Anticipate today,
benefit tomorrow
NN Group N.V.
Annual Report 2024
NN Group N.V. Annual Report 2024 | 2
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Contents
1 About NN
About this report 3
NN at a glance 4
Our profile 5
Our values and behaviours 7
A conversation with our CEO 12
The world around us 16
Determining our material sustainability matters 20
2 Our strategy and business
Our strategy 25
Progress on our commitments 26
How we create value 33
Stakeholder engagement and international commitments 35
3 Our performance
Our business performance 42
Creating value for investors 46
4 Managing our risks
Managing our risks 52
5 Governance
Corporate governance 66
Our Management Board 86
Our Supervisory Board 89
A conversation with our Supervisory Board chair 93
Report of the Supervisory Board 95
Remuneration Report 103
Our Code of Conduct and other policies 115
Conformity statement 119
8 Other information
Independent auditor’s report on the annual accounts 385
Limited assurance report of the independent auditor on the
Sustainability Statement 392
Appropriation of result 395
9 Appendix
Principles for Sustainable Insurance Progress report 2024 396
Our response to the Task Force on Climate-related
Financial Disclosures (TCFD) 397
United Nations Global Compact Progress report 2024 398
GHG emissions 402
Glossary 406
Publication details 412
6 Sustainability Statement
General disclosures 121
Environment 134
Social 179
Governance 207
Annex 210
7 Annual accounts
Consolidated annual accounts 244
Consolidated balance sheet 245
Consolidated profit and loss account 246
Consolidated statement of comprehensive income 248
Consolidated statement of cash flows 249
Consolidated statement of changes in equity 251
Notes to the Consolidated annual accounts 253
Risk management (Note 48) 344
Capital and liquidity management (Note 49) 366
Authorisation of the Consolidated annual accounts 374
Parent company balance sheet 375
Parent company profit and loss account 375
Parent company statement of changes in equity 376
Notes to the Parent company annual accounts 378
Authorisation of the Parent company annual accounts 383
PDF/printed version
This document is the PDF/printed version of the 2024 Annual Report
of NN Group N.V. and has been prepared for ease of use and does
not contain European Single Electronic Format (ESEF) information as
specified in the Regulatory Technical Standards on ESEF (Delegated
Regulation (EU) 2019/815). The 2024 Annual Report was made
publicly available pursuant to section 5:25c of the Dutch Financial
Supervision Act (Wet op het financieel toezicht) and was filed with
the Netherlands Authority for the Financial Markets (Autoriteit
Financiële Markten) in European single electronic reporting format
(the ESEF package). The ESEF package is available on the company’s
website and includes a human-readable XHTML version of the 2024
Annual Report. In any case of discrepancies between this PDF/
printed version and the ESEF package, the latter prevails.
NN Group N.V. Annual Report 2024 | 3
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About this report
This report is intended to inform our stakeholder
groups (customers, shareholders, employees,
business partners, regulators and society at large).
We aim to show how we create sustainable, long-
term value.
Purpose
The report brings together relevant information about
our strategy, governance and performance in a way
that reflects the current economic, environmental
and social contexts. This year, for the first time, we
include a separate Sustainability Statement, outlining
how we address our material sustainability matters.
Our financial statements are included in ‘Annual
accounts’. The report is published on 13 March 2025
and covers the year from 1 January to 31 December
2024.
Relevant topics and materiality
We take into account the sustainability matters (see
p. 20-21 for definition) that have a material impact on
our stakeholders and/or that are financially material
to our business. Our material sustainability matters
were selected as part of our Double Materiality
Assessment (DMA), as the basis for disclosure in our
Sustainability Statement. Read more on p. 20.
Preparation
This Integrated Annual Report, including the NN
Group Annual accounts, is prepared in accordance
with applicable Dutch law. NN Group’s Annual
accounts are also prepared in accordance with the
International Financial Reporting Standards as
endorsed by the European Union (IFRS-EU). The
non-financial information and data is prepared in
accordance with relevant non-financial disclosure
regulations, such as the European Sustainability
Reporting Standards (ESRS) and EU Taxonomy. Since
2017, NN Group has externally disclosed that it is
aligning its climate action approach to the Task Force
on Climate-related Financial Disclosures (TCFD). Our
approach to addressing net zero can be found in the
Sustainability Statement on p. 136, and included in a
TCFD reference table on p. 397.
We report our progress on the UN Principles for
Sustainable Insurance (PSI) on p. 396, and on the UN
Global Compact (UNGC) on p. 398.
Other reports
We aim to tailor our reporting for different
stakeholders by publishing additional reports on
specific topics on the NN Group website in the
Investors/Annual Report section. In 2024, NN
Group published its Active Ownership report and
a biodiversity white paper. Alongside this Annual
Report, NN Group publishes a Solvency and Financial
Condition Report and a Total Tax Contribution Report.
Data in this report
All amounts quoted in this Integrated Annual Report
are in euros (EUR), the functional currency of NN
Group. Millions of euros are rounded to the nearest
million, unless otherwise indicated. Calculations are
made using unrounded figures. As a result, rounding
differences can occur.
External assurance
The Consolidated annual accounts and the Parent
company annual accounts of NN Group are audited
by KPMG N.V. Accountants (KPMG). Read more in
the independent auditor’s report on p. 385. KPMG
also provided limited assurance on the Sustainability
Statement included in this Annual Report, read
more in the independent auditor’s report on p. 392.
KPMG issued a limited assurance report on NN
Group’s Total Tax Contribution Report, read more
in the Independent auditor’s report of the Total Tax
Contribution Report.
About this report
The Integrated Annual Report 2024 of NN Group N.V. (NN)
provides an overview of NN’s strategic and financial performance
over the past year.
NN Group N.V. Annual Report 2024 | 4
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NN at a glance
NN at a glance
CustomerFinancial
On par
*
Above
*
EUR 1.5bn
194%
People
7.9
41%
employee
engagement
women in senior management
positions
NPS-r Netherlands
businesses
NPS-r International
businesses
Society
EUR 12.8bn
766k
*
investments in climate
solutions
contribution to
our communities
free cash flow
solvency II ratio
S&P
A+ Stable outlook, Financial
strength rating
A- Stable outlook, Credit rating
Fitch
AA− Stable outlook, Financial
strength rating
A+ Stable outlook, Credit rating
* Compared to market average.
*
Cumulative number of people
supported since 2022.
EUR 1.9bn
operating capital
generation
Sustainability and ESG ratings Credit ratingsPeople
Our performance is recognised in indices and ratings
RGB colors
Japan
Key facts
NN Group N.V. Annual Report 2024 | 5
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Our profile
Our profile
Europe and Japan. We are committed to helping people care
for what matters most to them. Because what matters to them,
matters to us.
The Netherlands
Belgium
Czech Republic
Greece
Hungary
Japan
Poland
Romania
Slovakia
Spain
Turkey*
Our presence
* NN Turkey was divested in
January 2025.
~16k 19m 1845 10
*
employees customers year founded in
the Netherlands
countries we
operate in
Our group segments
NN Group
Netherlands
Life
Netherlands
Non-life
Insurance
Europe
Japan
Life
Banking Other
Our main brands
49% 19% 22% 5% 6%
Netherlands Life Japan Life BankingInsurance EuropeNetherlands Non-life
Operating capital generation FY24
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Our profile
NN Group segments
Netherlands Life
Netherlands Life is market leader in
the Dutch life and pensions market,
offering life insurance as well as the
full spectrum of pension solutions.
Pension solutions include insured
defined benefit (DB) and defined
contribution (DC) through the
Nationale-Nederlanden brand, as well
as Premium Pension Institution (PPI)
through the specialised brand
BeFrank. In addition, Netherlands Life
offers general pension fund (APF)
solutions through De Nationale, as
well as pension fund administration
and advisory services through AZL.
The individual life closed block
primarily consists of individual life
portfolios comprising a range of
discontinued products sold before
2012.
Netherlands Non-life
Netherlands Non-life is the market
leader in the Dutch Non-life market,
offering a wide range of non-life
insurance products, including motor,
fire, liability, transport, travel,
health, and disability and accident
insurance. We operate under
the following brands: Nationale-
Nederlanden, OHRA, Movir, HCS,
Heinenoord and Zicht, as well as
through our joint venture, ABN AMRO
Verzekeringen, and our partnerships
with ING and Volksbank. Our
distribution platform comprises
mandated and non-mandated
brokers, banks, and direct online
channels and engagement platforms.
Insurance Europe
Insurance Europe is the segment
covering eight countries in Europe
outside the Netherlands. The
businesses primarily focus on
providing long-term protection to
retail, self-employed and small and
medium-sized enterprises (SME)
customers. In most markets, we are
among the top three life insurance
companies. In addition, in Poland,
Romania, Hungary and Slovakia we
are the leading player in pensions.
Our European businesses have a
diversified distribution footprint
through tied agents, bancassurance
partners, brokers and direct
channels.
Japan Life
Japan Life offers life insurance
products that combine protection
and savings to support SME owners
and their families. Japan Life offers
its products through registered
independent agents and financial
institution partners (banks and
securities houses) supported by
sales support offices throughout
Japan.
Banking
NN Bank offers financial services in
the fields of savings, bank savings,
investments, bancassurance and
mortgages to 1.2 million customers
in the Netherlands. It is the portal for
all retail customers in the
Netherlands, both directly and
through independent advisors. NN
Bank also operates the label
Woonnu, a mortgage provider that
aims to help consumers make their
homes more sustainable.
Other
The segment ‘Other’ is composed of NN Re, the results of NN Group’s holding
company and other results. NN Re is NN Group’s internal reinsurer. It provides
reinsurance solutions to manage risks, optimise capital, support growth in
business units and safeguard stable and efficient hedging.
Our values and behaviours
Care Clear Commit
NN Group N.V. Annual Report 2024 | 7
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Our values and behaviours
Raising awareness
NN Group’s mission to create sustainable long-term
value for our stakeholders is anchored in the NN
statement of Living our Values, which was defined
in 2014 and is published on our website. Every
employee, including those of subsidiaries, as well
as anyone representing NN Group in any capacity, is
required to act in accordance with this statement.
We are committed to upholding ethical standards in
all our business practices and complying with laws
and regulations in all our operating countries. In this
way, we will continue to earn the trust of customers,
employees, shareholders, business partners and
society at large. We have developed the Living our
Values programme to raise awareness about the
values across our organisation, and to ensure we
incorporate and maintain these values in everything
we do.
Engaging our colleagues
To highlight the importance of values in maintaining
a strong company culture, we introduced Values
week. During Values week 2024 we celebrated ten
years of living our values. We engaged employees
from all our countries, with some 1,200 colleagues
registering for sessions in the Netherlands, including
218 from international units. According to the 2024
Values week survey, participants gave the sessions
an average rating of 8.4, with 64% thinking they
stimulated discussion on the values and 96% saying
they would encourage colleagues to join next year.
Members of the Management Board (MB) were active
participants, acting as role models in how to live our
values. The most popular session, with 452 viewers,
was the keynote on our NN behaviours given by
Dailah Nihot, our Chief People, Communications and
Sustainability Officer.
Our values are the foundation of our culture. They serve as a
compass for daily decision-making and guide us in interactions
with stakeholders to carefully consider their interests. Together
with our Code of Conduct, they also help prevent misconduct and
irregularities. And as an integral part of our strategy and business
model, they are designed to create sustainable long-term value for
our stakeholders.
We help people care for what matters most to them
Our NN values
Our non-negotiable promises to all our stakeholders. Our
values set the standards for conduct, and guide, unite and
inspire us – they are the foundation of our culture.
• Empower people
to be their best
• Respect each other and
the world we live in
• Communicate proactively
and honestly
• Be accessible and open
• Act with integrity
• Do business with the
future in mind
Our NN behaviours
Our way of working that will help us reach our strategic
objectives for the years to come.
Team up Speak up Step up
• We work together
• We put our shared
interests ahead of our own
• We have a positive attitude
• We trust and are
trusted to be our best
• We have open and honest
conversations
• We give and receive
feedback with grace
• We define agreements
and expectations upfront
• We improve and simplify
• We take ownership
• We challenge ourselves
to change, learn and grow
• We deliver quality and drive
operational excellence
• We do more with less and
keep up the speed
Raise awareness Engage Embed Monitor Evaluate
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Our values and behaviours
Embedding the values in our culture
The values are well-embedded in NN Group’s
culture and processes through the Living our Values
programme. To encourage a values-driven culture and
ensure that all employees know and live the values
throughout their careers with us, we incorporate
the values into HR policies and processes. They are
included in employee recruitment and onboarding
processes, embedded in our i-LEAD profile and HR
Framework standard, and form part of our Key Talent
Management process and trainee programmes. We
have processes in place for employees who feel
our values are not being lived up to, or who have
questions about them. If employees face a dilemma
about the values, they can consult their manager,
compliance officer or the Values and Code Desk
of NN Group or of their business. They can also
report potential violations of the NN statement of
Living our Values and/or a breach of the NN Code of
Conduct confidentially and anonymously through our
whistleblower reporting system Speak Up.
Our Executive Board’s remuneration targets include
several strategic goals that relate to how we live our
values and meet objectives related to sustainable
long-term value creation. Read more on p. 105.
Monitoring effectiveness
We monitor the effectiveness of the Living our Values
programme. Our employee engagement survey, held
twice a year, includes various questions on values.
(See table on this page for more information.) At the
end of 2024, employees indicated a connectiveness
with our values of 8.3 (2023: 8.2). We strive to
score 8 or higher for the key questions on our values
across businesses, and this target was again met
in 2024. We also saw a slight increase in the scores
for each value. We also measure how customers and
the public perceive our values through the Global
Brand Health Monitor (GBHM). The values are part of
our brand, and over 50% of customers in almost all
markets (totally) agree with their alignment to the
NN brand. There are three exceptions where lower
percentages can be identified: Japan, the Czech
Republic and the Netherlands. Significant increases
compared to the GBHM of Q4 2023 can be identified
in Japan. Most markets are relatively stable across
the three values and the all-market average has also
remained relatively stable over the past three years.
When it comes to the general public’s perception
of our values, most markets show relatively stable
scores in comparison to Q4 2023. Japan, Slovakia,
Spain, Greece and the Netherlands show a significant
increase on the fit with the values in comparison to
Q4 2023. Using the monitoring results, the MB and
the Living our Values Project Group define areas for
improvement and next steps.
Evaluation of values
Each year, the MB receives a report detailing any
areas of concern in the Living our Values programme
and gives recommendations for improvements. The
report is approved by the MB and discussed with the
Supervisory Board, the Central Works Council and
the European Works Council. Our MB is ultimately
responsible for incorporating and maintaining the
values across the company as well as its affiliated
enterprises. We regularly review our NN statement
of Living our Values, and revise it where necessary
to ensure it remains relevant and aligned with
stakeholder expectations around our culture. We
last updated the statement in 2020. In 2024, we
introduced our new strategic commitment to become
a digital and data-driven organisation. In light of this
development, we performed a broader assessment
of our culture, concluding that the values are still
relevant in our changing environment, mainly
because of the close connection our colleagues
feel with them. However, we conducted internal
interviews, in-depth analysis of our employee
engagement surveys and feedback sessions with
our international leadership, which showed that our
culture could benefit from more specific guidance on
how we work together.
Enhancing our cultural framework
We recognise that clarity around how we interact
and collaborate is an important enabler of our
shared strategic initiatives that aim to build an
even stronger, more resilient and purpose-led
organisation. This is why, based on our values ‘care,
clear, commit,’ we have identified our NN behaviours:
Team up, Speak up, Step up. These provide internal
guidance on how we aim to collaborate, and our goal
is to make them an integral part of our HR processes.
We introduced our behaviours at the International
Leadership Conference in June 2024, and started
an awareness campaign with communications
and tools to familiarise employees with these
behaviours, explain how they align with our values,
and guide them in how to apply them in their daily
work. We also embedded the behaviours in our
talent acquisition and onboarding processes, and
leadership programmes. We plan to integrate them
into our performance cycle from 2025 onwards.
Monitoring how we live our values: employee engagement survey questions on our values
2024 2023
Care: ‘In our team we genuinely care about our customers and treat them with respect’ 8.5 8.4
Clear: ‘In our team we are easy to approach and communicate proactively and honestly’ 8.4 8.3
Commit: ‘In our team we take responsibility for our actions and deliver on our promises’ 8.5 8.4
‘I feel well connected with our values: care, clear, commit’ 8.3 8.2
‘If I experienced any kind of misconduct or unethical behaviour at work, I’m confident
NN Group would take action to address the situation’ 8.3 8.3
‘In our team, we openly discuss consistency of our actions with NN values
(care, clear, commit)’ 8.1 8.1
‘My manager consistently acts as a role model when it comes to living our NN values’ 8.4 8.3
NN Group N.V. Annual Report 2024 | 9
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NN Volunteer week 2024 –
bringing community
investment to life
NN Group aims to support the financial,
physical and/or mental well-being of one
million people by 2025. This year, 2,106
colleagues took up the call to action
during NN Volunteer week.
Impact story
2,106
colleagues signed up for
volunteer activities
8,308
volunteer hours in
Volunteer week 2024
8,827
people supported during
Volunteer week
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Social impact is the main driver of NN Group’s community investment
programme and according to Jeroen Koks, who works in the Community
Investment (CI) team and is himself a volunteer, there is nothing like
volunteering to bring it alive. ‘It is the best way to engage colleagues in
community investment,’ he says. ‘They really become part of the impact
we have on society.’
Company-wide
In 2024, there were over 7,000 participations in our company-wide
volunteering programme (some colleagues took part more than once).
The programme has been running since 2014 and this year the number
of volunteer hours over the year reached an all-time high of 42,049.
‘During NN Volunteer week, from 27 to 31 May 2024, we spread
the word across the organisation with flyers and online campaigns,
about how great it is to get involved. And it’s not just great for our
communities. It really gave me a sense of pride and connectedness to
our values.’
Battling loneliness
Colleagues can sign up either as individuals or as part of a team. This
year, in the Netherlands, team participation was more popular than ever,
with 1,300 colleagues signing up with their team. Activities ranged from
walking, gardening and playing games with the elderly, who often battle
loneliness, to giving children in poverty a birthday like never before. NN
Group Management Board members also rallied round, packing 500 of
some 6,000 gifts and birthday boxes for children.
Social connection is an important theme for community investment,
says Jeroen: ‘I visit 96-year-old Mientje regularly, taking her out in her
wheelchair for a breath of fresh air.Connecting multiple times really
deepens the connection.’
NN Charity Run
Perhaps the biggest event in the volunteering year is the NN Charity Run.
This year over 1,000 enthusiastic colleagues ran over 20,000 km, raising
EUR 122,530 for local charities to spend on making a positive impact
in our communities. Those who ran in Belgium for example, supported
Pinocchio, a non-profit organisation helping children suffering from
serious burns as well as their families. In Romania, employees ran for the
Association Inima Copiilor, which supports the expansion of the cardiac
surgery department at the Marie Curie Hospital in Bucharest, improving
the chance of survival for children with heart disease.
This year, during NN Volunteer week, we contributed to the financial,
physical and mental well-being of 8,827 people in our communities.
‘Participating in a candle-
making activity with the
elderly filled me with joy,
seeing how a small gesture
can make such a difference
in their lives.’
Valeria Tsaganidi, Business Analyst & Quality
Assurance specialist, NN Hellas, Greece
NN Group N.V. Annual Report 2024 | 11
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A conversation with our CEO
David Knibbe, Chief Executive Officer:
‘ Reflecting on our
performance in 2024,
I am proud of how we
continued to fulfill our
role and help people
care for what matters
most to them.’
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A conversation with our CEO
A conversation with our CEO
How do you look back on the year 2024?
The past year was marked by ongoing geopolitical
uncertainties and political polarisation across the
globe, and this has continued into 2025. Risks of a
global trade war are rising, which could impact the
economy and result in a return of high inflation and
increased market volatility. These developments
are impacting people’s lives and livelihoods, and
it underscores the importance of our industry
in protecting customers against unforeseen
circumstances.
Reflecting on our performance in 2024, I am proud
how we continued to fulfill our role and helped people
care for what matters most to them. We made further
improvements in customer satisfaction scores,
particularly in our European markets. By the end of
the year, we ranked at or above market average in
eight out of ten countries. Employee satisfaction
scores also showed an upward trend, indicating
our success in jointly creating an attractive work
environment. Our target of at least 40% women in
senior management positions was also achieved.
And through our community investment programmes
we have supported 766 thousand people since 2022.
Our strategic progress translated into a strong
commercial and financial performance. Our business
in Europe continued to show strong commercial
momentum, with higher sales of protection
and pension products thanks to our successful
distribution mix and new product launches. In the
Netherlands, our pension business also reported
continued growth, supported by strong net inflows
in defined contribution of EUR 2.3 billion, renewals
of existing defined benefit pension contracts and
pension buyouts. Our Dutch non-life business
maintained its robust performance and delivered
volume growth of 4.5%.
Our operating capital generation, our main financial
performance metric, was EUR 1.9 billion, and we
achieved our 2025 target one year ahead of plan. Our
capital position remained robust with a Solvency II
ratio of 194%. We proposed a final dividend of EUR
2.16 per share, bringing the total dividend for 2024
to EUR 3.44 per share, an increase of 8% compared
to 2023. In addition, in line with our policy, we again
announced an annual share buyback programme of
EUR 300 million.
All in all, we can look back on an excellent year, which
highlights the strength of our diverse businesses and
teams. It also demonstrates we are well on track in
the delivery of our strategy focused on customers,
our people, and contribution to society.
NN Group is accelerating its digitalisation
efforts. What is the main driver of this?
Expectations of customers and other stakeholders
are evolving rapidly, driven in particular by the
rapid developments in technology and artificial
intelligence. Therefore, at the end of 2023, we refined
our strategy and introduced a new commitment on
becoming a digital and data-driven organisation.
This update was prompted by our belief that we need
to enhance our capabilities in this area to remain
competitive and to be ready for the future.
Throughout the year, we made good steps in
this direction, with several initiatives across
the organisation. We are scaling AI applications
throughout the business and we are simplifying our
IT landscape through standardisation. Additionally,
we launched data literacy programmes for colleagues
to improve their digital skills. Of course, more work
remains to be done in the coming years, with the aim
to further grow our business and to stay financially
healthy but we are clearly off to a good start in this
area.
What did NN Group do in the area of
sustainability?
In 2024, we made further progress in reducing
our carbon footprint, for example in our corporate
investment portfolio we are in line with our 2025
target of a 25% reduction. We also further increased
our investments in climate solutions, bringing total
investments to EUR 12.8 billion by the end of 2024.
Additionally, we took further steps to support the
transition to a low-carbon economy through our
insurance underwriting activities. This included
the publication of our Responsible Insurance
Underwriting Policy, which will be implemented
in 2025. We also joined the Forum for Insurance
Transition to Net Zero) a new forum that aims to
support the acceleration and scaling up of voluntary
climate action by the insurance industry.
As NN Group, we have committed to aligning our
business activities with the goals of the Paris
Agreement to limit global warming to 1.5°C. However,
the 1.5°C target already seems to be out of reach.
Increasingly, attention is shifting to how we can
protect ourselves and others in a world of rising
temperatures and extreme weather. I strongly believe
that as a financial services company, we can also play
an important role here.
Our CEO David Knibbe looks back on 2024, a year in which we
reported very good results, despite an increasingly volatile external
environment making it more important than ever that we continue to
provide financial security for our customers.
NN Group N.V. Annual Report 2024 | 13
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A conversation with our CEO
Where do you see the biggest challenges
going forward?
Our ambition is to be recognised as an industry
leader known for our customer engagement, talented
people and contribution to society. Since launching
our current strategy in 2020, we have made
significant strides across all areas and are on track to
meet our targets for 2025. However, we operate in a
turbulent environment. Our industry faces numerous
challenges, including rapidly evolving customer
preferences, increased regulation, geopolitical
upheaval, market volatility and climate change.
The biggest challenge is to navigate this dynamic
landscape with agility and speed, while maintaining
our long-term focus. This year marks our 180th
anniversary, a testament to our resilience. However,
this resilience is not guaranteed, and we must remain
vigilant and fully focused on serving our customers
and other stakeholders.
‘ This year marks our 180th anniversary, a testament to
our resilience. However, this resilience is not guaranteed,
and we must remain vigilant and fully focused on serving
our customers and other stakeholders.’
Looking ahead, what are the focus areas for
2025?
We will continue to apply ourselves to fulfilling our
role as a financial services company. Of course, it
all starts with providing financial security for our
customers during key moments in their lives, whether
that is retirement, illness or an extreme weather
event. We will provide an update of our strategy and
new medium-term targets at our Capital Markets Day
in May 2025. With our leading market positions and
robust balance sheet, we are in a good position to
continue to grow and create sustainable long-term
value for our stakeholders.
Our people play a crucial role in this, and I would
like to thank them for their contributions and
commitment over the past year. I would also like to
thank my colleagues in the Management Board for
the great teamwork, and the Supervisory Board for
their guidance and support. And I especially want to
thank our customers and other stakeholders for their
trust in our company.
NN Group N.V. Annual Report 2024 | 14
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8
sustainable features
added
0
extra costs for customers
66%
of all damage to insured
buildings is repaired
through our sustainable
repair network
Adding sustainable
features to home
insurance
A recently launched, updated home
insurance product sets a new standard
for Dutch home insurance, making
sustainable repair the norm.
Impact story
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NN Group believes that by embedding sustainability deeper into our
home insurance product, we can support a circular economy and help
reduce environmental impact. That is why we have made sustainable
repair a cornerstone of this renewed product, making it the default,
instead of replacement.
Extra coverage
We have added eight new elements to the product, all of them
supporting our ambition to contribute to a more sustainable future.
These include better insulation when repairing damaged windows, roofs,
or other parts of the property, coverage for sustainable installations
such as heat pumps and charging stations, and for any damage to solar
panels that results in a loss of energy generation. Support for mental
well-being in the case of severe damage is also part of the package, as is
the repair of damaged electronics such as mobile phones.
An additional impact of this initiative is that it addresses the need for
sustainable houses in the Netherlands, a crucial step in light of the
country’s stricter emissions restrictions.
The new standard
The renewed product is already available to many of our retail customers
and will be rolled out further in 2025. It is now the standard home
insurance product in both our direct and bank insurance channels.
Maaike van Beijsterveldt, Director of Retail for Property and Casualty:
‘Sustainable repair is now a requirement for retail customers, at no
additional cost to them. For intermediaries, we take a more collaborative
approach, engaging with them and sharing knowledge on our efforts
around sustainability. We allow an element of choice there.’
Working together
By making sustainable repair the ‘go to’ option, supported by our
sustainable repair network of service providers, and adding more
sustainable features, we have set a new standard in the market.
‘However, we can’t create systemic change on our own, that’s why we
urge intermediaries to include sustainability in their dialogues with
customers. If insurers, other financial service providers and customers
all work together, we can make a real impact.’
‘If insurers, other financial
service providers and
customers all work together,
we can make a real impact.’
Maaike van Beijsterveldt,
Director of Retail for Property and Casualty
The world around us
As a financial services provider, we operate in a dynamic and
complex environment, impacted by geopolitical, economic, social,
environmental and technological developments. In this chapter,
we provide an overview of these challenges, and how we are
addressing them.
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The world around us
Political developments
Geopolitical challenges intensified during 2024 and
in 2025, exemplified by the ongoing war between
Russia and Ukraine, the conflict between Israel and
Hamas, and continuing (trade) tension between the
world’s large regional blocks, which exacerbated in
early 2025. NN Group does not have direct business
activities in the countries in these regions, and
limited financial exposure. However, continued
geopolitical instability, which may coincide with
other macroeconomic developments, could impact
our operations. Read more about the measures we
have in place to mitigate these (potential) impacts in
‘Managing our risks’, p. 51.
This year, the global political landscape saw growing
polarisation and fragmentation, as reflected in
the outcomes of the 2024 European Parliament
election and the US election. This trend became
apparent in several of our key markets, including
the Netherlands, Spain and Poland, and added to
the existing complexity and uncertainty. This could
pose a challenge to achieving progress on much-
needed reforms in pensions, housing and healthcare,
as well as to our initiatives in the area of climate
solutions; for market participants with a longer-term
perspective it could also lead to a lack of clarity.
In the Netherlands, a new coalition government
prompted concerns that certain (proposed)
measures, such as cuts in education, could have
negative long-term impact. However, although
all plans have not yet been finalised, many of the
initiatives launched by the previous government,
such as those related to sustainability and the
housing market, remain unaffected. One positive
development is the increased focus on the Dutch
business climate. This has already led to a reversal of
earlier plans to abolish the exemption of dividend tax
for share buybacks, for example, and there has been
a softening of tax arrangements for expats.
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The world around us
Economic shifts
The world economy continued to grow at the same
pace as in 2023. However, persistently high inflation
rates still complicated the normalisation of monetary
policy. Although inflation dropped significantly from
the high single digits seen in 2023, it remained above
2% in the Eurozone throughout 2024. Nevertheless,
the downward inflation trend allowed central banks
to gradually reduce interest rates. Upside inflationary
risks remained, including increased geopolitical
trade tensions and high public debt levels. Global
government debt levels remained high. In Europe,
particularly in France, the debt situation was
concerning. This financial instability is relevant for
NN Group in our role as investor, see ‘Managing our
risks’, p. 51.
After years of stagnation, economic growth across
the EU showed an upswing in 2024 but continued
to lag behind other parts of the world, such as
the US and Asia. Outside our Dutch home market,
substantially higher growth rates, of between 2.5%
and 3%, are forecast in many of the countries where
we operate.
One event that could affect our activities in the
coming years, is the publication of Italian economist
Mario Draghi’s report, ‘EU competitiveness: Looking
ahead’, which is expected to significantly impact
the policy agenda of the new European Commission
(EC). The report recommends, for example, a review
of the requirements in Solvency II, which governs EU
insurance capital regulations, as well as proposals
to stimulate second-pillar pension schemes and
a proposed 25% cut in the number of reporting
and stakeholders is the EU’s proposed Financial Data
Access Regulation (FIDA). While this is expected
to establish clear rights and obligations to manage
customer data sharing, the full scope of its impact is,
as yet, unclear.
As the Corporate Sustainability Reporting Directive
(CSRD) has not yet been transposed into Dutch
law, it is not yet effective for NN Group. We have,
however, voluntarily applied the requirements of the
ESRS that will become mandatory once the CSRD is
implemented in the Netherlands. See our disclosures
in the Sustainability Statement, p. 121.
In early 2025, there was a momentum to simplify
regulations in the EU, notably the ‘omnibus’ initiative
to simplify and harmonise regulations around
sustainability. The ambition is to reduce overlapping
requirements, enhance consistency and reduce
unnecessary administration.
Climate change
The reality of global warming is becoming
increasingly evident, impacting people’s lives
and livelihoods. As a result, the insurance
industry is facing the effects of more frequent
natural catastrophes such as storms, heatwaves,
devastating wildfires and flooding from heavy
rainfall, in Europe and across the world. NN Group
is incorporating plans to address this in our
investments, our insurance and banking products,
our own operations and in our reinsurance strategy.
We are constantly evaluating and developing ways
to lower our environmental impact. (See ‘Climate
Change’, p. 136 in the Sustainability Statement, for
obligations. The report also emphasises the need for
a more coordinated industrial policy, faster decision-
making and massive investments in innovation,
decarbonisation and security, if the EU wants to
remain competitive with economic rivals like the
United States and China.
Developing regulations
Growing international and national regulatory
requirements potentially impact NN’s operations and
solvency position. On 13 December 2023, the EC, the
European Parliament and the European Council all
reached an agreement on the draft Solvency II review
(Directive, Level I). The Directive was published in
the Official Journal in January 2025 and will come
into force in January 2027. In addition, secondary
legislation is currently being drafted by relevant EU
authorities.
On 1 August 2024, the EU’s Artificial Intelligence
Act (AI Act) came into force, establishing a common
regulatory and legal framework for AI across the
European Union. NN anticipated this regulation by
aligning its AI Framework to accommodate new
obligations that are included in this Act, which will
become applicable in phases.
More recent EU legislation, which took effect on 17
January 2025, is the Digital Operational Resilience
Act (DORA), aiming to strengthen the IT security of
financial entities. NN Group is dedicating significant
resources to ensuring compliance with these rules,
making our systems and operations even more
resilient to the increasing threat of cyberattacks or
other incidents. Also important for our organisation
details of how we are addressing climate change.)
Tech transformation
Rapid advancements in AI are driving a major
transformation across the financial sector. Generative
AI, machine-learning and AI-powered language
models are quickly reshaping how insurers interact
with customers, streamline operations and manage
risks. A key area of impact is customer service.
Customer enquiries and claims processes were
traditionally handled in the financial sector by human
agents. However, with the integration of generative
AI, customer wait time is being drastically reduced
and operational costs lowered, while at the same
time the technology is continuously improving,
providing ever more accurate and up-to-date
information.
In addition to improving customer services,
generative AI is helping insurers streamline critical
functions like claims processing. By automating
various aspects of claim management, insurers
and banks can significantly reduce the time it takes
to process claims, leading to faster payouts for
customers and increased efficiency for insurers.
The integration of generative AI also enables
personalised policy recommendations and improves
risk assessment. As the technology continues to
evolve, its impact on the financial service industry
is likely to grow, offering new opportunities for
insurers and banks to better serve their customers
and navigate the complexities of an ever-changing
market. Process mining, a technique to analyse event
data to better understand and improve operational
processes, currently supports NN Bank’s digital
NN Group N.V. Annual Report 2024 | 18
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The world around us
significant steps on the journey to net zero, we also
need to ensure that this transition remains inclusive
for all our customers, and that shareholders, who are
generally less focused on environmental, social and
governance (ESG) topics, receive strong returns on
their investments.
We believe it is important to stay in dialogue with
all our different stakeholders (see more about this
on p. 35). Stakeholder engagement gives us the
opportunity to share both our strategic choices
and the dilemmas we face, as well as gain valuable
insights into stakeholders’ perspectives, which
we can incorporate into our service and product
offering. By balancing all these different interests,
and remaining flexible in our response to our dynamic
external environment, we will continue to develop a
solid long-term strategy. (See p. 24 for details of our
strategy.)
experience for customers and brokers, leading to a
more cost-efficient way of working.
Beyond leveraging AI for customer value, NN
is also preparing for digital threats. AI can be
used defensively to mitigate cyberattacks and
protect against digital warfare. In an increasingly
interconnected world, both large and small-scale
events can bring global networks to a standstill.
The unpredictable nature of such crises highlights
the critical role insurers and banks play in offering
stability to customers and society during these
challenging times.
Navigating complexity
In today’s dynamic world, balancing the interests
of our various stakeholders is an increasingly
complex challenge. Citizens are often vocal about the
importance of sustainability, but as consumers, their
purchasing decisions are still largely driven by price
or investment return, especially with the increasing
cost of living. This presents a challenge, particularly
as we navigate political developments and shifting
ideologies on climate change, which can sometimes
hinder long-term planning or investments.
European regulators are imposing higher
sustainability requirements, expecting our sector
to take ambitious steps towards achieving net-zero
emissions. At the same time, non-governmental
organisations (NGOs) are calling for greater ambition
and faster progress from companies in addressing
sustainability challenges. But while we are taking
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The world around us
Our strategy and operating environment
Trends and developments KPI Sustainability mattersRisks
1
• NPS • Climate change
• Circular economy
• Clear and secure data
• Financial inclusion
• Employee engagement
• Women in senior management
• NN workers' secure and fair employment
• Employee well-being
• Equal treatment and opportunities for all
• Human capital development
• Investments in climate solutions
• People supported
• Climate change
• Nature (biodiversity and water)
• Workers in the value chain
• Community investment
• Operating capital generation
• Solvency II ratio
• Free cash flow (FCF)
• Corporate culture
• Clear and secure data
• Corruption and bribery
Our strategic commitments
Engaged customers
Talented people
Contribution to society
Financial strength
Digital & data-driven
organisation
• Geopolitical instability
• Economic developments
• Technological developments
1-Cyber (security) risk
5-Sustainable cost levels
6-Geopolitical instability
7-Being outrun by competition
2-Regulatory environment
6-Geopolitical instability
2-Regulatory environment
3-Global debt crisis
4-Climate change - transition risk for assets
5-Sustainable cost levels
6-Geopolitical instability
8-Longevity risk
9-Inflation risk
1-Cyber (security) risk
2-Regulatory environment
5-Sustainable cost levels
7-Being outrun by competition
• War for talent
• Political developments
• Economic developments
• Sustainability
• Regulatory developments
• Geopolitical instability
• Political developments
• Economic developments
• Sustainability
• Regulatory developments
• Geopolitical instability
• Technological developments
• Regulatory developments
1
The numbers in the table relate to the numbering within the strategic risk assessment (SRA) in ‘Managing our risks’.
NN Group N.V. Annual Report 2024 | 20
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Determining our material matters
Determining our material
sustainability matters
Our approach
For the DMA we use two perspectives throughout our
value chain to determine our material sustainability
matters.
These perspectives are:
• Impact materiality (inside-out): this assesses
how NN Group’s actions affect people and the
planet, both positively and negatively.
• Financial materiality (outside-in): this evaluates
how sustainability issues could impact NN Group’s
financial risks or opportunities.
In 2024, we refined our sustainability assessment
based on new insights, developments, and
stakeholder engagement, building on our 2023 DMA.
We identified and scored relevant sustainability
matters in 2023, and in 2024 we fine-tuned these
matters to align with our role as a financial services
A Double Materiality Assessment (DMA) helps us understand
and manage our sustainability impacts and financial risks and
opportunities. By looking at how our actions affect people and the
planet and how sustainability issues affect our financial situation,
we can make more informed decisions on our strategy and address
the needs of our stakeholders.
• For own operations, we looked at our own
operations around employees for social topics,
and our buildings and business travel for
environmental topics. We also assessed our own
operations in terms of governance.
• For investments, we looked at the impact and the
risks and/or opportunities incurred through our
investment activities.
• As a financial services company, we examined the
products and services offered by our Life, Pension
and Non-life businesses, and by NN Bank.
• Finally, as a business partner, we focused on our
upstream and downstream collaborations and
procurement activities, and collaboration with
financial advisors and repair networks. Please see
p. 124 for more information on our value chain.
Outcome DMA
On the following page, we visualise our DMA results.
In this overview, we have included our material topics
for our different value chain roles. We have also
included whether we identified a positive or negative
impact, financial risk or financial opportunity. We
have included a reference to the chapters of our
Sustainability Statement where you can find more
details on what we do on each material sustainability
matter with regard to policy, processes, targets,
actions and metrics.
company. This year, we actively engaged with
stakeholders, including internal experts and external
sector dialogues, to better understand and address
the most material sustainability issues, aiming
to reduce negative impacts and enhance positive
contributions.
Our roles in the value chain
During the DMA process, we considered actual and
potential impacts, positive and negative impacts,
and financial risks and opportunities across our
value chain. We defined our value chain for the
assessment, dividing it into four categories: own
operations, investments, products and services, and
business partners. We looked at our different roles
and how they link to the applicable sustainability
matters, enabling us to specifically identify where the
most material impacts, risks and opportunities occur
in our value chain.
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Determining our material matters
Positive impact
Negative impact
Financial opportunity
Financial risk
Roles ESRS¹
Environment
Environment
Environment
Environment
ESD⁴
Social
Social
Social
Social
Social
ESD⁴
Social
Social
Governance
Governance
Own operations³
Investments
Products and services
Investments
Products and services
Own operations
Own operations
Own operations
Own operations
Investments & business partners
Own operations
Products and services
Products and services
Own operations
Own operations
1
European Sustainability Reporting Standards.
2
Climate change: this relates to transition and physical climate risks related to investments in the long term.
3
We have identified climate change as material for our own operations for the greenhouse gas (GHG) categories for which we have set targets, since we have
seen that stakeholders assess these cateogries as material. For these categories we idenitified only a material negative impact.
4
Entity Specific Disclosure.
Climate change²
Nature (biodiversity and water)
Sustainable repair
NN workers' secure and fair employment
NN workers’ well-being
Equal treatment and opportunities for all at NN
Human capital development and attraction at NN
Workers in the value chain
Community investment
Financial inclusion
Clear and secure data
Corporate culture
Corruption and bribery
NN Group material sustainability matters
Financial materialityImpact materiality
Material topics
NN Group N.V. Annual Report 2024 | 22
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‘Insurance support in
sickness’ – how NN Poland
is addressing a hot topic
in healthcare
In Europe, consumers are increasingly
aware of the need for protection in times
of illness, which is why we are adding new
services to our Protection business. Like
in Poland, where we partnered with one of
the country’s largest medical service
providers.
Impact story
EUR 116.2m
value of new business for
Risk Protection products
sold in Europe in 2024
45.7%
of new business value
in Europe comes from
Protection products and
services facilities
NN Group N.V. Annual Report 2024 | 23
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The ‘insurance support in sickness’ programme adds medical
components to life insurance, allowing it to address two of the top
healthcare concerns in Poland: a lack of access to good medical care
and inadequate financial resources in cases of serious illness. For
now, it offers cover for those who are critically ill or in need of surgery.
But Michał Nestorowicz, responsible for its development, says the
programme may go on to address other healthcare issues, such as long-
term care or accidents.
‘Fast track’ healthcare
‘In Poland, as in many countries, you may have to wait months, or
even years, for surgery. Healthcare is a hot topic. Now, because of our
partnership with LUX MED, we can guarantee access to a specialist
within three days, and surgical treatment within 30 days. We also
provide a hospital care coordinator for the rest of a client’s healthcare
journey.’
‘This partnership provides
a gateway to modern,
innovative and high-quality
healthcare across the
country.’
Michał Nestorowicz, Individual Client Segment
Director, NN Poland
Financial support
Coverage is not just about treatment. The new programme supports
patients financially if they are diagnosed with a serious illness and
may also cover, for example, diagnostics or medical transport. ‘Our
partnership with LUX MED allows us to deliver coverage throughout the
entire trajectory.’
LUX MED, part of Bupa Group, owns 16 hospitals and 300 other medical
facilities in Poland, and cooperates with some 3,000 more. This
enables us to provide a gateway to modern, innovative and high-quality
healthcare services across the country.
Tailor-made
One of the reasons Michał likes to call it a ‘programme’ and not a
‘product’, is because policies change as a client ages, and becomes more
likely to contract certain ailments, like dementia for example. ‘And clients
can tailor the policy to suit their own individual needs.’
It’s early days yet, but uptake for the programme has been higher than
expected, and it is definitely opening up a new market segment in Poland
– the large majority of clients are new. ‘We are addressing a new need.
Not an existing need in new places.’
Our strategy
and business
Our strategy is built around creating long-
term sustainable value for our customers,
colleagues, shareholders and society. A
new strategic focus to become digital and
data-driven makes us more resilient and
responsive, further enabling us to deliver
relevant products and services.
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NN Group N.V. Annual Report 2024 | 25
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Our strategy
Our strategy
Our five strategic commitments are the guiding
principles in the execution of our strategy. They are
focused around customers, colleagues, shareholders,
and our role in society. Since 2020, we have made
good progress towards achieving our 2025 targets.
Customers and broker satisfaction scores have
showed an upward trend, driven in part by our
efforts in digitalisation and further strengthening our
distribution networks. Employee engagement scores
are at a high level in a tight labour market, and the
number of women in senior management positions is
at target.
We made progress on our net-zero targets for
our own operations, products and services and
investments. We increased contributions to our
communities through a wide range of partnerships
focused on financial, mental and physical well-
being. We have also consistently delivered a strong
commercial and financial performance, resulting
in a robust balance sheet and solid returns for
shareholders.
Supported by our strong foundation, we ensure our
strategy remains well aligned with long-term market
trends, such as pension reforms and the need for
protection in many of our European markets. At
the same time, we continuously need to evolve
as the financial services industry is facing various
challenges, from changing customer preferences
and increased regulation to geopolitical upheaval
and volatile financial markets. Our industry is also
increasingly facing risks related to climate change.
As of 2024, we refined our strategic focus by
introducing a new commitment to become a ‘digital
and data-driven organisation’. This update reflects
our ambition to responsibly use technology and data,
enabling us to drive operational excellence across
the company and further improve the customer
experience. This will give us the ability to continue
growing our business and make us ready for the
future.
Our ambition is to be an industry leader known for
customer engagement, talented people and our
contribution to society. Since the launch of our strategy in
2020, we have made good progress.
Engaged customers
We deliver an outstanding customer
and distributor experience, and
develop and provide attractive
products and services.
Talented people
We foster a values-based culture
and empower our colleagues to be
their best.
Contribution to society
We contribute to the well-being
of people and the planet.
Financial strength
We are financially strong and seek solid
long-term returns for shareholders.
Digital & data-driven
organisation
We use technology and data
responsibly to transform our business
and drive operational excellence.
Our strategic commitments
We help people care for what matters most to them
Our ambition
We want to be an industry leader known for
our
customer engagement, talented people
and our contribution to society
Our purpose
Our values
Care Clear Commit
Our brand promise
You matter
On par
NPS-r
Netherlands businesses
2023: on par
2025 target: above market
average
Above
NPS-r
International businesses
2023: above
2025 target: above market average
NN Group N.V. Annual Report 2024 | 26
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Progress on our commitments
Progress 2024
Customer satisfaction
We are committed to offering a superior experience for customers and
agents. We track the satisfaction of our customers through the relational
Net Promoter Score (NPS-r), which measures how likely it is that they will
recommend our products and services to colleagues, friends or family.
In 2024, customer satisfaction, by way of the NPS-r score, continued its
positive trend, particularly in our European markets. At the end of 2024,
8 out of ten markets scored on par with, or above, market average.
Supporting customers’ plans for retirement
Across our markets, we are supporting customers to prepare for
retirement. In the Netherlands, our online pension platform, mijn.nn
Inkomen Later, reached the milestone of having over 1 million pension
participants. The platform provides participants with clear insights into
their retirement finances, and offers several options, such as making
extra contributions and arranging a supplementary partner’s pension.
See p. 49 for more on this, as well as how NN is responding to the
sweeping pension reforms in the Netherlands. In Spain, we launched a
pension plan for the self-employed, which is designed to complement
public benefits and therefore offer greater financial security to self-
employed workers.
Shift to protection in Europe
In our European markets, we continued to respond to the increased
customer risk awareness with a shift to protection products. In Spain,
we launched a solution that combines life insurance with healthcare
coverage options. In the Czech Republic, we introduced a long-term care
Progress on our commitments
insurance with tax deductibility, helping customers plan for their old age.
In Belgium, we launched a protection product for the self-employed,
offering coverage for incapacity due to accident or illness alongside
well-being services. Finally, in Poland, we partnered with a large medical
service provider, facilitating access to high-quality healthcare. Read
more about this on p. 22.
Home insurance with sustainable features
We enriched our home insurance offering in the Netherlands with a range
of sustainable features. In the event of damage, we offer customers the
option of repair instead of complete replacement, for example for mobile
phones. We also help customers make their homes more sustainable by
installing better insulating glass and applying sustainable solutions to fix
part of the damage. We also enable the transition to bio-based materials
in Dutch housing. Read more on p. 24.
Our customers are the starting point of
everything we do. We engage with them to
meet their needs and offer solutions that create
sustainable long-term value. We use our digital
capabilities and leverage our strong distribution
footprint to further enhance our customer
experience.
Engaged
customers
Employee engagement
202420232022
7.97.87.9
2021
7.7
2020
7.9
Women in senior management positions
202420232022
41%40%40%
2021
34%
2020
33%
NN Group N.V. Annual Report 2024 | 27
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Progress on our commitments
Progress 2024
Employee engagement
We measure our people’s connection to their work and our company,
and how we are progressing against our goals, through our bi-annual
employee engagement survey. By better understanding our employees’
perceptions, we can improve our working environment. The overall
engagement score in 2024 was 7.9 (the financial industry benchmark
is 8.0), a slight improvement compared to the previous year. In the
survey, the main strengths were in the area of personal goal-setting and
management support. Our colleagues also value the freedom to manage
their work and feel connected to our values. Process efficiency and
workload were mentioned as areas for improvement.
Data literacy
One of the biggest challenges in a digital transformation process is the
need to develop digital skills in the organisation. We want to support our
people in developing these skills, which is why we have rolled out a data
literacy programme for colleagues. The programme aims to support them
in building data and digital capabilities. This year, senior management
was upskilled in data and AI, and the curriculum for management and
employees will be rolled out in 2025. We also launched a digital training
programme across our business units that included eight hours of
training on topics such as AI, data analytics and IT-related skills. Read
more on p. 31.
Top Employer
For the sixth consecutive year, all business units within NN International
Insurance were certified as Top Employer. In the certification process,
NN International business units, on aggregate, showed significant
progress compared to last year in the areas of work environment, well-
being and career. Individually, NN International business units achieved
far and above benchmark scores in their results.
We nurture a culture aligned with our purpose,
values and ambitions – one that supports
continuous learning, collaboration and diversity
of thinking. We consider all colleagues as
talents, and invest in an inclusive and inspiring
environment that makes us optimally equipped
for the future.
Talented
people
Diversity, equity and inclusion
Percentage of women in senior management positions
EUR 12.8bn
investments in climate
solutions
2023: EUR 10.8bn
2030 target: EUR 11bn
766k*
people supported in
our communities
2023: 401k
2025 target: 1m
*
Cumulative number of people
supported since 2022.
NN Group N.V. Annual Report 2024 | 28
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Progress on our commitments
Contribution
to society
We aim to contribute to the well-being of people
and the planet. We do business with the future
in mind and contribute to a world where people
can thrive for many generations to come.
Climate solutions
In 2024, we invested a cumulative amount of EUR 12.8 billion in climate
solutions, such as renewable energy structure, certified green buildings
and green bonds. The investments are part of our broader target to aim
to achieve net-zero greenhouse gas (GHG) emissions by 2050 for our
proprietary investments. Read more on p. 177.
Responsible insurance underwriting
We published our first Responsible Insurance Underwriting Policy.
The policy, which will be implemented in 2025, sets standards
for implementing sustainability in our insurance activities such as
underwriting and product development. For example, in the area of
insurance underwriting, we aim to stop providing insurance services
to companies that derive their revenues from thermal coal mining,
tobacco products or controversial weapons and arms trade. For product
development, we have incorporated sustainability matters as one of the
factors we take into account in product approval and review processes.
We aim to reach net zero with our insurance underwriting portfolios by
2050 and we published our first intermediate targets in 2023.
Industry initiative towards net zero
We joined the Forum for Insurance Transition to Net Zero (FIT), a new
forum that aims to support the much-needed acceleration and scaling
up of voluntary climate action by the insurance industry and key
stakeholders. FIT draws on the experience gained with the Net-Zero
Insurance Alliance (NZIA) that first transformed net-zero insurance from
theory into practice. We joined FIT as a founding member because we
believe collaboration and knowledge-sharing with key players in the
international (re)insurance market is essential for the financial industry
to reach its net-zero targets.
Progress 2024
Community investment
We supported 365 thousand people with their financial, physical and/
or mental well-being in 2024. This means that, since 2022, we have
supported a total of 766 thousand people through our programme. We
continued existing partnerships and developed new ones to support our
target. As well as direct support for those in need through contributions,
we also support our partners in building their capacity, and support
knowledge development through research institutions.
Financial health and debt
For over a decade, we have been committed to enhancing financial
resilience and addressing the issue of poverty caused by problematic
debt in the Netherlands. Our dedicated team supports mortgage
customers facing financial difficulties through personalised solutions
such as payment arrangements, temporary payment pauses or
budget coaching, while also taking proactive steps to prevent financial
problems. Beyond individual support, we actively participate in initiatives
like the National Coalition for Financial Health (NCFG) and we chair the
Creditors Coalition. These initiatives aim to address the issue of poverty
and problematic debt through innovative public-private collaboration,
focusing on the financial well-being of all.
Operating capital generation
x EUR billion
202420232022
1.91.91.7
2021
1.6
2020
0.9
Progress 2024
NN Group N.V. Annual Report 2024 | 29
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Progress on our commitments
Financial
strength
We are committed to maintaining a strong
balance sheet and creating solid financial
returns for shareholders. We uphold this
commitment by leveraging our financial
strength, scale and international footprint and
efficiently managing portfolio assets, both
those of our customers and of NN.
Strong financial results
In full-year 2024, our operating capital generation (OCG) was EUR 1.9
billion, reflecting an increase from 2023 and exceeding the EUR 1.9
billion target set for 2025. This was mainly driven by the continued
business growth of Insurance Europe, which partially offset the
normalisation of the strong OCG in 2023 by the segments Other,
Banking, and Netherlands Non-life.
Free cash flow
Free cash flow (FCF) increased by 8% to EUR 1.5 billion, from EUR 1.4
billion in 2023, which is adjusted for the capital injections into NN Life
and NN Spain and the one-off dividend from NN Life Belgium, with better
diversification between the business units. We are comfortably on track
to deliver on the FCF target of EUR 1.6 billion in 2025.
Solvency
The Solvency II ratio of NN Group decreased to 194%, from 197% at
the end of 2023, mainly due to adverse market impacts and regulatory
changes, partly offset by management actions.
Capital return to shareholders
Our results continue to support our commitment to a capital return
policy of an increasing dividend per share, and a minimum annual share
buyback of EUR 300 million. Read more about these results on p. 46.
NN Group N.V. Annual Report 2024 | 30
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Progress on our commitments
We aim to excel in developing and providing
attractive products and services, and to operate
with efficiency, agility and speed. To continue
doing so, we will make use of digital and data
capabilities.
Digital and
data-driven
organisation
Helping colleagues use advanced AI tools
We launched Generative AI Applications (GAIA), a new knowledge
base platform designed to help colleagues use advanced AI tools like
chatbots and content generation without needing to code. GAIA enables
colleagues to streamline tasks, access information faster, and work more
efficiently, ultimately reducing costs. The platform is constantly evolving,
with ongoing updates to enhance self-service capabilities and introduce
new features. At the end of the year, GAIA was live with a limited number
of knowledge bots, but plans are underway to scale production. Read
more on p. 63.
Scaling Gen AI applications across the business
In 2023, we developed a tool that supports call centre colleagues by
providing an automatic summary of their conversations with customers.
This helps our colleagues save time and reduce their workload, as they
previously had to log customer conversations. Following the launch in
the Netherlands, the tool was scaled and implemented in Spain and
Japan.
We also redesigned our email classification, which uses AI to distribute
incoming customer emails to the right teams and people. The solution,
which is now using GenAI technology instead of machine learning,
provides better results and is easier to implement and maintain because
less model training is needed. It is currently in production at our banking
business in the Netherlands with more businesses to follow.
Simplifying our IT landscape
We continue to make progress on streamlining our technology landscape
by standardising applications, infrastructure and networks. As part of
this effort, we are in the process of introducing the NN Digital Hub. With
the establishment of the NN Digital Hub, we aim to build and retain IT
knowledge and skills across the Group, and be able to attract digital
talent. The hub will be located in Prague and Madrid.
Progress 2024
NN Group N.V. Annual Report 2024 | 31
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
300
senior managers took part in
the DLP in 2024
1,500
managers will have completed
the DLP by 2026
+/- 16,000
colleagues have access to the
Fundamentals track
>17,000
DLP upskilling hours in 2024
> 7,000
colleagues used our internal
Chat GPT programme this year
‘Data is everyone’s
business’
This year, NN Group introduced a new
strategic commitment to become a digital
and data-driven organisation. The
company-wide NN Data Literacy
Programme (DLP) empowers colleagues
to help us achieve this ambition.
Impact story
NN Group N.V. Annual Report 2024 | 32
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Every process in NN Group involves data. It is essential to our products
and services. We store it to ensure the financial safety of our customers.
‘And in the new world, where AI is increasingly commonplace, colleagues
need to know how to use it, register it and talk about it,’ says Hiske
Hoekstra, responsible for Learning and Talent Development at NN Group.
Securing future relevance
The NN Data Literacy Programme (DLP) has three target groups:
senior management, management and employees. This year, senior
management was upskilled in data and AI, and the curriculum for
management and employees will be rolled out in 2025.
There will be two tracks to the employee curriculum. The first will give
employees new skills around data and AI that could make them eligible
for different work. ‘The world is changing fast, and one skill set is no
longer good for life. To stay successful in the AI-impacted financial
sector, we continue to invest in the relevant skills for colleagues.
Data is everyone’s business.’ The second, the Fundamentals track,
will be mandatory except for those who are already data/AI experts,
empowering the entire workforce to increase its own, and the
organisation’s, efficiency, functionality and impact.
A common language
An important part of the DLP is to create a common language around
data. Collaboration starts with mutual understanding, and the
programme enables this by creating a common, Group-wide vocabulary.
‘Our businesses know where the challenges are, and our tech people
know what solutions we have in our toolbox. When both talk the same
language, there will be fewer roadblocks to change.’ This will not only
speed up how we optimise our processes, but also how we act on
insights.
ChatGPT
One part of the programme that is particularly useful is an internal
ChatGPT programme which is already used by over 7,000 colleagues
to test generative AI. Safe, controlled and fully GDPR-compliant, it is
allowing colleagues to use their new tech know-how to test their ideas
before our experts take them to the next level. ‘And the great thing is,
because this technology is so cool, everyone is keen to get on board.’
‘The world is changing fast,
and one skill set is no longer
good for life. To stay
successful in the AI-impacted
financial sector, we continue
to invest in the relevant skills
for colleagues.’
Hiske Hoekstra, Head of Learning and Talent
Development
NN Group N.V. Annual Report 2024 | 33
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Value creation model
How we create value
We provide retirement services, pensions, insurance, banking and investments to around 19 million customers.
By doing so, we aim to create sustainable long-term value for all our stakeholders.
Inputs What we do
Financial capital
Including debt, equity, revenue and
assets invested by clients
• shareholders’ equity: EUR 19.8bn
• gross premium income: EUR 14bn
Intellectual capital
Internal processes, systems
and controls
Natural capital
Use of natural resources
• total energy used:
37 GWh (of which 41% of the
electricity used was renewable)
Human capital
Employees’ skills, time and
resources
• total number of employees: +/- 16k
• amount spent on training and
development per employee: EUR 1.220
• applying our values
Manufactured capital
Company’s products, offices
and other physical assets
Social and relationship capital
Relations with customers and
other stakeholders
• customers: around 19m
• business partners and suppliers
• other key stakeholders
(e.g. regulators)
We help people
care for what
matters most
to them
We want to be an industry
leader, known for our
customer engagement,
talented people, and
contribution to society
Product development and pricing
We develop products and services to meet societal
and customer needs. Our experience and strong
understanding of risk means that we are able to offer
attractive insurance and banking solutions at a fair price.
Distribution
We distribute our products through a range of channels,
including directly to customers, and through banks,
agents and brokers. We leverage our scale and diverse
business footprint for cross-selling opportunities.
Investments
We invest the insurance premiums and fees that
we receive. We have a well-diversified portfolio for
our investments, and are guided by our Responsible
Investment Framework policy.
Claims and benefits
We use our digital capabilities to achieve a seamless
customer experience, including a simpler, more
personalised claims handling process.
What we do...
2
3
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Life insurance
Netherlands
Europe
Japan
Non-life insurance
Netherlands
Europe
Banking
Netherlands
Our activites
Profit
Our profit is what remains
after expenses. These include
claim payouts, pension benefits,
interest on customer deposits,
impairments and operating
costs (e.g. wages).
Income
We generate income through
insurance premiums and fees paid
for our products and services.
We also generate returns
on the investments
we make.
Business partner
We want to be
a strategic and
responsible business
partner.
Service provider
We want to offer
our customers
peace of mind.
Employer
We want to foster
an open, safe and
inclusive working
environment.
Investor
We want to
deliver resilient
and growing
capital generation.
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Strategic commitments
NN Group N.V. Annual Report 2024 | 34
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Value creation model
How we create value
Outputs: the benefit for our stakeholders
Customers
We offer customers peace of mind
through a seamless experience.
Our
products help protect their families, health, income,
companies and property. We also safeguard their
personal data and provide mortgages and a stable
source of income in retirement.
Society
We contribute to the well-being of
people and the planet.
We take a
long-term and responsible approach to investments
and underwriting, working to reduce our direct and
indirect impact on the environment. We contribute
to our communities and support the economy
through taxes and payments to intermediaries and
other business partners.
Investors
We are committed to delivering
resilient, and growing, long-term
capital generation.
To do so, we maintain a
strong balance sheet and create solid financial
returns by using our financial strength, scale and
international footprint.
Our people
We provide adequate wages and
other benefits.
We also contribute to our
people’s pensions. In addition, we offer skills
training and opportunities for career development.
We provide an inspiring, inclusive and innovative
place to work.
We have identified key Sustainable Development Goals (SDGs) where we can make the most impact through
our products, services, investments and community programmes. See ‘Annex’, p. 213.
Excellent customer
experience
Attract and retain
talent
Contribution to society Capital returns and
resilient balance sheet
NN Group N.V. Annual Report 2024 | 35
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Stakeholder engagement and international commitments
Stakeholder engagement
and international
commitments
promote thought leadership on sustainability issues.
For an overview, refer to our corporate website. By
taking an active role in these partnerships, we can
increase the impact of the capital we put to work.
We use our engagements with expert groups and
industry organisations such as the Partnership
for Carbon Accounting Financials (PCAF) and the
Institutional Investors Group on Climate Change
(IIGCC) to potentially refine our sustainability
activities, for example in our commitments and
target setting regarding net zero. These societal
and network organisations generally act on behalf
of affected parties, including people, nature and
animals, aiming to minimise adverse impacts on
them. We use the outcomes of engagements with
these organisations in our policy development and
thought leadership and for strengthening our due
diligence process.
Stakeholder Engagement Policy
Our Stakeholder Engagement Policy outlines the
principles we uphold and the approach we take
regarding our relations with stakeholders and
how we balance their interests. The policy covers
engagement on various aspects of NN Group’s
strategy, focusing on sustainable long-term value
creation, and is based on our purpose and values of
care, clear, commit. The scope covers NN Group’s
material activities and is available on our corporate
website.
Strategy and business model
We aim to best understand the interests and
perspectives of key stakeholders concerning our
strategy and business model, and address any
concerns they may have, by engaging with them
regularly through a range of channels, for example
in roundtables, calls and during our Annual General
meeting (AGM). These dialogues and interactions
also give us an opportunity to explain our strategic
choices and dilemmas. This means that we need to
stay flexible to adapt to their shifting expectations
and to changing regulations. The dialogue on relevant
aspects of the strategy and other related topics
is part of regular (or dedicated) meetings we hold
between the Executive Board, Management Board
and Supervisory Board. See ‘Governance’ on
p. 65 for information on how sustainability is
embedded across NN Group.
NN Group engages in ongoing dialogue with stakeholders on a
variety of topics, ranging from products, services and business
performance to our role in society. By endorsing national
and international sustainability initiatives, we underline our
ambitions and join forces with other organisations to increase
our leverage in this area.
Stakeholder engagement
Engagement is vital to earning and maintaining
the trust and support of stakeholders, and to fulfil
our duty as a responsible and engaged company.
We identify stakeholders based on their potential
to affect or be affected by our business and have
identified the following key stakeholder groups:
customers, colleagues, business partners,
investors, analysts, regulators, government
agencies, agents and intermediaries, societal and
network organisations, expert groups and industry
associations. The group of stakeholders we engage
with is not static and can be adjusted depending on
the topics of the dialogue and how they develop over
time.
How we engage with our stakeholders is visualised
on p. 38. We consider the insights we have gained
from stakeholder interactions when making strategic
and business decisions. By incorporating these
insights and other feedback into our strategic
planning process and daily operations, as well as into
our Double Materiality Assessment (DMA), we aim to
ensure that our business strategy is aligned with the
needs and expectations of stakeholders.
NN Group has endorsed several national and
international sustainability initiatives, and we
are a member of various relevant international
organisations. These include partnerships to share
best practices, develop industry guidance and
NN Group N.V. Annual Report 2024 | 36
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Stakeholder engagement and international commitments
initiating mitigation efforts. See ‘Social’ on p. 179 for
more information.
Agents and intermediaries are another important
type of business partner. We hold joint dialogue
sessions with agents and intermediaries where we
discuss our plans, receive their input and priority
topics, and provide feedback. We also engage with
them through user research, broker surveys and
feedback mechanisms in our digital and contact
centre channels. This can lead, for example, to new
products, services, features and ways of working.
As a result of these sessions, we work on combined
propositions such as good employership, business
continuity and well-being, driven by market demands.
These engagements have prompted us to invest in
new and better digital connections, for example by
improving our digital portal for advisors.
Society
We consider input from key societal stakeholders
to be essential in policy development, specifically
on climate change mitigation and adaptation. This
reflects our acknowledgement of the urgency in
reacting to climate change and associated external
developments around the topic, such as sector
guidance and stakeholder insights. We first included
climate change as a topic in our reporting in our 2017
Annual Report, when we endorsed the Task Force on
Climate-related Financial Disclosures (TCFD). Our first
Climate Action Plan was published in 2022. Input
from stakeholders was also taken into account when
drafting our Responsible Insurance Underwriting
Framework Policy (for more information, see p. 203).
Colleagues
We gather insights from colleagues through our
Peakon engagement survey, which includes a section
on our strategy and the extent to which respondents
feel our business goals and strategies guide us in
the right direction. The outcomes of the survey are
discussed with the Management Board, and we
define relevant actions to be taken. See ‘Social’ on p.
179.
Customers
We engage with customers through user research,
customer surveys and feedback mechanisms in our
digital and contact centre channels. Through these
engagements, we aim to build a better understanding
of their needs and increase trust and customer
satisfaction. We prioritise customer experience
investments in our processes and digital platforms
based on these engagements and use customer
input to develop new products and propositions. See
‘Social’ on p.179. for more information.
Investors and analysts
We are committed to delivering strong and
sustainable returns to our investors for the capital
they provide to NN Group. Our engagements with
both investors and analysts give us an opportunity
to understand their views on our strategy execution
and business model, as well as address any concerns
they may have.
Regulators and government agencies
When it comes to engagements with regulators
and government agencies, we are in continuous
dialogue with them about our vision on legislative
developments, as well as our strategic choices and
dilemmas as a financial services provider. We aim
to contribute to fair and effective regulations, and
advocate for a level playing field in the legislative
and regulatory process. We maintain an element
of flexibility in our long-term strategy to adapt to
developments, shifting expectations and regulations.
Business partners
We integrate the interests of our business partners
by collaborating with our suppliers on socioeconomic
issues, striving for fair labour conditions, focusing
on human rights, setting clear expectations
concerning conduct and actively engaging suppliers
on ESG issues. During the supplier qualification
process, suppliers are asked to share details of
their labour policy so we can assess that there
are fair working conditions for their employees.
We also aim to mitigate human rights risks in
our supply chain by asking suppliers to disclose
measures taken to prevent modern slavery and
human trafficking in their own business and supply
chain. In 2024, we developed and implemented
a supplier environmental, social, and governance
(ESG) engagement programme to inspire actions
on selected environmental and social issues and
assess suppliers’ positions on ESG topics. We also
conducted risk-based engagement with suppliers to
identify their position (beginner, advanced or leader)
on climate change and social issues, with the aim
of helping accelerate our suppliers’ journey to net
zero by measuring emissions, setting targets and
Sector initiatives and commitments help us develop
methodologies and undertake other activities
that support us in realising our climate goals. See
‘Environment’ on p.134 for more information.
We also engage with companies in our investment
universe and have regular discussions with civil
society organisations about the sustainability
risks and impacts we may be linked to through
our investment activities. Representatives from
NN Group’s Sustainability and Social Impact
(SSI) department and Investment Office regularly
participate in webinars, roundtables, conferences
and other knowledge-sharing initiatives that involve
discussions with topic experts and cover a range
of issues related to sustainability matters. We
actively seek dialogue with NGOs throughout our due
diligence process if the NGOs signal specific (severe
human rights-related) issues to us, or if we have
concerns about a specific sustainability case. We
aim to understand their findings and, where relevant
and possible, incorporate these into our responsible
investment policies and activities. Potentially
affected rightsholders can also report their
grievances to us, including those related to human
rights and environmental issues. We recognise that
we can improve the accessibility of our grievance
mechanisms for stakeholders which is why we will be
working on enhancing the mechanism. See ‘Social’ on
p.179 for more information.
With regards to our community investment activities,
we have regular contact with societal partners, such
as charitable organisations and social enterprises,
NN Group N.V. Annual Report 2024 | 37
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Stakeholder engagement and international commitments
with the aim of creating a positive impact in our
communities. We aim to support the financial,
physical and/or mental well-being of one million
people by 2025, and through our engagement we
try to evaluate whether our activities are the right
ones to achieve this ambition. Through regular
and evaluative conversations about the needs of
our partners, we seek to improve our community
investment programme.
International Responsible Business Conduct
Agreement
We actively participate in the International
Responsible Business Conduct Agreement for the
Dutch insurance sector, which aims to further align
the insurance sector’s investment activities with
international standards and guidelines on responsible
business conduct. The agreement is in line with
our own approach to these subjects. The scope of
the agreement is NN Group’s investment activities.
Alongside the Dutch insurance sector, signatories
include the Dutch government, the Dutch Association
of Insurers and several NGOs. Together, they pool
their knowledge and experience to better identify and
mitigate adverse ESG impacts in line with guidelines
from the Organisation for Economic Co-operation
and Development (OECD), as well as initiate steps
to mitigate those impacts. As part of the agreement,
we were one of several companies involved in a
collective engagement process aimed, amongst
other things, at preventing further biodiversity loss.
The five-year term of the agreement ended in 2023
and we have, in collaboration with other insurers,
started a follow-up initiative on specific topics such
as health and food, and biodiversity, guided by the
Dutch Association of Insurers and the participation of
several NGOs and experts. For more information, see
the visual on p. 38.
Looking ahead
In the meantime, we continue to prioritise and
improve stakeholder engagement. Our use of Peakon
is ongoing, as is our commitment to considering
the views of societal and network organisations in
our regular policy updates and target setting. In the
coming year, we aim to further exchange insights
with our stakeholders on a wide range of topics.
We understand that their perception of NN Group
will depend on to what extent they see their inputs
reflected in our policies and actions.
NN Group N.V. Annual Report 2024 | 38
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Stakeholder engagement and international commitments
Stakeholders, engagement, topics and outcomes
Customers
Investors
Society
Our people
Business
partners
Regulators
Stakeholders
Engagement Topics discussed Outcomes
Economic and financial market developments, risk
assessments, insurance regulations, pension and
labour market regulations, sustainable finance,
ESG, digitalisation.
User research, surveys and
feedback mechanisms in digital
and contact centre channels.
Customer experience. New and better digital experiences for
customers.
Support needs of partners, evaluation of
programmes.
Inform and engage partners and provide
input to improve our strategies and develop
new projects and programmes.
Customers
We aim to support our customers in dealing with expected and
unforeseen changes in the key moments in their lives through
offering products and services.
We strive to contribute to the well-being of people and the planet
through, for example, integrating sustainability factors into our
underwriting activities and managing our direct environmental footprint.
Knowledge sessions,
one-on-one and group
meetings, membership
meetings, roundtables.
Human rights, defence policy development,
ratings, animal welfare, biodiversity, active
ownership.
Development and update of policies and
ratings, input on negative impacts, building
on expertise.
One-on-one and group
meetings, knowledge sessions,
working groups, roundtables.
Impact assessment, data tools, corporate
engagement, policy engagement, human rights
due diligence, just transition, Nature Action Plan
for propriety.
Policy development, sharing knowledge/
views, engagement.
Societal and
network
organisations
Expert groups
and industry
associations
Communities
Suppliers
We want to contribute to a world where people can thrive for
generations to come, for example, by investing our assets
responsibly, by being a fair taxpayer, and through our activities in the
communities where we live and work.
Leadership and other (digital)
conferences, surveys, works
councils, unions.
Business strategy engagement, Pay Transparency
Directive, upskilling/reskilling employees, action
plans.
Inform and engage employees,
improve policies or communication.
Research, surveys, roundtables,
webinars, (digital) visits.
Conversations, evaluation
questionnaire, social
media.
Supplier ESG engagement
programmme.
Climate change, gender equality and equal pay. Regular dialogue and reporting between supplier
and contract manager.
Market topics in general, co-creation, products
and services.
Understanding their needs, increased
intermediary satisfaction and trust,
well-informed brokers.
Memberships of boards and
working groups of various
institutions and trade
organisations
Exchange views and insights, understanding of
strategic choices and dilemmas, insight into their
perspectives.
Colleagues
Agents and
intermediaries
Government
agencies
Our NN colleagues together create a culture that is based on
our values and purpose, and that supports a flexible and
open mindset.
We have relationships with many partners in our value chain,
including intermediaries and other entities linked to our
operations.
We aim to support the financial, physical and/or mental well-being
of people in the communities in which we operate.
We are committed to making sustainable procurement decisions
and encourage our suppliers to do the same.
We have direct engagements with public decision-makers and
regulators concerning regulatory and financial market-related issues.
Annual shareholders meeting,
analyst calls, investor meetings,
survey, (ESG) conferences.
Strategy, financial and operational developments,
capital position, approach to sustainability.
Inform and engage with analysts,
shareholders and other investors.
Investors,
analysts
We are committed to delivering strong and sustainable
returns for the capital that investors provide, and are clear and
transparent in how we communicate.
NN Group N.V. Annual Report 2024 | 39
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EUR 5m
the amount we committed
to the two partnerships
launched this year
150,000
the number of young
people we hope to reach
in the Netherlands
through our partnership
with Noaber
40,000
the number of
adolescents and
caregivers we hope
to reach through our
partnerships with SOS
Children’s Villages and
Save the Children
2021
the year NN made mental
(and physical) well-being
a strategic priority
‘Part of the solution’ –
how NN Group is helping
improve the mental well-
being of young people
Young people face a growing number of
challenges to their mental well-being,
creating an urgent need for targeted
support and prevention. NN Group is
meeting this need with two new
partnership programmes.
Impact story
NN Group N.V. Annual Report 2024 | 40
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
The world continues to be rocked by emergencies, challenging both the
physical and mental resilience of communities everywhere. And it is
often children and young people who are most at risk. NN Group feels
responsible for future generations and acknowledges that we cannot
solve societal challenges on our own. But we can be part of the solution.
Fostering positive social environments
In 2024 we launched two programmes to support young people facing
challenges to their mental well-being, one in the Netherlands and one
across all our markets. Mentale Gezondheid en Veerkracht (Mental
Health and Resilience) was developed with the Dutch Noaber Foundation
to prevent and reduce mental health issues among under-25s. Running
until the end of 2026, it aims to reach 150,000 young people in the
Netherlands, using workshops and other resources to foster positive
social environments, as well as teaching children practical techniques to
deal with stress and help build resistance.
Nurturing resilience through collaboration
The second programme, Mental Well-Being and Resilience for the Next
Generation, is a Group-wide partnership with SOS Children’s Villages
and Save the Children and will also run for two years. The joint venture
is designed to provide children, adolescents and their caregivers with
crucial resources and care to support their long-term mental well-being.
‘The global percentage of children with mental health issues is still far
too high, says Pim Kraan, CEO Save the Children Nederland. ‘Thanks to
our partnership with NN, we can improve mental health and psychosocial
well-being for children, adolescents and their families in five countries,
supporting thousands of young people at risk.’
Ongoing support
‘Mental health challenges can lead to loneliness, social isolation and
anxiety’, says Lonneke Roza, Head of Community Investment. ‘People
need support and guidance to break the harmful cycle that repeats from
one generation to the next. Through these new partnerships, we aim
to break this cycle, and equip adolescents and caregivers with tools to
support their long-term mental well-being.’
Lonneke adds that NN Group has chosen for long-term commitments
because it allows for sustained impact and deeper engagement. ‘We
recognise that mental health challenges often require ongoing support
rather than one-time interventions.’
‘This partnership is creating
lasting change, supporting
children to reach their full
potential and shaping brighter
futures for generations to
come.’
Sandra Sahusilawani, SOS Children’s Villages
International
NN Group N.V. Annual Report 2024 | 41
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Our
performance
Despite this year’s volatile geopolitical
environment, we reported excellent results
and exceeded our 2025 target for operating
capital generation for the second year in a
row. A strong business performance and
a resilient balance sheet drove attractive
capital returns for shareholders.
NN Group N.V. Annual Report 2024 | 42
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Our business performance
Our business performance
Our excellent results this year highlight the strength of our diverse
businesses and show we are on track in delivering our strategy
focused on customers, our people, and contribution to society.
Operating capital generation increased slightly to EUR 1.9 billion,
ahead of the 2025 target. There were strong business performances
across the Group, particularly in Europe and Netherlands Non-life.
NN Group
Key figures
amounts in millions of euros 2024 2023
Operating capital generation
1
1,922 1,902
Value of new business 395 330
Operating result
2
2,574 2,528
Net result 1,583 1,172
Solvency II ratio
3
194% 197%
1
Operating capital generation is an Alternative Performance
Measure, which is not derived from IFRS-EU. NN Group analyses
the change in the excess of Solvency II Own Funds over the
Solvency Capital Requirement (SCR) in the following components:
Operating Capital Generation, Market variance, Capital flows
and Other. Operating capital generation is the movement in the
solvency surplus (Own Funds before eligibility constraints over
SCR at 100%) in the period due to operating items, including the
impact of new business, expected investment returns in excess
of the unwind of liabilities, release of the risk margin, operating
variances, non-life underwriting result, contribution of non-
Solvency II entities and holding expenses and debt costs and the
change in the SCR. It excludes economic variances, economic
assumption changes and non-operating expenses.
2
Operating result is an Alternative Performance Measure. This
measure is derived from figures according to IFRS-EU. The
operating result is derived by adjusting the reported result before
tax to exclude the impact of result on divestments, amortisation
of acquisition intangibles, discontinued operations and special
items, changes to losses from onerous contracts due to
assumption changes, gains/losses and impairments, revaluations
and market and other impacts. Alternative Performance Measures
are non-IFRS-EU measures that have a relevant IFRS-EU
equivalent. For definitions and explanations of the Alternative
Performance Measures, reference is made to Note 28 in the
Annual accounts.
3
The solvency ratio is not final until filed with the regulators. The
Solvency II ratio for NN Group is based on the partial internal
model.
Consolidated results
• Strong OCG of EUR 1.9 billion in full-year 2024,
reflecting an increase from 2023 and exceeding
the EUR 1.9 billion target set for 2025, mainly
driven by continued business growth of Insurance
Europe partially offsetting normalisation of the
strong OCG in 2023 from the segments Other,
Banking, and Netherlands Non-life.
• The result before tax increased to EUR 1.9 billion
over 2024 from EUR 1.5 billion over 2023, which
contained a provision related to the unit-linked
insurance products settlement. The net result
increased to EUR 1.6 billion from EUR 1.2 billion in
2023.
• FCF up 8% year-on-year to EUR 1.5 billion, with
contribution better diversified between business
units.
• Value of new business (VNB) increased 20% to
EUR 395 million over 2024, reflecting organic
growth of volume and margins in Insurance
Europe, and an increase in NL Life mainly driven by
higher defined benefit pension sales and pension
buyouts.
• Netherlands Non-life gross written premiums
increased ~4.5% on a like-for-like basis driven by
premium increases and volume growth.
• Operating result over 2024 increased from the
previous year to EUR 2.6 billion, driven by business
growth of Insurance Europe, partly offset by a
lower operating result of Banking and Netherlands
Life.
Strong delivery on targets and attractive
shareholder returns
• Operating capital generation (OCG) for 2024
reached EUR 1.9 billion, reaching our 2025 target
a year ahead of plan.
• Free cash flow (FCF) up 8% year-on-year to EUR
1.5 billion, with contribution better diversified
between business units.
• Dividend per share also up 8% year-on-year,
reaching EUR 3.44; annual EUR 300 million share
buyback programme announced.
• Solvency II ratio remains robust at 194%, mainly
due to adverse market impacts and regulatory
changes, partly offset by management actions.
• Full-year operating result increased to EUR 2.6
billion; the net result increased to EUR 1.6 billion
from EUR 1.2 billion in 2023.
Strong business performance supported by
excellent commercial momentum
• Value of new business increased 20% to EUR 395
million, driven by organic growth and higher
margins in Europe and higher defined benefit sales
in Netherlands Life. Net inflows in the defined
contribution pension business in 2024 were
EUR 2.3 billion, boosting assets under
management above EUR 39 billion.
• Insurance Europe exceeded its OCG target of
EUR 450 million one year ahead of schedule,
mainly supported by strong pension performance
and new business growth.
• Netherlands Non-life showed strong performance
in 2024 with ~4.5% premium growth on a like-for-
like basis driven by premium increases as well as
volume growth, and achieved a strong level of OCG
at EUR 406 million. The combined ratio was 93.1%.
• Customer satisfaction scores continue positive
trend with eight out of ten countries ranking at or
above market average; number 1 broker
satisfaction scores at Dutch life and pension
businesses as well as P&C commercial lines.
• Continued progress in reducing carbon footprint of
corporate investment portfolio; total investments
in climate solutions increased to EUR 12.8 billion.
NN Group N.V. Annual Report 2024 | 43
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Our business performance
Netherlands Life’s OCG increased compared to 2023,
mainly due to a higher investment spread resulting
from wider government bond and mortgage spreads.
Higher defined benefit pension sales and pension
buyouts resulted in a higher VNB. In 2024, new
defined contribution inflows again exceeded EUR 2
billion, boosting assets under management above
EUR 39 billion.
Netherlands Non-life maintained its strong
performance in 2024, despite higher fire claims in
the first quarter. Gross written premiums increased
~4.5% on a like-for-like basis driven by premium
increases and volume growth. OCG slightly declined
from the strong results of 2023.
Insurance Europe exceeded its target of EUR 450
million in OCG one year ahead of schedule. The
sustained commercial momentum led to organic
growth in both sales and margins.
OCG for Japan Life remained broadly stable despite
lower sales following the improvement order issued
by the local regulator in the first quarter of 2023.
Banking OCG was lower than the strong results of
2023, but stayed robust despite a more normalised
net interest margin.
The segment Other continued to perform well, mainly
due to favourable debt costs, investment results, and
positive experience in the reinsurance business.
Operating capital
generation
amounts in millions of euros 2024 2023
Investment return 1,351 1,226
Life - UFR drag −152 −163
Life - Risk margin release 226 250
Life - Experience variance −63 14
Life - New business 199 180
Non-life underwriting 288 329
Non-Solvency II entities (Japan
Life, Banking, Other) 343 333
Holding expenses and debt costs −306 −293
Change in SCR 35 26
Operating capital generation 1,922 1,902
NN Group’s OCG for the full year 2024 increased to
EUR 1,922 million compared to EUR 1,902 million in
2023, reflecting continued business growth of
Insurance Europe partially offsetting normalisation of
the strong OCG in 2023 from the segments Other,
Banking, and Netherlands Non-life.
Netherlands Life’s OCG rose to EUR 1,049 million,
mainly due to a higher investment spread resulting
from wider government bond and mortgage spreads,
partly offset by unfavourable experience variances.
NN Group’s Solvency II ratio was 194%, which is at
the top of our 150-200% comfort range. Adverse
market impacts from most notably wider sovereign
spreads and regulatory changes were largely offset
by management actions.
FCF increased 8% to EUR 1.5 billion from EUR 1.4
billion in 2023, which is adjusted for the capital
injections into NN Life and NN Spain and the one-
off dividend from NN Life Belgium, with better
diversification between the business units. We are
comfortably on track to deliver on the FCF target of
EUR 1.6 billion in 2025.
Our results continue to support our commitment to
a capital return policy of an increasing dividend per
share and a minimum annual share buyback of EUR
300 million.
Operating capital generation
Operating capital
generation per segment
amounts in millions of euros 2024 2023
Netherlands Life 1,049 1,025
Netherlands Non-life 406 416
Insurance Europe 461 422
Japan Life 108 107
Banking 119 133
Other −221 −201
Operating capital generation 1,922 1,902
Netherlands Non-life reported a sustained strong
OCG of EUR 406 million, only slightly down from EUR
416 million in 2023, which was a very strong year. In
2024, property & casualty (P&C) claims benefited
from mild weather, offsetting large fire claims in the
first quarter. Both P&C and Disability experienced a
higher new business contribution compared to the
full year 2023. Insurance Europe continued its
impressive growth trajectory with a 9% increase in
OCG to EUR 461 million in full-year 2024, mainly due
to higher volumes and margin.
OCG of Japan Life remained broadly stable at EUR
108 million. Lower technical results and adverse
currency effects were offset by a higher reinsurance
result.
The OCG of Banking decreased to EUR 119 million
from EUR 133 million, mainly due to a less favourable
interest margin, partly offset by lower capital
consumption as a result of higher housing prices.
The OCG of segment Other was EUR -221 million in
full-year 2024, compared with EUR -201 million in
2023. OCG from reinsurance remained elevated but
was lower than in 2023, mainly due to less
favourable experience variance. The OCG of the
holding remained stable.
NN Group N.V. Annual Report 2024 | 44
Our business performance
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Analysis of results
amounts in millions of euros 2024 2023
Netherlands Life 1,368 1,390
Netherlands Non-life 364 364
Insurance Europe 559 468
Japan Life 203 197
Banking 189 226
Other −108 −118
Operating result 2,574 2,528
Non-operating items −520 −524
- of which gains/losses and
impairments −1,036 −345
- of which revaluations 535 94
- of which market and other
impacts −20 −272
Special items −89 −462
Acquisition intangibles and
goodwill −28 −29
Result on divestments 19
Result before tax 1,936 1,532
Taxation 334 348
Minority interests 19 13
Net result 1,583 1,172
Basic earnings per ordinary
share in EUR 5.58 4.04
Operating result
The operating result of NN Group increased to
EUR 2,574 million from EUR 2,528 million in 2023.
The strong performance of Insurance Europe was
partly offset by a lower interest result at Banking and
a lower investment result at Netherlands Life.
The operating result of Netherlands Life decreased to
EUR 1,368 million from EUR 1,390 million in 2023,
primarily due a lower investment result.
Netherlands Non-life’s operating result remained
stable at EUR 364 million. The combined ratio for
full-year 2024 was 93.1%, compared with 92.6% in
2023. P&C claims benefited from mild weather. The
combined ratio of P&C increased to 91.9% from
91.5% in 2023, mainly reflecting large fire claims in
the first quarter. The technical result on the Disability
portfolio was lower compared to 2023, which
benefited from a favourable claims experience,
whereas the result on expenses and claims was
lower in 2024. The combined ratio of Disability
increased to 96.0% from 95.2% in 2023. We expect
the Disability portfolio’s combined ratio to remain
higher as the contractual service margin builds up
over time.
For Insurance Europe, the operating result increased
by 19% to EUR 559 million, driven by business
growth, strong pensions performance, and higher
technical results.
Japan’s operating result slightly increased to EUR
203 million as a higher insurance result was partially
offset by adverse currency impacts.
The operating result for Banking decreased to EUR
189 million from EUR 226 million in 2023, mainly due
to lower interest margins resulting from ECB rate
cuts.
The operating result of the segment Other was EUR
-108 million compared with EUR -118 million in
2023. The holding’s operating result improved due to
a higher investment result. The 2024 operating result
of the reinsurance business was lower than in 2023.
Result before tax
The result before tax increased to EUR 1,936 million
from EUR 1,532 million in 2023, which contained a
provision of EUR 360 million related to the unit-linked
insurance products settlement.
Gains/losses and impairments were EUR -1,036
million compared with EUR -345 million in 2023.
Full-year 2024 primarily reflects the sale of debt
securities and mortgages at Netherlands Life as a
result of management actions.
Revaluations amounted to EUR 535 million versus
EUR 94 million in 2023. 2024 mainly shows
revaluations on real estate and other assets such as
private equity and infrastructure.
Market and other impacts amounted to EUR -20
million compared with EUR -272 million in 2023,
which mainly included non-operating losses on
onerous contracts including assumption changes.
Special items amounted to EUR -89 million compared
with EUR -462 million in 2023, which contained a
provision of EUR 360 million related to the unit-linked
insurance products settlement. Special items in 2024
mainly relate to non-operating project expenses.
Net result
The net result of full-year 2024 increased to
EUR 1,583 million from EUR 1.172 million in 2023.
The effective tax rate (ETR) was 17.3%, mainly
reflecting tax-exempt investment results.
Sales and value of new business
Sales and value of new
business
amounts in millions of euros 2024 2023
Gross premiums written 13,978 13,187
New sales life insurance (APE) 1,348 1,229
Value of new business 395 330
Assets under management DC (in
EUR billion) 39.1 32.7
Gross premiums written increased 6% to EUR 14.0
billion. The growth was mainly driven by three
pension buyout transactions in the Netherlands and
higher sales in Europe. Gross written premiums of
Netherlands Non-life increased ~4.5% on a like-for-
like basis driven by premium increases and volume
growth.
NN Group N.V. Annual Report 2024 | 45
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Our business performance
Total new sales (APE) rose by 10% to EUR 1.3 billion.
Insurance Europe reported strong new sales,
benefiting from its solid distribution partnerships.
Netherlands Life also reported higher sales from
renewals of existing defined benefit pension
contracts, and three pension buyout contracts
totalling EUR 0.9 billion.
The VNB increased by 20% to EUR 395 million from
EUR 330 million over 2023, reflecting an increase in
Netherlands Life and organic growth in Insurance
Europe.
The VNB of Netherlands Life increased to EUR 88
million from EUR 46 million over 2023, due to high
defined benefit sales, pension buyouts as well as a
benefit from longevity reinsurance on immediate
annuity products and buy-outs.
The VNB of Insurance Europe increased to EUR 254
million from EUR 219 million over 2023, reflecting
strong sales performance across the region in all
channels and products as well as a favourable
product mix.
The VNB of Japan decreased to EUR 53 million from
EUR 65 million, primarily due to lower sales of cash
value insurance products as a result of the business
improvement order, and negative currency impacts.
Assets under management DC increased to EUR 39.1
billion from EUR 32.7 billion as of 31 December 2023,
driven by net inflows of EUR 2.3 billion and positive
market movements.
Delivering on enhanced investor proposition
1
Based on normal weather and normalised mortgage margins, otherwise financial markets on 1 January 2024.
Resilient balance
sheet
Group SII ratio
194% (31 December 2024)
Higher capital quality
• Relatively low UFR benefit
• Reduced longevity risk and final
settlement of unit-linked issue
Robust investment portfolio
• High-quality real estate
portfolio
• Solid mortgage book, with
negligible default experience
Low leverage ratio
Attractive capital
return
Dividend per share
EUR 3.44 (2024 full-year
dividend)
Annual share buyback
At least EUR 300m
Additional excess capital to be
returned unless used for value-
creating opportunities
Upside to capital return
If NN Group SII ratio is sustainably
above 200%
Strong business
performance
Delivering on financial
targets 2025
Operating capital generation
EUR 1,922m (2024)
2025 target: EUR 1.9 bn
1
Free cash flow
EUR 1,519m (2024)
2025 target: EUR 1.6bn
NN Group will hold its Capital Markets Day on 27 May 2025
NN Group N.V. Annual Report 2024 | 46
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Creating value for investors
Creating value for investors
We are committed to delivering strong and sustainable capital
returns for our shareholders. We actively engage with our
shareholders and bondholders, and aim to be clear and transparent
on our strategy, financial results and operating developments,
so they can make informed investment decisions.
With the 2023 full-year results we demonstrated
confidence in our increased business performance by
raising the operating capital generation (OCG) target
for 2025 to EUR 1.9 billion from EUR 1.8 billion. Our
balance sheet was strengthened by two longevity
reinsurance transactions in 2023 and the removal of
litigation overhang following the milestone
settlement with interest groups on Dutch unit-linked
insurance products. On the back of solid business
performance and a strong balance sheet, we
expressed further comfort in our ability to generate
free cash flow (FCF) by setting an explicit target of
EUR 1.6 billion for 2025, an increase of
approximately EUR 100 million. We immediately
passed this upgrade on to our shareholders through
an accelerated 15% year-on-year increase of the
dividend per share and raised the annual minimum
share buyback to EUR 300 million from EUR 250
million.
Throughout 2024, our business performance was
solid, highlighted by an OCG of EUR 1,922 million.
This result supports our confidence in meeting our
increased targets. Within the strong OCG delivery, we
would like to highlight the continued commercial and
business momentum within Insurance Europe and
Netherlands Non-life. These segments continue to
enhance their contribution to overall Group
performance, resulting in a diversified business and
earnings mix.
Our Solvency II ratio remained robust at 194% at the
end of 2024 compared to 197% at the end of 2023.
Decisive management actions largely
counterbalanced the market headwinds coming
mainly from the widening of spreads in government
bonds. Additionally, FCF reached EUR 1.5 billion, a
8% year-on-year increase, well on track to achieve
our target of EUR 1.6 billion in 2025.
As such, we believe our 2024 performance is a
strong testimony to our ability to deliver on our 2025
targets. We have also announced a Capital Markets
Day on 27 May 2025, where we aim to provide
additional insights into our strategy and targets for
the businesses beyond 2025.
Share buyback
Dividend
Grafiek bevat fake cijfers;
voor ontwerp bedoeld
2025E20242023202220212020201920182017201620152014
DPS 2015-2023: 10% CAGR
1.51
0.57
1.55
1.66
1.90
2.16
2.33
2.49
2.79
3.20
3.44
6.6
3.5
10
Share buyback (in billions)
Dividend per share
1
Dividend (in billions)
Accumulated pay-out to shareholders
1,2
Returned EUR 10bn to shareholders since IPO in 2014
Continuing our attractive capital return trajectory
1
Dividend per share in EUR based on declared amounts in book year.
2
Total dividend amounts in EURm are shown on a cash out basis. Total share buyback amount in EURm shown in the year that
the programme commences. 2025 dividends and share buybacks in this graph are indicative and in line with our capital return
policy of a progressive dividend per share and annual share buyback of at least EUR 300m.
Rest of the World
Rest of Europe
The Netherlands
United Kingdom
Asia
United States
United States
Asia
United Kingdom
The Netherlands
Rest of Europe
Rest of the World
39%
4%
19%
10%
27%
1%
Shareholder by country/region
Shareholder analysis by Investor Update at
September 2024 (%)
NN Group N.V. Annual Report 2024 | 47
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Creating value for investors
Dividend policy
NN Group intends to pay a progressive ordinary
dividend per share in cash and execute an annual
share buyback of at least EUR 300 million. Additional
excess capital is to be returned to shareholders,
unless it can be used for value-creating
opportunities. When proposing a dividend or
announcing a share buyback programme, NN will take
into account, among other things, its capital position,
leverage and liquidity position, regulatory
requirements and strategic considerations as well as
expected developments thereof.
Dividends
On 27 August 2024, NN Group paid an interim
dividend of EUR 1.28 per ordinary share, which was
calculated in accordance with the NN Group dividend
policy. The proposed 2024 final dividend of EUR 2.16
per ordinary share plus the 2024 interim dividend of
EUR 1.28 per ordinary share gives a total dividend for
2024 of EUR 3.44 per ordinary share. This represents
an increase of 8% compared to the 2023 dividend per
share. Read more on p. 271.
Share buybacks
On 20 February 2025, NN Group announced it would
execute an open market share buyback programme
for an amount of EUR 300 million. The programme
will be executed within ten months, and commenced
on 3 March 2025. The share buyback will be deducted
from Solvency II Own Funds in the first half of 2025
and is estimated to reduce NN Group’s Solvency II
ratio by approximately 3%-points. NN Group reports
weekly on the progress of the share buyback
programme on its corporate website. Read more on
p. 373.
Share capital
The authorised share capital of NN Group N.V.
consists of ordinary shares and preference shares.
Currently, only ordinary shares are issued, while a call
option to acquire preference shares has been granted
to NN Group Continuityfoundation (Stichting
Continuïteit NNGroup). Read more on p. 74.
Dec
23
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
24
90
100
110
120
130
140
150
NN Group
Euro STOXX Insurance index
Listing
NN Group ordinary shares are listed and traded on Euronext Amsterdam under the symbol NN.
NN Group N.V. Annual Report 2024 | 48
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Creating value for investors
Authorised and issued capital (in EUR million)
Year-end 2024 Year-end 2023 Year-end 2022
Ordinary shares
– authorised
84 84 84
– issued 32 34 35
Preference shares
– authorised
84 84 84
– issued 0 0 0
Number of shares in issue and shares outstanding in the market
Year-end 2024 Year-end 2023 Year-end 2022
Authorised share capital (in shares) 700,000,000 700,000,000 700,000,000
Issued ordinary shares 269,000,000 285,000,000 295,000,000
Own ordinary shares held by NN Group 1,574,203 11,138,500 13,608,384
Outstanding ordinary shares 267,425,797 273,861,500 281,391,616
Major shareholders
According to the Autoriteit Financiële Markten (AFM)
register as at 25 February 2025, the following
shareholders had an interest of 3% or more in NN
Group on the notification date:
• BlackRock, Inc. 6.6% (29 May 2024)
• Norges Bank 5.0% (17 March 2023)
• Amundi Asset Management 3.1% (7 February
2025)
• State Street Corporation 3.0% (30 December
2024)
• Thornburg Investment Management 3.0%
(3 April 2023)
Please refer to the AFM register of substantial
holdings and gross short positions for more details
on the nature and characteristics of these interests.
Ratings
Credit ratings
On 23 May 2024, Standard & Poor’s affirmed NN
Group’s ‘A+’ financial strength rating and the ‘A-’
credit rating with a stable outlook.
On 6 November 2024, Fitch Ratings affirmed NN
Group’s ‘AA-’ financial strength rating
1
and ‘A+’ credit
rating with a stable outlook.
The latest rating reports can be found on our website.
Sustainability ratings
We are rated on sustainability by specialist research
agencies such as Sustainalytics (14.3/100, low risk),
MSCI (AA) and CDP. We are also included in indices
such as FTSE4Good. An overview of all sustainability
indices and ratings can be found in the appendix on
p. 405.
1
Financial Strength rating for Nationale-Nederlanden Levensverzekering Maatschappij N.V.
1st
place awarded to BeFrank, by the Dutch
Ministry of Finance’s PensioenWegwijzer,
for making pension choices easier
25%
more completed risk profiles since we
introduced a new risk profile assessor
>1m
active participants on NN’s pension
portal
NN Group N.V. Annual Report 2024 | 49
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Making pensions more
personal
Shifting demographics and less predictable
career paths are impacting today’s
pension landscape. Especially in the
Netherlands where sweeping reforms are
forcing employers to alter their pension
schemes. NN is frontrunner in facilitating
that transition.
Impact story
NN Group N.V. Annual Report 2024 | 50
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
On 1 July 2023, the Wtp (Wet toekomst pensioenen, or Future Pensions
Act) came into effect in the Netherlands. While the demographic and
economic trends that have prompted this new regulation are similar
across Europe, individual governments respond differently according to
local regulations. Reforms in the Netherlands are particularly
comprehensive, and pension funds have until 2028 to comply with them.
NN is already able to offer pension products that are Wtp-compliant.
Lower risk appetite
One of the main changes the Wtp brings is a shift from ‘defined benefit’
plans, with predetermined payouts, to ‘defined contribution’ plans,
where what you receive depends on your total contribution and the
performance of investments. ‘Given the volatile investment landscape,
declining interest rates and an ageing population, employers are less
‘A lot of people have a pension
scheme, but it’s often based
on default settings. Now
they can personalise it.
Our challenge is motivating
them to do so.’
willing to take risks,’ says Gerard van Rooijen, Director NN Life and
Pensions. Today’s population is not only ageing but is staying fit longer
and people want to get the most out of their retirement. NN is supporting
them in this ambition by adding new features and services to help
customers personalise their pension scheme.
Matching customers’ needs
One of the features that is having a lot of impact is the Pensioen APK,
which involves regular dialogues between advisors and employees at set
moments in their employment – when they start their job, at fifty, and
just before they retire. There are questions, for example, about how
dependant they will be on their pension, how much they understand the
investment landscape and if they want to invest sustainably, and
advisors give them the information they need to make the decision that’s
right for them. And it motivates them to become more engaged. ‘Let’s
face it, pension is not exactly at the top of most people’s agendas. They
may have a pension scheme, but it’s often based on default settings.
Now they can personalise it. Our challenge is motivating them to do so.’
Sustainability options
We have also made our online platform Mijn Inkomen Later more
user-friendly, and improved our Human Capital Planner − a platform for
advisors and employers, who can use it to benchmark their pension
profile in the market. BeFrank, our Pension Premium Institution, offers
three levels of ‘sustainable buy-in’ giving more choice to the end-user
about where to invest their money. ‘We are also exploring how AI could
improve the way we communicate with customers.’
In the Netherlands, NN has about 40% of the pension market outside
pension funds. ‘We also have a solid history, a wealth of knowledge and
an ambition to remain innovative. We were first to market with products
that are Wtp-compliant and are proud of that. We are moving from selling
pension products to supporting people to get the best out of their
pension scheme, contributing to their financial well-being.’
Gerard van Rooijen, Director NN Life and
Pensions
Managing
our risks
Our risk strategy enables NN Group to make
informed decisions and take conscious risks
to maximise our potential to deliver on our
commitments to our stakeholders.
NN Group N.V. Annual Report 2024 | 51
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NN Group N.V. Annual Report 2024 | 52
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3. Mitigate risks through controls and/or other
mitigation measures; and
4. Monitor effectiveness of mitigating measures and
report on them.
This cycle is supported by a sound risk culture.
The risk control cycle is integrated within NN Group
and supports the strategy (business plan process)
and (monitoring of) the subsequent execution
(among others, financial control cycle and HR cycle).
Step 1: Risk strategy
The risk strategy is determined together with the
business strategy. During this strategy-setting
process, strategic and emerging risks need to be
considered carefully. These risks, for example, look
at sensitivities around assumptions behind the
proposed business strategy, or the possibility that
a proposed business strategy does not align with
NNGroup’s values and You Matter brand promise (as
mentioned in chapter 2 ‘Our strategy and business’).
The risk strategy further clarifies what risks (and to
what extent) NN Group is willing to take in pursuit
of business objectives. Risk appetite statements
describe how NN Group weighs strategic decisions
and communicates its strategy to key stakeholders
and business unit CEOs with respect to the desired
level of risk-taking. They thereby define our
preferences for or against certain risk types. This
helps us avoid unwanted or excessive risk taking, and
optimise our use of capital. To the extent necessary,
the risk appetite can be further operationalised into
risk metrics (see under ‘Risk metrics’ in this chapter).
Furthermore, requirements and/or guidance on how
to mitigate risks can be provided through policies and
standards.
Embedding a sound risk culture within properly
organised and governed business processes and
projects is an important part of NN Group’s risk
strategy. More information on how risk management
responsibilities within NN Group are organised can be
found under ‘Corporate governance’ on p. 81-85.
Introduction
This section covers the following topics:
• Risk control cycle (p. 52-59)
• Risk profile, with a focus on material risks as
established by NN Group’s Management Board
(p. 59-62).
Other relevant risk management information can be
found in the following sections:
• The Risk governance section of ‘Corporate
governance’ (p. 81-85) covers how risk
management responsibilities within NN Group are
organised.
• Details on our financial risk profile can be found in
Note 48 Risk management.
• Details on sustainability and climate change-
related risks are included in ‘Anticipated financial
effects’ on p. 159 of the Sustainability Statement.
Risk control cycle
We manage any risks inherent to our business model
and the environment in which we operate within
NN Group’s risk appetite and framework. Every
employee has a role to play in identifying risks in
their area of responsibility and managing them in a
proactive way. It is important to know which risks
we need to avoid and which we are prepared to take,
to ensure an adequate return for the risks assumed
within the business, and to be aware of major
existing and emerging risks.
The risk control cycle supports that business units
and NN Group operate within our risk appetite:
1. Define risk strategy through risk appetite, policies
and standards;
2. Identify and assess the risks that need to be
managed;
Managing our risks
Risks represent potential future events that could
adversely impact our business performance and achieving
our strategic targets. Strong risk management helps us
monitor developments in our operating environment and
act where necessary.
NN Group N.V. Annual Report 2024 | 53
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Risk taxonomy
NN Group has defined and categorised its risk landscape in a risk taxonomy:
Risk appetite statement Risk class Description
Strategic risks
Managing strategy External strategic risks Emerging or changing risks in NN’s external environment that may not yet be fully assessed or quantified (‘uncertainties’)
but that could, in the future, affect the viability of NN Group’s strategy.
Internal strategic risks Risks related to shaping NN’s business arising from making incorrect business decisions, implementing decisions poorly
or being unable to adapt to changes in NN’s operating environment.
Financial risks
Solvency risks Market risks Risks related to (the volatility of) financial and real estate markets.
Counterparty default risks Risks related to the failure to meet contractual debt obligations.
Underwriting & pricing risks Financial risks related to insurance liabilities due to inadequate pricing and provisioning assumptions
(i.e. product-related risks from an NN perspective).
Liquidity risks Liquidity risks Risks related to not being able to settle financial obligations when due.
Non-financial risks
Sound business conduct Business conduct risks Risks related to unethical or irresponsible behaviour when doing business or representing the business (red lines).
People conduct culture People conduct risks Risks related to the attitude and behaviour of our workforce.
Product suitability Product suitability risks Product-related risks from a customer perspective.
Operational risks Business operating risks Risks related to inadequate or failed business processes (internally, or externally performed by business partners).
Technology risks Business technology risks Risks related to inadequate or failed information technology (for example cyber risk).
Reliable reporting Business operating risks Risks related to inadequate or failed business processes (internally, or externally performed by business partners).
Business continuity Business continuity risks Risks of accidents or external events impacting continuation or security of (people or assets in) our business operations.
NN Group N.V. Annual Report 2024 | 54
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Our key risk appetite statements are:
Risk appetite statement Risk appetite Description
Managing strategy Moderate We create long-term value for all our stakeholders and contribute to the well-being of people and planet, so we
continuously evaluate and adapt our business model to the external environment (product portfolio, distribution
channels, organisation, etc.) to meet evolving customer needs. When doing so, we moderately accept risks from the
same, including in attracting and retaining business leaders and (world class) talents.
Solvency risks Moderate to actively pursue for
rewarding risks
We accept financial risks on our balance sheet so we can offer financial security through products and services for our
customers as well as predictable and attractive returns for our investors. We only accept risks that we understand, can
price and effectively manage. We like to avoid having to raise equity capital after a 1-in-20-year event.
Limited for non-rewarding risks Market and counterparty default risks: In managing our investments, we generate excess return by taking spread,
liquidity, default, equity and property risk as we consider those rewarding risks. We limit exposure to, or volatility due
to, non-rewarding risks (in particular concentration, interest rate, currency and inflation risk) or risks to which we
already have a high exposure.
Underwriting and pricing risks: Underwriting risks are at the core of our business; we deem them rewarding and actively
pursue them. We have moderate appetite for risk concentrations in our portfolios (in particular longevity risk and
windstorm risk), and actively manage those through reinsurance.
Liquidity risks Limited We want to meet our payment and collateral obligations, even when under severe liquidity stress, while also actively
pursuing illiquid assets to back illiquid liabilities on our balance sheet.
Sound business conduct Avoid We have no appetite for material breaches of business integrity-related policies or standards.
People conduct culture Limited We nurture a culture aligned with our purpose, values and ambitions, which supports continuous learning, collaboration
and diversity, and limit risks to the same.
Product suitability Avoid We only market products and services that add value to our customers over their expected lifetime in line with their
preferences, and can be explained in an understandable and transparent manner.
Operational risks Moderate We moderately accept human errors and as such failures in processes, and therefore manage these to agreed
tolerances.
Technology risks Limited We limit losses arising from technology risks, and therefore ensure our technology assets are sufficiently resilient and
responsibly used.
Reliable reporting Avoid We have no appetite for material errors in external financial and non-financial reporting or internal reports used for
managerial decision-making.
Business continuity Limited We avoid, to the extent possible and even under severe circumstances, sustained discontinuation of business (people,
offices, systems).
Risk appetite framework
We have the following four risk appetite levels:
Risk appetite Description
Avoid We apply considerable efforts to avoid
these risks happening, or even eliminate
them. If they materialise, we apply a
zero-tolerance attitude to address
incidents.
Limited We accept these risks, but we still try to
limit them with reasonable efforts to
manage potential impact.
Moderate We accept these risks, but neither avoid
nor seek them actively. We use a risk/
reward or risk/cost consideration to
manage these risks.
Actively pursue We are risk-seeking for this type of risk,
accepting uncertainty or volatility, as we
expect taking the risk will be ultimately
rewarded.
The risk appetite is evaluated at least annually, as
part of the Own Solvency and Risk Assessment
process, in sync with the Business Plan process.
The risk appetite is approved by the Management
Board. In 2024, the risk appetite statement for
Solvency Risks was updated to more clearly reflect
the preferences for different financial risks. The
statement was rephrased consistent with the
investment beliefs of our investment strategy. In
addition to this, we added explanations on how we
treat risk concentrations.
NN Group N.V. Annual Report 2024 | 55
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Risk metrics
Risk monitoring is a regular process to assess
and evaluate developments in the risk profile. It
determines whether risks are within the risk appetite
and in line with policies and standards. Monitoring
activities are performed following developments in
qualitative and quantitative boundaries (risk metrics)
around risk taking, such as:
• Risk limit – maximum exposure of a risk that
management is willing to accept and should not be
breached.
• Risk tolerance – level of exposure of a risk, where
management wants to be actively informed.
A tolerance is set to function as a trigger for
reviewing the exposure regularly and reflects an
ambition level within which management wants to
act in the medium term.
• Key Risk Indicator (KRI) – can assist management
in determining whether specific areas or business
objectives are at risk of moving beyond the risk
appetite. The KRIs indicate when specific actions
might be necessary to stop or reduce increasing
risk levels.
• Policies and standards – in addition to risk
metrics, requirements and/or guidance on how
to mitigate risks can be provided through policies
and standards.
Sustainability risks
Sustainability risks are the risks related to environmental, social and governance (ESG) factors that can
cause material negative impact to NN Group’s long-term performance, reputation, value, balance sheet or
operations. We consider sustainability risks to be transversal, meaning they manifest through various risk
types recognised in our Risk Taxonomy, such as strategic, financial and non-financial risks. ESG factors
are seen as risk drivers, potentially influencing the risk levels across these categories. By integrating
sustainability risks into our overall risk management framework, we are better equipped
to identify and manage the risks and opportunities associated with sustainability matters.
Below we show examples of how sustainable risks fit within our risk appetite:
Risk class Sustainability perspective
Strategic risks We aim to promote sustainable business practices that prevent or minimise adverse impacts on the environment, people and economy, while also
supporting long-term growth and profitability, and engage with our stakeholders (including customers, intermediaries, policymakers and invested
companies) to achieve that.
Financial risks – We seek to limit our exposure towards companies or industries that may have sustainability risks that can lead to significant financial impact on our
investments, or those of our customers, or that have material adverse impact on the environment or people.
– We prioritise investments and financial products that promote sustainable practices in general and decarbonisation of portfolios and climate change
resilient actions in particular.
– We use active engagement approaches and consider exclusion as a last resort.
Non-financial risks For business conduct:
– We do not want to do business with or invest in companies that violate NN’s corporate values or environmental or social standards.
For product suitability, we will:
– recommend financial products and services to customers that are in line with their sustainability preferences,
– where relevant, inform customers whether certain investment products may be sensitive to sustainability risks; and
– provide clear substantiation about how sustainable a financial product is (avoid greenwashing).
NN Group N.V. Annual Report 2024 | 56
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The NN Group Policy House consists of mandatory
NN Group-wide general principles, standards and
technical documents to help operationalise the
risk appetite into more detailed requirements
for execution. General principles describe the
key structure, organisation, decision authorities,
operating principles and limits that apply within
NN Group. Policies describe what needs to be
achieved by defining control objectives and high-level
principles, while standards describe how certain
requirements must be implemented and/or executed.
Minimum requirements related to sustainability
matters are an integral part of our Policy House, such
as within the Responsible Investment Framework,
the Responsible Insurance Underwriting Policy and
Our key risk metrics are:
Risk class Risk metrics
Strategic risks We manage and monitor strategic risks by, among other ways, regularly monitoring how we perform
relative to our strategic commitments:
– Customer engagement (Net Promoter Score): customers’ willingness to recommend our company
(i.e. products and services).
– Employee engagement: measuring employee satisfaction.
– Operating capital generation (OCG): the movement in the solvency surplus (Own Funds before
eligibility over Solvency Capital Requirement (SCR) at 100%) due to operating items. A more
detailed definition can be found in ‘Glossary’ on p. 406.
– Progress of main strategic initiatives.
Solvency risks – Solvency II ratio: the ratio of Eligible Own Funds to SCR. NN Group aims to capitalise the Group
and its business units adequately at all times. To ensure adequate capitalisation, business units
are managed to their commercial capital levels (based on the Solvency II ratio or local solvency
regime) in accordance with the risk associated with the business activities.
– Cash capital position: NN Group maintains sufficient cash available at the holding company to
cover stress events, and fund holding company expenses and interest expenses. The cash capital
position is defined as the net current assets available at the holding company. This is further
translated into internal metrics for more detailed monitoring.
– Solvency II ratio sensitivities: show how the NN Group Eligible Own Funds and SCR are impacted
under various scenarios as decided by NN Group Management Board (e.g. changes in interest
rates or other financial market factors).
– Own Funds at Risk (OFaR): NN Group has implemented limits to monitor the impact of moderate
stress events in business units, and monitors the level of capital and financial flexibility this
requires at the holding level.
– Market Risk and Counterparty Default Risk metrics: NN Group has several risk metrics to limit
concentration risks with respect to counterparties, countries, type of assets and industries.
– Bank capitalisation: the amount of capital NN Bank is required to hold as part of the Basel III
framework, expressed as a capital adequacy ratio of equity that must be held as a percentage of
risk-weighted assets.
– Interest rate risk limits and tolerances: NN Group has implemented limits and tolerances for
interest rate risk exposures at NN Group and business unit level.
– Product and underwriting limits: limits designed to manage deviations between expected and
realised claims and payments, longevity risks, etc.
– Policies and standards: on investment management, mandates and asset allocation, responsible
investments, products and underwriting.
– Restricted list and Exclusion list: the lists are designed to prevent investments in securities not
in line with NN Group’s values and/or applicable laws and regulations, as established in NN’s
Responsible Investment Framework.
Liquidity risks – Cash buffer: a minimum buffer of immediately available liquidity (cash and committed facilities) to
be able to meet collateral calls from derivative exposures.
– Required sales ratio: liquidity risks are monitored by assessing the required sales ratio between
liquid assets and liquidity requirements for severe stress scenarios and different time horizons.
Risk class Risk metrics
Non-financial risks – Control completeness: timely execution and complete registration of control monitoring by
management and control functions.
– Control effectiveness: controls are embedded and effectively executed to prevent or mitigate
risks within the risk appetite.
– Overdue issues: the number of issues that are (not) solved in a timely manner within agreed
remediation period.
– Incident cost (losses): the number of realised incidents that have a financial and/or reputational
impact.
– Legal claims: the number of realised legal claims that have a financial and/or reputational impact.
– Mandatory trainings: the percentage of completed mandatory trainings.
– Code of conduct/oath: acknowledgement by employees of adherence to the Code of Conduct.
– Number and nature of whistleblower cases: the number of (new) whistleblower cases and how
many are completed or under investigation.
– Availability IT systems: the time a system or service is accessible and operational for users.
– Reporting materiality: potential deficiencies in reporting processes are evaluated, individually and
on an aggregate level, against the applicable reporting materiality.
– Policies and standards that define objectives and requirements around compliance, IT,
operations, security and business continuity.
Product Policy. How sustainability is embedded in our
governance is further detailed under ‘Governance’
see p. 65.
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Step 2: Risk assessment
Risk assessments specifically seek to identify and
assess risks to the business of NN Group and its
business units. The quantitative risk profile for
financial risks is mostly measured using NN Group
models on predefined confidence levels (‘shocks’),
and reported against risk limits. Non-quantifiable
risks, and non-financial impact of quantifiable risks,
are assessed through control effectiveness in relation
to acceptable impact. Tail events (low probability,
high impact) are explored through scenario analysis
and addressed with (tested) Business Continuity
Plans or contingency plans.
Below we describe some of these risk assessments
in more detail.
Risk assessment
Risk class Risks assessed via
Strategic risks Business planning; Strategic Risk Assessment (SRA) and scenario analysis,
including Own Risk and Solvency Assessment (ORSA).
Market risks Asset Liability Management (ALM) studies, Strategic Asset Allocation (SAA) and
New Asset Class Assessment (NACA).
Counterparty default risks Assessment of maximum exposure on asset class, issuer and country basis.
Underwriting & pricing risks Product approval and review process (PARP).
Liquidity risks SAA, NACA.
Non-financial risks Risk assessments on processes and projects (including aspects of IT, financial
economic crime, fraud, etc.); Systematic Integrity Risk Assessment (SIRA), looking
at behavioural and integrity risks; ECF Maturity Reflection, looking at risk maturity
and culture.
Strategic Risk Assessment (SRA) and
Own Risk and Solvency Assessment (ORSA)
NN Group, and each of its regulated (re)insurance
subsidiaries, prepares an ORSA at least once a year.
This also covers our non-Solvency II entity Japan.
Similar to an ORSA, NN Bank performs an internal
Capital and liquidity adequacy assessment, in
accordance with Basel III requirements.
NN assesses the resilience of its strategy and capital
position through applying qualitative and quantitative
techniques to identify and assess both opportunities
and risks, including sustainability-related ones.
As part of the ORSA, a Strategic Risk Assessment
(SRA) is performed at least annually by the NN
from the Intergovernmental Panel on Climate Change
(IPCC) and the Network for Greening the Financial
System (NGFS), for both physical and transition-
related risks. See for the definition of physical and
transition risks p. 159. Outcomes of this inform the
DMA. See ‘Determining our material matters’, p. 20.
NN Group also assesses the appropriateness of
our Partial Internal Model (PIM), which is used to
calculate required capital for the Solvency II ratio.
Risk Management prepares annually a separate
report for the Management Board and the Risk
Committee of the Supervisory Board on the
performance and appropriateness of the Internal
Model.
Stress testing can also be initiated outside the ORSA,
either internally or if requested by external parties,
such as the Dutch Central Bank (DNB) or European
Insurance and Occupational Pensions Authority
(EIOPA).
Group Management Board and the management
of operating units. The outcomes of the SRA are
key risks, being risks that are potentially solvency-
threatening or could have a significant negative
impact on the achievement of one or more of the
business objectives in NN Group’s strategy or
business plan.
Key risks are assessed in the ORSA using a forward-
looking view, with scenario analysis and stress
testing, to assess capital strength of the entities
across its business planning period and ability
to withstand potential impact from these risks.
Impact is mainly assessed on the Solvency II capital
position, but also on liquidity or operating capital
generation where relevant. The outcome of the SRA
is used, among other things, in the Double Materiality
Assessment (DMA). See ‘Determining our material
matters’, p. 20.
Sustainability risks (mostly related to climate change)
have been included in the ORSA since 2017. We
conduct qualitative and quantitative analyses of the
potential impacts of physical and transitional climate
change risks to assess how these risks may impact
our Solvency II balance sheet in the longer term. We
use the insights gained to inform our investment
strategy and to integrate sustainability matters into
our insurance underwriting and risk management
practices. Where possible, the assessment considers
relevant short-, medium- and long-term scenarios
aligned with industry best practice, such as scenarios
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Strategic Asset Allocation (SAA)
Regulated (re)insurance entities of NN Group execute
an SAA study once every three years, in which the
target allocation and bandwidth are set for each
asset class. The SAA study is reviewed annually,
using updates for the assumptions on return, risk and
feasibility, and a review of constraints and objectives.
In 2024, as part of the SAA, we conducted a climate
economic impact sensitivity analysis for NN Life
Netherlands. This exercise used NGFS scenarios,
translating them into impacts on macro-economic
financial indicators over a forward-looking period of
15 years. We compared the results of the three NGFS
climate scenarios – current policy, early adaptation
policy and late adaptation policy – against our
baseline to assess their effects on asset allocation
composition, returns and costs.
Product approval and review process (PARP)
The PARP has been developed to enable effective
design, underwriting and pricing of all insurance
products, and safeguards these to manage them
throughout their lifetime. The PARP takes into
account customer benefits and product suitability,
expected sales volumes, value-oriented pricing
metrics, requirements from relevant policies and
regulations, as well as the administration and
accounting aspects of the product. Increasingly,
sustainability risks are assessed as part of the overall
pricing, as well as to what extent product information
properly reflects sustainability characteristics.
New Assets Class Assessment (NACA)
and investment mandate process
NN Group maintains a NACA for approving
investments in new asset classes, thereby
establishing a global list of asset classes in which
NN Group entities may invest.
Investments in these asset classes are governed
through investment mandates given by the insurance
entities to the asset manager(s).
Process risk assessments
Process risk assessments are performed periodically
on (sub-)processes by the relevant process owners,
paying particular attention to risks in process
handover points, where responsibility for activities
moves between departments and/or managers.
Owners annually assess what the most important
non-financial risks are within their process, looking
at, for example, aspects of IT, data quality, human
error, changes to systems and processes, etc.
Step 3: Risk control
Risk control refers to activities undertaken to
ensure proper mitigating measures are designed,
documented and executed such that risks are
managed within defined risk limits and tolerances,
and in line with policies and standards.
Through its Preparatory Crisis Plan, NN Group has
determined a set of measures for early detection of
and potential response to a crisis, should it occur.
The plan’s aim is to ensure tools, measures and
processes are in place to enable NN Group to:
• Avoid going into recovery;
• Anticipate in good time any approaching financial
distress and/or potential recovery situation;
• Quickly recover to an acceptable minimum
solvency (and liquidity) level when faced with
financial distress and/or recovery.
In the ‘Risk profile’ paragraph, we describe
mitigating activities per risk type in more detail.
Risk class Risks are mitigated/controlledthrough
Strategic risks – Scenario analysis
1
and contingency/recovery planning.
– Adjusting the strategic targets/business model to meet the changing environment,
implemented through strategic initiatives/programmes.
– Business planning, monitoring of strategic execution.
Market risks – Monitoring based on limits and tolerances, and adjusting asset positions if necessary.
– Hedging/use of derivatives.
– Monitoring investment mandates for external investment managers.
Counterparty default risks – Monitoring based on limits and tolerances, and adjusting asset positions if necessary.
Underwriting and pricing risks – Hedging with financial instruments (asset-liability management).
– Monitoring based on concentration and exposure limits and tolerances, and acting in case
of breaches.
– PARP.
– (External) (re)insurance
1
.
Liquidity risks – Monitoring based on limits and tolerances, and adjusting asset positions if necessary.
– Cash management/treasury techniques.
Non-financial risks – Controls and control testing.
– Incident management and external insurance.
– Risk culture, awareness and training
1
.
– Project risk logs and monitoring.
– Business continuity management.
1
Controls that are also applied to our identified sustainability risks.
Step 4: Risk monitoring and reporting
Risk monitoring helps us assess and evaluate
developments in the risk profile. It determines
whether risks are managed within the applicable
risk appetite, related limits and tolerances, and
in line with policies and standards. Results of
the risk monitoring are reported regularly to the
responsible managers of departments, as well as the
management and supervisory boards of both
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NN Group and its entities. This includes information
on, for example, strategic projects, financial risk
limits and developments, control effectiveness,
control deficiencies and incidents, as well as
second line opinions and advice. Action is taken by
management when monitoring indicates that risks
are being inadequately controlled.
The Management Board and Supervisory Board
of NN Group receive a quarterly Enterprise Risk
Management (ERM) Report and Own Funds/SCR
Report. The ERM Report is designed to provide a
single consistent, holistic overview of the risks for
NN Group. It compares current risk levels to our risk
appetite, and aims to encourage a forward-looking
risk view. In the report, the different NN Group
business units report back on their risk profile in
relation to their risk appetite, including a second line
opinion from Risk, Legal and Compliance.
The Own Funds/SCR Report aims to give an overview
of the quarterly Solvency II capital position, and
developments in Own Funds and SCR. It also includes
the Solvency II ratio sensitivities.
Risk profile
Annually, the Management Board of NN Group
performs a Strategic Risk Assessment to establish
the key risks that might impact achieving our
strategic and financial targets. The assessment uses
a variety of inputs, including:
• External trends and material topics, as identified
by our stakeholders;
• Macroeconomic reports and publications from
analysts, the CRO Forum and the World Economic
Forum;
• Scenario analyses and stress-testing by our
investment and risk teams;
• Risk self-assessments by the management of
NN Group and its businesses.
Risks are managed throughout NN Group at different
levels of the organisation. Out of all risks, key risks
are a prioritisation mechanism, where the MB/CEO
select the risks they deem most relevant to the
strategy execution. Key risks are regularly monitored
and discussed by the MB itself. As such, the selection
of key risks varies over time and risks can (re)occur
as a key risk, depending on how our operating
environment and the strategy change.
Compared to 2023, global debt crisis (recession)
(3), geopolitical instability (6), and being outrun by
competition (7) have increased. Climate change –
physical risk for liabilities, model risk, recession and
product suitability were on the 2023 list, but are
either no longer considered key risks or have been
redefined. Geopolitical instability (6) and climate
change (4) are considered emerging risks. Though
not necessarily new, and to some extent already
materialised, in terms of both their nature and risk
level they are still developing, as is our response to
mitigate their impact.
The 2024 Strategic Risk Assessment identified nine key risks (ranked by relative importance):
Rank Key risk Risk class Risk level (vs 2023)
1 Cyber (security) risk Business technology risks
2 Regulatory environment Strategic risks
3 Global debt crisis (recession)
1
Market risks
4 Climate change – transition risk for assets Strategic risks
Market risks
5 Sustainable cost levels Strategic risks
Underwriting & pricing risks
6 Geopolitical instability Strategic risks
7 Being outrun by competition
1
Strategic risks
8 Longevity risk
1
Underwriting & pricing risks
9 Inflation risk Market risks
Underwriting & pricing risks
1
Selected as a key risk in 2024, was not a key risk in 2023.
Emerging risks
Emerging risks are external strategic risks that cannot yet be fully assessed or quantified but that could in the
future affect the viability of NN Group’s strategy. They are relevant for NN Group because they can accumulate
over time and they can be difficult to link to a specific cause. In 2024, NN Group participated in the ‘Emerging
Risk Initiative’ working group of the CRO Forum. The CRO Forum consists of a group of European chief risk
officers (CROs) from insurance companies that share ideas and benchmark risk management practices. The
Emerging Risk Initiative identifies and communicates emerging risks that may have significant impacts on
the industry within the next ten years. The new risks added to the Radar in 2024 are Social Fragmentation
and Economic trade conflicts and sanctions due to widening societal divisions and disparities as well as more
polarisation. By monitoring emerging risks through the Risk Radar, we can develop products and services that
help our customers insure themselves against new risks. CRO Forum identifies new risks in the latest Risk
Radar, for more information see nn-group.com
NN Group N.V. Annual Report 2024 | 60
Managing our risks
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Cyber (security) risk
Risk of cyberattacks, leading to misuse or loss of
information or privacy breaches, discontinuity of
operations or financial or reputation loss.
Given their pivotal role in the financial infrastructure,
and their possession of large amounts of financial
data and/or personal information about their
customers, financial services companies may be
a target for hackers as well as state actors. Cyber
incidents may lead to, amongst other things, loss of
data, disruption and shutdown of business activities,
criminal theft or reputational damage.
NN is continuously monitoring its IT infrastructure
through the NN IT General Controls, as well as
improving its security governance, processes and
technology. At the same time, the threats and
their levels of sophistication are also increasing.
Continuous investments are therefore needed
to avoid, for example, our systems becoming
unavailable, which might affect our daily business
and potentially customer confidence. Group IT’s
Enterprise Security Services (ESS) function leads all
efforts to further enhance our information security
and provide 24/7 protection against cyberthreats.
In particular, education and awareness-raising are
part of our security strategy. In 2024, we have
worked on implementing DORA requirements as part
of our information security and business continuity
practices.
Regulatory environment
Risk of adverse regulatory change due to political
shifts or increased supervisory scrutiny and
ambitions, which may have a profound impact
on our business model, performance or ability
to deliver our innovation or strategic initiatives.
Examples of these changes are, among others,
more severe Solvency II regulation, scrutiny on
internal model and extensive sustainable finance
legislation.
Ongoing regulatory changes and topics subject
to additional supervisory scrutiny may affect our
business model, solvency position or business
operations. Such regulatory developments include
new pension regulations in the Netherlands, changes
to the Solvency II framework and new sustainability
regulations.
Our capital position may be impacted by further
changes to the Solvency II framework (e.g. the
Solvency II 2020 review) or supervisory scrutiny
in areas such as the internal capital model. The
Solvency II review could have a positive impact on
the Solvency II ratio in certain areas, such as the
design of the Volatility Adjustment and risk margin.
However, the legislative proposals also include
potentially negative areas for NN and the industry
(e.g. changes to the extrapolation of the risk-free
curve, changes to the risk correction, introduction
of the enhanced prudency principle and extended
powers for supervisors). The amended regulation
will be effective as of 30 January 2027, which
means that reporting after this date will reflect the
changes from the Solvency II 2020 review. Some key
aspects in the agreement are not detailed out in the
Solvency II directive, but will be clarified later in the
process (part of Level II and Level III). This relates,
for example, to the parameterisation of elements
that are relevant for the determination of the risk
margin and the Volatility Adjustment. The revised
Solvency II directive forms the basis for the revision
of the Level II and III regulation, which can lead to
further changes. In addition to these changes, the
Solvency II review also introduces more detailed
requirements for liquidity risk management, climate
risk management and new reporting requirements.
Recent material developments around sustainability
legislation include the Corporate Sustainability
Reporting Directive (CSRD), which significantly
expands the scope of sustainability reporting, and
the upcoming Corporate Sustainability Due Diligence
Directive (CSDDD), which requires companies, among
other things, to conduct due diligence on the human
rights and environmental impacts of their operations
and upstream supply chain activities.
We follow the development of (future) regulations
closely so we can take timely action. NN proactively
maintains relationships with regulators and
supervisors, and assesses, and regularly calculates
the potential impact of, regulatory changes to its
solvency position and risk profile.
Global debt crisis (recession)
Risk of governments, businesses and/or consumers
not being able to pay their debt or debt service
costs in a higher interest rate environment, or debt
levels further increasing (lack of fiscal discipline or
increased expenditures, for example for greening
the economy, military expenses or other electoral
promises), potentially leading to defaults or
downgrades, as well global recession (negative
GDP growth, high unemployment).
In the past, monetary policies and government
stimuli have led to various countries, businesses and
consumers accumulating high levels of debt. While
interest rate cuts were introduced by central banks
(including the ECB and the Fed) in 2024, interest
rate hikes from 2022 and 2023, as well as increasing
credit spreads, make that debt is being (re)financed
at higher interest rates, which could further increase
the risk of defaults. Several countries in the eurozone
structurally do not meet agreed debt- and deficit-
to-GDP targets, which may further increase given
expected expenditures on greening the economy,
military spending and financing electoral promises. In
the US, too, government debts may further rise.
Geopolitical tensions are increasing and can lead
to further tightening of financial conditions for
Western economies via sanctions and trade tariffs,
market uncertainty, higher energy and commodity
prices, economic slowdown and financial market
fragmentation. Households and companies struggling
to cope with higher prices and borrowing costs may
lead to a recession. The depth of a recession
ultimately depends on actual levels of interest rates,
debt levels of companies and individuals, and the
resilience of the wider economy.
In the event of a recession, insurance companies will
be affected by higher lapses and lower new business
volumes. Corporate and mortgage defaults and
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downgrades may increase, real estate and equity
valuations may decrease, and government and
corporate bond spreads widen due to uncertainty in
the eurozone.
NN manages market risks within risk limits and other
boundaries set within various policies and standards.
This ensures our investments are well diversified
and that exposure to risks for which NN Group has
no or a limited appetite (e.g. interest rate, inflation
and foreign exchange risks) remains low. We also
apply ongoing monitoring of investment risks and
opportunities in the financial markets. Additionally,
we reduce downside risk through hedging
programmes and our SAA is designed to optimise
capital generation within acceptable risk levels.
Climate change – transition risk for assets
Risk of financial losses to investments and/or lower
investment returns resulting from the transition to
a lower-carbon/green economy.
Transition risks arise from the shift towards a low-
carbon economy, and associated market and policy
developments. This may have a profound impact
on the financial performance of companies across
a range of industries. Some industries, such as
renewable energy and electric vehicles, will likely
benefit from the transition while others, such as fossil
fuel extraction and energy-intensive manufacturing,
may face significant challenges.
To manage transition risk for NN Group’s assets, we
regularly review and update the company’s climate
strategy, investment portfolio and risk management
processes. We also engage with stakeholders to
stay abreast of the latest developments transitioning
to a low-carbon economy. We regularly screen
our investment portfolio to proactively react to
regulatory, legal, technological, market sentiment
and reputational trends that may impact the
transition of countries or sectors we invest in.
Through our role as a large institutional investor,
NN aims to positively impact sustainability matters.
We have developed asset-class-specific strategies
for the corporate investment portfolio, including
(i) greenhouse gas emission (GHG) reduction for
the corporate investment portfolio (25% by 2025
and 45% 2030) and (ii) a target to increase climate
solutions investments by at least EUR 6 billion
by 2030. Additionally, NN actively contributes to
industry bodies to define standards on sustainable
and responsible investments and underwriting,
and has endorsed various initiatives. We are
deploying qualitative and quantitative scenarios to
further understand the impact of both physical and
transitional risks, both during the business plan
period as well as beyond.
Sustainable cost levels
Risk of expense levels remaining at a too high level
for both the closed book (not managing cost in line
with runoff of the books) and new products.
To remain competitive, NN Group needs to align
its revenues and cost base for all businesses. For
example, for Netherlands Life, improving IT systems
and efficiency is important both to keep cost levels in
line with the run-off pace of the closed books and to
further grow the profitably of the defined contribution
(DC) portfolio. Overall, NN Group’s business units
faced continued higher inflation for procured services
and higher salaries of our own staff due to inflation/
Collective Labour Agreement increases.
NN reduces future expenses through projects
related to digitalisation (IT simplification, deploying
artificial intelligence), product rationalisation,
simplifying/standardising business processes and
the organisational set-up. We leverage scale where
possible, combine data and digital capabilities, and
employ an Agile Way of Working where beneficial.
Geopolitical instability
Escalation of geopolitical tensions in the world,
which may lead to economic impacts (e.g.
disruption of supply chains, trade tariffs, availability
of resources) for Europe as well as diversion of
resources to military goals (e.g. increased NATO
spending).
Geopolitical risk is the risk associated with tensions
or actions between states and political actors that
affect the normal and peaceful course of international
relations. Geopolitically, more and more alliances
are forming or shifting worldwide, with less clear or
stable demarcations between countries and different
power blocks/international alliances.
Recent relevant events include:
• The outcome of the US presidential elections.
With the Republicans winning the US elections,
various US economic, social, foreign and military
policies are being altered, which (could) lead to, for
Sustainability risks
NN Group Risk began developing a structural Climate Risk Assessment (CRA) in 2022, which allows for a
more holistic, structured approach to identifying and assessing potential balance sheet vulnerabilities to
physical and transitional climate-related risks. In 2023, NN Group progressed in further completing the
mapping of its portfolio to climate-related risks, and in 2024 NN is able to produce its first Sustainability
Statement disclosure concerning impacts, risks, and opportunities (IROs) related to environmental, social,
and governance (ESG) matters that are material to the Group’s activities and operations for the financial
year 2024. See ‘Sustainability Statement’, p. 120.
Climate risks are inherently long-term, non-linear, non-stationary, and systemic, making them challenging
to identify and measure. Regular re-evaluations of our sustainability risks are paramount to ensuring that
our risk management practices remain robust and adaptive. By doing so, we aim to safeguard our long-
term objectives and uphold our commitment to sustainable and responsible business operations. See
‘Anticipated financial effects’ on p. 159 for more details on our climate risk posture.
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
example, trade barriers (tariffs), or impact military
conflicts (increasing uncertainty). The US seems
to take a more transactional view of partnerships
to maximise US interests, which may not be in
the best interest of, for example, Europe. The
continuing US-China tensions, both military and
economic, could have potential side effects for
their allies (for example, sanctions or other trade
barriers). Furthermore, the US withdrawal from
the Paris Agreement may create deviating policies
with respect to sustainability matters between
countries.
• Right-wing/populist parties have gained influence
in Europe, potentially affecting EU policies around,
among other things, immigration and green
energy, causing uncertainty on how government
policies in these areas will further develop.
• The Russia-Ukraine war continues, with the risk
of a wider conflict remaining. In the meanwhile,
there are increasing signals of Russian actions
impacting European infrastructure by means of
sabotage, cyberattacks and other criminal activity.
• The fragile military situation in the Middle East
adds to existing geopolitical tensions, and further
complicates international political relations and
increases economic uncertainty.
NN does not have direct business activities in
Ukraine, Russia, China or Israel, and has limited
direct financial exposure to these countries. However,
the impact on our operating environment and on NN
will depend on how geopolitical tensions progress
and/or escalate, which may coincide with other
inflationary, governmental debt or recessionary
developments.
So far, NN has experienced relatively modest impact
from these adverse developments. NN manages
its asset exposures via concentration limits on
sovereign and country exposures that are regularly
reviewed and monitored. We also monitor the credit
quality of portfolios and deploy scenario analysis to
better understand our sensitivity to financial market
volatility.
Being outrun by competition
Risk of NN not meeting changing customers’
expectations, or not being able to transform the
business with respect to market trends (including,
among other things, AI, customer expectations and
changing markets).
The world in which we operate is rapidly changing.
Technology, digitalisation, the shift to a platform
economy and the use of data are all having a growing
impact on our everyday lives. Customers expect a
fast, transparent, direct and personalised experience,
with tailored products and services offered by
companies that act responsibly. AI is affecting the
way we do business.
To maintain our strong position and remain relevant
to all our stakeholders, we need to be able to
outperform new and different kinds of competition
(including aggregators and big-tech companies
with a high investment potential), and enhance
customer experience and engagement. NN has
various programmes to strengthen the distribution
strategy and the position within the value chain
while mitigating potential risks at the same time,
cost-efficiency initiatives, strategic pricing and
data initiatives, and we are accelerating our digital
strategy through partnerships with start-ups
and Insurtech companies, as well as through our
innovation labs.
Longevity risk
Risk of assumptions about life expectancy and
mortality rates being inaccurate due to advances in
medical research or improving health conditions.
NN Group’s pension and guarantee product portfolios
are exposed to longevity risk. Longevity risk is a
relatively big consumer of capital besides market
risk (which is the biggest) and mainly resides in NN
Life & Pensions. In recent years, NN Group has taken
active steps to manage longevity risk efficiently
from a risk-return perspective and completed
several longevity reinsurance transactions. We have
moderate appetite for this risk, while we manage risk
concentration. We manage our exposure by, among
other things, using reinsurance where deemed
necessary, and monitoring mortality assumptions
in pricing, and using the most recent internal and
external information for the longevity best estimate
assumptions.
Inflation risk
Risk of persisting inflation levels, driven by a
combination of geopolitics, higher energy and
commodity prices, and scarcity in some production
factors, leading to higher costs for households and
businesses and anaemic economic growth.
Inflation rates decreased in 2024 compared to
2022-2023, due, among other things, to falling fuel
and food prices, as well as the monetary policies
of central banks. Price pressure is still present and
visible in the price of various products and services.
Uncertainties with regards to future inflation remain
around, among other things, fiscal policy by newly
elected governments, transitioning to a greener
economy and extra expenditures by the EU to
become strategically independent of US/China.
The impact of inflationary developments on our
balance sheet and solvency position depends on
the actual level of inflation itself, but also on how
other market factors move, driven by, among other
things, the response of central banks to inflation
and the market expectations of investors. The risk
of structural inflation can have a direct (through
operating expenses and claims) or indirect (the effect
on interest rates, equities, real estate and sales)
impact on NN Group’s business plans and financial
position.
NN Group manages this risk by having a small
exposure to inflation-linked liabilities, managing
our cost base and product premiums, hedging
benefit inflation risk and interest rate risk, adapting
allocation to equity and other risky asset classes, and
selectively de- or re-risking the balance sheet.
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AI – the opportunities
and risks
The reach of AI is expanding fast, affecting
all our lives and demanding from
companies that they manage its impact
effectively.
Impact story
114
data scientists employed
by NN
>85%
AI use cases are GenAI
solutions, or involve
GenAI tech
32
new production solutions
created using GenAI in
2024
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Finance is one of the world’s most data-driven industries. As a financial
services provider, NN Group not only generates huge amounts of data,
but is reliant on it too, which means that we will be significantly affected
by AI.
AI brings with it a raft of opportunities and risks and to help us keep
on top of both, NN is upskilling employees, see p.31. ‘That doesn’t just
help them as individuals,’ says Tjerrie Smit, Chief Analytics Officer, ‘but it
makes NN ‘future-ready’ too, while addressing the challenge that skilled
AI specialists are often difficult and expensive to hire.’
GenAI
While AI models are improving processes in every corner of the
organisation, often carrying out repetitive tasks that free up colleagues
for more complex challenges, it is Generative AI (GenAI) in particular
that is creating new opportunities for NN. ‘GenAI has the ability to
create full digital processes that are easy and fast for customers to use,
whenever and wherever they want.’ (Read how we are embedding GenAI
in our business in ‘Strategy’, p.25.)
‘GenAI has the ability to
create full digital processes
that are easy and fast for
customers to use, whenever
and wherever they want.’
Tjerrie Smit, Chief Analytics Officer
Scaling up fast
GenAI tools (Chat GPT is probably the most widely used), can boost
operational speed, reduce cost and help meet customers’ growing
demands for seamless digital services. ‘If we execute correctly, we can
boost market retention. As an early adopter of AI, NN understands how
and where we can effectively apply current GenAI solutions. And, since
everyone in our sector is racing to leverage this technology, we make
scaling our AI applications a top priority.’
Improving accuracy
GenAI can improve accuracy in underwriting and fraud analytics and
improve efficiency in claims processing, as well as simulate trends
and risks to help us prepare for future scenarios. With today’s ageing
population, and a higher percentage of people retiring within a short time
span, AI can fill some of the gaps in the workforce.
New markets and threats
‘AI will also enable us to personalise products and services and open up
new markets. And because of its potential to improve accuracy, many
of our processes will be improved, leading to lower costs and higher
profitability.’ NN also has its own ChatGPT environment, which is already
being used by over 7,000 colleagues to test use cases and take them
into production.
But the predominance of ‘corporate AI’ is increasing
the likelihood of threats from ‘bad actors’ who are using this technology
to commit fraud or execute cyberattacks. Additionally, the EU is subject
to extensive regulation around AI, which could hinder the pace of
innovation, and escalating geopolitical tension could restrict access to
the latest technologies.
NN AI Framework
It is for these reasons that we have established the NN AI Framework,
to help ensure that whatever we do with AI is safe and trustworthy.
The Framework makes sure our AI use cases comply not only with the
developing regulations around AI but also our own ethical standards.
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Governance
NN recognises the importance of good
governance. We provide an overview
of our governing bodies, namely our
Executive Board, Management Board and
Supervisory Board, and the other main
elements of our governance.
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Corporate Governance
Corporate governance
General
NN Group N.V. (NN Group) is a public limited company
(‘naamloze vennootschap’) incorporated under the
laws of the Netherlands and has a two-tier board
structure consisting of an executive board (Executive
Board) and a supervisory board (Supervisory Board).
The Executive Board also established a management
board (Management Board). NN Group mandatorily
applies the full large company regime.
Executive Board
Duties
The Executive Board is entrusted with the
management (including NN Group’s culture), the
strategy, operations and risk management of
NN Group under supervision of the Supervisory
Board.
In performing its duties, the Executive Board must
carefully consider and act in accordance with the
interests of NN Group and the business connected
with it, taking into consideration the interests of all
stakeholders of NN Group. When considering these
interests, the Executive Board shall also take into
account the continuity of NN Group, NN Group’s
view on sustainable long-term value creation, the
impact the actions of NN Group have on people and
the environment, as well as applicable legislation,
regulations and rules of conduct.
The organisation, duties and working methods of
the Executive Board are detailed in the charter of the
Executive Board. This charter is available on the NN
Group website.
The Executive Board is responsible for ensuring
that the company has adequate internal risk
management and control systems in place so that it
is aware, in good time, of any material risks run by
the company and that these risks can be managed
properly. As part of its overall responsibilities for risk
management, the Executive Board is responsible
for establishing and maintaining adequate internal
control over financial reporting to provide reasonable
assurance regarding the reliability of financial
reporting and the preparation of the annual accounts
in accordance with generally accepted accounting
principles. Internal control over financial reporting
includes those policies and procedures that:
• Pertain to the maintenance of records that, in
reasonable detail, accurately and fairly reflect the
transactions and dispositions of assets;
• Provide reasonable assurance that transactions
are recorded as necessary to permit preparation of
the annual accounts in accordance with generally
accepted accounting principles (International
Financial Reporting Standards as endorsed by the
European Union and Part 9 of Book 2 of the Dutch
Civil Code);
• Provide reasonable assurance regarding prevention
or timely detection of unauthorised acquisition, use
or disposition of assets that could have a material
effect on the annual accounts.
The Executive Board is also responsible for
establishing and maintaining adequate internal
controls for the reliability of the sustainability
reporting included in the Sustainability Statement.
Because of its inherent limitations, internal control
over financial reporting and sustainability reporting
may not prevent or detect all misstatements.
Also, projections of any evaluation of effectiveness
to future periods are subject to the risk that controls
may become inadequate because of changes in
conditions, or that the degree of compliance with the
policies or procedures may deteriorate.
In the performance of its duties, the Executive Board
may gather information or seek advice from the
Management Board, Supervisory Board, NN Group
staff departments and/or external advisors.
Certain resolutions of the Executive Board require
the approval of the Supervisory Board and/or general
meeting of shareholders of NN Group (General
Meeting). These resolutions are outlined in the
articles of association of NN Group (Articles of
Association), which are available on the NN Group
website and in the charter of the Executive Board.
Appointment, removal and suspension
Under the full large company regime, the members of
the Executive Board are appointed individually by the
Supervisory Board.
Prior to appointing a member of the Executive Board,
the Supervisory Board must notify the General
Meeting of such an intended appointment. An
Executive Board member is appointed for a maximum
of four years and may be reappointed for a term of not
more than four years at a time.
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Corporate Governance
Only the Supervisory Board may suspend or remove
a member of the Executive Board. However, the
Supervisory Board is only entitled to remove a
member of the Executive Board after the General
Meeting has been consulted on the intended removal.
Composition
The Executive Board must consist of two or more
members, with the total number of members of the
Executive Board determined by the Supervisory
Board after consultation with the Executive Board.
There is no representation of employees or other
workers present in the Executive Board. Guiding
principles for the appointment of members and the
composition of the Executive Board are provided in
the profile of the Executive Board and Management
Board, and in the the Diversity and Inclusion Policy
for the Executive Board, Management Board,
Supervisory Board and senior management of
NN Group (D&I Policy). The profile and the D&I Policy
are available on the NN Group website.
Information on the composition and the members of
the Executive Board can be found below and on p. 87.
Remuneration
Information on the remuneration policy for members
of the Executive Board and on their individual
remuneration can be found in the Remuneration
Report on p. 107-113.
Management Board
Role and duties
The Management Board is entrusted with the day-to-
day management (including NN Group’s culture) and
the overall strategic direction of NN Group.
In performing its duties, the Management Board must
carefully consider and act in accordance with the
interests of NN Group and the business connected
with it, taking into consideration the interests of all
stakeholders of NN Group. When considering these
interests, the Management Board shall also take
into account the continuity of NN Group, NN Group’s
view on sustainable long-term value creation, the
impact the actions of NN Group have on people and
the environment, as well as applicable legislation,
regulations and rules of conduct. Notwithstanding
the foregoing, the rights and obligations of the
Executive Board under Dutch law, the Articles of
Association and the Charter of the Executive Board
remain in full force and effect. Each of the members
of the Management Board is responsible and
accountable to the Executive Board and within the
Management Board for the specific tasks as assigned.
Being comprised of the Executive Board members
as well as key leaders with a divisional or functional
responsibility, the Management Board allows for
integral and holistic decision-making at the highest
level of NN Group with functions, the businesses
and Executive Board members represented. Besides
providing balanced, effective and timely decision-
making, NN Group having a Management Board
also provides for flexibility in terms of composition,
allocation of tasks and responsibilities, and required
knowledge. In supervising the functioning of NN
Group’s corporate governance structure, including
its checks and balances, the Supervisory Board pays
specific attention to the dynamics and relationship
between the Executive Board and the Management
Board, as well as the way the Management Board
operates.
As at 31 December 2024, the Executive Board consisted of the following persons:
Name Position Date of birth Gender Nationality Appointment
Termination/
reappointment Tenure
David Knibbe Chair, Chief Executive Officer (CEO) 15 March 1971 Male Dutch 1 October 2019,
reappointment 2 June 2023
2027
1
5 years
Annemiek van Melick Vice-chair, Chief FinancialOfficer (CFO) 31 March 1976 Female Dutch 1 July 2022
2
2026
3
2 years
1
David Knibbe’s term of appointment will end at the close of the annual general meeting in 2027.
2
Annemiek van Melick joined NN Group as of 1 June 2022 as member of the Management Board.
3
Annemiek van Melick’s term of appointment will end at the close of the annual general meeting in 2026.
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Corporate Governance
The members of the Management Board may be
suspended and removed by the Executive Board after
consultation with the Supervisory Board. There is no
representation of employees or other workers on the
Management Board.
Information on the composition and the members of
the Management Board can be found below and on
p. 87-88.
The Supervisory Board will be provided with all the
information necessary for the proper performance of
its duties. In principle, members of the Management
Board are present at meetings with the Supervisory
Board where topics are discussed that relate to their
area of responsibility. Next to that, the Supervisory
Board regularly meets with the full Management
Board.
In the performance of its duties, the Management
Board may gather information or seek advice from the
Executive Board, NN Group staff departments and/or
external advisors.
The organisation, role, duties and working methods
of the Management Board are detailed in the charter
of the Management Board, which is available on the
NN Group website.
Composition, appointment and removal
The Management Board consists of the members
of the Executive Board and other members as
appointed individually by the Executive Board after
consultation with the Supervisory Board. The number
of members of the Management Board is determined
by the Executive Board. Guiding principles for the
appointment of members and the composition of
the Management Board are provided in the profile
of the Executive Board and Management Board, and
in the D&I Policy. The profile and the D&I Policy are
available on the NN Group website.
Bernhard Kaufmann was appointed CRO
and member of the Management Board as of
1 June 2020 and stepped down as of
1 October 2024. Mr Kaufmann was responsible for
the overall risk framework with direct responsibility
for the risk management departments. He was
also responsible for the actuarial function, and
reinsurance. Mr Kaufmann’s previous positions
include Group CRO and CRO Reinsurance at
Munich Re Group.
Mr Kaufmann holds a PhD (Dr. rer. Nat.) in theoretical
physics from the Technical University of Munich
(Germany), an intermediate diploma in economics
from the University of Hagen (Germany), and a
diploma in theoretical physics from the
Technical University of Munich (Germany).
As at 31 December 2024, the Management Board consisted of the following persons
1
:
Name Position Date of birth Gender Nationality Appointment Tenure
David Knibbe Chair, Chief Executive Officer (CEO)
(as of 1 October 2019)
15 March 1971 Male Dutch 7 July 2014 10 years
Annemiek van Melick Vice-chair, Chief Financial Officer (CFO)
(asof1July2022)
31 March 1976 Female Dutch 1 June 2022 2 years
Tjeerd Bosklopper CEO Netherlands Non-life, Banking & Technology
(asof1June 2020)
3 March 1975 Male Dutch 1 September 2018 6 years
Frank Eijsink CEO International Insurance 17 March 1973 Male Dutch 1 September 2023 1 year
Dailah Nihot Chief People, Communications, and
Sustainability Officer (CPCSO)
12 June 1973 Female Dutch 1 September 2018 6 years
Wilbert Ouburg Chief Risk Officer (CRO) 1 October 1985 Male Dutch 1 October 2024 <1 year
Leon van Riet CEO Netherlands Life & Pensions 2 September 1964 Male Dutch 1 June 2020 4 years
Janet Stuijt General Counsel 26 September 1969 Female Dutch 1 September 2018 6 years
1
Bernhard Kaufmann stepped down as member of the Management Board and CRO as of 1 October 2024.
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Corporate Governance
The Diversity and Skills matrix below provides an overview of the range of knowledge, experience and
backgrounds of the individual Management Board members.
Diversity and Skills matrix David Knibbe
Annemiek
van Melick
Tjeerd
Bosklopper Frank Eijsink Dailah Nihot Wilbert Ouborg Leon van Riet Janet Stuijt
Year of birth 1971 1976 1975 1973 1973 1985 1964 1969
Gender:
Male (M) or Female (F) M F M M F M M F
Nationality Dutch Dutch Dutch Dutch Dutch Dutch Dutch Dutch
Management of complex multinational enterprises
International economic, regulatory and public policy issues
Labour relations, human resources and management development
Insurance
Asset management
Retail banking
Audit, finance and control
Risk management
Legal affairs and corporate governance
Corporate integrity
Information technology and transformation
Marketing, in particular in the area of financial products and services
Sustainability matters
Considered an expert given previous and/or current roles (other than non-executive roles)
Sufficient experience and knowledge to be able to take an informed decision
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Corporate Governance
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Committees of the Executive Board
The Executive Board may establish permanent
committees other than the Management Board from
among its members and senior management. The
Executive Board has established among others the
following committees: Crisis Committee, Disclosure
Committee, Compensation Committee, Asset &
Liability Committee (ALCO) and Model Committee.
The main responsibility of the Crisis Committee is
handling financial and non-financial crisis situations
as defined by the Management Board. The Crisis
Committee is chaired by the CEO of NN Group.
The Disclosure Committee decides on disclosures
related to material - corporate - events. The
Disclosure Committee is chaired by the CFO of
NN Group.
The Compensation Committee is responsible for
assisting the Executive Board with remuneration
topics as laid down in the NN Remuneration
Framework Standard. The Compensation Committee
is chaired by the CPCSO of NN Group.
The Asset & Liability Committee oversees the
activities and market risks related to investments and
the matching of assets and liabilities at NN Group
level. The Asset & Liability Committee is chaired by
the CRO of NN Group.
The Model Committee is responsible, among other
things, for (i) approving the use of any Solvency
Capital Requirement (SCR) model and any change
to a Corporate SCR model, (ii) approving updates of
pricing buckets, (iii) providing advice on any model
or assumption change to a SCR model that exceeds
certain thresholds, (iv) approving waiver requests
for delayed model reviews, (v) accepting model
validation reports and (vi) discussing the yearly plan
for review of the Internal Model and Model Validation
planning. The Model Committee is chaired by the
head of Group Risk Models & Analytics.
Supervisory Board
Duties
The Supervisory Board is responsible for supervising
the management (including NN Group’s culture) of
the Executive Board and the general course of affairs
of NN Group and its businesses. The Supervisory
Board may, on its own initiative, provide the
Executive Board with advice.
In performing its duties, the Supervisory Board must
carefully consider and act in accordance with the
interests of NN Group and the business connected
with it, taking into consideration the interests of all
stakeholders of NN Group. When considering these
interests, the Supervisory Board shall also take into
account the continuity of NN Group, NN Group’s
view on sustainable long-term value creation, the
impact the actions of NN Group have on people and
the environment, as well as applicable legislation,
regulations and rules of conduct.
In the performance of their duties, the Supervisory
Board and the Committees of the Supervisory Board
may gather information or seek advice from the
Executive Board, Management Board, NN Group staff
departments and/or external advisors.
The organisation, duties and working methods of the
Supervisory Board are detailed in the charter of the
Supervisory Board. The charter is available on the NN
Group website.
Appointment, removal and suspension
The members of the Supervisory Board are appointed
individually by the General Meeting upon nomination
of the Supervisory Board. The General Meeting
and the Central Works Council may recommend
candidates for nomination to the Supervisory Board.
The Supervisory Board must simultaneously inform
the General Meeting and the Central Works Council
of the nomination. The nomination must state the
reasons on which it is based. The Supervisory Board
is required to nominate one-third of the Supervisory
Board members on the enhanced recommendation
(versterkt aanbevelingsrecht) of the Central Works
Council, unless the Supervisory Board objects
to the recommendation on the grounds that the
recommended candidate is not suitable to fulfil the
duties of a member of the Supervisory Board or that
the Supervisory Board will not be properly composed
if the nominated candidate is appointed. There is
no representation of employees or other workers
present on the Supervisory Board.
The General Meeting may reject the nomination of a
Supervisory Board member by an absolute majority of
the votes cast by shareholders representing at least
one third of NN Group’s issued share capital. If the
General Meeting resolves to reject the nomination
by an absolute majority of the votes cast, but this
majority does not represent at least one-third of
NN Group’s issued share capital, a new meeting
can be convened in which the nomination can be
rejected by an absolute majority of the votes cast,
irrespective of the part of NN Group’s issued share
capital represented. If the General Meeting resolves
to reject the recommendation, the Supervisory Board
will then prepare a new nomination. If the General
Meeting does not appoint the person nominated by
the Supervisory Board and does not resolve to reject
the nomination, the Supervisory Board will appoint
the person nominated.
A member of the Supervisory Board is appointed
for a maximum period of four years. A Supervisory
Board member can be reappointed once for a term
of four years. A Supervisory Board member can
subsequently be reappointed again for another period
of two years, which appointment can be extended by
two additional years. In the event of a reappointment
after an eight-year period, such reappointment shall
be adequately motivated in the Supervisory Board
Report. The members of the Supervisory Board retire
periodically in accordance with a rotation schedule
drawn up by the Supervisory Board. The rotation
schedule is available on the NN Group website.
The Supervisory Board may suspend a member of the
Supervisory Board. The suspension will lapse by law
if NN Group has not submitted a petition to remove
the suspended member of the Supervisory Board to
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Corporate Governance
the Enterprise Chamber of the Amsterdam Court of
Appeal (Ondernemingskamer van het Gerechtshof te
Amsterdam) within one month of commencement of
the suspension.
The General Meeting can, by an absolute majority
of votes cast, representing at least one-third of the
issued share capital, resolve to abandon its trust
(‘het vertrouwen opzeggen’) in the entire Supervisory
Board.
A resolution to remove the Supervisory Board for lack
of confidence cannot be adopted until the Executive
Board has notified the Central Works Council of the
proposal for the resolution and the reasons therefore.
If the General Meeting removes the Supervisory
Board members for lack of confidence, the Executive
Board must request the Enterprise Chamber of the
Amsterdam Court of Appeal to temporarily appoint
one or more Supervisory Board members.
Composition
The Supervisory Board must consist of three or more
members, with the total number of members of the
Supervisory Board determined by the Supervisory
Board. As at 31 December 2024, the Supervisory
Board consisted of seven members, who are all
independent (within the meaning of best practice
provision 2.1.8 of the Dutch Corporate Governance
Code), and there were no vacancies.
The profile of the Supervisory Board is available on
the NN Group website.
Information on the composition and the members
of the Supervisory Board can be found below, on
p. 90-91 and in the Report of the Supervisory Board
on p. 95.
As at 31 December 2024, the Supervisory Board
consisted of the following persons
1
:
Name Position Date of birth Gender Nationality Appointment
Termination/
reappointment Tenure
3
David Cole Chair (as of the close of theAGM
on 29 May 2019)
2 October 1961 Male Dutch and
American
1 January 2019,
reappointment 19May 2022
2026 6 years
Pauline van der Meer
Mohr
Vice-chair (as of the close of the
AGM on 2 June 2023)
(recommended by Central Works
Council)
22 February 1960 Female Dutch 1 January 2023 2026 2 years
Inga Beale Member 15 May 1963 Female British 20 May 2021 2025
2
3 years
Robert Jenkins Member 17 January 1951 Male American 2 February 2016,
reappointment 28May 2020,
24 May 2024
2026 9 years
Rob Lelieveld Member (recommended
by Central Works Council)
29 September 1962 Male Dutch 1 September 2021 2025
2
3 years
Cecilia Reyes Member 3 February 1959 Female Filipino andSwiss 20 May 2021 2025
2
3 years
Koos Timmermans Member 12 March 1960 Male Dutch 24 May 2024 2028 <1 year
1
Hans Schoen’s term of appointment ended at the close of the annual general meeting on 24 May 2024.
2
The current term of appointment of Inga Beale, Rob Lelieveld and Cecilia Reyes will end at the close of the annual general meeting to be held on 15 May 2025 (‘2025 AGM’).
As announced on 20 February 2025, the Supervisory Board has decided to nominate each of them for reappointment for a term of four years. The respective proposals will be submitted for adoption at the 2025 AGM.
3
Tenure up to the date of publication of this Annual Report.
Hans Schoen was appointed to the Supervisory
Board as of 7 July 2014. Mr Schoen was reappointed
on 31 May 2018 and on 19 May 2022. His term of
appointment ended as of the close of the AGM on
24 May 2024. He was appointed pursuant to the
enhanced recommendation right of the Central Works
Council.
Mr Schoen’s previous positions include partner at
KPMG Accountants and chair of the EFRAG Insurance
Accounting Working Group. Mr Schoen holds a
degree in economics and a postdoctoral degree in
accountancy from the University of Amsterdam (the
Netherlands). In September 2015, he received a
PhD from the Vrije Universiteit (VU) Amsterdam (the
Netherlands).
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Remuneration
Information on the remuneration of the members
of the Supervisory Board can be found in the
Remuneration Report, on p. 113-114.
Committees of the Supervisory Board
The Supervisory Board has established three
committees: the Audit Committee, the Risk
Committee, and the Nomination, Remuneration and
Governance Committee.
The organisation, duties and working methods of
the Supervisory Board committees are detailed in a
separate charter for each committee. These charters
are available on the NN Group website.
Information on the duties and responsibilities of the
respective committees and their composition can
also be found in the Report of the Supervisory Board
on p. 97-102.
Conflicts of interest
In 2024, no transactions were entered into in
which the interest of Executive Board members
and/or Supervisory Board members conflicted with
the interests of NN Group which are of material
significance to NN Group and/or to the relevant board
members.
Self-assessment and education programme
The Executive Board, Management Board and
Supervisory Board conduct an annual self-
assessment, (periodically) facilitated by an external
party. A questionnaire filled out by the members
of the Boards and evaluation sessions between
the Boards form the bases for discussions on their
functioning. As additional input for their evaluation,
the Executive Board and Management Board
members also make use of a survey filled out by their
direct reports. During the year, the members of the
Boards engage in reflective sessions to reassess the
findings of their evaluation.
The Boards are committed to continuous education
and professional development, ensuring its
members possess and maintain the requisite
skills and expertise to fulfill their duties, including
sustainability related expertise. In accordance with
e.g. the outcome of the self-assessments, the yearly
reviewed diversity and skills matrix, the double
materiality assessment (DMA) and identified material
impacts, risks and opportunities (IROs), a permanent
education programme is set up for the Boards every
year. Furthermore, the Boards have access to inhouse
expertise and external advisors.
Diversity and inclusion
NN Group aims to have an adequate and balanced
composition of its boards. In order to ensure such
composition at all times, several relevant selection
criteria are balanced and (re)appointments to these
boards are made on the basis of harmonised policies,
including the D&I Policy, and in accordance with legal
and regulatory requirements.
The objective of the D&I Policy is to set forth our
approach to reaching a diverse and inclusive
composition of NN Group’s boards and senior
management. In order to get to a balanced
composition of our Boards (and senior management),
the appointment procedures for Executive Board
members, Management Board members and
Supervisory Board members, as well as the NN Group
Human Resources Framework Standard, applicable
to the Management Board members and (other)
members of our senior management (excluding
Executive Board members), include various
principles and targets regarding the recruitment and
appointment or nomination (where applicable) for
these positions. These principles and targets, and
the guiding principles included in the profile of the
Executive Board and Management Board, and the
profile of the Supervisory Board, as well as in the D&I
Policy, are taken into account when (re)appointing
board members.
This means that in board composition (and senior
management) we strive for a balanced representation
in nationality, nation of origin, race, ethnicity,
languages spoken, belief system, gender, age, sexual
orientation, neurodiversity and physical diversity.
In addition, there has to be a balance in the affinity
with the nature and culture of the business of the
company and its subsidiaries.
As of 1 January 2021, NN Group aims to have a
gender diversity of at least 40% women and 40%
men on its boards.
As of 2021, NN Group also has a target to have at
least 40% women in senior management positions.
Since 2022, these positions include the Management
Board, managerial positions reporting directly to a
Management Board member and senior managerial
positions reporting to a business unit CEO.
With the application of ambitious gender diversity
targets for its boards, and the target to have more
than 40% women in senior management positions
(by 2025), NN Group complies with the requirement
to set ambitious gender diversity targets as included
in the act on gender diversity in boards of Dutch
companies
(Wet tot wijziging van Boek 2 van het
Burgerlijk Wetboek in verband met het evenwichtiger
maken van de verhouding tussen het aantal
mannen en vrouwen in het bestuur en de raad van
commissarissen van grote naamloze en besloten
vennootschappen,
‘the Act on gender diversity’)
which entered into force on 1 January 2022.
In support of our ambitious gender diversity targets,
NN Group has set an action plan, that has also been
adopted by the (other) NN Group companies in
scope of the Act on gender diversity. This action plan
supports a healthy and diverse succession pool for
senior management throughout the organisation,
as part of our Diversity and Inclusion and Key Talent
Management policy and processes.
We have set out various actions on the different
drivers behind our Diversity and Inclusion roadmap
such as: enhanced processes, data & monitoring,
visibility & networks, and mindset & awareness.
Actions include the following:
• The 40% target must be taken into account in the
succession planning and process for appointments
of persons in board and senior management
positions;
• At least once a year Talent Review & Succession
Planning sessions for senior management
positions are organised;
• Strive for a minimum of 50% females on shortlists
for senior management positions;
• A list of female talent pool is kept and participation
in succession planning sessions and leadership
and development programmes is ensured;
• Engagement with female talent pool and increase
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Corporate Governance
visibility, such as networking events, mentoring
programme Women in Leadership Network, etc.
• Carrying out equal pay analysis.
Composition of NN Group’s Executive,
Management and Supervisory Boards and
senior management
NN Group’s aim to have a gender diversity of at least
40% women and 40% men for its boards, and the
fact that its Executive Board consists of only two
members, requires the Executive Board to consist of
one female and one male. In 2023, the composition
of the Executive Board was 50% female and 50%
male, meeting this target. Considering the limited
number of members in the Executive Board, achieving
a well-rounded representation of the diverse criteria
outlined in our D&I Policy is challenging.
As the Executive Board members are part of the
Management Board as well, we prioritise attaining
diversity balance in the Management Board. For
the Management Board, NN Group also aims to
have a gender diversity of at least 40% of both
women and men. In 2024, the gender diversity
of the Management Board was 37.5% female and
62.5% male. The succession of Bernhard Kaufmann,
former CRO of NN Group, by Wilbert Ouburg as per
1 October 2024 has not altered the gender diversity
of the Management Board. Mr Ouburg’s appointment
followed a thorough process, resulting in his
selection as the preferred candidate. Mr Ouburg,
the only Gen Y/Millennial in the Management Board
brings generational diversity. Throughout 2024, the
Management Board was diverse and inclusive, its
members representing a broad diversity of thought.
In addition, the affinity with the nature and culture of
the business of the company and its subsidiaries was
well balanced across the Management Board.
Although the act on gender diversity in boards of
Dutch companies includes a statutory diversity quota
of at least one-third for both women and men on
supervisory boards of listed companies, NN Group
aims to have a gender diversity of at least 40% of
both women and men for its Supervisory Board.
As from 1 January 2024, the composition of the
Supervisory Board is 43% female and 57% male.
As per the Supervisory Board’s rotation schedule,
the terms of appointment of Cecilia Reyes, Inga Beale
and Rob Lelieveld will end as per the close of the
AGM on 15 May 2025. As announced on 20 February
2025, the Supervisory Board has decided to
nominate Inga Beale, Rob Lelieveld and Cecilia Reyes
for reappointment as members of the Supervisory
Board for another term of four years. The proposal
will be submitted for adoption at the AGM to be held
on 15 May 2025. If the proposed reappointments are
adopted, the composition of the Supervisory Board
as per the close of the AGM on 15 May 2025 will
continue to be 43% female and 57% male.
In 2024, the composition of the Supervisory Board
was diverse and inclusive. Despite many members
belonging to the same age group, representation
among other things of nationality, nation of origin,
ethnicity, languages spoken, gender and sexual
orientation was diverse, resulting in a board that
is characterised by strong diversity of thought. In
addition, the affinity with the nature and culture of
the business of the company and its subsidiaries was
well balanced across the Supervisory Board.
In future appointments of Executive, Management
and Supervisory Board members, NN Group will
continue to consider applicable laws and regulations,
our D&I Policy and relevant selection criteria
including but not limited to executive experience,
experience in corporate governance of large stock-
listed companies, and experience in the political and
social environment in which NN Group operates.
As at 31 December 2024, 41% of senior
management positions were held by women. More
information on senior management positions and
on inflow of employees can be found under ‘Own
workforce’, p. 183-194 of this Annual Report, and is
deemed to be incorporated by reference herein.
General meetings
Frequency, notice and agenda
Each year, no later than the month of June, NN Group
holds its annual general meeting (AGM). Its general
purpose is to discuss the Report of the Management
Board, advise on the Remuneration Report, adopt
the annual accounts, release the members of the
Executive Board and the members of the Supervisory
Board from liability for their respective duties,
appoint and reappoint members of the Supervisory
Board, decide on the dividend to be declared, if
applicable, and decide on other items that require
shareholder approval under Dutch law. Extraordinary
general meetings are held whenever the Supervisory
Board or the Executive Board deems such to be
necessary. In addition, one or more shareholders
who jointly represent at least 10% of the issued
share capital of NN Group may, on application, be
authorised by the court in interlocutory proceedings
of the district court to convene a general meeting.
General meetings are convened by a public notice
via the NN Group website no later than on the 42nd
day before the day of the general meeting. The notice
includes the place and time of the meeting and the
agenda items. Shareholders who, alone or jointly,
represent at least 3% of the issued share capital of
NN Group may request to place items on the agenda,
provided that the reasons for the request are stated
therein and the request is received by the chair of the
Executive Board or the chair of the Supervisory Board
in writing at least 60 days before the date of the
general meeting.
Admission to general meetings
Each holder of shares in the share capital of NN
Group entitled to vote, and each other person entitled
to attend and address the general meeting, is
authorised to attend the general meeting, to address
the general meeting and to exercise voting rights.
For each general meeting, a statutory record date
will, in accordance with Dutch law, be set on the
28th day prior to the date of the general meeting, to
determine whose voting rights and rights to attend
and address the general meeting are vested. Those
entitled to attend and address a general meeting
may be represented at a general meeting by a proxy
holder authorised in writing.
The 2024 AGM of NN Group was held in hybrid
form. Shareholders were able to attend in person or
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Corporate Governance
virtually, or follow the meeting via a live webcast.
Questions could be submitted in advance, as well
as during the meeting in person or virtually. Voting
rights could be exercised during the meeting in
person or by electronic means. Shareholders could
also exercise their voting rights by providing an
electronic proxy with voting instructions in advance.
Voting and resolutions
Each share in the share capital of NN Group confers
the right on the holder to cast one vote. At a general
meeting all resolutions must be adopted by an
absolute majority of the votes cast, except in those
cases in which the law or the Articles of Association
require a greater majority. If there is a tie in voting,
the proposal concerned will be rejected.
Powers of the General Meeting
The most important powers of the General Meeting
are to:
• Appoint members of the Supervisory Board upon
nomination of the Supervisory Board;
• Recommend persons to the Supervisory Board for
nomination as a member of that board;
• Abandon its trust in the Supervisory Board;
• Release the members of the Executive Board
and the members of the Supervisory Board from
liability for their respective duties;
• Advise on the Remuneration Report;
• Adopt the remuneration policy for the members
of the Executive Board and the remuneration
policy for the members of the Supervisory Board,
including the remuneration for the Supervisory
Board members, upon a proposal of the
Supervisory Board;
• Adopt the annual accounts;
• Appoint the external auditor;
• Approve resolutions of the Executive Board
regarding important changes in the identity or
character of NN Group or its business;
• Issue shares, restrict or exclude pre-emptive
rights of shareholders and delegate these powers
to the Executive Board, upon a proposal of the
Executive Board which has been approved by the
Supervisory Board;
• Authorise the Executive Board to repurchase
shares;
• Reduce the issued share capital, upon a proposal
of the Executive Board which has been approved
by the Supervisory Board;
• Dispose the profit remaining after the payment of
dividend on any outstanding preference shares
and after a decision has been taken on the
addition of all or part of the profits to the reserves,
upon a proposal of the Executive Board which has
been approved by the Supervisory Board;
• Amend the Articles of Association, upon a
proposal of the Executive Board which has been
approved by the Supervisory Board.
Shares and share capital
Classes of shares and NN Group Continuity
Foundation
The authorised share capital of NN Group consists of
ordinary shares and preference shares. Depositary
receipts for shares are not issued with the
cooperation of NN Group.
Currently, only ordinary shares are issued, while a
call option to acquire preference shares is granted
to the foundation Stichting Continuïteit NN Group
(NN Group Continuity Foundation). The objectives of
the NN Group Continuity Foundation are to protect
the interests of NN Group, the business maintained
by NN Group and the entities with which NN Group
forms a group and all persons involved therein,
in such a way that the interests of NN Group and
those businesses and all persons involved therein
are protected to the best of its abilities, and by
making every effort to prevent anything which may
affect the independence and/or the continuity and/
or the identity of NN Group and of those businesses
in violation of the interests referred to above. The
NN Group Continuity Foundation shall pursue its
objectives, inter alia, by acquiring and holding
preference shares in the share capital of NN Group
and by enforcing the rights, in particular the voting
rights, attached to those preference shares. To this
end, NN Group Continuity Foundation has been
granted a call option by NN Group.
According to the call option agreement concluded
between NN Group and NN Group Continuity
Foundation, NN Group Continuity Foundation has
the right to subscribe for preference shares in the
share capital of NN Group, consisting of the right to
subscribe for such preference shares repeatedly.
This may happen each time up to a maximum
corresponding with 100% of the issued share capital
of NN Group in the form of ordinary shares, as
outstanding immediately prior to the exercise of the
subscribed rights, less one share (which equals a
maximum of 50% less one share after dilution), from
which maximum shall be deducted any preference
shares already placed with NN Group Continuity
Foundation at the time of the exercise of the
subscribed rights. NN Group Continuity Foundation
qualifies as a legal entity independent from
NN Group, within the meaning of section 5:71,
paragraph 1, subparagraph c of the Dutch Financial
Supervision Act.
As at 31 December 2024, the board of NN Continuity
Foundation consisted of three members who are
independent from NN Group: Marc van Gelder (chair),
Karin Bergstein (treasurer) and Steven Perrick
(secretary).
Issuance of shares and pre-emptive rights
The General Meeting may resolve to issue shares
in the share capital of NN Group, or grant rights to
subscribe for such shares, upon a proposal of the
Executive Board which has been approved by the
Supervisory Board.
The Articles of Association provide that the General
Meeting may delegate the authority to issue shares,
or grant rights to subscribe for shares, to the
Executive Board, upon a proposal of the Executive
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Corporate Governance
has been approved by the Supervisory Board. Both
resolutions require a majority of at least two-thirds
of the votes cast, if less than one-half of the issued
share capital is represented at the general meeting.
The designation to the Executive Board to resolve
to limit or exclude the pre-emptive rights may be
granted for a specified period of time of not more
than five years, and only if the Executive Board
has also been designated or is simultaneously
designated the authority to resolve to issue shares.
A resolution of the Executive Board to limit or exclude
the pre-emptive rights requires the approval of the
Supervisory Board.
Designation of the Executive Board at the
2024 annual general meeting
Share issuance in the context of issuing
Contingent Convertible Securities
On 24 May 2024, the General Meeting designated
the Executive Board for a term of five years, from
24 May 2024 up to and including 23 May 2029,
as the competent body to resolve, subject to the
approval of the Supervisory Board, on the issuance
of ordinary shares in the share capital of NN Group
(including the granting of rights to subscribe for
ordinary shares) upon conversion of any Contingent
Convertible Securities (CCS) instruments in
accordance with its terms and conditions during the
term of the CCS instruments.
This authority of the Executive Board is limited to a
maximum of 30% of the issued share capital of NN
Group as at 24 May 2024. This designation enables
the Executive Board to issue CCS instruments and to
set the terms and conditions for any CCS instrument,
including the limitation or exclusion of pre-emptive
rights, the mechanism for the conversion and the
conversion price.
Share issuance and limitation of pre-emptive
rights
On 24 May 2024, the General Meeting designated
the Executive Board for a term of 18 months, from
24 May 2024 up to and including 23 November
2025, as the competent body to resolve, subject
to the approval of the Supervisory Board, to issue
ordinary shares in the share capital of NN Group and
to grant rights to subscribe for such shares, and to
limit or exclude the pre-emptive rights of existing
shareholders with respect to such issue of ordinary
shares in the share capital of NN Group and such
granting of rights to subscribe for ordinary shares.
The authority of the Executive Board is limited to a
maximum of 10% of the issued share capital of NN
Group as at 24 May 2024.
Rights issue
On 24 May 2024, the General Meeting designated
the Executive Board for a term of 18 months, from
24 May 2024 up to and including 23 November 2025,
as the competent body to resolve, subject to the
approval of the Supervisory Board, to issue ordinary
shares in the share capital of NN Group and to grant
rights to subscribe for ordinary shares by way of a
rights issue. This authority of the Executive Board
is limited to a maximum of 20% of the issued share
capital of NN Group as at 24 May 2024.
This authority to issue shares may be used for any
purpose, including but not limited to safeguarding
or conserving the capital position of NN Group and
mergers or acquisitions.
Acquisition of own shares
NN Group may acquire fully paid-up shares in its own
share capital for no consideration (‘om niet’) or if: (a)
NN Group’s shareholder’s equity less the payment
required to make the acquisition does not fall below
the sum of called-up and paid-in share capital and
any statutory reserves, and (b) the nominal value
of the shares which NN Group acquires, holds or
holds as pledge, or which are held by a subsidiary,
does not exceed half of the issued share capital.
The acquisition of its own shares by NN Group for
consideration requires authorisation by the General
Meeting. The authorisation is not required for the
acquisition of shares for employees of NN Group or
of a group company under a scheme applicable to
such employees. The Executive Board may resolve,
subject to the approval of the Supervisory Board,
to alienate the shares acquired by NN Group in its
own share capital. The resolution of the Executive
Board to acquire shares in its own share capital
for consideration requires the prior approval of the
Supervisory Board. No voting rights may be exercised
in the general meeting with respect to any share or
depositary receipt for such share held by NN Group
or by a subsidiary, and no payments will be made on
shares which NN Group holds in its own share capital.
On 24 May 2024, the General Meeting authorised
the Executive Board for a term of 18 months, from
24 May 2024 up to and including 23 November
2025, to acquire in the name of NN Group, subject to
the approval of the Supervisory Board, fully paid-up
ordinary shares in the share capital of NN Group.
This authorisation is subject to the condition that,
following such acquisition, the par value of the
Board which has been approved by the Supervisory
Board.
If the Executive Board has been designated as the
body authorised to resolve upon an issue of shares in
the share capital of NN Group, the number of shares
of each class concerned must be specified in such
designation. Upon such designation, the duration of
the designation shall be set, which shall not exceed
five years. A resolution of the Executive Board to
issue shares requires the approval of the Supervisory
Board.
Upon the issue of new ordinary shares (or the
granting of rights to subscribe for ordinary shares),
each holder of ordinary shares in the share capital of
NN Group has a pre-emptive right in proportion to the
aggregate nominal value of his or her shareholding of
ordinary shares.
Holders of ordinary shares have no pre-emptive right
upon (a) the issue of new ordinary shares (or the
granting of rights to subscribe for ordinary shares):
(i) against a payment in kind, (ii) to employees of
NN Group or of a group company or (iii) to persons
exercising a previously granted right to subscribe
for ordinary shares, and (b) the issue of preference
shares.
Upon a proposal of the Executive Board which
has been approved by the Supervisory Board, the
General Meeting may resolve to limit or exclude
the pre-emptive rights. According to the Articles of
Association, the General Meeting may designate
the Executive Board as the competent body to do
so upon a proposal of the Executive Board which
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The transfer of shares in the share capital of NN
Group not included in the Statutory Giro System
requires an instrument intended for that purpose.
To become effective, NN Group has to acknowledge
the transfer, unless NN Group itself is a party to the
transfer. The Articles of Association do not restrict
the transfer of ordinary shares in the share capital
of NN Group, while the transfer of preference shares
in the share capital of NN Group requires the prior
approval of the Executive Board. NN Group is not
aware of the existence of any agreement pursuant
to which the transfer of ordinary shares in the share
capital of NN Group is restricted.
Significant shareholdings
Substantial shareholdings, gross and net
short positions
Under the Dutch Financial Supervision Act, each legal
and natural person having a substantial holding or
gross short position in relation to the issued share
capital and/or voting rights of NN Group that reaches,
exceeds or falls below any one of the following
thresholds: 3%, 5%, 10%, 15%, 20%, 25%, 30%,
40%, 50%, 60%, 75% and 95%, must immediately
give written notice to the Dutch Authority for
Financial Markets.
These notifications will be made public via the
Register substantial holdings and gross short
positions (‘Register substantiële deelnemingen
en bruto short posities’) of the Dutch Authority for
Financial Markets.
Pursuant to EU regulation No. 236/2012, each legal
and natural person holding a net short position
representing 0.1% of the issued share capital of NN
Group must report this position and any subsequent
increase by 0.1% to the Dutch Authority for Financial
Markets. Each net short position equal to 0.5% of the
issued share capital of NN Group and any subsequent
increase of that position by 0.1% will be made public
via the short selling register of the Dutch Authority
for Financial Markets.
In 2024, no legal or natural person held at least 10%
of the shares in NN Group, therefore NN Group did
not enter into any transaction with any such person.
Information on shareholders with an (indirect)
holding and/or gross short position of 3% or more can
be found on p. 48 and is deemed to be incorporated
by reference herein.
Dutch Corporate Governance Code
NN Group is subject to the Dutch Corporate
Governance Code (Code). The application of the
Code by NN Group during the financial year 2024 is
described in the publication Application of the Dutch
Corporate Governance Code by NN Group, dated
12 March 2025, which is available on the website of
NN Group.
This publication is to be read in conjunction with
this chapter and is deemed to be incorporated by
reference herein. The Code is available on the website
of the Dutch Corporate Governance Code Monitoring
Committee (www.mccg.nl).
VNO-NCW Tax Governance Code
NN Group endorsed the VNO-NCW Tax Governance
Code and reports on the application of its principles
in the 2024 TTC Report, available on the NN Group
website.
Articles of Association
The General Meeting may pass a resolution to amend
the Articles of Association with an absolute majority
of the votes cast, but only on a proposal of the
Executive Board, which has been approved by the
Supervisory Board.
NN Group’s Articles of Association were last
amended on 28 May 2020.
Change of control
NN Group is not party to any material agreement
that takes effect, alters or terminates upon a change
of control of NN Group following a takeover bid as
referred to in article 5:70 of the Dutch Financial
Supervision Act, other than a revolving credit facility
agreement entered into with a syndicate of lenders.
The revolving credit facility agreement includes a
change of control provision which entitles the lenders
to cancel the commitment under the facility and
declare any outstanding amounts under the facility
immediately due and payable.
The assignment contracts with the members of the
Executive Board stipulate that in the event of an
involuntary termination of the contract, including
involuntary termination in connection with a public
bid as defined in article 5:70 of the Dutch Financial
ordinary shares in the share capital of NN Group
which are held by NN Group or for which NN Group
holds a right of pledge, or which are held by its
subsidiaries for their own account, shall not exceed
10% of the issued share capital of NN Group as at
24 May 2024. Shares may be acquired, on the stock
exchange or otherwise, at a price not less than the
par value of the ordinary shares in the share capital
of NN Group and not higher than 110% of the highest
market price of the shares on Euronext Amsterdam
on the date of the acquisition or on the preceding day
of stock market trading.
Cancellation of own shares
On 24 May 2024, the General Meeting adopted the
proposal to reduce the issued share capital of NN
Group by cancellation of ordinary shares held by NN
Group in its own share capital up to a maximum of
20% of the issued share capital of NN Group as at
24 May 2024.
The cancellation may be executed in one or more
tranches. The number of ordinary shares to be
cancelled shall be determined by the Executive
Board. Capital reduction shall take place with due
observance of the applicable statutory provisions and
the articles of association of NN Group.
Transfer of shares and transfer restrictions
The transfer of ordinary shares in the share capital
of NN Group included in the Statutory Giro System
must take place in accordance with the provisions
of the Dutch Securities Giro Act (‘Wet giraal
effectenverkeer’).
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Ernst & Young Accountants LLP as its new external
auditor for the financial years 2026 through 2029 at
the AGM on 15 May 2025. More information on NN
Group’s policy on external auditor independence is
available on the NN Group website.
Sustainability governance
Strategy setting
The Executive Board is responsible for the
formulation and execution of the company’s strategy,
consistent with its position on sustainable long-
term value creation. As redefined in 2023, our
five strategic commitments reflect our focus on
transforming our business (read more on p. 25-34).
Our strategy remains aligned with long-term trends
including sustainability matters.
The strategy pursued by the Executive Board
is supervised by the Supervisory Board. Each
Supervisory Board Committee covers sustainability
matters that fall within its responsibilities and area of
expertise.
Reporting the main points of discussion and
recommendations to the Supervisory Board
safeguards an integrated approach with regard to
sustainability matters at Supervisory Board level.
The Management Board is entrusted with the day-to-
day management and overall strategic direction of
NN Group. This includes the setting and achievement
of the company’s objectives, and any sustainability
matters it deems relevant.
The responsibility for sustainability matters of the
Executive Board, the Management Board and the
Supervisory Board and its Committees is laid down
in each of these bodies’ charters. To ensure the
material IROs are considered in decisions made by
either the Executive Board, Management Board or the
Supervisory Board, the material IROs are integrated
into the respective decision sheet templates.
As the Management Board comprises the members of
the Executive Board, resolutions of the Management
Board include the votes in favour by the members
of the Executive Board, unless explicitly stated
otherwise in the minutes of the meeting in which the
decision was taken.
The responsibility of the Executive Board’s
Committees as mentioned below is laid down in
the charters of these committees and reflected in
NN Group’s Governance Manual. The charters of NN
Group’s dedicated committees around sustainability
to support the strategy execution and monitoring of
progress include their respective responsibilities.
Reference is also made below to various
sustainability-related policy frameworks.
For the roles and responsibilities of the Executive
Board, the Management Board and the Supervisory
Board in the DMA process, reference is made to p.
131 of the Sustainability Statement.
Within the Management Board, the CPCSO, who
reports to the CEO, has Sustainability and Social
Impact, previously Corporate Citizenship
1
, in her
1
The Corporate Citizenship department included Sustainability, Community Investment and Art, Culture and History.
portfolio and is the sponsor of topics related to
sustainability, climate, responsible investment and
responsible insurance underwriting discussed in
the Management Board. The CRO, also a member of
the Management Board, and reporting to the CEO,
has day-to-day responsibility for NN Group’s Risk
Management function.
The CRO is tasked with ensuring both the
Management Board and Supervisory Board are
informed of and understand at all times the material
risks NN Group is exposed to, which also includes
sustainability risks.
The General Counsel, also a member of the
Management Board, ensures that both the
Management Board and Supervisory Board are
informed and understand the legal and compliance
risks related to sustainability matters.
The CRO is also the sponsor of the NN Group ORSA,
in which outcomes of scenario analyses, including
climate change, are evaluated on an annual basis.
To assess NN Group adheres to regulations related
to sustainability matters, the NN Group Control
Functions, including Risk and Compliance, are
tasked with overseeing proper implementation and
monitoring compliance. In addition, each of our
Management Board members is responsible for
promoting and integrating sustainability into their
respective businesses or functions as relevant.
Sustainability matters are regularly on the agenda
of the Management Board, covering items such as
Supervision Act, members of the Executive Board
are eligible to a termination arrangement. Such
termination arrangement is limited to a maximum of
one year base salary, in line with the Code and the
Dutch Financial Supervision Act.
External auditor
The external auditor is appointed by the General
Meeting upon nomination of the Supervisory Board,
after recommendation by the Audit Committee. On
28 May 2015, the General Meeting appointed KPMG
Accountants N.V. (KPMG) as the external auditor of
NN Group for the financial years 2016 through 2019.
On 29 May 2019, KPMG was reappointed as the
external auditor of NN Group for the financial years
2020 through 2022. On 19 May 2022, KPMG was
further reappointed as external auditor of NN Group
for the financial years 2023 through 2025.
The external auditor may be questioned at the
AGM in relation to its audit opinion on the annual
accounts. The external auditor will therefore
attend and be entitled to address this meeting. In
2024, the external auditor attended the AGM. The
external auditor also attended the meetings of the
Audit Committee and the Risk Committee of the
Supervisory Board in 2024, as well as part of the
meetings of the Supervisory Board where relevant,
such as the meeting in which the 2023 Annual
Accounts were approved.
In 2023, NN Group initiated the process to select a
new external auditor as of the financial year 2026. It
will be proposed to the General Meeting to appoint
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(material) policy changes and updates, assessments
of external benchmarks and ratings, and
sustainability risks and opportunities.
Providing information on IROs, the implementation
of due diligence, and the results and effectiveness
of policies, actions, metrics and targets adopted
to address them, is embedded in our regular
governance. This includes a structured approach
to informing and educating the Management and
Executive Boards and relevant committees. There is
an integrated process for reporting on, for example,
the results of the DMA, the quarterly risk report,
the annual ORSA report, the annual strategic target
setting and quarterly strategy updates.
During their formal meetings, the Executive,
Management and Supervisory Boards also receive
regular comprehensive updates on sustainability
matters that fall outside the scope of the examples
outlined above. These can be presented by experts
from NN Group’s Sustainability and Social Impact
department and help ensure board members are
well-informed on current sustainability issues.
As sustainability is an integral part of NN Group’s
strategy and business model, the topic often forms
part of the Boards’ offsite agendas.
Furthermore, sustainability matters are integrated
into the permanent education programme for
the Supervisory Board, in which Executive and
Management Board members also participate.
Sustainability is also one of the topics in the
induction programmes for new board members.
This structure is in place to support the Management
Board as the decision-making authority over the
outcomes of the DMA, sustainability related policies
and standards, and other significant matters in this
domain. The Board can then in turn discuss with
the Supervisory Board to take steps under their
supervision on how to further translate sustainability
matters into NN Group’s targets and strategy.
NN Group has the following dedicated committees
around sustainability to support the strategy
execution and monitoring of progress. See also the
visual on p. 80.
Group Sustainability Council
NN Group has installed a Group Sustainability
Council per 1 October 2024, to emphasize our focus
on sustainability matters. The Group Sustainability
Council is chaired by the Head of Sustainability and
Social Impact and includes the heads of the relevant
staff departments (including the second line of
defense functions) and business unit managers. The
CPCSO has a standing invitation to this Council and
is closely aligned with the Head of Sustainability and
Social Impact.
The Group Sustainability Council is set up to assist
the Management Board in relation to sustainability
matters by:
• Facilitating strategy implementation and
monitoring execution and performance, including
steering regulatory implementation;
• Discussing and consulting on material changes
and developments.
The Group Sustainability Council is a consultative
body, covering overarching sustainability strategy
implementation, plans and targets of NN Group as
a whole. Decision-making on sustainability strategy
and target setting remains the responsibility of the
Management Board.
The Group Sustainability Council incorporates the
sustainability and social impact responsibilities of
the former Purpose Council
1
and the responsibilities
of the Taskforce Sustainability in Business Steering
Committee. Both have ceased to exist as of the
effective date of the Group Sustainability Council.
Performance on strategic targets is reported via
a Strategy Dashboard, which is evaluated in the
Group Sustainability Council and subsequently in
the Management Board on a quarterly basis (see
p. 79-80 for an explanation on target setting and
monitoring).
Responsible Investment Committee
NN’s Responsible Investment (RI) Framework policy
describes our approach to integrating sustainability
factors, including climate change, in our investment
process. NN Group has an RI governance structure
to facilitate multidisciplinary discussions and
exchange of information between the right people
at the right time. The RI Committee is chaired by
the Group Chief Investment Officer, who reports to
the CEO. Other members include the CPCSO, the
CRO, and representatives from the RI team and
Investment Risk Management. Representatives of
Group Compliance and Group Legal have a standing
1
NN Group introduced its Purpose Council in 2019, consisting of several Management Board members, heads of relevant staff departments
and business representatives, which was chaired by the CPCSO and sponsored by the CEO. The Purpose Council supported the Management
Board in steering, measuring and reporting on targets related to customers, people and society.
invite. The RI Committee advises the Management
Board on the RI strategy and policies, and oversees
the RI approach of NN Group. It defines the net-zero
roadmap and related action plans, and targets and
performs oversight and steering of the net-zero
ambition for the proprietary investment portfolio.
It is authorised to decide on RI standards, non-
material policies and updates, and investment
restrictions. Material policy proposals and updates,
such as the changes to the norms based RI criteria
for sovereign bonds (scope Proprietary Assets),
require approval of the Management Board, while
asset-class-specific strategies for Paris Alignment
require approval of both the RI Committee and the NN
Group Investment Office Investment Committee. The
RI Committee reports on progress and challenges at
least once a year to the Management Board.
Controversy and Engagement Council
The Controversy and Engagement Council plays a key
role in monitoring and overseeing NN Group’s direct,
collaborative and delegated controversy engagement
activities. The Council is chaired by a member of the
RI team, with members from NN Group’s Investment
Office and Sustainability and Social Impact
department. The Council meets quarterly to discuss
progress on engagement activities and determine
necessary steps to achieve engagement objectives at
the individual company level.
In addition to its oversight and advisory function, the
Council provides inputs and recommendations to the
RI Committee, which validates whether engagement
remains feasible or if a company should be added to
the NN Group Restricted List.
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with a focus on accelerating the transition to a low-
carbon economy, an RI strategy and sustainability-
related strategic targets. Within NN Group, we have a
dedicated RI team that consists of several ESG and RI
professionals from within NN Group’s Sustainability
and Social Impact department and the NN Group
Investment Office.
To meet regulatory requirements, further embed
sustainability in our products and services, and
build sustainability capabilities throughout the
organisation, in 2022 we set up a Task Force
Sustainability in Business (TFSB) for, in principle, a
period of two years. With the additional dedicated
resources, we have accelerated our efforts and
provided our business units with guidance and
support in implementation. The Taskforce’s activities
were transferred to the line organisation in the
fourth quarter of 2024 and its Steering Committee’s
responsibilities have been taken over by the Group
Sustainability Council.
Target setting
As part of its strategy, NN has defined strategic
commitments. Each commitment is linked to targets,
some are financial and some are not directly related
to financial performance. The non-financial or
strategic targets may include environmental, social
and governance (ESG) goals, such as reducing carbon
emissions, increasing employee diversity or building
stronger communities. The sustainability targets are
linked to policy objectives in the areas of responsible
insurance underwriting, responsible investment,
diversity and community investment, and to our
net-zero strategies and climate action plans. NN
Group recognises that achieving these targets is
critical for creating sustainable long-term value for all
stakeholders, including our customers, employees,
investors, business partners and society at large.
Targets on sustainability matters
For our target setting we look at the material
sustainability matters as outcome of the DMA we
perform on a periodical basis. Through our DMA
we gather views and insights from our internal and
external stakeholders such as but not limited to
customers, industry organisations and NGOs. The
outcome is used as input for the company’s
strategy, helps to identify which sustainability
matters are most material and provides the basis for
target-setting. It must be noted that the long-term
commitments, intermediary milestones and targets
in place for 2024 and beyond have been set before
the CSRD regulation was sufficiently developed.
Material matters have been identified through a
sound impact materiality assessment that NN
Group has been performing since 2014, by actively
involving internal and external stakeholders, based
on the Global Reporting Initiative standards (GRI).
In the 2023 assessment, we applied GRI for the last
time and changed approach to double materiality
from a GRI to a CSRD approach.
NN Group’s long-term commitments (e.g. Net-zero
carbon proprietary investment portfolio 2050)
have been made over recent years, and so have
intermediary targets and milestones. The strategic
targets in place have been developed mostly in 2022,
when NN Group had its latest Capital Markets Day
update, and since then updated and fine-tuned in line
with relevant internal and external developments.
For our current targets internal stakeholders have
been involved in the target setting process; views of
external stakeholders have been captured as part of
our regular stakeholder engagement processes and
the DMA . These views are taken into consideration in
the target setting process. Going forward NN aims to
further develop our processes to involve stakeholders
in our target setting.
At the end of 2024, a Sustainability Target Setting
Procedure document was created, which sets out the
process, requirements, roles and responsibilities for
sustainability matters target setting. The provisions
of this procedure are to be observed for the target
setting and updating for 2025 targets and beyond,
and cover CSRD-specific requirements related to
target setting.
Responsibility for target setting
The Management Board of NN (MB) is entrusted with
the overall strategic direction of NN, more specifically
with respect to the setting and achievement of NN’s
objectives. It is its responsibility to steer, measure
and report on a number of sustainability matters
that are relevant for the strategy, and related to
customers, employees and society. In practice this
means that the MB is responsible for deciding on
strategic targets on sustainability matters. The
Management Board each year sets the strategic
targets that are linked to the commitments towards
our customers, people and society. The Supervisory
Board approves the NN Group strategic targets, as
part of the annual Business Plan process.
Responsible Insurance Underwriting
Committee
The RIU Committee is chaired by the CEO of NN
Re, who reports to the CRO. Members include the
Manager Group Sustainability and representatives of
Group Risk, Netherlands Life, Netherlands Non-Life
and NN Insurance International. Representatives
of Group Compliance and Group Legal have a
standing invite. This Committee strategically
discusses sustainability matters for NN’s insurance
underwriting activities; drafts and keeps oversight
on NN Group RIU-related policies, standards and
guidelines; proactively aligns and guides responsible
insurance throughout the company; and reports to
the Management Board on progress. RIU-related
policies and standards require approval of the
Management Board. NN published its Responsible
Insurance Underwriting Framework Policy in 2024.
The RIU Framework Policy provides direction on the
integration of sustainability matters in insurance
underwriting and product development. It is intended
to support NN Group in incorporating sustainability
matters into insurance activities.
Strategy execution and integration in
operating model
NN Group has a dedicated Sustainability and
Social Impact department, with a Sustainability
expert centre, to advise the Management Board
on the implementation of the overall approach to
sustainability. The experts work closely together with
the different business units and functions to steer
and advise on embedding sustainability matters
into their business in accordance with the overall
strategy. This includes our net-zero commitments,
Strategy execution and monitoring
2nd Line of defence
Sustainability is embedded in our governance
Strategy setting
Operational implementation
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Executive Board compensation
Several strategic targets linked to the Executive Board’s
variable remuneration are related to sustainability, including
the contribution to the transition to a low-carbon economy
and the reduction of our direct environmental footprint.
These climate-related targets set measurable reduction
targets for a specific year.
Pricing and underwriting
Pricing and underwriting, including sustainability aspects, are either a responsibility of
the local management board, or a dedicated Product Risk Committee (PRC).
Education and training
The Executive Board, Management Board, Supervisory
Board and senior management attend knowledge sessions
on our sustainability developments, the regulatory
landscape, and our net-zero strategy from internal and
external experts. We have introduced specific learning
modules for specialists and a general sustainability training
for all employees in 2023, further enhanced in 2024.
Centre of Expertise Group Climate
Risk Assessment
Develop necessary methodology for measuring
climate risk and ensure delivery of regulatory
requirements related to climate change.
Centre of Expertise Group functions
Business units
Develop and implement sustainability policies and
standards and embed in day-to-day operations.
Cross-functional working groups
Ensure there is internal alignment and oversight
on specific topics (e.g. net-zero strategy,
biodiversity).
Controversy and Engagement Council
• Monitoring and overseeing engagement activities,
and advising the RI Committee on potential
restrictions.
• Chaired by the RI team, members include
representatives from NN Group’s Investment
Office and the Sustainability and Social Impact
department.
Enterprise Risk Management (ERM),
Investment Risk Management (IRM)
Integrates sustainability in risk framework and
policies, risk management and reporting, and
helps mitigate strategic, financial and non-
financial risks.
Compliance and Legal
The functions review, challenge and support
management in setting and realising its
sustainability strategy and targets, as well as
identifying and assessing sustainability risks.
Group Sustainability Council
Assisting Management Board in relation to sustainability matters, by:
• Facilitating strategy implementation and monitoring execution and
performance, including steering regulatory implementation.
• Discussing and consulting on material changes and developments.
• Incorporates the sustainability and social impact responsibilities
of the former Purpose Council
1
and the responsibilities of the Taskforce
Sustainability in Business Steering Committee
2
, both of which ceased
to exist as of the effective date of the Group Sustainability Council.
• Chaired by Head of Sustainability and Social Impact, includes heads
of staff and BU managers; CPCSO standing invitation.
Responsible Investment Committee
• Advises Management Board on RI strategy and material policies,
including net-zero investment target.
• Decides on RI standards, non-material policies and updates,
and investment restrictions.
• Chaired by CIO, members include CPCSO, CRO, RI Team and IRM.
Responsible Insurance Underwriting Committee
• Advises Management Board on RIU strategy, including net-zero insurance
underwriting targets.
• Chaired by CEO NN Re, members include representatives Netherlands Life,
Netherlands Non-life, and Risk Management; Compliance and Legal
standing invitation.
Asset and Liability Committee
• Oversees the activities and market risks related to investments and the
matching of assets and liabilities, including sustainability risks.
Supervisory Board
Supervises the strategy pursued by the
Executive Board.
Executive Board
Is responsible for the formulation and execution of
the company’s strategy, which includes our
net-zero ambition.
Management Board
Is responsible for the company’s day-to-day
management and overall strategic direction. This
includes the setting and achievement of the
company’s objectives and any sustainability matter
it deems relevant. The Management Board is
responsible for risk taking and management.
1
NN Group introduced its Purpose Council in 2019, consisting of
several Management Board members, heads of relevant staff
departments and business representatives, which was chaired
by the CPCSO and sponsored by the CEO. The Purpose Council
supported the Management Board in steering, measuring and
reporting on targets related to customers, people and society.
2
In 2022 NN Group set up its Task Force Sustainability in Business
(TFSB) and the Taskforce’s Steering Committee for, in principle,
a period of two years. With the additional dedicated resources,
NN Group has accelerated our efforts and provided our BUs with
guidance and support in implementation.
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Risk governance
NN Group’s risk governance follows the three lines
concept, which outlines the decision-making,
execution and oversight responsibilities for NN
Group’s risk management. This structure has been
embedded at both Head Office and business unit
level.
The three lines approach defines three levels, each
with distinct roles, decision authorities, execution
responsibilities and oversight responsibilities. This
concept helps that risks are managed in line with the
risk appetite.
First line: Executive Management
The first line consists of the CEO of NN Group and
the CEOs of the business units, as well as their
management. They make business decisions and
take risks, with primary accountability for the
performance, sales, operations, investments,
compliance and risk management of the company.
This happens both on the executive as well as
process level of the organisation.
More information on the Executive Board,
Management Board and the Supervisory Board and
its committees, including their risk management
responsibilities, can be found earlier in this chapter.
.
NN Group gives direction to business units around
risk taking via the risk appetite framework and
related policies and standards. NN Group’s policies
and standards ensure that risks are managed
consistently and that NN Group as a whole aims to
operate within the risk appetite and related risk limits
and tolerances. The policies and standards focus on
risk measurement, risk control and risk governance.
Policies and standards have to be approved by the
Management Board.
Business units may perform all activities
independently and may make decisions that are
consistent with the strategy of NN Group and the
approved (three-year) business plan and NN Group’s
values, in line with the risk appetite and compliant
with NN governance, policies, standards, laws and
regulations. Decisions can be made by a business
unit CEO, unless decisions require approval of,
for example, the Management Board, specific
Management Board members or the Supervisory
Board, pursuant to the NN Group Decision Structure.
The business unit CEOs are responsible for:
• The profitability, as well as the business and
operational activities, and as such the risk and
control, in their respective areas;
• The execution in their respective areas of any
strategies that conform to the strategic framework
of NN Group;
Three lines
2
2
The Risk Management, Compliance, Actuarial and Internal Audit functions are key functions under Solvency II and apply the regulatory
requirements as part of their responsibility.
Executive
Management
First line
• Make business decisions
• Accountable for financial
performance, sales, operations,
investments, underwriting
• Accountable for risk taking
Risk, Actuarial,
Legal and
Compliance teams
Second line
• Support management in their
decision-making and risk/return
trade-offs
• Countervailing power to prevent
risk concentrations and
unwanted/excessive risk taking
• Developing policies for their
specific risk and control areas
• Encouraging, challenging and
monitoring sound
risk management throughout NN
• Escalation power in relation to
business activities that are
judged to present unacceptable
risks to NN
Corporate Audit
Service
Third line
• Provides independent assurance
on the effectiveness of
NN Group’s business and
support processes, including
governance, quality of risk
management and quality of
internal controls
• Assesses first line activities
as well as second line activities
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• Fulfilling their statutory responsibilities;
• Implementing and maintaining a sound control
framework and operating in accordance with laws
and regulations, NN Group governance, policies,
standards and internal controls, and NN values;
• Sustainability of the corresponding business unit
over the long term; and
• Sharing best practices across NN Group.
Regular oversight interaction between Head Office
and business units takes place with respect to,
among other things, product approval, mandate
approval, risk-limit setting, risk reporting, ORSA,
policy setting and implementation monitoring,
model and assumption review and validation. These
interactions cover all types of risks.
Ad-hoc interactions also take place when a business
unit proposes a material business initiative for
which any Management Board member has the
right to initiate a risk review. A risk review can also
be initiated to investigate a significant incident
or unexpected significant adverse business
performance. A risk review is an in-depth risk
analysis of the object in scope concluding with a risk
opinion and advice where relevant.
Risk-related committees for NN Group
The Executive Board has established the following
risk-related committees: Crisis Committee,
Disclosure Committee, Compensation Committee
(CompCo), Asset & Liability Committee (ALCO) and
Model Committee (MoC).
Second line: Risk Management, Compliance,
Actuarial and Legal
Risk Management function
Within the Management Board, the CRO is
entrusted with the day-to-day execution of the Risk
Management function, while the Legal function and
Compliance function fall within the responsibility of
the General Counsel.
The NN Group CRO steers an independent risk
organisation which supports the first line in its
decision-making, but which also has sufficient
countervailing power to prevent excessive risk
taking. The NN Group CRO is also responsible for
the organisation of Group Risk at Head Office level.
The NN Group CRO must ensure that both the
Management Board and the Supervisory Board are
at all times informed of and understand the material
risks to which NN Group is exposed.
Responsibilities of the Risk Management function
include:
• Setting, and monitoring compliance with, NN
Group’s overall risk policies;
• Formulating NN Group’s risk management strategy
and ensuring that it is implemented consistently
throughout NN Group’s organisation;
• Supervising the operation of NN Group’s risk
management and business control systems,
including NN Group’s Partial Internal Model (PIM);
• Reporting on NN Group’s risks, as well as the
effectiveness of internal business controls;
• Making risk management decisions with regards to
matters which may have an impact on the financial
results of NN Group or its reputation, without
limiting the responsibility of each individual
member of the Management Board in relation to
risk management;
• The NN Group Internal Model, including all
internal-model-related activities such as model
development and model validation; and
• Provide, together with the other second line
functions, a second line opinion when first line
business initiatives can materially impact the
risk profile of a business unit or NN Group and/
or provide additional assurance for presented key
first line risk-related information.
The Group Risk function supports the NN Group CRO
in the execution of his duties and responsibilities,
and consists of four departments:
• CRO International Organisation (CRO IO): performs
functional oversight and has regular involvement
in BU risk management for International BUs, as
well as sets policies, and provides expert support
to the CRO on product, pricing and underwriting
risks;
• Enterprise Risk Management (ERM): includes
Emerging, Strategic, Operational & IT Risk
Management, Business Continuity and GRC
tooling, as well as risk integration and reporting;
• ALM & Investment Risk Management (A&I):
includes risk management related to investments
and ALM, as well as Solvency II risk modelling of
market and counterparty default risks; and
• Risk Models & Analytics (RM&A): includes Internal
Model governance and reporting (including related
systems), as well as Model Validation.
In addition, the responsibility for non-market risks
models lies within the business units.
The business unit CROs of NN Life & Pensions, NN
Non-life and NN Bank report functionally to the NN
Group CRO. The International business unit CROs, as
well as CRO NN Re, report functionally to the Director
CRO of IO. All business unit CROs report hierarchically
to their respective business unit CEOs.
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Model Validation
Model Validation aims to ensure that NN Group’s
models are fit for their intended use and is part
of the Group Risk function. For this purpose,
Model Validation carries out validations of risk
and valuation models related to Solvency II and,
among other things, IFRS regulation. Models are
typically developed within first line teams, or
within the second line risk team, separate from
Model Validation. Any changes to models that have
an impact larger than certain pre-set materiality
thresholds require approval from either the NN Group
CRO, NN Group CFO or the NN Group Management
Board.
NN Group’s Model Validation process ensures the
design and operation of the models continuously
and appropriately reflects the risk profile of the
undertakings concerned. Any deficiencies identified
must be mitigated in time to limit model risk, so
Model Validation can perform different types of
validations during the lifecycle of a model to assure
the reliability of a model and mitigate the identified
Model Risk.
The validation process covers a mix of developmental
evidence assessment, process verification and
outcome analysis. The validation cycle determines
the maximum period between two model validations,
which can be up to five years. This means that each
model in scope will be independently validated
at least once within the validation cycle. Model
Validation can also start validating before the due
date, for example following specific portfolio/market
developments or regulatory changes. Materiality of
a model is determined based on quantitative and
qualitative criteria. Quantitative criteria relate to,
among other things, a percentage of Market Value of
Liabilities/Assets, or Solvency Capital Requirement.
Qualitative criteria cover model complexity, strategic
importance and other factors. Models with a higher
materiality are validated more frequently. Depending
on the materiality of the model, as well as the
severity of findings resulting from a model validation,
models receive a validation opinion. Models with
severe findings require remediation actions by
management, such as further adjustments of the
model, with a set timeline.
Compliance function and Legal function
Within the Management Board, the General Counsel
is entrusted with the day-to-day responsibility for
NN Group’s Legal function and the Compliance
function. The General Counsel steers an independent
compliance and legal organisation which supports
and challenges the first line in its decision-making
with sufficient countervailing power to prevent
excessive risk taking.
The General Counsel is responsible for the
organisation of Group Legal at Head Office level. At
the business unit level, management establishes
and maintains a Legal function and appoints a Head
of Legal. The Head of Legal in principle reports
hierarchically to the business unit CEO. The Heads of
Legal have a functional reporting line to the General
Counsel. The General Counsel must ensure that
both the Management Board and the Supervisory
Board are at all times informed of and understand
the material legal and compliance risks to which NN
Group is exposed.
To effectively manage business conduct risk, NN
Group has an independent Compliance function
headed by a Chief Compliance Officer who is the
Key Function Holder for Compliance and who has
a direct reporting line to the General Counsel. The
Compliance function is positioned independently
from the business it supervises. This independent
position is, among other things, warranted by
independent reporting, unrestricted access to senior
management as well as structural, periodic meetings
of the Chief Compliance Officer with the NN Group
CEO and the chair of the Risk Committee of the
Supervisory Board.
NN Group is committed to upholding its reputation
and integrity through compliance with applicable
laws, regulations and standards in each of the
markets in which NN operates. All employees are
expected to adhere to these laws, regulations and
standards, and management is responsible for
ensuring such compliance. Compliance is therefore
an essential part of good corporate governance.
The purpose of the NN Group Compliance Function
Charter is to help businesses effectively manage their
compliance risks. This document is available on the
NN Group corporate website.
Within NN Group’s broader risk framework, the
Compliance function provides an independent second
line function. Responsibilities of the Compliance
function include to:
• Understand and advocate rules, regulations and
laws for the effective management of risks in
scope of the Compliance function;
• Proactively work with and advise the business to
manage sound business conduct, people conduct
and product suitability risk throughout our
products’ life cycle and our business’ activities to
meet stakeholder expectations;
• Develop and enhance tools to enable the three
lines to detect, communicate, manage and report
on business conduct risks;
• Support NN Group’s strategy by independently
and objectively challenging decision-making in
relation to and management of risks in scope of
the Compliance function whereby a risk-based
approach is used to align business outcomes with
NN Group’s risk appetite;
• Foster a sound risk culture by encouraging a
culture of trust and accountability and addressing
non-compliant or otherwise non-constructive
conduct in an appropriate manner;
• Develop and maintain a framework to advise and
support the first line in adhering to material laws
and regulations as described in the Compliance
Function Charter; and
• Monitor that management and employees act
in accordance with NN Group’s policies and
standards, as well as relevant material laws and
regulation pertaining to integrity and conduct.
At the business unit level, management establishes
and maintains an independent Compliance function
and appoints a Head of Compliance. The Head of
Compliance in principle reports hierarchically to
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the business unit CEO. In addition, the Head of
Compliance has a functional reporting line to the
Chief Compliance Officer. Moreover, the Compliance
function keeps close contact with home and local
supervisors via regular meetings in which current
issues are discussed, as well as internal and external
developments and their impact on NN Group and the
Compliance function.
Actuarial function
The Actuarial function reports hierarchically to the NN
Group CRO and has in addition a functional reporting
line to the NN Group CFO for responsibilities outside
the scope of the Actuarial function. The primary
objective of the Actuarial function is to review
whether technical provisions (under Solvency II and
IFRS) are reliable and adequate, such that NN Group
is able to meet its obligations towards policyholders.
The Actuarial function operates within the context of
NN Group’s broader Risk Management System. Within
this system, the role of the Actuarial function is to:
• Understand and advocate the rules, regulations
and laws for effective management of the
calculation process of technical provisions,
covering elements such as data quality,
assumption setting, models and methods, as well
as underwriting and reinsurance arrangements;
• Proactively advise the business to manage the risk
of unreliable and inadequate technical provisions;
• Inform management and the Supervisory Board on
its opinion on the adequacy and reliability of the
(calculation of) technical provisions, the adequacy
of reinsurance arrangements and the underwriting
policy on an annual basis at least through the
Actuarial Function Report;
• Develop and enhance tools to strengthen the three
lines to detect, communicate, manage and to
report on risks related to unreliable or inadequate
technical provisions;
• Support NN Group’s strategy by establishing clear
roles and responsibilities to help embed good
(actuarial) practices throughout the organisation
by using a risk-based approach to align insights
with NN Group’s risk appetite;
• Strengthen the culture of professional risk
management by challenging management
and experts to increase the culture of trust,
accountability, transparency and integrity in
evaluating, managing and reporting on risks to
unreliable or inadequate technical provisions; and
• Provide a second line opinion when first line
business initiatives can materially impact the
risk profile of a business unit or NN Group and/
or provide additional assurance for presented key
first line risk-related information.
Third line: Corporate Audit Services
Corporate Audit Services (CAS) provides independent
assurance on the effectiveness of NN’s business and
support processes, including governance, quality
of risk management and quality of internal controls.
They assess the first line and the second line
activities. CAS supports NN Group in accomplishing
its mission and objectives through a systematic,
documented approach to examine, evaluate and
improve the design and effectiveness of (NN Group’s
framework of) governance, risk (management)
processes, and internal control.
CAS keeps close contact with home and local
supervisors and regulators, as well as with the
external auditor via regular meetings in which current
(audit) issues are discussed, as well as internal and
external developments and their impact on NN Group
and CAS. CAS also provides information such as risk
assessments and relevant (audit) reports.
The Head of CAS and all CAS employees are
authorised to:
• Obtain without delay, from general managers
within NN Group, information on any significant
incident concerning NN Group’s operations,
including but not limited to security, reputation
and/or compliance with regulations and
procedures;
• Obtain without delay, from responsible managers
within NN Group, a copy of all letters and reports
received from external review agencies (e.g.
external auditor, supervisors, regulators and other
agencies providing assurance-related services);
• Have free, full, unrestricted and unfettered
access – at any time deemed appropriate – to
all NN Group departments, offices, activities,
books, accounts, records, files, information. CAS
must respect the confidentiality of (personal)
information acquired;
• Require all NN Group staff and business
management to supply such information
and explanations, as may be needed for the
performance of assessments, within a reasonable
period of time;
• Allocate resources, set frequencies, select
subjects, determine scope of work and apply
appropriate techniques required to accomplish the
CAS’s objectives;
• Obtain the necessary assistance of personnel in
various departments/offices of NN Group where
CAS performs audits, as well as other specialised/
professional services where considered necessary
from within or outside NN Group. CAS exercises
its authority with the minimum possible disruption
to the day-to-day activities of the area being
assessed; and
• In compliance with the Code, the Executive Board
is responsible for the role and functioning of CAS,
supervised by the Supervisory Board, supported
by the Audit Committee of the Supervisory Board.
The Head of CAS is accountable to the NN Group
CEO and functionally (independent) to the chair of
the Audit Committee of the Supervisory Board. On
a day-to-day basis the Head of CAS reports to the
NN Group CEO.
Sustainability risk management
Responsibilities for managing sustainability risks
follow the overall risk governance of NN Group as
described on p. 81 ‘Risk governance’. The main
responsibilities around sustainability risks are
described below, and are based on the three lines
model. Integration of sustainability risks in our
regular risk governance is still developing, among
other things driven by the emerging character of the
related risks. Over time they will become a regular
part of (risk) management activities.
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First line: Executive Board, management
boards and other managers
The Executive Board and other managers are
responsible for setting sustainability-related
targets, policies and actions, as well as risk taking
and mitigation. The basis for defining material
sustainability IROs is the DMA, informed by other
(risk) management processes.
Investments are managed in the first line through a
dedicated Central Investment Office (CIO), which is
among other things responsible for the investment
strategy (including our net-zero strategy), Strategic
Asset Allocation, and managing/monitoring the
investment mandates and asset managers. This
includes managing related market risks, including
sustainability risks.
The Asset & Liability Committee (ALCO) oversees the
activities and market risks related to investments
and the matching of assets and liabilities, including
sustainability risks. This includes approving related
policies, monitoring performance of the investment
portfolios and setting/monitoring adherence to
several financial risk limits and tolerances.
Product management is typically locally arranged,
given the local characteristics of the market and
customers. Pricing and underwriting, including
sustainability aspects, are either a responsibility of
the local management board, or a dedicated Product
Risk Committee (PRC). Centrally and across all NN
Group business units, a Product Approval and Review
Process (PARP) is applied for proper product design,
product suitability, sound underwriting and claims
management, and adequate pricing of existing
and new products. As part of the PARP procedure,
sustainability risks are assessed as part of overall
pricing, as well as to what extent product information
properly reflects sustainability characteristics.
Second line: Risk, Actuarial, Compliance and
Legal teams
The Risk, Compliance and Legal functions have
dedicated resources working on sustainability
matters. The functions review, challenge and support
management in setting and realising its sustainability
strategy and targets, as well as identifying and
assessing sustainability risks. Our Risk, Compliance
and Legal functions support our business lines with
implementing sustainability related regulations,
including integrating this into NN’s own risk and
control framework. As such, second line teams are
represented in different committees mentioned
elsewhere in the Corporate Governance section, as
well as different project bodies. Reference is made to
those paragraphs for more details.
In 2022, NN established a Centre Of Expertise (CoE)
on Climate and Sustainability Risks, that brings
together experts from the first and second line to
share knowledge and ensure delivery of mandatory
deliverables, with a specific focus on climate risks.
Since 2023, an overall dedicated steering committee,
representing different teams from first and second
line, meets regularly and discusses/approves
methodologies, risk assessment results and other
documents relevant to managing NN Group’s climate
risks.
Tasks within the second line are:
• The Enterprise Risk Management team coordinates
the overall CoE on climate risks, coordinates a
materiality assessment into climate risks, delivers
input into the DMA, develops methodologies to
assess and monitor climate risks and coordinates
the yearly ORSA, which includes stress testing and
scenario analysis of climate risks;
• The Investment Risk team issues second
line opinions on investment (risk) proposals.
Furthermore, the team is involved in developing
further understanding how sustainability risks
might impact value of assets and develop risk
mitigation strategies for this;
• The CRO International Office team coordinates the
Product & Underwriting CoE, which owns several
product, pricing and underwriting related policies;
• The Chief Actuary Office is involved in assessing
sustainability risks that might impact pricing and
underwriting assumptions, as well as the overall
technical provisions of NN;
• Group Legal and Compliance are involved in the
relevant sustainability committees and projects,
supporting and challenging from their respective
areas of responsibility. They provide second line
views and, where applicable, second line opinions,
deliver input into relevant parts of the DMA, and,
together with Risk, coordinate and oversee the
PARP;
• Group Compliance is involved in the sustainability
risks that might impact the risks in scope of the
Compliance function and certain strategic risks,
with a focus on commitments, conduct, and
potential impact on customer or society; and
• Group Legal is involved in monitoring legislative
developments arising from new and changing laws
and regulations, as well as disclosures, including
the potential risk of greenwashing.
Third line: Corporate Audit Services (CAS)
CAS, as internal audit department, incorporates ESG
elements (e.g. CSRD reporting) into the annual risk
assessment and audit planning process to define a
proper audit response. In 2023 CAS performed an
assignment on the SFDR implementation throughout
NN Group and in 2024 an assignment on the set-up
of the CSRD dataflows.
System of Governance evaluation in 2024
In 2024, various elements of NN Group’s System
of Governance were reviewed and discussed
by the Management Board. Where appropriate
improvements were implemented.
Corporate Governance Statement
This chapter also serves as the corporate governance
statement referred to in section 2a of the Decree
contents of the management report (Besluit inhoud
bestuursverslag). This includes parts of this Annual
Report incorporated by reference, together with
the separate publication ‘Application of the Dutch
Corporate Governance Code by NN Group’, dated
12 March 2025 and available on the NN Group
website.
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Our Management Board
Our Management Board
From left to right:
Frank Eijsink
Janet Stuijt
David Knibbe
Annemiek van Melick
Tjeerd Bosklopper
Wilbert Ouburg
Dailah Nihot
Leon van Riet
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Our Management Board
Appointed to the Executive Board and
designated as Chief Executive Officer (CEO) of
NN Group and as a result chair of the Executive
Board and Management Board effective
1 October 2019 and was reappointed on
2 June 2023.
Mr Knibbe is responsible for the business
strategy, performance and day-to-day
operations of NN Group. He has been a
member of the Management Board since
7 July 2014, at which time he served as CEO
Netherlands. His previous positions include
CEO of ING Insurance Europe. Mr Knibbe holds
a Master’s degree in monetary economics
from the Erasmus University in Rotterdam (the
Netherlands). He is member of the board and
treasurer of the Confederation of Netherlands
Industry and Employers (VNO-NCW), member
of the Federative Board VNO-NCW and MKB
NL, member of the board of the Johan Cruyff
Foundation, member of the advisory board
of JINC, member of the Hoogeschoolraad of
Vereniging Trustfonds Erasmus University,
member of the Geneva Association, member of
the Pan-European Insurance Forum, member
of the World Economic Forum’s Alliance of
CEO Climate Leaders and Governors meeting
Financial Sector, supervisory board member
of Stichting Erasmus Trustfonds, and societal
member of the KHMW.
Appointed to the Executive Board and
designated as Chief Financial Officer (CFO) and
as a result vice-chair of the Executive Board
and Management Board effective 1 July 2022.
Ms van Melick is responsible for NN Group’s
finance departments and investor relations.
Her previous positions include CFO at a.s.r..
She holds a degree in business administration
from Nyenrode Business University (the
Netherlands) and a law degree from Utrecht
University (the Netherlands). She is member
of the supervisory board and chair of the audit
committee at Royal Swinkels Family Brewers
Holding N.V., and member of the CFO Forum.
Appointed CEO Netherlands Non-life, Banking
& Technology and member of the Management
Board as of 1 June 2020.
Mr Bosklopper is responsible for the Dutch
Non-life and Banking business segments,
Customer & Digital, NN Ventures, IT
and procurement globally. He was CEO
Netherlands ad interim from 17 December
2019 until 1 June 2020. He was appointed to
the Management Board of NN Group as Chief
Transformation Officer on 1 September 2018.
Mr Bosklopper’s previous positions include
Head of Integration of Nationale-Nederlanden
Netherlands and Belgium. He holds a
Master of Science in Business Information
Technology from the University of Twente
(the Netherlands). He is member of the board
and vice-chair of the Dutch Association of
Insurers (Verbond van Verzekeraars) and
member of the Steering Committee of National
Coalition Financial Health (Nationale Coalitie
Financiele Gezondheid).
Appointed CEO International Insurance and
member of the Management Board as of
1 September 2023.
Mr Eijsink is responsible for Insurance Europe,
NN Group’s European insurance businesses
excluding the Netherlands. His previous
positions include CEO of several NN Group
International Insurance business units,
such as NN Belgium, Japan Life, NN Life and
Pensions Turkey, and ING Life Luxembourg.
He holds a Master of Science in Physics and a
Master of Science in Business Engineering and
Management Science from the University of
Technology in Eindhoven (the Netherlands).
Appointment
Role and
experience
David Knibbe
Chief Executive Officer
Annemiek van
Melick
Chief Financial Officer
Tjeerd Bosklopper
Chief Executive Officer
Netherlands Non-life,
Banking & Technology
Frank Eijsink
Chief Executive Officer
International Insurance
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Our Management Board
Appointed CEO Netherlands Life & Pensions
and member of the Management Board as of
1 June 2020.
Mr van Riet is responsible for the Life and
Pension businesses in the Netherlands, as
well as for Japan Life as of 1 September
2023. His previous positions include CEO
of Nationale-Nederlanden Non-life in the
Netherlands. He holds a degree in electrical
engineering from Delft University of
Technology (the Netherlands).
Mr van Riet is chair of the sector life insurances
of the Dutch Association of Insurers (Verbond
van Verzekeraars) and member of the board
of Stichting Dienstverlening VoV. He is also
member of the supervisory board of the Dutch
Terrorism Claims Reinsurance Company
(Nederlandse Herverzekeringsmaatschappij
voor terrorismeschaden) and member of the
supervisory board of the Netspar Foundation.
Appointed to the Management Board as
General Counsel as of 1 September 2018.
Ms Stuijt is responsible for NN Group’s legal
function, the group compliance function
and Corporate Security & Investigations
department, and holds the position of
Company Secretary.
Her previous positions include General
Counsel & Head of Compliance of NN Group.
She holds a Master’s in Civil law, from the
University of Leiden (the Netherlands). Ms
Stuijt is vice-chair of the supervisory board
of Nederlandse Spoorwegen N.V., chair of its
remuneration & nomination committee and
member of its risk & audit committee. She
is also member of the advisory board of the
Master Law & Finance of the University of
Amsterdam.
Appointment
Role and
experience
Appointed Chief Organisation & Corporate
Relations and member of the Management
Board as of 1 September 2018. To better
reflect the portfolio managed by her, her title
changed to Chief People, Communications
and Sustainability Officer with effect from
1 December 2022.
Ms Nihot is responsible for NN Group’s
overall corporate relations, sustainability,
branding, human resources and facility
management functions, with a specific focus
on the company’s role in society. Her previous
positions include Managing Director of
Corporate Relations for NN Group. She holds
a Master’s degree in European Studies from
the University of Amsterdam (the Netherlands)
and an Executive Master’s in Corporate
Communication from the RSM Erasmus
University in Rotterdam (the Netherlands).
Ms Nihot is member of the supervisory board
of WOMEN Inc.
Dailah Nihot
Chief People,
Communications, and
Sustainability Officer
Leon van Riet
Chief Executive Officer
Netherlands Life &
Pensions
Janet Stuijt
General Counsel
Appointed Chief Risk Officer (CRO) and
member of the Management Board as of
1 October 2024.
Mr Ouburg is responsible for the overall risk
framework with direct responsibility for the
risk management departments. He is also
responsible for the actuarial function and
reinsurance. Mr Ouburg’s previous positions
include CRO at Nationale-Nederlanden Life
& Pensions. Mr Ouburg has an Executive
Master’s degree in Actuarial Science and
Mathematical Finance from the Amsterdam
Business School (the Netherlands), a Master’s
degree in Mathematical Sciences from Utrecht
University (the Netherlands), and he is a
qualified actuary. Besides being a member
of the Management Board, Mr Ouburg is a
member of the Dutch Actuarial Society and
member of the CRO Forum.
Wilbert Ouburg
Chief Risk Officer
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Our Supervisory Board
Our Supervisory Board
From left to right:
David Cole
Cecilia Reyes
Rob Lelieveld
Koos Timmermans
Robert Jenkins
Pauline van der Meer Mohr
Inga Beale
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Our Supervisory Board
Appointed to the Supervisory Board on
31 May 2018, effective from 1 January 2019.
As of the close of the AGM on 29 May 2019, Mr
Cole serves as chair of the Supervisory Board.
He was reappointed on 19 May 2022.
Mr Cole’s previous positions include CFO and
CRO of Swiss Re Ltd. He holds a Bachelor
of Business Administration degree from
the University of Georgia (United States)
and attended the International Business
Programme at the Nyenrode University
(the Netherlands). He is also member of the
board of directors of Vontobel Holding AG,
member of the European Financial Roundtable
(EFR), chair of the supervisory board of IMC
Global Holdings LLC and member of the board
of directors of COFRA Holding AG.
Appointed to the Supervisory Board on 19 May
2022, effective from 1 January 2023. As of
the close of the AGM on 2 June 2023, Ms
van der Meer Mohr serves as vice-chair of
the Supervisory Board. She is considered
appointed pursuant to the enhanced
recommendation right of the Central Works
Council as of the close of the AGM on 24 May
2024.
Ms van der Meer Mohr’s previous positions
include CHRO of ABN AMRO Bank N.V., chair
of the executive board of Erasmus University
of Rotterdam and chair of the Dutch Corporate
Governance Code Monitoring Committee. She
holds a Master’s degree in Advanced Dispute
Resolution, University of Amsterdam (the
Netherlands), and in Dutch Law, Erasmus
University Rotterdam (the Netherlands).
She is also chair of the supervisory board
of ASM International N.V. and member of
the supervisory board of Koninklijke Ahold
Delhaize N.V.
Appointed to the Supervisory Board on
20 May 2021.
Ms Beale’s previous positions include
CEO of Lloyd’s of London. As a reinsurance
underwriter, she attained a degree equivalent
insurance qualification as an Associate of the
United Kingdom Chartered Insurance Institute
and became Chartered in 2016. She also
completed the Manager Development Course
and higher-level Business Management
Course as part of the Executive Education
programme at GE’s Stamford-based University
(United States). She is non-executive director
of Crawford & Company Inc., member of the
board of Willis Towers Watson and chair of the
board of South Pole.
Appointed to the Supervisory Board on
6 October 2015, effective from February 2016.
Mr Jenkins was reappointed on 28 May 2020
and on 24 May 2024.
Mr Jenkins’ previous positions include head
of trading at various international Citibank
offices, CEO of several asset management
firms, and a policy-making role at the Bank
of England. He has chaired the Investment
Association UK, the AQR Asset Management
Institute, and CFA Institute. He holds a
Master’s degree in International Studies
with the focus on International Economics
and European Area Studies from Johns
Hopkins University (United States). He is
currently member of the Advisory Council to
the Research and Policy Center of the CFA
Institute.
Appointment
Skills,
competence
and experience
David Cole
Chair
Pauline van der
Meer Mohr
Vice-chair
Inga Beale
Member
Robert Jenkins
Member
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Our Supervisory Board
Appointed to the Supervisory Board on 20 May
2021, effective from 1 September 2021.
Mr Lelieveld was appointed pursuant to the
enhanced recommendation right of the Central
Works Council.
Mr Lelieveld’s previous positions include chair
of the managing board of EY Accountants in
the Netherlands and member of the board of
directors of EY in the Netherlands. He holds
a degree in accountancy but deregistered
as a chartered accountant from the register
of accountants held by the Koninklijke
Nederlandse Beroepsorganisatie van
Accountants (NBA) when he left EY in
June 2021. He is vice-chair of the supervisory
board and chair of the audit committee of
the Mauritshuis and member of the
supervisory board at Stichting Atlantische
Commissie.
Appointed to the Supervisory Board as of
20 May 2021.
Ms Reyes’ previous positions include group
CIO and group CRO at Zurich Insurance
Group Ltd. In both roles she was a member
of the group executive committee until her
retirement from the company in February
2018. She holds a Bachelor of Science degree
in Management Engineering from the Ateneo
de Manila University (Philippines), an MBA in
Finance from the University of Hawaii (United
States), and a PhD in finance from London
Business School (United Kingdom). Ms Reyes
serves as managing director of Pioneer
Management Services GmbH, non-executive
director and member of the audit, risk,
remuneration and nominations committees
of Beazley plc, and non-executive director of
RiverStone International Holdings Limited.
Appointed to the Supervisory Board as of
24 May 2024.
Mr Timmermans’ previous positions
include CRO of the Executive Board and
CFO at ING Groep N.V. At ING, he was also
responsible for the areas of sustainability,
international relations and regulatory affairs.
Mr Timmermans has a Master’s degree in
economics from the Erasmus University in
Rotterdam (the Netherlands). He is chair of the
supervisory board of Havenbedrijf Rotterdam
N.V., member of the supervisory board of
PostNL N.V., member of the supervisory board
of Nederlandse Financierings-Maatschappij
voor Ontwikkelingslanden N.V., and member
of the supervisory board of Stichting Koningin
Wilhelmina Fonds voor de Nederlandse
Kankerbestrijding.
Appointment
Rob Lelieveld
Member
Cecilia Reyes
Member
Koos Timmermans
Member
Skills,
competence
and experience
David Cole, Chair:
‘ It was a successful year
in which NN showed
good progress in strategy
execution with high levels
of customer satisfaction
and employee engagement,
and made a positive
contribution to society.’
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Conversation with our Supervisory Board chair
NN Group N.V. Annual Report 2024 | 93
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Conversation with our Supervisory Board chair
A conversation with our
Supervisory Board chair
Supervisory Board chair David Cole looks back on 2024. He
addresses the trends that affected our business as well as
the opportunities we seized and the progress we continue to
make in our strategy execution.
How do you look back on 2024?
The turbulent geopolitical environment continues
to cause a lot of uncertainties. It is affecting the
lives of many people and it poses a threat to
financial stability and the global economy. For an
internationally operating company like NN Group,
it is important to understand these global trends
and assess the potential impact, as it will allow us
to successfully navigate this environment and keep
supporting customers and the things that matter to
them.
Throughout the year, we worked to support the
Management Board in navigating this uncertainty.
For example, we discussed how NN is positioned to
absorb potential shocks caused by financial market
volatility, such as sudden changes in interest rates
or sovereign bond markets. We were pleased to see
the company continues to show financial strength,
thanks to its diverse footprint, strong client retention,
risk management capabilities and high-quality
investments.
How do you reflect on NN Group’s
performance?
Overall, we look back on a good year, both from a
strategic and financial perspective. Across European
markets, we made good headway in further
developing the protection business, partly thanks
to the successful integration of recent acquisitions
in Poland and Greece. The business in Japan is
also showing signs of improvement. The Dutch life
and pensions business continued to improve its
operating performance, positioning itself for the new
pension regulations that will come into effect over
the next couple of years. The Dutch non-life business
made good progress in further improving its market
position while maintaining strong profitability, and
the banking business also continued to perform well.
So altogether, it was a successful year in which NN
showed good progress in strategy execution, with
high levels of customer satisfaction and employee
engagement, and made a positive contribution to
society.
What were the focus areas of the
Supervisory Board in 2024?
As always, in our meetings with the Management
Board, we spent a lot of time discussing strategy
execution and monitoring performance. One of NN’s
strategic priorities is to further improve the customer
experience, which is a key driver for long-term
growth. Insurers typically have fewer touchpoints
with customers than, for example, banks or retailers,
so it’s important to get each interaction right.
We are pleased to see continued progress in this
area, but there is still work to be done as customer
expectations continue to evolve.
Secondly, the settlement on unit-linked insurance
products at the start of 2024 was a main focus.
The settlement was an important milestone in what
has been a long-standing issue, and it brought a
positive outcome for everyone involved. However, the
settlement still needs to be finalised in 2025,
and therefore it will continue to be an area of
attention for us.
Thirdly, we dedicated a lot of time on dialogue
around sustainability, also in light of the new
requirements under the Corporate Sustainability
Reporting Directive (CSRD). We not only discussed
the importance of setting clear objectives and how
to track progress, but we also focused on ensuring
proper reporting on these data.
Finally, as in previous years, we continued to focus on
talent development and succession planning during
2024. In these fast-changing times, it is crucial the
company has a strong and diverse leadership team
to steer the company in the right direction. We are
pleased to see NN is still able to attract and retain the
talent we need.
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NN Group aims to become a digital
and data-driven organisation. How
does the Supervisory Board view these
developments?
We all see how the world is changing rapidly as a
result of the current technological advancements,
particularly in the area of artificial intelligence (AI).
At the end of 2023, NN refined its strategy with a
focus on becoming more digital and data-driven.
Now that a year has passed, we are witnessing the
benefits, for example in the administration of the
company’s closed life insurance book, but also in
insurance underwriting, and customer engagement.
We had regular meetings with the Management
Board to discuss how further digitalisation can make
NN ready for the future, as long as it is deployed
in an effective and ethical fashion. Of course, the
breakneck pace of innovations nowadays poses a
challenge for any management team or supervisory
board. To keep ourselves up to speed and maintain
full awareness of the developments and the
impact, we dedicate a lot of time to education.
We also conducted technology deep-dives across
the organisation and invited internal and external
speakers.
What are the priorities for 2025?
As the Supervisory Board, our priorities will remain
focused on supporting the Management Board and
NN Group in executing the strategy, which enables it
to continue to create sustainable long-term value for
stakeholders.
Looking ahead, the upcoming Capital Markets Day in
May will be in focus. As Supervisory Board, we look
forward to engaging with the Management Board and
discussing the next steps for the company. On behalf
of the Supervisory Board, we thank the Management
Board and all employees at NN Group for their
commitment and strong performance in 2024, and
we look forward to supporting them in 2025.
Conversation with our Supervisory Board chair
‘ We all see how the world is changing
rapidly as a result of the current
technological advancements,
particularly in the area of artificial
intelligence.’
Male
Female
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Report of the Supervisory Board
Report of the Supervisory Board
The Supervisory Board is responsible for supervising the
management of the Executive Board (including NN Group’s culture)
and the general course of affairs of NN Group and its businesses.
The Supervisory Board also advises the Executive Board.
Taking into consideration all stakeholder interests,
the Supervisory Board monitors and evaluates the
management of the Executive Board and advises the
Executive Board on matters such as (i) establishing
and reaching NN Group’s strategic commitments, (ii)
sustainable long-term value creation by NN Group
and (iii) sustainability matters that are relevant to NN
Group.
This Supervisory Board Report should be read in
conjunction with the sections on Our Supervisory
Board (p. 89-91), Corporate governance, (p. 66-85)
and the Remuneration Report (p. 103-114) of this
Annual Report. The information in these sections
regarding the positions of the Supervisory Board
members, their date of first appointment and term of
appointment are considered an integral part of this
Supervisory Board Report.
Profile of the Supervisory Board
The composition of the Supervisory Board is such
that its members are able to act critically and
independently from each other, the Executive
Board and any particular interests. The Supervisory
Board works as a collegial body and the individual
members’ knowledge, experience and background
are attributed to the Supervisory Board as a whole.
In the composition of the Supervisory Board,
there is a balanced representation in members’
(a) nationality, nation of origin, race, ethnicity,
languages spoken, belief system, gender, age, sexual
orientation, neurodiversity and physical diversity;
(b) affinity with the nature of the businesses and
culture of NN Group; and (c) executive experience,
experience in complex multinationals, and the
political and social environment they operate in.
7
3
20
Supervisory Board
meetings
Supervisory Board
Committees
hours spent on
Permanent Education
sessions arranged by
NN Group
Attendance rate: 96%
98
%
Supervisory Board
composition
overall attendance of
Supervisory Board
meetings
4:3
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Report of the Supervisory Board
This ensures a broad range of relevant perspectives
and opinions on NN Group, and the opportunities and
challenges it faces today and will face in the future.
All members of the Supervisory Board are
independent, within the meaning of best practice
provision 2.1.8 of the Dutch Corporate Governance
Code.
The Diversity and Skills matrix on p. 102 provides the
range of knowledge, experience and backgrounds of
the individual Supervisory Board members.
Supervisory Board meetings
The Supervisory Board convened seven times in
2024, including one meeting held in Japan as
part of the Supervisory Board’s official visit to
NN Group’s offices in Tokyo. The attendance rate
for these meetings averaged 98%, reflecting the
dedication and capacity of the members to allocate
sufficient time and focus to NN Group. None of the
Supervisory Board members were frequently absent
from meetings, ensuring that quorum requirements
were met at each session. In addition, there were
four virtual meetings scheduled during the year to
address ad hoc topics. Beyond formal meetings,
the chair and other Supervisory Board members
maintained ongoing communication with NN Group’s
Executive Board, Management Board and senior
management. Furthermore, the Supervisory Board
engaged with regulatory authorities, (representatives
of) the Central Works Council, and the external
auditor, KPMG.
Discussion topics
Every conversation between the Supervisory Board
and the Executive Board and Management Board
regarding the general affairs of the company,
included a focus on the geopolitical and economic
environment NN Group operates in. It is imperative
that the boards are aware of the international
geopolitical and economic circumstances that
influence NN’s operations. The financial services
industry is inherently linked to global stability and
economic trends, and NN’s ability to adapt and
respond to these external factors is crucial for
sustaining growth and ensuring resilience in volatile
times. In reflecting on the past year and preparing
for the future, the Supervisory Board continuously
addresses these challenges, leveraging its collective
expertise to navigate the ever-evolving landscape
and advise the Executive Board and Management
Board. This commitment helps position NN Group to
meet the needs of NN’s stakeholders effectively and
responsibly.
Strategy
Although the Executive Board has primary
accountability for formulating NN’s strategy and
specific objectives, the Supervisory Board is much
involved. Its role is to challenge and advise the
Executive Board and Management Board on the
strategy and its implementation for sustainable
long-term value creation and the underlying drivers
thereof. For this reason, strategy discussions are a
recurring, prominent topic on the Supervisory Board
agenda. In 2024, the boards collectively agreed
to allocate more time to strategy discussions and
enhance the quality and robustness of the dialogues
in this regard, also in preparation for the Capital
Markets Day on 27 May 2025, when NN Group will
provide a strategic update.
The strategic and financial objectives, as included
in NN’s business and capital plans, received formal
approval from the Supervisory Board. The Supervisory
Board maintained close oversight of business
performance and received at least quarterly updates
on NN’s performance towards these objectives.
Besides monitoring business performance, the
Supervisory Board demonstrated a strong interest in
the various challenges and successes of the business
units, thereby requesting comprehensive updates
by the responsible Management Board members
throughout the year.
Financials
A major theme in the Supervisory Board meetings
was the integrity and quality of the financial and
sustainability reporting, assessed by the Audit
Committee. During 2024, the Supervisory Board
discussed and approved the 2023 annual accounts
as well as the proposed final dividend payment for
the year, both adopted by the AGM in 2024, the share
buyback programme, and NN Group’s 2024 interim
dividend.
Other
Society is changing due to digitalisation. To
adequately fulfil its monitoring role, the Supervisory
Board spent time on regular updates and education
on this topic. Moreover, NN Group is becoming a
digital and data-driven company, and digitising,
standardising and industrialising processes as a
means to deliver on strategy. It is therefore a topic
the Supervisory Board has to stay closely informed
on.
The Supervisory Board also maintained close
oversight of the execution of the settlement
agreement reached between NN and various interest
groups in January 2024, concerning unit-linked
insurance products sold in the Netherlands. Regular
updates were provided to the Supervisory Board to
enable thorough monitoring.
At the beginning of 2025, the Supervisory Board
discussed NN Group’s Corporate Culture Report
2024. Where the Executive Board and Management
Board are responsible for NN’s culture and values
‘care, clear, commit’, which serve as a compass for
conduct and decision-making, the Supervisory Board
is eager to discuss the developments in this area
with management on an annual basis. This time, the
introduction of the NN Behaviours was also part of
the discussion.
Additionally, the succession planning for managerial
positions reporting to the Management Board, also
as part of the key talent management process,
is a yearly recurring topic for discussion by the
Supervisory Board. The Supervisory Board is deeply
engaged in ensuring the quality and diversity of the
succession plans and the talent employed
by NN.
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Report of the Supervisory Board
Moreover, sustainability subjects, such as the
Responsible Insurance Underwriting Framework
Policy, designed to incorporate sustainability into
NN’s insurance underwriting, and updates to the
Sustainability Bond Framework, which allows NN
Group to issue green, social or sustainability bonds,
were particularly highlighted and discussed with the
Supervisory Board during their meetings.
Lastly, the Supervisory Board evaluated the
functioning of the Executive and Management Board,
including the performance of individual members, an
exercise which is performed every year.
Note that a diverse range of other topics were
diligently pre-discussed and prepared within one
of the three Supervisory Board Committees: the
Audit Committee, Risk Committee or Nomination,
Remuneration & Governance Committee. The
respective committee chairs have thoroughly
reported to the Supervisory Board on the subjects
delegated to their respective committee. Detailed
information can be found in the section on committee
activities.
Self-assessment
The Supervisory Board conducted an evaluation of its
performance for the year 2024. The self-assessment
was centered around five main questions: (i) How can
the Supervisory Board improve? (ii) Thinking about all
relevant areas, where should the Supervisory Board
increase its focus for 2025 and 2026? (iii) What can
the Supervisory Board do to help management to be
more effective? (iv) Are there any other matters worth
mentioning? (v) Is there any feedback for the chair of
the Supervisory Board? Furthermore, the Supervisory
Board gathered insights into its performance through
evaluation sessions with the Executive Board and
Management Board members. This comprehensive
approach ensured the identification of forward-
looking priorities.
In conclusion, the Supervisory Board functions well.
Members are committed to continuous improvement
by proactively addressing strategic topics and
ensuring clear communication with the Executive
Board and Management Board. The dedication
to transparency and constructive dialogue is
appreciated by all members and effectively navigates
future challenges and opportunities.
Education programme
The Supervisory Board is committed to continuous
education and professional development, ensuring
its members possess and maintain the requisite
knowledge and skills to fulfill their duties. In
accordance with the outcomes of the Supervisory
Board self-assessment, the yearly reviewed Diversity
and Skills matrix of the Supervisory Board members,
the Double Materiality Assessment (DMA), and
input from the business units and management, a
permanent education programme is crafted for the
Supervisory Board every year. This programme covers
a wide variety of topics in which the Executive Board
and Management Board members also participate.
Certain topics are covered by experts from outside
the company, providing the boards with access to
external perspectives and advice.
The 2024 permanent education programme
incorporated deep dives into two business units.
The Supervisory Board received a detailed update
on NN Group’s Non-life business in the Netherlands
and the Life business in Japan, and visited Japan as
part of their offsite. These deep dives were designed
to enhance the members’ understanding of local
challenges, opportunities, strategic initiatives,
products, customer bases and corporate cultures.
The programme also included sessions on economic
and market trends, and, as recurring bi-annual
components of the programme, educational sessions
focused on NN Group’s partial internal model (PIM),
including anticipated Major Model Changes (MMCs).
Moreover, and given the importance of operational
resilience, specific training was provided on the
Digital Operational Resilience Act (DORA) and NN’s
implementation efforts. Additionally, the Supervisory
Board received training on sustainability matters,
including on specific topics such as measuring
and monitoring greenhouse gas (GHG) emissions
and ways for NN to reduce them, and NN Group’s
community investment initiatives.
Furthermore, the Supervisory Board placed
significant emphasis on advancing their technological
proficiency, particularly their knowledge of artificial
intelligence and its beneficial impact on the company,
alongside the legal aspects associated with it.
The Supervisory Board is confident that the
permanent education programme in 2024 has further
enhanced and maintained the members’ expertise.
In addition, NN Group has a thorough induction
programme, which is mandatory as an onboarding
process for NN Group’s Supervisory Board members.
It consists of meetings with Executive Board,
Management Board and (other) Supervisory Board
members, management teams of the Dutch business
units, and other key staff, as well as sessions
on sustainability, governance, compliance, and
finance and risk topics, including financial reporting
and NN Group’s PIM.
Supervisory Board Committees
The Supervisory Board has three formal committees
that support it in performing its supervisory role:
The Audit Committee, the Risk Committee and the
Nomination, Remuneration & Governance Committee.
The Supervisory Board Committees assist the
Supervisory Board in its decision-making by reporting
their considerations and recommendations on
the topics delegated to them, with the underlying
discussion documented.
With the expiry of the term of appointment of Hans
Schoen and the appointment of Koos Timmermans
as Supervisory Board member, as of the close of
the 2024 AGM, the composition of the committees
changed, as is shown in the graphic on p. 102. The
topics that were included in the three Committee
agendas in 2024 are outlined in detail in the following
paragraphs.
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Report of the Supervisory Board
In addition to the Supervisory Board committee
members, the committees were attended by the
following people:
The Risk Committee meetings were attended by NN
Group’s CEO, CFO, CRO, General Counsel (GC), Head
of Corporate Audit Services (CAS), Head of Group
Enterprise Risk Management, Chief Compliance
Officer (CCO) and the external auditor.
The Audit Committee meetings were attended
by NN Group’s CEO, CFO, CRO, GC, CPCSO (when
appropriate), Head of CAS, Head of Group Finance,
Head of Performance & Analytics, Head of Financial
Accounting & Reporting, Chief Actuary and the
external auditor.
The Nomination, Remuneration & Governance
Committee meetings were attended by NN Group’s
CPCSO and when appropriate the CEO and the Head
of Reward.
Often, subject-matter experts participated in
committee meetings, and throughout the year, the
chairs of the committees stayed in regular contact
with the respective members of the Executive Board
and Management Board and other experts to discuss
various topics.
Audit Committee
The Audit Committee assists the Supervisory Board
in the performance of its duties. To this end, the
Audit Committee prepares items for discussion and
decision-making by the Supervisory Board, and
recommends actions in various areas, including
(i) the design, operation and effectiveness of the
internal risk management and control systems
related to financial and sustainability reporting,
(ii) the integrity and quality of the financial and
sustainability reporting process, (iii) periodic financial
reports and any ad-hoc financial information, (iv) the
findings and outcomes of any audit work, by both
the external auditor (KPMG) and CAS, NN Group’s
internal audit department (e.g. as contained in the
quarterly and annual audit reports), including the
findings and observations on the key audit matters
identified by the external auditor, and (v) the
procedure for the selection and recommendation of
the (re)appointment of the external auditor by the
Supervisory Board.
The Audit Committee works closely with the
Risk Committee, not only to avoid omissions and
duplication in its activities, but also to provide holistic
insight into the risks in the reporting of financial
and non-financial results. The chair of the Audit
Committee is therefore also a member of the Risk
Committee, and vice versa. In 2024, the chair of the
Audit Committee regularly met with the CFO, Head
of CAS, subject-matter experts and KPMG to discuss
various topical issues.
In addition to the regular Audit Committee meetings,
the Audit Committee also held closed sessions
attended by the Audit Committee members, Head of
CAS and KPMG.
The topics discussed and assessed during the Audit
Committee meetings included:
• NN Group’s quarterly performance reviews,
including financial results;
• Financial reporting: NN Group’s annual accounts,
interim financial information and financial press
releases;
• The implementation of CSRD at NN Group;
• The 2024 Audit Plans of CAS and KPMG;
• Audit findings and observations as included in the
quarterly internal and external reports of CAS and
KPMG;
• The rotation process towards appointment of a
new external auditor for NN Group as of financial
year 2026;
• Accounting and other regulatory developments;
• IFRS and Solvency II reporting, including a second
line review opinion on the Own Funds and the
SCR; internal controls on financial reporting and
changes in financial reporting processes and
systems;
• Tax-related topics: the current tax positions
and (legislative) developments impacting the
tax function such as Pillar II; NN Group’s tax
strategy; Tax Policy and Principles of Conduct;
developments in the area of public tax reporting;
• Various other topics: (interim) dividend payment to
shareholders and the share buyback programme;
appointment and remuneration of the new Head of
CAS; evaluation, independence and remuneration
of KPMG; an evaluation of the IFRS 9 and 17
implementation.
The quarterly performance review reports provided
updates on business performance and financial
results, both at NN Group level and at the level of
the various business segments. In addition, these
reports further provided the Audit Committee with
meaningful insights into, among other things,
NN Group’s OCG and expectations, the status of the
financial targets, and expected financial outlooks
and attention points going forward for NN Group
and its business segments. Throughout the year,
the Audit Committee closely monitored NN Group’s
performance and financial results in light of the
changing regulatory landscape, major geopolitical
developments and resulting impact on the macro-
economic environment.
As per 1 June 2024, a new Head of CAS was
appointed, approved by the Dutch Central Bank. The
Executive Board consulted the Audit Committee on
the proposed candidate and the Audit Committee
informed the Executive Board of its support for the
proposed appointment. The Audit Committee was
also consulted about the proposed remuneration
package of the new Head of CAS, and advised
positively in this regard.
The Audit Committee discussed the 2024 audit
plan of CAS. The main drivers behind the CAS audit
priorities for 2024 were (i) coverage needs, (ii)
strategic importance and key change initiatives, and
(iii) ongoing key remediations. The quarterly CAS
reports include findings and observations regarding
governance, risk management and internal control,
focusing on performed activities during the period,
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Report of the Supervisory Board
significant internal control weaknesses noted in
ongoing audit activities, and follow-up by responsible
management on agreed actions of noted CAS
weaknesses. The Audit Committee discussed and
monitored the follow-up on financial reporting risks
throughout the year. As of August 2024, the quarterly
CAS reports were added to the agenda of the Risk
Committee, while also remaining a quarterly agenda
topic of the Audit Committee. The chair of the Audit
Committee, chair of the Risk Committee and the Head
of CAS agreed that, as of August 2024, the Audit
Committee would discuss findings and observations
resulting from the CAS reports pertaining to CAS
internal matters and financial reporting risks. As of
the same date, all other findings and observations
resulting from the CAS reports were discussed in the
Risk Committee, to ensure an integral discussion of
operational and financial risks in the Risk Committee.
Both the Audit Committee and the Risk Committee
highly appreciated the change in set-up and will
continue this approach going forward.
The Audit Committee further discussed the 2024
KPMG audit plan, including their assessment of
the risk of error and fraud. KPMG’s areas of focus
in 2024 included (i) valuation of insurance contract
liabilities for life and disability insurance contracts,
(ii) valuation of the liability for incurred claims for
non-life insurance contracts, (iii) valuation of illiquid
investments, and (iv) risk of management override of
controls.
KPMG reports its findings and observations on NN
Group’s internal controls over financial reporting
in each quarterly KPMG report, and as part of its
year-end Audit Report, and as a consequence KPMG
no longer issues a separate management letter at
year-end. The quarterly reported key findings and
observations and those included in the year-end
Audit Report were discussed in the Audit Committee.
Examples of topics discussed are the valuation of
the insurance liabilities and illiquid investments,
the unit-linked settlement, and the CSRD and DORA
implementation status.
In 2024, the Audit Committee discussed the CSRD
implementation on a quarterly basis. The DMA, as
mandated by the CSRD, has been an annual agenda
item for the Executive Board and Management Board
since 2023. They deliberated on which sustainability
matters are material to NN Group from both impact
and financial materiality perspectives, considering
potential and actual impacts, risks and opportunities
(IROs). Midway through 2024, the Audit Committee
reviewed the outcomes of the DMA, including the
material sustainability topics and IROs for the
year for NN Group as a whole, which were climate
change adaptation, climate change mitigation and
customer needs and satisfaction. The chair of the
Audit Committee reported on these discussions at
the subsequent Supervisory Board meeting, which
resulted in the final list of sustainability matters.
In light of the mandatory rotation of the external
auditor as of the financial year 2026, NN Group
initiated a process to select a new external auditor.
For this purpose, an Auditor Selection Committee
(ASC) was established, chaired by the chair of the
Supervisory Board and including the chair of the
Audit Committee, the CFO and the Head of Financial
Accounting & Reporting. The ASC conducted a
thorough process whereby candidate audit firms
were evaluated on a broad number of criteria,
including experience with large listed companies in
the Netherlands, experience in the financial services
industry (particularly insurance), the proposed audit
plan and approach, knowledge and experience, lead
partner and lead audit team, quality of the local
international teams and international experience of
the lead partner, the (level and structure of) audit
fees and auditor independence and reputation. The
ASC reported on the outcome of their meetings in
four Audit Committee meetings in 2024 and the Audit
Committee provided their feedback and views. The
final decision on the proposal to the General Meeting
was taken by the full Supervisory Board in February
2025, where Mr Lelieveld and Ms Van der Meer Mohr
refrained from voting to avoid any appearance of
conflict of interest, given their roles in the past in
one of the two candidate firms. For further details on
the auditor selection process, evaluation and final
conclusions, please refer to the convocation for the
2025 AGM.
Risk Committee
The Risk Committee assists the Supervisory Board
in performing its duties. To this end, it prepares
items for discussion and decision-making by the
Supervisory Board, and recommends actions in
various areas, including (i) NN Group’s key risks
and risk appetite statements, risk strategy and
policies, (ii) risk exposures resulting from the
business strategies and plans of NN Group and its
affiliated businesses, (iii) the design, operation and
effectiveness of the risk management and internal
control systems of NN Group (the Risk Control
Framework), (iv) NN Group’s public disclosures
on risk and risk management, and (v) Material
Transactions.
The Risk Committee works closely with the Audit
Committee, not only in order to avoid omissions
and duplication in activities but also to give insights
into the risks in the reporting of financial and non-
financial results. The chair of the Risk Committee is
therefore also a member of the Audit Committee, and
vice versa. In 2024, the chair of the Risk Committee
regularly liaised with the CRO, Head of CAS, CCO and
GC, and met with the external auditor and relevant
subject-matter experts.
During the Risk Committee meetings, management
provided regular updates on strategic, financial and
non-financial risks, including legal and compliance
risks. These updates encompassed a range of
topics, including solvency, liquidity, credit and
capital markets, sustainability, IT, data and AI,
funding, sound business conduct including financial
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economic crime, product suitability, operational
risks and employee conduct. The discussions in the
Risk Committee were supported by analyses that
evaluated the potential impact of these events on
NN Group’s credit investment portfolio, capital and
liquidity position, and credit developments in specific
countries and portfolios.
During the year, the Risk Committee discussed its
regular agenda topics, including:
• The performance and appropriateness of NN
Group’s PIM;
• The Enterprise Risk Management (ERM) reports
covering strategic, financial and non-financial risks
(including legal and compliance risks);
• Financial economic crime updates;
• The risk appetite statements which are
foundational to the Group’s risk strategy;
• NN Group’s Own risk and solvency assessment
(ORSA);
• The NN Group Systematic Integrity Risk
Assessment (NN Group SIRA);
• The quarterly reports on IT risk and security, as of
May 2024;
• The quarterly CAS reports (pertaining to
operational risks), as of August 2024;
• NN Group’s Strategic Asset Allocation (SAA) and
investment-related risks;
• Annual operational work plans of Group Risk,
Actuarial and Compliance functions.
The quarterly ERM reports provided updates,
including measures taken and planned, on the
current and forward-looking risks emanating from
uncertainty in the operating environment. This
uncertainty was driven by geopolitical instability,
characterised by more volatile financial markets,
more persistent inflation, higher levels of interest
rates and risk of recession (especially in Europe).
As of May 2024, the Risk Committee also discussed
the IT Risk and Security report, providing a more
comprehensive risk view and integrating IT risk
into the quarterly ERM report discussions. The Risk
Committee considered it a positive development to
link these key risks.
As also mentioned in the Audit Committee paragraph,
the quarterly CAS reports were newly added to the
agenda of the Risk Committee as of August 2024,
while also remaining a quarterly agenda topic of the
Audit Committee.
Each year, the PIM’s performance is assessed in the
first quarter. This covers all relevant information from
the preceding calendar year, including all risk models
that are part of NN Group’s PIM used to calculate the
Basic Solvency Capital Requirement (SCR). The Risk
Committee extensively discussed the outcome of
this assessment, which for example also takes into
account results from stress testing in the ORSA and
includes the key priorities for the year going forward.
The Risk Committee agreed with the main conclusion
of the 2023 report on the PIM’s performance that,
given the assumptions used and understanding of
their implications, the internal model is appropriate
for its intended use.
The Risk Committee was pleased with the broad
scope of the scenarios that were included in
the 2023 ORSA. Although the Risk Committee
considered it reasonable to assume that liquidity
shocks occur gradually over a one-year period rather
than overnight, the Risk Committee considered that
severe interest rate spikes and resulting liquidity
requirements can still happen in a short period of
time. The Risk Committee therefore suggested that
the Management Board look at more longer-term
fundamental liquidity impacts going forward, which
the Management Board will take into account for the
2024 ORSA.
The Risk Committee also regularly discussed the
MMCs submitted by the relevant business units, as
well as the approvals granted by the Dutch Central
Bank (DNB) and terms and conditions attached to
them. In 2024, NN Group submitted to DNB for
approval major model changes to its PIM, for example
relating to (the redevelopment of) non-market risk
aggregation, which proposed model change was
approved by DNB and implemented in time for the
2024 year-end SCR calculation.
Nomination, Remuneration & Governance
Committee
The Nomination, Remuneration & Governance
Committee is entrusted with the preparation of
its mandated nomination-, remuneration- and
goverance-related matters. The Nomination,
Remuneration & Governance Committee prepares the
Supervisory Board’s decision-making on such topics
and reports on its deliberations and findings in regard
to these duties. All relevant topics are included in the
committee’s annual agenda as recurring items and
during the year the chair of the committee engages in
dialogue with stakeholders to ensure their interest is
considered.
The Nomination, Remuneration & Governance
Committee is in charge of preparing topics regarding
the composition of the boards, ensuring the formal
and transparent selection and (re)appointment
procedures of the members of the Executive Board,
Management Board and Supervisory Board are in
place, and it reviews the board profiles as part of the
annual review of the respective charters. In 2024,
the charters of the Supervisory Board, Executive
Board and Management Board were aligned with the
CSRD and DORA and there was no need to amend
the profiles. In addition, where the Supervisory
Board as a whole is committed to the succession
plans for staff below board level, the Nomination,
Remuneration & Governance Committee focuses on
sound succession plans for the boards themselves,
with a particular emphasis on diversity aspects.
To this end, it also annually prepares a retirement
schedule for the Supervisory Board members, which
indicated that for the Supervisory Board members
Inga Beale, Rob Lelieveld and Cecilia Reyes the four
years of their appointment will end in 2025. The
Nomination, Remuneration & Governance Committee
prepared the decision of the Supervisory Board to
nominate each of them for reappointment for a term
of four years, which will be submitted for adoption at
the 2025 AGM. Likewise, it prepared the appointment
of Koos Timmermans as Supervisory Board member
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last year, as well as the reappointment of Robert
Jenkins by the AGM in 2024. Reasons given for
this reappointment were his extensive knowledge
in the field of financial policy making and asset
management, his broad experience as board member
in executive and non-executive positions in the
financial services sector, the professional manner in
which he fulfils his membership of the Supervisory
Board and that with his reappointment continuity in
the composition of the Supervisory Board could be
safeguarded.
The Nomination, Remuneration & Governance
Committee also takes responsibility for developing
the approach for the annually performed evaluation
of the Executive Board and Management Board, and
the self-assessment of the Supervisory Board. It also
reviews the external positions of all board members
to ensure that each member can devote sufficient
time to its tasks and repsonsiblities and avoid
conflicts of interest.
With respect to remuneration topics, the Nomination,
Remuneration & Governance Committee advised
the Supervisory Board on the formulated objectives
for the Executive and Management Board members
for 2024, which are a translation of NN’s targets.
In this context, the committee also evaluated the
members’ performance against the 2023 objectives
and the corresponding remuneration proposals for
the respective board members. In February 2025,
it also reviewed and endorsed the remuneration
proposals for the Executive and Management Board
for 2024. The remuneration policies for the Executive
Board and Supervisory Board were also assessed
in the first quarter of 2024, as these policies were
due for renewal. The policies were adopted by the
shareholders at the AGM in 2024. In addition, the
committee assessed the remuneration proposals
for identified staff, including high earners, as well
as positively recommended on the proposal for
positions on the identified staff list for the year
2025. It also reviewed and agreed on NN Group’s
remuneration framework, which forms the basis
for all remuneration policies and which remained
unchanged, as well as the extensive risk assessment
performed on this framework. It was concluded
that the remuneration framework operates within
the limits as defined in NN Group’s risk appetite.
Furthermore, the committee reviewed and discussed
NN Group’s equal pay analysis and fully supported
the commitment to ensure fair and equitable pay
across the organisation.
In February 2025, the Nomination, Remuneration &
Governance Committee reviewed and discussed NN
Group’s application of and compliance with the Dutch
Corporate Governance Code for the financial year
2024.
Closing remarks
The Supervisory Board extends its heartfelt gratitude
to everyone who contributed to NN’s performance
throughout the year. Their dedication, hard work and
commitment have been instrumental in achieving
collective goals. The efforts of the Executive Board,
Management Board and all staff members have been
invaluable in navigating the complexities of the the
world and industry and striving towards excellence.
The Supervisory Board appreciates the support from
all stakeholders, whose engagement has ensured
that initiatives are aligned with broader interests. The
Supervisory Board looks forward to continuing this
journey of success and innovation.
Attendance
As of the close of the AGM on 24 May 2024:
• Hans Schoen’s term of appointment as
Supervisory Board member ended;
• Koos Timmermans was appointed as Supervisory
Board member, and member of the Risk
Committee and Audit Committee;
• David Cole stepped down as member of the Audit
Committee and was granted a standing invitation;
• Pauline van der Meer Mohr stepped down as
member of the Risk Committee to join as member
of the Audit Committee.
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Report of the Supervisory Board
Composition and attendance overview Inga Beale David Cole Robert Jenkins Rob Lelieveld
Pauline van der
Meer Mohr Cecilia Reyes Hans Schoen
Koos
Timmermans
Overall
attendance
average
Supervisory Board 7/7 7/7 7/7 7/7 7/7 7/7 4/4 2/3 98%
Audit Committee – 3/3 5/5 5/5 2/2 5/5 3/3 2/2 100%
Risk Committee 6/6 – 6/6 6/6 3/4 6/6 2/2 96.7%
Nomination, Remuneration & Governance Committee 5/5 5/5 – 5/5 5/5 – 3/3 – 100%
Diversity and Skills matrix Inga Beale David Cole Robert Jenkins Rob Lelieveld
Pauline van der
Meer Mohr Cecilia Reyes
Koos
Timmermans
Year of birth 1963 1961 1951 1962 1960 1959 1960
Gender:
Male (M) or Female (F) F M M M F F M
Nationality British
American,
Dutch American Dutch Dutch
Filipino,
Swiss Dutch
Management of complex multinational enterprises
International economic, regulatory and public policy issues
Labour relations, human resources and management development
Insurance
Asset management
Retail banking
Audit, finance and control¹
Risk management
Legal affairs and corporate governance
Corporate integrity
Information technology and transformation
Marketing, in particular in the area of financial products and services
Sustainability matters
1
Financial expert as defined in article 39 (1) of Directive 2014/56/EU of the European Parliament and of the Council of
16 April 2014 amending Directive 2006/43/EC on statutory audits of annual accounts and consolidated accounts.
All members of the Supervisory Board are independent, as defined in the Dutch Corporate
Governance Code.
Considered an expert given previous and/or current roles (other than non-executive roles).
Sufficient experience and knowledge to be able to take an informed decision.
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Remuneration Report
How do you look back on the year 2024?
Reflecting on 2024, I am happy to note that NN
Group remains well on track to deliver on its targets,
driven by a continued solid financial and strategic
performance in 2024. In a year in which the global
economy is still facing ongoing challenges, NN Group
has demonstrated strong business performance
despite these challenges. The Nomination,
Remuneration and Governance (NRG) Committee
has carefully considered these factors, ensuring our
compensation decisions are in line with the company
performance, the broader economic landscape and
current labour market conditions.
We were pleased with the General Meeting’s positive
advice on the 2023 Remuneration Report at the
2024 annual general meeting of shareholders. The
proposal was adopted with 97.3% of the votes
granted in favour, once again slightly above the
previous years’ support level.
The remuneration policies for the members of the
Executive Board and the Supervisory Board were
submitted for adoption to the General Meeting
as well. At the 2024 annual general meeting the
remuneration policies were adopted with 94.5% of
votes in favour for the proposed remuneration policy
for the members of the Executive Board and 99.5% of
votes in favour for the proposed remuneration policy
for the members of the Supervisory Board.
During 2024, the Supervisory Board also
performed an assessment of the Executive Board’s
remuneration, taking into account, among other
things, the position compared to the market, internal
pay relativities and the interests and opinions of
stakeholders. Based on the outcome of the overall
assessment, and balancing the interests of all
stakeholders, it was decided to increase the base
salary of the members of the Executive Board.
The external feedback provided on these topics is
highly valued, and stakeholders have indicated they
appreciate the background of our remuneration-
related decisions. More information is provided in the
Remuneration Report.
Both the remuneration policies and the decision
related to the increase of the base salary of the
members of the Executive Board were established
after a comprehensive engagement process with our
stakeholders. The feedback we received during this
engagement process, as well as the approval rates
during the 2024 annual general meeting, illustrate
we are on the right track.
Pauline van der Meer Mohr, Chair of the
Nomination, Remuneration and Governance
Committee:
Stakeholders
appreciate our focus
on aligning executive
remuneration with
the broader strategy
of NN Group.
A conversation with the NRG Chair
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You have had several conversations with
stakeholders of NN Group. What are your most
important insights?
After the update of the remuneration policies and
related compensation decisions, the Supervisory
Board remains committed to continuing the
consultation sessions with a diverse group of
stakeholders on a recurring basis, to gather
feedback on our remuneration policies and practices.
Feedback was obtained from investors, shareholder
representatives, proxy advisors and our Central
Works Council. In general, we feel that the path that
we have chosen was received positively and any
feedback was discussed in a constructive manner.
These sessions took place throughout 2024 and
the discussions provided valuable insights and
highlighted several key areas.
Stakeholders appreciated our focus on aligning
executive remuneration with the broader strategy
of NN Group. The emphasis on having performance
objectives for the Executive Board that have more
focus, are simpler and more measurable was well-
received. At the same time, our ambition is to retain
the strong elements from our previous framework.
We frequently discussed sustainability matters,
as these were high on the agenda for both the
Supervisory Board and many stakeholders.
There are several legislative changes in
remuneration entering into force in the future.
What is your take on the current developments?
First of all, I fully support the objective of the
European Pay Transparency Directive. The NRG
Committee stands behind NN Group’s efforts to
performance objectives with the longer-term targets
and ambition of the company.
As chair of the NRG Committee, it is my privilege
to present NN Group’s 2024 Remuneration Report.
I extend my gratitude to all stakeholders for their
valuable contributions and look forward to continuing
our constructive dialogues in the coming year.
Pauline van der Meer Mohr
Chair of the Nomination, Remuneration and
Governance Committee
contribute to an inclusive working environment by
ensuring equal opportunities, working conditions and
equal pay for equal work for all employees.
NN Group’s start with the implementation of the
Pay Transparency Directive and ongoing analyses
to understand and address any (unexplained)
differences were positively noted by the Supervisory
Board. NN Group has published the gender pay gap
for many years, and analyses the gap internally on
an annual basis. However, the Pay Transparency
Directive will require additional actions from all
companies.
Needless to say, the implementation of the Pay
Transparency Directive will remain high on the
agenda for the Supervisory Board in the coming years
to ensure that appropriate actions are taken and
equal work is remunerated equally.
The NRG Committee is also closely involved in the
remuneration-related disclosures as prescribed by
the European Sustainability Reporting Standards.
The 2024 Remuneration Report includes several
additional disclosures in comparison with previous
years.
What would you like to share on the year 2025?
The Supervisory Board has decided to maintain the
alignment between the performance objectives for
the members of the Executive Board and the overall
company strategy when determining the performance
objectives in 2025. There are no substantial changes
in the characteristics of the objectives in comparison
with previous years, which means we align the
EUR 3,051
EUR 2,032
CEO CFO
CEO CEO CEO CEO
CFO CFO CFO CFO
20% 15% 40%15%
35% 15% 25%15%
CEO
CFO
10%
10%
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Remuneration at a glance
Engaged customers Talented people Contribution to society Financial strength
Digital & data-driven
organisation
Our purpose
We help people care for what matters most to them
Our ambition
We want to be an industry leader, known for our customer engagement,
talented people, and contribution to society
Composition of the Executive
Board’s remuneration
(in EUR 1,000 and gross)
Our
commitments
Target
Weighting
We see our customers as the
starting point of everything
We empower our colleagues
to be their best
We contribute to the well-being of
people and the planet
We develop and provide attractive
products and services
CEO % CFO %
Base salary in cash 53 54
Base salary in shares 13 14
Variable remuneration in cash 6 7
Variable remuneration in shares 6 7
Pension 1 1
Other emoluments 4 1
Individual savings allowance 15 14
Employer cost social security 2 2
Target 2024 Outcome: Sustainability Finance Other strategic
We are financially strong and seek
long-term returns for shareholders
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Introduction
This Remuneration Report describes NN Group’s
remuneration policy and methodology, and provides
details on the remuneration of the Supervisory Board
and the Executive Board. This Report is divided into
the following subsections:
I Remuneration in general
II Remuneration of the Executive Board
III Remuneration of the Supervisory Board
Reference is made to Note 45 ‘Key management
personnel compensation’ in the Consolidated annual
accounts for more information on the remuneration
of the Executive Board, Management Board and
Supervisory Board, including loans and advances
provided to the members of these Boards. This
Remuneration Report serves as the report referred
to in article 2:135b of the Dutch Civil Code and Best
Practice Provision 3.4.1 of the Dutch Corporate
Governance Code. The information provided in this
Remuneration Report is based on the remuneration
policies of NN Group as applicable in 2024.
Remuneration in general
NN Group has an overall remuneration policy, as
described in the NN Group Remuneration Framework,
which sets out guidelines and principles for all
country and business unit remuneration policies
within NN Group. On an annual basis, the NN Group
Remuneration Framework is reviewed and updated
in line with legislative changes and other relevant
internal and external developments. NN Group aims
to apply a clear and transparent remuneration policy
that is adequate to attract and retain expert leaders,
senior staff and other highly-qualified employees.
The NNGroup strategy sets out our goals and how
we will achieve them through our shared purpose,
our ambition and our five strategic commitments.
These strategic commitments are embedded in
the remuneration policies within NN Group. The
remuneration policy is also designed to support
NN Group’s employees to act with integrity and to
carefully balance the interests of our stakeholders. It
supports doing business with the future in mind, and
aims to focus on creating sustainable long-term value
for all stakeholders.
At the same time, NN Group is conscious of its role
in society, which is considered and embedded in the
remuneration policies and practices as applicable to
NN Group employees. These policies promote robust,
balanced and effective risk management, including
risk management of sustainability risks - risks
related to environmental, social, and governance
(ESG) factors, and the integration thereof in the
risk management system and procedures. This is
supported by, among other things, performance
objective setting processes.
NN is committed to providing market-competitive
rewards through this clear and transparent
remuneration framework. This framework is built on
several key elements, including a total compensation
approach that aligns pay with relevant local market
conditions and considers the competencies and
experience required for each role. Differentations are
based on business needs and individual performance.
The remuneration system is designed to attract,
hire, and retain talent while ensuring consistency
with NN’s strategic positioning and development
goals, reflecting the company’s values and its role
in society. This focus on competitive pay supports
financial stability for employees, which is essential
for long-term job satisfaction and retention. Based
on our annual assessment of the hourly wage
per individual, it is concluded that all NN Group
employees are paid an adequate wage in 2024. For
this assessment, the compensation per individual
based on a full-time equivalent is compared to
60% of the median income per country, aligning
with the disclosure requirements in the European
Sustainability Reporting Standards and using data
available from Eurostat to the extent possible.
NN Group’s remuneration policy for executives
and senior staff is based on a total compensation
approach, and is benchmarked on a regular basis
with relevant national and international peers, both
within and outside the financial sector. Clear financial
and strategic performance objectives are set which
are aligned with the overall strategy of NN Group,
both in the short term and the long term, to ensure
that remuneration is properly linked to individual,
team and NN Group performance. The remuneration
policy supports a focus on the company’s long-term
interests and the interests of our customers and
various stakeholders by ensuring that, by linking
remuneration to the company’s long-term objectives,
staff are not encouraged via remuneration to take
excessive risk. In addition, the remuneration policy
ensures that NNGroup complies with all the relevant
(inter)national regulations on remuneration as
relevant to our business, such as the Act on Further
Remuneration Measures for Financial Undertakings
(Wet nadere beloningsmaatregelen financiële
ondernemingen) that entered into force on1 January
2023.
Gender and equal pay
Gender equality contributes to an inclusive working
environment by ensuring equal opportunities,
working conditions and equal pay for equal work.
NN Group constantly strives to promote and achieve
equal pay for equal work, or work of equal value,
for all employees, as this is a key component of
supporting equal opportunities for all genders.
To this end, NN Group has implemented remuneration
policies that do not differentiate on gender. This
means that, in principle, all aspects of NN Group’s
remuneration policies and processes are aimed at
being gender inclusive, such as the determination of
salary levels for our employees and the process in
relation to setting the award and pay-out levels for
variable remuneration.
NN Group’s pay is analysed annually with a focus on
gender equality. Our gender pay gap analyses show
that there is an overrepresentation of women in lower
pay grades, and an underrepresentation in higher pay
grades. This leads to a gender pay gap but does not
mean that our employees do not receive equal pay for
equal work. In general, men and women performing
similar jobs, with similar experience and age, receive
fair and equal pay.
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To further accelerate the process of closing the
gender pay gap, we are working on our talent
management, succession planning and diversity
and inclusion initiatives. We are closely monitoring
compensation packages for new hires and recently
promoted women, ensuring a balanced pay structure
for all NN colleagues.
Gender pay gap
2024 2023
Gender pay gap (%) 29% 28%
The gender pay gap is determined by dividing the
difference between the average gross hourly pay
level of male and female employees by the average
gross hourly pay level of male employees. In 2024,
more subsidiaries were included in the annual
analysis to comply with the reporting requirement as
prescribed by the European Sustainability Reporting
Standards. The developments in the composition of
the workforce and entities included in the analysis are
influencing the outcomes of the gender pay analysis.
Our work on achieving greater equity and becoming
an even more inclusive and fair workplace is not
done yet. We will therefore continue with conducting
annual analyses of our gender pay gap and equal pay
for equal work as part of our commitment to promote
equal pay for work of equal value. Together, we will
continue on our path of building and fostering a
diverse, inclusive, healthy and safe workplace for all
colleagues.
With respect to performance year 2024, the total
number of staff of NN Group eligible for variable
remuneration is 5,803. The total approved variable
remuneration budget is EUR 38.6 million, which
will be paid in March or April 2025. In 2024, 9
persons employed within NN Group received a total
remuneration of more than EUR 1 million. For this
calculation, the individual base salary, awarded
variable remuneration and, where applicable,
life course savings schemes, individual saving
allowances, severance payments and pension
contributions were included.
Remuneration of the
Executive Board
The members of the Executive Board have a
commission contract (in Dutch: overeenkomst van
opdracht) with NN Group N.V. David Knibbe was
appointed to the Executive Board and designated as
Chief Executive Officer (CEO) of NN Group and as a
result chair of the Executive Board effective 1 October
2019. After notification to the General Meeting of
NN Group at the AGM on 2 June 2023, David Knibbe
was reappointed as member of the Executive Board
and again designated as CEO of NN Group and as a
result chair of the Executive Board for a term of four
years, which term will end at the close of the 2027
AGM.
Annemiek van Melick was appointed member
of the Executive Board and designated as Chief
Financial Officer (CFO) and as a result vice-chair of
the Executive Board effective 1July 2022. Her term
of appointment will end at the close of the AGM of
NN Group in 2026.
Members of the Executive Board can be reappointed
by the Supervisory Board for consecutive periods
of up to four years after notification to the General
Meeting of NN Group.
The remuneration policy for the members of the
Executive Board was adopted by the General Meeting
on 24 May 2024, effective as from 1 January
2024. The data presented in this report relate
to remuneration awarded to the members of the
Executive Board in respect of the whole of 2024. The
2024 total remuneration as provided to the members
of the Executive Board is in line with the applicable
remuneration policy. The Supervisory Board has
not applied any deviation from the procedure for
the implementation of the remuneration policy or
derogation from the remuneration policy for the
members of the Executive Board.
The remuneration policy for the members of the
Executive Board is required to be submitted for
adoption by the General Meeting at least every four
years.
The remuneration of the members of the
Executive Board consists of a combination of
fixed remuneration (‘base salary’; of which 80% is
paid in cash and 20% in shares) and base-salary-
related allowances, variable remuneration (of which
50% is paid in cash and 50% in shares), pension
arrangements and other emoluments as described
below. To support the sustainable long-term value
creation, a retention period of five years starting from
the date of award is applicable to all share awards.
The detailed composition of the Executive Board
remuneration is illustrated below.
Composition EB remuneration
Remuneration elements Portion Split Awarded Retention period
Base salary in cash 80%
Base salary in shares 20% 5 years
Total base salary 100%
Variable remuneration Min 0%
Target 16%
Max 20%
50% in cash 60% deferred
40% upfront
50% in shares 60% deferred 5 years
40% upfront 5 years
Total direct remuneration Min 100%
Target 116%
Max 120%
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Award
moment
Vesting
year 1
Vesting
year 2
Vesting
year 3
Vesting
year 4
Vesting
year 5
Deferral period Retention period
SplitRemuneration Awarded Performance year
Variable
remuneration
Base salary
50%
shares
50%
cash
80%
cash
20% upfront
shares
60%
deferred
shares
60%
deferred
cash
40%
upfront
shares
40%
upfront
cash
Remuneration of the Executive Board
The total compensation of the members of the
Executive Board is benchmarked on a regular basis
against market data that includes peers both inside
and outside the financial sector in the Netherlands
and abroad. Based on a fundamental review of the
peer group approach, the Supervisory Board decided
in 2024 that this approach is still future-proof and fit
for purpose. The peers are selected with reference
to asset base, market capitalisation, revenue and
number of employees. In 2024, the peer group has
been validated and consisted of ABN AMRO Bank,
Achmea, Ageas, Akzo Nobel, a.s.r., Aviva, Hannover
Rueck Se, Koninklijke Philips, Legal & General Group,
Munich Re, Rabobank, Randstad, Swiss Life Holding,
Talanx and Wolters Kluwer.
In line with the remuneration policy for the members
of the Executive Board, the Supervisory Board
aims to set the remuneration levels below market
median. If, based on the annual benchmark, the
remuneration level is not in line with the approved
policy, appropriate measures will be considered.
The Supervisory Board also takes into account all
stakeholders’ interests, including social context and
the results of scenario analyses, before finalising
executive pay levels.
Only in the event of an involuntary exit (e.g. a mutual
agreement at NN Group’s initiative where the
member of the Executive Board has been requested
to leave), Executive Board members are eligible to an
exit arrangement limited to a maximum of one year
base salary. Exit arrangements will in no way qualify
as reward for failure (within the meaning of the
applicable regulatory requirements).
Executive Board base salary
The Executive Board base salary is based on the
remuneration policy for the Executive Board,
which aims at retaining highly qualified leaders
and positioning the Executive Board total direct
compensation (i.e. the total of the base salary
and variable remuneration) below the market
median. Aligned with this remuneration policy, the
Supervisory Board evaluates the remuneration of
the members of the Executive Board each year in
comparison with the remuneration at NN Group’s
peer companies. The Supervisory Board also consults
external experts to provide relevant benchmark
insights.
In 2024, the Supervisory Board performed an
assessment of the Executive Board’s remuneration,
taking into account the result of the benchmark
analyses as performed by an independent advisor as
well as the internal pay relativities and the interests
and opinions of stakeholders. Input was obtained
from various stakeholders and consideration has
been given to relevant remuneration developments in
and outside NN Group.
When assessing the individual and company
performance, the Supervisory Board concluded
that the members of the Executive Board have
consistently shown strong leadership. NN has
shown good progress in implementing its strategy
and achieving strong commercial and financial
performance under the leadership of the Executive
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Board. This has laid a strong foundation for long-
term growth and sustainable value creation for all
stakeholders.
After a balanced and thorough assessment, the
Supervisory Board has decided to increase the base
salary of the members of the Executive Board with
9%, with effect from 1 June 2024. The new base
salaries amount to EUR 2,108,878 gross for David
Knibbe and EUR 1,428,990 gross for Annemiek van
Melick.
The increased remuneration packages continue
to be positioned well below the market median
and continue to be in line with the requirements
resulting from the Executive Board Remuneration
Policy. During the decision-making process, a
scenario analysis has been performed and taken into
consideration by the Supervisory Board.
Executive Board variable remuneration
The remuneration policy for the members of the
Executive Board combines the short- and long-
term variable components into one structure. This
structure supports both sustainable long-term
value creation and short-term company objectives.
Performance objectives reflect NN Group’s medium-
term strategic priorities as communicated to the
market, and as such contribute to the long-term
strategy of NN Group. Variable remuneration is based
on both the financial and strategic performance of the
individual and the company. The Supervisory Board
annually determines the performance objectives at
the start of the performance year and defines the
relevant ‘at target’ level. Following the performance
year, the Supervisory Board determines the extent to
which the financial performance objectives are met
based on the full-year financial results. The extent
to which strategic performance objectives are met is
also assessed by the Supervisory Board.
The emphasis on long-term performance within the
variable component of the compensation package
is realised by means of deferral of 60% of the total
variable remuneration. Furthermore, an annual
re-evaluation by the Supervisory Board takes place
with the option to hold back (i.e. prevent from
ever vesting) and/or claw back vested and paid
variable remuneration. The Supervisory Board has
the authority to reclaim any variable remuneration
allocated to a member of the Executive Board based
on inaccurate data and/or behaviour that led to
significant harm to the company. In addition, the
Supervisory Board has the authority to adjust variable
remuneration in the event that the application of the
predetermined performance criteria would result in
an undesired outcome.
The maximum variable remuneration of the members
of the Executive Board for performance year 2015
onwards has been capped at 20% of the base
salary and the on-target level of the annual variable
remuneration has been set at 16% of the base salary.
This is in line with the requirements of the Dutch
regulatory regime as applicable to NN Group.
Additionally, the short-term component of variable
remuneration (the so-called ‘Upfront Portion’) is
40% of the total variable remuneration and is equally
divided between an award in cash and an award in
stock. The deferred portion is also equally divided
between an award in deferred cash and an award
in deferred stock. Both the deferred cash and the
deferred stock awards are subject to a tiered vesting
on the first, second and third anniversary of the
grant date (one-third per annum). Similar to the
shares awarded as fixed remuneration, a retention
period of five years starting from the date of award
is applicable to all stock awards (both upfront and
deferred), with the exception that part of the stock
will be withheld at the relevant date of vesting to
cover any income tax liability arising from the vested
share award (withhold-to-cover). In addition to the
general principles described above, more specific
details on the 2024 variable remuneration of the
members of the Executive Board are provided below.
Performance for the year 2024 was assessed
based on a number of objectives, as outlined in
the following pages. Estimated risks and capital
adequacy were also taken into account when
determining the award of variable remuneration.
Performance objectives of the members of
the Executive Board
The performance of the members of the Executive
Board is assessed annually against their financial
and strategic objectives as set by the Supervisory
Board. When determining the objectives for a specific
performance year, the Supervisory Board takes
into account the medium-term financial, as well as
strategic company targets which contribute to the
long-term strategy of NN Group. When determining
the relative weighting between the financial and
strategic performance objectives, the Supervisory
Board takes into account the requirements of the
Dutch regulatory regime as applicable to NN Group
and the Executive Board remuneration policy. At
the end of the year, the Supervisory Board executes
a performance assessment to determine to what
extent the objectives have been met. The Supervisory
Board is supported by various departments, such
as Finance, Sustainability & Social Impact, Business
Strategy, Compliance, Corporate Relations, Risk and
HR, to provide relevant input.
The ambition of our company describes what we want
to achieve in the years to come. We want to be an
industry leader, known for our customer engagement,
talented people, and contribution to society. All
our different business entities are expected to
contribute to the delivery of our ambition. To realise
this ambition, five strategic commitments have been
identified and the performance objectives of the
members of the Executive Board were structured
around these commitments. The financial and
strategic performance objectives of the members of
the Executive Board over the year 2025, as set by
the Supervisory Board in January 2025, remain to be
aligned with the strategic framework.
Targets related to the reduction of GHG emissions
are recognised in the Society commitment.
Over performance year 2024, two out of three
performance objectives in the Contribution to
society commitment are linked to climate-related
considerations. The performance of the members
of the Executive Board and Management Board in
relation to the Society commitment are reflected for
15% in the total annual variable remuneration target
level.
We are financially strong and seek
long-term returns for shareholders
CEO CEO CEO CEO CEO
CFO CFO CFO CFO CFO
20% 15% 10%40%15%
35% 15% 10%25%15%
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Our
commitments
Engaged customers Talented people Contribution to society Financial strength
Digital & data-driven
organisation
Objectives &
Achievements
Relational net promoter scores (NPS-r) for
the Netherlands on par with market average
and for Insurance International above market
average.
Above target: customer satisfaction scores
continue positive trend with 8 out of 10 countries
ranking at or above market average; number
1 broker satisfaction scores at Dutch life and
pension businesses as well as P&C commercial
lines.
Expand DC capabilities in Life, implement
Non-Life strategy 2025, implement Digital
Retail Bank strategy and continue to shift to
protection products for International.
On track: overall good performance supported
by strong commercial momentum on
business specific strategic and commercial
objectives. Better than expected results on
the implementation of the Non-Life strategy
programme, combined with strong performance
in Insurance Europe, both on the shift to
protection as well as continued development of
the Bancassurance channel. The net expansion of
the DC capabilities in Life has come in just below
target but the overall DC AuM development is
solid. On the Digital Retail Bank strategy some of
the key milestones have been met, but others are
facing some delay in implementation.
Continue to drive action plans to reduce GHG
emissions of the corporate investment portfolio
by 25% by 2025 and by 45% by 2030, further
substantiate actions plans to meet carbon
reduction targets of Dutch residential mortgages
and insurance underwriting in 2030, set targets
for real estate portfolio. Net additions to climate
solutions on average between EUR 550-750m
annually to be on track to reach at least EUR 11bn
investments in climate solutions by 2030.
On track: continued progress in reducing carbon
footprint of corporate investment portfolio. Several
measures are implemented that aim to motivate
borrowers to enhance their homes’ energy-efficiency
ratings, reduce GHG emissions and provide access to
financing. The Responsible Insurance Underwriting
(RIU) Framework Policy was published in 2024.
In 2024, net-zero audits were largely completed
for the standing assets in the real estate portfolio.
Total investments in climate solutions increased to
EUR 12.8 billion, ahead of target.
Reduce GHG emissions of our facilities/offices
and business air travel by at least 35% in 2024
(vs 2019), implement local plans to reduce GHG
emissions to meet 35% reduction target in 2025
Below target: 2025 ambition is still feasible but
does becomes more challenging as the reduction
is slowing down. Additional focus is needed on
reducing scope 3 business air travel emissions.
Moving towards becoming net zero for our own
operations, our progress is continuously monitored
across the value chain and the effectiveness of our
reduction strategies and actions is assessed.
Support the financial, physical and/or mental
well-being of 700 thousand people by 2024
(cumulative 2022-2024)
Above target: around 766 thousand people were
supported through NN’s community investment
programmes.
Successfully deliver on ambitions on IT
simplification, Data and AI, Digital and
Frictionless Journeys, Standardising support
processes and Profitable growth.
Above target: the digitalisation programme is
well-established and progressing as planned, with
full-scale execution of numerous initiatives driving
standardisation, automation, and reusability, while
maintaining a strong commitment to CX and growth.
Employee engagement of ≥ 7.9 for NN Group
At target: the 2024 year-end employee
engagement survey showed an upward trend and
resulted in a score of 7.9.
Women in senior management positions
≥ 39.5%
Above target: at the end of 2024, 41% of senior
management positions in NN Group were held by
women.
Target
Weighting
We see our customers as the
starting point of everything
We empower our colleagues
to be their best
We contribute to the well-being of
people and the planet
We develop and provide attractive
products and services
Target 2024 Outcome: Sustainability Finance Other strategic
Operating capital generation
(in EUR million)
1,862 2,328
1,876
1,9221,397
1,126
Free cash flow to the holding
(in EUR million)
1,501 1,519
Target
Target
Cap
Cap
Outcome
Outcome
Threshold
Threshold
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2024 Variable Remuneration award
The Supervisory Board concluded that, under the
leadership of the members of the Executive Board,
NN Group continued to deliver a strong business
performance throughout the year 2024. This is
supported by a consistently strong performance
in both financial and strategic objectives, which is
showcased by the overall outcome of the objectives
related to all strategic commitments resulting above
target.
On the basis of the assessment of the Supervisory
Board, it was concluded to award David Knibbe in his
capacity of CEO and chair of the Executive Board a
variable remuneration of 17.6% of his base salary,
which is EUR 358,109 and 110% of his variable
remuneration target (2023: 108% of target) and
Annemiek van Melick in her capacity of CFO and vice-
chair of the Executive Board a variable remuneration
of 19.1% of her base salary, which is EUR 263,412
and 119% of her variable remuneration target
(2023: 108% of target). This award is based on the
realisation of objectives on financial and strategic
objectives, and consideration has been given by the
Supervisory Board to significant additional efforts
of the CFO in relation to corporate initiatives and
strategic projects.
In 2024, there was no hold back applied to unvested
deferred variable remuneration nor was claw back
applied to paid or vested variable remuneration for
any of the Executive Board members.
David Knibbe Annemiek van Melick
2024 2023 2024 2023
Base salary in cash 1,629 1,548 1,104 1,049
Base salary in shares 407 387 276 262
Total base salary
2,036
1,935
1,380
1,311
Variable remuneration 358 334 263 227
Total direct remuneration
2,394
2,269
1,643
1,538
Employer contribution to pension fund 29 27 29 27
Individual savings allowance
1
442 421 289 275
Other emoluments 126 106 23 33
Employer cost social security
2
60 79 48 59
Relative proportion base salary versus variable
remuneration 85.0% / 15.0% 85.3% / 14.7% 84.0% / 16.0% 85.3% / 14.7%
1
The individual saving allowance scheme is applicable to both the Executive Board and staff of NN Group in the Netherlands.
2
The employer social security contributions do not impact the overall remuneration received by Executive Board members.
The total remuneration as disclosed in the table on
the left hand side (for 2024: EUR 5.1 million) includes
all variable remuneration related to the performance
year 2024. Under IFRS-EU, certain components of
variable remuneration are not recognised in the profit
and loss account directly, but are allocated over the
vesting period of the award. The comparable amount
recognised in staff expenses in 2024 and therefore
included in ‘Total expenses’ in 2024, relating to the
fixed expenses of 2024 and the vesting of variable
remuneration of 2024 and earlier performance years,
is EUR 4.9 million.
2024 Variable remuneration of the Executive Board members (in EUR1,000 and gross)
Upfront cash paid
Deferred cash
granted
Upfront shares
granted
Deferred shares
granted Total
David Knibbe 72 107 72 107 358
Annemiek van Melick 53 79 53 79 263
Executive Board pension arrangements
The pension arrangement for the members of
the Executive Board is the same as the pension
arrangement that is applicable to all staff of
NN Group in the Netherlands and as of 1 October
2022 comprises an individual defined contribution
(IDC) plan up to the annual tax limit (EUR 137,800
for the year 2024) and a taxable individual savings
allowance on pensionable fixed remuneration
exceeding the tax limit.
The table on the left hand side provides details on the
amount of contribution that was paid by NN Group
to the pension arrangement of the Executive Board
members.
Remuneration of the Executive Board members
(in EUR1,000 and gross)
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Executive Board: other emoluments
The members of the Executive Board were eligible
for a range of other emoluments, which may include
healthcare insurance, life cycle saving scheme,
transportation and external tax advice. The Executive
Board members were also able to obtain banking and
insurance services from NN Group in the ordinary
course of business and on terms that apply to all
employees of NN Group in the Netherlands. As at
31 December 2024, the Executive Board members
did not have loans outstanding with NN Group
regulated entities. No guarantees or advanced
payments were granted to the Executive Board
members. The remuneration overview provides
details on the amount of emoluments that was paid
by NN Group to the benefit of the Executive Board
members. Long-term incentives awarded in previous
years and in 2024 to the Executive Board members.
The Executive Board members receive deferred
cash and upfront and deferred share awards under
NN Group’s Aligned Remuneration Plan (ARP). The
table on the right hand side provides a summary of
the number of NN Group shares awarded and vested
for theExecutive Board members during 2024 under
the ARP.
Long-term incentives awarded in previous
years and in 2024 to the Executive Board
members
The Executive Board members receive deferred
cash and upfront and deferred share awards under
NN Group’s Aligned Remuneration Plan (ARP). The
table below provides a summary of the number
of NN Group shares awarded and vested for the
Executive Board members during 2024 under the
ARP.
Overview of number of NN Group shares awarded and vested for the Executive Board members during 2024
Plan Award Date
Outstanding and
unvested per
1January 2024
Awarded during
2024
Vested during
2024
Outstanding and
unvested per 31
December 2024
Vesting Price in
euros
David Knibbe Deferred Shares Plan 15March2021 784 784 40.70
Deferred Shares Plan 14March2022 1,291 645 646 40.85
Deferred Shares Plan 13March2023 2,099 699 1,400 41.03
Deferred Shares Plan 25March2024 2,433 2,433
Upfront Shares Plan 25March2024 1,622 1,622 41.52
Annemiek van Melick Deferred Shares Plan 13March2023 904 301 603 41.03
Deferred Shares Plan 25March2024 1,648 1,648
Upfront Shares Plan 25March2024 1,099 1,099 41.52
The table below shows a summary of the (vested)
NN Group shares held by the Executive Board
members on 31 December 2024 (including the
shares vested during 2024) and 31 December 2023.
The total of shares is broken down into shares that
may be sold (free) and shares that remain subject
to the retention period (restricted). The shares are
either awarded as part of base salary or variable
remuneration.
NN Group shares held by the Executive Board members
Total Free Restricted
2024 2023 2024 2023 2024 2023
David Knibbe 62,163 54,828 25,948 21,248 36,215 33,580
Annemiek van Melick 10,965 6,609 0 0 10,965 6,609
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Remuneration of the Executive Board members, company performance and average employee
remuneration
2024 2023 2022 2021 2020
Executive Board remuneration
(amounts in Euro 1,000 and gross)
Total direct remuneration Mr Knibbe 2,394 2,269 2,113 2,102 2,059
Total direct remuneration Mrs. van Melick 1,643 1,538 760
Total direct remuneration Mr Rueda
1
820 1,682 1,669
Company performance (amounts in
euro million)
Operating capital generation 1,922 1,902 1,711 1,584 993
Operating result 2,574 2,528 1,743 2,036 1,889
Solvency II ratio 194% 197% 197% 213% 210%
Average remuneration (amounts in
Euro 1,000 and gross)
Average employee remuneration 97.3 92.6 84.3 88.9 90.3
CEO pay ratio (average) 31:1 31:1 32:1 30:1 30:1
CEO pay ratio (median) 38:1
1
Delfin Rueda stepped down as member of the Executive Board and CFO of NN Group as of 1 July 2022. His remuneration in the capacity of
CFO of NN Group is shown in the table above.
Pay ratio
The pay ratio compares the total CEO compensation
and the remuneration of all staff (‘pay ratio’) as
stated in the Dutch Corporate Governance Code.
For the CEO, the total remuneration used in the
pay ratio is the total remuneration as disclosed in
the Remuneration Report. For the staff members,
the total remuneration used in the pay ratio is the
total remuneration as disclosed in the Consolidated
annual accounts Note 26 ‘Staff expenses’. In order
to provide a meaningful comparison, the total
remuneration of the staff population excludes the
remuneration of the CEO ofNN Group.
NN Group aims to align with the pay ratio calculation
method as prescribed in the Dutch Corporate
Governance Code. The pay ratio calculation excludes
external staff costs and includes all variable
remuneration related to the performance year.
In light of the reporting requirements as prescribed
in the European Sustainability Reporting Standards
(ESRS), NN Group discloses the pay ratio based on
the median remuneration of all staff as of 2024, in
addition to the calculation method as prescribed in
the Dutch Corporate Governance Code
. The median
CEO pay ratio is the ratio between the annual total
remuneration of NN Group’s highest paid individual
(the CEO) and the median remuneration of its
employees (excluding the total remuneration of the
CEO). The calculation method based on the median
remuneration aims to align with the calculation
method as described in the ESRS. The difference
between the two pay ratios is mainly triggered by
the fact that the average employee remuneration
at NN Group is higher than the median employee
remuneration. In addition, the pay ratio calculation
method based on average employee remuneration
includes more salary components compared to the
median employee remuneration calculation. This
is due to the fact that not all employee (benefit)
costs can be broken down or attributed to individual
employees, and as such can not be included in the
remuneration as used to determine the median
as the middle value in a sorted list of all individual
employees.
The Supervisory Board considers trends in the pay
ratio in its assessment of the compensation of the
members of the Executive Board, while HR closely
monitors the pay ratio.
Remuneration of the
Supervisory Board
On 31 December 2024, the Supervisory Board
was comprised of the following members: Mr Cole,
Ms Beale, Mr Jenkins, Mr Lelieveld, Ms Reyes, Mr
Timmermans and Ms Van der Meer Mohr. See more
information on the composition of the Supervisory
Board and its Committees in ‘Corporate governance’
on p. 90-91 and in ‘Report of the Supervisory Board’,
on p. 102. The 2024 total remuneration as paid
to each of the members of the Supervisory Board
is in line with the applicable Supervisory Board
Remuneration Policy effective as of 1 June 2024.
NN Group is dedicated to aligning the interests of the
members of the Executive Board with those of the
company and its stakeholders. For shareholders, this
is realised through various ways, including awarding
50% of the variable remuneration in NN Group shares
and applying a five-year retention period as from the
award date, during which period the shares cannot
be sold. Furthermore, 20% of the base salary of the
Executive Board members is delivered in the form of
NN Group shares, again with a mandatory retention
period of five years as from the award date. This way,
the Executive Board members build up a substantial
interest in NN Group shares, without having
formalised share ownership guidelines. As at 31
December 2024, the total value of the shares, based
on the year-end share price, equals 15 months of the
gross base salary held by the Chief Executive Officer
and four months of the gross base salary held by the
Chief Financial Officer.
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The Supervisory Board remuneration policy needs to
be submitted to the General Meeting of NN Group for
adoption every four years based on Dutch law. The
Supervisory Board remuneration policy, including an
amendment to the level of the fixed annual fee for the
members of the Supervisory Board has been adopted
by the General Meeting on 24 May 2024.
NN Group does not grant variable remuneration,
shares or options to the Supervisory Board members.
This ensures the independence of the Supervisory
Board and is in line with the Dutch Corporate
Governance Code. In line with this principle, there
are no sustainability-related performance objectives
related to the members of the Supervisory Board.
Supervisory Board members may obtain banking
and insurance services from NN Group subsidiaries
provided that such services are amongst others in
line with the ordinary course of busines and on terms
that are customary in the sector. As at 31 December
2024, the Supervisory Board members did not have
loans outstanding with NN Group regulated entities.
No guarantees or advanced payments were granted
to Supervisory Board members.
In line with market practice, a distinction is made
between the fees as provided to the chair, vice-chair
and other members of the Supervisory Board. A fixed
annual expense allowance is payable to cover all out-
of-pocket expenses. Travel and lodging expenses in
relation to meetings are paid by NN Group.
The remuneration for the members of the Supervisory Board (in EUR)
1
Chair Vice-chair Member
Fixed Annual fee Supervisory Board 125,000 85,000 75,000
Fixed annual fee for position in Committee 20,000 n/a
2
15,000
Fixed annual expense allowance to cover out of pocket expenses
(travel and lodging will be paid) 9,000 9,000 9,000
1
The level of the fixed annual fee for the members of the Supervisory Board is shown in the table above and is effective as from 1 June 2024.
2
There are no vice-chair positions in Supervisory Board Committees.
Fees and allowances of Supervisory Board members (in EUR and gross)
1
Fixed annual fees Total fixed gross expense allowance Total
2024 2023 2024 2023 2024 2023
D.A. (David) Cole (Chair)
3
142,225 143,708 9,000 9,000 151,225 152,708
P.F.M. (Pauline) van der
Meer Mohr (vice-chair) 117,292 104,542 9,000 9,000 126,292 113,542
I.K. (Inga) Beale 103,333 97,250 9,000 9,000 112,333 106,250
R.W. (Robert) Jenkins 103,333 97,250 9,000 9,000 112,333 106,250
R.J.W. (Rob) Lelieveld 123,333 114,542 9,000 9,000 132,333 123,542
C.G. (Cecilia) Reyes
3
108,333 107,250 9,000 9,000 117,333 116,250
J.V. (Koos) Timmermans
2
63,374 5,440 68,813
J.W. (Hans) Schoen
5
40,234 104,333 3,585 9,000 43,819 113,333
H.M. (Hélène) Vletter-
van Dort
4
42,917 3,750 46,667
1
This table shows the fixed fees and expense allowances for the members of the Supervisory Board of NN Group for 2024 and 2023.
Mr Schoen was appointed as Supervisory Board member of Nationale-Nederlanden Levensverzekering Maatschappij N.V. as from 21 January
2020 and Nationale-Nederlanden ABN AMRO Verzekeringen Holding B.V. and ABN AMRO Schadeverzekering N.V. as from 15 September
2021. Ms Beale has been appointed as Supervisory Board member of Nationale-Nederlanden Schadeverzekering Maatschappij N.V. as from
8 June 2022 and Mr Lelieveld has been appointed as Supervisory Board member of NN Re Netherlands N.V. as from 14 June 2022. In 2024,
the total fees for these roles were EUR 106,000.
2
Mr Timmermans was appointed as Supervisory Board member as from 24 May 2024.
3
Mandatory social security and occupational disability contributions in relation to the NN Group Supervisory Board fees are due for Mr Cole,
for Ms Beale and for Ms Reyes on the basis of specific local requirements as applicable to the Supervisory Board members. The mandatory
employer contributions in relation to 2024 that are made to relevant local institutions amount to EUR 19,760 for Mr Cole
and EUR 6,268 for
Ms Reyes. The relevant employee contributions are fully borne by Mr Cole and Ms Reyes themselves, and the Supervisory Board members are
not compensated for that in any way.
4
At the close of the 2023 AGM on 2 June 2023, Ms Vletter-van Dort’s term of appointment as NN Group Supervisory Board member ended.
5
At the close of the 2024 AGM on 24 May 2024, Mr Schoen’s term of appointment as NN Group Supervisory Board member ended.
NN Group N.V. Annual Report 2024 | 115
Our Code of Conduct and other policies
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Our Code of Conduct and
other policies
Business conduct policies and corporate
culture
In this chapter, we describe our approach to
promoting and safeguarding our corporate culture,
values and related behaviours. We structure this
approach around three key areas:
Prevention: The NN Code of Conduct and awareness
initiatives support and promote our NN Values and
beliefs. They are both designed to foster a positive
corporate culture and good business conduct.
Detection: We use dashboards and our Risk
Management Framework (RMF) to monitor business
and employee conduct. Our RMF involves risk
assessment by our first and second lines on items
using tools such as dashboarding and maturity
reflection. The maturity reflection is a self-
assessment by first and second line on items from
our RMF. This facilitates dialogue with management
on managing and improving our compliance
culture. Together, these tools help us assess the
effectiveness of our policies and identify areas for
improvement.
Response: We have reporting and investigation
mechanisms in place to address instances of
misconduct. These include clear policies and
processes for reporting unethical behaviour and
protecting whistleblowers.
The NN Code of Conduct
Founded on our company values, the NN Code of
Conduct and Manager Annex are directly linked to
the NN statement of Living our Values and other
relevant underlying policies and standards. The
Manager Annex includes additional expectations for
our business leaders, including managers and board
members so they can help everyone to embody
our values and meet our standards. Together, the
NN Code of Conduct and Manager Annex include
guidelines for how we interact with colleagues and
customers, handle information and (personal) data,
manage conflicts of interest, fraud, bribery and
corruption, address financial economic crime, use
equipment, the internet and AI, and report and deal
with breaches.
Each year, we review and update the NN Code
of Conduct and Manager Annex, along with the
underlying policies and standards. All internal
employees must formally acknowledge their
understanding of the NN Code of Conduct and their
commitment to applying the underlying policies
and standards each year. All managers also need to
formally acknowledge the Manager Annex annually.
Formal acknowledgement has been mandatory
for several years and in 2024 we achieved a
100% acknowledgement score (excluding staff on
long-term or sick leave). External employees and
contingent workers are to comply with the NN Code
of Conduct as part of their contract.
Awareness and e-learnings
We raise engagement and awareness among
employees on people- and business conduct-related
topics through e-learnings. Our internal SharePoint,
Conduct Matters, which is available in all local
languages, supports our NN Code of Conduct by
providing e-learnings around conduct as well as
additional conduct-related resources such as lists
of contacts in particular situations and dilemma
exercises. To improve employees’ understanding of
the NN Code of Conduct and improve their ability to
recognise and act on integrity-sensitive situations,
we also introduced The Code, the Basics e-learning.
We also offer mandatory e-learnings on different
topics to raise risk awareness around confidential
and price-sensitive information. These include
Confidential Matters, on confidentiality, Trading
Matters, for all NN insiders, which focuses on market
abuse/insider trading, Conflicting Matters, which
covers bribery, corruption and conflicts of interest,
Speaking Up Matters, which encourages speaking up,
and Data Matters on the use of data and confidential
information. The Code, the Basics, Conflicting
Matters, Speaking Up Matters and Data Matters are
available in all local languages.
In 2023, we launched an e-learning on financial
economic crime (FEC) in the Netherlands for all NN
employees. We also introduced additional e-learnings
on FEC and sanctions for specific employee groups.
At the start of 2024, these were rolled out to all
international business units in local languages.
These e-learnings are mandatory for all NN Group
employees and are integrated into the onboarding
process of new joiners and will be regularly updated.
The Integrity Dashboard monitors employee
participation in these mandatory learnings.
Digital compliance dashboards
In 2024, we continued developing the Integrity
Dashboard and Compliance Dashboard, used by
all NN business units to facilitate a more data-
driven Compliance function. Initially rolled out in
2023, the Integrity Dashboard provides detailed
NN Group N.V. Annual Report 2024 | 116
Our Code of Conduct and other policies
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
information for first line management to raise and
monitor awareness among team members on
compliance topics and related behaviour. Similar
to the Compliance Dashboard, it includes a clear
overview of outstanding tasks regarding mandatory
e-learnings, the mandatory Oath for all employees,
and other compliance topics such as the numbers of
insiders, approvals of received and offered gifts and
entertainment, potential conflicts of interest, and NN
Code of Conduct acknowledgment percentages.
In 2024, we introduced the Pre-Employment
Screening Dashboard for monitoring pre-employment
screening. We also enhanced our Integrity and
Compliance Dashboards to improve usability and
integrated relevant compliance risk metrics into
the Group Risk Dashboard at business unit level,
providing a better overview of compliance status
and integrity-related activities. This year, we added
new data sources for our risk management system,
business continuity management system, and
the system that presents legal structures. These
additions are important for compliance with the
Digital Operational Resilience Act (DORA) , which
mandates the disclosure of certain information. By
incorporating these additional data sources, we
have enhanced our reporting capabilities, providing
a more comprehensive view of how we monitor our
compliance with policies and standards across the
organisation.
Risk Maturity Reflection
The Risk Maturity Reflection is the integrated
framework of the Risk Culture Check-in
1
and the
Maturity Assessment of business unit control
functions. It forms the basis for constructive dialogue
with NN senior management on how we manage the
risk culture within the company and where we can
improve. Feedback from this dialogue underpins the
People Conduct & Business Culture statement. The
process is led by Group Risk in close cooperation with
Group Legal and Group Compliance. The Risk Maturity
Reflection is performed across business units every
two years. It was last executed in 2024.
Reporting misconduct (whistleblowing)
By living up to our values, we aim to create a safe
working environment for colleagues and business
partners, where everyone feels welcome, valued
and respected. In doing so, we build and protect
the reputation and integrity of our company while
adhering to applicable laws and regulations. At
NN Group, we encourage the internal reporting
of (potential) concerns and breaches of local and
European Union (EU) regulations, NN Core Values
and NN policies through various channels. Whenever
(potential) work-related concerns or breaches
are reported, NN Group takes them seriously and
carefully assesses each report to determine whether
further investigation or action is needed. The report
includes work-related issues around human rights
and equal treatment and opportunities for all.
1
Business units perform a self-assessment of the risk culture within their unit (including the independent view of local control functions) in
cooperation with Head Office control functions.
NN Group uses the Speak Up system, which allows
every employee and certain external parties
(contractors, subcontractors, suppliers), to report
concerns and breaches rising from within our
organisation outside the regular reporting channels.
Speak Up allows reports to be made anonymously
and in the reporter’s preferred language. The system
is designed, established, and operated securely to
ensure the confidentiality of a reporter’s identity if so
desired, with access restricted to a very limited group
of authorised NN Group staff members, who are
well trained reporting officers, NN Group Reporting
Officer/Chief Compliance Officer or delegated person,
Global Head Security and Investigation NN Group
or delegated persons. The Speak Up system also
supports (anonymous) communication between the
reporter and the reporting officers when needed. NN
takes appropriate measures, like maintaining the
confidentiality of the reporter, educating relevant
staff about retaliation during the process, ensure
proper follow up with the reporter, to prohibit any
form of retaliation against reporters and to protect
individuals. Additionally, NN Group also defines forms
of retaliation and strict disciplinary measures against
employee who attempts retaliation.
Through the Speak Up system, reporters are always
informed of their rights and how they are protected
against potential retaliation. They are also reminded
of their obligation to report in good faith and to
maintain the confidentiality of their report. We give
reporters feedback on whether their report falls
within the scope of the International Whistleblower
Policy or the Whistleblower Standard for Dutch
Business Units and Head Office of NN Group. If it
does, we investigate further and take follow-up
actions or disciplinary measures as appropriate.
These measures are designed to ensure that the
remedy is effective and to incorporate key learnings
into our existing processes and policies. The Speak
Up system keeps reporters informed and updated on
the progress of their report; if the report is outside
the scope of any of the above-mentioned Standards,
then the reporter is directed to other internal
procedures. Reports are recorded and periodically
reported by the Chief Compliance Officer to the NN
Group Management Board and Risk Committee of the
NN Group Supervisory Board.
In 2023, changes to the whistleblowing regulation
in the Netherlands narrowed the scope of concerns
that can be reported. Consequently, we follow up
reports that fall outside the new scope through
alternative but aligned channels. In 2024, the
Compliance function continued to raise awareness
to foster a culture of open dialogue and speaking
up through training and communication, both in the
Netherlands and internationally, in close cooperation
with the HR and Communication departments. This
training and communication gives clarity on different
reporting channels, processes and protection against
retaliation. The Speak Up e-learning is mandatory for
all employees. Additionally, reporting officer receive
regular training on how to handle reports.
The NN Group engagement survey ‘Peakon’ is
conducted twice a year. The survey asks employees
to give a score for the statement: ‘If I experienced
any kind of misconduct or unethical conduct at work,
NN Group N.V. Annual Report 2024 | 117
Our Code of Conduct and other policies
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
I’m confident NN Group would take action to address
the situation.’ This data point, along with other
assessments, enables us to evaluate the perceived
effectiveness of our reporting channels by employees
and identify areas for improvement. See ‘Social’ on
p. 179 for more information on the survey.
Corporate security and investigations
NN Group’s Investigation Standard outlines
requirements for reporting, investigating, and
settling (material) incidents in the organisation
consistently, transparently and professionally. The
standard is owned by the independent NN Group
Corporate Security & Investigations department
(CSI), which must always be consulted in cases of
material (suspected) breaches of the NN Code of
Conduct. CSI determines if and how an investigation
should be conducted. Investigations can be
conducted by CSI or under local responsibility, with
CSI approving the local proposal in terms of scope
and manner of the investigation. Only members of the
NN Group Management Board, their direct reports,
or members of the NN Group Supervisory Board may
commission investigations.
The way in which an investigation is conducted
must be proportional to the nature of the incident,
consider the rights and interests of employees and
other parties involved, and comply with local laws
and regulations, particularly in the field of privacy
and data protection, data retention and labour
legislation. The results of an investigation should be
reported to the commissioner of the investigation. In
cases where disciplinary actions may be necessary,
a Settlement Council, consisting of, among others,
the commissioner and representatives of HR, CSI,
Compliance and Legal, should be convened as soon
as possible. The members of this Settlement Council
will advise the commissioner on the next steps and
measures, including possible disciplinary actions.
2024 reported whistleblower cases
In 2024, we received whistleblower reports from
within various parts of NN Group, both in the
Netherlands and internationally. Reports are recorded
and numbers are periodically reported by the Chief
Compliance Officer to the NN Group Management
Board and Risk Committee of the NN Group
Supervisory Board.
Whistleblower cases
2024 2023 2022
Total reported 34 29 17
Investigated by CSI 6 3 2
Disciplinary actions
taken on reported
whistleblower cases 8 5 1
Other incidents and concerns
CSI was involved with 42 cases in 2024 (in 2023 the
figure was 48). In 4 of these, disciplinary measures
were taken (warning, reprimand, termination of
employment or instant dismissal). Three disciplinary
cases are overlapping with the disciplinary actions
taken on reported whistleblower cases. Employees
are informed in writing of any disciplinary measures.
CSI cases involving disciplinary measures
2024 2023 2022
Fraud-related 1 3 1
Unethical behaviour 3 2 1
Conflict of interest 0 0 0
Total 4 5 2
Product approval and review process (PARP)
and customer golden rules
We want to provide customers with value for
money, transparency, and products and services
that align with societal expectations and legislative
developments. For instance, new or modified
products or services are subject to a product approval
and review process (PARP) to safeguard they are
transparent and meet customer needs. Our ‘customer
golden rules’ are an integral part of the PARP. These
are:
• We strive to meet customers’ needs throughout
their life cycle.
• Offer fair value to customers.
• Explain the risks, returns and costs of our
products and services.
• Regularly assess products, services and
distribution practices.
• Only work with professional and licensed
distributors.
Product insight
In response to the Sustainable Finance Disclosure
Regulation (SFDR) and related Insurance Distribution
Directive (IDD) in 2023, we developed a centralised
data platform. This platform is developed for making
SFDR calculations to support SFDR disclosures
throughout NN Group. A SFDR Guidance Committee
and User Board were set up to further mature
the reporting process and address any required
regulatory changes to current processes or
methodology.
For our investment products, we optimised our
Unit-Linked dashboard, which gives insights into
Unit-Linked Asset Managers, as well as improving
understanding of funds offered on risk levels, SFDR
classification, fund returns, and the performance of
funds available within NN.
Data privacy
NN Group is aware of the need to strike an
appropriate balance between individual choices,
privacy and social responsibility. With digitalisation
continuing rapidly, we are conscious that to
safeguard the privacy of our customers, it is more
important than ever to secure their personal data and
handle it responsibly. We are subject to legislative
data protection requirements, the most important
being the EU General Data Protection Regulation
(GDPR). In our privacy statement we explain how
we have translated the GDPR into our day-to-day
operations. We raise awareness about the careful
processing of (personal) data by providing training for
our employees and regularly updating information on
our intranet.
Our Data Protection Office (DPO) Charter provides a
mandatory framework that establishes the function
of Data Protection Officer. Both NN Group and
NN Group N.V. Annual Report 2024 | 118
Our Code of Conduct and other policies
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
our individual business units within the EU have
appointed a DPO, who is assigned a clear mandate
and responsibilities in line with the DPO Charter
and the GDPR. Our Data Protection Officers monitor
compliance with the GDPR, and act as contact points
for supervisory authorities and data subjects. The
DPOs monitor the number of complaints and data
breaches, which are currently within an acceptable
range.
Artificial intelligence
We have established the NN AI Framework to
safeguard that we use trustworthy AI. This
framework includes AI assessments validated
by an AI Working Group, addressing key aspects
such as lawful data processing, bias prevention
and ethical considerations. The AI Act entered
into force on 1 August 2024, with most of its rules
coming into effect on 2 August 2026. To meet the
initial obligations effective from February 2025,
we have incorporated the prohibition of specific AI
systems into NN’s AI Framework and promoted AI
literacy through the NN Data Literacy programme.
The next steps will involve the categorisation of
NN’s AI systems according to the AI Act’s risk-
based approach. To support these efforts, we have
implemented a governance structure and are training
our employees on AI applications and assessments.
This initiative supports our workforce to manage AI
systems ethically and effectively. We will continue
to contribute to regulatory initiatives aimed at
establishing guidelines for complying with the AI Act
and keep a close watch on other upcoming legislation
regarding AI, like the proposed AI Liability Directive.
NN successfully rolled out Microsoft 365 Copilot
across the organisation, which aims to boost
productivity by automating routine tasks and offering
intelligent insights. To make employees more
proficient with these new AI tools, we introduced
three e-learnings: AI Essentials at NN, Perfect
Prompting, and Get Started with M365 Copilot. These
are designed to familiarise employees with AI tools
and teach effective prompting techniques, ultimately
increasing their productivity and confidence in
leveraging AI technology. The pilot phase has shown
promising results, facilitating access to internal
knowledge and process automation, aiming to
enhance productivity and reduce operational costs.
Building on this success, we launched a centralised
Generative AI platform (GAIA) in collaboration with
Group IT and Customer & Digital. GAIA enables
teams to integrate their own data and use out-of-
the-box generative AI capabilities, such as Retrieval
Augmented Generation (RAG) and AI Agents.
This platform supports NN’s ambition to improve
operational efficiency and drive innovation. These
initiatives have shown promising results, enhancing
access to internal knowledge and enabling our
operational departments to provide more efficient
customer support, contributing to our goals of
increased efficiency and cost reduction.
Financial economic crime
For NN, combating financial economic crime (FEC)
is not just a legal obligation, it is a way to protect
society, including customers, against criminal
activity. FEC covers the risk of money laundering,
financing of terrorism and breaching applicable
sanctions regimes. As a corporate citizen, NN Group
takes its gatekeeper role to protect the integrity of
the financial system seriously. This commitment is
reflected in our Risk Appetite Statement regarding
sound business conduct and in the NN Group FEC
Policy. Our FEC framework sets out mandatory
minimum requirements for detecting and preventing
FEC, and is based on applicable international,
European, Dutch and local laws, regulations and
guidelines.
In 2024, NN focused on implementing the updated
FEC Policy and the new governance structures
introduced in 2023, effectively integrating these
changes across all levels of the organisation.
This year we also set up a programme in the
Netherlands to further strengthen the framework
and overarching processes of the Dutch business
units. Looking ahead, we will continue our efforts
to maintain a robust FEC framework by training
relevant employees, conducting a Group-wide FEC
risk assessment and performing deep dives where
necessary.
NN Group N.V. Annual Report 2024 | 119
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Conformity statement
The Executive Board is required to prepare the annual
accounts and the Report of the management board
(bestuursverslag) of NN Group N.V. for each financial
year in accordance with applicable Dutch law and the
International Financial Reporting Standards (IFRS) as
endorsed by the European Union.
As required by section 5:25c paragraph 2(c) of
the Dutch Financial Supervision Act, each of the
signatories hereby confirms that to the best of his
knowledge:
• The NN Group N.V. 2024 annual accounts, as
referred to in section 2:361 of the Dutch Civil Code
including the relevant additional information as
referred to in section 2:392 paragraph 1 of the
Dutch Civil Code, give a true and fair view of the
assets, liabilities, financial position and profit or
loss of NNGroup N.V. and the enterprisesincluded
in the consolidation taken as a whole.
• The NN Group N.V. 2024 Report of the
management board (bestuursverslag), asreferred
to in section 2:391 of the Dutch Civil Code, gives
a true and fair view of the position at the balance
sheet date, and the development and performance
of the business during the 2024 financial year of
NN Group N.V. and the enterprises included in the
consolidation taken as a whole, together with a
description of the principal risks NN Group N.V. is
confronted with.
With reference to best practice provision 1.4.3(i), (iii)
and (iv) of the Dutch Corporate Governance Code, the
Executive Board hereby confirms that, tothe best of
its knowledge:
• NN Group N.V.’s description of its risk
management organisation and framework as
described in the Report of the management
board (bestuursverslag) including Note 48 Risk
management to the Consolidated annual accounts
provides sufficient insights into any material
failings in the effectiveness of the internal risk
management and control systems with regard to,
in any case, the strategic, operational, compliance
and reporting risks as referred to in best practice
provision 1.2.1 of the Dutch Corporate Governance
Code.
• Based on the current state of affairs, it is justified
that the financial reporting is prepared on a going
concern basis.
• The NN Group N.V. 2024 Report of the
management board (bestuursverslag) includes
the material risks as referred to in best practice
provision 1.2.1 of the Dutch Corporate Governance
Code, and the uncertainties, to the extent that
they are relevant to the expectation of NN Group
N.V.’s continuity for the period of 12 months after
the preparation of the report.
The Executive Board of NN Group N.V. assessed the
effectiveness of the internal control over financial
reporting during 2024. Based on the Executive
Board’s assessment, with reference to best practice
provision 1.4.3(ii) of the Dutch Corporate Governance
Code, the Executive Board of NN GroupN.V.
concluded that the risk management and control
systems provide reasonable assurance that the
financial reporting does not contain any material
inaccuracies.
The Hague, 12 March 2025
David Knibbe
CEO, chair of the Executive Board
Annemiek van Melick
CFO, vice-chair of the Executive Board
NN Group N.V. Annual Report 2024 | 120
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Sustainability
Statement
We believe our business has a role to play in
the transition to a sustainable economy and
are committed to doing what we can to
contribute to the well-being of people, the
planet and society.
NN Group N.V. Annual Report 2024 | 121
General disclosures
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
At NN Group, sustainability has long been an integral
part of our strategic vision. We view sustainability
from both an outside-in and inside-out perspective,
enabling us to address the challenges posed by
sustainability risks, as well as opportunities, and the
impact they may have on people and the
environment, while also tapping into new market
segments and fostering innovation.
Similar to previous annual reports, we comply with
the Non Financial Reporting Directive (NFRD). In
2024, the new EU Corporate Sustainability Reporting
Directive (CSRD) and the accompanying European
Sustainability Reporting Standards (ESRS) were
issued. These new requirements are not yet
transposed into Dutch law and, therefore, not yet
applicable to NN. In this year’s Annual Report we
have voluntarily used the ESRS as basis for
preparation for the Sustainability Statement.
As part of our commitment towards enhanced
transparency, NN Group discloses information
concerning impacts, risks and opportunities (IROs)
related to environmental, social, and governance
(ESG) matters that are material for our own
operations and our value chain for the reporting year
2024. Recognising the complexity of the task, and
reflecting on the important role of stakeholder
engagement, we performed a Double Materiality
Assessment (DMA) in 2023 to identify any gaps and
to develop our CSRD-enhanced reporting strategy.
This resulted in a first mapping of our material topics.
This year, leveraging the insights we gained from the
2023 DMA, we continued our efforts to further
improve our DMA process and reporting practices.
The DMA forms our basis for sustainability matters
and related IROs disclosed in this Sustainability
Statement.
The Sustainability Statement aims to inform our
stakeholders, including customers, investors,
employees, business partners and regulators, as well
as broader society, about our sustainability
objectives and the progress we have made on them.
It underscores our ongoing commitment to creating
sustainable long-term value for stakeholders.
The outcomes of our DMA are detailed on pp. 20 and
21, and inform this Statement, including our topical
disclosures. In alignment with our purpose to be an
industry leader, known for customer engagement,
talented people and our contribution to society, we
have also identified entity-specific disclosures (ESDs)
providing additional context to the material
sustainability matters identified through the DMA.
General disclosures
Contents
General basis for preparation 122
Integrating sustainability
into our strategy 122
Our value chain 124
Our material sustainability matters 125
Connecting our sustainability matters
to our strategy and business model 126
Our approach to the DMA 127
Topical sustainability matters 130
Statement on due diligence 132
Risk management and internal controls 133
NN Group N.V. Annual Report 2024 | 122
General disclosures
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
General basis for preparation
NN Group’s Sustainability Statement for the year
ended 31 December 2024 is prepared on a
consolidated basis, consistent with the scope of the
consolidated annual accounts, unless specifically
stated otherwise alongside the indicator.
All subsidiaries included in this Sustainability
Statement are exempt from individual sustainability
reporting (including EU Taxonomy), except for NN
Bank. Since NN Bank is a public-interest entity with
bonds listed on an EU regulated market, it prepares a
standalone Sustainability Statement, including EU
Taxonomy reporting. See Annual Accounts, note 1,
p. 253 for more information on the scope of
consolidation.
Our Sustainability Statement has been prepared
using the ESRS as basis of preparation. NN Group
continues to report under the EU Taxonomy, Article 8
of EU Regulation 2020/852.
Throughout the Statement, all information needed to
understand the quantitative disclosures, such as the
methodology, assumptions, estimations, etc., is
presented alongside the metrics. Our external auditor
KPMG has provided limited assurance on this
Sustainability Statement (see the independent
auditor’s report on p. 392); there was no additional
validation by other external assurance providers on
any metrics presented in this Sustainability
Statement.
Within our Sustainability Statement the most
significant assumptions, estimations and
uncertainties relate to financed emissions, see
p. 150 onwards ‘Important note on the results’,
Climate Risk Assessment (CRA) from p. 161 onwards
Climate Risk Assessment results, and EU Taxonomy
disclosures, see, p. 172 onwards ‘Assumptions’.
Since 2017, we have externally disclosed that we
align our climate action approach to the
recommendations of the Task Force on Climate-
related Financial Disclosures (TCFD). Our net-zero
approach is described on p. 136, and included in a
TCFD reference table on p. 397.
Time horizons
We define time horizons as follows:
• short/medium term is less than or equal to five
years,
• long term is more than five years.
Combining the short- and medium-term horizons
differs from the ESRS 2 General Requirements, but
this deviation does not impact our report, or the
results of the analysis, and is a suitable basis for
discussing time horizons in our sustainability
reporting. We have aligned the time horizons with
those applied to existing processes, where the
business planning period is five years. Hence ‘short/
medium term’ is five years or less, ‘long term’ more
than five years.
Disclosing on minimum disclosure
requirements
We disclose on our policies, actions, targets and
metrics throughout this Sustainability Statement. We
disclose information related to the minimum
disclosure requirements for our policies in a
dedicated policy table in the Annex, see p. 215
The minimum disclosure requirements related to
actions and metrics are disclosed in ‘Environment’,
from p. 134 , and ‘Social’, from p. 179. Target-related
requirments are disclosed in ‘Governance’, see p.
207.
Integrating sustainability into
our strategy
We aim to be an industry leader, known for our
customer engagement, talented people and
contribution to society. Employing some 16,439
people (see p. 191 for a country overview), NN
provides retirement services, pensions, insurance,
mortgages and investments to around 19 million
customers across Europe and Japan. We have
integrated sustainability into our overall strategy,
including our strategic commitment to society
whereby we aim to contribute to the well-being of
people and the planet. This commitment guides our
activities and operations. We do business with the
future in mind and aim to contribute to a world where
people can thrive for generations to come.
With our DMA we have identified our material IROs.
The detailed overview of sustainability matters in this
chapter includes the IROs we consider material from
a DMA perspective, and how we address them with
an aim to enhance the well-being of people and the
planet. For this year we apply the phase-in provision
for revenue and segment reporting. The phase-in
provision gives room to not disclose information in
the first three years of applying ESRS where that
information is hard to obtain, or not available.
Therefore, this information is not disclosed here.
In relation to our strategic commitment to society, we
took a closer look at our key products, services,
markets and customer groups. By considering
material sustainability matters from the perspective
of our four main activities – our own operations,
products and services, investments and business
partners, we aim to enhance our strategic
commitments to society. We used the material
sustainability matters to identify opportunities and
risks, and (positive and negative) impacts related to
ESG factors. The ESG factors identified include
climate change, nature, sustainable repair, employee
and human rights, business conduct and corruption
and bribery.
With the ambitions and strategic targets we have set,
we aim to create impact on the real economy to help
enable a transition to a sustainable economy for all.
However, to reach net-zero targets and meet our
strategic commitments we need to overcome several
challenges. These include our reliance on external
actors, complex nature-related financial risks,
visibility issues in the value chain, new regulations
and rapidly changing data availability. To address
these, we collaborate with stakeholders, keep up
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
our activities and business relationships). Following
the salience assessment, we developed a social
roadmap with actions defined for our various roles for
the coming years. For more information about our
approach to human rights and the social roadmap,
see ‘Social’, p. 179.
Our contribution to the SDGs
The SDGs were set as part of the global agenda for
sustainability in 2015. We strongly believe the public
and private sector should work together to help
achieve the SDGs. For this year we aligned our DMA
outcome to the SDG selection to show the relation
between our IROs and SDG selection. We have better
aligned the efforts we take on managing our
sustainability IROs and on contributing to the SDGs.
In the table in ‘Annex’, p. 213 we visualise the
connection between our material sustainability
matters, the SDGs and how we contribute to the
SDGs through our strategy and activities. The last
column shows where further information can be
found on this contribution, and where possible we
include our targets and progress on those targets.
We acknowledge that we have not yet set targets on
every material topic for enhancing our positive impact
and minimising our negative impact. In the visual we
mention the contribution we made in 2024 to show
our efforts.
Within our topical chapters we have further described
the policies we have developed, the targets we have
set, and the actions we have identified to meet these
targets. As we are continuously developing our
sustainability strategy to show the progress and
contribution we have made, we acknowledge that,
currently, we do not have concrete targets to
contribute to each selected SDG. However, we have
the ambition to identify how we can help accelerate
their achievement going forward.
In our ambition to be an industry leader, we recognise
the importance of partnerships in driving meaningful
change. Our dedication to SDG 17 is integrated into
our extensive collaborations and partnerships to
achieve broader sustainability goals. This year, we
increased our contributions to communities by
focusing on the financial, mental and physical
well-being of individuals in our communities.
Moreover, by taking an active role in partnerships
such as the PCAF, we are committed to assessing
and reducing our carbon footprint guided by
internationally recognised standards.
capital allocation to, and insurance of, climate
solutions, and by employing phase-out and/or
restriction criteria as a last resort.
• Developing and offering products and services
that address environmental challenges that our
customers might face, (e.g. by contributing to a
low-carbon economy or helping insure our
customers against climate-related impact).
• Effectively managing our direct environmental
footprint by reducing our use of natural resources,
seeking green alternatives and offsetting the
remainder of our GHG emissions.
Respecting human rights
NN Group believes that companies have a
responsibility to respect human rights. This belief
impacts our business activities and interactions with
stakeholders across our value chain.
Our policy commitment to human rights is described
in the NN Group Human Rights Statement, which sets
out what we expect from ourselves and our business
relationships in this area. The Statement outlines
how we implement this commitment in line with
international standards, including the UN Guiding
Principles on Business and Human Rights (UNGPs)
and the Organisation for Economic Co-operation and
Development (OECD) Guidelines for Multinational
Enterprises on Responsible Business Conduct.
As part of our commitment to the UNGPs, we have
identified our salient human rights issues, (i.e. human
rights that are at risk of the most severe and likely
actual or potential negative impact on people through
with changing regulations, invest in data
management systems, enhance transparency in the
value chain and aim to support vulnerable
communities. Effort is also needed from society.
Given the speed of the transition and the actions it
demands, it will impact people and communities and
may disproportionately affect vulnerable groups. We
aim to support all groups, leaving no one behind.
The two key focus areas in our sustainability
approach are our commitment to achieving net-zero
emissions and respecting human rights.
Our approach to net zero
NN Group is committed to becoming a net-zero
company by 2050 for our proprietary investments,
insurance and banking activities, and net zero for our
own operations by 2040. We are concerned about
the effects of climate change on society and therefore
apply science-based principles to contribute to a
low-carbon future that meets the needs of the next
generations. We have developed several strategies
to decarbonise our assets, liabilities and own
operations. For more on our ambition, agenda and
action plans to reduce greenhouse gas (GHG)
emissions, see p. 135.
Our approach to the material sustainability matters
that relate to our net-zero ambition include:
• Helping accelerate the transition to a low-carbon
economy to limit the rise in average global
temperature to 1.5°C through our proprietary
investments, insurance and banking activities. We
aim to do this through, for example, engagement,
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Our value chain
NN Group’s value chain consists of four main
activities: our own operations, products and services
(insurance, pensions and banking), investments and
business partners. As a financial institution, we
recognise that our investments and insurance
services impact the real economy; we collaborate
with many business partners in our procurement
processes, as well as with financial advisors and
repair networks, and finally, we have the value chain
associated with our products and services.
Within this report we have integrated a combination
of value chain elements and value chain roles
throughout our report. This means that the terms are
used interchangeably in this report. Hear you can
read the terms that we assess as equivalents:
• Our own operations and our role as employer;.
• Our products and services and our role as service
provider;
• Our investments and our role as investor; and
• Our business partners and our role as business
partner.
We have included both references in the visual, which
gives a simple depiction of our value chain.
Our defined value chain forms the basis of our DMA.
We have identified material topics in all parts of our
value chain. We discuss these in more detail on
p. 128.
Own operations
NN Group’s own operations and our role as employer
consist of our people, offices, insurance and banking
entities, investment office and subsidiaries. As the
visual shows, they form the core of our value chain.
The scope of our own operations is in line with the
consolidation scope we use for the annual accounts.
Products and services
In our downstream value chain we identify the
products and services we provide to our clients as a
financial institution. In our role as service provider,
NN Group
Upstream
Our role as business partner
Own operations
Our role as employer
Products and services
Our role as service provider
Investments
Our role as investor
Suppliers related to own
operations
1
Asset managers
1
Downstream
Our role as business partner
Own operations
Our role as employer
Our workforce
Our offices
Investment office
Life
Non-life
Bank
Proprietary assets Client assets
Repair networks¹
Claims managers¹
Distribution partners
1
Corporate clients
SME clients
Retail clients
1
Is considered a business partner.
we provide our clients with insurance and banking
products. Our clients can be grouped into three main
categories: corporates, SMEs and households (retail
clients). The property, casualty, assets and activities
that we insure for them are considered part of our
value chain.
Investments
Our investments cover the investment activities we
carry out for our client assets and proprietary assets.
In our role as investor we act on the IROs for the
investments we have.
Business partners
By developing and offering products and services, we
collaborate with insurance and banking partners such
as external claims managers and repair networks.
Downstream of our own operations, we work
together with distribution partners to deliver
products and services to our clients. Our external
asset managers are seen as are our key suppliers in
the investment value chain. Additionally, we purchase
goods and services from our suppliers for our own
operations.
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Our material sustainability
matters
In the connectivity table (see p. 126) we visualise the
current and expected effects of sustainability matters
and their associated IROs on our business model,
value chain, strategy and decision-making by
connecting them to our business model and strategic
commitments. Actions identified to address these
issues are detailed in the respective sections and
sub-sections of the Sustainability Statement.
We have disclosed our sustainability matters in line
with the structure of the topical disclosure sections
from the ESRS. The entity-specific sustainability
matters ‘Community investment’ and ‘Sustainable
repair’ are covered by NN Group-specific disclosures.
While estimations on financial effects can be
calculated using the figures for the returns on our
investments, it is not straightforward to report on
this for our role as investor in the market, given the
sensitivity of the methodology and because we feel
that our target for euros invested gives more relevant
information for this sustainability matter. See
‘Environment’, p. 134 for more information on this.
In the table ‘Changes in material topics’, the
outcomes of the DMA 2024 have been compared with
the outcomes of the DMA 2023. The column ‘Change’
lists changes to the associated sustainability matters
and associated topics between the DMA 2023
outcome and the DMA 2024 outcome.
Changes in material topics
Sustainability matter Change
Climate change – When no targets are set, the potential negative impact of our own operations
is no longer material
– Only financial opportunity for our investments
– The potential negative impact of our business partners is no longer material
Nature (biodiversity and water) – For the topic ‘water’ the actual negative impact of our investments on
‘marine resources’ and the sub-topics ‘extraction and use of marine
resources’ are no longer material
– For the topic ‘biodiversity’, the actual negative impact of our investments on
‘sea-use change’, ‘direct exploitation’, ‘invasive alien species’ and ‘pollution’
are no longer material
Sustainable repair – The potential positive impact of the entity-specific disclosure ‘sustainable
repair’ has been identified as a new material impact
– The financial opportunity related to products and services is no longer
material
– The potential negative impact of our products and services on ‘waste’ and
‘resource outflows related to products and services’ is no longer material
Workers in the value chain – Following the salience assessment, the potential negative impact of our
business partners on ‘freedom of association, including the existence of
work councils,’ ‘collective bargaining,’ and ‘gender equality and equal pay for
work of equal value’ have been integrated into the DMA
– Following the salience assessment, the potential negative impact of our
investments on ‘living wage’ and ‘diversity’ have been integrated into the
DMA for our role as an investor. The topic ‘diversity’ specifically concerns
‘non-discrimination and equality’
– The potential negative impact of our investments on ‘adequate housing’ and
‘privacy’ is no longer material
Community investment – The actual positive impact of NN-specific topics ‘financial well-being,’
‘physical well-being,’ and ‘mental well-being’ have been identified as new
material topics
Financial inclusion – The potential negative impact of our products and services on social
inclusion is no longer material
Clear and secure data – The potential negative impact of our products and services on ‘quality and
security of data’, this includes ‘privacy’, ‘access to (quality) information’ and
‘security of a person’ have been identified as new material impacts
– The potential negative and positive impact of our products and services on
customer needs and satisfaction is no longer material
Corruption and bribery – The potential negative impact of ‘corruption and bribery’ in our own operations
has been identified as new material impact
NN Group N.V. Annual Report 2024 | 126
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Talented people
Contribution to society
Contribution to society
Contribution to society
Engaged customers
Digital and data-driven
organisation
Sustainability matters
Connection with our business model
Our strategic commitments
Connection with our impacts,
risks and opportunities
NN Group aims to create an open, safe and
inclusive working environment. By fostering a
supportive workplace, NN Group ensures that
employees are motivated and engaged.
NN Group invests in our proprietary and client
assets. If these investments are managed
responsibly, they can positively impact the
environment and society.
By creating products and services that address
societal and customer needs, NN Group ensures
relevance and demand in the market at a fair price.
By promoting the rights of workers in our value
chain, NN Group strengthens its reputation as a
responsible partner and enhances trust with
stakeholders.
Value chain role
Own operations
Investments
Products and services
Business partners
• Climate change
• NN workers’ secure and fair employment
• Employee well-being
• Equal treatment and opportunities for all
• Human capital development
• Community investment
• Corporate culture
• Corruption and bribery
• NN Group’s strategic commitment to talented people
requires a values-based culture where colleagues are
empowered.
• NN Group shows its commitment to society by reducing its
CO
2
footprint, promoting employee well-being and upholding
responsible business practices.
• NN Group contributes to society by upholding responsible
investment practices. This can lead to positive outcomes
such as reduced carbon emissions and the advancement of
fair labour practices in the value chain.
• Addressing sustainability-related risks in our portfolio and
seizing climate-related opportunities contribute to the
financial strength of NN Group.
• It is important to keep our products at a fair price point and
develop more sustainable products to keep our customers
engaged.
• When developing our products and services, managing data
responsibly is key to transforming our business into a digital
and data-driven organisation.
• Promoting the rights of workers in our value chain reinforces
NN Group’s commitment to ‘contribution to society’.
• Climate change
• Nature
• Workers in the value chain
• Climate change
• Sustainable repair
• Clear and secure data
• Financial inclusion
• Workers in the value chain
Connecting our sustainability matters to our strategy and business model
NN Group N.V. Annual Report 2024 | 127
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Our approach to the DMA
For the DMA we use both the impact materiality
perspective (‘inside-out’) and the financial materiality
perspective (‘outside-in’) throughout our value chain,
to determine which sustainability matters are
material for our stakeholders. In 2023 we conducted
our first DMA, representing our first steps towards
full CSRD implementation.
This year we updated this assessment based on new
insights, developments and input from stakeholder
engagement. In 2023 we identified relevant
sustainability matters and used scoring to determine
which of these were material. In 2024, we finetuned
the relevant sustainability matters based on new
developments and sector insights, and made the
process specific to our situation and roles as an
insurance company. We actively engaged with
stakeholders to receive insights on which
sustainability matters they deem to be material to NN
Group, and how we as an organisation can better
contribute to decreasing our negative impact and
increasing our positive impact. We consulted internal
experts through expert sessions and external
stakeholders through a sector dialogue. Through
active internal and external stakeholder engagement
we finetuned our sustainability matters and the
associated actual and potential IROs. The overview
on the right shows our DMA 2024 process.
DMA
Refining the long list of ESG topics
at the level of impacts,
risks and opportunities (IROs),
referring to our Human Rights
salience assessment and
reflecting on our Strategic Risk
Assessment (SRA).
List of topics refined and updated
based on new insights and some
name changes.
Dialogues with internal experts per
business role or ESG differentiation.
Validation of refined list of
sustainability matters, possible new
clusters, and insights into changes in
the market or on sustainability matters
since last year’s expert sessions.
External stakeholder engagement
at sector level provided insights
into the role of insurers from an
ESG perspective and was
dedicated to environmental and
social topics.
External stakeholder engagement
dialogue.
Identify relevant
sustainability matters
Assess IROs and internal
stakeholder consultation
External stakeholder
dialogue
Consolidation and
validation of results
NN Group’s process to validate and refine the DMA
Refined list of sustainability
matters to the level of
impacts, risks and
opportunities (IROs).
Consolidating DMA results
and validating these
internally with the
Management Board.
Results impact the CSRD
disclosures 2024.
Integrating feedback on DMA
results into core DMA 2024
and IROs definition.
Refined list of DMA subjects across
NN roles
External stakeholder dialogue
Consolidate DMA results
Validate DMA results
Core DMA results
Key takeaways of the
process will be further
integrated in the DMA 2025.
The 2023
DMA process
and results
formed the
basis for the
2024 DMA
process.
Double Materiality Assessment process 2024
NN Group N.V. Annual Report 2024 | 128
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Our roles in the value chain
During the DMA process we considered actual and
potential impacts, positive and negative impacts, and
financial risks and opportunities across our value
chain. We looked at our different roles and how they
link to the applicable sustainability matters, enabling
us to specifically identify where material IROs occur
in our value chain.
• For our own operations, we looked at own
operations around employees for the social topics,
and our buildings and business travel for
environmental topics. We also assessed our own
operations in terms of governance.
• For our investments, we looked at the potential
impact and the risks and/or opportunities incurred
through our investment activities.
• For our role as financial services provider, we
examined the products and services offered by our
Life, Pension and Non-life businesses and by NN
Bank.
• Finally, as business partner, we focused on our
upstream and downstream collaborations and
procurement activities, as well as our
collaboration with financial advisors and repair
networks. See p. 124 for more information on our
value chain.
Stakeholder engagement
We involve stakeholders in our DMA to identify which
sustainability matters they consider most likely to be
material for NN Group. We identify our key
stakeholders based on their potential to affect or be
affected by our activities. We also engage with
stakeholders who may have relevant knowledge
about specific sustainability matters. The group of
stakeholders we engage with as part of the DMA
process is not static and can be adjusted depending
on the topics of the dialogue and how they develop
over time. In the 2024 DMA process we invited
internal experts on the sustainability matters we had
identified across our different roles to share their
qualitative input on the sustainability matters.
On top of our regular stakeholder engagement
efforts, reflected by these expert sessions, and in
collaboration with the Dutch Association of Insurers
(Verbond van Verzekeraars), we invited our peers to
join us in a dialogue on sustainability matters. This
reflects the value we place on broader discussion
within the insurance sector on where the sector has
the most impact. We believe collaboration to be
important in reducing our negative impact and
achieving our targets, and therefore valued this
particular collaboration where stakeholders had the
opportunity to share their thoughts on the broader
insurance sector.
The session included dialogue with several NGOs and
societal organisations representing different
stakeholder groups, sharing their views on selected
sustainability matters such as social topics in the
value chain, nature and climate change, and
customers. This was a useful exercise for us. Not only
did we further our knowledge on social and
environmental topics but also discovered that the
sector shares similar challenges in taking the DMA
process to the next level. These challenges include a
lack of quality ESG data (and data availability in
general), balancing different stakeholder
expectations, prioritising sustainability matters in the
different roles we hold in the value chain, and the
dilemma of balancing environmental and social
topics.
Input from stakeholders further enhances our DMA
process by helping identify topics that could be
material to NN Group. During the event, two topics in
particular were discussed extensively: addressing
human rights impacts in the value chain, especially
for an investment portfolio, and the increasing
importance of impacts on biodiversity. We have
integrated the outcomes of the session into our
assessment of sustainability matters.
How our approach has changed
In July 2023 we conducted our first DMA. This year,
in October 2024, we validated the outcomes and
finalised the process. The main changes to our
approach to identifying sustainability matters since
last year are:
• validating the survey results of the previous year
with internal experts;
• re-evaluating and consolidating the results with
the salience assessment;
• focusing on ESG sustainability matters, and
aligning with NN Group strategic risk assessment;
• finetuning ESRS-prescribed sustainability matters
to make them more specific to our own business;
• formulating and validating descriptions of the IROs
for each sustainability matter from the
perspectives of different roles in NN Group; and
• collaborating with peers and societal
organisations by organising an external
stakeholder session on the DMA and ESRS topics.
Identifying sustainability matters
We used the sustainability matters identified in 2023
as a starting point for the 2024 DMA. We again
performed a desk research and analysis of internal
and external sources to identify new sustainability
matters. These internal sources included the salience
assessment, which focuses on human rights impacts.
Our desk research looked at external standards, peer
reports and sector trends. This exercise resulted in a
list of sustainability matters to be validated internally
in expert sessions.
This year we enhanced our list with definitions of
sustainability matters specific to NN Group and/or the
financial service industry and/or the insurance sector,
and added these to the DMA. By so doing, we
improved our definitions of sustainability matters,
making them more specific to our business. This
created the basis for our sustainability matters short
list. This year we added NN Group-specific IRO
descriptions, resulting in more clarity in both the
definitions and the specific IROs.
Assessing materiality
For our 2023 DMA , we carried out an internal survey
to assess the impact materiality and financial
materiality of the consolidated sustainability matters.
The survey was completed by members of NN
Group’s Management Board, Supervisory Board and
Works Council, as well as senior managers, internal
NN Group N.V. Annual Report 2024 | 129
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We based salience on severity and likelihood, taking
severity as the primary and leading factor and
likelihood as the secondary factor. In the
assessment, we considered severity from the
perspective of affected people, i.e. risks to people,
not business. To assess severity, we held voting
sessions with relevant stakeholders on the scale,
scope and irremediability of an impact, asking them
to rate it from one to four, with ‘one’ being least
severe and ‘four’ most severe. We used a similar
scale to assess likelihood, based on external and
internal data and engagement with relevant
stakeholders. As we found the 2023 results of the
2023 salience assessment to still be representative
of our business activities and risks to people, we did
not update the assessment in 2024 to use as input
for the DMA. We have linked the results of the
salience assessment to the DMA sustainability
matters and applied them to our operations.
Financial materiality
In 2023 we assessed the materiality of our
opportunities based on a combination of how likely
they were to occur and the size of the possible
financial effect. Only those opportunities that fell
above a defined maximum threshold for both
likelihood and size of financial effect were deemed
material in the financial materiality assessment.
Respondents were able to score sustainability
matters both from an impact perspective and an
opportunity (financial impact) perspective. As our
DMA resulted in the identification of an opportunity
that is linked to our strategic targets for climate
solutions, the same time horizon applies to that of
the strategic target.
In 2024, we further finetuned the 2023 results by
having expert sessions with different internal parties,
including Finance, Risk and the Investment Office to
further qualitatively validate opportunities and risks
related to sustainability matters. We also compared
results of the DMA with the regular risk assessment
processes that NN Group undertakes, such as the
Strategic Risk Assessment (SRA) and Climate Risk
Assessment (CRA). Based on this, several changes
were made to risks/opportunities identified, as well
as their descriptions. For the risks, we relied on the
outcomes of these assessments. In these risk
assessments, prioritising was done through selection
of the key risks from a long list of risks. We did not
identify any material risks on the short-term horizon.
The experts who completed the survey were asked to
assess materiality from an impact and financial
perspective, but not how they are linked to each
other. We did consider the negative impact on climate
change in connection with our identified risk and
opportunity, see ‘DMA process 2024’, p. 127. This
showed us that IROs can be viewed from different
angles, and may be connected, given NN Group’s
different roles in the value chain.
applicable to negative impacts). Here, we also
assess the magnitude of the impact.
When assessing potential impact, we also evaluated
how likely it was for the impact to occur. In 2023 we
did this by using a scale of one to five. When we
assessed our impacts with internal and external
stakeholders, we took account of the fact that even
though we might have policies, remedies or
processes in place to help prevent negative impact,
there is still a potential for negative impact to occur.
This is an important assumption in our methodology
as it has resulted in certain sustainability matters and
impacts being material due to their likelihood. It also
reflects our realisation that there may be elements in
our qualitative assessments that we cannot (yet)
determine precisely. In the 2024 update, we
considered whether an impact was actual (almost
100% certain to occur, which we could know by it
already having occurred or been reported), or
potential (if the effect of the impact had not occurred
but indirect reporting/market insights indicated that
it may occur in the future). In our approach, we
aligned the horizons of the impacts with our strategic
targets as well but did not specify the horizon for
each impact. For investments, we used a long-term
horizon.
Salience assessment
We used the 2023 salience assessment, which
focused on the salient human rights issues, as input
for measuring our negative social impacts. (For more
information on these issues see ‘Social’, p. 179).
Below, we explain how we rated the materiality of
negative social impacts.
experts and employees. We asked the stakeholders
to select ten sustainability matters they found most
likely to be material for NN Group and to rate them
according to impact materiality and financial
materiality. We also asked external stakeholders to
score NN Group’s actual or potential negative impact
on a variety of social matters linked to our value
chain. These stakeholders included NGOs, human
rights experts, industry organisations, regulators,
ESG rating agencies and peer experts. This year we
asked internal experts to evaluate last year’s topics
during internal dialogues and used the scores to
refine the material topics for 2024. As we hope data
availability is increasing, we plan to continuously
improve our process and input for identifying IROs
based on relevant data.
Impact materiality
We define a sustainability matter as being material
from an impact perspective when NN Group creates
actual or potential material impact on people or the
environment. Impact can either be positive or
negative, and short-, medium- or long-term. In our
2024 approach, we combined short and medium
term, indicating an impact (potentially) occuring
within five years. ‘Long term’ referred to more than
five years.
We assess the severity of our actual and potential
impact according to scale, scope and irremediability,
in other words evaluating how big the positive or
negative impact is for people or the environment,
how widespread it is, and to what extent the
negative impact could be remediated (only
NN Group N.V. Annual Report 2024 | 130
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Topical sustainability matters
Environmental topics
Climate change
Own operations
NN Group acknowledges its impact on climate
change through its attributable GHG emissions. We
monitor those associated with our organisation’s
activities, which include direct emissions from our
own operations and indirect emissions linked to our
investment portfolio and underwriting activities. For
our own operations, we focus on our scope 1, 2 and 3
emissions and the associated targets we have set for
those operations.
Service provider
In assessing climate change impact we looked at
products and services in a qualitative manner and
integrated data where available. We evaluated our
core business as an insurance company,
acknowledging that while we provide products and
services that contribute to a healthy economy we
also insure companies and individuals that have a
potential negative impact on climate change. By
insuring those companies and individuals we could
indirectly support activities contributing to climate
change via their GHG emissions. By providing
insurance products and services we also identify a
potential positive impact as we can further enable the
transition to a sustainable economy through
engagement with and by offering financial support
and insurance for companies with low-carbon-
intensive activities.
investments in economic activities that contribute
substantially to climate change mitigation or
adaptation. In relation to investments, we mainly
considered a long-term time horizon, with a milestone
in 2030. As a step in classifying climate solutions
investments, and in line with guidance from the IIGCC
Paris Aligned Investment Initiative and UN-convened
Net-Zero Asset Owner Alliance, climate solutions
focus on SDG 7-related areas of energy efficiency and
renewable energy. Definitions are supported with
external certifications, asset labels and environmental
standards, where possible and relevant.
The material opportunity of climate solutions is linked
to our investment strategy, as well as to the
potentially higher risks involved in the transition to a
lower-carbon economy. A gradual shift from carbon-
intensive to renewable energy assets will help to
mitigate any risks that may be caused by activities
with negative climate impact, while leading to
potential returns from a switch to activities that have
a positive impact.
Nature
We identified our material IROs with regard to nature
(biodiversity and water), by using the ENCORE
assessment to assess the impacts and dependencies
of our corporate investment portfolio. We also
engaged with peers and joined other collaborative
engagement efforts to gain further insights into these
material topics. We did not consider our own
locations in assessing our impact as our investment
activities are more material. Also, as part of our
external stakeholder dialogue we discussed the topic
of biodiversity and used this as input for our
identification of IROs. See ‘Environment’ on p. 134
for more information on these processes.
Circular economy and sustainable repair
Our insurance products and services make us part of
the real economy and we aim to use our influence
where we can to make an impact. We screened
activities in our own operations as well as in our roles
as investor, products and services provider, and
business partner, in relation to resource use and
circular economy; and identified sustainable repair as
an area where we can make impact. We prioritised
this topic in our materiality assessment over more
generic ESRS topics such as resource inflows,
resource outflows and waste. Our sustainable repair
network was identified as a material positive impact
in the value chain of our Non-life insurance business,
linking it to the ESRS topic ‘circular economy’.
Social topics
Own workforce
We care for our employees and consider the impact
we have on them and have built on internal tools to
analyse material sustainability matters with regard to
our workforce. When we looked at our Diversity &
Inclusion (D&I) strategy, our efforts to enable our
employees to continuously learn and develop
themselves, as well as our employment benefits, we
found positive impacts. We used the outcome of the
salience assessment to identify our potential
negative impacts on employees.
Investments
When evaluating the carbon footprint of our
investment portfolio, we focus on NN Group’s
proprietary assets, (i.e. the investments we hold for
our own account).
We strive to align with internationally recognised
standards in our carbon footprint methodology, such
as the Global GHG Accounting and Reporting
Standard for the Financial Industry, from the
Partnership for Carbon Accounting Fiancials (PCAF).
We apply the corresponding PCAF standards to both
our financial emissions and insurance associated
emissions.
Where feasible, the analyses take into account
relevant short-, medium- and long-term scenarios
aligned with the recommendations of the TCFD. The
insights gained serve as further input for formulating
our investment strategy and integrating climate
change issues into our risk management practices.
As a signatory to the Paris Aligned Asset Owner
Commitment, we express our ambition to support the
global transition towards net-zero GHG emissions by
2050, in line with efforts to limit global warming to
1.5°C. Therefore our approach to align the proprietary
investment portfolio to the goals of the Paris
Agreement is guided by the Institutional Investors
Group on Climate Change (IIGCC) Net-Zero
Investment Framework.
One of the key dimensions of this approach is
investing in climate solutions, which we identified as a
material opportunity. We define ‘climate solutions’ as
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General disclosures
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Investments and business partners
We used the outcomes of the salience assessment to
identify our negative impacts on workers in the value
chain, considering both upstream and downstream
value chains. For our role as investor, we focused on
downstream activities to identify our negative
impacts on social sustainability matters. For our
business partner role we identified material negative
impacts that could affect workers upstream in our
value chain, such as our suppliers for our own
operations.
Customers
For our role as service provider, we took into
consideration our Non-life as well as our Life and
Banking products. Again, the outcomes of the
salience assessments were used to identify our
material negative impacts on our customers.
Governance topics
During the process of identifying material IROs in the
area of governance, we looked at how we conduct
business in the insurance industry in Europe
(including banking) and Japan, taking into account
the global corporate culture we aim to establish.
Consolidating and validating sustainability
matters
We identified which sustainability matters are
material from the perspective of our different roles in
the value chain. To validate these sustainability
matters, we held internal sessions on several topical
standards with experts and senior managers from
Legal, Compliance, Risk, Finance, Corporate
Citizenship, Investment Office, HR, Procurement,
Our future approach
Going forward, having improved the 2023 DMA
process this year, we will actively seek assessment
practices to prioritise the IROs and substantiate them
with ESG data. This way we hope to further improve
and finetune the DMA to our specific situation and
identify where we can make the most impact. We will
investigate further alignment opportunities internally
with different IRO assessments and incorporate
tooling. We strive to enhance our impact assessment
through a more detailed sustainability due diligence
process, value chain insights, and further exploration
of the use of internal and external databases. Looking
back on our external stakeholder session with the
Dutch Association of Insurers, we acknowledge the
added value of sector co-operation and peer learning,
and will seek further engagement with stakeholders
to enhance our sustainability and business strategy.
Facility Management, Life, Non-life and International.
These representatives play a key role in identifying
and assessing the IROs, and are responsible for
monitoring them. We adjusted our descriptions of the
IROs related to the sustainability matters based on
their insights.
We did not carry out a detailed survey to score the
topics, as we did in 2023, but built on the 2023 data
in the validation sessions with experts; this
assessment was done on a qualitative basis. This
year we integrated existing assessments into our
methodology for defining our sustainability matters,
such as the salience assessment and strategic risk
assessment. Our goal is to optimise these processes
and look at how we can include more quantitative
analysis in the future, to substantiate our IROs.
Approving sustainability matters
To approve the sustainability matters, we first
presented our materiality assessment process and
its outcomes to the former Purpose Council, which
was able to identify areas for concern. We then
included Risk’s second-line opinion in our
presentation to the Management Board, which
approved both the sustainability matters and our
assessment approach. The Management Board
approved the strategic risk assessment separately,
before we integrated the results of the assessment.
Finally, the Supervisory Board and the Supervisory
Board’s audit committee evaluated the outcomes
based on the concept of information materiality of our
initial sustainability matters, which resulted in the
final list of sustainability matters.
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Due diligence process references
Core elements of due diligence Location of disclosures
a) Embedding due diligence in
governance, strategy and
business model
– Governance - Corporate governance - Sustainability governance: p. 77-80
– Governance - Remuneration Report - Remuneration of the Executive Board: p. 107-113
– Sustainability statement - General Disclosures - Integrating sustainability into our
strategy: p. 122-123
– Sustainability statement - General Disclosures - Connecting our sustainability matters
to our strategy and business model: p. 126
– Sustainability Statement - Social - Introduction: p. 179-182
b) Engaging with affected
stakeholders in all key steps
of the due diligence
– About NN - Our values and behaviours: p. 7-8
– Our strategy and business - Stakeholder engagement and international commitments:
p. 35-38
– Governance - Corporate governance - Sustainability governance: p. 77-80
– Sustainability statement - General Disclosures - Our approach to the DMA -
Stakeholder engagement: p. 128
– Sustainability Statement - Social - Introduction - Human rights: p. 181-182
– Sustainability statement - Social - Own workforce - Monitoring progress on material
topics: p. 188-189
– Sustainability statement - Social - Workers in the value chain - Processes - Identifying
and addressing impacts: p. 196-198
– Sustainability Statement - Social - Consumers and end users - Processes for engaging
with customers: p. 204-205
– Sustainability statement - Annex - List of policies: p. 215-221
c) Identifying and assessing
adverse impacts
– Sustainability statement - General Disclosures - Our approach to the DMA - Assessing
materiality: p. 128-129
– Sustainability statement - General Disclosures - Topical sustainability matters:
p. 130-131
– Sustainability Statement - Environment - Introduction - Environmental material
matters: p. 135
– Sustainability Statement - Social - Introduction - Social material matters: p. 180
– Sustainability Statement - Social - Introduction - Sustainability matters: p. 181
– Sustainability statement - Social - Workers in the value chain - Processes - Identifying
and addressing impacts: p. 196-198
– Sustainability Statement - Governance - Introduction - Governance sustainability
matters: p. 208
Core elements of due diligence Location of disclosures
d) Taking actions to address
those adverse impacts
– About NN - Our values and behaviours : p. 7-8
– Governance - Our Code of Conduct and other policies: p. 115-118
– Sustainability statement - Environment - Climate change - Approach - Own operations
- Transition plan/Actions: p. 136-138
– Sustainability statement - Environment - Climate change - Approach – Investments -
Transition plan/Actions: p. 138-140
– Sustainability statement - Environment - Climate change - Approach - Insurance
underwriting - Transition plan/Actions: p. 143-144
– Sustainability statement - Environment - Nature (biodiversity and water) - Approach
- Transition plan/Actions: p. 167-168
– Sustainability Statement - Social - Introduction - Social roadmap: p. 182
– Sustainability statement - Social - Equal treatment and opportunities for all at NN:
p. 183-185
– Sustainability statement - Social - Workers in the value chain - Processes: p. 196-198
– Sustainability statement - Social - Consumers and end-users - Processes to remediate
negative impacts and for raising concerns/Actions: p. 206
– Sustainability statement - Governance - Prevention and detection of corruption and
bribery: p. 209
e) Tracking the effectiveness of
these efforts and
communicating
– About NN - Our values and behaviours - Monitoring effectiveness: p. 8
– Governance - Our Code of Conduct and other policies: p. 117
– Sustainability statement - Environment - Climate change - Approach - Own operations -
Targets: p. 138
– Sustainability statement - Environment - Climate change - Approach - Investments -
Targets: p. 140-143
– Sustainability statement - Environment - Climate change - Approach - Insurance
underwriting - Targets: p. 144-145
– Sustainability statement - Environment - Climate change - Progress: p. 145-158
– Sustainability statement - Environment - Nature (biodiversity and water) - Approach -
Targets: p. 168
– Sustainability statement - Social - Own workforce - Monitoring progress on material
topics: p. 188-194
– Sustainability statement - Social - Workers in the value chain - Targets: p. 198
– Sustainability statement - Social - Consumers and end - users - Actions: p. 206
– Sustainability statement - Governance - Prevention and detection of corruption and
bribery: p. 209
Statement on due diligence
Due diligence process
NN Group’s due diligence process refers to how we identify, prevent, mitigate and account for our actual and
potential negative impact on sustainability matters. The table below links the core elements of this due
diligence as defined in the CSRD to the relevant disclosures in this Annual Report.
Operational management tests
to see if controls are correctly
designed and executed
Control functions perform
risk-based monitoring to
assess the quality of the
work by the first line
Internal auditors perform
independent assurance
procedures on the sustainability
reporting process
Identification of risks that
could lead to material
misstatements in
sustainability reporting
Risk prioritisation based on
magnitude and likelihood
Design risk controls based on
type of risk, level of priority and
where in the process it occurs
Control assessment
Evaluate deficiencies and remediating actions, and report effectiveness of control to
Executive Board and Management Board
Risk identification Risk assessment Risk mitigation
Second line
First line
Third line
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Risk management and internal
controls
NN Group considers risk management and the setting
up of internal controls over sustainability reporting a
vital part of our risk monitoring process. As a result,
we follow a regular and transparent sustainability
reporting risk process. Our control framework scope
covers the internal processes, including outsourced
activities, that create the information as disclosed in
our Sustainability Statement. Our control framework
determines the scope of the risk management and
internal control process for the sustainability matters
that are part of our sustainability reporting. For these
matters, our business units and Group functions
identify and assess those risks that could lead to
material misstatements in our reporting, as well as
develop controls to mitigate such risks.
Throughout the reporting process, we consider
internal control assertions, such as completeness
and accuracy, to assess potential risks. Based on the
risk assessment, we identify areas with elevated risk
profiles and prioritise risk based on the magnitude
and likelihood of a misstated sustainability
disclosure.
We have designed controls based on the type of risk,
its level of priority and where in the process it occurs.
When designing a control, we consider what type of
control will be most appropriate for the process
involved, for example manual or automated,
preventative or detective. Areas with elevated risk
profiles receive additional scrutiny during the review
process from, for example, internal experts and
members of the Management Board.
To assess the controls, we use the three lines model.
The first line involves operational management
carrying out a Test of Design and Test of Effectiveness
to establish whether the controls were correctly
designed and executed. In the second line, control
functions such as operational risk management
perform risk-based monitoring, separately assessing
the quality of the work carried out by the first line.
The third line involves internal auditors performing
independent assurance procedures on the
sustainability reporting process if this is considered
necessary. Based on the lessons learned from
preparing the Sustainability Statement for the first
time, all lines will be strengthened in 2025. Local
teams develop controls themselves, based on their
specific risks and circumstances, but also follow
recommendations based on the risk assessment
performed at Group level.
Based on first-line testing results and second-line
quality assessment, business units and Group
functions evaluate all deficiencies and remediating
actions. The Management Board evaluates control
testing on quantitative metrics and qualitative
disclosures once a year. All material deficiencies, or
deficiencies that do not have a compensating control,
are reported to and evaluated by the Management
Board.
Contents
Climate change 136
Approach 136
Own operations 136
Investments 138
Insurance underwriting 143
Progress 145
Own operations 146
Investments 148
Insurance underwriting 156
Anticipated financial effects 159
Nature (biodiversity and water) 167
Sustainable repair 169
EU Taxonomy
disclosures 170
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Environment
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
The financial sector has an important role to play in
facilitating the transition to a sustainable economy
and we are committed to playing our part.
We incorporate climate action across our business
– our investment and banking activities, insurance
underwriting activities and own operations. We
believe this approach will not only benefit the
environment but also create sustainable long-term
value for all our stakeholders.
However, our sustainability approach extends beyond
climate. Through our Double Materiality Assessment
(DMA), we identified four environmental material
matters across our value chain: climate change,
nature (biodiversity and water) and sustainable
repair. We disclose our approach to these in the
Environment sub-sections. In the table on the next
page, we give descriptions of the identified impacts,
risks and opportunities (IROs) across our value chain
for each area.
Environment
In addition to the sub-sections covering our approach
to these environmental material matters, we disclose
our EU Taxonomy figures (see p. 170). The EU
Taxonomy Regulation requires NN Group to disclose
information on its taxonomy-eligible and taxonomy-
aligned activities. In our EU Taxonomy disclosure we
provide information related to our investments and
underwriting activities.
Environmental material matters
Climate change adaptation
Nature (biodiversity and water) Sustainable repair
Investments
Own operations
Products and services
Climate change mitigation
Climate change
Nature
Sustainable repair
With our insurance activities we insure activities
from companies and individuals that have a
potential negative impact on climate change. By
providing insurance, we may have a potential
negative impact by indirectly supporting the
activities that contribute to climate change via GHG
emissions or environmental degradation.
NN Group has a potential positive impact in our
response to climate-related disasters, as we play an
important role in providing the financial support
needed for recovery and rebuilding efforts. Our
products and services help communities to recover
faster, and can be directed towards more resilient
reconstruction in alignment with a low-carbon
economy.
By focusing on repairing items via our sustainable
repair network we have a potential positive
impact by extending the life of products,
substantially decreasing waste and reducing the
demand for new materials.
By investing in climate change adaptation solutions
we have a potental positive impact on the
environment. Through influencing the behaviour of
individuals and businesses, we aim to incentivise
the adoption of adaptation measures, helping us
reduce our risk of negative impacts due to climate
change.
We have identified a risk of financial losses to
investments, and/or lower investment returns,
because of the physical impacts of climate change,
such as extreme weather events and rising sea
levels, and the risks involved in a transition to a
lower-carbon economy.
We have a potential negative impact on climate
change by investing in industries that harm the
environment. Such investments might facilitate
GHG emissions and other harmful environmental
effects, making NN Group indirectly responsible for
these negative outcomes.
By investing in sustainable projects and companies
that contribute to climate change mitigation we
have a potential positive impact on climate
change mitigation. This can lead to positive
environmental outcomes and generate returns
aligned with a low-carbon future.
We have identified a risk of financial losses to
investments, and/or lower investment returns,
because of the physical impacts of climate change,
such as extreme weather events and rising sea
levels, and the risks involved in a transition to a
lower-carbon economy.
We have identified a financial opportunity from
increasing our investments in climate solutions as
part of our strategy to contribute to the transition to
a low-carbon economy. Broadening our investment
opportunities can potentially lead to better
investment outcomes.
Through our corporate investment portfolio
exposure, we have an potential negative impact
on nature-related factors driving biodiversity loss.
This means that some of our investments may
contribute to activities that harm ecosystems and
reduce biodiversity. We have identified negative
impacts on land degradation, desertification and
soil sealing based on sector hotspots.
Positive impact
Negative impact
Financial opportunity
Financial risk
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
We identified a potential negative impact
concerning emissions from buildings (scope 1),
energy consumption (scope 2) and air travel
(scope 3). These activities contribute to greenhouse
gas (GHG) emissions, which can negatively affect
the environment by driving climate change.
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insurance underwriting by 2050. Although we have
not yet identified decarbonisation levers as such, we
have defined actions across our value chain aimed
at reducing our GHG emissions and accelerating the
transition to net zero. The Climate Action Plan can be
found on our website.
Sustainability, and therefore our climate change
approach as described in our Climate Action Plan, is
embedded in our governance and strategy. We have
developed a governance structure that enables the
Executive Board, Management Board and Supervisory
Board, as well as senior management, to integrate
climate-related action into strategy, decision-making
and business processes. More information on our
governance and strategy can be found on p. 80.
Implementing measures to mitigate the risks and
impacts of climate change is ongoing, and we will
continue to expand solutions for customers to help
them become more climate-resilient and adapt to our
changing environment.
The Climate Action Plan will be updated on a regular
basis to reflect the latest developments and we
intend to evolve it into a Transition plan. We also
aim to address the gaps in areas that are not yet
implemented, such as the quantification of the
required investments, an assessment of the locked-
in emissions and the expected reduction in GHG
emissions linked to the decarbonisation levers and
actions.
Climate change
Climate change is one of today’s most pressing
challenges. We have committed to aligning our
business activities with the goals of the Paris
Agreement to limit global warming to 1.5°C.
Approach
In July 2019, we signed the commitment of the
financial sector to the Dutch Climate Agreement,
pledging to make a contribution to the financing of
the energy transition, to disclose the carbon footprint
of our proprietary investments and to publish a
Climate Action Plan.
Our Climate Action Plan, approved by our
Management Board, describes our approach to
reducing the adverse impact of climate change
on people and the environment. The approach is
based on helping to accelerate the transition to a
low-carbon economy, and developing and offering
products and services that help address the
environmental challenges of customers. The related
policies, processes, targets, actions and metrics we
have developed allow us to measure our progress
toward net-zero emissions.
The Climate Action Plan includes targets for reducing
greenhouse gas (GHG) emissions. We have set
separate net-zero targets for our own operations
by 2040, and for our proprietary investments and
Although EU Taxonomy-alignment and the respective
KPIs are not fully integrated into our transition
planning, NN Group has taken into account the
EU Taxonomy, on a ‘best effort’ basis and where
possible, when investing in climate solutions. See
the EU Taxonomy disclosures on p. 170 for further
information about eligibility and alignment of NN
Group’s economic activities and how they are
expected to evolve over time.
Through our DMA we have identified two climate-
related material matters: climate change mitigation
and climate change adaptation. The upcoming
sections elaborate on our climate-related approach,
the targets we have set and the progress we
have made in the areas of investments, insurance
underwriting and own operations. Additionally, in
the final part of this section, we describe our process
for evaluating both the physical and transition risks
associated with climate change.
Own operations
In line with our objective to contribute to the
transition to a low-carbon economy, we have set
a net-zero target for emissions related to our own
operations. As a financial services provider, we
operate mainly in an office environment. Therefore
the direct environmental impact from our own
operations is relatively limited. Nevertheless, we
have an ambition to treat the environment with
respect, and to inform, and strengthen engagement
with, our stakeholders. NN Group is not excluded
from the EU-Paris aligned Benchmarks
1
.
Transition plan
We aim to effectively manage our direct
environmental footprint by reducing our use of
natural resources, seeking green alternatives and
offsetting the remainder of our GHG emissions.
We aim for net-zero GHG emissions of our own
operations by 2040, in line with the Paris Agreement.
We have set interim reduction targets for 2025 and
2030 across three emissions scopes:
• scope 1 – GHG emissions mainly resulting from
the use of our office buildings,
• scope 2 (market-based) – GHG emissions mainly
from purchased electricity in our office buildings,
• scope 3 – GHG emissions from business air travel.
We acknowledge the existence of other upstream
scope 3 GHG emissions in our value chain, such as
from employee commuting, purchased goods and
services, and waste, and we have introduced several
initiatives to reduce these emissions. However,
based on the outcome of the 2024 DMA, these
emissions are not considered material in the context
of information materiality, and compared to the
impact of investments, and products and services.
That is why we include no further details on these
GHG emissions here. To read more on what we do
with our own operations and business partners, see
our website.
NN Group operates in ten countries
2
and we have
office buildings in several locations. For those in the
Netherlands, we aim to reach net zero by 2040 by
adhering to the Paris Proof building standards, which
1
To determine whether NN Group is excluded from the EU-Paris aligned Benchmarks, only the sectors in which NN Group directly operates
were considered. This means that the investments and underwriting activities of NN Group were not considered.
2
Turkey was divested in January 2025.
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were set up by the Dutch Green Building Council
(DGBC). The DGBC’s Paris Proof standards align with
the Paris Agreement by aiming to reduce the energy
consumption of buildings by two-thirds, ensuring
that the built environment operates within the CO₂
budget necessary to limit global warming to 1.5°C.
We are drawing up local action plans to align our
international office buildings with this commitment.
In terms of our buildings, we take two types of
emissions into account when considering a transition
to net zero: embodied emissions (from buildings and
office renovation), and operational emissions (related
to everyday office use, such as energy). For embodied
emissions, we have developed a renovation
strategy for net-zero office spaces. For operational
emissions, we are working towards reducing energy
consumption to 70 kWh per square metre per year,
aligned with DGBC standards. We take a threefold
approach to this:
1. reduce energy consumption – implement energy-
efficient systems and practices to lower energy
use by two-thirds,
2. enhance insulation – improve building insulation
to minimise energy loss,
3. use renewable energy – transition to renewable
energy sources such as solar and wind power.
NN Group uses a targeted approach to achieve net-
zero GHG emissions for business air travel by 2040.
The countries we operate in tailor their policies and
practices to the local context.
plans in line with our net-zero ambition. While
the creation of action plans is ongoing, reduction
measures have already been taken. As an example,
our initiatives to reduce office building emissions
focus mainly on switching to renewable energy
sources and adopting energy-efficiency measures.
For our office buildings in the Netherlands, we have
taken the following actions:
1. For the renovation of our head office in The
Hague, planned for 2025 to 2028, we are taking
actions in line with our Sustainable Renovation
policy (Duurzaamheidsraamwerk renovaties
Nationale-Nederlanden). These include, for
example, ‘circular renovation’ which aims to
maximise the use of products and materials that
are already present in our offices and minimise
the use of new products/materials. If we do need
to use new materials, we use bio-based materials
where possible.
2. To ensure reduced energy consumption, in
2024 we implemented measures that included
energy-efficient indoor temperature control, the
installation of timed switches for office equipment
and the closing of floors on quiet weekdays. We
will extend these in 2025.
We also monitor and optimise day-to-day energy
use, together with energy monitoring partner CFP
Green Buildings. Based on our actual use, which
we monitor on a quarterly basis, we assess what
additional reduction measures are needed per
building to reduce our CO
2
impact. Since we are
often housed in multi-tenant buildings, we do not
always have full control over the entire location,
Policies
We have developed a range of policies to help
mitigate our negative climate change impact
and support our goal of achieving net-zero GHG
emissions from our own operations by 2040. One
example is our Sustainable Renovation policy, which
includes measures aimed at reducing our embodied
GHG emissions. (See details below, under ‘Actions’.)
NN Group expects employees to adopt a responsible
and pro-active attitude to reducing emissions in
all types of business travel, including air travel. To
encourage this, in 2024 we introduced an updated
business travel policy, the Global Business Travel
Guideline, setting out expectations and guidelines
for business travel abroad, including the requirement
to assess the need for travel. If travel is considered
necessary, we expect the employee(s) to choose the
most GHG-efficient option. The policy also includes
the aim not to use air travel for distances below 700
km, if possible and reasonable. This policy applies to
all employees and other individuals working under
the responsibility of NN Group in the Netherlands,
which may include freelancers and temporary
workers. It also details the minimum standards to
be upheld, as far as possible and reasonable, for
NN Group employees outside the Netherlands. This
policy needs to be considered by countries who have
set, or will set, their own country-specific guidelines.
Actions
Our buildings
Given that the countries we operate in vary in
their potential for reducing GHG emissions, we are
developing country-specific, GHG-reduction action
but we implement as many reduction measures
as possible on our rented floors. We have also set
up agreements with landlords to optimise energy
use for each respective building.
3. We have switched to purchasing green
electricity in a further effort to reduce our
operational GHG emissions.
Business air travel
To reduce emissions related to business air travel,
we introduced an updated business travel policy at
the beginning of 2024 (see ‘Policies’ above). Other
options to reduce GHG emissions from business
travel focus on alternatives such as organising online
meetings and replacing air travel with low-carbon
transport. We have also extended the hybrid way of
working, which encourages employees to regularly
work from home, limiting the need for business
travel.
As we move towards becoming net zero with our
own operations, we will continuously monitor our
progress across the value chain and assess the
effectiveness of our reduction strategies and actions.
Carbon credit offsetting
In addition to our GHG emission reduction efforts,
we will compensate part of the GHG emissions
from our own operations through the purchase of
carbon credits. We have engaged in GHG emissions
offsetting by funding external carbon removal
projects since 2014. This contributes to the
compensation of our scopes 1 and 2, and scope 3
(business air travel) emissions.
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Environment
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
In 2021, NN Group started to cooperate with South
Pole and selected a third party-validated and -verified
forest conservation project in Peru. In 2024 we
chose to support an additional project, the Kuamat
Rainforest Conservation in Malaysia. Both adhere
to the Verified Carbon Standard (VCS) and Climate,
Community & Biodiversity (CCB) Standards. The
conservation projects support emissions reduction,
and contribute to a positive impact on communities
and the environment by protecting biodiverse
habitats.
In 2024, ten kilotonnes (kt) CO
2
were compensated
by carbon credits. More details can be found in
the table below. Going forward, we will refine and
strengthen our carbon credit offsetting approach.
GHG emissions compensated by carbon credits
2024 2023
Total GHG emissions
(ktCO
2
e) 10 10
Share from reduction
projects 100% 100%
Recognised quality
standard (VCS) 100% 100%
Share from projects within
EU 0% 0%
Targets
In 2021, NN Group established science-based
GHG reduction targets. These align with the level
of decarbonisation needed to keep a rise in global
temperatures to below 1.5°C, as outlined in the
Paris Agreement. We aim to achieve net-zero GHG
emissions with our own operations by 2040, in line
with the goal to support the transition to a low-
carbon economy, and have set interim reduction
targets for 2025 and 2030 across scopes 1 and
2, and scope 3 (business air travel). Setting both
long- and medium-term targets, and referring to
documentation by the Paris Agreement and the
Intergovernmental Panel on Climate Change (IPCC),
underscore our efforts to contribute to climate
change mitigation.
Investments
Transition plan
As an investor, we understand the crucial role of
mitigating climate change and have developed a
comprehensive transition plan to achieve net-zero
GHG emissions by 2050 for our proprietary assets
portfolio. Our proprietary assets are the investments
included in the NN Group consolidated balance
sheet and held for our account. Our approach to
align our investment portfolio with the goals of the
Paris Agreement (limiting global warming to 1.5 C)
is guided by the Net Zero Investment Framework
(NZIF). The plan focuses on two key pillars:
1. decarbonisation of the investment portfolio in line
with net-zero pathways,
2. increasing our investments in climate solutions.
Own operations: GHG emissions reduction targets
We aim to reduce GHG emissions from our own operations, compared to 2019 by:
35% 70% net zero
in 2025 in 2030 by 2040
scope 1 and 2
1
: 45% reduction scope 1 and 2
1
: 75% reduction
scope 3 business air travel: 25% reduction scope 3 business air travel: 50% reduction
1
Reduction target on scope 2 is market-based
A guiding principle is that we prefer approaches and/
or methods that have the best chance of maximising
impact in the real economy.
We recognise that a one-size-fits-all approach may
not be effective in achieving our goals. Therefore
we have developed asset-class-specific strategies
for our corporate investment, sovereign bonds,
residential mortgages and real estate portfolios. In
2024, we introduced new Paris alignment strategies
for our private equity and infrastructure investment
portfolios, guided by the NZIF.
To steer and monitor our portfolio, we aim to
establish science-based targets and objectives
for the different asset categories. In line with the
updated NZIF 2.0, we renamed ‘decarbonisation
reference targets’ to ‘decarbonisation reference
objectives’. This is to emphasise that they serve to
translate net-zero goals into quantified objectives,
monitor portfolio emissions and evaluate the
effectiveness of net-zero strategies. We do not intend
to use these objectives as a tool for achieving year-
on-year reductions in financed emissions, as portfolio
actions aimed at reducing financed emissions may
not result in a reduction of emissions in the real
economy.
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engagement activities to external asset managers
and engagement service provider Morningstar
Sustainalytics. In 2024, we enhanced the process
for how we monitor engagement progress for
our Paris Alignment strategy for our corporate
investment portfolio. This process includes three
main components: reviewing engagement plans for
top emitting issuers, tracking the effectiveness of
engagements through milestones, and assessing
company climate performance against a set of Key
Performance Indicators (KPIs). We focus initially on
the top 25 corporate holdings in terms of financed
emissions, and we continually refine our process to
incorporate the latest data and best practices. We
have also defined escalation measures for lagging
engagements to ensure timely progress.
In addition, we updated our voting policy for
proprietary assets in 2024 to clarify our views on
Paris alignment as well as other ESG topics such as
human rights, and taxation. These updates clarify our
expectations for investee companies and the external
asset manager who votes on behalf of our equity
portfolio.
We implement policies on climate change by working
closely with our asset managers and business
units; the policies are published on our external
and internal websites. To ensure policy alignment,
we continuously engage with our asset managers,
provide knowledge sessions, and monitor asset
alignment and overall portfolio development.
In the upcoming sections we describe our asset-
class-specific strategies in more detail.
Below, we describe the policies, actions, objectives
and targets for transitioning our proprietary
investment portfolio to net-zero by 2050. These
policies apply to our proprietary assets. While we
have not yet developed a Paris alignment strategy for
client assets (assets that are invested for risk of the
policyholder), business units are encouraged to apply
the same responsible investment principles to those
assets, where relevant and feasible. However, we
recognise that our client assets portfolio is diverse
and some business units are further along in the
process than others.
Policies
We have developed a range of policies covering
proprietary assets and, where relevant and feasible,
client assets, to mitigate and adapt to climate
change and support our goal to reach net-zero GHG
emissions by 2050. These are looked at in detail
below.
Responsible investment
Our Responsible Investment Framework (RIF) policy
sets out our vision and approach to integrating
environmental, social and governance (ESG)
factors into our investment process and being
an active owner. Our approach as described in
the RIF policy, is a reflection of our investment
beliefs, the organisation’s values, relevant
laws, and internationally recognised norms and
standards, which have been used to base minimum
requirements on for the investment process. It
also includes exclusionary criteria for fossil fuel
activities, including thermal coal mining and oil sands
There is a big difference between taking steps to
reach net zero in the real economy and achieving
this in an investment portfolio. A strategy that only
involves reallocating investments from high- to low-
carbon-intensive industries is a straightforward way
to decarbonise an investment portfolio relatively fast.
However, we choose to take a broader approach,
believing that certain carbon-intensive sectors such
as power generation, steel and cement will continue
to be important, and will need capital to be able
to decarbonise. We also believe that investing in
companies in these sectors that have ambitious and
credible decarbonisation plans, and helping them to
transition rather than divesting, will have a bigger
impact when it comes to achieving a low-carbon
world.
We work with a broad range of stakeholders to drive
best practice in measuring financed emissions and
Paris alignment strategies. As a signatory of the
Paris Aligned Asset Owner (PAAO) commitment, we
are committed to aligning our portfolios with the
objectives of the Paris Agreement and to regularly
sharing best practices with other asset owners. We
also contribute to the further development of the
NZIF through our participation in the Paris Aligned
Investment Initiative (PAII) working groups and
steering group. Both the PAII and the PAAO are
organised by four investor networks, including the
Institutional Investor Group on Climate Change
(IIGCC), of which NN Group is a member. Additionally,
we are involved in the Platform Carbon Accounting
Financials (PCAF) and the European Efficient
Mortgage Initiative (EEMI).
production, which apply to both our proprietary and
client assets.
For our proprietary assets, we have a comprehensive
Oil & Gas Policy that considers oil and gas activities
in the upstream, midstream and downstream supply
chains, including supporting products and services
(with more than 5% revenue exposure). Utilities are
excluded in this policy.
Since 2019, we have also implemented a coal
phase-out strategy for our proprietary investments.
This strategy is outlined in our RIF policy and aims
to reduce the portfolio companies’ involvement
in thermal coal mining and/or coal-fired power
generation to ‘close to zero’ (between 0% and 5%)
by 2030. As of the end of 2024, our portfolio of
corporate investments subject to this policy was
EUR 454 million (EUR 1.8 billion at policy launch in
2019). This gradual decline can be attributed to the
reduction of coal-related activities by companies
within our portfolio, bond maturities, and selective
divestments from certain holdings.
Engagement and voting policies
We have policies on engagement and voting that
support our commitment to a net-zero investment
portfolio by 2050, namely the Engagement Policy
for Proprietary Assets and the Voting Policy for
Proprietary Assets.
NN Group actively encourages portfolio companies
to transition to a low-carbon business model. As an
asset owner, we delegate a significant portion of our
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impact. We identify priority assets for engagement
based on the Paris alignment criteria, and are
developing an engagement plan, milestones and
timeframes for escalation. To support impactful
collective and direct engagement with investee
companies, we have set an ‘engagement threshold’
and focus our monitoring on the top 25 holdings
in terms of financed emissions. We regularly
evaluate our engagement plan to identify additional
companies we want to engage with.
We engage with our investees to promote
decarbonisation and support companies aligning with
1.5°C scenarios. However, if progress is insufficient
or companies engage in harmful fossil fuel activities,
we may use selective divestment as a last resort.
Objectives and targets
The figure below shows the corporate investment
portfolio decarbonisation reference objectives to
reduce scope 1 and 2 financed emissions by 25% in
2025 (tCO
2
e/EUR million invested), and 45% in 2030,
compared to the 2021 base year (which reflects
underlying emissions data from 2019).
Corporate investment portfolio
decarbonisation reference objective
Reduce scope 1 & 2 financed emissions (tCO
2
e/EUR
million invested), compared to 2021 by:
25% 45% net zero
in 2025 in 2030 by 2050
Sovereign bond portfolio
To transition our sovereign bond portfolio to net-
zero emissions by 2050, we use a Paris Alignment
strategy that involves selecting bonds with better
climate performance and investing in climate
solutions, such as sovereign green bonds. We
evaluate our holdings using the NN Country Climate
Score methodology, which we developed together
with our external asset manager to maintain or
improve our portfolio’s climate performance. We also
promote alignment with the Paris Agreement’s goals
by seeking to engage with sovereign issuers globally,
for instance to promote green bond alignment with
the EU Taxonomy.
We are currently updating our approach to assess
alignment of sovereign bonds. This will make
our strategy more aligned with new guidance on
sovereign bonds laid out in the NZIF 2.0, released
in June 2024. However, we believe that setting an
asset-alignment target, engagement threshold and
decarbonisation reference objective for our sovereign
bond portfolio remains challenging for several
reasons. These include the limited room to change
portfolio composition due to liability-matching
considerations, evolving data availability, data quality
and methodology to measure alignment, and an
approach to engagement that is still evolving.
Real estate investments
For our private real estate portfolio, which consists
of directly owned buildings and non-listed real
estate funds across Europe, our net-zero strategy
aims to increase the proportion of net-zero or
Scope 3 financed emissions are currently not
included in our portfolio decarbonisation reference
objective. However, we did publish scope 3 financed
emission actuals for the first time in our 2023 Annual
Report, following PCAF methodology. Although
scope 3 financed emissions are not included in
the decarbonisation reference objective, we do
include investees’ disclosure and target setting on
material scope 3 emissions in our portfolio alignment
assessment and engagement objectives.
Methodology: We used the NZIF as the main guide
for our approach and strategy, which was developed
together with our asset manager. Tools used to
inform the target-setting of the corporate investment
portfolio included the International Energy Agency’s
(IEA) Sustainable Development Scenario (SDS)
reference trajectory. Some pragmatic adjustments
were made to accelerate the pathway in line with our
ambition to steer the investment portfolio towards
net-zero GHG emissions by 2050. To monitor our
carbon footprint, we use a third-party data provider
(ISS).
The portfolio decarbonisation reference objectives
are supported by our underlying alignment and
engagement strategies (i.e. the portfolio coverage
target that monitors the portfolio’s progress towards
the Paris Agreement and the engagement threshold
that tracks the level of our own engagement coverage
and that of our investees that are aligned with the
transition).
Corporate investment portfolio
In 2021, NN Group set intermediate decarbonisation
reference objectives for our corporate investments
to guide our portfolio to net-zero emissions by 2050.
We believe our objectives are ambitious and aim
to align with global net-zero goals, for details and
methodology see below.
Actions
We aim to reach our decarbonisation reference
objectives by implementing a portfolio alignment
strategy that focuses on real-economy
decarbonisation. Our approach, based on the
IIGCC’s NZIF, involves evaluating and monitoring
portfolio alignment by mapping our holdings against
six criteria. These criteria determine the current
alignment status of all corporate holdings. Our
analysis involves assessing a company’s ambition to
achieve net-zero GHG emissions by 2050 and nearer-
term targets, disclose scope 1, 2, and material scope
3 emissions, as well as their emission intensity
performance. For high-impact companies, we also
evaluate the presence of a quantified decarbonisation
strategy and capital allocation plan.
For new investments, we apply screening criteria
based on their alignment or potential for transition.
We prefer to invest in companies that are considered
‘best-in-class’ based on their alignment status or
that make a substantial contribution to climate
solutions.
For existing assets, we focus on stewardship and
engagement to drive alignment, as we believe this
approach has the best chance of realising real-world
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(sustainability) platform, which provides insight
and tooling into possibilities and next steps in
carbon footprint reduction.
• Developing and adjusting propositions and
services
NN Bank has been encouraging customers
to improve the energy label of their house.
While customers may of course pay for such
improvements themselves, NN Bank can help
finance these investments with legislated
solutions. These include the EBB (Energy Savings
Budget) alongside the existing EBV (Energy
Savings Features), which adds a loan of up to
6% of the property value when energy-saving
measures have been executed. In Q4 2024, NN
Bank introduced a proposition encouraging,
and even sponsoring customers to take energy-
saving measures, and thus reduce their CO
2
footprint.
For mortgages not originated by NN Bank, NN
Group engages originators to monitor whether their
ambitions and progress align with our own.
NN Group’s investment portfolio includes residential
mortgages from its own banking operations as
well as external mortgage originators. For NN
Bank-originated mortgages, we have an interim
decarbonisation reference objective of achieving
a 34% reduction by 2030 (compared to base year
2021), to guide our mortgages portfolio towards net
zero in 2050.
aligned assets, as well as engagement with fund
managers. To align with our goal for the directly
managed portfolio to be on a 1.5°C pathway by
2030, our real estate asset manager has conducted
detailed net-zero audits using the Carbon Risk Real
Estate Monitor (CRREM). These audits map each
building’s pathways and establish improvement
plans detailing retrofit recommendations. We have
prioritised energy efficiency and electrification before
focusing on external green energy procurement.
The plans therefore include measures for energy
efficiency, electrification, and on-site green energy
production. By 2024, the net-zero audits have been
largely completed for the standing assets in our
portfolio. The proposed retrofits are expected to be
incorporated into business plans for each asset,
aligning with a decarbonisation reference objective
anticipated to be approved at the beginning of 2025.
For our indirect real estate portfolio, our main lever
is to engage with the managers of the funds in which
we invest, to encourage their ambition to achieve
net-zero emissions. In collaboration with our asset
manager, we aim to develop a Paris Alignment
categorisation framework for our fund investments in
2025. This framework would allow us to have better
insights into the status of our portfolio holdings in
alignment with our net-zero ambitions. By 2030, we
aim for most of our funds (over 75% based on Gross
Asset Value) to be committed to achieving net-zero
GHG emissions by 2040 or sooner (for scope 1 and
2 emissions), with the remainder achieving this by
2050 or sooner.
We evaluate potential exposure to physical climate
risks and set clear objectives for addressing them. In
addition, as an investor member of the Global Real
Estate Sustainability Benchmark (GRESB), we use
the annual Real Estate Assessment to assess and
benchmark our real estate portfolio’s sustainability
performance and identify areas for improvement.
Residential mortgages
Residential mortgages make up a significant
portion of our investment portfolio, including those
originated by the company’s own banking operations
and external mortgage originators. In 2022, NN
Bank and NN Group set a decarbonisation reference
objective for reducing GHG emissions for the
aggregate portfolio of NN Bank-originated mortgages
on the NN balance sheet. The objective is to guide the
mortgage portfolio towards net zero by 2050.
To transition the residential mortgage portfolio to net
zero by 2050, NN Bank is implementing measures
that aim to motivate borrowers to enhance their
homes’ energy-efficiency ratings, reduce GHG
emissions and provide access to financing. These
measures include:
• Engaging with customers and steering
our investment portfolio to reduce GHG
emissions
NN Bank directs, and engages with, customers to
help reduce their carbon footprint. In 2024, the
bank engaged customers through intermediaries
and direct communication. Customers
were encouraged to visit NN Group’s online
Methodology: Together with other financial
institutions in PCAF, we developed a model to
calculate a mortgage portfolio’s carbon footprint.
The model covers consumers’ absolute scope 1
and scope 2 emissions related to the energy use of
properties financed through mortgages; it reflects
the indirect emissions in our lending portfolio.
Construction emissions and a building’s embodied
GHG emissions are not taken into account. To
estimate the GHG emissions of residential real
estate, we need data about the natural gas and
electricity consumption per residence. Because this
data is not publicly available, PCAF has estimated
consumption per energy label and square metre,
using data from Statistics Netherlands (CBS).
We used the CRREM tool to analyse our portfolio
against science-based decarbonisation pathways
aligned with the Paris Agreement. These pathways
are calculated based on a carbon budget to remain
within the boundaries of a 1.5°C rise in global
temperatures. The financial sector increasingly
uses the CRREM methodology, which is aligned
Residential mortgage portfolio
decarbonisation reference objective
(NN Bank-originated)
Reduce financed emissions (kgCO
2
/m²), compared to
2021 by:
34% net zero
in 2030 by 2050
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policies, such as our Oil & Gas Policy, as well as our
focus on climate solutions in the portfolio.
Climate solutions
In 2021, we set an ambition to increase our
proprietary investments in climate solutions by EUR
6 billion by 2030. We define climate solutions as
investments in economic activities that contribute
to climate change mitigation or adaptation. As
an initial step in classifying them, and in line with
guidance from the IIGCC Paris Aligned Investment
Initiative, we focused on areas of energy efficiency
and renewable energy related to Sustainable
Development Goal (SDG) 7. We also supported our
definitions with external certifications, asset labels
and environmental standards where possible and
relevant. Our Green, Social, and Sustainability Bonds
Standard guides our approach to investing in green
bonds, providing guidelines for classifying bonds and
minimum requirements for external asset managers.
While we strive to align with the EU Taxonomy
criteria when investing in climate solutions, the
detailed requirements make it challenging to assess
alignment. We look for investments that satisfy the
substantial contribution criteria for categorising
them as climate solutions, but proof for the ‘do no
significant harm’ (DNSH) criteria is often limited.
Additionally, it remains uncertain what evidence is
acceptable for alignment.
For a comprehensive overview of our definition, which
encompasses green bonds, renewable infrastructure,
certified green buildings in our real estate portfolio,
and other investments, see p. 155.
with the Science Based Target initiative’s (SBTi)
recommendations. CRREM’s scenario is real estate-
and mortgages-specific, meaning it considers the
sector’s carbon budget and relevant technological
developments in the decarbonisation pathways.
The pathways are updated regularly with the latest
scientific input and stakeholder feedback.
As CRREM uses physical emission intensity per
square metre, we use data from Kadaster to convert
the current emissions to this metric. In 2022, based
on these methodological decisions, we developed a
model for the total portfolio of Dutch mortgages that
NN Bank originated and/or serviced, as represented
on the NN Group balance sheet.
The model indicated that we needed to reduce
our emission intensity to 18 kg CO
2
/m
2
by 2030
according to the 2021 CRREM pathway for the
Netherlands and the available CBS emission figures.
This is a 34% reduction compared to our baseline
year 2021. Based on the PCAF methodology we
currently use, this is approximately equal to an
average energy label A++ or higher for the entire
mortgage portfolio by 2030.
Achieving this target by 2030 requires collaboration
across the residential real estate value chain.
CRREM’s 2023 release of a steeper pathway for the
Netherlands introduces additional challenges. We
are evaluating the updated pathway to determine the
best approach to supporting the energy transition
and will provide more information in the next Climate
Action Plan update.
Private equity
In 2024, NN Group developed a Paris Alignment
strategy for our private equity portfolio. The strategy
aims to increase portfolio alignment through
monitoring asset alignment progress, engaging
with asset managers, and increasing investment
in climate solutions. To implement our strategy,
we have started incorporating our Paris alignment
criteria into asset management agreements. We plan
to fulfill the actions recommended by the NZIF over
the coming years as we renew our commitments
with managers. Going forward, NN Group will focus
on collecting financed emissions data and alignment
information from our external private equity
managers. Once we have a better understanding of
the data collected, we will explore setting an asset
alignment target for our private equity portfolio.
Infrastructure investments
Similarly, in 2024, we developed a Paris Alignment
strategy for our infrastructure portfolio, which
includes both equity and debt investments. NN
Group already implements many of the NZIF
recommendations and has a climate solutions
target in place since 2021. The strategy prioritises
investments in climate solutions which we decided
to classify as ‘aligned’ or ‘achieving net zero’.
Data on financed emissions and alignment will be
collected over the following years, allowing us to
review whether we can set an asset alignment and
engagement target. The NZIF recommends focusing
on material sectors like carbon-based energy and
transport when engaging with asset managers on
Paris alignment topics. We expect limited exposure
to new investments in these sectors due to existing
To measure the positive impact of our investments
on the environment, we have developed an impact
measurement framework that uses estimated
emissions avoided as an indicator of positive impact.
However, it is important to note that we do not use
this calculation as an offset in our carbon footprint
calculation for our investments. Furthermore,
our calculation does not account for any negative
impact that our climate solution investments may
have on society and the environment. We plan to
conduct more thorough analysis of the negative
environmental and social impacts of our investments
in climate solutions in the coming years.
Resources for implementation
We have allocated resources to implement our
approach, as described above. As a result, we
have accelerated our total investment in climate
solutions, reaching EUR 12.8 billion in 2024. The
increase is due partly to investments in green bonds,
improvements to the existing building stock and
new renewable infrastructure investments as well
as other low-carbon investments. See p. 154 for a
breakdown of our climate solutions.
Climate solutions target
Target: increase our investments in climate solutions
by EUR 6 billion by 2030. More than double
investments in green bonds, renewable energy
projects and energy efficient real estate investments,
compared to 2021.
EUR 5 billion EUR 11 billion
2021 (base year) by 2030
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While time-bound, the target indicated above is an
input-oriented target, describing the amount we have
invested in order to contribute to climate change
mitigation and adaptation. In 2023, we measured the
outcomes of our investments in climate solutions,
such as renewable energy capacity and production,
as well as emissions avoided, for the first time.
However, the quality of forward-looking data needs
to improve before we can set up a time-bound,
outcome-oriented target.
Insurance underwriting
Transition plan
The insurance industry has an important role to play
in challenges around climate change. It can help build
more climate-resilient communities by providing
customers with coverage for climate-related risks
such as flood, precipitation, storm damage, drought
and wildfires. Insurers can also help enable the
transition to a low-carbon economy by incentivising
and supporting customers to adopt low-carbon
technologies and practices, which will reduce GHG
emissions.
Our objective is to support the transition to a low-
carbon economy through our insurance underwriting
activities. Our target is for our underwriting portfolio
to become net-zero by 2050, in line with the Paris
Agreement, to help limit global warming to a
maximum temperature rise of 1.5°C. Our approach to
reach net zero is threefold:
1. Decarbonisation of our underwriting portfolio by
reducing insurance-associated GHG emissions.
2. Engagement in the value chain to accelerate
action.
3. Insuring climate solutions.
NN Group recognises that achieving a net-zero
insurance underwriting portfolio can best be
achieved through joint action. NN Group is a member
of the Forum for Insurance Transition to Net Zero
(FIT), which brings together insurers and other
stakeholders. FIT is a dialogue and multi-stakeholder
forum chaired by the UN Environment Programme
(UNEP) aiming to support the necessary acceleration
and scaling up of voluntary climate action by the
insurance industry and key stakeholders. NN
Group joined FIT because we believe collaboration
and knowledge-sharing with key players in the
international (re)insurance market is essential for the
financial industry in reaching its net-zero targets.
Policies
In 2024 we published our Responsible Insurance
Underwriting (RIU) Framework Policy. The policy
gives direction for integrating sustainability matters
into our insurance underwriting activities, including
how we address climate change mitigation across
insurance underwriting and product development.
This includes sustainability-related opportunities,
risk management and the consideration of the
potentially adverse impacts of decision-making in
our insurance underwriting activities. The RIU Policy
applies to our insurance underwriting activities in
the Netherlands for retail and commercial lines, and
it serves as a guiding principle for our insurance
activities outside the Netherlands
1
.
We consider thermal coal mining and unconventional
oil and gas exploration (shale gas, shale oil, Arctic
oil and oil sands) to significantly contribute to global
warming. Therefore, NN Group RIU Policy restricts
the provision of insurance services to companies that
derive their revenues from these activities. However,
package and company insurance in our marine cargo
business is exempt from this coal exclusion policy. If
products or services have been developed to benefit
employees, such as pension products and workers’
compensation, a waiver to this restriction might
apply. In such cases, the business unit (BU) involved
will take a case-by-case, customer-based decision.
Waivers will be discussed and approved/rejected
by the NN Group RIU Committee. This committee
strategically defines, and subsequently keeps
oversight of, the RIU Policy, and steers our ambition
for responsible insurance underwriting. In addition,
it oversees and makes recommendations, guides on
policy making and implementation, and advises the
1
This applies to Nationale-Nederlanden Schadeverzekering Maatschappij N.V., ABN AMRO Schadeverzekering N.V., Nationale-Nederlanden
Levensverzekering Maatschappij N.V. and NN Re (Netherlands) N.V. For NN Re, considering its position as reinsurer without any relationship
with primary insurance policyholders, implementation of sustainability risk identification and management differs from other NN business
units. When writing internal reinsurance for NN Group subsidiaries, NN Re shall rely on sustainability risk identification and management
in insurance underwriting performed by such subsidiaries on the basis of this policy. As part of the application process for reinsurance by
NN Re, NN Group subsidiaries should provide confirmation to NN Re of their compliance with the NN RIU Policy, taking into consideration
the extent to which this policy is applicable to the subsidiary. For external inward reinsurance activities, NN Re shall perform an appropriate
sustainability customer due diligence based on the ESG questionnaire as part of its customer acceptance and review process.
Management Board and other internal stakeholders
on RIU-related matters.
Actions
The actions we have taken that contribute to
the ambition to reach net zero in our insurance
underwriting activities by 2050, can largely be
divided into three categories:
1. Decarbonisation of our underwriting portfolio
Reducing insurance-associated emissions (IAE) is
an important step in realising a net-zero insurance
underwriting portfolio by 2050. We are undertaking
several reduction initiatives:
• As part of the RIU Policy, we have strengthened
our coal policy for insurance underwriting. By
restricting insurance services to companies that
derive their revenues from thermal coal mining or
unconventional oil and gas (shale gas, shale oil, oil
shale, Arctic oil and oil sands), we aim to support
the transition to a low-carbon economy.
• In line with the PCAF Standard, we have
introduced interim net-zero targets for our Non-life
portfolio in the Netherlands. By measuring and
monitoring the insurance-associated emissions
of our Property and Casualty (P&C) commercial
lines in scope of the PCAF methodology and
Private Motor portfolios, and by performing sector
analyses on decarbonisation pathways for those
sectors, we were able to set interim targets for
P&C commercial lines and an average reduction
strive per vehicle, for Private Motor.
Read more about our progress on decarbonisation of
the insurance underwriting portfolio on p. 156.
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2. Engagement in the value chain to accelerate
action
We believe that engaging with stakeholders in the
value chain (such as intermediary advisors and
clients) is key to driving positive change in the real
economy. This allows us to use our influence as a
financial services company to encourage companies
to adopt more sustainable practices, reduce
their exposure to risk, and contribute to a more
sustainable economy.
In Private Motor, for example, we aim to encourage
customers to drive less and consider their GHG
emissions while driving. We engage with clients and
intermediaries to extend the use of electric vehicles.
We also promote alternative transportation and have
created a tool for consumers to compare the total
cost of ownership of electric and fossil fuel cars.
3. Insuring climate solutions
Within our insurance business, we manage physical
climate risks in various ways. We offer a range of
products that help customers adapt to and mitigate
climate change, such as coverage against severe
weather events. We have also adapted existing
features in our insurance offerings to address the
climate-related needs of our customers.
Other actions
We have also taken other steps, in addition to the
three categories above. For example, Netherlands
Non-life has a Sustainability Steering Group in place,
which is chaired by the Netherlands Non-life director
of Strategy, Data, IT and Pricing (SDIP). The steering
group reports to the Netherlands Non-life CEO and
has representation from each insurance business
line of Netherlands Non-life and second-line Risk. It
manages the NN Non-life sustainability programme
to improve, align and accelerate progress, and further
integrate sustainability into NN Non-life’s operations.
Specific tracks have been defined, such as risk
management, product development and a reporting
structure on topics. Climate change is a key focus
item in the sustainability programme and is taken
into account as part of our Product Approval Review
Process (PARP). New and existing products are
assessed for potential to ‘do no significant harm’ and
we check that products do not focus on sensitive
sectors or activities that have a profound impact on
people and/or the environment. Non-life Netherlands
has also developed a tool to calculate the carbon
footprint of its underwriting portfolio, and uses a
Physical Risk climate change tool to assess the
impact of climate risks on the balance sheet, where
possible.
Targets
To set well-founded reduction targets, we first
calculated our IAE using PCAF methodology. As the
current PCAF Standard covers methods for specific
commercial lines and Private Motor, we focused on
these segments when setting intermediate reduction
targets. For products that are currently not covered
by the PCAF Standard, we are not yet able to measure
the IAE, or set intermediate targets. We will include
additional targets when, for example, the scope of
the PCAF methodology broadens, or if FIT provides
additional guidance and clarity.
Accomplishing net-zero insurance underwriting-
associated emissions by 2050 remains our overall
target:
• commercial lines (in scope of PCAF Standard) – to
reduce insurance-associated GHG emissions by
at least 26% by 2030, compared to 2022. The
reduction target is set on scope 1 and 2 emissions
from relevant insured clients.
• Private Motor – to strive to reduce insurance-
associated GHG emissions by 15% in carbon
intensity per car by 2030, in the Netherlands
compared to 2022
2
.
The sector’s decarbonisation pathways, used to set
the intermediate reduction ambtions, were built on
current and planned Dutch governmental measures
included in the Dutch Klimaatnota. In deciding on
the target for commercial lines, we took into account
the Dutch Klimaatnota measures (based on the ESR
3
sectors) and the KEV (Klimaat en Energie Verkenning)
scenarios leading to decarbonisation pathways. We
also considered assumptions on future inflation and
economic growth as well as limitations of the data
quality of the calculated IAE.
Each year, Netherlands Non-life assesses whether
the actual IAE reduction of commercial lines and
Private Motor is proceeding according to ambition.
We base this on annual portfolio developments, and
the realisation of Dutch climate and energy policy and
forecasts, in accordance with the annual KEV report.
Netherlands Non-life strives to achieve its ambition
and targets by managing the underwriting portfolio
Insurance-associated GHG emissions
reduction target: commercial lines
Reduce insurance-associated emissions compared
to 2022 base year value by:
26% net zero
in 2030 by 2050
Insurance-associated GHG emissions
reduction strive: Private Motor
Strive to reduce insurance-associated emissions
(carbon intensity per car) compared to 2022 base year
value by:
15% net zero
in 2030 by 2050
2
For Private Motor we realise that achieving substantial progress in emission reduction by 2030 will be challenging. For more information,
see p. 158.
3
The Dutch Climate Agreement includes measures across various sectors, including the ESR sectors. The ESR sectors refer to the sectors
covered by the European Union’s Effort Sharing Regulation (ESR), which includes a.o. emissions from transportation, buildings, agriculture,
waste management and small industry.
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strategically and actively. When necessary and
feasible, we will take additional measures to meet
the intermediate targets.
Progress
In addition to outlining our approach to climate
change and the steps we have taken to help mitigate
and/or adapt to it, we also monitor our progress in
this area. We report on our findings below, for own
operations, investments and insurance underwriting.
In line with our climate commitments, we measure
the GHG emissions of our activities to help align our
portfolios with the Paris Agreement. We report on
the GHG emissions of our own operations (scope
1 and 2) and of the material scope 3 categories,
as determined by the DMA. The material scope
3 categories include business air travel, as well
as emissions from our investment and insurance
underwriting activities. Scope 3 categories that
are applicable to NN Group, but not material, are
disclosed separately
4
.
The table on the next page (carbon footprint by scope
and category) presents actual GHG emissions, GHG
reduction targets and information on the progress
made.
4
Emissions stemming from applicable, but not material categories, are not reported in the Sustainability Statement; all applicable, including
the immaterial categories, are disclosed in ‘Appendix’, see p. 402.
Scope 1 includes direct emissions generated from
sources that are owned or controlled by NN Group.
Scope 2 includes indirect emissions from energy that
is purchased or acquired by, but not generated by, NN
Group and that occurs at sources owned or controlled
by another company. This mainly includes electricity
and district heating consumed in NN Group buildings
(but produced in power plants that are not owned by
NN Group). The ‘location-based’ scope 2 emissions
reflect the average emission-intensity of grids on
which energy is consumed in that specific location.
The ‘market-based’ scope 2 emissions reflect NN
Group’s own energy purchase, for example through
green energy purchase agreements.
Scope 3 includes indirect emissions occurring in NN
Group’s value chain, and we report on the applicable
and material scope 3 categories. NN Group uses the
scope 3 categories that are provided by the GHG
Protocol Corporate Value Chain (scope 3) Accounting
and Reporting Standard. Based on relevance and
materiality, we determined what categories to
disclose in the Sustainability Statement.
The following categories are considered not
applicable to NN, as NN Group does not significantly
engage in activities linked to these categories: capital
goods, upstream transportation and distribution,
upstream leased assets, downstream transportation
These 2023 comparative figures are presented on
a consistent basis with the 2024 disclosures. As a
result, they differ in some respects from the similar
amounts disclosed in the 2023 Annual Report. These
differences relate mainly to GHG emissions and are
largely a result of more information being available on
2023 emissions since the 2023 Annual Report was
finalised. In addition, the 2023 comparative figures
were updated in line the following methodology
amendments:
• In the GHG calculations of the financed emissions
of investments in corporates (scope 1 and 2), the
emissions of certain government-owned entities
are now included, while they were not previously.
• To calculate the financed emissions of government
bonds and lending (scope 1, 2 and 3), we use
the latest available emission data as well as the
latest available purchasing power parity-(PPP)
adjusted GDP data. As a result, the reference year
of emission data can differ from the reference year
of GDP data.
• We base the carbon intensity per EUR million
invested, for all investments, on the balance sheet
value of such investments. Previously, for the
investments in mortgages, the notional value was
used.
• To calculate the financed emissions of certain real
estate investments, the attribution factor is now
based on Gross Asset Value, instead of Net Asset
Value.
• To calculate the IAE of Private Motor, we use the
updated PCAF global-weighted average attribution
factors.
and distribution, processing of sold products, use of
sold products, end-of-life treatment of sold products,
downstream leased assets, and franchises.
Purchased goods and services, fuel- and energy-
related activities, business travel (ground), waste
generated in operations, and employee commuting,
are all applicable to NN, but not identified ‘material’.
The GHG emissions of these categories are disclosed
in the ‘Appendix’ on p. 402.
Business air travel and investments (scope 3,
category 15) are applicable to NN Group and
identified material in the DMA. Investments include
category 15 financed emissions (based on the scope
1 and 2 emissions from NN Group’s investees and
borrowers), and category 15 insurance-associated
emissions (based on the scope 1 and 2 emissions
from relevant insured clients).
GHG intensity per net revenue consists of the GHG
intensity divided by revenue in EUR million. Revenue
consists of insurance income, investment income and
fee and commission results. We exclude realised and
unrealised investment results and impairments from
revenue.
From 2024, NN Group discloses certain sustainability
metrics in line with definitions and guidance in
the Corporate Sustainability Reporting Directive
(CSRD) and the European Sustainability Reporting
Standards (ESRS). While comparative figures are
not required in the first year of reporting, NN Group
has included these in the Sustainability Statement.
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The following sections provide further details on GHG
emissions in the area of own operations, investments
and insurance underwriting. For each of these
categories, information is given on the calculation
methodology. The ‘Glossary’ on p. 406 contains an
explanation of our baseline recalculation policy for
GHG emission targets.
Own operations
We have disclosed our own operations GHG
emissions on scope 1, 2 and 3 (air travel) since 2019.
Over time, as data and calculation methodology
improved, our approach evolved to comply with
changing regulations. Notable changes include
an increased organisational reporting scope (from
significant subsidiaries to all NN Group subsidiaries),
emissions factors updated to the most recent
available, and changes in definition to align with GHG
Protocol. As a result of the latter, emissions from
business ground travel and lease car commuting
have been transferred from scopes 1 and 2 to scope
3, (categories ‘business travel’ and ‘commuting’).
These changes have a significant impact on GHG
emission values. To be able to monitor GHG emission
reduction over time, and track progress towards the
net-zero target, we recalculated scope 1 and 2 base
year values, as well as the 2023 values. These values
are presented in the table on this page.
Scope 1 GHG emissions increased from 1,785 tCO
2
e
in 2023 to 1,896 tCO
2
e in 2024. This increase is
primarily due to data improvements over time,
which result in more complete and accurate values
for 2024. We reduced scope 2 GHG emissions by
Total GHG emissions (tCO
2
e) aggregated by scope 1, 2 and material scope 3 categories
Retrospective Milestones and target years
Base year 2023 2024
% Actuals /
Last year
% Actuals /
Base year Target 2025 Target 2030 Target 2040 Target 2050
% Annual
target / Base
year
Scope 1 GHG emissions (base year = 2019)
Gross scope 1 GHG emissions
1
3,032 1,785 1,896 6% −37% −45% −75% Net zero −8%
Scope 2 GHG emissions (base year = 2019)
Gross scope 2 GHG emissions - location-based
2
7,832 6,613 −16%
Gross scope 2 GHG emissions - market-based 6,601 5,092 4,375 −14% −34% −45% −75% Net zero −8%
Material scope 3 GHG emissions - own operations (base
year = 2019)
Category 6 - business air travel 4,275 3,115 3,637 17% −15% −25% −50% Net zero −4%
Significant scope 3 GHG emissions - investments
Category 15 - financed emissions
3,4
3,493,779 2,897,152 −17%
Significant scope 3 GHG emissions - underwriting
Category 15 - insurance-associated emissions
5
200,844 199,513 −1% Net zero
Scope 3 GHG emissions
Gross scope 3 GHG emissions 3,697,738 3,100,302 −16%
Total material GHG emissions
6
Total material GHG emissions (scope 1, 2 and 3) – location-
based 3,707,355 3,108,811 −16%
Total material GHG emissions (scope 1, 2 and 3) – market-
based 3,704,615 3,106,573 −16%
GHG intensity per net revenue
7
GHG intensity (scope 1, 2 and 3) – location-based 238 192
GHG intensity (scope 1, 2 and 3) – market-based 238
192
1
0% of NN’s scope 1 GHG emissions are covered by regulated emissions trading schemes.
2
NN does not have any location-based targets. Therefore, a baseline is not applicable. Intermediate reduction targets are set on scope 1 and scope 2 (market-based) combined.
3
Represents the total scope 1 and 2 financed emissions of NN’s proprietary assets (excluding Government bonds & lending).
4
Intermediate targets are based on carbon intensity method. Refer to the financed emissions overviews for more information.
5
Intermediate targets are partly based on carbon intensity method. Refer to the insurance-associated emissions table for more information.
6
The total GHG emissions calculated in this overview represent the summation of the GHG categories in this table. This deviates from the ‘Total GHG emissions (tCO
2
e) aggregated by scope 1, 2 and 3 categories’ table,
(see ‘Appendix’, p. 402).
7
The GHG intensity per net revenue in EUR million is calculated based on the total GHG emissions shown in this table.
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Market-based and location-based emissions are
regarded as equal for consumption of district heating.
For scope 3, category 6 (business air travel), we
apply a distance-based calculation methodology.
We regard ‘activity data’ as the distance travelled by
air, and the applied emission factors are the average
emissions per kilometre travelled, split by cabin class
(source: The Department for Energy Security and Net
Zero).
determined per unit of consumed fuel, using factors
obtained from ‘CO
2
emissiefactoren’ and Ecoinvent.
For non-CO
2
gases, we use the most recent Global
Warming Potential (GWP) values as published by the
IPCC, based on 100-year time horizon.
Scope 2 emissions, both location-based and market-
based, are calculated based on indirect energy
consumption by assets or activities owned, operated
and/or controlled by NN Group. This concerns mainly
electricity and district heating in office buildings.
Measurement is based on invoices for indirect
energy consumption or, if these are not available,
is estimated using square metres or other relevant
metrics. Activity data for office buildings is based on
invoices from landlords and/or energy suppliers. For
energy consumption in scope 2, we use the ‘average
data’ method, where emissions are determined per
unit of energy consumption using factors obtained
from ‘CO
2
emissiefactoren’, AIB’s European Residual
Mixes, and the IEA. The sources for district heating
are obtained from ‘CO
2
emissiefactoren’, CE Delft and
other sources.
For scope 2 market-based emissions, we apply
national residual grid mixes to all non-renewable,
indirect electricity consumption, and zero emissions
to the green energy we consume, under the condition
that we have contractual evidence to substantiate
the energy source. For scope 2 location-based
emissions, we apply national average grid mixes to
all non-self-generated electricity consumption.
14% in 2024 compared to 2023. This is largely due
to the shift from using non-renewable electricity
to renewable electricity. To monitor the progress
towards our intermediate reduction targets,
which are set on GHG emissions of scope 1 and 2
combined, we analyse the total GHG emissions of
scope 1 and 2. Compared to the base year value,
the total of scope 1 and scope 2 GHG emissions
decreased by 35%, from 9,633 tCO
2
e in 2019 to
6,271 tCO
2
e in 2024.
Compared to 2019 base year value, scope 3 air travel
GHG emissions show a decrease of 15%. However,
over the last years, we observe a slight upward trend.
The GHG emissions of our scope 3 business air travel
increased from 3,115 tCO
2
e in 2023 to 3,637 tCO
2
in 2024. This makes it more challenging to meet the
intermediate reduction target of 25% compared to
2019 value.
The methodology used to determine emissions
from operations is based on internationally
recognised standards such as the GHG Protocol.
We calculate scope 1 emissions based on direct
energy consumption by assets and activities owned,
operated and/or controlled by NN Group; this refers
mainly to natural gas used in office buildings.
Measurement is based on invoices for direct energy
consumption or, if these are not available, estimated
using square metres or other relevant metrics. For
the energy types in scope 1, NN Group uses the
‘average data’ method, whereby emissions are
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Investments
Financed emissions
2024
Total assets covered (in EUR
million) Financed emissions (tCO
2
e)
PCAF weighted average data
quality score
1
Not part
of GHG
calculation
Included
in the GHG
calculation Scope 1 + 2 Scope 3 Scope 1 + 2 Scope 3
Fixed income corporate 2,076 25,163 2,267,843 20,454,161 1.8 3.3
Listed equity 15 2,729 139,579 1,272,959 1.4 3.4
Total corporate investments 2,091 27,892 2,407,422 21,727,120 1.8 3.3
Residential mortgages - NN Bank-
originated 364 49,786 434,442 3.4
Residential mortgages - other 2,914 1,900 27,656 3.4
Real estate 9,364 27,632 61,495 2.1 2.1
Other proprietary assets 23,104
Total proprietary assets (excl.
government bonds & lending) 28,473 88,942 2,897,152 21,788,615
Government bonds & lending excl. LULUCF 2,497 37,075 5,734,087 1.1
Total proprietary assets (incl.
government bonds & lending) 30,970 126,017
%Assets/Total proprietary assets 20% 80%
Investments for risk of policyholders 45,420
Other assets 7,968
Total assets 84,358 126,017
Government bonds & lending incl. LULUCF
2,497 37,075 5,540,090 1.1
1
PCAF weighted average data quality score: high quality = 1, low quality = 5.
2023
Total assets covered (in EUR
million) Financed emissions (tCO
2
e)
PCAF weighted average data
quality score
1
Not part
of GHG
calculation
Included
in the GHG
calculation Scope 1 + 2 Scope 3 Scope 1 + 2 Scope 3
Fixed income corporate 2,251 25,482 2,756,887 21,966,808 1.7 3.2
Listed equity 3 3,497 183,114 1,542,119 1.4 3.5
Total corporate investments 2,254 28,979 2,940,001 23,508,927 1.7 3.3
Residential mortgages - NN Bank-
originated 963 47,595 474,976 3.4
Residential mortgages - other 2,681 4,634 49,701 4.2
Real estate 9,401 29,100 62,616 2.2 2.2
Other proprietary assets 23,623
Total proprietary assets (excl.
government bonds & lending) 29,521 90,609 3,493,778 23,571,543
Government bonds & lending excl. LULUCF 2,421 37,698 6,620,801 1.1
Total proprietary assets (incl.
government bonds & lending)
31,942 128,307
%Assets/Total proprietary assets 20% 80%
Investments for risk of policyholders 40,289
Other assets 8,403
Total assets 80,634 128,307
Government bonds & lending incl. LULUCF 2,421 37,698 6,372,414 1.1
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NN Group’s methodology per asset class
Asset class Scope Attribution factor
GHG emissions covered as part of
scope 3 financed emissions Source
Corporate
investments
Listed corporate bonds and listed
equity.
Outstanding amount (market value) of
NN Group’s investments divided by the
total company value (i.e. investees and
borrowers).
Scope 1 and 2, with scope 3 reported
separately.
Emissions data from NN Group’s investees and
borrowers is sourced from ISS and Morningstar
Sustainalytics.
Government bonds
and lending
Government bonds and
government lending issued by a:
– central government or
treasury;
– supranational;
– central bank on behalf of a
sovereign.
NN Group’s exposure to sovereign debt
divided by the purchasing power parity
(PPP)-adjusted GDP.
Scope 1, which is defined as the
direct GHG emissions from sources
located within the country territory (i.e.
production emissions).
PPP-adjusted GDP is collected from the data
published on the website of the World Bank.
Emissions data (incl. and excl. LULUCF) is sourced
from the UNFCCC database for Annex I countries and
Climate Watch database for non-Annex I countries.
Real estate (Direct) investment properties
and (indirect) investments in real
estate funds.
NN Group’s share of the Gross Asset
Value divided by the total (fund) Gross
Asset Value.
Scope 1 and 2, with scope 3 reported
separately.
NN Group’s share in the real estate asset or fund,
and underlying GHG emissions, are sourced from NN
Group’s real estate manager, CBRE.
Residential
mortgage loans
Mortgage loans originated by NN
Bank. Mortgage loans originated
by external parties or other NN
entities are reported under other
residential mortgages.
A loan-to-value (LTV) ratio is applied,
which is the outstanding mortgage
amount (nominal value) divided by the
property value at origination. If the
property value at origination is not
available, the latest available property
value is used.
We report GHG emissions originating
from operational energy use of a
residential building. This covers
scope 1 and 2 emissions.
The calculations are based on floor area, energy labels
and building type.
Energy labels are sourced from EP-online. We use
PCAF emission factors, which are based on Centraal
Bureau Statistiek (CBS) data for energy consumption.
In January 2025 PCAF updated these emission
factors because new CBS data became available.
The updated factors have not yet been included in
our GHG calculation. The housing type and surface
area per building is taken from the database of the
Basisregistratie Adressen en Gebouwen (BAG).
Calculation methodology per asset class
NN Group uses an attribution approach to determine
the share of total GHG emissions that is associated
with the specific investment we are reporting on.
Both emissions data and financial data are key inputs
for calculating financed emissions. More details on
our methodology per asset class is shown in the
table below.
Asset scope
To assess the carbon footprint of our proprietary
assets, we use internationally recognised standards,
such as the GHG Protocol Corporate Accounting and
Reporting Standard, and the Global GHG Accounting
and Reporting Standard for the Financial Industry
(Part A, 2022) from the PCAF. Proprietary assets
are those investments that are included in the NN
Group consolidated balance sheet prepared using
International Financial Reporting Standards as
endorsed by the European Union (IFRS-EU) and held
for own account (i.e. where the investment risks and
returns are for NN Group). These assets include the
general account investment portfolio of the insurance
entities, the assets of NN Bank (primarily residential
mortgages) and the assets of the holding companies
within NN Group.
Investments for risk of policyholders of the insurance
entities are not covered by our carbon footprint
analysis. Whilst these assets are included in the
consolidated IFRS-EU balance sheet of NN Group,
we do not control the allocation of these assets
and the investment risks and returns are not for NN
Group; instead, policyholders direct the investment
allocations and the investment risks and returns are
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assets. The assessment of residential mortgages
covers all mortgages originated and/or serviced by
NN Bank, which accounts for the major portion of
the total mortgage portfolio, as well as part of the
mortgages that are originated by external mortgage
providers. The total proprietary assets that are
covered by a carbon footprint measured amount to
EUR 126 billion, which represents approximately
80% of the total proprietary assets. When data was
unavailable for only a minor part of a certain category
within proprietary assets, we extrapolated the
carbon footprint using data that was available for the
majority of these assets within the relevant category.
The extrapolation was performed using the relative
total carrying amounts and represents approximately
13% of the total proprietary assets that are covered.
When extrapolation was used, a PCAF data quality
score of 5 was attributed.
However, ‘other proprietary assets’ are not yet
covered by a carbon footprint measurement. These
are smaller asset categories, accounting for EUR 23
billion or 15% of our proprietary asset portfolio, and
mainly include investments in mutual funds, money
market funds, asset backed securities, commercial
real estate loans, cash and derivatives. Most of these
investments are excluded from GHG calculations due
to the lack of methodologies for these categories.
Additionally, measuring the carbon footprint of
certain assets, like cash and derivatives (primarily
FX and interest rate), may not be suitable or feasible.
We are working on collecting emission data for
other asset classes, prioritising those with available
carbon footprint methodologies and Paris Alignment
strategies. This year for example, we developed
strategies for our infrastructure and private equity
investments. A key focus moving forward will be
gathering emission data for these asset classes.
Important notes on the results
There are double counting challenges with respect
to financed emissions, for example when NN Group
invests in companies that form part of each other’s
value chain. To overcome this challenge, scope 1
and 2 financed emissions are reported separately
from scope 3 financed emissions. In addition, double
counting in the financed emissions of government
bonds and lending can occur if we hold sovereign
debt and investments in domestic companies; this
is because the sovereign emissions include GHG
emissions that are tied to the domestic industries.
To avoid this double counting, we report emissions
related to government bonds and lending separately
from other investments, including and excluding
GHG emissions and removals resulting from human
activities related to land use, land use change and
forestry (LULUCF).
The accuracy of the financed emissions is impacted
by the limited availability of corporate disclosure
and, sometimes, the low quality of reported
corporate data. If current data is not available, NN
Group uses the most recent available data for the
respective reporting period. If direct emissions
data is unavailable, we must rely on estimates and
industry averages, which can introduce inaccuracies
into the calculations and result in a correspondingly
lower PCAF data quality score. There may also be a
directly for the policyholders. These investments
consist mainly of unit-linked portfolios as well as
certain group pension business in the Netherlands.
Market practices and industry-specific requirements
on whether such investments for risk of policyholders
would be in scope of NN Group’s financed emissions
are still developing. Furthermore, the methodologies
for calculating GHG emissions on such investments
(mainly investments in mutual funds) are not yet
fully available. NN Group’s investments for risk
of policyholders are managed by various asset
managers that are contracted locally by the relevant
business units. NN Group currently does not have
complete and accurate data to determine and
disclose the overall emissions from these assets. We
will continue to monitor industry practices, industry
specific guidance and developing methodologies
and will improve availability and quality of relevant
data in order to consider disclosing emissions on
investments for risk of policyholders in future years in
addition to the emissions on our proprietary assets.
Information on insurance policies that invest in
investments for risk of policyholders that is relevant
for policyholders is included in SFDR reporting by
the relevant business units. However, the scope and
methodology for such reporting is different from the
reporting under ESRSs by NN Group.
Coverage proprietary assets
The December 2024 analysis of the proprietary
assets includes the following asset categories:
government bonds, corporate investments (corporate
fixed income and listed equities), residential
mortgages, real estate investments and other
delay in reflecting the actual changes in emissions
for NN Group’s investments due to the time lag in
receiving emissions data from our investees and
borrowers. This time lag differs per asset class. As
the availability and accuracy of emissions data used
as a basis for the calculations can vary significantly,
NN Group applies the PCAF data quality scoring
system. PCAF data quality scores range from 1
(highest quality) to 5 (lowest quality) and indicate
the quality of emissions data used in the calculation.
Data quality scores are specific to each asset class
and are based on an average score weighted by the
value of the assets included in the calculation. With
increased reporting regulations, we anticipate that
data availability and quality will improve over time.
Evaluating carbon emissions poses a challenge
as this is based on historical information, and,
depending on the asset class, may lag by one to
three years. As a result, the carbon footprint provides
a snapshot of a past moment in time and may not be
a good reflection of an entity’s future trajectory to
transition to a low-carbon economy. To address this,
we incorporate forward-looking views of companies’
decarbonisation strategies into our investment
process.
Objectives and targets to transition our
proprietary assets to net zero
To guide our progress in transitioning our investment
portfolio towards net zero, we establish objectives
and targets that are tailored to each asset class.
Drawing on guidance from the NZIF, we have
developed asset class-specific strategies and
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targets, including a decarbonisation reference
objective for our corporate investment and residential
mortgage portfolios that align with net-zero
pathways.
We view portfolio decarbonisation for our
investments as an objective that sets the ambition
of a net-zero strategy and helps to monitor changes
in a portfolio’s emissions and the effectiveness of
our investor actions. It is not intended to be used as
a target-setting tool for year-on-year reductions in
financed emissions.
To ensure effective steering of our portfolio, we have
set additional targets for our corporate investment
portfolio, including a portfolio coverage target and an
engagement threshold. These targets aim to support
decarbonisation in the real economy and increase
the proportion of assets moving towards net zero.
Looking ahead, we are working on developing similar
objectives and targets for other asset categories
based on the NZIF 2.0, which was published in 2024.
For more information on financed emissions related
to each asset class, please see the corresponding
sections below.
Corporate investments
The corporate investments portfolio includes listed
equities and corporate fixed income (i.e. corporate
bonds and loans).
The table shows changes in carbon footprint metrics
between 2023 and 2024, although as noted earlier,
the data set for corporate investment emissions
is the same in both years, so we cannot draw
conclusions regarding any underlying emission
reductions from corporate investment holdings.
Financed emissions related to NN Group’s corporate investment portfolio
Financed emissions (tCO
2
e)
Carbon intensity (tCO
2
e per EUR million
invested)
Weighted average carbon
intensity(tCO
2
e per EUR million of
revenue)
PCAF weighted average data quality
score
1
Scope 1 + 2 Scope 3 Scope 1 + 2 Scope 3 Scope 1 + 2 Scope 3 Scope 1 + 2 Scope 3
Fixed income corporate 2,267,843 20,454,161 90 813 1.8 3.3
Listed equity 139,579 1,272,959 51 466 1.4 3.4
Total corporate investments 2024 2,407,422 21,727,120 86 779 99.0 1,162.9 1.8 3.3
Total corporate investments 2023 2,940,001 23,508,927 101 811 108.2 1,278.1 1.7 3.3
YoY change % Actuals / Last year −18% −8% −15% −4% −8% −9%
Base year (2021) 125
% Actuals / Base year −31%
Decarbonisation reference objective 2025 - Scope 1 + 2 −25%
Decarbonisation reference objective 2030 - Scope 1 + 2 −45%
Decarbonisation reference objective 2050 - Scope 1 + 2 Net zero
1
PCAF weighted average data quality score: high quality = 1, low quality = 5.
In the table we also provide insight into our exposure
to carbon-intensive companies by disclosing the
weighted average carbon intensity (WACI) for
corporate investments. We calculate WACI by
determining the carbon intensity (for scope 1 and
scope 2 GHG emissions per EUR million revenue) for
each investee or borrower, multiplied by the portfolio
weighted average. The corporate assets included in
the WACI calculation are in line with the corporate
assets included in the GHG calculation for financed
emissions.
NN Group has established a corporate portfolio
decarbonisation reference objective to reduce scope
1 and 2 financed emissions (tCO
2
e/EUR million).
We have set interim objectives, aiming for a 25%
reduction in GHG emissions by 2025 and a 45%
reduction by 2030, compared to the 2021 carbon
intensity figure (based on the emissions of underlying
companies in 2019 due to a reporting time lag).
Although scope 3 financed emissions are not
included in our reference objective, we incorporate
investee disclosure and target setting on material
scope 3 emissions into our portfolio alignment
assessment and engagement objectives.
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Analysing changes against the 2021 baseline
provides valuable insights. Compared to our target-
setting baseline of 125 tonnes CO
2
e per EUR million
invested in 2021, we achieved a 31% reduction by
year-end 2024. Our attribution analysis, illustrated
below, indicates that changes in portfolio carbon
intensity are not solely influenced by real-world
emissions changes, but also changes in portfolio
composition and companies’ EVIC (Enterprise Value
including Cash). Focusing on the emissions changes,
and engagement for existing portfolio holdings to
encourage investee companies to accelerate their
decarbonisation pathways. For new assets, the
strategy prioritises those that are better positioned
to align in their transition to a low-carbon future.
Government bonds
We follow the PCAF production approach to report on
sovereign emissions, treating a sovereign issuer as a
national territory, and attributing its direct emissions
(scope 1) to those generated within its boundaries.
We have not included net imported electricity
(scope2) and non-energy imports (scope 3), as the
data quality for these emissions is not good enough
and would have resulted in increased time lag,
a substantial increase in estimated data, and lower
coverage.
In a similar way to corporate financed emissions,
sovereign financed emissions represent the share
of a country’s emissions that can be attributed to
NNGroup based on the amount we have invested
in the sovereign. As there is no ‘total market value
of a country’, it is market practice to use a proxy
to attribute the right amount of emissions to an
investment.
The table below presents changes in carbon footprint
metrics between 2023 and 2024.
Overview of financed emissions related to NN Group’s government bonds and lending portfolio
Financed emissions (tCO
2
e)
Carbon intensity (tCO
2
e per EUR million
invested)
PCAF weighted average data quality
score
1
Government
bonds & loans
incl. LULUCF
Government
bonds & loans
excl. LULUCF
Government
bonds & loans
incl. LULUCF
Government
bonds & loans
excl. LULUCF
Government
bonds & loans
incl. LULUCF
Government
bonds & loans
excl. LULUCF
2024 5,540,090 5,734,087 149 155 1.1 1.1
2023 6,372,414 6,620,801 169 176 1.1 1.1
YoY change % Actuals /
Last year −13% −13% −12% −12%
1
PCAF weighted average data quality score: high quality = 1, low quality = 5.
Changes in
emissions
1
New positions Divested/
matured
Changes in
weight
Interaction
weight-intensity
Data coverage EVIC effectInteraction
Emissions - EVIC
Delta
Emissions Portfolio composition Data EVICInteraction
-10%
-8%
-2%
-11%
6%
5%
-2%
-8%
-31%
1
Changes in investee emissions. Note that the New positions and Interaction categories may include potential emission reductions
which could not be separated from other effects.
the figure shows that companies’ emissions from
our existing holdings declined by 10%, with potential
further reductions through ‘New positions’ and the
‘Interaction’ categories, where effects overlap.
Although real-world emissions have started to
become visible in our portfolio’s financed emission
intensity, investee companies will need to accelerate
their decarbonisation efforts to meet the Paris goals.
Our Paris Alignment Strategy focuses on stewardship
Financed emissions intensity attribution analysis for NN Group’s
corporate investment portfolio 31 December 2021 – 31 December 2024
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Real estate investments
The reporting of our non-listed real estate investment
portfolio comprises the direct engine, over which
we have direct ownership, and the indirect engine,
which includes funds. NN Group requires all real
estate asset managers to participate in the GRESB
Real Estate assessment, which provides us with
emissions data. GRESB requires participants to
report on actual building energy consumption and
calculate GHG emissions based on the average
emissions intensity of the grids on which the energy
is consumed (using mostly grid-average emission
factor data provided by participants). Emission
factors are determined based on geographic
locations. This reporting corresponds to a data
quality score 2 using the PCAF Standard.
In the carbon footprint analysis of our real estate
portfolio, scope 1, 2 and 3 are relevant. Scope 1
and 2 emissions are under control of the buildings’
owner (i.e. the landlord), who can introduce and
implement operating and/or environmental policies
and measures. However, in some cases, tenants hold
the energy contracts directly. In that case, the energy
consumption of the tenants falls under scope 3 where
the owner or landlord has no operational control.
Considering that the energy consumption of tenants
is dominant in the overall energy consumption of
a building, scope 3 is especially important for real
estate. As with our corporate portfolio, we report on
scope 3 emissions separately from scope 1 and 2
emissions.
quality. By improving the monitoring of household
CO
2
emissions, we can bring the outcomes closer to
the actual emitted emissions.
The energy label remains an important data input
for the methodology. Compared to 2019 when we
first gathered this information, the share of label A
in our portfolio increased from 25% to 31%, label B
from 13% to 14%, label C declined from 26% to 25%,
labels D, E, F and G (taken together) declined from
36% to 31%.
To estimate CO
2
emissions from residential
real estate, data on natural gas and electricity
consumption per residence is needed. As these
are not publicly available, PCAF used CBS data to
estimate consumption per energy label and square
metre. In January 2025, CBS updated its energy
data, prompting PCAF to revise the emission factors.
A
25%
31%
13%
14%
26%
25%
9%
8% 8%
7%
9%
8%
10%
8%
B C D E F G
2019
2024
NN portfolio: energy label distribution
(based on number of houses, compared to 2019)
To calculate the carbon footprint of our real estate
investment portfolio, we attribute a real estate fund’s
annual emissions based on NN Group’s share in the
fund, determined by Gross Asset Value (GAV). For all
investment amounts, fund values are based on the
most recent data available, with emissions having a
one-year lag.
NN Group includes all disclosed emissions from
investments in the disclosure of scope 3 financed
emissions, as this is the most transparent and
consistent presentation. Discussions are ongoing on
whether the ESRS would require disclosing emissions
from (only) direct investments in real estate as
part of own operations GHG emission scope 1 and
2. The relevant scope 1 and 2 emissions of these
direct investments in real estate of NN Group were
approximately 12,884 tCO
2
e in 2024 and 13,271
tCO
2
e in 2023.
The table below presents year-on-year changes in
carbon footprint metrics.
Overview of financed emissions related to NN Group’s real estate portfolio
Financed emissions (tCO
2
e)
Carbon intensity (tCO
2
e per EUR million
invested)
PCAF weighted average data quality
score
1
Scope 1 + 2 Scope 3 Scope 1 + 2 Scope 3 Scope 1 + 2 Scope 3
2024 27,632 61,495 3 7 2.1 2.1
2023 29,100 62,616 3 7 2.2 2.2
YoY change % Actuals /
Last year −5% −2% −5% −1%
1
PCAF weighted average data quality score: high quality = 1, low quality = 5.
Residential mortgages
Dutch mortgages originated and/or serviced by NN
Bank account for the largest part of our reported
mortgages’ carbon footprint in 2024, with the
remainder being mortgages originated by external
mortgage providers. The analysis below focuses only
on NN Bank-originated mortgages.
We account for the scope 1 and 2 emissions of each
house (i.e. the energy consumed by the occupant,
which is comprised of the natural gas used to
heat the house, plus the electricity purchased by
the occupant). Construction emissions, notably a
building’s embodied GHG emissions, are not taken
into account.
In line with the PCAF Standard we measure the
carbon footprint of every house based on energy
label, floor space, building type and corresponding
emission factor. Together with other members of
PCAF, we are exploring ways to obtain the actual
consumption data to further enhance reporting
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areas of energy efficiency and renewable energy.
Where possible and relevant, we supported our
definitions with external certifications, asset labels
and environmental standards.
Total investments in climate solutions are ahead of
target, with a total of EUR 12.8 billion in 2024. This
keeps us in line with our 2030 target as it accounts
for redemptions. The acceleration of investments
in this area is mainly driven by higher-than-
expected investments in green bonds. Investments
in renewable energy show continued increase,
reflecting our commitments in previous years.
We are currently analysing this update and may
incorporate it into our next carbon footprint report.
The financed emissions of NN Group’s originated
mortgage portfolio at the end of 2024 were 434
kilotonnes of CO
2
e, showing a 9% decrease from the
previous year.
We also calculate a carbon intensity figure for the
mortgage portfolio, which indicates how efficient
NN Group’s mortgage portfolio is in terms of GHG
emissions (tCO
2
e) per unit of output (m
2
). We apply
an LTV ratio to determine the financed surface area
(in m
2
) of a property; this is calculated by dividing the
amount of the outstanding mortgage (nominal value)
by the property value at origination and multiplying
that by the property’s surface area. If the property
value at mortgage loan origination is unavailable, the
latest available property value is used.
Based on this metric, NN Group has set a portfolio
decarbonisation reference objective with a baseline
of 27.4 kgCO
2
/m
2
in 2021, and an interim reference
objective of 18.0 kgCO
2
/m
2
by 2030, representing a
34% decline from the baseline. Our methodology and
objective are based on the CRREM NL 1.5°C pathway
(2021 version) and are aligned with criteria set out by
the SBTi. For details on our methodology, see p. 141
of this report.
The emissions intensity at year-end 2024 was 22.9
kg of CO
2
e per m², representing a decline of 17%
compared to the baseline year of 2021.
Climate solutions
To support our Paris Alignment strategy, NN Group
has developed an internal framework to define
‘climate solutions investments’ as part of its
proprietary investments’ portfolio. By investing in
climate solutions, we aim to contribute to climate
change mitigation and adaptation. As a step in
classifying climate solutions investments, and in
line with guidance from the IIGCC’s Paris Aligned
Investment Initiative, we focused on SDG 7-related
Overview of financed emissions related to NN Group’s residential mortgage portfolio
(NN Bank-originated)
Financed
emissions (tCO
2
e)
Carbon intensity
(tCO
2
e per EUR
million invested)
Carbon
intensity per m
2
(kgCO
2
e/m
2
)
PCAF weighted
average data
quality score
1
Scope 1 + 2 Scope 1 + 2 Scope 1 + 2 Scope 1 + 2
Residential mortgages - NN Bank-originated 2024 434,442 8.7 22.9 3.4
Residential mortgages - NN Bank-originated 2023 474,976 10.0 24.4 3.4
YoY change % Actuals / Last year −9% −13% −6%
Residential mortgages - NN Bank-originated 2021 (Base
year) 27.4
% Actuals / Base year −17%
Decarbonisation reference objective 2030 - carbon
intensity (kgCO
2
e/m
2
) −34%
Decarbonisation reference objective 2050 - carbon
intensity (kgCO
2
e/m
2
) Net zero
1
PCAF weighted average data quality score: high quality = 1, low quality = 5.
Investments in climate solutions (in EUR million)
2024 2023 2021 (Base year) Target 2030
Renewable energy investments
2,035 1,255 567
- of which: infrastructure equity
924 354 44
- of which: infrastructure debt
1,111 901 523
Certified green buildings
1
5,020 5,323 3,817
- of which: direct and equity investments
4,498 4,722 3,236
- of which: debt investments
522 601 581
Green bonds
5,646 4,091 637
Other
2
99 83 41
Total 12,800 10,752 5,062 11,000
1
Relates to buildings within NN’s non-listed real estate portfolio; the residential mortgage portfolio of NN is not covered in this category.
2
Other included non-infrastructure (private equity).
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More details on NN Group’s definition per asset class and valuation method is shown in the table below.
Asset class Definition Valuation method
Green bond The green bonds NN Group invests in are in line with the NN Green, Social and
Sustainability Bond Standard; this aligns with the Green Bond Principles of the
International Capital Markets Association (ICMA) and needs to be applied in addition
to the basic Responsible Investment (RI) criteria as described in the RI Framework
Policy and related standards.
Valuation of the green bonds is on outstanding amount.
Renewable energy infrastructure Investments in infrastructure funds with a clear focus on climate change and/or
energy transition and investments in projects (equity/debt) for renewable energy
infrastructure, such as solar PV, offshore and onshore wind, hydrogen, storage,
energy efficiency and other renewable energy technologies.
Valuation for infrastructure equity is on market values; for
infrastructure debt, it is on outstanding loan amount.
Certified green buildings
Within the real estate portfolio (equity/debt), these include assets with at least
an Energy Performance Certificate (EPC) of class A. If an EPC is not available, they
have a high level of building certification (BREAAM or HQE certification of at least
Excellent, or LEED or DGNB of at least Gold).
1
Valuation for certified green buildings is, for equity investments,
on market value; for debt investments, it is on outstanding loan
amount.
Other Investments that do not fall into any of the categories above, including investments
in unlisted entities. For example, impact private equity funds that target and report
on clearly defined climate impact KPIs, or funds that have a broader ESG focus, but
where clean and renewable energy projects account for a substantial part of the
fund.
Market value.
1
BREEM, HQE, LEED and DGNB are all green building certifications.
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Insurance underwriting
In 2022, NN Group first calculated IAE for insurance
underwriting business lines in scope of the PCAF. All
IAE figures, including the 2022 base-year emissions
are calculated in line with the PCAF Standard.
The table below shows our progress towards our
climate ambitions in the two business lines in the
Netherlands in scope of the PCAF Standard: NN Non-
life’s Private Motor and commercial lines. ‘Insurance-
associated’ refers to those GHG emissions
associated with NN Group’s underwriting activities in
these business lines. The methodology to determine
IAE is based on internationally recognised standards
such as the GHG Protocol Corporate Accounting and
Reporting Standard, and the PCAF’s Global GHG
Accounting and Reporting Standard for the Financial
Industry (Part C, 2022).
Insurance-associated emissions (IAE) of our commercial lines and Private Motor
2024 2023
GHG emissions
(tCO
2
e)
Carbon intensity
(tCO
2
e/100
vehicles)
% Actuals / Base
year
PCAF weighted
average data
quality score
1
GHG emissions
(tCO
2
e)
Carbon intensity
(tCO
2
e/100
vehicles)
% Actuals / Base
year
PCAF weighted
average data
quality score
1
Base year (2022)
(tCO
2
e)
Base year (2022)
(tCO
2
e/100
vehicles) Target 2030
2
2050
Commercial lines
3
55,701 −11% 5.0 51,256 −18% 5.0 62,356 −26% Net zero
Private Motor
4
143,812 10.73 3% 2.3 149,588 10.95 5% 2.0 10.38 Net zero
Total Insurance associated emissions 199,513 200,844
1
PCAF weighted average data quality score: high quality = 1, low quality = 5.
2
The target for commercial lines is in absolute emissions (tCO
2
e). The target for commercial lines only applies to the Netherlands.
3
The commercial lines concern EUR 1,315 million GWP of Netherlands Non-life in 2024.
4
The Private Motor concerns EUR 536 million GWP of Netherlands Non-life in 2024.
Calculation methodology
In line with the underwriting activities covered by the
PCAF Standard, NN Group reports IAE for commercial
lines and Private Motor. We determine these IAE by
multiplying the GHG emissions associated with the
insurer by the GHG emissions of the insured.
For Private Motor, we calculate the emissions per
insured license plate and multiply that by the global
weighted average attribution factor, as published by
PCAF. This attribution factor is based on premium
charge divided by the costs of vehicle ownership. For
commercial lines, the attribution factor is determined
by dividing the insurance premium by the total
revenue of the policyholder.
As the availability and accuracy of the emissions data
we base our calculations on can vary significantly,
we use the PCAF data quality scoring system, with
scores ranging from 1 (highest quality) to 5 (lowest
quality), and we indicate the quality of the emissions
data used in the calculation. For commercial lines,
data quality scores are specific to each segment
and based on an average score weighted by the
premium charged to the policyholders included in the
calculation.
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More details on our methodology per product line is
shown in the table below.
The accuracy of the reported IAE is impacted by the
limited availability of data and occasionally by the
low quality of reported data. Also, carbon emissions
intensities provided by PCAF for commercial lines are
based on lagged 2019 emissions.
Commercial lines
As actual emission figures of individual small and
medium-sized enterprises (SMEs) are not yet
available, we have used industrial sector average
emission figures in the IAE calculations for our
NN Group’s methodology per line of business
Line of business Scope Attribution factor GHG emissions covered Source
Commercial lines Property and Casualty (P&C)
insurance lines covered by the
PCAF Standard.
Gross written premium (net of provisions,
commissions or any other agent fees), divided
by the yearly revenue of the insured company.
Scope 1 and 2 The calculations are based on the emission
intensities of a specific sector. Emission
intensities are collected through the PCAF
database.
Private Motor Personal automotive (insurance
of vehicles purchased by private
individuals or households).
Prescribed by PCAF as a constant across all
insurance policies, multiplied by the pool factor
(the part of the insurance or portfolio that NN
Group underwrites).
The attribution factor is corrected for risk
sharing with other insurers, to avoid double
counting.
Scope 1 and 2 Emissions are calculated by multiplying a
measure for exposure (fuel consumption or
distance travelled) by a vehicle’s emission
intensity.
Vehicle-specific emission intensities data
is sourced from the RDW. If internal data is
not available, the average distance travelled
is gathered via CBS (Statistics Netherlands)
and is based on vehicle type.
commercial lines’ underwriting portfolio. This is in
line with the PCAF Standard as a best-effort estimate.
We note that the data quality used to calculate IAE is
key in determining our progress towards reaching our
climate ambitions. The quality of the industrial sector
average emission figures we use may be subject
to change over time, for example in granularity or
through other metrics and technologies. We realise
that individual company emission data may deviate
from applicable and available industrial sector
average emission data. As we continuously strive
to improve the availability and quality of the data
used for calculations, including that of our own data,
we may need to adjust our emissions calculations.
As well as potential changes in the data used for
calculations, calculation methodologies such as the
ones we currently use may be subject to change
because of new scientific insights, assumptions,
regulatory requirements, industry standards or other
developments. We aim to be transparent about such
changes to allow for proper tracking of progress.
In 2023, there was a reduction in commercial lines’
IAE of approximately 11.10 kt CO
2
e compared to
base year 2022, due to portfolio developments
together with improved sector emission averages
from the 2019 PCAF database. By the end of 2024
compared to 2023, the IAE for commercial lines
increased by approximately 4.45 kt CO
2
e, a 11%
reduction against the base year of 2022, mainly
due to portfolio developments and improvements
in data collection and accuracy on sectoral coding.
Note that the 11% reduction figure does not include
improvements in sector emission averages, as no
recent update of the PCAF database was available.
The reduction in IAE per year-end 2024 is likely to
improve once a new version of the PCAF database
becomes available. To achieve the target of -26%
by 2030 in the Netherlands a further reduction of at
least 9.56 kt CO
2
e emissions is needed.
Although the KEV 2024 pathway deviates from the
Dutch Klimaatnota pathway, we expect that sector
emission averages are likely to further reduce
between now and 2030. The emission reduction
target for commercial lines therefore seems feasible
assuming that:
• governmental measures support the expected
outcomes;
• improvements in data quality and accuracy of
sectoral coding do not significantly deviate from
our best effort estimates, as we currently rely
heavily on sector averages and expect data quality
to improve year by year.
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Private Motor
We acknowledge the importance of reducing carbon
emissions across our Private Motor portfolio and
are committed to net-zero mobility towards 2050.
However, we realise that achieving substantial
progress in emission intensity reduction by 2030 will
be challenging, for several reasons. For example, for
Private Motor vehicles, a 20% reduction in emissions
between 2022 and 2030 is expected for the entire
Dutch market − for both new and used vehicles.
However, when electric vehicles (EVs) enter the
second-hand market, we can expect a delayed effect
of carbon reduction in that specific market.
By 2030, the reduction in GHG emissions for second-
hand passenger cars since 2022 is expected to be
around 16% to 19%. Given that a significant portion
of NN Group’s Private Motor portfolio comprises
second-hand vehicles, we anticipate a delay in
carbon reduction for our portfolio until new EVs are
made available. Second-hand passenger cars serve
a significant number of Dutch households; many
cannot afford new cars, or are not catered for through
company lease fleets.
However, to provide this support, we are largely
dependent on external factors, such as the pricing
of EVs (and other vehicles not driven by internal
combustion engines), continuous and accelerated
support from governments, improved infrastructure,
and the pace of EV development and manufacture
and other technological developments. While we are
committed to decreasing carbon emissions where we
can, excluding clients (by, for example, not insuring
fuel-powered motors or using prohibitive pricing) is
not a sustainable solution.
As we disclosed in our 2024 mobility trend report,
we aim for a 15% reduction in carbon intensity per
car by 2030 in the Netherlands, from 2022. To help
us achieve this we will leverage knowledge on net-
zero mobility and actively promote more sustainable
ways of driving and less frequent driving by exploring
‘pay as you drive’ and ‘pay how you drive’ products
and services. We will also engage with clients and
intermediaries to promote a switch to EVs where
possible, and explore battery guarantees for second-
hand EVs.
Compared to base year 2022, carbon intensity per
vehicle rose in 2023 by 5%, mainly due to an increase
that year in the average annual mileage per vehicle
for passenger cars (12.460 km) compared to 11.881
km in 2022, according to Statistics Netherlands
(CBS). By the end of 2024 the carbon intensity per
vehicle had increased by 3% since 2022, largely
because of an increase in driving in the Netherlands,
higher than we had predicted, as well as a growth
of older cars in our portfolio. It is important to note
that the figure of 3% is based on CBS 2023 figures on
emissions and average annual mileage, as CBS 2024
figures are not yet available; also, that the actual
mileage driven in our Private Motor portfolio may
deviate from the CBS figures. While our ambition of
reducing the carbon emission intensity per vehicle by
15% by 2030 will be challenging, we are committed
to striving to achieve it.
Identify climate risk drivers
Compile a comprehensive list of
risk drivers followed by screening
relevance for our balance sheet.
1
Assess inherent vulnerability
Assess the inherent climate
vulnerability through the location
or sector lens.
Assess exposure
Assess exposure on an object/
portfolio basis by considering
mitigation and adaptation
measures.
Assess impact
Use qualitative and quantitative
analysis to measure financial
impact.
2 3 4
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Anticipated financial effects
Climate Risk Assessment framework
We are committed to understanding and addressing
the impacts of climate change on our business
and customers. We perform regular Climate Risk
Assessments (CRAs) to evaluate both physical and
transition risks associated with climate change.
Our approach involves four key steps:
Step 1: Identify and define a list of climate risk
drivers and connect them to balance sheet items
We assess two sources of climate risk:
• Physical risk: risks that arise from the physical
effects of climate change. We differentiate
between 1) acute physical risks, which are
extreme weather events occurring with increased
frequency and severity; and 2) chronic physical
risks, which are driven by longer-term shifts in
climate patterns.
• Transition risk: risks that arise from the transition
to a low-carbon and climate-resilient economy,
and are associated with market, regulatory and
policy developments.
Each identified risk driver is rationalised against our
insurance product offerings and/or investments,
to further assess vulnerability at an inherent level,
i.e. without taking into account any risk mitigation
measures.
The CRAs are performed on the NN Group
balance sheet, excluding investments for risk of
policyholders, under the following six sections:
Climate Risk Assessment on balance sheet
Section
Underwriting Life & health insurance
Non-life insurance
Assets Corporate bonds & equity
Sovereign bonds
Real estate
Mortgages
Step 2: Assess the inherent vulnerability for each
risk
We assess inherent vulnerability in the portfolio
by determining the susceptibility of a location or
industry sector to the effects of climate change.
The country lens serves as a starting point to identify
the most significant climate risks affecting countries
where we offer insurance products, or invest.
The sector lens drills further into the portfolio by
qualitatively considering which industry sectors are
most at risk to climate change. We prioritise balance
sheet components that require further analysis.
Climate Risk Assessment approach
Exposure is defined as the extent to which our
insurance products or investments could be sensitive
to climate change. We consider risk reduction factors
like collateral posted or financial strength of
counterparts, (re)insurance arrangements which
reduce inherent risk of climate change to the balance
sheet, and adaptation measures such as flood
defence mechanisms that mitigate the impact of
climate events like river floods, heavy rainfall and sea
level rise.
Step 3: Assess exposure
In this step we further consider characteristics of
assets and liabilities, either on an individual location
level for buildings/housing or a portfolio level, to
establish which areas of the balance sheet might be
exposed. Furthermore, all risk-reduction measures
are incorporated in the analysis resulting in a
measurement on exposure.
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Step 4: Assess impact
We use both qualitative and quantitative
assessments to analyse climate-related risks. This
step involves the use of numerical data, models,
statistical analysis and expert judgment to estimate
the likelihood and impacts of climate risks. The
assessments include analysing historical data,
climate projections, and other relevant quantitative
information to quantify the risks. Quantitative
assessments translate the exposure measured in
step three into a potential loss (capturing resilience),
providing measurable estimates of the potential
impacts of climate risks.
Despite progress made, we use the phase-in
disclosure requirement for reporting anticipated
financial effects. This is explained under ‘Climate Risk
Assessment results’, below. We are continuously
enhancing our analysis by upgrading model
capabilities, methodologies and data as they become
more available. We also consistently assess and
incorporate developments from governmental,
institutional and industry sources to further increase
the sophistication and maturity of our assessment.
Time horizons and scenarios
As mentioned under General Disclosures, we define
time horizons as follows:
• short/medium-term: less than or equal to five
years (business and capital planning);
• long-term: more than five years, beyond the
business and capital planning period (scenario
analysis).
For scenario analysis and identifying emerging risks
and trends, such as climate change, a long-term
horizon may be considered as being beyond ten
years, depending on the risk or trend analysed.
The time horizons and scenarios used in the CRAs are
further detailed below.
Scenario analysis is included where possible, given
data availability and maturity of modelling. We
considered the scenarios in the table below, aligned
with CSRD requirements.
These scenarios provide a basis for analysing
different emission pathways. They have been adapted
towards the models used and considered individually,
without accounting for combined effects.
General limitations
Assessing climate change across investments and
insurance products currently requires a multi-faceted
and multi-tooled approach. Evaluating physical risks
requires highly granular geo-spatial data, which is
often not available at the time of evaluation. Many
data sets provide information at aggregated levels,
Risk scenarios
Temperature Risks assessed Scenario Scenario explanation Rationale
1.5°C Transition risk
Physical risk
NGFS Divergent
Net Zero (disorderly
transition)
Divergent Net Zero reaches net zero around2050 but with higher costs due to divergent
policies introduced across sectors leading to a quicker phase out of oil use.
Disorderly scenarios explore higher
transition risk due to policies
being delayed or divergent across
countries and sectors.
2-3°C Transition risk
Physical risk
NGFS Nationally
Determined
Contributions (NDCs)
Nationally Determined Contributions includes all pledged policies, even if not yet backed up
by implemented effective policies.
This scenario assumes that the moderate and heterogeneous climate ambition reflected
in the conditional NDCs at the beginning of 2024 continues over the 21st century (low
transition risks). Emissions decline but lead nonetheless to 2.3°C of warming associated
with moderate to severe physical risks.
Transition risks are assumed
relatively low under this scenario.
We continue to experience steady
increase in physical risks impacting
our underwriting portfolio and our
investments.
2-3°C Physical risk IPCC Shared
Socioeconomic Pathway
(SSP)2-4.5
GHG emissions remain around current levels until the middle of the century before starting
to fall mid-century, but do not reach net-zero by 2100. Socio-economic factors follow
their historic trends, with no notable shifts. Progress toward sustainability is slow, with
development and income growing unevenly. In this scenario, temperatures rise 2.7°C by the
end of the century.
>4°C Physical risk IPCC SSP5-8.5 scenario
(hot-house world)
GHG emissions roughly double from current levels by 2050, which leads to a global
temperature increase of nearly 4°C by the end of the century. It assumes limited success in
mitigating climate change, leading to severe and widespread physical hazards.
Severe physical risks, as assumed
under these scenarios, can
negatively impact the market value
of our assets and/or increase claim
frequency and claim size for Life and
Non-life liabilities.
such as postal codes or territorial units, rather than
specific addresses, and do not consider building
characteristics. Transition risk assessments often
include sector-level information or emissions-based
data, which can vary in granularity and comparability.
Translating such data into an expected loss value
needs to be further developed. Also, climate models
lack maturity and often the sophistication needed
for long-term projections and scenario analysis; this
can affect the reliability and in some instances the
availability of results.
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Climate Risk Assessment results
Because we use the phase-in disclosure requirement
for reporting anticipated financial effects that may
result from climate change, we disclose only on a
qualitative basis, which means we employ numerous
judgements in the execution of our methodology.
We are in discussion with multiple external data
providers on developments in screening and scoring
climate risk indicators for physical and transition risks
with the aim of increasing our reporting capabilities
over the coming years.
We assess sensitivity to climate-related risk for each
balance sheet item, as split in the balance sheet
coverage table at the physical (chronic and acute
combined) and transition level. The assessment
excludes investments for risk of policyholders and
was performed on Q3 2024 data.
Our assessment has identified potential sensitivity
to climate change risks for some parts of our balance
sheet, mainly in the longer term. For the short term,
given the mitigating management actions in place,
we do not consider climate change to have material
financial effect to our solvency position.
Balance sheet coverage
Short to medium term Long term
Sensitivity identified No sensitivity identified Not analysed
Mortgages
Real estate
Sovereign
bonds
Corporates
Life & health
Non-life
Transition
Physical
acute
Physical
chronic
Climate risk drivers
Transition
Physical
acute
Physical
chronic
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Investments
Mortgages
Physical climate risks in the mortgage portfolio
may cause damage to the underlying collateral,
reducing its value and affecting homeowners’ ability
to service their debt. Climate transition risks can
decrease the collateral value of the assets that are
not energy-efficient and that fall short of meeting
new regulations towards a more carbon-efficient
economy.
NN Group, in line with NN Bank, uses external
data sources and proprietary models to analyse
climate risk. The analysis is performed on the entire
mortgage portfolio (~EUR 61 billion), which includes
an immaterial portion (<0.5% of MV exposure) of
mortgages outside the Netherlands.
NN Group uses the Klimaateffectatlas tool,
maintained by the Dutch Climate Adaptation Services
in collaboration with the Dutch government, to gather
climate risk indicators on a per-collateral basis.
Hazards assessed are: fluvial and pluvial flood (under
a 1:10, 1:100 and 1:1000 event), wildfire, pole rot
and soil subsidence. By combining the indicators with
quantitative research from governmental bodies,
NGOs and other climate experts, we determine the
potential damages to each collateral. The damages
are combined with Loan To Value (LTV) information
to identify the extent of the assets that are exposed
to climate change. A key limitation of the analysis is
The results for the mortgage portfolio align with
expectations, identifying fluvial and pluvial flood as
the most significant hazards for the Netherlands. Sea
level rise might also become significant under a long-
term horizon in a ‘hot-house world’ scenario.
Although the results indicate an NN Group mortgage
portfolio that is sensitive to climate-related risk, it
is worth noting that the analysis does not consider
risk-reduction measures that are available to
homeowners or planned by the Dutch government,
such as insurance coverage, government support
or future adaptation actions. Such measures are
expected to provide large mitigating impacts on the
balance sheet.
The assessment of transition risks is internally
developed and aligned with the targets for energy
efficiency, and for transitioning to a low-carbon
economy, laid out by the IPCC and the Network for
Greening the Financial System (NGFS). We combine
energy label information and market value data
on the residential property portfolio to measure
potential shifts in valuation related to energy
efficiency. This information is combined with client-
level risk parameters such as loan-to-income ratios,
to assess mortgage risks from new regulatory
policies or market sentiment shifts (i.e. shifts in
consumer behaviour towards more energy-efficient
homes).
The analysis indicates no exposure that is sensitive
to transition risk for the NN Group mortgage portfolio.
that it does not incorporate factors such as insurance
and government support. Such mitigating effects will
further limit the impact of climate risk on the balance
sheet, so these effects are important to acknowledge
and incorporate in future assessments.
The assessment uses a baseline scenario, that is,
no change to the warming of the earth over the
short, medium or long term, and performed only
on the current portfolio not considering different
time projections. We do not have data to assess
longer-term horizons under the current tool. This is
a key limitation to assessing the mortgage portfolio.
Despite this, it is reasonable to expect that under
a ‘hot-house world’ scenario, flood severity and
frequency will magnify and sea level rise will increase,
leading to potentially large adverse impacts.
Regions with exposures sensitive to climate change-related risks
Hazard Explanation
Regional balance sheet
sensitivity
1
Acute Fluvial flood
(1:100 year event)
Risk of river flooding and a breach of a non-
primary embankments i.e. embankments
situated next to smaller waterways such as Geul
or Roer in Limburg.
Zuid-Holland, Utrecht, Gelderland.
Acute Pluvial flood
(1:100 year event)
Risk of flooding due to heavy rainfall.
Intense rainfall for a brief period can cause
waterlogging, leading to substantial damage to
buildings.
Zuid-Holland, Noord-Holland,
Noord-Brabant, Gelderland,
Utrecht, Limburg, Overijssel.
1
Areas with small exposures sensitive to climate-related risks are excluded.
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The transition risk assessment from CBRE focuses on
determining the level of adaptation of the property
portfolio using CRREM against two scenarios: a 1.5°C
and a 2°C increase in global temperatures. Currently
this analysis does not extend to financial impacts
from adaptation.
The real estate portfolio has an important focus on
the Netherlands, which accounts for almost 40% of
the total exposure, while the rest of the exposure
is diversified among various European countries. To
that end, results align with the mortgage portfolio,
identifying flood as the main risk particularly
impacting the Netherlands. However, the analysis
(as also mentioned for mortgages) does not account
for resilience factors such as insurance coverage,
governmental support or future adaptation plans. In
addition, Moody’s Climate on Demand does not fully
consider any existing local municipal flood defences,
which may exacerbate flood risk exposure results.
Real estate
NN Group invests in real estate through both direct
ownership of buildings and indirect investments
via non-listed real estate funds. Both physical and
transition risks have been identified as key for real
estate. Chronic and acute physical risks can impact
asset values, hinder business operations, impede
financing and increase insurance costs. Transition
risks can lead to increased capital expenditures or
reassessment of asset values.
For the physical risk assessment, we rely on our real
estate asset manager, CBRE, and cover 90% of the
portfolio as of 30 September 2024 (~EUR 9.5 billion).
CBRE uses Moody’s Climate on Demand, evaluating
six hazards relevant to real estate over two time
horizons (short-term: 2030, long-term: 2050) on two
emissions pathways (RCP 4.5 and RCP 8.5).
The following acute and chronic hazards are
assessed on geospatial coordinates considering
both country and sector level information: heat
stress (extreme heat events and chronic increase in
average temperature), water stress (reduced water
supply due to drought or changes in water supply/
demand dynamics), flood, hurricanes and typhoons,
wildfire and sea level rise. Climate risk indicators
are transformed into a standardised score (0-100)
by comparing the raw data of each indicator for any
given asset against the investible universe across
locations.
Sensitivity to climate change-related risks
Countries with exposures sensitive to physical risk
1
Reasoning
Short RCP 4.5 Long RCP 8.5
Acute The Netherlands The Netherlands Primarily from flood risk (includes fluvial and
pluvial). Other areas exposed to flooding to a
lesser extent: Germany, Spain, United Kingdom.
Chronic Spain Primarily from heat and water stress. Other
countries exposed to chronic risks to a lesser
extent: Italy and France to heat stress,
Netherlands and Germany to sea level rise.
1
Countries/sectors with small exposures sensitive to climate-related risks are excluded.
• Chronic physical risk: we used Notre Dame
University’s ND-Gain index to represent a
country’s current chronic climate risk. The index
considers several risk drivers, including water
stress, heat stress, and sea level rise. While the
index also includes information on acute physical
and transition risks, the methodology and output
is best suited to reflect chronic risk.
• Acute physical risk: we used the INFORM Risk
index developed by the Joint Research Centre of
the European Commission (JRC) and the Euro-
Mediterranean Centre on Climate Change. The
index is designed to be used as a risk assessment
tool for humanitarian crises and disasters, and to
support decisions about prevention, preparedness
and response. The methodology considers
indicators that are essential to determining a
country’s vulnerability or resilience to the sudden
nature of acute physical risk events. The index
considers a country’s exposure to cyclones, fluvial
floods and drought. INFORM Risk does not use
climate projections but we employed the INFORM
Climate Change Risk index by the JRC to project
a country’s vulnerability and resilience to climate
change in 2050 in line with an RCP 8.5 scenario.
• Transition risk: we used the Climate Change
Performance Index (CCPI) from Germanwatch,
which considers risk drivers such as a country’s
change in GHG emissions, country targets and
energy distribution.
Sovereign bonds
A country’s exposure to climate change depends on
its geography, economic and societal conditions,
as well as its future prospects, which all affect its
vulnerability and resilience.
To assess a country’s exposure, we developed an
impact and likelihood heatmap to identify country
vulnerability and resilience to acute and chronic
physical risks and transition risks for all countries in
our Group sovereign bond portfolio. The analysis is
performed on the full Group sovereign bond portfolio
(~ EUR 39 billion). We define vulnerability as a
country’s inherent susceptibility to climate change.
For the impact scale, we used three external indices
that incorporate climate change vulnerability and
country resilience in their methodologies. Country
coverage varies by index, but we are able to map over
90% of the portfolio’s market value for each index
(data as of November 2024):
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Our assessment identified a higher exposure
to chronic and acute physical risks for lower-
and middle-income countries. This is due to a
combination of geographic vulnerability to climate
events, a lower ability to withstand financial shocks
and a lower capacity to adapt to a changing climate.
Most of our sovereign exposures are in developed
markets, in particular the Eurozone and Japan.
Emerging markets represent a smaller portion of the
sovereign bond book. For transition risk, high-income
economies with large GHG emissions face higher
vulnerability to transition risk but can also withstand
larger disturbances in their economy.
Corporates
Industry sectors are impacted differently by physical-
or transition-related climate risk based on the nature
of their business, geographic location, reliance on
the existing natural resources and climate, and
their GHG emissions footprint. To assess these
differences in our corporate investments portfolio we
use a heatmap approach to determine sector-based
exposure for corporate issuers for both fixed income
(primarily bonds, but also including some loans)
and listed equities, accounting for ~EUR 38 billion,
to determine the extent to which certain sectors
are sensitive to climate risk due to their operating
environment.
We identify sectors and sub-sectors by using
NACE
1
codes. As we adopt a phase-in approach,
we will keep refining our methodology to enable us
to estimate the potential financial impact on our
For the likelihood scale we use the country’s
sovereign bond rating as a proxy for resilience. We
apply the index-specific ranking methodology and
sovereign bond rating to determine where to set the
different risk exposure ranges.
Using multiple country risk indices can provide a
more comprehensive assessment of a country’s risk
profile, giving attention to individual exposures to
climate change, and increasing coverage of the risk
drivers we can assess. However, there are limitations
to this approach that should be considered, such as
a lack of methodological consistency, overlapping
indicators, variation in data time lags and the main
objective of each index. We are working to further
refine our approach over the coming years.
The output provides us with an overview of which
countries may have exposures sensitive to climate
change-related risks:
Countries with exposures sensitive to
climate-related risks
1
Acute Azerbaijan, Brazil, Colombia, Turkey.
Chronic Brazil, Côte d’Ivoire, Dominican Republic,
South Africa.
Transition Hungary, South Africa, Turkey, United Arab
Emirates.
1
Countries/sectors with small exposures sensitive to climate-
related risks are excluded.
corporate portfolio. We used a Climate Value-at-Risk
(CVaR) measure developed by MSCI ESG Research
UK Limited to assess climate exposure, a forward-
looking quantitative model that forecasts the present
value of future costs and benefits under different
IPCC- and NGFS-aligned climate scenarios. We
leverage the provider’s methodology to assess the
exposure of our assets to:
• Transition risk: covers policy risk quantifying
the direct and indirect costs of climate
regulations imposed on companies (scope 1, 2
and 3 emissions), and technology opportunities
accounting for additional profits arising from the
development of new technologies serving the
transition to a low-carbon economy.
• Physical risk: covers the financial impact of
extreme weather events, coastal and fluvial flood,
wildfire, river low-flow, tropical cyclones and
chronic effects, including extreme heat and cold,
heavy precipitation, snowfall and wind gusts.
We assessed the following scenarios for our
corporate issuers for 2030 and 2050 across physical
and transition risk:
• 1.5°C REMIND Disorderly (NGFS)
• 3°C REMIND NDC (NGFS National Determined
Contribution).
When applying these scenarios to our corporate
portfolio, we found the following (see table below):
1
Nomenclature statistique des Activités économiques dans la Communauté Européenne.
Sectors with exposures sensitive to climate change-related risks
Scenarios Transition (short) Transition (long)
1.5°C Specific or multiple sub-sectors within
sectors B – Mining and quarrying; C –
Manufacturing; D – Electricity, gas, steam
and air conditioning supply; G – Wholesale
and retail trade, repair of motor vehicles
and motorcycles; H – Transporting and
storage.
Multiple sub-sectors within sectors B – Mining and quarrying; C
– Manufacturing; D – Electricity, gas, steam and air conditioning
supply; E – Water supply, sewerage, waste management and
remediation activities; G – Wholesale and retail trade, repair of
motor vehicles and motorcycles; H – Transporting and storage; I
– Accommodation and food service activities; N – Administrative
and support service activities; Q – Human health and social
work activities; and S – other services activities.
3°C Specific sub-sectors within sector C
– Manufacturing, and H – Transporting
and storage.
Specific sub-sectors within sectors B – Mining and quarrying;,C
– Manufacturing; D – Electricity, gas, steam and air conditioning
supply; E – Water supply, sewerage, waste management and
remediation activities; and G – Wholesale and retail trade;
repair of motor vehicles and motorcycles, H – Transporting and
storage.
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As part of our CRA, we evaluated the potential
implications of climate change on our life and health
portfolio, categorising threats related to morbidity,
mortality, longevity and hospitalisation into physical
acute, physical chronic and transition risks. We relied
on internal expertise, scientific research and industry
reports, such as the Geneva Association paper
‘Climate Change: What does the future hold for health
and life insurance?’ to identify what parts of our
business could be sensitive to climate change. We
identified heatwaves (acute risk for life), air pollution
(chronic risk for life and health) and changes in air
pollution due to a transition to a low-carbon economy
(transition risk for life), vector-borne diseases
(chronic risk for health) and mental health, which we
classified as a climate-related secondary peril, as risk
drivers requiring further assessment.
For these risk drivers, we developed climate
scenario narratives that consider short- (2030),
and long-term time horizons (2050) developed in
line with RCP 4.5 and RCP 8.5 assumptions. We
used scientific and medical studies to assess the
baseline correlation between climate change and the
change in risk affecting a population, and linked the
research to climate projections. Using the climate
scenario narratives, we defined risk driver-level
shocks on a country basis and applied them in our
Solvency Capital Requirement. Using the developed
scenarios, we concluded that while on an individual
level specific groups such as people with existing
medical conditions, the elderly and the pregnant will
be impacted by climate change, overall we did not
observe a significant impact on our underwriting
Risk-mitigating measures for investments
Below, we list the common actions we take to
mitigate financial risk related to investments. These
are also relevant in the context of managing climate
risks:
• We manage market risks within risk limits and
other boundaries set by various policies and
standards. This ensures our investments are
well-diversified and that concentration risks are
limited per country, industry or issuer. We also
monitor IROs in the financial markets on a regular
basis, and reduce downside risk through hedging
programmes. Our Strategic Asset Allocation (SAA)
is designed to optimise capital generation within
acceptable risk levels.
• NN Group has formulated asset class-specific
strategies and incorporated them into our
internal Paris Alignment Standard for Proprietary
Assets. To decarbonise our proprietary asset
portfolio in accordance with trajectories aligned
with the Paris Agreement, we adopt a forward-
looking perspective and evaluate the credibility
of transition strategies. These assessments are
integrated into our investment selection process,
aiming to invest in assets that have credible
climate strategies.
• Active stewardship: we consider voting and
engagement as valuable tools in managing
sustainability risks. For climate risk, we develop
clear stewardship expectations, with milestones
and targets. While we prefer engagement over
divestment, we will consider divestment if we see
no potential to change a company’s behaviour
through engagement.
• Investment restrictions: we have environmentally
focused exclusion criteria in place that support our
risk management and strategy. We have a policy
to phase out thermal coal. Additionally, we have
a comprehensive Oil & Gas policy that excludes
unconventional oil and gas activities such as oil
sands production and shale energy and applies
strict criteria for new investments in conventional
activities.
• Developing best practice: sector initiatives assist
us in developing methodologies and undertaking
other activities that support us in realising
our sustainability goals. NN Group actively
contributes to industry bodies to define standards
on responsible investments. NN also joined
the European Commission’s Climate Resilience
Dialogue in 2023 as a member of the Platform
for European Insurance and Financial Services
(PEIF). The primary task of the Climate Resilience
Dialogue is to exchange views on how to address
the losses incurred from climate-related disasters
and to identify how the insurance industry can
contribute more to climate adaptation.
Insurance
Life and health
With the occurance of more frequent and severe
weather events, as well as chronic environmental
changes, there is growing concern about the adverse
impact on human health and the insurance life and
health portfolio. Extreme weather events potentially
cause injuries and fatalities, and climatic change can
exacerbate chronic morbidities and the spread of
vector-borne diseases.
The analysis shows an exposure sensitive to
transition risk for the industries mentioned, mostly
in a 1.5°C scenario and to a lesser extent in a 3°C
scenario, by 2050. While our analysis was performed
at a sub-sector level, individual sub-sectors include
only a limited number of companies, making its
average sector CVaR calculation less reliable.
Therefore we only show overall NACE codes, with
further refinement per company still to be carried out.
The output is comparable to market findings and
assessments, such as the Climate Policy Relevant
Sector classification. We see a larger sector
sensitivity in the 1.5°C scenario, reflecting the high
transition risk assumed, due to policies being delayed
and divergent across economies in this scenario
narrative. For 2030 and 2050 we identify limited
exposure to physical risk on a sector level. Only in
the 3°C NDC for 2050 do we identify two sectors with
exposures sensitive to physical risk: sectors F and H.
By using an external metric for our risk
assessment, we are subject to the limitations of the
methodologies. For example, the CVaR methodology
provides limited options to consider an entities own
resilience. There remain uncertainties around our
approach and we will work towards a more detailed
understanding of measuring our anticipated financial
effects from climate change.
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portfolio for life and health in the case of both RCP
4.5 and RCP 8.5 scenarios.
We acknowledge limitations in our scenarios that
require addressing over time. We determined
overall scenario impact to be the sum of the impact
of individual risk drivers applied on an overnight
basis to the current portfolio. Certain assumptions
were based on approximations due to limitations in
available data. The assessment does not consider
potential ‘second order effects’, such as population
migration, changes in distribution and access to
healthcare, or economic stability. Research on the
impacts of climate change on life exposures needs
to be further developed and we will continue to
monitor developments around climate change and its
potential impact on our life and health liabilities.
Non-life
NN Group has non-life insurance products across
many countries in Europe, but most of them are in the
Netherlands. We performed a CRA for the key product
lines in our Dutch portfolio. We held internal expert
workshops to assess which climate risk drivers
could have an impact on our portfolios, considering
an increase in claims frequency, damage severity
and/or product coverage. We identified storms, hail,
fluvial and pluvial floods (including precipitation)
before reinsurance, as risk drivers requiring further
assessment for the Fire and Other Damage insurance
book; and hail to the Motor Vehicle Liability book.
For health insurance, similar to life and income
protection, the life and health assessment showed no
sensitivity to climate-related risk.
As part of our phase-in approach, we are working
on assessing the potential impact of these hazards
in line with climate scenarios. In 2024, NN Non-
life used the MunichRe Location Risk Intelligence
(LRI) tool to assess the change in geographic risk
exposure of the full Dutch residential property book
by using geospatial information and climate scenario
projections in line with RCP 4.5 and RCP 8.5 for 2030
and 2050. We assessed storm surges created by
windstorms, fluvial flood and pluvial flood using a
precipitation stress index. The storm surge and fluvial
flood metrics consider current flood defences that
protect people and assets from physical impact.
The assessment showed that the Dutch residential
property book has minimal change in fluvial flood
and storm surge risk across both scenarios and
time horizons. For pluvial flood, the precipitation
stress index identified a risk exposure increase in
the portfolio for both scenarios and time horizons.
However, risk levels remained within a low to
medium risk exposure. We note that risk exposure
does not reflect an indication of potential damage,
and assessments have been performed without
considering mitigation from reinsurance. The tool
does not offer climate projections for hail and storms
at this stage. We will continue to improve our effort in
assessing the portfolio impact over time.
Risk-mitigating measures for liabilities
Sustainability risk management is integrated
throughout underwriting processes and the
business uses the following tools to implement its
sustainability risk management approach:
• Adjusting product offering: we offer a range
of products that help customers adapt to and
mitigate climate change, such as coverage against
severe weather events and defined contribution
life cycle pension products that promote
sustainable lifestyles. We also adapt existing
features in our insurance offerings to address the
climate-related needs of our customers, such as
providing cover for solar panels on residential and
commercial insurance policies.
NN Group also helps customers take precautionary
measures to prevent and minimise claims caused
by windstorms, extreme rainfall, hail or other
weather-related events driven by climate change.
• Monitoring: we monitor our claims experience,
and reprice products or adjust policy conditions
where necessary. Most of our P&C portfolio can be
renewed annually, allowing product repricing over
the short term. However, we apply such measures
cautiously, as longer-term affordability for
customers remains an important consideration.
• Reinsurance: external reinsurance will, under
certain conditions, partially mitigate potential
impact. We have a Group-wide catastrophe
reinsurance programme to protect against
the severity and frequency of large natural
catastrophes. Reinsurance covers are placed with
a diverse range of strongly capitalised external
reinsurers and reduce the losses to NN Group
from both large and smaller events. Both the
applicability of the external vendor models and
the reinsurance structure and cover are reviewed
annually.
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Nature (biodiversity and water)
As a responsible financial institution, we understand
the importance of preserving the natural environment
and the impact it has on society. Environmental
issues like the acceleration of biodiversity loss,
increased scarcity of water resources and climate
change are virtually never a standalone risk but
rather complex issues with interconnected social and
environmental implications.
Climate change is one of the key drivers of
biodiversity loss. At the same time, processes
such as species extinction, ocean acidification
and deforestation are reducing the capacity of
ecosystems to form carbon sinks, which are
instrumental in curbing further global warming.
At the same time, it is important to recognise
that environmental issues usually have a social
component as well. Sustainable water management,
for example, is important for supporting habitats and
ecosystem services such as the provision of surface
and groundwater and water flow maintenance. This
is why we have chosen to combine our disclosures
on water and marine resources, and biodiversity and
ecosystems.
Approach
We support the development of a holistic view of
environmental topics and have been broadening
our responsible investment approach to cover other
material environmental issues. However, in 2023,
NN recognised the importance of addressing global
nature loss and made the decision to increase our
focus on biodiversity and nature. As part of this
effort, we are taking steps to evaluate our proprietary
asset portfolio. This includes exploring baseline
measurements, policies and engagement strategies
that are specifically focused on nature.
Transition plan
NN Group has not yet developed a transition plan
in relation to nature, as we still need to improve our
impacts assessement, potentially develop a policy
on nature, set targets and define an implementation
plan. We may develop a transition plan over the next
five years. We are not currently considering the use
of biodiversity offsets as part of our biodiversity
strategy.
Nature-related considerations in ESG
integration
Systematic integration of ESG factors into investment
decision-making and active ownership practices
form the basis of our Responsible Investment (RI)
approach. Investments are managed by external
asset managers, who are required to consider ESG
risks and opportunities when making investment
decisions and engaging with investees. In practice,
this typically involves using a ‘materiality matrix’,
which helps to assess, per sector, which ESG risks
are most relevant for that sector. For example, in the
agriculture or consumer products and paper sector,
environmental risks associated with raw material
sourcing, pollution, and water and wastewater
management are often important, while in the
technology sector social issues like cybersecurity
and data privacy are considered more material. At
NN Group level, we consider systemic environmental
risk from a top-down perspective. To do this, we use
various proprietary and external tools to identify
and evaluate sustainability factors and risks. These
include the Strategic Risk Assessment (SRA) as well
as materiality assessment and stress testing, as part
of the Own Risk and Solvency Assessment (ORSA).
By using the tools we have as an asset owner,
such as proxy voting and engagement, we aim to
encourage sustainable development as part of our
ESG risk and opportunity management. Across our
engagement activities, we focus on themes such as
climate change, the journey to net zero, biodiversity
and natural capital, water, human rights and
governance.
Policies
To support these efforts in the area of responsible
investments, we have developed investment
guidance papers that are intended to be a basis for
discussion between NN Group and stakeholders on
ESG-related topics such as environmental topics
like water, deforestation, the circular economy, and
climate change and biodiversity, which are covered
in our Environmental Investment Guidance paper. By
publishing these papers externally, we aim to express
our position and use it to leverage change in the
sphere of our investment activities.
We have implemented exclusionary criteria for fossil
fuel activities (see ‘Responsible investment’, p. 139).
Oil sands production in particular, requires significant
amounts of energy and water, and the GHG emissions
associated with producing fuels from oil sands are
much higher than those from conventional crude
oil. Similarly, shale oil and gas extraction requires
substantial amounts of water and can contaminate
groundwater and surface water, posing risks to local
ecosystems and human health.
In 2025 we will explore how feasible and relevant it is
for us to further develop or consolidate these efforts
into a potential investment policy on nature.
Actions
Since signing the Finance for Biodiversity (FfB) Pledge
in December 2022, we have focused on actions in
five key areas of the pledge.
Collaborating and knowledge sharing
A natural first step towards meeting this pledge is
collaborating and sharing knowledge. To promote
best practices on biodiversity, NN Group conducts
dialogues with teams to raise awareness and
share knowledge on biodiversity among internal
stakeholders. We also took part in external
working groups, such as those of the FfB Target
Setting and Impact Assessment, to contribute to
industry frameworks and build internal capacity.
We also collaborate on a national level, for example
through the development of a joint framework for
developing policies that relate to biodiversity loss,
which we do through the Convenant Internationaal
Maatschappelijk Verantwoord Beleggen (Agreements
on International Responsible Business Conduct).
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Targets
We are currently setting our first targets to reduce
the impact of our proprietary assets on biodiversity
loss using industry standards, methodologies, and
guidelines from FfB. To support us in this process we
use the Nature Target Setting Framework for asset
managers and owners released by FfB in July 2024.
Our resulting Nature Action Plan for Proprietary
Assets outlines the initiatives we will undertake in
2025 to fulfill our initiation targets, or action targets
as defined by the FfB guidelines. Metrics are not
disclosed, but we will start to establish them once
targets are set.
These initiatives include:
• Including nature in our RI governance and
education. We aim to raise internal awareness
and knowledge about nature among investment
experts and other functions, such as Finance
and Risk, through training sessions and learning
modules. Potential topics include the materiality
of nature to investment portfolios, target setting
approaches and best practices.
• Enhancing our risk management framework
for nature. We will expand our biodiversity risk
assessment for investment to include other
asset classes, such as real estate, and engage
with external asset managers to improve
oversights of biodiversity impacts as part of
ESG integration.
Along with several other banks, insurers, asset
managers and asset owners, NN Group contributed
to Unlocking the Biodiversity-Climate Nexus, a
guide for financial institutions on managing the
connections between biodiversity and climate in
their investments and lending. Focusing on water,
we also contributed to a report intended to enhance
investors’ understanding of water-related risks; this
was an outcome of the BRIDGE project, launched
in 2023. In this project, we partnered with water
specialists Deltares and the World Wide Fund for
Nature (WWF), as well as peers conduct an analysis
of water risks for two critical watersheds, one in São
Paolo (Brazil) and one in Chennai (India). By doing
so, we highlight the need for more up-to-date and
consistent location-specific data and scenarios
as well as an understanding of the risk profiles of
watersheds and supply chains.
Engaging with companies
As part of our ‘active ownership’ approach, we have
prioritised expanding our engagement initiatives
around biodiversity; these include Nature Action 100,
which can be considered the biodiversity equivalent
of the Climate Action 100+ initiative. We are also
participating in the Ceres Valuing Water Finance
Initiative to address the growing water-related
challenges faced by companies worldwide, such as
water quality and quantity, and access to water.
Assessing impact
In January 2024 we published our white paper on
biodiversity, available on our external website, which
details the results of the ENCORE assessment and
evaluates the impacts and dependancies on nature
of our corporate investment portfolio. Using our
financial exposure to each sector and the sector-
average materiality from ENCORE, we assessed
167 sub-sectors connected to 11 drivers of
biodiversity loss and the 21 ecosystems they
depend on.
Specifically on water, the assessment covered
our dependency on ecosystem services, such as
providing surface and ground water, water flow
maintenance and water quality, as well as water-
related drivers of biodiversity loss such as water
pollutants, water use and freshwater ecosystem use.
As highlighted in the white paper, we identified high
to very high impacts on water pollutants and water
use through our investments in utilities, materials,
information technology, industrials, healthcare,
consumer staples, consumer discretionary and
communication services sectors.
One of the main drawbacks of the ENCORE analysis is
the limited granularity for company-level assessment.
For example, only one production process can be
assigned to a company and the use of sector-average
materiality does not differentiate exposure between
companies within the same sector, such as the
reliance on high-risk commodities. In collaboration
with our external asset managers and considering
the latest data sources, we aim to enhance the
assessment with more recent data, as well as
company- and location-specific data as input for
re-evaluating the materiality matrix we use as part
of our ESG integration methodology.
• Developing a comprehensive approach to
halting and reversing nature loss. We will
explore approaches for baseline measurement and
‘nature solutions’, develop a nature policy, and
strengthen our biodiversity engagement strategy.
We are currently exploring and developing our
approach on biodiversity and nature. Therefore, we
have not yet established firm timeframes for our
actions on nature. We aim to report progress on
these initiatives by 2026. Our learnings will help
us prepare for setting potential portfolio targets on
nature in the near future. The implementation of the
actions does not require significant operational or
capital expenditure outside the regular business
cycle.
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discuss the option with the customer. If they choose
cash settlement over spot repair, the amount of the
settlement will match the cost of spot repair.
Making sustainable recovery the norm
We believe that making sustainable recovery the
norm is key to reaching our ambition, which is why
we introduced our sustainable recovery network.
This network is accessible to all business lines and
used most actively across our retail portfolio. We are
investing in internal and external communication to
make both colleagues and customers aware of this
network and encourage them to use it. As the claims
process becomes ever more digital, sustainable
repair is becoming the standard in our Straight
Through Processing (STP) claim handling.
Electronics recovery
We collaborate with companies that repair (mobile)
electronics to avoid replacement where possible;
these partners are part of our sustainable repair
network. Our guiding principle is that if damage
to a mobile electronic device can not be repaired,
the client is offered a refurbished device. If the
client does not want this, they can opt for a cash
settlement.
Targets
The most important target for the property domain
in the context of the circular economy is to increase
our repair rate of damages in the retail insurance
business (as defined under ‘Policies’ above) in
the Netherlands to 70% by 2026. We calculate
sustainable damage repair based on the total
number of home insurance claims sent to our
sustainable damage repair network, divided by the
Sustainable repair
Approach
NN Group recognises that repair rather than
replacement can significantly reduce environmental
impact, conserve resources and support a circular
economy. That is why we are committed to advancing
sustainable repair practices in the insurance industry.
Policies
NN Non-life’s Sustainable Repair Policy defines the
scope and objectives of sustainable repair, as well as
identifying the related material IROs. By 2026, if not
sooner, we aim to have 70% of our repairs to retail
property homebuilding in the Netherlands (including
items nailed to the property buildings) carried out by
our sustainable repair network. This applies to the
retail insurance business NN Non-life, which consists
of NN, OHRA, SNS Insurance and ING Insurance.
NN International, ABN AMRO Verzekeringen and the
retail portfolio of the business line P&C Intermediary
are out of scope.
We have defined key actions to achieve these
objectives. We intend to translate the 2026 70%
target for the retail insurance business into other
sustainable measurements, such as CO
2
avoidance,
and those related to the different stages of the
circular economy, as soon as we have access to
relevant data and calculation methods. The policy
scope encompasses further development of a
sustainable repair network in the Netherlands,
representing a strategic step towards a circular
economy. It not only supports the reduction of
waste through the repair and reuse of products but
also promotes the use of renewable resources and
sustainable practices.
Material impacts
Repairing damaged items through our sustainable
repair network will have an actual and positive impact
on the environment by extending the life of products,
decreasing waste and reducing demand for new
materials.
With its Sustainable Repair Policy, NN Non-life
aims to meet the requirements of the Manifesto
Sustainable Damage Repair developed by the Dutch
Association of Insurers (Verbond van Verzekeraars),
which outlines five principles:
1. Recovery becomes the norm
2. Do it together!
3. Price is not always leading
4. Ensure internal support
5. Prepared for the future
Actions
We focus on two main areas: increasing steering
towards sustainable repair and upgrading the quality
of the circular techniques of the repair network.
One action we undertook was engaging the Impact
Institute to carry out a life cycle assessment for
countertops and kitchen cabinets, comparing repair
with replacement. We also identified three main
actions for NN Non-life Property and Casualty (P&C)
to help it reach its ambition:
• Focusing on spot repair
• Making sustainable recovery the norm
• Electronics recovery.
Spot repair
Spot repair involves repair where the damage occurs,
be it to a vehicle or property; we regard it as a key
activity, contributing to CO
2
avoidance. In those
cases where spot repair is an option, we always
total number of home insurance claims processed.
We use a dashboard to monitor the progress of this
ambition as presented below. We base all targets
on pilots we ran that met three conditions: goods
can be repaired, NN Group can decide whether or
not to repair, and costs and effort involved are more
favourable than replacement. (In some cases, repair
is more expensive than either replacement or cash
settlement.)
Sustainable damage repair
Figures for retail insurance business in the Netherlands
(NN, OHRA, SNS Insurance and ING Insurance) for
property homebuilding.
2024
1
2023
% Actuals /
Target
2
Target 2026
% claims
sent to
repair
network 66% 62% −6% 70%
1
The sustainable damage repair for our property homebuilding
covers appr. EUR 80 mln GWP of NN Non-life.
2
The development of the current period claims repaired in % vs the
target.
The 66% in the table above exceeds our target of
55% for the retail channel (as defined under ‘Policies’
above) for a number of reasons: during the First
Notification Of Loss, we targeted our communication
about our sustainable repair network during the
claims flow; we added sustainable repair to our STP
claims journeys and trained employees to direct
damage claims to the sustainable repair network;
we added repair partners to the network to broaden
its scope, and we elevated sustainable repair to
become the norm, integrating it into new and existing
policies.
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The following sections give EU Taxonomy information
related to NN Group’s investments and underwriting
activities. The first section covers quantitative and
qualitative eligibility and alignment information of
the investments. In the second section, we disclose
eligibility and alignment information related to NN
Group’s non-life underwriting activities. Certain
required disclosures are contained in these sections,
with the rest of the detailed EU Taxonomy information
presented in the EU Taxonomy disclosure tables, see
‘Annex’, p. 233.
For the EU Taxonomy information related to NN
Group’s banking activities reference is made to the
EU Taxonomy disclosures contained in the NN Bank
2024 Annual Report.
In December 2023, the EU Commission published
a draft commission notice on the interpretation
and implementation of certain provisions of the
EU Taxonomy regulation. This draft notice was
finalised in November 2024. NN Group compared
the guidance in the notice to the approach that was
applied in preparing the disclosures in the Annual
Report. Certain differences were identified, which
are explained below. NN Group will continue to
monitor this and any new additional guidance and will
consider the impact on NN Group’s disclosures going
forward:
• The notice requires that parent entities of
financial conglomerates that have different
activities should report the KPI per segment as
EU Taxonomy disclosures
This section contains the disclosures required by the
EU Taxonomy Regulation along with descriptions of
the approach and decisions NNGroup has taken to
comply with this regulation.
To meet the EU’s climate and energy targets for
2030, and to achieve the objectives of the European
Green Deal for the EU to be climate neutral by
2050, it is important to direct investments towards
sustainable projects and activities. To contribute to
this, the EU has created the EU Taxonomy, a common
language with a definition of what is sustainable,
and a classification system for sustainable economic
activities.
The EU Taxonomy Regulation requires NN Group
to disclose information, such as the proportion
of covered assets that finance, or are invested in,
taxonomy-eligible, non-eligible and taxonomy-
aligned economic activities, as well as the proportion
of taxonomy-eligible, non-eligible and taxonomy-
aligned non-life insurance gross written premium
income. Taxonomy-eligible economic activities are
those activities that are described under one of the
six environmental objectives covered by the EU
Taxonomy:
1
The technical screening criteria (TSC) are specific characteristics that can be used to determine whether an economic activity provides a
substantial contribution to climate change mitigation or adaptation. The criteria also aim to avoid significant harm to other objectives and
comply with relevant laws.
Climate-related objectives
(1) climate change mitigation
(2) climate change adaptation
Non-climate-related objectives
(3) sustainable use and protection of water resources
(4) transition to a circular economy
(5) pollution prevention and control
(6) protection and restoration of biodiversity and
ecosystems
For economic activities to be aligned with the EU
Taxonomy they need to substantially contribute to
any one of the environmental objectives by adhering
to the technical screening criteria (TSC)
1
. In addition,
these activities should do no significant harm to any
of the other EU Taxonomy environmental objectives
and respect minimum social safeguards. As required
by the EU Taxonomy Regulation, NN Group discloses
taxonomy-eligibility related to the six environmental
objectives and taxonomy-alignment related to the
two climate objectives in this section of the Annual
Report.
Since 2021, NN Group has been required to disclose
taxonomy-eligibility information related to the two
climate objectives. Since 2023, NN Group has also
been required to disclose taxonomy-alignment
information related to the two climate objectives and
taxonomy-eligibility information related to the four
non-climate environmental objectives.
well as the weighted average KPIs for the sum
of the segments. This would result in NN Group
disclosing the KPIS separately for its insurance
and its banking activities. NN Group discloses
all its activities (insurance and banking) in a
consolidated manner in the format of the dominant
activity, which is insurance. NN Bank reports
stand-alone EU Taxonomy disclosures in its own
Annual Report and NN Group refers to the NN Bank
Annual Report to access those disclosures.
• The notice requires that the prudential scope of
consolidation should be used, whereas NN Group
uses the scope of consolidation of the IFRS Annual
Accounts. Had NN Group used the prudential
consolidation scope, information related to NN
Japan and NN Bank would have been excluded.
• The notice requires that green bonds issued by
non-NFRD companies should be included in the
numerator of the investment KPI. For 2024, NN
Group has not included these bonds (which has a
fair value of EUR 478 million) in the investment KPI
numerator.
All amounts are in millions of euros unless indicated
otherwise.
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Investments
The Investment KPI represents the amount and
extent to which NN Group’s investments are directed
at funding taxonomy-aligned economic activities.
We use externally available information to report
eligibility and alignment for the mandatory
disclosures. For investments for which there is no
externally reported information available, we use
estimates
2
. The estimated eligibility and alignment
are reported voluntarily
3
and are therefore not part
of the mandatory disclosures. With the increase of
data availability and regulatory clarity we expect our
investment KPI to develop further. However, in 2024
NN Group still considers voluntary disclosures to be
relevant.
Under the EU Taxonomy, exposures to derivatives and
non-NFRD companies cannot be eligible and aligned,
and are therefore excluded from the numerator of
the eligibility and alignment disclosures but included
in the denominator. Other assets
4
(non-investment
assets) and exposures to central governments,
central banks and supranational issuers (sovereign
entities) are excluded from both the numerator and
the denominator of the EU Taxonomy disclosures.
This amounts to EUR 51,695 million and is the
difference between total assets on the NN Group
consolidated balance sheet and assets covered by
the KPI (covered assets).
The table below summarises the key EU Taxonomy
information of NN Group’s investments. NN Group’s
assets covered in the Investment KPI are EUR
158,680 million. Out of these, the mandatory
taxonomy-alignment (Investment KPI) based on
turnover is 10% and 2% based on CapEx. The
main driver of the turnover Investment KPI is retail
mortgage loans, which are linked to the real estate
activity ‘Acquisition and ownership of buildings’ in
the EU Taxonomy.
Financing this activity contributes to the climate
change mitigation objective. The investments in the
covered assets that are eligible, but not aligned with
the TSC set out in the EU Taxonomy, amount to 25%
based on turnover and 2% based on CapEx. Together
with the alignment figures, this forms the eligible
investments proportion of NN Group’s covered
assets. The remainder of covered assets is the non-
eligible portion, which amounts to 64% based on
turnover and 97% based on CapEx.
Turnover CapEx
Amount Proportion % Amount Proportion %
Taxonomy-alignment 16,586 10% 2,642 2%
Of which related to CCM 16,478 10% 2,361 1%
Of which related to CCA 108 0% 281 0%
Taxonomy non-alignment 40,302 25% 2,582 2%
Taxonomy-eligible 56,888 36% 5,224 3%
Taxonomy non-eligible 101,792 64% 153,456 97%
Assets covered by the KPI 158,680 100% 158,680 100%
Mandatory Voluntary
1
Mandatory Voluntary
1
The weighted average value of all the investments of NN
Group that are directed at funding, or are associated with
Taxonomy-aligned economic activities relative to the value
of total assets covered by the KPI, with following weights for
investments in undertakings per below:
The weighted average value of all the investments of NN
Group that are directed at funding, or are associated with
Taxonomy-aligned economic activities, with following weights
for investments in undertakings per below:
Turnover-based: %
10% 3%
Turnover-based: amount
16,586 5,135
Capital expenditures-based:
%
2% 0%
Capital expenditures-
based: amount
2,642 297
The percentage of assets covered by the KPI relative to total
investments of NN Group (total AuM). Excluding investments
in sovereign entities.
The monetary value of assets covered by the KPI. Excluding
investments in sovereign entities.
Coverage ratio: %
100% 100%
Coverage: amount
158,680 158,680
1
Estimated EU Taxonomy figures are reported on a voluntary basis in addition to the mandatory EU Taxonomy figures, therefore there is no
overlap in mandatory and voluntary figures.
Investment KPI
This section contains a mandatory Investment
KPI disclosure. The remainder of the mandatory
disclosures, including the Gas and Nuclear
disclosures and the disclosures on the four non-
climate related objectives can be found in EU
Taxonomy disclosure tables, see ‘Annex,’ p. 233.
2
The only exceptions are externally managed mortgages, which are presented as non-aligned in the reported figures in the case of no data
available.
3
Group reports against the EU Taxonomy voluntarily because it recognises the importance of increasing transparency about how companies
are progressing in changing their response to, and adapting to, climate change, even if the regulation is evolving and not yet mature.
4
This relates to assets included in the following balance sheet lines: Insurance and Reinsurance contracts, Property and equipment,
Intangible assets, Deferred tax, and Other assets.
Based on the information available, the table below
reflects the proportion of assets covered by the KPI
(covered assets) that are taxonomy-aligned, related
to the two climate objectives. Consistent with the
summary table above, the mandatory taxonomy-
alignment (Investment KPI) based on turnover is 10%
and 2% based on CapEx.
Voluntary taxonomy-alignment based on turnover of
3% and 0% based on CapEx is shown. This voluntary
turnover KPI amount is mainly driven by investments
in real estate for which the alignment is estimated
based on buildings with at least an energy label of A.
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asset managers, investments funds and exposures
to other counterparties and assets consisting
of mortgage loans to retail clients, direct real
estate investments, derivatives, or sovereigns),
are classified as investments in non-financial
undertakings. For classifying investments into
counterparties from the EU and non-EU, internally
available data on country of incorporation of
counterparties was used.
NN Group’s weighted average of EU Taxonomy values
of investments is based on the proportion of EU
Taxonomy-aligned economic activities of investee
companies measured by their turnover and CapEx
KPIs. The green asset and investment ratios for
investments in banks and insurance companies
respectively are not presented as the necessary
alignment information is not yet available.
For determining the substantial contribution
criteria of mortgage loans, NN Group used Energy
Performance Certificates (EPCs) for the majority
of mortgage loans. The substantial contribution
criteria include an option of selecting the top 15% of
buildings based on Primary Energy Demand (PED).
Where no EPCs are available, the top 15% PED
approach is applied.
In case of unavailable data for investments subject
to a mandatory taxonomy-eligibility and alignment
assessment, NN Group has presented these
investments as taxonomy non-aligned for external
retail mortgage loans and real estate investments
and non-eligible for investments in NFRD companies
and investments funds.
NN Group’s mandatory eligibility is 36% based on
turnover and 4% based on CapEx. This turnover-
based figure consists of 10% aligned and 25%
non-aligned investments and the CapEx-based figure
consists of 2% aligned investments and 1% non-
aligned investments. The difference between these
turnover and CapEx-based figures can be explained
by the fact that retail mortgage loans are only
included in the turnover-based figure as they relate to
the financing of existing buildings.
The sum of alignment, non-alignment and non-
eligible must equal covered assets. As data is not
available for all investments for which EU Taxonomy
data is relevant, an adjustment was required at
aggregated level. As real estate investments are
100% eligible, the adjustment was made to non-
aligned for the part of investments with no available
data. For all other investments for which data is
expected but not available, the adjustment is made
to non-eligible as eligibility is unknown.
Assumptions
NN Group collected EU Taxonomy data related to
the two climate objectives in respect of mortgage
loans to retail clients internally and from external
data providers for direct investments and investment
funds where these data providers had this data
available. For direct investments, NN Group has
5
The EU Taxonomy currently applies only to companies that are subject to the Non-Financial Reporting Directive (NFRD), which are large
public-interest entities with more than 500 employees. Public-enterest Entities are defined as follows: (a) EU companies with transferable
securities (debt or equity) on an EU-regulated market; (b) credit institutions; or (c) insurance undertakings. Large companies are defined as
companies which, on balance sheet date, exceed at least two of the three following criteria: (a) a balance sheet total of EUR 20 million; (b) a
net turnover of EUR 40 million; (c) an average of 250 employees during the financial year.
6
These are investment funds that primarily invest in listed equities and debt instruments.
Non-life underwriting
The Underwriting KPI represents the amount and
extent to which NN Group’s non-life underwriting
activities are directed at taxonomy-aligned economic
activities.
In 2024, NN Group reports on both taxonomy-
eligibility and alignment for its underwriting
activities.
The EU Taxonomy-related activities covered by
the underwriting disclosures relate to non-life
(re)insurance activities consisting of the underwriting
of climate-related perils. To assess taxonomy
alignment, NN Group first identified the Lines of
Business (based on the Solvency II lines of business)
containing policies with terms related to the
treatment of ‘climate perils’ under the EU Taxonomy.
NN Group then selected the Solvency II lines of
business for which one or more climate-related perils
are priced separately.
assessed the NFRD
5
status of its counterparties
using internal and external data.
For investment funds
6
, NN Group has not used
look-through information regarding the exposure to
non-NFRD issuers and decided to consider these all
as NFRD issuers. Look-through information is only
used for calculating the eligibility and alignment of
the fund related to the two climate objectives using
the weighted average exposure to taxonomy-eligible
and aligned economic activities of the investments
in the fund. If EU Taxonomy data is not available
for investment funds, NN Group presented these
exposures as taxonomy non-eligible (zero in the
numerator and for the full amount in the denominator
of the investment KPI). Data availability is expected
to improve in the coming years when reported
eligibility and alignment data increases.
For type of counterparty information, all investment
funds are classified as exposures to financial
undertakings. NN Group's investments in other
insurance companies, banks and asset managers,
are also classified as exposures to financial
undertakings. Investments in other counterparties
and assets consist of mortgage loans to retail clients
and direct real estate investments. The remaining
investments (i.e. those that are not classified as
investments in other insurance companies, banks,
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The table below shows the climate-related policy
terms that are used in the underlying products of
the Solvency II lines of business, which have a direct
correlation with weather-related events, such as
windstorms, and mainly refer to properties, vehicles
and personal belongings.
Applicable Solvency II lines of business
Climate-related
policy terms
Use of climate-
related margin Type of climate-related peril
Medical expense No No Not applicable
Income protection No No Not applicable
Workers’ compensation No No Not applicable
Motor vehicle liability No No Not applicable
Other motor Yes Yes Windstorm, hail, river flood
Marine, aviation and transport Yes No Not applicable
Fire and other damage to property Yes Yes Windstorm, hail, river flood
Assistance Yes No Not applicable
eligibility approach the percentage of eligibility but
not aligned premiums would be 41%. NN Group
has taxonomy alignment of 0% for its underwriting
activities as NN Group does not yet fully meet the
minimum safeguards criteria under the EU Taxonomy.
For further information on minimum safeguards see
p. 175.
NN Group reports the percentage of products
measured by gross written premiums that cover
at least one aspect of climate-related perils (i.e.
measuring the premium at product level). Therefore,
only the share of premium covering specific climate
risks is considered taxonomy-aligned. This results
in a more required taxonomy alignment percentage
compared to when the climate-related coverage
is embedded in another, wider product; where the
full premium of this product qualifies as taxonomy-
aligned, provided that the TSC are fulfilled.
The interpretation and assessment of the TSC
for insurance activities was based on NN Group’s
interpretation of the current legislation and
guidance published by the European Commission.
NN Group continues to monitor developments and
interpretations, but different interpretations of the
regulations in the EU Taxonomy may exist.
In 2024, NN Group reports gross written premiums
of EUR 4,078 million included in the Underwriting
KPI, of which the taxonomy alignment (Underwriting
KPI) is 0%. The percentage of eligible but not
aligned premiums is 2% under the split premium
for eligibility approach. Under the full premium for
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Underwriting KPI
The NN Group Underwriting KPI represents the
amount of NN Group’s non-life gross premiums which
relate to taxonomy-aligned insurance activities.
This section covers the mandatory Underwriting
KPI template. Based on the information available,
the table below reflects the proportion of premiums
that are taxonomy-aligned based on the approach
explained above. The taxonomy-aligned underwriting
activities is 0%. Gross premiums included in the table
relates to the Netherlands Non-life segment. The
difference with gross premiums written in Note 28
Segments to the Annual accounts relates to non-life
premiums in certain international businesses.
Split premium method for eligibility and the split premium method for alignment
Substantial contribution to climate change adaptation DNSH (Do No Significant Harm)
Economic activities
Absolute
premiums, 2024
Proportion of
premiums, 2024
Proportion of
premiums, 2023
Climate change
mitigation
Water and marine
resources Circular economy Pollution
Biodiversity and
ecosystems
Minimum
safeguards
Amount % % Y/N Y/N Y/N Y/N Y/N Y/N
A.1. Non-life insurance and reinsurance underwriting taxonomy-aligned activities
(environmentally sustainable) 0 0 0 Y Y Y Y Y N
A.1.1 Of which reinsured 0 0 0 Y Y Y Y Y N
A.1.2 Of which stemming from reinsurance activity 0 0 0 Y Y Y Y Y N
A.1.2.1 Of which reinsured (retrocession) n/a n/a n/a n/a n/a n/a n/a n/a n/a
A.2 Non-life insurance and reinsurance underwriting taxonomy-eligible but not
environmentally sustainable activities (not taxonomy-aligned activities) 71 2% 1% n/a n/a n/a n/a n/a n/a
B. Non-life insurance and reinsurance underwriting Taxonomy-non-eligible activities 4,007 98% 99% n/a n/a n/a n/a n/a n/a
Total (A.1 + A.2 +B) 4,078 100% 100%
Note:
The total non-life insurance and reinsurance premium amount in this table relates to the Netherlands Non-life segment. The difference with gross premiums written as per the Annual Accounts relates to non-life premiums in certain international businesses.
NN Group N.V. Annual Report 2024 | 175
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To achieve a substantial contribution to climate
change adaptation NN Group has assessed the
following criteria:
Using forward-looking climate risk modelling
as basis for pricing
Relevant climate-related perils for NN Group’s
business such as windstorm and hail are taken
into account in the partial internal model for P&C
catastrophe risk. The partial internal model and
insights from the reinsurance programme are used
as a basis for pricing. In the ORSA process, we use
forward-looking climate-related scenarios to validate
the model. NN Group aims to further develop the use
of such scenarios and analyses, e.g. for river flood.
NN Group is assessing the impact under various IPCC
scenarios and time horizons.
Risk-based rewards for policyholders'
preventive actions
In NN Group’s Non-life insurance underwriting and
pricing activities, NN Group provides its policyholders
with incentives (where applicable and practicable)
to take risk-mitigating measures against climate
damage by means of (standard) product conditions
for the cover, and/or by setting price incentives.
These may, for example, include a premium discount
or premium surcharge, a deductible adjustment,
standard coverage for climate adaptation measures
with no premium surcharge, or a discount on the
purchase. For Solvency II lines of business ‘Fire
and other damage to property’, NN Group’s retail
home insurance product fulfils this criterion. It offers
standard conditions for preventive actions that (in)
directly contribute to the reduction of CO
2
emissions
and against climate damage; it also offers a premium
discount when using a sustainable damage repair
network. ‘Other motor’, NN Group’s mileage
insurance product offering consumers an incentive to
drive less, also fulfils this criterion.
Innovative solution for insurance coverage
Where possible, NN Group offers solutions to close
existing protection gaps, e.g. for flood risk. We have
extended the coverage of our policies to include
protection against a breach of secondary dykes.
Through our membership of the Dutch Association
of Insurers and our intensive involvement in climate
change-related topics, we investigate risk-mitigating
market solutions, including possibilities to provide
protection against losses resulting from primary dyke
flood risk.
Sharing of data
As a member of the Dutch Association of Insurers,
NN Group shares (climate-related claims) data with
the Association's Digital Analytics Centre. This
data can then be used for analytical research when
deemed necessary.
High level of service after a disaster
NN Group complies with the Code of Conduct
for Claims Handling and acts within applicable
(reasonable) periods. In this regard no structural
negative deviations have been identified regarding
recent calamities by the Foundation for the
Assessment of Insurers (STV) or by a judicial
authority. In the event of a (climate-related)
emergency, NN Group makes information relating to
procedures for taking additional measures available
to the public, including via the website.
Do No Significant Harm (DNSH)
Products that are aligned with the taxonomy
criterion ‘substantial contribution to climate change
adaptation’, must also be checked in relation to the
Do No Significant Harm (DNSH) criterion. Economic
activities that do not comply with the taxonomy’s
requirement for sustainable economic activities
cannot be considered taxonomy-aligned. For a
general insurance company, the DNSH criterion
is also an inherent part of the climate change
adaptation objective. For the non-life insurance
activity, only DNSH requirements relating to the EU
Taxonomy climate change mitigation environmental
objective apply. In relation to climate change
mitigation, this means that the insurance of activities
such as the production, storage, transport and
processing of fossil fuels must be deducted from the
earned premiums that are deemed to comply with the
criteria for sustainable non-life insurance. NN Group
has used NACE codes registered in its insurance
administration systems as the basis for identifying
relevant activities in the portfolio. The number of
activities that can be linked to DNSH after this review
would be deducted from the activities that are
covered by the taxonomy criterion.
We note that it is not possible to deduct a premium
for customers with a different SBI/NACE code, who,
for example, occasionally transport fossil fuels, from
the premiums earned that are deemed to meet the
criteria.
Minimum safeguards
In order to be aligned, the EU Taxonomy Regulation
also requires products to be compliant with the
Minimum Safeguards. These minimum safeguards
can be regarded as criteria or processes for
responsible business conduct, applicable both to the
products as well as NN Group as a corporate entity.
To meet the criteria of responsible business conduct,
both NN Group and the products in its value chain
will have to demonstrate compliance on the following
topics:
• human rights including workers’ rights
• anti-bribery and corruption
• taxation
• fair competition.
For the Investment KPI, NN Group has interpreted
that minimum safeguards do not need to be assessed
for mortgage loans.
For the Underwriting KPI, NN Group is deemed not to
be in full compliance with the minimum safeguards
criteria. As NN Group adheres to the OECD Guidelines
for Multinational Enterprises and is a member of
Global Compact, it adheres to principles of human
rights, labour rights, environmental protection and
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KPI Turnover multiplied by revenue and dividing
that sum by the total of the revenue and the gross
premiums disclosed in the EUT underwriting KPI
table to the total of the Underwriting alignment
KPI multiplied by the gross premiums disclosed
in the EUT underwriting KPI table and dividing
that sum by the total of the revenue and the gross
premiums disclosed in the EUT Underwriting KPI
table. Revenue is defined as the sum of insurance
income, the following components of investment
result (interest result, income from investments in
real estate, dividend income and other investment
income), and fee and commission result.
• The weighted average CapEx-based KPI of NN
Group is 1.6% (2023: 0.8%). This is calculated
by adding the total of the Investment alignment
KPI Capex multiplied by the revenue and dividing
that sum by the total of revenue and the gross
premiums disclosed in the EUT underwriting KPI
table to the total of the Underwriting alignment
KPI multiplied by the Gross premiums disclosed
in the EUT underwriting KPI table and dividing
that sum by the total of revenue and the gross
premiums disclosed in the EUT Underwriting
KPI table. Revenue is defined as the sum of
insurance income, the following components of
investment result − interest result, Income from
investments in real estate, dividend income and
other investment income) and fee and commission
result.
combating bribery and corruption, as documented
in NN Group’s most recent annual Communication
of Progress, which is listed on the Global Compact
website.
NN Group also has anti-corruption policies in
place via , for example, the Code of Conduct and
its underlying policies and standards, such as the
Outside Positions and Outside Interests standard,
the Gifts and Events and Business Meals policy and
the Financial Economic Crime policy. To become
compliant, additional steps have been determined in
2024 following the preparation of a social roadmap.
Next steps will be performed in combination with
further implementation of the OECD Guidelines.
For NN Group’s products in the value chain we deem
NN Group not yet compliant. On adherence to the
minimum safeguards, due diligence processes
will be enhanced on screening and monitoring
business sector clients. NN Group has established a
Responsible Insurance Underwriting Committee to
oversee achieving these next steps.
Weighted average KPI
As required by the EU Taxonomy NN Group has
calculated a weighted average turnover-based KPI
and a weighted average CapEx-based KPI as follows:
• The weighted average turnover based KPI of NN
Group is 8.0% (2023: 8.8%). This is calculated
by adding the total of the Investment alignment
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Investing in positive impact
Responsible investment is an important
part of NN Group’s strategy. We aim not
just to mitigate any negative
environmental impact our investments
may have, but to seek out those with
positive impact, like climate solutions.
Impact story
EUR 12.8 billion
total investments in
climate solutions at
year-end 2024
NN Group N.V. Annual Report 2024 | 178
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We define ‘climate solutions’ as investments in economic activities that
contribute substantially to climate change mitigation or adaptation.
In 2024, investments in climate solutions for our proprietary assets
portfolio reached a total of EUR 12.8 billion. Marieke van Kamp, Head
of Private Markets at NN Group Investment Office: ‘We aim to combine
strong investment returns with a focus on ESG. Climate change is a
critical issue, which is why we are committed to doubling the amount
we invest in climate solutions by 2030 against our base year 2021,
working with our teams and asset managers. Our efforts span sectors
and markets, across debt and equity, demonstrating the comprehensive
approach we take to addressing climate change.’
Steel project in Sweden
This year we entered a EUR 350 million partnership aimed at financing a
portfolio of assets focused on climate change mitigation and adaptation,
targeting investments that include sectors beyond traditional renewable
energy generation. The first investment finances a large-scale green
steel project in Sweden, which aims to produce steel with up to 95%
lower CO
2
emissions than steel produced in coke-fired blast furnaces.
Catalysing the transition
NN Group also collaborated with an asset manager to initiate
an investment fund for climate solutions, which aims to finance
infrastructure assets providing solutions to the challenges of climate
change. The fund focuses on European projects in the sectors of
wind, solar, hydro, public transport, EV charging, batteries and energy
management solutions in its aim to catalyse the transition to a resilient,
low-carbon economy.
Energy and efficiency efforts in the Netherlands
In the Netherlands we participate in the Dutch Climate Action Fund,
which targets investments in projects and companies that aim to
support the reduction of carbon emissions. The fund may invest in
energy efficiency, e-mobility, energy storage and hydrogen, as well
as renewable energy generation. Meanwhile, our Positive Impact
Programmatic Venture (PIPV) invests in Dutch sustainable and affordable
residential real estate with the intention of adding energy-efficient
buildings to the sector, while also helping address the lack of good,
affordable rental housing. PIPV targets a reduction of 80% of landlord-
controlled greenhouse gas emissions, procuring 100% renewable
electricity by 2030 and net-zero operational emissions by 2035.
Green bonds to finance environmental projects
We also invest in green bonds, their proceeds being used for
environmental projects. One such bond is the Dutch government’s
second green bond, which focuses particularly on climate adaptation
and water, with ‘blue’ expenditures earmarked to protect the country
from flooding, mitigate the impact of climate change and ensure supplies
of freshwater. This investment aligns closely with our ambition to help
mitigate water risk.
‘We are committed to further
expanding our investments in
climate solutions.’
Marieke van Kamp, Head of Private Markets
Contents
Own workforce 183
Workers in the value chain 195
Community investment 199
Consumers and end-users 203
NN Group N.V. Annual Report 2024 | 179
Social
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Social
Our purpose is to help people care for what matters
most to them. It reflects the kind of company we
aspire to be – one that delivers long-term value
for all stakeholders by considering their interests.
We have identified the following groups as key
stakeholders: customers, colleagues, business
partners, investors, analysts, regulators, government
agencies, agents and intermediaries, societal and
network organisations, expert groups and industry
associations. We recognise that our success is
deeply intertwined with the well-being of our
employees, the communities we serve and society at
large.
As an employer, we value the people who work
for us and prioritise their well-being, safety and
professional growth. We foster an inclusive
environment that celebrates diversity, promotes
work/life balance and encourages collaboration.
Through competitive compensation, benefits and
pension contributions, we empower our workforce to
thrive. Furthermore, through our roles as investor and
business partner, we affect the lives of many people.
We want to contribute to the well-being of workers
in the value chain and are committed to making
sustainable decisions across our broader value chain,
from procurement to investments. Our commitment
to social responsibility also extends to customers.
Transparency, ethical practices and fair treatment
are at the core of our interactions. We actively seek
feedback from customers and end-users to improve
our products and services and to align our business
practices with their best interests, needs and
expectations.
Positive impact
Negative impact
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Social material matters
NN workers’ secure and fair employment
Workers in the value chain – secure and fair
employment
Equal treatment and opportunities for all
Workers in the value chain – child labour and
forced labour
Human capital development
Clear and secure data
Community investment
Financial inclusion
Investments
Business partners
Own operations
Products and services
Employee well-being
Workers in the value chain – equal treatment
and opportunities for all
By offering adequate wages, committing to social
dialogue, supporting collective bargaining
agreements and emphasising job satisfaction, we
have a potential positive impact on secure and
fair employment for employees under an NN
Group contract. These efforts can lead to a
healthier, more motivated, and resilient
workforce, benefiting both employees and society
as a whole.
We have identified a potential positive impact
on our employees by promoting a healthy work/
life balance, as well as health measures that can
positively impact employees. These include
measures to reduce stress and burnout, improve
mental and physical health and raise the level of
job satisfaction. These aim to help workers
balance their personal and professional lives,
leading to a more fulfilling and rewarding work
experience that supports their overall well-being.
NN Group’s commitment to equal treatment and
opportunities for all workers has a potential
positive impact on all types of employees. This
includes greater financial security, improved job
satisfaction, increased well-being and a stronger
sense of belonging, especially for those from
under-represented groups. By ensuring that all
employees feel valued, respected, and supported,
NN Group can boost morale and motivation,
resulting in a more fulfilling and rewarding work
experience for everyone.
We have a potential negative impact on our
employees. Discrimination can significantly affect
employees’ emotional and mental well-being,
career advancement, work relationships and
sense of belonging in the workplace. Similarly,
unequal pay can negatively impact employees’
financial well-being, career growth opportunities
and work relationships.
Our commitment to training and skill development
has a potential positive impact on job
satisfaction and overall well-being for employees
under an NN Group contract. By equipping
workers with the skills they need to excel in their
roles, we can not only increase their joy in work
but also prepare them for future challenges and
opportunities. This proactive approach makes us
a more attractive employer for new joiners and
boosts employability, ensuring that employees
are well-prepared for evolving job requirements.
We have an actual positive impact on
communities through our community investment
programme. By leveraging our resources,
expertise and networks, we aim to advance the
well-being of communities in all the countries
where we operate.
As a financial services provider, we store
customer data. Misuse of this information can
lead to potential negative impact, including
identity theft, financial losses, reputational
damage and psychological distress for our
customers.
We offer people access to affordable financial
services. When this access is restricted, we can
have a potential negative impact on them as this
can perpetuate poverty, limit economic growth,
and lead to social exclusion, pushing individuals
towards informal financial services that pose risks
of fraud and exploitation. While we currently
provide useful and affordable insurance products,
climate change increases the risk of extreme
weather events, which could affect the insurability
and affordability of these products in the future.
We have identified a potential negative impact
on workers in the value chain as we recognise
that some companies in our portfolio may not pay
their workers, or those in their value chain, a
living wage. This can lead to those workers being
more likely to work excessive overtime, unable to
meet their own basic needs and those of their
families, and not able put aside savings, thus
being less likely to find their way out of poverty.
We have identified a potential negative impact
on our workers in the value chain as we recognise
that some companies we work with may not allow
their workers to form or join trade unions.
Consequently they may not be able to collectively
bargain for fair wages, safe working conditions or
other protections. This lack of collective
bargaining can lead to exploitation and abuse, as
workers have no way to address grievances or
negotiate with their employers.
We have identified a potential negative impact
on workers in the value chain as we recognise
that some companies in our portfolio may be
involved in discrimination against their workers or
those in their value chain. Discrimination of
workers can have a significant impact on their
emotional and mental well-being, career
advancement, work relationships and sense of
belonging in the workplace.
We have identified a potential negative impact
on workers in the value chain as we recognise
that some companies we work with may not pay
their workers equally. Unequal pay can hurt
workers’ finances, limit their career growth and
damage work relationships.
We have identified a potential negative impact
on workers in the value chain, as we may be
linked to cases of child or forced labour through
the companies we invest in. Forced labour can
result in physical and psychological abuse, as well
as the denial of basic human rights such as
freedom of movement and fair wages. Forced
labour can also perpetuate poverty, hinder access
to education and expose children to hazardous
working conditions. Worker-paid fees can lead to
debt bondage, worsening these issues.
Workers in the value chain
Own workforce
Consumers and end-users
Community investment
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Sustainability matters
All material impacts related to workers in our
value chain are linked to NN Group’s strategy and
business model. This connection is illustrated in
the visual on the previous page, under the value
chain roles ‘Investments’ and ‘Business partners’,
and serves as input for adapting the strategy,
as detailed in ‘General Disclosures’, p. 126. NN
Group has identified potential negative impacts on
workers in the value chain through its activities; our
sustainability disclosures cover these. The potential
negative impacts that have been identified are
systemic across NN Group’s operations. We aim for
a better understanding of which employees are at
greater risk of potential negative impact.
NN Group defines ‘workers in the value chain’ as
those performing work within NN Group’s value
chain, regardless of the existence or nature of any
contractual relationship with NN Group. ‘Workers in
the value chain’ encompasses workers employed by
companies in both the upstream and downstream
value chain, through our business partners and
the companies we invest in. Through our corporate
investment portfolio, we could potentially have a
negative impact on vulnerable people, like trade
unionists, migrant workers, home workers, women
and young workers. Through our role as business
partner, we could have a negative impact on people
working on our premises but who are not part of our
own workforce.
Our corporate investment portfolio consists of
companies primarily located in Europe, the US and
Japan. While incidents and potential risks from
forced or child labour may exist in these geographies,
the risks of causing, contributing to or being linked
to forced or child labour is greater in the regions
where the portfolio companies’ value chains are
situated. This is particularly relevant for sectors
such as food production, textiles and manufacturing.
Child and forced labour have also been identified as
salient human rights issues in activities related to
NN Group’s role as investor. In the coming years, we
plan to create heatmaps to pinpoint where the risks
of child and forced labour are most prevalent in our
corporate investment portfolio.
All material impacts related to customers are also
linked to NN Group’s strategy and business model.
This connection is illustrated in the visual under the
value chain role, ‘Products and services’, as detailed
in ‘General Disclosures’ on p. 126.
Types of customers that could be impacted by
NN Group include retail and corporate clients and
both groups are covered by our sustainability
disclosures. Additionally, the rights to privacy,
data protection, freedom of expression and non-
discrimination of both types of customers are
potentially negatively impacted. Accurate and
accessible product or service information to avoid
harmful use of those products and services is also
important to both types of customers, and some of
them may be particularly vulnerable to marketing and
sales strategies.
The potential negative impacts identified in the
sustainability matter of ‘clear and secure data’ are
typically related to individual incidents. In contrast,
the potential negative impacts identified in ‘financial
inclusion’ tend to be systemic. We have not yet
developed an understanding of which types of
customers are at greater risk of harm.
Human rights
As a financial services provider with a large number
of stakeholders, we understand that our operations
can impact many people. We view respect for human
rights as a minimum standard for responsible
business operations and conduct, and believe that
every individual, regardless of their background,
deserves to be treated with dignity, fairness and
respect.
The basis of our approach to human rights is
embedded in the NN statement of Living our Values,
which provides guidance on how we conduct
business. Our human rights approach is further
supported by specific policies, described in the NN
Group Human Rights Statement; these support our
day-to-day operations and describe our due diligence
processes.
Our Human Rights Statement sets out what we
expect from ourselves and our business partners
on human rights; it outlines how we implement our
human rights approach in line with international
standards, including the UN Guiding Principles
on Business and Human Rights (UNGPs) and
the Organisation for Economic Co-operation and
Development (OECD) Guidelines, for different roles.
The UNGPs refer to the International Bill of Human
Rights, which consists of the Universal Declaration of
Human Rights and the two Covenants that implement
it, as well as the International Labour Organisation’s
Declaration on Fundamental Rights and Principles as
Work.
We seek to avoid causing or contributing to adverse
human rights impacts in areas we can directly
influence through our management control; we seek
to address such impacts if they occur. Wherever
possible we strive to identify, prevent or mitigate
adverse indirect human rights impacts that may
be linked either to our operations, our products
and services, or to our relationships with business
partners or projects we have invested in or insured.
NN Group is committed to respecting human rights
by working to meet the expectations set by the
UNGPs and the OECD Guidelines for Multinational
Enterprises on Responsible Business Conduct.
As a financial services provider, we are at risk
of causing, contributing to and/or being linked
to adverse human rights impacts. By analysing
our business activities, customers, partners and
suppliers, we identified our salient human rights
issues in a 2023 assessment. Salient human rights
issues are those human rights issues that stand out
due to their severity and likelihood of negative impact
on people across our value chain. As a result of this
identification, we are better able to prioritise, manage
and track those impacts, as well as communicate on
Investor
Business partner
Employer
Service provider
Salient human rights issues
Equal pay Freedom of
association and
collective
bargaining
Data privacy and
security
Financial inclusion Non-discrimination
and equality
Living wage Child labour and
forced labour
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our progress. (See visual below for the salient human
rights issues we have defined for our different roles.)
To ensure a comprehensive assessment, we
consulted with internal and external stakeholders
including NGOs, peers, human rights experts,
industry organisations, researchers and financial
market supervisors. The outcomes of the salience
assessment were presented for the four roles NN
Group has in the value chain. Our salient human
rights issues align with NN Group’s Double Materiality
Assessment (DMA) conducted this year.
Social roadmap
We aim to further embed human rights due diligence
across our roles through policy development,
monitoring and tracking of adverse impacts,
strengthening our grievance mechanism, and
working on access to remedy. We continue our
human rights efforts in line with the UNGPs and
the OECD Guidelines, by increasing our knowledge
of potential negative impacts through the use
of leverage, and by building awareness in our
interactions with stakeholders. These actions have
been included in a social roadmap that defines
deliverables for our various roles over the next
two years. One of the roadmap’s central elements
is implementing the Corporate Sustainability Due
Diligence Directive (CSDDD), which applies to our
own operations and upstream activities. Meeting
the CSDDD requirements will further embed the
UNGPs and OECD Guidelines and strengthen our due
diligence processes.
We acknowledge a link between human rights and
other topics, such as climate change and biodiversity.
We are currently investigating how to integrate the
criteria for a just transition into our activities. ‘Just
transition’ in the context of NN Group implies that
we need to further integrate social aspects into our
sustainability governance, policies and due diligence
processes, as well as into positive impact solutions
and product development opportunities. This implies
careful consideration of both the environmental and
social impacts on vulnerable groups of people, and
the risks and opportunities related to our financial
activities (insurance underwriting, banking and
investments).
In the rest of this chapter, we focus first on our own
workforce, then look at how we engage with workers
in the value chain before describing our interactions
with customers and our commitment to safeguarding
their rights and interests.
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community investment and volunteering, leave of
absence, personal health, well-being, safety, and end
of employment. Another objective is to mitigate HR-
related risks, such as those around employee quality,
succession of key persons, employee attractiveness,
remuneration, discrimination, undesired behaviour
and risks related to HR regulation and legislation.
The Framework is available on NN Group’s internal
website and applies to all NN Group employees,
including business units, subsidiaries and controlled
joint ventures. While each business unit must comply
with the HR Framework, it implements it according to
local laws and regulations.
The HR Framework plays an important role in helping
ensure that NN Group is a fair employer, respecting
human rights, advocating equal opportunities and
encouraging diversity of thinking. The updated 2025
Human Resource Framework includes a reference
to the UNGPs. While focusing on (prospective)
employees, the Framework also considers other
relevant stakeholders where applicable.
We believe that by promoting a unified approach
to HR practices, we can attract and retain top
talent, mitigate HR-related risks and ultimately
drive business success. The HR Framework is
issued, owned and overseen by the Chief People,
Communications, and Sustainability Officer, who is a
member of the Management Board NN Group.
Below, we offer an in-depth analysis of each of the
four key material topics covering existing policies,
how we involve employees in addressing the topics,
the available channels for employees to voice their
concerns, the measures we have taken, and how we
evaluate the efficacy of those measures. We also
detail the targets we have established to help us
continuously improve our practices.
Equal treatment and opportunities for all
Our approach to diversity, equity and inclusion is
simple. It is about embracing people’s differences.
Together we aim to build an environment where
people feel welcome, valued and respected – a
company where we can bring our whole selves to
work, where an inclusive customer experience goes
without saying, and where we contribute to the well-
being of our communities. We believe our company
is strongest when we embrace the full spectrum of
humanity, regardless of what we look like, where
we come from or who we love. NN Group does not
tolerate discrimination, harassment or bullying of any
kind. All allegations of this kind are taken seriously
and handled according to local laws and policies.
Diversity, Equity and Inclusion strategy
In 2024, the Diversity, Equity and Inclusion (DEI)
team developed a new strategic direction that
explicitly includes equity as a key topic alongside
diversity and inclusion. In 2024, we were recognised
for our commitment to diversity, equity, and inclusion
through indices and reputational measures. NN
Group ranked 9th on the FT-Statista Diversity Leaders
list, out of 850 companies, and number one on
gender equality in the Netherlands by Equileap.
Our strategy aims to help us create a level playing
field where everyone can thrive and succeed.
Equity is not a new topic for us. Since 2018 we
have supported, for example, the Running Blind
foundation, which enables people with a visual
impairment to run safely and participate in events.
Our new strategic direction is accompanied by clear
DEI initiatives and a communication plan to embed
these principles and practices both internally and in
our public domains.
Our DEI strategic objectives are:
• to be an industry leader in providing an inclusive
and diverse work environment where employees
can bring their whole selves to work;
• to consider diversity, equity and inclusion as part
of our contributions to society.
Achieving these objectives will take time but will help
achieve both structural and behavioural inclusion. We
are partnering with HR teams in our efforts to look
at every part of the employee journey through a DEI
lens. For the broader organisation, we are working
towards strengthening our employee resource
groups and aim to ensure awareness around relevant
legislation, such as the European Accessibility Act.
Diversity and Inclusion Statement
Our Diversity and Inclusion (D&I) Statement outlines
our commitment to employees, customers and
society when it comes to diverse representation,
perspectives and products, equitable polices and
support, and inclusive employee and customer
experiences. Our approach helps us to better
understand and meet the changing needs of
customers and stakeholders in an ever-evolving
world, particularly in the financial sector. We believe
Own workforce
We are committed to fostering a workplace that
prioritises fairness, inclusivity and the growth of
our employees. As part of our sustainability efforts,
we have identified four key material topics: equal
treatment and opportunities for all, human capital
development and attraction, employee well-being,
and secure and fair employment. (The introduction
to this section gives more information on the
identification process). These material topics reflect
our commitment to creating a positive and supportive
work environment. We focus our efforts on these
topics by engaging with our workforce, implementing
meaningful policies and tracking progress.
When refering to our own workforce and the
associated impacts we have on them, we consider
employees as people with a contract from NN.
For information on how we consider material impacts
on our workforce when integrating into our strategy
and business model, see p. 126.
Human Resources Framework
To strengthen this commitment, we have established
the Human Resources Framework Standard (HR
Framework). Its key objective is to summarise core
HR principles and what they mean in practice, aiming
to ensure all employees have equal opportunities
wherever they are in the organisation. The Framework
covers a wide range of topics. These include diversity
and inclusion, recruitment, performance and talent
management, remuneration, work and personal time,
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that a diverse workforce that reflects the world
around us strengthens our ability to innovate and
respond to change.
Diversity and Inclusion Policy
Our Diversity and Inclusion (D&I) Policy outlines our
goals for diverse representation in terms of gender,
nationality, ethnicity, sexual orientation, age, neuro
and physical diversity for our boards and senior
management. This includes NN Group’s Executive
Board, Management Board, Supervisory Board and
senior management. (See p. 73 and p. 193 for more
information on gender distribution).
Diversity at all levels, particularly at the top, makes
us better able to steer and address the company’s
strategic opportunities. Talent acquisition and
management processes for senior positions are
designed with inclusion in mind to ensure objective
processes to avoid bias. Clear recruitment,
promotion and succession procedures are in place
to help enable diverse representation in leadership.
Specifically for our boards we seek to optimise
gender diversity with our target of at least 40% of
both women and men.
Gender and equal pay
Each year, we analyse all business units for gender
equality and parity. Through our remuneration
framework we aim to ensure that men and women in
the same job and compensation grade, with similar
experience and age, receive fair and equal pay for
equal work. (See ‘Remuneration Report’, p. 103 for
more information and outcomes.)
Diversity, equity and inclusion networks
NN Group has seven networks (see below), covering
gender, ethnicity, sexual orientation, neurodiversity
and generations. We cultivate and harness these
networks to support our DEI strategy and champion
inclusivity in our organisation by advocating for
the needs of our diverse workforce. The networks
provide opportunities to connect, support and
engage colleagues in safe spaces to create a sense of
belonging.
• NN Pride Network promotes LGBTQIA+ inclusion
within NN Group. In 2024 partner organisation
Workplace Pride researched our LGBTQIA+-
focused processes and policies, and gave
recommendations that will be incorporated into
future Pride plans. Members of the network
talked with communities across NN International
Insurance to understand local needs with a view
to expanding the network with local chapters in
2025.
• NN Neurodiversity Network focuses on creating
a safe environment to discuss invisible cognitive
differences. In October 2024 we celebrated ten
years of our values ‘clear, care and commit’ with
Values week, which included hosting a panel on
neurodiversity. In 2024 Facilities Management
also held focus groups on neurodiversity to
understand the different needs of neurodiverse
employees.
• Women in Leadership Network empowers
female employees to own and influence their
professional growth by holding events including
discussions and knowledge-sharing sessions.
• Women in IT Network, founded in 2024, aims to
provide a safe and supportive space for women in
IT in our organisation.
• NN Cultural Diversity Network fosters respect
for cultural differences in our company. In 2024,
the network hosted a hybrid session around
cultural diversity. This included introducing
dialogue cards for employees and managers to
facilitate connection through dialogue. In our
international expat community, we hosted a
connection event to continue building inclusion for
all employees.
• NN International D&I Network promotes global
inclusion by offering training and events across
our international business units. This network
encourages diverse perspectives and creates
safe spaces for dialogue. In 2024 it focused on
neurodiversity awareness as well as hosting an
event at our headquarters in The Hague attended
by country DEI ambassadors and leaders.
This event celebrated DEI accomplishments
internationally in NN Group; there was also a day
of learning about neurodiversity.
• NN Young Professionals Network helps young
employees to feel included and connected with
other generations through networking and events.
Diversity, equity and inclusion learning
Our commitment to promoting equal treatment
and opportunities for all is reflected in our ongoing
efforts to promote diversity, equity and inclusion
through a variety of learning opportunities. These
include unconscious bias training for example, and
inclusive leadership workshops. Several countries
have also implemented their own Diversity, Equity
and Inclusion (DEI) learning such as the Beyond the
Limits programme in Belgium, which aims to increase
physical diversity in the workplace. Another example
is the mandatory D&I training for Management Team
members in Poland.
Cross-country diversity, equity and inclusion
benchmark
Since 2021, we have conducted an annual DEI cross-
country benchmark exercise with an external partner
in all NN Group countries except the Netherlands;
this year the Netherlands was added. The exercise
uses interviews and employee surveys to assess how
mature diversity, equity and inclusion are in different
countries. The results give us insights into where our
strengths lie and where we can improve so we can
make informed decisions and adjustments to our DEI
initiatives, fostering a culture of inclusivity and equity
throughout our organisation. By engaging directly
with the countries, we can determine what actions
are needed, listen to their feedback and ensure
that our DEI efforts are measured and responsive,
addressing the countries’ own unique challenges and
opportunities.
Diversity, equity and inclusion survey
In 2024 we addressed the insights arising from the
first DEI survey that we conducted in 2023. The
survey asks questions related to discrimination,
including those linked to harassment, equal
opportunities, diversity, equity and inclusion. It
gives employees the opportunity to provide honest
and open feedback, which is then taken into the DEI
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team, and others if necessary. One issue that arose
from the survey and that we addressed this year was
that many employees do not understand the Dutch
language, which is perceived as dominant. As a
result, we reviewed ways to conduct our DEI dialogue
sessions, trainings and network events in English, to
be more inclusive.
Speak Up system
To operate successfully, we understand the
importance of maintaining our reputation and
organisational integrity. That’s why we encourage
employees to report any (potentially) unethical
conduct in our company to their manager or
manager’s manager, allowing us to maintain an
open dialogue and take any necessary actions.
However, we acknowledge that employees may feel
uncomfortable about reporting concerns through
regular channels, so we have set up alternative
options: reporting to a (local) Reporting Officer and
through the Speak Up system (in house).
These channels allow employees to report concerns
anonymously if preferred. All concerns are taken
seriously. We have the International Whistleblowing
Policy and the Whistleblower Standard for Dutch
Business Units and Head Office of NN Group, both
of which cover all of NN Group, to investigate and
address any concerns. With these measures we
aim to create a safe and inclusive work environment
where employees feel comfortable reporting
concerns and breaches related to, for example,
diversity, equity and inclusion. More information can
be found on p. 116.
Promoting diversity in senior leadership
We aim for diverse representation in our senior
management to ensure a wide range of perspectives
and views. ‘Women in leadership’ remains the main
strategic KPI for HR, with an aim of achieving at least
40% of senior management positions occupied by
women by 2025. In 2024, we achieved 41% (2023:
40%). At the same time, we continue to focus on
balanced representation in other dimensions such
as nationality, age and ethnicity. We have set out
various actions on the different drivers behind our
DEI roadmap such as enhancing processes, data and
data monitoring, visibility and networks, and mindset
and awareness.
Actions include (among other things):
• taking the target of at least 40% women in
leadership into account in the succession planning
and appointment process for all board and senior
management positions;
• holding talent review and succession planning
sessions for senior management positions at least
once a year;
• talent managers increasing engagement with
our female talent pool to increase visibility and
opportunity. Our Women in Leadership Network
(see above) supports this by holding networking
events and mentoring; and
• setting the aim of achieving a gender balance in
our leadership training programmes and the NN
Group Traineeship tracks.
Human capital development and attraction
We emphasise the importance of employee
development and talent management, recognising
all colleagues as valuable talents deserving
opportunities for growth. Below, we provide detailed
insights into how we engage with employees and
the specific activities we undertake in relation to this
topic.
People cycle
Our ‘people cycle’ includes performance and talent
management processes, and is the foundation
for identifying suitable learning and development
solutions. During the people cycle discussions, we
assess employees’ potential, their development
ambitions and their contributions, leading to
tailored development actions or plans. We actively
engage with employees to foster a culture of open
communication and collaboration. Regular feedback
mechanisms, such as surveys and one-on-one check-
ins, encourage employees to voice their needs and
aspirations, helping to ensure their perspectives are
considered in development plans.
By providing a comprehensive range of training and
development resources to foster continuous learning,
we facilitate an environment where employees
feel empowered to take ownership of their growth.
Employees can choose from various methods of
learning, including hands-on experience, knowledge
sharing and formal training, allowing them to select
opportunities that align with their personal and
professional development needs.
Talent and succession process
A talent and succession process facilitates
employee development and career progression.
Key components include the team review and talent
calibration, which help managers in assessing
employees’ contributions and potential, as well
as fostering meaningful discussions about their
development and opportunities for movement in
the organisation. The structured process mandates
all business units to conduct annual assessments
of employee contributions, ambitions and growth
potential.
Talent calibration supports a fair and consistent
application of these assessments, fostering a shared
understanding of the talent landscape. Regular talent
calibration and a recurring succession planning
process help identify potential successors across
domains and functions for (key) management roles,
supporting readiness and diversity while mitigating
the risks associated with vacant positions.
Future skills
To be ready for the future, NN Group has been
developing a global skills taxonomy to enhance
skills management and enable further skills-based
technologies. This will be further rolled out in 2025.
Strategic workforce planning
Through strategic workforce planning we can
identify the talent we need to achieve our goals and
establish a strategy to make sure we have the right
mix of talent to reach these goals. Our continuous
planning provides insight into the challenges and
solutions. These insights and solutions are used to
determine actions on attracting, hiring, developing,
and engaging with our workforce. For example, we
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identified a new learning need around data, analytics
and AI on both a specialist and non-specialist level
and are addressing it by designing and implementing
upskilling programmes to help employees develop in
this field.
Upskilling programmes
Upskilling initiatives rolled out in 2024 included a
Power BI Challenge, Inspiration Days, NN Future
Skills Olympic Games and Microsoft Technical
trainings. Key skills that were developed included
working with MS Power Platforms, skills around
data and business intelligence, process automation
and specialised IT skills where colleagues had the
opportunity to certify by passing Microsoft exams
on topics such as Azure Administrator, Azure
Fundamentals, DevOps Solutions, Data Engineering
and Data Analyst.
We also launched a senior management track of the
NN Data Literacy programme with the Massachusetts
Institute of Technology this year. This programme
is aimed at upskilling leaders on relevant data and
analytics knowledge. The Data Literacy Programme
for managers was piloted in 2024 to prepare for
roll-out at the beginning of 2025. The Data Literacy
Programme for employees will be rolled out during
the course of 2025.
Leadership development
In terms of leadership development, NN Group aims
to enhance the skills of current and potential leaders
through tailor-made LEAD programmes that support
the growth of future leaders. Aside from the LEAD
programmes, the NN Group Traineeship offers three
tracks, designed to attract and develop young talent.
Management onboarding
We want managers to feel they can be effective and
people-oriented in their role. To this end, we embed
our values into our way of working and make sure
managers are aware of our D&I Statement and act
accordingly. Our new Group-wide management
onboarding programmes support new managers
in their first 100 days; they receive a 100-day
checklist, with practical tips to help them get
started, and a ‘managers playbook’ detailing their
role as a people manager, supplemented with FAQs
about various processes in the employee journey.
A live manager-onboarding session, introduced in
September 2024, includes elements on strategy,
interaction and networking opportunities as well
as case discussions, interaction and networking
opportunities.
Talent acquisition
We strive for a fair and transparent recruitment
process, and our HR Framework Standard supports
this endeavour by providing principles to follow
around equal opportunities and respectful treatment.
It incorporates tools such as a leadership profile and
NN Competencies to assess candidates. In addition
to the standard, each country has a way to take local
obligations and legislation into account. For example,
for the Dutch population we have a recruitment policy
and an external hiring policy in place, which require
internal candidates to be considered first in the case
of a vacancy.
Candidates for an available position are screened
on their technical expertise and behavioural
competencies relevant to the position. We also
strongly recommend using a (semi-)structured
interview conducted by a diverse panel of two
interviewers, supporting diversity and inclusivity in
the hiring process. Agreements are formalised in a
contract or offer letter before hiring. External staff
hiring must comply with standards such as assessing
appropriate rates and signing a non-disclosure
agreement. NN Group encourages the movement of
talents between businesses, respecting the needs
of each business area and individual. Employability
is promoted, and screening is required to ensure the
integrity of the business and minimise risks.
Employee Value Proposition (EVP)
With our renewed Employee Value Proposition (EVP),
we showcase the benefits and opportunities we
offer employees, which in turn helps us attract and
retain talent. The proposition consists of four drivers:
‘master your skills’, which is about an employee
reaching their full potential with professional
opportunities and employee benefits; ‘move forward
together’, focusing on an inclusive culture and
working together; ‘make your work matter’, about
purposeful work and how our work impacts people
and the world around us; and finally ‘shape the
future’, in line with the new strategic commitment to
become digital and data-driven.
Employee well-being
We want employees to feel energetic and happy in
their work and believe they can only reach their full
potential if they are mentally and physically fit, which
will make them more resilient and energetic. Our
health and well-being practices aim to create optimal
working conditions, limit health risks and foster the
vitality and well-being of our employees.
In 2024 we introduced the Group-wide NN
Vitality Statement to underline the importance of
employees’ vitality. The statement’s priorities are
fostering vitality and employability, creating an
optimal workplace with well-organised procedures,
preventing and reducing absenteeism and
occupational disability and reducing the number
of employees with work-related health issues. Our
business units have the flexibility to adopt their
own local approaches to address themes that are
important to them, aligned with local legislation. In
the Netherlands for example, we have created a local
Health and Safety, Sick Leave and Vitality policy.
Our managers play a crucial role in this process
by focusing on the creation of a safe working
environment, promoting awareness around
resources, and supporting physical and mental
health, as well as monitoring the vitality of their team
members. Part of this is encouraging a good work/
life balance, offering support for personal challenges,
and fostering open communication and a supportive
team environment where team members feel
comfortable discussing any concerns or challenges
they may have.
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At Group level, experts in our HR Health and Vitality
team monitor the overall health of our colleagues.
They are responsible for ensuring that Group-wide
vitality services remain relevant to their evolving
needs. We monitor absenteeism on a regular basis
and act whenever we notice a significant change
in a business unit, department or team. We also
conduct an employee engagement survey that
includes questions on how colleagues perceive their
work environment and whether they feel they can
live a healthy lifestyle when working at NN Group.
For further details on how we assess employee
engagement, see p. 188.
Physical and mental health
In the Netherlands, an NN Vitality Platform allows
employees to take care of their physical and mental
health; it will be available Group-wide in 2025. We
encourage employees to prioritise both their mental
and physical health through regular exercise, a
healthy and balanced diet, relaxation and sufficient
sleep. We also recognise the importance of taking
regular breaks and incorporating physical activity
into the workday to promote productivity and reduce
stress.
We want our people to feel fit and energised, both at
work and in their personal lives and believe that both
physical and mental health are essential to overall
well-being. We stimulate colleagues to monitor
and optimise their mental health by reflecting on
topics such as whether they feel supported by their
environment and if they feel they have a sense of
purpose. We aim to create a safe environment where
colleagues can discuss any concerns they might
have.
Leave of absence
NN Group informs colleagues about their leave
options, supports them in the field of vitality and aims
to prevent absenteeism. If an employee is unable
to continue in their job, NN ensures alternative
employment on the basis of good employment
practices. We will consider unpaid breaks
(sabbaticals) of two to six months if an employee
has been continuously employed for five years, and
subject to business needs and local regulations.
As part of the Collective Labour Agreement in the
Netherlands, employees may take ‘vitality leave’ to
promote long-term vitality and enhance permanent
employability, allowing them to take paid leave for
two months while receiving 50% of their salary.
Personal health support
In the Netherlands we have the following personal
health support in place:
• The Personal Health Check, giving employees
insights into their lifestyle, blood pressure,
cholesterol, work stress and more. The personal
health report contains a risk assessment and
recommendations on how to improve health.
• The Zorggenoot support line, which provides
information to employees who are also caregivers
about different forms of support, helps them with
administrative work and supports them in finding
a good balance between their own life, caregiving
and work.
• As many as one in four working Dutch people
experiences sleep problems, recognising
associated symptoms. In 2024 we introduced
the possibility of employees using the HalloSlaap
programme free of charge for support in this area.
• Each quarter, NN Group provides information
sessions for pregnant colleagues, where they
receive practical information about our policy
regarding pregnancy, including appropriate
workplace conditions. They also receive tips to
stay healthy and vital, and prevent complaints
associated with pregnancy as much as possible.
Work/life balance
We believe that a healthy work/life balance is
essential for employees to perform at their best and
contribute to the success of the organisation. To
that end we offer flexible employment opportunities,
allowing people to work at times and locations that
suit them within the limits imposed by the nature of
their work, their personal situation and the interests
of their team, manager and other stakeholders. Our
HR Framework lays out guidelines on working hours,
overtime, rest breaks and travel time to ensure that
employees are treated fairly and equitably.
A safe and healthy work environment
Because we adopt a hybrid approach, allowing
employees to work from home or the office, we
support them in making their workspace safe and
well-equipped by giving them information, advice and
financial help.
In the Netherlands we complete an annual checklist,
part of the Working Conditions Act (Arbowet), which
allows our Health and Vitality department to pass
on any suggestions for mitigating potential health
and safety risks. All business units also have local
workplace accident prevention policies in place to
ensure employees are aware of, and adhere to, local
laws and regulations.
Secure and fair employment
We are committed to providing secure and fair
employment to all our employees and understand
that a safe and supportive work environment is
essential for their well-being and success. In this
section, we discuss our efforts to prioritise workers’
rights, promote social dialogue and ensure that our
employees are treated with respect and dignity.
European Works Council
We have a European Works Council (EWC) in place
as part of this commitment, to secure employment,
social dialogue, and workers’ rights across all
business units. The rights and obligations of EWC
members are outlined in the EWC agreement, aiming
to ensure that employee representation is integrated
into corporate governance. Most countries have one
or more local works councils (see next page), from
which members are delegated to the EWC.
The EWC plays a vital role in fostering social
dialogue by addressing issues that affect workers
across different countries. Important topics
discussed in the council range from data and AI to
upskilling, reskilling, strategic workforce planning
and the European Pay Transparency Directive.
These discussions not only facilitate the sharing
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of information, experiences and best practices but
also create a platform for consultation on significant
matters affecting employees, thus promoting a
culture of transparency and collaboration. A formal
meeting takes place twice a year in the presence of
the executive and the member of the Management
Board responsible for NN International Insurance,
ensuring that the highest levels of management are
engaged in these critical dialogues.
The framework for worker representation, including
the EWC and local works councils, supports workers’
rights by providing a structured mechanism for
employees to express their views and concerns.
The EWC agreement specifies that important
transnational matters are discussed within the EWC,
fostering a sense of security among employees
knowing that their voices are heard in decisions that
may impact their working conditions. If the EWC is
consulted on an important transnational issue, its
opinion can still have a significant impact on the
decision to be made.
The EWC meets with the Head of HR International
as well as internally, without the presence of
the executive. The executive is supported by an
employee of NN HR Legal & Labour Relations, who
also serves as a liaison between the executive and
the EWC.
Local works councils
In accordance with local customs, laws and
regulations, most countries have one or more
local works council. Hungary and Czechia, without
local works councils, delegate employee-elected
members to the EWC. Worker representative bodies,
including the EWC, are facilitated in terms of time and
resources.
The degree to which participation in local works
councils is an inherent part of the culture varies from
country to country, as does the extent to which trade
unions participate. In the Netherlands for example,
which has a long tradition of participation, the works
council and trade unions have separate functions. In
Belgium, however, there is no such distinction, and
employees can only become members of the works
council if they are also a member of a trade union.
Eastern European countries generally have a less
long-standing tradition of participation.
Collective Labour Agreement
The Netherlands, Belgium, Greece, Spain and
Romania have a Collective Labour Agreement (CLA)
in place, negotiated with works councils and trade
unions where applicable. These agreements not
only enhance job security but also reinforce our
commitment to adequate wages and equitable
working conditions for all employees.
Adequate wages
We are committed to providing market-competitive
rewards through a clear and transparent
remuneration framework. This framework is
built on several key elements, including a ‘total
compensation’ approach that aligns pay with relevant
local market conditions. It differentiates based on
business needs and individual performance, and
considers the competencies and experience required
for each role. The remuneration system is designed
to attract, hire and retain talent while aiming to
ensure consistency with NN Group’s strategic
positioning and development goals, reflecting
the company’s values and its role in society. This
focus on competitive pay also relates to secure
employment by providing financial stability for
employees, essential for long-term job satisfaction
and retention. See ‘Remuneration Report’, p. 103 for
more information.
Data privacy
We value the privacy and security of our employees
and recognise that personal data must be handled
with care. We do this in line with legislative data
protection requirements; the EU General Data
Protection Regulation (GDPR) being the most
important of these. See p. 117 for more information
on data privacy.
Living our values
We have implemented several measures to
encourage our employees to exhibit appropriate and
expected behaviour and actions. (See ‘Our values and
behaviours’, p. 7.)
Monitoring progress on material topics
By monitoring progress on these material topics
through tools such as engagement surveys and
benchmarks, we can track our performance and
identify where we can improve.
Engagement survey
Acknowledging that engaged colleagues are key to
obtaining our strategic ambition, we conduct Group-
wide engagement surveys twice a year and have set
a clear ambition to sustain high levels of engagement
across the organisation. Therefore it is important
that we listen carefully to what our colleagues
experience, think and feel. We communicate this
ambition internally and externally as part of our
strategic ambitions. The engagement scores and
progress are made public on a semi-annual basis. The
HR department is responsible for coordinating this
process.
We currently partner with Peakon to survey our
employee engagement. The Peakon platform
automatically translates information into the
desktop language setting of the participant, which
is usually their native language. We also manually
review translations to ensure their accessibility and
quality, and thus their comprehension, as well as the
reliability of the results. For employees who have
difficulty reading, Peakon supports the in-browser
text-to-speech functionality, allowing them to listen
to survey questions and feedback. Survey responses
deliver insights that help us create an optimal
working environment together.
We invite all NN Group employees with a fixed term
and permanent contract, as well as third-party
contractors, to take part in the survey. Participation
is voluntary. High participation rates are obtained
in both the mid-year and year-end survey, ensuring
reliable survey results.
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The survey contains no gendered language, and
each business unit may add up to five closed-
ended items and three open-ended questions
to ensure the content suits local needs. Closed-
ended items are scored on a scale from one to ten;
open-ended questions that are included allow for
written feedback. To support data interpretation, we
include internal and external benchmark information
alongside survey results; responses are confidential,
and individuals cannot be identified through the
results. Peakon uses the Net Promotor Score
methodology to give additional insights.
The survey is designed to measure employee
engagement as well as a broad range of employee
experience topics. Items included in the survey
are grouped into drivers, such as engagement,
accomplishment, autonomy, freedom of opinion, goal
setting, growth, management support, meaningful
work, organisational fit, peer relationships,
recognition, reward, strategy and workload.
Specific items within NN Group’s standard set of
questions represent the four material topics detailed
below.
• We evaluate ‘Equal treatment and opportunities
for all’ by asking if people from all backgrounds are
treated fairly in the employee’s business unit, and
how confident they are that reporting unethical
behaviour would lead to subsequent action.
• ‘Human capital development and attraction’ is
rated by asking if the respondent feels they are
growing professionally, if they are encouraged and
supported to do so, and whether they are enabled
to learn and develop new skills.
• ‘Employee well-being’ is captured by asking
employees if they feel they can live a physically
healthy lifestyle and to what extent they find their
workload manageable.
• ‘Secure and fair employment’ is assessed by
asking employees if they feel their opinions are
valued and to what extent they experience open
discussions about acting in accordance with
company values.
All these items are consistently scored favourably at
Group level and therefore not considered for Group-
wide action planning. However, depending on the
results, they may be included in unit or team action
plans.
Additional data analysis showed health and
professional and personal growth to be an area
for improvement, so we have introduced an NN
vitality platform to boost the vitality of all our
colleagues across NN. We also plan to optimise talent
management processes through digitalisation and
better use of data, increase the visibility of internal
development opportunities and determine the
reskilling and upskilling needs of the workforce.
Analysing the data obtained through the survey
leads to recommendations and the development of
data-driven action plans to improve the employee
experience and achieve business goals. The Peakon
platform facilitates this, as well as the necessary
analytical capabilities to gain actionable insights. All
managers are asked to share the survey outcomes
with their team(s), and initiate dialogue with them
to discuss what is going well and what could be
improved. Likewise, business units are asked to
create an action plan which details what actions
they will take to improve results for their unit; the
Management Board discusses the results on a Group
level, determining priorities and actions, which range
from launching new initiatives to updating policies
and processes.
Our 2025 ambition is to achieve an employee
engagement score of 8 or higher, which was derived
from the financial benchmark of Peakon. Our 2024
score stayed at a stable 7.9 with a participation rate
of 83%.
NN certified Top Employer Europe
In 2024, for the sixth consecutive year, all ten
business units in NN International Insurance
were certified Top Employer by the Top Employers
Institute, a globally recognised accreditation
programme that certifies organisations based on the
participation and results of their HR Best Practices
Survey. The survey covers six HR domains and 20
topics, such as People Strategy, Work Environment,
Talent Acquisition, Learning, Well-being, and
Diversity & Inclusion.
NN Group is ranked sixth in the institute’s top ten
ranking in Europe, having more than five business
units certified as Top Employer in Europe with a high
aggregated score, moving up four places since 2023.
NN International Insurance reached an overall score
of 96% in the Top Employer certification, up from
94% the previous year. We also showed substantial
improvement since 2023 in the areas related to
our four material topics. These areas are: work
environment (from 91% to 97%), well-being (from
80% to 86%) and career (from 90% to 96%).
NN International Insurance scores showed room for
improvement in our offboarding practices, which will
be a focus area in 2025.
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Employees by gender and by contract type and full-time/part-time
2024
Female Male Other Total
Headcount Percentage Headcount Percentage Headcount Percentage Headcount Percentage
Permanent employees 7,529 92% 7,692 93% 1 100% 15,222 93%
Temporary employees 660 8% 557 7% 1,217 7%
Non-guaranteed hours employees
Total number of employees 8,189 100% 8,249 100% 1 100% 16,439 100%
Full-time employees 5,918 72% 7,579 92% 13,497 82%
Part-time employees 2,271 28% 670 8% 1 100% 2,942 18%
Total number of employees 8,189 100% 8,249 100% 1 100% 16,439 100%
2023
Female Male Other Total
Headcount Percentage Headcount Percentage Headcount Percentage Headcount Percentage
Permanent employees 7,566 92% 7,655 94% 15,221 93%
Temporary employees 662 8% 516 6% 1 100% 1,179 7%
Non-guaranteed hours employees
Total number of employees 8,228 100% 8,171 100% 1 100% 16,400 100%
Full-time employees 5,856 71% 7,502 92% 1 100% 13,359 81%
Part-time employees 2,372 29% 669 8% 3,041 19%
Total number of employees 8,228 100% 8,171 100% 1 100% 16,400 100%
Employees
An employee is an individual who is in an
employment relationship with NN Group or one of its
subsidiaries according to national law or practice.
Employee data is reported in headcount at the end of
the reporting period. ‘Employees’ does not generally
include interns. The number of interns is reported
separately.
Gender
NN Group discloses employees in three categories:
female, male and other. ‘Other’ includes all gender
identifications other than ‘female’ and ‘male’, and
includes employees whose gender is not specified.
Interns
The headcount in the table is excluding the total
number of interns: 243 (2024) and 254 (2023).
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Employees by country and by contract type in headcount
2024
Permanent
employees
Temporary
employees
Non-guaranteed
hours employees Total
Full-time
employees
Part-time
employees Total
The Netherlands 8,892 889 9,781 7,265 2,516 9,781
Poland 1,028 113 1,141 1,115 26 1,141
Japan 982 49 1,031 1,031 1,031
Czech Republic 748 44 792 714 78 792
Belgium 706 706 543 163 706
Spain 625 6 631 591 40 631
Romania 549 38 587 557 30 587
Hungary 575 4 579 537 42 579
Greece 567 8 575 561 14 575
Slovak Republic 403 49 452 419 33 452
Other 147 17 164 164 164
Total 15,222 1,217 0 16,439 13,497 2,942 16,439
2023
Permanent
employees
Temporary
employees
Non-guaranteed
hours employees Total
Full-time
employees
Part-time
employees Total
The Netherlands 8,858 902 9,760 7,184 2,576 9,760
Poland 1,136 51 1,187 1,142 45 1,187
Japan 972 48 1,020 1,020 1,020
Czech Republic 739 56 795 719 76 795
Belgium 695 695 535 160 695
Spain 594 6 600 562 38 600
Greece 567 16 583 567 16 583
Hungary 541 4 545 496 49 545
Romania 535 25 560 511 49 560
Slovak Republic 400 53 453 421 32 453
Other 184 18 202 202 202
Total 15,221 1,179 0 16,400 13,359 3,041 16,400
Country
NN Group uses the countries in which it operates for the breakdown
by region. The consolidation on country level for the Sustainability
Statement is in line with the consolidated annual accounts.
The number of empoyees in the company remained relatively stable
throughout the year with only minor fluctuations.
Employee turnover
2024 2023
Employee turnover (headcount) 1,845 1,876
Total number of employees (headcount) 16,439 16,400
Employee turnover rate (%) 11% 11%
Employee turnover
Percentage is based on the employees who left NN Group in 2024
compared to the headcount year-end. NN Group does not include interns
in the employee turnover rate.
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Employees covered by collective labour agreements and workers’ representation
Covered by collective labour
agreements (%)
Covered by workers’ representation
(%)
2024 2023 2024 2023
The Netherlands 85% 85% 100% 100%
Poland 0% 0% 100% 100%
Japan 0% 0% 100% 100%
Czech Republic 0% 0% 0% 0%
Belgium 100% 100% 100% 100%
Spain 100% 100% 73% 75%
Romania 100% 100% 100% 100%
Hungary 0% 0% 0% 0%
Greece 100% 100% 100% 100%
Slovak Republic 0% 0% 90% 90%
Other 0% 0% 90% 91%
Total 66% 65% 90% 91%
NN Group provides insight into the extent to which
its working conditions and terms of employment are
determined by, or influenced by, collective labour
agreements, as well as to the extent to which NN
Group’s employees are represented in social dialogue
at country level. In this context, NN Group has a
European Works Council (EWC). See p. 187 for more
information.
Percentage is based on the coverage and
representation of employees at year-end.
Employees by age category
2024 2023
Headcount Percentage Headcount Percentage
<30 years of age 1,858 11% 1,955 12%
30 - 50 years of age 9,818 59% 9,861 59%
>50 years of age 5,006 30% 4,838 29%
Total number of employees 16,682 100% 16,654 100%
Numbers represent the headcount per age group at
year-end. Interns are included in the numbers for age
categories.
Employees covered by health and safety systems
2024 2023
Percentage Percentage
Employees covered by
H&S system 100% 100%
Percentage is based on the coverage of employees at
year-end.
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Gender distribution at top management level
2024 2023 Base year (2021) Target 2025 % Actuals / Target
Headcount Percentage Headcount Percentage Percentage Percentage Percentage
Number of females in top management 73 41% 73 40% 34% 40% 103%
Number of males in top management 103 59% 109 60%
Number of other in top management
Total number of employees in top management 176 100% 182 100%
Top management
At NN Group we use the following definition of ‘top
management’: employees (in headcount, at year-end)
that hold positions in the Management Board or
managerial positions reporting directly to the
Management Board, as well as the managerial
positions reporting directly to the CEOs of Non-life,
NN Bank or the CEOs of NN International business
units.
Newly hired managers
‘Newly hired managers’ includes the headcount of
all employees who have joined NN Group during
the reporting period whose responsibilities include
managing other employees.
Newly hired managers
2024 2023
Headcount Percentage Headcount Percentage
Number of newly hired managers female 21 34% 44 41%
Number of newly hired managers male 40 66% 63 59%
Number of newly hired managers other
Total number of newly hired managers 61 100% 107 100%
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Incidents and complaints
2024 2023
Incidents of discrimination, incl. harassment (# of cases) 10 8
Complaints filed through channels for people in NN’s own workforce to raise concerns (incl.
grievance mechanisms) (# of cases) 40 31
Total amount of fines, penalties, and compensation for damages as a result of work-related
incidents and complaints (EUR million) 0 0
Total number of severe human rights incidents (# of cases) 0 0
Total amount of fines, penalties, and compensation for damages regarding identified cases
of severe human rights (EUR million) 0 0
Incidents
‘Incidents’ refers to any work-related event that has
occurred, and has been formally registered, and that
relates to discrimination including harassment.
Complaints
‘Complaints’ are those that are formally registered.
They must relate to a complaint between the
employee who reports the complaint and NN Group.
Severe human rights
NN Group discloses whether severe human rights
issues and incidents connected to its upstream and
downstream value chain have been reported.
An incident can be classified as a severe human
rights impact if it meets these two criteria:
it covers one of three incident categories (forced
labour, human trafficking, child labour); it meets the
definition of ‘severe’ by virtue of one or more of the
characteristics scale, scope and irremediability.
A total of ten incidents are reported under category
ESRS 1-17 103(a) discrimination, including
harassment. The sources used are whistleblowing
reports and concerns, CSI investigations, and HR
complaints that qualified as an incident. A report is
qualified as an incident when disciplinary measure(s)
is taken.
A total of 40 other complaints related to matters
of working conditions in paragraph 2 under ESRS
1-17 103(b), are reported. The sources used are
all other whistleblowing reports and concerns,
excluding all whistleblowing reports and concerns
which are related to incidents reported in 103(a)
and excluding the whistleblowing reports which
are not related to matters of working conditions in
paragraph 2, and adding the complaints reported by
HR. Multiple reports of complaints may result in an
incident. Therefore, all complaints associated with
an incident are excluded during the deduplication
process. Overtime figures may fluctuate slightly due
to ongoing investigations into certain complaints.
Spend on training and development per employee
2024 2023
(EUR) (EUR)
Spend on training and
development per employee
(EUR) 1,220 946
Spend on training and development
NN Group provides insights to enable an
understanding of the training and skills development-
related activities that have been offered to
employees. The total amount spent on training and
development is expressed in euros and divided by
the total number of employees (including interns) in
headcount at the end of the reporting period.
Performance review
2024 2023
Percentage Percentage
Female employees with
completed performance
review 86% 85%
Male employees with
completed performance
review 89% 87%
Other employees with
completed performance
review 100%
Employees with
completed performance
review 87% 86%
To calculate this percentage we used the completed
performance reviews of the previous year, excluding
interns.
Reasons for performance reviews that are not
completed include new hires, end of employment,
redundancy and (long-term) illness.
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Workers in the value chain
We strive to contribute to the well-being of people
and planet and to create sustainable long-term value
for all our stakeholders. In our key roles as employer,
business partner, financial services provider and
investor, we affect the lives of many people across a
wide range of sectors, geographies and value chains.
In the context of workers in the value chain we
identified the roles of business partner and investor
as material, and it is those we will concentrate on in
this chapter.
Our DMA identified 'workers in the value chain' as a
sustainability matter in both these roles. We used
the outcomes of our 2023 salience assessment
as input for the 2024 DMA. For our investment
activities, the identification was based on three
underlying salient issues: non-discrimination and
equality, living wage, and child and forced labour. As
a business partner, the identification was based on
two underlying salient issues: equal pay, and freedom
of association and collective bargaining, (see p. 211
for definitions of these terms). These salient issues
were reconfirmed during the 2024 DMA. For more
information on the salience assessment, please see
the introduction to this section, on p. 182.
As an investor, our diverse investment portfolio
covers investment assets invested for own risk
(proprietary assets) and those that are invested for
risk of policyholders (client assets). This chapter will
focus on assets invested for own risk. As a business
partner, we procure goods and services in categories
that include IT, professional services and facility
management; each with its own value chain and with
its own human rights risks, usually location- and
work-specific. Across all these activities, in both
roles, we may be linked with potential negative
impacts on people’s lives.
In the following paragraphs we describe our policies,
processes, actions and targets to help mitigate
potential negative impact on workers in the value
chain, addressing each topic first from our role as
investor, and then as supplier.
For information on how the interests, views and
rights of workers in the value chain inform our
strategy and business model, see the connectivity
table on p. 126.
Policies
As an investor, we are supported by a solid
policy framework and governance structure.
Our responsible investment policies are based
on relevant international standards, principles
and guidelines, such as the OECD Guidelines for
Multinational Enterprises on Responsible Business
Conduct, the UNGPs and the ten principles of
UN Global Compact (UNGC). We respect human
rights and, as a responsible investor, aim to
use our influence to cease, prevent or mitigate
(potential) adverse impacts on human rights and the
environment.
Because we maintain a large, broadly diversified
proprietary investment portfolio that includes
investments in various companies, operating in a
wide array of countries and industries, we may be
directly linked to any potential or actual negative
impacts those companies have on human rights,
according to the principles of 'cause, contribute,
and directly linked' outlined in the UNGPs. Where
we are directly linked to adverse human rights
impacts caused or contributed to by the companies
we invest in, we have a responsibility to encourage
these companies to prevent, cease or mitigate these
impacts.
We have translated our commitment to international
standards, principles and guidelines into norms-
based criteria in our Responsible Investment (RI)
Framework policy. The objective of this policy is
to systematically incorporate sustainability IROs
into the investment process. NN Group considers
non-alignment with its RI Framework policy to be
controversial conduct. In the context of human rights
and labour rights, examples of this would be the
limitation of freedom of association, forced labour,
child labour and discrimination. When working with
external asset managers or investing in third-party
funds, we seek to align with our RI Framework
policy as far as possible. We also conduct periodic
monitoring and reviews of asset managers and
funds to evaluate this alignment. If necessary, we
proactively engage with them to further improve their
practices, results and disclosures.
The RI Framework policy contains several underlying
policies and guidelines that aim to embed our
responsibility to respect human rights across
our organisation. These are the Voting Policy for
Proprietary Assets, the Engagement Policy for
Proprietary Assets, the NN Group Exclusion list, and
the Investment Guidance papers on Human Rights
and Labour Rights. The voting and engagement
policies include the minimum active ownership
criteria we expect all investee companies and
external asset managers to investing on our behalf to
respect. The Investment Guidance papers describe
our understanding of the key financial risks and
adverse impacts related to people across all sectors.
The papers aim to provide external asset managers
with guidance on evaluating environmental,
social and governance (ESG) factors when making
investment decisions on our behalf, and are linked to
NN Group's Human Rights Statement. By publishing
these papers externally, we aim to express our
position and use it to leverage change in our
investment activities.
The Management Board is responsible for approving
material changes to NN Group’s responsible
investment (RI) strategy and the RI Framework policy.
The RI Committee advises the Management Board on
RI strategy and policies, oversees our RI approach,
and decides on RI standards, non-material policies
and updates, as well as investment restrictions. The
committee is chaired by the Chief Investment Officer
and includes members from various departments,
including the Management Board, the Responsible
Investment team and Investment Risk Management.
For background on the governance of RI-related
decision-making see p. 78.
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As a business partner, we are committed to
making sustainable procurement decisions and we
encourage our own suppliers to do the same. We
are a key client for many of our suppliers and try to
work together to drive socio-economic issues and
inclusiveness throughout our supply chain. We ask
suppliers to share details of their labour policy as
part of our supplier qualification process so we can
determine if working conditions for their employees
are in line with our expectations. We also assess
human rights risks in our supply chain by asking
suppliers to disclose the measures they take to
prevent modern slavery and human trafficking in their
own business and supply chain.
Our Procurement and Outsourcing Policy governs
our approach to, and minimum requirements for,
sourcing and contract management. The policy refers
to our Sustainable Procurement Statement, which
explains how we address environmental impacts
and human rights issues related to our purchasing
decisions and supply chain. NN Group's Terms and
Conditions include our most important standards on
these issues and by signing them our suppliers agree
to meet the standards we have included on human
rights, environmental care, labour rights, and anti-
bribery and corruption. When agreements are based
on supplier terms and conditions, a thorough check is
conducted to ensure that the standards are included.
Our Supplier Code of Conduct (SCC) outlines what
we require from suppliers in terms of policies and
practices covering the environment, human rights,
diversity and inclusion, and integrity and ethics,
including compliance with, among other things,
the core conventions of the International Labour
Organization (ILO). By either acknowledging the
minimum standards laid out in the SCC, or confirming
that they have in place a code of conduct of a similar
nature, suppliers commit to all existing and future
relationships with NN Group being subject to these
standards. If these minimum requirements are not
reached, suppliers shall inform their primary NN
contact and agree on a timeframe to take measures
to meet them. We offer support where the supplier
is unable to take these measures on its own.
Consequences for non-compliance with the action
plan are decided on a case-by-case basis. In 2025,
we aim to investigate the possibility of defining a
standardised approach.
Our Human Rights Statement highlights our
requirements on human rights not only for
suppliers but for all stakeholders. See ‘Stakeholder
engagement’ on p. 128 for information on how the
interests of workers in the value chain have been
considered. This year, our Terms and Conditions,
SCC, Sustainable Procurement Statement and Human
Rights Statement were revised and updated to
include human rights policy commitments relevant
to workers in the value chain, as well as to meet
the requirements of the Corporate Sustainability
Reporting Directive (CSRD).
NN Group expects suppliers to not only adhere to the
outlined standards but to actively encourage these
principles in their own supply chains.
Processes
Identifying and addressing impacts
As an investor, to identify the potential adverse
impacts we are exposed to, we assessed our
proprietary assets portfolio (corporate listed equity
and fixed income) according to the specific risks (to
people) that may be linked to the particular company,
the sector in which it operates and the country of
location.
We carried out the assessment using available data
from our ESG-data provider Sustainalytics, supported
by data from other external sources. Consequently,
we were able to narrow down the list of all potential
adverse impacts on people to a shortlist of those that
are relevant to NN Group. This shortlist was used as
input for the salience assessment described on p.
182.
The assessment resulted in three salient human
rights issues related to workers in investee
companies’ own operations and supply chains. NN
Group recognises the salient human rights impacts
as material negative social impacts in its DMA. See p.
180 for more information.
NN Group's Controversy and Engagement Council
plays a key role in addressing and monitoring adverse
impacts. It oversees our direct, collaborative and
delegated controversy engagement activities.
Established in 2023, the Council is chaired by the RI
team, with members from NN Group's Investment
Office and Sustainability and Social Impact (SSI)
department. If indications of severe human
rights issues arise, the Council is responsible for
determining whether they constitute a non-alignment
with our RI criteria and if so, how they should be
addressed.
Our Engagement Policy for Proprietary Assets
outlines the triggers for engagement, one of them
being (the increased risk of) violation of NN Group’s
norms-based criteria. The norms-based criteria
include human and labour rights. If the Council
determines that engagement to address the adverse
impacts is feasible, the company in question will be
included in NN Group's engagement programme,
which means that we can either engage with it
directly, or through external asset managers or
engagement service providers.
If we are not able to exert the necessary leverage
with an investee company or sector, we may decide
to exclude the issuer or activity from our investment
universe. However, it is important to note that we
see divestment in the case of adverse human rights
impacts as a last resort since it has the potential to
worsen negative impact instead of alleviating it.
If a company is included in our engagement
programme, a plan is developed that outlines
engagement objectives, milestones, timeframes, and
engagement activities. The engagement approach
varies depending on the type of engagement and
frequency of contact with the company. While our
policies do not explicitly mention vulnerable groups
or people, we do describe vulnerable groups related
to investments in our investment guidance paper on
human rights.
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Next to the active ownership activities carried out by
our external asset managers, we have an in-house
active ownership function as part of the RI team.
The RI Committee oversees the team's activities
and reports to the Management Board on progress
and challenges at least once a year. In the past two
years, we have increased our involvement in industry
initiatives and engagements.
Through our active ownership programme, we
address our commitment to human rights in several
ways. For example, we are active participants in
Sustainalytics’ human rights thematic engagement
programme, and an active member of the Platform
Living Wage Financials (PLWF). Sustainalytics’
human rights programme aims to accelerate the
adoption of the UNGPs by engaging from a human
rights perspective with companies in several high-
risk sectors: metals and mining, infrastructure,
electronics, food and services. The programme
addresses human rights issues that include most of
NN Group’s salient human rights risks. The PLWF is
a collaborative initiative that encourages investee
companies from the garment and food sectors to
enable living wages and incomes in their global
supply chains, and monitors the progress these
companies are making. Over 2024, NN Group led
the engagement trajectories with Nestlé and Ahold
Delhaize.
We require our asset managers to regularly provide
updates on their voting and engagement efforts,
which are then combined with our own active
ownership activities and included in the NN Group's
Active Ownership report. Our Active Ownership
report also contains the number of engagement
dialogues we have held with investee companies
on human rights, and information on engagement
dialogues with companies involved in controversies.
In our role as business partner, we reviewed our
due diligence process to identify and remediate
(potential) adverse human rights impacts. As a result,
we have revised the onboarding process for new
suppliers to embed salient issues in contracts, and
scan current suppliers to identify high-risk pockets
of activity (taking a risk-based approach based
on sector geography and an understanding of the
value chain). In addition, we have set up supplier
engagement with relevant suppliers, and revised the
SCC and other relevant policies to increase focus on
salient issues.
NN Group’s Terms and Conditions require suppliers to
perform regular due diligence in their value chain, and
if adverse impacts occur to take action and inform
NN Group. Suppliers are also required to update our
supplier qualification questionnaire every year and
provide us with information related to the outcomes
of their own due diligence process. This is part of NN
Group’s overall Supplier Risk Management process.
This year we launched a Supplier ESG Engagement
Programme, assessing selected suppliers on the
human rights-related strategies and policies they
have in place and on how they report on gender
equality and equal pay. We asked those suppliers we
found lacking to commit to providing a timeline for
correcting the gap.
For 2025, the engagement programme will also
include assessments on freedom of association and
collective bargaining for suppliers where it is found
to be relevant. The supplier engagement occurs
during the lifetime of the contract execution, and
implementation of action plans are followed up during
the regular performance meetings that contract
managers have with the relationship managers on
the supplier side. These regular meetings can be
quarterly, semi-annual, or annual, depending on
the criticality of goods or services that the supplier
delivers, and the spend.
The Chief Procurement Officer is operationally
responsible for the programme. While we do not
engage directly with all value chain workers, we
consider the vendor representative and their
sustainability teams to be reliable proxies for the
salient issues identified. In 2024 the scope of the
programme was limited to suppliers of the Dutch
business units and NN Group support functions,
representing more than 25% of the spend in the
Netherlands. In 2025, we will expand the scope to
include other operating countries and to cover 30% of
the spend of NN Group.
Remediating negative impacts
One way we help remediate negative impacts is
by having mechanisms in place for employees,
contractors, subcontractors and suppliers to report
concerns around human rights wherever they occur
across the value chain, including in NN Group itself.
We do not restrict value chain workers from using
these mechanisms. While we do not currently
assess if value chain workers are aware of, or trust,
these mechanisms for raising and addressing
their concerns, in 2025 we aim to look at how
we can establish a process to improve efficient
communication and adequate trust. For information
about our International Whistleblower Policy and
Whistleblower Standard for Dutch Business Units and
Head Office of NN Group, as well as the process, see
p. 116.
Potential non-alignment of investee companies with
NN Group’s norms-based RI criteria may be raised
by stakeholders such as NGOs, media sources,
external ESG researchers, engagement providers,
external asset managers or NN Group research staff.
Throughout the different phases of the due diligence
process, we actively seek dialogue with stakeholders
if they signal specific (severe human rights-related)
issues, or if we have concerns about a specific
case. We aim to understand their concerns and,
where relevant and possible, adjust our responsible
investment policies and processes. Potentially
affected stakeholders can also report their grievances
with us, including those related to human rights and
environmental issues. We recognise that we can
make our grievance mechanism for stakeholders
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more accessible, including those stakeholders that
are negatively affected by our investee companies.
We acknowledge that the preferred route is to
ensure suppliers have their own mechanisms for
reporting human rights concerns, as recommended
by the OECD guidelines on due diligence. We
assess whether suppliers have such mechanisms
in place during the supplier onboarding process.
All suppliers who sign our SCC commit to enabling
their employees and other stakeholders to report
concerns, including potentially unlawful practices, in
the workplace.
Procurement does not yet have established
processes in place to provide or enable remedy in the
event of material negative impacts. Over the course
of 2025 we plan to establish a Target Operating
Model Sustainable Procurement, which will include
such processes.
Acting on material impacts and mitigating
material risks
As an investor, we have made significant efforts in
recent years to improve our due diligence process,
including active participation in the International
Responsible Business Conduct Agreement for the
Dutch insurance sector, a multi-stakeholder initiative.
(See ‘Our strategy and business’ on p. 37 for more
information about this Agreement.) In 2024, we took
a step towards addressing the challenging issue of
measurability around human rights. It is not easy
to determine metrics to measure the impact and
effectiveness of our due diligence efforts on people
on the ground. As a step in this direction, we have
created a social roadmap that includes investigating
meaningful metrics on effectively addressing
adverse impact and strengthening our company-
wide grievance mechanism to enable affected
stakeholders to voice concerns. We aim to further
implement this roadmap during 2025 and 2026. See
p. 182 for more information.
When it comes to our role as business partner, no
severe human rights issues or incidents connected
to NN Group’s upstream value chain have been
reported or identified via negative news screening.
We currently do not have a documented process
to identify what action is needed and appropriate
in response to actual or potential negative impact
on value chain workers. If impacts are identified,
they will be treated on a case-by-case basis. During
2025, we will investigate the need of establishing a
documented process.
Our Supplier ESG Engagement programme (see
above) works as our mitigating strategy for potential
impacts on value chain workers. One of the steps
in the programme is to request suppliers in scope
to commit to establishing action plans to improve
their current policies and strategies around gender
equality and equal pay in their workforce. For 2025,
our focus will expand to encourage suppliers to
respect the right to freedom of association and
collective bargaining for their employees. We will
measure the effectiveness of the Supplier ESG
Engagement programme by yearly monitoring of
suppliers in scope, from the moment they joined
the programme until the engagement is considered
complete. As the programme launched in 2024, we
have not yet been able to assess its effectiveness.
We train all procurement professionals to consider
sustainability and human rights issues when
selecting a new supplier. Our terms and conditions
are applicable to all new contract and renewals, and
they outline our minimum environmental and social
requirements. NN Group's Procurement Sustainability
Officers regularly join peer learning groups to support
the development of collaborative action.
Targets
We do not yet have specific targets for managing
material negative impacts, advancing positive
impacts or managing material risks and opportunities
for our role as investor or business partner. As part
of our social roadmap, NN Group plans to investigate
establishing targets, tracking our progress against
them and identifying possible areas and related
actions for improvements.
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Community investment
NN Group has made a strategic commitment to
contribute to the well-being of people and the planet.
As part of this commitment, we aim to support
the financial, physical and/or mental well-being of
one million people in the communities in which we
operate by 2025. Our community investment focuses
particularly on people in our communities whose
well-being is under pressure or at risk.
We invest resources, expertise, and networks
to make positive change in those communities,
together with community partners such as non-profit
organisations, social enterprises and knowledge
institutes.
Our activities related to financial well-being aim to
improve people’s ability to meet financial obligations,
increase confidence in their financial future and
improve their ability to succeed in work and life. Our
activities related to physical and mental well-being
aim to empower people by improving their health
literacy (the ability to find, understand and use health
services) and provide access to quality healthcare.
We also intend to help people stay socially engaged
and reduce potential loneliness.
We apply a globally consistent and locally relevant
approach. ‘Globally consistent’ means we all adhere
to the same Group-wide standards and work on
societal issues that are close to our business
priorities. ‘Locally relevant’ indicates that we apply
the local context in developing interventions tailored
to specific local challenges and needs.
Our community investment programme adds
value to the business in various ways. It creates
sustainable long-term value for stakeholders and is
in line with our values and purpose. The programme
is aligned with the business by focusing on topics
that are relevant to business, society, customers
and employees. In our employee engagement survey
(Peakon), colleagues score an average of 8.5 on
a scale from one to ten when asked if they agree
with the statement: ‘I think it’s important for NN
to contribute to society by supporting charitable
organisations and volunteering’.
Interest in our community investment efforts is
recognised externally. NN Group receives invitations
to give presentations, keynotes and guest lectures at
events and knowledge institutions. Our community
investment activities are aligned with NN Group’s
DMA. See p. 125 for more information.
For information on how the interests, views and
rights of communities inform our strategy and
business model, see the connectivity table on p. 126.
Policies related to community investment
Our Sponsorship and Charitable Donation policy
encompasses objectives, scope, target audience,
risk management, control objectives and minimum
requirements related to sponsorships and community
investment. It serves as a guide for both sponsorship
and charitable donations, highlighting their
similarities and differences. The policy’s primary goal
is to establish mandatory principles and minimum
requirements for every charitable donation or
contribution we make, outlining the responsibilities
of all involved parties.
The policy has a dual purpose. First, we aim to
strengthen the positive impact of sponsorships and/
or community investment on our brand strength,
visibility, distinct positioning, and SSI profile by
establishing key themes to focus on. Second,
we seek to prevent and manage the potential
reputational risks and inherent risk of corruption
and conflict of interest caused by sponsorships and
community investment. We also clarify what is in
scope and what is not.
At NN Group, community investment includes cash
contributions, management costs, volunteer hours
and in-kind giving (the last two are both monetised).
Cash contributions are the gross monetary amount
that we pay to support a community organisation
or project. These include charitable donations,
membership of community organisations and
research for the public good.
Volunteer hours are paid working hours that
employees spend on a community organisation
or project. They include volunteering, training,
technical assistance and secondments. ‘In-kind
giving’ consists of free donations of company goods,
used equipment, meeting rooms or other resources.
Management costs include the salaries, benefits
and other overheads of community investment staff,
along with spend on research and communications if
it is used to help us engage with the community.
Two key documents support this policy: the
Charitable Donations Flowchart and the Charitable
Organisation Qualification Questionnaire. The
Flowchart helps determine whether a contribution
falls within scope and, if so, outlines the necessary
steps to take, such as compliance checks. The
questionnaire, part of our due diligence process
developed in consultation with local compliance
officers and/or operational risk managers, supports
our selection of legitimate, reputable charitable
organisations while mitigating associated risks.
We align our policy with the Business for Societal
Impact (B4SI) framework for measuring social
impact. We report according to its Corporate
Community Investment Guidance Manual, and
Corporate Community Investment Guidance Notes.
We also have an impact measurement framework in
place, in line with the policy and B4SI standard, to
further refine our transparency and accountability in
terms of the impact of community investment.
The Sponsorship and Charitable Donations policy
applies to all NN Group businesses, including head
office and those under NN Group’s management
control. In cases where local laws or regulations
impose stricter rules, those prevail. The policy
extends to our own operations. The Chief People,
We bring the best of NN
Whether through funding,
volunteering, (in-kind) donations
or our own expertise, we work to
strengthen our communities by
bringing the best we have to offer.
We are globally consistent
and locally relevant
Challenges in one community are
different from those in another.
Our global, Group-wide standards
provide clarity and consistency to
our work, and yet we always take
local context into account.
We build strong partnerships
for lasting impact
We not only support individual
organisations that have social
impact, but also bring different
partners together to increase
scope and strengthen our
partners’ organisational capacity
with our own expertise.
We take a systems approach
By working with a variety of
partners with complementary
expertise, we stimulate
stakeholder dialogue,
collaboration and research.
We are transparent and
accountable
Using the Business for Social
Impact (B4SI) framework, we
ensure a professional, consistent
and credible approach to reporting
and impact measurement.
Five key principles for community investment
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Communications, and Sustainability Officer is
accountable for policy implementation. The full policy
is available on NN Group’s intranet, for employees
only. The B4SI framework is publicly available on our
own website. The Guidance Manual and Guidance
Notes are available to B4SI members.
We base our community investment activities on five
key principles, shown in the table below.
Our local markets receive annual budgets for
community investment. Each year, based on
these budgets, the representative responsible
for community investment presents a business
plan including a three-year forecast on their cash
contributions, management costs, volunteer hours
(monetised), and in-kind giving (monetised). The
annual budgets are set in November for the following
year. All activities within the scope of our policy are
downstream and focused on our markets.
In 2024, we implemented a Community Investment
Impact Framework for internal use, providing further
details on our methodology and specifying in which
cases we can claim impact.
Results
People supported in their financial, physical
and/or mental well-being
We have the target to support the financial, physical
and/or mental well-being of one million people
by 2025 through our community investment
programme. The target is absolute and measured
by number of people supported. We define ‘people
supported’ as the number of beneficiaries who
receive a product or service through our contribution.
We divide that into two categories: ‘Financial well-
being’ and ‘Physical and mental well-being’. To
avoid double-counting, we only account for people
supported when the support comes to an end, and
only for those people who have been supported
thanks to our contribution. Also, in many instances,
people who received support once, do not return
for the same support again. But for a small portion
of activities there remains a small risk of double
counting. To protect the privacy of beneficiaries, we
cannot track this but consider this risk to be limited.
NN Group accounts for ‘people supported’ through
reporting from external partners.
Our partners report the number of people supported
by us in their half-year and full-year reports. For
the Disaster Relief Fund, NN Group refers to actual
reports and project proposals to define the number
of people supported whenever possible. However,
when the Red Cross provides immediate disaster
relief, they are often unable to confirm the number of
people supported through reports. In such cases, we
use a monetary proxy of EUR 90 per person, which
is a cautious estimate of the cost of an emergency
aid package, per person, in 2024, provided by Red
Cross Netherlands. This figure can be revised if new
estimates or reports become available during any
of the emergency aid campaigns supported by NN
Group.
In 2024, we supported a total of 364,904 people,
of which 217,302 were supported in their financial
well-being and 147,602 in their physical or mental
well-being.
Total contributions to communities
Total contributions are disclosed in euros and include
cash contributions, management costs, volunteer
hours and in-kind giving (both monetised). NN
Group discloses this amount as a percentage of its
operating capital generation (OCG). For this purpose,
the average OCG of the three preceding years is
used. Until 2023, NN Group disclosed community
investment as a percentage of Operating Result. In
line with OCG being NN Group’s primary metric for
its financial performance, as of 2024 the community
investment amount is disclosed as a percentage
of OCG. The comparative figures in the table were
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adjusted accordingly. This change had no impact
on the community investment target to support the
financial, physical and/or mental well-being of one
million people by 2025.
In 2024, we contributed 1.1% of OCG (the average
of 2021, 2022 and 2023) or EUR 18.7 million.
The scope of any community investment metric or
action is all NN Group markets with a business unit
employing more than 100 FTEs, unless there has
been a waiver procedure in line with our policy.
This year we continued our efforts to build strong
partnerships for lasting impact. Our local business
units further developed their partnerships in line with
our strategy and targets.
In 2024, the NN Social Innovation Fund committed
to invest EUR 2 million in Rubio Impact Ventures to
support social enterprises that positively impact
those whose well-being is at risk. Also we allocated
EUR 2 million to launch the partnership Mental
Well-being & Resilience for the Next Generation in
collaboration with SOS Children’s Villages and Save
the Children, two organisations working to improve
the psychosocial well-being of children worldwide.
By the end of 2025, through this initiative, we hope
to support over 40,000 children, adolescents and
caregivers with essential resources and care.
We also strengthen our partners’ organisational
capacity and take a systemic approach. For instance,
in the Netherlands, the ‘coaching for impact’
programme supports individual organisations in their
organisational development. We supported Emma
at Work for example, with its strategy development.
By using detailed data research of the target group,
Emma at Work adjusted its proposition and has
set the ambition to increase its impact tenfold.
NN Group also works with various partners that
have complementary expertise, and stimulates
stakeholder dialogue, collaboration and research.
As well as our participation in the Dutch National
Coalition for Financial Health (see below), we support
the University of Ghent in its research on happiness
in Belgium, and the University of Amsterdam with
the development of its Research Centre for Longevity
Risk.
The time horizons of the actions described above
vary from one partner to another; we have multi-
year agreements with some partners and annual
agreements with others. Our intention with all
of our partners is to build long-term sustainable
partnerships that work towards lasting impact.
The table below shows our progress on each of the
actions and metrics disclosed for the period 2022 to
2024.
Overview of our contributions to society (amounts in EUR million)
2024 2023 2022
Cash contributions 14.4 16.0 9.7
In-kind donations (monetised) 0.3 0.4 0.2
Volunteer hours
1
2.3 2.0 1.5
Management costs 1.6 1.6 1.4
Total contribution 18.7 20.1 12.8
% of operating capital generation
2
1.1 1.4 1.0
People supported with financial well-being 217,302 120,705 63,870
People supported with physical and mental well-being 147,602 50,896 165,409
Total number of people supported 364,904 171,601 229,279
Cumulative progress on target of people supported (2022-2024) 765,784 400,880 229,279
1
Monetised at EUR 55 p/h in 2024, and at EUR 50 p/h in 2023 and 2022.
2
Based on the average of three preceeding years.
Cash contributions
In 2024, we contributed EUR 14.4 million to our
community investmentment partners through cash
contributions.
NN Group’s cash contributions are measured in
euros. We account for our cash contributions through
contracts and invoices for example. Our Disaster
Relief Fund, set up in 2023, helps to mitigate
potential risks for our company and our stakeholders
in the case of (natural) disasters. In 2024, this
fund was used to support those impacted by the
earthquake in Japan, wildfires in Greece, and floods
in Poland, Czech Republic, Romania, Hungary and
Spain.
Management costs
In 2024, NN Group spent EUR 1.6 million on
management costs to professionally organise the
community investment programme. We account for
management costs based on, for example, contracts
and invoices. We account for FTE costs based on
the internal overview of cost allocation of FTEs at
the respective department where the community
investment programme is run.
In 2024, total management costs for community
investment represented 8.7% of total contributions
to communities.
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Volunteer hours
In 2024, we volunteered 42,409 hours across our
markets. This has a monetised value of EUR 2.3
million.
Volunteer hours are monetised at EUR 55 per hour
and based on time contributions. Since 2022, we
calculate time contribution costs based on the
average hourly rate at NN Group for the previous year,
rounding it down to approximate actual costs. In,
2024, in line with the methodology used in previous
years, we calculated the hourly rate based on the
total employee remuneration across NN Group as
disclosed in our 2023 Annual Report, divided by
1,650 hours a year, as this is the NN Group standard
for a full-time equivalent (FTE). This is rounded down
to a total cost of EUR 55 per hour.
The parties we volunteer for confirm the volunteer
hours through reports or email. We then reconcile
the hours confirmed with our internal registration.
A potential limitation of this methodology is that
it does not represent market value or actual value
to society.
Every business unit with a community investment
programme offers year-round volunteer
opportunities. Since 2020, NN Group has organised
an NN Volunteer week. In 2024, 2,106 employees
signed up to volunteer for a partner organisation
during that week. We continue to further build this
programme, seeking a balance between employee
interests, social impact and business relevance.
This approach is expected to lead to an increase in
volunteering hours in the coming years.
In-kind donations (monetised)
In 2024, NN Group contributed EUR 310,000 in
‘in-kind giving’. All in-kind contributions are valued
at what they have cost the company to make, not at
what the beneficiary organisation would otherwise
have had to pay in the open market
1
.
In-kind giving is measured in euros, at day value (e.g.
day value at amortised costs and based on evidence
from internal finance/service department or against
actual costs for NN through invoices). We account
for our in-kind donations based on contracts and
invoices for example, or external sources that confirm
the value.
Where appropriate, we look into how office
equipment such as furniture and laptops can be
shared with partner organisations. We do not plan or
steer on this but take a case-by-case approach based
on the added value our in-kind resources can bring to
these organisations and their beneficiaries.
Actions
National Coalition of Financial Health
Since 2023 we have been part of the Dutch National
Coalition of Financial Health, which aims to improve
the financial health of households in the Netherlands.
Through our participation in this coalition, we intend
1
B4SI Guidance Manual, 2021, Chapter 1.2, p. 12.
to contribute to the financial health of employees,
lead the working group for small and medium-sized
enterprises (SMEs) and to contribute EUR 10,000 to
support the coalition’s mission. The time horizon is
multi-year, but we may reconsider our engagement
with the coalition each year. The actions we take are
downstream and in the Netherlands only. The current
focus is on employees, but in the future the coalition
intends to broaden its scope to include other
stakeholders such as customers. In 2024, NN Group
actively participated in the working group on SMEs to
support SME employers with the financial health of
their employees.
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Consumers and end-users
‘Consumers and end-users’ comprises customers,
both retail and business, and our corporate clients.
Customers are the starting point for everything we
do. We aim to support them in dealing with both
expected and unforeseen changes at key moments in
their lives by offering products and services that are
easy to understand and use.
We operate in an ever-changing landscape. People
live longer, digital technologies are evolving rapidly,
and global warming is of growing concern. We
support customers in navigating this landscape by
providing products and services that aim to address
both their changing needs and societal issues,
assisted by our digital capabilities.
We have identified two material sustainability
matters that impact all our customers: ‘financial
inclusion’ and ‘clear and secure data’.
Material IROs and how they interact with
strategy and business model
All material impacts related to customers are linked
to NN Group’s strategy and business model; this is
illustrated in the visual on p. 180 under the value
chain role ‘Our products and services’ and detailed
further in ‘General disclosures’ on p. 126.
We identified financial inclusion as a material
sustainability matter for several reasons. Both
retail and corporate clients could be exposed to
potentially negative impacts on their right to privacy,
data protection, freedom of expression and non-
discrimination. They also both rely on accurate and
accessible information about avoiding harm when
using our products and services. We acknowledge
there may be customers who are potentially
vulnerable to marketing and sales practices. Both
of these customer groups are covered by our
sustainability disclosures.
We strive to offer products and services that serve
customers, and we aim to safeguard financial
inclusion. Our marketing practices, including the
way we communicate with customers, are designed
to support transparency, fairness and customers’
well-being. Our approach to arrears management
reflects our commitment to treating customers fairly
and responsibly, while also maintaining the financial
stability of our business.
The potential negative impacts identified in the
sustainability matter ‘clear and secure data’ are
typically related to individual incidents. In contrast,
the potential negative impacts identified in ‘financial
inclusion’ can be more systemic. We have not yet
developed an understanding of which types of
customers are at greater risk of harm.
For information on how the interests, views and
rights of customers inform our strategy and
business model, see the connectivity table on
p.126. See p. 122 for information on how we
integrate considerations around material impacts on
customers into our strategy and business model.
Policies and standards
We have several policies and standards in place that
relate to the identified material sustainability matters
‘clear and secure data’ and ‘financial inclusion’.
Policies are set centrally and implemented locally.
Each policy or standard is therefore applicable to NN
Group as a whole and serves as a baseline for our
business units. Below we describe relevant policies
and standards and indicate how our business units
(NN Bank, NN Non-life, NN life and NN International)
implement them locally.
Details about changes to the policies in the
period covered are described in each respective
paragraph. Where relevant, policies reflect the
views and expectations of stakeholders, and are
set and approved by NN according to the applicable
governance.
Product Policy
NN Group’s Product Policy gives concrete guidance
on fulfilling our strategic commitments towards
customers and distribution partners and relates to
the material topic of financial inclusion. Its most
important guiding legislation is the European
Insurance Distribution Directive, supplemented
by the EC-delegated regulation regarding product
oversight and governance requirements for insurance
undertakings and insurance distributors. The
interests of key stakeholders are considered in the
policy setting. NN Bank has additional, dedicated,
product-related policies to accommodate the specific
characteristics of banking products.
The Product Approval and Review Process (PARP),
part of the Product Policy, aims to reduce product
risk by assessing effective design, underwriting and
claims management, and the adequate pricing of
products, as well as assessing their suitability for
customers. PARP also safeguards that products are
reviewed on a regular basis and can be effectively
managed throughout their lifetime.
We regularly assess the product portfolio for
compliance with the Product Policy, as well as its
effectiveness. The policy owners are responsible for
informing the relevant functional line in the business
regarding policy updates and other (potential)
changes. Regulation related to our products may
vary locally, but all local standards and policies
must comply with the Product Policy as maintained
by NN Group. The policy was updated in December
2024, adding sustainability elements and ensuring
alignment with product descriptions.
Responsible Insurance Underwriting
Framework Policy
The Responsible Insurance Underwriting (RIU)
Framework Policy, which also covers financial
inclusion, sets the minimum standard for
implementing sustainability in our underwriting and
related product development and risk management
activities. The policy was published in April 2024
and aims to integrate sustainability matters into
insurance activities by evaluating the sustainability
risks and opportunities associated with a product or
service, as well as considering the potential impact
on clients, society and the environment. The policy
currently applies to the Dutch insurance activities
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for the retail and commercial lines of Nationale-
Nederlanden Schadeverzekering Maatschappij N.V.,
ABN AMRO Schadeverzekering N.V., Nationale-
Nederlanden Levensverzekering Maatschappij N.V.
and NN Re (Netherlands) N.V.
NN Group’s business units in the Netherlands were
given a year from the policy’s publication date to
define an implementation processes to align their
business activities. The implementation deadline for
NN Group’s business units in the Netherlands
is still running. Each business unit may develop
its own implementation process, based on the
RIU Policy and guided by the RIU Committee, to
accommodate its specific context. In the meantime,
the RIU Policy serves as a guiding principles for our
insurance activities beyond the Netherlands. We
will review the policy annually and revise it when
necessary to keep it relevant.
Data Protection Policy
The Group Data Protection Policy aims to support
adherence to the principles of the General Data
Protection Regulation (GDPR), as well as considering
the interests of key stakeholders and mitigating risks
associated with non-compliance to data protection
requirements, laws and regulations. The policy
applies to all NN Group entities established in the
EU that process personal data, and to those that
process the personal data of data subjects within
the EU, regardless of whether they are located in
the EU. Compliance with the policy is established by
implementing and monitoring related work processes
and statements, such as the Data Protection Officer
(DPO) Charter, the NN Privacy Statement and the
NN Code of Conduct. The Group Data Protection
Policy also includes a process for reporting data
breaches. There were no material changes to this
policy in 2024.
NN Artificial Intelligence Framework
The NN Artificial Intelligence Framework (NN
AI Framework) aims to achieve adequate
implementation and use of trustworthy AI within NN
Group for the ethical, transparent, and responsible
use and development of AI technologies. The
Framework aligns with the EU’s Artificial Intelligence
Act (AI Act). All business units and staff departments
must adhere to the NN AI Framework by conducting
AI Assessments before developing or using AI
systems. The AI Working Group validates these AI
Assessments with a specific focus on ethical aspects.
NN life and NN Non-life are both adding their own
enhancements. NN Non-life for example, is setting
up a local AI working group to help ensure there is
focus on the ethical implementation of AI, and that
potential follow-up actions are taken.
The AI Working Group is developing an AI
Governance model that empowers business units to
implement an effective AI governance structure and
that can be resized to meet their specific needs. The
Framework was updated in 2024 to ensure alignment
with the AI Act that came into force in August 2024.
Incident Management Standard
The Incident Management Standard aims to ensure
adequate and timely reaction to (potential) incidents
to limit their impact, including any material breaches
of laws, regulations, internal policies or standards. It
also aims to create a feedback loop for learning from
such incidents, and to enable disclosure to regulatory
bodies if appropriate or required. The Standard
applies to all NN Group’s processes. Compliance with
the Standard, and its effectiveness, are monitored
through regular reporting, monitoring of key
performance indicators, and regular assessment of
the incident management process. The Standard was
revised in June 2024.
Human rights
The relevant policies are aligned with NN Group’s
Human Rights Statement and designed to ensure we
respect and protect human rights, including those
associated with privacy, data protection and the fair
treatment of customers. Our NN AI guidelines also
include ethical considerations for the development
and use of AI, safeguarding that we do not violate
either human rights or data privacy.
We do not track cases of not respecting these
standards that involve customers, as there is no
labelling system in place to identify such cases in
the downstream value chain. Therefore, we cannot
confirm if there has been a case of non-respect.
NN Group is committed to promoting responsible
business practices and upholding human rights and
labour rights standards in our operations and supply
chain. Engagement with customers regarding human
rights is part of our salient human rights analysis and
general human rights efforts. (See p. 181-182 for a
full description of our human rights approach.)
Processes for engaging with customers
When we develop products, we use market research
to help us meet the needs of a diverse range of
customers and aim to ensure they receive all relevant
information before making a purchase. We also reach
out to clients if documentation or information is
needed to avoid mis-selling, and do our best to make
sure they have access to the financial services and
support they need.
Regarding our material sustainability matters of
‘financial inclusion’ and ‘clear and secure data’, we
have not yet taken specific steps to identify those
customers who are particularly vulnerable to financial
non-inclusion or exposure to data breaches. It is for
this reason that we describe our general processes.
The processes for engaging with customers,
including the frequency of engagement, vary
depending on the product and distribution channel,
as does the most senior role responsible for that
engagement. We enable direct customer contact
through our call centres and conduct surveys
allowing customers to share their experience
with us. In certain cases, we discuss issues with
consumer organisations representing a broad
range of customers. We evaluate how effective our
engagement is through periodic product reviews and
customer feedback. The NN statement of Living our
Values and our Communication Approval Process
both provide guidance on engaging with customers,
and safeguard that the communication contains
all relevant information and is in line with our
communication standards.
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To reflect our commitment to financial inclusion for all
customers, NN Bank has a dedicated team that aims
to help customers who fall behind on payments. In
the Netherlands, NN Life harnesses services such as
Pensioen Hulp and Pensioen TV to help customers
over the age of 50 prepare for their pension date.
Pensioen Hulp is free and used by around 70,000
Dutch customers. Pensioen TV is also free for all
active and inactive users of our pension products. It
explains what recent changes in the Dutch pension
system mean for them as NN customers.
Processes to remediate negative impacts
and for raising concerns
Each business unit has processes for addressing
concerns and negative impacts, as well as channels
available for customers to raise concerns. Multiple
channels, such as online calls and dedicated contact
centres, are available for customers to raise concerns
on matters related to financial inclusion and privacy,
among other topics. Our approach is to monitor,
and where possible remedy, the material negative
impacts we have identified for customers, as well as
assess how aware customers are of the channels that
are available to them, and what their experience is of
using them.
We recognise that it is important to not only have
complaints policies and procedures in place, but
also that our customers are aware of them. That is
why we include procedures for complaints, and for
communicating negative impacts experienced by
customers, clearly and in detail on our website. We
also provide an overview of NN Group’s procedures
for response and how we help ensure that such
impacts are addressed, together with routes for
escalation, including details of the appropriate
regulatory channels in those cases where the
customer does not feel we have addressed such
negative impacts satisfactorily. The Incident
Management Standard aims to ensure adequate and
timely reaction to incidents such as data breaches.
In the event of a data breach, NN Group actively
advises the party that caused the breach to take
measures. We have GDPR control frameworks in
place, and our policies detail the designated roles and
functions of people in the company who advise on
GDPR implementation and who monitor compliance.
To address the material negative impacts our
products may have on customers, we hold periodic
product reviews and optimisations during product
design and throughout the lifecycle. If there is a
material negative impact on customers relating
to product design, marketing or sales, we make
adjustments to the relevant (communication)
process. We monitor and review products that have
already been launched to identify anything that
could materially affect the product’s main features,
their risk coverage or guarantees. The Product Risk
Committee, Operational Risk Committee, and Data
Protection Officer (DPO) all play significant roles in
the processes of addressing negative impacts.
Remediation
As part of our financial inclusion remedies,
we apply forbearance measures if a client is
experiencing, or anticipating, difficulty meeting
their financial commitments. We may, for example,
grant concessions for premium payments where
appropriate. Since NN Bank is our clients’ loan and
mortgage provider, we have established arrears
management practices with the bank to assist
customers experiencing difficulties with their
mortgage repayments. We believe this approach
reflects our commitment to treating customers fairly
and responsibly, while maintaining the financial
stability of our business. Financial inclusion and
data privacy are also salient items, as described in
our human rights approach on p. 182 , which also
outlines our grievance mechanism.
Complaints and concerns channels
While there is no Group-wide policy for addressing
complaints, local business units have complaints
policies to guide them on how we remediate
and monitor concerns and negative impacts on
customers. All business units have multiple channels
for customers to raise concerns about our products
or services, either directly, through our website,
or through tied agents/advisors, phone calls, or
formal, regulatory complaints channels. Complaints
are recorded, processed and monitored for timely
resolution, and we have quality control measures in
place to handle them appropriately. Initial responses
are shared with the client within a short timeframe
before assessing the complaint to determine
potential remediation. The local complaints policies
aim to protect complainants from retaliation when
they use these channels and processes. The local
complaints policies and available channels can
be found on the (local) website, along with a clear
description of the complaints and remediation
process.
We monitor the effectiveness of complaints policies
and how complaints are treated. We analyse
the nature of the complaints, the product area,
customer group, root cause and effectiveness
of the response, including remediation efforts,
publishing our findings in the Klachtenrapportage
(complaints report). Our findings are incorporated
into the risk control framework to aid effectiveness,
and recommendations are made for improvement.
In some countries where we operate third-party
sales, partners are also able to use our customer
complaints channels. All business units have internal
processes and committees to deal with complaints
and, where possible, remediate the issues arising
from incidents.
We document lessons learned from the processes
described above and aim to follow up and/or
resolve all incidents in a timely manner. We review
unresolved complaints and seek resolutions (or
escalations, if resolutions are not possible) in
the existing framework. We also measure the
effectiveness of our channels by asking clients for
feedback about our complaints processes, inviting
suggestions for improvement.
Data protection
The Data Protection Policy includes a data breach
reporting process and NN Group is committed to
addressing any concerns or negative impacts that
might arise. This reporting process involves recording
and processing complaints, seeking solutions and
monitoring the timely resolution of complaints.
Channels for customers to raise their concerns or
needs include an online complaint form, physical
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mail, email and phone. NN Group aims to protect
complainants from retaliation when using the above-
mentioned structures or processes.
We aim to ensure these channels are effective
through a transparent communication process,
where responses are given in understandable
language and there is always the possibility of further
contact. NN Group tracks and monitors issues raised
and addressed. Channels are available to customers
directly through NN Group or through participation
in third-party mechanisms. NN Group supports
or requires its business partners to make similar
channels available.
Communication Approval Process
To further protect customers, our local
Communication Approval Process helps ensure all
communications we issue are accurate and clear and
comply with legal and regulatory requirements.
Actions
The policies and standards described above guide
the processes to determine what action we need to
take to prevent, mitigate, and remediate negative
material impacts on customers related to the
sustainability matters ‘clear and secure data’ and
‘financial inclusion’. Recognising the importance
of these topics, we take policy-based actions, and
the responsible business unit or Group function
evaluates the effectiveness of each action. There
is no specific time horizon for current or planned
actions. The specific contribution of each action to
the achievement of policy objectives or targets is not
measured. The scope of each action includes all our
customers, as defined on p. 203.
Regarding data protection, ongoing actions
include:
• training relevant employees to recognise
situations where risks might occur, and how to
prevent breaches;
• rolling out e-learnings, some of them mandatory
for all NN Group employees, aiming to educate
them about the risks and impacts around data
protection, and the processes and policies we
have in place to avoid them;
• if data breaches occur, we inform the local
data protection authority and data subjects, in
accordance with the requirements of applicable
data protection law;
• documenting and monitoring data breaches
and their impact, managed from the relevant
risk perspectives (reputational, regulatory and
financial). Learning from incidents helps us
strengthen he RMF, avoid repeating such incidents
in the future, and continually improve our policies
and processes.
Future data protection-related actions
include:
• simplifying and digitising our internal processes
to reduce errors and provide a better service for
customers.
To help ensure these actions are effective, the DPO
oversees processes that could cause impact in the
area of data protection.
Regarding financial inclusion, ongoing
actions include:
• helping customers who currently face, or who
are in danger of facing, financial distress, and
continuing our efforts committed to make our
products and services financially inclusive;
• referring customers in the Netherlands to the
National Debt Relief Route’s ‘Geldfit’, which
provides information about appropriate support
organisations;
• facilitating contact with budget coaches or job
coaches if needed.
Future financial inclusion-related actions
include:
• having received positive feedback, we plan to
extend a training that was piloted in 2023 and
continued in 2024, about how to recognise
employees who are under financial stress, offering
it free to the HR directors of our pension clients;
• we assume that the ongoing implementation of
the RIU Policy in the Netherlands and abroad will
also lead to actions related to financial inclusion
and, specifically, to product design. See p. 203 for
more details of the policy.
By focusing on financial inclusion, we can help to
reduce inequality and take steps to enable customers
to benefit from a low-carbon economy.
No additional actions or initiatives are in place that
have the primary purpose of positively contributing to
improved social outcomes. For information regarding
the integration of risks regarding our customers, see
‘Managing our risks’ p. 52-62.
Targets
We have not yet set specific targets for financial
inclusion, and do not yet have targets on clear and
secure data. As we monitor changes in customer
needs and in the world around us, we will be making
every effort to respond to these changes.
Contents
Governance sustainability matters 208
Prevention and detection of
corruption and bribery 209
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Governance
Good corporate governance is deeply rooted in our
purpose and essential to achieving our strategic
goals. Our culture and values guide our daily
decisions and shape our interactions with internal
and external stakeholders. We are committed to
conducting business according to our values, which
help ensure compliance with laws and regulations
across the various jurisdictions where we operate.
They also contribute to the continued trust of our
clients, shareholders, employees, business partners
and society.
Through our materiality assessment, we identified
‘corporate culture’, and ‘corruption and bribery in
our own operations’ as material topics for business
conduct. Non-adherence to our values of ‘care, clear,
commit’ can negatively impact our corporate culture
and thereby our stakeholders. Corruption and bribery
are illegal practices that do not align with NN Group’s
core values. They can exacerbate economic inequality
by allowing those with resources to influence
decisions in their favour, often at the expense of the
wider population. They can also potentially harm NN
Group’s reputation.
Using our values to guide our decisions, interactions
and strategic framework will positively impact our
corporate culture, and help us create sustainable
long-term value and fulfil our purpose of caring for
what matters most to people.
Information about combatting corruption and bribery
can be found on p. 209. For more about business
conduct see ‘Our values’ on p. 7 and ‘Our Code
of Conduct and other policies’ on p. 115, while
additional information about our corporate culture
can be found in ‘Our strategy’ on p. 25.
Governance sustainability matters
Corporate culture
Investments
Business partners
Own operations
Products and services
Corruption and bribery
By adhering to our core values ‘care, clear, and
commit’, we can have an actual positive impact
both on individuals and the environment. Our values
are the foundation of our culture, serve as a
compass for decision-making, guide us in all our
interactions and are an integral part of our strategic
framework. By adhering to them we aim to create
sustainable long-term value for our stakeholders.
Through this approach, we foster a culture of
responsibility and sustainability, helping people
protect what they value most.
If we do not live up to our values of ‘care, clear, and
commit’, we have a potential negative impact on
our stakeholders. Poor decision-making or failure to
address highlighted areas of concern and
recommendations for improvement can undermine
trust and damage relationships.
When we do not live up to our core values of ‘care,
clear, and commit’, there is a risk that we have a
potential negative impact if individuals in the
organisation engage in corruption and bribery.
Corruption and bribery is 1) (in most jurisdictions)
illegal, 2) not in line with NN’s values and 3) could
lead to economic inequality, as those with
resources might unfairly influence decisions to their
advantage, often at the expense of the wider
population.
Governance
Positive impact
Negative impact
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Prevention and detection of
corruption and bribery
Fighting corruption and bribery is integral to our Code
of Conduct, which strictly prohibits the offering or
accepting of bribes. We have established policies
and processes to prevent, detect and address
(allegations of) corruption and bribery. Examples
of these include the Outside Positions and Outside
Interests Standard, and the Gifts, Events and
Business meals Policy.
To help prevent corruption and bribery, our risk
framework prescribes periodic risk assessments,
which includes the assessment of bribery and
corruption risk. We also conduct an annual review of
policies to reflect our evolving risk landscape. These
policies are communicated to all employees through
e-learnings and the annual acknowledgment of the
NN Code of Conduct and Manager Annex.
We monitor participation rates and compliance
awareness through our Integrity Dashboard for first-
line management and the Compliance Dashboard for
the Compliance community. All employees (which
includes members of the Management Board and
not members of the Supervisory Board), including
new joiners, must complete the Conflicting Matters
e-learning, which covers corruption, bribery and
conflicts of interest risk, as well as ‘The Code’
e-learning, which covers expectations related to
employee conduct. These trainings are available in
all local NN languages. Additionally, NN Group has
several mandatory e-learnings focusing on raising
awareness about confidential and price-sensitive
information, market abuse and insider trading, the
whistleblowing procedure and the use of data. Since
corruption and bribery was added as a material topic
based on the DMA of 2024, we are assessing the
need for additional training in this area, as well as the
measures needed to calculate the percentage of at-
risk functions covered by training programmes, and
the general trainings and local initiatives we have in
place for functions (inherently) at risk, such as certain
commercial functions, procurement and teams from
investment and/or transactions.
To detect corruption and bribery, we leverage data
analytics to create dashboards that consolidate data
from various sources, enhancing risk management
and compliance monitoring. This supports effective
allocation of resources to manage compliance risks.
We also evaluate and integrate new technologies,
including AI, approved by the AI Working Group,
to address emerging risks. The AI Working Group
oversees AI assessments and the deployment of AI
in the organisation.
We expect (suspected) material breaches of the
Code of Conduct, including bribery and corruption,
to be reported to senior management, who can
commission an independent investigation; the
results are reported to its commissioner and a
multidisciplinary Settlement Council decides on the
next steps and (disciplinary) measures to be taken.
As part of NN Group’s risk framework, a detailed
quarterly report is provided to the NN Group
Management Board on (the effectiveness of
mitigating) compliance risks in the business units
and Group support functions, including Business
Conduct Risk, which covers bribery and corruption.
We have protocols and mechanisms in place for the
timely investigation of misconduct, including root
cause analysis.
Confirmed incidents of corruption or bribery
2024 2023
Convictions for corruption/
bribery (# of cases) 0 0
Amount of fines for
corruption/bribery (EUR
million) 0 0
Number of confirmed
incidents of corruption/
bribery (# of cases) 0 1
Throughout 2024, no reports on bribery or corruption
were received through either the Speak Up system
or Corporate Security and Investigations, so
no disciplinary measures (warning, reprimand,
termination of employment or instant dismissal) were
taken.
As there have been no cases of corruption or bribery
in 2024, NN Group has not needed to take any
additional mitigating actions.
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Annex
Definitions of material topics
This table includes the definitions of the material
sustainability matters identified in the DMA process.
These definitions are based on the list of ESRS and
made specific to NN Group.
Environmental topics Definition
Climate change adaptation Process of adjustment to actual and expected climate change and its impacts. Ways of how an organisation adjusts to current and
anticipated climate change-related physical and transitional risks, as well as how it contributes to the ability of societies and economies
to withstand impacts from climate change. This matter also covers an organisation’s strategy in relation to the transition to a low-carbon
economy and the impacts of that transition on workers and local communities.
Climate change mitigation Process of reducing GHG emissions and holding the increase in the global average temperature to well below 2 °C and pursuing efforts to
limit it to 1.5 °C above pre-industrial levels, as laid down in the Paris Agreement.
Nature (biodiversity and water) Water: the sum of effluents and water released into surface water or groundwater that is outside a company’s boundaries, or the
boundaries of a third party, over the course of the reporting period. The amount of water drawn into the boundaries of the undertaking or
facility, and used, over the course of the reporting period.
Factors that can directly affect biodiversity and lead to its decline. These drivers are typically human-induced changes that negatively
impact ecosystems and species that inhabit them. The human use or management of a natural resource that lies within a specific area,
that area having a specific purpose (such as residential, agricultural, recreational, industrial, etc.).
Sustainable repair (circular economy) A circular economy fosters a looped system where goods are reused, repaired, recycled or repurposed, as opposed to the traditional linear
economy’s ‘take-make-dispose’ approach. A circular economy includes the preferred option of repair as a solution to damages we cover
as an insurer with our products and services.
Social topics
NN workers’ secure and fair employment Secure employment: increasing the percentage of workforce with employment contracts (especially permanent contracts) and social
protection. This includes the freedom of expression, which is the right to seek, receive and impart information and ideas of your choice
without interference and regardless of frontiers.
Adequate wages: wages that provide for the satisfaction of the needs of the worker and his/her family in the light of national economic
social conditions.
Social dialogue, workers’ rights and collective agreements: extending social dialogue to more establishments and/or countries. This
includes the increasing percentage of own workers being covered by collective bargaining, negotiating collective bargaining agreements
over sustainability issues. This also includes privacy rights of NN Group employees, where these rights protect them from unlawful and
unnecessary surveillance.
NN workers’ well-being Extending work/life balance measures to a greater percentage of own workers and increasing the vitality and well-being of our people.
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Equal treatment and opportunities for all at NN Refers to a workforce that is representative and inclusive. This includes promoting gender equality and equal pay, increasing the presence
of women in the workforce and top management, reducing the wage gap, the employment and inclusion of persons with disabilities, as
well as increasing the representation of underrepresented groups in the workforce and top management to foster a diverse and inclusive
organisational culture.
Human capital development and attraction at NN Human capital can be broadly defined as the stock of knowledge, skills and other personal characteristics that people have that helps
them to be productive. This is gained by pursuing formal education (early childhood, formal school system, adult training programmes) but
also through informal and on-the-job learning and work experience. This is all investment in human capital.
The impact NN Group has on its own workforce by nurturing a culture that supports continuous learning and collaboration and investing
in personal and professional development. Also, the impact that attracting, retaining and developing the right talent, as well as fostering
employee satisfaction, has on NN Group and our ability to execute our business strategy. This includes reskilling our workforce towards
evolving ways of working and developing insurance business models.
Workers in the value chain (investments) Equal treatment and opportunities for all: within the value chain this means ensuring that every individual, regardless of their gender, race,
ethnicity, age, disability, sexual orientation, religion or any other characteristic, is given the same rights, responsibilities, and chances to
succeed, within the same job context. This principle is based on the concept of non-discrimination, which requires that no individual or
group is treated less favourably than another in similar situations.
Equal pay: The States Parties to the present Covenant, part of the International Covenant on Economic, Social and Cultural Rights,
recognises the right of everyone to the enjoyment of just and favourable conditions of work which ensure, in particular:
(a) Remuneration which provides all workers, as a minimum, with:
(i) fair wages and equal remuneration for work of equal value without distinction of any kind, in particular women being guaranteed
conditions of work not inferior to those enjoyed by men, with equal pay for equal work;
(ii) a decent living for themselves and their families in accordance with the provisions of the present Covenant;
(b) safe and healthy working conditions;
(c) equal opportunity for everyone to be promoted in their employment to an appropriate higher level, subject to no considerations other
than those of seniority and competence;
(d ) rest, leisure and reasonable limitation of working hours and periodic holidays with pay, as well as remuneration for public holidays.
Child labour: all forms of slavery or practices similar to slavery, such as the sale and trafficking of children, forced or compulsory
recruitment of children for use in armed conflict, procuring or offering of a child for illicit activities, work which is likely to harm the health,
safety or morals of children.
Forced and compulsory labour: all work or service which is exacted from any person under the threat of a penalty and for which the person
has not offered himself or herself voluntarily. Forced labour encompasses traditional practices such as vestiges of slavery or slave-like
practices, and various forms of debt bondage, as well as new forms of forced labour that have emerged in recent decades, such as human
trafficking, also called ‘modern slavery’.
Definitions of material topics continued
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Workers in the value chain (business partner) Secure and fair employment: the right of everyone to the enjoyment of just and favourable conditions of work which ensure, in particular:
fair wages and equal remuneration, a decent living for themselves and their families, safe and healthy working conditions, equal
opportunity for everyone to be promoted, rest, leisure and reasonable limitation of working hours and periodic holidays with pay.
Collective bargaining: everyone shall have the right to freedom of association with others, including the right to form and join trade unions
for the protection of their interests.
Community investment The impact of NN Group on the communities around us by investing our resources, expertise and networks to maximise positive change
in our communities, specifically around financial, mental and physical well-being (together with non-profit organisations and research
institutes).
Financial inclusion Financial inclusion of consumers and/or end-users means that individuals and businesses have access to useful and affordable financial
products and services that meet their needs: transactions, payments, savings, credit and insurance, delivered in a responsible and
sustainable way.
Clear and secure data Secure data: data privacy and security of end-user information call for more transparency:
1. No-one shall be subjected to arbitrary or unlawful interference with their privacy, family, home or correspondence, nor to unlawful
attacks on their honour and reputation.
2. Everyone has the right to the protection of the law against such interference or attacks.
Clear data: access to (quality) information, giving consumers transparency regarding the products and services they are obtaining so they
have the opportunity to make a well-informed decision.
Governance topics
Corporate culture Corporate culture expresses goals through values and beliefs. It guides the undertaking’s activities through shared assumptions and
group norms such as values or mission statements or a code of conduct.
Corruption and bribery Refers to unethical practices involving the misuse of power, influence, or resources for personal gain or advantage. It involves actions such
as offering, giving, receiving, or soliciting bribes, as well as engaging in fraudulent or dishonest activities that undermine the integrity and
fairness of business operations.
Definitions of material topics continued
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Climate change
1
Investments With our investment strategy on climate solutions related to energy efficiency
and renewable energy, such as renewable energy structure, we contribute to
universal access to affordable and clean energy by boosting clean energy
investments.
Sustainability Statement - Environment - Climate
Change
p. 142-143
With our Responsible Investment (RI) Framework policy, which also includes
exclusion criteria for fossil fuel activities, as a signatory of the Paris Aligned
Asset Owner (PAAO) and participation in the Paris Aligned Investment
Initiative (PAII), we are committed to aligning our portfolios with the
objectives of the Paris Agreement.
Sustainability Statement - Environment - Climate
Change
p. 138-139
Own operations
We contribute to this SDG by adopting strategies in our buildings and own
operations that reduce emissions and mitigate then negative effects on
climate change.
Sustainability Statement - Environment - Climate
Change
p. 136-138
Products and services
By considering climate change mitigation and adaptation as part of our
underwriting and product development we contribute to mitigating our
negative impacts and strengthen resilience and adaptative to climate-related
hazards.
Sustainability Statement – Environment - Climate
Change
p. 143-145
Nature
(biodiversity and water)
Investments We support the development of a holistic view of environmental topics and
aim to integrate nature-related considerations into our responsible
investment activities.
Sustainability Statement – Environment - Nature
p. 167-168
Sustainable repair
Products and services By advancing our sustainable repair practices we contribute to ensure
sustainable consumption by extending the life of products and encourage
reuse and repair of materials.
Sustainability Statement - Environment - Sustainable
repair
p.169
NN workers’ secure and fair
employment
Own operations By fostering social dialogue through the European Works Council (EWC) and
local works councils and negotiating Collective Labour Agreements (CLAs) we
contribute to decent work for all.
Sustainability Statement - Social - Own workforce
p. 187-188
NN workers’ well-being
Own operations By offering flexible employment opportunities and promote a healthy work/life
balance we contribute to achieve full and productive employment and decent
work for all.
Sustainability Statement - Social - Own workforce
p. 186-187
Equal treatment and opportunities
for all at NN
Own operations With our implementation of a Diversity, Equity & Inclusion strategy and policy
we directly contribute to the goal of ensuring women’s full and effective
participation and equal opportunities for managerial positions. In this strategy
we strive to be an inclusive employer and reduce inequalities for our
employees.
Sustainability Statement - Social - Own workforce
p. 183-185
Our contribution to the Sustainable Development Goals (SDGs)
Role SDG
Contribution
Chapter reference
2
Sustainability matter
1
Concerns both our contribution to climate change mitigation as well as adaptation.
2
In these chapters more information can be found on the impacts, risks and opportunities associated with our material sustainability matters.
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Human Capital Development and
attraction at NN
Own operations By offering upskilling programs in areas like data, analytics and AI we prepare
employees for future technological advances and contribute to higher levels of
economic productivity through diversification, technological upgrading, and
innovation.
Sustainability Statement – Social – Own workforce
p. 185-186
Workers in the value chain
Investments With our Responsible Investment (RI) framework policy we contribute to SDG
5, 8 and 10 we try to mitigate our negative impacts, with our investments on
workers in the value chain by ensuring that investments align with
international standards.
Sustainability Statement – Social – Workers in the
value chain
p. 195-196
Business partners
With our Supplier Code of Conduct and Sustainable Procurement Statement
we contribute to SDG 8 and 10 by trying to mitigate our negative impact on
workers in the value chain by requiring suppliers to adhere to fair labour
practices and disclose measures to prevent modern slavery and human
trafficking.
Sustainability Statement – Social – Workers in the
value chain
p. 195-196
Community investment
Own operations With our community investment activities, we aim to contribute to SDG 1 and
3 by focusing on people’s financial, physical and/or mental well-being.
Sustainability Statement – Social – Community
Investment
p. 199-202
Financial inclusion
Products and services With our Product Policy we aim to reduce our negative impact and ensure we
offer products and services that are easy to understand and use to ensure
access to financial services for all.
We support our customers who encounter or are at risk of encountering
financial distress.
Sustainability Statement – Social – Consumers and
end-uers
p. 203-204
Clear and secure data
Products and services With our Data Protection Policy we aim to adhere to the General Data
Protection Regulation (GDPR) principles to safeguarding privacy and security
of customer information and mitigate misuse of customer data fostering
secure and stable economic environment and a secure and resilient
infrastructure.
Sustainability Statement – Social – Consumers and
end-users
p. 204
Corporate culture
Own operations With our Code of Conduct and awareness initiatives we support and promote
our NN values and beliefs to create a safe, healthy, and productive workplace.
About NN - Our values and behaviours
p. 7-8
Corruption and bribery
Own operations
With the establishment of policies and processes such as Outside Positions
and Interests Policy and the Gifts, Events and Meals Policy alongside
conducting periodic risk assessments we contribute to reduce corruption and
bribery in all forms.
Governance – Our Code of Conduct and other policies
p. 115-118
Sustainability Statement – Governance – Prevention
and detection of corruption and bribery
p. 209
Our contribution to the SDGs (continued)
Role SDG
Contribution
Chapter reference
1
Sustainability matter
1
In these chapters more information can be found on the impacts, risks and opportunities associated with our material sustainability matters.
NN Group N.V. Annual Report 2024 | 215
Annex
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
List of policies
1
Policy IRO Objective Scope
Policy implementation, accountability and
monitoring
Third-party standards or initiatives
NN Group commits to through
implementation
Code of Conduct including
Manager Annex
Potential negative and actual positive impact of our
corporate culture on own operations.
Potential negative impact of corruption and bribery in
own operations.
To outline our views and expectations related to how
NN Group interacts, handles information and
(personal) data, deals with conflicts of interest, fraud,
financial economic crime, and competition law, uses
equipment and the Internet, reports breaches, and
addresses breaches. The Manager Annex explains NN
Group’s expectations on these topics for managers
and board members.
All employees employed by NN Group under an
employment agreement and anyone representing NN
Group in any capacity. The Manager Annex applies to
all managers and board members.
The Chief Compliance Officer is accountable for
implementing this policy. The policy is reviewed once
a year. If the review indicates that an update is
necessary, the policy is revised accordingly.
Additionally every employee must formally
acknowledge every year that they have read and
agree to follow the NN Code of Conduct and
managers and board members acknowledge yearly
that they have read and agree to follow the Manager
Annex. The policy is made available on our intranet
and our external website.
DNB Good Practices SIRA obligation
The Dutch Corporate Governance Code
Directive 2009/138/EC, Solvency II
Directive
Financial Supervision Act (Wet op het
financieel toezicht, Wft)
Data Protection Policy Potential negative impact of products and services
on clear and secure data.
To mitigate the risks associated with non-
compliance. To support this aim, the policy provides a
clear statement on our compliance with (European)
data protection regulations, and outlines the main
consequential obligations for the management and
employees of NN Group and its majority-owned
entities, who are subject to the General Data
Protection Regulation (GDPR).
Operations of NN Group in the EU that process
personal data in the context of their business
activities. It also covers NN entities that process the
personal data of data subjects within the EU,
regardless of whether these entities are established
in the EU, provided that the processing activities are
related to the offering of goods and services or the
monitoring of their behaviour.
The Head of Legal Holding Team is accountable for
implementing this policy. The policy is reviewed at
least once every two years. If the review indicates
that an update is necessary, the policy is revised
accordingly. The policy is made available on our
intranet.
The GDPR principles, next to (local) law
and guidance from (data protection)
regulators.
Diversity & Inclusion
Policy
Potential positive and potential negative impact of
our own operations on equal treatment and
opportunities for all.
To set forth our approach to reaching a diverse and
inclusive composition of NN Group’s Executive Board,
Management Board, Supervisory Board and senior
management.
NN Group’s Executive Board, Management Board,
Supervisory Board and Senior Management Group.
The Chief People, Communications, and
Sustainability Officer is accountable for the
implementing this policy. The monitoring process is
described in the Social chapter. The policy is
disclosed on the NN Group website.
Engagement Policy for
Proprietary Assets
Potential positive and potential negative impact of
our investments on climate change mitigation.
Potential negative impact of our investments on
workers in the value chain, (secure and fair
employment, equal treatment and opportunities for
all, and issues related to child labour and forced
labour).
To set out the objectives, overall approach and
governance of engagement, which is an integral part
of the investment process of NN Group’s Proprietary
Assets.
All proprietary investments and mandates for the
proprietary investment portfolios of NN Group.
The Responsible Investment Committee is
responsible for implementing this policy on behalf of
the Management Board. The policy is reviewed once a
year. If the review indicates that an update is
necessary, the policy is revised accordingly. The
policy is made available on our external website.
1
In this list of policies NN Group refers to all entities within NN Group, which is consistent with the scope of the consolidated annual accounts.
NN Group N.V. Annual Report 2024 | 216
Annex
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Policy IRO Objective Scope
Policy implementation, accountability and
monitoring
Third-party standards or initiatives
NN Group commits to through
implementation
Forbearance Policy Potential negative impact of products and services
on financial inclusion.
To provide the framework for determining
‘forbearance’. Forbearance measures are
concessions that may be granted by NN Bank to
minimise the likelihood of a client defaulting on one
or more of their loan commitments. These may be
granted if a client is experiencing, or is about to
experience, difficulties in meeting their financial
commitments. Such concessions are also known as
forbearance measures. The policy outlines which
operational manuals, standards and procedures are
impacted by these measures; it aims to set down
how NN Bank interprets and applies Annex V
Commission Implementing Regulation (EU) No.
680/2014, of April 16 2014.
NN Bank’s consolidated assets, including those
managed and/or administered by third parties, with
the exception of asset types to which no forbearance
measures are granted.
Policy is governed by the NN Bank Credit Risk
Committee under the responsibility of the Chief Risk
Officer (CRO). The policy must be reviewed and
updated at least annually and is made available on
our intranet.
NN Bank’s interpretation and application
of the EU’s Annex V Commission
Implementing Regulation No. 680/2014
of April 1 2014 as amended by the EU’s
Commission Implementing Regulation,
2015/2274, in which forbearance is
described in detail.
The policy also outlines NN Bank’s
interpretation and application of EBA’s
Final Guidelines.
(EBA/GL/2018/06) on managing non-
performing and forborne exposures.
Gifts, Events and
Business meals Policy
Potential negative impact of corruption and bribery in
own operations.
To support NN Group and its underlying entities in
mitigating the risk of bribery and corruption and
conflicts of interest related to Gifts, Events/
Entertainment and Business meals Entertainment.
Employees of NN Group business units outside the
Netherlands. under an employment agreement.
The Chief Compliance Officer is accountable for
implementing this policy. The policy is reviewed
annually. If the review indicates that an update is
necessary, the policy is revised accordingly. The
policy is made available on our intranet.
Financial Supervision Act (Wet op het
financieel toezicht, Wft)
- Wft part 3
- Wft part 4
- Besluit prudentiële regels Wft
UK Bribery Act
US Foreign Corrupt Practices Act
De Nederlandsche Bank Good Practices’
Systematic Integrity Risk Analysis
obligation.
Gifts, Events and
Business meals Standard
for NN Netherlands
including Group Head
Office
Potential negative impact of corruption and bribery in
own operations.
To support NN Group and its underlying entities in
mitigating the risk of bribery and corruption and
conflicts of interest related to Gifts, Events/
Entertainment and Business meals/Entertainment.
All employees employed by NN Group under an
employment agreement in the Netherlands, Group
Head Office and Group Support Functions.
The Chief Compliance Officer is accountable for
implementing this standard, which is reviewed
annually. If the review indicates that an update is
necessary, the standard is revised accordingly. The
standard is available on our intranet.
Financial Supervision Act (Wet op het
financieel toezicht, Wft)
- Wft part 3
- Wft part 4
- Besluit prudentiële regels Wft
UK Bribery Act
US Foreign Corrupt Practices Act
De Nederlandsche Bank Good Practices’
Systematic Integrity Risk Analysis
obligation.
Global Business Travel
Guideline
Potential negative impact of our own operations on
climate change mitigation.
To set out our expectations and guidelines for
business travel outside the Netherlands.
All employees under contract with NN Group in the
Netherlands, which may include freelancers and
temporary workers. The policy reflects the minimum
standard to be upheld in relation to employees of NN
Group outside the Netherlands, as far as is possible
and reasonable.
The Chief People, Communications, and
Sustainability Officer is responsible for implementing
this policy. The policy is reviewed at least once a year.
If the review indicates that an update is necessary,
the policy is revised accordingly. There is currently no
monitoring process in place for this policy. The policy
is made available on our intranet.
1
In this list of policies NN Group refers to all entities within NN Group, which is consistent with the scope of the consolidated annual accounts.
List of policies
1
continued
NN Group N.V. Annual Report 2024 | 217
Annex
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Policy IRO Objective Scope
Policy implementation, accountability and
monitoring
Third-party standards or initiatives
NN Group commits to through
implementation
Health & Safety, Sick
Leave and Vitality Policy
Potential positive impact of own operations on
employee well-being.
To outline our approach if an employee becomes sick
or occupationally disabled.
All employees employed by NN Group under an
employment agreement in the Netherlands.
The Chief People, Communications, and
Sustainability Officer is accountable for
implementing this policy. Monitoring processes are in
place to monitor this policy. The policy is made
available on our intranet.
Human Resources
Framework Standard
Potential positive impact of our own operations on
secure and fair employment.
Potential positive impact of our own operations on
employee well-being.
Potential positive and potential negative impact of
our own operations on equal treatment and
opportunities for all.
Potential positive impact of our own operations on
human capital development.
To summarise our core HR principles, and what they
mean in practice. It supports the objective of all of
our employees having the same opportunities
regardless of where they work in our organisation.
The document describes common standards for
diversity, talent, employee development and
performance.
All employees employed by NN Group under an
employment agreement.
The Chief People, Communications, and
Sustainability Officer is accountable for
implementing this policy. The policy is reviewed at
least once every two years. If the review indicates
that an update is necessary, the policy is revised
accordingly. The policy is made available on our
intranet.
- Universal Declaration of Human Rights
- United Nations’ Global Compact
Incident Management
Standard
Potential negative impact of products and services
on clear and secure data.
To limit the impact of incidents and near misses by
ensuring an adequate and timely response. The
policy aims to create a feedback loop so that learning
from incidents strengthens the Risk Management
Framework (RMF) and reduces the occurance of such
incidents in the future. Additionally, it enables
disclosure to regulatory bodies if appropriate or
required.
All processes including supporting technology and
other resources within NN Group. In the event of a
conflict with local law, the latter prevails.
The CRO is accountable for implementing this policy.
The policy is reviewed at least once every two years.
If the review indicates that an update is necessary,
the policy is revised accordingly. The policy is made
available on our intranet.
International
Whistleblower Policy
Potential negative and potential positive impact of
own operations on equal treatment and opportunities
for all.
Potential negative impact of our business partners on
workers in the value chain (secure and fair
employment, equal treatment and opportunities for
all).
Potential negative impact of the corporate culture of
our own operations.
Potential negative impact of corruption and bribery in
own operations.
To provide requirements for the protection of
whistleblowers, to foster an open culture, and to
enable whistleblowers to speak up and report
(suspected) wrongdoing by or within NN Group.
Employees of NN Group business units outside the
Netherlands who acquire information about concerns
and/or breaches in a work-related context with NN.
The Chief Compliance Officer is accountable for
implementing this policy. The policy is reviewed at
least once every two years. If the review indicates
that an update is necessary, the policy is revised
accordingly. The policy is made available on our
external website.
- Directive (EU) 2019/1937, the EU
Whistleblower Protection Directive
- The Whistleblowers Protection Act (Wet
bescherming klokkenluiders)
Investigation Standard Potential negative impact of corruption and bribery in
our own operations.
To provide a regulation concerning the reporting, the
investigation and the settlement of incidents within
NN Group in a consistent, transparent and
professional manner.
Compliance with this standard is mandatory for NN
Group.
The Head of Corporate Security and Investigations is
accountable for implementing this policy. The policy
is reviewed annually. If the review indicates that an
update is necessary, the policy is revised accordingly.
The policy is made available on our intranet.
1
In this list of policies NN Group refers to all entities within NN Group, which is consistent with the scope of the consolidated annual accounts.
List of policies
1
continued
NN Group N.V. Annual Report 2024 | 218
Annex
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Policy IRO Objective Scope
Policy implementation, accountability and
monitoring
Third-party standards or initiatives
NN Group commits to through
implementation
NN Artificial Intelligence
(AI) Framework
Potential negative impact of products and services
on clear and secure data.
To safeguard the ethical, transparent and responsible
use and development of AI technologies.
All AI systems and AI models that are part of AI
systems of NN Group.
The Head of Holding team Group Legal is the owner
of the policy. For each entity, the business unit
director is accountable for the implementation of the
policy. The policy is reviewed at least once every two
years. If the review indicates that an update is
necessary, the policy is revised accordingly. The
policy has been updated this year and will be updated
in the upcoming year to be compliant with applicable
obligations of the AI Act. The policy is made available
on our intranet.
NN statement of Living
our Values
2
Potential positive impact of our own operations on
secure and fair employment.
Potential negative and actual positive impact of the
corporate culture of our own operations.
Potential positive impact of our own operations on
secure and fair employment.
Potential negative impact and actual positive impact
of our own operations on corporate culture.
Every NN Group employee, including those of
subsidiaries and anyone representing NN in any
capacity.
The Head of Corporate Culture & Affairs is
accountable for monitoring the effectiveness of policy
implementation, as well as conducting reviews and
proposing improvements. Each year, the
Management Board receives a report detailing
insights into the Living our Values programme,
highlighting areas of attention and concern and
recommendations for improvements. The report is
approved by the Management Board, who is also
responsible for incorporating and maintaining the
values within the company and its
affiliated enterprises.
- The Bankers Oath for the Financial Sector
- Dutch Corporate Governance Code
NN Terms & Conditions Potential negative impact of our business partners on
workers in the value chain (secure and fair
employment, equal treatment and opportunities for
all).
To establish in a contractual manner the
commitments outlined in the Supplier Code of
Conduct and the Sustainable Procurement
Statement. Includes the most important standards in
our approach to the environment and human rights,
which our suppliers agree to when doing business
with us.
Agreements between NN Group and its suppliers,
and all entities under the managerial control of
NN Group.
The Chief Procurement Officer is accountable for
creating and implementing this policy. The policy is
reviewed at least once every two years, in
cooperation with Group Legal. If the review indicates
that an update is necessary, the policy is revised
accordingly. The policy is made available both on our
intranet and external website.
- The UN’s Guiding Principles on Business
and Human Rights
- The OECD’s Guidelines for Multinational
Enterprises.
Oil & Gas Policy Potential positive and potential negative impact of
our investments on climate change mitigation.
To set out the objectives, governance and minimum
requirements for investments in oil and gas activities.
All assets managed by majority-owned NN Group
businesses, and businesses under NN Group’s
management control.
The Responsible Investment Committee is
responsible for implementing this policy. The policy is
reviewed at least once every two years. If the review
indicates that an update is necessary, the policy is
revised accordingly. The policy is made available on
our intranet.
Strategic Framework for Paris Alignment
1
In this list of policies NN Group refers to all entities within NN Group, which is consistent with the scope of the consolidated annual accounts.
2
This statement has been included in the policy table for completeness. However, it should be noted that it does not meet all the MDR-Ps of ESRS 2.
List of policies
1
continued
NN Group N.V. Annual Report 2024 | 219
Annex
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Policy IRO Objective Scope
Policy implementation, accountability and
monitoring
Third-party standards or initiatives
NN Group commits to through
implementation
Outside Positions and
Outside Interests
Standard
Potential negative impact of corruption and bribery in
our own operations.
To support NN Group and its underlying entities in
mitigating the risks of bribery and corruption and
conflict of interests related to outside positions and
outside interests.
All employees employed by NN Group under an
employment agreement.
The Chief Compliance Officer is accountable for
implementing this policy. The policy is reviewed at
annually. If the review indicates that an update is
necessary, the policy is revised accordingly. The
policy is made available on our intranet.
Financial Supervision Act (Wet op het
financieel toezicht, Wft)
- Wft part 3
- Wft part 4
- Besluit prudentiële regels Wft
Mededingingswet
DNB Good Practices SIRA obligation
The Dutch Corporate Governance Code
Procurement and
Outsourcing Policy
Potential negative impact of our business partners on
workers in the value chain (secure and fair
employment, equal treatment and opportunities for
all).
To describe the objectives and requirements around
managing the risks related to procuring goods and
services and outsourcing functions or activities.
Agreements between NN Group and its suppliers,
and to all entities under the managerial control of NN
Group.
The agreements that are not in scope of this policy
are:
a) intra-group outsourcing;
b) the order-to-pay process; and
c) all other arrangements for categories not listed
above, such as reinsurance, mandated brokers,
mandatory memberships, investment and asset
management, fund management, banking services
and financial securities, and Sales and Purchase
Agreements related to mergers and acquisitions.
The Chief Procurement Officer is accountable for
creating and implementing this policy. The policy is
reviewed at least once every year. If the review
indicates that an update is necessary, the policy is
revised accordingly. The policy is made available on
our intranet.
Product Policy/PARP Potential negative impact of products and services
on financial inclusion.
To mitigate product risk through effective design,
underwriting and claims management, as well as the
adequate pricing of all products, and also to
safeguard their suitability for customers. The Product
Approval and Review Process (PARP) aims to
safeguard the effective management of products
throughout their lifetime.
All NN Group business units carrying product risk. The process of creating the policy runs via the policy
owners in NN Group Legal, Risk and Compliance. It is
reviewed by representatives from the business units
and finally approved by the Management Board. NN
Group Legal, Risk and Compliance perform product
risk oversight that covers the monitoring of those
products that require central approval, beyond
business unit approval. The policy is reviewed at
least once every two years. If the review indicates
that an update is necessary, the policy is revised
accordingly. The policy is made available on our
intranet.
The EU’s Insurance Distribution Directive
(IDD, EU 2016/97), including product
oversight and governance requirements
(POG)
Recruitment Policy and
Policy for Hiring External
Staff
Potential positive and potential negative impact of
our own operations on equal treatment and
opportunities for all.
To ensure a fair and consistent recruitment process
by providing clear guidelines and procedures for
managers, recruiters and candidates, outlining the
responsibilities of HR and hiring managers, and
detailing the use of recruitment tools.
NN Group business units where employees are
employed under an employment agreement with NN
Personeel B.V.
The Chief People, Communications, and
Sustainability Officer is accountable for implementing
this policy. The policy is updated when there are
changes in the policy or legislation. It is made
available on our intranet.
1
In this list of policies NN Group refers to all entities within NN Group, which is consistent with the scope of the consolidated annual accounts.
List of policies
1
continued
NN Group N.V. Annual Report 2024 | 220
Annex
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Policy IRO Objective Scope
Policy implementation, accountability and
monitoring
Third-party standards or initiatives
NN Group commits to through
implementation
Remuneration Framework
Standard
Potential positive impact of our own operations on
secure and fair employment.
Potential positive and potential negative impact of
our own operations on equal treatment and
opportunities for all.
To provide a clear framework for remuneration of NN
Group employees.
All employees employed by NN Group under an
employment agreement.
The Executive Board is accountable for implementing
this policy. The policy is reviewed at least once every
two years. If the review indicates that an update is
necessary, the policy is revised accordingly. It is
made available on our intranet.
Responsible Insurance
Underwriting Framework
Policy
Potential positive and potential negative impact of
our products and services on climate change
mitigation.
Potential negative impact of our products and
services on financial inclusion.
To provide direction on the integration of
sustainability matters into insurance underwriting
and product development.
Dutch insurance activities for retail and commercial
lines of Nationale-Nederlanden Schadeverzekering
Maatschappij N.V., ABN AMRO Schadeverzekering
N.V., Nationale-Nederlanden Levensverzekering
Maatschappij N.V. and NN Re (Netherlands) N.V.
The Responsible Insurance Underwriting Committee
is responsible for implementing this policy on behalf
of the Management Board. The policy is reviewed
annually. If the review indicates that an update is
necessary, the policy is revised accordingly. It is
made available on our external website.
Responsible Investment
Framework Policy
Potential positive and potential negative impact of
our investments on climate change mitigation.
Financial risk to our investments because of climate
change.
Financial opportunity of investments in climate
solutions.
Actual positive impact of our investments on climate
change adaptation.
Potential negative impact of our investments on
nature (biodiversity and water).
Potential negative impact of our investments on
workers in the value chain, (secure and fair
employment, equal treatment and opportunities for
all, and child labour and forced labour).
To support subsidiaries of NN Group, the NN Group
Investment Office,and other relevant NN Group
functions in incorporating Environmental, Social and
Governance (ESG) impacts, risks and opportunities
into their investment processes when feasible and
possible.
Every asset category where it is possible and feasible
to consider ESG factors.
The Responsible Investment Committee is
responsible for implementing this policy on behalf of
the Management Board. The policy is reviewed at
least once every two years. If the review indicates
that an update is necessary, the policy is revised
accordingly. It is made available on our external
website.
- Strategic Framework for Paris Alignment
- ICMA’s Green Bond Principles
- UN Global Compact
- UN Guiding Principles on Business and
Human Rights
- OECD Guidelines for Multinational
Enterprises
Sponsorship and
Charitable Donations
Policy
Actual positive impact of our own operations on
community investment.
To provide guidance for, and maximise the benefits
of, sponsorships and community investment,
including charitable donations. The policy aims to
prevent and manage potential reputational risks and
the inherent risks of corruption and conflict of
interest associated with these activities. It also
introduces key themes that affect the strength,
visibility and distinct positioning of our brand and
corporate citizen profile.
NN Group. The Chief People Communications, and Sustainability
Officer is responsible for implementing this policy.
The policy is reviewed at least once every two years.
If the review indicates that an update is necessary,
the policy is revised accordingly. It is made available
on our intranet.
The Business for Social Impact (B4SI)
Framework
Stakeholder Engagement
Policy
This policy is not related to a specific IRO but is
essential for adequately integrating the interests of
our stakeholders across our value chain.
To outline the principles and approach regarding our
relations with stakeholders and how we balance their
interests.
NN Group’s material activities. The Chief People, Communications, and
Sustainability Officer is accountable for implementing
this policy. Currently, there is no official monitoring
process in place, as we are still working on extending
it. It is made available on our external website.
1
In this list of policies NN Group refers to all entities within NN Group, which is consistent with the scope of the consolidated annual accounts.
List of policies
1
continued
NN Group N.V. Annual Report 2024 | 221
Annex
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Policy IRO Objective Scope
Policy implementation, accountability and
monitoring
Third-party standards or initiatives
NN Group commits to through
implementation
Supplier Code of Conduct Potential negative impact of our business partners on
workers in the value chain (secure and fair
employment, equal treatment and opportunities for
all).
To outline our expectations of the sustainability
policies and practices of our suppliers and sub-
contractors.
Agreements between NN Group and those suppliers
who went through our Supplier Qualification process
(with a spend above EUR 100k) or that signed the
NNTC24. The policy applies to NN Group.
The Chief Procurement Officer is accountable for
implementing this policy. The policy is reviewed at
least once every two years. If the review indicates
that an update is necessary, the policy is revised
accordingly. It is made available on our external
website.
- The Strategic Framework for Paris
Alignment
- UN’s Guiding Principles on Business and
Human Rights
- The OECD’s Guidelines for Multinational
Enterprises
Sustainable Renovation
Policy
Potential negative impact of our own operations on
climate change mitigation.
To set out objectives to realise sustainable
renovation for all offices buildings in the Netherlands
and reach net-zero operations.
All office buildings in locations serviced by Facility
Management in the Netherlands.
Head of Facility Management (FM) is responsible for
implementing this policy. The policy is monitored
throughout the year as it is actively used for all
renovations. Updates will take place if required. This
policy is made available by FM on our intranet.
- Dutch Green Building Council (DGBC)
- Milieukostenindicator (MKI)
- Zero Waste
Sustainable Repair Policy Potential positive impact of the sustainable repair of
our products and services on the circular economy.
To define our approach to advancing sustainable
repair practices and to facilitate the further
development of a sustainable repair network in the
Netherlands within the property segment of Non-life.
Retail Schade & Zorg (RSZ) for the domain ‘property’. The CEO NN Schade & Inkomen is accountable for
implementing this policy. The policy will be reviewed
each year and the inclusion of other business lines
will be discussed.
The Dutch Association of Insurers’
(Verbond van Verzekeraars) Manifesto
Sustainable Damage Repair
Voting Policy for
Proprietary Assets
Potential positive and potential negative impact of
our investments on climate change mitigation.
Potential negative impact of our investments on
workers in the value chain, (secure and fair
employment, equal treatment and opportunities for
all, and issues related to child labour and forced
labour).
To describe the framework that NN Group uses when
exercising voting rights attached to its own assets at
shareholder meetings or via proxy voting.
All proprietary investments and mandates for the
proprietary investment portfolios of NN Group.
The Responsible Investment Committee is
responsible for implementing this policy on behalf of
the Management Board. The policy is reviewed once a
year. If the review indicates that an update is
necessary, the policy is revised accordingly. It is
made available on our external website.
Whistleblower Standard
for Dutch Business Units
and Head Office of NN
Group
Potential negative and potential positive impact of
our own operations on equal treatment and
opportunities for all.
Potential negative impact of our business partners on
workers in the value chain (secure and fair
employment, equal treatment and opportunities for
all).
Potential negative impact of the corporate culture of
our own operations.
Potential negative impact of corruption and bribery in
our own operations.
To provide requirements aiming to ensure the
protection of whistleblowers, foster an open culture,
and enable whistleblowers to speak up and report
(suspected) wrongdoing by or within NN Group.
Employees of NN Group or reporting persons in the
Netherlands who acquire information about concerns
and/or breaches in a work-related context with NN
Group.
The Chief Compliance Officer is accountable for
implementing this standard. The standard is
reviewed annually. If the review indicates that an
update is necessary, the standard is revised
accordingly. It is made available on our external
website.
Directive (EU) 2019/1937, the
Whistleblower Protection Directive.
The Whistleblowers Protection Act (Wet
bescherming klokkenluiders).
1
In this list of policies NN Group refers to all entities within NN Group, which is consistent with the scope of the consolidated annual accounts.
List of policies
1
continued
NN Group N.V. Annual Report 2024 | 222
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Disclosure Description Reference Page(s) Explanation
General disclosures
BP-1 General basis for preparation of the Sustainability
Statement
Sustainability Statement - General disclosures - General basis for preparation
Sustainability Statement - General disclosures - Our value chain
p. 122
p. 123
We do not report on paragraph 5(d) and
5(e) as they are not applicable to NN
Group.
BP-2 Disclosures in relation to specific circumstances Governance - Remuneration Report - Remuneration in general
Governance - Remuneration Report - Remuneration of the executive board - Pay ratio
Sustainability statement - General disclosures - General basis for preparation
Sustainability statement - Environment - Climate change - Progress
Sustainability statement - Environment - Sustainable repair
Sustainability statement - Social - Own workforce
Sustainability statement - Social - Community investment
Sustainability statement - Annex - Reference table
Appendix - GHG emissions
p. 106-107
p. 113
p. 122
p. 145-158
p. 169
p. 190-194
p. 201-202
p. 222-232
p. 402-404
The information included in the
appendix relates to non-material
information.
GOV-1 The role of the administrative, management and
supervisory bodies
Governance - Corporate governance - Executive Board
Governance - Corporate governance - Management Board
Governance - Corporate governance - Supervisory Board
Governance - Corporate governance - Self-assessment and education programme
Governance - Corporate governance - Composition of NN Group’s Executive, Management and
Supervisory Boards and senior management
Governance - Corporate governance - Sustainability governance
Governance - Report of the Supervisory Board
p. 66-67
p. 67-69
p. 70-72
p. 72
p. 73
p. 77-80
p. 95-97, p. 102
GOV-1
paragraph 21 (d)
Board's gender diversity Governance - Corporate governance - Composition of NN Group’s Executive, Management and
Supervisory Boards and senior management
p. 73
GOV-1
paragraph 21 (e)
Percentage of board members who are
independent
Governance - Corporate governance - Profile of the Supervisory Board p. 71
GOV-2 Information provided to, and sustainability matters
addressed by, the undertaking’s administrative,
management and supervisory bodies
Governance - Corporate governance - Sustainability governance p. 77-80
GOV-3 Integration of sustainability-related performance in
incentive schemes
Governance - Remuneration Report p. 107-114
GOV-4 Statement on due diligence Sustainability Statement - General disclosures - Due diligence process references p. 132 This covers GOV-4 paragraph 30.
GOV-5 Risk management and internal controls over
sustainability reporting
Sustainability Statement - General disclosures - Risk management and internal controls p. 133
Reference table
The table below provides references to the sections in the Annual Report where the information required by the European Sustainability Reporting Standards, published by the European Commission on 31 July 2023, can be found.
It also includes data points required by other sustainability regulations and phase-in requirements. If whole topical chapters are not material, they are not shown in the overview below.
NN Group N.V. Annual Report 2024 | 223
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Disclosure Description Reference Page(s) Explanation
SBM-1 Strategy, business model and value chain Our strategy and business - Progress on our commitments
Our strategy and business - Value creation model - How we create value
Sustainability Statement - General disclosures - Integrating sustainability into our strategy
Sustainability Statement - General disclosures - Our value chain
p. 26-30
p. 33-34
p. 122-123
p. 124
SBM-1
paragraph 40(d)i-iv
Involvement in activities related to fossil fuel activities,
chemical production, controversial weapons, cultivation
and production of tobacco
Our strategy and business - Progress on our commitments - Responsible insurance underwriting p. 28 We currently have limited insight into
our involvement in chemical production,
as this is not specifically addressed in
our RIU and RI policy. Consequently, we
do not provide specific disclosures on
this topic.
SBM-2 Interests and views of stakeholders Our strategy and business - Stakeholder engagement and international commitments p. 35-38
SBM-3 Material impacts, risks and opportunities and their
interaction with strategy and business model
About NN Group - Determining our material matters - Outcome DMA
Managing our risks - Step 2: risk assessment - Strategic Risk Assessment (SRA) and Own Risk
and Solvency Assessment (ORSA)
Sustainability statement - General Disclosures - Our material sustainability matters
Sustainability statement - General Disclosures - Connecting our sustainability matters to our
strategy and business model
Sustainability statement - Environment - Introduction
Sustainability statement - Environment - Climate Change - Anticipated financial effects
Sustainability statement - Social - Introduction
Sustainability statement - Governance - Introduction
p. 20-21
p. 57
p. 125
p. 126
p. 135
p. 159-166
p. 180
p. 208
IRO-1 Description of the processes to identify and
assess material impacts, risks and opportunities
About NN Group - Determining our material matters - Our approach
About NN Group - Determining our material matters - Our roles in the value chain
Sustainability statement - General Disclosures - Our approach to the DMA
Sustainability statement - General Disclosures - Topical sustainability matters
p. 20
p. 20
p. 127-129
p. 130-131
IRO-2 Disclosure requirements in ESRS covered by the
undertaking’s sustainability statement
Sustainability statement - Annex - Reference table p. 222-232
MDR-P Policies adopted to manage material sustainability
matters
Sustainability Statement - Annex - List of policies p. 215-221
Reference table continued
NN Group N.V. Annual Report 2024 | 224
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Disclosure Description Reference Page(s) Explanation
MDR-A Actions and resources in relation to material
sustainability matters
About NN - Our values and behaviours
Governance - Our Code of Conduct and other policies
Sustainability statement - Environment - Climate change - Approach - Own operations
Sustainability statement - Environment - Climate change - Approach - Investments
Sustainability statement - Environment - Climate change - Approach - Insurance underwriting
Sustainability statement - Environment - Nature (biodiversity and water)
Sustainability statement - Environment - Sustainable repair
Sustainability statement - Social - Own workforce
Sustainability statement - Social - Workers in the value chain
Sustainability statement - Social - Community investment
Sustainability statement - Social - Consumers and end-users
p. 7-8
p. 115-118
p. 137-138
p. 140
p. 143-144
p. 167-168
p. 169
p. 183-189
p. 196-198
p. 202
p. 206
MDR-M Metrics in relation to material sustainability matters About NN - Our values and behaviours
Governance - Our Code of Conduct and other policies
Sustainability statement - Environment - Climate change - Approach - Own operations
Sustainability statement - Environment - Climate change - Progress - Own operations
Sustainability statement - Environment - Climate change - Progress - Investments
Sustainability statement - Environment - Climate change - Progress - Insurance underwriting
Sustainability statement - Environment - Sustainable repair
Sustainability statement - Social - Own workforce
Sustainability statement - Social - Community investment
Sustainability statement - Governance - Prevention and detection of corruption and bribery
processes
p. 8
p. 117
p. 138
p. 146
p. 148, p. 151-154
p. 156
p. 169
p. 190-194
p. 201
p. 209
MDR-T Tracking effectiveness of policies and actions through
targets
About NN - Our values and behaviours
Governance - Corporate Governance - Targets on sustainability matters
Sustainability statement - Environment - Climate change - Approach - Own operations
Sustainability statement - Environment - Climate change - Approach - Investments
Sustainability statement - Environment - Climate change - Approach - Insurance underwriting
Sustainability statement - Environment - Nature (biodiversity and water)
Sustainability statement - Environment - Sustainable repair
Sustainability statement - Social - Own workforce
Sustainability statement - Social - Workers in the value chain
Sustainability statement - Social - Community investment
Sustainability statement - Social - Consumers and end-users
p. 8
p. 79
p. 138
p. 140-143
p. 144-145
p. 168
p. 169
p. 188-189
p. 198
p. 200-201
p. 206
ESD Metrics related to the Supervisory Board Governance - Report of the Supervisory Board - Profile of the Supervisory Board p. 95
ESD Our contribution to the SDGs Sustainability statement - General disclosures - Our contribution to the SDGs
Sustainability statement - Annex - Our contribution to the SDGs
p. 123
p. 213-214
Reference table continued
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Disclosure Description Reference Page(s) Explanation
ESRS E1 – Climate change
NA EU Taxonomy information Sustainability Statement - Environment - EU Taxonomy
Sustainability Statement - Annex - EU Taxonomy Disclosure Tables
p. 170-176
p. 233-242
GOV-3 Integration of sustainability-related performance in
incentive schemes
Governance - Remuneration Report p. 111
E1-1 Transition plan for climate change mitigation Sustainability Statement - Environment - Climate change - Approach - Own operations
Sustainability Statement - Environment - Climate change - Approach - Investments
Sustainability Statement - Environment - Climate change - Approach - Insurance underwriting
p. 136-137
p. 138-139
p. 143
This covers E1-1 paragraph 14.
E1-1
paragraph 16 (g)
Undertakings excluded from Paris-aligned benchmarks Sustainability Statement - Environment - Climate change - Approach - Own operations p. 136
SBM-3 Material impacts, risks and
opportunities and their interaction with strategy and
business model
Managing our risks - Step 2: Risk assessment - Strategic Risk Assessment (SRA) and Own Risk
and Solvency Assessment (ORSA)
Managing our risks - Step 2: Risk assessment - Strategic asset allocation
Sustainability statement - Environment - Introduction
Sustainability statement - Environment - Anticipated financial effects
p. 57
p. 58
p. 135
p. 159-166
IRO-1 Description of the processes to identify and
assess material climate-related impacts, risks and
opportunities
Sustainability Statement - General Disclosures - Topical sustainability matters p. 130
E1-2 Policies related to climate change mitigation and
adaptation
Sustainability Statement - Environment - Climate change - Approach - Own operations
Sustainability Statement - Environment - Climate change - Approach - Investments
Sustainability Statement - Environment - Climate change - Approach - Insurance underwriting
p. 137-138
p. 139-140
p. 143
E1-3 Actions and resources in relation to climate
change policies
Sustainability Statement - Environment - Climate change - Approach - Own operations
Sustainability Statement - Environment - Climate change - Approach - Investments
Sustainability Statement - Environment - Climate change - Approach - Insurance underwriting
p. 137-138
p. 140
p. 143-144
We do not report resources because the
actions do not require significant OpEx
or CapEx beyond normal operations,
therefore there is limited information
materiality.
E1-4 Targets related to climate change mitigation and
adaptation
Sustainability Statement - Environment - Climate change - Approach - Own operations
Sustainability Statement - Environment - Climate change - Approach - Investments
Sustainability Statement - Environment - Climate change - Approach - Insurance underwriting
p. 138
p. 140-143
p. 144-145
This covers E1-4 paragraph 34.
E1-5 Energy consumption and mix Appendix - Energy consumption and mix and Sustainability indices and ratings p. 405 This covers E1-5 paragraph 37, 38, and
40 to 43.
This information is included in the
appendix as it is not material.
Reference table continued
NN Group N.V. Annual Report 2024 | 226
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Disclosure Description Reference Page(s) Explanation
E1-6 Gross scope 1, 2, 3 and total GHG emissions Sustainability Statement - Environment - Climate change - Progress p. 146 This covers E1-6 paragraph 53 to 55.
Total scope 1 and 2, as well as material
scope 3 GHG emissions, are disclosed
in the Sustainability Statement.
Additionally, the non-material scope
3 categories are disclosed in the
appendix.
E1-6
paragraph 44
Gross scope 1, 2, 3 and total GHG emissions Sustainability Statement - Environment - Climate change - Progress
Appendix - GHG emissions
p. 146
p. 402
Total scope 1 and 2, as well as material
scope 3 GHG emissions, are disclosed
in the Sustainability Statement.
Additionally, the non-material scope
3 categories are disclosed in the
appendix.
E1-7 GHG removals and GHG mitigation projects
financed through carbon credits
Sustainability Statement - Environment - Climate change - Approach - Own operations p. 138 This covers E1-7 paragraph 56.
E1-8 Internal carbon pricing NA NA We do not disclose this as NN Group
does not apply internal carbon pricing.
E1-9 Anticipated financial effects from material
physical and transition risks and potential climate-
related opportunities
Sustainability statement - General Disclosures - Our material sustainability matters
Sustainability Statement - Environment - Anticipated financial effects
p. 125
p. 159-166
We do not report paragraph 67(c) in
FY24 as we make use of the phase-in
option for quantitative disclosures for
climate change-related risks.
We do not report paragraph 69 as our
target for euros invested gives more
relevant information for the climate-
related opportunity.
E1-9
paragraph 66
Exposure of the benchmark portfolio to climate-related
physical risks
Sustainability Statement - Environment - Anticipated financial effects p. 162-166 This covers E1-9 paragraphs 66(c). We
do not report paragraph 66(a) in FY24
as we make use of the phase-in option
for quantitative disclosures for climate
change-related risks.
ESD Metrics related to investments Sustainability Statement - Environment - Climate change - Progress - Investments p. 148, p. 151-154
ESD Metrics related to investments in climate solutions Sustainability Statement - Environment - Climate change - Progress - Investments p. 154
ESD Metrics related to products and services Sustainability Statement - Environment - Climate change - Progress - Insurance underwriting p. 156
Reference table continued
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Disclosure Description Reference Page(s) Explanation
ESRS E2 – Pollution
E2 All data requirements NA NA Not material.
ESRS E3/E4 – Nature (biodiversity and water)
IRO-1 Description of the processes to identify and assess
material water and marine resources-related impacts,
risks and opportunities
Sustainability Statement - General Disclosures - Topical sustainability matters p. 130
E3-1 Policies related to water and marine resources Sustainability Statement - Environment - Nature (biodiversity and water) p. 167 This covers E3-1 paragraph 9 and 14.
E3-1
paragraph 13
Dedicated policy NA NA We do not report this as the datapoints
relate to own operations, which is not
material for E3.
E3-2 Actions and resources related to water and marine
resources
Sustainability Statement - Environment - Nature (biodiversity and water) p. 167-168 We do not report resources because the
actions do not require significant OpEx
or CapEx beyond normal operations,
therefore there is limited information
materiality.
E3-3 Targets related to water and marine resources Sustainability Statement - Environment - Nature (biodiversity and water) p. 168
E3-4 Water consumption NA NA We do not report this as the datapoints
relate to own operations, which is
not material for E3. This covers E3-4
paragraphs 28 (c) and 29.
E3-5 Anticipated financial effects from water and marine
resources-related impacts, risks and opportunities
NA NA We do not report this as the datapoints
relate to topics that are material from a
financial perspective. E3 is not material
from a financial perspective.
E4-1 Transition plan and consideration of biodiversity and
ecosystems in strategy and business model
Sustainability Statement - Environment - Nature (biodiversity and water) p. 167
SBM-3 Material impacts, risks and opportunities and their
interaction with strategy and business model
Sustainability Statement - Environment - Introduction p. 135 This covers SBM-3 - E4 paragraph 16(b).
We do not report paragraph 16(a) and
(c) as they relate to own operations,
which is not material for E4.
Reference table continued
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Disclosure Description Reference Page(s) Explanation
IRO-1 Description of processes to identify and assess material
biodiversity and ecosystem-related impacts, risks and
opportunities
Sustainability Statement - General Disclosures - Topical sustainability matters p. 130
E4-2 Policies related to biodiversity and ecosystems Sustainability Statement - Environment - Nature (biodiversity and water) p. 167 This covers E4-2 paragraph 24 (b), (c)
and (d).
E4-3 Actions and resources related to biodiversity and
ecosystems
Sustainability Statement - Environment - Nature (biodiversity and water) p. 167-168 We do not report resources because the
actions do not require significant OpEx
or CapEx beyond normal operations,
therefore there is limited information
materiality.
E4-4 Targets related to biodiversity and ecosystems Sustainability Statement - Environment - Nature (biodiversity and water) p. 168
E4-5 Impact metrics related to biodiversity and
ecosystems change
NA NA We do not report this as the datapoints
relate to own operations, which is not
material for E4.
E4-6 Anticipated financial effects from biodiversity and
ecosystem-related risks and opportunities
NA NA We do not report this as the datapoints
relate to topics that are material from a
financial perspective. E4 is not material
from a financial perspective.
ESRS E5 – Resource use and circular economy
E5 All data requirements NA NA Not material.
ESD– Sustainable repair
ESD Policies related to sustainable repair Sustainability statement - Environment - Sustainable repair p. 169
ESD Actions and resources related to sustainable repair Sustainability statement - Environment - Sustainable repair p. 169
ESD Targets related to sustainable repair Sustainability statement - Environment - Sustainable repair p. 169
ESD Metrics related to sustainable damage repair Sustainability statement - Environment - Sustainable repair p. 169
ESRS S1 – NN workers’ secure and fair employment , NN workers’ well-being, Equal treatment and opportunities for all at NN, Human capital development and attraction at NN
SBM-2 Interests and views of stakeholders Our strategy and business - Stakeholder engagement and international commitments p. 36
SBM-3 Material impacts, risks and opportunities and their
interaction with strategy and business model
Sustainability Statement - Social - Introduction p. 181 This covers SBM-3 - S1 paragraph 14(f)
and (g).
Reference table continued
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Disclosure Description Reference Page(s) Explanation
S1-1 Policies related to own workforce Sustainability Statement - Introduction
Sustainability Statement - Social - Own workforce
p. 181-182
p. 183-188
S1-1 paragraph 20 Human rights policy commitments Sustainability Statement - Introduction
Sustainability Statement - Social - Own workforce
p. 181-182
p. 183
S1-1 paragraph 21 Due diligence policies on issues addressed by the
fundamental International Labor Organisation
Conventions 1 to 8
Sustainability Statement - Introduction p. 181-182
S1-1 paragraph 22 Processes and measures for preventing trafficking in
human beings
NA NA We do not report this as child labour and
forced labour are not material for S1.
S1-1 paragraph 23 Workplace accident prevention policy or management
system
Sustainability Statement - Social - Own workforce p. 187
S1-2 Processes for engaging with own workforce and
workers’ representatives about impacts
Sustainability Statement - Social - Own workforce p. 187-188
S1-3 Processes to remediate negative impacts and
channels for own workforce to raise concerns
Sustainability Statement - Social - Own workforce p. 183-185 This covers S1-3 paragraph 32 (c).
S1-4 Taking action on material impacts on own workforce,
and approaches to mitigating material risks and
pursuing material opportunities related to own
workforce, and effectiveness of those actions
Sustainability Statement - Social - Own workforce p. 183-188 We do not report resources because the
actions do not require significant OpEx
or CapEx beyond normal operations,
therefore there is limited information
materiality.
S1-5 Targets related to managing material negative impacts,
advancing positive impacts, and managing material
risks and opportunities
Sustainability Statement - Social - Own workforce p. 188-189
S1-6 Characteristics of the undertaking’s employees Sustainability Statement - Social - Own workforce p. 190-191
S1-7 Characteristics of non-employee workers in the
undertaking’s own workforce
NA NA We do not report this disclosure in FY24
as we make use of the phase-in option.
S1-8 Collective bargaining coverage and social dialogue Sustainability Statement - Social - Own workforce p. 192
S1-9 Diversity metrics Sustainability Statement - Social - Own workforce p. 193
S1-10 Adequate wages Governance - Remuneration Report - Remuneration in general p. 106
S1-11 Social protection NA NA We do not report this disclosure in FY24
as we make use of the phase-in option.
S1-12 Persons with disabilities NA NA We do not report this disclosure in FY24
as we make use of the phase-in option.
Reference table continued
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Disclosure Description Reference Page(s) Explanation
S1-13 Training and skills development metrics Sustainability Statement - Social - Own workforce p. 194 Partially we do not report this disclosure
in FY24 as we make use of the phase-in
option.
S1-14 Health and safety metrics Sustainability Statement - Social - Own workforce p. 192 Partially we do not report this disclosure
in FY24 as we make use of the phase-in
option.
S1-14
paragraph 88 (b) and (c)
Number of fatalities and number and rate of work-
related accidents
NA NA We do not report this disclosure in FY24
as we make use of the phase-in option.
S1-14
paragraph 88 (e)
Number of days lost to injuries, accidents, fatalities or
illness
NA NA We do not report this disclosure in FY24
as we make use of the phase-in option.
S1-15 Work/life balance metrics NA NA We do not report this disclosure in FY24
as we make use of the phase-in option.
S1-16 Compensation metrics (pay gap and total
compensation)
Governance - Remuneration Report - Remuneration in general
Governance - Remuneration Report - Pay ratio
p. 106-107
p. 113
S1-16
paragraph 97 (a)
Unadjusted gender pay gap Governance - Remuneration Report - Remuneration in general p. 107
S1-16
paragraph 97 (b)
Excessive CEO pay ratio Governance - Remuneration Report - Pay ratio p. 113-114
S1-17 Incidents, complaints and severe human rights impacts Sustainability statement - Social - Own workforce p. 194 This covers S1-17 paragraph 103(a) and
104 (a).
ESD Metrics related to own workforce Sustainability statement - Social - Own workforce p. 193
ESRS S2 – Workers in the value chain
SBM-2 Interests and views of stakeholders Our strategy and business - Stakeholder engagement and international commitments p. 36
SBM-3 Material impacts, risks and opportunities and their
interaction with strategy and business model
Sustainability Statement - Social - Introduction p. 181 This covers SBM-3 - S2 paragraph 11
(b).
S2-1 Policies related to value chain workers Sustainability Statement - Social - Workers in the value chain p. 195-196 This covers S2-1 paragraph 17, 18 and
19.
S2-2 Processes for engaging with value chain workers about
impacts
Sustainability Statement - Social - Workers in the value chain p. 196-198
S2-3 Processes to remediate negative impacts and channels
for value chain workers to raise concerns
Sustainability Statement - Social - Workers in the value chain p. 196-198
Reference table continued
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Disclosure Description Reference Page(s) Explanation
S2-4 Taking action on material impacts on value chain
workers, and approaches to managing material risks and
pursuing material opportunities related to value chain
workers, and effectiveness of those actions
Sustainability Statement - Social - Workers in the value chain p. 198 This covers S2-4 paragraph 36
We do not report resources because the
actions do not require significant OpEx
or CapEx beyond normal operations,
therefore there is limited information
materiality.
S2-5 Targets related to managing material negative impacts,
advancing positive impacts, and managing material
risks and opportunities
Sustainability Statement - Social - Workers in the value chain p. 198
ESRS S3 - Affected communities
S3 All data requirements NA NA Not material.
ESRS S4 – Financial inclusion, Clear and secure data
SBM-2 Interests and views of stakeholders Our strategy and business - Stakeholder engagement and international commitments p. 36
SBM-3 Material impacts, risks and opportunities and their
interaction with strategy and business model.
Sustainability Statement - Social - Introduction p. 181
S4-1 Policies related to consumers and end-users Sustainability Statement - Social - Consumers and end-users p. 203-204 This covers S4-1 paragraphs 16 and 17.
S4-2 Processes for engaging with consumers and end-users
about impacts
Sustainability Statement - Social - Consumers and end-users p. 204-205
S4-3 Processes to remediate negative impacts and channels
for consumers and end-users to raise concerns
Sustainability Statement - Social - Consumers and end-users p. 205-206
S4-4 Taking action on material impacts, and approaches
to mitigating material risks and pursuing material
opportunities related to consumers and end-users and
effectiveness of those actions and approaches
Sustainability Statement - Social - Consumers and end-users p. 206 We do not report resources because the
actions do not require significant OpEx
or CapEx beyond normal operations,
therefore there is limited information
materiality.
S4-4 paragraph 35 Human rights issues and incidents Sustainability Statement - Social - Consumers and end-users p. 205
Reference table continued
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Disclosure Description Reference Page(s) Explanation
S4-5 Targets related to managing material negative impacts,
advancing positive impacts, and managing material
risks and opportunities
Sustainability Statement - Social - Consumers and end-users p. 206
ESD – Community Investment
ESD Policies related to community investment Sustainability Statement - Social - Community investment p. 199-200
ESD Actions in relation to community investment Sustainability Statement - Social - Community investment p. 202
ESD Targets related to community investment Sustainability Statement - Social - Community investment p. 200-201
ESD Metrics related to community investment Sustainability Statement - Social - Community investment p. 201
ESRS G1 – Corporate culture, corruption and bribery
GOV-1 The role of the administrative, supervisory and
management bodies
Governance - Corporate governance - Diversity and Skills matrix
Governance - Corporate governance
Governance - Corporate governance - Report of the Supervisory Board - Diversity and Skills matrix
p. 69
p. 83-84
p. 102
IRO-1 Description of the processes to identify and assess
material impacts, risks and opportunities
Sustainability Statement - General Disclosures - Topical sustainability matters p. 131
G1-1 Corporate culture and business conduct policies and
corporate culture
About NN - Our values and behaviours
Governance - Our Code of Conduct and other policies
Sustainability Statement - Governance - Prevention and detection of corruption and bribery
processes
p. 7-8
p. 115-118
p. 209
This covers G1-1 paragraph 10 (b) and
(d).
G1-2 Management of relationships with suppliers NA NA We do not report this as G1-2 is not
material.
G1-3 Prevention and detection of corruption and bribery Sustainability Statement - Governance - Prevention and detection of
corruption and bribery processes
p. 209
G1-4 Confirmed incidents of corruption or bribery Sustainability Statement - Governance - Prevention and detection of
corruption and bribery processes
p. 209 This covers G1-4 paragraph 24 (a) and
(b).
G1-5 Political influence and lobbying activities NA NA We do not report this as G1-5 is not
material.
G1-6 Payment practices NA NA We do not report this as G1-6 is not
material.
ESD Metrics related to corporate culture About NN - Our values and behaviours p. 8
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EU Taxonomy disclosure tables
This appendix contains additional mandatory EU Taxonomy disclosures
that should be read in conjunction with the disclosures related to the EU
Taxonomy Investment KPI included in ‘Environment’ on p. 171.
Investments
In this section NN Group provides the following mandatory EU Taxonomy
disclosure tables:
• Denominator of the Investment KPI
• Numerator of the Investment KPI
• Numerator of the Investment KPI by environmental objective and
economic activity
• Eligibility of the four non-climate environmental objectives
• Gas and nuclear activities
For investments for which there is no externally reported information
available, estimates are used
1
. The estimated eligibility and alignment
are reported voluntarily
2
and are therefore not part of the mandatory
disclosures.
All amounts are in millions of euros unless indicated otherwise.
1
The only exception are externally managed mortgages, which are presented as non-aligned
in the reported figures in case of no data available.
2
NN Group reports against the EU Taxonomy voluntarily because it recognises the
importance of increasing transparency about how companies are progressing in changing
of and adapting to climate change, even if the regulation is evolving and not yet mature.
Denominator of the Investment KPI
In the table below, information on the denominator (covered assets)
of the Investment KPI is provided. The largest part of the denominator
(38%) relates to investments in other counterparties which consist
of retail mortgages loans and direct real estate investments. The
investments in Non-Financial Reporting Directive (NFRD) companies
are in total 9% of the denominator. These two figures together (47%)
comprise the investments of NN Group subject to a mandatory eligibility
and alignment assessment.
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Additional, complementary disclosures: breakdown of denominator of the KPI
Mandatory Voluntary
1
Mandatory Voluntary
1
The percentage of derivatives relative to total assets covered by the KPI. 2% 2% The value in monetary amounts of derivatives: 2,967 2,967
The proportion of exposures to financial and non-financial undertakings from
EU-countries not subject to Articles 19a and 29a of Directive 2013/34/EU
over total assets covered by the KPI:
Value of exposures to financial and non-financial undertakings from EU-
countries not subject to Articles 19a and 29a of Directive 2013/34/EU:
For non-financial undertakings: % 3% 3% For non-financial undertakings: amount 4,613 4,613
For financial undertakings: % 40% 40% For financial undertakings: amount 63,651 63,651
The proportion of exposures to financial and non-financial undertakings from
non-EU countries not subject to Articles 19a and 29a of Directive 2013/34/EU
over total assets covered by the KPI:
Value of exposures to financial and non-financial undertakings from non-
EU countries not subject to Articles 19a and 29a of Directive 2013/34/
EU:
For non-financial undertakings: % 4% 4% For non-financial undertakings: amount 6,766 6,766
For financial undertakings: % 5% 5% For financial undertakings: amount 7,237 7,237
The proportion of exposures to financial and non-financial undertakings
subject to Articles 19a and 29a of Directive 2013/34/EU over total assets
covered by the KPI:
Value of exposures to financial and non-financial undertakings subject to
Articles 19a and 29a of Directive 2013/34/EU:
For non-financial undertakings: % 5% 5% For non-financial undertakings: amount 7,246 7,246
For financial undertakings: % 4% 4% For financial undertakings: amount 5,952 5,952
The proportion of exposures to other counterparties and assets over total
assets covered by the KPI: % 38% 38%
Value of exposures to other counterparties and assets: amount
60,247 60,247
The proportion of NN Group’s investments other than investments held in
respect of life insurance contracts where the investment risk is borne by the
policy holders, that are directed at funding, or are associated with, Taxonomy-
aligned economic activities: % N/A for NN N/A for NN
Value of NN Group’s investments other than investments held in respect
of life insurance contracts where the investment risk is borne by the
policy holders, that are directed at funding, or are associated with,
Taxonomy-aligned economic activities: amount N/A for NN N/A for NN
The value of all the investments that are funding economic activities that are
not Taxonomy-eligible relative to the value of total assets covered by the KPI:
Value of all the investments that are funding economic activities that are
not Taxonomy-eligible:
Turnover-based: % 64% 90% Turnover-based: amount 101,792 142,373
Capital expenditures-based: % 97% 98% Capital expenditures-based: amount 153,456 155,165
The value of all the investments that are funding Taxonomy-eligible economic
activities, but not Taxonomy-aligned relative to the value of total assets
covered by the KPI:
Value of all the investments that are funding Taxonomy-eligible
economic activities, but not Taxonomy-aligned:
Turnover-based: % 25% 7% Turnover-based: amount 40,302 11,172
Capital expenditures-based: % 2% 2% Capital expenditures-based: amount 2,582 3,218
1
Estimated EU Taxonomy figures are reported on a voluntary basis in addition to the mandatory EU Taxonomy figures, therefore there is no overlap in mandatory and voluntary figures.
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Numerator of the Investment KPI
In the table below, we provide information on the numerator (taxonomy-
alignment) by type of counterparty of the Investment KPI. This shows
that NN Group’s mandatory alignment is mainly driven by investments
in other counterparties, which are the retail mortgage loans, and to a
small extent by investments in non-financial companies. There is limited
alignment from investments in financial companies because alignment
information of these counterparties, other than investments funds, is not
yet available as these companies are reporting this information at the
same time as NN Group.
Additional, complementary disclosures: breakdown of numerator of the KPI
The proportion of Taxonomy-aligned exposures to financial and non-financial
undertakings subject to Articles 19a and 29a of Directive 2013/34/EU over total
assets covered by the KPI:
Value of Taxonomy-aligned exposures to financial and non-financial undertakings
subject to Articles 19a and 29a of Directive 2013/34/EU:
Mandatory Voluntary
1
Mandatory Voluntary
1
For non-financial undertakings: For non-financial undertakings:
Turnover-based 1% 0% Turnover-based 917 2
CapEx-based 1% CapEx-based 1,281
For financial undertakings: For financial undertakings:
Turnover-based 0% 3% Turnover-based 669 4,169
CapEx-based 1% 0% CapEx-based 1,361 297
The proportion of the insurance or reinsurance undertaking’s investments other
than investments held in respect of life insurance contracts where the investment
risk is borne by the policy holders, that are directed at funding, or are associated
with, Taxonomy-aligned over total assets covered by the KPI:
Value of insurance or reinsurance undertaking’s investments other than
investments held in respect of life insurance contracts where the investment risk
is borne by the policy holders, that are directed at funding, or are associated with,
Taxonomy-aligned:
Turnover-based
N/A for NN N/A for NN Turnover-based N/A for NN N/A for NN
CapEx-based N/A for NN N/A for NN CapEx-based N/A for NN N/A for NN
The proportion of Taxonomy-aligned exposures to
other counterparties and assets over total assets
covered by the KPI:
Value of Taxonomy-aligned exposures to other
counterparties and assets over total
assets covered by the KPI:
Turnover-based 9% 1% Turnover-based 15,000 964
CapEx-based CapEx-based
1
Estimated EU Taxonomy figures are reported on a voluntary basis in addition to the mandatory EU Taxonomy figures, therefore there is no overlap in mandatory and voluntary figures.
2
NN Group does not have non-life insurance contracts where the investment risk is borne by policy holders.
3
Under the EU Taxonomy, enabling activities are economic activities that directly enable
other activities to make a substantial contribution to one or more of the six environmental
objectives of the EU Taxonomy.
4
Under the EU Taxonomy, transitional activities are ones that support the transition to
a climate-neutral economy in a manner that is consistent with a pathway to limit the
temperature increase to 1.5 degrees Celsius above pre-industrial levels.
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Numerator of the Investment KPI by environmental objective
and economic activity
In the table below, we provide information on the numerator (taxonomy-
alignment) of the Investment KPI by environmental objective and type
of economic activity. This shows that NN Group’s mandatory alignment
is related to the climate change mitigation objective and only to a very
limited extent related to transitional and enabling activities
3
. This can be
explained by the fact that mandatory alignment is mainly driven by the
retail mortgage loans that link to the economic activity ‘Acquisition and
ownership of buildings’, which is not a transitional
4
or enabling activity,
and makes a substantial contribution to climate change mitigation.
Breakdown of the numerator of the KPI per environmental objective
Taxonomy-aligned activities – provided ‘do-not-significant-harm’ (DNSH) and social safeguards positive assessment:
Transitional Enabling
Mandatory Voluntary
1
Mandatory Voluntary
1
Mandatory Voluntary
1
Climate change mitigation
Turnover 10% 3% 0% 0% 1% 1%
CapEx 1% 0% 0% 0% 1% 0%
Climate change adaptation
Turnover 0% 0% 0% 0%
CapEx 0% 0% 0%
The sustainable use and protection of water and marine resources
Turnover
CapEx
The transition to a circular economy
Turnover
CapEx
Pollution prevention and control
Turnover
CapEx
The protection and restoration of biodiversity and ecosystems
Turnover
CapEx
1
Estimated EU Taxonomy figures are reported on a voluntary basis in addition to the mandatory EU Taxonomy figures, therefore there is no overlap in mandatory and voluntary figures.
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Based on the information currently available, the tables above provide
insight into the composition of NN Group’s Investment KPI. Further
explanation on this information, associated assumptions and limitations,
is presented below.
Eligibility of the four non-climate environmental objectives
In 2023 the EU Commission introduced the Environmental Delegated Act
defining the economic activities that make a substantial contribution to
one or more of the four non-climate environmental objectives. Under the
Environmental Delegated Act, taxonomy-eligibility information related to
the four non-climate environmental objectives is required to be disclosed
from 2023 onwards.
NN Group has reported counterparty information when available. For
the remainder, we assessed this eligibility based on the NACE codes
of the counterparties and presented this as a voluntary disclosure.
The EU Taxonomy includes NACE codes in the description of economic
activities. If the NACE code of the counterparty for the remaining
exposures matches those included in the EU Taxonomy, these are
considered taxonomy-eligible; if the NACE code of the counterparty does
not match to the EU Taxonomy, these are considered taxonomy non-
eligible. An inherent limitation in this approach is that the outcome of
the assessment of the counterparty using the NACE code is binary, and
therefore does not reflect a counterparty’s multiple economic activities.
As shown below, non-climate eligibility amounts to EUR 688 million
and represents 0% of covered assets. In calculating these figures,
investments for reported climate eligibility were adjusted based on
turnover, where applicable.
Amount Proportion %
Non-climate eligible 688 0%
Assets covered by the KPI 158,680 100%
Gas and nuclear activities
From 2023 the Complementary Delegated Act added gas and nuclear
activities to the economic activities that can make a substantial
contribution to climate change mitigation and climate change
adaptation. Following the inclusion of gas and nuclear economic
activities in the scope of the EU Taxonomy disclosures, NN Group is
required to disclose information on eligibility and alignment of gas and
nuclear activities as described in the EU Taxonomy.
The tables below are required under the EU Taxonomy Regulation
and reflect whether NN Group finances or invests in gas and nuclear
activities.
EU Taxonomy data is not available for all gas and nuclear investments.
Therefore, at aggregated level, adjustments were made so that the sum
of alignment, non-alignment and non-eligible equals covered assets.
The investment alignment figures were used as a base for totals for
each template. For certain rows in each template, the alignment figures
have been determined by deducting the sum of fossil gas and nuclear
economic activities from the respective total number. Where alignment
data was received for both the climate change mitigation and climate
change adaptation objectives, the alignment has been included in the
climate change mitigation section.
The table below shows the mandatory overview of activities. While
a YES can be shown in the first table it is possible that the following
tables show no data in the respective fields, due to the small amount of
exposure. In general, most alignment stems from other activities with
limited gas and nuclear data available.
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Template 1: nuclear- and fossil gas-related activities
Nuclear energy related activities Mandatory Voluntary
1
The undertaking carries out, funds or has exposures to research, development, demonstration
and deployment of innovative electricity generation facilities that produce energy from nuclear
processes with minimal waste from the fuel cycle.
NO NO
The undertaking carries out, funds or has exposures to construction and safe operation of new
nuclear installations to produce electricity or process heat, including for the purposes of district
heating or industrial processes such as hydrogen production, as well as their safety upgrades,
using best available technologies.
YES YES
The undertaking carries out, funds or has exposures to safe operation of existing nuclear
installations that produce electricity or process heat, including for the purposes of district heating
or industrial processes such as hydrogen production from nuclear energy, as well as their safety
upgrades.
YES YES
Fossil gas related activities
The undertaking carries out, funds or has exposures to construction or operation of electricity
generation facilities that produce electricity using fossil gaseous fuels.
YES YES
The undertaking carries out, funds or has exposures to construction, refurbishment, and operation
of combined heat/cool and power generation facilities using fossil gaseous fuels.
YES NO
The undertaking carries out, funds or has exposures to construction, refurbishment and operation
of heat generation facilities that produce heat/cool using fossil gaseous fuels.
NO NO
1
Estimated EU Taxonomy figures are reported on a voluntary basis in addition to the mandatory EU Taxonomy figures, therefore there is no
overlap in mandatory and voluntary figures.
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The tables below (Template 2 and Template 3) provide information on the amount and proportion of taxonomy-
aligned exposures to gas and nuclear economic activities. Template 2 sets the alignment into perspective to
covered assets (denominator).
Template 2: gas and nuclear taxonomy-aligned economic activities (denominator)
Mandatory Turnover Mandatory CapEx Voluntary Turnover
1
Voluntary CapEx
1
CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA) CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA) CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA) CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
Amount and proportion of taxonomy-
aligned economic activity referred to
in Section 4.26 of Annexes I and II to
Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
Amount and proportion of taxonomy-
aligned economic activity referred to
in Section 4.27 of Annexes I and II to
Delegated Regulation 2021/2139 in the
denominator of the applicable KPI 0 0% 0 0% 0 0% 0 0%
Amount and proportion of taxonomy-
aligned economic activity referred to
in Section 4.28 of Annexes I and II to
Delegated Regulation 2021/2139 in the
denominator of the applicable KPI 5 0% 5 0% 5 0% 5 0%
Amount and proportion of taxonomy-
aligned economic activity referred to
in Section 4.29 of Annexes I and II to
Delegated Regulation 2021/2139 in the
denominator of the applicable KPI 13 0% 13 0% 16 0% 16 0%
Amount and proportion of taxonomy-
aligned economic activity referred to
in Section 4.30 of Annexes I and II to
Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
Amount and proportion of taxonomy-
aligned economic activity referred to
in Section 4.31 of Annexes I and II to
Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
Amount and proportion of other
taxonomy-aligned economic activities
not referred to in rows 1 to 6 above in
the denominator of the applicable KPI 16,568 10% 16,460 10% 108 0% 2,621 2% 2,341 1% 281 0% 5,135 3% 5,131 3% 4 0% 297 0% 295 0% 2 0%
Total applicable KPI 16,586 10% 16,478 10% 108 0% 2,642 2% 2,361 1% 281 0% 5,135 3% 5,131 3% 4 0% 297 0% 295 0% 2 0%
1
Estimated EU Taxonomy figures are reported on a voluntary basis in addition to the mandatory EU Taxonomy figures, therefore there is no overlap in mandatory and voluntary figures.
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The table below (Template 3) aims to show the gas and nuclear portion of the overall taxonomy-alignment. Therefore, the total alignment is used as a base instead of covered assets.
Template 3: gas and nuclear taxonomy-aligned economic activities (numerator)
Mandatory Turnover Mandatory CapEx Voluntary Turnover
1
Voluntary CapEx
1
CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA) CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA) CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA) CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
Amount and proportion of taxonomy-aligned
economic activity referred to in Section 4.26 of
Annexes I and II to Delegated Regulation
2021/2139 in the numerator of the applicable
KPI 0
Amount and proportion of taxonomy-aligned
economic activity referred to in Section 4.27 of
Annexes I and II to Delegated Regulation
2021/2139 in the numerator of the applicable
KPI 0 0% 0 0% 0 0% 0 0%
Amount and proportion of taxonomy-aligned
economic activity referred to in Section 4.28 of
Annexes I and II to Delegated Regulation
2021/2139 in the numerator of the applicable
KPI 5 0% 5 0% 5 0% 5 0%
Amount and proportion of taxonomy-aligned
economic activity referred to in Section 4.29 of
Annexes I and II to Delegated Regulation
2021/2139 in the numerator of the applicable
KPI 13 0% 13 0% 16 1% 16 1%
Amount and proportion of taxonomy-aligned
economic activity referred to in Section 4.30 of
Annexes I and II to Delegated Regulation
2021/2139 in the numerator of the applicable
KPI
Amount and proportion of taxonomy-aligned
economic activity referred to in Section 4.31 of
Annexes I and II to Delegated Regulation
2021/2139 in the numerator of the applicable
KPI
Amount and proportion of other taxonomy-
aligned economic activities not referred to in
rows 1 to 6 above in the numerator of the
applicable KPI 16,568 100% 16,460 100% 108 0% 2,621 99% 2,341 89% 281 11% 5,135 100% 5,131 100% 4 0% 297 100% 295 99% 2 1%
Total applicable KPI 16,586 100% 16,478 100% 108 0% 2,642 100% 2,361 89% 281 11% 5,135 100% 5,131 100% 4 0% 297 100% 295 99% 2 1%
1
Estimated EU Taxonomy figures are reported on a voluntary basis in addition to the mandatory EU Taxonomy figures, therefore there is no overlap in mandatory and voluntary figures.
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The table below (Template 4) provides information on the amount and proportion of taxonomy-eligible but not taxonomy-aligned exposures to gas and nuclear economic activities.
Template 4: taxonomy-eligible but not taxonomy-aligned gas and nuclear economic activities
Mandatory Turnover Mandatory CapEx Voluntary Turnover
1
Voluntary CapEx
1
CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA) CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA) CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA) CCM + CCA
Climate change
mitigation (CCM)
Climate change
adaptation (CCA)
Amount and proportion of taxonomy-
eligible but not taxonomy-aligned
economic activity referred to in Section
4.26 of Annexes I and II to Delegated
Regulation 2021/2139 in the
denominator of the applicable KPI
Amount and proportion of taxonomy-
eligible but not taxonomy-aligned
economic activity referred to in Section
4.27 of Annexes I and II to Delegated
Regulation 2021/2139 in the
denominator of the applicable KPI 0 0% 0 0% 0 0% 0 0%
Amount and proportion of taxonomy-
eligible but not taxonomy-aligned
economic activity referred to in Section
4.28 of Annexes I and II to Delegated
Regulation 2021/2139 in the
denominator of the applicable KPI 0 0% 0 0%
Amount and proportion of taxonomy-
eligible but not taxonomy-aligned
economic activity referred to in Section
4.29 of Annexes I and II to Delegated
Regulation 2021/2139 in the
denominator of the applicable KPI 91 0% 91 0% 15 0% 15 0%
Amount and proportion of taxonomy-
eligible but not taxonomy-aligned
economic activity referred to in Section
4.30 of Annexes I and II to Delegated
Regulation 2021/2139 in the
denominator of the applicable KPI 0 0% 0 0% 0 0% 0 0%
Amount and proportion of taxonomy-
eligible but not taxonomy-aligned
economic activity referred to in Section
4.31 of Annexes I and II to Delegated
Regulation 2021/2139 in the
denominator of the applicable KPI
Amount and proportion of other
taxonomy-eligible but not taxonomy-
aligned economic activities not referred
to in rows 1 to 6 above in the
denominator of the applicable KPI 40,210 25% 39,217 25% 993 1% 2,567 2% 1,962 1% 605 0% 11,172 7% 7,076 4% 4,096 3% 3,218 2% 1,117 1% 2,101 1%
Total applicable KPI 40,302 25% 39,308 25% 993 1% 2,582 2% 1,977 1% 605 0% 11,172 7% 7,076 4% 4,096 3% 3,218 2% 1,117 1% 2,101 1%
1
Estimated EU Taxonomy figures are reported on a voluntary basis in addition to the mandatory EU Taxonomy figures, therefore there is no overlap in mandatory and voluntary figures.
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The table below (Template 5) provides information on the amount and proportion of gas and nuclear exposures that are not taxonomy-eligible.
Template 5: taxonomy-non-eligible economic activities
Mandatory Turnover Mandatory CapEx Voluntary Turnover
1
Voluntary CapEx
1
Amount and proportion of economic activity referred to in row 1 of Template 1 that is taxonomy-non-
eligible in accordance with Section 4.26 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI
Amount and proportion of economic activity referred to in row 2 of Template 1 that is taxonomy-non-
eligible in accordance with Section 4.27 of Annexes I and II to Delegated Regulation 2021/2139 in the
denominator of the applicable KPI 0 0% 1 0% 0 0% 1 0%
Amount and proportion of economic activity referred to in row 3 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.28 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI 151 0% 151 0% 23 0% 24 0%
Amount and proportion of economic activity referred to in row 4 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.29 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI 854 1% 894 1% 371 0% 434 0%
Amount and proportion of economic activity referred to in row 5 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.30 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI 11 0% 11 0%
Amount and proportion of economic activity referred to in row 6 of Template 1 that is taxonomy-non-eligible in
accordance with Section 4.31 of Annexes I and II to Delegated Regulation 2021/2139 in the denominator of the
applicable KPI
Amount and proportion of other taxonomy-non-eligible economic activities not referred to in rows 1 to 6 above in the
denominator of the applicable KPI 100,775 64% 152,399 96% 141,979 89% 154,706 97%
Total amount and proportion of taxonomy-non-eligible economic activities in the denominator of the
applicable KPI 101,792 64% 153,456 97% 142,373 90% 155,165 98%
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Notes to the Consolidated annual accounts continued
Annual
accounts
NN Group N.V. Annual Report 2024 | 244
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Consolidated annual accounts
Consolidated balance sheet
Consolidated profit and loss account
Consolidated statement of comprehensive income
Consolidated statement of cash flows
Consolidated statement of changes in equity
Notes to the Consolidated annual accounts
1 Accounting policies
2 Cash and cash equivalents
3 Investments at fair value through other
comprehensive income
4 Investments at cost
5 Investments at fair value through profit or loss
6 Investments in real estate
7 Investments in associates and joint ventures
8 Property and equipment
9 Intangible assets
10 Other assets
11 Equity
12 Insurance contracts
13 Investment contracts
14 Reinsurance contracts
15 Debt instruments issued
16 Subordinated debt
17 Other borrowed funds
18 Customer deposits
19 Derivatives
20 Other liabilities
21 Insurance income
22 Insurance expenses
23 Investment result
24 Finance result
25 Fee and commission result
26 Non-attributable operating expenses
27 Earnings per ordinary share
28 Segments
29 Insurance contracts by segment
30 Principal subsidiaries and geographical information
31 Taxation
32 Fair value of financial assets and liabilities
33 Fair value of non-financial assets
34 Hedge accounting
35 Assets by contractual maturity
36 Liabilities by maturity
37 Assets not freely disposable
38 Transferred, but not derecognised financial assets
39 Offsetting of financial assets and liabilities
40 Contingent liabilities and commitments
41 Legal proceedings
42 Companies and businesses acquired and divested
43 Structured entities
44 Related parties
45 Key management personnel compensation
46 Fees of auditors
47 Subsequent and other events
48 Risk management
49 Capital and liquidity management
Authorisation of the consolidated annual accounts
Parent company annual accounts
Parent company balance sheet
Parent company profit and loss account
Parent company statement of changes in equity
Notes of the Parent company annual accounts
Authorisation of the Parent company annual
accounts
Other information
Independent auditor’s report
Limited assurance report of the independent auditor
on the Sustainability Statement
Appropriation of result
NN Group N.V. Annual Report 2024 | 245
Consolidated annual accounts
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Consolidated balance sheet
| amounts in millions of euros, unless stated otherwise | |||
notes | 2024 | 2023 | |
| Assets | |||
| Cash and cash equivalents | 2 | ||
Investments at fair value through Other Comprehensive Income | 3 | ||
Investments at cost | 4 | ||
Investments at fair value through profit or loss | 5 | ||
Investments in real estate | 6 | ||
Investments in associates and joint ventures | 7 | ||
Derivatives | 19 | ||
Investments | |||
Insurance contracts | 12 | ||
Reinsurance contracts | 14 | ||
Insurance and reinsurance contracts | |||
Property and equipment | 8 | ||
Intangible assets | 9 | ||
Deferred tax assets | 31 | ||
Other assets | 10 | ||
Other | |||
Total assets |
References relate to the notes starting with Note 1 ‘Accounting policies’. These form an integral part of the
Consolidated annual accounts.
notes | 2024 | 2023 | |
| Equity | |||
| Shareholders’ equity | |||
Minority interests | |||
Undated subordinated notes | |||
Total equity | 11 | ||
| Liabilities | |||
Insurance contracts | 12 | ||
Investment contracts | 13 | ||
Reinsurance contracts | 14 | ||
Insurance, investment and reinsurance contracts | |||
Debt instruments issued | 15 | ||
Subordinated debt | 16 | ||
Other borrowed funds | 17 | ||
Customer deposits | 18 | ||
Funding | |||
Derivatives | 19 | ||
Deferred tax liabilities | 31 | ||
Other liabilities | 20 | ||
Other | |||
Total liabilities | |||
Total equity and liabilities |
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Consolidated annual accounts
About NN | Governance Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability Stateme | nt | |||
| Consolidated profit and loss account | |||||
For the year ended 31 December | notes | 2024 | 2023 | ||
Release of contractual service margin | |||||
Release of risk adjustment | |||||
Expected claims and benefits | |||||
Expected attributable expenses | |||||
Recovery of acquisition costs | |||||
Experience adjustments for premiums | |||||
Insurance income Premium Allocation Approach | |||||
Insurance income | 21 | ||||
Incurred claims and benefits | |||||
Incurred attributable expenses | |||||
Amortisation of acquisition costs | |||||
Changes in incurred claims and benefits previous periods | − | ||||
(Reversal of) losses on onerous contracts | − | ||||
Insurance expenses Premium Allocation Approach | |||||
Insurance expenses | 22 | ||||
Net insurance result | |||||
Net reinsurance result | − | − | |||
Insurance and reinsurance result |
For the year ended 31 December | notes | 2024 | 2023 |
Investment income | |||
Gains (losses) on investments | |||
Other investment result | |||
Investment result | 23 | ||
Finance result on (re) insurance contracts | 24 | ||
Result on investment contracts | |||
Finance result other | 24 | ||
Finance result | |||
Net investment result | |||
Fee and commission result | 25 | ||
Result on disposals of group companies | |||
Non-attributable operating expenses | 26 | − | − |
Other | |||
Other result | − | − | |
Result before tax | |||
Taxation | 31 | ||
Net result |
NN Group N.V. Annual Report 2024 | 247
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Consolidated profit and loss account continued
Net result
For the year ended 31 December | 2024 | 2023 |
| Net result attributable to: | ||
Shareholders of the parent | ||
Minority interests | ||
Net result |
Earnings per ordinary share
For the year ended 31 December and amounts in euros per ordinary share | notes | 2024 | 2023 |
Basic earnings per ordinary share | 27 | ||
Diluted earnings per ordinary share | 27 |
Reference is made to Note 27 ‘Earnings per ordinary share’ for the disclosure on the Earnings per ordinary
share.
NN Group N.V. Annual Report 2024 | 248
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Consolidated statement of comprehensive income
For the year ended 31 December | 2024 | 2023 | ||
Net result | ||||
– finance result on insurance contracts, recognised in OCI | − | − | ||
– finance result on reinsurance contracts, recognised in OCI | − | |||
– revaluations on debt securities at fair value through OCI | − | |||
– revaluations on loans at fair value through OCI | ||||
| – realised gains (losses) transferred to the profit and loss | ||||
account | ||||
– changes in cash flow hedge reserve | − | |||
| – share of OCI of investments in associates and joint | ||||
ventures | − | − | ||
– foreign currency exchange differences | − | − | ||
Items that may be reclassified subsequently to the profit and loss account | ||||
– revaluations on equity securities at fair value through OCI | − | |||
– revaluations on property in own use | − | |||
– remeasurement of the net defined benefit asset/liability | − | |||
| Items that will not be reclassified to the profit and loss | ||||
account | - | |||
Total other comprehensive income | ||||
Total comprehensive income |
Reference is made to Note 31 ‘Taxation’ for the disclosure on the income tax effects on each component of
comprehensive income.
For the year ended 31 December | 2024 | 2023 |
| Comprehensive income attributable to: | ||
Shareholders of the parent | ||
Minority interests | ||
Total comprehensive income |
NN Group N.V. Annual Report 2024 | 249
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Consolidated statement of cash flows
For the year ended 31 December | 2024 | 2023 |
Result before tax | ||
| Adjusted for: | ||
– depreciation and amortisation | ||
– changes in (re) insurance and investment contracts | ||
– (un) realised results and impairments on investments | − | − |
– other | − | |
Net premiums, claims, and attributable expenses on (re) insurance contracts | − | − |
Tax paid (received) | − | − |
| Changes in: | ||
– derivatives | − | − |
– investments at cost | − | − |
– other assets | ||
– customer deposits | ||
– other liabilities | − | |
Net cash flow from operating activities | − | |
| Investments and advances: | ||
– group companies, net of cash acquired | − | − |
– investments at fair value through OCI | − | − |
– investments at cost | − | − |
– investments at fair value through profit or loss | − | − |
– investments in associates and joint ventures | − | − |
– investments in real estate | − | − |
– other investments | − | − |
For the year ended 31 December | 2024 | 2023 |
| Disposals and redemptions: | ||
– group companies | ||
– investments at fair value through OCI | ||
– investments at cost | ||
– investments at fair value through profit or loss | ||
– investments in associates and joint ventures | ||
– investments in real estate | ||
– other investments | ||
Net cash flow from investing activities | ||
Proceeds from issuance of undated subordinated notes | ||
Repayments of undated subordinated notes | − | − |
Proceeds from issuance of subordinated notes | ||
Repayments of subordinated notes | − | − |
Repayments of debt instruments issued | − | |
Proceeds from other borrowed funds | ||
Repayments of other borrowed funds | − | − |
Dividend paid | − | − |
Purchase (sale) of treasury shares | − | − |
Coupon on undated subordinated notes | − | − |
Net cash flow from financing activities | − | − |
Net cash flow | − |
NN Group N.V. Annual Report 2024 | 250
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Consolidated statement of cash flows continued
Included in net cash flow from operating activities
For the year ended 31 December | 2024 | 2023 |
Interest received | ||
Interest paid | − | − |
Dividend received | ||
| Cash and cash equivalents |
For the year ended 31 December | 2024 | 2023 |
Changes in Cash and cash equivalents - opening balance | ||
Net cash flow | − | |
Effect of foreign currency exchange differences on cash and cash equivalents | − | − |
Changes in Cash and cash equivalents - closing balance |
NN Group N.V. Annual Report 2024 | 251
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Consolidated statement of changes in equity (2024)
| Total | |||||||
| Shareholders' | Undated | ||||||
| Share | Share | equity | Minority | subordinated | Total | ||
| capital | premium | Reserves | (parent) | interest | notes | equity | |
Balance at 1 January 2024 | |||||||
Finance result on insurance contracts recognised in OCI | − | − | − | ||||
Finance result on reinsurance contracts recognised in OCI | |||||||
Revaluations on debt securities at fair value through OCI | − | − | − | ||||
Revaluations on loans at fair value through OCI | |||||||
Realised gains (losses) transferred to the profit and loss account | |||||||
Changes in cash flow hedge reserve | |||||||
Share of OCI of investments in associates and joint ventures | − | − | − | ||||
Foreign currency exchange differences | − | − | − | ||||
Revaluations on equity securities at fair value through OCI | − | − | − | ||||
Remeasurement of the net defined benefit asset/liability | |||||||
Total amount recognised directly in equity (OCI) | |||||||
Net result for the year | |||||||
Total comprehensive income | |||||||
Issuance (redemption) of undated subordinated notes | |||||||
Changes in share capital | − | ||||||
Dividend | − | − | − | − | |||
Purchase (sale) of treasury shares | − | − | − | ||||
Employee stock option and share plans | |||||||
Coupon on undated subordinated notes | − | − | − | ||||
Changes in the composition of the group and other changes | − | − | − | ||||
Balance at 31 December 2024 |
NN Group N.V. Annual Report 2024 | 252
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Consolidated statement of changes in equity (2023)
| Total | |||||||
| Shareholders' | Undated | ||||||
| Share | Share | equity | Minority | subordinated | Total | ||
| capital | premium | Reserves | (parent) | interest | notes | equity | |
Balance at 1 January 2023 | |||||||
Finance result on insurance contracts recognised in OCI | − | − | − | ||||
Finance result on reinsurance contracts recognised in OCI | − | − | − | ||||
Revaluations on debt securities at fair value through OCI | |||||||
Revaluations on loans at fair value through OCI | |||||||
Realised gains (losses) transferred to the profit and loss account | |||||||
Changes in cash flow hedge reserve | − | − | − | ||||
Share of OCI of investments in associates and joint ventures | − | − | − | ||||
Foreign currency exchange differences | − | − | − | ||||
Revaluations on equity securities at fair value through OCI | |||||||
Remeasurement of the net defined benefit asset/liability | − | − | − | ||||
Revaluations on property in own use | − | − | − | ||||
Total amount recognised directly in equity (OCI) | |||||||
Net result for the year | |||||||
Total comprehensive income |
Issuance (redemption) of undated subordinated notes | − | − | |||||
Changes in share capital | − | ||||||
Dividend | − | − | − | − | |||
Purchase (sale) of treasury shares | − | − | − | ||||
Employee stock option and share plans | |||||||
Coupon on undated subordinated notes | − | − | − | ||||
Changes in the composition of the group and other changes | − | − | − | ||||
Balance at 31 December 2023 |
NN Group N.V. Annual Report 2024 | 253
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts
NN Group N.V. Annual Report 2024 | 254
Consolidated annual accounts
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
NN Group N.V. Annual Report 2024 | 255
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
Group companies
The results and financial positions of all group companies that have a functional currency different from the
presentation currency are translated into the presentation currency as follows:
∙ Assets and liabilities included in each balance sheet are translated at the closing rate at the date of that
balance sheet.
∙ Income and expenses included in each profit and loss account are translated at average exchange rates
(unless this average is not a reasonable approximation of the cumulative effect of the rates prevailing on
the transaction dates, in which case income and expenses are translated at the dates of the transactions).
∙ All resulting exchange rate differences are recognised in a separate component of equity in ‘Currency
translation reserve’.
On consolidation, exchange rate differences arising from the translation of a monetary item that forms part
of the net investment in a foreign operation and of borrowings and other instruments designated as hedges
of such investments are taken to shareholders’ equity. When a foreign operation is sold the corresponding
exchange rate differences are recognised in the profit and loss account as part of the gain or loss on sale.
Goodwill and fair value adjustments arising from the acquisition of a foreign operation are treated as assets
and liabilities of the foreign operation and translated at the exchange rate prevailing at the balance sheet
date.
Fiduciary activities
NN Group commonly acts as trustee and in other fiduciary capacities that result in the holding or placing of
assets on behalf of individuals, trusts, retirement benefit plans and other institutions when conducting asset
management activities. The assets and income arising thereon are excluded from these annual accounts, as
they are not assets or income of NN Group. Fees received acting as trustee and in other fiduciary capacities
are recognised as income.
NN Group N.V. Annual Report 2024 | 256
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
2024 | 2023 | |
Changes in Cash and cash equivalents - opening balance | 8,207 | 6,670 |
Net cash flow | −1,247 | 1,609 |
Effect of foreign currency exchange differences on cash and cash equivalents | −31 | −72 |
Changes in Cash and cash equivalents - closing balance | 6,929 | 8,207 |
2024 | 2023 | |
Cash and bank balances | 3,764 | 3,888 |
Money market funds | 2,759 | 2,976 |
Short-term deposits | 406 | 1,343 |
Cash and cash equivalents | 6,929 | 8,207 |
NN Group N.V. Annual Report 2024 | 257
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
2024 | 2023 | |
Debt securities | 65,198 | 66,131 |
Equity securities | 3,110 | 3,919 |
Loans | 37,742 | 40,050 |
Investments at fair value through other comprehensive income | 106,050 | 110,100 |
NN Group N.V. Annual Report 2024 | 258
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
2024 | Debt securities | Equity securities | Loans | Total |
| Change in Investments at fair value through OCI - | ||||
opening balance | 66,131 | 3,919 | 40,050 | 110,100 |
Additions | 13,129 | 173 | 1,990 | 15,292 |
Disposals and redemptions | −12,514 | −875 | −5,500 | −18,889 |
Revaluations | −1,588 | −106 | 1,223 | −471 |
Impairments and reversal of impairments | 23 | −11 | 12 | |
Amortisation | −18 | −42 | −60 | |
Changes in the composition of the group and other changes | 14 | 14 | ||
Foreign currency exchange differences | 35 | −1 | 18 | 52 |
Change in Investments at fair value through OCI - closing balance | 65,198 | 3,110 | 37,742 | 106,050 |
2023 | Debt securities | Equity securities | Loans | Total |
| Change in Investments at fair value through OCI - | ||||
opening balance | 69,684 | 4,106 | 41,271 | 115,061 |
Additions | 15,448 | 423 | 1,986 | 17,857 |
Disposals and redemptions | −19,995 | −875 | −2,744 | −23,614 |
Revaluations | 2,580 | 245 | 952 | 3,777 |
Impairments and reversal of impairments | −50 | 4 | −46 | |
Amortisation | −69 | −55 | −124 | |
Transfers and reclassifications | −1,351 | −1,351 | ||
Changes in the composition of the group and other changes | −13 | −13 | ||
Foreign currency exchange differences | −1,467 | 20 | −1,447 | |
Change in Investments at fair value through OCI - closing balance | 66,131 | 3,919 | 40,050 | 110,100 |
Stage 1 | Stage 2 | Stage 3 | ||
| 12 month | Lifetime | Lifetime | ||
| expected credit | expected credit | expected credit | ||
| 2024 | losses | losses | losses | Total |
Impairments - Debt instruments at fair value through OCI and loans - opening balance | −82 | −15 | −67 | −164 |
Transfers between stage 1,2 and 3 | 2 | −2 | 0 | |
Additions | 38 | −13 | −13 | 12 |
Disposals | 12 | 10 | 22 | 44 |
Impairments - Debt instruments at fair value through OCI and loans - closing balance | −30 | −18 | −60 | −108 |
Stage 1 | Stage 2 | Stage 3 | ||
| 12 month | Lifetime | Lifetime | ||
| expected credit | expected credit | expected credit | ||
| 2023 | losses | losses | losses | Total |
Impairments - Debt instruments at fair value through OCI and loans - opening balance | −46 | −22 | −128 | −196 |
Transfers between stage 1,2 and 3 | 2 | 1 | −3 | 0 |
Additions | −38 | 5 | −13 | −46 |
Disposals | 1 | 77 | 78 | |
Impairments - Debt instruments at fair value through OCI and loans - closing balance | −82 | −15 | −67 | −164 |
NN Group N.V. Annual Report 2024 | 259
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
2024 | 2023 | |
Mortgage loans | 22,182 | 21,390 |
Other | 54 | 101 |
Impairments | −2 | −3 |
Investments at cost - net of impairments | 22,234 | 21,488 |
2024 | Mortgage loans | Other | Total |
Changes in Investments at cost - opening balance | 21,387 | 101 | 21,488 |
Additions | 2,540 | 76 | 2,616 |
Disposals and redemptions | −1,938 | −126 | −2,064 |
Fair value changes recognised on hedged items | 186 | 186 | |
Impairments and reversal of impairments | 1 | 1 | |
Amortisation | 3 | 3 | |
Transfers and reclassifications | 4 | 4 | |
Changes in Investments at cost - closing balance | 22,179 | 55 | 22,234 |
2023 | Mortgage loans | Other | Total |
Changes in Investments at cost - opening balance | 20,028 | 263 | 20,291 |
Additions | 2,728 | 117 | 2,845 |
Disposals and redemptions | −1,943 | −156 | −2,099 |
Fair value changes recognised on hedged items | 535 | 535 | |
Impairments and reversal of impairments | 3 | 5 | 8 |
Amortisation | −27 | −27 | |
Transfers and reclassifications | 64 | −69 | −5 |
Changes in the composition of the group and other changes | −1 | −59 | −60 |
Changes in Investments at cost - closing balance | 21,387 | 101 | 21,488 |
NN Group N.V. Annual Report 2024 | 260
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
2024 | 2023 | |
| For risk of policyholders: | ||
– debt securities | 797 | 889 |
– equity securities and investment funds | 41,999 | 36,789 |
– loans and other | 2,624 | 2,611 |
Total for risk of policyholders | 45,420 | 40,289 |
| For risk of company: | ||
– debt securities | 445 | 460 |
– equity securities and investment funds | 8,679 | 7,821 |
– loans and other | 424 | 822 |
Total for risk of company | 9,548 | 9,103 |
Investments at fair value through profit or loss | 54,968 | 49,392 |
NN Group N.V. Annual Report 2024 | 261
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
2024 | 2023 | |
Investments in real estate – opening balance | 2,620 | 2,754 |
Additions | 114 | 193 |
Transfers from (to) other assets | −3 | −1 |
Fair value gains (losses) | −13 | −276 |
Disposals | −206 | −50 |
Investments in real estate – closing balance | 2,512 | 2,620 |
2024 | 2023 | |
Most recent appraisal in current year | 100% | 100% |
100% | 100% |
2024 | 2023 | |
Investments in real estate | 2,512 | 2,620 |
Investments at fair value through profit or loss | 2,050 | 2,181 |
Investments at fair value through OCI | 369 | 348 |
Investments in associates and joint ventures | 4,586 | 4,384 |
Property and equipment – property in own use | 91 | 92 |
Real estate exposure | 9,608 | 9,625 |
NN Group N.V. Annual Report 2024 | 262
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
| Interest | Balance | Total | Total | Total | Total | |
| 2024 | held | sheet value | assets | liabilities | income | expenses |
Vesteda Residential Fund FGR | 24% | 1,757 | 10,050 | 2,779 | 1,335 | 206 |
Macquarie European Infrastructure Debt Fund | 47% | 357 | 756 | 1 | 64 | 2 |
Rivage Euro Debt infrastructure 3 | 34% | 317 | 927 | 55 | 7 | |
Nestar Residencial S.I.I. S.A. | 23% | 268 | 1,762 | 606 | 105 | 67 |
CBRE Dutch Office Fund FGR | 19% | 263 | 2,129 | 715 | 79 | 81 |
Hayfin Amber GP S.A R.L. | 100% | 253 | 347 | 94 | 22 | 3 |
CBRE Dutch Residential Fund I FGR | 8% | 250 | 3,161 | 140 | 340 | 39 |
CBRE Retail Property Fund Iberica L.P. | 50% | 225 | 988 | 537 | 109 | 36 |
Rivage Hopitaux Publics Euro | 34% | 207 | 600 | 17 | 6 | |
Ardstone Residential Partners III | 29% | 203 | 1,068 | 363 | 33 | 28 |
NRP Nordic Logistic Fund SA | 42% | 187 | 474 | 30 | 22 | 5 |
Healthcare Activos SOCIMI S.A. | 38% | 177 | 883 | 416 | 35 | 26 |
| Rivage Priv. Debt – Fund for Infrastructure | ||||||
Climate Solutions | 100% | 168 | 169 | 1 | 14 | 2 |
Dutch Urban Living Venture FGR | 49% | 160 | 478 | 155 | 66 | 12 |
Rivage Euro Debt Infrastructure High return 2 | 34% | 153 | 454 | 37 | 8 | |
| Dutch Student and Young Professional Housing | ||||||
Fund FGR | 49% | 143 | 370 | 81 | 45 | 8 |
CBRE Dutch Retail Fund FGR | 22% | 126 | 790 | 223 | 11 | 25 |
Allee center Kft | 50% | 116 | 251 | 19 | 20 | 12 |
Fiumaranuova s.r.l. | 50% | 98 | 202 | 6 | 18 | 8 |
Macquarie Climate Inv Debt. | 58% | 95 | 163 | 4 | 1 | |
| Bentall Green Oak Europe Secured Lending III | ||||||
SLP | 33% | 92 | 413 | 129 | 13 | 8 |
Octopus Commercial Real Estate Debt Fund III LP | 46% | 90 | 219 | 21 | 13 | 3 |
Prime Ventures V.C.V. | 18% | 89 | 501 | 0 | −12 | 5 |
DPE Deutschland III (Parallel) GmbH & Co | 17% | 81 | 676 | 201 | 214 | 2 |
CBRE UK Property Fund PAIF | 8% | 80 | 1,035 | 14 | 16 −5 |
NN Group N.V. Annual Report 2024 | 263
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
| Interest | Balance | Total | Total | Total | Total | |
| 2023 | held | sheet value | assets | liabilities | income | expenses |
Vesteda Residential Fund FGR | 24% | 1,545 | 8,982 | 2,590 | −481 | 176 |
Rivage Euro Debt infrastructure 3 | 34% | 313 | 917 | 1 | ||
Macquarie European Infrastructure Debt Fund | 50% | 289 | 583 | 7 | ||
CBRE Dutch Office Fund FGR | 19% | 273 | 2,214 | 745 | −370 | 90 |
Nestar Residencial S.I.I. S.A. | 23% | 267 | 1,693 | 538 | 87 | 71 |
CBRE Retail Property Fund Iberica L.P. | 50% | 221 | 971 | 528 | 72 | 37 |
CBRE Dutch Residential Fund I FGR | 7% | 209 | 3,013 | 136 | −269 | 43 |
Ardstone Residential Partners III | 30% | 208 | 1,031 | 335 | 29 | 20 |
Hayfin Amber GP S.A R.L. | 100% | 205 | 376 | 171 | ||
NRP Nordic Logistic Fund SA | 42% | 194 | 493 | 31 | 10 | 5 |
Healthcare Activos SOCIMI S.A. | 38% | 177 | 855 | 387 | 33 | 20 |
CBRE Dutch Retail Fund FGR | 21% | 150 | 996 | 282 | −47 | 21 |
Dutch Urban Living Venture FGR | 49% | 138 | 434 | 156 | −39 | 7 |
Rivage Hopitaux Publics Euro | 34% | 133 | 389 | 3 | ||
| Dutch Student and Young Professional Housing | ||||||
Fund FGR | 49% | 130 | 342 | 78 | −9 | 6 |
Allee center Kft | 50% | 118 | 257 | 20 | 21 | 7 |
CBRE UK Property Fund PAIF | 9% | 112 | 1,309 | 37 | 21 | −1 |
NN Group N.V. Annual Report 2024 | 264
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
2024 | 2023 | |
Investments in associates and joint ventures – opening balance | 6,231 | 6,450 |
Additions | 706 | 507 |
Transfers from (to) investments at fair value through OCI | −3 | |
Share in changes in equity (revaluations) | −9 | |
Share of result | 579 | −237 |
Dividends received | −250 | −244 |
Disposals | −244 | −259 |
Foreign currency exchange differences | 17 | 23 |
Investments in associates and joint ventures – closing balance | 7,036 | 6,231 |
NN Group N.V. Annual Report 2024 | 265
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
2024 | 2023 | |
Property in own use | 91 | 92 |
Equipment | 59 | 82 |
Property and equipment owned | 150 | 174 |
Right of use assets | 152 | 174 |
Property and equipment total | 302 | 348 |
2024 | 2023 | |
Property in own use – opening balance | 92 | 97 |
Additions | 3 | 3 |
Revaluations | 2 | −2 |
Disposals | −6 | |
Depreciation | −2 | −2 |
Impairments | −6 | |
Changes in the composition of the group and other changes | 2 | 2 |
Property in own use – closing balance | 91 | 92 |
Gross carrying value | 150 | 146 |
Accumulated depreciation, revaluations and impairments | −59 | −54 |
Net carrying value | 91 | 92 |
Revaluation surplus – opening balance | 14 | 16 |
Revaluation in year | 2 | −2 |
Revaluation surplus – closing balance | 16 | 14 |
| Data processing | Fixtures and fittings and | |||||
| equipment | other equipment | Total | ||||
2024 | 2023 | 2024 | 2023 | 2024 | 2023 | |
Equipment – opening balance | 33 | 30 | 49 | 70 | 82 | 100 |
Additions | 8 | 20 | 24 | 6 | 32 | 26 |
Disposals | −18 | −1 | −18 | −1 | ||
Depreciation | −17 | −14 | −20 | −20 | −37 | −34 |
Changes in the composition of the group and other changes | −3 | −6 | 0 | −9 | ||
Equipment – closing balance | 24 | 33 | 35 | 49 | 59 | 82 |
Gross carrying value | 204 | 196 | 272 | 266 | 476 | 462 |
Accumulated depreciation | −180 | −163 | −237 | −217 | −417 | −380 |
Net carrying value | 24 | 33 | 35 | 49 | 59 | 82 |
Property | Equipment | Total | ||||
2024 | 2023 | 2024 | 2023 | 2024 | 2023 | |
Right of use assets – opening balance | 155 | 183 | 19 | 19 | 174 | 202 |
Additions | 9 | 15 | 17 | 12 | 26 | 27 |
Disposals | −2 | −11 | −2 | −1 | −4 | −12 |
Depreciation | −31 | −35 | −12 | −11 | −43 | −46 |
Changes in the composition of the group and other changes | 7 | 1 | 1 | 7 | ||
Foreign currency exchange differences | −2 | −4 | −2 | −4 | ||
Right of use assets – closing balance | 129 | 155 | 23 | 19 | 152 | 174 |
Gross carrying value | 355 | 350 | 92 | 76 | 447 | 426 |
Accumulated depreciation | −226 | −195 | −69 | −57 | −295 | −252 |
Net carrying value | 129 | 155 | 23 | 19 | 152 | 174 |
NN Group N.V. Annual Report 2024 | 266
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
NN Group N.V. Annual Report 2024 | 267
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
2024 | Goodwill | Software | Other | Total |
Intangible assets – opening balance | 892 | 79 | 299 | 1,270 |
Additions | 36 | 3 | 39 | |
Amortisation | −37 | −38 | −75 | |
Disposals | −6 | −6 | ||
Changes in the composition of the group and other changes | −26 | 24 | −2 | |
Foreign currency exchange differences | 3 | 3 | ||
Intangible assets – closing balance | 869 | 72 | 288 | 1,229 |
Gross carrying value | 1,842 | 1,030 | 871 | 3,743 |
Accumulated amortisation | −888 | −533 | −1,421 | |
Accumulated impairments | −973 | −70 | −50 | −1,093 |
Net carrying value | 869 | 72 | 288 | 1,229 |
2023 | Goodwill | Software | Other | Total |
Intangible assets – opening balance | 871 | 91 | 318 | 1,280 |
Additions | 12 | 29 | 18 | 59 |
Amortisation | −35 | −35 | −70 | |
Disposals | −3 | −3 | ||
Impairments | −3 | −2 | −5 | |
Foreign currency exchange differences | 9 | 9 | ||
Intangible assets – closing balance | 892 | 79 | 299 | 1,270 |
Gross carrying value | 1,865 | 1,000 | 844 | 3,709 |
Accumulated amortisation | −851 | −495 | −1,346 | |
Accumulated impairments | −973 | −70 | −50 | −1,093 |
Net carrying value | 892 | 79 | 299 | 1,270 |
2024 | 2023 | |
Netherlands Non-life | 434 | 460 |
Insurance Europe | 373 | 370 |
Banking | 62 | 62 |
Goodwill | 869 | 892 |
2024 | 2023 | |
Income tax receivable | 446 | 251 |
Accrued interest and rents | 1,474 | 1,414 |
Other accrued assets | 219 | 228 |
Cash collateral amounts paid | 2,584 | 3,000 |
Other | 525 | 672 |
Other assets | 5,248 | 5,565 |
NN Group N.V. Annual Report 2024 | 268
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
2024 | 2023 | |
Share capital | 32 | 34 |
Share premium | 12,581 | 12,579 |
Accumulated revaluations on investments | −3,865 | −4,116 |
Accumulated revaluations on (re) insurance contracts | 12,901 | 13,313 |
Foreign currency translation reserve | −487 | −421 |
Net defined benefit asset/liability remeasurement reserve | −55 | −63 |
Other reserves | −1,276 | −1,702 |
Shareholders' equity (parent) | 19,831 | 19,624 |
Minority interests | 85 | 79 |
Undated subordinated notes | 1,736 | 1,416 |
Total equity | 21,652 | 21,119 |
| Total | ||||
| shareholders' | ||||
| Share | Share | equity | ||
| 2024 | capital | premium | Reserves | (parent) |
Shareholders' equity (parent) – opening balance | 34 | 12,579 | 7,011 | 19,624 |
Total amount recognised directly in equity (other comprehensive income) | 25 | 25 | ||
Net result for the year | 1,583 | 1,583 | ||
Changes in share capital | −2 | 2 | 0 | |
Dividend | −680 | −680 | ||
Purchase (sale) of treasury shares | −529 | −529 | ||
Employee stock option and share plans | 1 | 1 | ||
Coupon on undated subordinated notes | −62 | −62 | ||
Changes in the composition of the group and other changes | −131 | −131 | ||
Shareholders' equity (parent) – closing balance | 32 | 12,581 | 7,218 | 19,831 |
| Total | ||||
| shareholders' | ||||
| Share | Share | equity | ||
| 2023 | capital | premium | Reserves | (parent) |
Shareholders' equity (parent) – opening balance | 35 | 12,578 | 6,652 | 19,265 |
Total amount recognised directly in equity (other comprehensive income) | 312 | 312 | ||
Net result for the year | 1,172 | 1,172 | ||
Changes in share capital | −1 | 1 | 0 | |
Dividend | −422 | −422 | ||
Purchase (sale) of treasury shares | −632 | −632 | ||
Employee stock option and share plans | 1 | 1 | ||
Coupon on undated subordinated notes | −57 | −57 | ||
Changes in the composition of the group and other changes | −15 | −15 | ||
Shareholders' equity (parent) – closing balance | 34 | 12,579 | 7,011 | 19,624 |
NN Group N.V. Annual Report 2024 | 269
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
| Share capital | Ordinary shares | |||
| Ordinary shares (in number) | (Amounts in millions of euros) | |||
2024 | 2023 | 2024 | 2023 | |
Authorised share capital | 700,000,000 | 700,000,000 | 84 | 84 |
Unissued share capital | 431,000,000 | 415,000,000 | 52 | 50 |
Issued share capital | 269,000,000 | 285,000,000 | 32 | 34 |
2024 | 2023 | |
Share premium – opening balance | 12,579 | 12,578 |
Issue of ordinary shares | 2 | 1 |
Share premium – closing balance | 12,581 | 12,579 |
| Changes in Accumulated revaluations investments (2024) | ||||
| Property | Investment | Cash flow | ||
| revaluation | revaluation | hedge | ||
| 2024 | reserve | reserve | reserve | Total |
Revaluation reserve – opening balance | 10 | −6,967 | 2,841 | −4,116 |
Revaluations | −303 | −303 | ||
| Realised gains / losses transferred to the profit and loss | ||||
account | 757 | 757 | ||
Realised gains / losses on equity securities | −244 | −244 | ||
Changes in cash flow hedge reserve | 44 | 44 | ||
Other revaluations | −2 | −2 | ||
Revaluation reserve – closing balance | 10 | −6,759 | 2,885 | −3,864 |
NN Group N.V. Annual Report 2024 | 270
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
| Changes in Accumulated revaluations investments (2023) | ||||
| Property | Investment | Cash flow | ||
| revaluation | revaluation | hedge | ||
| 2023 | reserve | reserve | reserve | Total |
Revaluation reserve – opening balance | 11 | −10,037 | 2,894 | −7,132 |
Revaluations | −1 | 2,868 | 2,867 | |
| Realised gains / losses transferred to the profit and loss | ||||
account | 249 | 249 | ||
Realised gains / losses on equity securities | −38 | −38 | ||
Changes in cash flow hedge reserve | −53 | −53 | ||
Other revaluations | −9 | −9 | ||
Revaluation reserve – closing balance | 10 | −6,967 | 2,841 | −4,116 |
2024 | 2023 | |
Revaluation reserve – opening balance | 13,313 | 15,962 |
Finance result on insurance contracts recognised in other comprehensive income | −447 | −2,634 |
Finance result on reinsurance contracts recognised in other comprehensive income | 35 | −15 |
Revaluation reserve – closing balance | 12,901 | 13,313 |
2024 | 2023 | |
Foreign currency translation reserve – opening balance | −421 | −338 |
Unrealised revaluations after taxation | −23 | −24 |
Foreign currency exchange differences for the year | −43 | −59 |
Foreign currency translation reserve – closing balance | −487 | −421 |
| Changes in Other reserves (2024) | |||
| Share of | |||
| Retained | associates | ||
| 2024 | earnings | reserve | Total |
Other reserves – opening balance | −3,018 | 1,316 | −1,702 |
Net result for the year | 1,583 | 1,583 | |
Transfers from (to) share of associates reserve | −344 | 344 | 0 |
Realised gains / losses on equity securities | 243 | 243 | |
Dividend | −680 | −680 | |
Purchase (sale) of treasury shares | −529 | −529 | |
Employee stock option and share plans | 1 | 1 | |
Coupon on subordinated notes | −62 | −62 | |
Changes in the composition of the group and other changes | −131 | −131 | |
Other reserves – closing balance | −2,937 | 1,660 | −1,277 |
| Changes in Other reserves (2023) | |||
| Share of | |||
| Retained | associates | ||
| 2023 | earnings | reserve | Total |
Other reserves – opening balance | −3,601 | 1,812 | −1,789 |
Net result for the year | 1,172 | 1,172 | |
Transfers from (to) share of associates reserve | 496 | −496 | 0 |
Realised gains / losses on equity securities | 39 | 39 | |
Dividend | −422 | −422 | |
Purchase (sale) of treasury shares | −632 | −632 | |
Employee stock option and share plans | 1 | 1 | |
Coupon on subordinated notes | −57 | −57 | |
Changes in the composition of the group and other changes | −14 | −14 | |
Other reserves – closing balance | −3,018 | 1,316 | −1,702 |
NN Group N.V. Annual Report 2024 | 271
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
Dividends
2024 | 2023 | |
Dividend paid in cash (interim current year) | 347 | 164 |
Dividend paid in cash (final previous year) | 334 | 258 |
Stock dividend (interim current year) | 146 | |
Stock dividend (final previous year) | 232 | 236 |
Total dividend | 913 | 804 |
Interim dividend 2024
In September 2024, NN Group paid an interim dividend of EUR 1.28 per ordinary share, or approximately
EUR 347 million in total based on the number of shares outstanding at the date of announcement (net of
treasury shares), calculated as 40% of the 2023 full-year dividend per ordinary share in accordance with the
NN Group dividend policy. The interim dividend was paid fully in cash, after deduction of withholding tax if
applicable.
Proposed final dividend 2024
At the Annual General Meeting on 15 May 2025, a final dividend will be proposed of EUR 2.1 6 per ordinary
share, or approximately EUR 578 million in total based on the current number of outstanding shares (net of
treasury shares). The final dividend will be paid in cash, after deduction of withholding tax if applicable. The
final dividend is subject to adoption by the General Meeting at the annual general meeting to be held on
15 May 2025.
Interim dividend 2023
In September 2023, NN Group paid an interim dividend of EUR 1.12 per ordinary share, or approximately
EUR 309 million in total based on the number of shares outstanding at the date of announcement (net of
treasury shares). The interim dividend was paid either in cash, after deduction of withholding tax if
applicable, or in ordinary shares, at the election of the shareholders. Dividends paid in the form of ordinary
shares were delivered from NN Group treasury shares. To neutralise the dilutive effect of the stock dividend,
NN Group repurchases ordinary shares for an amount equivalent to the value of the stock dividend. The cash
dividend was distributed out of Other reserves.
Final dividend 2023
On 24 May 2024, the General Meeting adopted the proposed final dividend of EUR 2.08 per ordinary share, or
approximately EUR 570 million in total. Together with the 2023 interim dividend of EUR 1.12 per ordinary
share paid in September 2023, NN Group’s total dividend for 2023 was EUR 3.20 per ordinary share. The
final dividend was paid either fully in cash, after deduction of withholding tax if applicable, or fully in ordinary
shares, at the election of the shareholders. Dividends paid in the form of ordinary shares were delivered from
NN Group treasury shares or issued at the expense of the share premium reserve. To neutralise the dilutive
effect of the stock dividend, NN Group repurchases ordinary shares for an amount equivalent to the stock
dividend. The cash dividend was distributed out of Other reserves.
Undated subordinated notes
In March 2024, NN Group announced a tender for purchase by NN Group of the EUR 750 million Fixed to
Floating Rate Undated Subordinated Notes for cash at a price of 100.1% of the nominal amount. The tender
was completed in March 2024 and NN Group accepted the purchase of EUR 287 million in nominal amount. In
June 2024, NN Group additionally redeemed EUR 128 million of the EUR 750 million Fixed to Floating Rate
Undated Subordinated Notes.
In March 2024, NN Group issued euro-denominated, perpetual, restricted Tier 1, temporary write-down
securities for an amount of EUR 750 million. The notes are first callable as from 12 September 2030. The
coupon is fixed at 6.375% per annum until 12 March 2031 and will be reset every fifth year thereafter. These
securities are classified as equity under IFRS-EU. Coupon payments are distributed out of equity if and when
paid or contractually due.
In April 2023 NN Group announced a tender for purchase by NN Group for cash of outstanding subordinated
notes. The tender was completed in May 2023 and NN Group accepted the purchase of EUR 1 billion in
nominal amount. This includes EUR 665 million of subordinated notes previously classified as liabilities in the
balance sheet and EUR 335 million previously classified in equity. Reference is made to Note 16
‘Subordinated debt’.
NN Group N.V. Annual Report 2024 | 272
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
In July 2014, NN Group N.V. issued fixed to floating rate undated subordinated notes with a par value of
EUR 1,000 million. The notes are undated, but are callable after 11.5 years and every quarter thereafter
(subject to regulatory approval). The coupon is fixed at 4.5% per annum for the first 11.5 years and will be
floating thereafter. As these notes are undated and include optional deferral of interest at the discretion of
NN Group, these are classified under IFRS-EU as equity. Coupon payments are distributed out of equity if and
when paid or contractually due. The discount to the par value and certain issue costs were deducted from
equity at issue, resulting in a balance sheet value equal to the net proceeds of EUR 986 million.
In June 2014, fixed to floating rate undated subordinated notes with a par value of EUR 750 million were
originally issued by Delta Lloyd which are classified as equity under IFRS-EU. The notes are undated, but are
callable as from 13 June 2024 and every quarter thereafter (subject to regulatory approval). The coupon is
fixed at 4.375% per annum until 13 June 2024 and will be floating thereafter. Coupon payments are
distributed out of equity if and when paid or contractually due. These notes were recognised upon
acquisition of Delta Lloyd for an amount of EUR 778 million.
NN Group N.V. Annual Report 2024 | 273
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
NN Group N.V. Annual Report 2024 | 274
Consolidated annual accounts
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
NN Group N.V. Annual Report 2024 | 275
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
General Model | Variable Fee Approach | |||
2024 | 2023 | 2024 | 2023 | |
1 year | 3.2% | 4.1% | 2.3% | 3.4% |
5 years | 3.1% | 3.1% | 2.2% | 2.4% |
10 years | 3.2% | 3.2% | 2.3% | 2.5% |
20 years | 3.2% | 3.2% | 2.3% | 2.5% |
30 years | 2.9% | 2.9% | 2.1% | 2.2% |
40 years | 2.9% | 2.9% | 2.1% | 2.3% |
One year view | Ultimate view | |||
2024 | 2023 | 2024 | 2023 | |
Life | 89% | 90% | 69% | 69% |
Non-life | 69% | 70% | 62% | 64% |
| Total General | |||||
| Model and | Premium | ||||
| Variable Fee | Variable Fee | Allocation | |||
2024 | General Model | Approach | Approach | Approach | Total |
Life Insurance contracts for risk of company | 95,796 | 1,953 | 97,749 | 1 | 97,750 |
Life Insurance contracts for risk of policyholders | 6,239 | 36,523 | 42,762 | 42,762 | |
Life insurance contracts | 102,035 | 38,476 | 140,511 | 1 | 140,512 |
| Non-life contracts for remaining | |||||
coverage | 3,948 | 3,948 | 225 | 4,173 | |
| Non-life contracts for incurred claims | |||||
and benefits | 111 | 111 | 2,336 | 2,447 | |
Non-life insurance contracts | 4,059 | 0 | 4,059 | 2,561 | 6,620 |
Total insurance contracts | 106,094 | 38,476 | 144,570 | 2,562 | 147,132 |
– of which presented as assets | 409 | 409 | 409 | ||
– of which presented as liabilities | 106,503 | 38,476 | 144,979 | 2,562 | 147,541 |
Total insurance contracts | 106,094 | 38,476 | 144,570 | 2,562 | 147,132 |
NN Group N.V. Annual Report 2024 | 276
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
| Total General | |||||
| Model and | Premium | ||||
| Variable Fee | Variable Fee | Allocation | |||
2023 | General Model | Approach | Approach | Approach | Total |
Life Insurance contracts for risk of company | 98,489 | 1,760 | 100,249 | 100,249 | |
Life Insurance contracts for risk of policyholders | 6,137 | 31,819 | 37,956 | 37,956 | |
Life insurance contracts | 104,626 | 33,579 | 138,205 | 0 | 138,205 |
| Non-life contracts for remaining | |||||
coverage | 3,706 | 3,706 | 221 | 3,927 | |
| Non-life contracts for incurred claims | |||||
and benefits | 241 | 241 | 2,336 | 2,577 | |
Non-life insurance contracts | 3,947 | 0 | 3,947 | 2,557 | 6,504 |
Total insurance contracts | 108,573 | 33,579 | 142,152 | 2,557 | 144,709 |
– of which presented as assets | 355 | 355 | 355 | ||
– of which presented as liabilities | 108,928 | 33,579 | 142,507 | 2,557 | 145,064 |
Total insurance contracts | 108,573 | 33,579 | 142,152 | 2,557 | 144,709 |
| Total General | ||||
| Estimates of the | Risk adjustment | Model and | ||
| present value of | for non-financial | Contractual | Variable Fee | |
| 2024 | future cash flows | risk | service margin | Approach |
– opening balance presented as assets | 778 | −70 | −353 | 355 |
– opening balance presented as liabilities | 134,158 | 1,730 | 6,619 | 142,507 |
Net opening balance | 133,380 | 1,800 | 6,972 | 142,152 |
– insurance contracts initially recognised in the year | −709 | 101 | 659 | 51 |
| – changes in estimates that adjust the contractual | ||||
service margin | −475 | −630 | 1,105 | 0 |
– changes in estimates that do not adjust the contractual service margin | −2 | −76 | −78 | |
Changes that relate to future service | −1,186 | −605 | 1,764 | −27 |
NN Group N.V. Annual Report 2024 | 277
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
| Total General | ||||
| Estimates of the | Risk adjustment | Model and | ||
| present value of | for non-financial | Contractual | Variable Fee | |
| 2023 | future cash flows | risk | service margin | Approach |
– opening balance presented as assets | 348 | −26 | −198 | 124 |
– opening balance presented as liabilities | 129,854 | 1,603 | 6,652 | 138,109 |
Net opening balance | 129,506 | 1,629 | 6,850 | 137,985 |
– insurance contracts initially recognised in the year | −709 | 73 | 673 | 37 |
| – changes in estimates that adjust the contractual | ||||
service margin | −293 | 102 | 191 | 0 |
– changes in estimates that do not adjust the contractual service margin | 116 | 83 | 199 | |
Changes that relate to future service | −886 | 258 | 864 | 236 |
– release to profit or loss | −168 | −778 | −946 | |
| – experience adjustments not adjusting the contractual | ||||
service margin | 1 | 1 | ||
Changes that relate to current service | 1 | −168 | −778 | −945 |
| – changes in incurred claims and benefits previous | ||||
periods | 18 | 18 | ||
Changes that relate to past service | 18 | 0 | 0 | 18 |
– finance result through profit or loss | 5,823 | 38 | 67 | 5,928 |
– finance result recognised in OCI | 3,439 | 51 | 3,490 | |
Finance result on insurance contracts | 9,262 | 89 | 67 | 9,418 |
– premiums received | 10,346 | 10,346 | ||
– acquisition costs paid | −593 | −593 | ||
– claims, benefits and attributable expenses paid | −12,975 | −12,975 | ||
– changes in the composition of the group and other changes | 95 | 1 | 96 | |
Cash flows | −3,127 | 1 | 0 | −3,126 |
| Total Insurance | ||||
| Onerous | Insurance | contracts | ||
| Insurance | Other Insurance | contracts | initially | |
| 2024 | contracts issued | contracts issued | acquired | recognised |
Estimates of the present value of future cash inflows | −719 | −6,876 | −7,595 | |
– acquisition costs | 31 | 508 | 539 | |
– claims, benefits and attributable expenses | 732 | 5,615 | 6,347 | |
| Estimates of the present value of future cash | ||||
outflows | 763 | 6,123 | 0 | 6,886 |
Risk adjustment | 7 | 94 | 101 | |
Contractual service margin | 659 | 659 | ||
Total insurance contracts initially recognised in the year | 51 | 0 | 0 | 51 |
NN Group N.V. Annual Report 2024 | 278
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
| Total Insurance | ||||
| Onerous | Insurance | contracts | ||
| Insurance | Other Insurance | contracts | initially | |
| 2023 | contracts issued | contracts issued | acquired | recognised |
Estimates of the present value of future cash inflows | −760 | −5,700 | −6,460 | |
– acquisition costs | 56 | 437 | 493 | |
– claims, benefits and attributable expenses | 735 | 4,523 | 5,258 | |
| Estimates of the present value of future cash | ||||
outflows | 791 | 4,960 | 0 | 5,751 |
Risk adjustment | 6 | 67 | 73 | |
Contractual service margin | 673 | 673 | ||
Total insurance contracts initially recognised in the year | 37 | 0 | 0 | 37 |
| Composition of underlying items for insurance contracts | ||
Fair value of underlying items | 2024 | 2023 |
– debt securities | 766 | 856 |
– equity securities and investment funds | 39,534 | 33,785 |
– loans and other | 2,462 | 3,315 |
Total | 42,762 | 37,956 |
| Contract issued | ||||
| after transition | Total General | |||
| and full | Modified | Model and | ||
| retrospective | retrospective | Fair value | Variable Fee | |
| 2024 | approach | approach | approach | Approach |
Disaggregation of the contractual service margin by transition approach - opening balance | 1,983 | 824 | 4,165 | 6,972 |
– insurance contracts initially recognised in the year | 659 | 659 | ||
| – changes in estimates that adjust the contractual | ||||
service margin | 213 | 69 | 823 | 1,105 |
Changes that relate to future service | 872 | 69 | 823 | 1,764 |
– release to profit or loss | −365 | −138 | −354 | −857 |
Changes that relate to current service | −365 | −138 | −354 | −857 |
Finance result through profit or loss | 40 | 9 | 31 | 80 |
Other movements | 16 | 31 | 47 | |
Foreign currency exchange differences | −38 | −9 | −9 | −56 |
Disaggregation of the contractual service margin by transition approach - closing balance | 2,508 | 755 | 4,687 | 7,950 |
NN Group N.V. Annual Report 2024 | 279
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
| Disaggregation of contractual service margin by transition approach (2023) | ||||
| Contract issued | ||||
| after transition | Total General | |||
| and full | Modified | Model and | ||
| retrospective | retrospective | Fair value | Variable Fee | |
| 2023 | approach | approach | approach | Approach |
Disaggregation of the contractual service margin by transition approach - opening balance | 1,707 | 977 | 4,166 | 6,850 |
– insurance contracts initially recognised in the year | 673 | 673 | ||
| – changes in estimates that adjust the contractual | ||||
service margin | −50 | 12 | 229 | 191 |
Changes that relate to future service | 623 | 12 | 229 | 864 |
– release to profit or loss | −335 | −154 | −289 | −778 |
Changes that relate to current service | −335 | −154 | −289 | −778 |
Finance result through profit or loss | 27 | 9 | 31 | 67 |
Other movements | 7 | 41 | 48 | |
Foreign currency exchange differences | −46 | −20 | −13 | −79 |
Disaggregation of the contractual service margin by transition approach - closing balance | 1,983 | 824 | 4,165 | 6,972 |
2024 | 2023 | |
Less than 1 year | 687 | 698 |
1-2 years | 590 | 586 |
2-3 years | 529 | 528 |
3-4 years | 479 | 479 |
4-5 years | 440 | 436 |
5-10 years | 1,627 | 1,638 |
Over 10 years | 3,598 | 2,607 |
Total | 7,950 | 6,972 |
| Liabilities for remaining coverage and incurred claims and benefits (2024) | Total General | |||
| Liability for | Model and | |||
| incurred claims | Variable Fee | |||
| Liability for remaining coverage | and benefits | Approach | ||
| Remaining | ||||
| 2024 | coverage | Loss component | ||
– opening balance presented as assets | 391 | −6 | −30 | 355 |
– opening balance presented as liabilities | 140,190 | 315 | 2,002 | 142,507 |
Net opening balance | 139,799 | 321 | 2,032 | 142,152 |
– release of contractual service margin | −857 | −857 | ||
– release of risk adjustment | −134 | −134 | ||
– expected claims and benefits | −5,139 | −5,139 | ||
– expected attributable expenses | −1,280 | −1,280 | ||
– recovery of acquisition costs | −415 | −415 | ||
– experience adjustments for premiums relating to current or past service | −18 | −18 | ||
Insurance income | −7,843 | 0 | 0 | −7,843 |
– incurred claims and benefits | 5,110 | 5,110 | ||
– incurred attributable expenses | 1,298 | 1,298 | ||
– amortisation of acquisition costs | 415 | 415 | ||
| – changes in incurred claims and benefits previous | ||||
periods | −17 | −17 | ||
– (reversal of) losses on onerous contracts | −45 | −45 | ||
Insurance expenses | 415 | −45 | 6,391 | 6,761 |
| Investment components excluded from insurance | ||||
expenses and insurance income | −6,894 | 6,894 | 0 | |
NN Group N.V. Annual Report 2024 | 280
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Notes to the Consolidated annual accounts continued
| Liabilities for remaining coverage and incurred claims and benefits (2023) | Total General | |||
| Liability for | Model and | |||
| incurred claims | Variable Fee | |||
| Liability for remaining coverage | and benefits | Approach | ||
| Remaining | ||||
| 2023 | coverage | Loss component | ||
– opening balance presented as assets | 135 | −1 | −10 | 124 |
– opening balance presented as liabilities | 136,143 | 111 | 1,855 | 138,109 |
Net opening balance | 136,008 | 112 | 1,865 | 137,985 |
– release of contractual service margin | −778 | −778 | ||
– release of risk adjustment | −168 | −168 | ||
– expected claims and benefits | −5,104 | −5,104 | ||
– expected attributable expenses | −1,237 | −1,237 | ||
– recovery of acquisition costs | −363 | −363 | ||
– experience adjustments for premiums relating to current or past service | −12 | −12 | ||
– other insurance income | 3 | 3 | ||
Insurance income | −7,659 | 0 | 0 | −7,659 |
– incurred claims and benefits | 5,126 | 5,126 | ||
– incurred attributable expenses | 1,250 | 1,250 | ||
– amortisation of acquisition costs | 363 | 363 | ||
| – changes in incurred claims and benefits previous | ||||
periods | 18 | 18 | ||
– (reversal of) losses on onerous contracts | 209 | 209 | ||
– other insurance expenses | 2 | 2 | ||
Insurance expenses | 365 | 209 | 6,394 | 6,968 |
| Investment components excluded from insurance | ||||
expenses and insurance income | −6,738 | 6,738 | 0 | |
– finance result through profit or loss | 5,915 | 1 | 12 | 5,928 |
– finance result recognised in OCI | 3,499 | −9 | 3,490 | |
Finance result on insurance contracts | 9,414 | 1 | 3 | 9,418 |
NN Group N.V. Annual Report 2024 | 281
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
| Total Premium | |||||
| Liability for incurred claims and | Allocation | ||||
| Liability for remaining coverage | benefits | Approach | |||
| Estimates of the | |||||
| Remaining | present value of | ||||
| 2024 | coverage | Loss component | future cash flows | Risk adjustment | |
– opening balance presented as assets | 0 | ||||
– opening balance presented as liabilities | 217 | 2 | 2,295 | 43 | 2,557 |
Net opening balance | 217 | 2 | 2,295 | 43 | 2,557 |
Insurance income | −2,863 | −2,863 | |||
– incurred claims and benefits | 1,498 | 4 | 1,502 | ||
– incurred attributable expenses | 922 | 922 | |||
– amortisation of acquisition costs | 5 | 5 | |||
| – changes in incurred claims and benefits | |||||
previous periods | 55 | −9 | 46 | ||
– other insurance expenses | 1 | 1 | |||
Insurance expenses | 5 | 0 | 2,476 | −5 | 2,476 |
– finance result through profit or loss | 30 | 30 | |||
– finance result recognised in OCI | 44 | 44 | |||
Finance result on insurance contracts | 0 | 0 | 74 | 0 | 74 |
– premiums received | 2,872 | 2,872 | |||
– acquisition costs paid | −5 | −5 | |||
| – claims, benefits and attributable | |||||
expenses paid | −2,549 | −2,549 | |||
Cash flows | 2,867 | 0 | −2,549 | 0 | 318 |
Foreign currency exchange differences | −1 | −1 | 2 | 0 | |
Net closing balance | 225 | 2 | 2,295 | 40 | 2,562 |
– closing balance presented as assets | 0 | ||||
– closing balance presented as liabilities | 225 | 2 | 2,295 | 40 | 2,562 |
Net closing balance | 225 | 2 | 2,295 | 40 | 2,562 |
NN Group N.V. Annual Report 2024 | 282
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Notes to the Consolidated annual accounts continued
| Total Premium | |||||
| Liability for incurred claims and | Allocation | ||||
| Liability for remaining coverage | benefits | Approach | |||
| Estimates of the | |||||
| Remaining | present value of | ||||
| 2023 | coverage | Loss component | future cash flows | Risk adjustment | |
– opening balance presented as assets | 0 | ||||
– opening balance presented as liabilities | 193 | 9 | 2,421 | 67 | 2,690 |
Net opening balance | 193 | 9 | 2,421 | 67 | 2,690 |
Insurance income | −2,791 | −2,791 | |||
– incurred claims and benefits | 1,398 | 4 | 1,402 | ||
– incurred attributable expenses | 897 | 897 | |||
– amortisation of acquisition costs | 6 | 6 | |||
| – changes in incurred claims and benefits | |||||
previous periods | −2 | −27 | −29 | ||
| – (reversal of) losses on onerous | |||||
contracts | −8 | −8 | |||
– other insurance expenses | 1 | 1 | |||
Insurance expenses | 6 | −8 | 2,294 | −23 | 2,269 |
– finance result through profit or loss | 1 | 23 | 24 | ||
– finance result recognised in OCI | 76 | 1 | 77 | ||
Finance result on insurance contracts | 0 | 1 | 99 | 1 | 101 |
– premiums received | 2,840 | 2,840 | |||
– acquisition costs paid | −6 | −6 | |||
| – claims, benefits and attributable | |||||
expenses paid | −2,451 | −2,451 | |||
| – changes in the composition of the group | |||||
and other changes | −25 | −70 | −1 | −96 | |
Cash flows | 2,809 | 0 | −2,521 | −1 | 287 |
NN Group N.V. Annual Report 2024 | 283
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Notes to the Consolidated annual accounts continued
| Gross claims development table 2024 | ||||||||
| Accident year | ||||||||
2018 1 | 2019 | 2020 | 2021 | 2022 | 2023 | 2024 | Total | |
| Estimate of cumulative claims | ||||||||
At the end of accident year | 1,358 | 1,217 | 1,535 | 1,378 | 1,556 | 1,410 | 1,557 | |
1 year later | 1,341 | 1,324 | 1,436 | 1,364 | 1,515 | 1,523 | ||
2 years later | 1,403 | 1,332 | 1,440 | 1,310 | 1,520 | |||
3 years later | 1,437 | 1,338 | 1,380 | 1,314 | ||||
4 years later | 1,401 | 1,323 | 1,380 | |||||
5 years later | 1,372 | 1,321 | ||||||
6 years later | 1,381 | |||||||
Estimate of cumulative claims | 1,381 | 1,321 | 1,380 | 1,314 | 1,520 | 1,523 | 1,557 | 9,996 |
Cumulative payments | −1,286 | −1,193 | −1,226 | −1,132 | −1,251 | −1,135 | −757 | −7,980 |
95 | 128 | 154 | 182 | 269 | 388 | 800 | 2,016 | |
Effect of discounting | −9 | −12 | −15 | −17 | −25 | −36 | −51 | −165 |
Liabilities recognised | 86 | 116 | 139 | 165 | 244 | 352 | 749 | 1,851 |
Liabilities relating to accident years prior to 2018 and liability for incurred expenses | 358 | |||||||
LIC expenses | 85 | |||||||
Risk adjustment | 41 | |||||||
| Total liability for incurred claims and benefits | ||||||||
Premium Allocation Approach 2 | 2,335 | |||||||
| 1 | NN Group does not disclose claims development for years prior to 2018. | |||||||
| 2 | The claims development table includes the liability for incurred claims related to non-life contracts accounted for under the Premium Allocation Approach. Uncertainty about the amount and timing of the incurred claims for life contracts and | |||||||
| non-life contracts accounted for under the General Model is typically resolved within one year, thus these have not been included in this table. |
NN Group N.V. Annual Report 2024 | 284
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Notes to the Consolidated annual accounts continued
2024 | 2023 | |
Investment contracts – opening balance | 3,621 | 3,421 |
Current year liabilities | 450 | 458 |
| Prior years liabilities: | ||
– payments to contract holders | −462 | −463 |
– interest accrual | 6 | 7 |
– valuation changes investments | 250 | 217 |
Foreign currency exchange differences | −6 | −19 |
Investment contracts – closing balance | 3,859 | 3,621 |
NN Group N.V. Annual Report 2024 | 285
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Notes to the Consolidated annual accounts continued
| Reinsurance contracts held (2024) | |||
| Premium | |||
| Allocation | |||
2024 | General Model | Approach | Total |
Life reinsurance contracts | 391 | 391 | |
Non-life reinsurance contracts | 15 | 162 | 177 |
Total life and non-life reinsurance contracts | 406 | 162 | 568 |
- of which presented as assets | 514 | 166 | 680 |
- of which presented as liabilities | 108 | 4 | 112 |
Total life and non-life reinsurance contracts | 406 | 162 | 568 |
| Reinsurance contracts held (2023) | |||
| Premium | |||
| Allocation | |||
2023 | General Model | Approach | Total |
Life reinsurance contracts | 320 | 320 | |
Non-life reinsurance contracts | 26 | 243 | 269 |
Total life and non-life reinsurance contracts | 346 | 243 | 589 |
- of which presented as assets | 490 | 243 | 733 |
- of which presented as liabilities | 144 | 144 | |
Total life and non-life reinsurance contracts | 346 | 243 | 589 |
| Reinsurance contracts held under General Model (2024) | ||||
| Estimates of the | ||||
| present value of | Contractual | Total General | ||
| 2024 | future cash flows | Risk adjustment | service margin | Model |
– opening balance presented as assets | −266 | 281 | 475 | 490 |
– opening balance presented as liabilities | 211 | −10 | −57 | 144 |
Net opening balance | −477 | 291 | 532 | 346 |
– reinsurance contracts initially recognised in the year | 26 | 12 | −38 | 0 |
| – changes in estimates that adjust the contractual | ||||
service margin | −133 | −178 | 311 | 0 |
– changes in estimates that do not adjust the contractual service margin | −1 | −1 | ||
Changes that relate to future service | −108 | −166 | 273 | −1 |
– release to profit or loss | −11 | −88 | −99 | |
| – experience adjustments not adjusting the contractual | ||||
service margin | −16 | −16 | ||
Changes that relate to current service | −16 | −11 | −88 | −115 |
– changes in reinsurance recoveries previous periods | 6 | 6 | ||
Changes that relate to past service | 6 | 0 | 0 | 6 |
– finance result through profit or loss | −38 | 5 | 4 | −29 |
– finance result recognised in OCI | 38 | 25 | 63 | |
Finance result from reinsurance contracts | 0 | 30 | 4 | 34 |
– reinsurance recoveries received | −1,799 | −1,799 | ||
– reinsurance premiums paid | 1,945 | 1,945 | ||
Cash flows | 146 | 0 | 0 | 146 |
Foreign currency exchange differences | −9 | −1 | −10 | |
Net closing balance | −458 | 144 | 720 | 406 |
– closing balance presented as assets | −262 | 139 | 637 | 514 |
– closing balance presented as liabilities | 196 | −5 | −83 | 108 |
Net closing balance | −458 | 144 | 720 | 406 |
NN Group N.V. Annual Report 2024 | 286
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Notes to the Consolidated annual accounts continued
| Reinsurance contracts held under General Model (2023) | ||||
| Estimates of the | ||||
| present value of | Contractual | Total General | ||
| 2023 | future cash flows | Risk adjustment | service margin | Model |
– opening balance presented as assets | 23 | 138 | 383 | 544 |
– opening balance presented as liabilities | 234 | −9 | −2 | 223 |
Net opening balance | −211 | 147 | 385 | 321 |
– reinsurance contracts initially recognised in the year | −179 | 168 | 11 | 0 |
| – changes in estimates that adjust the contractual | ||||
service margin | −148 | −25 | 173 | 0 |
– changes in estimates that do not adjust the contractual service margin | 1 | 1 | ||
Changes that relate to future service | −326 | 143 | 184 | 1 |
– release to profit or loss | −16 | −40 | −56 | |
| – experience adjustments not adjusting the contractual | ||||
service margin | −2 | −2 | ||
Changes that relate to current service | −2 | −16 | −40 | −58 |
– changes in reinsurance recoveries previous periods | −4 | −4 | ||
Changes that relate to past service | −4 | 0 | 0 | −4 |
– finance result through profit or loss | 31 | 1 | 3 | 35 |
– finance result recognised in OCI | −48 | 15 | −33 | |
Finance result from reinsurance contracts | −17 | 16 | 3 | 2 |
– reinsurance recoveries received | −1,142 | −1,142 | ||
– reinsurance premiums paid | 1,243 | 1,243 | ||
– changes in the composition of the group and other changes | 2 | 2 | ||
Cash flows | 103 | 0 | 0 | 103 |
Other movements | 1 | 1 | ||
Foreign currency exchange differences | −20 | −20 | ||
Net closing balance | −477 | 291 | 532 | 346 |
– closing balance presented as assets | −266 | 281 | 475 | 490 |
– closing balance presented as liabilities | 211 | −10 | −57 | 144 |
Net closing balance | −477 | 291 | 532 | 346 |
NN Group N.V. Annual Report 2024 | 287
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
Interest rate | Year of Issue | Due date | First call date | Notional amount | Balance sheet value | ||
2024 | 2023 | 2024 | 2023 | ||||
1.625% | 2017 | 01 June 2027 | 01 March 2027 | 600 | 600 | 599 | 598 |
0.875% | 2021 | 23 November 2031 | 23 May 2031 | 600 | 600 | 597 | 597 |
Debt instruments issued | 1,196 | 1,195 |
Interest rate | Year of Issue | Due date | First call date | Notional amount | Balance sheet value | ||
2024 | 2023 | 2024 | 2023 | ||||
4.625% | 2014 | 08 April 2044 | 08 April 2024 | 335 | 335 | ||
4.625% | 2017 | 13 January 2048 | 13 January 2028 | 850 | 850 | 845 | 844 |
5.250% | 2022 | 01 March 2043 | 30 August 2032 | 500 | 500 | 494 | 494 |
6.000% | 2023 | 03 November 2043 | 03 May 2033 | 1,000 | 1,000 | 1,007 | 1,007 |
Subordinated debt | 2,346 | 2,680 |
NN Group N.V. Annual Report 2024 | 288
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Notes to the Consolidated annual accounts continued
| Customer deposits | ||
2024 | 2023 | |
Savings | 7,724 | 7,451 |
Bank annuities | 9,750 | 9,009 |
Customer deposits | 17,474 | 16,460 |
2024 | 2023 | |
Customer deposits – opening balance | 16,460 | 16,235 |
Deposits received | 4,694 | 4,246 |
Withdrawals | −3,661 | −4,000 |
Amortisation | −19 | −21 |
Customer deposits– closing balance | 17,474 | 16,460 |
2024 | 2023 | |
Credit institutions | 1,856 | 2,881 |
Other | 6,131 | 7,111 |
Other borrowed funds | 7,987 | 9,992 |
NN Group N.V. Annual Report 2024 | 289
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Notes to the Consolidated annual accounts continued
| Derivatives (assets) | ||
2024 | 2023 | |
| Derivatives used in: | ||
– fair value hedges | 4 | |
– cash flow hedges | 630 | 536 |
– hedges of net investments in foreign operations | 5 | |
Other derivatives | 2,050 | 1,945 |
Derivatives (assets) | 2,684 | 2,486 |
| Derivatives (liabilities) | ||
2024 | 2023 | |
| Derivatives used in: | ||
| – fair value hedges | 1 | 39 |
– cash flow hedges | 1,463 | 2,006 |
– hedges of net investments in foreign operations | 2 | 2 |
Other derivatives | 2,205 | 2,020 |
Derivatives (liabilities) | 3,671 | 4,067 |
NN Group N.V. Annual Report 2024 | 290
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Notes to the Consolidated annual accounts continued
2024 | 2023 | |
Income tax payable | 26 | 29 |
Net defined benefit liability | 41 | 49 |
Other post-employment benefits | 4 | 4 |
Other staff-related liabilities | 87 | 82 |
Other taxation and social security contributions | 103 | 113 |
Lease liabilities | 229 | 233 |
Accrued interest | 483 | 516 |
Costs payable | 285 | 305 |
Provisions | 463 | 524 |
Amounts to be settled | 29 | 32 |
Cash collateral amounts received | 1,454 | 1,595 |
Other | 569 | 558 |
Other liabilities | 3,773 | 4,040 |
2024 | 2023 | |
Fair value of plan assets | 71 | 70 |
Defined benefit obligation | 112 | 119 |
Net defined benefit liability recognised in the balance sheet (funded status) | 41 | 49 |
2024 | 2023 | |
NN Group N.V. Annual Report 2024 | 291
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Notes to the Consolidated annual accounts continued
21 Insurance income
| Insurance income (2024) | Contracts issued | |||
| after transition | ||||
| and full | Modified | |||
| retrospective | retrospective | Fair value | ||
| 2024 | approach | approach | approach | Total |
Release of contractual service margin | 321 | 138 | 398 | 857 |
Release of risk adjustment | 37 | 17 | 80 | 134 |
Expected claims and benefits | 909 | 88 | 4,142 | 5,139 |
Expected attributable expenses | 574 | 125 | 581 | 1,280 |
Recovery of acquisition costs | 325 | 89 | 1 | 415 |
Experience adjustments for premiums that relate to current or past service | 15 | 3 | 18 | |
| Insurance income General Model and Variable Fee | ||||
Approach | 2,181 | 457 | 5,205 | 7,843 |
Insurance income Premium Allocation Approach | 2,863 | |||
Total insurance income | 10,706 |
| Insurance income (2023) | Contracts issued | |||
| after transition | ||||
| and full | Modified | |||
| retrospective | retrospective | Fair value | ||
| 2023 | approach | approach | approach | Total |
Release of contractual service margin | 335 | 154 | 289 | 778 |
Release of risk adjustment | 34 | 19 | 115 | 168 |
Expected claims and benefits | 676 | 93 | 4,335 | 5,104 |
Expected attributable expenses | 449 | 140 | 648 | 1,237 |
Recovery of acquisition costs | 254 | 109 | 363 | |
Experience adjustments for premiums that relate to current or past service | 9 | 3 | 12 | |
| Insurance income General Model and Variable Fee | ||||
Approach | 1,757 | 515 | 5,390 | 7,662 |
Insurance income Premium Allocation Approach | 2,791 | |||
Total insurance income | 10,453 |
2024 | 2023 | |
Incurred claims and benefits | 5,110 | 5,126 |
Incurred attributable expenses | 1,298 | 1,250 |
Amortisation of acquisition costs | 415 | 363 |
Changes in incurred claims and benefits previous periods | −17 | 18 |
(Reversal of) losses on onerous contracts | −45 | 209 |
Other insurance expenses | 2 | |
Insurance expenses General Model and Variable Fee Approach | 6,761 | 6,968 |
NN Group N.V. Annual Report 2024 | 292
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Notes to the Consolidated annual accounts continued
| (Reversal of) losses on onerous contracts General Model and Variable Fee Approach | ||
2024 | 2023 | |
Losses on onerous contracts initially recognised in the year | 51 | 37 |
Changes in estimates not adjusting the contractual service margin | −78 | 198 |
Release of risk adjustment attributed to the loss component | −1 | −3 |
Expected claims and benefits attributed to the loss component | −4 | −5 |
Expected attributable insurance expenses attributed to the loss component | −13 | −18 |
| (Reversal of) losses on onerous contracts General Model and Variable Fee | ||
Approach | −45 | 209 |
| Insurance expenses Premium Allocation Approach | ||
2024 | 2023 | |
Incurred claims and benefits | 1,502 | 1,402 |
Incurred attributable expenses | 922 | 897 |
Amortisation of acquisition costs | 5 | 6 |
Changes in incurred claims and benefits previous periods | 46 | −29 |
(Reversal of) losses on onerous contracts | −8 | |
Other insurance expenses | 15 | 19 |
Insurance expenses Premium Allocation Approach | 2,490 | 2,287 |
| (Reversal of) losses on onerous contracts Premium Allocation Approach | ||
2024 | 2023 | |
Losses on onerous contracts initially recognised in the year | 3 | 3 |
Changes in estimates regarding onerous contracts | 1 | −4 |
Reversal of the loss component | −4 | −7 |
(Reversal of) losses on onerous contracts Premium Allocation Approach | 0 | −8 |
2024 | 2023 | |
Interest income from investments in debt securities | 1,764 | 1,744 |
Interest income from mortgage loans | 1,378 | 1,307 |
Interest income from other loans | 367 | 423 |
Interest income on (hedging) derivatives | 700 | 538 |
Other interest income | 289 | 208 |
Interest income | 4,498 | 4,220 |
Income from investments in real estate | 109 | 114 |
Dividend income on equity securities | 439 | 364 |
Other investment income | 5 | 9 |
Total other investment income | 553 | 487 |
Investment income | 5,051 | 4,707 |
NN Group N.V. Annual Report 2024 | 293
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Notes to the Consolidated annual accounts continued
2024 | 2023 | |
Netherlands Life | −2 | 29 |
Netherlands Non-life | −4 | 4 |
Insurance Europe | −2 | |
Japan Life | −2 | 8 |
Banking | −2 | |
Other | −1 | |
Total | −13 | 41 |
2024 | 2023 | |
| Change in fair value of derivatives relating to: | ||
– fair value hedges | −115 | −381 |
– cash flow hedges (ineffective portion) | 1 | 3 |
– other derivatives | −817 | 729 |
Net result on derivatives | −931 | 351 |
Change in fair value of assets and liabilities (hedged items) | 82 | 341 |
Result on derivatives and hedging | −849 | 692 |
NN Group N.V. Annual Report 2024 | 294
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Notes to the Consolidated annual accounts continued
2024 | 2023 | |
Change in fair value of underlying items | 4,862 | 4,084 |
Interest accreted | 1,892 | 1,832 |
Changes in value of options and guarantees for which the risk mitigation solution is used | −3 | −3 |
Finance result | 6,751 | 5,913 |
2024 | 2023 | |
Interest expenses on derivatives | 625 | 482 |
Other interest expenses | 684 | 551 |
Finance result other | 1,309 | 1,033 |
2024 | 2023 | |
Investment income | 4,498 | 4,220 |
Interest expenses on derivatives | −625 | −482 |
Other interest expenses | −684 | −551 |
Total interest income and expenses | 3,189 | 3,187 |
2024 | 2023 | |
Asset management fees | 283 | 251 |
Insurance brokerage and advisory fees | 223 | 196 |
Other | 103 | 65 |
Fee and commission income | 609 | 512 |
Asset management fees | 111 | 107 |
Commission expenses and other | 58 | 17 |
Fee and commission expenses | 169 | 124 |
Fee and commission result | 440 | 388 |
2024 | 2023 | |
Staff expenses | 1,698 | 1,680 |
Other operating expenses | 2,531 | 2,832 |
| Of which attributed to: | ||
– incurred acquisition costs | −649 | −602 |
– incurred insurance expenses | −2,255 | −2,192 |
Non-attributable operating expenses | 1,325 | 1,718 |
NN Group N.V. Annual Report 2024 | 295
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Notes to the Consolidated annual accounts continued
2024 | 2023 | |
Salaries | 1,099 | 1,045 |
Pension costs | 148 | 138 |
Social security costs | 168 | 156 |
Share-based compensation arrangements | 5 | 5 |
External staff costs | 189 | 255 |
Education | 20 | 16 |
Other staff costs | 69 | 65 |
Staff expenses | 1,698 | 1,680 |
2024 | 2023 | |
Current service cost | 6 | 5 |
Net interest cost | −1 | −2 |
Defined benefit plans | 5 | 3 |
Defined contribution plans | 143 | 135 |
Pension costs | 148 | 138 |
NN Group N.V. Annual Report 2024 | 296
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Notes to the Consolidated annual accounts continued
2024 | 2023 | |
Depreciation of property and equipment | 82 | 82 |
Amortisation of software | 36 | 35 |
Computer costs | 310 | 297 |
Office expenses | 69 | 69 |
Travel and accommodation expenses | 17 | 15 |
Advertising and public relations | 85 | 85 |
External advisory fees | 211 | 210 |
Claims handling expenses | 234 | 244 |
Additions to (releases of) other provisions | 7 | 403 |
Commissions, fees and other | 1,480 | 1,392 |
Other operating expenses | 2,531 | 2,832 |
| Earnings per ordinary share | ||||||
| Weighted average | ||||||
| Amounts (in millions of | number of ordinary | Per ordinary share (in | ||||
| euros) | shares (in millions) | euros) | ||||
2024 | 2023 | 2024 | 2023 | 2024 | 2023 | |
Net result | 1,583 | 1,172 | ||||
Coupon on undated subordinated notes | −66 | −51 | ||||
Basic earnings per ordinary share | 1,517 | 1,121 | 271.7 | 277.3 | 5.58 | 4.04 |
| Dilutive instruments: | ||||||
– Share plans | 0.2 | 0.2 | ||||
Dilutive instruments | 0.2 | 0.2 | ||||
Diluted earnings per ordinary share | 1,517 | 1,121 | 271.9 | 277.5 | 5.58 | 4.04 |
NN Group N.V. Annual Report 2024 | 297
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
28 Segments
NN Group N.V. Annual Report 2024 | 298
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Notes to the Consolidated annual accounts continued
| Netherlands | Insurance | ||||||
2024 | Netherlands Life | Non-life | Europe | Japan Life | Banking | Other | Total |
Profit margin | 200 | 343 | 142 | 685 | |||
Technical result | 38 | 53 | 32 | 124 | |||
Service expense result | 9 | −2 | 19 | 25 | |||
Other (re) insurance result | −1 | −1 | |||||
(Re) insurance result | 246 | 0 | 393 | 194 | 0 | 0 | 833 |
Investment result | 1,240 | 148 | 40 | 1,428 | |||
Other results - insurance businesses | −112 | −96 | −31 | −239 | |||
Operating result insurance businesses | 1,375 | 0 | 445 | 203 | 0 | 0 | 2,023 |
Operating result non-insurance businesses | −7 | 113 | 107 | ||||
Operating result non-life | 364 | 364 | |||||
Operating result banking | 189 | 189 | |||||
Operating result other | −108 | −108 | |||||
Total operating result | 1,368 | 364 | 559 | 203 | 189 | −108 | 2,574 |
| Non-operating items of which: | |||||||
– gains (losses) and impairments | −1,045 | −1 | 9 | 2 | −1,036 | ||
– revaluations | 514 | 50 | 19 | −57 | 9 | 535 | |
– market and other impacts | −29 | −5 | 57 | −1 | −10 | −32 | −20 |
Special items | −25 | −12 | −27 | −2 | −22 | −89 | |
Acquisition intangibles and goodwill | −2 | −26 | −28 | ||||
Result before tax | 783 | 397 | 604 | 153 | 179 | −180 | 1,936 |
Taxation | 83 | 99 | 134 | 40 | 46 | −67 | 334 |
Minority interests | 20 | 19 | |||||
Net result | 700 | 279 | 470 | 114 | 133 | −113 | 1,583 |
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Notes to the Consolidated annual accounts continued
Result by segment (2023)
| Netherlands | Insurance | ||||||
2023 | Netherlands Life | Non-life | Europe | Japan Life | Banking | Other | Total |
Profit margin | 180 | 315 | 156 | 652 | |||
Technical result | 60 | 26 | 22 | 107 | |||
Service expense result | −14 | −9 | 7 | −16 | |||
Other (re) insurance result | −1 | −1 | |||||
(Re) insurance result | 225 | 0 | 331 | 185 | 0 | 0 | 742 |
Investment result | 1,278 | 163 | 49 | 1,492 | |||
Other results - insurance businesses | −110 | −88 | −37 | −233 | |||
Operating result insurance businesses | 1,395 | 0 | 407 | 197 | 0 | 0 | 2,000 |
Operating result non-insurance businesses | −5 | 61 | 55 | ||||
Operating result non-life | 364 | 364 | |||||
Operating result banking | 226 | 226 | |||||
Operating result other | −118 | −118 | |||||
Total operating result | 1,390 | 364 | 468 | 197 | 226 | −118 | 2,528 |
| Non-operating items of which: | |||||||
– gains (losses) and impairments | −311 | −14 | −5 | −12 | −4 | −345 | |
– revaluations | 225 | 1 | −79 | −73 | −8 | 28 | 94 |
– market and other impacts | −68 | −4 | −182 | 17 | −21 | −14 | −272 |
Special items | −413 | −7 | −23 | −1 | −1 | −17 | −462 |
Acquisition intangibles and goodwill | −2 | −27 | −29 | ||||
Result on divestments | 19 | 19 | |||||
Result before tax | 823 | 340 | 196 | 129 | 196 | −151 | 1,532 |
Taxation | 166 | 91 | 37 | 32 | 51 | −30 | 348 |
Minority interests | −1 | 14 | −1 | 12 | |||
Net result | 657 | 235 | 159 | 97 | 146 | −121 | 1,172 |
Special items in 2023 mainly reflect a provision of EUR 360 million related to the final settlement with interest groups on unit-linked insurance products and project
expenses.
NN Group N.V. Annual Report 2024 | 300
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Notes to the Consolidated annual accounts continued
| I | |||||||
| Income by segment (2023) | |||||||
| Netherlands | Insurance | Other and | |||||
2023 | Netherlands Life | Non-life | Europe | Japan Life | Banking | eliminations | Total |
Insurance income | 4,164 | 3,843 | 1,830 | 590 | 26 | 10,453 | |
Investment income | 5,700 | 174 | 1,488 | 107 | 1,068 | 128 | 8,665 |
| Interest income and interest expenses by segment (2024) | |||||||
| Netherlands | Insurance | Other and | |||||
2024 | Netherlands Life | Non-life | Europe | Japan Life | Banking | eliminations | Total |
Interest income | 2,425 | 164 | 408 | 153 | 1,321 | 27 | 4,498 |
Interest expenses | −391 | −39 | −21 | −11 | −897 | 50 | −1,309 |
| Interest income and interest expenses by segment (2023) | |||||||
| Netherlands | Insurance | Other and | |||||
2023 | Netherlands Life | Non-life | Europe | Japan Life | Banking | eliminations | Total |
Interest income | 2,384 | 156 | 394 | 164 | 1,096 | 26 | 4,220 |
Interest expenses | −372 | −36 | −19 | −1 | −651 | 46 | −1,033 |
NN Group N.V. Annual Report 2024 | 301
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Notes to the Consolidated annual accounts continued
| Total assets and Total liabilities by segment | ||||
Total assets | Total liabilities | Total assets | Total liabilities | |
2024 | 2024 | 2023 | 2023 | |
Netherlands Life | 132,533 | 118,223 | 130,428 | 116,119 |
Netherlands Non-life | 8,781 | 7,235 | 8,672 | 7,069 |
Insurance Europe | 27,725 | 23,791 | 26,959 | 23,238 |
Japan Life | 13,778 | 12,645 | 15,562 | 14,344 |
Banking | 25,331 | 24,313 | 25,016 | 24,097 |
Other | 31,911 | 10,563 | 32,659 | 11,787 |
Total | 240,059 | 196,770 | 239,296 | 196,654 |
Eliminations | −29,684 | −8,047 | −30,355 | −8,832 |
Total assets and Total liabilities | 210,375 | 188,723 | 208,941 | 187,822 |
NN Group N.V. Annual Report 2024 | 302
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Notes to the Consolidated annual accounts continued
2024 | 2023 | |
Staff expenses | 1,698 | 1,680 |
Other operating expenses | 2,531 | 2,832 |
Total IFRS operating expenses (before attribution) | 4,229 | 4,512 |
Presented in insurance expenses and commissions | 1,292 | 1,263 |
Presented in insurance acquisition expenses | 537 | 510 |
Presented in non-operating items (including special items) | 117 | 479 |
Other adjustments | 53 | 54 |
Administrative expenses | 2,230 | 2,206 |
NN Group N.V. Annual Report 2024 | 303
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Notes to the Consolidated annual accounts continued
| Written premiums (2024) | |||
2024 | Life | Non-life | Total |
Gross written premiums | 9,776 | 4,202 | 13,978 |
Reinsurance ceded | −1,863 | 132 | −1,731 |
Net written premiums | 7,913 | 4,334 | 12,247 |
| Written premiums (2023) | |||
2023 | Life | Non-life | Total |
Gross written premiums | 9,190 | 3,997 | 13,187 |
Reinsurance ceded | −1,259 | 139 | −1,120 |
Net written premiums | 7,931 | 4,136 | 12,067 |
| Insurance contracts by segment (2024) | |||
| General Model | Premium | ||
| and Variable Fee | Allocation | ||
| 2024 | Approach | Approach | Total |
Netherlands Life | 108,114 | 108,114 | |
Netherlands Non-life | 3,907 | 2,520 | 6,427 |
Insurance Europe | 19,331 | 19,331 | |
Japan Life | 12,047 | 12,047 | |
Other | 1,171 | 42 | 1,213 |
Insurance contracts | 144,570 | 2,562 | 147,132 |
| Insurance contracts by segment (2023) | |||
| General Model | Premium | ||
| and Variable Fee | Allocation | ||
| 2023 | Approach | Approach | Total |
Netherlands Life | 104,312 | 104,312 | |
Netherlands Non-life | 3,798 | 2,504 | 6,302 |
Insurance Europe | 19,181 | 19,181 | |
Japan Life | 13,648 | 13,648 | |
Other | 1,213 | 53 | 1,266 |
Insurance contracts | 142,152 | 2,557 | 144,709 |
NN Group N.V. Annual Report 2024 | 304
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Notes to the Consolidated annual accounts continued
| Insurance contracts under General Model and Variable Fee Approach (2024) | ||||
| Total General | ||||
| Estimates of the | Risk adjustment | Model and | ||
| present value of | for non-financial | Contractual | Variable Fee | |
| Netherlands Life 2024 | future cash flows | risk | service margin | Approach |
– opening balance presented as assets | 0 | |||
– opening balance presented as liabilities | 99,719 | 966 | 3,627 | 104,312 |
Net opening balance | 99,719 | 966 | 3,627 | 104,312 |
– insurance contracts initially recognised in the year | −170 | 36 | 159 | 25 |
| – changes in estimates that adjust the contractual | ||||
service margin | −76 | −636 | 712 | 0 |
– changes in estimates that do not adjust the contractual service margin | 27 | −19 | 8 | |
Changes that relate to future service | −219 | −619 | 871 | 33 |
– release to profit or loss | −37 | −272 | −309 | |
| – experience adjustments not adjusting the contractual | ||||
service margin | 1 | 1 | ||
Changes that relate to current service | 1 | −37 | −272 | −308 |
| – changes in incurred claims and benefits previous | ||||
periods | −6 | −6 | ||
Changes that relate to past service | −6 | 0 | 0 | −6 |
– finance result through profit or loss | 5,051 | 22 | 32 | 5,105 |
– finance result recognised in OCI | 658 | 193 | 851 | |
Finance result on insurance contracts | 5,709 | 215 | 32 | 5,956 |
– premiums received | 4,298 | 4,298 | ||
– acquisition costs paid | −39 | −39 | ||
– claims, benefits and attributable expenses paid | −6,178 | −6,178 | ||
Cash flows | −1,919 | 0 | 0 | −1,919 |
NN Group N.V. Annual Report 2024 | 305
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Notes to the Consolidated annual accounts continued
| Insurance contracts under General Model and Variable Fee Approach (2023) | ||||
| Total General | ||||
| Estimates of the | Risk adjustment | Model and | ||
| present value of | for non-financial | Contractual | Variable Fee | |
| Netherlands Life 2023 | future cash flows | risk | service margin | Approach |
– opening balance presented as assets | 0 | |||
– opening balance presented as liabilities | 95,529 | 1,024 | 3,573 | 100,126 |
Net opening balance | 95,529 | 1,024 | 3,573 | 100,126 |
– insurance contracts initially recognised in the year | −97 | 15 | 99 | 17 |
| – changes in estimates that adjust the contractual | ||||
service margin | −87 | −76 | 163 | 0 |
– changes in estimates that do not adjust the contractual service margin | 40 | 5 | 45 | |
Changes that relate to future service | −144 | −56 | 262 | 62 |
– release to profit or loss | −66 | −233 | −299 | |
| – experience adjustments not adjusting the contractual | ||||
service margin | 25 | 25 | ||
Changes that relate to current service | 25 | −66 | −233 | −274 |
| – changes in incurred claims and benefits previous | ||||
periods | −12 | −12 | ||
Changes that relate to past service | −12 | 0 | 0 | −12 |
– finance result through profit or loss | 4,133 | 29 | 24 | 4,186 |
– finance result recognised in OCI | 2,856 | 35 | 1 | 2,892 |
Finance result on insurance contracts | 6,989 | 64 | 25 | 7,078 |
– premiums received | 3,415 | 3,415 | ||
– acquisition costs paid | −39 | −39 | ||
– claims, benefits and attributable expenses paid | −6,044 | −6,044 | ||
Cash flows | −2,668 | 0 | 0 | −2,668 |
NN Group N.V. Annual Report 2024 | 306
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Notes to the Consolidated annual accounts continued
| Insurance contracts under General Model (2024) | ||||
| Estimates of the | Risk adjustment | |||
| present value of | for non-financial | Contractual | Total General | |
| Netherlands Non-life 2024 | future cash flows | risk | service margin | Model |
– opening balance presented as assets | 0 | |||
– opening balance presented as liabilities | 3,173 | 130 | 495 | 3,798 |
Net opening balance | 3,173 | 130 | 495 | 3,798 |
– insurance contracts initially recognised in the year | −94 | 12 | 83 | 1 |
| – changes in estimates that adjust the contractual | ||||
service margin | −19 | 25 | −6 | 0 |
– changes in estimates that do not adjust the contractual service margin | −2 | −2 | ||
Changes that relate to future service | −115 | 37 | 77 | −1 |
– release to profit or loss | −24 | −62 | −86 | |
| – experience adjustments not adjusting the contractual | ||||
service margin | 12 | 12 | ||
Changes that relate to current service | 12 | −24 | −62 | −74 |
| – changes in incurred claims and benefits previous | ||||
periods | 2 | 2 | ||
Changes that relate to past service | 2 | 0 | 0 | 2 |
– finance result through profit or loss | 68 | 2 | 7 | 77 |
– finance result recognised in OCI | 63 | 1 | 64 | |
Finance result on insurance contracts | 131 | 3 | 7 | 141 |
– premiums received | 1,187 | 1,187 | ||
– acquisition costs paid | −14 | −14 | ||
– claims, benefits and attributable expenses paid | −1,132 | −1,132 | ||
Cash flows | 41 | 0 | 0 | 41 |
NN Group N.V. Annual Report 2024 | 307
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Notes to the Consolidated annual accounts continued
| Insurance contracts under General Model (2023) | ||||
| Estimates of the | Risk adjustment | |||
| present value of | for non-financial | Contractual | Total General | |
| Netherlands Non-life 2023 | future cash flows | risk | service margin | Model |
– opening balance presented as assets | 0 | |||
– opening balance presented as liabilities | 2,906 | 149 | 355 | 3,410 |
Net opening balance | 2,906 | 149 | 355 | 3,410 |
– insurance contracts initially recognised in the year | −160 | 14 | 146 | 0 |
| – changes in estimates that adjust the contractual | ||||
service margin | 40 | −28 | −12 | 0 |
– changes in estimates that do not adjust the contractual service margin | 1 | 1 | ||
Changes that relate to future service | −119 | −14 | 134 | 1 |
– release to profit or loss | −23 | −48 | −71 | |
| – experience adjustments not adjusting the contractual | ||||
service margin | −14 | −14 | ||
Changes that relate to current service | −14 | −23 | −48 | −85 |
| – changes in incurred claims and benefits previous | ||||
periods | 5 | 5 | ||
Changes that relate to past service | 5 | 0 | 0 | 5 |
– finance result through profit or loss | 56 | 2 | 6 | 64 |
– finance result recognised in OCI | 210 | 16 | 226 | |
Finance result on insurance contracts | 266 | 18 | 6 | 290 |
– premiums received | 1,053 | 1,053 | ||
– acquisition costs paid | −3 | −3 | ||
– claims, benefits and attributable expenses paid | −921 | −921 | ||
Cash flows | 129 | 0 | 0 | 129 |
NN Group N.V. Annual Report 2024 | 308
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Notes to the Consolidated annual accounts continued
| Insurance contracts under General Model and Variable Fee Approach (2024) | ||||
| Total General | ||||
| Estimates of the | Risk adjustment | Model and | ||
| present value of | for non-financial | Contractual | Variable Fee | |
| Insurance Europe 2024 | future cash flows | risk | service margin | Approach |
– opening balance presented as assets | 777 | −69 | −353 | 355 |
– opening balance presented as liabilities | 17,679 | 372 | 1,485 | 19,536 |
Net opening balance | 16,902 | 441 | 1,838 | 19,181 |
– insurance contracts initially recognised in the year | −319 | 38 | 305 | 24 |
| – changes in estimates that adjust the contractual | ||||
service margin | −308 | −33 | 341 | 0 |
– changes in estimates that do not adjust the contractual service margin | −31 | −58 | −89 | |
Changes that relate to future service | −658 | −53 | 646 | −65 |
– release to profit or loss | −47 | −371 | −418 | |
| – experience adjustments not adjusting the contractual | ||||
service margin | −25 | −25 | ||
Changes that relate to current service | −25 | −47 | −371 | −443 |
| – changes in incurred claims and benefits previous | ||||
periods | −13 | −13 | ||
Changes that relate to past service | −13 | 0 | 0 | −13 |
– finance result through profit or loss | 1,188 | 13 | 37 | 1,238 |
– finance result recognised in OCI | 17 | 3 | 20 | |
Finance result on insurance contracts | 1,205 | 16 | 37 | 1,258 |
– premiums received | 3,714 | 3,714 | ||
– acquisition costs paid | −480 | −480 | ||
– claims, benefits and attributable expenses paid | −3,750 | −3,750 | ||
Cash flows | −516 | 0 | 0 | −516 |
| I | ||||
NN Group N.V. Annual Report 2024 | 309
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| I | ||||
NN Group N.V. Annual Report 2024 | 310
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Notes to the Consolidated annual accounts continued
12,047 |
| Total General | ||||
| Estimates of the | Risk adjustment | Model and | ||
| present value of | for non-financial | Contractual | Variable Fee | |
| Japan Life 2023 | future cash flows | risk | service margin | Approach |
– opening balance presented as assets | 0 | |||
– opening balance presented as liabilities | 13,932 | 162 | 1,182 | 15,276 |
Net opening balance | 13,932 | 162 | 1,182 | 15,276 |
– insurance contracts initially recognised in the year | −143 | 11 | 132 | 0 |
| – changes in estimates that adjust the contractual | ||||
service margin | −75 | 111 | −36 | 0 |
– changes in estimates that do not adjust the contractual service margin | 1 | 1 | 2 | |
Changes that relate to future service | −217 | 123 | 96 | 2 |
– release to profit or loss | −27 | −161 | −188 | |
| – experience adjustments not adjusting the contractual | ||||
service margin | −18 | −18 | ||
Changes that relate to current service | −18 | −27 | −161 | −206 |
| – changes in incurred claims and benefits previous | ||||
periods | 9 | 9 | ||
Changes that relate to past service | 9 | 0 | 0 | 9 |
– finance result through profit or loss | 135 | 1 | 4 | 140 |
– finance result recognised in OCI | 54 | 12 | 66 | |
Finance result on insurance contracts | 189 | 13 | 4 | 206 |
– premiums received | 2,441 | 2,441 | ||
– acquisition costs paid | −112 | −112 | ||
– claims, benefits and attributable expenses paid | −2,447 | −2,447 | ||
Cash flows | −118 | 0 | 0 | −118 |
Foreign currency exchange differences | −1,395 | −13 | −113 | −1,521 |
Net closing balance | 12,382 | 258 | 1,008 | 13,648 |
– closing balance presented as assets | 0 | |||
– closing balance presented as liabilities | 12,382 | 258 | 1,008 | 13,648 |
Net closing balance | 12,382 | 258 | 1,008 | 13,648 |
NN Group N.V. Annual Report 2024 | 311
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Notes to the Consolidated annual accounts continued
| Average number | Total | Result | Income | |||||
Country/Name of principal subsidiaries | Main activity | of employees 1 | Total revenues 2 | Revenues 3 | assets | before tax | Taxation 4 | tax paid |
Nationale-Nederlanden Levensverzekering Maatschappij N.V. | Life insurance | |||||||
Nationale-Nederlanden Bank N.V. | Banking | |||||||
Nationale-Nederlanden Schadeverzekering Maatschappij N.V. | General insurance | |||||||
REI Investment I B.V. | Real estate | |||||||
NN Re (Netherlands) N.V. | Reinsurance | |||||||
The Netherlands | 9,215 | 15,989 | 12,656 | 167,455 | 1,156 | 153 | 268 | |
NN Life Insurance Company, Ltd. | Life insurance | |||||||
Japan | 1,005 | 840 | 686 | 13,033 | 131 | 36 | −16 | |
NN Insurance Belgium nv | Life insurance | |||||||
Belgium | 641 | 758 | 670 | 10,473 | 126 | 34 | 1 | |
NN Hellenic Life Insurance Co. S.A. | Life insurance | |||||||
Greece | 567 | 639 | 463 | 4,627 | 86 | 21 | ||
Nationale Nederlanden Vida, Compania de Seguros y Reaseguros. S.A. | Life insurance | |||||||
Nationale Nederlanden Generales, Compania de Seguros y Reaseguros, S.A. | General insurance | |||||||
Spain | 594 | 669 | 423 | 4,577 | 88 | 19 | 2 | |
Nationale-Nederlanden Towarzystwo Ubezpieczeń na Życie S.A. | Life insurance | |||||||
Nationale-Nederlanden Powszechne Towarzystwo Emerytalne S.A. | Pensions | |||||||
Poland 5 | 1,100 | 655 | 565 | 3,484 | 152 | 24 | 13 | |
NN Biztosító Zártkörûen Mûködõ Részvénytársaság | Life insurance | |||||||
Hungary | 515 | 302 | 121 | 1,375 | 15 | 5 | 2 | |
NN Životní pojišťovna N.V. (pobočka pro Českou republiku) | Life insurance | |||||||
Czech Republic | 710 | 233 | 154 | 1,300 | 29 | 7 | −10 | |
NN Asigurari de Viata S.A. | Life insurance | |||||||
Romania 6 | 546 | 253 | 211 | 1,117 | 43 | 8 | 7 |
NN Group N.V. Annual Report 2024 | 312
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Notes to the Consolidated annual accounts continued
NN Group N.V. Annual Report 2024 | 313
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| Principal subsidiaries and geographical information (2023) | ||||||||
| Average number | Total | Result | Income | |||||
Country/Name of principal subsidiaries | Main activity | of employees 1 | Total revenues 2 | Revenues 3 | assets | before tax | Taxation 4 | tax paid |
Nationale-Nederlanden Levensverzekering Maatschappij N.V. | Life insurance | |||||||
Nationale-Nederlanden Bank N.V. | Banking | |||||||
Nationale-Nederlanden Schadeverzekering Maatschappij N.V. | General insurance | |||||||
REI Investment I B.V. | Real estate | |||||||
NN Re (Netherlands) N.V. | Reinsurance | |||||||
The Netherlands | 9,127 | 15,128 | 12,254 | 165,114 | 1,277 | 295 | 147 | |
NN Life Insurance Company, Ltd. | Life insurance | |||||||
Japan | 976 | 914 | 754 | 14,683 | 116 | 30 | 93 | |
NN Insurance Belgium nv | Life insurance | |||||||
Belgium | 639 | 688 | 584 | 10,402 | −83 | −18 | 1 | |
Nationale Nederlanden Vida, Compania de Seguros y Reaseguros. S.A. | Life insurance | |||||||
Nationale Nederlanden Generales, Compania de Seguros y Reaseguros, S.A. | General insurance | |||||||
Spain | 580 | 562 | 386 | 4,516 | 16 | 2 | 6 | |
NN Hellenic Life Insurance Co. S.A. | Life insurance | |||||||
Greece | 581 | 601 | 432 | 4,289 | 20 | 3 | ||
Nationale-Nederlanden Towarzystwo Ubezpieczeń na Życie S.A. | Life insurance | |||||||
Nationale-Nederlanden Powszechne Towarzystwo Emerytalne S.A. | Pensions | |||||||
Poland 5 | 1,169 | 770 | 509 | 3,461 | 150 | 33 | −3 | |
NN Biztosító Zártkörûen Mûködõ Részvénytársaság | Life insurance | |||||||
Hungary | 488 | 205 | 114 | 1,313 | 8 | 2 | 2 | |
NN Životní pojišťovna N.V. (pobočka pro Českou republiku) | Life insurance | |||||||
Czech Republic | 688 | 250 | 133 | 1,299 | 25 | 1 | 4 | |
NN Asigurari de Viata S.A. | Life insurance | |||||||
Romania 6 | 512 | 265 | 175 | 1,082 | 40 | 7 | 4 | |
France | −48 | 19 | 831 | −54 | −7 | 5 | ||
Slovak Republic | 392 | 177 | 128 | 786 | 36 | 9 | 7 | |
Germany | −22 | 18 | 595 | −22 −5 3 |
NN Group N.V. Annual Report 2024 | 314
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
NN Group N.V. Annual Report 2024 | 315
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Notes to the Consolidated annual accounts continued
31 Taxation
| Changes in | ||||||
| the | ||||||
| composition | Foreign | |||||
| Net | Changes | Changes | of the group | currency | Net | |
| liability | through | through net | and other | exchange | liability | |
| 2023 | equity | result | changes | differences | 2024 | |
Investments | −2,152 | 151 | −7 | 2 | −2,006 | |
Investments in real estate | 1,013 | 51 | −18 | 1,046 | ||
Insurance contracts | 594 | −129 | 188 | −8 | 645 | |
Cash flow hedges | 990 | 16 | 1,006 | |||
Fiscal reserves | 36 | −34 | 2 | |||
Unused tax losses carried forward | −134 | 11 | −123 | |||
Other | 66 | 4 | −15 | 43 | 2 | 100 |
Deferred tax | 413 | 42 | 194 | 25 | −4 | 670 |
Presented in the balance sheet as Deferred tax liabilities | 559 | 764 | ||||
Deferred tax assets | 146 | 94 | ||||
Deferred tax | 413 | 670 |
NN Group N.V. Annual Report 2024 | 316
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Notes to the Consolidated annual accounts continued
| Changes in | ||||||
| the | ||||||
| composition | Foreign | |||||
| Net | Changes | Changes | of the group | currency | Net | |
| liability | through | through net | and other | exchange | liability | |
| 2022 | equity | result | changes | differences | 2023 | |
Investments | −3,158 | 953 | −3 | 55 | 1 | −2,152 |
Investments in real estate | 1,162 | −151 | 2 | 1,013 | ||
Insurance contracts | 1,572 | −923 | 150 | −197 | −8 | 594 |
Cash flow hedges | 1,005 | −15 | 990 | |||
Fiscal reserves | 36 | 36 | ||||
Unused tax losses carried forward | −131 | −3 | −134 | |||
Other | 43 | −5 | −56 | 84 | 66 | |
Deferred tax | 493 | 10 | −27 | −56 | −7 | 413 |
Presented in the balance sheet as Deferred tax liabilities | 624 | 559 | ||||
Deferred tax assets | 131 | 146 | ||||
Deferred tax | 493 | 413 |
| Deferred tax on unused tax losses carried forward | ||
2024 | 2023 | |
Total unused tax losses carried forward | 741 | 757 |
Unused tax losses carried forward not recognised as a deferred tax asset | −217 | −186 |
Unused tax losses carried forward recognised as a deferred tax asset | 524 | 571 |
Average tax rate | 23.4% | 23.4% |
Deferred tax asset | 123 | 134 |
| Total unused tax losses carried forward analysed by term of expiration | ||||
No deferred tax asset recognised | Deferred tax asset recognised | |||
2024 | 2023 | 2024 | 2023 | |
Within 1 year | 9 | 18 | 7 | |
More than 1 year but less than 5 years | 6 | 32 | 135 | 171 |
More than 5 years but less than 10 years | 5 | 15 | ||
Unlimited | 202 | 131 | 382 | 385 |
Total unused tax losses carried forward | 217 | 186 | 524 | 571 |
| Taxation on result | ||
2024 | 2023 | |
Current tax | 140 | 375 |
Deferred tax | 194 | −27 |
Taxation on result | 334 | 348 |
NN Group N.V., together with certain of its subsidiaries, is a part of a fiscal unity for Dutch income tax
purposes. The members of the fiscal unity are jointly and severally liable for any income taxes payable by the
Dutch fiscal unity.
Reference is made to Note 30 ‘Principal subsidiaries and geographical information’ for more information on
the taxation per country.
NN Group N.V. Annual Report 2024 | 317
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Notes to the Consolidated annual accounts continued
Reconciliation of the weighted average statutory tax rate to NN Group’s effective tax rate
2024 | 2023 | |
Result before tax | 1,936 | 1,532 |
Weighted average statutory tax rate | 24.6% | 24.7% |
Weighted average statutory tax amount | 477 | 378 |
Participation exemption | −126 | −49 |
Other income not subject to tax and other | −18 | 22 |
Expenses not deductible for tax purposes | 8 | 8 |
Impact on deferred tax from change in tax rates | 2 | −4 |
Tax benefit for previously unrecognised amounts | 6 | −2 |
Adjustments to prior periods | −15 | −5 |
Effective tax amount | 334 | 348 |
Effective tax rate | 17.3% | 22.7% |
In 2024, the effective tax rate of 17.3% was lower than the weighted average statutory tax rate of 24.6%.
This was mainly a result of tax exempt investment results.
In 2023, the effective tax rate of 22.7% was lower than the weighted average statutory tax rate of 24.7%.
This was mainly a result of tax exempt investment results.
| Taxation on components of other comprehensive income | ||
2024 | 2023 | |
Finance result on (re) insurance contracts recognised in OCI | 118 | 917 |
Revaluations on debt securities and loans at fair value through OCI | 134 | −816 |
Realised gains (losses) transferred to the profit and loss account | −265 | −84 |
Changes in cash flow hedge reserve | −16 | 15 |
Remeasurement of the net defined benefit asset/liability | −3 | 5 |
Income tax | −32 | 37 |
Estimated fair value | Balance sheet value | |||
2024 | 2023 | 2024 | 2023 | |
| Financial assets | ||||
| Cash and cash equivalents | 6,929 | 8,207 | 6,929 | 8,207 |
Investments at fair value through other comprehensive income | 106,050 | 110,100 | 106,050 | 110,100 |
Investments at cost | 21,780 | 20,651 | 22,234 | 21,488 |
Investments at fair value through profit or loss | 54,968 | 49,392 | 54,968 | 49,392 |
Derivatives | 2,684 | 2,486 | 2,684 | 2,486 |
Financial assets | 192,411 | 190,836 | 192,865 | 191,673 |
| Financial liabilities | ||||
Investment contracts for risk of company | 1,176 | 1,223 | 1,201 | 1,289 |
Investment contracts for risk of policyholders | 2,658 | 2,332 | 2,658 | 2,332 |
Investment contracts | 3,834 | 3,555 | 3,859 | 3,621 |
Debt instruments issued | 1,109 | 1,098 | 1,196 | 1,195 |
Subordinated debt | 2,560 | 2,784 | 2,346 | 2,680 |
Other borrowed funds | 7,630 | 9,633 | 7,987 | 9,992 |
Customer deposits | 17,198 | 16,069 | 17,474 | 16,460 |
Derivatives | 3,671 | 4,067 | 3,671 | 4,067 |
Financial liabilities | 36,002 | 37,206 | 36,533 | 38,015 |
NN Group N.V. Annual Report 2024 | 318
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
NN Group N.V. Annual Report 2024 | 319
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Notes to the Consolidated annual accounts continued
| Methods applied in determining the fair value of financial assets and liabilities at fair value (2024) | ||||
2024 | Level 1 | Level 2 | Level 3 | Total |
| Financial assets | ||||
Derivatives | 65 | 2,619 | 2,684 | |
Investments at fair value through OCI | 48,451 | 20,639 | 36,960 | 106,050 |
Investments at fair value through profit or loss | 45,035 | 1,708 | 8,225 | 54,968 |
Financial assets | 93,551 | 24,966 | 45,185 | 163,702 |
| Financial liabilities | ||||
Investment contracts (for contracts at fair value) | 2,658 | 2,658 | ||
Derivatives | 3 | 3,644 | 24 | 3,671 |
Financial liabilities | 2,661 | 3,644 | 24 | 6,329 |
| Methods applied in determining the fair value of financial assets and liabilities at fair value (2023) | ||||
2023 | Level 1 | Level 2 | Level 3 | Total |
| Financial assets | ||||
Derivatives | 1 | 2,485 | 2,486 | |
Investments at fair value through OCI | 46,113 | 24,508 | 39,479 | 110,100 |
Investments at fair value through profit or loss | 40,251 | 1,594 | 7,547 | 49,392 |
Financial assets | 86,365 | 28,587 | 47,026 | 161,978 |
| Financial liabilities | ||||
| Investment contracts (for contracts at fair value) | 2,332 | 2,332 | ||
Derivatives | 57 | 3,990 | 20 | 4,067 |
Financial liabilities | 2,389 | 3,990 | 20 | 6,399 |
NN Group N.V. Annual Report 2024 | 320
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
NN Group N.V. Annual Report 2024 | 321
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
| Changes in Level 3 financial assets (2024) | Investments at | ||
| fair value | Investments at | ||
| through other | fair value | ||
| comprehensive | through profit or | ||
| 2024 | income | loss | Total |
Level 3 Financial assets – opening balance | 39,479 | 7,547 | 47,026 |
Amounts recognised in the profit and loss account | −545 | 148 | −397 |
Revaluations recognised in other comprehensive income (equity) | 1,700 | 1,700 | |
Purchase | 2,086 | 1,079 | 3,165 |
Sale | −101 | −534 | −635 |
Maturity/settlement | −5,385 | −24 | −5,409 |
Other transfers and reclassifications | −48 | −48 | |
Transfers out of Level 3 | −334 | −334 | |
Transfers into Level 3 | 16 | 16 | |
Changes in the composition of the group and other changes | 25 | 25 | |
Foreign currency exchange differences | 19 | 57 | 76 |
Level 3 Financial assets – closing balance | 36,960 | 8,225 | 45,185 |
| Changes in Level 3 financial assets (2023) | Investments at | ||
| fair value | Investments at | ||
| through other | fair value | ||
| comprehensive | through profit or | ||
| 2023 | income | loss | Total |
Level 3 Financial assets – opening balance | 40,748 | 5,613 | 46,361 |
Amounts recognised in the profit and loss account | −97 | 42 | −55 |
Revaluations recognised in other comprehensive income (equity) | 909 | 909 | |
Purchase | 2,029 | 900 | 2,929 |
Sale | −183 | −728 | −911 |
Maturity/settlement | −2,634 | −9 | −2,643 |
Other transfers and reclassifications | −1,286 | 1,286 | 0 |
Transfers out of Level 3 | −3 | −11 | −14 |
Changes in the composition of the group and other changes | −4 | 454 | 450 |
Level 3 Financial assets – closing balance | 39,479 | 7,547 | 47,026 |
2024 | 2023 | |
Level 3 Financial liabilities – opening balance | 20 | 19 |
Amounts recognised in the profit and loss account | 4 | 1 |
Level 3 Financial liabilities – closing balance | 24 | 20 |
NN Group N.V. Annual Report 2024 | 322
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
| Held at balance | Derecognised | ||
| 2024 | sheet date | during the year | Total |
| Financial assets | |||
Investments at fair value through other comprehensive income | −80 | −465 | −545 |
Investments at fair value through profit or loss | 147 | 1 | 148 |
Financial assets | 67 | −464 | −397 |
| Financial liabilities | |||
Derivatives | 4 | 4 | |
Financial liabilities | 4 | 0 | 4 |
| Level 3 – Amounts recognised in the profit and loss account during the year (2023) | |||
| Held at balance | Derecognised | ||
| 2023 | sheet date | during the year | Total |
| Financial assets | |||
Investments at fair value through other comprehensive income | −109 | 12 | −97 |
Investments at fair value through profit or loss | 45 | −3 | 42 |
Financial assets | −64 | 9 | −55 |
| Financial liabilities | |||
Derivatives | 1 | 1 | |
Financial liabilities | 1 | 0 | 1 |
NN Group N.V. Annual Report 2024 | 323
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
| Methods applied in determining the fair value of financial assets and liabilities at cost (2024) | ||||
2024 | Level 1 | Level 2 | Level 3 | Total |
| Financial assets | ||||
Cash and cash equivalents | 6,929 | 6,929 | ||
Investments at cost | 21,780 | 21,780 | ||
Financial assets | 6,929 | 0 | 21,780 | 28,709 |
| Financial liabilities | ||||
Subordinated debt | 2,560 | 2,560 | ||
Debt instruments issued | 1,109 | 1,109 | ||
Other borrowed funds | 5,751 | 1,879 | 7,630 | |
Investment contracts for risk of company | 307 | 869 | 1,176 | |
Customer deposits | 9,091 | 8,107 | 17,198 | |
Financial liabilities | 18,818 | 9,986 | 869 | 29,673 |
2023 | Level 1 | Level 2 | Level 3 | Total |
| Financial assets | ||||
Cash and cash equivalents | 8,207 | 8,207 | ||
Investments at cost | 42 | 17 | 20,592 | 20,651 |
Financial assets | 8,249 | 17 | 20,592 | 28,858 |
| Financial liabilities | ||||
Subordinated debt | 2,784 | 2,784 | ||
Debt instruments issued | 1,098 | 1,098 | ||
Other borrowed funds | 6,648 | 2,985 | 9,633 | |
Investment contracts for risk of company | 329 | 894 | 1,223 | |
Customer deposits | 9,440 | 6,629 | 16,069 | |
Financial liabilities | 20,299 | 9,614 | 894 | 30,807 |
| Fair value of non-financial assets | ||||
Estimated fair value | Balance sheet value | |||
2024 | 2023 | 2024 | 2023 | |
Investments in real estate | 2,512 | 2,620 | 2,512 | 2,620 |
Property in own use | 91 | 92 | 91 | 92 |
Fair value of non-financial assets | 2,603 | 2,712 | 2,603 | 2,712 |
NN Group N.V. Annual Report 2024 | 324
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
| Methods applied in determining the fair value of non-financial assets at fair value (2024) | ||||
2024 | Level 1 | Level 2 | Level 3 | Total |
Investments in real estate | 2,512 | 2,512 | ||
Property in own use | 91 | 91 | ||
Non-financial assets | 0 | 0 | 2,603 2,603 |
2023 | Level 1 | Level 2 | Level 3 | Total |
Investments in real estate | 2,620 | 2,620 | ||
Property in own use | 92 | 92 | ||
Non-financial assets | 0 | 0 | 2,712 | 2,712 |
| Changes in Level 3 non-financial assets (2024) | |||
| Real estate | Property | ||
| 2024 | investments | in own use | Total |
Level 3 non-financial assets – opening balance | 2,620 | 92 | 2,712 |
Amounts recognised in the profit and loss account during the year | −13 | −13 | |
Purchase | 114 | 3 | 117 |
Sale | −206 | −6 | −212 |
Changes in the composition of the group and other changes | −3 | 2 | −1 |
Level 3 non-financial assets – closing balance | 2,512 | 91 | 2,603 |
| Changes in Level 3 non-financial assets (2023) | |||
| Real estate | Property | ||
| 2023 | investments | in own use | Total |
Level 3 non-financial assets – opening balance | 2,754 | 97 | 2,851 |
Amounts recognised in the profit and loss account during the year | −276 | −9 | −285 |
Purchase | 193 | 3 | 196 |
Revaluation recognised in equity during the year | −1 | −1 | |
Sale | −50 | −50 | |
Changes in the composition of the group and other changes | −1 | 1 | 0 |
Foreign currency exchange differences | 1 | 1 | |
Level 3 non-financial assets – closing balance | 2,620 | 92 | 2,712 |
| Held at balance | Derecognised | ||
| 2024 | sheet date | during the year | Total |
Investments in real estate | −11 | −2 | −13 |
Property in own use | −1 | 1 | 0 |
Level 3 Amounts recognised in the profit and loss account during the year on non-financial assets | −12 | −1 | −13 |
| Held at balance | Derecognised | ||
| 2023 | sheet date | during the year | Total |
Investments in real estate | −275 | −1 | −276 |
Property in own use | −8 | −1 | −9 |
Level 3 Amounts recognised in the profit and loss account during the year on non-financial assets | −283 | −2 | −285 |
NN Group N.V. Annual Report 2024 | 325
Consolidated annual accounts
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
NN Group N.V. Annual Report 2024 | 326
Consolidated annual accounts
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
NN Group N.V. Annual Report 2024 | 327
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
NN Group N.V. Annual Report 2024 | 328
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
NN Group N.V. Annual Report 2024 | 329
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
35 Assets by contractual maturity
Amounts presented in these tables by contractual maturity are the amounts as presented in the balance
sheet.
| Assets by contractual maturity (2024) | ||||||||||
| Maturity not | ||||||||||
2024 | Less than 1 year | 1-2 years | 2-3 years | 3-4 years | 4-5 years | 5-10 years | Over 10 years | applicable | Adjustment | Total |
Cash and cash equivalents | 6,929 | 6,929 | ||||||||
Investments at fair value through OCI | 6,610 | 5,015 | 4,436 | 4,874 | 5,001 | 15,239 | 62,082 | 2,793 | 106,050 | |
Investments at cost | 447 | 294 | 401 | 425 | 469 | 3,113 | 17,085 | 22,234 | ||
Investments at fair value through profit or loss 1 | 868 | 66 | 69 | 80 | 24 | 81 | 62 | 53,718 | 54,968 | |
Investments in real estate | 2,512 | 2,512 | ||||||||
Investments in associates and joint ventures | 7,036 | 7,036 | ||||||||
Derivatives | 138 | 14 | 38 | 21 | 12 | 90 | 2,371 | 2,684 | ||
Insurance contracts | 36 | 66 | 58 | 49 | 22 | 104 | 207 | −133 | 409 | |
Reinsurance contracts | 66 | 67 | 78 | 116 | 62 | 92 | 16 | 183 | 680 | |
Property and equipment | 302 | 302 | ||||||||
Intangible assets | 61 | 51 | 43 | 38 | 39 | 90 | 23 | 884 | 1,229 | |
Deferred tax assets | 5 | 5 | 5 | 5 | 9 | 21 | 18 | 26 | 94 | |
Other assets | 4,533 | 93 | 25 | 28 | 37 | 328 | 180 | 24 | 5,248 | |
Total assets | 19,693 | 5,671 | 5,153 | 5,636 | 5,675 | 19,158 | 82,044 | 67,295 | 50 | 210,375 |
1
Includes Investments for risk of policyholders. Although individual Investments for risk of policyholders may (or may not) have a maturity depending on their nature, this does not impact the liquidity position of NN Group.
NN Group N.V. Annual Report 2024 | 330
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
| Assets by contractual maturity (2023) | ||||||||||
| Maturity not | ||||||||||
2023 | Less than 1 year | 1-2 years | 2-3 years | 3-4 years | 4-5 years | 5-10 years | Over 10 years | applicable | Adjustment | Total |
Cash and cash equivalents | 8,207 | 8,207 | ||||||||
Investments at fair value through OCI | 8,671 | 5,009 | 4,977 | 4,147 | 4,276 | 15,065 | 64,504 | 3,451 | 110,100 | |
Investments at cost | 453 | 341 | 399 | 412 | 432 | 2,726 | 16,725 | 21,488 | ||
Investments at fair value through profit or loss 1 | 1,076 | 74 | 66 | 63 | 48 | 103 | 64 | 47,898 | 49,392 | |
Investments in real estate | 2,620 | 2,620 | ||||||||
Investments in associates and joint ventures | 6,231 | 6,231 | ||||||||
Derivatives | 140 | 43 | 6 | 34 | 26 | 97 | 2,140 | 2,486 | ||
Insurance contracts | 51 | 61 | 53 | 47 | 41 | 148 | 110 | −156 | 355 | |
Reinsurance contracts | 157 | 124 | 117 | 127 | 193 | 263 | 82 | −330 | 733 | |
Property and equipment | 348 | 348 | ||||||||
Intangible assets | 54 | 50 | 47 | 37 | 43 | 95 | 35 | 909 | 1,270 | |
Deferred tax assets | 45 | 6 | 7 | 8 | 17 | 58 | −4 | 9 | 146 | |
Other assets | 4,984 | 70 | 18 | 20 | 23 | 316 | 113 | 21 | 5,565 | |
Total assets | 23,838 | 5,778 | 5,690 | 4,895 | 5,099 | 18,871 | 83,769 | 61,487 | −486 | 208,941 |
1
Includes Investments for risk of policyholders. Although individual Investments for risk of policyholders may (or may not) have a maturity depending on their nature, this does not impact the liquidity position of NN Group.
NN Group N.V. Annual Report 2024 | 331
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
36 Liabilities by maturity
The tables below include all liabilities by maturity based on contractual, undiscounted cash flows.
Furthermore, the undiscounted future coupon interest on financial liabilities payable is included in a separate
line and in the relevant maturity bucket. Derivative liabilities are included on a net basis if cash flows are
settled net. For other derivative liabilities the contractual gross cash flow payable is included.
Reference is made to the Liquidity Risk paragraph in Note 48 ‘Risk management’ for a description on how
liquidity risk is managed.
| Liabilities by maturity (2024) | ||||||||||
| Maturity not | ||||||||||
2024 | Less than 1 year | 1-2 years | 2-3 years | 3-4 years | 4-5 years | 5-10 years | Over 10 years | applicable | Adjustment 1 | Total |
| Insurance contracts | 11,676 | 11,553 | 9,877 | 11,163 | 8,852 | 35,885 | 129,233 | −70,698 | 147,541 | |
| Investment contracts | 77 | 69 | 67 | 64 | 63 | 292 | 263 | 2,964 | 3,859 | |
Reinsurance contracts | 10 | 4 | 3 | 3 | 4 | 19 | 115 | −46 | 112 | |
Debt instruments issued | 600 | 600 | −4 | 1,196 | ||||||
Subordinated debt 2 | 850 | 1,500 | −4 | 2,346 | ||||||
Other borrowed funds | 2,799 | 790 | 798 | 987 | 493 | 940 | 1,180 | 7,987 | ||
Customer deposits | 11,010 | 1,214 | 863 | 603 | 562 | 1,921 | 1,301 | 17,474 | ||
Derivatives | 527 | 461 | 584 | 625 | 727 | 2,302 | 7,228 | −8,783 | 3,671 | |
Deferred tax liabilities | 191 | 11 | 24 | 39 | 20 | 41 | −648 | 1,086 | 764 | |
Other liabilities | 2,973 | 466 | 52 | 36 | 29 | 92 | 60 | 65 | 3,773 | |
Total liabilities | 29,263 | 14,568 | 12,268 | 14,970 | 10,750 | 43,592 | 138,732 | 4,115 | −79,535 | 188,723 |
Coupon interest due on financial liabilities | 211 | 356 | 337 | 286 | 260 | 1,037 | 1,433 | 3,920 |
1
This column reconciles the contractual undiscounted cash flow on financial liabilities to the balance sheet values. The adjustments mainly relate to valuation differences, the impact of discounting and, for derivatives, to the fact that the contractual cash flows are presented on a gross
basis (unless the cash flows are actually settled net).
2
Subordinated debt maturities are presented based on the first call date. For the legal date of maturity reference is made to Note 16 ‘Subordinated debt’.
NN Group N.V. Annual Report 2024 | 332
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
| Liabilities by maturity (2023) | ||||||||||
| Maturity not | ||||||||||
2023 | Less than 1 year | 1-2 years | 2-3 years | 3-4 years | 4-5 years | 5-10 years | Over 10 years | applicable | Adjustment 1 | Total |
Insurance contracts | 11,232 | 11,247 | 11,080 | 10,025 | 9,329 | 39,060 | 113,466 | −60,375 | 145,064 | |
Investment contracts | 71 | 65 | 64 | 65 | 65 | 324 | 305 | 2,662 | 3,621 | |
Reinsurance contracts | 12 | 3 | 1 | −1 | 3 | 152 | −3 | −23 | 144 | |
Debt instruments issued | 600 | 600 | −5 | 1,195 | ||||||
Subordinated debt 2 | 335 | 850 | 1,500 | −5 | 2,680 | |||||
Other borrowed funds | 3,872 | 1,008 | 790 | 796 | 956 | 1,407 | 1,164 | −1 | 9,992 | |
Customer deposits | 10,942 | 855 | 723 | 510 | 421 | 1,732 | 1,277 | 16,460 | ||
Derivatives | 543 | 316 | 448 | 597 | 482 | 2,192 | 7,493 | 1 | −8,005 | 4,067 |
Deferred tax liabilities | 87 | −6 | 1 | −13 | 17 | 141 | −734 | 1,066 | 559 | |
Other liabilities | 3,176 | 464 | 83 | 52 | 33 | 121 | 27 | 84 | 4,040 | |
Total liabilities | 30,270 | 13,952 | 13,190 | 12,632 | 12,152 | 47,080 | 123,150 | 3,809 | −68,413 | 187,822 |
Coupon interest due on financial liabilities | 297 | 198 | 291 | 247 | 210 | 900 | 1,654 | 0 | 0 | 3,797 |
1
This column reconciles the contractual undiscounted cash flow on financial liabilities to the balance sheet values. The adjustments mainly relate to the impact of discounting and, for derivatives, to the fact that the contractual cash flows are presented on a gross basis (unless the cash
flows are actually settled net).
2
Subordinated debt maturities are presented based on the first call date. For the legal date of maturity reference is made to Note 16 ‘Subordinated debt’.
NN Group N.V. Annual Report 2024 | 333
Consolidated annual accounts
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
Expected maturity of insurance contracts
The table below provides the expected maturity of the cash flows, risk adjustment and contractual service
margin remaining at the end of the reporting period. The maturity is based on contractual, undiscounted
cash flows.
| Expected maturity of insurance contracts (2024) | |||||||
| Total General | |||||||
| Estimates of the | Model and | Total Premium | |||||
| present value of | Contractual | Variable Fee | Allocation | Total Insurance | Total Insurance | ||
| 2024 | future cash flows | Risk adjustment | service margin | Approach | Approach | assets | liabilities |
Less than 1 year | 9,660 | 174 | 687 | 10,521 | 1,119 | 36 | 11,676 |
1-2 years | 10,334 | 140 | 590 | 11,064 | 423 | 66 | 11,553 |
2-3 years | 8,864 | 110 | 529 | 9,503 | 316 | 58 | 9,877 |
3-4 years | 10,280 | 118 | 479 | 10,877 | 237 | 49 | 11,163 |
4-5 years | 8,085 | 124 | 440 | 8,649 | 181 | 22 | 8,852 |
5-10 years | 33,289 | 458 | 1,627 | 35,374 | 407 | 104 | 35,885 |
Over 10 years | 124,382 | 857 | 3,598 | 128,837 | 189 | 207 | 129,233 |
Adjustments 1 | −69,563 | −692 | −70,255 | −310 | −133 | −70,698 | |
Total | 135,331 | 1,289 | 7,950 | 144,570 | 2,562 | 409 | 147,541 |
1
The adjustments reconciles the contractual undiscounted cash flow on insurance contracts to the balance sheet values. The adjustments mainly relate to the impact of discounting.
| Expected maturity of insurance contracts (2023) | |||||||
| Total General | |||||||
| Estimates of the | Model and | Total Premium | |||||
| present value of | Contractual | Variable Fee | Allocation | Total Insurance | Total Insurance | ||
| 2023 | future cash flows | Risk adjustment | service margin | Approach | Approach | assets | liabilities |
Less than 1 year | 9,242 | 163 | 698 | 10,103 | 1,078 | 51 | 11,232 |
1-2 years | 10,015 | 156 | 586 | 10,757 | 429 | 61 | 11,247 |
2-3 years | 10,043 | 148 | 528 | 10,719 | 308 | 53 | 11,080 |
3-4 years | 9,138 | 138 | 479 | 9,755 | 223 | 47 | 10,025 |
4-5 years | 8,551 | 131 | 436 | 9,118 | 170 | 41 | 9,329 |
5-10 years | 36,350 | 545 | 1,638 | 38,533 | 379 | 148 | 39,060 |
Over 10 years | 109,646 | 918 | 2,607 | 113,171 | 185 | 110 | 113,466 |
Adjustments 1 | −59,604 | −400 | −60,004 | −215 | −156 | −60,375 | |
Total | 133,381 | 1,799 | 6,972 | 142,152 | 2,557 | 355 | 145,064 |
1
The adjustments reconciles the contractual undiscounted cash flow on insurance contracts to the balance sheet values. The adjustments mainly relate to the impact of discounting.
Amounts payable on demand were EUR 56,328 million as at 31 December 2024 (EUR 58,763 million as at 31 December 2023).
NN Group N.V. Annual Report 2024 | 334
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
Assets relating to instruments lending are disclosed in Note 38 ‘Transferred, but not derecognised financial
assets’. Assets in securitisation programmes originated by NN Bank are disclosed in Note 43 ‘Structured
entities’.
38 Transferred, but not derecognised financial assets
The majority of NN Group’s financial assets that have been transferred, but do not qualify for derecognition,
are debt instruments used in securities lending. NN Group retains substantially all risks and rewards of those
transferred assets. The assets are transferred in return for cash collateral or other financial assets. Non-cash
collateral is not recognised in the balance sheet. Cash collateral is recognised as an asset and an offsetting
liability is established for the same amount as NN Group is obligated to return this amount upon termination
of the lending arrangement.
Transfer of financial assets not qualifying for derecognition
2024 | 2023 | |
Investments at fair value through other comprehensive income | 8,720 | 8,994 |
Investments at fair value through profit or loss | 8 |
The table above does not include assets transferred to consolidated securitisation entities, as these related
assets are not transferred from a consolidated perspective. Reference is made to Note 43 ‘Structured
entities’.
NN Group N.V. Annual Report 2024 | 335
Consolidated annual accounts
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
39 Offsetting of financial assets and liabilities
| Financial assets subject to offsetting, enforceable master netting arrangements and similar agreements (2024) | Related amounts not offset in the | ||||||
| 2024 | |||||||
| balance sheet | |||||||
| Gross financial | Cash and | ||||||
| liabilities | Net financial | financial | |||||
| Gross financial | offset in the | assets in the | Financial | instruments | |||
Balance sheet line item | Financial instrument | assets | balance sheet | balance sheet | instruments | collateral | Net amount |
Derivatives | Derivatives | 2,684 | 2,684 | −1,257 | −1,386 | 41 | |
Other items where offsetting is applied in the balance sheet | Other assets | 439 | 439 | −349 | −86 | 4 | |
Total financial assets | 3,123 | 0 | 3,123 | −1,606 | −1,472 | 45 |
| Financial assets subject to offsetting, enforceable master netting arrangements and similar agreements (2023) | Related amounts not offset in the | ||||||
| 2023 | |||||||
| balance sheet | |||||||
| Cash and | |||||||
| Net financial | financial | ||||||
| Gross financial | assets in the | Financial | instruments | ||||
Balance sheet line item | Financial instrument | assets | Net amount | balance sheet | instruments | collateral | Net amount |
Derivatives | Derivatives | 2,447 | 2,447 | −1,172 | −1,273 | 2 | |
Other items where offsetting is applied in the balance sheet | Other assets | 404 | 404 | −350 | −53 | 1 | |
Total financial assets | 2,851 | 0 | 2,851 | −1,522 | −1,326 | 3 |
NN Group N.V. Annual Report 2024 | 336
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
| Financial liabilities subject to offsetting, enforceable master netting arrangements and similar agreements (2024) | Related amounts not offset in the | ||||||
| 2024 | |||||||
| balance sheet | |||||||
| Gross financial | Cash and | ||||||
| assets | Net financial | financial | |||||
| Gross financial | offset in the | liabilities in the | Financial | instruments | |||
Balance sheet line item | Financial instrument | liabilities | balance sheet | balance sheet | instruments | collateral | Net amount |
Derivatives | Derivatives | 3,518 | 3,518 | −1,257 | −2,211 | 50 | |
Repo’s and Other items where offsetting is applied in the balance sheet | 1,686 | 1,686 | −349 | −1,336 | 1 | ||
Total financial liabilities | 5,204 | 0 | 5,204 | −1,606 | −3,547 | 51 |
| Financial liabilities subject to offsetting, enforceable master netting arrangements and similar agreements (2023) | Related amounts not offset in the | ||||||
| 2023 | |||||||
| balance sheet | |||||||
| Gross financial | Cash and | ||||||
| assets | Net financial | financial | |||||
| Gross financial | offset in the | liabilities in the | Financial | instruments | |||
Balance sheet line item | Financial instrument | liabilities | balance sheet | balance sheet | instruments | collateral | Net amount |
Derivatives | Derivatives | 3,922 | 3,922 | −1,172 | −2,608 | 142 | |
Repo’s and Other items where offsetting is applied in the balance sheet | 2,980 | 2,980 | −350 | −2,599 | 31 | ||
Total financial liabilities | 6,902 | 0 | 6,902 | −1,522 | −5,207 | 173 |
NN Group N.V. Annual Report 2024 | 337
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
| Contingent liabilities and commitments (2024) | |||||||||
| Maturity | |||||||||
| Less than | Over 10 | not | |||||||
| 2024 | 1 year | 1-2 years | 2-3 years | 3-4 years | 4-5 years | 5-10 years | years | applicable | Total |
Commitments | 1,281 | 92 | 22 | 1,395 | |||||
Guarantees | 18 | 18 | |||||||
Contingent liabilities and commitments | 1,299 | 92 | 0 | 0 | 0 | 0 | 22 | 0 | 1,413 |
| Contingent liabilities and commitments (2023) | |||||||||
| Maturity | |||||||||
| Less than | Over 10 | not | |||||||
| 2023 | 1 year | 1-2 years | 2-3 years | 3-4 years | 4-5 years | 5-10 years | years | applicable | Total |
Commitments | 1,333 | 160 | 19 | 1,512 | |||||
Guarantees | 18 | 18 | |||||||
Contingent liabilities and commitments | 1,351 | 160 | 0 | 0 | 0 | 0 | 19 | 0 | 1,530 |
NN Group N.V. Annual Report 2024 | 338
Consolidated annual accounts
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
NN Group N.V. Annual Report 2024 | 339
Consolidated annual accounts
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
43 Structured entities
NN Group’s activities involve transactions with structured entities in the normal course of business. A
structured entity is an entity that has been designed so that voting or similar rights are not the dominant
factor in deciding who controls the entity, such as when any voting rights relate to administrative tasks only
and the relevant activities are directed through contractual arrangements. NN Group’s involvement in these
entities varies and includes both debt financing and equity financing of these entities as well as other
relationships. Based on its accounting policies, as disclosed in Note 1 ‘Accounting policies’, NN Group
establishes whether these involvements result in no significant influence, significant influence, joint control
or control over the structured entity.
The structured entities over which NN Group can exercise control are consolidated. NN Group may provide
support to these consolidated structured entities as and when appropriate, however this is fully reflected in
the Consolidated annual accounts of NN Group as all assets and liabilities of these entities are included in
the Consolidated balance sheet and off-balance sheet commitments are disclosed.
| Mortgage loans securitised | RMBS issued and held by third | ||||
Maturity year | Related mortgage loans | parties | |||
2024 | 2023 | 2024 | 2023 | ||
Soft Bullet Covered Bonds | 2024-2041 | 8,535 | 9,257 | 7,327 | 8,322 |
Total | 8,535 | 9,257 | 7,327 | 8,322 |
NN Group N.V. Annual Report 2024 | 340
Consolidated annual accounts
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
NN Group has significant influence for some of its real estate investment funds as disclosed in Note 7
‘Investments in associates and joint ventures’.
The maximum exposure to loss for NN Group is equal to the reported carrying value of the investment
recognised in the balance sheet of NN Group.
2024 | 2023 | |
Assets | 83 | 85 |
Income | 4 | 4 |
45 Key management personnel compensation
Transactions with key management personnel (Executive Board, Management Board and Supervisory Board)
are transactions with related parties. These transactions are disclosed in more detail as required by Part 9
Book 2 of the Dutch Civil Code in sections II and III in the remuneration report in the financial report. These
sections of the remuneration report are therefore part of the annual accounts.
NN Group N.V. Annual Report 2024 | 341
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Notes to the Consolidated annual accounts continued
| 2024 | |||
| Executive Board and Management Board (2024) | |||
| Executive | Management | ||
| Amounts in thousands of euros | Board | Board | Total |
| Fixed compensation | |||
– base salary (cash) | 2,733 | 4,563 | 7,296 |
– base salary (fixed shares) | 683 | 1,141 | 1,824 |
– pension costs 1 | 58 | 173 | 231 |
– individual saving allowance 1 | 732 | 1,136 | 1,868 |
| Variable compensation | |||
– upfront cash | 124 | 167 | 291 |
– upfront shares | 124 | 167 | 291 |
– deferred cash | 186 | 250 | 436 |
– deferred shares | 186 | 250 | 436 |
Fixed and variable compensation | 4,826 | 7,847 | 12,673 |
Other benefits | 149 | 296 | 445 |
Employer cost social security 2 | 108 | 215 | 323 |
Total compensation | 5,083 | 8,358 | 13,441 |
1
The pension costs consist of an amount of employer contribution (EUR 231 thousand) and an individual savings allowance (EUR 1,868 thousand which is
23,3% of the amount of base salary above EUR 137,800).
2
The employer cost social security does not impact the overall remuneration received by the Executive Board and Management Board members.
In the table above, ‘Executive Board’ refers to the two members of the Executive Board as at 31 December
2024. The two members of the Executive Board are also members of the Management Board. In the table
above, ‘Management Board’ refers to the six members of the Management Board as at 31 December 2024,
i.e. those members that are not also member of the Executive Board. In the table above ‘Total’ refers to all
members of the Management Board during 2024.
Remuneration of the members of the Executive Board and the Management Board is recognised in the profit
and loss account in ‘Staff expenses’ as part of ‘Total expenses’. The total remuneration as disclosed in the
table above (for 2024: EUR 13.4 million) includes all variable remuneration related to the performance year
2024. Under IFRS-EU, certain components of variable remuneration are not recognised in the profit and loss
account directly, but are allocated over the vesting period of the award. The comparable amount recognised
in staff expenses in 2024 and therefore included in ‘Total expenses’ in 2024, relating to the fixed expenses
of 2024 and the vesting of variable remuneration of 2024 and earlier performance years, is EUR 13.3 million.
As at 31 December 2024, members of the Executive Board and Management Board held a total of 166,511
NN Group N.V. shares.
In 2024, 18,306 share awards on NN Group N.V. (both deferred and upfront) were granted to the Executive
Board and Management Board.
| Supervisory Board (2024) | |
| Supervisory | |
| Amounts in thousands of euros | Board |
Fixed fees | 801 |
Expense allowances | 63 |
Compensation Supervisory Board | 864 |
As at 31 December 2024, members of the Supervisory Board held no NN Group N.V. shares.
| Loans and advances to members of the Management Board (2024) | |||
| Amount | |||
| outstanding | Average | ||
| Amounts in thousands of euros | 31 December | interest rate | Repayments |
Management Board members | 349 | 2.34% | 3 |
Loans and advances | 349 | 3 |
As at 31 December 2024, no loans and advances were provided to members of the Executive Board and
Supervisory Board.
NN Group N.V. Annual Report 2024 | 342
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Notes to the Consolidated annual accounts continued
| 2023 | |||
| Executive Board and Management Board (2023) | |||
| Executive | Management | ||
| Amounts in thousands of euros | Board | Board 2 | Total |
| Fixed compensation | |||
– base salary (cash) | 2,597 | 4,131 | 6,728 |
– base salary (fixed shares) | 649 | 1,033 | 1,682 |
– pension costs 1 | 54 | 157 | 211 |
– individual saving allowance 1 | 696 | 1,029 | 1,725 |
| Variable compensation | |||
– upfront cash | 112 | 171 | 283 |
– upfront shares | 112 | 171 | 283 |
– deferred cash | 168 | 257 | 425 |
– deferred shares | 168 | 257 | 425 |
Fixed and variable compensation | 4,556 | 7,206 | 11,762 |
Other benefits | 139 | 282 | 421 |
Employer cost social security 2 | 138 | 192 | 330 |
Total compensation | 4,833 | 7,680 | 12,513 |
1
The pension costs consist of an amount of employer contribution (EUR 211 thousand) and an individual savings allowance (EUR 1,724 thousand which is
23,3% of the amount of base salary above EUR 128,810).
2
The employer cost social security does not impact the overall remuneration received by the Executive Board and Management Board members.
In the table above, ‘Executive Board’ refers to the two members of the Executive Board as at 31 December
2023. The two members of the Executive Board are also members of the Management Board. In the table
above, ‘Management Board’ refers to the six members of the Management Board as at 31 December 2023,
i.e. those members that are not also member of the Executive Board. In the table above ‘Total’ refers to all
members of the Management Board during 2023.
Remuneration of the members of the Executive Board and the Management Board is recognised in the profit
and loss account in ‘Staff expenses’ as part of ‘Total expenses’. The total remuneration as disclosed in the
table above (for 2023: EUR 12.5 million) includes all variable remuneration related to the performance year
2023. Under IFRS-EU, certain components of variable remuneration are not recognised in the profit and loss
account directly, but are allocated over the vesting period of the award. The comparable amount recognised
in staff expenses in 2023 and therefore included in ‘Total expenses’ in 2023, relating to the fixed expenses
of 2023 and the vesting of variable remuneration of 2023 and earlier performance years, is EUR 12.5 million.
As at 31 December 2023, members of the Executive Board and Management Board held a total of 160,574
NN Group N.V. shares.
In 2023, 15,099 share awards on NN Group N.V. (both deferred and upfront) were granted to the Executive
Board and Management Board.
| Supervisory Board (2023) | |
| Supervisory | |
| Amounts in thousands of euros | Board |
Fixed fees | 812 |
Expense allowances | 67 |
Compensation Supervisory Board | 879 |
As at 31 December 2023, members of the Supervisory Board held no NN Group N.V. shares.
| Loans and advances to members of the Management Board (2023) | |||
| Amount | |||
| outstanding | Average | ||
| Amounts in thousands of euros | 31 December | interest rate | Repayments |
Management Board members | 352 | 2.41% | 9 |
Loans and advances | 352 | 9 |
As at 31 December 2023, no loans and advances were provided to members of the Executive Board and
Supervisory Board.
NN Group N.V. Annual Report 2024 | 343
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
2024 | 2023 | |
Audit fees | 23 | 20 |
Audit related fees | 2 | 5 |
Fees of auditors NN Group N.V. | 25 | 25 |
NN Group N.V. Annual Report 2024 | 344
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
47 Subsequent and other events
Turkey
On 10 January 2025, the sale of NN Turkey was completed. Reference is made to Note 42 'Companies and
businesses acquired and divested'.
Share buyback
In February 2025, NN Group announced that it will execute an open market share buyback programme for an
amount of EUR 300 million. The programme will be executed within nine months and commenced on 3 March
2025. NN Group intends to cancel any repurchased NN Group shares under the programmes unless used to
cover obligations under share-based remuneration arrangements.
Tender offer for its subordinated notes
In March 2025, NN Group announced a tender for purchase by NN Group of the EUR 1 billion Fixed to Floating
Rate Undated Subordinated Notes for cash at a price of 101.6% of the nominal amount. The tender was
completed in March 2025 and NN Group accepted the purchase of EUR 763 million in nominal amount.
In March 2025, NN Group issued euro-denominated, perpetual, restricted Tier 1, temporary write-down
securities for an amount of EUR 1 billion. The notes are first callable on 11 September 2034. The coupon is
fixed at 5.75% per annum until 11 March 2035 and will be reset every fifth year thereafter.
48 Risk management
This note explains details with regard to the risk profile of NN Group.
Topics described in this section include:
∙ Partial Internal Model (PIM) (including assumptions and limitations).
∙ Solvency Capital Requirement of NN Group.
∙ Risk profile, risk mitigation and risk measurement of the main types of risks: Market risk, Counterparty
default risk, Liquidity risk and Non-market risk.
1. Partial Internal Model (PIM)
The Solvency Capital Requirement (SCR) is calculated based on the actual risk exposure of NN Group. Under
Solvency II, the SCR is the capital required to ensure that the (re) insurance company will be able to meet its
obligations over the next 12 months with a probability of at least 99.5%. The risk-based framework for
calculating Solvency Capital Requirements at NN Group is a combination of an Internal Model (IM) and
Standard Formula (SF) components, the so-called Partial Internal Model (PIM). The major Dutch insurance
entities use an internal model for modelling SCR for Market, Counterparty default and Non-market risks. The
determined SCR is used for both, local reporting and group consolidation purposes. For the EU-based
international insurance businesses and smaller insurance undertakings in the Netherlands, NN Group uses
the Solvency II Standard Formula to calculate the SCR for local reporting and for Group consolidation. The
capital requirement for Operational risk is based on the Standard Formula approach across the Group.
The non-insurance businesses (e.g. Pension Funds, NN Bank) and international insurance undertakings not
based in the EU (e.g. Japan) are consolidated in the Group SCR based on the local applicable (sectoral)
capital requirements. The Solvency II concept of (provisional) Equivalence is granted to capital frameworks
that are deemed to have similarity with the Solvency II framework and/or principles and as such can be relied
upon to assess capital requirements. At NN Group, the (provisional) Equivalence applies to Japan. The total
Group SCR is obtained from the Internal Model and Standard Formula capital requirements using EIOPA’s
integration technique 3 and the capital requirements for non-insurance businesses and international
insurance undertakings not based in the EU.
The choice for a Partial Internal Model is based on the conviction that an Internal Model in general better
reflects the risk profile of the major Dutch (re) insurance entities and has additional benefits for risk
management purposes, whilst the Standard Formula adequately captures the risk profile of the international
businesses and smaller Dutch entities:
NN Group N.V. Annual Report 2024 | 345
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Notes to the Consolidated annual accounts continued
2.4 Model limitations
NN Group’s Partial Internal Model set-up resulted from managing a balance between (1) an easy-to-
communicate methodology and (2) efficient calculations with appropriate accuracy and granularity to reflect
the underlying risks. Despite several limitations stemming from this, the PIM is considered to be adequate to
assess NN Group’s risk profile, to determine Solvency Capital Requirements and to be used in key decision
making processes (use test).
As a result of the granular modelling approach and the wide variety of NN Group’s assets and liabilities, the
PIM is more complex than the Standard Formula.
Inherent model limitations of the PIM are related to the calibration of a 1-in-200-year stress event for a full
spectrum of Market and Non-market risks, which are based on sometimes limited historical data. Limitations
also relate to the overall aim of determining forward-looking distributions of risk factors under stress based
on historical data as well as the use of modelling assumptions and expert judgements.
The components of NN Group’s PIM for Market and Counterparty default risk and the models for risk
aggregation and replication have been developed and are run centrally and thus carry an inherent risk that
the developed models include aspects which might be less appropriate for individual entities. On a regular
basis the business units perform ‘Fit For Local Use’ assessments. Models also undergo regular reviews and
monitoring, under agreed governance, and in addition, model validations are performed by an independent
model validation function. Such reviews can result in additional monitoring and/or locally calculated and
further centrally processed adjustments.
The Risk Management function informs the Management Board and Supervisory Board on an annual basis on
the performance of the Internal Model.
3. Solvency II 2020 review
After a long period of negotiations between the European Commission, the European Council and the
European Parliament, a revised Solvency II directive (Level I) was published in the Official Journal of
8 January 2025. The amended regulation will be effective as of 30 January 2027, wich means that reporting
after this date will reflect the changes from the Solvency II 2020 review. Some key aspects in the agreement
are not detailed out in the Solvency II directive but will be clarified later in the process (part of Level II and
III). This relates for example to the parameterisation of elements that are relevant for the determination of
the risk margin and the Volatility Adjustment. The revised Solvency II directive forms the basis for the
revision of the Level II and III regulation, which can lead to further changes.
NN Group N.V. Annual Report 2024 | 346
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Notes to the Consolidated annual accounts continued
4. Solvency Capital Requirement
4.1 Solvency II ratio of NN Group
The following table shows the NN Group Solvency II ratio as at 31 December 2024 and 31 December 2023,
respectively.
Solvency II ratio of NN Group
2024 | 2023 | |
Eligible Own Funds | 17,026 | 17,691 |
Solvency Capital Requirement | 8,786 | 8,990 |
NN Group Solvency II ratio (Eligible Own Funds/SCR) | 194% | 197% |
The SCR is based on NN Group’s PIM. This comprises Internal Model calculations for all risks, except for
Operational risk, for NN Life, NN Non-life, NN Re and the main holding companies owned by NN Group N.V.
and SF calculations for ABN AMRO Non-life and the international insurance entities of NN Group in Europe.
SCR for Operational risk is calculated using the Standard Formula for all Solvency II entities. The capital
requirements of non-Solvency II entities, in particular NN Life Japan, Pension Funds, and NN Bank are
calculated using local sectoral rules.
4.2 Solvency Capital Requirement
The following table shows the NN Group SCR as at 31 December 2024 and 31 December 2023, respectively.
Solvency Capital Requirements
2024 | 2023 | |
Market risk | 6,555 | 6,602 |
Counterparty default risk | 112 | 129 |
Non-market risk | 4,966 | 4,773 |
Total BSCR (before diversification) | 11,633 | 11,504 |
Diversification | −3,085 | −2,659 |
Total BSCR (after diversification) | 8,548 | 8,845 |
Operational risk | 567 | 560 |
LACDT | −1,757 | −1,780 |
Other | 5 | 4 |
Solvency II entities SCR | 7,363 | 7,629 |
Non Solvency II entities | 1,423 | 1,361 |
Total SCR | 8,786 | 8,990 |
The Solvency II total Basic Solvency Capital Requirement (total BSCR after diversification) includes both the
PIM businesses’ BSCR and the Standard Formula businesses’ BSCR. This figure also reflects the
diversification benefits between the business units using Internal Model and Standard Formula.
The general developments of the Basic SCR (BSCR):
∙ Lower Market risk SCR, mainly due to portfolio developments, partially offset by model refinements and
market movements.
∙ Lower Counterparty default risk SCR, driven by various portfolio developments.
∙ Higher Non-market risk SCR, mainly driven by lower interest rates and the impact of model changes mainly
at NN Non-Life, partially offset by the impact of longevity reinsurance at NN Life.
More details on the Market and Non-market risk SCR, as well as explanation on the most important changes
in the risk profile, are presented in the next sections.
NN Group N.V. Annual Report 2024 | 347
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Notes to the Consolidated annual accounts continued
SCR for Operational risk is broadly stable. The offsetting effect of Loss Absorbing Capacity of Deferred Taxes
(LACDT) decreased mainly due to a lower tax base. In the above table, ‘Other’ includes loss-absorbing
capacity of technical provisions (LACTP) and capital requirements for non-modelled Solvency II entities.
4.3 Solvency II ratio sensitivities
Along with the SCR, NN Group regularly calculates the sensitivities of the Solvency II ratio under various
scenarios, by assessing the changes for both Eligible Own Funds and SCR. The Solvency II ratio sensitivities
are primarily designed to support the NN Group Management Board and the Risk Management functions in
having a forward-looking view on the risks to solvency of the company, and to analyse the impacts of market
or other events. Additionally, Solvency II ratio sensitivities are used for external communication to enable
investors to assess the potential volatility of the company’s solvency ratio. The sensitivities are selected to
reflect plausible, realistic scenarios that could materialise within the foreseeable future and are not
calibrated on a pre-defined confidence interval or time horizon.
The effect on the Solvency II ratio is calculated based on applying an instantaneous stress on the balance
sheet, and on ceteris paribus basis. For all Solvency II insurance entities, NN Life Japan and NN Bank, the
after stress Own Funds are calculated for each of the sensitivity scenarios; the impacts on SCR are
recalculated for the BSCR and Operational risk SCR components. LACDT is recalculated keeping the LACDT
percentage fixed. ‘Other’ SCR components including the LACTP are kept constant.
The Solvency II sensitivities are disclosed for the main Market risks in the sections below.
Main types of risks
In the next sections the main risks associated with NN Group’s business are discussed. Each risk type is
analysed through the risk profile, risk mitigation and risk measurement. For Market and Non-market risks
more detailed quantification of risk exposures are provided.
We assess natural catastrophe risks such as windstorm, flood and hail (depended on the business unit's
exposure to these risks) in our current SCR models considering losses over the next one-year horizon under
a 1-in-200 year event. Furthermore, we regularly conduct assessments into the financial materiality of
sustainability risks on our balance sheet. NN has concluded that the calculation of SCR does not require any
adjustments at this point due to risks related to sustainability, as these risks are either covered by the SCR
or not considered material over this time horizon.
| Market risk capital requirements | ||
2024 | 2023 | |
Interest rate risk | 1,163 | 898 |
Equity risk | 2,186 | 2,457 |
Credit spread risk | 3,659 | 3,340 |
Real estate risk | 1,907 | 2,014 |
Foreign exchange risk | 519 | 584 |
Inflation risk | 231 | 216 |
Basis risk | 56 | 53 |
Diversification market risk | −3,166 | −2,960 |
Market risk | 6,555 | 6,602 |
NN Group N.V. Annual Report 2024 | 348
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Notes to the Consolidated annual accounts continued
Market value | % of total | Market value | % of total | |
2024 | 2024 | 2023 | 2023 | |
Fixed income | 132,556 | 82% | 136,530 | 81% |
Government bonds and loans | 39,492 | 24% | 40,046 | 24% |
Financial bonds and loans | 7,918 | 5% | 7,671 | 5% |
Corporate bonds and loans | 23,325 | 14% | 23,308 | 14% |
Asset-backed securities | 2,423 | 2% | 2,642 | 2% |
Mortgages 1 | 58,265 | 36% | 61,729 | 37% |
Other retail loans | 1,133 | 1% | 1,134 | 1% |
Non-fixed income | 20,335 | 13% | 20,448 | 12% |
Common & preferred stock 2 | 2,770 | 2% | 3,533 | 2% |
Private equity | 106 | 0% | 138 | 0% |
Real estate 3 | 11,932 | 8% | 12,007 | 7% |
Mutual funds (money market funds excluded) 4 | 5,527 | 3% | 4,770 | 3% |
| Money market instruments (money market funds | ||||
included) 5 | 8,471 | 5% | 10,682 | 6% |
Total investments | 161,362 | 100% | 167,660 | 100% |
NN Group N.V. Annual Report 2024 | 349
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
| Own Funds | Solvency II ratio | ||
impact | SCR impact | impact | |
Interest rate: Parallel shock +50 bps | −407 | −226 | 0% |
Interest rate: Parallel shock -50 bps | 451 | 247 | -0% |
Interest rate: 10 bps steepening between 20y-30y | −129 | −8 | −1% |
| Own Funds | Solvency II ratio | ||
impact | SCR impact | impact | |
Interest rate: Parallel shock +50 bps | −343 | −224 | 1% |
Interest rate: Parallel shock -50 bps | 393 | 251 | −1% |
Interest rate: 10 bps steepening between 20y-30y | −151 | −7 | −2% |
2024 | 2023 | |
Common & preferred stock | 2,770 | 3,533 |
Private equity | 106 | 138 |
Mutual funds (money market funds are excluded, fixed income mutual funds are included) | 5,527 | 4,770 |
Total | 8,403 | 8,441 |
NN Group N.V. Annual Report 2024 | 350
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
| Own Funds | Solvency II ratio | ||
impact | SCR impact | impact | |
Equity Downward shock -25% | −1,0 81 | −160 | −9% |
| Own Funds | Solvency II ratio | ||
impact | SCR impact | impact | |
Equity Downward shock -25% | −1,604 | −299 | −12% |
| Fixed-income bonds and loans by type of issuer | ||||
Market value | Percentage | |||
2024 | 2023 | 2024 | 2023 | |
Sovereign | 39,492 | 40,046 | 54% | 54% |
Finance and Insurance | 7,918 | 7,671 | 11% | 10% |
Manufacturing | 7,089 | 6,560 | 10% | 9% |
Utilities | 2,504 | 2,585 | 3% | 4% |
Asset-backed securities | 2,423 | 2,642 | 3% | 4% |
Transportation and Warehousing | 1,885 | 2,114 | 3% | 3% |
Information | 1,697 | 1,778 | 2% | 2% |
Real Estate and Rental and Leasing | 1,589 | 1,800 | 2% | 2% |
Other | 8,561 | 8,471 | 12% | 12% |
Total | 73,158 | 73,667 | 100% | 100% |
NN Group N.V. Annual Report 2024 | 351
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Notes to the Consolidated annual accounts continued
Market value of government bond and loans in 2024 by number of years to maturity 3 | |||||||||||
| Domestic | |||||||||||
2024 | Rating 1 | exposure 2 | 0-1 | 1-2 | 2-3 | 3-5 | 5-10 | 10-20 | 20-30 | 30+ | Total 2024 |
Japan | A+ | 100% | 394 | 284 | 321 | 652 | 1,391 | 1,692 | 1,314 | 519 | 6,567 |
France | AA- | 0% | 73 | 80 | 43 | 100 | 204 | 1,355 | 347 | 2,063 | 4,265 |
Belgium | AA- | 27% | 7 | 58 | 329 | 327 | 1,578 | 936 | 618 | 3,853 | |
Netherlands | AAA | 99% | 51 | 9 | 13 | 250 | 320 | 2,699 | 267 | 9 | 3,618 |
Germany | AAA | 0% | 30 | 99 | 53 | 353 | 926 | 1,228 | 413 | 210 | 3,312 |
Spain | A- | 30% | 114 | 43 | 24 | 262 | 190 | 1,591 | 125 | 79 | 2,428 |
European Union | AAA | 0% | 5 | 24 | 3 | 3 | 213 | 791 | 1,305 | 2,344 | |
Austria | AA+ | 0% | 157 | 233 | 7 | 38 | 512 | 257 | 1,098 | 2,302 | |
United States | AA+ | 0% | 205 | 1,369 | 1,574 | ||||||
Finland | AA+ | 0% | 162 | 3 | 1 | 68 | 1 | 722 | 48 | 54 | 1,059 |
Italy | BBB | 0% | 9 | 4 | 103 | 174 | 317 | 111 | 270 | 35 | 1,023 |
Other 4 - Above Investment Grade | 263 | 317 | 245 | 738 | 1,385 | 1,552 | 1,606 | 82 | 6,188 | ||
Other 4 - Below Investment Grade | 4 | 61 | 106 | 644 | 106 | 38 | 959 | ||||
Total | 1,108 | 1,082 | 1,100 | 3,042 | 5,956 | 14,142 | 8,295 | 4,767 | 39,492 |
NN Group N.V. Annual Report 2024 | 352
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Notes to the Consolidated annual accounts continued
Market value of government bond and loans in 2023 by number of years to maturity 4 | |||||||||||
| Domestic | |||||||||||
2023 | Rating 1 | exposure 2 | 0-1 | 1-2 | 2-3 | 3-5 | 5-10 | 10-20 | 20-30 | 30+ | Total 2023 |
Japan | A+ | 100% | 413 | 418 | 305 | 681 | 1,665 | 1,913 | 1,594 | 654 | 7,643 |
France | AA | 0% | 55 | 24 | 79 | 46 | 307 | 1,413 | 353 | 3,135 | 5,412 |
Germany | AAA | 0% | 316 | 18 | 96 | 418 | 501 | 1,647 | 607 | 209 | 3,812 |
Belgium | AA- | 28% | 11 | 11 | 62 | 335 | 135 | 1,741 | 1,052 | 622 | 3,969 |
Netherlands | AAA | 99% | 2 | 95 | 11 | 247 | 328 | 2,280 | 158 | 244 | 3,365 |
Austria | AA+ | 0% | 11 | 168 | 241 | 1 | 145 | 495 | 1,134 | 2,195 | |
Spain | A- | 29% | 109 | 101 | 46 | 74 | 428 | 1,176 | 512 | 76 | 2,522 |
United States | AAA | 0% | 208 | 1,432 | 1,640 | ||||||
Multilateral 3 | AAA | 0% | 63 | 11 | 133 | 66 | 327 | 872 | 592 | 22 | 2,086 |
Finland | AA+ | 0% | 4 | 143 | 3 | 66 | 1 | 712 | 50 | 979 | |
Italy | BBB | 0% | 17 | 9 | 4 | 133 | 395 | 177 | 250 | 33 | 1,018 |
Other 5 – Above Investment Grade | 315 | 268 | 178 | 462 | 1,461 | 1,267 | 696 | 69 | 4,716 | ||
Other 5 – Below Investment Grade | 3 | 113 | 410 | 125 | 37 | 688 | |||||
Total | 1,316 | 1,098 | 1,088 | 2,882 | 5,959 | 13,676 | 7,828 | 6,198 | 40,045 |
NN Group N.V. Annual Report 2024 | 353
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Notes to the Consolidated annual accounts continued
| Market value non-government bond securities and loans (2024) | |||||||||
| Market value of non-government bond securities and loans in 2024 by number of years to maturity | |||||||||
2024 | 0-1 | 1-2 | 2-3 | 3-5 | 5-10 | 10-20 | 20-30 | 30+ | Total 2024 |
AAA | 344 | 212 | 196 | 88 | 572 | 783 | 888 | 962 | 4,045 |
AA | 213 | 277 | 330 | 494 | 589 | 405 | 80 | 84 | 2,472 |
A | 1,022 | 1,424 | 1,191 | 2,281 | 3,920 | 1,420 | 847 | 142 | 12,247 |
BBB | 1,044 | 1,529 | 1,140 | 1,808 | 3,031 | 1,518 | 560 | 66 | 10,696 |
BB | 362 | 190 | 378 | 799 | 509 | 70 | 13 | 2,321 | |
B and below | 173 | 186 | 115 | 713 | 292 | 54 | 11 | 1,544 | |
No rating available | 143 | 84 | 18 | 70 | 25 | 340 | |||
Total | 3,301 | 3,902 | 3,368 | 6,253 | 8,938 | 4,250 | 2,386 | 1,267 | 33,665 |
| Market value non-government bond securities and loans (2023) | |||||||||
| Market value of non-government bond securities and loans in 2023 by number of years to maturity | |||||||||
2023 | 0-1 | 1-2 | 2-3 | 3-5 | 5-10 | 10-20 | 20-30 | 30+ | Total 2023 |
AAA | 216 | 320 | 219 | 235 | 291 | 922 | 909 | 1,320 | 4,432 |
AA | 108 | 186 | 253 | 508 | 507 | 306 | 114 | 101 | 2,083 |
A | 1,014 | 1,117 | 1,357 | 2,033 | 3,241 | 1,246 | 930 | 159 | 11,097 |
BBB | 1,834 | 1,206 | 1,390 | 1,838 | 3,246 | 1,397 | 631 | 69 | 11,611 |
BB | 264 | 370 | 449 | 881 | 598 | 55 | 25 | 2,642 | |
B and below | 89 | 121 | 384 | 387 | 213 | 8 | 1,202 | ||
No rating available | 206 | 41 | 31 | 179 | 82 | 14 | 1 | 554 | |
Total | 3,731 | 3,361 | 4,083 | 6,061 | 8,178 | 3,948 | 2,609 | 1,650 | 33,621 |
NN Group N.V. Annual Report 2024 | 354
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Notes to the Consolidated annual accounts continued
2024 | 2023 | |
AAA | 13,754 | 13,259 |
AA | 17,535 | 18,144 |
A | 23,296 | 22,860 |
BBB | 13,250 | 14,200 |
BB | 3,193 | 3,233 |
B and below | 1,765 | 1,417 |
No rating available | 263 | 439 |
Mortgages 1 | 58,265 | 61,729 |
Other Retail Loans | 1,235 | 1,249 |
Total | 132,556 | 136,530 |
2024 | 2023 | |
NHG | 27% | 27% |
LTV <= 80% | 68% | 66% |
LTV 80% - 90% | 4% | 4% |
LTV 90% - 100% | 1% | 2% |
LTV > 100% | 1% | |
Total NN Group | 100% | 100% |
NN Group N.V. Annual Report 2024 | 355
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Notes to the Consolidated annual accounts continued
redit quality: NN Group mortgage portfolio, outstanding 1,2,5 | ||||||||
Life business | Banking | Other 3 | Total | |||||
2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | |
Performing mortgage loans that are not past due | 25,610 | 25,915 | 22,491 | 21,887 | 4,807 | 4,876 | 52,908 | 52,678 |
Performing mortgage loans that are past due | 105 | 119 | 136 | 161 | 23 | 26 | 264 | 306 |
Non-performing mortgage loans 4 | 75 | 79 | 113 | 99 | 15 | 13 | 203 | 192 |
Total | 25,790 | 26,114 | 22,740 | 22,147 | 4,845 | 4,915 | 53,375 | 53,176 |
Provisions for performing mortgage loans | 1 | 2 | 1 | 2 | 2 | 4 | ||
Provisions for non-performing mortgage loans | 1 | 2 | 1 | 1 | 2 | 3 | ||
Total 4 | 2 | 4 | 2 | 3 4 7 |
NN Group N.V. Annual Report 2024 | 356
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Notes to the Consolidated annual accounts continued
ollateral on mortgage loan 1,2,5 | ||||||||
Life business | Banking | Other 3 | Total | |||||
2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | |
Carrying value | 25,790 | 26,113 | 22,740 | 22,147 | 4,845 | 4,915 | 53,375 | 53,175 |
Indexed collateral value of real estate | 55,761 | 55,531 | 49,913 | 45,931 | 10,179 | 9,487 | 115,853 | 110,949 |
Savings held 6 | 1,146 | 1,134 | 1,563 | 1,481 | 80 | 77 | 2,789 | 2,692 |
NHG guarantee value 4 | 4,998 | 5,300 | 6,081 | 5,853 | 966 | 1,026 | 12,045 | 12,179 |
Total cover value + including NHG guarantee capped at carrying value | 25,784 | 26,100 | 22,739 | 22,138 | 4,845 | 4,913 | 53,368 | 53,151 |
Net exposure | 6 | 13 | 1 | 9 | 2 7 24 |
NN Group N.V. Annual Report 2024 | 357
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Notes to the Consolidated annual accounts continued
| Own Funds | Solvency II ratio | ||
impact | SCR impact | impact | |
Credit spread: Parallel shock for AAA-rated government bonds +50 bps | −501 | −9 | −6% |
| Credit spread: Parallel shock for AA and lower-rated government bonds | |||
+50 bps | −759 | −45 | −8% |
Credit spread: Parallel shock spreads corporates +50 bps | 391 | −72 | 6% |
Credit spread: Parallel shock spreads mortgages +25 bps | −551 | −18 | −6% |
| Own Funds | Solvency II ratio | ||
| 2023 | impact | SCR impact | impact |
Credit spread: Parallel shock for AAA-rated government bonds +50 bps | −397 | −4 | −4% |
| Credit spread: Parallel shock for AA and lower-rated government bonds | |||
+50 bps | −738 | −37 | −7% |
Credit spread: Parallel shock spreads corporates +50 bps | 371 | −63 | 6% |
Credit spread: Parallel shock spreads mortgages +25 bps | -564 | -15 | -6% |
| Solvency II ratio sensitivities to credit spread increased as the OF sensitivity has increased because of asset |
NN Group N.V. Annual Report 2024 | 358
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Notes to the Consolidated annual accounts continued
2024 | 2023 | |
Western Europe | 56% | 56% |
Southern Europe | 18% | 18% |
Nordics | 10% | 10% |
Central and Eastern Europe | 5% | 5% |
UK and Ireland | 11% | 11% |
Total | 100% | 100% |
Own Funds impact | SCR impact | Solvency II ratio impact | ||||
2024 | 2023 | 2024 | 2023 | 2024 | 2023 | |
| Real estate Downward | ||||||
shock -10% | −1,334 | −1,199 | −90 | −68 | −13% | −12% |
NN Group N.V. Annual Report 2024 | 359
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Notes to the Consolidated annual accounts continued
NN Group N.V. Annual Report 2024 | 360
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Notes to the Consolidated annual accounts continued
6. Counterparty default risk
Counterparty default risk is the risk of loss due to default or deterioration in the credit standing of the
counterparties and debtors (including reinsurers) of NN Group. The SCR for Counterparty default risk is
primarily based on the issuer’s probability of default (PD) and the loss-given- default (LGD) of each individual
position taking into account diversification across these positions.
The Counterparty default risk module also covers any Credit risk exposures which are not covered in the
Credit spread risk sub-module.
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Notes to the Consolidated annual accounts continued
Counterparty Default Risk exposures
1
arising from insurance and reinsurance contracts at 31 December 2024
| Insurance | Reinsurance held | Reinsurance held | Reinsurance | |
| 2024 | contracts 2 | as Assets 3 | as Liabilities 3 | Total 3 |
AA | 653 | −894 | −241 | |
A | 53 | 183 | −67 | 116 |
BBB | 14 | 14 | ||
No rating available | 1,134 | 32 | −15 | 18 |
1
Maximum exposure given on Solvency II Standard Formula basis. Standard Formula basis is used due to the fact that Standard Formula rating is more
conservative. Intercompany exposure is excluded.
2
Insurance contracts exposure is related to receivables from policyholders, brokers, and tied agents as well as policyholder loans.
3
Reinsurance exposure is related to, among others, reinsurance recoverables, receivables from and payables to (external) reinsurers.
Counterparty Default Risk exposures
1
arising from insurance and reinsurance contracts at 31 December 2023
2023
Insurance
contracts
2
| Reinsurance held | Reinsurance held | Reinsurance | ||
as Assets 3 | as Liabilities 3 | Total 3 | ||
AA | 714 | −343 | 371 | |
A | 49 | 221 | 34 | 255 |
BBB | 32 | −27 | 5 | |
No rating available | 1,106 | 27 | 12 | 39 |
1
Maximum exposure given on Solvency II Standard Formula basis. Standard Formula basis is used due to the fact that Standard Formula rating is more
conservative. Intercompany exposure is excluded.
2
Insurance contracts exposure is related to receivables from policyholders, brokers, and tied agents as well as policyholder loans.
3
Reinsurance exposure is related to, among others, reinsurance recoverables, receivables from and payables to (external) reinsurers.
NN Group N.V. Annual Report 2024 | 362
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Notes to the Consolidated annual accounts continued
For the uusiness Units applying Standard Formula, Non-market risks are split between:
∙ Life risk: the life portfolio is mainly attributed to the individual and group business in the international
entities of NN Group (mainly Belgium, Spain Life, Poland). This risk comprises the Mortality, Longevity,
Disability-morbidity, Expense, Lapse, and Life catastrophe risks.
∙ Health risk: this covers the Similar to Life Techniques (SLT) Health portfolio risk (comprising Mortality,
Longevity, Disability-morbidity, Expense and Lapse risks), the Non-SLT (NSLT) Health portfolio risk
(comprising Premium and Reserve risk and Lapse risk), and the Health catastrophe risk. Within NN Group,
the Health risk stems from morbidity riders in Belgium, Poland, Slovakia, Romania, from the yearly
renewable health insurance portfolio of Greece and Hungary.
∙ Non-life risk: this covers Non-life portfolio mainly contributed by ABN AMRO Non-life. This risk covers the
Premium and Reserve risk, Non-life catastrophe risk, and Lapse risk.
8.1 Risk profile
The table below presents the Non-market risk SCR composition at the end of 2024 and at the end of 2023,
respectively. The main changes in the risk profile are explained in the subsequent section of this document.
Non-market risk capital requirements
2024 | 2023 | |
Insurance risk (IM entities) | 2,641 | 2,480 |
Business risk (IM entities) | 1,729 | 1,846 |
Life risk (SF entities) | 1,286 | 1,190 |
Health risk (SF entities) | 325 | 289 |
Non-life risk (SF entities) | 100 | 89 |
Diversification non-market risk | −1,115 | −1,121 |
Non-market risk | 4,966 | 4,773 |
The Non-market risk SCR increased from EUR 4,773 million in 2023 to EUR 4,966 million in 2024.
The increase is predominantly driven by lower interest rates and the impact of model changes mainly at NN
Non-Life, partially offset by the impact of longevity reinsurance at NN Life.
NN Group N.V. Annual Report 2024 | 363
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Notes to the Consolidated annual accounts continued
8.2 Risk mitigation
Proper pricing, underwriting, claims management and diversification are the main risk mitigating actions for
Insurance risks.
NN Group Insurance risks are mainly managed on business unit level. Insurance liabilities cover multiple
geographies, product benefits, lengths of contract and both Life and Non-life risk, NN Group reduces the
likelihood that a single risk event will have a material impact on NN Group’s financial condition. Risks not
sufficiently mitigated by diversification are managed through concentration and exposure limits and through
reinsurance: retention limits for Non-life insurance risks are set by line of business for catastrophic events
and individual risk.
Furthermore, Insurance risks are managed through terms and conditions of the insurance policies to ensure
that NN Group underwriting is correctly aligned with the intended policyholder benefits to mitigate the risk
that unintended benefits are covered. This is achieved through NN Group’s underwriting standards, product
design requirements, and product approval and review processes – as referred to under Risk Management
Policies, Standards and Processes.
8.3 Insurance risk
Insurance risk is the risk that the future insurance claims and other contractual benefits cannot be covered
by premiums, policy fees and/or investment income or that insurance liabilities are not sufficient because
claims and benefits might differ from the assumptions used in determining the best estimate liability.
Insurance risk manifests itself in the life as well as in the Non-life portfolio of NN Group.
8.3.1 Risk profile
The table below presents the Partial Internal Model Insurance risk SCR for the Dutch NN insurance entities of
NN Group (namely NN Life, NN Non-life and NN Re) as at 31 December 2024 and 31 December 2023,
respectively.
Insurance risk capital requirements
2024 | 2023 | |
Mortality (including longevity) risk | 1,969 | 1,975 |
Morbidity risk | 1,295 | 981 |
Property & Casualty risk | 816 | 815 |
Diversification insurance risk | −1,439 | −1,291 |
Insurance risk (IM entities) | 2,641 | 2,480 |
Increase in the Insurance risk SCR is mostly driven by lower interest rates, as well as the impact of model
changes at NN Non-Life related to morbidity risk.
Mortality risk occurs when claims are higher due to higher mortality experience (for instance in relation to
term insurance). Longevity risk is the risk that technical provisions to cover insurance obligations will not be
sufficient due to higher than expected life expectancies arising from mortality improvements such as better
living conditions, improved health care, and medical breakthroughs. While NN Group is exposed to both
Longevity and Mortality risks, these risks do not fully offset one another as the impact of the Longevity risks
in the pension business in the Netherlands is significantly larger than the Mortality risk in the other
businesses.
Morbidity risk is borne primarily by the health insurance portfolio which pays out a fixed amount benefit,
reimburses losses (e.g. in the case of loss of income), or pays for expenses of medical treatment related to
certain illness or disability events. The main exposures to Morbidity risks within NN Group are the disability
insurance policies underwritten in Netherlands Non-life.
Non-life portfolio includes Property & Casualty (P&C) products covering risks such as fire damage, car
accidents, personal and professional liability, windstorms, hail, and third-party liabilities. The P&C risk is
primarily underwritten by Netherlands Non-life and catastrophic losses are partially mitigated to external
reinsurers through NN Re.
The additional (physical) impact of climate change on the Insurance risk is not quantified yet but is expected
to be limited because of the shorter time horizon of one year used to define the Solvency Capital
Requirements. NN Group performs qualitative and quantitative risk assessments to assess the physical
impact of climate change on various Non-life product lines based on the latest IPCC scenarios and taking into
account various time horizons. We refer to the 'Anticipated financial effects' section of the Sustainability
Statement of this report.
8.3.2 Risk mitigation
Insurance risk is mitigated through diversification between NN Group business units, between Mortality and
Longevity risks within NN Group business units, appropriate pricing, underwriting and claims management
policies, and risk transfer via reinsurance and index-based hedges, which are used to reduce the Own Funds
volatility.
NN Group N.V. Annual Report 2024 | 364
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Notes to the Consolidated annual accounts continued
The risks that are not sufficiently mitigated by diversification are managed through concentration and
exposure limits and through reinsurance:
∙ Retention limits for Life insurance risks are set per insured life and significant mortality events affecting
multiple lives such as pandemics.
∙ Retention is used to manage risk levels (such as Non-life reinsurance and morbidity reinsurance in Japan
Life).
∙ Retention limits for Non-life insurance risks are set by line of business for catastrophic events and
individual risks.
For NN Non-life natural catastrophic events are a major risk. One of the main natural catastrophe threatening
the Netherlands is storms causing severe wind damage. NN Non-life has a reinsurance programme in place,
offering protection against severe storms and other natural perils. In addition, reinsurance contracts per risk
group are in place, covering NN Non-life against large one-off events such as fires.
The reinsurance programmes are in general facilitated by NN Re. In addition, reinsurance creates Credit risk
which is managed in line with the Reinsurance Standard of NN Group.
8.4 Business risk
Business risk include risks related to the management and development of the Insurance risk, Persistency
risk, and Expense risks. These risks occur because of internal, industry, regulatory/political, or wider market
factors.
8.4.1 Risk profile
The table below presents the Partial Internal Model Business risk SCR for the Dutch NN insurance entities of
NN Group as at 31 December 2024 and 31 December 2023, respectively.
Business risk capital requirements
2024 | 2023 | |
Persistency risk | 605 | 632 |
Premium risk | 1 | 1 |
Expense risk | 1,529 | 1,564 |
Diversification business risk | −406 | −351 |
Business risk (IM entities) | 1,729 | 1,846 |
The Persistency risk SCR decreased from EUR 632 million in 2023 to EUR 605 million in 2024 primarily due to
model refinements.
The SCR for Expense risk decreased from EUR 1,564 million in 2023 to EUR 1,529 million in 2024. The
decrease is due to model refinements that is partially offset by decreased interest rates. This SCR reflects
the risk that future actual expenses exceed the expenses assumed in our best estimate provisions. Expense
risk comprises Expense level and Expense inflation risks, materially driven by NN Life.
8.4.2 Risk mitigation
Persistency and Premium risks are managed through the product development, product approval and review
processes and by ensuring that appropriate advice is given to the customer, not only at the point of sale but
also during the lifetime of the product. The policyholder behaviour experience of in-force policies is assessed
at least annually.
As part of its strategy, NN Group has put several programmes in place to improve the customer experience.
These programmes improve the match between customer needs and the benefits and options provided by
NN Group’s products. Over time, NN Group’s understanding and anticipation of the choice policyholders are
likely to make, will improve, thereby decreasing the risk of a mismatch between actual and assumed
policyholder behaviour.
Ongoing initiatives are in place to manage Expense risk throughout NN Group, especially in the Netherlands
where company targets are in place to reduce expenses, thus, lowering Expense risk going forward. These
initiatives seek to reduce expenses in line with the number of underlying contracts in place. Besides the
already described mitigating actions, proper pricing, underwriting, claims management, and diversification
are also risk mitigating actions for Business risk.
8.5 Life risk
Life risk includes risks arising from the underwriting of life insurances of the business units applying
Standard Formula and is split into Mortality risk, Longevity risk, Disability/Morbidity risk, Persistency risk,
Expense risk, Revision risk, and Catastrophic risk. These risks refer to the adverse deviation from the best
estimate liabilities due to the perils covered, policyholder behaviour and the processes used in the conduct
of business.
NN Group N.V. Annual Report 2024 | 365
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Notes to the Consolidated annual accounts continued
8.5.1 Risk profile
Life risk capital requirements
2024 | 2023 | |
Mortality risk | 104 | 99 |
Longevity risk | 59 | 57 |
Morbidity risk | 16 | 14 |
Expense risk | 356 | 361 |
Lapse risk | 997 | 897 |
Catastrophe risk | 118 | 110 |
Diversification life risk | −364 | −348 |
Life risk (SF entities) | 1,286 | 1,190 |
As shown in the table above, the Life risk SCR for the SF business units increased slightly from EUR 1,190
million in 2023 to EUR 1,286 million in 2024 mainly due to portfolio development.
8.5.2 Risk mitigation
The majority of Life risk is comprised of Lapse, Expense and Mortality risks (in Standard Formula entities)
mainly from the international NN Group entities (Belgium, Poland, Spain).
The NN Group Standard Formula entities manage the Expense risk through detailed budgeting and
monitoring the costs using activity-based costing.
Lapse risk management serves an important objective for NN Group entities. When deviations from assumed
lapse rates are observed over a prolonged period of time, a product review and further management actions
are taken to address the underlying reasons.
8.6 Health risk
Health risk arises from issuing health insurance contracts, which is divided in Similar to Life Techniques (SLT)
risk, Non-Similar to Life Techniques (NSLT) risk and Catastrophe risk. SLT risk is associated to health
obligations pursued on a similar technical basis to that of life insurance, while NSLT risk applies to health
obligations not pursued on a similar technical basis to that of life insurance. These risks refer to the adverse
deviation from the best estimate liabilities due to the perils covered, policyholder behaviour and the
processes used in the conduct of business.
8.6.1 Risk profile
Health risk capital requirements
2024 | 2023 | |
SLT | 302 | 268 |
NSLT | 24 | 22 |
Catastrophe risk | 33 | 32 |
Diversification health risk | −34 | −33 |
Health risk (SF entities) | 325 | 289 |
As shown in the table above, the Health risk SCR of the business units applying Standard Formula increased
from EUR 289 million in 2023 to EUR 325 million in 2024. The increase is mainly explained by portfolio
development.
8.6.2. Risk mitigation
The majority of Health risk originates from international NN Group entities (Belgium, Poland, Slovakia and
Romania). They mitigate the risks by strict acceptance policies and stringent claims-handling procedures. An
acceptance policy and internal control processes are developed for each product line maintained by those
entities.
8.7 Non-life risk
Non-life risk involves risks arising from the underwriting of Non-life insurance, which includes Premium and
Reserve risk, Persistency risk and Catastrophic risk. These risks refer to the adverse deviation from the best
estimate liabilities due to the perils covered, policyholder behaviour and the processes used in the conduct
of business.
8.7.1 Risk profile
Non-life risk capital requirements
2024 | 2023 | |
Premium and reserve risk | 83 | 78 |
Lapse risk | 19 | 16 |
Catastrophe risk | 35 | 24 |
Diversification non-life risk | −37 | −29 |
Non-life risk (SF entities) | 100 | 89 |
NN Group N.V. Annual Report 2024 | 366
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Notes to the Consolidated annual accounts continued
As shown in the table above, the Non-life risk SCR of the business units applying Standard Formula increased
from EUR 89 million in 2023 to EUR 100 million in 2024 mainly due to portfolio development.
8.7.2 Risk mitigation
Non-life risk is mitigated through appropriate pricing and underwriting policies and through risk transfer via
reinsurance. Most of the Non-life risk comes from ABN AMRO Non-life, and they manage the risk using
various reinsurance contracts.
Capital management and framework
NN Group manages its capital along a three-pillar framework taking into account the solvency positions at
NN Group and its operating entities, cash capital at holding, and financial and debt metrics:
∙ NN Group defines a comfort zone between 150%-200% Group Solvency ratio where NN Group intends to
pay a progressive dividend per share and execute an annual share buyback. In the case of a Group
Solvency ratio sustainably above 200%, there is an opportunity to increase the share buyback further.
NN Group aims to capitalise its operating entities adequately at all times. Operating entities have to
comply with the local statutory capital frameworks that are under supervision of local regulators. To
ensure adequate capitalisation, they are managed to commercial capital target levels, which are set in
accordance with the risk associated with the business activities, commercial requirements and other
relevant factors. The commercial capital target levels are set in local legal entity capital policies and
approved by the Management Board of NN Group. Capital adequacy is ensured through the capital planning
process which starts with the annual budgeting process in which a capital plan is prepared for NN Group
and its operating entities with a time horizon of 5 years. NN Group’s risk appetite statements, as further
described in Note 48 ‘Risk Management’, drive the target setting and are cascaded down to the operating
entities in line with NN Group’s risk management strategy. Other important factors which are considered in
the capital plan are efficient capital allocation, the cost of capital and capital generation. Capital positions
of operating entities are closely monitored and, if necessary, measures are taken to ensure capital
adequacy. At the end of 2024, all operating entities were capitalised above their local regulatory
requirements.
∙ In addition, cash capital is held at the holding company to cover capital needs of the entities after a 1-in-20
year stress event and to cover financial leverage costs and holding company expenses for a period of at
least 12 months. The free cash flow to the holding is the cash made available to NN Group, and is driven by
remittances and capital injections with subsidiaries, financial leverage costs and holding company
expenses. This can be distributed to shareholders (reference is made to Note 11 ‘Equity’ for information on
distributable reserves), used to reduce debt or for other corporate purposes. The free cash flow to the
holding is closely monitored and forecasted on a regular basis.
∙ NN Group aims to maintain a financial leverage and fixed-cost coverage ratio consistent with a single ‘A’
financial strength rating. Financial leverage measures the amount of debt that NN Group issued to
capitalise its businesses. Debt used for funding of operating activities or liquidity needs is not considered
financial leverage. The fixed-cost coverage ratio measures the ability of NN Group to pay its financing
expenses and is defined as the earnings before interest and tax (EBIT) divided by interest before tax on
financial leverage. Special items, revaluations on derivatives that are non-eligible for hedge accounting,
market and other impacts and amortisation of acquisition intangibles are excluded from EBIT.
49 Capital and liquidity management
Objectives, policies and processes
Objective
The goal of NN Group’s capital and liquidity management is to adequately capitalise NN Group and its
operating entities at all times to meet the interests of our stakeholders, including our customers and
shareholders. The balance sheet is assessed in line with our capital management framework which is based
on regulatory, economic and rating agency requirements. NN Group closely monitors and manages the
following metrics: Own Funds/Solvency Capital Requirement (SCR), cash capital at the holding company,
financial leverage, fixed cost coverage, capital generation and liquidity.
Governance
The NN Group Capital Management and Corporate Treasury Department reports to the NN Group CFO.
Activities of the department are executed on the basis of established policies, guidelines and procedures.
Capital Management is responsible for the sufficient capitalisation of NN Group entities, which involves the
management, planning and allocation of capital within NN Group. Corporate Treasury is responsible for the
management and execution of debt capital market transactions, term (capital) funding, cash management
and risk management transactions.
NN Group N.V. Annual Report 2024 | 367
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Notes to the Consolidated annual accounts continued
Liquidity management
NN Group monitors and manages its liquidity risk based on certain severe stress scenarios, assessed by
operating entities and aggregated at the group level. Liquidity positions are periodically reported and
monitored both on an individual entity and on a consolidated basis.
NN Group measures liquidity risk as the difference between liquidity needs and liquidity sources available for
sale in a stress event for different time horizons. At 31 December 2024, the liquidity position of all entities
was adequate (reference is made to Note 48 ‘Risk Management’ for more information on liquidity risk
management).
For the Banking business, the Dutch Central Bank (DNB) requires an annual internal evaluation of capital
adequacy, liquidity position and the risk management framework, including stress testing. This internal
evaluation is performed using an Internal Capital and Liquidity Adequacy Assessment Process (ICAAP and
ILAAP) and reviewed by DNB in its Supervisory Review & Evaluation Process (SREP). The ICAAP, ILAAP, and
SREP show that NN Bank has a robust capital and liquidity position.
NN Group has an undrawn syndicated revolving credit facility of EUR 1.9 billion. In October 2024 the maturity
of the revolving credit facility was extended with one year to 2028. The facility is available until its maturity
in 2028. In 2023 and 2024, no amounts were drawn under the revolving credit facility.
Significant events of 2024 are listed below in chronological order
On 9 January 2024, NN Group announced a settlement with interest groups ConsumentenClaim,
Woekerpolis.nl, Woekerpolisproces, Wakkerpolis and Consumentenbond regarding unit-linked products sold
in the Netherlands by Nationale-Nederlanden, including Delta Lloyd and ABN AMRO Life. Reference is made
to Note 41 ‘Legal Proceedings’ for more information.
On 29 February 2024, NN Group announced an open market share buyback programme for an amount of
EUR 300 million within 9 months, which commenced on 2 April 2024. The share buyback programme was
completed on 12 December 2024.
On 12 March 2024, NN Group issued EUR 750 million of undated subordinated notes. The EUR 750 million
undated subordinated notes are first callable on 12 September 2030. The coupon is fixed at 6.375% per
annum until the first coupon reset date on 12 March 2031 and will be reset every fifth year thereafter. The
undated subordinated notes qualify as restricted Tier 1 regulatory capital.
On 13 March 2024, the tender offer announced by NN Group on 4 March 2024 was settled. NN Group
repurchased EUR 287 million of the outstanding EUR 415 million undated subordinated notes issued in 2014.
On 23 May 2024, NN Group announced the early redemption of the remaining EUR 128 million undated
subordinated notes on the first call date 13 June 2024.
On 20 March 2024, NN Group announced the early redemption of the outstanding EUR 335 million dated
subordinated notes issued in 2014 on the first call date 8 April 2024.
On 20 June 2024, NN Group paid a 2023 final dividend of EUR 2.08 per ordinary share, equivalent to
EUR 566 million in total. To neutralise the dilutive effect of the stock dividend on earnings per share,
NN Group announced the repurchase of ordinary shares for a total of EUR 232 million. The share buyback
programme was completed on 30 August 2024.
On 27 August 2024, NN Group paid a 2024 interim dividend of EUR 1.28 per ordinary share, equivalent to
EUR 347 million in total. The 2024 interim dividend was fully paid in cash.
On 25 September 2024, NN Group announced it had reached an agreement to sell its Turkish operations to
Zurich Türkiye. The transaction was completed on 10 January 2025. The completion of the transaction
followed the fulfilment of the customary closing conditions, including receipt of all necessary regulatory
approvals.
Solvency II
Solvency II is the regulatory framework for (re-)insurance undertakings and groups domiciled in the EU.
Under the Solvency II regime, required capital (Solvency Capital Requirement) is risk-based and calculated as
the post-tax value-at-risk at the confidence interval of 99.5% on a one-year horizon. Available capital (Own
Funds) is determined as the excess of assets over liabilities, both based on economic valuations, plus
qualifying subordinated debt. The EU Solvency II directive requires that (re-)insurance undertakings and
groups hold sufficient Eligible Own Funds to cover the SCR.
NN Group is the holding company of licensed insurers and banking businesses. Regulated entities which
from local regulatory perspective are not subject to the Solvency II regime (e.g. pension funds in Central
Europe, NN Bank, BeFrank and BeFrank PPI) are included in Own Funds based on their local available capital
and in SCR based on required capital defined by sectoral supervisory rules. NN Life Japan is included in Own
Funds and SCR based on its available and required capital determined according to the local solvency regime
recognised by the European Commission as provisionally equivalent.
NN Group N.V. Annual Report 2024 | 368
Consolidated annual accounts
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
NN Group uses the Partial Internal Model (PIM) to calculate capital requirements under Solvency II. The
group capital model is named as such due to the fact that an Internal Model is used to calculate the capital
requirements for the Dutch insurance entities (namely NN Life, NN Non-life and NN Re in the Netherlands),
while the Standard Formula is used to calculate capital requirements for operational risk (across the group),
for the international insurance entities that fall under Solvency II, and for ABN AMRO Non-life.
Further details on the NN Group capital requirements at 31 December 2024 are provided in Note 48 ‘Risk
Management’.
After a long period of negotiations between the European Commission, the European Council and the
European Parliament, a revised Solvency II directive (Level I) was published in the Official Journal of
8 January 2025. The amended regulation will be effective as of 30 January 2027, which means that
reporting after this date will reflect the changes from the Solvency II 2020 review. Some key aspects in the
agreement are not detailed out in the Solvency II directive but will be clarified later in the process (part of
Level II and Level III). This relates for example to the parameterisation of elements that are relevant for the
determination of the risk margin and the Volatility Adjustment. The revised Solvency II directive forms the
basis for the revision of the Level II and III regulation, which can lead to further changes. Based on the Level
I text and current market conditions, NN Group remains comfortable with its solvency position and does not
expect changes to its dividend policy.
Eligible Own Funds and Solvency Capital Requirement
2024 | 2023 | |
Shareholders’ equity | 19,831 | 19,624 |
Minority interest | 85 | 79 |
Elimination of intangible assets | −1,197 | −1,234 |
Valuation differences on assets | −1,362 | −1,361 |
Valuation differences on liabilities, including insurance and investment contracts | −4,294 | −2,998 |
Deferred tax effect on valuation differences | 1,516 | 1,132 |
Difference in treatment of non-Solvency II regulated entities | −12 | −3 |
Excess assets/liabilities | 14,567 | 15,240 |
Qualifying subordinated debt | 4,188 | 4,127 |
Foreseeable dividends and distributions | −683 | −681 |
Basic Own Funds | 18,072 | 18,685 |
Non-available Own Funds | 867 | 896 |
Non-eligible Own Funds | 179 | 98 |
Eligible Own Funds (a) | 17,026 | 17,691 |
– of which Tier 1 unrestricted | 9,578 | 10,388 |
– of which Tier 1 restricted | 1,783 | 1,414 |
– of which Tier 2 | 2,361 | 2,631 |
– of which Tier 3 | 1,105 | 1,144 |
– of which non-Solvency II regulated entities | 2,199 | 2,113 |
Solvency Capital Requirements (b) | 8,786 | 8,990 |
– of which from solvency II entities | 7,363 | 7,628 |
– of which from non-solvency II entities | 1,423 | 1,362 |
NN Group Solvency II ratio (a/b)1 | 194% | 197% |
1
The Solvency ratio is not final until filed with the regulator.
NN Group N.V. Annual Report 2024 | 369
Consolidated annual accounts
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
NN Group was adequately capitalised at 31 December 2024 with a Solvency II ratio of 194% based on the
Partial Internal Model.
The NN Group Solvency II ratio decreased to 194% from 197% at the end of 2023, mainly due to capital flows
to shareholders, adverse market impacts and other changes, partly offset by operating capital generation as
well as management actions. Market impacts mainly reflect movements in government bond spreads and
negative equity variance. Other changes mainly consist of regulatory changes, including the impact of the
reduction of the Ultimate Forward Rate, an update of the Volatility Adjustment representative portfolio by
EIOPA and the counter-cyclical buffer step-up of NN Bank, as well as model and assumption changes.
Eligible Own Funds decreased to EUR 17,026 million at 31 December 2024 from EUR 17,691 million at
31 December 2023. The decrease was mainly driven by capital flows to shareholders and the
aforementioned market impacts, regulatory changes and model and assumption changes, partly offset by
operating capital generation.
The SCR of NN Group decreased to EUR 8,786 million at 31 December 2024 from EUR 8,990 million at
31 December 2023. The decrease was mainly driven by management actions, partly offset by regulatory
changes.
NN Group N.V. Annual Report 2024 | 370
Consolidated annual accounts
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
Structure, amount and quality of Own Funds
Subordinated liabilities included in NN Group Own Funds
Interest rate | Issue 1 | Year of issue | Notional | First call date | Due date | Own Funds tier | Solvency II value | |
2024 | 2023 | |||||||
4.500% | NN Group N.V. | 2014 | 1,000 | 15 January 2026 | Perpetual | Tier 1 | 1,011 | 994 |
4.625% | NN Group N.V. | 2017 | 850 | 13 January 2028 | 13 January 2048 | Tier 2 | 849 | 830 |
5.250% | NN Group N.V. | 2022 | 500 | 30 August 2032 | 1 March 2043 | Tier 2 | 510 | 503 |
6.000% | NN Group N.V. | 2023 | 1,000 | 3 May 2033 | 3 November 2043 | Tier 2 | 1,047 | 1,037 |
6.375% | NN Group N.V. 2 | 2024 | 750 | 12 September 2030 | Perpetual | Tier 1 | 771 | |
4.375% | NN Group N.V. 3,4 | 2014 | 415 | 13 June 2024 | Perpetual | Tier 1 | 420 | |
4.625% | NN Group N.V. 5 | 2014 | 335 | 8 April 2024 | 8 April 2044 | Tier 2 | 334 |
1
All securities are listed on Euronext Amsterdam, except the EUR 750 million Tier 1 notes issued in 2024, which are listed on Euronext Dublin.
2
These securities possess a principal loss-absorbency mechanism such that, in case of specified trigger events related to non-compliance with the SCR or MCR as specified in Solvency II legislation, (part of) the principal amount of the notes can be (temporarily) written-down to immediately absorb losses.
3
These securities were originally issued by Delta Lloyd N.V. which was merged into NN Group N.V. at the end of 2017.
4
These securities were part of two tender offers announced on 25 April 2023 and 4 March 2024 by NN Group. The notional presented is the remaining notional at year-end 2023.
5
These securities were part of a tender offer announced on 25 April 2023 by NN Group. The notional presented is the remaining notional at year-end 2023.
The undated subordinated notes issued in 2014 with a notional amount of EUR 1 billion have a coupon of
4.50% and are fully paid in. NN Group N.V. has the right to redeem these notes on the first call date on
15 January 2026 or on any interest payment date thereafter. The subordinated notes are classified as
Restricted Tier 1 capital based on the transitional provisions (grandfathering). These subordinated notes are
grandfathered for a maximum period of 10 years until 1 January 2026.
The dated subordinated notes issued in 2017 with a notional amount of EUR 850 million have a coupon of
4.625%, maturity date on 13 January 2048, and are fully paid in. NN Group N.V. has the right to redeem
these notes on the first call date on 13 January 2028 or on any interest payment date thereafter. These
subordinated notes qualify as Tier 2 capital.
The dated subordinated notes issued in 2022 with a notional amount of EUR 500 million have a coupon of
5.25%, maturity date on 1 March 2043, and are fully paid in. It was the first issuance under NN Group’s
Sustainability Bond Framework. NN Group N.V. has the right to redeem these notes on the first call date of
30 August 2032 or any other interest payment date thereafter. These subordinated notes qualify as Tier 2
capital.
The dated subordinated notes issued in 2023 with a notional amount of EUR 1 billion have a coupon of
6.00%, maturity date on 3 November 2043, and are fully paid in. It was the second issuance under
NN Group’s Sustainability Bond Framework. NN Group N.V. has the right to redeem these notes on the first
call date of 3 May 2033 or any other interest payment date thereafter. These subordinated notes qualify as
Tier 2 capital.
The undated subordinated notes issued in 2024 with a notional amount of EUR 750 million have a coupon of
6.375% and are fully paid in. NN Group N.V. has the right to redeem these notes on the first call date on
12 September 2030 or on any interest payment date thereafter. These subordinated notes qualify as
Restricted Tier 1 capital.
The undated subordinated notes (originally issued by Delta Lloyd N.V. in 2014) with outstanding notional
amount of EUR 128 million (EUR 415 million outstanding notional amount at year-end 2023) were redeemed
on the first call date of 13 June 2024.
The dated subordinated notes issued in 2014 with outstanding notional amount of EUR 335 million were
redeemed on the first call date of 8 April 2024.
NN Group N.V. Annual Report 2024 | 371
Consolidated annual accounts
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
Eligible Own Funds
NN Group Own Funds are classified into three tiers as follows:
∙ The excess of assets over liabilities on the basis of consolidated accounts excluding net Deferred Tax Asset
is classified as (unrestricted) Tier 1.
∙ The proportional share in the Own Funds of BeFrank, BeFrank PPI and pension funds in Central Europe is
classified as (unrestricted) Tier 1.
∙ The proportional share in the Eligible Own Funds of NN Life Japan is classified as (unrestricted) Tier 1
(European Commission recognised the solvency regime applied to the insurance undertakings in Japan as
provisionally equivalent to Solvency II according to Commission Delegated Decision (EU) 2016/310 of
26 November 2015).
∙ The proportional share in the Own Funds of NN Bank is classified as (unrestricted) Tier 1 with the exception
of the subordinated loans which are classified as Tier 2.
∙ Undated subordinated notes are classified as (restricted) Tier 1 including those based on the transitional
provisions (grandfathering).
∙ Dated subordinated debt is classified as Tier 2.
∙ The Net Deferred Tax Asset (Deferred tax assets and liabilities are offset only where such assets and
liabilities relate to taxes levied by the same tax authority on the same taxable undertaking) is classified as
Tier 3.
As at 31 December 2024 and 2023, NN Group had no ancillary Own Funds.
There are a number of regulatory restrictions on the amounts classified as Restricted Tier 1, Tier 2 and Tier 3
capital. The following restrictions have to be taken into account:
∙ Restricted Tier 1 capital cannot exceed 20% of the total Tier 1 amount.
∙ The proportion of Tier 1 items in the Eligible Own Funds should be higher than one third of the total amount
of Eligible Own Funds.
∙ Tier 2 and Tier 3 capital together cannot exceed 50% of the SCR.
∙ Tier 3 capital cannot exceed 15% of the Solvency Capital Requirements.
∙ Tier 3 capital cannot exceed one third of the total amount of Eligible Own Funds.
The application of the regulatory restrictions as at 31 December 2024 is reflected in the table below.
Eligible Own Funds to cover the Solvency Capital Requirement
| Available | Eligible | Available | Eligible | ||
| Own Funds | Own Funds | Own Funds | Own Funds | ||
| 2024 | 2024 | 2023 | 2023 | Eligibility restriction | |
Tier 1 | 11,361 | 11,361 | 11,802 | 11,802 | More than one third of total EOF |
| Of which: | |||||
| – Unrestricted Tier 1 | 9,578 | 9,578 | 10,388 | 10,388 | Not applicable |
| – Restricted Tier 1 | 1,783 | 1,783 | 1,414 | 1,414 | Less than 20% of Tier 1 |
| Tier 2 + Tier 3 | 3,645 | 3,465 | 3,873 | 3,775 | Less than 50% of SCR |
| Tier 2 | 2,361 | 2,361 | 2,631 | 2,631 | |
| Less than 15% of SCR; | |||||
Tier 3 | 1,284 | 1,105 | 1,243 | 1,144 | Less than one third of total EOF |
| Non-Solvency II regulated entities | 2,199 | 2,199 | 2,113 | 2,113 | |
Total Own Funds | 17,205 | 17,026 | 17,789 | 17,691 |
Transferability and fungibility of Own Funds
NN Group adjusts the group Own Funds taking into account the value of own fund items that cannot
effectively be made available to cover the group SCR. These are the own fund items of related undertakings
subject to legal and regulatory constraints that restrict the ability of those items to absorb all types of loss
within the group and/or transferability of assets. Based on NN Group’s assessment these own fund items
mainly include:
∙ Differences between valuations of assets and liabilities based on Solvency II principles and according to
principles that related undertakings use to prepare respective local annual accounts.
∙ For NN Life Japan, own fund items according to local rules but which are not part of shareholders’ equity.
∙ For NN Bank, own funds covering pillar II guidance issued by regulator.
∙ The transitional measures on risk-free interest rates and technical provisions.
∙ Legal reserves set up according to local company law.
∙ Any minority interest in a related undertaking.
Consolidated annual accounts
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
These own fund items are included in NN Group Own Funds to the extent they are eligible for covering
contribution of the respective related undertaking to the NN Group’s SCR. On 31 December 2024 excess
non-available own funds amounted to EUR 867 million. On 31 December 2023, this amount was EUR 896
million.
Cash capital position at the holding company
NN Group holds a cash capital position at the holding company to cover capital needs of the entities after a
stress event and to cover financial leverage costs and holding company expenses for a period of at least 12
months. Cash capital is defined as net current assets available at the holding company. NN Group is
comfortable with a cash capital position at the holding company to be in a range of EUR 0.5 billion and
EUR 1.5 billion. A related metric is the free cash flow at the holding which is defined as the change in the
cash capital position at the holding company over the period, excluding acquisitions, divestments, and
capital transactions with shareholders and debtholders.
Cash capital position at the holding company
2024 | 2023 | |
Cash capital position at the holding company - opening balance | 971 | 2,081 |
Remittances from subsidiaries 1 | 1,877 | 1,855 |
Capital injections into subsidiaries 2 | −91 | −1,117 |
Other 3 | −267 | −267 |
Free cash flow to the holding 4 | 1,519 | 470 |
Cash divestment proceeds | 0 | 0 |
Acquisitions | 0 | −20 |
Capital flow to shareholders | −1,213 | −1,053 |
Increase/decrease in debt and loans | −6 | −507 |
Cash capital position at the holding company - closing balance | 1,271 | 971 |
1
Includes interest on and repayment/redemption of intragroup subordinated loans provided to subsidiaries by the holding company.
2
Includes subordinated loans provided to subsidiaries by the holding company.
3
Includes interest on subordinated loans and debt with external debtholders, holding company expenses and other cash flows.
4
Free cash flow to the holding company is defined as the change in cash capital position of the holding company over the period, excluding acquisitions,
divestment proceeds and capital transactions with shareholders and debtholders.
| Financial leverage | ||
2024 | 2023 | |
Shareholders' equity | 19,831 | 19,624 |
Contractual service margin after tax 1 | 5,458 | 4,861 |
Minority interest | 85 | 79 |
Capital base for financial leverage (a) | 25,374 | 24,564 |
– Undated subordinated notes 2 | 1,736 | 1,416 |
– Subordinated debt | 2,346 | 2,680 |
Total subordinated debt | 4,082 | 4,096 |
Debt securities issued | 1,196 | 1,195 |
Financial leverage (b) | 5,278 | 5,291 |
Financial leverage ratio (b/(a+b)) | 17.2% | 17.7% |
Fixed-cost coverage ratio 3 | 10.2x | 8.7x |
NN Group N.V. Annual Report 2024 | 373
Consolidated annual accounts
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
The financial leverage ratio of NN Group decreased to 17.2% from 17.7% at the end 2023. This reflects the
increase of the capital base driven by the increase of CSM and the net result, partly offset by capital flows to
shareholders.
The debt transactions in 2024 had no material impact on the financial leverage position. These include the
issuance of EUR 750 million of undated subordinated notes, the repurchase of EUR 287 million and
redemption of EUR 128 million of undated subordinated notes, and the redemption of EUR 335 million of
dated subordinated notes.
The fixed-cost coverage ratio (on the basis of the last 12 months) increased to 10.2x from 8.7x at the end of
2023. This mainly reflects higher revaluations on real estate, partly offset by realised losses on the sale of
debt securities and loans.
Proposed 2024 final dividend
At the annual general meeting on 15 May 2025, a final dividend will be proposed of EUR 2.16 per ordinary
share, or approximately EUR 578 million in total based on the current number of outstanding shares (net of
treasury shares). The final dividend will be paid fully in cash, after deduction of withholding tax. If the
proposed dividend is adopted by the General Meeting, NN Group ordinary shares will be quoted ex-dividend
on 19 May 2025. The record date for the dividend will be 20 May 2025. The dividend will be payable on
27 May 2025. (For more information: https://www.nn-group.com/investors/share-information/dividend-
policy-and-dividend-history.htm).
On 27 August 2024, NN Group paid an interim dividend of EUR 1.28 per ordinary share, equivalent to
EUR 347 million in total. The 2024 interim dividend was fully paid in cash. The proposed 2024 final dividend
of EUR 2.16 per ordinary share plus the 2024 interim dividend of EUR 1.28 per ordinary share gives a total
dividend for 2024 of EUR 3.44 per ordinary share.
On 20 June 2024, NN Group paid the 2023 final dividend of EUR 2.08 per ordinary share, equivalent to
EUR 566 million in total.
Share buyback
On 20 February 2025, NN Group announced that it will execute an open market share buyback programme
for an amount of EUR 300 million. The programme will be executed within ten months and is anticipated to
commence on 3 March 2025. The share buyback will be deducted in full from Solvency II Own Funds in the
first half of 2025 and is estimated to reduce NN Group’s Solvency II ratio by approximately 3%-points.
The share buyback programmes will be executed within the limitations of the existing authority granted by
the General Meeting on 24 May 2024 and such authority to be granted by the General Meeting on 15 May
2025. The shares will be repurchased at a price that does not exceed the last independent trade or the
highest current independent bid on the relevant trading platform. The programme will be executed by
financial intermediaries and will be performed in compliance with the safe harbour provisions for share
buybacks.
On 29 February 2024, NN Group announced an open market share buyback programme for an amount of
EUR 300 million within nine months, commencing on 2 April 2024. The share buyback programme was
completed on 12 December 2024.
NN Group neutralised the dilutive effect of the 2023 final dividend that was paid in the form of ordinary
shares for a total amount of EUR 232 million. This share buyback programme was completed on 30 August
2024.
NN Group reports on the progress of the share buyback programmes on its corporate website on a weekly
basis. (For more information: https://www.nn-group.com/investors/share-information/share-buyback-
programme.htm).
Share capital
On 30 December 2024, 16,000,000 NN Group treasury shares which were repurchased under the share
buyback programmes were cancelled.
In 2024, a total number of 12,093,872 ordinary shares for a total amount of EUR 532 million were
repurchased (reference is made to Note 11 ‘Equity’ regarding the number of shares repurchased and the
total amount in 2023).
On 7 March 2025, the total number of NN Group shares outstanding (net of 1,952,675 treasury shares) was
267,047,325.
NN Group N.V. Annual Report 2024 | 374
Consolidated annual accounts
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Consolidated annual accounts continued
Credit ratings
On 23 May 2024, Standard & Poor’s affirmed NN Group’s financial strength rating of ‘A+’ with stable outlook
and credit rating of ‘A-’ with stable outlook.
On 6 November 2024, Fitch Ratings affirmed NN Group’s ‘AA-’ financial strength rating and ‘A+’ credit rating
with a stable outlook.
| Credit ratings on NN Group N.V. on 12 March 2025 | ||
| Financial | NN Group N.V. | |
| Strength | Counterparty | |
| Rating | Credit Rating | |
Standard & Poor's | A+ | A- |
Stable | Stable | |
Fitch | AA- 1 | A+ |
Stable | Stable |
1
Financial Strength Rating for Nationale-Nederlanden Levensverzekering Maatschappij N.V.
NN Group N.V. Annual Report 2024 | 375
Parent company annual accounts
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Parent company annual accounts
Parent company balance sheet
As at 31 December before appropriation of result notes 2024 2023
Assets
Intangible assets
2 216 234
Investments in group companies 3 21,271 21,329
Investments in debt securities at fair value through OCI 4 1,196 1,650
Other assets 5 3,981 3,619
Total assets 26,664 26,832
Equity
Share capital
32 34
Share premium 12,581 12,579
Share of associates reserve 3,058 2,915
Revaluation reserve 16 19
Retained earnings 2,908 3,069
Unappropriated result 1,236 1,008
Shareholders’ equity 19,831 19,624
Undated subordinated notes 1,736 1,416
Total equity 6 21,567 21,040
Liabilities
Subordinated debt
7 2,346 2,680
Other liabilities 8 2,751 3,112
Total liabilities 5,097 5,792
Total equity and liabilities 26,664 26,832
References relate to the notes starting with Note 1 ‘Accounting policies for the Parent company annual
accounts’. These form an integral part of the Parent company annual accounts.
Parent company profit and loss account
For the year ended 31 December notes 2024 2023
Result group companies 1,719 1,310
Net fee and commission income −3 −3
Other income 239 301
Total Income 1,955 1,608
Amortisation of intangible and other impairments 17 18
Interest expenses 207 248
Operating expenses 217 199
Total expenses 441 465
Result before tax 1,514 1,143
Taxation −69 −29
Net result 1,583 1,172
NN Group N.V. Annual Report 2024 | 376
Parent company annual accounts
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Parent company annual accounts continued
Parent company statement of changes in equity (2024)
Share
capital
Share
premium Other reserves
1
Total
Shareholders’
equity
Undated
subordinated
notes
Total
equity
Balance at 1 January 2024 34 12,579 7,011 19,624 1,416 21,040
Revaluations in group companies −102 −102 −102
Other revaluations −3 −3 −3
Total amount recognised directly in equity (Other comprehensive income) 0 0 −105 −105 0 −105
Net result for the year 1,583 1,583 1,583
Total comprehensive income 0 0 1,478 1,478 0 1,478
Issuance (redemption) of undated subordinated notes 0 320 320
Changes in share capital −2 2 0 0
Dividend −681 −681 −681
Purchase (sale) of treasury shares −529 −529 −529
Employee stock option and share plans 1 1 1
Coupon on undated subordinated notes −62 −62 −62
Balance at 31 December 2024 32 12,581 7,218 19,831 1,736 21,567
1.
Other reserves include Retained earnings and Unappropriated result.
NN Group N.V. Annual Report 2024 | 377
Parent company annual accounts
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Parent company annual accounts continued
Parent company statement of changes in equity (2023)
Share
capital
Share
premium Other reserves
1
Total
Shareholders’
equity
Undated
subordinated
notes
Total
equity
Balance at 1 January 2023 35 12,578 6,652 19,265 1,764 21,029
Revaluations in group companies 285 285 285
Other revaluations 1 1 1
Total amount recognised directly in equity (Other comprehensive income) 0 0 286 286 0 286
Net result for the year 1,172 1,172 1,172
Total comprehensive income 0 0 1,458 1,458 0 1,458
Issuance (redemption) of undated subordinated notes 0 −348 −348
Changes in share capital −1 1 0 0
Dividend −422 −422 −422
Purchase (sale) of treasury shares −632 −632 −632
Employee stock option and share plans 1 1 1
Coupon on undated subordinated notes −57 −57 −57
Changes in the composition of the group and other changes 11 11 11
Balance at 31 December 2023 34 12,579 7,011 19,624 1,416 21,040
1
Other reserves include Retained earnings and Unappropriated result.
NN Group N.V. Annual Report 2024 | 378
Parent company annual accounts
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Parent company annual accounts
1 Accounting policies for the Parent company annual accounts
The parent company accounts of NN Group N.V. are prepared in accordance with the financial reporting
requirements included in Part 9 of Book 2 of the Dutch Civil Code. The accounting policies applicable to
presentation and disclosures are in accordance with the financial reporting requirements included in Part 9
of Book 2 of the Dutch Civil Code. The principles of valuation and determination of results stated in
connection with the Consolidated balance sheet and profit and loss account are also applicable to the parent
company balance sheet and profit and loss account with the exception of the following:
∙ Investments in group companies and Associates and joint ventures which are recognised at net asset
value with goodwill, if any, recorded under intangible assets.
∙ Receivables from group companies are measured at amortised cost.
A list containing the information referred to in Article 379 (1), Book 2 of the Dutch Civil Code has been filed
with the Commercial Register of the Chamber of Commerce in Amsterdam in accordance with Article 379 (5),
Book 2 of the Dutch Civil Code.
Changes in balance sheet values due to changes in the revaluation reserves of associates are reflected in the
‘Share of associates reserve’, which forms part of shareholders’ equity. Changes in balance sheet values due
to the results of these associates, accounted for in accordance with NN Group accounting policies, are
included in the profit and loss account. Other changes in the balance sheet value of these associates, other
than those due to changes in share capital, are included in the ‘Share of associates reserve’.
A legal reserve is carried at an amount equal to the share in the results of associates since their first
inclusion at net asset value less the amount of profit distributions to which rights have accrued in the
interim. Profit distributions which can be repatriated to the Netherlands without restriction are likewise
deducted from the ‘Share of associates reserve’.
2 Intangible assets
Intangible assets
2024 2023
Goodwill 148 148
Other intangible assets 68 86
Intangible assets 216 234
Reference is made to Note 9 ‘Intangible assets’ in the Consolidated annual accounts.
3 Investments in group companies
Investments in group companies
Interest
held
Balance
sheet value
Interest
held
Balance
sheet value
2024 2024 2023 2023
NN Insurance Eurasia N.V. Amsterdam, The Netherlands 100% 20,152 100% 20,307
NN Bank N.V. The Hague, The Netherlands 100% 1,018 100% 919
Nationale-Nederlanden ABN AMRO
Verzekeringen Holding B.V. Zwolle, The Netherlands 51% 81 51% 74
NN Insurance International B.V. The Hague, The Netherlands 100% 20 100% 29
21,271 21,329
Changes in Investments in group companies
2024 2023
Investments in group companies – opening balance 21,329 20,409
Revaluations −102 285
Result of group companies 1,718 1,310
Capital contributions 698
Dividend and repayments −1,674 −1,368
Changes in the composition of the group and other changes −5
Investments in group companies – closing balance 21,271 21,329
NN Group N.V. Annual Report 2024 | 379
Parent company annual accounts
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Parent company annual accounts continued
4 Investments in debt securities at fair value through other comprehensive
income
Changes in Investments in debt securities at fair value through other comprehensive income
2024 2023
Changes in Investments at fair value through OCI - opening balance 1,650 2,398
Additions 3,958 7,250
Disposals and redemptions −4,443 −8,038
Revaluations −1 3
Amortisation 32 37
Changes in Investments at fair value through OCI - closing balance 1,196 1,650
5 Other assets
Other assets
2024 2023
Receivables from group companies 2,514 2,563
Cash 930 570
Investments at fair value through profit or loss 166 367
Other receivables, prepayments and accruals 371 119
Other assets 3,981 3,619
As at 31 December 2024, an amount of EUR 2,196 million (2023: EUR 1,060 million) is expected to be
settled after more than one year from the balance sheet date.
6 Equity
Total equity
2024 2023
Share capital 32 34
Share premium 12,581 12,579
Other reserves 7,218 7,011
Shareholders’ equity 19,831 19,624
Undated subordinated notes 1,736 1,416
Total equity 21,567 21,040
As at 31 December 2024, share premium includes an amount of EUR 6,386 million (2023: EUR 6,387 million)
exempt from Dutch withholding tax.
Share capital
Ordinary shares
(in number)
Ordinary shares
(Amount in millions of euros)
2024 2023 2024 2023
Authorised share capital 700,000,000 700,000,000 84 84
Unissued share capital 431,000,000 415,000,000 52 50
Issued share capital 269,000,000 285,000,000 32 34
For details on share capital and share premium, reference is made to Note 11 ‘Equity’ in the Consolidated
annual accounts.
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Notes to the Parent company annual accounts continued
Changes in Other reserves (2024)
2024
Share of
associates
reserve
Revaluation
reserve
Retained
earnings
Unappropriated
result
1
Total
Other reserves – opening balance 2,915 19 3,069 1,008 7,011
Net result for the year 1,583 1,583
Revaluations in group companies −102 −102
Other revaluations −3 −3
Transfer from (to) share of associates
reserve 245 −245 0
Transfer from (to) retained earnings 674 −674 0
Dividend −681 −681
Purchase (sale) of treasury shares −529 −529
Employee stock option and share plans 1 1
Coupon on undated subordinated notes −62 −62
Other reserves – closing balance 3,058 16 2,908 1,236 7,218
Changes Other reserves (2023)
2023
Share of
associates
reserve
Revaluation
reserve
Retained
earnings
Unappropriated
result
1
Total
Other reserves – opening balance 2,642 2,376 1,634 6,652
Net result for the year 1,172 1,172
Revaluations in group companies 285 285
Other revaluations 1 1
Transfer from (to) share of associates
reserve −12 18 5 11
Transfer from (to) retained earnings 1,376 −1,376 0
Dividend −422 −422
Purchase (sale) of treasury shares −632 −632
Employee stock option and share plans 1 1
Coupon on undated subordinated notes −57 −57
Other reserves – closing balance 2,915 19 3,069 1,008 7,011
1
Unappropriated result at the end of the period represents the net result for the period minus interim dividends paid.
The total amount of Equity in the Parent company annual accounts equals Shareholders’ equity (parent) in
the Consolidated annual accounts. Certain components within equity are different, as a result of the
following presentation differences between the Parent company accounts and Consolidated accounts:
∙ Unrealised revaluations within consolidated group companies, presented in the ‘Revaluation reserve’ in
the Consolidated annual accounts, are presented in the ‘Share of associates reserve’ in the Parent
company annual accounts.
∙ Foreign currency translation on consolidated group companies, presented in the ‘Currency translation
reserve’ in the Consolidated annual accounts, is presented in the ‘Share of associates reserve’ in the
Parent company annual accounts.
∙ Remeasurement of the net defined benefit asset/liability within consolidated group companies presented
in the ‘Net defined benefit asset/liability remeasurement reserve’ in the Consolidated annual accounts, are
presented in the ‘Share of associates reserve’ in the Parent company annual accounts.
∙ Non-distributable retained earnings of associates presented in ‘Other reserves’ in the Consolidated annual
accounts, are presented in the ‘Share of associates reserve’ in the Parent company annual accounts.
∙ For capitalised software and revaluations on illiquid investments held for risk of company recognised in the
profit and loss account in the Consolidated annual accounts, a reclassification is made from ‘Retained
earnings’ to the ‘Share of associates reserve’ in the Parent company annual accounts for the part that is
not distributable.
In 2024, NN Group updated the methodology to determine the legal reserves in the parent company balance
sheet to reflect the full impact of illiquid assets that are classified as Investments at fair value through profit
or loss since the implementation of IFRS 9. The comparative figures as at 31 December 2023 were adjusted
accordingly. This resulted in a reclassification between components of shareholder’s equity in the 2023
comparative figures. The related reclassification is included in the line ‘Transfers from (to) share of
associates reserve and other changes’ in the 2023 disclosure of changes in equity and amounted to EUR 594
million. There was no impact on total shareholders’ equity, net result and distributable reserves.
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Parent company annual accounts
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Parent company annual accounts continued
2024 | 2024 | 2023 | 2023 | |
Shareholders' equity | 19,832 | 19,624 | ||
Share capital | 32 | 34 | ||
Non-distributable reserves | 3,074 | 2,934 | ||
Total non-distributable part of shareholders' equity: | 3,106 | 2,968 | ||
Distributable reserves based on the Dutch Civil Code | 16,726 | 16,656 |
2024 | 2024 | 2023 | 2023 | ||
Solvency requirement under the Financial Supervision Act | 8,786 | 8,990 | |||
Reserves available for financial supervision purposes | 17,026 | 17,691 | |||
Total freely distributable reserves on the basis of solvency requirements | 8,240 | 8,701 | |||
Total freely distributable reserves on the basis of the Dutch Civil Code | 16, | 726 | 16,656 | ||
| Total freely distributable reserves (lower of the values | |||||
above) | 8,240 | 8,701 |
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Notes to the Parent company annual accounts continued
Undated subordinated notes
In March 2024, NN Group announced a tender for purchase by NN Group of the EUR 750 million Fixed to
Floating Rate Undated Subordinated Notes for cash at a price of 100.1% of the nominal amount. The tender
was completed in March 2024 and NN Group accepted the purchase of EUR 287 million in nominal amount. In
June 2024, NN Group additionally redeemed EUR 128 million of the EUR 750 million Fixed to Floating Rate
Undated Subordinated Notes.
In March 2024, NN Group issued euro-denominated, perpetual, restricted Tier 1, temporary write-down
securities for an amount of EUR 750 million. The notes are first callable as from 12 September 2030. The
coupon is fixed at 6.375% per annum until 12 March 2031 and will be reset every fifth year thereafter. These
securities are classified as equity under IFRS-EU. Coupon payments are distributed out of equity if and when
paid or contractually due.
In April 2023 NN Group announced a tender for purchase by NN Group for cash of outstanding subordinated
notes. The tender was completed in May 2023 and NN Group accepted the purchase of EUR 1 billion in
nominal amount. This includes EUR 665 million of subordinated notes previously classified as liabilities in the
balance sheet and EUR 335 million previously classified in equity. Reference is made to Note 16
‘Subordinated debt’.
In July 2014, NN Group N.V. issued fixed to floating rate undated subordinated notes with a par value of
EUR 1,000 million. The notes are undated, but are callable after 11.5 years and every quarter thereafter
(subject to regulatory approval). The coupon is fixed at 4.5% per annum for the first 11.5 years and will be
floating thereafter. As these notes are undated and include optional deferral of interest at the discretion of
NN Group, these are classified under IFRS-EU as equity. Coupon payments are distributed out of equity if and
when paid or contractually due. The discount to the par value and certain issue costs were deducted from
equity at issue, resulting in a balance sheet value equal to the net proceeds of EUR 986 million.
7 Subordinated debt
Subordinated debt
Interest rate
Year of
Issue Due date First call date Notional amount Balance sheet value
2024 2023 2024 2023
4.625% 2014 08April2044 08April2024 335 335
4.625% 2017 13January2048 13January2028 850 850 845 844
5.250% 2022 01March2043 30August2032 500 500 494 494
6.000% 2023 03November2043 03May2033 1,000 1,000 1,007 1,007
Subordinated debt 2,346 2,680
The above subordinated debt instruments have been issued to raise hybrid capital. Under IFRS-EU these
debt instruments are classified as liabilities. They are considered capital for regulatory purposes. All
subordinated debt is euro denominated.
In April 2024, NN Group redeemed the remaining outstanding amount of EUR 335 million of 4.625% Fixed to
Floating Rate Subordinated Notes on their first call date.
In April 2023 NN Group announced the issue of EUR 1 billion subordinated notes issued under NN Group’s
Sustainability Bond Framework with a maturity of 20.5 years and which are first callable after 10 years,
subject to redemption conditions. The coupon is fixed at 6.00% per annum until the first reset date on
3 November 2033 and will be floating thereafter. The Notes qualify as Tier 2 regulatory capital.
In April 2023 NN Group also announced a tender for purchase by NN Group for cash of outstanding
subordinated notes. The tender was completed in May 2023 and NN Group accepted the purchase of EUR 1
billion in nominal amount. This includes EUR 665 million of subordinated notes previously classified as
liabilities in the balance sheet and EUR 335 million previously classified in equity. Reference is made to Note
11 ‘Equit y’.
In June 2014, fixed to floating rate undated subordinated notes with a par value of EUR 750 million were
originally issued by Delta Lloyd which are classified as equity under IFRS-EU. The notes are undated, but are
callable as from 13 June 2024 and every quarter thereafter (subject to regulatory approval). The coupon is
fixed at 4.375% per annum until 13 June 2024 and will be floating thereafter. Coupon payments are
distributed out of equity if and when paid or contractually due. These notes were recognised upon
acquisition of Delta Lloyd for an amount of EUR 778 million.
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Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Notes to the Parent company annual accounts continued
8 Other liabilities
Other liabilities
2024 2023
Debt instruments issued 1,196 1,195
Amounts owed to group companies 1,428 1,790
Other amounts owed and accrued liabilities 127 127
Other liabilities 2,751 3,112
Amounts owed to group companies by remaining term
2024 2023
Within 1 year 1,428 1,790
Amounts owed to group companies 1,428 1,790
9 Other
NN Group N.V. has issued statements of liability in connection with Article 403, Book 2 of the Dutch Civil
Code and other guarantees (mainly funding and redemption guarantees) for group companies. Article 403
statements are issued to NN Insurance International B.V., Nationale-Nederlanden Interfinance B.V. and NN
Personeel B.V. and filed with the Chamber of Commerce.
Reference is made to the Consolidated annual accounts for the number of employees, audit fees and
remuneration of the Executive Board, the Management Board and the Supervisory Board.
Authorisation of the Parent company annual accounts
The Parent company annual accounts of NN Group N.V. for the year ended 31 December 2024 were
authorised for issue in accordance with a resolution of the Executive Board on 12 March 2025. The Executive
Board may decide to amend the Parent company annual accounts as long as these are not adopted by the
General Meeting.
The General Meeting may decide not to adopt the Parent company annual accounts, but may not amend
these during the meeting. The General Meeting can decide not to adopt the Parent company annual
accounts, propose amendments and then adopt the Parent company annual accounts after a normal due
process.
The Hague, 12 March 2025
The Supervisory Board
D.A. (David) Cole, chair
P.F.M. (Pauline) van der Meer Mohr, vice-chair
I.K. (Inga) Beale
R.W. (Robert) Jenkins
R.J.W. (Rob) Lelieveld
C.G. (Cecilia) Reyes
J.V. (Koos) Timmermans
The Executive Board
D.E. (David) Knibbe, CEO, chair
A.T.J. (Annemiek) van Melick, CFO, vice-chair
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Other
information
NN Group N.V. Annual Report 2024 | 385
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
KPMG Accountants N.V., a Dutch limited liability company registered with the trade register in the Netherlands under number 33263683, is a member firm of the global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee.
3074293/25W00196161AVN
Independent auditor's report
To: The General Meeting of Shareholders and the Supervisory Board of NN Group N.V.
Report on the audit of the annual accounts 2024 included in the annual report
Our opinion
In our opinion:
• the accompanying consolidated annual accounts give a true and fair view of the financial position of NN
Group N.V. (hereafter also: ‘the Group’) as at 31 December 2024 and of its result and its cash flows for
the year then ended, in accordance with International Financial Reporting Standards as adopted by the
European Union (EU-IFRS) and in accordance with Part 9 of Book 2 of the Dutch Civil Code; and
• the accompanying parent company annual accounts give a true and fair view of the financial position of
NN Group N.V. as at 31 December 2024 and of its result for the year then ended in accordance with Part
9 of Book 2 of the Dutch Civil Code.
What we have audited
We have audited the annual accounts 2024 of NN Group N.V. based in Amsterdam and headquartered in The
Hague, as set out on pages 243 to 383 of the annual report. The annual accounts include the consolidated
annual accounts and the parent company annual accounts.
The consolidated annual accounts comprise:
• the consolidated balance sheet as at 31 December 2024;
• the following consolidated statements for 2024: the profit and loss account, the statements of
comprehensive income, cash flows and changes in equity; and
• the notes comprising material accounting policy information and other explanatory information.
The parent company accounts comprise:
• the parent company balance sheet as at 31 December 2024;
• the parent company profit and loss account for 2024; and
• the notes comprising a summary of the accounting policies and other explanatory information.
Basis for our opinion
We conducted our audit in accordance with Dutch law, including the Dutch Standards on Auditing. Our
responsibilities under those standards are further described in the ‘Our responsibilities for the audit of the
annual accounts’ section of our report.
We are independent of NN Group N.V. in accordance with the ‘Verordening inzake de onafhankelijkheid van
accountants bij assurance-opdrachten’ (ViO, Code of Ethics for Professional Accountants, a regulation with
respect to independence) and other relevant independence regulations in the Netherlands. Furthermore, we
have complied with the ‘Verordening gedrags- en beroepsregels accountants’ (VGBA, Dutch Code of Ethics).
We designed our audit procedures in the context of our audit of the annual accounts as a whole and in forming
our opinion thereon. The information in respect of going concern, fraud and non-compliance with laws and
regulations, climate change and the key audit matters was addressed in this context, and we do not provide a
separate opinion or conclusion on these matters.
We believe the audit evidence we have obtained is sufficient and appropriate to provide a basis for our
opinion.
Information in support of our opinion
Summary
Materiality
• Materiality of EUR 200 million
• 1% of shareholders’ equity
Group audit
Performed procedures for:
• 92% of revenue
• 88% of shareholders’ equity
• 96% of total assets
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Risk of material misstatements related to Fraud, NOCLAR, Going concern and Climate risks
• Fraud risks: presumed risk of management override of controls and presumed risk of revenue
recognition as further described in the section ‘Audit response to the risk of fraud and non-compliance
with laws and regulations’
• Non-compliance with laws and regulations (NOCLAR) risks: no reportable risk of material misstatement
related to NOCLAR risks identified
• Going concern risks: no going concern risks identified
• Climate risks: We have considered the impact of climate-related risks on the annual accounts and
described our approach and observations in the section ‘Audit response to climate-related risks’
Key audit matters
• Valuation of insurance contract liabilities for life and disability insurance contracts applying the General
Measurement Model
• Valuation of illiquid investments
Materiality
Based on our professional judgement we determined the materiality for the annual accounts as a whole at
EUR 200 million (2023: EUR 200 million). The materiality is determined with reference to shareholders’ equity
and amounts to 1% (2023: 1%).
We consider shareholders’ equity as the most appropriate benchmark based on our assessment of the
general information needs of the users of the annual accounts of insurance companies.
We have also taken into account misstatements and/or possible misstatements that in our opinion are material
for the users of the annual accounts for qualitative reasons.
We agreed with the Audit Committee of the Supervisory Board that misstatements identified during our audit in
excess of EUR 10 million (2023: EUR 10 million) would be reported to them, as well as smaller misstatements
that in our view must be reported on qualitative grounds.
Scope of the group audit
NN Group N.V. is at the head of a group of components. The financial information of this group is included in
the consolidated annual accounts of the Group.
This year, we applied the revised group auditing standard in our audit of the annual accounts. The revised
standard emphasizes the role and responsibilities of the group auditor. The revised standard contains new
requirements for the identification and classification of components, scoping, and the design and performance
of audit procedures across the group.
We performed risk assessment procedures throughout our audit to determine which of the Group’s
components are likely to include risks of material misstatement to the Group annual accounts. To
appropriately respond to those assessed risks, we planned and performed further audit procedures, either at
component level or centrally. We identified 21 components associated with a risk of material misstatement.
For 16 out of these 21 components we involved component auditors. We as group auditor audited the
remaining components. We set component performance materiality levels considering the component’s size
and risk profile.
We have performed substantive procedures for 92% of Group revenue, 96% of Group total assets and 88% of
shareholders’ equity. At Group level, we assessed the aggregation risk in the remaining financial information
and concluded that there is a less than reasonable possibility of a material misstatement.
In supervising and directing our component auditors, we:
• held risk assessment discussions with the component auditors to obtain their input in identifying matters
relevant to the group audit;
• issued group audit instructions to component auditors on the scope, nature and timing of their work, and
received written communication about the results of the work they performed;
• held meetings with all component auditors in person and/or virtually to discuss relevant developments,
understand and evaluate their work;
• attended the audit closing meetings with the component auditor and component management for 6
components;
• performed site visits and physically met with component auditors in the Netherlands, Japan, Belgium,
Czech and Spain to evaluate the work of the component auditor and to attend meetings with local
management; and
• inspected the work performed by 16 component auditors. In doing so we evaluated the appropriateness of
audit procedures performed and conclusions drawn from the audit evidence obtained, and reviewed the
communicated findings for consistency. In our inspection we mainly focused on key audit matters,
significant risks and key judgement areas that are material to the Group.
We consider that the scope of our group audit forms an appropriate basis for our audit opinion. Through
performing the procedures mentioned above we obtained sufficient and appropriate audit evidence about the
Group’s financial information to provide an opinion on the annual accounts as a whole.
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Audit response to the risk of fraud and non-compliance with laws and regulations
As part of our audit, we have gained insights into the Group and its business environment and the Group’s risk
management in relation to fraud and non-compliance. Our procedures included, among other things,
assessing the Group’s code of conduct, whistleblowing procedures, incidents register and its procedures to
investigate indications of possible fraud and non-compliance. Furthermore, we performed relevant inquiries
with the Executive Board, the Supervisory Board and other relevant functions, such as Corporate Audit
Services, Legal Counsel and Compliance, and included correspondence with relevant supervisory authorities
and regulators in our evaluation. We have also incorporated elements of unpredictability in our audit.
In addition, we performed procedures to obtain an understanding of the legal and regulatory frameworks that
are applicable to the Group.
As a result of our risk assessment, we identified the following laws and regulations as those most likely to
have a material effect on the annual accounts in case of non-compliance:
• Wet op het financieel toezicht (Wft) (including the European Solvency II directives);
• Financial and economic crime (FEC) related laws and regulations; and
• Data privacy regulation (GDPR).
Based on the above and on the auditing standards, we identified the following fraud risks that are relevant to
our audit, including the relevant presumed risks laid down in the auditing standards in respect of management
override of controls and revenue recognition.
Management override of controls (a presumed fraud risk)
Risk
Management is in a unique position to manipulate accounting records and prepare fraudulent annual accounts
by overriding controls that otherwise appear to be operating effectively, such as those related to journal entries
and accounting estimates which require significant judgement, for example the valuation of insurance contract
liabilities and illiquid investments.
Response
• We assessed the design and implementation of internal controls that mitigate the risk of fraud related to
journal entries and key estimates.
• We performed data analysis of high-risk journal entries and evaluated key estimates and judgements for
bias by the Group, including retrospective reviews of prior year’s estimates.
• Where we identified instances of unexpected journal entries or other risks through our data analysis we
performed additional audit procedures to address each identified risk. These procedures also included
testing of transactions back to source information.
• We incorporated elements of unpredictability in our audit, such as the revised scoping on account level
and the attendance of closing meetings with management of the components.
• We considered the outcome of our other audit procedures and evaluated whether any findings or
misstatements were indicative of fraud or non-compliance. If so, we re-evaluated our assessment of
relevant risks and its resulting impact on our audit procedures.
We refer to the key audit matters below that provide information of our approach related to areas of higher risk
due to accounting estimates where management makes significant judgements.
Revenue recognition (a presumed fraud risk)
Risk and response
Insurance revenue for the period based on the General Measurement Model (GMM) is to a large extent
determined by the key assumptions made for the measurement of related insurance contract liabilities. We
have covered our assessment of the risk of fraudulent revenue recognition and our response thereto in the key
audit matter below ‘Valuation of insurance contract liabilities for life and disability insurance contracts applying
the General Measurement Model.
We communicated our risk assessment, audit responses and results to management and the Audit Committee
of the Supervisory Board. Our audit procedures did not reveal indications and/or reasonable suspicion of fraud
and non-compliance that are considered material for our audit.
Audit response to going concern
The Executive Board has performed its going concern assessment and has not identified any going concern
risks. To assess management’s assessment, we have performed, inter alia, the following procedures:
• We considered whether management’s assessment of the going concern risks included all relevant
information of which we are aware as a result of our audit.
• We assessed whether the scenarios included in the Own Risk Solvency Assessment (ORSA) and
Preparatory Crisis Plan that were submitted to De Nederlandsche Bank N.V. (the Dutch Central Bank,
DNB) and other regulatory correspondence indicate a significant going concern risk.
• We considered whether the outcome of our audit procedures on the Group’s financial position and
Solvency II capital position indicate a significant going concern risk.
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The outcome of our risk assessment procedures did not give reason to perform additional audit procedures on
management’s going concern assessment.
Audit response to climate-related risks
Management has assessed how climate-related risks and opportunities, and the Group’s own ambitions, could
have a significant impact on its business or could impose the need to adapt its strategy and operations.
Management has considered the impact of both transition and physical risks on the annual accounts in
accordance with the applicable financial reporting framework, more specifically through the valuation of
investments on the asset side and insurance exposure on the liability side. The Group identified the risk of
climate change as an emerging risk which is still developing and could affect the viability of the Group’s
strategy, as is described in the section ‘managing our risks’ in the annual report.
Management prepared the annual accounts and considered whether the implications from climate-related
risks, ambitions and the current and/or anticipated financial effects relating to sustainability matters included in
the sustainability statement have been appropriately accounted for and disclosed. As part of our audit we
performed a risk assessment of the impact of climate-related risk and the ambitions made by the Group in
respect of climate change on the annual accounts and our audit approach. In doing this we performed the
following:
To understand management's processes we:
• Performed an analysis of the external environment and obtained an understanding of the sustainability
themes and issues relevant for the Group;
- Made inquiries of the Sustainability Officer of the Management Board, the Audit Committee of the
Supervisory Board and other senior management.
- Inspected relevant documents to understand management’s assessment against the background of
the Group’s business and operations and the potential impact of climate-related risk and opportunities
on the Group’s annual accounts, and the Group’s preparedness for this.
- Read the minutes of meetings of the Executive Board, Management Board and Supervisory Board.
- Inspected regulatory correspondence to obtain an understanding of management’s assessment of
climate risk and the risk management thereof.
• The Group has prepared its sustainability statement in accordance with the Non-Financial Reporting
Directive using the European Sustainability Reporting Standards (ESRS) as basis for preparation of the
sustainability statement. As part of our risk assessment we have read and considered the sustainability
statement, which includes information on the material impacts, risks and opportunities relating to climate
change. This included reviewing the information reported over the connectivity of the sustainability
statement with the annual accounts, specifically relating to the anticipated financial effects of the
sustainability matters identified (see section: ‘Anticipated financial effects’).
• We have identified and evaluated climate-related fraud risk factors related to reporting inappropriate
disclosures on climate-related risk and pressures for management to meet climate targets, noting that
sustainability targets are linked to the Executive Board’s remuneration.
• We used KPMG climate change subject matter experts to assist in understanding how climate-related
risks and opportunities may affect the Group, in order to understand potential implications for the annual
accounts.
Based on the procedures performed above, we found that climate-related risks have no material impact on the
2024 annual accounts under the requirements of International Financial Reporting Standards as adopted by
the European Union (EU-IFRS), and Part 9 of Book 2 of the Dutch Civil Code, and have no material impact on
our key audit matters.
Furthermore we have read the ‘Other information’ included in the annual report with respect to climate-related
risks and considered whether such information contains material inconsistencies with the annual accounts or
our knowledge obtained through the audit, in particular as described above and our knowledge obtained
otherwise.
Our key audit matters
Key audit matters are those matters that, in our professional judgement, were of most significance in our audit
of the annual accounts. We have communicated the key audit matters to the Executive Board and the Audit
Committee of the Supervisory Board. The key audit matters
are not a comprehensive reflection of all matters
discussed.
These matters were addressed in the context of our audit of the annual accounts as a whole and in forming
our opinion thereon, and we do not provide a separate opinion on these matters.
Compared to last year the key audit matters with respect to the initial application of IFRS 17 and unit-linked
exposure are not included, as the Group has transitioned to IFRS 17 and the significance of the unit-linked
exposure to our audit has declined in 2024 with the agreement reached with interest groups on a settlement.
Valuation of insurance contract liabilities for life and disability insurance contracts applying the
General Measurement Model
Description
Insurance contracts (hereafter: insurance liabilities) measured applying the General Measurement Model
(GMM) amount to EUR 106,503 million as at 31 December 2024, or 72% of total liabilities. The valuation of
insurance liabilities involves the use of cash flow models and methodologies and requires significant
management judgement over assumptions, which also form the basis for determining the Solvency II best
estimate liability.
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Elements that give rise to a significant risk of error are the use of judgmental assumptions in estimating the
fulfillment cash flows under the General Measurement Model. Key assumptions for the valuation of life
insurance contracts relate to expenses, inflation and longevity. For disability contracts key assumptions
relate to morbidity.
As referred to in the section ‘Audit response to the risk of fraud and non-compliance with laws and
regulations’ in this auditor’s report, assumption setting inherently includes the risk that management may
influence assumptions to manage the outcome of calculations and measurements. For example, in
response to perceived pressure to achieve certain key performance targets communicated internally and
externally. In this regard we consider the most critical judgements the maintenance expense assumption for
life insurance contracts and the morbidity assumption for disability contracts.
Given the financial significance, the level of judgement required and the inherent risk of fraud we
considered the valuation of insurance contract liabilities for life and disability insurance contracts applying
the General Measurement Model a key audit matter.
Our response
Our audit approach involves a combination of controls testing and substantive audit procedures. Our
procedures over internal controls focused on testing of controls governing assumption setting and internal
review procedures performed by the actuarial functions at both the Group and component levels. We also
assessed the process for the internal validation and implementation of the models used for the valuation of
the insurance liabilities.
In collaboration with our actuarial specialists we performed the following substantive audit procedures:
• Assessed the appropriateness of assumptions used in the valuation of insurance liabilities for all
significant components by reference to Group data as well as relevant market and industry data.
• Tested the appropriateness of the data used, assumptions and methodologies applied in the valuation
of insurance liabilities for all significant components.
• Performed substantive analysis of developments in actuarial results and movements in provisions, the
risk adjustment, Contractual Service Margin (CSM) and other comprehensive income during the year,
supplemented with corroborative inquiries with management and the Group Chief Actuary.
• Specifically for life insurance contracts, we performed the following:
- Tested and assessed the data used and expert judgment applied by management in determining
the updated Covid-19 excess mortality impact on the level and trend of the longevity assumptions
to identify potential indicators of management bias of assumptions changes made. We also
derived our own estimate for such an impact based on NN’s mortality data and compared the
outcome with management’s estimate.
- Challenged the appropriateness of management’s estimate of expense cash flow projections for
life insurance and pension products, assessing the main assumptions underlying the expected
wage cost development, inflation assumptions and future savings.
We assessed significant changes to the allocation keys used to allocate expenses and we
assessed the methodology applied to determine the cost per policy per product group to also
address the fraud risk of intentionally shifting expenses between portfolios to leverage off the
duration effect to reduce expense provisions in particular product groups.
- We evaluated the outcome of the work performed by the NN Group Model Validation function on
the newly implemented best-estimate Expense inflation model and SCR Expense Inflation Risk
Model, including the use of appropriate external inflation data and expert judgment applied by
management. We reperformed the calculations of the impact of updated inflation rates on the
expense cash flow projections and compared our outcome with management’s valuations.
• For disability contracts we challenged and assessed the appropriateness of the morbidity assumption
and assessed that the morbidity assumption is in line with historical data and expected developments.
• We assessed the disclosures in the annual accounts for compliance with EU-IFRS and the Dutch Civil
Code.
Our observation
We consider the valuation of the insurance contract liabilities measured using the General Measurement
Model to be appropriate. We refer to Note 12 ‘Insurance contracts’ of the annual accounts. No indications
and/or reasonable suspicion of fraudulent activity was identified as a result of the audit procedures
performed.
Valuation of illiquid investments
Description
For illiquid (non-listed) investments quoted prices are not available and fair values are based on valuation
techniques which often involve the exercise of judgement by management and the use of assumptions,
estimates and unobservable inputs. Where significant pricing inputs are unobservable, management has no
reliable, relevant market data available in determining the fair value. For these illiquid investments the
estimation uncertainty can be high, especially due to increased market volatilities. This is mainly applicable
to:
• mortgages held by the insurance entities, which are measured at fair value through other
comprehensive income;
• real estate investments; and
• private equity and private debt investments.
Given the financial significance and estimation uncertainties we considered the valuation of illiquid
investments a key audit matter.
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Our response
We assessed management’s approach to the valuation of illiquid investments and performed the following
procedures:
• Evaluated the Group’s processes and controls governing the valuation of non-listed investments.
• Inspected the supporting valuation documents prepared by management’s internal and external
valuation experts.
• We evaluated the objectivity, independence and professional competence of external valuation experts
engaged by management.
• We involved our real estate valuation specialists in the substantive audit procedures of selected real
estate investments. These procedures included inspecting the valuation reports obtained from
management’s expert, testing the source data used and the calculations made, and challenging
significant assumptions such as the gross initial yield/discount rate and estimated rental values.
• Where available, we assessed the assumptions used against relevant market data and object specific
underlying characteristics such as occupancy rates and contract renewals.
• We tested and challenged management’s valuation of private equity and private debt investments by
critically reviewing the minutes of the meetings of management with the external fund managers, we
tested the timeliness of such meetings and performed a retrospective review of prior valuations to
assess the reliability of the fair value estimates provided by the external fund managers. We compared
movements in the valuations for the period with available external market data and the results of
comparable asset sales that occurred during the period.
• In collaboration with KPMG valuation specialists, challenged the appropriateness of the models and
methodologies used by management in calculating fair values of mortgages. We tested the source data
used and assessed the appropriateness of critical valuation parameters. Our valuation specialists
independently calculated whether the fair value for the mortgage portfolio as a whole as determined by
management is within the acceptable fair value range.
• We assessed the disclosures in the annual accounts for compliance with EU-IFRS and the Dutch Civil
Code.
Our observation
We consider the fair value of illiquid investments to be appropriate. We observed that valuation
uncertainties in real estate investments remained significant in 2024 due to the limited number of relevant
market transactions to support the estimated yield levels that are used for valuation purposes. We refer to
Note 33 ‘Fair value of non-financial assets’ of the annual accounts in which the real estate valuation
uncertainties are disclosed.
Report on the other information included in the annual report
In addition to the annual accounts and our auditor’s report thereon, the annual report contains other
information.
Based on the following procedures performed, we conclude that the other information:
• is consistent with the annual accounts and does not contain material misstatements; and
• contains the information as required by Part 9 of Book 2 of the Dutch Civil Code for the management
report and other information.
We have read the other information. Based on our knowledge and understanding obtained through our audit of
the annual accounts or otherwise, we have considered whether the other information contains material
misstatements.
By performing these procedures, we comply with the requirements of Part 9 of Book 2 of the Dutch Civil Code
and the Dutch Standard 720. The scope of the procedures performed is less than the scope of those
performed in our audit of the annual accounts.
The Executive Board is responsible for the preparation of the other information, including the information as
required by Part 9 of Book 2 of the Dutch Civil Code.
Report on other legal and regulatory requirements and ESEF
Engagement
We were initially appointed by the General Meeting of Shareholders as auditor of NN Group N.V. on 28 May
2015, as of the audit for the year 2016 and have operated as statutory auditor since that date. We were
reappointed at the General Meeting of Shareholders on 19 May 2022 to continue to serve the Group as its
external auditor for financial years 2023-2025.
No prohibited non-audit services
We have not provided prohibited non-audit services as referred to in Article 5(1) of the EU Regulation on
specific requirements regarding statutory audits of public-interest entities.
European Single Electronic Format (ESEF)
The Group has prepared its annual report in ESEF. The requirements for this are set out in the Delegated
Regulation (EU) 2019/815 with regard to regulatory technical standards on the specification of a single
electronic reporting format (hereinafter: the RTS on ESEF).
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In our opinion, the annual report prepared in XHTML format, including the (partly) marked-up consolidated
annual accounts as included in the reporting package by NN Group N.V., complies in all material respects with
the RTS on ESEF.
The Executive Board is responsible for preparing the annual report including the annual accounts in
accordance with the RTS on ESEF, whereby the Executive Board combines the various components into one
single reporting package.
Our responsibility is to obtain reasonable assurance for our opinion whether the annual report in this reporting
package complies with the RTS on ESEF. We performed our examination in accordance with Dutch law,
including Dutch Standard 3950N ‘Assurance-opdrachten inzake het voldoen aan de criteria voor het opstellen
van een digitaal verantwoordingsdocument’ (assurance engagements relating to compliance with criteria for
digital reporting).
Our examination included, but was not limited to:
• Obtaining an understanding of the entity’s financial reporting process, including the preparation of the
reporting package.
• Identifying and assessing the risks that the annual report does not comply in all material respects with the
RTS on ESEF and designing and performing further assurance procedures responsive to those risks to
provide a basis for our opinion, including:
- Obtaining the reporting package and performing validations to determine whether the reporting
package containing the Inline XBRL instance document and the XBRL extension taxonomy files have
been prepared in accordance with the technical specifications as included in the RTS on ESEF.
- Examining the information related to the consolidated annual accounts in the reporting package to
determine whether all required mark-ups have been applied and whether these are in accordance
with the RTS on ESEF.
Description of responsibilities regarding the annual accounts
Responsibilities of the Executive Board and the Supervisory Board for the annual
accounts
The Executive Board is responsible for the preparation and fair presentation of the annual accounts in
accordance with EU-IFRS and Part 9 of Book 2 of the Dutch Civil Code. Furthermore, the Executive Board is
responsible for such internal control as management determines is necessary to enable the preparation of the
annual accounts that are free from material misstatement, whether due to fraud or error. In that respect the
Executive Board, under supervision of the Supervisory Board, is responsible for the prevention and detection
of fraud and non-compliance with laws and regulations, including determining measures to resolve the
consequences of it and to prevent recurrence.
As part of the preparation of the annual accounts, the Executive Board is responsible for assessing the
Group’s ability to continue as a going concern. Based on the financial reporting frameworks mentioned, the
Executive Board should prepare the annual accounts using the going concern basis of accounting unless the
Executive Board either intends to liquidate the NN Group N.V. or to cease operations or has no realistic
alternative but to do so. The Executive Board should disclose events and circumstances that may cast
significant doubt on the Group’s ability to continue as a going concern in the annual accounts. The
Supervisory Board is responsible for overseeing the Group’s financial reporting process.
Our responsibilities for the audit of the annual accounts
Our objective is to plan and perform the audit engagement in a manner that allows us to obtain sufficient and
appropriate audit evidence for our opinion.
Our audit has been performed with a high, but not absolute, level of assurance, which means we may not
detect all material errors and fraud during our audit.
Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate,
they could reasonably be expected to influence the economic decisions of users taken on the basis of these
annual accounts. The materiality affects the nature, timing and extent of our audit procedures and the
evaluation of the effect of identified misstatements on our opinion.
A further description of our responsibilities for the audit of the annual accounts is located at the website of de
‘Koninklijke Nederlandse Beroepsorganisatie van Accountants’ (NBA, Royal Netherlands Institute of Chartered
Accountants): eng_beursgenoteerd_01.pdf (nba.nl)
. This description forms part of our auditor’s report.
Amstelveen, 12 March 2025
KPMG Accountants N.V.
J.N. Vos RA
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KPMG Accountants N.V., a Dutch limited liability company registered with the trade register in the Netherlands under number 33263683, is a member firm of the global organization of independent member firms affiliated with
KPMG International Limited, a priv
ate English company limited by guarantee.
Limited assurance report of the independent auditor on the Sustainability
Statement
To: the General Meeting of Shareholders and the Supervisory Board of NN Group N.V.
Our conclusion
We have performed a limited assurance engagement on the consolidated Sustainability Statement for
2024 of NN Group N.V. based in Amsterdam and headquartered in The Hague, (hereafter also: ‘NN
Group’), including the information incorporated in the Sustainability Statement by reference
(hereinafter: the sustainability statement).
Based on the procedures performed and the assurance evidence obtained, nothing has come to our
attention that causes us to believe that the sustainability statement is not, in all material respects:
― prepared in accordance with the European Sustainability Reporting Standards (ESRS) as
adopted by the European Commission and in accordance with the double materiality
assessment process carried out by NN Group to identify the information reported pursuant to
the ESRS; and
― compliant with the reporting requirements provided for in Article 8 of Regulation (EU) 2020/852
(Taxonomy Regulation).
Basis for our conclusion
We performed our limited assurance engagement on the sustainability information in accordance with
Dutch law, including Dutch Standard 3810N ‘Assurance-opdrachten inzake
duurzaamheidsverslaggeving’ (Assurance engagements relating to sustainability reporting) which is a
specified Dutch standard that is based on the International Standard on Assurance Engagements
(ISAE) 3000 (Revised) ’Assurance engagements other than audits or reviews of historical financial
information’. Our responsibilities under this standard are further described in the section ‘Our
responsibilities for the assurance engagement on the sustainability information’ section of our report.
We are independent of NN Group in accordance with the ‘Verordening inzake de onafhankelijkheid van
accountants bij assurance-opdrachten’ (ViO, Code of Ethics for Professional Accountants, a regulation
with respect to independence). Furthermore, we have complied with the ‘Verordening gedrags- en
beroepsregels accountants’ (VGBA, Dutch Code of Ethics for Professional Accountants).
We believe the assurance evidence we have obtained is sufficient and appropriate to provide a basis
for our conclusion.
Emphasis of matters
We draw attention to section ‘General Basis for Preparation’ of the sustainability statement. This
disclosure sets out that the sustainability statement has been prepared in a context of new
sustainability reporting standards requiring entity-specific and temporary interpretations and addressing
inherent measurement or evaluation uncertainties.
The section ‘General Basis for Preparation’, addresses inherent measurement or evaluation
uncertainties. This paragraph identifies the quantitative metrics and monetary amounts that are subject
to a high level of measurement uncertainty and discloses information about the sources of
measurement uncertainty and the assumptions, approximations and judgements NN Group has made
in measuring these in compliance with the ESRS.
We draw attention to the disclosure on the asset scope of financed emissions on page 149, disclosing
the cause for excluding NN Group’s carbon footprint related to investments for risk of policyholders.
The comparability of sustainability information between entities and over time may be affected by the
lack of historical sustainability information in accordance with the ESRS and by the absence of a
uniform practice on which to draw, to evaluate and measure this information. This allows for the
application of different, but acceptable, measurement techniques, especially in the initial years.
‘Our approach to the DMA’, ‘Assessing materiality’, and ‘Our material sustainability matters’
paragraph’s in the sustainability statement explains future improvements in the ongoing due diligence
and double materiality assessment process, including robust engagement with affected stakeholders.
Due diligence is an on-going practice that responds to and may trigger changes in NN Group’s
strategy, business model, activities, business relationships, operating, sourcing and selling contexts.
The double materiality assessment process may also be impacted in time by sector-specific standards
to be adopted. The sustainability statement may not include every impact, risk and opportunity or
additional entity-specific disclosure that each individual stakeholder (group) may consider important in
its own particular assessment.
Our conclusion is not modified in respect to these matters.
Limitations to the scope of our assurance engagement
Limited assurance has been provided on the non-financial statements reported in the prior-year annual
report, however not in the context of the new sustainability reporting standards (ESRS). Consequently
the corresponding sustainability information and thereto related disclosures on the period up to 2024
has not been subject to limited assurance procedures in the context of the ESRS.
In reporting forward-looking information in accordance with the ESRS, the Executive Board of NN
Group is required to prepare the forward-looking information on the basis of disclosed assumptions
about events that may occur in the future and possible future actions by NN Group. The actual
outcome is likely to be different since anticipated events frequently do not occur as expected. Forward-
looking information relates to events and actions that have not yet occurred and may never occur. We
do not provide assurance on the achievability of this forward-looking information.
The references to external sources or websites in the sustainability information are not part of the
sustainability information as included in the scope of our assurance engagement. We therefore do not
provide assurance on this information.
Our conclusion is not modified in respect to these matters.
NN Group N.V. Annual Report 2024 | 393
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Responsibilities of the Executive Board and the Supervisory Board for the
sustainability statement
The Executive Board is responsible for the preparation of the sustainability statement in accordance
with the ESRS, including the double materiality assessment process carried out by NN Group as the
basis for the sustainability statement and disclosure of material impacts, risks and opportunities in
accordance with the ESRS. As part of the preparation of the sustainability statement, management is
responsible for compliance with the reporting requirements provided for in Article 8 of Regulation (EU)
2020/852 (Taxonomy Regulation). The Executive Board is also responsible for selecting and applying
additional entity-specific disclosures to enable users to understand NN Group’s sustainability-related
impacts, risks or opportunities and for determining that these additional entity-specific disclosures are
suitable in the circumstances and in accordance with the ESRS
Furthermore, the Executive Board is responsible for such internal control as it determines is necessary
to enable the preparation of the sustainability statement that is free from material misstatement,
whether due to fraud or error.
The Supervisory Board is responsible for overseeing the sustainability reporting process including the
double materiality assessment process carried out by NN Group.
Our responsibilities for the assurance engagement on the sustainability
statement
Our responsibility is to plan and perform the assurance engagement in a manner that allows us to
obtain sufficient and appropriate assurance evidence for our conclusion.
Our assurance engagement is aimed to obtain a limited level of assurance to determine the plausibility
of sustainability information. The procedures vary in nature and timing from, and are less in extent,
than for a reasonable assurance engagement. The level of assurance obtained in a limited assurance
engagement is therefore substantially less than the assurance that is obtained when a reasonable
assurance engagement is performed.
We apply the quality management requirements pursuant to the Nadere voorschriften
kwaliteitsmanagement (NV KM, regulations for quality management) and accordingly maintain a
comprehensive system of quality management including documented policies and procedures
regarding compliance with ethical requirements, professional standards and applicable legal and
regulatory requirements.
Our limited assurance engagement included among others:
― Performing inquiries and an analysis of the external environment and obtaining an
understanding of relevant sustainability themes and issues, the characteristics of NN Group, its
activities and the value chain and its key intangible resources in order to assess the double
materiality assessment process carried out by NN Group as the basis for the sustainability
statement and disclosure of all material sustainability-related impacts, risks and opportunities in
accordance with the ESRS.
― Obtaining through inquiries a general understanding of the internal control environment, NN
Group’s processes for gathering and reporting entity-related and value chain information, the
information systems and NN Group’s risk assessment process relevant to the preparation of the
sustainability statement and for identifying NN Group’s activities, determining eligible and
aligned economic activities and prepare the disclosures provided for in Article 8 of Regulation
(EU) 2020/852 (Taxonomy Regulation), without obtaining assurance evidence about the
implementation, or testing the operating effectiveness, of controls.
― Assessing the double materiality assessment process carried out by NN Group and identifying
and assessing areas of the sustainability statement, including the disclosures provided for in
Article 8 of Regulation (EU) 2020/852 (Taxonomy Regulation) where misleading or unbalanced
information or material misstatements, whether due to fraud or error, are likely to arise
(‘selected disclosures’). We designed and performed further assurance procedures aimed at
assessing that the sustainability statement is free from material misstatements responsive to
this risk analysis.
― Considering whether the description of the double materiality assessment process in the
sustainability statement made by the Executive Board appears consistent with the process
carried out by NN Group.
― Performing analytical review procedures on quantitative information in the sustainability
statement, including consideration of data and trends.
― Assessing whether NN Group’s methods for developing estimates are appropriate and have
been consistently applied for selected disclosures. We considered data and trends, however,
our procedures did not include testing the data on which the estimates are based or separately
developing our own estimates against which to evaluate management’s estimates.
― Analysing, on a limited sample basis, relevant internal and external documentation available to
NN Group (including publicly available information or information from actors throughout its
value chain) for selected disclosures.
― Reading the other information in the annual report to identify material inconsistencies, if any,
with the sustainability statement.
― Considering whether:
- the disclosures provided to address the reporting requirements provided for in Article 8 of
Regulation (EU) 2020/852 (Taxonomy Regulation) for each of the environmental
objectives, reconcile with the underlying records of NN Group and are consistent or
coherent with the sustainability statement;
- the disclosures provided to address the reporting requirements provided for in Article 8 of
Regulation (EU) 2020/852 (Taxonomy Regulation) appear reasonable, in particular
whether the eligible economic activities meet the cumulative conditions to qualify as
aligned and whether the technical screening criteria are met; and
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- the key performance indicators disclosures have been defined and calculated in
accordance with the Taxonomy reference framework as defined in Appendix 1 Glossary
of Terms of the CEAOB Guidelines on limited assurance on sustainability reporting
adopted on 30 September 2024 , and in compliance with the reporting requirements
provided for in Article 8 of Regulation (EU) 2020/852 (Taxonomy Regulation), including
the format in which the activities are presented.
― Considering the overall presentation, structure and the fundamental qualitative characteristics of
information (relevance and faithful representation: complete, neutral and accurate) reported in
the sustainability statement, including the reporting requirements provided for in Article 8 of
Regulation (EU) 2020/852 (Taxonomy Regulation).
― Considering, based on our limited assurance procedures and evaluation of the assurance
evidence obtained, whether the sustainability statement as a whole, is free from material
misstatements and prepared in accordance with the ESRS.
Amstelveen, 12 March 2025
KPMG Accountants N.V.
J.N. Vos RA
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Appropriation of result
The result is appropriated pursuant to Article 34 of the Articles of Association of NN Group N.V., the relevant
stipulations of which state that the appropriation of result shall be determined by the General Meeting, on
the proposal of the Executive Board, as approved by the Supervisory Board, having heard the advice of the
Executive Board. It is proposed to add the 2024 net result less the (interim and final) cash dividends to the
retained earnings.
Other information
NN Group N.V. Annual Report 2024 | 396
Our response to the Task Force on Climate-related Financial Disclosures (TCFD) continued
Appendix
In this section we share our progress on
our commitments, show where we have
included TCFD disclosures, detail our GHG
emissions, provide an overview of the
sustainability indices and ratings, and
include a glossary of terms used in this
report.
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
NN Group N.V. Annual Report 2024 | 397
Principles for Sustainable Insurance (PSI) Progress report 2024
In June 2012, we became a founding signatory of the UN Principles for Sustainable Insurance. We report on
our progress in implementing the principles in our business operations throughout the NN Group Annual
Report.
Our commitment Our goals Our progress 2024
We will embed in our decision-making environmental,
social and governance issues, relevant to our business
– Transition proprietary investment portfolio to net-zero GHG
emissions by 2050
– Transition the underwriting portfolio to net-zero GHG emissions by
2050
– Reduce GHG emissions of own business operations to net-zero by
2040
– More than double investments in climate solutions such as
renewable infrastructure, green bonds and energy-efficient real
estate
– Carbon footprint (measured as tonnes CO
2
e/EUR million invested) of NN Group’s corporate investments (proprietary
assets) was 86 tonnes of CO
2
e in 2024. p. 151
– Carbon footprint (measured as tonnes CO
2
e/m
2
) of NN Group’s residential mortgages was 22.9 kg of CO
2
e in 2024.
p. 154
– The insurance-associated GHG emissions for NN Group’s commercial lines was 56 kilotonnes CO
2
e in 2024. p. 156
– The insurance-associated GHG emissions (measured as tonnes CO
2
e/100 vehicles) for NN Group’s Private Motor line
was 10.73 in 2024. p. 156
– NN Group’s own operations’ GHG emissions, scope 1 and scope 2 (market-based) was 6.3 kilotonnes CO
2
e in 2024
and scope 3 business air travel was 3.6 kilotonnes CO
2
e. p. 146
– NN Group’s total Investments in Climate Solutions was EUR 12.8 bn in 2024. p. 154
We will work together with clients and business
partners to raise awareness of environmental, social
and governance issues, manage risk and develop
solutions
– Reassess our role as an asset owner and expand active ownership
activities
– Develop relevant products and services
– Manage our direct footprint and review our procurement process in
order to create more sustainable practices
– In 2024, we formulated a Responsible Insurance Underwriting (RIU) Framework Policy, to provide direction on the
integration of sustainability matters into insurance underwriting activities. p. 143
– In 2024, NN Group updated its Voting Policy for Proprietary Assets available on our website. The revision includes
detailed explanation of NN’s stance on environmental, social and governance (ESG) topics, clarification of
expectation for investee companies and external asset managers and updates on NN’s voting policy on issues like
remuneration and taxation. p. 139
– As an insurer we engaged with clients and intermediaries on sustainability matters like climate change. p. 144
We will work together with governments, regulators
and other key stakeholders to promote widespread
action across society on environmental, social and
governance issues
– Engage with stakeholders on general developments or more specific
issues, ranging from products, services and business performance
to our role in society
– Contribute to communities by supporting the financial, physical and/
or mental well-being of one million people by 2025
– In 2024, we partnered with the Verbond van Verzekeraars (Dutch Association of Insurers) to host a collaborative
dialogue, supported by their knowledge partner EY. This initiative brought together leading organisations in the
Netherlands on sustainability topics, creating a space for valuable cross-sector conversations. p. 128
– In 2024, we have a partnership on Mental Well-being & Resilience for the Next Generation in collaboration with SOS
Children’s Villages and Save the Children. p. 201
We will demonstrate accountability and transparency in
regularly disclosing publicly on our progress in
implementing the principles
– Ensure public disclosure of our non-financial objectives, and the
progress we make, in our annual reporting
– NN Group published our 2024 Annual Report. This table serves as a cross-reference to the relevant sections in these
reports and our website.
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
NN Group N.V. Annual Report 2024 | 398
Our response to the Task Force on Climate-related Financial Disclosures (TCFD)
TCFD Recommended Disclosures Annual Report reference
Governance a) Describe the board’s oversight of climate-related risks and opportunities – Governance - Corporate governance - Sustainability governance
– Governance - Corporate governance - Sustainability is embedded in our
governance
b) Describe management’s role in assessing and managing climate-related
risks and opportunities
– Governance - Corporate governance - Sustainability is embedded in our
governance
Strategy a) Describe the climate-related risks and opportunities the organisation has
identified over the short, medium and long term
– Sustainability Statement - General disclosures - Our approach to the DMA
b) Describe the impact of climate-related risks and opportunities on the
organisation’s business, strategy and financial planning
– Sustainability Statement - General disclosures - Our approach to the DMA
– Sustainability Statement - General disclosures - Connecting our
sustainability matters to our strategy and business model
c) Describe the resilience of the organisation’s strategy, taking into
considerations different climate-related scenarios, including a 2°C or lower
scenario
– Sustainability Statement - Environment - Risk scenarios
Risk management a) Describe the organisation’s processes for identifying and assessing
climate-related risks
– Sustainability Statement - Environment - Climate Risk Assessment
framework
– Sustainability Statement - Environment - Climate Risk Assessment
approach
b) Describe the organisation’s processes for managing climate-related risks – Sustainability Statement - Environment - Climate Risk Assessment results
- Risk-mitigating measures for investments
– Sustainability Statement - Environment - Climate Risk Assessment results
- Risk-mitigating measures for liabilities
– Managing our risks - Sustainability risks
c) Describe how processes for identifying, assessing and managing climate-
related risks are integrated into the organisation’s overall risk management
– Managing our risks - Managing our risks
Metric and targets a) Disclose the metrics used by the organisation to assess climate-related
risks and opportunities in line with its strategy and risk management
process
– Sustainability Statement - Environment - Climate Risk Assessment - Step 4:
Assess impact
b) Disclose scope 1, scope 2, and, if appropriate, scope 3 GHG emissions, and
the related risks
– Sustainability Statement - Environment - Total GHG emissions aggregated
by scope 1 and 2 and material scope 3 categories
c) Describe the targets used by the organisation to manage climate-related
risks and opportunities and performance against targets
– Sustainability Statement - Environment - Targets
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
NN Group N.V. Annual Report 2024 | 399
United Nations Global Compact (UNGC) Progress report 2024
UN Global Compact NN Group commitment Performance
Principle 1
Businesses should support and respect the protection
of internationally proclaimed human rights
– The NN statement of Living our Values includes the commitment to
respect human rights
– Human rights are an integral part of NN Group’s Responsible
Investment Framework policy that applies to all asset classes
– We ask our suppliers to agree to comply with the UNGC principles
that promote human rights, fair labour practices, environmental
protection and anti-corruption
– NN Group is a member of various international networks and
initiatives
– NN statement of Living our Values
– NN Group Human Rights statement
– NN Group’s Responsible Investment Framework policy sets out our vision and
approach in this area. NN Group applies norms-based responsible investment
criteria that are a reflection of relevant laws, the organisation’s values and
internationally recognised standards such as the UN Global Compact, the UN
Guiding Principles on Business and Human Rights, and the OECD Guidelines for
Multinational Enterprises
– NN will implement human rights considerations as part of its RIU Policy, first
published in 2024
– NN Group Sustainable Procurement Statement
– NN Group Supplier Code of Conduct
– NN Group Investment Guidance paper on Human Rights
– NN Group memberships
www.nn-group.com
Principle 2
Businesses should make sure that they are not
complicit in human rights abuses
– The NN statement of Living our Values includes the commitment to
respect human rights
– Human rights are an integral part of NN Group’s Responsible
Investment Framework policy that applies to all asset classes
– We ask our suppliers to agree to comply with the UNGC principles
that promote human rights, fair labour practices, environmental
protection,and anti-corruption.
– NN Group is a member of various international networks and
initiatives
– NN statement of Living our Values
– NN Group Human Rights statement
– NN Group’s Responsible Investment Framework policy sets out our vision and
approach in this area. NN Group applies norms-based responsible investment
criteria that are a reflection of relevant laws, the organisation’s values and
internationally recognised standards such as the UN Global Compact, the UN
Guiding Principles on Business and Human Rights, and the OECD Guidelines for
Multinational Enterprises
– NN will implement human rights considerations as part of its RIU Policy, first
published in 2024
– NN Group Sustainable Procurement Statement
– NN Group Supplier Code of Conduct
– NN Group Investment Guidance paper on Human Rights
– NN Group memberships
www.nn-group.com
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
NN Group N.V. Annual Report 2024 | 400
United Nations Global Compact (UNGC) Progress report 2024 continued
UN Global Compact NN Group commitment Performance
Principle 3/ILO Conventions 87 and 98
Businesses should uphold the freedom of association
and the effective recognition of the right to collective
bargaining
– The NN statement of Living our Values includes the commitment to
respect human rights, advocate equal opportunities and encourage
diversity of thinking
– At NN Group, we uphold the freedom of association for all our
employees and recognise the right to collective bargaining
– Human rights are an integral part of NN Group’s Responsible
Investment Framework policy that applies to all asset classes
– We ask our suppliers to agree to comply with the UNGC principles
that promote human rights, fair labour practices, environmental
protection and anti-corruption
– NN statement of Living our Values
– NN Group Human Rights statement
– NN Group Investment Guidance paper on Labour Rights
– NN Group Statement on Diversity and Inclusion
– Diversity and Inclusion overview
– Human Resources Framework Standard
– NN Group’s Responsible Investment Framework policy sets out our vision and
approach in this area. NN Group applies norms-based responsible investment criteria
that are a reflection of relevant laws, the organisation’s values, and internationally
recognised standards such as the UN Global Compact, the UN Guiding Principles on
Business and Human Rights, and the OECD Guidelines for Multinational Enterprises
– NN Group Sustainable Procurement Statement
– NN Group Supplier Code of Conduct
www.nn-group.com
Principle 4/ILO Conventions 29 and 105
Businesses should support the elimination of all forms
of forced and compulsory labour
– The NN statement of Living our Values includes the commitment to
respect human rights
– Human rights are an integral part of NN Group’s Responsible
Investment Framework policy that applies to all asset classes
– We ask our suppliers to agree to comply with the UNGC principles
that promote human rights, fair labour practices, environmental
protection and anti-corruption
– NN statement of Living our Values
– NN Group Human Rights statement
– NN Group Investment Guidance paper on Labour Rights
– NN Group’s Responsible Investment Framework policy sets out our vision and
approach in this area. NN Group applies norms-based responsible investment criteria
that are a reflection of relevant laws, the organisation’s values, and internationally
recognised standards such as the UN Global Compact, the UN Guiding Principles on
Business and Human Rights, and the OECD Guidelines for Multinational Enterprises
– NN Group RIU Policy
– NN Group Sustainable Procurement Statement
– NN Group Supplier Code of Conduct
www.nn-group.com
Principle 5/ILO Conventions 138 and 182
Business should support the effective abolition of child
labour
– The NN statement of Living our Values includes the commitment to
respect human rights.
– Human rights are an integral part of NN Group’s Responsible
Investment Framework policy and applies to all asset classes.
– We ask our suppliers to agree to comply with the UNGC principles
that promote human rights, fair labour practices, environmental
protection and anti-corruption.
– NN statement of Living our Values
– NN Group Human Rights statement
– NN Group Investment Guidance paper on Labour Rights
– NN Group’s Responsible Investment Framework policy sets out our vision and
approach in this area. NN Group applies norms-based Responsible Investment
criteria that are a reflection of relevant laws, the organisation’s values, and
internationally recognised standards such as the UN Global Compact, the UN Guiding
Principles on Business and Human Rights, and the OECD Guidelines for Multinational
Enterprises.
– NN Group RIU Policy
– NN Group Sustainable Procurement Statement
– NN Group Supplier Code of Conduct
www.nn-group.com
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NN Group N.V. Annual Report 2024 | 401
United Nations Global Compact (UNGC) Progress report 2024 continued
UN Global Compact NN Group commitment Performance
Principle 6/ILO Conventions 100 and 111
Businesses should support the elimination of
discrimination in respect of employment and
occupation
– The NN statement of Living our Values includes the commitment to
respect human rights
– At NN Group, we believe it is right for the composition of our
workforce to reflect that of society and for our people to bring a
diversity of talents, beliefs and perceptions to their work
– NN statement of Living our Values
– NN Group Human Rights statement
– Diversity and Inclusion overview
– NN Group Statement on Diversity and Inclusion
www.nn-group.com
Principle 7
Businesses should support a precautionary approach to
environmental challenges
– The NN statement of Living our Values includes the commitment to
respect each other and the world we live in
– NN Group will increase investments in climate solutions with an
additional EUR 6 billion by 2030, taking the total investments in
climate solutions to around EUR 11 billion
– NN Group’s Climate Action Plan aims to mitigate environmental and
social risk of our investment and insurance activities
– NN Group RIU Policy, with restrictions for climate change sensitive
sectors and additional due diligence for possible environmental risks
in specific sectors
– NN Group’s environmental approach aims to minimise the
environmental impact of our own operations
– NN Group’s Procurement and Outsourcing Policy includes
environmental aspects
– NN statement of Living our Values
– NN Group Climate Action Plan
– NN Group RIU Policy
www.nn-group.com
Principle 8
Businesses should undertake initiatives to promote
greater environmental responsibility
– The NN statement of Living our Values includes the commitment to
respect each other and the world we live in
– NN Group will increase investments in climate solutions with an
additional EUR 6 billion by 2030, taking the total investments in
climate solutions to around EUR 11 billion
– NN Group’s RIU Policy aims to mitigate environmental and social risk
of our investment activities
– NN Group’s Procurementand Outsourcing Policy includes
environmental issues, this is to ensure environmental sustainability
– NN Group is a member of various international networks and
initiatives
– NN statement of Living our Values
– NN Group Climate Action Plan
– NN Responsible Investment Framework Policy
– NN Group Investment Guidance paper on the Environment
– NN Group Investment Guidance paper on Animal Welfare
– NN Group White paper Biodiversity approach for investments
www.nn-group.com
Principle 9
Businesses should encourage the development and
diffusion of environmentally friendly technologies
– The NN statement of Living our Values includes the commitment to
respect each other and the world we live in
– NN Group will increase investments in climate solutions with an
additional EUR 6 billion by 2030, taking the total investments in
climate solutions to around EUR 11 billion
– NN statement of Living our Values
– NN Group Climate Action Plan
– NN Responsible Investment Framework Policy
– NN Group Investment Guidance paper on the Environment
– NN Group White paper Biodiversity approach for investments
www.nn-group.com
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NN Group N.V. Annual Report 2024 | 402
United Nations Global Compact (UNGC) Progress report 2024 continued
UN Global Compact NN Group commitment Performance
Principle 10
Businesses should work against corruption in all its
forms, including extortion and bribery
– The NN statement of Living our Values includes the commitment to
act with integrity. NN Group has zero tolerance of bribery and
corruption and has clear policies on this. NN Group implements a
Code of Conduct.
– NN statement of Living our Values
– NN Group Code of Conduct
www.nn-group.com
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NN Group N.V. Annual Report 2024 | 403
GHG emissions
Total GHG emissions (tCO
2
e) aggregated by scope 1, 2 and 3 categories
Retrospective Milestones and target years
Base year 2023 2024
% Actuals / Last
year
% Actuals / Base
year Target 2025 Target 2030 Target 2040 Target 2050
% Annual target /
Base year
Scope 1 GHG emissions (base year = 2019)
Gross scope 1 GHG emissions
1
3,032 1,785 1,896 6% −37% −45% −75% Net zero −8%
Scope 2 GHG emissions (base year = 2019)
Gross scope 2 GHG emissions - location-based
2
7,832 6,613 −16%
Gross scope 2 GHG emissions - market-based 6,601 5,092 4,375 −14% −34% −45% −75% Net zero −8%
Significant scope 3 GHG emissions - own operations (base year = 2019)
Category 1 - purchased goods and services 87,064 75,057 −14%
Category 3 - fuel and energy related activities (not included in scope 1 or scope 2) 1,214 1,183 −3%
Category 5 - waste generated in operations 533 636 19%
Category 6 - business travel (ground + air) 5,362 6,185 15%
Category 6 - business travel (ground) 2,247 2,548 13%
Category 6 - business travel (air) 4,275 3,115 3,637 17% −15% −25% −50% Net zero −4%
Category 7 - employee commuting 5,603 6,133 9%
Significant scope 3 GHG emissions - investments
Category 15 - financed investments
3,4
3,493,779 2,897,152 −17%
Significant scope 3 GHG emissions - underwriting
Category 15 - insurance-associated emissions
5
200,844 199,513 −1% Net zero
Scope 3 GHG emissions
Gross scope 3 GHG emissions 3,794,398 3,185,858 −16%
Total GHG emissions
6
Total GHG emissions (scope 1, 2 and 3) – location-based
3,804,015 3,194,367 −16%
Total GHG emissions (scope 1, 2 and 3) – market-based
3,801,276 3,192,130 −16%
1
0% of NN’s scope 1 GHG emissions are covered by regulated emissions trading schemes.
2
NN does not have any location-based targets. Therefore, a baseline is not applicable. Intermediate reduction targets are set on scope 1 and scope 2 (market-based) combined.
3
Represents the total scope 1 and 2 financed emissions of NN’s proprietary assets (excluding Government bonds & lending).
4
Intermediate targets are based on carbon intensity method. Refer to the financed emissions overviews for more information.
5
Intermediate targets are partly based on carbon intensity method. Refer to the insurance-associated emissions table for more information.
6
The total GHG emissions calculcated in this overview represents the summation of the GHG categories in this table. This deviates from the ‘Total GHG emissions (tCO
2
e) aggregated by scope 1, 2 and material scope 3 categories’.
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NN Group N.V. Annual Report 2024 | 404
GHG emissions continued
Based on the outcome of our Double Materiality
Assessment (DMA), we have identified that not all
GHG emissions are material as we do not have a
material impact for our own operations for
example. Therefore this information is included in
this appendix of the Annual Report for the purpose
of comparability and insight into the actual impact.
The 2023 comparatives are presented on a
consistent basis with the 2024 disclosures. As a
result, the 2023 comparatives differ in some
respects from similar amounts disclosed in the
2023 Annual Report. These differences relate
mainly to GHG emissions and are largely a result of
more information being available on 2023
emissions compared to the moment of finalising
the 2023 Annual Report. The 2023 comparatives
were also updated for certain methodology
amendments. Reference is made to the
Sustainability Statement for more information.
Calculation methodology
In this appendix, we disclose the GHG emissions
of our own operations (scope 1 and 2) and
applicable scope 3 categories. Scope 3 includes
indirect emissions occurring in NN Group’s value
chain. We use the scope 3 categories that are
provided by the GHG Protocol Corporate Value
Chain (Scope 3) Accounting and Reporting
Standard. The relevance of these categories for NN
Group is set out in the table below.
GHG Protocol Corporate Value Chain (Scope 3)
categories Relevance
1. Purchased goods and services Applicable to NN Group, but the category is not material
2. Capital goods Not applicable as NN Group does not significantly engage
in activities linked to this category
3. Fuel and energy-related activities Applicable to NN Group, but the category is not material
4. Upstream transportation and distribution Not applicable as NN Group does not significantly engage
in activities linked to this category
5. Waste generated in operations Applicable to NN Group, but the category is not material
6. Business travel (ground) Applicable to NN Group, but the category is not material
6. Business travel (air) Applicable to NN Group and material
7. Employee commuting Applicable to NN Group, but the category is not material
8. Upstream leased assets Not applicable as NN Group does not engage in activities
linked to these categories
9. Downstream transportation and distribution Not applicable as NN Group does not engage in activities
linked to these categories
10. Processing of sold products Not applicable as NN Group does not engage in activities
linked to these categories
11. Use of sold products Not applicable as NN Group does not engage in activities
linked to these categories
12. End-of-life treatment of sold products Not applicable as NN Group does not engage in activities
linked to these categories
13. Downstream leased assets Not applicable as NN Group does not engage in activities
linked to these categories
14. Franchises Not applicable as NN Group does not engage in activities
linked to these categories
15. Investments Applicable to NN Group and material. This category
includes category 15 financed emissions, and category 15
insurance-associated emissions
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NN Group N.V. Annual Report 2024 | 405
GHG emissions continued
GHG emissions identified as material based on the
outcomes of our DMA are disclosed in our
Sustainability Statement. A description of the GHG
calculation methodology of our material own
operations’ emissions, financed emissions and
insurance-associated emissions are included in
the Sustainability Statement (see p. 147). For the
scope 3 categories that are not covered in the
Sustainability Statement and reported in this
appendix only, methodology per category is shown
in the table below.
Protocol Corporate Value Chain
(Scope 3) categories Calculation method Activity data Emissions factors applied Source
1. Purchased goods and services Spend-based Euro spend per procurement
category
Emissions per euro spend per
procurement category
US EEIO database
3. Fuel and energy-related
activities
Average data In line with scope 1 and scope 2 Downstream emissions per unit of
consumed energy
Ecoinvent and
CO
2
emissiefactoren
5. Waste generated in operations Supplier-specific for business units
in the Netherlands and average
data for the other business units
Solid waste and water consumption
from NN Group buildings
Emissions per unit of solid office
waste, split by recycled and
non-recycled, and wastewater
treatment
Ecoinvent and CE Delft
6. Business travel (ground) Distance-based and partly
spend-based; spend-based only for
public transport in case data for
distance travelled is unavailable
Distance travelled by transport
type
Note: also includes emissions
related to lease cars provided by
NN Group to its employees via
secondary employment conditions
Average emissions per kilometre
travelled, per transport type and
emissions per euro spend on public
transport
CO
2
emissiefactoren
7. Employee commuting Distance-based Distance travelled by transport
type.
Note: also includes emissions
related to lease cars provided by
NN Group to its employees via
secondary employment conditions
Average emissions per kilometre
travelled per transport type
CO
2
emissiefactoren
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Energy consumption and sustainability indices and ratings
Energy consumption in Mega-Watt-hours (MWh)
2024 2023 Variance
Consumption of energy from fossil sources 20,648 22,137 −1,489
Consumption of energy from nuclear sources 1,478 1,875 −397
Fuel consumption from renewable sources
Consumption of self-generated non-fuel renewable energy 190 133 57
Consumption of purchased or acquired electricity and district heating
from renewable sources 14,976 14,618 358
Consumption of energy from renewable sources 15,166 14,751 415
Total energy consumption 37,292 38,763 −1,471
Based on the outcome of our DMA, we have identified the energy consumption from fossil sources as not
material as we do not have a material impact with our own operations. Therefore this information is included
in this appendix of the Annual Report for the purpose of transparency and insight in the actual impact.
Calculation methodology
We provide a comprehensive overview of the total energy consumption associated with NN Group’s
operations. ‘Own operations’ specifically refers to the activities and processes of entities included in the NN
Group’s consolidation. The energy consumption primarily stems from the use of buildings operated by NN
Group. In this context, ‘purchased or acquired energy’ denotes energy that has been sourced from third
parties.
Sustainability indices and ratings
2024 2023 2022
Indices
FTSE4Good
Included Included Included
Bloomberg Gender-Equality Index
1
Included Included
Ratings and benchmarks
Sustainalytics
2
14.3/100
(low risk)
18.5/100
(low risk)
14.7/100
(low risk)
MSCI AA AA AA
ISS ESG research C C C+
CDP
1
B B
World Benchmarking Alliance financial system benchmark
3
35th position 8th position
VBDO (Ranking of Responsible Investments by Insurers in the
Netherlands)
4
4th position
Financial Times-Statista 2025 Diversity Leaders 9th position 42nd position 772nd position
Equileap
1st position Not included Not included
1
No 2024 scoring available.
2
Sustainalytics provides ESG Risk Ratings scoring companies on their ESG risks from negligible (0-10), low (10-20), medium (20-30),
high (30-40) to severe risk (40-100).
3
The World Benchmarking Alliance financial system benchmark assessment takes place once every two years.
4
VBDO 4th out of 20 for Ranking of Responsible Investments by Insurers in the Netherlands and 1st out of 116 on Tax Transparency
Benchmark.
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NN Group N.V. Annual Report 2024 | 407
Annual total compensation
Compensation provided over the course of a year.
Average FTE
Average FTE in the business unit for which sick
leave is registered. Definition of total workdays:
either 365 or the number of actual working days of
the reported year for a full-time FTE.
Average years of service
Average of all service years of all employees.
Service years is calculated by looking at the years
between 31/12/YYYY and the value of Continuous
Service Years.
Base year
Historical date (such as year) against which a
measurement is tracked over time.
Baseline
Starting point used for comparisons. In the
context of energy and emissions reporting, the
baseline is the projected energy consumption or
emissions in the absence of any reduction activity.
Business partner
Entity with which the organisation has some form
of direct and formal engagement for the purpose
of meeting its business objectives.
Business relationships
Relationships that the organisation has with
business partners, with entities in its value chain
including those beyond the first tier (parties we
have a direct contract with), and with any other
entities directly linked to its operations, products,
or services.
Business travel by air
Greenhouse gas emissions (GHG) based on the
total distance and cabin class of business travel by
air by NN employees.
CDP
A global disclosure system for companies, cities,
states and regions to manage their environmental
impacts,and for investors and purchasers to
access environmental information for use in
financial decisions.
Collective bargaining
All negotiations that take place between one or
more employers or employers’ organisations and
one or more workers’ organisations (e.g. trade
unions), for determining working conditions and
terms of employment or for regulating relations
between employers and workers.
Contributions to society
The Business for Social Impact (B4SI) framework
offers a consistent and credible approach to
reporting and impact measurement. This helps us
track our contributions to society and is fully
integrated into our internal and external reporting.
We aim to contribute to communities by
supporting financial, physical and/or mental
well-being of one million people by 2025
(accumulative 2022-2025) and to contribute 1% of
our operating result before tax to our communities
by 2023.
Customer engagement measured through Net
Promoter Score (NPS)
The internationally recognised Net Promoter Score
(NPS) system, one of the key metrics in the Global
brand Health Monitor (GBHM), measures how likely
it is that our customers recommend our products
and services to colleagues, friends or family. We
use relational NPS (NPS-r) to measure the strength
of the relationship with customers and gain
understanding of customer satisfaction over time.
Customer privacy
Right of the customer to privacy and personal
refuge.
Distance-based method
Involves determining the distance and transport
mode of trips and applies the appropriate emission
factor for the transport mode used in line with the
applicable GHG Protocol Standards.
Due diligence
Process to identify, prevent, mitigate, and account
for how the organisation addresses its actual and
potential negative impacts.
EIOPA
European Insurance and Occupational Pensions
Authority. EIOPA focuses on providing a sound
regulatory framework for and consistent
supervision of insurance and occupational
pensions sectors in Europe, and is an independent
advisory body to the European Commission, the
European Parliament and the Council of the
European Union.
Employee engagement
We measure employee engagement through our
biannual global employee engagement survey to
determine progress against one of our key KPIs.
This survey contains a broad selection of
questions covering how employees feel about the
company culture, how they are managed and the
direction of the company as a whole. The scoring
of these questions results in an employee
engagement score, that is compared to the finance
industry benchmark from Peakon.
Employee engagement survey
A questionnaire measuring how a company’s
brand and values are experienced by its
employees, how its leaders live up to the
standards the company sets, and how the
company fulfils its employee value proposition as
an organisation.
Employee turnover
Employees (individuals who are in an employment
relationship with the organisation according to
national law or practice) who leave the
organisation voluntarily or due to dismissal,
retirement, or death in service. Total of HC of all
terminated employees/Avg employee headcount.
A termination is defined as a termination when the
following Business Processes are successfully
completed: ‘End Contract Event’ and ‘Terminate
Employee Event’.
Glossary
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NN Group N.V. Annual Report 2024 | 408
Glossary continued
Employees covered by Collective Labour
Agreement (CLA)
Internal employees who are covered by a
collective bargaining agreement can be read as
covered by a Collective Labour Agreement
contract.
Employees represented by an employee
representative body
Internal employees who are covered by a works
council, unions or other organisations
representing employees.
Employees with completed standard
performance process
All employees that have performed all the steps in
the performance process concerning the goal
setting, first snapshot, team review, second
snapshot and year-end review.
Energy consumption
We provide a comprehensive overview of the total
energy consumption associated with NN Group’s
operations. ‘Own operations’ specifically refers to
the activities and processes of entities included in
the NN Group’s consolidation. The energy
consumption primarily stems from the use of
buildings operated by NN Group. In this context,
‘purchased or acquired energy’ denotes energy
that has been sourced from third parties.
Energy reduction
Amount of energy no longer used or needed to
carry out the same processes or tasks.
Engagement
In the context of managing climate risks,
engagement means entering into dialogue with
investee companies on the risks of climate change,
and the need to transition to a low-carbon
economy.
Environmental laws and regulations
Laws and regulations related to all types of
environmental issues applicable to the
organisation.
Environmental, social and governance (ESG)
factors
Environmental factors include (non-exhaustive):
climate change, other forms of environmental
degradation (e.g. air pollution, water pollution,
scarcity of fresh water, land contamination,
biodiversity loss and deforestation) and animal
welfare, in addition to corrective policy actions
aimed at addressing such factors. Climate change
is further divided into:
a) transitional effects resulting from the transition
to a green economy, and
b) physical effects resulting from changes in
weather patterns, temperature, hydrological
conditions or natural ecosystems (both acute or
longer-term shifts).
∙ Social factors include (non-exhaustive): rights,
well-being and interests of people and
communities, including human rights, (in)
equality, health, inclusiveness, diversity,
employee rights and labour relations,
workplace health and safety.
∙ Governance factors include (non-exhaustive):
pursuing or applying proper governance
practices, amongst others including executive
leadership, executive pay, audits, internal
controls, responsible tax practices, board
independence, shareholder rights, anti-
corruption and anti-bribery, and also the way
in which companies or entities include
environmental and social factors in their
policies and procedures.
Financial economic crime (FEC)
Involvement in money laundering, the funding of
terrorism or other criminal activities that could
harm stakeholder confidence in a financial
services provider such as NN.
Financial sector oath or promise
An ethical statement introduced in early 2013 for
employees in the Dutch financial sector, along with
the introduction of a social charter and update of
the Banking Code. It applies to employees of
banks and other financial enterprises, including
insurance companies, investment firms and
financial service providers.
By taking the oath, employees declare that they
are bound by a code of conduct to the ethical and
careful practice of their profession.
Formal meetings held with employee
representative bodies
Number of formal meetings is seen as how often
the Executive Board has consulted with the works
council, union or other organisations representing
employees.
Formal meetings held with employee
representative bodies
Count of the number of meetings held with
employee representative bodies.
Fuel-based method
Involves determining the amount of fuel and
electricity consumed during transportation and
applies the appropriate emission factor for that
fuel or electricity in line with the relevant GHG
Protocol Standards.
Full-time employee
Employee whose working hours per week, month,
or year are defined according to national law or
practice regarding working time. FTE is not
maximised at 100% (e.g. an employee with 36
default hours and 40 scheduled weekly hours is
counted as 111.11% FTE).
General Data Protection Regulation (GDPR)
Regulation by which the European Parliament,
Council of the European Union and European
Commission aim to unify data protection for all
individuals within the European Union. The GDPR
came into effect on 25 May 2018.
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NN Group N.V. Annual Report 2024 | 409
Glossary continued
GHG emissions of our own operations
Sum of our GHG emissions in scope 1, 2 and 3 in
tonnes of CO
2
equivalent (CO
2
e). The main sources
concern:
∙ International Energy Agency or IEA. It uses
emission factors from electricity of national
grids.
∙ Association of Issuing Bodies or AIB. It provides
emission factors from electricity of national
grids.
∙ CO
2
emissiefactoren.nl which uses international
or European values. It provides a variety of
emission factors.
∙ Department for Energy Security & Net Zero or
DESNZ. It provides a variety of emission factors.
GRESB
GRESB is a mission-driven and industry-led
organisation that provides actionable and
transparent ESG data for commercial real estate
and infrastructure to financial markets. GRESB
collects, validates, scores and benchmarks ESG
data to provide business intelligence, engagement
tools and regulatory reporting solutions for
investors, asset managers and the wider industry.
Global Reporting Initiative (GRI)
An international independent standards
organisation that helps businesses, governments
and other organisations understand and
communicate their impact on issues such as
climate change, human rights and corruption.
Grievances on labour practices
NN’s general policy is that employees who feel
they have been harmed in their work situation as a
result of an individual decision that the
management has either made or failed to make,
and employees who have been confronted with
behaviour they perceive to be inappropriate,
should attempt to resolve their situation by
discussing their grievances. If discussions fail to
render an acceptable solution, the employee has
the option of submitting a complaint or dispute to
the Complaints & Disputes Committee.
Group Sustainability Council (GSC)
The Group Sustainability Council is assisting the
Management Board in relation to sustainability
matters, by:
∙ Facilitating strategy implementation and
monitoring execution and performance,
including steering regulatory implementation.
∙ Discussing and consulting on material changes
and developments.
∙ Incorporating the sustainability and social
impact responsibilitiesof the former Purpose
Council and the responsibilities of the Taskforce
Sustainability in Business Steering Committee,
both of which ceased to exist as of the effective
date of the Group Sustainability Council.
∙ Chaired by Head of Sustainability and Social
Impact, includes heads of staff and BU
managers; CPCSO standing invitation.
Headcount
The total number/headcount of all employees
categorised as ‘fixed term’ and ‘permanent’.
Human capital return on investment
Calculated as (Operating Results Ongoing
Business + Employee Expenses)/Employee
Expenses. Employee Expenses = Staff Expenses
– External Staff Costs.
Locked-in emissions
Estimates of future GHG emissions that are likely
to be caused by NN Groups’s key assets or
products sold within their operating lifetime.
Male/female ratio
Total headcount of all employees where gender is
male or female/Total headcount of all employees.
Employee is Worker Sub Type ‘fixed term’ and
‘permanent’.
Net-zero
Reducing emissions in the real economy as close
to zero as possible and remaining emissions are
balanced using carbon removal technologies. The
ambition is based on the Paris Climate Agreement
to limit temperature rise to 1.5°C.
New hires
Total headcount of all hired employees. A hire is
defined as a hire when the following Business
Processes are successfully completed: ‘Contract
Contingent Worker Event’ or ‘Hire Employee
Event’.
NN Group Compliance Function Charter
A policy set in place by NN to help businesses
manage their compliance risks effectively and to
set out the responsibilities on compliance risk
management for the business and the Compliance
function.
Non-governmental organisation (NGO)
An organisation that is neither part of a
government nor a conventional for-profit business.
Usually set up by citizens, NGOs may be funded by
governments, foundations, businesses or private
individuals.
OECD
The Organisation for Economic Co-operation and
Development, an international organisation,
established after World War II, with the aim of
shaping policies that foster prosperity, equality,
opportunity and well- being for all.
Open positions filled by internal candidates
Percentage of hires from the internal NN
population for the stated period. Included in the
percentage are the categories ‘internal mobility’,
‘conversion from intern’ and ‘redundant’.
Operating capital generation (OCG)
The movement in the solvency surplus (Own Funds
before eligibility over SCR at 100%) in the period
due to operating items, including the impact of
new business, expected investment returns in
excess of the unwind of liabilities, release of the
risk margin, operating variances, Non-life
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Glossary continued
underwriting result, contribution of non-Solvency
II entities and holding expenses and debt costs
and the change in the SCR. It excludes economic
variances, economic assumption changes and
non-operating expenses.
Other incidents and concerns
Concerns refer to a report raised by an employee
about an actual or suspected irregularity or
misconduct within NN that leads or could lead to a
violation of: NN’s Values; any NN Policy; and/or any
national law, regulation or code.
Participation in engagement survey
Percentage of employees who filled in the
engagement survey.
Part-time employees
Sum of all employees who have an FTE value of
<100%.
People supported
Following the B4SI Guidance Manual on defining
output, this is the number of beneficiaries who
receive a product or service as a result of our
contribution. We divide that into two categories,
which are our strategic themes: ‘Financial well-
being’ and ‘Physical and mental well-being’.
Allocation to one of these categories is based on
how resources we contributed were allocated
within the theme. For example, in 2023, our cash
contribution to Brand New Job is part of the
‘financial well-being’ strategic theme. The number
reported is a cumulative figure over the years
2022-2023-2024-2025.
Product approval and review process (PARP)
The assessment of a product in relation to its
customer suitability, financial and non-financial
risks, and profitability. NN conducts a PARP when
it introduces a new product, changes the
characteristics of an existing product or reviews a
product. This is to ensure the product is
acceptable to our company, our customers and
society in general.
Ratio of CEO compensation to the average
employee compensation
CEO compensation/Average employee
compensation. The ratio of CEO compensation to
the average employee compensation refers to the
pay ratio calculation method as prescribed by the
Dutch Monitoring Commission Corporate
Governance. The pay ratio should be understood
to mean: the ratio between the total annual
remuneration of the CEO and the average annual
remuneration of the employees in which the total
annual remuneration of the CEO includes all
remuneration components (such as base salary,
variable compensation in both cash and shares,
social premiums, pension, expense allowances,
etc.). The average annual remuneration of
employees is the total wage costs divided by the
average number of FTEs during the year. The value
of the share-based remuneration is determined at
the moment of grant.
Recalculation Policy for Baseline GHG emissions
targets
In order to accurately report on the progress
towards our decarbonisation targets we will on an
annual basis assess whether there are significant
changes that require a recalculation of our targets
and the related baselines. A materiality threshold
is set at 10%, but we may choose to recalculate
our base year for changes below this threshold
such as in case of structural changes (i.e. mergers,
acquisitions and/or divestitures).
Regardless of such events NN will review and
update its targets at least every five years.
Relevant events triggering an update of baselines
and associated targets before this five-year time
horizon has passed are amongst others (1)
Structural changes to our organisation such as
mergers, acquisitions and divestitures, (2)
Methodological changes and/or significant
improvements in data accuracy, (3) External
factors affected a single base year value making it
not representative, (4) other changes such as the
discovery of material (cumulative) reporting errors
or a material change in the scope of targets.
Report of the Management Board
The NN Group N.V. 2024 Report of the
Management Board (Bestuursverslag), as referred
to in section 2:391 of the Dutch Civil Code. It
includes the following chapters of the Annual
Report: About NN, Our strategy and business, Our
performance, Managing our risks, Governance
(excluding A conversation with our Supervisory
Board, and, Report of the Supervisory Board),
Sustainability Statement, and Our response to the
TCFD disclosures and GHG emissions as included
in the Appendix.
Responsible Investment (RI) Framework Policy
Sets out NN’s vision, approach and key principles
on responsible investment. NN defines RI as the
systematic integration of relevant ESG factors into
investment decision-making and active ownership
practices.
Road travel
GHG from transportation in vehicles leased and
owned by NN. The calculation is based on the fuel
(including electricity) consumption and otherwise
the distance travelled in kilometres.
Scope 1 GHG emissions
Direct GHG from sources that are owned or
controlled by NN.
Scope 2 GHG emissions
Indirect GHG that result from the generation of
purchased or acquired electricity, heating, cooling,
and steam consumed in the office buildings owned
(and held for own use) or leased by NN.
Scope 3 GHG emissions
Indirect GHG other than those reported in scope 1
and 2 that occur in NN’s upstream and
downstream value chain.
SMEs
Small- and medium-sized enterprises.
Spend on training and development
NN Group provides insights to enable an
understanding of the training and skills
development-related activities that have been
offered to employees. The total amount spent on
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NN Group N.V. Annual Report 2024 | 411
Glossary continued
training and development is expressed in euros
and divided by the total number of employees (incl.
interns) in headcount at the end of the reporting
period
Sustainability matters
Sustainability matters are opportunities, risks and
positive and adverse impacts related to
environmental, social and governance factors,
including climate change, employee and human
rights, anti-corruption and anti-bribery.
Sustainability matters are identified based on the
double materiality concept: our impact on the
environment and society (inside-out perspective),
but also how these matters impact our company
(outside-in perspective).
Sustainability impacts
Sustainability impacts are positive/adverse
impacts on environmental, social and governance
factors that are created/caused by or (in)directly
linked to NN Group’s activities (NN’s strategy,
investment decisions, underwriting and
operations).
Sustainability opportunities
Sustainability opportunities are opportunities
related to environmental, social and governance
factors that can create a positive contribution to
NN Group’s (non-)financial and/or strategic
targets, reputation and/or balance sheet, as well
as a positive impact to environment or society.
Sustainability risk
NN considers sustainability risks as risks related
to ESG factors that can cause material negative
impact to NN’s long-term performance, reputation,
value, balance sheet or operations.
Sustainable Development Goals (SDGs)
Also known as the Global Goals, these are 17
global goals set in 2015 by the UN General
Assembly to be achieved by 2030. They form a
universal call-to-action to end poverty, protect the
planet, and ensure all people can enjoy peace and
prosperity.
Sustainable recovery
Sustainable recovery is a way of ensuring recovery
of damaged goods or property related matters by
not replacing it by fully new equipment or virgin
materials but repairing it or using refurbished
equipment or circular materials.
Task Force on Climate-related Financial
Disclosures (TCFD)
An industry-led initiative of the Financial Stability
Board to develop recommendations on climate-
related financial disclosures. The Task Force
published its final recommendations in June 2017.
The TCFD has fulfilled its remit and disbanded. The
IFRS Foundation has taken over the monitoring of
the progress of companies’ climate-related
disclosures.
Temporary employees
Temporary employees are employees with a
contract for a limited period (i.e. fixed term
contract) that ends when the specific time period
expires, or when the specific task or event that has
an attached time estimate is completed (e.g. the
end of a project or return of replaced employees).
Total spending on training and development
The total amount spent on facilitating training and
development for employees (internal and
external).
Time contributions: volunteering hours
We account for a monetary value for our
colleagues’ volunteer hours based on time
contributions.
B4SI defines this as ‘… the cost to the company of
the paid working hours contributed by employees
to a community organisation or activity. The term
“volunteering” is often used to describe time
contributions, but it can go beyond this to include
any active engagement in community activity
during paid working time. Examples include:
employee volunteering, active participation in
fundraising activities, longer-term secondments to
community organisations, supervision of work
experience placements.’ Reference: Chapter 1.2,
B4SI Guidance Manual, 2021 (p. 11). As of 2022,
we calculate time contribution costs based on the
average hourly rate of the previous year across NN
and round down (2022: EUR 50 per hour) to be
more accurate in the actual costs. The hourly rate
is calculated based on the total employee
remuneration across NN as disclosed in our Annual
Report of the previous year, divided by the total
number of hours per FTE (full- time equivalents).
Currently, the rate is based on 52 weeks/36 hours
per week, rounded down.
UN Global Compact
A UN initiative to encourage businesses worldwide
to adopt sustainable and socially responsible
policies, and report on their implementation. It is a
principle-based framework for business containing
ten principles in the areas of human rights, labour,
environment and anti-corruption.
Voting
Voting is one of the most powerful tools of active
ownership and we vote at shareholder meetings
on behalf of our own assets. Our Voting Policy for
Proprietary Assets guides the voting
considerations on behalf of NN Group’s proprietary
equity portfolio, and we publish our voting records
on our website.
Weighted average carbon intensity
We calculate this metric to understand exposure
to carbon intensive companies. Portfolio’s
exposure to carbon intensive companies,
expressed as tCO
2
e/€M company revenue. This
normalises each company’s emissions by its sales.
The weighted average is then calculated by
portfolio weight.
Whistleblower concerns filed
Number of whistleblower concerns filed and
assessed as being in scope of the Whistleblower
policy/standard.
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NN Group N.V. Annual Report 2024 | 412
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Women in senior management positions
All the women in the Management Board, in
managerial positions reporting directly to the
Management Board, and in managerial positions
reporting directly to the CEOs of NN Non-life, NN
Bank or the CEOs of the NN International business
units.
Workforce
The total number of employees with an employee
contract.
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NN Group N.V. Annual Report 2024 | 413
Publication details
Prepared by
NN Group Corporate Relations
Design
CF Report
Contact us
For further information on NN Group, please visit our corporate website or contact us via external.
communications@nn-group.com
For further information on NN Group’s sustainability page on our website or contact us via
sustainability@nn-group.com
Important legal information
The 2024 Annual Report provides an integrated review of the performance of NN Group. More information –
for example the Solvency and Financial Condition Report (SFCR), Total Tax Contribution Report and the GRI
Index Table – is available on the corporate website in the Investors/financial reports section.
Small differences in the tables are possible due to rounding. Certain of the statements in this 2024 Annual
Report are not historical facts, including, without limitation, certain statements made of future expectations
and other forward-looking statements that are based on management’s current views and assumptions and
involve known and unknown risks and uncertainties that could cause actual results, performance or events
to differ materially from those expressed or implied in such statements. Actual results, performance or
events may differ materially from those in such statements due to, without limitation: (1) changes in general
economic conditions, in particular economic conditions in NN Group’s core markets, (2) changes in
performance of financial markets, including developing markets, (3) consequences of a potential (partial)
break-up of the euro or European Union countries leaving the European Union, (4) changes in the availability
of, and costs associated with, sources of liquidity as well as conditions in the credit markets generally, (5)
the frequency and severity of insured loss events, (6) changes affecting mortality and morbidity levels and
trends, (7) changes affecting persistency levels, (8) changes affecting interest rate levels, (9) changes
affecting currency exchange rates, (10) changes in investor, customer and policyholder behaviour, (11)
changes in general competitive factors, (12) changes in laws and regulations and the interpretation and
application thereof, (13) changes in the policies and actions of governments and/or regulatory authorities,
(14) conclusions with regard to accounting assumptions and methodologies, (15) changes in ownership that
could affect the future availability to NN Group of net operating loss, net capital and built-in loss carry
forwards, (16) changes in credit and financial strength ratings, (17) NN Group’s ability to achieve projected
operational synergies, (18) catastrophes and terrorist-related events, (19) operational and IT risks, such as
system disruptions or failures, breaches of security, cyber-attacks, human error, changes in operational
practices or inadequate controls including in respect of third parties with which we do business, (20) risks
and challenges related to cybercrime including the effects of cyberattacks and changes in legislation and
regulation related to cybersecurity and data privacy, (21) business, operational, regulatory, reputation and
other risks and challenges in connection with Sustainability Matters (please see the link to our sustainability
matters definition www.nn-group.com/sustainability/policies-reports-and-memberships/policy-and-report-
library.htm), (22) the inability to retain key personnel, (23) adverse developments in legal and other
proceedings and (24) the other risks and uncertainties contained in recent public disclosures made by
NN Group.
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NN Group N.V. Annual Report 2024 | 414
Publication details
Any forward-looking statements made by or on behalf of NN Group in this 2024 Annual Report speak only as
of the date they are made, and NN Group assumes no obligation to publicly update or revise any forward-
looking statements, whether as a result of new information or for any other reason.
This publication contains information and data provided by third party data providers. NN Group, nor any of
its directors or employees, nor any third party data provider, can be held directly or indirectly liable or
responsible with respect to the information provided.
This document does not constitute an offer to sell, or a solicitation of an offer to buy, any securities.
© 2025 NN Group N.V.
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
Our strategy and business Our performance Managing our risks Annual accounts Other information AppendixSustainability StatementGovernanceAbout NN
NN Group N.V.
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