Chubb 2024 Climate-Related Financial Disclosure

Addressing Climate Change Through a Science-Based Underwriting Approach

We are proud to present Chubb's fourth annual TCFD Report, which reflects our ongoing work to manage our climate risks and opportunities and our evidence-based approach to addressing climate change. At Chubb, we remain firmly committed to encouraging the transition to a net zero economy while recognizing the ongoing energy needs of the global economy. We take thoughtful and innovative actions to support our clients in their efforts to transition to a net zero economy. In the eighteenth year of the Chubb Corporate Environmental Program, we continue to be guided by the same fundamental underwriting principles that underpin our business and by the best available climate science. We strive to create new ways to work with our clients and provide the essential risk transfer capacity necessary to support the net zero transition.

At Chubb, we actively review emerging climate change disclosure requirements and voluntary frameworks, in addition to complying with existing climate disclosure requirements. We have focused recently on the increasing global momentum towards the adoption of the International Sustainability Standards Board's (ISSB) IFRS Requirements for Disclosure of Climate-Related Information. Our Sustainability Report provides information on how we have considered the ISSB and other reporting frameworks in developing our approach to disclosure. Overall, we believe that we and

our stakeholders are best served by focusing our disclosures on financially material, business-relevant information. These principles guide both the scope of our disclosures in this report and our global engagement with regulators seeking comment on the adoption of climate disclosure frameworks.

Addressing Scope 3 Emissions

The fundamental purpose of insurance is to provide risk transfer capacity to ensure the efficient functioning of the global economy. Chubb is broadly exposed to global macroeconomic conditions, and it is important to emphasize both our role in the global economy and our limited ability to shape the net zero transition when considering the utility of Scope 3 greenhouse gas (GHG) emissions measurements and goals in the management of our business.

Stakeholders, including a number of regulators, have sought to require the quantification of scope 3 emissions based on the idea that if scope 3 emissions are measured, the financial industry can manage the economy to the net zero transition by allocating capital accordingly. There is one fundamental flaw with this theory: it simply doesn't work.1

This should come as no surprise because financial institutions are not regulators and cannot singlehandedly set the course for the global economy. Financial institutions can only finance and insure net zero solutions if there is a market for them. At present, global energy demand continues to grow and global economic growth mandates that energy supply keep pace with demand. Policies that restrict investment or insurance capacity supporting the critical energy needs of the global economy will only serve to raise the cost of energy to businesses and consumers, and to distance large, publicly-traded financial institutions from key sectors of the economy that require support and investment to ensure energy security and affordable, reliable, and clean energy for all.

These issues are magnified when we narrow our focus to insurance. The short-term nature of insurance contracts means that we follow market conditions rather than shape them. At Chubb, we engage with our clients on opportunities to reduce emissions in their operations. We focus these efforts on high emitting industries and seek to promote the adoption of engineering controls or practices that directly reduce emissions.

Contrast this with current approaches to calculating "insurance- associated" Scope 3 emissions. Because these efforts look across an insurer's entire book of coverage - or at least all clients in a particular sector - an estimate of insurance-associated emissions requires data from every single client. At present, this data is not actually available, so companies rely on estimates of emissions. While these estimates may at times go by technical-sounding names like "enriched" data sets, in reality they represent made up data that fails to provide meaningful insights into the conduct of the actual client and do not meet our standards for making business decisions.

Beyond questions of data availability, the Partnership for Carbon Accounting Financials (PCAF) methodology for applying that data to generate "insurance-associated" emissions is deeply flawed.

We detail below the many ways in which the PCAF methodology can be distorting. The most fundamental issue is this: the use of an "attribution factor" by PCAF, based on a ratio of premium

to revenues, strips "insurance-associated emissions" from any reasonable relationship they may have had to activity in the real economy. The pursuit of an insurance-associated emissions metric also risks diverting significant resources away from our focused work on engaging with clients in high-emitting industries, which we believe will generate greater value for our stakeholders and the net zero transition.

In light of these challenges, we believe that our holistic approach to GHG reduction will more effectively advance the transition than estimating insured emissions. Our approach focuses on several key areas discussed below:

• Chubb Climate+. Chubb Climate+ is Chubb's global, interdisciplinary team of underwriters and engineers focused on providing essential risk management services to support the transition to a net zero economy. In May 2024, Chubb introduced a Climate Resilience Service Leader to develop services that help our customers understand their physical climate risks and capitalize on resilience opportunities. These services are underpinned by data and our expert engineering assessments to create actionable climate plans. More details on Chubb Climate+ can be found in the Strategy section of
  this report.

• Chubb's Underwriting Criteria. Since becoming the first global insurer to announce methane criteria for oil and gas extraction activities in 2023, we have continued to develop underwriting criteria for high-emitting industries. In addition to these criteria, our risk engineering teams provide on-the-ground engagement and support for our clients as they work to address their GHG emissions in the real economy. More details on the development of our underwriting criteria are in the Strategy section of
  this report.
• Supporting Thought Leadership on the Role of Insurance in the Net Zero Transition.We are proud to continue our industry leadership in encouraging ascience-basedapproach to climate change, including through our collaboration with the University of Pennsylvania to facilitate dialogue between investors, regulators, insurance companies and other stakeholders regarding the role of the insurance industry in facilitating the transition to a net zero economy. We also continue to explore other opportunities to contribute to efforts by our regulators and with our peers to support the net zero transition and enhance climate resilience.

We understand that our investors seek information to quantitatively assess both our exposure to climate risks and our progress in facilitating the transition to a net zero economy. We believe that the most essential information we can provide relates to our efforts to grow our support of the transition activities of our clients through Chubb Climate+ and to assess our engagement efforts through our underwriting criteria. Further data on these efforts is provided in the Metrics and Targets section of this report.

Challenges with the PCAF Attribution Factor

PCAF relies on premium revenue and total reported GHG emissions to identify insurance-associated emissions. PCAF uses revenue exclusively, ignoring commonly used indicators such as total assets, total revenue or number of employees. This reliance on revenue alone is flawed in numerous ways, including because revenue fluctuates with general macroeconomic market movements unrelated to GHG emissions and because there are differences in how revenue is calculated across the world due to the differences in the reporting frameworks used by companies depending on their size and respective industry.

These factors, when considered separately and in combination, all mean that relying on revenue as a proxy for the importance

1. Premiums fluctuate with insurance market hardening and softening cycles that are unrelated to GHG emissions.
2. Premiums reflect an insurer's assessment of an insured's risk profile for perils covered by the policy, which may change for reasons unrelated to GHG emissions.

This can lead to nonsensical results under the PCAF framework:

For example, an insurer who sells a policy with a $200,000 premium to an early-stage mining company with $15,000 in revenue and a total reported GHG emissions inventory of 100,000 metric tons. Under the PCAF methodology, the "insured emissions" associated with this client would be:

of an insurance purchase made by a given company is inherently distorting. PCAF then calculates an insured's proportionate responsibility for a company's emissions by multiplying the

( $200,000 )

$15,000

x 100,000 mtCO2e = 1,333,333 tCO2e

company's emissions by an attribution factor defined as premium divided by revenue. This reliance on premium is also flawed in numerous ways, including:

Alternatively, the insured emissions for an insurer who sells a policy with a $1 million premium to a large tech company with

$1 billion in revenue and a total reported GHG emissions inventory of 200,000 metric tons would be:

( $1,000,000 )

$1,000,000,000

x 200,000 mtCO2e = 200 tCO2e

A Note on Emerging Climate Disclosure Frameworks

In the past year, Chubb closely monitored global climate disclosure regulatory developments including the Securities and Exchange Commission (SEC) Climate Disclosure Rules release (and related challenges). In general, we are concerned about the proliferation of disclosure requirements across numerous jurisdictions that are overly burdensome, duplicative or unduly focused on Scope

3 reporting, which fail to meaningly advance GHG reduction. We favor approaches that allow us to focus on financially material issues and facilitating the reduction of GHG emissions in the real economy over those that remain narrowly focused on counting or are overly reliant on estimation of data.

To encourage consistency and efficiency in climate reporting, Chubb supports the adoption of the ISSB and we anticipate the ISSB framework will become the prevailing disclosure standard. After reviewing alternative materiality metrics that apply to climate and sustainability reporting, such as the Corporate Sustainability Reporting Directive (CSRD) "dual materiality" approach, we continue to believe that financial materiality is the most appropriate approach to provide our stakeholders with information that is relevant to our business and our management of climate and sustainability risks.

This year, in accordance with the requirements of Article 964b of the Swiss Code of Obligations (CO), Chubb published its first annual Sustainability Report. Consistent with the requirements of Article 964b CO, this inaugural Sustainability Report begins

with an overview of Chubb's business model and a summary of our approach to sustainability. The Sustainability Report then includes specific sections addressing sustainability governance, environmental issues (including climate change), our development of a diverse and sustainable workforce, and our commitment to ethical business practices. The Sustainability Report was approved by Chubb's shareholders at its May 2024 Annual General Meeting.

Outside of the regulatory context we continue to monitor developments in voluntary standards. The most notable recent development in this space is the release of the Science Based Targets Initiative's (SBTi) second consultation draft for net zero standards for financial institutions. Unfortunately, SBTi's rigid stance on fossil fuels remains at odds with the needs of the present energy economy. Under SBTi's proposed approach, we would

be required to immediately cease all investing and underwriting activity related to "long term" fossil fuel assets. This approach ignores the complexities of the energy transition and the fact that the global economy must both decarbonize and meet rising energy demand. While we believe that there is ample opportunity to engage with the energy industry on transition planning and actual measures that will reduce GHG emissions, meaningful engagement cannot be driven by an absolutist, exclusionary approach that fails to address the energy economy.

Chubb governance related to climate risk includes the oversight functions and active engagement of its Board of Directors, extensive involvement of its most senior executives, and its global enterprise risk management (ERM) framework.

Board of Directors Oversight

The Board of Directors recognizes the critical risks arising from climate change and is actively engaged in overseeing the company's climate-related strategies, including the development of its climate policies and climate-related business activities. The Board and its committees receive regular updates on climate issues from management and external experts.

In addition to the full Board's general oversight, two Board committees are charged with specific climate-related oversight responsibility:

• Risk & Finance Committee: oversees our ERM function, which includes extensive analysis of climate risk, including climate- related catastrophe risk, such as increased threats of wildfire, sea level rise and hurricane frequency and intensity, and reviews investment risks associated with climate change.
• Nominating & Governance Committee:oversees our corporate citizenship activities and environmental, social, and governance (ESG) policies and initiatives, including those relating to climate change and the environment, such as our fossilfuel-relatedunderwriting and investment policies, corporate environmental goals and philanthropic efforts. The committee also receives updates and provides input on feedback from shareholders and other stakeholders on Chubb's climate efforts.

Management Responsibilities

Chubb is engaged in a wide range of climate-related activities that include:

• Identifying and analyzing climate risk;
• Public engagement on climate issues with government officials, regulatory bodies, climate advocacy groups, climate experts and a variety of other interest groups;
• Consideration and implementation of appropriate climate- related underwriting and investment actions;
• Limiting the company's own GHG emissions; and
• Providing philanthropic support for climate resilience projects.

Chubb's CEO and its management Executive Committee provide oversight and direction of these activities and set the company's climate-related strategies. The CEO engages extensively on climate issues, including in his annual shareholder letter and other public communications. Other senior executives with climate- related responsibilities include:

• The General Counsel coordinates the company's ESG initiatives, including its climate-related policies and strategies.
• The Chief Risk Officer oversees the ERM function, including risks associated with climate change. Various management teams, including the Risk and Underwriting Committee, product boards and risk-related committees, meet regularly to evaluate specific risks and risk accumulation in Chubb's business activities and investments.
• The Global Climate Officer is responsible for coordinating
  Chubb's climate-related strategies and supporting the execution of business and public policy initiatives. The Global Climate
  Officer also oversees our internal climate activities, including
  GHG emissions measurement and reduction commitments.

Chubb believes the most effective use of its resources to support society's transition to net zero is to provide our clients with the risk transfer capacity necessary to facilitate their transition efforts. Our climate strategy is underwriting-focused and consists of three main pillars: (1) applying our underwriting and engineering expertise to support the technologies that will promote the transition to the net zero economy, (2) promoting climate resilience through engineering and new service offerings, and

1. applying a science-based underwriting approach to develop technical underwriting criteria that encourage the adoption of controls and best practices in high-emitting industries.

Chubb Climate+: Underwriting for the Transition and Engineering for Resilience

In January 2023, we launched Chubb Climate+, our global climate practice. Chubb Climate+ focuses on facilitating and advancing a global transition to a net zero economy by expanding the company's already market-leading position in the natural resources and Climate Tech industries. Chubb Climate+ provides a range of global solutions to support our clients in their transition to a net zero economy and increase their resilience to the physical impacts of climate change. The practice draws on Chubb's extensive technical capabilities in underwriting

and risk engineering, bringing together Chubb units engaged in traditional, alternative and renewable energy, climate tech and risk engineering services. Chubb Climate+ provides a broad spectrum of insurance products and services to businesses engaged in developing or employing new technologies and processes that support the transition to a net zero economy. It also provides risk management and resilience services to help those managing the impact of climate change. Our commitment to this endeavor is reflected in the scope of our Chubb Climate+ business: as of January 2024, Chubb insured one-third of the Global Cleantech

100. Chubb Climate+ is focused on growing our practice in renewable energy and Climate Tech.

We have defined our Climate Tech sectors as follows:

Chubb Climate+ Climate Tech Occupancies

Renewable & Alternative Energy Companies supporting solar, wind, hydro, geothermal, biomass, hydrogen, biofuels, and nuclear

Built Environment & Energy Efficiency Building automation solutions, technology for efficient heating and cooling equipment, alternative materials, industrial processes, adaptation, andwaste-waterfiltration technology

Food & Agriculture

Vertical farming, ag tech, plant-based/cellular foods, crops engineering, low-carbon fertilizer, and aquaculture

Transport & Mobility

Electric vehicles, EV component parts, charging stations and infrastructure, maritime decarbonization, aviation, micro-mobility, and contractors' equipment

Storage & Transmission

Batteries, alternative storage, fuel cells, smart grids, and transmission infrastructure

Carbon Technology & Climate Finance

Carbon Capture Utilization and Storage, nature- Carbon Capture Utilization and Storage, nature- based solutions, carbon financial markets, venture capital, incubators, associations, research, and development firms supporting Climate resilience

Chubb has added to the capabilities of the risk engineering team by hiring specialists with climate, resilience, and adaptation experience, and also implementing significant efforts over the past year to upskill the broader Chubb Risk Engineering team to be able to engage with our insureds on a broad range of issues related to sustainability and climate. In March, fourteen of Chubb's dedicated Oil and Gas Risk Engineers and Energy Underwriters participated in a two-day customized training program at the Methane Emissions Technology Evaluation Center (METEC) within Colorado State University Energy Institute. The training, which provided invaluable hands-on insights into cutting-edge methane detection technologies, leak sources, and abatement opportunities, further strengthens our Risk Engineering and Underwriting team's deep technical knowledge within the oil and gas industry.

Additionally, in May 2024 we established Chubb Climate+ Resilience Services, a strategic service practice. Led by a dedicated Resilience Service leader, this practice combines strategic advisory capabilities with our extensive engineering expertise and forward-looking climate modeling to provide customers with comprehensive insights into their physical climate risk landscape, and actionable resilience recommendations to support strategic decision-making. By developing these strategic services

in collaboration with broader business functions such as risk engineering, underwriting, and claims, Chubb Climate+ Resilience Services takes a comprehensive and innovative approach to helping customers and consumers maximize the opportunities arising from the global transition to a net zero economy.

Developing science-based underwriting criteria for high-emitting industries

Through Chubb's underwriting process, we have opportunities to promote good risk management and the adoption of sound engineering practices by our clients. Our climate strategy seeks to deploy Chubb's fundamental areas of expertise to address the high-emitting industries we insure. Our approach to these industries involves conducting our own review of best practices, seeking guidance from non-governmental organization (NGO) partners, and engaging with our clients to develop perspectives on GHG emissions mitigation measures that apply best engineering practices and relate to risk quality. As we develop underwriting criteria, we will simultaneously offer our on-the-ground engineering expertise, working on-site with our clients to help deploy best practices and controls to reduce GHG emissions.

We applied this approach to the development of our oil and gas underwriting criteria and we are currently evaluating the potential evidence to support the development of criteria in other high-emitting industries. We anticipate announcing criteria for additional high-emitting industries in the near term.

Oil and Gas Underwriting Criteria and

Conservation Policy

In March 2023, Chubb introduced underwriting criteria and conservation criteria that applied to oil and gas extraction projects.2 In April of this year, we updated these criteria for larger oil and gas companies and announced new standards for midstream activities. Chubb's climate underwriting criteria for oil and gas encompass:

Standards for methane emissions

• For oil and gas producers with annual revenues less than
  $1 billion, Chubb will continue to provide insurance coverage for clients that implement evidence-based plans to manage methane emissions, including, at a minimum, having in place programs for leak detection and repair, the elimination of non-emergency venting, and adopting one or more measures that have been demonstrated to reduce emissions from flaring.
  Clients will have a set period of time to develop an action plan based on their individual risk characteristics. We may decline coverage if a potential policyholder cannot meet our methane performance expectations.
• For oil and gas producers with annual revenues greater than $1 billion, Chubb expects our insureds will achieve a methane emissions intensity of 0.2% or less by 2030 across their global operations. Chubb will continue to provide coverage for clients that are able to report their methane emissions intensity, are engaging in direct measurement of methane emissions, and demonstrate progress towards achieving methane emissions intensity of 0.2% or less. We may decline coverage if a potential policyholder cannot meet our methane performance expectations.
• For midstream oil and gas operations with annual revenues greater than $1 billion, Chubb expects our insureds will achieve a methane emissions intensity of 0.2% or less by 2030 across their global operations. Chubb will continue to provide coverage for clients that are able to report their methane emissions intensity, are engaging in direct measurement of methane emissions, and demonstrate progress towards achieving near zero methane emissions intensity. We may decline coverage if a potential policyholder cannot meet our methane performance expectations.

• For midstream oil and gas operations with annual revenues less than $1 billion, Chubb will continue to provide insurance coverage for clients that implement evidence-based plans to manage methane emissions, including, at a minimum, having in place programs for leak detection and repair and the elimination of non-emergency venting and adopting one or more measures that have been demonstrated to reduce emissions from flaring.
  Clients will have a set period of time to develop an action plan based on their individual risk characteristics. We may decline coverage if a potential policyholder cannot meet our methane performance expectations.

We will support our clients as they endeavor to improve their methane emissions controls by providing resources and support through our risk engineering services. We have created and will continue to expand the Chubb Methane Resource Hub as a central location for resources and support for our insureds.

Coal Policy: Chubb was the first major insurer in the U.S. to announce a policy concerning thermal coal-related underwriting and investment. In 2019, we adopted the following policy:

• Chubb no longer underwrites risks related to the construction and operation of new coal-fired plants.
• Chubb does not underwrite new risks for companies that generate >30% of revenues from thermal coal mining and began phasing out coverage of existing risks that exceeded this threshold at the end of 2022.
• Chubb does not underwrite new risks for companies generating more than 30% of their energy production from coal and began phasing out coverage of existing risks exceeding this threshold at the start of 2022 (accounting for the viability of alternative energy sources in the impacted region).
• Chubb no longer makes new debt or equity investments in companies that generate more than 30% of revenues from thermal coal mining or that generate more than 30% of energy production from coal.

Given that our Coal Policy is now five years old, we are reviewing the policy and expect to provide an update before the end of the year.

Oil Sands Policy: In 2022, Chubb adopted a policy that it would no longer underwrite risks for projects involving direct mining or in- situ extraction and processing of bitumen from oil sands.

Chubb Methane Resource Hub

To support our clients in their steps to improve their methane emissions controls, Chubb developed and launched the Chubb Methane Resource Hub in 2023. The goal of the hub is threefold:

1. Educate and raise awareness for reducing methane emissions to drive near-term climate impact.
2. Be a one-stop shop resource library for methane emissions thought leadership.
3. Assist oil and gas companies with identifying vendors who have knowledge and expertise in detecting and managing methane emissions.

In 2024, Chubb updated the library with new content including interviews and discussions with our partners at the Environmental Defense Fund, new educational animations and videos, and new featured service providers.

Building off the success of the Chubb Methane Resource Hub, we look forward to expanding the climate resources we offer to our clients through the development of a hub focused on agriculture sustainability and resilience. Chubb's agriculture clients include farmers, ranchers and agribusinesses, who each face unique exposure to extreme weather events. The new hub will be designed to support these clients in understanding the climate risks facing the agriculture sector and equip them with resources and guidance to adopt on-farm practices which can increase resilience and sustainability. Further details on the Agriculture Hub rollout are expected in the near term.

Assessing our exposure to climate risks

We consider a wide range of risks related to climate change, from the effect of increased wildfire and storm intensity on property claims to the potential effect that changing energy usage may have on the fossil fuel industry's insurance demand. Underlying our physical climate change risk and resilience assessment is one fundamental fact about the insurance industry: most insurance policies are issued on an annual basis, meaning that we are able to quickly adapt our underwriting strategies to emerging climate risks. For example, we can respond to increased claims risk (e.g. from wildfires or hurricanes) with rates and geographic limitations on exposure that reflect that increased risk. It also means that we can quickly adjust our underwriting strategies to, for example, focus on new business opportunities in clean energy, as we are doing with Chubb Climate+.

As we manage climate risk, Chubb closely follows emerging trends in climate litigation. For example, the risk associated with "greenwashing" and "impact washing" - the false or misleading impression regarding the environmental and sustainability practices, policies, products, and activities of a company - is increasing, particularly with expanding regulatory focus. Alleged corporate greenwashing and other alleged ESG-related misrepresentations by companies from many sectors have received scrutiny by a wide range of interested parties. Chubb is monitoring these risks on its insurance products, in particular directors and officers (D&O) liability coverages and General Liability coverages. We continue to evaluate these risks in transition-exposed industries and have provided extensive training to our global D&O underwriters about the risks presented by climate change. We seek to manage our exposure through limits management, appropriate pricing and coverage terms.

We conduct extensive analysis of the risks related to how climate change may be altering the frequency and severity of natural catastrophe events. We maintain a large internal team of natural catastrophe modelers who regularly assess the potential for climate-driven changes in the frequency and severity of losses. We quantify these risks on an annual basis through the Probable Maximum Loss ("PML") calculation, which is described in more detail below.

Our Enterprise Risk Unit supports Climate Change Scenario testing across Chubb's global operations. The ERU is working to develop a unified approach to climate scenario analysis that can be applied across Chubb's operations. The scenarios under assessment rely on the Intergovernmental Panel on Climate Change (IPCC) RCP4.5 and RCP8.5 scenarios for physical climate impacts, as well as multiple transition scenarios over short, medium and long-term timeframes, and the Network for Greening the Financial System ("NGFS") scenarios for both transition and physical risks. We assess the impact of physical, transition and liability risks over modeled timeframes.

The IPCC has published several trajectories of global warming, which are used to inform scenarios assessed across the financial services industry. We are evaluating the IPCC's extreme climate change scenario, RCP8.5, which represents a 4.5ºC temperature rise by the end of the century, to provide a broad range of outcomes. The impacts of this scenario are layered on our existing natural catastrophe perils. We have licensed the RMS (industry standard natural catastrophe model vendor) forward-looking climate views for U.S. hurricane, which is the largest contributor to our Worldwide Aggregate PML, and will be evaluating additional climate solutions for other key perils.