AXIS

Underwriting^∗:

Project restrictions

AXIS will not provide insurance or facultative reinsurance for:

• Thermal coal:
  • New and existing thermal coal plants or mines or their dedicated infrastructure
• Oil sands:
  • New and existing oil sands extraction or pipeline projects and operations and their dedicated infrastructure, including any facility, structure or the like
• Arctic National Wildlife Refuge:
  • Contracts for risks (including projects and operations) covering the exploration, production, or transportation of oil and gas in the Arctic National Wildlife Refuge

Company restrictions

AXIS will also not provide insurance or facultative reinsurance to companies that:

• Thermal coal:
  • Generate 20% or more of their revenues from thermal coal plants or mines
  • Generate 20% or more of their power from thermal coal
  • Are developers of thermal coal plants or mines or their dedicated infrastructure
• Oil sands:
  • Generate 20% or more of their revenues from oil sands
  • Hold more than 20% of their reserves in oil sands
• Arctic National Wildlife Refuge:
  • Generate 20% or more of their revenues from energy exploration, production or transportation activities conducted within the Arctic National Wildlife Refuge

Investments^∗:

AXIS will not make direct investments in and, as of the end of 2025, has phased out existing direct investments in companies that:

• Thermal coal:
  • Generate 20% or more of their revenues from thermal coal mining
  • Generate 20% or more of their power from thermal coal
  • Are developers of thermal coal mines or plants or their dedicated infrastructure
• Oil sands:
  • Generate 20% or more of their revenues from oil sands
  • Hold more than 20% of their reserves in oil sands
• Arctic National Wildlife Refuge:
  • Generate 20% or more of their revenues from energy exploration, production or transportation activities conducted within the Arctic National Wildlife Refuge; additionally, AXIS will not provide investment support for oil and gas projects and operations in the Arctic National Wildlife Refuge.  

^∗AXIS is committed to fully phasing out thermal coal business models from our insurance, facultative reinsurance, and investment portfolios and, accordingly, commits to reducing the remaining thresholds (e.g., revenue, power and reserve) over time. Unless a contract qualifies for an exception, the thresholds will reach 0% no later than 2030 in OECD countries and the EU and 2040 globally.

Exceptions:

We recognize that the energy transition is one of the defining challenges of our time, and that companies have an important role to play. Companies do not operate in isolation but within complex market and economic systems. We therefore believe progress requires partnership, working alongside companies as they adopt new technologies, improve resource efficiency, and transition to more sustainable business practices. Accordingly, exceptions to this policy may be considered on a case-by-case basis and we may exercise discretion in some cases, where specific criteria are met, and subject to internal review and approval, for investments and for insurance or facultative reinsurance contracts related to:

1. (i) Projects, operations, or financings related solely to renewable or “green” energy;
2. (ii) Projects that contribute to the climate transition;
3. (iii) Companies that have a transition plan in place to end all thermal coal or oil sands-related activities by 2030 in OECD countries and the EU and by 2040 globally. Coverage could from time to time include a) incidental or ancillary exposures related to existing thermal coal risks and b) exit timelines that extend beyond 2030 in OECD countries and the EU and by 2040 globally after careful consideration of a range of factors such as transition plan credibility, public decarbonization statements and commitments, or relevant industry or geographic considerations. However, a company that plans to, or is in the process of developing or expanding a coal mine, plant or its dedicated infrastructure will not be eligible for this exception; or
4. (iv) Reclamation bonds.

Effective: September 17, 2026