Tower Delivers Strong FY24 Result
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
should only be made where it is clearly indicated that this is permitted, otherwise, if an Issuer considers a particular
element does not apply, mark the row as N/A, Any other changes to this prescribed form must first be approved by
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)
ANNUAL REPORT 202459
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Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents
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
Notes to the consolidated financial statements (continued)
Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents
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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Notes to the consolidated financial statements (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)
ANNUAL REPORT 202465
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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
ANNUAL REPORT 202466
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Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents
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)
Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents
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
Notes to the consolidated financial statements (continued)
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
Notes to the consolidated financial statements (continued)
Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents
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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Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents
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
Notes to the consolidated financial statements (continued)
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
Notes to the consolidated financial statements (continued)
Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents
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
Notes to the consolidated financial statements (continued)
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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
Notes to the consolidated financial statements (continued)
Our strategy2024 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Contents
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
Notes to the consolidated financial statements (continued)
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.
ANNUAL REPORT 202489
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
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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
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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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s
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.