LocalTapiola General Mutual Insurance
Company
Report of the Board of Directors and financial
statements for 2025
Business ID: 0211034-2
Table of contents
Report of the Board of Directors for 2025
1Key information
2Key events during the financial year
3Solvency and the risk position
4Events after the financial year
5Future prospects
6Governance of LocalTapiola Group
7Sustainability statement
8Proposal for the use of profit
Financial statements for 1 January 2025 - 31 December 2025
9Consolidated financial statements, LocalTapiola Group
10Parent company, LocalTapiola General
11Accounting principles
12Notes on risk management
Signatures for the report of the Board of Directors and financial statements
Auditor’s note
LocalTapiola General | Report of the Board of Directors for 2025
1
Report of the Board of Directors
for 2025
LocalTapiola General Mutual Insurance Company
(LocalTapiola General) is domiciled in Espoo, Finland, and its
business ID is 0211034-2. LocalTapiola General provides
voluntary and statutory non-life insurance.
As the ultimate parent company, LocalTapiola General
prepares the consolidated financial statements of
LocalTapiola Group to the extent determined for insurance
groups as defined in the Insurance Companies Act. The
business areas of LocalTapiola Group are non-life insurance,
life insurance, asset management, and motor vehicle finance
and corporate lending.
1 Key information
• In 2025, LocalTapiola Group’s premiums written increased in both
non-life and term life insurance, and our business also continued to
grow in asset management and motor vehicle finance.
• In spite of the uncertainty that shook the investment market,
different asset classes provided a positive yield, and the investment
year ultimately turned out largely as expected.
• LocalTapiola Group’s solvency remained strong and operating result
for 2025 was EUR 445.9 million (in 2024: EUR 630.8 million). Total
result, which also reflects changes in the valuation differences of
investments, was EUR 576.8 million (EUR 835.6 million).
• LocalTapiola Group’s market position consolidated in several
business areas:
• In non-life insurance, direct premiums written grew 6.2 per cent.
According to statistics by Finance Finland published in 2025, we
became the market leader in workers’ compensation insurance, as
measured by premiums written. We further consolidated our position
as the motor liability insurance market leader, as measured by the
number of insurance contracts, and we are also the market leader in
farm insurance. 
• In term life insurance, we are the market leader in Finland, and
premiums written for term life insurance increased 4.2 per cent.
LocalTapiola Life’s total premiums written grew 0.7 per cent.
• At year-end, assets under management by LocalTapiola Asset
Management Group were EUR 35.2 billion, representing year-on-year
growth of 8.9 per cent. Seligson & Co, which is part of LocalTapiola
Asset Management Group, grew to become the fourth-largest fund
management company in Finland.
• LocalTapiola Finance is Finland’s second-largest motor vehicle
finance company, and despite the difficult market situation, the
finance portfolio under its management grew 1.0 per cent.
• As outlined in our Owner Intent, we focus on increasing customer
benefits for our owner-customers. In 2025, we credited our customers
EUR 139.6 million (EUR 123.5 million) in non-life and life insurance
customer bonuses and EUR 45.1 million (EUR 41.5 million) in S Group
bonus on insurance premiums. Overall, LocalTapiola Group had 1.8
million (1.8 million) customers.
• Sari Heinonen started as LocalTapiola Group’s President on 1 May
2025.
• Antti Pulkkanen started as Managing Director of LocalTapiola
General on 1 August 2025.
• In the 2025 Report of the Board of Directors, we report sustainability
information for LocalTapiola Group as required under the Accounting
Act.
LocalTapiola General | Report of the Board of Directors for 2025
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LocalTapiola Group
Volume and profitability of insurance operations
2025
2024
Non-life insurance, Premiums written in direct insurance,
EUR m
1,604.2
1,510.9
Life insurance, Premiums written, EUR m
418.9
416.0
Combined ratio (excl. unwinding of discount expense), %
91.2
96.2
Risk ratio, %
61.8
66.3
Cost ratio, %
29.4
29.9
Claims and customer benefits
Claims paid, non-life insurance, EUR m
1,014.6
1,035.2
Claims paid, life insurance, EUR m
393.5
409.1
Customer credits, non-life and life insurance, EUR m
139.6
123.5
S Bonus, EUR m
45.1
41.5
Result and solvency
Operating profit, EUR m
445.9
630.8
Total result, EUR m
576.8
835.6
Solvency ratio, %
196.3
201.7
Solvency ratio = amount of eligible own funds as compared to the Solvency
Capital Requirement (Solvency II). Solvency calculation does not fall within
the remit of statutory audit. The formulae for calculating the key figures are
described in the financial statements. The comparative figures for the profit
and loss account items and for the periodic key figures (shown in
parentheses) are those reported for 1 January 2024 - 31 December 2024. The
comparative figures for the balance-sheet and other cross-sectional key
figures (shown in parentheses) are those representing the situation on 31
December 2024
2 Key events during the financial year
2.1 Non-life insurance
2.1.1 Non-life insurance activities of LocalTapiola
Group
The non-life insurance activities of the group comprise LocalTapiola General,
the regional non-life insurance companies and Finnish P&C Insurance Ltd.
LocalTapiola General is active in the businesses of workers’ compensation
insurance, insurance for large corporate clients, and reinsurance. The business
activity of the LocalTapiola regional companies consists in the provision of
insurance to private and farm customers, and to small and medium-sized
enterprises. Finnish P&C Insurance Ltd provides non-life insurance to private
customers by utilising digital service channels in particular.
Our operational starting point is to deliver benefit to owner-customers.
LocalTapiola is there for its customers. Our aim is to produce the greatest
customer benefit and customer satisfaction achievable – at a competitive
price. We measure how the financial benefits of owner-customers develop. In
our group strategy, we seek profitable growth, a sound customer base and
sustainable success over the long term.
As our business landscape is becoming increasingly digital, we continued
improving the online services of both private and corporate customers and
clients across our insurance, saving and investment services. By developing
digital services, we facilitate customer self-service for routine transactions in
order to ensure smooth multichannel service as well as wide access to
specialist services in more complex transaction needs.
A high customer retention rate is testament to the satisfaction of our owner-
customers. A large-scale reform of insurance systems is ongoing in both non-
life insurance and life insurance.
Direct premiums written in non-life insurance amounted to  EUR 1604.2
million (EUR 1510.9 million), representing year-on-year growth of 6.2 per cent.
Premiums were affected by price increases and indexation, and the growth in
premiums written was supported by the consistently high customer retention
rate. In terms of our lines of business, growth was strongest in voluntary
personal insurance, where premiums written increased 9.5 per cent. Over the
LocalTapiola General | Report of the Board of Directors for 2025
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course of 2025, we consolidated our position as the motor liability insurance
market leader by 0.4 percentage points. Measured by the number of
insurance contracts, our market share at year-end was 37.4 per cent.
Furthermore, we are also the market leader in farm insurance, with a market
share of 66 per cent as the principal insurer of farms
LocalTapiola Group
Development of direct premiums written, by group of classes, EUR million
For the second consecutive year, non-life insurance claims paid to customers
exceeded one billion euros, but claims development and inflation moderated
compared to the past couple of years. Claims paid decreased 2.0 per cent
year-on-year, with the actual figure at EUR 1,014.6 million (EUR 1,035.2
million). The number of claims increased further in some lines of business,
including medical expenses insurance and pet insurance. However, the volume
of building, motor and occupational accident claims decreased compared to
2024. Following the Hannes storm, which in December buffeted western
Finland in particular, 2025 recorded the highest claims expenditure volume
for storms in the 2020s.
There were 91 (93) property and business claims for catastrophes worth at
least EUR 300,000, slightly fewer the year before. Our gross claims
expenditure for these claims was EUR 60.0 million (EUR 85.1 million).
LocalTapiola Group’s non-life insurance claims incurred were EUR 1,096.7
million (EUR 1,101.6 million) and the group’s risk ratio, which describes the
profitability of the core insurance business, excluding the unwinding of
discount rate, was 61.8 per cent (66.3%). The actual figure includes non-
recurring changes made to the actuarial principles, both in 2025 and in the
comparison period, that decreased claims incurred in both years.
Increased non-life insurance volumes, wage inflation and investments made in
operational development have raised the group’s operating expenses. Non-
life insurance operating expenses were EUR 449.8 million (EUR 434.8 million),
but as a result of good growth in premiums earned, the cost ratio, which
measures the efficiency of non-life insurance, improved 0.5 percentage
points to 29.4 per cent (29.9%).
Balance on the technical account before the change in the equalisation
provision was EUR 111.8 million (EUR 36.4 million). The combined ratio
excluding the unwinding of discount rate was 91.2 per cent (96.2%).
In non-life insurance, premiums written, premiums earned and claims incurred
include non-recurring items related to changes in the actuarial principles and
method of calculation of technical provisions. The combined impact from the
items improved the balance on the technical account before the change in
the equalisation provision by EUR 48.7 million. The changes are described in
more detail in the accounting principles of the financial statements.
2.1.2 LocalTapiola General
For LocalTapiola General, 2025 was a good year in terms of sales and
investment. During the year, direct premiums written increased 7.3 per cent
to EUR 282.4 million. Premiums written strengthened particularly in voluntary
personal insurance and property insurance. All in all, premiums written
increased 3.0 per cent.
In 2025, we surpassed goals in non-life insurance sales to large clients. Sales
were strongest in corporate property and business insurance.
LocalTapiola General | Report of the Board of Directors for 2025
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We serve large clients across Finland, with six teams responsible for clients in
their respective geographical regions, and five sectorally organised teams
serving our clients in the Helsinki Metropolitan Area.
We offer large clients LocalTapiola Group’s products and services for non-life
insurance, life insurance, asset management, finance and remuneration, and
earnings-related pension products and services provided by a partner. In
2025, we continued to invest strongly in developing our broker services.
During 2025, we launched a new responsible client selection guideline and
approach. We continued to invest in our employees’ sustainability
competences and preventive risk management. In our Sustainability Report,
we published a PCAF-based GHG emission calculation for the corporate
clients that we insure.
LocalTapiola has several ongoing projects for developing insurance products
and services of corporate clients. It is of particular importance for us that the
projects address client needs. In 2025, an increasing number of our specialists
participated in these projects, in various different roles. Internally, we
deployed, among other things, a new telephone system and a host of
artificial-intelligence tools.
The profitability of our claims service continued to improve during the year. A
mild winter reduced the number of occupational accidents. Lead times for
claims in the statutory lines of business, and the claims service’s workload,
were at a good level throughout the year. The close cooperation by the claims
service with occupational healthcare and client companies produced good
results. The Accident Appeal Board’s rate of revision – an indicator of the
quality of claims handling – decreased further from the previous year, and
LocalTapiola’s figure was the smallest for large companies.
For investment, the year 2025 was very much as expected. LocalTapiola
General’s investment income was 4.7 per cent (EUR 168.5 million). Driven by
equity investments, the return on investment in all asset classes was clearly
positive. Returns on listed equities, in particular, were good. Furthermore, the
return on fixed-income investments was also positive, aided by the clearly
higher interest rates as compared to recent years. The return on sovereign
debt investments, used to hedge the interest rate risk of technical provisions,
remained approximately 4% negative following a rise in long-term interest
rates. On the other hand, the increased interest rates decreased the present
value of the technical provisions of the group’s insurance companies, thereby
improving solvency. Also, the return on illiquid investments was positive, which
was primarily due to alternative investments and investment loans. As a result
of steady rent cash flows, returns from real estate investments were
moderately positive, although property values continued to show a slight
decline.
Due to a strong return on investment, LocalTapiola General’s capital and
reserves position enhanced by some EUR 83 million during the year. The
solvency ratio at the end of the financial year was 337 per cent. The company
meets regulatory requirements clearly. 
LocalTapiola Group deployed a new HR system, Hertta. At LocalTapiola
General, we continued to pursue the systematic development of
competences, focusing on the core skills we have identified, including
leadership, management, technological and customer experience
competences. We invested in improving collaboration between teams, units
and companies by developing more effective structures and enhancing our
communications. We increased management’s and employees’ awareness and
understanding of diversity and inclusion. Based on the Roihu employee survey,
our employee experience was good and leadership was excellent.
LocalTapiola General 
Volume and profitability of insurance operations
2025
2024
Premiums written in direct insurance, EUR m
282.4
263.2
Change %
7.3
3.4
Margin before change in equalisation provision, EUR m
25.4
13.5
Combined ratio (excl. unwinding of discount expense), %
87.8
92.1
Risk ratio, %
62.6
64.9
Cost ratio, %
25.2
27.2
Claims paid, EUR m
198.7
198.5
Result and solvency
Operating profit, EUR m
152.0
279.7
Total result, EUR m
194.4
325.4
Solvency ratio, %
336.6
346.5
2.2 Life insurance
A sound financial basis has allowed us to develop our products, processes and
services, and increase customer benefits. An increasing number of Finns have
recognised how important it is to personally prepare for the future. In risk
insurance, we have strengthened our market leader position, and we expect
this growth to also continue in the coming years.
LocalTapiola General | Report of the Board of Directors for 2025
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We have invested in corporate clients and the development of remuneration
services. In 2024, we founded a remuneration services company to
complement the service offering of LocalTapiola Group. Employee
engagement is becoming increasingly important for companies, and they
want to hold on to top talents.
Employee satisfaction remained strong. We focused on customer service,
ensuring the availability of consistently high‑quality service across all
customer processes. These successes contributed to the continued positive
development of customer experience.
We continued the development of co-investment service models and
products. With LocalTapiola’s assistance, our owner-customers get to invest
in instruments in which we also invest. In future, we will be seeking strong
growth in the savings life insurance sector.
We continued the development project to reform our core systems, with the
aim of considerably improving customer experience by providing increasingly
smoother services and by investing in making services more understandable
and relevant. Our system reform and lifelong security strategy are both based
on excellent customer experience.
LocalTapiola Life’s total premiums written increased 0.7 per cent to EUR
418.9 million (EUR 416.0 million). The good development of premiums written
continued in term life insurance. In term life insurance, premiums written
increased 4.5 per cent. The premiums written for savings life insurance fell 0.8
per cent, while the premiums written for group pension insurance declined 0.4
per cent.
LocalTapiola Life paid its customers EUR 393.5 million (EUR 409.1 million) in
claims. EUR 132.4 million (EUR 124.8 million) was paid in pensions, EUR 26.3
million (EUR 22.6 million) in reimbursement for medical expenses and
disability benefits and EUR 54.6 million (EUR 48.3 million) in death benefits.
LocalTapiola Life’s operating profit was EUR 130.3 million (EUR 218.3 million)
and total result was EUR 121.7 million (EUR 232.6 million). Investment income
at fair value was 2.1 per cent, or EUR 61.9 million (6.1%, or EUR 177.6 million).
The company’s underwriting result developed well. Risk result was EUR 60.4
million (EUR 54.7 million), and expense result was EUR 3.0 million (EUR 5.6
million). Expense result includes items treated as loading income.
2.3 Investment markets, and the insurance
companies’ investments 
Investment aims to generate value for our owner-customers in the interests
of insureds. Investment income enables us to maintain solvency and provide
competitive services in the future. 
In the financial market, equity prices increased in 2025 across the board. The
eventful year was marked particularly by President Trump’s volatile trade and
economic policies, which caused significant market swings in the first half of
the year. In the second half of the year, the strong rise in the stock markets
was supported by stronger‑than‑expected economic and performance
developments, a reduction in trade policy uncertainty, a strengthening of
investor risk appetite, and continued enthusiasm for artificial intelligence.
Unlike in recent years, the performance of the European and Finnish stock
markets was stronger than in the United States. As for bonds, high-risk
corporate bonds and emerging market bonds, in particular, performed well. A
significant weakening of the U.S. dollar reduced the euro‑denominated
returns of dollar‑denominated investments.
At the start of the year, the overall outlook for the financial markets
regarding economic and performance growth prospects is reasonably
positive. Global economic growth is expected to continue in 2026 close to the
previous year’s level. The outlook for the international economy improved in
the second half of 2025 as trade policy uncertainty eased, but politics and
geopolitical tensions continue to be surrounded by significant uncertainty. In
the financial markets as well, the most significant risk factors are linked to
politics and geopolitics. In addition, sovereign debt challenges, the reduced
fiscal space for stimulus, and elevated asset valuations may, in weaker
scenarios, cause instability in the economic and financial system.
For investment, 2025 proved very much as expected for the LocalTapiola
Group insurance companies, with a positive return on investment in all asset
classes, driven by equity investments. As a result of higher technical provisions
and a weaker profit from the fixed-income investments hedging them,
LocalTapiola Life’s profit fell short of the profit recorded by the group’s non-
life insurance companies. As a whole, the LocalTapiola Group insurance
companies’ net investment income for 2025 was EUR 434 million (EUR 728
million). Returns on listed equities, in particular, were good. Furthermore, the
return on fixed-income investments was positive, with risky corporate bonds
performing extremely well. The return on sovereign debt investments, used to
hedge the interest rate risk of technical provisions, remained negative
following a rise in long-term interest rates. On the other hand, the increased
LocalTapiola General | Report of the Board of Directors for 2025
6
interest rates decreased the present value of technical provisions, thereby
improving the solvency of the companies. The return on illiquid investments
was positive, which was primarily due to alternative investments and
investment loans. As a result of steady rent cash flows, returns from real
estate investments were moderately positive, although property values
continued to show a slight decline. 
Taken as a whole, the risk level of the investment portfolios of the group’s
insurance companies is moderate in relation to risk-bearing capacity.
LocalTapiola General’s net investment income at fair value for 2025 was 4.7
per cent (9.4%). Of all investments, more than 47.7% were equity
investments. LocalTapiola General’s average five-year annual investment
income was 4.4 per cent (4.1%), and the average ten-year annual investment
income was 4.3 per cent (4.4%).
LocalTapiola General
Investment activities
2025
2024
Return on investment at current value, %
4.7
9.4
Fixed-income investments
2.8
4.5
Equity investments
7.8
15.4
Real estate investments
1.2
3.2
Other investments
6.6
5.2
Investment allocation, %
Fixed-income investments
33.5
35.2
Equity investments
47.7
45.1
Real estate investments
18.6
19.5
Other investments
0.2
0.3
LocalTapiola General’s investment assets at fair value were EUR 3,646.1
million in 2025 (EUR 3,496.9 million in 2024).
The LocalTapiola regional companies recorded a 5.3 per cent (6.1%) fair-value
rate of return on investments.
LocalTapiola Life’s net investment income at fair value was 2.1 per cent
(6.1%), or EUR 62 million (EUR 178 million). LocalTapiola Life’s average five-
year annual investment income was 2.3 per cent (2.4%).
2.4 Asset management
Apart from LocalTapiola Life, services for saving and investment are provided
by the following companies: LocalTapiola Asset Management Ltd, which acts
as asset manager for investment clients; Seligson & Co Fund Management
Company Plc, which engages in the funds business; alternative investment
fund manager LocalTapiola Alternative Investment Funds Ltd (merged to
Seligson & Co Fund Management Company Plc on 31 December 2025) and its
subsidiaries; and real estate investment manager LocalTapiola Real Estate
Asset Management Ltd and its subsidiaries. Together, the companies make up
LocalTapiola Asset Management Group, whose parent company is
LocalTapiola Asset Management Ltd.
On 31 December 2025, LocalTapiola Alternative Investment Funds Ltd was
merged to Seligson & Co Fund Management Company Plc. After the merger,
Seligson & Co Fund Management Company Plc manages LocalTapiola Asset
Management Group’s all funds. The concentration of the fund management
companies clarifies the operations of LocalTapiola Asset Management Group,
enabling services to be produced more efficiently.
Relating to the merger, the group has centralised activities, harmonised
processes and carried out system integrations. The measures support
LocalTapiola’s investment services growth strategy while enabling a stronger
focus on the development of customer experience and services.
In early 2025, LocalTapiola Asset Management Group published updated
climate strategy milestones for 2030. In autumn, the real estate division
prepared new goals for nature-related action and updated its climate goals.
LocalTapiola Asset Management Group’s operating result excluding
amortisation of goodwill on consolidation increased EUR 2.2 million year on
year, buoyed by favourable market developments. LocalTapiola Asset
Management Group’s turnover was EUR 62.5 million (EUR 60.0 million) and
operating result was EUR -0.5 million (EUR -2.7 million). Operating result
excluding amortisation of goodwill on consolidation was EUR 6.5 million (EUR
4.3 million).
In the equity market, 2025 was a strong year, as was 2024. A strengthening
of the global economic cycle, a slowdown in inflation and an easing of
monetary policy boosted investor risk appetite, which was reflected in a
broad-based rise in equity prices. In addition, credit risk rewarded investors,
and the returns on high-risk corporate bonds and emerging market fixed-
income investments, in particular, were exceptionally good. As a result of
positive developments, net commissions received by LocalTapiola Asset
LocalTapiola General | Report of the Board of Directors for 2025
7
Management Group from equity and fixed-income investment management
rose 5.0 per cent year on year.
Net commissions from real estate operations fell 1.7 per cent in 2025. During
2025, trading activity in the Finnish real estate market picked up significantly
compared with the previous year. There were no significant changes in the
yield requirements of properties during 2025. The LocalTapiola Group
companies did not make any new real estate investments during 2025. We
largely managed to maintain the occupancy rates for commercial properties
at a good level, and although the residential rental market remains
challenging, occupancy rates have in many areas improved as the demand–
supply balance has stabilised.
For private equity funds, the positive outlook seen at the beginning of 2025
faded with the introduction of Liberation Day tariffs. However, the
LocalTapiola private equity and private debt funds continued on the growth
path. The LocalTapiola Private Equity VI LP fund held its last closing in
November (EUR 428 million), and for the LocalTapiola Private Debt III LP fund,
investments were completed when the fund made its final investment in July.
LocalTapiola Asset Management Group’s net commissions from private
equity and private debt funds increased 25.1 per cent.
The (gross) assets under management by the LocalTapiola Asset
Management Group companies totalled EUR 35.2 billion (EUR 32.3 billion). Of
these, EUR 16.7 billion (EUR 15.2 billion) was in assets in portfolio
management, and EUR 14.3 billion (EUR 12.7 billion) was in fund capitals, EUR
1.5 billion (EUR 1.6 billion) in other contractually managed assets and EUR 2.8
billion (EUR 2.8 billion) in administered real estate.
2.5 Finance
2.5.1 Motor vehicle finance 
The year 2025 continued the strong development achieved in 2024. Despite
challenges in the business landscape both in the Finnish economy and in the
automotive market, our competitive position as a motor vehicle finance
company improved. Our market share of new sales increased, and the market
share of the financed vehicle stock also rose. Our position as the
second‑largest motor vehicle finance company in Finland strengthened during
2025, and our refinancing position is strong. We completed one public
securitisation transaction worth over EUR 575 million, and we have more than
EUR 1.3 billion in bilateral securitisation facilities with various banks. In
addition to securitisation and LocalTapiola Group, our funding sources
include bilateral loans, the commercial paper market and the green finance
bond market. In 2025, our receivables from customers increased to EUR 2.5
billion as profitability improved. Our operating result improved, soaring 28%
to EUR 17.1 million. The credit rating agency Standard & Poor’s maintained
LocalTapiola Finance Ltd’s credit rating unchanged at the ‘BBB’ level with a
stable outlook.
2.5.2 Corporate lending
LocalTapiola General is the company pursuing corporate lending activity at
LocalTapiola. In 2025, the corporate lending and real estate financing
portfolio remained qualitatively good. During 2025, the volume of corporate
lending increased slightly compared to the turn of the year, while real estate
financing volumes decreased as planned. Investments by businesses as well as
M&A activity picked up slightly compared with 2024, particularly towards the
end of 2025. In new real estate financing projects, we continued to take a
cautious approach, as in the two previous years. We mainly participated in
the refinancing of our existing real estate loans, while also financing a small
number of new real estate projects during 2025. LocalTapiola will continue
the cooperation with EU guarantee programmes, and in 2025 LocalTapiola’s
corporate client finance division still participated in two different guarantee
programmes that offer additional collateral for the finance provided to
corporate entities.
2.6 Ancillary activity
In the reporting year, the ancillary activity of the LocalTapiola Group
insurance companies included the marketing of services related to saving and
investment, finance services and insurance products. As ancillary activity, the
group’s insurance companies also engaged in marketing cooperation with
partners operating in the risk management and loss prevention sector.
Furthermore, companies belonging to LocalTapiola Group, including
LocalTapiola Remuneration Services Ltd, LocalTapiola Finance Ltd and
LocalTapiola Asset Management Group, used the organisation and
distribution channels of insurance companies to market their own products
and services.
2.7 Credit rating
The credit rating agency Standard & Poor’s has been performing a credit
rating evaluation on LocalTapiola Group since 2019.
Standard & Poor’s on 10 December 2025 confirmed LocalTapiola General’s
‘A’ rating with a stable outlook. This rating was affected by the group’s
strong solvency and good performance in recent years. The rating and the
outlook are equivalent to the previous rating in November 2024. Standard &
LocalTapiola General | Report of the Board of Directors for 2025
8
Poor’s believes that LocalTapiola will continue to maintain its leading position
on the Finnish insurance market.
3 Solvency and the risk position
At LocalTapiola Group, risk and prudential management is based on the risk
management policy and the prudential management principles, which are
confirmed annually at the group’s Boards of Directors. The purpose is to
ensure that the interests of policyholders, compensation recipients and other
beneficiaries are safeguarded while defining standard operating procedures
for risk and prudential management for LocalTapiola Group and its
companies. On the subject of risks and risk management, we have prepared a
note to these financial statements, which discusses, inter alia, the
organisation and responsibilities of risk management.
3.1 Prudential management
Prudential management is part of the risk management undertaken by the
group and its companies. The starting point for prudential management is
that the group and the companies have sufficient solvency capital to meet
their obligations, with due consideration of expected and unexpected losses.
It follows from operating as a group of mutual companies that prudential
management emphasises good solvency across the group and its companies,
so as to ensure the financial security of customers at all times.
LocalTapiola Group constitutes an insurance group within the meaning of the
Insurance Companies Act and an insurance and financial conglomerate within
the meaning of the Act on the Supervision of Financial and Insurance
Conglomerates. As the ultimate parent company, LocalTapiola General is
tasked with ensuring that the group and its companies fulfil the legal solvency
requirements. The solvencies of LocalTapiola Group and its insurance
companies are calculated by employing the Solvency II standard formula.
Solvency calculation does not fall within the remit of statutory audit.
A Joint Liability Agreement has been concluded between LocalTapiola
General and the regional companies with the aim of safeguarding the
solvency of the LocalTapiola Group companies. The Agreement defines the
policy and the decision-making procedures for the extraordinary situation
that the solvency of a group company is being or may be jeopardised.
According to the Agreement, LocalTapiola General and the regional
companies are obliged, where necessary, to capitalise another group
company, provided that the capitalising company’s own solvency is
sufficiently strong and will remain so after the capitalisation. The amount of
capitalisation to be provided under the Agreement is restricted in proportion
to the assets of the capitalising company.
The Joint Liability Agreement also contains terms whereby the solvency of
LocalTapiola Mutual Life Insurance Company and of the group’s asset
management companies (LocalTapiola Asset Management Ltd, LocalTapiola
Real Estate Asset Management Ltd, LocalTapiola Alternative Investment
Funds Ltd) can, where necessary, be supported under corresponding
principles, in proportions commensurate with the guarantee capital holdings
and share capital holdings. As applicable, the principles laid down in the Joint
Liability Agreement also apply to ensuring the solvency of LocalTapiola
Finance Ltd. However, these companies are not parties to the Joint Liability
Agreement, and consequently they cannot rely on the Agreement to demand
additional capitalisation.
The LocalTapiola Group non-life insurance companies are among the most
solvent companies in their sector in Finland, and currently the solvency of all
group companies is strong. More details about the group’s prudential
management are provided in the Solvency and Financial Condition Reports at
www.lahitapiola.fi/tietoa-lahitapiolasta/lahitapiola-ryhma/lahitapiola-
ryhman-raportit. The LocalTapiola Group report for 2025 will be published by
8 April 2026.
LocalTapiola General | Report of the Board of Directors for 2025
9
3.2 Solvency position
The solvency ratio of LocalTapiola General at the end of the financial year
(the company’s eligible own funds as compared to the Solvency Capital
Requirement) was 337 per cent (346%), while the solvency ratio of
LocalTapiola Group was 196 per cent (202%).
The solvency ratios of LocalTapiola Group and the non-life insurance
companies part of it mainly weakened during the financial year, nevertheless
remaining strong. An increase in the value of investment assets, and market
risk growth, particularly for equity and currency risk, increased the market-
risk capital requirement for several companies. For LocalTapiola General,
increased non-life insurance risk and market risk had an increasing impact on
the amount of the capital requirement.
Solvency position 2025
(% / EUR million)
Solvency ratio
Own funds
Solvency capital
requirement
LocalTapiola General
337%
2,693.1
800.1
Group's other non-life
insurance companies
271%
2,571.9
949.9
LocalTapiola Life
254%
1,464.9
577.8
LocalTapiola Group
196%
4,630.8
2,359.6
3.3 Risk position
The main risks to operations are insurance risks in the non-life insurance
business; insurance risks in the life insurance business; market risks associated
with investment activities; operational risks; and risks relating to the
operating environment and the strategy.
In the non-life insurance business, the main insurance risks relate to the
pricing and underwriting of insurance products, inflation, interest rate
fluctuations, mortality rate changes, occupational diseases, and reinsurance
covers.
In the life insurance business, the main insurance risks include risks associated
with technical provisions and the customer behaviour-related risks of
termination of contracts and interruption of the payment of premiums.
Market risk is caused by fluctuations in the market values of assets, including,
for example, fluctuation that is due to changes in interest rates, share prices
or foreign exchange rates.
Operational risk refers to the risk of loss resulting from inadequate or failed
internal processes, personnel, systems and external factors. Legal risks are
included in operational risks.
Operating environment and strategy risks include, for example, risks
associated with the general operating landscape; with changes in the markets
and in customer behaviour; with the competitive situation and competitors;
and with the content and implementation of the strategy.
On the basis of the group’s assessment model, the LocalTapiola Group
companies identify and assess risks on the basis of their likelihood and
potential impacts, defining responsible persons and scheduled management
actions for each risk. The Boards of the companies approve the risk
management plan, which includes a summary of the relevant company’s risk
appetite, risk tolerance based on various metrics, and risk assessment by risk
category. Furthermore, as part of the sustainability reporting process, we
implement a CSRD-compliant double materiality assessment that addresses
not only LocalTapiola Group’s impacts on the environment and society, but
also the financial effects, relating to sustainability topics, that impact the
activities of LocalTapiola Group. Sustainability reporting risk management is
described in this document in section ESRS 2 GOV-5 Risk management and
internal controls over sustainability reporting.
The financial sector is very dependent on the general economic landscape
and its development. According to forecasts by the Bank of Finland, Finland’s
recovery from the recession will be slow. According to the forecast (December
2025), Finland’s economy will grow by approximately 0.2% in 2025. Economic
recovery will be muted, with the development hindered in particular by trade
war escalation, general uncertainty in the global economy and a weak labour
market situation. Inflation is expected to remain moderate, while the increase
in prices will be slow. At the same time, general government finances will
remain in deficit, and the debt‑to‑GDP ratio will continue to rise due to
measures including tax cuts and higher defence spending. Increasing trade
and geopolitical tensions are weighing on global developments, and this has
also been felt in Finland. However, household incomes are rising, with the rate
of price increases remaining moderate. Falling borrowing rates will support
the recovery of consumption and investment. Public expenditures will
continue to exceed revenues, causing government indebtedness to increase
further.
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10
Geopolitical tensions in Ukraine, the Middle East and Greenland are
heightening uncertainty further in the global economy. In Finland, fiscal policy
tightening may weaken private consumption more strongly than expected in
the short term. In an economic recession, both individuals and businesses may
reduce insurance purchases to save costs. This can lead to a decrease in the
premiums written by insurers.
In the insurance sector, operating environment and strategy risks are
heightened by the concurrent uncertainty in the geopolitical and financial
landscape as well as by the ever-increasing pace of change in the operating
landscape: including digital transformation, consolidation, new types of
entities and consortia, demographic change, internationalisation and climate
change. Uncertainty in the operating landscape, and the materialisation of
different types of shock to the financial sector, expose the financial market
to sudden market swings. If materialised, negative asset price developments,
for example on the equity and bond markets, would increase the investment
losses of businesses. Furthermore, the situation in the real estate sector and
the construction industry remains difficult, which increases both credit risks
and risks related to the valuation of real estate investments. However, as we
move into early 2026, a clear recovery is expected in the property markets in
Finland and across the Nordic countries. The normalisation of interest rates,
easing inflation and cautious economic growth support a pick‑up in the
markets.
Over the longer term, financial sector entities will be challenged not only by
unstable economic conditions, but also by long-term trends including climate
change impacts and the measures aimed at preventing them; demographic
change; digitalisation; new technologies, products, policies and approaches;
and cyber risks. 
More details about LocalTapiola Group’s risk management and key risks are
provided in the risk management notes to the financial statements and in the
Solvency and Financial Condition Report at www.lahitapiola.fi/tietoa-
lahitapiolasta/lahitapiola-ryhma/lahitapiola-ryhman-raportit.
4 Events after the financial year 
According to a decision issued by the Financial Supervisory Authority, Turva
Mutual Insurance Company (business ID 0211695-5) will be included in the
Solvency II reporting of LocalTapiola Group and consolidated into the
consolidated financial statements of LocalTapiola General starting from the
financial year beginning on 1 January 2026.
5 Future prospects
5.1 Prospects for non-life insurance 
For non-life insurance, the prospects for 2026 are moderate. Economic
growth forecasts have been repeatedly downgraded, and modest growth is
expected for 2026.
The projected low inflation, stable interest rate environment and growth in
household purchasing power support moderate growth in the non-life
insurance market. Due to global uncertainty and a weak employment
situation, households are focusing on saving, and a significant recovery in
private consumption is unlikely. Both consumers and businesses are being
cautious in their purchasing decisions.
Investments by businesses will remain low overall, although production‑related
investments in the green transition, data centres and the defence industry will
bring some positive momentum to the national economy. Residential
construction has relied on public support, and the construction cycle remains
weak. Declining house prices are not a sign of improving prospects.
Significant risks continue to cloud the growth outlook. Geopolitical and
geoeconomic risks may lead to unpredictable market consequences. In the
financial sector, elevated equity market valuations increase the risk of a
major correction. If realised, risks related to data security and data
protection may also substantially weaken trust in insurance companies. Risks
associated with the use of artificial intelligence represent a new and
emerging area of risk.
In a tight economic environment, both households and businesses value
tangible financial benefits in insurance services. In non-life insurance, efforts
focus on competitive pricing and developing financial customer benefits.
In non-life insurance operations, investments in technological renewal are at
a high level. In addition to core system reforms, the aim is to improve
automation generally and explore experimental uses of artificial intelligence.
The benefits of AI are reflected more in companies’ increased internal
efficiency than as innovations that genuinely enhance customer experience.
LocalTapiola General | Report of the Board of Directors for 2025
11
In the automotive market, the persistently weak sales of new vehicles are
expected to see a slight upturn. Cost challenges in the public healthcare
system support demand for health insurance, although the strongest market
growth phase has already passed.
5.2 Prospects for life insurance
The long-term prospects are positive. LocalTapiola Life aims to make
preparing for the future through saving, insurance and investment easy
across all service channels. This objective is supported by the core system
reform launched in 2023.
Longer lives and the pressure on social security emphasise the importance of
individual arrangements. This increases demand for saving products and term
life insurance products alike, which lays a solid foundation for future growth.
5.3 Prospects for investment
The initial outlook for the 2026 investment year is fairly good. In the baseline
scenario, the economic cycle outlook and favourable corporate earnings
expectations support the equity markets. However, one of the key questions
for equity market performance is the future trajectory of the artificial
intelligence theme. A key risk for equity markets is related to elevated
valuations, as a result of which potential economic or earnings
disappointments could, in weaker scenarios, lead to a repricing of risks.
Political and geopolitical uncertainty also remains high, which may be
reflected in equity market developments.
For bond investments, the interest rate outlook in the euro area is relatively
clear. The European Central Bank has, for the time being, ended its rate cuts
and moved to a wait-and-see stance. A substantial decrease in short-term
rates is no longer in sight, although small movements remain possible. Also, a
significant decline in long-term euro area rates would require that the
economy recede. In the United States, there are more question marks
surrounding the Federal Reserve’s interest rate policy.  For corporate bonds,
yield levels remain reasonable as we head into 2026, but risk premiums of
corporate bonds have narrowed to historically tight levels. In the baseline
scenario, strengthening economic conditions support corporate earnings
performance and solvency, but there is limited room for a further tightening
of risk premiums.
In real estate investments, valuations have reached their bottom. The
markets are supported particularly by lower interest rates and an improving
economic cycle. However, the Finnish real estate market is recovering with a
delay compared to markets in Europe and the other Nordic countries.
Polarisation on the real estate markets continues, and investors, financiers
and users remain selective in their choices.
Overall, 2026 will be an interesting year on the investment market. Economic
prospects particularly in the United States are still positive and, following the
fiscal stimulus efforts led by Germany, euro area households are also
expected to recover. On the other hand, markets have yielded exceptional
returns over the past three years, and as a result some valuation levels have
already risen rather high particularly in the United States. Furthermore, the
profitability of artificial intelligence-related investments is surrounded by
significant risks. However, interest rate levels continue to be clearly positive,
which is why the return expectation for all investment assets is good.
Consequently, the building blocks are in place for a positive investment year.
In the light of these premises, the prospects for the investment activities of
LocalTapiola Group companies continue to be surrounded by an exceptionally
high degree of uncertainty. Investment income has a major impact on
insurers’ results. With its good solvency level and the investments made in
prudential management, LocalTapiola Group is well prepared for different
movements to take place on the investment market.
LocalTapiola General | Report of the Board of Directors for 2025
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6 Governance of LocalTapiola Group 
6.1 Structure of LocalTapiola Group
All LocalTapiola Group insurance companies, with the exception of one, are
mutual companies, owned by their policyholders and guarantee capital
owners. Finnish P&C Insurance Ltd is an exception to the mutual company
form. As the ultimate parent company of LocalTapiola Group, LocalTapiola
General prepares the consolidated financial statements, which consolidate
the LocalTapiola General group pursuant to the Accounting Act and the other
companies that, together with the LocalTapiola General group, constitute an
insurance group within the meaning of chapter 26, section 2 of the Insurance
Companies Act. LocalTapiola’s group-wide risk management reporting and
prudential reporting are based on the consolidated financial statements of
LocalTapiola Group. Although the financial statements are drawn up to cover
the entire insurance group as defined in the Insurance Companies Act, this
does not expand LocalTapiola General’s company-law group structure under
the Accounting Act.
The most notable companies consolidated into LocalTapiola Group are the 19
regional non-life insurance companies; Finnish P&C Insurance Ltd;
LocalTapiola Life and its group entities LocalTapiola Remuneration Services
Ltd and LocalTapiola Asset Management Ltd Group – comprising
LocalTapiola Real Estate Asset Management Ltd and Seligson & Co Fund
Management Company Plc; LocalTapiola Finance Ltd; LocalTapiola Services
Ltd; and Tieto-Tapiola Oy. Most of the other consolidated companies are
housing and real estate companies. Turva Mutual Insurance Company is a
LocalTapiola General subsidiary, of whose guarantee capital the LocalTapiola
Group companies own 76 per cent; yet, in accordance with a derogation
issued by the Financial Supervisory Authority that was effective until 31
December 2025, it is not consolidated into the consolidated financial
statements of LocalTapiola Group.
The LocalTapiola Group regional insurance companies
and their network of offices cover entire Finland
6.2 Governance of LocalTapiola Group
LocalTapiola Group and its companies adhere to good corporate governance
practices, which are based on insurance and financial sector legislation, the
regulations and guidelines issued by the Financial Supervisory Authority and
also, where applicable to mutual insurance companies, the Finnish Corporate
Governance Code for listed companies. LocalTapiola General provides a
LocalTapiola General | Report of the Board of Directors for 2025
13
governance statement in a document that is separate from the report of the
Board of Directors, in accordance with the recommendation laid down in the
Finnish Corporate Governance Code 2025. LocalTapiola General’s and
LocalTapiola Life’s corporate governance statement is available at
www.lahitapiola.fi/tietoa-lahitapiolasta/lahitapiola-ryhma/lahitapiola-
ryhman-raportit.
As the ultimate parent company of the insurance group, LocalTapiola General
has responsibility extending to entire LocalTapiola Group for the organisation
of reliable governance, prudential supervision, risk management, internal
control and related regulatory reporting within the group and its companies.
The LocalTapiola Group companies have concluded intragroup agreements
on their mutual responsibilities and division of duties.
6.2.1 Annual General Meeting
The Annual General Meeting of LocalTapiola General was held on 28 May
2025. The meeting approved the financial statements for 2024, decided on
the use of the company’s profit, discharged from liability the members of the
Supervisory Board and the Board of Directors as well as the Managing
Director and the temporary Managing Director, and elected the company’s
auditor and the sustainability reporting assurer. Furthermore, the meeting
confirmed the number and remuneration of the members of the Supervisory
Board, and elected the new Supervisory Board members.
6.2.2 Supervisory Board
At LocalTapiola Group, our governance model is strongly affected by the
mutual status of the group’s insurance companies, which means that
policyholders are owning members in the insurance companies. As there is
therefore a very large number of members, the Supervisory Boards, in
addition to the duties laid down for them in the Articles of Association, play a
major role in the corporate governance of the insurance companies and as a
channel for interaction between the companies and their members.
The salaries and commitments of the Supervisory Board are presented in the
note ‘Management salaries and remunerations, pension commitments,
monetary loans and terms thereof, as well as guarantees and contingent
liabilities’ to the profit and loss account.
6.2.2.1 Nomination Committee of the Supervisory
Board 
The purpose of the Nomination Committee of the Supervisory Board is to
ensure diversity and transparency in the preparation of appointment
proposals when electing members to the company’s Supervisory Board and
Board of Directors. The Nomination Committee drafts the proposals
regarding the selection of members to the Supervisory Board and to the
Board of Directors, with the exception of the Board Chair and Deputy Chair,
with regard to whom all selection proposals are drafted by the Cooperation
Committee of the LocalTapiola Supervisory Boards.
6.2.2.2 Cooperation Committee of the Supervisory
Boards
The Cooperation Committee of the Supervisory Boards of LocalTapiola
General and LocalTapiola Life drafts the decision proposals for the
Supervisory Boards, as well as preparing the other business on the agenda of
the meetings of the Supervisory Boards. The Cooperation Committee
oversees the work of the Boards of Directors, President, Managing Directors
and the entire group, reporting on it to the Supervisory Boards.
By virtue of the authorisation given to it by the Supervisory Boards, the
Cooperation Committee takes decisions on the pay and remuneration of the
LocalTapiola Group President, who chairs the Board of Directors, as well as on
the pay and remuneration of the full-time members of the Boards of
Directors. Decisions on the remuneration of non-full-time members of the
Board of Directors are taken by the Supervisory Board.
6.2.3 Board of Directors
The Board of Directors is in charge of the governance of LocalTapiola
General, and it ensures the appropriate organisation and control of activities,
accounts and asset management.
The composition of the Board of Directors in the 1 January 2025–31
December 2025 financial year is discussed in the sustainability statement in 
section 7.1.2 ESRS 2 GOV Governance.
The salaries and commitments of the Board of Directors are presented in the
note ‘Management salaries and remunerations, pension commitments,
monetary loans and terms thereof, as well as guarantees and contingent
liabilities’ to the profit and loss account.
6.2.3.1 Committees of the Boards of Directors of
LocalTapiola General and LocalTapiola Life
The committees assisting the Boards of Directors of LocalTapiola General
and LocalTapiola Life – the Audit and Risk Management Committee, the
Human Resources and Compensation Committee and the Investment and
ALM Committee – are discussed in the sustainability statement in section
7.1.2 ESRS 2 GOV Governance.
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14
6.2.4 Group’s Management Group
LocalTapiola Group has a Group’s Management Group that is appointed by
the Board of Directors of LocalTapiola General. The Management Group has
broad representation from the various LocalTapiola Group companies and
from the responsible managers of the most important group-level functions.
The Group’s Management Group is responsible for preparing strategic and
other group-wide matters of LocalTapiola Group, for related decision-making
and implementation, and for the overall control and development of the
group, within the authorisations granted to it by the Board of Directors and
set out in the Joint Agreement concluded between the LocalTapiola Group
companies.
The Management Group was chaired by LocalTapiola Services Ltd Managing
Director Pekka Antikainen, and the members were the managers of the
group’s shared functions, Jari Eklund, Vesa-Matti Kultanen and Esa Tihilä,
and temporary LocalTapiola General Managing Director Mika Makkonen until
31 July 2025, and LocalTapiola General Managing Director Antti Pulkkanen
from 1 August 2025, Pasi Haarala (LocalTapiola Life), Olli Aakula
(LocalTapiola Varsinais-Suomi), Kari Salmela (LocalTapiola Lappi), Asko
Lammela (LocalTapiola Savo-Karjala), Kristian Nygren (LocalTapiola
Etelärannikko) and Teemu Toivanen (LocalTapiola Keski-Suomi) until 31
January 2025 and Teemu Routti (LocalTapiola Kaakkois-Suomi) from 1
February 2025.
6.2.5 Managing Director
Until 31 July 2025, Mika Makkonen (LL.M., MBA) served as the temporary
Managing Director of LocalTapiola General, and Antti Pulkkanen (Master of
Science in Technology [Industrial Engineering and Management]) served as
Managing Director beginning on 1 August 2025.
The salaries and commitments of the Managing Director and the temporary
Managing Director are presented in the note ‘Management salaries and
remunerations, pension commitments, monetary loans and terms thereof, as
well as guarantees and contingent liabilities’ to the profit and loss account.
6.2.6 Auditor and the sustainability statement
auditor
The Annual General Meeting elected KPMG Oy Ab to continue as
LocalTapiola General’s auditor and to act as the sustainability statement
auditor, with Timo Nummi (Authorised Public Accountant, Authorised
Sustainability Auditor) acting as the principal auditor and sustainability
reporting auditor appointed by KPMG Oy Ab.
6.2.7 Supervisory authority
LocalTapiola General is a non-life insurance company subject to public
supervision by the Financial Supervisory Authority (FIN-FSA). The FIN-FSA
supervises and ensures that insurance institutions comply with the law and
good insurance practice, and that they employ appropriate methods in their
operations. It monitors and assesses the financial position of the companies
that it supervises, as well as monitoring and assessing the management,
supervision and risk management systems, operating prerequisites and
changes in the operating landscape of these companies.
6.2.8 Related parties
The related parties of LocalTapiola General are discussed in the notes to the
financial statements.
6.3 Personnel and remuneration
The total number of full-time equivalent personnel at LocalTapiola Group
averaged 4,035 (3,996), of which 409 (355) at LocalTapiola General.
Incentive payment schemes form an integral part of the special remuneration
scheme of LocalTapiola Group, and their aim is to support the achievement
of strategic and operative goals by incentivising and committing personnel.
Incentive payment schemes comprise annual performance reward schemes
and senior management’s long-term incentive payment scheme. When
confirming the special remuneration scheme, efforts are made to ensure that
the scheme is aligned with the business strategy, targets and values of the
company and of LocalTapiola Group and that it works in the long-term
interests of the group. The special remuneration scheme is in harmony with
the group’s good and effective risk management and does not encourage
excessive risk-taking.
The management’s annual bonus is based on elements that affect the group’s
and the companies’ results, as well as on employee experience, customer
experience, sustainability and the targets of each bonus recipient’s own
business unit and duties. Primarily, the indicators are based on official key
figures. The targets are derived from the group’s strategy, and they can be
either group-specific or company-specific. The management’s long-term
incentive bonus is based on the strategic objectives determined for the result
of the group, measured over a period of several years. Personnel at the
investment organisations have in place their own incentive payment model,
whereby their bonus is determined on the basis of the following factors:
elements that affect the companies’ results; sustainability; personnel
experience and customer experience; and investment income calculated from
LocalTapiola General | Report of the Board of Directors for 2025
15
different levels. The incentive of those working in control functions that are
independent of the business functions is mainly determined on the basis of
achievement of the objectives defined for control, and it must not be
dependent on the result of the business unit controlled. In addition, a profit
bonus item, specified on the basis of achieved targets, is annually transferred
to the personnel funds of LocalTapiola Group. This bonus item is determined
on the basis of targets derived from the strategy. The personnel funds do not
cover the employees of all companies. The criteria for determining the profit
bonus are confirmed each year. Profit bonus transfers are deducted in
accordance with preliminary estimates from the results of the relevant
financial years.
The retirement age of the senior management of LocalTapiola General is
determined on the basis of employee pension legislation, unless a retirement
age of 63 years is specifically agreed. LocalTapiola General has taken out
supplementary pension insurance cover for its employees, which improves
their pension cover. All those whose employment relationship with the group
commenced before 1 January 2013 are covered by this benefit. Employment
relationships that have commenced after this date are not eligible for the
supplementary pension benefit. In addition, LocalTapiola General has taken
out defined-contribution supplementary pension insurance cover for persons
with an agreed retirement age that deviates from the statutory retirement
age. The pension payable is based on the contributions paid by the employer
and on the interest income accruing on them.
The salaries and other short-term benefits paid to the members of the Board
of Directors and to the Managing Director and the temporary Managing
Director during the 2025 financial year are shown in the notes to the financial
statements. In addition, more details about them and the remuneration
principles are provided in the remuneration report at www.lahitapiola.fi/
tietoa-lahitapiolasta/lahitapiola-ryhma/lahitapiola-ryhman-raportit.
LocalTapiola General | Report of the Board of Directors for 2025
16
7 Sustainability statement
7.1 ESRS 2 General disclosures
IRO-2, 56
Starting in 2024, we have reported the sustainability statement of
LocalTapiola Group as part of the Report of the Board of Directors. The
LocalTapiola Group 2025 sustainability statement is based on the material
sustainability topics, selected on the basis of a double materiality assessment,
that the Board of LocalTapiola General approved in June 2025.
E1 Climate change
In the 2024 sustainability statement, we announced an effort to prepare a
sustainability reporting standard-compliant transition plan during 2025. In
2025, we initiated the harmonisation of climate goals into group-wide goals,
but we have not yet prepared a transition plan. In 2025, we updated 2024 as
the new baseline year for GHG emissions, and retrospectively revised the
2024 emission calculation. As a new topic, in section E1-7 GHG removals and
GHG mitigation projects financed through carbon credits, we report on the
carbon offset credits that we have acquired as a group.
S1 Own workforce
As new dimensions, we report sections S1-8 Collective bargaining coverage
and social dialogue, and S1-16 Remuneration metrics (pay gap and total
remuneration). In terms of employee experience, our aim for 2025 was to
attain the AAA level, but AA was the actual level realised. In addition, we
deployed a new HR and training system.
S4 Consumers and end-users
We added a new reported sustainability topic, section S4 Consumers and
end-users, in relation to which we describe our policies, contact with
customers, processes, and measures in relation to identified impacts, and our
objectives. Customer encounter NPS is the metric we use to measure
LocalTapiola Group’s strategic objective ‘The best service in the sector
personally, locally and by digital means’. Our metrics target for 2025 was 66,
with 65 the actual figure realised.
G1 Business conduct
We updated our Partner Code of Conduct and created a whistleblowing
channel policy. For 2025, we do not report the completion figures for the
Code of Conduct course, for reporting is not possible due to a training system
switch.
On the LocalTapiola website, LocalTapiola Group will also publish a
Sustainability Report on the data concerning the 2025 financial year.
In the following table, we have compiled the table of contents of the
LocalTapiola Group sustainability statement, and in the table, we also
present the sustainability reporting standard acronyms that we use in the
sustainability statement.
Reported disclosure requirements
Disclosure Requirement
Page
BP-1 – General basis for preparation of the CSRD report
BP-2 – Disclosures in relation to specific circumstances
GOV-1 – The role of the administrative, management and supervisory
bodies
GOV-2 – Information provided to and sustainability matters
addressed by the undertaking’s administrative, management and
supervisory bodies
GOV-3 – Integration of sustainability-related performance in
incentive schemes
GOV-4 – Statement on due diligence
GOV-5 – Risk management and internal controls over sustainability
reporting
SBM-1 – Strategy, business model and value chain
SBM-2 – Interests and views of stakeholders
SBM-3 – Material impacts, risks and opportunities and their
interaction with strategy and business model
IRO-1 – Description of the process to identify and assess material
impacts, risks and opportunities
IRO-2 – Disclosure Requirements in ESRS covered by the undertaking’s
sustainability statements
MDR-P – Policies adopted to manage material sustainability matters
MDR-A – Actions and resources in relation to material sustainability
matters
61, 86, 94, 99
MDR-M – Metrics in relation to material sustainability matters
63, 70, 72, 81,
86, 89, 89,
95, 96, 99
MDR-T – Tracking effectiveness of policies and actions through
targets
63, 86, 95, 96,
99
E1-1 – Transition plan for climate change mitigation
E1-2 – Policies related to climate change mitigation and adaptation
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17
Reported disclosure requirements
Disclosure Requirement
Page
E1-3 – Actions and resources in relation to climate change policies
E1-4 – Targets related to climate change mitigation and adaptation
E1-5 – Energy consumption and mix
E1-6 – Gross Scopes 1, 2, 3 and Total GHG emissions
E1-7 – GHG removals and GHG mitigation projects financed through
carbon credits
E1-8 – Internal carbon pricing
S1-1 – Policies related to own workforce
S1-2 – Processes for engaging with own workers and workers’
representatives about impacts
S1-3 – Processes to remediate negative impacts and channels for own
workers to raise concerns
S1-4 – Taking action on material impacts and approaches to
mitigating material risks and pursuing material opportunities related
to own workforce, and effectiveness of those actions and approaches
S1-5 – Targets related to managing material impacts, advancing
positive impacts, as well as to risks and opportunities
S1-6 – Characteristics of the Undertaking’s Employees
S1-8 – Collective bargaining coverage and social dialogue
S1-11 – Social protection
S1-13 – Training and Skills Development metrics
S1-14 – Health and safety metrics
S1-15 – Work-life balance metrics
S1-16 – Remuneration metrics (pay gap and total remuneration)
S1-17 – Incidents, complaints and severe human rights impacts
S4-1 – Policies related to consumers and end-users
S4-2 – Processes for engaging with consumers and end-users about
impacts
S4-3 – Processes to remediate negative impacts and channels for
consumers and end-users to raise concerns
S4-4 – Taking action on material impacts on consumers and end-
users, and approaches to managing material risks and pursuing
material opportunities related to consumers and end-users, and
effectiveness of those actions
Reported disclosure requirements
Disclosure Requirement
Page
S4-5 – Targets related to managing material negative impacts,
advancing positive impacts, and managing material risks and
opportunities
G1-1 – Corporate culture and business conduct policies and corporate
culture
G1-2 – Management of relationships with suppliers
G1-3 – Prevention and detection of corruption and bribery
G1-4 – Confirmed incidents of corruption or bribery
ESRS acronyms
Acronym
English term
ESRS
European sustainability reporting standards
BP
Basis of preparation
GOV
Governance
SBM
Strategy, business model and value chain
IRO
Impacts, risks and opportunities
MDR
Minumum disclosure requirements
P
Policy
A
Actions
M
Metrics
T
Targets
LocalTapiola General | Report of the Board of Directors for 2025
18
7.1.1 ESRS 2 BP Principles for preparation
7.1.1.1 ESRS BP-1 General basis for preparation of the
sustainability statement
BP-1, 5
We prepare the LocalTapiola Group sustainability statement in accordance
with the requirements laid down in the Accounting Act (1336/1997) for the
preparation and presentation of sustainability information. We report the
information required by the European Sustainability Reporting Standard
(ESRS) and the Commission Delegated Regulations on the EU classification
system for sustainable activities (taxonomy) in the scope of the consolidated
financial statements of LocalTapiola Group. The accounting principles of the
consolidated financial statements of LocalTapiola Group are discussed in
further detail in the financial statements as part of section  11.1 Composition
of LocalTapiola Group Any exceptions to the scope or coverage of
sustainability reporting are mentioned separately in the context of the
Disclosure Requirements in question. The companies consolidated into the
consolidated financial statements of LocalTapiola Group are not obligated to
submit sustainability reporting in 2025. Our double materiality assessment in
the sustainability statement covers only the main business relationships in the
upstream and downstream value chain, as well as the material available
information for the upstream and downstream value chain. We have not
omitted any information corresponding to intellectual property, know-how or
the results of innovation.
7.1.1.2 ESRS BP-2 Disclosures in relation to specific
circumstances
BP-1, 10; BP-2, 13
We have made changes to the GHG emissions calculation compared with last
year’s statement, which can be found in section E1-6 Gross Scopes 1, 2, 3 and
Total GHG emissions. As a new dimension, in Scope 2 calculation, we have
included the real estate division’s cold sites where tenants are responsible for
the electricity contract. In Scope 3 category 15, we have introduced GHG
emissions from sovereign bonds and those associated with commercial lines
portfolios. Furthermore, we have transferred emissions from financed vehicles
from Scope 3 category 11 to category 15, and updated the calculation
methodology for financed cars.
Due to the above changes, the emission figures published in the 2024
sustainability statement are not comparable. We have retrospectively re-
calculated the GHG emissions for 2024 by applying the 2025 methodology in
order to ensure comparability. Starting from 2025, in the total emissions
table, we use 2024 as the baseline year, instead of 2021. As a result of the
retroactively updated calculations, total location-based GHG emissions for
2024 increased 279,949 tCO2e, and market-based GHG emissions increased
285,972 tCO2e.
7.1.2 ESRS 2 GOV Governance
7.1.2.1 ESRS 2 GOV-1 The role of the administrative,
management and supervisory bodies
GOV-1, 21; GOV-1, 22; GOV-1, 23
As the insurance group’s ultimate parent company within the meaning of the
Insurance Companies Act, LocalTapiola General is responsible that the
governance system of the group complies with the statutory requirements
and that the functions of the governance system, and prudential supervision
and reporting, are organised lawfully and in a consistent manner across all
group companies. As the ultimate parent company of the insurance group,
LocalTapiola General prepares the sustainability statement of LocalTapiola
Group.
The Board of Directors of LocalTapiola General manages LocalTapiola
General professionally and in compliance with sound and prudent business
practices and reliable-governance principles and regulations. It is in charge of
the governance of LocalTapiola General, and ensures the appropriate
organisation and control of activities, accounts and asset management. The
Boards of LocalTapiola General and LocalTapiola Life are assisted by joint
board committees. 
The Audit and Risk Management Committee assists the Boards of
LocalTapiola General and LocalTapiola Life in matters of finance, accounting,
solvency, risk management, audit, internal control and internal audit. As part
of financial reporting, the Committee monitors and evaluates the
sustainability reporting of LocalTapiola Group and its development. The
Committee directs senior management in the control and monitoring of
sustainability goals, and with respect to the content of the sustainability
statement to be submitted to the Boards for consideration. The Board makes
the decisions relating to sustainability reporting, and controls the
achievement of the sustainability goals. Furthermore, the Audit and Risk
Management Committee presents to the Boards the results from the audit
and from the assurance of sustainability reporting, as well as its view on the
LocalTapiola General | Report of the Board of Directors for 2025
19
reliability of reporting and on its own role in the assurance of the audit
process and sustainability reporting. 
The Human Resources and Compensation Committee assists the Boards of
LocalTapiola General and LocalTapiola Life in the examination of matters
that concern human resources and compensation. In addition, the Committee
assists LocalTapiola General and LocalTapiola Life in formulating policy with
regard to their human resources and compensation matters which, according
to the Joint Agreement, fall under the common matters of LocalTapiola
Group. Inter alia, the Committee monitors and assesses leadership,
management, supervisory work and the state and development of the
corporate culture and staff satisfaction, and for its part drafts the Human
Resources Strategy and the key policies and guidelines concerning the status
and treatment of staff for the consideration of the Board.
The Investment and ALM Committee assists the Boards of LocalTapiola
General and LocalTapiola Life with the statutory matters, and the matters
provided for in the rules of procedure, that concern prudential supervision
and the appropriate organisation of asset management. Inter alia, the
Committee monitors and assesses the implementation and promotion of a
responsible corporate culture in investment activities and how climate
change-related targets are addressed in investment choices.
By examining the reports determined in its annual wheel and provided for in
its rules of procedure, the Board of LocalTapiola General seeks to efficiently
ascertain that the operational management of LocalTapiola General and
LocalTapiola Group carries out the sustainability goal actions and reports on
them appropriately to the Board. The regularly examined reports include: risk
management reports, the ORSA report, the group’s voluntary Sustainability
Report, investment activity reports, the HR report, the report on the
functioning of the governance system, the Data Protection Annual Report
and reports illustrating the implementation of the group strategy. In 2025, we
specified the group-wide and company-wide roles and responsibilities of the
insurance companies’ governance system, increased resources for key
functions and developed the reporting and oversight of these functions. 
The Board of LocalTapiola General is composed of eight members. The
position of Board Chair is a full-time position, and it is discharged by the
LocalTapiola Group President. The position of Board Deputy Chair has also
been discharged by a full-time executive person of LocalTapiola Group who
works under a contract of service with the group. The remaining six members
are independent of the executive management of LocalTapiola Group, two of
whom have been selected from amongst candidates put forward by the
LocalTapiola Group regional non-life insurance companies in order to ensure
geographically comprehensive representation of owner-customers on the
Board. No employee representatives sit on the Board. Instead, employees are
represented in governance through Supervisory Board membership. In
accordance with the regulations of the Financial Supervisory Authority,
professional skills, competencies and experience from the following sectors
are collectively represented on the Board of LocalTapiola General: the
insurance and financial markets, business strategy and business model,
governance system, financial analysis, actuarial analysis, and regulation and
the requirements it imposes on insurance activities. Furthermore, the
composition of the Board takes into account experience and competencies in
overall leadership and change management, strategic planning capacity,
customer account management, digitalisation and sustainability. In order to
promote diversity in the composition of the Board, the Board has a balanced
representation of both sexes and persons of different ages and with a range
of experiences and educational backgrounds. The responsibility of the Board
is collective regardless of the fact that individual Board members have
complementary competencies relating to the activities of LocalTapiola
Group, in accordance with official regulations and the skills profile targets of
the Board.
On the last day of the financial year, 75 per cent of the Board members were
independent of LocalTapiola Group, and 50 per cent of the Board members
were male and 50 per cent were female.
LocalTapiola General Board members in  2025
• Board Chair Sari Heinonen, born 1976, D.Sc. (Econ.), President, from 1 May
2025
• Deputy Chair Jari Eklund, born 1963, M.Sc. (Econ.), Group Director,
LocalTapiola Group, Board Chair until 30 April 2025
• Eeva Ahdekivi, born 1966, M.Sc. (Econ.), DBA, board professional
• Birgitta Forsström, born 1973, PhD (Econ.), CEO, Brita Maria Renlund
Commemorative Foundation
• Olli Holmström, born 1960, MTh, board professional
• Ulla-Maija Moisio, born 1962, Master of Laws, trained on the bench,
varatuomari, Senior Vice President, Legal Affairs, Industrial Power
Corporation
• Jussi Tolvanen, born 1978, M.Sc. (Econ.), CEO, DNA Plc
• Timo Vuorinen, born 1964, Master of Laws, board professional
LocalTapiola General | Report of the Board of Directors for 2025
20
The Audit and Risk Management Committee consists of members of the
Boards of LocalTapiola General and LocalTapiola Life who are independent of
LocalTapiola Group. The Committee reports to the Boards of these
companies. In 2025, Ulla-Maija Moisio (Chair of the Audit and Risk
Management Committee) and Timo Vuorinen were the LocalTapiola General
Board members who sat on the Audit and Risk Management Committee.
The Human Resources and Compensation Committee is made up of Sari
Heinonen, President of LocalTapiola Group and Chair of the Board of
LocalTapiola General, who chairs the Committee, and two to four members of
the Board of LocalTapiola General and LocalTapiola Life who are
independent of LocalTapiola Group. The Committee reports to the Boards of
these companies. In 2025, Jussi Tolvanen and Birgitta Forsström were the
LocalTapiola General Board members who sat on the Human Resources and
Compensation Committee.
The Investment and ALM Committee comprises Jari Eklund, Deputy Chair of
the Board of LocalTapiola General, who chairs the Committee, and two Board
members from LocalTapiola General and two from LocalTapiola Life who are
independent of LocalTapiola Group. The Committee reports to the Boards of
these companies. In 2025, Eeva Ahdekivi and Timo Vuorinen were the
LocalTapiola General Board members who sat on the Investment and ALM
Committee.
Before the opinion of the auditor of the Report of the Board of Directors and
the financial statements and the opinion of the sustainability statement
auditor, the Board of LocalTapiola General signs the sustainability statement
as part of the Report of the Board of Directors, and for its part ensures the
accuracy and adequacy of the content of the sustainability statement. The
Board and its Audit and Risk Management Committee assess the
competences and expertise of the corporate group’s management in
sustainability-relevant issues regularly as part of examinations of the
sustainability statement and in connection with the Sustainability Report that
is examined annually by the Board. Furthermore, requirements concerning
competences and expertise are examined as part of the company’s and the
group’s annual ORSA policy debate, report and control, and when evaluating
the implementation, timeliness and change needs of policies related to
sustainability matters.
Where necessary, the Board guides senior management on increasing the
competence and expertise related to material sustainability impacts, and on
improving management or staff competences. The Audit and Risk
Management Committee plays a key role in guiding and monitoring the
sustainability statement processes and content. The Board of LocalTapiola
General and its Audit and Risk Management Committee both have an
opportunity to use independent external specialists to support their own
assessment and the increasing of their competencies, and to support the
auditing of the achievement of sustainability requirements.
In the group’s risk management processes, we also take into account the
material sustainability reporting impacts, risks and opportunities identified in
the double materiality assessment. The material impacts, risks and
opportunities are described in further detail in section SBM-3 Material
impacts, risks and opportunities and their interaction with strategy and
business model.
Annually, in spring, the Board of LocalTapiola General conducts a policy
debate on the statutory risk and solvency assessment (ORSA) of LocalTapiola
Group. The Board instructs senior management and the group’s risk
management function on the selection of risks and scenarios. The ORSA
report contains, inter alia, the conclusions of LocalTapiola Group’s risk
assessment, risk scenario reviews, the solvency and risk position, and
information on the organisation and assessment of risk management. The
Board-approved ORSA report will be sent to the Financial Supervisory
Authority. In autumn, the Board examines the situational picture in order to
ensure that the criteria of the ORSA report continue to be up to date and
adequate. The responsibility for preparing, implementing and monitoring the
ORSA report rests with the Managing Director and other management of
each company. The group’s risk management function supports the company
in the preparation of the report. Reporting to LocalTapiola General, the Risk
Management Committee has representation not only from the Managing
Directors and risk management representatives of the group companies, but
also from the directors responsible for finance, information technology and
the actuarial and compliance function.
7.1.2.2 ESRS 2 GOV-2 Information provided to and
sustainability matters addressed by the undertaking’s
administrative, management and supervisory bodies
GOV-2, 26
Risk Management Services produce to the Board the material for the
following: the ORSA policy debate of LocalTapiola Group and LocalTapiola
General conducted every spring; the examination of the ORSA report
confirmed before summer; and the ORSA monitoring undertaken in late
autumn. Twice a year, the Board examines the progress made with the
implementation of the LocalTapiola sustainability programme. Annually in
late spring, the Board of LocalTapiola General examines the key corporate
LocalTapiola General | Report of the Board of Directors for 2025
21
group-wide and company-wide policies, and assesses their timeliness,
functioning and adequacy. These policies include the Climate Policy, the
Human Rights Policy, the Tax Policy, the statutory governance policies, and
the Code of Conduct that applies to the group’s own operations. In autumn
2025, the Board of LocalTapiola General adopted the group’s updated
Partner Code of Conduct. The LocalTapiola Group Partner Code of Conduct
describes the approaches to which LocalTapiola requires its partners to
commit. The content of the Partner Code of Conduct was expanded and
specified, and it was updated to better meet regulatory requirements.
Twice a year, Human Resources Services produces to the Board a human
resources report, which takes into account goals related to material
sustainability topic ‘S1 Own workforce’ and the monitoring of their
implementation. Furthermore, on a proposal from Human Resources Services,
on the basis of a strategy report presented to the Board annually, the Board
confirms the LocalTapiola Group Human Resources Strategy and monitors
how the strategy is implemented.
At its 2025 meetings, the Audit and Risk Management Committee regularly
examined sustainability reporting. In June, the Audit and Risk Management
Committee’s meeting examined the updated sustainability reporting double
materiality assessment and the scope of the 2025 sustainability statement. In
June, the Board of LocalTapiola General approved the material sustainability
topics to be reported in the LocalTapiola Group sustainability statement, as
well as the scope of the sustainability statement. 
On a regular basis, the Board of LocalTapiola General examines reports and
reviews, presented by the management of LocalTapiola General and
LocalTapiola Group, that involve material sustainability factors. Reports and
reviews provide the Board with information about material sustainability
impacts, risks and opportunities while reinforcing and ensuring the Board’s
competency with regard to sustainability matters. In addition to actual
sustainability-related reports, sustainability factors are included, inter alia, in
regular risk management, compliance function, data protection, HR
management and investment reports.
During 2025, at its meetings, the Board of LocalTapiola General examined
the following sustainability issues in particular:
• LocalTapiola Group Sustainability Report 2024 and the material
sustainability topics
• Sustainability and advocacy review
• LocalTapiola Group insurance companies’ principles for responsible
investment, and their annual performance reporting
• LocalTapiola General’s principles for responsible investment and
corporate governance principles
• HR Strategy priorities, and the HR Strategy performance report incl.
results of the personnel satisfaction survey
• Evaluations by the Financial Supervisory Authority and an external
party on the functioning and adequacy of the governance system of
LocalTapiola Group, and the development measures decided on their
basis and the monitoring of these measures
• Donations from the contingency reserve: supporting the climate
programme
• Sustainability statement materiality assessment
• Reformed LocalTapiola Partner Code of Conduct
• Sustainability review, and the 2026 matching-funding topics for
donations to be made from the contingency reserve
• Flood extension for corporate insurance policies
• Sustainability reporting monitoring report
• Sustainability goals 2026
• Draft sustainability statement
• LocalTapiola Group’s transition plan for climate change mitigation
How material sustainability impacts, risks and opportunities are addressed in
the monitoring of the implementation of the strategy and in risk
management and major business decisions will develop as sustainability
impacts are integrated more broadly in the strategy, business plans and risk
management as well as in related reporting. The aim is to be able to integrate
sustainability goals in the group’s regular plans and processes.
LocalTapiola General | Report of the Board of Directors for 2025
22
7.1.2.3 ESRS 2 GOV-3 Integration of sustainability-
related performance in incentive schemes
GOV-3, 29
From the beginning of 2025, a sustainability indicator combining three
components was added to the remuneration of the Board members who work
under a contract of service with LocalTapiola Group. The three dimensions of
this composite indicator are: the image Finns have of LocalTapiola as a
proactive insurer (measured as part of the group’s annual B2C brand
monitoring); the own operations climate goal of LocalTapiola Group and its
companies; and the ROIHU employee survey Sustainability Index, which
gauges the staff’s experience about how well equality, diversity, inclusion and
occupational wellbeing are achieved in work communities. All three
dimensions of the sustainability indicator are linked to the goals set out in the
LocalTapiola Group sustainability programme.
The remuneration principles of the management of LocalTapiola Group, and
the bases, targets and indicators of their performance-related bonuses, are
decided by companies’ Boards. In the annual bonus scheme of the Board
members who work under a contract of service, the remuneration
sustainability indicator carries a weight of ten per cent. The sustainability
indicator is also employed for other members of the senior management of
the group companies operating in Espoo, and a recommendation to use the
indicator has been given to the group’s regional companies and LocalTapiola
Finance. Asset Management Group uses its own sustainability indicators in
remuneration.
7.1.2.4 ESRS 2 GOV-4 Statement on sustainability
due diligence
GOV-4, 30; GOV-4, 32
In the following table, we present the main components of the sustainability
due diligence process in our sustainability statement and the sections in
which they appear in the sustainability statement.
Core elements of due
diligence 
Sections in the Sustainability
statement
Page
a) Embedding due diligence
in governance, strategy and
business model 
ESRS 2 GOV-2
ESRS 2 GOV-3
ESRS 2 SBM-3
b) Engaging with affected
stakeholders in all key steps
of the due diligence 
ESRS 2 GOV-2
ESRS 2 SBM-2
ESRS 2 IRO-1
ESRS 2 MDR-P
The phases and purposes of stakeholder
engagement in the topical standards
63, 86, 95, 96,
99
c) Identifying and assessing
adverse impacts 
ESRS 2 IRO-1
ESRS 2 SBM-3
d) Taking actions to address
those adverse impacts 
Efforts to influence the impacts
61, 86, 94, 99
e) Tracking the effectiveness
of these efforts and
communicating 
Topical standards that deal with the
metrics and objectives
63, 70, 72, 81,
86, 89, 89,
95, 96, 99
7.1.2.5 ESRS 2 GOV-5 Risk management and
internal controls over sustainability reporting
GOV-5, 36
In 2025, we carried out expert work to update the identification and
assessment of risks to the sustainability reporting process. In the assessment
of risks, we employed the risk assessment model of LocalTapiola Group, under
which risk is assessed on the basis of likelihood and potential impacts.
Furthermore, a responsible person and scheduled management actions are
defined for each risk.
In their progress reviews, the LocalTapiola Group sustainability reporting
project Steering Group and the Audit and Risk Management Committee of
the Board of Directors of LocalTapiola General examine the main risks of the
sustainability reporting process risk assessment. We update the risks regularly
on an annual basis.
The main risks of the sustainability reporting process risk survey are
associated with the ambiguity of reporting requirements and the backup
personnel arrangements of information producers. The ambiguity of
sustainability reporting standards may lead to incomplete or incorrect
reporting, but the likelihood of this risk has diminished from the previous year
due to published sustainability statements. We manage this risk by ensuring
LocalTapiola General | Report of the Board of Directors for 2025
23
sufficient expert resources and taking advantage of external expertise in
interpreting reporting requirements. As for the risk associated with backup
personnel arrangements, we manage it by adequate resources.
Internal control of the reporting process is based on set timetables and on
monitoring the tasks for which the information producers are responsible.
Control is supported by the information system used in the sustainability
reporting process, which allows us to monitor the progress of tasks and the
quality and adequacy of the information produced. The continuity of
information production is secured by process descriptions compiled by
information producers containing, inter alia, information on the sources of
the reported information, on the information collection process and on the
control measures by which the accuracy and adequacy of information are
ensured.
LocalTapiola General | Report of the Board of Directors for 2025
24
7.1.3 ESRS 2 SBM Strategy
7.1.3.1 ESRS 2 SBM-1 Strategy, business model and value
chain
SBM-1, 40; SBM-1, 42
LocalTapiola Group is a corporate group serving private, farm, entrepreneur,
corporate and institutional customers and clients. The mutual insurance
companies of the group have as their purpose to generate financial benefit
for their members, who consist of policyholders and owners of guarantee
shares. Relying on multichannel services, we operate on the basis of a local
service network covering entire Finland that is close to customers. Our
products and services protect health, finances and property, adapting to
each customer’s unique situation. Our voluntary and statutory non-life
insurance products cover people, property and business against risks, while
our personal insurance and health insurance products and related services
support health and wellbeing. Furthermore, by delivering solutions for asset
management, saving, finance and life insurance, we also help our customers
and clients increase their wealth and prepare financially for the future. And
not just that: we also produce real estate investment and management
services. All our operations aim at excellent customer satisfaction, controlled
growth and long-term sustainable success.
For LocalTapiola, sustainability is an essential enabler of profitable and long-
term business operations. To improve our sustainability impact is one of the
five objectives set out for the LocalTapiola 2022–2026 strategy period. We
want to be a pioneer in impactful sustainability in our sector, across Finland.
At LocalTapiola Group, sustainability work is guided by the group strategy
and the Owner Intent. The LocalTapiola sustainability programme 2022–2026
defines the group’s common sustainability goals and key actions. We want to
be the most impactful partner in preventing evolving risks and to step up the
impact of our loss prevention work. Evolving risks associated with climate,
mental health and the cyber environment, in particular, challenge us to
develop our products and services. We have done a good job when no harm
happens, or when steps have been taken to anticipate it. In addition, we want
to strengthen our position as a responsible investor. In respect of climate, our
objective is to bring our insurance-associated and financed GHG emissions
down to net zero by 2050. For our own operations (Scope 1 and 2), we have in
place a climate goal for 2025. All climate goals are discussed in further detail
in section ESRS E1-4 Targets related to climate change mitigation and
adaptation.
Developing our operations together with our owner-customers and other key
stakeholders, we invest in improving products and services with a long-term
focus, anticipating changes in customer needs, in order to ensure the
interests and success of customers now and in the future. By producing stable
and cost efficient e-services, we enable the growth of LocalTapiola Group’s
business and a better digital customer experience. We provide more specific
information about interaction with LocalTapiola’s customers in section S4
Consumers and end-users.
Our professional staff and investments made in the development of
competences enable us to succeed, with due regard to regional needs. In
2025, the number of employees at LocalTapiola Group was 4,345. We provide
more specific information about LocalTapiola employees in section S1 Own
workforce.
We use the financial surplus from operations for the benefit of customers in
the form of discounted premiums, customer bonuses and service
development. Some of the profit we use for strengthening solvency, which will
also safeguard the interests of our customers in the future. We monitor the
development of both direct and indirect customer benefits.
We divide the value chain of LocalTapiola Group into three sections:
upstream, own operations, and downstream. The following table describes our
value chain in more detail.
LocalTapiola General | Report of the Board of Directors for 2025
25
Upstream
Own operations
Downstream
Goods and services procured (suppliers)
Insurance and claim services
Use of LocalTapiola’s services (customers)
ICT service procurement (suppliers)
Investment services
Insurance (customers and insured assets)
Claim remediation procurement and services (suppliers)
Real estate operations
Investment and asset management (clients and portfolio
investments)
Service and sales cooperation (suppliers)
Asset management services
Claim remediation (compensation recipients and beneficiaries)
Procurement for real estate operations (suppliers)
Financial services
Financing (clients)
External investments (portfolio investments)
Remuneration services
Use and leasing of properties (users and lessees)
Reinsurance (reinsurers)
Product and service development
Communication, and media cooperation (media, society)
Cooperation with authorities, and supervision (authorities)
Sales and distribution
Social partnerships and donations (local communities and
other partners)
Group’s services
Marketing and communications
7.1.3.2 ESRS 2 SBM-2 Interests and views of
stakeholders
SBM-2, 45
The most important stakeholders of LocalTapiola Group are customers,
employees and governance bodies. Other identified stakeholders include
strategic and other partners, service providers, authorities and political
decision-makers, cross-industry organisations and special interest groups,
research institutes and educational institutions, NGOs, local communities and
the media.
Engagement with customers, employees, governance bodies, partners and
authorities is regular and continuous. The role played by decision-makers,
organisations, local communities and the media takes on heightened
importance not only when it comes to maintaining our business prerequisites
and upholding our reputation, but also in local advocacy. 
In 2025, the themes we discussed with our stakeholders included climate
change risks and adaptation, working life and mental health issues,
sustainability in investment activities, and safety and security topics. In the
following table, we have compiled a summary of stakeholder interaction for
2025.
LocalTapiola General | Report of the Board of Directors for 2025
26
Stakeholder engagement 2025
Stakeholder
Modes of engagement
Purpose of engagement
Consideration of the results
Customers
Customer service and customer work
Digital service and communication channels
Customer surveys, satisfaction surveys and
feedback
The LocalTapiola customer community
Customer events and functions
Training and coaching events
Customer communication
Service aligned with customer needs and
circumstances
Customer insight
Customer needs and expectations
Risk management and loss prevention
Inclusion of customers in development
Communication objectives
Product and service development
Customer encounter and care models
Clear and understandable communication
Sustainability and responsibility goals
Personnel
Employee surveys and polls, statutory reports
Networks and cooperation forums
Staff events and functions
Discussion events and workshops
Induction and training
Workplace communication
Employee experience and occupational
wellbeing
Achievement of equality and non-discrimination
Employer image
Upskilling
Inclusion and involvement
Policies
Management and leadership
Leadership Promises and Employee Promises
Equality and Non-Discrimination Plan
Diversity Plan
Development opportunities
Strategy and operational development
Governance
Meetings
Working groups and committees
Events and functions
Training and coaching
Satisfaction survey for governance bodies
Implementation of Owner Intent
Governance
Inclusion of governance bodies
Owner-customers’ views and expectations
Governance bodies’ view in operational
development
Governance bodies’ Leadership Promises
Partners, suppliers and
service providers
Contractual cooperation
Cooperation negotiations and meetings
Events and functions
Stakeholder surveys
Projects and initiatives
Business partnerships
Claim remediation activity
Procurement, and supply chain management
Social and non-profit activity
Partnership management model
Partner Code of Conduct
Responsible supply chains
Cooperation development
LocalTapiola General | Report of the Board of Directors for 2025
27
Stakeholder engagement 2025
Stakeholder
Modes of engagement
Purpose of engagement
Consideration of the results
Authorities
Regulatory meetings and discussions
Supervisory meetings and contacts
Regular communication
Reporting
Application and development of regulation
Regular and continuous dialogue
Reporting to authorities
Ensuring legal compliance for business
operations
Ensuring operational prerequisites
Development of business operations and
reporting
Decision-makers and interest
groups
Advocacy and protection of interests
Meetings and contributions
Cooperation projects and networks
Discussion events
Ensure operational prerequisites
Regular dialogue
Cooperation and related projects
Advocacy and Protection of Interests Plan
Operational development
Development of cooperation and approaches
Organisations, local
associations and educational
institutions
Contractual cooperation
Cooperation initiatives and projects
Events, functions and trainings
Local presence through regional companies
Communication cooperation 
Anticipation of risks, and risk management
Stakeholder discussions and cooperation
Donations and sponsoring
Support health, safety and economic actors
Safety training events
National and local cooperation
Social debate
Promote the vitality, safety and wellbeing of
local communities
Risk management and loss prevention
Selection of partners and cooperation initiatives
Cooperation impact
Selection of donation and sponsorship recipients
Selection of partners and cooperation initiatives
Identification of regional risks, and research
cooperation
Impact assessment
Selection of donation recipients
Media
Media encounters and events
Media releases
Pitches
Interviews
Support business
Build the LocalTapiola brand
Increase awareness and visibility
Protect and enhance the company’s reputation
Contribute to social debate
Landscape analysis
Communication preparedness
Brand building
Stakeholder support
LocalTapiola Group owner-customers are represented in the governance
bodies that guide the activities of our insurance companies. Each mutual
insurance company of LocalTapiola Group has a Board of Directors and a
Supervisory Board, whose members represent broadly the customer base and
different sectors of society. Owner-customers exercise their voting right at
General Meetings of the mutual insurance companies. The regional
companies cooperate actively with their regional stakeholders, which include
organisations, safety operators, educational institutions and sport clubs.
At LocalTapiola Group, the purpose of stakeholder engagement is, for its
part, to help our customers protect their life and business. LocalTapiola
Group has as one of its long-term objectives to increase customer benefits,
which is why we are regularly monitoring how the customer benefits develop.
The regular dialogue conducted with our partners and other collaborating
LocalTapiola General | Report of the Board of Directors for 2025
28
entities supports national and local cooperation while enabling operational
development.
By keeping in contact with authorities and decision-makers, we strive, for
example, to confirm issues concerning the interpretation of regulation and of
our reporting obligations. Furthermore, we also influence our future operating
prerequisites through social debate and the protection of interests. Regular
and continuous engagement with different stakeholders helps us identify
their expectations and anticipate changes taking place in our business
landscape.
In 2025, members of the LocalTapiola Group management and specialists
from various functions participated broadly in the sustainability reporting
double materiality assessment. They also infused the process with their
experience of the results of the 2022 sustainability materiality assessment
carried out in the form of a stakeholder survey. In the sustainability
statement double materiality assessment in 2025, we updated the description
of the LocalTapiola Group value chain. This allowed us to ensure that all key
stakeholders are taken into account. We examine the double materiality
assessment once a year or more frequently, and will update it where
necessary when there are changes in business operations or stakeholder
expectations.
Twice a year, we provide reporting on the implementation of the Owner
Intent and the group strategy to the Boards of Directors of LocalTapiola
General and LocalTapiola Life. In addition, twice a year, the Board of
LocalTapiola General deliberates on the implementation of the LocalTapiola
sustainability programme, and approves the separate voluntary sustainability
report of LocalTapiola Group on an annual basis.
The goals laid down in the LocalTapiola group strategy are based on
anticipating changes in the business landscape and on ensuring future
competitiveness. Our strategy process is participated in broadly by
representatives of the corporate group’s governance bodies, management
members and specialists, which gives us useful information for our strategy
work about the views and interests of our different stakeholders. The
currently valid LocalTapiola group strategy has been drawn up for the years
2022–2026, which is why the group strategy objectives were not changed in
2025. As part of assessing long-term developments in the operating
environment, representatives of governing bodies and the personnel during
2025 evaluated the impacts of climate change and biodiversity loss on both
customers and business operations.
In accordance with the strategy process of LocalTapiola Group, we review the
content of the group strategy on an annual basis. Our strategic goals that
guide operational development can be found at the LocalTapiola Group
website (https://www.lahitapiola.fi/tietoa-lahitapiolasta/lahitapiola-ryhma/
toiminnan-tarkoitus/).
The LocalTapiola group strategy and the Owner Intent describe the long-term
intent of the group. Owner-customer representatives play a role in the
corporate group’s governance bodies, contributing to our operational
development. From the annual satisfaction survey targeting LocalTapiola
Group’s governance bodies, we obtain information on the views held by
members of the Boards of Directors and Supervisory Boards of the group
companies about issues related to the governance of LocalTapiola Group.
7.1.3.3 ESRS 2 SBM-3 Material impacts, risks and
opportunities and their interaction with strategy and
business model
SBM-3, 48, E1.SBM-3, 18; E1.SBM-3, 19; E1.SBM-3, AR 7, and AR 8;
S1.SBM-3, 14; S1.SBM-3, 15; S1.SBM-3, 16
In the sustainability reporting double materiality assessment process, we
identify the material impacts, risks and opportunities of LocalTapiola Group.
We present the material impacts in the following tables: Material impacts on
the environment, Material impacts on society, and Material impacts on
governance. The material risks and opportunities are illustrated in the
Material financial impacts table. All material impacts, risks and opportunities
fall within the scope of the sustainability reporting standard Disclosure
Requirements. In 2025, no resilience analysis was carried out for the strategy
and business model of LocalTapiola Group. In the planning of our upcoming
strategy period, we will address the material impacts, risks and opportunities
identified in the double materiality assessment. Compared with the reporting
period of the previous year, we report new sustainability topics that exceed
the materiality threshold. These topics are S4 Consumers and end-users, S1-8
Collective bargaining coverage and social dialogue and S1-16 Remuneration
metrics (pay gap and total remuneration).
Consumers and end-users cover the policyholders, insured persons and other
customers and clients of LocalTapiola Group (inter alia, the clients of assets
management, finance and remuneration services, and the tenants of
properties). We have identified that LocalTapiola’s consumers and end-users
may be affected by negative impacts relating to privacy protection, the
protection of personal data, and non-discrimination. We describe these
impacts in further detail in the ‘Material impacts on society’ table. By their
LocalTapiola General | Report of the Board of Directors for 2025
29
nature, negative impacts are mainly individual cases, but wide-ranging
negative impacts are also possible, for example, in the event of an extensive
personal data security breach. We outline actions related to positive impacts
in the description of the following table, and describe them in more detail in
section S4-4 Taking action on material impacts on consumers and end-users,
and approaches to managing material risks and pursuing material
opportunities related to consumers and end-users, and effectiveness of those
actions. As part of the double materiality assessment, we have identified that
we collect most personal information about insured customers (inter alia,
health information), which is why they may be affected by negative impacts
more likely than other customer groups. The data protection and data
security risks that affect the personal data of insured customers are
therefore more significant than in other customer groups. 
Material impacts on the environment
Material topic
Value chain part
Activities
Sustainability impact on the environment
Nature of the impact
Time horizon
E1
Climate change
mitigation 
Downstream
GHG emissions from portfolio
investments
Emissions generated by portfolio investments
Negative
Actual
Long-term
GHG emissions from insured assets
Emissions generated by insured assets (corporate activities
and assets, vehicles, homes etc.)
Negative
Actual
Long-term
GHG emissions from the remediation
of claims
Emissions generated by the remediation of customers’
claims (for example, home, car, health)
Negative
Actual
Long-term
GHG emissions from financed
vehicles
Emissions generated by financed vehicles
Negative
Actual
Long-term
GHG emissions from real estate
investments
Operational energy consumption, repair and new
construction of investment properties
Negative
Actual
Long-term
Select investments that support and
promote climate change mitigation
Select portfolio investments that support climate change
mitigation
Positive
Potential
Long-term
Insure green transition assets
Promote the green transition by insuring sectors and
technologies that further it
Positive
Actual
Medium-term /
Long-term
Provide insurance products that
enable the green transition
Development related to insurance products to enable the
green transition.
Positive
Potential
Long-term
Climate change
adaptation
Downstream
Invest in assets that support climate
change adaptation
Invest in assets that, through their own business operations,
promote climate change adaptation.
Positive
Actual
Long-term
Progress of climate work of client
companies
Support client companies in setting their own climate
change-related measures, metrics and goals
Positive
Actual
Long-term
Energy
Downstream,
Upstream
Emissions from value chain energy
consumption
Emissions generated by the energy consumption of insured
assets, portfolio investments and outsourced service
providers
Negative
Actual
Long-term
Asiakasyritysten ilmastotyön
edistyminen
Asiakasyritysten tukeminen oman ilmastonmuutoksen
liittyvien toimenpiteiden, mittaroinnin ja tavoitteiden
asetannassa
Positive
Actual
Long-term
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Material impacts on society
Material topic
Value chain part
Activities
Sustainability impact on human beings
Nature of the impact
Time horizon
S1
Other wok-
related rights
Own operations
Security breaches of workers’
personal data
Security breaches compromising the personal data of own
employees, and the harm they cause to employees.
Negative
Actual
Short-term /
Medium-term /
Long-term
Working
conditions
Own operations
Anticipate workers’ working capacity
risks
By anticipating workers’ working capacity risks, the
occupational wellbeing of staff improves, the number of
sick leaves and occupational accidents decreases and
cooperation with occupational healthcare runs smoothly
Positive
Actual
Short-term /
Medium-term /
Long-term
Worker wellbeing and employee
experience
Good leadership has a major impact on staff wellbeing and
a good employee experience
Positive
Actual
Short-term /
Medium-term /
Long-term
Realisation of workers’ rights
Ensure employment-related rights and employment security
through policies and agreements
Positive
Actual
Short-term /
Medium-term
Develop policies and approaches
within the work community
We ensure appropriate treatment and working conditions
for our employees so as to be able to guarantee correct
policies and the consideration of different views
Positive
Potential
Short-term /
Medium-term /
Long-term
Equal treatment
and opportunities
for all
Own operations
Development of workers’
competences
For employees, learning pathways are available that have
been defined on the basis of their own work roles. In
addition to learning pathways, we also offer our staff a
diverse range of other opportunities for upskilling.
Positive
Potential
Short-term /
Medium-term /
Long-term
Unequal treatment of workers and
job-seekers based on sex
Not all employees are treated in a non-discriminatory
manner due to sex, and not everyone is offered equal
opportunities
Negative
Actual
Short-term /
Medium-term /
Long-term
Workers’ unequal pay
Not all employees are paid the same pay for work of equal
value
Negative
Actual
Short-term /
Medium-term /
Long-term
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Material impacts on society
Material topic
Value chain part
Activities
Sustainability impact on human beings
Nature of the impact
Time horizon
S4
Personal safety of
consumers and/or
end-users
Downstream
Provision of insurance products and
services to customers
Insurance products and services can provide protection to
support customers’ health and safety. Loss prevention and
proactive health and wellbeing support for customers We
deliver expert services to customers for managing different
risks and for safety work.
Positive
Actual
Short-term /
Medium-term /
Long-term
Social inclusion of
consumers and/or
end-users
Downstream
Non-discriminatory treatment of
customers
Customers are treated on a non-discriminatory basis in
insurance and claim encounters. In terms of decisions,
customers are treated equally and fairly.
Positive
Actual
Short-term /
Medium-term /
Long-term
Service network coverage
Customers can use services via multiple channels and
locally around Finland. Regional companies operate a wide
network of offices.
Positive
Actual
Short-term /
Medium-term /
Long-term
Generation of customer benefit
Provision of products and services that align with customer
circumstances and needs. By developing customer benefits,
better customer value can be generated.
Positive
Actual
Short-term /
Medium-term /
Long-term
Services and products do not satisfy
accessibility requirements
In terms of accessibility requirements, legal requirements
are not met, that is to say, customers’ special needs are not
taken into account comprehensively enough. Use of
services may become more difficult.
Negative
Actual
Short-term /
Medium-term /
Long-term
Information-
related impacts
for consumers
and/or end-users
Downstream
Security breaches of customers’
personal data
Security breaches of customers’ personal data and the
harm that they cause to the privacy of customers
Negative
Actual
Short-term /
Medium-term /
Long-term
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Material impacts on governance
Material topic
Value chain part
Activities
Sustainability impact on the environment or human beings
Nature of the impact
Time horizon
G1
Corruption and
bribery
Own operations
Prevention of corruption and bribery
Anti-corruption and bribery prevention efforts can combat
financial crime and the grey economy. Knowledge and
training ensure that our own staff have the capability to
identify situations and act right.
Positive
Actual
Short-term
Own
operations /
Upstream /
Downstream
Incidents of corruption and bribery
Incidents of corruption and bribery occur in our own
operations or value chain
Negative
Actual
Short-term
Management of
relationships with
suppliers including
payment practices
Upstream
Suppliers adhere to responsible
policies
Suppliers ensure that their business operations comply with
the law, and they follow the best practices of their industry
Positive
Actual
Short-term /
Medium-term /
Long-term
Corporate culture
Downstream
Implementation of a responsible
corporate culture in portfolio
companies and insured companies
Require a responsible corporate culture from portfolio
companies and insured companies.
Positive
Actual
Short-term /
Medium-term /
Long-term
Own operations
Reinforcing responsible policies
Management practices, common policies and guidelines
support the creation of a responsible corporate culture
Positive
Actual
Short-term /
Medium-term /
Long-term
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Material financial effects
Material topic
Description of the risk / opportunity
Financial effect
Nature of
the effect
Time horizon
E1
Climate change
mitigation
Physical risks in insurance activities
Compensation claims for weather-related loss and damage are expected to
increase. The wide exclusions in current products or in future insurance cover are
not compatible with our lifelong security strategy, causing clients disappointments
and risk of financial losses. The financial effect will target the profit and loss
account as the number of clients decreases.
Risk
Medium-term
Transition risks in insurance
activities
Risks related to remediating loss and damage resulting from transitioning to a
carbon-neutral economy (for example, solar panels). The financial effect will target
the profit and loss account as remediation costs increase.
Risk
Long-term
Climate change
adaptation
Physical risks in insurance activities
Increased compensation claims for weather-related loss and damage and their
impact on the profitability of non-life insurance (for example, damage to forest
and property). The financial effect will target the profit and loss account as the
volume of claims increases.
Risk
Long-term
Transition risks in insurance
activities
Impacts from transitioning to a carbon neutral economy on investment returns.
Climate risks to investments.  The financial impact will affect the balance sheet.
Risk
Medium-term
S1
Other work-related
rights
Data protection and data security
risks affecting the personal data of
our own employees
The number and severity of data protection and data security incidents may
increase in the coming years. The financial impact will affect the profit and loss
account if potential claims increase.
Risk
Short-term
Working conditions
Increasing safety risks for employees
Compromised occupational safety increases reputational risk and affects the
customer experience and satisfaction. The financial impact will affect the profit
and loss account if the number of customers declines, and for potential claims.
Risk
Short-term
S4
Social inclusion of
consumers and/or end-
users
The scope of cover of products does
not meet customer expectations
If the scope of cover of products does not meet customer expectations, the
number of customers can be anticipated to decrease and reputational risk can
increase. The financial impact will affect the profit and loss account as the number
of customers decreases.
Risk
Medium-term
Data-related impacts on
consumers and/or end-
users
Data protection and data security
risks affecting customers’ personal
data
The number and severity of data protection and data security incidents may
increase in the coming years. The financial impact will affect the profit and loss
account if potential claims increase and the number of customers decreases.
Risk
Short-term
LocalTapiola General | Report of the Board of Directors for 2025
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7.1.4 ESRS 2 IRO Impact, risk and opportunity
management Disclosures on the materiality
assessment process
7.1.4.1 ESRS 2 IRO-1 Description of the processes to
identify and assess material impacts, risks and
opportunities
IRO-1, 53; E1.IRO-1, 20; E1.IRO-1, 21; E2.IRO-1, 11; E3.IRO-1, 8;
E4.IRO-1, 17; E4.IRO-1, 18; E4.IRO-1, 19; E5.IRO-1, 11; G1.IRO-1, 6;
IRO-2, 59
The identification and assessment of impacts, risks and opportunities of the
sustainability topics that are material to LocalTapiola Group is a continuous
process. We update our sustainability reporting double materiality
assessment as needed, but in any case at least annually. In this work, we take
into account the value chain and important stakeholders of LocalTapiola
Group. In spring 2025, the double materiality update process was
participated in broadly by specialists and responsible persons from, inter alia,
insurance functions, the insurance companies’ investment divisions, asset
management, finance functions, sustainability, financial management, risk
management and legal services. In the sustainability reporting double
materiality assessment, in addition to the 2024 double materiality
assessment, we used the LocalTapiola sustainability materiality assessment
approved in 2023, the results from the survey of the group’s sustainability
risks and the feedback received from stakeholders in the course of
sustainability work. In this assessment, we did not focus on specific activities,
business relationships, geographies or other factors that potentially give rise
to heightened risk of adverse impacts.
At LocalTapiola, the sustainability reporting double materiality assessment is
a four-step, continuous process:
1) Map the value chain;
2) Identify the impacts of the activities of LocalTapiola Group
3) Identify the financial effects on the activities of LocalTapiola Group (risks
and opportunities); and
4) Assess materiality, and formulate the double materiality reporting
requirements.
In the first step of the double materiality assessment, we update the
description of the LocalTapiola Group value chain. The value chain
descriptions cover both direct and indirect contractual relationships, in the
upstream and downstream of which we take into account, when possible, not
only first-tier suppliers but also those in the subsequent tiers.
In the second step, we identify impacts that LocalTapiola Group’s own
operations and value chain have on people and the environment. The
outcome we deliver is a summary of the positive and negative impacts, either
actual or possible, of LocalTapiola Group’s own operations and value chain.
Furthermore, for the impacts, risks and opportunities, we also define a time
horizon: short-term (the reporting year), medium-term (1–5 years) or long-
term (more than 5 years).
In the third step of the assessment, we identify financial risks and
opportunities presented by the sustainability topics. In this work, we also
address the sustainability risks identified in the LocalTapiola Group
companies’ own risk surveys. As the outcome of the third step, we define
impact pathways and the financial effects deriving from the sustainability
topics. As for financial effects, we classify them into opportunities and risks.
In the fourth step of the process, we score the impacts, risks and
opportunities identified in the previous steps. Based on the identification and
scoring of impacts, risks and opportunities, we compile a preliminary double
materiality summary of the sustainability topics that emerge as material. As
regards our impacts on people and the environment, we assess them as the
average of severity and likelihood on a scale of one to five, in which the
scoring for severity is determined as the average of scale, scope and
irreparability on a scale of one to five. The financial materiality scale we use
is the same scale used in the LocalTapiola Group risk survey, that is to say, we
assess the magnitude and likelihood of risks and opportunities on a scale of
one to five. As a product of these two above values, we obtain a full financial
materiality scale of one to 25.
In the sustainability reporting double materiality assessment updated in
2025, we kept the threshold for impacts unchanged from the previous
reporting period, at four. As for the threshold for financial risks and
opportunities that affect LocalTapiola Group, we maintained it at nine. We
defined material sustainability reporting standards, that is, standards to be
reported, as those that exceed the threshold for either impact materiality or
financial materiality.
LocalTapiola General | Report of the Board of Directors for 2025
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The sustainability reporting double materiality assessment summary is
processed by the LocalTapiola Group sustainability reporting project Project
Group and Steering Group. Based on the summary, the Project Group
consisting of specialists from different functions prepares a proposal on the
reported, material and excluded sustainability topics, Disclosure
Requirements and datapoints. The Project Group ensures that the results of
the double materiality assessment and the scope of the sustainability
statement are aligned. All this is documented in the information collection
system used in sustainability reporting. After examining the proposal, the
Audit and Risk Management Committee submits it to the Board of Directors
of LocalTapiola General for confirmation. At its meetings, the Risk
Management Committee allots time for examining sustainability reporting
and drafting proposals to be submitted to Board meetings. The Audit and
Risk Management Committee is also responsible for supervising the
independence of the sustainability statement auditor. The Board of
LocalTapiola General confirms that the sustainability statement included in
the Report of the Board of Directors has been prepared in compliance with
the sustainability reporting standard and the Accounting Act.
Discussions of the sustainability statement and the double materiality
assessment are included in the annual wheels governing the scheduling of
meetings of the Board of LocalTapiola General and its Committees.
Whenever there are any material changes in the operating landscape or
business operations, the Board of LocalTapiola General will also confirm the
updated sustainability reporting double materiality assessment in between
the annual discussions undertaken at meetings. In addition to examining the
topics already identified as material, the Board of LocalTapiola General will
also examine whether some of the topics, Disclosure Requirements or
datapoints previously assessed as not material exceed, after the changes, the
threshold for impact materiality or financial materiality.
We include the material risks identified in the double materiality assessment
as part of the sustainability risks highlighted in LocalTapiola Group’s risk
survey. Finally, we also use the LocalTapiola Group risk assessment model for
assessing other risks, which we discuss in further detail in section GOV-5 Risk
management and internal controls over sustainability reporting.
E1 Climate change
In the double materiality assessment, we examine the impacts that the
operations of LocalTapiola Group have on climate change, as well as the
impacts of climate change-related risks and opportunities on the operations
of LocalTapiola Group. In the materiality assessment process, we address
physical risks in our own operations and in the upstream and downstream
value chain. We identify chronic and acute hazards related to temperature,
wind, water and solid mass over the short-, medium- and long-term, and
assess their effects for assets and business activities. In this assessment, we
employ time horizon definitions that are compliant with the sustainability
reporting standard. At LocalTapiola Group, we address the impacts of
climate change-related risks and opportunities in product development and
strategy planning, but no specific capital expenditures are allocated to this
work. The impact assessment of climate-related hazards is included in the
operational risk survey process of the LocalTapiola Group regional non-life
insurance companies. We identify transition risks over the different time
horizons, and evaluate our exposure to these events. In the identification
process, we evaluate the likelihood, scope and duration of the transition risks
of investment activities, insurance activities and finance. In 2025, we did not
use climate-related scenario analysis as part of the double materiality
assessment, but have developed the assessment process with regard to the
insurance business.
E2 Pollution, E3 Water and marine resources, E4 Biodiversity and
ecosystems, and E5 Resource use and circular economy
In the double materiality assessment, we also examine impacts, risks and
opportunities related to other environmental standards in the own operations
and value chain of the LocalTapiola Group companies (E2 Pollution, E3 Water
and marine resources, E4 Biodiversity and ecosystems, E5 Resource use and
circular economy). In 2025, these sustainability topics did not exceed the
threshold for double materiality assessment reporting, meaning that we did
not identify any material impacts, risks or opportunities for these. During
2025, we did not conduct stakeholder consultations relating to these themes.
In assessing E2 Pollution, we take into account the nature of our operations,
the location of offices, and our value chain. In the assessment, we use our
specialists’ assessment from the perspective of insurance activities,
investment activities and finance, examining pollution sub-topics including
pollution of air, pollution of soil, microplastics and pollution of water. In the
2025 assessment, the main topics were soil emissions from portfolio
investments and insured assets as well as emissions from insured assets into
water, but, on the basis of the scoring, the impacts were determined to be
not material. 
In assessing E3 Water and marine resources, we take into account not only
our own operations but also our value chain. In the assessment, we use our
specialists’ assessment from the perspective of insurance activities,
investment activities and finance, examining water and marine resources sub-
topics including water consumption, water discharges, water withdrawals and
extraction and use of marine resources. In the 2025 assessment, the water
consumption of investment real estate properties and water discharges from
LocalTapiola General | Report of the Board of Directors for 2025
36
insured assets were highlighted, but, on the basis of the scoring, the impacts
were determined to be not material.
For E4 Biodiversity and ecosystems, we identify and assess real and potential
impacts and dependencies on biodiversity, taking into account the location of
our offices, and our value chain. Furthermore, we identify and assess
transition risks, physical risks, opportunities and systemic risks related to the
standard In the 2025 assessment, for LocalTapiola Group’s own operations,
we did not identify activities in or near biodiversity-sensitive areas or any
material direct impacts on biodiversity loss. In respect of the value chain, we
identified impacts, inter alia, for portfolio investments, agricultural and
forestry assets and real estate investment assets, and for the construction
and insurance of new developments. However, based on the scoring,
biodiversity did not exceed the reporting threshold.
For E5 Resource use and circular economy, we assess the impacts of own
operations and our value chain on circular economy. In the 2025 assessment,
the amount and quality of waste from claim remediation activities and from
damage repairs, and the acquisitions made for claim remediation activities,
were highlighted as the most material impacts, but, on the basis of the
scoring, the impacts were determined to be not material.
G1 Business conduct
In the G1 Governance and corporate culture-related double materiality
assessment, we address the business areas of LocalTapiola Group, the
structure of the corporate group, the multichannel nature and coverage of
services in Finland and updates to the corporate culture policies.
7.1.4.1 ESRS 2 IRO-2 Disclosure Requirements in ESRS
covered by the undertaking’s sustainability statement
IRO2, 56; IRO-2, 58; IRO-2, 59
In the following tables, in accordance with Appendix B to the ESRS 2
standard, we illustrate the datapoints reported in the 2025 sustainability
statement, and the sections in which they appear in the sustainability
statement.
Datapoints in cross-cutting and topical standards that derive from other
EU legislation
Standard, Disclosure
Requirement & datapoint
Description
Location
ESRS 2 GOV-1, 21 d
Board’s gender diversity
ESRS 2 GOV-1, 21 e
Percentage of independent board
members
ESRS 2 GOV-4, 30
Statement on due diligence
ESRS 2 SBM-1, 40 d i
Involvement in activities related to fossil
fuel activities
Not material
ESRS 2 SBM-1, 40 d ii
Involvement in activities related to
chemical production
Not material
ESRS 2 SBM-1, 40 d iii
Involvement in activities related to
controversial weapons
Not material
ESRS 2 SBM-1, 40 d iv
Involvement in activities related to
cultivation and production of tobacco
Not material
ESRS E1, E1-1, 14
Transition plan to reach climate neutrality
by 2050
ESRS E1, E1-1, 16 g
Undertakings excluded from Paris-aligned
Benchmarks
ESRS E1, E1-4, 34
GHG emission reduction targets
ESRS E1, E1-5, 38
Energy consumption from fossil sources
disaggregated by sources
ESRS E1, E1-5, 37
Energy consumption and mix
ESRS E1, E1-5, 40-43
Energy intensity associated with activities
in high climate impact sectors
ESRS E1, E1-6 , 44
Gross Scopes 1, 2, 3 and Total GHG
emissions
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Datapoints in cross-cutting and topical standards that derive from other
EU legislation
Standard, Disclosure
Requirement & datapoint
Description
Location
ESRS E1, E1-6, 53-55
Gross GHG emissions intensity
ESRS E1, E1-7, 56
GHG removals and carbon credits
ESRS E1, E1-9, 66
Exposure of the benchmark portfolio to
climate-related physical risks
Not material
ESRS E1, E1-9, 66 a
Disaggregation of monetary amounts by
acute and chronic physical risk
Not material
ESRS E1, E1-9, 66 c
Location of significant assets at material
physical risk
Not material
ESRS E1, E1-9, 67 c
A breakdown of the carrying value of the
undertaking’s real estate assets by
energy-efficiency classes
Not material
ESRS E1, E1-9, 69
Degree of exposure of the portfolio to
climate-related opportunities
Not material
ESRS E3, E3-1, 13
Dedicated policy
Not material
ESRS E3, E3-1, 14
Sustainable oceans and seas
Not material
ESRS E3, E3-4, 28 c
Total water recycled and reused
Not material
ESRS E3, E3-4, 29
Total water consumption in m3 per net
revenue on own operations
Not material
ESRS 2 - SBM-3 - E4, 16 a i
Activities negatively affecting biodiversity
sensitive areas
Not material
ESRS 2 - SBM-3 - E4, 16 b
Whether the undertaking has identified
material negative impacts with regards to
land degradation, desertification or soil
sealing
Not material
ESRS 2 - SBM-3 - E4, 16 c
Whether the undertaking has operations
that affect threatened species
Not material
ESRS E4, E4-2, 24 b
Sustainable land / agriculture practices or
policies
Not material
ESRS E4, E4-2, 24 c
Sustainable oceans / seas practices or
policies
Not material
ESRS E4, E4-2, 24 d
Policies to address deforestation
Not material
ESRS E5, E5-5, 37 d
Non-recycled waste
Not material
ESRS E5, E5-5, 39
Hazardous waste and radioactive waste
Not material
ESRS 2 - SBM-3 - S1, 14 f
Risk of incidents of forced labour
Not material
ESRS 2 - SBM-3 - S1, 14 g
Risk of incidents of child labour
Not material
Datapoints in cross-cutting and topical standards that derive from other
EU legislation
Standard, Disclosure
Requirement & datapoint
Description
Location
ESRS S1, S1-1, 20
Human rights policy commitments
ESRS S1, S1-1, 21
Due diligence policies on issues addressed
by the fundamental International Labor
Organisation Conventions 1 to 8
ESRS S1, S1-1, 22
Processes and measures for preventing
trafficking in human beings
ESRS S1, S1-1, 23
Workplace accident prevention policy or
management system
ESRS S1, S1-3, 32 c
Grievance/complaints handling
mechanisms
ESRS S1, S1-14, 88 b, c
Number of fatalities and number and rate
of work-related accidents
ESRS S1, S1-14, 88 e
Number of days lost to injuries, accidents,
fatalities or illness
ESRS S1, S1-16, 97 a
Unadjusted gender pay gap
ESRS S1, S1-16, 97 b
Excessive CEO pay ratio
ESRS S1, S1-17, 103 a
Incidents of discrimination
ESRS S1, S1-17, 104 a
Non-respect of UNGPs on Business and
Human Rights principles and OECD
guidelines
ESRS 2 - SBM-3 - S2, 11 b
Significant risk of child labour or forced
labour in the value chain
Not material
ESRS S2, S2-1, 17
Human rights policy commitments
Not material
ESRS S2, S2-1, 19
Due diligence policies on issues addressed
by the fundamental International Labor
Organisation Conventions 1 to 8
Not material
ESRS S2, S2-4, 36
Human rights issues and incidents
connected to its upstream and
downstream value chain
Not material
ESRS S3, S3-1, 16
Human rights policy commitments
Not material
ESRS S3, S3-1, 17
Non-respect of UNGPs on Business and
Human Rights, ILO principles or OECD
guidelines
Not material
ESRS S3, S3-4, 36
Human rights issues and incidents
Not material
ESRS S4, S4-1, 16
Policies related to consumers and end-
users
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38
Datapoints in cross-cutting and topical standards that derive from other
EU legislation
Standard, Disclosure
Requirement & datapoint
Description
Location
ESRS S4, S4-1, 17
Non-respect of UNGPs on Business and
Human Rights principles and OECD
guidelines
ESRS S4, S4-4, 35
Human rights issues and incidents
ESRS G1, G1-1, 10 b
United Nations Convention against
Corruption
ESRS G1, G1-1, 10 d
Protection of whistleblowers
ESRS G1, G1-4, 24 a
Fines for violation of anti-corruption and
anti-bribery laws
ESRS G1, G1-4, 24 b
Standards of anti-corruption and anti-
bribery
We describe the definition of material datapoints and the use of thresholds in
the section ESRS 2 IRO-1 Description of the processes to identify and assess
material impacts, risks and opportunities’.
The sustainability topics determined to be material in 2024,
E1 Climate change, S1 Own workforce and G1 Business conduct, also
exceeded the materiality threshold in the 2025 assessment. As a new
reported sustainability topic in the sustainability statement, S4 Consumers
and end-users was highlighted as material. In the 2025 results for the
sustainability reporting double materiality assessment, the E5 Resource use
and circular economy standard was at the reporting threshold but did not
exceed it. In the review of the E5 Resource use and circular economy
standard, impact materiality reached the materiality threshold for two
dimensions. The materiality of financial effects remained clearly below the
threshold.
The sustainability reporting project Project Group examined the double
materiality assessment-based reporting package, and documented the
criteria for excluding the standards that were found to be close to the
reporting threshold. The Audit and Risk Management Committee examined
the proposal submitted to the Board of Directors for confirmation. The
proposal also contained the excluded sustainability topics
LocalTapiola General | Report of the Board of Directors for 2025
39
7.1.4.2 ESRS 2 MDR-P Policies adopted to manage material sustainability matters
MDR-P, 65
In the following table, we present our policies in use at LocalTapiola Group to manage material sustainability matters.
LocalTapiola Group Code of Conduct
Policies
Key content
Scope of
application
Responsible
party
Commitments
Addressing the interests of
stakeholders
Availability
Owner Intent
Promote the interests of LocalTapiola
Group owner-customers, and direct
mutual corporate governance
LocalTapiola
Group companies
Supervisory
Boards of
LocalTapiola
General and
LocalTapiola Life
No commitments to external
principles
Inclusion of owner-customers and
representatives of governance
bodies
Non-public,
available to
staff in the
intranet*
Group strategy
Anticipate and prepare for changes in
LocalTapiola Group’s business
landscape, strengthen the modern
meaning and benefit of being an
owner-customer, develop future
competitive advantage and
competitiveness and direct the
development of business operations
and our offering.
LocalTapiola
Group companies
Supervisory
Boards of
LocalTapiola
General and
LocalTapiola Life
No commitments to external
principles
Inclusion of owner-customers and
representatives of governance
bodies
Non-public,
available to
staff in the
intranet*
Code of
Conduct
The key LocalTapiola Group policies
with which we at the group are
committed to complying. The Code
describes the policies we follow and
the action we do not approve of.
LocalTapiola
Group companies
excluding Finnish
P&C Insurance Ltd
and LTC Otso Oy
Group
companies’
Boards
Finance Finland’s Responsible
Financial Sector principles,
Good insurance practice
(provision of insurance, and
claims handling),
Principles for responsible
investment (investment
activities and asset
management activities),
Good securities markets
practice.
LocalTapiola Group’s business mix
and changing business landscape
taken into account. In 2024,
specialists from different functions
and companies were involved in the
updating of the Code of Conduct.
Publicly
available at the
LocalTapiola
website
Partner Code
of Conduct
The LocalTapiola Group policies and
approaches to which we require our
partners to commit and which we also
follow.
LocalTapiola
Group partners,
suppliers and
other cooperation
partners
Group
companies’
Boards
No commitments to external
principles
Diversity of LocalTapiola Group’s
cooperation partners taken into
account. Specialists from
LocalTapiola companies and
functions, and selected partners,
were involved in the preparation of
the Code.
Publicly
available at the
LocalTapiola
website
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40
LocalTapiola Group Code of Conduct
Policies
Key content
Scope of
application
Responsible
party
Commitments
Addressing the interests of
stakeholders
Availability
Sustainability
programme
The LocalTapiola sustainability
programme 2022–2026 defines the
group’s common sustainability goals
and the key actions to achieve them.
LocalTapiola
Group companies
excluding Finnish
P&C Insurance Ltd
and LTC Otso Oy
Group’s
Management
Group
UN Principles for Sustainable
Insurance
Asset Management Group: UN-
supported Principles for
Responsible Investment
We made use of results from the
sustainability materiality
assessment. The materiality
assessment surveyed stakeholder
views on LocalTapiola’s material
sustainability impacts. The survey
was sent out to clients, members of
governance bodies and staff, and
to a group representing partners,
decision-makers and organisations.
Representatives from senior
management, governance bodies
and partners participated in the
interviews.
Publicly
available at the
LocalTapiola
website
Human Rights
Policy
The LocalTapiola Human Rights Policy
contains a human rights commitment
and information about LocalTapiola
Group’s main adverse human rights
impacts. The impact assessment
addresses entire LocalTapiola Group
and the group’s value chain. The
Policy sets out methods to monitor
respect for human rights, and it
describes measures for preventing
and mitigating adverse impacts.
LocalTapiola
Group companies
excluding LTC
Otso Oy
Group
companies’
Boards
The UN’s International Bill of
Human Rights, which includes
the International Covenant on
Civil and Political Rights (ICCPR)
and the International Covenant
on Economic, Social and
Cultural Rights (ICESCR)
The ILO Declaration on
Fundamental Principles and
Rights at Work
We have identified human rights
impacts relating to the various
roles that LocalTapiola occupies,
and, as a result, have taken into
account the perspectives of
different stakeholders (employer,
service provider, investor and asset
manager, procurer, partner, and
community member)
Publicly
available at the
LocalTapiola
website
Human
Resource
Strategy
The LocalTapiola Group Human
Resources Strategy aims to ensure,
support and contribute to the
achievement of LocalTapiola’s
strategic objectives through
measures of HR work and HR
management.
LocalTapiola
Group companies
excluding Finnish
P&C Insurance Ltd
and LTC Otso Oy
Group’s
Management
Group
No commitments to external
principles
Inclusion and involvement of our
own staff
Non-public,
available to
staff in the
intranet*
Tax Policy
The LocalTapiola Tax Policy was
drawn up to lay down the goals and
key principles which LocalTapiola as a
corporate group follows in the
management of tax matters.
LocalTapiola
Group companies
excluding Finnish
P&C Insurance Ltd
and LTC Otso Oy
Group
companies’
Boards
No commitments to external
principles
As an insurer, LocalTapiola Group
is helping strengthen and create
stability in Finnish society. Through
investment and financing, we help
clients increase their wealth and
finance their business. LocalTapiola
Group aims to make tax and tax-
like payments according to valid
tax legislation, yet in such a way
that taxes will not be paid in excess
of the provisions of laws and
regulations.
Publicly
available at the
LocalTapiola
website
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41
LocalTapiola Group Code of Conduct
Policies
Key content
Scope of
application
Responsible
party
Commitments
Addressing the interests of
stakeholders
Availability
Climate Policy
The LocalTapiola Climate Policy
describes the approaches that we
employ to prevent, mitigate, manage
and remediate our impacts on the
climate and to address climate
change-related risks. We address
climate change mitigation and
adaptation-related aspects in the
client and risk selection relating to
our insurance activities, in product
development, loss prevention and
claims handling, in investment, asset
management and finance, and in our
own operations. As for energy
efficiency and the use of renewable
energy, we promote them particularly
in our real estate activities and own
operations.
LocalTapiola
Group companies
excluding Finnish
P&C Insurance Ltd
and LTC Otso Oy
Group
companies’
Boards
UN Principles for Sustainable
Insurance
Asset Management Group: UN-
supported Principles for
Responsible Investment, and the
Net Zero Asset Managers
climate initiative
Real estate division: Net Zero
Carbon Buildings initiative
LocalTapiola Finance: Green
Deal agreement concluded
jointly between the State of
Finland and the automotive
sector
LocalTapiola wants to deliver
Finnish solutions for climate
change adaptation and mitigation
– in cooperation with clients,
partners and other stakeholders.
Publicly
available at the
LocalTapiola
website
Data
protection
policy
The data protection policy outlines
the general principles and practices
underlying data protection at
LocalTapiola. The policy describes the
fundamental requirements for data
protection so that data protection by
design and by default is also achieved
in practice. Data protection covers
the privacy of individuals and the
other rights which safeguard privacy
when processing personal data. The
data protection policy aims to ensure
lawful processing of personal data,
safeguard the privacy of customers
and employees, support
LocalTapiola’s reputation as a reliable
and responsible player, lay a
foundation for credible, functioning
and systematic processing of
personal data and define the roles
and responsibilities relating to the
protection of personal data.
LocalTapiola
Group companies
excluding Finnish
P&C Insurance Ltd
and LTC Otso Oy
Group
companies’
Boards
No commitments to external
principles
Safe management of customer and
employee data as part of daily
activities.
Non-public,
available to
staff in the
intranet*
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42
LocalTapiola Group Code of Conduct
Policies
Key content
Scope of
application
Responsible
party
Commitments
Addressing the interests of
stakeholders
Availability
Data security
policy
The data security policy defines the
goals, responsibilities and
implementation methods of cyber
and data security. Cyber and data
security are an element of business
management, risk management,
corporate responsibility and
corporate security. Data security aims
at ensuring the confidentiality,
integrity and availability of the data
that our companies process. The
policy aims to ensure that the digital
environment of LocalTapiola is secure
and free from disruptions.
LocalTapiola
Group companies
excluding Finnish
P&C Insurance Ltd
and LTC Otso Oy
Group
companies’
Boards
ISO/IEC 27001 standard
Data on stakeholders are managed
in a manner that is secure and
meets the requirements laid down
in national legislation and the
GDPR.
Non-public,
available to
staff in the
intranet*
Risk
management
policy
The risk management policy defines
the practices used to prepare, within
the limits of the defined risk appetite,
for threats and opportunities arising
from evolving external and internal
conditions in order to achieve
strategic and operational objectives.
Risk management reduces the
likelihood of unforeseen financial
losses and the amount of loss, as well
as mitigating threats to
LocalTapiola’s reputation
LocalTapiola
Group companies
excluding Finnish
P&C Insurance Ltd
and LTC Otso Oy
Group
companies’
Boards
ORSA
Solvency 2
Increases stakeholder trust in
LocalTapiola. Guarantees a
sufficient solvency position, which
enables the payment of benefits to
customers in the event of
surprising risks.
Non-public,
available to
staff in the
intranet*
Insurance
companies’
product
management
policy
The product management policy
guides the LocalTapiola Group
insurance companies in taking
customer objectives, interests and
characteristics appropriately into
account in product development and
throughout the entire product
lifecycle. In addition, the product
management policy provides the
Board, management and superiors
with guidelines on the principles and
procedures to be followed in product
development and product
management.
LocalTapiola
Group insurance
companies,
excluding Finnish
P&C Insurance Ltd
and the insurance
intermediaries
involved in the
production of
insurance
products
Boards of the
group’s
insurance
companies
No commitments to external
principles
Customer objectives, interests and
characteristics are taken into
account throughout the entire
product lifecycle.
Non-public,
available to
staff in the
intranet*
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43
LocalTapiola Group Code of Conduct
Policies
Key content
Scope of
application
Responsible
party
Commitments
Addressing the interests of
stakeholders
Availability
Non-life
insurance
underwriting
policy
The underwriting policy provides an
overall view of the principles and
guidelines governing non‑life
insurance and underwriting activities.
The policy aims at guiding the
risk‑taking involved in the
underwriting activities of the non‑life
insurance companies in order to
achieve their financial objectives;
providing the Board, management,
superiors and staff with guidelines on
the principles to be followed in
underwriting; supporting the
companies’ Boards, management and
superiors in carrying out their
respective responsibilities; and serving
as a basis for the companies’ more
detailed operating models and
instructions.
LocalTapiola
Group insurance
companies
excluding Finnish
P&C Insurance Ltd
Group
companies’
Boards
Finance Finland’s general
underwriting principles
Ensure the continuity of
LocalTapiola Group’s operations,
and responsible non‑life insurance,
which enables the ability to meet
payment obligations.
Non-public,
available to
staff in the
intranet*
Insurance
companies’
principles for
responsible
investment
The insurance companies’ principles
for responsible investment guide
investments so that environmental,
social and governance sustainability
factors are integrated into
investment processes and
decision‑making.
LocalTapiola
Group insurance
companies
excluding Finnish
P&C Insurance Ltd
Boards of
LocalTapiola
General and
LocalTapiola Life
UN’s Principles for Sustainable
Insurance (PSI)
The objective of investment
activities is to safeguard the value
of invested capital and to generate
the best possible long‑term returns,
while taking into account risk
management and responsibility for
the benefit of clients and
stakeholders.
Publicly
available at the
LocalTapiola
website
Partnership
management
principles
The partnership management
principles determine how
LocalTapiola examines the
partnership lifecycle and addresses
the various dimensions of partnership
management.
LocalTapiola
Group companies
excluding Finnish
P&C Insurance Ltd
and LTC Otso Oy
Board of
LocalTapiola
Services
No commitments to external
principles
Active partnership management
enables improved process
efficiency during the lifecycle of
partnerships and allows the
provision of the most effective
service possible to consumers and
end-users.
Non-public,
available to
staff in the
intranet*
Climate and
nature strategy
of Asset
Management
Group
LocalTapiola Asset Management
Group’s climate and nature strategy
sets out the concrete measures for
mitigating climate change and
safeguarding biodiversity. The
strategy guides investment activities,
real estate operations and ownership
steering toward carbon neutrality,
responsibility and the achievement of
sustainable development goals.
LocalTapiola
Asset
Management
Group
Board of
LocalTapiola
Asset
Management
Paris Agreement, Net Zero Asset
Managers initiative, The Net
Zero Carbon Buildings
Commitment, TCFD (Task Force
on Climate Related Financial
Disclosures), PRI (Principles for
Responsible Investment), CDP
(Carbon Disclosure project),
Climate Action 100+, TNFD
(Taskforce on Nature-related
Financial Disclosures), CDP
Science-Based Targets
Campaign, UN’s Sustainable
Development Goals (SDG)
Prevent and minimise the impacts
of climate change as part of
LocalTapiola Asset Management
Group’s operations. Promote
stability and predictability in the
business landscape, which enables
sustainable societal, business and
investment development.
Publicly
available
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44
LocalTapiola Group Code of Conduct
Policies
Key content
Scope of
application
Responsible
party
Commitments
Addressing the interests of
stakeholders
Availability
Claims policy
The claims service policy sets out that
claims services implement the
LocalTapiola strategy and deliver the
best customer experience and lifelong
security to customers. Targets are
defined for the strategic objectives of
claims services, and their
achievement and timeliness are
continuously monitored within the
claims service organisation. In claims
service, it is ensured that customers
are provided with service that
exceeds their expectations across
online, mobile, telephone and
in‑office channels.
LocalTapiola
Group insurance
companies
excluding Finnish
P&C Insurance Ltd
Board of
LocalTapiola
Services
No commitments to external
principles
Customers are provided with a
uniform claims service based on
common processes, shared policies
and uniform claims guidelines.
Claims are always processed in
accordance with the law and the
applicable insurance contract.
Non-public,
available to
staff in the
intranet*
Customer
encounter
model
The customer encounter model
defines the practices related to the
role of customer insight,
measurement and feedback in
developing the customer experience.
LocalTapiola
Group companies
excluding Finnish
P&C Insurance Ltd
and LTC Otso Oy
Board of
LocalTapiola
Services
No commitments to external
principles
To be able to deliver the best
lifelong security to customers, we
need to understand
customers’ (life) situation and
needs. Through genuine interaction
and attentive listening, we can
offer customers the best possible
solutions or help them in their
moment of need.
Non-public,
available to
staff in the
intranet*
Customer
feedback
processing
principles
The customer feedback processing
principles define the policies for
collecting and processing customer
feedback
LocalTapiola
Group companies
excluding Finnish
P&C Insurance Ltd
and LTC Otso Oy
Board of
LocalTapiola
Services
No commitments to external
principles
Feedback given by customers is
taken into account as part of
business operations.
Non-public,
available to
staff in the
intranet*
Customer
complaints
processing
policy
The processing of customer
complaints is based on efficiency,
fairness and the customer first
principle. Complaints can be
submitted in several ways, including
by telephone and email or through
electronic service channels, and each
complaint is recorded systematically.
The handling of complaints is
continuously monitored and analysed,
they are regularly reported to
management and the Board, and the
timeliness of the processing principles
is ensured annually.
LocalTapiola
Group insurance
companies
excluding Finnish
P&C Insurance Ltd
Board of
Directors of
LocalTapiola
General
EIOPA-BoS-12/069
EIOPA-BoS-12/07
Complaints lodged by customers
are processed transparently,
efficiently, fairly and on a customer
first basis
Non-public,
available to
staff in the
intranet*
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45
LocalTapiola Group Code of Conduct
Policies
Key content
Scope of
application
Responsible
party
Commitments
Addressing the interests of
stakeholders
Availability
Whistleblowing
channel policy
The purpose of the whistleblowing
channel policy is to describe
LocalTapiola Group’s whistleblowing
procedures, handling processes and
work instructions. The document
serves as guidance for all users of the
whistleblowing channel, those
handling reports and other parties
involved in the process.
LocalTapiola
Group companies
excluding Finnish
P&C Insurance Ltd
and LTC Otso Oy
Board of
Directors of
LocalTapiola
General
Ilmoittajansuojelulaki (the
whistleblowing act) (1171/2022)
European Union’s
whistleblowing directive (EU
2019/1937)
The policy applies to all
LocalTapiola Group companies and
their staff, and to other
stakeholders that can file a report
through the channel.
Non-public,
available to
staff in the
intranet*
*With the exception of the employees of Finnish P&C Insurance Ltd, Seligson & Co Fund Management Company Plc and LTC Otso Oy, the employees of LocalTapiola
Group have access to the LocalTapiola intranet.
LocalTapiola General | Report of the Board of Directors for 2025
46
7.2 ESRS E Environmental information
In the Environmental information section of this sustainability statement, we
examine taxonomy reporting and the E1 Climate change sustainability topic.
7.2.1 Disclosures pursuant to Article 8 of
Regulation (EU) 2020/852 (Taxonomy Regulation)
We report the disclosures required by the Taxonomy Regulation, its Annexes
and the supplementing Delegated Regulation. We report Taxonomy
Regulation disclosures as per the legislation effective on 31 December 2025.
The Commission Delegated Regulation (EU) 2026/73 allows the application, in
the sustainability reporting for the 2025 financial year, of the same EU
Taxonomy regulations that were applied in the 2024 sustainability reporting
(these include the Commission Delegated Regulation (EU) 2021/2139, the
supplementary delegated climate regulation (Commission Delegated
Regulation (EU) 2022/1214), the delegated environmental regulation
(Commission Delegated Regulation (EU) 2023/2486), and the amendments to
the delegated climate regulation (Commission Delegated Regulation (EU)
2023/2485). The taxonomy reporting for the 2025 financial year of
LocalTapiola Group takes advantage of this opportunity.
7.2.1.1 Non-life insurance premiums written
The following climate change adaptation-related activities set out in the
Taxonomy Regulation concern non-life insurance and reinsurance operations:
10.1. Non-life insurance: underwriting of climate-related perils, and 10.2.
Reinsurance. Under some non-life insurance products, we provide
compensation for natural event-related losses, such as those from storms,
wildfire and flooding. The terms and conditions of our non-life insurance
products do not specifically exclude climate change-related losses from
coverage.
We report as Taxonomy-eligible (Annex X, template row A.2) only that portion
of the premiums written for each non-life insurance class which we charge to
cover losses that are due to one or several of the climate risks set out in
Appendix A to the Delegated Regulation. The premiums written for
reinsurance acceptances and reinsurance cessions and for retrocession of
reinsurance acceptances are reported as Taxonomy-eligible according to the
insurance class-specific portions of direct premiums written.
Taxonomy-aligned reporting (Annex X, template row A.1) of non-life insurance
premiums written requires compliance with the relevant technical criteria and
minimum safeguards. The minimum safeguards require compliance with the
guidelines on human rights, corruption, taxation and fair competition laid
down in the United Nations (UN) Guiding Principles on Business and Human
Rights (UNGP). In our Human Rights Policy, Code of Conduct and elsewhere,
we, for example, pledge to respect and implement human rights in everything
we do. Development work is underway at LocalTapiola Group to comply with
the minimum safeguards, with which we do not comply in the 2025 reporting.
The insurance products of LocalTapiola do not in all respects meet the
Taxonomy-alignment criteria set for non-life and life insurance activities.
With regard to the technical criteria for making a substantial contribution to
climate change adaptation, our current insurance products do not meet the
technical criteria for climate-risk modelling and pricing. This is because
forward-looking climate models are not employed for rating purposes. In
future, we will aim to develop our non-life insurance products and, where
possible, increase the share of both direct insurance and reinsurance
premiums written that meets the technical criteria.
We use the template determined for non-life and reinsurance undertakings in
Annex X to the Commission Delegated Regulation to report on the non-life
insurance premiums written shown in the consolidated financial statements
of LocalTapiola Group.
LocalTapiola General | Report of the Board of Directors for 2025
47
Annex X template: The underwriting KPI for non-life insurance and reinsurance undertakings
Substantial contribution to climate change
adaptation
DNSH (Do No Significant Harm)
Economic activities (1)
Absolute
premiums, year
2025 (2)
Proportion of
premiums, year
2025 (3)
Proportion of
premiums, year
2024 (4)
Climate
change
mitigation
(5)
Water and
marine
resources
(6)
Circular
economy
(7)
Pollution
(8)
Biodiversity
and
ecosystems
(9)
Minimum
safeguards
(10)
MEUR
%
%
Y/N
Y/N
Y/N
Y/N
Y/N
Y/N
A.1 Non-life insurance and reinsurance underwriting
Taxonomy-aligned activities (environmentally
sustainable)
0.00
—%
—%
Y
Y
Y
Y
Y
N
A.1.1 Of which reinsured
0.00
—%
—%
Y
Y
Y
Y
Y
N
A.1.2 Of which stemming from reinsurance activity
0.00
—%
—%
Y
Y
Y
Y
Y
N
A.1.2.1 Of which reinsured (retrocession)
0.00
—%
—%
Y
Y
Y
Y
Y
N
A.2 Non-life insurance and reinsurance
underwriting Taxonomy-eligible but not
environmentally sustainable activities (not
Taxonomy-aligned activities)
207.95
12.93%
13.09%
B. Non-life insurance and reinsurance underwriting
Taxonomy-non-eligible activities
1,412.56
87.07