Tower Limited/Announcement
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Tower Delivers Strong FY24 Result

Full Year Results27 November 2024TWRFinancials

28 November 2024
Tower Limited

FY24 Full Year Results for Announcement to Market

In accordance with NZX Listing Rule 3.5.1 we enclose the following for release to the market

in relation to Tower Limited’s (NZX/ASX: TWR) FY24 Full Year Results:


1 Media Release

2 Results Announcement

3 Annual Report (including Financial Statements)

4 Results Announcement Presentation

5 Results Announcement Call Script

6 NZX Distribution Notice

7 Climate Statement


Tower’s Chairman Michael Stiassny, Chief Executive Officer Blair Turnbull and Chief Financial

Officer Paul Johnston will discuss the full year results at 10:00am New Zealand time today.

Tower’s Board confirms for the purposes of ASX Listing Rule 1.15.3 that Tower continues to

comply with the NZX Main Board Listing Rules.


ENDS


This announcement has been authorised by the Tower Board.


Blair Turnbull

Chief Executive Officer

Tower Limited


For media enquiries, please contact in the first instance:

Emily Davies

Head of Corporate Affairs and Sustainability

+64 21 815 149

emily.davies@tower.co.nz


For investor queries, please contact in the first instance:

James Silcock

Head of Strategy, Planning and Investor Relations

+64 22 395 9327

james.silcock@tower.co.nz


Market Information

NZX Limited

Level 1, NZX Centre

11 Cable Street

Wellington

New Zealand

Company Announcements Office

ASX Limited

Exchange Centre

Level 6, 20 Bridge Street

Sydney NSW 2000

Australia

---

Level 5, 136 Fanshawe Street
Auckland 1142, New Zealand

ARBN 645 941 028

Incorporated in New Zealand

28 November 2024


Tower Delivers Strong FY24 Result


Kiwi insurer, Tower Limited (NZX/ASX: TWR) today reported its result for the year to 30 September 2024,

recording an underlying net profit after tax (underlying NPAT) of $83.5m and a reported profit of $74.3m.


The strong results were due to Tower experiencing no large events in the financial year, year-on-year

improvements in business-as-usual (BAU) claims performance, premium growth, and operational and digital

efficiencies. This was a significant improvement compared to the $1m

1

reported loss in FY23, which was primarily

due to catastrophe events.


Summary of FY24:

• Underlying profit $83.5m vs $7.1m in FY23

• Reported profit $74.3m vs $1m loss in FY23

• Gross written premium (GWP) $595m, up 15% on FY23

• Business as usual (BAU) claims ratio 48.1% vs 55.1% in FY23

• Management expense ratio (MER) improved to 31.4% vs 32% in FY23

• Large event costs -$2.3m vs $55.6m in FY23, due to Tower experiencing no large events in the financial

year and a favourable revision to prior year large events costs

• Customer numbers were down 2% to 305,000 vs 311,000

2

in FY23 partly due to tightened risk appetite

for high-theft motor vehicle models


Reflecting the positive FY24 results and based on Tower's ordinary dividend policy, the Board has declared a final

dividend of 6.5 cents per share. This brings total dividends for FY24 to 9.5 cents per share.


The Board has also conditionally approved a return of NZ$45m of excess capital to shareholders, by way of

mandatory share buyback

3

. The return of capital is expected to deliver meaningful earnings per share accretion

to Tower’s shareholders.


Strong business performance

Tower CEO, Blair Turnbull says, “Continued improvements in claims performance, sustained GWP growth and

enhanced business efficiencies along with unusually benign weather in New Zealand and the Pacific, have

delivered a positive result for shareholders.


“This strong result is underpinned by our strategy of delivering simple and rewarding customer experiences

combined with our use of digital technology and data.”


The BAU claims ratio has reduced to 48.1% compared to 55.1% in FY23. This improvement was driven by a

combination of rating increases, enhanced processes, a reduction in motor theft claims due to targeted

underwriting actions and lower crime, and calmer weather, which flattened the frequency of house claims in the

year.



1

All prior year metrics have been restated to align with the new accounting standard, IFRS 17, for consistent comparisons.

2

Prior year customer numbers have been adjusted to exclude sold and held for sale portfolios which include the Solomon Islands

business and Vanuatu subsidiary, and the New Zealand commercial rural portfolio.

3

The return of capital will be conducted as a scheme of arrangement. It is subject to receipt of High Court approval of the arrangement

and shareholder approval, as well as Tower continuing to satisfy solvency and prudential capital requirements, and the Tower Board

remaining satisfied that it remains prudent to undertake the capital return, in each case up to the time the capital return is give effect.


Level 5, 136 Fanshawe Street

Auckland 1142, New Zealand

ARBN 645 941 028

Incorporated in New Zealand

As at 31 October 2024, Tower had closed 99% of both the Auckland Anniversary and Cyclone Gabrielle FY23

catastrophe event claims.


Premium growth continued in FY24 with GWP increasing 15% year on year to $595m. This was mainly due to

prior period rating increases aimed at mitigating the impacts of inflation, crime and higher reinsurance costs

following the 2023 catastrophe events.


Mr Turnbull says, “We recognise the impact of premium increases for customers. As inflation settled later in the

financial year we moved to moderate premium increases, particularly for low-risk assets. With inflation now

easing, we expect premium increases to stabilise further.”


GWP from house insurance policies grew by 18% in the year, reflecting a stronger focus on the home insurance

market.


Delivering operational efficiencies

Tower’s GWP growth, along with disciplined cost control has led to another improvement in MER, with it

reducing to 31.4% from 32% in FY23. Tower is continuing to further improve business efficiency through

investments in digitisation and streamlining operations.


Tower’s Suva hub, which was expanded in FY24, is now answering more than half (55%) of all New Zealand

customer sales and service calls.


No large events recorded in FY24

Tower’s conservative large events allowance of $45m for FY24 was unused as no large events were recorded in

the financial year. The unused allowance increased underlying NPAT by $32m ($45m less tax).


FY25 guidance

Tower's FY25 full year guidance is for underlying NPAT to be between $50m and $60m. This assumes full

utilisation of a large events allowance which has prudently been set at $50m, reflecting growth in the house

portfolio, and inflation-based increases to sums insured. GWP growth in FY25 is expected to be between 10% and

15% reflecting a balance of rating and organic growth. Digitisation and efficiency initiatives are expected to

improve MER to less than 29%.


ENDS


This announcement has been authorised by Blair Turnbull, CEO, Tower Limited.


For media enquiries, please contact:

Emily Davies

Head of Corporate Affairs and Sustainability

+64 21 815 149

emily.davies@tower.co.nz


For investor enquiries, please contact:

James Silcock

Head of Strategy, Planning and Investor Relations

+64 22 395 9327

James.silcock@tower.co.nz

---

Template
Results announcement

(for Equity Security issuer/Equity and Debt Security issuer)

Updated as at June 2023


Please do not amend or delete individual rows. As this template relates to prescribed content, changes to content

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NZX as required under NZX Listing Rule 3.26.1.


Results for announcement to the market

Name of issuer Tower Limited

Reporting Period 12 months to September 2024

Previous Reporting Period 12 months to September 2023

Currency NZD

Amount (000s) Percentage change

Revenue from continuing

operations

$555,818 18%

Total Revenue $562,409 17%

Net profit/(loss) from

continuing operations

$70,884 2640%

Total net profit/(loss) $74,285 N/a – prior year was a loss

Interim/Final Dividend

Amount per Quoted Equity

Security

6.5 cents

Imputed amount per Quoted

Equity Security

Not Applicable.

Record Date 16 January 2025

Dividend Payment Date 30 January 2025

Current period Prior comparable period

Net tangible assets per

Quoted Equity Security

$0.73 $0.48

A brief explanation of any of

the figures above necessary

to enable the figures to be

understood

Growth in revenue from continuing operations was predominantly

driven by prior period rating increases designed to mitigate the

impacts of inflation, crime and increased reinsurance costs

following the 2023 catastrophe events.


The growth in profit reflected premium growth and improvements

in the management expense ratio; improvements in claims

performance; along with the absence of large events, which had

impacted the prior year’s profit.


Please refer to the 2024 full year results announcement

presentation for further information.

Authority for this announcement
Name of person


authorised

to make this announcement

Tania Pearson, General Counsel & Company Secretary

Contact person for this

announcement

Emily Davies, Head of Corporate Affairs and Sustainability

Contact phone number +64 21 815 149

Contact email address emily.davies@tower.co.nz

Date of release through MAP


28 November 2024

---

Tower Limited
Annual Report 2024

Contents
2024 In review2

2024 snapshot

3

Update from the Chair and CEO

5

Delivering on our strategy

9

Our purpose, vision and strategy

10

Leading customer experience

11

Operationally efficient

22

Resilient

29

Effective & distinctive culture

34

Environmental, social and governance performance

41

Board of Directors

50

Consolidated financial statements

52

Financial statements

53

Notes to the consolidated financial statements

58

Independent auditor’s report

99

Appointed actuary’s report

103

Corporate governance at Tower

104

Global Reporting Initiative content index

115

Tower directory

121

Registry details

122

1ANNUAL REPORT 2024 ContentsGRI content index Corporate governanceConsolidated financial statementsSustainabilityOur strategy2024 in reviewANNUAL REPORT 2024Our strategy

2024
in review

2ANNUAL REPORT 2024 ContentsGRI content index Corporate governanceConsolidated financial statementsSustainabilityOur strategy2024 in review

1
Underlying Profit, GWP, MER, BAU claims ratio and COR are non-GAAP financial information. Consequently, they may not be comparable to similar measures presented by other reporting entities and are not subject to audit or independent review. GWP is a component of

Insurance Service Revenue. MER is the ratio of underlying management expenses, including claims handling expenses, to underlying Insurance Service Revenue. BAU Claims Ratio is the ratio of underlying claims expense, excluding large events, to underlying Insurance

Service Revenue. Underlying Profit includes large events but excludes certain large or non-recurring items. Tower uses Underlying Profit, and related measures, as internal reporting measures because management believes they provide a better measure of Tower’s

underlying performance than Reported Profit and are useful to investors as they make it easier to compare Tower’s underlying financial performance between periods. A reconciliation of these items to GAAP financial information can be found in the appendix of Tower’s

FY24 Results Announcement Presentation released on 28 November 2024 via the NZX and, for FY23 comparatives, in the appendix of the IFRS 17 transition update released on 15 May 2024 via the NZX.

2

Excluding divested portfolios.

3

HY24 dividend 3c, FY24 dividend 6.5c.

Reported profit after

taxation vs. $1m

loss in FY23

Underlying profit

vs. $7.1m in FY23

1


$

74.3

m

$

83.5

m

Management

expense ratio

(MER)

1

down from

32% in FY23

Gross written premium

(GWP)

1

, up 15%

2

from

$527m in FY23

1

31.4

%

$

595

m

Combined

operating ratio

1


(COR) vs 100.4%

in FY23

Business as usual

(BAU) claims ratio

1

vs

55% in FY23

79

%

48

%

Shareholders

Total FY24 dividends

per share declared

3


Capital return

declared

9.5

C

$

45

m

Performance

2024 snapshot

3ANNUAL REPORT 2024 ContentsGRI content index Corporate governanceConsolidated financial statementsSustainabilityOur strategy2024 in review

Customers
Community

1

As at 13 September 2024, based on Tower’s latest staff engagement survey.

Employee diversity and inclusion score in the top 10% of the global finance sector.

2

Prior year customer numbers have been adjusted to exclude sold and held for sale

portfolios which include the Solomon Islands business and Vanuatu subsidiary, and

the New Zealand commercial farm portfolio. FY24 customer numbers decreased

2% partly due to tightened risk appetite for high-theft motor vehicle models.

3

FY23 reported claims includes large events, there were no large events in FY24.

4

Two Tower Climate Change Scholarships awarded to University of Waikato

students (NZ) and three Tower Vunilagi Scholarships awarded to University of the

South Pacific students (Fiji).

Employee diversity and

inclusion score

1

vs. 8.6

in FY23

Employee engagement

score

1

vs. 7.8 in FY23

Volunteer hours in our

communities in FY24

vs. 390 in FY23

Tower scholarships

awarded to university

students

4

8.9

8.1

2,300

5

Customers vs.

311,000 in FY23

2

305,000

Reported claims across

NZ and the Pacific vs.

87,500 in FY23

3

67,500

People

4ANNUAL REPORT 2024 ContentsGRI content index Corporate governanceConsolidated financial statementsSustainabilityOur strategy2024 in review

Update from the Chair and CEO
Tower has a strong purpose, clear

strategy and is focused on fostering

a distinctive culture. We are pleased

to report on the progress we made

in FY24.

FY24 was a year of milestones for Tower: from

celebrating our 150-year anniversary in Fiji; to opening

our new Suva hub operational centre; ringing in 25 years

of being listed on NZX; and it was followed by entry into

the NZX 50 just after year end.

All the while we have remained focused on progressing

our strategy to be the leading direct personal lines

and SME insurer in New Zealand (NZ) and our chosen

Pacific markets.

We continue to strive towards delivering beautifully

simple and rewarding experiences that our people

and customers rave about. And our investments in

technology continue to improve Tower’s customer

experience and operational efficiency.

Strong business performance

For the year to 30 September 2024, underlying profit

was $83.5m, up from $7.1m in FY23. Reported profit was

$74.3m, compared to a $1m loss in FY23.

Premium growth, excluding divested portfolios,

continued in FY24 with gross written premium (GWP)

increasing 15% year on year to $595m. This was

predominantly driven by prior period rating increases

designed to mitigate the impacts of inflation, crime

and reinsurance cost hikes following the 2023

catastrophe events.

Tower’s GWP growth, combined with disciplined cost

control has seen management expense ratio (MER)

further improve, reducing from 32% in FY23 to 31.4%.

Targeted underwriting actions, stronger-than-expected

business performance, particularly in claims, and

unusually, no large events occurring in the financial year,

have been key drivers of this year’s results.

Tower’s FY24 market guidance assumed full utilisation

of a $45m large events allowance. However, as no large

events occurred, net profit after tax (NPAT) was $32m

higher than initially indicated, reflecting the tax-adjusted

$45m allowance that was not used.

We have a robust reinsurance programme to help

manage large events and adequately protect Tower’s

solvency and capital positions.

Tower’s NZ parent solvency margin improved from

$79.8m at 30 September 2023 to $171.4m at September

30 2024. As at 30 September 2024, Tower’s NZ parent

solvency ratio was 212%.

During the year Tower began reporting against NZ IFRS

17 Insurance Contracts (IFRS 17), a new accounting

standard applicable to all insurance companies. Tower’s

strategy, profitability and dividend policy are unaffected

by the new standards.

In accordance with Tower’s ordinary dividend policy to

pay 60-80% of adjusted earnings, where prudent to

do so, Tower’s Board has declared a final dividend of

6.5 cents per share, bringing total dividends to 9.5 cents

per share in FY24.

The Board also approved a return of NZ$45m of excess

capital to shareholders, by way of a mandatory share

buyback, subject to shareholder approval at Tower’s

annual shareholder meeting (ASM) in early 2025 and

fulfilment of other conditions. The return of capital is

expected to deliver meaningful earnings per share

accretion to Tower’s shareholders.

Leading customer experience

Central to Tower’s strategy is delivering a consistent,

easy-to-understand insurance experience for all

our customers.

This is facilitated by our core, cloud-based technology

platform and our ongoing investment in My Tower, our

sales and service platform. This enables us to provide

customers with a consistent, online insurance buying

and management experience while reducing our cost-

to-serve.

Our online journeys continue to resonate with customers,

boosting GWP growth, with 63% of this year's NZ sales

coming through our online channels.

5ANNUAL REPORT 2024Our strategySustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents2024 in review

Our partners enable us to reach more Kiwi and Pacific
customers. In FY24, Trade Me GWP increased by 16%,

comprising 37% of Partnerships’ GWP. Additionally, we

were proud to launch new partnerships with Kiwibank

and HealthCare Plus and expanded further in the

mortgage broker market.

We ended FY24 with a three-month average customer

net promoter score of +38, up from +28 in FY23. We

continue to invest in digitisation, data and process

excellence to further enhance our customer experience.

One example of this is ‘ways to save’. Throughout the

year, 29,000 customers used our ways to save feature in

My Tower, which offers useful tips and options to reduce

premiums. By providing these tools, we empower our

customers to manage their insurance more effectively

and reduce while also reducing the workload for our

customer care team.

We were particularly proud to be named Canstar's

Home & Contents Insurer of the Year for 2024. The award

acknowledged our customer service, commitment

to affordability and the overall value we deliver to

Kiwi households.

While we value this recognition, we are also committed

to fixing things when we don’t get them right. In FY24,

we made significant progress towards remediating

customers identified as being owed a premium refund

due to errors in applying our multipolicy discount. As

at 30 September 2024, we had identified refunds of

around $12m (including GST and interest) owed to

66,000 customers and had repaid over $11m. We are

also actively addressing premium overcharges resulting

from separate promotions and policy discounts and

other policy errors, ensuring all affected customers are

fairly compensated.

Fixing issues that have required customer remediations

is important to us. In FY24 we launched Foundations

First, a strategic programme focused on strengthening

our business fundamentals. Two of its key initiatives

involve improving data management across Tower and

investigating the root causes of incidents that lead to

remediations, enabling us to develop strategies to tackle

these underlying issues. Ultimately, Foundations First

aims to bolster business resilience, promote positive

customer outcomes and foster sustainable growth.

Tower also initiated a comprehensive programme to

align its conduct framework with the upcoming Conduct

of Financial Institutions (CoFI) regime, which comes into

force on 1 April 2025. This is a key priority for Tower and

supports our strategic commitment to delivering fair

outcomes for our customers.

Targeted growth through risk-based

pricing and disciplined underwriting

Tower’s adoption of risk-based pricing and underwriting

has given us a competitive advantage by enabling more

accurate risk selection and pricing. We believe it’s fairer

for customers to only pay for the risks that apply to their

property. We also believe in transparency, so we provide

customers with a detailed premium breakdown that

shows the impact of their risk ratings on their premiums

and offer comparison at renewal.

6ANNUAL REPORT 2024Our strategySustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents2024 in review

During the financial year we expanded our risk-based
pricing model by introducing automated underwriting

rules for landslide risks across NZ. This follows the

implementation of similar rules for sea surge risks

in FY23.

In the coming year, our customers will be able to see

their home’s risk ratings for landslide and sea surge

on their property – alongside those for earthquake

and flood hazard – and the impact those risks have on

their premiums.

We are particularly pleased to see new business house

policies increase by 18%, compared to FY23, as we focus

more on the home insurance market.

Enhanced claims management

Following record claims volumes in FY23 due to

catastrophe events, we improved processes and

implemented new technology to deliver faster and more

efficient claims management.

In FY24 we continued investing in our home and

motor claims journey, resulting in significantly reduced

claims processing times and improved end-to-end

claims management.

Since May 2024, two-thirds of customers who submitted

weather, accidental damage or escape of water claims

through My Tower had their claims automatically

accepted and or referred to an assessor or house

supplier, bypassing manual processing or review.

Delivering operational excellence

This year, we celebrated 150 years of operation in Fiji and

continued to streamline our wider Pacific operations.

As part of this effort, we completed the sale of our

Solomon Islands business and Vanuatu subsidiary

in FY24, following the divestment of our Papua New

Guinea subsidiary in FY23.

Additionally, we opened our new operational hub in

Suva, which now handles over half of our NZ customer

service calls, significantly improving call answer times.

With around 300 local employees in Fiji, this enhances

our ability to allocate resources flexibly across locations

and functions, bolstering business resilience.

Fostering a more sustainable future

Witnessing the impacts of climate change firsthand in

the communities we serve has driven us to implement

changes in our business operations, support customers

with innovative products, and fund scholarships to

deepen understanding of climate change.

In 2022, we launched Cyclone Response Cover, our first

parametric product designed for Pacific communities

and small businesses. After introducing this innovative

product in Samoa in FY24, it is now available in three

Pacific countries. In FY25 we plan to introduce a new

parametric rainfall product.

For the fourth consecutive year, we supported the

University of Waikato’s Bachelor of Climate Change

degree by providing scholarships for second and third-

year students.

As a Kiwi and Pacific insurer, we are acutely aware of the

climate risks faced by island nations and are particularly

pleased to award this year’s scholarships to students

focused on mitigating climate change impacts on Māori

and Pasifika communities.

Additionally, we piloted initiatives to reduce our Scope

three emissions. We are committed to reducing our

Scope 1, 2 and 3 emissions and have achieved a 20%

reduction in Scope 1 and 2 greenhouse gas emissions

compared to our FY20 baseline year.

More details can be found in our first Climate Statement,

released alongside this annual report. Our teams

also dedicated 2,300 hours to volunteering in our

communities, a pleasing and very worthwhile effort.

Investing in our people and culture

This year’s results are a testament to the entire Tower

team. We remain committed to supporting our people,

enabling us to attract, develop, and retain the best talent.

In FY24 we continued to enhance the Tower experience

for our people. We now have seven well-established

employee representation groups (ERGs), with one in

three staff actively participating.

A key metric we focus on are our employee engagement

scores. Our latest staff survey in September 2024

showed an employee engagement score of 8.1, up from

7.8 in September 2023.

Encouragingly, our focus on company culture has

resulted in a diversity and inclusion score of 8.9, placing

us in the top 10% of the finance sector globally.

7ANNUAL REPORT 2024Our strategySustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents2024 in review

Michael Stiassny
Chair

The year ahead

Insurance plays a vital role in supporting economic and

community resilience. This is increasingly important in

a world where the impacts of climate change are not a

matter of if, but when and how much?

We aim to maintain affordable premiums, and with

Tower’s risk-based pricing strategy, we anticipate that

premium increases will continue to level off in certain

areas, while some premiums reduce. Together with the

digitisation and operational performance efficiency gains

achieved this year, we are well-positioned for FY25.

In November, Tower shared with the market that Blair

will step down as CEO, following the 2025 annual

shareholder meeting in February.

On behalf of the board, I would like to thank Blair and

acknowledge his leadership which has driven significant

progress in Tower’s journey to become the leading direct

personal lines and SME insurer in New Zealand and our

chosen Pacific markets.

Tower is committed to continuing to serve our customers

and communities. With a strong business platform

and a robust strategy, we are well positioned to deliver

sustainable premium growth and attractive long-term

shareholder returns.

Blair Turnbull

CEO

"In my view, Tower is a really unique

business, and I am very proud to

have played a part in its long history.

"Together, we have significantly transformed Tower’s

customer experience by leveraging digitisation and

realised marked operational efficiencies through our

cloud-based platform. Our business is now sharply

focused and streamlined in our chosen markets, and

we continue to innovate with risk-based pricing and

new offerings like parametric insurance.

"I believe the platform is solid and as such it’s an

ideal juncture to pass the baton.

"A sincere thank you to our people for always

showing up for our customers over the past four

and half years, particularly the executive team, who

have truly lived up to our core values; we do what’s

right, our people come first, our customers are our

compass and progress boldly.

"Put simply, it has been a privilege and a pleasure."

- Blair Turnbull

ANNUAL REPORT 20248Our strategySustainabilityConsolidated financial statements2024 in reviewCorporate governanceGRI content index Contents

Delivering
on our

strategy

9ANNUAL REPORT 2024 ContentsGRI content index Corporate governanceConsolidated financial statementsSustainability2024 in reviewOur strategy

Our purpose
To inspire, shape and protect the future for

the good of our customers and communities.

Our vision

Ta tātou kaupapa

To deliver beautifully simple and rewarding

experiences that our people and our

customers rave about.

Our strategy

To be the best direct personal lines and

SME insurer in our selected markets differentiated

through digital and data, fair and transparent,

and with customer care in everything we do.

Our values

We do

what’s right

Our people

come first

Our customers

are our compass

Progress

boldly

Our strategic pillars

LEADING

CUSTOMER

EXPERIENCE

Succinct, easy

customer

experiences

across the

lifecycle

OPERATIONALLY

EFFICIENT

Digitise and

automate core

processes and

leverage

geographical

footprint

EFFECTIVE &

DISTINCTIVE

CULTURE

An inclusive,

diverse and risk

aware culture.

Empower our

people to

achieve

great things

RESILIENT

Manage volatility

and deliver

sustainable

outcomes for all

stakeholders

10ANNUAL REPORT 2024 ContentsGRI content index Corporate governanceConsolidated financial statementsSustainability2024 in reviewOur strategy

Leading
customer

experience

11ANNUAL REPORT 20242024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index ContentsOur strategy

My Tower
Tower customers benefit from an

easy-to-understand insurance buying

and management process, that also

reduces our service costs.

Launched in 2019, our self-service digital platform,

My Tower, is an online sales and service portal.

Features include the ability to lodge a claim,

check claims progress, and automated referrals to

some suppliers.

In line with our focus on transparency, customers

can view their premium breakdown and a premium

comparison at renewal, as well as their property’s flood

and earthquake risk ratings.

Customers increasingly seek an online experience, but

also value the opportunity to call someone if they need

help or support. In FY24, our average call wait time was

2 minutes and 10 seconds, contributing to a drop in our

sales and service abandonment rate to 8% compared

to 13% in FY23.

Customer NPS for

My Tower, up from

+28 in FY23

+

35

Tower’s Fiji digital

retail branch.

FY24 marked the first full financial year during which

My Tower and our online quote-to-buy journey were

available across all Tower’s Pacific markets.

This is a positive step forward in increasing insurance

accessibility, penetration and awareness in the Pacific.

In the coming year we’ll continue to grow our presence

in-region.

1

Adjusted to exclude divested portfolios which includes the New Zealand

commercial rural portfolio.

NZ My Tower users,

up 5% in FY24

164,000

Tower direct GWP,

up 16%

1

from FY23

$

446

m

12ANNUAL REPORT 20242024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index ContentsOur strategy

Ways to save
To help our customers manage

their insurance and affordability,

we introduced ways to save.

Ways to save is a My Tower feature for our New

Zealand customers that offers useful tips and options

to reduce premiums. For example, customers can

explore how their premiums would change by

increasing or decreasing their excess.

Like our wider My Tower offering, ways to save

empowers customers to manage their insurance,

without the need to call our contact centre team,

helping to create a more efficient experience for our

customers and teams.

In FY24, 16% of customers who interacted with ways

to save made changes to their cover that resulted in

lower premiums.

Customers accessed

ways to save on average

per month in FY24

2,400

Decrease in annual

premium per customer

via ways to save in FY24

1

$

122

1

Average amount saved by customers who decreased their

premiums via ways to save.

13ANNUAL REPORT 20242024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index ContentsOur strategy

Products to suit our customers and communities
House

Contents

Motor

CaravanLandlord

Boat

Pet

Travel

Business

MotorbikeMotorhome

Parametric cover

(for Cyclone and Rainfall)

• Canstar Outstanding Value Trans-Tasman

Travel Insurance – 2023

• Canstar Outstanding Value South Pacific Cruise

Travel Insurance – 2023

14ANNUAL REPORT 2024 ContentsGRI content index Corporate governanceConsolidated financial statementsSustainability2024 in reviewOur strategy

Market-leading risk-based pricing
In FY24, we expanded our risk-based pricing model by

introducing automated underwriting rules for landslide

risks across NZ. This followed the implementation of

automated underwriting rules for sea surge risks across

NZ in FY23.

Through our award-winning and market-leading

approach to risk-based pricing, customers can already

see their home’s risk ratings for floods and earthquakes

1

.

We believe risk-based pricing is a fairer way to price

insurance as customers only pay for the risks that apply

to their properties.

In the coming year, we will include pricing and

customer-facing landslide and sea surge risk ratings for

our customers’ homes.

1

Risk ratings may not be immediately available for customers if the address

is not in our address database (for example, the property is a new build).

2

Independent research conducted by the Octopus Group in April 2023, with

a sample size of 1,000 representative of NZ’s population.

Kiwi think risk-based

pricing is a fair way to

price insurance

2

87

%

15ANNUAL REPORT 20242024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index ContentsOur strategy

Tower’s work to increase insurance
awareness, accessibility and uptake

in the Pacific through parametric

insurance, continued in FY24.

Parametric insurance offers a lower-cost alternative that

provides a level of cover for Pacific communities that

may not benefit from traditional insurance.

2023

Nov - Announced partnership with global Insurtech

CelsiusPro to upgrade our Cyclone Response Cover

IT platform.

Oct - In partnership with the the United Nations Capital

Development Fund (UNCDF), Tower featured on the

world stage via a panel talking about parametric

insurance in Ghana, at the International Conference for

Inclusive Insurance 2023.

Dec - Launched parametric Cyclone Response Cover in

Samoa in collaboration with the United Nations Capital

Development Fund (UNCDF), under its flagship Pacific

Insurance and Climate Adaptation Programme.

2024

Jul - Tower Parametric Product Manager Felichya Khan

represented Tower as part of a UNCDF delegation that

attended the 20th Asia NAT CAT and Climate Change

Summit 2024, in the Philippines.

Aug - Reserve Bank of Fiji announced a collaboration

with the InsuResilience Solutions Fund, and the local

insurance sector, including Tower, to have 5,000 new

parametric policies in place across Fiji by the end

of 2025.

Sep - Launched new parametric platform for customers

in Fiji and Tonga, with CelsiusPro, aiming to make it

simpler for Tower customers to access and manage their

parametric cover.

Oct - Tower Tonga Country Manager Manase Tafea,

presented on parametric insurance at the 53rd Pacific

Islands Forum Leaders Meeting, in Tonga.

Looking ahead

In the coming financial year, we plan to launch Cyclone

Response Cover in the Cook Islands and add a new

parametric rainfall product to our suite, for our Fiji market.

Tower is also looking into opportunities to launch a

parametric insurance product in NZ.

We look forward to continuing to partner with our

communities in the other Pacific territories we operate in,

all with the goal of increasing the uptake of insurance in

the Pacific.

Increasing insurance accessibility

with parametric insurance

Promoting parametric at the Commonwealth

Heads of Government Meeting 2024 (CHOGM),

Business Forum

As an opportunity to expand the reach of our parametric

offering, in October 2024, Tower was proud to partner

with the Commonwealth Enterprise and Investment

Committee, to attend CHOGM 2024 in Apia, Samoa.

Tower CEO Blair Turnbull featured on a tech and

innovation panel, Tower Chief Underwriting Officer

Ronald Mudaliar and Head of Pacific Retail Distribution

Joanne Rasmussen, took part in roundtable discussions

on unlocking green investment and risk mitigation, and

leadership in island nations.

Tower delegation at CHOGM 2024.

16ANNUAL REPORT 20242024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index ContentsOur strategy

Our product range is designed
for the lifestyles of Kiwi and

Pacific customers.

In recent years, we’ve added new products such

as parametric, pet, travel, boat and contract works -

renovation cover to our product suite.

At the same time, we’ve continued to phase out

products that are not compatible with our digital

customer experience.

That’s why, from February 2024 we stopped offering

insurance for commercial farms. However, we

continue to offer cover for lifestyle blocks under

our strategy.

In FY24, our customer net promoter score (NPS)

increased. The majority of NZ direct sales continue

to come through our online channels.

1

Three-month average as at 30 September 2024.

Award winning

Tower experience

Members of Tower's product and marketing teams and Canstar

representatives, with some of FY24's Canstar awards.

NZ sales online

vs. 70% in FY23

63

%

Customer NPS

1

, up

from +28 in FY23

+

38

Increase in new

business house

policies in FY24

18

%

17ANNUAL REPORT 20242024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index ContentsOur strategy

Our corporate, retail and advisory
referral partnerships help us to scale

efficiently, and deliver products

in better ways for Kiwi and Pacific

customers.

Our advisor referral model accounted for 42% of

partnerships' GWP in FY24, with a 19% increase in risks

sold through our advisor network.

TradeMe GWP grew 16% in FY24, accounting for 37%

of partnerships’ GWP.

Proud to partner

Building on the success of our partnership model,

in FY24, we welcomed new partners Kiwibank and

HealthCarePlus.

Tower also has referral agreements in place with New

Zealand Financial Services Group, Kiwi Adviser Network,

New Zealand Home Loans, Ray White Concierge, the

New Zealand Defence Force and TSB.

These and other relationships have contributed to 24%

increase in GWP from partnerships against FY23.

This year, we’re proud to mark three years of supporting

Coastguard New Zealand to help bring Kiwi home safe.

Growth in advisor

network to 3,300

vs. FY23

32

%

Partnerships' GWP,

up 24% from FY23

$

102

m

Increase in new

risks sold through

our advisor

network vs. FY23

19

%

18ANNUAL REPORT 2024 ContentsGRI content index Corporate governanceConsolidated financial statementsSustainability2024 in reviewOur strategy

Kiwibank
We welcomed our first Kiwibank customers to Tower in

early September. This partnership presents a strategic

opportunity for Tower, aligning with our focus on growing

our home insurance portfolio.

Our initial five-year referral agreement with Kiwibank

allows their customers to insure their assets directly with

Tower under Tower branded policies.

HealthCarePlus

HealthCarePlus is jointly owned by the five education

unions and the Public Service Association, supporting

more than 180,000 members across the teaching,

tertiary and public service sectors.

Our partnership with HealthCarePlus provides its

members with access to Tower’s products via the

HealthCarePlus website and member platform.

Welcoming the Kiwibank team to Tower.

• Supreme Award for Retention –

First Place

• Most Outstanding

Outbound Representative –

Tower Partnership Sales

Consultant Molly Stokes

• Outbound Business to

Consumer Gold Award –

Second Place

• Outbound Business to

Business Silver Award –

Third Place

19ANNUAL REPORT 20242024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index ContentsOur strategy

Using data driven decision-making to
manage premiums and our business

Our commitment to careful risk

selection and robust underwriting

supports a strong core business,

enabling us to offer tailored pricing

to customers with lower risks.

Key to our resilience is our ability to monitor

and adjust our pricing and underwriting

to remain competitive and responsive to

macroeconomic conditions.

As part of this, in FY23 and FY24, we tightened our

risk appetite for vehicles with high theft-risks. This

contributed to a reduction in customer numbers from

311,000

1

in FY23 to 305,000 in FY24, as Tower reduced

high theft-risk motor policies by over 5,000 throughout

the year.

As claims cost performance improved in certain

customer segments, we were able to reduce

some premiums.

For our customers, this meant that as inflation began to

settle later in the year, we moved quickly to moderate

premium increases, particularly for low-risk assets.

This included a review of motor pricing performance

for the 100 most common makes and models

(including all years and specifications), representing

70% of Tower’s motor portfolio. The review led to a

reduction in premiums of varying levels for 71% of the

models reviewed.

A range of factors have influenced premium increases

over recent years including; inflation, crime rates,

weather events, reinsurance costs, and supply

chain pressures.

While it costs more now to cover our customers and

their assets, we continue to manage the impact of some

increases in claims costs through business efficiencies,

risk-based pricing, our claims transformation project and

underwriting automation.

1

FY23 customer numbers have been adjusted to exclude sold and held for sale

portfolios which include Papua New Guinea and Solomon Islands businesses,

Vanuatu subsidiary, and exit of NZ rural commercial portfolio.

Pricing and underwriting

adjustments made

across FY24

68

20ANNUAL REPORT 20242024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index ContentsOur strategy

Putting things right for
our customers

An important part of delivering a

positive customer experience is fixing

things when we don’t get them right.

We continue to focus on putting

things right for customers who had

not received the discounts or benefits

they were entitled to.

We’re pleased to have made significant progress

towards remediating customers identified as being

owed a premium refund, due to errors in applying our

multi-policy discount.

As of 30 September 2024, we have identified refunds

of around $12 million (including GST and interest)

owed to 66,000 customers and have repaid over $11m.

Other remediations we have in progress relate to

premium overcharges in connection with the

application of promotions and policy discounts,

and other policy errors. For all current customer

remediations, we’ve provisioned $9.2m as at the

end of FY24.

Remediation activities are carried out by our

Foundations First taskforce. You can read more about

Foundations First on page 32 of this report.

This year, the FMA issued proceedings against Tower in

respect of overcharges related to the application of its

multi-policy discount. We continue to engage with the

FMA in relation to our multi-policy discount remediation.

Tower's customer care centre.

21ANNUAL REPORT 2024 ContentsGRI content index Corporate governanceConsolidated financial statementsSustainability2024 in reviewOur strategy

Operationally
efficient

ANNUAL REPORT 2024222024 in review ContentsGRI content index Corporate governanceConsolidated financial statementsSustainabilityOur strategy

In line with our strategy, throughout
FY24 Tower continued to digitise and

automate core processes, and leverage

our geographical footprint to become

more operationally efficient and effective.

Efficient and effective

1

COR impacted by higher large event costs in FY23 (Auckland floods and Cyclone Gabrielle), and no large events in FY24.

2

Digital service tasks are any policy adjustments made through the My Tower portal divided by the total number of policy adjustments made. In prior years, multiple tasks

completed on the same call were reported as one assisted transaction, which are now reported individually. Digital claims tasks refer to claim lodgement only.

Decrease in NZ sales and

service abandonment

rate, now at 8%

5

%

Minutes and 10

seconds, our average

phone wait time in

FY24 vs. 3 minutes and

33 seconds in FY23

2

Combined operating

ratio (COR) vs. 100.4%

in FY23

1

79

%

Sales and service calls

answered in FY24,

down from 380,000

in FY23

329,000

Service tasks and

transactions completed

digitally in NZ, in line

with FY23

2

45

%

Hours, our average

email response time

in FY24 vs. 45 hours

in FY23

35

Management expense

ratio (MER) down from

32% in FY23

31.4

%

The number of times

customers made manual

payments in My Tower,

our top digital customer

transaction in FY24

142,000

23ANNUAL REPORT 20242024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index ContentsOur strategy

Claims transformation
Our claims transformation

programme aims to harness

data and technology to deliver

straight through claims and

repair experiences.

The programme began in FY23, with

the ultimate goals of transforming and

improving our claims experience, increasing

transparency for customers and operating

more efficiently and effectively.

In FY24, we continued to deliver on this

ambition, automating key manual processes

in our motor and home claims’ journeys.

Continuing to automate the claims journey

In FY24, we continued to automate the claims journey

for house customers in My Tower, using technology to

deliver faster and more efficient claims management.

In March, we updated customers’ claims information

in My Tower to include contact details for their claims

manager. Claims managers are now automatically

assigned at lodgment for house, motor and contents.

This has helped lessen calls to our frontline teams and

made things easier for our customers, with one clear

point of contact for the duration of their claim.

In May, we automated the acceptance of house claims

for our most common types of house claims: weather,

accidental damage and escape of water claims (for

example, water damage from a burst pipe). At the same

time, we automated referrals to assessors or repairers

for these types of claims. This means that claims of this

type, that meet set criteria, are automatically accepted

and or referred to an assessor or supplier for the next

step in the settlement journey, without the need for

manual review.

Since then, two thirds of customers who lodged a

weather, accidental damage or escape of water claim in

My Tower, have had their claim automatically accepted

and or referred to an assessor or house supplier, without

the need for manual processing or review.

While we experienced no large weather events in FY24,

these changes will improve our efficiency and the

customer experience during future events.

Members of Tower's claims and assessing

team at one of our Repair Partner Network's

repair shops in Auckland.

House claims lodged via

My Tower automatically

accepted and or

referred to an assessor

or supplier

1

65

%

Customers accessed

their claims manager’s

name and contact

details via My Tower

2

25,000

1

Applies to claims for weather, accidental damage or escape of water (collectively,

our most common claims), since new system launched in May 2024.

2

Since feature launched in March 2024.

24ANNUAL REPORT 20242024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index ContentsOur strategy

Streamlining the motor repair journey
In April, we announced that we had partnered with

Hello Claims to integrate their assessing and repair

management platform into our online systems, starting

in June.

Previously, it took up to four days on average to accept

a claim, allocate an assessor, process a quote and

authorise work for panel repairs.

Since integrating the new platform into our internal

referral process, when customers lodge a claim in

My Tower and use our Repair Partner Network, our repair

partners automatically receive a referral as soon as the

claim is accepted.

They are then able to make contact and organise

assessments or repairs, without Tower needing to

manually refer customers or sign off repair quotes.

We have been working closely with repairers, as we

embed this new assessing and repair platform into our

systems. Full integration will be completed in early 2025

and will enable customers to view their motor claims

status at every point of the claims journey via My Tower.

Members of Tower's claims and

assessing team with a member

of our Repair Partner Network.

Claims now lodged

online vs. 59% in FY23

64

%

BAU claims ratio

vs. 55% in FY23

48

%

25ANNUAL REPORT 20242024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index ContentsOur strategy

Delivering operational efficiencies
This year, Tower was proud to mark

150 years of operation in Fiji and open

our new Suva hub.

Our Suva hub is a modern work environment that

presents a strategic advantage for Tower. A range of

business units from finance and human resources to

marketing and claims are represented in Fiji.

Our core platform unifies our operations, allowing us

to function as one Tower across all markets we serve.

Over the year, this saw an increase in the volume of

sales and service tasks handled by our Fiji team, for our

New Zealand customers.

The ability to flex resources across locations and

departments to meet demand helps us deliver a

consistent experience for all our customers, while

increasing business resilience.

“We are opening doors to opportunity,

growth and prosperity...Tower, over the

years, has shown a steadfast commitment

to enhancing the landscape of Fiji. I also

acknowledge Tower’s continuous efforts

to enhance efficiency, productivity, and

employee development.”

- The Hon. Professor Biman Prasad, Deputy Prime Minister

of Fiji, at the opening of Tower’s Suva hub, in February.

The Hon. Professor Biman Prasad, Deputy Prime Minister of Fiji.

Years in operation

150

Of Tower Fiji staff

are locals

100

%

Of staff have previous

experience in international

businesses

94

%

Of NZ sales and service

calls answered by Suva

hub vs. 16% in FY23

55

%

Team members across

all multiple business

functions

300

+

Of Tower Fiji’s leadership

team are women

80

%

26ANNUAL REPORT 2024 ContentsGRI content index Corporate governanceConsolidated financial statementsSustainability2024 in reviewOur strategy

Doing business in Fiji makes good
business sense

In June, the Rt. Hon. Christopher Luxon, Prime Minister

of New Zealand visited our Suva hub, as part of the

New Zealand government’s Pacific trade visit.

The visit was a chance for Tower to showcase

our people, the benefits of our Suva hub, and our

parametric cyclone product.

“To see an incredible business like we

saw this morning with Tower actually, that

is trailblazing a world class organisation

here in Suva.”

- The Rt. Hon. Christopher Luxon, Prime Minister

of New Zealand, The Fiji Times, June 7 2024.

The Rt. Hon. Christopher Luxon, Prime Minister of New Zealand at our Suva hub.

27ANNUAL REPORT 20242024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index ContentsOur strategy

In FY24 we completed the sales of our Solomon
Islands business and Vanuatu subsidiary.

This follows the sale of the Papua New Guinea subsidiary in FY23.

The establishment of our new Suva hub and these sales reinforce

the actions Tower has taken over the last three years to streamline

our Pacific operations, refine our risk appetite, and enhance our

digital and operational proposition in key Pacific markets.

Our remaining Pacific businesses in Fiji, Tonga, Samoa, American

Samoa and the Cook Islands have the infrastructure required to

successfully operate and upgrade My Tower.

These capabilities are crucial to our strategy to deliver a leading

customer experience for personal lines and small to medium

enterprises (SMEs) in the Pacific.

Team members at Tower’s Suva hub.

Streamlining and strengthening

our Pacific operations

Pacific markets;

Fiji, Tonga, Samoa,

American Samoa,

and the Cook Islands

5

Pacific GWP, a 2%

1


decrease from FY23

$

48

m

1

Adjusted to exclude divested portfolios which include the Solomon Islands

business and Vanuatu subsidiary.

28ANNUAL REPORT 20242024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index ContentsOur strategy

Resilient
29ANNUAL REPORT 20242024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index ContentsOur strategy

Here for our customers
at claims time

We’re committed to helping

customers recover from a loss

at claims time – it’s what we are

here for.

While we experienced no large weather or natural

hazard events in New Zealand or across the Pacific

in FY24, we still helped our customers protect

the things that matter to them, reporting 67,500

everyday claims*.

* While there were no large weather

events in FY24, our everyday claims

figure still includes claims for weather

related damage.

12,200

Kiwi house claims for

garages, mostly due to

damage by a vehicle

or trailer

1,100

Travel insurance policies

for trips to Australia, our

most popular destination

4,000

Of travel claims were for

baggage and personal

effects in FY24

14

%

Boat claims were for

mishaps while fishing

on jet skis

1.5

%

Boat claims happened on

the way to or after leaving

the boat ramp

8.5

%

New couches supplied

to living rooms

throughout NZ

219

Claims for new glasses,

mostly due to sitting

on them

2,200

NZ motor claims for

damage that occurred

while stopped or parked

30ANNUAL REPORT 2024 ContentsGRI content index Corporate governanceConsolidated financial statementsSustainability2024 in reviewOur strategy

Claims for
Pacific homes

98

Claims for

Kiwi homes

13,300

Smashed window claims

for Kiwi homes

1,700

Pacific motor claims

1,600

31ANNUAL REPORT 20242024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index ContentsOur strategy

Strengthening the
foundations of our

business

We launched Foundations First, in

April 2024, a strategically important

programme for our business.

Key projects under Foundations First include:

• Carrying out all customer remediations

• Investigating root causes of various incidents with

a view to developing strategies to address those

root causes

• Enhancing delivery and project execution

• Improving end-to-end customer data management

at Tower.

The Foundations First programme will ultimately

drive outcomes that will help increase business

resilience to support good customer experiences

and sustainable growth in a competitive market.

Our Foundations First programme is

complemented by Tower's process excellence

initiative, which focuses on end-to-end process

simplification and risk reduction opportunities.

Tower's customer care centre.

32ANNUAL REPORT 20242024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index ContentsOur strategy

Tower’s reinsurance arrangements limit
Tower’s exposure to the impacts of large

events and maintain financial flexibility

to support growth, while underpinning

strong solvency.

We renewed our reinsurance programme for FY25, with

comprehensive reinsurance cover at competitive rates for

our home, motor, boat and commercial portfolios across

New Zealand and our Pacific markets.

To support growth and align with our prudent risk appetite,

Tower’s FY25 reinsurance programme includes:

• Increased catastrophe upper limit of $800m for the first

two events, up from $750m in FY24

• Increased cover for a third catastrophe event up to

$85m, up from $75m in FY24

• Reinsurance excess of $18.75m for the first two

events, up from $16.9m in FY24, due to expiring

multi-year arrangements

• $20m excess for a third event, unchanged from FY24.

Tower’s focus on risk-based pricing combined with our

dynamic rating ability helped us secure favourable terms

for our FY25 reinsurance. We’ve further strengthened

relationships with global reinsurers, with several agreeing to

new multi-year arrangements, providing greater long-term

certainty of reinsurance costs and catastrophe excesses.

Securing a programme with stable excesses and pricing

helps us to maintain competitive pricing for customers.

Robust reinsurance to support

growth and strong solvency

Cover in place for first

two catastrophe losses

in FY25

$

800

m

Cover in place for a

third catastrophe event

in FY25

$

85

m

33ANNUAL REPORT 20242024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index ContentsOur strategy

Effective &
distinctive

culture

ANNUAL REPORT 2024342024 in review ContentsGRI content index Corporate governanceConsolidated financial statementsSustainabilityOur strategy

Our people
come first

We’re committed to making Tower

an even better place to work,

enabling us to attract and retain

talented individuals and empower

our teams to do great things.

Employee engagement score*

8.1

Employees are non-European,

based on the 92% of staff

who chose to disclose

their ethnicity

68

%

Twice a year we ‘check in’ via employee engagement

surveys, which have shown increasing levels of

engagement and connection to Tower.

We know that diversity is essential for a business to

thrive, innovate and succeed in a competitive market so

we’re proud to share that all our employee diversity and

inclusion (D&I) scores, have continued to increase.

*

As at 13 September 2024, based on Tower’s latest staff engagement survey

In our latest survey* our overall D&I score was 8.9, up

from 8.6 in FY23, placing Tower in the top 10% of the

global finance sector. Inclusiveness, feeling valued and

belonging all received scores of 8.4, marking an increase

of 0.1-0.4 compared to FY23.

Tower head office celebrating being announced as a finalist in the 2024 ANZIIF

New Zealand Insurance Industry Awards’ Excellence in Workplace DE&I category.

35ANNUAL REPORT 20242024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index ContentsOur strategy

Quarterly staff awards for living our values.
Committed

to our people

36ANNUAL REPORT 20242024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index ContentsOur strategy

We know that by taking care of our
people, we enable them to show

up in the best way possible for

our customers.

In FY24 we continued to enhance the Tower experience

for our people. We offer a range of benefits and flexible

working options, including the ability to use discretionary

leave and purchase up to eight additional days beyond

the initial four-week entitlement, to help employees

proactively manage their personal and family wellness. In

the year we also ran 18 financial and emotional wellbeing

sessions for our teams.

All of these actions contributed to our high employee

health and wellbeing score, at 8.5*, in the top 25% of the

global finance sector.

Looking after

our people

*

As at 13 September 2024, based on Tower’s latest staff engagement survey

Fiji Human Resources

Institute Awards,


Silver Award for HR

Practicing Leader 2024

– Monish Chand

Weeks full pay parental

leave for primary carers

16

Gender affirmation

leave

Paid day off on or

near your birthday

1

Weeks full pay for partners

(all parental leave also

applied to adoptions)

4

Days wellbeing leave

10

Day of volunteer leave

per year

1

The Tower Tonga team.

The Tower American Samoa team.

37ANNUAL REPORT 20242024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index ContentsOur strategy

Tower became one of the first 50
businesses to join New Zealand’s Mind

the Gap register in 2022, to publicly

report on pay gap data.

Our FY24 pay equity data is below.

Leadership gender pay gap

Comparing our senior leadership population and

the average pay gap between men and women, our

New Zealand leadership pay gap is -4.6% (women are

paid 4.6% more than men, this is because our lower

level leadership roles have a higher proportion of

men, which impacts the overall weighted average).

-4.6

%

Leadership gender pay equity gap

When we compare like-for-like roles for our

leadership population at Tower in New Zealand, our

leadership pay equity gap is [0.1%] (men are paid 0.1%

more than women for the same role).

0.1

%

Gender pay equity gap

When we compare like-for-like roles for women and

men, our pay equity gap is 0.9% for our workforce in

New Zealand, and 1.9% for our workforce in Fiji (men

are paid 0.9% more than women for the same role in

New Zealand and 1.9% more in Fiji).

0.9

%

Gender pay gap

When we take the total salary for all women and

divide that by the number of women, and the total

salary of all men and divide that by the number

of men, we have a gap of 20.2% for our workforce

in New Zealand, and a gap of 9.5% for our work

workforce in Fiji. For the most part, this is because we

have a larger proportion of of women in frontline roles.

20.2

%

Staff at Tower's head office.

ANNUAL REPORT 2024382024 in reviewSustainabilityOur strategy ContentsGRI content index Corporate governanceConsolidated financial statements

For Tower, by
Tower people

Our employee representation

groups (ERGs) champion the unique

backgrounds and perspectives of

our teams.

They work to enhance, celebrate and continuously

improve diversity, equity and inclusion in our

organisation, and regularly contribute to our fortnightly

all staff meetings.

In FY24 our ERGs led events, among others, for Matariki,

Diwali, Lunar New Year, Te Wiki o te Reo Māori, other

language weeks for our Pacific operations, and raised

over $10,800 for Sweat with Pride 2024 (one of the top

10 highest contributions by a workplace in New Zealand).

1. Rainbow Network (LGBTIQ+).

2. Mana Wahine Toa (women’s

network).

3. Ahi Kā (Māori roopu).

4. SPARK (supporting physical and

neurodiversity, advocacy, respect

and knowledge) Network.

5. We@Tower Group

(celebrates cultural diversity).

6. Mera Hanua (celebrates

cultural diversity in Fiji).

7. Tower Bula Fiji (focused

on staff wellbeing).

of Tower staff are

members of an ERG

30

%

123

4

7

56

ERGs at Tower

7

39ANNUAL REPORT 20242024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index ContentsOur strategy

Strengthening
our culture of risk

awareness

Risk management is central to Tower’s

strategic and operational activities

and is underpinned by Tower’s

enterprise-wide Risk Management

Framework (RMF).

The RMF sets out guiding principles to enable Tower

to identify, assess, monitor and mitigate risk to support

the achievement of our strategic objectives.

Part of this strategy in FY24, was to enhance Tower’s

culture of risk awareness. During the year, this included

strengthened risk assessment and incident management

practices and a dedicated focus on process excellence.

Tower’s work on conduct through the Conduct of

Financial Institutions (CoFI) lens will further advance

fair customer outcomes. Through Foundations First,

root cause analysis was also undertaken to understand

and address key issues and causes of incidents across

people, processes, systems, and culture.

Pleasingly, in FY24 we saw an uplift in all employee

scores for risk culture and awareness*.

Risk Culture employee

score, up 0.2 in FY24*

8.3

Employee score for

‘managing risks across

our business is a part of

Tower’s culture’, up 0.2

in FY24*

8.6

* Employee engagement surveys are run twice yearly, in March and

September, scores are compared from our March 2024 survey and

our latest survey, completed September 13 2024.

Staff at Tower's head office.

40ANNUAL REPORT 20242024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index ContentsOur strategy

Environmental,
social and

governance

performance

41ANNUAL REPORT 2024 ContentsGRI content index Corporate governanceConsolidated financial statementsOur strategy2024 in reviewSustainability

Fostering a more
sustainable

business for

our customers,

communities

and planet

Our sustainability strategy

guides how we manage relevant

environmental, social and

governance issues and provides a

framework for managing our most

material impacts. It was developed

to enable us to deliver on our

company purpose:

To inspire, shape and protect the future

for our customers and communities.

42ANNUAL REPORT 2024

A diverse and inclusive workplace that builds

people’s physical and emotional wellbeing.

DIVERSE AND

INCLUSIVE TO THE CORE

Moving all aspects of our business towards

zero-carbon and zero waste, and ensuring we

have a positive impact on Aotearoa and the

Pacific, now and in the future.

THINKING AHEAD

FOR OUR PLANET

Championing informed dialogue about

climate change and pursuing win-win

outcomes that tackle sustainability issues.

HELPING COMMUNITIES NAVIGATE

CLIMATE CHANGE

Providing no-surprises, easy to understand

insurance that is accessible and affordable.

PEOPLE’S GO-TO TRUSTED

INSURANCE PARTNER

Our strategy2024 in reviewConsolidated financial statementsCorporate governanceGRI content index ContentsSustainability

ESG Governance
Tower’s Board promotes the development of

Tower’s ESG practices, monitoring performance

via periodic management updates.

ESG governance is formalised through an

executive-level steering committee, chaired

by our CEO, which oversees progress on our

initiatives and monitors environmental and social

risks. Our ESG performance is coordinated by the

Head of Corporate Affairs and Sustainability and

supported by our Sustainability Manager.

In FY24 Tower delivered its first Climate

Related Financial Disclosures (CRD). This work

included the development of a new governance

framework which covers ESG and climate change

issues. You can find detailed information about

our governance of climate change and ESG

issues in our 2024 Climate Statement, in the

sustainability section of our website.

43ANNUAL REPORT 2024 ContentsGRI content index Corporate governanceConsolidated financial statementsOur strategy2024 in reviewSustainability

We hosted four virtual all-staff lunch-and-learn sessions
for Plastic Free July, focusing on the uses and types of

plastics, as well as strategies to eliminate single-use plastics

from our home and work environments. These sessions aimed

to encourage our staff to make more sustainable choices.

4

Executive and Senior Leadership team members completed

training on climate disclosures and Tower’s Climate-Related

Disclosure obligations.

18

Staff completed Climate Fresk training. Delivered to more

than 1.7m people globally, Climate Fresk teaches the basics

of climate science in a fun and interactive workshop that

explores the causes and effects of climate change and

empowers people to take high impact actions. During the

year, Tower also hosted two community Fresk workshops,

at our head office.

33

Staff attended Sustainability Foundations Training.

The sessions provided participants with a clear

understanding of key sustainability concepts.

40

This year we focused on upskilling our people on

sustainability issues to further embed a culture of

sustainability across our business activities.

During the year, senior leaders and other team members took part in training

focused on the fundamentals of sustainability, climate change and relevant

legislative and regulatory requirements.

Bringing our people on the

sustainability journey

Staff at Tower's head office.

44ANNUAL REPORT 2024Our strategy2024 in reviewConsolidated financial statementsCorporate governanceGRI content index ContentsSustainability

We're proud to support the next
generation of climate leaders.

Tower has supported students studying the University of

Waikato’s (UoW) world-first Bachelor of Climate Change

degree since its inception in 2021, offering three $5,000

scholarships annually to assist students in their studies.

In FY24 we were pleased to announce Maia Waudby

and Hannah Dagger as the 2024 Tower Climate Change

Scholarship recipients. Both Maia and Hannah are aiming

to use their studies to mitigate the adverse effects of

climate change on Māori and Pacific communities.

As a Kiwi and Pacific insurer, we’re acutely aware of

the climate risks faced by island communities and are

inspired by Maia and Hannah’s passion for helping our

communities navigate the impacts of climate change.

In the year, Maia and other third-year UoW students

worked on a project for Tower, to identify initiatives

to reduce Scope 3 insured emissions related to

customer assets.

During a briefing at our Auckland office, students

learned about insurance fundamentals, Tower’s current

methodology for calculating insured emissions, and

reviewed relevant international case studies.

“The scholarship is definitely a big help.

It’s nice to know that there’s a big insurance

company out there in Tower, that supports

what you do.”

– Maia Waudby,

Tower Climate Change Scholarship recipient.

Tower Climate

Change Scholarship

In FY25, we will evaluate the students’ proposals

to identify the most impactful opportunities for

decarbonisation, while considering the needs of

our communities, customers, other stakeholders

and business.

UoW student briefing for emissions reduction project.

45ANNUAL REPORT 2024Our strategy2024 in reviewConsolidated financial statementsCorporate governanceGRI content index ContentsSustainability

“This scholarship serves as a catalyst
for personal growth, equipping me with

essential skills while fostering connections

that will enhance my capacity as a future

leader in my home country.”

- Saula Baleinubu,

Tower Vunilagi Scholarship recipient.

During celebrations to mark 150 years

in operation in Fiji, we launched the

Tower Vunilagi Scholarship.

Launched in June, each year the Tower Vunilagi

Scholarship will be awarded to students who demostrate

potential to be future Tower leaders, helping us build

an even better business and create a more equitable,

resilient and sustainable future for all Fijians.

Reflecting the purpose of the scholarship, the word

‘vunilagi’ means ‘new horizons’.

The scholarship covers a full year of tuition fees for three

students in their final year of bachelor’s degree study at

The University of the South Pacific (USP).

Recipients will also complete paid internships with Tower.

This year’s successful applicants; Shaunil Chand

(Bachelor of Commerce, Accounting and Finance),

Shayal S Gosai (Bachelor of Commerce, Accounting and

Finance) and Saula Baleinubu (Bachelor of Arts in Social

Work and Sociology), will begin their internships with

Tower Fiji in the first half of FY25.

Tower Vunilagi

Scholarship

Tower leadership team members with the 2024

Tower Vunilagi Scholarship recipients.

46ANNUAL REPORT 2024Our strategy2024 in reviewConsolidated financial statementsCorporate governanceGRI content index ContentsSustainability

At Tower, permanent, full-time
employees receive one annual

volunteer leave day to support a

cause they are passionate about.

Teams can decide on projects together, or individual

staff members choose a cause close to their hearts

to support.

We relaunched our volunteer leave programme in Q4 of

FY23, with a target of 1,000 volunteer hours spent in our

communities for FY24.

In line with our purpose, we’re proud to report that our

teams recorded 2,300 hours of volunteer leave in FY24,

up from 390 hours in FY23.

We look forward to building on our volunteer efforts in

FY25 and have set a target of 2,500 hours.

“We’ve been receiving food from Fair

Food since our programme began, and we

remain so incredibly grateful. Fair Food is

part of helping our women succeed.”

– Helen,

Fair Food Young Mums Programme.

2,300 hours of

volunteering by our

people

Mural painting at the National Council

for Persons with Disabilities' school, Fiji.

Volunteering at Papatoetoe

Central School, NZ.

Fair Food, New Zealand.Beach cleanup, American Samoa.

47ANNUAL REPORT 2024Our strategy2024 in reviewConsolidated financial statementsCorporate governanceGRI content index ContentsSustainability

FY24 is our first year of mandatory
disclosure, under the Climate-Related

Disclosure regime.

Tower has tracked Scope 1, 2 and selected Scope 3

emissions for our operations across New Zealand and

the Pacific since 2020.

In FY24 we reduced our Scope 1 and 2 emissions by 20%

from our 2020 baseline and by 9% compared to FY23.

Our full greenhouse gas emissions report is provided in

our Climate Statement 2024, which is in the sustainability

section of our website. The Statement contains our

Scope 1, Scope 2 and operational Scope 3 emissions

data, as well as information about our work to identify

and assess our climate related risks, opportunities and

business impacts.

In FY25, we will also assess material Scope 3 emissions

related to the assets we insure and our supply chain.

This will help us better understand our upstream and

downstream carbon footprint, including contributions

from our partners and customers, and support a low

emission, climate resilient future.

Future focused

for our planet

48ANNUAL REPORT 2024Our strategy2024 in reviewConsolidated financial statementsCorporate governanceGRI content index ContentsSustainability

Material impacts
Each financial year, we review the material impacts

identified in our baseline FY21 Materiality Assessment,

which serves as the foundation of our 2020-2025

Sustainability Strategy.

Our priority impacts remained unchanged in FY24.

However, given New Zealand’s cost of living crisis, there

is a greater need to support affordable and accessible

insurance products for our communities. Our ways to

save and pricing and underwriting features on pages 13

and 20 outline some of the actions we are taking

to manage this challenge.

Our 12 most material topics are;

• affordable and accessible insurance,

• diversity and inclusion,

• employee wellbeing,

• transparent insurance,

• product development and innovation,

• data protection,

• managing the impacts of climate change,

• corporate and community citizenship,

• carbon emissions,

• corporate governance,

• environmental footprint,

• responsible investment.

The details of Tower’s material impacts including the

actions we are taking to manage these, and our targets

are available in our material impacts table, which can

be found in the sustainability section of our website.

B Corp

In FY24, work continued towards obtaining B

Corp certification. Tower completed the B Corp

Business Impact Assessment and has submitted

its application for certification. We are currently

in the evaluation stage, working with B Corp to

advance to the verification stage. We look forward

to sharing more information with the market as our

application progresses.

49ANNUAL REPORT 2024Our strategy2024 in reviewConsolidated financial statementsCorporate governanceGRI content index ContentsSustainability

Board of Directors
Independent

Director from: 12 October 2012

Graham Stuart

BCom (Hons), MS, FCA

Non-Executive Director

Geraldine McBride

BSc

Non-Executive Director

Michael Stiassny

LLB, BCom, CFInstD

Chairman

Non-Executive Director

Michael holds both a Commerce and Law degree

from the University of Auckland and is a Chartered

Fellow and past President of the Institute of Directors.

Michael has enjoyed a high-profile governance career

and is currently Chairman of 2 Cheap Cars Group

Limited, and director of Momentum Life Insurance

Limited, Tegel Group Holdings Limited, and New

Talisman Gold Mines Limited.

With a keen interest in fostering successful next

generation New Zealand businesses, Michael

also dedicates significant time to start ups and

championing entrepreneurship through his

involvement in Founders Advisory.

Michael resides in Auckland — New Zealand.

Independent

Director from: 24 May 2012

Graham is an experienced Director, with over 30 years’

experience in governance roles in New Zealand and

internationally. He is currently the Chair of NorthWest

Healthcare Property Management Limited and Comhla

Vet Limited and a Director of VinPro Limited. Previous

executive roles include Sealord Group CEO, Fonterra

Co-operative Group CFO and Director of Strategy and,

Lion Nathan International Managing Director.

Graham has a Bachelor of Commerce (First Class Hons)

from the University of Otago, a Master of Science from

Massachusetts Institute of Technology and is a Fellow

of Chartered Accountants Australia and New Zealand.

He has served on multiple Government bodies including

the Food & Beverage Taskforce, Māori Economic

Development Panel and as Chair of the Lincoln Hub

Establishment Board.

Graham resides in Auckland — New Zealand.

Independent

Director from: 1 October 2022

Geraldine has extensive governance and technology

industry experience, having performed Board and senior

leadership roles both in New Zealand and internationally,

with Sky Network Television Limited, SAP, Dell, IBM,

National Australia Bank and Fisher & Paykel Healthcare.

Geraldine is the founder and CEO of MyWave. Geraldine

holds a Bachelor of Science from Victoria University and

is a Chartered Member of the NZIOD.

Geraldine resides in Christchurch — New Zealand.

50ANNUAL REPORT 2024Our strategy2024 in reviewConsolidated financial statementsCorporate governanceGRI content index ContentsSustainability

Marcus Nagel
MBA (International Management),

MBA (Banking and Finance)

Non-Executive Director

Mike Cutter

BSc (Hons) GAICD

Non Executive Director

Non-independent

Director from:

14 January 2019

Marcus has significant insurance industry experience.

For a decade he has performed senior leadership roles

for Zurich in Europe and globally. In his last role at

Zurich, he served as the Chief Executive Officer of Zurich

Germany managing both life insurance and general

insurance businesses. Marcus holds a Master’s Degree in

Banking and Finance from Goethe University in Frankfurt,

Germany and Master of International Management

from the Arizona State University Thunderbird School of

Global Management in Arizona, United States of America.

Marcus was nominated by Bain Capital Credit LP

(Bain Capital) to represent Bain Capital’s stake in Tower

(Bain Capital hold 20.00% of Tower’s ordinary shares)

and his appointment was supported by the Tower Board.

Marcus resides in Schindellegi — Switzerland.

Independent

Director from:

17 November 2023

Mike has significant experience in a range of financial

services businesses in Australia, New Zealand, Asia and

Europe. He is the Chair of Arteva Funding and Fairway

Group Limited, and a Non-Executive Director of Pepper

Money. He is the co-founder of Kadre, a credit risk

management consultancy.

Mike has recently served as interim Managing Director

for Bambora Aus and was previously the Group

Managing Director for Equifax ANZ. Before this he held

various senior roles with GE, ANZ, Wesfarmers/OAMPS

Insurance Brokers, Halifax/BankOne and NAB.

Mike is a Senior Fellow of Financial Services Institute

of Australia. He has served on the Boards of the

Women’s Cancer Foundation, Ovarian Cancer Institute,

the Australian Finance Congress, the National

Insurance Brokers Association and the Australian Retail

Credit Association.

Mike resides in Melbourne – Australia.

51ANNUAL REPORT 2024Our strategy2024 in reviewConsolidated financial statementsCorporate governanceGRI content index ContentsSustainability

Consolidated
financial statements

ANNUAL REPORT 202452 ContentsGRI content index Corporate governanceConsolidated financial statementsSustainabilityOur strategy2024 in review

Financial Statements
Consolidated statement of comprehensive income

54

Consolidated balance sheet55

Consolidated statement of changes in equity56

Consolidated statement of cash flows57

Notes to the consolidated financial statements

1Overview58

1.1About this report58

1.2Consolidation58

1.3Critical accounting judgements and estimates60

1.4Changes in accounting policies and disclosures60

1.5Segmental reporting61

2Insurance and reinsurance contracts63

2.1Insurance and reinsurance contracts accounting policies63

2.2Insurance service expense and other operating expenses65

2.3Net insurance finance expense66

2.4Insurance and reinsurance assets and liabilities66

2.5Receivables73

2.6Payables74

2.7Provisions74

3Investments and other income75

3.1Investment income75

3.2Investments75

3.3Other income76

4Risk management76

4.1Risk management overview76

4.2Strategic risk77

4.3Insurance risk77

4.4Credit risk78

4.5Market risk80

4.6Liquidity risk81

4.7Capital management risk82

4.8Operational risk83

4.9Regulatory and compliance risk83

4.10Conduct risk83

4.11Cyber risk83

4.12Environment, Social and Governance (ESG) risk84

5Capital structure84

5.1Contributed equity84

5.2Reserves85

5.3Net tangible assets per share85

5.4Earnings per share85

5.5Dividends85

6Other balance sheet items86

6.1Property, plant and equipment86

6.2Intangible assets87

6.3Leases89

7Tax 91

7.1Tax expense91

7.2Current tax91

7.3Deferred tax92

7.4Imputation credits93

8Other information94

8.1Notes to the consolidated statement of cash flows94

8.2Related party disclosures95

8.3Auditor's remuneration95

8.4Discontinued operations96

8.5Tower Long-Term Incentive Plan97

8.6Contingent liabilities98

8.7Capital commitments98

8.8Subsequent events98

Independent Auditor's report, and Appointed Actuary's report

Independent Auditor's report99

Appointed Actuary's report103

ANNUAL REPORT 202453Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

Consolidated statement of comprehensive income
FOR THE YEAR ENDED 30 SEPTEMBER 2024

NOTE

2024

$000

RESTATED

2023

$000

Insurance revenue555,818 472,611

Insurance service expense2.2(381,608)(604,851)

Insurance service result before reinsurance contracts held174,210 (132,240)

Net (expense)/income from reinsurance contracts held(91,364)124,360

Insurance service result82,846 (7,880)

Investment income3.121,800 14,627

Investment expense(250)(298)

Net investment income21,550 14,329

Finance expense from insurance contracts issued2.3(5,592)(1,510)

Finance income from reinsurance contracts held2.33,020 162

Net insurance finance expense(2,572)(1,348)

Net insurance and investment result101,824 5,101

Other income4,064 5,727

Other operating expenses2.2(2,348)(2,145)

Finance costs(882)(920)

Profit before taxation from continuing operations102,658 7,763

Tax expense from continuing operations7.1(31,774)(5,176)

Profit after taxation from continuing operations70,884 2,587

Profit/(loss) after taxation from discontinued operations8.43,401 (3,609)

Profit/(loss) after taxation for the year74,285 (1,022)

NOTE

2024

$000

RESTATED

2023

$000

Items that may be reclassified to profit or loss

Currency translation differences(1,308)(1,494)

Reclassification of the foreign currency translation reserve8.4410 544

Other comprehensive loss net of taxation(898)(950)

Total comprehensive profit/(loss) for the year73,387 (1,972)

Earnings per share:

Basic earnings per share (cents) for continuing operations5.418.7 0.7

Basic earnings per share (cents) for profit attributable to

shareholders5.419.6 (0.3)

Profit/(loss) after taxation attributed to shareholders74,285 (1,022)

Total comprehensive profit/(loss) attributed to shareholders73,387 (1,972)

Refer to note 1.1d for further details of the restatement of the comparative period.

The above statement should be read in conjunction with the accompanying notes.

ANNUAL REPORT 202454Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

Consolidated balance sheet
AS AT 30 SEPTEMBER 2024

NOTE

2024

$000

2023

$000

RESTATED

2022

$000

Assets

Cash and cash equivalents8.175,390 64,009 84,502

Investments3.2367,506 258,798 258,634

Receivables2.519,799 16,797 13,408

Current tax assets7.2a13,222 12,917 13,069

Assets classified as held for sale8.4 – 11,505 16,673

Reinsurance contract assets2.435,503 147,236 26,918

Deferred tax assets7.3a382 16,074 16,492

Right-of-use assets6.3a19,990 23,204 23,326

Property, plant and equipment 6.16,735 6,280 5,417

Intangible assets6.296,621 98,524 94,653

Total assets635,148 655,344 553,092

Liabilities

Payables2.632,287 18,378 20,861

Insurance contract liabilities2.4177,569 285,809164,912

Current tax liabilities7.2b606 198 136

Liabilities classified as held for sale8.4 – 7,609 5,119

Provisions2.721,959 12,823 11,873

Lease liabilities6.3a28,855 32,615 35,054

Deferred tax liabilities7.3b13,716 178 339

Total liabilities274,992 357,610 238,294

Net assets360,156 297,734 314,798

NOTE

2024

$000

2023

$000

RESTATED

2022

$000

Equity

Contributed equity5.1460,734 460,315 460,191

Retained earnings/(losses)4,428 (58,473)(43,942)

Reserves5.2 (105,006)(104,108)(101,451)

Total equity360,156 297,734 314,798

Refer to note 1.1d for further details of the restatement of the comparative periods.

The above statement should be read in conjunction with the accompanying notes.

The financial statements were approved for issue by the Board on 28 November 2024.

Michael P Stiassny Graham R Stuart

Chairman Director

ANNUAL REPORT 202455Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

Consolidated statement of changes in equity
YEAR ENDED 30 SEPTEMBER 2024

ATTRIBUTED TO SHAREHOLDERS

NOTE

CONTRIBUTED

EQUITY

$000

RETAINED

EARNINGS/

(LOSSES)

$000

RESERVES

$000

TOTAL EQUITY

$000

Year Ended 30 September 2024

Balance as at 30 September 2023 (restated)460,315 (58,473)(104,108)297,734

Comprehensive income

Profit for the year –74,285 –74,285

Currency translation differences––(1,308)(1,308)

Reclassification of foreign currency translation reserve to profit or loss8.4––410 410

Total comprehensive income–74,285 (898)73,387

Transactions with shareholders

Dividends paid5.5–(11,384)–(11,384)

Share rights issued under Tower Long-Term Incentive Plan8.5419 ––419

Total transactions with shareholders419 (11,384)–(10,965)

At the end of the year460,734 4,428 (105,006)360,156

Year Ended 30 September 2023

Balance as at 30 September 2022 originally reported460,191 (41,212)(101,451)317,528

Adjustment on initial application of NZ IFRS 17 on 1 October 20221.4 – (2,730) – (2,730)

Restated balance at beginning of the year460,191 (43,942)(101,451)314,798

Comprehensive loss (restated)

Loss for the year – (1,022) – (1,022)

Currency translation differences – – (1,494)(1,494)

Reclassification of foreign currency translation reserve to profit or loss8.4 – – 544 544

Revaluation surplus transferred to retained earnings5.2 – 1,707 (1,707) –

Total comprehensive loss (restated) – 685 (2,657)(1,972)

Transactions with shareholders

Dividends paid – (15,216) – (15,216)

Share rights issued under Tower Long-Term Incentive Plan8.5124 – – 124

Total transactions with shareholders124 (15,216) – (15,092)

At the end of the year (restated)460,315 (58,473)(104,108)297,734

Refer to note 1.1d for further details of the restatement of the comparative period.

The above statement should be read in conjunction with the accompanying notes.

ANNUAL REPORT 202456Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

Consolidated statement of cash flows
FOR THE YEAR ENDED 30 SEPTEMBER 2024

NOTE

2024

$000

RESTATED

2023

$000

Cash flows from operating activities

Premiums received for insurance contracts issued560,514 482,701

Insurance acquisition costs paid(68,119)(58,441)

Reinsurance paid(72,944)(69,508)

Interest received 17,606 11,611

Fee and other income received2,857 2,920

Insurance claims paid and other insurance service expenses(386,791)(420,279)

Reinsurance recoveries received91,551 78,487

Other operating payments(2,348)(2,145)

Income tax paid(1,011)(1,805)

Operating activities cash flow from discontinued operations3,872 (15,276)

Net cash inflow from operating activities 8.1 145,187 8,265

Cash flows from investing activities

Proceeds from sale of interest bearing investments404,097 256,607

Payments for purchase of interest bearing investments(503,035)(255,111)

Payments for purchase of intangible assets (17,395)(15,299)

Payments for purchase of customer relationships6.2 – (5,900)

Proceeds from sale of property, plant & equipment 30 5,746

Payments for purchase of property, plant & equipment (2,360)(2,557)

Net proceeds from sale of discontinued operations2,019 2,658

Investing activities cash flow from discontinued operations76 1,427

Net cash outflow from investing activities (116,568)(12,429)

NOTE

2024

$000

RESTATED

2023

$000

Cash flows from financing activities

Dividends paid(11,384)(15,213)

Payments relating to lease liabilities6.3 (5,064)(6,980)

Financing activities cash flow from discontinued operations(25)(56)

Net cash outflow from financing activities (16,473)(22,249)

Net increase/(decrease) in cash and cash equivalents12,146 (26,413)

Effect of foreign exchange rate changes(2,067)(575)

Cash and cash equivalents at the beginning of the year 65,311 92,299

Cash and cash equivalents at the end of the year 75,390 65,311

Cash from discontinued operations 8.4 – 1,302

Cash and cash equivalents at the end of the year

from continuing operations75,390 64,009

Refer to note 1.1d for further details of the restatement and re-presentation of the comparative period.

The above statement should be read in conjunction with the accompanying notes.

ANNUAL REPORT 202457Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

1 Overview
This section provides information that is helpful to an overall understanding of the financial statements

and the areas of critical accounting judgements and estimates included in the financial statements.

It also includes a summary of Tower’s operating segments.

1.1 About this Report

a. Entities reporting

The financial statements presented are those of Tower Limited (the Company) and its subsidiaries.

The Company and its subsidiaries together are referred to in this financial report as Tower or the Group.

The address of the Company’s registered office is 136 Fanshawe Street, Auckland, New Zealand.

During the periods presented, the principal activity of the Group was the provision of general insurance. The

Group predominantly operates in New Zealand with some of its operations based in the Pacific Islands region.

The financial statements were authorised for issue by the Board of Directors on 28 November 2024. The entity’s

owners or others do not have the power to amend the financial statements after issue.

b. Statutory base

Tower Limited is a company incorporated in New Zealand under the Companies Act 1993 and listed on the

NZX Main Board and the Australian Securities Exchange. The Company is a reporting entity under Part 7 of the

Financial Markets Conduct Act 2013.

c. Basis of preparation

The Company is a for-profit entity and the financial statements have been prepared in accordance with

New Zealand Generally Accepted Accounting Practice (NZ GAAP). They comply with International Financial

Reporting Standards Accounting Standards (IFRS Accounting Standards), New Zealand Equivalents to

International Financial Reporting Standards (NZ IFRS) and other applicable financial reporting standards, as

appropriate for Tier 1 for-profit entities.

The financial statements of the Group have been prepared in accordance with the requirements of Part 7 of the

Financial Markets Conduct Act 2013 and the NZX Main Board Listing Rules.

The Group financial statements are presented in New Zealand dollars and rounded to the nearest thousand

dollars. They have been prepared in accordance with the historical cost basis except for certain financial

instruments that are stated at their fair value.

Notes to the consolidated financial statements

d. Restatement and re-presentation of comparatives

As a result of the adoption of NZ IFRS 17 Insurance Contracts (NZ IFRS 17), there have been restatements

made to the comparatives as at 30 September 2023. There are also changes in presentation of the

consolidated statement of comprehensive income, consolidated balance sheet and consolidated statement

of cash flows. Refer to note 1.4a for further details.

In addition to the restatements due to the adoption of NZ IFRS 17 there has been certain reclassifications in

the cash flow statement to ensure the consistency in the presentation in the current year.

e. Discontinued operations

The Group's Solomon Islands Operations (disposal group), and Vanuatu Operations (disposal group) were

disposed in the year ended 30 September 2024.

All disposal groups together form the "discontinued operations". Profit or loss information for the current period

is prepared on a continuing basis with net results from discontinued operations presented separately. Refer to

note 8.4 for further details.

The activities of the businesses have been reported in the current period, and as at 30 September 2023, as a

discontinued operation.

1.2 Consolidation

a. Principles of consolidation

The Group financial statements incorporate the assets and liabilities of all subsidiaries of the Company at

reporting date and the results of all subsidiaries for the year.

Subsidiaries are those entities over which the consolidated entity has control, being power over the investee;

exposure, or rights to variable returns from its involvement with the investee; and the ability to use its power

over the investee to affect the amount of the investor’s returns.

The results of any subsidiaries acquired during the year are consolidated from the date on which control

was transferred to the consolidated entity and the results of any subsidiaries disposed of during the year are

consolidated up to the date control ceased.

Intercompany transactions and balances between Group entities are eliminated on consolidation.

ANNUAL REPORT 202458Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

b. Foreign currency
(i) Functional and presentation currencies

The financial statements of each Group entity are presented in the currency of the primary economic

environment in which the entity operates. The Group financial statements are presented in New Zealand

dollars and rounded to the nearest thousand dollars unless stated otherwise.

(ii) Transactions and balances

In preparing the financial statements of the individual entities, transactions denominated in foreign currencies

are translated into the entities functional and reporting currency using the exchange rates in effect at the

transaction dates. Monetary items receivable or payable in a foreign currency are translated at reporting date

at the closing exchange rate.

Translation differences on non-monetary items such as financial assets held at fair value through profit or loss

are reported as part of their fair value gain or loss.

Exchange differences arising on the settlement or retranslation of monetary items at year end exchange

rates impact profit after tax in the consolidated statement of comprehensive income unless the items form

part of a net investment in a foreign operation. In this case, exchange differences are taken to the foreign

currency translation reserve (FCTR) and recognised (as part of comprehensive profit) in the statement of

comprehensive income and the statement of changes in equity.

(iii) Consolidation

For the purpose of preparing consolidated financial statements, the assets and liabilities of subsidiaries

with a functional currency different to the Company are translated at the closing rate at the reporting date.

Income and expense items for each subsidiary are translated at a weighted average of exchange rates over

the period, as a surrogate for the spot rates at transaction dates. Foreign currency translation differences

are taken to the FCTR and recognised in the statement of comprehensive income and the statement of

changes in equity.

Goodwill and fair value adjustments arising on the acquisition of a foreign operation are treated as assets

and liabilities of the foreign operation and are translated at the closing rate with movements recorded

through the FCTR in the statement of changes in equity.

On disposal of a foreign entity, the deferred cumulative amount recognised in equity relating to that

particular foreign operation is recognised in the statement of comprehensive income.

c. Subsidiaries

The table below lists Tower Limited’s principal subsidiary companies and controlled entities. All entities have a

balance date of 30 September.

HOLDINGS

NAME OF COMPANYINCORPORATION20242023

Parent Company

New Zealand general insurance operations

Tower LimitedNZParentParent

Subsidiaries

Overseas general insurance operations

Tower Insurance (Cook Islands) LimitedCook Islands100%100%

Tower Insurance (Fiji) LimitedFiji100%100%

Tower Insurance (PNG) LimitedPNG0%0%

National Pacific Insurance LimitedSamoa100%100%

National Pacific Insurance (Tonga) LimitedTonga100%100%

National Pacific Insurance (American Samoa)

Limited

American Samoa100%100%

Tower Insurance (Vanuatu) LimitedVanuatu0%100%

Management service operations

Tower Services LimitedNZ100%100%

Tower Group Services (Fiji) Pte LimitedFiji100%100%

1.2 Consolidation (continued)

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1.3 Critical accounting judgements and estimates
In preparing these financial statements management is required to make estimates and related assumptions

about the future. The estimates and related assumptions are based on experience and other factors that are

considered to be reasonable, and are reviewed on an ongoing basis. Revisions to the estimates are recognised

in the period in which they are revised, or future periods if relevant. The key areas in which estimates and

related assumptions are applied are as follows:

—Insurance and reinsurance contracts

Premium allocation approach (PAA) eligibility note 2.1

Identification of groups of onerous contracts note 2.1

Liability for incurred claims and reinsurance asset for incurred claims,

including risk adjustment and the confidence level used note 2.4

—Compliance and remediation provision note 2.7

—Intangible assets note 6.2

—Lease liabilities (incremental borrowing rate) note 6.3a(ii)

—Deferred tax note 7.3

1.4 Changes in accounting policies and disclosures

a. New standards and interpretations

Tower adopted NZ IFRS 17 Insurance Contracts (NZ IFRS 17) from 1 October 2023. NZ IFRS 17 replaces

the guidance in NZ IFRS 4 Insurance Contracts (NZ IFRS 4) and establishes principles for the recognition,

measurement, presentation and disclosure of insurance contracts. There has been no material impact to

Tower's profitability or strategies, with the main impact being on the disclosure and presentation of financial

information. Tower has not adopted any other standard, amendment or interpretation with a material effect

on Tower.

Accounting policy change

Tower has applied the PAA to the measurement of all insurance contracts issued and reinsurance contracts

held by Tower. The PAA is a simplified measurement model in comparison with the general model under NZ

IFRS 17, it is similar to the previous measurement model used for general insurance under NZ IFRS 4.

NZ IFRS 17 introduces several new concepts, including:

— Measuring insurance contract assets and liabilities separately from reinsurance contract assets

and liabilities.

— Onerous contracts, where losses from unprofitable contracts are recognised when onerous contract

testing shows that the fulfilment cash flows of a group of insurance contracts is likely to be greater than

the carrying value of the liability for remaining coverage (LRC).

— LRC, which reflects the insurance coverage expected to be provided by Tower after the reporting date.

— Liability for incurred claims, which reflects the remaining liability for insurance claims that occurred prior

to the reporting date, adjusted for the time value of money. The liability also includes an explicit risk

adjustment for non-financial risks.

— Reinsurance asset for remaining coverage, which reflects Tower’s reinsurance coverage, adjusted to

include a loss-recovery component for expected recoveries over underlying contracts that are considered

to be onerous.

— Reinsurance asset for incurred claims, which reflects reinsurance recoveries on claims that occurred

prior to the reporting date, adjusted for the time value of money. The asset also includes an explicit risk

adjustment for non-financial risks.

Tower’s accounting policy for recognition, classification, measurement, and derecognition of insurance and

reinsurance contracts is explained in note 2.1.

Impact of accounting policy change

NZ IFRS 17 requires insurers to retrospectively apply the standard as if it had always been in effect, unless it is

impracticable to do so. Tower has determined that reasonable and supportable information was available for

all contracts in force at the transition date. NZ IFRS 17 has been applied using the full retrospective approach

in accordance with Appendix C of the standard, and the comparative information for the year ended 30

September 2023 has been restated.

As a result of the adoption of NZ IFRS 17, Tower has identified, recognised, and measured each group of

insurance contracts as if NZ IFRS 17 had always applied. Premium receivable, reinsurance recoveries, deferred

insurance costs, unearned premiums, and outstanding claims are no longer presented on the face of the

balance sheet or in the notes. These are now replaced by insurance contract liabilities and reinsurance

contract assets.

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Impact of accounting policy change (continued)
Tower has applied the transitional provisions under NZ IFRS 17 and has not disclosed the impact to each

financial statement line item and earnings per share. The impact on equity for transitioning to NZ IFRS 17 is

shown in the table below.

CONTRIBUTED

EQUITY

$000

ACCUMULATED

LOSSES

$000

OTHER

RESERVES

$000

TOTAL

EQUITY

$000

Closing balance (30 September 2022)460,191 (41,212)(101,451)317,528

Risk adjustment

1

– (4,761) – (4,761)

Changes in discounting

2

– 1,120 – 1,120

Changes in deferred IACF

3

– (155) – (155)

Tax impact

4

– 1,066 – 1,066

Opening balance under NZ IFRS 17

(1 October 2022)

460,191 (43,942)(101,451)314,798

The impact to opening total equity is driven by the following:

1

The net impact from the derecognition of risk margin under NZ IFRS 4 and the recognition of risk adjustment on liability for incurred

claims and reinsurance asset for incurred claims under NZ IFRS 17.

2

The impact of discounting certain liabilities for incurred claims and reinsurance assets for incurred claims under NZ IFRS 17 which

Tower opted not to discount under NZ IFRS 4.

3

The exclusion of non-attributable expenses under NZ IFRS 17 from the deferral of insurance acquisition cash flows (IACF).

4

The tax impact of the above adjustments against deferred tax assets and liabilities.

There are other standards, amendments and interpretations which have been approved but are not yet

effective. The Group expects to adopt other standards when they become mandatory. NZ IFRS 18 Presentation

and Disclosure in Financial Statements (NZ IFRS 18) will replace NZ IAS 1 Presentation of Financial Statements

and may have a material impact on Tower's disclosures. NZ IFRS 18 has been issued but is not effective for

Tower until 1 October 2027. Tower has not yet completed an assessment of the impact of adopting NZ IFRS 18.


1.4 New standards and interpretations (continued)1.5 Segmental reporting

a. Operating segments

Information is provided by operating segment to assist an understanding of the Group's performance.

Tower operates in two geographical segments, New Zealand and the Pacific region. New Zealand comprises

the general insurance business underwritten in New Zealand. Pacific Islands comprises the general insurance

business underwritten in the Pacific by Tower subsidiaries and branch operations. Other contains balances

relating to Tower Services Limited and group diversification benefits.

The Group does not derive revenue from any individual or entity that represents 10% or more of the Group's

total revenue.

The financial performance for Pacific Islands operating segment excludes the disposal groups. Intercompany

transactions with the disposal group are eliminated within continuing operations, refer note 8.4.


b. Financial performance of continuing operations

NEW ZEALAND

$000

PACIFIC

ISLANDS

$000

OTHER

$000

TOTAL

$000

Year Ended 30 September 2024

Insurance revenue513,566 42,252 – 555,818

Insurance service expense(356,693)(24,553)(362)(381,608)

Net (expense)/income from reinsurance

contracts held

(86,029)(5,398)63 (91,364)

Insurance service result70,844 12,301 (299)82,846

Net investment income20,666 884 – 21,550

Net insurance finance expense(2,572) – – (2,572)

Net insurance and investment result88,938 13,185 (299)101,824

Other income3,873 191 – 4,064

Other operating expenses(2,307)(41) – (2,348)

Finance costs(722)(160) – (882)

Profit/(loss) before taxation from

continuing operations89,782 13,175 (299)102,658

Tax (expense)/benefit(25,716)(6,101)43 (31,774)

Profit/(loss) after taxation from

continuing operations64,066 7,074 (256)70,884

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b. Financial performance of continuing operations (continued)
NEW ZEALAND

$000

PACIFIC ISLANDS

$000

OTHER

$000

TOTAL

$000

Year Ended 30 September 2023 (Restated)

Insurance revenue429,706 42,905 - 472,611

Insurance service expense(586,730)(18,146)25 (604,851)

Net income/(expense) from reinsurance

contracts held

140,371 (16,250)239 124,360

Insurance service result(16,653)8,509 264 (7,880)

Net investment income13,622 707 - 14,329

Net insurance finance expense(1,348) - - (1,348)

Net insurance and investment result(4,379)9,216 264 5,101

Other income4,338 761 628 5,727

Other operating expenses(2,106)(39) - (2,145)

Finance costs(734)(186) - (920)

(Loss)/profit before taxation from continuing

operations(2,881)9,752 892 7,763

Tax expense(2,437)(2,567)(172)(5,176)

(Loss)/profit after taxation from continuing

operations(5,318)7,185 720 2,587

c. Financial position of continuing operations

NEW ZEALAND

$000

PACIFIC ISLANDS

$000

OTHER

$000

TOTAL

$000

Additions to non-current assets

30 September 2024

18,702 2,175 – 20,877

Additions to non-current assets

30 September 2023

24,081 6,319 – 30,400

Total assets 30 September 2024589,793 56,580 (11,225)635,148

Total assets 30 September 2023

(restated)

618,213 50,975 (25,349)643,839

Total liabilities 30 September 2024250,337 25,478 (823)274,992

Total liabilities 30 September 2023

(restated)333,896 27,704 (11,599)350,001

Additions to non-current assets include additions to property, plant and equipment, right-of-use assets and

intangible assets.

Total assets and liabilities exclude assets and liabilities held for sale.

Definition

An operating segment is a group of assets and operations engaged in providing products or services

that are subject to risks and returns that are different to those of other operating segments. Operating

segments are reported in a manner consistent with the internal reporting provided to the chief operating

decision-maker (the Chief Executive Officer) who reviews the operating results on a regular basis and

makes decisions on resource allocation and assessing performance.

1.5 Segmental reporting (continued)

ANNUAL REPORT 202462

Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

2 Insurance and reinsurance contracts
This section provides information on Tower's underwriting activities.

Tower collects premiums from customers in exchange for providing insurance coverage. These

premiums are recognised as insurance revenue when they are earned by Tower, reducing the liability for

remaining coverage on the balance sheet.

When customers suffer a loss that is covered by their policy, Tower will make payments to customers or

suppliers, which it recognises as insurance expenses. To ensure that Tower’s obligations to customers are

properly recorded within the financial statements, Tower recognises a liability for incurred claims on the

balance sheet.

To manage Tower’s risk and optimise its returns, Tower reinsures some of its exposure with reinsurance

companies. Net expense from reinsurance contracts is measured as an allocation of reinsurance

premiums paid plus any other directly attributable expenses, less amounts recovered from reinsurers

and any change in risk from reinsurer non-performance.

2.1 Insurance and reinsurance contracts accounting policies

a. Recognition

Tower recognises insurance contracts at the earlier of the commencement of the coverage period, or when

the first premium for a group of insurance contracts is due. At inception of insurance contracts, Tower analyses

and identifies any distinct contract components that may need to be accounted for under another NZ IFRS

instead of NZ IFRS 17. Currently, Tower does not have any product groups that include distinct components that

require separation.

Insurance revenue is recognised based on passage of time over the coverage period of the contract, resulting

in a linear allocation of revenue for each contract across its coverage period. Revenue earned excludes taxes

and levies collected on behalf of third parties.

Insurance service expenses arising from insurance contracts are generally recognised in profit or loss as they

are incurred, except for insurance acquisition cash flows.

Insurance finance income and expenses comprise changes in the carrying amounts of groups of insurance and

reinsurance contracts arising from the effects of, and changes in, the time value of money and financial risk.

Tower has elected to present all insurance finance income and expenses in profit or loss.

b. Measurement Model - Insurance Contracts

NZ IFRS 17 contains three measurement models:

1) The general measurement model (GMM) measures insurance contracts based on the fulfilment cash flows

(the present value of estimated future cash flows with an explicit risk adjustment for non-financial risk) and

the contractual service margin (the unearned profit that will be recognised as services are provided over the

coverage period)

2) A modified version of the general model (the variable fee approach, or VFA) is applied to insurance contracts

with direct participation features

3) A simplified measurement model (the PAA) is permitted in certain circumstances.

The majority of Tower's insurance portfolios have a coverage period of one year or less, which allows for

application of the PAA. The coverage period, or contract boundary, is the period during which Tower has a

substantive obligation to provide customers with insurance contract services. The substantive obligation ends

when Tower can reprice insurance contracts to reflect reassessed risk.

For any insurance groups with coverage periods greater than one year, Tower has assessed that the resulting

liability for remaining coverage as measured under the PAA would not differ materially from the result of

applying the GMM. Therefore Tower has applied the PAA to all its insurance groups. Refer to note 2.1(i) for

discussion around reinsurance PAA eligibility assessment.

Tower does not issue any insurance contracts that provide an investment return, or have direct participating

contracts, therefore the VFA does not apply to Tower.

c. Level of aggregation

Tower manages insurance contracts issued by aggregating them into portfolios. Insurance contracts for

product lines with similar risks that are within the same geographical area, and managed together, are

considered to be in the same portfolio. The geographical areas for portfolio purposes are New Zealand and the

Pacific, and within each geographical area there are a number of separate portfolios based on product type.

Each portfolio will contain annual cohorts which contain contracts that are issued within a financial year. Annual

cohorts can be further disaggregated into three groups at inception: onerous contracts, contracts with no

significant risk of becoming onerous, and the remainder.

d. Onerous contracts

The profitability of groups of contracts is assessed by actuarial valuation models. All insurance contracts are

measured under the PAA, and therefore Tower assumes that no contracts in a group are onerous at initial

recognition unless facts and circumstances indicate otherwise.

To determine which facts and circumstances are indicative of onerous contracts management considers future

profitability for a group of contracts, as well as factors that may be internal to Tower (e.g., pricing decisions) or

external (e.g., sudden and unexpected changes to the economic or regulatory environments). When facts and

circumstances indicate a set of contracts may be onerous, Tower will perform an additional assessment to

distinguish onerous contracts from non-onerous contracts. Onerous contract testing will involve determining

the estimation of the fulfilment cash flows in relation to that group of onerous contracts.

ANNUAL REPORT 202463

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d. Onerous contracts (continued)
Tower will recognise a loss in profit or loss for onerous contracts, which is measured as the difference between

fulfilment cash flows related to the remaining coverage of the group using the general model, and liability for

the remaining coverage using the PAA. The increase to the liability for remaining coverage resulting from the

recognition of onerous contracts will be tracked separately as a loss component. In subsequent periods, Tower

will reassess previously onerous contracts then remeasure fulfilment cash flows. The impact from changes in

fulfilment cash flows will be recorded in profit or loss, and the liability for remaining coverage will reflect the

remeasured fulfilment cash flows. When fulfilment cash flows are incurred, they are allocated systematically

between the loss component and the liability for remaining coverage. The systematic allocation is based on the

loss component relative to the total estimated present value of future cash outflows.

e. Liability for remaining coverage

The LRC reflects insurance coverage expected to be provided by Tower after the reporting date. This is

measured inclusive of any taxes and levies collected on behalf of third parties. On initial recognition of each

group of contracts, the carrying amount of the LRC is measured as the premiums received less any insurance

acquisition cash flows allocated to the group at that date, and adjusted for any amount arising from the

derecognition of any assets or liabilities previously recognised for cash flows related to the group.

Subsequent measurement of the carrying amount of the LRC is increased by any premiums received and

the amortisation of insurance acquisition cash flows recognised as expenses, and decreased by the amount

recognised as insurance revenue for services provided and any additional insurance acquisition cash flows

allocated after initial recognition.

On initial recognition of each group of contracts, Tower expects that the time between providing each part of the

services and the related premium due date is no more than a year. Accordingly, Tower has chosen not to adjust

the LRC to reflect the time value of money and the effect of financial risk.

f. Insurance acquisition cash flows

Insurance acquisition cash flows (IACF) comprise the costs of selling, underwriting and starting a group of

insurance contracts (which are issued or expected to be issued) that are directly attributable to portfolios of

insurance contracts.

Tower has elected to defer IACF and recognise as insurance expenses across the coverage period of contracts

issued, rather than to expense them when incurred. The amortisation period for IACF begins at the later of when

the costs are incurred or when the underlying insurance contracts are recognised, and are expected to be

amortised within 12 months on a straight-line basis. All IACF are allocated to groups of insurance contracts.

g. Liability for incurred claims

Liability for incurred claims (LIC) relate to claims that have occurred prior to reporting date but have not

been paid. This is measured as the present value of the estimated future cash outflows plus a specific risk

adjustment (RA) factor to account for non-financial risks. Tower has elected to discount the LIC to reflect the

time value of money.

Tower does not disaggregate changes in the RA between the insurance service result and insurance finance

income or expenses. All changes in the RA are included in the insurance service result.

h. Insurance modification and derecognition

Tower derecognises insurance contracts when rights and obligations relating to the contract are extinguished,

or when the contract is modified in a way that would have changed the accounting for the contract significantly

had the new terms been included at contract inception. In such a case a new contract based on the modified

terms is recognised.

i. Measurement Model - Reinsurance Contracts

Some reinsurance contracts held by Tower have a three year contract boundary, however the result of applying

the PAA model does not result in a material difference from applying the GMM model. Therefore all reinsurance

contracts held by Tower are measured using the PAA measurement model.

Quantitative PAA eligibility testing has been performed over these contracts, where the following key

assumptions and estimates are modelled:

— Expected future cash flows

— Risk adjustment

— Contractual service margin (CSM), the balancing component to result in nil profit or loss impact at

inception.The CSM represents the net cost of purchasing reinsurance, which will be released over the

coverage period.

— Expected variability in assumptions used, such as changes in discount rates

Tower measures its reinsurance assets on the same basis as insurance contracts issued, however these are

adapted to reflect the features of reinsurance contracts held that differ from insurance contracts held.

j. Reinsurance contracts - level of aggregation

Tower manages all reinsurance contracts held together and the contracts held provide coverage for similar

risks. All reinsurance contracts held by Tower are considered as a single portfolio.

2.1 Insurance and reinsurance contracts accounting policies (continued)

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k. Reinsurance contract assets - recognition and measurement
A reinsurance asset for remaining coverage (RI ARC) is recognised at the start of the coverage period of the

reinsurance contract where the contract provided non-proportionate coverage, or when the underlying

insurance contract is recognised where the contract provides proportionate coverage. The asset is measured

as premiums paid, adjusted for any acquisition cash flows.

A loss-recovery component is established within the RI ARC for the gain recognised in profit or loss when

the Group has recognised a loss on underlying groups of onerous contracts that are covered by reinsurance

contracts held. The gain is calculated by multiplying the loss recognised on underlying insurance contracts

by the percentage of claims on underlying insurance contracts that the Group expects to recover from the

reinsurance contracts held that are entered into before or at the same time as the loss is recognised on the

underlying insurance contracts.

This loss-recovery component is adjusted to reflect changes in the loss component of the onerous group of

underlying contracts and is further adjusted, if required, to ensure that it does not exceed the portion of the

carrying amount of the loss component of the onerous group of underlying insurance contracts that Tower

expects to recover from the reinsurance contracts held.

Reinsurance asset for incurred claims (RI AIC) is recognised when a claim is made on an underlying contract

and a reinsurance contract was held to cover the risks on the underlying insurance contract. This is measured

based on estimated future cash flows, adjusted to reflect the time value of money, and a RA factor for any non-

financial risks.

Net (expense)/income from reinsurance contracts held is measured as an allocation of reinsurance premiums

paid plus any other directly attributable expenses, less amounts recovered from reinsurers, and any change in

risk from reinsurer non-performance.

Reinsurance premiums paid reflect premiums ceded to reinsurers and are recognised as an expense in

accordance with the pattern of reinsurance service received. Commission revenue from reinsurance contracts

held by Tower that are not contingent on claims for underlying insurance contracts is treated as a reduction in

premiums paid.

Tower also has profit-share commission arrangements for some proportional reinsurance contracts, where

the commission is contingent on claims. Commission from the profit-share arrangements will offset against RI

claims recoveries in RI AIC.

Amounts recovered from reinsurers are recognised when a claim has been incurred and the basis for

measurement is the expected future cash inflows.

l. Discount rates

Tower discounts future cash flows related to insurance liabilities for incurred claims and reinsurance assets for

incurred claims to recognise the impact of the time value of money. Tower has adopted a 'bottom-up' approach to

derive the discount rate. The risk-free yield is derived from observable secondary market prices for NZ government

bonds. Nil illiquidity premium has been assumed on the basis that it would not have a material impact.

2.2 Insurance service expense and other operating expenses

Composition

2024

$000

2023

$000

Claims expenses 245,048 489,021

(Reversals)/losses on onerous insurance contracts(223)607

Commission expenses amortised 13,022 12,342

Management expenses:

People costs92,671 84,408

People costs capitalised during the year(10,824)(9,562)

Technology17,189 16,372

Amortisation19,269 17,327

Depreciation5,962 5,836

External fees20,128 10,687

Marketing14,792 13,128

Communications3,852 3,361

Miscellaneous3,605 3,814

Movement in non-commission deferred insurance acquisition

cash flows

(6,011)(4,540)

Claims related management expenses reclassified to claims

expense

(35,756)(36,208)

Service fees charged to discontinued operations(1,116)(1,742)

Total insurance service expense381,608 604,851

Other operating expenses2,348 2,145

Total insurance service expense and other

operating expenses383,956 606,996

2.1 Insurance and reinsurance contracts accounting policies (continued)

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2.3 Net insurance finance expense
2024

$000

2023

$000

Interest accreted(5,314)(1,804)

Effect of changes in interest rates and other financial

assumptions

(278)294

Finance expense from insurance contracts issued(5,592)(1,510)

Interest accreted2,877 212

Effect of changes in interest rates and other financial

assumptions

143 (50)

Finance income from reinsurance contracts held3,020 162

Net insurance finance expense(2,572)(1,348)

2.4 Insurance and reinsurance assets and liabilities

a. Insurance and reinsurance contracts

2024

$000

ASSETSLIABILITIES

CURRENT

PORTION

NON-

CURRENT

PORTIONTOTAL

Liability for remaining coverage – 42,042 42,042 – 42,042

Liability for incurred claims – 135,527 110,169 25,358 135,527

Total insurance contracts issued – 177,569 152,211 25,358 177,569

Total reinsurance contracts held35,503 – 28,854 6,649 35,503

2023

$000

ASSETSLIABILITIES

CURRENT

PORTION

NON-

CURRENT

PORTIONTOTAL

Liability for remaining coverage – 44,614 44,614 – 44,614

Liability for incurred claims – 241,195 198,860 42,335 241,195

Total insurance contracts issued – 285,809 243,474 42,335 285,809

Total reinsurance contracts held147,236 – 125,567 21,669 147,236

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b. Reconciliation of insurance assets and liabilities
2024

$000

LIABILITIES FOR REMAINING COVERAGELIABILITIES FOR INCURRED CLAIMSTOTAL

EXCLUDING LOSS

COMPONENTLOSS COMPONENT

ESTIMATES OF THE

PRESENT VALUE

OF FUTURE CASH

FLOWSRISK ADJUSTMENT

Opening insurance contract liabilities43,994 620 223,565 17,630 285,809

Insurance revenue(555,818) - - - (555,818)

Insurance service expense:

Incurred claims and other insurance service expenses* - - 314,130 3,666 317,796

Amortisation of IACF62,835 - - - 62,835

Changes relating to past service - - (15,950)(8,117)(24,067)

Reversals on onerous contracts - (223) - - (223)

Finance expense from insurance contracts issued - - 5,592 - 5,592

Effect of movements in exchange rates(272)(13)(348) - (633)

Amounts included in statement of comprehensive income(493,255)(236)303,424 (4,451)(194,518)

Cash flows:

Premiums received559,383 - - - 559,383

Claims and other insurance service expenses paid - - (404,641) - (404,641)

Insurance acquisition cash flows(68,119) - - - (68,119)

Amounts included in statement of cash flow491,264 - (404,641) - 86,623

Pre-recognition cash flows derecognised and other changes(345) - - - (345)

Insurance contract liabilities at 30 September 202441,658 384 122,348 13,179 177,569

* Excludes $25m of insurance service expenses for depreciation and amortisation, which do not form part of insurance contract liabilities on the balance sheet.

Certain cash flows presented above may be on a deemed basis in respect of movements through the insurance contract liabilities, and certain amounts may be recognised in other receivable, payable and provision balances,

so they may differ from the actual cash flow amounts reported in the consolidated statement of cash flows.

2.4 Insurance and reinsurance assets and liabilities (continued)

ANNUAL REPORT 202467

Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

b. Reconciliation of insurance assets and liabilities (continued)
2023

$000

LIABILITIES FOR REMAINING COVERAGELIABILITIES FOR INCURRED CLAIMSTOTAL

EXCLUDING LOSS

COMPONENTLOSS COMPONENT

ESTIMATES OF THE

PRESENT VALUE

OF FUTURE CASH

FLOWSRISK ADJUSTMENT

Opening insurance contract liabilities43,343- 105,32116,247164,911

Insurance revenue(472,611)- - - (472,611)

Insurance service expense:

Incurred claims and other insurance service expenses*- - 516,6778,064524,741

Amortisation of IACF54,000- - - 54,000

Changes relating to past service- - 8,887(6,546)2,341

Losses and reversals on onerous contracts- 607- - 607

Finance expense from insurance contracts issued- - 1,511- 1,511

Effect of movements in exchange rates26513444- 722

Amounts included in statement of comprehensive income(418,346)620527,5191,518111,311

Cash flows:

Premiums received482,701- - - 482,701

Claims and other insurance service expenses paid- - (408,546)- (408,546)

Insurance acquisition cash flows(58,441)- - - (58,441)

Amounts included in statement of cash flow424,260- (408,546)- 15,714

Pre-recognition cash flows derecognised and other changes(5,263)- (728)(136)(6,127)

Insurance contract liabilities at 30 September 202443,994620223,56617,629285,809

* Excludes $23m of insurance service expenses for depreciation and amortisation, which do not form part of insurance contract liabilities on the balance sheet.

Certain cash flows presented above may be on a deemed basis in respect of movements through the insurance contract liabilities, and certain amounts may be recognised in other receivable, payable and provision balances,

so they may differ from the actual cash flow amounts reported in the consolidated statement of cash flows. Pre-recognition cash flows derecognised and other changes also includes the derecognition of liabilities that moved to

liabilities held for sale during the period.

2.4 Insurance and reinsurance assets and liabilities (continued)

ANNUAL REPORT 202468

Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

c. Reconciliation of reinsurance assets and liabilities
2024

$000

ASSETS FOR REMAINING

COVERAGE

ASSET FOR

INCURRED CLAIMSTOTAL

EXCLUDING

LOSS RECOVERY

COMPONENT

LOSS RECOVERY

COMPONENT

ESTIMATES OF THE

PRESENT VALUE

OF FUTURE CASH

FLOWSRISK ADJUSTMENT

Year ended 30 September 2024

Opening reinsurance contract assets(4,229)– 146,3275,138147,236

Reinsurance premiums(79,587)– – – (79,587)

Amounts recoverable from reinsurers:

Amounts recoverable for incurred claims– – 6,5276427,169

Changes relating to past service– – (15,812)(3,134)(18,946)

Finance income from reinsurance contracts held– – 3,020– 3,020

Effect of movements in exchange rates101– 25– 126

Amounts included in statement of comprehensive income(79,486) – (6,240)(2,492)(88,218)

Cash flows:

Premiums paid net of ceding commissions72,025– – – 72,025

Reinsurance recoveries (net of profit share commissions)– – (95,540)– (95,540)

Amounts included in statement of cash flow72,025– (95,540)– (23,515)

Reinsurance contract assets at 30 September 2024(11,690) – 44,547 2,646 35,503

Certain cash flows presented above may be on a deemed basis in respect of movements through the reinsurance contract assets, and certain amounts may be recognised in other receivable, and payable balances, so they may

differ from the actual cash flow amounts reported in the consolidated statement of cash flows.

2.4 Insurance and reinsurance assets and liabilities (continued)

ANNUAL REPORT 202469

Notes to the consolidated financial statements (continued)

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c. Reconciliation of reinsurance assets and liabilities (continued)
2023

$000

ASSETS FOR REMAINING

COVERAGE

ASSET FOR

INCURRED CLAIMSTOTAL

EXCLUDING

LOSS RECOVERY

COMPONENT

LOSS RECOVERY

COMPONENT

ESTIMATES OF THE

PRESENT VALUE

OF FUTURE CASH

FLOWSRISK ADJUSTMENT

Year ended 30 September 2023

Opening reinsurance contract assets4,917- 21,80519626,918

Reinsurance premiums(79,746)- - - (79,746)

Amounts recoverable from reinsurers:

Amounts recoverable for incurred claims- - 201,3565,815207,171

Changes relating to past service- - (2,198)(866)(3,064)

Finance income from reinsurance contracts held- - 162- 162

Effect of movements in exchange rates(139)- (66)- (205)

Amounts included in statement of comprehensive income(79,885)- 199,2544,949124,318

Cash flows:

Premiums paid net of ceding commissions72,080- - - 72,080

Reinsurance recoveries (net of profit share commissions)- - (74,693)- (74,693)

Amounts included in statement of cash flow72,080- (74,693)- (2,613)

Assets reclassified to assets held for sale(1,341)- (39)(7)(1,387)

Reinsurance contract assets at 30 September 2023(4,229)- 146,3275,138147,236

Certain cash flows presented above may be on a deemed basis in respect of movements through the reinsurance contract assets, and certain amounts may be recognised in other receivable, and payable balances, so they may

differ from the actual cash flow amounts reported in the consolidated statement of cash flows.

2.4 Insurance and reinsurance assets and liabilities (continued)

ANNUAL REPORT 202470

Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

d. Development of claims
The following table shows how estimates of cumulative claims have developed over time on a net of reinsurance basis.

Tower considers the probability and magnitude of future experience being more adverse than assumed. This uncertainty is reflected in the risk adjustment. In general, the uncertainty associated with the ultimate cost of settling

claims is greatest when the claim is at an early stage of development. As claims develop, the ultimate cost of claims becomes more certain.

ULTIMATE CLAIMS COST ESTIMATE

PRIOR

$000

2020

$000

2021

$000

2022

$000

2023

$000

2024

$000

TOTAL

$000

At end of incident year155,506 181,849 197,830 262,858 230,703

One year later152,143 180,386 204,450 253,812 -

Two years later150,830 181,928 206,682 - -

Three years later150,684 181,609 - - -

Four years later151,748 - - - -

Ultimate claims cost151,748 181,609 206,682 253,812 230,703

Cumulative payments(151,629)(179,513)(205,232)(245,729)(161,805)

Net estimates of the undiscounted amount of the claims11,112 119 2,096 1,450 8,083 68,898 91,758

Third party recoveries outstanding(8,372)

Claims handling expense8,538

Effect from discounting(1,601)

Effect from risk adjustment10,533

Reinsurance outstanding on paid claims(12,522)

Total net liabilities for incurred claims88,334

2.4 Insurance and reinsurance assets and liabilities (continued)

ANNUAL REPORT 202471

Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

d. Development of claims (continued)
NOTE

ESTIMATES OF

THE PRESENT

VALUE OF FUTURE

CASH FLOWS

$000

RISK

ADJUSTMENT

$000

TOTAL

$000

Insurance contract liabilities2.4b122,348 13,179 135,527

Total gross liabilities for incurred claims122,348 13,179 135,527

Reinsurance contract assets2.4c(44,547)(2,646)(47,193)

Total net liabilities for incurred claims77,801 10,533 88,334

Tower has limited exposure to long-tail classes of business. Long-tail classes have increased uncertainty of the

ultimate cost of claims due to the additional period of time to settlement.

Prior year numbers have been restated at current year exchange rates to reflect the underlying development

of claims.

e. Liability for incurred claims

Future cash outflows are estimated using data specific to each portfolio, relevant industry data and general

economic data. The estimation process factors in the risks to which the business is exposed to at a point in

time, claim frequency and severity, historical trends in the development of claims as well as legal, social and

economic factors that may affect Tower.

Assumption

20242023

Expected future claims development64.0%45.5%

Claims handling expense ratio7.9%5.6%

Risk adjustment10.7%7.8%

Discount rate4.4%5.7%

Future Canterbury Earthquakes overcap property claims$5.2m$3.5m

Expected future claims development proportion

This is the proportion of additional claims cost that is expected to be recognised in the future for claims that

have already been reported. The assumption is expressed as a proportion of current case estimates for open

claims and the resulting amount is recognised in the balance sheet as a liability for incurred claims. The ratio

in 2024 has increased due to the settlement of the bulk of the claims from the 2023 storm events and the

corresponding change in the mix of outstanding claims at September 2024 compared to the previous year.

2.4 Insurance and reinsurance assets and liabilities (continued)

Claims handling expense ratio

This reflects the expected cost to administer future claims. The ratio is calculated based on historical

experience of claims handling expenses. The increase in 2024 is due to the reclassification of certain external

assessment costs as claims handling expenses.

Discount rate

The discount rates determined for 30 September 2024 were between 3.8 and 5% (2023: 5.3 and 5.8%).

The table below summarises the yield curves used to discount Tower's liability for incurred claims.

As at 30 September 2024

%1 year2 years3 years4 years5+ years

New Zealand4.2%3.7%3.6%3.7%3.8%

As at 30 September 2022

%1 year2 years3 years4 years5+ years

New Zealand5.8%5.5%5.4%5.3%5.3%

Risk adjustment (RA)

The risk adjustment is the compensation Tower requires for bearing uncertainty about the amount and timing of

the cash flows that arises from non-financial risk related to a group of insurance contracts.

The determination of the appropriate level of risk adjustment takes into account:

— the level of economic capital that Tower requires to support the insurance business and the weighted

average cost of servicing that capital;

— the run-off profile and term to settlement of the net discounted cash flows;

— class of business; and

— the benefit of diversification between geographic locations.

The Group determines the risk adjustment for non-financial risk at the Group level and allocates it to groups of

insurance and reinsurance contracts in a systematic and rational way.

Tower uses the cost of capital method to derive the overall risk adjustment for non-financial risk. In the cost

of capital method, the risk adjustment is determined by applying a cost rate to the value of projected capital

relating to non-financial risk. A required return of capital of 12.5%, net of reinsurance, has been used for

assessing risk adjustment for LIC and LRC balances. The resulting risk adjustment corresponds to outcomes

expected with a confidence level of 72.5% for New Zealand (excluding Canterbury earthquakes), 75% for Pacific

and 90% for Canterbury earthquakes. A diversification benefit is included to reflect the diversification of risk

across countries, reflecting the compensation that the entity requires.

ANNUAL REPORT 202472

Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

f. Sensitivity Analysis
The impact on profit or loss before tax, and the impact on equity for any reasonable changes at period end

have been summarised below. Each change has been calculated in isolation from the other variables.

Liability for incurred claims

IMPACT ON PROFIT OR

LOSS GROSS OF

REINSURANCE

IMPACT ON PROFIT OR

LOSS NET OF

REINSURANCE

MOVEMENT

IN

ASSUMPTION

2024

$000

2023

$000

2024

$000

2023

$000

Expected future claims development + 10%(4,805)(7,177)(3,434)(3,251)

- 10%4,805 7,177 3,434 3,251

Claims handling expense ratio + 10%(970)(1,243)(854)(677)

- 10%970 1,243 854 677

Risk adjustment + 10%(1,318)(1,414)(1,053)(900)

- 10%1,318 1,414 1,053 900

Discount rate + 1.75%1,128 1,939 806 905

- 1.75%(1,128)(2,009)(806)(937)

Number of future Canterbury + 50%(4,100)(2,800)(4,100)(2,800)

Earthquake overcap claims - 50%4,100 2,800 4,100 2,800


2.4 Insurance and reinsurance assets and liabilities (continued)2.5 Receivables

Composition

2024

$000

2023

$000

Prepayments13,969 5,417

Finance lease receivables – 344

Other receivables5,830 11,036

Receivables19,799 16,797

Receivable within 12 months16,16816,797

Receivable in greater than 12 months3,631 –

Receivables19,799 16,797

Recognition and measurement

Receivables (inclusive of GST) are recognised at fair value and are subsequently measured at amortised

cost, less any expected credit loss (ECL). Tower applies the simplified approach in calculating ECL.

The ECL calculation is based on a provision matrix which is based on historical credit loss experience,

adjusted for forward looking factors specific to the receivables and the economic environment.

ANNUAL REPORT 202473

Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

2.6 Payables
Composition

2024

$000

2023

$000

Trade payables 16,747 10,833

Pre-coverage liability 2,035 1,930

GST payable 3,497 (1,511)

Unsettled investment purchases 5,400 -

Other 4,608 3,899

Payable to discontinued operations - 3,227

Payables 32,287 18,378

Payable within 12 months 32,287 18,378

Payable in greater than 12 months - -

Payables 32,287 18,378

Recognition and measurement

Payables are recognised where goods or services that have been received or supplied and have been

invoiced or formally agreed with the supplier. Payables are stated at the fair value of the consideration to

be paid in the future inclusive of GST. GST payable represents the net amount payable to the respective

tax authorities.

Tower receives some premiums in advance of the initial recognition date of an insurance contract. For

these premiums received in advance Tower recognises a separate pre-coverage liability (PCL). When the

coverage period for the contract starts, the PCL is reduced and the value of the premiums is transferred

to the liability for remaining coverage.

2.7 Provisions

Composition

2024

$000

2023

$000

Annual leave and other employee benefits 12,771 5,737

Compliance and remediation 9,188 7,086

Provisions 21,959 12,823

Payable within 12 months 20,926 11,762

Payable in greater than 12 months 1,033 1,061

Provisions 21,959 12,823

The annual leave and other employee benefits provision has increased by $14.2m during the period, offset by

payments to employees of $7.2m.

A compliance and remediation provision has been recognised and is reassessed at each reporting period.

A range of possible outcomes is considered, and the re-assessment has resulted in an additional $7.5m

being recognised in the current period, which has been offset by payments made during the period. The

resulting provision allows for amounts to be repaid to customers and costs associated with any potential

regulatory action.

The Financial Markets Authority (FMA) is seeking a declaration from the court that Tower contravened the

Financial Markets Conduct Act (2013) and that a pecuniary penalty is paid to the Crown. Any eventual penalty

to be determined by the High Court may be in excess or lower than the provision recognised in these financial

statements. The timing of any penalty payable by Tower is also uncertain.

Recognition and measurement

Tower recognises a provision when it has a present obligation as a result of a past event and it is more

likely than not that an outflow of resources will be required to settle the obligation. Tower's provision

represents the best estimate of the expenditure required to settle the present obligation at the end of

the reporting period.

ANNUAL REPORT 202474

Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

3 Investments and other income
Tower invests funds collected as premiums and provided by shareholders to ensure it can meet its

obligations to pay claims and expenses and to generate a return to support its profitability. Tower has

a low risk tolerance for investment and credit risk and therefore the majority of its investments are in

investment grade supranational and government bonds, and term deposits.

3.1 Investment income

2024

$000

2023

$000

Interest income17,767 12,871

Net realised gain1,626 1,173

Net unrealised gain2,407 583

Investment income 21,800 14,627

Recognition and measurement

Tower’s investment income is primarily made up of realised and unrealised interest income on fixed

interest investments and fair value gains or losses on its investment assets. Both are recognised in the

period that they are earned through profit or loss.

3.2 Investments

Tower designates its investments at fair value through profit or loss in accordance with its Treasury policy.

It categorises its investments into three levels based on the inputs available to measure fair value:

Level 1 Fair value is calculated using quoted prices in active markets. Tower currently does not have any

Level 1 investments.

Level 2 Investment valuations are based on direct or indirect observable data other than quoted prices

included in Level 1. Level 2 inputs include: (1) quoted prices for similar assets or liabilities;

(2) quoted prices for assets or liabilities that are not traded in an active market; or (3) other

observable market data that can be used for valuation purposes. Tower investments included

in this category include government and corporate debt, where the market is considered to be

lacking sufficient depth to be considered active, and part ownership of a property that is rented

out to staff.

Level 3 Investment valuation is based on unobservable market data. Tower currently does not have any

Level 3 investments..

LEVEL 1

$000

LEVEL 2

$000

LEVEL 3

$000

TOTAL

$000

As at 30 September 2024

Fixed interest investments– 367,472 – 367,472

Property investment– 34 – 34

Investments– 367,506 – 367,506

As at 30 September 2023

Fixed interest investments – 258,764 – 258,764

Property investment – 34 – 34

Investments – 258,798 – 258,798

There have been no transfers between levels of the fair value hierarchy during the current period (2023: nil).


ANNUAL REPORT 202475

Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

Recognition and measurement
Tower’s investment assets are designated at fair value through profit or loss. Investment assets are

initially recognised at fair value and are remeasured to fair value through profit or loss at each reporting

date. Tower's approach to measuring the fair value of these assets is covered above.

Purchases and sales of investments are recognised at the date which Tower commits to buy or sell

the assets (i.e. trade date). Investments are derecognised when the rights to receive future cash flows

from the assets have expired, or have been transferred, and substantially all the risks and rewards of

ownership have transferred.

3.3 Other income

2024

$000

2023

$000

Agency fees*1,705 3,574

Gain on disposal of property, plant and equipment30 1,243

Other2,329 910

Other income 4,064 5,727

* Agency fees include fees received for managing claims on behalf of the Natural Hazards Commission.

4 Risk Management

Tower is exposed to multiple risks as it works to set things right for its customers and their communities

whilst maximising returns for its shareholders. Everyone across the organisation is responsible for

ensuring that Tower's risks are managed and controlled on a day-to-day basis.

4.1 Risk management overview

Tower’s approach to achieving effective risk management is to embed a risk-aware culture where everyone

across the organisation (including contractors and third parties) is responsible for managing risk.

Tower’s Board expresses its appetite for risk in a Risk Appetite Statement, which:

(i) Gives clear concise guidance to management of parameters for risk taking.

(ii) Embeds risk management into strategic and decision-making processes.

(iii) Facilitates risk to be managed at all levels of the organisation through a structured process to identify

risk, and the allocation of clear, personal responsibility for management of identified risks by assigned

risk owners.

The Board then approves and adopts: (i) the Risk Management Framework (RMF) which is the central document

that explains how Tower effectively manages risk within the business; and (ii) the Reinsurance Management

Strategy (ReMS) which describes the systems, structures, and processes which collectively ensures Tower's

reinsurance arrangements and operations are prudently managed. These documents are approved annually

by the Board.

The Board has delegated its responsibility to the Risk Committee to provide oversight of risk management

practices and provide advice to the Board and management when required. In addition, the Risk Committee

also monitors the effectiveness of Tower’s risk management function which is overseen by the Chief Risk Officer

(CRO). The CRO provides regular reports to the Risk Committee on the operation of the RMF.

Tower has embedded the RMF with clear accountabilities and risk ownership to ensure that Tower identifies,

manages, mitigates and reports on all key risks and controls through the three lines of defence model.

(i) First line: Operational management has ownership, responsibility and accountability for directly identifying,

assessing, controlling and mitigating key risks which prevent them from achieving business objectives.

(ii) Second Line: Tower’s Risk, Advice and Assurance Function is responsible for developing and implementing

effective risk, compliance and conduct management processes; providing advisory support to the first

line of defence and constructively challenging operational management and risk and obligation owners to

ensure positive assurance.

3.2 Investments (continued)

ANNUAL REPORT 202476

Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

(iii) Third line: Internal Audit is responsible and accountable for providing an independent and objective view
of the adequacy and effectiveness of the Group’s risk management, governance and internal control

framework. Internal audit, along with other groups such as external audit, report independently to the

Board and/or the Audit Committee.

The RMF is supported by a suite of policies that address the risks and compliance obligations covered in

this section.

4.2 Strategic risk

Strategic risk is the risk that internal or external factors compromise Tower’s ability to execute its strategy or

achieve its strategic objectives. Strategic risk is managed through:

(i) Monitoring and managing performance against Board-approved plan and targets.

(ii) Board leading an annual strategy and planning process which considers our performance, competitor

positioning and strategic opportunities.

(iii) Identifying and managing emerging risks using established governance processes and forums.

4.3 Insurance risk

Insurance risk is the risk that for any class of risk insured, the present value of actual claims payable will exceed

the present value of actual premium revenues generated (net of reinsurance). This risk is inherent in Tower's

operations and arises and manifests through underwriting, insurance concentration and reserving risk.

a. Underwriting risk

Underwriting risk refers to the risk that claims arising are higher (or lower) than assumed in pricing due to bad

experience including catastrophes, weakness in controls over underwriting or portfolio management, or claims

management issues. Tower has established the following key controls to mitigate this risk:

(i) Use of comprehensive management information systems and actuarial models to price products based

on historical claims frequencies and claims severity averages, adjusted for inflation and modelled

catastrophes, trended forward to recognise anticipated changes in claims patterns after making allowance

for other costs incurred by the Group.

(ii) Passing elements of insurance risk to reinsurers. Tower's Board determines a maximum level of risk to be

retained by the Group as a whole. Tower's reinsurance programme is structured to adequately protect the

solvency and capital position of the insurance business. The adequacy of reinsurance cover is modelled by

assessing Tower's exposure under a range of scenarios.


The plausible scenario that has the most financial significance for Tower is a major earthquake. Each year,

as part of setting the coming year's reinsurance cover, comprehensive modelling of the event probability

and amount of the Group's exposure is undertaken.

(iii) Underwriting limits are in place to enforce appropriate risk selection criteria and pricing with specific

underwriting authorities that set clear parameters for the business acceptance.

Tower has not experienced significant changes in exposure to underwriting risk during the period, and no

significant changes to underwriting risk management have been implemented in the current period.

Refer to note 2.4a for exposure of underwriting risk at reporting date. Liability for incurred claims (LIC) is the

key component of insurance liability sensitive to possible changes in underwriting risk, and we have performed

sensitivity analysis over all variables that could reasonably change and impact the measurement of LIC in

note 2.4f.

b. Concentration risk

Concentration risk refers to the risk of underwriting a number of like risks, where the same or similar loss events

have the potential to produce claims from many of Tower's customers at the same time. Tower is particularly

subject to concentration risks in the following variety of forms:

(i) Geographic concentration risk – Tower purchases a catastrophe reinsurance programme to protect against

a modelled 1-in-1000 years whole of portfolio catastrophe loss.

(ii) Product concentration risk - Tower's business is weighted towards the NZ general insurance market where its

risks are concentrated in house insurance (Home & Contents) and motor insurance. Tower limits its exposure

through proportional reinsurance arrangements, where Tower transfers its exposure on any single insured

asset (for example, a house) above a set amount, in exchange for ceding portion of the premium to reinsurers.

Tower has not experienced significant changes in exposure to concentration risk during the period, and no

significant changes to concentration risk management have been implemented in the current period.

The following table illustrates the diversity of Tower’s operations.

4.1 Risk management overview (continued)

ANNUAL REPORT 202477

Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

% of Insurance Revenue
20242023

NZPACIFIC*TOTALNZPACIFIC*TOTAL

Home38%2%40%37%3%40%

Contents14%0%14%14%0%14%

Motor38%2%40%37%3%40%

Other3%3%6%3%3%6%

Total93%7%100%91%9%100%

* The Pacific operating segment excludes the disposal groups.

c. Reserving risk

Reserving risk is managed through the actuarial valuation of insurance liabilities and monitoring of the

probability of adequacy booked reserves. The valuation of the liability for incurred claims is performed by

qualified and experienced actuaries. The liability for incurred claims is subject to a comprehensive review at

least annually.

Tower has not experienced significant changes in exposure to reserving risk, and no significant changes to

reserving risk management have been implemented in the current period.

Refer to note 2.4a for exposure of reserving risk at reporting date. Liability for incurred claims (LIC) is the key

component of insurance liability sensitive to possible changes in reserving risk, and we have performed

sensitivity analysis over all variables that could reasonably change and impact the measurement of LIC in

note 2.4f.

4.3 Insurance risk (continued)4.4 Credit risk

Credit risk is the risk of loss that arises when a counterparty fails to meet their financial obligations to Tower

in accordance with the agreed terms. Tower's exposure to credit risk primarily results from transactions with

security issuers, reinsurers and policyholders and is set out below.

a. Investment and treasury

Tower manages its investment and treasury credit risks in line with limits set by the Board:

(i) New Zealand cash deposits that are internally managed are limited to banks with a minimum Standard &

Poor’s (S&P) AA- credit rating.

(ii) Cash deposits and investments that are managed by external investment managers are limited to

counterparties with a minimum S&P A- credit rating.

(iii) Tower holds deposits and invests in Pacific regional investment markets through its Pacific Island

operations to comply with local statutory requirements and in accordance with Tower investment policies.

These deposits and investments generally have low credit ratings representing the majority of the value

included in the 'Below BBB' and 'not rated' categories in the table below. This includes deposits and

investments with Australian bank subsidiaries that comprise 33% (2023: 45%) of the 'not rated' category.

CASH AND CASH EQUIVALENTSFIXED INTEREST INVESTMENTSTOTAL

2024

$000

2023

$000

2024

$000

2023

$000

2024

$000

2023

$000

AAA–– 121,497 104,646 121,497 104,646

AA62,106 47,992 188,655 113,971 250,761 161,963

A–– 55,240 38,137 55,240 38,137

Below BBB 10,466 11,917 1,948 1,322 12,414 13,239

Not rated2,818 4,100 166 722 2,984 4,822

Total 75,390 64,009 367,506 258,798 442,896 322,807

ANNUAL REPORT 202478

Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

b. Reinsurance
Tower manages its reinsurance programme in line with the ReMS. Tower seeks to manage the quantum and

volatility of insurance risk in order to reduce exposure and overall cost.

Tower's policy is to only deal with reinsurers with a credit rating of S&P A- or better unless local statutory

requirements dictate otherwise. Additional requirements of the policy are for no individual reinsurer to have

more than 25% share of the overall programme and Tower is prohibited from offering inwards reinsurance to

external entities.

Tower has not experienced significant changes in exposure to reinsurance risk during the period, and no

significant changes to reinsurance risk management have been implemented in the current period.

REINSURANCE AIC

2024

$000

2023

$000

AA 34,592 80,489

A 11,768 70,862

BBB– 9

Below BBB 70 81

Not rated 763 24

Total 47,193 151,465

4.4 Credit risk (continued)

Tower's receivables for insurance contracts primarily relates to policies which are paid on either a fortnightly or

monthly basis. Payment default or policy cancellation - subject to the terms of the policyholder's contract - will

result in the termination of the insurance contract eliminating both the credit risk and the insurance risk.

The following table provides details on Tower's maximum exposure to credit risk for insurance contracts and

other receivables:

PAST DUE

NOT DUE*

$000

1 MONTH

$000

1 TO 2

MONTHS

$000

2 TO 3

MONTHS

$000

OVER 3

MONTHS

$000

TOTAL

$000

As at 30 September 2024

Net premiums receivable 270,422 4,559 1,665 683 257 277,586

Other receivables 5,830 –––– 5,830

As at 30 September 2023

Net premium receivable 237,736 4,375 270 844 50 243,275

Other receivables 11,036 – – – – 11,036

* This includes premiums that are less than 30 days outstanding (which are owed but not past due) of $5.2m (2023: $4.3m).

The remaining balance is related to the provision of future insurance services to customers.

c. Insurance and other credit risk

ANNUAL REPORT 202479

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Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

4.5 Market risk
Market risk is the risk of adverse impacts on investment earnings resulting from changes in market factors.

Tower's market risk is predominately as a result of changes in the value of the New Zealand dollar (currency

risk) and interest rate movements. Tower's approach to managing market risk is underpinned by its Treasury

Policy as approved by the Board.

a. Currency risk

Tower's currency exposure arises from the translation of foreign operations into Tower's functional currency

(currency translation risk) or due to transactions denominated in a currency other than the functional currency

of a controlled entity (operational currency risk). The currencies giving rise to this risk are primarily the US dollar,

Fijian dollar and Papua New Guinea (PNG) Kina.

Tower's principal currency risk is currency translation (where movement impacts equity). Tower generally elects

not to hedge this risk as it is difficult given the size and nature of the currency markets in the Pacific. Tower

seeks to minimise its net exposure to foreign operational risk by actively seeking to return surplus cash and

capital to the parent company.

Operational currency risk impacts profit and generally arises from:

(i) Procurement of goods and services denominated in foreign currencies. Tower may enter into hedges for

future transactions, using authorised instruments, provided that the timing and amount of those future

transactions can be estimated with a reasonable degree of certainty.

(ii) Investment assets managed by the external investment manager that are denominated in foreign

currencies. Tower's Board set limits for the management of currency risk based on prudent asset

management practice. Regular reviews are conducted to ensure that these limits are adhered to.

Tower has not experienced significant changes in exposure to currency risk during the period, and no

significant changes to currency risk management have been implemented in the current period.

The following table demonstrates the impact of the New Zealand dollar weakening or strengthening against

the most significant currencies for which Tower has foreign exchange exposure before tax, holding all other

variables constant.

DIRECT IMPACT ON

EQUITY THROUGH CURRENCY

TRANSLATION RESERVEIMPACT ON PROFIT OR (LOSS)

2024

$000

2023

$000

2024

$000

2023

$000

New Zealand Dollar - USD

Currency strengthens by 10%(619)(1,025)905 1,378

Currency weakens by 10%7561,253 (1,106)(1,684)

New Zealand Dollar - Fijian Dollar

Currency strengthens by 10%(1,182)(887)(8)(74)

Currency weakens by 10%1,4451,084 9 91

New Zealand Dollar - PNG Kina

Currency strengthens by 10%––(674)(805)

Currency weakens by 10%– – 822 984

The impact on profit or loss for New Zealand Dollar - USD in the 2023 comparative has been updated for

consistency with 2024 sensitivity.

ANNUAL REPORT 202480

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b. Interest rate risk
Tower is exposed to interest rate risk through its holdings in interest-bearing assets. Interest-bearing assets

with a floating interest rate expose Tower to cash flow interest rate risk, whereas fixed interest investments

expose Tower to fair value interest rate risk.

Tower's interest rate risk primarily arises from fluctuations in the valuation of fixed-interest investments

recognised at fair value and from the underwriting of general insurance contracts, which have interest rate

exposure due to the use of discount rates in calculating the value of insurance liabilities.

Fixed-interest investments are measured at fair value through profit or loss. Movements in interest rates impact

the fair value of interest-bearing financial assets and therefore impact profit or loss (there is no direct impact

on equity). The impact of a 1% increase or decrease in interest rates on fixed interest investments, after tax, is

shown below (holding everything else constant).

IMPACT ON PROFIT OR (LOSS)

2024

$000

2023

$000

Interest rates increase by 1% (1,287)(1,652)

Interest rates decrease by 1%1,2671,726

Tower manages its interest rate risk through Board-approved investment management guidelines that give regard

to policyholder expectations and risks, and to target surplus for solvency as advised by the Appointed Actuary.

Tower has not experienced significant changes in exposure to interest rate risk during the period, and no significant

changes to interest rate risk management have been implemented in the current period.


4.5 Market risk (continued)4.6 Liquidity risk

Liquidity risk arises where liabilities cannot be met as they fall due as a result of insufficient funds and/or

illiquid asset portfolios. Tower mitigates this risk through maintaining sufficient liquid assets to ensure that it can

meet all obligations on a timely basis.

Tower is primarily exposed to liquidity risk through its obligations to make payment for claims of unknown

amounts on unknown dates. Fixed-interest investments can generally be readily sold or exchanged for cash to

settle claims and are managed in accordance with the policy of broadly matching the overall maturity profile to

the estimated pattern of claim payments.

Tower has not experienced significant changes in exposure to liquidity risk during the period, and no significant

changes to liquidity risk management have been implemented in the current period.

The following table presents the estimated amount and timing of the remaining contractual discounted cash

flows arising from investment assets and insurance liabilities.

LIABILITY FOR INCURRED CLAIMSCASH AND INVESTMENTS

2024

$000

2023

$000

2024

$000

2023

$000

Floating interest rate (at call) - - 75,446 89,909

Within 3 months 62,412 105,702 124,629 28,682

3 to 6 months 25,556 44,944 46,598 30,231

6 to 12 months 22,201 40,147 81,257 61,661

1 to 2 years 14,623 29,066 48,178 29,977

2 to 3 years 5,083 10,102 19,025 47,145

3 to 4 years 4,471 8,886 19,671 8,663

4 to 5 years 616 1,225 13,977 12,435

5+ years 565 1,123 14,115 14,104

Total 135,527 241,195 442,896 322,807

ANNUAL REPORT 202481

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4.7 Capital management risk
Capital risk is the risk that capital is insufficient or not of the best form to provide a buffer against losses arising

from unanticipated events, while also maximising the efficient use of capital with a view to enhancing growth

and returns, and adding long-term value to Tower's shareholders.

Tower has a documented description of its capital management process which sets out Tower's principles,

approaches, and processes in relation to capital management that enables it to operate at an appropriate level

of target solvency capital which is within the bounds of Tower's risk appetite.

The capital management process allows the Board, management, rating agencies and the regulator to

understand Tower's approach to capital management, including requirements for formulating capital targets,

and monitoring, reporting and remediating capital as required.

The operation of the capital management process is reported annually to the Board together with a forward-

looking estimate of expected capital utilisation and capital resilience. In addition, Tower carries out stress,

reverse stress and scenario testing to ensure the level of capital is appropriate given its risk appetite.

a. Regulatory solvency capital

The Reserve Bank of New Zealand (RBNZ) is the prudential regulator and supervisor of all insurers carrying on

insurance business in New Zealand, and is responsible for administering the Insurance (Prudential Supervision)

Act 2010. Tower measures the adequacy of capital against the Solvency Standards published by the RBNZ

alongside additional capital held to meet RBNZ minimum requirements and any further capital as determined

by the Board.

Foreign operations are subject to regulatory oversight in the relevant jurisdiction. It is Tower's policy to ensure

that each of the licenced insurers in the Group maintain an adequate capital position within the requirements of

the relevant regulator.

During the year ended 30 September 2024 the Group complied with all externally imposed capital

requirements (2023: complied).

Tower has applied the RBNZ’s new Interim Solvency Standard (ISS) from 1 October 2023.

Tower has calculated the below solvency position in accordance with the current published ISS. This is the

mandatory regulatory solvency position required until any amendments are issued and effective. A second

amendment to the ISS is proposed by RBNZ and is not expected to be issued and effective until 1 March 2025.


2024

$000

2023

$000

PREPARED UNDER ISSPREPARED UNDER NLSS

PARENTGROUPPARENTGROUP

Solvency capital (2023: Actual

solvency capital) 323,834 339,139 145,421 174,734

Adjusted prescribed capital

requirement (2023: Minimum

solvency capital) 152,474 148,547 91,634 99,729

Adjusted solvency margin

(2023: Solvency margin) 171,360 190,592 53,787 75,005

Adjusted solvency ratio

(2023: Solvency ratio)212%228%159%175%

Tower is required to maintain a solvency margin of at least $0m (2023: $15m), due to a license condition issued

by the RBNZ.

The 30 September 2023 comparative is per the prior period audited financial statements in accordance with

the RBNZ's Non-Life Solvency Standard (NLSS) which was applicable until 30 September 2023.

b. Financial strength rating

Tower Limited has an insurer financial strength rating of "A- (Excellent)" and a long-term issuer credit rating of

"a-" as affirmed by international rating agency AM Best Company Inc. in April 2024.

ANNUAL REPORT 202482

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Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

4.8 Operational risk
Operational risk is the risk of loss due to inadequate or failed internal processes or systems, human error or

from external events.

Tower's approach is to proactively manage our operational risks to mitigate potential customer detriment,

regulatory or legal censure, financial and reputational impacts.

Tower has in place appropriate operational processes and systems, including prevention and detection

measures. These include processes which seek to ensure Tower can absorb and/or adapt to internal or

external occurrences that could disrupt business operations.

Management and staff are responsible for identifying, assessing, recording and managing operational risks

in accordance with their roles and responsibilities. Associated controls for identified risks are recorded and

then actively monitored and managed through our enterprise risk management system (ERMS). Incidents are

managed by the first line of defence and overseen by the second line of defence, with ongoing reporting to

management and the Board Risk Committee.

Tower also maintains and regularly updates its Crisis Management, Business Continuity and Disaster Recovery

Plans to minimise the impact of material incidents or crisis events and to support continuity of critical systems

and processes.

4.9 Regulatory and compliance risk

Regulatory and compliance risk is defined as the risk of legal, regulatory or reputational impacts arising

from failure to manage compliance obligations, or failure to anticipate and prepare for changes in the

regulatory environment.

Tower, via its ERMS, has in place an obligations management framework. The framework provides operational

and managerial oversight of applicable and relevant regulatory compliance obligations to Tower and supports

Tower in discharging its obligations under legislation across NZ & the Pacific.

Tower engages with regulators and regularly monitors developments in regulatory requirements to support

ongoing compliance.

4.10 Conduct risk

Conduct risk is defined as the risk of not meeting customers' reasonable expectations.

Tower manages Conduct risk through a number of measures including undertaking ongoing product reviews

to ensure products are delivering good customer outcomes, reviewing customer feedback to identify conduct

trends or issues, completing quality assurance reviews, managing vulnerable customers, holding workshops

with frontline staff to identify potential conduct issues and embedding and monitoring controls across the

business to deliver fair customer outcomes.

Tower's approach to managing conduct risk is set out in its Conduct Governance Framework. The framework

is a collation of policies, frameworks and processes and ensures there's robust governance in place to oversee

Tower's conduct risk profile including reporting to the Management and Board Committees. From 31 March

2025, this framework will be superseded by Towers Fair Conduct Programme, developed in accordance with

requirements in the Financial Markets (Conduct of Institutions) Amendment Act 2022.

4.11 Cyber risk

Cyber risk is any risk associated with financial loss, disruption or damage to the reputation of Tower resulting

from either the failure, or unauthorised or erroneous use of its information systems.

Tower’s approach to Cyber risk is to proactively protect against, monitor for and respond to those cyber threats

seen to be targeting the organisation. Tower continues to monitor evolving key cyber risks, which are discussed

and reviewed on a monthly basis through our Management Risk and Conduct Committee and on a quarterly

basis with the Risk Committee. Risk mitigation is achieved through ongoing investment in Tower’s security

programme and Tower’s dedicated security function.

ANNUAL REPORT 202483

Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

4.12 Environment, Social and Governance (ESG) risk
Tower Limited’s ESG risks and opportunities are identified and prioritized through our Materiality Assessment

and Risk Management Framework (RMF). They form the basis for Tower’s Sustainability Framework and include

climate-related risk outlined below.

a. Climate-related risk

Climate- related risk relates to the physical and transitional impacts of climate change. Physical risks are

associated with an increasing frequency and severity of severe weather events, sea level rise and coastal

inundation. Transitional risks are related to potential social, political and economic changes as New Zealand

and the world transition to low emission and climate resilient economies.

As a listed, licensed New Zealand insurer Tower qualifies as a climate reporting entity (CRE) under the Financial

Markets Conduct Act 2013 and the Aotearoa New Zealand Climate Standards (NZ CS 1, NZ CS 2 and NZ CS 3)

published by the XRB in December 2022 (CRD Regime). Our first group climate statement has been prepared

alongside our financial statements and annual report, and Tower will make these disclosures available on

Tower’s website, the New Zealand Stock Exchange (NZX) and Australian Stock Exchange (ASX). The climate

statement covers our New Zealand and Pacific operations and outlines the steps we are taking to address

climate-related risks and opportunities.

Tower’s RMF considers climate-related risks, which are regularly reported to the Board. Tower's approach to

managing climate-related risk includes continuing to expand our risk-based pricing strategy for climate-related

hazards, maintaining a robust reinsurance programme to provide protection from volatility in weather events,

planning for increasing large events over time in our budget process to limit financial impacts, and supporting

communities through climate change via product development.

Other than the impact on liability for incurred claims, Tower considers that climate change risk does not

materially impact the valuation of Tower's assets and liabilities, where these assets or liabilities are expected to

be realised in one year or less. For non-current assets, Tower has looked to its short-medium term forecasting,

which implicitly includes allowances for the risk of climate change in forecasts of the severity and frequency

of future claims, including large events. These forecasts show continued profitability for Tower, which supports

the carrying value of non-current assets. Accordingly, Tower does not consider that climate change risk has a

material impact on the assets and liabilities recorded in these financial statements, as at 30 September 2024.


5 Capital Structure

This section provides information about how Tower finances its operations through equity. Tower's capital

position provides financial security to its customers, employees and other stakeholders whilst operating

within the capital requirements set by regulators.

5.1 Contributed equity

NOTE

2024

$000

2023

$000

Opening balance460,315 460,191

Share rights issued under Tower Long-Term Incentive Plan8.5419 124

Total contributed equity460,734 460,315

Represented by:

Opening balance379,483,987 379,483,987

Total shares on issue379,483,987 379,483,987

Ordinary shares issued by the Company are classified as equity and are recognised at fair value less direct issue

costs. All shares rank equally with one vote attached to each share. There is no par value for each share.

On 9 September 2024, the Board approved $45m capital return by way of a compulsory share buyback.

The capital return remains conditional on shareholder approval at Tower’s Annual Shareholder Meeting in

early 2025; the receipt of High Court approval of the arrangement; Tower continuing to satisfy solvency and

prudential capital requirements and the Tower Board remaining satisfied that the capital return is prudent to

undertake. Subject to these conditions being fulfilled, the capital return is likely to occur in March 2025.

ANNUAL REPORT 202484

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5.2 Reserves
2024

$000

2023

$000

Opening balance(3,098)(2,148)

Currency translation differences arising during the year(898)(950)

Foreign currency translation reserve(3,996)(3,098)

Opening balance – 1,707

Revaluation surplus transferred to retained earnings – (1,707)

Asset revaluation reserve – –

Capital reserve11,990 11,990

Separation reserve*(113,000)(113,000)

Reserves(105,006)(104,108)

* The separation reserve was created in 2007 at the time of the demerger of the New Zealand and Australian businesses in

accordance with a ruling provided by the Australian Tax Office (ATO). It will be carried forward indefinitely as a non-equity reserve

to meet the requirements of the ATO.

Recognition and measurement

The assets and liabilities of entities whose functional currency is not the New Zealand dollar are

translated at the exchange rates ruling at reporting date. Income and expense items are translated at a

weighted average of exchange rates over the period approximating spot rates at the transaction dates.

Exchange rate differences are taken to the foreign currency translation reserve.

Tower's land and buildings are valued at fair value less accumulated depreciation. Any surplus on

revaluation of these items is transferred directly to the asset revaluation reserve unless it offsets a

previous decrease in value recognised in profit or loss in which case it is recognised in the consolidated

statement of comprehensive income.

5.3 Net tangible assets per share

2024

CENTS

2023

CENTS

Net tangible assets per share73 48

Net tangible assets per share have been calculated using the net assets as per the balance sheet adjusted for

intangible assets (including goodwill) and deferred tax divided by total shares on issue.

5.4 Earnings per share

20242023

Profit from continuing operations attributable to shareholders

($ thousands)

70,884 2,587

Profit/(loss) from discontinued operations attributable to shareholders

($ thousands)

3,401 (3,609)

Total profit/(loss) attributable to shareholders ($ thousands)74,285 (1,022)

Weighted average number of ordinary shares for basic earnings

per share (number of shares)

379,483,987 379,483,987

Basic earnings per share (cents) for continuing operations18.7 0.7

Basic earnings per share (cents)19.6 (0.3)

The basic average numbers of ordinary shares shown above are used for calculating all earnings per share

measures including those for profit after tax from discontinued operations (note 8.4).

Tower has assessed if the future potential instruments have a dilutive impact on earnings. The long-term

incentive plan will not have a dilutive impact on earnings because shares are not expected to be issued, rather

purchased from the market.

5.5 Dividends

On 27 June 2024, Tower paid an interim dividend of 3.0 cents per share, totalling $11.4m .

On 28 November 2024, the Board approved a final dividend of 6.5 cents per share, with the dividend being

payable on 30 January 2025 for approximately $24.7m.

No dividends were paid during 2024 in respect of the 2023 financial year.

ANNUAL REPORT 202485

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6 Other balance sheet items
This section provides information about assets and liabilities not included elsewhere.

6.1 Property, plant and equipment

30 September 2024

OFFICE

EQUIPMENT &

FURNITURE

$000

MOTOR

VEHICLES

$000

COMPUTER

EQUIPMENT

$000

TOTAL

$000

Composition:

Cost7,261 1,524 4,646 13,431

Accumulated depreciation(2,491)(1,198)(3,007)(6,696)

Property, plant and equipment4,770 326 1,639 6,735

Reconciliation:

Opening balance4,123 608 1,549 6,280

Depreciation(623)(241)(1,002)(1,866)

Additions1,360 33 1,092 2,485

Disposals(1)(26) – (27)

Foreign exchange movements(89)(48) – (137)

Closing Balance4,770 326 1,639 6,735


30 September 2023

OFFICE

EQUIPMENT &

FURNITURE

$000

MOTOR

VEHICLES

$000

COMPUTER

EQUIPMENT

$000

TOTAL

$000

Composition:

Cost6,052 1,702 3,587 11,341

Accumulated depreciation(1,929)(1,094)(2,038)(5,061)

Property, plant and equipment4,123 608 1,549 6,280

Reconciliation:

Opening balance2,244 970 2,203 5,417

Depreciation(496)(316)(1,102)(1,914)

Additions2,489 – 480 2,969

Disposals(71) – (16)(87)

Foreign exchange movements14 (18)(10)(14)

Assets reclassified as held for sale*(57)(28)(6)(91)

Closing Balance4,123 608 1,549 6,280

* Assets reclassified as held for sale include the assets of discontinued operations. Refer to note 8.4.

Recognition and measurement

Property, plant and equipment (PPE) is initially recorded at cost including transaction costs and

subsequently measured at cost less any accumulated depreciation and impairment losses.

Depreciation is calculated using the straight line method to allocate the asset's cost or revalued

amounts, net of any residual amounts, over their useful lives. The assets' useful lives are reviewed and

adjusted if appropriate at each reporting date. An asset's carrying amount is written down immediately to

its recoverable amount if it is considered that the carrying amount is greater than its recoverable amount.

Furniture & fittings 5-9 years

Leasehold property improvements 3-12 years

Motor vehicles 5 years

Computer equipment 3-5 years

ANNUAL REPORT 202486

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6.2 Intangible assets
a. Amounts recognised in the balance sheet

30 September 2024

GOODWILL

$000

SOFTWARE AND

WORK IN PROGRESS

$000

CUSTOMER

RELATIONSHIPS

$000

TOTAL

$000

Composition:

Cost17,744 107,977 40,674 166,395

Accumulated amortisation – (47,122)(22,652)(69,774)

Intangible Assets17,744 60,855 18,022 96,621

Reconciliation:

Opening balance17,744 57,326 23,454 98,524

Amortisation – (13,837)(5,432)(19,269)

Additions* – 18,392 – 18,392

Disposals – (47) – (47)

Transfers to property,

plant and equipment

– (979) – (979)

Closing Balance17,744 60,855 18,022 96,621

* During the year ended 30 September 2024, additions to software assets primarily related to continued investment in Tower’s core

insurance platform and website, and digitisation of claims processes. Total software additions in the year ended 30 September

2024 includes $10.8m (2023: $9.6m) of internally generated assets.


30 September 2023

GOODWILL

$000

SOFTWARE AND

WORK IN PROGRESS

$000

CUSTOMER

RELATIONSHIPS

$000

TOTAL

$000

Composition:

Cost17,744 94,215 40,645 152,604

Accumulated amortisation – (36,889)(17,191)(54,080)

Intangible Assets17,744 57,326 23,454 98,524

Reconciliation:

Opening balance17,744 53,458 23,451 94,653

Amortisation – (11,430)(5,897)(17,327)

Additions* – 17,526 5,900 23,426

Disposals – (256) – (256)

Transfers to property,

plant and equipment

– (1,972) – (1,972)

Closing Balance17,74457,32623,45498,524

* During the year ended 30 September 2023, additions to software assets primarily related to continued investment in Tower’s

core insurance platform, while additions to customer relationships related to the acquisition of Kiwibank’s rights and obligations

relating to servicing a portfolio of insurance policies underwritten by Tower.

ANNUAL REPORT 202487

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Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

Recognition and measurement
Intangible assets are assets without physical substance. They are recognised as an asset if it is probable

that expected future economic benefits attributable to the asset will flow to Tower and that costs can be

measured reliably.

Application software and customer relationships are recorded at cost less accumulated amortisation and

impairment. Application software is amortised on a straight line basis over the estimated useful life of

the software. Customer relationships are amortised over the estimated useful life in accordance with the

pattern of economic benefit consumption.

Internally generated intangible assets are recorded at cost which comprise all directly attributable costs

necessary to create, produce and prepare the asset to be capable of operating in the manner intended

by management. Amortisation of internally generated intangible assets begins when the asset is

available for use and is amortised on a straight line basis over the estimated useful life.

The useful lives for each category of intangible assets with a finite life are as follows:

- capitalised software: 3-5 years for general use computer software and 3-10 years for core operating

system software

- customer relationships: 5-10 years

Goodwill (i.e. assets with an indefinite useful life) generated as a result of business acquisition is initially

measured as the excess of the purchase consideration over the fair value of the net identifiable assets

and liabilities acquired. Goodwill is not subject to amortisation but is tested for impairment annually or

more frequently where there are indicators of impairment.

Critical accounting estimates and judgements

The customer relationships asset predominantly consists of customer relationship assets with a useful

life equivalent to the customer base’s expected lifespan of ten years with the exception of one asset

(acquired in 2021) with an additional non-compete component that has a contracted useful life of

five years.

Where applicable the estimated capitalised cost related to the customer relationships asset has been

apportioned between the two asset components by valuing the non-compete at the differential in net

present value of the asset from improved customer retention over the non-compete period, pro-rated

over the full asset value.

b. Impairment testing

An impairment charge is recognised in profit or loss when the carrying value of the asset, or cash-generating

unit (CGU), exceeds the calculated recoverable amount.

(i) Software and customer relationships

Software and customer relationships are reviewed at each reporting date by determining whether there is an

indication that the carrying values may be impaired. If an indication exists, the asset is tested for impairment. A

loss is recognised for the amount by which the carrying value exceeds the asset's recoverable value.

There were no indications of impairment during the year and therefore these assets were not tested for

impairment (2023: no indications).

6.2 Intangible assets (continued)

a. Amounts recognised in the balance sheet (continued)

ANNUAL REPORT 202488

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(ii) Goodwill
Goodwill is deemed to have an indefinite useful life and is tested annually for impairment or more frequently

where there is an indication that the carrying value may not be recoverable.

Goodwill is allocated to cash generating units (CGUs) expected from synergies arising from the acquisition

giving rise to goodwill. Tower's goodwill is allocated to the New Zealand general insurance CGU.

Tower undertook an annual impairment review and no impairment has been recognised as a result (2023: nil).

Critical accounting estimates and judgements

The recoverable amount of the New Zealand general insurance business is assessed by determining

its value in use by discounting the future cash flows generated from the continuing use of the CGU .

A discount rate of 11.9% was used in the calculation (2023: 13.1%). The cash flows are based on Board-

approved management plans and forecasted profits for FY25 - FY27 (2023: FY24 - FY26). The projected

cash flows are determined based on past performance and management's expectations for market

developments with a terminal growth rate of 2.5% (2023: 2.5%).

The overall valuation is sensitive to a range of assumptions including management's forecasted profits,

the discount rate and the terminal growth rate. Reasonable changes to these assumptions will not result

in an impairment.

6.2 Intangible assets (continued)

b. Impairment testing (continued)

6.3 Leases

a. Amounts recognised in the balance sheet

(i) Right-of-use assets

OFFICE SPACE

2024

$000

2023

$000

Composition:

Cost29,814 30,267

Accumulated depreciation(9,824)(7,063)

Right-of-use assets19,990 23,204

Reconciliation:

Opening balance23,204 23,326

Depreciation(4,096)(4,209)

Additions65 4,162

Disposals(89) –

Revaluations518 (204)

Net foreign exchange movements388 239

Assets reclassified as held for sale – (110)

Right-of-use assets19,990 23,204

Recognition and measurement

Right-of-use assets are recognised when Tower has the right to use the corresponding assets. Right-

of-use assets are measured at cost comprising the initial measurement of the lease liability adjusted for

any lease payments made at or before the commencement date less any lease incentives received; and

indirect costs; and restoration costs. Right-of-use assets are generally depreciated over the shorter of the

asset's useful life and the lease term on a straight line basis.

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Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

a. Amounts recognised in the balance sheet (continued)
(ii) Lease liabilities

2024

$000

2023

$000

Composition:

Current4,909 5,477

Non-current23,946 27,138

Lease liabilities28,855 32,615

Due within 1 year4,909 5,477

Due within 1 to 2 years4,782 5,921

Due within 2 to 5 years13,309 12,483

Due after 5 years8,114 11,865

Discount(2,259)(3,131)

Lease liabilities28,855 32,615

Recognition and measurement

Lease liabilities are recognised at the date Tower has the right to use the corresponding asset.

Lease liabilities are initially measured as the present value of expected lease payments under lease

arrangements. Lease liability will include any option to extend where it is reasonably certain that the

option will be exercised. The lease payments are discounted using the incremental borrowing rate as

the interest rate in the lease cannot be readily determined. The incremental borrowing rate is the rate

of interest that Tower would have to pay to borrow over a similar term, and with a similar security, the

funds necessary to obtain an asset of a similar value to the right-of-use asset in a similar economic

environment. Tower's incremental borrowing rate is based on bonds issued by financial institutions

with similar credit rating and maturity profile. Incremental borrowing rates used during the year ranged

between 1.9% and 5.9% (2023: between 1.9% and 5.0%).

Subsequent repayments are split between principal and interest cost where the finance cost represents

the time value of money and is charged to the profit or loss over the lease period. The discount rate

applied is unchanged from that applied at the initial recognition of the lease, unless there are material

changes to the lease.

6.3 Leases (continued)

b. Amounts recognised in the consolidated statement of comprehensive income

CLASSIFICATION

2024

$000

2023

$000

Depreciation and impairmentInsurance service expense(4,096)(4,027)

Interest expenseFinance costs(882)(920)

Lease expense(4,978)(4,947)

c. Amounts recognised in the consolidated statement of cash flows

2024

$000

2023

$000

Total cash outflow for lease principal payments(5,064)(6,980)

ANNUAL REPORT 202490

Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

7 Tax
This section provides information on Tower's tax expense during the year and its position at reporting date.

7.1 Tax expense

Composition

2024

$000

RESTATED

2023

$000

Current tax 2,948 2,525

Deferred tax29,274 (419)

Adjustments in respect of prior years11 1,152

Tax expense32,233 3,258

Tax expense from continuing operations31,774 5,176

Tax expense/(benefit) from discontinued operations459 (1,918)

Reconciliation of prima facie tax to income tax expense

2024

$000

RESTATED

2023

$000

Profit before tax from continuing operations102,658 7,763

Profit/(loss) before tax from discontinued operations3,860 (5,527)

Profit before taxation 106,518 2,236

Prima facie tax expense at 28% (2023: 28%)29,825 626

Adjustments in respect of prior years11 1,152

Tax effect of non-deductible expenses and non-taxable

income

1,641 679

Foreign tax credits written off218 492

Other538 309

Tax expense32,233 3,258

Recognition and measurement

Tax expense is calculated on the basis of the applicable tax rates that have been enacted or

substantively enacted at the end of the reporting period in the jurisdictions Tower operates in. There

have been no tax rate changes during the year in these jurisdictions. Current tax expense relates to tax

payable for the current financial reporting period while deferred tax will be payable in future periods.

7.2 Current tax

a. Current tax asset

2024

$000

RESTATED

2023

$000

Excess tax payments related to prior periods*11,76612,038

Excess tax payments/tax payable related to current period**1,456879

Current tax asset13,22212,917

* Expected to be recovered from 2025 as per the Board-approved operational plan for 2025 to 2027.

** Excess tax payment made in the Pacific Islands during the reporting period.

b. Current tax liability

The current tax liabilities balance of $606k (2023: $198k) relates to taxes payable to offshore tax authorities in

the Pacific Islands.

Recognition and measurement

Overpayment of tax in the current and prior periods is recognised as a current tax asset. Current tax

assets are measured at the amount expected to be recovered from the tax authorities, using the tax rates

and tax laws that have been enacted or substantively enacted by the end of the reporting period.

ANNUAL REPORT 202491

Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

7.3 Deferred tax
a. Deferred tax asset

Composition

2024

$000

RESTATED

2023

$000

Tax losses recognised1,079 29,411

IFRS 17 restatements, software, PPE and other1,041 1,165

Leases8,080 9,166

Provisions and accruals3,828 3,206

Recognised in profit or loss14,028 42,948

Impact through other comprehensive income – –

Recognised in comprehensive profit or loss14,028 42,948

Set-off of deferred tax liabilities pursuant to NZ IAS 12(13,646)(26,830)

Deferred tax asset382 16,118

Deferred tax asset from continuing operations382 16,074

Deferred tax asset from discontinued operations – 44

Reconciliation of movements

2024

$000

RESTATED

2023

$000

Opening balance42,948 31,315

Movements recognised in profit or loss(28,920)11,633

Deferred tax asset pre NZ IAS 12 set off14,028 42,948

b. Deferred tax liability

Composition

2024

$000

RESTATED

2023

$000

Insurance acquisition cash flows(9,211)(7,848)

Customer relationships(4,002)(5,001)

Software, property, plant and equipment(6,079)(5,447)

Leases(7,362)(8,664)

Other*(708)(48)

Recognised in profit or loss(27,362)(27,008)

Set-off of deferred tax liabilities pursuant to NZ IAS 1213,646 26,830

Deferred tax liability(13,716)(178)

* Primarily relates to deferred tax items in the Pacific islands.

Reconciliation of movements

2024

$000

RESTATED

2023

$000

Opening balance(27,008)(16,084)

Movements recognised in other comprehensive income – 290

Movements recognised in profit or loss(354)(11,214)

Deferred tax liability pre NZ IAS 12 set off(27,362)(27,008)

ANNUAL REPORT 202492

Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

Recognition and measurement
Deferred tax is income tax which is expected to be payable or recoverable in the future as a result of

the unwinding of temporary differences. These arise from differences in the recognition of assets and

liabilities for financial reporting and from the filing of income tax returns. Deferred tax is recognised on all

temporary differences, other than those arising from (i) goodwill or (ii) from the initial recognition of assets

and liabilities in a transaction (other than in a business combination) that affects neither the accounting

nor taxable profit or loss.

At the reporting date, the Group has recognised deferred tax assets in respect of its unused tax losses of

$3.8m (2023: $105.0m).

Deferred tax is calculated at the tax rates that are expected to apply to the year when the liability is

settled or the asset realised, based on tax rates and tax laws that have been enacted or substantively

enacted at reporting date.

Deferred tax assets and liabilities are offset when there is a legally enforceable right to set off current

tax assets against current tax liabilities and when they relate to income taxes levied by the same tax

authority and the Group intends to settle its current tax assets and liabilities on a net basis.

Critical accounting estimates and judgements

Deferred tax assets are recognised for all unused tax losses to the extent it is probable that taxable

profits will be available against which the losses can be utilised. Significant management judgement

is required to determine the amount of deferred tax assets that can be recognised based on the likely

timing and quantum of future taxable profits. Management expects the tax losses to be utilised within the

foreseeable future.

This assessment is completed on the basis of Board-approved management plans and forecasted

profits for Tower Limited and subsidiaries. Tower's ability to utilise these tax losses depends on future

profitability, shareholder continuity and no major change in Tower's business. The enactment of the new

business continuity test in the Income Tax Act 2007 on 30 March 2021 for carrying forward tax losses

means that Tower is able to carry forward its tax losses even if there is a significant shareholding change,

as long as the business continuity test is met.

7.4 Imputation credits

The Group imputation credit account reflects the imputation credits held by the Company as the representative

member of the Group.

2024

$000

2023

$000

Imputation credits available for use in subsequent reporting periods–271

7.3 Deferred tax (continued)

ANNUAL REPORT 202493

Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

8 Other information
This section includes additional required disclosures.

8.1 Notes to the consolidated statement of cash flows

Composition

2024

$000

2023

$000

Cash at bank51,931 42,068

Deposits at call*23,459 21,941

Cash and cash equivalents75,390 64,009

* The average interest rate at 30 September 2024 for deposits at call is 4.24% (2023: 4.65%).

Tower operates in countries in the Pacific Islands that are subject to foreign exchange restrictions, which may

restrict the ability for immediate use of cash by the parent or other subsidiaries. As at 30 September 2024, this

included NZD 7.4m held in Papua New Guinea and NZD 3.3m held in the Solomon Islands following the sales

of the disposal groups (2023: NZD 8.9m held in Papua New Guinea). This cash is not currently available for use

by the Group.

Reconciliation of profit/(loss) for the year to cash flows

from operating activities

2024

$000

RE-PRESENTED

2023

$000

Profit/(loss) after taxation74,285 (1,022)

Adjusted for non-cash items

Depreciation of property, plant and equipment1,866 1,855

Depreciation and disposals of right-of-use assets4,096 4,209

Amortisation of intangible assets19,269 17,327

Financing costs885 928

Fair value losses on financial assets(4,034)(1,756)

Share rights issued under Tower Long-Term Incentive Plan419 124

Change in deferred tax29,280 222

Change in foreign exchange759 (967)

Adjusted for investing activities

Loss on disposal of fixed assets(30)(1,243)

Gain on disposal of discontinued operation(1,988)(2,165)

Impairment loss recognised for disposal group – 563

Investment expenses250 298

Adjusted for movements in working capital

Change in receivables(4,379)(7,076)

Change in payables and provisions19,613 (5,735)

Change in insurance contract liabilities(113,363)127,475

Change in reinsurance contract assets116,317 (125,902)

Change in taxation payable1,942 1,130

Net cash inflow from operating activities145,187 8,265

Net cash inflow from operating activities from continuing operations141,315 23,541

Net cash inflow/(outflow) from operating activities from

discontinued operations3,872 (15,276)

ANNUAL REPORT 202494

Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

8.2 Related party disclosures
Tower considers key management personnel to consist of the Board of Directors, Chief Executive Officer and

executive leadership team. Information regarding individual director and executive compensation is provided in

the Corporate Governance section of the annual report.

2024

$000

2023

$000

Salaries and other short term employee benefits4,9745,511

Long term benefits428536

Termination benefits215 -

Director fees648613

Related party remuneration 6,265 6,660

Tower insurance products are available to all key management personnel on the same terms as available to

other employees. In addition, Tower purchases indemnity insurance for all directors both past and present

covering liabilities and legal expenses incurred whilst in office.

The Board implemented a share-based long-term incentive plan with effect from 7 December 2022. Refer

note 8.5.

8.3 Auditor’s remuneration

2024

$000

2023

$000

Audit of financial statements*997 748

Audit or review related services**23 32

Other assurance services**55 35

Assurance related services**30 –

Total fees paid to Group's auditors1,105 815

Fees paid to subsidiaries' auditors different to Group auditors:

Audit of financial statements*** – 15

Auditors remuneration1,105 830

* Audit of financial statements includes fees for both the audit of annual financial statements and the review of the interim financial

statements. It also includes fees for the transition to NZ IFRS 17. PwC Fiji performs the audits of all overseas incorporated

subsidiaries with the support of PwC New Zealand and other PwC network firms. $122k is paid to other PwC network firms (non

New Zealand) for their audit services.

** Audit or review related services includes the audit of the Pacific Islands regulatory returns (Solomon Islands Branch and Tower

Insurance (Fiji) Limited), other assurance services includes annual solvency return assurance, and assurance related services

includes Greenhouse gas emissions pre-condition assessment for assurance. The other assurance services for the year ended 30

September 2023 were completed during the year ended 30 September 2024.

*** The audit of Tower Insurance (Vanuatu) Limited was performed by Law Partners in 2023.

ANNUAL REPORT 202495

Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

8.4 Discontinued operations
On 29 January 2024 Tower completed the sale of its Solomon Islands business to Trans Pacific Assurance

Limited for a sale price of SBD 18.2m (NZD 3.3m). On 30 August 2024 Tower completed the sale of all of its

shares in its Vanuatu subsidiary to Capital Insurance Group of Papua New Guinea for a sale price of NZD2.4m,

subject to finalisation of completion accounts.

The activities of the businesses have been reported in the current period, and as at 30 September 2023, as a

discontinued operation.

Financial information on these disposals are set out below. The gain on sale in the table below is subject to

finalisation of completion accounting in the year ended 30 September 2025.

Details of the sale of the subsidiary

SOLOMON

ISLANDS

$000

VANUATU

$000

Cash and cash equivalents– 1,888

Receivables– 1,182

Reinsurance contract assets161,035

Right of use assets3419

Property, plant and equipment647

Total assets at the date of disposal1144,131

Payables237311

Liability for remaining coverage220952

Liability for incurred claims131749

Lease liabilities3423

Provisions1168

Total liabilities at the date of disposal6332,103

Net (liabilities)/assets at the date of disposal(519)2,028

Net cash consideration received less costs of disposal1,7062,201

Gain on sale before income tax and reclassification of foreign

currency translation reserve

2,225173

Reclassification of foreign currency translation reserve to profit or loss– (410)

Gain/(loss) on sale 2,225(237)

The following assets and liabilities were reclassified as held for sale in relation to the discontinued operations in

the comparative period.

Assets and liabilities classified as held for sale

2024

$000

2023

$000

Cash and cash equivalents–1,302

Investments–820

Receivables–3,356

Current tax assets–147

Reinsurance contract assets–5,635

Deferred tax assets–44

Right of use assets–110

Property, plant and equipment–91

Total assets at the date of disposal–11,505

Payables–160

Liability for remaining coverage–2,054

Liability for incurred claims–5,121

Lease liabilities–119

Provisions–155

Total liabilities at the date of disposal–7,609

Net assets classified as held for sale–3,896

* As at 30 September 2023, the Tower Group owed disposal groups $3.2m. The assets and liabilities from discontinued operations

disclosed above are stated without adjustment for these intercompany transactions.

The currency translation reserve in relation to the discontinued operations as at 30 September 2023

was $219k.

ANNUAL REPORT 202496

Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

The comparatives presented in the table below include the profit or losses of the Solomon Islands business,
the Vanuatu subsidiary and the Papua New Guinea subsidiary (sale completed during the year ended 30

September 2023).

Profit from discontinued operations

2024

$000

2023

$000

Insurance revenue6,591 9,970

Insurance service expense363 (25,384)

Insurance result before reinsurance contracts held6,954 (15,414)

Net (expense)/income from reinsurance contracts held(5,054)8,247

Insurance service result1,900 (7,167)

Net investment income23 20

Net insurance and investment result1,923 (7,147)

Other income6 64

Other operating expenses(54)(38)

Finance costs(3)(8)

Gain on sale of the subsidiaries1,988 2,165

Impairment loss recognised for disposal group - (563)

Profit/(loss) before taxation from discontinued operations3,860 (5,527)

Tax expense/(income)(459)1,918

Profit/(loss) after taxation from discontinued operations3,401 (3,609)

Disposal groups paid fees to other members of the Tower Group of $1.6m during the financial year ended

30 September 2024 (2023: $2.6m), relating to the provision of reinsurance, management and other services.

These amounts are included within the net expense from reinsurance contracts held and insurance service

expense lines above, and are then eliminated within continuing operations.

Insurance service expense includes ($1.5m) (2023: $7.1m) of claims expense incurred by the parent company

under an internal reinsurance treaty with its Vanuatu subsidiary.

8.4 Discontinued operations (continued)

Earnings per share

20242023

Basic earnings per share (cents) for discontinued operations 0.9(1.0)

The currency translation differences recognised in other comprehensive income during the year ended

30 September 2024 in relation to the discontinued operations, including reclassification adjustment, were

$0.2m (2023: nil).

8.5 Tower Long-Term Incentive Plan

The Group has a long-term incentive plan which is intended to align the interests of management and

shareholders.

Recognition and measurement

The Tower Long-Term Incentive Plan is considered to be an equity settled scheme under NZ IFRS

2 Share-based Payments and the vesting conditions for the scheme include both service and

performance conditions.

The costs associated with this plan are measured at fair value at grant date and are recognised as an

expense in profit or loss over the vesting period, with a corresponding entry to a reserve in equity. The

estimate of the number of rights for which the service conditions are expected to be satisfied is revised

at each reporting date, with any cumulative catch-up adjustment recognised in profit or loss in the period

that the change in estimate occurred. Any rights not vested after the expiry date are cancelled.

The plan provides selected eligible employees with Restricted Share Rights (RSR's), which ‘vest’ over a three-

year period, during which participants must remain employed by the Group and performance conditions must

be met as follows.

Share Rights vest if Tower’s Total Shareholder Return (TSR) sits at or above the 50th percentile of the NZX 50

index ranked by TSR over the same period:

(i) Where the company TSR equals the 50th percentile TSR of the index companies over the performance

period, 50% of the share rights will vest.

(ii) Where the company TSR equals or exceeds the 75th percentile TSR of the index companies over the

performance period, 100% of the share rights will vest

(iii) Where the company TSR over the performance period exceeds the 50th percentile TSR of the index

companies but does not reach the 75th percentile, then between 50% and 100% of the share rights will

vest as determined on a straight line progression basis.

ANNUAL REPORT 202497

Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

During the year the following movements of rights to shares occurred in accordance with the rules of the plan:
20242023

NUMBER OF SHARE

RIGHTS (RSR’S)

NUMBER OF SHARE

RIGHTS (RSR’S)

Share Rights outstanding at the beginning of the period1,946,557 –

Share Rights granted during the period2,612,452 1,946,557

Share Rights forfeited during the period(147,429) –

Share Rights vested and settled during the period – –

Share Rights outstanding at the end of the period4,411,580 1,946,557

The weighted average remaining contractual life for share rights outstanding under the plan is 1.8 years (2023:

2.2 years).

The assessed fair value of the rights granted during the year was 40 cents (2023: 23 cents). This was

calculated using a Monte Carlo share price simulation model by Deloitte Limited. The significant inputs into the

model for rights granted during the period are in the table below:

Assumptions20242023

Share price at grant date (cents)6970

10 Day VWAP (cents)5970

Exercise PriceNilNil

Option life3 years3 years

Risk-free rate4.51%4.36%

Expected volatility20%23%

The expected price volatility is based on annualised price volatility for the four years prior to the grant date.

The total share-based payment expense during the year was $419k (2023: $124k).

There were no liabilities arising from share-based payment transactions at reporting date (2023: nil). The plan

allows participants to request a PAYE Election, under which they may ask Tower to make payment to the

IRD to settle their PAYE liability subject to Tower being reimbursed by the participant. Tower is not required

to accept any participant’s request for a PAYE Election. Tower has not entered into any agreed PAYE Election

arrangements during the year.

8.6 Contingent liabilities

Claims and disputes

The Group is occasionally subject to claims and disputes as a commercial outcome of conducting insurance

business. Provisions are recorded for these claims or disputes when it is probable that an outflow of resources

will be required to settle any obligations. Best estimates are included within claims reserves for any litigation

that has arisen in the usual course of business.

The Group has no other contingent liabilities.

8.7 Capital commitments

As at 30 September 2024, Tower has nil capital commitments (2023: nil).

8.8 Subsequent events

On 28 November 2024, the Board approved a final dividend of 6.5 cents per share, with the dividend being

payable on 30 January 2025 for approximately $24.7m. There were no other subsequent events.

8.5 Tower Long-Term Incentive Plan (continued)

ANNUAL REPORT 202498

Notes to the consolidated financial statements (continued)

Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

Independent auditor’s report
To the shareholders of Tower Limited

Our opinion

In our opinion, the accompanying consolidated financial statements of Tower Limited (the

Company), including its subsidiaries (the Group), present fairly, in all material respects, the

financial position of the Group as at 30 September 2024, its financial performance and its cash

flows for the year then ended in accordance with New Zealand Equivalents to International

Financial Reporting Standards (NZ IFRS) and International Financial Reporting Standards

Accounting Standards (IFRS Accounting Standards).

What we have audited

The Group's consolidated financial statements comprise:

• the consolidated balance sheet as at 30 September 2024;

• the consolidated statement of comprehensive income for the year then ended;

• the consolidated statement of changes in equity for the year then ended;

• the consolidated statement of cash flows for the year then ended; and

• the notes to the consolidated financial statements, comprising material accounting policy

information and other explanatory information.

Basis for opinion

We conducted our audit in accordance with International Standards on Auditing (New Zealand)

(ISAs (NZ)) and International Standards on Auditing (ISAs). Our responsibilities under those

standards are further described in the Auditor’s responsibilities for the audit of the consolidated

financial statements section of our report.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a

basis for our opinion.

Independence

We are independent of the Group in accordance with Professional and Ethical Standard 1

International Code of Ethics for Assurance Practitioners (including International Independence

Standards) (New Zealand) (PES 1) issued by the New Zealand Auditing and Assurance Standards

Board and the International Code of Ethics for Professional Accountants (including International

Independence Standards) issued by the International Ethics Standards Board for Accountants

(IESBA Code), and we have fulfilled our other ethical responsibilities in accordance with

these requirements.

Our firm carries out other services for the Group. These services are a) audit or review related:

audit of the insurance regulatory returns; b) other assurance: reasonable assurance on the

Company’s solvency return; and c) assurance related: assessment of whether the preconditions

for assurance exist in preparation for the assurance over greenhouse gas emissions. In addition,

certain partners and employees of our firm may deal with the Group on normal terms within

the ordinary course of trading activities of the Group. The provision of these other services and

relationships have not impaired our independence as auditor of the Group. The provision of these

other services and relationships have not impaired our independence as auditor of the Group.

ANNUAL REPORT 202499Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

Independent auditor’s report (continued)
Key audit matters

Key audit matters are those matters that, in our professional judgement, were of most significance in our audit of the consolidated financial statements of the current year. These matters were

addressed in the context of our audit of the consolidated financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters.

Description of the key audit matterHow our audit addressed the key audit matter

Valuation of the liability for incurred claims (2024: $135,527,000; 2023:

$241,195,000 (restated))

We considered the valuation of the liability for incurred claims a key audit matter as it

involves an estimation process combined with significant judgements and assumptions,

made by the Group, to determine the balance.

The liability for incurred claims relates to claims incurred under groups of insurance

contracts, as at and prior to reporting date, which have not been paid. The liability includes:

• an estimate of the present value of future cash outflows to settle claims; and

• a risk adjustment for non-financial risk.

There is uncertainty over the amount that reported claims, and claims incurred at the

reporting date but not yet reported to the Group, will ultimately be settled at. The estimation

process relies on the quality of underlying claims data and the use of informed estimates to

determine the quantum of the ultimate future cash flows.

Key actuarial assumptions applied in the valuation of future cash flows include:

• expected future claims development;

• claims handling expense ratios;

• future Canterbury Earthquake overcap property claims; and

• discount rate.

Changes in assumptions can lead to significant movements in the liability for incurred claims.

A risk adjustment allows for the inherent uncertainty in the amount and timing of the

cash flows that arise from non-financial risk related to a group of insurance contracts. In

determining the risk adjustment, the Group makes judgements about the level of required

capital to support the insurance business, claims experience of business classes, volatility of

each class of business written and the correlation between different geographical locations.

Refer to note 2.4 to the consolidated financial statements.

Our audit procedures included obtaining an understanding of key claims and actuarial processes and

controls, including key data reconciliations and the Group’s review of the actuarial estimates of the

liability for incurred claims related to past services.

Claims data is the key input to the actuarial estimate. Accordingly we:

• evaluated the design effectiveness and tested key controls over claims processing;

• assessed a sample of claim case estimates at the year end to check that they were supported

by an appropriate management assessment and documentation, and classified appropriately to

relevant claim type;

• assessed, on a sample basis, the accuracy of the previous claim case estimates by comparing to

the actual amount settled during the year and assessed the changes in the claim case estimate to

determine whether such change was based on new information available during the year;

• inspected a sample of claims paid during the year to confirm that they are supported by

appropriate documentation;

• agreed, on a sample basis, key attributes of insurance contract information to each underlying

contract to determine the level of aggregation and groups used for valuation purposes; and

• tested the integrity of data used in the actuarial models by agreeing relevant model inputs, such as

claims data, to source, on a sample basis.

Together with our actuarial experts, we:

• considered the work and findings of the Group’s Actuaries;

• evaluated the actuarial models and methodologies used, by comparing to generally accepted

models and methodologies applied in the sector and to the prior year, seeking justification for

any variances;

• assessed key actuarial judgements and assumptions and challenged them by comparing with our

expectations based on the Group’s historical claims experience, our own sector knowledge and

independently observable industry trends (where applicable);

ANNUAL REPORT 2024100Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

Independent auditor’s report (continued)
Description of the key audit matterHow our audit addressed the key audit matter

• tested on a sample basis, the underlying calculations in certain valuation models;

• evaluated the relevant underlying calculation used to derive the risk adjustment, including the

significant assumptions, against our own knowledge of the Group’s business and independently

observable market inputs (where applicable); and

• assessed the appropriateness of presentation and disclosures in the financial statements against

the requirement of accounting standards.

The Group adopted NZ IFRS 17 Insurance Contracts from 1 October 2023. We have also considered

the extent to which the procedures above are relevant in the context of the comparative restated

number and executed those procedures accordingly, including confirming that disclosures meet the

requirements of accounting standards.

Our audit approach

Overview

Overall group materiality: $5.5 million, which represents approximately

1% of insurance revenue.

We chose insurance revenue as the benchmark because, in our view, it

is the benchmark against which the performance of the Group is most

commonly measured by users, and is a generally accepted benchmark

for insurance companies. The application of approximately 1% is based

on our professional judgement, noting that it is also within the range of

commonly accepted revenue related thresholds.

A full scope audit was performed for the Company based on its financial

significance to the Group. Specified audit procedures were performed

on financial statement line items of certain subsidiaries and analytical

review procedures were performed on remaining Group entities.

As reported above, we have one key audit matter, being:

• Valuation of the liability for incurred claims

Materiality

Group scoping

Key audit

matters

As part of designing our audit, we determined materiality and assessed the risks of material

misstatement in the consolidated financial statements. In particular, we considered where

management made subjective judgements; for example, in respect of significant accounting

estimates that involved making assumptions and considering future events that are inherently

uncertain. As in all of our audits, we also addressed the risk of management override of internal

controls, including among other matters, consideration of whether there was evidence of bias

that represented a risk of material misstatement due to fraud.

Materiality

The scope of our audit was influenced by our application of materiality. An audit is designed

to obtain reasonable assurance about whether the consolidated financial statements are free

from material misstatement. Misstatements may arise due to fraud or error. They are considered

material if, individually or in aggregate, they could reasonably be expected to influence the

economic decisions of users taken on the basis of the consolidated financial statements.

Based on our professional judgement, we determined certain quantitative thresholds for

materiality, including the overall Group materiality for the consolidated financial statements as a

whole as set out above. These, together with qualitative considerations, helped us to determine

the scope of our audit, the nature, timing and extent of our audit procedures and to evaluate

the effect of misstatements, both individually and in aggregate, on the consolidated financial

statements as a whole.

ANNUAL REPORT 2024101Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

Independent auditor’s report (continued)
How we tailored our group audit scope

We tailored the scope of our audit in order to perform sufficient work to enable us to provide an

opinion on the consolidated financial statements as a whole, taking into account the structure of

the Group, the accounting processes and controls, and the industry in which the Group operates.

Other information

The Directors are responsible for the other information. The other information comprises the

information included in the Annual report, but does not include the consolidated financial

statements and our auditor's report thereon.

Our opinion on the consolidated financial statements does not cover the other information and we

do not express any form of audit opinion or assurance conclusion thereon.

In connection with our audit of the consolidated financial statements, our responsibility is to

read the other information and, in doing so, consider whether the other information is materially

inconsistent with the consolidated financial statements or our knowledge obtained in the audit,

or otherwise appears to be materially misstated. If, based on the work we have performed on the

other information that we obtained prior to the date of this auditor’s report, we conclude that there

is a material misstatement of this other information, we are required to report that fact. We have

nothing to report in this regard.

Responsibilities of the Directors for the consolidated financial statements

The Directors are responsible, on behalf of the Company, for the preparation and fair presentation

of the consolidated financial statements in accordance with NZ IFRS and IFRS Accounting

Standards, and for such internal control as the Directors determine is necessary to enable the

preparation of consolidated financial statements that are free from material misstatement,

whether due to fraud or error.

In preparing the consolidated financial statements, the Directors are responsible for assessing the

Group’s ability to continue as a going concern, disclosing, as applicable, matters related to going

concern and using the going concern basis of accounting unless the Directors either intend to

liquidate the Group or to cease operations, or have no realistic alternative but to do so.

Auditor’s responsibilities for the audit of the consolidated

financial statements

Our objectives are to obtain reasonable assurance about whether the consolidated financial

statements, as a whole, are free from material misstatement, whether due to fraud or error, and

to issue an auditor’s report that includes our opinion. Reasonable assurance is a high level of

assurance, but is not a guarantee that an audit conducted in accordance with ISAs (NZ) and ISAs

will always detect a material misstatement when it exists. Misstatements can arise from fraud or

error and are considered material if, individually or in the aggregate, they could reasonably be

expected to influence the economic decisions of users taken on the basis of these consolidated

financial statements.

A further description of our responsibilities for the audit of the consolidated financial statements

is located at the External Reporting Board’s website at:

https://www.xrb.govt.nz/assurance-standards/auditors-responsibilities/audit-report-1/

This description forms part of our auditor’s report.

Who we report to

This report is made solely to the Company’s shareholders, as a body. Our audit work has been

undertaken so that we might state those matters which we are required to state to them in an

auditor’s report and for no other purpose. To the fullest extent permitted by law, we do not accept

or assume responsibility to anyone other than the Company and the Company’s shareholders, as

a body, for our audit work, for this report or for the opinions we have formed.

The engagement partner on the audit resulting in this independent auditor’s report is Lisa Crooke.

For and on behalf of:

PricewaterhouseCoopers Auckland

28 November 2024

ANNUAL REPORT 2024102Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

28 November 2024
The Directors

Tower Limited

136 Fanshawe Street

Auckland 1010

Dear Directors

Review of Actuarial Information contained in the financial statements

Finity Consulting Pty Limited (Finity) has been asked by Tower Limited (Tower) to carry out a

review of the 30 September 2024 Actuarial Information contained in the financial statements and

used in their preparation and to provide an opinion as to the appropriateness of this information.

This letter sets out the findings of our review, as required under Section 78 of the Insurance

(Prudential Supervision) Act 2010 (the Act).

Geoff Atkins is an employee of Finity and is the Appointed Actuary to Tower. Finity has no

relationship with Tower apart from being a provider of actuarial services.

We prepared the actuarial valuation of liabilities remaining from the Canterbury Earthquakes and

reviewed the actuarial valuations of insurance liabilities for the New Zealand business and the

Pacific Islands businesses. The scope of our review was as required by Section 77 of the Act.

Having carried out the review, nothing has come to our attention that would lead us to believe

that the Actuarial Information used in the financial statements or their preparation, or the

determination of the solvency position for Tower as at 30 September 2024 is inappropriate.

In our opinion the company has maintained a solvency margin in excess of the minimum required

as at 30 September 2024.

Geoff Atkins (Appointed Actuary)

Fellow of the New Zealand Society

of Actuaries

Anagha Pasche

Fellow of the New Zealand

Society of Actuaries

Appointed Actuary’s report

No limitations were placed on us in performing our review and all data and information requested

was provided

The report is being provided for the sole use of Tower for the purpose stated above. It is not

intended, nor necessarily suitable, for any other purpose and should only be relied on for the

purpose for which it is intended.

Yours sincerely

ANNUAL REPORT 2024103Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents

Corporate
Governance

at Tower

104ANNUAL REPORT 2024 ContentsGRI content index Consolidated financial statementsSustainabilityOur strategy2024 in reviewCorporate governanceConsolidated financial statements

This section of the Annual Report provides an overview
of the corporate governance principles, policies and

processes adopted and followed by Tower’s Board (Board)

during the year ending 30 September 2024 (FY24).

The Board is committed to achieving high standards of corporate governance, ethical

behaviour, and accountability. When there are developments in corporate governance

practices, the Board reviews these against Tower’s practices and updates them

where appropriate, including seeking external advice to encourage an environment of

continuous improvement in Board performance.

For the reporting period to 30 September 2024, the Board considers that Tower’s

corporate governance practices have materially adhered to the NZX Corporate

Governance Code (NZX Code). Further information about the extent to which Tower has

complied with each of the NZX Code recommendations is set out in Tower’s corporate

governance statement, available on Tower’s website at tower.co.nz/investor-centre.

Statutory disclosures

Diversity

Gender Diversity

The below table provides a quantitative breakdown as to the gender composition of

Tower’s Directors and Officers, and other employee groups as at 30 September 2024,

compared to 30 September 2023, including subsidiaries. The Executive Leadership

team includes the Chief Executive Officer and those employees who report directly

to the Chief Executive Officer. The Senior Leadership Team refers to employees in

remuneration band 8 and above. Total company figures exclude the Board of Directors,

and include permanent and fixed term employees, and the employees of Tower’s Pacific

Island subsidiaries:

30 SEPTEMBER 202430 SEPTEMBER 2023

GROUP% GROUPNUMBER% GROUPNUMBER

Board of Directors

Males80%480%4

Females20%120%1

Gender Diverse0%00%0

Executive Leadership team

Males50%570%7

Females50%530%3

Gender Diverse0%00%0

Senior Leadership team

Males60%2957%23

Females33%1643%17

Gender Diverse0%00%0

Prefer not to disclose6%3 Data not collected

Employees

Males34%29435%281

Females62%53264%513

Gender Diverse1%51%6

Prefer not to disclose3%25 Data not collected

Total company

Males36%32839%311

Females60%55361%533

Gender Diverse1%61%6

Prefer not to disclose3%28 Data not collected

Total employees915850

ANNUAL REPORT 2024105Our strategy2024 in reviewSustainabilityConsolidated financial statementsGRI content index ContentsCorporate governance

Evaluation from the Board on Tower’s performance with respect
to diversity, equity and inclusion

Tower has a Diversity Equity and Inclusion Policy, which outlines Tower’s commitment

to diversity, equity and inclusion, and provides principles and approaches to cultivate a

respectful and inclusive environment.

The Policy notes that the Company actively seeks to increase diversity in all its forms,

including but not limited to race, ethnicity, gender identity, experience, education,

sexual orientation, age, disability, neurodiversity, socio-economic status and

cultural background.

The Board has delegated to its People, Remuneration and Appointments Committee the

responsiblity to review the Company’s performance against measurable objectives for

achieving diversity and inclusion, pursuant to the Diversity, Equity and Inclusion policy.

In furtherance of those goals, in FY24, the Company increased senior leadership

accountability, by including performance objectives attached to inclusion, equity and

diversity goals.

Employee Resource Groups have been refreshed, to increase employee engagement,

and to provide additional opportunities to share diverse perspectives. Tower aimed to:

• Increase diversity and inclusion engagement results to 8.8 for both ethnic and gender

diverse populations (from 8.6). The Company achieved an engagement result of 8.9

for the year ended 30 September 2024.

• Have 25% of employees engaged in at least one employee representation groups.

30% of employees are engaged in Tower’s employee representation source groups.

• Maintain our 0.0% (+/- 0.9%) Pay Equity gap. Tower has maintained its 0.0%(+/-0.9%)

Pay Equity gap.

• Reduce overall pay gap by 2% (from 20.2%). This goal was not achieved.

• Add new reporting and analysis of Māori and Pacific pay equity analysis for

New Zealand based employees. This analysis is now undertaken and provided

to the People, Remuneration and Appointment Committee.

• Improve retention of diverse talent. 30% of the participants in the Emerging

Talent Programme and Talent Acceleration Programme are Māori or Pasifika. 73%

of participants identify as female. Overall retention of participants in the talent

programmes is 85%, compared to 82% in FY23.

The Board considers that in FY24, the Company has met all but one if its targets in

respect of diversity and inclusion and has continued to increase diversity in all its forms

across the business.

Board and Committee Composition

During FY24 the Board comprised the following members:

Michael Stiassny (Chair)

Graham Stuart

Marcus Nagel

Geraldine McBride

Mike Cutter (from 17 November 2023)

Blair Turnbull (retired 17 November 2023)

Director Independence

The Board has determined, based on information provided by directors regarding their

interests, and criteria for independence benchmarked against the FMA, RBNZ and

NZX independence requirements, that at 30 September 2024 Mr Stiassny, Mr Stuart,

Ms McBride and Mr Cutter were independent. The Board determined that Mr Nagel

was not independent due to his relationship with Tower’s largest shareholder. The

Board does not consider that the tenures of Mr Stiassny or Mr Stuart alter their status as

independent directors.

Board Committees

During FY24 the Board had the following Committees:

Audit Committee

Members: Graham Stuart (Chair), Michael Stiassny, Marcus Nagel, Geraldine McBride,

Mike Cutter (from 17 November 2023).

Risk Committee

Members: Geraldine McBride (Chair), Michael Stiassny, Graham Stuart, Marcus Nagel,

Mike Cutter (from 17 November 2023).

People, Remuneration and Appointment Committee

Members: Michael Stiassny (Chair), Graham Stuart, Marcus Nagel, Geraldine McBride,

Mike Cutter (from 17 November 2023).

Other Committees

Tower’s Board may establish sub-committees from time to time. In 2024, a Results Sub-

Committee was convened on two occasions.

ANNUAL REPORT 2024106Our strategy2024 in reviewSustainabilityConsolidated financial statementsGRI content index ContentsCorporate governance

Board and Committee meeting attendance
Director attendance at Board and Committee meetings held from 1 October 2023 to

30 September 2024 is set out below:

BOARD

AUDIT

COMMITTEE

RISK

COMMITTEE

REMUNERATION

AND APPOINTMENTS

COMMITTEE

RESULTS SUB-

COMMITTEE

Meetings held 154442

Michael Stiassny 154442

Graham Stuart144442

Marcus Nagel15444–

Geraldine McBride15444–

Mike Cutter15444–

Blair Turnbull*1––––

* Mr Turnbull retired as an executive director on 17 November 2023. As an executive director, he was not a member of any

Board Committees.

In addition to meetings, the Board held a two-day strategy session in July, attended

by Directors, members of the Executive Leadership Team and various speakers

and experts.

Remuneration

Director Remuneration

The Board’s approach is to remunerate directors at a similar level to comparable

Australasian companies, with a small premium to reflect the complexity of the

insurance and financial services sector. At the Annual Shareholders’ Meeting in February

2004 shareholders approved a maximum payment of NZ$900,000 per annum for

director fees.

Tower seeks external advice when reviewing Board remuneration. The People,

Remuneration and Appointments Committee is responsible for assisting directors

with the review of directors’ fees. Remuneration is considered through the lens of the

Director and Executive Remuneration Policy to ensure that directors and executives

are remunerated in a fair and reasonable manner, and that such remuneration is

transparently communicated to relevant stakeholders.

Annual fees as approved by the Board with effect from 1 October 2020 are:

TOWER LIMITED BOARD/COMMITTEE FEESCHAIR (NZ$)MEMBER (NZ$)

Base fee – Board of directors180,000100,000

Audit Committee10,000(included in base Director fee)

Risk Committee10,000(included in base Director fee)

Remuneration and Appointments Committee––

The total remuneration received by each director for the year ended 30 September

2024 is set out below (NZ$, and exclusive of GST, if any):

REMUNERATION AND BENEFITS RECEIVED BY TOWER LIMITED DIRECTORS

IN THE YEAR ENDED 30 SEPTEMBER 2024 (NZD)

Michael Stiassny180,000

Graham Stuart110,000

Geraldine McBride*114,166

Marcus Nagel 100,000

Mike Cutter87,222

* Ms McBride received an additional payment during the year to reflect her role as Acting Chair of the Risk Committee from

April 2023.

ANNUAL REPORT 2024107Our strategy2024 in reviewSustainabilityConsolidated financial statementsGRI content index ContentsCorporate governance

REMUNERATION AND BENEFITS RECEIVED BY TOWER SUBSIDIARY DIRECTORS
IN THE YEAR ENDED 30 SEPTEMBER 2024

Isikeli Tikoduadua, Director Tower Insurance (Fiji) Limited and

Southern Pacific Insurance Company (Fiji) Limited18,000 Fijian Dollars

Barry Whiteside, Director Tower Insurance (Fiji) Limited and Southern

Pacific Insurance Company (Fiji) Limited, Chair of Audit & Risk Committee,

Tower Insurance (Fiji) Limited20,000 Fijian Dollars

Directors of Tower Limited and its subsidiaries are reimbursed for out of pocket

expenses incurred in the course of their activities as directors, including travel and

other expenses. As these expenses are not in the nature of remuneration or benefits,

they are not listed here. No employee of Tower Limited or its subsidiaries who acts as

a director of a subsidiary receives any remuneration for their role as a director of that

subsidiary. The number of employees who receive remuneration of more than $100,000

is included in the remuneration table on page 109. Auditor fees paid on behalf of Tower

and its subsidiaries are disclosed in the financial statements.

CEO and senior executive remuneration

The Board’s approach to remunerating the Chief Executive Officer and other key

executives is to provide market based remuneration packages comprising a blend

of fixed and variable remuneration, with clear links between individual and company

performance, and reward.

This approach is intended to encourage Tower’s executives to meet the Company’s short

and long term objectives. The People, Remuneration and Appointments Committee

reviews the remuneration packages of the Chief Executive Officer and the Chief

Executive Officer’s direct reports at least annually.

Fixed remuneration

During FY24 the Chief Executive Officer, Mr Blair Turnbull, received a base salary of

$681,575, plus a 3% employer Kiwisaver contribution. In addition, Mr Turnbull receives

Life Insurance and Income Protection Insurance as part of Tower’s group scheme

available to all permanent employees working at least 15 hours a week.

In FY24, we received external and independent advice from EY on the CEO’s

remuneration, including market benchmarking against comparable New Zealand

companies. EY’s advice was sought in order to gauge actual and forecast movements

within the market, and to assess the levels of fixed and target total remuneration to

pay its CEO. EY reported to the board on this advice.

Variable Remuneration

In FY24, the CEO’s variable remuneration consists of a Short Term Incentive (STI) of up

to 50% of base salary and a Long Term Incentive (LTI) of up to 100% of base salary.

The maximum STI for FY24 is $340,788 based on performance against a company

scorecard that includes financial targets, customer metrics and employee

engagement (the FY24 scorecard is set out in the Corporate Governance Statement).

In FY24, Mr Turnbull was awarded an STI payment of $276,038 based on a company

scorecard against targets of 81%, as detailed below:

PILLARMEASURE%FY24 ACTUALSCORECARD OUTCOME

Financial

(75%)

Underlying NPAT45%83.5m45%

GWP10%595m6.8%

MER10%30.7%

1

6.0%

BAU Claims Ratio10%48%10%

Customer

(20%)

NPS

20%+388.2%

People

(5%)

Engagement

5%8.15.0%

Company Outcome81.0%

As disclosed in the FY23 Annual Report, no STI was earned in respect of FY23.

The maximum LTI grant per annum is currently $681,575 (total) of share rights as well

as an LTI payment of $260,000 in respect of the FY21 LTI scheme, which vested in full.

The FY21 LTI scheme was a cash-based scheme granted at the end of FY21. The

scheme had a maximum award amount of $975,000 in cash (being 150% of the

CEO’s then base salary), with the award amount based on the performance of

Tower’s Total Shareholder Return against the NZX50 at the end of the financial year,

which translated to an award equal to 40% of the CEO’s FY21 base salary. Vesting

is dependent on the CEO remaining employed with Tower and not subject to any

disciplinary action or performance management process as at the end of FY24. The

Board exercised its discretion to approve full vesting of the FY21 LTI payment in

October 2024

2

.

1

The actual MER used for this scorecard does not include additional Short Term incentive payments accrued for all staff in FY24.

2

STI payments are paid in first quarter of the financial year following the year for which they are earned.

ANNUAL REPORT 2024108Our strategy2024 in reviewSustainabilityConsolidated financial statementsGRI content index ContentsCorporate governance

Mr Turnbull received 1,155,509 unvested share rights pursuant to the FY24 long term
incentive plan that vests based on Tower’s Total Shareholder Return performance

relative to the performance of companies within the NZX50 index. The details of the

LTI scheme are included in the Corporate Governance Statement.

Given the resignation of Mr Turnbull, no further LTI grants will be made to the CEO.

CEO’s Long Term Incentives

GRANT

YEARPERFORMANCE PERIOD

SHARE

RIGHTS

ISSUED DATE

NUMBER OF SHARE

RIGHTS ISSUED ON

GRANT DATE

VALUE OF SHARE

RIGHTS ON GRANT

DATE ($)STATUS

FY247 December 2023 to

6 December 2026

26 March

2024

1,155,509681,575Unvested

FY237 December 2022 to

6 December 2025

13 January

2023

939,840657,888 Unvested

The value of share rights on grant date is calculated using the volume weighted average price of Tower Limited’s shares over the 10

trading days preceding the commencement date of the performance period.

CEO’s Remuneration History

The CEO’s remuneration for the last two years is set out in the table below.

YEAR

FIXED REMUNERATIONSTILTITOTAL

BASE SALARY

OTHER

BENEFITSEARNED

AMOUNT

EARNED AS %

OF MAXIMUM

AWARDLTI VESTED

FIXED REM + STI

EARNED + LTI

VESTED

FY2024681,57523,195276,03881%260,000*1,240,808

FY2023657,88822,485-0%-680,373

*STI payments are paid in first quarter of the financial year following the year for which they are earned.

Employee remuneration

The table below sets out the number of employees or former employees of

Tower and its subsidiaries (excluding directors and former directors) who received

remuneration and other benefits valued at or exceeding $100,000 for the years ended

30 September 2023 and 2024. Tower has not previously included its subsidiaries

in this reporting. Remuneration includes base salary, performance payments and

redundancy or other termination payments. The 2024 figures include company

contributions of 3% of gross earnings for those individuals who are members of a

KiwiSaver scheme. The remuneration bands are expressed in New Zealand Dollars:

FROMTO20242023

100,000109,9993626

110,000119,9993124

120,000129,9993534

130,000139,9993125

140,000149,9992915

150,000159,9992826

160,000169,9991411

170,000179,99944

180,000189,99986

190,000199,99953

200,000209,99946

210,000219,99955

220,000229,99933

230,000239,99926

240,000249,99923

250,000259,99901

260,000269,99940

270,000279,99942

280,000289,99933

290,000299,99910

300,000309,99911

310,000319,99912

FROMTO20242023

320,000329,99911

330,000339,99911

340,000349,99901

350,000359,99911

360,000369,99901

370,000379,99901

410,000419,99920

420000429,99910

430,000439,99901

440,000449,99920

450,000459,99910

460,000469,99901

470,000479,99911

490,000499,99901

530,000539,99901

610,000619,99910

650,000659,99910

670,000679,99901

680,000689,99910

700,000709,99901

850,000859,99901

Total264220

ANNUAL REPORT 2024109Our strategy2024 in reviewSustainabilityConsolidated financial statementsGRI content index ContentsCorporate governance

Security Holder Information
Substantial product holders (as at 30 September 2024)

The names and holdings of Tower’s substantial product holders based on notices filed

with Tower under the Financial Markets Conduct Act 2013 at 30 September 2024 are:

NAMETOTAL ORDINARY SHARES

Bain Capital Credit LP, Bain Capital Investments (Europe Limited and Dent

Issuer Designated Activity Company67,464,858

Salt Funds Management Limited26,454,673

Accident Compensation Corporation36,239,113

New Zealand Funds Management Limited on behalf of itself and its wholly

owned subsidiary New Zealand Funds Superannuation Limited26,615,216

Pacific International Insurance Pty Limited22,072,615

These totals may differ from the shareholdings described in other sections on this report.

Largest shareholders (as at 30 September 2024)

The names and holdings of the 20 largest registered Tower shareholders as at

30 September 2024 were:

UNITS% UNITS

1. Dent Issuer Designated Activity Company75,896,44720.00

2. Accident Compensation Corporation - NZCSD <ACCI40>34,040,3218.97

3. Citibank Nominees (New Zealand) Limited - NZCSD <CNOM90>47,507,39812.52

4. Pacific International Insurance Pty Limited22,072,6155.82

5. Lennon Holdings Limited16,200,0004.27

6. HSBC Nominees (New Zealand) Limited - NZCSD <HKBN90>11,714,7233.09

7. Masfen Securities Limited13,430,1973.54

8. HSBC Custody Nominees (Australia) Limited9,430,1602.48

9. Forsyth Barr Custodians Limited <1-Custody>8,857,2412.33

10. MMC – Queen Street Nominees Limited ACF Salt Long Short Fund –

NZCSD <Salt Long Short Fund>

8,296,9282.19

11. JBWere (NZ) Nominees Limited <NZ RESIDENT A/C>7,921,4212.09

12. BNP Paribas Nominees (NZ) Limited - NZCSD2,536,0160.67

13. MMC- Queen Street Nominees Ltd ACF Salt Funds Management <Salt

Funds Management>

6,192,2011.63

14. Public Trust - NZCSD <THE ASPIRING FUND>4,725,0001.25

15. Investment Custodial Services Limited <A/C C>5,415,6471.43

16. Custodial Services Limited <A/C 4>1,623,3150.43

17. New Zealand Depository Nominee Limited <A/C 1 CASH ACCOUNT>2,185,2750.58

18. Tea Custodians Limited Client Property Trust Account - NZCSD

<TEAC40>

2,988,9970.79

19. JP Morgan Chase Bank NA NZ Branch-Segregated Clients ACCT -

NZCSD <CHAM24>

3,778,3741.00

20. JBWere (NZ) Nominees Limited <NR USA A/C>1,343,3440.35

Totals: top 20 holders of ordinary shares 278,727,99973.45

Total remaining holders balance100,755,98826.55

ANNUAL REPORT 2024110Our strategy2024 in reviewSustainabilityConsolidated financial statementsGRI content index ContentsCorporate governance

Securities held by Directors
Until Tower’s shareholders adopted a revised constitution at the annual shareholder

meeting held in February 2024, directors were required to hold shares in the Company.

At 30 September 2024, directors, or entities related to them held relevant interests (as

defined in the Financial Markets Conduct Act 2013) in Tower Limited shares as follows:

Ordinary shares

DIRECTORBENEFICIAL

Wongaling Pty Limited (Geraldine McBride)5,477

Marcus Nagel62

Michael Stiassny624,897

Graham Stuart202,500

Mike Cutter34,726

Director trading in Tower securities

On 15 December 2023 Mike Cutter disclosed his purchase of 34,726 shares in

Tower Limited.

Shareholder analysis

Tower’s shares are quoted on both the NZSX and ASX. At 30 September 2024, 10,992

Tower shareholders held less than A$500 of Tower shares (i.e., less than a marketable

parcel as defined in the ASX Listing Rules), amounting to a total of 2,825,689 of the

Tower shares on issue.

In comparison, a ‘minimum holding’ under the NZX Listing Rules means a holding

of shares having a value of at least NZ$1,000. At 30 September 2024, 15,611 Tower

shareholders held less than NZ$1,000 of Tower Shares (being, a parcel size of 741 at

$1.35 per share), amounting to a total of 5,355,099 of the Tower shares on issue.

Total voting securities

ORDINARY SHARESNUMBER OF HOLDERS

30 September 2024379,483,98722,934

Tower’s ordinary shares each carry a right to vote on any resolution on a poll at a meeting

of shareholders. Holders of ordinary shares may vote at a meeting in person, or by proxy,

representative or attorney.

The address and telephone number of the office at which the register of Tower

securities is kept is set out in the directory at the back of this Annual Report.

Spread of Shareholders (as at 30 September 2024)

HOLDING RANGETOTAL HOLDERSUNITS% UNITS

1 - 1,00017,2056.733,2221.77%

1,001 - 5,0003,9498,128,7102.14%

5,001 - 10,0006064,359,4661.15%

10,001 - 100,00096929,969,3127.90%

100,001 and over205330,293,27787.04%

Total22,934379,483,987100%

Indemnity and insurance

In accordance with section 162 of the Companies Act 1993 and Tower’s constitution,

Tower has provided insurance for and indemnities to, directors and employees of Tower

for losses from actions undertaken in the course of their duties. The insurance includes

indemnity costs and expenses incurred to defend an action that falls outside the scope

of the indemnity. Particulars have been entered in the Interests Register pursuant to

section 162 of the Companies Act 1993.

ANNUAL REPORT 2024111Our strategy2024 in reviewSustainabilityConsolidated financial statementsGRI content index ContentsCorporate governance

Subsidiary Company Directors’ Interests
Directors of Tower’s subsidiary companies made the following new entries into the

interests register.

Michael Yee Joy

Natadola Bay Resorts LimitedDirector

Momi Bay Resort LimitedDirector

Rosie Holidays LimitedChair, Local Advisory

Board and Chair of the Audit

& Risk Committee

Westpac Banking Corporation, Fiji BranchMember, Local Advisory Board

Chanel Home of CompassionChair, Advisory Board

Fiji MuseumDeputy Chair, Board of Trustees

University of South PacificChair, University Grants

Committee

Archdiocese of Suva Roman Catholic ChurchDeputy Chair, Finance Council

Specific disclosures of interest

Directors also disclosed the monetary value of dividends received during the year.

NATURE OF INTERESTMONETARY VALUE

Michael StiassnyShareholder of 624,897 shares in Tower Limited

$18,746.91

Graham StuartShareholder of 225,000 shares in Tower Limited

$6,075.00

Marcus NagelShareholder of 62 shares in Tower Limited$1.68

Mike CutterShareholder of 34,726 shares in Tower Limited$1,041.78

Wongaling Pty Limited

(Geraldine McBride)

Shareholder of 5,477 shares in Tower Limited$164.31

* Based on a Dividend of NZ$0.030 per share (declared on 28 May 2024).

** Mr Nagel was nominated by Bain Capital Credit LP (Bain Capital) to represent Bain Capital’s stake in Tower and his appointment was

supported by the Tower Board.

Interests register

Tower and its subsidiaries are required to maintain an interests register in which the

particulars of certain transactions and matters involving the directors must be recorded.

The interests register for Tower Limited is available for inspection on request by

shareholders. Tower’s constitution provides that an ‘interested’ director may not vote on a

matter in which he or she is interested unless the director is required to sign a certificate

in relation to that vote pursuant to the Companies Act 1993, or the matter relates to a

grant of an indemnity pursuant to section 162 of the Companies Act 1993.

During the year to 30 September 2024, pursuant to section 140 of the Companies Act

1993 Tower’s directors disclosed new interests and cessations of interest as noted in the

table below:

Mike Cutter

Pepper MoneyDirector

Sezzle Inc (until 26 July 2024)Director

Arteva Premium FundingChair

Kadre ConsultingPrincipal

Graham Stuart

Dairy Goat Co-operative NZ Limited (from 24 May 2024)Director

Ravensdown Co-operative Limited (from 27 May 2024)Director

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TOWER SUBSIDIARY COMPANY DIRECTORS
National Pacific Insurance (Tonga) LimitedBlair Turnbull

Paul Johnston

Ronald Mudaliar

Tower Insurance (Vanuatu) Limited

(ceased to be a subsidiary on 30 August 2024)

Blair Turnbull

Paul Johnston

Stephen Grant Ives (until 20 December 2023)

Ronald Mudaliar

Tania Laloyer (from 20 December 2023)

National Pacific Insurance (American Samoa)Blair Turnbull

Ronald Mudaliar

Paul Johnston

Tower subsidiary company directors

Directors of Tower’s subsidiary companies during the year to 30 September 2024 were:

TOWER SUBSIDIARY COMPANY DIRECTORS

Tower Services Limited Blair Turnbull

Paul Johnston

Angus Shelton

The National Insurance Company of New Zealand LimitedBlair Turnbull

Paul Johnston

Angus Shelton

Tower Group Services (Fiji) Pte LimitedBlair Turnbull (retired 20 December 2023)

Isikeli Tikoduadua (retired 24 April 2023)

Paul Johnston (retired 20 December 2023)

Ronald Mudaliar (retired 20 December 2023)

Andrew Hambleton (from 20 December 2023)

Jajeena Bhan (from 20 December 2023)

Shannon Dooley (from 20 December 2023)

Marina Elliott (from 20 December 2023)

Joanne Rasmussen (from 20 December 2023)

Steve Wilson (from 20 December 2023)

Southern Pacific Insurance Company (Fiji) LimitedBlair Turnbull

Isikeli Tikoduadua

Barry Whiteside

Paul Johnston

Ronald Mudaliar

TOWER SUBSIDIARY COMPANY DIRECTORS

Tower Insurance (Fiji) LimitedBlair Turnbull

Isikeli Tikoduadua

Paul Johnston

Barry Whiteside

Ronald Mudaliar

Tower Insurance (Cook Islands) LimitedBlair Turnbull

Paul Johnston

Ronald Mudaliar

National Pacific Insurance LimitedBlair Turnbull

Paul Johnston

Ronald Mudaliar

ANNUAL REPORT 2024113Our strategy2024 in reviewSustainabilityConsolidated financial statementsGRI content index ContentsCorporate governance

Other matters
Donations

During the financial year ended 30 September 2024, donations made by Tower Limited,

and its subsidiaries totalled $600.00.

Credit rating

In April 2024, global rating organisation A.M. Best Company affirmed Tower Limited’s

financial strength rating of A- (Excellent).

Waivers

Tower Limited did not rely on, or make any applications for, waivers from the NZX Listing

Rules or the ASX Listing Rules in the financial year ending on 30 September 2024.

Limits on acquisition of securities

Tower undertook to the ASX, at the time it granted Tower a full listing in July 2002 to

include the following information in its annual report. Except for the limitations detailed

below, Tower securities are freely transferable under New Zealand law.

The New Zealand Takeovers’ Code prohibits a person (including associates) from

increasing their shareholding to more than 20% of the voting rights in Tower except in

accordance with the Takeovers Code. The exceptions include a full or partial takeover

offer in accordance with the Takeovers Code, a scheme of arrangement (under the

Companies Act 1993), an acquisition or an allotment approved by an ordinary resolution

of shareholders, a creeping acquisition (in defined circumstances) and a compulsory

acquisition once a shareholder owns or controls 90% or more of the voting rights

in Tower.

The New Zealand Overseas Investment Act 2005 and related regulations determine

certain investments in New Zealand by overseas persons. Generally, the Overseas

Investment Office’s consent is required if an ‘overseas person’ acquires Tower shares

or an interest in Tower shares of 25% or more of the shares on issue or, if the overseas

person already holds 25% or more, the acquisition increases that holding.

The New Zealand Commerce Act 1986 is likely to prevent a person from acquiring Tower

shares if the acquisition would, or would be likely to, substantially lessen competition in

a market.

Tower is incorporated in New Zealand and therefore not subject to Chapters 6, 6A, 6B or

6C of the Corporations Act 2001 (Australia) dealing with the acquisition of shares (such

as substantial holdings and takeovers).

The Annual Report is signed on behalf of the Board by:

Michael Stiassny Graham Stuart

Chair Director

ANNUAL REPORT 2024114Our strategy2024 in reviewSustainabilityConsolidated financial statementsGRI content index ContentsCorporate governance

Global Reporting
Initiative Content

Index

115ANNUAL REPORT 2024 ContentsCorporate governanceConsolidated financial statementsSustainabilityOur strategy2024 in reviewGRI content index

DISCLOSURELOCATION/INFORMATION
GRI 2: General Disclosures 2021

2-1 Organisational detailsPg 121 Tower Directory.

2-2 Entities included in the

organisation’s sustainability

reporting

See pg 121 Tower Directory, as well as our FY24 Pacific operations

in Fiji, Tonga, Samoa, American Samoa, the Cook Islands. Solomon

Islands and Vanuatu operations included up until sales finalised in the

financial year.

2-3 Reporting period,

frequency and contact

point

Tower reports sustainability information annually. This report covers

the period 1 October 2023 – 30 September 2024. This report was

published on 28 November, 2024. Questions about this report can be

directed to Emily.Davies@tower.co.nz

2-4 Restatements of

information

This is Tower’s third report in accordance with the GRI Standard.

2-5 External assurance

External assurance approach is covered in our Corporate Governance

Statement which can be found in this link: https://www.tower.co.nz/

investor-centre/corporate-governance/policies/

Our External Audit Independence Policy can also be found in this link:

https://www.tower.co.nz/investor-centre/corporate-governance/

policies/

We have not sought external assurance on our sustainability

information.

2-6 Activities, value chain

and other business

relationships

https://www.tower.co.nz/about-us/

Note, sale of Solomon Islands and Vanuatu operations during the

financial year.

2-7 EmployeesTower has 915 employees across New Zealand and the Pacific,

62% of whom are women, 37% are men, 1% are gender diverse,

non- binary, or transgender. This is based on the 98% of staff who

chose to disclose their gender. Out of the 62% population of women,

96% are permanent full-time employees, 3% are permanent part-

time employees, 1% are fixed term employees and <1% are casual

employees. Out of the 37% population of men, 94% are permanent

full-time employees, 2% are permanent part-time employees and 4%

are fixed term employees. Out of the 1% gender diverse, non- binary,

or transgender employees, 86% are permanent full-time employee

and 14% are fixed term employees.

DISCLOSURELOCATION/INFORMATION

2-8Workers who are not

employees

As at 30 September 2024, Tower had 54 contingent workers who are

predominantly independent contractors on either direct or agency

contracts engaged in technology, finance or project-based work.

There were no significant fluctuations in this number during the

reporting period.

2-9Governance structure

and composition

Our Governance structure and composition, along with a list of

committees of the highest governance body, and our Corporate

Governance Statement can be found in this link: https://www.tower.

co.nz/investor-centre/corporate-governance/policies/

2-10Nomination and selection

of the highest governance

body

Tower’s Constitution and Board Renewal Policy can be found in

this link https://www.tower.co.nz/investor-centre/corporate-

governance/policies/

2-11Chair of the highest

governance body

Pg 50.

2-12Role of the highest

governance body

in overseeing the

management of impacts

Pg 50-51.

2-13Delegation of responsibility

for managing impacts

The board delegates day-to-day management of the company to

the CEO and does not currently provide for any additional specific

delegation of ESG impacts.

2-14Role of the highest

governance body in

sustainability reporting

Pg 50-51.

2-15Conflicts of interest

Our Code of Conduct Policy and Conflict of Interest Policy can

be found in this link: https://www.tower.co.nz/investor-centre/

corporate-governance/policies/

2-16Communication of critical

concerns

See Corporate Governance Statement in this link: https://www.tower.

co.nz/investor-centre/corporate-governance/policies/

Communication of critical concerns regarding ESG topics is

unavailable.

See Corporate Disclosure Policy in this link: https://www.tower.co.nz/

investor-centre/corporate-governance/policies/

Tower has reported the information cited

in this GRI content index for the period 1

October 2023 to 30 September 2024, in

accordance with the GRI Standards.

GRI 1: Foundation 2021GRI 1 used:

Statement of use:

Global Reporting

Initiative (GRI)

content index

ANNUAL REPORT 2024116Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governance ContentsGRI content index

DISCLOSURELOCATION/INFORMATION
2-17Collective knowledge of

the highest governance

body

See Corporate Governance Statement in this link: https://www.tower.

co.nz/investor-centre/corporate-governance/policies/

Actions to advance the collective knowledge, skills, and experience

of the highest governance body on sustainable development will

continue to be undertaken in FY25.

Tower’s 2024 Climate Statement can be found in the investor

section of our website, here: https://www.tower.co.nz/investor-

centre/reports/

2-18Evaluation of the

performance of the highest

governance body

See Corporate Governance Statement in this link: https://www.tower.

co.nz/investor-centre/corporate-governance/policies/

2-19Remuneration policies

See Corporate Governance Statement in this link: https://www.tower.

co.nz/investor-centre/corporate-governance/policies/

2-20Process to determine

remuneration

See Director and Remuneration and Appointment Committee Terms

of Reference in this link: https://www.tower.co.nz/investor-centre/

corporate-governance/policies/

Pg 107.

2-21 Annual total

compensation ratio

Not disclosed: information on annual compensation ratio is not

reported externally.

2-22 Statement on sustainable

development strategy

Pg 42.

2-23 Policy commitments

Relevant policies currently in place can be found here: https://www.

tower.co.nz/investor-centre/corporate-governance/policies/

Tower also has an Internal Procurement Policy and a Procurement

Engagement Framework, a Supplier Relationship Management

Framework and a Supplier Code of Conduct.

2-24Embedding policy

commitments

See Corporate Governance Statement in this link: https://www.tower.

co.nz/investor-centre/corporate-governance/policies/

2-25Processes to remediate

negative impacts

https://www.tower.co.nz/contact-us/complaints-and-compliments/

Our material impacts table can be found here: https://www.tower.

co.nz/about-us/sustainability/

Remediation process for our material impacts is covered under the

relevant topics.

DISCLOSURELOCATION/INFORMATION

2-26 Mechanisms for seeking

advice and raising

concerns

See Code of Conduct Policy in this link: https://www.tower.co.nz/

investor-centre/corporate-governance/policies/

Through our internal Whistleblower Policy, staff are encouraged

to raise concerns with their manager, or a senior leader. Tower’s

whistle blower service provides a confidential avenue to report any

serious concerns.

2-27Compliance with laws

and regulations

During the reporting period the Financial Markets Authority (FMA)

filed proceedings regarding the Company’s self-reported failure to

correctly apply multi-policy discounts. Other remediations we have

in progress relate to premium overcharges in connection with the

application of promotions and policy discounts and other policy

errors. Further information about Tower’s remediation programme

can be found on page 21 of this report.

In this reporting period, Tower has not been fined, nor has it incurred

any non-monetary sanctions for breaches or non-compliance with

laws and regulations during the reporting period, or in any previous

reporting period.

2-28Membership associationsTower is a member of Insurance Council of New Zealand and is active

in ICNZ’s Climate Change committee. Tower is also a member of the

Sustainable Business Council, a signatory of the Climate Leaders

Coalition and associate partner of the Centre for Sustainable Finance:

Toitū Tahua.

2-29Approach to stakeholder

engagement

Tower takes a collaborative approach to stakeholder engagement.

Our company purpose and values consider stakeholder interests, see

page 10. Similarly, our Southern Star drives outcomes for customers

and our people, see ‘our vision’ page 10. Our ESG strategy was

developed in consultation with a range of stakeholders and considers

our impacts on various stakeholder groups.

2-30Collective bargaining

agreements

None.

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DISCLOSURELOCATION/INFORMATION
GRI 3: Material Topics 2021

3-1Process to determine

material topics

Pg 49.

3-2List of material topicsPg 49.

3-3Management of material

topics

See our material impacts table via our website for all:

https://www.tower.co.nz/about-us/sustainability/

GRI 305: Emissions 2016

305-1 Direct (Scope 1) GHG

emissions

Pg 48.

Scope 1 emissions include distributed natural gas in New Zealand

and vehicle fleet fuel in New Zealand and the Pacific.

FY20 chosen as the baseline year as this was the first year Tower

measured emissions.

New Zealand emissions factors used were sourced from Ministry

for the Environment’s (MfE) 2024 Measuring Emissions: A Guide

for Organisations. Emissions for Pacific Island electricity use were

sourced from emissionfactors.com and were derived from UN 2021

and IPCC 2006.

Quantities of each greenhouse gas are converted to tonnes CO

2

e

using the global warming potential from the Intergovernmental Panel

on Climate Change (IPCC) Fourth Assessment Report (AR4). The

time horizon is 100 years. Further information on methodology and

assumptions is unavailable.

Our full greenhouse gas emissions report is provided in our 2024

Climate Statement, which is in the investor section of our website,

here: https://www.tower.co.nz/investor-centre/reports/

The Statement contains our Scope 1, Scope 2 and operational

Scope 3 emissions data, as well as information about our work to

identify and assess our climate related risks, opportunities and

business impacts.

DISCLOSURELOCATION/INFORMATION

305-2Energy indirect (Scope 2)

GHG emissions

Pg 48.

Scope 2 emissions include electricity consumption from all business

premises. See 305-1 for relevant disclosures on baseline year,

emissions factors and methodology and assumptions.

Our full greenhouse gas emissions report is provided in our 2024

Climate Statement, which is in the investor section of our website,

here: https://www.tower.co.nz/investor-centre/reports/

305-3Other indirect (Scope 3)

GHG emissions

Pg 48.

Scope 3 emissions include in our FY24 disclosure are transmission

& distribution losses for electricity & gas, air travel, hotel stays, rental

cars, taxi travel, employee commute, working from home, paper

purchased (NZ only), waste to landfill (NZ only) and water (NZ and

some Pacific locations).

The following Scope 3 emissions sources that have been excluded

from our reporting: HFC emissions from refrigeration or HVAC (NZ

and Pacific); employee vehicle claims NZ; transmission & distribution

losses for Pacific electricity; waste generated in Pacific operations;

value chain emissions from purchased goods & services, capital

goods, transportation & distribution – upstream and downstream,

use of sold products, investment portfolio. Tower will expand its

measurement and reporting of scope 3 emissions in FY25. See

305-1 for relevant disclosures on baseline year, emissions factors,

methodology and assumptions.

305-5 Reduction of GHG

emissions

Pg 48.

Our full greenhouse gas emissions report is provided in our 2024

Climate Statement, which is in the investor section of our website,

here: https://www.tower.co.nz/investor-centre/reports/

The Statement contains our Scope 1, Scope 2 and operational

Scope 3 emissions data, as well as information about our work to

identify and assess our climate related risks, opportunities and

business impacts.

Global Reporting Initiative (GRI) content index

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DISCLOSURELOCATION/INFORMATION
2016 GRI 401: Employment 2016

401-1 New employee hires and

employee turnover

In FY24 Tower hired 194 new employees to address growth and

attrition. These comprised permanent, fixed term and casual new

hires. New hires by Gender: Female: 113, Male: 75, Not disclosed: 7.

New hires by region: New Zealand: 82, Pacific: 113. Number and rate

of new employees by age is currently unavailable.

Over the period employee numbers increased by 27 full-time

equivalent staff, from 845 in FY23 to 872 in FY24, with our total head

count of 915 staff, due to continuous development of our Suva hub

in Fiji.

Employee attrition was 18.7% in FY24, reflecting a softening of the

employment market in New Zealand and our decision to expand

our Customer Hub in Fiji, which typically experiences lower level of

employee movement.

401-2 Benefits provided to full-

time employees that are

not provided to temporary

or part-time employees

Benefits are offered to both full-time and part-time permanent

employees. Tower benefits include Group Insurances, parental leave,

ability to buy additional leave, birthday leave, domestic violence

leave, gender affirmation leave, volunteer leave, discretionary leave,

free flu vaccinations, Tower insurance discounts, health insurance

discounts, partner discounts, eyesight testing, and study assistance.

401-3 Parental leaveFrom July 2023, all Tower employees have enjoyed 16 weeks paid

leave for primary carer leave (or maternity leave as it’s referred to

in the Pacific), or four weeks paid partner’s leave for partners of

primary carers.

We also offer all employees compassionate leave and flexible

working on return. Additionally, any annual leave taken on the

employee’s return from parental leave will be paid at their usual rate.

This is more generous than the current Holidays Act legislation and

means take home pay is not affected when the employee takes paid

annual leave.

In In FY24: 35 employees took parental leave (27 female and 8 Male)

versus 22 in FY23. All 35 employees returned to work from parental

leave during FY24 (27 female and 8 Male); of these 33 are still

employed (26 female and 7 Male).

DISCLOSURELOCATION/INFORMATION

GRI 403: Occupational Health and Safety 2018

403-1 Occupational health

and safety management

system

See Health and Safety Policy in this link:

https://www.tower.co.nz/investor-centre/corporate-governance/

policies/

403-2 Hazard identification, risk

assessment, and incident

investigation

Tower’s H&S Management System has an incident register where

incidents are reported. When reporting, it is mandatory that all

incidents are assessed and each incident must have corrective

actions identified and implemented before being closed. Once

reported, incidents are then reviewed by the Health and Safety

Officer, who investigates all incidents.

Workers are encouraged to report hazards and hazardous situations

through the H&S system. Tower’s H&S Policy is in line with New

Zealand’s Health and Safety at Work Act 2015. All workers have

access to the Health and Safety Policy on Tower’s intranet.

403-3 Occupational health

services

Tower workers have access to Employee Assistance Programme

EAP counselling sessions provided by external trained counsellors.

These sessions are arranged by workers independently. If employees

choose to use counselling or health and wellbeing services via EAP,

these services are strictly confidential between the worker and

healthcare provider.

403-4 Worker participation,

consultation, and

communication on

occupational health and

safety

As per the NZ Health and Safety at Work Act 2015, Tower has a

team of Health and Safety Committee Members from across the

NZ business. In the Pacific we have also have Health and Safety

committee members in each country. These Committee Members

engage and consult with workers regularly and report any concerns

to the Health and Safety Officer and/or at the regular Health and

Safety meeting. Tower’s H&S Management system is continuously

reviewed by the Health and Safety Officer to ensure risks are kept up

to date.

Tower has several Health and Safety committees that meet monthly.

Committee members are allocated specific time each month to

undertake their responsibilities. Their responsibilities include but

are not limited to; office inspections, disseminating H&S updates

from the meetings to relative teams, ensuring H&S is on the agenda

at team meetings and promotion of health, safety and wellbeing

education and activities.

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DISCLOSURELOCATION/INFORMATION
403-5 Worker training on

occupational health and

safety

Tower offers training to workers who volunteer to be First Aiders, Fire

Wardens, Mental Health First Aiders and Domestic Violence First

Responders. Building Assessors are asbestos awareness trained.

403-6 Promotion of worker healthTower supports its employees that have non-work-related accidents

by offering workstation assessments to ensure they have the

necessary equipment to undertake their job. Where a return-to-

work plan is required, Tower will work alongside ACC to facilitate a

satisfactory solution for the employee. Health checks in the Pacific

are done through a local General Practitioner, and the results are

confidential and not shared with Tower.

Tower offers employees access to several health promotion services

including; EAP (online and in person), discounted flu vaccinations,

access to trained Mental Health First Aiders and trained Domestic

Violence first responders (online and in-person).

Tower promotes prevention of communicable diseases in the

Pacific through education on symptoms, prevention and treatment.

Our Rainbow network supports education on AIDS awareness

and prevention.

DISCLOSURELOCATION/INFORMATION

GRI 405: Diversity and Equal Opportunity 2016

405-1 Diversity of governance

bodies and employees

Pg 105-106.

405-2 Ratio of basic salary and

remuneration of women

to men

Pg 38.

GRI 418: Customer Privacy 2016

418-1 Substantiated complaints

concerning breaches of

customer privacy and

losses of customer data.

In the reporting period, two substantiated breaches concerning

customer privacy were identified. These were considered to be

one-off breaches, rather than systemic and did not result in serious

harm. We remain committed to maintaining the highest standards of

data protection and continuously improving our practices to prevent

future occurrences.

Global Reporting Initiative (GRI) content index

ANNUAL REPORT 2024120Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governance ContentsGRI content index

Tower Directory
Enquiries

For customer enquiries, call Tower on 0800 808 808

or visit www.tower.co.nz

For investor enquires:

Telephone: +64 9 369 2000

Email: investor.relations@tower.co.nz

Website: www.tower.co.nz

Board of Directors

Michael Stiassny (Chair)

Graham Stuart

Marcus Nagel

Geraldine McBride

Mike Cutter (from 17 November 2023)

Blair Turnbull (until 17 November 2023)

Chief Executive Officer

Blair Turnbull

Company Secretary

Tania Pearson

Executive Leadership Team (at 30 September 2024)

Blair Turnbull, Chief Executive Officer

Paul Johnston, Chief Financial Officer

Sharyn Reichstein, Chief Risk Officer

Michelle Finch, Chief Revenue, Marketing and Brand Officer

Andrew Hambleton, Chief Administrative Officer

Anna Kooperberg, Chief Customer Experience Officer

Ronald Mudaliar, Chief Underwriting Officer

Steven Wilson, Chief Claims Officer

Liz Cawson, Co Chief Data Digital Officer (Acting)

Johannah Benton, Co Chief Data Digital Officer (Acting)

Registered Office

New Zealand

Level 5, 136 Fanshawe Street, Auckland

PO Box 90347

Auckland

Telephone: +64 9 369 2000

Facsimile: +64 9 369 2245

Australia

c/- Peter Davison

18 Korinya Road

Castle Cove

Sydney NSW 2069

Australia

Auditor

PricewaterhouseCoopers

Lawyers

MinterEllisonRuddWatts

Banker

Westpac New Zealand Limited

Company numbers

Tower Limited

(Incorporated in New Zealand)

NZ Incorporation 143050

NZBN 9429040323299

ARBN 645 941 028

Stock Exchanges

The Company’s ordinary shares are listed on the NZSX and the ASX. On

Wednesday 18 May 2016, Tower’s ASX admission category changed to

“ASX Foreign Exempt Listing”.

ANNUAL REPORT 2024121Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governance ContentsGRI content index

Registry details
Shareholders should make enquiries in respect of their shareholdings,

notify changes of details or address administrative queries to Tower’s

Share Registrar.

Direct payment to a bank account is the only way in which dividend

payments are made. Shareholders are strongly encouraged to ensure

that the Registrar has up to date bank account details.

Tower also encourages shareholders to receive communications

electronically, to minimise cost, ensure quicker communication, and to

reduce environmental impacts.

New Zealand

Computershare Investor Services Limited

Level 2, 159 Hurstmere Road

Takapuna, Auckland

Private Bag 92119

Auckland 1142

Freephone within New Zealand: 0800 222 065

Telephone New Zealand: +64 9 488 8777

Australia

Computershare Investor Services Pty Limited

Yarra Falls, 452 Johnston Street

Abbotsford VIC 3067

GPO Box 3329

Melbourne Vic 3000

Freephone within Australia: 1800 501 366

Telephone Australia: +61 3 9415 4083

Email: enquiry@computershare.co.nz

Website: www.computershare.com/nz

ANNUAL REPORT 2024122Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governance ContentsGRI content index

tower.co.nz

---

Tower
2024 Full

Year Results

1 October 2023 to 30

September 2024

28 November 2024

2
Chairman’s update

Michael Stiassny, Chairman

Business update

Blair Turnbull, Chief Executive Officer

FY24 financial performance

Paul Johnston, Chief Financial Officer

Looking forward

Blair Turnbull, Chief Executive Officer

Agenda

3
Chairman’s update

Delivering shareholder value

•Final dividend of 6.5 cents per share declared; FY24 total dividends declared of 9.5 cents per share

•Capital return of $45m declared, subject to high court approval and shareholder vote at Annual

Shareholder Meeting

1

•Tower entered NZX 50 Portfolio Index and MidCap Index

Tower is well positioned

•Strategy is delivering operational results; improvements in customer experience and business

performance

•Risk-based pricing and enhanced underwritingcapability underpincompetitive positioning

•Continued improvements in digital and operational efficiencies

Strong business performance driven by focus on strategy and operational delivery

Note 1: The return of capital will be conducted as a scheme of arrangement. It is subject to receipt of High Court approval of the arrangement and shareholder approval, as well as Tower

continuing to satisfy solvency and prudential capital requirements and the Tower Board remaining satisfied that it is prudent to undertake the capital return until such time as it is actioned

4
Business update

Blair Turnbull,

Chief Executive Officer

5
Results summary

•Continued targeted premium growth​

•Continued improvement in MER​, achieved through premium

growth, and operational & digital efficiencies

•Claims ratio improved due to actions to mitigate cost

increases from inflation, reinsurance, and motor crime

•No large events; robust reinsurance programme

•Capital return of $45m declared, subject to conditions

•6.5 cents per share final dividend, FY24 total dividend

9.5 cents per share

1

Note 1: Based on Tower’s ordinary dividend policy to pay a sustainable annual dividend in the range of between

60-80% of adjusted earnings where prudent to do so

6
9.5 cents per share

vs no dividend in FY23

Dividend

Total FY24 declared dividends

48%

vs 55% in FY23

Our performance

Positive operational and business performance

BAU claims ratio

(Business as usual)

MER

(Management expense ratio)

31.4%

vs 32.0% in FY23

Large event costs

(including reinsurance reinstatement)

-$2.3m

vs $55.6m in FY23

Reported profit

$74.3m

vs $1.0m loss in FY23

Prior year metrics have been restated to align to IFRS 17 for consistent comparisons

Note 1: Excluding divested portfolios. Prior year customer numbers have been adjusted to exclude sold and held for sale portfolios which include the Solomon Islands business and Vanuatu subsidiary, and the New

Zealand commercial rural portfolio

Note 2: Large event costs are negative in FY24 due to due to the absence of large events in the financial year and a favourable revision to prior year large events costs

Note 3: Definition of underlying profit and a reconciliation to reported profit is included in the appendices

GWP growth

(Gross written premium)

15% | $595m

vs $527m in FY23

$83.5m

vs $7.1m in FY23

Underlying profit

305,000

vs 311,000 in FY23

Customers

1

1

2

3

7
Continued premium growth

Targeted growth

•House GWP growth 18%; 72% rate, 28% volume

•Motor GWP growth 13%; off-risking of high theft

vehicles reduces number of motor policies

•Risk-based pricing improving exposure; 91% of policies

rated ‘Low’ or ‘Very Low’ flood risk (FY23: 90%)

Addressing customer affordability

•NZ retention at 77%(FY23: 77%)

2

•53% of customers have multiple policies

•29k customers accessed ‘Ways to Save’ feature

G R O S S W R I T T E N P R E M I U M ($m)

Note 1: Excluding divested portfolios. Prior year customer numbers have been adjusted to exclude sold and held for sale portfolios which include the Solomon Islands business and Vanuatu subsidiary, and

the New Zealand commercial rural portfolio

Note 2: Commercial rural policies have not been included because this business has been sold and policies are actively being transferred out of the portfolio

Note 3: Other products include Marine, Travel, Pet, Liability, and Workers Compensation

15% underlying GWP growth

1

3

8
Customer experience improves

N E T P R O M O T E R S C O R E

Digital journey

•New Zealand digital tasks

1

– 63% sales, 45% service; 64% claims

•Active users of My Tower increased by 5% to 164k

Assisted journey

•Sales & service contact centre abandonment rate reduced to 8%

(FY23: 13%)

•Award winning service - 1

st

place Supreme Award for Retention in the

CRM Contact Centre Awards (NZ)

Customer remediation

•$11.5m multi-policy discount customer remediation payments made

by 31 Oct (excl GST)

Note 1: Sales tasks are all New Zealand new business policies sold online (previously reported as Tower Direct only). Service tasks are either digital (actioned by the customer through the My Tower

portal online) or assisted (through Tower’s call centre). In prior years, multiple tasks completed on the same call were reported as one assisted transaction - these are now reported individually.

Digital claims tasks refer to claim lodgement only.

Net promoter score improved to +38

9
Continued improvement in MER

MANAGEMENT EXPENSE RATIO

1

Operational efficiencies

•Achieving scale with targeted premium growth

•Suva hub answering 55% of NZ sales and service calls

(FY23: 16%)

Streamlining the business

•Sale of Solomon Islands, Vanuatu and NZ commercial

rural portfolio

•Commission ratio

2

at 1.5%; down from 2.1%, partly due to

legacy portfolio


purchases and transition to referral

arrangements

•26% reduction in Tower’s on-premise data centre

footprint (71 virtual servers decommissioned)

Note 1:Calculated as management expenses and net commission expense divided by net insurance revenue

Note 2: Commission ratio for the comparative period has been restated due to adoption of IFRS17 which treats a portion of commission revenue as insurance revenue

Management expense ratio (MER) improved to 31.4%

10
BAU claims ratio significantly improves

Effective pricing and underwriting

•Targeted rating has reduced high-risk policies

•Rating for inflation, reinsurance, high motor theft

Faster and more efficient claims management

•Digital evolution: new motor assessing tool live, auto

allocation of online motor and house claims to repairers

•Number of open BAU claims down by 50%

•Turn around time decreased by 30%

External factors improved performance

•Calmer weather, easing inflationary pressures, and lower

motor theft frequency

BAU CLAIMS RATIO

1

Note 1:BAU claims are defined as those not part of a large event (large events are defined as having a cost to Tower of $2m or more, with lodged claims from two or more policyholders). BAU

claims ratio is calculated as BAU claims expense divided by net insurance revenue

Business as usual claims ratio improved to 48.1%

OPEN CLAIMS NZ

11
Underlying business performance improving consistently

•Underlying business improving half-on-half

•Reduction in BAU claims ratio from targeted rate

increases and high-risk vehicle off-risking

•Management expense efficiencies improved profit

•Investment income benefiting from higher interest rates

U N D E R L Y I N G N P A T

1


E X C L U D I N G L A R G E E V E N T S ( $ m )

Underlying NPAT excluding large events was $81.9m in FY24

Note 1: Definition of underlying profit and a reconciliation to reported profit is included in the appendices

Financial
performance

Paul Johnston,

Chief Financial Officer

13
Group underlying financial performance

•Premium growth of 15%

1

•BAU claims ratio reduced to 48.1% due to targeted rate

increases and operational improvements

•No large events in FY24; favourable release of $2.3m from

FY23 Vanuatu Cyclones

•Management expense ratio improved to 31.4% as a result of

business growth and expense efficiencies

•Net investment income increased $7.2m due to higher

investment balances and higher yields

•Underlying NPAT including large events of $83.5m

2

•Reported profit of $74.3m impacted by customer

remediation and CEQ strengthening

Note 1: Adjusted to exclude sold/held for sale portfolios: Solomon Islands, Vanuatu, and NZ commercial rural

Note 2: Definition of underlying profit and a reconciliation to reported profit is included in the appendices

1

14
•Underlying NPAT

1

of $83.5m vs $7.1m in FY23

•No new large events in FY24 vs $55.6m of large event

costs in FY23

•Business growth includes higher net earned premium

and expense growth

•BAU claims ratio improved from rating and underwriting

actions, reduction in open BAU claims, and lower motor

theft frequency

•Non-underlying items include customer remediation costs

(remediating 66k customers) and CEQ strengthening,

partially offset by the gain on sale of divested portfolios

Movement in underlying NPAT

Note 1: Definition of underlying profit and a reconciliation to reported profit is included in the appendix

15
BAU claims ratio reduced

N Z M O T O R S E V E R I T Y

1

& F R E Q U E N C Y

2

•Targeted rate increases and high-risk vehicle off-risking

•Inflationary pressures easing

•Motor theft frequency reduced from peak in FY23

•Risk-based pricing – improved house exposure reduces

frequency of house claims

•Calmer weather in comparison to prior years

Note 1: Severity is defined as the cost of claims (excluding large events, large house, windscreen) divided by the count of claims

Note 2: Frequency is defined as the number of claims (same exclusions as above) divided by risks in force

The historical severity and frequency numbers are updated to the current estimates as at 30 September 2024 reflecting development of prior year claims in their respective incurred periods

N Z H O U S E S E V E R I T Y & F R E Q U E N C Y

T O T A L C L A I M S R A T I O

16
Continued improvement in management expense ratio

M O V E M E N T I N M A N A G E M E N T E X P E N S E

R A T I O ( M E R )

•MER reduced 0.6% to 31.4%

•Business growth contributes 4.2% reduction

in MER

•Net commission contributes 0.3% reduction

in MER driven by an increase in reinsurance

profit share commission income

•Increase in project spend incurred to

deliver key strategic initiatives

•Staff and other costs impacted by inflation

and staff incentives (none paid in FY23)

partially offset by cost efficiencies

17
Higher investment returns

Note 1: Core investment portfolio refers to Tower’s fixed income investment portfolio in NZ. It excludes cash held for operational purposes in NZ and cash and short-term deposits held by Tower’s

Pacific subsidiaries. Subsidiaries of banking groups with a credit rating have been grouped under their parent bank’s credit rating, even if unrated themselves

•Net investment income $21.6m in FY24, $7.2m higher than FY23

•Running yield on the core investment portfolio is 4.9% as at 30 September 2024

•Conservative investment strategy with low duration (target of 0.5 years)

•Now past the peak of the rating cycle, with yields expected to continue decreasing through FY25

I N V E S T M E N T A S S E T P R O F I L E

C O R E I N V E S T M E N T P O R T F O L I O

1


Y I E L D

18
Reinsurance programme

FY24

•No large events; $2.3m release from FY23 Vanuatu

Cyclones

FY25

•Catastrophe reinsurance of up to $800m for two events,

up from $750m in FY24

•Additional prepaid third event catastrophe cover up to

$85m with $20m retention

•FY25 retention change mitigated by 3-year rolling

contracts, and expected to benefit future years

•Full utilisation of $50m large event allowance for FY25

events assumed in guidance

•FY25 large events - Dunedin flooding event in October

2024 estimated at $3m

1

$800m

$85m

1st Cat loss

(retention $16.9m)

2nd Cat loss

(retention $16.9m)

1st Cat event

2nd Cat event

3rd Cat event

3rd Cat loss

(retention $20m)

Reinsurance

coverage of

$781.2m

Reinsurance

coverage of

$781.2m

Reinsurance

coverage of

$65m

1st Cat Loss

(retention $18.8m)

2nd Cat Loss

(retention $18.8m)

3rd Cat Loss

(retention $20m)

Note 1: Tower’s practice is to not give separate NZX announcements on large events during the year unless material to overall results

19
Capital and solvency position

Note 1: SR = Solvency ratio – the ratio of solvency capital to adjusted prescribed capital

Note 2: Based on Tower’s ordinary dividend policy to pay a sustainable annual dividend in the range of between 60-80% of adjusted earnings where prudent to do so

T O W E R S O L V E N C Y

1


N Z P A R E N T ( $ m )

•Solvency ratio

1

of 212% (139% as at 30 Sep 23)

•Adjusted solvency margin is $171.4m, an increase from $79.8m

as at 30 Sep 23

•Adjusted solvency margin at 30 Sep 24 is net of final dividend

of 6.5 cents per share.

2

The planned capital return of $45m is

not yet taken into account and is expected to be deducted

from solvency in FY25

•Tower’s regulatory solvency position is now calculated under

the new Interim Solvency Standard (ISS) effective 1 Oct 23

•The RBNZ is consulting on a further amendment to the ISS,

expected to be issued and effective this financial year

•The proposed changes to the ISS, if implemented, are likely to

have a material impact on Tower’s regulatory solvency position,

and will reduce the solvency margin

•$15m RBNZ licence condition reduced to $0

•A- financial strength rating reaffirmed in April 2024 by AM Best

Looking forward
Blair Turnbull,

Chief Executive Officer

21
Focus on customer experience and targeted growth

•Enhancing risk-based pricing – landslide and sea surge

applied to renewal book and included in purchase journey

•New partnerships for further growth

•Motor policy growth through targeted risk approach

•Renewal journey uplift to increase retention

•Targeting annual underlying GWP growth of 10%-15% to FY27

22
Continuous efficiency & process improvements

•Targeting 80% of all NZ sales, service, and claim

lodgement tasks to be digital by end FY27 (FY24: 45%)

•New house assessing system planned, reducing

assessment time and repair costs

•New contact centre platform planned to deliver frontline

efficiencies

•Remediation lessons applied to processes and systems

•Streamlining the business - NZ commercial rural

portfolio completes migration in Jan-25

•Targeting MER of < 26% in FY27

M A N A G E M E N T E X P E N S E R A T I O ( % N E P )

Targets

23
Fostering sustainability

Our people

•Staff engagement score 8.1

•Gender pay equity gap 0.9%

1

•Tower staff spent 2,300 hours volunteering in our communities

•30% of Tower staff are members of representation groups

2

•Winner 2024 ANZIIF NZ Insurance Industry Awards Excellence in

Workplace Diversity, Equity & Inclusion

Climate

•Parametric partnership with CelsiusPro, global insurtech,

targeting10K+ parametricpolicies by end of FY25

•FY24 Scope 1 and 2 emissions20% below FY20 baseline year

•Supporting climate change education & future sustainability with

university scholarships in New Zealand and Fiji

Note 1: Comparison of like-for-like roles for women and men at Tower (men are paid 0.9% more than women for the same role)

Note 2: Employee representation groups include groups for rainbow, Māori, women, physical & neuro diversity, wellbeing, and cultural diversity

24
FY25 guidance and future targets

FY24

Actual

FY25

Guidance

FY27

Target

GWP growth

(excluding operations sold)

15%10% - 15%10% - 15%

Large events cost/allowance-$2.3m$50m

Management expense ratio31.4%< 29%< 26%

Combined operating ratio79%87% - 89%< 86%

Underlying NPAT

(assuming full utilisation of large events allowance)

$83.5m$50m - $60m

Return on equity

1

23%13% - 17%> 18%

Note 1: Return on equity is defined as reported net profit after tax divided by average closing book equity

FY25 priorities
•Customer experience

•Customer remediations, FMA proceedings and

implementing lessons

•Conduct of Financial Institutions (CoFI)

•End-to-end customer data management

•Risk-based pricing - landslips and sea surge

•Efficiency, digitisation, and process improvements

25

Questions?

Appendices

28
P A R T N E R S H I P S G W P ( $ m )

P A C I F I C G W P ( $ m )

Business unit distribution

•Underlying growth of 16%

1

•House new risks sold +14% vs FY23

•55% of Tower Direct customers hold

multiple policies (FY23: 54%)

•Underlying growth of 24%

•Total in force risks increased 6% to

109,000

•Advisor network grew 32% to 3,300

•Underlying growth of -2%

1

•Solomon Islands & Vanuatu

businesses sold in FY24; PNG in FY23

•Tightening risk appetite in American

Samoa

PARTNERSHIPS

TOWER DIRECT

PACIFIC

1

T O W E R D I R E C T G W P ( $ m )

T O W E R D I R E C T G W P ($m)

P A R T N E R S H I P S G W P ($m)

P A C I F I C G W P ($m)

Note 1: Excluding divested portfolios which include the Solomon Islands business and Vanuatu subsidiary, and the New Zealand commercial rural portfolio

29
Reconciliation between underlying profit after tax and reported profit after tax

Underlying and reported profit/(loss):

•“Net insurance revenue”, “net insurance service

expense” and “underlying profit” do not have a

standardised meaning under Generally Accepted

Accounting Practice (GAAP). Consequently, they

may not be comparable to similar measures

presented by other reporting entities and are not

subject to audit or independent review.

•Tower uses underlying profit as an internal reporting

measure as management believes it provides a

better measure of Tower’s underlying performance

than reported profit/(loss), as it excludes large or

non-recurring items that may obscure trends in

Tower’s underlying performance, and is useful to

investors as it makes it easier to compare Tower’s

financial performance between periods.

•Tower has applied a consistent approach to

measuring which items are excluded from

underlying profit in the current and comparative

periods.

•“Reported profit/(loss) after tax” is calculated and

presented in accordance with GAAP

(1)Non-underlying items include net impact of customer remediation provision increase and related costs, Canterbury earthquake valuation update, regulatory and compliance projects (such as the adoption of

IFRS-17), and gain on sale of operations

(2)Reclassification of claims handling expenses from management expenses to claims expense; and FX gains/losses from other income to management expenses

(3)Operations sold during FY24 are treated as discontinued operations for statutory purposes

(4)Reclassification of reinsurance expenses to present as net income from reinsurance contracts held for statutory purposes

(5)Reclassification of reinsurance and other recoveries to present as net income from reinsurance contracts held for statutory purposes

30
Disclaimer

This presentation has been prepared by Tower Limited to provide shareholders with information on Tower’s business. This document is part of, and should be read in

conjunction with an oral briefing to be given by Tower. A copy of this webcast of the briefing is available at http://www.tower.co.nz/investor-centre/ It contains

summary information about Tower as at 30 September 2024 which is general in nature, and does not purport to contain all information a prospective investor should

consider when evaluating an investment. It is not an offer or invitation to buy Tower shares. Investors must rely on their own enquiries and seek appropriate

professional advice in relation to the information and statements in relation to the proposed prospects, business and operations of Tower. The data contained in this

document is for illustrative purposes only. Past performance is not a guarantee of future performance and must not be relied on as such. The information in this

presentation does not constitute financial advice.

Forward looking statements

This document contains certain forward-looking statements. Such statements

relate to events and depend on circumstances that will occur in the future and

are subject to risks, uncertainties and assumptions. There are a number of

factors which could cause actual results and developments to differ materially

from those expressed or implied by such forward-looking statements, including,

among others: the enactment of legislation or regulation that may impose costs

or restrict activities; the re-negotiation of contracts; fluctuations in demand and

pricing in the industry; fluctuations in exchange controls; changes in government

policy and taxation; industrial disputes; and war and terrorism. These forward-

looking statements speak only as at the date of this document.

Disclaimer

Neither Tower nor any of its advisers or any of their respective affiliates,

related bodies corporate, directors, officers, partners, employees and agents

(other persons) makes any representation or warranty as to the currency,

accuracy, reliability or completeness of information in this presentation. To

the maximum extent permitted by law, Tower and the other persons

expressly disclaim any liability incurred as a result of the information in this

presentation being inaccurate or incomplete in any way. The statements

made in this presentation are made only as at the date of this presentation.

The accuracy of the information in this presentation remains subject to

change without notice.

---

1

Tower FY24 Results Announcement Investor Presentation Script

Slide 1 – 2024 Full Year Results

Michael Stiassny

Mōrena, good morning and thank you for making the time to join us for this

investor call and presentation of our 2024 full year results.

Slide 2 - Agenda

With me in Auckland is our Chief Executive Officer, Blair Turnbull and our Chief

Financial Officer, Paul Johnston who will take you through the results and

answer your questions.

Slide 3 – Chairman’s update

The 2024 financial year has been a strong one for Tower. Following an

extremely challenging previous year, it is particularly pleasing to be recording

underlying net profit after tax of $83.5m and reported profit of $74.3m.

Delivering shareholder value

These results have been hard won. While significantly aided by the absence of

large events in the period, more importantly the business has achieved year-

on-year improvements in business as usual claims, premium growth and

operational and digital efficiencies. These are the measures that ensure Tower

remains well positioned to deliver value to shareholders.



2


I am pleased to announce that we have declared a final dividend of 6.5 cents

per share. This brings our total dividends for the fiscal year to 9.5 cents per

share.

And, while still subject to high court approval and shareholder vote at the

Tower Annual Shareholder Meeting on 11 February, the Board has also

approved a return of $45 million of excess capital by way of a scheme of

arrangement. This capital return is expected to deliver meaningful earnings per

share accretion, further demonstrating our commitment to returning value to

our shareholders.

Tower has entered the NZX50 portfolio index, a significant milestone that

recognises our company's growth and stability. This achievement is a

testament to our strategic initiatives, which have led to improvements in

customer experience and overall business performance.

Tower is well positioned

We are acutely aware that the current, sustained economic downturn is

affecting almost everyone, including many of our customers. Ensuring

insurance remains affordable and premiums stabilise is a priority. Blair will talk

about how Tower began moderating premium increases – particularly for low-

risk assets – as inflation settled in the second half. Those efforts are continuing

to ensure Tower can remain competitive and profitable, while providing good

value and a great customer experience.

Tower’s competitive positioning has for some time been underpinned by risk-

based pricing. We continue to believe that this is the fairest way to address



3


both affordability and the impacts of climate change, ensuring that our pricing

models are transparent, sustainable and equitable.

By setting premiums that reflect actual environmental risks, we are

incentivising our communities and policyholders to adopt sustainable practices

and invest in resilience measures.

This approach helps to reduce overall risk and financial burden but

importantly, promotes fairness and encourages community-wide preparedness

and adaptation.

And, from a cost perspective our customers who take proactive steps to

mitigate risks are rewarded with lower premiums, while those with higher risks

pay accordingly. This differentiation encourages responsible behaviour and

brings transparency to our pricing structure, allowing customers to see a direct

correlation between their actions and their insurance costs.

By doing so, we foster a more equitable and resilient market, ultimately driving

our company's success and sustainability in the long run.

[pause]

In closing, I’d like to thank the Tower team. It’s a very good result – we’re

paying a dividend, the business remains strong and well capitalised, and has

achieved sustained premium growth. None of this would be possible without

the vision, dedication and commitment of our people.

As you will be aware, Blair is stepping down as CEO in February after the ASM.

The Board joins me in thanking him for the strong contribution he has made to

Tower during his tenure.



4


I’ll now hand over to Blair and Paul, who will take you through the results and

outlook before we take questions.

Blair Turnbull

Slide 4 – Business update

Kia ora, and good morning, everyone.

Thank you for joining us for our 2024 financial results.

And thank you Michael for those kind words.

Slide 5 - Results summary

Here is a summary of our results, which demonstrate Tower’s positive

operational and business performance.

Sustained GWP growth and enhanced business efficiencies, continued

improvements in claims performance along with unusually benign weather in

New Zealand and the Pacific, have delivered a positive result for shareholders.

This strong result is underpinned by our strategy of delivering simple and

rewarding customer experiences combined with our use of digital technology

and data.

It has been enabled by the more than $150m we’ve invested in the past five

years in digitisation and data, operational capability such as our Suva hub and

streamlining our business. Investments that are now supporting growth and

efficiency and continuing to build our business resilience.



5


I will talk through these points in more detail shortly, but first, an overview of

our performance this year.

Slide 6 – Our performance - positive operational and business performance

Gross written premium for the year to 30 September 2024 increased to $595

million, up 15% on FY23, excluding divested portfolios. This was predominantly

driven by prior period rating increases designed to mitigate the impacts of

inflation, crime and increased reinsurance costs following the 2023

catastrophe events.

Customer numbers decreased by 2% to 305,000, partly due to our tightened

risk appetite for high-theft motor vehicle models. Tower reduced high-risk

motor policies by 5,000 in the year.

We expect to see growth in customer numbers in FY25, as we target higher

quality risks, enabled in part, by our risk-based pricing capability to target

customers with lower risks.

Rating increases, enhanced processes, a reduction in motor theft claims due to

targeted underwriting actions and lower crime, as well as calmer weather in

comparison to prior years have led to an improvement in the BAU claims ratio

to 48%.

We are pleased to see our management expense ratio improve to 31.4%,

thanks to our GWP growth combined with disciplined cost control and

improved efficiencies from investments in digitisation and streamlining the

business.



6


Tower experienced no large events incurred during the financial year, which is

rare. Looking back over the past 20 years, there have only been two years

where no large events costs have been incurred.

Large event costs for FY24 were negative $2.3 million, due to the absence of

large events and a favourable revision of prior year large event costs. This is a

reduction from $55.6m of large event costs in FY23.

Reflecting our positive operational and business performance we are reporting

an underlying profit after tax of $83.5m, up from $7.1m in FY23.

Reported FY24 profit is $74.3m compared to a loss of $1m in FY23.

On the basis of these results Tower will pay a full year dividend of 6.5 cents per

share, bringing the total FY24 dividend to 9.5 cents per share.

Slide 7 – Continued premium growth

Premium growth continued in FY24, increasing 15%.

The prior period rating increases that were designed to mitigate the impacts of

inflation, crime and increased reinsurance costs following the 2023

catastrophe events have taken effect and were the predominant driver of the

GWP growth in the year.

In FY24 we were particularly pleased to see our proportion of house policies

increase as we focused more on the home insurance market. Nearly a third of

our house insurance GWP growth came from volume.

In line with risk-based pricing, we offer more favourable pricing to lower risk

vehicles and apply higher premiums to those that our data shows will



7


potentially incur higher claims costs. In FY24 this approach, led to a reduction

of motor policies while GWP from our motor portfolio grew by 13%.

Tower’s adoption of risk-based pricing and underwriting continues to give us a

competitive advantage by enabling more accurate risk selection and pricing. At

the end of FY24 91% of house policies rated low or very low for flood risk, a 1%

improvement from FY23.

We continually review premiums to ensure we provide good value and

competitive prices for our customers, while ensuring that the premiums we

collect cover the costs of the claims we pay out.

As we signaled at the half year, we began to moderate premium increases,

particularly for low-risk assets, in the second half of FY24 as inflation began to

settle.

Our retention rate for our New Zealand risk portfolio remains stable at 77%

with just over half of our customers holding multiple policies with us.

To help our customers manage their insurance and affordability, we

introduced Ways to Save, a My Tower feature for our New Zealand customers

that offers useful tips and options to reduce premiums.

In FY24, 29,000 customers used Ways to Save, with 16% of them making

changes to their cover that resulted in lower premiums. On average, those

who adjusted their premiums through Ways to Save in the year saved $122.

A range of factors have influenced premium increases over recent years

including inflation, crime rates, weather events, reinsurance costs, and supply

chain pressures. While it costs more now to cover our customers’ assets, we



8


continue to manage these impacts through risk-based pricing, and business

efficiencies, which we cover later in this presentation.

Slide 8 – Customer experience improves

Our focus on customer experience combined with our use of digital technology

and data has increased our overall net promoter score to plus 38, up from plus

28 in FY23.

Customer experience improvements have been seen across both our digital

and our contact centre agent assisted customer journeys.

In FY24 in New Zealand, 63% of sales tasks, 45% of service tasks and 64% of

claims tasks were completed digitally.

And active My Tower users increased by 5% to 164,000, demonstrating that

our online journeys continue to resonate with customers.

The benefits of our core platform (now live across the Tower group) and our

300-strong Suva Hub team continue to be realised, contributing to a pleasing

reduction in our sales and service contact centre abandonment rate, now at

8%.

We were pleased to win the first place Supreme Award for Customer Retention

in the New Zealand CRM Contact Centre Awards.

This year Canstar also announced Tower as the winner of its Home and

Contents Insurer of the Year Award. The independent research panel noted the

outstanding value offered by Tower’s insurance products, especially its

Standard and Plus policy options, which Canstar stated, feature comprehensive

insurance cover at affordable prices.



9


An important part of delivering a positive customer experience is fixing things

when we don’t get them right. We have made significant progress in

remediating customers identified as being owed a premium refund, due to

errors in applying our multi-policy discount.

We have identified multi-policy discount refunds of around $12 million

(including GST and interest) owed to 66,000 customers and had repaid $11.5m

by 31 October.

While addressing outstanding remediations, we are also identifying and

developing strategies to tackle the root causes of these incidents. This

approach aims to increase business resilience, support positive customer

experiences and promote sustainable growth.

Slide 9 – Continued improvement in MER

We are pleased to have achieved a further reduction in MER to 31.4% in FY24,

down from 32% in FY23.

It’s clear that the $150m Tower has invested in the past five years is realising

benefits in targeted growth and operational efficiency.

The expansion of our Suva hub has delivered well in this respect. In the year

our Suva team answered 55% of all New Zealand sales and service calls to

Tower; an increase from 16% in FY23.

In FY24 we completed the sales of our Solomon Islands business and Vanuatu

subsidiary. Tower stopped offering commercial rural insurance in November

2023. The planned exit of existing customers at renewal will be completed at

the end of January 2025.



10


Our commission ratio continues to improve, reducing to 1.5% in the year from

2.1% in FY23 partly due to legacy portfolio purchases and referral

arrangements that have reduced total commission.

By decommissioning 71 virtual servers in the year and moving more of our

services to the cloud, we have continued to streamline and modernise our

technology delivery.

Slide 10 – BAU claims ratio significantly improves

In FY24 our BAU claims ratio has significantly improved from 55% in FY23 to

48.1%, thanks to effective pricing and underwriting, efficient claims

management and external factors.

Targeted rating, across our house and motor portfolios have reduced claims

from higher risk policies. General rating increases implemented to offset

inflation and increased reinsurance costs are also continuing to earn through.

Tower’s efforts to improve processes and implement new technology to

deliver faster and more efficient claims management include a new digital

motor assessing tool. Online motor and house claims are also now

automatically being allocated to repairers.

Among others, these initiatives have seen the number of open BAU claims in

New Zealand halve and claims turnaround times decrease by a third.

External factors have also played a part with calmer weather reducing the

frequency of claims in New Zealand and the Pacific region. Motor vehicle crime

also reduced in the year.



11


Slide 11 – Underlying business performance improving consistently

Underlying NPAT excluding large events was $81.9m in FY24.

As you can see from this chart, we are steadily improving our underlying

business performance and improving half on half.

The fundamentals of our business are performing well, and investment income

is also benefiting from higher interest rates.

Slide 12 - Financial performance title slide – Paul Johnston

I will now hand you over to our Chief Financial Officer, Paul Johnston who will

talk you through the details of our financial performance this year.

Slide 13 – Group underlying financial performance

Thank you, Blair.

Looking at the consolidated results, we can see that GWP has increased by

$68.5m, or 15% - excluding divested portfolios - compared to FY23. This

growth was driven by an appropriate mix of rating and underwriting actions,

alongside modest volume growth in the house portfolio.

Rating and underwriting actions have significantly improved the BAU claims

ratio to 48.1%.

The absence of large weather events in the year, combined with a favourable

release from the FY23 Vanuatu cyclones has contributed another $2.3m to the

result.



12


Pleasingly, the MER improved to 31.4% as a result of expense efficiencies and

scale.

Higher investment balances and yields have seen net investment income

increase by $7.2m to $21.6m.

Underlying NPAT including large events is $83.5m up from $7.1m, reflecting

Tower’s resilience and agility following catastrophic weather events

experienced in FY23.

Towers’ FY24 reported profit after tax is $74.3m, up from a loss of $1m in

FY23. Reported profit was impacted by an increase to customer remediation

costs and a strengthening of the Canterbury Earthquake provision.

Slide 14 – Movement in underlying NPAT

Here is the bridge between underlying NPAT in FY23 of $7.1m and underlying

NPAT of $83.5m in FY24.

You can see that calmer weather with no large event costs, business growth,

improving BAU loss ratio, and higher investment income have driven this

result.

Reported profit was impacted by a strengthening of the Canterbury

Earthquake provision, an increase to customer remediation costs and

provisions, and other non-underlying costs partially offset by the gain on the

sale of the Solomon Islands business.




13


Slide 15 – BAU claims ratio reduced

Our BAU claims ratio has significantly improved to 48.1%, driven by Tower’s

prior period rating increases and efficient claims management. Additional

external factors including inflation easing, lower crime and relatively benign

weather have also contributed to this improvement.

As shown in these graphs, inflation has impacted the insurance industry in

recent years, but it began to level off in late FY24. For example, the severity (or

cost) of motor claims went up 4% in FY24, compared to 12% in FY23.

Our rating ability allows us to respond quickly to external factors. For our

customers, as inflation began to stabilise later in the year, we implemented

more moderate premium increases, particularly for low-risk assets.

This included a review of motor pricing performance for the 100 most common

makes and models (including all years and specifications), representing 70% of

Tower’s motor portfolio. The review led to a reduction in premiums of varying

levels for 71% of the models evaluated.

Risk-based pricing predominantly helps protect Tower from large events.

However, we’re also seeing it contribute to the improved BAU claims ratio.

Each year, Tower pays out on claims for weather events that don’t meet our

$2m threshold for a large event, and these are reflected in BAU claims.

Our efforts to attract lower-risk properties have contributed to house

frequency flattening in FY24 and severity increasing at a slower rate.

As previously mentioned, external factors, including calmer weather, have also

played a role.



14


Slide 16 – Continued improvement in management expense ratio

We are pleased to see our management expense ratio continue to reduce with

a 0.6% improvement over the year to 31.4%.

Increased scale from business growth and efficiencies enabled a 4.2%

reduction in MER with a further 0.3% decrease in net commission expenses

which was mainly driven by an increase in reinsurance profit share commission

income.

A 0.4% increase in amortisation was due to prior year technology capital

investments while continued spend on investments to deliver key strategic

initiatives drove a 1.4% rise.

Staff and other costs increased by 2%, partly driven by inflation. This year-on-

year increase also reflects the payment of staff incentives in FY24. These were

not paid in FY23 due to the company missing nominated NPAT targets

following the catastrophe events that year. This increase was partially offset by

cost efficiencies.

Slide 17 – Higher investment returns

In FY24 net investment income increased to $21.6m before tax, this was $7.2m

higher than the same period last year.

This increased income is due to a larger investment balance and high interest

rates in FY24.

Tower maintains a conservative investment policy with a focus on high credit

quality and liquidity, and a target duration for the core investment portfolio of

six months.



15


Our strategy has mitigated the impact on our profit from macroeconomic

factors and mark-to-market movements in the past. This allowed us to benefit

from higher interest rates through FY23, and up to HY24, when the running

yield on the core investment portfolio began to decrease, finishing the year at

4.9%.

The outlook is for interest rates to continue decreasing through FY25.

Slide 18 – Reinsurance programme

Tower’s reinsurance strategy shields against the volatility of major events,

ensuring financial flexibility to support growth and robust solvency.

Our reinsurance arrangements for FY25 include catastrophe reinsurance of up

to $800m for two events. This was increased from $750m in FY24 due to

business growth. The excess for each event would be $18.8m.

We have also purchased coverage for a third event of up to $85m with a $20m

excess.

Our FY25 retention limits and programme premium increases were mitigated

by our three-year rolling contracts. And we were pleased to sign a significant

multi-year contract with a global reinsurer that will help to mitigate future

increases.

Tower’s FY25 large event allowance is $50m. Full utilisation of the large events

allowance is assumed in our guidance for the year.

We have recorded one large event in FY25 so far - the Dunedin flooding event

in October, which has an estimated cost of around $3m.



16


Slide 19 - Capital and solvency position

Our increased profits, along with the progress made in settling catastrophe

event claims and collecting the recoveries from reinsurers this year, have

further strengthened our solvency position. As a result, our parent solvency

ratio has improved to 212%, compared to 139% in FY23.

Tower’s regulatory solvency position is calculated under the new Reserve Bank

of New Zealand (RBNZ) Interim Solvency Standard (ISS), which applied from the

start of this financial year.

We note that the RBNZ is consulting on a further amendment to the ISS, which

is expected to be issued and effective this financial year.

The proposed changes to the ISS are likely to have a material impact on

Tower’s regulatory solvency position and will reduce the solvency margin.

Accounting for the final dividend, we are now holding $171.4m above the

regulatory minimum capital required for solvency. This is an increase from

$79.8m as at 30 September 2023.

In accordance with the ISS, the planned capital return of $45m is not yet taken

into account in the solvency position and is expected to be deducted from

solvency in FY25.

We were pleased that the RBNZ reduced Tower’s licence condition from $15m

to $0 in the year and Tower’s A- credit rating was reaffirmed by AM Best.

The Board has declared a final dividend of 6.5 cents per share, bringing total

dividends for FY24 to 9.5 cents per share.



17


The Board has also conditionally approved a return of NZ$45m of excess

capital to shareholders, by way of mandatory share buyback. These conditions

are noted in our market announcement.

Slide 20 – Looking forward

Thank you. I will now hand back to Blair who will provide an update on our

guidance and priorities for FY25.

Blair Turnbull

Thank you, Paul.

Slide 21 – Focus on customer experience and targeted growth

In the year ahead Tower will continue to invest in creating leading customer

experiences, while targeting the right risks at the right price.

This includes applying landslide and sea surge risk ratings to policy renewals

and adding these perils to our automated customer-facing quote-to-buy tool,

where customers can already see their home’s risk ratings for earthquake and

flood hazards.

We will continue our focus on increasing new business from home insurance

policy sales by targeting high quality risks, and at the same time we expect our

motor book to grow as our pricing becomes more attractive for lower risk

vehicles.

And we will continue to grow through new partnerships including Kiwibank,

homes.co.nz and HealthCare Plus who joined us in FY24.



18


In the coming year we are looking to further increase customer retention by

improving our online policy renewal experience.

Through these initiatives and more, we are targeting annual underlying GWP

growth of 10%-15% out to FY27.

Slide 22 – Continuous efficiency & process improvements

In FY25, we will continue to focus on delivering efficiency and process

improvements.

We are aiming for 80% of all New Zealand service tasks to be completed via

digital channels by the end of FY27, up from 45% in FY24.

Following the launch of our new motor assessing system in the year, we plan

to launch a new house assessing system in FY25. This is all about continuing to

drive down assessment times and repair costs.

We also intend to implement a new contact centre platform in FY25 designed

to deliver greater frontline efficiencies and improved customer experience.

As we examine and improve our systems and processes, we are committed to

addressing the root causes and applying lessons from the errors that led to

customer remediations.

Our work to streamline the business continues with the New Zealand

commercial rural portfolio due to complete migration from Tower in January,

another step towards decommissioning our last legacy technology system in

New Zealand.



19


This graph shows the journey Tower has taken to steadily improve our

efficiency over the years. This work will continue with Tower targeting an MER

of less than 26% in FY27.

Slide 23 – Fostering sustainability

Ultimately, we want to have a positive impact on people and the environment

so we will continue to invest in initiatives and products that foster

sustainability and future climate change resilience.

An important part of our business strategy is to build an effective and

distinctive staff culture across our New Zealand and Pacific locations.

We’re committed to making Tower an even better place to work, enabling us

to attract and retain talented people and empower our teams to show up in

the best way possible for our customers.

This slide shows some of our FY24 people-related metrics that we are proud of,

and we are continually working to further improve. These highlight our staff

engagement and gender pay equity scores and our people’s growing

participation in our community volunteering initiatives and our various cultural

representation groups.

Last week we were particularly pleased to win the Excellence in Workplace

Diversity, Equity & Inclusion award at the 2024 ANZIIF New Zealand Insurance

Industry Awards.

You can read more about some of these achievements in our annual report

released today alongside our results materials.



20


We also released our inaugural climate statement today. This covers in detail

the climate change risks and opportunities we’ve identified, along with our

strategic responses aimed at supporting a low-emissions and resilient future.

Innovation is key to our ongoing success. One cost-effective alternative to

traditional insurance is parametric insurance, which we have now

implemented in three Pacific nations. In FY24, we partnered with global

insurtech, CelsiusPro, to offer this product on a digital platform.

Our goal is to reach 10,000 parametric insurance policies by the end of FY25.

Tower has set an absolute, science-aligned reduction target of 21% for our

Scope 1 and 2 emissions by the end of the 2025 financial year, using FY20 as

the base year. Our FY24 Scope 1 and 2 emissions show a 20% reduction on

FY20 levels and a 9% reduction on FY23.

We continue to support education that addresses climate change and

promotes a more equitable, resilient, and sustainable future by awarding five

university scholarships in New Zealand and Fiji in FY24.

Slide 24 – FY25 guidance and future targets

In FY25 Tower expects GWP growth - excluding revenue from sales of

subsidiary operations - of between 10% and 15%.

We have set a prudent large events allowance of $50m.

We expect further improvements to our management expense ratio which we

anticipate will be less than 29%.

We are targeting a combined operating ratio of between 87% and 89%.



21


Assuming full utilisation of the $50m large events allowance Tower anticipates

underlying NPAT to be between $50m and $60m.

We are targeting a return on equity of between 13% and 17%.

You can see we have also disclosed a range of medium-term targets for FY27.

Slide 25 – FY25 priorities

Here are our priorities for FY25 which have a key focus on enhancing our

customer experience.

We will continue to work through customer remediations and associated

proceedings, while implementing the lessons learnt from these experiences.

We are also focused on the Conduct of Financial Institutions (CoFI) regime

which comes into force in March 2025, to further advance fair customer

outcomes.

This year we are implementing a new end-to-end customer management

solution to further enhance the customer experience, increase efficiency and

reduce risk by being a single source of the truth.

And we will expand risk-based pricing and offer greater transparency of

customers’ landslip and sea surge risks.

And, importantly, we will continue to pursue efficiency, digitisation, and

process improvements that deliver benefits to our customers and drive value

for our shareholders.



22


These priorities aim to continually enhance our customer experience,

positioning us to deliver sustainable premium growth and attractive long-term

shareholder returns.

Thank you for your time this morning, I will now hand back to the operator to

ask for questions.

---

Distribution Notice


Classification: Sensitive






Section 1: Issuer information

Name of issuer Tower Limited

Financial product name/description Ordinary Shares

NZX ticker code TWR

ISIN (If unknown, check on NZX

website)

NZTWRE0011S2

Type of distribution

(Please mark with an X in the

relevant box/es)

Full Year X Quarterly

Half Year Special

DRP applies

Record date 16/01/2025

Ex-Date (one business day before the

Record Date)

15/01/2025

Payment date (and allotment date for

DRP)

30/01/2025

Total monies associated with the

distribution

1


$24,666,459


Source of distribution (for example,

retained earnings)

Retained earnings

Currency NZD

Section 2: Distribution amounts per financial product

Gross distribution

2

$0.06500000

Gross taxable amount

3

$0.06500000

Total cash distribution

4

$0.06500000

Excluded amount (applicable to listed

PIEs)

N/A

Supplementary distribution amount $0.00000000

Section 3: Imputation credits and Resident Withholding Tax

5


Is the distribution imputed No imputation


1

Continuous issuers should indicate that this is based on the number of units on issue at the date of the form

2

“Gross distribution” is the total cash distribution plus the amount of imputation credits, per financial product, before the deduction of

Resident Withholding Tax (RWT).

3

“Gross taxable amount” is the gross distribution minus any excluded income.

4

“Total cash distribution” is the cash distribution excluding imputation credits, per financial product, before the deduction of RWT.

This should include any excluded amounts, where applicable to listed PIEs.

5

The imputation credits plus the RWT amount is 33% of the gross taxable amount for the purposes of this form. If the distribution is

fully imputed the imputation credits will be 28% of the gross taxable amount with remaining 5% being RWT. This does not constitute

advice as to whether or not RWT needs to be withheld.


Classification: Sensitive

If fully or partially imputed, please

state imputation rate as % applied

6


N/A

Imputation tax credits per financial

product

N/A

Resident Withholding Tax per

financial product

$0.02145000

Section 4: Distribution re-investment plan (if applicable)

DRP % discount (if any)


Start date and end date for

determining market price for DRP


Date strike price to be announced (if

not available at this time)


Specify source of financial products to

be issued under DRP programme

(new issue or to be bought on market)


DRP strike price per financial product


Last date to submit a participation

notice for this distribution in

accordance with DRP participation

terms


Section 5: Authority for this announcement

Name of person


authorised to make

this announcement

Blair Turnbull

Contact person for this

announcement

Emily Davies

Contact phone number +64 21 815 149

Contact email address emily.davies@tower.co.nz

Date of release through MAP


28/11/2024






6

Calculated as (imputation credits/gross taxable amount) x 100. Fully imputed dividends will be 28% as a % rate applied.

---

Tower Limited
Climate Statement 2024

Contents
Introduction

2

Tower’s business model and strategy

5

Tower’s value chain

7

Tower’s FY24 operational footprint

8

Tower’s approach to climate change

9

Current climate-related impacts

10

Understanding our possible futures

12

Tower’s climate change scenarios

14

Climate-related risks and opportunities

17

Climate-related risks

18

Climate-related opportunities

23

Anticipated impacts

24

Our greenhouse gas (GHG) emissions

25

GHG emissions

27

GHG emissions target

28

Our emissions reductions initiatives

29

Measuring our performance

30

Risk management

31

Integration of climate risks in Tower’s Risk Management Framework

32

Governance

34

Governance framework

34

Climate-related skills and capabilities

39

Appendices

40

1 ContentsCLIMATE STATEMENT 2024

Climate change is not just an
environmental issue; it is a

fundamental challenge to Tower’s

operations as a general insurer.

More than any other industry, insurance is particularly

exposed to the direct financial and operational

consequences of climate-related changes, affecting

both our business and the communities we serve. From

rising sea levels and increased frequency of extreme

weather events to shifts in temperature patterns,

ecosystem disruptions and societal shifts, these changes

directly affect the risks we underwrite and the claims

we manage. This increasingly necessitates that climate-

related issues are not peripheral concerns, but integral to

our day-to-day business operations.

As a result, climate-related risks and opportunities

are important to our operations, from underwriting

and risk management to claims handling and

corporate governance.

Tower’s stated purpose is to inspire, shape, and

protect the future for the good of our customers and

communities. As we confront the realities of climate

change and take decisive actions that we consider are

in the best interests of our customers, shareholders,

and stakeholders, this purpose takes on even

greater significance.

Managing climate-related risks and opportunities

For more than 150 years, Tower has operated across

New Zealand and the Pacific. We have weathered

catastrophic storms, innovated our technology and

evolved our products to support customers through

challenges. Managing climate-related risks and seizing

opportunities, as illustrated by our climate change

scenarios, will be increasingly important to our business

as a general insurer.

In 2021, Tower was New Zealand’s first insurer to

announce the implementation of risk-based pricing

for inland flooding. Since then, we have refined and

expanded our modelling to encompass other climate-

related risks. We have also empowered our customers

by sharing hazard ratings, helping Kiwis understand

the risks their homes face. In FY25, we will introduce

ratings for landslide and coastal risks, further arming our

customers with knowledge they need to prepare.

As we plan for the future, we budget for an increasing

number of large weather events to manage their

financial impacts with $45m set aside in Financial Year

2024 (FY24). Although FY24 was unusual with Tower

recording no large weather events, we understand that

a future shaped by climate change will bring a range of

extremes, including periods of deceptive calm. Tower

remains steadfast in our conservative approach to

managing these risks.

Our reinsurance programme is designed to shield us

from the volatility of large events. In 2024, we secured

comprehensive cover at competitive rates for our

home, motor, boat, and commercial portfolios across

New Zealand and the Pacific, backed by some of the

world’s largest reinsurers.

Innovation is key to our continued resilience. We are

developing cost-effective alternatives to traditional

insurance, including parametric insurance, which we

have already successfully implemented in three Pacific

nations. Beyond managing climate-related risks, Tower

is committed to advancing our sustainability strategy,

as detailed in our 2024 annual report, addressing

our broader environmental, social, and governance

(ESG) impacts.

Introduction

CLIMATE STATEMENT 20242 Contents

Michael Stiassny

Chair

Graham Stuart

Audit Committee Chair

While Tower has made significant strides in managing
climate-related risks and opportunities, we are at

the beginning of our climate reporting journey. We

recognise we have much work to do as we embark

on transition planning.

Understanding our risks and opportunities

As Tower continues to implement our current climate-

related strategies, we have taken significant steps over

the past two years to deepen our understanding of the

climate-related risks and opportunities that lie ahead.

The External Reporting Board (XRB) requires Tower to

describe the scenario analysis we have undertaken

to help identify these risks and opportunities and

to stress-test our strategy’s resilience. Tower has

developed scenarios that allow us to rigorously

examine our business model and strategy. Through this

process, we have identified a comprehensive set of

climate-related risks—both physical and transitional—

and opportunities. Our analysis has revealed that

the most pressing climate-related impacts for Tower

are the financial and operational consequences of

increasingly frequent and severe weather events.

Alongside this, ensuring the continued availability of

affordable insurance products is a critical focus area.

We have also delved into the potential impacts of

government interventions in the insurance market,

keeping a watchful eye on developments in international

markets. Tower is committed to providing expert advice

to government representatives on the likely impacts

of such interventions in New Zealand and the Pacific.

We advocate for sensible actions that safeguard our

customers and communities.

Supporting a low-emissions and

climate-resilient future

At Tower, we are committed to managing our climate-

related risks and opportunities, with the objective of

ensuring our business remains resilient for generations

to come.

In the years ahead, we intend to expand risk-based

pricing to help navigate the impacts of severe weather

events. We will innovate our products to tackle

affordability issues and address insurance retreat,

while advancing our data and technology capabilities

to enhance pricing, underwriting, and operational

efficiencies during large events. Crucially, we recognise

that earning the trust and support of our stakeholders

in an uncertain world is vital to our resilience. We

are committed to upholding strong relationships by

delivering fair and transparent insurance services. A key

challenge before us will be aligning our products and

services with the transition to a low-emissions future

while bolstering our resilience to climate change. In

FY24, Tower took the first steps towards measuring

emissions from our underwriting portfolios and parts of

our supply chain. Over the coming year, we will further

develop our emissions measurement and reduction

plans as we embark on our transition journey.

Strong governance and risk management

underpin our climate change responses

Our Board of Directors provides Tower’s highest level

of climate change governance. Beyond ensuring

compliance with the Climate Standards, the Board steers

our response to climate-related risks and opportunities,

setting appropriate metrics and targets. Tower’s Board

and Management are committed to navigating the

changing climate in support of our customers and

communities in New Zealand and the Pacific, and in

the long-term interests of our shareholders. We look

forward to sharing our progress with you in future

climate statements.

Scope of the Climate Statement and Statement

of Compliance

As a listed, licensed New Zealand insurer Tower qualifies

as a climate reporting entity (CRE). This report is Tower

Limited’s first group climate statement and is prepared in

accordance with section 461ZA of the Financial Markets

Conduct Act 2013 and the Aotearoa New Zealand

Climate Standards (NZ CS 1, NZ CS 2 and NZ CS 3)

published by the XRB in December 2022 (CRD Regime).

It covers our New Zealand and Pacific operations and

outlines the steps we are taking in support of a low-

emissions and climate-resilient business for the future.

This climate statement has been prepared for our

primary users, who we have identified as primarily

being potential and existing shareholders and asset

managers. All financial information is provided in NZD.

Our corporate structure is further explained under the

Governance Section on page 34.

CLIMATE STATEMENT 20243 Contents

Chair,
Michael Stiassny

Audit Committee Chair,

Graham Stuart

Tower has chosen to use the following adoption provisions in this first Climate Statement

Adoption provision Rationale

1. Current financial impactsThis adoption provision has been used to provide additional time to

develop a methodology linking financial impacts with climate-related

risks and opportunities. Financial impacts information regarding 2023

weather events is included in this disclosure to help illustrate climate-

related risks associated with future large weather events.

2. Anticipated financial impactsAs set out above.

3. Transition planningTower will provide a Transition Plan in its second-year Climate Statement

based on work undertaken in FY24 and FY25.

4. Scope 3 greenhouse gas (GHG) emissionsSelected operational Scope 3 emissions have been included to maintain

consistency with previous Annual Report inclusions,

5. Comparatives for Scope 3 GHG emissionsAs described above, our material Scope 3 inclusions are in development.

6. Comparatives for metricsComparatives for all relevant metrics will be developed alongside our

work on current and anticipated financial impacts and the development of

our Transition Plan.

7. Analysis for trendsTrend analysis will be conducted as part of the ongoing development

of metrics.

Statement of Compliance

These climate-related disclosures comply with Aotearoa New Zealand Climate Standards issued by the XRB.

This Climate Statement is dated 28 November 2024 and is signed on behalf of Tower by:

CLIMATE STATEMENT 20244 Contents

Tower’s products cover:
House

Contents

Motor

CaravanLandlord

Boat

Pet

Travel

Business

MotorbikeMotorhome

Parametric cover

(for cyclone and rainfall -

only in the Pacific)

Tower’s business model is customer-focused. We deliver

general insurance products and services directly to

customers via digital platforms and phone, using data

to enhance customer service and streamline processes.

Our commitment is to provide fair and transparent

services, with customer care at the heart of everything

we do.

Operationally Tower is structured around the ways our

customers interact with our business: via claims, service

(renewal, payments and queries) and new business (new

and existing customers), both via our digital channels

and our phone lines.

Tower provides general insurance products to customers

in New Zealand, Fiji, Cook Islands, Samoa, American

Samoa and Tonga.

Tower’s business model and strategy

5 ContentsCLIMATE STATEMENT 2024

Our purpose
To inspire, shape and protect the future for

the good of our customers and communities.

Our vision

Ta tātou kaupapa

To deliver beautifully simple and rewarding

experiences that our people and our

customers rave about.

Our strategy

To be the best direct personal lines and

SME insurer in our selected markets differentiated

through digital and data, fair and transparent,

and with customer care in everything we do.

Our values

We do

what’s right

Our people

come first

Our customers

are our compass

Progress

boldly

Our strategic pillars

LEADING

CUSTOMER

EXPERIENCE

Succinct, easy

customer

experiences

across the

lifecycle

OPERATIONALLY

EFFICIENT

Digitise and

automate core

processes and

leverage

geographical

footprint

EFFECTIVE &

DISTINCTIVE

CULTURE

An inclusive,

diverse and risk

aware culture.

Empower our

people to

achieve

great things

RESILIENT

Manage volatility

and deliver

sustainable

outcomes for all

stakeholders

6 ContentsCLIMATE STATEMENT 2024

Tower’s value chain
Tower’s full value chain is depicted in the diagram below.

Content within our Climate Statement related to our

scenario analysis, assessment of climate-related risks and

opportunities, and governance encompasses all aspects

of our value chain, across our New Zealand and Pacific

operations. Content relating to GHG emissions excludes

partners, reinsurers and shareholders.

Inspire, shape and protect

the future for the good

of our customers and

communities.

We pay claims directly

to customers or pay

suppliers to fulfil

customers’ claims.

Shareholders

receive shares

in the company

and Tower aims

to provide an

appropriate return

on investment.

Customers pay

premiums to

protect their risks

or assets

Our shareholders

provide capital,

enabling us to

grow and operate.

OUR PEOPLE

& EXPERTISE

Our reinsurers

compensate us when

large risks occur.

Our people enable

us with their skills,

expertise and

commitment.

We provide our people

with a positive culture,

attractive benefits and

career development.

OUR CUSTOMERS

REINSURERS






















































































































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We build mutually

beneficial partnerships with

data, technology, servicing

and banking partners.

Partnerships enable new

products and services and

drive service, efficiency

and quality gains.

OUR PARTNERS

& SUPPLIERS

We invest premiums (less

costs) to hold in reserve

for potential future claims.

INVESTMENTS

SHAREHOLDERS

CLIMATE STATEMENT 20247 Contents

Map not to scale
1

All figures are as at 30 September 2024.

2

Gross Written Premium (GWP) includes all operations during the year.

3

Scope 1 and 2 greenhouse gas emissions tonnes of carbon dioxide equivalent (tCO

2

e).

Pacific

New Zealand

Tower’s FY24 operational footprint

1

GWP

2

GWP

2

customers

customers

policies

policies

staff

tCO

2

e

3

tCO

2

e

3

staff

$48m

$547m

22,000

283,000

35,000

575,000

322

175

127

593

New Zealand

Vanuatu

Samoa &

American

Samoa

Tonga

Fiji

Cook

Islands

8 ContentsCLIMATE STATEMENT 2024

Product innovation –
developing new products

to help address affordability

challenges and support

the transition to lower

emissions assets.

2.

Data and technology

– investing in enhanced

data and technology to

continually improve our

underwriting and pricing and

to better support customers

through large events.

3.

Maintaining our social licence

to operate – upholding

strong relationships with our

shareholders, reinsurers,

government representatives

and industry stakeholders,

and keeping pace with the

changing expectations of

customers and communities.

4.

Risk-based pricing –

managing risk at an

increasingly granular level.

1.

Tower’s approach to climate change

As the global and domestic economy transitions

towards a low-emissions, climate-resilient future,

Tower recognises the need to develop a climate

resilient business for the long term.

Our strategy for managing climate-related risks and

leveraging opportunities aligns with our broader

business strategy and builds on our existing

sustainability strategy.

It centres on four main approaches:

Reducing our emissions is an important aspect of our

sustainability strategy and our operational emissions

have reduced by 20% from our 2020 baseline year.

Further details are provided in the Measuring our

performance section on page 30. We will disclose

further details in our FY25 transition plan and

Climate Statement.

CLIMATE STATEMENT 20249 Contents

FY24FY23FY22FY21FY20FY19FY18FY17FY16FY15FY14
$10m$10m

$7m$7m

$12m$10m

$7m

$9m

$25m

$0m$0m$0m$0m

$10m

$14m

$13m$14m

$19m

$18m

$37m

$14.7m

$10.5m

$222m

$5m

Current climate-related impacts

Catastrophic and large weather eventsPhysical impacts

Over the past 10 years Tower has experienced an

increasing frequency and severity of large weather

events that may be linked to a changing climate. As

shown in the graph, the five-year rolling average of large

event costs for Tower up to the financial year ending

30 September 2024 increased by $4.2m, compared to

the ten-year average.

In a departure from recent norms, no large weather

events were recorded in FY24 and Tower is reporting a

profit of $74.3m. This volatility related to climate change

presents challenges for Tower in our modelling and

financial planning. We continue to take a conservative

approach to these to support our financial resilience.

Reinsurance costs increased following the events of

2023 due to the need to purchase additional reinsurance

and price increases by reinsurers in response to the

changed risk environment.

Similarly, Tower reviewed its risk appetite in affected

areas, resulting in more properties being deemed to

have high flood risk in our model. Combined with rising

inflation, these impacts contributed to insurance pricing

increases in FY23 and FY24 for customers with higher

flood risks as policies renewed.

Net costs

Gross costs

5-yr average – net cost

10-yr average – net cost

NB Tower measures large events as those which have a net cost to Tower of more than $2m. Division of net and gross values are approximate, based on internal records.

CLIMATE STATEMENT 202410 Contents

Transition impacts
An early indicator of the transition to a low emission,

resilient economy is the development of the

climate-related disclosure regime with mandatory

requirements for climate reporting entities including

Tower. While not currently material, Tower’s

resourcing and compliance costs have increased to

meet the climate-related disclosure requirements.

Opportunities have also arisen from the increased

focus on transparency on climate-related issues.

These include a growth in the support services

available to businesses such as GHG emissions

calculation tools, climate adaptation solutions and

collaboration opportunities.

2023 Catastrophe event impacts

In 2023 New Zealand and the Pacific experienced

several catastrophic weather events consistent

with climate change projections. These were North

Island weather events, Cyclone Gabrielle, Cyclones

Judy and Kevin in Vanuatu, and the Auckland

floods. The impacts on Tower were:

• $38m net impact to Tower, excluding

reinsurance reinstatement.

• $1m loss after taxation, versus a profit of $18.9m

in the previous financial year.

• 10,057 claims of $208 million from the Auckland

and upper North Island weather event and

Cyclone Gabrielle alone.

• Five years’ worth of large house claims received

in two weeks (Auckland floods and Cyclone

Gabrielle).

These combined weather events put significant

demand on our frontline claims teams and

assessors, with flow on effects to other business

units supporting the claims response. Tower

demonstrated resilience by leveraging our

geographically dispersed workforce, redeploying

our Fiji and Rotorua employees to phone lines and

utilising key supplier relationships. As of June 2024,

97% of all these claims were settled.

These events are detailed in our 2023 Annual

report (page 12-14). The experience underscores

how climate-related risks are already impacting our

business and our customers.

CLIMATE STATEMENT 202411 Contents

The NZ CS requires disclosure of the scenario analysis
process Tower has undertaken to identify climate-related

risks and opportunities. Scenario-based analysis explores

how uncertain, forward-looking variables might logically

interact to create plausible future states. The purpose

of Tower’s scenarios is not to predict the future, but to

identify and interrogate the assumptions underlying

critical decisions.

Tower’s climate scenarios are based on the Insurance

Council of New Zealand’s (ICNZ) shared climate

scenarios for the insurance sector. In 2022, Tower

participated in a New Zealand insurance industry

initiative to co-design these industry scenarios.

Scenario development

In 2023 Tower engaged KPMG to facilitate the entity-

level scenario development and analysis process with

a cross functional working group of executives and

senior leaders. Through a series of workshops, this group

translated the ICNZ climate change scenarios to Tower’s

business, strategy and operations in New Zealand and

our Pacific markets in line with XRB guidance.

Tower’s climate change scenarios use, as a base,

the same framework architecture, quantitative and

qualitative parameters, and narrative storylines as the

ICNZ scenarios. However, they were adapted to better

reflect our business operations, focusing on:

• The potential physical impacts of climate change in

the Pacific, given our geographic distribution.

• Navigating financial markets during disruption to

highlight possible impacts on our investment portfolio.

Analysis undertaken

These scenarios were analysed in a series of workshops

by a selected cross-functional group of Tower executives

and senior leaders. The group assessed Tower’s strategy

and operations against the three climate change

scenarios, identifying a range of physical and transitional

impacts. These impacts were then assessed against

the three identified time horizons and prioritised by

likelihood and potential impact.

Understanding our possible futures

Through this process, Tower identified a long list of 42

impacts and implications, which were further assessed

via our climate-related risk management and strategy

processes to develop the climate-related risks and

opportunities outlined later in this section.

Tower’s climate change scenarios and climate-related

opportunities were reviewed by the Sustainability and

Climate Change Steering Committee and approved

by the Tower Board. Tower’s climate-related risks were

reviewed by the executive-level Management Risk

and Compliance Committee (MRCC) and the Board

Risk Committee.

The scenario analysis was a standalone process

designed specifically to address the CRD Regime

requirements. As our approach to climate reporting

matures, Tower will consider integrating climate

change scenario analysis into our business strategy

development processes.

2022

Summary of scenario development process

2023

2024

Management level and Board approvals

of scenarios and climate-related risks

and opportunities

ICNZ collaboration to

develop Insurance

Sector scenarios for NZ

Scenario analysis to

identify climate-related

risks and opportunities

Workshops with Senior

leaders to test scenarios

Tower senior leader

workshops to develop

Tower-specific scenarios

1.2.3.4.5.

CLIMATE STATEMENT 202412 Contents

Scenario architecture, socioeconomic pathways and rationale for selection
Tower’s climate change scenarios build upon the ICNZ scenarios which were based, in turn, on the Network for Greening the Financial System (NGFS) scenarios. The below table sets

out Tower’s scenario architecture, how Tower’s scenarios align with relevant local and international socioeconomic pathway parameters and the rationale for selection.

Tower’s scenario architecture

ParametersOrderly 1.5ºCDisorderly >2ºCHothouse >3ºC

Global emissions and

socioeconomic pathway

parameters

Representative Concentration Pathway

(RCP) 2.6

Intergovernmental Panel on Climate Change

(IPCC) Shared Socioeconomic Pathway

(SSP) 1-2.6

RCP4.5

IPCC SSP2-4.5

RCP7.0

IPCC SSP3-7.0

Global physical risk

pathway parameters

Network for Greening the Financial System

(NGFS) Net Zero 2050

NGFS Delayed TransitionNGFS Current Policies

New Zealand-specific

emissions, transition and

socioeconomic pathway

parameters

NZ Treasury Shadow Price ‘High’ Pathway

Climate Change Commission (CCC) ‘Tailwinds’

Shared Policy Assumptions for New Zealand

(SPANZ) ‘100% Smart’

NZ Treasury Shadow Price ‘Medium’

Pathway

CCC ‘Headwinds’

SPANZ ‘Kicking, screaming’

NZ Treasury Shadow Price ‘Low’ Pathway

CCC ‘Current Policy Reference’

SPANZ ‘Homo Economicus’

Rationale for selectionMost commonly used scenario by financial

institutions globally.

Aligned with scenarios already selected by

ICNZ for the General Insurance Sector (and

other sectors).

Meets XRB’s requirement for a 1.5ºC

aligned scenario.

Commonly used scenario by financial

institutions globally.

Aligned with scenarios already selected by

ICNZ for the General Insurance Sector (and

other sectors).

Meets XRB’s requirements for a third

climate-related scenario.

Commonly used scenario by financial

institutions globally.

Aligned with scenarios already selected by

ICNZ for the General Insurance Sector (and

other sectors).

Meets XRB’s requirements for a

>3ºC scenario.

CLIMATE STATEMENT 202413 Contents

This scenario explores Tower’s readiness to rapidly
transform its business in the short term towards a low-

emissions and climate-resilient future, and envisions

that by 2050...

New Zealand has invested in adapting to climate

change, building the country’s resilience. As a result,

reinsurers remain in the region and view the growing

population as a growth opportunity.

The requirement to decarbonise and build resilience

rapidly put strain on some customers, resulting in

financial challenges. However, governments and the

financial sector helped to educate the general public

on climate change, coupling innovative products and

services with transparency around pricing increases.

This meant most were open to new products that

reflected different risks, and social policies were in place

to support those who struggled to afford them.

The Pacific has benefitted from international support

and funding to improve its resilience, but sea level

rise and extreme weather events have impacted

most nations. Migration has meant that new talent

with regional knowledge has entered New Zealand’s

workforce. Collaboration across the Pacific region has

been an important driver of action against climate

change by government and businesses, as has

emerging technology.

Across the region, offerings like parametric insurance

and risk-based pricing emerged quickly, allowing

insurers to better cost their risk and provide realistic

cover to customers. New Zealand’s substantiated

‘clean, green’ reputation, alongside its embrace of new

technology such as AI, helped attract international and

domestic talent.

Organisations that were early, vocal actors in the

transition to a net zero economy benefitted from

positive sentiment from customers, communities

and stakeholders. Those that were able to fulfil and

substantiate their commitments enjoyed increased

market share. However, the window was small; those

that didn’t move quickly had to work harder to catch up

and transition.

While capital markets underwent a sharp-but-short

period of volatility and loss, organisations that prioritised

climate-smart resilience in their investment portfolios

were well-positioned to ride the post-transition wave.

Organisations that stepped into the challenge of

climate change and diversified their offerings early were

attractive for investors.

Policy ambition:2050 warming:

<1.5°C1.6°C

NZ Pacific

Mean annual temperature

change 2050

1.6°C1.8°C

Mean sea level rise22cm20.4cm

Severity of physical riskLow

Severity of transition riskModerate

Policy reactionImmediate & smooth

Regional policy variationMedium

Technology changeFast

Carbon dioxide removalMedium

International and domestic policy settings aim to limit

total warming by end-of-century to less than 1.5°C.

Orderly scenario – Net Zero 2050

Tower’s climate change scenarios

Our climate change scenarios are summarised in the high-level data points and narratives below.

CLIMATE STATEMENT 202414 Contents

Global emissions peak in 2030, then drop sharply.
As a result of delayed action, deeply destabilising

policies are required to keep total warming below

potentially catastrophic levels.

The disorderly, delayed transition scenario explores

Tower’s resilience to an especially condensed and

disruptive transition in the medium term and depicts

a future whereby 2050...

The region (New Zealand and Pacific) is just starting

to recover from a costly, painful and profoundly

disruptive global transition to our low emissions,

climate-resilient economy.

General Insurers were deeply bruised by the scope

and scale of extreme flooding in 2037. However, most

business models cope with the physical impacts of

climate change.

Without leadership from, and timely investment by

government, small insurers struggle to compete with

more innovative peers with global backing, in terms

of products, pricing models, regulatory compliance,

or reputation.

Some organisations were slower than others to

acknowledge or address the enterprise level risks that

climate change posed to their business model and

strategy. Where different countries moved at different

speeds, those taking a compliance-led approach found

their response fragmented. Most organisations took

several years to understand the full potential of transition

plans and failed to achieve any first-mover (or even

fast-follower) advantage. This also meant customers

struggled to compare providers and understand how

to improve the resilience of their assets until later in

the transition.

Difficult decisions had to be made by organisations

that suffered reputational damage during the transition.

Streamlining business models and focusing on larger

markets meant insuring higher risk areas like the Pacific

became less feasible.

Policy ambition:2050 warming:

<2.0°C1.8°C

Severity of physical riskHigh

Severity of transition riskLow

Policy reaction

Continuation of

current policies

Climate technology changeSlow change

Carbon dioxide removalLow use

Regional policy variationLow variation

NZ Pacific

Mean annual temperature

change 2050

1.8°C2.0°C

Mean sea level rise25cm22cm

Disorderly scenario – delayed transition

CLIMATE STATEMENT 202415 Contents

Current climate policies in New Zealand and
abroad are sporadic and weak. Any policy changes

are insufficient to limit total warming to 2.0°C.

The hot house, current policies scenario was

designed to explore how the collective failure to

cut emissions might steadily erode value in the long

term. This scenario depicts that by 2050...

Startling new technologies (enabled by advances in

AI) have benefited insurers, their customers, and the

global economy. However, this formidable ‘tailwind’

has been overpowered by the cumulative impact of

increasingly intense and frequent natural disasters and

has not always been used for good.

Some assets have become stranded due to global

changes to climate policies and insurers that

were slow to capitalise on the opportunities that

presented themselves during the climate transition

are responsible for underwriting these with expensive

insurance products.

General Insurers have been particularly hard hit – though

less so in countries like New Zealand that benefit from a

relatively benign climate (as compared, for example, to

Australia). New Zealand also benefitted from the way in

which its government facilitated early adaptation to the

physical impacts of climate change.

Customer needs are more bespoke due to the changed

environment with a greater need for specialist advice

and specialist policies. Offerings in regional markets

differ across insurance providers as the market for

insurance becomes increasingly unprofitable and

unaffordable for the average family. Data has become a

commodity and has increased drastically in price.

Insurers withdrew early on from high-risk areas in

New Zealand, leaving some communities stranded.

After some time and concurrent natural disasters, the

same approach is taken with the Pacific nations as they

become less viable and the long-term outlook is poor.

Policy ambition:2050 warming:

+3.0°C+2.0°C

Severity of physical riskHigh

Severity of transition riskLow

Policy reaction

Continuation of

current policies

Climate technology changeSlow change

Carbon dioxide removalLow use

Regional policy variationLow variation

NZ Pacific

Mean annual temperature

change 2050

2.0°C2.0°C

Mean sea level rise39cm23cm

Hot house scenario – current policies

CLIMATE STATEMENT 202416 Contents

Climate-related risks
and opportunities

Our work to identify potential climate-related risks and

opportunities that may affect Tower commenced in

2023 and was further refined in 2024. These risks were

assessed under the three climate-related scenarios

outlined in the previous section.

Alongside the development of our three scenarios,

Tower selected three time horizons to assess the

related risks and opportunities. These time horizons

were selected to align with the ICNZ scenarios and

are independent of our business strategy and planning

cycles, which are based on a three-year forward-looking

view and reviewed annually.

Time horizonPeriod

Short2023-2025

Medium2026-2035

Long2036-2050

CLIMATE STATEMENT 202417 Contents

Climate-related risks
In total, 26 climate-related risks were identified. Of

these, five inherently high risks identified during our risk

assessment process (see page 31 Risk management) are

considered material and included in the table below on

page 19.

Physical and transition risks

Physical risks, as defined in NZ CS 1, relate to the

physical impacts of climate change. These risks can be:

• Acute, such as those related to extreme weather

events like Cyclone Gabrielle, or

• Chronic, due to longer-term shifts in weather patterns,

such as changes in precipitation, temperature, or sea

level at a regional or national level.

Tower does not directly own or lease assets that are

materially vulnerable to acute or chronic climate-related

physical risks. However, our customers do, and the

potential risks to their assets – and the subsequent risks

to our business – have been identified and assessed for

disclosure. These risks comprise the largest proportion

of Tower’s material risks.

As New Zealand and the world transitions to a low

emission, climate-resilient economy, the context for

insurance will likely alter and present new challenges.

These challenges, defined as transition risks, include

changes in government policy, legislation, markets,

technology and societal behaviours and expectations.

Transition risks make up a larger proportion of Tower’s

climate risks than physical risks (69%). However only one

transition risk has been assessed with a high inherent

severity and therefore is considered material.

Tower recognises that transition risks may increase

in severity over time. Tower will continue to monitor

these and reassess their materiality in line with our Risk

Management Framework. We also recognise that some

risks can be categorised as both physical and transition

and this is reflected in the material risks table below.

The following graph shows the distribution of risks

according to risk type and severity.

Physical

1

3

1

Physical

& Transitional

1

2

Transitional

11

1

6

Distribution of risks

High

Medium

Low

CLIMATE STATEMENT 202418 Contents

Identified climate-related risks and associated anticipated impacts
A description of our inherently high risks, their risk type, anticipated impact, existing mitigations and assessed magnitude

against each scenario and time horizon are detailed in the table below.

RiskRisk typeDescription

Anticipated

business impact

Current strategies

Regions

affected

Scenario

Time horizons

ShortMedLong

Operational stress

from climate

impacts.

PhysicalIncreasing extreme

weather events

subject Tower

to substantial

operational stress

that reduces its

ability to adapt.

Operational stress

due to volume and

complexity of claims.

Reputational damage.

Lack of specialist

resource may affect

operational response.

Prioritising events

responses over

progressing

business strategy.

Claims transformation

programme to automate

and streamline

claims processes.

Resource diversification

via Suva Hub and

strategic partners.

Development of large event

response plan.

New

Zealand

Pacific

Orderly

Disorderly

Hothouse

Significantly

larger scale

extreme weather

events in the

Pacific region.

PhysicalExtreme weather

resulting in repeated

large loss events.

Providing

comprehensive

insurance in Pacific

markets becomes

unviable.

Parametric insurance to

diversify offering

Efficient digital operations to

manage costs.

Divestment of Pacific

subsidiaries at high risk

from weather related

large events.

Pacific

Orderly

Disorderly

Hothouse

Legend:

Risk remains the same

Risk increasesContinuing to assess change

CLIMATE STATEMENT 202419 Contents

RiskRisk typeDescription
Anticipated

business impact

Current strategies

Regions

affected

Scenario

Time horizons

ShortMedLong

Financial stress

from climate

impacts.

PhysicalRepeated large-scale

extreme weather

events subject

Tower to substantial

financial stress due

to high volume and

costs of claims.

Accumulated financial

losses.

Insufficient reinsurance.

Insufficient resources.

Higher costs of capital.

Reduced investor

support.

Enhanced hazard data

and risk selection, risk-

based pricing to minimise

exposure to high-risk

assets and communication

with reinsurers regarding

improvements to risk profile.

Increasing large events

budget in financial planning.

Increasing reinsurance

cover.

Product innovation

such as parametric to

diversify offering.

New

Zealand

Pacific

Orderly

Disorderly

Hothouse

Affordability

of reinsurance

diminishes

TransitionReduced access to

reinsurance for all

perils (or certain)

perils and at short

notice leads to

price increases.

Increased reinsurance

premiums.

Increased product

development costs to

offer alternative cover.

Risk based pricing –

as above.

New

Zealand

Pacific

Orderly

Disorderly

Hothouse

Legend:

Risk remains the same

Risk increasesContinuing to assess change

CLIMATE STATEMENT 202420 Contents

RiskRisk typeDescription
Anticipated

business impact

Current strategies

Regions

affected

Scenario

Time horizons

ShortMedLong

Scope, speed and

scale of climate

change physical

and/or transition

impacts outpaces

Tower’s ability

to adapt.

Physical/

Transition

New Zealand and the

Pacific experience

multiple large

weather events in

quick succession,

flood risks and

coastal hazards

become frequent

occurrences

in increasing

geographies.

Diminished customer

experience leads

to brand and

reputational impacts.

Difficulty retaining

staff due to increased

workloads.

Financial impacts

resulting from claims

errors and/or reduced

customer growth.

Substantial increase

in operational costs for

data and technology,

models.

Capital shortages pose

challenges in optimising

opportunities.

Geographical distribution

of operations.

Digitisation to automate

processes and improve

customer experience.

Developing an agile culture.

Robust strategic and

financial planning to

mitigate financial risks.

New

Zealand

Pacific

Orderly

Disorderly

Hothouse

Legend:

Risk remains the same

Risk increasesContinuing to assess change

CLIMATE STATEMENT 202421 Contents

Transition
risks currently

assessed as

medium

Risk typeDescription

Anticipated

business impact

Current strategies

Regions

affected

Scenario

Time horizons

ShortMedLong

Government

intervention and/

or societal shifts

in behaviour.

Medium

Transition

High levels of

government

intervention.

Attraction and

attrition of skilled

employees.

Changes in

technology.

Changing motor

vehicle ownership

trends.

Changes in banks’

lending criteria.

Reputational damage

from unintended

consequences of

interventions.

Customer needs/

expectations outpace

product design as NZ

transitions to net zero.

Comprehensive

insurance cover

becomes unviable

leading to customer

impacts. Increased

regulatory pressure

adding to financial

and human resource

constraints.

Closely monitor

societal trends.

Product innovation/

customer propositions.

Participate in submissions

on government proposals.

Engagement with local

and central government

representatives directly and

via ICNZ.

Pricing transparency.

New

Zealand

Pacific

All

Legend:

Risk remains the same

Risk increasesContinuing to assess change

CLIMATE STATEMENT 202422 Contents

Climate-related opportunities
While climate-related risks are front of mind when

developing climate strategy and mitigation, the scenario

analysis process also identified potential opportunities

for Tower. The highest priority identified opportunities

are outlined below. These apply to all Tower’s

climate change scenarios, across all time horizons in

New Zealand and our Pacific markets.

Our strategy to innovate will be increasingly important

as the transition to a low emission, climate resilient

economy presents the need for new products that

reflect societal and economic shifts. One example of our

innovation is parametric insurance in the Pacific, which

aims to enhance insurance affordability and accessibility

in this market. While parametric insurance is currently

only a small part of our business and revenue, Tower

sees an opportunity to expand its market share in the

future, both in New Zealand and the Pacific.

In the coming year, our transition planning will focus

on refining our product innovation approach to bolster

resilience and accelerate the move towards lower-

emissions assets.

We have also identified the opportunity to develop

industry partnerships that benefit customers and other

stakeholders, which could strengthen the insurance

industry’s future resilience. Examples of this include:

• ICNZ’s collaboration on government proposal

responses for climate change adaptation

and resilience.

• ICNZ’s collaboration to estimate emissions from

motor repairers, reducing the reporting burden on

these suppliers.

Tower FY24 climate-related opportunities

OpportunityOpportunity typeDescriptionBusiness impactCurrent strategiesTime horizons

Enhanced brand

and reputation.

TransitionNew products and

attractive pricing that

address affordability

issues and / or support

the transition to lower

emissions assets.

Supports growth

Enhanced brand

reputation

Parametric insurance

Risk-based pricing.

Working towards B-Corp certification.

Contributing to public discourse on climate change

impacts directly and via sustainability and climate-

change focused corporate memberships.

Product innovation.

Short

Medium

Long

A more resilient

insurance industry.

TransitionIndustry partnerships that

benefit customers.

Supports efficiency for

insurers, ability to offer

improved pricing.

ICNZ collaboration on responses to Government

proposals i.e. Climate Adaptation Framework.

ICNZ pilot to estimate emissions from

motor repairers.

Short

Medium

Long

CLIMATE STATEMENT 202423 Contents

Anticipated impacts
Tower used scenario analysis to model the expected

impacts on its future business.

The modelling used a ‘top down’ approach, taking

external data and trends from Tower’s climate change

scenarios and applying these to Tower’s business with

assumptions spanning out to 2050 relating to:

• Population growth

• Dwelling growth

• Transition to Electric Vehicles (EVs) and vehicle

ownership rate assumptions

• Tower’s expected market share of target markets

• Claims estimates

• Proportion of dwellings in high hazard risk areas

• Growth of multi-unit dwellings

• Stormwater infrastructure investments

• Potential public interventions in the general

insurance market.

Tower notes there is significant uncertainty in

assumptions spanning out to 2050. The benefit

of using a top-down modelling approach is to

identify the factors most likely to significantly impact

Tower’s business performance over the period. This

model presented a practical solution, considering

available data, extended time horizons, and systemic

variables. This analysis was applied across the three

Tower scenarios.

The potential impacts for Tower to monitor are

summarised below:

• Financial and operational impacts from increased

frequency and severity of weather events across NZ

and the Pacific.

• Customer affordability challenges due to increasing

insurance costs (through increased weather

events, BAU frequency, increasing return on

investments costs).

• Government intervention to mitigate affordability and/

or insurance retreat.

• Societal shift in demand for products through

changing transportation trends such as increased use

of public transportation and uptake of EVs.

Tower has begun working with data suppliers to

scientifically estimate the anticipated increase in climate

change-related claims costs through to 2050.

Our approach to transition planning

A key climate-related priority for 2025 is to develop

a transition plan for Tower. Our preparation has

commenced with actions to upskill key staff on transition

planning, measure emissions from scope 3 sources and

consider appropriate metrics and targets.

We have opted to apply Adoption Provision 3 under NZ

CS 2 for the transition planning aspects of our strategy.

We intend to integrate climate change transition

planning into our 2025 business strategy and financial

planning processes.

Capital expenditure and investment

As a general insurer, managing climate-related risk is a

core component of Tower’s business as usual activities.

Tower invests in enhancing our natural hazard modelling

and pricing capabilities annually.

During Tower’s annual strategic planning process,

executive leaders evaluate material risks and

opportunities, and strategic decisions. These are then

escalated to the Board for oversight, guidance and

investment decisions. This process includes assessing

climate-related risks and opportunities, which in recent

years has led to investments in parametric insurance

and risk-based pricing. The Board approves funding for

further proposition, investigation and development, and

considers initiatives for inclusion in the business strategy

and annual business plan.

The annual purchase of reinsurance to manage the

financial impacts of large events, including potential

climate-related events, is considered under Tower’s

reinsurance strategy and approved by the Board.

Tower’s capital level is influenced by loss history, which

in turn can be influenced by climate related risks

and impacts. Capital requirements are determined

by the products we develop and sell, and the risk

levels associated with those assets. For instance, a

house insurance policy requires Tower to hold more

capital than a motor insurance policy, due to higher

replacement costs. As the industry transitions to a

low-emissions, climate resilient future, expanding into

different asset classes, will result in different capital

requirements. These decisions are made in accordance

with Tower’s capital management process.

Tower has an annual operational budget for sustainability

initiatives and compliance with the Climate-related

Disclosures (CRD) regime. This includes the costs of

measuring emissions, consultancy support, and climate

change and sustainability training.

CLIMATE STATEMENT 202424 Contents

Tower has been calculating its GHG emissions since
2020, in accordance with the requirements of the

Greenhouse Gas Protocol. We used an operational

control consolidation approach to account for emissions

reported by both location and market-based emission

factors. Total emissions are reported using the location-

based approach.

To date our GHG inventory has included Scope 1 and

2 emissions for New Zealand and Pacific operations

and selected Scope 3 emissions as detailed below.

Our base year is 2020, the first year of our five-year

Sustainability Strategy. Restatements made are provided

in Appendix 4.

In our first year of climate-related reporting we have

elected to apply adoption provision 4 of NZ CS 2 which

exempts Tower from disclosing all or some of its Scope

3 GHG emissions. Tower has chosen to disclose a subset

of Scope 3 emissions in line with previous annual report

inclusions, please see Appendix 4 for the sources that

have been excluded this year. The methods, assumptions

and estimations used in calculating our GHG emissions

are also included in Appendix 4.

The following illustration summarises relevant emissions

sources for Tower’s operations (it does not depict all

potential emissions sources and includes sources that

may be reported in future years).

Our greenhouse gas (GHG) emissions

Legend for icons provided in following tables.

CLIMATE STATEMENT 202425

Scope 3

Upstream

Indirect Emissions

Scope 1 & 2

Direct Emissions

& Electricity

Scope 3

Downstream

Indirect Emissions

Contents

Scope 3 sources disclosed for FY24 are detailed in
Appendix 4 and include:

Emissions source

Business travel: flights and accommodation

– NZ and Pacific, taxis and rental vehicles –

NZ only

Employee commute – NZ and Pacific

Work from home – NZ and Pacific

Waste – NZ only

Purchased goods and services: paper use –

NZ only

Water supply – NZ and Pacific

All other relevant Scope 3 emissions from our upstream

and downstream value chain will be assessed for

materiality in FY25.

In 2024, we began assessing Scope 3 emissions related

to our wider upstream and downstream business

activities, focusing on emissions sources material to

our business. Tower is currently working on four areas

to prepare for disclosing material Scope 3 emissions in

future disclosures:

ICNZ/Cogo pilot for motor repair emissions

Tower is participating in an industry working

group coordinated by the ICNZ, involving four

other insurers. This group has launched a pilot

programme to calculate claims emissions

from motor repair services, in partnership with

sustainability fintech Cogo. The pilot provides

motor repair suppliers with free access to Cogo’s

Carbon accounting software, Carbon Manager,

for a five-month period. Using supplier spend and

activity data, the software generates emissions

intensity figures for each participant. This enables

insurers to calculate their share of emissions based

on their spend with motor repair suppliers for

customer claims.

The initiative seeks to simplify emissions reporting for

collision repair businesses as businesses in the claims

supply chain, as they will face increased pressure

to measure and report their emissions footprint in

response to climate-related legislation.

At the date of this climate statement, the pilot

is ongoing, with participants set to evaluate the

approach’s feasibility for future disclosures in FY25.

What opportunities exist to

scale the pilot into a permanent

collaboration across the wider

claims supply chain?

3.

What are the benefits of

adopting a collaborative

approach within the insurance

industry?

2.

How effective is a carbon

accounting tool in reporting

supply chain emissions?

1.

The aim of the pilot is to evaluate:

Calculation of emissions relating to our

underwriting portfolio

Purchased goods and services – ICNZ

collaboration to pilot the assessment of

motor repair provisions related to claims

Assessment of investment emissions

Purchased goods and services –

assessment of supply chain emissions

CLIMATE STATEMENT 202426 Contents

The following table summarises Tower’s emissions from our FY20 baseline year to the FY24 reporting period
FY20 (tCO2e)FY21 (tCO2e)FY22 (tCO2e)FY23 (tCO2e)FY24 (tCO2e)

Scope 1169115300165160

Scope 2207179146166142

Selected Scope 3209295202183

859

Total585399649514

1,161

Footnote: Tonnes of Carbon Dioxide equivalent (tCO

2

e) = unit of measurement for combined GHG emissions represented as carbon dioxide. FY20-23 no employee commute emissions, work from home, Pacific water, Pacific T&D losses reported.

GHG emissions

The largest proportion of Tower’s GHG emissions come

from travel. In FY24 14% of total emissions were from the

operation of our vehicle fleets in New Zealand and the

Pacific, while 17% came from business travel, including

flights, accommodation, taxis and rental cars.

In our first year of undertaking an employee commute

survey (FY24) we calculated associated emissions at 43%

of our total footprint. This addition has resulted in a clear

increase in our overall Scope 3 values along with work

from home emissions.

Our fleet vehicles are crucial for our claims and assessing

teams to meet the needs of our customers. Our business

travel enables us to remain connected across our

geographical locations with colleagues and business

partners and our employee commute emissions reflect

our people’s journeys to work. As a result our approach to

emissions reduction needs to maintain our service value

in these areas. Initiatives to reduce emissions associated

with these sources are provided in the table on page 29.

The chart below shows the breakdown of Tower’s GHG

emissions by source.

Employee commute

Business travel

Vehicle fleet

Electricity

Working from home

Waste and water

Paper

CLIMATE STATEMENT 202427 Contents

Scope 1 and 2 emissions are also calculated as an intensity figure using our total risk numbers as the key indicators1. The intensity results from our base year (FY20) to FY24 are
outlined in the table below. The total emissions intensity per policy show a consistent value before decreasing for FY24. The decrease is related to maintaining policy numbers whilst

reducing emissions.

Emissions intensity in tCO

2

e/risks insured (000s)FY20FY21FY22FY23FY24

NZ intensity0.210.240.130.190.22

Pacific intensity  6.143.868.555.074.55

Total intensity0.670.510.740.530.48

1 Calculated as Scope 1 & 2 emissions divided by average risk count for the year. In this context risk refers to the specific addressable property or risk covered by an insurance policy, e.g., the house, the motor vehicle, or a period of overseas travel. The Pacific intensity figures

include emissions for the Suva hub which provides services in relation to NZ policies.

GHG emissions target

Tower has set an absolute, science-aligned reduction target of 21% for our Scope 1 and

2 emissions by the end of the 2025 financial year, using 2020 as the base year. Our FY24

Scope 1 and 2 emissions show a 20% reduction on 2020 levels and a 9% reduction

on FY23.

This target was established based on the Paris Agreement goal to limit global warming

to 1.5°C. The Paris Agreement goal (UNFCCC 2015) requires emissions to peak before

2025 at the latest and decline 43% by 2030. Tower calculated our reduction trajectory to

2025 on the basis of this ambition.

During FY25 we will revise our target against a 1.5°C global warming ambition using a

science-based methodology and extend it to include our Scope 3 emissions. Assurance

of the target will be obtained through the mandatory FY25 GHG emission disclosures,

and we will explore the viability of an intensity-based metric and target as our

understanding of our material Scope 3 emissions improves.

In taking responsibility for our emissions, our preferred approach is to invest in initiatives

to reduce gross emissions as much as possible. Therefore, there are no offsets applied

to our target.

0

50

100

150

200

250

300

350

400

450

202520242023202220212020

tCO

2

e

Scope 1 & 2 target

Actual emissions

Current GHG target and tracking scopes 1 & 2

CLIMATE STATEMENT 202428 Contents

ScopeInventory itemDetail20232024 to date
1Vehicle fleet fuelTower Policy to only purchase hybrid, plug in hybrid or fully electric Vehicles.

NZ vehicles transitioned, Pacific Island vehicles to follow.

165 tCO2e160 tCO2e

2ElectricityGreenstar Auckland office, Suva meter recently installed.

166 tCO2e142 tCO2e

3Business travelTower’s Sustainable Travel Policy includes an intention (without a target) to

reduce air travel. Tower’s increased presence in Suva has required additional

travel in FY24.

148 tCO2e203 tCO2e

Waste (landfill)

Employee initiatives such as Plastic Free July to encourage waste

minimalisation. Waste volumes have increased in line with increased staff

numbers and office attendance.

6 tCO2e7 tCO2e

2nd year employee

commute/WFH

To be developed.

Second survey to be completed.

Employee commute

WFH

501 tCO2e

29 tCO2e

2nd year supply chain Review of existing ESG supplier requirements to include material

emissions reporting.

2nd year underwriting Current Generate Zero project.

Tower has continued working towards reducing our

Scope 1 & 2 emissions. Since 2022, Tower has had a

policy commitment to purchasing only EVs or hybrid

vehicles. In New Zealand our fleet was fully transitioned

by 2023. In our Pacific locations, our fleet remains

primarily internal combustion engine (ICE) vehicles.

Our emissions reductions initiatives

We recognise that electricity generation in the Pacific

Islands is primarily fossil fuel-based and therefore

conversion to hybrid or EVs is unlikely to generate the

same emission reductions as our New Zealand fleet.

However, there are parallel benefits to moving away

from petrol or diesel vehicles in all locations, including

lower running costs and supporting improvements in

local air quality.

The table below outlines completed or ongoing

emissions calculation and reductions initiatives for

FY23 and FY24. Initiatives slated for completion in

financial year FY25 and disclosure in our second climate

statement are highlighted in cyan.

CLIMATE STATEMENT 202429 Contents

TypeDescriptionMetricFY24 estimates
Transition risksAmount or % of assets or business activities vulnerable to transition risks

% of vehicles insured that are internal combustion

engines (ICEs)

91%

Physical risksAmount or % of assets or business activities vulnerable to physical risks.

% of homes insured that are high flood risk1

3%

Opportunities –

Current

Amount or percentage of assets, or business activities aligned with

climate-related opportunities.

% of electric vehicle (EV) and plug-in hybrid (PHV)

vehicles covered

9%

Capital

deployment

Amount of capital expenditure, financing, or investment deployed toward

climate-related risks and opportunities.

Capital or operating expenditure deployed towards:

• Risk Based Pricing

• Parametric

• Sustainability

• CRD

• Fleet transition

Approx $769K

Internal emissions

price

Price per metric tonne of CO2e used internally by an entity.Tower does not currently set an internal emissions price. To be considered

in FY25.

RemunerationManagement remuneration linked to climate-related risks and

opportunities in the current period – %, weighting, description or amount

of overall management remuneration.

Tower has not set any management remuneration linked to climate-related risks

and opportunities. To be considered in FY25.

1 Limitation for use of flood risk ratings - the definition of “High Flood Risk” is Tower’s own definition and not necessarily a consistent definition with any other public source. Specifically, it relates to insurance risk and cost to repair or replace property relative to the risk of

flooding and not just the chances of flooding happening alone. It also relates to Tower’s own risk appetite and what we consider is “High”, which may differ to others risk appetites or interpretation of the level of risk.

Tower uses various metrics and tools to manage

our business risk indicators, including those relevant

to climate-related risks and opportunities and our

GHG emissions. As we developed our scenarios,

risks and opportunities, strategy and GHG emissions

profile, we assessed the availability of relevant and

appropriate metrics.

The following table describes key metrics related to the

financial impacts of our physical and transition risks and

opportunities, as well as capital deployment.

In our first reporting period we have focused on

identifying the key physical and transition risks and

opportunities and associated metrics. We did not

identify any relevant industry-based metrics in FY24.

Targets related to GHG emissions are provided in

Section 5 above.

Measuring our performance

CLIMATE STATEMENT 202430 Contents

Risk management is central to Tower’s strategic and operational activities and is
underpinned by Tower’s enterprise-wide Risk Management Framework (RMF). The RMF

is approved by the Tower Board and applies to all Tower employees and operations.

Risk management

Risk appetite statement

People

Risk & control

assessments

Obligations

management

Risk governance

Processes

Risk

registers

Fraud risk

management

Capital management process

Systems

Incident reporting

& remediation

Operational

resilience

Primary risk

framework enablers:

Secondary risk

framework enablers:

Risk management

process:

Enabling foundations:

Respond to riskMonitor, assure,

escalate

Assess riskMeasure riskIdentify risk

The RMF sets out guiding principles to enable Tower to identify, assess, monitor and

manage its risk exposures to pursue its strategic objectives. The RMF and its key

components are depicted below:

CLIMATE STATEMENT 202431 Contents

Fundamental to the application of the RMF is Tower’s
Risk Appetite Statement (RAS), which outlines the

Board’s risk appetite against key categories defined in

the RMF. Tower’s Board Risk Committee is responsible for

monitoring the adequacy of the RMF, receiving reports

on key risks, exposures and their management against

the RAS.

The primary executive governance forum for the

RMF is the Tower Management Risk and Compliance

Committee (MRCC) which meets monthly and is

governed by an annually reviewed Charter overseen by

the Chief Risk Officer (CRO).

The RMF is implemented through risk, compliance,

conduct and internal audit processes across each

business function. The executive, senior management

and staff must demonstrate that reasonable steps have

been taken to effectively manage Tower’s risks in line

with the RMF. Responsibilities are assigned to individuals

to manage identified risks, and material changes to

Tower’s risk profile are monitored.

Each business unit within Tower maintains a risk register

that records the likelihood and consequence of risks,

actively identifying, assessing and monitoring the risks

and associated controls. These risks are recorded,

maintained and managed within our Protecht risk

management software platform with clear identification

of the risk owner, inherent risk, risk mitigation(s) and

residual risk scores.

Risk owners are responsible for updating their risks

whenever changes occur that may alter the inherent or

residual risk score. To ensure regular reviews, each risk

is assigned an agreed time period for review. These time

periods may range between 6-monthly and 2-yearly.

The Protecht platform also enables the prioritisation

of all risks, ensuring appropriate escalation in a timely

manner. Risks are prioritized as Low, Medium or High

residual risk status. High residual risks are given priority

for suitable mitigation and raised to the Board for

acceptance or deployment of capital if the risk cannot be

effectively mitigated, and then closely monitored.

Integration of climate risks in

Tower’s Risk Management

Framework

Tower revised its RMF in February 2024 to include

climate-related physical and transition risks as a specific

risk category along with the other key risks facing Tower

across its full value chain. Tower also introduced a

dedicated Climate Risk Forum to regularly review and

monitor its climate risk profile. The Climate Risk Forum

meets quarterly. Additionally, Tower revised its risk

assessment matrix to enable a more focused approach

to risk assessment across the business.

The process undertaken by Tower to assess climate-

related risks followed the approach outlined under the

RMF, as follows:

1. Identify

2. Measure and Assess

3. Respond

4. Monitor, assure and escalate

Identify

Tower conducted a cross-functional workshop to

consider the climate risks and opportunities as part of

the climate change scenario development and analysis.

The workshop and subsequent internal analysis included

all material elements of Tower’s value chain, covering

both New Zealand and Pacific-based operations, as well

as our core supply chain. Some 42 climate related risks

and opportunities were identified during this exercise.

Measure and assess

The identified risks served as the basis for further internal

stakeholder meetings to:

• Refine the risks

• Assign ownership

• Identify key impacted business units

• Complete initial risk and control assessments across

the short, medium and long-term time horizons with

the same duration outlined in the Strategy section.

• Agree appropriate controls against each risk to

mitigate the impact of the risks occurring

CLIMATE STATEMENT 202432 Contents

The data was also divided into specific areas to illustrate
Tower’s overall climate risk profile across each scenario

and time horizon (as detailed within the Strategy section):

• Key Impacted Business Units – by climate related risks

• Climate Risk Categories – Transition & Physical Risks

• Climate Risk Ratings – high, medium, low

• High Inherent Risks – measured under the three

climate scenarios and three time horizons.

Respond

Tower’s response considered each of the climate-related

risks and assigned controls against them to arrive at

a residual risk rating. In line with Tower’s RMF, where a

residual risk is High and cannot be managed through the

control environment, it is reported to the Tower Board

for risk acceptance or otherwise. No climate-related

risks have been identified as unable to be managed

effectively through appropriate controls and actions.

Accountability for managing these risks is assigned to

Tower’s executives and senior management. The suite of

risks provides an overall climate-related risk profile for

Tower and facilitates the monitoring of those risks over

time. Where the nature of the risk changes, the response

to managing that risk may change also.

Monitor, assure and escalate

Due to the nature of Tower’s business and our risk-based

pricing approach, climate-related risks make up five of

our high residual risks. All five of these climate-related

risks have actions in place to monitor and help mitigate.

All material climate-related risks across each of the

identified scenarios and time horizons (as detailed within

the Strategy section) have been recorded in Protecht

and will be reviewed as part of the usual cycle of risk

reviews within each business unit. The Climate Risk

Forum will assist in regular monitoring of the climate risk

landscape and is described on the right.

A comprehensive review of identified risks and

opportunities will be undertaken annually and following

any updates to Tower’s climate change scenarios.

The Climate Risk Forum

The purpose of the Climate Risk Forum (CRF) is to

facilitate discussion, collaboration, and action on

climate-related risks and opportunities.

The CRF convenes internal stakeholders from

various teams to review and share knowledge,

best practices, and innovative solutions. Its goal

is to ensure identified climate-related risks and

opportunities remain current and relevant, and to

address the challenges posed by climate change.

The CRF is composed of climate risk owners and

the Sustainability Manager, with subject matter

experts (SMEs) attending as required. The CRF

meets quarterly to discuss specific climate-related

risks and opportunities, with the first meeting held

in July 2024.

Climate-related risks are considered over the short,

medium and long-term time horizons identified in

the Strategy section page 17.

CLIMATE STATEMENT 202433 Contents

Strong governance underpins our management of
climate-related risks and opportunities.

Tower’s Board of Directors provides leadership within a

framework of prudent and effective controls, enabling

the assessment and management of all risks and

opportunities, including those that are climate-related.

The Board composition is provided in our Annual Report

2024, on page 50.

Details of our governance of climate-related topics in

FY24 are detailed in the table on page 36.

Governance

Governance framework

The Board is responsible for approving and overseeing

Tower’s ESG strategy and reporting. This includes

considering sustainability strategies and oversight of

Tower’s climate-related risks, including physical and

transition risks, and climate-related opportunities.

The Board retains overall accountability for the

development and ownership of climate-related

strategy, transition planning, metrics and targets and

climate-related disclosures.

The Board is assisted in its oversight by its Audit, Risk and

People, Remuneration and Appointments Committees.

Additionally, Tower’s Executive Leadership Team

(ELT) led by our CEO, and topic specific management

committees and forums, sponsor and direct key

elements of our climate statement development.

The roles and responsibilities of each of these bodies,

along with key milestones over the reporting period

are provided in the table on page 36.

In FY24, the Board approved a Climate and Sustainability

Governance Framework, establishing the Company’s

structures and processes for effective oversight and

management of climate-related risks and opportunities.

The following diagram illustrates the key roles,

responsibilities, communication, and decision-making

processes that support the Board in fulfilling its climate-

related governance obligations.

In FY24 climate change risks and opportunities were

integrated into Tower’s strategy development processes.

This included:

• May 2024 – Board consideration of Tower’s climate-

related risks and opportunities identified through the

risk management processes detailed on page 31, and

the process for integrating these into Tower’s overall

strategy and business planning

• July 2024 – Annual Board strategy offsite including

consideration of climate-related risks, opportunities

and associated strategic priorities, alongside wider

business considerations in developing the overall

strategy and business planning.

• July – September 2024 -The outputs of these strategy

discussions were incorporated into the three-year

business strategy and FY25 operating plan, which the

Board approved in October 2024.

CLIMATE STATEMENT 202434 Contents

Climate, sustainability governance framework
Submits

workstream

outputs for

approval and

feedback.

Provide

updates on

performance

against

strategy

development,

metrics and

targets,

submit draft

disclosures

for approval.

FeedbackFeedbackFeedback

Tower Board - overall accountability for overseeing climate-related risks and opportunities, and Tower’s strategy

Audit Committee


Recommends approval on:

Climate change & ESG, scenarios, risks

and opportunities, metrics and targets,

performance and disclosures.


Recommends approval

on: Climate change

& ESG related risks.


Assists with: Board

and Management

and competencies.

Risk Committee

People, Remuneration

and Appointment Committee


Submit Strategy, risks,

opportunities and climate

statement.


Submit Strategy, risks,

opportunities and climate

statement.


Inform intentions for

training and resourcing.

Executive Leadership Team

Sustainability and Climate Change Steerco

Management Forums and Committees

CLIMATE STATEMENT 202435 Contents

Governance bodyRoles and responsibilitiesActivity
Tower Limited Board

of Directors

Overall accountability for climate-related risk and opportunities, transition planning and strategy and

all other disclosures in the company’s Climate Statement.

Monthly progress update on sustainability

and CRD.

February 2024 Board review of CRD workplan

and activities

March 2024 Approval of climate change

scenarios, consideration of climate change risks.

Review of internal CRD record-keeping process

and guidelines.

July 2024 consideration of draft climate change

strategy, draft metrics and targets and GHG

emissions update. Director skills and capabilities

survey completed.

August 2024 update on Board and Management

climate-related skills and capabilities and training.

October 2024 Approval of metrics and targets.

Audit CommitteeThe Audit Committee assists the Board by:

• Overseeing climate-related disclosures and the adequacy of control systems for

climate-related reporting.

• Reviewing climate change scenarios, risks and opportunities, metrics and targets, and

disclosures, and recommending Board approval.

• Agreeing on the scope of the external auditor’s limited assurance of GHG emissions for the

climate statement.

May 2024 Consideration of progress

towards CRD.

Risk CommitteeThe Risk Committee assists the Board by:

• Monitors climate-related risks.

• Assessing the effectiveness of Tower’s Risk Management Framework, strategy, risk appetite,

and risk profile. Ensuring compliance with relevant prudential regulatory requirements,

including climate-related transition risks.

Monthly Chief Risk Officer (CRO) report to Risk

Committee or Board includes climate change

and increased frequency of large events as both

a key strategic risk and a compliance risk. This

report provides updates on work on climate

related risks.

FY24 was a foundational year for establishing our governance processes. The Board approved the Climate and Sustainability Governance Framework in March 2024. Throughout the

year, the full Board considered elements of the climate-related disclosure development on behalf of its committees to ensure progress within desired timeframes. The requirements

of the framework will be fully embedded in FY25.

Table of Governance bodies, frequency of meetings, their roles and responsibilities

CLIMATE STATEMENT 202436 Contents

Governance bodyRoles and responsibilitiesActivity
People, Remuneration

and Appointment

Committee

The People, Remuneration and Appointment Committee assists the Board in its oversight of

remuneration strategy by:

• Recommending whether climate metrics should be included in reward frameworks, and

recommending potential metrics.

• Recommending required skills, capabilities and experience for Board members to ensure the

Board can effectively manage risks and opportunities arising from climate change.

Climate metrics are not currently included in

reward frameworks.

Executive Leadership

Team

With respect to the Climate Statement, the Executive Leadership Team is responsible for:

• The development and execution of Tower’s climate change strategy and transition plan;

• Ensuring that sustainability and climate-related risks and opportunities are considered as part

of investment, underwriting, product design, customer experience, pricing, supply chain and

claims processes;

• Ensuring that all employees are aware of their responsibilities for the identification of climate

change risks and opportunities;

• Ensuring that employees have relevant climate change and sustainability skills and capabilities.

December 2023 Climate change strategy

discussion

May 2024 Workshop on climate change strategy.

June 2024 Completion of Management Skills and

Capabilities Survey.

July- September 2024 Climate-related training

for management and employees.

August/September FY25 Operating plan and

3-year strategic plan development

Management

Sustainability and

Climate Change

Steerco

This Executive-level committee is chaired by the CEO and includes the CRO, Chief Underwriting

Officer and Deputy CFO. It oversees:

• Tower’s progress and performance against sustainability strategy and climate change strategy/

transition plan/ metrics and targets.

• The assignment of resources to ensure sustainability and climate change outcomes are achieved.

• Delivery of Tower’s sustainability reporting and climate-related disclosures to the Board and

its Committees.

Minimum Monthly meetings chaired by the CEO.

Updates on Steerco activities are provided to the

Board in the monthly CEO report.

Key climate-related decisions and information

are raised through appropriate governance

committees as required.

Management Risk

and Compliance

Committee

The Management Risk and Compliance Committee (MRCC) assists Tower Limited to discharge its

management and governance responsibilities for risk including climate-related risk. The primary

purpose of the MRCC is to oversee, manage and approve Tower-wide risk, compliance, and conduct

management practices.

Monthly meetings with summary of Board CRO

report discussed.

Climate Risk ForumThe Climate Risk Forum is comprised of senior leaders from key functions including claims, sales

and service, underwriting, pricing, finance and technology. The Forum will meet quarterly and is

dedicated to identifying, assessing, and monitoring climate-related risks and opportunities and

ensuring appropriate mitigating actions are incorporated into Tower’s strategy and operating plan.

July 2024 First meeting and review of Terms

of Reference

CLIMATE STATEMENT 202437 Contents

Governance bodyRoles and responsibilitiesActivity
Product, Pricing

& Underwriting

Committee

This Committee oversees monitoring, reporting and management of emissions from Tower’s

underwriting portfolios. It will be responsible for:

• Recommending targets for underwriting portfolio emissions reduction to the Sustainability &

Climate Steering Committee.

• Directing underwriting, product and pricing actions to achieve Tower’s sustainability strategy,

climate change strategy, and transition plan (once developed).

• Ensuring alignment of sustainability and climate change underwriting and pricing actions with

Tower’s business strategy and operations.

Monthly meeting

This committee’s contribution to climate-related

disclosures will commence in FY25.

Claims CommitteeThe Claims Committee will oversee monitoring, reporting and management of emissions from

Tower’s claims supply chain. It will:

• Recommend targets for claims supply chain emissions reduction to the Sustainability & Climate

Steering Committee.

• Recommend claims actions that will achieve Tower’s sustainability strategy and climate change

strategy, and transition plan (once developed) to the ELT/Sustainability Steering Committee.

Monthly meeting

This committee’s contribution to climate-related

disclosures will commence in FY25.

CLIMATE STATEMENT 202438 Contents

Board climate skills and capabilities
The Board aims to have an appropriate mix of relevant

skills, with particular competencies in the insurance and

financial services sector.

In FY24, Tower Directors completed an overview training

session with KPMG on CRD Regime requirements.

Additionally, all Directors completed a targeted survey to

assess their understanding and knowledge of climate-

related topics, including:

• Climate change drivers, risks, and opportunities

• GHG emissions

• Climate and ESG legislation

Based on the survey results, where necessary Directors

will undertake further training in FY25 on Climate

and ESG Legal obligations and GHG Calculation

and reporting.

Management climate-related skills

and capabilities

As an insurer, Tower’s teams have existing skills and

capabilities that are highly relevant to managing climate-

related risks and opportunities including general risk

management, actuarial, data management, natural

hazard modelling, finance, governance, and strategy.

Tower has dedicated sustainability roles, including within

senior management. Reporting to the Sustainability and

Climate Steering Committee, Tower’s Head of Corporate

Affairs and Sustainability is responsible for:

• Developing and delivering Tower’s sustainability

strategy, incorporating climate-related goals and

initiatives for the period 2020-2025.

• Leading the delivery of climate-related disclosures,

with support from Tower’s Sustainability Manager.

Since beginning work on the first Climate Statement in

2022, management has invested in building specific

climate change competencies. In 2023, 32 Tower senior

leaders were involved in developing Tower’s climate

change scenarios and risk and opportunity themes,

thereby building awareness of relevant climate-related

issues for Tower.

Climate-related skills and capabilities

In August 2024, select members of the ELT and

senior leaders completed training on climate-related

disclosures and other ESG disclosure obligations with

law firm MinterEllisonRuddWatts.

Between July and September 2024, 41 Tower employees

including senior leaders and staff involved in delivering

climate statements, completed training on the basics

of climate change science. Additionally ELT and other

senior staff involved in climate-related disclosures

received training in sustainability foundations,

including climate-related disciplines and GHG

accounting standards.

Senior staff in our underwriting and sustainability

teams have also completed role-specific training in

sustainability and climate-related issues.

Senior leaders actively working on Tower’s Climate

Statement have included objectives in their FY24

performance plans related to resourcing and completing

their contributions.

Tower also has access to a range of external consultants

for specialist expertise and advice which has been noted

in Board updates throughout the year as appropriate.

CLIMATE STATEMENT 202439 Contents

Appendices
Index – CRD way finder

Appendix 1

CRD sectionsCRD disclosuresTower disclosureAdoption provisions

Governance - To enable primary

users to understand both the role

an entity’s governance body plays

in overseeing climate-related risks

and climate-related opportunities,

and the role management plays

in assessing and managing

those climate-related risks

and opportunities.

(a) the identity of the governance body responsible for oversight of climate-related risks

and opportunities;

(b) a description of the governance body’s oversight of climate-related risks and

opportunities (see paragraph 8); and

(c) a description of management’s role in assessing and managing climate-related risks

and opportunities .

(a) the processes and frequency by which the governance body is informed about

climate related risks and opportunities;

(b) how the governance body ensures that the appropriate skills and competencies are

available to provide oversight of climate-related risks and opportunities;

(c) how the governance body considers climate-related risks and opportunities when

developing and overseeing implementation of the entity’s strategy; and

(d) how the governance body sets, monitors progress against, and oversees

achievement of metrics and targets for managing climate-related risks and

opportunities, including whether and if so how, related performance metrics are

incorporated into remuneration policies (see also paragraph 22(h)).

Section 10:

Governance

Framework pg 35.

Section 10 pg 36

Strategy - To enable primary users

to understand how climate change

is currently impacting an entity and

how it may do so in the future. This

includes the scenario analysis an

entity has undertaken, the climate-

related risks and opportunities an

entity has identified, the anticipated

impacts and financial impacts of

these, and how an entity will position

itself as the global and domestic

economy transitions towards a low-

emissions, climate-resilient future.

(a) a description of its current climate-related impacts;

(b) a description of the scenario analysis it has undertaken

(c) a description of the climate-related risks and opportunities it has identified over the

short, medium, and long term

(d) a description of the anticipated impacts of climate-related risks and opportunities

; and

(e) a description of how it will position itself as the global and domestic economy

transitions towards a low-emissions, climate-resilient future state.

Section 4:

Strategy

Pg 10

Pg 12

Pg 17-23

Pg 19, 24

Pg 9, 24

Adoption provision 1:

Current financial impacts.

Adoption provision 2:

Anticipated Financial

impacts

Adoption provision 3:

Transition planning

Adoption provision 4:

Scope 3 GHG emissions

Adoption provision 5:

Comparatives for Scope 3

GHG emissions

CLIMATE STATEMENT 202440 Contents

CRD sectionsCRD disclosuresTower disclosureAdoption provisions
Risk management - To enable

primary users to understand how

an entity’s climate-related risks

are identified, assessed, and

managed and how those processes

are integrated into existing risk

management processes.

(a) a description of its processes for identifying, assessing and managing climate-

related risks (see paragraph 19); and

(b) a description of how its processes for identifying, assessing, and managing climate

related risks are integrated into its overall risk management processes.

An entity must include the following information when describing its processes for

identifying, assessing and managing climate-related risks:

(a) the tools and methods used to identify, and to assess the scope, size, and impact of,

its identified climate-related risks;

(b) the short-term, medium-term, and long-term time horizons considered, including

specifying the duration of each of these time horizons;

(c) whether any parts of the value chain are excluded;

(d) the frequency of assessment; and

(e) its processes for prioritising climate-related risks relative to other types of risks.

Section 7: Risk

management

pg 31

Metrics and Targets: To enable

primary users to understand how

an entity measures and manages

its climate-related risks and

opportunities. Metrics and targets

also provide a basis upon which

primary users can compare entities

within a sector or industry.

To achieve the disclosure objective, an entity must disclose:

(a) the metrics that are relevant to all entities regardless of industry and business model;

(b) industry-based metrics relevant to its industry or business model used to measure

and manage climate-related risks and opportunities;

(c) any other key performance indicators used to measure and manage climate-related

risks and opportunities; and

(d) the targets used to manage climate-related risks and opportunities, and

performance against those targets

Measuring our

performance

pg 30

Adoption provision 6:

Comparatives for metrics

Adoption provision 7:

Analysis of trends

NZ CS 3

Methods and assumptions, and data

and estimation uncertainty

(a) a description of the methods and assumptions used in the preparation of its climate-

related disclosures where they are not apparent, including the limitations of those

methods.

(b) aspects of its disclosure (including amounts) that involve data and estimation

uncertainty, disclosing the sources and nature of data and estimation uncertainties.

Appendix 5

pg 50

CLIMATE STATEMENT 202441 Contents

CRD sectionsCRD disclosuresTower disclosureAdoption provisions
NZ CS 3

Scenario analysis methods and

assumptions

(a) the climate-related scenarios it has used, including:

i a brief description of each scenario narrative;

ii. the time horizons considered, including endpoints and whether the endpoints

are determined by a year or a temperature target;

iii. a description of the various emissions reduction pathways in each scenario

and the assumptions underlying pathway development over time, including

the scope of operations covered, policy and socioeconomic assumptions,

macroeconomic trends, energy pathways, carbon sequestration from

afforestation and nature-based solutions and technology assumptions including

negative emissions technology;

iv. an explanation of why the entity believes the chosen scenarios are relevant

and appropriate to assessing the resilience of the entity’s business model and

strategy to climate-related risks and opportunities; and

v. the sources of data used to construct each scenario.

(b) how the scenario analysis process has been conducted, including:

vii. whether scenario analysis is a standalone analysis or integrated within the

entity’s strategy processes;

viii. the governance process used to oversee and manage the scenario analysis

process, including the role of the governance body and management;

ix. if modelling has been undertaken, a clear description of what modelling was

undertaken and why the model was chosen as the appropriate model; and

x. which external partners and stakeholders are involved.

Section 3

Understanding

our Possible

Futures

pg 12

Appendix 2

Scenario

Development

pg 43

GHG emissions methods,

assumptions and estimation

uncertainty

(a) a description of the methods and assumptions used to calculate or estimate GHG

emissions, and the limitations of those methods. When choices between different

methods are allowed, or entity-specific methods are used, an entity must disclose

the methods used and the rationale for doing so.

(b) uncertainties relevant to the entity’s quantification of its GHG emissions, including

the effects of these uncertainties on the GHG emissions disclosures.

(c) an explanation for any base year GHG emissions restatements.

Section 5 Our

greenhouse gas

(GHG) emissions

pg 25

Appendix 4

GHG emissions

methodology

pg 45

Statement of complianceAn entity whose climate-related disclosures comply with Aotearoa New Zealand

Climate Standards must include an explicit and unreserved statement of compliance.

Section 1

Introduction

pg 4

CLIMATE STATEMENT 202442 Contents

APPENDIX B: Source data
Boundary condition factor2022-20252026-20352036-2050Data source

ORDERLY: NET ZERO 2050

– NEW ZEALAND

Physical climate changes (RCP 2.6)

Average NZ temperature (1986-2006

baseline + .7°C)

+1.3°C+1.5°C+1.6°C

NGFS Climate impact explorer. ‘Absolute change in air temperature in New Zealand. RCP 2.6’.

Labourproductivity due to heat stress (lower

bound)

-0.1%-0.2%-0.3%

NGFS Climate impact explorer. ‘Change in labour productivity due to heat stress in New Zealand. RCP 2.6’.

NZ land exposed to flooding (1986-2006

baseline) (upper bound)

0.08%0.15%0.2%

NGFS Climate impact explorer. ‘Change in land annually exposed to river floods in New Zealand RCP 2.6’.

Snowfall (1986-2006 baseline)-41%-45%-48%

NGFS Climate impact explorer. ‘Relative change in snowfall in New Zealand RCP 2.6’. Retrieved from:

Sea level rise NZ (1996-2006 baseline)10cm17cm22cm

Ministry for the Environment.(2017). ‘Coastal Hazards and Climate Change. Guidance for

Local Government.’.pp.105.

Days above 25°C

Estimated. Estimated.40%

Climate Change Projections for New Zealand

Ministry for the Environment.(2018). Climate Change Projections for New Zealand: Atmosphere

Projections Based on Simulations from the IPCC Fifth Assessment, 2nd Edition. Wellington: Ministry

for the Environment. Table 1. pp.17.

Social, economic factors

NZ GDP (Billion US$2022/year)232.41 (NZD 355.15)297.55 (NZD 454.69)438.18 (NZD 669.58)

Riahi, K et al.(2017). ‘The Shared Socioeconomic Pathways and their energy use, land use and greenhouse

gas emissions implications: an overview. Global Environmental Change, Volume 42.

NZ population (million)5.15.56.0

As above

Carbon price (NZ$ 2021) $132$230$343

New Zealand Treasury.(2021). CBAx Tool User Guidance. CBAx Tool User Guidance - September 2021

(treasury.govt.nz)

(Orderly follows a high price path) (Assumptions taken from price path noting this is not a market indication

of supply and demand)

Travel by EVs (light passenger vehicles)3%46%100%Climate Change Commission.(2021). ‘Draft advice report charts data and scenario dataset. Tailwinds’.

Change in person-km travel (greatest modal

increase)

Public railCycleCycle As above

Global governance and institutionsStrong and flexible, focus on mitigation and adaptation

Climate Scenarios. ‘To The Toolkit, ‘Socioeconomic Development’. Retrieved from: Primer to Climate

Scenarios

(Orderly follows SSP1)

Market access and trade settingsModerate free-trade, balanced between globalisation and local communities

LifestyleHuman wellbeing

Consumer preferencesSelect for corporates with more sustainability attributes

Technology and innovationMedium. High uptake in sustainable technologies

Land useStrong land use regulation. Tropical deforestation strongly reduced.

Tiriti o WaitangiIndigenous wellbeing and property rights are protected

Frame, B, et al.

(2018). ‘Adapting global shared socio-economic pathways for national and local scenarios’.

Climate Risk Management. Volume 21. Retrieved from: https://doi.org/10.1016/j.crm.2018.05.001

(Orderly follows ‘100% Sustainability’)

APPENDIX B: Source data

Boundary condition factorLocation2025 (short-term)

2035 (medium-

term)

2050 (long-

term)

Data Source

ORDERLY: NET ZERO 2050

– PACIFIC

Physical risk data

Mean Annual Temperature Change

(Average annual temperature (°C) change from pre-

industrial baseline)

Pacific

1

1.5°C1.7°C1.8°C

NGFS Climate impact explorer. ‘Absolute change in mean air temperature in Fiji.’ RCP

2.6’. Retrieved from: NGFS Climate Impact Explorer plus 0.87 °C (Global average

temperature change pre-industrial baseline)

Temperature Days Above 35.0°C

(Annual average number)

Pacific0.250.522.06

Climate change knowledge portal (World bank). Projected Days with Heat

Index Exceeding 35°c – Fiji RCP2.6.

Precipitation (Median)

(% increase in precipitation per year vs 1986-2006

baseline)

Pacific+6.1%+6.1%+6.2%

NGFS Climate impact explorer. ‘Relative change in precipitation (%) in Fiji. RCP 2.6’.

Mean Sea Level Rise

(Centimetres vs 1986-2006 baseline)

Pacific5.5cm10.4cm20.4cm

The IPCC AR6 Sea-Level Rise Projections. SSP1-2.6 2020, 2030 and 2050 Fiji (Suva) .

Retrieved from: Sea Level Projection Tool – NASA Sea Level Change Portal

Expected Damage from River Flooding

(% change vs 2015 baseline)

2

Pacific-8.4%23.7%38.3%

NGFS Climate impact explorer. ‘Relative change in annual expected damage from

river floods in Fiji. RCP 2.6’.

Socioeconomic data

Population

(Millions)

Pacific0.89m0.88m0.82mFIJI population, SSP1.

GDP

(Billion US$2005/year)

Pacific$5.07(NZD 8.57b)$7.71b (NZD 13.04b)

$14.02b (NZD

23.71b)

FIJI GDP, OECD Env-Growth – SSP1. Exchange rate of 1.69 was used to convert

US dollar to NZ dollar

Productivity due to Heat Stress (lower bound)

(% change vs 1986-2006 baseline)

Pacific-5.2%-6.5%-8.1%

NGFS Climate impact explorer. ‘Relative change in labour productivity due to heat

stress in Fiji.’

1.Fiji used as an index for the Pacific to avoid gaps in data availability

2.Expected Damage from River Flooding 1986-2006 baseline data was not available

Consideration of materiality

The NZ Climate Standards require disclosure of

information if it is material according to the definition in

NZ CS 3 .

The information provided in our climate disclosure is

material to Tower’s primary users, who we have defined

as existing and potential shareholders and asset

managers. Contextual information is also provided as it

supports the key elements of the climate statement.

Considerations we use when determining

materiality:

• Primary users – existing and potential shareholders

and asset managers

• Geographical distribution of our operations

• Level of influence

• Level of impact or anticipated impact

• Combined effects

Scenario sources of data

Appendix 2Appendix 3

CLIMATE STATEMENT 202443 Contents

Boundary condition factor2022-20252026-20352036-2050Data source
DISORDERLY: DELAYED TRANSITION

– NEW ZEALAND

Physical climate changes (RCP 4.5)

Average NZ temperature (1986-2006 baseline + .7°C) +1.3°C+1.6°C+1.8°C

NGFS Climate impact explorer. ‘Absolute change in air temperature in New Zealand. RCP 4.5’.

Labour productivity due to heat stress (lower bound)-0.1%-0.2%-0.4%

NGFS Climate impact explorer. ‘Change in labour productivity due to heat stress in New Zealand.

RCP 4.5’.

NZ land exposed to flooding (1986-2006 baseline) (upper

bound)

0.06%0.1%0.2%

NGFS Climate impact explorer. ‘Change in land annually exposed to river floods in New Zealand

RCP 4.5’.

Snowfall (1986-2006 baseline)-41%-45%-56%

NGFS Climate impact explorer. ‘Relative change in snowfall in New Zealand RCP 4.5’.

Sea level rise NZ (1996-2006 baseline)10cm17cm25cm

Ministry for the Environment. (2017). ‘Coastal Hazards and Climate Change. Guidance for

Local Government.’.pp.105.

Days above 25°C

Estimated. Estimated.Estimated.

Ministry for the Environment.(2018). Climate Change Projections for New Zealand: Atmosphere

Projections Based on Simulations from the IPCC Fifth Assessment, 2nd Edition. Wellington: Ministry

for the Environment. Table 1. pp.17.

Social, economic factors

NZ GDP (Billion US$2022/year)220.57 (NZD 337.05)

247.22 (NZD

377.78)

293.11 (NZD447.9)

Climate Change Commission. (2021). ‘Draft advice report charts data and scenario dataset. Headwinds’.

NZ population (million)5.35.86.2

Carbon price (NZ$ 2021)$99$173$343

New Zealand Treasury.(2021). CBAx Tool User Guidance. CBAx Tool User Guidance - September 2021

(treasury.govt.nz)

(Disorderly follows a central price path till 2035 then high price path onwards)

(Assumptions taken from price path noting this is not a market indication of supply and demand)

Travel by EVs (light passenger vehicles)2%28%94%

Climate Change Commission.(2021). ‘Draft advice report charts data and scenario dataset. Headwinds’.

Change in person-km travel (greatest modal increase) Public railPublic railCycle As above

Global governance and institutionsGlobal and national institutions make slow progress towards SDGs.

Climate Scenarios. ‘To The Toolkit, ‘Socioeconomic Development’. Retrieved from: Primer to Climate

Scenarios

(Disorderly follows SSP2)

Market access and trade settingsCurrent trends, intermediate globalization.

LifestyleCurrent trends, some consumerism but also lifestyle

Consumer preferences

Current trends, general push for ESG and climate but intention to

action gap

Technology and innovationModerate technology development, disparities between regions.

Land useCurrent trends, land use incompletely regulated

Tiriti o WaitangiAd-hoc protection for indigenous rights

Frame, B, et al.(2018). ‘Adapting global shared

socio-economic pathways for national and local

scenarios’. Climate Risk Management. Volume 21. Retrieved from:

https://doi.org/10.1016/j.crm.2018.05.001

(Disorderly follows ‘Kicking, screaming’).

APPENDIX B: Source data cont.

APPENDIX B: Source data cont.

Boundary condition factor

Location2025 (short-term)2035 (medium-term)2050 (long-term)Data source

DISORDERLY: DELAYED TRANSITION

- PACIFIC

Physical risk data

Mean Annual Temperature Change

(Average annual temperature (°C) change from pre-industrial

baseline)

Pacific

1

1.5°C1.7°C2.0°C

NGFS Climate impact explorer. ‘Absolute change in mean air

temperature in Fiji.’ RCP 4.5’. Retrieved from: NGFS Climate Impact

Explorer plus 0.87 °C (Global average temperature change pre-

industrial baseline)

Temperature Days Above 35.0°C

(Annual average number)

Pacific0.551.473.18

Climate change knowledge portal (World bank). Projected Days with

Heat Index Exceeding 35°c – Fiji RCP4.5. Retrieved from:

https://climateknowledgeportal.worldbank.org/country/fiji/cmip5

Precipitation (Median)

(% increase in precipitation per year vs 1986-2006 baseline)

Pacific+6.1%+6.1%+7.8%

NGFS Climate impact explorer. ‘Relative change in precipitation

(%) in Fiji. RCP 4.5’.

Mean Sea Level Rise

(Centimetres vs 1986-2006 baseline)

Pacific5.3cm10.1cm22cm

The IPCC AR6 Sea-Level Rise Projections. SSP2-4.5 2020, 2030

and 2050 Fiji (Suva). Retrieved from: Sea Level Projection Tool –

NASA Sea Level Change Portal

Expected Damage from River Flooding

(% change vs 2005 baseline)

2

Pacific-8.4%23.7%57.9%

NGFS Climate impact explorer. ‘Relative change in annual

expected damage from river floods in Fiji.’ RCP 4.5’.

Socioeconomic data

Population

(Millions)

Pacific0.94m0.97m0.97m

FIJI GDP, OECD Env-Growth – SSP2.

GDP

(Billion US$2005/year)

Pacific$5.01b (NZD 8.47b)$7.01b (NZD 11.85b)$11.33b (NZD 19.16b)

FIJI GDP, OECD Env-Growth – SSP2. Exchange rate of 1.69

was used to convert US dollar to NZ dollar.

Productivity due to Heat Stress (lower bound)

(% change vs 1986-2006 baseline)

Pacific-5.2%-6.5%-9.7%

NGFS Climate impact explorer. ‘Relative change in labour

productivity due to heat stress in Fiji.’ RCP 4.5.

1.Fiji used as an index for the Pacific to avoid gaps in data availability

2.Expected Damage from River Flooding 1986-2006 baseline data was not available

CLIMATE STATEMENT 202444 Contents

Boundary condition factor2022-20252026-20352036-2050Data source
HOT HOUSE WORLD: CURRENT POLICIES

– NEW ZEALAND

Physical climate changes (RCP 6.0)

Average NZ temperature (1986-2006 baseline + .7°C) +1.3°C+1.6°C+2.0°C

NGFS Climate impact explorer. ‘Absolute change in air temperature in New Zealand.

RCP 6.0’.

Labour productivity due to heat stress (lower bound)-0.1%-0.2%-0.4%

NGFS Climate impact explorer. ‘Change in labour productivity due to heat stress in

New Zealand. RCP 6.0’.

NZ land exposed to flooding (1986-2006 baseline) (upper bound)0.06%0.09%0.2%

NGFS Climate impact explorer. ‘Change in land annually exposed to river floods in

New Zealand RCP 6.0’.

Snowfall (1986-2006 baseline)-41%-45%-56%

NGFS Climate impact explorer. ‘Relative change in snowfall in New Zealand RCP 6.0’.

Sea level rise NZ (1996-2006 baseline)10cm17cm30cm

Ministry for the Environment. (2017). ‘Coastal Hazards and Climate Change.

Guidance for Local Government.’.pp.105.

Days above 25°C

Estimated. Estimated.Estimated.

Ministry for the Environment. (2018). Climate Change Projections for New Zealand:

Atmosphere

Projections Based on Simulations from the IPCC Fifth Assessment, 2nd Edition.

Wellington:

Ministry for the Environment. Table 1. pp.17.

Social, economic factors

NZ GDP (Billion US$2005/yr)242.77 (NZD 370.98)339 (NZD 518.03)577.33 (NZD 882.22)Riahi, K et al. (2017). ‘The Shared Socioeconomic Pathways and their energy use, land

use and greenhouse gas emissions implications: an overview. Global Environmental

Change, Volume 42.

NZ population (million)5.35.96.9

Carbon price $67$116$173

New Zealand Treasury. (2021). CBAx Tool User Guidance. CBAx Tool User Guidance -

September 2021 (treasury.govt.nz)

(Hot House World follows a low price path) (Assumptions taken from price path noting this

is not a market indication of supply and demand)

Travel by EVs (light passenger vehicles)2%15%81%

Climate Change Commission. (2021). ‘Draft advice report charts data and scenario

dataset. Current Policy Reference’. Retrieved from: Climate Change Commission

Change in person-km travel (greatest modal increase) Public railPublic railPublic railAs above

Global governance and institutions

Strong investment in institutions globally and nationally to enhance

human and social capital

Climate Scenarios. ‘To The Toolkit, ‘Socioeconomic Development’. Retrieved from: Primer

to Climate Scenarios

(Hot House World follows SSP5)

Market access and trade settingsHighly globalised trade

LifestyleConsumerism driven, disjoint from nature

Consumer preferencesEconomic and social preferences

Technology and innovationHigh rates of technology and innovation, including in adaptation

Land useIncomplete regulation, historic trends followed

Tiriti o WaitangiLacking commitment from Government

Frame, B, et al. (2018). ‘Adapting global shared socio-economic pathways for national

and local scenarios’. Climate Risk Management. Volume 21. Retrieved from:

https://doi.org/10.1016/j.crm.2018.05.001

(Hot House World follows “Homoeconomicus”).

APPENDIX B: Source data cont.

APPENDIX B: Source data cont.

Boundary condition factorLocation2025 (short-term)2035 (medium-term)2050 (long-term)Data source

HOT HOUSE WORLD: CURRENT POLICIES

– PACIFIC

Physical risk data

Mean Annual Temperature Change

(Average annual temperature (°C) change from pre-

industrial baseline)

Pacific

1

1.5°C1.7°C1.9°C

NGFS Climate impact explorer. ‘Absolute change in mean air temperature in

Fiji. RCP 6.0’.

Temperature Days Above 35.0°C

(Annual average number)

Pacific0.280.264.34

Climate change knowledge portal (World bank). Projected Days with Heat

Index Exceeding 35°c – Fiji RCP6.0.

Precipitation (Median)

(% increase in precipitation per year vs 1986-2006

baseline)

Pacific+6.1%+6.1%+7.1%

NGFS Climate impact explorer. ‘Relative change in precipitation (%) in Fiji.

RCP 6.0’.

Mean Sea Level Rise

(Centimetres vs 1986-2006 baseline)

Pacific5.1cm10cm23cm

The IPCC AR6 Sea-Level Rise Projections. SSP3-7.0 2020, 2030 and 2050 Fiji

(Suva). Retrieved from: Sea Level Projection Tool – NASA Sea Level Change

Portal

Expected Damage from River Flooding

(% change vs 2005 baseline)

2

Pacific-8.4%23.7%55.9%

NGFS Climate impact explorer. ‘Relative change in annual expected damage

from river floods in Fiji.’ RCP 6.0’.

Socioeconomic data

Population

(Millions)

Pacific0.97m1.04m1.12mFIJI GDP, OECD Env-Growth – SSP3.

GDP

((Billion US$2005/year)

Pacific$5.07b (NZD 8.57b)$6.52b (NZD 11.02b)$9.17 (NZD 15.51b)

FIJI GDP, OECD Env-Growth – SSP3. Exchange rate of 1.69 was used to convert

US dollar to NZ dollar

Productivity due to Heat Stress (lower bound)

(% change vs 1986-2006 baseline)

Pacific-4.7%-6.5%-9.2%

NGFS Climate impact explorer. ‘Relative change in labour productivity due to

heat stress in Fiji.’ RCP 6.0.

1.Fiji used as an index for the Pacific to avoid gaps in data availability

2.Expected Damage from River Flooding 1986-2006 baseline data was not available

GHG emissions methodology

Tower’s GHG emissions have been calculated and

reported in line with the requirements of the GHG

Protocol. We have adopted an operational control

consolidation approach with our accounting boundary

incorporating all Tower offices in NZ and the Pacific.

Tower has contracted the services of Bravegen to assist

with the collation, assessment and loading of emissions

source data into their online Corporate Sustainability

Reporting (CSR) tool.

Bravegen CSR has been developed to meet the

requirements of the GHG Protocol and ISO 14064-1:2018

Greenhouse gases — Part 1: Specification with guidance

at the organization level for quantification and reporting

of greenhouse gas emissions and removals.

The CSR software uses a calculation methodology for

quantifying the emissions inventory using emissions

source activity data multiplied by emission or removal

factors. Emissions factors are primarily sourced

from the 2024 Ministry for the Environment’s (MFE)

Measuring Emissions: A Guide for Organisations unless

otherwise stated. Tower has procured electricity

emissions factors for our Pacific Island facilities from the

International Energy Agency (IEA) derived from the 2006

Intergovernmental Panel on Climate Change (IPCC)

Guidelines and the IEA World Energy Balances data. The

Oceania total emissions factor has been selected for use.

Quantities of each GHG are converted to tonnes of CO

2


equivalent (tCO

2

e) using the global warming potential

from the IPCC Fifth Assessment Report (AR5). The time

horizon is 100 years.

Appendix 4

CLIMATE STATEMENT 202445 Contents

Scope
& GHG

protocol

category

GHG emission

source

Business units

Data collection

unit

Methodology Estimates/assumptions/uncertainty Quality

1Vehicle fleet fuel All business unitsLitresUsing litres of fuel report

and MfE emissions factor

for vehicle classes and

fuel types.

NZ – fuel types and volumes reports provided by

fleet card provider. Electricity used to charge EVs is

not captured or estimated for charging offsite.

Pacific – fuel card data is reported in fuel types and

volumes or spend data from finance system with

current average fuel price to calculate litres where

fuel card data not available. MfE emissions factor

used in absence of Pacific specific factors.

NZ – high

Pacific –

moderate

2Electricity

consumption

(location based

All business unitskWhApply MfE purchased

electricity annual average

emissions factor to kwh

reports from suppliers for

Auckland, and Rotorua

Pacific emissions factor

sourced from IEA.

NZ – invoices from electricity supplier. Auckland

shared space 17.3% attribution to Tower based and

net leased area as a % of total floor area.

Pacific – kWh extracted from invoices or estimated

using average per capita energy use for invoiced

Pacific offices.

NZ – high

Pacific -

moderate

3

Category 3

Fuel- and

energy-

related

activities

T&D losses

electricity

New Zealand

GJ/kWh

Apply MfE purchased

electricity T&D losses

to New Zealand energy

consumption data.

Apply IEA T&D emissions

factor for Pacific.

Supplier invoices. NZ – high

Pacific

– low/

moderate

Restatements

The following emissions source have been restated for the period 2020 to 2023:

• Closure of Papua New Guinea facilities 2023. Base year emission have been adjusted to exclude Papua New Guinea to enable comparable assessment against FY24 emissions.

• Estimation of Vanuatu and Suva retail offices’ Scope 2 emissions in 2024 and applied to all years from FY20. The estimation is based on the average Pacific office kwh electricity

consumption per FTE and multiplied by the FTE numbers for each office. The restatement ensures completeness in Scope 2 reporting for our Pacific Island facilities.

CLIMATE STATEMENT 202446 Contents

Scope
& GHG

protocol

category

GHG emission

source

Business units

Data collection

unit

Methodology Estimates/assumptions/uncertainty Quality

3

Category

6 Business

Travel

Air travelAll business unitsNZ – pkm

Pacific – pkm

Apply MfE 2024 emissions

factor for appropriate flight

class with radiative forcing to

travel agent reports on pkm.

NZ – Air travel booked through contracted provider.

All flight categories (domestic, short haul, long haul),

pkm distances and class of travel reported.

Pacific – Flights primarily booked through travel

agent and reported as above. The remainder are

captured through financial reports on expenditure.

Trip distance is estimated based on most common

trips and $ value where direct supplier data is

not available.

NZ – high

Pacific – low

3

Category

6 Business

Travel

Hotel staysAll business unitsNZ – room

nights

Pacific – spend

data

Apply MfE 2024 emissions

factor to reported room

nights or MfE 2023 for

locations excluded in 2024.

NZ –Accommodation booked through contracted

provider and reported as night stays per person.

Pacific – Estimated room nights based on

spend captured in financial reports. Assumed all

spend included.

NZ – high

Pacific – low

3

Category

6 Business

Travel

Rental carsNew Zealand onlyNZ – kms +

uplift

Apply MfE 2024 rental car

emissions factor to kms.

NZ – Rental car provider report and annual uplift

estimated to take account of bookings made with

other providers based on expense data.

NZ – high

3

Category

6 Business

Travel

Taxi travelNew Zealand onlykms & $ spendApply MfE 2024 emissions

factor for taxi journeys to

reported or estimated kms.

NZ – All taxi travel booked through Corporate Cabs

& Taxi Charge and reported as km travelled in

vehicle category. Expenses also assessed annually

to estimate other journeys based on spend.

NZ – high

3

Category 7

Employee

Commuting

Employee

Commute

All business unitskms travelled

per transport

mode

Apply MfE 2024 emissions

factors for each transport

category using the Abley

Carbonwise commute

emissions web based survey.

NZ & Pacific – Estimated total employee commute

emissions data using employee commute survey

to provide an average commute emissions per

employee extrapolated to total employee numbers.

48% survey response rate across NZ and Pacific

NZ –

moderate

Pacific –

moderate

CLIMATE STATEMENT 202447 Contents

Scope
& GHG

protocol

category

GHG emission

source

Business units

Data collection

unit

Methodology Estimates/assumptions/uncertainty Quality

3

Category 7

Employee

Commuting

Working from

home

All business unitsEmployee dayApply MfE 2024 emissions

factor for employee days

worked from home.

NZ & Pacific – Estimated WFH data calculated

using employee commute survey data extrapolated

to total employee numbers. 48% response rate

across NZ and Pacific.

NZ –

moderate

Pacific –

moderate

3

Category 1

– Purchased

goods and

services

Paper

purchased

New Zealand onlykgApply EPA Victoria 2019

emissions factor for premium

grade paper kg.

Reports provided by paper providers.

Primarily carbon neutral paper purchased with small

quantities of premium quality paper.

NZ – high

3

Category

5 – Waste

generated in

operations.

Waste to landfillNew Zealand onlytApply MfE 2024 landfilled

waste emissions factor to

actual and estimated tonnes.

Reports provided by waste providers.

Auckland landlord agent provides waste quantities

from contracted waste removal contractor based

on 17.3% attribution for shared office space. The %

allocation is based on the Net Leased Area for each

tenant as a proportion of overall floor area.

NZ – high

3

Category 1

Purchased

Goods &

Services.

Water supplyNew Zealand

and some Pacific

locations

kLApply MfE 2024 water

emissions factor to reported

and estimate quantities.

Reports provided by water providers. Auckland

office applies a 17.3% share of data provided based

on the landlord agents report.

NZ – high

Selected

Pacific

locations –

moderate

CLIMATE STATEMENT 202448 Contents

Scope
GHG emission

source

Reason for exclusion

1Hydrofluorocarbon (HFC) emissions from

refrigeration or heating, ventilation, and air

conditioning (HVAC) (NZ and Pacific)

These were estimated to be 0.03% of emissions in FY20 for NZ operations.

We have been unable to clarify the nature of HVAC systems in our Pacific Island offices in FY24. However the largest

office in Suva is newly refurbished and it is considered unlikely any leaks or top ups will have occurred.

As a result we do not believe this will be a significant emissions source.

1Stationary diesel related to back up

generators (Pacific)

Insufficient data available to calculate related emissions. Due to the size of Pacific offices considered likely to

be immaterial.

3Employee vehicle claims (NZ)

In previous years these emission sources were calculated to be less than 1% and continue to remain an immaterial

emissions source.

3Waste generated in operations (Pacific) We have been unable to obtain data for waste generated in our Pacific Island operations in FY24. We do not believe

this will be a significant emissions source.

3Value chain emissions from:

• Purchased goods & services

• Capital goods

• Transportation & distribution – upstream

and downstream

• Use of sold products

We have not yet developed our whole of value chain reporting processes. We have included working from home

and paper for our NZ operations in the FY24 year.

In FY24, we commenced workstreams to capture broader scope 3. These will include emissions from our

underwriting portfolios, supply chain and investment portfolios.

Footnote: There are inherent data uncertainties with emissions data due to the limited availability of information and Tower’s reliance on external sources, which means that there may be a lag in the data, the data is over or understated, and/or the quantification may be

unreliable. The Quality score is assigned based on the availability, certainty and completeness of data.

CLIMATE STATEMENT 202449 Contents

Assumptions, Methodologies and
Limitations Statement

Forward looking statements

This climate statement contains climate-related and

other forward-looking statements and metrics, which

are not and should not be considered guarantees,

predictions or forecasts of future climate-related

outcomes or financial performance.

There remains significant uncertainty in climate data,

metrics, and modelling. The forward-looking statements

are inherently subject to uncertainties, risks, and

assumptions, many of which are beyond our control.

These may include, but are not limited to, economic

conditions, market trends, regulatory developments, and

other known and unknown factors. The many underlying

risks and assumptions may cause actual outcomes to

differ materially.

As a result, readers are cautioned not to place undue

reliance on any forward looking statements contained

within this climate statement. All information stated

within this climate statement is relevant at the date of

publication only.

Appendix 5

Further Clarifications

Current climate-related impacts have been derived from

internal categorization and quantification of claims data

alongside known catastrophic and large weather events.

Climate-related risks & opportunities were developed

on the basis of the ICNZ Climate-related scenarios,

Tower’s scenarios, internal expertise and knowledge and

guidance from scenario source data. These are limited

by the current lack of clear modelling.

Anticipated Impacts were derived using a combination of

internal and external data sources.

• Population growth - Projections for scenario

development as detailed in Appendix 3.

• Dwelling growth - Internal analysis based on

forecasted population growth above.

• Transition to EV vehicles and vehicle ownership

rate assumptions based on internal data and

market trends.

• Tower’s expected market share of target markets

- Management’s best estimate based on internal data

and knowledge.

• Claims estimates – Management’s best estimate

based on internal data and knowledge.

• Proportion of dwellings in high hazard risk areas –

Management’s best estimate based on internal data

and knowledge.

• Growth of multi-unit dwellings – Management’s best

estimate based on internal data and knowledge

• Stormwater infrastructure investments –

Management’s best estimate based on internal data

and knowledge.

Measuring our Performance - Metrics

• Transition risks - % of vehicles insured that are internal

combustion engines (ICEs) derived from categorized

motor policies as sourced from the underlying vehicle

data obtained from RedBook.

• Physical risks - % of high flood risk homes insured.

The definition of ‘High Flood Risk’ is Tower’s own

definition and not necessarily consistent with other

public sources. Specifically it relates to insurance risk

and cost to repair or replace property relative to the

risk of flooding and not just the chances of flooding

occurring in isolation. It also relates to Tower’s own risk

appetite or interpretation of the level of risk.

• Opportunities current – % of EV and PHV vehicles

covered. Data is derived from categorised motor

policies as sourced from the underlying vehicle data

obtained from RedBook.

• Capital Deployment has been calculated based

on FY24 operational expenditure on climate-

related activities identified by the Sustainability and

Climate Steerco.

CLIMATE STATEMENT 202450 Contents

tower.co.nz

Data sourced from publicly available filings. Our datasets may not be complete. Automated analysis can produce errors. If you believe any data on this page is incorrect, please contact us at hello@nzxplorer.co.nz. For informational purposes only. Not investment advice.