Chubb Ltd

Chubb's Board of Directors is actively engaged in oversight of strategy and management of sustainability-related risks and opportunities. Environmental, social and governance (ESG) is a full-Board topic, and our directors are regularly briefed by senior executives and outside consultants on emerging ESG risks. In addition, the following Board committees have specific responsibilities related to the oversight and management of sustainability risks and opportunities. [...] Nominating & Governance Committee: oversight of Chubb's corporate governance structure and practices, including Board leadership and composition, our Corporate Citizenship activities and ESG policies and initiatives, including associated risks. [...] Chubb engages in voluntary reporting on sustainability topics to a variety of external entities including the CDP, the UN Global Compact, and EcoVadis. Chubb also produces an annual report following the TCFD framework that is publicly available on our website and separately filed with our U.S. state insurance regulators through our response to the National Association of Insurance Commissioners' Climate Risk Disclosure Survey. [...] Chubb also has policies that restrict our coal and oil sands activities that predate our development of the underwriting criteria approach described above. These policies are described in detail in our 2023 TCFD Report.

## Board of Directors Oversight

The Board of Directors recognizes the critical risks arising from climate change and is actively engaged in overseeing the company's climate-related strategies, including the development of its climate policies and climate-related business activities. The Board and its committees receive regular updates on climate issues from management and external experts.

In addition to the full Board's general oversight, two Board committees are charged with specific climate-related oversight responsibility:

* **Risk & Finance Committee:** oversees our ERM function, which includes extensive analysis of climate risk, including climate-related catastrophe risk, such as increased threats of wildfire, sea level rise and hurricane frequency and intensity, and reviews investment risks associated with climate change.

* **Nominating & Governance Committee:** oversees our corporate citizenship activities and environmental, social, and governance (ESG) policies and initiatives, including those relating to climate change and the environment, such as our fossil fuel-related underwriting and investment policies, corporate environmental goals and philanthropic efforts. The committee also receives updates and provides input on feedback from shareholders and other stakeholders on Chubb's climate efforts.

## Management Responsibilities

Chubb is engaged in a wide range of climate-related activities that include:

* Identifying and analyzing climate risk;
* Public engagement on climate issues with government officials, regulatory bodies, climate advocacy groups, climate experts and a variety of other interest groups;
* Consideration and implementation of appropriate climate-related underwriting and investment actions;
* Limiting the company's own GHG emissions; and
* Providing philanthropic support for climate resilience projects.

Chubb's CEO and its management Executive Committee provide oversight and direction of these activities and set the company's climate-related strategies. The CEO engages extensively on climate issues, including in his annual shareholder letter and other public communications. Other senior executives with climate-related responsibilities include:

* The General Counsel coordinates the company's ESG initiatives, including its climate-related policies and strategies.
* The Chief Risk Officer oversees the ERM function, including risks associated with climate change. Various management teams, including the Risk and Underwriting Committee, product boards and risk-related committees, meet regularly to evaluate specific risks and risk accumulation in Chubb's business activities and investments.
* The Global Climate Officer is responsible for coordinating Chubb's climate-related strategies and supporting the execution of business and public policy initiatives. The Global Climate Officer also oversees our internal climate activities, including GHG emissions measurement and reduction commitments.

Discussions regarding climate change occur at all levels of Chubb Life. This includes oversight by the Board, the direct involvement of senior management and grassroots efforts by staff-led committees. The role of the Chubb Life Board The Chubb Life Board of Directors meets six times per year and is responsible for oversight of climate-related risks and opportunities affecting Chubb Life. In late 2022 the Chubb Life Board delegated certain responsibilities in relation to climate risk oversight to the Risk Committee of the Board. The Risk Committee is made up of all directors of Chubb Life and is actively involved in the oversight of the effort to comply with the Aotearoa New Zealand Climate Standards and the work to understand and respond to climaterelated risks. It is important that the information Chubb Life collects regarding our climate risks and opportunities is used to support the Chubb Life strategy. The Board retains the right to make decisions relating to climate matters, including via recommendation from the Risk Committee. The Board agenda includes a standing agenda item for the Chair of the Risk Committee to provide a summary of the Risk Committee discussion. The membership of the Risk Committee (all directors) as well as the reservation of the right to make decisions in relation to climate matters, means that the Board's delivery of Chubb Life's overarching strategy will be regularly informed by the evolving view of climate risks and opportunities. More information about the alignment of the Chubb Life strategy and relevant climate opportunities is set out on page 10. The role of the Risk Committee The Risk Committee meets four times per year and receives and considers reporting related to climate risks and, where relevant, opportunities from senior management at each quarterly meeting. In 2023, the General Counsel & Chief Risk Officer provided the Committee with specific reporting on progress towards compliance with the climate reporting regime, including the climate-related risks and opportunities identified during the scenario analysis process. In 2024, the reporting to the Risk Committee will be expanded to include work on establishing Chubb Life's metrics and targets, and additional reporting on climate risk and regulatory developments from the General Counsel & Chief Risk Officer and the Head of Risk, Compliance and Assurance. This reporting will include: - updates on emerging science relating to climate change impacts both globally and within New Zealand, - information about emerging trends in climate risk management, and - insights into evolving expectations from our key stakeholders, including our customers. Climate-specific reporting helps to ensure the Risk Committee has access to new or emerging information relating to climate change that is relevant to Chubb Life, or life insurance more broadly, and provides an opportunity for the directors to regularly review and discuss the risks and opportunities related to climate change. In 2023, the Risk Committee's involvement in climate related matters included: - Recommending to the Board that it approve changes to the risk appetite statement, as recommended by the General Counsel & Chief Risk Officer. - Recommending to the Board that it approve the rating of Climate Risk, as recommended by the General Counsel & Chief Risk Officer for inclusion in Chubb Life's risk profile. - Reviewing and commenting on the findings of Chubb Life's scenario analysis, which has included findings relating to both climate risks and opportunities. The Risk Committee will be responsible for reviewing and recommending to the Board that it approves any non-GHG metrics, and any targets, relating to climate matters. Relevant metrics and targets will then be allocated to specific members of senior management as they are established, who will report against those metrics and targets in the regular Committee meetings. Chubb Life's remuneration policies do not currently include performance metrics relating to climate. As noted in our transition plan on page 12, we will review management remuneration and establish the appropriateness of incorporating performance metrics relating to climate in FY24. The role of the Audit Committee From FY24, it is expected that the Audit Committee of the Chubb Life New Zealand Board will have responsibility for appointment of an external assurance provider, in order to complete an assurance engagement in relation to GHG emissions and any other matters identified for assurance. Senior management responsibilities Climate Working Group Chubb Life established the Climate Working Group in April 2022. The Climate Working Group is made up of senior management from across Legal, Risk and Governance, Finance, Actuarial, Strategy and Human Resources, and is chaired by the General Counsel & Chief Risk Officer. In 2023, it was responsible for overseeing the delivery of Chubb Life's work to comply with the Aotearoa New Zealand Climate Standards and, in particular undertook the scenario analysis exercises. The General Counsel & Chief Risk Officer reported on the progress of this Working Group via the quarterly report to the Risk Committee described above. In 2024, the Chubb Life Board will review the role of the Working Group as Chubb Life develops its approach to transitioning to a low carbon economy. The Climate Working Group is expected to play an important role in overseeing the delivery of Chubb Life's five objectives, set out on page 12. Risk and Compliance Forum The Senior Leadership Team Risk and Compliance Forum is made up of the entire SLT[2] and is chaired by the Chief Executive Officer. It meets monthly to discuss and review various matters relating to risk and compliance management at Chubb Life that are set out in the monthly SLT Risk and Compliance reporting, undertaken in compliance with the Risk and Compliance Management Framework. This includes making recommendations to the Risk Committee as to the appropriate risk appetite for climate risk, assessing the level of transitional and physical risks, and providing direction and feedback on the approach to mitigating climate risk to the Climate Working Group and Chubb Life employees, as required. In addition to this approach to climate-related matters undertaken as a as part of their membership of the Senior Leadership Team Risk and Compliance Forum, the SLT is also responsible for ensuring that climate opportunities are considered as required when proposing strategic activity and planning change. This includes oversight and approval of business initiatives that align with our climate-related opportunities. In particular, the SLT meets on a fortnightly basis to discuss both operational and strategic matters, and participates in a regular strategic prioritisation process. Individual initiatives also report to SLT via Steering Committees and other governance structures, as appropriate. General Counsel & Chief Risk Officer The General Counsel & Chief Risk Officer is responsible for the implementation and operation of the risk management framework, which specifically contemplates our appetite for climate risk and the tools we use to manage risks (for further information on this process, see Risk Management on page 13). The General Counsel & Chief Risk Officer provides a management report to each Board meeting, and provides the Climate Update to each Risk Committee meeting. In addition, each Risk Committee agenda explicitly provides for CRO time alone with the Risk Committee. Other members of the Senior Leadership Team The General Manager, Human Resources is responsible for supporting staff initiatives and organisational culture related to climate change, and the General Manager Strategy and Marketing is responsible for ensuring that climate is incorporated into Chubb Life's strategic planning, as required. In undertaking these tasks, they consider the information provided to them as members of the SLT Risk and Compliance Forum, and otherwise in their roles. The CEO meets regularly with the members of the SLT and provides the Board with a regular CEO Update. Chubb Life's approach to climate and other ESG-related matters is informed, in part, by the approach taken by its ultimate parent, Chubb Limited. The General Counsel & Chief Risk Officer is responsible for ensuring that Chubb Life's approach to climate change is coordinated with and supports Chubb Limited's global intentions. More about Chubb's approach to climate-related [matters, can be viewed [here] Chubb 2023 Sustainability Report;](https://s201.q4cdn.com/471466897/files/doc_financials/2024/ar/Chubb-2023-Sustainability-Report_4-1-24_FINAL.pdf) [[here] Chubb 2023 Climate-Related Financial Disclosure and [here]](https://about.chubb.com/stories/2023-climate-disclosure-tcfd-reporting.html) _Chubb and Climate Change: Our Policy._

Chubb addresses climate risk through the oversight functions and active engagement of its Board of Directors, through extensive involvement of its most senior executives and through its global enterprise risk management (ERM) framework.\n\n### Board of Directors Oversight\n\nThe Board of Directors recognizes the critical risks to society and to Chubb arising from climate change and is actively engaged in overseeing the company's climate-related strategies, including the development of its climate policies and climate-related business activities. The Board as a whole receives regular updates from management on climate issues and received two significant climate briefings from outside experts over the last year.\n\nIn addition to this general oversight, two Board committees are charged with specific climate-related oversight responsibility:\n\n- Nominating & Governance Committee: oversees our corporate citizenship activities and environmental, social and governance (ESG) policies and initiatives, including those relating to climate change and the environment, such as our fossil fuel-related underwriting and investment policies, corporate environmental goals and philanthropic efforts.\n\n- Risk & Finance Committee: oversees our ERM function, which includes extensive analysis of climate risk, and reviews investment risks associated with climate change, including climate-related catastrophe risk, such as increased threats of wildfire, sea rise and hurricane frequency and intensity.\n\n### Management Responsibilities \n\nChubb is engaged in a wide range of climate-related activities that include:\n\n- Identifying and analyzing climate risk;\n\n- Public engagement on climate issues with government officials, climate advocacy groups, climate experts and a variety of other interest groups;\n\n- Consideration of appropriate climate-related underwriting and investment actions;\n\n- Development of products and services to promote the transition to a net-zero economy and support our customers' resiliency in the face of climate change;\n\n- Limiting the company's own GHG emissions; and\n\n- Providing philanthropic support for climate resilience projects.\n\nThe CEO and Executive Committee provide oversight and direction of these activities and set the company's climate-related strategies. The CEO engages extensively on climate issues, including in his annual shareholder letter and in other public communications. Other senior executives with climate-related responsibilities include:\n\n- The General Counsel coordinates the company's ESG initiatives, including its climate-related policies and strategies.\n\n- The Chief Risk Officer oversees the ERM function, including risks associated with climate change. Various management teams, including the Risk and Underwriting Committee, product boards and risk-related committees, meet regularly to evaluate specific risks and risk accumulation in Chubb's business activities and investments.\n\n- Currently, the Vice Chairman, Global Underwriting and Claims, has management oversight of climate strategy and the execution of underwriting and portfolio management decisions thereof. The Vice Chairman also oversees Chubb's Global Climate Practice. In January 2023, this responsibility will be assumed by the company's newly appointed Global Chief Climate Officer, who will provide broad oversight of the company's day-to-day climate-related activities.\n\n- The Assistant Vice President, Climate Sustainability Manager is responsible for identifying and implementing opportunities for climate-related products and services, establishing a framework to measure progress and driving operational sustainability, and manages:\n\n - Internal climate activities, including GHG measurement and reduction activities.\n\n - The Climate Advisory Group, composed of senior business unit managers and other global leaders, collaborates cross-divisionally to pursue opportunities to develop and expand climate-relevant products and services.

Effective risk governance for Chubb requires close and dynamic collaboration as well as a strong focus on communication. At the Board of Directors level, the Risk and Finance Committee helps execute the Board's supervisory responsibilities pertaining to ERM. The company's Executive Committee, comprised of the company's most senior executive leaders including the Chairman and CEO, General Counsel, Chief Risk Officer and the Vice Chairman who has responsibility for Chubb's global environmental program and climate sustainability strategy, has responsibility for ensuring that Chubb's environmental, social, and governance (ESG) and citizenship activities, including those related to climate issues, are consistent with the company's culture, values, corporate mission, and business objectives, including those pertaining to climate–related risks and opportunities. Chubb's Nominating and Governance Committee has responsibility at the Board level for reviewing ESG issues, including climate change. [...] The company's Risk and Underwriting Committee, product boards, and risk–related committees meet at least quarterly to evaluate specific risks and risk accumulations in Chubb's business activities and investments. Various risk–related reports are provided at least quarterly to the full Board, senior management, business division management, product boards and risk–related committees, including the Risk and Underwriting Committee and the Risk and Finance Committee. [...] Chubb has a comprehensive, coordinated global environmental program that is embedded in all areas of the organization and its activities and performance are reported to the Risk and Underwriting Committee and executive team. The company's Vice Chairman, Global Underwriting and Claims is the senior executive responsible for overseeing this program. The Climate Sustainability Manager manages the program and is responsible for identifying and implementing opportunities for climate–related products and services, encouraging employee engagement in climate sustainability issues and establishing an objective, metric–driven framework against which to measure progress of Chubb's sustainability initiatives. The Climate Sustainability Manager reports to the Vice Chairman. The Vice Chairman reports to the CEO of Chubb and is a member of the company's Executive Committee. The goals and objectives of the environmental program are approved by the CEO, and the Vice Chairman provides regular updates to the CEO and modifies the program as necessary. [...] The Climate Sustainability Manager chairs two committees as part of Chubb's climate management. The Climate Advisory Group (CAG) is comprised of senior business unit managers from across the company and meets six times per year to collaborate cross–divisionally to pursue opportunities to develop and expand climate–relevant products and services. The deliverables from the CAG flow to the Vice Chairman and Executive Committee for review and approval. The Operational Climate Committee (OCC) oversees the operationally focused climate and environmental sustainability policies, strategies and programs of Chubb. This includes Chubb's greenhouse gas measurement and reduction activities. The deliverables of the OCC flow to the Global Head of Operations, Vice Chairman and Executive Committee for review and approval.

## Governance

Chubb addresses climate risk through the oversight functions and active engagement of its Board of Directors, through extensive involvement of its most senior executives and through its global enterprise risk management (ERM) framework.

## Board of Directors Climate Change Oversight

The Board of Directors recognizes the critical risks arising from climate change and is actively engaged in overseeing the company's climate-related strategies, including the development of its climate policies and climate-related business activities. The Board and its committees receive regular updates on climate issues from management and external experts.

In addition to the full Board's general oversight, two Board committees are charged with specific climate-related oversight responsibility:

* **Nominating & Governance Committee:** oversees our corporate citizenship activities and environmental, social and governance (ESG) policies and initiatives, including those relating to climate change and the environment, such as our fossil fuel-related underwriting and investment policies, corporate environmental goals and philanthropic efforts. The committee also receives updates and provides input on feedback from shareholders and other stakeholders on Chubb's climate efforts.

* **Risk & Finance Committee:** oversees our ERM function, which includes extensive analysis of climate risk, including climate-related catastrophe risk, such as increased threats of wildfire, sea level rise and hurricane frequency and intensity, and reviews investment risks associated with climate change. For example, over the past year the committee received detailed presentations and engaged in discussions with management on various activities and initiatives relating to climate risk, such as governance, insurance products and services initiatives, investment strategies and ERM actions.

## Management Responsibilities

Chubb is engaged in a wide range of climate-related activities that include:

* Identifying and analyzing climate risk;
* Public engagement on climate issues with government officials, climate advocacy groups, climate experts and a variety of other interest groups;
* Consideration and implementation of appropriate climate-related underwriting and investment actions;
* Limiting the company's own GHG emissions; and
* Providing philanthropic support for climate resilience projects.

Chubb's CEO and its Executive Committee provide oversight and direction of these activities and set the company's climate-related strategies. The CEO engages extensively on climate issues, including in his annual shareholder letter and other public communications. Other senior executives with climate-related responsibilities include:

* The General Counsel coordinates the company's ESG initiatives, including its climate-related policies and strategies.
* The Chief Risk Officer oversees the ERM function, including risks associated with climate change. Various management teams, including the Risk and Underwriting Committee, product boards and risk-related committees, meet regularly to evaluate specific risks and risk accumulation in Chubb's business activities and investments.
* The Global Climate Officer is responsible for coordinating Chubb's climate-related strategies and supporting the execution of business and public policy initiatives. The Global Climate Officer also oversees our internal climate activities, including greenhouse gas emissions measurement and reduction commitments.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]Chubb has a government affairs function that coordinates with business units and the executive team on public policy and advocacy strategies. As a global insurance company, assessing and managing risk is a core competency for Chubb. Chubb's business and operating models are exposed to the full impact of global climate change. The potential physical effects of climate change present a significant risk to the company, and therefore, have been integrated into Chubb's overall risk management process. The company's Executive Committee, which includes the Chairman and CEO and Chubb's most senior executive leaders, has responsibility for ensuring that Chubb's climate-related activities are consistent with the company's culture, values and corporate mission. Chubb's General Counsel is responsible for monitoring ongoing climate-related activities, reporting periodically to the Nominating and Governance Committee of the Board of Directors on those activities and raising any new climate-related issues which may involve advocacy or specific corporate action to the Committee's attention for review and direction. Chubb also maintains a rigorous process to ensure that its direct and indirect activities to influence policy are consistent with the company's strategy and objectives, including overall climate change strategy. Chubb has a global environmental program that is embedded in all areas of the organization and reports to the Risk and Underwriting Committee and executive team. The company's Vice Chairman is the senior executive responsible for overseeing this program. Chubb's policy and legislative activities are closely managed by the Government Affairs department, which maintains relationships with government agencies, legislative bodies, and governments at the state, federal and international levels. Chubb Government Affairs also represents the company's views by engaging with different organizations, associations and groups. Because Chubb operates in a highly regulated industry, the communications function is also closely managed. The company's Chief Communications Officer reports directly to the Chairman and CEO of Chubb. The strategic direction, management and review of all company environmental program communications are centralized. This includes media relations, executive speaking engagements, publications, internal communications, social media and advertising.

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]Chubb has a government affairs function that coordinates with business units and the executive team on public policy and advocacy strategies. Chubb's policy and legislative activities are closely managed by the Government Affairs department, which maintains relationships with government agencies, legislative bodies, and governments at the state, federal and international levels. Chubb Government Affairs also represents the company's views by engaging with different organizations, associations and groups. Because Chubb operates in a highly regulated industry, the communications function is also closely managed. The company's Chief Communications Officer reports directly to the Chairman and CEO of Chubb. The strategic direction, management and review of all company environmental program communications are centralized. This includes media relations, executive speaking engagements, publications, internal communications, social media and advertising. In addition, Chubb published its board-approved Climate Change Policy Statement in April 2022, which outlines the strategic direction on our climate strategy.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes