December 2024

At Securian Financial, our purpose is to build secure tomorrows. As a mutual holding company, we take a long-term view of managing our company by prioritizing the interests of our customers, employees, and other stakeholders. Sustainable investing aligns with our purpose and values of integrity, caring for our community and ensuring long-term financial security.

Purpose and Scope

The purpose of this Sustainable Investing Statement is to clearly communicate the ways in which we incorporate principles of sustainability into our investment decision making process for our life insurance general accounts. Non-market rate impact investments are not addressed within this statement. These types of opportunities are reviewed separately, on a case-by-case basis.

Philosophy and Beliefs

Sustainable investing refers to the risks and opportunities that stem from incorporating material environmental, social and governance factors into our investment decision-making and ownership. Material factors include those decisions that can significantly affect a company’s performance, such as the financial value of certain assets or liabilities, operational risks, and strategic outcomes.

We believe that incorporating material and relevant sustainability factors can affect investment returns and enhance our decision-making when paired with the traditional, fundamental data that remains at the core of our investment framework. Our investment framework accounts for widely varying drivers across asset classes. Instead of a one-size-fits-all approach, investment teams identify factors to inform the analysis of each investment we consider. We pay special attention to how each factor affects our risk of loss, given our position in the capital structure and the term of our investment. Factors considered and relative impact will vary for each investment, depending on individual company governance, sector, geographic region and asset class. For example, good governance and strong social practices support a sustainable, fair, and transparent approach to meeting the needs of all stakeholders. We prefer a comprehensive approach to corporate governance. While integrated elements may differ from strategy to strategy, corporate governance is almost always an important influencing factor in our investment decisions. Depending on the situation, we may also consider rapidly evolving physical, economic, and political risks in our framework, such as physical climate risk and potential policy impacts, like carbon taxes or extreme weather. We recognize that company performance can also be affected by litigation, capital spending, or negative reputational effects. All other things being equal, we favor investments with a strong sustainability profile because we believe considering all relevant factors will enhance our investment decision making, help reduce volatility and improve returns over the long term.

Relevant Company Policies

Our code of ethics and business conduct policy addresses conflicts of interest and requires adherence to high ethical standards and integrity. Our information protection program addresses privacy, responsible data use and related controls.

Integration and Reporting

To the extent that we identify sustainability factors that represent financially material risks or potential commercial opportunities for companies and assets we invest in, our investment teams will consider these factors as part of their investment analysis and decision-making as appropriate to achieving their risk/return objectives. We believe in a tailored approach to sustainability by asset class, and encourage tailored analytical frameworks, assessment tools and implementation approaches suited to each asset class. Identified financially material sustainability risks and opportunities will impact our investment processes in different ways depending on the particular factor, the applicable asset class, investment strategy, and the idiosyncratic details of each investment. The risks most frequently cited include extreme weather impacts, environmental legislation, and regulations. To address identified risks, portfolio managers consider a wide range of mitigants, including premium pricing, the term of the investment, internal ratings adjustments, sizing adjustments, and other “best-in-class” approaches.

Where data is available, we review general account investments based on various sustainability metrics and criteria, enabling a better understanding of portfolio risks and decision making around desired sustainability outcomes. We continue to build on this work by expanding our asset coverage universe and improving data quality in non-public asset classes to enhance our analytics.

Frameworks/Third Party Standards

We actively monitor external frameworks to determine what is relevant and appropriate for Securian Financial. Currently, our climate risk framework is aligned with the Task Force for Climate-Related Financial Disclosures (TCFD) guidance and the NAIC’s climate risk disclosure survey.

Oversight and Governance

Sustainability oversight is imbedded across the organization and includes four board committees: Audit, Human Resources and Compensation, Investment, and Nomination and Governance. Each committee oversees different elements of sustainability. In addition, at the asset management level, Securian Asset Management’s Investment Risk Oversight Committee, which includes the Chief Investment Officer, the President, as well as all asset class portfolio managers, reviews and discusses reporting related to sustainable investments. In addition, we provide regular updates on sustainable investments to the Investment Committee of the Board.

Securian Financial publishes an annual Sustainability Report that highlights how the company addresses the many sustainability issues and initiatives impacting our business. More information on our overall approach to sustainability, including oversight and governance, can be found in our annual Sustainability Report.

Statement Review

We review this statement at least annually. Updates are recommended by senior leaders and reviewed in the Investment Committee of the Board prior to publication on our website and in our Sustainability Report.