5. Workers in the value chain (ESRS S2)
5.1 Material impacts, risks and opportunities and their interaction with strategy and business model (ESRS 2 SBM-3)
The workforces of business partners play a key role in UNIQA’s value chain. Internationally recognised standards are applied to ensure that the key interests of relevant stakeholders are considered even when there is no direct interaction between UNIQA and workers in the value chain. The materiality assessment identified workers along the value chain from the following areas that may be subject to material impacts from UNIQA’s operations:
Suppliers
The selection of suppliers can indirectly affect workers’ working conditions. The selection and risk assessment process for suppliers are geared towards preventing violations of labour law. Group Procurement uses a structured risk assessment conducted using digitalised surveys that consist of financial, procurement and ESG criteria. Based on this assessment, the suppliers are assigned to one of four risk classes (A to D). Depending on the risk classification, suppliers are reassessed every three or five years.
In the event of a negative supplier evaluation (risk class D), appropriate measures are taken, which may include the termination of contracts or blacklisting. One such incident occurred in the financial year that led to termination of the contract in question. In the future, the Corporate Sustainability Due Diligence Directive (CSDDD) will address this topic further.
Corporate customers
The insurance coverage offered indirectly affects the business activities and working conditions of corporate customers’ workers. Failure to adequately implement measures when reviewing the acceptance of corporate customers and as part of their ongoing assessment means that corporate customers have little incentive to improve working conditions for their employees. As a result, an ESG risk assessment process and a due diligence process have been implemented to minimise potential risks and negative impacts to corresponding workers and to prevent violations of labour law. Both are described in detail in the following sections.
Four serious human rights violations in the value chain were reported within the underwriting portfolio in the financial year (2024: no violations). The measures taken as a result are discussed in the sections below. No negative impacts specifically associated with the business model or arising from specific incidents as a result of UNIQA’s business activities were identified. It was also not possible to limit any potential negative impacts to workers with specific characteristics.
Since 2020, UNIQA has been a member of the UN Global Compact, the principles of which are enshrined in the UNIQA Code of Conduct. Suppliers are also expected to uphold the principles of the UNIQA Code of Conduct and to act accordingly. This ensures that the interests of the affected stakeholder groups are taken into account. The UNIQA Code of Conduct contains the material social and environmental criteria of the UN Global Compact. It addresses numerous topics, including ethical and legally compliant governance; conduct towards customers, suppliers, employees and other stakeholders; payment in kind (gifts, donations, etc.); the management of property and confidential information; competitive conduct; conflicts of interest; environmental and social sustainability, such as human rights (forced and child labour); labour standards, environmental protection and anti-corruption; as well as general rules of communication.
Occupational safety, precarious employment and human trafficking are not covered because they have not been identified as material risks in UNIQA’s normal course of business.
The corporate strategy is also aligned with the internationally recognised provisions of the UN Universal Declaration of Human Rights. This not only ensures compliance but also contributes to stable and sustainable business relationships in the long term.
5.2 Policies related to value chain workers (S2-1)
5.2.1 Workforce of suppliers
UNIQA’s business model is based on the integration of sustainability principles throughout the value chain. Suppliers are selected not only based on economic factors but also based on social and environmental factors depending on the product group in question.
The Group Procurement Policy adopted by the Management Board provides the framework for procurement procedures. Along with other aspects, the policy stipulates that suppliers with which a defined order value has been agreed must complete a questionnaire containing specific questions on the topics of human trafficking, forced labour and child labour. The questionnaire is based on the German Supply Chain Act and covers roughly 50 aspects of the following categories:
Risk analysis
Measures and control mechanisms
Prevention and remedies
Grievance mechanisms
Reporting and transparency
UNIQA sends out this questionnaire each year so that the data can be updated, reviewed and used to ensure that suppliers meet UNIQA’s compliance requirements in the long term. In the financial year, the human rights questionnaire was incorporated into the ongoing supplier evaluation process for the first time. It serves as the basis for discussions with suppliers and comprehensive risk assessment.
Responsibility for the Group Procurement Policy lies with the Management Board member for Operations, Data & IT.
5.2.2 Workforce of corporate customers
In the corporate customer segment, the UNIQA Sustainability Strategy in Corporate Business and the ESG Underwriting Standard ensure that corporate customers are evaluated in terms of ESG risks as part of the underwriting process. In the risk assessment process, all enquiries that exceed a defined threshold are already reviewed in the preliminary offer phase. An in-depth review is always conducted for corporate customers who are engaged in any activities related to fossil fuels. The existing portfolio is also reviewed over the course of the year. Both reviews involve an ESG due diligence check, which looks into whether companies have entered into commitments for fundamental ESG standards and analyses potential critical incidents. With regard to social matters, along with issues such as child labour, human trafficking and forced labour, aspects such as poor working conditions and violations of workers’ rights are also taken into account. The UNIQA Sustainability Strategy in Corporate Business and the ESG Underwriting Standard are the responsibility of the Customers & Markets Austria and Customers & Markets International Management Board function.
The risk assessment regarding sustainability topics is carried out for insurance projects across the non-life business for individual customers. For standardised products that cover small and medium-sized companies, a new solution will be integrated into new offerings starting in 2026. There is no corresponding engagement with the workforce in this regard. The UNIQA Sustainability Strategy is available to view on the UNIQA website.
5.3 Processes for engaging with value chain workers about impacts (S2-2)
Beyond the processes described above, UNIQA does not have a general procedure in place for engaging with workers in the value chain.
5.4 Processes to remediate negative impacts and channels for value chain workers to raise concerns (S2-3)
Business partners can raise their concerns or complaints on the whistleblowing platform. There are no specific channels for the workforce of suppliers or corporate customers. Please consult the Business conduct (ESRS G1) chapter for more information.
Suppliers
In terms of suppliers, the risk assessment process introduced in the financial year serves both to identify potential risks early on and to take preventive measures. The risk assessment focuses on IT suppliers and service providers. Based on this assessment, the suppliers are assigned to one of four risk classes (A – low risk, to D – high risk). For suppliers in risk category D, the corresponding risks in the supply chain are identified, assessed and mitigation measures developed.
Corporate customers
Companies where serious critical incidents are uncovered are added to the watchlist. This status leads to annual reviews to ensure that the incident is not recurring. Known incidents involving existing corporate customers are analysed in terms of their severity, remedial actions taken and potential impacts to the portfolio. In particularly serious cases concerning the core areas of human rights, ESG experts support the implementation of the disclosed actions and inform underwriters in good time about the prospects for continuing to offer insurance coverage. A lack of publicly documented appropriate countermeasures or recurring incidents may result in exclusion of the company concerned from the insurance offering.
5.5 Taking action on material impacts on value chain workers, and approaches to managing material risks and pursuing material opportunities related to value chain workers, and effectiveness of those actions (S2-4)
5.5.1 Workforce of suppliers
Supplemental agreements are concluded with suppliers that fall under the scope of the implementation of the Digital Operational Resilience Act (DORA). These agreements cover aspects such as environmental protection and safety, labour policies and business ethics, among other topics. Only suppliers from the information and communication technology (ICT) sector fall under the scope of DORA. Affected suppliers are identified annually based on IT applications and services as part of a business impact analysis. The UNIQA Supplier Commitment Letter forms part of the supplementary agreements. It contains the key aspects of the Code of Conduct and requires suppliers to take action to reduce their environmental impacts, guarantee labour rights and comply with ethical business practices. The commitments also include regular reporting on sustainability metrics, adhering to environmental and safety standards, and ensuring fair working conditions. The Supplier Commitment Letter also covers compliance with safety, quality and data protection standards, participation in training courses and emergency tests and the establishment of a whistleblower and complaints mechanism. In the financial year, over 95 per cent (2024: 38 per cent) of suppliers signed DORA addenda to the master agreement.
The effectiveness of these actions is monitored on an annual basis by analysing the human rights questionnaires and by engaging in dialogue with suppliers within the scope of supplier engagement. In the event of deviations from the standards, actions such as those described in the section above are taken.
5.5.2 Workforce of corporate customers
It is only possible to demand action be taken by corporate customers to a limited extent as the business activities primarily focus on assuming and assessing risk, not on exerting direct operational influence. Actions are therefore currently mainly addressed in the approval process. This was also considered for the first time for automatic contract renewals in the financial year and will take place annually from 2026 onwards.
Since 2025, the process of assessing ESG risks for all requests for proposals that exceed a defined threshold has been integrated into the underwriting for corporate customers. Furthermore, most of the local portfolios will be reviewed over the course of the year for compliance with ESG standards and for critical incidents. In the financial year, four serious human rights incidents were reported within the corporate customer portfolio. These customers are therefore subject to increased monitoring and undergo an ESG assessment, regardless of the premium amount. This approach ensures that UNIQA transparently manages existing risks and minimises potential reputational or consequential risks. As a result, all new decisions made concerning proposals, including decisions to renew contracts, require the prior approval of ESG experts. Known measures taken by the corresponding company are reviewed and documented for each enquiry received. ESG experts monitor progress on reported actions, regularly update risks and escalate matters in the event of a lack of or inadequate remediation. The ability to underwrite new insurance contracts may be restricted or suspended in the event of repeated serious critical incidents or if sufficient remediation is not publicly apparent. The above-mentioned serious incidents relating to human rights violations resulted in several different outcomes. In one case, the insurance contract was terminated. The respective underwriters were informed about the remaining three incidents and further steps were taken to conduct an in-depth ESG assessment. ESG experts are in close contact with the responsible underwriters to continuously assess the documented actions of the customers and to monitor the effectiveness of the steps taken. The actions taken by customers will be considered when determining how to proceed with the terms of the contract. Depending on their progress and outcome, additional monitoring measures may be initiated or – in the event of persistently inadequate countermeasures – more far-reaching steps such as restricting further insurance benefits may be considered. Further decisions regarding the monitoring or possible suspension of insurance contracts are still pending.
5.6 Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities (S2-5)
5.6.1 Targets related to suppliers
Findings from the risk assessment are used to produce specific targets and metrics for managing and evaluating supplier relationships. UNIQA’s business activities only have a negligible impact on sustainability within the value chain. To further minimise impacts, the set targets primarily include continually increasing supplier transparency by carrying out the risk assessment on an ongoing basis.
5.6.2 Targets related to corporate customers
The ESG standard governing the integration of the ESG assessment in underwriting also defines the steps for working with corporate customers to track their actions for improving their ESG performance. In the event of serious critical incidents, each new proposal received is subject to a mandatory ESG audit. Regular internal communication ensures that future business activities take current ESG performance into account. This makes it possible to react promptly to any worsening of the situation, while allowing the business relationship to continue if there is a demonstrably positive development.
Plans have been made for the development of a comprehensive UNIQA Human Rights Policy in 2026 as part of a cross-functional cooperation with various specialist departments. The policy will summarise human rights due diligence obligations with respect to all stakeholder groups and commitments made by UNIQA.