1
The Triglav Group and Zavarovalnica Triglav d.d.
Annual Report for the Year Ended 31 December 2025
MANAGEMENT BOARD:
President: Andrej Slapar
Members: Uroš Ivanc
Tadej Čoroli
Marica Makoter
Blaž Jakič
Ivica Vulić
Ljubljana, 10 March 2026
2
Business Report
1. Address by the President of the Management Board ............................................................. 5
2. Triglav Group and Zavarovalnica Triglav in 2025 ................................................................... 7
3. Report of the Supervisory Board ........................................................................................... 17
4. Triglav Group strategy and plans .......................................................................................... 27
5. Corporate Governance Statement ........................................................................................ 40
6. The share and shareholders of Zavarovalnica Triglav .......................................................... 62
7. Macroeconomic environment and market trends ................................................................ 70
8. Operations of the Triglav Group and Zavarovalnica Triglav ................................................ 79
9. Risk management ................................................................................................................ 103
10. Sustainability report ............................................................................................................ 117
11. Digital Operational Resilience Report ................................................................................. 208
Accounting Report
Statement of management s responsibilities 213
1. Financial statements 221
2. Notes to the financial statements 227
3. Notes to the specific significant items in the financial statements 324
4. Other information 414
Appendix
1. Triglav Group as at 31 December 2025 425
2. Business network of the Triglav Group 430
3. Glossary of terms 432
4. Alternative performance measures 437
5. The list of ESRS disclosure requirements included in the sustainability statement 440
6. The list of datapoints in cross-cutting and topical standards that derive from other EU
legislation 442
3
4
Credit rating of the Triglav Group
Stable medium-term outlook (S&P Global)
Stable medium-term outlook (AM Best)
Total revenue in EUR million
Total business volume in EUR million
Combined ratio Non-Life and Health
Return on equity
Earnings before tax in EUR million
"A+"
"A"
1,393.2
1,694.7
940.3
1,201.1
2024 2025
Triglav Group Zavarovalnica Triglav
* Without total business volume generated on the Italian market in collaboration with Prima Assicurazioni.
159.0
≈ 160
174.1
117.6
142.1
2024 2025 plan 2025
Triglav Group Zavarovalnica Triglav
1,717.6
≈ 2,400
2,561.2
1,868.3
1,113.3
1,927.7
1,234.8
2024 2025 plan 2025 2025 recurring
business*
Triglav Group Zavarovalnica Triglav
93.6%
≈ 95.0%
93.2%
92.2%
92.9%
2024 2025 plan 2025
Triglav Group Zavarovalnica Triglav
14.0%
13.2%
13.8%
14.8%
2024 2025
Triglav Group Zavarovalnica Triglav
5
1. Address by the President of the Management Board
Dear Shareholders and Readers,
The year 2025 marked the beginning of a new strategy period through to 2030, during which we
are combining the stability of our business model, an exceptional client experience, ambitious
profitability targets, international growth and continued digital transformation. Throughout this
period, we remain committed to our mission – building a safer future for all our stakeholders.
We are very pleased with the results achieved in 2025. In a challenging economic and competitive
environment, earnings before tax reached EUR 174 million, with net earnings amounting to EUR
137 million. Strong performance was delivered in both insurance and asset management. Looking
ahead with optimism, earnings before tax for 2026 are projected in the range of EUR 170–190
million under expected operating conditions. This represents a further step toward the strategic
ambition of achieving EUR 250–300 million in earnings before tax by 2030.
The Triglav Group maintained strong capitalisation, as confirmed by the improved S&P Global
rating of "A+" and the affirmed AM Best rating of "A", both with a stable medium-term outlook.
Commitments to being a profitable, stable and safe investment were also met. From this
perspective, 2025 was an exceptional year. Market capitalisation surpassed EUR 1 billion, ending
the year at EUR 1.3 billion. Triglav's share, with a 51% total return and increased liquidity, was the
best-performing stock on the Ljubljana Stock Exchange.
Increased business volume, focus on internationalisation.
All insurance segments operated profitably, except for the Health segment, which is operating
under a revised business model. Strong results were achieved in the Non-Life segment, where the
insurance operating result increased by 58%. This growth was driven by an expanded insurance
portfolio, improved profitability of key insurance portfolios and the absence of significant CAT
events. The combined ratio for the Group's Non-Life and Health segments stood at a favourable
93.2%. The Life segment maintained a sound new business margin, increased its business volume
and achieved a solid operating result.
In 2025, the business volume was strengthened while ensuring that the business model remained
balanced and robust. Based on sales and development activities, organic growth of 9% was
achieved, increasing business volume to EUR 1.9 billion. New growth opportunities were also
explored in international insurance markets, where operations are conducted under a partnership
model. This model is already in use in Greece, Poland and Germany, and in mid-2025, the Group
entered the Italian motor vehicle insurance market in collaboration with partners. This generated
an additional EUR 0.7 billion in business. Including this new business, total business volume grew
by 49%, reaching EUR 2.6 billion. In conducting operations, we recognise that higher business
volume in insurance business provides potential for generating investment returns. Going forward,
activities will be dynamically adapted to opportunities available in individual markets, while some
year-on-year volatility is expected due to the dynamics of international operations and other
factors. For 2026, total business volume is planned to exceed EUR 2.4 billion, with the strategic
ambition of reaching EUR 2.5–3.0 billion by 2030.
In the Adria region, where the Group maintains a leading market position, business performance
was successful and in line with plans. On all markets, favourable profitability of the insurance
business was either improved or maintained. Business volume increased across all markets except
Bosnia and Herzegovina, where an ownership consolidation process and business optimisation are
underway.
Strategically, efforts continue to focus on further diversifying operations and increasing the share
of business generated outside Slovenia, thereby strengthening our resilience. In this respect, 2025
was a milestone year. The share of business generated in the Slovenian market decreased to 40%,
while other markets in the Adria region accounted for 15%. International insurance and reinsurance
markets contributed 46% of total business volume.
6
A solid investment result and growth in assets under management.
Assets under management increased by 6% to EUR 6.3 billion, a step toward the goal of exceeding
EUR 10 billion by 2030. The investment portfolio comprising own funds and the insurance segment
grew by 10% to EUR 4.3 billion, while its quality and conservative asset allocation remained largely
unchanged. Despite volatile conditions in financial markets, the investment segment delivered a
solid result, consistent with the previous year. Other assets – including mutual funds, discretionary
mandate assets, pension funds and alternative investments – totalled EUR 2.0 billion, supported by
both higher net inflows from clients and positive capital market developments. Efforts continue to
focus on leveraging synergies at Group level. In 2025, the management of pension insurance assets
was optimised, enhancing operational and process efficiency.
Advanced solutions for an enhanced client experience.
The Group continues to strengthen its position as a trusted partner. Client experience and
satisfaction are measured using the Net Promoter Score (NPS) methodology, with the Group's high
score of 77 confirming its clients' strong satisfaction. Development activities remain focused on
further enhancing the user experience, with particular emphasis on digitalisation and solutions
aligned with evolving client and market needs.
Significant progress was made in 2025. The i.triglav digital platform was upgraded, a substantial
portion of claims processes was automated, data analytics capabilities were strengthened, and
activities were implemented to enhance resilience and security amid rising cyber risks.
Improvements and new solutions were systematically rolled out across markets, including
automated claims reporting and drone-based loss inspections. Artificial intelligence was introduced
prudently through targeted projects, such as Triglav Direkt, which enables automated data
collection for motor vehicle insurance.
Several products were enhanced and expanded. These include the Triglav Direkt digital product,
redesigned motor vehicle and home insurance products, the inclusion of basic legal expense
insurance within personal liability insurance, the expansion of health insurance products through
Triglav Med services, and the introduction of cyber insurance for banking clients, among others.
Business partners can now access their portfolios and claims digitally, while the Triglav Investments
mobile application evolved into a modern investment platform.
Creating long-term value for stakeholders.
Sustainable operations lay the foundations for the future: a safer environment, resilient business
performance and long-term value creation for all stakeholders. In 2025, the share of bonds with
sustainability characteristics increased to 15% of the bond portfolio. In insurance business, the
range of products promoting environmental benefits and providing protection against climate-
related risks was further strengthened, alongside the enhancement of processes for assessing
exposure to floods, hail and other weather-related events. Investments were directed towards
energy efficiency in buildings and digital solutions, while responsible conduct was maintained
across the entire value chain. In the environmental area, the carbon footprint from operations
(Scope 1 and 2) was further reduced, and the share of electricity from renewable sources increased
to 75%. Partnerships with local communities were fostered, supporting a responsible relationship
with the wider society. Particular attention was devoted to organisational culture, promoting
creativity, agility and collaboration. We are pleased with the high ORVI score achieved, which
confirms that our employees are engaged and satisfied.
Our accomplishments in 2025 are the result of the knowledge, dedication and cooperation of our
team, as well as the trust of our clients and the support of our shareholders. Thank you to all of you.
Andrej Slapar
President of the Management Board of Zavarovalnica Triglav
7
2. Triglav Group and Zavarovalnica Triglav in 2025
- The Triglav Group exceeded planned earnings before tax and recorded organic growth in
business volume across all segments.
- The Group maintained financial strength and improved its credit rating with S&P Global to
"A+".
- The Group retained its leading position in the insurance sector both in Slovenia and the Adria
region.
2.1 Financial highlights of the Triglav Group
in EUR million
2025
2024
Index
Total business volume
2,561.2
1,717.6
149
Gross written premium
2,475.0
1,622.3
153
Other income
86.1
95.4
90
Total revenue
1,694.7
1,393.2
122
Insurance operating result
122.5
97.5
126
Insurance revenue
1,608.8
1,298.0
124
State compensation pursuant to the Decree on supplemental health
insurance premium
0.0
11.0
0
Claims incurred
964.2
678.7
142
Acquisition and administrative costs including non att. costs
431.4
370.9
116
Net reinsurance service result
-64.8
-140.9
46
Net other insurance revenue and expenses
-25.9
-20.9
124
Net investment result
44.8
49.0
91
Investment result
87.8
159.7
55
Financial result from insurance contracts
-47.8
-118.5
40
Change in provisions for not achieving the guaranteed yield
0.0
0.9
2
Gains/losses and impairments of investments in associates
4.7
6.9
69
Result from non-insurance operations
6.8
12.5
54
Earnings before tax
174.1
159.0
109
Net earnings
136.7
131.4
104
Other comprehensive income
15.4
6.3
243
Combined ratio Non-Life and Health
93.2%
93.6%
-0.4 p.p.
Claims ratio Non-Life and Health
66.4%
65.5%
0.9 p.p.
Expense ratio Non-Life and Health
26.8%
28.1%
-1.3 p.p.
New business margin Life
13.3%
13.4%
-0.1 p.p.
CSM growth ratio
96%
112%
-15.7 p.p.
Return on equity (ROE)
13.2%
14.0%
-1.0 p.p.
Return on financial investments
2.6%
3.0%
-0.4 p.p.
Share of non/attributable operating costs/expenses in gross written
insurance premium
25.1%
28.5%
-3.4 p.p.
31 Dec 2025
31 Dec 2024
Index
Balance sheet total
5,436.0
4,538.3
120
Equity
1,078.1
989.0
109
Contractual service margin (CSM)
306.7
286.8
107
Assets under management (AUM)
6,271.1
5,893.8
106
Number of employees
5,155
5,204
99
Number of employees (full-time equivalent)
5,037
5,088
99
The breakdown of profit or loss in the Business Report (comprising insurance operating result, net investment result, result from non-insurance operations)
differs from that of the statement of profit and loss in the Accounting Report (comprising insurance service result, investment result, financial result from
insurance contracts and other profit or loss categories). The presentation of the insurance operating result also takes into account non-attributable costs,
insurance revenue, insurance service expenses, net other insurance revenue and insurance service expenses, and state compensation under the Decree on
setting the maximum price of the supplemental health insurance premium. Furthermore, the net investment result includes the financial result from
insurance contracts, change in provisions for not achieving the guaranteed yield, gains/losses on investments in associates and impairment of investments
in associates, in addition to the investment result. Other categories are included in the result from non-insurance operations.
8
2.2 Financial highlights of Zavarovalnica Triglav*
in EUR million
2025
2024
Index
Total business volume
1,927.7
1,113.3
173
Gross written premium
1,910.7
1,084.0
176
Other income
17.0
29.3
58
Total revenue
1,201.1
940.3
128
Insurance operating result
95.6
84.4
113
Insurance revenue
1,184.2
911.1
130
State compensation pursuant to the Decree on supplemental health
insurance premium
0.0
11.0
0
Claims incurred
724.8
420.8
172
Acquisition and administrative costs including non att. costs
314.1
266.0
118
Net reinsurance service result
-25.3
-130.7
19
Net other insurance revenue and expenses
-24.4
-20.2
121
Net investment result
52.1
33.8
154
Investment result
64.4
134.9
48
Financial result from insurance contracts
-37.3
-110.1
34
Change in provisions for not achieving guaranteed yield
0.0
0.0
Gains/losses and impairments of investments in associates
25.1
9.0
278
Result from non-insurance operations
-5.6
-0.6
1,010
Earnings before tax
142.1
117.6
121
Net earnings
113.6
98.2
116
Other comprehensive income
6.7
0.7
994
Combined ratio Non-Life and Health
92.9%
92.2%
0.7 p.p.
Claims ratio Non-Life and Health
66.2%
63.1%
3.1 p.p.
Expense ratio Non-Life and Health
26.8%
29.1%
-2.3 p.p.
New business margin Life
14.5%
14.6%
-0.1 p.p.
CSM growth ratio
94%
103%
-9.1 p.p.
Return on equity (ROE)
14.8%
13.8%
1.0 p.p.
Return on financial investments
3.4%
2.8%
0.7 p.p.
Share of non/attributable operating costs/expenses in gross written
insurance premium
24.4%
29.4%
-4.9 p.p.
31 Dec 2025
31 Dec 2024
Index
Balance sheet total
3,744.3
2,983.0
126
Equity
798.3
741.6
108
Contractual service margin (CSM)
288.2
271.4
106
Number of employees
2,147
2,223
97
Number of employees (full-time equivalent)
2,121
2,197
97
* Zavarovalnica Triglav's figures for 2024 have been adjusted for transferred financial contract assets and liabilities. The impacts are reported in Section 2.7 of the
Accounting Report.
Alternative performance measures and a
glossary of key terms are provided in the
appendix to the Annual Report.
9
2.3 Environmental, social and governance (ESG) aspects of the Triglav Group's operations
2025
2024
Index
1. Environmental aspects
Carbon footprint (tonnes of CO2 equivalent)*
6,879
7,049
98
Scope 1 and 2 carbon footprint per employee (tonnes of CO2 equivalent)*
1.33
1.34
99
Electricity consumption (MWh)
9,079
9,420
96
Share of electricity consumption from renewable sources (%)
75
66
114
Written premium from products promoting environmental benefits (EUR million)
23.2
22.9
101
Investment funds – Article 8 of the SFDR (EUR million)
2,105.9
1,924.0
109
Sustainable fixed-income investments (EUR million)**
425.9
339.4
125
2. Social aspects
Employee satisfaction (ORVI)
4.03
3.97
101
Average employee age
45.2
45.1
100
Women employees to total employees ratio (%)
55.6
55.7
100
Employee turnover (number of leavers/average number of employees; %)
12.5
16.5
76
Client satisfaction of Triglav Group (NPS)***
34
31
108
Investments into the community (prevention, donations, sponsorships) (EUR million)
77
70
110
3. Governance aspects
Proportion of women in the management board/supervisory board in parent company (%)
20.0/42.9
20.0/37.5
Proportion of women at the first management level under the management board (%)
47.4
45.7
104
Proportion of women in management and supervisory bodies (%)
29.2
26.4
111
Average age of Zavarovalnica Triglav Management Board members
49.8
48.8
102
Independence of Zavarovalnica Triglav Supervisory Board members, shareholder
representatives (% of members)
100
100
100
Fair business practices (number of fraud cases investigated)
1,780
1,756
101
Internationally renowned audit firm (Big 4)
YES
YES
Period of cooperation with the existing auditor (years)
7
6
117
Investor relations when publishing results
YES
YES
* Includes Scope 1 and 2 emissions under the location-based method. A more detailed calculation of Scope 1 and 2 GHG emissions is shown in Section 10.2.1.1 The
Triglav Group's carbon footprint.
** Sustainable fixed-income investments include social bonds, green bonds, sustainability-linked bonds, and sustainable bonds
*** NPS shows the share of promoters who would recommend the Company to their acquaintances and friends based on experience.
For additional information about this report please contact:
Zavarovalnica Triglav d.d., Ljubljana
Miklošičeva cesta 19, 1000 Ljubljana
Darko Popovski, Executive Director of Finance, Accounting and Controlling
Email: darko.popovski@triglav.si
10
2.4 Significant events in 2025
▪ Strong performance: During the year, the Group raised its annual profit guidance and
ultimately exceeded it by year-end. The Group achieved organic growth in total business
volume across all segments (see Section 8. Operations of the Triglav Group and Zavarovalnica
Triglav for more details).
▪ Dividend payment: At the June General Meeting of Shareholders, the shareholders adopted the
resolution proposed by the Management Board and the Supervisory Board to pay a dividend of
EUR 2.80 gross per share or EUR 63.7 million in total. At year-end, the ZVTG dividend yield stood
at 4.7%. See Section 6.4 Dividends and the dividend policy for more information.
▪ The high credit rating affirmed: In June, S&P Global upgraded the Group's financial strength
and issuer credit rating from "A" to "A+", while AM Best reaffirmed the "A" credit rating in
October. Both credit ratings have a stable medium-term outlook. See Section 6.6 Credit rating
of the Triglav Group and Zavarovalnica Triglav for more information.
▪ Corporate governance: The General Meeting of Shareholders appointed Andrej Andoljšek and
Barbara Cerovšek Zupančič as Supervisory Board members – shareholder representatives. Janja
Strmljan Čevnja and Aleš Košiček, Supervisory Board members – employee representatives,
tendered their resignations in March 2025. In September, the Supervisory Board considered the
proposal of the Works Council and appointed Ivica Vulić to the Management Board as Worker
Director. His five-year term of office began in January 2026. The Works Council appointed Rudi
Lipovec to the Supervisory Board as employee representative. See Section 5.3 Management
bodies of Zavarovalnica Triglav for more information.
▪ Ongoing optimisation at Group level: In order to simplify and optimise the Triglav Group's
operations, the entire supplemental voluntary pension insurance business related to the
accumulation phase, along with the management of guarantee funds, was transferred from
the parent company to the specialised subsidiary Triglav, pokojninska družba. The proposed
spin-off was also approved by the General Meeting of Shareholders. The spin-off was entered
in the register of companies on 1 October 2025. See Section 2.7 Transfer of part of the assets to
Triglav, pokojninska družba d.d. of the Accounting Report for further details.
▪ Internationalisation of operations: In line with its strategic ambition to internationalise
operations, the Group expanded its business on foreign markets. In the Italian motor vehicle
insurance market, it launched operations in June in partnership with the Italian insurance
agency company Prima Assicurazioni and the reinsurer Ageas Re, significantly increasing its
total business volume. In August 2025, AXA entered into an agreement to acquire a 51%
participating interest in Prima, with the acquisition completed in November 2025. As a result
of the AXA Group’s acquisition of Prima, changes in the extent of business cooperation can be
expected. In the Polish motor vehicle insurance market, the Group, together with the EBRD,
acquired a participating interest in its partner, the insurance agency company HPI GMA S.A., to
strengthen its presence in this market. The Group plans to reach 24.8% ownership within two
years and acquired a 21.68% participating interest by the end of 2025. See Section 4. Triglav
Group strategy and plans for more details.
11
2.5 Financial calendar 2026
Calendar of financial announcements for 2026
Date of announcement*
Time
Type of announcement
Silent period**
Friday, 6 March 2026
8:30
Preliminary key figures for 2025
From Friday, 13 February 2026
Monday, 30 March 2026
8:30
Audited annual report for 2025
From Monday, 16 March 2026
Thursday, 23 April 2026
Call notice of the General Meeting of Shareholders to decide
on the distribution of accumulated profit
Wednesday, 20 May 2026
8:30
January–March 2026 interim financial report
From Wednesday, 6 May 2026
Tuesday, 2 June 2026
General Meeting of Shareholders and announcement of its
resolutions
Friday, 21 August 2026
8:30
January–June 2026 interim financial report
From Thursday, 6 August 2026
Wednesday, 18 November 2026
8:30
January–September 2026 interim financial report
From Wednesday, 4 November 2026
* These are planned dates, which may differ from the actual dates.
** The silent period denotes a period preceding the announcement of a financial report, during which Zavarovalnica Triglav does not disclose any information
on current operations to the public.
The general public is informed about the dates of key announcements and about any amendments
to the planned time of announcement:
▪ in the Ljubljana Stock Exchange SEOnet information system (seonet.ljse.si) and
▪ on Zavarovalnica Triglav's corporate website (www.triglav.eu).
12
2.6 Activities, markets and position of the Triglav Group
The Triglav Group is the leading insurance and financial group in Slovenia and the Adria region as well as one of the leading groups in South-East
Europe. The Group also operates in the wider international environment, mainly through partnerships with foreign insurance brokerage companies,
insurance agency companies and reinsurers. Its key markets in the Adria region and its core activities are shown below.
Strategic activities
Insurance
Asset management
Non-life
Investment portfolios of insurance
companies
Life
Health
Mutual funds and discretionary
mandate services
Reinsurance
Pension funds
Adria region and international markets
Slovenia
Serbia
Croatia
Bosnia and
Herzegovina
Montenegro
North
Macedonia
International
insurance and
reinsurance
1st place
34.8% market share
(–1.0 p.p.)
5th place
7.7% market share*
(0.0 p.p.)
8th place
4.6% market share
(–0.2 p.p.)
6th place
7.3% market share
(–1.0 p.p.)
1st place
32.7% market share
(–1.9 p.p.)
3rd place
13.9% market share*
(–0.4 p.p.)
2,575
employees
842
employees
566
employees
511
employees
380
employees
281
employees
EUR 1,015 million
total business volume
(+3%)
EUR 126 million
total business volume
(+8%)
EUR 104 million
total business volume
(+12%)
EUR 50 million
total business volume
(–3%)
EUR 53 million
total business volume
(+5%)
EUR 41 million
total business volume
(+8%)
EUR 1,171 million
total business volume
(+210%)
* Data for Serbia and North Macedonia are for the period from January to September 2025.
13
2.6.1 Insurance
The Triglav Group's insurance activity includes non-life, health and life insurance, as well as
reinsurance.
The Group's insurance business comprises:
▪ in Slovenia: Zavarovalnica Triglav d.d. and Pozavarovalnica Triglav Re d.d.;
▪ outside Slovenia: eight insurance companies in the Adria region (Croatia, Serbia,
Montenegro, Bosnia and Herzegovina, and North Macedonia), Zavarovalnica Triglav d.d.'s
branch in Greece (under the FOE principle) and business partnerships under the principle of
free movement of services (FOS).
Insurance market position in the Adria region and South-East Europe
The Triglav Group holds a dominant market position in the Adria region (Slovenia, Croatia,
Serbia, Montenegro, Bosnia and Herzegovina, and North Macedonia). Based on the latest
available data for 2024, the Group had a 20.6% market share, 1.2 percentage points lower than
in 2023, primarily due to the termination of supplemental health insurance (excluding this
premium, the Group's market share in 2023 would have been 20.9%).
The market share of insurance groups and insurers in the Adria region in 2024 and 2023*
* Data for 2025 not yet available.
Source: Zavarovalnica Triglav's calculation based on the data of national insurance supervision agencies and insurance associations
Zavarovalnica Triglav, the Group's parent company, is the leader among the insurers in South-
East Europe (Albania, Bulgaria, Bosnia and Herzegovina, Montenegro, Croatia, Moldova,
Romania, North Macedonia, Slovenia and Serbia). The Romanian insurers Groupama Asigurari
and Allianz – Tiriac Asigurari again ranked second and third. Seven insurance companies of the
Triglav Group ranked among the top 100 insurers in South-East Europe in terms of gross written
premium. All 100 insurers collectively recorded a total written premium of EUR 13.4 billion, up
by 8% compared to the previous year.
2.2%
3.4%
3.5%
4.1%
5.1%
6.0%
7.7%
8.3%
10.5%
12.9%
21.8%
2.4%
3.6%
3.7%
4.7%
5.7%
6.5%
8.4%
9.0%
11.8%
11.9%
20.6%
Modra
zavarovalnica
Allianz
Uniqa
Grawe
Dunav
VIG
Croatia Group
Agram
Sava insurance
Group
Generali
Triglav Group
2024 2023
14
The largest insurers in South-East Europe by written premium in 2024 (million EUR)
Source: SeeNews 2025.
2.6.2 Asset management
The asset management activity at the Triglav Group comprises the management of the
insurance portfolios of insurance companies, clients' pension savings through the insurance
services of the Group's insurance and pension companies, asset management by asset
management companies and the management of clients' assets in mutual funds and
discretionary mandate assets. See Section 8.4 Asset management and Section 7.5 The asset
management and investment fund market in Slovenia for more information on asset
management.
244.7
246.0
252.9
269.5
271.1
364.5
364.9
396.1
424.6
489.5
559.3
619.7
739.6
863.0
1,104.8
Adriatic osiguranje d.d.
Grawe Romania Asigurare SA
Euroherc Osiguranje d.d.
Dall Bogg Zhivot i Zdrave EAD
Generali Osiguranje Srbija AD
Asirom VIG SA
Generali Romania SA
Dunav Osiguranje AD
Generali Zavarovalnica d.d.
Croatia Osiguranje, d.d.
Omniasig VIG SA
Zavarovalnica Sava, d.d.
Allianz - Tiriac Asigurari SA
Groupama Asigurari SA
Zavarovalnica Triglav, d.d.
15
2.6.3 Composition of the Triglav Group
As at 31 December 2025, the Triglav Group comprised 53 companies: the parent company, 29 subsidiaries, 10 associates and 13 joint ventures.
The Triglav Group members and their participating interests as at 31 December 2025
16
The changes in the Group are discussed in greater detail in Section 2.1.4.5 of the Accounting
Report.
2.7 Management of Zavarovalnica Triglav
The Management Board of Zavarovalnica Triglav comprises:
▪ Andrej Slapar, President
The period from the first appointment to the end of the current term of office: 2013–2029
Employed at the Triglav Group: from 1997
▪ Uroš Ivanc, Member
The period from the first appointment to the end of the current term of office: 2014–2029
Employed at the Triglav Group: from 2001
▪ Tadej Čoroli, Member
The period from the first appointment to the end of the current term of office: 2014–2029
Employed at the Triglav Group: from 2001
▪ Marica Makoter, Member
The period from the first appointment to the end of the current term of office: 2011–2026
Employed at the Triglav Group: from 2001
▪ Blaž Jakič, Member
The period from the first appointment to the end of the current term of office: 2023–2028
Employed at the Triglav Group: from 2010
▪ Ivica Vulić, Member, Worker Director
The period from the first appointment to the end of the current term of office: 2026–2031
1
Employed at the Triglav Group: from 2006.
1
He assumed the position of Management Board member, Worker Director, on 8 January 2026.
17
3. Report of the Supervisory Board
Report of the Supervisory Board of Zavarovalnica Triglav d.d. on the verification of the Annual
Report of the Triglav Group and Zavarovalnica Triglav d.d. for 2025
and
Opinion of the Supervisory Board of Zavarovalnica Triglav d.d. on the Annual Internal Audit
Report of the Internal Audit Department of Zavarovalnica Triglav d.d. for 2025
In 2025, the Supervisory Board of Zavarovalnica Triglav diligently and responsibly fulfilled its
supervisory role, ensuring high-quality oversight of the operations of Zavarovalnica Triglav d.d.
and the Triglav Group. It oversaw various aspects of their operations and development, and on
that basis took appropriate decisions and followed up on their implementation. Individual topics
were initially reviewed by the Supervisory Board's committees, whose findings and proposals
supported well-informed and prudent decision-making. The Supervisory Board also monitored
the implementation and execution of the Triglav Group's strategy and actively participated in
the formulation and adoption of the new strategy.
The Supervisory Board performed its work within the scope of its powers and competencies set
out by law, the Company's Articles of Association and its own Rules of Procedure.
1. INTRODUCTION
Pursuant to Article 282 of the Companies Act and Article 69 of the Insurance Act, the Supervisory
Board hereby presents its Report on the verification of the Annual Report of the Triglav Group
and Zavarovalnica Triglav d.d. for 2025 (hereinafter: the report) and its Opinion on the Annual
Internal Audit Report of the Internal Audit Department of Zavarovalnica Triglav d.d. for 2025.
The findings are based on the results of the supervision of operations of Zavarovalnica Triglav
d.d. (hereinafter: the Company, the controlling company or the parent company) in 2025 and on
the verification of the Audited Annual Report of the Triglav Group and Zavarovalnica Triglav d.d.
for 2025, the reports of the non-life insurance actuarial function holder and the life insurance
actuarial function holder for 2025, Solvency and Financial Condition Report of Zavarovalnica
Triglav, d.d. for 2025 and Solvency and Financial Condition Report of Triglav Group for 2025.
An integral part of the report is also the opinion of the Supervisory Board on the work of the
Internal Audit Department in 2025 and the Annual Internal Audit Report of the Internal Audit
Department of Zavarovalnica Triglav d.d. for 2025.
2. GENERAL INFORMATION
The Supervisory Board and its committees in 2025
The composition of the Supervisory Board in 2025 is described in Section 5. Corporate
Governance Statement (Supervisory Board) of the Business Report. In 2025, the Supervisory Board
held ten sessions and had five committees: the Audit Committee, the Risk Committee, the
Appointment and Remuneration Committee, the Strategy Committee and the Nomination
Committee. The composition of the Supervisory Board committees in 2025 as well as the more
important duties and powers of individual committees are described in Section 5. Corporate
Governance Statement (Composition of Supervisory Board committees and their activities in 2025)
of the Business Report.
18
Audit Committee
In 2025, the Audit Committee held seven meetings, at which it, among other things:
▪ Monitored and discussed financial reporting procedures and the external audit of the annual
financial statements of the Triglav Group and Zavarovalnica Triglav d.d.;
▪ Assessed the content of the Annual Report of the Triglav Group and Zavarovalnica Triglav
d.d. for 2024 and the 2025 interim reports;
▪ Took note of the draft independent auditor's reports, the Letter to Management following
the completed audit, and the Management Representation Letter for Zavarovalnica Triglav
d.d. and the Triglav Group;
▪ Discussed the Solvency and Financial Condition Report of Zavarovalnica Triglav d.d. and the
Solvency and Financial Condition Report of the Triglav Group as at 31 December 2024,
including the independent auditor’s assurance reports;
▪ Took note of the reports of the actuarial function holders for solvency reporting purposes;
▪ Took note of the Remuneration Report for 2024;
▪ Regularly took note of the Report on Current Issues Related to the Audit Committee's Work;
▪ Discussed the Report on the Self-Assessment of the Effectiveness of Internal Controls in
Financial Reporting;
▪ Monitored and discussed the risk management systems, the functioning of internal controls,
the Annual Internal Audit Report of the Internal Audit Department for 2024, the Internal
Audit Department's interim reports, recommendations and the annual work plan for 2026;
▪ Discussed the findings of the Slovenian Insurance Supervision Agency and other supervisory
bodies in supervision procedures under the Audit Committee's responsibility and was briefed
on procedures related to these findings or requirements;
▪ Supervised and discussed the conclusion of agreements with audit firms, the independence
of the certified auditor, the quality of auditing, the audit plan for 2025 and the auditor's
report following the pre-audit of Zavarovalnica Triglav d.d. for 2025;
▪ Reviewed and updated the protocol and guidelines for the oversight of the engagement of
audit firms;
▪ Took note of remuneration of the director of Internal Audit Department for 2024 and
proposed amendments to the Remuneration Policy for the director of the Internal Audit
Department;
▪ Discussed the Compliance Office Annual Report for 2024;
▪ Discussed the Statement of Compliance with the Slovenian Corporate Governance Code;
▪ Took note of and approved the Quality Monitoring Report of the External Auditor for
Zavarovalnica Triglav d.d. for 2024;
▪ Led the reappointment process for the statutory auditor for the financial years 2025–2028,
reviewed agreements, and verified compliance with independence and assurance
requirements;
▪ Considered the Sustainability Report, the Limited Assurance Report and the Letter to
Management;
▪ Took note of the Report on the Double Materiality Assessment Process of Zavarovalnica
Triglav d.d. and the Triglav Group for 2025;
▪ Took note of the content and accounting treatment of the planned spin-off of part of the
assets of Zavarovalnica Triglav d.d. to be transferred to Triglav, pokojninska družba d.d., and
agreed to provide limited assurance engagement in connection with the spin-off and to
perform agreed procedures in relation to the merger of the SVPI guarantee funds;
▪ Approved amendments to the Sustainable Development Policy of Zavarovalnica Triglav d.d.
and the Triglav Group and discussed amendments to the Rules of Procedure of the Audit
Commission. The Audit Committee carried out a performance self-assessment with the aim
of ensuring the continued improvement and quality of its work and adopted an action plan
for the improvement of its performance.
19
Appointment and Remuneration Committee
The Appointment and Remuneration Committee held nine meetings in 2025. Its most important
activities included:
▪ Drawing up of draft periodic fit and proper assessments of the members of the Management
Board and the Supervisory Board and of the two bodies as a whole;
▪ Preparation of draft fit and proper assessments for Supervisory Board candidates, a
Management Board member, an external member of the Audit Committee and the newly
appointed external members of the Risk Committee, as well as for the body as a whole;
▪ Review of the calculation and amount of the average gross salary for 2025 in the Group
members which are headquartered in the Republic of Slovenia and were fully consolidated
by the Group pursuant to the Act Governing the Remuneration of Managers of Companies
with Majority Ownership Held by the Republic of Slovenia or Self-Governing Local
Communities (ZPPOGD);
▪ Discussion of the adjustment of the basic salary of Management Board members and the
calculation of the variable part of remuneration of the Management Board members based
on the Group's performance;
▪ Approval of the draft amendments to the Methodology for Determining the Variable
Remuneration and Decreasing Basic Salary of Management Board Members in 2026 and
setting of the targets for the part of the salary for the performance of the Management
Board members for 2026;
▪ Discussion of the report on the development of key high-potential staff at Zavarovalnica
Triglav d.d.;
▪ Consideration of the succession evaluation report;
▪ Discussion of an employment agreement of a Management Board member;
▪ Review of the authorisation of the deputy internal audit key function holder in Zavarovalnica
Triglav d.d. and the Triglav Group;
▪ Consideration of amendments to the Fit and Proper Policy for the Management Board and
Supervisory Board Members of Zavarovalnica Triglav d.d., the Fit and Proper Policy for the
Key Function Holders and Business Function Holders of Zavarovalnica Triglav d.d., and the
Diversity Policy for the Members of Management and Supervisory Bodies of Zavarovalnica
Triglav d.d.
Strategy Committee
The Strategy Committee, which held one meeting in 2025, devoted special attention to the
implementation of the revised Triglav Group strategy for 2025–2030 and the starting points for
the development of the Triglav Group's business plan for 2026.
Risk Committee
The Risk Committee held seven meetings in 2025, at which it:
▪ Discussed the Solvency and Financial Condition Report (SFCR) of Zavarovalnica Triglav d.d.
and the Triglav Group for 2024 and the annual capital adequacy as at 31 December 2024, as
well as the independent auditor's assurance reports;
▪ Discussed interim risk reports and the draft amendments to the Risk Underwriting and
Management Strategy, the Risk Appetite Statement, the Capital Management Policy and the
Policy of the Risk Management Function;
▪ Reviewed the Own Risk and Solvency Assessment 2025 (ORSA) reports for Zavarovalnica
Triglav and the Triglav Group;
▪ Considered the Progress Report on the IT Project in Support of the Core Business;
▪ Discussed the implementation of the Business Intelligence Strategy;
20
▪ Discussed the risks associated with the MGA business model and the parameters of the new
business in Italy;
▪ Considered the draft amendments to the Actuarial Function Policy;
▪ Monitored ICT and cyber risks and business intelligence strategy;
▪ Discussed S&P and AM Best credit ratings;
▪ Considered amendments to the Rules of Procedure of the Risk Committee.
Nomination Committee
The Nomination Committee was established on 19 November 2024 to carry out the nomination
process for appointing two candidates for Supervisory Board members – shareholder
representatives to replace Andrej Andoljšek and Tomaž Benčina, whose term of office expired on
14 June 2025. In 2025, the Nomination Committee held six meetings and proposed two
candidates for Supervisory Board members – shareholder representatives, both of whom were
subsequently appointed for a four-year term of office at the General Meeting of Shareholders,
i.e. Andrej Andoljšek and Barbara Cerovšek Zupančič.
3. WORK OF THE SUPERVISORY BOARD AND SCOPE OF SUPERVISION OF THE COMPANY'S
OPERATIONS IN 2025
The description of the Supervisory Board's operations and the scope of monitoring and
supervision of the governance of the Company and the Group in 2025 are based on the
supervision of the Company's and the Group's operations performed by the Supervisory Board in
2025, acting within its powers. The Supervisory Board held ten sessions in 2025.
The Supervisory Board's duty is to supervise how the Company conducts its business and to
perform other tasks in accordance with the Companies Act, the Insurance Act, the Company's
Articles of Association, the Rules of Procedure of the Supervisory Board and the Slovenian
Corporate Governance Code. The methods and organisation of its work are set out in the Rules
of Procedure of the Supervisory Board, which are published on the Company's website.
a) With regard to its core competences, in 2025 the Supervisory Board:
▪ Approved the Solvency and Financial Condition Report (SFCR) of Zavarovalnica Triglav d.d.
and the Triglav Group for 2024 and the annual capital adequacy as at 31 December 2024
and took note of the independent auditor’s assurance report;
▪ Adopted the Audited Annual Report of the Triglav Group and Zavarovalnica Triglav d.d. for
2024, the Report by the Supervisory Board of Zavarovalnica Triglav d.d. on the verification
of the Annual Report of the Triglav Group and Zavarovalnica Triglav d.d. for 2024 and the
Opinion of the Supervisory Board of Zavarovalnica Triglav d.d. on the Annual Internal Audit
Report for 2024 of the Internal Audit Department of Zavarovalnica Triglav d.d.;
▪ Discussed unaudited interim financial reports of the Triglav Group and Zavarovalnica
Triglav d.d. for the periods from 1 January to 31 March 2025, from 1 January to 30 June
2025 and from 1 January to 30 September 2025;
▪ Discussed the Annual Internal Audit Report of the Internal Audit Department for 2024;
▪ Approved the Triglav Group's business policy and business plan for 2025;
▪ Took note of the Updated Business Performance Assessment of Zavarovalnica Triglav and
the Triglav Group for 2025 and the Own Risk and Solvency Assessment 2025 (ORSA) reports
for Zavarovalnica Triglav and the Triglav Group;
▪ Approved the new Triglav Group Strategy for 2025–2030;
▪ Approved the Internal Audit Department's work plan for 2026;
▪ Proposed to the 50th General Meeting of Shareholders of Zavarovalnica Triglav d.d. to
grant a discharge to the Management Board for 2024; submitted a proposal on the
21
distribution of accumulated profit; presented the Remuneration Report for 2024;
acknowledged the expiry of a Supervisory Board member's term of office and proposed the
appointment of two Supervisory Board members; proposed the appointment of an auditor
for 2025–2028 financial years; proposed to the General Meeting of Shareholders to give its
consent to the spin-off of part of the assets of the transferor company Zavarovalnica Triglav
d.d. to the transferee company Triglav, pokojninska družba d.d.;
▪ Discussed the findings of the Insurance Supervision Agency and other supervisory bodies
in supervision procedures and was briefed on procedures related to these findings or
requirements;
▪ Approved amendments to the Governance System and Policy of Zavarovalnica Triglav d.d.;
the Diversity Policy; the Fit and Proper Policy for the Management Board and Supervisory
Board Members of Zavarovalnica Triglav d.d.; the Fit and Proper Policy for the Key Function
Holders and Business Function Holders of Zavarovalnica Triglav d.d.; the Actuarial Function
Policy; the Remuneration Policy of the Director of the Internal Audit Department; and the
Sustainable Development Policy of Zavarovalnica Triglav and the Triglav Group;
▪ Adopted the Audit Committee's guidelines for ensuring the independence of the statutory
auditor of the financial statements of Triglav Group companies;
▪ Discussed the Statement of Compliance with the Slovenian Corporate Governance Code
and took note of the positions on the Corporate Governance Code for Companies with
Capital Assets of the State and the Recommendations and Expectations of the Slovenian
Sovereign Holding.
b) With regard to the supervision of the management of the Company's operations, in 2025 the
Supervisory Board:
▪ Discussed the reports of the Audit Committee, the Appointment and Remuneration
Committee, the Strategy Committee, the Nomination Committee and the Risk Committee,
and was briefed on the financial reports of Zavarovalnica Triglav d.d., the Triglav Group and
Zavarovalnica Triglav's subsidiaries;
▪ Took note of the implementation of the Triglav Group strategy;
▪ Monitored the assessed performance indicators of the Company in each period, capital
adequacy, the implementation of the business plan and potential measures;
▪ Took note of risk reports and approved amendments to the Risk Underwriting and
Management Strategy, the Risk Appetite Statement, the Capital Management Policy and
the Policy of the Risk Management Function;
▪ Took note of the capital adequacy of Zavarovalnica Triglav d.d. and the Triglav Group;
▪ Oversaw the work of the Internal Audit Department and was briefed on its internal audit
reports as well as on the Compliance Office Annual Report for 2024 and its work plan for
2026;
▪ Took note of the Report of the Life Insurance Actuarial Function Holder in Zavarovalnica
Triglav d.d. and the Report of the Non-Life Insurance Actuarial Function Holder in
Zavarovalnica Triglav d.d.;
▪ Discussed the Report on the Double Materiality Assessment Process of Zavarovalnica
Triglav d.d. and the Triglav Group for 2025 and the Sustainability Report;
▪ Reviewed the documents, assurances and procedures; proposed the appointment of an
auditor for the spin-off in connection with the spin-off of the management of the SVPI
funds to the subsidiary Triglav, pokojninska družba d.d. and monitored the compliance of
the procedure with the applicable legislation;
▪ Took note of the report on the development of key high-potential staff at Zavarovalnica
Triglav d.d. in 2024;
▪ Approved investment decisions, including an additional contribution to an alternative fund
and an equity investment in HPI GMA S.A.;
▪ Discussed the parameters of the new business in Italy;
22
▪ Reviewed and approved agreements with the audit firm Deloitte revizija d.o.o. for 2025–
2028;
▪ Took note of other information regarding Zavarovalnica Triglav d.d., the Triglav Group and
its subsidiaries;
▪ Approved individual transactions in accordance with the law and the Rules of Procedure of
the Supervisory Board.
c) Other major actions taken by the Supervisory Board in 2025:
▪ Discussion of fit and proper assessments of the members of the Management Board and
the Management Board as a collective body, the members of the Supervisory Board and the
Supervisory Board as a collective body, as well as of the external members of the Audit
Committee and the Risk Committee;
▪ Setting of the annual performance bonus for the Management Board in 2024; approved
the Methodology for Determining the Variable Remuneration and Decreasing Basic Salary
of Management Board members for 2026, and the Management Board's targets for 2026;
review of the annual report of the Works' Council of Zavarovalnica Triglav d.d. and the
procedures related to the appointment of the Management Board member – Worker
Director;
▪ Adoption of the labour costs plan of the Supervisory Board for 2026, the financial calendar
and the timetable for the meetings of the Supervisory Board and its committees in 2026;
▪ Adoption of amendments to the Rules of Procedure of the Supervisory Board, the Rules of
Procedure of the Audit Committee and the Rules of Procedure of the Risk Committee;
▪ Appointment of two external members of the Risk Committee;
▪ Performance of other activities related to the supervision and work of the Supervisory
Board and its committees.
The costs in connection with the Supervisory Board's work other than the remuneration paid to
its members and committees (disclosed in Section 4.4 Related party transactions of the
Accounting Report) mostly included the rental costs of interpretation equipment and translation
costs for smooth execution of its sessions, training costs of the members of the Supervisory
Board and its committees, and the outsourced IT services for the Audit Committee. These costs,
including all remuneration, amounted to EUR 337,128 in 2025.
4. SELF-ASSESMENT
Specific topics were discussed in advance by the Supervisory Board's committees, which drafted
resolutions to be adopted by the Supervisory Board and meticulously carried out other tasks
within the scope of their powers. The committee chairs regularly reported on their work at the
sessions of the Supervisory Board, which discussed the adopted decisions, submitted
recommendations and opinions and passed appropriate resolutions after due consideration.
All members were involved in the work of the Supervisory Board and its committees. With their
attendance at its sessions and active participation in discussions and decision-making, they
contributed to the effective discharge of duties within the powers of the Supervisory Board and
its committees. The work of the Supervisory Board is well managed and supported, whilst the
planning and frequency of its sessions is adequate. Both the Rules of Procedure of the
Supervisory Board and the Rules of Procedure of the Audit Committee include clear rules of
conduct in the event of a conflict of interest. The Supervisory Board members and the Audit
Committee's external member signed and submitted statements of independence in accordance
with the Slovenian Corporate Governance Code, which are published on the Company's website.
All Supervisory Board members declared themselves independent in accordance with the
Slovenian Corporate Governance Code criteria (all statements of independence are published on
the Company's website). All members of the Supervisory Board and its committees diligently
23
adhere to the rules on managing conflicts of interest. The Supervisory Board and its committees
follow the highest standards of conflict of interest management.
The Supervisory Board is of the opinion that its cooperation with the Management Board was
adequate, in accordance with the applicable legislation and good practices. To the best of its
knowledge, the Supervisory Board was informed of all events of material significance to the
assessment of the situation and its consequences, and to the effective supervision of the
Company's operations. The documents provided as materials for the Supervisory Board’s
sessions were of good quality and information was accurate, relevant, reliable, comparable and
exhaustive. The Supervisory Board regularly followed the implementation of its resolutions. The
Governance System and Policy of Zavarovalnica Triglav d.d. sets out main corporate governance
guidelines, taking into account the set long-term objectives and the defined role and work of the
Supervisory Board and its committees.
The fit and proper criteria as set out in the Fit and Proper Policy for the Management Board and
Supervisory Board Members of Zavarovalnica Triglav d.d. apply to both the Supervisory Board as
a collective body and to Supervisory Board members as individuals. A fit and proper assessment
was carried out before new Supervisory Board members – shareholder representatives took
office. The Supervisory Board, as a collective body, was assessed as fit and proper, taking into
account appropriate diversity in terms of gender, qualifications, knowledge and experience, in
line with the frameworks and requirements in which the Company operates. A fit and proper
assessment is also performed for both the Audit Committee's external member and the Risk
Committee's external members.
The Supervisory Board regularly carries out the self-assessment procedure. Based on its findings,
it adopts an action plan containing a series of proposals and measures aimed at improving its
future performance. The implementation of the action plan is monitored on an ongoing basis.
By implementing the self-assessment procedures, the quality of the Supervisory Board's work is
improved, which is reflected in a higher quality of supervision of the operations and the areas
material for the Company and the Group.
The Supervisory Board believes that its composition (despite the absence of two Supervisory
Board members – employee representative) in 2025 corresponded to the size, activities and set
objectives of both the Company and the Group, which enabled it to make quality decisions.
The Supervisory Board carried out its duties and powers smoothly. The sessions of the
Supervisory Board and its committees were held in person and, in exceptional cases, also
virtually with the help of technical means.
In view of the above, the Supervisory Board is of the opinion that its work and the work of its
committees in 2025 were successful.
5. OPINION ON THE ANNUAL INTERNAL AUDIT REPORT FOR 2025
In accordance with paragraph three of Article 165 of the Insurance Act (ZZavar-1), the Annual
Internal Audit Report of the Internal Audit Department of Zavarovalnica Triglav d.d. for 2025 was
submitted to the Supervisory Board, which took note of it at its session on 5 March 2026. The
report contains an overview of the implementation of the Internal Audit Department's
(hereinafter: IAD) planned activities in 2025 and a summary of material audit findings, including
an assessment of the adequacy and effectiveness of risk management and the internal control
system of the audited areas, the assessment of the adequacy of the IAD's funds for its work, the
IAD's quality assurance and improvement programme and its results, and the statement of
independence and impartiality of the IAD and its employees.
24
The Internal Audit Department conducted the planned internal audits in the Company and other
companies of the Group and presented its internal audit findings to the relevant persons in
charge and made recommendations for improving risk management and the internal control
system of audited areas. Based on the performed internal audits and the follow-up of
implementation of recommendations, the IAD assessed that risk management and the internal
control system of the audited areas within the Company and the Group were overall mostly
appropriate and were constantly improving. The IAD also carried out advisory activities, followed
up on the implementation of recommendations made by external auditors, and carried out tasks
related to quality assurance and improvement of the IAD and the internal audit departments of
other Group members. The IAD reported on the implementation of its work plan, material audit
findings and the implementation of recommendations on a quarterly basis to the Audit
Committee and on a semi-annual basis to the Supervisory Board.
Based on the monitoring of the IAD's work and the submitted Annual Internal Audit Report of
the Internal Audit Department of Zavarovalnica Triglav d.d. for 2025, the Supervisory Board is of
the opinion that the IAD operated in line with its work plan for 2025, which was adopted by the
Management Board with the approval of the Supervisory Board, and in accordance with the
Supervisory Board's expectations. Through its work and the implementation of the full 2025
plan, the IAD made a significant contribution to enhancing the effectiveness of the internal
control and risk management system at the Company and the Group. The Supervisory Board has
no objection to the Annual Internal Audit Report of the Internal Audit Department of
Zavarovalnica Triglav d.d. for 2025.
6. FINDINGS OF THE SUPERVISORY BOARD REGARDING THE OPERATIONS OF ZAVAROVALNICA
TRIGLAV D.D. IN 2025
Based on its monitoring and supervision of the Company's operations in 2025 and the
examination and verification of the Annual Report of the Triglav Group and Zavarovalnica Triglav
d.d., the Supervisory Board hereby establishes that the Company performed well and pursued its
strategic objectives.
The Group generated EUR 174.1 million in consolidated earnings before tax and EUR 136.7
million in consolidated net earnings. The parent company's net earnings amounted to EUR 113.6
million. The Group's total revenue amounted to EUR 1,694.7 million, a 22% increase, with all
business segments, except for the Health segment, showing growth.
The Group's total business volume rose by 49% to EUR 2,561.2 million. The Group's insurance
companies generated insurance, coinsurance and reinsurance premiums of EUR 2,475.0 million
in 2025 (index 153), of which EUR 1,910.7 million (index 176) was earned by the parent company.
Premium growth was achieved in all insurance segments and in all markets where the Group
operates, except for Bosnia and Herzegovina's market.
The Group's consolidated operating expenses, including other attributable insurance service
expenses, increased by 14% year-on-year to EUR 511.8 million.
The Group's total equity increased by 9% to EUR 1,078.1 million as at 31 December 2025. Return
on equity stood at 13.2%. The Group’s capital adequacy is within target range amounting 206%.
S&P Global upgraded the Group's financial strength and issuer credit rating from "A" to "A+",
while AM Best reaffirmed the "A" credit rating. Both credit ratings have a stable medium-term
outlook.
The findings of the Supervisory Board are also based on the following:
25
▪ Report of the non-life insurance actuarial function holder for 2025;
▪ Report of the life insurance actuarial function holder for 2025;
▪ Annual Internal Audit Report of the Internal Audit Department of Zavarovalnica Triglav d.d.
for 2025;
▪ Solvency and Financial Condition Report of Zavarovalnica Triglav, d.d. for 2025;
▪ Solvency and Financial Condition Report of Triglav Group for 2025.
The Supervisory Board has no objection to the aforementioned reports.
7. ANNUAL REPORT
The Management Board submitted the Unaudited and later the Audited Annual Report of the
Triglav Group and Zavarovalnica Triglav d.d. for 2025 to the Audit Committee and the
Supervisory Board.
The Supervisory Board hereby ascertains that the Annual Report, which includes the Triglav
Group Sustainability Report, was compiled within the statutory deadline and submitted to the
appointed auditor. The Annual Report of the Triglav Group and Zavarovalnica Triglav d.d. for
2025 was audited by the audit firm Deloitte revizija d.o.o., Ljubljana, which on 11 March 2026
expressed an unmodified opinion on the separate and consolidated financial statements in the
Annual Report of the Triglav Group and Zavarovalnica Triglav d.d. for 2025. In their report as an
independent auditor, they took a stance on key audit matter related to the valuation of
insurance contract liabilities and insurance revenue.
The audit firm Deloitte revizija d.o.o., Ljubljana also conducted the audit of the Group's
consolidated Sustainability Report for 2025 and issued an independent limited assurance
opinion on 11 March 2026.
The certified auditor, a key audit partner, was present at the session of the Supervisory Board
and the Audit Committee regarding those items where the Annual Report was discussed and
provided the requested additional explanations to the Audit Committee and the Supervisory
Board.
Based on a detailed verification, the Supervisory Board established that the Annual Report of the
Triglav Group and Zavarovalnica Triglav d.d. for 2025, which was prepared by the Management
Board and verified by a certified auditor, was compiled in a clear and transparent manner and
that it was a true and fair presentation of the assets, liabilities, financial position, and profit or
loss of the Triglav Group and Zavarovalnica Triglav d.d. The Supervisory Board also verified the
consolidated Sustainability Report, prepared in accordance with ESRS and the EU Taxonomy
Regulation, ensuring reporting integrity and regulatory compliance.
The Supervisory Board is of the opinion that the Corporate Governance Statement, which is
included in the Annual Report, is appropriate and has no objections to it.
In accordance with the aforementioned findings, the Supervisory Board expresses no objection
to the unmodified opinion of the certified audit firm Deloitte revizija d.o.o., Ljubljana, which
found that in all material respects the consolidated and separate financial statements presented
a true and fair presentation of the financial position of the Triglav Group and Zavarovalnica
Triglav d.d. as at 31 December 2025, their profit or loss, comprehensive income and cash flows
for the year then ended, in accordance with the International Financial Reporting Standards as
approved by the EU.
The Supervisory Board has no comments on the certified auditor's Limited Assurance Report on
the consolidated Sustainability Report for 2025, included in the Annual Report. The auditor
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concluded that nothing has come to their attention that causes them to believe the consolidated
Sustainability Report is not prepared, in all material respects, in accordance with the applicable
legal requirements.
In view of the above, the Supervisory Board approves the Audited Annual Report of the Triglav
Group and Zavarovalnica Triglav d.d. for the Year Ended 31 December 2025.
At its session, the Supervisory Board also discussed the Remuneration Report for 2025, which
was verified by the authorised audit firm Deloitte revizija d.o.o., Ljubljana, and in accordance
with paragraph six of Article 294b of the Companies Act (ZGD-1) issued the auditor’s report
confirming that the Remuneration Report contains all the information required by paragraphs
two and three of Article 294b of the ZGD-1.
8. PROPOSAL FOR THE DISTRIBUTION OF ACCUMUATED PROFIT
At its 2nd/2026 session, the Supervisory Board examined the Management Board's proposal for
the distribution of accumulated profit as at 31 December 2025, which will be subject to a final
decision by the General Meeting of Shareholders of Zavarovalnica Triglav d.d., and approved the
following draft resolution on the distribution of accumulated profit to be proposed by the
Management Board to the General Meeting of Shareholders:
"The accumulated profit totalling EUR 103,646,725.63 as at 31 December 2025 shall be
distributed as follows:
▪ A part of the accumulated profit amounting to EUR 68,205,444.00 shall be distributed for
dividend payments. A dividend in the amount of EUR 3.00 gross per share shall be paid to
the shareholders appearing in the Share Register as at 16 June 2026. By 17 June 2026, the
Company shall ensure funds for the payment of all dividends on the account of KDD –
Centralno klirinška depotna družba d.d., intended to execute the corporate action of paying
out dividends to the shareholders in accordance with the common European standards for
corporate actions.
▪ The distribution of the remaining accumulated profit of EUR 35,441,281.63 shall be decided
on in the coming years."
Andrej Andoljšek
Chairman of the Supervisory Board
Ljubljana, 26 March 2026
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4. Triglav Group strategy and plans
- In line with its vision as an international insurance and financial group, the Triglav Group
has set high strategic ambitions for the 2025–2030 strategy period in terms of business
performance, growth in business volume and greater geographic, product and service
diversification.
- In the first year of the strategy period, very good results were achieved in the
implementation of the strategy.
- The ambitiously defined strategy to 2030 addresses the challenges and opportunities
identified in a rapidly changing business and social environment, and sets out how further
profitable and sustainable growth and development are to be ensured.
4.1 Today's challenges and opportunities
The environment in which the Triglav Group operates is being shaped by rapid economic,
regulatory, technological and social changes. The Group regularly monitors and effectively
manages the most material risks that could affect the achievement of its strategic ambitions,
while also assessing the adequacy of its business model (see Section 10.1.3 Triglav Group's
business model and value chain for further details).
4.1.1 Risks related to the macroeconomic and regulatory environment
In 2025, global economic growth remained moderate and financial market conditions volatile,
also influenced by geopolitical tensions (see Section 7. Macroeconomic environment and market
trends and Section 2.8 Risk management in the Accounting Report). At the same time, the Group
operated within a complex regulatory framework which, in addition to existing regulations (e.g.
Solvency II, IFRSs and the abolition of the former supplemental health insurance system in
Slovenia), also includes new rules in the area of sustainability reporting, digital operational
resilience and the use of artificial intelligence.
The Group's approach to challenges and risk management
The Group manages macroeconomic and market risks primarily through a conservative
investment policy, effective capital management and a robust business model. Investment
portfolios are carefully diversified, with the duration structure of assets and liabilities regularly
aligned. Scenario analyses and stress tests are used to support strategic decision-making and
risk appetite. Liquidity is managed through appropriate reserves and cash flow monitoring, with
particular attention given to investments in alternative funds.
Insurance underwriting, pricing and reinsurance activities are designed to mitigate the impact
of macroeconomic risks on the insurance business. In 2025, reinsurance programmes were also
effective in limiting major losses and supporting the growth of reinsurance and international
activities. The geographical and segmental diversification of operations makes a significant
contribution to resilience. In 2025, the Group achieved strong growth in international insurance
and reinsurance markets and continued to adapt its Health segment offering to the new
regulatory framework in Slovenia and to market opportunities in the wider Adria region.
Regulatory risks are managed through an integrated compliance framework, active dialogue
with supervisory authorities, and regular own risk and solvency assessments (ORSA).
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4.1.2 Climate change and sustainable development
Climate change is increasingly shaping the business environment and risk profile in the
insurance industry, as more frequent and intense extreme weather events are already noticeably
affecting the frequency and severity of insured losses, including in the Group's markets. In
addition to physical risks, the transition to a low-carbon and more efficient economy gives rise
to transition risk. Insurers are expected not only to manage their own climate risks but also to
support the transition through their products, investment strategies and engagement with
stakeholders.
The Group's approach to challenges and risk management
These trends create both risks and opportunities for the Group: they require appropriate pricing,
effective risk accumulation management and reinsurance protection, while also enabling the
development of new insurance and investment solutions. Sustainable development is an
integral part of the Group's strategy to 2030 and is implemented through its ESG ambitions. In
2025, the Group updated its double materiality assessment (DMA) methodology, enhancing its
approach to risk assessment, while continuing to pursue its ESG ambitions across its key areas
(see Section 10. Sustainability report for more information).
4.1.3 Digital transformation and cybersecurity
Digital transformation is a key driver of change in the insurance industry, as clients increasingly
expect simple, fast and personalised digital services. New technologies – including advanced
analytics, artificial intelligence and automation – enable more sophisticated product design, risk
assessment, claims management and client interaction. The wider use of digital technologies
and data also introduces new operational and cyber risks. In addition, regulatory requirements
are becoming more stringent, particularly with the introduction of EU regulations such as the
Digital Operational Resilience Act (DORA), the EU Digital Identity Wallet and the Artificial
Intelligence Act.
The Group's approach to challenges and risk management
In 2025, Triglav continued to integrate digital and artificial intelligence technologies into its
business processes (see Section 4.4 Development activities), while security, reliability and
resilience of information systems remained a strategic priority. The Group is strengthening its
security architecture, incident monitoring and employee training. Its approach to digital
operational resilience is aligned with new EU requirements. Furthermore, the Group is
developing digital competences and ensuring the responsible use of data and artificial
intelligence, with active collaboration across business, IT and risk functions (see Section 11.
Digital Operational Resilience Report for more details).
4.1.4 Demographic and human resource risks
Demographic changes – an ageing population, low birth rates and youth emigration – have a
significant impact on demand for insurance and investment products, as well as on the
availability of talent. There is increasing demand for life, pension and health solutions, while the
labour market faces a shortage of key skills, particularly in actuarial science, risk management,
IT, digital development and data analytics. Rapid digital transformation is further reshaping the
competences required, while employees increasingly expect greater flexibility and development
opportunities; companies that fail to adapt to these trends risk higher staff turnover, lower
engagement and reduced productivity.
29
The Group's approach to challenges and risk management
The Group manages demographic and human resource risks by developing tailored insurance
and investment solutions and enhancing its employer attractiveness. It focuses on attracting,
developing and retaining talent, particularly in key professional areas, and continues to
strengthen its employer brand, youth development and succession planning. Flexible work
arrangements, modernised workspaces and continuous skills development, particularly digital
skills, are supported. In 2025, the Group achieved a record-high ORVI index and maintained its
Family-Friendly Enterprise certificate (see Section 10.3.1 Own workforce and Section 8.5
Investment in own-use real property and equipment for further details).
4.2 Triglav Group Strategy for 2025 - 2030
The upgraded Triglav Group strategy, adopted at year-end 2024, sets ambitious targets to 2030.
Based on the starting point, it aims to double its earnings before tax and significantly increase
its total business volume and the volume of assets under management. In implementing its
strategy, it will continue to pursue its mission of "building a safer future" while strengthening
the Group's profile as an international insurance and financial group.
Mission:
Building a Safer Future
▪ We are client-focused.
▪ We help our partners grow.
▪ We promote employee development.
▪ We are a profitable, stable and safe investment.
Vision:
An international insurance and finance group.
The Triglav Group is the leading insurance and financial group in the Adria
region, strengthening its dominant position in the region.
An international group, further strengthening its identity and visibility.
Revenue from regional and international markets will exceed that of the
Slovenian market.
Values and
beliefs:
Responsiveness, simplicity and reliability are reflected in daily operations.
▪ A group that provides clients a sense of security. A reliable partner that
ensures a simple (clear and understandable steps), fast, predictable
(consistent procedure) and transparent experience.
▪ An agile and efficient organisation that responds quickly to challenges
and adapts to environmental changes. Processes are lean, simple,
technologically advanced and cost-effective.
▪ Committed to fostering a winning and entrepreneurial mindset.
Strategic
activities:
Insurance
Asset management
▪ Non-life
▪ Life
▪ Health
▪ Reinsurance
▪ Investment portfolios of
insurance companies
▪ Mutual funds and discretionary
mandate services
▪ Pension funds
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Triglav Group's strategic ambitions to 2030
▪ Highly profitable operations – value for shareholders
The Triglav Group aims to double its earnings before tax by 2030
compared with the base year, targeting EUR 250–300 million,
while remaining a profitable, stable and safe investment for
investors.
In pursuing these ambitious profit targets, the Group strives for
geographic and product-service diversification of its resources
while consolidating its market position. In the insurance business,
it aims to achieve high profitability, maintaining a combined ratio
below 95% for the Non-Life and Health segments throughout the
strategy period.
The Group's dominant market position in the region allows it to
leverage the economy of scale and achieve greater process
efficiency. Cost-effectiveness will be improved by simplifying and
centralising processes and continuing the digital transformation
of operations.
The Group aims to maintain a high credit rating of "A", affirming
its strong business performance, reliable risk management and
strong capitalisation. The target capital adequacy ratio stands at
200–250% (see Section 9.2.1 Capital management for more
details). Plans include growing earnings per ZVTG share at an
average annual rate of 10% and the book value per share at 8%.
The Group's ambition is to achieve a net return on equity (ROE) of
12–13% by 2030.
In line with the dividend policy (see Section 6. The share and
shareholders of Zavarovalnica Triglav for more information), the
Group plans to distribute approximately EUR 400 million in
dividends to shareholders over this strategy period.
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▪ Above-average growth in markets outside Slovenia
▪ The Triglav Group is strengthening its recognition
as an international insurance and financial
group.
In the Adria region, it maintains a dominant market position while
focusing on improving its position in individual markets across the
region. The objective is for business volume in international
markets to exceed that in Slovenia.
In international markets outside the region, growth opportunities
are pursued through reinsurance activities and new business
models (FOS and MGA).
▪ Ambitious growth in business volume and assets under
management
The Group aims for its business volume to reach EUR 2.5–3.0
billion in 2030, with assets under management exceeding EUR 10
billion.
Ambitious organic growth will be complemented with acquisition
activities, should the right opportunities arise.
▪ An outstanding client experience
Clients and their needs remain at the core of all activities. The goal
is to deliver a consistently high-quality experience, regardless of
the point of contact with the Group. Developing hybrid client
journey processes will be a step toward a fully integrated, multi-
channel user experience.
A diversified offering will be adapted to clients' needs and
expectations, ensuring their well-being and enhancing their
quality of life. Client-specific requirements will be considered,
providing affordable, innovative, simple and comprehensive
insurance and investment solutions.
▪ An agile and efficient organisation
The Group operates as an agile organisation, adapting effectively to challenges and changes,
including technological advancements, evolving client expectations and climate change. This
strengthens the Group's ability to reallocate, upgrade or phase out assets, and adjust its product
and service portfolio. Its activities are focused on further process simplification and improving
cost effectiveness.
The Group also set out its sustainable development ambitions, see Section 10.1.2.1 Strategic
ambitions in sustainable development for more information.
▪ An environment that attracts top talent
The Group brings together engaged, collaborative and entrepreneurial employees, who share
common values and thrive in a creative, dynamic work environment.
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The Group's organisational culture is designed for high effectiveness and is aligned with its
vision as an international group.
The Group's strategic ambitions are supported by numerous strategic initiatives, the most important of
which include:
• Enhancing sales channel efficiency. The Group is developing a hybrid sales model that combines
sales through agents with digital sales channels. The aim is to provide a consistent user
experience while balancing growth and efficiency across sales channels. Advanced segmentation
will be used to deliver more personalised client solutions and to maximise the value of the agent
portfolio by providing appropriate support in advisory services, cross-selling and product
upgrades.
• Further development of the health insurance ecosystem. The Group aims to offer comprehensive
solutions for clients' healthcare needs across all stages of life. The range of products and services
will be expanded by combining health insurance with assistance services and healthcare services,
supported by a digital platform that simplifies services and improves accessibility.
• Internationalisation. The Group is increasing its business volume outside Slovenia. Growth
opportunities in international insurance and reinsurance markets will be leveraged through new
business models (e.g. MGA). The diversity of the employee structure will also be enhanced by
attracting and retaining talent from the global labour market.
• Ongoing digital transformation. The Group will continue simplifying products and processes
while introducing data- and AI-based tools to automate routine tasks and standardise ways of
working. By expanding integrated digital and self-service channels and equipping agents and
partners with better tools, the Group aims to improve the user experience and increase sales
efficiency across its multi-channel network.
• Cost and process optimisation. Efficiency remains a priority. The Group implements optimisation
strategies at both regional and global levels to remain competitive in a demanding environment.
Further simplification of products and processes will continue, including automation and the
implementation of standardised tools and workflows.
4.3 Implementation of the Triglav Group strategy in 2025
Implementation of the ambitious 2025–2030 Group strategy progressed well in the first year of
the strategy period: total business volume increased significantly, reaching EUR 2,565.3 million,
driven primarily by premium growth in the non-life insurance segment and international
reinsurance operations. The Group achieved earnings before tax of EUR 174.1 million, exceeding
the revised mid-year estimate.
A significant step was made towards further internationalisation and geographic diversification
of operations. The Group entered the Italian motor vehicle insurance market in partnership with
Prima Assicurazioni and Ageas Re, increasing the total business volume by EUR 692.9 million in
2025. At the start of its business relationship with the new partner, the Group assessed that on
this basis it would generate a temporarily high business volume in 2025 and forecast that this
would decrease in 2026 to around EUR 400 million, representing up to 20% of Prima
Assicurazioni's insurance portfolio in Italy. In the second half of 2025, a transaction was
completed under which the AXA Group acquired a majority ownership interest in Prima
Assicurazioni. This may affect the future volume of cooperation between the Group and Prima
Assicurazioni in future reporting periods.
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The Group's financial strength and capital adequacy remained within the target range. In 2025,
S&P Global upgraded the Group's credit rating from "A" to "A+", while AM Best reaffirmed the
high credit rating of "A". Both credit ratings carry a stable medium-term outlook.
The Group aimed for the ZVTG share to be a profitable, safe and stable investment for investors.
Based on strong interim results, future outlook, implementation of the dividend policy and
active promotion of the ZVTG share among investors, the ZVTG share liquidity increased
significantly in 2025, with its total return reaching a high 51%. Triglav's market capitalisation
exceeded the EUR 1 billion mark (see Section 6. The share and shareholders of Zavarovalnica
Triglav for more information).
The Group remained focused on the client and their user experience. It further developed its
insurance and asset management offerings while strengthening multichannel and digital
capabilities, including upgraded online and mobile solutions, digital claims reporting, and tools
for remote sales and advisory services. These initiatives support a more convenient and
personalised client experience in insurance underwriting, after-sales services and claims
handling, helping to maintain a high level of client satisfaction, as measured by the NPS index.
The Group continued investing in its organisational culture and employees. It intensified
activities to strengthen its employer brand and employee development, supported by further
training programmes and initiatives promoting a healthy lifestyle and work-life balance.
Through sustainability-oriented business practices, the Group further integrated ESG aspects
into its core insurance and asset management activities. The Sustainable Development Policy
and Sustainable Investment Policy guide the integration of environmental, social and
governance factors into risk underwriting, investment decisions and product design. This
includes products that promote environmental and social characteristics in line with SFDR
requirements. By doing so, the Group aims to create long-term value for clients, employees,
investors and the wider community, while contributing to the transition toward a more
sustainable and resilient economy.
Safe and profitable operations and internationalisation
Profitable operations and credit rating
▪ Earnings before tax: EUR 174.1 million, confirming sustainable profitability growth.
▪ Return on equity (ROE): 13.2%.
▪ The Company's market capitalisation exceeded the EUR 1 billion mark, reaching EUR 1.3 billion.
▪ The ZVTG total return: 51%, accompanied by a significant increase in turnover (Ljubljana Stock
Exchange Prime Market Share of the Year Award). The dividend was paid out in line with the dividend
policy, amounting to EUR 63.7 million, or EUR 2.80 gross per share.
▪ Credit rating: S&P Global Ratings upgraded the Group's rating from "A" to "A+" with a stable outlook.
Growth in business volume
▪ Total business volume: increased by 49% to EUR 2,561.2 million, driven primarily by strong growth in
international insurance and reinsurance markets.
▪ The Group's dominant market position in the Adria region: 20.6%
Internationalisation
▪ The share of business volume outside Slovenia: increased by 17.9 percentage points, reaching 60.3%.
▪ Entry into the Italian motor vehicle insurance market in partnership with Prima Assicurazioni; continued
operations in Greece, Poland, Germany and other insurance markets, as well as in international
reinsurance markets.
Capital adequacy and capital allocation
▪ Prudent implementation of capital management policy and maintenance of capital adequacy within
the target range.
34
An outstanding client experience
Client satisfaction and loyalty
▪ High client satisfaction score with Group services (Net Promoter Score): 77
▪ More than 16% growth in the number of users of the i.triglav digital office in the Company and a 27%
increase in the number of clients who gave their consent for e-services.
Comprehensive and client-tailored services and an omni-channel approach
▪ Multichannel, client-focused sales and after-sales capabilities, enhanced through the development
of hybrid and digital channels, including AI-powered virtual assistants.
Products and services
▪ In Slovenia, the Group upgraded dental insurance products with a stronger focus on prevention and
treatment, and expanded the activities of the Triglav Health Centre, thereby strengthening its health-
related offerings.
▪ The Triglav Direkt motor vehicle insurance represents a step towards digitalisation and a simpler user
experience.
▪ Selected insurance products continue to be transferred to other Group markets. Products are adapted
to local requirements, expanding the Group's product range to clients across the region.
An agile and efficient organisation
Digital transformation
▪ The Group continued integrating digital technologies and artificial intelligence into business
processes to enhance the user experience, automate routine tasks and optimise workflows.
▪ The i.Triglav digital office was upgraded with additional functionalities, including risk assessment,
and the Triglav Asistenca service was expanded to be accessible via Viber and WhatsApp.
▪ The automated and digital claims reporting process, initially implemented at Zavarovalnica Triglav,
has begun to be rolled out to other Group insurance companies, simplifying claims handling and
reducing processing times.
▪ The Triglav Investments mobile application was upgraded to a modern, user-friendly digital
investment platform, offering market news, educational content, financial planning tools, an
enhanced portfolio overview, QR payments, recurring payments and accessibility options. The
number of active users already exceeds 11,000.
Process efficiency and synergies
▪ The Group continued process and cost optimisation projects using centrally supported technologies
and competences, increasing operational efficiency and business scalability.
▪ Zavarovalnica Triglav transferred supplemental voluntary pension insurance business, including the
accumulation phase and the management of associated guarantee funds, to its specialised
subsidiary Triglav, pokojninska družba, thereby strengthening operational focus and efficiency.
An environment that attracts top talent
Living the Triglav Group's values
▪ The Group fosters a culture based on responsibility, client focus and sustainable development.
Activities described in Section 10. Sustainability Report support responsible conduct towards clients,
employees and the wider community.
Employee development and satisfaction
▪ Zavarovalnica Triglav successfully retained the Family-Friendly Enterprise certificate, strengthening
its employer brand and supporting talent attraction and retention.
▪ A record-high ORVI index confirms strong employee satisfaction and motivation.
▪ Benefits and development activities are regularly adapted to enhance employee health, satisfaction
and engagement.
▪ Special focus was placed on the professional development of young talent and succession planning
for key roles, including training in digital competences, data and artificial intelligence, sales, client
relations and leadership skills.
Delivering on ESG strategic ambitions
▪ An increased share of ESG-compliant bonds in the investment portfolio to 15 %.
▪ A further reduction of the Group's environmental footprint through expanded paperless and digital
operations, implementation of energy efficiency and renovation projects, the increased use of hybrid
and electric vehicles, and the increased use of renewable energy sources.
35
4.4 Development activities
In 2025, the Triglav Group remained consistently focused on clients and their needs and
expectations. It continued its digital transformation, the automation of business processes
supported by artificial intelligence, the adaptation of insurance products and the strengthening
of high-quality business partnerships. Products were adapted to new risks and regulatory
changes in the field of health insurance and pensions. The client experience is monitored using
the NPS methodology across all touchpoints, and corrective measures are implemented where
necessary.
In non-life insurance, a new insurance underwriting programme was implemented and
extended to roadworthiness test providers and vehicle dealers, while simplifying the
underwriting process through integration into partners' programmes. In the corporate account
segment, the Group strengthened the development of comprehensive solutions for managing
complex business risks. Advanced analytical tools and data models were implemented to
improve risk assessment and enable more precise determination of premiums and capacities.
This has enhanced competitiveness and provided a higher level of support to corporate clients
in managing their risks. Processes for underwriting complex policies were also upgraded,
including automation of data verification from business registers, geolocation databases and
specialised technical sources. Business partners were offered digital access to portfolio status,
open claims and other relevant client data.
In non-life insurance claims, intensive development of tools and processes for claims reporting
and settlement continued. The Group's objective is to ensure a high level of client satisfaction
based on simplicity, efficiency and transparency of procedures. Through process optimisation
and automation, the Group pursues objectives of cost effectiveness, balancing employee
workload and shortening claims settlement times. By increasing the share of digital claims
reporting, conditions are created for further optimisation and continuous improvement of
service quality. The integration of artificial intelligence into the regular claims settlement
processes continues. New solutions are developed in a way that enables their easy transferability
across individual business areas and Group companies.
In life insurance, products were developed to provide clients with comprehensive life protection,
greater flexibility and easier usability. In the market of Bosnia and Herzegovina, the life
insurance underwriting process was fully digitalised, with a major innovation being the
introduction of automatic underwriting. In North Macedonia, online services were enhanced to
facilitate collaboration with financial partners, the loyalty programme was upgraded, a new
combined unit-linked insurance product for borrowers with a decreasing sum insured and the
option to save in various funds was launched through the banking sales network, and mortgage
insurance was upgraded. With regard to pension annuities from SVPI, significant innovations
were implemented, allowing clients more freedom in managing their accumulated funds.
Clients can now more easily cover costs associated with transitioning into a new stage of life, as
the innovations provide greater choice, flexibility and financial security upon retirement.
In health insurance, the Group develops comprehensive solutions to meet clients' healthcare
needs at all stages of life. An outstanding user experience is achieved through the ongoing
integration of advanced technologies into key business processes. The Healthcare ecosystem is
expanded by onboarding new partners, enhancing existing partnerships, and broadening the
range of assistance and healthcare services. In Croatia, a new tool was introduced for creating
personalised product offers, while in Montenegro, the Lovčen Zdravje application was launched,
allowing clients to monitor the utilisation of their coverage limits. Within the Group, Triglav Med
operates as a specialised company delivering healthcare and assistance services. In developing
health insurance, the Group collaborates with numerous leading physicians and specialists
36
across various fields, while continuously strengthening partnerships with healthcare providers
in Slovenia and abroad.
In 2025, the Group implemented centralised administration for pension insurance within
specialised companies. This strengthens the long-term stability of operations, improves the
quality of fund management and ensures cost effectiveness for clients.
The internationalisation of operations
In mid-2025, the Group entered the Italian market through the Prima insurance agency
company, offering clients motor vehicle insurance and related assistance services. In Poland,
activities in motor vehicle insurance are conducted through HPI GMA SA, in which the Group,
together with the EBRD, also made an equity investment in 2025 (see Section 2.4 Significant
events in 2025). Operations in Greece have been successful for several years. In 2025, the Group
joined the motor vehicle liability claims settlement system operating in the Greek market, which
enhanced Group's visibility and reputation.
Development of insurance products and services
In non-life insurance, the Group updated the insurance terms and conditions for motor vehicle
insurance and launched the Triglav direkt digital product, marking an important step towards
digitalisation and a simpler user experience. Home and personal protection insurance was
upgraded, with basic legal protection included as a built-in feature under personal liability
coverage. Special attention was given to the development of integrated solutions, notably the
introduction of cyber protection insurance for bank clients. Pet insurance was redesigned and
supported by a full range of ancillary services. Particular emphasis was placed on upgrading
products for industrial and commercial clients, including expanded coverage for business
interruption, cyber risks, liability programmes, and specialised insurance for the energy, logistics
and manufacturing sectors. In Serbia, a glasses insurance product was launched in partnership
with Diopta, the country's largest retailer.
Life insurance products were upgraded to offer clients greater flexibility, including accelerated
pension annuities and the Varnost uspešnih (Security for the Successful) insurance, designed for
entrepreneurs and small businesses.
The key innovation in health insurance upgrades was the insurer's obligation to secure
appointments within the prescribed timeframe at network providers. Due to changes in the
scope of compulsory health insurance coverage in dental care, the content of Zobje (Teeth),
Zobje+ (Teeth+) and Zobje kolektivno (Teeth group) health insurance products was redesigned
and enhanced. Within Triglav medicinski center, a paediatrics clinic was opened alongside the
family medicine clinic. The service offering was further expanded to include a reference clinic
and self-pay services, such as acupuncture, nutritional counselling, psychotherapy and
vaccination.
Digital transformation
To optimise the utilisation and cost-efficiency of IT equipment and enhance security,
centralisation of IT infrastructure continued in 2025. To further improve the efficiency of the
digital transformation, IT functions were organisationally consolidated across the Group.
The i.triglav digital platform recorded promising growth in user numbers in 2025, and its use
expanded to the markets of the Group subsidiaries in the Adria region.
37
The DRAJV application of Zavarovalnica Triglav celebrated its tenth anniversary, reaching a
milestone of two billion kilometres safely driven. With over 200,000 downloads and more than
65,000 monthly active users, it significantly contributes to safer driving. On this anniversary, the
application was upgraded, reinforcing its leading role in digital insurance solutions.
Foundations for the use of artificial intelligence were established and are being implemented
through projects such as the Triglav Direkt, which automates data collection for motor vehicle
insurance. Automation of requests forwarded to back-office services has optimised client
experience processes, directly enhancing operational efficiency. The Group is focusing its
development activities on advanced solutions for automatically generating sales opportunities
and contacting technical service providers, further strengthening proactive market engagement.
The deployment of additional robotic process automation improved the processing of business
data, including verification of SEPA (Single Euro Payments Area) direct debit mandates,
communication with external institutions, and the termination of non-life insurance at clients'
request. Health insurance claims recovery was brought in-house, and a payment option via Flik
was introduced, increasing efficiency, control and user experience.
Through the Data Management Strategy, a foundation was laid for the gradual transformation
of Zavarovalnica Triglav into a data-driven organisation, where data become a strategic factor
for business decisions, efficiency and innovation.
Asset management activity
Triglav Skladi was renamed Triglav Investments, marking the start of a broader and more
comprehensive asset management offering, extending beyond mutual funds and serving as the
Group's central platform for asset management.
A key step in this direction was the centralisation of pension portfolio management, creating a
more transparent, harmonised and efficient management process. The company continues to
advance digitalisation, including significant upgrades to back-office processes and further
development of its mobile application, providing users with a modern, fast and intuitive
experience.
Brand development
The Group continued to strengthen its reputation as one of the most respected brands in the
industry. In 2025, a new corporate visual identity was launched, applying to all Group companies.
This initiative aims to achieve consistency, particularly visual consistency, across all
communication channels and markets where the brand is present.
In 2025, the sub-brand Triglav Med was launched, dedicated to medical and healthcare services.
With the renaming of Triglav Skladi to Triglav Investments, a new brand was also registered for
the Group's asset management pillar, which is now present in the market of Bosnia and
Herzegovina. A new product brand, Direkt, was developed for the new digital product, offering
an affordable, simple and fully digital user experience. The product's identity and visual
guidelines were specifically designed to highlight its differentiation from the parent brand and
to create a distinct user experience.
At the employer brand level, efforts focused on strengthening the brand through a multichannel
approach and initiatives targeting current and future employees. The Group participated in
study challenges, mentoring programmes and career events, promoting the insurance sector as
a modern and development-oriented industry. Activities continued through the Triglav
International Business Academy (TIBA) programme, designed to develop promising employees,
38
complemented by the TIBA Show series, where employees presented company values and
culture in an engaging way. Social media presence also played an important role in enhancing
visibility and attractiveness.
The Group's work has received external recognition: in the MojeDelo.com survey, the Triglav
Group was once again ranked among the most reputable employers and placed first in the
insurance sector. At the Employer Brand Awards Adria 2025, the Group received three awards,
confirming its success in fostering an engaged, productive and supportive working environment,
and reinforcing its reputation as an employer prioritising teamwork, transparent dialogue, agile
ways of working and collaboration. All these activities hold strategic significance for attracting
and retaining talent, creating an environment that combines professional development with a
focus on people.
4.5 Implementation of the Triglav Group's business plans in 2025
The Triglav Group achieved earnings before tax of EUR 174.1 million, exceeding both the original
target (EUR 130–150 million) and the upwardly revised mid-year profit guidance (EUR 140–160
million or around EUR 160 million). See Section 8. Operations of the Triglav Group and
Zavarovalnica Triglav for further information.
Total business volume amounted to EUR 2.6 billion; excluding the new business in the Italian
market through the partner Prima, i.e. from regular operations only, it reached EUR 1.9 billion.
The original estimate was around EUR 1.8 billion; following the new business in Italy, the
forecast was revised mid-year to approximately one third above the original plan. Compared
with the previous year, total business volume was 49% higher, primarily driven by strong growth
in premium written in the international market. Growth was achieved across most insurance
markets, with the exception of the Bosnia and Herzegovina market.
The Group's combined ratio for the Non-Life and Health segments stood at a favourable 93.2%,
compared with a planned target of around 95%. It improved by 0.4 percentage points year-on-
year, due to a better expense ratio. See Section 8. Operations of the Triglav Group and
Zavarovalnica Triglav for more information.
In June 2025, S&P Global upgraded the Group's financial strength and issuer credit rating from
"A" to "A+", while AM Best reaffirmed the "A" credit rating in October 2025. Both credit ratings
have a stable medium-term outlook. Achieving an "A" credit rating ensures an appropriate
competitive position of the Group in insurance, reinsurance and financial markets as it confirms
its financial strength, stability and sound performance. See Section 6.6 Credit rating of the Triglav
Group and Zavarovalnica Triglav for more information.
4.6 The Triglav Group's plans for 2026
The Group's plans for 2026 represent the next step in the implementation of the Triglav Group
Strategy to 2030, which sets out ambitious goals for profitable, safe and sustainability-oriented
operations (see Section 4.2 Triglav Group Strategy 2025–2030 for more information).
The Group assesses that its operations will be most significantly affected by macroeconomic
conditions, financial market developments, reinsurance cover, market situation and the
development potential of its markets. Taking the expected conditions into account, the Group's
earnings before tax are projected to reach EUR 170–190 million.
39
In the insurance business, the Group aims to achieve a high level of profitability and expects the
combined ratio for the Non-Life and Health segments to reach approximately 95% in 2026.
The Group will expand its business volume, while diversifying and growing in markets outside
Slovenia, in alignment with strategic ambitions. The Group's total business volume is projected
to exceed EUR 2.4 billion in 2026. Ambitious organic growth will be complemented by prudent
acquisition activities, should the right opportunities arise.
The aim is to maintain the high "A+" credit rating, reaffirming sound risk management and
capital adequacy, while striving to remain a stable, safe and profitable investment for investors.
40
5. Corporate Governance Statement
- The three-line system, comprising corporate governance and the management of key
functions and business lines, constitutes the foundation of effective management and
oversight of subsidiaries.
- Ivica Vulić was appointed as a Management Board member – Worker Director for a five-year
term of office.
- Andrej Andoljšek was reappointed as a Supervisory Board Member – shareholder
representative, and Barbara Cerovšek Zupančič was appointed as a new Supervisory Board
Member – shareholder representative.
- Rudi Lipovec was appointed as a new Supervisory Board member – employee representative.
5.1 Governance policy
Zavarovalnica Triglav's governance system plays the main role in the implementation of the
business strategy and effective risk management on which it is based. The main governance
guidelines take into account the set long-term objectives. They are defined in the Governance
System and Policy of Zavarovalnica Triglav d.d., which is adopted by the Management Board and
the Supervisory Board. It is published on SEOnet, the Ljubljana Stock Exchange information
system, and on the Company's website (www.triglav.eu).
5.2 Statement of compliance with the Slovenian Corporate Governance Code
In its operations, Zavarovalnica Triglav abides by the Slovenian Corporate Governance Code
(hereinafter: the Code), which was adopted on 2 December 2024. The Code is published on the
Ljubljana Stock Exchange's website in Slovenian and English. Zavarovalnica Triglav's statement
of compliance with the Corporate Governance Code for the period from 1 January 2025 to the
day of its publication in 2026 is available on SEOnet and Zavarovalnica Triglav's official website.
Zavarovalnica Triglav adheres to the provisions of the Code. For well-grounded reasons, the
Company deviated from or did not comply with the following provisions of the Code:
▪ Point 5.6, which refers to an external assessment of the appropriateness of the Corporate
Governance Code by an independent institution:
Zavarovalnica Triglav, as a regulated entity under the supervision of the Slovenian Insurance
Supervision Agency, does not submit the Corporate Governance Statement for external
assessment by an independent institution, as its adequacy is ensured through the
company’s internal procedures, governance system and internal control framework.
▪ Point 21.6, which refers to the prior approval of the Supervisory Board before the appointment
of the members of the Management Board to the management or supervisory bodies in other
companies:
Pursuant to the resolution of the Supervisory Board, Management Board members do not
require the prior approval of the Supervisory Board for their appointment to the
management or supervisory bodies of Zavarovalnica Triglav's direct and indirect
subsidiaries and associates. However, the Management Board members promptly inform
the Supervisory Board in writing about their appointment in accordance with point 1 of
paragraph two of Article 62 of the Insurance Act (ZZavar-1).
▪ Paragraph three of point A2 of Appendix A to the Code, which provides, among others, that
the chairman of the remuneration committee is not the chairman of the supervisory board:
The Chair of the Appointment and Remuneration Committee of the Supervisory Board of
Zavarovalnica Triglav is also the Chairperson of the Supervisory Board. The responsibilities
41
of the Appointment and Remuneration Committee are closely linked to the Supervisory
Board’s representation on behalf and for the account of the Company in dealings with the
Management Board, making it appropriate for the Chairperson of the Supervisory Board to
serve as Chair of the Appointment and Remuneration Committee.
In its operations, the Company abides by the principles of the Insurance Code, available on the
website of the Slovenian Insurance Association (www.zav-zdruzenje.si/en/).
The Company also has its own code, published on its website, which defines its fundamental
values and business principles in order to achieve its business objectives, strategic guidelines and
competitive advantages in a fair and transparent manner and in compliance with the law and
ethics.
The Statement of compliance with the Slovenian Corporate Governance Code is available both
on SEOnet and the Company's official website.
5.3 Management bodies of Zavarovalnica Triglav
The Company has a two-tier governance system in place. Its governance bodies are as follows:
General Meeting of Shareholders, Management Board and Supervisory Board. They operate in
compliance with the primary and secondary legislation, the Articles of Association of
Zavarovalnica Triglav d.d. (hereinafter: the Articles of Association) and adopted rules of
procedure. Zavarovalnica Triglav's Articles of Association are published on its official website.
The most important documents (Articles of Association of Zavarovalnica Triglav d.d., the
Governance System and Policy of Zavarovalnica Triglav d.d. and similar) defining the governance,
controls and operating procedures are published at https://www.triglav.eu/en/about-
us/zavarovalnica-triglav/documents.
Two-tier governance of Zavarovalnica Triglav
5.3.1 General Meeting of Shareholders
The shareholders of Zavarovalnica Triglav exercise their rights at the General Meeting of
Shareholders, which is convened at least once a year, by the end of August at the latest. It may
also be convened in other circumstances provided by law and the Articles of Association, and
when it is in the interest of the Company.
The powers and operation of the General Meeting of Shareholders are set out in the Companies
Act and the Articles of Association.
42
The holder of a Zavarovalnica Triglav share has the right to:
▪ one vote at the General Meeting of Shareholders,
▪ proportional dividends from the profit intended for the dividend payment and
▪ a proportional share from the remaining bankruptcy or liquidation estate in the event of
bankruptcy or liquidation.
All shareholders who are entered in the share register managed by KDD – Centralno klirinška
depotna družba d.d. not later than by the end of the seventh day before the date of the General
Meeting of Shareholders have the right to attend the General Meeting. They may exercise their
voting right provided that they register their attendance not later than by the end of the fourth
day before the date of the General Meeting of Shareholders.
The rights and obligations attached to the shares as well as the notes on the restriction of
transfer of shares and on reaching a qualifying holding are described in Section 6.2 Equity. See
the Insurance Act for further details.
In accordance with the Financial Instruments Market Act, the following three shareholders of
Zavarovalnica Triglav held a qualifying holding as at 31 December 2025:
▪ Zavod za pokojninsko in invalidsko zavarovanje Slovenije (Institute of Pension and Invalidity
Insurance of Slovenia; hereinafter: ZPIZ) is the direct holder of 7,836,628 shares or 34.47%
of the Company's share capital. Its stake in 2025 remained unchanged. On behalf and for
the account of ZPIZ, the shareholder's rights are exercised by Slovenski državni holding d.d.
(hereinafter: SDH).
▪ SDH is the direct holder of 6,386,644 shares or 28.09% of the Company's share capital. Its
stake remained unchanged in 2025.
▪ Erste Group Bank AG - a fiduciary account, Vienna, holds 1,910,782 shares or 8.40% of the
Company's share capital, up 1.61 percentage points on the previous year.
According to the data available, as at the reporting date Zavarovalnica Triglav had no other
shareholders whose interests exceeded 5.00% of the share capital, nor any issued securities that
would grant their holders special control rights.
General Meeting of Shareholders in 2025
In 2025, the General Meeting of Shareholders of Zavarovalnica Triglav convened once, at the
50th General Meeting held on 3 June 2025. The total number of shares and voting rights
represented was 17,347,858 or 76.53% of all shares. The shareholders took note of the following
documents:
▪ Annual Report of the Triglav Group and Zavarovalnica Triglav d.d. for 2024, including the
independent auditor's report;
▪ Annual Internal Audit Report for 2024;
▪ Report of the Supervisory Board of Zavarovalnica Triglav d.d. on the Verification of the
Annual Report of the Triglav Group and Zavarovalnica Triglav d.d. for 2024;
▪ Opinion given by the Supervisory Board on the Annual Internal Audit Report for 2024.
The General Meeting of Shareholders approved the Remuneration Policy of Zavarovalnica Triglav
d.d. for 2024.
The shareholders adopted a resolution on the following distribution of the accumulated profit
of EUR 109,430,652.82 as at 31 December 2024:
▪ A part of accumulated profit in the amount of EUR 63,658,414.40 is to be allocated for
dividend payments. The dividend of EUR 2.80 gross per share will be paid to the shareholders
43
entered in the share register as at 17 June 2025. As at 18 June 2025, the Company provided
funds for the payment of all dividends to the account of KDD – Centralno klirinška depotna
družba d.d.
▪ The distribution of the remaining accumulated profit of EUR 45,772,238.42 will be decided
in the next few years.
The shareholders granted a discharge for the 2024 financial year to both the Management Board
and the Supervisory Board of Zavarovalnica Triglav.
Following the expiry of the terms of office of Andrej Andoljšek and Tomaž Benčina, Andrej
Andoljšek was reappointed as a Supervisory Board Member – shareholder representative, and
Barbara Cerovšek Zupančič was appointed as a new Supervisory Board Member – shareholder
representative. The General Meeting of Shareholders also took note of the expiry of the terms of
office of two Supervisory Board members – employee representatives, following their
resignation.
The General Meeting of Shareholders reappointed Deloitte revizija d.o.o. as the auditor for the
2025, 2026, 2027 and 2028 financial years.
The shareholders approved the spin-off of the entire supplemental voluntary pension insurance
(SVPI) business, along with the management of Skupina kritnih skladov Triglav PDPZ (both in the
accumulation phase), from Zavarovalnica Triglav d.d. to Triglav, pokojninska družba d.d.
5.3.2 Management Board
The Management Board manages and governs the Company independently and at its own
responsibility, and presents and represents the Company without limitations. In legal
transactions, the Company is always jointly presented and represented by two members of the
Management Board, one of whom is its President.
In line with the Solvency II Directive, all persons who manage an insurance undertaking must
have adequate professional qualifications (fit) and be appropriate to perform this function, i.e.
be of good reputation and integrity (proper). The fit and proper assessment of the Management
Board members is carried out based on national legislation and internal regulations.
Any person fulfilling the requirements stipulated by the Insurance Act, the Companies Act and
the applicable documents of the Company may be appointed to the Management Board as its
President or member. The fit and proper criteria applying to individual Management Board
members and the Management Board as a collective body are clearly defined in the Fit and
Proper Policy for the Management and Supervisory Board Members of Zavarovalnica Triglav d.d.,
which sets out the fit and proper assessment procedure for Management Board members to be
performed before the appointment, periodically, extraordinarily or after the appointment of an
individual Management Board member. With respect to the latter, the Supervisory Board takes
into account the diversity of knowledge and competences, which not only allow comprehensive
functioning of the Management Board, but also contribute to an appropriate variety of skills,
knowledge and experience for professional management of the Company. The members are
required to together possess the relevant knowledge and experience relating to insurance and
financial markets, the business strategy and business models, governance systems, financial and
actuarial analyses, risk management, and the regulatory and legal environment in which the
Company operates. In the latest revision of the Fit and Proper Policy for Management and
Supervisory Board Members of Zavarovalnica Triglav d.d. in March 2025, the fit criterion
regarding in-depth knowledge and experience in regulatory and other legal requirements was
expanded to include knowledge and experience in sustainability reporting, cybersecurity and
44
resilience, business continuity, tax reporting, business intelligence, artificial intelligence and ICT
systems. The financial strength of a candidate was added to the proper criterion as a factor that
significantly affects their ability to act independently and helps mitigate the risk of conflicts of
interest.
In accordance with the Fit and Proper Policy for Management and Supervisory Board Members
of Zavarovalnica Triglav d.d., a preliminary fit and proper assessment was conducted by the
Appointment and Remuneration Committee and the Supervisory Board. In 2025 Ivica Vulić was
found fit and proper to serve as a Management Board member. The fit and proper assessment
of the Management Board as a collective body, taking into account Ivica Vulić as a candidate,
indicates that the Management Board as a whole – comprising Andrej Slapar, Uroš Ivanc, Tadej
Čoroli, Marica Makoter, Blaž Jakič, and Ivica Vulić – is fit and proper to exercise prudent and
diligent management of Zavarovalnica Triglav d.d.
A periodic fit and proper assessment was conducted in 2025 for Management Board members
Andrej Slapar, Marica Makoter, Blaž Jakič, Tadej Čoroli and Uroš Ivanc, as well as for the
Management Board as a collective body. The assessment concluded that the individual
Management Board members continue to be fit and proper for their positions, and that the
Management Board as a collective body is fit and proper to exercise prudent and diligent
management of the Company.
The appointment of each Management Board member also takes into account the Diversity
Policy for the Members of Management and Supervisory Bodies of Zavarovalnica Triglav
(hereinafter: the Diversity Policy), which was amended in 2025 in line with amendments to the
Companies Act – ZGD-1M. The Diversity Policy outlines the Company's commitment to
considering various aspects of diversity in relation to representation on the Management Board
and the Supervisory Board (e.g. gender, age, professional competences, continuity in the
composition of the body, and other personal characteristics relevant to the Company given its
nature and attributes). It defines the objectives, holders, implementation mechanisms and the
reporting of results achieved under the Diversity Policy during the reporting period. In addition
to complementarity and diversity in the Management Board and Supervisory Board, including a
range of qualifications, experience and knowledge, the Diversity Policy aims to ensure gender
balance and representation of different demographic groups. A provision was added stating
that, prior to the commencement of any selection procedure, the Supervisory Board will
establish clear, neutral and unambiguous criteria and requirements for the appointment of a
Management Board or Supervisory Board member, which will be applied throughout the
selection process for filling any vacant position. Also included is the obligation for the Works
Council, when appointing employee representatives to supervisory and management bodies
under the law governing employee participation in management, to ensure that at least 33% of
its representatives belong to the under-represented gender, unless no eligible person of that
gender is available at the time of appointment. The objective of gender representation in both
the management body and the supervisory body is explicitly set, so that the members of the
Management Board and the Supervisory Board together include at least 33% of the
under-represented gender (gender representation ratio). In 2025, the gender representation
target for the members of the Management Board and the Supervisory Board was achieved.
Procedures are also established for situations in which the Company does not achieve the
prescribed gender balance. Specifically, if multiple candidates meet the criteria and
requirements of the selection procedure for the appointment of Management Board or
Supervisory Board members equally, preference must be given to the candidate of the under-
represented gender. Exceptions may apply in objectively justified cases, for example, to comply
with the Diversity Policy based on other personal circumstances, in which case preference may
be given to a candidate of the opposite gender, provided that the decision is specifically justified.
45
Composition and appointment of the Management Board
In accordance with the Company's Articles of Association, the Management Board may have no
less than three and no more than six members, one of whom one is the president. The number
of the Management Board members, their powers, the manner of representation and
presentation and the transfer of the Management Board's authorisations are determined by the
Supervisory Board in the Management Board Rules.
The Management Board is appointed by the Supervisory Board. The term of office of individual
Management Board members is up to five years, with the possibility of reappointment without
limitation. Zavarovalnica Triglav has one Worker Director, who is a member of the Management
Board.
The appointment or recall of an individual member or all members of the Management Board is
proposed to the Supervisory Board by the President of the Management Board. Any individual
member or President of the Management Board may be dismissed by the Supervisory Board if
legal grounds for their dismissal have been established.
On 24 September 2025, the Supervisory Board, on a proposal from the Works Council, appointed
Ivica Vulić as a Management Board member – Worker Director. He was appointed for a five-year
term, with the appointment taking effect upon receipt of authorisation from the Slovenian
Insurance Supervision Agency to perform the function of a Management Board member.
5.3.2.1 Management Board's powers to increase the share capital
In accordance with the Company's Articles of Association, the Management Board is authorised
to increase the share capital of Zavarovalnica Triglav by up to EUR 14,740,278.36 through new
shares issued for cash contributions within five years of 28 May 2021. The issue of new shares,
the amount of capital increase, the rights attached to the new shares and the conditions for
issuing new shares are decided upon by the Company's Management Board with the consent of
the Supervisory Board. Following a share capital increase, the Supervisory Board is authorised to
amend the Company's Articles of Association.
46
5.3.2.2 Presentation of the Management Board, its functioning and powers
Composition of the Management Board in 2025
Name and
surname
Function
Area of work in the Management Board
(as at 31 December 2025)
Start of term
of office (the
first)
End of term
of office
Gender
Nationality
Year of
birth
Education
Professional profile
Membership in the supervisory and/or
management bodies of other companies
Andrej Slapar
President
Manages and directs the work of the Management
Board and Internal Audit Department (a head office
support department). In charge of Corporate Accounts
Division, Non-Life Insurance Division, Corporate and
Legal Affairs Division, and Health Insurance Division.
Also responsible for arbitration and Nuclear Pool, as well
as for the drawing up and implementation of the
strategy of Zavarovalnica Triglav and the Triglav Group.
22 May 2013
13 November
2029
Male
Slovenian
1972
LL.B.
Management, strategic
management,
commercial law,
insurance and
reinsurance, actuarial
science
Uroš Ivanc
Member
In charge of Finance, Accounting and Controlling
Division, Triglav Group Subsidiary Management Division
and two head office support departments – Investment
Department and Actuarial Affairs Department. Also
responsible for mergers and acquisitions (M&A),
investor relations (IR) and relations with credit rating
agencies.
14 July 2014
16 July 2029
Male
Slovenian
1975
MSc in
Business and
Organisation
Management and
organisation, strategic
management, insurance,
financial management,
financial markets and
analyses, asset
management, actuarial
analyses and risk
management
Trigal, upravljanje naložb in svetovalne
storitve d.o.o.*
Triglav INT d.o.o.
Tadej Čoroli
Member
In charge of Non-Life Insurance Claims Division,
Insurance Sales Division and International Operations
Division.
29 July 2014
31 July 2029
Male
Slovenian
1975
LL.M.
Management, strategic
management,
commercial law,
insurance, marketing
Pozavarovalnica Triglav Re d.d.
Triglav, Upravljanje nepremičnin d.o.o.
Marica Makoter
Member and
Worker
Director
Represents the workers' interests as set out in the
Worker Participation in Management Act. In charge of
Back Office Division, Human Resource Management
Division, Marketing and Corporate Communications and
Client Experience Division, and Process, General Affairs
and Project Management Division. Also responsible for
Compliance Office (a head office support department).
21 December
2011
23 December
2026
Female
Slovenian
1972
LL.B.
Management, strategic
management,
commercial law,
insurance, human
resources and
organisation, worker
representation
Triglav Investments d.o.o.
Blaž Jakič
Member
In charge of Life Insurance Division, IT Division and two
head office support departments – Risk Management
Department and Outward Reinsurance Department.
Responsible for bancassurance, the environmental,
money laundering prevention, and environmental,
social and corporate sustainable development (ESG)
activities.
2 March 2023
2 March 2028
Male
Slovenian
1982
BSc in
Economics
Insurance, finance,
accounting, business
strategy and business
models, governance
systems, actuarial
analyses, risk
management
Triglav, pokojninska družba d.d.
Triglav Investments d.o.o.
Diagnostični center Bled d.o.o.
* A member of the company's advisory board.
Andrej Slapar assumed the position of President of the Management Board twelve years ago; in 2025, the members of the Management Board
collectively held their positions for an average of 9.75 years.
47
5.3.3 Supervisory Board
The Company's conduct of business is supervised by the Supervisory Board. In line with the
Articles of Association, the Supervisory Board is composed of nine members: six shareholder
representatives and three employee representatives. As at 31 December 2025, it consisted of
seven members, comprising six shareholder representatives and one employee representative.
The term of office of the Supervisory Board members is four years, and they can be re-elected
without a term limit.
Shareholder representatives are elected by the General Meeting of Shareholders and employee
representatives by the Company's Works Council. The Chairperson and Vice Chairperson of the
Supervisory Board are elected from among its members representing shareholders. The
appointment and dismissal of the Supervisory Board members is made in accordance with the
applicable legislation and Company regulations. The General Meeting of Shareholders may
dismiss any elected Supervisory Board member before the expiry of their term of office, while
each Supervisory Board member may resign from their position under the conditions and in the
manner laid down by the Articles of Association.
The term of office of the Supervisory Board members – shareholder representatives, Andrej
Andoljšek and Tomaž Benčina, expired on 14 June 2025. The General Meeting of Shareholders
reappointed Andrej Andoljšek and Barbara Cerovšek Zupančič as new Supervisory Board
members – shareholder representatives for a four-year term of office, commencing on 15 June
2025. Janja Strmljan Čevnja, a Supervisory Board member – employee representative, resigned
with effect from 13 March 2025, and Aleš Košiček, also a Supervisory Board member – employee
representative, resigned with effect from 25 March 2025. The Works Council of Zavarovalnica
Triglav appointed Rudi Lipovec to the Supervisory Board as an employee representative for a
four-year term of office, commencing on 7 November 2025.
According to the Solvency II Directive requirements, the Supervisory Board members must have
adequate professional qualifications (fit) and be appropriate to perform this function, i.e. be of
good reputation and integrity (proper). Their fit and proper assessment is carried out based on
national legislation and internal regulations, especially the Fit and Proper Policy.
Fit and proper assessment is made before the appointment, periodically, extraordinarily or after
the appointment of an individual Supervisory Board member. In line with this policy, a fit and
proper assessment of the candidates for Supervisory Board members – shareholder
representatives and of the Supervisory Board as a collective body, taking into account the
candidates assessed, was carried out before the appointment of new members also in 2025. The
two Supervisory Board members appointed in 2025 as shareholder representatives, Andrej
Andoljšek and Barbara Cerovšek Zupančič, were assessed as fit and proper to perform their
functions.
In October 2025, a periodic fit and proper assessment was conducted for Supervisory Board
members who had not previously been assessed during the year, as well as for the Supervisory
Board as a collective body, comprising Andrej Andoljšek, Barbara Cerovšek Zupančič, Monica
Cramér Manhem, Rok Ponikvar, Barbara Nose and Tim Umberger. All individual members and
the Supervisory Board as a collective body were assessed as fit and proper.
In December 2025, a preliminary assessment was conducted for Rudi Lipovec, candidate for
Supervisory Board member – employee representative, as well as for the Supervisory Board as a
collective body, with the consideration of Rudi Lipovec as a Supervisory Board member –
employee representative.
48
In addition to Supervisory Board members, the fitness and propriety of external members of
Supervisory Board committees, including the independent expert on the Audit Committee
qualified in accounting and auditing, are assessed in accordance with the Fit and Proper Policy
for Management and Supervisory Board Members of Zavarovalnica Triglav. Accordingly, a
periodic fit and proper assessment of the external Audit Committee member, Katarina Sitar
Šuštar, an independent expert qualified in accounting or auditing, was carried out in 2025, and
she was assessed as fit and proper to perform her function. Furthermore, for the first time, a fit
and proper assessment was conducted for candidates for external members of the Risk
Committee of the Supervisory Board. Jure Vehovec and Jörgen Olsen were assessed as fit and
proper to serve as independent members of the Risk Committee.
In assessing its composition and performance in accordance with the Insurance Act and the
Companies Act, the Supervisory Board takes into account that all members possess the relevant
knowledge, skills and experience relating to insurance and financial markets, the business
strategy and business models, governance systems, financial and actuarial analyses, risk
management, and the regulatory and legal environment in which the Company operates. In
addition, new areas of in-depth knowledge and experience were added to the fit criterion in
2025, including sustainability reporting, cybersecurity and resilience, business continuity, tax
reporting, business intelligence, artificial intelligence and ICT systems, and any other
requirements set by competent authorities. The financial strength of a candidate was added to
the proper criterion as a factor that significantly affects their ability to act independently and
helps mitigate the risk of conflicts of interest. If more than one candidate meets the fit and
proper criteria, the provisions of the Diversity Policy are applied, taking into account various
aspects of diversity (e.g. gender, age, professional competences, continuity in the composition
of the body, and other personal characteristics relevant to the Company given its nature and
attributes). The goal is to ensure complementarity and diversity in the Supervisory Board by
taking into account qualifications, experience and knowledge defined in the Fit and Proper Policy
for the Management and Supervisory Board Members of Zavarovalnica Triglav d.d., a balanced
representation of both genders and representation of different demographic groups. This
enables prudent and careful supervision of the Company, thereby achieving strategic objectives
and ensuring long-term values for all key stakeholders. Prior to the commencement of any
selection procedure, the Supervisory Board establishes clear, neutral and unambiguous criteria
and requirements for the appointment of a Supervisory Board member, which must be applied
throughout the selection process for filling any vacant position. When appointing employee
representatives to supervisory bodies under the law governing employee participation in
management, the Works Council must ensure that at least 33% of its representatives belong to
the under-represented gender, unless no eligible person of that gender is available at the time
of appointment.
If multiple candidates meet the fit and proper criteria, priority in the selection process will be
given to the candidate who enhances the diversity of the Supervisory Board.
The objective is to ensure balanced gender representation in both the management body and
the supervisory body, so that the members of the Management Board and the Supervisory Board
together include at least 33% of the under represented gender (gender representation ratio). In
2025, the gender representation target set out in the Diversity Policy for the members of the
Management Board and the Supervisory Board was achieved.
Where the company does not meet the gender balance set out in the preceding paragraph of
this point, specifically, if multiple candidates meet the criteria and requirements of the selection
procedure for the appointment of Supervisory Board members equally, preference must be given
to the candidate of the under-represented gender. Exceptions may apply in objectively justified
cases, for example, to comply with the Diversity Policy based on other personal circumstances,
49
in which case preference may be given to a candidate of the opposite gender, provided that the
decision is specifically justified.
As at 31 December 2025, the Supervisory Board comprised six shareholder representatives –
Chairman Andrej Andoljšek and members Tim Umberger, Barbara Nose, Monica Cramér
Manhem, Rok Ponikvar and Barbara Cerovšek Zupančič – and one employee representative, Rudi
Lipovec.
5.3.3.1 Powers of the Supervisory Board
The powers and operation of the Supervisory board are set out by the applicable legislation, the
Company's Articles of Association and the Rules of Procedure of the Supervisory Board (available
on the Company's website). In addition, the Supervisory Board gives consent to the decisions of
the Management Board where the value or an investment exceeds the amount set out in the
Rules of Procedure of the Supervisory Board, i.e. in the event of:
▪ The founding of limited companies in Slovenia and abroad;
▪ The acquisition or sale of Zavarovalnica Triglav's participating interests in domestic or
foreign companies, except in the case of participating interests for which the conventional
portfolio management approach is used;
▪ The issue of debt securities and long-term borrowing from domestic or foreign banks;
▪ The acquisition and sale of real property and investment in real property of Zavarovalnica
Triglav.
In accordance with the law and the Rules of Procedure, the Supervisory Board holds at least one
session per quarter, or more if necessary.
50
5.3.3.2 Supervisory Board in 2025
Composition of the Supervisory Board in 2025
Name and
surname
Function
Start of term
of office
(the first)
End of term of
office
Attendance
of sessions
of the
Supervisory
Board /
total
number of
Supervisory
Board
sessions
Gender
Nationality
Year
of
birth
Education
Professional profile
Independence
pursuant to
the Slovenian
Corporate
Governance
Code
Existence
of conflict
of interest
in 2025
Membership in
the supervisory
and/or
management
bodies of other
companies while
serving on the
Supervisory
Board in 2025
Membership in
Supervisory Board
committees
Function in
Supervisory Board
committees
Attendance of
meetings of
Supervisory
Board
committees /
total number of
meetings of
Supervisory
Board
committees
Andrej Andoljšek
Member
13 June 2017
13 June 2021
10 of 10
Male
Slovenian
1970
Graduate in
Economics
(Level VII)
Financial and general
management, financial markets
and analyses, banking, corporate
governance, business and financial
restructuring of companies
YES
YES
Sava d.d.
Strategy
Committee
Appointment and
Remuneration
Committee
Member
Member until 22
June 2025
Chair from 23 June
2025
1 of 1
/
9 of 9
Vice Chairman
Chairman
Member
Chair
Member
Chair
21 June 2017
18 August
2020
14 June 2021
18 June 2021
15 June 2025
23 June 2025
17 August
2020
13 June 2021
14 June 2025
14 June 2025
15 June 2029
15 June 2029
Tim Umberger
Member
Vice Chairman
7 June 2023
10 July 2024
9 July 2027
7 June 2027
10 of 10
Male
Slovenian
1980
MSc in Economics
Financial markets and analyses
YES
YES
Gorenjska banka
d.d.
Audit Committee
Strategy
Committee
_______________
Nomination
Committee
Appointment and
Remuneration
Committee
Member until 23
June 2025
Chair
______________
Chair
Member
5 of 7
____________
/
1 1 of 1
6 of 6
9 of 9
Barbara Nose
Member
4 June 2024
4 June 2029
10 of 10
Female
Slovenian
1964
BSc in Economics
Financial and insurance markets,
strategy and business model, risk
management, controlling,
accounting and audit, corporate
governance
YES
YES
Luka Koper d.d.
Pošta Slovenije
d.o.o.
Strategy
Committee
_______________
Audit Committee
Risk Committee
Member
Chair
______________
Member
1 of 1
7 of 7
7 of 7
Tomaž Benčina
Member
14 June 2021
14 June 2025
10 of 10
Male
Slovenian
1965
BSc in Economics
and BSc in
Metallurgy
Financial markets, business strategy
and business models, governance
system, financial analyses
YES
YES
Luka Koper d.d.
Appointment and
Remuneration
Committee
Strategy
Committee
Chair
until 14 June 2025
Member until 14
June 2025
5 of 9
0 of 1
Monica Cramér
Manhem
Member
7 June 2023
7 June 2027
10 of 10
Female
Swedish
1959
Bachelor of
Business /
Economics
International regulatory and other
legal requirements, financial and
actuarial analyses
YES
NO
Sompo Int'l Lux,
ASML (Apollo
Syndicates
Management at
Lloyds)
Sompo
International
Holding,
Bermuda
Strategy
Committee
Risk Committee
Member
Chair
1 of 1
7 of 7
51
Name and
surname
Function
Start of term
of office
(the first)
End of term of
office
Attendance
of sessions
of the
Supervisory
Board /
total
number of
Supervisory
Board
sessions
Gender
Nationality
Year
of
birth
Education
Professional profile
Independence
pursuant to
the Slovenian
Corporate
Governance
Code
Existence
of conflict
of interest
in 2025
Membership in
the supervisory
and/or
management
bodies of other
companies while
serving on the
Supervisory
Board in 2025
Membership in
Supervisory Board
committees
Function in
Supervisory Board
committees
Attendance of
meetings of
Supervisory
Board
committees /
total number of
meetings of
Supervisory
Board
committees
Rok Ponikvar
Member
2 September
2024
2 September
2029
10 of 10
Male
Slovenian
1972
BSc in
Economics
Financial markets, governance
system, financial analyses, business
strategy and business models
YES
YES
Loterija Slovenije
d.d.
Strategy
Committee
Risk Committee
_______________
Nomination
Committee
Appointment and
Remuneration
Committee
Member
Member
______________
Member
______________
Member from 26
March 2025
1 of 1
7 of 7
6 of 6
______________
7 of 9
Barbara Cerovšek
Zupančič
Member
15 June 2025
15 June 2029
6 of 10
Female
Slovenian
1975
Master of Science
Financial management, banking,
financial markets and analyses,
corporate governance
YES
NO
Pošta Slovenije
d.o.o.
Audit Committee
Strategy
Committee
Member from 23
June 2025
Member from 23
June 2025
2 of 7
1 of 1
Rudi Lipovec
Member
7 November
2025
7 November
2029
2 of 10
Male
Slovenian
1969
BSc in
Mechanical
Engineering
Insurance and financial markets,
business strategy and business
models, governance systems,
financial and actuarial analyses,
risk management
YES
NO
/
/
/
/
Aleš Košiček
Member
11 July 2023
25 March
2025
1 of 10
Male
Slovenian
1966
MSc in Business
and Organisation
Insurance, governance systems,
business strategy and business
models, financial analyses in the
context of Zavarovalnica Triglav's
operations
YES
NO
/
Audit Committee
Nomination
Committee
Appointment and
Remuneration
Committee
Strategy
Committee
Member until 25
March 2025
Member
Member
Member
2 of 7
5 of 6
2 of 9
0 of 1
Janja Strmljan
Čevnja
Member
11 July 2023
13 March
2025
1 of 10
Female
Slovenian
1969
LL.B.
Regulatory and other legal
requirements that apply to
Zavarovalnica Triglav
YES
NO
/
Strategy
Committee
Risk Committee
Member
Member
0 of 1
1 of 7
52
External members of Supervisory Board committees in 2025
Name and surname
Supervisory Board
committee
Attendance of meetings of
Supervisory Board committees and
total number of committee meetings
Gender
Nationality
Education
Year of birth
Professional profile
Membership in the supervisory bodies of
other companies while serving on a
Supervisory Board committee in 2025
Jure Vehovec
Risk Committee
From 27 March 2025
4 of 7
Male
Slovenian
Graduate in Economics
(Level VII)
1962
Information technology in the financial sector,
management of IT systems and digital solutions,
banking and financial institutions, corporate
governance, audit committees and risk
management, strategic management of IT areas,
knowledge of regulatory requirements in the
financial and insurance sectors
/
Jörgen Olsen
Risk Committee
27 March 2025
7 of 7
Male
Slovenian
/
Risk Committee
From 27 March 2025
Risk Committee
From 27 March 2025
7 of 7
Male
Slovenian
/
4 of 7
Male
Swedish
PhD
1972
Actuarial science and mathematical statistics,
risk and capital management, insurance and
reinsurance, corporate governance, strategic and
operational management, process optimisation
(GRC), digital transformation, artificial
intelligence and machine learning (AI/ML)
Swedish Actuarial Association (Svenska
Aktuarieföreningen)
Mateja Lovšin Herič
Nomination Committee
From 28 November
2024 to 3 June 2025
6 of 6
Female
Slovenian
BSc in Economics
1969
Corporate governance and finance
Istrabenz turizem d.d., Koto d.o.o.
Katarina Sitar Šuštar
Audit Committee
From 19 November
2024
7 of 7
Female
Slovenian
MSc in Business
1971
Certified auditor, audit of various legal entities,
insurance
The audit committees of the supervisory
boards of Pošta Slovenije d.o.o. and University
of Ljubljana
53
By signing the Statement of Independence and Loyalty, the members of the Supervisory Board
undertook to adhere to the principles of independence laid down in item B of the Annex to the
Corporate Governance Code. The statement is available on the company's website. Data on the
remuneration of the Supervisory Board members are disclosed in Section 4.4 of the Accounting
Report. Their remuneration was in line with the resolution passed by the 41st General Meeting
of Shareholders of Zavarovalnica Triglav.
5.3.3.3 Composition of the Supervisory Board committees and their activities in 2025
In 2025, the Company had the following committees: the Audit Committee, the Appointment
and Remuneration Committee, the Strategy Committee, the newly established Risk Committee
and the Nomination Committee as an ad-hoc committee. Supervisory Board committees prepare
draft resolutions for the Supervisory Board, assure their implementation and carry out other
tasks.
The duties and powers of the committees are set out in the Companies Act, the Rules of
Procedure of the Supervisory Board, Supervisory Board resolutions and the rules of procedure of
individual committees. Their main tasks are presented in the figure below.
54
The Supervisory Board committees and their main tasks
Supervisory Board
Audit Committee
▪ Monitors the financial reporting and
sustainability reporting process and draws
up reports and proposals for ensuring its
integrity;
▪ Monitors the efficiency and effectiveness
of internal controls, internal audit and risk
management systems;
▪ Monitors the obligatory audit of annual
and consolidated financial statements and
reports on the audit findings to the
Supervisory Board;
▪ Is in charge of the auditor selection
procedure, proposes a candidate to the
Supervisory Board to audit the Company’s
annual report and participates in the
drafting of an agreement between the
auditor and the Company;
▪ Reviews and monitors the independence
of the auditor for the Company's annual
report, particularly regarding the provision
of additional non-audit services;
▪ Monitors the quality of the auditor's audit
in accordance with the Guidelines for audit
committees for monitoring the quality of
external auditing adopted by the Agency
for Public Oversight of Auditing and the
Slovenian Directors' Association;
▪ Supervises the integrity of financial
information provided by the Company,
evaluates the drafting of the annual report
and draws up a proposal for the
Supervisory Board;
▪ Cooperates with the Internal Audit
Department, monitors its quarterly
reports, examines the internal documents
of the Internal Audit Department, the
Rules of the Internal Audit Department
and the annual plan of the Internal Audit
Department;
▪ Discusses decisions on the appointment,
dismissal and remuneration of the head of
the Internal Audit Department.
▪ Monitors the Company's annual
compliance reports and reports on
contracts with audit firms and firms in
their networks.
Strategy Committee
▪ Discusses and draws up
proposals for the Supervisory
Board regarding the Triglav
Group strategy;
▪ Monitors the implementation of
the strategy;
▪ Discusses and draws up
proposals and opinions for the
Supervisory Board related to the
strategic development and
planning of the Triglav Group.
Appointment and Remuneration
Committee
▪ Proposes criteria for membership in
the Management Board;
▪ Proposes the policies of
remuneration, reimbursement and
other benefits for the Management
Board members;
▪ Preliminary considers the proposals
of the President of the Management
Board related to the management of
the Company;
▪ Performs fit and proper assessments
of the Management Board and
Supervisory Board members;
▪ Provides support and makes
proposals on matters related to the
Supervisory Board (e.g. conflicts of
interest, design and implementation
of a remuneration system for the
Supervisory Board members,
assessment of the Supervisory
Board's work pursuant to the Code
of Corporate Governance).
Nomination Committee (an ad-hoc
committee established to carry out
a nomination procedure for
shareholder representatives)
▪ Prepares criteria for the selection of
candidates for members of the
Supervisory Board, shareholder
representatives, unless the
Supervisory Board determines
otherwise;
▪ Registers the candidates for
members of the Supervisory Board;
▪ Instructs the Appointment and
Remuneration Committee to carry
out a fit and proper assessment of
the candidates;
▪ Submits to the Supervisory Board a
proposal to nominate one or
several candidates for Supervisory
Board members – shareholder
representatives, including the draft
fit and proper assessment of the
candidates for members of the
Supervisory Board.
Risk Committee
▪ Monitors the functioning and
adequacy of the risk management
system;
▪ Advises the Supervisory Board on the
Company's overall current and future
risk appetite and on its risk
management strategy;
▪ Oversees the implementation of
capital and material risk management
strategies;
▪ Reviews key internal documents and
other risk management documents
submitted to, noted by or approved by
the Supervisory Board;
▪ Reviews the annual Solvency II capital
adequacy calculation reports, the
Solvency and Financial Condition
Reports (SFCR) of the Company and
the Group, the own risk and solvency
assessment report, the regular risk
profile reports of the Company and
the Group, and any other reports
related to risk management;
▪ Supervises disclosures and examines
the credit rating agencies' reports for
the year.
55
As at 31 December 2025, the Audit Committee comprised Barbara Nose as chair, Barbara
Cerovšek Zupančič as member and Katarina Sitar Šuštar as an independent external expert.
As at 31 December 2025, the Appointment and Remuneration Committee comprised Andrej
Andoljšek as chair, with Tim Umberger and Rok Ponikvar as members.
As at 31 December 2025, the Strategy Committee comprised Tim Umberger as chair, with Andrej
Andoljšek, Monica Cramér Manhem, Barbara Nose, Rok Ponikvar and Barbara Cerovšek Zupančič
as members.
As at 31 December 2025, the Risk Committee comprised Monica Cramér Manhem as chair,
Barbara Nose and Rok Ponikvar as members, and Jure Vehovec and Jörgen Olsen as external
members.
The Nomination Committee operates as an ad hoc committee. It was established on 19
November 2024 due to the expiry of the term of office of Supervisory Board members Andrej
Andoljšek and Tomaž Benčina in 2025. The Committee operated until the election of new
Supervisory Board members, shareholder representatives, at the General Meeting of
Shareholders. It is composed of Tim Umberger as chair, Rok Ponikvar and Aleš Košiček as
members, and Mateja Lovšin Herič as an external member.
See Section 5.3.3.2 Supervisory Board in 2025 for more information about the structure of
Supervisory Board committees in 2025.
5.4 Governance and management of subsidiaries
The Triglav Group is comprised of Zavarovalnica Triglav as the controlling company, its
subsidiaries and associates, and joint ventures. The subsidiaries operate as independent legal
entities in accordance with the applicable local legislation, the resolutions passed by their
general meetings and their management and supervisory bodies, business cooperation
agreements (where applicable) and other adopted internal documents.
The Governance Policy of the Triglav Group's Subsidiaries sets out the main guidelines for the
governance of subsidiaries, taking into account the Group's long-term objectives, values and
strategy.
It establishes a governance system for subsidiaries through the operation of general meetings
and supervisory and management bodies of individual subsidiaries, and through the
standardisation and harmonisation of key policies and procedures in specific areas of expertise,
including the key functions of risk management, compliance, internal audit and actuarial. Its aim
is to enforce uniform minimum standards across core business performance, effective
governance, reporting and control at Group level.
To ensure effective governance and oversight of the Group's subsidiaries, a three-line
governance system is in place, forming the basis for the implementation of the Policy. The
system is designed to support a clear separation of powers and responsibilities, and effective risk
management, while ensuring that business activities are conducted in line with the Group's
corporate objectives and strategy, thereby harmonising operations and achieving synergies.
The three-line governance system includes:
▪ Corporate governance: The first line relates to corporate governance as the active exercise
of the management rights held by the parent company, or by its subsidiary acting as a
56
parent company, in accordance with the legislation applicable to each subsidiary and its
internal regulations. Corporate governance also encompasses the establishment and
maintenance an effective dialogue between the Company and its subsidiaries in order to
ensure the achievement of common objectives.
▪ Key function management: The second line comprises the parent company's key functions:
risk management, compliance, internal audit and actuarial. These functions are key to
supporting business lines in achieving business objectives while ensuring that risks are
properly identified, assessed, monitored and managed. Key functions operate
independently of the business lines to ensure objective risk assessment and control.
▪ Management of business lines: The third line consists of the parent company's business
lines, which are responsible for managing business activities at Group level.
By implementing the three-line governance system, the Company provides a robust framework
for the management of its subsidiaries that promotes transparency, accountability and effective
risk management, while also allowing flexibility in achieving its business objectives. The Triglav
Group Subsidiary Management Division, key functions, relevant departments and business
segments of the parent company are responsible for ensuring the effective implementation of
the Group's governance system. Through mutual cooperation, they establish and maintain an
efficient and transparent Group governance system.
At Zavarovalnica Triglav, a top-down management approach is maintained. This principle is
central to all aspects of governance, strategy and operational decision-making within the
Company and its subsidiaries, ensuring that management directions, policies and strategic
objectives are established at the highest level and consistently communicated and implemented
across all levels.
The Policy clearly defines the governance powers of the parent company over its subsidiaries,
the process for identifying risk escalation, and the powers and responsibilities of Group
subsidiaries. It also establishes the foundation for the Remuneration Policy applicable to
members of supervisory and management bodies of subsidiaries, outlines the framework for
transactions between the parent company and subsidiaries, and specifies the subsidiaries'
reporting system.
The subsidiary governance system is designed so that Zavarovalnica Triglav, as the parent
company, manages its direct subsidiaries. Accordingly, its direct subsidiaries assume
responsibility for transferring the governance system to their own subsidiaries and actively
managing them.
In order to ensure a high level of governance in all Group subsidiaries, processes are in place to
implement Zavarovalnica Triglav's Minimum Standards for Subsidiaries. They set out the basic
and key requirements for ensuring the efficient and consistent operation of all Group members,
irrespective of their geographical location or specific activities.
The purpose of the Minimum Standards for Subsidiaries is to align all Group subsidiaries with
the Group's objectives, values and strategy, while respecting local legislation and accounting for
market specificities.
The Policy defines the procedures for preparing, monitoring, implementing, enforcing and
updating the Minimum Standards for Subsidiaries, outlines the responsibilities of the relevant
departments of the parent company and the management of the subsidiaries, and specifies the
actions to be taken in the event of deviations. They are regularly updated. The relevant business
segments of the parent company monitor their implementation, thereby achieving integration
between the subsidiaries' and Zavarovalnica Triglav's business functions and ensuring a
comprehensive overview at the Group level.
57
The Company has in place and is implementing a robust and reliable governance system for the
Triglav Group, which is compliant with statutory requirements and comparable to other
insurance groups.
Governance of the Triglav Group's subsidiaries
The composition of management and supervisory bodies as at 31 December 2025
Company
Management
Supervisory function
Slovenia
Pozavarovalnica Triglav Re d.d., Ljubljana
Gregor Stražar – President
Supervisory Board:
Tomaž Rotar – Member
Tadej Čoroli – Chairman,
Maja Omahen Petrič – Member
Katja Modec, Janko Šemrov
Triglav, pokojninska družba d.d., Ljubljana
Aljoša Uršič – President
Supervisory Board:
Peter Krassnig – Member
Blaž Jakič – Chairman,
Vida Šeme Hočevar – Member
Blaž Kmetec, Miha Grilec,
Miran Kalčič, Vesna Vodopivec,
Borut Simonič, Helena Lokar
Triglav Investments, družba za upravljanje
d.o.o., Ljubljana
Benjamin Jošar – President
Andrej Petek – Member
Supervisory Board:
Blaž Jakič – Chairman,
Miha Grilec – Member
Jaka Kirn, Damir Verdev, Marica Makoter,
Barbara Gorjup, Damjan Kralj
Triglav INT, holdinška družba d.o.o.,
Ljubljana
Tedo Djekanović – Director
Supervisory Board:
Uroš Ivanc – Chairman,
Damir Verdev, Saša Kovačić
Triglav, Upravljanje nepremičnin d.o.o.,
Ljubljana
Jure Valjavec – Chief Executive Officer
Rok Pivk – Director
Supervisory Board:
Tadej Čoroli – Chairman,
Ksenija Zajc, Nataša Novak Priveršek
Triglav Svetovanje, zavarovalno zastopanje
d.o.o., Domžale
Tomaž Dvořak – Director
Supervisory Board:
Maja Benko – Chairwoman,
58
Company
Management
Supervisory function
Jana Polda, Matjaž Novak, Lidija Breznik
Triglav Avtoservis d.o.o., Ljubljana
Mladen Jug – Director
Robert Tisovec – Director
Supervisory Board:
Matej Ferlan – Chairman,
Nataša Novak Priveršek, Jaka Klement
Triglav Med, družba za zdravstveno
dejavnost d.o.o., Ljubljana
Polona Peterle – Director
Supervisory Board:
None
Eskulap družba za zdravstveno dejavnost
d.o.o., Ljubljana
Polona Peterle – Director
Supervisory Board:
None
Vse bo v redu, zavod Zavarovalnice Triglav
za družbeno odgovorne aktivnosti
Tjaša Kolenc Filipčič – Director
Management Board:
Marica Makoter – President,
Metoda Debeljak, Aleš Vahčič
Croatia
Triglav Osiguranje d.d., Zagreb
Vilma Učeta Duzlevska – President
Supervisory Board:
Tedo Djekanović – Chairman,
Blaž Kmetec – Member
Gorazd Jenko, Alenka Vrhovnik Težak,
Lidija Pecigoš Višnjić – Member
Pave Srezović-Pušić, Aleš Vahčič
Triglav, Upravljanje nekretninama d.o.o.,
Zagreb
Goran Branković – Director
Supervisory Board:
Rok Pivk – Chairman,
Ana Stradar Iglič, Luka Reflak
Serbia
Triglav Osiguranje a.d.o., Belgrade
Dragan Marković – President of the
Executive Committee
Supervisory Board:
Tedo Djekanović – Chairman,
Ivan Grujić – Member of the Executive
Committee
Fejsal Hrustanović, Vuk Šušić,
Gorazd Jenko, Milan Tomaževič
Triglav International d.o.o., Belgrade
Stanka Pejanović – Director
Supervisory Board:
None
Montenegro
Lovćen Osiguranje a.d., Podgorica
Matjaž Božič – Chief Executive Officer
Board of Directors:
Stanko Mugoša – Executive Director
Tedo Djekanović – Chairman,
Tomaž Žust, Alenka Vrhovnik Težak,
Marjeta Gorinšek, Stanka Pejanović
Lovćen Auto d.o.o., Podgorica
Ratko Babić – Director
Board of Directors:
None
Lovćen životna osiguranja a.d., Podgorica
Zorka Milić – Executive Director
Board of Directors:
Ljubica Kovačević – Chairwoman,
Slobodanka Vukadinović, Danilo Pavličić
Bosnia and Herzegovina
Triglav Osiguranje d.d., Sarajevo
Edib Galijatović – President
Supervisory Board:
Emir Krivošija – Member
Tedo Djekanović – Chairman,
Simon Vidmar, Janko Šemrov,
Stanka Pejanović, Robert Trnovec
Triglav Investments d.o.o., Sarajevo
Senada Smajić-Ermacora – Director
Slaven Jurešić – Executive Director
Supervisory Board:
Andrej Petek – Chairman,
Bakir Pilav, Tomaž Kuntarič
Sarajevostan d.o.o., Sarajevo
Ammar Gorčić – Director
Supervisory Board:
Sead Šabeta – Chairman,
Emir Osmanbašić, Žan Matić
Autocentar BH d.o.o., Sarajevo
Jasmin Bijedić – Director
Supervisory Board:
Adnan Suljagić – Chairman,
Amra Karasalihović, Muhidin Olovčić
59
Company
Management
Supervisory function
Triglav Savjetovanjee d.o.o., Sarajevo
Zlatko Hadžić – Director
Supervisory Board:
None
Triglav upravljanje nekretninama d.o.o.,
Sarajevo
Goran Branković – Director
Supervisory Board:
Rok Pivk – Chairman,
Ana Stradar Iglič, Luka Reflak
Društvo za upravljanje Evropskim
dobrovoljnim penzijskim fondom, a.d.,
Banja Luka
Zdravko Zečević – Executive Director
Gordana Drobnjak – Director
Management Board:
Aljoša Uršič, Saša Stevanović,
Tamir Mostarac
North Macedonia
Triglav Osiguruvanje a.d., Skopje
Gjorgje Vojnović – Chief Executive Officer
Board of Directors:
Vojdan Jordanov – Executive Director
Tedo Djekanović – Chairman,
Darko Popovski, Matej Ferlan,
Matej Narat, Gjorgje Vojnović,
Vojdan Jordanov, Gjorgji Jančevski
Triglav Osiguruvanje Život a.d., Skopje
Hristina Đambazovska Anastasov – Chief
Executive Officer
Board of Directors:
Tedo Djekanović – Chairman,
Ivan Sotošek, Vilma Učeta Duzlevska,
Gjorgji Jančevski, Vladimir Mišo Čeplak,
Hristina Đambazovska Anastasov,
Stanka Pejanović
Triglav penzisko društvo a.d., Skopje
Tihomir Petreski – President
Supervisory Board:
Marijan Nikolovski – Member
Aljoša Uršič – Chairman,
Rok Pivk, Blaž Kmetec, Andraž Rangus
Triglav upravuvanje so nedvižen imot
DOOEL, Skopje
Goran Branković – Director
Supervisory Board:
Rok Pivk – Chairman,
Ana Stradar Iglič, Luka Reflak
5.5 External and internal audit
The financial statements of the Triglav Group and Zavarovalnica Triglav are audited by Deloitte
revizija d.o.o., which was appointed in 2025 for the financial years 2025, 2026, 2027 and 2028.
The auditor reports its findings to the Management Board, the Supervisory Board and the Audit
Committee.
The report on the work of the Internal Audit Department is presented in Section 9.1 Risk
management system.
5.6 Internal controls and risk management in relation to financial reporting
The Group's integrated internal control and risk management system is continuously adapted to
the development, organisational changes and good practices, thereby maintaining its
effectiveness. The system complies with the basic statutory requirements for insurance
undertakings set out in the Companies Act and the Insurance Act, as well as special
implementing regulations of the Insurance Supervision Agency on the establishment and
maintenance of a suitable internal control and risk management system.
The characteristics and operation of the risk management system is discussed in detail in Section
9. Risk management. The system was set up in all organisational levels and processes and
includes:
▪ A clear organisational structure with a precisely defined and transparent system of duties,
responsibilities and powers;
60
▪ Efficient procedures for an ongoing control, error prevention, and identification,
assessment, management and monitoring of risks to which the insurance undertakings are
or may be exposed in the course of their operations;
▪ An adequate internal control system that includes appropriate administrative and
accounting procedures (reporting, working procedures, risk exposure limits and physical
controls);
▪ Ensuring compliance with the applicable regulatory requirements.
The Internal Audit Department is an independent organisational unit, established in compliance
with the law. It regularly reviews the effectiveness of the internal control and risk management
system and offers upgrade proposals as well as reports to the Management Board, the Audit
Committee and the Supervisory Board.
The accuracy, completeness and timeliness of financial reporting as well as compliance with
applicable regulations are ensured by the internal control system established by the parent
company and implemented by the Group at all levels. Accounting controls are based on the
principles of appropriate sharing of responsibilities. They include checking the performance of
transactions, keeping up-to-date records, ensuring the matching of balance of books of account
with the actual balance, separation of the records from the execution of transactions,
professionalism of accountants and their independence. Accounting controls are closely linked
to IT controls, which, inter alia, restrict and control access to the data and applications and ensure
completeness and accuracy of data capturing and processing.
The processes for identifying, assessing, monitoring and managing tax risks are described in
more detail in Section 2.11 Tax policy of the Accounting Report.
5.7 Notes on the takeover legislation
Zavarovalnica Triglav is subject to the Takeover Act (hereinafter: ZPre-1).
The share capital structure of Zavarovalnica Triglav, the rights and obligations attached to the
shares, the restriction on transfer of shares and the absence of shares that would grant their
holders special control rights are described in detail in Section 6. The share and shareholders of
Zavarovalnica Triglav.
5.8 Disclosure of existence of any agreements or authorisations regarding shares or voting
right
Zavarovalnica Triglav is not aware of any shareholder agreements that could cause a restriction
on the transfer of shares or voting rights.
The Company's Management Board is not authorised by the General Meeting of Shareholders to
buy its own shares. The Management Board's authorisation to increase the share capital is
described in Section 5.3.2.1. The issue of new shares, the amount of capital increase, the rights
attached to new shares and the conditions for issuing new shares are decided on by the
Company's Management Board with the consent of the Supervisory Board.
Zavarovalnica Triglav has no employee share scheme.
61
The Company is not aware of any agreements that would become effective, change or expire on
the basis of a changed control of the Company or as a consequence of a takeover bid as defined
by the ZPre-1.
Zavarovalnica Triglav did not enter into any agreements with the members of its management
or supervisory bodies or employees which would provide for remuneration if a takeover bid in
line with the ZPre-1 caused them to resign, be dismissed without justified grounds, or caused
their employment to be terminated in some other manner.
Andrej Slapar
President of the
Management Board
Uroš Ivanc
Management Board
member
Tadej Čoroli
Management Board
member
Marica Makoter
Management Board
member
Blaž Jakič
Management Board
member
Ivica Vulić
Management Board
member
62
6. The share and shareholders of Zavarovalnica Triglav
- Zavarovalnica Triglav's share achieved a total return of 51% in 2025. The Company's market
capitalisation exceeded EUR 1 billion for the first time, standing at EUR 1.3 billion at year-
end 2024.
- Triglav received the prestigious Ljubljana Stock Exchange Prime Market Share of the Year
Award, and also the Biggest Stock Market Rise Award.
- S&P Global upgraded the Group's credit rating from "A" to "A+", while AM Best reaffirmed
the high credit rating of "A".
- The Company's shareholder structure continued to see growth in the share held by Slovenian
shareholders.
6.1 Share of Zavarovalnica Triglav
In 2025, Zavarovalnica Triglav's share (ZVTG) achieved significantly improved liquidity and
strong total return. It was the most successful share on the Ljubljana Stock Exchange, receiving
the stock exchange's most prestigious award, the Prime Market Share of the Year Award, as well
as the Biggest Stock Market Rise Award.
The annual ZVTG share turnover (excluding block trades) reached EUR 57.6 million, up 136%
year-on-year. Around a quarter of ZVTG share turnover was carried out by the liquidity provider,
which has rendered its services since 2019. In addition, block trades of the ZVTG share on the
stock exchange amounted to EUR 22.2 million (EUR 1.0 million the previous year), while over-
the-counter transactions totalled EUR 91.8 million (index 417). According to Centralna klirinško
depotna družba, the estimated total value of all transactions in ZVTG shares reached EUR 171.6
million (index 361).
The turnover of free-float market capitalisation on the Ljubljana Stock Exchange stood at 16%,
while the total share return reached 50.9% (21.0% in the previous year). As at 31 December 2025,
the price-to-book ratio (P/B) amounted to 1.3, while the price-to-earnings ratio (P/E) was 10.0.
With a market capitalisation of EUR 1,345.9 million, Zavarovalnica Triglav, the Triglav Group's
parent company, was the fourth-largest Slovenian listed company.
The ZVTG share has been traded on the Ljubljana Stock Exchange since the end of 2008 and has
been included in the Prime Market segment since 2011. Detailed information is provided in the
table.
Key figures relating to the ZVTG share (EUR)
Items
2025
2024
Maximum closing price
62.00
41.40
Minimum closing price
40.60
33.60
Closing price as at 31 December
59.20
40.50
Book value per share (parent company)
35.11
32.62
Book value per share (consolidated data)
47.42
43.50
Net earnings per share (consolidated data)
6.00
5.76
Market capitalisation as at 31 December
1,345,920,762
920,773,494
Average daily turnover (excluding block trades)
232,260
98,980
Average daily turnover (with block trades)
321,869
103,193
Dividend per share
2.80
1.75
Number of shares
22,735,148
22,735,148
63
Items
2025
2024
Percentage of free float
29.0%
30.6%
Traded on
Ljubljana Stock Exchange - LJSE
ISIN code
SI0021111651
Ticker symbol
ZVTG
Bloomberg
ZVTG SV
Reuters
ZVTG.LJ
Credit rating
S&P Global: »A+«, stable
medium-term outlook
S&P Global: »A«, positive
medium-term outlook¸
AM Best: »A«, stable
medium-term outlook
AM Best: »A«, stable
medium-term outlook
According to available data, the ZVTG share is included in 25 indices of various providers,
including those of S&P, MSCI, Bloomberg, Sustainalytics, STOXX (Deutsche Börse), FTSE Russell
(London Stock Exchange), as well as the Ljubljana, Vienna and Warsaw Stock Exchanges.
Movement in the ZVTG share price in 2025 compared to the Ljubljana Stock Exchange SBITOP index
and the index of European insurance companies STOXX Europe 600 Insurance
(the baseline date:31 December 2024 = 100)
Movement in the ZVTG share price (left axis) and turnover (right axis) in EUR in 2025 (the baseline
date: 31 December 2024 = EUR 40.50)
146
150
125
80
90
100
110
120
130
140
150
160
Index
ZVTG SBITOP Index STOXX Europe 600 Insurance Index
0
500
1.000
1.500
2.000
2.500
3.000
3.500
4.000
4.500
30
32
34
36
38
40
42
44
46
48
50
52
54
56
58
60
62
64
Turnover in EUR thousand
ZVTG price in EUR
ZVTG turnover ZVTG closing price
59.20
64
The ZVTG share price increased by 46% year-on-year in 2025, while the STOXX Europe 600
Insurance index rose by 25% and the Ljubljana Stock Exchange SBITOP index gained 50%. After
rising in the first two months of the year, the ZVTG share price was negatively affected in March
and April by corrections on global equity markets triggered by the introduction of US tariffs. In
May, after the release of strong annual and quarterly results, the share price came under selling
pressure from a major shareholder, followed in June by the usual impact of the dividend payout.
The ex-dividend date was 17 June 2025 (see Sections 5.3.1 General Meeting of Shareholders and
6.4 Dividends and the dividend policy for more information). Following strong operating
performance, the share price rose sharply, reaching a historical high of EUR 62.00 at the end of
July. In the subsequent period until year-end, the share price was influenced by the release of
strong interim results accompanied by an upgraded annual profit guidance, selling pressure
from a major shareholder and certain market-driven corrections.
6.2 Equity
As at 31 December 2025, Zavarovalnica Triglav's share capital remained unchanged and
amounted to EUR 73,701,391.79 compared to the previous year. It is divided into 22,735,148
ordinary registered no-par value shares constituting one class. The shares are issued in
dematerialised form and are freely transferable. Each share represents the same stake and
corresponding amount in share capital, and all have been fully paid up. Each share gives its
holder the right to one vote at the general meeting of shareholders and a proportionate share of
profit allocated for dividend payment. In the event of bankruptcy or liquidation, the shareholders
are entitled to a proportionate share of residual bankruptcy or liquidation estate after the payoff
of preference shareholders.
In acquiring shares, Zavarovalnica Triglav's existing and potential shareholders are required to
comply with the Insurance Act (ZZavar-1). An authorisation of the Slovenian Insurance
Supervision Agency is a prerequisite for:
▪ The acquisition of shares of an insurance undertaking by which a person acquires or exceeds
a qualifying holding (i.e. a direct or indirect holding of shares or other rights that gives the
holder a minimum 10% share of voting rights or capital, or that gives the holder a share of
voting rights or capital lower than 10%, but nevertheless allows the holder to significantly
influence the management of the company). In its decision on issuing an authorisation to
acquire a qualifying holding, the Insurance Supervision Agency determines the level of the
share in the voting rights or capital of the insurance undertaking for which the authorisation
is issued as one of the following ranges:
▪ The share of the voting rights or capital of the insurance undertaking that is equal to or
greater than a qualifying holding and less than 20%;
▪ The share of the voting rights or capital of the insurance undertaking that is equal to or
greater than 20% and less than one third;
▪ The share of the voting rights or capital of the insurance undertaking that is equal to or
greater than one third and less than 50%;
▪ The share of the voting rights or capital of the insurance undertaking that is equal to or
greater than 50%;
▪ The share on the basis of which the future qualifying holder becomes the parent
company of the insurance undertaking;
▪ Before any subsequent acquisition of shares by the qualifying holder that would result in
the qualifying holding exceeding the range subject to the already issued authorisation for
acquisition of a qualifying;
▪ For the entities that agree to a concerted acquisition of the shares of the insurance
undertaking or a concerted exercising of management rights arising from the shares (joint
qualifying holders) and intend to acquire a holding by which they would jointly reach or
exceed a qualifying holding of the undertaking;
65
▪ Before any subsequent acquisition of shares by the joint qualifying holders that would result
in their joint qualifying holding exceeding the range subject to the already issued
authorisation for acquisition of a qualifying holding.
The holder of shares of an insurance undertaking that were acquired or are being held in
contravention of the ZZavar-1 has no voting rights with respect to those shares. See the ZZavar-
1 for further information.
6.3 Shareholder structure
Zavarovalnica Triglav's shareholder structure remained largely unchanged in 2025. As at 31
December 2025, the Company's ten largest shareholders held a 76.3% stake, down by 0.5
percentage points compared to the preceding year. Among shareholders with a stake exceeding
5%, two funds owned by the Republic of Slovenia (ZPIZ Slovenije and SDH d.d.) maintained their
stakes, while the Croatian pension fund, listed on the fiduciary account of its custodian bank,
increased its stake by 1.6 percentage points, to 8.4%. The nominee account of UniCredit Bank
Austria, which was the fourth largest shareholder as at year-end 2024, is no longer among the
ten largest shareholders following a major sale by the ultimate owner. The shares on Citibank's
custodial account decreased by 1.2 percentage points in 2025 due to a change of the asset
manager of a major ultimate shareholder, while the remaining members of the ten largest
shareholders increased their stakes. The most significant increase was recorded for clients on
the Intercapital Securities fiduciary account, which rose by 0.6 percentage points. NLB Skladi –
Slovenija mešani and Forplan d.o.o. entered the list of the ten largest shareholders.
Zavarovalnica Triglav’s ten largest shareholders as at 31 December 2025
* Based on publicly available information, shares of PBZ CROATIA OSIGURANJE d.d. – Obvezni mirovinski fond, Category A and
Category B, are held in the bank's custody account.
Source: Centralna klirinško depotna družba
As at 31 December 2025, Zavarovalnica Triglav had 8,748 shareholders from 30 countries, 530
more than at year-end 2024.
The free float, representing the minority shareholders, accounted for 37.4% of ZVTG shares (the
same as the previous year). After deducting the stake of the third largest shareholder, the
pension fund, the free float stood at 29.0% (compared to 30.6% as at 31 December 2024).
0.38%
0.57%
0.62%
0.69%
0.76%
1.09%
1.23%
8.40%
28.09%
34.47%
Forplan d.o.o., Slovenia
NLB Skladi - Slovenija mešani, Slovenia
OTP Banka d.d., Croatia - fiduciary account
Citibank N.A., Great Britain - fiduciary account
Clearstream Europe AG, Germany
Intercapital Securities Ltd., Croatia - fiduciary account
Hrvatska poštanska banka, Croatia – fiduciary account
Erste Group Bank, Austria – fiduciary account*
SDH, Slovenia
ZPIZ Slovenije, Slovenia
Ownership in %
66
As at 31 December 2025, international shareholders held 14.8% of all ZVTG shares, 1.1
percentage points lower than at 31 December 2024. Among them were approximately 30
international banks with fiduciary accounts held on behalf of their clients, as well as
institutional investors, primarily from Europe and the United States.
In recent years, Slovenian retail shareholding has gradually increased, a trend that continued in
2025, with their stake rising by 0.7 percentage points to 14.5%. The share of Slovenian
institutional shareholders stood at 8.2%, up by 0.4 percentage points relative to the previous
year.
Zavarovalnica Triglav’s shareholder structure as at 31 December 2025
Source: Centralna klirinško depotna družba
The members of Zavarovalnica Triglav's Management Board held a total of 7,224 ZVTG shares as
at 31 December 2025. In 2025, ZVTG shares were bought by President of the Management Board
Andrej Slapar and Management Board members Uroš Ivanc and Tadej Čoroli. The members of
the Supervisory Board of Zavarovalnica Triglav do not hold any ZVTG shares.
The number of shares held by the members of the Management and Supervisory Boards as at 31
December 2025
Name and surname
Function
Number of shares
Participating
interest
Andrej Slapar
President
2,020
0.01%
Uroš Ivanc
Member
1,390
0.01%
Tadej Čoroli
Member
800
0.00%
Marica Makoter
Member
150
0.00%
Blaž Jakič
Member
2,864
0.01%
Management Board
7,224
0.03%
Supervisory Board
0
0.00%
Total Management Board and Supervisory Board
7,224
0.03%
6.4 Dividends and the dividend policy
At Zavarovalnica Triglav, the dividend policy is regarded as a firm commitment to its
shareholders. The Company strives to implement its dividend policy consistently, thereby
62.6%
14.8%
14.5%
8.2%
Two state-owned funds
International shareholders
Slovenian retail investors
Slovenian institutional shareholders
67
fulfilling shareholders' expectations of the ZVTG share as a stable, safe and profitable long-term
investment.
Zavarovalnica Triglav's dividend policy provides as follows: "The Company pursues an attractive
and sustainable dividend policy. The part of consolidated net profit of the preceding year which is
to be allocated to dividend payment accounts for at least 50%. The Company will strive to pay out
a dividend no lower than the dividend paid out in the preceding year. As thus far, the future
implementation of the dividend policy will be subordinated to achieving the medium-term
sustainable target capital adequacy of the Triglav Group. The proposal of the Management Board
and the Supervisory Board as regards the annual distribution of accumulated profit of the
Company will therefore take into account the following three objectives in a balanced manner: to
ensure prudent capital management of the Triglav Group and its financial stability, to reinvest net
profit in the implementation of the strategy of growth and development of the Triglav Group and
to pay out attractive dividends to its shareholders."
The strategic objectives of capital management in conjunction with the dividend policy are
described in Section 9.2 Capital position.
In recent years, the implementation of the dividend policy has been influenced by exceptional
circumstances resulting from the COVID-19 pandemic and one-off events that affected the
Group's results. The Management Board and the Supervisory Board took these circumstances
into account when proposing the distribution of accumulated profit for the year, while the
General Meeting of Shareholders supported their proposals every year. In 2025, the General
Meeting of Shareholders approved the proposal of the Management Board and the Supervisory
Board to pay a dividend of EUR 2.80 gross per share, or a total of EUR 63.7 million (see Section
5.3.1 General Meeting of Shareholders for more information).
Gross dividend per share by year (EUR), its share of consolidated net earnings for the preceding year
for the dividend payment and the dividend yield in 2013–2025
6.5 Investor relations management
The Company aims to provide clear and consistent information to the market. All key
information about the Company's operations, financial position and outlook is regularly
published in both Slovenian and English on the SEOnet information system of the Ljubljana Stock
Exchange and on the Company's website (www.triglav.eu), which is continuously enhanced.
Through the proactive engagement with investors, shareholders and analysts, the Company
promotes the attractiveness of its financial instruments. In doing so, it follows best international
2.00
1.70
2.50
2.50 2.50 2.50 2.50 0,00 1.70 3.70 2.50 1.75 2.80
63%
56%
67%
64%
69%
82%
70%
0%
53%
74%
51%
247%
49%
0,00
0,50
1,00
1,50
2,00
2,50
3,00
3,50
4,00
0%
50%
100%
150%
200%
250%
300%
2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025
Gross dividend per share (in EUR) % of consolidated net profit for the previous year
10.5%
Dividend yield EOY
7.2%
4.3%
10.6%
10.8%
8.7%
8.3%
7.5%
0.0%
4.6%
10.7%
7.2%
4.7%
68
practices and, as a company listed on the Ljubljana Stock Exchange Prime Market, helps to shape
the standards of the Slovenian market.
Open and constructive relationships with shareholders, investors and analysts are maintained
through numerous videoconferencing meetings, conference calls and email communication. In
2025, the Company organised or attended 15 investor events targeting retail and institutional
investors. A calendar of all investor events, including related presentations, is available at
(www.triglav.eu). In early 2025, the first in-person Capital Markets Day 2025 was held for
institutional investors and analysts, featuring a presentation of the Triglav Group's strategic
ambitions and initiatives through to 2030. Regular virtual meetings with investors were held
following the announcement of financial results, along with an additional meeting dedicated to
presenting the entry into the Italian motor vehicle insurance market. The Group also
participated, both virtually and in person, in conferences for institutional investors organised by
other organisers in Ljubljana, Zagreb, Japan and Austria. Special attention was given to retail
investors; the ZVTG share was presented to them in 2025 at three dedicated events specifically
organised for this audience.
The aim is to ensure the highest possible participation in general meetings of shareholders. In
2025, 77% of all shares with voting rights were represented (see Section 5.3.1 General Meeting
of Shareholders for more information).
Information for shareholders and investors:
Zavarovalnica Triglav d.d., Ljubljana
Miklošičeva cesta 19, 1000 Ljubljana
Helena Ulaga Kitek, Director of Investor Relations Department
Telephone: +386 1 47 47 331
Email: investor.relations@triglav.si
6.6 Credit rating of the Triglav Group and Zavarovalnica Triglav
The credit ratings of the Triglav Group – and thus its parent company Zavarovalnica Triglav and
its subsidiary Pozavarovalnica Triglav Re – are assigned by two renowned credit rating agencies:
S&P Global (hereinafter: S&P) and AM Best. In its regular review in June 2025, S&P upgraded the
Triglav Group's financial strength rating and issuer credit rating from "A" to "A+", while AM Best
reaffirmed its "A" rating at the beginning of October 2025. Both credit ratings carry a stable
medium-term outlook.
Credit ratings of Zavarovalnica Triglav since 2008
Year
Credit
rating
Medium-term outlook
Rating agency
2025
A
Stable
AM Best
A+
Stable
S&P Global
2024
A
Positive
S&P Global
Stable
AM Best
Stable
S&P Global
2023
A
Stable
AM Best
S&P Global
2022
A
Stable
AM Best
S&P Global
2021
A
Stable
AM Best
S&P Global
2020
A
Stable
AM Best
S&P Global
69
Year
Credit
rating
Medium-term outlook
Rating agency
2019
A
Stable
AM Best
S&P Global
2018
A
Stable
AM Best
S&P Global
2017
A
Stable
AM Best
S&P Global
2016
A
Stable
AM Best
S&P Global
2015
A-
Positive
AM Best
S&P Global
2014
A-
A-
Positive
AM Best
Stable
S&P Global
2013
A-
Stable
S&P Global
Stable
AM Best
BBB+
Positive
S&P Global
2012
A-
Negative
S&P Global
2011
A
Negative
S&P Global
2010
A
Stable
S&P Global
2009
A
Stable
S&P Global
2008
A
Stable
S&P Global
The latest credit rating information for 2025 is available on the website www.triglav.eu under
the Investor Relations tab.
6.7 Bonds
Zavarovalnica Triglav issued two subordinate bonds, which are included in own funds for the
purpose of calculating capital adequacy under Solvency II. The bonds were issued as part of the
Group's regular capital management to ensure the capital's optimal composition and cost
efficiency. The first bond was issued in 2019 and the second in early July 2024.
In June 2025, S&P Global raised the ratings on both Triglav's subordinated bonds from "BBB+" to
"A–". See the table below for more information.
Bond of Zavarovalnica Triglav
ISIN
XS1980276858
XS2848005166
Type
Subordinated bond (Tier 2 pursuant to the
Solvency II regulations)
Subordinated bond (Tier 2 pursuant to the
Solvency II regulations)
Issue size in EUR
50,000,000
100,000,000
Currency
EUR
EUR
Coupon rate and payment
Fixed at 4.375% annually until first call date,
payable annually
Fixed at 6.70% annually until first call date,
payable annually
Thereafter variable at 3-month Euribor plus
4.845% (equal to the original initial credit
spread + 1 percentage point), payable quarterly
Thereafter variable at 3-month Euribor plus
4.937% (equal to the original initial credit
spread + 1 percentage point), payable quarterly
First call date
22 October 2029
16 January 2035
Maturity date
22 October 2049
16 January 2045
Maturity in years
30.5
20.5
Regulated market
Luxembourg Stock Exchange
Luxembourg Stock Exchange
70
Credit rating
A- (S&P Global, June 2025)
A- (S&P Global, June 2025)
7. Macroeconomic environment and market trends
- Despite uncertainty in financial markets, the Triglav Group increased the value of its
financial investments and assets under management, as well as its investment result.
- The Group maintained its leading position in the insurance markets in Slovenia and
Montenegro.
- Premium growth was recorded across most insurance markets in the Adria region.
7.1 The general economic environment globally and in Slovenia
In 2025, the global economy demonstrated more resilient growth than initially expected. This
was accompanied by numerous uncertainties, primarily related to the introduction of new
import tariffs by the US administration and the resulting trade war, as well as to military
conflicts in Ukraine and the Middle East. In March, Germany and the European Union presented
plans for substantial defence investments, with Germany also announcing significant
infrastructure investments. In September, attention focused on relatively highly indebted France
following the resignation of the French Prime Minister, shortly followed by the United States,
where political disagreements led to a federal government shutdown lasting more than a
month.
Based on the latest estimates by international institutions, the euro area recorded
approximately 1.5% real GDP growth in 2025. Economic activity strengthened more noticeably
at the beginning of the year, primarily due to expectations of higher US import tariffs, and then
moderated later in the year. Private consumption and investment expenditure grew solidly.
Growth in private consumption was supported by rising real household income and favourable
labour market conditions, while investment activity was supported by favourable financing
conditions and stronger demand. Unemployment in the euro area, measured by Eurostat, fell to
6.3% in November, one of the lowest levels on record, while headline inflation in December was
moderate at 2.0% year-on-year. In its latest forecast in December 2025, the European Central
Bank projected real GDP growth of 1.4% for 2025 and 1.2% for the following year, with moderate
annual headline inflation of 2.1% and 1.9%, respectively.
In contrast to the stronger growth in the euro area, Slovenian economic growth was relatively
modest at around 1%. At the beginning of the year, it was marked by reduced foreign demand
and deteriorating export competitiveness. Private consumption, supported by high employment
and accelerated growth in real income, mitigated the decline in economic activity throughout
the year. According to Eurostat, unemployment in Slovenia was 5.0% in November, while
headline inflation reached 2.6% year-on-year in December. In its latest December forecast, the
Bank of Slovenia projected real GDP growth of 1.0% for 2025 and a stronger 2.2% for the
following year, with relatively moderate annual headline inflation of 2.5% and 2.3%,
respectively.
On global financial markets, investor sentiment remained largely positive despite prevailing
uncertainties. In the first half of the year, the European Central Bank continued to lower its key
interest rate, reducing it by a total of two percentage points, and maintained it at 2.0% from June
onwards. The US Federal Reserve (FED) only began lowering its target interest rate range in
September and had reduced it by 1.75 percentage points by the end of the year, to a range of
3.50–3.75%.
Required yields on long-term euro government bonds rose noticeably in the first days of March,
gradually declined in the second quarter, and began rising again by the end of the year. The 10-
71
year German bond ended the year with a yield of 2.85%, 0.49 percentage points higher than at
the start of the year. The spread between the 10- and 2-year German bonds widened to 0.73
percentage points. The ten-year Slovenian and Italian government bonds remained largely
unchanged compared with the beginning of the year, finishing at 3.15% and 3.55%, respectively,
while the yield on the French bond of the same maturity rose by 0.37 percentage points, to
3.56%.
Corporate bond spreads narrowed slightly from their relatively low levels at the beginning of the
year, while global stock indices recorded notable annual gains despite a temporary downturn in
April. Measured in local currency, the Japanese NIKKEI, German DAX and US S&P 500 rose by
26.2%, 23.0% and 16.4%, respectively. The Chinese Hang Seng increased by 27.8% and the
Slovenian SBITOP index recorded an exceptionally high increase of 50.3%.
7.2 Environmental impact on the Triglav Group's operations
The Group's business result was impacted by CAT events in a total estimated value of EUR 42.8
million (2024: EUR 45.5 million). Of this, hailstorms in Slovenia accounted for EUR 21.6 million in
claims. Reinsurance claims were estimated at EUR 21.2 million, primarily due to the earthquake
in Myanmar and Thailand, the June floods in Central Europe, Typhoon Ragasa in Taiwan, Hong
Kong and China, Hurricane Melissa in the Caribbean, Storm Amy in Scandinavia, floods in
Southeast Asia, and Typhoon Ditwah in Sri Lanka and India. The net effect of CAT events
amounted to EUR 41.6 million (in the previous year amounted to EUR 41.0 million).
Volatile financial market conditions did not have a significant impact on the Group's and the
Company's investment result, owing to the conservative investment policy.
7.3 Global insurance market
According to the latest official data from the Swiss Re reinsurance company, total premium
volume in the global insurance market reached USD 7.8 trillion in 2024, recording a 5.2% growth
in real terms year-on-year (7.2% nominal growth). Non-life insurance premium rose by 4.7%,
while life insurance premium increased by 6.1%. Advanced markets accounted for 81% of global
insurance premiums, achieving 4.3% premium growth, while emerging markets grew by 9.6%.
Written premium in the euro area increased by 6.4% in real terms compared to the previous year.
The US holds the largest share of the global insurance market at 44.8% (2023: 44.9%), followed
by China (10.2%), the UK (6.2%), Japan (4.4%) and the EU markets, France (3.8%) and Germany
(3.4%).
Swiss Re estimates that global premium growth was 2.0% in 2025. Demand for insurance is
being restrained by negative global economic growth trends, geopolitical risks and heightened
protectionist risks, which limit international trade flows. In the non-life insurance market, Swiss
Re expects a gradual moderation in premium growth following years of stronger premium rate
increases. Despite higher interest rates, which have a positive effect on demand for savings-type
life insurance products, policyholder uncertainty in 2025 is expected to result in minimal growth
in life insurance premium. Swiss Re forecasts a global premium growth of 2.3% in 2026, with
slightly higher growth in life insurance.
72
Real global premium growth in 2023–2026
Source: Swiss Re, SIGMA 2/2025
7.4 Triglav Group's key insurance markets
The Triglav Group operates in Slovenia, the region and the wider international environment,
with a strategic focus on strengthening business outside Slovenia. In the Adria region, the
Group's companies sell insurance products and services across seven insurance markets in six
countries: Slovenia, Croatia, Serbia, Montenegro, Bosnia and Herzegovina, and North
Macedonia. In the wider international environment, the Group operates through Zavarovalnica
Triglav's branch in Greece and via partnerships with foreign insurance brokerage, agency and
reinsurance companies, where Triglav RE also operates alongside the parent company.
Within the Adria region, the Slovenian insurance market is the most developed, while the other
markets are less developed and therefore offer business potential.
Main macroeconomic data for 2025 by Triglav Group insurance market and in the EU
Macroeconomic indicators
Slovenia
Croatia
Serbia
Montenegro
Bosnia and
Herzegovina
North
Macedonia
European
Union
Population (in million)
2.1
3.9
6.5
0.6
3.4
1.8
450.7
GDP growth (estimate, in %)
1.1
3.1
2.4
3.2
2.4
3.4
1.4
2025 GDP (estimate, in USD billion)
79.2
103.9
100.0
9.4
33.2
18.8
21,096.8
2025 GDP per capita (estimate, in USD)
37,178
26,958
15,322
14,986
9,648
10,378
64,870.5
2025 inflation rate (in %)
2.5
4.4
4.6
4.1
4.0
3.9
2.4
2025 unemployment rate (in %)
3.8
5.0
8.6
10.1*
12.6
12.8
n.a.
Source: International Monetary Fund (IMF), World Economic Outlook, October 2025, *Agency for Statistics of Montenegro (Q3 2025)
The Triglav Group is the leading insurance group in the Adria region, with the details of its
market position in individual regional markets shown in the table.
3.8%
4.1%
3.6%
5.2%
4.7%
6.1%
2.0%
2.6%
1.0%
2.3%
2.3%
2.4%
Total Non-Life insurance Life insurance
2023 2024 2025 estimate 2026 forecast
73
Market shares and market position of the Triglav Group in the Adria region in 2025
Market
Market share
Market share trend
Ranked in 2024
Ranked in 2023
Slovenia*
34.8%
-1.0-percentage point
1
1
Croatia***
4.6%
-0.2-percentage point
8
8
Serbia**
7.7%
0.0-percentage point
5
5
Montenegro
32.7%
-1.9-percentage point
1
1
Bosnia and Herzegovina
7.3%
-1.0-percentage point
6
5
- Federation of BiH
9.4%
-0.3-percentage point
4
4
- Republic of Srpska****
3.1%
-2.3-percentage point
17
8
North Macedonia**
13.9%
-0.4-percentage point
3
3
* Premium written in Slovenia.
** Data for January–September 2025.
** Market share calculations for the Croatian insurance market are based on premium paid.
*** Including the market shares of Triglav Osiguranje, Banja Luka and the branch of Triglav Osiguranje, Sarajevo in Banja Luka.
Presented below are the characteristics of individual markets and the market position of Group
members.
7.4.1 Slovenia's insurance market
The well-developed Slovenian insurance market represented 0.2% of the euro area market,
where the premium per capita (insurance density) stood at EUR 2,565 (2023: EUR 2,327) and the
premium accounted for 6.5% of GDP (2023: 6.2%).
In 2024, premium per capita in Slovenia reached EUR 1,281. Premium as a percentage of GDP
stood at 4.1% (0.8 percentage points lower than in 2023), reaching its lowest level since 2003.
This decline resulted from the termination of supplemental voluntary health insurance as of 1
January 2024. Excluding the impact of this change, the non-life insurance market grew by 13.5%
in 2024. The life insurance sector has recorded growth for the third consecutive year, with a 5.5%
increase over the past year.
Development of Slovenia's insurance market
Premium per capita (data for 2024)
EUR 1,281
Premium as percentage in GDP (data for 2024)
4.1%
Insurance market growth index in 2025
106.6
Source: Slovenian Insurance Association (SZZ)
As at 31 December 2025, a total of 10 insurance companies, five foreign branches, two
reinsurance companies and two pension companies operated in Slovenia's insurance market, all
members of the Slovenian Insurance Association (SZZ). These data exclude direct insurance
transactions of insurers from other EU Member States (FOS).
Insurance companies collected EUR 2.7 billion in gross written insurance, coinsurance and
reinsurance premiums, up by 6.6% year-on-year (this calculation does not take into account
internal transfers of assets for the payment of pension annuities). The highest premium growth
was recorded in health insurance (17.7%), followed by capital redemption insurance, unit-linked
life insurance and real property insurance.
The Slovenian insurance market remains highly concentrated, with the four largest insurers
holding a 79.5% market share. Zavarovalnica Triglav has the leading position with a 32.4%
market share, while the Group ranks first among insurance groups with a 34.8% market share
(the parent company and Triglav, pokojninska družba).
74
The market share of the Triglav Group and Zavarovalnica Triglav in 2025 and premium growth of
the Slovenian market and the Triglav Group (based on written gross premium collected in the
Slovenian market)
Triglav Group
Zavarovalnica Triglav*
Growth index 2025/2024
Market share
Change
Market share
Change
Slovenian
market
Triglav Group
Non-life insurance
36.7%
-1.2 p.p.
36.7%
-1.2 p.p.
105
102
Non-life insurance - excluding health
insurance
36.8%
-1.3 p.p.
36.8%
-1.3 p.p.
105
101
Health insurance
34.3%
+0.9 p.p.
34.3%
+0.9 p.p.
118
121
Life insurance
31.0%
-0.4 p.p.
23.8%
-2.7 p.p.
110
108
Total
34.8%
-1.0 p.p.
32.4%
-1.8 p.p.
107
104
* In the calculation of market share, pension insurance contracts are considered as insurance premium, whereas under IFRS 17 they are
financial contracts under the "fund inflows" item.
The market shares of insurers and insurance groups in Slovenia in 2025 and comparison with the
previous year
Source: Slovenian Insurance Association (SZZ)
Among supplemental voluntary pension insurance providers, Triglav, pokojninska družba held a
30.0% market share as at 31 December 2025 (0.2 percentage point lower than the previous year).
As at 31 December 2024, Pozavarovalnica Triglav Re held a market share of 59.9% in the
Slovenian reinsurance market, recording an increase of 0.2 percentage points year-on-year.
7.4.2 Croatia
In 2025, GDP growth was 3.1%, according to the International Monetary Fund (IMF), and is
expected to gradually trend down to 2.6% by 2027. The main drivers of growth were domestic
consumption and investment, while net exports are expected to contribute negatively due to
higher imports of services and weaker price competitiveness in tourism.
Inflation in 2025 was slightly higher than in 2024, primarily due to rising food and energy prices.
This was mainly driven by administrative increases in gas, electricity and heating prices at the
end of 2024 and in early 2025. As a result, the inflation rate rose to 4.4% in 2025 and is expected
to gradually decline to 2.4% by 2027. Core inflation, which excludes energy and food prices, is
6.1%
2.5%
3.5%
6.8%
17.0%
28.3%
35.8%
6.1%
2.5%
3.9%
6.9%
17.0%
28.7%
34.8%
Others
Merkur
Grawe
Modra zavarovalnica
Generali
Sava Insurance Group
Triglav Group
2025 2024
75
expected to continue slowing, supported by moderating growth in industrial goods and service
prices.
The labour market remained robust. According to IMF projections, the unemployment rate is
expected to stabilise at 5% in the coming years. Following an exceptional 15% nominal increase
in 2024, salary growth moderated to 9.5% nominally, or 6.5% in real terms. The main inflation
risks remain linked to geopolitical tensions, energy prices, and trends in tourism and exports.
The country's sovereign rating is assessed as investment grade by all rating agencies. As of March
2025, Croatia held an A rating with stable or positive outlooks from both Fitch and Standard &
Poor's (S&P).
Insurance market
Development of Croatia's insurance market
Premium per capita (data for 2024)
EUR 497
Premium as percentage in GDP (data for 2024)
2.2%
Insurance market growth index in 2025
107.5
Source: Croatian Insurance Bureau
As at 31 December 2025, a total of 14 insurance companies were active in the Croatian market,
comprising nine composite insurers, four non-life insurers and one life insurer. Their total
written premium was 7.5% higher than the year before (market share calculations for Croatia's
insurance market are based on premium paid). Non-life and life insurance premiums increased
by 9.1% and 0.2%, respectively. In total written premium, non-life insurance premium rose to
83.8% (2024: 82.6%), while life insurance accounted for the rest.
Market concentration remained high, with the top three insurers controlling 51% of the market.
Croatia osiguranje continued to hold the dominant position with a 25.9% market share (up 0.5
percentage points from the previous year). Triglav Osiguranje, Zagreb retained eighth place with
a 4.6% market share, (down 0.2 percentage points year-on-year).
7.4.3 Serbia
According to IMF estimates, real GDP growth in 2025 stood at 2.4%. In 2026, growth is expected
to reach 3.6%, accelerating further to 4.6% by 2027, predominantly due to the impact of Expo
2027.
Inflation in 2025 was 4.6% year-on-year, remaining within the target range. The labour market
remained stable, with the unemployment rate at 8.6% and a high labour force participation rate
of 73.1%. Average real salary growth in the first nine months of the year was 6.5% year-on-year.
The country's sovereign rating remained in the investment-grade range, confirming the stability
of its fiscal policy. In July 2025, Fitch reaffirmed Serbia’s credit rating at BB+ with a positive
outlook.
Insurance market
Development of Serbia's insurance market
Premium per capita (data for 2024)
EUR 231
Premium as percentage in GDP (data for 2024)
1.8%
Insurance market growth index in Q1-Q3 2025
108.5
Source: National Bank of Serbia
76
Serbia's insurance market was highly concentrated, with 16 insurance companies active (six
composite insurers, six non-life insurers and four life insurers). The top four insurers controlled
two-thirds of the market. Total written premium increased by 8.5% in the first nine months of
2025. Non-life insurance premium recorded strong growth of 9.9%, while life insurance premium
grew by 2.2%. Non-life insurance premium accounted for 83.3% of total written premium, up
from 82.3% in the preceding year.
Triglav's insurer in Serbia, Triglav Osiguranje, Belgrade, achieved a 7.7% market share,
maintaining its fifth place.
7.4.4 Montenegro
According to IMF estimates, GDP growth in Montenegro stood at 3.2% in 2025, with the same
rate projected for 2026. The main drivers of growth were transport, trade and construction, while
tourism and industrial production recorded declines.
IMF data indicate that inflation in 2025 was 4.1% and is expected to decline to 2.3% by 2027.
Positive trends in the labour market continued throughout 2025. Following a record low
unemployment rate of 11.5% in 2024, it further declined to 10.1% by the end of the third quarter
of 2025. Average net salary showed steady growth.
In March 2025, S&P affirmed Montenegro's credit rating at B+ with a stable outlook.
Insurance market
Development of Montenegro's insurance market
Premium per capita (data for 2023)
EUR 215
Premium as percentage in GDP (data for 2023)
1.8%
Insurance market growth index in 2025
110.5
,3
Source: Insurance Supervision Agency of Montenegro
As at 31 December 2025, nine insurance companies were active in Montenegro's insurance
market (five non-life insurers and four life insurers), generating 10.5% more written premium
than the year before. The non-life premium volume grew by 11.3% and the life premium volume
increased by 10.3%. In total written premium, non-life insurance continued to account for the
bulk (79.1%).
The Triglav Group, represented by Lovćen Osiguranje and Lovćen životna osiguranja in
Montenegro, maintained its leading position in the market, securing a 32.7% market share
(compared to 34.6% in the previous year). The Group is followed by Sava Osiguranje and Uniqa
Group (combined non-life and life insurers) with market shares of 17.6% and 17.0%, respectively.
7.4.5 Bosnia and Herzegovina
According to the latest IMF estimates, economic growth in 2025 amounted to 2.4% and is
projected to accelerate to around 3.0% by the end of 2027. Private consumption remains the
main driver of growth, supported by rising salaries and inflows from abroad.
Inflation in 2025 was 4.0%, compared with 2.2% in the previous year, and is expected to
moderate to 2.0% by 2027. The largest contribution to inflation comes from domestic prices of
services and food. The unemployment rate remained high at 12.6%, although showing signs of
gradual improvement. Salary growth and income from abroad continued to be key drivers of
consumption.
77
In August 2025, S&P affirmed Bosnia and Herzegovina's credit rating at B+ with a stable outlook.
Insurance market
Development of Bosnia and Herzegovina's insurance market
Premium per capita (data for 2024)
EUR 175
Premium as percentage in GDP (data for 2024)
2.1%
Insurance market growth index in 2025
108.0
Source: FBIH Insurance Supervision Agency, RS Insurance Agency
As at 31 December 2025, a total of 24 insurance companies were active on the small but highly
competitive insurance market of Bosnia and Herzegovina, of which 10 were domiciled in the
Federation of BiH and 14 in Republika Srpska, including branches. In the BiH market as a whole,
written premium increased by 8.0%, with premium in the Federation of BiH growing by 7.9% and
in Republika Srpska by 8.3%. Non-life insurance premium continued to dominate total written
premium, accounting for 81.4%.
In Bosnia and Herzegovina, the Triglav Group held a 7.3% market share (a decrease of 1.0
percentage point year-on-year), ranking sixth among the insurance groups.
7.4.6 North Macedonia
According to IMF estimates, economic growth in North Macedonia was 3.4% in 2025. Growth is
expected to remain stable at 3.2% through 2027.
Inflation in North Macedonia has been variable in recent years; IMF estimates put it at 3.9% in
2025, with a projected decline to 2.2% by 2027. According to the latest available data, the
unemployment rate was 12.8% in 2025, compared with 13.0% in the previous year.
In 2025, S&P and Fitch assigned North Macedonia credit ratings of BB with a stable outlook and
BB+ with a stable outlook, respectively.
Insurance market
Development of North Macedonia's insurance market
Premium per capita (data for 2024)
EUR 145
Premium as percentage in GDP (data for 2024)
1.7%
Insurance market growth index in Q1-Q3 2025
113.3
Source: Insurance Supervision Agency of North Macedonia
A total of 17 insurance companies were active in North Macedonia's insurance market (11 non-
life insurers and six life insurers). Total written premium increased by 13.3% in the first nine
months of 2025. Non-life insurance premium, accounting for 83.5% of total written premium
(0.4 percentage points lower than the previous year), grew by 13.8%, while life insurance
premium rose by 10.6%.
The Triglav Group operates in the market through two insurance companies, which together
achieved a 13.9% market share (14.3% the previous year), maintaining third place among
insurance groups. Triglav Osiguruvanje, Skopje, holding a 10.1% market share (down 0.3
percentage points year-on-year), ranked fourth among insurers. Specialising in non-life
insurance, it holds a 12.1% market share. Triglav Osiguruvanje Život, Skopje increased its share
in the life insurance market to 23.1% (2024: 22.6%), supported by premium growth (index 113).
78
7.5 The asset management and investment fund market in Slovenia
The asset management and investment fund market in Slovenia experienced further growth in
assets under management in 2025, driven by favourable developments on capital markets and
increased investor interest in long-term investment solutions. As at 31 December 2025, five
asset management companies were operating in Slovenia, with total assets in mutual funds
reaching EUR 7.2 billion, representing a 15.8% increase compared with 2024.
As at the reporting date, Triglav Investments managed total assets of EUR 3.0 billion (index 137)
through mutual funds and discretionary mandates. In the investment fund segment, the
company managed EUR 2.1 billion, achieving a 29.1% market share. The company remains
among the leading asset managers in the Slovenian market, with its asset growth aligned with
overall market expansion.
The Group recorded a particularly pronounced shift in the discretionary mandate segment, a key
strategic focus. As at 31 December 2025, total assets in this segment amounted to EUR 3.2
billion, of which Triglav Investments managed EUR 943.2 million, representing a 29.7% market
share (2024: 12.7%). This has significantly strengthened the company's position within a single
year, placing it among the leading asset managers in this segment as well.
79
8. Operations of the Triglav Group and Zavarovalnica
Triglav
- In 2025, the Triglav Group delivered strong performance, achieving earnings before tax of
EUR 174.1 million, a 9% increase compared with the previous year.
- Total business volume increased by 49%, with organic growth recorded in all business
segments.
- The combined ratio for the Group's Non-Life and Health segments stood at favourable
93.2%.
In 2025, the Group delivered strong performance, achieving earnings before tax of EUR 174.1
million (2024: EUR 159.0 million). Net earnings amounted to EUR 136.7 million (2024: EUR 131.4
million). The Group was profitable across both activities and the majority of business segments,
with the exception of the Health segment. In 2024, EUR 142.9 million of earnings before tax
related to continuing operations, while EUR 16.1 million related to discontinued operations (the
effect of the termination of supplemental health insurance).
Higher other comprehensive income in 2025, amounting to EUR 15.4 million (2024: EUR 6.3
million), was primarily driven by higher risk-free interest rates and their impact on the
remeasurement of assets and liabilities. Risk-free interest rates increased mainly at the long end
of the yield curve, which, through remeasurement effects, led to a decrease in the value of
insurance/reinsurance liabilities and assets. The impact of the change was most pronounced in
life insurance contracts due to their long-term nature. Return on equity reached a favourable
13.2% (2024: 14.0%), reflecting the increase in net earnings.
Total business volume rose by 49% to EUR 2,561.2 million. The main contributor to the increase
was strong 53% growth in gross written insurance, coinsurance and reinsurance premiums,
predominantly driven by premium growth in the Non-Life segment and in international markets.
Income from asset management also recorded strong growth (index 109), while other income
was 30% lower due to the state compensation received last year for the termination of
supplemental health insurance by insurance companies on the Slovenian market.
Total business volume of the Triglav Group by segment (EUR million)
Zavarovalnica Triglav achieved earnings before tax of EUR 142.1 million (2024: EUR 117.6
million) and net earnings of EUR 113.6 million (2024: EUR 98.2 million). Earnings before tax of
continuing operations, i.e. excluding supplemental health insurance business, amounted to EUR
101.4 million in 2024. The insurance operating result increased by 13% to EUR 95.6 million,
primarily due to strong growth in insurance revenue and an improved net reinsurance service
56.2
112.5
244.6
1,304.4
1,717.6
53.2
118.9
265.6
2,123.5
2,561.2
Health
Asset
Management
Life
Non-Life
Total
2025 2024
80
result, largely driven by higher reinsurance income due to higher income from reinsurers' share
of liabilities for incurred claims. The net investment result grew by 54% to EUR 52.1 million. Amid
volatility in financial markets, the investment result totalled EUR 64.4 million (index 48), while
the financial result from insurance contracts amounted to EUR −37.3 million (2024: EUR −110.1
million). The investment result was also affected by gains and impairments of investments in
associates, amounting to EUR 25.1 million (2024: EUR 9.0 million), primarily due to the reversal
of impairments of investments in subsidiaries (EUR 18.0 million), which has no impact on the
consolidated result. The Company's other comprehensive income amounted to EUR 6.7 million,
compared to EUR 0.7 million the year before.
Certain categories of the Group's operations and the structure of earnings generated in 2025 are
explained in more detail below.
The Group's total revenue amounted to EUR 1,694.7 million, a 22% increase, with all business
segments, except for the Health segment, showing growth. Insurance revenue increased by 24%
to EUR 1,608.8 million, income from asset management grew by 9% to EUR 53.6 million, and
other income amounted to EUR 32.4 million, down by 30% due to the state compensation
received last year.
Insurance revenue of the Triglav Group by segment (EUR million)
The Group charged EUR 2,475.0 million in consolidated gross written insurance, coinsurance and
reinsurance premiums, up by 53% year-on-year. Excluding the premium generated through on
the Italian market in cooperation with partner Prima Assicurazioni, which totalled EUR 692.9
million, premium growth would have been 10%. The Group achieved premium growth in
Slovenia, in the Adria region excluding Slovenia, and in international markets in both insurance
and reinsurance operations. In the Slovenian market, premium written increased by 4%, while
the international market recorded a 210% growth (reinsurance premium: EUR 346.0 million,
index 129; international insurance: EUR 825.5 million, index 756). Premium written in other
markets of the Adria region grew by 7%. Premium growth in the Adria region markets was
achieved in all insurance markets except Bosnia and Herzegovina (due to ownership
consolidation and business optimisation).
The Group successfully advanced its strategic ambition to increase the share of business
generated outside Slovenia. A total of 38.2% of premium earned in the Slovenian insurance
market (2024: 56.0%) and 14.5% in the remaining markets of the Adria region (2024: 20.7%). The
share of international insurance and reinsurance in total gross written premium increased by
24.1 percentage points to 47.3%, with international insurance growing by 26.6 percentage
points to 33.4% and reinsurance premium decreasing by 2.6 percentage points to 14.0%.
43.3
98.4
1,156.3
1,298.0
50.2
105.9
1,452.7
1,608.8
Health
Life
Non-Life
Total
2025 2024
81
Gross written premium of the Triglav Group by market (EUR million)
Composition of the Triglav Group gross written premium by market
909.2
114.9
91.3
47.0
46.4
35.9
109.2
268.3
944.3
124.2
103.3
44.8
48.5
38.5
825.5
346.0
Slovenia Serbia Croatia Bosnia and
Herzegovina
Montenegro North
Macedonia
International
insurance
Reinsurance
2024 2025
2.2%
2.9%
2.9%
5.6%
7.1%
23.3%
56.0%
1.6%
1.8%
2.0%
4.2%
5.0%
47.3%
38.2%
North Macedonia
Bosnia and Herzegovina
Montenegro
Croatia
Serbia
International insurance and
reinsurance
Slovenia
2025 2024
82
Gross written premium structure for international insurance
Insurance service expenses rose by 35% to EUR 1,336.0 million. The highest growth, at 37%,
recorded in the Non-Life segment, with strong growth also observed in the Health segment
(index 131). More detailed information can be found in the sections on the performance results
of individual segments.
Insurance service expenses of the Triglav Group by segment (EUR million)
The Group's combined ratio for the Non-Life and Health segments stood at favourable 93.2%,
down by 0.4 percentage points year-on-year. Despite favourable claims development, the claims
ratio increased by 0.9 percentage points (to 66.4%), primarily due to a change in international
insurance portfolio. The expense ratio decreased by 1.3 percentage points to 26.8%, as the
growth in insurance revenue significantly outpaced the growth in expenses and net insurance
service expenses.
40.1
66.2
885.5
991.8
52.4
72.4
1,211.2
1,336.0
Health
Life
Non-Life
Total
2025 2024
22.1%
23.7%
51.6%
2.7%
4.6%
3.6%
7.4%
84.4%
Other
Greece
Poland
Italy
2025 2024
83
Combined ratio for the Non-Life and Health segments of the Triglav Group
Combined ratio for the Non-Life and Health segments of the Triglav Group by market
The combined ratio for the Non-Life and Health segments decreased across most insurance
markets. The largest decrease was recorded in the Croatian market, mainly due to an improved
claims ratio driven by higher insurance revenue and lower claims incurred, whereas the expense
ratio increased slightly. The combined ratio deteriorated slightly in the Bosnia and Herzegovina
market, mainly due to a higher expense ratio, and in Slovenian insurance and reinsurance
companies due to a higher combined ratio in international operations.
The Group's CSM of new contracts amounted to EUR 47.6 million, down by 3% year-on-year,
mainly due to slightly lower sales of regular premium life insurance in the Company. The share
of the CSM for new contracts in the total contractual service margin was 15.5% (2024: 17.0%),
reflecting an increase in the contractual service margin compared to 31 December 2024, which
rose by 7%. The release of the contractual service margin to profit or loss amounted to EUR 53.8
million in the reporting period, up by 12.8% year-on-year.
The Group's contractual service margin of insurance contracts amounted to EUR 306.7 million, a
7% increase relative to 31 December 2024.
65.5%
66.4%
28.1%
26.8%
2024 2025
Expense ratio
Claims ratio
93.6%
93.2%
92.8%
104.5%
98.7%
94.7%
97.9%
97.7%
93.0%
99.6%
97.1%
95.4%
95.5%
94.8%
Slovenia Croatia Serbia Bosnia and
Herzegovina
Montenegro North Macedonia
2024 2025
International insurance
and reinsurance: 95.3%
84
Earnings before tax of the Triglav Group
Structure of earnings before tax of the Triglav Group
2025
2024
Non-Life
Life
Health
Asset
Management
Total
Non-Life
Life
Health
Asset
Management
Total
Insurance operating result
109,054,173
20,505,823
-7,034,193
122,525,803
69,084,585
19,804,608
8,620,876
97,510,069
Insurance revenue
1,452,659,576
105,922,695
50,169,655
1,608,751,926
1,156,299,596
98,399,942
43,252,835
1,297,952,373
State compensation pursuant to the Decree on
supplemental health insurance premium
0
0
10,996,355
10,996,355
Claims incurred
898,452,514
30,461,979
35,258,115
964,172,608
627,530,982
27,161,982
23,996,976
678,689,940
Acquisition and administrative costs incl. non-att.
items
360,145,761
50,888,966
20,356,242
431,390,969
304,338,440
48,590,117
18,007,025
370,935,582
Net reinsurance service result
-63,530,495
-860,285
-361,742
-64,752,522
-139,958,713
272,006
-1,244,211
-140,930,918
Net other insurance revenue and expenses
-21,476,633
-3,205,642
-1,227,749
-25,910,024
-15,386,876
-3,115,241
-2,380,102
-20,882,219
Net investment result
33,248,539
7,965,520
503,004
3,042,620
44,759,683
32,865,549
10,523,083
1,247,919
4,355,021
48,991,572
Result from non-insurance operations
-5,593,591
240,354
608,746
11,509,691
6,765,200
-1,118,837
9,987
472,074
13,177,336
12,540,560
Insurance service expenses to insurance revenue
0
0
0
53,618,623
53,618,623
0
0
0
49,364,063
49,364,063
Operating expenses
14,306,093
7,524,121
4,541,922
40,833,941
67,206,077
13,510,736
7,818,872
3,684,670
36,417,154
61,431,432
Net other income and expenses
8,712,502
7,764,475
5,150,668
-1,274,991
20,352,654
12,391,899
7,828,859
4,156,744
230,427
24,607,929
Earnings before tax
136,709,121
28,711,697
-5,922,443
14,552,311
174,050,686
100,831,297
30,337,678
10,340,869
17,532,357
159,042,201
Earnings before tax of discontinued operations
0
16,147,704
16,147,704
Earnings before tax of continuing operations
136,709,121
28,711,697
-5,922,443
14,552,311
174,050,686
100,831,297
30,337,678
-5,806,835
17,532,357
142,894,497
The Group's insurance operating result increased by 26% to EUR 122.5 million, driven by the strong performance, with the Non-Life segment having
the greatest impact on the improvement. The Non-Life segment's insurance operating result (EUR 109.1 million) was predominantly influenced by a
26% rise in insurance revenue, attributed to business volume growth (see Section 8.1 Non-Life segment for further details), along with an improved
net reinsurance service result. The insurance operating result of the Life segment grew by 4% year-on-year to EUR 20.5 million (see Section 8.2 Life
segment for more information). In the Health segment, the insurance operating result reached EUR –7.0 million, compared to a positive EUR 8.6
million last year (see section 8.3 Health segment for more information on this and the impact of discontinued operations). Claims incurred rose by
42% to EUR 964.2 million, reflecting significant increases across all insurance segments (for more details, see the sections on the performance results
of individual business segments).
The net reinsurance service result, influenced by a favourable volume of CAT claims, amounted to EUR –64.8 million (2024: EUR –140.9 million).
Reinsurance income increased to EUR 374.2 million (2024: EUR 125.0 million), reflecting a higher reinsurers' share in claims incurred. Due to the
higher international business volume and the corresponding reinsurance protection, reinsurance service expenses also increased, amounting to EUR
438.9 million (index 165).
85
Acquisition costs and administrative costs including non-attributable items were 16% higher.
The increase was recorded across all business segments.
Despite volatility in financial markets, the net investment result totalled EUR 44.8 million (2024:
EUR 49.0 million). The investment result amounted to EUR 87.8 million (2024: EUR 159.7 million),
while the financial result from insurance contracts reached EUR −47.8 million (2024: EUR −118.5
million). These results are mainly attributable to the return on unit-linked life insurance assets,
which forms part of the total investment result but simultaneously affects the financial result
from insurance contracts in the opposite amount. See Section Investments for more information.
The result from non-insurance operations before tax totalled EUR 6.8 million (2024: EUR 12.5
million). This decrease was mainly due to higher interest on issued bonds, amounting to EUR 3.5
million, and higher asset management costs of EUR 4.4 million. Income from asset management
rose by 9% to EUR 53.6 million.
Earnings before tax of the Triglav Group (EUR million)
Earnings before tax of the Triglav Group by segments (EUR million)
97.5
49.0
12.5
159.0
122.5
44.8
6.8
174.1
Insurance operating result Net investment result Result from non-insurance Earnings before tax
2024 2025
100.8
30.3
10.3
17.5
159.0
136.7
28.7
-5.9
14.6
174.1
Non-Life Life Health Asset Management Earnings before tax
2024 2025
86
Operating expenses
The Group's consolidated operating expenses, including other attributable insurance service
expenses, increased by 15% to EUR 519.2 million (excluding operating expenses related to Prima
Assicurazioni, the increase would have been 7%). Operating expenses rose by 35% to EUR 626.9
million and other attributable insurance service expenses increased by 10% (EUR 33.5 million),
while the change in deferred acquisition costs reduced the expenses by EUR 124.2 million (index
453). The strong growth in the change in deferred acquisition costs was mainly driven by the
increased business volume with Prima Assicurazioni.
Operating expenses of the Triglav Group by nature
2025
2024
Index
Share
Acquisition costs
259,192,824
107,782,991
240
41.3%
Cost of goods sold
20,915
52,458
40
0.0%
Depreciation/amortisation costs
26,979,278
27,327,518
99
4.3%
Depreciation/amortisation costs of leased assets
5,978,214
6,054,267
99
1.0%
Depreciation/amortisation costs of other operating assets
21,001,064
21,273,251
99
3.4%
Labour costs
214,292,556
206,498,232
104
34.2%
Wages and salaries
150,187,512
143,838,211
104
24.0%
Social and pension insurance costs
32,988,143
31,205,439
106
5.3%
Other labour costs
31,116,901
31,454,582
99
5.0%
Costs of services
126,366,298
122,191,835
103
20.2%
Costs of advertising, representation and sponsorship
25,128,275
25,736,029
98
4.0%
Maintenance costs
17,991,213
16,873,880
107
2.9%
Costs of material and energy
8,245,774
8,524,083
97
1.3%
Costs of payment transactions and banking services
2,167,058
2,381,188
91
0.3%
Insurance premium costs
2,272,314
2,073,784
110
0.4%
Costs of intellectual services
9,891,150
9,466,647
104
1.6%
Training costs
1,764,691
1,704,344
104
0.3%
Expenses for short-term leases, low-value leases and other leases
11,621,606
9,396,303
124
1.9%
Costs of transport and communications services
4,796,974
5,540,728
87
0.8%
Reimbursement of labour-related costs
5,221,656
5,596,351
93
0.8%
Costs of services provided by natural persons other than sole
proprietors
2,284,109
2,186,331
104
0.4%
Other costs of services
34,981,478
32,712,167
107
5.6%
Total operating expenses (1)
626,851,871
463,853,034
135
100.0%
Other attributable insurance service expenses (2)
33,467,407
30,452,813
110
Change in deferred acquisition costs (3)
-124,150,699
-27,435,542
453
Total (1+2+3)
536,168,579
466,870,305
115
Elimination of intercompany transactions
-16,919,794
-16,023,214
106
Total consolidated (1+2+3+4)
519,248,785
450,847,091
115
Costs and other attributable insurance service expenses of discontinued
operations (5)
0
-1,177,761
Total costs and insurance service expenses of continuing operations (1 +
2 + 3 + 4 + 5)
519,248,785
449,669,330
115
Acquisition costs rose by 140% to EUR 259.2 million, driven by a higher business volume and
expansion into international markets, especially Italy. The share of these costs in operating
expenses increased to 41.3%, compared to 23.2% in the previous year. Excluding the acquisition
costs related to Prima Assicurazioni (EUR 145.5 million), their growth would have been 5%.
Labour costs accounted for 34.2% of operating expenses. They amounted to EUR 214.3 million,
up by 4% year-on-year. Total growth in employee salaries at Group level was also 4%, Labour
costs were influenced by long-term care contribution and the payment of the winter allowance
in Slovenian companies, salary adjustments and minimum wage increases in certain companies,
87
a higher number of employees in some companies, and increased payments to agents due to
premium growth.
Costs of services amounting to EUR 126.4 million increased by 3%. Among them, the bulk was
accounted for by other costs of services (EUR 35.0 million), costs of advertising, representation
and sponsorships (EUR 25.1 million), and maintenance costs (EUR 18.0 million). A significant
reduction in this cost category was achieved in costs of payment transactions and banking
services, mainly due to contractual price reductions with the bank at the parent company (index
91), costs of transport and communications services (index 87) and reimbursement of labour-
related costs (index 93). Higher growth within this cost category was recorded in expenses for
short-term leases, low-value leases and other leases (index 124), primarily in the parent company
due to higher IT lease costs and in the Macedonian insurer due to costs of early termination of
office leases. Insurance premium costs (index 110), other costs of services (index 107) and
maintenance costs (index 107) also increased in some subsidiaries.
The Group's non-consolidated operating expenses from insurance operations totalled EUR 562.6
million, up 39%, primarily due to higher attributable acquisition costs (mainly relating to the
acquisition costs of the partner company Prima Assicurazioni in the Italian market). Attributable
costs of EUR 506.3 million represented 90.0% of expenses from insurance operations, while non-
attributable costs made up the remaining 10.0%. Non-consolidated expenses from non-
insurance operations increased by 10% and amounted to EUR 64.2 million, primarily due to
higher labour costs and other costs of services were (mainly reflecting higher fees at Triglav
Investments, which are linked to the net asset value of assets under management). Other
attributable insurance service expenses (index 110) were impacted by higher expenses for fire
fee and other insurance service expenses.
88
Operating expenses of the Triglav Group
2025
2024
Operating
expenses
Other
attributable
insurance
service expenses
Changes in deferred
acquisition
costs
Elimination of
intercompany
transactions
Total
Operating
expenses
Other
attributable
insurance
service expenses
Changes in
deferred
acquisition costs
Elimination of
intercompany
transactions
Total
Attributable costs
506,344,156
33,467,407
-124,150,699
-3,536,102
412,124,762
349,515,846
30,452,813
-27,435,542
-2,873,853
349,659,264
Attributable acquisition costs
392,174,045
152,739
-124,150,699
-1,178,910
266,997,175
235,989,740
214,163
-27,435,542
-1,022,550
207,745,811
Attributable claim handling expenses
31,340,172
9,006,961
0
0
40,347,133
29,527,952
7,007,582
0
0
36,535,534
Attributable administrative costs
82,829,939
24,307,707
0
-2,357,192
104,780,454
83,998,154
23,231,068
0
-1,851,303
105,377,919
Non-attributable costs
56,284,848
0
0
-10,662,820
45,622,032
56,064,132
0
0
-10,700,778
45,363,354
Insurance operations (1)
562,629,004
33,467,407
-124,150,699
-14,198,918
457,746,794
405,579,978
30,452,813
-27,435,542
-13,574,631
395,022,618
Non-insurance operations (2)
64,222,867
0
0
-2,720,872
61,501,995
58,273,056
0
0
-2,448,583
55,824,473
Total (1 + 2)
626,851,871
33,467,407
-124,150,699
-16,919,794
519,248,785
463,853,034
30,452,813
-27,435,542
-16,023,214
450,847,091
Index
Attributable costs
145
110
453
123
118
Attributable acquisition costs
166
71
453
115
129
Attributable claim handling expenses
106
129
0
0
110
Attributable administrative costs
99
105
0
127
99
Non-attributable costs
100
0
0
100
101
Insurance operations (1)
139
110
453
105
116
Non-insurance operations (2)
110
0
0
111
110
Total (1 + 2)
135
110
453
106
115
89
Investments
The Triglav Group manages its investment portfolio conservatively to ensure adequate
investment yield, safety and liquidity, while maintaining a high credit rating for the overall
portfolio. In accordance with its sustainable development policy, environmental, social and
governance (ESG) aspects are being enhanced in investment processes.
Through active investing, the Group maintained an investment portfolio structure at year-end
2025 comparable to that at year-end 2024, with its value increasing to EUR 4,305.9 million
(index 110). The bulk of the investment portfolio, i.e. 53.3%, was accounted for by bonds. The
bond portfolio is predominantly composed of bonds from developed markets, most of which
have a high credit rating. Their value, as well as the value of the equity portfolio, was mainly
affected by the situation on the financial markets. Investments in associates and joint ventures
declined by 13%, primarily due to a decrease in the value of the investment in the associate
KATERA, which disposed of its participating interest in Nama. This participating interest was
transferred to the real estate fund Trigal RE Development Fund and to Trigal. This transfer had
the greatest impact on the increase in equity investments (index 126), which was further
supported by regular payments into alternative funds and their positive revaluation. The 87%
increase in loans granted was driven by a loan to the associate Diagnostični center Bled. The
growth of bank deposits (index 130) was driven by increased business volume with Prima
Assicurazioni. The structure of financial investments is described in greater detail in Section 2.6
of the Accounting Report.
The majority of unit-linked insurance assets is accounted for by assets invested in mutual funds
of the policyholders' choice, mainly in funds managed by Triglav Investments. As at 31 December
2025, these assets amounted to EUR 749.6 million (index 110).
As at the reporting date, financial investments from financial contracts amounted to EUR 802.5
million, up by 9% compared to 31 December 2024. They include individual and group
supplemental voluntary pension insurance contracts of Triglav, pokojninska družba. Financial
contract assets are presented in more detail in Section 2.7 of the Accounting Report.
Investments of the Triglav Group as at 31 December 2025 and 31 December 2024
Investments
Index
Share
31 Dec 2025
31 Dec 2024
2025/2024
31 Dec 2025
31 Dec 2024
Investment property
65,015,642
70,411,373
92
1.5%
1.8%
Investments in associates and joint ventures
48,652,990
55,621,373
87
1.1%
1.4%
Shares and other variable-income securities
253,168,421
200,682,891
126
5.9%
5.1%
Debt and other fixed-income securities
2,293,710,965
2,092,633,169
110
53.3%
53.6%
Loans given
12,382,941
6,622,689
187
0.3%
0.2%
Bank deposits
79,039,533
60,833,549
130
1.8%
1.6%
Other financial instruments
843,680
909,337
93
0.0%
0.0%
Total (1)
2,752,814,172
2,487,714,381
111
63.9%
63.7%
Unit-linked life insurance assets (2)
749,596,814
678,910,235
110
17.4%
17.4%
Financial investments from financial contracts (3)
802,451,207
739,510,939
109
18.6%
18.9%
Total (1 + 2 + 3)
4,304,862,193
3,906,135,555
110
100.0%
100.0%
Sustainable fixed-income investments increased by 25% to EUR 425.9 million, mainly due to the
inclusion of a new bond type – sustainability-linked bonds. The share of sustainable bonds in the
total bond portfolio rose to 15.0% (compared to 12.9% as at 31 December 2024).
90
Bond investments of the Triglav Group with sustainability characteristics
Sustainable fixed-income investments
Index
Share in debt securities
31 Dec 2025
31 Dec 2024
2025/2024
31 Dec 2025
31 Dec 2024
Green bonds *
265,536,727
221,398,009
120
9.3%
8.4%
Social impact bonds**
83,657,158
95,206,404
88
2.9%
3.6%
Sustainability linked bonds***
37,598,473
0
0
1.3%
0.0%
Sustainable bonds****
39,107,914
22,821,428
171
1.4%
0.9%
Total ESG bonds
425,900,273
339,425,841
125
15.0%
12.9%
* Green bonds are an instrument for funding environmental projects, the funds of which are intended for ecologically efficient products, technologies and processes,
pollution prevention and control, sustainable management of natural resources, sustainable management of water resources, renewable energy use, energy efficiency
and clean transport.
** Social impact bonds are an instrument for funding social services.
*** Sustainability-linked bonds are financial instruments whose repayment terms (e.g. interest rate) are tied to the achievement of pre-defined sustainability objectives
by the issuer, such as reducing emissions or increasing the share of renewable energy sources. They are not used to finance specific green projects, but to incentivise the
organisation as a whole to enhance its sustainability performance. If the objectives are not met, the interest rate may increase.
**** Sustainable bonds are an instrument for funding sustainability projects and a combination of green and social impact bonds. Funding is often conditional on
achieving sustainability goals.
As at the reporting date, the Company's investments stood at EUR 2,825.7 million, 10% higher
than the previous year.
Investments of Zavarovalnica Triglav as at 31 December 2025 and 31 December 2024
Investments
Index
Share
31 Dec 2025
31 Dec 2024
2025/2024
31 Dec 2025
31 Dec 2024
Investment property
40,382,302
44,971,145
90
1.4%
1.8%
Investments in subsidiaries
214,585,232
196,624,457
109
7.6%
7.7%
Investments in associates and joint ventures
48,652,990
55,059,388
88
1.7%
2.2%
Shares and other variable-income securities
202,892,088
152,938,524
133
7.2%
6.0%
Debt and other variable-income securities
1,580,097,966
1,450,298,136
109
55.9%
56.7%
Loans given
10,505,162
5,306,572
198
0.4%
0.2%
Bank deposits
19,113,849
7,212,864
265
0.7%
0.3%
Other financial instruments
1,584
19,810
8
0.0%
0.0%
Total (1)
2,116,231,173
1,912,430,896
111
74.9%
74.8%
Unit-linked life insurance contract investments (2)
709,479,016
645,594,699
110
25.1%
25.2%
Total (1 + 2)
2,825,710,189
2,558,025,595
110
100.0%
100.0%
Amid volatility in financial markets, the Group's investment result amounted to EUR 87.8 million
as at 31 December 2025 (compared to EUR 159.7 million as at 31 December 2024). The result
excluding unit-linked life insurance assets amounted to EUR 61.9 million, remaining at the same
level as the previous year. Taking into account the financial result from insurance contracts of
EUR –47.8 million (2024: EUR –118.5 million), gains and impairments of investments in
associates of EUR 4.7 million (2024: EUR 6.9 million), and the change in provisions for not
achieving the guaranteed yield in the amount of EUR 17 thousand (2024: EUR 908 thousand),
the impact of the investment result on the Group's earnings was positive in the amount of EUR
44.8 million (2024: EUR 49.0 million).
The return on unit-linked life insurance assets is part of the total investment result, but at the
same time it affects the financial result from insurance contracts in the opposite amount. It
stood at EUR 25.9 million (2024: EUR 98.0 million).
The total return on the Group's financial investments, excluding returns on unit-linked life
insurance contract assets, amounted to EUR 66.6 million in 2025, 3% lower than in 2024. Net
gains on financial investments at fair value through profit or loss decreased due to the lower
growth in the value of equity investments. The result from the Group's own financial
investments measured at fair value through profit or loss was 58% lower than in 2024,
amounting to EUR 3.7 million, reflecting lower returns on global equity markets compared with
the previous year. Interest income grew by 17%, reflecting a higher value of fixed-return
securities in the portfolio and higher average interest rates. Dividend income rose to EUR 2.7
91
million (index 103). The result from other investment income/expenses amounted to EUR 1.2
million (index 39), driven by higher exchange rate differences. Gains/losses and impairments of
investments in associates amounted to EUR 4.7 million (2024: EUR 6.9 million). The result from
gains and losses on equity-accounted investments was EUR 1.3 million lower in 2025, while
gains on disposals of participating interests in associates did not change significantly compared
with 2024.
Return on financial investments of the Triglav Group
Return on financial investments
Return excluding unit-linked life
insurance assets
2025
2024
Index
2025
2024
Index
Interest income calculated using the effective interest method
55,474,173
47,286,696
117
55,474,173
47,286,696
117
Dividend income
2,684,609
2,599,868
103
2,684,609
2,599,868
103
Net gains/losses on financial investments at fair value through
profit or loss
29,603,872
106,774,705
28
3,709,878
8,839,813
42
Net gains/losses on financial investments at amortised cost
-516
-335
154
-516
-335
154
Net gains/losses on financial investments at fair value through
other comprehensive income
-965,615
-3,314,398
29
-965,615
-3,314,398
29
Net impairment/reversal of impairment
-154,590
3,334,270
-154,590
3,334,270
Other investment income/expenses
1,168,958
3,065,770
38
1,169,418
2,992,442
39
Total return on financial investments (1)
87,810,891
159,746,576
55
61,917,357
61,738,356
100
Gains/losses and impairments of investments in associates (2)
4,730,009
6,878,092
69
4,730,009
6,878,092
69
Total (1 + 2)
92,540,900
166,624,668
56
66,647,366
68,616,448
97
Rate of return on investment
2.8%
5.8%
-2.9 p.p.
2.6%
3.0%
-0.4 p.p.
The rate of return on investments of the Group (excluding unit-linked insurance assets) was
2.6%, down by 0.4 percentage points year-on-year. Excluding exchange rate differences, the rate
of return at Group level was 2.7% (2024: 3.0%). The positive impact on returns was attributed to
interest income, which amounted to EUR 55.5 million (index 117). Despite volatility in financial
markets, the Group recorded a positive return on its equity portfolio, which resulted into lower
gains on investments at fair value through profit or loss. Gains on impairments of investments
in associates, totalling EUR 4.7 million, were lower than in the previous year (see note above).
The rate of return on investments of the parent company was also 3.4%, 0.7 percentage points
higher than the previous year. A significant contribution to the higher rate of return resulted
from the reversal of impairments on investments in subsidiaries amounting to EUR 18.0 million.
The 7% increase in the rate of return on investment was driven by higher dividend income,
interest income and other income (returns on alternative investments).
Return on financial investments of Zavarovalnica Triglav
Return on financial investments
Return excluding unit-linked life
insurance assets
2025
2024
Index
2025
2024
Index
Interest income calculated using the effective interest method
34,403,607
29,070,767
118
34,403,607
29,070,767
118
Dividend income
2,447,544
2,019,696
121
2,447,544
2,019,696
121
Net gains/losses on financial investments at fair value through
profit or loss
24,225,130
101,301,907
24
2,500,048
6,125,799
41
Net gains/losses on financial investments at fair value through
other comprehensive income
-1,757,952
-2,543,756
69
-1,757,952
-2,543,756
69
Net impairment/reversal of impairment
-107,293
2,754,998
-107,293
2,754,998
Other investment income/expenses
5,168,193
2,257,704
229
5,168,653
2,258,064
229
Total return on financial investments (1)
64,379,229
134,861,316
48
42,654,607
39,685,568
107
Gains/losses and impairments of investments in associates (2)
25,076,925
9,032,880
278
25,076,925
9,032,880
278
Total (1 + 2)
89,456,154
143,894,196
62
67,731,532
48,718,448
139
Rate of return on investments
3.4%
6.1%
-2.7 p.p.
3.4%
2.8%
0.7 p.p.
Equity
The Triglav Group's total equity as at 31 December 2025 amounted to EUR 1,078.1 million, up
by 9% relative to 31 December 2024. The Group's total equity represented 19.8% of total balance
92
sheet liabilities, a decrease of 2.0 percentage points. The increase was driven by higher net
earnings for the period in the amount of EUR 136.7 million and other comprehensive income in
the amount of EUR 15.4 million, while dividend payments reduced it by EUR 63.6 million. The
parent company's controlling interests increased by 9% to EUR 1,072.9 million, while non-
controlling interests rose by 27% to EUR 5.3 million, driven by an increase in other comprehensive
income and positive net earnings for the period attributable to non-controlling interests. The
share capital of EUR 73.7 million remained unchanged and was divided into 22,735,148 ordinary
shares. Zavarovalnica Triglav's total equity increased by 8% and amounted to EUR 798.3 million.
The Group's comprehensive income after tax amounted to EUR 152.1 million (2024: EUR 137.7
million) and the parent company's to EUR 120.3 million (2024: EUR 98.9 million).
8.1 Non-Life segment
The Non-Life segment delivered strong performance in both the insurance segment, where the
combined ratio reached a favourable 92.5%, and the investment segment.
Performance results of the Non-Life segment of the Triglav Group
2025
2024
Index
Total business volume
2,123,453,881
1,304,374,330
163
Gross written insurance premium
2,093,472,603
1,274,332,716
164
Other income
29,981,278
30,041,614
100
Total revenue
1,482,640,854
1,186,349,643
125
Insurance operating result
109,054,173
69,084,585
158
Insurance revenue
1,452,659,576
1,156,299,596
126
Claims incurred
898,452,514
627,530,982
143
Acquisition and administrative costs including non-attributable costs
360,145,761
304,338,440
118
Net reinsurance service result
-63,530,495
-139,958,713
45
Net other insurance revenue and expenses
-21,476,633
-15,386,876
140
Net investment result
33,248,539
32,865,549
101
Result from non-insurance operations
-5,593,591
-1,118,837
500
Earnings before tax
136,709,121
100,831,297
136
Combined ratio
92.5%
94.0%
–1.5 p.p.
CSM of new contracts/Total CSM
42.2%
53.3%
–11.1 p.p.
Insurance service expenses to insurance revenue
24.8%
26.3%
–1.5 p.p.
31 Dec 2025
31 Dec 2024
Index
Contractual service margin (CSM)
19,885,859
14,441,155
138
Risk adjustment (RA)
38,451,275
33,191,759
116
Net insurance contract liabilities
1,725,265,326
1,035,308,305
167
Net reinsurance contract assets
732,523,533
287,403,984
255
The Non-Life segment includes non-life insurance business of insurance and reinsurance companies and non-insurance companies supporting this
business (Triglav, Upravljanje nepremičnin, Triglav Avtoservis, Sarajevostan, Lovćen Auto and others). The segment presentation also includes the
investment portion of the Non-Life segment's own insurance portfolios.
Total business volume of the Non-Life segment rose by 63% to EUR 2,123.5 million. Gross written
premium in the Non-Life segment recorded strong growth of 64%. In the Slovenian market,
premium grew by 1%, in the international market by 210%, and in other markets of the Adria
region by 6%. Strong premium growth in the international market was primarily driven by a
significant increase in inward reinsurance premium (index 129), mainly due to new business
with certain cedents, and by substantial growth in premium written under the principles of free
movement of services (FOS business) and freedom of establishment (FOE) (index 756). The
highest premium volume was recorded in Italy (EUR 697.0 million, of which EUR 692.9 million
93
was generated through Prima Assicurazioni), followed by Poland (EUR 60.7 million), with 8%
growth, and Greece (EUR 30.0 million). Strong growth was achieved in the German market (EUR
19.5 million, index 140) in combined non-life insurance and international marine hull insurance.
Premium growth was achieved in most markets in the Adria region, with the exception of Bosnia
and Herzegovina (index 88), where the decline in premium resulted from ownership
consolidation and business optimisation. High, 14% growth in non-life insurance premium was
recorded in Croatia, followed by the Serbian (index 107) and North Macedonian insurance
markets (index 104). Premium increases were observed across most non-life insurance groups,
except for credit and surety insurance.
The total revenue of the Non-Life segment reached EUR 1,482.6 million, up by 25%. The growth
was mainly driven by higher insurance revenue resulting from a higher premium volume in
insurance and reinsurance business. Other income remained at the same level as in the previous
year (index 100).
The Group's Non-Life segment's insurance operating result totalled EUR 109.1 million,
representing a 58% increase year-on-year. The strong performance was driven by both volume
growth and a change in portfolio structure.
Insurance revenue increased by 26%, while acquisition costs, administrative costs and non-
attributable costs were 18% higher at EUR 360.1 million. The net reinsurance service result
amounted to EUR –63.5 million (2024: EUR –140.0 million), primarily due to higher reinsurance
income (EUR 369.9 million, index 308). Due to the increased business volume, reinsurance
service expenses rose (index 167). Non-life insurance claims incurred, which comprise insurance
service expenses for claims, the change in cash flows, the change in experience correction and
the effects of allocation to onerous contracts, increased by 43% to EUR 898.5 million at Group
level. The increase in non-life insurance claims written resulted from a rise in reported claims,
mainly due to a larger international insurance portfolio.
The net investment result amounted to EUR 33.2 million, 1% higher than in the previous year,
predominantly driven by higher interest income from financial investments. The result from
non-insurance operations amounted to EUR –5.6 million (2024: EUR –1.1 million), mainly due to
higher interest on bonds issued. Earnings before tax of the Non-Life segment reached EUR 136.7
million, compared to EUR 100.8 million year-on-year.
The combined ratio for the Non-Life segment at Group level decreased by 1.5 percentage points
to a favourable 92.5%. The decrease was driven by both a 0.2 percentage point improvement in
the claims ratio (strong growth in insurance revenue and a better reinsurance result) and a 1.4
percentage point improvement in the expense ratio (the growth in insurance revenue outpacing
the growth in expenses and net insurance service expenses).
94
Performance results of the Non-Life segment of Zavarovalnica Triglav
2025
2024
Index
Total business volume
1,685,249,874
880,069,705
191
Gross written insurance premium
1,671,482,271
866,712,582
193
Other income
13,767,603
13,357,123
103
Total revenue
1,089,402,831
824,375,017
132
Insurance operating result
83,954,007
54,508,347
154
Insurance revenue
1,075,635,228
811,017,894
133
Claims incurred
686,011,532
396,432,489
173
Acquisition and administrative costs including non-attributable costs
261,799,115
215,478,525
121
Net reinsurance service result
-24,407,844
-130,046,609
19
Net other insurance revenue and expenses
-19,462,730
-14,551,924
134
Net investment result
44,117,808
24,947,939
177
Result from non-insurance operations
-5,263,718
-1,389,929
379
Earnings before tax
122,808,097
78,066,357
157
Combined ratio
92.2%
93.3%
–1.1 p.p.
CSM of new contracts/Total CSM
44.1%
57.4%
–13.3 p.p.
Insurance service expenses to insurance revenue
24.3%
26.6%
–2.2 p.p.
31 Dec 2025
31 Dec 2024
Index
Contractual service margin (CSM)
19,031,245
13,420,019
142
Risk adjustment (RA)
15,229,711
15,135,083
101
Net insurance contract liabilities
1,354,410,585
688,541,300
197
Net reinsurance contract assets
710,974,896
249,027,855
286
8.2 Life segment
The Life segment delivered strong performance, primarily in the insurance business.
Performance results of the Life segment of the Triglav Group
2025
2024
Index
Total business volume
265,647,540
244,566,606
109
Gross written insurance premium
263,702,026
242,588,054
109
Other income
1,945,514
1,978,552
98
Total revenue
107,695,527
100,265,726
107
Insurance operating result
20,505,823
19,804,608
104
Insurance revenue
105,922,695
98,399,942
108
Claims incurred
30,461,979
27,161,982
112
Acquisition and administrative costs including non-attributable costs
50,888,966
48,590,117
105
Net reinsurance service result
-860,285
272,006
Net other insurance revenue and expenses
-3,205,642
-3,115,241
103
Net investment result
7,965,520
10,523,083
76
Result from non-insurance operations
240,354
9,987
2,407
Earnings before tax
28,711,697
30,337,678
95
CSM of new contracts/Total CSM
13.6%
15.1%
–1.5 p.p.
New business margin
13.3%
13.4%
–0.1 p.p.
CSM growth ratio
96%
112%
–15.7 p.p.
Insurance service expenses to insurance revenue
48.0%
49.4%
–1.3 p.p.
31 Dec 2025
31 Dec 2024
Index
Contractual service margin (CSM)
286,788,544
272,164,764
105
Risk adjustment (RA)
33,589,264
32,489,424
103
Net insurance contract liabilities
1,415,656,748
1,404,899,165
101
Net reinsurance contract assets
245,106
346,996
71
95
The Life segment includes life insurance business of insurance companies and non-insurance companies supporting this business
(Triglav Svetovanje and Triglav Savjetovanje, Sarajevo). This segment's result also takes into account the investment portion of
related own insurance portfolios.
The total business volume amounted to EUR 265.6 million, representing a 9% increase year-on-
year. Gross written premium was also rose by 9%. Premium growth was achieved across all
insurance markets, highest in Montenegro (index 114) and North Macedonia (index 113).
Growth was particularly strong in unit-linked life insurance, mainly due to higher one-off and
additional premium payments at the parent company and the North Macedonian life insurer.
Total revenue increased by 7%, driven primarily by growth in insurance revenue.
The insurance operating result of EUR 20.5 million was 4% higher, mainly due to an 8% increase
in insurance revenue. Claims incurred, which in addition to insurance service expenses for claims
comprise the change in future cash flows, the change in experience correction, the effects of
allocation to onerous contracts and other insurance expenses, increased by 12% at Group level,
amounting to EUR 30.5 million. Their increase was primarily influenced by higher insurance
service expenses for claims and the effects of the loss on onerous contracts.
The net investment result of the Life segment amounted to EUR 8.0 million (index 76). The lower
net investment result was influenced by financial market conditions, which led to lower growth
in equity investments compared to the previous year. The result from non-insurance operations
amounted to EUR 240 thousand (2024: EUR 10 thousand). Earnings before tax of the Life
segment at Group level amounted to EUR 28.7 million, representing a 5% decrease year-on-year.
The Group's CSM of new life insurance contracts amounted to EUR 39.0 million, of which 40%
was accounted for by unit-linked life insurance contracts and the rest by other life insurance
contracts. The CSM of new contracts in the total contractual service margin was 13.6%, down by
1.5 percentage points year-on-year, primarily due to a lower CSM of new contracts at the North
Macedonian life insurer. The release of the contractual service margin to profit or loss amounted
to EUR 40.4 million compared to EUR 36.6 million year-on-year.
In the reporting period, the new business margin of the Group's Life segment stood at 13.3%,
down by 0.1 percentage points year-on-year, predominantly due to a lower CSM of new
contracts (as mentioned above).
The Group's contractual service margin growth ratio shows the relationship between the CSM
of new contracts and the release of the contractual service margin to profit or loss as a result of
cash flow maturity. It reached 96%, compared with 112% in the previous year.
The contractual service margin of the Group's life insurance contracts rose by EUR 14.6 million
in 2025, amounting to EUR 286.8 million as at 31 December 2025. The increase was positively
affected by a EUR 13.1 million change in expected cash flows, the majority of which relates to
the parent company (see note below). The contractual service margin was also positively
affected by an increase in other changes of EUR 3.0 million, whereas the difference between the
CSM of new contracts and the release of the CSM to profit or loss had a negative impact of EUR
1.4 million.
96
Movement in the Triglav Group's CSM of insurance contracts in the Life segment in 2025
Performance results of the Life segment of Zavarovalnica Triglav
2025
2024
Index
Total business volume
212,533,358
195,443,569
109
Gross written insurance premium
211,914,902
194,421,298
109
Other income
618,456
1,022,271
60
Total revenue
81,143,361
77,469,581
105
Insurance operating result
17,782,894
18,431,324
96
Insurance revenue
80,638,122
76,553,208
105
Claims incurred
18,895,525
17,639,863
107
Acquisition and administrative costs including non-attributable costs
39,042,219
37,076,869
105
Net reinsurance service result
-765,764
-105,762
724
Net other insurance revenue and expenses
-4,151,720
-3,299,390
126
Net investment result
7,547,908
7,642,237
99
Result from non-insurance operations
303,701
172,324
176
Earnings before tax
25,634,503
26,245,885
98
CSM of new contracts/Total CSM
12.1%
13.0%
–0.9 p.p.
New business margin
14.5%
14.6%
–0.1 p.p.
CSM growth ratio
94%
103%
–9.1 p.p.
Insurance service expenses to insurance revenue
48.4%
48.4%
0.0 p.p.
31 Dec 2025
31 Dec 2024
Index
Contractual service margin (CSM)
269,137,743
257,806,279
104
Risk adjustment (RA)
30,131,623
29,240,452
103
Net insurance contract liabilities
1,271,933,214
1,272,022,364
100
Net reinsurance contract assets
47,546
-8,336
Earnings before tax of the Company's Life segment totalled EUR 25.6 million, down by 2% year-
on-year. The insurance operating result was EUR 17.8 million, representing a 4% decline. The
insurance operating result was positively impacted mainly by a higher release of the contractual
service margin amounting to EUR 2.2 million. Changes in the projection of future cash flows and
in assumptions also affected the result; however, their positive effect on reducing losses from
onerous contracts, was by EUR 0.8 million lower than in the previous year. The insurance
operating result was by EUR 1.9 million lower also due to slightly less favourable claims
development in complementary accident insurance. The operating result was also impacted by
increased acquisition costs and administrative costs including non-attributable costs (index
272.2
286.8
39.0
13.1
-40.4
3.0
31 Dec 2024 CSM of new
contracts
Change in expected
cash flows
Release of the CSM
to profit or loss
Other 31 Dec 2025
97
105), a net reinsurance service result of EUR –766 thousand and net other insurance expenses of
EUR –4.2 million. The net investment result decreased by 1% to EUR 7.5 million, primarily due to
lower interest income from the bond portfolio.
The Company's CSM of new contracts amounted to EUR 32.5 million in 2025 compared to EUR
33.5 million in the previous year. Unit-linked life insurance contracts accounted for 47% of the
CSM for new contracts (2024: 50%). The CSM of new contracts in total contractual service margin
was 12.1% (2024: 13.0%). The release of the contractual service margin to profit or loss
amounted to EUR 34.8 million in 2025 (index 107).
The Company's contractual service margin of insurance contracts amounted to EUR 269.1
million as at 31 December 2025, an increase of EUR 11.3 million relative to 31 December 2024.
Its movement was primarily positively affected by a EUR 10.9 million change in expected cash
flows, resulting from revised assumptions used in calculating the present value of expected cash
flows from life insurance, as well as by higher expected future reimbursements of management
fees from increased unit-linked life insurance assets. The difference between the CSM of new
contracts and the release of the CSM to profit or loss had a negative impact of EUR 2.2 million
on the contractual service margin, while the increase in other changes amounted to EUR 2.7
million.
The Company's new business margin fell by 0.1 percentage points to 14.5%. The decline was due
to a higher volume of single premium unit-linked insurance, which yields a lower return than
regular premium insurance. The Company's contractual service margin growth ratio reached
94%, compared with 103% in the previous year.
Movement in the Company's CSM of insurance contracts in the Life segment in 2025
257.8
269.1
32.5
10.9
-34.8
2.7
31 Dec 2024 CSM of new
contracts
Change in expected
cash flows
Release of the CSM
to profit or loss
Other 31 Dec 2025
98
8.3 Health segment
In 2024, the Triglav Group restructured the business model of its Health segment following the
statutory abolition of supplemental health insurance on the Slovenian market. The Group
focused its activities on the growth and development of complementary health insurance
products across its markets. As expected, the segment recorded a negative operating result in
2025; excluding discontinued operations, the result would have been at the previous year's level.
The operating result is expected to remain volatile until the target volume of the health
insurance business is achieved.
Performance results of the Health segment of the Triglav Group
2025
2024
Index
Total business volume
53,230,370
56,223,031
95
Gross written insurance premium
52,766,590
44,336,316
119
Other income
463,780
11,886,715
4
Total revenue
50,633,435
55,139,550
92
Insurance operating result
-7,034,193
8,620,876
Insurance revenue
50,169,655
43,252,835
116
State compensation pursuant to the Decree on supplemental health
insurance premium
0
10,996,355
Claims incurred
35,258,115
23,996,976
147
Acquisition and administrative costs including non-attributable costs
20,356,242
18,007,025
113
Net reinsurance service result
-361,742
-1,244,211
29
Net other insurance revenue and expenses
-1,227,749
-2,380,102
52
Net investment result
503,004
1,247,919
40
Result from non-insurance operations
608,746
472,074
129
Earnings before tax
-5,922,443
10,340,869
Combined ratio
114.0%
84.1%
29.9 p.p.
CSM of new contracts/Total CSM
808.7%
11.1%
797.6 p.p.
Insurance service expenses to insurance revenue
40.6%
41.6%
–1.1 p.p.
31 Dec 2025
31 Dec 2024
Index
Contractual service margin (CSM)
20,693
212,799
10
Risk adjustment (RA)
555,508
533,650
104
Net insurance contract liabilities
10,827,751
13,449,389
81
Net reinsurance contract assets
550,429
-295,163
The Health segment includes the health insurance products sold by the Group insurance companies and the two non-insurance
companies complementing this business (Triglav Med and Eskulap). The segment presentation also includes the investment portion
of the Health segment's own insurance portfolios.
The total business volume of the Health segment amounted to EUR 53.2 million. Organic growth
of the Group's total business volume, excluding the one-off state compensation of EUR 11.0
million in 2024, amounted to 18%. Following the restructuring of the segment's business model,
the Company continued its marketing and development activities for complementary health
insurance products both in Slovenia and in other regional markets. On this basis, it successfully
increased gross written premium by 19% to EUR 52.8 million.
The Group's non-consolidated complementary health insurance premium grew by 19% to EUR
51.6 million in 2025 (shown by insurance market in the table below). Growth was recorded
across all of the Group's markets.
Non-consolidated health insurance premium in the Triglav Group
2025
2024
Index
Slovenia
27,304,173
22,885,015
119
Serbia
14,016,291
11,373,915
123
99
2025
2024
Index
North Macedonia
4,041,066
3,587,856
113
Croatia
3,547,997
3,129,285
113
Montenegro
1,805,272
1,533,082
118
Bosnia and Herzegovina
840,382
839,534
100
Total
51,555,181
43,348,687
119
Earnings before tax of the Health segment totalled EUR –5.9 million (2024: EUR 10.3 million),
including EUR 16.1 million from discontinued operations. The insurance operating result was
negative and amounted to EUR –7.0 million (2024: EUR 8.6 million, predominantly due to the
effect of discontinued operations). The negative impact was mainly due to an increase in claims
incurred, driven by portfolio growth and the positive impact in the previous year from the release
of provisions for supplemental health insurance amounting to EUR 6.4 million. Acquisition costs
and administrative costs including non-attributable items were 13% higher. Insurance revenue
increased by 16%, while the net reinsurance service result amounted to EUR –362 thousand. The
net investment result amounted to EUR 503 thousand, while the result from non-insurance
operations stood at EUR 609 thousand. The combined ratio for the Health segment at Group
level stood at 114.0% (2024: 84.1%), comprising a claims ratio of 71.0% and an expense ratio of
43.0%. Excluding the impact of supplemental health insurance in 2024 (reported below for the
parent company), the combined ratio would have been 117.6% (with a claims ratio of 73.3% and
an expense ratio of 44.3%).
The combined ratio for the Company was 121.9%, with an expense ratio of 50.4% and a claims
ratio of 71.6%. The result in 2024 was positively affected by state compensation (EUR 11.0
million) and the release of provisions for supplemental health insurance (EUR 6.4 million).
Excluding the impact of one-off effects in 2024, the combined ratio of the parent company
would have been 120.5% (with a claims ratio of 58.1% and an expense ratio of 62.4%).
Performance results of the Health segment of Zavarovalnica Triglav
2025
2024
Index
Total business volume
27,337,171
34,490,282
79
Gross written insurance premium
27,304,173
22,885,015
119
Other income
32,998
11,605,267
0
Total revenue
27,982,669
35,137,987
80
Insurance operating result
-6,133,779
11,434,413
Insurance revenue
27,949,671
23,532,720
119
State compensation pursuant to the Decree on supplemental health
insurance premium
0
10,996,355
Claims incurred
19,856,994
6,717,258
296
Acquisition and administrative costs including non-attributable costs
13,238,743
13,492,574
98
Net reinsurance service result
-153,022
-504,728
30
Net other insurance revenue and expenses
-834,691
-2,380,102
35
Net investment result
473,534
1,175,208
40
Result from non-insurance operations
26,556
533,887
5
Earnings before tax
-5,633,689
13,143,508
Combined ratio
121.9%
66.9%
55.1 p.p.
CSM of new contracts/Total CSM
808.7%
11.1%
797.6 p.p.
Insurance service expenses to insurance revenue
47.4%
57.3%
–10.0 p.p.
31 Dec 2025
31 Dec 2024
Index
Contractual service margin (CSM)
20,693
212,799
10
Risk adjustment (RA)
455,644
432,808
105
Net insurance contract liabilities
7,414,764
7,617,888
97
Net reinsurance contract assets
51,695
12,090
428
100
8.4 Asset Management
Despite a volatile financial market environment, the Asset Management segment achieved
strong performance.
The Group's total assets under management as at 31 December 2025 amounted to EUR 6.3
billion, representing a 6% increase compared to 31 December 2024. The Group manages own
funds, unit-linked insurance assets and financial contract assets in the total amount of EUR 4.3
billion (index 110) in its companies. In addition, the Group manages assets in mutual funds and
discretionary mandate assets, as well as assets in pension funds and alternative investments, in
the total amount of EUR 2.0 billion (index 99).
Assets under management of the Triglav Group as at 31 December 2025 and 31 December 2024
Assets under management
Index
31 Dec 2025
31 Dec 2024
2025/2024
Own investment portfolio (1)
2,752,814,172
2,487,714,381
111
Unit-linked life insurance assets (2)
749,596,814
678,910,235
110
Financial instruments from financial contracts (3)
802,451,207
739,510,939
109
Total (1+2+3)
4,304,862,193
3,906,135,555
110
Assets under management – Triglav Investments (4)*
1,561,213,389
1,628,351,605
96
Assets under management – Triglav penzisko društvo, Skopje (5)
271,797,673
208,952,512
130
Assets under management – Triglav Investments, Sarajevo (6)
13,739,060
9,801,044
140
Total (4+5+6)
1,846,750,122
1,847,105,161
100
Assets under management – Trigal (7)**
92,109,234
117,412,162
78
Assets under management – Evropski dobrovoljni penzijski fond, Banja Luka (8)
27,336,927
23,129,461
118
Total (7+8)
119,446,160
140,541,623
85
Total
6,271,058,475
5,893,782,338
106
* Unit-linked life insurance contract assets of Zavarovalnica Triglav and investments of Triglav, pokojninska družba managed by it are excluded from
Triglav Investments' assets under management.
** Own funds and the Group's investments in alternative funds managed by Trigal are excluded from Trigal's assets under management.
Performance results of the Triglav Group Asset Management segment
2025
2024
Index
Total business volume
118,855,573
112,462,118
106
Gross written insurance premium SVPI
65,102,434
61,007,668
107
Total revenue
53,753,139
51,454,450
104
Operating result
11,509,691
13,177,336
87
Income from asset management
53,618,623
49,364,063
109
Net other income and expenses
-1,274,991
230,427
Operating expenses
40,833,941
36,417,154
112
Net investment result
3,042,620
4,355,021
70
Earnings before tax
14,552,311
17,532,357
83
Expenses to asset management income ratio
76.2 %
73.8 %
2.4 p.p.
The asset management activity at the Triglav Group comprises the management of investment portfolios of insurance companies,
clients' pension savings through the insurance services of the Group's insurance and pension companies, the management of clients'
assets in mutual funds and discretionary mandate assets by asset management companies and alternative investment
management. The disclosed assets therefore refer to the Group's total assets under management. As the investment results of own
insurance portfolios are taken into account in the insurance segments, the Asset Management segment includes clients' pension
saving through the insurance services of the Group's insurance and pension companies, asset management and the management
of clients' assets in mutual funds and discretionary mandate assets in the aforementioned companies.
The Group's total business volume of the Asset Management segment amounted to EUR 118.9
million, up by 6% year-on-year. The voluntary pension insurance premium (EUR 65.1 million) rose
by 7%, driven by a rise in the number of new policies taken out with Triglav, pokojninska družba.
Income from asset management rose by 9% to EUR 53.6 million. Income from asset management
comprises income from fees, which increased in all companies, with the highest growth recorded
101
in the North Macedonian company Triglav penzisko društvo (index 128) and Triglav, pokojninska
družba (25%). This is the result of the merger of the activity from Zavarovalnica Triglav, which
was entered in the court register on 1 October 2025, as described in more detail in Section 2.7
Transfer of part of the assets to Triglav, pokojninska družba d.d. in the Accounting Report. The
transfer of part of the assets has no impact on the Group’s total business volume and income
from asset management.
Earnings before tax of the Asset Management segment reached EUR 14.6 million, down by 17%
year-on-year. The operating result amounted to EUR 11.5 million, 13% lower than in the previous
year. Income from asset management and other income each rose by 6%, while operating
expenses were 12% higher. The lower net investment result of EUR 3.0 million (2024: EUR 4.4
million) resulted from a lower investment result (index 83) due to lower returns on equity
investments, while last year's result was also positively impacted by income from the change in
provisions for not achieving the guaranteed yield amounting to EUR 908 thousand (2025: EUR
18 thousand).
As part of the spin-off, the asset management segment was transferred from Zavarovalnica
Triglav to its subsidiary Triglav, pokojninska družba, as a result of which Zavarovalnica Triglav
ceased to operate in this segment. The spin-off resulted in transfer of assets and liabilities, from
accumulation phase of supplemental voluntary pension insurance. While the operating results
up to the transfer date remained recognised in statement of profit or loss of Zavarovalnica
Triglav. The entry in the court register was completed on 1 October 2025. See Section 2.7 Transfer
of part of the assets to Triglav, pokojninska družba d.d. for further details.
Management of assets and investment funds
Triglav Investments is the Group's core company in asset management. As at the reporting date,
it managed assets of EUR 2.1 billion in mutual funds, representing a 9% increase compared to 31
December 2024. The value of net assets under management rose by EUR 74.6 million owing to
the capital market developments, while the net inflow impact amounted to EUR 107.3 million.
Following the transfer of Triglav, pokojninska družba's assets into management, discretionary
mandate assets amounted to EUR 943.2 million as at 31 December 2025, representing a 181%
increase compared with 31 December 2024. Net inflows amounted to EUR 35.4 million, while
the positive effects of capital markets increased net asset value by EUR 40.5 million.
Triglav Investments, Sarajevo managed EUR 13.7 million of assets as at 31 December 2025 in its
two open-end investment funds, OIF Triglav Obveznički and OIF Triglav Globalni dionički,
representing a 40% increase compared with the end of the previous year. Net inflows into the
two funds totalled EUR 3.3 million in 2025.
Movement in net assets under management (mutual funds and discretionary mandate services)
Net asset value of assets under
management
Net inflow
Net market
31 Dec 2025
31 Dec 2024
Change
impact
impact
Triglav Investments
3,049,100,197
2,260,084,264
789,015,933
673,930,354
115,085,579
- mutual funds
2,105,853,459
1,923,993,403
181,860,056
107,251,770
74,608,286
- discretionary mandate assets
943,246,738
336,090,861
607,155,877
566,678,584
40,477,293
Triglav Investments, Sarajevo
13,739,060
9,801,044
3,938,016
3,336,997
601,019
Total
3,062,839,257
2,269,885,308
792,953,949
677,267,351
115,686,598
102
8.5 Investment in own-use real property and equipment
The Group invested EUR 14.8 million (index 146) in property, plant and equipment and EUR 20.2
million (index 158) in intangible assets (software and property rights). The Company invested
EUR 5.8 million (index 131) in property, plant and equipment and EUR 17.0 million (index 199)
in intangible fixed assets. See Section 3.7.1 for more information on property, plant and
equipment and Section 3.7.4 of the Accounting Report for more information on intangible
assets.
The value of own-use real property is enhanced through active management and prudent
investment. Within the adopted annual plans, the utilisation of real property is optimised,
functionality is enhanced and energy efficiency is improved through energy renovations.
Through the adoption of minimum standards for the design of flexible workplaces and points of
sale within the Group, alignment is ensured with international best practices for modern and
efficient operations. The main objectives pursued are as follows:
▪ To provide employees with a modern business environment and appropriate conditions for
new ways of working (hybrid workplaces), and to provide clients with an excellent and
comfortable user experience (e.g. remote business transactions); and
▪ To achieve lasting effects through the rationalisation of operating expenses and
maintenance costs while maintaining the quality of the space.
With the continued digitalisation and automation of processes, which improve efficiency and
enhance the user experience for online underwriting and remote claims reporting, optimisation
will continue in the coming years, particularly with regard to space utilisation in large business
units. Optimisation measures ensure effective use of space for operational activities, while
surplus areas are repurposed for other uses (e.g. investment property), thereby reducing
operating expenses and maintenance costs for business premises and contributing to a lower
carbon footprint for the Group.
As the pilot project on hybrid working (a hybrid work model in which employees combine on-
site and remote work) proved successful, it will be continued. In 2025, projects were prepared
and modern, flexible workplaces were introduced at the Headquarters in Building D at
Verovškova 60c in Ljubljana and at the Kranj business unit.
The real property management software was upgraded with investment management and cost
management functionalities, along with enhancements to energy accounting.
Investments in information technology focus on stable development and long-term support for
key business processes. In software, emphasis is placed on the development and upgrading of
core underwriting information systems, aimed primarily at optimising the underwriting process,
providing licensed support for ancillary systems, and strengthening digital services, mobile
solutions and data-analytics capabilities. The largest portion of software investment relates to
system infrastructure software, which, together with investment in communication and server
hardware, ensures stable IT system operations, reduces the risk of downtime and strengthens
cybersecurity.
To support a modern and stable work environment that enables more efficient performance of
tasks and better support for digital business processes, part of the investment is also allocated
to employees' IT equipment.
103
9. Risk management
- The Triglav Group capital adequacy remains within target range and was primarily affected
by increased business volume, mainly due to the entry into the Italian motor insurance
market, which increased capital requirements for underwriting, operational and credit risks.
- The Group adapted to the macroeconomic environment and maintained an optimal level of
underwritten risks.
- Planned asset-liability matching was ensured while risks were mitigated through
appropriate diversification.
- The development activities mainly focused on the systematic management of strategic risk
and the enhancement of the information and communication technology (ICT) risk
management system, including information security and sustainability risks.
The Triglav Group was well-capitalised in 2025. The outlined dividend policy was followed,
achieving a high capital adequacy ratio of 206% at the year-end, despite changes in the
macroeconomic environment and financial markets. The Group's adequate capital strength was
reaffirmed by AM Best, which assigned a long-term credit rating of "A", and S&P Global, which
assigned a financial strength rating of "A+". The latter upgraded the Group's credit rating from
"A" to "A+" in 2025. See Section 6.6 Credit rating of the Triglav Group and Zavarovalnica Triglav
for more information.
From a macroeconomic perspective, inflation continued to play a central role, moderating
throughout the year and remaining close to the target level in the euro area; as a result, the
European Central Bank cut key interest rates, particularly in the first half of the year. Economic
growth remained subdued (see Section 7. Macroeconomic environment and market trends).
These conditions mainly affected market and underwriting risks. In assuming and managing
these risks, the Group’s focus remained on adapting to the macroeconomic and financial market
situation.
The Group carried out key risk management development activities at the business line level,
where opportunities for improvement were identified or responses to external circumstances
were required.
▪ In capital management, the "bridging analysis" in the Group's (re)insurance subsidiaries was
upgraded, providing a comprehensive explanation of the differences between the valuation
of insurance technical provisions for solvency and financial statement purposes.
▪ With regard to market risks, the Group upgraded its internal methodologies for measuring
and monitoring interest rate risk at Group level and established an internal methodology
for measuring property risk.
▪ In relation to non-life underwriting risks, reporting on natural catastrophe realisations at
Group level was harmonised, and the monitoring of concentration in non-life underwriting
risks was upgraded.
▪ In the context of credit risk management, the method for calculating the appropriateness
of standard formula parameters for type 2 credit risk exposures was upgraded.
▪ With respect to liquidity risk, the existing methodology for calculating the main risk
indicator was refined based on a comprehensive review of liquidity clauses in reinsurance
contracts and the findings of the backtesting exercise.
▪ In relation to operational risk management, methodologies and the operational risk and
internal control register were upgraded to include risks and controls for ICT, while
operational risk exposure assessments were updated by business process, as well as from
outsourcing and information security perspectives.
▪ Regarding non-financial risk management, the existing strategic risk management system
was upgraded with a new methodology allowing for the systematic assessment and
104
monitoring of these risks. The reputational risk management methodology was updated in
line with the updated indicators. Sustainability risk management was further developed,
with the sustainability risk management methodology upgraded separately for the
insurance and investment portfolios. Measurement methods were enhanced, in particular
for climate-related transition risk and for the overall sustainability risk assessment of the
investment portfolio.
▪ The risk management system was also modernised by streamlining the work of the
committees within the system and reviewing their powers and membership.
For all remaining types of risks, efforts focused on maintaining established systems and
processes. The risk management system at Group level was systematically upgraded by
consistently monitoring all material risks.
9.1 Risk management system
The risk management system is key to achieving the Group's strategic and business objectives.
It is implemented at Group level as a set of harmonised rules, powers and responsibilities, clearly
delineated by business function and organisational level. The system defines and integrates
processes for the continuous identification, assessment, monitoring and management of
assumed, potential and emerging risks. A clear, transparent and well-documented system
enables the Company to take appropriate and timely action and to maintain the risk profile at
the level defined in the main document – Group Risk Appetite Statement. The system is
maintained up-to-date and comprehensive through continuous upgrades and updates. In
subsidiaries, the system is aligned with the standards and rules of the parent company, taking
into account the principle of proportionality.
9.1.1 Powers and responsibilities
The system of powers and responsibilities in risk management is based on the "three lines of
defence" model.
The Management Board and Supervisory Board have a key role in the risk management system.
They are responsible for its operation and defining organisational goals and strategies for
achieving them. Furthermore, they establish the management structure and processes for
appropriate management of assumed risks.
The first line of defence comprises the business functions, which identify and underwrite risks
in their respective work area in accordance with the Management Board's guidelines. Actual
risks are actively managed within the limits of acceptable or allowed exposure.
105
The decision-making bodies participating in the integrated corporate risk management process
and the three lines of defence
Supervisory Board
Management Board
1.
First line of defence
Risk underwriting
2.
Second line of defence
Risk management
3.
Third line of defence
Independent supervision
Business functions at all
levels
Competent risk
management committees,
the risk management
function, the actuarial
function, the compliance
function and other related
areas
Internal audit
▪ Active operational
management of
concrete business risks
▪ Responsibility for risk
identification and
underwriting
▪ Definition of the risk
management system
▪ Definition and
execution of exposure
identification,
measurement and
monitoring procedures
▪ Definition of the
exposure limit system
▪ Execution of regular
independent
effectiveness and
efficiency reviews of
the internal control
system and the risk
management system
The second and third lines of defence comprise the decision-making bodies and key functions
of the governance system that are organised as independent organisational units. The second
line of defence includes the relevant risk management committees and key functions: the risk
management function, the non-life and life insurance actuarial functions, and the compliance
function. The internal audit function, providing independent supervision of the system, is part
of the third line of defence. All key functions cooperate with one another, with other areas
within the Company and with Group companies. They are independent in their work.
The risk management function is responsible and accountable for the development and
effective operation of the risk management system, in line with the Management Board's
guidance. It monitors the overall risk profile, identifies and assesses emerging risks, coordinates
and calculates capital requirements, and assesses capital adequacy using the regulatory method
and other capital models. It also conducts the own risk and solvency assessment process and
prepares other regulatory reports, such as the Solvency and Financial Condition Report and the
Regular Supervisory Report.
106
The compliance function monitors the compliance of the Company's operations with the
applicable regulations and commitments within the internal control system. It monitors and
assesses the impacts of the changed legal environment and compliance risks. As part of its
duties, it reviews and advises on the adequacy and effectiveness of procedures and measures to
ensure compliance. It also co-creates the internal controls for ensuring compliance of a
particular process, business line, or the Company as a whole by providing guidelines and making
recommendations and proposals, on which it regularly reports to the Management Board and
the Supervisory Board. In addition, the compliance function plays a major role in ensuring fair
and transparent operations.
The actuarial function coordinates and implements the calculation of insurance technical
provisions, applying appropriate methods, models and assumptions, while ensuring the use of
comprehensive, high-quality data. It also calculates capital requirements for underwriting risks.
A key task of the function is to verify the adequacy of the overall underwriting and reinsurance
policies and to provide an opinion on whether the amount of the premium of individual
products is sufficient to cover all the liabilities arising from insurance contracts. The function
also participates in the own risk and solvency assessment and reports its significant findings to
the Management Board and the Supervisory Board.
The internal audit function provides regular and comprehensive oversight of the Company's
operations based on an audit risk assessment. The adequacy and effectiveness of the Company's
corporate governance, risk management and control processes are reviewed and assessed in an
impartial, systematic and methodical manner, with recommendations made to improve their
effectiveness and efficiency. In addition to providing independent and objective assurance, the
function also provides advisory services, cooperates with supervisory bodies and other
assurance providers, monitors the implementation of external auditors' recommendations and
regulators' measures, and participates in internal audit reviews of other Group companies.
Among its tasks is also ensuring the quality and continuous development of internal audit
within the Company and to maintain an appropriate level of internal audit quality across the
Group.
All key functions are in charge of not only transferring know-how and best practices to Group
subsidiaries but also of ensuring their harmonised operation.
The second line of defence of the risk management system includes committees that support
the Management Board by monitoring risks on a regular basis and informing it of their work.
107
The risk management system's committees and their responsibilities
Risk Management Committee (RMC)
Responsible for monitoring and managing risks:
▪ non-financial risks that do not fall within the powers of other committees,
▪ capital risks,
▪ overall all other types of risks, with an emphasis on the Group's most
material risks.
Approves:
▪ methodologies and rules defining risk assessment methods,
▪ limit systems related to all risk types,
▪ maximum net retention tables,
▪ recommendations to subsidiaries regarding the maximum permitted exposure to individual risks.
Assets and Liabilities
Committee
(ALCO)
Non-life
Underwriting
Committee
(UWC)
Operational Risk
and Compliance
Committee (ORCC)
IT and ICT Risk
Management
Committee (ITRMC)
Life Insurance
Product Forum
(LIPF)
Non-life Insurance
Product Forum
(NIPF)
Health Insurance
Product Forum
(HIPF)
Project Steering
Committee
(PSC)
Responsible for:
liquidity risk, market
risks, life
underwriting and
pension risks, credit
risks of the
investment portfolio
Responsible for:
non-life
underwriting and
credit risks
Responsible for:
operational risks,
compliance risks
and reputational
risk
Responsible for:
ICT risks, including
information security
risks and business
continuity
management
system
Responsible for:
life underwriting
risks
Responsible for:
non-life
underwriting risks
Responsible for:
health underwriting
risks
Responsible for:
project risks
108
Risk management is initially carried out at the level of individual companies and then
comprehensively at Group level. The management of individual Group members and the
persons in charge of risk management are responsible for the establishment and operation of
the risk management system.
The operation of the risk management system is transferred from the parent company to the
Group with minimum standards harmonised by the Triglav Group Subsidiary Management
Division, in cooperation with the parent company's Risk Management Department, which is
responsible for risk management minimum standards. Through the common standards, the
Group ensures an effective and transparent risk management system at Group level, which is
based on effective communication, quality exchange of data and information, time availability,
methodological consistency, accounting verifiability and integrity.
9.1.2 Risk management process
The key building blocks of the comprehensive risk management process are the Group's strategy
and the Company's business plan. These elements are used to define the Group-level risk
appetite for all material categories of risk that the Group is willing to assume. Additionally, this
document outlines the key indicators for measuring and monitoring these risks, including their
target and maximum values. Zero tolerance is established for all risks the Group is unwilling to
assume. One of the key indicators for measuring business performance and the achievement of
strategic objectives is the capital adequacy ratio.
The risk management process consists of risk identification, assessment or measurement,
treatment, monitoring and reporting.
Risk identification is an ongoing process involving business functions at all levels. It is normally
carried out once a year as part of drawing up the business and financial plan, and more
frequently if necessary.
The standard Solvency II formula (the regulatory method) is primarily used for risk assessment.
The formula is based on regulatory volatilities and own risk exposure. The overall risk
assessment (solvency capital requirement) takes into account the diversification defined by the
regulatory method. This assessment is complemented by the Company's own estimates of the
volatility of risk factors, generally using the Value at Risk method and based on the same
assumptions as the regulatory method, i.e. with a 99.5% confidence level over a one-year
horizon. Risks are additionally assessed according to the methodology of S&P credit rating
agency.
109
In the risk management process, the target values or limits for assumed and potential risks are
defined and must be complied with when assuming these risks. The Company employs well-
established multi-level risk monitoring systems to efficiently identify potential risk increases.
These trends are identified through processes at the business line level and regularly
communicated to the competent bodies by key functions. At Group level, exposure
concentration and heightened volatility for risks associated with the Group's major
vulnerabilities are closely monitored. Material detected or identified risks are treated also in the
own risk and solvency assessment process.
The Risk Management Department regularly monitors the matching of the current risk profile
and the defined risk appetite. The findings are reviewed by the Risk Management Committee,
which approves appropriate measures to address any detected deviations. The findings are
regularly reported to the Management Board, the Supervisory Board and its Risk Committee.
Risk management also includes the own risk and solvency assessment (ORSA) process, in which
the Group assesses its solvency needs over the entire strategy period and evaluates the
appropriateness of strategic guidelines in terms of ensuring adequate capital adequacy.
Measures are planned to maintain the Group's capital adequacy ratio within the target range of
200–250%. The appropriate value of the ratio is ensured through the capital management
process. The movement of the ratio is monitored through a set of detailed risk indicators and
exposure limits across all segments of the Group's operations. Maintaining capital adequacy
within the target range is an ongoing process, which requires regular review of business
decisions in terms of profitability and the risks assumed. Capital adequacy is also influenced by
the dividend policy, as set out in the Capital Management Policy of the Company and the Group,
and is subordinated to strategic objectives and the requirement to maintain adequate capital.
In the context of the own risk and solvency assessment process, the firmness of capital adequacy
is evaluated using stress scenarios that account for existing, potential and emerging risks, with
each type of risk being assessed individually. In 2025, the Group carried out nine stress tests,
which enable appropriate action, such as adjusting the guidelines for transaction acceptance,
premium rates, the limit system, risk transfer and other activities. This approach strengthens
the Group's resilience to identified risks and supports the improvement of internal control
systems, while also updating an effective strategic decision-making process.
As part of the ORSA process, the appropriateness of the regulatory method is also verified,
taking into account the findings of the internal risk assessment method. A comprehensive
analysis is conducted at least annually to determine the regulatory method's suitability.
9.1.3 Risk classification
The Group monitors risks internally in accordance with the standard formula set out in the
Insurance Act (ZZavar-1). The methods used to manage each type of risk, together with the
exposures and the assessment of these risks, are presented in Section 2.8 of the Accounting
Report.
The most significant types of risk assumed in the course of the Gorup's operations are described
below.
▪ Capital risk is the risk of loss due to inadequate capital amount and/or structure with regard
to the size and nature of the business. The risk may also arise from difficulties encountered
when the company seeks to acquire additional capital, particularly in situations requiring a
rapid capital increase and/or under adverse conditions. Capital risks also include legislative
changes and changes in accounting standards having an impact on the Group's capital
adequacy and, consequently, on the Company's dividend policy.
110
▪ Underwriting risk is the risk of loss or of adverse change in the value of insurance liabilities
due to inadequate pricing and provisioning assumptions taken into account in the
calculation of insurance technical provisions. Underwriting risk is divided into non-life
underwriting risk (including health insurance) and life underwriting risk (including pension
insurance).
▪ Non-life underwriting risk comprise premium risk, provision risk, lapse risk and
catastrophe risk.
▪ Life underwriting risk comprise mortality risk, longevity risk, morbidity risk, lapse risk,
expense risk, catastrophe risk and revision risk.
▪ Market risk is the risk of loss from adverse changes in the financial position, which may
result from fluctuations in the level and the volatility of market prices of assets, liabilities
and financial instruments. Market risk includes interest rate risk, equity risk, property risk,
spread risk, currency risk and market risk concentration.
▪ Credit risk is the risk of loss or adverse change in the financial position of the company due
to fluctuations in the credit position of counterparties and is a result of the debtor's inability
to fulfil contractual obligations.
▪ Liquidity risk is the risk of loss if the company is unable to settle all due obligations or is
forced to provide the necessary funds at significantly higher costs than usual. The risk of
settling matured and contingent liabilities and market liquidity risk are monitored in the
context of the liquidity risk.
▪ Operational risk is the risk of loss arising from inadequate or failed internal processes,
personnel or systems, or from external events and their impact. This also includes ICT risk,
covering information security risk, with a focus on cyber risk and major business
interruptions.
▪ Non-financial risk includes strategic risk, reputational risk, Group risk and sustainability
risks. It predominantly originates from the external environment and is closely linked to
other risks, especially operational risk. Generally, it includes several realised factors both
inside and outside of the Group. Sustainability risk is also identified and assessed through
the double materiality assessment (DMA) process, in accordance with ESRS. See Section
10.1.5 Double materiality assessment for more information.
The Group is also exposed to potential or emerging risk. This is the risk that may develop in the
future or that already exists but is not yet considered material. It is difficult to assess but may
have a significant impact on the business. It cannot be predicted based on past experience as
there is often not enough data from which to predict either the frequency or the severity of the
damage caused.
Potential or emerging risk is therefore monitored closely and, in view of the findings, the risk
management system is upgraded accordingly.
Classification of the Group's risks according to IFRS
The International Financial Reporting Standards (IFRS) comprise underwriting, market, credit,
liquidity and other risks. The Group's risk classification can be translated into the IFRS risk
classification as follows:
▪ Market risk is most commonly identified as interest rate risk, equity risk, property risk,
spread risk, currency risk and market risk concentration, according to these standards.
▪ Under IFRS, credit risk includes counterparty default risk, a significant part of which
comprises exposures from reinsurance, cash, cash equivalents and receivables, as well as
spread risk and market concentration risk. The classification used by the Group considers
the latter two as part of market risk.
111
▪ There are no differences between the classifications of underwriting risk and liquidity risk.
▪ Other risks under IFRS include capital, operational and non-financial risks.
The situation is regularly and systematically monitored. Risk exposure and risk assessment
based on regulatory requirements and internal risk classification are reported to the relevant
bodies and the regulator. Due to the differences in the IFRS and Solvency II valuation, the values
of individual balance sheet items may differ noticeably, which is also reflected in differences in
the identified exposure to individual risks. In addition, different valuation methods affect the
sensitivity of the items and therefore the risk assessment. A more detailed presentation of the
differences between the two valuations is included in the Solvency and Financial Condition
Report, which is published on the website (www.triglav.eu).
Risk exposures according to the classification used in the risk management system are
presented further on in the text.
9.2 Capital position
With its continuous capital management process, the Group also ensured an optimal level and
structure of capital in 2025. Its use is optimised while also managing capital and other risks.
9.2.1 Capital management
2
A well-integrated risk management system is essential to effective management of capital and
capital risk. Ensuring capital adequacy within the target range allows the Group to maintain
capital that is always aligned with its risk profile and business strategy.
The purpose of capital management is to achieve safe and profitable operations, as well as a
long-term and stable return on investment, by paying out dividends based on the criteria in the
dividend policy. When entering into transactions, profitability is consistently assessed in
relation to the risks assumed. This ensures the Group's target capital adequacy while providing
an appropriate return to shareholders.
The Group's target capital adequacy is set within the range of 200–250%. This means that the
Group has an adequate amount of capital to carry out its core business and cover potential
losses. Capital surplus provides protection against losses due to unforeseen adverse events and
volatile capital requirements. As part of capital management, the Group regularly plans and
assesses the amount of available capital and its consistency with the strategic objectives of the
Company and the Group.
Capital adequacy also has a significant impact on the Group's credit rating. Therefore, when
making business decisions, the criteria of the models of major credit rating agencies are taken
into account. The Group's capital model is assessed by the credit rating agencies S&P Global and
AM Best. See Section 6.6 Credit rating of the Triglav Group and Zavarovalnica Triglav for more
information on the credit rating.
2
SASB: FN-IN-550a.3
112
9.2.2 Capital adequacy and the risk profile in 2025
Effective capital management enhances the Group's operations, enabling it to make the right
decisions and maintain its competitive edge.
Explanation of differences in capital valuation in the balance sheet for solvency and financial
reporting purposes for the Triglav Group as at 31 December 2025 (EUR million)
* Consolidation method for solvency purposes differs for Triglav Investments, Triglav pokojninska družba, Sarajevostan, TPD Skopje and Triglav Investments Sarajevo.
** The fair value of intangible assets is valued at 0.
*** In this item interests in companies with sectoral rules and forseeable dividends are included.
1,078.1
1,161.7
1,215.7
119.5
37.5
832.1
248.0
3.4
152.2
60.3
35.6
914.0
140.2
6.8
86.2
12.0
0 400 800 1.200
Group's equity*
Intangible assets and deferred acquisition costs**
Net deferred taxes
Investments in subsidiaries and associates
Property
Financial investments
Net unit-linked insurance assets
Reisurance recoverables
Insurance technical provisions
Subordinated liabilities
Other assets and liabilities
Excess of assets and liabilities
Deductions for participants in other financial…
Deductibles for non-available own fund itmes
Subordinated liabilities
Group's eligible own funds
113
The definition of equity in the balance sheet for the preparation of financial statements differs
from its definition for solvency purposes. Differences and important reasons for changes in
items of both types of capital in 2025 are described in the Group's Solvency and Financial
Condition Report for 2025, D and E sections, available at www.triglav.eu.
Capital adequacy is calculated according to the Solvency II standard formula as the ratio
between eligible own funds and the solvency capital requirement. Adjustments and
simplifications are not taken into account in the calculation.
The Triglav Group was well-capitalised as at 31 December 2025. Its capital adequacy ratio stood
at 206%, within the target range, aligning with the capital management strategic objectives and
the dividend policy criteria presented in Section 9.2.1 Capital management.
Capital adequacy of the Triglav Group and Zavarovalnica Triglav
Triglav Group
Zavarovalnica Triglav
31 Dec 2025
31 Dec 2024
31 Dec 2025
31 Dec 2024
Available own funds (EUR million)
1,215.7
1,105.5
1,242.9
1,130.3
SCR (EUR million)
589.0
504.9
479.7
416.4
Capital adequacy (%)
206
219
259
271
The Group's capital adequacy was affected by the increase in own funds by EUR 110.3 million
compared to 2024. The bulk of the increase comes from a higher reconciliation reserve. The
available own funds for 2025 reflect the expected dividend for the financial year of EUR 68.4
million, whereas those for 2024 included an expected dividend of EUR 65.7 million. The Group's
solvency capital requirement increased by EUR 84.1 million, primarily due to higher capital
requirements for underwriting risks resulting from business volume growth.
At least once a year a sensitivity analysis of the Group's capital adequacy ratio is performed to
test the effects of major changes in selected variables. Based on this analysis, the stability of the
Group's capital position and its resilience to material risk factors is assessed.
The analysis as at 31 December 2025 shows sensitivity to individual shocks on financial markets.
The sensitivity analysis of the Group's capital adequacy ratio
206%
210%
203%
204%
209%
201%
212%
214%
199%
210%
203%
150% 175% 200% 225% 250%
Capital adequacy ratio as at 31 Dec. 2025
Equity investments + 25 %
Equity investments - 25 %
Interest rates + 100 bps
Interest rates - 100 bps
Credit spreads + 50 bps
Credit spreads - 50 bps
Property + 25 %
Property - 25 %
Exchange rates + 20 %
Exchange rates - 20 %
114
Among the risks included in the standard formula, the Group is most exposed to underwriting
and market risks, followed by operational and credit risks. Within the Group, the parent
company assumes the bulk of the risks. See Section 2.8 of the Accounting Report for more
information about the types of risks assumed by the Group.
The risk profile of the Company and the Group shows the types of risks to which they are most
exposed.
Risk dashboard of Zavarovalnica Triglav and the Triglav Group* as at 31 December 2025
Risk
Risk
assessment
(current)
Risk trend
(future)
Note
Capital
adequacy
and capital
risk
◼
The capital adequacy of both the Company and the Group remained
within the target range. Their capital strength was reaffirmed by AM
Best, which assigned a long-term credit rating of "A", and S&P Global,
which assigned a financial strength rating of "A+". The latter
upgraded the Group's credit rating from "A" to "A+" in 2025.
Underwriting
risks
◼
The assessment of underwriting risks had not changed significantly
over the past year. Growth in insurance premium resulted in an
increase in exposures to premium, provision and catastrophe risks,
leading to a corresponding rise in capital requirements.
Market risks
◼
The Group continues to maintain risks at defined levels. Particular
attention is given to identifying optimal investment policies, with a
focus on asset-liability matching.
Credit risks
◼
Credit risks remain low due to regular, systematic and
comprehensive exposure management. The suitability and quality of
reinsurance partners are regularly reviewed to ensure they are well-
diversified.
Liquidity risk
◼
The Company's strong liquidity position and the adequate
operational liquidity of the Group's subsidiaries are ensured through
regular liquidity monitoring. Liquidity risk is regularly monitored
using internally established indicators to ensure adequate liquidity
of the parent company and its major subsidiaries, even under stress
scenarios.
Operational
risks
◼
Operational risks are managed proactively. Priority is given to the
regular maintenance and upgrading of outsourcing management
and ICT risks, including the information security management
system, with particular focus on cyber risks. Technological risks
related to the development of artificial intelligence, automation and
digital transformation are also significant. Furthermore, internal
interprocess risks are also managed. Operational risks are also
increased by large-scale regulatory changes and the general staffing
risk when recruiting workers in shortage occupations.
Non-
financial risk
◼
Non-financial risk remained stable and well-managed. Reputational
risk, Group risk, sustainability risk and strategic risk are effectively
monitored and managed through key indicators and timely
responses to external factors. Regular integration of sustainability
aspects, monitoring of intra-Group dependencies and adjustment of
strategic guidelines ensure that exposure remains low.
* An overall assessment of the main risk categories was made on the basis of quarterly risk reports. The risk trend shows a potential
assessment of future risks relative to the latest projections.
i) The colour scale of assessed risks:
High
Medium
Low
ii) Risk trend: (↓) downward, (→) stable, (↑) upward
The presentation of the Triglav Group's risk profile and assessments by individual risk category
are based on market values for solvency purposes. The Company uses a regulatory method,
115
which is assessed as appropriate for risk measurement in the context of the own risk and
solvency assessment process.
Risk profile assessment* of the Triglav Group as at 31 December 2025
* The risk profile is determined based on risk assessment using the standard formula, without taking into account the effects of
diversification across individual risk categories.
As at 31 December 2025, the Group was financially stable and adequately liquid with a strong
capital base.
9.2.3 Identified future risks
The main risk arising from the external environment relates to geopolitical uncertainties,
including tighter customs policies. These can affect inflation, economic growth and financial
market movements. Uncertainty regarding the future trend of inflation is also linked to
uncertainty regarding the direction of key interest rates.
With regard to market risks, particularly an increase in spread risk could arise due to the
aggravated economic situation or deteriorating credit ratings of issuers of securities. If
economic activity deteriorates, negative developments in stock markets are possible and a
possible decline in the value of real property may also be expected. This could then manifest in
a decrease in the value of financial investments. Triglav Group potential impact of interest rate
risk associated with possible changes in risk-free interest rates successfully manages by actively
matching assets and liabilities.
Potential more severe recession could negatively affect demand for insurance and reduce the
volume of premiums written, which could consequently have a detrimental effect on the
Group's operations. The potential emergence of recession could also affect liquidity risk, which
could increase due to the potential reduction of inflows from the insurance business and a lower
market liquidity of the investment portfolio.
An increase in underwriting and credit risks could also affect business in the coming year,
primarily due to increased business volume in the Italian motor insurance market. In the context
of underwriting risks, premium risks and the appropriateness of pricing policies are consistently
monitored, while provision risks are managed. To mitigate credit risks, mechanisms for
56%
24%
7%
8%
2%
3%
57%
25%
6%
7%
3%
2%
0%
10%
20%
30%
40%
50%
60%
Underwriting risk Market risk Credit risk Operational risk Risk of residual
companies
Risk of companies
from other
financial sectors
2025 2024
116
assessing the credit ratings of major partners are being strengthened, along with close
monitoring of their payment discipline. The adequacy of reinsurance protection is also carefully
assessed and adjusted where necessary.
Technological risks are expected to gain further importance, particularly with respect to the
further development of artificial intelligence, automation and the digital transformation of
business and the broader business environment. Cyber risks remain among the key challenges
to ensuring the security and resilience of the Group's operations.
All of these risks affect capital adequacy, therefore they are actively managed by Triglav Group.
As part of testing the Group's sensitivity, the factors that could have a material impact on its
operations in the coming years were examined.
Sensitivity analysis as at 31 December 2025* (EUR million)
Total impact on equity
Triglav Group
Zavarovalnica Triglav
Spread risk (+50 bp)
–33.1
–26.1
Interest rate risk (+100 bp)
–12.6
–8.3
Equity risk (–10%)
–7.4
–7.0
Property risk (–5%)
–8.9
–5.5
Total
–62.0
–47.0
* The effects shown include the tax aspect.
A sensitivity analysis shows potential impacts on the Group's capital in the case of an adverse
event with a sudden increase in interest rates (by 100 basis points), an increase in credit spreads
(by 50 basis points), a drop in equity exposure (by 10 percentage points) and in real property
exposure (by 5 percentage points). Should this event be realised, the Group's capital would
decrease by EUR 62.0 million.
The sensitivity analysis of the Group's credit portfolio again confirmed that the credit ratings of
banks and reinsurers, as well as the share of insurance and subrogation claims, have a significant
impact on operations. The sensitivity analyses for the renewal rate and the suitability and
sensitivity analysis to test the appropriateness of the "probability of default" assumption
indicated a high sensitivity of the Group's portfolio to these factors.
In testing the Group's sensitivity to liquidity risk through regular stress scenarios, it was found
that the Group was sensitive to mass policy lapse. Equally important are any declines in the value
of liquid investments that may materialise as a result of reduced liquidity or other financial
market fluctuations.
117
10. Sustainability report
10.1 ESRS 2 General disclosures
10.1.1 Basis for preparation
The Sustainability Report is an integral part of the Annual Report for the financial year ending 31
December 2025. It is based on the requirements of Directive (EU) 2022/2464 (CSRD) and the
European Sustainability Reporting Standards (ESRS) and includes disclosures in accordance with
Regulation (EU) 2020/852 (EU Taxonomy Regulation) and Commission Delegated Regulation
(EU) 2021/2178 of 6 July 2021. In preparing the disclosures, amendments adopted by the
European Commission under the delegated act for simplification (the Omnibus) are also taken
into account, namely Commission Delegated Regulation (EU) 2026/73 of 4 July 2025 amending
Delegated Regulation (EU) 2021/2178 concerning the simplification of the content and
presentation of information to be disclosed concerning environmentally sustainable activities
and Delegated Regulations (EU) 2021/2139 and (EU) 2023/2486 concerning the simplification
of certain technical screening criteria for determining whether economic activities cause no
significant harm to environmental objectives. The CSRD was transposed into Slovenian law by
amending the Companies Act (ZGD-1). In reporting under the ESRS, we apply the “quick-fix”
reliefs; therefore, during the transitional period certain data points are not disclosed within ESRS
S1 (S1-7, S1-11, S1-13, selected S1-14, and S1-15). These reliefs are applied in accordance with
the applicable provisions of the Delegated Regulation and will be progressively replaced by full,
regular disclosures.
The disclosures and information in the sustainability report to which the auditor’s limited
assurance engagement relates apply exclusively to the Triglav Group (consolidated reporting)
and not to Zavarovalnica Triglav, d.d. as an individual company. Disclosures and data relating to
periods prior to 2024, as well as all comparative calculations based on information from periods
before 2024, are not subject to the auditor’s assurance engagement.
The Sustainability Report presents the material impacts, risks and opportunities (IROs) related
to the environmental, social and governance (ESG) aspects of Triglav Group's operations.
Material impacts, risks and opportunities were identified through a double materiality
assessment (DMA), covering the Group's environmental and social impacts, and the associated
risks and opportunities for its operations.
The consolidation level of sustainability disclosures
3
The financial reporting for the Group comprises all companies included in the consolidated
financial statements (see Section 2.3 of the Accounting Report for more information). However,
the consolidation level of data in the 2025 Sustainability Report differs for some disclosures from
the scope of companies included in the consolidated financial statements. Companies with no
more than one employee and no office space of their own are excluded in the carbon footprint
calculation. These companies are Zavod Vse bo v redu, Ljubljana, Triglav INT, d.o.o., Triglav
Savjetovanje, d.o.o., Sarajevo, Triglav International, d.o.o., Beograd, Triglav upravljanje
nekretninama, d.o.o., Podgorica, Triglav upravljanje nekretninama, d.o.o., Zagreb, Triglav
upravljanje nekretninama, d.o.o., Sarajevo, and Triglav upravuvanje so nedvižen imot DOOEL,
Skopje.
3
BP-1_01, BP-1_02, BP-1_03.
118
Sustainability risks are managed across all (re)insurance and major financial companies within
the Group. However, for other companies within the Group, these risks are rendered negligible
due to their size and are therefore not actively managed.
Disclosures related to marketing activities (S4) do not include the following companies:
Autocentar BH, d.o.o., Društvo za upravljanje EDPF, a.d., Banja Luka, Eskulap, družba za
zdravstvene storitve, d.o.o., Lovćen auto, d.o.o., Podgorica, Penzisko društvo, a.d., Skopje,
Sarajevostan, d.d., Sarajevostan, d.o.o., Triglav Investments, d.o.o., Sarajevo, Triglav INT, d.o.o.,
Triglav International, d.o.o., Beograd, Triglav penzisko društvo, a.d., Skopje, Triglav Savetovanje,
d.o.o. Beograd, in liquidation, Triglav Savjetovanje, d.o.o., Sarajevo, Triglav Svetovanje, d.o.o.,
Triglav upravljanje nekretninama, d.o.o., Podgorica, Triglav upravljanje nekretninama, d.o.o.,
Zagreb, Triglav upravljanje nekretninama, d.o.o., Sarajevo, Triglav upravuvanje so nedvižen imot
DOOEL, Skopje, Triglav Upravljanje nepremičnin, d.o.o., Zavod Vse bo v redu, Ljubljana, and
Zavarovalnica Triglav Re, d.d.
The information on supplier management (G1-2) applies to all subsidiaries in Slovenia, except
Eskulap, družba za zdravstvene storitve d.o.o.
The compliance information (G-1, S4-1, S1-3) does not include the following companies: Triglav
INT d.o.o., Triglav Med d.o.o., Eskulap, družba za zdravstvene storitve d.o.o., Triglav Avtoservis
d.o.o., Zavod Vse bo v redu, Ljubljana, Triglav Investments, d.o.o., Sarajevo, Društvo za upravljanje
EDPF, a.d., Banja Luka, Triglav upravljanje nekretninama, d.o.o., Zagreb, Triglav upravljanje
nekretninama, d.o.o., Sarajevo, Triglav upravuvanje so nedvižen imot DOOEL, Skopje, Triglav
International, d.o.o., Beograd, Autocentar BH, d.o.o., Sarajevostan, d.o.o., Triglav Savjetovanje,
d.o.o., Sarajevo and Lovčen auto, d.o.o., Podgorica.
The double materiality assessment process described in Section 10.1.5 encompasses impacts,
risks and opportunities stemming from the Group's own operations and from other parts of the
value chain, as identified by stakeholders involved during the double materiality assessment
process. The Group's own operations are at the core of its business model, enabling efficient
functioning across three pillars: insurance, asset management and other services. See Section
10.1.6 Identified impacts, risks and opportunities for more information.
4
No information regarding intellectual property, know-how or innovation outcomes has been
omitted from the Sustainability Report. Similarly, the Group did not apply any exemptions from
disclosure in respect of any anticipated event or matter subject to ongoing negotiations.
5
Changes in the preparation or presentation of sustainability information
6
From the reporting period for the financial year ending 31st December 2024, the Group's
sustainability disclosures are prepared in accordance with the requirements of the CSRD and the
ESRS. Any changes, including the methodologies used for calculating individual indicators,
(particulary in the methodologies for calculating indicators within ESRS-1 – Carbon Footprint),
are described within the text and footnotes.
7
The Triglav Group reviews the double materiality
assessment (DMA) process at least once a year and, where necessary, updates it to reflect any
significant changes in impacts, risks and opportunities, as well as in the Group’s internal and
external context.
4
BP-1_04.
5
BP-1_05, 06.
6
IRO-1_15, BP-2_10.
7
BP-2_11-14.
119
In 2025, the Group significantly updated the methodology of the double materiality assessment
(DMA) process. The updates included broadening the range of stakeholders involved, conducting
a more in-depth analysis across the entire value chain, and refining the materiality thresholds
and quantification of impacts, risks and opportunities. A geographical perspective was further
integrated into the methodology, particularly for environmental topics, enabling better
consideration of the local specificities of the markets in which the Group operates. These
changes affected the categorisation and assessment of the materiality of individual topics
compared with the 2024 DMA, as some topics had their materiality assessments revised, while
others were further broken down or merged.
In the 2025 reporting year, the Group also updated the presentation of material impacts, risks
and opportunities by systematically linking the results of the DMA to the ESRS structure and
supporting them with a final list of material impacts, risks and opportunities. The comparison
with 2024 is therefore primarily reflected in the reorganisation and consolidation of topics from
broader topic titles into ESRS E1, S1, S4 and G1, while the content of the key areas has largely
been retained and the presentation standardised and made more clearly traceable to individual
impacts, risks and opportunities.
Key substantive changes compared to 2024 include: (i) merging the topics of Own workforce and
Equal treatment and opportunities for all in ESRS S1, with a clearer distinction between material
impacts and financial risks and opportunities, respectively; (ii) placing the topics of Privacy and
data protection and Access to services and financial literacy in ESRS S4, with a more precise
definition of impacts, risks and opportunities in terms of privacy, access to products and services,
and transparency of information and communication to clients; (iii) including the topics of
Business ethics and Management of relationships with suppliers in ESRS G1, with a clear
illustration of the impacts, risks and opportunities related to corporate culture, anti-corruption
practices and responsible relationships with suppliers; (iv) presenting the climate-related topic
of Climate change adaptation and mitigation in ESRS E1 with a more detailed set of impacts,
risks and opportunities covering own operations, insurance business and asset management,
and highlighting financially material physical risks; and (v) separately highlighting the Group-
specific disclosure on Responsible investment, reflecting the materiality of impacts and
expectations in relation to the Group's investment activities.
8
Time horizons
9
The Triglav Group deviates from the proposed time horizons defined in ESRS 1, section 6.4.
Instead, it has adopted time horizons in its internal documents based on the business cycle, as
recommended by EIOPA
10
. The short-term is defined as 1 to 5 years, the medium-term as 6 to 10
years, and the long-term as more than 10 years.
Incorporation by reference
11
All content required by the ESRS is presented in Section 10. Sustainability Report. However,
information on risk management and internal controls related to sustainability reporting (GOV-
5) is included in Section 2.8 Risk management in the Accounting Report.
8
SBM-3_11.
9
BP-2_01, BP-2_02.
10
Consultation paper on application guidance on using climate change scenarios in the ORSA.
11
ESRS 2 BP-2_20.
120
10.1.2 Sustainable development management system
12
Company governance
Zavarovalnica Triglav d.d., the parent company of the Triglav Group, operates under a two-tier
governance system. Its governance bodies are the General Meeting of Shareholders, the
Management Board and the Supervisory Board. The Management Board presents and represents
the Company, independently and on its own responsibility, managing and governing it with the
objective of maximising the value of the Company and shareholders' wealth over time, while
taking into account the principles of sustainable development and the interests of other
stakeholders. The Supervisory Board oversees the management of the Company and, in addition
to its statutory powers, gives its consent to selected decisions of the Management Board. A more
detailed regulation of the powers, responsibilities and activities of the management and
supervisory bodies is defined in the document Governance System and Policy of Zavarovalnica
Triglav d.d. (available at: https://www.triglav.eu/wps/wcm/connect/55bf2bf4-0637-4946-
8602-3da5017e0595/ENG+-Sistem+in+politika+upravljanja+ZT%282025%29-
za+objavo.pdf?MOD=AJPERES&CONVERT_TO=url&CACHEID=ROOTWORKSPACE-55bf2bf4-
0637-4946-8602-3da5017e0595-pz7HvWU). The objective is to ensure balanced gender
representation in the management and supervisory bodies, so that the members of the
Management Board and the Supervisory Board together include at least 33% of the under
represented gender (gender representation ratio). In 2025, the gender representation target set
out in the Diversity Policy for the members of the Management Board and the Supervisory Board
was achieved.
In 2025, the Management Board had five members, including one Worker Director:
▪ Andrej Slapar, President of the Management Board,
▪ Uroš Ivanc, Member,
▪ Tadej Čoroli, Member,
▪ Marica Makoter, Member and Worker Director,
▪ Blaž Jakič, Member.
The Company's conduct of business is overseen by the Supervisory Board. As at 31 December
2025, the Supervisory Board had seven members, comprising six shareholder representatives
and one employee representative:
▪ shareholders representatives:
▪ Andrej Andoljšek, Chairman,
▪ Tim Umberger, Vice Chairman,
▪ Barbara Nose, Member,
▪ Barbara Cerovšek Zupančič, Member,
▪ Rok Ponikvar, Member,
▪ Monica Cramér Manhem, Member.
▪ employee representatives:
▪ Rudi Lipovec, Member.
In 2025, the Company had the following committees: the Audit Committee, the Appointment
and Remuneration Committee, the Strategy Committee and the Risk Committee, as well as the
Nomination Committee as an ad-hoc committee.
By signing the Statement of Independence, all Supervisory Board members confirmed their
compliance with the conflict-of-interest criteria and declared themselves independent, meaning
that 100% of the Company's Supervisory Board members are independent.
12
ESRS 2 GOV-1_01-15, GOV-1_17, G1.GOV-1_01-02, GOV-2_02, IRO-1_13.
121
Expertise, competence and reporting to management and supervisory bodies
In its regular assessment of its composition and effectiveness in accordance with the Insurance
Act (ZZavar-1) and the Companies Act (ZGD-1), the Supervisory Board verifies that its members
possess appropriate knowledge, skills and experience relating to insurance and financial
markets, business strategy and business models, governance systems, financial and actuarial
analyses, risk management, and the regulatory and legal environment in which the Company
operates. Members of the Management Board and the Supervisory Board possess experience
relevant to the Group’s insurance and financial activities, its key products, and the geographical
markets in which it operates (Slovenia and selected countries of the Adria region.
The knowledge and experience of the members of the Management Board and Supervisory
Board are also crucial for managing the Group's material impacts, risks and opportunities (IROs)
in sustainability. Management and strategic leadership competences enable the integration of
sustainability objectives into long-term guidelines and the adaptation to regulatory and market
changes. Legal expertise supports compliance and mitigates legal risks. Insurance and actuarial
expertise facilitates the assessment of climate risks and long-term liabilities. Finance and
financial markets expertise guides investments with sustainable characteristics. Risk
management competences ensure the systematic management of environmental, social and
governance risks. HR skills and knowledge of social dialogue further contribute to the
management of social aspects.
The Group ensures the relevance and continuous development of these competences through
fit and proper assessment procedures for candidates and members of the management and
supervisory bodies, as provided for by law and internal regulations and detailed further in the Fit
and Proper Policy for Management and Supervisory Board Members. This policy defines pre-
appointment, periodic, ad hoc and post-appointment assessments and emphasises the diversity
of knowledge and competences at the level of the body as a whole. With the March 2025 update,
the Group further highlighted the importance of in depth knowledge in sustainability reporting,
cyber security and resilience, business continuity, tax reporting, business intelligence, artificial
intelligence and ICT systems, as well as the financial strength of candidates against property
criteria, to support independent operations and mitigate the risk of conflicts of interest.
The Management Board, collectively, leverages these competencies to support the integration
of sustainability aspects into the Group's business models and to strengthen business resilience.
To ensure effective and prudent management, key functions and other business functions report
regularly to the Management Board, the Supervisory Board and the Audit Committee, while key
functions notify the Management Board – and, where appropriate, the Supervisory Board –
immediately of highly material risks. The Management Board is also regularly informed of
material impacts, risks and opportunities, due diligence activities, and the effectiveness of
policies, measures, indicators and targets adopted for managing these impacts, risks and
opportunities, based on regular reporting on indicators and the achievement of milestones.
Sustainable development management
The organisation and operation of the sustainable development system within the Group is
regulated in a way that ensures the alignment of all key sustainability-related activities with the
Group's strategic ambitions and compliance with legislative requirements. The Management
Board is responsible for developing and implementing the Group's strategy, which includes its
strategic objectives in sustainable development, while the Supervisory Board approves the
Group's strategy and takes note of its implementation. The sustainable development policy is
adopted by the Management Board and approved by the Supervisory Board. A member of the
122
Management Board is designated as responsible for the environmental, social and corporate
sustainable development (ESG) activities.
The Sustainable Development Department is responsible for the overall management of the
Group's sustainable development and operates within the Management Board Office,
specifically within the Corporate and Legal Affairs Division of the Group's parent company. The
department oversees the development and implementation of the sustainable development
policy and strategy, the carbon footprint methodology and the double materiality assessment;
supports sustainability risk management; reports to the relevant member of the Management
Board; and ensures the transfer of guidelines to subsidiaries. Sustainability coordinators are
appointed in the relevant departments and business lines of the Company and its subsidiaries
to ensure the implementation of strategic guidelines and compliance with legislative
requirements.
The Company's business functions report sustainability-related activities to the Management
Board and the Sustainable Development Department reports to the Management Board
member responsible for ESG. The Audit Committee of the Supervisory Board and the Supervisory
Board monitor these processes and oversee sustainability reporting, which they discuss and
approve as part of the adoption of each Triglav Group's annual report.
13
In 2025, the Management Board members received an average of 18.6 teaching hours of training
on sustainability-related topics. In March 2025, an online training session on ORSA and cyber
security was organised for members of the Supervisory Board, and they also participated in
various external training programmes.
14
Integration of sustainability-related performance in incentive schemes
15
The basis for the remuneration of the Management Board is the Remuneration Policy of
Zavarovalnica Triglav (hereinafter: the Remuneration Policy), which is based on Directive
2009/138/EC – Solvency II, as amended by Directive 2012/23/EU, Commission Delegated
Regulation (EU) 2015/35 supplementing Directive 2009/138/EC, Regulation (EU) 2019/2088 on
sustainability‐related disclosures in the financial services sector and the ZGD-1. The
Remuneration Policy is one of the policies with which the Company implements a robust and
reliable management system, ensures business integrity and transparency, and maintains the
appropriate capital strength of the Company. Furthermore, it encourages reliable and effective
risk management, and provides for the acquisition and retention of appropriately professionally
qualified, competent, responsible and engaged employees. The Policy is designed to take into
account the Company's internal organisation and the nature, scope and complexity of risks,
including sustainability risks. The variable remuneration of employees is determined by taking
into account the implementation of strategic guidelines, which also include the commitments
to sustainability, long-term interests and performance of the Company and the Group as a
whole. The Remuneration Policy is available at the following link: The Remuneration Policy is
available at the following link: www.triglav.eu/en/about-us/compliance/documents-and-
commitments.
The remuneration of the Management Board members consists of the basic salary (fixed part)
and a variable part of the salary. The basic salary is based on the Remuneration Policy, the
employment and performance contract and the Act Governing the Remuneration of Managers
of Companies with Majority Ownership Held by the Republic of Slovenia or Self-Governing Local
Communities (ZPPOGD). In accordance with the revised Remuneration Policy, the basic salary of
13
ESRS 2 GOV-2_01.
14
ESRS 2 GOV-1_16.
15
ESRS 2 GOV-3_01-06, E1.GOV-3_01-03.
123
the President and members of the Management Board shall not exceed EUR 22,000.00. Every
two years, the ceiling shall be increased according to the increase in the average consumer price
index for each of the last two years.
The contract of employment and appointment to office concluded with the President and the
members of the Management Board will set the basic salary within the limits defined in this
Policy, i.e. the amount of the basic salary of the President of the Management Board shall be set
at the ceiling and the amount of the basic salary of each Management Board member shall be
up to a maximum of 95% of the President of the Management Board's salary, depending on the
duties and responsibilities of the specific Management Board member (e.g. taking into account
the sectoral division of their areas of responsibility, their individual qualities (knowledge,
experience, references, skills) and the remuneration of members of the management bodies of
comparable companies in the insurance sector in Slovenia and in the region.
Notwithstanding the above, during the period of validity of the ZPPOGD, the basic salary of the
President of the Management Board is set at five times the average gross salary in the previous
financial year, paid in the Triglav Group companies headquartered in the Republic of Slovenia
and consolidated in the annual report in accordance with the Companies Act, while the basic
salary of the Management Board members is set at 95% of the basic salary of the President of
the Management Board.
The performance-based variable remuneration may be set at a maximum of 60% of the basic
salaries paid in the financial year. If the Company meets at all of the following criteria: it is a
public limited company, more than 50% of its net revenue is generated in foreign markets, it has
more than 5,000 employees in the group and it has at least EUR 500 million of share capital, a
performance-based variable remuneration may be set up to a maximum of 100% of the basic
salaries paid in the financial year. Notwithstanding the above, during the period in which the
ZPPOGD applies, the amount of the variable remuneration may be set at a maximum of 30% of
the basic salaries paid in the financial year. The variable remuneration includes part of the salary
for performance, part of the salary for the overall performance based on the overall annual
targets of the Management Board and part of the salary for individual performance based on
personal annual targets.
The Management Board's performance is determined by taking into account the Company's
performance in the short and long term, including taking into account the current and future
risks to which the Company is exposed. The performance assessment takes into account:
▪ Financial criteria (70% of all criteria) that can measure the business volume, profitability of
the insurance activity, profitability of the investment activity, cost efficiency, return on
equity and growth in the Company's value or other financial performance criteria.
▪ Non-financial criteria (30% of all criteria) that can measure the achievement of the business
strategy's non-financial objectives, compliance with the relevant regulations, internal acts
and limitations from the risk appetite statement, compliance with ethical and professional
standards, the achievement of sustainable development goals (environmental, social,
governance), and other non-financial performance criteria.
The variable remuneration is set in more detail using a methodology approved by the
Supervisory Board upon approval of the plan for the next financial year and a one-on-one annual
interview with each Management Board member, where the personal annual targets are
identified.
The variable remuneration proportion for Management Board members tied to the
Management Board's overall annual and medium-term sustainability objectives was up to 1.5%
of their basic salaries paid in 2025. Additionally, for Management Board members with
124
sustainability objectives included as part of their personal annual objectives, the proportion was
up to 5% of their basic salaries. Environmental objectives, particularly Scope 1 and 2 carbon
footprint (location-based method), are among the sets assessed in connection with the
sustainability objectives tied to the Management Board's remuneration.
Data on the remuneration of the Management Board members are disclosed in Section 4.4 of
the Accounting Report.
Due diligence statement
16
The due diligence system in the Group is ensured through compliance with legislation, external
commitments and internal documents. It is implemented through targeted compliance reviews,
internal audits, monitoring of operational loss event reports, issuing recommendations, tracking
the implementation and effectiveness of corrective actions, regular risk assessments and
assessing the adequacy of internal controls in accordance with the adopted annual plan. Regular
compliance audits address sustainability areas such as scenario assessments for sustainability
risks, non-compliance with human rights, ethical commitments, corruption and bribery
prevention, management of conflicts of interest, internal fraud, violations related to labour, and
health and safety at work.
In the area of business ethics and corporate culture, due diligence is performed in line with
applicable internal regulations, placing particular emphasis on employee training, ongoing
compliance monitoring, remediation of violations and strengthening a culture of integrity. In
relation to fraud and corruption prevention, procedures are in place to identify, report and
investigate internal and insurance fraud, protect whistleblowers and deploy advanced
technological systems to detect suspected fraud. Due diligence is also carried out in the areas of
competition and consumer protection, client and business relationships, supplier and contractor
management, including sustainability criteria, and the outsourcing of business functions.
Additionally, due diligence forms part of the Group's procedures for handling complaints from
clients and other external stakeholders, as well as for monitoring transparency and fairness
across the Group.
The table below outlines how the Group implements the core elements of due diligence for
people and the environment, and where details are provided in the Sustainability Report.
Core elements of due diligence
Sections in the Sustainability Report
Disclosures relate to impacts on people
and/or the environment
(a) Embedding due diligence in
governance, strategy and
business model
▪ ESRS 2 GOV-2 – section 10.1.2
▪ People and the environment
▪ ESRS 2 GOV-3 – section 10.1.2
▪ People and the environment
▪ ESRS 2 SBM-3 – sections 10.1.3, 10.1.6
▪ People and the environment
(b) Engaging with affected
stakeholders in all key steps
of the due diligence
▪ ESRS 2 SBM-2 – section 10.1.4
▪ People and the environment
▪ ESRS 2 GOV 2 – section 10.1.2
▪ People and the environment
▪ S1 – section 10.3.1
▪ People
▪ ESRS 2 MDR-P– section 10.1.2
▪ People and the environment
▪ ESRS 2 IRO-1, section 10.1.5
▪ People and the environment
▪ S4 – section 10.3.2
▪ People
(c) Identifying and assessing
adverse impacts
▪ ESRS 2 IRO-1, section 10.1.5
▪ People and the environment
▪ ESRS 2 SBM-3, section 10.1.6
▪ People and the environment
16
ESRS 2 GOV- 4_01.
125
(d) Taking actions to address
those adverse impacts
▪ ESRS 2 MDR-A, section 10.1.2
▪ People and the environment
▪ E1 – section 10.2.1
▪ The environment
▪ ESRS 2 MDR-M
▪ People and the environment
▪ ESRS 2 MDR-T
▪ People and the environment
▪ S1 – section 10.3.1
▪ People
▪ S4 – section 10.3.2
▪ People
▪ G1 – section 10.4.1
▪ People
(e) Tracking the effectiveness of
these efforts and
communicating
▪ S1 – section 10.3.1.2, 10.3.1.3
▪ People
▪ S4 – section 10.3.2.1
▪ People
▪ G1 – section 10.4.1
▪ People
Risk management and internal controls over sustainability reporting
Risk management, including sustainability risks, is outlined in Section 2.8 Risk management in
the Accounting Report. Sustainability risk management systems and processes are embedded in
this internal process and are continuously upgraded.
17
10.1.2.1 Strategic ambitions in sustainable development
In the Triglav Group's strategic ambitions in sustainable development (ESG) for the period to
2030, which build on the original ambitions for 2021–2025, the Group defined that by
systematically managing sustainable development, it creates a long-term stable basis for its
profitable and safe operations, supports the transition to a sustainable society and reduces its
impact on climate change. This approach is pursued across four key areas: (i) insurance and asset
management, (ii) own business processes, (iii) responsible stakeholder engagement and (iv)
effective corporate governance.
The Group's climate change mitigation and adaptation objectives are aimed at comprehensively
managing climate risks and contributing to the transition towards a low-carbon and climate-
resilient economy and society. With regard to climate change mitigation, the objectives include
reducing greenhouse gas emissions, including by lowering the carbon footprint of own
operations, increasing the share of bonds with sustainability characteristics, transitioning to
renewable energy sources and improving the energy efficiency of operations. Regarding climate
change adaptation, the objectives include developing insurance products that provide cover for
natural disasters linked to climate change. The Group defined its sustainability ambitions for
2030 in four key areas, which are outlined below.
18
Insurance and asset management
In asset management, the share of green and sustainable bonds, social impact bonds and
sustainability-linked bonds will be increased to 15% of the Group's bond portfolio by 2030, while
increasing the share of sustainable investments in line with the EU Taxonomy Regulation.
Exposure to issuers on the Coal Exit List (companies at which at least 10% of electricity
production or income stems from coal) will be kept below 1% of the total investment value. The
range of financial products aligned with Article 8 of the EU Regulation on sustainability-related
disclosures in the financial services sector (SFDR) will be increased.
In its insurance business, the Group will promote its range of insurance products related to
sustainable mobility and provide effective risk protection to companies engaged in the
17
IRO-1_12.
18
ESRS 2 SBM-1_21, SBM-1_23.
126
production of energy from renewable sources. Products and services that promote a healthy
lifestyle and support vulnerable groups of policyholders will be developed.
Triglav Group's business processes
A 30% reduction in location-based (Scope 1 and 2) carbon footprint per employee is planned by
2030 compared to the base year. Furthermore, the Group will increase the share of electricity
from renewable energy sources, reduce energy consumption, and increase the share of electric
and hybrid vehicles in its fleet to at least 30%.
Responsible stakeholder engagement
The Group acts responsibly towards its employees, clients, partners and the wider community.
Its objective is to maintain a high level of client satisfaction (NPS)
19
and employee satisfaction,
while fostering a culture of trust, inclusion and diversity. Clients are provided with an
outstanding user experience through innovative, accessible and simple solutions that reflect
their needs and expectations. The concept of flexible working was implemented, alongside the
expansion of programmes promoting employee health and well-being. The focus will continue
to be on multidimensional diversity, intergenerational cooperation, and employee development
and training. At the same time, the Group remains strongly engaged in corporate social
responsibility projects, partnerships and donations, and continues to promote initiatives that
contribute to the achievement of the United Nations Sustainable Development Goals (SDGs).
Effective corporate governance
The Group maintains high standards of corporate governance and adheres to its code of ethics
and other internal regulations in the conduct of its business operations. It will continue to
integrate and further develop environmental, social and governance (ESG) factors in corporate
governance policies, fully incorporating sustainability aspects into business processes and risk
management. Diversity in the composition of the Group's management and supervisory bodies
will be maintained and promoted in terms of gender, education, experience and other aspects
of diversity, while transparency, accountability and ethical behaviour are ensured at all levels of
decision-making.
Implementation of strategic guidelines and sustainable development goals of the Triglav Group
in 2025 (compared to 2024)
▪ Insurance and asset management
→The share of green bonds, social impact bonds, sustainable bonds and sustainability-
linked bonds in own investment portfolio: an increase from 12.9% to 15%.
→ Triglav Investment mutual funds: all funds are promoting environmental and social
characteristics, in accordance with Article 8 of the SFDR.
→ Income from insurance products that promote general social and environmental
benefits: an increase in written premium in the insurance business.
▪ The Group's business processes
→ Reduction of the Group's Scope 1 and 2 carbon footprint (location-based method): 1.33
tons CO2e/employee.
→ Increase the share of electricity from renewable energy sources from 66% to 75%.
→ Sustainable mobility: a higher share of electric and hybrid vehicles in the fleet from 17%
to 28%.
19
S4.MDR-T_01, 04.
127
▪ Responsible stakeholder engagement
→ Maintaining a high level of employee satisfaction (ORVI index) and customers
satisfaction (NPS).
→ Active relations with shareholders and investors and compliance with Ljubljana Stock
Exchange Prime Market terms and conditions.
▪ Effective corporate governance
→ Standards: high standards of corporate governance.
→ Policies: implementation of the Group's Sustainable Development Policy, Sustainable
Investment Policy and Statement on principal adverse impacts of investment decisions on
sustainability factors.
→ Global alliances: a signatory to the United Nations Principles for Responsible Investing
(PRI) and the United Nations Principles for Sustainable Insurance (PSI).
Overview of strategic ESG indicators
20
Triglav Group
Strategic indicator
Unit
2019
achievem
ent
2021
achievem
ent
2022
achieveme
nt
2023
achieveme
nt
2024
achieveme
nt
2025
achieveme
nt
2030
strategic
plan
Carbon footprint (Scope 1 and 2
– location-based) per employee
tCO
2
-eq
per
employee
2.18
1.90
1.64
1.51
1.34
1,33
1.44
Share of electricity consumption
from renewable energy sources
%
1%
33%
63%
62%
66%
75%
75%
Energy consumption per
employee
TOE per
employee
0.47
0.30
0.31
0.29
0.27
0.27
0.40
Share of electric and hybrid
vehicles in the fleet
%
4%
4%
8%
11%
17%
28%
30%
Share of investment exposure to
issuers on the Coal Exit List
%
n/a
n/a
n/a
0%
0%
0%
<1%
Share of ESG bonds
%
n/a
8%
10%
11%
13%
15%
15%
Share of in-house training via an
e-platform
%
n/a
91%
67%
52%
55%
59%
>30%
Share of women in the Group's
management and supervisory
boards
%
20%
18%
24%
27%
26%
29%
>20%
Average number of training
hours per employee
No
5
31
33
32
31
34
28
Digital training for employees
%
21%
81%
62%
52%
50%
54%
35%
Employee satisfaction
ORVI
index
3.88
4.00
4.00
3.94
3.97
4.03
3.80
* The data in the table have not been audited.
10.1.2.2 Sustainable development policy
21
The Sustainable Development Policy (hereinafter: the Policy) of Zavarovalnica Triglav and the
Triglav Group sets out the framework of the Group's sustainable development, which defines
the way of achieving strategic ambitions in sustainable development. The Policy defines how the
Group's ESG strategic ambitions will be achieved. It addresses the following: the identification
of sustainability risks and the perception of opportunities to achieve business objectives; the
sustainable development management system at the parent company and Group levels;
guidelines on managing sensitive economic activities in terms of sustainability risks; key
corporate governance elements; and other key aspects of sustainable development, including
responsibility to employees and corporate social responsibility projects. The Policy is available on
the Company's website: www.triglav.eu/en/sustainable-development/sustainable-business.
20
ESRS 2 SBM-1_22, E1.MDR-T_01-08, S1.MDR-T_01–08.
21
ESRS 2 S1.MDR-P_01-04,06, S4.MDR-P_01-04, 06, E1.MDR-P_01-04, 06, G1.MDR-P_01-04, 06.
128
The following table summarises key policies related to the management of identified material impacts, risks and opportunities. Further details on
these policies are provided in the individual sections. Material impacts, risks and opportunities are described in Section 10.1.6.
Policy
Key policy messages
Areas of application
Responsible body
Related standards/initiatives
Availability
Sustainable Development
Policy
▪ A framework for implementing the Group's
sustainability strategy
▪ Commitment to long-term economic, social
and environmental value creation
▪ The sustainable development management
system at the Triglav Group
▪ Guidelines on sensitive economic activities
▪ Sustainability risk management
▪ Employee well-being, diversity and inclusion
▪ Sustainability reporting and stakeholder
engagement
The Triglav Group (except for the clients'
assets managed in mutual funds and
discretionary mandate assets, which are
managed by the Group's asset
management companies)
Management Board of
Zavarovalnica Triglav
United Nations Principles for
Sustainable Insurance (UN PSI),
Partnership for Carbon
Accounting Financials (PCAF)
Corporate website
Sustainable Investment
Policy
The Triglav Group (except for the clients'
assets managed in mutual funds and
discretionary mandate assets, which are
managed by the Group's asset
management companies)
Management Board of
Zavarovalnica Triglav
SFDR, United Nations Principles
for Responsible Investment (UN
PRI)
Corporate website
Succession Policy for
Management Members of
Triglav Group Companies
▪ Acquisition and retention of high-quality
staff
▪ Succession planning
▪ Ensuring a positive working environment
▪ Commitment to employee engagement,
satisfaction and health
▪ Promotion of knowledge transfer at Group
level
▪ Creation of a uniform organisational
culture
Triglav Group
Business function
Internal – the internal
documents module on the
intranet
Policy on the Management
of Key High-Potential and
Young High-Potential
Employees
Triglav Group
Business function
Internal – the internal
documents module on the
intranet
Employee Development and
Care Policy
Zavarovalnica Triglav
Business function
Internal – the internal
documents module on the
intranet
Rules on the Protection of
Workers' Dignity
Zavarovalnica Triglav
Business function
Internal – the internal
documents module on the
intranet
Rules on Specialised In-
House Training in the Triglav
Group
Triglav Group
Business function
Internal – the internal
documents module on the
intranet
Triglav Group Code
▪ The Triglav Group's ethical principles guide
actions to uphold its reputation, build trust
in the brand, and ensure successful,
profitable and sustainable operations in line
with its objectives, mission, vision and
strategy.
▪ They establish uniform corporate business
and ethical standards, complementing the
Triglav Group
Management Board of
Zavarovalnica Triglav
UN Universal Declaration of
Human Rights, ILO Declaration
on Fundamental Principles and
Rights at Work, Commitment to
Respect Human Rights in
Business, National Action Plan
of the Republic of Slovenia on
Business and Human Rights,
Slovenian Corporate
Corporate website
129
standards of conduct followed by all
employees.
▪ Everyone acting on behalf and for the
account of the Group companies is
committed to adhering to these principles.
It serves as a guide for workplace issues and
a compass for making responsible decisions.
▪ They provide direction for drafting internal
regulations within Group companies,
ensuring compliance with the provisions of
the Code.
▪ Consideration, identification, reporting and
investigation of unfair practices
▪ Measures to protect whistleblowers from
retaliation and to provide immediate
assistance
▪ Protection of the whistleblower's identity
▪ It defines the key elements of the corruption
risk management system designed to
effectively prevent and detect corrupt
practices and establishes the procedure for
reporting and handling cases that may pose
a corruption risk and requires employees to
take an active role.
▪ It sets out written rules, procedures and
standards for organising the Compliance
Office.
▪ Reporting and supervision lines
▪ Organisation of the compliance function,
Compliance and Sustainable Development
Committee
▪ Education, information and training
▪ Consistency in taking action for non-
compliant behaviour
▪ Determining the effectiveness of the
compliance system
▪ Risk management for compliance
Governance Code, Slovenian
Corporate Integrity Guidelines,
Insurance Code
Rules on the Handling of
Internal Fraud and
Violations of the Triglav
Group Code
Zavarovalnica Triglav
Business function
Commitment to Respect Human
Rights in Business, Directive (EU)
2019/1937
Internal – the internal
documents module on the
intranet
Corruption Risk
Management Policy
Triglav Group
Management Board of
Zavarovalnica Triglav
United Nations Global Compact
Slovenia Declaration on Fair
Business
Internal – the internal
documents module on the
intranet
Slovenian Corporate Integrity
Guidelines
Compliance Policy
ZZavar-1, Commission
Delegated Regulation (EU)
2015/35 supplementing
Directive 2009/138/EC
(Solvency II), EIOPA Guidelines
on System of Governance
Internal – the internal
documents module on the
intranet
Diversity Policy for the
Members of Management
and Supervisory Bodies of
Zavarovalnica Triglav
▪ Positioning of the communication function,
responsibilities for communication
▪ Communicating in a crisis
Triglav Group
Management Board
Internal – the internal
documents module on the
intranet
Triglav Group
Business function
130
Triglav Group
Communication Code
Internal – the internal
documents module on the
intranet
Policy on Insurance Product
Governance, Oversight and
Distribution at
Zavarovalnica Triglav
▪ Consumer protection
▪ Identification and tracking of the needs of
the target market
Zavarovalnica Triglav
Management Board,
person responsible for
distribution
Directive (EU) 2016/97,
Commission Delegated
Regulation (EU) 2017/2358
supplementing Directive (EU)
2016/97, Commission
Delegated Regulation (EU)
2017/2359 supplementing
Directive (EU) 2016/97,
Commission Delegated
Regulation (EU) 2021/1257
amending Delegated
Regulations (EU) 2017/2358 and
(EU) 2017/2359, EIOPA
Guidelines, supervisory bodies'
views and good business
practices of Zavarovalnica
Triglav d.d.
Internal – the internal
documents module on the
intranet
Overarching Information
Security Policy of
Zavarovalnica Triglav
▪ Establishment, operation, monitoring,
maintenance and improvement of the
information security management system
Zavarovalnica Triglav
Business function
EIOPA, DORA, ISO 27001
Internal – the internal
documents module on the
intranet
Privacy Policy
▪ Personal data protection
Zavarovalnica Triglav
Business function
GDPR
Corporate website
Cookie Policy
▪ Rules for the lawful processing of data in
specific business segments
Zavarovalnica Triglav
Business function
GDPR
Corporate website
Personal Data Protection
Rules
Business function
GDPR
Internal – the internal
documents module on the
intranet
Remuneration Policy of
Zavarovalnica Triglav d.d.
▪ Business integrity and transparency
Zavarovalnica Triglav, Triglav Group
subsidiaries
Business function
ZGD-1, Solvency II Directive,
Commission Delegated
Regulation (EU) 2015/35
supplementing Directive
2009/138/EC, EU Regulation
2019/2088 and local legislation
Internal – the internal
documents module on the
intranet
Remuneration policy for the
members of the supervisory
and management bodies of
Group subsidiaries
▪ Maintenance of the appropriate capital
strength of the Company
Zavarovalnica Triglav's
Procurement Policy
▪ Definition of the core development
guidelines in procurement, fostering long-
term partnerships and emphasising
sustainability
Zavarovalnica Triglav's partners and
suppliers
Business function
Code, Outsourcing Policy,
Internal – the internal
documents module on the
intranet
Information security
131
Agreement Management
Policy
▪ Definition of the selection process with
built-in internal controls
▪ Supplier suitability assessment, with a focus
on compliance and sustainability
▪ Definition of roles in the procurement
process and agreement management
Business function
Internal – the internal
documents module on the
intranet
Rules on Procurement at
Zavarovalnica Triglav
Business function
Corporate website
General terms and
conditions for Zavarovalnica
Triglav's suppliers
Business function
Internal – the internal
documents module on the
intranet
Governance System and
Policy of Zavarovalnica
Triglav d.d.
▪ Definition of the key elements of the
Company's governance system and the
main governance rules for the Company and
the Group, aligned with the Group's
strategy.
▪ Definition of transparent internal
relationships of responsibility and powers
within the governance system.
▪ Establishment of a sustainable orientation
in environmental, social and governance
(ESG) areas, creating a long-term stable
basis for its profitable and safe operations,
promoting the transition to a sustainable
society and reducing its impact on climate
change.
▪ Outlining the organisation and operation of
a sustainable development system that
ensures the overall alignment of all
important sustainable development
activities with the Group's strategic
ambitions and compliance with
sustainability-related legislative
requirements.
Zavarovalnica Triglav
Management Board of
Zavarovalnica Triglav
ZZavar-1
Corporate website
132
10.1.3 Business model and value chain
22
In 2025, the Triglav Group updated the presentation of its business model and value chain to
align with the requirements of the ESRS and established practice in the European insurance
sector. Value is created primarily through insurance and asset management activities, supported
by key resources and partnerships. Due to the diversified nature of the Group's insurance and
financial activities, the division of the value chain into upstream, own operations and
downstream is less transparent. The value chain is therefore presented by the main value-
creating activities: (1) insurance, (2) own operations, (3) asset management and (4) other
services.
In the upper part of the value chain, key stakeholders include primarily reinsurance companies,
IT and data service providers, financial partners, suppliers of professional and support services,
and distribution partners. At the lower end of the value chain, stakeholders comprise retail and
corporate clients, beneficiaries, injured parties and users of related services who receive
insurance cover, financial solutions, assistance and claims payments.
The Group secures financial resources through a diversified business model, sound capital
management and a regional presence. Human resources capacity is strengthened through talent
and leadership development programmes, investment in digital competences and a culture that
supports collaboration, efficiency and results. Technology and data capabilities are developed
through digital initiatives, automation and IT infrastructure upgrades, while specialised
knowledge and services are complemented by a diversified network of partners and suppliers.
The Group creates value for its clients by providing financial protection and insurance cover,
reliable and timely claims settlement, and access to related services, including assistance, and
savings and investment products. Looking ahead, it anticipates the provision of more customised
solutions, further development of digital services, and additional support to strengthen
resilience and adaptation. Value is created for investors and shareholders through profitability,
dividend policy, long-term capital management and transparent reporting, with future priorities
focused on the implementation of the Strategy 2025–2030, including earnings growth, organic
growth with potential M&A, improved cost efficiency and diversification. The Group provides
employees with stable employment, a secure and supportive working environment, and
development opportunities, with further benefits derived primarily from investments in
competences (including digital), organisational culture and talent development. The broader
social environment and public institutions are supported through tax contributions, job creation,
corporate social responsibility activities, and products and services that, where relevant,
incorporate sustainability aspects.
22
ESRS 2 SBM-2_01-06, SBM-1_01-02, 04, 06, SBM-1_25-28.
133
The figure below illustrates the Triglav Group's value chain. A detailed description of the business model of the Triglav Group and Zavarovalnica
Triglav in 2025, including financial highlights and an overview of the Group's activities, markets and position, is provided in Section 2.6 Activities,
markets and position of the Triglav Group.
134
Changes to the strategy and business model for 2025–2030
23
The Strategy 2025–2030 builds on the current insurance and finance business model and the
implementation of strategic priorities informed by industry trends, stakeholder expectations
and external challenges. Key priorities include safe and profitable operations; enhancing client
value through quality of service and experience; further development of products and services;
increased organisational agility and competence development, including digital skills; improved
efficiency through process optimisation; and deeper integration of sustainability aspects to
support safe and profitable operations over the long term.
Consideration of stakeholders' interests and next steps
24
The strategic guidelines take into account the expectations of key stakeholders. For shareholders
and investors, security, stability and return on investment, and sound risk management are
important. Clients expect simple, accessible and high-quality services, as well as the further
development of processes and digital channels. For employees, the focus is on development,
engagement, a supportive working environment, and the building of agility and competences.
The Group aims to continue working with partners and suppliers through clearly defined ways
of working, while the wider society and regulators expect consistent compliance, responsible
integration of sustainability aspects, and the addressing of environmental and social challenges.
The implementation of the Strategy 2025–2030 is designed to be gradual. In the early phase, the
focus is on performance management and priority initiatives; in the middle phase, these
initiatives are expanded and embedded across business lines and markets; and in the final
phase, key lessons are integrated into operational models and decision-making, with priorities
adjusted on an ongoing basis in response to changes in the environment and risk assessments.
The measures are expected to strengthen relationships with stakeholders over the long term –
for example, through an improved client experience, enhanced employer attractiveness, and
greater trust from investors and regulators – while some changes, such as process improvements
or distribution adjustments, may also give rise to new forms of cooperation.
Resilience of strategy and business model and climate change adaptation
25
The resilience of the Group's strategy and business model to material impacts, risks and
opportunities is supported by integrated strategic planning, risk management, product and
portfolio management, and capital management processes. Flexibility stems from the
continuous development of insurance products and the possibility to adapt the portfolio, the
high liquidity of the investment portfolio for timely adjustments of the investment allocation,
and the continuous capital management that supports the quality and availability of funding
sources and the resilience to shocks.
For climate risks, the Group takes into account uncertainties in climate projections and
modelling (e.g. the dynamics of physical impacts, the timeline and content of transition policies,
market reactions and limitations in data availability); where information is available, climate
risks are integrated into strategic processes and impact assessments on risk-taking, claims,
23
SBM-2_08.
24
SBM-2_09; SBM-2_10; SBM-2_11.
25
SBM-3_10; E1.SBM-3_07.
135
investment portfolio and capital planning, and the findings guide mitigation and adaptation
measures.
The ability to adapt to climate change in the short, medium and long term depends on: (i)
financial flexibility and access to funding through disciplined capital and liquidity management;
(ii) the adaptation of products and services; (iii) the redirection of financial investments as risks
and opportunities evolve; and (iv) strengthening organisational capacity and employee
competences, including digital skills, to integrate climate-related factors into decision-making.
10.1.4 Key stakeholders
26
The screening, relevance assessment and updating of the Triglav Group's key stakeholders was
carried out by the Group in accordance with the Governance System and Policy of Zavarovalnica
Triglav d.d., which identifies the key stakeholder groups relevant to management and strategic
guidelines. The determination was based on the Stakeholder Engagement Standard, the
practices of leading insurance and financial groups in the region, and the Group's specific
characteristics. Within this year's double materiality assessment cycle, the definition of
stakeholders was reviewed and validated, with no significant changes identified. The Group
recognises seven primary stakeholder groups: clients; employees; shareholders and investors;
state and supervisory authorities; partners and suppliers; local communities, interest groups
and nature; and the media.
The Group's stakeholders are proactively included in the Group's operations, thereby
strengthening mutual trust and understanding. Their needs and interests, as well as the impacts
of the Group's operations on them, are identified through relationships at strategic and
operational levels. In doing so, the Company measures reputation, satisfaction and the Net
Promoter Score (NPS), monitors regulatory changes and implements the supervisory bodies'
requirements and recommendations, analyses complaints and compliments, maintains daily
contact with investors and clients, and regularly communicates with the media. Employee
satisfaction is measured by the ORVI index. Interests, opinions and suggestions are regularly
monitored by analysing the needs and interests of stakeholders. Based on this analysis, the
scope of disclosures is outlined in the annual report.
27
The Group seeks to incorporate the insights gained and the resulting guidance into its business
and operations to the greatest extent possible. The table below presents the key stakeholder
interests identified and the corresponding forms of engagement.
28
26
ESRS 2 SBM-2_01–04.
27
ESRS 2 SBM-2_05, SBM-2_06.
28
ESRS 2 SBM-2_07, S4.SBM-3_01.
136
Highlighted topics and engagement results of key stakeholders
Stakeholders
Key interests
Engagement method
Clients
▪ Policyholders
▪ Savers or investors in funds
▪ Users of assistance services
▪ Users of other services
▪ Understanding client needs
▪ Rapid claim settlement
▪ Innovative financial and insurance products and services
▪ Clear terms and conditions
▪ Personal data privacy and security
▪ Quality insurance and financial products and services
▪ A broad range of quality assistance services
▪ Financial literacy
▪ Digital ways of doing business and an easy-to-use online presentation of
products/services
▪ Raising awareness of users about risky behaviour and promoting prevention
▪ Personal contact with insurance experts, asset managers
▪ Recording complaints and compliments and responding thereto
▪ Email
▪ Telephone conversations
▪ Opinion polls and surveys
▪ Websites, blogs and e-newsletters
▪ Social networks
▪ Mobile apps
▪ Marketing communication
Employees
▪ Internal culture of cooperation
▪ Rewarding performance
▪ Personal and professional development
▪ Career advancement system
▪ Information about important milestones and changes in the Company
▪ Business strategy
▪ Work-life balance
▪ Equal treatment and opportunities for all
▪ Participation in management
▪ Career development and training system
▪ Measurement of organisational vitality
▪ Opinion polls and surveys
▪ Triglav.smo programme
▪ In-house print and online media
▪ In-house events, professional training, sports and recreational
events
▪ Personal contact
▪ Email
Shareholders and investors
▪ Institutional shareholders
▪ Retail shareholders
▪ Financial analysts
▪ Brokerage firms
▪ Investment firms
▪ Business strategy and its implementation
▪ Operations
▪ The Group's position and plans
▪ The implementation of the dividend policy and ZVTG share profitability
▪ Capital adequacy and risk management
▪ Implementation of growth and development activities
▪ Performance by particular market, situation in the markets and outlook
▪ Corporate governance and sustainable operations
▪ Cost-effectiveness
▪ General Meetings of Shareholders
▪ Quality and transparent information (SEOnet)
▪ Active contact and relations with institutional investors (investor
conferences, meetings, conference calls)
▪ Organised presentations for retail shareholders (individual
investors) and provision of information
▪ Additional information for investors
▪ Corporate website and LinkedIn
▪ Minority shareholders' associations
State and supervisory bodies
▪ Government
▪ Ministries and government agencies
▪ Securities Market Agency
▪ Insurance Supervision Agency
▪ Ensuring capital adequacy
▪ Safety of policyholders and/or users of insurance services
▪ Efficient risk management system
▪ Compliance of operations and insurance and financial services and products
▪ Complying with all obligations of a public company
▪ Responsible and sustainable operations
▪ Regulatory reporting (to the Insurance Supervision Agency, the
Securities Market Agency)
▪ Regular reviews by inspection and supervisory bodies
▪ Audits by certified auditors
137
Stakeholders
Key interests
Engagement method
Partners and suppliers
▪ Insurance agents (external sales network)
▪ Suppliers
▪ Ecosystem partners and assistance service providers
▪ Long-term cooperation
▪ Reliable and timely payments
▪ Upgrading the existing cooperation
▪ Delivery times, prices of services and goods
▪ Delivery of environmentally friendly material
▪ Paperless operations
▪ Public tenders and competitions
▪ Working meetings
▪ Email and electronic operations
▪ Telephone conversations
▪ Assessment of suppliers according to ESG criteria
Local communities, interest groups and nature
▪ Local communities
▪ Municipalities, local self-government
▪ Industry associations
▪ Expert community
▪ Interest associations
▪ Non-governmental organisations
▪ Other initiatives, societies and associations in which
the Triglav Group participates
▪ Traffic and fire safety
▪ Health protection and care
▪ Co-development of projects in the areas of culture, sport, prevention, health,
art and charity
▪ Infrastructure investments
▪ Access to services for people with various disabilities
▪ Insurance and financial literacy
▪ Fair business practices
▪ Disaster relief
▪ Partnerships with non-profit organisations and educational
institutions and execution of joint projects
▪ Joint projects with local communities, particularly in traffic safety
▪ Funds allocation system for sponsorships and donations
▪ Cooperation with local decision-makers
▪ Email
▪ Telephone conversations
Media
▪ Transparent information about the operations, events and changes in the
Triglav Group
▪ Information about insurance and financial products and services
▪ Cooperation with local and wider communities
▪ Professional insurance and financial topics
▪ Press releases and statements
▪ Meetings with media representatives
▪ Answers and explanations
▪ Email
▪ Telephone conversations
▪ Websites
138
10.1.5 The double materiality assessment process (DMA)
The Triglav Group's DMA 2025 was implemented as a structured, cross-cutting project led by the
Sustainable Development Department (ESG) within the Management Board Office, specifically
in the Corporate and Legal Affairs Division. The Risk Management Department provided targeted
support for the risk assessment components, and the Group collaborated with an external
consultant on the methodological design and tools. During the preparatory phase, the Group
conducted a benchmarking exercise with selected European insurers, which confirmed that
climate change, along with workforce, consumers and business conduct, are among the key
areas of materiality. Portfolio analysis and the classification of exposures in accordance with the
NACE classification confirmed substantial overlap between investment and insurance activities,
allowing for the transfer of insights between the two portfolios. On this basis, the Triglav Group's
2025 value chain was updated.
29
10.1.5.1 Methodology
30
Impact materiality
The impact materiality assessment phase initially involved a combination of structured internal
document review, external benchmarking and expert input to generate a long list of potential
ESG impacts on the Group's operations and value chain. This step represents a due diligence
review to identify potential and actual impacts on people and the environment, taking into
account both internal processes and records as well as relevant external sources and
benchmarking practices. Each impact was classified according to its nature (positive or negative),
relevance (actual or potential), time horizon (short-term: 1–5 years; medium-term: 6–10 years;
long-term: 10 years or more), and its placement within the updated Group value chain. When
positioning within the value chain, the Group distinguishes between impacts related to its own
operations (e.g. employees, use of resources, business practices) and impacts to which it is linked
through its business relationships (e.g. suppliers, distribution partners, claims management and
remediation, reinsurance, and the investment portfolio).
Impacts were assessed based on four factors: scope, scale, irremediable character (for negative
impacts) and likelihood, each scored on a scale of 0 to 5, with actual impacts assigned a likelihood
of 1. Assessment thresholds were initially set using expert judgement, then reviewed and
validated by the internal project team, with additional feedback provided by the wider team
during a workshop. Following a preliminary review, two workshops were conducted according
to a common methodology: one with the core project team and one with representatives of the
subsidiaries. The results were consolidated into an impact register, subject to control review and
incorporated into an internal materiality calculation tool. Topic-level materiality is determined
using a pre-defined algorithm that combines individual factor scores into an overall impact
assessment. An impact is considered material if it achieves a score of ≥ 3.0, reflecting sufficient
severity and likelihood of impacts on people or the environment. Impacts with the highest scores
are prioritised in the subsequent steps of the DMA (consolidation at the topic level, identification
of priority topics, and definition of actions/measures), with prioritisation carried out based on
severity and likelihood, as well as stakeholder input.
Stakeholder engagement
29
ESRS 2 IRO-1_02–06, 2 IRO-1_11, IRO-1_14, SBM-2_12.
30
ESRS 2 IRO-1_01, IRO-1_07–10, GOV-2_03.
139
Stakeholder engagement within the DMA aims to comprehensively identify and assess impacts,
risks and opportunities (IROs) from both the Group's internal perspective and the perspective of
stakeholders affected by the Group, in line with the ESRS focus on impact materiality. Due to
implementation constraints, the Group applied an approach based on internal representatives
of stakeholder groups (ESRS 1, AR 8) and collected targeted feedback through a structured
questionnaire across the value chain. The questionnaire and expert assessments were also
directed at activities, business relationships, and geographic exposures associated with a higher
risk of adverse impacts. IROs were assessed in detail by internal experts, while stakeholder
surveys focused on broader topics, ensuring accessibility and effective collaboration, balancing
analytical depth with feasibility, and enhancing the credibility and practical relevance of the
DMA results.
Financial materiality
The methodology for calculating the financial materiality of sustainability topics was developed
in line with ESRS 1 guidelines and aligned with the Group's risk assessment methodology,
following the recommendations of the European Insurance and Occupational Pensions
Authority (EIOPA). The topics were rated on a three-level scale (from 0 to 3) based on likelihood
of occurrence, potential financial impact and the time horizon of financial impacts, with financial
impact thresholds defined either quantitatively or qualitatively to reflect differences in the
classification of sustainability risks and opportunities. The Group assessed the financial
materiality of risks and opportunities in terms of their potential effects on performance,
resilience and strategy, applying a combination of qualitative and quantitative approaches
where data and methodologies allowed, supplemented by targeted in-depth analyses and
expert review to calibrate results in technically complex areas.
During the workshop and a subsequent online survey, the Group's senior representatives
assessed the likelihood and scope of financial impacts using scales consistent with the
materiality assessment methodology. This resulted in the identification of financially material
topics across the areas of climate, society and governance, including the prioritisation of climate
change-adapted products and insurance; a focus in investment management on financial assets
with sustainable characteristics; improvements in cost efficiency through energy-related
measures; enhanced employee care; increased client satisfaction and clarity on pricing and
eligibility, supported by accessible sales and communication channels; and the strengthening of
corporate culture, participation in policy-making and responsible relationships with suppliers.
The quantitative assessment of transition risk was based on the NACE classification of
investments and an analysis of exposure to climate-sensitive sectors, taking into account
different scenarios, including accelerated and slow transition and emission-related risks. The
physical risk analysis covered seven hazards (flash floods, river floods, coastal floods, storms, hail,
drought and landslides) and compared projected changes in key climate variables with historical
loss events to derive composite materiality assessments by time horizon. Two physical risks,
floods and hail, were identified as financially material. A risk or opportunity is considered
financially material if it attains a score of ≥ 2.0 (rating on a scale from 1 to 3), reflecting a
sufficient scale and likelihood of financial impacts on the Group.
10.1.6 Identified impacts, risks and opportunities
The results of the DMA were consolidated by combining impact materiality assessments,
financial materiality assessments and stakeholder contributions. Impact materiality was
calculated as a weighted average, with impacts identified as material at a score of ≥ 3.0 and risks
and opportunities at a score of ≥ 2.0. A topic was considered material if at least one IRO met the
relevant threshold. The DMA 2025 results were reviewed and validated by the internal project
140
team, they were also approved by the Management Board, and the Audit Committee of the
Supervisory Board was informed of the findings. As the DMA is a dynamic process, the Group
regularly monitors and updates impacts, risks and opportunities (at least annually and, where
necessary, in response to significant events, regulatory changes or new findings from
operations). It monitors progress in managing priority topics through governance processes,
indicators and reporting, and updates the priorities accordingly.
Based on a combination of impact and financial materiality, the Triglav Group identified material
topics under ESRS E1 (Climate change), S1 (Own workforce), S4 (Consumers and end-users) and
G1 (Business conduct) and the Group-specific disclosure (Responsible investment) as part of the
DMA process for 2025. The Group's most material sustainability topics, identified through both
aspects of the DMA – impact on people and the environment, as well as financial impact – are
presented in the top right quadrant of the graphic.
The Triglav Group sustainability topics, presented based on a double materiality assessment
141
The Triglav Group's most material sustainability impacts, risks and opportunities (IROs) and their positioning in the value chain
31
Topics/sub-topics
IRO name
IRO type
Part of the value chain
Time horizon
E1
Climate change
Climate change mitigation
Carbon footprint reduction: energy efficiency and RES
Impact (+)
Own operations
Short-term, medium-
term, long-term
Insurance for companies in the fossil fuels sector
Impact (–)
Insurance
Short-term, medium-
term, long-term
RES and electric vehicle (EV) insurance
Impact (+)
Insurance
Short-term, medium-
term
Exposure to activities with high GHG emissions
Impact (–)
Asset management
Medium-term
Investments in sectors exposed to transition risks
Risk
Asset management
Medium-term, long-
term
Financing of the transition to renewable energy
sources and low-carbon technologies
Impact (+)
Asset management
Medium-term
Investment of assets of clients and insurance
portfolios in green and sustainable investments
Opportunity
Asset management
Medium-term, long-
term
Climate change adaptation
Insurance exposure to river and urban floods
Risk
Insurance
Short-term, medium-
term, long-term
Insurance exposure to hail-related claims
Risk
Insurance
Short-term, medium-
term, long-term
Climate resilient insurance products
Opportunity
Insurance
Short-term, medium-
term, long-term
Underwriting risks from clients not aligned with
climate change mitigation objectives
Risk
Insurance
Long-term
Energy
Insurance of RES assets
Opportunity
Insurance
Short-term, medium-
term, long-term
Reduction of costs by investing in energy efficient
solutions
Opportunity
Own operations
Short-term, medium-
term
Entity-specific
Responsible investment in
the Triglav Group
Investment in ESG bonds and promotion of mitigation
of adverse environmental and social impacts (in
accordance with Article 8 of the SFDR)
Impact (+)
Asset management
Medium-term
31
S1.SBM-3_05.
142
S1
Own workforce
Working conditions
Work-life
balance
Working from home promotes work-life balance
Impact (+)
Own operations
Short-term
Health and
safety at work
Comprehensive care for employees' health and safety
Impact (+)
Own operations
Short-term
Secure
employment
Strengthening of the employer brand by ensuring job
stability
Opportunity
Own operations
Short-term, medium-
term, long-term
Working time
Improved employee retention by introducing flexible
and hybrid forms of work
Opportunity
Own operations
Short-term, medium-
term, long-term
Adequate wage
Improved employee retention and performance
through fair and transparent pay systems
Opportunity
Own operations
Short-term, medium-
term, long-term
Work-life
balance
Increased productivity and mental well-being
Opportunity
Own operations
Short-term, medium-
term, long-term
Equal treatment and
opportunities for all
Gender equality
and equal work
for equal pay
Ensuring pay equity and fairness
Impact (+)
Own operations
Short-term, medium-
term, long-term
Training and
skills
development
Development of employee competences
Impact (+)
Own operations
Short-term, medium-
term, long-term
Measures
against violence
and harassment
in the workplace
Respect for diversity, inclusion and non-discrimination
Impact (+)
Own operations
Short-term
Training and
skills
development
Better performance and innovation through
continuous learning
Opportunity
Own operations
Short-term, medium-
term, long-term
S4
Consumers and
end-users
Information impacts for
consumers and/or end-
users
Privacy
Client protection and security
Impact (+)
Insurance
Asset management
Short-term
Access to
(quality)
information
Increased loyalty through transparent and inclusive
communication
Opportunity
Insurance
Short-term, medium-
term, long-term
143
Personal safety of
consumers and/or end-
users
Health and
safety
Better results for clients with proactive security
solutions
Opportunity
Insurance
Short-term, medium-
term, long-term
Social inclusion of
consumers and/or end-
users
Access to
products and
services
Efficient and timely claims settlement
Impact (+)
Insurance
Short-term, medium-
term, long-term
Non-
discrimination
Clear product eligibility conditions and pricing logic
Opportunity
Insurance
Short-term, medium-
term, long-term
Access to
products and
services
Alternative access through agents and branch offices
Opportunity
Insurance
Short-term, medium-
term, long-term
Responsible
marketing
practices
Increased client engagement through simple and
transparent communication
Opportunity
Insurance
Short-term, medium-
term, long-term
G1
Business
conduct
Corporate culture
Conduct in accordance with the code of ethics
Impact (+)
Own operations
Insurance
Asset management
Other services
Short-term, medium-
term, long-term
Cost efficiency and business stability through a strong
ethical culture
Opportunity
Own operations
Other services
Short-term, medium-
term, long-term
Management of relationships with suppliers
including payment practices
Promotion of responsible supplier conduct
Impact (+)
Own operations
Short-term, medium-
term, long-term
Corruption and bribery
Prevention and
detection
including
training
Prevention of corruption and bribery
Impact (+)
Own operations
Short-term, medium-
term, long-term
Compliance with legal and regulatory
requirements
A stable regulatory environment with transparent
involvement in public policy-making
Opportunity
Own operations
Other services
Short-term, medium-
term, long-term
Management of relationships with suppliers
including payment practices
Strong supplier relationships that strengthen cost
stability and continuity of service
Opportunity
Own operations
Other services
Short-term, medium-
term, long-term
144
10.2 Environmental aspects
The Triglav Group is committed to addressing environmental challenges responsibly and
disclosing its commitments transparently. A key focus is on managing climate-related risks and
opportunities and supporting the climate transition through its insurance and investment
activities. At the same time, the Group is systematically reducing the carbon footprint of its own
operations (Scope 1 and Scope 2). As part of the double materiality assessment, the Group
identified a combination of climate-related risks, opportunities, and both positive and negative
impacts arising from insurance and asset management for environmental topics (E1).
With regard to climate change adaptation, increased exposures of the insurance portfolio to
river and urban floods, hail damage and climate-relevant sectors are highlighted as key risks.
Additionally, an opportunity was identified in the development of climate-resilient insurance
products.
In relation to climate change mitigation, material positive impacts are associated with reducing
the Group's operational carbon footprint (through energy efficiency measures and the use of
renewable energy sources), the insurance of renewable energy projects and electric vehicles, and
the financing of the transition to low-carbon technologies. Exposures to insurance and
investments in fossil fuels and in activities with high greenhouse gas emissions, including
transition risks within investment portfolios, are identified as negative impacts and risks.
Additionally, opportunities were identified in relation to cost optimisation through investments
in energy efficiency solutions.
10.2.1 E1 Climate change adaptation and mitigation
32
In line with its Sustainable Development Policy and strategic ambitions, the Group promotes the
transition to a sustainable society and reduces its impact on climate change. Environmental
impacts in business processes are minimised by reducing the Scope 1 and 2 carbon footprint. Key
quantitative performance indicators by 2030:
▪ reduce the location-based carbon footprint (Scope 1 and 2) per employee by 30% compared
to the 2019 base year;
▪ increase the share of electricity from renewable energy source to 85%;
▪ increase the share of electric and hybrid vehicles in the fleet to at least 30%.
The targets for reducing the Scope 1 and Scope 2 carbon footprint are set and monitored using
the same organisational and operational boundaries as the GHG emissions inventory disclosed
under E1-6, i.e. for the fully consolidated Group entities with significant office activities (office
premises or more than one employee), and for the same Scope 1 and Scope 2 emission sources.
In the event of significant scope changes (e.g. acquisitions/divestments) or methodological
updates that would affect the comparability of time series, the Group ensures comparability
through appropriate recalculations and disclosure of the changes.
The Group has not yet defined a detailed methodology or scenario for the described objectives,
nor has it assessed their alignment with the relevant national, international and EU policies.
Furthermore, the Group's environmental targets are not yet fully based on scientifically sound
evidence. The Group applies a methodology aligned with the GHG Protocol requirements for
calculating the Scope 1 and 2 carbon footprint, and with the PCAF Standard (Part A) requirements
for calculating financed emissions (Scope 3.15).
32
E1.MDR-P_01–06, E1-2_01, E1.MDR-A_01-12, E1-4_01, E1-4_18, E1-4_22, E1.MDR-M_01.
145
Relevant stakeholders are involved in the target-setting process, as outlined in more detail in the
double materiality assessment process and in the stakeholder engagement table. The Group
regularly monitors and reports on progress towards its climate change mitigation goals,
maintaining a commitment to transparency and accountability in its sustainability efforts. In
2025, the methodology for measuring the Scope 1 and 2 carbon footprint remained unchanged;
however, the categorisation of hybrid vehicles in the vehicle fleet and the related data capture
were revised. For hybrid vehicles, consumption and emissions are now recorded based on actual
fuel consumption (litres of petrol or diesel) rather than kilometres driven, as was the case in
2024. This change was implemented to improve data classification and alignment with available
(fuel) records and resulted in no or only negligible material differences in total Scope 1 emissions.
By contrast, the methodology for calculating financed emissions was updated to include
additional asset classes and to extend the scope of the calculation to investments at Group level.
For the remaining indicators in 2025, there were no changes to the targets or methodologies.
33
The Group has not yet adopted a transition plan with comprehensive decarbonisation targets
covering key elements of the value chain. The climate targets set out within the strategic
ambitions related to sustainable development by 2030, together with progress towards their
achievement, are presented in Section 10.1.3 Business model and value chain. In the coming
years, the Group plans to build on the adopted targets in order to develop a comprehensive
transition plan.
34
In November 2024, the Group adopted sustainable development goals for reducing its Scope 1
and 2 carbon footprint as part of the approval of its strategy to 2030. In addition, the Group is
committed to increasing the share of environmentally sustainable activities aligned with the EU
Taxonomy Regulation within its asset management and insurance activities.
Reducing the carbon footprint of own business processes remains one of the Group's strategic
objectives. As part of this strategic commitment, the Group aims to reduce energy consumption
and Scope 1 and 2 carbon footprint per employee by 30% by 2030 compared to the 2019 base
year. These objectives are pursued through the following sets of activities:
35
▪ improving the energy efficiency of own properties, increasing the sustainable use of energy
and self-supply from renewable energy sources, including the energy renovation of buildings
and heating/cooling systems, the installation of energy-saving appliances, and the
upgrading and expansion of solar power plants; for major renovations, the Group is
examining the feasibility of using alternative renewable energy sources (e.g. geothermal
energy) and of substituting existing energy products with energy products with lower
environmental impact alternatives;
as well as setting up an energy efficiency monitoring and
management system;
▪ optimising the size of own-use premises and adapting office and client spaces to new trends
and ways of working;
▪ promoting green mobility, in particular by increasing the share of electric and hybrid vehicles
in the fleet and expanding the number of electric vehicle charging stations at Group sites;
▪ raising awareness among employees about rational energy use and promoting
micromobility.
The implementation of these measures is integrated into the Group's regular management and
operational processes, covering activities related to the Group's own properties, employee
mobility and behaviour, and work organisation. The measures are implemented in a phased
33
E1.MDR-T_01–13, E1-4_17.
34
E1-1_16.
35
E1-1_03, E1-1_13–14, E1-3_01–02, E1-4_23.
146
manner and are adapted to available data, technical capabilities, and the specific needs of
individual sites and companies within the Group.
36
Scope 1 and 2 emission reduction measures involve investments and costs, which are typically
undertaken as part of the regular management of real property, equipment and mobility. The
Group does not record these investments as separate, earmarked items under individual climate
actions; instead, they are generally reflected within regular items. The link to the indicators
under Commission Delegated Regulation (EU) 2021/2178 is provided in the EU Taxonomy
section. The Group has not yet adopted a comprehensive transition plan for key elements of the
value chain and, accordingly, does not disclose separate capital investments related to such a
plan in the reporting period.
37
10.2.1.1 The Triglav Group's Scope 1 and Scope 2 carbon footprint
38
The implementation of plans to reduce the Scope 1 and 2 carbon footprint led to a reduction of
approximately 2% in the Group's carbon footprint in 2025 under the location-based method
compared to 2024 (index 98), and a reduction of 9% under the market-based method (index 91).
Compared to the 2019 base year, the Scope 1 and 2 carbon footprint was 37% lower under the
location-based method (index 63) and 50% lower under the market-based method (index 50).
The Group has therefore already achieved performance below the 2030 target for Scope 1 and 2
emissions under the location-based method (6,879 tCO₂e in 2025 versus a target of 7,601 tCO₂e),
although additional measures, particularly regarding company cars, will be needed to achieve
the full Scope 1 target.
Scope 1 emissions were 3% lower in 2025 compared to 2024 (2,510 tCO₂e; index 97) and 10%
lower compared to 2019 (index 90). Within Scope 1, emissions from own-capacity energy
consumption (Scope 1.1) decreased by 6% (index 94), while emissions from company car fuel
(Scope 1.2) decreased by 2% (index 98) and remain 10% lower than in 2019 (index 90).
Scope 2 emissions decreased by 2% (index 98) in 2025 under the location-based method and by
14% (index 86) under the market-based method. Relative to 2019, this represents a decrease of
46% under the location-based method (index 54) and 65% under the market-based method
(index 35), reflecting further improvements in the electricity supply structure and the use of
contractual instruments.
The intensity indicators show a stable trend: the Group's Scope 1 and 2 carbon footprint per
employee under the location-based method remained virtually unchanged, standing at 1.33
tCO₂e (index 99), and was 33% lower than in 2019 (index 67). The Company's total Scope 1 and
2 carbon footprint under the location-based method was slightly higher in 2025 than in 2024
(index 102), mainly due to an increase in Scope 1.1 emissions (index 105), while emissions from
company vehicles remained stable (index 99) and were lower compared to 2019 (index 80).
According to the market-based method, the Company's Scope 1 and Scope 2 carbon footprint
decreased further in 2025 (index 97), confirming the effectiveness of electricity-related
measures.
36
E1-3_07.
37
E1-3_08, E1-3_05.
38
E1-6_15, E1-6_29.
147
The Triglav Group's carbon footprint by Scope 1 and 2
39
GHG emissions in
tCO
2
e
Index
Quantity by activity
2025
2024
2030
target
Base year
2019
2025/
2024
2025/
2030
2025/
2019
Triglav Group
Scope 1.1 – Consumption of energy products from
own capacities *
729
772
567
810
94
129
90
Scope 1.2 – Fuel consumption of company cars
1,780
1,816
1,386
1,981
98
128
90
Scope 1 – Direct GHG emissions
2,510
2,588
1,953
2,790
97
129
90
Scope 2 – Indirect GHG emissions (location-based)
4,369
4,462
5,648
8,068
98
77
54
Scope 2 – Indirect GHG emissions (market-based)
2,560
2,988
5,141
7,345
86
50
35
Total Scope 1–2 GHG emissions (location-based)
6,879
7,049
7,601
10,859
98
91
63
Total Scope 1–2 GHG emissions (market-based)
5,070
5,575
7,094
10,135
91
71
50
Carbon footprint (Scope 1–2) per employee
(location-based)
1.33
1.34
1.44
2.00
99
79
67
Carbon footprint (Scope 1–2) per employee
(market-based)
0.98
1.06
-
-
92
-
-
Carbon footprint (Scope 1–2) per EUR 1 million net
revenue (location-based)
4.06
5.06
-
-
80
-
-
Carbon footprint (Scope 1–2) per EUR 1 million net
revenue (market-based)
2.99
4.00
-
-
75
-
-
Total revenue used for the intensity calculation
1,694,722,955
1,393,209,369
-
-
122
-
-
* Data on heating oil consumption for Zavarovalnica Triglav for 2023 and 2024 were subsequently revised to include previously
unrecorded consumption based on additional notifications from building managers.
The Zavarovalnica Triglav's carbon footprint by Scope 1 and2
40
GHG emissions
in tCO
2
e
Index
Quantity by activity
2025
2024
Base year
2019
2025/2024
2025/2019
Zavarovalnica Triglav
Scope 1.1 – Consumption of energy products from
own capacities
418
396
393
105
106
Scope 1.2 – Fuel consumption of company cars
438
444
546
99
80
Scope 1 – Direct GHG emissions
855
841
938
102
91
Scope 2 – Indirect GHG emissions (location-based)
2,042
2,013
3,719
101
55
Scope 2 – Indirect GHG emissions (market-based)
851
925
3,676
92
23
Total Scope 1–2 GHG emissions (location-based)
2,898
2,854
4,657
102
62
Total Scope 1–2 GHG emissions (market-based)
1,707
1,765
4,615
97
37
Carbon footprint (Scope 1–2) per employee
(location-based)
1.33
1.26
1.95
106
70
Carbon footprint (Scope 1–2) per employee
(market-based)
0.78
0.78
-
101
-
* Data on heating oil consumption for Zavarovalnica Triglav for 2023 and 2024 were subsequently revised to include previously
unrecorded consumption based on additional notifications from building managers.
** The data for Zavarovalnica Triglav, d.d. have not been audited.
Methodology and assumptions for calculating the carbon footprint
41
The Triglav Group's carbon footprint calculation is based on the requirements of the
international GHG Protocol. The challenges in calculating Scope 3.1 to 3.14 emissions mainly
relate to the systematic collection of data and the lack of high-quality and comparable data
across the value chain. The Group applied a 5% materiality threshold in the calculation of Scope
3 emissions, in line with GHG Protocol guidelines, meaning that only categories contributing
more than 5% to the total carbon footprint were included in the reporting. Based on an internal
39
E1-4_02-16, E1-6_01-02, E1-6_04, E1-6_07, E1-6_09, E1-6_10, E1-6_11, E1-6_12, E1-6_13, E1-6_30, E1-6_31_34.
40
E1-6_01, E1-6_02, E1-6_04, E1-6_07, E1-6_09, E1-6_10, E1-6_11, E1-6_12, E1-6_13, E1-6_30, E1-6_31_34.
41
BP-2_03-09, E1.MDR-M_02, E1-6_18, E1-6_19, E1-6_21, E1-6_25, E1-6_26, E1-6_27.
148
materiality analysis, only category 3.15 – Financed emissions was included in Scope 3 for public
reporting. See Section Financed emissions for more information.
For setting targets to reduce the carbon footprint, 2019 was set as the base year (GHG).
42
The
base year 2019 was selected because it represents a representative year in terms of the scale of
operations and the related Scope 1 and Scope 2 emissions and was not affected by the
extraordinary impacts of the COVID-19 pandemic (e.g. changes in mobility, the extent of remote
work, the use of business premises, etc.), which could have significantly influenced energy
consumption and, consequently, emissions. This ensures that the baseline provides an
appropriate basis for tracking progress towards the targets, without significant one-off external
deviations. The base year for financed emissions is not disclosed, as the Group has not yet
formally defined targets for this area against which progress could be monitored.
The carbon footprint calculation according to the location-based method includes all Group
companies that are fully consolidated and have office space or more than one employee and
therefore meet the materiality criterion. Scope 1 and Scope 2 emissions are based on primary
data, while the calculations for Scope 3.15 – financed emissions are based on data from paid
databases and emission factors. The Group uses certificates or guarantees of origin for the
purchase of green electricity.
Emission factors are taken from internationally recognised and publicly available sources. The
primary reference source is the UK GHG factors (GOV.UK), as these provide methodologically
consistent and broadly applicable factors for a wide range of activities and are suitable for use
outside the UK. Additional sources are applied for specific national parameters. For Slovenia,
fuel-specific factors are based on the Typical Net Calorific Values and Emission Factors published
by the Slovenian Environment Agency and the Ministry of the Environment, Climate and Energy,
which serve as the national reference for selected energy products and calculations. For
electricity in Slovenia, factors and methodological explanations from relevant expert
institutions, including the Jožef Stefan Institute, are used where factors reflecting the Slovenian
electricity mix or national methodological specificities are required.
For international coverage and comparability, International Energy Agency (IEA) data sources are
also used for electricity and heat emission factors where appropriate for EU or broader
comparisons, and for country- and scenario-specific coverage. The selection and application of
emission factors is based on a hierarchy of sources, ensuring consistency over time, traceability
of sources and documentation of any methodological changes.
From the 2024 reporting year onwards, the Group applies updated emission factors (IEA,
Climatiq) to calculate Scope 2 GHG emissions, enhancing calculation accuracy and aligning the
methodology with international standards and the best available sources. Consequently,
calculations for 2024 and 2025 are based on updated data, ensuring greater consistency and
comparability of results. The websites and databases used as sources for emission factors and
calculation assumptions for each GHG category are detailed in the internal carbon footprint
report.
The calculation of the Group's carbon footprint included the following scopes and categories of
emissions.
▪ Scope 1: Direct emissions from sources owned or controlled by the company (e.g. boilers,
stoves, painting chambers, company vehicles) and fugitive emissions associated with air-
conditioning units.
▪ Scope 2: Indirect emissions resulting from purchased district heating and electricity.
42
E1-4_20.
149
For business premises or areas where consumption data are unavailable, consumption was
estimated in proportion to their share of the total premises area. These estimates reflect the
proportion of properties used by the Company for which actual consumption data are not
available. The surcharges (estimated shares) by category are disclosed below:
▪ electricity consumption: 2% (rented properties without individual meters);
▪ energy consumption for heating: 5% (rented properties and part of own properties where
actual consumption data are not provided by the building administrator).
Use of energy products
For heating, cooling, lighting, and the operation of electrical and electronic equipment, the
Group consumed approximately the same amount of energy in 2025 as in 2024. The Company's
energy consumption decreased by around 3%. The largest reductions at Group level were in gas
consumption (13%) and wood pellets (24%), with electricity consumption also down (4%), while
heating water (18%) and fuel oil (5%) consumption increased. At the parent company, electricity
consumption decreased by 5% and gas consumption by 6%, heating water consumption
remained broadly stable (down approximately 1%), and fuel oil consumption increased by 30%.
The share of green electricity in the Group rose to 75.0% in 2025 (2024: 65.7%) and remained
very high at the parent company. The Group promotes energy-efficient practices among
employees, including limiting the temperature of office and sales premises and hot water usage.
When renovating premises, priority is given to highly energy-efficient equipment. Additionally,
for new forced-air ventilation installations, integrated heat recovery systems are used. All new
premises and advertising signs are fitted with LED lighting. When replacing lighting in
basements and garages, lighting sensors are installed in addition to LED lights (see Section 8.5
Investment in own-use real property and equipment for further information).
150
Use of energy products in MWh at the Triglav Group and Zavarovalnica Triglav
43
MWh
Index
Quantity
2025
2024
Base year
2019
2025/2024
2025/2019
Triglav Group
Heating water
MWh
4,698
3,988
4,714
118
100
Fuel oil
MWh
192
182
898
105
21
Gas
MWh
2,402
2,770
2,581
87
89
Wood pellets
MWh
138
182
124
76
111
Electricity
MWh
9,041
9,420
11,270
96
81
Green electricity
MWh
6,774
6,192
118
109
5,757
Share of green electricity (%)
%
75%
66%
1%
114
7,177
Total
MWh
16,470
16,543
19,587
100
84
Zavarovalnica Triglav
Heating water
MWh
3,345
3,374
4,044
99
83
Fuel oil
MWh
116
90
234
130
50
Gas
MWh
1,360
1,445
1,732
94
78
Wood pellets
MWh
0
0
0
0
0
Electricity
MWh
4,943
5,182
6,291
95
79
Green electricity
MWh
4,881
5,113
118
95
4,148
Share of green electricity (%)
%
99%
99%
2%
100
5,279
Total
MWh
9,764
10,090
12,301
97
79
* In 2021, the adoption of an internal methodology for calculating the carbon footprint led to changes in data capture for Zavarovalnica Triglav and the Triglav
Group. Therefore, the data for 2019 and 2020 have also been adjusted.
** The data on heating oil consumption for Zavarovalnica Triglav for 2023 and 2024 were subsequently revised to include previously unreported consumption,
based on additional notifications from property managers.
*** The data for Zavarovalnica Triglav, d.d. have not been audited.
Total energy consumption related to own operations at the Triglav Group and Zavarovalnica
44
Total energy consumption in
MWh
Index
2025
2024
2025/2024
Triglav Group
Total energy consumption from fossil sources
9,876
10,477
94
Total energy consumption from nuclear sources
10
39
250
Total energy consumption from renewable sources
7,442
6,192
120
– Fuel consumption for renewable sources including biomass (also comprising industrial
and municipal waste of biologic origin), biofuels, biogas, hydrogen from renewable
sources, etc.
138
182
76
– Consumption of purchased or acquired electricity, heat, steam and cooling from
renewable sources
6,774
6,192
109
– Consumption of self-generated non-fuel renewable energy
530
539
98
Total energy consumption
17,327
17,430
99
Zavarovalnica Triglav
Total energy consumption from fossil sources
4,934
4,991
99
Total energy consumption from nuclear sources
0
0
0
Energy consumption from renewable sources
5,339
5,573
96
– Fuel consumption for renewable sources including biomass (also comprising industrial
and municipal waste of biologic origin), biofuels, biogas, hydrogen from renewable
sources, etc.
0
0
0
– Consumption of purchased or acquired electricity, heat, steam and cooling from
renewable sources
4,881
5,113
95
– Consumption of self-generated non-fuel renewable energy
459
459
Total energy consumption
10,273
10,564
97
* The fuel oil consumption data for Zavarovalnica Triglav for 2023 and 2024 were subsequently revised due to the inclusion of previously unreported consumption,
based on additional notifications from property managers.
**The data for Zavarovalnica Triglav, d.d. have not been audited.
43
E1-5_01–17.
44
E1-5_01–09.
151
Financed emissions
45
The Group calculates financed GHG emissions associated with the investment assets through which it finances economic activities. The calculation
covers selected balance sheet items, specifically investment property, investments in associates and joint ventures, financial investments and
financial contract assets. Financed emissions are calculated in accordance with the PCAF (Partnership for Carbon Accounting Financials) standard.
Based on the characteristics of the portfolio, the Group defined three key asset classes: (1) equity and corporate debt, (2) sovereign debt and (3)
investment property.
The equity and corporate debt asset class includes shares and participating interests, as well as corporate bonds and loans where the use of assets is
for general corporate purposes. Sovereign debt includes government bonds, including supranational and subnational bonds. Investment property
comprises investment property held to generate rental income; this category also includes investment property in acquisition and loans for the
acquisition, construction or renovation of commercial real property. Investments may be direct or indirect (e.g. via investment or alternative funds),
where sufficiently granular data are available on a look-through basis.
The Group does not calculate financed emissions for cash and cash equivalents, bank deposits, loans to individuals, or other financial receivables;
these exposures represent a smaller share of the investment portfolio and are presented in the tables under “Other”. In 2025, the Group changed its
GHG emissions data provider, established a methodology for investment property, and expanded the calculation to the entire Group level. Due to
the update of the financed emissions methodology in 2025 (including the change of data provider and methodological enhancements), the
comparative figure for 2024 was also recalculated to ensure comparability in line with ESRS requirements. In 2025, the carrying amount of the
investment portfolio included in the calculation of financed emissions totalled EUR 4,319,253 thousand, while the portfolio’s carbon intensity
amounted to 310.0 tCO₂e per EUR million invested. Total financed GHG emissions of the Group amounted to 1,257,214 tCO₂e, of which 366,257
tCO₂e related to Scope 1 and Scope 2 emissions and 890,957 tCO₂e to Scope 3 emissions. In calculating financed emissions, the Group used reported
company data to the greatest extent possible and, where such data were not available, relied on estimates provided by external data providers. The
average PCAF data quality score was 2.8 (financial investments: 2.9; assets from financial contracts: 2.6), where 1 represents the highest and 5 the
lowest data quality.
In 2025, data coverage was ensured for 93.9% of the portfolio (investment property: 100.0%; financial investments: 93.3%; assets from financial
contracts: 96.1%). Total financed emissions were primarily driven by financial investments (987,705 tCO₂e), followed by assets from financial
contracts (266,935 tCO₂e) and investment property (2,574 tCO₂e). Within financial investments, the largest share was attributable to listed equity
and corporate bonds (607,755 tCO₂e) and sovereign bonds (379,950 tCO₂e). Similarly, within assets from financial contracts, the largest contributions
stemmed from listed equity and corporate bonds (205,171 tCO₂e) and sovereign bonds (61,764 tCO₂e).
45
E1-4.
152
For comparability purposes, the 2024 figures were recalculated. The carrying amount of the portfolio totalled EUR 3,921,630 thousand, carbon
intensity amounted to 303.1 tCO₂e per EUR million invested, total financed emissions reached 1,105,434 tCO₂e (of which 327,995 tCO₂e related to
Scope 1 and 2 and 777,439 tCO₂e to Scope 3), and overall data coverage stood at 93.0%. The table presents the carrying value of Triglav Group’s
investment portfolio, absolute financed GHG emissions, carbon intensity, data quality score, and absolute financed GHG emissions by asset class.
Scope 3 financed emissions are presented separately, as the Group recognises the limitations and challenges associated with determining this
portion of emissions.
Financed emissions of the Triglav Group in 2025 and 2024
2025*
2024**
Asset class
Carrying
amount
(EUR
thousand)
Carbon
intensity
(tCO
2
e/million
EUR invested)
PCAF data
quality
assessment
Financed
emissions
(tCO
2
e):
Scope 1
and 2
Financed
emissions
(tCO
2
e):
Scope 3
Financed
emissions
(tCO
2
e):
Total
Data
coverage
Carrying
amount
(EUR
thousand)
Carbon
intensity
(tCO
2
e/million
EUR invested)
PCAF data
quality
assessment
Financed
emissions
(tCO
2
e):
Scope 1
and 2
Financed
emissions
(tCO
2
e):
Scope 3
Financed
emissions
(tCO
2
e):
Total
Data
coverage
Investment property
65,016
39.6
2.7
2,574
2,574
100.0%
70,411
38.4
2.8
2,704
2,576
100.0%
Investment property
65,016
39.6
2.7
2,574
2,574
100.0%
70,411
38.4
2.8
2,704
2,576
100.0%
Financial investments
3,437,420
308.1
2.9
305,926
681,779
987,705
93.3%
3,380,795
302.5
2.9
295,903
652,122
948,025
92.7%
Equity and corporate debt
1,796,941
356.3
2.4
51,294
556,461
607,755
94.9%
1,748,947
347.4
2.4
44,972
525,425
570,397
93.9%
Sovereign debt***
1,524,819
253.3
3.5
254,632
125,318
379,950
98.4%
1,527,713
253.0
3.5
250,931
126,697
377,628
97.7%
Investment property
3,215
0.0%
2,669
0.0%
Other
112,445
101,466
Financial contract assets
816,817
340.0
2.6
57,757
209,178
266,935
96.1%
470,424
349.2
2.6
29,388
125,317
154,705
94.2%
Equity and corporate debt
548,189
383.7
2.2
19,230
185,941
205,171
97.5%
313,760
396.4
2.2
9,998
110,885
120,883
97.2%
Sovereign debt
253,195
246.8
3.4
38,527
23,237
61,764
98.9%
140,981
244.9
3.4
19,390
14,432
33,822
97.9%
Investment property
0
0
Other
15,433
15,683
Total
4,319,253
310.0
2.8
366,257
890,957
1,257,214
93.9%
3,921,630
303.1
2.8
327,995
777,439
1,105,434
93.0%
* In 2025, the Group changed its greenhouse gas (GHG) data provider, established a methodology for investment property, and expanded the calculation to cover the entire Group level.
** Data for the 2024 reporting year were recalculated at Group level based on the updated methodology. As a result, the 2024 figures may differ from previously published or earlier calculated data.
*** In the sovereign debt asset class, the value of countries’ emissions used to calculate financed emissions included land use, land-use change and forestry (LULUCF). For the sake of transparency, the Group also discloses an alternative value of
financed emissions of sovereign debt, calculated excluding LULUCF sector emissions: 2025: 1,251,751 tCO₂e; 2024: 1,052,876 tCO₂e.
Summary of the methodology for calculating financed GHG emissions
Financed GHG emissions are those attributable to the Group's investment activities. They represent the portion of emissions associated with financial
assets in the Group's investment portfolios (e.g. equity instruments, debt instruments of issuers, government bonds and investment property).
The Group applies a methodology aligned with the Partnership for Carbon Accounting Financials (PCAF) guidelines to calculate financed GHG
emissions and distinguishes between three asset classes: (i) equity and corporate debt, (ii) sovereign debt and (iii) investment property.
153
The financed GHG emissions are calculated using the following formula:
Financed GHG emissions = ∑ (Outstanding Amount / Enterprise Value Including Cash (EVIC) × Company GHG emissions)
Outstanding amount is the value of the Group's equity or debt stake in the recipient company. EVIC (Enterprise Value Including Cash) is the total
value of the company, including equity, debt and cash. Total GHG emissions include Scope 1 (direct emissions), Scope 2 (indirect emissions from
energy) and, where data are available and of sufficient quality, Scope 3. For the sovereign debt asset class, the EVIC in the denominator is
appropriately proxied by the country's gross domestic product (GDP) adjusted for purchasing power parity (PPP), and for the investment property
asset class by the value of the entire real property.
Calculations are based on disclosed (i.e. reported) company and country data, estimates derived from segment averages and other methods for
estimating GHG emissions. The Group uses data from the commercial provider MSCI, the PCAF database and other relevant sources.
The methodological approach, data sources, assumptions, and key limitations and uncertainties in the calculation are described in greater detail in
the internal document Methodology for the Calculation and Disclosure of Financed Emissions of Investment Portfolios of Zavarovalnica Triglav d.d.
and the Triglav Group.
Carbon footprint of the Triglav Group (Scope 1, 2 and 3)
The table presents the Triglav Group’s carbon footprint for Scopes 1, 2 and 3 based on ESRS requirements, together with a comparison to the base
year and targets. The base year has currently been defined only for Scopes 1 and 2; therefore, target values and indices relate to these two scopes,
with Scope 2 being reported using both the location-based and market-based methods. Scope 3 categories 3.1–3.14 have been assessed as
immaterial in line with the (double) materiality assessment and are therefore not reported quantitatively, while Scope 3.15 (financed emissions) is
calculated separately based on the PCAF methodology and is presented as part of total Scope 1–3 emissions and the related intensity indicators.
In 2025, Scope 1 and Scope 2 emissions are slightly lower than in 2024: Scope 1 amounts to 2,510 tCO₂e (97% compared to 2024), while Scope 2
totals 4,369 tCO₂e using the location-based method (98%). Combined Scope 1 and Scope 2 therefore remain stable. Within Scope 3, the only material
category identified is financed emissions (3.15), which amount to 1,257,214 tCO₂e in 2025 and are approximately 14% higher than in 2024, thereby
significantly affecting the overall result. Consequently, total Scope 1–3 emissions in 2025 are higher (index 114 compared to 2024), despite
improvements in Scopes 1–2. This is also strongly reflected in the Scope 1–3 emissions intensity, which increased under the location-based method
to 245 tCO₂e per employee (2024: 116).The carbon footprint indicator for Scopes 1–3 per EUR 1 million of net revenue improved in 2025 by
approximately 7% compared to 2024 (index 93) under both the location-based and market-based methods. The decrease in the indicator is primarily
the result of higher net revenue (a larger denominator). As the values under both methods are virtually identical, the impact of the choice between
the location-based and market-based method (Scope 2) on this indicator is limited.
154
Triglav Group’s carbon footprint by scope categories, in accordance with ESRS requirements*
46
Emissions GHG v tCO2e
Index
Activity quantities
Quantity
2025
2024
2030
target
Base year
2025/2024
2025/2019
2019
Triglav Group
Scope 1.1 – Consumption of energy sources in own facilities*
tCO2e
729
772
567
810
94
87
Scope 1.2 – Fuel consumption for company cars
tCO2e
1,780
1,816
1,386
1,981
98
90
Scope 1 – Direct GHG emissions
tCO2e
2,510
2,588
1,953
2,790
97
89
Scope 2 – Indirect GHG emissions (location-based method)
tCO2e
4,369
4,462
5,648
8,068
98
54
Scope 2 – Indirect GHG emissions (market-based method)
tCO2e
2,560
2,988
5,141
7,345
86
35
Total Scope 1–2 GHG emissions (location-based method)
tCO2e
6,879
7,049
7,601
10,859
98
63
Total Scope 1–2 GHG emissions (market-based method)
tCO2e
5,070
5,575
7,094
10,135
91
50
Scope 3.1 – Purchased goods and services
tCO2e
NM
NM
-
-
-
-
Scope 3.2 – Capital goods
tCO2e
NM
NM
-
-
-
-
Scope 3.3 – Fuel- and energy-related activities (not included in Scope 1 or 2)
tCO2e
NM
NM
-
-
-
-
Scope 3.4 – Upstream transportation and distribution
tCO2e
NM
NM
-
-
-
-
Scope 3.5 – Waste generated in operations
tCO2e
NM
NM
-
-
-
-
Scope 3.6 – Business travel
tCO2e
NM
NM
-
-
-
-
Scope 3.7 – Employee commuting
tCO2e
NM
NM
-
-
-
-
Scope 3.8 – Upstream leased assets
tCO2e
NM
NM
-
-
-
-
Scope 3.9 – Downstream transportation and distribution
tCO2e
NM
NM
-
-
-
-
Scope 3.10 – Processing of sold products
tCO2e
NM
NM
-
-
-
-
Scope 3.11 – Use of sold products
tCO2e
NM
NM
-
-
-
-
Scope 3.12 – End-of-life treatment of sold products
tCO2e
NM
NM
-
-
-
-
Scope 3.13 – Downstream leased assets
tCO2e
NM
NM
-
-
-
-
Scope 3.14 – Franchises
tCO2e
NM
NM
-
-
-
-
Scope 3.15 - Financed emissions
tCO2e
1,257,214
1,105,434
-
114
-
Total Scope 1–3 GHG emissions (location-based method)
tCO2e
1,263,093
1,112,483
-
-
114
-
Total Scope 1–3 GHG emissions (market-based method)
tCO2e
1,262,284
1,111,009
-
-
114
-
46
E1-4_02-16, E1-6_01-02, E1-6_04, E1-6_07, E1-6_09, E1-6_10, E1-6_11, E1-6_12, E1-6_13, E1-6_30, E1-6_31_34.
155
Carbon footprint (Scope 1–2) per employee (location-based method)
1.33
1.34
1.44
2.00
99
66
Carbon footprint (Scope 1–2) per employee (market-based method)
0.98
1.06
-
-
92
-
Carbon footprint (Scope 1–2) per EUR 1 million of net revenue (location-based method)
4.06
5.06
-
-
80
-
Carbon footprint (Scope 1–2) per EUR 1 million of net revenue (market-based method)
2.99
4.00
-
-
75
-
Carbon footprint (Scope 1–3) per employee (location-based method)
244.93
212.82
-
-
116
-
Carbon footprint (Scope 1–3) per employee (market-based method)
244.58
212.54
-
-
116
-
Carbon footprint (Scope 1–3) per EUR 1 million of net revenue (location-based method)
745.90
798.50
-
-
93
-
Carbon footprint (Scope 1–3) per EUR 1 million of net revenue (market-based method)
744.83
797.45
-
-
93
-
Total revenue used to calculate the intensity
1,694,722,955
1,393,209,369
-
-
122
-
* GHG emission categories marked as NM were assessed as immaterial based on an internal immateriality assessment.
** Fuel oil consumption data for Zavarovalnica Triglav for 2023 and 2024 were subsequently corrected to include previously unrecorded consumption, based on
additional notifications from property/building managers.
156
10.2.1.2 Climate-related risk management
47
The Company conducts an annual analysis of its exposure to climate-related risks as part of the
ORSA process. For 2025, only physical risks in the insurance portfolio are assessed as material in
the short term.
48
Particular attention is given to adequately addressing sustainability risks, with a focus on
climate-related risks that may materialise through the value of assets and liabilities and thereby
affect the Company's financial position. The resilience analysis is integrated into the ORSA
process for the Company's investment and insurance portfolios, where climate scenario analyses
– including analyses used to inform the identification and assessment of physical risks in the
short, medium and long term – are selected based on an EIOPA template
49
, and the calculations
are tailored to the Company's exposure profile. Processes are regularly updated using
established methods to ensure their continuous improvement. In the assessment of transition
risks within the ORSA, we also consider climate transition scenarios aligned with the Paris
Agreement (limiting warming to 1.5°C; e.g. NGFS/IEA reference scenarios), which inform the
identification of potential transition events and the assessment of exposure. In 2025, no
transition events with a material impact on operations were identified in the short term. The risk
analysis of the insurance and investment portfolios comprises different assessment and
measurement methods for transition risks (CPRS sectors
50
, PCAF
51
, qualitative analysis of the
impact on assets and liabilities
52
) and physical risks (exposure to natural catastrophes, the ND-
GAIN Index
53
, the INFORM risk indicator
54
, qualitative analysis of the impact on assets and
liabilities
55
), which are addressed annually within the framework of the ORSA process. All of the
above analyses, including the qualitative analyses, are carried out within the time periods set
out in the internal documents. The CPRS methodology indicates that the Company has exposure
to all six climate-relevant sectors in both the insurance and investment portfolios. Within the
ORSA, we did not identify any operational assets or business activities of the Company that
would, in themselves, be incompatible with the transition to a climate-neutral economy or
would require disproportionately high efforts to align. Potential exposures to such activities may
arise indirectly through the investment portfolio, where they are addressed within the
investment management framework (e.g. through the responsible investment/exclusion policy
47
E1.SBM-3_06, E1.IRO-1_01–16.
48
E1.SBM-3_01.
49
Consultation paper on application guidance on using climate change scenarios in the ORSA, where the methods are
aligned with the GHG-based NGFS scenarios.
50
A Climate Stress-test of the Financial System, a methodology based on a proposal by researchers Battiston, S.,
Mandel, A., Monasterolo, I., Schütze, F., & Visentin, G. (2017). The Climate Policy Relevant Sectors (CPRS) methodology
divides sectors into nine categories, six of which are exposed to potential transition risks (fossil fuel, infrastructure,
energy-intensive, buildings, transportation and agriculture). The remaining three categories (finance, development
and progress, and other) are only indirectly related to transition risks or are of minor relevance.
51
The PCAF (Partnership for Carbon Accounting Financials) methodology estimates a company's Scope 3 carbon
footprint based on the proportion of the Scope 1, 2 and 3 carbon footprints of the entity, whether natural or legal, to
which the company has direct exposure.
52
Taking into account the findings from applying the CPRS method, the PCAF methodology and the PACTA tool, the
materiality of transition risk is reviewed across different time horizons (short, medium and long term) from the
perspective of the investment and insurance portfolios.
53
The Notre Dame Global Adaptation Initiative (ND-GAIN) Index measures a country's current vulnerability to climate
change and evaluates its readiness to utilise private and public sector investments for implementing adaptation
measures.
54
The indicator is published twice a year by the European Commission. More broadly, it covers countries based on the
risks of humanitarian crises and disasters that may exceed national emergency response capacities. It comprises the
following dimensions: risk and exposure, vulnerability, and a lack of coping capacity.
55
The materiality of physical risks was assessed by time horizon (short, medium, long term) from the perspective of
the investment and insurance portfolios, with separate assessments of exposure relating to insurance technical
provisions and exposure arising from natural catastrophe events.
157
and carbon footprint monitoring). The ORSA process also analyses exposure to flood, storm, hail,
sea-level rise, extreme weather events, forest fire and drought. Analyses indicate that the most
significant damages in Slovenia (Central Europe) are likely to result from forest fires, flooding
and hail. The Company has high exposures in Slovenia, primarily to flood risk, and the risk of
flooding in Slovenia is rated as medium according to the INFORM risk indicator. Nevertheless,
this threat to Slovenian society is considered material
56
. As part of the ORSA process, the
exposures and projected damages for the four RCP flood hazard scenarios for society were also
evaluated. The Company prepared an overall assessment of the materiality of climate-related
risks over the time horizon. In the short term (up to five years), it considers physical risks in the
insurance portfolio, i.e. on the liability side, to be the primary climate-related risks material to
the Company.
Transition risks on both the asset and liability sides are expected to become material for the
Company in the medium term (5–10 years) at most, and are more likely to potentially become
material in the long term (beyond 10 years).
Physical risks in the investment portfolio are more difficult to assess due to potential indirect
impacts, as direct impacts on investments are assumed to be primarily related to real property,
where the Company has limited exposure. Physical risks in the insurance portfolio are expected
to remain material in the medium and long term. The Company's existing reinsurance protection
includes both proportional and non-proportional coverage for the non-life portfolio and is
considered adequate under unchanged reinsurance market conditions. However, in the event of
adverse impacts, the Company itself would be most affected. As a mitigation measure, in a long-
term scenario it would be possible to discontinue insurance coverage for climate-related risks
57
.
Assumptions for climate scenarios and financial statements are aligned.
58
10.2.1.3 Insurance solutions for the low carbon transition and climate resilience
59
As part of its own initiatives, the Group promotes products and services that support
decarbonisation, energy efficiency and renewable energy sources, while developing solutions to
enhance resilience to climate impacts.
The Group also provides appropriate cover for electric and hybrid vehicles within its range of
motor vehicle insurance (comprehensive car insurance and assistance). Micromobility insurance
supports the use of lower-emission modes of transport. Additionally, the Group provides
insurance coverage for owners and operators of renewable energy facilities, including solar,
wind, hydroelectric and biogas plants.
By developing and tailoring insurance solutions, the Group strengthens clients' climate resilience
and promotes preventive action. In agricultural insurance, it participates in preventive
programmes for more sustainable food production, such as irrigation systems, crop protection
systems, hail nets and shelter structures.
In non-life insurance, the Group develops and adapts product coverages to address climate-
related perils, including flood, heavy rainfall, storms, hail, drought and other extreme weather
events, as well as the associated claims management. Exposure to climate-related risks is taken
into account when designing cover and setting premiums, while clients are encouraged to
56
According to internally defined materiality limits for exposure.
57
E1.SBM-3_02, E1.SBM-3_03, E1.SBM-3_04, E1.SBM-3_05, E1.SBM-3_06, E1.IRO-1_07, E1.IRO-1_08, E1.IRO-1_09,
E1.IRO-1_10, E1.IRO-1_11, E1.IRO-1_12, E1.IRO-1_13, E1.IRO-1_14, E1.IRO-1_15.
58
E1.IRO-1_16.
59
S4.SBM-3_05.
158
implement preventive measures. Further information on the criteria, methodology and scope of
climate-related covers in the context of the EU Taxonomy is provided in Section 10.1.2.2 Key
performance indicators related to underwriting activities.
In asset management, the Group has been gradually increasing its shares of green bonds, social
impact bonds, sustainable bonds and sustainability-linked bonds since 2021. It further
strengthened investment approaches that integrate sustainability approaches into the
management of client assets. At the same time, the Group recognises that insuring fossil fuel
companies and exposure to activities with high greenhouse gas emissions can contribute to
negative climate impacts and is therefore progressively reducing such exposures within the
scope of available policies and options. Further information is provided in Section Responsible
investment at the Triglav Group.
In 2025, the Group recorded a slight increase in written premium for insurance products that
promote environmental benefits. The growth was primarily driven by higher written premium
for electric vehicle insurance (index 130) and solar power plant insurance (index 125), reflecting
strengthened activities related to e-mobility and renewable energy sources. Written premium
for wind farm insurance and micromobility insurance remained stable. Crop and fruit insurance
recorded lower written premium (EUR 10,395,724, index 82), partly offsetting growth in other
categories.
Written premium from the Triglav Group insurance products that promote environmental benefits
Written premium
Index
2025
2024
2025/2024
Crop insurance
10,395,724
12,727,873
82
Electric vehicle insurance
8,367,134
6,450,792
130
Micromobility insurance
519,277
523,458
99
Solar power plant insurance
3,739,398
2,997,657
125
Wind farm insurance
177,486
175,116
101
Total written premium
23,199,021
22,874,896
101
10.2.2 Disclosures under the EU Taxonomy Regulation
10.2.2.1 Key performance indicators related to investments
60
In 2020, the European Union adopted Regulation (EU) 2020/852 (the EU Taxonomy Regulation),
establishing a fundamental regulatory framework to promote sustainable investments and
enhance the transparency of sustainable disclosures by financial market participants and other
companies. The EU Taxonomy provides a standardised system for identifying environmentally
sustainable economic activities. To this end, the EU has defined six environmental objectives: (1)
climate change mitigation, (2) climate change adaptation, (3) sustainable use and protection of
water and marine resources, (4) transition to a circular economy, (5) pollution prevention and
control, and (6) protection and restoration of biodiversity and ecosystems.
The EU Taxonomy framework then specifies the conditions under which an economic activity is
considered environmentally sustainable. An activity is considered Taxonomy-aligned if it: (i)
makes a substantial contribution to at least one of the six environmental objectives; (ii) does not
cause significant harm to any of the remaining objectives; (iii) is carried out in accordance with
minimum safeguards; and (iv) meets the technical screening criteria established for the specific
activity. More detailed rules of the EU Taxonomy are set out in delegated acts, which define the
technical criteria for activities and the disclosure requirements. Key acts include those for
60
E1-1_08.
159
climate objectives (2021/2139), Article 8 disclosures (2021/2178), amendments covering
nuclear and gas energy under certain conditions (2022/1214) and criteria for the remaining
environmental objectives (2023/2486).
On 4 July 2025, the European Commission adopted a delegated act to simplify the application of
the Taxonomy, amending the disclosure requirements and parts of the technical criteria, in
particular the amendments to acts 2021/2178, 2021/2139 and 2023/2486. These
simplifications apply from 1 January 2026 (for 2025), with the possibility to apply them also from
2026, if more appropriate for the Company, following completion of the control procedure and
publication in the Official Journal of the EU. The Triglav Group decided to prepare disclosures
under the EU Taxonomy in accordance with the latest applicable delegated acts and their
updates, including the simplifications mentioned above. The Triglav Group takes climate change
impacts into account in its investment management, as its investment decisions influence
companies and the economy. In response, it is adapting its business strategy and has set key
performance indicators as part of its strategic ambitions for 2030 to guide its investment
strategy. These include progressively reallocating capital towards sustainable investments and
supporting the transition to a low-carbon economy:
▪ Increase the share of green bonds, sustainable bonds, social impact bonds and sustainability-
linked bonds to 15% of the bond portfolio.
▪ Expand the range of products to include SFDR Article 9 funds (dark green funds).
▪ Keep investment exposure to the Coal Exit List below 1%.
▪ Increase the EU taxonomy alignment of investments.
When offering insurance products with an investment component, the Triglav Group
incorporates sustainability aspects into its strategic guidelines, product management, and
engagement with clients and counterparties. At the strategic level, the Group promotes a
greater inclusion of investments with sustainability characteristics in clients' decision-making,
in particular within insurance products with an investment component, and, in the development
and management of the product offering, takes into account the available information on the
sustainability characteristics of products and funds (including classification under the SFDR and
other relevant disclosures by managers, where data on the EU Taxonomy are also available).
Within the framework of product development and regular product review processes, the Group
currently does not set specific minimum requirements regarding the proportion of alignment of
funds or investment options with Regulation (EU) 2020/852 (the EU Taxonomy). The Group will
continue to progressively enhance the integration of the requirements of Regulation (EU)
2020/852 into product development processes, product management and engagement with
counterparties, in line with the development of the offering, data availability and regulatory
requirements.
The proportion of the Group's investments directed at or associated with financing of Taxonomy-
aligned activities in relation to total investments in 2025
Exposures
%
EUR million
1
Total assets under management
100
4,319,253,689.55
2
Assets covered by the KPI
26.74
1,155,039,813.43
% of covered assets
% turnover-based
% CapEx-based
3
Taxonomy-eligible
29.01
32.95
4
Nuclear activities (6)
0.25
0.41
5
Fossil gas activities (7)
0.62
0.55
6
Taxonomy-aligned
5.04
7.59
7
Undertakings subject to Articles 19a and 29a of Directive 2013/34/EU:
5.04
7.58
8
of which non-financial udertakings
3.73
6.17
160
9
of which financial udertakings
1.31
1.42
10
Other covered counterparties and real estate assets
0.00
0.00
11
Investments other than investments held in respect of life insurance contracts where the
investment risk is borne by the policyholders
2.85
4.15
12
Exposures included on a voluntary basis
0.00
0.00
13
Transitional activities
0.30
0.47
14
Enabling activities
2.42
3.56
15
Nuclear activities
0.26
0.16
16
Fossil gas activities
0.01
0.01
Taxonomy-aligned per objective
% turnover-based
% CapEx-based
17
Climate change mitigation (CCM)
4.72
7.27
18
Climate change adaptation (CCA)
0.02
0.07
19
Water and marine resources (WTR)
0.06
0.09
20
Circular economy (CE)
0.22
0.12
21
Pollution (PPC)
0.02
0.03
22
Biodiversity and ecosystems (BIO)
0.00
0.00
23
Non-assessed exposures
0.00
0.00
24
Exposures financing non-material activities of counterparties
0.00
0.00
25
Exposures financing counterparties reporting in accordance with Article 7(9) to this
Regulation
0.00
0.00
26
Non-assessed exposures considered non-material by the reporting entity
0.01
0.01
Breakdown of covered assets
%
EUR million
27
Undertakings subject to Articles 19a and 29a of Directive 2013/34/EU:
94.09
1,086,809,439.63
28
of which non-financial undertakings
39.14
452,027,296.60
29
of which financial undertakings
54.96
634,782,143.03
30
Other covered counterparties and real estate assets
5.91
68,230,373.80
31
Investments other than investments held in respect of life insurance contracts where the
investment risk is borne by the policyholders
65.54
757,062,770.23
32
Exposures included on a voluntary basis
0.00
0.00
The proportion of the Group's investments directed at or associated with financing of Taxonomy-
aligned activities in relation to total investments in 2024
Exposures
%
EUR million
1
Total assets under management
100
3,906,135,551.95
2
Assets covered by the KPI
57.00
2,209,254,391.90
% of covered assets
% turnover-based
% CapEx-based
3
Taxonomy-eligible
6.25
6.04
4
Nuclear activities (6)
0.06
0.01
5
Fossil gas activities (7)
0.83
0.74
6
Taxonomy-aligned
1.51
2.47
7
Undertakings subject to Articles 19a and 29a of Directive 2013/34/EU:
1.51
2.47
8
of which non-financial undertakings
1.18
2.10
9
of which financial undertakings
0.34
0.37
10
Other covered counterparties and real estate assets
0.00
0.00
11
Investments other than investments held in respect of life insurance contracts where the
investment risk is borne by the policyholders
1.35
2.09
12
Exposures included on a voluntary basis
/
/
13
Transitional activities
0.14
0.18
14
Enabling activities
0.61
1.06
15
Nuclear activities
0.32
0.24
16
Fossil gas activities
0.25
0.37
Taxonomy-aligned per objective
% turnover-based
% CapEx-based
17
Climate change mitigation (CCM)
0.71
1.13
161
18
Climate change adaptation (CCA)
0.02
0.10
19
Water and marine resources (WTR)
0.00
0.00
20
Circular economy (CE)
0.02
0.01
21
Pollution (PPC)
0.00
0.00
22
Biodiversity and ecosystems (BIO)
0.00
0.00
23
Non-assessed exposures
0.00
0.00
24
Exposures financing non-material activities of counterparties
0.00
0.00
25
Exposures financing counterparties reporting in accordance with Article 7(9) to this
Regulation
0.00
0.00
26
Non-assessed exposures considered non-material by the reporting entity
0.00
0.00
Breakdown of covered assets
%
EUR million
27
Undertakings subject to Articles 19a and 29a of Directive 2013/34/EU:
27.86
615,496,854.11
28
of which non-financial undertakings
12.39
273,657,827.09
29
of which financial undertakings
15.47
341,839,027.02
30
Other covered counterparties and real estate assets
72.14
1,593,737,727.56
31
Investments other than investments held in respect of life insurance contracts where the
investment risk is borne by the policyholders
76.08
1,680,871,821.54
32
Exposures included on a voluntary basis
/
/
The Group reports on the proportion of Taxonomy-eligible assets, the proportion of Taxonomy-
aligned assets, and a breakdown of the key performance indicator per environmental objective.
The framework for implementing the Taxonomy is the calculation of statutory metrics,
particularly the key performance indicator (KPI) – the value and proportion of Taxonomy-aligned
investments. Currently, Taxonomy indicators are not integrated in the Group's investment
process. Within the Group's investment process, Taxonomy indicators are not currently used as
an operational decision-making criterion.
The Group's total managed assets represent the Company's total investments (i.e. managed
assets). It refers to those balance sheet assets that are invested, i.e. intended for investment and
the generation of income or actively used to achieve returns or finance economic activities. This
constitutes a part of the Group's total balance sheet assets. This constitutes a part of the Group's
total balance sheet assets. These assets primarily comprise investment property, investments in
associates, financial investments and financial contract assets. The balance sheet assets not
included in the Group's total managed assets comprise property, plant and equipment, right-of-
use assets, intangible assets and goodwill, insurance and reinsurance contract assets,
receivables, other assets, and cash and cash equivalents.
In accordance with Commission Delegated Regulation (EU) 2026/73, derivatives, cash and cash
equivalents, and certain other categories of assets are excluded from the denominator of the key
performance indicators of financial undertakings; at the same time, exposures to undertakings
that are not subject, in their management report, to sustainability disclosure requirements
under Articles 19a or 29a of Directive 2013/34/EU (or do not belong to a group subject to such
requirements) are also excluded from the denominator. As a result of these methodological and
scope changes, the structure of the denominator changed compared to previous years, which
affects the comparability of KPI values between years.
All assets that finance economic activities fall under the Taxonomy-alignment indicators (KPIs).
These assets relate to the Group's portfolios covering obligations for non-life, life, pension and
unit-linked insurance, and the Company's own funds. They primarily include balance sheet items
such as financial investments, financial contract assets and investment property, but exclude
intangible assets, own-use real property and equipment, and insurance and reinsurance contract
assets.
Economic activities are considered Taxonomy-eligible if they are listed in Commission Delegated
Regulation (EU) 2021/2139 supplementing the EU Taxonomy Regulation. Activities are
162
Taxonomy-aligned where they substantially contribute to one or more environmental
objectives, do not significantly harm any of the other objectives (DNSH), are carried out in
compliance with the minimum safeguards, and meet the technical screening criteria.
For the purpose of assessing the degree of Taxonomy alignment of investments, the Group uses
information from an external data provider (MSCI), relying exclusively on reported data (i.e. no
estimated data are used). For investments in collective investment undertakings and alternative
investments, the Group applies a first-level look-through approach. Investments for which,
despite best efforts, a detailed assessment cannot be performed are classified as “assets
financing economic activities that are not Taxonomy-aligned”.
For 2025, the Group prepared its disclosures in accordance with the simplified requirements of
Commission Delegated Regulation (EU) 2026/73, which shortens and streamlines the disclosure
templates and introduces additional rules for the treatment of financially immaterial items. In
the tables, the Group presents comparative data for the previous year (2024) in the new
disclosure format, in line with the templates set out in Commission Delegated Regulation (EU)
2026/73. The comparative data for 2024 are based on the figures reported for the 2024 financial
year under Delegated Regulation (EU) 2021/2178 and were appropriately adapted to the new
disclosure templates.
In 2025, the Triglav Group increased its total managed assets to EUR 4,319.3 million (2024: EUR
3,906.1 million). Covered assets in the key performance indicator (KPI) amounted to EUR 1,155.0
million in 2025, representing 26.74 % of total managed assets. The comparative data for 2024
are therefore not fully directly comparable with the 2025 figures, as there were changes in the
methodology and scope of the KPI denominator between the periods (particularly regarding
covered assets and the treatment of certain exposure categories). The Group takes this
difference into account when explaining the year-on-year developments.
When explaining the development of key performance indicators regarding Taxonomy
alignment, it is important to distinguish between business factors and methodological and data-
related factors. Among the methodological factors, the change in the scope of covered assets in
the KPI is particularly significant, as the proportion of covered assets changed substantially
between the years due to new rules on exclusions from the denominator and the treatment of
exposures to undertakings not subject to reporting under Articles 19a or 29a of Directive
2013/34/EU. Therefore, the year-on-year KPI movement between 2024 and 2025 is not fully
directly comparable. For a better explanation of year-on-year developments, the Group also uses
an internal recalculation of the comparative data for 2024 based on the new methodology (this
recalculation is not presented as a separate table in the annual report). On this comparable basis,
covered assets in the KPI increased in 2025 to EUR 1,155.0 million, or 26.74 % (2024 recalculated:
EUR 957.9 million, or 24.52 %). The growth in covered assets in the KPI is primarily due to the
increase in the Group's total managed assets, which rose from EUR 3,906 million in 2024 to EUR
4,319 million in 2025. The increase, exceeding the planned earnings before tax, was mainly
driven by higher business volume across all segments except the Health segment, and by the
expansion into foreign markets in line with the strategic ambition of internationalisation. A
significant contribution to asset growth came from the expansion into the Italian motor vehicle
insurance market in cooperation with Prima Assicurazioni and Ageas Re. With the investment
strategy unchanged, the comparable proportion of investments aligned with the EU Taxonomy
was consequently maintained. More detailed explanations of the Group's business activities are
presented in the Business Report. The share of Taxonomy-aligned investments remained at a
similar level: 5.04 % based on income (2024 recalculated: 5.00 %) and 7.58 % based on CapEx
(2024 recalculated: 8.06 %), while the share of Taxonomy-eligible investments in 2025 was lower
(29.01 % based on income and 32.95 % based on CapEx; 2024 recalculated: 31.16 % and 34.27 %).
163
Compared with the publicly disclosed 2024 figures under the previous methodology (e.g. 57.00 %
of covered assets), the differences are therefore primarily methodological.
The Group therefore explains the year-on-year KPI movement as a combination of a
methodological effect (changes in reporting rules and coverage), a data effect (availability and
quality of counterparties' disclosures), and a business effect (portfolio changes). A breakdown of
aligned exposures by environmental objective shows that, in 2025, the Group's investment
alignment primarily stems from activities contributing to climate change mitigation, while the
shares for other environmental objectives are lower. The Group relies on the available reported
Taxonomy disclosures of counterparties (via an external data provider); therefore, the
substantive profile of aligned activities depends on the portfolio structure as well as the quality
and timeliness of individual issuers' disclosures.
Restrictions on the calculation of indicators
In the calculation of the key performance indicator, the reported alignment indicators of the
counterparties in which the Group invests are taken into account. As the transition to the
simplified templates under Commission Delegated Regulation (EU) 2026/73 is new and the
timing of counterparties’ disclosures is being aligned gradually, for a portion of the investments
during the reporting period only counterparty indicators prepared under the previous
methodology were available, which may affect the full comparability and the breakdown
according to the new categories. Commission Delegated Regulation (EU) 2026/73 also
introduces the separate treatment of “not assessed” or “unassessed exposures” (e.g. in cases
where activities are considered financially immaterial or where data availability does not allow
for a detailed assessment). The Group therefore discloses these items in accordance with the
applicable templates and the information available.
10.2.2.2 Key performance indicators related to underwriting activities
The Triglav Group is committed to developing preventive solutions associated with climate-
related risks, with the aim of reducing the adverse effects of extreme weather events. In the
context of strategic ambitions for 2030, an important objective is to increase the share of the
premium related to natural catastrophes as defined in the EU Taxonomy, allowing better
coverage of climate-related risks. The Group's objective is to progressively increase the share of
Taxonomy-aligned product categories that are included in the climate change adaptation
framework. The Group is committed to promoting innovative approaches to climate change
adaptation and raising awareness among its clients about the importance of adaptation and risk
prevention. Through targeted communication initiatives, strategic partnerships and continuous
dialogue with clients – both before and after extreme weather events – the Group aims to
strengthen resilience and preparedness for climate-related risks. Increasing the proportion of
damage repaired is also a priority, contributing to waste reduction and sustainable restoration
of damaged buildings and assets. The Group actively promotes a wide range of insurance
products for electric and hybrid vehicles and provides effective risk protection for companies
engaged in renewable energy production, such as solar power plants, wind farms and other
forms of sustainable energy production.
164
The underwriting KPI for non-life insurance and reinsurance undertakings
Economic activities: Non-life insurance and
reinsurance underwriting activities
Absolute premiums
Proportion of
premiums
Absolute premiums
Proportion of
premiums
2025
2025
2024
2024
EUR
%
EUR
%
Taxonomy-aligned activities
71,766,888
3.43%
67,600,000
5%
Nuclear activities
-
-
-
0%
Fossil gas activities
-
-
-
0%
Taxonomy-eligible activities
60,405,248
2.89%
26,600,000
2%
Nuclear activities
-
-
-
0%
Fossil gas activities
295,538
0%
-
-
Non-assessed activities considered non-material
-
-
-
-
Total
2,093,472,603
100%
1,318,669,030
100%
Eligibility and alignment of non-life insurance
To assess alignment with the EU Taxonomy, the Group reviewed selected economic activities
carried out during the reporting period that are classified as insurance services (other than life
insurance) in accordance with Annex I of Commission Delegated Regulation (EU) 2015/35. The
assessment was conducted in line with Commission Delegated Regulation (EU) 2021/2139, as
amended by Delegated Regulation (EU) 2023/2485, which establishes the technical screening
criteria for determining the conditions under which an economic activity substantially
contributes to climate change mitigation or adaptation, and for determining whether the
activity causes no significant harm (DNSH) to any of the other environmental objectives. The
updated requirements and disclosures also take into account the simplifications introduced by
Commission Delegated Regulation (EU) 2026/73 of 4
th
July 2025, which amends the disclosure
requirements under Delegated Regulation (EU) 2021/2178 and simplifies certain DNSH criteria
in Delegated Regulations (EU) 2021/2139 and (EU) 2023/2486. These simplifications apply from
1 January 2026, while the Regulation also allows the application of the rules in force on 31
December 2025 to the 2025 financial year. The assessment focused on the activities within the
Company's and the Group's business model that involve non-life insurance services associated
with the insurance of climate-related hazards, as outlined in Appendix A.
61
As this is the second year of reporting, the Group, in accordance with Annex XI, provides a clear
explanation of the development of insurance KPIs between 2024 and 2025, distinguishing
between (i) business-related factors and (ii) methodological/data-related factors. From a
business perspective, movements in the indicators were influenced by the expansion of the
portfolio due to the internationalisation of operations (entry into the Italian motor insurance
market and the strengthening of operations in the Polish market), which increased the
denominator (total gross written premium) and thereby affected the respective ratios. From a
methodological and data perspective, updates to disclosures (including the application of
simplifications) affected the determination of taxonomy-eligible and taxonomy-aligned
premiums, as well as the comparability of year-on-year data.
The premium distribution methods used comply with EU Taxonomy guidelines and are aligned
with the Group's gross written premium to ensure data comparability. The method for
calculating the proportion of the premium covering climate-related events is based on a claims
database, enabling a more accurate assessment of climate-related risks' impact on business.
The EU Taxonomy identifies non-life insurance activities that could potentially contribute to
climate change adaptation and, therefore, are eligible under the Regulation if they meet specific
conditions related to the underwriting of climate-related perils. Based on the assessment, the
Group identified Taxonomy-eligible insurance subclasses. In this process, the materiality
61
See https://ec.europa.eu/sustainable-finance-taxonomy/assets/documents/CCA%20Appendix%20A.pdf.
165
criterion was considered, and only major insurance subclasses that would significantly
contribute to alignment were included. When identifying these subclasses, the gross written
premium for each was considered, and only those with a portfolio size significant enough to
impact climate change adaptation were assessed for Taxonomy alignment. The Group
conducted an analysis of direct non-life insurance activities, Four taxonomy-aligned insurance
activities were identified:
1. fire and other damage to property insurance,
2. other motor insurance,
3. marine, aviation and transport insurance,
4. income protection insurance,
5. compulsory motor third-party liability insurance.
The Taxonomy alignment calculation is based on assessing insurance premium against the
technical screening criteria for significant contribution to climate change adaptation. The
assessment aims to identify activities that contribute significantly to climate change adaptation,
without causing significant harm to the climate change mitigation objective, and that meet the
minimum safeguards and 'do no significant harm' (DNSH) criteria. The assessment of premium
alignment with technical criteria considers the Company's total gross written premium, linked
to specific hazards. Additionally, the proportion of premium associated with particular hazard
classes is taken into account, determined based on 10 years of claims experience. Claims with a
specific cause or hazard are considered. The alignment assessment found that the complex
technical criteria and established processes for modelling, pricing, product design and innovative
solutions allow alignment only for the Company's gross written premium. The Triglav Group will,
in the forthcoming period, progressively establish appropriate processes within its subsidiaries
to enable potential alignment with the technical criteria across multiple Group companies.
A leading role in modelling and pricing for climate-related risks
Zavarovalnica Triglav incorporates climate-related risks into its insurance business across several
key areas. Historical weather event data are used in underwriting, alongside climate change
modelling to assess potential future risks. Tailored insurance products are developed to provide
coverage for climate change impacts, such as floods, fires, droughts and extreme weather
events, with premiums adjusted based on climate-related risk exposure. The Company promotes
preventive measures, including raising client awareness of best practices to reduce risk
exposure, and offers more favourable premiums for buildings designed to be more resilient to
extreme weather events. Advanced technologies, including climate change modelling and
analysis of extreme weather events, are used to assess these risks. Through these strategies, the
Company ensures a comprehensive response to climate risks, enhancing the resilience of
policyholders and businesses to climate change impacts.
The Company reviews historical claims experience, adjusting values to current levels. In addition
to historical data, changes in the frequency and severity of natural catastrophes and projected
future possibilities are assessed using models that simulate future events alongside internal
assessments. Various scenarios for the total sum of natural catastrophe claims are applied. In
assessing premium adequacy, the Company, for the portion of the portfolio relating to specific
perils, considers the total gross written premium, as well as the share of premium attributable
to individual peril groups, determined on the basis of ten-year claims experience.
The Company publicly discloses information on coverage provided to policyholders for
protection against natural catastrophes, along with general terms and conditions and product
information available on its website. This allows interested parties to easily access coverage
details, compare them against their needs and requirements, and, in some cases, such as home
insurance, check prices in advance. In cases of premium increases due to natural disaster risks,
166
transparency is ensured through distributors, who personally inform policyholders of the
reasons for the increase when renewing policies.
The Company is committed to encouraging measures that reduce climate-related risks among
its policyholders. To this end, climate-related risks are considered when setting premiums.
Additionally, such risks may also be reflected in insurance terms and conditions, including
deductibles or policy limits. In this way, the Company not only manages risks effectively, but also
promotes responsible behaviour by its clients in adapting to the effects of climate change.
Recognising the value of preventive action by policyholders, the Company integrates detailed
and sophisticated modelling with the development of new software tools. For example, the
Geographic Information System (GIS) defines areas with varying degrees of exposure to climate
change-driven natural phenomena, adjusting premiums accordingly. To this end, preventive
behaviour is encouraged through premium discounts, Particularly in mass-market insurance,
while specialised underwriters assess clients' climate change adaptability to negotiate more
favourable insurance terms.
The Company applies tailored approaches to each type of insurance and policyholder. For
property insurance against flood risks, it has introduced a GIS-based building classification
system, developed using data from the official national meteorological system and its own long-
term records of claims experience. This enables lower premiums for properties located in less
flood-prone areas. A similar approach is used in agricultural production insurance, where hazard
classes are regularly updated by area, peril and agricultural crop each season.
Product design
The Company encourages policyholders to implement preventive measures to mitigate risks
associated with climate-related hazards. These measures include premium reductions or more
favourable terms for policyholders who take protective actions, such as installing flood barriers,
co-financing flood nets, enhancing flood protection, investing in fire protection systems and
purchasing firefighting equipment.
The Company provides policyholders and the general public with guidance on preventive
measures through its sales network, online resources and other media. This includes the
Everything Will Be Alright portal, which features in-depth stories and articles on severe weather
events such as floods, landslides, storms, hail, earthquakes and fires, as well as podcasts on
floods, earthquakes and fires. These topics are explained together with experts, covering both
the occurrence of such events and the preventive measures to be taken.
The Triglav Vreme app delivers timely push notifications on severe weather events and offers
hail risk trend displays, as well as real-time monitoring of water flow and levels.
The Company informs its clients through its distribution network, advises and raises awareness
among visitors to agricultural fairs and educates young people in agricultural schools. Preventive
financial incentives are offered to policy-holding organisations, such as companies and fire
brigades, to mitigate various risks covered by their policies. These incentives include co-financing
for anti-hail nets, flood protection measures, investments in fire-fighting systems, and the
purchase of fire-fighting equipment to support intervention and prevention efforts of fire
brigades. Additionally, resources are allocated to awareness-raising programmes that educate
the general public on preventive measures, such as flood, hail, lightning, fire and storm
protection, as well as guidance on health prevention, braking distances and road weather
conditions.
167
Innovative solutions for insurance cover
Each year, the Company conducts a regular annual review of its insurance products, during
which development departments assess the compliance of products with the needs of the target
market and the appropriateness of their design. They also evaluate potential negative impacts
on clients, including emerging risks, and review the suitability and control of distribution
strategies. If any deviations are identified, corrective measures are implemented. Beyond the
regular annual review, an extraordinary review may be conducted if circumstances arise that
affect product suitability, such as significant changes in product content, shifts in the broader
economic environment impacting sales viability or findings from supervisory inspections. This
systematic approach enables proactive risk management, ensuring alignment with regulatory
expectations and client needs.
Insurance products play a key role in addressing climate change, as insurers help businesses and
individuals manage climate-related risks and promote sustainable practices. This includes
assessing climate-related risks and developing adaptation strategies. The floods and storms in
Slovenia during the summer of 2023, which caused record-high damage, underscored the
importance of adequate insurance against natural catastrophes. The Company analysed
relevant climate-related perils covered by its products to ensure they are tailored to client needs
and expectations regarding climate-related risk coverage. As a result, a new functionality was
developed within the i.triglav digital office.
At the i.triglav digital office, policyholders can check the risk exposure of their location,
identifying the extent to which their property is at risk from natural hazards such as floods,
earthquakes, hail and lightning. This serves as the basis for determining appropriate insurance
cover. As part of its non-life insurance offerings, the Company provides business interruption
insurance for weather-related risks, including windstorms, hail, floods and earthquakes. For
individually owned solar power plants (solar power plant insurance), business interruption
coverage is included under home insurance, protecting against destruction or damage caused by
perils covered under the home insurance policy, such as storms, hail, floods, stormwater,
landslides and frost. This type of coverage is also available for owners of solar power plants
operated for profit.
As part of its activities, in April 2023, Zavarovalnica Triglav launched an automated campaign
encouraging home insurance clients without flood cover to add it during the policy renewal
month. This initiative aims to enhance client protection against the effects of extreme weather
events and promote preventive action. Additionally, during the summer, the Company launched
a campaign targeting clients who do not have home insurance with Zavarovalnica Triglav but
hold other insurance policies. Through a series of emails, the campaign highlighted the risks of
summer weather events such as storms, hail and floods. Through such targeted campaigns, the
Company raises awareness of the importance of adequate protection and encourages timely
action to mitigate climate-related risks.
Data communication
The Company reports the number of natural catastrophe claims to the Slovenian Insurance
Association annually and provides data to supervisory authorities upon request.
Comprehensive post-catastrophe services
Clients can report claims through multiple channels, with digital reporting becoming the
predominant method. The Company maintains an extensive network of insurance agents who
assist policyholders in the claims process. By publishing the necessary claim reporting forms and
information on the claims settlement process, it ensures that policyholders have access to all
168
relevant information at all times. Additionally, the claims reporting and settlement process is
further streamlined through registration with the i.triglav digital office, which offers various
functionalities to facilitate faster and more efficient claims handling.
'Do no significant harm' criterion
Reporting on the 'do no significant harm' (DNSH) criterion within the EU Taxonomy includes an
assessment of whether insurance premium related to climate change coverage negatively
impact other environmental objectives, even when they contribute to one of them, such as
climate change mitigation or adaptation. For an economic activity to be Taxonomy-aligned, it
must not harm the environmental objective of climate change mitigation. The Company verifies
compliance with legal requirements using an internal classification of economic activities based
on the statistical classification of economic activities in the European Community (the NACE
classification). A thorough review of the portfolio is conducted, applying a conservative
approach. For retail clients (insurance for natural persons), DNSH compliance is not a key
requirement, as personal use (e.g. home heating or personal vehicles) is not considered harmful.
The DNSH criteria are presented in tables within the document, where they are indicated as "Y"
(yes) or "N" (no) for various environmental objectives.
The Company further verified alignment of premium to ensure compliance with the 'do no
significant harm' (DNSH) and minimum safeguards requirements. The assessments in this report
are based on Delegated Regulation (EU) 2021/2139, which establishes DNSH criteria for non-life
insurance activities related to the EU Taxonomy for climate change mitigation. The Company
verified that the Taxonomy-aligned premium does not include insurance for the extraction,
storage, transport or production of fossil fuels, and insurance of vehicles, property or other
assets. The Company acknowledges that identifying whether a particular vehicle is used to
transport fossil fuels is currently challenging, and this is disclosed as a data constraint. The
importance of accuracy in reporting is recognised, and efforts are being made to improve the
calculation methodology to enable better identification of vehicles used to transport fossil fuels
in the coming year.
Minimum safeguards
For final premium alignment, compliance with minimum safeguards is essential. These
safeguards require that economic activities comply with the UN Guiding Principles on Business
and Human Rights and the OECD Guidelines for Multinational Enterprises on Responsible
Business Conduct. Compliance with minimum safeguards is ensured at various levels and across
different areas through the implementation of guidelines and processes.
As part of its investment portfolio management, the Company carefully monitors investment
choices and ensures that its products adhere to the highest standards of responsible investment.
Limitations on the calculation of indicator
The Triglav Group disclosed the Taxonomy-aligned premium only for Zavarovalnica Triglav, as
the insurance and reinsurance activities of its subsidiaries do not yet meet the technical
screening criteria under the EU Taxonomy. The premium of subsidiaries was therefore classified
as non-aligned. Given the evolving regulatory environment, these limitations are acknowledged,
and efforts are ongoing to improve the alignment analysis for subsidiaries to ensure more
accurate disclosures in the next EU Taxonomy report.
Currently, the linkage between individual insurance line items and reinsurance premiums has
not yet been fully established.
169
Based on the assessment procedures performed, it was determined that the complex technical
screening criteria and the established processes for modelling, pricing, product design and the
development of innovative solutions currently enable the assessment and recognition of
taxonomy-aligned premiums only at the level of the parent company. In the forthcoming period,
the Group will progressively establish appropriate processes in other subsidiaries to enable the
assessment and potential alignment with the technical screening criteria across a broader scope
of entities.
Within the motor third-party liability (MTPL) line of business, the key performance indicator is
particularly sensitive to the allocation of premiums and data availability. In 2025, the Group
included MTPL in taxonomy-eligible premiums but did not include it in taxonomy-aligned
premiums, as not all technical screening criteria were met. In determining eligibility, only perils
that can be directly linked to specific claims events (e.g. hail, windstorm, snow, flood, heavy
precipitation) were taken into account; claims occurring on days with rain or fog were not
automatically attributed to weather-related events. The Group applied a claims co-occurrence
approach (an MTPL claim under the same policy and on the same day as a claim arising from a
natural event in another insurance sub-line) and, on this basis, estimated the share of eligible
premiums.
For large policyholders, where premium was individually determined and uncertainty existed
regarding full compliance with all technical criteria, the entire premium was classified as eligible
but non-aligned.
With regard to the reinsurance business, the Group currently does not have sufficient and
comparable data to enable the calculation of taxonomy eligibility or alignment under Activity
10.2. Reinsurance premiums are generally received on an aggregated contractual basis, without
full visibility into the detailed structure of the underlying insurance portfolios of cedants. Due to
these limitations, the Group was not able to reliably calculate either taxonomy-eligible or
taxonomy-aligned premiums for reinsurance in the reporting period.
The Triglav Group is an insurance and financial group and therefore discloses the average of key
performance indicators for the investment and insurance businesses as a percentage of each
segment's income. The final common key performance indicator combines both segments and
is prepared in accordance with the requirements of Annex XI of the Disclosures Delegated Act
(DDA).
Weighted average of key performance indicators for the investment and insurance segments in
2025
Key performance indicator by
business segment
Revenue
Share of total
Group
revenue
(A))
Revenue-
based key
performance
indicator
(B)
Capital
expenditure
(CapEx)-based
key
performance
indicator
(C) )
Weighted
revenue-
based key
performance
indicator
(A×B)
Weighted
CapEx-based
key
performance
indicator
(A×C)
Asset management
53,753,139
3.17%
5.04%
7.59%
0.16%
0.24%
Insurance
1,640,969,816
96.83%
3.43%
3.43%
3.32%
3.32%
- non-life insurance
1,482,640,854
87.49%
3.43%
3.43%
- health insurance
50,633,435
2.99%
-
- life insurance
107,695,527
6.35%
-
Total
1,694,722,955
100.00%
Average key performance indicator
3.48%
3.56%
170
Weighted average of key performance indicators for the investment and insurance segments in
2024
Key performance indicator by
business segment
Revenue
Share of total
Group
revenue
(A))
Revenue-
based key
performance
indicator
(B)
Capital
expenditure
(CapEx)-based
key
performance
indicator
(C)
Weighted
revenue-
based key
performance
indicator
(A×B)
Weighted
CapEx-based
key
performance
indicator
(A×C)
Asset management
51,454,450
3.69%
1.51%
2.47%
0.06%
0.09%
Insurance
1,341,754,919
96.31%
5.13%
5.13%
4.94%
4.94%
- non-life insurance
1,186,349,643
85.15%
5.13%
5.13%
- health insurance
55,139,550
3.96%
0.00%
- life insurance
100,265,726
7.20%
0.00%
Total
1,393,209,369
100.00%
Average key performance indicator
5.00%
5.03%
10.3 Social aspects
The Triglav Group considers social aspects as a key part of sustainable development and the
long-term resilience of its business model. It is committed to ensuring a supportive, inclusive and
safe working environment, fostering employee development and well-being, on the belief that
motivated and skilled employees underpin an excellent client experience and the Group’s
success. It also builds trust and long-term relationships by delivering high-quality, secure client
services, responsibly developing insurance and financial solutions, and communicating
transparently.
10.3.1 S1 Employee care
62
S1 disclosures cover fixed-term and permanent employees, as well as external contractors
providing services under civil law contracts, such as work contracts and copyright work contracts.
Employee care and long-term well-being are key strategic priorities for the Group. Focus areas
include a safe and supportive working environment, health and safety at work, equal
opportunities, pay equity, and a culture of diversity, inclusion and non-discrimination,
recognising work-life balance as a positive influence. Key opportunities are providing stable and
secure employment, fair and transparent pay, competence and leadership development, and
flexible or hybrid working arrangements that enhance employer attractiveness, talent retention
and productivity.
The Group addresses positive effects and opportunities through development activities, culture
management and well-being programmes at Group level. Their impact is monitored via turnover
and absenteeism data, as well as employee satisfaction, engagement (ORVI) and
ambassadorship (eNPS) metrics.
The Group carries out various initiatives to develop and support employees. An annual interview
system is in place under which employees, in agreement with their supervisors, set yearly goals
and identify competences for further development. As part of the annual performance review, a
single common "competence of the year" is defined for all employees to support the target
organisational culture. In 2025, this competence was "decision-making". By the end of 2025, the
approach was simplified so that, alongside this competence, employees also focus on developing
one additional competence, supported by the Group through internal and external training.
62
S1.SBM-3_01, S1.SBM-3_02, S1.SBM-3_04, S1.SBM-3_05, S1.SBM-3_12.
171
Targeted development activities are particularly relevant for certain employee groups.
Competence development, mentoring, and development and training programmes are
prioritised for young, high-potential employees, key profiles and those on specific career paths.
Leadership development measures primarily support managers. Well-being and work-life
balance activities, including flexible and hybrid working arrangements, are especially important
for employees with family responsibilities or those in roles with higher workloads or specific
work organisation needs.
Strategic employee management guidelines and the recruitment policy
63
Among its strategic guidelines for employee management, the Triglav Group prioritises
attracting, retaining and systematically developing talent. To achieve this, it continuously
improves selection procedures and seeks to harmonise HR processes by implementing minimum
standards
64
and transferring best practices across the Group. Simultaneously, it builds a unified
organisational culture based on constructive behaviour, teamwork, initiative, accountability and
cooperation, while systematically strengthening its employer brand.
The Group has established policies addressing key employee-related matters, including
occupational health and safety, equality, inclusion, professional development and work-life
balance. These policies are grounded in respect for human rights, employee dignity, and
compliance with local and international legislation. Key policies adopted at Group level include:
Policy on the Management of Key High-Potential and Young High-Potential Employees;
Employee Development and Care Policy; Succession Policy for Management Members of Triglav
Group Companies; Policy on Specialised In-House Training; and Remuneration Policy for the
Members of the Supervisory and Management Bodies of Group Subsidiaries. These policies are
implemented in Group companies, adapted to the specifics of each company and local
legislation, and monitored through the minimum standards system (Minimal Standards Apps),
under which the parent company reviews and updates standards with relevant functions.
65
The
Triglav Group currently has no specific policies or dedicated commitments aimed at the inclusion
of and/or positive action for employees from groups at increased risk of vulnerability. Any
further directions in this area will be addressed as part of the continued development of the
Group’s human resources practices.
Human rights commitments and approach to respecting the rights of the workforce
66
Respect for the human rights of employees and other stakeholders is embedded in the Triglav
Group Code, which serves as the central ethical document and foundation of corporate culture.
A safe and healthy working environment underpins high-quality work; the Group identifies and
manages risks through appropriate measures, training and internal communication. Employees'
rights to participate in management and trade union activities are respected, and any violations
are addressed through pre-defined procedures that ensure confidentiality and protection for
whistleblowers.
The Group companies have adopted Rules on the Protection of Workers' Dignity at Work, which
establish the role of a confidant as a contact point for alleged human rights violations,
harassment, discrimination or bullying. Employees also have the option to report violations to
their supervisor, the HR function or the Compliance Department. Reports, including the
63
S1.MDR-P_01-06, S1-1_01, S1-1_03, S1-1_04, S1-1_05, S1-1_06, S1-1_07.
64
The Minimum Standards of Zavarovalnica Triglav for the operations of subsidiaries constitute a single document of
minimum business standards for subsidiaries, designed to ensure the harmonised implementation of ZT’s standards
and the continuous supervision of their adoption and application.
65
S1.SBM-3_01-02.
66
S1-1_03, S1-1_04, S1-1_05, S1-1_06, S1-1_07.
172
whistleblower's identity, are treated confidentially, and whistleblowers are protected from
retaliation in accordance with internal regulations, including the Whistleblower Protection
Rules. Reports may also be submitted via the Code violation reporting app:
https://prevare.triglav.eu/whistleblower/#/zt.
The Company is a signatory to the Commitment to Respect Human Rights in Business and
complies with the UN Guiding Principles on Business and Human Rights (UNGPs) and the
fundamental principles and rights at work (ILO).
Engagement with employees and their representatives.
67
The Triglav Group strengthens direct cooperation with employees and their representatives,
taking into account employee views, identified through various mechanisms, when making
decisions and managing impacts on employees. Cooperation occurs both directly (e.g. regular
surveys, feedback, annual interviews and internal communication channels) and via
representative bodies.
At Zavarovalnica Triglav, representativeness is ensured through trade unions and the Works
Council, while employee management rights are exercised in line with the Worker Participation
in Management Act and the Agreement on Employee Participation in the Management of
Zavarovalnica Triglav. Engagement also takes place through structured social dialogue,
collective agreements and mechanisms enabling employee representatives' participation in
management bodies, where relevant. The companies of the Triglav Group operate in different
jurisdictions and are subject to the applicable local legislation governing employee
representation. As a result, control mechanisms and formal forms of employee representation
vary between individual companies (e.g. works councils, trade unions or other legally provided
forms). At the level of the Triglav Group, a governance framework is in place to ensure the
implementation of social dialogue as part of the corporate governance system. This framework
includes formalised communication channels with employee representatives, collective
agreements and other forms of cooperation with management or the Management Board,
where relevant and in compliance with local regulations.
The Group monitors employee satisfaction and engagement using ORVI and eNPS. Operational
responsibility for employee engagement lies with the Human Resource Management Division,
with ultimate responsibility resting with the relevant Management Board member. A detailed
description of the ORVI survey and results is provided in the Employee Satisfaction section.
Initiatives for employees and monitoring of effects
68
The key umbrella programme for managing impacts, risks and opportunities, and strengthening
employee satisfaction at Zavarovalnica Triglav is Triglav.smo. It covers health and well-being
activities (e.g. health days, active breaks, psychosocial support) and measures to support work-
life balance (e.g. benefits under the Family-Friendly Enterprise certificate and, where possible,
hybrid working), including activities for employees' children and networking events. Individual
Group companies may offer different benefits depending on local circumstances and financial
capacity.
The Group focuses particularly on managers and key and high-potential employees. In 2025, the
Group-level Leadership School was launched, providing systematic leadership training and
coaching. Development of young high-potential employees identified in 2024 continued, with
the completion of the eight-month Triglav International Business Academy in May 2025 and the
67
S1-2_01, S1-2_02, S1-2_03, S1-2_04, S1-2_06, S1-2_07.
68
S1-4_02, S1-4_03, S1-4_04, S1-4_07, S1-4_09.
173
launch of development mentoring programme in autumn. Induction mentoring is provided for
new hires, and mobility within and between Group companies is encouraged where aligned with
business needs and employee development paths.
Employee development is further supported through learning, knowledge sharing and idea
generation. Access to knowledge is expanded via e-learning; in 2025, the Group-level unified e-
learning platform was in its final implementation phase. The Ideja.In system at Group level
enables employees to submit improvement proposals in the Gecko HRM module, which are
reviewed and implemented if positively evaluated. Zavarovalnica Triglav also introduced the
"One Hour Colleague" system to strengthen networking and knowledge transfer and began
piloting a digital mentoring system in 2025, with plans to extend both solutions to all Group
companies in 2026.
The effectiveness of measures is monitored using a combination of indicators (e.g. ORVI, eNPS,
turnover, absenteeism, training, accidents at work, pay gap) and through the implementation of
action plans across organisational units. Strategic indicators are monitored as part of the Group's
strategy monitoring, while operational indicators are reported to the management of the
companies and the parent company at least annually in accordance with minimum standards.
The Group focuses its ongoing activities on developing data and digital competences, enhancing
user-friendly HR processes, developing key and high-potential employees, strengthening
organisational culture, advancing hybrid working methods and gradually overhauling
remuneration systems. Targeted budgets and resources are allocated for the implementation of
initiatives, particularly for training and development, health and well-being programmes,
employee benefits and psychosocial support, which are updated annually to meet current needs.
The Company has established procedures to take action and remedy consequences in the event
of significant impacts on employees or other stakeholders. When violations are reported (e.g.
regarding personal data protection, discrimination, harassment or other violations), relevant
internal procedures are activated, including recording the report, assessing the circumstances,
notifying the competent functions, implementing corrective measures and monitoring their
effectiveness. A business continuity and crisis management system is also in place. During the
reporting period, no significant impacts occurred that required remedial action. Based on the
minimum standards, the companies have adopted an internal policy on the prevention and
handling of inappropriate conduct and have appointed a responsible person.
10.3.1.1 Employee composition
The Triglav Group had 5,155 employees as at 31 December 2025, down by 49 over the preceding
year. The number of employees decreased primarily due to organisational changes following
the merger of Triglav, Zdravstvena zavarovalnica with Zavarovalnica Triglav. Further reductions
occurred at Triglav Osiguranje, Banja Luka and Triglav Savetovanje, Belgrade, with smaller
decreases at Zavarovalnica Triglav and other Group companies.
174
The number of Triglav Group employees at the end of 2025
A total of 50% of all Group employees are employed in Slovenia, down by 0.4 percentage points
relative to the preceding year. The share of employees in Serbia increased the most (by 0.6
percentage points). The majority, i.e. 87.2%, of all employees worked in the insurance activity.
Employees by Triglav Group market by gender at the end of 2025*
69
2025
2024
Women
Share
Men
Share
Total
Share
Women
Share
Men
Share
Total
Share
Slovenia
1,375
26.7%
1,200
23.3%
2,575
50.0%
1,405
27.0%
1,216
23.4%
2,621
50.4%
Serbia
546
10.6%
296
5.7%
842
16.3%
526
10.1%
292
5.6%
818
15.7%
Bosnia and
Herzegovina
259
5.0%
252
4.9%
511
9.9%
278
5.3%
259
5.0%
537
10.3%
Croatia
325
6.3%
241
4.7%
566
11.0%
331
6.4%
236
4.5%
567
10.9%
Montenegro
190
3.7%
190
3.7%
380
7.4%
191
3.7%
187
3.6%
378
7.3%
North Macedonia
170
3.3%
111
2.2%
281
5.5%
170
3.3%
113
2.2%
283
5.4%
Triglav Group
2,865
55.6%
2,290
44.4%
5,155
100.0%
2,901
55.7%
2.303
44.3%
5,204
100.0%
*A representative number of employees is disclosed in the Accounting Report section 2.1.3, which provides the comparable figure for employees.
Employees by Triglav Group activity at the end of 2025
The proportion of employees with at least level VI education according to the Bologna Process
study programmes has been steadily increasing, up by 0.6 percentage points in 2025.
69
S1-6_01, S1-6_02, S1-6_04, S1-6_05, S1-6_17, SBM-1_03.
5.155
5.204
5.318
202520242023
Insurance
4,496 (87.2%)
Asset
management
144 (2.8%)
Other
515 (10.0%)
175
Proportion of employees at the Triglav Group with at least level VI education according to the
Bologna Process study programmes at the end of 2025
Employees at the Triglav Group and Zavarovalnica Triglav by type of employment (full-time, part-
time) at the end of 2025
70
Triglav Group
Zavarovalnica Triglav**
2025
2024
2025
2024
Women
Men
Women
Men
Women
Men
Women
Men
Type of employment by working
time
Part-time*
160
83
157
81
50
20
50
20
Full-time
2,705
2,207
2,435
1,998
1,068
1,009
1,114
1,039
Total
2,865
2,290
2,901
2,303
1,118
1,029
1,164
1,059
Type of employment agreement
Fixed-term
375
228
389
234
10
14
17
15
Permanent
2,490
2,062
2,512
2,069
1,108
1,015
1,147
1,044
Total
2,865
2,290
2,901
2,303
1,118
1,029
1,164
1,059
* The data for 2024 have been revised due to a technical data entry error in TOZG. The comparative data for 2024 have been updated. In the 2024 report, the
figures for the number of part-time and full-time employees at Triglav Osiguranje, Zagreb were inadvertently reversed. The updated comparative figures for
2024 are: part-time 326 and full-time 550. The change affects only the breakdown by working time; the total number of employees (876) remains unchanged.
** The data for Zavarovalnica Triglav, d.d. have not been audited.
The turnover rate
71
at Group level decline to 12.5% (2024: 16.5%) and to 6.1% at Zavarovalnica
Triglav (2024: 10.6%). A total of 591 new employees were hired in 2025; most new hires were
aged between 20 and 30 years. A total of 645 employees left; most leavers were aged over 56
years (due to retirement) and 41–45 years.
The most common reasons for leaving are retirement, failure to meet expectations in annual
and quarterly interviews, and a desire to pursue career development in other work
environments. However, turnover is largely driven by retirements due to an ageing workforce.
The Company does not employ any employees without a guaranteed minimum or fixed number
of working hours.
72
Employee data refer to the total number of employees (headcount) on the last day of the
reporting year at Group level. These data include all employees of the Company and its
subsidiaries. Indicators per employee are calculated using the average number of employees
during the year, determined as the average of the number of employees on the last day of the
70
S1-6_07, 08, 09, S1-6_18–20.
71
S1-6_11–12.
72
S1-6_07.
60.7%
60.1%
59.0%
202520242023
176
reporting year and the last day of the previous year. Metrics based on full-time equivalents are
disclosed separately.
73
10.3.1.2 Employee training and development
Education and training at the Triglav Group is planned in cooperation with managers, who
identify employee needs, and in accordance with strategic guidelines. Knowledge and skills are
developed through annual interviews (setting goals, competences and training plans), in which
100% of employees at Zavarovalnica Triglav participate, mandatory and recommended training,
professional consultations, mentoring and coaching programmes, external training and e-
learning via learning platforms. In 2025, the annual interview system and competence model
were further upgraded, and the Leadership School programme for managers was also rolled out
to subsidiaries. Development of high-potential young employees continued through TIBA and
mentoring programmes.
74
The total number of functional training hours at the Company was higher than in 2024 (index
108). Average participation was 34 hours at Group level and 51 hours at Company level.
75
Average number of hours of functional training per employee in 2025*
2025
2024
Triglav Group
Zavarovalnica Triglav
Triglav Group
Zavarovalnica Triglav
Women
33
51
33
44
Men
35
52
33
47
Total
34
51
31
46
* The data for Zavarovalnica Triglav, d.d. have not been audited.
The Group training costs amounted to EUR 2.9 million, representing a 10% increase compared to
2024.
76
Employees are encouraged to continue their formal education. Work study was funded
for 161 Group employees and scholarships were provided to 56 pupils and students. A total of
80 students and pupils completed obligatory work placement, while nine young employees
completed traineeship under the guidance of mentors. The Spring School specialised in-house
training was attended by 36 subsidiary employees. Collaboration with faculties and schools was
actively pursued, strengthening the Group's employer brand recognition among young
generations.
10.3.1.3 Occupational health and safety
77
Occupational health and safety is managed by the Company through the Safety Statement and
Risk Assessment. This document identifies all hazards and risks that employees may encounter
in the course of their work and in the work environment. The statement includes measures to
prevent and minimise these risks.
78
Workplace risk assessments are regularly reviewed, with
actions updated and employees and occupational medicine specialists directly involved. Based
on the risk assessment, employees are referred to periodic medical examinations and every new
hire is required to undergo a statutory medical examination before commencing employment.
Participation in training and passing a test on fire safety and occupational health and safety are
mandatory for employees. Safe working conditions at the parent company are defined in the
73
S1-6_13–15.
74
S1.MDR-A_01–05, S1-1_22, S1-13_01–02.
75
S1-13_03-04.
76
S1.MDR-A_06.
77
S1-4_20.
78
S1-1_09.
177
collective agreement and the applicable legislation, while the subsidiaries adhere to the
applicable local legislation.
The Company ensures occupational health and safety through a comprehensive and strategic
approach. To control and minimise risks, several activities are implemented, including strict
compliance with sectoral legislation, provision of personal protective equipment, appropriate
working conditions, ergonomic design of workplaces, and awareness-raising and training for
employees. Many of these activities are part of the Family-Friendly Enterprise certificate, further
contributing to employee satisfaction and better health.
79
In addition, the goal is to identify,
mitigate and manage risks arising from duties and the work environment. Employees can report
any perceived deficiencies in the health and safety management system to the relevant
departments for remediation. Health promotion is planned and implemented in a targeted and
deliberate manner, based on the most common health issues observed among employees, as
well as anonymous occupational medicine reports.
The occupational health and safety system and health promotion are implemented by
subsidiaries in line with minimum standards, local legislation and their financial capabilities.
80
Accidents at work
The number of accidents in the Group remains low relative to the number of employees. A small
increase was recorded in 2025. A total of 12 accidents were recorded in the Group, with seven
occurring in the parent company. The number of lost work days also increased due to a higher
number of accidents and greater absenteeism. The Group companies have not yet reported on
any work-related ill health, nor have any work days been lost as a result. No fatalities due to
work-related injuries were recorded.
81
Injuries at work at the Triglav Group and Zavarovalnica Triglav*
82
2025
2024
Index
Triglav Group
Number
Proportion (%)
Number
Proportion (%)
2025/2024
At work
9
75.0
7
70.0
129
On business trips
3
25.0
3
30.0
100
Total
12
100.0
10
100.0
120
Zavarovalnica Triglav
Number
Proportion (%)
Number
Proportion (%)
2025/2024
At work
4
57.1
0
0.0
0
On business trips
3
42.9
1
100.0
300
Total
7
100.0
1
100.0
700
Lost work days and lost time incident rate due to injuries at work at the
Triglav Group and Zavarovalnica Triglav
83
Index
2025
2024
2025/2024
Triglav Group
Lost work days due to work-related injuries
329
289
114
Lost time incident rate – LTIR*
1.16
0.96
121
Zavarovalnica Triglav
Lost work days due to work-related injuries
179
5
3,580
Lost time incident rate – LTIR*
1.57
0.22
728
* The number of work-related incidents/total number of hours of all employees x 1,000,000. The figure for 2023 was adjusted
due to a change in methodology.
** The data for Zavarovalnica Triglav, d.d. have not been audited.
79
S1.MDR-A_01–04, S1-4_11.
80
S1-14_01-03.
81
S1-14_06–07.
82
S1-14_04-05.
83
S1-1_14-07.
178
Each injury which would render an employee unfit for work for more than three working days,
each dangerous occurrence and each established occupational disease must be reported to the
Labour Inspectorate of the Republic of Slovenia. The Group's absenteeism rate was slightly
higher than the previous year, at 4.47% (4.38% a year earlier). The share of absenteeism for which
sickness benefits are borne by the employer increased by 0.02 percentage points (medical leave
up to 30 days), while the share of lost work days for which benefits are borne by other
organisations increased by 0.08 percentage points (medical leave longer than 30 days, sick
nursing, accompanying a sick person). The absenteeism rate at the Company was slightly higher
and stood at 5.22% (compared to 4.95% the year before). As a result, the share of work days lost
borne by the employer fell by 0.02 percentage points, whereas the share of work days lost borne
by other organisations increased by 0.29 percentage points.
10.3.1.4 Equal treatment and opportunities for all
84
Respect for workers' rights and human rights are fundamental ethical principles defined in the
Triglav Group Code. The Group consistently respects and protects the internationally recognised
human rights and fundamental freedoms, which comply with the UN's goals and principles and
originate from the Universal Declaration of Human Rights, and the fundamental rights as
defined in the International Labour Organization's Declaration on Fundamental Principles and
Rights at Work.
85
The key policies that help manage equal opportunities include: the Triglav Group Code, which
expressly prohibits discrimination based on race and ethnic origin, colour, gender, sexual
orientation, gender identity, disability, age, religion, political opinion, or national or social origin;
the Rules on the Protection of Workers' Dignity at Work, which provide detailed guidelines on
identifying, preventing and remedying discrimination, harassment and mobbing in the
workplace; the Rules on the Handling of Violations of the Triglav Group Code; and, at the
Company, the Diversity Policy. In addition to the Triglav Group Code, the Group companies
operating outside Slovenia also comply with local legislation and the Company's minimum
standards. Internal resolution mechanisms are used, and violations of the Code are reported
directly to the Company's Compliance Office.
86
Zavarovalnica Triglav implements measures to ensure equal opportunities and the inclusion of
potentially more vulnerable employee groups (e.g. persons with disabilities, older workers,
young people and parents of young children). These commitments are fulfilled through job and
task adjustments, the option of reduced working hours and, where appropriate, working from
home. As a holder of the Family-Friendly Enterprise certificate, the Company enables flexible
forms of work and takes into account statutory restrictions on overtime work for parents of
young children and older workers. Employees are also enabled to exercise their statutory rights
to family-related leave (e.g. maternity, paternity, parental and carer's leave). The Group monitors
employee awareness of existing structures and processes, as well as trust in them, through
regular feedback. At Group level, ORVI also assesses psychosocial risks and aspects of equal
treatment, including whether employees know whom to contact in cases of pressure, conflicts
or other issues. Where scores are unfavourable, targeted reviews are carried out and corrective
measures are defined.
84
S1-1_10, S1-1_11, S1-1_12, S1-1_13, S1-3_02, S1-3_05, S1-3_06, S1-3_07, S1-3_08, S1-3_09.
85
S1-1_03, S1-1_05.
86
S1-1_04, S1-1_06, S1-1_10, S1-1_11.
179
Employee diversity
87
A diversity policy has been adopted at Zavarovalnica Triglav and at some of its subsidiaries.
Across the Group, the principles of diversity are applied to management and supervisory bodies
and, in practice, also to other areas, supporting a proactive approach to gender equality.
The proportion of women among all employees, both at the Company and Group level, remained
unchanged from last year. Women accounted for 55.6% of employees at Group level and 52.1%
at the Company. The proportion of women on the Management Board of Zavarovalnica Triglav
was 20.0% (2024: 20.0%), on the Supervisory Board it increased to 42.9% (2024: 37.5 %), and in
the management and supervisory bodies of all Group companies it rose to 29.5% (2024: 26.4%).
The average age of employees in the Group remained stable at 45.1 years; at the parent company
it stood at 47.1 years (2024: 46.6 years). The average age of Zavarovalnica Triglav's Management
Board members was 49.8 years. In Slovenia, senior management is hired from the local
community, as is the majority of senior management in markets outside Slovenia.
Employee satisfaction
88
The organisational vitality survey (ORVI) is the Triglav Group's primary annual tool for
monitoring employee satisfaction and engagement. It systematically collects feedback on key
aspects of the employee experience (e.g. the working environment, relationships, personal
development, leadership, information, cooperation, remuneration, career progression) and on
factors affecting well-being and work efficiency.
Following the ORVI, each Group company receives reports at both company and organisational
unit level, with anonymity ensured. The results are presented to the management and
employees; managers discuss them with their teams, jointly identify key strengths and
challenges, and determine priority areas for improvement. Agreed measures, with deadlines, are
recorded in the HR system, and their implementation is monitored as part of routine
management. The Group also uses ORVI to identify psychosocial risks and to verify whether
employees know whom to approach in cases of pressure, conflict or other problems. Where
scores are low, a focused discussion is held with the manager and the HR function, and additional
support (such as coaching) is provided if necessary.
The ORVI index is also one of the Group's key performance indicators (KPIs), with target values
for the 2025–2030 strategy period defined in the Group's strategy. The strategy, together with
key results on organisational culture, ORVI and eNPS, is presented to employees via the intranet
and through additional presentations. The Company's Management Board reviews the results
and adopts overarching measures at Group and parent company levels, which are also
communicated to the human resource management departments at subsidiaries. At the level of
individual companies, measures are determined based on the results, with managers
responsible for discussing the reports with their teams and confirming the implementation of
agreed activities in the HR system.
The 2025 organisational vitality survey (ORVI) showed high levels of employee satisfaction and
engagement. The ORVI index
89
improved for both the Group and the Company, reaching 4.03
and 4.01, respectively. A total of 87% of employees from 16 Group companies participated
87
ESRS 2 GOV-1_05–06.
88
S1-5_01, S1-5_02, S1-5_03.
89
ORVI results are reported on a scale of 1 to 5, where 1 indicates the lowest possible overall rating and 5 the
highest possible overall rating.
180
(compared to 85% the previous year). Once again, employees rated their satisfaction highest in
operational leadership, with the survey also indicating high engagement levels. They feel that
supervisors are transparent, responsive to team needs and provide constructive feedback.
Confidence in their objective assessments of colleagues' work has further increased. Most
managers willingly share knowledge and information, trust each other and prioritise
collaboration over competition. They exchange ideas with their teams and are not afraid to make
mistakes. Employees are satisfied with job stability, working hours and training opportunities.
Fair and transparent remuneration
90
In all employee categories, activities and countries where the Group operates, the basic salary of
men and women is equal. Benefits are the same for all employees, be it permanent full-time
employees, fixed-term employees or part-time employees. All Group employees receive a fair
salary, aligned with the applicable benchmarks in the countries where the Group operates.
Salaries are ensured to comply with local legal requirements, collective agreements and relevant
benchmarks for a decent standard of living.
The gender pay gap is defined as the ratio of the average gross pay of female employees to the
average gross pay of male employees, expressed as a percentage of the average gross pay of
men. The calculation includes all payments made in the reporting year that are borne by the
employer (monthly gross salaries and other taxable income), while reimbursed absences and net
expense reimbursements (meal allowance, commuting allowance, per diems) are excluded.
In 2025, the Group updated the methodology for calculating the gender pay gap to ensure more
consistent and comparable reporting. The update includes a more precise definition of the scope
of payments considered (all gross payments borne by the employer, including other taxable
income). The calculation is based on data processed in a way that does not allow direct
identification of individuals, and comparability is further supported by the classification of jobs
into job complexity groups.
Recalculating the comparative gender pay gap figure for 2024 using the updated methodology
is not feasible, as not all required input data and attributes for 2024 were systematically
collected and archived in a format that would allow the new metric definition to be applied
consistently to the prior reporting period. The Group’s calculation includes salaries paid for the
period from January 2025 (paid in February 2025) to December 2025 (paid in January 2026), as
well as all additional payments made in 2025. The scope of payments included and the reference
period are defined in internal data collection guidelines, ensuring consistency of reporting and
comparability of data across Group companies.
In 2025, the unadjusted gender pay gap at Group level was 27.1% (2024: 27.7%), and 24.8% at
the Insurance Company level (2024: 26.0%). The largest driver of the observed gap is the gender
distribution across job complexity levels. There are more men among managerial employees and
employees in the most demanding roles, as well as in roles requiring a second-cycle university
degree, which include positions in claims assessment, underwriting and IT—technical and scarce
profiles that are more often held by men. A second factor is the variable remuneration model in
sales, which is performed in the field and is also predominantly carried out by men. The table
below shows the gender pay gap by job complexity groups, which reflect four factors: knowledge
and skills, effort, responsibility and working conditions. It also presents the gender distribution,
i.e., the share of men and women by job complexity level.
90
S1-10_01.
181
Ratio of average salaries between male and female employees by job complexity at Triglav Group*
Employee groups by job complexity
Gender pay gap
Men by
group
Women by
group
Senior management and employees in the most demanding jobs
9.8%
11.4%
6.2%
Employees in jobs requiring second-cycle education or equivalent
1.8%
21.5%
21.1%
Employees in jobs requiring first-cycle education or equivalent
-11.0%
17.8%
29.0%
Employees in jobs requiring secondary technical, vocational or general education
4.1%
11.7%
18.2%
Insurance agents earning remuneration based on the premium they generate
45.6%
37.5%
25.5%
* The figures are unaudited.
The Group has a gender-neutral remuneration policy and is committed to ensuring equal pay for
equal work, recognising that gender pay inequality and achieving full pay equity is a broader
societal challenge. Efforts are focused on improving data and analysis to better understand the
pay gap and its underlying causes. Moving forward, efforts will continue to ensure that all
employees – regardless of gender – have equal opportunities for career development and
advancement and are placed in roles with appropriate remuneration.
The annual total remuneration ratio of the highest paid individual to the median annual total
remuneration for all employees (excluding the highest-paid individual) was 15.1 (last year
14.84). It covers the remuneration of all employees, including basic salary, cash allowances,
benefits in kind, long-term incentives and other bonuses (e.g. voluntary pension insurance,
supplemental pension insurance). Amounts in foreign currencies are converted into euros.
91
The Group also provides employees with additional benefits, including supplemental pension
insurance, preferential terms for supplemental accident insurance for employees and their
family members, supplemental accident insurance for business trips, the option to join voluntary
supplemental and voluntary pension insurance after one year of employment with the parent
company, and the group insurance package Comprehensive Medical Care (Celostna zdravstvena
oskrba – CZO). The Group companies operating outside Slovenia provide additional benefits to
their employees in line with local practices (such as voluntary health insurance premium,
discounts on medical examinations, the payment of accident insurance premium and discounts
on other types of insurance).
Work-life balance
Circumstance and work requirements permitting, working hours can be adapted to the needs
and wishes of employees. At Zavarovalnica Triglav and some Group companies, employees
whose nature of work allows it may work from home, with their proportion increasing. At the
end of 2025, 38% of Group employees and 67% of Company employees had this option available
to them. All Group employees are entitled to family-related leave in accordance with applicable
law, the relevant collective agreement and internal company regulations. Employees who are
parents of first graders can take advantage of a day's paid leave on the first school day.
Employees can take unpaid leave in certain cases and in agreement with their supervisors.
92
10.3.2 S4 Clients
The Triglav Group's mission is to provide security, strengthening personal protection and long-
term financial resilience for its clients and the wider community through insurance and
investment solutions. In its ESRS S4 disclosures, the Group focuses primarily on individuals and
end users who benefit from its coverage and services (e.g. beneficiaries and injured parties). It
generates positive impacts through life, health and non-life insurance, as well as savings and
91
S1-16_01–03.
92
S1-15_04.
182
investment solutions that support long-term goals and provide assistance in unforeseen life
situations.
The Group builds long-term relationships based on trust and a thorough understanding of client
needs. It responds to feedback promptly and transparently, using it to improve processes,
product development and the user experience, including through digital solutions and modern
communication channels. Clients are provided with clear product information, and their
personal data and rights are protected. Products are developed and managed in accordance with
approval and regular review procedures, distribution strategies are regularly tested, and
adjustments are made where deviations are identified. Sales are managed centrally across
multiple channels, employing a multi-channel approach to address different target groups.
93
From the perspective of clients and end users, the Group recognises client protection and safety,
privacy protection, and effective and timely claims settlement as key positive impacts. It
identifies opportunities in transparent and inclusive communication, proactive health and
safety solutions, clear eligibility criteria and premium pricing logic, alternative access channels
(e.g. through the network of agents and branch offices) and responsible marketing that
strengthens client trust and loyalty.
The Group's client relations are guided by policies that ensure client protection, secure and
responsible data processing, and clear communication. The Policy on Insurance Product
Governance, Oversight and Distribution directs the development, oversight and distribution of
products with an emphasis on client protection and suitability for the target market. The
overarching information security policy, together with the Privacy Policy, Cookie Policy and
Personal Data Protection Rules, defines the information security system, rules for personal data
processing and transparent communication in line with the GDPR, thereby reinforcing user
confidence. The Triglav Group Communication Code sets out principles for responsible, balanced
and crisis communication, ensuring clarity of information for clients and the general public. The
detailed content and application of individual policies are further described in the relevant
sections on specific impacts and opportunities.
10.3.2.1 Transparent and easy-to-understand products
The Group provides clients with easy access to key information about its products and services,
including factors affecting pricing, enabling them to make informed decisions and select
insurance policies that meet their needs. Insurance and other general terms and conditions are
fair, clear and transparent, with the scope of coverage and associated premium presented
transparently during the sales process.
Products are developed, managed and distributed in accordance with the Policy on Insurance
Product Governance, Oversight and Distribution, which establishes rules and practices for
identifying target market needs and for product development and testing. This ensures that
clients' objectives, interests and characteristics are appropriately taken into account, conflicts of
interest are effectively managed, and products are designed to prevent or mitigate potential
harm. Equal treatment of policyholders is prioritised, and exclusions and premiums are based on
actuarial calculations. The Group does not provide services that would violate human rights. In
Group companies outside the EU, internal regulations are aligned with local legislation.
94
Marketing strategies and campaigns are implemented in compliance with legal and other
consumer protection regulations.
93
S4.SBM-3_06, S4.SBM-3_08, S4.MDR-P_01-06, S4-1_01, S4-2_01–03.
94
S4-1_02, S4-1_03, S4-1_04.
183
10.3.2.2 Transparent and easy communication with clients
95
The Triglav Group aims to establish lasting, high-quality relationships with clients based on
trust, honesty and an understanding of their needs. It responds to changes and requests
promptly, transparently and with a high level of professionalism. Client feedback is treated
responsibly, as it supports the improvement of business processes and the development of new
services, products and comprehensive solutions. The Group enhances the user experience
through digital tools and modern communication channels, while maintaining personal contact
via traditional sales channels. Special attention is given to the protection of personal data and
the provision of clear product information. Products and distribution strategies are regularly
reviewed for suitability and adjusted where deviations are identified. A variety of sales channels
and communication platforms are used to deliver insurance and financial products.
Through its multi-channel approach, the Group seeks to reach all client segments, from younger
to older clients. This is implemented as part of the Group's omni-channel strategy, which aims
to provide clients with a seamless, consistent and comparable experience across different
distribution channels. The strategy allows the Group to better understand client profiles,
purchasing behaviour and responses to sales campaigns, enabling the delivery of personalised
offers and tailored campaigns for different target groups. Improved accessibility to insurance
and financial services, along with enhanced financial literacy, fosters greater client trust and
strengthens the Group's reputation, thereby increasing opportunities for business expansion.
Client satisfaction and loyalty: NPS and feedback
96
The Triglav Group’s strategy focuses on establishing and maintaining stable, long-term
relationships with clients, as its business model is directly linked to their satisfaction, trust and
loyalty. Client experience management is therefore regarded as a key pillar of business
opportunity and risk management. Through systematic dialogue, monitoring of client
touchpoints, and consistent responsiveness, the Group maintains service quality, strengthens
brand reputation and supports portfolio growth.
Client needs, expectations and experiences are monitored continuously and in a structured
manner at key touchpoints, primarily using the Net Promoter Score (NPS) methodology, which
is measured daily. The results are integrated into regular operational activities and reporting.
The NPS is complemented by feedback collected through the complaints and compliments
mechanism, responses on social media and the Group's websites, direct feedback from sales and
advisory staff, and ad hoc marketing research.
Clients can submit complaints via digital channels, branch offices and contact centres.
Complaints are handled in accordance with a predefined procedure, which includes recording,
professional assessment of the content, responses from the relevant departments, and
monitoring the timeliness and quality of resolution. Complaint records are maintained in the
prescribed, predominantly electronic format, enabling traceability, trend analysis and
improvement planning. Negative feedback identified through the NPS is analysed on an ongoing
basis; based on this, the relevant departments contact clients, clarify the circumstances and
implement corrective measures, while responsiveness is regularly monitored and reported to
management.
The Group systematically incorporates feedback into product development and adjustments,
process optimisation and service quality improvement. Effectiveness is assessed using the NPS
and other indicators (e.g. complaints in relation to claims, client retention and growth, and the
95
S4-1_01, S4-1_04, S4-1_09, S4-2_01, S4-2_03, S4-2_05, S4-2_06, S4-4_15, S4-4_16.
96
S4.MDR-T_01–04, S4-2_01, S4-2_02, S4-2_03, S4-2_04, S4-2_05, S4-4_09, S4-4_12, S4-5_01, S4-5_02, S4-5_03,
S4.MDR-A_01_12, S4.MDR-T_01-13.
184
reputation index). Management is supported by clearly defined responsibilities and appropriate
resources: the Client Experience Section leads data collection and analysis and monitors the
implementation of measures, while the relevant departments are responsible for implementing
the measures. Objectives are linked to measurable indicators and are regularly adjusted based
on feedback, thereby involving clients in target-setting and performance monitoring.
In 2025, the Group maintained a high level of client satisfaction despite challenges such as
market changes and price adjustments. The NPS index for the Triglav Group reached 77 (2024:
70) and for Zavarovalnica Triglav it reached 76, representing an increase of 10 points relative to
the preceding year, mainly due to the merger of Triglav, Zdravstvena zavarovalnica into the
parent company. Client satisfaction with healthcare service providers is measured at the
Zdravstvena točka health information office, with scores consistently exceeding target values.
The Group prepares a client satisfaction report twice a year. This report tracks policyholder
complaints and compliments, and helps drive actions for improvement.
The NPS is calculated in accordance with a standard, established methodology; however, it is not
designed as an indicator primarily monitored against a formally defined base year or base value.
As a rule, it is used to monitor the current situation and trends over time. The NPS target value
is set as a threshold, meaning that the NPS must exceed a predefined value. Relevant
stakeholders, including clients and their representatives, are involved in the target-setting
process, as outlined in the context of the double materiality assessment process and in the
stakeholder engagement table. There were no changes to the targets or the measurement
methodology during the reporting period.
10.3.2.3 Access to services
With a wide range of digital solutions supported by a multi-channel sales and support network
both in Slovenia and abroad, the Group provides clients with broad service accessibility, fast and
simple remote handling of matters, and an improved user experience throughout the entire
insurance and investment lifecycle – from information and contract conclusion to claims
reporting, assistance, prevention and transparent investment management.
97
The services of
Zavarovalnica Triglav and Triglav Investments are available to clients via toll-free telephone
numbers and email, with call centres also operating abroad. The Group upgraded its TRIA virtual
assistant to use artificial intelligence, enabling more natural and flexible communication.
Digital solutions enable clients to manage their affairs easily and enhance the user experience.
Through the i.triglav digital office (also available as a mobile application), clients can manage
most insurance-related activities, including taking out or renewing insurance, reporting claims,
tracking claim status and ordering assistance. In parallel, the Group enables claims submission
through multiple digital channels, electronic signing of documentation and remote inspection
of the insured object using modern technologies, further accelerating and simplifying
procedures.
Through the DRAJV mobile application, the Group promotes safe driving by rewarding users and
offering functionalities that support safer route planning, while the Triglav vreme application
provides reliable weather information and alerts. In CAT events, mobile assessment units are
deployed to enable rapid inventory and damage assessment in affected areas.
Investors have access to mobile and online solutions for transparent investment management
and up-to-date financial market content, while in the field of health insurance the Group also
provides remote consultations with specialists. Triglav Lab further strengthened prevention
97
S4.SBM-3_05.
185
activities through a safe driving simulator, enabling safe learning and testing of responses in
unforeseen situations.
Digital channels as a complement to traditional sales
98
Digital channels at the Triglav Group complement traditional sales channels (insurance agents,
branch offices and contractual partners) and enable effective business with clients who are
proficient in digital tools and prefer this mode of communication, which is particularly relevant
for younger and more digitally literate clients. Access to services is further enhanced by the
adaptation of points of sale for people with various disabilities, with most points of sale in
Slovenia being accessible and equipped with aids for the visually impaired, and with the
headquarters of all six regions also equipped with aids for the hearing impaired.
Call centres play a key role in providing clients with information and support when branch office
visits are not possible. The Group's presence in multiple markets enables locally tailored services
and strengthens trust through greater proximity and accessibility. Feedback systematically
collected by call centres on client satisfaction, needs and issues is used to improve products,
processes and the user experience, as well as to adapt products, services and distribution
strategies.
The multi-channel sales approach thus plays a strategic role in ensuring a comprehensive user
experience and compliance with regulatory requirements, while strengthening the resilience of
the business model and adaptability in a changing market environment. By expanding access to
insurance and financial services, including in less populated areas and economically less
developed regions, as well as to vulnerable groups, and through financial literacy activities via
workshops, training and partnerships, the Group helps clients better understand financial risks
and opportunities and provides high-quality support for financial security at all stages of life.
Zavarovalnica Triglav adapts its services and business premises to people with various
disabilities, thereby supporting independence and social inclusion. At its points of sale, solutions
are provided to facilitate easier access and ensure equal treatment of clients, including
appropriate arrangements of reception areas. Branch offices are equipped with aids for the
visually impaired, and regional offices provide support equipment for the hearing impaired.
Accessibility and inclusion are further strengthened through cooperation and partnerships with
organisations focused on disability and safe mobility.
10.3.2.4 Client protection: privacy, data security and information security
All Group employees, including those involved in insurance sales, are committed to protecting
personal data and maintaining information confidentiality in accordance with legal
requirements and internal regulations. Training on information security and personal data
protection is mandatory for employees of Zavarovalnica Triglav and is delivered via an e-learning
platform, followed by a test. Employees who pass the test receive a certificate of completion.
Hours completed in these areas are included in the required professional training hours under
Article 564 of the Insurance Act (ZZavar-1).
The Group's information security strategy defines strategic objectives, principles and measures,
with a focus on managing information security risks associated with assets managed by the
Company and identified incidents. The aim is to establish a robust cyber resilience framework
that ensures technological security, optimal performance and rapid recovery from breaches and
incidents, while maintaining the highest level of information security (confidentiality, integrity,
98
S4-1_01, S4-2_01, S4-2_03, S4-2_05, S4-2_06, S4-4_09, S4-4_12, S4-4_16.
186
authenticity and availability) of data. The Group is committed to IT standards and best practices
in information security, including personal data protection.
Privacy is governed by the Personal Data Protection Rules, along with more detailed rules for the
lawful processing of data in specific business segments. Information security is governed by the
Company's Overarching Information Security Policy, which defines the basic requirements for
establishing, operating, monitoring, maintaining and improving the information security
management system. Both the Personal Data Protection Rules and the Overarching Information
Security Policy are part of the minimum standards for the Group's subsidiaries. The parent
company provides advisory support, monitors implementation and oversees the review of
personal data processing agreements among Group members.
At the Company, the Privacy Policy and related internal acts are regularly reviewed, along with
the list of categories of processors and controllers and cookie policies. Special attention is given
to reviewing the personal data protection information for individuals engaging in business with
the Company through foreign entities. Before entering into agreements, the adequacy of
personal data protection for business partners involved in data processing is assessed. The
Company prioritises a comprehensive and documented ICT risk management framework, which
includes internal ICT protocols and tools to ensure the adequate protection of all IT and ICT
assets, as well as relevant physical components and infrastructure.
99
The Company processes requests from individuals to exercise their personal data protection
rights, maintains records of data breaches and monitors the implementation of compliance
measures across both the Company and the Group. All Group companies have designated
personal data protection officers or coordinators.
Across the Group, 71 substantiated reports of privacy and data breaches, including personal data
loss, were identified. Of these, 70 were substantiated complaints at the Company, with 44
arising from the conduct of insurance business in the Polish market. No material sanctions for
non-compliance with personal data protection regulations were imposed on the Group. In
response to identified breaches, the internal control system is being upgraded to prevent future
incidents.
Data privacy and security are regularly communicated to employees, with ongoing training that
must be periodically renewed.
10.3.2.5 Efficient and timely settlement of claims
100
Efficient and timely claims settlement represents a significant positive impact of the Group on
its clients, as the key value of insurance services is realised when a loss event occurs. An
accessible, clear and predictable claims process reduces administrative barriers, enables the
prompt handling and settlement of claims, and helps mitigate the financial and social
consequences of loss events for clients, thereby enhancing their social and economic resilience.
The Group emphasises simple claims reporting through multiple channels and the rapid
assessment and handling of cases. Procedures are continuously improved based on systematic
monitoring and consideration of client feedback, aiming to reduce barriers and ensure the most
understandable and effective user experience for different client groups.
Service accessibility is further strengthened through a range of digital solutions and sales
channels, facilitating easier interaction with the Group and broader access to services. Clients
99
S4-4_01.
100
S4-2_01, S4-2_03, S4-2_05, S4-4_12, S4-4_16, S4-4_18, S4.MDR-T_01-13.
187
can submit claims via multiple digital channels (e.g. website, mobile app, B2B links and i.triglav)
and electronically sign documents and assistance requests without the need to make phone
calls. This reduces barriers, accelerates claims processing, and contributes to a clearer and more
efficient user experience.
In CAT events, mobile assessment units are deployed to enable rapid inventory and damage
assessment in the field. For example, following hailstorms in Slovenia in 2025, six mobile units
conducted more than 2,500 assessments, accelerating case handling and reducing process
bottlenecks.
The claims process is further expedited by remote inspections, where the insured object can be
examined using smartphones, drones, 360° cameras and OCR technology. This approach
simplifies and shortens claim reporting and inspection procedures while allowing clients to
participate in a more flexible and time-efficient manner.
The Group is committed to continuously improving service accessibility and the efficiency and
quality of claims handling, with particular focus on addressing recurring causes of dissatisfaction
and complaints.
10.3.2.6 Respect for human rights
101
The Triglav Group Code is the Group's central ethics document and commits employees to
uniform standards of conduct towards all stakeholders, including the insured, policyholders and
insurance beneficiaries. The core of the Code consists of ethical principles that promote fair
conduct, transparent operations and communication, responsible care for stakeholders and risk
management. The Company is also committed to complying with the Insurance Code, which
requires that business with clients be based on mutual trust and the protection of clients' rights
and interests, in accordance with the rules and principles of the insurance industry. When
concluding insurance contracts, it ensures equality and equal treatment of all clients and
policyholders, except where deviations are justified by the subject matter of insurance. The
policies apply to all clients, while subsidiaries outside the EU adhere to local legislation and the
minimum standards set by the parent company.
Measures to ensure access to legal remedies and redress for violations
102
The procedure for filing and handling client complaints is governed by rules available on the
Company's website. These rules define the stages of the complaint procedure and the
responsibilities of the parties involved. Clients are also informed about the possibility of filing a
complaint through insurance documents and the Company's websites. A report on complaints
and compliments is prepared annually for management, including proposals for measures to
improve procedures and processes. Records of complaints are maintained in the prescribed form,
generally in electronic format Clients who are dissatisfied with the decision are offered
mediation at the Mediation Centre of the Slovenian Insurance Association, with the insurer's
participation being mandatory. In addition, complaints may be lodged with the Ombudsman of
Good Business Practices in Insurance (for matters related to good business practices). For
disputes regarding compensation claims, judicial protection is available, and clients may also
resolve disputes through arbitration at Zavarovalnica Triglav, provided the parties enter into an
arbitration agreement. Subsidiaries follow procedures adapted to local regulations, while in
countries outside the EU, the minimum standards of the parent company are applied.
101
S4-1_03.
102
S4-1_05.
188
Compliance with international instruments and cases of non-compliance
103
The Company is a signatory to the Commitment to Respect Human Rights in Business and
adheres to the UN Guiding Principles on Business and Human Rights (the "Protect, Respect and
Remedy" framework). Respect for human rights is embedded in the values and principles of the
Triglav Group Code, which refers to the Universal Declaration of Human Rights and the
International Labour Organization Declaration on Fundamental Principles and Rights at Work.
The Company has appointed a Human Rights Officer responsible for integrating respect for
human rights into values and practices, conducting due diligence to identify key risks,
monitoring and reporting, raising awareness among employees and stakeholders, and
promoting respect for human rights among business partners. Mechanisms were established for
reporting violations, protecting whistleblowers from retaliation and safeguarding their identity.
Respect for human rights is also included as a standard in the minimum standards applicable to
subsidiaries.
In 2025, no violations of human rights or the principles of the UN, the ILO Declaration on
Fundamental Principles and Rights at Work, or the OECD Guidelines for Multinational
Enterprises involving clients were identified within the Triglav Group. Similarly, no cases of non-
compliance with these principles relating to clients were identified among key suppliers.
104
10.4 G1 Governance aspects
The Group is aware that by acting legally and ethically and by respecting the fundamental
principles of corporate integrity it maintains its safe operations, reputation and credibility,
ensures efficient governance and strengthens the mutual cooperation and trust of its
shareholders, investors, clients, suppliers, partners and other stakeholders. Efforts are made to
establish appropriate, transparent, clear and up-to-date rules of conduct and procedures,
including mechanisms to ensure legality and compliance.
In the area of governance, the Group recognises that an ethical culture, compliance and integrity
form the foundation of stakeholder trust and serve as key levers for effective governance,
helping to prevent corruption and other unethical behaviour, manage reputation and
operational risks, and ensure the long-term stability of operations. Among the opportunities
identified, the Group notes that a strong ethical culture and consistent adherence to the Code
of Ethics contribute to greater efficiency, business stability and enhanced resilience to
operational and reputational risks. Transparent participation in public policy-making and
effective management of compliance with legislative and regulatory requirements are also
important opportunities. Positive impacts include the prevention of corruption and bribery –
through prevention, training and detection mechanisms – and the promotion of responsible
behaviour in the supply chain. With respect to suppliers, the Group recognises both the positive
effects of promoting responsible business conduct and the opportunities that strong and stable
supplier relationships provide for service continuity and cost stability.
10.4.1 Framework of policies and internal regulations governing business conduct
105
At the Company and the Group, the management of material impacts, risks and opportunities
related to business conduct and corporate culture is supported by a coherent set of mutually
consistent policies and other internal regulations. The Triglav Group Code and the Sustainable
103
S1-4_06-07.
104
S4-1_07.
105
G1.MDR-P_01-06, G1-1, G1-1_01
189
Development Policy serve as the cornerstones, with the Code establishing standards of integrity
and guiding the identification, reporting and handling of potential violations, including the
protection of whistleblowers and the prevention of unfair practices and corruption. This
framework is complemented by the Corruption Risk Management Policy, the Compliance Policy,
the Rules for the Handling of Violations of the Triglav Group Code, the Fraud Management Rules
and the Whistleblower Protection Rules, as well as by regulations governing key support areas
such as contract management, sponsorship and donation partnerships, and procurement
implementation, together with other related internal regulations.
Zavarovalnica Triglav complies with the United Nations Global Compact Slovenia Declaration on
Fair Business and is a signatory to the Commitment for implementing the principles of fair and
ethical conduct and ensuring integrity and transparent business, the Slovenian Corporate
Integrity Guidelines, and the Commitment to Respect Human Rights in Business in line with the
National Action Plan of the Slovenian Ministry of Foreign and European Affairs. Group companies
also comply with the laws of the countries of their registered office, and the practices of the
parent company are transferred to subsidiaries through the Company's Minimum Standards for
Subsidiaries.
106
Corporate culture
107
Corporate culture is defined by the Triglav Group Code, the Group's main ethical document and
foundation. It establishes uniform business and ethical standards for companies, consolidating
the standards of conduct used by the Group. It provides guidance for drafting other internal
documents of Group companies, which must comply with its provisions, and applies to both
governance bodies and all employees. The Triglav Group Code emphasises that engaged, highly
professional and motivated employees are the foundation of sustainable development and
accountability to all stakeholders. The full text of the Code is available on the Company's
website: https://www.triglav.eu/en/about-us/compliance/documents-and-commitments.
The Compliance Office business function administers the Triglav Group Code, ensuring
corporate culture development and continuous communication and employee training on the
ethical standards adopted by the Company and the Group. It also manages the procedure
dealing with Code violations and internal fraud in accordance with the Rules on the Handling of
Violations of the Triglav Group Code, and prepares amendments and upgrades to the Code.
Furthermore, it participates in external activities related to ethical performance and
development, and monitors compliance with the Insurance Code and the Company's other
ethical commitments. The Compliance Office identifies, measures and assesses compliance and
corporate culture risks by evaluating the risk of violations of the Code's core values and ethical
principles. It also maintains a risk register and an internal control register. Compliance risk
assessments are reported to the (operational) risk management body.
In line with the Compliance Policy, all employees receive regular training on compliance risk
assessment, regulatory requirements and other commitments. Compliance development and
implementation across all Group companies are ensured through the preparation of Minimum
Standards for Group subsidiaries, as well as through guidance, expert advice, internal
documents, training materials, regular compliance monitoring in subsidiaries, risk assessments
and targeted reviews. This approach standardises business processes, promotes corporate
culture, and facilitates knowledge transfer and good business practices across the Group's
insurance and financial companies.
108
106
G1-1_12.
107
G1.MDR-P_01, G1-1.
108
G1-1_10.
190
Mechanisms for identifying, managing and taking action in the event of unlawful behaviour
109
The Group has measures in place to protect whistleblowers reporting suspected corruption,
internal fraud or violations of the Code. These measures include safeguarding the
whistleblower's identity, high standards of secure reporting, allowing anonymous reporting and,
where relevant, enabling secure communication with the anonymous whistleblower through an
internal channel. In addition, the reporting channel available at
https://prevare.triglav.eu/whistleblower/#/zt ensures the protection of the confidentiality of
the whistleblower's identity and the proper handling of anonymous reports. Whistleblowers are
provided with immediate assistance in cases of imminent threat, including threats to their life,
personal safety, the safety of family or colleagues, or personal property, with support from the
relevant departments in preventing retaliatory measures. Additional protection measures
include the possibility of transfer to an equivalent position within the organisation, free legal
assistance and advice, support in informing the police and law enforcement authorities, special
protective measures and, where appropriate, sanctions against perpetrators. The Company is
bound by the Whistleblower Protection Act (ZPri), which sets out procedures for reporting and
handling violations, as well as protection and support measures to prevent or eliminate
retaliation. Group companies also comply with the applicable laws of the countries of their
registered office.
In addition to reporting through internal channels, potential non-compliant behaviour is
identified through the activities of key and other control functions during reviews, through the
exchange of information between functions, and through the findings from internal and
external audit and other external bodies. As part of mandatory reporting, organisational units
provide information on detected violations or operational loss events to the compliance function
and the Risk Management Department.
Additional mechanisms are provided in the Rules on the Protection of Workers' Dignity, which
grant the right to report alleged unwanted conduct and ensure that such reports are handled
appropriately, sensitively and confidentially. Procedures include restricting disclosure to persons
not involved in the case, addressing reports without delay, conducting timely investigations,
ensuring fair treatment of all parties, prohibiting false accusations with corresponding
sanctions, and taking action against those engaging in unwanted conduct.
110
Group companies not subject to EU law implement these mechanisms in accordance with local
legislation. In doing so, they also comply with the Group's Minimum Standards for subsidiaries,
which provide a group framework for the transfer and implementation of key governance
mechanisms.
In 2025, Triglav Group handled 7 cases of breaches of the Code and 35 cases of suspected internal
fraud, of which 2 breaches of the Code and 20 internal fraud cases were confirmed. Compared
to 2024, when the Group handled 20 reports of alleged breaches of the Code and 10 reported
suspicions of internal fraud (13 Code breaches and 9 internal fraud cases confirmed), 2025 saw
fewer handled and confirmed breaches of the Code, while there were more reported suspicions
of internal fraud and more confirmed internal fraud cases.
Corruption risk management and business integrity
111
The Triglav Group's Corruption Risk Management Policy comprehensively defines the system for
the prevention, identification and handling of behaviour involving elements of corruption, and
109
G1-1_02; G1-1_08, G1-1_12
110
G1-1_05.
111
G1.MDR-A_01–12, G1-1_08, G1-1_11, G1-3_01, G1-3_06, G1-3_02, G1-3_03, G1-3_08.
191
sets minimum standards of conduct in procedures where a corruption risk is identified. The
Policy is also implemented in subsidiaries and imposes a duty of proactive behaviour on
employees – including reporting suspected corruption and participating in the handling of cases
– to strengthen controls and manage these risks more effectively. Policy requirements are
integrated into key business and contractual procedures: potential risks are screened before
entering into cooperation, anti-corruption clauses (e.g. anti-corruption clause, conflict of interest
clause, restrictive covenants, anti-fraud clause, reputational clause, human rights clause,
protection of personal data, and clauses on inside information and business secrets) are
mandatory in contracts, and procedures are in place to monitor compliance during the period of
cooperation and to terminate cooperation in the event of any identified corrupt behaviour. The
following areas or activities have been identified as carrying higher risk due to the nature of the
work (in particular because of frequent contact with external partners or clients and decision-
making on the eligibility for insurance claims or other benefits): procurement, claims handling,
sales, project management and financial management.
The Group imposes clear prohibitions and restrictions on donations and sponsorships, for
example to holders of public authority, public office holders, political parties or religious
organisations, as well as on the funding of political parties, campaigns, elections and
referendums, with exceptions allowed only to a limited extent and on the grounds of public
interest. The giving or receiving of improper gifts and hospitality, payments to expedite official
procedures and other conduct that could constitute undue influence are also prohibited.
Lobbying is carried out exclusively in accordance with the law and the principle of transparency.
Suspected corrupt behaviour is handled by the compliance function in accordance with internal
regulations, which also define the actions to be taken when a suspicion is confirmed, as well as
the procedures for monitoring their implementation and internal reporting. Policies and internal
regulations are available to all employees, general terms and conditions for business partners,
including anti-corruption provisions, are available on the website, and relevant content is also
incorporated into the general terms and conditions of insurance policies when dealing with
clients.
112
The handling of business ethics matters and allegations of corrupt behaviour within the Group
is organised separately from the business lines and is managed by the compliance function,
which operates as an internal control function in the second line of defence. The function
monitors compliance with regulations and other obligations, assesses compliance risks, tracks
the impact of changes in the legal environment, and provides advice on the coordination and
establishment and upgrading of compliance programmes, including internal controls. This
includes assessing the adequacy and effectiveness of existing procedures and measures through
advisory activities and targeted reviews.
The compliance function regularly reports to the Management Board, the Supervisory Board, and
relevant commissions and internal committees on the functioning of the system, significant
findings and matters addressed, typically in the context of the half-yearly and annual reports,
but also on an ad hoc basis if necessary. In the event of confirmed corrupt behaviour, the
Management Board is informed immediately and, where appropriate, the Supervisory Board is
also notified. The Management Board reports the relevant facts and circumstances to the
Slovenian Insurance Supervision Agency.
The system is complemented by mandatory training for all employees on managing corruption
risks and conflicts of interest, regular internal communications, such as circulars on gift and
hospitality policies, and an annual compliance risk assessment, which also covers this area. Since
112
G1-3_05.
192
2018, the Company has been a partner of Transparency International Slovenia, and since 2019 it
has also been included in the National Action Plan on Business and Human Rights issued by the
Slovenian Ministry of Foreign and European Affairs. Compliance representatives attend relevant
external consultations and meetings, regularly report on commitments made and raise
awareness of corporate integrity and human rights on key occasions.
Compliance officers or coordinators ensure that subsidiaries adopt arrangements that are
meaningfully equivalent, in line with the Minimum Standards.
Training and internal communication
113
All employees receive regular training from the Compliance Office on compliance risk
assessment, regulatory requirements and other commitments. Training and communications
cover in particular the prevention of corruption, conflicts of interest, gifts and hospitality,
whistleblowing mechanisms and whistleblower protection, and other related topics.
All Group employees are included in the training programmes – those in high-risk positions for
corrupt behaviour, as well as other employees. The Group provides regular and periodic
mandatory training covering the definition of corruption, the Corruption Risk Management
Policy, third-party contracting procedures, handling suspected or confirmed corrupt behaviour,
employee responsibilities, safeguarding whistleblower identities and protection against
retaliation, as well as topics such as public procurement, gifts and hospitality, sponsorships and
donations, and respect for human rights.
Functions with a higher inherent risk are fully integrated and comprehensively covered, with
procurement, claims settlement, sales, project management and finance identified as high risk
areas. In these functions, the Group also implements targeted awareness initiatives, training and
additional internal controls in line with the risk assessment.
Training courses are available via the Group's E-Campus and include a post-training knowledge
assessment. The Minimum Standards for Subsidiaries also set out expectations for training and
awareness-raising in subsidiaries (including the role of compliance coordinators), with content
tailored to local requirements and risks.
The number of training hours on corruption prevention
114
Employees in key functions
of the governance system
Leaders
Management Board and
Supervisory Board
Other employees
2025
2024
2025
2024
2025
2024
2025
2024
Training coverage
Total required
77
90
234
250
12
10
1,830
1,880
Total implemented
215
111
363
481
9
12
3,974
4,879
Training method
In-person training
126
24
78
40
6
558
24
Computer based
training
89
87
285
441
1
12
3,416
4,855
Frequency
How often training is
required
twice a year
twice a year
annually
annually
annually
annually
annually
annually
In 2025, no confirmed cases of corruption were recorded in the Triglav Group, nor were any
convictions, fines or other measures imposed for violations of anti-corruption legislation.
115
113
G1-1_10, G1-1_11, G1-3, G1-3_06_07, 05–G1-3_08.
114
G1-3_08, G1-4_03.
115
G1-4_01, G1-4_02, G1-4_03, G1-4_04, G1-4_05.
193
Protection of competition
The Group is committed to respecting consumer rights and good business practices in its
operations, product development and marketing. When choosing suppliers, it aims for
transparency and respects the protected interests of its competitors, while avoiding the risk of
violating regulations and the principles of fair competition. In the markets where the Group
holds a dominant position, consumers are advised to be cautious when taking out insurance and
business partners when entering into business relationships.
A stable regulatory environment with transparent involvement in public policies
116
The Triglav Group recognises a stable and predictable regulatory environment as an important
opportunity to promote quality governance, client protection, and long-term safe and profitable
operations. Accordingly, it engages in public policy discussions in a transparent, professional and
compliant manner, aiming to contribute to clear, feasible and proportionate rules, as well as to
a better understanding of the impact of regulatory changes on the market, consumers and
financial stability.
The Group's engagement is guided by the principle of integrity: it takes positions based on
expert analysis and conducts dialogue with regulators and other stakeholders responsibly,
honestly and respectfully, with appropriate internal approvals. This approach enhances
confidence and predictability in the business environment, reduces the risks associated with
unclear or unenforceable regulation, and supports effective compliance with legal and
regulatory requirements – resulting in greater operational stability, improved risk management
and enhanced client service.
10.4.2 Supplier relationship management
Zavarovalnica Triglav's procurement policy applies to all relevant commodity groups. The
procurement procedures above a certain amount are performed by the Strategic Sourcing and
Contract Management Department, which is responsible for coordination and communication
between the relevant departments in need of procurement and suppliers. The parent company's
practices are already being implemented in certain areas in the companies of the Adria region,
and further transfers and standardisation of procurement procedures are planned for 2026. The
procurement policy for each commodity group defines the relevant characteristics of the
supplier market and associated risks. Updates to the procurement policy are made based on
identified risks, changes in the supplier market, regulatory developments or adjustments in the
Company's strategy. The Company's procurement procedures follow a well-defined selection
process with built-in internal controls. Procurement procedure management is supported by a
standardised software solution, which increases the transparency and reduces the operational
risks of non-compliance with good business practices. The adopted general terms and conditions
for suppliers require a sustainability assessment for all suppliers and contractual partners before
an agreement is concluded. At a minimum, compliance with all legal requirements is
mandatory.
117
Important criteria that the Group considers in assessing supplier suitability include risks of
corrupt practices, conflicts of interest and political exposure. When assessing business
sustainability, the Company evaluates respect for human rights, the provision of a safe and
healthy work environment for employees and other workers, compliance with Slovenian
legislation, international human rights documents and environmental legislation requirements.
116
G1-1.
117
G1-2_02.
194
Since 2023, suppliers' ESG maturity has also been quantitatively assessed using a scoring system.
New suppliers undergo assessment in the selection process, while existing suppliers are
reviewed annually. These ESG criteria were applied to evaluate 1,161 suppliers and potential
suppliers participating in the selection process. Whenever possible, preference is given to local
sourcing (minimising international transport) and sustainable sourcing (recycled materials,
renewables, reuse, refurbishment). These priorities are applied on a level playing field. Under the
general terms and conditions, suppliers are required to report any changes that affect
sustainability aspects or compliance with these terms.
118
Insurance agents and sales staff also form a large part of the Group's sales network. See
Appendix 2. Business network of the Triglav Group for further information. The Group prioritises
open communication with business partners and the development of genuine business
relationships, in which consistently meeting contractual obligations and adhering to agreed
payment practices are key. At the Group, the general terms and conditions
(https://www.triglav.eu/sl/trajnostni-razvoj/odnosi-z-dobavitelji#) and legally defined
deadlines are followed when setting payment terms. This approach is applied uniformly,
ensuring that all suppliers are treated equally, regardless of legal status or size.
The standard payment period is 30 days, unless otherwise contractually agreed, which is often
sector-specific. On average, invoices received have a payment period of 17 days, the same as last
year.
In 2025, the Group paid invoices on average within 14 days (last year 13 days) of the contractual
or statutory payment date. The calculation included 81,788 invoices received from suppliers. A
total of 95% of invoices received from suppliers were paid in accordance with the contractual
payment terms (last year 80%). As of the reporting date, Triglav Group is involved in one court
proceeding relating to an alleged non-payment of a payable to a supplier. The company against
which the proceeding has been initiated assesses that the claim is unfounded.
119
10.5 Responsible investment at the Triglav Group
Responsible investment is an important means for the Triglav Group to systematically
incorporate environmental and social objectives into investment decisions, while ensuring that
sustainability risks in the portfolio are identified and managed appropriately, gradually reducing
exposure to activities with higher negative impacts. As investment decisions affect a broader
range of stakeholders (issuers of financial instruments, investors, regulators and the wider
society), the Group considers responsible investment as an integral part of sustainable
development and investment management. This approach is based on a combination of clear
rules (exclusions and limitations), the integration of sustainability factors into decision-making,
an active ownership role and regular monitoring of key indicators, including principal adverse
impacts (PAIs), in line with EU requirements.
The significant positive impact of the Group's approach can be observed in two areas of asset
management. Within the Group's own investment portfolio (investments from own funds and
guarantee funds), the share of social impact bonds, green bonds, sustainable bonds and
sustainability-linked bonds is being increased, thus supporting the financing of projects and
activities aimed at reducing negative impacts on the environment and society. Triglav
Investments, as asset manager to clients, promotes environmental and/or social characteristics
in funds classified under Article 8 of the SFDR and monitors relevant indicators and disclosures
118
G1-2_03.
119
G1-2_01, G1-6_01, G1-6_02 , G1-6_03, G1-6_04, G1-6_05.
195
in accordance with the requirements of the SFDR in the context of investment fund
management.
Responsible investment at the Group is based on a comprehensive set of policies that together
define the guidelines, criteria and expectations for managing investments in terms of
sustainability factors. The Sustainable Development Policy sets out the overarching framework
and strategic objectives for the Group's sustainable operations, while the Sustainable
Investment Policy defines how sustainability aspects are incorporated into investment decision-
making (including the integration of environmental, social and governance factors into risk
management and portfolio monitoring processes).
At Triglav Investments, the Responsible Investment Policy sets out the principles and operational
approaches, while the Engagement Policy defines the approach to active ownership with the aim
of promoting best practices and long-term investment sustainability.
10.5.1 Sustainable investment policy
120
The Group's Sustainable Investment Policy sets out a comprehensive approach to integrating
environmental, social and governance (ESG) aspects into the investment process, thereby
pursuing its mission of building a safer future. The Policy sets targets to increase the share of
investments with sustainable characteristics, while reducing exposure to activities with higher
sustainability risks. To this end, it identifies sensitive economic activities to which investment
activity is not directed or exposure is gradually reduced and sets limits on the maximum allowed
exposure to sensitive sectors. An important element of the Policy is the Group's active ownership
in the sustainable investment process, which includes dialogue with issuers and the exercise of
rights under financial instruments to promote improvements in issuers' sustainable practices
and governance.
This Policy applies to all insurance and pension companies within the Triglav Group, except for
clients' assets managed in mutual funds and discretionary mandate assets, which are managed
by the Group's asset management companies, and unit-linked assets (financial assets held to
back the Group's unit-linked products, where the investment risk is borne by the policyholders).
It covers the entire investment process, including decisions on asset allocation, sustainability risk
monitoring and reporting. It is geographically applicable in all markets where the Group
operates, without being limited to specific regions. The impact of the Policy is primarily felt at
the financial instrument issuer and portfolio levels, and indirectly by investors and wider society,
as the Policy aims to reduce adverse impacts on the environment and society.
The implementation of the Policy is the responsibility of the Management Board at the highest
level, with the Management Board member responsible for investments having primary
responsibility for integrating sustainability aspects into the investment strategy and processes.
The Supervisory Board monitors the implementation of the Policy through oversight of key
strategic indicators and regular reporting. The content of the Policy is subject to regular annual
monitoring and review at least once a year, taking into account the findings from the monitoring
of principal adverse impacts (PAIs), compliance with EU legislation and the Triglav Group's
strategic guidelines on sustainable development. Based on data analysis, risk assessments and
regulatory requirements, updates and improvements are made where necessary to ensure the
relevance and effectiveness of the Policy and its contribution to the transition to a low-carbon
circular economy.
120
MDR-P_01–MDR-P_06.
196
In its implementation, the Policy is based on international and EU standards and initiatives
followed by the Group, in particular the SFDR and related technical standards and the United
Nations Principles for Responsible Investment (UN PRI), to which Zavarovalnica Triglav and
Triglav Investments are signatories. The Policy also has substantive links to Sustainable
Development Goals (SDGs), where relevant. The interests of key stakeholders are taken into
account in policy formulation and updating through regular dialogue, reporting and the
integration of findings into policy monitoring and review processes. The Sustainable Investment
Policy is available on the Group's website in Slovenian and English, and is integrated internally
into investment management, sustainability risk monitoring and reporting procedures, ensuring
that relevant personnel are aware of its requirements. The full Policy is available at
https://www.triglav.eu/en/sustainable-development/sustainable-business/sustainability-
related-disclosures.
10.5.2 Policy implementation in 2025: activities and progress
121
In 2025, the Triglav Group implemented key measures to advance the Sustainable Investment
Policy and its related strategic ambitions. Central to these activities were the positive selection
of investments and the continuation of the strategy to increase the share of social impact, green,
sustainable and sustainability-linked bonds, while taking into account portfolio constraints and
asset–liability management (ALM) requirements.
At the same time, the Group continued to gradually reduce its exposure to sensitive sectors and
to refrain from investing in issuers developing new infrastructure in sectors identified as
sensitive. Another important aspect of implementing the Policy was the strengthening of the
monitoring of PAIs at portfolio level, including an annual review of indicators and the
development of additional guidance to mitigate them. The Group further reinforced active
ownership by participating in consultations, conferences and meetings with financial
instrument issuers, and by promoting sustainable practices in a targeted manner where impact
is possible and relevant.
These measures are expected to reduce sustainability risks within the portfolio (including
carbon-intensive exposures), contribute to decarbonisation objectives and broader policy goals,
enhance transparency and compliance with EU regulation, and strengthen confidence among
investors and other stakeholders in the Group's sustainability orientation. The measures are
being phased in over the Policy horizon and cover investments of the parent company and its
subsidiaries, as well as the management of client assets under Triglav Investments' relevant
policies. They apply to both direct investments and fund investments, as far as practicable given
product structure and data availability. The Group's investment portfolio is predominantly
exposed to the EU and the Western Balkans, and monitoring is tailored to the portfolio structure
as well as market and data constraints.
Activities are structured according to time horizons: in the short term, the focus is on updating
the Policy, establishing and maintaining exclusion lists, integrating sustainability aspects into
investment processes, tracking core indicators, and optimising control mechanisms and the
monitoring of sustainability risks; in the medium term, the focus shifts on upgrading
methodologies (e.g. carbon footprint of the investment portfolio, scenario analyses) and
expanding data coverage; in the long term, the focus is on achieving strategic ambitions, such
as further increasing the share of bonds with sustainability characteristics and progressively
reducing the adverse impacts of investments, taking into account investment constraints.
121
MDR-A_01–MDR-A_03, MDR-A_05.
197
The Group monitors progress through regular annual benchmarking of key indicators and
reporting to management bodies. In 2025, sustainability reporting was enhanced with periodic
measurement of quantitative indicators, providing better managers and the management with
better insight into the status of sustainable investments. The Group continued to gradually
increase the share of social impact bonds, green bonds, sustainable bonds and sustainability-
linked bonds, while maintaining low exposure to issuers on the Coal Exit List. For the second
consecutive year, the Group conducted an assessment of EU taxonomy-aligned investments. For
the third consecutive year, the parent company and Triglav Osiguranje, Zagreb and Triglav,
pokojninska družba, Ljubljana prepared a statement on principal adverse impacts of investment
decisions on sustainability factors in accordance with the SFDR. In 2025, the Group also
introduced a new sustainability data provider to better align with its reporting needs and
standards.
The Group does not maintain separate records of operating expenses and capital investments
related to responsible investment; therefore, the requirements to disclose separate amounts are
not applicable in this area. The development of responsible investment is mainly financed
through operating expenses, including licences for ESG data and tools, in-house staff capacity
for the investment activity, and training and awareness-raising activities. These expenses are
part of the regular labour and service costs of the investment activity segments and are included
in the consolidated financial statements under the corresponding standard cost items.
122
10.5.3 Progress measurement: indicators, methodologies and targets
123
The Triglav Group relies on a combination of quantitative and qualitative indicators to monitor
the performance and effectiveness of responsible investment. Key targets and monitoring
indicators for 2030 include:
▪ increase the share of green bonds, social impact bonds, sustainable bonds and sustainability-
linked bonds to 15% of the bond portfolio;
▪ limit exposure to issuers on the Coal Exit List to no more than 1% of the total investment
value.
The Group also monitors the PAIs at the level of the investment portfolios of the parent
company, Triglav Osiguranje, Zagreb and Triglav, pokojninska družba, Ljubljana, focusing in
particular on GHG emission indicators (PAIs 1–4) and exposure to the production of weapons,
ammunition and combat vehicles (PAI 14), where data are available. It qualitatively monitors the
implementation of active ownership (e.g. dialogue with issuers, voting and participation in
relevant expert frameworks) and the gradual disinvestment from sensitive activities (e.g. coal
mining, thermal power plants, weapons production, gambling and tobacco production) in line
with Policy constraints. The Group also aims to gradually increase the share of EU taxonomy-
aligned investments, subject to data availability and market opportunities.
The methodologies for calculating and ranking indicators are based on a combination of internal
approaches and established external standards. When classifying and monitoring the
proportion of bonds with sustainability characteristics, the Group considers both the Bloomberg
classification and the internal criteria set out in the Policy. PAI monitoring follows the regulatory
technical standards set out in Commission Delegated Regulation (EU) 2022/1288, with data
sourced from external ESG data providers; these data are regularly reviewed and assessed (at
least annually) and adjusted as necessary to reflect changes in reporting requirements. The
objectives to reduce exposure to sensitive activities are supported by an internal methodology
that identifies issuers based on relevant lists (e.g. Coal Exit List) and other sources reflecting
122
MDR-A_06–MDR-A_12.
123
MDR-M_01–MDR-M_03; MDR-T_01–MDR-T_13.
198
sustainability risks. Key limitations arise from the availability, quality and comparability of ESG
data across sectors and geographies, requiring expert judgement in interpreting results.
Indicator measurements are generally not validated by a specific external body (separate from
any reporting obligations). Indicators are clearly and unambiguously named and, for those
expressed in monetary units, the Group uses the reporting currency of the financial statements
(EUR).
The objectives of responsible investment are aligned with the Sustainable Investment Policy and
the Group's Sustainable Development Strategy, supporting the reallocation of capital towards
investments with sustainable characteristics and the reduction of exposure to activities with
higher adverse impacts. Targets are defined with a baseline, a base year and a period of validity,
including intermediate milestones where appropriate. Performance against targets is monitored
annually, with the Group disclosing the actual values of the relevant indicators and comparing
them with the set trajectory for achieving the targets, accompanied by explanations of the
impact of key factors. If the event of changes to targets or methodologies, the Group discloses
the reasons for the change and assess the impact on comparability of data across periods.
Bond investments of the Triglav Group with sustainability characteristics
Bonds with sustainability
characteristics
Index
Share in debt securities
31 Dec 2025
31 Dec 2024
2025/2024
31 Dec 2025
31 Dec 2024
Social impact bonds*
83,657,158
95,206,404
88
2.9%
3.6%
Green bonds**
265,536,727
221,398,009
120
9.3%
8.4%
Sustainability-linked bonds***
37,598,473
-
-
1.3%
-
Sustainable bonds****
39,107,914
22,821,428
171
1.4%
0.9%
Total
425,900,273
339,425,841
129
15%
12.9%
* Social impact bonds are an instrument for funding social services.
** Green bonds are an instrument for funding environmental projects, the funds of which are intended for ecologically efficient products,
technologies and processes, pollution prevention and control, sustainable management of natural resources, sustainable management of water
resources, renewable energy use, energy efficiency and clean transport.
*** Sustainability-linked bonds are financial instruments whose repayment terms (e.g. interest rate) are tied to the achievement of pre-defined
sustainability objectives by the issuer, such as reducing emissions or increasing the share of renewable energy sources.
They are not used to finance specific green projects, but to incentivise the organisation as a whole to enhance its sustainability performance.
If the objectives are not met, the interest rate may increase.
**** Sustainable bonds are an instrument for funding sustainability projects and a combination of green and social impact bonds. Funding is
often conditional on achieving sustainability goals.
At year-end, sustainable bond investments amounted to EUR 425.9 million, representing a 26%
increase compared to the end of 2024 (index 129). Consequently, the share of sustainable
investments in debt securities rose from 12.9% to 15.0%. The growth was driven mainly by green
bonds and sustainability bonds. In 2025, we also added a new asset class – sustainability-linked
bonds, where the financing terms are tied to the achievement of the issuer’s predefined
sustainability targets.
10.5.4 Responsible Investment Policy – Triglav Investments
124
Triglav Investments' Responsible Investment Policy defines the principles and processes that the
company applies when making investment decisions, with the aim of systematically integrating
environmental, social and governance (ESG) factors. It carries a dual responsibility: to clients, as
custodian of their assets, taking into account material risks and opportunities; and to wider
society, seeking to contribute to reducing the adverse impacts of the issuers and countries in
which it invests. It is implemented in the context of investment fund management and, where
124
MDR-P_01, MDR-P_02, MDR-P_03, MDR-P_04, MDR-P_05, MDR-P_06, MDR-T_01, MDR-M_01, MDR-M_02, MDR-
M_03, MDR-A_06.
199
relevant, in financial instrument management (discretionary mandate services), clearly
distinguishing the elements applicable to all products from those specific to products under
Article 8 of the SFDR, so that the Policy requirements are proportionately applied according to
the nature of the product and the scope of disclosures. The Policy is available on the Company's
website: https://www.triglavinvestments.si/assets/dokumenti/Politika-odgovornega-
investiranja-.pdf
125
Responsible Investment Policy and key pillars
The integration of sustainability factors into the investment process is further detailed in the
Responsible Investment Policy. Triglav Investments aims to reduce investment risks arising from
ESG factors while capturing opportunities through increased exposure to companies, countries
and transnational organisations that effectively understand and manage key environmental and
social changes. The core of the Responsible Investment Policy consists of three interlinked pillars:
(1) integration of ESG factors into investment decisions, (2) incorporation of aspects to mitigate
adverse impacts and PAI monitoring, and (3) active ownership.
As greenhouse gases are a key driver of global warming and climate change, the Policy
encourages investments that contribute to their reduction. It sets targets for indicators directly
or indirectly related to greenhouse gas emissions and develops portfolios with a lower carbon
footprint than the relevant benchmark indices when managing investment funds and
investment policies that promote environmental and social characteristics. Moreover, it
excludes companies exposed to activities with the highest negative environmental impacts,
including coal, oil sands, hydraulic fracturing, and oil and gas extraction in the Arctic.
Scope, management and control, reporting and methodology
The company has also adopted the Policy for the Identification and Prioritisation of Principal
Adverse Impacts on Sustainability Factors, which supports the systematic identification,
prioritisation and monitoring of PAIs. The role of active ownership – through the design of
engagement strategies, monitoring of results and escalation – is comprehensively addressed in
the Engagement Policy.
Policies are applied proportionately to the nature of the product:
▪ the ESG integration pillar and the active ownership pillar apply to all investment funds and
investment policies under the company's management and, where relevant, to discretionary
mandate services;
▪ the mitigation of adverse impacts and the PAI monitoring pillar applies to investment funds
and investment policies that meet the disclosure criteria set out in Article 8 of the SFDR;
▪ the Policy for the Identification and Prioritisation of Principal Adverse Impacts on
Sustainability Factors applies to products (funds and investment policies of discretionary
mandate services) that meet the disclosure criteria set out in Article 8 of the SFDR;
▪ the Engagement Policy applies to investment funds and to clients of discretionary mandate
services to the extent consistent with the mandate or client agreement (for discretionary
mandate services, generally based on an agreement; for funds, generally on a systematic
basis).
The policies are adopted and approved by the Company's Management Board, with each policy
specifying the control mechanisms for the relevant control functions. Sustainability
characteristics are assessed by fund managers and investment policies prior to transactions in
accordance with the Responsible Investment Policy, and these assessments documented.
125
MDR-P_01, MDR-P_03.
200
Monthly reviews for individual funds are independently prepared and recorded by Risk
Management and the Middle Office. The steps from the Policy for the Identification and
Prioritisation of Principal Adverse Impacts on Sustainability Factors are implemented by the
Investment Committee, while the Engagement Policy is implemented by the Active Ownership
Group appointed by the Management Board, with oversight provided by the permanent internal
control functions.
Responsible investment is reported in Triglav Investments' annual report, through the SFDR
disclosures and financial products and services, in the UN PRI annual report and on the website
through key policies and methodologies.
The methodology for assessing, measuring and monitoring environmental and social
characteristics and good governance is set out in the Responsible Investment Policy and its
accompanying methodology. In monitoring sustainability characteristics, Triglav Investments
uses a combination of internal analyses and external data sources, including MSCI Inc.'s primary
database and tools, Bloomberg where appropriate, and other credible sources (e.g. issuers'
annual and sustainability reports, public announcements and investor communications), as well
as its own analyses, subject to limitations in data availability and comparability.
10.5.5 Policy implementation
126
Triglav Investments ensures the implementation of the Policy by consistently integrating ESG
factors into the assessment of investment opportunities and the monitoring of investments,
aiming both to manage risks more effectively and to identify opportunities in issuers and
countries that respond effectively to key environmental and societal changes. In the investment
process, managers assess and consider the potential impacts of environmental, social and
governance factors on the future performance results of companies, the economic stability of
countries and the performance of transnational organisations, with all assessments being
documented.
To mitigate adverse impacts, the company employs a system for identifying and monitoring
environmental and social impacts through predefined indicators, including PAIs, which are
identified, prioritised and monitored at least annually in accordance with the Policy. The
adequacy and compliance of issuers, as well as the consistency of portfolios, are monitored
regularly. Any deviations and planned actions are discussed by the Investment Committee, with
findings and planned actions reported to the Management Board and the Compliance Officer,
while deviations are followed up until they are resolved.
Active ownership is exercised through voting at general meetings and through engagement or
dialogue with issuers. It focuses on topics most critical for long-term performance and
sustainability-oriented governance, including disclosure transparency, good governance
practices, climate aspects and human rights. The engagement process typically involves
selecting the topic and the addressees, developing a strategy (objectives, responsibilities,
methods and timeline), establishing communication and discussions with the relevant
stakeholders. Where appropriate, engagement is also conducted jointly with other stakeholders.
Progress is monitored through regular investment and management processes and is taken into
account in future decisions.
126
MDR-A_01, MDR-A_02, MDR-A_03, MDR-A_05.
201
10.5.6 Progress measurement: indicators, methodologies and targets
127
The Company measures its progress towards responsible investment against the objectives,
thresholds and methodologies set out in the Responsible Investment Policy and its
accompanying methodology. The central environmental objective is to promote the reduction
of greenhouse gas emissions; the Company pursues this by excluding from the portfolios of
investment funds and the investment policies of IUP that meet the criteria for disclosures under
Article 8 of Regulation (EU) 2019/2088 those companies with a high negative environmental
impact and countries that have not committed to achieving carbon neutrality by 2050, while at
the same time pursuing target values for the carbon footprint or carbon intensity in the
management of these portfolios. In addition, the preparation of a decarbonisation plan and the
achievement of high scores in reporting under the UN PRI (United Nations Principles for
Responsible Investment) are defined as company-level objectives.
With regard to the social dimension, progress is monitored through rules and exclusions related
to human rights and key social risks. In particular, the Company does not invest in companies
that violate the principles of the UN Global Compact or OECD guidelines, and applies exclusions
for tobacco (above the income threshold) and controversial weapons. For countries, it also
considers rules related to violations of social rights and low scores on selected indicators (e.g.
human rights, corruption, the rule of law).
As part of its responsible investment approach, the Group also monitors progress in the area of
issuers' good governance. A multi-criteria model is used to assess good governance, with issuers
either meeting the required threshold or engaging in a dialogue process for products that
promote environmental and social characteristics. PAIs are part of the adverse impact
monitoring system, selected and prioritised at least annually, and monitored in accordance with
defined processes and data availability.
Measurement relies on a combination of internal analyses and external data sources, taking into
account limitations in data availability and comparability. The appropriateness of the selected
indicators, reference benchmarks and thresholds is regularly assessed. The methodologies,
reference benchmarks and thresholds are set out in a methodology included as an appendix to
the Policy and are updated as necessary to reflect developments in standards, regulation and
data.
Assets held in investment funds complying with the requirements of Article 8 of the SFDR
Written premium and assets under management
Index
2025
2024
2025/2024
Investment funds – Article 8 of the SFDR
2,105,853,459
1,923,993,403
110
127
MDR-T_01–MDR-T_13, MDR-M_01–MDR-M_03.
202
10.6 Limited Assurance Report on Sustainability Information
203
204
205
206
207
208
11. Digital Operational Resilience Report
11.1 Information security risk management
The Group has established an information security management system designed to ensure the
effective management of information security risks, which are managed as part of operational
risks within the Company's comprehensive risk management system (see Section 9.1 Risk
management system).
Within the established risk management system, information security risks that overlap with
information and communication technology (ICT) risks are regularly identified, assessed,
managed and monitored. This ensures the protection of the Company against internal and
external hazards and threats, intentional or unintentional, that could compromise security and
the uninterrupted execution of business processes. In 2025, the risk assessment process was
further upgraded, as described in more detail in Section 11.2 Information security objectives.
To manage identified information security risks, internal regulations set out the principles and
rules for protecting the confidentiality, integrity, authenticity and availability of data and
information, as well as the ICT systems supporting the implementation of the Company's
strategy. These internal regulations are binding on all Group subsidiaries.
Effective cooperation at management level is a key factor in ensuring information security and
digital operational resilience. Accordingly, assessment results, identified risks and measures are
regularly discussed at internal meetings.
11.2 Information security objectives
The Company's information security objectives are shaped by the needs and expectations of key
stakeholders and aligned with strategic goals. The strategy defines its approach to managing
information security objectives in accordance with the ISO/IEC 27001:2022 standard and taking
into account applicable regulatory requirements. A set of indicators is used to monitor the
achievement of objectives and the effectiveness of the strategy. These indicators reflect both the
functioning of controls in individual areas and the overall effectiveness of the established
information security management system. The status of the indicators is regularly reported to
the management. The key information security objectives are as follows:
▪ Ensuring confidentiality, integrity, authenticity and availability of information processed in
business processes.
To achieve this objective, numerous procedures and controls are defined in internal acts within
the scope of the information security management system. These procedures and controls are
regularly reviewed and updated to reflect internal and external developments, including
technological advances and changes in legislation.
Proper management of ICT resources supporting the functioning of the Company’s business
processes is a key element in ensuring the confidentiality, integrity, authenticity and availability
of information. Accordingly, additional attention was devoted to this in 2025.
▪ Continuously identifying and managing in a controlled manner information security risks
related to the Group's business, ICT assets supporting business processes and ICT service
providers (including subcontractors), in order to maintain these risks at an acceptable level.
209
Internal and external threats that could compromise the security of the Company's information
and information systems are regularly monitored through dedicated tools as part of control
processes and based on information obtained from reliable external sources.
In 2025, the Company enhanced its information security risk assessment through more effective
technical support. This improvement increased the transparency and traceability of information
security and ICT risk management processes, as well as the quality and consistency of data,
thereby contributing to more effective and reliable risk management.
▪ Maintaining a consistently appropriate level of knowledge of information security risks
within the Group's operations, as well as of technological solutions and other risk
management measures, through staff training and employee awareness initiatives.
Assigning roles and responsibilities to ensure collective accountability for information
security, thereby minimising the impact of security threats.
In 2025, the Company enhanced its information security training programme to improve
employee awareness and competence regarding security threats, with the aim of increasing the
Company's resilience to an evolving threat landscape, including cyber threats. The programme is
tailored to the specific information security risks, threats and regulatory requirements relevant
to the work of various employee groups, including management.
In addition to periodic training, employees are regularly informed about cyber threats and
appropriate response procedures to reduce the likelihood of such threats materialising.
Real-life social engineering attack simulations are conducted, the results of which serve as a
valuable indicator of the effectiveness of regular employee training.
Knowledge of information security is also an integral part of the professional competences of
technical staff, who participate in education and training to enhance their skills in line with their
tasks and responsibilities.
▪ Ensuring business continuity to the greatest extent possible, even when the Company relies
on external ICT service providers. Minimising business damage from security incidents
through effective identification, resolution and mitigation of their consequences.
In 2025, the Company updated its methodology for conducting business impact analyses,
forming the basis for effective business continuity planning and the systematic management of
operational resilience.
As part of the programme to ensure digital operational resilience, a series of activities was carried
out to test the Company's preparedness for various disruptions and incidents. Particular
emphasis was placed on testing response procedures during security incidents and verifying the
effectiveness of business continuity plans for critical processes and ICT systems that support
services. Test scenarios were designed to reflect current threats, emerging trends and regulatory
requirements in digital resilience, ensuring realistic and relevant testing conditions. The purpose
of these activities was to assess the ability to respond quickly and in a coordinated manner and
to ensure that the mechanisms in place to manage risks and maintain business continuity are
effective in practice. The results of these tests provide a key basis for further improvements and
for strengthening the Company's resilience to future challenges.
▪ Ensuring the continuous monitoring and improvement of the Company's information
security management system, as well as its compliance with legislative requirements and
the positions of the competent supervisory authorities.
As part of this process, in 2025 the Company reviewed and enhanced the information security
management system (ISMS) framework, taking into account technological developments, good
practices, legislative changes, and recommendations arising from internal and external reviews.
210
11.3 Adopted information security and digital operational resilience frameworks
As the parent company of the Group, the Company has established a comprehensive information
security management system based on internationally recognised standards, regulatory
requirements and good practices. The ISO/IEC 27001 certificate confirms the commitment to the
continuous maintenance and improvement of this system, ensuring a high level of data and
information security and compliance with regulatory requirements.
In 2025, as part of its regular activities, the Company implemented a series of measures to
strengthen information security and digital operational resilience. Key tasks included assessing
the impact on operations, conducting comprehensive risk assessments and reviewing the
effectiveness of existing controls, including testing under the digital operational resilience
programme. In addition, further control mechanisms were introduced to ensure the
confidentiality, integrity, authenticity and availability of information. ICT risk management,
forming the foundation of digital operational resilience, was upgraded in line with the
requirements of the DORA Regulation, resulting in even greater alignment with EU standards. All
activities carried out are regularly reported to the management, ensuring transparency and
supporting strategic decision-making.
11.4 Measures to improve ICT incident preparedness
ICT incidents can have a significant impact on the smooth operation and the achievement of the
Group's strategic objectives. It is therefore essential that the Company maintains a
comprehensive incident management system, including clear rules, procedures and
responsibilities. The purpose of this system is to ensure a rapid, coordinated and effective
response to any disruptions, thereby minimising damage and enabling key activities to continue
while remedial measures are implemented.
To achieve these objectives, the operation of information systems is continuously monitored to
detect deviations from normal operation and identify threats. In addition, response procedures
are regularly tested as part of a digital operational resilience testing programme aligned with
the requirements of the DORA Regulation. This programme enables a comprehensive
assessment of preparedness for cyberattacks, system failures and other operational disruptions,
and helps identify and address potential vulnerabilities.
Advanced security and monitoring tools are used to support these processes, continuously
tracking the performance of ICT systems and services and promptly detecting events that could
compromise information security and business continuity. In line with the increasing scale of
cyber threats, financial investment in information security and digital resilience solutions
increases every year by over 15%. Approximately one-third of these funds are allocated to threat
protection and system security services, with the remainder directed to software solutions that
enhance resilience to cyberattacks.
This approach ensures that the Group is prepared for the challenges of the modern digital
environment and can respond quickly and effectively to any incidents, thereby reducing risks and
strengthening confidence in its services.
11.5 Obtained assurances (internal and external)
In November 2024, the Company's Internal Audit Department prepared an annual work plan,
which was adopted by the Management Board with the consent of the Supervisory Board. The
plan is based on an audit risk assessment, strategic orientations and work guidelines. It identifies
the need to increase the frequency of internal audits in areas with major risks identified,
211
including ICT, which are regularly audited. As part of its mandate, the Internal Audit Department
regularly monitors the implementation of issued recommendations and provides periodic
reports to the Management Board, the Audit Committee and the Supervisory Board.
In the audits conducted in 2025 at the Company and selected Group companies, the focus was
primarily on the management of ICT process areas. In this context, the Internal Audit
Department also examined the management of cyber risks, including ICT asset management, IT
changes, network management and key aspects of implementing the requirements of the DORA
Regulation.
In cooperation with external experts, it also conducted security reviews, which did not reveal any
increased information security risks.
212
213
Statement of management's responsibilities
The Management Board herewith confirms the financial statements Zavarovalnica Triglav, d.d.
and Triglav Group for the year ended 31 December 2025, and the accompanying accounting
policies and notes to the accounting policies.
The Management Board is responisible for preparing the Annual Report so that it is true and fair
presentation of the Company's and Group's assets and liabilities, financial position and profit for
the year ended 31 December 2025 in accordance with International Financial Reporting
Standards as adopted by the EU.
The Management Board additionally confirms that the appropriate accounting policies were
consistently used and that the accounting estimates were prepared accoring to the principles of
prudence and good management. The Management Board furthermore confirms that the
financial statements, together with the notes are prepared on a going concern basis and that
they comply with the applicable legislation and International Financial Reporting Standards as
adopted by the EU.
The Management Board confirms that the Business Report includes a fair presentation of the
development and financial position of the Company and the Group, including a description of
the significant risks to which the Company and the Group are exposed to.
The Management Board is also responsibile for appropriate accounting practices, for the
adoption of appropriate measures for the protection of assets, and for the prevention and
identification of fraud and other irregularities or illegal acts.
The tax authorities may, at any time within the period of five years since the day the tax become
chargeable, review the operations of the Company, which may result in additional tax liabilities,
default interest and penalties related to corporate income tax and/or other taxes or levies. The
Management Board of the Company is unaware of any circumstances that could potentially
result in any such significant liability.
Andrej Slapar
President of the
Management Board
Uroš Ivanc
Management Board Member
Tadej Čoroli
Management Board Member
Marica Makoter
Management Board Member
Blaž Jakič
Management Board Member
Ivica Vulić
Management Board Member
Ljubljana, 10 March 2026
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In Slovenia, the services are provided by Deloitte revizija d.o.o and Deloitte svetovanje d.o.o. (jointly referred to as “Del
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Deloitte revizija d.o.o.
- The company is registered with the Ljubljana District Court, registration no. 1647105 - VAT ID SI62560085 - Nominal capital EUR 74,214.30.
© 202
6. For information, contact Deloitte Slovenia.
5999004E805C598C1CC88CDACDE26396
INDEPENDENT AUDITOR’S REPORT
to the shareholders of ZAVAROVALNICA TRIGLAV, d.d.
Report on the Audit of the Separate and Consolidated Financial Statements
Opinion
We have audited the separate financial statements of the company ZAVAROVALNICA TRIGLAV, d.d.
(hereinafter ‘the Company’) and the consolidated financial statements of the company ZAVAROVALNICA
TRIGLAV, d.d. and its subsidiaries (hereinafter ‘the Group’), which comprise the separate and the
consolidated statement of financial position as at 31 December 2025, and the separate and consolidated
statement of profit or loss, separate and consolidated statement of other comprehensive income,
separate and consolidated statement of changes in equity, separate and consolidated cash flow statement
for the year then ended, and notes to the separate and consolidated financial statements, including
material accounting policy information.
In our opinion, the accompanying separate and consolidated financial statements present fairly, in all
material respects, the financial position of the Company and the Group as at 31 December 2025, and their
financial performance and cash flows for the year then ended in accordance with International Financial
Reporting Standards as adopted by the EU (hereinafter ‘IFRS’).
Basis for Opinion
We conducted our audit in accordance with International Standards on Auditing and Regulation (EU)
537/2014 of the European Parliament and of the Council, dated 16 April 2014, on specific requirements
regarding statutory audit of public-interest entities (EU Regulation). Our responsibilities under those rules
are further described in the Auditor’s Responsibilities for the Audit of the Separate and Consolidated
Financial Statements section of our report. We are independent of the Company and the Group in
accordance with the International Code of Ethics for Professional Accountants (including International
Independence Standards) of the International Ethics Standards Board for Accountants (IESBA Code), as
applicable to audits of financial statements of public interest entities, and other ethical requirements that
are relevant to our audit of the separate and consolidated financial statements in Slovenia. We have also
1.
Deloitte revizija d.o.o.
Dunajska cesta 165
1000 Ljubljana
Slovenia
VAT ID:
SI62560085
Tel: +386 (0) 1 3072 800
Fax: +386 (0) 1 3072 900
www.deloitte.si
5999004E805C598C1CC88CDACDE26396
fulfilled our other ethical responsibilities in accordance with these requirements and the IESBA Code. We
believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our
audit opinion.
Emphasis of Matter
We draw attention to Note 2.7 Transfer of part of the assets to Triglav, pokojninska družba, d.d., in the
separate and consolidated financial statements, which describes the effects of the transfer of the savings
portion of the voluntary supplementary pension insurance (PDPZ) activity from Zavarovalnica Triglav, d.d.,
to Triglav, pokojninska družba, d.d., which is wholly owned by Zavarovalnica Triglav, d.d., using the
retrospective method in the Company’s separate financial statements. Our opinion is not modified in
respect of this matter.
Key Audit Matters
Key audit matters are those matters that, in our professional judgment, were of most significance in our
audit of the separate and consolidated financial statements of the year ended 31 December 2025. These
matters were addressed in the context of our audit of the separate and consolidated financial statements
as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these
matters.
Valuation of liabilities from insurance contracts and insurance income for the Company and the Group
Key Audit Matter
How our audit addressed the key audit matter
Accounting policies for description of key assumptions, methodologies and models used in the calculation of
liabilities and income from insurance contracts are presented in Note 2.5.2 Insurance and reinsurance
contract assets and liabilities. For other related disclosures please see Notes 3.1 Insurance business.
International Financial Reporting Standard 17 –
Insurance Contracts (‘IFRS 17’), requires
insurance contracts, that meet the scoping
criteria of the standard, to be valued using the
General Measurement Model (or Building Block
Approach - ‘BBA’), the Variable Fee Approach
(‘VFA’), or the Premium Allocation Approach
(‘PAA’) all of which are used by the Company and
the Group. The measurement of liabilities from
insurance contracts as well as insurance income
comprises the present value of expected future
cash flows, including financial and non-financial
risks, with particular focus on the expected
margin (so-called contractual service margin
‘CSM’), which will be recognized during the
period of contractual coverage.
The company's and the group's insurance
liabilities as at 31 December 2025, amount to
EUR
2.646.831.171 (31. 12. 2024: EUR
1.982.613.699) and EUR 3.173.858.739 (31. 12.
2024: EUR 2.473.497.966), respectively. The
To address the risks associated with the valuation of
liabilities from insurance contracts and insurance income
identified as a key audit matter, we designed audit
procedures that enabled us to obtain sufficient
appropriate audit evidence for our conclusion on that
matter. Namely, we performed the following audit
procedures with the use of our own information
technology (‘IT”) experts and actuarial experts:
Evaluation of internal controls
• Gaining an understanding of the control environment
and internal controls designed by the Management in
the process of calculating liabilities from insurance
contracts and insurance income, including the
applications and information technology tool used;
• Assessing the adequacy of the design and verifying
the implementation of the identified internal controls
relevant to the process of valuation of liabilities from
insurance contracts and insurance income;
5999004E805C598C1CC88CDACDE26396
Company's and the Group's insurance income for
the year ended 31 December 2025 amount to
EUR
1.184.223.021 (31. 12. 2024: EUR
911.051.366) and EUR 1.608.751.926 (31. 12.
2024: EUR 1.297.899.920), respectively.
Valuation of liabilities from insurance contracts
and insurance income involves significant
management judgment when developing and
using input data and assumptions in the actuarial
calculation models, dependent on the
management's assumptions about past, future,
internal and external variables, the change of
which can result in a significant impact on the
value of these liabilities. There is also a high
degree of complexity due to the numerous
assumptions and actuarial valuation models
applied. Some of the key assumptions include
risk adjustment, discount curves, inflation
forecasts, cost projection, mortality, longevity,
lapse assumptions, claims/expense ratios
assumptions, coverage units and CSM
recognition pattern.
Given the pervasive complexities related to the
requirements of IFRS 17, we consider the
valuation of liabilities from insurance contracts
and insurance income as a key audit matter for
our audit of the separate and consolidated
financial statements for the year 2025.
•
Testing the operating effectiveness of identified
relevant internal controls on valuation of liabilities
from insurance contracts and insurance income.
Testing of actuarial models in accordance with IFRS 17
• Testing the reliability and accuracy of the IFRS 17
engine used for the valuation of liabilities from
insurance contracts and insurance income;
• Verification of inputs to the IFRS 17 engine:
o Review and simplified recalculation of the
projected cash flows for selected
products taking into account specific
features of insurance products;
o Verification of the mathematical
calculations, logic, and appropriateness of
other model inputs of the IFRS 17 engine.
Assessment of management assumptions in accordance
with IFRS 17
• Challenging the appropriateness of key technical
accounting decisions, judgments, assumptions
and elections made in determining the estimate
against the requirements of the standard;
• Verification of the applied assumptions in the
context of the experience of the Company, the
Group and the industry and specific features of
insurance products.
Testing of disclosures in the separate and consolidated
financial statements
• Evaluating the completeness and accuracy of the
disclosures in the notes to the separate and
consolidated financial statements with respect to the
requirements of IFRS 17.
Other information
Management is responsible for the other information. The other information comprises the information,
included in Annual report, other than the separate and consolidated financial statements and our
auditor’s report thereon. We obtained other information before the date of the auditor's report, except
for the report of the supervisory board, which will be available later.
Our opinion on the separate and consolidated financial statements does not cover the other information
and we express no assurance thereon.
5999004E805C598C1CC88CDACDE26396
In connection with our audit of the separate and consolidated financial statements, our responsibility is to
read the other information and, in doing so, assess whether the other information is materially
inconsistent with the separate and consolidated financial statements, legal requirements, except those
related to sustainability report which was subject of separate limited assurance report, or our knowledge
obtained in the audit, or otherwise appears to be materially misstated. If based on our work performed
we conclude that other information include material misstatement we need to report such circumstances.
In relation to this and based on our procedures performed, we report that:
• other information is, in all material respects, consistent with the audited separate and
consolidated financial statements;
• other information except sustainability report on which we issued separate limited assurance
report dated 11 March 2026, is prepared in compliance with applicable law or regulation; and
• based on our knowledge and understanding of the Company and the Group and their
environment obtained in the audit, we did not identify any material misstatement of fact related
to the other information.
Responsibilities of Management and Those Charged with Governance for the Separate and Consolidated
Financial Statements
Management is responsible for the preparation and fair presentation of the separate and consolidated
financial statements in accordance with IFRS, and for such internal control as management determines is
necessary to enable the preparation of separate and consolidated financial statements that are free from
material misstatement, whether due to fraud or error.
In preparing the separate and consolidated financial statements of the Company and the Group,
management is responsible for assessing their ability to continue as a going concern, disclosing matters
related to going concern and using the going concern basis of accounting unless management either
intends to liquidate the Company and the Group or to cease operations, or has no realistic alternative but
to do so.
Those charged with governance are responsible for overseeing the Company’s and the Group’s financial
reporting process.
Auditor’s Responsibilities for the Audit of the Separate and Consolidated Financial Statements
Our objectives are to obtain reasonable assurance about whether the separate and consolidated financial
statements as a whole are free from material misstatement, whether due to fraud or error, and to issue
an auditor’s report that includes our opinion. Reasonable assurance is a high level of assurance, but is not
a guarantee that an audit conducted in accordance with International Standards on Auditing will always
detect a material misstatement when it exists. Misstatements can arise from fraud or error and are
considered material if, individually or in the aggregate, they could reasonably be expected to influence the
economic decisions of users taken on the basis of these separate and consolidated financial statements.
As part of an audit in accordance with International Standards on Auditing, we exercise professional
judgment and maintain professional scepticism throughout the audit. We also:
• Identify and assess the risks of material misstatement of the separate and consolidated financial
statements, whether due to fraud or error, design and perform audit procedures responsive to
those risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for our
opinion. The risk of not detecting a material misstatement resulting from fraud is higher than for
one resulting from error, as fraud may involve collusion, forgery, intentional omissions,
misrepresentations, or the override of internal control.
5999004E805C598C1CC88CDACDE26396
• Obtain an understanding of internal control relevant to the audit in order to design audit
procedures that are appropriate in the circumstances, but not for the purpose of expressing an
opinion on the effectiveness of the Company's and the Group’s internal controls.
• Evaluate the appropriateness of accounting policies used and the reasonableness of accounting
estimates and related disclosures made by management.
• Conclude on the appropriateness of management’s use of the going concern basis of accounting
and, based on the audit evidence obtained, whether a material uncertainty exists related to
events or conditions that may cast significant doubt on the Company’s and the Group’s ability to
continue as a going concern. If we conclude that a material uncertainty exists, we are required to
draw attention in our auditor’s report to the related disclosures in the separate and consolidated
financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions
are based on the audit evidence obtained up to the date of our auditor’s report. However, future
events or conditions may cause the Company or the Group to cease to continue as a going
concern.
• Evaluate the overall presentation, structure and content of the separate and consolidated
financial statements, including the disclosures, and whether the separate and consolidated
financial statements represent the underlying transactions and events in a manner that achieves
fair presentation.
• Plan and perform the group audit to obtain sufficient appropriate audit evidence regarding the
financial information of the entities or business units within the Group as a basis for forming an
opinion on the group financial statements. We are responsible for the direction, supervision and
review of the audit work performed for purposes of the group audit. We remain solely responsible
for our audit opinion.
We communicate with those charged with governance regarding, among other matters, the planned
scope and timing of the audit and significant audit findings, including any significant deficiencies in
internal control that we identify during our audit.
We also provide those charged with governance with a statement that we have complied with relevant
ethical requirements regarding independence, and to communicate with them all relationships and other
matters that may reasonably be thought to bear on our independence, and where applicable, action taken
to eliminate threats or safeguards applied.
From the matters communicated with those charged with governance, we determine those matters that
were of most significance in the audit of the separate and consolidated financial statements of the current
period, and are therefore the key audit matters. We describe these matters in our auditor’s report unless
law or regulation precludes public disclosure about the matter or when, in extremely rare circumstances,
we determine that a matter should not be communicated in our report because the adverse
consequences of doing so would reasonably be expected to outweigh the public interest benefits of such
communication.
Report on Other Legal and Regulatory Requirements
Report on the requirements of the Regulation (EU) No 537/2014 of the European Parliament and of the
Council (Regulation EU 537/2014)
5999004E805C598C1CC88CDACDE26396
Confirmation to the Audit Committee
We confirm that our audit opinion on the separate and consolidated financial statements expressed herein
is consistent with the additional report to the Audit Committee in accordance with Article 11 of Regulation
(EU) No. 537/2014 of the European Parliament and the Council.
Prohibited Services
We confirm that no services referred to in the Article 5(1) of Regulation (EU) No. 537/2014 of the European
Parliament and the Council were provided and that the audit company fulfilled independence requirements.
Other services performed by the audit company
There are no services, in addition to the statutory audit, which the audit company provided to the Company
and its controlled undertakings, and which have not been disclosed in the Annual Report.
Appointment of the Auditor and responsible certified auditor
Deloitte revizija d.o.o. was appointed as the statutory auditor of the Company and the Group on General
Shareholders’ Meeting held on 3 June 2025, while the president of the Supervisory Board signed the audit
contract on 7 July 2025. The audit contract was signed for 4 years. Our total uninterrupted engagement as
statutory auditors has lasted since 21 June 2019.
Engagement partner responsible for the audit on behalf of Deloitte revizija d.o.o. is Barbara Žibret Kralj.
Auditor’s Report on Compliance of Financial Statements in Electronic Form with the Commission Delegated
Regulation (EU) No. 2019/815 on European Single Electronic Format (ESEF)
We undertook a reasonable assurance engagement on whether the separate and consolidated financial
statements of the Company and the Group for the year ended 31 December, 2025 (hereinafter ‘audited
separate and consolidated financial statements’) are prepared taking into consideration the Commission
Delegated Regulation (EU) 2019/815 of 17 December 2018 supplementing Directive 2004/109/EC of the
European Parliament and of the Council with regard to regulatory technical standards on the specification
of a single electronic reporting format, valid for the year 2025 (hereinafter ‘Delegated Regulation’).
Responsibilities of Management and Those Charged with Governance
Management is responsible for the preparation and correct presentation of audited separate and
consolidated financial statements in electronic form in accordance with the requirements of the
Delegated Regulation and for such internal control as determined necessary by the management, to
enable the preparation of separate and consolidated financial statements in electronic form that are free
from material misstatement, whether due to fraud or error.
Those charged with governance are responsible for overseeing the preparation of audited separate and
consolidated financial statements in electronic form in accordance with the requirements of the
Delegated Regulation.
Auditor’s Responsibility
Our responsibility is to carry out a reasonable assurance engagement and to express the conclusion on
whether the audited separate and consolidated financial statements in electronic form are prepared in
accordance with the requirements of the Delegated Regulation. We conducted our reasonable assurance
engagement in accordance with the International Standard on Assurance Engagements 3000 (Revised) –
Assurance Engagements Other than Audits or Reviews of Historical Financial Information (ISAE 3000)
5999004E805C598C1CC88CDACDE26396
published by the International Auditing and Assurance Standards Board. This standard requires that we
plan and perform the engagement to obtain reasonable assurance for providing a conclusion.
We have conducted the engagement in compliance with independence and ethical requirements as
provided by the Regulation EU No. 537/2014 and IESBA Code. The code is based on the principles of
integrity, objectivity, professional competence and due diligence, confidentiality and professional conduct.
We are in compliance with the International Standard on Quality Management (ISQM 1) and accordingly
maintain an overall quality management system, including documented policies and procedures regarding
compliance with ethical requirements, professional standards and applicable legal and statutory
requirements.
Summary of Work Performed
Within the scope of the work performed, we have carried out the following audit procedures:
• we have identified and assessed the risk of material non-compliance of audited separate and
consolidated financial statements misstatement with the requirements of the Delegated
Regulation;
• we have obtained understanding of the internal control processes considered important for our
reasonable assurance engagement in order to design appropriate procedures in given
circumstances, however, not with the purpose of expressing an opinion on the effectiveness of
internal control;
• we have assessed whether the audited separate and consolidated financial statements satisfy the
conditions of Delegated Regulations, valid on the reporting date;
o we have obtained reasonable assurance that the audited separate and consolidated
financial statements of the issuer are presented in the electronic XHTML format;
o we have obtained reasonable assurance that the values and disclosures in the audited
consolidated financial statements in the electronic XHTML format are tagged correctly
and in the Inline XBRL technology (iXBRL), so that their machine reading can ensure
complete and correct information that is included in the audited consolidated financial
statements.
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our
conclusion.
Conclusion
In our opinion, based on the procedures performed and the evidence obtained we believe that the
audited separate and consolidated financial statements of the Company and the Group for the year ended
31 December 2025, are in all material respects prepared in accordance with the requirements of the
Delegated Regulation.
DELOITTE REVIZIJA d.o.o.
Barbara Žibret Kralj
Certified auditor
For signature please refer to the
original Slovenian version.
Ljubljana, 11 March 2026 TRANSLATION ONLY, SLOVENE ORIGINAL PREVAILS
221
1. Financial statements
128
1.1 Statement of financial position
in EUR
Triglav Group
Zavarovalnica Triglav
Notes
31 Dec 2025
31 Dec 2024
31 Dec 2025
31 Dec 2024
adjusted*
1 Jan 2024
adjusted*
ASSETS
Property, plant and equipment
3.7.1
Investment property
3.7.2
Right-of-use assets
3.7.3
Intangible assets and goodwill
3.7.4
Deferred tax assets
3.7.5
Investments in subsidiaries
3.3
Investments in associates and jointly controlled
companies accounted for using the equity
method
3.3
Financial investments
3.4
– at fair value through other comprehensive
income
– at amortised cost
– at fair value through profit or loss
Financial contract assets
3.5
– investments at amortised cost
– investments at fair value through profit or
loss
– receivables from financial contracts
– cash from financial contracts
Insurance contract assets
3.1
Reinsurance contract assets
3.2
Non-current assets held for sale
Current corporate income tax assets
3.7.17
Other receivables
3.7.7
Cash and cash equivalents
3.7.8
Other assets
3.7.9
EQUITY AND LIABILITIES
Equity
3.7.10
Controlling interests
– share capital
– share premium
– treasury share reserves
– treasury share
-364,680
-364,680
– other reserves from profit
– accumulated other comprehensive income
-15,658,675
-31,253,300
-22,706,240
-29,518,795
-30,153,273
– retained earnings from previous years
– net profit or loss for the year
-4,782,244
– translation differences
-3,227,136
-3,074,712
Non-controlling interests
Subordinated liabilities
3.7.11
Deferred tax liabilities
3.7.5
Financial contract liabilities
3.5
Insurance contract liabilities
3.1
Reinsurance contract liabilities
3.2
Provisions
3.7.12
Lease liabilities
3.7.3
Other financial liabilities
Current corporate income tax liabilities
3.7.17
Other liabilities
3.7.13
* The figures for the comparative period are adjusted for the transfer of part of the assets to Triglav, pokojninska družba d.d., as described in Section 2.7.
128
The notes in Section 2, 3 and 4 are an integral part of the financial statements.
222
1.2 Statement of profit or loss
in EUR
Triglav Group
Zavarovalnica Triglav
Notes
2025
2024
2025
2024
Insurance service result
– insurance income
3.1
– insurance service expenses
3.1
-1,335,950,234
-997,300,760
-999,178,369
-651,239,341
– net reinsurance service result
3.2
-64,752,522
-140,930,917
-25,326,630
-130,657,099
Investment result
3.4
– interest income calculated using the effective
interest method
– dividend income
– net gains and losses on financial investments
– net impairment and reversal of impairment of
financial investments
-154,590
-107,294
– other effects of investing activities
Financial result from insurance contracts
-47,799,090
-118,428,159
-37,316,904
-110,015,438
– financial result from insurance contracts
3.1
-52,023,900
-124,991,075
-40,466,720
-115,748,853
– financial result from reinsurance contracts
3.2
Income from asset management
3.7.14
Non-attributable operating expenses
3.6
-107,124,023
-100,950,971
-42,673,764
-43,730,392
Net other operating income and expenses
3.7.14
-11,317,779
-8,138,587
-18,104,798
-15,861,691
Net other financial income and expenses
3.7.15
-13,609,808
-7,300,418
-12,299,219
-7,006,800
Net impairment and reversal of impairment of non-
financial assets
3.3
-66,398
-66,111
Gains and losses on investments in associates
3.7.16
Net other income and expenses
-307,307
EARNINGS BEFORE TAX FROM CONTINUING
OPERATIONS
EARNINGS BEFORE TAX FROM DISCONTINUED
OPERATIONS
Tax expense from continuing operations
3.7.17
-37,338,635
-27,624,088
-28,518,477
-19,352,563
Tax expense from discontinued operations
3.7.17
TOTAL NET EARNINGS FOR THE PERIOD
Net earnings per share (basic and diluted)
129
– controlling interests
– non-controlling interests
129
Basic earnings per share are calculated by dividing the shareholders' net profit by the weighted average number of ordinary shares, excluding
ordinary shares held by the Company or the Group. The Group and the Company do not have dilutive potential ordinary shares, thus the basic and
diluted earnings per share are the same.
223
1.3 Statement of other comprehensive income
in EUR
Triglav Group
Zavarovalnica Triglav
Notes
2025
2024
2025
2024
TOTAL NET EARNINGS FOR THE PERIOD
OTHER COMPREHENSIVE INCOME FOR THE PERIOD
AFTER TAX FROM CONTINUING OPERATIONS
Items that will not be reclassified to profit or loss in
future periods
– effects of equity instruments
– actuarial gains and losses related to employee
benefits
-144,838
-31,908
– other gains and losses that will not be reclassified
to profit or loss
– tax on items that will not be reclassified to profit
or loss
-90,656
-90,459
Items that may be reclassified to profit or loss in
future periods
– effects of insurance contracts
-25,712,354
-20,285,725
– effects of reinsurance contracts
-889,567
-1,116,705
– effects of debt instruments
-3,909,451
-5,919,121
– other gains and losses that may be reclassified to
profit or loss
– tax on items that may be reclassified to profit or
loss
-3,127,333
-1,136,174
-2,336,268
-4,476
Translation differences
-204,180
OTHER COMPREHENSIVE INCOME FOR THE PERIOD
AFTER TAX FROM DISCONTINUED OPERATIONS
-2,979
-2,979
TOTAL COMPREHENSIVE INCOME FOR THE PERIOD
AFTER TAX
Controlling interests
Non-controlling interests
224
1.4 Statement of changes in equity
in EUR
Reserves from profit
Triglav Group
Share
capital
Share
premium
Contingency
reserves
Legal and
statutory
reserves
Treasury
share
reserves
Treasury
shares
Other reserves from
profit
Accumulated
other
comprehensive
income
Retained
earnings
Net profit or
loss
Translation
differences
Total equity
attributable to
controlling
interests
Equity
attributable to
non-controlling
interests
Total
As at 1 January 2025
-364,680
-31,253,300
-3,074,712
Comprehensive income for the period
after tax
-141,575
-152,424
– net profit
– other comprehensive income
-141,575
-152,424
Dividend payment
-63,580,123
-63,580,123
-10,216
-63,590,339
Allocation of last year's net profit to
retained earnings
-75,049,031
Allocation of net profit to reserves
from profit
-60,801,127
Change in Group
As at 31 December 2025
-364,680
-15,658,675
-3,227,136
in EUR
Reserves from profit
Triglav Group
Share capital
Share
premium
Contingency
reserves
Legal and
statutory
reserves
Treasury
share
reserves
Treasury
shares
Other reserves
from profit
Accumulated
other
comprehensive
income
Retained
earnings
Net profit or
loss
Translation
differences
Total equity
attributable
to controlling
interests
Equity
attributable to
non-controlling
interests
Total
As at 1 January 2024
-364,680
-37,415,983
-7,192,538
-3,194,650
Comprehensive income for the period
after tax
– net profit
– other comprehensive income
-8,654
Dividend payment
-39,742,259
-39,742,259
-1,704
-39,743,963
Allocation of last year's net profit to
retained earnings
-7,192,538
Allocation of net profit to reserves from
profit
-55,844,921
Change in Group
-42,510
-42,510
As at 31 December 2024
-364,680
-31,253,300
-3,074,712
Notes to the changes in Group's equity are included in Section 3.7.10.
225
Notes to the changes in Company's equity are included in Section 3.7.10.
in EUR
Reserves from profit
Zavarovalnica Triglav
Share capital
Share premium
Legal and statutory
reserves
Other reserves from
profit
Accumulated other
comprehensive
income
Retained earnings
Net profit or loss
Total
As at 1 January 2025
-29,518,795
Comprehensive income for the period after tax
-141,575
– net profit
– other comprehensive income
-141,575
Dividend payment
-63,658,414
-63,658,414
Allocation of last year's net profit to retained earnings
-49,231,897
Allocation of net profit to reserves from profit
-55,600,000
As at 31 December 2025
-22,706,240
in EUR
Reserves from profit
Zavarovalnica Triglav
Share capital
Share premium
Legal and statutory
reserves
Other reserves from
profit
Accumulated other
comprehensive
income
Retained earnings
Net profit or loss
Total
As at 1 January 2024
-30,153,273
-4,782,244
Comprehensive income for the period after tax
– net profit
– other comprehensive income
Dividend payment
-39,786,509
-39,786,509
Allocation of last year's net profit to retained earnings
-4,782,244
Allocation of net profit to reserves from profit
-49,000,000
As at 31 December 2024
-29,518,795
226
227
2. Notes to the financial statements
228
229
230
130
All subsidiaries except Zavod Vse bo v redu, which is not material for the Group, are included in the consolidated financial statements according to the full consolidation method. GRI 207-4.
231
232
233
234
235
236
237
238
239
240
241
242
243
244
245
246
247
248
249
250
251
252
253
254
255
256
257
258
259
260
261
262
263
264
265
266
267
268
269
270
271
272
273
274
131
SASB: FN-IN-550a.2
275
276
277
278
279
280
281
132
ESRS GOV-5_01–05
282
133
SASB: FN-IN-550a.1
283
284
285
134
SASB: FN-IN-450a.1
286
287
288
289
290
291
292
293
294
295
296
297
298
299
300
301
302
303
304
305
306
307
308
309
310
311
312
313
314
315
316
317
318
319
320
321
322
323
324
325
326
327
328
329
330
331
332
333
334
335
336
337
338
339
340
341
342
343
344
345
346
347
348
349
350
351
352
353
354
355
356
357
358
359
360
361
362
363
364
365
366
367
368
369
370
371
372
373
374
375
376
377
378
379
380
381
382
383
384
385
386
387
388
389
390
391
392
393
394
395
396
397
398
399
400
401
402
403
404
405
406
407
408
409
410
411
412
413
135
The provisions of the Minimum Tax Act (ZMD) are interpreted and applied in accordance with the guidelines issued and published by the OECD,
which are continuously updated.
414
415
416
417
418
419
420
421
422
423
437
425
Appendix 1: Triglav Group as at 31 December 2025*
Insurance
Zavarovalnica Triglav d.d.
Pozavarovalnica Triglav Re d.d.
Triglav Osiguranje a.d.o., Belgrade
Triglav Osiguranje d.d., Zagreb
Address
Miklošičeva cesta 19, Ljubljana, Slovenia
Miklošičeva cesta 19, Ljubljana,
Slovenia
Milutina Milankovića 7a, Novi Beograd,
Serbia
Antuna Heinza 4, Zagreb, Croatia
Phone
+386 1 474 72 00, 080 555 555
+386 1 474 79 00
+381 11 330 51 00
+385 1 563 27 77
Email
info@triglav.si
info@triglavre.si
office@triglav.rs
info@triglav.hr
Website
www.triglav.si, www.triglav.eu
www.triglavre.si
www.triglav.rs
www.triglav.hr
Activity
Insurance
Reinsurance
Insurance
Insurance
Equity stake of Zavarovalnica
Triglav/the Triglav Group
100.00%/100.00%
- /100.00%
- /100.00%
Share of voting rights of Zavarovalnica
Triglav/the Triglav Group
100.00%/100.00%
- /100.00%
- /100.00%
Share capital
EUR 73,701,392
EUR 4,950,000
EUR 19,661,348
EUR 48,228,552
Nominal value of equity stake held by
Zavarovalnica Triglav/the Triglav
Group
EUR 4,950,000/EUR 4,950,000
- /EUR 19,661,348
- /EUR 48,228,552
Triglav Osiguranje d.d., Sarajevo
Lovćen Osiguranje a.d., Podgorica
Lovćen životna osiguranja a.d.,
Podgorica
Triglav Osiguruvanje a.d., Skopje
Address
Dolina 8, Sarajevo, Bosnia and
Herzegovina
Ulica slobode 13a, Podgorica,
Montenegro
Ulica Marka Miljanova 29/III,
Podgorica, Montenegro
Bulevar 8-mi Septemvri br. 16, Skopje,
North Macedonia
Phone
+387 33 252 110
+382 20 404 404
+382 20 231 882
+389 2 510 22 22
Email:
info@triglav.ba
info@lo.co.me
info@lovcenzivot.me
info@triglav.mk
Website
www.triglav.ba
www.lo.co.me
www.lo.co.me
www.triglav.mk
Activity
Insurance
Insurance
Insurance
Insurance
Equity stake of Zavarovalnica
Triglav/the Triglav Group
- /97.78%
- /99.07%
- /99.07%
- /82.01%
Share of voting rights of Zavarovalnica
Triglav/the Triglav Group
- /98.87%
- /99.07%
- /99.07%
- /82.01%
Share capital
EUR 10,861,337
EUR 10,459,925
EUR 3,700,000
EUR 3,008,425
Nominal value of equity stake held by
Zavarovalnica Triglav/the Triglav
Group
- /EUR 10,620,215
- /EUR 10,362,648
- /EUR 3,665,590
- /EUR 2,467,209
* Note: Company details are provided for the parent company and subsidiaries of the Triglav Group.
426
Triglav Osiguruvanje Život a.d., Skopje
Triglav Osiguranje a.d., Banja Luka
Address
Bulevar 8-mi Septemvri br. 18, Skopje,
North Macedonia
Ulica Prvog krajiškog korpusa 29,
Banja Luka, Bosnia and Herzegovina
Phone
+389 2 510 22 01
+387 51 215 262
Email
info@triglavzivot.mk
info@triglavrs.ba
Website
www.triglavzivot.mk
www.triglavrs.ba
Activity
Insurance
Insurance
Equity stake of Zavarovalnica
Triglav/the Triglav Group
- /100.00%
- /97.78%
Share of voting rights of Zavarovalnica
Triglav/the Triglav Group
- /100.00%
- /100.00%
Share capital
EUR 7,002,583
EUR 4,777,227
Nominal value of equity stake held by
Zavarovalnica Triglav/the Triglav
Group
- /EUR 7,002,583
- /EUR 4,671,173
Asset management
Triglav Investments d.o.o.
Triglav, pokojninska družba d.d.
Triglav, Upravljanje nepremičnin d.o.o.
Triglav penzisko društvo a.d., Skopje
Address:
Dunajska cesta 20, Ljubljana,
Slovenia
Dunajska cesta 22, Ljubljana, Slovenia
Dunajska cesta 22,
Ljubljana, Slovenia
Bulevar 8-mi Septemvri br. 18, Skopje,
North Macedonia
Phone:
+386 1 300 73 00, 080 10 19
+386 1 47 00 840, 080 555 555
+386 1 47 44 440
+389 2 510 21 90, 2 551 50 10
Email:
info@triglavinvestments.si
info@triglav.si
info@triglav-upravljanje.si
info@triglavpenzisko.mk
Website:
www.triglavinvestments.si
www.triglavpokojnine.si
www.triglav-upravljanje.si
www.triglavpenzisko.mk
Activity:
Mutual fund management
Pension funds
Asset management
Pension funds
Equity stake of Zavarovalnica Triglav/the
Triglav Group
100.00%/100.00%
100.00%/100.00%
100.00%/100.00%
100.00%/100.00%
Share of voting rights of Zavarovalnica
Triglav/the Triglav Group
100.00%/100.00%
100.00%/100.00%
100.00%/100.00%
100.00%/100.00%
Share capital
EUR 563,345
EUR 25,756,808
EUR 3,160,113
EUR 7,356,000
Nominal value of equity stake held by
Zavarovalnica Triglav/the Triglav Group
EUR 563,345/EUR 563,345
EUR 25,756,808/EUR 25,756,808
EUR 3,160,113/EUR 3,160,113
EUR 7,356,000/EUR 7,356,000
427
Triglav Investments d.o.o., Sarajevo
Triglav upravljanje nekretninama
d.o.o., Zagreb
Triglav upravljanje nekretninama
d.o.o., Sarajevo
Triglav upravuvanje so nedvižen imot
DOOEL, Skopje
Address
Ul. Mehmed paše Sokolovića br. 15,
Sarajevo, Bosnia and Herzegovina
Ulica Josipa Marohnića 1/1, Zagreb,
Croatia
Branilaca Sarajeva 45, Sarajevo, Bosnia
and Herzegovina
Dame Gruev br. 8, Skopje, North
Macedonia
Phone
+387 33 277 270
+386 31 370 370
+387 61 182 345
+386 31 370 370
Email
info@triglavfondovi.ba
Website
www.triglavfondovi.ba
Activity
Management of financial funds
Asset management
Asset management
Asset management
Equity stake of Zavarovalnica Triglav/the
Triglav Group
- /63.20%
- /100.00%
- /100.00%
- /100.00%
Share of voting rights of Zavarovalnica
Triglav/the Triglav Group
- /63.20%
- /100.00%
- /100.00%
- /100.00%
Share capital
EUR 632,466
EUR 514,673
EUR 998,710
EUR 2,161,000
Nominal value of equity stake held by
Zavarovalnica Triglav/the Triglav Group
- /EUR 399,719
- /EUR 514,673
- /EUR 998,710
- /EUR 2,161,000
Društvo za upravljanje Evropskim
dobrovoljnim penzijskim fondom, a.d.,
Banja Luka
Address
Kralja Petra I Karađorđevića 109/III
78000 Banja Luka,
Bosna in Hercegovina
Phone
+387 51 492 824
Email
office@epf.ba
Website
www.epf.ba
Activity
Management of funds and pension
funds
Equity stake of Zavarovalnica Triglav/the
Triglav Group
- /67.00%
Share of voting rights of Zavarovalnica
Triglav/the Triglav Group
- /67.00%
Share capital
EUR 2,249,684
Nominal value of equity stake held by
Zavarovalnica Triglav/the Triglav Group
- /EUR 1,507,288
428
Other
Triglav INT d.o.o.
Triglav Med d.o.o.
Triglav Svetovanje d.o.o.
Triglav Avtoservis d.o.o.
Address
Dunajska cesta 22, Ljubljana, Slovenia
Dunajska cesta 22, Ljubljana, Slovenia
Ljubljanska cesta 86, Domžale,
Slovenia
Verovškova 60b, Ljubljana, Slovenia
Phone
+386 1 430 95 34
+386 1 893 84 50
+386 1 724 66 50, 080 15 10
+386 1 580 68 72
Email
triglavint@triglav-int.si
info@triglavmed.si
info@triglav-svetovanje.si
info@triglav-avtoservis.si
Website
www.triglav-int.si
www.triglavmed.si
www.triglav-svetovanje.si
www.triglav-avtoservis.si
Activity
Holding company
Other human health activities
Insurance agency activities
Maintenance and repair of motor
vehicle
Equity stake of Zavarovalnica Triglav/the
Triglav Group
100.00% /100.00%
100.00% /100.00%
100.00%/100.00%
100.00%/100.00%
Share of voting rights of Zavarovalnica
Triglav/the Triglav Group
100.00%/100.00%
100.00% /100.00%
100.00%/100.00%
100.00%/100.00%
Share capital
EUR 77,180,734
EUR 7,500
EUR 8,763
EUR 43,663
Nominal value of equity stake held by
Zavarovalnica Triglav/the Triglav Group
EUR 77,180,734 /EUR 77,180,734
EUR 7,500 /EUR 7,500
EUR 8,763 /EUR 8,763
EUR 43,663 /EUR 43,663
Lovćen auto d.o.o., Podgorica
Autocentar BH d.o.o., Sarajevo
Sarajevostan d.o.o., Sarajevo
Triglav Savjetovanje d.o.o., Sarajevo
Address
Novaka Miloševa 6/2, Podgorica,
Montenegro
Džemala Bijedića 165b, Sarajevo,
Bosnia and Herzegovina
Bulevar Meše Selimovića 12, Sarajevo,
Bosnia and Herzegovina
Dolina 8, Sarajevo, Bosnia and
Herzegovina
Phone
+382 69 810 005
+387 33 715 935
+387 33 276 690
+387 3 361 81 06
Email
registracija@lovcen-auto.me
info@autocentarbh.ba
sastan@sarajevostan.com.ba
info@triglav-savjetovanje.ba
Website
www.lovcen-auto.me
www.autocentarbh.ba
www.sarajevostan.com.ba
www.triglav-savjetovanje.ba
Activity
Roadworthiness tests and vehicle
registration
Roadworthiness tests and vehicle
registration
Asset management
Insurance agency activities
Equity stake of Zavarovalnica Triglav/the
Triglav Group
- /99.07%
- /97.78%
- /90.95%
- /97.78%
Share of voting rights of Zavarovalnica
Triglav/the Triglav Group
- /99.07%
- /98.87%
- /91.97%
- /98.87%
Share capital
EUR 12,850,000
EUR 1,376,952
EUR 1,182,323
EUR 153,388
Nominal value of equity stake held by
Zavarovalnica Triglav/the Triglav Group
- /EUR 12,730,495
- /EUR 1,346,384
- /EUR 1,075,323
- /EUR 149,983
429
Triglav International d.o.o., Belgrade
Eskulap d.o.o.
Vse bo v redu, zavod Zavarovalnice
Triglav za družbeno odgovorne
aktivnosti
Address
Milutina Milankovića 7a, Belgrade,
Serbia
Redelonghijeva ulica 12, Ljubljana,
Slovenia
Miklošičeva cesta 19, Ljubljana,
Slovenia
Phone
+386 1 281 13 76, 1 893 84 51
+386 1 47 47 518
Email
info-int@triglav.rs
eskulap@tza.si
vsebovredu@triglav.si
Website
www.vsebovredu.triglav.si
Activity
Holding company
Other human health activities
Humanitarian and charity activities
Equity stake of Zavarovalnica Triglav/the
Triglav Group
- /100.00%
- /100.00%
100.00%/100.00%
Share of voting rights of Zavarovalnica
Triglav/the Triglav Group
- /100.00%
- /100.00%
100.00%/100.00%
Share capital
EUR 513,611
EUR 21,000
EUR 100,000
Nominal value of equity stake held by
Zavarovalnica Triglav/the Triglav Group
- /EUR 513,611
- /EUR 21,000
EUR 100,000/EUR 100,000
430
Appendix 2: Business network of the Triglav Group
In 2025, the Group continued to enhance its well-developed and client-accessible business
network. It strengthened cooperation with existing partners and sought new contractual
partners, while upgrading online and assistance services and expanding digital underwriting
sales channels.
The sales network in Slovenia consists of regularly employed staff (insurance agents, sales
representatives and employees at the Company's own points of sale), as well as a large number
of contractual partners, numbering approximately 450 in 2025.
In the non-life insurance segment, the Group successfully partners with car dealerships, leasing
companies, roadworthiness test providers, travel agencies, insurance brokerage and agency
companies, and hardware stores. In the life insurance segment, the Group works with insurance
agency and brokerage companies, as well as banks providing insurance agency services. Before
entering into a business relationship with a partner, the Group conducts due diligence and a risk
assessment with respect to personal data processing. In non-life claims settlement, the scope of
its partner network is adjusted to align with current demand. Business support applications for
contractual partners were updated, enabling the automated capture of various types of vehicle
damage and the automatic assessment of repair feasibility. For all types of assistance services,
the digitalisation of business interactions with partners continues through the establishment of
direct communication links or the provision of dedicated mobile applications. Using these tools,
stakeholders can track the settlement of claims in real time, and partner operations are
becoming fully digital. For partners in car repair shops and sales agencies, a user-friendly mobile
claims reporting application was developed. The subsidiaries in the Adria region maintain a
stable partner network, with a slight upward trend in the number of points of sale on external
insurance channels, particularly in Serbia and Croatia. The current number of external partners
in the region exceeds 1,700. Among the newest sales channels, cooperation with the postal
service as an agency channel in Croatia stands out. Across all countries, the number of
partnerships with insurance brokers continues to grow. The external sales network is smaller
only in the life insurance segment in Montenegro, due to stricter regulatory requirements for
external partners in this line of business.
Based on the principle of free movement of services, the Company is also present in other EU
markets, with the most developed partner networks in Greece, Italy and Poland.
Insurance
▪ Zavarovalnica Triglav d.d., Ljubljana – registered office
Regional centres:
▪ Central Slovenia region
▪ Gorenjska region
▪ West region
▪ South region
▪ North region
▪ East region
Zavarovalnica Triglav's existing sales network is available at
www.triglav.si/uporabno/poslovalnice.
▪ Zavarovalnica Triglav d.d., Branch Greece, Athens
▪ Pozavarovalnica Triglav Re d.d., Ljubljana – registered office
▪ Triglav Osiguranje d.d., Zagreb – registered office, the list of branch offices at
www.triglav.hr/korisno/poslovnice-i-kontakti
431
▪ Triglav Osiguranje a.d.o., Belgrade – registered office, the list of branch offices at
www.triglav.rs/korisno/mreza-poslovnica
▪ Lovćen Osiguranje a.d., Podgorica – registered office, the list of branch offices at
www.lo.co.me/korisne-informacije-i-kontakt/filijale-i-kontakti
▪ Triglav Osiguranje d.d., Sarajevo – registered office, the list of branch offices at
www.triglav.ba/korisno/poslovnice-i-kontakti
▪ Triglav Osiguranje a.d., Banja Luka – registered office, the list of branch offices at
www.triglavrs.ba/korisno/filijale-i-kontakti
▪ Triglav Osiguruvanje a.d., Skopje – registered office, the list of branch offices at
www.triglav.mk/korisno/lokacii-i-kontakti
▪ Triglav Osiguruvanje Život a.d., Skopje – registered office
▪ Lovćen životna osiguranja a.d., Podgorica – registered office
Asset management
▪ Triglav Investments d.o.o., Ljubljana – registered office, the list of branch offices at
www.triglavinvestments.si/
▪ Triglav, pokojninska družba d.d. – registered office
▪ Triglav, Upravljanje nepremičnin d.o.o., Ljubljana – registered office
▪ Triglav Investments d.o.o., Sarajevo – registered office
▪ Triglav penzisko društvo a.d., Skopje – registered office
▪ Triglav upravljanje nekretninama d.o.o., Zagreb – registered office
▪ Triglav upravljanje nekretninama d.o.o., Sarajevo – registered office
▪ Triglav upravuvanje so nedvižen imot DOOEL, Skopje – registered office
▪ Društvo za upravljanje Evropskim dobrovoljnim penzijskim fondom a.d., Banja Luka –
registered office
Other
▪ Triglav INT, holdinška družba d.o.o., Ljubljana – registered office
▪ Triglav Med d.o.o., Ljubljana – registered office
▪ Triglav Svetovanje d.o.o., Domžale – registered office
▪ Triglav Savjetovanje d.o.o., Sarajevo – registered office
▪ Triglav Avtoservis d.o.o., Ljubljana – registered office
▪ Lovćen auto d.o.o., Podgorica – registered office,
the list of branch offices at lovcen-auto.me/lokacije
▪ Autocentar BH d.o.o., Sarajevo – registered office, the list of branch offices at
www.autocentarbh.ba/poslovna-mreza
▪ Sarajevostan d.o.o., Sarajevo – registered office
▪ Triglav International d.o.o., Belgrade – registered office
▪ Eskulap d.o.o., Ljubljana – registered office
432
Appendix 3: Glossary of terms
Inward reinsurance
The activity of a reinsurance company to assume from other insurance and reinsurance
companies the portion of underwriting risks which exceeds their retention limits.
Accumulated profit
The legally justified amount of net profit for the year (net earnings for the year), net profit
brought forward (retained earnings) and reserves from profit, which in accordance with the
decision of the insurance company's management board is first used to increase reserves (legal
reserves, treasury share reserves and treasury shares, and statutory reserves) and other reserves
according to the supervisory board's decision. The remainder, referred to as accumulated profit,
is allocated by the general meeting of shareholders to dividends, other reserves, carry-forwards
and other purposes.
Cedent
A party to a reinsurance contract who passes a portion of their assumed risks to reinsurance. The
recipient of those risks is usually an insurance company. To cede means to pass a portion of
assumed risk to a reinsurance company.
Total return on share
The sum of growth in the share price in the accounting period and the dividend yield as at the
reporting date.
Net earnings per share
The ratio of net earnings in the accounting period which refers to the ordinary shareholders of
the controlling company to the weighted average number of ordinary shares less ordinary shares
held by Zavarovalnica Triglav or the Triglav Group members.
Free float
Shares held by shareholders who own 5% or less of shareholders' equity.
Economic value distributed
Comprises claims incurred, net reinsurance service result, finance expenses from financial and
insurance contracts, other expenses, dividend payments, labour costs, tax expense and
community investment (prevention, donations, sponsorships).
Dividend yield
The ratio of gross dividends per share to price per share on a given day.
Supplemental insurance/rider
Insurance that is underwritten as a supplement to another (precisely defined) insurance and that
cannot be underwritten independently.
Investment return/investment result
A difference between income and expenses from financial investments. Income from financial
investments comprises income from investments in associates and income from investments
(interest income, dividend income, gains on financial investments from revaluation at fair value,
reversal of impairment, gains on disposal of investments and other income from investments).
Expenses from financial investments comprise expenses from investments in associates and
433
expenses from investments (impairment of investments, losses on the disposal of investments,
losses on financial investments from revaluation at fair value and other expenses from
investments). Return on own investment portfolio does not include the effect of unit-linked life
insurance assets and financial investments from financial contracts.
Endowment (for life insurance products with a savings component)
An insured event in which the insurance company pays the sum insured, together with bonuses
after the insured survives the agreed insurance period.
Financial investments
On initial recognition, a financial investment is classified into one of the following measurement
categories:
▪ financial investments measured at fair value through profit or loss (FVTPL),
▪ financial investments measured at amortised cost (AC),
▪ financial assets measured at fair value through other comprehensive income (FVOCI).
Financial contracts
Contracts that take the form of an insurance contract but do not meet the definition of an
insurance contract under IFRS 17. Distinct investment components of pension insurance
contracts are also treated as financial contracts because these contracts do not bear insurance
risk during the accumulation (savings) phase.
Capitalisation
The reduction of sums insured in life insurance with a savings component, which is carried out
if the policyholder stops paying the premium. In addition to standard criteria for setting the
premium (gender and age of the insured), the amount of the sum insured depends primarily on
the number of paid-in premiums and the remaining insurance term.
Book value per share
The ratio of shareholders' equity to the number of outstanding shares as at the reporting date.
Onerous contracts
Non-profitable insurance contracts where all cash flows arising from an insurance contract
together represent a negative net present value of the cash flow.
Composite (or universal, general) insurance company
An insurance company that conducts non-life and life insurance business.
Gross/net
In the insurance industry, the terms gross and net typically relate to quantities and ratios before
and after the deduction for reinsurance.
Own Risk and Solvency Assessment (ORSA)
The insurance company's own assessment of the risks to which it is exposed in the course of its
business, including the risks to which it may be exposed in the future, and an assessment of the
adequacy of own funds available to cover them.
Measurement of insurance contracts under MSRP 17
The following methods are used to measure insurance contracts:
▪ The general model or building block approach (BBA) is the default model used for all long-
term insurance contracts.
434
▪ The simplified approach or premium allocation approach (PAA) is used for the measurement
of insurance contracts with short-term coverage (usually applicable to non-life insurance
policies with short-term coverage).
▪ The variable fee approach (VFA) is typically applied to life insurance contracts with direct
participation features (unit-linked contracts).
Operating expenses
Operating expenses are recognised as original costs by nature. They are classified into functional
cost groups (acquisition costs, claim handling expenses, asset management costs and other
administrative costs) and into costs attributable and non-attributable to insurance contracts.
Surrender
The termination of a life insurance policy that results in the payout of the value thereof (saved
assets and mathematical provisions less the costs incurred by the insurance company).
Contractual Service Margin (CSM)
Represents the estimated unearned profit of insurance contracts, which will be recognised in the
statement of profit or loss over the coverage period of the insurance service. It is calculated based
on the present value of expected future cash flows (inflows and outflows) of the group of
insurance contracts and the risk adjustment for non-financial risk.
Share average daily turnover
The ratio of the total value of share turnover in the accounting period to the number of trading
days in that period.
Reinsurance
Reinsurance is the business of accepting risks ceded by an insurance or reinsurance company.
Prevention
The portion of non-life insurance premium that an insurance company allocates to prevention
activities to mitigate future risks.
Associate
A company in which another entity directly or indirectly holds between 20% and 50% of voting
rights, and thus has a significant effect on capital, but does not control that company.
Insurance revenue
Revenue from insurance contracts issued under IFRS 17 that do not include a savings component.
Risk Adjustment for non-financial risk (RA)
Relates to the compensation set by the insurance company because it bears uncertainty about
the amount and timing of the cash flows that arises from non-financial risk.
Risk profile
A risk profile is a quantitative assessment of the risks to which an insurance company is exposed.
In order to adequately identify the risk profile, processes are established, and risk exposure and
measurements are defined for every type of risk for the purpose of assessing the extent thereof.
Deferred Acquisition Costs – DAC
An accounting deferral of costs incurred by the insurer in acquiring a new insurance contract,
deferred evenly over the entire term of the contract. In this way, a one-off cost incurred at the
inception of the insurance contract is spread evenly over the entire insurance term.
435
Available own funds
Available own funds are used to cover the solvency capital requirement and represent the
surplus of assets over liabilities, plus subordinated liabilities, taking into account other
regulatory, insurer-specific adjustments.
Reserves from profit
Comprise other reserves from profit, legal and statutory reserves, contingency reserves and
credit risk equalisation reserves.
Solvency II
The European Union's regulatory framework in the field of insurance, which defines the
calculation of capital adequacy and the governance of and reporting by insurance companies. An
insurance company's available own funds must be at least equal to the assessment of assumed
risks, as set as out in the regulatory framework.
Coinsurance
A way to equalise risks, where assumed risks are split or spread among several insurance
companies. The proportion of risk assumed by an individual insurance company may vary and
represents the basis for determining an individual insurance company's share of the premium
and potential loss. Each insurance company is jointly and severally liable to the insured, i.e. for
the full amount of benefits and/or claims from an insurance contract, irrespective of the
proportion of risk it assumes.
Contractual service margin sustainability
The contractual service margin sustainability shows the ratio of the contractual service margin
(CSM) of new contracts to the release of the contractual service margin to profit or loss.
Market capitalisation
The value of a company calculated as the product of the closing share price and the number of
shares on the reporting date.
Economic value generated
Comprises total revenue and finance income from financial and insurance contracts.
Comprehensive income
Comprehensive income consists of two components. The first component comprises net
earnings for the year from the statement of profit or loss. The second component comprises
other comprehensive income, which discloses income and expense items not recognised in the
statement of profit or loss, but which affect the amount of shareholders' equity. The recognition
of business events in net earnings or other comprehensive income is aligned with IFRS.
Movements in other comprehensive income mainly arise from the revaluation of assets at fair
value and the financial effects of the valuation of insurance and reinsurance contracts.
Economic value retained
The difference between economic value generated and economic value distributed.
Solvency Capital Requirement (SCR)
The amount of an insurance company's capital that it needs to remain solvent for at least one
year with a 99.5% probability calculated in accordance with Solvency II. It is calculated according
to a statutory standard formula that takes into account all material measurable risks:
underwriting, market, credit and operational risks.
436
Insurance density (premium per capita)
The ratio of gross written premium to the number of inhabitants of a particular country.
Insurance penetration
Insurance premium as a proportion of gross domestic product (GDP).
Insurance premium
The amount set out in an insurance contract that the policyholder pays to the insurance
company. Insurance premium covers the payment of current and future claims, the costs of
prevention activities and the insurance company's operating expenses.
Insurance class
Various insurance types that are grouped in accordance with the Slovenian Insurance Act based
on the main types of risks they cover. The Slovenian Insurance Act defines 24 different insurance
classes.
Insurance contract
A contract is defined as an insurance contract when, at the time of conclusion, significant
insurance risk is accepted from the policyholder.
437
Appendix 4: Alternative performance measures
ALTERNATIVE PERFORMANCE MEASURE
DEFINITION OF CALCULATION
EXPLANATION OF USE AND LIMITATIONS
Total business volume
Comprises gross written premium and other income.
A measure broader than gross written premium, it is useful for comparison between product
segments, regions and, to a limited extent, companies. However, it is not suitable for disclosing
profitability, as it is influenced by fluctuations that are not directly related to the way the
business is conducted, such as price changes, changes in foreign exchange rates, and changes in
the business network and products (e.g. acquisitions, spin-offs, transfers).
Total revenue
Comprises insurance revenue, asset management
income, other operating income and other income.
This measure is designed to compare product segments, regions and, to a limited extent,
companies. However, it is not suitable for disclosing profitability,
as it is influenced by fluctuations that are not directly related to the way the business is
conducted, such as price changes, changes in foreign exchange rates, and changes in the
business network and products (e.g. acquisitions, spin-offs, transfers).
Costs/insurance service expenses to gross
written premium
Represents costs/insurance service expenses to gross
written premium excluding financial contracts
(supplemental voluntary pension insurance premium
– SVPI).
This metric is designed for monitoring, comparison and cost control. It is used to assess the
efficiency of resource use and to support decision-making in cost optimisation.
Return on equity (ROE)
The ratio of net earnings for the period to the average
balance of shareholders' equity in the period.
It enables annual comparability of profitability data and provides a quick annual assessment.
Rate of return on investment
The ratio of return on investment to the average
balance of financial investments. Own investment
portfolio includes financial investments, investments
in associates, loans granted, bank deposits and other
financial investments, but excludes unit-linked life
insurance assets, financial investments from financial
contracts and investment property.
This measure is suitable for monitoring the success of management and profitability of financial
investment management.
However, it is influenced by external factors that companies can manage through other
processes (such as currency risk and interest rate risk management) and that are not directly
reflected in the result of this measure, such factors related to existing agreements or
commitments in cases of acquisitions, mergers and similar transactions.
New business margin/new business margin of
life insurance/new business margin Life
The ratio of the sum of the contractual service margin
(CSM) of new contracts to the loss of onerous
contracts recognised for new policies and the present
value of new premium.
It measures the profitability of new business in the insurance industry.
However, its use is limited by actuarial estimates and assumptions, which are based on
historical or current data and do not account for potential future changes, such as shifts in client
behaviour or the country's development.
Capital adequacy ratio
The ratio of available own funds eligible to cover the
solvency capital requirement to the solvency capital
requirement.
It is a legal obligation and the necessary practice of due diligence.
It serves as a measure of an insurer's financial stability, in accordance with the provisions of
Solvency II.
Combined ratio/CoR Non-Life & Health
The sum of the expense ratio and claims ratio.
It measures the profitability of contracts in the Non-Life, Health, or both segments, excluding
investment returns. A value of less than 100% indicates profit from a particular segment.
However, this measure does not reveal the absolute values of the calculation and, therefore,
does not directly explain the underlying reasons for the values.
438
ALTERNATIVE PERFORMANCE MEASURE
DEFINITION OF CALCULATION
EXPLANATION OF USE AND LIMITATIONS
CSM of new contracts/Total CSM
The ratio of the contractual service margin (CSM) of
new contracts in the reporting period to the total
contractual service margin.
It is appropriate for monitoring the future effects of new business.
Caution is required when assessing it during the year, as business events do not necessarily
follow the dynamics of the previous year. Similarly, the impact of any one-off or non-recurring
events should likewise be assessed. The measure is applied to insurance contracts that are not
measured using the premium allocation approach (PAA).
Gross written premium
The sum of all premiums that the insurance company
charges to policyholders following the underwriting or
renewal of policies in the accounting period.
Gross written premium is primarily useful as a measure of business growth for comparing
various regions and segments.
Gross written premium does not provide information on the profitability of the company/group
and should always be considered alongside IFRS measures of revenue and profitability (e.g. net
profit or loss for the period).
Gross claims paid
Benefits and claims calculated for all or a portion of
settled claims in the accounting period, including
claim settlement costs.
This measure shows the actual calculated costs from claims during the reporting period. It is
useful for comparison over time and across various segments,
though it is subject to the impact of claims inflation.
Claims incurred
Comprise insurance service expenses for claims,
change in future cash flows, change in experience
correction, loss of onerous contracts, allocation to
onerous contracts and the remaining insurance
expenses.
The purpose of this measure is to show the estimated effect of claims on the company's current
and future operations.
The estimate incorporates actuarial assumptions, which may differ due to actual future events.
Expense ratio
The ratio of the sum of attributable and non-
attributable costs to insurance revenue.
The expense ratio is a component of the combined ratio and plays a crucial role in explaining the
cost-effectiveness impact.
However, as it does not present absolute values in its calculation, it does not directly explain the
underlying reasons for its value.
Net investment result
Comprises the investment result, the financial result
from insurance contracts, gains and losses on
investments in associates, net gains or losses from the
impairment of investments in associates and the
change in the provisions for not achieving the yield on
supplemental voluntary pension insurance.
This measure should be assessed in conjunction with the investment result under IFRS 1, while
also considering the broader context of financial investment markets and financial expenses
from insurance contracts.
However, it is not suitable for predicting future business performance.
Insurance operating result/result from
insurance operations
Comprises insurance revenue less claims incurred and
acquisition and administrative costs, including non-
attributable costs, net reinsurance service result and
net other insurance income/expenses.
This measure is suitable for analysing business performance of insurance operations, as it
improves the comparability of profitability over time.
Additionally, this measure is subject to fluctuations influenced by factors beyond business
operations, such as foreign exchange rates.
Result from non-insurance operations
The sum of the categories that are not included in the
insurance operating result and the net investment
result.
This measure is suitable for analysing the performance of non-insurance operations and other
business events. Additionally, this measure is subject to fluctuations influenced by factors
beyond the performance of analysed business operations, such as foreign exchange rates.
It is appropriate to monitor this measure through reporting by business segment.
439
ALTERNATIVE PERFORMANCE MEASURE
DEFINITION OF CALCULATION
EXPLANATION OF USE AND LIMITATIONS
Assets under management (AUM)
Comprise own investment portfolio, assets from the
pension insurance savings funds, unit-linked insurance
assets, assets in mutual funds and discretionary
mandate assets, and alternative investments.
It shows the scope and effectiveness of asset management; however, it is important to consider
its limitations, including the impact of potential takeovers, disposals or mergers, as well as
fluctuations in currency rates.
Claims ratio
The ratio of the sum of claims, change in future cash
flows, change in experience correction, change in
onerous contracts and the reinsurance result to
insurance revenue.
It reflects both the realised and estimated future effects of loss events on insurance revenue and
serves as an appropriate measure for monitoring the impact of realised loss events within a
given period. It is also useful for comparison across segments and regions.
However, this measure does not provide absolute values or reflect the overall performance of
the company's operations. Additionally, it is influenced by external factors, such as inflation.
440
Appendix 5: The list of ESRS disclosure requirements included in the sustainability
statement
157
The list of material disclosure requirements
Page
ESRS 2 – General disclosures
BP-1 – General basis for preparation of the sustainability statement
117-118
BP-2 – Disclosures in relation to specific circumstances
118-119, 147
GOV-1 – The role of the administrative, management and supervisory bodies
120, 122, 179
GOV-2 – Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies
120, 122, 124, 138
GOV-3 – Integration of sustainability-related performance in incentive schemes
122, 124
GOV-4 – Statement on due diligence
124
GOV-5 – Risk management and internal controls over sustainability reporting
119
SBM-1 – Strategy, business model and value chain
125, 127, 132, 174
SBM-2 – Interests and views of stakeholders
119, 132, 134, 135, 138, 141,
156-157, 170-171, 182, 184
SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business model
119, 134
IRO-1 – Description of the process to identify and assess material impacts, risks and opportunities
118, 120, 125, 138, 156, 157
IRO-2 – Disclosure Requirements in ESRS covered by the undertaking’s sustainability statement
Page of Appendix 5
E1 – Climate change
ESRS 2 GOV-3-E1 – Integration of sustainability-related performance in incentive schemes
122
E1-1 – Transition plan for climate change mitigation
145, 158
ESRS 2 SBM-3-E1 – Material impacts, risks and opportunities and their interaction with strategy and business model
134, 156
ESRS 2 IRO-1-E1 – Description of the processes to identify and assess material climate-related impacts, risks and opportunities
156-157
E1-2 – Policies related to climate change mitigation and adaptation
144
E1-3 – Actions and resources in relation to climate change policies
145, 146
E1-4 – Targets related to climate change mitigation and adaptation
144-145, 147-148, 151, 154
E1-5 – Energy consumption and mix
150
E1-6 – Gross Scopes 1, 2, 3 and Total GHG emissions
146-147, 154
E1-9 – Anticipated financial effects from material physical and transition risks and potential climate-related opportunities
157
S1 – Own workforce
ESRS 2 S1.SBM-2 – Interests and views of stakeholders
132, 134, 135, 138
ESRS 2 S1.SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business model
141, 170-171
S1-1 – Policies related to own workforce
171, 176-177, 178, 180-181
S1-2 – Processes for engaging with own workforce and workers’ representatives about impacts
172
157
ESRS 2 IRO-2_02.
441
The list of material disclosure requirements
Page
S1-3 – Processes to remediate negative impacts and channels for own workforce to raise concerns
178
S1-4 – Taking action on material impacts on own workforce, and approaches to managing material risks and pursuing material opportunities related
to own workforce, and effectiveness of those actions
172, 176-177, 188
S1-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
179
S1-6 – Characteristics of the undertaking's employees
175-176
S1-7 – Characteristics of non-employees in the undertaking’s own workforce
117
S1-9 – Diversity metrics
178
S1-10 – Adequate wages
180
S1-13 – Training and skills development metrics
176
S1-14 – Health and safety metrics
177
S1-15 – Work-life balance metrics
181
S1-16 – Remuneration metrics (pay gap and total remuneration)
181
S4 – Consumers and end-users
ESRS 2 S4.SBM-2 – Interests and views of stakeholders
132, 134, 135, 138
ESRS 2 S4.SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and business model
182, 184, 165, 157
S4-1 – Policies related to consumers and end-users
182, 183, 185, 187-188
S4-2 – Processes for engaging with consumers and end-users about impacts
182, 183, 185, 186
S4-4 – Taking action on material impacts on consumers and end- users, and approaches to mitigating material risks and pursuing material
opportunities related to consumers and end-users and effectiveness of those actions
183, 185, 186
S4-5 – Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
183
G1 – Business conduct
ESRS 2 G1.GOV-1 – The role of the administrative, supervisory and management bodies
120
G1-1 – Business conduct policies and corporate culture
188-190, 192-193
G1-2 – Management of relationships with suppliers
193-194
G1-3 – Prevention and detection of corruption and bribery
190-192
G1-4 – Incidents of corruption or bribery
192
G1-6 – Payment practices
194
442
Appendix 6: The list of datapoints in cross-cutting and topical standards that derive from
other EU legislation
158
Disclosure ESRS 2 IRO-2, paragraph 56, and ESRS 2, Appendix B
Disclosure requirement and related datapoint
SFDR reference
Pillar 3 reference
Benchmark regulation
reference
EU Climate Law
reference
Material/
not material
Page
ESRS 2 GOV-1
Board's gender diversity, paragraph 21 (d)
Indicator number 13 of
Table #1 of Annex I
Commission
Delegated Regulation
(EU) 2020/1816,
Annex II
179
ESRS 2 GOV-1
Percentage of board members who are independent,
paragraph 21(e)
Delegated Regulation
(EU) 2020/1816,
Annex II
Not material
120
ESRS 2 GOV-4
Statement on due diligence, paragraph 30
Indicator number 10 Table
#3 of Annex I
124
ESRS 2 SBM-1
Involvement in activities related to fossil fuel activities,
paragraph 40(d)i
Indicators number 4 Table
#1 of Annex I
Article 449a of Regulation (EU) No
575/2013;
Commission Implementing Regulation
(EU) 2022/2453, Table 1: Qualitative
information on Environmental risk and
Table 2: Qualitative information on
Social risk
Delegated Regulation
(EU) 2020/1816,
Annex II
Not material
156
ESRS 2 SBM-1
Involvement in activities related to chemical
production, paragraph 40(d)ii
Indicator number 9 Table
#2 of Annex I
Delegated Regulation
(EU) 2020/1816,
Annex II
Not material
156
ESRS 2 SBM-1
Involvement in activities related to controversial
weapons, paragraph 40(d)iii
Indicator number 14 Table
#1 of Annex I
Delegated Regulation
(EU) 2020/1818,
Article 12(1)
Delegated Regulation
(EU) 2020/1816,
Annex II
Not material
156
158
ESRS 2 IRO-2_01.
443
Disclosure requirement and related datapoint
SFDR reference
Pillar 3 reference
Benchmark regulation
reference
EU Climate Law
reference
Material/
not material
Page
ESRS 2 SBM-1
Involvement in activities related to cultivation and
production of tobacco, paragraph 40(d)iv
Delegated Regulation
(EU) 2020/1818,
Article 12(1)
Delegated Regulation
(EU) 2020/1816,
Annex II
Not material
156
ESRS E1-1
Transition plan to reach climate neutrality by 2050,
paragraph 14
Regulation (EU)
2021/1119,
Article 2(1)
144
ESRS E1-1
Undertakings excluded from Paris-aligned
Benchmarks, paragraph 16(g)
Article 449a of Regulation (EU) No
575/2013;
Commission Implementing Regulation
(EU) 2022/2453, Template 1: Banking
book – Indicators of potential climate
change transition risk: credit quality of
exposures by sector, emissions and
residual maturity
Delegated Regulation
(EU) 2020/1818,
Article
article 12(1), points (d)
to (g), and Article 12(2)
Not material
/
ESRS E1-4
GHG emission reduction targets, paragraph 34
Indicator number 4 Table
#2 of Annex I
Article 449a of Regulation (EU) No
575/2013;
Commission Implementing Regulation
(EU) 2022/2453, Template 3: Banking
book – Indicators of potential climate
change transition risk: alignment
metrics
Delegated Regulation
(EU)
2020/1818, Article 6
144
ESRS E1-5
Energy consumption from fossil sources disaggregated
by sources (only high climate impact sectors),
paragraph 38
Indicator number 5 Table
#1 and Indicator n. 5 Table
#2 of Annex I
Not material
/
ESRS E1-5
Energy consumption and mix paragraph, 37
Indicator number 5 Table
#1 of Annex I
150
ESRS E1-5
Energy intensity associated with activities in high
climate impact sectors, paragraphs 40 to 43
Indicator number 6 Table
#1 of Annex I
Not material
/
444
Disclosure requirement and related datapoint
SFDR reference
Pillar 3 reference
Benchmark regulation
reference
EU Climate Law
reference
Material/
not material
Page
ESRS E1-6
Gross Scope 1, 2, 3 and Total GHG emissions,
paragraph 44
Indicators number 1 and 2
Table #1 of Annex I
Article 449a of Regulation (EU) No
575/2013;
Commission Implementing Regulation
(EU) 2022/2453, Template 1: Banking
book – Indicators of potential climate
change transition risk: credit quality of
exposures by sector, emissions and
residual maturity
Delegated Regulation
(EU) 2020/1818,
Articles 5(1), 6 and
8(1)
147
ESRS E1-6
Gross GHG emissions intensity, paragraphs 53 to 55
Indicators number 3 Table
#1 of Annex I
Article 449a of Regulation (EU) No
575/2013;
Commission Implementing Regulation
(EU) 2022/2453, Template 3: Banking
book – Indicators of potential climate
change transition risk: alignment
metrics
Delegated Regulation
(EU)
2020/1818, Article
8(1)
147
ESRS E1-7
GHG removals and carbon credits, paragraph 56
Regulation (EU)
2021/1119,
Article 2(1)
Not material
/
ESRS E1-9
Exposure of the benchmark portfolio to climate-related
physical risks, paragraph 66
Delegated Regulation
(EU) 2020/1818,
Appendix II; Delegated
Regulation (EU)
2020/1816, Appendix
II
/
ESRS E1-9
Disaggregation of monetary amounts by acute and
chronic physical risk paragraph 66(a)
ESRS E1-9
Location of significant assets at material physical risk
paragraph 66(c)
Article 449a of Regulation (EU) No
575/2013;
Commission Implementing Regulation
(EU) 2022/2453, paragraphs 46 and 47;
Template 5: Banking book – Indicators of
potential climate change physical risk:
exposures subject to physical risk
/
445
Disclosure requirement and related datapoint
SFDR reference
Pillar 3 reference
Benchmark regulation
reference
EU Climate Law
reference
Material/
not material
Page
ESRS E1-9
Breakdown of the carrying value of its real estate
assets by energy-efficiency classes paragraph 67(c)
Article 449a of Regulation (EU) No
575/2013;
Commission Implementing Regulation
(EU) 2022/2453, paragraph 34; Template
2: Banking book – Indicators of potential
climate change transition risk: loans
collateralised by immovable property –
energy efficiency of the collateral
/
ESRS E1-9
Degree of exposure of the portfolio to climate- related
opportunities, paragraph 69
Delegated Regulation
(EU) 2020/1818,
Appendix II
/
ESRS E2-4
Amount of each pollutant listed in Annex II of the E-
PRTR Regulation (European Pollutant Release and
Transfer Register) emitted to air, water and soil,
paragraph 28
Indicator number 8 Table
#1 of Annex I Indicator
number 2 Table #2 of
Annex I Indicator number
1 Table #2 of Annex I
Indicator number 3 Table
#2 of Annex I
Not material
/
ESRS E3-1
Water and marine resources, paragraph 9
Indicator number 7 Table
#2 of Annex I
Not material
/
ESRS E3-1
Dedicated policy, paragraph 13
Indicator number 8 Table
2 of Annex I
Not material
/
ESRS E3-1
Sustainable oceans and seas, paragraph 14
Indicator number 12 Table
#2 of Annex I
Not material
/
ESRS E3-4
Total water recycled and reused, paragraph 28(c)
Indicator number 6.2
Table #2 of Annex I
Not material
/
ESRS E3-4
Total water consumption in m
3
per net revenue on
own operations, paragraph 29
Indicator number 6.1
Table #2 of Annex I
Not material
/
ESRS 2 – IRO-1 – E4, paragraph 16(a), point (i)
Indicator number 7 Table
#1 of Annex I
Not material
/
ESRS 2 – IRO-1 – E4, paragraph 16(b)
Indicator number 10 Table
#2 of Annex I
Not material
/
446
Disclosure requirement and related datapoint
SFDR reference
Pillar 3 reference
Benchmark regulation
reference
EU Climate Law
reference
Material/
not material
Page
ESRS 2 – IRO-1 – E4, paragraph 16(c)
Indicator number 14 Table
#2 of Annex I
Not material
/
ESRS E4-2
Sustainable land/agriculture practices or policies,
paragraph 24(b)
Indicator number 11 Table
#2 of Annex I
Not material
/
ESRS E4-2
Sustainable oceans/seas practices or policies,
paragraph 24(c)
Indicator number 12 Table
#2 of Annex I
Not material
/
ESRS E4-2
Policies to address deforestation, paragraph 24(d)
Indicator number 15 Table
#2 of Annex I
Not material
/
ESRS E5-5
Non-recycled waste, paragraph 37(d)
Indicator number 13 Table
#2 of Annex I
Not material
/
ESRS E5-5
Hazardous waste and radioactive waste, paragraph 39
Indicator number 9 Table
#1 of Annex I
Not material
ESRS 2 – SBM-3 – S1
Risk of incidents of forced labour, paragraph 14(f)
Indicator number 13 Table
#3 of Annex I
Not material
/
ESRS 2 – SBM-3 – S1
Risk of incidents of child labour, paragraph 14(g)
Indicator number 12 Table
#3 of Annex I
Not material
/
ESRS S1-1
Human rights policy commitments, paragraph 20
Indicator number 9 Table
#3 and Indicator number
11 Table #1 of Annex I
176
ESRS S1-1
Due diligence policies on issues addressed by the
fundamental International Labor Organisation
Conventions 1 to 8, paragraph 21
Delegated Regulation
(EU) 2020/1816,
Annex II
178
ESRS S1-1
Processes and measures for preventing trafficking in
human beings, paragraph 22
Indicator number 11 Table
#3 of Annex I
Not material
/
ESRS S1-1
Workplace accident prevention policy or management
system, paragraph 23
Indicator number 1 Table
#3 of Annex I
176
447
Disclosure requirement and related datapoint
SFDR reference
Pillar 3 reference
Benchmark regulation
reference
EU Climate Law
reference
Material/
not material
Page
ESRS S1-3
Grievance/complaints handling mechanisms,
paragraph 32(c)
Indicator number 5 Table
#3 of Annex I
178
ESRS S1-14
Number of fatalities and number and rate of work-
related accidents, paragraph 88(b) and (c)
Indicator number 2 Table
#3 of Annex I
Delegated Regulation
(EU) 2020/1816,
Annex II
176
ESRS S1-14
Number of days lost to injuries, accidents, fatalities or
illness, paragraph 88(e)
Indicator number 3 Table
#3 of Annex I
178
ESRS S1-16
Unadjusted gender pay gap, paragraph 97(a)
Indicator number 12 Table
#1 of Annex I
Delegated Regulation
(EU) 2020/1816,
Annex II
181
ESRS S1-16
Excessive CEO pay ratio paragraph 97(b)
Indicator number 8 Table
#3 of Annex I
Not material
/
ESRS S1-17
Incidents of discrimination, paragraph 103(a)
Indicator number 7 Table
#3 of Annex I
/
ESRS S1-17
Non-respect of UNGPs on Business and Human Rights
and OECD, paragraph 104(a)
Indicator number 10 Table
#1 and Indicator n. 14
Table #3 of Annex I
Delegated Regulation
(EU) 2020/1816,
Annex II Delegated
Regulation (EU)
2020/1818, Article
12(1)
/
ESRS 2 – SBM-3 – S2
Significant risk of child labour or forced labour in the
value chain, paragraph 11(b)
Indicators number 12 and
13
Table #3 of Annex I
Not material
/
ESRS S2-1
Human rights policy commitments, paragraph 17
Indicator number 9 Table
#3 and Indicator number
11 Table #1 of Annex I
Not material
/
ESRS S2-1
Policies related to value chain workers, paragraph 18
Indicators number 11 and
4 Table #3 of Annex I
Not material
/
448
Disclosure requirement and related datapoint
SFDR reference
Pillar 3 reference
Benchmark regulation
reference
EU Climate Law
reference
Material/
not material
Page
ESRS S2-1
Non-respect of UNGPs on Business and Human Rights
principles and OECD guidelines, paragraph 19
Indicator number 10 Table
#1 of Annex I
Delegated Regulation
(EU) 2020/1816,
Annex II Delegated
Regulation (EU)
2020/1818, Article
12(1)
Not material
/
ESRS S2-1
Due diligence policies on issues addressed by the
fundamental International Labor Organisation
Conventions 1 to 8, paragraph 19
Delegated Regulation
(EU) 2020/1816,
Annex II
Not material
/
ESRS S2-4
Human rights issues and incidents connected to its
upstream and downstream value chain, paragraph 36
Indicator number 14 Table
#3 of Annex I
Not material
/
ESRS S3-1
Human rights policy commitments, paragraph 16
Indicator number 9 Table
#3 of Annex I and
Indicator number 11 Table
#1 of Annex I
/
ESRS S3-1
Non-respect of UNGPs on Business and Human Rights,
ILO principles or and OECD guidelines, paragraph 17
Indicator number 10 Table
#1 of Annex I
Delegated Regulation
(EU) 2020/1816,
Annex II Delegated
Regulation (EU)
2020/1818, Article
12(1)
Not material
/
ESRS S3-4
Human rights issues and incidents, paragraph 36
Indicator number 14 Table
#3 of Annex I
Not material
/
ESRS S4-1
Policies related to consumers and end-users, paragraph
16
Indicator number 9 Table
#3 and Indicator number
11 Table #1 of Annex I
183
449
Disclosure requirement and related datapoint
SFDR reference
Pillar 3 reference
Benchmark regulation
reference
EU Climate Law
reference
Material/
not material
Page
ESRS S4-1
Non-respect of UNGPs on Business and Human Rights
principles and OECD guidelines, paragraph 17
Indicator number 10 Table
#1 of Annex I
Delegated Regulation
(EU) 2020/1816,
Annex II Delegated
Regulation (EU)
2020/1818, Article
12(1)
/
ESRS S4-4
Human rights issues and incidents, paragraph 35
Indicator number 14 Table
#3 of Annex I
/
ESRS G1-1
United Nations Convention against Corruption,
paragraph 10(b)
Indicator number 15 Table
#3 of Annex I
188
ESRS G1-1
Protection of whistleblowers, paragraph 10(d)
Indicator number 6 Table
#3 of Annex I
189-190
ESRS G1-4
Fines for violation of anti-corruption and anti-bribery
laws, paragraph 24(a)
Indicator number 17 Table
#3 of Annex I
Delegated Regulation
(EU) 2020/1816,
Annex II
192
ESRS G1-4
Standards of anti-corruption and anti-bribery,
paragraph 24(b)
Indicator number 16 Table
#3 of Annex I
192