Sustainability policy 2025
Background
Sustainability is a fundamental and guiding principle for all activities within Max Matthiessen Group (“Max Matthiessen” or “the Group”). Max Matthiessen has a strong commitment to ensuring that its activities contribute to sustainable development regarding economic, environmental and social aspects.
Max Matthiessen's sustainability strategy, objectives and sustainability policy guide its sustainability efforts.
Objective
The overall vision of the company’s efforts is to be the leading sustainable advisory platform. The objective is to contribute to sustainable development by reducing our negative - and maximizing our positive - impact on people, the environment and society.
Purpose and scope
Structure of sustainability-related steering documents
Sustainability work is described in normative and activating governing documents within the Max Matthiessen Group. Normative governing documents clarify principles and describe how operations should be conducted (policies, guidelines and instructions) while activating documents (the sustainability strategy and project plans) drive the development.
Scope of the sustainability policy
The Sustainability Policy is the overarching normative document that clarifies principles for the implementation and governance of sustainability efforts across the Max Matthiessen Group. It also includes a description of principles for development, decisions and supervision.
Subordinate to the sustainability policy at Group level are policies within each subsidiary. Guidelines and procedures are then in place that specify frameworks and recommendations for the activities in specific contexts.
The policy applies to the Group and covers Max Matthiessen's business operations in all geographical locations where Max Matthiessen operates. All employees and agents, full-time and part-time employees working on behalf of Max Matthiessen are subject to the policy. The sustainability policy also covers Max Matthiessen's value chain: suppliers, business partners and customers.
The sustainability policy has been developed with Max Matthiessen's stakeholders in mind. Max Matthiessen holds direct and indirect dialogue with them, such as through customer surveys, employee engagement surveys and through participation in industry forums.
Roles and responsibilities
Decision-making bodies and responsibility for sustainability issues
Sustainability shall be an integrated part of our business, where each business area and company are expected to contribute to the overall sustainability agenda.
The Board of Directors has the ultimate responsibility for the sustainability strategy, makes decisions on the overall direction of the work, the content of the sustainability policy and adopts the annual sustainability report.
The CEO and Group Management are responsible for ensuring that the company follows the strategic direction and makes decisions on policy, measures, targets and metrics. To monitor implementation, there are goals and KPIs that are reported annually to the board.
The Sustainability Committee is the management's decision-making body for sustainability issues responsible for reviewing the implementation of the sustainability strategy. The Sustainability Committee is led by the Head of Sustainability with a mandate from the CEO and consists of representatives from the Group Management Team. The Sustainability Committee proposes updates to policies, targets and metrics.
Group functions
The day-to-day work is delegated to managers and functions within the area of each subject area. The Sustainability Function acts as a business partner to the organisation in matters relating to sustainability. The Sustainability function is led by the Head of Sustainability with the task of driving, developing and coordinating the Group's sustainability agenda, commitments, related initiatives and development projects.
The sustainability function ensures that ambitions and commitments are in line with the decided strategy and provides recommendations on key strategic business decisions with expected environmental or social impact.
Risk
The financial impact and risk management for environmental, social and governance (ESG) aspects are managed by set risk management processes according to the 1st, 2nd and 3rd line of defence. Responsible for risk management is the Group's risk and compliance function.
Principles for sustainability work
General principles
Our view on sustainability is summarized as follows:
- We want to show the way to sustainable development and contribute to the transition that is needed to ensure a long-term sustainable world to live in.
- Our main opportunity to contribute is through sustainable advice, value-creating investment and insurance solutions, and responsible asset management.
- We want to build our business on long-term value creation, satisfied customers, prosperous and proud employees and good relationships with partners and suppliers.
- The Group shall be a good corporate citizen that takes responsibility for our impact on people, the environment and society.
In order to drive the development towards a sustainable society, Max Matthiessen takes into account the precautionary principle and, as a minimum, society's requirements according to laws and regulations.
Impacts, Risks and Opportunities (IRO)
Max Matthiessen's sustainability work is guided by a double materiality analysis through which material sustainability factors as well as impacts, risks and opportunities have been identified and calibrated.
The double materiality analysis has been carried out with Max Matthiessen's stakeholders in mind.
Due diligence
Max Matthiessen shall regularly review sustainability risks and proactively identify actual or potential negative impacts on the environment and human rights, as well as take measures to prevent adverse impacts due to our business operations. Processes for identifying, preventing, mitigating and accounting for how the company manages actual and potential adverse impacts in its own operations, supply chain and in other business relationships are set out in due diligence procedures regarding, for example investment decision-making processes and asset management.
Environmental issues
Environmental sustainability is about our impact on nature, animals and the environment. We are convinced that we all have a responsibility to reach the global goal of limiting global warming to 1.5 degrees Celsius. To achieve this, clear commitments are needed from states, business and civil society. As a player in the financial sector, we have a great opportunity to influence and a responsibility to contribute to the transition to a low-carbon economy.
Max Matthiessen's commitment to the environment and climate includes measures for climate change mitigation, climate adaptation, energy efficiency and renewable energy.
Social sustainability
Social sustainability is about our impact on people, local communities and community development. Max Matthiessen works actively with social sustainability and takes these issues into account in our operations. We shall respect and promote respect for human rights, fair working conditions, inclusion, equality and active civic engagement. Max Matthiessen opposes all forms of discrimination, sexual harassment and victimization regarding gender, transgender identity or expression, ethnicity, race, religion or other beliefs, age, political opinion, disability, sexual orientation, national origin or social
origin, or any other form of discrimination covered by UN regulations or national law. Max Matthiessen also applies a zero-tolerance policy towards all forms of slavery and human trafficking, including forced labour, penal labour and child labour.
Human rights
Max Matthiessen supports the protection and respect for human rights and is guided by fundamental principles of human rights, such as those in the United Nations Universal Declaration of Human Rights and the International Labour Organization's (ILO) Declaration on Fundamental Principles and Rights at Work (including the eight core conventions).
Max Matthiessen will take responsibility for respecting human rights as expressed in the UN Guiding Principles on Business and Human Rights and corresponding expectations in the OECD Guidelines for Multinational Enterprises.
Corporate Governance and Ethics
Corporate governance is about how we take responsibility for and run our business. Good business ethics are the foundation of how we conduct our business. Everyone at Max Matthiessen has an individual and a collective responsibility to comply with laws, rules and guidelines and to act so that our credibility and position can never be questioned. Our actions shall be based on respect, integrity, care and professionalism.
To ensure compliance with Max Matthiessen's internal procedures, processes and policies in business ethics, employees are trained on an ongoing basis as needed and at least annually. Relevant staff also receive initial training and a review of the company's internal procedures and processes in connection with the person starting the position/assignment.
Financial sustainability
Financial sustainability is about how we ensure a sustainable business model and how we strengthen our and our customers' long-term competitiveness. This includes living up to customer expectations and shareholder demands for returns, as well as taking into account the impact on society and the environment. Meeting expectations and demands requires financial stability and strength, which requires earnings growth and profitability.
Max Matthiessen is also committed to responsible tax practises where decisions are guided by commercial objectives, prudence, transparency and long-term sustainable behaviour.
Business principles
Asset and wealth management
At Max Matthiessen, we look at investments from a holistic perspective with the dimensions: return, risk and impact on sustainability factors. As a financial player, we can contribute to sustainable social development by channelling capital into sustainable investments. We do this by offering investment alternatives that maintain an adequate level of sustainability, as well as facilitating sustainable savings options.
In asset and portfolio management, sustainability efforts are manifested primarily through the integration of sustainability (ESG) factors in investment and decision-making processes, as well as through using stewardship and engagement tools. Specific focus and thematic areas and related objectives are based on the overall sustainability strategy and decided at the business area level.
Methods used for the integration of sustainability factors are 1) integration, 2) exclusion and 3) active ownership. The methods are applied in different ways depending on whether it concerns asset or wealth management.
Investment advice and insurance brokerage
Sustainability is a central and integral part of life insurance brokerage and investment advice. We have a responsibility to understand our customers' preferences for sustainability and to enable informed decisions about pensions, savings and insurance coverage.
We will continuously develop our understanding and expertise in ESG issues in relation to financial advice and brokerage of insurance-based investment products.
The company integrates sustainability risks into insurance distribution. We consider adverse impacts on sustainability factors when providing advice on investments and insurance based-based investment products .
Suppliers and business partners
Max Matthiessen will work for openness, transparency and dialogue with various stakeholders and welcomes feedback. This is important to be able to set relevant priorities and develop our processes, routines and working methods.
Max Matthiessen expects business partners, suppliers and subcontractors upstream and downstream in the value chain to have the same approach. Max Matthiessen's principles for suppliers and subcontractors are specified in Max Matthiessen's Supplier Code of Conduct.
External commitments and initiatives
Max Matthiessen's sustainability work is based on the following conventions and principles:
- The UN's 17 Sustainable Development Goals
- UN Universal Declaration of Human Rights
- The International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work (including the eight core conventions).
- UN Guiding Principles on Business and Human Rights (UNGP)
- OECD Guidelines for Multinational Enterprises
Compliance and follow-up
Monitoring
Compliance with the policy and our sustainability work will be reviewed regularly and our sustainability goals are tracked on a regular basis. We will conduct introduction and training of staff within
sustainability relates areas. The result means a continuous improvement of our sustainability work and reduced adverse impact.
Follow-up of Max Matthiessen's impact, risks and opportunities is managed by the Board of Directors at least annually.
Follow-up of accounting and reporting of sustainability is managed within the Board's Audit Committee and will take place at least annually.
Complaint mechanisms
Max Matthiessen has a whistleblowing function through which employees, contractors or other persons who, in a work-related context, in connection with the companies within the Group, can report violations, including for human rights.
Max Matthiessen also has a complaints function through which customers can report complaints with a product or service.
Remedy
Max Matthiessen is committed to ensuring remediation where our operations have caused or contributed to adverse impacts. Issues raised through the company’s whistleblower channel is addressed in a fair a timely manner and may result in corrective or disciplinary actions following investigation.
If Max Matthiessen has caused financial damage, the company may provide financial compensation adapted to the situation. These matters are handled by the company's complaint management process.
Publication
The sustainability policy shall always be provided to stakeholders in Max Matthiessen's value chain through publication on the Group's website.