> UNDERWRITING POLICY
As part of the governance system requirements, insurance companies must define and implement
documented policies, approved by the Board of Directors and reviewed at least annually, relating to
risk management, including underwriting risk. Beyond the legal and regulatory requirements,
Fidelidade is also committed to embedding ESG factors across its processes and activities as part of
its broader ambition to strengthen its sustainability practices, positioning itself progressively at
the forefront of sustainability in the areas in which it operates. In this context, Fidelidade is
committed to further developing sustainable products and services and to strengthening customer
awareness on sustainability issues over time, in line with its Sustainability Policy. While this
work is ongoing, Fidelidade already offers services such as Fidelidade Drive and Multicare Vitality,
which encourage behaviours aligned with the United Nations’ Sustainable Development Goals (SDGs).
As a result, Fidelidade has its Underwriting Policy, which is a core element of the insurance
business and a fundamental part of the Governance System, covering both Fidelidade – Companhia de
Seguros, S.A., and the other insurance companies in Portugal within the Fidelidade Group.
RISK CLASSIFICATION
Risk classification under the Policy considers traditional variables such as risk knowledge and
technical risk and is currently developing the integration of environmental impacts and other ESG
factors as quantifiable elements for evaluating the sustainability of the business, for the
insurance lines where this is applicable.
The Policy framework is implemented through a risk management process based on two main approaches:
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ESG risk assessments, which are currently under development and applied in a project-based
context, with high-risk ESG cases being referred to the Underwriting Acceptance and
Monitoring Committee (UAMC); and
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Ongoing monitoring of the Underwriting Policy by the UAMC.
Roles and responsibilities of those engaged in the underwriting process are clearly defined
within the Policy, which is approved by the Executive Committee.
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Business Divisions: manage and assess the risks associated with the underwriting of
Fidelidade’s products;
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Underwriting Acceptance and Monitoring Committee (CAAPS): decides on the acceptance of
risks that exceed the authority of the Business Divisions.
Information about the Policy and any changes to it are communicated to the employees
affected by it, and, whenever deemed relevant, training is provided on the principles and
practices underlying compliance with the Policy.
The Underwriting Policy is a core document for Fidelidade's
business operations and
contains strategic and commercially sensitive information. For this reason, it is not
disclosed in full, and only its key principles and general guidelines (presented in this
website section) are publicly available.