Independent Limited Assurance Report on the Swiss Re Sustainability Reporting for the financial year 2019

To the Executive Management of Swiss Re Ltd, Zurich (Swiss Re)

We have been engaged to perform a limited assurance engagement on the consolidated CO2 emissions reporting and Sustainability topics and sections disclosed with the online version of the 2019 Swiss Re Sustainability Report (“Sustainability Report 2019”) as well as with the online version of the 2019 Swiss Re Financial Report. Those sections and information of the Sustainability Report 2019 and Financial Report 2019 selected by Swiss Re and subject to our assurance engagement are marked with the label ‘PwC CH’.

Scope and subject matter

Our engagement focused on the following data and information disclosed in the Sustainability Report 2019 and Financial Report 2019 of Swiss Re and its consolidated subsidiaries, for the financial year ended 31 December 2019:

  • The management and reporting processes with respect to the consolidated sustainability reporting as well as the control environment in relation to the aggregation of data and information;
  • The organizational measures and internal key controls in place at the corporate level regarding aggregation of information obtained from the subsidiaries and reporting functions;
  • The consolidated data and information disclosed in the Sustainability Report 2019 in the sections “Creating solutions for sustainability”, “Extending our risk intelligence”, “Being a responsible investor”, “Engaging in dialogue with our stakeholders”, “Reducing our footprint”, “Engaging our people” and “Compliance: Code of Conduct” marked with the label ‘PwC CH’;
  • The information marked with the label ‘PwC CH’, namely the consolidated CO2 emissions 2019 (Scope 1, 2 and 3 in adherence with the Greenhouse Gas Protocol) in the tables of the Sustainability Report 2019 entitled “CO2 emissions per employee (full-time equivalent, FTE), Swiss Re Group”, “Underlying environmental data, Swiss Re Group” and “Indirect emissions from purchased electricity, Swiss Re Group” in the Sustainability Report 2019 covering the reporting period from 1 October 2018 to 30 September 2019;
  • The information marked with the label ‘PwC CH’, namely the retirement of 76’340 tonnes of CO2e (CO2 equivalents) described in the Sustainability Report 2019.
  • The information marked with the label ‘PwC CH’, namely the consolidated data and information disclosed in the Financial Report 2019 in the sections “Climate-related financial disclosures (TCFD)”, “Climate governance”, “Climate strategy”, “Climate risk management” and “Climate metrics and targets”.


The management reporting processes with respect to the sustainability reporting 2019 were assessed against the internal and external policies and procedures as set forth in the following:

  • “Internal Environmental Performance Indicators for the Financial Industry” published by the Verein für Umweltmanagement in Banken, Sparkassen und Versicherungen e.V. (VfU) published in 1997 and 2011;
  • “The Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (Revised Edition)” published in 2004 by the World Resources Institute and the World Business Council for Sustainable Development;
  • DEFRA Guidelines to DEFRA/DECC’s GHG Conversion Factors for Company Reporting. AEA for the Department of Energy and Climate Change (DECC) and the Department for Environment, Food and Rural Affairs (DEFRA);
  • The framework document “Environmental Performance Indicators (EPI) Reporting at Swiss Re”, version 1.1 from December 2015 including Annex; and
  • The defined internal guidelines, by which sustainability data and information are internally gathered, collated and aggregated.

Inherent limitations

The accuracy and completeness of environmental indicators are subject to inherent limitations given their nature and methods for determining, calculating and estimating such data. Our assurance report should therefore be read in connection with Swiss Re’s internal guidelines, definitions and procedures on the reporting of its sustainability performance.

Swiss Re’s responsibility

The Executive Management of Swiss Re is responsible for both the subject matter and the criteria as well as for selection, preparation and presentation of the selected information in accordance with the criteria. This responsibility includes the design, implementation and maintenance of related internal control relevant to the calculation of the sustainability indicators that is free from material misstatement, whether due to fraud or error.

Our responsibility

Our responsibility is to express a limited assurance conclusion on the sustainability indicators based on the procedures we have performed and the evidence we have obtained. We conducted our limited assurance engagement in accordance with the International Standard on Assurance Engagements 3000 (revised), “Assurance Engagements other than Audits or Reviews of Historical Financial Information”, and, in respect of greenhouse gas emissions, with the International Standard on Assurance Engagements 3410, “Assurance Engagements on Greenhouse Gas Statements”, issued by the International Auditing and Assurance Standards Board. These standards require that we plan and perform this engagement to obtain limited assurance about whether the identified sustainability indicators are free from material misstatement.

A limited assurance engagement undertaken in accordance with ISAE 3000 (revised) and ISAE 3410 involves assessing the suitability in the circumstances of Swiss Re’s use of applicable criteria as the basis for the preparation of the sustainability data and information, assessing the risks of material misstatement of the sustainability data and information whether due to fraud or error, responding to the assessed risks as necessary in the circumstances, and evaluating the overall presentation of sustainability data and information. A limited assurance engagement is substantially less in scope than a reasonable assurance engagement in relation to both the risk assessment procedures, including an understanding of internal control, and the procedures performed in response to the assessed risks. The procedures selected depend on the assurance practitioner’s judgement.

Our independence and quality controls

We are independent of the Swiss Re in accordance with the International Code of Ethics for Professional Accountants (including International Independence Standards) issued by the International Ethics Standards Board for Accountants (IESBA Code) that are relevant to our audit of the financial statements and other assurance engagements in Switzerland. We have fulfilled our other ethical responsibilities in accordance with the IESBA Code.

Our firm applies International Standard on Quality Control 1 and accordingly maintains a comprehensive system of quality control including documented policies and procedures regarding compliance with ethical requirements, professional standards and applicable legal and regulatory requirements.

Summary of the work performed

Our assurance procedures included, amongst others, the following work:

  • Evaluation of the application of Swiss Re’s sustainability reporting
    guidelines Assessing whether the methodology applied by Swiss Re is in line with the reporting criteria;
  • Interviews and management inquiry 
    Evaluating the sustainability reporting and underlying performance indicators by performing analytical procedures and interviewing selected key contacts to assess whether the internal Environmental Performance Indicators Reporting guidelines and sustainability guidance were consistently applied by the selected locations; Performing inquiries of personnel responsible for internal sustainability reporting and data collection at the Swiss Re corporate level to evaluate the reporting and aggregation process and to assess its appropriateness;
  • Reconciliation of CO2 emissions data 
    Reconciling the CO2 emissions data for energy consumption, business travel, copy paper, waste, water, technical gases and commuting and sustainability data and information to the data used for the internal sustainability reporting of the selected locations;
  • Assessment of the key figures 
    Performing tests on a sample basis of evidence supporting selected sustainability data and information (natural catastrophes and climate change, the commitment to the UN, the commitment with Women’s World Banking, sustainable business risk transactions referred to the team of sustainability experts, responsible investments, CO2 emissions and reductions, energy consumption for heating and electricity, business travel data, sustainable supply chain data, the COyou2 programme, HR data and information, diversity and inclusion, employee health data) to assess their completeness, accuracy, adequacy and consistency;
  • Review of the documentation 
    Reviewing the relevant documentation on a sample basis, including Swiss Re’s sustainability-related policies, the management of reporting structures, the documentation and systems used to collect, analyse and aggregate reported sustainability data and information;
  • Assessment of the processes and data consolidation 
    Reviewing the appropriateness of the management and reporting processes for sustainability reporting; and assessing the processing and consolidation of data at Swiss Re’s Group level; and
  • Review of certified emission reductions and removals 
    Reviewing the retirement of 76’340 tonnes of CO2e: 57’600 certified emission reductions (CERs) with additional Gold Standard label, 18’640 CERs from the Community Development Carbon Fund, 100 CORCs (verified CO2 Removal Certificates from the marketplace).

We have not conducted any work on data other than outlined in the subject matter as defined above. We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our assurance conclusions.


Based on our work described in this report, nothing has come to our attention that causes us to believe that the sustainability data and information outlined in the scope and subject matter section has not been prepared, in all material aspects, in accordance with suitable criteria.

PricewaterhouseCoopers AG

Paul de Jong
Konstantin Meier

Zurich, 19 March, 2020