European rules on sustainable finance disclosure.

Life insurance company SRLEV N.V. and Zwitserleven PPI (English: IORP) N.V. both use the Zwitserleven brand and trade name. In Europe, there are rules for disclosing information on sustainability in the financial services sector. The information on these European rules is different for SRLEV than for Zwitserleven PPI.

European rules on sustainable finance disclosure

In Europe, there are rules for disclosing information on sustainability in the financial services sector. These rules also apply to SRLEV. 

SRLEV N.V. uses the brand and trade name Zwitserleven as well as the brand and trade name Reaal. The name SRLEV is used in this text.

Action plan for financing sustainable growth

The European Commission (EC) presented the Europese Green Deal in December 2019. This is a series of policy initiatives aimed at making Europe climate neutral by 2050. The EC drafted an Action Plan for Financing Sustainable Growth.

Rules and regulations for the financial sector

This action plan consists of a large number of rules and regulations affecting most financial institutions. The European rules for sustainable finance disclosure are part of this.
On the basis of the new rules, we ensure that you can read information on the following topics:

  • how we handle sustainability risks in our business operations, and 
  • how we take into account adverse sustainability impact resulting from our investment policy. 

You can read about the sustainable characteristics of the product we offer.
View our sustainable investment policy


SRLEV is a life insurance company offering various types of life insurance and pension schemes. The Zwitserleven Feeling is inextricably linked to a beautiful world. We all want to have enough income to live on later, but in a world that is worth living in. SRLEV believes that the financial sector should take a leading role in achieving this.

We believe that the transition to a sustainable economy is necessary. Therefore, we assess sustainability risks and opportunities in our processes, for example, in the selection of asset managers. Professional investors are in charge of investing at SRLEV. The investments are made through investment mandates (guidelines) or funds. The integration of sustainability risks into the investment process depends on the policy in a specific mandate or fund and therefore on the asset manager. In addition, SRLEV has investments in its own investment portfolios.

Who are the asset managers

The primary asset manager is ACTIAM, an internationally recognised asset manager in the field of responsible, sustainable and impact investments. Approximately 90.1% of our investments are in funds and mandates from ACTIAM.

In addition to ACTIAM, we also work with other asset managers. For example, ASN, BlackRock and Threadneedle. All of these asset managers have their own way of investing and their own line of conduct for integrating sustainability risks and opportunities into their investment process. SRLEV has currently placed approximately 1.2% of the investments for its clients with these asset managers.

In addition to investments carried out by an asset management company, SRLEV also has approximately 8.7% of investments in Mortgages and Direct Real Estate.

You can read more about the integration of sustainability risks in the ACTIAM investment policy here. And we refer to information on how our other asset managers incorporate sustainability risks into their investment policies, including for our own investments.

Who do we invest for?

SRLEV is always the investor. But who gets the return? For the majority of premiums applies that the return is for SRLEV. In exchange, SRLEV gives certain guarantees, for example, that it will pay a certain sum in the event of death or to pay a certain monthly sum upon retirement. This is what we call investing for SRLEV.

Some of SRLEV’s insurance policies are unit-linked policies, pension schemes or special separate pension deposits for large corporate clients. The risks associated with the investments in these insurance policies and deposits are borne entirely by the customer. This is what we call investing for customers.

Sustainability risks in our investments

Asset management by ACTIAM (91%)

ACTIAM uses a sustainable investment framework which makes a distinction between responsible, sustainable and impact investing.

Sustainability risks and opportunities

ACTIAM's Sustainable Investment Policy sets out its Environmental, Social & Governance (ESG) principles. For all ACTIAM funds and mandates, it states whether the companies, governments and institutions invested in comply with the ESG principles. Do they show that they can manage the main sustainability risks and/or seize sustainability opportunities? Then they are classified as a responsible, sustainable or impact fund. Let us explain:

  • For responsible investment funds or mandates, minimum behavioural requirements and/or limited sustainability objectives are set.
  • In the sustainable funds or mandates, strict sustainability objectives are formulated in addition to the financial objective.
  • The impact funds or mandates have an additional objective on top of the financial objectives and strict sustainability objectives. Demonstrable positive social added value is created, according to the UN Sustainable Development Goals.

Even if ACTIAM does not itself invest, but instructs another asset manager to invest, it has a policy. ACTIAM selects these asset managers, investigates how they handle sustainability risks and, if necessary, enters into a dialogue with them to make adjustments or improvements.

ACTIAM believes that this approach to integrating sustainability risks into investment policy leads to better investment decisions. And, in the long run, to a better risk-return ratio
An overview of sustainability risks and the possible impact on returns can be found here  

ACTIAM’s sustainable and impact funds and mandates have sustainable investment objectives within the meaning of the European regulations. ACTIAM’s responsible funds and mandates qualify as funds and mandates which promote environmental and social characteristics according to the same rules. ACTIAM uses a number of instruments for both purposes. These instruments are:

  • Exclusion policy and use of ESG scores;
  • Engagement policy; and
  • Voting policy at shareholders' meetings.

Here you can read more about these instruments and how ACTIAM applies them. 

Other asset managers (1,2%)

The other asset managers where SRLEV places investments have different investment policies. When it comes to investments in SRLEV pension schemes, you can read here how ASN and BlackRock handle the sustainability risks.

The portfolio also includes investments from yet other fund managers. These are mainly positions that we hold in relation to (long-standing) client portfolios. How these asset managers handle sustainability and sustainability risks can be found on their own websites.

Investment in real estate and mortgages (7.8%)

The main investments held by SRLEV in this category are loans granted to individuals to finance their homes (mortgages) and buildings and land owned by SRLEV (so-called direct real estate). We receive interest, rent or lease on these. At present, sustainability risks are not taken into account when selecting these investments for the portfolios.

Reward policy regarding the integration of sustainability risks

SRLEV is part of Athora Netherlands N.V. and the group reward policy of Athora Netherlands also applies to SRLEV. Athora Netherlands included how this policy is consistent with the way in which sustainability risks are taken into account in its group reward policy. More information about the Athora Netherlands group reward policy here.

Explanation of principal adverse impact 

Besides sustainability risks, we also have to deal with the adverse impact of investment decisions on sustainability factors. You can read more about this in our statement of principal adverse impacts.