SUSTAINABILITY AND RESPONSIBLE BUSINESS CONDUCT
At EUCARE Insurance PCC Ltd., sustainability is part of how we govern our activities and manage risks. As a health-focused insurer, our primary impact on society is through the healthcare system. We address sustainability in a structured and proportionate way, aligned with our size, business model and regulatory context.
Our Approach
We address sustainability through two main areas:
- WIA (Work and Income according to Labour Capacity Act) covers targeted at income protection for employees.
- WGA (Return to Work for Partially Disabled Persons Scheme) cover for employers
Focus on Healthcare
Our most significant sustainability impact is indirect and linked to healthcare services. We address this through healthcare procurement, dialogue with providers and alignment with sector initiatives.
Responsible Investment
Our investment policy supports our overall governance approach. ESG factors are considered in risk assessment, oversight and selection of counterparties, while investment decisions remain focused on capital preservation, liquidity and alignment with insurance liabilities.
Further Information
More information is available in our Sustainability and Responsible Business Conduct disclosure.
Disclaimer
As the Company is not currently required to report under the Corporate Sustainability Reporting Directive (CSRD) or the European Sustainability Reporting Standards (ESRS), this information is provided on a voluntary basis to offer transparency regarding our approach. It does not constitute compliance with the CSRD or ESRS, nor does it represent a standalone sustainability framework.
Sustainability and Responsible Business Conduct Disclosure
Scope and context
EUCARE Insurance PCC Limited (“the Company”) is an insurance undertaking active in health insurance, income protection insurance and non-life insurance. Health insurance represents the largest share of premium income and constitutes the Company’s most significant interface with society and the healthcare system.
The Company considers sustainability and responsible business conduct as part of sound governance and prudent risk management. In line with its scale, business model and regulatory position, the Company has included the following disclosure on a voluntary basis, with the objective of providing relevant and proportionate transparency. This disclosure is intended to enhance Board-level transparency and does not introduce separate sustainability policies or targets.
The Company considers sustainability and responsible business conduct as part of sound governance and prudent risk management. In line with its scale, business model and regulatory position, the Company has included the following disclosure on a voluntary basis, with the objective of providing relevant and proportionate transparency. This disclosure is intended to enhance Board-level transparency and does not introduce separate sustainability policies or targets.
Double materiality assessment
During the financial year (2025), the Company performed its first Double Materiality Assessment (DMA). The assessment was performed in line with the principles underlying the European Sustainability Reporting Standards and focused on identifying sustainability-related topics that are relevant from both an impact perspective and a financial perspective.
The assessment included an analysis of:
The assessment included an analysis of:
- The Company’s business model and activities
- Its value chains
- Identification of sustainability-related impacts, risks and opportunities (IROs) over the short, medium and long term, and determination of the material IROs
In view of the composition of the Company’s portfolio, the assessment primarily focused on the Company’s role as a health insurer. Other lines of business were not separately analysed in detail, but are reflected where relevant under governance, risk management and compliance considerations.
Key sustainability-related topics
The outcome of the assessment indicates that the Company’s most material sustainability topics arise mainly from activities within the healthcare value chain, rather than from its own operational footprint. The following topics were identified as material:
- Climate change, primarily through indirect emissions related to healthcare services and pharmaceutical supply chains
- Pollution, including environmental impacts associated with medication residues
- Circular economy and waste, linked to material use and waste streams in healthcare
- Workers in the healthcare value chain, including aspects of health, safety and workload
- Consumers and end-users, such as access to healthcare services, information provision and data protection
- Business conduct and integrity, with particular regard to information security and cybersecurity risks
Healthcare procurement
For the Company, healthcare procurement represents the primary mechanism through which sustainability-related impacts and risks can be influenced. Through contracting and dialogue with healthcare providers, sustainability considerations are addressed as part of the procurement process.
Sustainability considerations are embedded in the Company’s healthcare procurement policies for 2025, in line with the uniform sector approach coordinated through Zorgverzekeraars Nederland (ZN), including commitments under the Green Deal Sustainable Healthcare. This alignment supports consistency across the sector and limits unnecessary administrative burden for healthcare providers.
For other insurance activities, sustainability considerations are mainly reflected through governance arrangements, responsible product design, partner oversight and risk management frameworks.
Sustainability considerations are embedded in the Company’s healthcare procurement policies for 2025, in line with the uniform sector approach coordinated through Zorgverzekeraars Nederland (ZN), including commitments under the Green Deal Sustainable Healthcare. This alignment supports consistency across the sector and limits unnecessary administrative burden for healthcare providers.
For other insurance activities, sustainability considerations are mainly reflected through governance arrangements, responsible product design, partner oversight and risk management frameworks.
Environmental and social considerations
The Company’s environmental impact is predominantly indirect and linked to healthcare services financed through its insurance products. Within its own operations, the Company applies prudent practices with regard to energy use, mobility and digital processes, in line with its operational scale.
From a social perspective, the Company places emphasis on fair treatment of insured persons, accessibility of information and robust protection of personal and medical data.
The Company also acknowledges broader societal challenges facing the healthcare sector, including workforce pressures, which are taken into account in procurement and policy considerations.
From a social perspective, the Company places emphasis on fair treatment of insured persons, accessibility of information and robust protection of personal and medical data.
The Company also acknowledges broader societal challenges facing the healthcare sector, including workforce pressures, which are taken into account in procurement and policy considerations.
Governance and oversight
The Company’s governance framework provides for the oversight of sustainability-related matters insofar as these relate to risk management, compliance and responsible business conduct. Relevant developments, including data protection and cybersecurity risks, form part of the regular governance and risk management processes and are discussed at Board level as appropriate.
Outlook
The completed Double Materiality Assessment provides a structured basis for the Company’s sustainability considerations. The Company will continue to assess identified material sustainability-related matters within its procurement and risk management activities and will periodically evaluate whether further refinement of the disclosure is appropriate, taking into account regulatory developments and stakeholder expectations.
Basis of preparation
This sustainability disclosure has been prepared on a voluntary basis and is published separately from the Company’s audited financial statements. No external assurance has been obtained in respect of this information.
