�ֲ���ý��Ƶ

Management groups or sub-committees also have responsibility for identifying and assessing climate- related risks and reporting potential exposures to their respective standing committees. The Sustainability function within the CSR program is responsible for supporting and coordinating firm-wide efforts across the existing and emerging climate-related issues from these groups. The responsibilities of these groups and sub-committees are described below.

• Enterprise Risk Committee (ERC)
  • Responsible for overseeing the enterprise-wide risk, capital, and liquidity management frameworks and practices, including climate-related risks
• �ֲ���ý��Ƶ Compliance Committee (PLCC)
  • Responsible for ensuring effective design and execution of the Compliance and Ethics Program including climate-related compliance requirements
  • Provides insight into the execution and consistency of risk analysis and mitigation strategies across the enterprise that are outside the purview of the ERC
• Management Investment Committee (MIC)
  • Responsible for oversight of investment risk related to climate risk
  • Reviews and approves �ֲ���ý��Ƶ’s responsible investment policy and program
• Corporate Social Responsibility team
  • Updates the Governance and Nominating Committee of the Board at least once per year on relevant CSR developments across customers, people, communities and the environment

�ֲ���ý��Ƶ has engaged various stakeholders and business functions throughout the organization, including Board and management committees (see the ‘Governance’ section response), Enterprise Risk Management (ERM) and Business Continuity (see the ‘Risk Management’ section response), Investment, Actuarial, and Corporate Affairs. Below is additional information on the work done within each business area regarding climate-related risks and opportunities.

Investment

Climate-related risks and opportunities in �ֲ���ý��Ƶ’s investment portfolio have been an area of focus for �ֲ���ý��Ƶ. This focus led to initiatives such as the creation of �ֲ���ý��Ƶ’s Responsible Investment Policy, which was initially published and adapted by �ֲ���ý��Ƶ in 2019 and updated in November 2025. These principles, which continue to be refined, outline �ֲ���ý��Ƶ’s desire to achieve sustainable, long-term returns in a balanced and responsible manner by acknowledging the evolving materiality of environmental, social, and governance (ESG) factors.

�ֲ���ý��Ƶ has also developed a roadmap which outlines development plans to enhance the company’s ESG investment strategy. This plan aims to allow �ֲ���ý��Ƶ to deliver consistent risk-adjusted returns to policyholders in a responsible manner by better understanding ESG factors as part of the investment making process, and it will allow for continued monitoring and mitigation of climate-related transition risks within �ֲ���ý��Ƶ’s investment portfolio.

In 2025, �ֲ���ý��Ƶ used its climate scenario analysis to support regulatory reporting requests from Canada and Australia. As the underlying climate scenarios do not materially change year over year, �ֲ���ý��Ƶ applied the analysis to 2025 holdings for those entities to assess climate-related risk exposures. Consistent with the company’s broader assessment of climate-related risks, potential exposure within the Canadian and Australian portfolios was deemed manageable.

Lastly, �ֲ���ý��Ƶ has taken steps to take advantage of climate-related opportunities through the creation of the Sustainable Financing Framework. The framework was created to finance green and social projects that align with our sustainability priorities. �ֲ���ý��Ƶ will not provide funding through its Sustainable Financing Framework and sustainable note offerings if the borrower is associated with the following climate-related risks: activities related to the exploration, production, or transportation of fossil fuels (e.g., coal, oil, and gas); consumption of fossil fuels for power generation; large hydroelectric power generation (e.g., plants with a capacity of greater than 20 megawatts or dams with a height greater than ten meters); and nuclear energy. Through the transition to a low carbon economy, �ֲ���ý��Ƶ is seeing more opportunities to invest in projects that use renewable energy such as solar and wind power, liquefied natural gas, and battery technology. This financing framework, and subsequent note issuances, highlight the investment �ֲ���ý��Ƶ is making to support the transition to a low carbon economy.

Actuarial

Assessing and understanding climate-related risk is important for proper underwriting and accurate identification of new risks that may impact policyholders or operations. Volatility in frequency and severity of weather events are expected to make certain geographic locations more prone to climate risk. To monitor this risk, geographical concentration risk assessments of �ֲ���ý��Ƶ’s insurance portfolio are done regularly to understand what areas are policy-dense and how these areas may be impacted by future changes in weather events.

Research has also been done into the ways climate-related risks may impact mortality in the future. To quantify these impacts, excess mortality stress testing is performed on the underwriting portfolio to understand how stressed mortality may impact the business. Results of this stress testing have been immaterial thus far, but �ֲ���ý��Ƶ plans to continue to test and integrate climate risk assumptions and factors into pricing, projection, and valuation models as appropriate.

Corporate Affairs

�ֲ���ý��Ƶ’s Corporate Social Responsibility team sits within the Corporate Affairs team and is responsible for climate-related disclosures and company-wide environmental initiatives aimed at tracking and managing emissions and promoting sustainability programs. The CSR team works with the business units to determine priorities, engage the appropriate stakeholders and address issues related to climate, while supporting integration of processes that support the business.

Scope 1 and 2 greenhouse gas emissions are calculated annually using 2019 as a baseline. Current company and employee efforts to limit �ֲ���ý��Ƶ’s environmental footprint include:

• Providing the option for policyholders to receive electronic account statements and e-delivery of required mailings
• Increased use of digital files in lieu of paper files
• Office buildings that incorporate green concepts and technology, including smart thermostats, efficient reflective roofs, high energy efficiency lighting, systems, as well as sustainable materials
• Consideration of green leasing options in real estate procurement
• Proactive electronic waste, bottle & can recycling, and trash recycling programs
• Landscaping with drought-tolerant plants to reduce water consumption
• Completed work with Southern California Edison Electric company to reduce energy usage and still meet business needs
• Changes to kitchen equipment and air conditioning optimization to reduce gas consumption
• Energy-efficient LED lighting in office buildings’ common areas
• Data center optimization to reduce energy usage and increase efficiency
• Purchase of hardware certified to be energy efficient including Energy Star

�ֲ���ý��Ƶ’s risk management organization is tasked with determining investment portfolio resilience, testing credit risk of the portfolio. Climate risk scenario analysis has been performed using quantitative 1.5C- and 4C-degree scenarios to determine climate risk within the investment portfolio and inform future long-term climate risk strategy. Both physical and transition risk assessments were performed across the most material drivers of loss. Various impact pathways were identified to assess how changing risk profiles of corporate bonds and commercial loans will affect the portfolio. Physical impacts were assessed from increases in frequency and intensity of physical hazards such as hurricanes, coastal inundation, flooding, etc. Transition impacts were assessed from impacts of the low carbon transition; carbon tax, labor costs, retrofit costs, etc. Effects driven from climate scenarios can result in losses due to default, which are used to calculate projected losses in value. We intend to repeat climate scenario analysis at a regular cadence, adjusting the frequency as our risk profile dictates.

BCM and the BIA process help inform risks that are considered by Enterprise Risk Management (ERM). ERM is responsible for �ֲ���ý��Ƶ’s Risk Management Framework, which describes how risks across the organization are identified, assessed, and managed. Management committees are also used to assess risks on a group level. The Enterprise Risk Committee, Management Investment Committee and �ֲ���ý��Ƶ Compliance Committee are responsible for overseeing all risks present to the company including people, processes, and systems. The Emerging Risk Committee is a sub-committee of the Enterprise Risk Committee responsible for monitoring and assessing new risks and evaluating if they have a material impact on �ֲ���ý��Ƶ. The committee then assesses ownership, estimated impact, and likelihood. When risks are fully managed, they are removed from the emerging risk list. Climate risk is considered an emerging risk that is regularly monitored for material impact to �ֲ���ý��Ƶ.

Operational Risk Management

Climate change may result in increased frequency and more severe weather-related events such as hurricanes, tidal waves, sea level changes, wildfires, heatwaves, drought and tornados. With offices in California, Nebraska, Bermuda, UK, Canada, Australia, Singapore and other geographic areas, the company has exposure to business disruption and operational risk associated with these events. There are Business Continuity Plans (BCP) in place to ensure the availability, recoverability and integrity of critical business and technology-driven processes with minimal impact on normal operations. With hybrid work options already in place and the majority of the offices leased, physical and transition risks to our business operations are limited.

Underwriting Policy Portfolio Risk Management

Extreme weather events and heat stress could result in higher than anticipated mortality experience. Given a well-balanced portfolio of life, annuity, and investment products - with offsetting mortality exposures, the net financial effect for �ֲ���ý��Ƶ is expected to be manageable. Additionally, the risk management team handles excess mortality stress tests linked to climate-related risk. The analysis considers a wide range of scenarios and what impact pathways may occur. Drivers by region are also considered. For example, floods, wildfires, insect-born flus, heatwaves, cold fronts, and air quality impact different regions in different ways. Thus far, the mortality testing results have not been material but will continue to be monitored to identify potential risks. Geographic concentration analysis of the insurance portfolio is done to monitor the number of policyholders per region. There are not currently any parameters influenced by climate risk in pricing or valuation models, but evolving underwriting practices and modeling methodologies may lead to future assumption changes.

Investment Portfolio Risk Management

�ֲ���ý��Ƶ’s Risk team has made progress in identifying climate risk in the portfolio.�� To help prepare the investment portfolio for transition risks, �ֲ���ý��Ƶ created a roadmap that outlines a process to better measure and manage these risks. Climate risk scenario analysis has been used to assess physical and transition risks within the portfolio. For relevant asset classes we are incorporating climate risk mitigants into the underwriting process. For example, risk mitigants for real estate area flood zones and proper insurance placements.

�ֲ���ý��Ƶ is a signatory to the United Nations Principles for Responsible Investment (UN PRI), in alignment with our responsible investment practice and adherence to the UN PRI Principles, acting as a framework to assess and manage climate-related financial risks.

Regulatory Risk Management

�ֲ���ý��Ƶ monitors existing, proposed, and forthcoming regulatory requirements regarding climate change as part of ongoing due diligence. We monitor not only those regulations that will directly affect �ֲ���ý��Ƶ, but also those that will affect our peers and business partners as they may have a cascading effect that could influence our approach.��

Insurance

�ֲ���ý��Ƶ monitors geographic concentration risk of the underwriting portfolio, which aids in the analysis of how exposure to physical risks may impact the insurance portfolio. Catastrophe modeling is not used to assess climate-related risks at this time and is not incorporated into underwriting assumptions or factors given climate change events are deemed to be manageable for business operations.

��

Investment

To better plan for the transition to a low carbon economy, �ֲ���ý��Ƶ is incorporating investment criteria, metrics, and targets into portfolio management. �ֲ���ý��Ƶ’s Sustainable Financing Framework aims to finance green and social projects that align with �ֲ���ý��Ƶ’s sustainability priorities. The framework encourages issuers to structure and administer their issuances of green bonds, social bonds and sustainability bonds in alignment with the Green Bond Principles, the Social Bond Principles and the Sustainability Bond Guidelines, respectively. The Principles are intended to promote integrity in the Sustainable Bond market through recommendations relating to transparency, disclosure, and reporting. �ֲ���ý��Ƶ's Sustainable and Green Bond issuances target eligible green investments, with the remaining proceeds allocated to eligible social investments, and these metrics will be regularly tracked. Examples of eligible projects include green buildings, renewable energy, energy efficiency and clean transportation.

�ֲ���ý��Ƶ updates investors annually regarding the allocation of net proceeds from issued Sustainable Bonds, until such time bonds are fully allocated. Where feasible, the allocation reporting includes qualitative and quantitative key performance indicators including:

• Green Buildings
  • Green building certifications
  • Total number of buildings certified
  • Total square feet certified
  • Percentage of overall company square feet certified
• Renewable Energy
  • Renewable energy capacity sourced and developed (MW)
  • Renewable energy procured and produced from the capacity above (MWh)
  • Emissions (including metric tons of CO2e) avoided or reduced
  • Annual renewable energy procured and produced as a % of annual global electricity consumption
• Energy Efficiency
  • Energy savings (MWh)
  • Emissions (including metric tons of CO2e) avoided or reduced
  • Office energy consumption/square foot
  • Office energy consumption/employee
  • Data center Power Usage Effectiveness
• Clean Transportation
  • Commuter carbon emissions (including metric tons of CO2e) avoided or reduced

Emissions

Greenhouse Gas (GHG) emission disclosures inform investors of �ֲ���ý��Ƶ’s carbon footprint and track progress as society transitions to a low carbon economy. Scope 1 and Scope 2 emissions are calculated annually with a baseline of 2019, using emission quantification methodologies drawn from the Greenhouse Gas Protocol developed by the World Resources Institute and World Business Council for Sustainable Development (GHG Protocol). The emissions manual is reviewed and updated at least annually based on developments in data collection, calculation, and data quality review process in future years. Emissions are calculated in Metric Tons of Carbon Dioxide emissions, or MTCO2e.

2025 Scope 1 emissions are 817 MTCO2e, and 2025 Scope 2 emissions are 2324 MTCO2e. In total, Scope 1 and Scope 2 GHG emissions have been reduced 67% from our baseline in 2019. �ֲ���ý��Ƶ defines its GHG emissions inventory organizational boundaries using the Operational Control Approach. Offices over which �ֲ���ý��Ƶ has operational control are included in the GHG emissions inventory, including owned and leased properties globally except for the following: 1) Field offices and 2) Any office that is smaller than 5000 sq.ft. Progress will be monitored and reported year over year. Scope 3 emissions will be calculated in certain locations where regulation requires reporting.