommendations

Monitoring:

• Framework to ensure necessary investigations and control of companies invested in to safeguard workers' rights in the value chain
• If material violations uncovered that are not handled trustworthy, company excluded from investments

Policies related to affected communities

The company references ESRS S3-1 disclosure requirement 16 (Human rights policy commitments) on page 119 of its sustainability statement. However, the excerpts provided do not contain the actual policy content from page 119.

Based on the index table, the company indicates it has addressed:

• Human rights policy commitments (ESRS S3-1, DR 16) - referenced on p. 119
• Non-respect of UNGPs on Business and Human Rights, ILO principles or OECD guidelines (ESRS S3-1, DR 17) - marked as "Not material"

Without access to page 119, the specific policy details including policy name, scope, governance, content, public availability, links to international standards, and monitoring mechanisms cannot be extracted from the provided excerpts.

Policies related to consumers and end-users

The excerpts provided do not contain the actual content of ESRS S4-1 disclosure on page 140. The references indicate that:

• Page 140 contains the S4-1 disclosure on "Policies related to consumers and end-users"
• There is a cross-reference to G1-1 "Corporate culture and business conduct policies" on pages 148-149
• The company confirms in the datapoint table that it has "Policies related to consumers and end-users" (datapoint 16) on page 140
• The company indicates "Not material" for "Non-respect of UNGPs on Business and Human Rights and OECD guidelines" (datapoint 17)

However, the actual policy content, names, scope, governance, and other details required by ESRS S4-1 are not included in the provided excerpts. To complete this extraction, the full content from pages 140, 148-149 would be needed.

Taking action on material impacts on consumers

Voluntary operational climate adaptation target

Action description:
Operational target adopted by the Board that 80 per cent of the insurance revenues that can qualify under the EU Taxonomy shall be adjusted by the end of 2026.

Scope:
Own operations (insurance product portfolio)

Time horizon:
Medium-term (target deadline: end of 2026)

Resources allocated:
Not specified

Expected outcomes:

• More comprehensive picture of insurance coverage, as climate risk has a broad scope
• Products include wide range of climate-relevant risks
• Standard products with wide range of coverage and/or "all risk"

Link to policy/target:
Linked to EU Taxonomy compliance and climate adaptation

---

Climate-adapted insurance products

Action description:
Adaptation of insurance products to meet EU Taxonomy's technical criteria for non-life insurance. By end of 2024, seven insurance products have been adapted.

Scope:
Downstream (consumer-facing products)

Time horizon:
Short to medium-term (seven products adapted by end of 2024, with continuation towards 2026 target)

Resources allocated:
Not specified

Expected outcomes/features:

• Products ensure customers are insured against relevant climate-related damages
• Customers are encouraged to climate-adapt their assets to reduce risk of damage
• More robust ways to rebuild through adapted products to avoid recurrent damage
• Share relevant data with authorities

Link to policy/target:
Linked to operational target of 80% taxonomy-aligned revenues by 2026 and EU Taxonomy compliance

Business conduct policies and corporate culture

Gjensidige has established several policies to ensure high ethical standards, good corporate governance, and responsible business conduct. The company's approach is based on the 10 UN Global Compact principles, the UN Convention on Human Rights, ILO international standards, UN Guiding Principles on Business and Human Rights, and OECD Guidelines on Responsible Business Conduct. The company has also signed the UN Principles for Sustainable Insurance (UN PSI) and UN Principles for Responsible Investment (UN PRI).

Code of Conduct

Scope: Applies to Gjensidige Forsikring ASA and its subsidiaries.

Governance: Adopted by the CEO. The Executive Vice President of People & Communication owns the policy and the Executive Vice President of Employee Responsibility has management responsibility.

Key content: The Code of Conduct forms the basis for a good corporate culture, correct behaviour and a good reputation. All employees must act with due care, honesty and objectivity, and must refrain from doing anything that could undermine people's trust in the Group. Managers have a particular responsibility and must be good role models. All employees are covered by this Code, while suppliers are covered by the Supplier Code of Conduct.

Public availability: Available on the company website.

International standards: Based on the 10 UN Global Compact principles, UN Convention on Human Rights, ILO's basic standards for human and labour rights, UN Guiding Principles for Business and Human Rights, OECD Guidelines for Responsible Business, UN Principles for Sustainable Insurance (UN PSI), and UN Principles for Responsible Investment (UN PRI).

Monitoring: All employees must complete a course in ethics annually and confirm familiarity with the Code of Conduct in their performance appraisal interview. Regular refresher courses are provided. The status of ethics is included in the six-monthly senior management follow-up ('People Review').

Corporate governance policy

Scope: Applies to the entire Gjensidige Forsikring ASA organisation and subsidiaries.

Governance: Adopted by the Board. The CEO has overall responsibility for following up the policy in the organisation.

Key content: Ensures that employees fulfil their responsibilities and tasks. Includes a section on adequate wages and training and skills development. Variable remuneration for senior group management is performance-based, with 50 per cent paid in the form of a share scheme over three years. The policy emphasizes compliance with external and internal regulations, including the undertaking's Code of Conduct and values.

Monitoring: All permanent employees have the opportunity to participate in Gjensidige's share savings programme. Compliance with the Code of Conduct and values is a prerequisite for payment of variable remuneration.

Policy for handling irregularities and malpractices, including corruption

Scope: Applies to Gjensidige Forsikring ASA and its subsidiaries.

Governance: Adopted by the CEO. The Chief Risk Officer owns the policy and the head of SIU (Internal Investigation Unit) has management responsibility.

Key content: Describes procedures and responsibilities for following up and dealing with irregularities and malpractices, including corruption. Zero tolerance of corruption, bribery, facilitation payments and gifts that may influence decisions. Ensures that such matters are investigated in an ethical, objective, uniform and satisfactory manner in accordance with the law and internal guidelines.

International standards: References the United Nations Convention against Corruption.

Monitoring: The Internal Investigation Unit is responsible for uncovering corruption and investigating concrete cases. Quarterly reports on irregularities and malpractices are submitted to the Board. The programme is revised annually.

Instructions for gifts and hospitality activities

Scope: Applies to Gjensidige Forsikring ASA and its subsidiaries.

Governance: Adopted by the CEO. The Executive Vice President of People & Communication owns the instructions and the Executive Vice President of Employee Responsibility has management responsibility.

Key content: Employees may not accept gifts worth more than NOK 600. Regardless of value, gifts must not be accepted if they compromise impartiality or independence. Special rules apply to employees with responsibility for customer and supplier relations. All gifts and hospitality activities must be registered in the Group's gift and hospitality register.

Monitoring: All gifts and hospitality activities are registered and monitored through the Group's gift and hospitality register.

The anti-corruption handbook

Scope: Based on the policy for handling irregularities and malpractices, including corruption.

Key content: Focuses on awareness-raising and preventive activities. Defines corruption with examples, highlights situations requiring extra vigilance, encourages good choices, and defines guidelines for employees, managers and partners. Zero tolerance for bribes or facilitation payments. Rules apply to managers and employees at all levels, also in countries where Norwegian law does not apply.

Public availability: Available at gjensidige.com, on the intranet and in e-learning courses.

Monitoring: The anti-corruption programme consists of three main elements: roles with special responsibility, preventive activities, and controls and detection mechanisms. The programme is revised annually.

Policy for the processing of personal data

Scope: Applies to the entire Gjensidige Forsikring ASA organisation and its subsidiaries.

Governance: Adopted by the CEO. The Chief Compliance Officer owns the policy and the Data Protection Officer in Norway has management responsibility.

Key content: Sets out detailed requirements for processing personal data and ensures compliance with applicable data protection rules. Personal data shall only be processed if there is a legal basis. The most common grounds are need to fulfil an agreement with the customer or an employment contract with the employee. Special grounds are required for processing sensitive personal data.

Monitoring: Compliance is monitored through the compliance function and internal control procedures.

Operational risk policy

Scope: Applies to the entire Gjensidige Forsikring ASA organisation and subsidiaries.

Governance: Adopted by the Board. The CEO owns the policy and has management responsibility.

Key content: Information security is defined as an operational risk. Operational risk management is part of the company's overall risk management and forms an integral part of the Group's corporate governance. Establishes requirements and principles for the management of operational risk, including for areas that represent a higher operational risk such as information security.

Monitoring: Integrated into the Group's risk management framework with regular monitoring and reporting to the Board.

Information security and resilience policy

Scope: Applies to Gjensidige Forsikring ASA and its subsidiaries.

Governance: Adopted by the Board. The CEO is responsible for information security in Gjensidige. Group Security is a second-line function led by the Chief Security Officer, who supports and assists the CEO. The function is independent of day-to-day security operations.

Key content: Defines information security and principles for resilience as part of Gjensidige's framework for risk management of information and communication technology (ICT). The goal is to protect Gjensidige's information assets and ensure that risk management related to information security is of a high standard and in accordance with applicable regulations.

Monitoring: Group Security, as a second-line function, monitors compliance and assists the CEO in exercising responsibility for information security.

Artificial Intelligence policy

Scope: Applies to the entire Gjensidige Forsikring ASA organisation and subsidiaries.

Governance: Adopted by the CEO. The Executive Vice President of Analysis, Product and Price owns the policy and the AI Risk Officer has management responsibility.

Key content: Sets out overall requirements and principles for work on artificial intelligence. Ensures that Gjensidige uses AI in a trust-based and ethical manner and complies with applicable internal and external requirements. Based on principles of proportionality, fairness and non-discrimination, transparency and explainability, human oversight, data governance and documentation, and robustness and performance.

Monitoring: The AI Risk Officer has management responsibility for monitoring compliance. All employees must complete an introduction to 'AI governance and ethics' course.

Inclusion, diversity and belonging policy

Scope: Applies to Gjensidige Forsikring ASA and its subsidiaries.

Governance: The Executive Vice President of People & Communication has overall responsibility.

Key content: Provides a framework for efforts to attract, identify, develop and include broad diversity among employees. Work on diversity should be about drawing on each other's differences and acknowledging employees' knowledge, skills and strengths, regardless of potential grounds for discrimination such as gender, pregnancy, leave, care responsibilities, ethnicity, religion, beliefs, functional impairment, sexual orientation, gender identity and gender expression.

Note: The policy does not include specific strategies to combat differential treatment and discrimination; the company plans to focus on this in 2025.

Sustainability policy

Scope: Applies to Gjensidige Forsikring ASA and its subsidiaries.

Governance: Adopted by the CEO. The Executive Vice President of Analysis, Product and Price owns the policy and the Group's sustainability department monitors compliance.

Key content: Sets out principles and guidelines for addressing social factors, including human and labour rights of workers in the value chain, and corporate governance in all activities. Provides framework for identifying and mitigating incidents and actions against impacts and risks.

International standards: References the 10 UN Global Compact principles, UN Convention on Human Rights, ILO's basic standards for human and labour rights, UN Guiding Principles for Business and Human Rights, OECD Guidelines for Responsible Business, UN Principles for Sustainable Insurance (UN PSI), and UN Principles for Responsible Investment (UN PRI).

Monitoring: The Group's sustainability department monitors compliance.

Procurement policy

Scope: Applies to Gjensidige Forsikring ASA and subsidiaries.

Governance: Adopted by the CEO. The Chief Procurement Officer is responsible for following up compliance.

Key content: Sets requirements and defines roles and responsibilities in the procurement process. All suppliers must sign a Supplier Code of Conduct obliging them to comply with the 10 UN Global Compact principles as a minimum, including environmental principles and ethical requirements such as anti-corruption. Companies providing claims-related services in Norway must be certified in Startbank.

International standards: Requires compliance with the 10 UN Global Compact principles, UN Convention on Human Rights, ILO standards on labour rights, in accordance with the Transparency Act.

Public availability: Supplier Code of Conduct is available on the company website.

Monitoring: The Corporate Procurement Department checks suppliers through the EcoVadis portal, conducts regular supplier reviews, and maintains a gift and hospitality register.

Policy for Responsible Investments

Scope: Applies to Gjensidige Forsikring ASA and its subsidiaries.

Governance: Adopted by the CEO based on principles established by the Board.

Key content: Ensures investments achieve the highest possible long-term return while respecting ethical and environmental principles. Asset management is based on ensuring minimum requirements for human and labour rights are met. Material violations not handled in a trustworthy manner result in exclusion from Gjensidige's investments.

International standards: Based on the 10 UN Global Compact Principles, OECD Guidelines for Multinational Enterprises, UN Guiding Principles on Business and Human Rights, and UN Principles for Responsible Investment (UN PRI) recommendations.

Monitoring: All companies invested in are monitored quarterly either through direct dialogue or through asset managers. Engagement in dialogue occurs in case of violations; exclusion is considered if influence cannot be exerted.

Incidents of corruption or bribery

Confirmed incidents and convictions

Gjensidige Forsikring reports zero confirmed incidents of corruption or bribery and zero convictions for the reporting period 2024.

Fines and penalties

The company explicitly reports that no fines were received by the Group in 2024:

Disciplinary actions and contract terminations

The company does not disclose specific numbers of employees dismissed or disciplined, or contracts with business partners terminated, specifically due to corruption or bribery incidents.

Investigation and speak-up mechanisms

Gjensidige maintains multiple notification channels:

Whistleblowing channel: The company operates a notification channel accessible to both internal employees and external stakeholders (including workers in the value chain) through portal.mittvarsel.no. The channel enables anonymous reporting and communication with anonymous whistleblowers. All reports are handled by the Internal Investigation Unit in complete confidentiality. In 2024, 192 incidents were reported through the whistleblowing channel (compared to 79 in 2023).

Ethics mailbox: Available on the company's intranet and at gjensidige.no for reporting ethics-related matters and censurable conditions.

Anti-corruption programme: Gjensidige has zero tolerance for corruption, bribes, and facilitation payments. The programme consists of three main elements:

• Preventive activities (definitions, ethical rules, training, risk mapping)
• Controls and detection (indicators, reporting channels, audits, internal investigations)
• Follow-up and sanctions (policies for handling irregularities)

The company's anti-corruption handbook is publicly available and applies to all managers and employees at all levels, including in countries where Norwegian law does not apply.

Investigation procedures: The Internal Investigation Unit, comprising employees with police backgrounds and investigation expertise, is responsible for investigating concrete cases of suspected improper conduct, including corruption. Matters threatening employee safety or well-being receive highest priority. The People department considers sanctions when censurable conditions are uncovered, and the CEO decides whether to report employees to police. Relevant matters are reported to the Group's risk committee and the Board.

Training: All employees must complete mandatory courses in ethics and anti-corruption. In 2024, 4,256 employees completed courses in ethics and anti-corruption. The training is computer-based (1 hour per employee), required annually, and covers:

• Definition of ethics and morals
• Anti-corruption and different types of corruption
• Internal regulations
• Principal and disciplinary training
• Routines in case of suspicion/detection

Supplier requirements: 95% of suppliers have signed a sustainability self-declaration based on the UN Global Compact.

Related cases

While not specifically corruption or bribery, the company reports:

• 62 cases reported to internal investigation in 2024 (43 in 2023)
• 15 cases of harassment and discrimination (4 in 2023)
• 34 cases reported to Økokrim (Norwegian National Authority for Investigation and Prosecution of Economic and Environmental Crime) related to anti-money laundering (30 in 2023)