Our Sustainable Business Risk Framework

In a properly regulated market environment, profitable business activities create economic value. Occasionally, however, they may also have adverse effects on the environment and certain vulnerable groups. If such impacts are ignored, they may pose a threat to societies’ long-term sustainable development.

Many businesses – including our own – grapple with the issue that some business transactions may be economically beneficial and perfectly legal, yet may still have adverse environmental or social impacts. We believe it is important to recognise the existence of such dilemmas and address them responsibly throughout our business.

Our Sustainable Business Risk Framework is an advanced risk management instrument that allows us to identify, assess and address potential social and environmental risks associated with our transactions. This framework applies to our entire business, including all our re/insurance transactions and investments, to the extent that we can influence their various aspects.

The Sustainable Business Risk Framework consists of:

  • Two umbrella policies on human rights and environmental protection plus eight specific guidelines on sensitive sectors or issues
  • The Sustainable Business Risk (SBR) process comprising a sustainable business risk rating in a semi-automated assessment and referral tool – due-diligence mechanisms to assess our business transactions
  • Company exclusions
  • Sector exclusions in specified countries beyond mere compliance with international trade controls (ITCs)

Brochure “Swiss Re Sustainable Business Risk Framework”

In 2020, we updated our publication on the Sustainable Business Risk Framework. Over 21 pages it describes the Framework and its core elements in detail.

Sustainable Business Risk Framework

Swiss Re Sustainable Business Risk Framework brochure cover (photo)

Policies and guidelines

Our Sustainable Business Risk Framework is based on the overarching principles of respecting human rights and protecting the environment, encapsulated in two umbrella policies that are valid for all our transactions. In addition, specific guidelines apply these overarching principles to eight sectors or issues in which we perceive major sustainability risks: the defence industry; oil and gas; mining; dams; animal testing; forestry, pulp and paper, and oil palm; nuclear weapons proliferation; and thermal coal.

We regularly review all the policies and guidelines of our Sustainable Business Risk Framework to ensure they stay abreast of new risk developments and changing stakeholder expectations. In 2020, we developed a thermal coal phase-out strategy for our treaty business and continued with the implementation of our revised oil and gas policy. These improvements to the Sustainable Business Risk Framework form an important part of the efforts we have taken towards gradually decarbonising our business model (see Decarbonising our business model).

The Sustainable Business Risk process

We implement the framework’s policies through a due-diligence process with three elements: the Sustainable Business Risk (SBR) Assessment, the SBR Referral Tool and an appeals process. This process is firmly embedded in the Group’s underwriting guidelines and processes.

In 2020, we further automated the SBR assessment and fully embedded it in the underwriting processes for direct and facultative transactions. The SBR Assessment in the underwriting workflow now provides our underwriters with a sensitivity rating for the human rights and environmental impacts of their transactions, and provides them with clear guidance on what to assess in further detail.

Sustainable Business Risk transactions referred to our team of sustainability experts


(238 in 2019)

The transactions identified as the most critical are transferred through the SBR Referral Tool to Swiss Re’s team of sustainability experts, who conduct in-depth research to decide whether the transaction at hand is acceptable according to the policies of the Sustainable Business Risk Framework.

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. If there is disagreement about the recommendation, the case can be escalated to the next management level and, ultimately, to the Group Chief Risk Officer and the Group Executive Committee.

The number of SBR referrals rose from 238 to 258 in 2020. In total, we issued negative recommendations in 28 cases and positive recommendations with conditions in 57 cases (see graphs below). No recommendations were escalated.

Sustainable Business Risks referred to our expert team in 2020, by sector/issue
Sustainable Business Risks referred to our expert team in 2020, by sector/issue (pie chart)
Number of Sustainable Business Risk referrals and decisions taken
Number of Sustainable Business Risk referrals and decisions taken (bar chart)

Company exclusions

Each policy of our Sustainable Business Risk Framework specifies 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). No business may be conducted with any of these companies by any part of Swiss Re while they remain on the exclusion list.

Excluded sector and country combinations

Swiss Re excludes high-risk industries in combination with countries where human rights are violated in a severe and systematic way, and where no reasonable prospect of imminent improvement can be foreseen. This measure goes further than compliance with ITCs.

Our goal is to refrain from directly underwriting risks or making investments in entities that are involved in high-risk industries in countries with a poor human rights record.

As the Sustainable Business Risk Framework is based on the principles of respecting human rights and protecting the environment, the SBR process with its two due-diligence tools, company exclusions and country exclusions is our principal means to ensure compliance with the UN Global Compact in our core business.


We offer our employees regular in-house training on the Sustainable Business Risk Framework. Three years ago, we developed a completely new eLearning course for this purpose and updated it in 2020. It is compulsory for all our employees who work in underwriting and with our clients as well as for all our new entrants. In 2020, a total of approximately 4 000 employees completed the mandatory training course.

Client and industry interaction

Over the year, we had a number of important external engagements on sustainability risks with clients, brokers, investors, industry peers and civil society groups such as environmental and humanitarian NGOs. We held meetings with clients operating in sensitive sectors such as mining, forestry, and oil and gas, discussing potential measures they could take to address their sustainability risks.

As part of our ongoing efforts to implement our thermal coal policy, we had over 400 engagements with clients across the globe in 2020. Many of them have introduced a thermal coal policy themselves and in turn are helping us reduce our carbon exposure in our own business.

In the context of implementing our revised oil and gas policy, we held several meetings with brokers to explain our approach to avoid exposure to the world’s most carbon-intensive oil and gas production.

In partnership with other re/insurers, we are also developing risk assessment tools designed to help the industry better understand and manage sustainability risks. One of these ongoing partnerships is the UNEP FI Principles for Sustainable Insurance (PSI). In 2020, we jointly organised and held a four-part virtual event series on “Sustainability Leadership in Insurance”. You can find more information about this series and other collaborations with partner organisations under “Sustainability Leadership in Insurance” event series.