Our Sustainability Risk Framework

Sometimes, business transactions that create economic value and are perfectly fine from a legal perspective may also have negative impacts on the environment or certain vulnerable groups. Furthermore, such transactions may damage our brand and/or reputation.

Based on our long-standing commitment to enabling sustainable progress, we believe that it is important to recognise and address such dilemmas. Doing so requires a well-defined approach and the willingness to make decisions based on ethical principles.

Our Sustainability Risk Framework is an advanced risk management instrument specifically designed to identify and address potentially negative effects of our transactions on local communities, workforces and the environment — helping us to safeguard our reputation in the process. The framework applies to all of our business transactions, re/insurance as well as investments, to the extent that we can influence their various aspects.

The Sustainability Risk Framework consists of:

  • Eight policies on sensitive sectors or issues;
  • The Sensitive Business Risk (SBR) process with an online assessment tool and a referral tool — due diligence mechanisms to assess our business transactions;
  • Company exclusions; and
  • Country exclusions beyond mere compliance with international trade controls.


Our Sustainability Risk Framework is based on the principles of respecting human rights and protecting the environment. Through detailed policies, the framework applies these principles to seven sectors in which we perceive major sustainability risks: the defence industry, oil and gas (including oil sands and hydraulic fracturing), mining, dams, animal testing, forestry, pulp & paper and oil palm, and nuclear weapons proliferation. (The list of key concerns addressed by the eight policies can be viewed at media.swissre.com/documents/Swiss_Re_SBR_policy_concerns.pdf)

The Sensitive Business Risks process

Each of the eight policies of our Sustainability Risk Framework contains criteria and qualitative standards which define precisely when a transaction may present a “sustainability risk”. In 2015, we introduced a new online tool which enables our underwriters to screen all transactions for their possible impacts on the local environment and on the human rights of the affected people and workforces.

3 550

Number of sensitive business transactions assessed by our underwriters


Number of sensitive business transactions referred to our sustainability expert team

(454 in 2014)

When the screening reveals any potential issues, the underwriters carry out further due diligence. Finally, the most critical transactions are referred to our team of sustainability experts, who then conduct targeted research to decide whether the transaction at hand is acceptable on ethical grounds.

Sensitive Business Risks referred to our expert team in 2015

Sensitive Business Risk referrals 2015 (pie chart)

This decision takes the form of a binding recommendation either to go ahead with the transaction, to go ahead with certain conditions attached or to abstain from it. If there is disagreement about the recommendation, the case can be escalated to the next management level, ultimately to the Group Chief Risk Officer and the Group Executive Committee.

When making these decisions, we refer to internationally recognised ethical principles. Swiss Re is a signatory to the UN Global Compact, which derives its human rights principles from the Universal Declaration of Human Rights, its labour principles from the ILO Declaration on Fundamental Principles and Rights at Work, its environment principles from the Rio Declaration on Environment and Development and its anti-corruption principles from the United Nations Convention against Corruption.

After continuously rising for several years, the number of transactions referred to the SBR process fell to 309 in 2015. Of those we issued negative recommendations in 32 cases and positive recommendations with conditions in 24 cases. The fall in referrals is due to the introduction of our SBR assessment tool, which enables our underwriters to carry out due diligence checks themselves. In 2015, they used the new tool for a total of 3 550 cases.

Number of Sensitive Business Risk referrals

Number of Sensitive Business Risk referrals (bar chart)

Company exclusions

The policies of our Sustainability Risk Framework specify certain criteria that may lead to the exclusion of a company from both our re/insurance transactions and our investments, to the extent that such an exclusion is permissible (eg by virtue of mandatory law or internal policies) and possible (eg if existing documentation relating to such re/ insurance transactions and investments provide for it). These criteria include: involvement in prohibited war material; verifiable complicity in systemic, repeated and severe human rights violations; causing repeated, severe and unmitigated damage to the environment; proliferation of nuclear weapons; and unethical/cruel animal testing practices.

Country exclusions

Swiss Re also excludes certain countries from its business, beyond compliance with international trade controls (ITCs). The criterion for these country exclusions is a particularly poor human rights record. Our goal is not to directly underwrite risks or make investments in entities that are based in these countries. At the end of 2015, the countries excluded from our business for human rights reasons were North Korea, Somalia, Sudan (North only) and Syria. The underlying methodology has recently been revised and is being implemented in 2016.