The following disclosure statement relates to Utmost PanEurope dac. Under Regulation (EU) 2019/2088 of the European Parliament and of the Council (the “Disclosure Regulation”), Utmost PanEurope dac (“UPE”) is required to make certain disclosures on the integration of sustainability risks associated with our investment decision-making process. Sustainability risk is defined as an “environmental, social or governance event that, if it occurs, could cause an actual or a potential negative material impact on the value of the investment”. In relation to its Investment Based Insurance Products, UPE plays a passive role regarding policyholder investments and does not make investment decisions for policyholders, nor does it play a role in recommending or advising on investment selection. Where UPE offers the policyholder the ability to direct the investment choice on a product, either via a list of funds approved by UPE, or on an “open architecture” basis, we invest in an underlying investment fund. In this case, the policyholder, or their adviser is responsible for the investment choice and setting their investment strategy. Where UPE’s investments are managed on a discretionary basis, management of those investments may be delegated to a number of regulated discretionary asset managers. In a small number of cases, we may appoint an investment adviser who would advise on investment choice, in accordance with an investment strategy chosen by a policyholder. In those cases, we would authorise the recommendation and transmit to the relevant custodian for execution, based on the investment adviser’s advice. Our investments have been selected by discretionary asset managers or, in a small number of cases, on the basis of advice from an investment adviser, who ensure that investment decisions or recommendations are aligned to the risk profiles and investment objectives of our policyholders. Accordingly, UPE does not actively engage with investee companies in its portfolios and relies on its appointed asset managers to do so. UPE may set or describe a ‘standard’ investment strategy that policyholders may select. However, UPE will delegate the portfolio management of that strategy to its appointed discretionary asset manager or, in a small number of cases, appoint an investment adviser who will advise on the portfolio management. Therefore, UPE is not required to, nor does it currently, integrate sustainability risk into its asset approval process. Customers should consult their professional advisers to understand how sustainability risk is integrated into their investment policies. Remuneration Policy As part of Utmost Group, UPE follows a remuneration policy that incorporates and promotes sound and effective risk management linked to risk-adjusted performance.