Annual Report and Accounts 2025

Standard Life plc

Formerly Phoenix Group Holdings plc

Who we are

Standard Life is a retirement specialist focused entirely on

retirement savings and income. We are proud to manage

£300 billion in assets on behalf of our 12 million customers,

and champion the belief that everyone’s journey to and

through retirement can be better.

We are helping our customers achieve better outcomes and

greater financial security in later life. In parallel, we are using

our size, expertise and influence to shape the world our

customers will retire into, driving change that reflects how

people actually live,not how the system assumes they do.

We’ve changed our name

On 24 February 2026 we changed our name from

Phoenix Group Holdings plc to Standard Life plc.

References to performance to 31 December

2025were under Phoenix Group Holdings plc.

Our Company is listed on the London Stock

Exchange under the ticker SDLF.

Look out for these icons

in the Annual Report

You can find out more about our

activities, financial performance,

sustainability strategy and our progress

towards becoming a net zero business

by 2050 by visiting our website:

www.standardlifeplc.com

For further reading

in the Annual Report

For more information read

our supplementary reports

Reference to further

reading online

Helping people

secure alife

ofpossibilities.

In this report

2 Strategic report

2 At a glance

4 How we deliver our

purpose-led business

10 Chair’s statement

12 Group Chief Executive

Officer’s report

16 Our investment case

18 Our business model

22 Our growth drivers

24 Our key divisions

28 Our strategic priorities

36 Key performance indicators

38 Business review

48 Sustainability review

78 Risk management

84 Viability statement

86 Corporate governance

86 Chair of the Group Board’s

introduction to governance

88 Board leadership and

Company purpose

93 Division of responsibilities

100 Stakeholder engagement

104 Workforce engagement

106 Composition, succession

and evaluation

120 Audit, risk and internal controls

136 Directors’ Remuneration report

176 Directors’ report

182 Statement of

Directors’ responsibilities

183 Financials

346 Additional information

Operating Cash

Generation

£1,474m

(2024: £1,403m) REM APM

Group Solvency II surplus

(estimated)

£3.6bn

(2024: £3.5bn) REM

Group Solvency II Shareholder

Capital Coverage Ratio (estimated)

176%

(2024: 172%) APM

Total cash

generation

£1,711m

(2024: £1,779m) REM APM

Total ordinary dividend

per share

55.40p

(2024: 54.00p)

IFRS adjusted

operating profit

£945m

(2024: £825m) REM APM

IFRS loss

after tax

£(394)m

(2024: £(1,078)m loss after tax)

IFRS adjusted

shareholders’ equity

£3,098m

(2024: £3,656m) APM

Solvency II

leverage ratio

33%

(2024: 36%) REM APM

In the UK, Solvency II as modified by the PRA’s

2024 reforms (‘Solvency UK’) became effective

from 31 December 2024. Solvency UK has been

referred to in this document except for where

referring to relevant Alternative Performance

Measures and other solvency metrics, where we

refer to Solvency II in line with the current PRA

guidance and consistent with the name of the

prudential regime in the PRA policy manual.

The Strategic report was approved by the Board of Directors

on 13 March 2026 and signed on its behalf by

Andy Briggs

Group Chief Executive Officer

Successfully delivering on our strategy

2025 has been an excellent year. We’re now two years into our 3-year

strategy and continue to make progress on executing against our

strategic priorities. We are firmly on track to meet our 2026targets.

2025 performance

Key performance indicators

All amounts throughout the report

marked with REM are KPIs linked

to Executive remuneration. See

Directors’ Remuneration report

on pages 136 to 175. All amounts

throughout the report marked with

APM are alternative performance

measures. Read more on pages

340to 345.

1Standard Life plc Annual Report and Accounts 2025

Strategic report

For more than two centuries, we’ve been standing beside our

customers, helping them plan and prepare for their financial

futures. Our vision is to be the UK’s leading retirement savings

and income business. We are helping our customers achieve

better outcomes and greater financial security in later life by

providing the right products and solutions at the right time.

At a glance

Our business

£317bn

total assets under administration APM

c.£550m

annual dividend paid to shareholders

c.5,500

colleagues

FTSE 100

and FTSE All World

c.12m

customers

Our brands

For more than 200 years, Standard Life

has been trusted to look after people’s

life savings and retirement needs.

Phoenix Life focuses on providing a secure

home for policies, brought together from

anumber of life companies over the years.

ReAssure looks aftercustomers

across a broad range of retirement,

investment and protectionproducts.

SunLife’s straightforward and affordable

financial products and services are designed

to meet the needs of the over 50s.

For more information visit

standardlifeplc.com/about-us/our-brands

2 Standard Life plc Annual Report and Accounts 2025

Strategic report

Sufficient savings

• Defined contribution workplace pensions

• Retail savings for retirement

• International bonds

• Legacy savings and pension products

See Our business model on pages 18 to 21

Secure retirement

• Defined benefit pension income

• Income drawdown and lifetime annuities

• Fixed-term annuities

• Smoothed managed funds

See Our business model on pages 18 to 21

Our customer products

Financial metrics shown refer to the assets under administration by segment type APM

We help customers journey to and

through retirement. Our Workplace

business supports people who save

through their defined contribution

workplace pension scheme, and our

Retail business supports individual

customers to save for, transition to,

and secure an income in retirement

See more on our Pensions

and Savings division on

pages24to 25

We participate across the

Annuities markets, as we seek

to help customers secure income

certainty in retirement, including

Pension Risk Transfer (‘PRT’) and

individual annuities.

See more on our Retirement

Solutions division on

pages26 to 27

Standard Life International, which

operates in Ireland and Germany,

offers a range of pensions and

savings products. SunLife offers

protection solutions direct to

the over 50s market in the UK

We are a market leader in the safe

and efficient management of

legacy pensions and savings

policies to deliver better customer

outcomes, with a range of legacy

With-Profits savings products that

are closed to new business that

we manage for our customers.

Pensions and Savings£212bn

Retirement Solutions£42bn

Europe and Other£28bnWith-Profits £35bn

Our business areas

£317bn

Assets under administration

(2024: £292bn)

1. Pensions and Savings includes International bonds which were reallocated in 2025 from Europe, and it excludes a held for transfer Corporate Trustee Investment Plan (‘CTIP’)

mandate that was reclassified in 2025 to Other.

3Standard Life plc Annual Report and Accounts 2025

Strategic report

How we deliver our purpose-led business

Our purpose

Helping people secure a life of possibilities

Our vision

To be the UK’s leading retirement and savings business

Enhance

Transforming our

operating model

and culture.

Optimise

Optimising our scale

in-force business and

balance sheet.

Grow

Meeting more of our existing

customers’ needs and

acquiring new customers.

Our strategic priorities

Read more about Our strategic priorities on pages 28 to 37

Embed responsibility

We are committed to embedding responsible and sustainable business

practices and maintaining high standards of oversight, integrity and ethics.

Planet

Better futures

We want to play our part in delivering a net

zero economy and managing our impact and

dependency on nature, to help deliver better

outcomes for our customers and shape the

world they will retire into.

People

Better journeys

We want to be the business that people

trust to guide their retirement journey,

helping our customers achieve better

outcomes and greater financial security

in later life.

Read more in our Sustainability Report

Our sustainability strategy

The development of our culture remains a top priority. Read more on pages 98 to 99

We put our

customers first

We aim

high

We work

together

Our culture: The Big Three

Read more about our engagement with our stakeholders on pages 100 to 103

• Customers

• Colleagues

• Shareholders

• Community and environment

Our key stakeholders

4 Standard Life plc Annual Report and Accounts 2025

Strategic report

Better

outcomes.

We champion the belief that everyone’s

journeyto and through retirement can be

better, andare helping our customers achieve

better outcomes and greater financial security

in later life. In parallel, we are using our size,

expertise and influence to shape the world

ourcustomers will retire into.

5Standard Life plc Annual Report and Accounts 2025

Strategic report

Better

journeys.

We want Standard Life to be the business that

people trust to guide their retirement journey.

We are empowering our customers to engage

with their financial futures and helping them

imagine the later life they want and live

retired life their way. We do this by providing

the right products and solutions at the right

time, with clarity, warmth and empathy.

Better outcomes continued

Strategic report

6 Annual Report and Accounts 2025Standard Life plc

Standard Life

customer logins

Logins via the app 72%

Non-app logins including

Standard Life website 2

Standard Life plc Annual Report and Accounts 2025

Affordable retirement

savingsadvice

In 2025 we launched our Financial

Advice service which aims to help

those who wouldn’t usually consider

paid advice gain access to the support

they need when saving and deciding

how to take their pension income.

The service is intended to support

customers with decisions such as how

to structure their retirement income,

the level of investment risk they

should take in retirement, and how to

take tax-free cash from their pension.

Supporting

financialwellbeing

We know digital engagement is key

tosupport financial wellbeing as our

customers journey to and through

retirement. We see our Standard Life app

as the tool of today and tomorrow to

deepen this further. We were delighted

our app was ranked as number one across

the leading Workplace providers in

BehindLogin’s comprehensive and

independent 2025 benchmarking report

In2025 72% of Standard Life logins

were via the app, up from 66% in 2024.

Read more in the Sustainability

review on page 51

+3m

Help 3 million more

customers over the next

10years take action towards

abetter retirement

1. https://behindlogin.com/report/pension-benchmark-2025/

2. Standard Life launches affordable pension advice business.

Strategic report

Better

futures.

We are leading the industry by advocating for better

retirements and convening to drive meaningful change that

reflects how people actually live, not how the system assumes

they do. We are leveraging our investment capabilities to

deliver strong returns, implementing sustainability-related

solutions, and creating trusted partnerships with aligned

objectives and shared value creation.

Better outcomes continued

8 Standard Life plc Annual Report and Accounts 2025

Strategic report

Decarbonising our

investment portfolio

58% reduction achieved

in the

carbon intensity of our listed

equity and debt credit portfolio

relative to our 2019 baseline.

2019 2025

105

tCO

e/£m

tCO

e/£m

Improving outcomes

through our Net Zero

TransitionPlan

We believe transitioning to net zero

willsupport better outcomes for our

customers, help deliver our commercial

objectives and fulfil our societal

responsibility, which is why we are

committed to being a net zero business

by 2050. We have exceeded our 25%

2025 interim portfolio decarbonisation

target and under most scenarios are on

track for our 2030 50% reduction target

Opportunities for

better returns

Our long-term ambition is to invest up

to £40 billion in sustainable, transition

and UK-focused productive assets

We pledged to invest 10% of our

Workplace default funds into private

markets by 2030 to boost returns for

our customers and to support the

growth of the UK economy. Future

Growth Capital (‘FGC’), our joint

venture with Schroders, will support

us in achieving this objective as it aims

to enhance access to private market

investments for pension savers.

Sustainability

improving approach

As a result of introducing the

Sustainability Improvers™ labelled

funds, more than two million

members investing in our £39billion

assets under administration (‘AUA’)

Sustainable Multi Asset default

Workplace solution are expected

tobenefit from improved

long-termfinancial outcomes

andgreatertransparency.

Read more in the

Sustainability Report

We continue to innovate,

leveraging our investment

capabilities to offer more

choice to our members

and to deliver strong and

sustainable returns.

Gail Izat

Managing Director Workplace

and Retail Intermediary

9Standard Life plc Annual Report and Accounts 2025

Strategic report

In February 2026 we changed our

name from Phoenix Group Holdings

plc to Standard Life plc bringing our

most trusted brand to the forefront.

To mark this change, we have launched

a new long-term social impact target to

help three million more customers over

the next 10 years take action towards

a better retirement. To achieve this

commitment, Standard Life will provide

support and solutions designed to ensure

more people have sufficient savings and

greater financial security in later life.

Helping build a world

worthretiring into

As a retirement specialist, focused

entirely on retirement savings and

income, we champion the belief that

everyone’s journey to and through

retirement can be better.

We are empowering people to engage

with their financial futures and in order

to help people achieve better financial

security in later life, we have been

investing to provide the right products

and solutions at the right time.

In parallel, we are using our scale, expertise

and influence to drive meaningful change,

working with industry and policymakers

toshape theworld our customers will

retire into.

Driving positive impact at scale

There is an ever-growing body of

researchevidencing the scale of the

retirement savings gap in the UK and

thatby the early 2040s we expect 3-in-5

defined contribution pension savers

willbe entering retirement with

inadequate savings

We see the UK Government’s Pension

Adequacy Review as essential toassess

thecomplexity of factors impacting

adequacy and to create consensus

onanimplementation timeline for

Read more in our Sustainability Report

Chair’s statement

10 Standard Life plc Annual Report and Accounts 2025

Strategic report

We areactively contributing to the

Pensions Commission’s work, andhave

previously advocated to gradually

increase contribution rates into workplace

pensions from 8% to at least 12%.

Research suggests that only c.10% of

people access and pay for independent

financial advice when making important

financial retirement decisions

, leaving

the majority of people facing an ‘advice

gap’. As a result, consumers face making

life-changing complex decisions without

sufficient support, increasing the risk of

financial harm. We played a central role in

shaping the implementation of Targeted

Support, a Financial Conduct Authority

(‘FCA’) initiative, reinforcing Standard

Life’s leadership in regulatory innovation.

We are expecting the final rules in 2026.

To compound the positive impact of our

customers saving more for retirement,

westrive to provide them with better

returns. As a founding signatory of the

Mansion House Accord, which builds on

the Mansion House Compact, we are

contributing to continued industry-led

efforts to improve retirement outcomes

and unlocking long-term investment in

UK growth through investing more into

alternative asset classes.

We can drive good outcomes for our

customers and manage the risks of

climate change by delivering on our

NetZero Transition Plan commitments

and deepening our understanding

of our impact and dependency on

nature. In parallel, we are helping to

remove the barriers to allow capital

to flow at scale into productive

and sustainable investments.

Successfully executing

onourvision

Two years into our 3-year strategy, we

continue to make good progress towards

achieving our vision, to be the UK’s leading

retirement savings and income business,

by executing against our strategic priorities.

We’ve completed our full service customer

offering, optimised assetmanagement,

further streamlined our group structure

and progressed our customer policy

migrations. In doing so we are meeting

even more of our customers’ needs.

This has delivered a strong set of financial

results for 2025 and means we are firmly

on track for all of our 2026 financial targets.

Attractive shareholder returns

Our progressive and sustainable dividend

policy reflects our commitment to

predictable long-term value creation and

financial strength, and is supported by

robust cash generation and disciplined

capital management.

I am delighted to announce that the

Board is recommending a 2.6% increase

in the Group’s 2025 Final dividend to

28.05 pence per share. Thismeans the

Group’s Total dividend for2025 will be

55.40 pence per share.

Thank you

Finally, I would like to take this opportunity

to thank the Board, our colleagues, our

partners and our wider stakeholders for

their continued dedication and support

throughout the year. Your commitment

has been central to delivering another

period of strong progress.

Sir Nicholas Lyons

Chair of the Group Board

Standard Life champions the belief that everyone’s

journey to and through retirement can be better.

Our purpose, helping people secure a life of

possibilities, demonstrates our commitment

tohelping customers while delivering better

outcomes forallour stakeholders.

Sir Nicholas Lyons

Chair of the Group Board

Section 172

statement

During the year, Directors

haveapplied section 172 of the

Companies Act 2006 in a manner

consistent with the Group’s

purpose, values and strategic

priorities. The Directors have

acted in a way which they

consider, in good faith, is most

likely to promote the success of

the Company for the benefit of

itsmembers as a whole. In doing

so the Directors have paid due

regard to the matters set out in

section 172(1) (a) to (f), namely:

• the likely consequences of

anydecision in the long-term;

• the interests of any of the

Company’s employees;

• the need to foster the

Company’s business

relationships with suppliers,

customers and others;

• the impact of the Company’s

operations on the community

and the environment;

• the desirability of maintaining

the Company’s reputation for

high standards of business

conduct; and

• the need to act fairly between

members of the Company.

Details on how the

Directorshave considered

these matters in connection

with key decisions, and

outcomes for engagement

with our key stakeholder

groups throughout 2025

can be found on pages 100

to 103 of the Corporate

governance report

1. https://library.standardlife.co.uk/Tomorrows-

problem-analysing-the-future-impact-of-dc-pension-

undersaving.pdf

2. https://library.standardlife.co.uk/What-role-could-

targeted-support-play-in-supporting-consumers-in-

retirement.pdf

11Standard Life plc Annual Report and Accounts 2025

Strategic report

Standard Life is a retirement specialist

focused entirely on retirement

savings and income, and is proud to

manage £317 billion of assets under

administration (‘AUA’) on behalf of

our 12 million customers. Our purpose

of ‘helping people secure a life of

possibilities’ is embedded in everything

that we do as we help customers

journey to and through retirement.

Around two-thirds of our business by

assets is Pensions and Savings, our

capital-light fee-based business, which

comprises our Workplace and Retail

offerings. 13% of our business by assets is

Retirement Solutions, our capital-utilising

spread-based business, comprising our

annuities offering across Pension Risk

Transfer (‘PRT’) and individual annuities.

In March 2024 we set out our 3-year

strategy, to realise our vision to be the

UK’s leading retirement savings and

income business. Progress towards

fulfilling our vision is delivered through

executing against our strategic

priorities of Grow, Optimise and

Enhance. Our strategy fully embeds our

environmental, social and governance

(‘ESG’) themes of People and Planet.

In February 2026 we changed our

name from Phoenix Group Holdings

plc to Standard Life plc. This move

brought our most trusted brand to

the forefront and demonstrates our

commitment to helping customers

secure a better retirement.

Successful

delivery

against our

strategy

Standard Life has an

exciting opportunity to

shape our industry. Our

2025 results show our

commitment to better

customer outcomes while

increasing shareholder

returns and strengthening

our financial flexibility.

Andy Briggs

Group Chief Executive Officer

Group Chief Executive Officer’s report

2025 highlights

• Full product suite now available for all customers’ life stages;

launchedthe Standard Life Guaranteed Lifetime Income plan

• Progressed customer engagement including the launch of our

Retailadvice proposition

• Strong trading performance with Workplace gross inflows

of£10billion; signed our largest-ever Pension Risk Transfer

deal;Retail gross inflows continuing to improve

• Firmly on track to deliver all our 2026 financial targets

• Generating c.£1 billion free cash flow, comfortably covering

ourdividend and creating further financial flexibility

Andy Briggs

Group Chief Executive Officer

+2.6%

2025 Final dividend increase

(2024: +2.6%)

12 Standard Life plc Annual Report and Accounts 2025

Strategic report

Achieving our vision to be the

UK’s leading retirement savings

and income business

To achieve our vision, our 2024–26

strategy is designed to build on the

strong foundations we had already

developed, leveraging our scale and

strong positions in the attractive markets

we operate in and completing our

full-service customer offering.

To Grow we need to have a full suite of

products which meet the needs of our

customers, and build out our ability to

engage with them. Having broadened

our range of products in the market over

recent years, including the launch of

the Standard Life Guaranteed Lifetime

Income plan, we now have a full product

suite to support customers across all

stages of their retirement journey.

There is always more to do as we continue

to innovate and adapt to changing

customer needs, behaviours and market

trends, but this phase is now largely

complete and sets us up well for the future.

We have also been working to unlock

access to products and engagement

opportunities. The launch of our advice

proposition in 2025, and our wide range

of digital offerings, from our Family

Finance Hub, to our Mixed Income

Builder tool, are all helping customers

navigate their retirement journey, by

supporting households with engaging

planning and budgeting options.

We’re focused on scaling our products,

and deepening our intermediary

partnerships, to widen our access

to potential customers. In January

2026 we expanded the distribution

of our smoothed managed fund

onto the Quilter platform.

To Optimise our scale in-force business

and our balance sheet, we have been

further enhancing our unique in-house

asset management expertise, including

evolving our annuity-backing assets. For

example, in September we announced we

were preparing to in-house c.£20 billion

of annuity-backing assets. Our asset

management expertise will deliver

enhanced returns, drive better customer

outcomes, create cost savings and it

underpins our ability to deliver recurring

management actions. Together these

contribute totheexcess cash generation

we are consistently achieving and in turn

enabled us to repay £0.4 billion of

debttosupport our deleveraging

programme, which will continue in 2026.

Under Enhance, our priority is to

transform our operating model and

culture, which in turn helps us to

deliverbetter customer outcomes.

Alarge aspectof this is completing the

migrationof customer administration to

modern, technology-enabled platforms.

In total, 75% of our policies are now

ontheir end-state platforms, up from

45%in 2024, enabled by our strategic

partnerships, including with Diligenta

andWipro.

Through leveraging technology and

streamlining the organisation, we have

made good progress on our cost savings

programme with run-rate savings of

£180 million achieved at the end of

2025. This underpins our confidence

in achieving our end-2026 £250million

run-rate savings cost target.

Our remaining area of focus, which

presents a significant opportunity as we

continue to help our customers navigate

their retirement journey, is the digital

customer interface. Whilst we already

have an award winning app, the next

stepis to enhance our technology and

customer engagement capabilities by

leveraging our digital infrastructure to

create digitally enabled and personalised

customer journeys – focused on

data, guidance and advice. We’re also

focused on deepening our intermediary

partnerships, widening our access to

potential customers. While for Workplace

and Annuities it’s about continuing

to deliver excellent performance.

See pages 28 to 37 for more

detailon how we are delivering

ourstrategy and pages 48 to77

forour Sustainability review

Achieving our vision to be the UK’s leading

retirement savings and income business

We deliver this by investing in our strategy to Grow, Optimise and Enhance

Retirement Solutions

Retirement Solutions underwrote

c.£11bn of annuities volumes

over two years

Pensions and Savings

Pensions and Savings margin

improved from 11bps to 19bps

over two years

Innovative retirement

income solutions

Full product suite

Optimised asset management and fund performance

Asset Management integrated into Group-wide operating model

Efficient Group-wide operating model

Optimised through streamlining Group structure and cost savings progress

Digital customer interface with personalised data, guidance and advice

Our focus is now turning to advanced digital engagement with our customers and offering a more personalised service

13Standard Life plc Annual Report and Accounts 2025

Strategic report

Group Chief Executive Officer’s report continued

An attractive market with

structural growth drivers

andfurther tailwinds

The UK long-term savings and retirement

market is already large, with c.£3.6trillion

of assets managed on behalf of customers,

but it is also structurally growing across

our key markets of Workplace, Retail and

Annuities, and set to grow by c.70% over

the next decade

This growth is driven by the current

demographic and socio-economic

trends, which have seen increasing

responsibility for retirement falling

onindividuals rather than employers

as was previously the case, including

the shift from defined benefit (‘DB’) to

defined contribution (‘DC’) schemes.

We continue to advocate for the

changes that will make the biggest

difference to our customers, and in

this regard I am really encouraged by

recent regulatory and political proposals

that will support better retirement

outcomes across all our key markets.

These will also act as further tailwinds

to the industry that will accelerate the

existing structural growth opportunities

beyond the c.70% expected growth.

As the only scale UK player solely

focused on the full savings and

retirement lifecycle, Standard Life is

uniquely positioned to benefit from

this market growth. Our ambition

isto grow faster than the market.

See pages 22 to 23 for more

onOurgrowth drivers

Taking share in our

chosenmarkets

Workplace is typically the foundation

of a customer’s retirement savings

journey and it acts as a key acquisition

tool for us. We’re a scaled player, with

AUA of £70.6 billion and three million

members, both of which are growing.

Our ambition here is to consolidate

ourtop-3 market position as this market

grows rapidly; concentrates down to

fewer players; and will be supported by

expected contribution increases. This

acceleration and concentration will

be driven by proposals outlined in the

Pension Schemes Bill which includes a

requirement for minimum thresholds

for default funds. We will achieve

our strategy through deep customer

engagement which will drive retention

and support new scheme wins.

Winning in Workplace requires three

things: a leading employer proposition,

excellent customer service, and

scale driven cost efficiency. We are

strong on all three, as demonstrated

across a collection of metrics.

We achieved an excellent Net Promoter

Score (‘NPS’) of +60 in 2025

. We welcomed

247k new Workplace members in 2025,

up from 216k in 2024 and wewon over

200 schemes in 2025. Lastly, Workplace

AUA is up almost 40% in three years,

importantly driven by strong positive

netfund flows. With £10billion of gross

inflows reached this year, our market

share grew to over 10%.

Our Retail strategy is to engage customers

with innovative products to join, stay and

consolidate with us. Delivering on this

strategy will enable us to move from our

current top-10 position to top-5.

Success in this market is driven by

three things: customer engagement,

offering products that meet customers’

evolving needs and leveraging digital

infrastructure to do all this proactively.

With 1-in-5 UK adults being customers

of Standard Life plc, this provides us

with a unique opportunity to win market

share in the retail market – both via

advisers and direct to customers. Our

ability to win is further evidenced by our

expanded product range now meeting

more of our customers’ evolving needs.

The positive outcomes of our efforts

include high customer satisfaction

scores, with 93% of customers rating us

“good” or “excellent”. This is translating

to more digital customer engagement,

with total logins up c.50% in two years.

While our Retail business remains in net

outflow, we’re seeing positive customer

outcomes reflected in gross retail inflows

of £7.1 billion in 2025, up by nearly

£3 billion over the last three years.

Alongside our newly launched advice

proposition, Targeted Support will enhance

our ability to offer timely services to our

customers and is very much aligned to

our belief that everyone’s journey to

andthrough retirement can be better.

We have a significant opportunity to

leverage our digital infrastructure, but

we are not there yet. One area we’re

focusing on is building out our Salesforce

customer relationship management

(‘CRM’) integration. This gives us deeper

insight to support customers so we can

gather insights and proactively help

by ‘nudging’ them to make the right

choices at the right life stages, as they

journey to and through retirement.

Within Annuities, which includes PRT

and individual annuities, winning is

all about having a leading employer

proposition, excellent member

experience, and competitive pricing.

Our strength in all three is why we are

winning in these markets today. Our

comprehensive buy-in and buy-out

capabilities, and a full product suite,

mean that we can serve customers,

however complex their needs may be.

We currently have a top-5 position

andour ambition is to maintain this.

Wewill achieve this by continuing to

havea disciplined capital deployment

approach of c.£200 million per annum,

and through providing a holistic suite

ofde-risking solutions.

Having re-entered the individual

annuity market in 2023 we have nearly

doubled our market share to 15%, from

8% only two years ago, driven by our

ability to launch a product that is both

competitively priced and delivered via

a leading digital customer experience.

+93%

Customer satisfaction – digital

(2024: 94%) REM

+60

Workplace Net Promoter Score

(2024: +60)

70%

Expected growth in long-term

savings and retirement market

over the next decade

1. Company analysis of market data and industry

forecasts including 2024 LCP Pension Risk

Transfer report, NMG, The 2024 Purple Book

and publicly available FY2024 and HY2025

financial disclosures.

2. Customer satisfaction score converted to NPS

equivalent metric.

14 Standard Life plc Annual Report and Accounts 2025

Strategic report

In PRT we wrote our largest-ever deal

of £1.9 billion in 2025, owing to our

expertise and ability to provide member

certainty in complex transactions.

Ourdisciplined approach, reflected in

our focus on value rather than volume

in this market, means we are achieving

attractive returns, with lifetime

internal rates of returns (‘IRRs’) on our

annuity business of more than 20%.

Whether it is saving for retirement

through our Workplace business, or

staying and consolidating in Retail, or

securing income through our Annuities

business, we’re well positioned to serve

customers and their evolving needs.

See pages 18 to 21 for Ourbusiness

model and pages 24 to 27 on Our

key divisions

Strengthening our

competitiveadvantages

Standard Life is clearly already winning

today and is well-positioned to win share

in our growing markets, underpinned by

our three competitive advantages of

customer engagement, capital efficiency

and cost efficiency.

With 1-in-5 UK adults being customers of

Standard Life plc we have an exceptional

level of customer access which enables

our customer engagement. This gives

usinsights into what customers – both

corporate and consumers – really need,

which in turn supports how we develop

and design propositions. Our recent

name change has brought our strongest

brand to the forefront.

We also benefit from capital efficiency

from our diversified long-term savings

and retirement businesses, comprising

both capital-light fee-based and

capital-utilising spread-based products.

Our unique asset management capabilities

are already delivering superior returns,

reflected in the sustainable delivery

ofrecurring management actions at

c.£500million per annum, all whilst

remaining cash flowmatched.

Our existing cost efficiency, underpinned

by our 12 million customerbase, has

beenachieved by leveraging technology

across our business, as reflected in our

sector-leading Pensions and Savings

margin. This margin expansion will

continue as we deliver further cost

savings. And, technology advancements

will drive operating leverage higher as

wescale.

Looking ahead, we will continue to

strengthen those competitive advantages,

which will support our growth.

See pages 16 to 17 for

Ourinvestment case

Firmly on track for all our 2026

financial targets

Consistently executing on each of our

strategic priorities is translating directly

into the delivery of attractive financial

outcomes. Our 2025 performance

has been strong across our financial

framework of cash, capital and earnings

and we are firmly on track to deliver

all of our 2026 financial targets.

See the Business review on

pages 38 to47 for more detail

Operating Cash Generation (‘OCG’)

continues to be the metric which best

demonstrates the long-term underlying

value generation from our business.

OCG grew by 5% in the period to

£1,474 million (2024: £1,403 million).

For 2025 the Board has recommended

a 2.6% increase in the Final dividend

of 28.05 pence per share, bringing

our Total dividend to 55.40 pence

per share, extending our strong

track record of dividend growth.

We delivered £1 billion free cash flow

in 2025, which has doubled from when

we started this journey in 2023. At

this level we are comfortably covering

our dividend of £548 million and

delivering £423 million of excess cash.

We continue to expect mid-single digit

percentage growth per annum in OCG.

This means dividends and excess cash will

both grow, as OCG grows, particularly

as recurring uses are reducing.

2026 is our final year of prioritising this

excess cash to reduce debt. So excess

cash generated after the end of this year,

will be available to be deployed to the

highest returning opportunities, in line

with our capital allocation framework.

Summary

We operate in one of the most attractive

retirement and savings markets in the

world, and StandardLife has an important

role to play in shaping the industry and

providing better outcomes for pensioners.

When we set out our 3-year strategy

in 2024, we were clear on the scale

of the opportunity in front of us.

Two years on, I’m delighted with the

progress we’ve made and looking

ahead, I continue to be optimistic.

Our execution positions us exceptionally

well to meet the needs of our customers,

and is strengthening our competitive

advantages. This is translating into strong

and attractive financial performance

and returns to shareholders.

As we continue to serve our customers,

colleagues and other key stakeholders,

this will support us in achieving our

vision of becoming the UK’s leading

retirement savings and income business.

Thank you

Our performance is only achieved

through the continued hard work and

dedication of our outstanding people so

Iwould like to thank each and every one

of my colleagues across the Group for

their contributions. With our move

toStandardLife plc, I am even more

energised about our future and the

progress we will make together in the

years ahead.

Andy Briggs

Group Chief Executive Officer

£1,474m

2025 Operating Cash Generation

(2024: £1,403m) REM APM

15Standard Life plc Annual Report and Accounts 2025

Strategic report

Our investment case

How we generate shareholder value

Our strategic priorities

will strengthen our

competitive advantages

Enabling

our financial

framework

Competitive advantages

Customer engagement

With 12 million customers, we have

anexceptional level of customer access.

Thisgivesus deep customer insights that

underpin our developing propositions,

enablingus to better meet our customers’

evolving needsontheir journey to and

throughretirement.

Capital efficiency

As a genuinely diversified long-term savings

and retirementbusiness, we get greater

diversification from ourbreadth of products.

Our capital position is also highlyresilient,

through our core capabilities in risk

management and capital optimisation.

Cost efficiency

We have a cost efficiency advantage, which is

enabled through our customer administration

and IT partnerships. We are looking to

further this advantage as we continue to

progress our cost savings programme.

Cash

Growing Operating Cash Generation

that more than covers our recurring

uses, including our progressive and

sustainable dividend, and delivers

excess cash.

Capital

Resilient balance sheet that

supportsinvestment to grow,

optimise and enhance our business.

Earnings

Growing IFRS adjusted operating

profit to cover our recurring uses

and create excess profits.

For more information see the

Business review on pages 38 to 47

Grow

Optimise

Enhance

For more information see Delivering

on our strategy on pages 28 to 29

Read more about Our sustainability

strategy on page 50

16 Standard Life plc Annual Report and Accounts 2025

Strategic report

2023 2024 2025 2026

target

Illustrative

based on 2025

£0.6bn

£0.8bn

£0.9bn

£1.1bn

Excess

profit

Recurring

uses

2023 2024 2025 2025 uses

£1.1bn

£1.4bn

£1.5bn

Excess cash

Other recurring uses

Dividend

1. Drawn up data – duplicate

2. Ungroup /expand / remove 0.2 from top/bottom

where necessary / add keylines (0.4pt/outside stroke)

Delivering a clear set

of financial outcomes

for our shareholders

The Group operates a

progressive and sustainable

ordinary dividend policy

Our dividend policy is supported by our strategy

to deliver sustainable, growing Operating Cash

Generation, which more than covers our uses

andgenerates excess cash.

And supporting our

progressive and

sustainabledividend policy

Operating Cash Generation REM APM

IFRS adjusted operating profit REM APM

Strong growth in IFRS adjusted operating profit

140–180%

Shareholder Capital Coverage

Ratio operating range APM

c.30%

Solvency II leverage ratio target

by the end of 2026 REM APM

55.40p

2025 Total dividend per share

28.05p

2025 Final dividend per share

+2.6%

increase in 2025 Final dividend

c.3%

10-year CAGR

17Standard Life plc Annual Report and Accounts 2025

Strategic report

Our business model

What we do

We help our customers achieve better

outcomes and greater financial security

later in life. We empower them to engage

with their financial futures by providing the

right products and solutions at the right

time and help them imagine the later life

they want, and live retired life their way.

Creating long-term value …

Using our scale and ambition, we are

committed to creating sustainable

long-term value for all our stakeholders.

We generate returns on our capital-light fee-based

savings products by earning a fee and managing the

associated costs. On our retirement products we

optimisethereturns on the assets backing the liabilities

througheffective risk management and earn a spread.

A growing and sustainable business

Standard Life is a retirement specialist focused entirely on retirement

savings and income. We champion the belief that everyone’s journey

to and through retirement can be better.

Our purpose

Helping people

secure a life

of possibilities

Our vision

To be the UK’s

leading retirement

and savings

business

For more information on our family of brands visit

standardlifeplc.com/about-us/our-brands

See Our investment case on pages 16 to 17

18 Standard Life plc Annual Report and Accounts 2025

Strategic report

Customers

Colleagues

Shareholders

Community and

environment

Wealth

Lifetime

For more information on how we are driving positive outcomes for our stakeholder groups,

see Stakeholder engagement on pages 100 to 103

… and better outcomes for all our stakeholders.

12m

customers

2024: 12 million

40.2%

of Senior Leadership

arewomen

2024: 39.7% REM

55.40p

2025 Total dividend

per share

2024: 54.00p

58%

reduction in the emissions

intensity of our portfolio

2024: 52% REM

We are helping more people to be on track for

sufficient pension savings. We’re doing this by

engaging them in planning for their retirement

and helping them save more.

We are helping more people achieve financial

security in later life. We’re doing this by supporting

them to make better decisions when accessing

their pension and achieve sufficient income

throughout retirement.

Our first priority is ensuring

we achieve consistently

good outcomes for our

customers, and financial

security as they journey to

and through retirement.

We are inspiring our colleagues

and attracting anddeveloping

top talent. Wewant to

create the conditions for

our people to succeed in a

high-performance, customer-

centric, purpose-led culture.

We continue to successfully

execute on our 3-year

strategy, delivering a clear

set of financial outcomes for

shareholders and supporting

our progressive and

sustainable dividend policy.

We want to play our part in

delivering a net zero economy

and managing our impact and

dependency on nature, to

deliver better outcomes for

our customers and shape the

world they will retire into.

To learn more about our products and how we engage with our customers see pages 20 to 21

Sufficient savings Secure retirement

19Standard Life plc Annual Report and Accounts 2025

Strategic report

Our business model continued

For the life we live.

Wewant Standard Life to be the business that people trust to

guide their retirement journey. We provide the right products and

solutions at the right time – with clarity, warmth and empathy.

Sufficient savings

Defined contribution

workplace pensions

With a defined contribution (‘DC’)

workplace scheme, individuals and

typically their employer pay into their

pension on a regular basis as they work.

Standard Life is one of the leading

UKproviders that help employers

andtrustees set up high-quality,

easy-to-run workplace pension schemes,

underpinned by our Sustainable

MultiAsset (‘SMA’)strategy.

Sufficient savings

International bonds

Our international bond is an offshore

bond provided by Standard Life’s entity

in Dublin to UK customers. Offshore

bonds are a tax-efficient way to invest

money over the medium to long-term.

As customers don’t normally pay tax on

investment growth, which could give

more savings for the future.

Sufficient savings

Retail savings for retirement

We help retail customers both

directlyand indirectly via financial

advisers by providing a range of

pensionand investment solutions to

support their retirement ambitions.

Engagement

Advice proposition

Our new advice service aims to support customers

with decisions such as how to structure their

retirement income, the level of investment risk

theyshould take in retirement and how to take

tax-free cash from their pension.

Sufficient savings

Legacy savings and

pension products

Over the years, Standard Life has grown

through the acquisition of closed books

of legacy pension and insurance policies

from a number of companies. We are the

market leader in the safe and efficient

management of legacy pensions and

savings policies, with a strong track

record of delivering better outcomes for

customers of long-standing policies that

are no longer sold in the wider market.

We are leveraging the products and

services from Standard Life to better

support these customers at retirement.

Engagement

The Standard Life app

Our mobile app makes it easy for customers to

engage with their pension wherever they are.

Itincorporates handy functions and interactive

toolsto make managing pensions straightforward.

20 Standard Life plc Annual Report and Accounts 2025

Strategic report

Secure retirement

Smoothed managed funds

Smoothed funds are designed to provide

steadier long-term growth. They hold a

range of different investments and are

designed to reduce the worry of investing

by smoothing out the short-term ups

anddowns of the investment markets.

Fixed-term annuities

The Standard Life Guaranteed Fixed-term

Income product provides a guaranteed

income for a particular period of time,

typically between 3 and 25 years, but also

provides flexibility with an option for

customers to surrender it and reassess

their financial needs at a later stage. It’s a

useful tool when bridging the gap in the

run-up to retirement.

Income drawdown

and lifetime annuities

Income drawdown provides a flexible way

for our customers to take income from

their pension pot as they can take out

money whenever they like, while our

lifetime annuity product offers pension

savers secure guaranteed regular income

in retirement.

Secure retirement

Defined benefit pension income

Also known as a ‘final salary’ pension, a

defined benefit (‘DB’) pension pays out a

guaranteed income to scheme members

for life in retirement, but they are

generally no longer offered to

employees. The remaining DB pension

schemes are exposed to a range of

market and demographic risks that the

sponsoring employer is responsible for.

To remove these risks and enhance

benefit security for scheme members,

sponsors and trustees look to insure

some or all of their pension scheme

obligations with a specialist insurance

group like StandardLife.

Engagement

Adviser distribution

We partner with financial advisers by equipping

them with products, planning tools, and specialist

technical support, enabling them todeliver

high-quality retirement, investment, and fund

solutions to their clients.

21Standard Life plc Annual Report and Accounts 2025

Strategic report

Pensions and Savings

Retirement Solutions

Our growth drivers

There is a huge societal need to better support people on their journey

toandthrough retirement and significant growth opportunities available

throughproviding products and solutions that reflect how people actually live.

The market is expected to increase from £3.6 trillion to £6.1 trillion by 2034

Demographic and

socio-economic trends

Driving growth

opportunities…

The population

is ageing

Shift to defined

contribution (‘DC’)

pensions

Only 14% of DC savers

on track for an

adequate retirement

c.10% take

financial advice

Workers have

multiple pension pots

Individuals want

simplicity and

control of income

Workplace

Retail

c.£80bn

annual market flows

c.£150bn

annual market flows

The rapidly growing DC workplace pension

scheme market is primarily driven by

auto-enrolment and the continued move

fromdefined benefit (‘DB’) pension schemes

to DCpension schemes.

As the responsibility for retirement planning

has shifted towards individuals, away from

corporates, people are seeking an increasingly

broad range of innovative retirement savings and

income products either directly or via advisers.

Pension

Risk

Transfer

Individual

annuities

c.£35–55bn

annual market flows

c.£8–9bn

annual market flows

Corporates are de-risking their DB pension

scheme liabilities through Pension Risk

Transfer (‘PRT’) transactions in order to

focuson their core businesses. This is

fuellingincreased demand for PRTs.

Similar to workplace, the demand for individual

annuities is increasingly driven by the move

away from DB to DC pension schemes with

asmany as 9-in-10 people saying income

certainty in retirement is important to them

22 Standard Life plc Annual Report and Accounts 2025

Strategic report

… accelerated by political,

regulatory and economic tailwinds

1. Company analysis of market data and industry forecasts

including 2024 LCP Pension Risk Transfer report, NMG,

The2024 Purple Book and publicly available FY2024 and

HY2025 financial disclosures.

2. https://library.standardlife.co.uk/Great-Expectations-Report.pdf

3. https://library.standardlife.co.uk/What-role-could-

targeted-support-play-in-supporting-consumers-in-

retirement.pdf

4. Company estimate based on NMG market model (2024).

5. NMG market model (2024) data.

6. Company estimate based on 2025 LCP Pension Risk

Transferreport.

7. https://www.standardlife.co.uk/about/retirement-voice

8. Company estimate based on publicly available information.

Higher salary inflation has accelerated growth from our

existing Workplace pension schemes. Despite cost-of-living

pressures, the vast majority of customers are choosing

to continue making contributions into their workplace

schemes. As a scale player we stand to benefit from

proposals in the Pension Schemes Bill including minimum

scale for default funds and potential increases in

auto-enrolment.

Through a combination of changes in inheritance tax

rules, market entrants stimulating pension consolidation

and the future implementation of pensions dashboards,

people are being prompted to think more about what

they do with their long-term savings and therefore are

more likely to move their savings to seek better value

from their long-term savings provider.

Higher interest rates mean PRT, both buy-ins

and buy-outs, are more affordable for trustees,

driving high levels of demand. Buy-outs from

establishedbrands are still considered the gold

standardfor pensions de-risking.

Higher interest rates have also resulted in

higherratesofincome for customers buying

individualannuities now.

• Leading and innovative

propositions that meet

evolving needs

• Excellent customer service

and engagement

• Cost-efficient administration

supported by excellent

digital infrastructure

• Leading employer proposition

and innovative products

• Excellent member experience

• Competitive pricing

Read more about Retirement

Solutions on pages 26 to 27

See Our strategic priorities

onpages 28 to 35

Why we are winning…

23Standard Life plc Annual Report and Accounts 2025

Strategic report

Pensions and Savings

£212bn

Retirement Solutions

£42bn

Europe and Other

£28bn

With-Profits

£35bn

Pensions and Savings

£396m

Retirement Solutions

£879m

Europe and Other

£123m

With-Profits

£76m

Pensions and Savings

Our key divisions

Measuring our financial success

Growth in AUA…

+7%

average AUA vs 2024

… and enhancing our operating margin…

19bps

IFRS operating margin, up 2bps in FY2025

… drives growing IFRS adjusted operating profit…

£389m

23% growth year-on-year

… and drives growing OCG

£396m

13% growth year-on-year

See our Business review on pages 38 to 47

Assets under administration (‘AUA’)

APM

Operating Cash Generation (‘OCG’)

REM APM

Helping our customers to and through retirement

Pensions and Savings is our capital-light fee-based business

and comprises our Workplace and Retail offerings.

Business areas

Asset management strategy

We operate an outsourced approach to managing policyholder assets. We are consolidating the number of

asset managers we work with; Aberdeen remains our key asset management strategic partner. This supports

the delivery of fund simplification management actions and improves value for money for customers.

1. Includes reallocation of flows and AUA for International bonds to Retail from Europe, and held for transfer Corporate Trustee Investment Plan (‘CTIP’) mandate to Other from Workplace.

24 Standard Life plc Annual Report and Accounts 2025

Strategic report

Compelling

strategy to

support our

ambitions

Consolidating our top-3

provider position with deep

customer engagement

driving retention, supported

by new scheme wins.

Ambition to be a top-5

player in the retirement

savings and income market

as we engage customers

with innovative products to

join, save and consolidate

with us via direct and

intermediated channels.

Workplace Retail (direct

and intermediated)

Strong market

positions with

structural growth

opportunities

What we’ve built

to help us win in

growing markets

• Leading employer proposition

underpinned by award-winning

MasterTrust and sector-first

retirement and savings innovations

• Excellent customer service underpinned

by digital-first member engagement

and extensive range of financial tools

• Cost-efficient administration

underpinned by ongoing migrations

toefficient administration platform

• Effective customer engagement

underpinned by our market-leading

app, telephony guidance and

advice proposition

• Innovative propositions available

inthe market which meet

customers’ evolving needs

• Leveraging excellent digital

infrastructure underpinned by

integration of customer data

Top-3 player

Top-10 player

£10.0bn

Standard Life gross inflows

£7.1bn

Standard Life gross inflows

1. Company estimate based on 2024 Broadridge

Workplace Provider Benchmarking Report for

newand transferring schemes (averaged 2022–24). 2. Company estimate based on market data.

What our customers and key stakeholders say

At Equiniti, we want colleagues to feel

informed and confident about their

retirement savings. Standard Life’s focus

on digital innovation and member

engagement has helped us strengthen

scheme transparency and improve how

employees understand, use and trust

theirworkplace pension.

Alex Lawrie

Reward Director, Equiniti

Read more on Our growth

drivers on pages 22 to 23

3. Equiniti was a new employer to our Master Trust in 2025.

25Standard Life plc Annual Report and Accounts 2025

Strategic report

Business areas

Pensions and Savings

£396m

Retirement Solutions

£879m

Europe and Other

£123m

With-Profits

£76m

Pensions and Savings

£212bn

Retirement Solutions

£42bn

Europe and Other

£28bn

With-Profits

£35bn

Our key divisions continued

Retirement Solutions

Helping our customers secure income certainty in retirement

Our Retirement Solutions business is our capital-utilising spread-based

business and includes Pension Risk Transfer and individual annuities.

Assets under administration (‘AUA’)

APM

Operating Cash Generation (‘OCG’)

REM APM

Measuring our financial success

Growth in AUA…

+3%

average AUA vs 2024

… and enhancing our OCG margin…

219bps

OCG margin up 49bps in 2025 vs 2023

… and drives growing IFRS adjusted operating profit

£563m

19% growth year-on-year

… drives growing OCG…

£879m

3% growth year-on-year

See our Business review on pages 38 to 47

Asset management strategy

We have been evolving our asset management strategy to predominantly in-house management

of annuity-backing assets. This move supports the delivery of annuity portfolio re-optimisation

management actions, origination of private credit, improving our efficiency and competitiveness.

26 Standard Life plc Annual Report and Accounts 2025

Strategic report

£3.9bn

Standard Life gross inflows

£1.2bn

Standard Life gross inflows

15%

market share in 2025; vs 8% in 2023

when we re-entered the market

Top-5 player

three-year average ranking

based on Pension Risk Transfer

annuityvolumes

2. Company estimates based on publicly

availableinformation.

1. Company estimate based on 2023 and

2024LCP Pension Risk Transfer report

andpublicly available information.

Ambition to maintain our top-5 position

through disciplined capital deployment of

£200 million per annum and providing a

holistic suite of de-risking solutions, with

deep customer engagement across channels.

Strong market

positions with

structural growth

opportunities

Read more on Our growth

drivers on pages 22 to 23

Pension Risk Transfer Individual

annuities

Compelling

strategy to

support our

ambitions

What we’ve built

to help us win in

growing markets

• Leading employer proposition enabled

through comprehensive buy-in and

buy-out capabilities and a holistic suite

ofde-risking propositions including

combined DB and DC solutions

• Excellent member experience

• Competitive pricing underpinned

byour uniquely diversified business

mix and the evolution of asset

management strategy

• Fast guaranteed pricing

andtimelyexecution with

adigital-first approach

• Enhanced end-to-end

customerexperience

• Expanded product range

with innovative products

tomeetmore of our

customers’needs

We feel very confident

recommending StandardLife

annuities to our clients, knowing

they will receive exceptional

service, and that we, as advisers,

can rely on a smooth, efficient

and well-managed process

forthem.

Hannah Mark

Arthur Dodds and Co Limited

Standard Life’s strong

brand and member-focused

proposition played a key

role in our decision to work

with them.

Robert Tickell

Trustee Chair of the of IBM I.T.

Solutions Pension Scheme

What our customers and key stakeholders say

27Standard Life plc Annual Report and Accounts 2025

Strategic report

Our strategic priorities

Delivering on our strategy

We’re two years into our 3-year strategic plan and

executing against our strategic priorities which is

improving operational and financial outcomes.

We are firmly on track to meet our 2026 targets.

Strategic priorities

2024–26 key delivery

Meeting more

of our existing

customers’ needs

and acquiring

new customers

Optimising our

scale in-force

business and

balance sheet

Transforming our

operating model

and culture

Grow

Optimise

Enhance

Read more on pages 34 to 35

Products

Develop innovative Retail

propositions for both the

adviser and direct markets.

Engagement

Further develop our

Workplace and Annuities

businesses to drive more

profitable growth.

Asset management

Enhance our asset

managementand balance

sheetefficiency capabilities.

Deleveraging

Deleverage our balance sheet.

Cost savings

Simplify our business

byembedding an

efficient Group-wide

operating model.

Migrations

Complete remaining

customerpolicy migrations.

28 Standard Life plc Annual Report and Accounts 2025

Strategic report

Years 1 and 2:

2024 and 2025 progress

Year 3:

2026 priorities

Products

Full product suite now available

tosupport our customers at all

life stages.

Engagement

Unlocking access to products

and engagement opportunities

through digital tools, advice

and distribution partnerships.

Asset management

Unique in-house expertise

delivering better customer

outcomes and enhancing

returnsincluding c.£500

millionper annum of recurring

management actions.

Deleveraging

Debt repayments improving

Solvency II leverage ratio,

enabled by business growth.

Cost savings

Delivered £180 million

run-rate cost savings, largely

through using technology.

Group-wide operational

designchanges.

Changed name from

PhoenixGroup Holdings plc

toStandardLife plc.

Migrations

75% of policies now

on their end-state platform.

Engagement

Enhancing engagement with

customers and proactively

‘nudging’ to provide better

retirement outcomes.

Distribution

Scaling and deepening

intermediarypartnerships.

Delivery

Continuing to trade strongly in our

Workplace and Annuities businesses.

Asset management

Managing more annuity-backing

assets in-house.

Deleveraging

Complete programme and

achieve c.30% Solvency II

leveragetarget.

Cost savings and migrations

Deliver remaining £70 million

of£250 million run-rate target

and progress final stages of

migrations to Diligenta’s

TCSBaNCS.

1. From a base of £1.4bn OCG in 2024.

Mid-single

digit % growth

in Operating Cash

Generation per annum

REM APM

£1.1bn

IFRS adjusted operating profit

REM APM

c.30%

Solvency II leverage

ratio bythe endof 2026

REM APM

£250m

of annual run-rate cost

savings by the end of 2026

REM APM

Our sustainability strategy is fundamental to the delivery of our

long-term growth; read more about how our strategic priorities

areunderpinned by our sustainability strategy on page 50

Our key performance indicators are used to measure our

progressagainst our strategy; read more on pages 36 to 37

Our financial framework supports the delivery of our strategic

priorities; read more about our financial performance in our

Businessreview on pages 38 to 47

2026 targets

29Standard Life plc Annual Report and Accounts 2025

Strategic report

Given the evolving needs of our customers,

we have consciously chosen to invest in

our products and solutions. This demand

is underpinned by the significant market

opportunities available to us (see Our

growth drivers on pages 22 to 23).

Thanksto our strong foundations we have

established leading positions in our key

markets of workplace, retail and annuities.

We are investing to grow more and are

focused on connecting our products and

solutions onto and into the right channels.

We continue leading the industry by

advocating for better retirements and

convening to drive meaningful change.

Evolving our award-winning

Workplace proposition

We see our Workplace proposition as

one of our key customer acquisition

toolswith 247k new Workplace members

this year (2024: 216k) helping to drive

£5.3 billion of Workplace net fund

flows and supporting average assets

under administration (‘AUA’) growth

to £70.6 billion (2024: £66.5 billion).

Testament to the strength of our

proposition in the workplace market and

specifically our Master Trust offering, is

the fact we were the first provider to win

the Master Trust treble across Corporate

Adviser, the Pensions Age and the

Professional Pensions awards. Given

Master Trust continues to be the

fastest-growing area of the workplace

market, we are particularly proud of

thisachievement. These, among other

accolades,have supported 60% growth

inour Master Trust assets over the last

two years, taking AUA to £14.2 billion.

We continue to enhance our market-leading

proposition, often with sector-first

initiatives including being the first provider

to successfully adopt the Sustainability

Improvers™ labelling, which is now across

£39 billion AUA within our Sustainable

Multi Asset (‘SMA’) default.

In March 2026 we marked the fifth

anniversary of our SMA strategy, recording

a cumulative performance of 55.7% gross

since launch, outperforming its CPI +3.5%

benchmark despite periods of high inflation.

We are currently preparing to launch Future

Opportunities, an alternative pension

default fund which is designed to offer

higher future returns through diversified

access to high-quality private assets and

will complement the strong foundation

ofour flagship default strategy.

In a growing market, with over £200 billion

inthe single employer trust market and

continued consolidation into Master Trusts,

in 2025, we further evolved our Master Trust.

Developments included a retirement-only

section, a deferred member section and the

ability to accept defined benefit surpluses

into the Master Trust, to position us well

when these opportunities come to market.

Alongside offering market-leading

propositions, key to our success is the

service to both employers and members.

Our digital capabilities in particular help

to support our members’ financial

wellbeing and empower them to engage

with their financial futures.

Our drive and pace to deliver for customers

continues to improve, with 635 releases

across our online estate this year. Of these,

approximately one-third were changes

toimprove experience. Customers

responded, logging in c.30 million times,

an increase of 9% year-on-year. Of these,

72% were through our independently

verified, market-leading app. Our app was

ranked number one across the leading

workplace providers in BehindLogin’s

comprehensive and independent

benchmarking report

We launched our Retirement Hub, a

newand improved one-stop destination

designed to help customers make confident,

informed decisions about their retirement.

In doing so we’ve brought together

refreshed educational content, real-life case

studies and easy-to-access tools and services,

all in one place. This launch, alongside

Family Finance Hub and the Retirement

Income Tool, reflects our joined-up approach

to helping people make confident financial

decisions, wherever they are in their

retirement planning journey.

Grow

Meeting more of our existing

customers’ needs andacquiring

new customers.

We are helping new and

existing customers on

their journey to and

through retirement by

leveraging our scale and

expertise to deliver

integrated retirement

solutions that drive

sustainable outcomes

andstrong returns.

£5.3bn

Workplace net fund flows

(2024: £5.3bn)

Our strategic priorities continued

1. https://behindlogin.com/report/pension-

benchmark-2025/

2. New products launched since re-entering

themarketin 2023.

30 Standard Life plc Annual Report and Accounts 2025

Strategic report

Operating Cash Generation

IFRS adjusted operating profit

20252024

0.9

1.5

0.8

1.4

2.0

1.5

1.0

0.5

£bn

Delivering profitable growth

Expanding our Retail capabilities

Having acquired customers through

our Workplace offering, we are

focused on retaining them for longer

as they transition to and secure

income in retirement. Our broader

product portfolio provides a key step

in unlocking the retail market where

we are now focused on connecting

these products and propositions

onto the right adviser platforms and

into the right direct channels.

We have widened the availability of

the Standard Life retirement offering

to now include ReAssure customers.

We had already made this available to

Phoenix Life customers a number of

years ago and in recent years have been

focusing on our engagement with these

customers, ensuring they are aware of

the wider offering they have available to

them within the Group. As a result of this

focus, across the Phoenix Life population

we have seen an increase from 25%

retained in 2023 to 34% in 2025.

Having launched the smoothed

managed fund product in 2024, we

expanded the distribution in early

2026 so it is now available on both the

Quilter and Fidelity Adviser Solutions

platforms. As the funds continue to

build a demonstrable performance

track record, on top of the expanded

distribution, we anticipate attracting

additional investments in the product.

In support of us being able to deliver

more bespoke advice to our customers

we launched Standard Life Financial

Advice. The service aims to help those

who wouldn’t usually consider paid

advice, which accounts for c.90% of

the UK population, gain access to

the support they need when saving

and deciding how to take their

pension income. We launched with

10 advisers and will expand the team

to meet future demand as it arises.

One significant change that we are

expecting in 2026 is the final rules of the

new Targeted Support permission from

the Financial Conduct Authority (‘FCA’).

This will allow us to engage with

customers in a more tailored fashion,

helping them with the complex decisions

around saving and retirement. These

changes should be viewed alongside

thepotential arrival of the first pensions

dashboard that will allow consumers

toaggregate their pensions data.

Our Retail business remains in net fund

outflow at present but encouragingly is

showing signs of improvement. Through

better supporting and engaging the 1-in-5

adults who are already StandardLife plc

customers, we will make further inroads

into stemming the annual outflows from

our legacy products.

Enhancing and leveraging our

annuities capabilities to support

secure income in retirement

Since re-entering the individual annuity

market in 2023, we have looked to

provideinnovative products and solutions

to meet our evolving customers’ needs

and are now able to provide a full

range ofretirement products. New

product launches in 2025 included the

StandardLife Guaranteed Lifetime

Income plan with Fidelity. Encouragingly

we have seen 60% year-on-year growth

innew individual annuity product

lines in2025

, with £1.2 billion of total

assets written (2024: £1.0 billion).

To further enhance our digital experience

for individual annuity customers we

launched the UK’s first digital, signature-

free, annuity application process in May,

whichis fully integrated with a number

ofkey portals. This followed the launch of

Smoothed managed fund

These capital-light funds are designed to

helpgrow pension investments while providing

somereassurance from the daily uncertainty

ofinvesting. Our smoothed managed funds are

designed to cushion the daily ups and downs

ofthe stock market. This helps reduce the risks

created by needing to withdraw income at regular

but otherwise inopportune times, as well as

arising from the unpredictability of life events.

Aswe build our performance track record further

and expand onto new platforms we see this as

anattractive foundation for future growth.

Find out more on our website

Annuity Desk for Standard Life customers,

which provides a seamless, personalised

journey when exploring annuity options.

We’ve continued to enhance our

Pension Risk Transfer (‘PRT’) offering.

This included leveraging our extensive

novation experience, to support

conversion of schemes with existing

longevity insurance into PRT transactions.

This means we have the expertise to

help customers with a broad range

of complex requirements. This,

among other innovations including

equalising gender benefits, enabled

us to complete our largest-ever PRT

deal in July worth £1.9 billion.

Having begun completing buy-outs

in 2024, momentum has continued

in 2025. This represents an attractive

additional customer acquisition tool

for us and strengthens the number of

customers we can cross-sell to. At the

end of 2025, we had c.31k members as

StandardLife customers, gaining access

to ourcustomer portal, online tools,

guidance and wider support to help them

manage their retirement with confidence.

31Standard Life plc Annual Report and Accounts 2025

Strategic report

Our strategic priorities continued

Optimise

Optimising our scale

in-force business and

balance sheet.

Capital improvements are generated by

improving our capital and balance sheet

modelling as the investment universe

evolves. This is enabled by enriched asset

data and calculation granularity which in

turn provides greater accuracy of risk.

Inpart this opportunity arises as a function

of our history of back book consolidation

which enables us to identify efficiencies.

Lastly, we are increasing the simplification

of fund management as our asset base

grows, through fee reviews of investment

management agreements as well as fund

rationalisation. We currently have c.5k

funds so there is still significant

simplification opportunity.

Evolving our asset

managementstrategy

To optimise customer outcomes and

enhance returns we have been evolving

our approach to asset management.

Historically we have operated an

outsourced operating model for all

assets, partnering with the best asset

manager in each asset class that we

operate across. For our Pensions and

Savings business, which represents the

majority of our AUA, this strategy is

unchanged. Our team is solely focused

on providing the best solution and

execution for our policyholders. Moving

forward, we expect to consolidate the

number of asset managers we partner

with, and Aberdeen continues to be our

key asset management strategic partner,

potentially attracting a greater share

of the Pensions and Savings assets.

To optimise our scale in-force business

and our balance sheet we are further

enhancing our strong existing capabilities

in asset and liability management to

deliver sustainable recurring management

actions over the long term, as well as

deleveraging to our c.30% Solvency II

leverage target by 2026.

We embed sustainability throughout

our business and across our strategic

priorities. As a result, investing in a

better future is a key part of optimising

our in-force business, as we look to

protect our customers from the risks

of, and maximise the opportunities

presented by, climate change.

For more information see

our Sustainability Report

Delivering recurring

management actions

In 2025 we delivered £560 million

ofrecurring management actions

(2024:£537 million), in line with our

c.£500 million per annum guidance.

These recurring management actions

are the small repeatable actions that

wetake to optimise our in-force balance

sheet. They contribute to increased cash,

capital and earnings, while ensuring that

our risk profile remains unchanged.

They can be broadly grouped into

three categories of annuity portfolio

re-optimisation, capital improvements

and fund simplification.

Within annuity portfolio re-optimisation

we evolve our annuity-backing asset

portfolio as market and economic

conditions change, evolving the

holdings in the portfolio in line

with our risk appetite. We are also

increasingly participating in new debt

issuances. We see these management

actions as a repeatable source of

income into the long term.

We are deleveraging our balance sheet and further

enhancing our strong existing capabilities in asset

and liability optimisation. This approach enhances

capital efficiency and supports predictable

long-term value creation for investors.

As we continue to

evolveour unique asset

management capabilities

we’re ensuring that

everydecision supports

long-term resilience and

delivers better, more

dependable outcomes

forthe millions of

customers who trust us

with their retirement.

Nuwan Goonetilleke

Interim Group Chief Investment Officer

£560m

recurring management actions

delivered in 2025 (2024: £537m)

32 Standard Life plc Annual Report and Accounts 2025

Strategic report

2024 2025 2026

target

36%

33%

c.30%

(6%)pts

Deleveraging our balance sheet

The strength of our execution against

ourstrategic priorities is driving the

generation of excess capital which is

allowing us to deliver and increase the

quality of our capital.

In line with recent years we used surplus

cash to repay historic M&A-related debt.

In February 2025 we repaid c.£200million

of debt, with a further c.£200 million

redeemed in December 2025.

Our Solvency II leverage ratio at the

endof December improved to 33%

(2024:36%) and we are on track for a ratio

of c.30% by the end of 2026. Progress

to reach our Solvency II leverage ratio

target may not be linear as we may

choose to refinance some tranches of

remaining debt in the intervening period.

Using our scale to create

abetter future

We continue to integrate decarbonisation

strategies into our portfolio, ensuring

effective stewardship of our assets and

investing in climate solutions. We see this

commitment as essential to managing the

risks and opportunities that climate

change poses to our customers and a key

step in meeting our interim 2025 and 2030

As signalled in March 2025, our strategy

for the management of our £41.8 billion

annuity-backing assets is evolving to

one which is predominantly in-house,

leveraging the internal capabilities we

have built to manage derivatives, public

credit and private assets alongside

partnerships to source differentiated

and unique private assets.

We’re excited about the benefits this brings

by underpinning the delivery of annuity

portfolio re-optimisation management

actions and greater cost efficiency.

Improving customer

returns with evolved

asset management

As signalled in March 2025, our

strategy for the management of our

annuity-backing assets is evolving

to one which is predominantly

in-house, leveraging the internal

capabilities we have built. We’re

excited about the benefits this

brings by underpinning the

delivery of annuity portfolio

re-optimisation management

actions and greater cost efficiency.

We are now managing £7 billion of

our £41.8 billion portfolio in-house,

with planning progressing to

in-house a further £20 billion.

£7bn

annuity-backing assets

nowmanaged in-house

Deleveraging our balance sheet

On track to achieve our c.30%

Solvency II leverage ratio target

by the end of 2026

decarbonisation targets on our journey to

being net zero by 2050. We exceeded our

2025 targets which included reducing the

emissions intensity of our listed equity and

credit portfolio by 58%, well ahead of our

target for a 25% reduction by 2025, as well

as achieving net zero in our own operations.

We are making good progress towards

our 2030 targets to reduce the emissions

intensity of our investment portfolio and

supplier base by 50%. However, our

ability to achieve our targets is ultimately

dependent on action from others and

factors outside our direct control.

Standard Life has been at the forefront

of developments to integrate the

opportunity offered by private markets

in its pension propositions through

Future Growth Capital (‘FGC’). Via FGC,

Standard Life DC customers will have

exposure to a range of innovative fast

growing UK companies through FGC’s

venture capital allocations including

life sciences and technology. We are

continually scaling and deploying

across all private asset classes.

Standard Life was also an original

signatory of both the Mansion House

Compact and the Mansion House Accord.

33Standard Life plc Annual Report and Accounts 2025

Strategic report

Our strategic priorities continued

Enhance

Transforming our operating

model and culture.

We are transforming our operating model

and culture to drive better customer

outcomes, scalability and efficiency.

Thistransformation underpins our ability

to deliver strong and sustainable returns

while maintaining a high-performance

culture. We will do this by completing

ourplanned integrations and customer

policy migrations, alongside our

transformation programmes, and through

driving simplification to an efficient,

Group-wide operating model that

benefits both our customers and our

colleagues. This supports us in delivering

a seamless unified customer experience

and enables us to further enhance our

cost efficiency.

Alongside this, we are also committed

tobeing a leading responsible business,

which attracts and retains the best

talent,through a diverse and inclusive,

high-performance culture.

Driving scale efficiencies

Our focus on driving efficiencies and

better customer outcomes has supported

the delivery of £180 million of run-rate

cost savings in 2025. The progress we

aremaking means we are confident of

achieving our £250 million run-rate cost

savings target by the end of 2026.

75% of policies on their

end-state platform having

progressed our migrations

Having already moved over 1.2 million

Phoenix Life customers from Capita to

TCS BaNCS, in 2025 we completed the

migration of the remaining 450k

customers. All our Phoenix Life

customers, previously administered by

Capita, are now serviced by Diligenta on

TCS BaNCS, allowing us to fully exit our

contracts with Capita.

We completed the second phase of

ourStandard Life policy migrations to

Diligenta with c.340k policies migrated

tothe TCS BaNCS platform at the start

of2025 and a further 1.1 million policies

migrated in the third quarter,

representing our largest migration yet.

Until now, our integration and migration

programmes have focused on moving

existing policies to TCS BaNCS. However,

we have now reached the point where we

Progressing our migrations

and integrations alongside

transforming our operating

model andculture are key

tooursuccess.

34 Standard Life plc Annual Report and Accounts 2025

Strategic report

2025 run-rate

cost savings £180m

2026 expected

run-rate savings £70m

£250m

run-rate cost

savings target

Simplifying our transformation landscape

are able to start writing selected new

business directly on TCS BaNCS for our

Standard Life customers and we will

continue rolling this out over the next

18months.

In March 2025 we announced a new

strategic partnership with Wipro

todiversify our outsourcing partner

ecosystem and more specifically to deliver

administration services for the c.1.9 million

policies on the ALPHA platform which

predominantly includes our ReAssure

customers. We safely transferred the

ALPHA platform and servicing to Wipro

atthe end of September 2025.

Product simplification delivering

better customer outcomes

Product simplification is all about making

things simpler and better for both

our customers and our business. It’s a

great example of how Standard Life has

embraced Consumer Duty and is putting

itsrequirements into practice. By moving

appropriate customers into newer, easier-

to-understand products, where we think

it’s in their interests to do so, everyone

can benefit. In doing so customers get

more flexible and wherever possible

lower-cost products, and we become

more efficient and agile as a business.

Standard Life looks after more than

3k different products, so there’s a lot

to do. In 2025 we ran a successful pilot

exercise and we’re targeting upgrading

a further c.80k customers this year.

1. Through Servaada, Wipro’s FCA regulated entity.

2. The 2025 figure excludes colleagues who left the

business through TUPE transfer to Wipro.

Simplifying and transforming

ourorganisation

We continue to make good progress in

simplifying our business into an efficient,

Group-wide structure. In 2025 we brought

our Retirement Solutions and Asset

Management business into a single

business unit. By aligning two closely

connected areas – one designing and

delivering retirement income products,

the other managing the assets behind

them – we’re working more closely to

deliver better outcomes for our customers

and other key stakeholders. Bringing

these capabilities together enables more

joined-up decision making, better risk

management and faster, more flexible

responses to changing customer and

market needs, which in turn underpins

the delivery of our c.£500 million recurring

management actions per annum.

In April 2025 we launched the Finance

Transformation Programme. Through

this dedicated programme, a new finance

organisation design was created, enabling

streamlined processes, increased

automation and enhanced controls.

The additional tools and capabilities

delivered by this transformation,

combined with other initiatives which

simplify current processes, will result

in a reduction in manual interventions

and hand-offs between teams.

In February 2026 we changed our name

from Phoenix Group Holdings plc to

Standard Life plc. The move aligned

our brand strategy with our Group

strategy, helping with our objective

to simplify our business. For example,

by consolidating the brands, we have

created a single-brand team and in doing

so we have reduced the cost of brand

management. It unifies our colleagues

and strengthens our employer brand.

Italso reduces duplication and costs, and

it supports our organic growth strategy.

We always try to mitigate the need for

compulsory redundancies in any period

of transformation. However, this is

not always practically possible; in 2025

c.600 colleagues left StandardLife

(2024: c.300) as a result of our wider

transformation programme

We want to create the conditions for our

people to succeed in a high-performance,

customer-centric, purpose-led culture.

Following the recent transformation

programmes there has been no long-

term impact on colleague retention rates.

Although Standard Life engagement rate,

reflected in our employee Net Promoter

Score, ended the year on a score of +22

(2024: +23), we’ve continued to be above

average within the finance industry.

We have continued to make progress

against our gender, ethnicity and inclusion

goals in 2025. We set ourselves a

stretching gender target of 42% women

at Senior Leadership level; we ended the

year at 40.2% (2024: 39.7%). We were

delighted to rank fourth for female

leadership overall in the FTSE 100 rankings

in the 2025 FTSE Women Leaders Review.

A strong culture is the

foundation of sustainable

transformation. At

Standard Life, we’re

building a culture shaped

by our colleagues –

onethat’s connected,

innovative and ambitious.

Sara Thompson

Group HR Director

Driving scale efficiencies

On track to deliver our £250m

run-rate costsavings target by

theend of2026

In March 2025, we entered an

agreement with a new strategic

partnership with Wipro

, which,

effective from the end of September

2025 provides life and pensions

servicing for our ReAssure

customersand owns the ALPHA

platform. This approach simplifies

ourtransformation landscape and

enables a sharper focus on other key

strategic priorities and capabilities.

This appointment complements our

continuing partnership with Diligenta

75%

policies on their

end-state platform

who remains a key strategic

partnerforStandard Life.

Diligenta will continue to play

acritical role in enabling us to

deliverour long-term growth

andcustomer ambitions.

35Standard Life plc Annual Report and Accounts 2025

Strategic report

REM

APM

REM

APM

REM

APM

REM

APM

2025

2023

2024

£1,

474m

£1,403m

£1,146m

2025

2023

2024

£1,711m

£1,779m

£2,024m

2025

2023

2024

176%

172%

176%

2025

2023

2024

33%

36%

2025

2023

2024

£945m

£825m

£629m

Measuring our progress

2025 has delivered strong performance across our key metrics.

Key performance indicators

Financial KPIs underpinning our financial framework

year ended 31 December

In March 2024 we

outlined a new 3-year

strategy for 2024–26

which supports us in

achieving our vision and

delivers growing cash,

capital and earnings.

Ourstrategy fully embeds

our key environmental,

social and governance

(‘ESG’) themes of

PeopleandPlanet.

Why we use this indicator

Total cash generation represents the

total cash remitted from the operating

entities to the Group and is made up

of the OCG and non-operating cash

generation, which includes non-recurring

management actions and the release

of free surplus. This cash generation

provides capacity for the Group’s

non-recurring uses including investment

across our strategic priorities to

support us in achieving our vision.

Why we use this indicator

Introduced in 2024, OCG represents the

sustainable level of cash generation in

our Life Companies each and every year,

that is remitted from our underlying

business operations. The measure

provides the sources of recurring organic

cash generated. It supports the Group’s

dividend, debt interest, allocation of

c.£200 million per annum of capital

into annuities, and central costs.

Why we use this indicator

The SCCR demonstrates the extent

to which shareholders’ Eligible Own

Funds cover the Solvency Capital

Requirements. It therefore measures

the capital adequacy of the Group

from a shareholder perspective.

Why we use this indicator

The Group seeks to manage the level of

debt on its balance sheet by monitoring

its financial leverage ratio. We choose

to focus on Solvency II leverage ratio on

a regulatory basis as that is consistently

understood and used by both equity and

debt investors. By reducing leverage,

we improve the quality of our capital.

Why we use this indicator

We use IFRS adjusted operating profit

as a measure of IFRS performance

based on long-term assumptions.

Adjusted operating profit is less affected

by the short-term market volatility

driven by Solvency II hedging and

non-recurring items than IFRS profit.

Operating Cash Generation (‘OCG’)

£1,474m

Total cash generation

£1,711m

Group Solvency II Shareholder Capital

Coverage Ratio (‘SCCR’) (estimated)

176%

Solvency II leverage ratio

33%

IFRS adjusted operating profit

£945m

36 Standard Life plc Annual Report and Accounts 2025

Strategic report

REM REM REM

REMREM

2025

2023

2024

88%

87%

2025

2023

2024

93%

94%

93%

2025

2023

2024

+22

+23

+32

2025

2023

2024

40.2%

39.7%

39.1%

2025

2023

2024

44 tCO

e/£m

52 tCO

e/£m

62 tCO

e/£m

Non-financial and sustainability KPIs underpinning our ESG strategy

year ended 31 December

Why we use this indicator

This measure highlights how satisfied

our customers are with Standard Life’s

telephony servicing propositions

across our various brands.

Why we use this indicator

At Standard Life we want to make sure

our colleagues represent our wider

community and so we are committed

to promoting diversity, equity and

inclusion across the business, which

enables colleagues to bring their

whole self to work. The figure reflects

the percentage of senior leadership

who identify as female out of the

total senior leadership population.

Why we use this indicator

This measure highlights how

satisfied our customers are with

StandardLife’s digital service

proposition across our various brands.

Why we use this indicator

We set an interim net zero target of

a25% reduction in the carbon intensity

of our listed equity and credit portfolio

(where we have control and influence)

by 2025, relative to our 2019 baseline.

To date we have achieved a 58%

reduction and under most scenarios

areon track for our 2030 50%

reduction target.

Why we use this indicator

We want to create the conditions

for our people to succeed in a

high-performance, customer-centric,

purpose-led culture and so getting

regular colleague feedback is important

to enable us to track progress and

respond to feedback as we deliver our

ambition. Employee Net Promoter Score

(‘eNPS’) is a broadly used and holistic

metric that indicates how colleagues

feel about working for the Group.

Strategic priorities

Grow

Optimise

Enhance

Remuneration and APMs

REM KPIs linked to

Executiveremuneration.

Seepages 136 to 175.

APM All amounts throughout the

report marked with APMare

alternative performance measures.

See pages 340 to 345.

Sustainability strategy

People

Planet

Embed responsibility

Customer satisfaction

– Telephony

88%

Customer satisfaction

– Digital

93%

Colleague engagement

eNPS score

+22

Female senior leaders

40.2%

Decarbonising our

investment portfolio

58%

37Standard Life plc Annual Report and Accounts 2025

Strategic report

13% CAGR

FY2023 FY2024 FY2025 FY2026

target

1,146

1,403

1,474

Mid-single

digit %

growth

3ppts improvement

FY2023 FY2024 FY2025 FY2026

target

3636

c.30

23% CAGR

FY2023 FY2024 FY2025 FY2026

target

629

825

945

c.£1.1bn

Business review

Our 2025 results reflect another year of

strong, meaningful progress towards our

2026 financial targets. We are firmly on

track to achieve these goals as we work

towards our vision to be the UK’s leading

retirement savings and income business.

Operating momentum underpins

our financial progress

In March 2024 we set 3-year targets

under our financial framework of cash,

capital and earnings, and we were

able to upgrade a number of those

targets in March 2025. Two years into

our 3-year strategic plan, the Group

has delivered clear operational and

financial improvement across our Grow,

Optimise and Enhance priorities. Strong

operating performance and sustainable

cash generation continue to increase

financial flexibility and support delivery

of our 2026 financial framework.

In 2025, Operating Cash Generation

increased 5% and IFRS adjusted operating

profit rose 15%, driven by profitable

growth in both our capital-light,

fee-based Pensions and Savings business

and our capital-utilising Retirement

Solutions business. Growing levels of

assets under management and improved

margins supported this outcome,

alongside further cost reductions as

weprogress towards our £250 million

netcost savings target by 2026.

We also strengthened our balance sheet,

improving Solvency II leverage to 33%,

with a clear line of sight to reaching

c.30%by 2026, while maintaining our

Shareholder Capital Coverage Ratio

(‘SCCR’) at the upper halfof our

140–180% operating range.

Delivering

cash, capital

and earnings

We are successfully executing on our 3-year

strategic priorities, which is driving improved

performance and creating strong operating

momentum across the key Group financial

framework metrics of cash, capital and earnings.

Nicolaos Nicandrou

Group Chief Financial Officer

Cash

Growing Operating Cash

Generation (£m)

Firmly on track to deliver our 2026 targets

Capital

Strengthening balance sheet (%)

Solvency II Leverage Ratio

Earnings

Improving profitability (£m)

IFRS adjusted operating profit

38 Standard Life plc Annual Report and Accounts 2025

Strategic report

Delivering successfully on our

financial framework metrics

In 2025, we delivered total cash

generation of £1,711 million, taking our

2024–25 total cash generation to £3.5

billion and remain on track to achieve our

2024–26 cumulative £5.1 billion target.

Underpinning this is strong growth in

OCG to £1,474 million, up 5% year-on-year

in line with our annual mid-single digit

percentage growth guidance. Our strong

operating momentum, supported by

the continued contribution of recurring

management actions delivered by our

in-house asset management team, has

led to increased OCG contributions

from our two main operating

businesses: Pensions and Savings (up

13% year-on-year) and Retirement

Solutions (up 3% year-on-year).

Importantly, OCG more than covered

our recurring cash uses and dividend,

totalling £1,051 million in the period,

and generated £423 million of excess

cash to deploy in line with our capital

allocation framework, which we

directed to reducing our debt leverage.

Once this deleveraging programme is

completed in 2026, future excess cash

will be deployed towards the most

attractive return opportunities across

growth investments, targeted M&A,

and increased returns to shareholders.

Our SII capital position remains strong

with improvements in the SII surplus

to £3.6 billion and in the SCCR to 176%.

This reflected positive net recurring

solvency capital generation of £0.4

billion, equivalent to a 9%pts increase

in SCCR. Other SII capital actions more

than covered our continued investment

across our strategic priorities to

grow, optimise and enhance, while

our hedging programme eliminated

the impact of market effects.

2025 financial summary

Financial performance metrics 2025 2024 YOY change

Cash Operating Cash Generation

£1,474m £1,403m +5%

Total cash generation

£1,711m £1,779m -4%

Solvency II capital Group Solvency II surplus £3.6bn £3.5bn +2%

Group Shareholder Capital Coverage Ratio

176% 172% +4%pts

Solvency II leverage ratio

33% 36% -3%pts

IFRS Adjusted operating profit

£945m £825m +15%

Loss after tax attributable to owners £(394)m £(1,078)m +63%

Shareholders’ equity £244m £1,213m -80%

Contractual Service Margin (gross of tax) £3,806m £3,257m +17%

Adjusted shareholders’ equity

£3,098m £3,656m -15%

Assets Assets under administration

£317bn £292bn +8%

Dividend Final dividend per share 28.05p 27.35p +2.6%

Total dividend per share 55.40p 54.00p +2.6%

1. Denotes metrics that are alternative performance measures (‘APMs’) – further information can be found on pages 340 to 345.

Growing momentum in the Group’s

operating performance is also evident

in the 15% increase in our IFRS adjusted

operating profit to £945 million.

Improved performance in Pensions and

Savings and in Retirement Solutions has

delivered higher IFRS adjusted operating

profit for these businesses, up 23%

and 19% year-on-year respectively.

We reported an IFRS statutory loss after

tax of £394 million in the period primarily

due to adverse economic variances of

£604 million pre-tax, reflecting the known

consequence of the Group’s hedging

programme under this reporting basis.

This statutory loss has impacted our IFRS

shareholders’ equity position, which has

reduced to £244 million. This decline

is not economically meaningful as the

strength of our underlying economic

financial position measured on a Solvency

basis remains unchanged, with no

consequential effect on cash generation,

liquidity or strategic flexibility. As a

reminder, our hedging programme aims

to protect cash and SII capital from

volatility in equities and interest rates,

thereby safeguarding the Group’s ability

to deliver a progressive and sustainable

dividend. The hedging covers components

of the Solvency balance sheet which

are not present under IFRS, giving rise

to accounting volatility. We continue to

prioritise stable SII surplus capital and

predictable dividends and accept the

hedge-related volatility in the IFRS result.

Notably, our Contractual Service Margin

(‘CSM’) (gross of tax) grew 17% in 2025,

which represents a sizeable stock of

value that will be released into IFRS

adjusted operating profit in future

years. The growth in our CSM partially

offset the decline in our shareholders’

equity, with adjusted shareholders’

equity of £3,098 million at end-2025.

As a result of our improved operating

performance, the Board is recommending

a 2.6% increase in the 2025 Final

dividend to 28.05 pence per share,

taking the Total dividend for the

year to 55.40 pence per share.

Alternative performance

measures

With our financial framework designed

to deliver cash, capital and earnings,

we recognise the need to use a broad

range of metrics to measure and report

the performance of the Group, some

of which are not defined or specified

in accordance with Generally Accepted

Accounting Principles (‘GAAP’) or the

statutory reporting framework.

We use a range of alternative

performance measures (‘APMs’) to

evaluate our business, which are

summarised on pages 340 to 345

39Standard Life plc Annual Report and Accounts 2025

Strategic report

Pensions and Savings

Retirement Solutions

Europe and Other

FY2024FY2023 FY2025

850

645

879

123

350

295

396

129

131

1,403

1,146

1,474

With-Profits

Corporate Centre

FY2024FY2023 FY2025

474

378

629

563

316

190

144

389

(102)

(93)

(114)

825

945

+5% +15%

Business review continued

Strong business momentum

supports our strong

operatingperformance

Our diversified business model

is a core source of strength for

our Group and provides a robust

foundation for sustainable and

predictable earnings performance.

Pensions and Savings, covering new and

in-force life insurance and unit-linked

investment products, remains a key

source of capital-light fee-based

income. Retirement Solutions includes

individual annuities and Pension Risk

Transfer (‘PRT’) business, which add

capital utilising spread-based margin

to our results, diversifying our earnings

sources. Europe and Other, which includes

Ireland, Germany and SunLife protection,

bring further diversification through

premiums, fees and investment margins

across distinct markets. With-Profits

continues to generate low-volatility

earnings via shareholder transfers

from the Group’s With-Profits funds.

Together, these segments have

underpinned the Group’s strong 2025

performance, enhancing OCG and

IFRS adjusted operating profit and

reinforcing our trajectory towards

the delivery of our 2026 targets.

This is our first year of providing a full

segmental breakdown of OCG. The largest

contributor to OCG is our Retirement

Solutions business which represents over

half of the total. In 2025, Retirement

Solutions OCG grew by 3% to £396million

(2024: £350 million), supported by

yield re-optimisation actions.

Our Pensions and Savings business is the

fastest growing contributor to OCG, up 13%

to £396 million in 2025 (2024: £350 million).

This growth was supported by business

growth and actions to reduce operating

costs and simplify fund structures.

Europe and Other and With-Profits broadly

maintained their combined £199million

OCG contribution, of £123million

(2024: £129 million) and £76million

(2024: £74 million) respectively.

In 2025 Pensions and Savings’ IFRS

adjusted operating profit grew by 23%

to £389 million (2024: £316 million)

reflecting the benefit of growing

assetsand improved cost efficiencies.

Retirement Solutions’ IFRS adjusted

operating profit increased 19% to

£563million (2024: £474 million),

supported by a higher CSM release

reflecting ongoing growth of the annuity

book, higher portfolio optimisation

actions and improved cost efficiencies.

Europe and Other IFRS adjusted operating

profit decreased to £83million (2024:

£96million), primarily due to a lower

insurance result, while With-Profits reported

a lower IFRS adjusted operating profit

result of £24million (2024: £41million)

asthe 2024 results included one-off

adjustments that did not repeat in 2025.

The Group’s Corporate Centre operating

loss of £114 million (2024: £102 million)

includes lower interest income of

£38million (2024: £54 million) from

reduced cash balances owing to debt

repayments made.

Business

segment

review

Operating Cash Generation (£m) IFRS adjusted operating profit (£m)

+5%

Group OCG growth REM APM

+15%

Group IFRS adjusted operating

profit growth REM APM

40 Standard Life plc Annual Report and Accounts 2025

Strategic report

Gross inflows

Gross outflows

FY2024FY2023 FY2025 FY2024FY2023 FY2025 FY2024FY2023 FY2025

8.5

4.5

6.1

7.1

9.3

10.0

5.3

4.7

(3.8)

(4.0)

(4.7)

(12.4)

(7.9)

(14.7)

(8.6)

(14.9)

(7.8)

5.3

+8bps

Pensions and Savings

performance driving

higherprofitability

Our Pensions and Savings business

reported 11% growth in gross inflows

to £17.1 billion

(2024: £15.4 billion

)

as our leading propositions and brand

support our strong momentum

here, and we continue to strengthen

our capabilities across both our

Workplace and Retail segments.

Workplace saw £10 billion of inflows in

2025, £1.5 billion of which were from new

scheme wins. Excluding new schemes,

gross inflows were £8.5billion, highlighting

the strong flywheel effect of this business.

In Retail, gross inflows continue to

improve, up 16% to £7.1billion in 2025,

benefiting from a greater take up of

ourdrawdown product, and higher

international bond sales.

Gross outflows totalled £19.6 billion

(2024: £18.7 billion

), and reflect our

higher asset base and actions taken by

our customers to access their retirement

savings in the form of annuity income,

drawdown payments or withdrawing

tax-free lump sumps, as they journey

to and through retirement.

Scheme retention in Workplace remains

high, and outflows reflect the higher

asset base, and the natural attrition

fromthose taking their pensions. Retail

outflows include fulfilling our primary

purpose of customers accessing their

retirements savings, estimated at

£5billion in 2025. While the remaining

retail outflows remain sizeable, we expect

them to improve as a percentage of AUA

as we increase our focus on retention.

The overall net outflow position was more

than offset by £24.6 billion of positive

market effects, driving AUA 8% higher

to £211.7 billion at 31 December 2025.

The capital-light fee-based nature of

this business means that we consider

IFRS adjusted operating profit as the

best measure to assess its performance.

The increasing scale of this business and

actions to reduce costs and simplify our

funds range drove a 2bps improvement

in operating profit margin to 19bps

(2024: 17bps). Combined with an average

AUA growth of 7%, this led to strong

growth in IFRS adjusted operating

profit of 23% to £389 million (2024:

£316 million). OCG similarly increased

to £396 million (2024: £350 million).

1. 2024 AUA, flows and average AUA have been restated

to reflect the reallocation of the Retail International

Bond from Europe and Other to Pensions and Savings.

2. Retail International Bond AUA and flows reallocated

from Europe and Other to Pensions and Savings for

2023, 2024 and 2025. 2025 also reflects the

reclassification of Corporate Trustee Investment Plan

Held for Transfer assets from Workplace to Europe and

Other at end-2025.

Pensions

and

Savings

19bps

IFRS adjusted operating

profitmargin APM

+7%

Average AUA growth APM

+23%

IFRS adjusted operating

profitgrowth APM

Workplace flows

strong (£bn) Retail flows

improving (£bn) Improved IFRS adjusted operating

profit margin (bps)

41Standard Life plc Annual Report and Accounts 2025

Strategic report

FY2023 FY2024 FY2025

0.6

1.0

1.2

+67%

+20%

FY2023

FY2024 FY2025

170

218

219

+49bps

FY2023 FY2024 FY2025

6.2

5.1

3.9

219bps

OCG spread APM

+3%

Average AUA growth APM

+3%

OCG growth APM

Retirement Solutions driving

resilient capital-efficient growth

We have two main product lines here,

being individual annuities and PRT.

We run £42 billion of annuity assets,

and it is the management of this

large book, that drives most of our

profitability. New volumes are not the

primary driver of current year profits

but are a source of future value.

Our Retirement Solutions business

reported 20% growth in individual

annuities new business to £1.2 billion

(2024: £1.0 billion) and we maintained

our discipline in PRT in a narrow credit

spread environment and competitive

market, writing £3.9 billion of new

business (2024:£5.1 billion). Due to our

proactive approach in managing capital

allocation and pricing discipline to secure

attractive returns, we took the strategic

decision to forgo volumes to protect the

economics, investing 21% less capital

this year. Our aim remains to direct up to

£200 million capital to annuities this year,

provided we secure sufficiently attractive

returns. We expect continuation of the

competitive landscape in 2026, and

we remain confident in our abilities

1. Indicative figures provided for OCG in 2023.

to win in thismarket, with £1.6 billion

of PRT transactions completed or at

an exclusive stage in 2026 to date. We

remain focused on disciplined capital

deployment in a competitive market.

The capital-utilising spread-based

natureof this business means that we

consider OCG as the most meaningful

measure to assess performance.

In-force business management has a

greater bearing on profitability and

cash generation than new business

flows. Our proactive management of

the in-force book combined with our

scale and efficiency, our effective risk

management, and our expertise in

delivering asset portfolio optimisation

actions, enabled us to sustain a

spread-based margin of 219 bps (2024:

218bps), dynamics which we consider to

be enduring. Around half of this margin

reflects the steady release of capital

and spread margins as our liabilities

run-off, with the other half relating to the

benefit from both yield re-optimisation

and capital improvement actions.

Applied to our growing average AUA,

which was up 3% at £40.2 billion

(2024: £39.0 billion), resulted in OCG

growth of 3% to £879 million (2024:

£850million). This growth accounts

for over half of the Group’s OCG.

IFRS adjusted operating profit also

increased to £563 million (2024:

£474 million) driven by disciplined

pricing, investment optimisation,

cost efficiencies and growth.

Retirement

Solutions

Discipline maintained on PRT

premiums (£bn)

Attractive OCG margins

(bps)

Individual Annuities strong

growth (£bn)

Business review continued

42 Standard Life plc Annual Report and Accounts 2025

Strategic report

OCG Recurring uses

£1,474m

£548m

£423m

£503m

Excess

Dividend

Other

recurring

uses

Consistent OCG delivery

In 2025, OCG increased 5% to £1,474

million (2024: £1,403 million), in line with

our guidance to grow OCG at a mid-single

digit percentage rate per annum. This

was driven by higher surplus emergence

of £914 million (2024: £866 million),

supported by new business written and

the benefit of our ongoing cost savings

programme, which have offset the

natural run-off of our in-force business.

The remaining £560 million of OCG

was generated through recurring

management actions (2024: £537 million),

reflecting another strong performance

driven by our developed in-house

asset management capabilities, and

in line with our guidance of delivering

sustainable recurring management

actions of around £0.5 billion per

annum. The majority of these actions

were portfolio optimisation actions

contributing £363 million (2024: £323

million), with a further £93 million from

fund simplification actions (2024: £122

million) and £104 million from capital

improvement actions (2024: £92 million).

Total cash generation supports

deleveraging and investment

Total cash generation during the period

was £1,711 million (2024: £1,779 million).

In addition to the OCG generated this

year, we also contributed £237 million

(2024: £376 million) of non-operating

cash generation from the delivery of

non-recurring management actions. Over

2024–25 we have delivered £3.5 billion

total cash generation and are on track to

achieve our 3-year target of £5.1 billion.

The £5.1 billion total cash generation

target is expected to exceed both our

expected recurring uses and the planned

investment in our business over the

2024–26 period, which together are

expected to total £3.9 billion. As a result,

we will generate £1.2 billion of excess

cash. In line with our capital allocation

framework, the financial headroom

created by this excess cash is being

directed to deleveraging in order to meet

our c.30% SII leverage ratio target by the

end of 2026, with £651 million of debt

already retired across 2024 and 2025.

Recurring uses of cash

Our recurring uses of cash comprise

of central operating expenses, debt

interest, capital invested in annuities

and shareholder dividends. Operating

expenses decreased to £112 million

(2024: £132 million) reflecting cost

reductions. Debt interest fell to £229

million (2024: £236 million) as we reduce

the level of debt on our balance sheet.

We invested £162 million of capital

into our annuities business (2024:

£206million) to support £5.1 billion

of new business annuity premiums

in the year (2024: £6.1 billion).

Combined, these recurring uses

excluding the shareholder dividend

reduced to £503 million (2024: £574

million) as we took steps to improve

both operating and capital efficiency.

Importantly, OCG of £1,474 million

more than covered the recurring uses

of cash including dividend in the period

of £1,051 million. The excess cash

generated of £423 million was principally

deployed to retire debt in support

of our deleveraging programme.

Non-recurring uses of cash

Non-operating net cash outflows

increased to £533 million (2024: £314

million), partly driven by cash collateral

outflows on currency derivatives used to

hedge non-sterling debt instruments of

£105 million, following depreciation of

the US Dollar in the period. Non-operating

costs also include our planned investment

across our strategic priorities of £275 million

(2024: £354 million) to grow, optimise and

enhance our business, as well as other

payments relating to provision of capital

support to new ventures, subsidiary

closure, costs and other one-off items

funded centrally.

Debt repayments

Net debt repayments were higher at

£398 million (2024: £253 million net

repayment) and represent the redemption

of $250 million of Restricted Tier 1

notes(£200 million) and £198million

Tier2 notes in February and December

2025, respectively.

Cash

£423m excess cash generated

from OCG in 2025

1. Comprises central operation expenses, debt

interest and capital invested in annuities.

£1,474m

Operating Cash Generation

REM APM

£1,711m

Total cash generation

REM APM

Standard Life plc holding companies’ sources and uses of cash

£m 2025 2024

Holding companies’ cash at 1 January

1,117 1,012

Operating Cash Generation 1,474 1,403

Non-operating cash generation 237 376

Total cash generation

1,711 1,779

Recurring uses of cash (1,051) (1,107)

Non-operating cash outflows (533) (314)

Holding companies’ cash, pre-debt movements 1,244 1,370

Debt repayments (398) (643)

Debt issuance – 390

Holding companies’ cash at 31 December

846 1,117

Operating Cash Generation comprises:

Recurring management actions 560 537

Surplus emergence 914 866

1. Total cash generation includes £123 million received by the holding companies in respect of tax losses surrendered

(2024: £156 million).

2. Holding companies' cash is an APM – further information can be found on pages 340 to 345.

43Standard Life plc Annual Report and Accounts 2025

Strategic report

Business review continued

Resilient Solvency II position

Our SII capital position remains resilient,

with an estimated surplus of £3.6 billion

(2024: £3.5 billion) and is stated after

theaccrual for the 2025 Final dividend.

Our surplus was £0.1 billion higher than

2024 despite retiring £398 million of debt

this year, demonstrating the improved

operating capital generation capabilities

of our business. Our SCCR increased

4%pts to 176% (2024: 172%) and remains

in the upper half of our target operating

range of 140–180%.

Recurring capital generation

In 2025, recurring SII capital generation

pre-dividend totalled £0.9 billion, with

£0.4 billion generated post-dividend

which increased the SCCR by 9%pts.

Surplus emergence from in-force

business, together with the release of

capital requirements, contributed

£0.9billion to the SII surplus and 21%pts

to the SCCR. In addition, we delivered

£0.5billion of recurring management

actions, predominantly Own Funds

accretive as a result of portfolio

optimisation actions, increasing the

SCCRby 13%pts.

Operating costs, dividends and debt

interest totalled £0.9 billion, reducing the

SCCR by 20%pts, while our new business

strain was lower this year at £0.1 billion,

reflective of lower capital allocation to

protect economics in a highly competitive

market, and reduced the SCCR by 5%pts.

Non-recurring capital generation

Non-recurring SII capital generation,

excluding the debt repayments, added

£0.1 billion to surplus, as £0.4billion

of surplus generated from other

management actions more than

offset our other non-recurring uses

in the period, including £0.3 billion of

investment spend and other items.

These uses primarily reflect our planned

investment to grow, optimise and

enhance our business over 2024–26 and

include the Day 1 benefit from appointing

Wipro as our new strategic partner to

assume management of the existing

ReAssure platform, ALPHA, earlier than

previously planned. Other management

actions include the benefits achieved

from transitioning to the in-house

management of our annuity-backing

assets, which has improved cost

efficiency and strengthened our ability to

deliver long-term value to shareholders.

They also include the benefits from

selling the shareholders’ share of future

income from our with-profits funds to

the estate of these funds. We continue

tobe well hedged on an economic basis

under SII and experienced a positive

impact of £0.1 billion this year driven

by a steepened yield curve, lower

inflation and higher equity markets.

This impact was offset by £0.1 billion

losses on currency hedge instruments

relating to our debt instruments.

Strong progress on leverage

Our SII leverage ratio improved by

3%pts to 33% at 31 December 2025

(2024: 36%), as a result of the £398

million debt repayments completed

in February and December 2025. We

remain on track to achieve our c.30% SII

leverage ratio target by the end of 2026,

although the path will not be linear.

Capital

£3.6bn

Group Solvency II surplus

(estimated) REM

176%

Group Shareholder Capital

Coverage Ratio (estimated) APM

33%

Solvency II leverage ratio REM APM

Solvency II economic sensitivity analysis

Surplus

(£bn)

SCCR

(%)

Solvency II base 3.6 176

Equities: 20% fall in markets – 7

Long-term rates: 100bps rise in interest rates – 4

Long-term rates: 100bps fall in interest rates – (4)

Long-term inflation: 50bps rise in inflation – (1)

Property: 12% fall in values (0.2) (4)

Credit spreads: 145bps widening with no allowance for downgrades 0.1 4

Credit downgrade: immediate full letter downgrade on 20% of portfolio

(0.3) (7)

Lapse: 10% increase/decrease in rates (0.2) (2)

Longevity: 6 months increase (0.4) (8)

1. Illustrative impacts assume changing one assumption on 1 January 2026, while keeping othersunchanged, and that

there is no market recovery. They should not be used to predict the impact of futureevents as this will not fully

capture the impact of economic or business changes. Given recent volatile markets,we caution against extrapolating

results as exposures are not all linear.

2. Impact of an immediate full letter downgrade across 20% of the shareholder exposure to the bond portfolio (e.g. from AAA

toAA, AA to A, etc.). This sensitivity assumes management actions are taken to rebalance the annuity portfolio backto the

original average credit rating and makes no allowance for the spread widening which would be associated with adowngrade.

Movement in Group Solvency II capital during 2025

Recurring capital generation of +£0.4bn

surplus and +9%pts SCCR

Non-recurring capital utilisation

of +£0.1bn surplus and +3%pts SCCR

£m 2024

Surplus

emergence

and release

of SCR

Recurring

management

actions

Operating

costs, debt

interest and

dividend

New

business

strain

Other

management

actions

Economics

and

temporary

strain

Investment

spend

and other

2025

(pre-debt

repayment)

Debt

repayment 2025

Own Funds 8.4 0.7 0.5 (0.9) 0.1 0.3 0.0 (0.4) 8.7 (0.4) 8.3

SCR (4.9) 0.2 0.0 – (0.2) 0.1 0.0 0.1 (4.7) – (4.7)

SII surplus 3.5 0.9 0.5 (0.9) (0.1) 0.4 0.0 (0.3) 4.0 (0.4) 3.6

SCCR

172% 21% 13% (20)% (5)% 9% 1% (7)% 184% (8)% 176%

1. The SCCR excludes SII Own Funds and Solvency Capital Requirements (‘SCR’) of unsupported With-Profit funds and unsupported pension schemes.

44 Standard Life plc Annual Report and Accounts 2025

Strategic report

FY2024 FY2025

£63m £117m

£250m

Delivered

Target

end-2026

IFRS adjusted operating profit

momentum continues

We generated a 15% year-on-year

increase in IFRS adjusted operating

profit to £945 million (2024: £825

million) driven by uplifts in both of

our two main operating business

units, Pensions and Savings (23%

growth year-on-year) and Retirement

Solutions (19% growth year-on-year).

Looking ahead, our continued IFRS

adjusted operating profit momentum

in 2025 provides us with confidence

in meeting our 2026 IFRS adjusted

operating profit target of c.£1.1 billion.

Accelerated delivery

ofcostsavings

The Group’s cost savings programme

remains firmly on track to deliver the

end-2026 targeted £250 million of annual

run-rate cost savings, net of inflation,

relative to the Group’s 2023 cost

levels, as we continue to enhance our

business and progress towards a more

efficient Group-wide operating model.

In 2025, £117 million of run-rate savings

were delivered, which combined

with the savings achieved in 2024,

brings the cumulative run-rate cost

savings total to £180 million across

2024–25, £55 million ahead of our

original delivery profile by 2025.

Of these run-rate savings, £110million

were earned in the year (2024: £28million),

with £55 million of the £82million

year-on-year increase emerging IFRS

adjusted operating profit, with the

balance accounted through the CSM.

Amortisation and impairment

ofintangibles

The previously acquired in-force business,

relating to IFRS 9 capital-light fee-based

business, is being amortised in line with

the expected run-off profile of the

investment contract profits to which it

relates. Amortisation and impairment

during the period reduced to £233

million (2024: £270 million) reflecting

the run-off of this acquired business.

Finance costs and other

non-operating items

Other non-operating losses in the period

totalled £396 million (2024: £520 million

loss), the majority of which reflects

£264million (2024: £372 million) of

planned investment spend across our

strategic priorities, with£132 million

(2024: £148 million) of other one-off items.

Finance costs of £193 million (2024:

£204 million) reflected interest

borne on the Group’s debt.

IFRS loss after tax shaped

byeconomic variances

The Group generated an IFRS loss after

tax attributable to owners of £394million

(2024: loss of £1,078 million). The loss

is driven by £604 million of adverse

hedging-related economic variances

(2024: £1,297 million adverse), primarily

from rising equity markets in the year

(FTSE 100 +21.5%, S&P 500 +16.4%

and Eurostoxx 50 +18.3%), and reflects

the result of the Group’s hedging

programme which aims to protect cash

and SII capital from volatility in equities

and interest rates. This gives rise to

accounting movements, as several of

the SII capital components covered by

hedging are not recognised on the IFRS

balance sheet, with the IFRS market

sensitivities shown on pages 242 to 248.

Earnings

£945m

IFRS adjusted operating profit

REM APM

£3,806m

Contractual Service Margin

(gross of tax)

£3,098m

IFRS adjusted shareholders’

equity APM

IFRS income statement

£m 2025 2024

Pensions and Savings 389 316

Retirement Solutions 563 474

Europe and Other 83 96

With-Profits 24 41

Corporate Centre (114) (102)

Adjusted operating profit 945 825

Amortisation and impairment of intangibles (233) (270)

Finance costs attributable to owners (193) (204)

Other non-operating items (396) (520)

Profit/(loss) before economics, tax and NCI 123 (169)

Economic variances (604) (1,297)

Loss before tax and NCI (481) (1,466)

Profit before tax attributable to non-controlling interest 49 12

Loss before tax attributable to owners (432) (1,454)

Tax credit attributable to owners 38 376

Loss after tax attributable to owners (394) (1,078)

Run-rate cost savings

45Standard Life plc Annual Report and Accounts 2025

Strategic report

Business review continued

Earnings continued

CSM momentum drives value

The Group’s CSM (gross of tax) rose by

17%to £3,806 million at 31 December

2025 (2024: £3,257 million) and represents

a sizeable stock of value that will unwind

into IFRS adjusted operating profit in

future years.

The increase in the period was driven

bya£296 million contribution from

strategic project initiatives, which

comprised the impact of the lower cost

of managing ourannuity-backing assets

which will be in-housed and the impact

from the net expense benefits related to

the Wipro strategic partnership. An

additional £150million contribution was

generated from new business, principally

from annuities written in Retirement

Solutions (2024: £248 million), with a

further £308million from assumption

changes, experience profits, positive

market effects and other(2024: £370

million). Both periods benefited from lower

expense maintenance loadings reflecting

our cost savings initiatives and from

positive market effects.

The 2025 CSM release into the income

statement of 7% is broadly in line with

theprior year (2024: 8%), contributing

£274million to pre-tax IFRS adjusted

operating profit (2024: £281 million).

Within-year net CSM generation more

than exceeding amortisation, the net

oftax value of theCSM increased to

£2,854 million at 31 December 2025

(2024: £2,443 million).

Other stores of value not

captured in IFRS balance sheet

In addition to the store of future value

of£2.9 billion (post-tax) captured

in the CSM for insurance contracts,

there is afurther store of future value

which isincluded in Solvency II Own

Funds, relating to the value-in-force for

investment contracts. This increased

to£4.4 billion post-tax in2025 (2024:

£3.4billion post-tax), reflecting new

business flows, cost savings, improved

in-force business management and equity

market rises. These stores of valuewill

emerge through IFRS adjusted operating

profit in future years, providing a strong

underpin to the Group performance

trajectory for many years to come.

IFRS shareholders’ equity and adjusted shareholders’ equity

£m 2025 2024

Adjusted operating profit 945 825

Recurring uses:

Amortisation of intangibles (233) (270)

Finance costs attributable to owners (193) (204)

Dividend (548) (533)

Adjusted operating profit before tax, less recurring uses (29) (182)

Non-recurring uses, economics and tax:

Other non-operating items (396) (520)

Economic variances (604) (1,297)

Tax and other items recognised in equity 60 470

Movement in shareholders’ equity (969) (1,529)

Opening shareholders’ equity 1,213 2,742

Movement in shareholders’ equity (969) (1,529)

Closing shareholders’ equity 244 1,213

CSM (net of tax) 2,854 2,443

Adjusted shareholders’ equity 3,098 3,656

Movement in Group Contractual Service Margin during 2025, including segmental split

£m

Opening

CSM

(gross)

New

business

Interest

accretion

Assumption

changes,

experience

economics

and other

Strategic

project

initiatives

Closing

CSM,

pre-release

(gross)

CSM

release

Closing

CSM

(gross) Tax

Closing

CSM

(net)

Pensions and Savings 263 – – 56 10 329 (33) 296 (74) 222

Retirement Solutions 2,306 128 61 223 271 2,989 (189) 2,800 (700) 2,100

Europe and Other 196 22 2 (5) 5 220 (24) 196 (49) 147

With-Profits 492 – 6 34 10 542 (28) 514 (129) 385

2025 Total Group CSM 3,257 150 69 308 296 4,080 (274) 3,806 (952) 2,854

2024 Total Group CSM 2,853 248 67 370 – 3,538 (281) 3,257 (814) 2,443

Adjusted shareholders’

equityhighlights strong

underlying value

We have built on our progress made in

2024 in increasing the level of pre-tax

IFRS adjusted operating profitability to

cover our recurring uses. In 2025 only

£29million (pre-tax) remained uncovered,

an improvement on the equivalent

amount of £182 million in 2024.

We continue to expect that our target

ofc.£1.1 billion IFRS adjusted operating

profit in 2026 will be sufficient to fully

cover our recurring uses and create

excess to fund non-recurring uses.

The level of non-operating items are

elevated at present, largely driven by our

planned 3-year non-recurring investment

spend. The level of non-operating items

is expected to moderate once our current

spend on migrations and transformation

is completed. From 2027 we expect

adjusted operating profit to cover all

uses, excluding economic variances.

The resulting IFRS loss after tax in the

period drove shareholders’ equity lower

at the end of 2025 to £244 million (2024:

£1,213 million). As described above, this is

owing to economic variances and has no

impact on operating performance, cash,

or capital strength, so the movement

does not change the financial viability of

our business, which is best measured by

reference to Solvency capital, which

includes the store of future value on

annuities, with-profits and investment

contract business. The Board continues

to prioritise stable SII surplus capital and

predictable dividends and accepts the

hedge-related volatility in the IFRS result.

Adjusted shareholders’ equity provides a

better, albeit still partial, view of the value

of the business under IFRS. It comprises

IFRS shareholders’ equity and the CSM

(net of tax) and stood at £3,098 million at

31 December 2025 (2024: £3,656 million).

46 Standard Life plc Annual Report and Accounts 2025

Strategic report

2026 financial targets

Financial target Status Performance in 2025 and 2024

Cash Mid-single digit percentage growth p.a. in Operating

Cash Generation

On track £1,474m, +5% vs FY2024 (£1,403m)

Total cash generation of £5.1bn across 2024–26 On track £3.5bn across 2024–25 (FY2025: £1.7bn, FY2024: £1.8bn)

Capital Operate within our 140–180% Shareholder Capital

Coverage Ratio operating range

On track 176%, within operating range (FY2024: 172%)

Solvency II leverage ratio of c.30% by the end of 2026 On track 33%, -3%pts vs FY2024 (36%)

Earnings c.£1.1bn of IFRS adjusted operating profit in 2026 On track £945m, +15% vs FY2024 (£825m)

£250m of annual run-rate cost savings by the end of2026 On track £180m across 2024–25 (FY2025: £117m, FY2024: £63m)

In March 2024, the Board outlined

a 3-year strategy for 2024–26, to

support the creation of a business

which delivers sustainable and

growing cash, capital andearnings and

adopted a progressive and sustainable

ordinary dividend policy,reflecting its

confidence in the Group’sstrategy.

In operating this dividend policy, the

Board will announce any potential

annual dividend increase alongside the

Group’s Full Year results and expects

the Interim dividend to be in line with

the previous year’s Final dividend.

The Board continues to prioritise the

sustainability of our dividend over

the long term. Future dividends and

annual increases will be subject to

the discretion of the Board, following

assessment of longer-term affordability.

In operating the policy and assessing

longer-term affordability, the Board

considers the quantum and trajectory of

the Group’s OCG, SII surplus, SCCR and

the distributable reserves atthe Group’s

holding company.

At 31 December 2025, distributable

reserves at Standard Life plc, the Group’s

holding company that pays dividends to

shareholders, stood at £5,800 million

(2024: £5,571 million), supported by

The Group continues to operate in an

environment with increased global

geopolitical and macroeconomic

uncertainty, including the escalation

of conflict in the Middle East in recent

weeks. Despite this backdrop, the UK

consumer retirement needs we serve

arelong term in nature and enduring.

Two years into this 3-year period, we have

made demonstrable progress across our

strategic priorities and our improved

operating performance puts us firmly on

track to meet our 2026 financial targets.

distributions from its main operating

companies which continue to report

under UK GAAP and carry sizeable

distributable reserves. In 2025 the

Group’s main operating subsidiaries

generated strong UK GAAP net profits

after hedging impacts, which supported

the cash remittances to Group.

In the consolidated IFRS financial

statements, the Group is targeting

apositive pre-hedge post-dividend

IFRSnet profit contribution to the

IFRSshareholders’ equity from 2027.

TheGroup accepts the hedge-related

volatility that impacts IFRS shareholders’

equity, which is a known consequence of

our Solvency II hedging strategy that is

designed to protect our cash, capital

anddividend.

In this overall context and consistent with

previous guidance, the Board considers

that the Group’s consolidated IFRS

shareholders’ equity is not a constraint

to the payment of our dividends.

As a result of our improved operating

performance in 2025 and our ongoing

confidence in the Group’s strategy, the

Board is recommending a 2.6% increase

in the 2025 Final dividend to 28.05

pence per share, taking the 2025 Total

dividend to 55.40 pence per share.

At the end of 2026, our business will

have a higher OCG and IFRS adjusted

operating profit base and a higher quality

Solvency balance sheet. Importantly,

it will generate a healthy and growing

level of excess cash, improving both

our financial and strategic flexibility.

Dividend

Looking

ahead

28.05p

2025 Final dividend per share

+2.6%

2025 Final dividend increase

+3%

10-year Total dividend CAGR

47Standard Life plc Annual Report and Accounts 2025

Strategic report

Sustainability review

Sustainability

review

With our expertise as a retirement

specialist and as one of the UK’s

largest asset owners, we are uniquely

positioned to guide our customers’

retirement journeys and shape the

world they will retire into.

In this section, we provide an overview

of our progress on our sustainability

strategy and our future aims.

In this section

48 Sustainability review overview

49 2025 highlights

50 Our sustainability strategy

51 Introducing our new social target

52 Our Net Zero Transition Plan

53 Our climate and nature-related

financialdisclosures

Read more on pages 53–75

Responding to current

and upcoming regulation

We support the regulatory agenda for more

efficient,improved non-financial disclosures and

recognise the need for transparency about our

impactsand dependencies on people and the planet.

Wehave commenced preparatory work to meet

upcoming standards that will affect the Group

andourentities, including the UK Sustainability

ReportingStandards (‘SRS’).

Our reporting

You can find out more about our activities,

financial performance, sustainability strategy,

policies and detailed governance information

byvisiting our website:

www.standardlifeplc.com

Sustainability Report

This report covers our social and environmental

sustainability progress in the People and Planet

sections, including progress against our Net Zero

Transition Plan (‘NZTP’) and targets. Broader

disclosures including human rights and modern

slavery, Diversity, Equity and Inclusion (‘DEI’) and

a summary of Governance topics are included in

the Embed responsibility section.

ESG Data Appendix

Our Environmental, Social and Governance (‘ESG’)

Data Appendix summarises our ESG metrics and

Sustainability Accounting Standards Board

(‘SASB’)disclosures.

Net Zero Transition Plan

Our latest Net Zero Transition Plan details

our journey to net zero by 2050.

Standard Life has appointed KPMG to provide limited independent

assurance over selected disclosures within this report marked with ^.

Theassurance engagement was planned and performed in accordance

with the International Standard for Assurance Engagements (‘ISAE’) (UK)

3000 Revised, Assurance Engagements OtherThan Audits orReviews of

Historical Financial Information. A limited assurance opinion was issued

and isavailable in the ‘Independent Practitioner’s Limited Assurance

Report’ section on pages 2 and 3, which is available here.

48 Standard Life plc Annual Report and Accounts 2025

Strategic report

Partnerships

We took action to support working carers

through new partnerships with the Carers

Trust and Family Carers Ireland

c.2m

Our Sustainable Multi Asset default Workplace

solution has grown to £39 billion AUA, serving

c.2 million customers

>21m

In 2025 our customers accessed

ourindustry leading Standard Life app over

21 million times

93%

Our customer satisfaction score

for digital services across our

brands was 93%

£74bn

We have implemented decarbonising benchmarks

and strategies designed to manage climate risk

and opportunity across £74 billion AUA to date

58%

reduction in the emissions intensity of our listed

asset portfolio relative to a 2019 baseline, well

ahead of our target of a 25% reduction by 2025

81%

reduction and carbon neutral in our

operational Scope 1 and Scope 2 absolute

emissions (market-based) relative to a 2019

baseline, in line with a net zero trajectory

40.2%^

Our percentage of Senior

Leadershipthatare women

88%

Our combined Group customer

satisfaction score for telephone

Our colleague engagement employee

Net Promoter Score (‘eNPS’)

Campaign

We led an award-winning campaign

for

areview of pensions adequacy, which has

been adopted by the UK Government and

is set to report in 2027

2025 sustainability highlights

Embed responsibility

1. We aim to roll out decarbonising benchmarks and strategies across our listed asset portfolio (£153 billion AUA).

2. EVIC intensity metric (Scope 1 and 2). Where we exercise influence and control.

PlanetPeople

49Standard Life plc Annual Report and Accounts 2025

Strategic report

Sustainability review continued

Our sustainability strategy

Planet

Better futures

We want to play our part in delivering a net

zero economy and managing our impact

and dependency on nature, to help deliver

better outcomes for our customers and

shape the world they will retire into.

Our approach focuses on these areas:

Climate and nature action

People

Better journeys

We want to be the business that people

trust to guide their retirement journey,

helping our customers achieve better

outcomes and greater financial security

in later life.

Our approach focuses on these areas:

Sufficient savings, Secure retirement

Our sustainability strategy

Material sustainability topics

Embed responsibility

We are committed to embedding responsible and sustainable business practices

and maintaining high standards of oversight, integrity and ethics.

We want to ensure we are focusing our sustainability

strategy on the most significant issues.

Our sustainability strategy

Enhance

Transforming our

operating model

andculture.

Optimise

Optimising our scale

in-force business and

balance sheet.

Grow

Meeting more of our existing

customers’ needs and

acquiring new customers.

Read more about our strategic priorities on pages 28 to 35

Our strategic priorities

Read more in our Sustainability Report

See our Sustainability Report for a full list of our material topics and an explanation of our approach

We are committed to embedding sustainability throughout our business and

to ensuring we are focusing our sustainability strategy on the most significant

issues that could impact us and those on which we can have an impact too.

50 Standard Life plc Annual Report and Accounts 2025

Strategic report

People

Introducing our new social target

We champion the belief that everyone’s journey to and through retirement can

bebetter. That’swhy we have set a new target that provides a clear strategic focus,

reinforcing our commitment to prioritise the things which will drive meaningful change.

The retirement

problem we’re facing

In the UK today, too many people are not saving

enough for retirement, and too many don’t get

the support they need to feel confident making

decisions about using the money they’ve saved

in their pension. As a retirement specialist

focused entirely on retirement savings and

income, we can provide the right products

andsolutions at the right time, helping our

customers achieve better outcomes and

greaterfinancial security in later life.

we want to help three million

more customers by 2035, take

actiontowards a better retirement

Our target

How will we achieve our target?

We have set a new target to help three million more customers over the next ten years take actions towards

abetter retirement. We are doing this by empowering customers to engage with their financial futures,

transforming how they interact with long-term savings and supporting confident well-informed decisions.

How does our target work?

The target will track progress

over the next 10 years across two

customer outcomes that are critical

to achieving a better retirement:

• Increasing engagement in

planning for retirement

• Increasing the number of

customers who are supported

tomake better decisions when

accessing their pension

Over the decade, we aim for at

least three million customers

to see a genuine improvement

in these outcomes, not simply

measure the number we reach

or engage. This target will focus

on customers who are on their

journey to retirement and reaching

retirement over the next 10 years.

During 2026, as this is new

target, we will refine and test

our methodology and publish

it together with our first

progress update in next year’s

report. We will provide updates

on our target annually.

How we will drive progress

To achieve this, we have identified

the key activity within our enterprise

strategy that is driving a step change

in customers’ retirement outcomes,

and we will measure its impact over

time. We’ve used best practice to

design a theory of change that links

the outcomes we want to achieve

with the actions we are taking.

To drive increased engagement

weare creating personalised

andintuitive digital experiences,

running awareness raising campaigns

to encourage customers to take

action, enabling enhanced

communications and proactive

nudges. We offer tools that

buildfinancial engagement and

confidence, and are strengthening

long term outcomes by achieving

higher returns through our

investment design.

We will give our customers more

support when making decisions

by expanding access to affordable

advice and targeted support, and

provide clearer, more tailored

guidance at the key moments

when customers make decisions

about their pension. We will also

make retirement income work

harder with adaptable products.

As well as assessing the overall

outcomes for customers we will

measure the impact of these

underlying initiatives that will help

drive change and share our progress.

Read more about our social target and how our target is driving change in our Sustainability Report

51Standard Life plc Annual Report and Accounts 2025

Strategic report

Sustainability review continued

Planet

Our Net Zero Transition Plan

We have achieved our 2025 investment portfolio and operations

decarbonisation targets, and we are taking action at scale across

thebusiness towards our 2030 targets.

Where we

are now

58%

reduction in the carbon

intensity of our listed equity

and credit assets achieved

81%

reduction and carbon neutral

in our operational absolute

emissions achieved

What we want to

achieve by 2030

≥50%

reduction in the carbon

intensity of our investment

portfolio and supplier base

3,4

90%

reduction in our operational

Scope 1 and 2 absolute

emissions

What we want to

achieve by 2050

Net

zero

business across our

investments, operations

and supply chain

Our Transition Plan is an important step on our journey to net zero

Commitment

The fundamental drivers to act on climate change remain

as strong as ever and we remain committed to achieving

net zero by 2050 and shaping a world worth retiring into.

Value

We believe transitioning to net zero will support

better outcomes for our customers, the business and

society. The actions we take are designed to help our

customers achieve greater financial security in later life.

Progress

We have achieved our 2025 investment portfolio

decarbonisation target and carbon neutral operations

and are taking bold action at scale across the business.

Outlook

We believe we are likely to achieve our 2030 targets

under most scenarios, although we will become

increasingly dependent on action from others and

the global transition to net zero by 2050 is currently

off track. We are using our scale, expertise and

influence todrive meaningful system change.

Integration

We have started to integrate nature, just

transition and adaptation and resilience

considerations into our Net Zero Transition

Plan, in recognition of their fundamental

importance and interconnectedness.

Read more about how we are strengthening our approach

to risk assessment in our Sustainability Report

Read more in our Net Zero Transition Plan

1. EVIC intensity metric (Scope 1 and 2). Relative to a 2019 baseline, where we exercise influence

and control. Well ahead of our target of a 25% reduction by 2025. We note that the emissions

intensity of our portfolio could increase in the future if asset values fall.

2. Scope 1 and 2 (market-based). Relative to a 2019 baseline, in line with a net zero trajectory.

3. EVIC intensity metric (Scope 1 and 2). Relative to 2019 baseline, where we exercise influence and

control. Assets in scope include listed and private equity, credit assets and directly held real estate.

4. Scope 3 category 1 & 2 (location-based) emissions of our supplier base. Relative to a 2022 baseline.

52 Standard Life plc Annual Report and Accounts 2025

Strategic report

Our climate and nature-related financial disclosures

Our disclosures, indicated in the

table below, are aligned with the

recommendations of the Taskforce

on Climate-related Financial

Disclosures (‘TCFD’), in compliance

with the FCA Listing Rule 6.6.6R(8).

Pillar Recommended disclosures

Governance

Disclose the organisation’s governance of

climate and nature-related dependencies,

impacts, risks and opportunities

• Describe the board’s oversight of climate and nature-related

dependencies, impacts, risks and opportunities.

• Describe management’s role in assessing and managing climate

andnature-related dependencies, impacts, risks and opportunities.

• Describe the organisation’s human rights policies and engagement

activities, and oversight by the board and management, with

respect to Indigenous Peoples, Local Communities, affected and

other stakeholders, in the organisation’s assessment of, and

response to, climate and nature-related dependencies, impacts,

risks and opportunities.

Pages

54–55

Strategy

Disclose the effects of climate and

nature-related dependencies, impacts,

risks and opportunities on the

organisation’s business model, strategy

and financial planning where such

information is material.

• Describe the climate and nature-related dependencies, impacts,

risks and opportunities the organisation has identified over the

short, medium and long-term.

• Describe the effect of climate and nature-related dependencies,

impacts, risks and opportunities have had on the organisation’s

business model, value chain, strategy and financial planning,

aswellas any transition plans or analysis in place.

• Describe the resilience of the organisation’s strategy to climate and

nature-related risks and opportunities, taking into consideration

different scenarios.

• Disclose the locations of assets and/or activities in the organisation’s

direct operations and, where possible, upstream and downstream

value chain(s) that meet the criteria for priority locations.

Pages

56–62

Risk management

Describe the process used by the

organisation to identify, assess,

prioritiseand monitor climate

andnature-related dependencies,

impacts,risks and opportunities.

• Describe the organisation’s processes for identifying, assessing

andprioritising climate and nature-related dependencies,

impacts,risks and opportunities in its direct operations.

• Describe the organisation’s processes for identifying, assessing

andprioritising nature-related dependencies, impacts, risks and

opportunities in its upstream and downstream value chain(s).

• Describe the organisation’s processes for managing climate and

nature-related dependencies, impacts, risks and opportunities.

• Describe how processes for identifying, assessing, prioritising and

monitoring climate and nature-related risks are integrated into and

inform the organisation’s overall risk management processes.

Pages

63–64

Metrics and Targets

Disclose the metrics and targets used to

assess and manage relevant climate and

nature-related risks and opportunities

where such information is material.

• Disclose the metrics used by the organisation to assess and manage

material climate and nature-related risks and opportunities in line

with its strategy and risk management process.

• Disclose the metrics used by the organisation to assess and manage

dependencies and impacts on climate and nature.

• Describe the targets and goals used by the organisation to manage

climate and nature-related dependencies, impacts, risks and

opportunities and its performance against these.

Pages

65–75

Recognising the inherent interconnectedness between

climate change and nature loss, we have chosen to publish

integrated climate and nature-related financial disclosures.

We have also begun to disclose in

line with the recommendations of

the Taskforce on Nature-related

Financial Disclosures (‘TNFD’),

noting that our approach is less

mature than it is for climate and

this applies to these disclosures.

In response to FCA Listing Rule 6.6.12G,

we have also published a standalone Net

Zero Transition Plan which sets out our

approach to achieving net zero emissions

across our business (investment portfolio,

operations and supply chain) by 2050.

TCFD and TNFD compliance summary

53Standard Life plc Annual Report and Accounts 2025

Strategic report

Boards and Committees

Direct reporting Indirect reporting/engagement

Management committees

Standard Life plc Board

Sustainability review continued

Our climate and nature-related financial disclosures

Governance

Our Board has a robust governance structure in place to assist in

thedischarge of its responsibilities with respect to the oversight of

climate and nature-related risks through delegations within approved

Terms of Reference.

The Board’s oversight of climate

and nature-related dependencies,

impacts, risks and opportunities

The Board is responsible for the overall

strategy of the Group, including its

sustainability strategy. The Board

recognises that managing the impact

ofclimate and nature-related risks and

opportunities on the business is a

strategic priority. Sustainability-related

responsibilities are allocated to certain

committees depending on the

committee’s purpose and remit.

Board Committees with climate

and nature-related governance

responsibilities

The following Board Committees have

defined roles and responsibilities relating

to the management, oversight and

reporting of climate and nature-related

risk and opportunities. Cross-Committee

membership and engagement between

the Committees is key to driving consistency

with how matters are addressed across

the Group’s governanceframework.

• The Life Companies Board is

responsible for approving and

monitoring the overall Life Companies’

long-term strategy, including but not

limited to: investments, asset and

liability management, customers

(andvulnerable customers) and

conduct whilst ensuring that

customers’ interests are properly

balanced against those of its other

stakeholders to deliver fair outcomes.

• The Life Companies Board Investment

Committee oversees the overall

investment and asset liability strategies

on behalf of the Group’s Life Companies

and Phoenix Unit Trust Managers,

ensuring that customer interests

arebalanced with those ofother

stakeholders to ensure fair outcomes.

It oversees and recommends

GroupInvestment management

arrangements, within the Group,

andoversees these arrangements,

considering new asset classes as

andwhen appropriate.

• The Group Board Sustainability

Committee is responsible for

assistingthe Board in overseeing

theachievement of the Group’s

sustainability strategy.

• The Group Board Audit Committee is

responsible for reviewing data assured

by third parties in external reporting

including non-financial reporting and

external disclosures.

• The Group Board Risk Committee

isresponsible for overseeing the

identification, assessment, management

and reporting of risks (including climate

and nature-related risks) within the Group

Risk Management Framework (‘RMF’).

• The Group Audit, Risk and Sustainability

Committees held joint bi-annual

meetings in 2025 to ensure a more

harmonised and collaborative approach

in relation to sustainability reporting.

• The Group Board Remuneration

Committee is responsible for engaging

with the Board Sustainability

Committee to ensure that there are

appropriate environmental, social and

governance (‘ESG’) elements within the

Group remuneration framework.

* The individuals with SMF

responsibilities for managing

climate-related financial risk.

Audit

Committee

Risk

Committee

Sustainability

Committee

Nomination

Committee

Chief

Financial

Officer*

Life Companies Board

Investment Committee

Chief

Risk

Officer*

Remuneration

Committee

Asset Liability

Committee

Enterprise

Risk Committee

Enterprise

Sustainability

Committee

Enterprise Asset

Management

Committee

54 Standard Life plc Annual Report and Accounts 2025

Strategic report

The Group’s Chief Financial Officer (‘CFO’)

and the Group’s Chief Risk Officer (‘CRO’)

are both appointed as Senior Managers

responsible for climate-related financial

risk under the UK Prudential Regulation

Authority (‘PRA’)’s and Financial

Conduct Authority (‘FCA’)’s Senior

Managers and Certification Regime.

The Group CFO has responsibility for

ensuring the appropriate identification,

assessment, management and

reporting of climate-related financial

risks and opportunities that could

impact the Group. The Group CFO is

also responsible for reporting metrics

and targets and external disclosures.

The Group CRO has responsibility

forensuring that the Group’s RMF

appropriately supports the identification,

assessment, management and reporting

of the financial risks associated with

climate change that could impact the

firm. The Group CRO is also responsible

for the oversight of the identification,

assessment, management and reporting

of the financial risks associated with

climate change that could impact the

firmin line with the Group’s three lines

ofdefence.

Remuneration

Climate-related performance measures

form a component of the Group’s

Executive Directors’ variable pay and is

included in the Long-Term Incentive Plan.

See Directors’ Remuneration

reporton page 136 for more detail

Management-level forums

withclimate and nature-

relatedresponsibilities

Executive management is assisted

in making day-to-day decisions and/

or reporting to the Life Companies

and Group Boards and Committees on

climate and nature-related matters

by management-level governance

forums which do not have decision-

making authority within the business.

• Enterprise Sustainability Committee:

Provides holistic executive oversight of

the implementation and achievement

of the Group’s sustainability strategy

(including Planet, People and Embed

Responsibility priorities), driving

forward the Group’s agenda covering

the breadth of those priorities and

related initiatives. The Committee

supports the Board Sustainability

Committee, providing updates on

progress against strategy, business

plans and targets.

• Enterprise Asset Management

Committee: Provides holistic executive

direction and oversight of the Group’s

investment strategy (including the

strategic asset allocation framework and

the asset liability management strategy)

and asset management activities

undertaken for policyholder and

shareholder funds, ensuring alignment

with sustainability strategies and

relevant risk appetites. The Committee

provides a forum to support senior

management decision making by

reviewing and providing input to papers

going to the Life Companies Board

Investment Committee, including those

relating to sustainable investment

andstewardship.

• Asset Liability Committee: Provides

oversight and governance in relation

toall strategic balance sheet matters

including (but not limited to) financial

management, hedging and markets.

This includes the oversight of

relevantclimate and nature-related

financial risks.

• Enterprise Risk Management

Committee: Provides executive

oversight of risk management across

the Group, ensuring effective

implementation of the Group’s risk

framework and strategy. It monitors

material and emerging risks, including

climate and nature-related risks, to

confirm appropriate controls and

management actions are in place.

Key management forum climate

and nature-related activity

andoutcomes

The climate and nature-related activity

undertaken by our key management

forums support decision-making activity

and outcomes at Board-level committees.

Training activity provided to

management reflects training

provided to Board see page 133

Our policies and oversight of

human rights issues relating

toclimate and nature

Our Human Rights Policy aligns with the

United Nations Guiding Principles on

Business and Human Rights (‘UNGPs’)

and is approved by the Board. It is

a Group-wide policy and therefore

applies to our assessment of, and

response to, climate and nature-related

dependencies, impacts, risks and

opportunities. It is through this policy

that we ensure there is accountability

with respect to how the Group takes into

consideration the rights of indigenous

peoples, local communities and other

stakeholders through investments,

business operations and supplier base.

Group Board and Group Board

Committee climate and nature-

related activity and outcomes

For further details on the role of

each Group Board Committee and

key areas of focus and outcomes

ofmeetings see page 95

Training activity

For details of training provided

to the Board and Group Board

Committees on climate change

andnature see page 133

Board of Directors’ skills

andcompetencies

For details of the Board’s skills and

expertise, including relating to

sustainability see page 88–91

Management’s role in assessing

and managing climate and

nature-related dependencies,

impacts, risks and opportunities

Management oversight

Key individuals and Committees at

management level support the Board

with decisions relating to assessing

and managing climate and nature-

related risks and opportunities.

Individual accountability

The Group’s Chief Executive Officer

(‘CEO’) is responsible for the creation

and delivery of the entity strategy

and Strategic Financial Business Plan,

consistent with the strategy and

thresholds set by the Life Companies and

Group Boards, that reflects the needs

of shareholders, customers, employees,

regulators and other stakeholders.

As delegated by the CEO, the Director

of Corporate Affairs & Brand has

responsibility for defining, and

overseeing delivery of, the Group

sustainability strategy including the

Net Zero Transition Plan as agreed with

Group and Life Companies Boards, and

ensuring appropriate accountabilities,

risk and controls oversight, and decision

rights are in place to achieve business

sustainability strategy objectives.

55Standard Life plc Annual Report and Accounts 2025

Strategic report

Strategy

We identify and assess the impact of climate-related risks and

opportunities on our business, strategy and financial planning,

andwe are developing corresponding processes for nature.

As a long-term savings and retirement

business, our customers can beinvested

with us over many years to and through

retirement. As such, we recognise our

fiduciary duty to identify and manage

thepotential risks that may impact our

investments and operations over the

short-, medium- andlong-term. We also

seek to maximise the opportunities

presented by the transition to a net

zeroeconomy that could deliver

betteroutcomes for our customers

andshareholders.

We undertake quantitative and

qualitative analysis to identify and

assesshow climate-related risks and

opportunities could materially impact the

Group’s strategy and financial resilience

over the following time horizons:

Note: our climate risk analysis uses different time frames

fromthose used in financial reporting. Accordingly,

thereferences to short-, medium- and long-term here

arenot indicative of the meaning of similar terms used

inour other disclosures.

Sustainability review continued

Our climate and nature-related financial disclosures

Our Climate and Nature Action Model

Invest

Investing for

the future

Decarbonise our

portfolio; carry out

effective stewardship

of our assets; invest in

climate solutions; and

manage our impact and

dependency on nature.

Engage

Engaging to

multiply our impact

Work with industry

and government to drive

wider system change and

engage with customers

and colleagues on climate

and nature action.

Metrics and targets

Set clear targets for cutting emissions and publish transparent data on our performance against them.

See pages 65–75

Governance

See page 54–55

Risk Management

See page 63–64

Scenario analysis

See page 58–62

Lead

Leading by example

Reduce our direct

emissions and impact and

dependency on nature;

and reduce our wider

climate and nature impacts

by working collaboratively

with suppliers.

Our purpose

Helping people secure a life of possibilities

Our climate and nature ambition

We aim to tackle climate change and nature loss in support of delivering better outcomes for our customers

• Short-term: 0–1 year. This is

consistent with the liquidity monitoring

time horizon that we use for setting

capital requirements under Solvency UK.

• Medium-term: 1–5 years. This is

consistent with our financial planning

process which considers the medium-

term plans and strategy for the business.

• Long-term: over 5 years. This

captures the long-term nature of our

business and the risks that may emerge

beyond the financial planning process.

We continually seek to enhance our

approach, including strengthening how

we assess the resilience of our balance

sheet and strategic implications of climate

risk in light of Supervisory Statement

(‘SS’) 5/25.

Nature loss is identified as an

emerging risk for the Group due to

our potential exposure to financially

material nature-related risks in our

investments, operations and supplier

base. We have developed assessment

methods to begin to understand our

potential exposure to nature-related

dependencies, impacts, risks and

opportunities. We will continue to

enhance our approach as methodologies

evolve and data quality improves.

For more information on our

processes for identifying climate and

nature-related risks see page 63

56 Standard Life plc Annual Report and Accounts 2025

Strategic report

Summary of the effect on the organisation’s business model, valuechain,strategy and financial planning

The following table summarises the material climate and nature-related dependencies, risks and opportunities faced by the

businessover short-, medium- and longer-term time horizons, and the impact on our strategy. Our strategy for managing climate

andnature-related risks is comprised of three core pillars: Invest, Engage, Lead, as shown by our Climate and Nature Action Model

onpage 56. Our strategy is covered in more detail inourNet Zero Transition Plan and Sustainability Report.

Material

dependencies/ risks/

opportunities

identified

Relevant

strategy

pillar Potential impact of dependencies/risks/opportunities on our business, strategy and financial planning

Impact over

time horizon

Climate and

nature risk

exposures

within our

investment

portfolios

Invest/

Engage

Risk

• Investments in sectors or companies which do not effectively manage exposure to climate and nature-related

risks and dependencies lose value or are downgraded, resulting in losses.

• Increased frequency and/or severity of extreme weather events impact the value of physical assets or the

value of investee companies with high exposures to these risks.

• The systemic impacts of climate change and nature loss play out across the global economy leading to

widespread market losses and devaluations.

Opportunity

• Our custom Climate Aligned indices identify companies which are well prepared for the transition to a low

carbon economy and generate revenue from green business activities.

• Climate and nature-based solutions are potentially strong growth markets and may present investment

opportunities that deliver positive returns.

Short

Medium

Long

Changing

demand for

products,

fundsand

solutions

Invest/

Engage

Risk/dependency

• Loss of market share should our products be perceived as not meeting evolving customer needs orcustomer

preferences change entirely.

Opportunity

• Creating products that support growth in our Workplace business e.g. our Sustainable Multi Asset default.

• Engaging with existing customers to understand their preferences regarding climate change and nature.

Short

Medium

Long

Emerging

government

policy,

regulatory and

legal changes

Invest/

Engage/

Lead

Risk/dependency

• A breach of evolving legislative or regulatory requirements may expose us to litigation or regulatory sanction

and damage our brand.

• Governments and companies fail to act in line with net zero by 2050, impacting our ability to meet our 2030

and 2050 net zero targets and deliver better outcomes for our customers.

Opportunity

• Engaging with companies and governments to drive the transition to net zero by 2050 and achieve global

goals on halting and reversing nature loss can help support the business’s commercial objectives and deliver

better outcomes for our customers.

Short

Medium

Long

Reputational

damage if

climate and

nature risks are

not appropriately

managed

Invest/

Engage/

Lead

Risk

• Customers lose trust in the business and decide to leave, leading to loss of market share.

Opportunity

• Perception of good management of climate and nature risks in the market helps us retain and win new business.

Short

Medium

Disruptions

toour business

operations and

supply chain

Lead Risk/dependency

• High delivery costs of implementing decarbonisation solutions and reducing the impact of our premises on nature.

• Disruption to our suppliers from climate and nature-related impacts affect the services provided to the Group.

Opportunity

• Implementing and exploring decarbonisation and water usage solutions can reduce exposure to volatile

energy prices and lead to cost savings for the business.

Short

Medium

Long

integrate the management of nature-

related risks into existing organisational

frameworks and strategies, including the

Group’s RMF and responsible investment

strategy, as data and methodologies for

assessing and quantifying risks evolve.

Read more in our Net Zero

Transition Plan

Assets and/or activities in our direct

operations and value chain that meet

the criteria of priority locations

We do not currently have any direct

operations in priority locations exposed

to nature risk but recognise that we do

have exposure through our investment

portfolios and suppliers. Asset location

specific data that can link company and

issuer operations to principal impact

pressures and dependencies and in

turn changes in state of nature and

ecosystems service provision is critical

for identifying, monitoring and managing

nature-related risks and opportunities.

To meet this aim we are reviewing

asset location and geospatial data

providers that offer products which

would enable this analysis and we aim

to conclude this work in 2026. Wedo

assess our investment portfolio’s

exposure to climate physical risk using

asset location data. The results of

this work can be found on page 60.

See our Glossary on page 348 for

the definition of priority locations

and other key terms

Our strategic approach to

managing climate and nature-

related risks and opportunities

The management actions to

mitigate the Group’s exposure to

the identified material climate and

nature-related risks and to maximise

opportunities are set out on page 64

of the Risk management section.

Our Net Zero Transition Plan sets out

in detail the actions that the Group is

taking to manage climate risk and achieve

our net zero targets. We have begun

to integrate nature into our plan to

reflect the significant interdependencies

between climate and nature factors

and the important role of nature in

climate change mitigation, adaptation

and resilience. We will seek to further

57Standard Life plc Annual Report and Accounts 2025

Strategic report

Sustainability review continued

Our climate and nature-related financial disclosures

We use quantitative and qualitative

scenario analysis to model the impact

of different temperature pathways on

our business to gain insight into how

climate-related risks may materialise

over time. The output of this modelling,

alongside research and analysis, informs

our strategic response to transfer,

accept, control or mitigate our exposure

to the risk. We have developed a set of

metrics to help us measure, track and

manage the potential financial impact of

climate-related risks and opportunities.

These are set out in the Metrics and

targets section on pages 65 to 75.

Scenario analysis helps us to

assess the impact of the following

risks and opportunities that

were described on page 57:

• Climate risk exposures within

ourinvestment portfolios.

• Changing demand for products,

fundsand solutions.

• Emerging government policy,

regulation and legal changes.

• Reputational damage if climate

riskisnot appropriately managed.

• Disruption to our business

operationsand supplier base.

We are continuing to develop our

approach to assessing nature-related

risks and opportunities and to better

understand the implications for the

Group and its investment strategy.

Giventhe close interconnections

between climate change and nature

loss,in particular the role of stable and

healthy functioning ecosystems as carbon

sinks, we have started to explore the

potential integration of nature factors

within climate scenario analysis. While

very early stage, we will look to develop

our approach in alignment with best

practice market guidance as it evolves.

Scenario analysis use

acrosstheGroup

We continue to build on our progress

indeveloping our approach to climate

scenario analysis with a focus on

producing decision-useful outputs,

noting there remain material challenges

experienced across the industry. We use

climate-related scenario analysis to meet

different business needs across the Group:

• Stress testing our investment

portfolio: We use scenarios which

consider both transition and physical

risk to assess the potential quantitative

impacts on different assets classes,

model possible decarbonisation

pathways and support the design of

investment strategies and our

stewardship activities. Due to the

uncertain and long-term nature of

climate change, such modelling is

subject to a wide variety of limitations

(see page 62). Given the significant

limitations, qualitative judgement

isrequired to supplement the

quantitative analysis to improve the

robustness of the results and support

decision making.

• Own Risk and Solvency Assessment:

We use both quantitative and

qualitative scenario testing to assess

the potential financial implications of

different climate pathways on the

ongoing viability of the business and on

resilience of the balance sheet, and to

provide insight into risks associated

with the Group’s objectives.

• Business resilience: We stress test

theability of the Group to continue

tooperate under extreme weather

events such as heatwaves and floods.

During 2025 we performed a range

ofscenario analyses which considered

various climate pathways both

quantitatively and qualitatively.

External service providers are used in the

production of quantitative analysis. It is

important to note the modelled scenarios

represent a small set of possible climate

outcomes and there remain infinite

possible pathways that could emerge.

The analysis assumes a static asset

allocation throughout the projection

period 2025–2050 and does not take into

account actions to manage climate risk.

Scenario analysis

We assess the resilience of our strategy to climate-related risks and

opportunities, taking into consideration different climate-related

scenarios, across a range of temperature outcomes.

58 Standard Life plc Annual Report and Accounts 2025

Strategic report

Transition risk analysis

Three scenarios from the Network for

Greening the Financial System (‘NGFS’)

Phase V were chosen to represent a

range of climate outcomes with varying

pace of global transition to a low carbon

economy. These include: Net Zero 2050

– the transition starts immediately and

unfolds in an orderly fashion to achieve a

temperature rise of below 1.5°C by 2050;

Current Policies – globally misaligned

climate ambitions lead to emissions

growth causing irreversible climate

change; and Delayed Transition – policy

action is delayed and abrupt, leading

to higher transition risk impacts.

The analysis was performed on the

Group’s listed asset portfolio, testing

the impact across geographies,

sectors and holdings across individual

counterparties. We qualitatively interpret

and assess the risk that is evaluated

by the model’s quantitative output to

arrive at a risk label of ‘low’, ‘medium’

or ‘high’. The first phase of modelling

the impact to the investment portfolio

is ‘bottom-up’ quantitative analysis,

enabling the processing of complex

financial counterparty analysis in

response to changing climate-related

variables. However, we note the raw

model outputs as spuriously precise,

particularly given that certain risks such

as environmental tipping points are

not adequately captured. We therefore

interpret the model results with

reference to baskets of counterparties

we understand to have low, moderate

or high levels of climate-related risks

associated with them. This allows us to

calibrate the risk labelling and reflect our

judgement when considering results.

The scenario analysis results highlight

potentially material exposures to

transition risks across each of the three

scenarios (shown as medium or high risk),

indicating that the impacts of climate

change have the potential to materially

reduce investment returns and increase

volatility for customers and shareholders

if the Group does not continue to take

action to manage and mitigate the risk.

These actions include decarbonising our

investment portfolio, ensuring effective

stewardship of our assets and investing

in climate solutions. Further details of

the actions taken are outlined in the

Riskmanagement section on page 64.

The analysis also highlights that the

impact of climate risk on asset values

can differ significantly between regions,

sectors and individual counterparties

within each asset class for each scenario.

Regional deep dive

The chart below illustrates the impact

of the three climate scenarios on the

Group’s listed assets, with the greatest

impact seen in our Asia Pacific assets

under the Current Policies scenario. The

modelling assumes that due to slower

decarbonisation and resulting higher

warming in this scenario, investments

in the Asia Pacific region (and others)

become increasingly exposed to

higher physical risks, requiring more

adaptation actions to remain resilient.

This implies that mitigating actions

should consider our exposure to the

more highly impacted regions, and as

part of our engagement activities we are

incorporating consideration of physical

risks into the dialogue with companies.

However, given the known limitations

of model outputs, judgement should be

taken when interpreting the results.

In the Delayed Transition scenario, the

impacts of the slower pace of transition

aren’t fully captured until later in the

century, due to limitations of the scenario

timing, which leads to results which

look benign prior to 2050 and gives a

somewhat counterintuitive view that Net

Zero 2050 may have higher risk. However,

when the impacts do occur under the

Delayed Transition risk scenario (post

2050), they are likely to be more severe

as more rapid action is needed, and

compounded by increased physical risk

impacts resulting from higher warming.

This reiterates the importance of having a

strategy which aligns to net zero by 2050

to proactively manage transition risks.

Indicative impact from transition risk on the Group’s listed asset portfolio

byregion

Scenario

Asset value

Impact by region

Net Zero 2050 Delayed Transition Current Policies

2030 2040 2050 2030 2040 2050 2030 2040 2050

UK & Europe

North America

Asia Pacific

South America

Africa

Indicative impact

Low risk High risk

Medium risk

59Standard Life plc Annual Report and Accounts 2025

Strategic report

Sustainability review continued

Our climate and nature-related financial disclosures

Sectoral deep dive

The chart illustrates the impact of three

climate scenarios on a sample of sectors

within the Group’s listed asset portfolio.

The results show there are sectors

materially impacted by climate transition

risk, with energy and materials being the

most negatively impacted under faster

transitioning scenarios and the utilities

sector most positively impacted over

thelong-term – see page 67. Under

theCurrent Policies scenario, the energy

sector is less severely impacted, however

materials and consumer staples begin

tosee impacts from physical risks. This

implies that mitigating actions should

consider our exposure to high-impact

sectors under different scenarios, and as

part of our engagement activities we are

incorporating consideration of physical

risks into our dialogue with companies.

Given the known limitations of model

outputs, judgement should be taken

when interpreting the results. In addition,

individual counterparty analysis shows

To manage the transition risks

described in the analysis the Group

hasimplemented several management

actions. This includes introducing

decarbonising benchmarks that aim

to proactively identify and tilt towards

companies operating across all sectors

which are better placed to manage

the risks and opportunities from

the transition to net zero by 2050.

These use a range of forward-looking

metrics including projected carbon

performance, an assessment of the

quality of management of emissions

and an assessment of the management

of risk and opportunities related to

the low carbon transition. As part of

our stewardship activities we actively

engage with our investee companies on

transition risks and transition planning.

It is important to highlight that the

results of our transition risk scenario

analysis carry significant limitations

given that the scenario models used by

external providers do not adequately

capture physical risks, tipping points and

the cascading effect of these tipping

points. Across the Delayed Transition

and Current Policies scenarios we would

expect the impact on the investment

portfolio to be more material and

accelerated. As such, the following

physical risk scenario analysis was

performed to assess the impacts on

subsections of the investment portfolio.

Physical risk analysis

Analysis has been performed to assess the

potential physical risk to our real estate

portfolio from different climate scenarios

(on both directly held real estate assets

and real estate loans), usingS&P’s

Climanomics platform. Theplatform

makes use of four scenarios underpinned

by climate change projections used

by the Inter-governmental Panel on

Climate Change (‘IPCC’). These range

from a low emissions scenario with a

pathway to 1.5°C, to a high emissions

scenario with no changes to climate

policies leading to a greater than

4°C global mean temperature rise

(relative to pre-industrial levels).

The assessment measures the potential

future cost of a response to different

risk hazards over the short, medium

and long-term on our real estate assets.

The risks considered cover both chronic

and acute physical risks including the

impact of flooding (fluvial, pluvial

and coastal), temperature extremes,

drought, wildfire and tropical cyclones.

The impacts of these hazards can differ

according to the type of building at each

location. For example, there may be

increased future cost through clean-

up or repair, interruption to business

or increased cooling or heating costs.

awide level of variability in individual

assetreturns within sectors, of -100% up

to +750%. This highlights the importance

of not divesting from whole sectors and

looking through to individual holdings to

better understand potential climate

impacts within sectors.

As noted in the regional deep dive,

theimpacts under a Delayed Transition

scenario aren’t fully captured until later

inthe century and we would expect these

to become more severe as more rapid

action is needed and the impacts from

physical risk increase. As high emitting

sectors, the energy and materials sectors

will likely be materially impacted by a

delayed transition due to rapidly shifting

consumer demand and carbon pricing

which occur at a later point than in the

Net Zero 2050 scenario. This reiterates

the importance of having a strategy

which aligns to net zero to proactively

manage transition risks.

Indicative impact from transition risk on the Group’s listed assets by sector

Scenario

Asset value

impact by sector

Net Zero 2050 Delayed Transition Current Policies

2030 2040 2050 2030 2040 2050 2030 2040 2050

Energy

Industrials

Materials

Utilities

Real Estate

Consumer Staples

Low risk

High risk

Medium risk

60 Standard Life plc Annual Report and Accounts 2025

Strategic report

Estimated cost from physical risk on directly held corporate real estate assets

Scenario

Low to high

physical risk

Estimated cost from physical

risk in each decade

2030 2040 2050

Low (RCP 2.6)

Medium (RCP 4.5)

Medium-High (RCP 7.0)

High (RCP 8.5)

Estimated cost

Lower Higher

Medium Highest

Representative Concentration Pathways (‘RCP’s) are trajectories of greenhouse gas concentrations

used for climate modelling in the IPCC Fifth Assessment Report (2013).

Estimated cost from physical risk on corporate real estate loans

Scenario

Low to high

physical risk

Estimated cost from physical

risk in each decade

2030 2040 2050

Low (RCP 2.6)

Medium (RCP 4.5)

Medium-High (RCP 7.0)

High (RCP 8.5)

Estimated cost

Lower Higher

Medium Highest

The potential future costs calculated

are the cumulative cost in each decade,

i.e. 10 years of aggregated costs, as a

percentage of current asset value.

The results below show the aggregated

impact across £3.4 billion of directly

held real estate and £1.2 billion of real

estate loans under the four scenarios

in each decade from 2030 through to

2050. The results for the real estate

loans portfolio reflect our participation

in the financing of the underlying

properties and capture our attributed

share of emissions, which will typically

be a smaller percentage than directly

held assets. As such the scale of possible

future costs for real estate loans is lower

than the directly held real estate assets.

The overall results indicate there is an

increasing relationship between the

cost and severity of risk factors over

time. In later decades, physical risks are

more severe than historic levels which

increases potential future costs. Similarly,

in higher emissions scenarios physical

risks further increase in severity leading

to potentially higher future costs.

We continue to enhance our approach

for assessing the potential physical

risk impacts to other parts of our

portfolio such as listed equity and

credit. Our initial assessment utilised

the S&P Capital IQ Pro platform

and highlighted the following:

• At an aggregate level the listed equity

portfolio exhibits median scoring for

physical risks relative to the investment

universe which S&P has assessed for

physical risk impacts. Scoring increases

in the latter half of the century and the

highest warming scenarios. Listed

credit (noting a lower level of coverage)

is less impacted with scores remaining

below median levels.

• Listed equity at an aggregate level

exhibits higher scoring for three main

hazards: pluvial flooding, extreme heat

and water stress. However, scores for

these hazards do remain below median

levels, even in higher warming

scenarios. Extreme heat is an exception

to this, which scores slightly above

median level in the latter half of the

century in the high warming scenario.

• Listed credit scores at hazard level are

well below median in all scenarios,

although extreme heat and water

stress score highest.

• Analysis for both listed equity and

credit at investee company level for

material positions, suggests some

individual companies may have

particularly high scores to certain

hazards, typically those which are

related to extreme heat, water stress

and wildfire, or fluvial, pluvial and

coastal flooding.

We plan to further enhance this analysis

during 2026 and beyond. In particular,

we note that further work is needed

to understand the impact of physical

risk at the asset level to inform the

management actions required to improve

resilience and reduce risk exposure.

Qualitative scenarios

As part of the ORSA process qualitative

scenarios are used to assess the

impact of risk events that are not

easily quantifiable through financial

modelling. Scenarios were selected,

having considered the Group’s top

risks, market trends and emerging risks.

This includes a climate risk scenario:

• This qualitative scenario considered a

halt in global transition activity driven

by political headwinds. Investment in

carbon intensive industries increases

and returns associated with ‘green’

companies reduce. This is assumed to

drive a reduction in demand for

investments labelled as sustainable.

• The scenario determined that such an

event could drive a mass lapse in our

flagship sustainable workplace default

funds, potentially requiring customer

remediation activity if they did not fully

understand how their assets were

being invested, with accompanying

reputational damage.

• It was concluded that there were no

actions to be taken due to confidence

that there is sufficient customer

messaging in place to provide

information on funds and fund

labelling. It was also felt that

customers had the option to switch

easily and there is active engagement

with the governance bodies overseeing

the contract-based workplace schemes

and members of our Master Trusts

(Standard Life Master Trust Committee).

61Standard Life plc Annual Report and Accounts 2025

Strategic report

Sustainability review continued

Our climate and nature-related financial disclosures

Limitations and dependencies in

scenarios andmodelling

We are conscious of the limitations related

to scenario analysis and we take these

limitations into account when assessing

the implications of scenario analysis for

the business and management actions

needed. We will continue to ensure that

actions taken to manage climate risk are

implemented at the appropriate pace and

support the delivery of better outcomes

for our customers and shareholders.

Scenarios

• How climate risk will emerge, the

speed at which it will emerge, and

when it will emerge are all highly

uncertain. Only a subset of possible

climate outcomes have been assessed

and we acknowledge an infinite range

of possible climate pathways could

emerge, each of which could impact

the Group’s business model, balance

sheet resilience and our customers in

arange of ways.

• There are limitations to how physical

risks are captured within quantitative

modelling, particularly relating to the

impacts of tipping points and the

systemic effects of climate risk events

on the wider economy.

• The scenarios used are not considered

to be upper or lower limits for potential

climate outcomes and impacts could

befar in excess of those estimated.

Impacts

• The impacts of the climate scenarios on

our investment holdings do not account

for potential further abatement and

adaptation actions that companies and

governments may take as the scenarios

unfold. If and how these actions

emerge are highly uncertain so there

may be additional impact to that which

is included in modelling currently.

• The impacts of the scenarios are highly

sensitive to the underlying assumptions,

including the future trajectory of carbon

prices which are inherently uncertain.

Data

• The Group has sourced scenario data

from a leading data provider, however

data is currently more readily available

for investments in listed counterparties

than in private markets.

• Data coverage in the climate models

used for scenario analysis currently

stands at 80% of our listed equity and

credit portfolio where we exercise

influence and control. Our ability

toincrease the coverage further is

limited by the granularity and

functionality of data providers.

Other limitations

• Asset modelling assumes the asset mix

of the Group remains constant

throughout the projection period.

• The modelling does not account for

possible management actions that may

be taken to decarbonise the portfolio.

Conclusions and next steps

The results of the scenario analysis

performed this year were not deemed

to significantly threaten the strategic

objectives of the Group. However, the

medium to highest risk labels do indicate

that climate change has the potential to

materially reduce investment returns in

certain sectors and increase volatility for

customers and shareholders over time,

if the Group does not continue to take

action to manage and mitigate the risk.

We fundamentally believe that an

orderly transition to net zero will lead

to better outcomes for our customers

and shareholders, in particular because

current models underplay the potential

impacts of physical risk under scenarios

that lead to a higher temperature

outcome. Our Net Zero Transition Plan

sets out our approach to achieving

net zero by 2050 in support of good

customer outcomes in more detail.

In certain asset classes we have levels of

flexibility as to how and where to invest

and could, theoretically, decarbonise

certain parts of our investment portfolio

in a short period. However, we recognise

that narrowing the investable universe

in this way is unlikely to be aligned with

delivering better outcomes for our

customer and managing other risks

(such as concentration risk), and nor

would it necessarily contribute to real

economy decarbonisation. The Group

will continue to assess the impact of

possible climate pathways. This will

help inform the appropriate pace of

actions taken in managing climate risks,

in particular if the global transition

deviates from a net zero 2050 pathway.

Climate stress and scenario testing

will continue to be developed and

performed to identify and manage

further potential exposures and

possible mitigating actions.

Given the uncertainty with the

materialisation of physical risks and

modelling limitations, the Group

continues to work through its climate

physical risk roadmap to better identify

and understand the impact of physical

risks (flooding, subsidence, sea level

rise, wildfire, etc.) on our investment

portfolio in order of materiality. As part

of this roadmap, we plan to explore

extending our physical risk analysis

to other asset classes, such as illiquid

credit, and explore the integration of

nature factors. We will also review data

providers to seek enhancements to

the physical risk data points within the

scenario modelling, while continuing to

build on our own qualitative judgements.

62 Standard Life plc Annual Report and Accounts 2025

Strategic report

Our processes for identifying,

assessing, and managing climate-

related risks are integrated into the

organisation’s overall Risk Management

Framework (‘RMF’). Nature risk is

identified as an merging risk and we

have developed an initial approach.

The Group’s understanding of

climate-related risks has deepened as

regulatory expectations, stakeholder

priorities and scientific understanding

evolves. In particular, the release

of SS5/25 has raised regulatory

expectations, prompting the Group

to further strengthen its approach.

As part of this evolution, we are

considering the interdependencies

between climate and nature-related

risks to ensure that components of the

framework are adapted to maintain

resilience against these interconnected

and emerging challenges.

Identifying and assessing

climate-related risks

The identification of climate-related

risks has been embedded into the

components of the RMF which

support the identification of risks

both quantitatively and qualitatively,

and from top-down and bottom-up

perspectives. The materiality of climate

risks is assessed on an ongoing basis, and

differs between business areas. Individual

areas ensure their strategies suitably

consider climate risk, proportionately

to the materiality of other risks they

face. This informs how and when climate

risk-driven decisions are taken over time.

We use the following tools, which have

a combination of internal and external

inputs, to understand our climate risk

exposures and assess materiality:

• Annual stress and scenario

testingprogramme

• Carbon footprinting exercises

forourassets and operations

• Horizon scanning

• Monitoring and reporting

progressagainst climate risk

metricsand targets

Identifying and assessing

nature-related risks

Nature loss is identified as an emerging

risk for the Group due to our potential

exposure to nature-related risks through

our investments, operations and supplier

base – see emerging risks on page 83.

We have developed an initial approach

which is aligned with the TNFD’s Locate,

Evaluate, Assess, Prepare to act (‘LEAP’)

framework, expanded with an initial

evaluation step. This has enabled us to

begin to identify and assess potential

nature-related dependencies, impacts,

risks and opportunities in our investment

portfolio and supplier base. Our nature

risk assessments for our investment

portfolio and supplier base are covered

in more detail in the Metrics and

targets section on pages 65 to 75.

Our processes for managing

climate and nature-related

impacts, dependencies,

risksandopportunities

The Group has embedded the management

of climate risks across the business and

isbuilding its capabilities to manage

nature-related risks.

Risk management

Our processes for managing climate and nature-related

dependencies, impacts, risks and opportunities continue to evolve.

63Standard Life plc Annual Report and Accounts 2025

Strategic report

Sustainability review continued

Our climate and nature-related financial disclosures

The management actions the Group is taking to address the material climate and emerging nature-related risks identified on page57

are set out in the table below. Our Net Zero Transition Plan sets our further information on the actions we will take toreduce our

exposure to climate risk and support the transition to net zero by 2050.

Material risks Mitigating actions

Climate and nature

risk exposures

within our

investment

portfolios

• We use scenario analysis to stress test our investment portfolio against a range of scenarios. This helps inform our actions to manage

our exposure to climate transition and physical risks. See pages 58–62 for outputs of our scenario analysis.

• We are adopting decarbonisation strategies (including through the use of our custom climate indices) across our listed equity and

credit portfolios.

• Our ESG integration framework for illiquid credit integrates both climate and nature-related factors. We aim to further integrate

nature factors into credit origination and credit portfolio monitoring for in-house asset management teams.

• We are running a multi-year engagement programme with high emitting companies on climate change. We have also begun to include

nature-related factors into our corporate research to encourage companies to measure and manage their dependencies and impacts

on nature.

• We engage with our asset management partners, seeking alignment with our objectives on climate change and nature.

• We aim to scale up our investment in line with our ambition to invest up to £40 billion in sustainable, transition or UK-focused

productive assets, including climate solutions and nature-related investment opportunities, in line with delivering better outcomes

for our customer and our fiduciary duty.

• Our Exclusions Policy sets out our thresholds for excluding investment in companies whose business practices are not aligned with our

standards. We have completed initial research to identify potential new exclusions linked to high nature impact, where this aligns with

better outcomes for our customers and shareholders.

Changing demand

for products, funds

and solutions

• We engage with our customers to understand their changing needs and preferences and to help them understand the impact of their

investments. This includes preferences relating to addressing climate change and nature loss.

• We are focused on growing customers’ money while reducing their exposure to climate risk. We do this through products such as our

Sustainable Multi Asset default Workplace solution and other sustainable investment options.

Emerging

government policy,

regulatory and

legalchanges

• We engage with decision makers, collaborate with peers and deliver thought leadership to overcome barriers and play our part in

addressing systemic climate risk. This also informs our own decision-making and management of climate risks. We will broaden the

scope of our thought leadership and policy engagement to include nature over time.

Reputational

damage if climate

and nature risks are

not appropriately

managed

• We ensure the implementation and reporting of risk management controls, including anti-greenwashing, across the business.

• We conduct ongoing horizon scanning and reporting of Management Information on climate and nature-related topics to the Board.

Disruptions to our

business operations

and supply chain

• We are decarbonising our own operations to mitigate our exposure to climate risk and considering opportunities to reduce our water

consumption and improve biodiversity across our sites.

• We assess the business’ resilience to physical climate risk on an ongoing basis to ensure that the Group can continue to operate under

extreme weather events.

• We have conducted an initial assessment of the Group’s supplier base to identify exposure to nature-related impacts and dependencies.

• We have a supplier risk management and oversight process in place. Suppliers must be able to demonstrate that they operate/provide

services that satisfy the Group’s risk appetite to be onboarded and must continue to demonstrate this on an ongoing basis.

Our risk policies and capital

Risk policies are in place to cover key

sources of climate and sustainability risk

across the business. Sustainability-

related enhancements have also been

made to the suite of quantitative and

qualitative tolerances and triggers which

support the monitoring of risk appetites.

Specific capital is not currently

held for climate risk; however, the

appropriateness of capital is assessed

through scenario analysis (see page58).

In addition, the Group’s Internal Model

Governance Policy requires explicit

consideration of climate-related

risks when developing and reviewing

Solvency UK methodology and

assumptions. This approach to capital

will continue to evolve as internal

and industry practices mature.

For more information on the

Group’sRisk Management

Framework see pages 78–83

Limitations and dependencies

The Group recognises several limitations

when using current tools and data to

identify, assess and manage climate

and nature-related risks, such as:

• Data quality

• Data coverage

• Sophistication of models for scenario

analysis and modelled climate and

nature outputs

• Methodology differences across

different data sources and tools

• Evolving regulatory landscape

We will continue to enhance our

approach as the quality of tools

and data improves to better inform

decisions relating to risk management.

Responding to developing regulation

and reporting requirements

The Group continues to evaluate the

evolving regulatory landscape and how

this will impact ongoing climate and

nature risk assessment and reporting,

including the implications of Supervisory

Statement SS5/25 and UK Sustainability

Reporting Standards (‘SRS’).

The Group continues to develop its

internal climate risk reporting to

reflect the evolution of market best

practice and to enable effective

management of climate risk.

64 Standard Life plc Annual Report and Accounts 2025

Strategic report

Our investment portfolio

Investment portfolio

targetsframework

We believe science-based targets are

essential to help us reduce our emissions

in line with a credible pathway to net

zeroby 2050. Our targets are aligned

with the target-setting protocol

developed by the Net-Zero Asset Owner

Alliance. We do not use carbon offset

credits to achieve our investment

portfolio decarbonisation targets.

We will continue to monitor the

development of nature-related target-

setting frameworks and seek to develop

our approach as best practice evolves.

Investment metrics framework

We use the financed emissions

methodologies developed by the

Partnership for Carbon Accounting

Financials (‘PCAF’) insofar as possible.

Our 2025 position reflects asset

values as at YE2025, and carbon

emissions largely from calendar

year 2024 (the latest year for which

emissions data is readily available).

Our primary metric to analyse our

investment portfolio emissions is economic

emissions intensity, which is used as the

basis for our externally reported

investment portfolio targets. To support

the interpretation of this metric, we also

disclose data quality scores and data

coverage at an asset class level. In addition,

we have a suite of investment metrics

which helps us to better understand

ourexposure to transition risk, and to

determine how aligned our investment

portfolio is to net zero by 2050.

Investment portfolio decarbonisation targets

1. Our investment portfolio decarbonisation targets relate

tothe Scope 1 and 2 emissions of our investee companies

relative to a 2019 baseline. Targets apply to our investment

portfolio where we have control and influence.

Seeglossary for definition of control and influence.

2. Sovereign debt is no longer in scope of this target due

to a change in methodology in line with best practice.

The development of metrics to measure

our exposure to key nature-related risks

and opportunities is ongoing and will

evolve as data quality and availability

improves. We have completed an initial

exploratory assessment of listed equity

and listed credit portfolios based on

metrics that are supported by currently

available data. The metrics selected are

broadly aligned with TNFD assessment

metric guidance where possible and

support the articulation of how nature

factors are being integrated within the

Group’s responsible investment strategy.

Key progress in 2025

• Achieved our 2025 target to reduce the

carbon intensity of our listed equity and

credit portfolio (where we have control

and influence) by 25%. We have

observed a 58% reduction in the carbon

intensity of our listed equity and credit

portfolio relative to our 2019 baseline.

• Reviewed and refined our 2030 target

in the context of global

decarbonisation progress, evolution

oftarget-setting guidance and our peer

landscape. Our 2030 target maintains

the 50% reduction in economic

emissions intensity (versus our 2019

baseline year) of assets over which

wecan exercise control and influence,

but this target now applies specifically

to listed and private equity, credit

assets and directly held real estate

• Experienced a 42% reduction in

absolute emissions across our

investment portfolio relative to the

baseline, from 24.6 MtCO

e (YE2019)

to14.3 MtCO

e^ (YE2025).

• Enhanced our reporting of Scope 3

emissions from companies in our listed

asset portfolio. The Scope 3 emissions

of companies in our listed asset

portfolio is 99 MtCO

e at YE2025

(vs97MtCO

e at YE2024), 78% of

whichis from four sectors: industrials,

energy, financials and materials.

• Assessed our listed equity and

listedcredit portfolio’s potential

exposure to potential nature-related

impacts and dependencies.

Measuring our carbon

footprintbaseline

We have selected YE2019 as our baseline

position against which we measure

progress. As a pre-COVID-19 pandemic

year this reflects a more comparable level

of global economic activity emissions.

We have developed internal re-baselining

guidelines which articulate trigger points

for recalculating the carbon footprint

baseline of our portfolio. Possible factors

that could drive a re-baseline include

(but are not limited to): material changes

in our asset values due to business

acquisition or disposal, material changes

in our carbon footprint methodology,

changes in data vendors which drive

material corrections in prior years, or a

restatement of financials in our external

reporting which has a material impact on

our asset portfolio. Our primary source

of counterparty carbon emissions data

is Institutional Shareholder Services

(‘ISS’), an established sustainability data

vendor. Our analysis captures the Scope

1 and Scope 2 emissions of our investee

companies, and we have separately

conducted analysis to consider the Scope

3 emissions of our investee companies.

Metrics and targets

Our metrics and targets help us assess and manage our climate

andnature-related dependencies, impacts, risks and opportunities.

2025

25%

reduction in the carbon

intensity of our listed

equityandcredit portfolio

(58%reduction achieved)

2030

≥50%

reduction in the

carbonintensityof our

investmentportfolio

1,2

2050

Net

zero

across our investment portfolio

65Standard Life plc Annual Report and Accounts 2025

Strategic report

2019

24.6

20.8

18.1

13.4

14.3^

-42%

+7%

20232021 2024 2025

Real estate

Illiquid credit

Equity release mortgages

Listed credit

Listed equity

Sovereign debt

MtCO

250

200

150

100

tCO

e/£m

2024

2025

2019

2021

2023

Listed

credit

Listed

equity and

credit (scope

of 2025 target)*

Listed

equity

Sovereign

debt

Real

estate

Illiquid

credit

Equity

release

mortgages

Alternatives

All assets

within

control and

influence

105

-58%

-16%

44^

67^

Sustainability review continued

Our climate and nature-related financial disclosures

Our carbon footprinting results

captureall assets within our control and

influence, including assets supporting

annuity, with-profits and unit-linked

products. The total AUA (YE2025)

covered in our carbon footprinting results

is £218 billion, which is 69% of our total

AUA and covers 100% of assets in scope

of our 2030 target – see note 2 on page 65.

The table shows asset classes covered

by our carbon footprinting results.

Analysing our investment

portfolio emissions

Absolute emissions

We have experienced a 42% reduction

in total absolute emissions relative

to the baseline, from 24.6 MtCO

(YE2019) to 14.3 MtCO

e^ (YE2025).

Thereduction in absolute emissions

for our investment portfolio is driven

by both decarbonisation activity

undertaken by our investee companies

and a result of investment allocation

changes from the introduction of

decarbonising benchmarks in our

equity portfolio. This is partly offset by

an increase in the AUA in scope of our

carbon footprinting exercise over time.

We have experienced an 7% increase

in total absolute emissions across the

investment portfolio in 2025, from

13.4MtCO

e (YE2024)

to 14.3 MtCO

(YE2025). This is primarily driven by an

increase in sovereign debt AUA and

an improvement in our methodology

which now uses reported and verified

emissions data from the United Nations

Convention on Climate Change, rather

than reported but unverified emissions

data. The absolute emissions profile

of our baselined investment portfolio

is primarily driven by sovereign debt

(51%), listed equity (34%) and listed

credit (11%). Other asset classes that

we have footprinted (illiquid credit, real

estate, equity release mortgages and

alternatives) collectively make up less

than 4% of our absolute emissions.

Emissions intensity

Economic emissions intensity is an

important measure for portfolio investors

as this enables comparison between

portfolios of different sizes and between

different time periods. We observe a

16% reduction in the economic emissions

intensity of our listed asset portfolio

between YE2024

and YE2025, which

brings the total reduction observed since

the baseline YE2019 position to 58%.

We have therefore achieved our 2025

target to reduce the carbon intensity

of our listed equity and credit portfolio

(where we have control and influence)

by 25%, relative to our 2019 baseline.

2. As part of our commitment to improving our carbon footprinting process, we show updated YE24 numbers to reflect

anenhancement in listed asset data coverage that was delivered after publication of our Group Annual Report and

Accounts 2024. The restatement only impacts YE24 numbers, not the 2019 baseline. The assured metrics impacted are:

absolute emissions of the investment portfolio, increasing from 12.4 MtCO

e to 13.4 MtCO

e, driven by absolute emissions

of listed equity increasing from 4.3 MtCO

e to 4.7 MtCO

e and listed credit increasing from 1.5 MtCO

e to 2.0 MtCO

Economic emissions intensity of the assets in scope of 2030 target increased from 72 tCO

e/£m to 73 tCO

e/£m, driven

by listed equity and credit increasing from 51 tCO

e/£ to 52 tCO

e/£m (due to listed equity increasing from 47 tCO

e/£m

to 49 tCO

e/£m).

Due to the time lag in sourcing climate data, prior disclosures reported investment portfolio GHG emissions from earlier

financial periods. Since the YE2023 reporting cycle, our reporting capability was upgraded to enable portfolio emissions

disclosures to relate to the latest financial year. The result is that there has been no reporting against YE2020 and YE2022.

* Achieved our target of a 25% reduction from 2019 baseline.

Absolute emissions (Scope 3, Category 15 – emissions from investment)

for all assets in carbon emissions baseline

Economic emissions intensity (EVIC) of all assets within

our control and influence

Coverage of carbon footprint analysis by asset class

Asset class

AUA as at YE25

(£bn)

Included in carbon

footprinting results

Listed equity and credit 153

Sovereign debt 42

Real estate 5

Illiquid credit 9

Equity release mortgages 5

Alternatives 3

Currently not

included in carbon

footprinting results

Collectives outside of influence and control 68

Other

Cash 9

Total 317

1. Includes off-balance sheet AUA, assets held in Wrap Self-Invested Personal Pension products, and onshore bond

products, enabling a reconciliation to the Group AUA of £317bn.

66 Standard Life plc Annual Report and Accounts 2025

Strategic report

2019 20232021 2024

2025

Industrials

Other

Energy

Utilities

Materials

100

28%

25%

22%

13%

24%

22%

27%

12%

18%

Industrials

Energy

Financials

Materials

Other

2024 2025

21%

11%

22%

21%

10%

29%

31%

15%

27%

13%

100

The reduction in economic emissions

intensity of our listed asset portfolio

between YE2024 and YE2025 is largely

driven by an increase in the Enterprise

Value Including Cash (‘EVIC’) component

of the intensity calculation, which is a

measure of a company’s capital base.

An increase in company value since

YE2024 is in line with expectations given

market performance over this period.

We recognise that our economic emissions

intensity metric can change year-on-year

due to changes in asset values, volatility

inthe EVIC component of the calculation,

and evolution of methodology and process.

We are therefore prudent in the inference

that we draw from the reduction in

economic emissions intensity achieved

todate and recognise that the economic

emissions intensity of our investment

portfolio could increase in future if asset

values fall. We will continue to explore ways

to improve our understanding of drivers of

change and enhance our attribution

analysis to support increased transparency.

We also calculate emissions intensity

on a revenue basis for our listed asset

portfolio in line with TCFD guidance.

Revenue emissions intensity provides

insight into a company’s carbon efficiency

per dollar of revenue earned and is a

particularly useful metric for comparing

companies within sectors. We observe

a 17% reduction in revenue emissions

intensity for listed credit from YE2019 to

YE2025, and a 38% reduction for listed

equity over the same period. Revenue

emissions intensity remained broadly

unchanged between YE2024 and YE2025.

Sector exposure as % of listed asset absolute emissions (Scope 1 & 2)Scope 3 absolute emissions

ofinvestee companies in

ourlisted asset portfolio

splitby sector

Analysis of the Scope 3 emissions

ofinvestee companies

We believe that considering the Scope

3 emissions of our investee companies

enables a more complete view of

the carbon profile of our investment

portfolio. We use ISS as our primary

source of Scope 3 emissions data.

Our share of the Scope 3 absolute

emissions of all investee companies in

our listed asset portfolio has increased

from 97 MtCO

e at YE2024 to 99

MtCO

e at YE2025, based on reported

numbers (where available) and estimated

data. This is due to improvements in

the transparent reporting of Scope

3 emissions by investee companies,

and enhancements in the capabilities

of our data vendors to estimate

Scope 3 emissions data where it is not

reported. This far exceeds the financed

emissions for which we are responsible

under Scope 1 and 2, since Scope 3

emissions capture the upstream and

downstream activities of the company.

The majority of our share of the Scope

3 absolute emissions of investee

companies in our listed asset portfolio

at YE2025 is from investee companies

in four sectors (industrials, energy,

financials and materials), which is

broadly unchanged from YE2024. While

methodologies continue to improve, we

recognise that there are still significant

limitations to Scope 3 emissions data,

which is dependent on high-quality

and transparent reporting by investee

companies. We will continue to engage

with our data vendors to enhance Scope

3 estimation methodologies where

investee company reporting gaps remain.

Understanding our

exposuretoclimate risk

Our exposure to high

transitionrisksectors

We identify four industry sectors as being

particularly vulnerable or susceptible to

transition risks due to policy, technology

or market changes – energy, utilities,

materials and industrials. 24% of our

listed asset portfolio (by AUA) is invested

in these high transition risk sectors, and

collectively they account for 88% of listed

asset portfolio emissions. As shown in

the chart the sector exposure is broadly

comparable with the YE2024 position,

indicating that the high transition risk

sectors we have identified continue

to be responsible for a significant

proportion of our portfolio emissions.

In addition to our analysis of high

transition risk sectors, we have applied

a screen to our listed asset portfolio

to identify investee companies which

generate greater than 20% of their

revenues from the fossil fuel value

chain, including production, exploration,

distribution and services. The proportion

of our listed asset portfolio exposed to

the fossil fuel industry has decreased

from 9% at YE2024 to 7% at YE2025.

Analysis of our top 10

emittingcounterparties

The profile of our listed asset portfolio’s

top-10 emitting counterparties is similar

between YE2024 and YE2025. They make

up 3% of listed asset AUA but 33% of

listed asset absolute emissions. Two of

our top-10 emitting investee companies

have approved science-based targets.

67Standard Life plc Annual Report and Accounts 2025

Strategic report

Sustainability review continued

Our climate and nature-related financial disclosures

Our exposure to physical risk

While our current analysis indicates

we are more materially exposed

to transition risk in our investment

portfolio, we do have exposure to

sectors and geographies which are

materially susceptible to physical

risk. We have conducted analysis to

assess potential physical risk within

our real estate portfolio, using the

S&P Climanomics platform – see

page 60 for more information.

Measuring the alignment

ofourinvestment portfolio

tonetzero by 2050

We measure the ‘climate alignment’

of our investment portfolio to track

whether it is aligning with net zero by

2050, and to support our engagement

with investees on their net zero targets

and transition plans. As at YE2025,

53% of our listed asset portfolio is

invested in counterparties that have

committed to set or already set approved

science-based targets (based on their

affiliation with the Science Based

Targets initiative (‘SBTi’)). This figure

is broadly unchanged from YE2024.

While evaluating an investee company

based on whether it has affiliated itself

with the SBTi gives a useful sense of

alignment to net zero by 2050, it is one

of several metrics that could be used.

We recognise that SBTi may not be an

appropriate methodology to follow

for some companies in some sectors,

particularly where a standardised

methodology may not provide the

flexibility required. We continue to

develop our suite of forward-looking

climate investment risk metrics to form

a more detailed picture of net zero

alignment across the investment portfolio.

Limitations

Change in data coverage

Our data coverage metric represents

the proportion of our investments

that we have been able to successfully

calculate financed emissions for. We

calculate a data coverage metric for

each asset class included in the baseline

and expect this to improve over time as

data availability continues to improve.

As at YE2025, of the 69% of our total

AUA which we footprint, the total

portfolio data coverage is 95% which

is broadly unchanged from last year

(post restatement, previously 2024 data

coverage was 89%). Small improvements

in listed asset and sovereign debt data

coverage since YE2024 have been

partly offset by the introduction of

alternative assets into our carbon

footprinting exercise at YE2025.

Change in data quality

scorebyassetclass

Our ability to report accurate emissions

information is dependent on the quality

and transparency of the reporting of

our investee companies. We use the

PCAF data quality hierarchy to assess the

quality of emissions data of individual

companies (Scope 1 and 2 emissions

only), where a score of 1 represents

the highest standard of disclosed and

verified emissions and a score of 5

represents the lowest standard based

on industry estimates. Our total data

quality score has improved from 1.7

at YE2024 to 1.5 at YE2025, which is

primarily driven by an improvement

in our data quality score for sovereign

debt. This is driven by an improvement

in our methodology which now uses

reported and verified emissions data

for sovereign counterparties from ISS.

While reported climate data is generally

of a higher standard than modelled

data, there are challenges with the

consistency, transparency and coverage

of reported climate data which limits

the true accuracy of the carbon profile

of the portfolio. Climate reporting is

still relatively nascent and even high-

quality data has its limitations.

As a result, while our total data quality

score (for assets included in our carbon

footprinting exercise) is relatively high,

we are prudent with what inference we

can draw. The metric results reported

are best estimates. Therefore there

remain limitations in the quality and

coverage of climate data and best

practice methodologies are still

evolving across all metrics. We also

recognise the inherent challenge with

double counting financed emissions

and emissions in the real economy.

Decarbonisation actions

We continue to take action to

decarbonise our investment portfolio

in line with our fiduciary duty and in

support of delivering better customer

outcomes. Our Net Zero Transition

Plan sets out these actions in detail.

We have conducted initial

assessments of our investment

portfolio’s exposure to nature-

related impacts and dependencies

The assessments have been conducted on

portfolio holdings using 2025 Q2 data

within our listed equity and listed credit

portfolios where we have control and

influence. They provide an initial high-level

overview of potential portfolio exposures.

We have considered these outputs along

with more general publicly available

information on sectoral exposures such

asinformation provided by TNFD when

selecting initial areas of focus.

We note that there are significant

limitations to the data used for these

assessments, which are set out in

the limitations section on page 70.

These outputs support work to identify

priority impacts and dependencies

but as we develop our approach we

will look to establish a more bottom-

up led methodology to identifying

sectoral exposure and materiality,

the outputs from which can be better

integrated into investment processes

and support disclosure and reporting.

We recognise that our approach

to assessing and disclosing our

investment portfolio’s potential

exposure to nature-related impacts

and dependencies is still at an early

stage and we will continue to develop

our approach in line with emerging

best practice and as data improves.

See our Glossary on page 348

forthe definition of nature

impactsanddependencies.

Data quality score by asset class

Asset class

Listed

equity

Listed

credit

Sovereign

debt

Real

estate

Illiquid

credit

Equity

release

mortgages Alternatives Total

2019 1.5 1.9 2.0 3.6 2.6 5.0 – 1.8

2021 1.4 2.3 2.0 3.4 – – – 1.9

2023 1.3 1.3 2.0 3.0 2.8 – – 1.7

2024 1.3 1.6 2.1 3.0 2.7 5.0 – 1.7

2025 1.2 1.3 1.3 2.9 2.8 5.0 2.5 1.5

1. Total weighted by AUA.

68 Standard Life plc Annual Report and Accounts 2025

Strategic report

Impacts

Sectors with high or very high potential exposures to nature impacts

Sector

Number of

high/very high

impact exposures

Sector

NAV % High/very high impacts

Materials 6 3% Marine, Freshwater, Emissions of non-GHG air pollutants, Toxic emissions to soil

and water, Generation and release of solid waste, Disturbances

Energy 4 4% Marine, Freshwater, Toxic emissions to soil and water, Disturbances

Utilities 2 6% Emissions of non-GHG air pollutants, Generation and release of solid waste

Consumer

staples

2 4% Toxic emissions to soil and water, Disturbances

Consumer

discretionary

1 8% Disturbances

NAV = Net asset value

Marine and Freshwater impacts refers to ecosystem change, as defined by the publicly available ENCORE tool.

1. ENCORE: Exploring Natural Capital Opportunities, Risks and Exposure. ENCORE Partners (Global Canopy, UNEP FI, and UNEP-WCMC), 2024.

Dependencies

Sectors with high or very high potential exposures to nature dependencies

Sector

Number of

high/very high

dependency exposures

Sector

NAV % High/very high dependencies

Consumer staples 6 4% Water supply, Soil and sediment retention, Water purification, Storm mitigation, Water

flow regulation, Rainfall pattern regulation

Materials 4 3% Water supply, Water purification, Water flow regulation, Rainfall pattern regulation

Healthcare 3 7% Water supply, Water purification, Water flow regulation

Utilities 2 6% Water supply, Solid waste remediation

Energy 2 4% Water supply, Water purification

Assessing our exposure

tonature-related impacts

We assessed our listed equity and

listed credit portfolios for potential

exposure to different impacts defined

by ENCORE

. The table above provides

a high-level summary of sectors

where we are potentially exposed to

nature-related impacts of high or very

high materiality and provides details

of these impacts by sector. Investment

weighted materiality ratings for each

Global Industry Classification Standard

(‘GICS’) level 4 sub-industry have been

aggregated to GICS sector level 1.

Our analysis is based on ENCORE

materiality ratings, with a higher

materiality rating indicating greater

potential for investment value exposure

to nature impacts. In our analysis we

have overweighted ‘Very High’ and ‘High’

materiality ratings to emphasise these

exposures and reflect their increased

potential for financial materiality.

A number of sectors are shown to have

higher potential exposure across multiple

impacts, including utilities, consumer

staples and energy and materials; in

total representing around 17% of the

investment value of assessed portfolios.

Financials and information technology

sectors represent nearly 37% of

investment value assessed but are not

shown due to relatively low potential

exposure materiality. However, we

note that financial institutions will

have increased exposure through

their investment and lending activities

to issuers and clients with high

exposure to nature impacts, which

isnot captured within this analysis.

The analysis reveals a number of

potentially material impacts for our

investment portfolios, including:

emissions of non-GHG air pollutants;

emissions of toxic pollutants to soil

and water; generation and release of

solid waste; and disturbances. Land use

change also features at a more moderate

level of materiality across several sectors.

Assessing our exposure to

nature-related dependencies

We applied the same methodology

to assess our potential exposure to

nature-related dependencies. As

with the impacts analysis, a high or

very high materiality rating indicates

elevated potential exposure to

nature-related dependencies.

The sectors with the most significant

potential exposure to nature-related

dependencies are healthcare, consumer

staples, utilities, energy and materials,

collectively representing nearly 24% of

investment value assessed across our

listed asset portfolios. These sectors

have dependencies across ecosystem

service types, with greatest potential

exposure to dependencies on rainfall

pattern regulation, water purification,

water supply, flood mitigation, storm

mitigation and water flow regulation.

As with impacts, the financial and

information technology sectors show

low materiality of dependence on

ecosystem services and are therefore not

shown; however, we note that this likely

downplays potential exposure to risks

within direct operations and value chains.

Our initial focus on deforestation and

water use and scarcity reflects both

the potential impact and dependency

of portfolio exposures to these topics.

These topics represent potential issuer-

level and more systemic risks and so

we will continue to develop our risk

assessment approaches for both.

69Standard Life plc Annual Report and Accounts 2025

Strategic report

Sustainability review continued

Our climate and nature-related financial disclosures

Impact pressure

focusedassessments

Tropical deforestation

Land use change (driven by tropical

deforestation) has been identified as a

priority impact pressure for the Group.

Several different biomes need to be

considered when addressing land use

change but we have initially focused

our work on tropical forest biomes.

Tropical forest biomes are vital for

climate mitigation and adaptation,

biodiversity and global water cycles.

The deforestation of these critical

biomes is also linked to other issues

such as illegal forest clearance,

misappropriation of lands belonging to

indigenous peoples and financial crime.

To better understand our listed equity and

listed credit portfolios’ potential exposure

to deforestation risks we used data from

Forest 500. Forest 500 identifies the

companies most exposed to deforestation

risks as significant producers, traders and

buyers of agricultural commodities, and

assesses the quality of these companies’

actions to mitigate these risks. We looked

at three factors, including number of

portfolio companies within the Forest

500 dataset, the distribution of Forest

500 scores across these companies and

the percentage investment value for each

score category. Our analysis on page71

shows that we have 157 portfolio

holdings in Forest 500 companies,

representing 9.5% of total investment

value assessed. The analysis identified

that 108 portfolio holdings have a

Forest 500 score of 0–2 indicating that,

of the total portfolio investment value

assessed, 6.2% is exposed to companies

that potentially have poor deforestation

risk management practices.

For more information see our

investment position statement

ontropical deforestation here

Water withdrawal and use

in areas ofhigh water stress

Freshwater scarcity has also been

identified as a priority nature factor for

the Group, given the potential exposure

to material risks and dependencies

in our investment portfolios.

The availability of fresh water is affected

by many factors including climate

change, over-extraction of ground and

surface water resources, pollution and

changes to freshwater ecosystems. Our

summary analysis on page 71 reflects

water withdrawal and use only, with

assessment methods still in development

for portfolio exposure to water pollution

and changes to freshwater ecosystems.

This initial analysis provides a high-level

indication of the extent to which our

listed equity and listed credit portfolios

are exposed to freshwater-related risk

through our portfolio companies’ water

use and the quality of management

actions to mitigate associated risks.

Our analysis shows that around 20% of

our investment portfolio value is exposed

to sub-industries that are classified by

ENCORE as having a moderate, high or

very high impact on water availability

through water withdrawal and use.

Ofour holdings in companies that have

potentially significant exposure, around

45% of investment is in companies

that are scored by CDP as A to B- which

indicates evidence of management

actions to mitigate water-related

risks. However, almost 55% of the

investment value assessed is exposed to

companies which have a CDP rating of

C or lower including ‘failure to respond’

and ‘score not available’ categories,

which may indicate a more elevated

risk profile for these investments.

For more information see our

investment position statement

onfreshwater scarcity here

Limitations

The outputs of our assessment of nature-

related impacts and dependencies

provide a high-level overview of potential

areas of risk within our investment

portfolio. However, there are significant

limitations to the analysis, which limit

the insights we can draw into portfolio-

and issuer- level exposure and risks.

Note that the analyses summarised

above do not yet support investment

decision making within our investment

activities but serve as an input into

the ongoing evolution of our portfolio

assessment methodologies and emerging

investment strategy for nature.

Principal limitations include:

Impact and dependency assessment

• ENCORE materiality data is provided

using the International Standard

Industrial Classification of All Economic

Activities (‘ISIC’) framework. We have

undertaken an exercise to map ISIC

classifications to the Statistical

Classification of Economic Activities in

the European Community (‘NACE’)

classifications using the cross-walk

provided by ENCORE and then mapped

NACE classifications to the MSCI Global

Industry Classficiation Standard (‘GICS’)

classification framework. As a result

ofsystematically applying a double

cross-walk approach some holdings

willbe applied with impact and

dependency materiality ratings that

may be inappropriate and therefore

may significantly under or overstate

ENCORE materiality scores at the

sub-industry and sector levels.

• Impact and dependency exposure

assessments have been generated

atthe GICS sub-industry level and

subsequently aggregated to the GICS

sector level. Sector materiality can be

significantly affected by the number

and diversity of sub-industries. Where

there are a greater number and more

diverse range of sub-industries the

more diluted the sector materiality

may be to reflect the aggregate

investment weighted position at the

sector level.

• ENCORE data is generated top-down

and globally applied and does not

include assessment of the local

geospatial context of issuer activities

at the asset level specifically or full

supply chain exposures of portfolio

companies. We note that gaps in

assessment of critical supply chain

exposures can understate materiality

of high impact and dependency

activities.

• ENCORE data is incomplete, with data

gaps across impact and dependencies

for sub-industries, resulting in a likely

understatement of exposure at

aggregated portfolio level views.

• Materiality ratings may also be based

onhistoric data, potentially understating

or overstating impact or dependency

materiality ratings provided due to

absence of forward-looking components.

• ENCORE data does not support

quantification of financial impacts

ofimpact and dependency exposure

onthe financial metrics of issuers.

Additional data and assessment

approaches are required to

achievethis.

70 Standard Life plc Annual Report and Accounts 2025

Strategic report

0 0

1.9

1.5

5.6

0.6

0 1 3 4 5

Holding count

% of total portfolio assessed

Forest 500 score (0-5)

Holding count

A B C C- D D- Failed to

respond

Score

not

available

A- B-

% investment value of exposed

issuers assessed

CDP score

Tropical deforestation assessment

• Limited portfolio coverage is provided

by Forest 500. We have used historic

data from 2023 with data covering 350

corporate entities only, updated with

2024 Forest 500 scores. Portfolio

exposure and risk is therefore very

likely underrepresented.

• Security identifiers, such as ISINs, are not

provided by Forest 500 and so we have

had to manually apply these resulting in

potential gaps in ISIN coverage.

• Forest 500 data is a proxy for

deforestation risk only. While this

provides good coverage of the

companies handling the largest volumes

of agricultural commodities, it does

notcapture smaller and medium-sized

companies that are still capable of

driving significant deforestation.

• Forest 500 data is unable to link

portfolio companies to actual instances

of deforestation and trace purchased

commodities back to landscapes of

production. As a result, low Forest 500

scores may not necessarily correspond

to instances of deforestation.

Water withdrawal and use assessment

• This assessment relies on ENCORE data

to provide a filter for companies and

issuers based on the materiality rating

for water use. This approach is therefore

subject to the limitations of our approach

to using ENCORE data highlighted on

page 70. In particular it relies on the

mapping of ENCORE’s ISIC classifications

to MSCI GICS which may result in

significant omissions and inclusions

within this filter and subsequently over

or understate the exposure and risk

proxy assessment outputs provided.

• CDP overall company scores provide a

high level and more general assessment

of company responses to managing

water-related risks and as such are

considered as a proxy for risk only.

• Company actions to mitigate impact

pressure and dependency-related risks

are not fully captured by CDP data and

are required to be assessed separately.

Given the limitations of the data, we

emphasise that this analysis serves as

a starting point and that further steps

are being taken to enhance the outputs.

Weare considering options for accessing

additional impact and dependency

data, and conducting more detailed,

bottom-up assessment of exposure,

risk and opportunity that can then be

aggregated to the sector and portfolio

level to provide insights that support

investment decision making. In particular,

we are working to address additional

data needs and we continue to review

evolving asset-level and geospatial

data products with a view to acquiring

additional relevant data in the near term.

Portfolio holdings by Forest 500 score

% investment value of holdings by CDP score

Forest 500 assessment data, Global Canopy, 2024.

Water-related disclosures, CDP, sourced October 2025.

We set nature-related ambitions to

assess and manage nature-related

dependencies, impacts, risks and

opportunities and measure our

performanceagainst these

In line with Finance for Biodiversity

Pledge (‘F4BP’) requirements, the Group

established priority nature ambitions

for2025 with the aim to identify further

options for integrating nature within

investment decision making. We have

achieved these ambitions and the

tablebelow provides information on

ourprogress.

Ambition Progress

Develop initial investment position statements

in relation to priority nature topics.

Statements on deforestation and water scarcity

published on our website here.

Develop initial sovereign debt asset class

portfolio exposure and risk assessment

methodology.

High-level methodology developed and

subsequently aligned with F4BP sovereign

debtassessment guidance.

Continue with and further develop

ongoingmonitoring and assessment of

assetmanagement partners’ integration

ofnature factors.

Additional nature-related questions included

within annual questionnaire for distribution

to asset management partners.

Conduct horizon scan for emerging

nature-related risks for potential inclusion

within in-house credit investment due diligence.

Nature-related factors included within broader

ESG integration framework for illiquid credit with

additional nature factor integration in development

for credit origination and due diligence.

Deliver periodic education and training sessions

with relevant Board and management-level

governance forums.

Introductory sessions on nature were provided

to relevant teams across the Group. Education

sessions and an introductory paper on nature

were also provided to relevant management

andgovernance committees.

71Standard Life plc Annual Report and Accounts 2025

Strategic report

Sustainability review continued

Our climate and nature-related financial disclosures

Our operations

Operations metrics and

targetsframework

The following section is our statement of

our UK and global energy consumption

and GHG emissions for the financial year

1 January 2025 to 31 December 2025,

and the 2024 comparative year. Our

approach is in line with the Streamlined

Energy and Carbon Reporting (‘SECR’)

requirements. We are considering our

approach to developing metrics and

targets to measure and manage the

impact of our operations on nature.

Key progress in 2025

• We have achieved an 84% reductionin

our emissions intensity (Scope 1 and 2

per FTE (market-based)) against our

2019 baseline. Achieving our target to

maintain a 75–85% reduction vs 2019.

• Absolute Scope 1 and 2 emissions

(market-based) reduced by 27%

from2024 and 81% from 2019, in line

with a net zero trajectory. We have

usednature-based carbon removal

credits to offset our residual Scope 1

and 2 emissions and achieve carbon

neutral status.

• Building electricity and gas consumption

was reduced by 12% from YE2024.

We previously set a target to reach net

zero operational emissions by 2025

including by offsetting our residual

emissions, this was based on emerging

best practice. In line with current

best practice, we are now targeting

a 90% reduction in our Scope 1 and

2 absolute emissions, which we aim

to achieve by 2030 or sooner.

Measuring our

operationalemissions

Emissions intensity

The Group has used the GHG Protocol

Corporate Standard (revised edition)

and emissions factors from the

International Energy Agency (‘IEA’),

DESNZ UK Government Conversion

Factors, and Association of Issuing

Bodies (‘AIB’) European Residual

Mix as the basis to report on any

greenhouse gas (‘GHG’) in tonnes of

carbon dioxide equivalent (‘tCO

e’).

This expresses multiple greenhouse

gases in terms of carbon dioxide based

on their global warming potential

(including methane, nitrous oxide,

hydrofluorocarbons, perfluorocarbons

and sulphur hexafluoride).

Operational decarbonisation targets

Absolute energy consumption and GHG emissions

Absolute energy consumption in GWh

Consumption (GWh)

from: 2025 2024

Building electricity 18.0 19.0

Building natural gas 11.5 14.4

Business travel 0.1 0.2

Homeworking electricity 1.4 1.4

Homeworking natural gas 20.6 21.7

Total consumption 51.6^ 56.7

Absolute GHG emissions in tonnes of CO

Emissions

(tCO

e) from:

2025 2024

(Market-

based)

(Location-

based)

(Market-

based)

(Location-

based)

Scope 1 – Combustion of fuels,

business travel (in company owned

and operated vehicles), and fugitive

emissions of refrigerant gases

1,533^ 1,533^ 2,111 2,111

Scope 2 – Electricity purchased for

landlord shared services and own use

(heat, steam and cooling not applicable)

0^ 2,480^ 0 2,457

Scopes 1 + 2 – Mandatory carbon

footprint disclosure

1,533 4,013 2,111 4,568

Scope 3 – category 3: Fuel and energy

related activities (T&D)

300 300 290 290

Scope 3 – category 6: Business travel

2,319 2,319 2,887 2,887

Scope 3 – category 7:

Employee commuting

(incl. Homeworking emissions)

4,319 4,099 4,507 4,309

Scope 3 – category 8:

Upstream leased assets

1,077 803 951 722

Scope 3 – category 13:

Downstream leased assets

968 1,073 842 1,058

Scopes 1 + 2 + 3 –

Voluntary carbon footprint

10,516 12,607 11,588 13,834

Carbon offsets purchased

3,852 2,039

1. Energy Units: 1 GWh = 1,000,000 kWh.

2. Emissions factors – IEA (for location-based Scope 2 and Scope 3 T&D losses), AIB (for market-based residual mix

factors for non-renewable electricity), and DEFRA (fuels, refrigerants and travel). There is a significant time-lag in the

availability of IEA factors –2025 factors will not be published until late 2026. Therefore all 2025 consumption data are

converted using the factors arising in 2021 (except business travel which uses DEFRA factors as published in 2025).

3. Restatements – 2024 business travel emissions have been updated from the originally reported 2,310 tCO

e to 2,887

tCO

e. This was due to an incorrect formula applied to the data identified after the publication of our 2024 SECR

disclosure. The figure has been restated in this 2025 SECR disclosure.

4. Carbon offsets – Carbon offsets purchased in 2025 differ to those in previous years. Previously, offsets attached to

our gas contract that were purchased by the supplier were reported but did not contribute towards the Group’s

emissions reductions. For 2025, the Group purchased and retired carbon removal credits to directly offset operational

emissions in our Scope1, Scope 2 and Scope 3 category 6 emissions. From 2025 onwards, the Group will only report

offsets that are purchased and retired to offset these operational emissions. Once credits are retired they cannot be

used again.

2030

90%

reduction in our operational

Scope 1 and Scope 2 absolute

emissions (market-based) relative

to a 2019 baseline

2025

75–85%

Maintain a 75–85% reduction

inScope 1 and 2 operational

emissions intensity per FTE

(market-based) relative to a

2019baseline

72 Standard Life plc Annual Report and Accounts 2025

Strategic report

0.34

0.28^

-8 4%

-18%

1.7

1.23

0.98

0.79

0.63

0.5

0.4

Target

2.0

1.5

1.0

0.5

tCO

e/FTE

20202019 20222021 2023 2024 2025

-3%

tCO

e/FTE

2.0

1.5

1.0

0.5

1.7

-67%

0.57

0.59

20202019 20222021 2023 2024 2025

kgCO

e/m

101

-45%

-5%

120

150

100

20202019 20222021 2023 2024 2025

Emissions considered relate to activities

both in the UK and globally for which

theGroup is responsible and include as

applicable: combustion of any fuel and

operation of its facilities; fugitive emissions

released from refrigerants purchased

(based on refrigerant top-ups); and

annual emissions from the purchase of

electricity, heat, steam or cooling by the

Group for its own use. In addition, the

Group estimates Scope 3 emissions

associated with employee homeworking

(using the EcoAct Homeworking Emissions

Whitepaper 2020) and employee

commuting, as well as business travel

from other third-party owned/operated

sources, including car, air, taxi, hotel and

rail travel. Reported data relates to

occupied premises in the UK, Ireland,

Germany, Austria and Bermuda, where the

Group is responsible for energy consumption.

The operational control approach has been

used to define our reporting boundary

(Scope 1 and 2), as described in the GHG

Protocol, to our GHG emissions. Therefore,

the businesses we report on are the

Group and its wholly owned and operated

subsidiaries, and exclude joint ventures

and associates. We consider all locations

where the Group is responsible for the

utility costs and able to tangibly influence

our energy supplier to be within our

‘operational control’ as Scope 1 and 2. For

locations that fall outside this boundary,

emissions are reported under Scope 3

(category 8 or 13, depending on whether

the Group is the end user of energy).

TheGroup reports Scope 2 emissions

using the GHG Protocol dual-reporting

methodology, stating two figures:

• A location-based method that reflects

the average emissions intensity of the

national electricity grids from which

energy is drawn.

• A market-based method that reflects

emissions from electricity specific to

each supply/contract. Where electricity

supplies are known to be from a

certified renewable source, a zero

emissions factor is used. Otherwise,

residual mix factors are used, or

location-based factors where residual

mixes are unavailable.

Market-based emissions remain the

primary measure of GHG emissions for

the Group to focus on the actual carbon

impact of energy consumption. This

recognises the organisation’s actions to

promote sustainable procurement and

improve environmental outcomes.

For completeness we also disclose

ourtotal Scope 3 emissions – total

ofcategories 1,2,3,6,7,8,13 which has

decreased from 66,375 tCO

e (YE2024)

(restated) to56,099 tCO

e^ (YE2025).

Emissions intensity metric for Scope 1 and 2 emissions per FTE

(market-based) – accounting forrenewable energy purchasing

as a carbon reduction method

Emissions intensity metric for Scope 1 and 2 emissions

per FTE (location-based)

Emissions intensity metric for Scope 1 and 2 emissions

from occupied premises per floor area (location-based)

The Group’s chosen intensity measurement

Emissions (kilogrammes and tonnes)

of CO

e per chosen intensity metric:

2025 2024

(Market-

based)

(Location-

based)

(Market-

based)

(Location-

based)

Scope 1 and 2 emissions from occupied

premises per floor area (kg CO

e/m

)

28^ 56 34 59

Scope 1 and 2 emissions from occupied

premises per full-time equivalent

employee (tCO

e/FTE)

0.28^ 0.57 0.34 0.59

73Standard Life plc Annual Report and Accounts 2025

Strategic report

Sustainability review continued

Our climate and nature-related financial disclosures

Commentary on the

Group’sperformance

In 2025, the Group consumed 29.6 GWh

of energy globally (the sum of building

electricity, building natural gas and

business travel, as shown on page 70),

approximately 98% of which was from UK

operations. This is a decrease in global

energy consumption compared with

2024, driven by estate consolidation and

energy efficiency measures. In addition,

21.92 GWh of energy consumption

from employee homeworking has

been estimated in 2025, of which 89%

occurred within the UK. This is a decrease

compared to 2024, primarily driven by

a decrease in the number of FTEs.

The Group’s GHG emissions (location-

based Scope 1 and 2) have continued to

decrease year-on-year, by 12% in 2025.

The Group has further consolidated

its occupied areas by sub-letting

spaces within an additional site. The

associated emissions for this site

have been apportioned into Scope 3

category 13, resulting in an increase of

1.4% (location-based) for this category.

The Group also entered three new

office leases in 2025, including them

into Scope 3 category 8, resulting in

an increase of 11% (location-based)

emissions for this category in 2025.

Business travel has seen a decrease

of 19.7% (restated) largely due to a

reduction in FTEs and starting to utilise

travel carbon budgets as a lever to

reduce travel emissions. This is despite

the addition of taxi emissions to our

Scope 3 category 6 emissions in 2025.

The Group continues to procure 100%

of its directly obtained electricity from

certified renewable sources, which is

why market-based Scope 2 emissions

are zero in the table on page 72.

Operational emissions intensity

The Group’s chosen operational intensity

metrics detail GHG emissions per

occupied floor area (m

) and per FTE in

occupied premises. Themethodology

to establish whether buildings should

be included in the intensity metric only

covers occupied areas of buildings where

emissions are considered Scope 1 and

2, where Group FTEs are present, and

where 12 months of data is available in

the current reporting year. To calculate

the intensity for both occupied floor

area and FTE per occupied premises, the

total Scope 1 and 2 emissions for these

buildings were divided by the applicable

occupied floor area and FTEs respectively.

Analysing our

operationalemissions

In 2025, both the floor area and FTE

intensities have seen slight reductions

due to a decrease in the total Scope 1 and

2 emissions. This is despite a reduction in

total FTEs and floor area occupied. Our

Scope 1 and 2 emissions market-based

intensity metric per FTE intensity has

decreased from 0.34 tCO

e (YE2024) to

0.28 tCO

e^ (YE2025). This is primarily

due to the reduction in Scope 1 and 2

emissions despite a reduction in FTE

numbers for the Group. The Group has

achieved an 84% reduction in emissions

intensity since YE2019 and is therefore

within the target range of a 75–85%

reduction vs 2019. The reduction in

emissions intensity is driven by estate

consolidation and the implementation

of energy efficiency measures. The

emissions intensity per floor area (m

)

(location-based) decreased slightly from

59 tCO

e/m

in YE2024 to 56 tCO

in YE2025. This is due to a decrease

in emissions as well as occupied floor

area. The emissions intensity per FTE

(location-based) has also reduced slightly

at YE2025 compared to YE2024. The

Group has achieved overall reductions

from the 2019 baseline of 45% and

67% in these areas respectively.

Our approach to offsetting

In 2025, the Group purchased carbon

removal credits totalling 3,852 tCO

to offset residual Scope 1, Scope 2 and

Scope 3 category 6 emissions. This is the

first time the Group has offset its direct

operational emissions. Our approach

follows the mitigation hierarchy set out

by the Oxford Offsetting Principles,

prioritising emissions reductions

first. To offset any residual emissions,

weprocure carbon credits from high

integrity nature-based removal projects

as defined by industry standards,

including the International Carbon

Reduction and Offset Alliance’s Code

of Best Practice and the Core Carbon

Principles developed by the Integrity

Council for the Voluntary Carbon Market.

Read our Position statement

ontheuse ofcarbon credits

Decarbonisation actions

We continue to take action to

decarbonise our operational emissions.

The Group aims to prioritise its spending

based on the potential carbon impact of

projects across the operational estate.

The following key projects are a selection

of the actions undertaken by the Group

in 2025; our Net Zero Transition Plan

sets out these actions in detail.

1. Completed Year 1 delivery of our

Energy Performance Contract with

facilities management partner, Mitie.

Delivering c.200 individual energy

conservation measures at four of our

main sites (Standard Life House,

Telford, Wythall and Glenogle Road).

2. Upgraded our building management

systems in Standard Life House and

completed a full audit, identifying and

replacing faulty sensors to bring them

in line with our Comfort Policy.

3. Consolidated floor space and reduced

heating, ventilation and air-

conditioning equipment demand on

one floor in our Wythall office in

preparation for site exit.

4. Reviewed office equipment and

replaced poor performers with more

efficient alternatives. This included

ventilation and air-conditioning

equipment at Telford and a

refurbishment at our Dublin office.

We continue to review opportunities

on an ongoing basis to reduce our GHG

emissions through the Group’s Eliminate-

Reduce-Substitute-Compensate model.

2030

50%

reduction in our supplier base Scope 3

category 1 and 2 emissions intensity

2050

Net zero

across our supply chain

Supplier base decarbonisation targets

74 Standard Life plc Annual Report and Accounts 2025

Strategic report

-36%

-10%

65^

101

tCO

e/£m

120

20232022 20252024

Emissions intensity

(Scope 3 emissions – categories 1 and 2 on a per £ spend intensity)

20232022

9 9

-33%

47^

6060

20252024

80,000

70,000

60,000

50,000

40,000

30,000

20,000

10,000

tCO

Total absolute emissions (Scope 3 – category 1 and 2)

Absolute emissions (Scope 3 – category 1)

Absolute emissions (Scope 3 – category 2)

Emissions intensity of our supplier base (location-based)

Absolute emissions of our supplier base

Our supplier base

Supplier base metrics

andtargets framework

We continue to review and enhance our

supplier metrics taking into account

examples of emerging best practice in

evaluating exposure to climate-related

risks and opportunities. We have set

science-based emissions reductions

targets which are aligned with a net zero

by 2050 pathway. We do not use carbon

credits to achieve our supplier base

decarbonisation targets. We have begun

to assess our exposure to nature-related

risks and dependencies within our

supplier base and will aim to introduce

nature-related metrics and targets as

data, methodologies, industry guidance

and best practice develop.

Key progress in 2025

• We are making progress towards our

2030 decarbonisation target; noting a

dependency on action by our suppliers.

• We have achieved a 36% reduction in our

Scope 3 category 1 and 2 emissions

intensity from our 2022 baseline year.

• Our 10 highest emitting suppliers,

accounting for 41% of the supplier

base’s absolute emissions, have set

ascience-based net zero target.

• Our absolute emissions have decreased

by 33% from our 2022 baseline to

47,116 tCO

e^.

Measuring our supplier

baseemissions

Data is integrated from multiple

sources to calculate the supplier base’s

emissions, including: supplier Scope

1, 2 and 3 emissions data from public

disclosures (upstream only); supplier

revenue; invoiced spend reports; supplier

carbon data collected by the Group’s

ESG third-party data collection partner;

and UK Government Standard Industrial

Classification codes and the associated

emission factors provided by DEFRA

(and the University of Leeds). These

inputs are combined in an Extended

Environmental Input-Output model,

where spend is multiplied by emission

factors to calculate supplier emissions.

Analysing our supplier

baseemissions

The Group achieved a 36% reduction

inthe supplier base emissions intensity

(tCO

e/£m), relative to the baseline, from

101 tCO

e/£m (YE2022) to 65 tCO

e/£m^

(YE2025); and a 33% reduction in the

absolute supplier base total emissions

(tCO

e), relative to thebaseline, from

69,861 tCO

e (YE2022) to 47,116 tCO

(YE2025). These reductions are primarily

driven by a lower supplier spend in

2025 and our suppliers decarbonising

in line with expectations. The Group’s

supplier base emissions are concentrated

within our Business Process Outsource,

Technology and Professional Services

categories. Our top 50 highest

emitting suppliers account for 75%

of all emissions across the supplier

base, which comprises c.1,100 active

suppliers, and our 10 highest emitting

suppliers in 2024 accounted for 41% of

the supplier base’s absolute emissions.

Limitations and dependencies

The Group’s carbon accounting of

category 1 and category 2 emissions

only covers the supplier base (our direct

suppliers). The Group does not measure

or report the emissions arising outside

of this boundary. The Group has made

significant improvements with its

methodology to calculate its Scope 3

category 1 and 2 emissions, however

we recognise that Scope 3 category

1 and 2 emissions are not based on

complete spend data and we continue

to work to improve the data set.

Decarbonisation actions

We continue to take action to decarbonise

our supplier base and engage with our

direct suppliers on their journey towards

net zero. Our Net Zero Transition Plan

sets out these actions in detail.

Our initial assessment of our

supplier base’s exposure to

nature-related impacts and

dependencies

The assessment identified the

sectors where we’re most exposed

to material nature-related risks. The

value chains of companies operating

in data infrastructure and computer

manufacturing sectors were shown to

have highest exposure to risks such as

water stress, land-use change, pollution

and biodiversity loss. Furthermore,

physical climate risks such as droughts

and flooding were also shown to pose

potential operational risks for these

sectors, and transition risks linked

to tightening global regulations may

increase compliance costs. We are using

the outputs to develop next steps.

75Standard Life plc Annual Report and Accounts 2025

Strategic report

Sustainability review continued

NFSIS

Non-financial and sustainability

information statement

As required by the Companies Act 2006 sections 414CA and 414CB, this

table outlines our non-financial and sustainability information statement

with a reference to relevant policies and additional documents.

This section primarily covers our non-financial information

as required by the regulations. Other related information

can be found as follows:

Environment

Our policies

The Group aims to reduce the impact on the environment from our

operations, and our Environmental Management System certified to ISO

14001 is intended to help us achieve this. We aim to minimise emissions that

contribute to climate change, including our direct emissions and working

collaboratively with our suppliers. We are taking steps to decarbonise our

investment portfolio, ensuring effective stewardship of our assets, and

investing in climate solutions. We are collaborating with decision makers

and peers to drive wider system change, and engaging customers and

colleagues on climate action.

In our Environmental Policy we commit to:

1. Compliance with relevant environmental regulations and standards

and other obligations.

2. Protection of the environment.

3. The prevention of pollution and the management of our

environmentalimpacts.

4. Continual improvement regarding our environmental performance.

We have a range of additional policies and strategies including:

• our approach to ESG integration,

• our sustainability strategy,

• our sustainable investing risk policies.

In addition, we review Group risk policies on an annual basis to consider

sustainability matters and ensure high standards are maintained.

Due diligence

Andy Briggs, Group CEO, is responsible for embedding sustainability within

the Group, in line with the strategy set by the Group Board. The Group

CEO reports directly to the Board on all sustainability activity across the

business including the Environmental Policy. We will monitor and review

our environmental performance against our environmental commitments

set out in our policy and targets.

We report on our environmental performance annually and review the

policy to ensure it remains relevant and appropriate.

Outcomes

Read more about our net zero and climate-related reporting commitments

and KPIs on pages 48 to 52 and our sustainability actions in our 2025

Sustainability Report, Net Zero Transition Plan, and Stewardship Report.

Our GHG emissions and energy consumption disclosure can be found in

the ESG Data Appendix.

For further information

• Our sustainability policies: https://www.standardlifeplc.com/

sustainability/reports-policy-membership

• For further reading on sustainability governance see pages 42–43 of our

Sustainability Report: https://library.standardlife.co.uk/sustainability-

report-2025.pdf

• Our Net Zero Transition Plan: https://library.standardlife.co.uk/net-zero-

transition-plan.pdf

Colleagues

Our policies

Risk is defined in the Group’s People Risk Policy as the risk of reduction

inearnings and/or value, through financial or reputational loss from

inappropriate staff behaviour or industrial action issues. Loss can also

beincurred through failure to recruit, retain, train, reward or incentivise

appropriately skilled staff to achieve objectives and/or through failure totake

appropriate action as a result of staff under performance. Our Group approach

to support the health and wellbeing ofcolleagues is a key enabler to build an

inclusive, attractive, and safe working environment that can adapt and respond

quickly to change. A key priority for our business is to create aworkplace that is

diverse, inclusive and reflective of our customers and communities, where all

colleagues feel valued and supported. Our Group Dignity at Work Policy sets out

what we commit to and what we expect ofouremployees to ensure we maintain

a working environment free of discrimination where everyone is treated with

dignity and respect. It provides clear guidance to helpmanage discriminatory

complaints fairly, effectively, andas quickly as possible.

Board members

Female 7 58%

Male 5 42%

Senior managers

Female 28 43%

Male 37 57%

All employees

Female 2,726 49%

Male 2,793 51%

Senior managers and

theirdirectreports

Female 48 45%

Male 59 55%

1. Companies Act 2006, s.414C(8)(c)(i).

2. Companies Act 2006, s.414C(8)(c)(ii).

3. Companies Act 2006, s.414C(8)(c)(iii).

4. Provision 23, UK Corporate Governance Code, see page 114

Due diligence

Adherence to the People Risk Policy is managed by the Group People function

via quarterly control assessments. Control testing is integrated as part of the

Risk Management Framework and People controls are currently tested every

12, 24 or 36 months depending on materiality. There were no material issues

raised during the year. All colleagues are required to complete annual

computer-based health and safety training. Arrangements are in place to

manage on-site facilities across all sites, ensuring the working environment

is compliant and fit for purpose. We have a range of tools and resources

available to support our colleagues, their dependents, family members

andloved ones to help look after their personal health and wellbeing.

Outcomes

Other relevant colleague engagement, including Diversity, Equity and Inclusion data

can be found on pages 113 to 114 as well as in the ‘Supporting our colleagues’

and ‘Diversity, Equity and Inclusion’ sections ofour 2025 Sustainability Report.

For further information

• Health and wellbeing approach: https://library.standardlife.co.uk/

health-and-wellbeing-statement.pdf

• Reward and benefits: https://www.standardlifeplc.com/careers/

rewards-benefits

• Diversity, Equity and Inclusion: https://www.standardlifeplc.com/careers/dei

• Dignity at Work Policy: https://library.standardlife.co.uk/dignity-at-work-

policy-may-2025.pdf

For further details on our Business model see pages 18 to 21

For further details on our climate-related financial disclosures

see our TCFD compliance statement on page 53

For further details on our principal risks and how

they are managed see pages 80 to 83

76 Standard Life plc Annual Report and Accounts 2025

Strategic report

Social and community

Our policies

Customers

The Group’s Customer Outcomes Risk Policy sets the minimum

operating standards relating to the management of customer

outcomes risk across the organisation that could impact the

delivery of good customer outcomes and cause foreseeable harm.

The Group is committed to continuously improving communications

and support, ensuring customer vulnerabilities are carefully

considered to allow them to make informed decisions.

Robust processes and controls are in place to facilitate

ongoing oversight and monitoring of customer outcomes,

ensuring we continue to deliver good customer outcomes

andfair value, and avoid foreseeable harm on our product and

proposition design in line with regulatory requirements.

Our Responsible Marketing Policy sets out our commitment

tocommunicating the correct information at the correct time

and manner, ensuring our communications are easily accessible

and understood.

Suppliers

We are committed to embedding sustainable best practice

across our supplier base. We ask our partners and suppliers

toimplement the requirements and targets within our ESG

Supplier Standards, which reflect our own ESG standards.

Additionally, our Supplier Code of Conduct (‘Code’) applies

toall suppliers that provide goods or services to us and/or any

of our subsidiaries. The Code outlines the minimum conduct

standards to which suppliers must adhere when doing business

with us, as well as supporting operational resilience and

strategic growth.

Community engagement

Giving back is part of our culture and we do this by fundraising,

volunteering and sharing knowledge through our colleague

programme. All colleagues across the UK and Ireland are

entitled to three days’ volunteering. We match fundraising

donations colleagues make to approved registered charities

across the year. We also give our colleagues the opportunity

todonate to registered charities through the payroll giving

scheme Give as You Earn in the UK, and 1HOP and Good2Give

in Ireland.

Due diligence

Our Data Protection Officer oversees and monitors compliance

with the GDPR and DPA 2018. Through an aligned Data

Protection Risk Policy, they provide training and awareness

services and drive compliance through embedded frameworks

and standards. Our Chief Information Security Officer oversees

the delivery of and compliance to our Information Security

Policy, utilising capabilities such as Threat Intelligence,

Penetration Testing and Vulnerability Management to identify

and control cyber risks. The Group manages a comprehensive

programme of continuous testing and improvement to our

Information Security Framework, collaborating with industry

experts and authorities to embed best practices throughout.

Complaint activity, including those referred to the Financial

Ombudsman Service and the Pensions Ombudsman, is

monitored, and we also resolve a significant proportion of

complaints across the Group in fewer than three days.

Outcomes

Information on our customer satisfaction scores and initiatives

can be found on pages 33–34 of our 2025 Sustainability Report.

Information on relevant supplier and communities metrics can

be found in our 2025 Sustainability Report.

For further information

• Privacy Policy: https://www.standardlifeplc.com/privacy-hub

• ESG Supplier Standards: https://library.standardlife.co.uk/

esg-supplier-standards_dec2024.pdf

• Responsible Marketing Policy: https://library.standardlife.

co.uk//responsible-marketing-policy.pdf

Human rights

Our policies

We recognise our responsibility to respect human

rights and do this in accordance with:

• the International Bill of Human Rights; and

• the International Labour Organization’s (‘ILO’)

Core Conventions.

As an asset owner, we also align with the

Organisation for Economic Co-Operation and

Development (‘OECD’) Guidelines for Multinational

Enterprises, a set of responsible business conduct

standards for multinational enterprises, as well

as the OECD guidance on responsible business

conduct for institutional investors.

We are committed to fully aligning with the

United Nations Guiding Principles on Business

and Human Rights (‘UNGPs’), the authoritative

global framework on business and human

rights,and our ambition is to encourage other

organisations to do the same.

Our Group-wide Human Rights Policy applies to

all entities, business units and operations and we

expect all employees to adhere to the policy in

their work.

We are committed to working with our partners

tomultiply our impact and we expect our suppliers,

contractors, asset managers and investee

companies to be aware of our policy and respect

human rights in their business operations. We are

committed to updating our Human Rights Policy

at least every three years.

Due diligence

During 2022 we appointed a human rights

consultant to review our alignment to the UNGPs

by conducting an assessment and identifying

opportunities for improvement. This work

informed the development of a roadmap to

address gaps, which we will continue to make

progress on. As part of our ongoing due diligence

processes, we continue to identify and assess the

salient human rights issues to prioritise for

further action across our operations and value

chain. This process includes a portfolio-level

assessment of human rights risks in countries

ofoperations and high-risk business relationships

on an ongoing basis.

In 2025, we completed a due diligence of our

investments portfolio to understand our

exposure to human rights risks through our

investment activities. In 2026, this due diligence

will inform our thematic engagement programme

on human rights starting in 2026.

Outcomes

During 2025 The Group effectively resolved all

colleague disputes and as a result has not been

subject to any adverse employment tribunals,

judgements or awards. We report on our salient

human rights issues, actions, and progress

toalign with the UNGPs through our 2025

Sustainability Report and Modern Slavery

Statement , and our Stewardship Report captures

our assessment of human rights risks across our

investment portfolios.

For further information

• Modern Slavery Statement: https://library.

standardlife.co.uk/modern-slavery-

statement-2025.pdf

• Human Rights Policy: https://library.

standardlife.co.uk//human-rights-policy.pdf

• Stewardship Report: https://www.

standardlifeplc.com/sustainability/reports-

policy-membership

Anti-bribery and corruption

Our policies

The Group has a zero-tolerance

policy to bribery and corruption

in all its forms. The Group is

committed to countering bribery

and corruption and has suitable

policies and procedures in place.

This includes, for example:

• a Group Financial Crime

Prevention Policy that covers

Anti-bribery and corruption risk;

• mandatory training for our

employees covering compliance

with the Bribery Act;

• a Code of Ethics for ethical

behaviour and general

standards; and

• a Group Stewardship Policy which

details our stewardship approach.

The Group’s Financial Crime

Prevention Policy addresses risks

such as money laundering, terrorist

financing, fraud (including Failure

to Prevent Fraud – ECCTA 2023),

sanctions breaches, bribery and

corruption risks and the facilitation

of tax evasion.

The Group also operates a Speak Up

Policy, prompting colleagues to

disclose information where they

believe wrongdoing, malpractice or

risk exists across any of the Group’s

operations. The Group has a zero

tolerance for individuals experiencing

detriment as a result of raising

Speak Up concerns.

Due diligence

Colleagues are required to

complete annual computer-based

training in all aspects of financial

crime prevention and are also

required to complete a Gifts and

Hospitality Register which is

overseen and managed by the

Financial Crime Team.

Outcomes

The Group’s governance processes

for financial crime prevention,

anti-bribery and anti-corruption,

ethics and compliance training,

whistleblowing and speaking up

can be found on our Group website.

Of the 30 Speak Up reports

received during the reporting

period, 20 met the threshold for

aSpeak Up disclosure and were

investigated in accordance with our

Speak Up processes. The remaining

reports related to people policy or

local management matters and

were progressed through HR or

therelevant business channels.

For further information

• Governance: https://www.

standardlifeplc.com/

sustainability/governance

• Anti-bribery statement: https://

www.standardlifeplc.com/

investors/governance/anti-bribery

• ESG Data Appendix: https://

library.standardlife.co.uk/

esg-data-appendix-2025.xlsx

77Standard Life plc Annual Report and Accounts 2025

Strategic report

Our risks and risk management

Effective risk management is key to delivery of our purpose and

strategy – ensuring that we make informed risk-based decisions that

allow us to navigate the dynamic and uncertain risk environment to

deliver good outcomes for our customers and our shareholders.

We prefer risks that support our strategy

and purpose, that are rewarded and that

we can measure and manage. Our

leadership, people and culture are key to

effective risk management, underpinned

by our continuously evolving Risk

Management Framework (‘RMF’).

Our ongoing investment in our RMF and

associated technologies underscores our

dedication to protecting our customers

and achieving sustainable growth.

Our risk environment

The Group continues to operate in an

uncertain risk environment. In 2025, this

was shaped by US tariffs, historically low

credit spreads and persistent geopolitical

tensions, alongside a competitive

market environment that is evolving

as customer expectations and artificial

intelligence (‘AI’) capabilities advance. In

addition, the recent escalation of conflict

in the Middle East has contributed

to ongoing uncertainty. Despite this

backdrop, the strategy is unchanged.

There continues to be strong structural

demand for retirements savings and

Pension Risk Transfer (‘PRT’) solutions,

even amid economic uncertainty.

We continue to maintain a risk-aware

culture and adapt as the nature of risks

changes and new risks emerge. Our

principal risks are set out below and

are materially unchanged from 2024.

Our business and balance sheet remains

resilient. We use our Partial Internal

Model to measure our exposure to

quantifiable risks – with the exception

of liquidity risk which is separately

quantified using stress testing. Stress

and scenario testing (including reverse

stress testing) is used to test the

financial and operational resilience

of our strategy, business model,

balance sheet and operations.

Our Risk Management

Framework

Effective risk management is

fundamental to our strategic objectives,

operational resilience, and the long-

term sustainability of our organisation.

Our RMF as illustrated on page 79

is an integral component of our

corporate governance, so that risks

are systematically identified, assessed,

managed and reported on throughout

all levels of our business. The regular

review and continuous improvement

of our RMF are essential to maintaining

its effectiveness and adapting to an

evolving risk landscape. This includes

the continued development of our

approaches to emerging risk areas

such as AI and nature-related risks.

The RMF consists of a number of key

components that collectively enable

comprehensive oversight and effective

risk management throughout the Group.

Risk strategy and appetite

Our Group’s risk strategy is intrinsically

linked to our overarching purpose to

help people secure a life of possibilities

and our strategic aim to build and grow

a long-term sustainable business. We

are deeply committed to disciplined

risk taking, which is guided by our risk

appetite and governance frameworks

so that leaders can evaluate and

challenge opportunities on the

risks we are willing to accept.

Risk culture and riskgovernance

Effective risk governance and a risk-

aware culture are fundamental to

achieving our strategic objectives

and upholding our purpose.

Our culture is a strategic asset,

fundamental to delivering our purpose

and achieving sustainable growth. We

are committed to operating a culture

where every colleague is empowered to

champion risk management and deliver

good outcomes for our customers.

We regularly assess our risk culture

through surveys, workshops, and

behavioural science inputs, ensuring

that our desired cultural attributes

are embedded and owned across all

teams. Our senior leaders actively

model and reinforce the behaviours

that define our culture, supporting

colleagues to challenge, innovate, and

collaborate. We value every colleague’s

voice in shaping our culture, using

feedback and engagement initiatives

to drive continuous improvement.

Our governance framework is built

upon the three lines of defence risk

governance model, underpinned by our

comprehensive RMF. Within this model:

• The business functions in the First Line

hold primary accountability and

ownership for identifying, assessing,

managing and reporting on the risks

inherent in their day-to-day activities.

They are responsible for the proactive

management of risks at the point

oforigin.

• The Second Line Risk and Compliance

function provides expert advice,

guidance, and independent oversight

of the First Line’s risk management

activities. It is responsible for

developing and maintaining the RMF,

setting risk policies, and offering

constructive challenge to make sure

the business adheres to risk appetite

and regulatory requirements.

• The Third Line Internal Audit function

delivers independent and objective

assurance on the effectiveness of the

Group’s governance, risk management,

and internal control processes.

Overall responsibility for approving

the RMF rests with the Board. The

Board delegates the maintenance and

review of the design and operating

effectiveness of the RMF to the

Board Risk Committee alongside

the review and recommendation to

the Board of the risk appetite, risk

policies, management of the Group’s

risk profile and any emerging risks.

Risk management

78 Standard Life plc Annual Report and Accounts 2025

Strategic report

Risk strategy and appetite

Risk governance

Risk culture

Risk Universe

Internal control

Risk policies

Oversight and validation

Tech, data and innovation

Incident management

and continuous learning

Enterprise Risk

Management

Framework

Emerging risks, stress

testing and scenario analysis

Risk and Control

Self-Assessments

Risk analytics and

management information

Own Risk and

Solvency Assessment

Internal Model

The Group’s financial incentive

arrangements incorporate risk

management metrics, ensuring

alignment with the Group’s risk appetite

and governance frameworks. The

Group’s Chief Risk Officer advises

the Remuneration Committee on any

adjustments to these incentives where

appropriate, and both incentives and

metrics are subject to regular review.

To support effective risk management

being embedded in the business,

colleagues across all lines of defence

receive regular training on the RMF.

Risk Universe and

internalcontrol

Our Risk Universe consistently defines

and categorises all known risks to

the organisation. This Risk Universe

is regularly reviewed and updated to

adapt to the evolving risk environment.

It is fully integrated into our risk

management activities, including the

setting of our risk appetite and our

Own Risk and Solvency Assessment

(‘ORSA’) process. Aligned with our

Risk Universe is our Internal Control

Framework (‘ICF’), which establishes the

objectives, processes and responsibilities

for maintaining an effective internal

control environment. The ICF effectively

manages risks and provides an

evidence-based approach for assessing,

monitoring, and reporting on control

effectiveness throughout the business.

Risk policies

The Group maintains a central Risk

Management Policy that supports the

controlled delivery of our purpose and

strategic objectives. It is supported by a

suite of policies and standards that set

out the Group-wide requirements for the

identification, assessment, management

and reporting of risks.

Oversight and validation

The oversight and validation approach

is used to assess and monitor the design

and operational effectiveness of our

RMF. This includes confirming that our

risk management approach, processes,

systems and activities, alongside the

quality and integrity of the risk data

and key models, are fit for purpose and

are used as intended. It provides critical

evidence of the RMF’s robustness,

effectiveness and consistent

implementation across the Group.

Technology, data

andinnovation

The technology, data and innovation

component of the RMF sets out

the systems, processes and tools

to support effective and consistent

risk management across the Group.

Our risk technology environment is

evolving to keep pace with emerging

market practice and our changing

risk landscape. This will allow us to

further strengthen our ability to

provide data insights and analysis

to aid strategic decision making.

Risk Management Framework

79Standard Life plc Annual Report and Accounts 2025

Strategic report

Risk management focus

Maintaining

Increasing

Decreasing

Risk management continued

Principal risks and uncertainties

facing the Group

Our principal risks focus on the specific risks with the potential to materially

impact the Group’s strategic objectives, future performance, or reputation,

including those that could threaten our business model, solvency or liquidity.

They are not intended to be exhaustive

but are the risks most likely to seriously

affect the Group.

These principal risks are directly

alignedwith the Group’s strategic

priorities and are aligned with the risks

regularly discussed by the Executive

Committee and reported to the Board

Risk Committee.

The Board Risk Committee provides

oversight, considering whether the

consequences of risks crystallising are

understood and appropriate action is

being taken if required to ensure the risks

continue to be managed and mitigated.

Strategic risk

The Group’s ability to deliver its transformation agenda successfully Risk management focus

Impact Mitigating actions

Failure to deliver the successful transformation of our policy

administration capabilities and cost efficiency programmes to meet our

expense saving targets and ensure good customer outcomes.

It is key to bring our business together into an efficient operating model

and achieve the Group’s target expense profile. This will provide us with

the right tools and infrastructure to enable more efficient growth as we

scale the business further.

These policy administration migration programmes also expose the

Group to the risk of significant disruption to the operation of necessary

business processes and controls; and failing to deliver good outcomes

for its customers, should failures occur.

The Group is reliant on our strategic partners to support these

transformation programmes, which introduces further risk if capability

or performance does not meet programme needs.

The Group has a strong track record in delivering policy administration

migration and transformation and has made excellent progress in its overall

cost transformation programme.

Over 2025, the Group carried out its largest migration in history and

successfully migrated a further c.1.9 million policies to the TCS BaNCS

administration system with minimum customer impact.

On 1 October 2025, the Group completed the transfer of ownership of

theALPHA platform to Wipro

, which will continue to serve our ReAssure

customers and invest further in this modern platform. This reduced the

riskand complexity within our migration portfolio. At the end of 2025,

75%of policies are on their end-state platform.

The Group maintains its focus on delivering the remaining key programmes

that support the delivery of an efficient operating model including the

remaining customer platform migrations.

1. Through Servaada, Wipro’s FCA regulated entity.

80 Standard Life plc Annual Report and Accounts 2025

Strategic report

Strategic risk continued

The Group is exposed to the risk that customer behaviours evolve in ways that Risk management focus

are difficult to predict, influenced both by factors within and outside their control

Impact Mitigating actions

Shifts in wider social and societal attitudes, including increasing

expectations around digital accessibility and transparency, and

heightened political and social sensitivities, may influence how

customers perceive and engage with long-term savings and

retirementproducts.

Such behavioural changes may affect customer engagement,

persistency, product demand and satisfaction, potentially resulting

inadverse customer outcomes, reputational harm, or commercial

performance.

This risk is amplified by macro-economic uncertainty and rising public

expectations around fairness and sustainability, which continue to

shape customer sentiment and influence financial decision making.

The Group focuses on long-term decision making prioritising our Consumer

Duty obligations, with a clear emphasis on supporting customers’ retirement

savings and income needs.

The Group actively works to improve customer understanding of long-term

financial planning and the importance of securing a sustainable retirement

income. We are continuing to develop solutions to support customer

decision making.

In line with evolving customer expectations, the Group continues to invest

and improve our digital access for customers.

The Group closely monitors customer opinion and wider consumer and

economic trends, enabling us to adjust our approach where appropriate

tosupport customers in meeting their long-term retirement savings and

income needs.

Climate risk

The Group fails to understand and respond to risks associated with climate Risk management focus

change and other environmental, social and governance (‘ESG’) factors

Impact Mitigating actions

Climate risk is significant for both the Group and our customers.

Toreduce the physical impacts of climate risk, the global economy

needs to transition to a low carbon economy. This creates both

physicaland transition risks that could impact our strategy and

businessmodel, shareholder and customer asset values, our operations,

and the behaviours of our customers. The Group is also exposed to

litigation risk.

We actively manage climate risk for all our stakeholders and look to

support the transition to a low carbon economy through our Net Zero

Transition Plan – nonetheless our priority focus is delivering good

customer outcomes.

Emissions pathways are inherently uncertain due to the unpredictability

of economy-wide decarbonisation rates and evolving policy, regulatory

and market environments – all factors that could affect our ability to

effectively manage climate risk and that are outside our direct control.

The Group has a clear sustainability strategy in place which is reviewed

annually and includes our response to climate change. Delivery is overseen

by the Board Sustainability Committee.

Investment decisions are made in customers’ interests, including managing

their exposure to climate and other risks. We focus on initiatives that

support good customer outcomes and effective climate risk management,

including our Sustainable Multi Asset funds, SDR-labelled products, climate

aware benchmarks, and our broader stewardship and engagement work.

The Group uses qualitative and quantitative scenario analysis to assess our

risk exposure and monitor a defined set of sustainability key metrics.

The Group also maintains constructive engagement with investee

companies, asset managers, policymakers, and market participants to shape

our approach and support broader system-wide responses to climate and

sustainability risks.

81Standard Life plc Annual Report and Accounts 2025

Strategic report

Risk management focus

Maintaining

Increasing

Decreasing

Operational risk

The Group or its partners are not sufficiently resilient Risk management focus

Impact Mitigating actions

Across the wider market, both the volume and sophistication of

cyber-attacks have risen significantly, and this trend is expected

tocontinue.

Severe disruption – whether within the Group or through our key

suppliers – could affect our ability to deliver our important business

services and meet customer outcomes.

Severe events may lead to customer hardship, reputational damage,

regulatory scrutiny or increased operating costs.

The Group is committed to protecting customers from harm inthe event

ofacyber-attack or an unexpected disruption.

The Group continues to invest in adapting our cyber security controls as

threats evolve and become more sophisticated.

The Group’s Operational Resilience Framework supports our ability to

maintain critical and important business services and recover quickly in the

event of an interruption or disruption to service from a material third party.

We continually review our important business services and undertake

resilience testing to understand our ability to avoid intolerable harm in

theevent of a severe scenario.

The Group continues to work closely with its outsource partners and

third-party suppliers to ensure it remains within risk appetite and impact

tolerances for operational resilience.

The Group is impacted by significant changes in the regulatory Risk management focus

or legislative environment

Impact Mitigating actions

Changes in the regulatory or legislative environment could impact the

industry, products we offer, our distribution channels or the Group’s

capital requirements.

Regulatory focus on the PRT market continues to evolve and the Group

continues to monitor and respond to developments in this space.

The Group is exposed to the risk of changes in tax legislation or fiscal

policy, which could affect the taxation of life insurance business,

investment returns, and impact the ongoing attractiveness of

retirement and savings products to customers.

The Group is exposed to changes to policy in the markets we invest

inwhich could impact the value of our investments.

The Group regularly engages with regulators and policymakers to listen and

contribute to discussions on a wide range of matters, including those that

could have market-wide and systemic risks. The Group will continue to monitor

developments across the political and regulatory environment during 2026

anduse our voice and experience to influence thinking.

Sensitivity testing and scenario analysis of the Group’s business model and

balance sheet are used to consider potential strategies to respond to

changes in regulations.

The Group fails to retain or attract a diverse and engaged workforce Risk management focus

with the skills needed to deliver its strategy

Impact Mitigating actions

The Group requires talented, diverse and engaged people with the

rightskills and capability to deliver our strategy.

There is a risk that it will be harder to retain skilled colleagues,

maintaining critical capabilities during transformation. This could

impact the delivery of critical business change programmes such as

migrations or transformation.

There is also a key risk that it will be harder to attract new capabilities

(e.g. AI) in a competitive market and impact our ability to deliver

ourambition.

There is ongoing monitoring of the capability and capacity required to

support both business as usual activities alongside key programme delivery

and to ensure the operating environment remains stable.

The Group continues to build on its future-focused skills needed to support

long-term growth, including investment in AI and data capability, leadership

development and targeted upskilling to ensure colleagues can succeed

andsupport delivery of the Group strategy as markets change and evolve.

The Group has a strong focus on employee value proposition. It offers

competitive terms and conditions, benefits, and flexibility to foster

colleague engagement, which is monitored regularly through employee

engagement surveys that track colleague sentiment and enable prompt

intervention on areas of concern.

Risk management continued

82 Standard Life plc Annual Report and Accounts 2025

Strategic report

Financial Markets risk

The Group is exposed to adverse movements in the value of assets, liabilities Risk management focus

or liquidity caused by a deterioration in macro-economic conditions, downgrades,

counterparty failure and wider geopolitical instability

Impact Mitigating actions

Volatile market conditions and geopolitical disruption can affect the

certainty and timing of future cash flows and the long-term investment

performance for the Group and its customers.

It increases the risk of immediate financial loss and/or reduced capital,

solvency, and liquidity positions, which may constrain the Group’s ability

to execute strategic priorities.

Escalating regional conflicts, protectionist policies, and supply-chain

disruption can amplify inflationary pressures, impact creditworthiness,

and drive changes in market conditions, which in turn can impact the

pricing of PRT business, the Group’s market competitiveness, the ability

to deliver recurrent management actions and the effectiveness of

hedging strategies.

The Group operates within a well-defined risk appetite supported by clear

limits and regular monitoring of market, credit, and geopolitical exposures.

Through hedging unrewarded risks, the Group actively manages its position

to reduce sensitivity to market movements and preserve capital strength,

while maintaining flexibility to respond to changing conditions.

Scenario analysis and stress testing, informed by global developments,

supportongoing assessment of business model resilience and the feasibility

ofmanagement actions under different market environments. All of this is

supported by the hiring and retention of personnel with deep markets expertise

and investment in technology to understand the implications of market dynamics.

The Group operates a suite of controls over customer funds to ensure

exposure to market risk is maintained within the customer’s risk appetite.

These controls include regularly reviewing the strategic asset allocations of

customer funds, monitoring of external asset managers and associated fund

performance. In addition, proactively adjusting strategies or asset managers,

when we believe this can offer better risk-adjusted returns to customers.

Emerging technologies

Impact Mitigating actions

AI presents opportunities across our organisation. However,

itpresentsa range of risks, most notably a change in the

competitivelandscape, customer, and reputational harm.

Quantum computing also presents promising opportunities

formanyindustries; however, this may create risk to existing

encryptiontechniques.

The Group continues to develop and enhance its AI Framework to support

safe adoption of AI to deliver business benefits. This includes ensuring

controls are fit for purpose and in line with our standards.

The Group is assessing our encryption capabilities across all services and

creating a roadmap to achieve quantum safe encryption in line with

regulatory guidance and recommended timeline.

Nature risk

Impact Mitigating actions

Nature loss and ecosystem collapse presents a systemic risk to the

global financial system. It is complex and inherently interconnected with

other global risks such as climate change. The World Economic Forum

ranks nature loss and ecosystem collapse as the second most severe

global risk over the next 10 years.

Nature loss may pose a material financial risk for the Group due to our

exposure to nature-related risks through our investments, operations

and supplier base which depend upon the ecosystem services that

nature provides.

The Group has developed assessment methods to understand our potential

exposure to nature-related risks and support investment portfolio decisions

for both customers and shareholders.

The Group is taking action to reduce its potential exposure to nature-related

risk by integrating nature-related factors into its stewardship activity and

illiquid asset origination and portfolio monitoring.

The Group is undertaking further work on protecting our supply chain by

integrating nature into our procurement processes – with the ultimate aim

of enhancing operational resilience.

Emerging risks andopportunities

The Group’s Senior Management

and Board take emerging risks and

opportunities into account when

considering potential outcomes. This

determines if appropriate management

actions are in place to manage the risk

or take advantage of the opportunity.

Examples of key emerging risks

and opportunities discussed by

Senior Management and the

Board during 2025 are:

The Group maintains a comprehensive

library of emerging risks, which are

distinguished from the current risks by

the amount of available information

resulting in a higher level of uncertainty

as to how and when the risks will

crystallise and its impact to the Group.

83Standard Life plc Annual Report and Accounts 2025

Strategic report

Viability statement

In accordance with Provision 31 of the 2018 UK Corporate Governance

Code, the Board is required to conduct an assessment of the viability

of the Group over a specified time horizon.

Assessment process

In assessing the future viability of

the Group, the Board has defined

‘viability’ as maintaining the capability

to satisfy mandatory liabilities and

meet the recurring uses of capital.

In doing so, the Board considered

whether the definition of viability should

reflect the success of the Group in

delivering against its strategic priority

to invest in the growth of the business

on an organic and inorganic basis. It

concluded that any such investment

needs to comply with the Group’s capital

allocation framework and risk appetite,

and that the Board retains flexibility

to manage the level of investment to

support the Group’s strategic priorities.

In the absence of new business growth,

the Group maintains a significant cash

generation capacity from its in-force

business which remains resilient under

stress, supporting longer-term viability.

The Board has determined that the

three-year time horizon to December

2028 is an appropriate period for the

assessment which aligns to the period

covered by the Group’s latest Board-

approved Strategic Financial Business

Plan (‘the Plan’), and which includes

the 2026 period for which the Group

has established its external targets.

In making its assessment and

assessing the prospects of the Group

over the short, medium and longer

term, the Board considered a large

range of information including:

• The Group’s strategic and operational

plans as set out in the Plan, approved

by the Board in December 2025;

• The latest financial results for

theGroup;

• Financial projections of the Group’s

capital, liquidity and funding positions

over the viability assessment period.

These projections have considered

both base assumptions and severe

butplausible stress scenarios,

reflecting the major risks to which

theGroup is exposed;

• The results of wider stress and scenario

testing activity, including reverse stress

testing, capturing non-financial risks as

well as more onerous scenarios with a

low likelihood of occurrence;

• The operation of the Group’s Risk

Management Framework, including

anybreaches of risk appetite;

• The principal risks and uncertainties

impacting the Group, together with

anassessment of emerging risks that

may impact on the Group’s future

performance;

• The Own Risk and Solvency

Assessment process which provides

aforward-looking assessment of the

Group’s risk and capital profile as a

result of its business strategy, the Plan

and the overall risk environment; and

• An assessment of the wider operating

environment for the Group, including

legal, regulatory, political, climate and

competitive factors.

Assessment of viability

The Standard Life plc Plan is reviewed

and approved by the Board on an at

least annual basis and results in a set of

strategic priorities, detailed financial

forecasts across multi-year periods,

risk assessments and associated

resilience, and available contingent

actions. Those strategic priorities

are outlined in the Strategic Report

of the Group’s Annual Report and

Accounts, and progress against the Plan

is reviewed monthly by the Board.

The Board reviewed the results of stress

testing to assess viability under severe

but plausible scenarios, including three

adverse stresses as follows, which

are deemed to be representative of

the key financial risks to the Group:

1. Plausible economic downside stress

– a combined market stress broadly

equivalent to a 1 in 10 year event,

characterised by a broad deterioration

in financial conditions, including falls in

equities and property values, widening

credit spreads and a general tightening

of credit markets.

2. Lower than planned levels of cash and

capital generated by management

actions, aimed at assessing execution

risk; and

3. Plausible combined stress – which

considers market downside coupled

with delays in key transformation

programmes and migration-related

operational changes.

The calibration and assessment

of the stresses is informed by the

Group’s Solvency II Internal Model.

The projections take into account the

impact of any appropriate Solvency II

recalculation of transitional benefits

and allow for refinancing of certain

of the Group’s debt obligations. In

considering the projections, the

Board has assessed the availability of

mitigating actions to increase resilience.

Viability statement

84 Standard Life plc Annual Report and Accounts 2025

Strategic report

The scenarios were applied to the

Solvency II capital, liquidity and

funding positions of the Group, and

demonstrated that the Group could

continue to meet its mandatory

obligations, maintaining sufficient

headroom and without any breach to

regulatory capital requirements, while

continuing to track towards the delivery

of the Group’s strategic priorities.

Additional stress testing

In addition, through the ORSA, Business

Plan stress and scenario testing and

wider financial resilience processes

during the year, the Board has reviewed a

wide range of stress and scenario testing

which has provided additional insight

with regard to the defined viability

assessment period. The scope of this

testing covers the Group’s risk universe

and includes scenarios such as:

• Additional severe downside

economicscenarios with a low

likelihood of occurrence;

• Operational disruption or failure

ofkeythird party service providers;

• Cyber-attack, and resultant denial of

service to key systems or applications;

• Failure to execute and deliver key

change activities within the Group; and

• Climate related risks, including

thoserelated to a disorderly

climatetransition.

In doing so, the Board has considered the

results of reverse stress testing that has

been performed to analyse scenarios that

have a low probability but where, if they

occurred, have the potential to render

the business model unviable. Reverse

stress testing validates and improves,

where necessary, mitigating actions in

place to deal with threats to the Group’s

viability by starting at the point of

business failure and working backwards

to identify the sequence of events that

would lead to that outcome. It supports

the development of actions that can be

implemented now to avoid the failure.

The scenarios assessed under both

ORSA (including reverse stress testing)

and the stress and scenario testing

for the Business Plan demonstrated

that the Group had the ability to

withstand severe events as a result of

robust risk management and a range of

mitigating actions, thereby maintaining

its viability over the Plan period.

Risk assessment

The Board reviewed the Group’s principal

risks and uncertainties as set out on

pages 80 to 83 of the 2025 Annual

Report and Accounts and considered

the impacts of changes in the related

impact assessments and the mitigating

actions implemented. This included an

assessment of the potential impacts of

emerging risks on the Group’s business

during the viability assessment period.

As noted in the Risk Management section

of the Annual Report and Accounts,

the Group identifies, assesses and

manages risk through the operation

of its Risk Management Framework

(‘RMF’). The Board approves the RMF

and monitors its operation against

established risk appetites through

regular reporting that comes from

across the three lines of defence.

Whilst noting continued macroeconomic

uncertainty and an evolving political

and regulatory landscape, the

Board will continue to monitor risk

exposures relative to risk appetites

to ensure the risks are proactively

managed and do not present a material

threat to the Group’s viability.

2025 financial results

The latest financial results for the

Group as included within the 2025

Annual Report and Accounts have

been considered as part of the

assessment. Key factors included:

• The Group’s strong capital position

with a Solvency II surplus of £3.6 billion

and a Shareholder Capital Coverage

Ratio of 176%, providing significant

headroom above regulatory minimum

capital requirements and the Group’s

risk appetite;

• The resilience of the Group’s capital

position and cash generation to

movements in market factors, as

indicated in the sensitivity analysis

included on page 44, which is reflective

of the Group’s hedging approach; and

• Holding company cash of £846m at the

end of 2025, as well as access to the

Group’s undrawn £1.5 billion unsecured

revolving credit facility, provides

assurance over the Group’s ability to

meet mandatory obligations as they

fall due.

The impact of losses on an IFRS

basis were considered as part of the

assessment. It was noted that the

Group’s hedging approach prioritises

the protection of the Solvency II capital

position and therefore the dependable

delivery of future cash generation.

It is accepted that this results in

volatility in the IFRS metrics but as

the Board considers that IFRS metrics

only partially reflect the underlying

cash potential of the business which is

captured more fully under the Solvency

II cash and capital metrics this was not

considered to represent a material

threat to the Group’s viability.

Concluding statement

onviability

Based on the factors outlined above,

the output of the Group’s financial

projections and its resilience under

severe but plausible stressed conditions,

and the management of the Group’s

principal risks and associated mitigating

actions, the Board has a reasonable

expectation that the Group will be

able to continue in operation and

meet its liabilities as they fall due over

the three-year period of assessment

ending 31 December 2028.

85Standard Life plc Annual Report and Accounts 2025

Strategic report

Chair of the Group Board’s

introduction to governance

Dear Shareholder,

I am delighted to introduce our Corporate

governance report for 2025. During

the year, the Group Board continued

its oversight of the second year of

our 3-year strategic journey. There

have also been a number of Board and

governance changes highlighted below.

Governance

A key governance focus in 2025

was simplifying our Group and

Life Companies Board meetings to

support a collaborative and cohesive

approach to decision making and

governance while ensuring robust

agenda planning and appropriate

management of any potential conflicts.

A Joint Meeting Model was implemented

on 25 August 2025 for the Group and

Life Companies Boards, Nomination,

Audit and Risk Committees. The Group

Board Sustainability and Remuneration

Committees’ arrangements have not

changed. The Joint Meeting Model

comprises three segments: Life

Companies Board Directors meet first,

followed by a joint session between

the Group and Life Companies Boards’

Directors, concluding where required

with a meeting of the Group Board

Directors only. This approach replaces

the previous structure where up to 80%

of agenda items were duplicated across

separate meetings. The new format

streamlines discussions, strengthens

governance, enhances efficiency,

and fosters meaningful dialogue.

There is greater onus on the Chair of

these meetings to manage conflicts

of interest and ensure an increased

number of Directors are given the

appropriate opportunity to challenge,

but it has encouraged cross-Board

understanding and reduced siloed

working. Directors from both Boards

have welcomed the more cohesive

and inclusive meeting structure.

Joint private sessions and Board dinners

are also now held, giving all Directors an

opportunity to build relationships and

discuss matters outside the boardroom.

Standard Life plc

The Group Board was proud to announce

the Company’s name change from

Phoenix Group Holdings plc to Standard

Life plc on 24 February 2026. The ticker

atthe London Stock Exchange has

nowchanged to SDLF. This change has

brought the Standard Life brand to

theforefront of our business, further

supporting our vision to become the UK’s

leading retirement savings and income

business and championing the belief that

everyone’s journeys to and through

retirement can be better.

Simplifying and

strengthening

governance

Sir Nicholas Lyons

Chair of the Group Board

Board highlights 2025

Board activities during 2025

Read more on page 94

86 Standard Life plc Annual Report and Accounts 2025

Corporate governance

2026 priorities

During 2026, the Group Board intends to focus on:

• Monitoring the Joint Meeting Model to continue

to strengthen governanceand improve efficiency.

• Supporting the continued embedding of our established culture

andTheBigThree in the context of the Standard Life plc rebrand.

• Continuing the open and transparent relationship with the

regulators andother stakeholders such as our customers.

Board activities during 2025

The Group Board has recommended

aFinal dividend of 28.05 pence per

sharein line with its progressive and

sustainable dividend policy, bringing the

total 2025dividend to 55.40 pence per

share. Conflicts of interest are carefully

managed when the dividend is reviewed,

approved and recommended by the Life

Companies Board to the Group Board

Risk Committee, which recommends it to

the Group Board before its final approval

for payment to our shareholders.

The Group Board continues to prioritise

strong relationships with UK and

overseas regulators. Updates on this

areprovided by the Group Chief Risk

Officer (‘CRO’) and Head of Regulatory

Relationships, providing insights on

regulatory views and strategic impact.

Artificial Intelligence (‘AI’) and cyber

security are priority areas for both

Boards. Emerging risks now include

emerging technologies, covering both

AIand quantum risks. Standard Life

takes its oversight and management of

these matters seriously. AI will be applied

across our business, technology, data

and people. AI-related risk, including

the investment-focused ‘AI bubble’

highlighted in H2 2025, will continue to

be monitored and challenged robustly

by the Board. To strengthen oversight,

aDigital Advisory Group (‘DAG’) will

be established in 2026, comprising

of both Group and Life Companies

Non-Executive Directors, to provide

expert guidance and challenge on

items such as the Group’s AI strategy.

Board changes

Sherry Coutu was appointed as a Director

of the Group Board on 1 May 2025 and

Chair of the Group Board Remuneration

Committee on 1 July 2025. She replaced

Nicholas Shott who retired from the Group

Board on 30 June 2025 having served

nine years. Sherry’s biography on page 90

outlines her many years of remuneration

committee chair experience. Further

information on Sherry Coutu’s

induction is available on page 117.

Belinda Richards retired from the

GroupBoard on 24 August 2025, having

served for eight and a half years, and

Siobhan Boylan replaced David Scott on

1 September 2025 as the Shareholder

Nominated Director representative for

Aberdeen Group plc.

With the implementation of the Joint

Meeting Model, two Directors were

appointed as Dual Directors to the Group

Board and the Life Companies Board.

On25 August 2025, following regulatory

approval, Mark Gregory was appointed

as a member of the Life Companies

Board and assumed the role of Chair

of the Risk Committee on both Boards.

Onthe same date, Karin Cook joined the

Group Board as an Independent Non-

Executive Director. Further information

on KarinCook’s induction is available

on page 117. In 2026, Nic Nicandrou will

become Dual CFO of the Group and

Life Companies Boards. This is in line

with Andy Briggs’ role as Dual CEO.

Rosie Harris was appointed as Chair of

the Life Companies Board on 25 August

2025 and now attends the Group Board

Remuneration Committee, bringing not

only a Consumer Duty lens as the Group’s

Consumer Duty Champion, but a wider

Life Companies focus to key discussions.

See the Directors’ Remuneration

report on page 136

Board performance review

The 2025 Board performance review was

facilitated externally by Ffion Hague of

Independent Board Evaluation (‘IBE’).

Anexternal consultant was chosen

to assess our transition to the Joint

Meeting Model. This engagement is

forathree-year term while we continue

to embed and evolve the model.

Annual General Meeting (‘AGM’)

Standard Life plc’s AGM will be held

on 14 May 2026 at Floor 9, 20 Old

Bailey, London EC4M 7AN. The AGM

will be held asaphysical meeting, in

line with the Institutional Shareholder

Services Inc. (‘ISS’) definition. Following

shareholder approval of updated Articles

of Association (the ‘Articles’) at the 2025

AGM, hybrid meetings are now permitted

by the Company. However, physical

meetings will continue, allowing direct

engagement with shareholders, which

the Group Board values. Hybrid AGMs will

only be implemented if government

restrictions mean that a physical meeting

cannot reasonably be held. Full details of

the 2025 AGM will be found in the Notice

ofMeeting, to be published shortly and

made available on our website. The Group

Board appreciates its shareholders’

strong support in 2025 and looks forward

to continued engagement in 2026.

Sir Nicholas Lyons

Chair of the Group Board

Shareholder and stakeholder engagement

The following engagement with shareholders took place during 2025

and includes the 2026 Chair’s Roadshow:

Number of meetings Topic Outcome

Chair of the

Group Board

5 meetings covering

45.66% of the register

were held.

Share price,

newGroup CFO

performance

Group CFO appointment welcomed

by shareholders.

2026 Group

Board Chair’s

Roadshow

13 meetings covering

56.13% of the register

were held.

Stewardship,

Strategy and ESG

Direct investor feedback received

through open and transparent

engagement has been relayed

to the Board.

Chair of the

Group Board

Remuneration

Committee

34 shareholders engaged

through the circulation

of detailed information

to 75% of the register.

21 shareholders requested

a meeting covering 57.82%

of the register.

Proposed 2026

Remuneration

Policy

Retained TSR (excl. Investment

Trusts) benchmark vs a peer group.

Proxy advisers and ESG rating

agencies feedback within the

Directors’ Remuneration report

(see page 136).

87Standard Life plc Annual Report and Accounts 2025

Corporate governance

Board leadership and Company purpose

Our Board of Directors

Leading from

the top to drive

governance and

a clear purpose

The Group Board comprises the Chair of the Group

Board, the Group Chief Executive Officer, the Group

Chief Financial Officer, one Aberdeen Group plc

(‘Aberdeen’) Nominated Director, one MS&AD

Insurance Group Holdings, Inc. (‘MS&AD’) Nominated

Director and seven Independent Non-Executive

Directors, including two Dual Directors.

Career and experience

Nicholas has wide-ranging experience

across the financial services industry,

both in executive and non-executive

roles. He started his career at

Morgan Guaranty Trust Company

of New York UK (later JP Morgan),

where he held various roles in Debt

and Equity Capital Markets and

then in Mergers & Acquisitions. He

later moved to Salomon Brothers

and then to Lehman Brothers

International Limited where he

was a Managing Director and

Co-Head of their European Financial

Institutions Group and then Global

Co-Head of Recruitment, Training

and Career Development for the

whole of Lehman Brothers.

Nicholas has extensive Non-Executive

Director (‘NED’) experience,

including Chair of Miller Insurance

Services LLP, Senior Independent

Director of Pension Insurance

Corporation plc and Catlin Group

Limited and NED of Friends Life

Group Limited and Convex Group

Limited. Nicholas is a member of

the Chartered Insurance Institute.

Key skills and competencies

• Seasoned business leader with

experience and understanding

ofinsurance and the financial

services industry, including the

regulatory environment.

• Strong communicator, bringing a

sharp focus to people leadership,

succession planning and

development.

• Experience in the governance of

large-scale business operations,

leading mergers and acquisitions

and managing complex projects

which are skills key to the

fulfilment of Standard Life’s

visionand purpose supporting

hisrole as an experienced Chair

ofthe Group Board.

Current external

appointments

NED at Convex Group Limited and

Alderman in the City of London.

Sir Nicholas Lyons

Chair of the Group Board

Appointed:

31 October 2018 to

1 September 2022, re-appointed

on 1 December 2023

Committee:

Chair of the Group Board

Nomination Committee

2025 Group Board changes

• Sherry Coutu was appointed to the Group Board on 1 May 2025.

• Nicholas Shott retired from the Group Board on 30 June 2025.

• Belinda Richards retired from the Group Board

on 24 August 2025.

• Karin Cook was appointed to the Group Board on

25 August 2025 as part of her role as Dual Director.

• Mark Gregory was appointed to the Life Companies Board

on 25 August as part of his role as a Dual Director.

• David Scott retired from the Group Board on 31 August 2025.

• Siobhan Boylan was appointed to the Group Board

on 1 September 2025.

Committee membership key

Audit

Nomination

Remuneration

Risk

Sustainability

88 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Career and experience

Andy joined the Company in 2020,

bringing over 30 years of experience

in the insurance industry. He has held

senior executive roles across multiple

business areas within the industry,

including CEO of UK Insurance and

Global Life and Health at Aviva plc,

CEO of Friends Life Group Limited,

Managing Director of Scottish

Widows, CEO of the Retirement

Income Division at Prudential plc and

Chair and President of the Association

of British Insurers (‘ABI’). Andy is a

Fellow of the Institute of Actuaries.

Key skills and competencies

• Sound executive leadership and a

considered approach to strategy,

demonstrated through continued

delivery of the Company’s

operating model. Strong history

ofhigh-profile M&A work in his

previous roles.

• Broad knowledge of the global

insurance industry, which helps

inform views on long-term

strategicdirection.

• Proactive approach to

understanding stakeholder

priorities, which closely

alignstothe Company’s core

social purpose and strategy,

includingwork on developing

initiatives such as financial and

digitalinclusion.

Current external

appointments

President of the ABI and a

member of the Business in the

Community Leadership Council.

Career and experience

Nicolaos joined the Company in

December 2024, bringing over 30

years of experience in financial

services. He most recently held the

position of Chief Executive Officer at

Prudential Asia & Africa, and prior to

this, was Group CFO of Prudential plc.

Nicolaos has held several senior

finance and executive leadership roles

during his career, including CFO of

Aviva UK Life, Group Financial Control

Director of Aviva plc, and Chair of

the European Insurance Industry

CFO Forum. He is a Non-Executive

Director (‘NED’) of Kingdom of Saudi

Arabia Insurance Authority and a

member of the Institute of Chartered

Accountants of England & Wales.

Key skills and competencies

• Experienced in leading significant

transformational and infrastructure

projects which assists with

oversight of the implementation

of the Company’s evolved

financialframework, driving

progress towards being the UK’s

leadingretirement savings and

income business.

• Detailed knowledge of financial

markets as leader of the Company’s

financial strategy, supporting the

achievement of strong financial

results in line with the financial

framework of Cash, Capital

andEarnings.

• Extensive financial services

experience and strong awareness

of the global life insurance sector,

enabling informed contributions to

discussions on long-term strategy.

Current external

appointments

NED and member of the

AuditCommittee of Kingdom of

SaudiArabia Insurance Authority.

Career and experience

Karen has over 30 years of financial

services experience. She has held a

number of senior executive roles,

including Chief Executive Officer of

Aspen UK (comprising the principal

insurance and reinsurance companies

of Aspen Insurance Holdings),

Principal of MMC Capital Limited

(now Stonepoint Capital LLC), and

Director of Corporate Development

of GE Capital Europe Limited.

Karen has significant Non-Executive

Director (‘NED’) experience, including

as Chair of the Remuneration

Committee at Admiral Group plc,

aformer Council member and Chair

of the Investment Committee at

Lloyd’s of London, and NED and

SID at Great Portland Estates plc.

Key skills and competencies

• Significant experience in the

insurance industry, supporting

oversight of the Company’s

activities and ensuring alignment

with market expectations and

stakeholder needs.

• A strong background in strategic

planning and corporate

development, including M&A,

facilitating informed oversight

and constructive challenge of the

development andexecution of

the Company’s growth strategy.

• A balanced sounding board, with

significant leadership experience

and understanding of the

Company allowing the provision of

qualified support to the Chair of

the Group Board and the Group

Board as awhole in the role of SID.

Current external

appointments

NED and Chair of the Remuneration

Committee at Admiral Group plc,

Board member and Chair of the

Audit and Risk Committee of the

TMF Group, SID and Chair of the

Audit and Risk Committees at Miller

Insurance Services LLP and Ben

Nevis Cleanco Ltd (the Miller broking

group), SID at Great Portland Estates

plc, NED at Hamilton Insurance

Group Ltd, Adviser at Cytora Limited,

Trustee of Wellbeing of Women

and Governor of Bute House

Preparatory School for Girls Ltd.

Career and experience

Siobhan is the appointed

representative of one of the

Company’s major shareholders,

Aberdeen Group plc (‘Aberdeen’).

She has over 30 years’ experience

and significant knowledge across

the financial services sector and as

an executive director. Siobhan is

currently Aberdeen’s Chief Financial

Officer (‘CFO’), having joined from

Coutts & Co, the private banking

arm of NatWest Group, where she

was also CFO. Prior to this, she was

CFO of Brewin Dolphin (a FTSE 250

constituent until its acquisition by

Royal Bank of Canada in 2022),

CFO of Legal & General Investment

Management Limited, the asset

management subsidiary of Legal

& General Group plc and held

various finance roles at Aviva plc.

Siobhan is a member of the

Institute of Chartered Accountants

in England & Wales and has

previous NED experience as NED

of Jupiter Fund Management plc.

Key skills and competencies

• Brings broad financial leadership

and strong experience across

leading financial services

organisations, offering practical

insight, sound judgement and

deepsector knowledge to support

board-level decision making.

• Extensive leadership background

within financial services

organisations, providing valuable

appreciation of industry dynamics

and contributing to informed

challenge during board discussions.

Current external

appointments

Chief Financial Officer of

Aberdeen Group plc and Director

at Interactive Investor Limited.

Andy Briggs MBE

Group Chief Executive Officer

(‘CEO’)

Appointed:

10 February 2020

Nicolaos Nicandrou

Group Chief Financial Officer

(‘CFO’)

Appointed:

2 December 2024

Committee:

Chair of the Group Board

Sustainability Committee

Shareholder Nominated Director

Karen Green

Senior Independent

Director (‘SID’)

Appointed:

1 July 2017

Siobhan Boylan

Non-Executive Director

(‘NED’)

Appointed:

1 September 2025

89Standard Life plc Annual Report and Accounts 2025

Corporate governance

Board leadership and Company purpose continued

Our Board of Directors

Career and experience

Eleanor has a wealth of experience in

investment and asset management.

Most recently she was Chief

Investment Officer of Lloyd’s of

London. Prior to this, Eleanor held

several senior roles at Legal & General

plc, including Chief Operating Officer

of Legal & General Capital, Managing

Director of Direct Investments and

Real Assets, and Chief Investment

Officer of Legal & General

Retirement. Eleanor previously

served as Chair of Lloyd’s Investment

Platform ICAV and has held executive

directorships as Chair of Legal &

General Investment Management’s

Alternative Investment Fund

Manager and as Director of Legal

& General’s Single-Family Build-to-

Rent business. Eleanor is a Fellow

of the Institute of Actuaries.

Key skills and competencies

• Seasoned investment

professional, experienced

inleading high-performing

investment teams and setting

investment strategy for both

insurance and pension funds.

• Deep understanding of the life

insurance sector and the

investment approaches that

underpin those businesses,

bringing an external perspective

and supporting the delivery

ofrobust, constructive

challengeand guidance

duringboard discussions.

Current external

appointments

Director at ReMarkitMe Ltd.

Career and experience

Karin has over 30 years’ experience

in financial services. Her experience

spans across retail, commercial

and investment banking, as well as

financial advice, wealth management

and insurance. Karin brings customer-

focused, digital, operational and

transformation expertise from several

leadership roles. Most recently, Karin

served as Chief Operating Officer

ofQuilter plc. Prior to this, she held

anumber of senior executive roles at

Lloyds Banking Group plc, including

Director of Group Operations/

Services and Chief Operating Officer

– Commercial Banking and at HSBC

Bank plc including as Global Chief

Operating Officer – HSBC Private

Bank. Karin’s NED experience includes

NED of NatWest Holdings Limited,

NED of the Group’s Life Companies

and Chair of SunLife Limited.

Karin is committed to Diversity

Equity & Inclusion (‘DE&I’) and has

been recognised in the LGBT Great’s

Top 50 Executive Allies, featured

on the FT OUTstanding LGBT

Role Model list, and was named

Stonewall Champion of the Year.

Key skills and competencies

• Deep knowledge and

understanding of the Group’s

LifeCompanies, providing insight

andperspective to Group Board

discussions and adding value as

aDual NED, while maintaining

herindependence.

• Knowledge of running large global

operational and technology teams,

delivering major strategic change,

including technology-enabled

programmes and transformations,

supporting the strategic objectives

of the Company.

Current external

appointments

Chair of SunLife Limited and NED of

NatWest Holdings Limited, National

Westminster Bank Public Limited

Company and The Royal Bank of

Scotland Public Limited Company

(neither of which are UK listed).

Career and experience

Sherry has a wealth of businessand

entrepreneurial experience, having

founded several technology

companies and invested in both tech

start-up companies and venture capital

firms. Throughout her career, Sherry

has held senior leadership positions

including Chief Executive Officer at

Interactive Investor International plc

and UK Managing Director at ISI

Emerging Markets Group and has

supported numerous companies in

their transformation journeys.

Sherry has significant experience

as a NED from a combination of

technology, investment, innovation,

education and financial services

organisations that empower

their customers. Her experience

includes roles as NED at London

Stock Exchange Group plc, Senior

Independent Director (‘SID’) and Chair

of the Remuneration Committee at

RM plc and Raspberry PI and NED and

Chair of the Remuneration Committee

at Pearson plc and Zoopla plc (prior

to its acquisition by private equity).

Key skills and competencies

• Seasoned remuneration

committee chair with experience

indifferent industries and

regulated environments which

enables well-informed and

productive discussions at the

Group Board Remuneration

Committee, while always being

mindful of the Company’s

stakeholders.

• Deep understanding of the role

posed by technology, Artificial

Intelligence and cyber within the

business environment, which offers

a unique insight into the ways in

which the Group can capitalise on

opportunities and keep abreast

ofrisks while navigating a rapidly

changing digital landscape for

ourcustomers.

Current external

appointments

NED and Chair of the Remuneration

Committee at Pearson plc, SID

and Chair of the Remuneration

Committee at Raspberry Pi and Chair

of Trustees at Founders4Schools.

Career and experience

Mark brings 25 years of experience

in the financial services industry.

Most recently, Mark served as Chief

Executive Officer (‘CEO’) of Merian

Global Investors Limited (‘Merian’).

Preceding this, he held roles at

Legal & General Group plc including

Group Chief Financial Officer, CEO

of Savings and Managing Director

of With Profits, at Asda Group plc as

the Divisional Director for Finance

and the Business Development

Director, and at Kingfisher plc

as a Senior Financial Analyst.

His previous NED experience consists

of roles as NED and Chair of the Risk

Committee at Direct Line Insurance

Group plc, NED and Chair of the

Remuneration Committee at Entain

plc and NED at Merian and the

Group’s Life Companies

. Mark is an

associate of the Institute of Chartered

Accountants in England & Wales.

Key skills and competencies

• A wealth of executive finance

experience and acumen and a

deep knowledge of the insurance

industry, particularly life and

general insurance, which

contribute to his effectiveness

asChair of the Group Board

andLife Companies Board Risk

Committees and a member of the

Group Board Audit Committee.

• Highly qualified to appraise

strategy development and

execution, having led corporate

projects and transactions with

added appreciation of the

retailsector andcustomer

serviceactivity.

• Valuable experience in

establishing and delivering

strategy while managing risk

appetite and compliance, which

contributes to hiseffectiveness

asChair of the Group and Life

Companies RiskCommittees.

Current external

appointments

Director of Westdown Park

Management Company Limited.

Eleanor Bucks

Independent Non-Executive

Director (‘NED’)

Appointed:

1 December 2023

Karin Cook

Dual Independent

Non-Executive Director (‘NED’)

Appointed:

25 August 2025

Sherry Coutu CBE

Independent Non-Executive

Director (‘NED’)

Appointed:

1 May 2025

Mark Gregory

Dual Independent

Non-Executive Director (‘NED’)

Appointed:

1 April 2023

Committee:

Chair of the Group Board and Life

Companies Board Risk Committees

Committee:

Chair of the Group Board

RemunerationCommittee

Committee:

1. The term ‘Life Companies’ refers

collectively to the Group’s insurance

subsidiaries: Phoenix Life CA Limited,

Phoenix Life Limited, ReAssure Life

Limited, ReAssure Limited and

Standard Life Assurance Limited.

90 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Hiroyuki Iioka

Non-Executive Director (‘NED’)

Appointed:

23 July 2020

Katie Murray

Independent Non-Executive

Director (‘NED’)

Appointed:

1 April 2022

Maggie Semple OBE

Independent Non-Executive

Director (‘NED’)

Appointed:

1 June 2022

Career and experience

Hiroyuki serves as the appointed

representative of one of the

Company’s major shareholders,

MS&AD Insurance Group Holdings

Inc. (‘MS&AD’). He is an MBA-qualified

professional with over 38 years

of experience and is currently the

Senior Advisor for MSIG Corporate

Services (Europe) Limited. Previously

he was Senior General Manager

for the International Business

Planning Department at MS&AD,

General Manager for the Asian Life

Insurance Business Department

at Mitsui Sumitomo Insurance

Company Limited (Japan), and

Assistant General Manager for MSIG

Holdings (Europe) Limited (UK).

Hiroyuki’s NED experience includes

roles as NED of ReAssure Group

plc and Mitsui Sumitomo Insurance

(London Management) Limited

(UK), as well as an Alternate NED

of Challenger Limited (Australia).

Hiroyuki is a Chartered Member

of the Securities Analysts

Association of Japan and a Certified

International Investment Analyst.

Key skills and competencies

• Commercial business leader,

providing an international

business perspective, with strong

global insurance and financial

services industry experience.

• Responsible for general

management, including managing

efficient and effective operations

and business development within

the financial services industry.

Current external

appointments

Senior Advisor for MSIG Corporate

Services (Europe) Limited, a UK

subsidiary of MS&AD Insurance

Group Holdings, Inc.

Career and experience

Katie has over 30 years of experience

gained across the financial services

industry and is currently Group Chief

Financial Officer (‘CFO’) of NatWest

Group plc, having also acted as

Deputy Group CFO. Prior to this, Katie

spent several years at Old Mutual plc,

where she held senior executive roles

including Group Finance Director

of Old Mutual Emerging Markets,

Director of Finance – Group Chief

Accountant and Head of Group

Planning and Analysis. She was also

aSenior Audit Manager at KPMG LLP.

Katie is a member of the Institute of

Chartered Accountants in Scotland.

Key skills and competencies

• Vast financial services experience

positions her to provide valuable

and technical input in board

discussions and in her capacity

asChair of the Group Board

andChair of the Joint Group

Board and Life Companies Board

AuditCommittee.

• Current business leader

withrecent and relevant

financialexperience and

deepunderstanding of

industrycomplexities.

• Valuable knowledge and

executive director experience

within global financial services

organisations.

• Plays an active role in the

development and reporting

forclimate reporting across

thefinancial services sector.

Current external

appointments

Group Chief Financial Officer

of NatWest Group plc.

Career and experience

Maggie has over 30 years experience

of working internationally in the

private and public sectors. Formerly

an academic, she began advising

governments on large-scale cultural

transformation projects and was a

member of several UK Government

and European task groups. She has

been a global senior management

consultant and has worked in the

energy, media, technology, and

legal sectors. Maggie was a member

of the King’s Counsel Selection

Panel, a Civil Service Commissioner

and Director of the Learning

Experience at the New Millennium

Experience Company. Maggie is an

author and owner of a professional

services management company,

and a luxury consumer business.

Maggie’s NED experience includes

roles as NED of PwC Business

Restructuring Services, JN Bank UK

Limited, McDonald’s Restaurants

Limited, University of Cambridge HR

Committee, as well as the University

of Cambridge Ambassador of the

Black British Voices Project.

Key skills and competencies

• Combines deep experience and

passion for sustainability, ethics

and inclusivity bringing a breadth

ofknowledge across the broad

Environmental, Social and

Governance (‘ESG’)agenda.

Informs the development of

operations and strategy in this

area, while also drawing on

extensive experience in cultural

transformation and customer

insight, with a deep

understanding of developing

successful businesses through

thelens of its people.

• Brings a strong sense of social

purpose and depth of perspective

toboard considerations and

distinguished stakeholder

engagement with a highly

personable style, as demonstrated

in her role as DNED.

Current external

appointments

NED of Crest Nicholson Holdings plc.

Committee:

Designated NED for

WorkforceEngagement (‘DNED’)

Committee:

Chair of the Group Board

AuditCommittee

Shareholder Nominated Director

Our business, led

bythe Executive

Committee (‘ExCo’)

The Executive

Management of the

Group is led by the Group

CEO, who is supported

bythe ExCo. During 2025,

the ExCo played a key role

in driving Standard Life’s

year of significant

progress, striving to help

people secure a life of

possibilities. Career and

experience details for

each member of the ExCo

can be found on:

www.standardlifeplc.com

Andy Briggs

Group Chief

Executive Officer

Nicolaos Nicandrou

Group Chief

FinancialOfficer

Angela Byrne

Chief Executive Officer,

Pensions & Savings

Arlene Cairns

Life Chief Financial

Officer& Group

Performance Director

Claire Hawkins

Director of Corporate

Affairs & Brand

Brid Meaney

Group Chief Risk Officer

Jackie Noakes

Group Chief

OperatingOfficer

Vanessa Swanton

Group Chief Audit Officer

Sara Thompson

Group Chief People

Officer

Quentin Zentner

Group General Counsel

91Standard Life plc Annual Report and Accounts 2025

Corporate governance

Board leadership and Company purpose continued

UK Corporate Governance Code

Compliance with the UK Corporate Governance Code 2024 (the ‘2024 Code’)

The Group Board is committed to maintaining high standards of corporate governance. For the year ended 31 December 2025,

the Group Board considers that Standard Life plc applied the Principles and complied with the Provisions of the 2024 Code that

were in force at that date. In accordance with UKLR 6.6.6(5), the table below highlights where examples of compliance can be

found within this Annual Report.

Board leadership and Company purpose

A. Board leadership and long-term success Pages 88 to 91

B. Purpose, values, strategy and culture Pages 98 to 99

C. Board decisions and outcomes Pages 97, 112, 122, 130

and 132

D. Stakeholder engagement Pages 100 to 103

E. Wider workforce considerations Pages 98 to 99, 100 to

103, 104 to 105 and 122

Division of responsibilities

F. Role of the Chair Page 93

G. Board composition and

division of responsibilities

Pages 88 to 91, 93 to 95

H. Directors’ responsibilities

and time commitment

Pages 96 and 115

I. Support information and resources

available to the Board

Page 95

Composition, succession and evaluation

J. Appointments, succession planning

and diversity considerations

Pages 76, 110 to 115

and118

K. Board skills, experience and knowledge Pages 88 to 91, 113 and 118

to 119

L. Board performance review Pages 106 to 107

Audit, risk and internal control

M. Audit independence and effectiveness Pages 120 to 126

N. Fair, balanced and understandable

assessment of company’s position

and prospects

Pages 84 to 85, 120 to126,

176 to 181

O. Risk management and internal controls Pages 78 to 79, 80 to 83,

127 to 130

Remuneration

P. Remuneration alignment to strategy,

company purpose and values

Pages 138 to 175

Q. Executive and senior management

remuneration

Pages 138 to 175

R. Independent judgement and discretion

whenauthorising remuneration outcomes

Pages 136 to 137 and

138 to 175

Areas for enhancement

Progress made during 2025

In the Group’s Full Year 2024 Annual Report, two areas of enhancement were identified. The below table sets out the actions taken

during 2025 to strengthen compliance with the 2024 Code.

Board leadership and Company purpose

Provision or Principle Enhancements during 2025

2. The Board should assess and monitor

culture and how the desired culture has

been embedded.

During 2025, the Group Board enhanced its oversight of culture through several key actions. The culture

dashboard, introduced in 2024, was updated and presented for periodic review by the Joint Group and

LifeCompanies Board and the ExCo. Maggie Semple, DNED, attended relevant ExCo meetings to monitor

how the desired culture had been embedded and provided quarterly updates, along with bi-annual

reflections, to the Joint Group and Life Companies Boards following engagement with the Colleague

Representation forum (‘CRF’). In addition, the Group’s Internal Auditfunction, together with external

support from Ernst&Young LLP, completed an independent review of the Group’s culture framework and

3-year culturestrategy. Findings were considered by the Joint Group and Life Companies Boards, and the

ExCo has committed to further amplifying culture initiatives in 2026 through site visits, optimising ways of

working to ensure cross-functional teams are aligned on enterprise-wide priorities and ensuring a culture

of psychological safety for all colleagues.

29. The Board should monitor and review the

effectiveness of the Company’s risk management

and internal control framework and a description

of how this has been done, along with details

regarding the effectiveness of the material

controls and action taken to improve any material

controls which have not operated effectively,

should be included in the Annual Report.

The Joint Group and Life Companies Boards continued to monitor the effectiveness of the risk

management and internal control framework through regular reporting from the Joint Group and

LifeCompanies Audit and Risk Committees. Further enhancements will be carried out on internal

controlsin 2026 so that the Board can confirm compliance with Provision 29 of the 2024 Code for

FullYear2026 reporting.

Focus areas for 2026

Provision or Principle Action currently undertaken Enhancements for 2026

21. There should be a formal and rigorous

annual review of the performance of the

board, its committees, the chair and individual

directors. The chair should commission

a regular externally facilitated board

performance review. In FTSE 350 companies

this should happen at least every three years.

During 2025, an external performance review facilitated by Ffion Hague

of IBE, assessing the effectiveness of the Group Board, its Committees and

the Chair of the Group Board was completed. Individual Director evaluations

were not undertaken as part of this review to allow for the embedding of

thenew Joint Meeting Model and to provide newly appointed Directors

sufficient time to settle into their roles.

During 2026, individual

Director evaluations will

be reinstated and will

form a key area of focus.

92 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Division of responsibilities

Division of responsibility on the Board

Division of responsibilities on the Group Board

Chair of the Group Board

(independent upon appointment)

• Leadership and effective operation of the Group Board.

• Leading the Group Board in driving the strategy, desired

culture and values of the Group. Assessing and monitoring

howthe Group culture has beenembedded.

• Setting the Group Board agenda, working with the Group

Company Secretary to ensure effective meetings.

• Leading, while ensuring effective challenge from all

members of the Group Board on all agenda items.

• Leading the development of and monitoring the effective

implementation of policies and procedures for the induction,

training and education sessions for the Group Board.

• Leading the highest standards of corporategovernance.

• Effective shareholder engagement.

• Ensuring an orderly succession process for the Group

CEOand the Group Board as a whole.

Independent Non-Executive Directors

• Assessing, challenging and monitoring Management’s

delivery of the strategy, within the risk and governance

structure set by the Group Board.

• Measuring, monitoring and assessing culture.

• Robustly challenging items brought to any Committee

they are a member of, applying their skillset and expertise

(seepages 88 to 91).

• Co-operating with regulators and any other applicable

regulatory authority.

• Dual Directors are appointed to both the Group and the

Life Companies Boards. Their conflicts ofinterest are

robustly managed by the Group Company Secretary and

are detailed on page 94.

Designated Non-Executive Director

for Workforce Engagement

In addition to the responsibilities of Independent

Non-Executive Directors, the DNED is responsible for:

• Developing an annual communication programme

withthe CRF to collate employees’ views.

• Acting as the primary Group Board feedback mechanism

between colleagues across the Group and the Board and

raising relevant matters, or issues of concern, highlighted

by engagement with theworkforce.

• Participating in ExCo and Life Companies Board meetings

when culture is discussed.

Shareholder Nominated Directors

(not independent in line with the 2024 Code)

• A relationship agreement between the Company and MS&AD

includes the right for MS&AD to appoint a representative

NED to the Group Board, provided that MS&AD continues

to hold 10% or more of the Company’sshares.

• A relationship agreement between the Company and

Aberdeen includes the right for Aberdeen to appoint a

representative NED to the Group Board, provided that

Aberdeen continues to hold 10% or more of the

Company’s shares.

Group Chief Financial Officer

• Overall responsibility for the financial management

andperformance of the Group.

• Leading on embedding strong financial governance,

integrity, and transparency throughout the Group.

• Operational matters relating to:

– financial strategy and planning;

– capital management, including liquidity and funding;

– financial risk management and internal controls;

– statutory and regulatory financial reporting;

– tax and treasury management;

– communication with investors, analysts, and

– regulators; and

– succession planning within the Finance function.

Full descriptions of the Group Board’s roles and

responsibilities are available on the

Company’swebsitewww.standardlifeplc.com

Senior Independent Director

• Acting as a sounding board for the Chair of the Group Board.

• Chairing Group Board meetings in the Chair’sabsence.

• Supporting on governance matters, including the annual

Board performance review and the Chair’s performance

review by the NEDs.

• Serving as an intermediary between theChair of the Group

Board and the other Executive Directors as necessary.

• Being available to shareholders whose concerns are

notresolved through the normal channels or when

suchchannels are inappropriate.

• Ensuring an orderly succession process for the Chair

of the Group Board.

Group Chief Executive Officer

• Overall performance and day-to-day management

oftheGroup.

• Leading on embedding the desired culture,

valuesandpurpose of the Group throughout.

• Operational matters relating to:

– business strategy and management;

– investment and financing;

– risk management and controls;

– recommending remuneration policies and succession

plans to the relevant Group Board Committees

foremployees belowExecutive Director level;

– regulation;

– sustainability;

– communication; and

– HR policies.

Clear roles and responsibilities to drive forward our purpose and strategy

The Directors understand their individual and collective responsibility to ensure the long-term success of the Company

and fulfil the Group’s purpose. The Group Board maintains a clear division of responsibilities, avoiding any

concentration of power or over-reliance on one individual. Director independence supports strong governance and

encourages diversity of thought and inclusion. All NEDs are considered independent, except for the Shareholder

Nominated Directors and the Chair of the Group Board, who was independent upon appointment.

93Standard Life plc Annual Report and Accounts 2025

Corporate governance

Division of responsibilities continued

Division of responsibility on the Board

Independence

During the year, the Group and

Life Companies Board Nomination

Committees continued to assess the

independence of the NEDs to ensure

that they were able to properly fulfil

their roles on their respective Boards

and provide constructive challenge

to the Executive Directors.

Conflicts of interest

A Conflicts of Interest Register is

maintained by the Group Company

Secretary. Under the Companies Act

2006, each Director has a duty to avoid

situations where they have, or may have,

a direct or indirect interest that conflicts

with the Company’s interests. Ifa

Director becomes aware of a potential

conflict, they must inform the Board

on which they sit immediately. That

Board may then authorise such conflicts

under the Company’s Articles, and any

authorisation is recorded in the Register,

along with the date of approval.

Each Director certifies annually that

the Register is accurate and completes

a questionnaire to confirm all conflicts

have been disclosed. From 2025,

the Register was presented to the

Group Board quarterly for review.

When considering authorisation,

* This change will take place in 2026 subject to regulatory approval.

onlynon-conflicted Directors may

participate in the discussion. A conflict

isauthorised only if the relevant Board

believes it will not affect its ability to

promote the Company’s long-term

success. The Board may also impose

conditions or limits on any authorisation.

Potential conflict situations are reviewed

and authorised, where applicable, at the

start of each Board meeting. Particular

care is taken regarding the Shareholder

Nominated Directors for Aberdeen and

MS&AD, and Dual Directors such as the

Group CEO and INEDs who are Dual

Directors of the Group and Life

Companies Boards.

Managing potential conflicts

As part of the implementation of a

Joint Meeting Model, the management

of potential conflicts of interest was

reviewed and an updated protocol

approved by the Group and Life

Companies Boards. It was decided that

Dual Directors will act in their capacity as

a Life Companies Director in line with the

table below. This ensures the majority of

Life Companies Directors are aligned to

the best interests of the Life Companies.

The Dual CEO will recuse himself from

voting at the subsidiary level, when

the other party is Standard Life plc.

Outside directorships

Executive Directors are encouraged to

serve as NEDs of external companies,

dependent upon time commitment

in accordance with the 2024 Code.

Andy Briggs is the President of the

ABI and a member of the Business in

theCommunity Leadership Council.

NicolaosNicandrou is a NED of Kingdom

of Saudi Arabia Insurance Authority.

Re-appointment of Directors

In accordance with the 2024 Code, all

Directors offer themselves individually

toshareholders for initial election or

re-election annually, unless retiring

immediately following the AGM.

Independent advice

All Directors have access to the advice

and services of the Group Company

Secretary to support their Board and

Committee responsibilities. They may

also seek independent professional

advice at the Group’s expense, although

none did so during 2025. The Group

provides insurance cover for legal actions

against Directors and has entered into

indemnities with them, as outlined in

the Directors’ report on page 177.

Role Life Companies Board Standard Life plc Board

Dual Directors Vote in their capacity as a Director of the Life

Companies, including on cash remittances.

Participate in discussions; recused from

decisions on intra-group loans between

theGroup and the LifeCompanies.

Can vote and be included on dividends paid

toshareholders of the Group.

Dual CEO Recused from voting, but may participate

in discussion.

Can vote and be included in decisions

for the Group.

Dual CFO* Vote in their capacity as CFO/a Director

ofthe Life Companies, including on

cashremittances.

Participate in discussion; recused from

decisions on intra-Group loans.

Can vote and be included on dividends

paid to shareholders of the Group.

Chief Actuary Presents all cash remittance papers at the

Group Board and Life Companies Board

RiskCommittees and the Group and Life

Companies Boards andis supported by a

Line 2 opinion.

94 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Our governance framework

The Group and Life Companies Boards provide strong challenge

to Management through a robust governance framework

enabling cohesion of our purpose, strategy, values and culture.

We maintain high standards of corporate governance

to enable the successful delivery of our strategy.

Group Board

Nomination

Committee

• Recommends Group

Board appointments.

• Reviews the

Group Board

and Committee

composition.*

• Reviews Board and

Senior Executive

succession planning.*

• Recommends Life

Companies Board

appointments.

• Oversees

nomination,

induction and

evaluation of

theGroup Board.

• Oversees the

diversity, equity

andinclusion of

theGroup Board

andsenior

appointments.*

• Monitors the Boards

in line with the

Group’s strategy and

Joint Meeting Model.*

Group Board

Remuneration

Committee

• Sets and reviews

the Group’s

remuneration

framework.

• Recommends

Executive Directors’

remuneration

andpolicy.

• Reviews Chair,

executive, Senior

Management and

SMF remuneration.

• Assesses the impact

of the Group CRO

report on any undue

risk taken by

individuals or the

Group andapplying

itsdiscretion.

• Reviews

performance- related

share schemes.

• Reviews wider

workforce

remuneration-

related policies.

Group Board

Audit

Committee

• Monitors the

integrity of

financial

reporting.

• Reviews

significant

reporting

judgements.

• Maintains an

appropriate

relationship

with the External

Auditor.

• Drives the

Internal Audit

programme

andany

recom-

mendations.*

• Reviews ESG

reporting.

The Group Board’s role is to provide leadership, promoting the long-term sustainable success of the Company,

generating value for shareholders and positively contributing to wider society, within a framework of prudent

and effective controls, which enables risk tobe assessed and managed. It establishes the Standard Life strategy,

leading the development and setting of its culture.

Our governance framework ensures that the Group Board is effective in both making decisions and

maintaining oversight of those Committees it delegates to. The Chair of each Group Board Committee reports

into the Group Board at the end of each Board meeting cycle.

Matters Reserved for the Group Board and each Committee’s Terms of Reference can be found at: www.standardlifeplc.com

Group Board Risk

Committee

• Reviews the risk

appetite and

high-level risk

matters ensuring

they are

appropriate for the

Group as awhole.*

• Assesses the

effectiveness of

theGroup’s Risk

Management

Framework

(‘RMF’).*

• Monitors

whistleblowing.*

• Oversees the

appropriateness of

the Group’s capital

and liquidity

requirements.*

• Assesses the

effectiveness

of the Group’s

internal controls

system.

Group Board

Sustainability

Committee

• Agrees and

monitors progress

against the

Sustainability

Strategy.

• Reviews ESG

reporting.

• Monitors culture,

and diversity,

equity and

inclusion (‘DE&I’).

• Oversees the

organisation’s

thought leadership

plans to advocate

across priority

sustainability

themes.

• Monitors progress

against the

Group’sNet Zero

Transition Plan.

Standard Life plc Board

Chair of the Group Board, Sir Nicholas Lyons

Committee report

on page 110

Committee report

on page 120

Committee report

on page 128

Committee report

on page 133

Committee report

on page 136

* These items were considered as part of theJoint Meeting Model, whichwas introduced with effect from August2025.

Board support

All Directors have access to the advice and services of the Group

Company Secretary to support the discharge of their duties and

on matters of governance. The Group Company Secretary

supports the Chair of the Group and Life Companies Boards,

ensuring that the Directors receive accurate, timely and clear

information. Appropriate policies, processes, time and resources

are available to the Board to ensure its effective and efficient

operation. The Group Company Secretary ensures that accurate

records of Board and Committee meetings are prepared on a

timely basis enabling unresolved concerns of Directors to be

duly recorded. No concerns were recorded during 2025.

The ExCo supports the Group CEO in discharging his responsibilities in managing Standard Life’s business day-to-day.

In addition, a Market Disclosure Committee reports into the Group CEO and has oversight of Standard Life’s

disclosure obligations in accordance with the Listing Rules.

95Standard Life plc Annual Report and Accounts 2025

Corporate governance

Planning Board meeting agendas

Division of responsibilities continued

2025 Group Board and Committee meeting attendance

The Group Board met formally seven

times during 2025, including a two-

day strategy setting meeting. The

Group Board regularly holds calls

outside of the formal schedule to

facilitate education sessions or provide

support or feedback to Management

on matters between meetings if

required. The NEDs met with the

Chair of the Group Board on at least

seven occasions without Executive

Directors present, which normally

takes place after each Board meeting.

The Group and Life Companies Chairs

work closely with the Group Company

Secretary and Group Executive

Directors to plan appropriate and

well-informed agendas, ensuring

time is given to strategic matters and

full challenge can be provided by the

Group and Life Companies Boards.

The following attendance table details all formal Group Board and Committee meetings held during 2025. Group Board members are

expected to attend all formal Group Board meetings with the aim of 100% attendance.

The Group Board Nomination Committee has confirmed its satisfaction with the time and commitment given to the Standard Life plc

Board and its Committees by all Directors.

Group Board

Audit

Committee

Group Board

Risk

Committee

Group Board

Remuneration

Committee

Group Board

Nomination

Committee

Group Board

Sustainability

Committee

Actual/Max Actual/Max Actual/Max Actual/Max Actual/Max Actual/Max

Chair

Sir Nicholas Lyons 7/7 – – – 7/7 –

Executive Directors

Andy Briggs (Group CEO) 7/7 – – – – –

Nicolaos Nicandrou (Group CFO) 7/7 – – – – –

Non-Executive Directors

Karen Green

7/7 – 6/7 7/7 7/7 5/5

Siobhan Boylan

3/3 – – – – –

Eleanor Bucks

7/7 3/3 5/5 – – –

Karin Cook

3/3 – 3/3 – – 2/2

Sherry Coutu

4/5 – – 5/5 3/3 –

Mark Gregory

7/7 8/8 7/7 – 7/7 –

Hiroyuki Iioka 7/7 – – – – –

Katie Murray 7/7 8/8 – – 7/7 –

Belinda Richards

4/4 – 4/4 4/4 – –

David Scott

4/4 – – – – –

Maggie Semple 7/7 – – 7/7 – 5/5

Nicholas Shott

4/4 4/5 – 4/4 4/4 3/3

1. Karen Green was unable to attend a Group Board Risk Committee meeting due to a funeral.

2. Siobhan Boylan was appointed as a Director of the Group Board on 1 September 2025.

3. Eleanor Bucks became a member of the Group Board Risk Committee on 1 April 2025 and the Group Board Audit Committee on 25 August 2025.

4. Karin Cook was appointed to the Group Board as a Dual Director on 25 August 2025, becoming a member of the Group Board Risk Committee and the Group Board Sustainability

Committee on this date.

5. Sherry Coutu was appointed as a Director of the Group Board and member of the Group Board Remuneration Committee on 1 May 2025 and became Chair of the Group Board

Remuneration Committee on 1 July 2025. Sherry became a member of the Group Board Nomination Committee on 1 July 2025. She was unable to attend a Group Board meeting

inJune due to an unforeseen clash of meetings scheduled prior to her joining the Group Board.

6. Mark Gregory was appointed as a Dual Director to the Life Companies Board on 25 August 2025. He also became Dual Chair of the Risk Committees by being appointed to the

LifeCompanies Board Risk Committee on that date. Mark Gregory became a member of the Group Board Remuneration Committee on 1 December 2025.

7. Belinda Richards retired from the Group Board on 24 August 2025.

8. David Scott retired from the Group Board on 31 August 2025.

9. Nicholas Shott retired from the Group Board on 30 June 2025. He was unable to attend a Group Board Audit Committee meeting due to an unforeseen clash of meetings.

• The Group Company Secretary meets

with the Group CEO and Group CFO

to discuss the first draft of the Board

agenda following the previous ExCo

meeting. Meeting agendas stem

from the annual planner, which is

approved by the Group Board at the

end of each year and sets out the

regular items and expected topics

ofdiscussion for the following

year.Management, following

consultation with the Group

Company Secretary, may add items

to the agenda which are notified

tothe Group CEO for approval.

• This agenda is then presented to

the Chair of the Group Board who

meets with both the Group CEO,

Group CFO and the Group Company

Secretary to provide feedback.

Actions from theprevious meeting,

the Board planner, strategic items

and stakeholder matters, for

example our regulatory

relationships or customers, are

discussed to ensure the agenda is

appropriately balanced.

• The Group Board planner is

reviewed in that meeting and

updated in anticipation of the next

agenda. Asimilar process is

followed by the Group Company

Secretary or their designate for

each of the Group Board

Committee meetings.

• The Group Company Secretary

follows a similar process including

the Chair of the Life Companies

Board for any related meetings

forthe Joint Meeting Model.

96 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Group Board activities

Meeting agendas are derived from

the annual planner which sets out the

recurring items and expected topics of

discussion for the following year. Each

meeting features a balanced and tailored

agenda, structured around governance,

strategy and financial performance,

alongside emerging matters.

During 2025, in addition to the scheduled

meetings, the Group Board calendar was

supplemented with informal updates

and calls as needed as well as an annual

two-day strategy session along with

additional education sessions. Details

of the education sessions delivered

can be found on pages 108 to 109.

Key activities during the year

Q1 Outcome

Approved the Full Year

2024 financial results,

Annual Report and

Accounts, revised external

targets, and Final

dividend

recommendation.

Reinforced financial transparency and

shareholder confidence by aligning

market expectations with internal

plans, confirming the credibility

of ambitious targets.

Approved the

Solvencyand Financial

Condition Report (‘SFCR’).

Confirmed regulatory compliance

and capital strength, with a 172%

shareholder coverage ratio

supported by robust controls

overreport preparation.

Received a deep dive

onthe Group’s ongoing

migrations.

Oversight of the Group’s migration

programme and movement to Wipro.

Approved to

recommendthe

Articlesof Association for

shareholder approvalat

the AGM.

Future-proofed governance

framework for Mandatory Direct

Credit, hybrid meetings (if government

restrictions mean that a physical

meeting cannot reasonably be held)

and change ofCompany name.

Approved (in principle)

theproposed change

tothe Group Brand

Strategy and change

ofCompany name.

Enhanced brand alignment and

strategic clarity by focusing

activitiesand investment on our

strongest brand; Standard Life.

Thissupports organic growth

andsimplifies the business for

customers and capital markets.

Q2 Outcome

Hosted the Group’s AGM. Delivered effective shareholder

engagement and developed

relationships ahead of the 2025

Remuneration Policy review.

Held a two-day strategy

meeting with members of

the Life Companies Board

to discuss the strategy of

the Group.

Improved alignment between the

Group Board and Life Companies

Boardby agreeing to a Joint Meeting

Model from 25 August 2025,

supporting strong governance

andmeeting efficiency.

Considered the

Technology and Data

Strategy (including

information security

andcyber security).

Strengthened the technology roadmap,

including the introduction ofa Board

Digital Advisory Group (‘DAG’) in 2026

to provide expert guidance and

challenge on behalf of the Boards on

cyber security and digital-related items.

Q3 Outcome

Approved the 2025

Interim financial results,

Interim dividend

recommendation, and

the announcement of

the proposed change

tothe Group brand

strategy and

Companyname.

Maintained transparency and

investor confidence while

signalling strategic progress

through brand alignment and

positioning for long-term growth.

Reviewed and approved

the strategy for the

Asset Management

and Retirement

Solutions functions.

Positioned business for growth

and innovation through strategic

projects, including the decision to

in-house c.£20bn of the Group’s

annuities portfolio.

Considered early drafts of

the Strategic Financial

Business Plan and 2026

Annual Operating Plan.

Introduced concise metrics for

remuneration alignment and

ensured robust financial targets.

Approved the

Consumer Duty

Annual Assessment.

Reinforced customer-centric

compliance culture.

Approved the ORSA. Enhanced risk management

andcapital planning.

Q4 Outcome

Approved the Strategic

Financial Business

Planand Annual

Operating Plan.

Confirmed forward-looking

financialresilience.

Approved a new

CapitalRisk Appetite

Framework.

Ensuring appropriate risk appetite.

Approved the Group’s

Position Statements on

tropical deforestation,

freshwater scarcity

andthe use of

carboncredits.

Enhanced sustainability

governanceand transparency

aligning commitments with

stakeholder expectations and

industry best practice.

Considered the roadmap

for compliance with

Provision 29 of the 2024

Code ahead of the YE26

controls attestation.

Confirmed roadmap for

Provision 29 compliance and agreed

enhanced evidence-based control

effectiveness reporting, including

dry runs through2026.

Strategic priorities key

Grow

Optimise

Enhance

The Chair of the Group Board and

Group Company Secretary work

closely together to finalise each

agenda which, across the year, consists

of the following regular reports:

• Group CEO report detailing business

updates covering people and culture,

brand and strategic priorities.

• Group CFO report detailing financial

performance, capital management

and liquidity updates.

• Group CIO updates on asset

management strategy and

performance.

• Group General Counsel updates

onlegal developments.

• Project Manager updates on key

transformation initiatives.

• Designated NED for Workforce

Engagement insights.

• Updates from the Chair of the Group

Board Audit Committee on audit

matters.

• Updates from the Chair of the Group

Board Risk Committee on risk and

compliance matters including

regulatory updates.

• Updates from the Chair of the

Group Board Sustainability

Committee on our sustainability

approach; People andPlanet.

• Updates from the Director of

Corporate Affairs & Brand on Investor

Relations and market engagement.

• Life Companies Board reports

detailingregulatory compliance

andConsumer Duty updates.

For more information see out

Strategic priorities on pages 28 to 35

97Standard Life plc Annual Report and Accounts 2025

Corporate governance

Division of responsibilities continued

Our culture

As the principal decision-making body

for the Group, the Group Board sets

the cultural tone for the organisation

through strong custodianship and

alignment with the Group’s intended

purpose, values and strategy.

Our desired culture:

The Big Three

In 2024, the Group introduced new

cultural principles for the Group. The Big

Three are the Group’s guiding principles

and the cultural strategy serves as a

roadmap to embed The Big Three into

everything we do, providing a framework

for optimum commercial growth

while maintaining focus on customer

outcomes. In 2024, the Group launched

a 3-year culture strategy to define,

implement and embed the desired

cultural outcomes and strengthen

alignment with strategic objectives.

This 3-year strategy will continue to be

monitored and challenged by the Joint

Group and Life Companies Boards, with

improvements and refinements made

using a dashboard of qualitative and

quantitative metrics, combining key

data points with colleague feedback

to provide a holistic view of cultural

performance against The Big Three.

The Big Three was launched with the

aim of being simple, clearly expressed

and relevant to all colleagues across

the Group, agnostic of brand. During

the year, the Company committed to

a significant change in its name and

The following pages explain how the Directors of the Group monitor and

assess the embeddedness of its desired culture across the organisation.

branding. This decision was carefully

considered by Management and subject

to robust challenge by the Group Board,

with particular focus on the potential

impact on culture and the continued

embeddedness of our core values. A

key question was whether a change in

identity could influence the way our

culture is lived and experienced across

the organisation. Feedback since the

announcement to rebrand has indicated

strong support for the move to a

brand that carries both heritage and

future relevance, with many colleagues

welcoming the opportunity to align

under one unified culture, reinforcing a

sense of shared purpose and belonging.

Embedding and

measuring our culture

The Group Board continues to prioritise

the monitoring and assessment

of organisational culture and its

integration across all areas of the

business. To support this, the Group

and Life Companies Boards receive

comprehensive data tracking progress

against The Big Three and other priority

action areas. During 2025, the Group and

Life Companies Boards strengthened

their oversight mechanisms by enhancing

the materials used to review and monitor

culture, including improvements to

reporting frameworks, cultural data

points such as exit interviews, and a

focus on evaluating the effectiveness of

DE&I initiatives across the workforce.

During the year, the Group’s Internal

Audit function, with external support

from Ernst Young LLP, conducted an

audit of the Group’s culture framework

and 3-year culture strategy. The results

of the audit were presented to the

Joint Group and Life Companies Board

meeting in November 2025. The audit

found that the 3-year culture strategy is

well designed, aligned with the Group’s

strategic objectives and supported by a

comprehensive plan that defines cultural

ambition and approach. Feedback from

participants indicated that culture

was fundamentally business and

leader led and it is therefore essential

that Senior Management continue to

model and reinforce cultural values

across the organisation while retaining

flexibility to prioritise cultural values

most relevant to their business areas.

As such, the ExCo has committed to

further amplifying the culture in 2026

through site visits, optimising ways

of working to ensure cross-functional

teams are aligned on enterprise-wide

priorities and ensuring a culture of

psychological safety for all colleagues.

As part of our commitment to fostering

a culture of transparency and trust,

the Group has strengthened its Speak

Up (Whistleblowing) Framework by

expanding the dedicated team. This

enhancement provides greater support

and structure for colleagues who

wish to raise concerns, reinforcing

confidence in our reporting mechanisms

and embedding our desired culture.

The Big Three

We put our

customers first

We aim high We work

together

98 Standard Life plc Annual Report and Accounts 2025

Corporate governance

How the Group Board and Committees monitor and assess culture

Board performance review

The annual Board performance

review assesses both the

performance as a whole and

individual elements, such as

measuring how well the Group

Board promotes the Group’s culture,

embodies the Group’s values and

continues to set a clear cultural

‘tone from the top’. The Group

Board Nomination Committee

advises the Group Board on

succession planning, ensuring that

appropriate candidates are chosen

and the desired culture is preserved.

Workforce policies

Workforce policies support fairness

and consistency by describing

colleagues’ entitlements and

responsibilities. They reinforce the

Group’s culture and strengthen

understanding of required

behaviours. The Group Board Risk

Committee receives Speak Up data

and challenges Management on its

behavioural insights. Mark Gregory,

Chair of the Group and Life

Companies Risk Committees,

istheGroup’s Whistleblowing

(SpeakUp) Champion.

Diversity, equity

andinclusion

The Group Board Sustainability

Committee oversees the

implementation of the DE&I

strategy. The strategy shapes the

Group’s culture and supports the

ambition to be the best place that

colleagues have ever worked.

Intranet and employee

communications

Colleague communications,

providing Group-wide news and

updates, emphasising the Group’s

values and culture and promoting

The Big Three, are provided in a

variety of formats such as intranet

announcements and interactive

all-colleague hybrid sessions.

Colleague voice

Monthly surveys provide leaders

with timely insights to review with

their teams and shape action

plans to strengthen our culture.

This helps the Group Board

understand colleague experiences

and monitor cultural trends. The

DNED meets quarterly with the

CRF, which brings colleague views

into early decision making. Their

insights on colleague experience

inform her cultural discussions

with the Joint Group and Life

Companies Board and ExCo.

Internal Audit

To achieve the principles

contained in the Internal Audit

Charter, the Group Board is

required to set an appropriate

‘tone from the top’. This is

to ensure a supportive and

collaborative culture of internal

audit, assurance and internal

controls at all levels of the

organisation. Updates on the

effectiveness of this are provided

to the Group Board Audit

Committee on a regular basis.

Customer

The Life Companies Board

has primary responsibility

of overseeing the Group’s

customer strategy, encouraging

a culture of customer centricity

and in turn helping people

secure a life of possibilities.

Site visits

Maggie Semple, in her capacity

as DNED, conducts site visits

across the Group’s main offices

to better understand specific

colleague experiences, which vary

depending on location. Group

Board members are invited to

attend. These visits enable the

Group Board to monitor culture

and ensure appropriate tailored

responses to any specific needs.

Colleague engagement

The Group Board attends various

colleague engagement sessions.

This two-way dialogue enables

the Group Board to understand

colleague experiences and the

topics that matter most. This

supports the Group Board with

monitoring culture and

discharging its duties under

section 172 (‘s172’) by having

regard to the interests of the

Company’s employees. To read

more about the work of our DNED

see pages 104 to 105.

Remuneration

The Group Board Remuneration

Committee ensures the Group’s

remuneration policies and

practices are implemented

and maintained in line with the

Group’s culture and strategic

direction. NEDs review

remuneration for material

risk takers and others within

the Committee’s remit where

adjustments may affect the

application of the Annual

Incentive Plan rewards. Page 141

outlines the underpin framework.

Risk culture

The Group Board Risk Committee

monitors the Group’s risk culture

which determines our awareness,

attitude and behaviour towards

risk and is an important feature

of the Group’s culture. The

Joint Group and Life Companies

Board receives regular updates

on risk culture and appetite.

Culture dashboard

The Group Board monitors and

assesses culture on a quarterly

basis by reviewing a culture

dashboard which includes

statistics on employee surveys,

diversity data and talent pipeline

development, as well as key data

points from across the organisation.

The Group Board also receives

and challenges bi-annual culture

updates from the Group CEO.

99Standard Life plc Annual Report and Accounts 2025

Corporate governance

Stakeholder engagement

s172 statement

Under Section 172 of

the Companies Act 2006

(the ‘Act’), all directors

of UK companies have a

duty to act in a way that

promotes the success

ofthe Company or the

benefit of its members

as a whole.

The Group Board recognises that effective

stakeholder engagement is essential to

fulfilling this duty. Engagement enables

the Group Board to understand what

matters most to our stakeholders and

totake these factors into account when

making decisions in the long-term interests

of the Company and its stakeholders.

Strategic engagement strengthens the

Group Board’s understanding of issues

material to each stakeholder group. This

involves a combination of business-led

initiatives and Board-level interaction.

The Group Board aims to foster a culture

where stakeholder interests are considered

throughout the decision-making process

across all levels of the organisation.

Alongside Board-level discussions, the

ExCo regularly engages with stakeholders

and discusses any key issues identified.

The Group Board acknowledges that it

isnot always possible to deliver positive

outcomes for all stakeholders simultaneously

and that decisions often require balancing

competing priorities. In such cases, the

Group Board aims to act in a way that

best supports the delivery of our strategy

and creates sustainable long-term value

for all stakeholders.

s172 Principle Relevant disclosure

The likely

consequence

of any decision

in the long term

• Chair’s statement (pages 10 to 11)

• Group CEO’s report (pages 12 to 15)

• Risk management and principal risks (page 78 to 83)

• Board activities (page 97)

• Viability statement (page 84 to 85)

• Going concern (page 178)

• Our strategic priorities and KPIs (pages 28 to 37)

• Our business model (pages 18 to 21)

The interests of the

Company’s employees

• Our culture (pages 98 to 99)

• Workforce engagement (pages 104 to 105)

• Our business model (pages 18 to 21)

• Sustainability Report (www.standardlifeplc.com)

• Group Board Nomination Committee report

(pages110to 115)

• Group Board Remuneration Committee report

(pages136 to 137)

• DE&I (page 118 and 114)

• Speak Up (Whistleblowing) Policy (page 122)

The need to foster

business relationships

with suppliers,

customers and others

• Our business model (pages 18 to 21)

• Sustainability Report (www.standardlifeplc.com)

• Group Board Sustainability Committee report

(pages133 to 135)

The impact of the

Company’s operations

on the community and

the environment

• TCFD (page 53)

• SECR (page 72)

• Sustainability Report (www.standardlifeplc.com)

• Group Board Sustainability Committee report (pages

133 to 135)

• Net Zero Transition Plan (www.standardlifeplc.com)

The desirability of the

Company maintaining

a reputation for

highstandards of

business conduct

• Risk management (page 78 to 83)

• Board activities (page 97)

• Sustainability Report (www.standardlifeplc.com)

• Board performance review (pages 106 to 107)

• Division of responsibilities (page 93)

• Our governance framework (page 95)

The need to act fairly

as between members

of the Company

• Annual General Meeting (pages 87 and 177)

• Dividend Policy and Final dividend (pages 17, 47 and176)

• Group Board Sustainability Committee report

(pages133 to 135)

• Our business model (pages 18 to 21)

1. Director induction and training

• The Directors’ induction programme includes

detailed training on Directors’ duties and the

requirements of s172.

• The Group and Life Companies Boards are

formulatedtoinclude a diverse set of skills and

experience which contribute to well-considered

andstrategic decision making.

2. Board information

• The Group and Life Companies Boards and Committees

agendas contain the details of Directors’ duties.

3. Board discussion

• Rigorous risk management, challenge and assessment

of s172 factors to ensure value creation in the short,

medium and long term.

• The Chair of the relevant Board or Committee

isresponsible for ensuring that the outcomes and

decisions are informed by s172 factors.

• The s172 factors are discussed by the relevant Board to

ensure thatlong-term value is created for stakeholders.

4. Board decision feedback to business

• CRF consultation and feedback loop from the DNED.

• Intranet communications on business-wide decisions.

• Senior Management tasked with follow-up actions.

• Boards are updated on progress as the decision is actioned.

s172 preparation, discussion and feedback mechanism

100 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Customers

Key stakeholder groups

Colleagues

How we engage

• Discussed the inclusion of Consumer Duty as

anunderpin inthe Annual Incentive Plan (‘AIP’).

• Reviewed Pensions and Savings strategy and

customerjourney.

• Oversaw migration of c1.7 million customers to the

newplatform.

• Enabled customer shareholders to submit questions

in advance of the AGM and on the day.

• Monitored customer satisfaction scores and included

them in the AIP for Executive Directors, monitored

by theGroup Board Remuneration Committee.

• Approved the rebrand strategy for Standard Life.

• Completed the Consumer Duty Annual Assessment.

How we engage

• Provided colleague shareholders the opportunity

to meet the Group Board and submit questions at

aphysicalAGM.

• Delivered ‘Connect Live’ events throughout the year,

hosted by the Group CEO and other members of the

ExCo to provide workforce updates and receive live

Q&A both in-person and via streaming.

• Received regular updates from the DNED following

engagement sessions with colleagues and the CRF.

• Continued to collect DE&I ‘Who We Are’ surveys

tobetter understand the composition of the

workforce and their needs, with the completion

ratenow at 71.5%.

• Regularly reviewed whistleblowing data at the Joint

Group and Life Companies Board Audit Committees

before review by the Joint Group and Life

Companies Board.

• Requested inclusion of grievance data in quarterly HR

Management Information to improve oversight.

• Discussed the gender and ethnicity pay gaps across

various functions, discussing improvements and the

actions being taken to address disparities.

• Reviewed talent and succession planning across

keyroles.

• Received regular updates on People, Culture

andDE&I.

Outcome

• Consumer Duty was incorporated into the 2025 AIP

asanunderpin. See page 150 of the 2024 Directors’

Remuneration report and page 156 of the 2025

Directors’ Remuneration report.

• Migrations successfully delivered with strong service

standards maintained.

• Company rebranded as Standard Life plc in March 2026.

• ‘Phoenix Insights’ rebranded as the ‘Standard Life

Centre for the Future of Retirement’ to align impactful

research and campaigning work with the trusted and

customer-facing Standard Life brand.

Outcome

• Incorporated grievance data into quarterly HR

Management Information to improve oversight and

tracking of employee complaints.

• Introduced collaborative interviews between

NEDsandExCo members to improve colleague

understanding of the role of the Group Board

followingCRF survey feedback.

• Approved the office move from Wythall to

Brindleyplace, Birmingham City Centre, enhancing

colleague experience and talent attraction through

acentral location.

• Increased engagement with identified successors

forkeyroles to foster relationships and empower

futureleaders.

• Won multiple awards including, the ‘Best Women’s

Health initiative for Wellbeing & Menopause’ at the

InsideOut Awards 2025 and the ‘Most Impactful

Rewardand Recognition Strategy’ and Bronze for the

‘Best Benefits Launch/Relaunch’ at the Appreciation

Awards 2025.

• Signed the Employers’ Pension Pledge in July 2025.

• Introduced a Shadow ExCo comprising high-performing,

high-potential colleagues representing diverse

perspectives. It provides check and challenge input to

support ExCo decision making, with representatives

attending ExCo and Board meetings to share insights

and cascade feedback, ensuring two-way engagement.

• Received recognition for the LGBTQ+ network and

itsimpact on the business at the Proud Scotland

Awards2025.

• Signed the Armed Forces Covenant and achieved a Gold

Award under the Ministry of Defence Employer

Recognition Scheme.

• Reinforced the commitment to closing pay gaps and

improving transparency.

• Racial allyship training has been organised for the Group

and Life Companies Boards in 2026.

101Standard Life plc Annual Report and Accounts 2025

Corporate governance

Key stakeholder groups

Community and environment

How we engage

• Supported employee volunteering and fundraising

programmes including the Company’s social partnership

with Carers UK and the Give As You Earnscheme.

• Received regular updates, via the Group Board

Sustainability Committee, on progress against the

Group’s sustainability targets, Sustainability Strategy

andNet Zero Transition Plan.

• Received horizon scanning updates, via the Group

BoardSustainability Committee to ensure that Directors

are apprised of regulatory and climate-related changes.

• Reviewed and approved the 2026 Sustainability

Strategyframing and materiality assessment.

• Considered the Nature and Carbon Offsetting

PositionStatements.

• Discussed stewardship engagement.

Outcome

• Approved updated Sustainability Strategy and DE&I

targets focused on embedding inclusive practices.

• The Group raised nearly £130,000 in the first year of

partnership with Carers UK, which included a period

oftriple-matching contributions by the Group.

• Trained 30 colleagues to champion carers’ needs

ineveryaspect of our customer service.

• Publication of Position Statements on tropical

deforestation, freshwater scarcity and Carbon

offsetting (in line with the Oxford Principles).

• Confirmed commitment to 2025 interim net zero goals

and continued transparency in reporting. Provided

challenge ahead of the second iteration of the Net Zero

Transition Plan, due to be published in March 2026.

Suppliers

How we engage

• Approved the Modern Slavery Statement and received

an externally provided, holistic education session from

industry experts, including information on supplier

basereviews.

• Ensured all supplier-related activity is managed in line

with Group procurement processes to ensure that risk

ismanaged and mitigated.

• Reviewed and approved amendments to the ESG

Supplier Standards, considering DE&I provisions and

Modern Slavery compliance.

Outcome

• Continued reinforcement of practices and processes

tofocus engagement on suppliers’ material to carbon

reduction commitments.

• Approved updated ESG Supplier Standards with

enhanced DE&I requirements.

Stakeholder engagement continued

How we engage

• Engaged directly with shareholders before and at the

2025 AGM.

• Received regular updates from the Chair of the Group

Board on Investor Relations Roadshow meetings and

from the Group CEO on investor feedback.

• Reviewed all key shareholder communications, including

the Annual Report, Interim Financial Report and Notice

of AGM.

• Conducted detailed shareholder consultation on the

Directors’ Remuneration Policy.

• Maintained dialogue with the two Shareholder

Nominated Directors from major shareholders,

Aberdeen and MS&AD, who joined Group Board

meetings and shared direct views on behalf of

thoseinstitutions.

• Continued our engagement programme with private

client brokers via roadshows.

• Increased direct interactions with retail investors via a

dedicated session post 2025 Half Year results with the

Group CEO and Group CFO.

• Reviewed and updated our forward-looking Investor

Targeting Plan and brokerstrategy, conducting a Group

Board-approved tender process.

Outcome

• All resolutions at the 2025 AGM passed.

• Following engagement with stakeholders and detailed

discussion by the Group Board and the Group Board

Remuneration Committee, the updated Directors’

Remuneration Policy will be presented for shareholder

approval at the 2026 AGM. See page 138 for detailed

feedback from the shareholder consultation process,

and the impact this had on the design of the Directors’

Remuneration Policy.

• Investor engagement increased by approximately

50% year-on-year in 2025.

• BNP Paribas appointed as Joint Corporate Broker,

alongside BofA Securities.

Shareholders

102 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Key stakeholder groups

Regulators

Government

How we engage

• Met formally with the Financial Conduct Authority

(‘FCA’) and Prudential Regulation Authority (‘PRA’)

during the yearon a range of matters, including the

Joint Meeting Model.

• Considered the Life Insurance Stress Test (‘LIST’)

2025 and the Group’s approach to completing

thestress test.

• Together with the Group Board Risk Committee,

reviewed the Group’s Recovery and Resolution Plans,

taking into account feedback from the PRA.

• Discussed the Regulatory Relationships Engagement

Model during the Strategic Financial Business

Planreview.

• Along with the Group Board Risk Committee and

theLife Companies Model Governance Committee,

considered the Internal Model Major Model

Changeapplication.

• Together with the Group Board Risk Committee,

theGroup Board considered the Group’s regulatory

relationships at eachmeeting.

• Reviewed the PRA PSM letter and theFCA FE letter.

• Discussed the Company’s progress towards

compliance with Provision 29 of the 2024 Code and

the internal control attestation roadmap.

• Together with the Group Board Risk Committee and

the Group Board Audit Committee, considered the

Own Risk and Solvency Assessment (‘ORSA’).

• Completed CBEST cyber resilience exercise with the

PRA, FCA and the Central Bank of Ireland.

How we engage

• The Group Board, via the Group Board Sustainability

Committee, received updates onpublic affairs and

priorities, and the work being undertaken by

Management to influence external policyto create

better outcomes for its customers.

• The Group Board, via the Group Board Risk

Committee, received updates from the Director of

Public Affairs on fiscal strain,polarisation and the

rise of the Reform party, andpolitical management.

Outcome

• Filed the LIST with the PRA in June 2025, with feedback

being received in November 2025 and an announcement

to the market published.

• Approved the Recovery and Resolution Plans,

responding to feedback and communicated refinements

to the PRA.

• Submitted the application for a Major Model Change

inJune 2025 and received approval in December 2025.

• Maintained positive engagement and transparency with

regulators, including discussions on Board simplification

and governance frameworks and structure.

• Confirmed the roadmap for Provision 29 compliance

andenhanced evidence-based control reporting.

• Approved the ORSA and submitted it to the Regulator.

• Confirmed the CBEST remediation plan and submitted

itto theRegulator for feedback.

Outcome

• Continued constructive engagement with policymakers

toadvocate for pension reform and customer-focused

outcomes.

• Raised Group Board awareness of political nuances to

inform strategic planning andexternal engagement.

103Standard Life plc Annual Report and Accounts 2025

Corporate governance

Workforce engagement

Maggie Semple, OBE

Designated Non-Executive

Director for Workforce

Engagement (‘DNED’)

Our colleagues are fundamental

to the Group’s success. They play

a vital role in driving our growth

and delivering our strategy, so

itisessential that we create an

environment where they can

perform at their best. The Group

Board sets the cultural tone for

the organisation and actively

engages with colleagues

throughout the year, both directly

and indirectly. It recognises that

our people are key to achieving

our strategic priorities and to

ensuring the Group delivers the

best possible outcomes for

customers and allstakeholders.

An annual programme of

colleague engagement ensures

coverage across business functions

and targeted groups. The Big

Three cultural ambitions define

our goals for the colleague

experience. They guide the Group

and Life Companies Boards’

engagement with theworkforce

and provide a clearframework

formeasuring progress.

Active participants in

engagement activities

244

Average views of

quarterlyblogs

1,300

Monthly survey

engagement

83%

Average views for internal

social channel posts

3,000

Engagement

in action:

listening to the

colleague voice

In-person engagement sessions

Sessions were hosted across business

locations to ensure visibility across the

Group. At these site visits, I engaged with

the leadership population to understand

the local leadership perspective, then

with colleagues at the site to compare,

contrast and understand all experiences.

Towards the end of the year, I introduced

a lunch and connect element to the

site visits, to celebrate the Colleague

Representation Forum (‘CRF’) and our

colleague networks. In these sessions

I used local colleague survey data

to prompt discussion on emerging

themes such as our strategy, customers,

leadership and the colleague experience.

Virtual engagement sessions

Sessions were held quarterly with a

specific focus or theme. Group Board

members were invited to join these

sessions and colleagues could opt

to attend. Some sessions targeted

specific audiences to shape discussion

around shared experience.

Monthly engagement surveys

The Group Board and I continue to

take a keen interest in the outputs

from the Group’s monthly colleague

engagement survey, Peakon. This data

is used to create culture dashboards

which inform site visits and my

ExCo one-to-one discussions.

CRF engagement and surveys

The CRF is an autonomous, regulated

forum that represents the collective

colleague voice. It gathers colleague

feedback through various data

channels, including direct interactions

with colleagues across the business,

and conduct surveys and polls on key

subject areas. The insights shared with

me from this activity guide my sessions

with colleagues and inform reporting

to the ExCo and the Group Board.

Quarterly DNED blog

I write a quarterly blog, which is published

on the Group’s intranet and is informed

by my engagement with colleagues on

key topics that quarter. This blog is a key

aspect of the feedback loop between

the Group Board and colleagues.

Engagement statistics

Methods of engagement with colleagues

104 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Engagement activities throughout the year

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Board meeting and colleague engagement session

DNED site visit

DNED update to the Group Board

DNED engagement with CRF

DNED network leads meeting andQ&A

DNED blog

Employee survey

Examples of outcomes from my engagement with colleagues in 2025

Engagement Attendance* Outcome

Focus group:

Workload,

April 2025

Maggie Semple I attended a focus group with eight participants to discuss workload and its impact on colleague experiences of the Group.

Amongst discussions, I was asked to clarify the feedback loop between the Group Board and colleagues, and how

discussions at Board meetings directly impact outcomes for colleagues. In response, my quarterly blog will be developed

in 2026 to act as a mechanism for closing the feedback loop and keeping colleagues informed on how their input and

thoughts are used and responded to.

ExCo session:

May 2025

Maggie Semple From the second half of 2025, I committed to holding quarterly one-to-one sessions with the Group CEO as well as

bi-annual meetings with each member of the ExCo. These sessions are designed to deliver the combination of monthly

survey data and the colleague voice directly to members of the ExCo with the nuance and external perspective of a NED.

This will also strengthen the feedback loop between the Boards and colleagues.

Focus group:

External

Customer

Service,

July 2025

Maggie Semple

Sherry Coutu

I attended a focus group with seven colleagues, accompanied by Sherry Coutu. Colleagues highlighted a strong

commitment to customer outcomes, supported by robust governance, outcome testing and a culture of care, particularly

in areas of vulnerable customer support. The group also highlighted some operational challenges and the value of

cross-functional collaboration to improve outcomes. Sherry Coutu attended the ExCo meeting in August 2025, leveraging

her knowledge and expertise in the sector, to discuss the ways in which AI could be utilised to further improve outcomes

for customers and support efficiencies for those communicating with customers.

Focus groups:

Culture

Reflection,

October 2025

Maggie Semple

Karen Green

Eleanor Bucks

I attended two focus groups on culture, one with Karen Green and one with Eleanor Bucks. A key theme from discussions

was the work being undertaken to transform and simplify the business, which had brought uncertainty for some

colleagues. I write a regular blog, sharing my reflections and perspectives on transformation activity and best practice

approaches for colleagues to support themselves and navigate through times of ambiguity. The blog titled ‘Change is

easier when we face it together’ was published on the Group’s Intranet in October 2025.

CRF meeting,

October 2025

Maggie Semple

Karin Cook

Karin Cook joined me for a CRF meeting in October 2025. The session focused on leadership consistency, transformation,

customer focus and workload. While it was noted that Peakon data showed engagement above industry benchmarks,

there were signs of strain in areas undergoing strategic improvements and colleagues indicated that leaders could be

more present. As such, the ExCo has committed to increased site visits in 2026 to increase visibility across all offices and

to engage more regularly with colleagues within their functions to better understand their experiences.

CRF Survey N/A A CRF survey highlighted that many colleagues did not fully understand the role of a Group Board Director. In response, Group

Board members were invited to attend CRF meetings during the year to provide insight and foster greater transparency. The Group

Board and ExCo, in collaboration with Company Secretariat, created a series of videos for the Group’s intranet which detailed

the role of Directors and how they collaborate with Management in deciding the strategic direction of the organisation.

2026

Engagement

Plan

N/A Following feedback from key internal stakeholders and colleagues, the 2026 Engagement Plan will be more targeted,

with specific Board members invited to discuss subjects directly related to their responsibilities. For example, toensure

holistic and transparent discussions relating to relevant governance and strategic decisions, a focus meeting will be held

in Q2 2026 to discuss remuneration and the updated Directors’ Remuneration Policy. Sherry Coutu, Chair of the Group

Board Remuneration Committee, will attend this meeting.

Full Year 2026

Remuneration

underpin

N/A During 2025, it was agreed that, as a matter of good governance, I would review the Company’s employee engagement,

culture, workforce matters and related management objectives within my remit as DNED. Accordingly, in 2026, before

final variable remuneration outcomes are determined, I will review overall progress on culture and workforce matters,

working with the Group Chief People Officer and supported by a defined scorecard. I will consider whether formula-

driven remuneration outcomes appropriately reflect performance in these areas. Where concerns within my remit are

identified, I will recommend to the Group Board Remuneration Committee that discretion be exercised in respect of

variable pay outcomes, including reductions of up to 100%.

* Other attendees during the year included Mark Gregory, Nicolaos Nicandrou and Katie Murray.

Maggie Semple, OBE

Designated NED for Workforce Engagement

105Standard Life plc Annual Report and Accounts 2025

Corporate governance

Composition, succession and evaluation

Board review

Although an external Board performance review was undertaken in 2023,

the Directors decided it was appropriate to conduct an external review

again in 2025 due to the move to a Joint Meeting Model between the

Group and LifeCompanies Boards and Committees.

Feedback from the review would support the change in governance ensuring it was fit for purpose. Ffion Hague of Independent

Board Evaluation (‘IBE’) facilitated the 2025 performance review. The Group Board confirms that IBE has no other connection with

StandardLife plc or individual Directors. IBE is a founder of The International Register of Board Reviewers, which provides the

principles under which board reviews are conducted. The following process was undertaken by IBE:

External Board review process

1 The format and scope of the review were discussed by IBE, the Chair

ofthe Group Board, the Chair of the Life Companies Board, the Group

CEO and the Group Company Secretary. IBE was chosen due to its

experience of the insurance sector, two-tier boards and highly

regulated, listed companies. IBE provided a longer-term partnership

demonstrated through its three-year engagement and AI-enabled

support, ‘Derek’. This AI-enabled tool operated alongside the service to

eliminate potential human bias such as length of service, gender or

ethnicity and supported subsequent internal reviews.

4 IBE observed the Group Board and the Joint Group and Life

Companies Board and Committee meetings held between 18 to 20

November 2025 and 17 December 2025. IBE prepared for meetings by

reviewing the Board and Committee papers for those meetings. IBE

also observed the ExCo meeting on 18 December 2025. Other Life

Companies subsidiary boards and the Enterprise Risk Management

Committee were also included in IBE’s review.

5 Draft reports were circulated to the Chair of the Group Board and

Chair of the Life Companies Board and discussed at the Joint Group

and Life Companies Board meeting on 27 January 2026. IBE also met

with each Committee Chair to discuss each Committee report.

2 Each member of the Group and Life Companies Boards, Senior

Management, advisers, ExCo members and the Group Company

Secretary had a confidential interview with IBE which included a set

agenda tailored to the Company’s Board to discuss pertinent topics.

6 Observations were circulated in the meeting packs for the January

Board and Committee meetings by IBE.

3 The Group Company Secretary, or her designate, worked with each

individual Committee Chair to finalise actions and any potential 2026

education sessions. These were then added to the 2026 education

session schedule. Actions were approved at the January 2026 meeting

and will be monitored by the relevant Board and Committees throughout

the year.

7 Actions identified and those to be taken throughout 2026 to enhance

Board effectiveness were approved at the meeting of the Joint Group

and Life Companies Board on 13 March 2026.

The 2025 Board performance review included both the Group and Life Companies Boards. The below enhancements relate to IBE’s

observations at Joint Group and Life Companies Board meetings, and Group Board only meetings, chaired by Sir Nicholas Lyons,

theChair of the Group Board. The Joint Group and Life Companies Board and Committees were found to be effective, well chaired,

engaged and evolving in response to the Joint Meeting Model. Continued attention on strategic focus, comprehensive Director

skillsets and robust challenge will be key to enhancing effectiveness. The following recommendations relate to the Joint Group

andLife Companies Board as the Joint Meeting Model evolves.

Action 1

Rebalance the agenda in

favourofstrategic objectives

Action 4

Assist the Company Secretary

inproviding strategic support

tothe Board

Action 2

Clarify the roles of the Group and

Life Companies Boards within

Board and Committee planners

Action 5

Enhance the mechanism whereby

challenge is captured as actions

Action 3

Review the Board skills matrix

106 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Committees’ performance

The Group Board Remuneration and

Sustainability Committees and the Boards

and Committees that operate in a Joint

Meeting Model were also part of IBE’s

performance review. All duties set out

in each Committee’s Terms of Reference

were addressed during the year.

Individual performance

No individual review of performance

was conducted during the 2025

Board performance review due to

the timing of the implementation of

the Joint Meeting Model. This will be

completed in 2026 when individuals

have had more time to embed and

reflect upon the new framework.

Assessment of the

Chair’sperformance

IBE carried out the above process for

the Chair of the Group Board, who

also chairs the Joint Meetings of the

Group and Life Companies Boards.

Feedback was provided by Group Board

members and the Group Company

Secretary. The Chair was found to be

effective. He was particularly adept at

fostering an inclusive culture between

the Group and Life Companies Boards.

Directors found the Joint Meeting

Model a positive process, with

enhancements identified on page 106.

Continue to enhance and monitor the quality of Board papers

to ensure sustained improvement.

A paper template for the Joint Meeting Model was

implemented from 25 August 2025 with training provided to

key authors. In addition, quality of papers continues to be

challenged by the Company Secretariat team, Management

and the Board. Directors are encouraged to provide feedback

on papers at each meeting and any feedback loop completed.

Review agenda focus and consider the frequency of meetings. With the implementation of the Joint Meeting Model, the

Company Secretariat team and Management have thoroughly

reviewed the Group and Life Companies Boards’ agendas to

bring any overlap into the Joint Meeting Model. This will

continue to be monitored as the Joint Meeting Model

continues to be embedded throughout 2026.

Thoroughly review in advance the approach to, and agenda for,

the 2025 Board Strategy Day to ensure alignment with

long-term strategic objectives.

The 2025 strategy agenda was reviewed thoroughly with

topics including: emerging risks and industry trends, an

update and analysis of competitors’ business performances;

and strategies for discussion on our competitive advantages

and changes in accounting methodologies. The Life

Companies Board also attended the Strategy Day in line with

the Joint Meeting Model.

Continue to enhance NED and colleague engagement. See pages 104 to 105 for details of how NED and colleague

engagement has been enhanced.

The 2024 Board review

The 2024 Group Board performance review was internally facilitated by the Chair of the Group Board and Group Company Secretary.

The following progress against actions identified during the review have taken place during 2025:

Action identified Action taken

107Standard Life plc Annual Report and Accounts 2025

Corporate governance

Q1 Q2

Each year, the Group Board ensures a continuous improvement cycle providing

personal and collective development through a formal programme of

education and deep dive sessions. The following education and deep dive

sessions were provided to the Group Board and Committees during 2025.

Composition, succession and evaluation continued

Group Board education and development

Annual review of targets and

dividend approach

The Group CFO transparently briefed the Group Board

on the rationale behind external targets, published on

17 March 2025, ensuring robust challenge and discussion.

Outcome:

Well-executed results and stable share price since

17 March 2025, driven by a transparent investor

presentation and clear proposed metrics outlined

in the 2024 Directors’ Remuneration report.

Board

Macro-economics and political landscape

The Chief Investment Officer led a deep dive on external

risksaffecting equity, credit, and interest rate markets,

examining macro-economic, market, and geopolitical

factors – including the incoming US administration –

andtheir impact on Standard Life’s investment

performance and financial framework, with emphasis

onkey strategic initiatives.

Outcome:

Better understanding of the impact from a new US

administration upon the Group’s strategy and rationale

for decisions made.

Board

Funded reinsurance

The funded reinsurance strategy and its impact upon

business planning, managing investment risk capital,

including temporary strain and boosting returns.

Outcome:

Better strategic understanding of funded reinsurance

in respect of life companies firms and the increased

demand for bulk transfers of the defined benefit

pensionliabilities.

Risk

Migrations

Deep dive into the progress of migrations and the

importance of all Standard Life’s strategic partners

that are key stakeholders under s172 of the Companies

Act 2006.

Outcome:

Enhanced collaboration with key third-party suppliers,

including a 10-year strategic partnership with Wipro to

deliver life and pension administration for ReAssure and

accelerate Standard Life’s operational transformation.

Board

Management actions

Deep dive into the sustainability of the recurring and

non-recurring management actions upon the Strategic

Financial Business Plan.

Outcome:

The Group Board provided challenge on management

actions with a full understanding of what actions would

be recurring.

Board

Mansion House Accord

Deep dive into the next phase of the Mansion House Compact.

Outcome:

The Company became a signatory to the Mansion House

Accord on 13 May 2025.

Board

Strategy Day Sessions

Topics included: Retail/Master Trust, market trends, profit

pools and strategy, Strategic Financial Business Plan, key

dependencies and risks, customer opportunity, rebrand

and change of Company name.

Outcome:

Approved in principle the transition of our principal brand

from Phoenix Group to Standard Life.

Board

In-house management of annuity-backing assets

Deep dive into the risks of transferring Standard Life’s

annuity-backing assets from its current asset manager

toin-house to benefit our scaled asset management

capabilities, while optimising customer outcomes and

ensuring enhanced returns.

Outcome:

Approved the in-housing strategy at its September

2025meeting.

Risk

Modern Slavery

Education session delivered by ‘Unseen,’ the UK’s leading

modern slavery charity, marking the 10-year anniversary

of the Modern Slavery Act.

Outcome:

The Group Board Sustainability Committee received key

updates, recent case examples and guidance on UK Principles

and best practice knowledge on the Modern Slavery Act.

Sustainability

108 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Q3 Q4

Investor Relations

Feedback provided to the Group Board following

HalfYear 2025 investormeetings.

Outcome:

Investor presentation improved further following

consideration of investor feedback.

Board

2026 Remuneration Policy

Deep dive sessions with Deloitte (advisers) and

Management to streamline the key metrics for Full

Year2026 from 22 metrics towards market practice

of5–6 metrics.

Outcome:

Shareholders welcomed the streamlined number of

metrics that truly improved strategy.

Remuneration

Cyber security

Deep dive into the CBEST exercise which aimed to test

the organisation’s security posture using threat-led

penetration testing to emulate real-world threat actor

techniques, and the Cyber Security and Resilience

Self-Assessment.

Outcome:

The ExCo completed its CBEST at its August 2025

meeting and any actions were reported to the Group

andLife Companies Board. The Digital Advisory Group

(‘DAG’) will be constituted in 2026 to ensure that the

Group and Life Companies Boards have appropriate

members monitoring such threats.

Risk

Net Zero Transition Plan outline,

context and messaging

Education session on the Group’s Net Zero investment

proposition in light of evolving market sentiment,

customer expectations and regulatory developments.

The second iteration of the Net Zero Transition Plan

willbe published in Q1 2026.

Outcome:

To review the impact of any change in government

atthenext general election with a particular focus

oncustomer outcomes.

Sustainability

Finance Transformation Programme (‘FTP’)

A progress report on people, culture, automation,

process reporting, performance management of the

balance sheet, and capital within the Finance function.

Outcome:

A continued focus in 2026 for the Joint Group and

LifeCompanies Board Audit Committees.

Board

Underpin framework within the 2026

Remuneration Policy

Deep dive into the process and how the underpin

would work for a number of metrics including people,

customer, audit, risk and sustainability.

Outcome:

See page 141 of the Directors’ Remuneration report.

Audit, Risk, Remuneration and Sustainability Committee Chairs,

DNED and the Chair of the Life Companies Board

Wider workforce dashboard

Annual review of the wider workforce dashboard that

isbenchmarked against peers on fixed and variable pay,

benefits and wellbeing.

Outcome:

See page 145 of the Directors’ Remuneration report.

Board

Mandatory training

The Board received specific mandatory training on:

• Code of Conduct;

• Consumer Duty;

• Data Protection;

• Financial Crime;

• Failure to Prevent Fraud in accordance with the

implementation of the Economic Crime and

CorporateTransparency Act 2023 (‘ECCTA’ 2023);

• Market Abuse Regulations;

• Information Security; and

• Internal Model Validation.

Outcome:

All mandatory training for 2025 was completed by

January 2026.

Board

Strategic priorities

Grow

Optimise

Enhance

See our Strategic priorities

on pages 28 to 35

109Standard Life plc Annual Report and Accounts 2025

Corporate governance

Composition, succession and evaluation continued

Group Nomination Committee report

Sir Nicholas Lyons

Group Board Nomination

Committee Chair

Role, responsibilities

and effectiveness

The Role of the Committee is shown on page 95

The Committee’s responsibilities and duties can

be found within its Terms of Reference, which are

available on the Company’s website.

Key Committee activities in 2025

• Reviewed and challenged the Joint MeetingModel

forthe Group Board andLifeCompanies Board

Nomination Committeesby assessing which items

overlapfor the Joint Meeting Model.

• Appointment of Mark Gregory to theLife

CompaniesBoard and Karin Cook to the Group

Boardas Dual Directors.

• Retirement of Belinda Richards after serving eight

anda half years on the Group Board.

• Appointment of Sherry Coutu as Chair of the Group

Board Remuneration Committee, succeeding Nicholas

Shott. Sherry also brings expertise in AI, addressing a

previously identified skills gap onthe Group Board.

• Review of succession plan for Executive Directors,

theExCo and Senior Management with emergency

cover identified for all roles.

• Retirement of David Scott as the Shareholder Nominated

Director for Aberdeen Group plc andappointment of

Siobhan Boylan from 1 September 2025.

2026 focus

• Succession planning for the Group Board’s Senior

Independent Director ahead of her reaching her

nine-year term in June 2026.

• Monitoring the Joint Meeting Model for the Group

and Life Companies Boards NominationCommittees.

• Ensure individual directors’ performance is reviewed

during the 2026 Group and Life Companies Boards

performance review in line with Provision 21 ofthe

2024 Code.

Committee meetings

and membership

Member

from

2025 meeting

attendance

2025 %

attendance

Sir Nicholas Lyons 1 December 2023 7/7 100%

Sherry Coutu

1 July 2025 3/3 100%

Karen Green 5 May 2022 7/ 7 100%

Mark Gregory 4 December 2024 7/7 100%

Katie Murray 29 June 2023 7/ 7 100%

Nicholas Shott

11 May 2017 4/4 100%

1. Sherry Coutu became a member of the Group Board Nomination

Committee on 1 July 2025.

2. Nicholas Shott retired from the Group Board on 30 June 2025.

Additional regular attendees include the Group CEO, Group Chief People

Officer andthe Group Company Secretary.

Number of Committee meetings

held this year (including ad hoc)

110 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Group Board Nomination Committee reporting cycle

Q2Q1

Q3 Q4

* These items were considered as part of the Joint Meeting Model, which was introduced in August 2025.

• Approved the Nomination Committee report for the

Full Year 2024 Annual Report

• Re-election proposals for 2025AGM

• Reviewed NED independence andtimecommitments

• Reviewed Executive Directors, ExCo succession plans

and emergency cover

• Considered proposals for the JointMeeting Model

• Implemented the JointMeeting Model on

25 August 2025*

• Discussed Group and Life Companies Boards and their

Committees’ composition and appointments*

• Reviewed the Advisory Groups to the Group Board

• Renewed NED appointments

• Reviewed Board succession planningin lightof the

Boardsimplification strategy

• Approved the Colleague Engagement Plan for

JulyandAugust

• Considered and challenged the proposed

Boardsimplification strategy

• Considered the successor of the SID in advance of

Karen Green’s retirement in June 2026

• Agreed that from 2026, the Group and Life

Companies Board Audit Committees would

meet jointly, with standalone meetings only

when required*

• Reviewed the Group Board DE&I Policy

The Joint Meeting Model has

been a key focus of the Group

Board Nomination Committee

in2025. This will continue to be

monitored during 2026, but the

Group and Life Companies Boards

are pleased with the improved

ways of working todate.

Sir Nicholas Lyons

Chair of the Group Board Nomination Committee

111Standard Life plc Annual Report and Accounts 2025

Corporate governance

Outcomes from Committee discussions

On an annual basis, a review of the Committee’s activities is undertaken. In 2025, it was concluded that all elements of responsibility

detailed in the Committee’s Terms of Reference had been addressed. An overview of some of the significant activities undertaken

during the year and the way in which they contributed to important outcomes is detailed in the following table:

Key activities

Board simplification Outcome

Joint Meeting Model A more streamlined approach to the previous two-tier model where meetings ran separately two weeks

apart. The Joint Meeting Model means meetings are run concurrently. The Joint Meeting Model was

applied to the Group and Life Companies Boards and Nomination, Audit and Risk Committees. The

introduction of Dual Directors appointed to both the Group and Life Companies Boards provides a

better level of continuity and a streamlined approach, with conflicts robustly managed. The initial

success of this Joint Meeting Model will lead to further refinement during 2026.

Succession planning Outcome

Executive Directors,

ExCo and ExCo-1

Appropriate emergency cover for the Dual CEO is now in place. Development themes for ExCo

successors have been communicated. Though gender balance at ExCo level is 50:50, the ethnicity

balance requires further improvement. To support the challenge of ensuring more ethnic minorities are

‘future ready’ for the ExCo, a Shadow ExCo has been introduced from 2026, ensuring broader diversity

is a focus and giving our best talent the tools and experience needed to reach their full potential. The

Group Board is mindful of the succession pipeline required for better ethnic minority representation

within Senior Management. The amalgamation of the Asset Management and Retirement Solutions

businesses following the retirement of Andy Curran, CEO Savings and Retirement, UK and Europe,

alsoallowed those businesses to be streamlined under the supervision of one ExCo member.

NED process Outcome

NED succession

planning

Sherry Coutu joined the Group Board on 1 May 2025 and became Chair of the Group Board Remuneration

Committee on 1July 2025 following the retirement of Nicholas Shott on 30 June 2025. Karen Green

willretire from the Group Board on 30 June 2026 following her nine-year tenure and consideration has

been given to who will replace her on the Group Board as SID, Chair of the Group Board Sustainability

Committee and member of the Group Board Risk Committee. Mark Gregory joined the Group Board

Remuneration Committee on 1 December 2025 to allow for orderly succession for that Committee.

Appointment

of Karin Cook

The Group Board’s composition requirements were reviewed in light of skills gaps following Belinda

Richards’ retirement from the Group Board, as well as the implementation of the Joint Meeting Model.

The Joint Meeting Model has brought closer links between the two Boards to ensure focused debate and

challenge. It was considered sensible to recruit a candidate from the Life Companies Board and Karin Cook

was identified as a suitable replacement given her strong customer, operational and transformation

background. It was deemed unnecessary to involve the use of an external search consultancy for Belinda

Richards’ replacement as Karin Cook had already been through a rigorous process when appointed to the

Life Companies Board on 1 May 2024, where she had demonstrated challenge at Life Companies Board

meetings since her appointment.

Committee changes Outcome

With the introduction

of the new Joint

Meeting Model a refresh

of Committee members

was also considered

Mark Gregory joined the Life Companies Board on 25 August 2025 as a Dual Director and Chair of the

Group and Life Companies Board Risk Committees. Karin Cook joined the Group Board on 25 August

2025 as a Dual Director. She replaced Belinda Richards, who retired from the Group Board with effect

from 24 August 2025 following an eight and a half year tenure. Eleanor Bucks joined the Group Board

Risk Committee and the Group Board Audit Committee from 1 April 2025 and 25 August 2025,

toreplace Belinda Richards and Karen Green respectively.

Colleague engagement Outcome

DNED It was agreed that the DNED, Maggie Semple, would attend ExCo meetings at least twice ayear to

provide feedback on colleague engagement, enabling Management to consider and agree appropriate

actions. In addition, Maggie Semple met individually with ExCo members to discuss key themes

emerging from their teams. These interactions support continuous monitoring of how the desired

culture is being embedded across the organisation. Further information on how the Group Board

monitors and assesses culture can be found on pages 98 to 99.

The Committee also received education sessions as shown on pages 108 to 109.

Composition, succession and evaluation continued

Group Board Nomination Committee report

Board and Executive

successionplanning

Succession planning is a key focus

for the Group and Life Companies

Boards from both a leadership and

governance perspective. The Committee

continually reviews the composition

and skillsets of the Group Board and

Committees to ensure they can support

Management to execute the Group’s

strategy. Aspreviously mentioned, the

succession planning for when Karen

Green retires from the Group Board is

underway. As the JointMeeting Model

is embedded, a further review of Group

Board requirements will be monitored

during 2026, as a full cycle of joint

meetings has not yet been completed.

The Committee ensures that Board

recruitment and succession planning

are conducted in a measured and timely

manner, allowing a robust and rigorous

search to be undertaken for each Board

appointment. This allows an appropriate

amount of time for the Directors to

interview and select the best candidate.

112 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Appointment process

The standard process used by the Group

Board Nomination Committee for Group

Board appointments involves the use

of an external search consultancy to

source external candidates and, in the

case of executive appointments, also

considers internal candidates. A role

profile is drafted by the Group Company

Secretary and reviewed and approved by

the Group Board Nomination Committee.

Detailed assessments of short-listed

candidates are undertaken by the search

consultancy and the Committee. The

Committee requires search firms to

ensure that both long-lists and short-

lists are balanced from a diversity

and inclusion perspective. If not, the

Committee will insist on a refresh.

Each member of the Group Board

Nomination Committee interviews

short-listed candidates individually

or jointly with other members of the

Committee. A pre-prepared list of

questions is used to ensure continuity.

Interviewers are mindful of the skills

matrix, diversity of thought and how

Standard Life’s values are demonstrated

to ensure any potential Director is a

good cultural fit for the Group Board.

Interviews are also held with the

Group CEO and Group Chief People

Officer as part of the process and other

members of the ExCo as appropriate.

References are then obtained prior

totheCommittee recommending the

appointment to the Group Board. Once

the Group Board has approved the

recommendation, a market announcement

is made as soonas possible, and the

onboarding process begins.

Succession planning

The Committee follows a similar

approach to succession planning for

Executive Directors. For ExCo roles,

the process ensures that, in the event

of an emergency, there is at least one

identified internal successor who is

either immediately ready or expected

to be ready within one to two years.

External candidates are also included in

the process. ExCo succession planning

was a focus for 2025, considering talent,

capabilities and the broader diversity

agenda. Though the gender balance at

ExCo level is 50:50, the ethnic minority

balance requires some enhancement.

To support the challenge of ensuring

more ethnic minorities are ‘future

ready’ for the ExCo, a Shadow ExCo has

been introduced from 2026, ensuring

broader diversity is a focus and giving

our best talent the tools and experience

needed to reach their full potential.

Subsidiary governance

Part of the Committee’s role is the

oversight of the Group’s subsidiary

governance framework, which forms

part of our regulated entities. With the

implementation of the Joint Meeting

Model, certain items such as ExCo

successors, emergency CEO, CFO and

CRO cover and colleague engagement

have been discussed at Joint Group

and Life Companies Board Nomination

Committee meetings. Though the

Life Companies Board reviews its own

succession planning, this is also noted by

the Group Board Nomination Committee.

Board skills

The Group Board’s skills and experience

are regularly assessed. The introduction

of the Joint Meeting Model made

it essential to ensure that the Life

Companies Board possessed the

appropriate skills and experience on a

standalone basis. The implementation

of the model has also enabled the

Group Board to benefit from additional

expertise and perspectives drawn from

the Life Companies Board. For example,

the Committee identified certain

Non-Executive Directors that bring

strong technology, AI and customer

expertise and created the DAG, which

addresses a previously identified

skills gap and leads to increased

challenge and oversight in this area.

Board Diversity Policy

The Group Board annually reviews and

updates its Board DE&I Policy to ensure

it reflects its values, culture and relevant

Listing Rules compliance and 2024 Code

Principles. The 2025 Board DE&I Policy

can be found on the Company’s website.

The Group Board is pleased that it

currently complies with its own policy in

line with UKLR 6.6.6(9), the Parker Review

and the FTSE Women Leaders Review.

Objectives Compliance update as at 31 December 2025

Board diversity

Ongoing compliance with the FTSE Women Leaders Review,

Parker Review and the FCA’s Listing Rules:

• at least 40% of women on the Board;

• at least one of the senior Board positions (Chair, CEO, CFO

orSenior Independent Director) should be a woman; and

• at least one Board member should be from a non-white

minority ethnic background (as defined by the ONS).

As at 13 March 2026:

• Seven female Directors representing 58% of Group

Boardcomposition.

• The Senior Independent Director is Karen Green.

Shewillretire from the Group Board on 30 June 2026 and

theGroup Board willbe mindful of gender diversity when

making future seniorBoard appointments.

• Two minority ethnic Directors representing 17% of Group

Board composition.

• Standard Life plc’s target for ethnic minority representation

at Senior Management

level was 13% by 31 December 2025.

At 13 March 2026, it is tracking at 13.8%. The Group Board

ismindful of the succession pipeline required for better

representation in Senior Management. See page 112.

1. Definition of Senior Management is in line with the Parker Review of ExCo and ExCo minus 1, excluding those not in Senior Management roles.

113Standard Life plc Annual Report and Accounts 2025

Corporate governance

The Group Board was pleased to be recognised as a top performer for 2025 in the FTSE Women Leaders Review. In addition, the Group

Board met the recommendation of the Parker Review for FTSE 100 companies in relation to there being at least one Director from an

ethnic minority background on the Group Board.

The Committee has been active in promoting gender and ethnic diversity on the Group Board and continues to take an active role in

oversight and guidance of the executive diversity and inclusion process. Details of the diversity and inclusion initiatives for Standard

Life colleagues (including the Executives) are contained in the Sustainability Report, which is available on the Company’s website.

The Group’s Senior Management gender diversity data (including statutory requirements) is contained in the Strategic report on page 76.

Gender diversity

Number ofBoard

members

Percentage

ofthe Board

Number ofsenior

positions on the

Board (CEO, CFO,

SID and Chair)

Number in

Executive

Management

Percentage

ofExecutive

Management

Number oftotal

employees

Percentage

oftotal

employees

As at 13 March 2026

Men 5 42% 3 3 27% 2,712 51%

Women 7 58% 1 8 73% 2,622 49%

As at 31 December 2025

Men 5 42% 3 6 46% 2,793 51%

Women 7 58% 1 7 54% 2,726 49%

The definition of Executive Management includes the Group Company Secretary in line with that under UKLR 6.6.6(10) and Provision

23 of the 2024 Code.

Ethnic diversity

Number

of Board

members

Percentage

ofthe Board

Number ofsenior

positions on the

Board (CEO, CFO,

SID and Chair) Number in ExCo

Percentage

ExCo

Number of total

employees

2,3

Percentage

oftotal

employees

As at 13 March 2026

White British or other

White (including minority

White groups)

10 84% 4 9 90% 2,965 56%

Mixed/Multiple

Ethnic Groups 0 0 0 0 0% 70 1%

Asian/Asian British 1 8% 0 0 0% 358 7%

Black/African/Caribbean/

Black British 1 8% 0 0 0% 74 1%

Other ethnic group,

including Arab 0 0 0 0 0% 44 1%

Not specified/

prefer not to say 0 0 0 1 10% 1,823 34%

As at 31 December 2025

White British or other

White (including minority

White groups) 10 84% 4 11 92% 3,086 56%

Mixed/Multiple

Ethnic Groups 0 0% 0 0 0% 76 1%

Asian/Asian British 1 8% 0 0 0% 375 7%

Black/African/Caribbean/

Black British 1 8% 0 0 0% 80 1%

Other ethnic group,

including Arab 0 0% 0 0 0% 45 1%

Not specified/

prefer not to say 0 0% 0 1 8% 1,857 34%

1. Based on the Office for National Statistics classification and included: Asian, Black, Mixed/multiple ethnic groups, Other ethnic groups, White and Prefer not to say.

2. Standard Life collects data through the internal HR platform with the aim of providingup-to-date views of colleague diversity and allowing data analysis at a Group, function and

business unit level, asat31 December, the participation rate was 71.5%.

3. Data collected, permissible and volunteered by colleagues.

Composition, succession and evaluation continued

Group Board Nomination Committee report

114 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Board independence

With the exception of the Chair of the

Group Board and Shareholder Nominated

Directors, all NEDs are considered

independent in character and judgement.

The independence criteria set out in

Provision 10 of the 2024 Code is reviewed

as part of the selection process for the

NEDs who join the Group Board. The

Committee determined that Sherry Coutu

was independent upon her appointment

to the Group Board on 1 May 2025.

Karin Cook was appointed as a Group

NEDand a Dual Director with effect from

25 August 2025. During her appointment

process a cross-directorship was

identified with Katie Murray at NatWest

(on the ringfenced bank which is a

significant subsidiary of the listed

NatWest Group plc). Thorough due

diligence was undertaken with robust

protocols implemented following legal

advice to ensure both Karin and Katie

could be considered to be independent

NEDs of the Group Board. It was

concluded that:

• Neither Director would have a decisive

influence at a Board level given the

sizeof the Group Board and Life

Companies Board.

• The activity between NatWest and

Standard Life on a group-to-group

basis is largely minimal. For any treasury

matters brought to the Group Board

for approval both Katie Murray and

Karin Cook would recuse themselves

from any decision.

• No treasury matters are brought to either

the Group or Life Companies Board Audit

Committees, where Katie Murray is Chair

of the Joint Group Board and Life

Companies Audit Committees and Karin

Cook is a member of the Life Companies

Board Audit Committee.

The Group Board was therefore able to

confirm that Katie Murray and Karin Cook

remained Independent NEDs of the

Group Board.

Additional appointments

If any Director wishes to take on an

additional external appointment, they are

required to seek permission from the

relevant Board. That Board will then take

into consideration the additional time

commitments, independence and any

potential conflicts of interest in relation

to the Directors’ current roles and

responsibilities beforeany permission

isgiven.

Time commitment

All Directors are expected to commit

sufficient time to the Group or Life

Companies Board. Time commitments

forDirectors are reviewed by the

GroupBoard and Life Companies Board

Nomination Committees on an annual

basis including prior to recommendation

for re-appointment to the Group Board at

the Company’s AGM, on changes in role

(joining additional Committees or taking

on further responsibility) and prior to

approving external appointments. A list

oftime commitments of each Director for

their external and internal appointments

are maintained and updated immediately

following any change in their portfolio.

Before the implementation of the Joint

Meeting Model on 25 August 2025, time

commitments required by each Director

were thoroughly reviewed and the

number of days per role established.

Asimilar process is applied to external

appointments to ensure Directors have

enough time to dedicate to the Company.

These will be reviewed and updated once

the Joint Meeting Model has completed

its first annual cycle to ensure they

remain fit for purpose.

The basic time commitment can be

significantly increased on account of

transactional or other activity. The

Group Board Nomination Committee

confirms that all Group NEDs have

demonstrated they have sufficient time,

which is regularly reviewed by calculating

days allocated to their appointment at

Standard Life plc with external board

appointments, whilst also considering

the size, complexity and global scale

of those additional appointments.

Time commitment was a focus during the

recruitment process of Sherry Coutu. Her

current appointments were listed against

the proxy and major shareholders’ voting

guidelines on overboarding along with

the complexity and number of days spent

on each board and any committees to

ensure she had the appropriate time to

also commit to her role at Standard Life.

The Committee agreed that Sherry will

not be appointed to any additional

committees during the 2026 Directors’

Remuneration Policy review and

shareholder consultation. This approach

ensures she can devote the necessary

time and focus to her responsibilities as

Chair of the Group Board Remuneration

Committee at Standard Life, while

managing her other external

commitments. The Committee will revisit

her Committee appointments following

the 2026 AGM.

It has been a busy year with a strong

focus on strengthening governance and

this will continue in 2026 as the Joint

Meeting Model continues to be

embedded.

Sir Nicholas Lyons

Chair of the Group Board and

NominationCommittee

Role Number ofdays Notes

Group Board and Nomination Committee Chair

and any Committee membership/attendee

104

Life Companies Board and Nomination Committee

Chair and any Committee membership/attendee

Executive Director who is a Committee Chair or

has two Committee memberships

Group SID 7

Group/Life Companies NED and member of one or

more Group/Life Companies Board Committees

40 This includes Board, Committee and AGM attendance and preparation. The Group

Board Nomination Committee agreed approximately 3 days are required to participate

in meetings (including meetings and dinners) with a further day required to prepare

forthe meetings. One day per month is to review Group information and any briefing

sessions for Committee members.

Dual Director (on both Group Board and Life

Companies Board) and member of one or more

Group or Life Companies Board Committees

Chair of Group and Life Companies Risk Committee 15

Chair of the Group Board Audit Committee 10

Chair of the Group Board Remuneration Committee 15 This will reduce to 10 days once the 2026 Remuneration Policy has been completed.

Chair of the Group Board Sustainability Committee 10

115Standard Life plc Annual Report and Accounts 2025

Corporate governance

• Chairs of the Group Board and the Life Companies Board

• Group Company Secretary

• Group Chief Executive Officer

• Group Chief Financial Officer

• Individual NEDs of the Group and Life Companies Boards

• ExCo members

• Customer Operations Manager

• Group Treasurer

• Investor Relations Director

• Key external advisers

• Directors’ duties and s172 requirements.

• Group and Life Companies Boards’ operations and

governance framework.

• Joint and Group meeting minutes and meeting packs.

• Group policies/delegations of authority/conduct/regulatory

responsibilities.

• Financial, strategic and operation plans and priorities.

• Directors’ & Officers’ liability insurance summary.

• Market Abuse Regulations training.

• Listed company and life companies governance training.

• Other documents as appropriate in relation to the level

of Board or Board Committee responsibilities.

• Mandatory training.

• London

• Birmingham

• Edinburgh

• Telford

• Ireland

• Bristol

These provide insight into the Group and office culture

acrossStandard Life. Site visits provide an opportunity

tomeetacross-section of the wider workforce.

Provide an understanding of each role, challenges and

opportunities, culture of the Group Board and ExCo.

Being a highly regulated Group, it is important NEDs

have a full understanding of the importance of the regulators.

Though some of the documents such as those relating to

MarketAbuse Regulations will be familiar to many NEDs, there

are some Standard Life specific documents relating to the Group

and Life Companies Boards governance framework which

support the NEDs in familiarising themselves with the Group.

Meetings Outcomes

Directors’ induction

The Chair of the Group Board discusses training

annually with each NED, supported by the Group

Company Secretary, particularly after Board

effectiveness reviews, to see if any additional

training requirements have been suggested.

Directors are encouraged to suggest training topics

and have access to a Board portal with additional

resources. For example, when the Cyber Governance

Code was introduced all Directors were encouraged

to complete the training referred to in this code.

The Chair of the Group Board leads

thedevelopment and oversight and

implementation of training policies and

procedures for Directors. On appointment,

each Director receives a tailored induction,

followed by ongoing education and

deep dives (see pages 108 to 109).

Composition, succession and evaluation continued

NED inductions

Key documents

Site tours with management

Outcomes

116 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Sherry Coutu, CBE

Joined the Group Board on 1 May 2025

I received the typical programme and an in-person

course by a third-party supplier as shown below to

deepen my financial services knowledge in an informal

environment where I could challenge and ask questions.

Ifound this level of support comforting and invaluable:

Topic Session

Time

commitment Outcome

Introduction to Life

Insurance – valuation

of reserves and

UK Solvency II.

SMCR – overview of

the regime and what

it means for NEDs.

1 2hrs Full understanding

of the regime

and the specific

responsibilities

of the SMF12 role.

Additional sessions were available on request and if

deemed necessary. These topics range from insurance

market/product landscape to more technical areas such

as IFRS 17 and the Own Risk and Solvency Assessment

and Internal Model.

Karin Cook

Joined the Group Board on

25 August 2025

Upon joining the Life Companies

Board as a NED on 1 May 2024, I

received the typical programme.

Following my appointment to the

Group Board as a Dual Director

on 25 August 2025, I undertook a

second programme addressing

potential conflicts of interest across

the Group and Life Companies

Boards,with emphasis on dividend

governance, Listing Rules, and

Market Abuse Regulations which

deepened myunderstanding

of Group-level oversight.

Siobhan Boylan

Joined the Group Board on

1 September 2025

I was appointed as the

Shareholder Nominated

Directorfor Aberdeen Group plc

on 1 September 2025, following

David Scott’s retirement. My

induction programme was

tailored to ensure I met with the

mostrelevant people internally,

included the typical programme,

with additional emphasis on

strategic priorities, particularly

asset management and

sustainable investments. I was

also reminded of my legal

responsibilities under the

Companies Act 2006, including

the management of conflicts

ofinterest specific to my role as a

Shareholder NominatedDirector.

The induction programme at Standard

Life has been comprehensive and I

wish to thank Nicholas Shott for his

diligent and detailed handover.

Mark Gregory

Joined the Life Companies Board

on 25 August 2025

I was appointed to the Life

Companies Board on 25 August

2025, having attended several Life

Companies Board Risk Committee

meetings beforehand. This early

involvement ensured that I was

well prepared and familiar with

the Life Companies Board’s

operations prior to my formal

appointment.

117Standard Life plc Annual Report and Accounts 2025

Corporate governance

Board gender balance

(including Shareholder

Nominated Directors)

Male (5) 42

Female (7) 58

Board ethnicity

(including Shareholder

Nominated Directors)

White British/English (6) 50%

White Irish (2) 1

White Scottish (1)

White Canadian (1)

Asian (Japanese) (1)

Black (Caribbean) (1)

Non-Executive

Director tenure

Less than 1 year (3)

30%

1–3 years (2)

20%

3–6 years (3)

30%

6–9 years (2)

20%

9 years or more (0)

The Group Board’s composition reflects a diverse mix of backgrounds,

skills, knowledge and expertise which enhances decision making;

mitigatesthe risk of ‘groupthink’; and supports robust risk management.

Composition, succession and evaluation continued

Board diversity

AGM votes in favour of all

resolutions May 2025

84%

97% in 2024

For a summary of how the Group complied with the 2024 Code during 2025 see page 92

Independent Board Directors¹

58%

FTSE Women Leaders ranking

(February 2026)

7th

6th in 2025

Board ethnic minority

Director representation¹

17%

17% as at 14 March 2025

Board female Director

representation¹

58%

42% as at 14 March 2025

Average age of the Board¹

1. As at 13th March 2026.

118 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Board skills and expertise

The Board skills and expertise detailed below demonstrates strong capability across the expected categories, as well

as a broadrange of complementary skills. This assessment informs the Group Board’s succession planning and the

ongoing recruitment ofNEDs, with targeted action taken to strengthen any areas identified for development.

Mergers & Acquisitions

Capital markets

Regulatory

Financial

Life assurance

Actuarial

Asset/Investment management

Risk management

Customer service and solutions

Sustainability/ESG

Change/Transformation

IT/ Product digitisation

Sales/Distribution

Marketing

Operations

Human resources

FTSE 100 board experience

Artificial Intelligence

Sir Nicholas Lyons

Chair of the Group Board

Andy Briggs MBE

Group Chief Executive Officer

Nicolaos Nicandrou

Group Chief Financial Officer

Karen Green

Senior Independent Director

Siobhan Boylan

Shareholder Nominated Director

Eleanor Bucks

Independent Non-Executive Director

Karin Cook

Independent Non-Executive Director

Sherry Coutu CBE

Independent Non-Executive Director

Mark Gregory

Independent Non-Executive Director

Hiroyuki Iioka

Shareholder Nominated Director

Katie Murray

Independent Non-Executive Director

Maggie Semple OBE

Independent Non-Executive Director

Total primary skills 9 9 11 9 7 2 7 8 6 7 5 4 3 3 5 6 11 2

Total secondary skills

1 1 1 2 3 2 3 4 2 3 4 3 2 2 4 5 0 1

119Standard Life plc Annual Report and Accounts 2025

Corporate governance

Audit, risk and internal controls

Group Board Audit Committee report

Katie Murray

Chair of the Group Board

Audit Committee

Role and responsibilities

The Role of the Committee is shown on page 95

The Committee’s responsibilities and duties

can be found within its Terms of Reference,

which are available on the Company’s website.

Key Committee activities in 2025

• Reviewed the plans for the implementation of the

Internal Control Framework (‘ICF’) in anticipation

ofthe Group Board’s declaration in accordance with

Provision 29 of the 2024 Code at Full Year 2026.

• Challenged the strategic improvements being made

tothe Finance function, including the embeddedness

of the IFRS 17 reporting processes.

• Oversaw the external disclosure for the PRA Life

Insurance Stress Test (‘LIST’) results.

• Reviewed the introduction of new business unit

segmental disclosures for IFRS adjusted operating

profit andOperating Cash Generation.

• Further considered the financial reporting and

disclosure impacts of Solvency II as modified by

thePRA’s 2024 reforms (‘Solvency UK’).

• Supported the new Chief Audit Officer intheir

role,including oversight of functional performance,

reporting and organisational designchanges.

• Discussed accounting policy application.

2026 focus

• Continue to monitor the embeddedness and

effectiveness of the Group’s ICF and testing of

material controls in anticipation of the Board’s

declaration as to its effectiveness of internal controls

at Full Year 2026, in accordance with the 2024 Code.

• Continue to support the strategic changes and

efficiencies of the Internal Audit function.

• Further alignment between the Committee and

theLife Companies Board Audit Committee to

enhance governance.

• Continue to oversee strategic improvements to

theCompany’s Finance function including deliveries

of the FTP.

• Oversee the roll-out of the enhanced control

framework forsustainability reporting.

• Monitor key Management objectives and matters

within its remit. Where concerns are identified, the

Committee will consider whether to recommend to the

Group Board Remuneration Committee that discretion

be exercised in respect of variable remuneration

outcomes, including reductions up to 100%.

Committee meetings

and membership

Member

from

2025 meeting

attendance

2025 %

attendance

Katie Murray 1 April 2022 8/8 100%

Mark Gregory 1 January 2024 8/8 100%

Eleanor Bucks

25 August 2025 3/3 100%

Nicholas Shott

2 July 2019 4/5 80%

1. Eleanor Bucks became a member of the Group Board Audit Committee on

25 August 2025.

2. Nicholas Shott retired from the Group Board on 30 June 2025. He

wasunable to attend a Group Board Audit Committee meeting due to an

unforeseen clash of meetings.

Additional regular attendees include the Group CFO, Group CEO, External

Auditor, Chief Audit Officer, Group CRO and the Group Company Secretary.

Number of Committee meetings

held this year (including ad hoc)

120 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Group Board Audit Committee reporting cycle

Q1 Q2

Q3 Q4

* These items were considered as part of the Joint Meeting Model, which was introduced in August 2025.

• Full Year 2024 results

• External targets

• External Audit update

• Internal Audit update

• Annual Control Assurance Opinion

• External Quality Assessment of Group Internal Audit

• Solvency Reporting

• Quarterly Actuarial Assumptions

• Internal Controls report

• Update from Chair of the Group and Life Companies

Board Risk Committees

• Full Year Internal Control Assessment report

• Appointment of new Chief AuditOfficer

• 2025 Half Year 2025*

• Half Year External Audit*

• Half Year illiquidity premium*

• FTP update*

• Half Year Control AssuranceOpinion*

• Internal Audit plan refresh*

• Quarterly Actuarial Assumptions*

• Solvency Reporting*

• External Auditor fees*

• LIST 2025 update*

• Internal Controls report

• Update from Chair of the Group and Life

CompaniesBoard RiskCommittees*

• Full Year 2025 External Audit Plan

• Solvency Reporting

• Internal Controls report

• Annual Quantitative Reporting template

• LIST 2025 update

• Base Balance Sheet governance framework

• Internal Audit update

• External Audit effectiveness review

• External Audit planningreport

• Joint Audit & Risk Committees – approved

theSolvency Financial Condition Report

• Group Tax Strategy

• Quarterly Actuarial Assumptions

• Whistleblowing update

• Update from Chair of the Group and Life

CompaniesBoard RiskCommittees

• Key financial reporting judgements

• External Audit update*

• Solvency Reporting*

• Internal Audit update*

• FTP scope review*

• Quarterly Actuarial Assumptions*

• LIST 2025 announcement review*

• Whistleblowing update*

• Update from Chair of the Group and Life

CompaniesBoard RiskCommittees*

121Standard Life plc Annual Report and Accounts 2025

Corporate governance

Outcomes from Committee discussions

On an annual basis, a review of the Committee’s activities is undertaken. In 2025, it was concluded that all elements of responsibility

detailed in the Committee’s Terms of Reference had been addressed. An overview of some of the significant activities undertaken

during the year and the way in which they contributed to important outcomes are detailed in the following table:

Key activities

Financial reporting Outcome

Strategic changes to

the Finance function

The Group CFO provided updates to the Committee on how the Finance function was

transforming to support the needs of the business. Review and challenge was given on the

embedding of the IFRS 17 process as well as control enhancements and new technology

solutions, supporting Group reporting, performance management and capital and liquidity

forecasting. The Committee also reviewed the new Finance organisational design model and

related Senior Management changes.

External financial

targets

The Committee reviewed performance against targets set in March 2024 and oversaw the work

supporting the proposed revisions to the external financial targets, which were approved by the

Group Board and announced as part of the Full Year 2024 results in March 2025.

Reporting Disclosure

Committee (‘RDC’)

The Committee monitored the implementation of the RDC which was formed to strengthen

Management’s oversight of all external reporting disclosures prior to Committee review. Thisallowed

all relevant internal stakeholders to strengthen confirmatory due diligence, challenge and review

processes before the Committee’s approval and recommendation ofcertain public disclosures.

Review of Going concern

andViability statements

Following review, the Committee approved the Viability statement. See page 84 to 85 and 178

respectively for the Group’s Going concern and Viability statement.

Fair, balanced and

understandable

The Committee satisfied itself that Standard Life plc’s 2025 Annual Report and Accounts was

fair, balanced and understandable. It did so by considering relevant FRC guidance, feedback

from various sources and robust challenge from a RDC formed of internal senior stakeholders.

The Committee can therefore concur with the declaration made bythe Board of Directors on

page 180 in line with Principle N of the 2024 Code.

Key estimates

andjudgements

Thorough review and challenge by the Committee. See significant matters on pages 125 to 126.

External audit Outcome

Re-appointment of

KPMG as External Auditor

The Committee noted the positive working relationship with KPMG and work undertaken since

its appointment as External Auditor in May 2024.

Internal controls Outcome

Monitoring the overall

integrity of financial

reporting by the Company

and its subsidiaries and

the effectiveness of the

Group’s internal controls

The Committee provided oversight of Management’s programme of work to upgrade and mature

the control environment, delivered through the FTP and business as usual initiatives, recognising

that further development is underway to prepare for the enhanced control effectiveness

reporting expectations under Provision 29 of the 2024 Code.

Whistleblowing (Speak Up) During 2025, a total of 29 concerns werereported. Of these, 18 were triaged as ‘Speak Up

Disclosures’, andwere investigated in accordance with established processes. Following triage

theremaining cases were referred to relevant functions and taken forward through appropriate

channels. Our investigations resulted in various recommendations for the business. Employee

survey scores indicated colleagues generally felt that the Group was a psychologically safe

environment where they can speak upfreely and had a strong belief that serious misconduct

would be dealt with appropriately. Whistleblowing will move under the remit of the Group Board

Risk Committee in 2026.

Private meetings Private meetings were held with the External Auditor, Chief Audit Officer, Head of Speak Up

(Whistleblowing) andGroup CFO.

Joint Meeting Model The Committee moved to a Joint Meeting Model in 2025, which will remain a focus in 2026 with

a view to continually improving the Committee’s effectiveness.

Full Year 2026 discretion Outcome

Application of discretion

toFullYear 2026

remunerationoutcomes

Read about the work

of theGroup Board

Remuneration Committee

on pages 136 to 137

During 2025, the Committee identified that, as a matter of good governance, it should review

the Company’s Full Year financial results, non-financial results and Management objectives

within the Committee’s remit before final remuneration outcomes were determined.

From 2026, the Committee will:

• Review the Full Year results and underlying performance.

• Consider whether formula-driven remuneration outcomes appropriately reflected performance.

• If any concerns within the Committee’s remit were identified, recommend that the Group

Board Remuneration Committee exercise its discretion to adjust variable pay outcomes.

Seepage 141.

Where relevant, all papers receive a Line 1, 2 and regulatory review.

The Committee also received education sessions as shown on pages 108 and 109.

Audit, risk and internal controls continued

Group Board Audit Committee report

122 Standard Life plc Annual Report and Accounts 2025

Corporate governance

External Auditor

The Group Board Audit Committee is

responsible for reviewing and overseeing

the work of the Group’s External Auditor.

KPMG was appointed on 14 May 2024

and re-appointed at the AGM on 13 May

2025. External Audit partners attended

all Committee meetings during 2025.

KPMG presented its audit plan and

strategy, setting out key milestones,

materiality thresholds, audit scope,

andsignificant risks. It also outlined its

approach to providing assurance over

theHalf Year results for the six months

ended 30 June 2025. The Committee

received KPMG’s findings from its review

procedures, followed by regular updates

and private sessions in preparation for

the Full Year 2025 results.

Audit Quality Indicators (‘AQIs’)

AQIs aim to provide users of audit

services with information regarding

factors contributing to audit quality,

and to complement other means of

assessment. KPMG has developed

proposed AQIs which focus on

inspections, engagement and team,

which were presented to the Committee

in May 2025. Regular updates were

provided to the Committee to

provide an indication of the direction

of travel, highlight improvements

in the management of information

requests and to identify further

opportunities for improvement in the

delivery of information for audit.

Assessment of the effectiveness

of the external audit process

Overall, the assessment of KPMG remains

positive and, where opportunities for

improvement have been identified

through the Committee’s annual

external audit effectiveness review,

KPMG have agreed to implement

these in future audit cycles. Based on

the formal evaluation and ongoing

monitoring, the Committee is satisfied

that KPMG remained independent and

objective and that the audit process

was effective. On this basis, the Group

Board will recommend KPMG’s re-

appointment as Auditor at the 2026 AGM.

Independence and objectivity

ofthe External Auditor

KPMG’s independence was reviewed

and monitored against the Group’s

External Auditor Policy, including

itsprovision of non-audit services.

The Committee remains satisfied with

KPMG’s objectivity, and that KPMG is

fully independent from Management

and free from conflicts of interest.

KPMG continually monitors its own

independence throughout the year

and voluntarily brings any potential

matter to the Committee. KPMG

confirmed its ongoing independence

and has stated that between

1 January 2025 and 13 March 2026

there were no relationships that

would be thought to bear on KPMG’s

independence and objectivity. KPMG’s

independent approach, including

threats and safeguards, is outlined

to the Committee when the audit

plan for that year is approved.

External Auditor Policy

The Company’s External Auditor Policy

safeguards auditor independence and

caps non-audit fees at 70% of the average

audit fees paid over the previous three

years. The policy was reviewed in 2025 to

reflect the FRC’s Revised Ethical Standard

with no significant changes required.

Thepolicy, available on our website,

covers audit partner rotation, employment

of former audit team members, and

permitted non-audit and audit-related

services. Permitted non-audit services

are those set out in the FRC’s Revised

Ethical Standard. In 2025, non-audit

services provided were ESGassurance,

assurance related to the Hong Kong

Branch’s Insurance Authority Levy for

the year ended 30 September 2025

and agreed upon procedures relating

to Standard Life International Dac.

The Group’s policy requires audit partner

rotation at least every five years in line

with the FRC’s Revised Ethical Standard.

Stuart Crisp became Audit Partner on

14 May 2024 and will be required to

rotate following completion of the

31 December 2028 audit. At the 2026

AGM, resolutions will propose KPMG’s

re-appointment and authorisation

for the Group Board to determine

remuneration, on the Group Board

Audit Committee’s recommendation.

External Auditor’s fees

The Committee reviewed the audit

fee proposal and discussed the factors

driving the fee level increase with the

External Auditor. The engagement of

the External Auditor to perform any

non-audit service is subject to a process

of pre-approval by the Committee

to safeguard the External Auditor’s

objectivity and independence and

the prescribed limit set out above

inline with statutory requirements.

Fees payable to

KPMG LLP 2025

£m

Non-audit fees 0.6

Audit fees 25.1

Audit-related fees 3.3

Total 29.0

Ratio of non-audit: audit fees 0.15:1

In 2025, total fees of £29.0 million

werepayable to KPMG. Of this amount,

£25.1 million related to statutory audit

fees of the parent and its subsidiaries

and £3.3 million was payable in respect

of audit-related services. The remaining

fees of £0.6 million related to other

services, including ESG assurance. This

gives rise to a non-audit to audit fee ratio

under the EU Directive and Regulations

of 15% for 2025. This lies well within

the limits prescribed in the Group’s

policy. The Committee challenged and

reviewed the KPMG fees for the 2025

audit to ensure the proposed figure

was appropriate prior to approval.

In light of the above, the Committee

is satisfied that the non-audit services

performed during 2025 have not

impaired the independence of KPMG

in its role as External Auditor.

Katie Murray

Chair of the Group Board

AuditCommittee

123Standard Life plc Annual Report and Accounts 2025

Corporate governance

Internal Audit

During 2025, the Committee continued to receive regular updates from the Chief Audit Officer on all Internal Audit-related matters.

This included:

Item Outcome

Internal Audit Strategy The Committee reviewed and approved the Internal Audit Strategy. This included the purpose,

vision and operating model for Internal Audit, aligned to Standard Life’s core purpose and

strategy. The strategy focused on harnessing data analytics and AI innovations and supporting

enhancements to overall Company risk and governance capabilities.

Internal Audit

functiondesign

In June 2025, the Chief Audit Officer presented the outcomes of a review of the Internal Audit

operating model, which considered the future skills needed in response to the evolution of

thebusiness and its risk profile. TheCommittee noted the proposed strategic changes to

theorganisational design, noting the importance ofensuring the function’s independence.

Theamendments to the operating model were actioned in 2025 andincluded reducing spans

andlayers across the function, removal of duplication, improved colleague engagement,

alignment with Line 2 and Line 1 risk categories and balancing the resource mix.

Internal Audit Plan,

budget,resources

andplanprogress

The Committee reviewed and approved the Internal Audit Plan and budget. Internal Audit’s

risk-based plan was aligned to Standard Life’s strategic priorities and core purpose. The

Committee monitored progress against the plan throughout the year. This included oversight

oftrends in findings, the status of management actions to resolve issues identified, the

ongoingadequacy of Internal Audit resources and progress against key performance metrics.

Private sessions were held with the Chief Audit Officer.

Internal Audit Charter The Internal Audit Charter was updated and approved by the Committee. This sets out Internal

Audit’s role, mandate, and independence and was drafted in line with the Global Audit

Standards and Internal Audit Code.

Control Assurance Opinion The Committee reviewed and challenged control assurance opinion reports which set out

Internal Audit’s view of the Risk Management, Governance and Control Framework at Half

Yearand Full Year. Controls assurance will continue to be a focus in 2026.

Internal Audit effectiveness The Committee reviewed and approved the Internal Audit strategy which is aligned to the

overall Standard Life strategy. An annual update was provided on Internal Audit effectiveness,

which included output from independent quality control, annual stakeholder effectiveness

surveys and progress of actions to further enhance Internal Audit activity. The Committee

received updates on strategic improvements made to the Internal Audit function throughout

the year. An external independent assessment of Internal Audit is completed every five years.

Audit, risk and internal controls continued

Group Board Audit Committee report

124 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Significant matters considered by the Committee in relation to the financial statements,

where KPMG was invited to provide robust challenge.

Significant matters in

relation to the 2025 IFRS

financial statements How these issues were addressed

Review of the IFRS and

Solvency II actuarial valuation

process, to include the setting

of actuarial assumptions

andmethodologies, andthe

robustness ofactuarial data

Management presented papers to the Life Companies Board Audit Committee detailing

recommendations for the actuarial assumptions and methodologies to be used for the Half

Yearand Full Year reporting periods, with justification and benchmarking as appropriate. This

included assumptions related to longevity, mortality, expenses, persistency and policyholder

behaviour, as well as economic assumptions. These assumptions and methodologies were

debated and challenged by the Life Companies Board Audit Committee, prior to their approval,

including consideration of the impacts of continued economic volatility, expense inflation and

data quality.

A summary of these papers was presented for oversight review by the Committee, and the

LifeCompanies Board Audit Committee’s conclusions were reported to the Committee through

minutes of its meeting and a discussion between the Chairs of the Committees. TheCommittee

discussed and questioned Management and KPMG on the content of the summary papers and

the Life Companies Board Audit Committee’s conclusions.

The Committee considered and debated the basis of the valuation for adjustments to actuarial

provisions that arise at a consolidated Group level, including the methodology and derivation

ofcertain IFRS 17 assumptions where calibrated on a Group basis. This included consideration

ofthe results of a detailed review of the Group’s maintenance expense assumptions in light

ofstrategic transformation and cost reduction initiatives. The Committee also evaluated the

determination of the IFRS 17 discount rate, including the appropriateness of the allowances

forilliquidity and credit risk, together with the calibration of the risk adjustment assumption.

Pension assumptions for use in the IAS 19 Employee Benefits valuations were reviewed and

approved by theCommittee.

The Committee received and considered detailed written and verbal reporting from KPMG

setting out their observations and conclusions in respect of the assumptions, methodologies

and actuarial models, including benchmarking analysis.

Valuation of complexand

illiquid financial assets

Management presented papers setting out the basis of the valuation of financial assets,

includingchanges in methodology and assumptions, for the Half Year and Full Year reporting

periods to the Life Companies Board Audit Committee. The assumptions, valuations and

processes, particularly for financial assets determined by valuation techniques using significant

non-observable inputs (Level 3), were debated and challenged by the Life Companies Board

AuditCommittee prior to being approved. This included a review of judgements made in respect

ofdata and inputs driving the valuation of equity release mortgages, assumptions utilised in the

valuation of modelled debt securities such as credit ratings and bond spreads, and the impacts

ofcontinued economic volatility.

The valuation information was then presented for oversight review by the Committee which

considered and further challenged the information prior to confirmation of the appropriateness

ofthe basis of valuation.

Valuation and recoverability

of intangible assets andthe

Parent Companyinvestment

insubsidiaries

Management presented papers detailing the results of annual impairment testing carried out

inrespect of goodwill balances and reviews for indicators of impairment performed in respect

offinite life intangibles and the Parent Company’s investment in its subsidiaries. Where indicators

of impairment were identified, Management provided an analysis of the recoverable amounts

determined and the assumptions and judgements underlying their calculation. This included

assessing the potential impact of the risk of climate change.

The Committee considered the results of the work performed and confirmed the appropriateness

of the conclusions reached.

Provisions Management presented papers detailing the basis of recognition and measurement of

accounting provisions recognised by the Group. The Committee considered the results of the

analysis performed, the uncertainties surrounding the measurements adopted and confirmed

the appropriateness of the conclusions reached.

125Standard Life plc Annual Report and Accounts 2025

Corporate governance

Significant matters considered by the Committee in relation to the financial statements,

where KPMG was invited to provide robust challenge.

Significant matters in

relation to the 2025 IFRS

financial statements How these issues were addressed

Alternative performance

measures (‘APMs’)

The Committee reviewed the use of APMs in the Group’s financial reporting, understanding

thebasis for determining the metrics and considering the clarity and explanation of their

usagewithin the Group’s Annual and Interim Reports.

On reviewing the results, the Committee provided challenge as to the allocation of amounts

toeither adjusted operating profit or to non-operating items for consistency with the Group’s

adjusted operating profit framework.

The Committee concluded that the usage, disclosure and prominence of APMs within the

Group’s Annual Report and Accounts was appropriate.

Assessment of whether

the Annual Report and

Accounts arefair, balanced

andunderstandable

The Committee considered and confirmed agreement with the analysis in support of

Management’s conclusions that the Annual Report and Accounts are fair, balanced and

understandable. As part of the year-end procedures, the Committee discussed with

Management and KPMG the review processes that operated over the production of the

AnnualReport and Accounts.

Going concern and

viabilityanalysis

The Committee reviewed information on the capital and liquidity position of the Group,

together with a review of the associated risks and supporting stress and scenario testing.

Thiswas part of a comprehensive assessment undertaken prior to the Committee

recommending to the Group Board that the Group financial statements should be prepared

on a Going concern basis and that the disclosures, with regard to the long-term viability of

theGroup, were sufficient and appropriate. Specifically, the Committee challenged the impact

of losses experienced in the Group’s IFRS results on the disclosures included in the Viability

statement in concluding on theirappropriateness.

Audit, risk and internal controls continued

Group Board Audit Committee report

126 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Internal Controls Statement

The Group Board is accountable for

ensuring that an appropriate and

effective system of risk management

and internal control is in place

across the Group. This framework

underpins the Group’s ability to deliver

sustainable performance, protect its

customers and respond effectively

to an evolving risk landscape.

Oversight of internal control is

undertaken jointly by the Group Board

Risk Committee and the Group Board

Audit Committee, with each Committee

reviewing and approving controls within

its respective terms of reference. This

co-ordinated governance structure

forms the basis for the Group’s internal

controls assurance and will support the

Provision 29 statement, as required

under the 2024 Code), contained within

the Group Board Audit Committee

section of the 2026 Annual Report.

The Group operates a well-established

‘three lines of defence’ model. Line 1 (the

Business) is responsible for risk ownership

and for maintaining effective processes,

procedures and controls. Line 2 (Risk

and Compliance) provides independent

oversight and challenge. Line 3 (Internal

Audit) provides objective assurance

over the design and effectiveness of the

internal control environment. Further

information on the Group’s approach to

risk management is provided in the ‘Our

Risk Management Framework’ section.

Throughout 2025, the Group continued

to operate its processes for identifying,

assessing, managing, monitoring and

reporting risks, and their related controls,

against approved risk appetites. A key part

of this activity was the bi-annual Internal

Control Self-Assessment (‘ICSA’), requiring

Senior Management to evaluate the

adequacy and effectiveness of the Group’s

internal control environment and to

identify areas that require strengthening.

TheICSA was independently validated

by Line 2 and supplemented by an

Annual Internal Control Environment

Opinion Report from Line 3. These

processes, alongside regular reporting

on control improvements across the

Group, support the Group’s adherence

to the 2024 Code’s provisions on risk

management and internal controls.

The Group continued to invest in

strengthening its control environment

during 2025, particularly in relation

to financial reporting, cyber security,

liquidity, capital and expense

management. In preparation for the

enhanced requirements under the

2024 Code, including Provision 29,

work continues in 2026 in these areas,

aimed at embedding a strong risk

and controls culture, supported by

technology enabled processes and

enhanced leadership engagement.

127Standard Life plc Annual Report and Accounts 2025

Corporate governance

Audit, risk and internal controls continued

Group Board Risk Committee report

Mark Gregory

Chair of the Group Board

and Life Companies

Board Risk Committees

Role and responsibilities

The Role of the Committee is shown on page 95

The Committee’s responsibilities and duties

can be found within its Terms of Reference,

which are available on the Company’s website.

Key Committee activities in 2025

• Monitored the risk profile against the risk appetite

andchallenged Management to continue enhancements

to risk reporting.

• Monitored external and emerging risks throughout

the year from macro-economic, political, regulatory,

competitive and technology perspectives.

• Reviewed and challenged the upgrades to the

Group’sexternal targets.

• Oversaw a detailed review of the risks to the

StrategicFinancial Business Plan including stress

andscenario testing.

• Challenged, before recommending, the Own Risk

andSolvency Assessment (‘ORSA’) to the Group Board

for approval.

• Monitored improvements to the control environment

including capital and liquidity Management Information.

• Monitored customer risk including the embeddedness

of Consumer Duty in the organisation.

• Monitored the Group’s cyber security risk including

the enhancement of our controls given the increased

prevalence of cyber-attacks.

• Oversaw the execution risk of the Group’s planned

change initiatives given the scale of investment in

change across the business.

2026 focus

• Continue to monitor the Group’s principal risks

andthe potential impacts to the organisation from

changes in the external environment.

• Provide effective oversight of the risk profile against

the risk appetite of the Group.

• Oversee the refresh of the Risk Appetite Framework

and the implementation of a simplified RMF including

the preparation forthe new obligations under

Provision 29 of the 2024 Code.

• Continue to oversee the execution of the planned

enhancements to managing market and liquidity risks.

• Continue to monitor cyber and AI risks and the

operational resilience of the Group.

• Continue to oversee the execution risk of the key

strategic change initiatives.

• Further monitor customer outcome reporting

andtheembeddedness of Consumer Duty.

• Take on responsibility for monitoring

whistleblowingupdates.

• Monitor risk culture, Consumer Duty and key

Management objectives within its remit. Where concerns

are identified, it will consider whether to recommend

to the Group Board Remuneration Committee that

discretion be exercised in respect of variable remuneration

outcomes, including reductions of up to 100%.

Committee meetings

and membership

Member

from

2025 meeting

attendance

2025 %

attendance

Mark Gregory 1 April 2023 7/ 7 100%

Karen Green

13 September 2024 6/7 86%

Belinda Richards

1 October 2017 4/4 100%

Eleanor Bucks

12 May 2025 5/5 100%

Karin Cook

25 August 2025 3/3 100%

1. Karen Green was unable to attend a Group Board Risk Committee meeting

due to a funeral.

2. Belinda Richards retired from the Group Board on 24 August 2025.

3. Eleanor Bucks became a member of the Group Board Risk Committee on

1 April 2025.

4. Karin Cook was appointed to the Group Board as a Dual Director on

25 August 2025 becoming a member of the Group Board Risk Committee

on this date.

Additional regular attendees include the Group CEO, Group CRO, Group CFO,

Chief Audit Officer, General Counsel and the Group Company Secretary.

Number of Committee meetings

held this year (including ad hoc)

128 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Risk Committee reporting cycle

Q3 Q4

* These items were considered as part of the Joint Meeting Model, which was introduced in August 2025.

• Group CRO report including Top Risks report

• Update on external market risks

• 2024 Final dividend

• External targets

• Group Recovery and ResolutionPlans

• Review of Annual Control Assessment and agreed

enhancements for 2025

• Update on RMF

• Review of Funded reinsurance strategy andrisks

• Group CRO report including Top Risks report*

• Interim Internal Control Self-Assessment

• Review of the competitive landscape of the BPA

market and Pensions and Savings market*

• Review of private debt macro risk*

• Review on cyber risks and control enhancements*

• Deep dive on specific change initiatives

• Review of customer risks and key action plans

• 2025 Interimdividend

• Approval of ORSA

• Group CRO report includingTopRisks report

• Review of the risks to management actions

• BPA Solvency based termination rights

• Macro-economic environment

• Group Money Laundering Risk Officer report

• Medium-term capital management plan

• Review of ORSA

• Risk culture framework

• Group CRO report including

Top Risksreport*

• Approval of new Capital Risk Appetite Framework

• Setting risk limits for leveraged sovereign

bondexposure*

• Cyber risks and control enhancements*

• Update from Chair ofStandard Life International

RiskCommittee*

• Customer risks and key action plans*

• Review of Strategic Financial Business Plan 2025–30*

• Reinsurance Counterparty Framework review*

129Standard Life plc Annual Report and Accounts 2025

Corporate governance

Outcomes from Committee discussions

On an annual basis, a review of the Committee’s activities is undertaken. In 2025, it was concluded that all elements of responsibility

detailed in the Committee’s Terms of Reference had been addressed. An overview of some of the significant activities undertaken

during the year and the way in which they contributed to important outcomes is detailed in the following table:

Key activities

Discussion Outcome

Operational and customer risk

Political, regulatory

andcompetitor risk

The Committee acknowledged the Group’s principal risks and the potential impacts to the

organisation from the macro-economic, regulatory, political and competitive landscape and

requested regular updates from Management. Deep dives were held on external risks at the

majority of Committee meetings in 2025.

Change delivery risk The Committee continues to recognise the importance of progress on projects designed to

transform areas of the organisation and to increase efficiency. Updates on key transformation

projects across the organisation were presented to the Committee throughout 2025.

Cyber risk and ability

torespond

The Committee monitored the impact of cyber risks and the ability of the organisation to

respond appropriately to an attack given the increasing nature of the risk. The Committee

reviewed the outcomes of the ExCo cyber crisis simulation, which took place in September.

Financial and strategic risk

Final and Interimdividends The Committee took responsibility for robustly challenging the affordability of the payment of the

2024 Final and 2025 Interim dividend ahead of recommending to the Group Board for approval.

Funded reinsurance In July 2024, the PRA published SS5/24, directed to all life insurers to outline their expectations

for managing risks associated with funded reinsurance. The Committee received a deep dive on

the Company’s Funded Reinsurance Strategy, with an update provided following market-wide

information from the regulator in September and an updated framework in November.

Climate and environmentalrisk From 2026, it was agreed the Committee would have responsibility for monitoring climate risk and its

potential impact on the organisation. The oversight of climate risk would sit with the Group Board.

Asset management strategy The Committee reviewed the operational risks related to the shift to an in-housing model for

annuity-backing assets. After robust challenge from the Committee, the Group announced

initsHalf Year 2025 results that it was preparing to in-house a further c.£20bn of assets.

Risk Management Framework

Effectiveness of the RMF The Company commissioned an external review of the RMF in Q4 2024. Throughout 2025,

theCommittee provided oversight of the changes and improvements which will continue

throughout 2026.

Full Year 2026 Underpin

Application of discretion

totheFull Year 2026

remunerationoutcomes

Read about the work of the

Group Board Remuneration

Committee on pages 136

to 137

During 2025, the Committee identified that as a matter of good governance, it should continue

to review the Group’s risk culture through the CRO Report and Management objectives within

the Committee’s remit. From 2026, before remuneration variable outcomes are determined,

the Committee will:

• Review the Half Year and Full Year CRO Report, that includes Consumer Duty.

• Consider whether formula-driven remuneration outcomes appropriately reflected performance.

• If any concerns within the Committee’s remit are identified, recommend the Group Board

Remuneration Committee exercise its discretion to adjust variable pay outcomes. See page 141.

The Committee also received education sessions as shown on pages 108 to 109.

Audit, risk and internal controls continued

Group Board Risk Committee report

Group CRO report

At each meeting, the Committee receives

a formal report from the Group CRO

which contains an assessment of the top

risks against the Group’s risk appetite,

as well as an overview of the current

and emerging risks to the organisation.

This also provides an update on the

plan to deliver enhancements to

the RMF throughout the year.

During the year, the Committee

maintained focus on the macro-economic

and geopolitical environment, and

the potential risk events that could

crystallise, challenging management on

whether the appropriate mitigations

are in place. A key focus in 2025 was

implementing a Joint Meeting Model

for the Group and Life Companies

Board Risk Committees, which has

streamlined discussions, strengthened

governance processes, enhanced

efficiency and fostered meaningful

dialogue between members. The

Committee continued to focus on

overseeing non-financial risks such as

cyber risk, operational resilience and

execution risk in delivering the change

agenda. A summary of the principal

risks and uncertainties facing the Group

can be found on pages 80 to 83.

Customer risks

The Committee received regular

customer outcome reporting with

an outline of the customer risks

and plans to mitigate them. This

report was accompanied by an

update from the Group Compliance

Officer. In addition, the Committee

reviewed the Consumer Duty Annual

Assessment before recommending

to the Board for approval. Monitoring

the embeddedness of the Group’s

Consumer Duty plans was a key focus

in 2025 and this will continue in 2026.

Mark Gregory

Chair of the Group Board and Life

Companies Board Risk Committees

130 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Joint Audit, Risk and Sustainability Committee report

Key Committee activities in 2025

• Oversaw the disclosures within the Sustainability

Report and the integration of climate risk (including

the requirements as set out by the Taskforce on

Climate-related Financial Disclosures) reporting

within the Annual Report, in place of a standalone

Climate Report. Ensure that disclosures provide all

information required by the market.

• Continuously reviewed climate risk.

• Monitor requirements and implementation of ESG

reporting frameworks, where required, including

Taskforce on Nature-related Financial Disclosures,

UKSustainability Reporting Standards and Corporate

Sustainability Reporting Directive, and receive

updates on new and evolving regulation.

• Continuously challenged and reviewed the processes

followed to produce sustainability disclosures.

• Education session on the risk and impact of tipping

points upon the future world, economy and financial

services sector.

• Challenged assurance and controls around

sustainability reporting.

2026 focus

• From 1 January 2026, a separate Committee

will no longer be required, and its

responsibilities will be allocated to existing

governance structures. Sustainability

reporting and related controls will fall under

the Group Board Audit Committee, while

oversight of climate-related matters,

including the principal risk of climate and

climate risk stress testing, will be managed

by the Group and Life Companies Board Risk

Committees. The Group Board Sustainability

Committee will focus on the sustainability

content and disclosures as well as oversight

of the Group’s climate and nature ambitions.

Committee meetings

and membership

Member

from

2025 meeting

attendance

2025 %

attendance

Karen Green 1 January 2024 2/2 100%

Mark Gregory 1 January 2024 2/2 100%

Katie Murray 1 January 2024 2/2 100%

Eleanor Bucks

1 April 2025 1/1 100%

Karin Cook

25 August 2025 1/1 100%

Belinda Richards

1 January 2024 1/1 100%

Maggie Semple 1 January 2024 2/2 100%

Nicholas Shott

1 January 2024 1/1 100%

1. Eleanor Bucks became a member of the Group Board Risk Committee on

1 April 2025 and the Group Board Audit Committee on 25 August 2025.

2. Karin Cook was appointed to the Group Board as a Dual Director on

25 August 2025, becoming a member of the Group Board Risk Committee

and Group Board Sustainability Committee on this date.

3. Belinda Richards retired from the Group Board on 24 August 2025.

4. Nicholas Shott retired from the Group Board on 30 June 2025.

Additional regular attendees included the Group CFO, Group CRO,

Director of Corporate Affairs and Brand, and the Group Company Secretary.

Climate risk, its controls relating

toreporting and climate risk

reporting will continue to evolve

and be a focus for 2026.

Katie Murray

Chair of the Group Board Audit Committee

Number of Committee meetings

held this year (including ad hoc)

131Standard Life plc Annual Report and Accounts 2025

Corporate governance

Outcomes from Committee discussions

Bi-annual joint meetings of the Audit, Risk and Sustainability Committees focused on reviewing sustainability reporting disclosures,

internal and external assurance (including Line 2 opinions), climate risk and regulatory implementation.

The Chairs of the Group Board Audit, Group Board Risk and Group Board Sustainability Committees rotate at each meeting in that

order to allow each Chair to provide a different perspective. Since the Joint Meeting Model was implemented from 25 August 2025,

the Life Companies Board Risk Committee members have joined for risk-related items, including climate risk and stress testing.

Key activities

Activity Outcome

Full Year 2024

Sustainabilityreporting

The Climate Report was discontinued, with all relevant content integrated into the Sustainability

and Annual Reports. The balance of information across reports has evolved for the Full Year

2025 process, with increased signposting. Sustainability strategy framing has aligned with the

Standard Life brand, a new social impact target shapes the content, and disclosures are enhanced

where possible to align to regulatory requirements.

Climate risk stress testing Nature risk would be included in the risk appetite statement. Given the breadth of climate risk

the Committees requested that consideration be given to separating the Group’s appetite for

climate risk as it related to its balance sheet and investment portfolio, from climate risk relating

to its operations.

Evolving role of

Financefunction

The initial transition work commenced to increase the role of the Finance function, including

assurance ownership and development of an ESG data control framework across assured

metrics in the 2025 ARA. An implementation plan based on a gap analysis commissioned to

Deloitte in October 2025, along with the plan to design and implement the internal controls

tosupport an approved sign-off process of the 2026 annual sustainability disclosures (both

subject to assurance and not) was presented to the Joint Group and Life Companies Board

Audit Committee in March 2026. This will continue to be an evolving focus of the Committee

in2026.

Education session –

tippingpoints

The session highlighted the underestimated impact of climate tipping points, which are

notwell captured by linear climate scenario models commonly used by financial institutions.

The Committee discussed how tipping points could affect future asset values, as well as

theirbroader geopolitical and macro-economic implications.

Climate risk Known areas of development included forward-looking financial metrics to monitor exposure,

assessment of the Group’s exposure to physical risk, and scenario analysis given the industry-

wide challenges in modelling climate change over the short to long term. The review highlighted

the need to evolve climate risk from a cross-cutting risk consideration into a defined component

of the RMF.

Climate change risk

During 2025, climate risk became

a standing agenda item for the

Committees’ meetings. The CRO

explained that Standard Life continues

to develop its approach to scenario

analysis and embedding climate risk

within its RMF in line with SS3/19

‘Enhancing bankers’ and ‘insurers’

approaches to managing the financial

risks from climate change’ and allowing

challenge on climate risk appetite

by the Committees’ members.

Katie Murray

Chair of the Group Board

AuditCommittee

Mark Gregory

Chair of the Group Board and Life

Companies Board Risk Committees

Karen Green

Chair of the Group Board

SustainabilityCommittee

Audit, risk and internal controls continued

Joint Audit, Risk and Sustainability Committee report

132 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Sustainability Committee report

Karen Green

Chair of the Group Board

Sustainability Committee

Role and responsibilities

The Role of the Committee is shown on page 95

The Committee’s responsibilities and duties

can be found within its Terms of Reference,

which are available on the Company’s website.

Key Committee activities in 2025

• Agreed and measured progress against the Group’s

Sustainability Strategy, in the context of external

policyand market developments.

• Approved a social target to support strategic

objectives, differentiate the Group’s brand and

continue to embed the customer-first mindset.

• Assisted the Group Board with the close monitoring

of the Group’s culture.

• Challenged the proposals for the Group’s updated

NetZero Transition Plan, for publication in March2026.

• Oversaw the Group’s thought leadership plans, which

detailed the intention to continue to advocate for

changeacross priority sustainability themes.

• Received education sessions on relevant existing and

emerging sustainability-related issues and trends.

• Considered the repositioning of the ESG and

employee engagement AIP and LTIP metrics from

standalone to ahard underpin metric as part of the

Directors’ Remuneration Policy review.

2026 focus

• Continue to monitor and challenge progress against

the Sustainability Strategy in the context of external

developments and emerging best practice.

• Oversee the key actions to support the delivery of the

long-term social target and how these are embedded

in the organisation.

• Oversee the second iteration of the Net Zero

Transition Plan, monitor progress in delivery and

provide challenge to key strategic activities.

• Monitor progress on priority sustainability themes

and any required response to evolving external

reporting and regulatory requirements.

• Oversee Management’s thought leadership and

engagement with stakeholders to effect change in

policy and market developments to unlock societal

impact and better customer outcomes.

• Further embed and monitor ESG and related

Management objectives that could impact the AIP

andLTIP outturns and make recommendations to the

Remuneration Committee as part of the Full Year

2026 remuneration underpin.

Committee meetings

and membership

Member

from

2025 meeting

attendance

2025 %

attendance

Karen Green 1 December 2020 5/5 100%

Nicholas Shott

1 December 2020 3/3 100%

Maggie Semple 1 September 2022 5/5 100%

Karin Cook

25 August 2025 2/2 100%

1. Nicholas Shott retired from the Group Board as a Director of the Company

on 30 June 2025.

2. Karin Cook was appointed to the Group Board as a Dual Director on

25 August 2025 becoming a member of the Group Board Sustainability

Committeeon this date.

Additional regular attendees include the Group CEO, Chair of the

GroupBoard, Chief Sustainability Officer, Director of Corporate Affairs

&Brand and the Group Company Secretary.

Number of Committee meetings

held this year (including ad hoc)

133Standard Life plc Annual Report and Accounts 2025

Corporate governance

Sustainability Committee report

Sustainability Committee reporting cycle

Q3 Q4

• Approval of Sustainability Strategyand targets

• Update on the sustainability organisational

designmodel

• Approval of the DE&IStrategy

• People, culture and DE&Iupdate

• Report from DNED

• Progress update againstthe NetZero

Transition Plan

• Forward plans for thought leadership

• Quarterly Chief Sustainability Officer report

• Review of long-term social target initial analysis

• People, culture and DE&Iupdate

• Report from DNED

• Net Zero Transition Plan outline content

and messages

• Deep dive on business travel

• Review of Net Zero investment proposition

development

• Quarterly Chief Sustainability Officerreport

• Recommendation of the Stewardship Report

to the Group Board

• Recommendation of the Modern Slavery,

HumanRights and Supply ChainStatement to

theGroup Board

• State of the nation review of 2030climate targets

• Review of the roadmap toinvest £40bn in

sustainabletransition andproductive assets

• Externally facilitated education session:

ModernSlavery: Ten years on fromthe inception

ofthe Modern Slavery Act 2015

• Quarterly Chief Sustainability Officerreport

• 2026 Sustainability Strategy framing and double

materiality assessment results

• ESG litigation update

• Approval of changes tothe ESGSupplier Standards

• Approval of long-term social targetapproach

• Forward plans on nature and recommendation

ofnature position statement to the GroupBoard

• Recommendation ofcarbon creditposition

statement totheGroup Board

• Quarterly Chief Sustainability Officerreport

• Externally facilitated education session: DE&I

horizon scanning

I am proud of the strong partnership between

the Committee and Management over the last

five years, which has been central to driving

meaningful sustainability progress.

Karen Green

Chair of the Group Board Sustainability Committee

134 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Outcomes from Committee discussions

On an annual basis, a review of the Committee’s activities is undertaken. In 2025, all elements of responsibility detailed in the Committee’s

Terms of Reference were addressed. An overview of some of the significant activities undertaken during the year and the way in which

they contributed to important outcomes is detailed in the following table:

Key activities

Discussion Outcome

Modern Slavery Statement The Committee received an externally facilitated education session on Modern Slavery inthe 10years since the inception of

the Modern Slavery Act 2015. The Committee challenged the disclosures within the draft statement andreviewed the gap

analysis against the CCLA Modern Slavery Benchmark. The Committee supported and strongly advocated for the organisation

to aimfor an improved CCLA rating. The Group received confirmation in November 2025 that ithad attained a Tier 2

‘demonstrating evolving good practice’ rating from the CCLA following the release ofits 2025 Modern Slavery Statement.

Culture monitoring and DE&I

Read about how the Group Board

monitorsculture onpages98 to 99

Read about Maggie Semple’s

work as DNED and Workforce

engagement on pages 104 to 105

The Committee reviewed DE&I as part of its quarterly updates and noted the rollback of DE&I initiatives in the US due

to the macro-political environment. The Committee requested anexternally facilitated education session on DE&I

horizon scanning, which was held in November 2025. Going forward, DE&I data will be presented to the Joint Group

and Life Companies Board meetings alongside the bi-annual culture update and the DNED workforce engagement

update, intended to provide a holistic view of the colleague experience.

Long-term social target The Committee challenged the initial analysis for the long-term social target, noting that the target should be more

stretching. The team was encouraged to go away and revert with more ambitious targets. The Committee reviewed

the target again in November. The Group Board approved the target in February 2026.

ESG litigation The Committee held a session on ESG litigation and its global impact, noting the rise invarious types of cases being

brought against companies and the associated risks, including reputational, commercial, and financial. The Committee

requested a separate session on fiduciary duties case law, which will be scheduled for 2026.

ESG Supplier Standards While reviewing changes to the ESG Supplier Standards in November, the Committee requested adeep dive on the

process for ensuring that modern slavery and human trafficking were eliminated from the supply chain. This session

will take place in 2026.

ESG link to executive remuneration ESG performance forms part of executive remuneration and is overseen by the Group Board Sustainability Committee.

Having analysed the implications for external benchmarking, index positioning and long-term investor outcomes, and

after consulting our major shareholders and engaging with ESG rating agencies, the Group Board Sustainability

Committee concluded that the proposed approach for 2026, as part of the Directors’ Remuneration Policy review, which

is to be tabled for shareholder approval at the 2026 AGM, appropriately aligns ESG delivery with executive accountability

and sustainable value creation.

Application of discretion to Full Year

2026 remuneration outcomes

Read about the work of the Group

Board Remuneration Committee

on pages 136 to 137

The Group Board Sustainability Committee will continue to review progress against the Group’s ESG targets quarterly,

and, as part of its review, also continue to consider annually whether formula-driven remuneration outcomes reflect

performance appropriately. The Group Board Sustainability Committee determined that selected ESG metrics would be

included as a hard underpin for the Full Year 2026 outturn. In particular, it will consider, if the selected Group Net Zero

Transition Plan targets and commitments have not been met during the year, recommending to the Group Board

Remuneration Committee that it exercise its discretion to adjust variable pay outcomes. (See page 141). The Group Board

Sustainability Committee may propose a downward adjustment to remuneration of up to 100% based on its assessment.

Full Year 2026 ESG metrics

and targets for Executive

Directors remuneration

For the 2026 LTIP (evaluated FY2028) the Group Board Sustainability Committee’s recommendation will include an

assessment of whether the following two targets relating to our Net Zero Transition Plan ambitions have been met:

(i) Investment portfolio intensity reduction of -40%, and (ii) 50% of shareholder private assets originated which are

deemed to be sustainable, transition or productive (evaluated over three years).

The Committee also received education sessions as shown on pages 108 to 109.

Monitoring progress against

ourNet Zero Transition Plan

The Group believes that transitioning to

net zero will deliver better outcomes for

our customers, which is why we are

committed to being a net zero business by

2050, with interim targets in place for 2025

and 2030. The transition to a low carbon

economy presents both risk and

opportunity for our customers’ financial

futures and we recognise our responsibility

to act. Throughout 2025, the Committee

received regular updates on progress

against the Net Zero Transition Plan.

As part of this, the Committee reviewed

and approved the Group’s third Stewardship

Report, which sets out the focus on

effective stewardship and the intention

to have a positive effect on action on climate

change and other ESG priority topics.

TheGroup’s second iteration of the Net

Zero Transition Plan will be published in

2026 and has been a key focus of challenge

for the Committee throughout 2025.

Assessing materiality

During 2025, the Committee supported

management in conducting a double

materiality assessment to ensure the

Company’s 2026 Sustainability Strategy

focused on the most material ESG topics.

The assessment considered market

trends, regulatory developments, peer

priorities, and stakeholder expectations.

The results confirmed that the highest-

ranking ESG topics identified in the

previous 2024 assessment remain largely

unchanged, with some minor adjustments.

Key drivers of change include an increased

emphasis oncustomer engagement

following the rebrand to Standard Life,

the growing interconnection between

climate and nature, ongoing ESG-related

political headwinds, and the rising impact

of cyberrisks and AI. Further details on

the assessment outcomes are available

inour Sustainability Report on the

Group’s website.

It has been a pleasure to chair the Group

Board Sustainability Committee since its

inception five years ago. I retire from the

Board at the end of June 2026 and I would

like to thank my fellow Committee members

and executive colleagues for the

meaningful progress made in realising

the Group’s sustainability objectives.

Karen Green

Chair of the Group Board Sustainability

Committee

135Standard Life plc Annual Report and Accounts 2025

Corporate governance

Directors’ Remuneration report

Sherry Coutu CBE

Chair of the Group Board

Remuneration Committee

Role and responsibilities

Key Committee activities in 2025

• Completed a comprehensive review of the 2026

Directors’ Remuneration Policy (‘Remuneration

Policy’), which is subject to approval at the 2026

Annual General Meeting (‘AGM’). The review focused

on ensuring that the new Remuneration Policy

supports strategy execution and the attraction

andretention of market leading talent.

• The Annual Incentive Plan (‘AIP’) and Long Term

Incentive Plan (‘LTIP’) metrics were streamlined to

ensure they also aligned with our forward-looking

strategy, purpose and values.

• Engaged with shareholders and stakeholders (both

internal and external) on the Remuneration Policy

proposals. The Committee considered all feedback

received and reflected it in the final proposals

whereappropriate. This is outlined on page 142.

• Assessed AIP and LTIP performance outcomes,

ensuring alignment with risk, the wider stakeholder

experience and performance context.

• Reviewed and approved the remuneration

policiesand practices for all colleagues within

theCommittee’s remit.

2026 focus

• Approval of the Remuneration Policy by shareholders.

• Implementation of discretionary underpin

framework process for 2026 incentive outturns.

• Approval of colleagues’ compensation to ensure

the attraction and retention of market-leading

talent as we continue our ongoing transformation

and organisation design.

• Monitor and review remuneration arrangements

toensure they remain aligned to market practice

andour Standard Life strategy.

• Listen to the voice of the wider workforce

on remuneration through the Board’s

DesignatedNon-Executive Director (‘DNED’)

for Workforce Engagement and the Chair of

the Group Board Remuneration Committee.

Committee meetings

and membership

Member

from

2025 meeting

attendance

2025 %

attendance

Sherry Coutu CBE

1 May 2025 5/5 100%

Nicholas Shott

20 October 2016 4/4 100%

Karen Green 1 July 2017 7/ 7 100%

Belinda Richards

2 July 2019 4/4 100%

Maggie Semple OBE 1 January 2024 7/ 7 100%

Mark Gregory

1 December 2025 0/0 0%

1. Sherry Coutu became a member of the Committee on 1 May 2025

andChairof the Committee on 1 July 2025.

2. Nicholas Shott retired from the Group Board on 30 June 2025.

3. Belinda Richards retired from the Group Board on 24 August 2025.

4. Mark Gregory became a member of the Committee on 1 December 2025.

Additional regular attendees include the Group CEO and Group Chief

PeopleOfficer.

Number of Committee meetings

held this year (including ad hoc)

The Role of the Committee is shown on page 95

The Committee’s responsibilities and duties can

be found within its Terms of Reference which are

available on the Company’s website.

136 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Our new Remuneration Policy

reflects deliberate ambition and

responsible stewardship. In a fiercely

competitive and rapidly evolving

market we have set a higher standard

– aligning Executive reward with

exceptional customer outcomes,

disciplined performance and

sustainable shareholder value.

Because safeguarding the long-term

security of our policyholders

underpins the strength and

enduringsuccess of the Company.

Sherry Coutu CBE

Chair of the Group Board Remuneration Committee

Company performance snapshot

Outturn of 2025 Group AIP

(all employee) scorecard

87.9%

Outturn of 2023 LTIP

68.4%

Remuneration Committee review cycle

Q3 Q4

• 2025 Full Year Group Chief Risk Officer

(‘Group CRO’) report

• Approval of 2024 AIP and 2022 LTIP outturns

• Executive Director and Executive Committee

(‘ExCo’) 2024 performance ratings

• Approval of 2025 AIP and LTIP metrics and targets

• Approval of 2025 share awardgrants

• 2025 Half Year Group CROreport

• Approval of 2025 share award grants

• Monitoring 2025 AIP outturn and in-flight LTIP awards

• Review of Remuneration Policy

• Chief Executive Officer (‘Group CEO’) and Chief

Financial Officer (‘Group CFO’) benchmarking

• Review of market trends and AGM results

• Review of Remuneration Policy

• Review of 2026 AIP and LTIPmetrics

• Review of the discretionary share plans

• Review of shareholder feedback following

the Remuneration Policy consultation

• Review and approval of the 2026

shareholding guidelines

137Standard Life plc Annual Report and Accounts 2025

Corporate governance

1 Jan

2024

1 Apr

2024

1 Jul

2024

1 Oct

2024

1 Jan

2025

1 Apr

2025

1 Jul

2025

1 Oct

2025

1 Jan

2026

Standard Life plc

Benchmarking sectoral peers

(median)

FTSE 100

FTSE 350 (excl. IT)

170

160

150

140

130

120

110

100

Directors’ Remuneration report continued

Chair’s statement

Dear Shareholder,

On behalf of the Board, I am pleased to

present the Directors’ Remuneration

report for the year ended 31 December

2025. As the newly appointed Chair

of the Group Board Remuneration

Committee from 1 July 2025, I wish

to extend my thanks to Nicholas

Shott for his work as Remuneration

Committee Chair since 2023.

This year we are asking shareholders

to vote on the following remuneration

resolutions at our 2026 AGM:

• The Directors Remuneration Policy

(‘Remuneration Policy’), which outlines

the remuneration framework that will

apply to our Executive Directors,

Non-Executive Directors and the Group

Chair, should it be approved by our

shareholders; and

• The Annual Report on Remuneration

(‘Remuneration report), which sets out

remuneration outcomes for 2025 and

explains how we intend to apply the

Remuneration Policy in 2026.

Remuneration outcomes

for2025

We made strong strategic progress in

2025, the second year of our 3-year

strategy, delivering robust financial

performance across our financial

framework of cash, capital and earnings:

• Delivered £1.7 billion of Total

CashGeneration for FY2025 on track

tomeetour 2024–26 cumulative

£5.1billion target.

• Robust balance sheet position with our

Solvency II (‘SII’) Shareholder Capital

Coverage Ratio (‘SCCR’) of 176%,

remaining in the upper half of our

140–180% operating range.

• Growth in operating profit for the year

of 15% to £945 million, supported by

the continued delivery of cost savings

as we progress towards our £250

million cost savings target by the end

of 2026.

• Strong shareholder returns in the year

with closing share price up 44% on

opening position.

• Continued execution on strategic

priorities, including strong business wins

and ongoing focus on building out our

ability to engage with our customers.

The strong financial performance,

alongside strategic progress, made in

2025 has resulted in an overall formulaic

outcome of 84.8% of maximum under

the AIP for Andy Briggs, Group Chief

Executive Officer (‘Group CEO’), and

Nicolaos Nicandrou, Group Chief

Financial Officer (‘Group CFO’). This was

due to achieving 100% in all financial

performance outcomes, 60% of

maximum in non-financial performance

outcomes, and 72.25% of maximum

under the Strategic Scorecard.

The 2023 LTIP award covering the years

2023–2025 has an overall formulaic

outcome of 68.4% of maximum through

achieving 70% of maximum under

the financial performance outcomes

and 62% of maximum under the non-

financial performance outcomes.

The Committee reviewed the AIP and

LTIP outcomes in the context of the

Group’s performance, individual

performance, strategic delivery and the

experience of broader stakeholders.

Overall, the Committee was satisfied that

the AIP and LTIP outcomes were reflective

of performance and no discretion has

been applied by the Committee in

respect of incentive outcomes.

Remuneration Policyreview

As signalled in our Directors’

Remuneration report last year, during

2025 the Committee undertook a

comprehensive review of the existing

remuneration framework, in line with

the normal 3-year cycle. Our review

centred on ensuring that remuneration

arrangements incentivise and retain

our Executive team to continue to

execute our strategy and to achieve

our vision of being the UK’s leading

retirement savings and income business.

Given the 2024–2026 strategy

concludes next year, the Board will

undertake a review of our strategy

for FY2027 and beyond, with a focus

on accelerating our drive to meet

more of our existing customer needs,

acquire new customers and deliver

better outcomes for stakeholders.

We are uniquely positioned to capture

momentum in a growing market, and

retaining our high-performing Executive

team to lead the business through the

next phase is a priority. We operate

within a highly competitive sector and

attracting and retaining Executives with

the requisite sector knowledge is very

challenging, in particular in an evolving

landscape affected by regulatory and

artificial intelligence disruption.

Andy Briggs is a highly valued and

experienced Group CEO who is

successfully driving forward the

transformation of our business. In

December 2024, we announced the

appointment of Nicolaos Nicandrou as

our Group CFO. Nicolaos is an exceptional

and highly regarded leader, with extensive

insurance, asset management and

executive leadership experience in the

FTSE 100. The Board was delighted to

appoint an individual of his calibre and

is pleased with the excellent progress

that Andy Briggs, Nicolaos Nicandrou

and the wider Executive team are

making in advancing our strategic

priorities with pace and purpose.

As part of the review, we consulted

extensively with 34 of our largest

shareholders, representing 75% of

share ownership, and both proxy and

environmental, social and governance

(‘ESG’) agencies. Overall, the majority

of shareholders were supportive of

our proposals and we highly value the

feedback and views shared. A summary

of the context against which the

Committee reviewed the Remuneration

Policy is set out below, as well as detailed

changes proposed to both the Policy and

performance measurement framework.

Standard Life (formerly Phoenix Group Holdings plc) Total Shareholder

Return since FY2024–26 strategy launch (Jan 2024 to date)

138 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Group CEO – current

Lower quartile Upper quartileMedian

Standard Life – market capitalisation

Lower quartile Upper quartileMedian

Performance context and

businesstransformation

Since the launch of our strategy in 2024,

Standard Life plc has delivered total

shareholder returns of 67%, materially

inexcess of the FTSE 350 (excluding

investment trusts) (36.5%) and FTSE 100

(38%) returns, as well as the median of

sector peers. We are over two-thirds of

theway through our 3-year strategic cycle

and pleased with the strong progress.

Wehave consistently executed against our

strategic priorities, and we are seeing our

businesses winning in their markets and

growing organically, delivering against

allour financial targets. This strong

performance and operating momentum

issupporting the progress of our strategy

and delivery gives us the financial flexibility

to reduce our leverage, while also

sustaining our progressive dividend policy.

Changing our name from Phoenix Group

Holdings plc to Standard Life plc brings

our most trusted brand to the forefront –

helping to simplify our business, unify our

colleagues, and strengthen our brand.

Our sector peers and marketpositioning

As part of the review, the Committee

carried out a review of arrangements

against relevant sector peers and was

mindful of the need to ensure that our

remuneration framework is competitive

and fit for purpose across the next

3-year policy cycle. The Committee

carefully considered market data to

ensure that it was appropriate taking into

account Standard Life’s size, complexity,

sector and talent market, as well as our

context as a UK FTSE-listed business.

Given Standard Life’s business focus,

there are a limited number of firms

which would be considered primary

sector comparators. To ensure a peer

group of robust size and reflecting

the markets in which we compete for

talent across the organisation, we

developed a benchmarking peer group

consisting of firms with a broader

insurance and asset management focus,

as summarised in the table below.

Other insurers and asset managers

including Admiral Group, Lancashire

Holdings and Schroders were excluded

on the basis of speciality focus, location

and/or nature of operations.

Sector peers – current market

positioning

A review of market positioning of the

Group CEO’s current package against

market peers demonstrated that this was

below the lower quartile of our sector

peers. Andy Briggs will enter his sixth year

as Group CEO with a strong track record

of performance over this period and the

Board believes he will play a critical role in

leading the next phase of our strategy.

Remuneration Policy proposals

We believe that the combination of

the AIP and LTIP continues to support

the delivery of our customer-focused

and performance-driven strategy,

aligning pay with the interests of wider

stakeholders. As such, we are not

proposing to change the overall incentive

framework. Having carefully considered

several alternative remuneration

structures, the Committee concluded

that the current structure remains

appropriate for the business at this time.

For the 2026–28 cycle, the Committee is

proposing to implement the following

changes to the Remuneration Policy:

• Long Term Incentive Plan: increase

the maximum LTIP opportunity to

425% of salary (from 275% of salary),

with the removal of the previous

exceptional maximum limit of 400%

ofsalary. The maximum LTIP

opportunity for the Group CEO will

increase to 425% of salary for 2026.

There is no change to maximum

opportunity for LTIP for the Group CFO.

• Shareholding requirements:

increase the Group CEO shareholding

requirement from 350% to 425%

ofsalary, in line with the revised LTIP

maximum, and retain the Group CFO

shareholding requirement of 300%

ofsalary.

• Malus and clawback: expand our

malus and clawback provisions to

enable us to recover remuneration

inthe event of a material downturn

infinancial performance or errors

incalculation, and extend malus and

clawback time horizons on share plans

to seven years.

In line with the principle of aligning pay

tolong-term investor and policyholder

outcomes, we are not proposing to make

any changes to the AIP maximum levels

which will remain at 200% for the Group

CEO andGroup CFO.

Group CEO – current target total compensation vs sector peers

Standard Life plc – market capitalisation vs sector peers

Selection of benchmarking peer group

Sector Company

Size – market

capitalisation Size – employees

Operations –

geographical focus

Talent market

alignment

Insurers

Aviva

Beazley

Hiscox

L&G

Prudential

Asset managers

Aberdeen

M&G

Quilter

Rathbones

St. James’s Place

Peers within x0.5 – x2.0 of Standard Life equivalent values where criteria is numerical based.

Peers less/greater than x0.5 – x2.0 of Standard Life equivalent values where criteria is numerical based.

139Standard Life plc Annual Report and Accounts 2025

Corporate governance

Group CEO

Current

£3.0m

£3.8m

29%

39%

32%

24%

50%

26%

Group CEO

Proposed

Fixed pay

AIP

LTIP

4.5

4.0

3.5

3.0

2.5

2.0

1.5

1.0

0.5

£m

Group CEO

Current

£5.1m

£6.5m

34%

47%

19%

37%

58%

15%

Group CEO

Proposed

7.0

6.0

5.0

4.0

3.0

2.0

1.0

Fixed pay

AIP

LTIP

£m

£0m £1.0m £1.5m £2.0m £2.5m £3.0m £3.5m £4.0m £4.5m £5.0m

£5.5m

£0.5m

Prudential

Aviva

L&G

M&G

Standard Life plc – Proposed

Aberdeen

Beazley

Hiscox

Standard Life plc – Current

St. James’s Place

Quilter

Rathbones

Fixed pay LTIP targetAIP target

Median

Upper

quartile

Lower

quartile

Total Group CEO target compensation against our benchmarking peers

Group CEO target package

– current vs proposed

Group CEO maximum package

– current vs proposed

Note: Peer data is based on disclosure available as of the end of 2025 – excludes benefits.

Directors’ Remuneration report continued

Chair’s statement

The impact of this change is illustrated below for the Group CEO on target and

maximum package scenarios:

The proposed LTIP increase rebalances the overall pay package towards variable, long-term pay with value dependent on the

achievement of stretching long-term performance objectives, bringing the Group CEO’s total target compensation in line with

ourmarket capitalisation positioning relative to peers.

The Committee also carefully considered

the Investment Association guidance that

where an Executive Director has met the

shareholding guideline, investors may

support a reduction in the level of deferral.

However, we are choosing to propose no

change to our current approach to deferral

of 50% of earned bonus for three years,

reflecting our commitment to a

Remuneration Policy which provides

long-term alignment of Executive and

investor interests.

Our proposals have been carefully

structured to ensure that overall

Group CEO remuneration is market

competitive while rebalancing the

package towards variable, long-term

pay. The Committee believes an

adjustment to the LTIP opportunity

– which will only be realised if strong

long-term performance is delivered – is

important in the context of Andy Briggs’

performance and contribution, as well

as wider competitive market practice.

Increased shareholding requirements

further enhance long-term investor

alignment, and the removal of an

additional exceptional LTIP limit provides

a simplified and more market-aligned

approach to incentive opportunities.

140 Standard Life plc Annual Report and Accounts 2025

Corporate governance

The Remuneration Policy we are

proposing improves the competitive

positioning of the total Group CEO

package, moving it from below the lower

quartile to between median and upper

quartile of the sector peer group, in line

with the relative market capitalisation

positioning within the Group. This

proposal has been designed to ensure

that any increase in total remuneration

depends on the achievement of

stretching long-term performance

metrics, with increased shareholding

requirements further enhancing

long-term alignment to our shareholders.

Whilst a phased approach was

considered, the Committee believes it is

critical to ensure that market competitive

arrangements are in place as we

transition to the next phase of our

ambitious growth strategy. The LTIP will

also be linked to revised performance

metrics from FY2026 focused on driving

superior customer and investor returns

(see below).

The Group CFO LTIP opportunity

will remain at 275% of salary for

FY2026. As stated in the 2024

Directors’ Remuneration report, on his

appointment in December 2024, the

Committee recognised that the package

for Nicolaos Nicandrou was at the upper

end of the market when compared to UK

listed insurance companies, reflecting

the quality and global experience that

he brings to the Group. The Committee

will keep this under review over the

life of the Remuneration Policy.

The full Remuneration Policy can

befound on page 148

Performance framework and

metricreview

Our Remuneration Policy is designed

to support Standard Life in achieving

its purpose with regard to our

customers and shareholders.

Consequently, the Committee is

proposing a number of changes to

performance metrics to better align

with the next phase of growth based

on our evolving strategy, ensuring

that our incentives drive superior

customer and investor returns.

Key principles

1. Simplification of framework – the

Committee has sought to simplify

andfocus the overall performance

metric framework.

2. Retained focus on financial strength

and balance sheet resilience – AIP

and LTIP metrics will continue to be

weighted towards the delivery of

stretching cash, capital and earnings

performance, in line with our strategy

and commitment to wider stakeholders.

The weighting of financial metrics on

the AIP will increase to 70%, with the

remaining 30% based on quantifiable,

customer metrics. Financial metrics

willcontinue to represent 80% of the

LTIP opportunity.

3. Delivering for our customers – we are

introducing new metrics linked to the

delivery of customer growth and

outcomes aligned to our vision to be

the UK’s leading retirement, savings

and income business. Success will be

measured by our net customergrowth,

customer retention and the

performance of the pensions of our

customers, supporting our purpose

andcommitment to ConsumerDuty.

New AIP metrics will be Net Customer

Growth (Net Flows) and Customer

Retention.

Under the LTIP, a new customer

outcomes metric (Relative Policyholder

Outcomes versus peers) will be

introduced with a 20% weighting to

directly align Executives’ outcomes

with those of our customers,

supporting our purpose of helping

people secure a life of possibilities.

Thismetric will track how we support

most of our customers to achieve

better returns through our flagship

multi-asset default pension funds

where we have full discretion over the

investment strategy. We want to help

more customers achieve better

outcomes and greater financial security

as we aim to deliver customer

outcomes ahead of peers and long

term real returns above inflation (UK CPI).

4. Underpin and robust discretion

framework – the AIP and LTIP will be

subject to robust underpins informed

by input from the Chairs of the Risk,

Audit, and Sustainability Committees

and the DNED for Workforce

Engagement. Downward adjustments

to outcomes may range from 0–100%,

depending on the materiality and

significance of any issues identified.

Each Committee Chair may consider

matters arising from their respective

areas of responsibility – including, but

not limited to, those relating to risk,

audit, compliance, customer

experience, employee engagement

and ESG/sustainability.

It is important to note that ESG/

sustainability will continue to be

assessed as part of the robust underpin

framework, with progress against key

sustainability, people (including DEI)

and culture ambitions forming a key

input for the Committee’s assessment

of any adjustments to be made and

recommendations provided to the

Remuneration Committee on whether

overall performance is consistent with

the Company’s targets in this area. This

will include assessment of specific

quantifiable targets against our Net

Zero Transition Plan.

The Remuneration Committee will

consider this input and retains full

discretion to determine whether, and

to what extent, any adjustment to

incentive outcomes is appropriate.

Further details are provided on

page 166

We considered amending the Relative

Total Shareholder Return (‘TSR’) metric

to measure performance against a

sector-aligned peer group, with the

objective to make comparison with

companies subject to similar external

factors. Some shareholders had concerns

that, with a limited number of truly

comparable peers, the peer group

risked becoming smaller should there

be further consolidation or private

investment in the sector. Taking into

account shareholder feedback, the

current approach of comparison with

the FTSE 350 excluding investment

trusts will be retained for 2026 and

kept under review for future awards.

The proposed changes to AIP and LTIP

metrics and weightings for FY2026

are summarised overleaf, with FY2025

metrics provided for comparison.

Full details of the 2026 AIP and

LTIPmetrics are provided on

pages164 to 165

141Standard Life plc Annual Report and Accounts 2025

Corporate governance

Customer Experience

20%

Strategic Scorecard

20%

2026

2025

Total Cash

Generation

12%

SII Shareholder Own

Funds Unrestricted Tier 1

(excluding economics)

16%

4%*

*Colleague Engagement eNPS

Net Customer Growth

20%

Customer

Retention

10%

Total Cash Generation

20%

SII Shareholder Own Funds

Unrestricted Tier 1

(excluding economics)

25%

IFRS Adjusted Operating Profit

25%

IFRS Adjusted

Operating Profit

16%

Cumulative

run-rate

cost savings

12%

Diversity,

Equity and

Inclusion

10%

Decarbonisation

– Investment

Portfolio

10%

Cumulative Operating

Cash Generation

20%

2026

2025

Relative Policyholder

Outcomes (pension fund

value growth)

20%

Cumulative Operating

Cash Generation

20%

SII Surplus

20%

SII Surplus

20%

Relative TSR

20%

Relative TSR

20%

Cumulative IFRS Adjusted

Operating Profit

20%

Cumulative IFRS Adjusted

Operating Profit

20%

2025

2026

2025

2026

Financial objectives Non-financial objectives

forthcoming AGM. Further information

will be provided in the Notice of AGM.

Shareholder engagement

As noted above, as part of the

Remuneration Policy renewal, the

Committee engaged extensively with

shareholders representing 75% of

our investor base, as well as proxy

and ESG rating agencies, on both our

Remuneration Policy proposals and

performance metric review. I would

like to take this opportunity to thank

those who took the time to engage

with us and provide feedback.

We were pleased that the overwhelming

majority of shareholders consulted

were supportive of our proposals.

Shareholders recognised the importance

of retaining and fairly rewarding our

high-performing Executive team

through the next strategic phase

in a highly competitive sector, and

were supportive of our proposed

adjustment to rebalance the Group

AIP and LTIP will be subject to robust underpins informed by input from the Chairs of the Risk, Audit and Sustainability Committees and the Employee Engagement Lead.

Downwardadjustments to outcomes may range from 0–100%, depending on the materiality and significance of any issues identified.

Salary review for 2026

A salary increase of 2.35% effective

from 1 April 2026 will apply for Andy

Briggs and Nicolaos Nicandrou, in line

with the wider workforce. This is the

first salary increase for Nicolaos since

his appointment in December 2024.

Further details on how

we implement pay for the

wider workforce is set out

onpages167to168

Share plan rules

The rules of the existing Company’s LTIP

and DBSS (the ‘Rules’) were previously

approved by shareholders in 2018.

Though the Rules are yet to expire,

the renewal of the Remuneration

Policy provided an appropriate time to

review the Rules and ensure they were

in line with best market practice. As a

result, we will be seeking shareholder

approval for a new Standard Life plc

Incentive Plan and Deferred Share

Bonus Plan on 14 May 2026 at our

CEO’s remuneration towards long-term

variable pay subject to appropriately

stretching targets, creating alignment

with shareholders. Themes from the

shareholder feedback included a request

for transparent disclosure in terms of

benchmarking peers, as well as views on

our TSR group and approach to ESG.

We remain committed to a constructive

and positive relationship with our

shareholders and will continue to engage

widely as appropriate going forward.

We are grateful for the ongoing support

and engagement of our investors, and I

would like to thank shareholders for their

continued support at the 2026 AGM.

Yours sincerely,

Sherry Coutu CBE

Chair of the Group Board

RemunerationCommittee

Directors’ Remuneration report continued

Chair’s statement

AIP – FY2026 vs FY2025: Increased focus on customer growth & retention

LTIP – FY2026 vs FY2025: Increased alignment with policyholder outcomes

142 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Overview

Remuneration structure

Base salary

Base salaries are reviewed each year against

companies of similar size and complexity.

Benefits

Market competitive benefits are provided in

a consistent manner with the wider workforce.

Pension

Competitive employer-sponsored defined contribution

pension plan with contributions at the same level as the

wider workforce.

Annual Incentive Plan

AIP to motivate employees and incentivise delivery

of annual performance targets aligned to strategy.

Long Term Incentive Plan

LTIP to motivate and incentivise delivery of sustained

performance over the long-term in line with our

strategyand purpose, and to promote alignment

withshareholders’ interests.

Statement of intent

The Committee adopts a simple and transparent

approach to remuneration to support the Group’s

purpose, values and strategic priorities, in order to

ensure the sustainability of the business. When

settingthe remuneration for Executive Directors,

theCommittee carefully considers wider workforce

payacross the whole organisation.

Our remuneration principles

• Support long-term, sustainable value

creation for stakeholders.

• Enable attraction and retention of

high-performing talent.

• Aligned to Group purpose, values and risk appetite.

• Support a strong pay for performance culture.

Alignment to purpose and strategy

Our Remuneration Policy is designed to align to our purpose and

is focused on the delivery of our strategy and long-term value

creation for our stakeholders.

Our variable pay plans ensure remuneration outcomes are

directly aligned to our core strategic priorities as shown on

page146 and to deliver long-term sustainable value. A significant

portion of Executive remuneration is delivered in shares and

deferred for up to five years.

Our purpose

Helping people secure

a life of possibilities

Remuneration at a glance

Grow People

Optimise Planet

Enhance Embed

responsibility

Pay for performance

A material portion of total remuneration is based on

variable pay. Performance targets are set with reference

to the AnnualOperating Plan and consensus, with stretch

targets set such that maximum payouts can only be

achieved forexceptional performance. Subject to approval

of the Remuneration Policy at the 2026 AGM, under the

maximum scenario over 70% of theGroup’s CEO maximum

remuneration is delivered in shares, deferred for three years

under the DBSS and subject to a combined vesting and

holding period offive years for the LTIP. This ensures strong

alignment between Executive Directors and shareholders.

Remuneration at a glance

Strategic priorities Sustainability strategy

143Standard Life plc Annual Report and Accounts 2025

Corporate governance

Fixed pay 20%

Salary

18%

Pension

and benefits

Variable pay 80%

AIP 30%

LTIP 50%

Fixed pay

20%

£101k

£861k

£1,460k

£2,444k

Variable pay

80%

Fixed pay 39%

Salary

36%

Pension

and benefits

Variable pay 61

AIP

61%

LTIP n/a

Fixed pay

39%

£730k

£77k

£1,238k

Variable pay

61%

Total Cash Generation (12% weighting)

SII Shareholder Own Funds Unrestricted

Tier 1 (excl. economics)

(16% weighting)

IFRS Adjusted Operating Profit (16% weighting)

Cumulative run-rate cost savings

(12% weighting)

Customer Experience

(20% weighting)

Colleague Engagement eNPS

(4% weighting)

Strategic Scorecard

(20% weighting)

100%

64%

38%

72%

Relative TSR (20% weighting)

Net Operating Cash Receipts (20% weighting)

Group In-force Long-term Free Cash (20% weighting)

Persistency (20% weighting)

Decarbonisation – Investment Portfolio (10% weighting)

Decarbonisation – Operations (10% weighting)

80%

100%

50%

74%

What did Executive Directors earn during2025?

2025 at a glance

Group CEO total pay

(Andy Briggs)

£4.87m

Group CEO

(Andy Briggs)

84.8%

Group CEO

(Andy Briggs)

68.4%

Group CFO

(Nicolaos Nicandrou)

84.8%

Group CFO

(Nicolaos Nicandrou)

n/a

Nicolaos Nicandrou did not

participate in the 2023 LTIP

See page 157 for

furtherdetails

See pages 158 to 160 for further details See page 160 for further details

Group CFO total pay

(Nicolaos Nicandrou)

£2.05m

Total 2025 AIP out of maximum opportunity

Overall outturn 84.8%

Total 2023 LTIP out of maximum opportunity

Overall outturn 68.4%

2025 single figure

The outcomes under the AIP and

LTIP resulted in a single figure

outcome for Andy Briggs of

£4.866 million and for Nicolaos

Nicandrou £2.045 million.

Directors’ Remuneration report continued

Remuneration at a glance

Fixed vs variable pay (% weighting)

Group CEO (Andy Briggs)

Fixed vs variable pay (% weighting)

Group CFO (Nicolaos Nicandrou)

144 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Group CEO

Andy Briggs

150%

824%

300%

350%

Group CFO

Nicolaos Nicandrou

Shareholding guideline (for 2025)

Shares held at 31 December 2025

2026 at a glance

Long-term alignment with shareholders

A significant proportion of Executive remuneration

isdelivered in shares which are released over a period

offive years. Incombination with our shareholding

guidelines, this aligns Executive Directors with

shareholders over the long term.

The graph to the right illustrates the percentage of

sharesheld under the current shareholding guidelines.

Shareholding requirements (from 2026)

Further details on shareholding requirements

(includingpost-cessation) are included in the

proposedRemuneration Policy on page 152.

Wider workforce remuneration in 2025

Salary

Annual salary review – average 3.32% increase (2.65% median)

Pension

Pension – up to 12% Company contribution

AIP

AIP outcome based on 88% Group outturn for 4,876 current employees

LTIP

107 colleagues were awarded a 2025 LTIP

2026 at a glance

Fixed pay

Group CEO

Andy Briggs

Group CFO

Nicolaos Nicandrou

Salary

£886,863 (2.35% increase)

Salary

£747,155 (2.35% increase)

Wider workforce pay

budget increased by 2.5%

Pension value of 12% aligned

to wider workforce rate

Variable pay

AIP Maximum LTIP Maximum

Group CEO

Andy Briggs

Group CFO

Nicolaos Nicandrou

Group CEO

Andy Briggs

Group CFO

Nicolaos Nicandrou

200%

of base salary

200%

of base salary

425%

of base salary

275%

of base salary

Operation Operation

50% paid in cash

50% deferred into shares for 3 years

3-year performance period

2-year holding period

145Standard Life plc Annual Report and Accounts 2025

Corporate governance

Directors’ Remuneration report continued

Remuneration at a glance

Performance measures 2026

This table demonstrates how each of our performance measures for AIP and LTIP align with the Group’s strategic priorities.

Financial framework and strategic priorities

Cash Capital Earnings Grow Optimise Enhance

AIP

Total Cash Generation

– – – – –

SII Shareholder Own Funds Unrestricted

Tier 1 (excluding economics)

–

– – – –

IFRS Adjusted Operating Profit – –

– – –

Net Customer Growth – – –

– –

Customer Retention – – –

– –

LTIP

Cumulative Operating Cash Generation

– – – – –

SII Surplus –

– – – –

Cumulative IFRS Adjusted Operating Profit – –

– – –

Relative TSR (excl. Investment Trusts)

Relative Policyholder Outcomes

(pension fund value growth)

– – –

– –

The AIP and LTIP are subject to robust underpins informed by input from the Chairs of the Risk, Audit, and

SustainabilityCommittees and the DNED for Workforce Engagement. Downward adjustments to outcomes may

rangefrom0–100%. ESG/sustainability will continue to be assessed, with progress against key sustainability,

people(including DEI) and culture ambitions (including specific quantifiable targets against our Net Zero Transition

Plan)forming a key input for the Committee’s assessment of any adjustments to be made and recommendations

providedtothe Remuneration Committee on whether overall performance is consistent with the Company’s targets.

All employees participate in a common incentive plan ensuring consistency of corporate goals and individual

performance management. Certain sales colleagues in our Pensions and Savings Workplace function have

additional functional metrics.

146 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Minimum On-target Maximum Maximum

with growth

100% 26%

24%

50%

15%

27%

58%

12%

21%

45%

22%

Total fixed pay

AIP

LTIP

Share price growth and dividends

991

3,762

6,534

8,418

100% 32%

29%

39%

19%

34%

47%

15%

28%

38%

19%

826

2,600

4,375

5,402

Minimum On-target Maximum Maximum

with growth

Total fixed pay

AIP

LTIP

Share price growth and dividends

Potential remuneration under various scenarios (£000)

The charts below illustrate the maximum levels of total remuneration payable under the 2026 Directors’ Remuneration Policy.

Scenario charts

Group CEO (Andy Briggs)

£000

Group CFO (Nicolaos Nicandrou)

£000

Minimum, on-target and maximum represent the scenario charts required under the Directors’ Remuneration Policy – see the data

assumptions below.

Executive Director

Base salary

£000

Benefits

£000

Pension

£000

Total fixed

£000

Andy Briggs 887 11 93 991

Nicolaos Nicandrou 747 1 78 826

Minimum Consists of base salary, benefits and pension:

• Base salary is the salary to be paid in 2026.

• Benefits measured as benefits to be paid in 2026.

• Pension measured as the full entitlement of approximately 10.5% of base salary receivable

(after the reduction to payments made in cash for employers’ National Insurance Contributions).

On-target Based on what the Executive Director would receive if performance was on-target:

• AIP: consists of the on-target annual incentive (100% of base salary).

• LTIP: consists of the target level of vesting (50% of maximum for Group CEO and Group CFO).

Maximum Based on the maximum remuneration receivable:

• AIP: consists of the maximum annual incentive (200% of base salary).

• LTIP: assumes maximum vesting of awards and valued as on the date of grant (award of 425% of base salary for

Group CEO and 275% of base salary for Group CFO).

Maximum

with growth

Based on the maximum remuneration receivable assuming a 50% share price growth assumption over the 3-year

period until LTIP vesting.

• AIP: consists of the maximum annual incentive (200% of base salary for Group CEO and Group CFO).

• LTIP: assumes maximum vesting of awards and valued as on the date of grant (award of 425% of base

salary for Group CEO and 275% of base salary for Group CFO) and assumes 50% share price growth.

147Standard Life plc Annual Report and Accounts 2025

Corporate governance

The Directors’ Remuneration Policy

(‘Remuneration Policy’)

Subject to approval from shareholders, the Remuneration Policy set

out below will be effective from the date of the 2026 AGM. It will

apply for a period of three years, until the 2029 AGM, unless a revised

Remuneration Policy is approved by shareholders before then.

Comparing the 2026 Remuneration Policy with the current Remuneration Policy

The main features of the 2026 Remuneration Policy are summarised in the table below. The table also includes details of how the

Remuneration Policy is intended to beapplied subject to approval by shareholders at the 2026 AGM.

Current Proposed

Base salary Base salary

Pension

12% of salary for Group CEO and Group CFO

Pension

12% of salary for Group CEO and Group CFO

No change

Annual incentive

200% of salary for Group CEO and Group CFO

Annual incentive

200% of salary for Group CEO and Group CFO

No change

Long-term incentive

Exceptional maximum limit 400% of salary

275% of salary for Group CEO

275% of salary for Group CFO

Long-term incentive

Overall maximum limit 425% of salary

425% of salary for Group CEO

275% of salary for Group CFO

Shareholding guidelines

350% of salary for Group CEO

300% of salary for Group CFO

Shareholding guidelines

425% of salary for Group CEO

300% of salary for Group CFO

Consideration of shareholders’

views when shaping the

Remuneration Policy

As part of the Remuneration Policy

renewal, the Committee engaged

extensively with shareholders

representing 75% of our investor base, as

well as proxy and ESG agencies, on both

our Remuneration Policy proposals and

performance metric review. We would like

to take this opportunity to thank those

who took the time to engage with us and

provide feedback.

We were pleased that the overwhelming

majority of shareholders consulted were

supportive of our proposals. Shareholders

recognised the importance of retaining

and fairly rewarding our high-performing

Executive team through the next strategic

phase in a highly competitive sector, and

were supportive of our proposed adjustment

to rebalance the Group CEO’s remuneration

towards long-term variable pay subject to

appropriately stretching targets, creating

alignment with shareholders.

In order to ensure that the package is

fairly positioned against sector peers

relative to our size, we considered a

number of scenarios, including a more

moderate increase to the LTIP alongside

an increase to the short-term incentive

opportunity. On balance, the Committee

felt strongly that any uplift in pay should

be focused on the LTIP, thereby linked to

sustainable, long-term performance

delivery. This is also aligned to our

underlying remuneration principle of

ensuring reward is appropriately aligned

to risk and avoids unduly rewarding

short-term behaviours.

In considering a range of scenarios, we

also discussed a phased approach to the

LTIP increase (e.g. a stepped increase in

two stages in 2026 and 2027). However,

the Committee believes it is critical to

ensure that market competitive

arrangements are in place now as we

transition to the next phase of our

ambitious growth strategy, recognising

Andy Briggs’ performance and

contribution and the highly competitive

sector in which we operate. In our

consultation with other major investors

and proxy agencies, we are pleased to

have received strong support for the LTIP

adjustment subject to appropriate

stretching targets.

Other themes from the shareholder

feedback included a request for

transparent disclosure in terms of

benchmarking peers, as well as views on

our TSR group and approach to ESG.

In our initial proposals, we considered

amending the Relative TSR metric to

measure performance against a sector-

aligned peer group, with the objective

tomake comparison with companies

subject to similar external factors.

Some shareholders had concerns

that, with alimited number of truly

comparable peers, the peer group

risked becoming smaller should there

be further consolidation or private

investment in the sector. Taking into

account shareholder feedback, the

current approach of comparison with

the FTSE 350 excluding investment

trusts will be retained for 2026 and

kept under review for futureawards.

General policy

The Remuneration Policy for Executive

Directors is summarised in the table below

along with the policy on the Chair’s and

the Non-Executive Directors’ fees.

Directors’ Remuneration report continued

The Directors’ Remuneration Policy

148 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Remuneration Policy table

Element and purpose in

supportingstrategic objectives Remuneration Policy and operation Maximum Performance measures

Base salary

This is the core element of pay

which supports the recruitment

and retention of Executive

Directors and reflects the

individual’s role and position

within the Group as well as their

capability and contribution.

• Base salaries are normally reviewed

each year and are positioned to

ensure we are able to attract

and retain Executives with

appropriate skills and experience.

In reviewing base salaries, the

Committee may reference market

data of comparators which

the Remuneration Committee

considers to be suitable based on

index, size and/or sector.

• The Remuneration Committee

takes into account a number

of factors when setting base

salary. These may include, but are

not limited to: relevant market

data; corporate and individual

performance and skillset and any

changes in an individual’s role and

responsibilities; and the level of

salary increases awarded to other

employees of the Group.

• Base salary is normally paid

monthly in cash.

• Changes to base salaries normally

take effect from 1 April.

• Salary levels are specific to the role

and individual.

• When reviewing salaries

for Executive Directors, the

Remuneration Committee will

also review the salaries, and salary

increases, for Senior Management

and employees in relevant

countries and sectors to maintain

consistency. Typically, percentage

increases for Executive Directors

will not exceed that of the broader

employee population, other than in

specific circumstances identified by

the Remuneration Committee (e.g.

in response to a substantial change

in responsibilities).

• N/A

Benefits

To provide other benefits valued

by recipient.

• The Group provides market

competitive benefits in kind.

Details of the benefits provided

in each year will be set out in the

Implementation of Remuneration

Policy within this report. The

Remuneration Committee reserves

discretion to introduce new

benefits where it concludes that

it is in the interests of the Group

to do so, having regard to the

particular circumstances and to

market practice.

• Where appropriate, the Group

will meet certain costs relating to

Executive Director relocations and

other exceptional expenses.

• It is not possible to prescribe the

likely change in the cost of insured

benefits or the cost of some

of the other reported benefits

year-to-year, but the provision of

benefits will normally operate on a

consistent basis.

• The Remuneration Committee

will monitor the costs in practice

and ensure that the overall costs

do not increase by more than

the Remuneration Committee

considers to be appropriate in all

the circumstances.

• N/A

Pension

To provide retirement benefits

which keep the Group competitive

within the marketplace and

provide for the future of

ouremployees.

• The Group provides a competitive

employer-sponsored defined

contribution pension plan.

• All Executive Directors are eligible

to participate in the defined

contribution pension plan available

to all new joiners or they may opt

to receive the contribution in cash

if they are impacted by the relevant

lifetime or annual limits, aligned

to the wider workforce. Any such

cash payments are reduced for

the effect of employers’ National

Insurance Contributions.

• Pension contributions for

Executive Directors are aligned

with the wider workforce rate

which is currently 12% of salary

(reduced to 10.5% when taken as

cash in lieu of contribution).

• N/A

149Standard Life plc Annual Report and Accounts 2025

Corporate governance

Remuneration Policy table

Element and purpose in

supportingstrategic objectives Remuneration Policy and operation Maximum Performance measures

Annual Incentive Plan (‘AIP’) and

Deferred Bonus Share Scheme

(‘DBSS’)

To motivate employees and

incentivise delivery of annual

performance targets aligned

tostrategy.

• AIP levels and the appropriateness

of measures are reviewed annually

to ensure they continue to support

the Group’s strategy.

• AIP outcomes are normally paid

in cash in one tranche (less the

deferred share award).

• At least 50% of any annual AIP

award is to be deferred into

shares for a period of three years

although the Remuneration

Committee reserves discretion

to alter the current practice of

deferral (whether by altering the

portion deferred, the period of

deferral or whether amounts are

deferred into cash or shares). Such

alterations may be required to

ensure compliance with regulatory

guidelines for pay within the

insurance sector, butwill not

otherwise reduce the current

deferral level or the period

ofdeferral.

• Deferral of AIP outcomes into

Company shares is currently made

under the DBSS.

• The 3-year period of deferral

will normally run to the third

anniversary of the award date.

• Dividend entitlements will accrue

over the deferral period and will

normally be delivered as additional

vesting shares.

• Malus/clawback provisions apply to

the AIP and to amounts deferred

under the DBSS as explained in the

notes to this table.

• The maximum annual incentive

level for an Executive Director is

200% of base salary per annum.

• The performance measures

applied to the AIP will be set by

the Remuneration Committee and

may be financial or non-financial

and corporate, divisional or

individual and in such proportions

as it considers appropriate.

However, the weighting of

financialperformance measures

will not be reduced below 60%

oftotal AIP potential in any

year forthe duration of this

Remuneration Policy.

• In respect of the financial and

non-financial performance

measures, attaining the threshold

performance level normally

produces a £nil annual incentive

payment for that metric.

• On-target performance on all

measures normally produces an

outcome of 50% of maximum

annual incentive opportunity.

However, the Remuneration

Committee reserves the right to

adjust the threshold and target

levels for future financial years in

light of competitive practice.

• Recognising that the business of

the Group is to engage in corporate

activity, the Remuneration

Committee may adjust targets

during the year to take account of

such activity and ensure the targets

continue to reflect performance as

originally intended.

• An underpin informed by

input from the Chairs of the

Risk, Audit, and Sustainability

Committees and the DNED for

Workforce Engagement ensures

alignment to overall Company

performance. The AIP remains a

discretionary arrangement, and the

Remuneration Committee reserves

discretion to adjust outcomes

from 0–100%, depending on the

materiality and significance of any

issues identified.

Directors’ Remuneration report continued

The Directors’ Remuneration Policy

150 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Remuneration Policy table

Element and purpose in

supportingstrategic objectives Remuneration Policy and operation Maximum Performance measures

Long Term Incentive Plan (‘LTIP’)

To motivate and incentivise

delivery of sustained performance

over the long-term in line with our

strategy and purpose, and to

promote alignment with

shareholders’ interests.

• LTIP awards are typically

grantedannually.

• The vesting period will normally be

at least three years and run until

the third anniversary of the award

date (unless a longer vesting period

is introduced).

• A holding period will normally

apply so that Executive Directors

may not normally exercise

vested LTIP awards until the fifth

anniversary of the award date.

• Dividend entitlements will accrue

until the end of the holding

period in respect of performance

vested shares and will normally

be delivered as additional

vestingshares.

• Malus/clawback provisions apply

on a basis consistent with the

equivalent provisions in the AIP and

DBSS and as explained in the notes

to this table.

• The Group will honour the vesting

of all awards granted under

previous policies in accordance

with the terms of such awards.

• The maximum limit under the LTIP

is 425% of base salary per annum.

• The Remuneration Committee’s

normal practice is to make LTIP

awards to Executive Directors each

year over shares with a value (as

at the award date) of up to 425%

of the Group CEO’s annual base

salary and 275% of the Group

CFO’s annual base salary although

discretion is reserved to make

awards up to the maximum levels

of the Remuneration Policy.

• The Remuneration Committee may

set such performance measures

for LTIP awards as it considers

appropriate (whether financial

or non-financial and whether

corporate, divisional or individual).

• For every LTIP award, appropriate

disclosures regarding the proposed

performance conditions will be

made in the Implementation

of Remuneration Policy within

thisreport.

• Once set, performance measures

and targets will generally remain

unaltered unless events occur

which, in the Remuneration

Committee’s opinion, make it

appropriate to make adjustments

to ensure alignment with strategic

objectives, provided that any

adjusted performance measure is,

in its opinion, neither materially

more nor less difficult to satisfy

than the original measure.

• For each part of an LTIP award

subject to a specific performance

condition, the threshold level of

vesting will be no more than 25%

of that part of the LTIP award.

• The performance period for LTIP

awards will normally be at least

three years, but the Remuneration

Committee reserves discretion

to lengthen the applicable

performance periods for

LTIPawards.

• An underpin informed by

input from the Chairs of the

Risk, Audit and Sustainability

Committees and the DNED for

Workforce Engagement ensures

alignment to overall company

performance. The LTIP remains a

discretionary arrangement, and the

Remuneration Committee reserves

discretion to adjust outcomes

from 0–100%, depending on the

materiality and significance of any

issues identified.

• The Remuneration Committee

retains discretion to adjust the

weightings or substitute metrics

but would normally consult with

its major shareholders regarding

any material changes to the

current performance measures

applied for LTIP awards made

to Executive Directors or the

relativeweightings.

151Standard Life plc Annual Report and Accounts 2025

Corporate governance

Directors’ Remuneration report continued

The Directors’ Remuneration Policy

Remuneration Policy table

Element and purpose in

supportingstrategic objectives Remuneration Policy and operation Maximum Performance measures

All-employee share plans

To encourage share ownership by

employees, thereby allowing them

to participate in the long-term

success of the Group and align

their interests with those of

theshareholders.

• Executive Directors are able to

participate in all-employee share

plans on the same terms as other

Group employees as required by

HMRC legislation.

• ShareSave – the Remuneration

Committee has the facility to

allow individuals to save up to a

maximum of £500 each month

(or such other level as permitted

by HMRC legislation) for a fixed

period. At the end of the savings

period, individuals may use their

savings to buy ordinary shares in

the Group at a discount of up to

20% of the market price set at the

launch of each plan.

• Share Incentive Plan (‘SIP’) – the

Remuneration Committee has

the facility to allow individuals

to have the opportunity to

purchase, out of their pre-tax

salary, shares in the Group and

receive one matching share for

every purchased share up to a

maximum of £50. The maximum

saving is £150 each month (or

up to such level as permitted

by the Group in line with HMRC

legislation). The SIP also has the

facility to allow for reinvestment

of dividends in further shares, or

the award of additional free shares

(up to the limits as permitted by

HMRClegislation).

• Consistent with normal practice,

such awards are not subject to

performance conditions.

Shareholding guidelines

To encourage share ownership

bythe Executive Directors over

thelong-term, including

post-cessation of employment,

and ensure interests are aligned.

• Executive Directors are normally

expected to retain all shares (net

of tax) which vest under the DBSS

and under the LTIP (or any other

discretionary long-term incentive

arrangement introduced in the

future) until such time as they hold

a minimum of 425% of base salary

in shares for the Group CEO and

300% of base salary in shares for

the Group CFO.

• Only beneficially owned shares,

vested share awards, and

unvested share awards not

subject to performance conditions

(discounted for anticipated tax

liabilities), may be counted for the

purposes of the guidelines. Share

awards subject to performance

conditions do not count prior

tovesting.

• Once shareholding guidelines have

been met, individuals are expected

to retain these levels as a minimum.

The Remuneration Committee

willreview shareholdings

annually in the context of this

RemunerationPolicy.

• Post-cessation of employment,

Executive Directors are

expected to retain the lower of

their full level of employment

shareholding guideline or their

actual shareholding at termination

foraperiod of two years.

• N/A • N/A

152 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Remuneration Policy table

Element and purpose in

supportingstrategic objectives Remuneration Policy and operation Maximum Performance measures

Chair of the Group Board and

Non-Executive Director fees

• The fees paid to the Chair of the

Group Board and to the other

Non-Executive Directors are set to

be competitive with other listed

companies of equivalent size

andcomplexity.

• Additional fees are paid to Non-

Executive Directors who chair or are

amember of a board or committee

of a subsidiary company and to

the Senior Independent Director

(‘SID’) and Designated NED for

WorkforceEngagement.

• Fees are normally paid monthly in cash;

however, a proportion of that fee may

be paid in Standard Life plc shares.

If implemented, shares are normally

acquired at the prevailing market price

with the individuals tax and associated

costs deducted.

• Fee levels for Non-Executive

Directors are reviewed annually

with any changes normally taking

effect from 1 April. Additional

reviews may take place in exceptional

circumstances, such as following

major corporate events, to ensure

that fees remain appropriate in

the context of the Group’s size and

complexity and to reflect the time

commitment required.

• The aggregate fees of the Chair

of the Group Board and Non-

Executive Directors will not

exceed the limit from time to time

prescribed within the Group’s

Articles of Association for such

fees (currently £2 million per

annum in aggregate).

• The Group reserves the right to

vary the structure of fees within

this limit including, for example,

introducing time-based fees or

reflecting the establishment

of new Board or subsidiary

companycommittees.

• N/A

153Standard Life plc Annual Report and Accounts 2025

Corporate governance

Directors’ Remuneration report continued

The Directors’ Remuneration Policy

Notes to the Remuneration Policy table

1. Differences between the Remuneration Policy forDirectors and the remuneration policy

forotheremployees

When determining Executive Directors’ remuneration, the Committee takes into account pay throughout the Group to ensure that

the arrangements in place remain appropriate.

The Group has (as required by Solvency II regulations) one consistent reward policy for all levels of employees and this policy is made

available to all staff. Therefore, the same reward principles guide reward decisions for all Standard Life plc employees, including

Executive Directors, although remuneration packages differ to take into account appropriate factors in different areas of the

business as follows:

• AIP – all permanent employees participate in the AIP, although the quantum varies by level. The most senior staff are subject to

theregulatory requirements of Solvency II, and these individuals also receive part of their bonus in Company shares deferred for

aperiod of three years. For Solvency II Identified staff in ‘control functions’ (Risk, Compliance, Internal Audit and Actuarial), AIP is

considered in the context of their role to ensure independence of the areas they monitor.

• LTIP – our most senior employees participate in the LTIP, currently based on the same performance conditions as those for

Executive Directors, although the Committee reserves the discretion to vary the performance conditions for awards made to

employees below the Board for future awards.

• All-employee share plans – the Committee considers it is important for all employees to have the opportunity to become

shareholders in the Company. The Company offers two HMRC tax advantaged arrangements in which all UK employees can

participate and acquire shares on a discounted and tax advantaged basis (ShareSave and SIP), and equivalent arrangements in

foreign jurisdictions (including on a tax advantaged basis permitted under local laws).

2. Malus and clawback

Malus (being the forfeiture of unvested awards) and clawback (being the ability of the Company to claim repayment of paid amounts

as a debt) provisions apply to the AIP, DBSS and LTIP. These provisions may be applied up to the seventh anniversary of the grant date

for LTIP, DBSS or other equity awards, and up to the third anniversary of the payment date for AIP or other cash awards, where the

Remuneration Committee considers it appropriate to do so following:

• A material financial misstatement of the Group’s audited financial accounts for any period, or a misleading representation of

performance for any period.

• A scenario or event which causes a material downturn in financial performance.

• The calculation of the original award was based (in whole or in part) on a material error.

• There are circumstances which would warrant or would have warranted the Company summarily dismissing the participant

(whether or not the Company had chosen to do so), or of employee misbehaviour, or material error whether or not justifying such

summary dismissal.

• Any regulatory investigation or breach of law, rules of codes of conduct or misconduct, which, in the opinion of the Committee

ought to result in the complete or partial lapse of an award.

• There has been a material failure of risk management and/or controls by the participants, the Company, or a relevant business unit.

• The Company or a relevant business unit has suffered a material downturn in its financial performance.

• There are circumstances which in the Committee’s opinion have (or would have if made public) a sufficiently significant impact on the

reputation of the Company or of any Group member that would justify the application of malus and/or clawback.

These time frames are considered appropriate to allow sufficient time for any of the above circumstances to come to light and for

the Committee to take such action as it considers appropriate.

3. Business expenses

While the Remuneration Committee does not consider this to form part of benefits in the normal usage of that term, it has been

advised that corporate hospitality (whether paid for by the Company or another Group company) and certain instances of business

travel (including any related tax liabilities settled by the Company or another Group company) for Directors may technically be

considered as benefits and so the Remuneration Committee expressly reserves the right to authorise such activities and

reimbursement of associated expenses within its agreed policies.

154 Standard Life plc Annual Report and Accounts 2025

Corporate governance

4. Discretions reserved in operating incentive plans

The Remuneration Committee will operate the AIP, DBSS and LTIP according to their respective rules and the above Remuneration

Policy table. The Remuneration Committee retains certain discretions, consistent with market practice, in relation to the operation and

administration of these plans including:

• (as described in the Remuneration Policy table) the determination of performance measures and targets and resulting vesting and

payout levels;

• (as described in the Remuneration Policy table) the ability to adjust performance measures and targets to reflect events and/or to

ensure the performance measures and targets operate as originally intended;

• (as described in the Termination policy summary) determination of the treatment of individuals who leave employment, based on

therules of the incentive plans, and the treatment of the incentive plans on exceptional events, such as a change of control of the

Company;

• the ability to make adjustments to existing awards made under the incentive plans in certain circumstances (e.g. rights issues,

corporate restructurings or special dividends). Any exercise of discretion will be disclosed in the Implementation of Remuneration

Policy for theyear.

• consistent with the UK Corporate Governance Code 2024, the Remuneration Committee may apply discretion to override formulaic

outcomes if they are considered inconsistent with the underlying performance of the Group (see page 166).

Recruitment remuneration policy

The Group’s recruitment remuneration policy aims to give the Remuneration Committee sufficient flexibility to secure the

appointment and promotion of high-calibre Executives to strengthen the management team and secure the skillsets to deliver our

strategic aims.

In terms of the principles for setting a package for a new Executive Director, the starting point for the Remuneration Committee will

be to apply the Remuneration Policy for Executive Directors as set out above and structure a package in accordance with that policy.

The AIP and LTIP will operate (including the maximum award levels) as detailed in the Remuneration Policy in relation to any newly

appointed Executive Director.

For an internal appointment, any variable pay element awarded in respect of the prior role may either continue on its original terms

or be adjusted to reflect the new appointment as appropriate.

For external and internal appointments, the Remuneration Committee may agree that the Company will meet certain relocation

expenses as it considers appropriate.

For external candidates, it may be necessary to make awards in connection with the recruitment to buy out awards forfeited by

theindividual on leaving a previous employer. For such awards, the value of any buy-out will not be more than is, in the view of the

Remuneration Committee, necessary and will in all cases seek, in the first instance, to deliver any such awards under the terms of the

existing incentive pay structure. It may, however, be necessary in some cases to make such awards to incoming Executive Directors on

terms that are more bespoke than the existing annual and equity-based pay structures in the Group in order to secure a candidate.

Details of any buy-out awards will be appropriately disclosed.

All such buy-out awards, whether under the AIP, LTIP or otherwise (for example, specific arrangements made under Listing Rule 9.4.2),

will take account of the service obligations and performance requirements for any remuneration relinquished by the individual when

leaving a previous employer. The Remuneration Committee will seek to make buy-out awards subject to what are, in its opinion,

comparable requirements in respect of service and performance. However, the Remuneration Committee may choose to relax this

requirement in certain cases (such as where the service and/or performance requirements are materially completed), and where the

Remuneration Committee considers it to be in the interests of shareholders and where suchfactors are, in the view of the

Remuneration Committee, reflected in some other way, such as a significant discount to theface value of the awards forfeited.

Exceptionally, where necessary, this may include a guaranteed or non pro-rated annual incentive in the year of joining. For the

avoidance of doubt, such buy-out awards are not subject to a formal cap.

A new Non-Executive Director would be recruited on the terms explained in the Remuneration Policy for such Directors.

Executive Directors’ service contracts

Executive Director service contracts, which do not contain expiry dates, provide that compensation provisions for termination without

notice will only extend to 12 months of salary, certain fixed benefits and pension (which may be payable in instalments and subject to

mitigation). By excluding any entitlement to compensation for loss of the opportunity to earn variable pay, the Remuneration Committee

believes the contracts to be consistent with best practice. The Remuneration Committee also has discretion to mitigate further by paying

on a phased basis with unpaid instalments ceasing after the initial period of six months if the Executive Director finds alternative

employment. Contracts do not contain change of control provisions. The template contract is reviewed from time to time and may be

amended provided it is not overall more generous than the terms described above.

Subject to Board approval, Executive Directors are permitted to accept outside appointments on external boards as long as these are

not deemed to interfere with the business of the Group.

155Standard Life plc Annual Report and Accounts 2025

Corporate governance

Directors’ Remuneration report continued

The Directors’ Remuneration Policy

Non-Executive Directors

The Non-Executive Directors, including the Chair, have letters of appointment which set out their duties and responsibilities.

Appointment is for an initial fixed term of three years (which may be renewed), terminable by one month’s notice from either side

(sixmonths in the case of the Chair). Non-Executive Directors are not eligible to participate in incentive arrangements or receive

pension provision or other benefits such as private medical insurance and life insurance.

Copies of Executive Director service contracts and Non-Executive Director letters of appointment are available for inspection at the

Company’s registered office.

Termination policy summary

In practice, the facts surrounding any termination do not always fit neatly into defined categories. Therefore, it is appropriate for

theRemuneration Committee to consider the suitable treatment on a termination having regard to all of the relevant facts and

circumstances available at that time. This policy applies both to any negotiations linked to notice periods on a termination and any

treatment which the Remuneration Committee may choose to apply under the discretions available to it under the terms of the AIP,

DBSS and LTIP plans. The potential treatments on termination under these plans are summarised below.

Incentives Approved Leaver

1, 2

Non-Approved Leaver Exceptional Events

A participant is considered an Approved

Leaver if leaving through redundancy,

serious ill health or death or otherwise at

the discretion of the Remuneration

Committee.

A participant would typically be a

Non-Approved Leaver if they leave

through voluntary resignation or for

disciplinary reasons.

For example, change in control or winding

up of the Company.

AIP Pro-rated annual incentive. Pro-rating to

reflect only the period worked.

Assessment determined by the

Remuneration Committee.

No awards made. Either the AIP will continue for the year or

there will be a pro-rated annual incentive.

Performance metrics determined by the

Remuneration Committee.

DBSS Deferred awards vest at the end of the

original vesting period.

Deferred awards normally lapse. Deferred awards vest.

LTIP Will receive a pro-rated award subject to

the application of the performance

conditions at the normal measurement

date and, generally, any holding period

will continue to apply. Remuneration

Committee discretion to disapply

pro-rating or to accelerate vesting to the

date of leaving (subject to pro-rating and

performance conditions) and/or the

release of any holding period.

All awards will normally lapse. Will receive a pro-rated award subject to

the application of the performance

conditions at the date of the event.

Remuneration Committee discretion to

disapply pro-rating.

1. Under the DBSS Rules, an Approved Leaver is an individual who leaves for a reason other than voluntary resignation and dismissal.

2. Where the reason for leaving is retirement, the individual will be required to provide confirmation of their continued retirement before any payments are released to them after

the end of the vesting period.

The Group has power to enter into settlement agreements withExecutives and to pay compensation to settle potential legal claims.

In addition, and consistent with market practice, inthe event of termination of an Executive Director, the Group may pay a

contribution towards the individual’s legal fees and fees for outplacement services as part of a negotiated settlement. Any such fees

would be disclosed as part of the detail of termination arrangements. For the avoidance of doubt,the policy does not include an

explicit cap on the cost oftermination payments.

In the event of cessation of a Non-Executive Director’s appointment (excluding the Chair) they would be entitled to a one month’s

notice period. The Chair, as detailed in his letter of appointment, would be entitled to a six months’ notice period.

Consideration of employment conditions elsewhere in the Group

As explained in the notes to the Remuneration Policy table, the Remuneration Committee takes into account Group-wide pay and

employment conditions. The Remuneration Committee reviews the average Group-wide base salary increase and annual incentive

costs and is responsible for all discretionary and all-employee share arrangements.

Consistent with previous practice, the Remuneration Committee did not specifically consult with employees in preparing the

Remuneration Policy although has established further employee engagement in accordance with the requirements under the UK

Corporate Governance Code 2024.

Potential rewards under various scenarios (£000)

See page 147 for the maximum levels of total remuneration payable under the Remuneration Policy.

156 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Annual report on remuneration

This section of the Directors’ Remuneration report sets out the

Executive Directors’ remuneration for 2025. It contains the annual

report on remuneration which forms part of the Directors’

Remuneration report to be proposed for approval by the Company’s

shareholders at the AGM on 14 May 2026.

Introduction

This report contains the material required to be set out as the Directors’ Remuneration report (‘Remuneration report’) for

thepurposes of The Large and Medium-sized Companies and Groups (Accounts and Reports) (Amendment) Regulations 2008

(asamended) (‘the DRR regulations’).

Implementation report – Audited information

Single Figure Table

Salary/fees

1,2

Benefits

Pension

Total

fixed pay

Annual

incentive

Long-term

incentives

6,7

Total

variable pay Total

£000 2025 2024 2025 2024 2025 2024 2025 2024 2025 2024 2025 2024

2025 2024

Executive

Directors

Andy Briggs

861 844 11 11 90 89 962 944 1,460 1,323 2,444 1,343 3,904 2,666 4,866 3,610

Nicolaos

Nicandrou

730 61 1 – 76 7 807 68 1,238 100 – – 1,238 100 2,045 168

1. Andy Briggs’ salary increased to £866,500 with effect from 1 April 2025.

2. The Executive Directors are entitled to adjust their salary/benefit combination under flexible benefits arrangements and the figures shown are before individual elections.

3. Benefits for Executive Directors include legacy car allowance where relevant, private medical insurance, any ShareSave benefit and matching shares awarded under the Share Incentive

Plan. No individual benefit provided has a value which is significant enough to warrant separate disclosure.

4. Executive Directors are entitled to each receive a Company pension contribution of 12% of salary, (plus salary sacrifice uplift of 10% of the employee contribution) aligned to the wider

workforce. This may be paid as a cash supplement (without the salary sacrifice uplift), reduced for the effect of employers’ National Insurance Contributions. Both Executive Directors

received contributions as cash supplements (10.5%). No Director participated in a defined benefit pension arrangement in the year, and none have any prospective entitlement to a

defined benefit pension arrangement.

5. Annual incentive amounts are presented inclusive of any amounts which must be deferred into shares for three years and which are subject to continued employment (i.e. 50% of the

AIP award for 2025). In 2025 £729,980 of Andy Briggs’ incentive payment is subject to 3-year deferral delivered in shares, and £618,919 of Nicolaos Nicandrou’s incentive payment is

subject to a similar deferral (2024: Andy Briggs’ deferral was £661,635 and Nicolaos Nicandrou’s deferral was £50,200).

6. The 2025 value for long-term incentives is an estimate of the vesting outcomes for LTIP awards granted in 2023 which are due to vest once the Full Year results are announced. This

vesting level is at 68.4%, reflecting outcomes against the performance measures described on page 160 to 31 December 2025. This vesting outcome is then applied to the average

share price between 1 October 2025 and 31 December 2025 (682.25 pence) to produce the estimated long-term incentives figures shown for 2025 in the above table. The assumptions

will be trued up for actual share price at the day of vesting in the Directors’ Remuneration report for 2026. For Andy Briggs, the disclosed LTIP figure of £2,443,533 comprises

£1,879,292 representing the proportion of the original LTIP award which ultimately vested, plus the value of dividend roll-up on those shares of £564,241. £290,825 of the award

related to share price appreciation over the performance period. Nicolaos Nicandrou was not a participant in the 2023 LTIP.

7. For 2022’s LTIP awards which are reflected in the 2024 long-term incentives column above, the performance conditions were met as to 51.1% of maximum. These values reflect the

value of the Company’s shares on the date of vesting which was 18 March 2025 (581.25 pence per share) multiplied by the number of shares vesting whereas the equivalent figure

within the published 2024 Single Figure Table was an estimate which reflected the average share price between 1 October 2024 and 31 December 2024 (511.05 pence per share) and

certain assumptions regarding the cumulative value of dividends on the number of shares vesting.

157Standard Life plc Annual Report and Accounts 2025

Corporate governance

AIP outcomes for 2025 – Audited information

The overall weightings between Corporate measures and Strategic Scorecard for AIP in 2025 were:

• 80% – Corporate (financial and customer) performance measures.

• 20% – Strategic Scorecard (strategic Company priorities).

As described in the Remuneration Policy, 50% of 2025 AIP outcomes will be delivered as an award of deferred shares under the DBSS

which will vest after a 3-year deferral period subject to continued employment or approved leaver status.

Outcomes for the 2025 AIP are shown below:

Performance measure

Threshold

performance

level for 2025 AIP

Target

performance

level for 2025 AIP

Maximum

performance

level for 2025 AIP

Performance

level attained for

2025 AIP

% of Corporate

element based on

performance

measure % achieved

Total Cash Generation (£m)

1,500 1,600 1,700 1,711 15.0% 15.0%

SII Shareholder Own Funds Unrestricted Tier 1

(excluding economics) (£m)

4,100 4,300 4,500 4,519 20.0% 20.0%

IFRS Adjusted Operating Profit (£m)

805 855 905 945 20.0% 20.0%

Cumulative run-rate cost savings (£m)

100 125 150 180 15.0% 15.0%

Customer Experience

Customer Satisfaction – Telephony (%)

86.0% 88.0% 90.0% 88.4% 5.0% 3.0%

Customer Satisfaction – Digital (%)

92.0% 94.0% 96.0% 93.3% 5.0% 1.6%

Claims Experience (% in SLA)

89.0% 92.0% 95.0% 94.7% 5.0% 4.7%

Service Experience (% in SLA)

90.0% 93.0% 96.0% 93.8% 5.0% 3.2%

Complaints Volume per 1,000 Customers

0.7 0.5 0.3 0.42 5.0% 3.5%

Colleague Engagement eNPS

19 23 27 22 5.0% 1.9%

Total of Corporate element

100.0% 87.9%

1. Customer feedback scores as reported through a survey following telephony service, where customers can rate us between 1–5. The approach is now consistent across each

platform/entity and customers are asked specific questions about their recent interaction.

2. Customer satisfaction scores as gathered immediately following customer digital journeys, where customers can rate their experience between 1–5. For Standard Life, all

transactional journeys for which feedback is live on our secure site including all transactional journeys for which feedback is live on our mobile app. For Phoenix Life, encashment

journey for which survey is live on MyPhoenix.

3. This metric captures a measure for the end-to-end customer experience and outcome as an aggregate view across the varying claims journeys. This is measured as a percentage of

all back-office manual workflow for end-to-end claim journey requirements.

4. This metric captures a measure for the end-to-end customer experience and outcome as an aggregate view across the varying service journeys. This is measured as a percentage of

all back-office manual workflow for end-to-end service journey requirements.

5. This metric provides a ratio of the number of complaints received per 1,000 polices in-force.

2025 financial results demonstrated strong strategic progress in the second year of our 3-year strategy, delivering robust financial

performance across our financial framework of cash, capital and earnings. Total Cash Generation in 2025 was £1,711 million, above

the top end of our £1.6 billion target for the year. Solvency II Shareholder Own Funds Unrestricted Tier 1 (excluding economics)

delivered £4,519 million, benefitting from strong delivery of management actions in the year. IFRS Adjusted Operating Profit of £945

million was supported by improved business performance which generated profitable growth in our two main operating businesses,

and our focus on driving cost efficiencies has enabled delivery of £180 million cumulative run rate cost savings (£63 million delivered

in 2024).

2025 AIP underpin

Prior to confirming the outcomes for the 2025 AIP, the Committee reviewed in detail the extent to which the Group had operated

within its stated risk appetite and delivered on its holistic Consumer Duty obligations, and determined that no adjustment to the

2025 formulaic outcome was necessary.

Directors’ Remuneration report continued

Annual report on remuneration

158 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Strategic Scorecard

The Strategic Scorecard represents 20% of the overall incentive opportunity. Metrics and targets relating to this scorecard were

agreed by the Remuneration Committee at the start of the year. The table below details the outcome against targets of the Strategic

Scorecard together with weightings and outturn.

Strategic priority Weighting Description Base target Performance Outcome

Group CEO and

Group CFO

outcome

Grow

15% Progress on key strategic outcomes See Note 1 See Note 1 75% 11.25%

Operating Cash Generation £1.45bn £1.47bn

Workplace new scheme wins £1.0bn £1.5bn

Net flows £(3.8)bn £(4.7)bn

including

People

12.5% Progress on helping more people journey

to and through retirement

See Note 2 See Note 2 40% 5.00%

Customer engagement – Standard Life

customers who are active digital users (%)

33% 30%

Optimise

30% Deliver incremental value through asset

management optimisation and enhanced

capital efficiency

See Note 3 See Note 3 95% 28.50%

Solvency leverage 35% 33%

Annuities internal rate of return (‘IRR’) Low-teens

IRR

Mid-teens

IRR

including

Planet

12.5% Decarbonisation – investments – reduction

in carbon intensity (%) – meet 2025 target

25% 58% 100% 12.50%

Decarbonisation – investments – transition

equity and fixed income Phoenix Unit Trust

Managers

Sustainable Multi Asset funds

into SDR

labelled vehicles and launch

(assets under management (‘AUM’))

£32bn £41.6bn

Enhance

including

building a

sustainable

business

30% Progress on transformation milestones

and delivery of cost efficiency

See Note 4 See Note 4 50% 15.00%

Risk Action Delivery Plan closures 90% 96%

Diversity, Equity and Inclusion – Female

senior leaders (%)

42.0% 40.2%

Total 100% 72.25%

1. Full suite of retirement savings and income products completed in year with the successful launch of the Standard Life Guaranteed Lifetime Income plan.

2. Significant progress in strengthening customer engagement through launches of Annuity Desk and financial advice service, together with a wide range of digital engagement tools

including Retirement Hub and Family Finance Hub.

3. Progressed move to a predominately in-house model for managing annuity backing assets with £7 billion of £41.8 billion portfolio now managed internally with planning

progressing to in-house a further £20 billion. Increases our confidence in the ongoing delivery of recurring management actions and creates greater cost efficiencies.

4. 1.9 million customers successfully migrated to TCS BaNCS and management of a further 1.9 million customers on the ALPHA platform transferred to Wipro with 75% of policies

now on their end state administration platforms. Progress towards our end-state operating model, including actuarial and finance transformation, unlocked cost savings of

£180million, an acceleration versus previous expectations, and on track for our 2026 £250 million cost savings target.

5. Phoenix Unit Trust Managers will be rebranded to Standard Life Fund Management as part of phase two of the rebrand, either late 2026 or early 2027.

6. Sustainability Disclosure Requirements.

As described in the Committee Chair’s covering letter (page 138), the Group has achieved strong financial and non-financial

performance and progress on key strategic objectives during the year. 2025 has resulted in an overall formulaic AIP outcome of

84.8% of maximum for the Executive Directors, achieving 100% of maximum in all financial performance outcomes, 60% of

maximum in non-financial performance outcomes, and 72.25% of maximum under the Strategic Scorecard.

159Standard Life plc Annual Report and Accounts 2025

Corporate governance

Directors’ Remuneration report continued

Annual report on remuneration

The Committee reviewed the AIP outcomes in the context of the Group’s performance, individual performance, strategic delivery

and the experience of broader stakeholders, and is satisfied that the remuneration outcomes for 2025 are an appropriate reflection

of the year’s business performance and its trajectory providing strong alignment between pay and performance. No discretion has

been applied by the Committee in respect of the AIP outcome.

The Committee determined it was appropriate to pay the following outcomes under the AIP for Andy Briggs and Nicolaos Nicandrou.

Name

Corporate

element

outcome (80%

weighting) – % of

maximum and

£000

Scorecard

element

outcome (20%

weighting) – % of

maximum and

£000

Total

outcome – % of

maximum and

£000

Maximum

opportunity as %

of salary and

£000

Andy Briggs 87.9% 72.3% 84.8% 200%

£1,211,133 £248,827 £1,459,960 £1,721,990

Nicolaos Nicandrou 87.9% 72.3% 84.8% 200%

£1,026,867 £210,970 £1,237,837 £1,460,000

LTIP outcomes for 2023 awards – Audited information

Performance

measure Weighting Target range

Performance

achieved

Vesting

outcome % achieved

Relative TSR 20% Target range between median performance

against theconstituents of the FTSE 350 (excluding

Investment Trusts) rising on a pro-rata basis until full

vesting for upper quintile performance.

71st

percentile

80% 16.0%

Net Operating

Cash Receipts

20% Target range of £3.556bn to £4.006bn. £5.157bn 100% 20.0%

Group In-force

Long-term Free

Cash

20% Target range of £14.7bn to £15.4bn. £16.6bn 100% 20.0%

Persistency 20% Target range of 7.10% and 6.08%. 7.3% 0% 0.0%

Decarbonisation

– Investment

Portfolio

5% Net zero strategy applied between target range

of80%and 90% of assets in scope by 2025.

<80.0% 0% 0.0%

5% 25% reduction in carbon intensity

(provided in the best interests of customers).

>25.0% 100% 5.0%

Decarbonisation

– Operations

10% Target range of 75% to 85% reduction pre-offset,

plus net zero post-offset.

82.4% 74% 7.4%

Total 100% 68.4%

The above targets were all measured over the period of three financial years 1 January 2023 to 31 December 2025. The 2023 LTIP

award covering the years 2023–25 has an overall formulaic outcome of 68.4% of maximum resulting from strong Relative TSR, Net

Operating Cash Receipts and Group In-Force Long-term Free Cash. We have significantly outperformed our 3-year Net Operating

Cash Receipts due to the strong performance in 2023 supported by the c.£0.4 billion benefit from the completion of the Phoenix Life

and Standard Life Part VII transfer, and the strong Operating Cash Generation in 2024 and 2025. Group In-force Long-term Free Cash

outperformance is driven by higher cash generation from Life Companies.

The Committee reviewed the LTIP outcomes in the context of the Group’s performance, individual performance, strategic delivery

and the experience of broader stakeholders. Overall, the Committee was satisfied that the LTIP outcome was reflective of

performance and no discretion has been applied by the Committee in respect of the LTIP outcomes.

2025 LTIP underpin

In addition to the above targets, the Committee confirmed that the underpin performance condition relating to risk management

within the Group, customer satisfaction and, in exceptional cases, personal performance had been achieved in the performance

period and that no adjustment is required to the vesting outturn.

Windfall gains

The Committee reviewed the grant price of the 2023 LTIP (576.6 pence) compared to the grant price of the 2022 LTIP (635.9 pence)

and was satisfied that no adjustments were required to the awards on grant for windfall gains. The Committee has again reviewed

the position ahead of the vesting, taking into account the Group’s share price as at 27 February 2026 (767.0 pence), and is satisfied

that no windfall gains have occurred and that no adjustment is required on vesting.

Discretion

Discretion was not applied by the Committee in respect of 2023 LTIP outcomes.

160 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Malus and clawback

In line with the UK Corporate Governance Code 2024 requirements, the Committee confirms that there was no application of malus

and clawback provisions for Executive Directors in the reporting period.

Share-based awards

LTIP targets

The performance conditions for the 2023, 2024 and 2025 awards are set out below.

2023 award 2024 award 2025 award

Performance

measure

20% Net Operating Cash Receipts

20% Group In-force Long-term Free Cash

20% Relative TSR

20% Persistency

20% Decarbonisation

20% Net Operating Cash Receipts

20% Return on Capital

20% Cumulative Net Flows

20% Relative TSR

10% Decarbonisation (Investment Portfolio)

10% Diversity, Equity & Inclusion

20% Cumulative Operating Cash Generation

20% SII Surplus

20% Cumulative IFRS Adjusted Operating Profit

20% Relative TSR

10% Decarbonisation (Investment Portfolio)

10% Diversity, Equity & Inclusion

Net Operating Cash

Receipts

Target range of £3.556bn

to £4.006bn.

Target range of £3.848bn

to £4.298bn.

n/a

Group In-force

Long-term Free Cash

Target range between £14.7bn

and £15.4bn.

n/a n/a

Persistency Target range between 7.10%

and 6.08%.

n/a n/a

Decarbonisation

– Investment

Portfolio

Net zero strategy applied to

target range of 80% to 90%

of in-scope assets and 25%

reduction in carbon intensity

(provided in the best interests

of customers).

Target range of 29% to 35%

carbon intensity reduction of

equity and credit portfolio and

target range of 87.5% to 100%

assets to have agreed

decarbonisation approach

taken through governance.

Target range of 37% to 43%

carbon intensity reduction of

equity and credit portfolio and

target range of 60% to 90% of

private assets to have agreed

decarbonisation approach taken

through governance.

Decarbonisation

– Operations

Target range of 75% to 85%

reduction pre-offset, plus net

zero post-offset.

n/a n/a

Relative TSR

Target range between median performance against the constituents of the FTSE 350

(excluding Investment Trusts) rising on a pro-rata basis until full vesting for upper quintile performance.

Return on Capital n/a Target range between 12.6%

and 14.7%.

n/a

Cumulative

Net Flows

n/a Target range between £(7.1)bn

and £3.8bn.

n/a

Diversity, Equity and

Inclusion – Senior

Leadership Black,

Asian and Ethnic

Minority

Representation

n/a Target range between >12%

and >14%.

Target range between >12%

and >14%.

Cumulative

Operating Cash

Generation

n/a n/a Target range between £4.425bn

and £4.65bn.

SII Surplus n/a n/a Target range between £3.8bn

and £4.1bn.

Cumulative IFRS

Adjusted Operating

Profit

n/a n/a Target range between £3.000bn

and £3.225bn.

1. For each measure above, 25% of the award vests at threshold performance rising on a pro-rata basis until 100% vests. Measured over three financial years commencing with the

year of award.

2. For the investment portfolio that is within control and influence.

3. Includes where the approved strategy can be to take no further action.

4. The Committee must also consider whether the TSR performance is reflective of the underlying performance of the Company measured over three financial years commencing

with the year of award.

A consistent approach to target setting for the LTIP metrics has been taken each year with reference to the Group’s long range plan

so that delivery of target performance is considered to be comparably stretching for each award. The 2026 LTIP cash targets

disclosed on page 165 have been set with reference to the Group’s financial framework.

161Standard Life plc Annual Report and Accounts 2025

Corporate governance

Directors’ Remuneration report continued

Annual report on remuneration

LTIP underpin (2023, 2024 and 2025 awards)

The 2023, 2024 and 2025 awards are subject to an underpin relating to risk management within the Group, consideration of customer

satisfaction and to meet Solvency II requirements, in exceptional cases, personal performance.

From 2026, the underpin framework is being strengthened for the LTIP and AIP. Both plans will be subject to underpins informed by

input from the Employee Engagement Lead and the Chairs of the Risk, Audit, and Sustainability Committees. See page 166 for

further details.

Scheme interests awarded in the year – Audited information

Name

Date

of award

Type

of award

Nature of

the award

How the award

is calculated

Face value

of award

Percentage

vesting at

threshold

performance

Vesting date

Performance

measures

Andy Briggs 1 Apr 2025 LTIP Nil Cost

Option

275% of

salary

£2,382,875 25% 1 Apr 2028 See page

161

DBSS Nil Cost

Option

50% of AIP £661,635 – – None

Nicolaos Nicandrou 1 Apr 2025 LTIP Nil Cost

Option

275% of

salary

£2,007,500 25% 1 Apr 2028 See page

161

DBSS Nil Cost

Option

50% of AIP £50,200 – – None

1. The DBSS awards have no threshold performance level.

The face value represents the maximum vesting of awards granted (before any dividend equivalent options are applied) and is

calculated using a three-day average closing middle market share price prior to the date of grant (2025 LTIP and DBSS price was

572.33 pence).

ShareSave – Audited information

Name

As at

1 Jan 2025

Options

granted

Options

exercised

Options

lapsed

As at

31 Dec 2025

Exercise

price

Exercisable

from

Date

of expiry

Andy Briggs

4,437 – – – 4,437 418.0p 1 Dec 2027 1 Jun 2028

Nicolaos Nicandrou – – – – – – – –

1. Andy Briggs contributed the maximum amount permitted under ShareSave 2024 resulting in no available headroom to join any other plans.

ShareSave options are granted at a 20% discounted option price, calculated using the three-day average share price immediately

before the invitation date.

As a result of Andy Briggs electing to contribute the maximum amount permitted under ShareSave 2024, he had no available award

to exercise in 2025, resulting in a nil gain (2024: nil).

Aggregate gains of Directors from share options exercised under all share plans in 2025 was £1,860,625 (2024: £873,349). This figure

relates to Andy Briggs exercising his 2022 DBSS and 2020 LTIP.

During the year ended 31 December 2025, the highest mid-market price of the Company’s shares was 737.5 pence and the lowest

mid-market price was 479.4 pence. At 31 December 2025, the Company’s share price was 737.0 pence.

Executive Directors’ interests – Audited information

The number of shares and share plan interests held by each Director and their connected persons are shown below:

Name

Share interests as

at 1 January 2025

or date of

appointment if

later

Share interests as

at 31 December

2025

Total share plan

interests as at 31

December 2025

– Subject to

performance

measures

Total share plan

interests as at 31

December 2025

– Not subject to

performance

measures

Total share plan

interests as at 31

December 2025

– Vested but

unexercised

scheme interest

Andy Briggs 423,442 591,809 1,252,431 328,449 385,312

Nicolaos Nicandrou – 144,000 350,759 9,021 –

1. Figures include DBSS awards, shares purchased and awarded under the Share Incentive Plan and options granted under ShareSave.

The share interests of the following Directors have increased between 31 December 2025 and 13 March 2026 (being the latest

practicable date prior to the release of this Annual Report). Andy Briggs and Nicolaos Nicandrou acquired 61 and 60 shares

respectively following purchases under the Group’s Share Incentive Plan.

162 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Shareholding requirements – Audited information

The Executive Directors are subject to shareholding requirements during their employment with the Group and for a period of two

years post termination of employment. Andy Briggs and Nicolaos Nicandrou are subject to a post-cessation shareholding of 100% of

their in-employment shareholding for a period of two years post-employment. The extent to which Executive Directors have achieved

the requirements by 31 December 2025 (using the share price of 737.0 pence as at 31 December 2025) is summarised below.

Vested share awards no longer subject to performance conditions and unvested DBSS awards (both discounted for tax liabilities) are

included within the shareholding requirements. In addition to the share awards and shares previously acquired, Andy Briggs retained

49,870 and 118,497 net shares respectively following his 2022 DBSS and 2020 LTIP exercise. Through participation in the Share

Incentive Plan, a further 512 shares (partnership and dividend) were acquired during 2025. Nicolaos Nicandrou acquired 250 shares

through participation in the Share Incentive Plan.

The extent to which the Executive Directors have achieved their shareholding percentages are shown below:

Name

Shareholding

requirement

(minimum % of

salary)

Shareholding

held as at 31

December 2025

(% of salary)

Andy Briggs 350% 824%

Nicolaos Nicandrou 300% 150%

1. It is expected that shareholding guidelines will be met within five years of appointment.

2. The shareholding percentage also includes shares held by the Executive Directors‘ Persons Closely Associated (PCAs).

As described in the Chair’s covering letter on page 139, the shareholding requirement for the Group CEO will increase from 350% to

425% of salary, from 2026 in line with revised LTIP maximum. The shareholding requirement for the Group CFO will remain at 300%

of salary.

The post-cessation shareholding requirement is monitored and enforced by direct liaison and confirmation with the Executive

Directors and their brokers; all trades and transfers are notified to the Group by the relevant Director and registered accordingly.

The Executive Directors are required to sign a declaration that they have not, and will not at any time during their employment with

the Group, enter into any hedging contract in respect of their participation in the AIP, LTIP, ShareSave, Share Incentive Plan or any

other incentive plan of the Company, or pledge awards in such plans as collateral, and additionally that they will neither enter into a

hedging contract in respect of, nor pledge as collateral, any shares which are required to be held for the purposes of the Company’s

shareholding requirements or any vested LTIP award shares subject to a LTIP holding period.

Non-Executive Directors’ interests – Audited information

The number of shares held by each Director and their connected persons are shown below:

Share interests

as at 1 January

2025 or date

of appointment

if later

Share interests

as at 31

December 2025

or retirement

if earlier

Non-Executive Chair

Sir Nicholas Lyons 105,990 105,990

Non-Executive Directors

Karen Green – –

Siobhan Boylan – –

Eleanor Bucks – –

Karin Cook – –

Sherry Coutu – –

Mark Gregory – –

Hiroyuki Iioka – –

Katie Murray 9,780 9,780

Belinda Richards – –

David Scott – –

Maggie Semple – –

Nicholas Shott 182,146 182,146

163Standard Life plc Annual Report and Accounts 2025

Corporate governance

Directors’ Remuneration report continued

Annual report on remuneration

Implementation of Remuneration Policy in 2026 – Unaudited

A summary of the packages of the Executive Directors is set out in the table below.

Andy Briggs Nicolaos Nicandrou

Salary £886,863, increase of 2.35% aligned

to the wider workforce.

£747,155, increase of 2.35% aligned

to the wider workforce.

Benefits Benefits in line with the rest of the workforce.

Pension Contribution rate of 12% of base salary reduced for the impact of employers’ National

Insurance Contributions.

Annual bonus 200% of base salary at maximum. Details of the 2026 AIP are set out below.

LTIP 425% of base salary. 275% of base salary.

Details of the 2026 LTIP awards are set out overleaf.

Shareholding requirement 425% of base salary. 300% of base salary.

Post-cessation

shareholding requirement

Executive Directors are expected to retain the lower of their shareholding on termination

or their full in-employment shareholding requirement for two years.

Element of Remuneration Policy

Annual Incentive

Plan (‘AIP’)

The Committee regularly reviews the performance measures of the incentive plans to ensure

they remain aligned with our strategy, are appropriately challenging, support the Company’s

culture and values, and create value for stakeholders. Rationale for the metrics selected are

shown on pages 141 to 142 of the Chair’s covering letter.

The performance measures and associated weightings for the 2026 AIP are summarised

below:

Performance measure % of incentive potential

Total Cash Generation 20%

SII Shareholder Own Funds Unrestricted

Tier 1 (excluding economics) 25%

IFRS Adjusted Operating Profit 25%

Net Customer Growth 20%

Customer Retention 10%

Total 100%

The new Net Customer Growth metric will measure net fund flows in our Pensions and

Savings business. Net fund flows is an in-year movement representing aggregate net position

of gross assets under administration (‘AUA’) inflows less gross outflows (adjusted), reflecting

both new business growth and the retention of existing business.

Customer Retention in our Pensions and Savings business will measure the retention of

Standard Life branded pension customers, reflecting internal transfers as a proportion of

total transfers.

Whilst the performance measures for the 2026 AIP are disclosed above, the actual

performance targets for these measures are regarded as commercially sensitive at the current

time and accordingly are not disclosed. However, as in previous years, the Group intends to

disclose the performance targets for the 2026 AIP retrospectively in next year’s Remuneration

report on a similar basis to the disclosures made above in respect of the 2025 AIP.

The AIP will be subject to underpins informed by input from the Chairs of the Risk, Audit, and

Sustainability Committees and the DNED for Workforce Engagement. Adjustments to

outcomes may range from 0–100%, depending on the materiality and significance of any

issues identified. Further detail is provided on page 166.

50% of outcomes under the 2025 AIP will be delivered as an award of deferred shares under

the DBSS which will vest after a 3-year deferral period.

164 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Andy Briggs Nicolaos Nicandrou

Long Term Incentive

Plan (‘LTIP’)

Awards under the LTIP will usually be granted at the beginning of April following the

announcement of the Group’s 2025 annual results.

The Committee reviews the performance measures and targets of the LTIP each year to ensure

these act as a driver of our customer-focused growth strategy. Following this review, the

Committee is proposing a number of changes to performance metrics to better align with the

next phase of growth and our evolving strategy, ensuring that our incentives drive superior

customer and investor returns. The key principles underpinning these changes – and a summary

of metrics proposed for 2026 – are detailed in the Chair’s covering letter on pages 141 to 142.

Consistent with previous years, targets have been set with reference to the Group Strategic

Financial Business Plan and market consensus, and maximum payouts will only be delivered in

the event of exceptional performance.

The targets are measured over a period of three financial years, commencing with financial

year 2026.

Metrics, weightings and targets are shown below:

Performance measure Weighting Threshold target Full vesting target

Cumulative Operating

Cash Generation

20% £4,485m £4,975m

SII Surplus 20% £3,700m £4,500m

Cumulative IFRS

Adjusted Operating Profit

20% £3,375m £3,750m

Relative TSR vs FTSE 350

(excl. Investment Trusts)

20% 50th percentile 80th percentile

Relative Policyholder Outcomes

(pension fund value growth)

20% 50% assets under

management (‘AUM’)

in Standard Life

Sustainable Multi-

Asset Growth and

comparable Multi

Asset funds ahead

ofpeer median

withunderpin of

achievingat least

inflation growth

80% AUM in Standard

Life Sustainable

Multi-Asset Growth

and comparable Multi

Asset funds ahead

ofpeer median

withunderpin of

achievingat least

inflation growth

A consistent approach to target setting is taken each year with reference to the Group’s

Strategic Financial Business Plan so that delivery of target performance is considered to be

comparably stretching for each award.

The new customer outcomes metric, Relative Policyholder Outcomes, will track how we

support more of our customers to achieve better returns, through our flagship multi-asset

default pension funds (Sustainable Multi-Asset (‘SMA’) and Multi-Asset Comparable funds).

We want to help more customers achieve better outcomes and greater financial security

through these best-in-class solutions, which will be our primary route to support the growing

market (through growth in the defined contribution pension market and consolidation). These

are funds where we have full discretion over the investment strategy and we will aim to deliver

customer outcomes ahead of peers and long-term real returns above inflation (UK CPI).

The LTIP will be subject to underpins informed by input from the Chairs of the Risk, Audit,

andSustainability Committees and the DNED for Workforce Engagement Committees.

Adjustments to outcomes may range from 0–100%, depending on the materiality and

significance of any issues identified. Further detail is provided on page 166.

All-employee

share plans

Executive Directors have the opportunity to participate in HMRC tax advantaged ShareSave

and Share Incentive Plans on the same basis as all other UK employees. Employees based in

the Republic of Ireland and Germany have the opportunity to join the Irish Share Incentive

Plan and the International Purchase Plan.

165Standard Life plc Annual Report and Accounts 2025

Corporate governance

New underpin introduced for 2026 AIP and LTIP

When determining performance outcomes, the Committee has adopted a discretion framework which it will apply when assessing

AIP and LTIP outcomes to include input from Chairs of the Risk, Audit, and Sustainability Committees and the DNED for Workforce

Engagement. Discretionary framework adjustments may reduce outturns by 0%–100% depending on materiality of any issues/

events identified. Using the formulaic outcome for the AIP and LTIP against existing targets as a starting point, the following

illustrative framework will be used.

Recommendations from Chairs of Risk, Audit, and Sustainability

Committees and the DNED for Workforce Engagement

Is the outcome

consistent with

overall Company

performance?

Progress against Net

Zero Plan, diversity

in Senior Leadership,

sustainable product

development

Is the outcome

consistent with the

wider stakeholder

experience?

Customer

experience KPIs,

Colleague Net

Promoter Score,

key employee

programmes

Are there any

material risk, audit,

culture, ESG or

operational issues to

be considered?

Quality of earnings

assessment, internal

audit and financial

control standards,

solvency position,

compliance with

accounting standards

Are there any

one-off or

exceptional events

to be taken into

consideration?

Risk and control

behaviours, control

environment

maturity, adherence

to corporate risk

appetite, customer

digitalisation

Indicative

areas

Evidenced by

Key questions

to consider

Progress against key sustainability, people (including Diversity, Equity, and Inclusion) and culture ambitions will form a key input for

the Committee’s assessment of any adjustments to be made (which could be up to 100% of total remuneration) and

recommendations provided to the Remuneration Committee on whether overall performance is consistent with the Company’s

targets in this area. This will include an assessment of progress against our Net Zero Transition Plan, including specific quantifiable

targets and management action commitments as detailed on page 135.

The Remuneration Committee will consider the above input to determine whether the formulaic outcomes are appropriate and

retains full discretion to determine whether, and to what extent, any adjustment to incentive outcomes is required. The proposed

framework does not remove the ability of the Remuneration Committee to apply positive discretion in exceptional circumstances.

Directors’ Remuneration report continued

Annual report on remuneration

166 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Consideration of employee pay

When determining the Remuneration Policy and remuneration for our Executive Directors, the Committee took into consideration

the pay and benefits of the wider workforce to ensure that our reward offering remains competitive, attractive, and suitably aligned

to our Group performance, while supporting our values and purpose of helping people secure a life of possibilities.

We have a reward policy that is broadly consistent for all levels of employees, with the same remuneration principles guiding reward

decisions for all Group colleagues, including Executive Directors. The AIP and LTIP performance metrics are the same for Executive

Directors as for other eligible colleagues, with a higher proportion of total remuneration for the Executive Directors linked to

corporate performance. Pay for the wider colleague base is driven primarily by market practice and there is a standard benefit

offering across all levels, except where the external market drives differences based on role accountability. Colleagues are also

eligible to participate in the Group’s success through our share plans (ShareSave and Share Incentive Plan) on the same basis as those

offered to Executive Directors.

We offer benefits which engage and retain our existing colleagues, as well as attract new talent to the organisation. To support this,

we offer a transparent flexible and tailored reward package that is competitive in the market, with clear principles around pay,

alongside comprehensive benefits and wellbeing support. Our diversity, equity and inclusion agenda remains an integral underpin to

our approach to reward. Our diversity data questionnaire within our HR system enables us to continually understand the diversity

and needs of our colleagues. This data is also integral to our gender and ethnicity pay gap reporting and provides insight to where we

may need to implement targeted and focused initiatives to make real change.

We aim to pay a fair, market-aligned remuneration package for colleagues based on their skills, knowledge and expertise using our

grading structure to benchmark not only the accountability of the role and the external market rate, but also the colleague’s ‘toolkit’

of experience they bring. We provide transparent salary ranges for our colleagues and ensure that all colleagues below the minimum

of their pay range have their fixed pay increased to that minimum level on an annual basis. This is an ongoing commitment that will

see all colleagues receive increases to the minimum level of our pay ranges each year as part of our annual pay review. We continue

to be a proud Real Living Wage employer, and are committed to ensuring that these pay ranges, which are reviewed annually, will

always be at or above the Real Living Wage.

Equal pay and consistency of treatment for all colleagues, irrespective of gender or ethnicity, are integral guiding principles of the

reward practices across the Group. The remuneration principles and framework are reviewed on a regular basis to ensure these are

aligned with the Group’s purpose, values and sustainability strategy. Maggie Semple, our Designated NED for Workforce Engagement,

is a member of the Remuneration Committee and provides additional input to the Committee on the views of the wider workforce.

Further details of Maggie Semple’s engagement with the workforce throughout 2025 are shown on pages 104 to 105 of the

Corporate governance report.

167Standard Life plc Annual Report and Accounts 2025

Corporate governance

Directors’ Remuneration report continued

Annual report on remuneration

Wider workforce pay in 2026

Alignment to wider workforce

The Committee considers a range of factors when setting the remuneration for Executive Directors, one of which is the alignment

with remuneration practices across the wider workforce. We provide colleagues across the Group with a competitive reward package

with details of each element included in the table below.

Executive Directors and Executive Committee Senior Management Wider workforce

Salary Salaries are reviewed annually and increases are typically in line

with or less than the wider employee population.

Base salary is the basis for a

competitive total reward package

for all employees, and these are

reviewed annually with engagement

from employee representatives.

Regular benchmarking exercises are

carried out to ensure salaries remain

competitive against the market.

We are an accredited Living Wage

employer and all employees are paid

at least the Real Living Wage.

Benefits

and Pension

All employees are eligible to participate in our range of flexible benefits and wellbeing initiatives in

respective markets.

Core benefits include private medical cover, life assurance cover, group income protection and a range

of flexible benefits. The level of core benefits is the same across all grades.

Colleagues can participate in a share matching plan under the Group Share Incentive Plan and, in the UK,

theGroup ShareSave plan.

All employees are automatically enrolled in the Company’s Master Trust pension scheme with a 10% core

contribution and 2% matching contribution (plus salary sacrifice uplift of 10% of the employee contribution).

Payment in lieu of contribution, reduced for the impact of employers’ National Insurance Contributions is

permitted where lifetime or annual limits are reached. Separate occupational pension schemes with varying

contribution rates operate in Ireland and Germany.

AIP All permanent and fixed-term employees are eligible to participate in a discretionary AIP with overall bonus

funding determined by Group measures. Awards are distributed on a fully discretionary basis considering

functional and individual performance. Malus and clawback provisions apply.

Deferral Half of any AIP award is

subject to deferral into

shares for a 3-year period.

Malus and clawback

provisionsapply.

One-third of any AIP award is

subject to deferral into shares

for a 3-year period.

Malus and clawback

provisionsapply.

Deferral where required on

an individual basis for Solvency II

purposes, and within our Retirement

Solutions and Asset Management

business where AIP award exceeds

a£75,000 threshold.

Malus and clawback provisionsapply.

LTIP Senior Executives participate in an LTIP with a 3-year performance

period and vesting is subject to Group performance outcomes.

Measures and targets for the LTIP are consistent for

all participants and measured over a 3-year period.

Malus and clawback provisions apply.

Whilst LTIP allocation can extend

below Senior Management,

in practice this is rarely done.

Holding period A two-year holding period

afterthe vesting date also

applies for LTIPs.

No holding period. Not applicable.

Shareholding

requirement

Shareholding requirements

ensures greater alignment

with interests of shareholders.

• 425% of salary for Group CEO

• 300% of salary for Group CFO

• 150% of salary for ExCo members

Not required. Not applicable.

168 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Non-executive fees – Audited information

The emoluments of the Non-Executive Directors for 2025 based on the current disclosure requirements were as follows:

Name

Directors’ fees Benefits

Total

2025

£000

2024

£000

2025

£000

2024

£000

2025

£000

2024

£000

Non-Executive Chair

Sir Nicholas Lyons 497 460 5 5 502 465

Non-Executive Directors

Karen Green 176 161 1 5 177 166

Siobhan Boylan

– – – – – –

Eleanor Bucks

3,11

117 96 1 5 118 101

Karin Cook

4,11

60 – 6 – 66 –

Sherry Coutu

73 – 4 – 77 –

Mark Gregory

6,11

160 133 – 4 160 137

Hiroyuki Iioka

– – 1 8 1 8

Katie Murray 113 108 – 3 113 111

Belinda Richards

87 134 1 4 88 138

David Scott

– – 3 2 3 2

Maggie Semple 132 142 1 3 133 145

Nicholas Shott

82 164 3 7 85 171

Total 1,497 1,398 26 46 1,523 1,444

1. The amounts within the benefits columns reflect the reimbursement of business expenses to Non-Executive Directors for travel and accommodation costs incurred whilst

attending Board and associated meetings represent a taxable benefit. This position has been clarified with HMRC and the amounts shown are for reimbursed expenses (and the

related tax liability which is settled by the Group).

2. Siobhan Boylan was appointed as a Director of the Group Board on 1 September 2025 and has waived all current and future emoluments with regard to Directors’ fees.

3. Eleanor Bucks became a member of the Group Board Risk Committee on 12 May 2025 and the Group Board Audit Committee on 25 August 2025.

4. Karin Cook was appointed to the Group Board as a Dual Director on 25 August 2025.

5. Sherry Coutu was appointed as a Director of the Group Board on 1 May 2025 and became Chair of the Group Board Remuneration Committee on 1 July 2025.

6. Mark Gregory was appointed as a Dual Director to the Life Companies Board on 25 August 2025 and became a member of the Group Board Remuneration Committee on 1 December 2025.

7. Hiroyuki Iioka has waived all current and future emoluments with regard to Directors’ fees.

8. Belinda Richards retired from the Group Board on 24 August 2025.

9. David Scott retired from the Group Board on 31 August 2025.

10. Nicholas Shott retired from the Group Board on 30 June 2025.

11. Some Group Directors are also Directors of certain subsidiary boards which is reflected within the fee and benefits calculation.

The aggregate remuneration of all Executive and Non-Executive Directors under salary, fees, benefits, cash supplements in lieu

ofpensions and annual incentive was £8.435 million (2024 restated: £6.354 million).

Implementation of Remuneration Policy in 2026 (Non-Executive Directors) – Unaudited

A summary of the annual base fees of the Non-Executive Directors is set out below.

Fee from

1 April 2025

£000

Fee from

25 August 2025

£000

Fee from

1 April 2026

£000

Chair of the Group Board and Joint Group and Life Companies Boards 472 550 550

Group Non-Executive Director 78 82 82

Non-Executive Director (Dual Director)– additional fee where either an additional

Group or Life Companies Board Non-Executive Director

_ 16.4 16.4

Group Senior Independent Director 20 30 30

Designated Non-Executive Director for Workforce Engagement 15 20 20

Group Audit, Risk and Remuneration Committee Chair 30 40 40

Group Sustainability Committee Chair 30 30 30

Group Committee Chair (Dual Director) – additional fee where an additional Life

Companies Board Committee Chair

_ 10 10

Group Committee member 18 18 18

The Committee agreed to increase the Chair’s fee to £550,000 (an increase of £78,000) with effect from 25 August 2025. Following

this increase, fees will not be reviewed again until 1 April 2027 in line with the wider workforce. The fees above reflect the additional

responsibilities associated with chairing the Joint Group and Life Companies Board meetings. The Group Chair must possess the

necessary experience, skillset and ability to lead these meetings effectively –ensuring that all members can challenge and contribute

meaningfully, and that Management receives clear actions and outputs. Additionally, the Chair must carefully manage any potential

conflicts of interest between the Group and Life Companies Boards. The Committee considered that, given the Chair has not

received an increase in fees since 2021, the introduction of this new Joint Meeting Model was an appropriate time to review fees

toensure they reflect time commitment responsibilities.

Non-Executive Director fees are not a matter for the Committee’s remit, but rather a matter for the Group Chair and Executive

Directors. Following a comprehensive review of time commitment and market data for FTSE 350 insurers, other adjustments were

made to fees to ensure they remain market competitive and fairly reflect the responsibilities and skillset required, noting that fees

generally have historically not been increased in line with wider workforce pay.

169Standard Life plc Annual Report and Accounts 2025

Corporate governance

Directors’ Remuneration report continued

Annual report on remuneration

Performance graph and table

The graph below shows the value to 31 December 2025 on a TSR basis, of £100 invested in Standard Life plc (formerly Phoenix Group

Holdings plc) on 31 December 2015 compared with the value of £100 invested in the FTSE 100 Index and the FTSE 350 index

(excluding Investment Trusts).

The FTSE 100 Index is considered to be an appropriate comparator for this purpose as it is a broad equity index of which the Group is

a constituent, and the FTSE 350 index (excluding Investment Trusts) is the comparator index for the Relative TSR component of the

Group’s Long-Term Incentive Plan.

Total shareholder return

Value of a 100 unit investment made on 31 December 2015.

Dec 2015 Dec 2016 Dec 2017 Dec 2018 Dec 2019 Dec 2020 Dec 2021 Dec 2022 Dec 2023 Dec 2024 Dec 2025

250

200

150

100

£6,000

£5,000

£4,000

£3,000

£2,000

£1,000

CEO single figure of total remuneration

FTSE 100 Index

Standard Life (formerly Phoenix Group Holdings plc)

FTSE 350 (excluding Investment Trusts) Index

Value of a 100 unit investment

made on 31 December 2015

CEO single figure of total remuneration £000

Group CEO remuneration

Single figure of

total

remuneration

(£000)

Annual variable

element award

rates against

maximum

opportunity

(‘AIP’)

Long-term

incentive vesting

rates against

maximum

opportunity

(‘LTIP’)

2025 Andy Briggs 4,866 84.8% 68.4%

2024 Andy Briggs 3,610

78.3% 51.1%

2023 Andy Briggs 2,975 73% 41.1%

2022 Andy Briggs 3,112 87% 44.3%

2021 Andy Briggs 1,831 78% n/a

2020 Andy Briggs

1,706 83% 0.0%

Clive Bannister

3,5

321 81% n/a

2019 Clive Bannister 2,715 92% 68.5%

2018 Clive Bannister 2,567 86% 49.5%

2017 Clive Bannister 2,888 86% 64.0%

2016 Clive Bannister 2,878 84% 55.0%

1. Figures are restated for actual share price in year of vesting.

2. Andy Briggs was not in receipt of a 2019 LTIP due to the timing of his appointment.

3. Clive Bannister left the role of Group CEO on 10 March 2020 and left the Group on the same date. Andy Briggs was appointed to the Board on 10 February 2020

and remained as CEO-designate until 10 March 2020. The total figure of remuneration for 2020 shown below is a combination of the single figures for Clive Bannister

and Andy Briggs to reflect the change in Group CEO in 2020.

4. See footnote 11 on page 130 of the 2020 Annual Report and Accounts for details of Andy Briggs’ LTIP vesting.

5. Clive Bannister’s 2020 single figure of total remuneration does not include compensation for loss of office.

6. Clive Bannister’s 2020 single figure of total remuneration does not include any value in respect of the 2018 LTIP. LTIP awards which vested after Clive Bannister stepped

down from the Board have been reported as Payments to Past Directors on page 132 of the 2022 Annual Report and Accounts and are not included in the single figure

of total remuneration, in line with the reporting regulations.

170 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Group CEO pay ratio

The table below details the Group CEO pay ratio for the year ended 31 December 2025, in line with the UK regulatory requirements.

Theratios compare the Group CEO total pay against the pay of three UK employees, whose earnings represent the lower quartile,

median, and upper quartile positions of the UK employee population. The calculations are based on Option A of the three

methodologies, which we believe is the most statistically robust approach.

The Group CEO value used is the total single figure remuneration data for 2025 (as detailed on page 157). For the 2025 ratio, the

total compensation figure for UK employees follows the same methodology as for the Group CEO and is based on a full-time

equivalent of actualearnings including amounts due from incentive plans.

The Group reviewed the pay of the three identified employees at the 25th percentile, 50th percentile (median) and 75th percentile

and concluded that they were a fair representation of pay at the relevant quartiles of the UK employee base. Each individual was a

direct employee on a permanent or fixed-term contract during 2025 and received remuneration in line with Group-wide

remuneration policies. None received an exceptional award that would otherwise inflate their pay figure.

The table below sets out the salary and total single figure remuneration for the Group CEO and percentile employees included in

thebelow ratios.

Year Methodology Group CEO

25th

percentile

50th

percentile

(median)

75th

percentile

Salary (earned in 2025) 2025 Option A £860,995 £40,434 £56,357 £82,209

Total remuneration (single figure) £4,865,898 £50,086 £76,304 £109,322

2025 ratio (total compensation) 97:1 64:1 45:1

2024 ratio (total compensation) 82:1 52:1 36:1

2023 ratio (total compensation) 87:1 54:1 34:1

2022 ratio (total compensation) 100:1 69:1 41:1

2021 ratio (total compensation) 66:1 46:1 26:1

2020 ratio (total compensation) 78:1 54:1 31:1

2019 ratio (total compensation) 94:1 62:1 40:1

The above figures show an increase in median ratio for 2025. Salary and total compensation levels at the relevant data points have

increased reflecting our continuing Group-wide organisational review and capability uplift to deliver on our future strategy. This has

included a number of lower paid colleagues transferring out of the Group as part of our ongoing outsourced strategy. The increase in

ratio for 2025 primarily reflects the increase in the 2023 LTIP outturn for the Group CEO compared to the 2022 LTIP outturn as shown

on page 157.

Colleagues are also covered for Death in Service and Group Income Protection and are eligible to participate in our all-employee

share plans. These figures are not included in the total remuneration figures shown above. Over half of all employees participate in

our growth and success through either ShareSave, the Share Incentive Plan or the International Purchase Plan. We are committed to

attracting best-in-class talent at all levels with a compelling and competitive total reward proposition. This includes a holistic core

and flexible suite of benefits with the ability to customise these to meet individual needs, as well as industry-leading people policies

including equal parental leave.

We are confident that the median pay ratio reported this year is consistent with our approach to pay, reward, career progression and

growth for all colleagues. All colleagues have the opportunity for annual pay awards, performance-driven pay and recognition, as

well as access to opportunities to develop their careers at the Group and create a culture that’s connected, innovative, and ambitious.

171Standard Life plc Annual Report and Accounts 2025

Corporate governance

Directors’ Remuneration report continued

Annual report on remuneration

Directors’ percentage change in pay 2024 to 2025

The table below provides a comparison of the percentage change in the prescribed pay elements of each individual who was a Director

during the year (salary, taxable benefits and annual incentive outcomes) between financial years 2024 and 2025 and the equivalent

percentage changes in the average of all staff employed by the Group. As no staff are employed directly by Standard Life plc (formerly

Phoenix Group Holdings plc), we have disclosed information for an appropriate group that is representative of the employees of the

Group and its subsidiaries, in line with the regulatory guidance for this disclosure). This group was selected as being representative

ofthe wider workforce using the same process as was used for this comparison in last year’s Annual Report and Accounts.

Salary % Taxable benefits % Annual incentive %

Year-on-year % change 2025 2024 2023 2022 2021 2025 2024 2023 2022 2021 2025 2024 2023 2022 2021

Executive Directors

Andy Briggs 2.0 1.0 3.4 1.1 0.0 2.1 0.4 (0.96) 2.6 3.3 10.3 7.8 16.6 12.4 (5.5)

Nicolaos Nicandrou

1100 n/a

– – – 2897 n/a

– – – 1133 n/a

– – –

Non-Executive Chair

Sir Nicholas Lyons 8.1 1,100 (87.5) (17.1) 13.8 8.8 n/a

(100) 897.6 0.0

n/a

Non-Executive Directors

Karen Green 8.9 (6.8) 8.9 12.8 12.8 (86.4) 142.1 (26.2) 362.9 0.0

Siobhan Boylan 0.0 – – – – n/a

– – – –

Eleanor Bucks 22.3 n/a

– – – (83.4) n/a

– – –

Karin Cook n/a

– – – – n/a

– – – –

Sherry Coutu n/a

– – – – n/a

– – – –

Mark Gregory 20.2 55.7 – – – (100) 61.2 – – –

Hiroyuki Iioka 0.0 0.0 0.0 0.0 0.0 (88.4) n/a

0.0 0.0 0.0

Katie Murray 4.7 0.7 45.4 n/a

– (95.2) 124.1 (3.3) n/a

–

Belinda Richards (35.1) 6.6 8.4 4.5 5.7 (78.4) 89.8 (10.7) 0.0 0.0

David Scott 0.0 0.0 – – – 27.9 n/a

– – –

Maggie Semple (6.5) 10.4 102.8 n/a

– (53.8) 28.6 106.4 n/a

–

Nicholas Shott (50) 3 14.5 7.7 22.8 (58.5) 211.7 42.8 208.3 (100)

Wider employee population 4.4 4.8 8.9 4.4 4.7 16.8 (9.6) (55.3) 57.2 1.4 6.1 7.3 11.5 27.6 9.1

1. The taxable benefits figures used for Andy Briggs and Nicolaos Nicandrou include ongoing taxable benefits only.

2. The increase in salary, benefits and annual incentive for Nicolaos Nicandrou reflect a full year’s pay and bonus for 2025 compared to 2024 figures which were from his appointment

to the Board on 2 December 2024 only.

3. n/a is provided when no salary, fee or taxable benefit were received in the prior year and therefore it is not possible to calculate a percentage change.

4. Percentage change in fees were due to the implementation of the Joint Meeting Model on 24 August 2025 which resulted in increased fees due to additional responsibilities and

roles, such as a Dual Director, changes to Committee membership or to reflect the additional skillset required to chair Joint Group and Life Companies Board meetings. See page

169 for further details on fees and taxable benefits for Non-Executive Directors.

5. Non-Executive Directors are not in receipt of payments relating to the Group’s Annual Incentive Plan.

The figure shown above in respect of salary for Andy Briggs reflects the increase effective 1 April 2025. The taxable benefits figure

reflects the increase in premium for private medical cover (same level of cover as in 2024), and the increase in AIP reflects the higher

outturn under the Corporate element compared to 2024. Although all colleagues benefitted from the higher Corporate outturn in

2025, the year-on-year AIP percentage increase for the Group CEO vs 2024 was higher than that of the workforce, reflecting both the

use of a discretionary downward adjustment in 2024, and the differing weighting on the Corporate and strategic scorecards.

Figures for Nicolaos Nicandrou reflect a full year for salary, benefits and annual incentive compared to 2024 which showed these

amounts from his appointment to the Board on 2 December 2024.

With regard to the figures for the wider employee population:

• The pay review in April 2025 was operated using a consistent approach with a pay budget of 3.0%. As in 2024, the pay budget firstly

allocated awards to bring all colleagues up to at least the minimum of the salary ranges we published, ensuring all colleagues are

paid the market minimum for the role they perform. Leaders were then empowered to make discretionary pay awards within the

remaining pay award budget, ensuring colleagues were remunerated for the skills, knowledge and experience they bring to the

role. Additional out-of-cycle salary increases were awarded throughout the year, where appropriate, to maintain internal relativity,

support progression aligned to the colleagues’ ‘toolkit’, and to retain talent.

• The change to the taxable benefits figure is as a result of an increase to the premium under our comprehensive Private Medical

Insurance cover which we offer to all colleagues on a consistent basis.

• The increase in annual incentive payments compared to 2024 reflects the higher Corporate outturn achieved in 2025.

172 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Distribution statement

The DRR Regulations require each quoted company to provide a comparison between profits distributed by way of dividend and

overall expenditure on pay.

Relative importance (£m)

2025

750

721

540

556

2024

Profits distributed by way of dividend (% change +3%)

Overall expenditure on pay (% change -4%)

Profits distributed by way of dividend has been taken as the dividend paid and proposed in respect of the relevant financial year.

For2025 this is the interim dividend paid (£274 million) and the recommended final dividend of 28.05 pence per share multiplied by

the total share capital issued at the date of the Annual Report and Accounts as set out in note D1 in the notes to the consolidated

financial statements. No share buybacks were made in the year.

Overall expenditure on pay has been taken as employee costs as set out in note C5 Expenses in the notes to the consolidated

financial statements. Expenditure on pay has decreased by 4% in the period, reflecting the impact of the reduced headcount

following the launch of the Group’s operational simplification programme in 2024. This reduction has been partially offset by

inflationary pay increases to the wider workforce and the impact of the changes to employers’ national insurance which came

intoeffect on 1 April 2025.

Payments for loss of office – Audited information

There were no payments for loss of office in 2025.

Payments to past Directors – Audited information

As disclosed in the 2024 Directors’ Remuneration report, Rakesh Thakrar stepped down from the Board and his position as Group

Chief Financial Officer and Executive Director on 8 September 2024 and went on garden leave effective from this date to his initial

termination date of 13 May 2025. At Rakesh’s request, his termination date was brought forward to 30 November 2024 as a result

ofsecuring employment elsewhere.

In the period from 1 January 2025 to 13 May 2025, Payment in Lieu of Notice (‘PILON’) was paid, but was reduced by the level of

remuneration paid by his new employer. PILON payments in respect of the 2025 financial year totalled £4,305.

In line with the Remuneration Policy, Rakesh was deemed to be an Approved Leaver in respect of the 2024 AIP and 2022, 2023 and

2024 LTIP plans and as such, Approved Leaver provisions apply. Rakesh’s in-flight LTIP awards (which include the 2022, 2023 and 2024

LTIPs) were pro-rated to his termination date of 30 November 2024. Final vesting of the LTIP awards will be determined by the

Committee at the conclusion of each performance period upon assessment of the achievement of the conditions set out for each

award. Unvested LTIP awards will continue to vest on the normal vesting dates and will remain subject to their respective holding

periods and malus and clawback provisions.

In line with the performance conditions as set out on page 160, the estimated value of Rakesh’s 2023 LTIP that is due to vest in March

2026 totals £605k. This is based on the average share price between 1 October 2025 and 31 December 2025 (682.25 pence). £72k of

this figure relates to share price appreciation over the performance period. An updated figure based on the actual share price at the

date of vesting will be disclosed in the 2026 Directors’ Remuneration report.

An estimated figure of £462k in respect of the vesting of Rakesh’s 2022 LTIP award was included in the 2024 Directors’ Remuneration

report. This was based on the average share price between 1 October 2024 and 31 December 2024 (511.05 pence). The actual figure

at vesting in March 2025 was £526k which is based on the actual share price at the date of vesting (581.25 pence).

Rakesh continues to be subject to a post-cessation shareholding requirement of 300% of salary until 30 November 2026.

173Standard Life plc Annual Report and Accounts 2025

Corporate governance

Directors’ Remuneration report continued

Annual report on remuneration

Executive Directors’ service contracts

The dates of contracts and letters of appointment and the respective notice periods for Executive Directors are as follows:

Name Date of service contract Notice period from either party (months)

Andy Briggs 7 November 2019 12

Nicolaos Nicandrou 5 November 2024 12

External directorships

Details of external directorships held by Executive Directors can be found on pages 88 to 91 of the Annual Report.

Non-Executive Directors’ letters of appointment

Name

Date of current appointment/

re-appointment letter

Date of expiry of current appointment/

re-appointment letter

Unexpired term

(months)

Sir Nicholas Lyons 2 December 2024 31 October 2028 6

Karen Green 12 May 2023 30 June 2026 1

Siobhan Boylan 15 August 2025 31 August 2028 1

Eleanor Bucks 23 November 2023 30 November 2026 1

Karin Cook

14 August 2025 1 May 2027

Sherry Coutu 13 March 2025 30 April 2028 1

Mark Gregory 13 March 2026 31 March 2029 1

Hiroyuki Iioka 22 July 2023 22 July 2026 1

Katie Murray 1 April 2025 31 March 2028 1

Maggie Semple 22 May 2025 31 May 2028 1

1. The date of expiry refers to each individual Directors’ letter of appointment which covers a 3-year term. All Directors are subject to annual re-election at the AGM on 14 May 2026.

2. Karin Cook’s 3-year term commenced on 1 May 2024, aligned with the date of appointment as a Non-Executive Director of the Life Companies Board.

The tables above have been included to comply with UKLA Listing Rule 6.6.6(7). In the event of cessation of a Non-Executive

Director’s appointment (excluding the Chair of the Group Board) they would be entitled to a one-month notice period. The Chair

ofthe Group Board, as detailed in his letter of appointment, would be entitled to a six-month notice period.

Dilution

Awards granted under the LTIP and International Purchase Plan are satisfied through shares purchased in the market and held in the

Employee Benefit Trust. A dividend waiver is in place for all shares. ShareSave and the DBSS are satisfied through newly issued shares.

The Group monitors the number of shares issued, and their impact on dilution limits as stipulated by the Investment Association (all plans

10%, and Executive share plans 5% in any rolling 10-year period). At 31 December 2025, dilution was 1.98% and 0.96% respectively.

Advice provided to the Committee

During the year, the Committee received independent remuneration advice from its appointed advisers.

The Committee assesses the performance of its advisers regularly and reviews the quality of advice provided to ensure that it is

independent of any support provided to Management. As PricewaterhouseCooper (‘PwC’) had been advisers for seven years, a

tender invitation was issued tofiveadvisers. Evaluation criteria included proven experience providing quality advice to Remuneration

Committees in comparable organisations, and deep subject matter expertise across all relevant areas of the Committee’s remit,

including remuneration, benchmarking, corporate governance, and regulation. As a result of this tender, Deloitte LLP was appointed

as the Committee adviser with effect from 11 July 2025.

174 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Both PwC and Deloitte LLP are members of the Remuneration Consultants Group (the professional body for remuneration

consultants) and adhere to its code of conduct. The Remuneration Committee was satisfied that the advice provided by both

advisers was objective and independent.

Deloitte and PwC also provided general remuneration consultancy services to Management during the year. Separate teams

withinPwC and Deloitte provided unrelated professional services to the Group during the year; PwC provided services in respect of

tax, assurance, risk consulting and advisory, and Deloitte provided services including technology consulting, tax advisory, finance and

accounting, and cyber services. TheCommittee is satisfied that these activities did not compromise the independence or objectivity

of the advice it has received as Remuneration Committee advisers. PwC’s fees for work relating to the Committee for the period

1 January 2025 to 11 July 2025 were £117,885 which included an initial review of the Remuneration Policy renewal. These were

charged on the basis of the firm’s standard terms of business for advice provided.

Deloitte LLP fees for work relating to the Committee for the period 11 July 2025 to 31 December 2025 were £206,940.

The Group CEO, Chief People Officer, Reward Director, Head of Executive Compensation and Group CFO attend various Committee

meetings by invitation during the year. No Executive is ever permitted to participate in discussions or decisions regarding his or her

own remuneration.

The Committee consults with the Group Chief Risk Officer (without Management present) on a regular basis. The Group Chief Risk

Officer is asked to detail the extent to which the Group has operated within its stated risk appetite during the year and to keep the

Committee informed of any risk-related concerns that required the Committee to consider using its judgement to moderate

incentive plan outcomes.

Voting outcomes on remuneration matters

The table below shows the votes cast to approve the Directors’ Remuneration report for the year ended 31 December 2024 at the

2025 AGM held on 13 May 2025 and the Directors’ Remuneration Policy at the 2023 AGM held on 04 May 2023.

For Against Abstentions

Number % of votes cast Number % of votes cast Number

To approve the Directors’ Remuneration report

for the year ended 31 December 2024 (2025 AGM)

687,401,105 95.92 29,230,842 4.08 13,216,384

To approve the Directors’ Remuneration Policy

(2023 AGM)

764,184,513 98.81 9,241,995 1.19 216,361

Approval

This report in its entirety has been approved by the Remuneration Committee and the Board of Directors and signed on its behalf by:

Sherry Coutu CBE

Chair of the Group Board Remuneration Committee

Approved by the Board on 13 March 2026

175Standard Life plc Annual Report and Accounts 2025

Corporate governance

Directors’ report

The Directors present their report for the year ended 31 December

2025. Standard Life plc (formerly Phoenix Group Holdings plc) is

incorporated in England and Wales (registered no. 11606773) and

islisted on the London Stock Exchange under the ‘Equity shares

(commercial companies)’ category.

Shareholders

Dividends

Dividends for the year ended

31December 2025

Dividends for the year are as follows:

Ordinary shares

Paid Interim dividend 27.35p per share (2024: 26.65p per share)

Recommended Final dividend 28.05p per share (2024: 27.35p per share)

Total ordinary dividend 55.40p per share (2024: 54.00p per share)

Dividends declared in respect of the Company’s ordinary shares must be capable of being

cancelled and withheld or deferred at any time prior to payment. This is so that the Company’s

ordinary shares can be counted towards Group capital. Accordingly, the Final dividend will be

declared on a conditional basis and the Directors reserve the right to cancel or defer the

recommended dividend. The Directors do not expect to exercise this right other than where

they believe that it may be necessary to do so as a result of legal or regulatory requirements.

Share capital

Issued share capital The issued share capital of the Company increased by 3,140,405 shares during 2025 as a result of

the use of newly issued shares for the Company’s ShareSave and Deferred Bonus Share Scheme.

At 31 December 2025, the issued ordinary share capital totalled 1,006,252,243. Subsequently,

205,865ordinary shares have been issued in 2026 in connection with the Company’s ShareSave

tobring the total in issue to 1,006,458,108 at the date of this Directors’ report. Full details of the

issued and fully paid share capital as at 31 December 2025 and movements in share capital during

the period are presented in note D1 to the IFRS consolidated financial statements.

Authority to purchase

ownshares

At the Company’s 2025 AGM, shareholders approved the renewal of the Company’s authority to

make purchases of up to 100,316,480 of its own shares and make payment for the redemption

or purchase of its own shares in any manner permitted by the Companies Act 2006 including

without limitation, out of capital, profits, share premium or the proceeds of a new issue of

shares. The authority was not used and none of the Company’s ordinary shares were purchased

by the Company during 2025. The authority will expire at the 2026 AGM. A resolution to renew

this authority shall be proposed in the 2026 AGM Notice of Meeting.

Treasury shares The Company held no treasury shares during the year or up to the date of this Directors’ report.

Rights and obligations

attached

The rights and obligations attaching to the Company’s ordinary shares are set out in the

Company’s Articles of Association (the ‘Articles’) which are available on the Company’s website

at www.standardlifeplc.com.

Employee Benefit Trust

(‘EBT’)

Where the EBT holds shares for unvested awards, the voting rights for these shares are exercisable

by the trustees of the EBT at their absolute discretion, ensuring that it would be in the best interest

of the beneficiaries of the Trust and taking into account the recommendations of the Group.

Restrictions on

transfer ofshares

Under the Articles, the Directors may, in certain circumstances, refuse to register transfers of shares.

Certain restrictions on the transfer of shares may be imposed from time to time by applicable laws

and regulations (for example, insider trading laws), and pursuant to the UK Listing Rules of the FCA

and the Company’s own share dealing rules whereby Directors and certain employees of the Group

require individual authorisation to deal in the Company’s ordinary shares.

Substantial shareholdings Information provided to the Company pursuant to Chapter 5 of the FCA’s Disclosure Guidance

and Transparency Rules (‘DTRs’) is published on a Regulatory Information Service and on the

Company’s website. As at 31 December 2025, the following interests with voting rights in the

ordinary share capital of the Company had been notified to it under DTR 5. No changes have

occurred in respect of the holdings below between 31 December 2025 and 13 March 2026.

Name

Number of voting

rightsinshares

Percentage of shares

in issue

MS&AD Insurance Group Holdings Inc. 144,877,304 14.50%

Aberdeen Group plc 107,025,201 10.70%

BlackRock, Inc. 59,271,117 5.91%

Kingdom Holding Company 50,051,192 5.00%

176 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Shareholders continued

AGM

2026 AGM The AGM of the Company will be held at Floor 9, 20 Old Bailey, London, EC4M 7AN on 14May2026

at 11:00am. A separate Notice of Meeting convening this AGM will be distributed to shareholders

in due course and will include an explanation of the items of business to be considered at

themeeting.

Investor communications

Investor communications The Company’s Annual Report, together with the Company’s Half Year Report and other public

announcements and presentations, are designed to present a fair, balanced and understandable

view of the Company’s activities and prospects. These are available on the Company’s website

atwww.standardlifeplc.com, along with a wide range of relevant information for private and

institutional investors, including the Company’s financial calendar.

Board

Board membership The membership of the Group Board of Directors during 2025 is provided within the

Corporategovernance report on pages 88 to 91, which is incorporated by reference

intothisDirectors’ report.

During 2025, and up to the date of this Directors’ report, the following Group Board

changesoccurred:

• Sherry Coutu was appointed as a Director on 1 May 2025

• Nicholas Shott retired as a Director on 30 June 2025

• Belinda Richards retired as a Director on 24 August 2025

• Karin Cook was appointed as a Director on 25 August 2025

• David Scott retired as a Director on 31 August 2025

• Siobhan Boylan was appointed as a Director on 1 September 2025

Related party transactions Details of related party transactions which took place during the year with Directors of the Company

and consolidated entities where Directors are deemed to have significant influence, are provided in

note I4 to the IFRS consolidated financial statements.

Appointment, re-election

andremoval of Directors

The rules about the appointment and replacement of Directors are contained in the Articles.

These state that a Director may be appointed by an ordinary resolution of the shareholders

orbyaresolution of the Directors. If appointed by a resolution of the Directors, the Director

concerned holds office only until the conclusion of the next AGM following their appointment.

In accordance with the 2024 Code, all Directors must stand for election/re-election annually.

The Board of Directors will be unanimously recommending that all of the Directors included in the

Notice of Meeting for the AGM should be put forward for election/re-election at the forthcoming

AGM to be held on 14 May 2026.

The Articles give details of the circumstances in which Directors will be treated as having

automatically vacated their office and also state that the Company’s shareholders may remove

aDirector from office by passing an ordinary resolution.

Director powers

andauthorities

The powers of the Directors are determined by the Companies Act 2006, the provisions of the

Articles and by any valid directions given by shareholders by way of special resolution.

The Directors have been authorised to allot and issue securities and grant options over or otherwise

dispose of shares under the Articles.

Directors’ remuneration

andinterests

A report on Directors’ remuneration is presented within the Directors’ Remuneration report on

pages 136 to 175 including details of their interests in shares and share options or any rights to

subscribe for shares in the Company.

Directors’ indemnities The Company has entered into deeds of indemnity with each of its Directors whereby the Company

has agreed to indemnify each Director against all losses incurred by them in the exercise, execution

or discharge of their powers or duties as a Director of the Company, provided that the indemnity

shall not apply when prohibited by any applicable law.

The deeds of indemnity remain in force as at the date of signature of this Directors’ report.

Directors’ conflicts

of interest

The Group Board has established procedures for handling conflicts of interest in accordance with

the Companies Act 2006 and the Articles. See page 94 of the Corporate governance report for

moredetail.

On an ongoing basis, Directors are responsible for informing the Group Company Secretary of any

new, actual or potential conflicts that may arise.

Directors’ and Officers’

liabilityinsurance

The Company maintains Directors’ and Officers’ liability insurance cover which is renewed annually.

177Standard Life plc Annual Report and Accounts 2025

Corporate governance

Directors’ report continued

As part of its comprehensive assessment as to whether

the Company is a Going concern, the Group Board has

considered financial projections over the period to

31 March 2027, which demonstrate the ability of the

Company to withstand market shocks in a range of

severe but plausible stress scenarios.

Nicolaos Nicandrou

Group Chief Financial Officer

Governance

Going concern

The Company’s business activities, together with the factors likely to affect its future development, performance and position are

set out in the Strategic report. The Strategic report includes details of the Company’s cash flow and solvency position, alongside

details of any key events affecting the Company (and its consolidated subsidiaries) since the end of the financial year. Principal

risks and their mitigation are detailed on pages 80 to 83. In addition, the IFRS consolidated financial statements include, amongst

other things, notes on the Company’s borrowings (note E5), management of its financial risk including market, credit and liquidity

risk (note E6), its commitments and contingent liabilities (notes I5 and I6) and its capital management (note I3). The Strategic

report (on pages 16 to 19) sets out the business model and how the Company creates value for shareholders and policyholders.

As part of its comprehensive assessment as to whether the Company is a Going concern, the Board has considered financial

projections over the period to 31 March 2027, which demonstrate the ability of the Company to withstand market shocks in a

range of severe but plausible stress scenarios. Further details of these stress scenarios are included in the Viability statement on

pages 84 and 85. The projections demonstrate that appropriate levels of capital would remain in the Life Companies under both

the base and reasonably foreseeable stress scenarios, thus supporting cash generation in the Going concern period. In addition,

the Group Board noted the Company’s access to additional funding through its undrawn £1.5bn revolving credit facility.

Thestresses donot give rise to any material uncertainties over the Company’s ability to continue as a Going concern.

The Directors therefore have a reasonable expectation that the Company has adequate resources to meet its liabilities as they fall

due and continue in operational existence over the period to 31 March 2027, the period covered by the Going concern assessment.

Thus, they continue to adopt the Going concern basis of accounting in preparing the annual financial statements.

The Directors have acknowledged their responsibilities in the Statement of Directors’ responsibilities in relation to the IFRS

financial statements for the year ended 31 December 2025.

Viability statement

The Viability statement, as required by the 2024 Code, has been undertaken for a period of three years to align to the Company’s

business planning and is detailed on pages 84 to 85.

Corporate governance statement

The disclosures required by section 7.2 of the FCA’s DTRs can be found in the Corporate governance report on pages 86 to 135

which is incorporated by reference into this Directors’ report and comprises the Company’s Corporate governance statement.

The 2024 Code applied to the Company for Full Year 2025 and details on the Company’s compliance with the Code are included in

the Corporate governance report on page 92. The 2024 Code is available on the website of the FRC – www.frc.org.uk. Provision 29

of the 2024 Code became effective on 1 January 2026 and the Company will ensure that compliance with Provision 29 of 2024

Code is appropriately measured and disclosed. See page 127.

The disclosures required by the Companies Act 2006 in respect of the following matters are set out in the Strategic report,

as below:

Our strategy and future

developments

The Company’s strategy and priorities for 2026 are

highlighted in the Our strategic priorities section of the

Strategic report.

• See pages 28 to 35 of the

Strategicreport.

Our people and diversity The Company’s people strategy for colleagues is

detailed in the Group’s Sustainability Report. The

Company’s diversity and inclusion targets for colleagues

are also detailed in the Group Sustainability Report,

with highlights set out in the Strategic report.

• See pages 28, 34 and 35.

• See the Sustainability Report

ontheCompany’s website

www.standardlifeplc.com.

178 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Governance continued

Disability The Company has an Equal Opportunities and

DiversityFramework which ensures full and fair

consideration is given to applications from, and the

continuing employment and training of, disabled

people. The Company also has a Workplace Adjustment

Guidelines which set out the Company’s duty to make

reasonable adjustments to help ensure that all

colleagues can access opportunities and thrive in

employment. In addition, the Company has a Dignity at

Work Policy which sets out its commitment to creating

a work environment free of discrimination where

everyone is treated with dignity and respect. One of

ourcolleague inclusion networks, ‘Enable’ promotes

the interests of colleagues with disabilities and other

long-term health conditions.

• See the Company’s website

www.standardlifeplc.com

formoreinformation.

Our people and engagement Details of how the Company has engaged with, and

considered the interests of, employees in key decision

making can be found in the Stakeholder engagement

and Workforce engagement sections of the Corporate

governance report.

During the year, information about the Company’s

performance and market trends impacting the

Company was shared via an all-employee intranet.

Inaddition, colleagues were invited to participate in

theCompany’s ShareSave, advertised through the

all-employee intranet.

• See pages 100 to 103 of the

Corporate governance report

(forStakeholder engagement)

andpages 104 to 105 (for

Workforce engagement).

Our business relationships Details of how the Company has engaged with

stakeholders, along with details of how the Board has

considered the need to foster the Company’s business

relationships with suppliers, customers and others, in

line with section 172 of the Companies Act 2006, can

befound in the Stakeholder engagement section of

theCorporate governance report.

• See pages 100 to 103 of the

Corporate governance report.

Greenhouse gas

(‘GHG’) emissions

All disclosures concerning the Company’s GHG

emissions are contained in the Group’s Streamlined

Energy and Carbon Reporting (‘SECR’) statement and

TCFD disclosures forming part of the Strategic report.

• See pages 72 and 74 of

theStrategicreport.

Other disclosures required within this Corporate governance statement are set out below:

Task Force on Climate-related

Financial Disclosures (‘TCFD’)

In accordance with UKLR 6.6.6R, climate-related financial disclosures consistent with the TCFD

recommendations and recommended disclosures are contained in the Strategic report on page53.

Given the progress we have made with embedding the recommendations of the TCFD across

thebusiness and the increasing need for transparent reporting, we have opted to integrate our

TCFD disclosures into our Annual Report and Accounts. In response to UKLR 6.6.12G, we have

also published a standalone Net Zero Transition Plan which sets out our approach to achieving

net zero across our business by 2050.

Board diversity –

gender and ethnicity

In accordance with UKLR 6.6.6R, a statement on Board diversity targets and numerical data on

the ethnic background and gender of the Group Board of Directors and Executive Committee

are included in the Corporate governance report on page 118. Data was collated through the

standard process for preparing the Company’s annual submission to the Department for

Business and Trade in respect of the Parker Review: FTSE 350 Ethnic Diversity Data Submission

and FTSE Women Leaders Review, under applicable data protection laws.

Energy usage and carbon

emissions under the

Companies (Directors’ Report)

and Limited Liability

Partnerships (Energy and

Carbon Report) Regulations

2018 (SI 2018/1155)

The Company’s SECR statement on the Group’s UK and global energy consumption and GHG

emissions for the financial year 1 January 2025 to 31 December 2025, and the 2024 comparative

year is contained in the Strategic report on pages 72 and 74.

Branches The Company, through its subsidiaries, has established branches in Germany, Hong Kong and Ireland.

179Standard Life plc Annual Report and Accounts 2025

Corporate governance

Directors’ report continued

Governance continued

Political donations The Company is a politically neutral organisation and, as further explained below, did not make

any political donations or incur any political expenditure (within the ordinary meaning of those

words) in 2025. The Company regularly engages with regulators and policymakers (including

those associated with political parties and governments) to listen and to contribute to discussions

on a wide range of matters. Such engagement is an important part of our strategy and contributes

to initiatives enabling the UK in its goal of reaching net zero by 2050. Further information on

howwe engage with stakeholders can be found on pages 100 to 103 and our Sustainability

Report, which includes information on our own net zero ambitions can be found onour website at

www.standardlifeplc.com.

Due to the broad definition of political donations under the Companies Act 2006 (the ‘Act’) and

as a matter of good governance and transparency, we have provided information on areas of

expenditure incurred as a result of this engagement which may be regarded as falling within the

scope of the Act.

During the year ended 31 December 2025, the Company exhibited at, sponsored, and held events

at, conferences organised by political parties, spending a total of £69,040.01. This included

sponsorship of events and tickets for, the Labour Party Annual Conference, Conservative Party

Annual Conference, Liberal Democrat Party Conference, Reform Party Annual Conference,

Scottish Labour Annual Conference, Scottish National Party Annual Conference, and Scottish

Conservative Party Annual Conference. These events allow the Company to present its views on a

non-partisan basis to politicians from across the political spectrum and non-political stakeholders

such as Non-Government Organisations and other listed and non-listed companies. These

payments do not indicate support for any political party. At the 2026 AGM, the Company will be

seeking renewal from shareholders of the existing authority approved at the 2025 AGM. More

details are contained in the Notice of Meeting which will be available on the Company’s website

at www.standardlifeplc.com.

Articles of Association Changes to the Articles require prior shareholder approval by special resolution. The Articles,

areavailable for inspection on the Company’s website at www.standardlifeplc.com.

Re-appointment of the

External Auditor

KPMG was re-appointed as Auditor of the Company on 13 May 2025. KPMG has indicated its

willingness to continue in office and shareholder approval will be sought at the AGM on 14 May 2026.

There is no cap on Auditor liability in place in relation to audit work carried out on the IFRS

consolidated financial statements and the Group’s UK subsidiaries’ individual financial statements.

Details of fees paid to KPMG during 2025 for audit and non-audit work are disclosed in note C6 to

the IFRS consolidated financial statements.

Disclosure of information

toExternal Auditor

The Directors who held office at the date of approval of this Directors’ report confirm that, so far

as they are aware, there is no relevant audit information of which the Company’s External Auditor

is unaware and that each Director has taken all the steps that they ought to have taken as a

Director to make themselves aware of any relevant audit information and to establish that the

Company’s External Auditor is aware of that information.

Group Company Secretary The Group Company Secretary during the period was Kulbinder Dosanjh.

Fair, balanced and

understandable

In accordance with the 2024 Code, the Directors confirm that they have reviewed the Annual

Report and Accounts and consider that it is fair, balanced and understandable and provides the

information necessary for shareholders to assess the Company’s position, performance, business

model and strategy. Further information on the activity undertaken by the Group Board Audit

Committee can be found on page 120.

180 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Contractual/Other

Significant agreements

impacted by a change of

control of the Company

The £1.5bn revolving credit facility has provisions which would enable the lending banks to

require repayment of all amounts borrowed following a change of control.

All of the Company’s employee share and incentive plans contain specific provisions relating to a

change of control. Outstanding awards and options would normally become exercisable/available

on the date of notification, subject to the satisfaction of any performance conditions and pro rata

reduction as may be applicable under the rules of the employee share incentive plans.

Apart from the aforementioned, there are a number of agreements that take effect, alter or

terminate upon a change of control of the Company, such as commercial contracts. None is

considered to be significant in terms of their potential impact on the business of the Company.

Important post balance

sheetevents

Details of important events affecting the Company which have occurred since the end of the

financial year are contained in note I7 to the IFRS consolidated financial statements.

Disclosures under UK Listing

Rule 6.6.1R

For the purposes of UKLR 6.6.4R, the information required to be disclosed by UKLR 6.6.1R,

whereapplicable, can be found within the following sections of the Annual Report:

Requirement Location

Statement of interest capitalised Note E5 to the consolidated financial statements

Details of long-term incentive schemes Directors’ Remuneration report

Waiver of emoluments by a Director Directors’ Remuneration report

Waiver of any future emoluments by a Director Directors’ Remuneration report

181Standard Life plc Annual Report and Accounts 2025

Corporate governance

Statement of Directors’ responsibilities

Statement of Directors’

responsibilities in respect

oftheAnnual Report and

theFinancial Statements

The Directors are responsible for

preparing the Annual Report, and

the Group and Parent Company

financial statements in accordance

with applicable law and regulations.

Company law requires the Directors to

prepare Group and Parent Company

financial statements for each financial

year. Under that law they are required to

prepare the Group financial statements

in accordance with UK-adopted

international accounting standards

and applicable law and have elected to

prepare the Parent Company financial

statements on the same basis.

Under company law, the Directors must

not approve the financial statements

unless they are satisfied that they give a

true and fair view of the state of affairs

of the Group and Parent Company

and of the Group’s profit or loss for

that period. In preparing each of the

Group and Parent Company financial

statements, the Directors are required to:

• select suitable accounting policies

andthen apply themconsistently;

• make judgements and estimates that

are reasonable, relevantand reliable;

• state whether they have been

prepared in accordance

withUK-adopted international

accounting standards;

• assess the Group and Parent

Company’s ability to continue asa

going concern, disclosing, as applicable,

matters related to going concern; and

• use the going concern basis of

accounting unless they either intend

toliquidate the Group or the Parent

Company or to cease operations, or

have no realistic alternative but to

doso.

The Directors are responsible for

keeping adequate accounting records

that are sufficient to show and explain

the Parent Company’s transactions and

disclose with reasonable accuracy at

any time the financial position of the

Parent Company and enable them to

ensure that its financial statements

comply with the Companies Act 2006.

They are also responsible for such

internal control as they determine is

necessary to enable the preparation

of financial statements that are free

from material misstatement, whether

due to fraud or error, and have general

responsibility for taking such steps as are

reasonably open to them to safeguard

the assets of the Group and prevent and

detect fraud and other irregularities.

Under applicable law and regulations,

the Directors are also responsible for

preparing a Strategic report, Directors’

report, Directors’ Remuneration

report and Corporate governance

statement that complies with that

law and those regulations.

The Directors are responsible for

themaintenance and integrity of the

corporate and financial information

included on the Company’s website.

Legislation in the UK governing the

preparation and dissemination of

financial statements may differ from

legislation in other jurisdictions.

In accordance with Disclosure Guidance

and Transparency Rule (‘DTR’) 4.1.16R,

the financial statements will form part

of the annual financial report prepared

under DTR 4.1.17R and 4.1.18R. The

External Auditor’s report on these

financial statements provides no

assurance over whether the annual

financial report has been prepared in

accordance with those requirements.

Responsibility statement

oftheDirectors inrespect

oftheannual financial report

We confirm that to the best of

ourknowledge:

• the financial statements, prepared in

accordance with the applicable set of

accounting standards, give a true and

fair view of the assets, liabilities,

financial position and profit or loss

ofthe Company and the undertakings

included in the consolidation taken

asawhole; and

• the Strategic report, includes a fair

review of the development and

performance of the business and

theposition of the issuer and the

undertakings included in the

consolidation taken as a whole,

together with a description of the

principal risks and uncertainties

thatthey face.

We consider the Annual Report and

Accounts, taken as a whole, is fair,

balanced and understandable and

provides the information necessary

forshareholders to assess the Group’s

position and performance, business

model and strategy.

Andy Briggs Nicolaos Nicandrou

Group Chief Group Chief

Executive Officer Financial Officer

13 March 2026

182 Standard Life plc Annual Report and Accounts 2025

Corporate governance

Financials

184 Independent auditor’s report

200 IFRS consolidated financial statements

206 Notes to the consolidated financial statements

317 Parent company financial statements

320 Notes to the parent company financial statements

330 Additional life company asset disclosures

334 Additional capital and segmental disclosures

340 Alternative performance measures

Additional information

346 Shareholder information

348 Glossary

354 Forward-looking statements

183Standard Life plc Annual Report and Accounts 2025

Financials

Independent auditor’s report

Independent Auditor’s Report to

the members of Standard Life plc

(formerly Phoenix Group Holdings plc)

1. Our opinion is unmodified

In our opinion:

• the financial statements of Standard Life plc give a true and

fair view of the state of the Group’s and of the Parent

Company’s affairs as at 31 December 2025, and of the Group’s

loss for the year then ended;

• the Group financial statements have been properly prepared

in accordance with UK-adopted international accounting

standards;

• the Parent Company financial statements have been properly

prepared in accordance with UK-adopted international

accounting standards as applied in accordance with the

provisions of the Companies Act 2006; and

• the Group and Parent Company financial statements have

been prepared in accordance with the requirements of the

Companies Act 2006.

What our opinion covers

We have audited the Group and Parent Company financial

statements of Standard Life plc (“the Company”) for the year

ended 31 December 2025 included in the Annual Report and

Accounts, which comprise:

Group Parent Company

(Standard Life plc)

Consolidated income

statement, statement of

comprehensive income,

statement of consolidated

financial position, statement

of consolidated changes in

equity and statement of

consolidated cash flows.

Notes A1 to I7 to the Group

financial statements,

including the accounting

policies in note A, except

forthe information marked

asunaudited.

Statement of financial

position, statement of

changes in equity and

statement of cash flows.

Notes 1 to 21 to the Parent

Company financial

statements, including the

accounting policies in note 1.

Basis for opinion

We conducted our audit in accordance with International

Standards on Auditing (UK) (“ISAs (UK)”) and applicable law. Our

responsibilities are described below. We believe that the audit

evidence we have obtained is a sufficient and appropriate basis

for our opinion. Our audit opinion and matters included in this

report are consistent with those discussed and included in our

reporting to the Audit Committee (“AC”).

We have fulfilled our ethical responsibilities under, and we

remain independent of the Group in accordance with, UK ethical

requirements including the FRC Ethical Standard as applied to

listed public interest entities.

2. Overview of our audit

Factors driving our view of risks

The risk associated with the valuation of insurance contract

liabilities Key Audit Matter (“KAM”) (4.1) is predominantly driven

by the inherent subjectivity associated with the longevity,

expense and discount rate assumptions for insurance contract

liabilities as well as the ongoing change in the control

environment as the Group has continued to enhance processes

and controls following the implementation of IFRS 17. We

consider the impact of external factors such as the current

uncertain economic conditions including heightened market

interest rates affecting the credit risk of assets backing annuity

liabilities and the trends in demographic experience on

longevity assumptions.

The risk associated with the valuation of certain illiquid financial

investments KAM (4.2) is predominantly driven by the significant

estimation uncertainty associated with valuing Level 3

investments, specifically modelled debt securities and equity

release mortgages.

The financial significance of the Parent company’s investment in

subsidiaries drives the identification of its recoverability as a

KAM for the Parent company’s audit (4.3).

Key Audit Matters Vs. 2024 Item

Valuation of insurance

contract liabilities

4.1

Valuation of certain illiquid

financial investments

4.2

Parent Company’s recoverability

of investments in its subsidiaries

4.3

184 Standard Life plc Annual Report and Accounts 2025

Financials

Group

GPM

HCM

PLC

LCM

AMPT

2.6

2.9

Group

GPM

HCM

PLC

LCM

AMPT

Group Materiality

Group Performance Materiality

Highest Component Materiality

Parent Company Materiality

Lowest Component Materiality

Audit Misstatement Posting Threshold

2025 £m

2024 £m

Audit Committee interaction

During the year, the Audit Committee (“AC”) met eight times.

We are invited to attend all AC meetings and are provided with

an opportunity to meet with the AC in private sessions without

the Executive Directors being present. For each Key Audit Matter,

we have set out communications with the AC in section4,

including matters that required particular judgement for each.

The matters included in the Audit Committee Chair’s report on

page 120 are materially consistent with our observations of

those meetings.

Our independence

We have fulfilled our ethical responsibilities under, and we

remain independent of the Group in accordance with, UK ethical

requirements including the FRC Ethical Standard as applied to

listed public interest entities.

We have not performed any non-audit services during 2025

orsubsequently which are prohibited by the FRC Ethical Standard.

We were first appointed as auditor by the shareholders for the

year ended 31 December 2024. The period of total uninterrupted

engagement is for the two financial years ended 31 December 2025.

The Group engagement partner is required to rotate every five

years. As these are the second set of the Group’s financial

statements signed by Stuart Crisp, he will be required to rotate

off after the 31 December 2028 audit.

The tenure of component engagement partners is two years.

Total audit fee £25.1m

Audit related fees (including interim review) £3.3m

Other services £0.6m

Non-audit fee as a % of total audit

and audit related fee %

2.2%

Date first appointed 14 May 2024

Uninterrupted audit tenure 2 years

Next financial period which requires a tender 2034

Tenure of Group engagement partner 2 years

Tenure of component signing partners 2 years

Materiality

(Item 6 below)

The scope of our work is influenced by our view of materiality

and our assessed risk of material misstatement (‘RMM’).

We have determined overall materiality for the Group financial

statements as a whole to be £54m (2024: £65m) and for the

Parent Company financial statements as a whole to be £51m

(2024: £62m).

A key judgement in determining materiality was the most

relevant metric to select as the benchmark, by considering

factors including which metrics have the greatest bearing on

shareholder decisions.

Consistent with 2024 we determined that Group IFRS adjusted

shareholders’ equity, being shareholders’ equity adjusted for

the contractual service margin (CSM) net of tax, as disclosed on

page 342 remains the most relevant benchmark for the Group,

although we also considered materiality with reference to other

metrics, particularly adjusted operating profit, in setting the

absolute amount. Group materiality represents 1.74% (2024:

1.77%) of this benchmark.

We applied a higher materiality for certain balances relating to

the unit-linked and with-profits business in the Consolidated

Balance Sheet, Consolidated Income Statement and related

notes as follows:

• For unit linked assets and corresponding unit linked liabilities we

applied materiality of £1.88bn (2024: £1.4bn) which represents

0.89% (2024: 0.73%) of the total unit linked asset balance.

• For unsupported with profit fund assets and liabilities we

applied materiality of £510m (2024: £540m) which represents

1.00% (2024: 1.05%) of the total with profits asset balance.

Consistent with 2024, materiality for the Parent Company

financial statements was determined with reference to a

benchmark of Parent Company net assets, of which it represents

0.74% (2024: 0.92%).

185Standard Life plc Annual Report and Accounts 2025

Financials

Components where audit procedures

were performed 2025

Remaining out of scope components 2025

Components where audit procedures

were performed 2024

Remaining out of scope components 2024

97%

85%

88%

12%

15%

Independent auditor’s report continued

Group scope

(Item 7 below)

We have performed risk assessment procedures to determine

which of the Group’s components are likely to include risks of

material misstatement to the Group financial statements, what

audit procedures to perform at these components and the

extent of involvement required from our component auditors.

In total, we identified seven components (2024: seven

components), having considered our evaluation of the Group’s

legal and operational structure, the existence of common

information systems, the existence of common risk profiles across

divisions and our ability to perform audit procedures centrally.

Of these, we identified two (2024: two) quantitatively significant

components, and five (2024: five) other components included in

the scope of our work for other reasons.

We consider the scope of our audit, as communicated to

theAudit Committee, to be an appropriate basis for our

auditopinion.

The impact of climate change on our audit

In planning our audit, we have considered the potential impact

of climate change on the Group’s business and its financial

statements.

Climate change, and the associated initiatives and

commitments, impact the Group in a variety of ways including

the potential financial risks which could arise from the

associated physical and transition risks and the narrative

anddisclosure of the impact of climate change risk that is

incorporated into the Annual report and accounts. The Group’s

exposure to climate change is primarily through climate related

transition risks which potentially impact the carrying amount of

investments and potential reputational risk associated with the

Group’s delivery of its climate related commitments.

As a part of our audit we have made enquiries of management

to understand the extent of the potential impact of climate

change risk on the Group’s financial statements, including how

climate is considered as part of the investment making and

monitoring processes, and the Group’s preparedness for this.

We have performed a risk assessment of how the impact of

climate change may affect the financial statements and

ouraudit.

Coverage of group financial statements

Group revenue

Our audit procedures covered the following

percentages of Group revenue:

Group Total assets

We performed audit procedures in relation to

components that accounted for the following

percentages of Group Total Assets:

186 Standard Life plc Annual Report and Accounts 2025

Financials

3. Going concern, viability and principal

risksanduncertainties

The directors have prepared the financial statements on the

going concern basis as they do not intend to liquidate the Group

or the Parent Company or to cease their operations, and as they

have concluded that the Group’s and the Parent Company’s

financial position means that this is realistic. They have also

concluded that there are no material uncertainties that could

have cast significant doubt over their ability to continue as a

going concern for at least a year from the date of approval of

the financial statements (“the going concern period”).

Going concern

We used our knowledge of the Group, its industry, and the

general economic environment to identify the inherent risks to

its business model and analysed how those risks might affect

the Group’s financial resources or ability to continue operations

over the going concern period. The risks that we considered

most likely to adversely affect the Group’s available financial

resources over this period were:

• Adverse impacts arising from fluctuations or negative trends

in the economic environment including, but not limited to,

interest rates and inflation, wider credit spreads, defaults and

property price movements which affect regulatory capital

solvency coverage ratios, liquidity ratios, the valuations of the

Group’s illiquid financial investments and valuation of

insurance contract liabilities; and

• Severely adverse policyholder lapse or claims experience.

We also considered less predictable but realistic second order

impacts, such as political or policy changes that could affect

demand in the Group’s markets.

We considered whether these risks could plausibly affect the

liquidity and solvency in the going concern period by comparing

severe, but plausible downside scenarios that could arise from

these risks individually and collectively against the level of

financial resources indicated by the Group’s financial forecasts.

Our procedures also included

• Critically assessing assumptions used in management’s

three-year Annual Operating Plan (‘AOP’), which forms the

basis for management’s going concern projections and

determining whether the models are appropriate to enable

management to make an assessment on the going concern

ofthe Group.

• Critically assessing assumptions in base case and downside

scenarios relevant to liquidity and solvency.

• Assessing whether downside scenarios applied mutually

consistent and severe assumptions in aggregate, using our

assessment of the possible range of each key assumption and

our knowledge of inter-dependencies.

• Comparing past budgets to actual results to assess the

directors’ track record of budgeting accurately.

• Evaluating the achievability of the contingent actions the

directors consider they would take to improve the position

should the risks materialise.

• Assessing the entity’s debt covenants and ability to meet

maturities arising during the going concern period

• Critically assessing the projections for distributable reserves

in the subsidiaries which drive the availability of dividend

income to be received by the parent company

• We considered whether the going concern disclosure in note

A1 to the financial statements gives a full and accurate

description of the directors’ assessment of going concern,

including the identified risks and dependencies.

Accordingly, based on those procedures, we found the directors’

use of the going concern basis of accounting without any

material uncertainty for the Group and Parent Company to

beacceptable.

However, as we cannot predict all future events or conditions

and as subsequent events may result in outcomes that are

inconsistent with judgements that were reasonable at the time

they were made, the above conclusions are not a guarantee that

the Group or the Parent Company will continue in operation.

Our conclusions

• We consider that the directors’ use of the going concern basis

of accounting in the preparation of the financial statements is

appropriate;

• We have not identified, and concur with the directors’

assessment that there is not, a material uncertainty related to

events or conditions that, individually or collectively, may cast

significant doubt on the Group’s or Parent Company’s ability

to continue as a going concern for the going concern period;

• We have nothing material to add or draw attention to in

relation to the directors’ statement on page 206 to the

financial statements on the use of the going concern basis of

accounting with no material uncertainties that may cast

significant doubt over the Group and Parent Company’s use of

that basis for the going concern period, and we found the

going concern disclosure in note 1 to be acceptable; and

• The related statement under the Listing Rules set out on page

182 is materially consistent with the financial statements and

our audit knowledge.

187Standard Life plc Annual Report and Accounts 2025

Financials

Independent auditor’s report continued

Disclosures of emerging and principal risks

and longer-term viability

Our responsibility

We are required to perform procedures to identify whether

there is a material inconsistency between the directors’

disclosures in respect of emerging and principal risks and the

viability statement, and the financial statements and our audit

knowledge.

Based on those procedures, we have nothing material to add or

draw attention to in relation to:

• the directors’ confirmation within the viability statement on

pages 84–85 that they have carried out a robust assessment

of the emerging and principal risks facing the Group, including

those that would threaten its business model, future

performance, solvency and liquidity;

• the Principal risks and uncertainties disclosures describing

these risks and how emerging risks are identified and

explaining how they are being managed and mitigated; and

• the directors’ explanation in the viability statement of how

they have assessed the prospects of the Group, over what

period they have done so and why they considered that period

to be appropriate, and their statement as to whether they

have a reasonable expectation that the Group will be able to

continue in operation and meet its liabilities as they fall due

over the period of their assessment, including any related

disclosures drawing attention to any necessary qualifications

or assumptions.

We are also required to review the viability statement set out on

pages 84–85 under the Listing Rules.

Our work is limited to assessing these matters in the context of

only the knowledge acquired during our financial statements

audit. As we cannot predict all future events or conditions and

as subsequent events may result in outcomes that are

inconsistent with judgements that were reasonable at the time

they were made, the absence of anything to report on these

statements is not a guarantee as to the Group’s and Parent

Company’s longer-term viability.

Our reporting

We have nothing material to add or draw attention to in relation

to these disclosures.

We have concluded that these disclosures are materially consistent

with the financial statements and our audit knowledge.

4. Key audit matters

What we mean

Key audit matters are those matters that, in our professional

judgement, were of most significance in the audit of the financial

statements and include the most significant assessed risks of

material misstatement (whether or not due to fraud) identified

by us, including those which had the greatest effect on:

• the overall audit strategy;

• the allocation of resources in the audit; and

• directing the efforts of the engagement team.

We include below the Key Audit Matters in decreasing order of

audit significance together with our key audit procedures to

address those matters and our results from those procedures.

These matters were addressed, and our results are based on

procedures undertaken, for the purpose of our audit of the

financial statements as a whole. We do not provide a separate

opinion on these matters.

188 Standard Life plc Annual Report and Accounts 2025

Financials

4.1 Valuation of insurance contract liabilities (group)

Financial Statement Elements

£113,423m

Estimates of present value

of future cash flows

2024: £109,354m

Our assessment of risk vs 2024

We have not identified any significant

changes to our assessment of the level

ofrisk relating to valuation insurance

contract liability as compared to 2024.

Our results

Acceptable

2024: Acceptable

£5,741m

Contractual Service Margin (CSM)

2024: £5,231m

Acceptable

2024: Acceptable

Description of the Key Audit Matter Our response to the risk

Subjective valuation

The valuation of insurance contract liabilities is an inherently subjective area,

requiring management judgement in the setting of key assumptions. The

discount rate, longevity and expense assumptions involve the greatest level of

subjectivity. A small change in these assumptions can have a significant impact

on the estimates of the present value of future cash flows.

Discount rate methodology including allowance for credit defaults and

targeted asset mix

The Group’s current discount rates for its annuity portfolios are derived by

applying an illiquidity premium to the risk-free rate. This illiquidity premium is

determined based on the yield of a reference asset portfolio which has been

adjusted for risks that are not present in the related insurance liabilities, in

particular the risk of credit default.

The credit risk deduction methodology is judgmental and small changes in

thiscanhave a significant impact on the present value of future cash flows.

Theassumptions surrounding this deduction require significant judgement and

there isa risk that actual default experience and anticipated trends are not

appropriately reflected. This is particularly significant during the current uncertain

economic conditions which impact the forward-looking view of credit risk.

In addition, the reference portfolio is derived from a targeted asset mix,

theselection of which is judgemental requiring consideration of current and

future asset portfolios.

In addition, the calculation of the illiquidity premium relies on significant

volumes of data and processes that include complex and manual elements.

There is a risk of error in the calculations as a result.

Expense assumptions

Judgement is required in setting the maintenance expense assumption which

isbased on management’s long-term view of the expected future costs of

administering the underlying policies. This is informed by expected inflation in

costs, the allocation between cost centres and the determination of costs that

are directly attributable to the maintenance of insurance contracts, rather than

other activities such as the acquisition of new business.

Additional judgement is required to be applied where the future costs of

administering policies include the expected benefits from cost saving

initiatives and ongoing transition, transformation and policy administration

transfer programmes (“transformation programmes”).

In the period until those programmes are complete, judgement is required as

to the provisions required for the short term additional running costs and

project costs required to complete the programmes.

Longevity assumptions

Longevity assumptions have two main components: longevity base

assumptions and the rate of longevity improvements. The changing trends in

longevity and emerging medical trends mean there is a high level of uncertainty

in the assumptions. There is also a high degree of expert judgement in the

calibration of the Cause-of-Death model which management uses to derive the

mortality improvement assumptions.

Actuarial model overlays

There are numerous and significant manual overlay adjustments that are applied

to the modelled actuarial valuations. This is particularly the case for the IFRS

specific manuals and overlay adjustments made in the downstream CSM

reporting processes. Many of these overlays are material in amount, complex

and calculated through manual processes in an environment.

Estimation uncertainty

The effect of these matters is that, as part of our risk assessment, we

determined that the valuation of insurance contract liabilities has a high

degree of estimation uncertainty, with a potential range of reasonable

outcomes greater than our materiality for the financial statements as a whole,

and possibly many times that amount. The financial statements disclose the

sensitivities (Note F9.1) estimated by the Group.

We performed the tests below rather than seeking to rely on any of the

Group’s controls because the nature of the balance is such that we would

expect to obtain audit evidence primarily through the detailed procedures

described. We used our own actuarial specialists in order to assist us in

performing procedures over methodology choice and assumptions in this area.

Our procedures to address the risk included:

Control design and implementation: testing of the design and

implementation of key controls over the valuation process, including the

setting of assumptions, for insurance contract liabilities.

Methodology choice: Assessing the appropriateness of the methodology

for selecting assumptions by applying our understanding of developments

in the business and expectations derived from market experience,

including consideration of the effects of credit risk and how medical trends

impact on policyholder longevity.

Accounting analysis: Assessing whether management’s proposed

methodology for determining the discount rate, and in particular the

credit deductions and reference portfolios which underpin it, is consistent

with the requirements of IFRS 17.

Test of detail: Independently recalculating the illiquidity premium using

management’s inputs.

Historical comparisons: Evaluating the longevity base assumptions used

in the valuation of the liabilities by comparing to historic mortality

experience.

Benchmarking assumptions: Assessing longevity improvement

assumptions against industry data on expected future mortality rate

improvements and industry historical mortality improvement rates and

assessing the appropriateness of the credit risk assumptions by comparing

to industry practice and our expectations derived from market experience.

Test of detail: Evaluating whether the expense assumptions reflect the

expected future costs of administering the underlying policies by

considering the historical accuracy of management’s forecast expenses

and analysing the allocations of the forecast costs to directly attributable

maintenance expenses with reference to the historical allocations, future

plans and the inclusion of benefits arising from cost saving initiatives and

ongoing transformation programmes.

Test of detail: Evaluating whether the short term provisions for expenses

appropriately reflect the additional running costs and project costs

associated with ongoing transformation programmes.

Test of detail: Assessing the appropriateness of the methodologies used

in calculating the actuarial model IFRS specific overlay adjustments. For

certain overlays, selected based on risk criteria, testing the accuracy of the

input data and either reperforming the calculation of the overlay

adjustment or developing our own expectation of the value of the overlay.

Considering, through our testing of other parts of the IFRS17 process,

whether these indicate that additional overlay adjustments are required.

Assessing transparency: Considering whether the disclosures in relation

to the assumptions used in the calculation of the valuation of insurance

contract liabilities are compliant with the relevant accounting

requirements and appropriately represent the sensitivities of these

assumptions to alternative scenarios and inputs.

189Standard Life plc Annual Report and Accounts 2025

Financials

Independent auditor’s report continued

Communications with the Standard Life plc

AuditCommittee

Our discussions with and reporting to the Audit

Committeeincluded:

• Our approach to the audit of insurance contract liabilities

including the extent of our control reliance.

• Our conclusions on the appropriateness of the Group’s

methodology for setting assumptions.

• Our conclusions on the appropriateness of the discount

ratemethodology including allowance for credit defaults,

expense assumptions, and longevity assumptions, including

challenge of the assumptions using our sector experience

andmarket knowledge.

• Our conclusions on the appropriateness of the manuals

andoverlay adjustments applied to the modelled

actuarialvaluations.

• The adequacy and appropriateness of the disclosures,

including the sensitivity of insurance contract liabilities to

keyassumptions.

Areas of particular auditor judgement

We identified the following as the areas of particular

auditorjudgement:

• The appropriateness of the methodology used in determining

the discount rate including the credit default deduction.

• The cost savings assumed in expense assumptions and the

provisions required for the transformation programmes.

• The approach and methods applied to determine the

longevity assumptions.

Our results

We found the resulting estimate of the valuation of insurance

contract liabilities to be acceptable (2024: acceptable).

Further information in the Annual Report and Accounts: See the Audit

Committee Report on page 125 for detailson how the Audit Committee

considered valuationof insurance contract liabilities as an area ofsignificant

attention, pages 251 to 257 for the accounting policy on valuation of

insurance contract liabilities, and note F for the financialdisclosures.

4.2 Valuation of certain illiquid financial investments (group)

Financial Statement Elements

£16,263m

Debt securities

2024: £15,146m

Our assessment of risk vs 2024

We have not identified any significant

changes to our assessment of the level of

risk relating to valuation of hard to value

(Level 3) investments compared to 2024.

Our results

Acceptable

2024: Acceptable

Description of the Key Audit Matter Our response to the risk

Subjective valuation

6.34% of the investment portfolio as at 31 December 2025 was classified as Level

3 assets. Of this we consider the valuation of modelled debt securities and equity

release mortgages backing insurance contract liabilities in the shareholder

(rather than with profits or unit-linked) fund to involve the greatest level of

subjectivity. The subjectivity of the asset valuations remains heightened during

the current uncertain economic conditions which impact the forward-looking

view of credit risk.

For these positions a reliable third-party price from a recent market transaction

is not readily available and therefore the application of expert judgement from

management in the valuations adopted is required.

The key assumptions underlying the valuations are:

• Modelled debt securities: credit ratings that are not provided by external

credit rating agencies

• Equity release mortgages: illiquidity premium.

Estimation uncertainty:

The effect of these matters is that, as part of our risk assessment, we determined

that the valuation of certain illiquid financial investments has a high degree of

estimation uncertainty, with a potential range of reasonable outcomes greater

than our materiality for the financial statements as a whole, and possibly many

times that amount.

We used our own actuarial, valuation and credit specialists in order to

assist us in performing procedures over methodology and assumptions in

this area. Our procedures to address the risk included:

Control design and implementation: Testing of the design and

implementation of key controls over the valuation process for modelled

debt securities and equity release mortgages.

Control operation: Testing of the operating effectiveness of key controls

over the credit rating process for modelled debt securities.

Our valuation expertise:

• Using our own valuation specialists to assess the suitability of the

valuation and credit rating methodologies used by the Group, and to

independently recalculate a sample of the credit ratings derived from

credit rating models; and

• Using our own actuarial specialists to evaluate the appropriateness of

the assumptions used in the valuation of equity release mortgages with

reference to data on the Group’s recent mortgage originations.

Methodology choice: Assessing the appropriateness of the credit rating

methodologies for modelled debt securities, and the illiquidity premium

spread methodology for equity release mortgages, with reference to

relevant accounting standards and the Group’s own valuation guidelines as

well as industry practice.

Assessing transparency: Assessing whether the disclosures in relation to

the valuation of illiquid financial investments are compliant with the

relevant financial reporting requirements and that the sensitivities of the

valuation to alternative assumptions are appropriately presented.

190 Standard Life plc Annual Report and Accounts 2025

Financials

Communications with the Standard Life plc

AuditCommittee

Our discussions with and reporting to the Audit Committee

included:

• Our approach to the valuation of modelled debt securities

and equity release mortgages, including details of our

planned substantive procedures and the extent of our control

reliance.

• Our conclusions on the appropriateness of the methodology

adopted by the Group to the valuation of modelled debt

securities and equity release mortgages.

• The adequacy of disclosures, particularly as they relate to the

sensitivity of Level 3 investments to key assumptions.

Areas of particular auditor judgement

We identified the following as the areas of particular auditor

judgement:

• Determination of the valuation methodology where external

pricing sources are not readily available or unreliable.

• The appropriateness of the internally-generated credit ratings

and valuation of these modelled debt securities.

• The appropriateness of the illiquidity premium used in the

valuation of equity release mortgages.

Our results

We found the resulting estimate of the valuation of certain illiquid

financial investments to be acceptable (2024: acceptable).

Further information in the Annual Report and Accounts: See the Audit

Committee Report on page 125 for details on how the Audit Committee

considered the valuation of certain illiquid financial investments as an area

ofsignificant attention, pages 226 to 228 for the accounting policy on valuation

of certain illiquid financial investments, and note E for the financial disclosures.

4.3 Recoverability of investments in subsidiaries (parent company)

Financial Statement Elements

£9,199m

Investment in subsidiaries

2024: £9,247m

Our assessment of risk vs 2024

We have not identified any significant

changes to our assessment of the level

ofrisk relating to Recoverability of the

parent company’s investment in

subsidiaries compared to 2024

Our results

Acceptable

2024: Acceptable

Description of the Key Audit Matter Our response to the risk

Forecast-based assessment

The carrying amount of the Parent Company’s investments in subsidiaries is at

risk of irrecoverability given the net assets of the Parent Company continue to

exceed the consolidated net assets. Management performs an impairment test

which for certain of the subsidiaries utilises dividend cash flows based on the

emergence of surplus for in-force business on a Solvency II basis, together with

new business cash flows on a Solvency II basis, to determine a value in use. The

estimated recoverable amount of these balances is subjective due to the

inherent uncertainty in forecasting and discounting cash flows used in the

valuations of these subsidiaries.

The effect of these matters is that, as part of our risk assessment, we

determined that the recoverable amount of the cost of investment in

subsidiaries has a high degree of estimation uncertainty, with a potential range

of reasonable outcomes greater than our materiality for the financial

statements as a whole, and possibly many times that amount.

We performed the tests below rather than seeking to rely on any of the

Parent Company’s controls because the nature of the balance is such that

we would expect to obtain audit evidence primarily through the detailed

procedures described.

Our procedures included:

• Control design and implementation: Evaluate the design and

implementation of the controls over the impairment in subsidiaries

assessment process.

• Test of detail: Comparing the carrying amount of each subsidiary with

the relevant subsidiaries’ financial statements/draft balance sheet to

identify whether their net assets, being an approximation of their

minimum recoverable amount, were in excess of their carrying amount.

• For investments where the carrying amount exceeded the net asset

value, our procedures included:

• Benchmarking assumptions: Comparing the Group’s assumptions to

externally derived data in relation to key inputs such as Weighted

Average Cost of Capital (“WACC”) and terminal growth rates, with the

support of our valuation specialists;

• Comparing valuations: Assessing whether any adjustments were required

to the value in use estimates to reflect the subsidiaries’ equity value;

• Our sector experience: Evaluating the assumptions used, in particular

those relating to the dividend cash flows based on our knowledge of the

Group and the markets that the subsidiaries operate in, including

considering potential constraints on dividends being paid by the

subsidiaries arising from capital, liquidity or distributable reserve

requirements;

• Historical comparisons: Assessing the reasonableness of the forecast

dividend cash flows by considering the historical accuracy of the

previous forecasts;

• Sensitivity analysis: Assessing the sensitivity of the headroom on the

Parent Company’s investment in subsidiaries. This was performed by

considering reasonable possible changes in key assumptions underlying

the value in use, including the discount rate, terminal growth rate and

forecast dividend cash flows;

• Assessing transparency: Assessing whether the Parent Company’s

disclosures about the sensitivity of the outcome of the impairment

assessment to changes in key assumptions reflected the risks inherent

in the recoverable amount of the investment in subsidiaries.

191Standard Life plc Annual Report and Accounts 2025

Financials

Independent auditor’s report continued

Communications with the Standard Life plc

AuditCommittee

Our discussions with and reporting to the Audit Committee

included:

• Our approach to the audit of the recoverability of the

Parentcompany’s investment in subsidiaries.

• Our conclusions on the appropriateness of the valuation

ofthe Parent company’s investment in subsidiaries.

Areas of particular auditor judgement

We identified the following as the areas of particular auditor

judgement:

• The appropriateness of the methodology used in calculating

the recoverable amount.

• The appropriateness of the internally-generated dividend

cash flow forecasts.

• The appropriateness of the methodology used in determining

the discount rate applied.

Our results

We found the Parent Company’s investment in subsidiaries and

the related impairment charges in the period to be acceptable

(2024: acceptable).

Further information in the Annual Report and Accounts: See theAudit

Committee Report on page 125 for details on how theAudit Committee

considered the Parent Company’s recoverability of investments in subsidiaries

as an area of significant attention, page 320 for the accounting policy on the

Parent Company’s recoverability of investments in subsidiaries, and note 4

for the financial disclosures.

5. Our ability to detect irregularities, and our response

Fraud – identifying and responding to risks of material misstatement due to fraud

Fraud risk assessment Identifying and responding to risks of material misstatement due to fraud

To identify risks of material misstatement due to fraud (“fraud risks”) we assessed events or conditions

that could indicate an incentive or pressure to commit fraud or provide an opportunity to commit fraud.

Our risk assessment procedures included:

• Enquiring of directors, the audit committee, internal audit and inspection of policy documentation as

to the Group’s high-level policies and procedures to prevent and detect fraud, including the internal

audit function, and the Group’s channel for “whistleblowing”, as well as whether they have knowledge

of any actual, suspected or alleged fraud.

• Reading Board, audit committee, risk and remuneration committee minutes.

• Considering remuneration incentive schemes and performance targets for management.

• Using analytical procedures to identify any unusual or unexpected relationships. Using our own

professionals with forensic knowledge to assist us in identifying fraud risks based on discussion of

thecircumstances of the Group;

• Inspecting correspondence with regulators to identify instances or suspected instances of fraud;

• Reviewing the audit misstatements from the prior period to identify fraud risk factors; and

• Reading broker reports and other public information to identify third-party expectations and concerns.

Risk communications We communicated identified fraud risks throughout the audit team and remained alert to any

indications of fraud throughout the audit. This included communication from the Group auditor to

component auditors of relevant fraud risks identified at the Group level and requests that component

audit teams report to the Group audit team any instances of fraud that could give rise to a material

misstatement at the Group level.

Fraud risks As required by auditing standards, and taking into account possible pressures to meet profit targets, we

perform procedures to address the risk of management override of controls, in particular the risk that

Group and component management may be in a position to make inappropriate accounting entries and

exercise bias in accounting estimates and judgements.

We do not believe there is a fraud risk related to Group revenue because there is limited management

judgement involved in the recognition of and measurement of material revenue streams.

We identified a fraud risk related to insurance contract liabilities, illiquid financial investments and the

Parent Company’s investment in subsidiaries in response to possible pressures to meet financial targets.

Link to KAMs Further detail in respect of insurance contract liabilities, illiquid financial investments and the Parent

Company’s investment in subsidiaries is set out in the key audit matter disclosures in section 4 of this report.

Procedures to address

fraud risks

We also performed procedures including:

• Identifying journal entries and other adjustments to test at the Group level and for selected

components based on risk criteria and comparing the identified entries to supporting documentation.

These included but were not limited to those posted by senior finance management, those posted to

seldom used accounts and are linked to an estimate associated with a significant risk, those posted to

unusual accounts, journals impacting cash balances that were identified as unusual or unexpected in

our risk assessment procedures and journal entries and other adjustments containing unusual

descriptions.

• Evaluating the business purpose of significant unusual transactions.

• Assessing whether the judgements made in making accounting estimates are indicative of a potential bias.

192 Standard Life plc Annual Report and Accounts 2025

Financials

Laws and regulations – identifying and responding to risks of material misstatement relating to compliance with laws and

regulations

Laws and regulations

risk assessment

We identified areas of laws and regulations that could reasonably be expected to have a material effect

on the financial statements from our general commercial and sector experience, through discussion

with the directors and other management (as required by auditing standards), and from inspection of

the Group’s regulatory and legal correspondence and discussed with the directors and other

management the policies and procedures regarding compliance with laws and regulations.

As the Group is regulated, our assessment of risks involved gaining an understanding of the control

environment including the entity’s procedures for complying with regulatory requirements.

Risk communications We communicated identified laws and regulations throughout our team and remained alert to any

indications of non-compliance throughout the audit. This included communication from the Group

auditor to component auditors of relevant laws and regulations identified at the Group level, and a

request that component auditors report to the Group audit team any instances of non-compliance with

laws and regulations that could give rise to a material misstatement at the Group level.

Direct laws context and

link to audit

The potential effect of these laws and regulations on the financial statements varies considerably.

Firstly, the Group is subject to laws and regulations that directly affect the financial statements

including financial reporting legislation (including related companies’ legislation), distributable profits

legislation, taxation legislation and pension legislation and we assessed the extent of compliance with

these laws and regulations as part of our procedures on the related financial statement items.

Most significant indirect

law/ regulation areas

Secondly, the Group is subject to many other laws and regulations where the consequences of non-

compliance could have a material effect on amounts or disclosures in the financial statements, for

instance through the imposition of fines or litigation or the loss of the Group’s license to operate.

We identified the following areas as those most likely to have such effect:

• Specific aspects of regulatory capital and liquidity;

• Financial crime and customer conduct regulations;

• Consumer duty

• Market abuse regulations;

• Data protection laws;

• Employment legislation;

• Environmental protection legislation;

• Health and safety legislation; and

• Certain aspects of company legislation, recognising the financial and regulated nature of the group’s

activities and certain regulated subsidiaries.

Auditing standards limit the required audit procedures to identify non-compliance with these laws and

regulations to enquiry of the directors and other management and inspection of regulatory and legal

correspondence, if any. Therefore if a breach of operational regulations is not disclosed to us or evident

from relevant correspondence, an audit will not detect that breach.

Actual or suspected

breaches discussed

withAC

We discussed with the audit committee matters related to actual or suspected breaches of laws or

regulations, for which disclosure is not necessary, and considered any implications for our audit.

Context

Context of the ability of

the audit to detect

fraud or breaches of law

or regulation

Owing to the inherent limitations of an audit, there is an unavoidable risk that we may not have detected

some material misstatements in the financial statements, even though we have properly planned and

performed our audit in accordance with auditing standards. For example, the further removed

non-compliance with laws and regulations is from the events and transactions reflected in the financial

statements, the less likely the inherently limited procedures required by auditing standards would identify

it. In addition, as with any audit, there remained a higher risk of non-detection of fraud, as fraud may

involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal controls.

Our audit procedures are designed to detect material misstatement. We are not responsible for

preventing non-compliance or fraud and cannot be expected to detect non-compliance with all laws and

regulations.

193Standard Life plc Annual Report and Accounts 2025

Financials

Independent auditor’s report continued

6. Our determination of materiality

The scope of our audit was influenced by our application of materiality. We set quantitative thresholds and overlay qualitative

considerations to help us determine the scope of our audit and the nature, timing and extent of our procedures, and in evaluating

the effect of misstatements, both individually and in the aggregate, on the financial statements as a whole.

£54m Materiality for the group financial statements as a whole

2024: £65m

What we mean

A quantitative reference for the

purpose of planning and performing

our audit.

Basis for determining materiality and judgements applied

We determined materiality for the Group financial statements as a whole to be £54m

(2024: £65m), with reference to a benchmark of Group IFRS adjusted shareholders’

equity (shareholders’ equity adjusted for the contractual service margin (CSM) net of

tax). Adding back the CSM net of tax to shareholders’ equity removes the deferral of

dayone gains on annuity contracts in the CSM, and so measures the value of the policies

written to date. This metric is more closely aligned to regulatory solvency, which also

recognises the day one gains on annuity contracts. It is therefore relevant to users

because surplus funds above capital requirements are necessary to fund investment

andpay returns to debt and equity holders.

When using a benchmark of IFRS adjusted shareholders’ equity to determine overall

materiality, our approach for listed entities considers a guideline range 0.5%-2% of the

measure. Our Group materiality is 1.74% (2024: 1.77%) of the benchmark and in setting

the absolute amount of materiality we also considered the materiality relative to other

relevant metrics, particularly adjusted operating profit.

We applied a higher materiality for certain balances relating to the unit-linked and

with-profits business in the Consolidated Balance Sheet, Consolidated Income

Statement and related notes, in accordance with FRC Practice Note 20. This is because

changes in these balances are offset by changes in related balances such that the impact

on the profit attributable to the shareholder is eliminated (in the case of unit-linked

asset) or significantly reduced (in the case of with profit funds). The higher materiality

amounts were as follows:

• For unit linked assets and corresponding unit linked liabilities we applied materiality

of£1.88bn (2024: £1.4bn) which represents 0.89% (2024: 0.73%) of the total unit linked

asset balance.

• For unsupported with profit fund assets and liabilities we applied materiality of

£510m(2024: £540m) which represents 1.00% (2024:1.05%) of the total with profits

asset balance.

For the purposes of our Group audit the materiality of the parent company is limited,

such that it is lower than the materiality for the Group financial statements. Materiality

for the Parent Company financial statements was set at £51m (2024: £62m). This is lower

than the materiality we would otherwise have determined with reference to Parent

Company net assets, of which it represents 0.74% (2024: 0.9%).

£35m Performance materiality

2024: £42m

What we mean

Our procedures on individual account

balances and disclosures were

performed to a lower threshold,

performance materiality, so as to

reduce to an acceptable level the

riskthat individually immaterial

misstatements in individual account

balances add up to a material amount

across the financial statements as

awhole.

Basis for determining performance materiality and judgements applied

We have considered performance materiality at a level of 65% of materiality for the

Group financial statements as a whole to be appropriate.

We applied this percentage in our determination of performance materiality based

onour expectation of an increased level of identified misstatements and driven by the

levelof change within the business and the potential for that to impact the control

environment during the period.

The Parent Company performance materiality was set at £38.4m (2024: £46.3m), which

equates to 75% of materiality for the Parent Company financial statements as a whole.

194 Standard Life plc Annual Report and Accounts 2025

Financials

£2.6m Audit misstatement posting threshold

2024: £2.9m

What we mean

This is the amount below which

identified misstatements are

considered to be clearly trivial from a

quantitative point of view. We may

become aware of misstatements below

this threshold which could alter the

nature, timing and scope of our audit

procedures, for example if we identify

smaller misstatements which are

indicators of fraud.

This is also the amount above which

allmisstatements identified are

communicated to the Group’s

AuditCommittee.

Basis for determining the audit misstatement posting threshold and

judgementsapplied

We set our audit misstatement posting threshold at 4.8% (2024: 4.5%) of our materiality

for the Group financial statements. We also report to the Audit Committee any other

identified misstatements that warrant reporting on qualitative grounds.

The overall materiality for the Group financial statements of £54m (2024: £65m) compares as follows

to the main financial statement caption amounts:

Total Group Revenue 2025

£6,584m

Financial statement caption

2024: £6,166m

0.82%

Group Materiality as % of caption

2024: 1.05%

Total Group Assets 2025

£332,241m

Financial statement caption

2024: £307,857m

0.02%

Group Materiality as % of caption

2024: 0.02%

195Standard Life plc Annual Report and Accounts 2025

Financials

Independent auditor’s report continued

7. The scope of our audit

Group scope

What we mean

How the Group auditor

determined the procedures to

be performed across the Group.

We performed risk assessment procedures to determine which of the Group’s components

are likely to include risks of material misstatement to the Group financial statements and

which procedures to perform at these components to address those risks.

In total, we identified seven components (2024: seven components), having considered

our evaluation of the Group’s operational and legal structure, the existence of common

information systems and the existence of common risk profiles across components and

our ability to perform audit procedures centrally.

Of those, we identified quantitatively significant components which contained the

largest percentages of either total revenue or total assets of the Group, for which we

performed audit procedures.

Additionally, having considered qualitative and quantitative factors, we selected

additional components with accounts and/or disclosures contributing to the specific

risks of material misstatement of the Group financial statements.

The below summarises where we performed audit procedures:

Component type

Number of components where we

performed audit procedures Range of materiality applied

2025 2024 2025 2024

Quantitatively

significant components 2 2

£32.4m

– £50.2m

£36m

– £58m

Other components where

we performed procedures 5 5

£8.1m

– £45.9m

£10m

– £55m

Total 7 7

We involved component auditors in performing the audit work on six components (2024:

six components). We set the component materialities having regard to the mix of size

and risk profile of the Group across the components. We also performed the audit of the

Parent Company.

Our audit procedures covered 90% (2024: 88%) of Group revenue.

We performed audit procedures in relation to components that accounted for 98%

(2024: 97%) of total assets.

For the remaining components for which we performed no audit procedures, no component

represented more than 4% (2024: 6%) of Group total revenue or Group total assets.

Weperformed analysis at an aggregated Group level to re-examine our assessment that

there is not a reasonable possibility of a material misstatement in these components.

The Group also operates a shared service centre that is relevant to our audit in the

UK.This service centre performs accounting and reporting activities alongside related

controls and processes a substantial portion of the Group’s expense transactions. We

identified this service centre as a component and performed audit procedures over it.

We identified a number of IT systems to be relevant to our audit, including those

supporting financial reporting, policy administration and investment management.

Weused our IT auditors, including in the components, to assist us in assessing the

designand operating effectiveness of the general IT controls of the relevant systems.

Following our testing, including additional testing performed to determine if

deficiencies noted had resulted in exceptions, we relied on IT general controls over

these systems in determining the work to be performed in the audit.

We tested operating effectiveness and placed reliance on manual and automated controls

in some areas of our audit, including over outsourced service providers, the valuation of

level 3 debt securities and certain balance sheet accounts. As the Group has continued

to enhance its processes and manual controls associated with the implementation of

IFRS 17 Insurance contracts reporting requirements, we did not plan to place reliance

onmanual controls in this area.

196 Standard Life plc Annual Report and Accounts 2025

Financials

Group auditor oversight

What we mean

The extent of the Group auditor’s

involvement in work performed by

component auditors.

In working with component auditors, we:

• Included the component auditors’ engagement partners and managers in the Group

planning discussions to facilitate inputs from component auditors in the identification

of matters relevant to the Group audit.

• Issued Group audit instructions to component auditors on the scope and nature of

their work.

• Held meetings with component auditors as the audit progressed to understand and

evaluate their work, and organised weekly video conferences and in person meetings

with the component auditors. At these meetings and video conferences, the results of

the planning procedures and further audit procedures communicated to us were

discussed in more detail and any further work required by us was then performed by

the component auditors.

• We inspected the work performed by the component auditors for the purpose of

theGroup audit and evaluated the appropriateness of conclusions drawn from the

audit evidence obtained and consistencies between communicated findings and

workperformed.

• We inspected component teams’ key work papers in-person and using remote

technology capabilities to evaluate the quality of execution of the audits of the

components with a particular focus on insurance contract liabilities and illiquid

financial investments.

8. Other information in the Annual Report

The directors are responsible for the other information presented in the Annual Report together with the financial statements.

Ouropinion on the financial statements does not cover the other information and, accordingly, we do not express an audit opinion

or, except as explicitly stated below, any form of assurance conclusion thereon.

All other information

Our responsibility

Our responsibility is to read the other information and,

in doing so, consider whether, based on our financial

statements audit work, the information therein is materially

misstated or inconsistent with the financial statements or

our audit knowledge.

Our reporting

Based solely on that work we have not identified material

misstatements or inconsistencies in the other information.

Strategic report and Directors’ report

Our responsibility and reporting

Based solely on our work on the other information described above we report to you as follows:

• we have not identified material misstatements in the strategic report and the directors’ report;

• in our opinion the information given in those reports for the financial year is consistent with the financial statements; and

• in our opinion those reports have been prepared in accordance with the Companies Act 2006.

Directors’ remuneration report

Our responsibility

We are required to form an opinion as to whether the part of

the Directors’ Remuneration Report to be audited has been

properly prepared in accordance with the Companies Act 2006.

Our reporting

In our opinion the part of the Directors’ Remuneration Report

to be audited has been properly prepared in accordance with

the Companies Act 2006.

197Standard Life plc Annual Report and Accounts 2025

Financials

Independent auditor’s report continued

Corporate governance disclosures

Our responsibility

We are required to perform procedures to identify whether

there is a material inconsistency between the financial

statements and our audit knowledge, and:

• the directors’ statement that they consider that the annual

report and financial statements taken as a whole is fair,

balanced and understandable, and provides the information

necessary for shareholders to assess the Group’s position

and performance, business model and strategy;

• the section of the annual report describing the work of the

Audit Committee, including the significant issues that the

Audit Committee considered in relation to the financial

statements, and how these issues were addressed; and

• the section of the annual report that describes the review

ofthe effectiveness of the Group’s risk management and

internal control systems.

Our reporting

Based on those procedures, we have concluded that each

ofthese disclosures is materially consistent with the

financialstatements and our audit knowledge.

We are also required to review the part of the Corporate

Governance Statement relating to the Group’s compliance

with the provisions of the UK Corporate Governance Code

specified by the Listing Rules for our review.

We have nothing to report in this respect.

Other matters on which we are required to report by exception

Our responsibility

Under the Companies Act 2006, we are required to report to

you if, in our opinion:

• adequate accounting records have not been kept by the

Parent Company, or returns adequate for our audit have

notbeen received from branches not visited by us; or

• the Parent Company financial statements and the part of

the Directors’ Remuneration Report to be audited are not

inagreement with the accounting records and returns; or

• certain disclosures of directors’ remuneration specified by

law are not made; or

• we have not received all the information and explanations

we require for our audit.

Our reporting

We have nothing to report in these respects.

198 Standard Life plc Annual Report and Accounts 2025

Financials

9. Respective responsibilities

Directors’ responsibilities

As explained more fully in their statement set out on page 182,

the directors are responsible for: the preparation of the financial

statements including being satisfied that they give a true and

fair view; such internal control as they determine is necessary

toenable the preparation of financial statements that are free

from material misstatement, whether due to fraud or error;

assessing the Group and Parent Company’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 they either intend to liquidate the Group or the Parent

Company or to cease operations, or have no realistic alternative

but to do so.

Auditor’s responsibilities

Our objectives are to obtain reasonable assurance about

whether the financial statements as a whole are free from

material misstatement, whether due to fraud or error, and to

issue our opinion in an auditor’s report. Reasonable assurance is

a high level of assurance, but does not guarantee that an audit

conducted in accordance with ISAs (UK) will always detect a

material misstatement when it exists. Misstatements can arise

from fraud or error and 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

financial statements.

A fuller description of our responsibilities is provided on the

FRC’s website at www.frc.org.uk/auditorsresponsibilities.

The Company is required to include these financial statements

inan annual financial report prepared under Disclosure Guidance

and Transparency Rule 4.1.17R and 4.1.18R. This auditor’s report

provides no assurance over whether the annual financial report

has been prepared in accordance with those requirements.

10. The purpose of our audit work and to whom

weowe our responsibilities

This report is made solely to the Company’s members, as a body,

in accordance with Chapter 3 of Part 16 of the Companies Act

2006. Our audit work has been undertaken so that we might

state to the Company’s members those matters 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 members, as a body, for our audit work, for this

report, or for the opinions we have formed.

Stuart Crisp (Senior Statutory Auditor)

for and on behalf of KPMG LLP, Statutory Auditor

Chartered Accountants

15 Canada Square,

London E14 5GL

13 March 2026

199Standard Life plc Annual Report and Accounts 2025

Financials

200 Annual Report and Accounts 2025

Financials

Standard Life plc

		2025	2024
	Notes	£m	£m
Insurance revenue	C1	5,512	5,139
Insurance service expenses	C5	(4,743)	(4,493)
Insurance service result before reinsurance contracts		769	646
Net expenses from reinsurance contracts		(290)	(245)
Insurance service result		479	401
Fees and commissions	C2	1,072	1,027
Net investment income	C3	30,662	18,852
Other operating income		63	89
Total income		32,276	20,369
Net finance expense from insurance contracts	C4	(8,364)	(3,656)
Net finance income/(expense) from reinsurance contracts	C4	28	(109)
Net insurance finance expense		(8,336)	(3,765)
Change in investment contract liabilities		(23,388)	(15,719)
Change in reinsurers’ share of investment contract liabilities		1,767	681
Amortisation and impairment of intangible assets	G2	(240)	(273)
Administrative expenses	C5	(1,541)	(1,825)
Net expense attributable to unit holders		(252)	(285)
Profit/(loss) before finance costs and tax		286	(817)
Finance costs	C7	(266)	(290)
Profit/(loss) for the year before tax		20	(1,107)
Tax charge attributable to policyholders’ returns	C8	(452)	(347)
Loss before the tax attributable to owners		(432)	(1,454)
Tax (charge)/credit	C8	(414)	29
Add: tax attributable to policyholders’ returns	C8	452	347
Tax credit attributable to owners	C8	38	376
Loss for the year		(394)	(1,078)
Attributable to:
Owners of the parent		(443)	(1,090)
Non-controlling interests	D5	49	12
		(394)	(1,078)
Earnings per ordinary share
Basic (pence per share)	B3	(47.1)p	(111.8)p
Diluted (pence per share)	B3	(47.1)p	(111.8)p

Consolidated income statement

For the year ended 31 December 2025

201Annual Report and Accounts 2025

Financials

Standard Life plc

		2025	2024
	Notes	£m	£m
Loss for the year		(394)	(1,078)
Other comprehensive (expense)/income:
Items that are or may be reclassified to profit or loss:
Cash flow hedges:
Fair value (losses)/gains arising during the year	D3	(67)	24
Reclassification adjustments for amounts recognised in profit or loss	D3	45	(15)
Exchange differences on translating foreign operations (net of deferred tax)		3	33
Items that will not be reclassified to profit or loss:
Remeasurements of owner-occupied property	D3	–	(2)
Remeasurements of pension scheme asset/liability	G1	49	109
Tax charge relating to other comprehensive income items	C8	(7)	(36)
Total other comprehensive income for the year		23	113
Total comprehensive expense for the year		(371)	(965)
Attributable to:
Owners of the parent		(420)	(977)
Non-controlling interests	D5	49	12
		(371)	(965)

Statement of consolidated comprehensive income

For the year ended 31 December 2025

202 Annual Report and Accounts 2025

Financials

Standard Life plc

		2025	2024
	Notes	£m	£m
Assets
Pension scheme asset	G1	33	35
Reimbursement right assets	G1	175	183
Intangible assets	G2	1,554	1,784
Property, plant and equipment	G3	74	91
Investment property	G4	4,528	4,370
Investment in associate accounted for using the equity method	H3	11	4
Financial assets	E1	309,031	279,539
Reinsurance contract assets	F3	5,808	5,187
Deferred tax assets	G8	327	146
Current tax assets	G8	298	523
Prepayments and accrued income		367	399
Other receivables	G5	2,719	3,043
Cash and cash equivalents	G6	7,302	9,453
Assets classified as held for sale	H2	14	3,100
Total assets		332,241	307,857
Equity
Share capital	D1	101	100
Share premium		20	16
Shares held by employee benefit trust	D2	(14)	(18)
Foreign currency translation reserve		127	124
Other reserves	D3	594	616
Retained earnings		(584)	375
Equity attributable to owners of the parent		244	1,213
Tier 1 Notes	D4	494	494
Non-controlling interests	D5	554	539
Total equity		1,292	2,246
Liabilities
Pension scheme liability	G1	1,247	1,312
Reimbursement right liabilities	G1	10	34
Insurance contract liabilities	F1	120,326	115,791
Reinsurance contract liabilities	F3	180	158
Financial liabilities	E1	205,437	181,789
Provisions	G7	188	206
Deferred tax liabilities	G8	490	198
Current tax liabilities	G8	18	21
Lease liabilities	G9	59	64
Accruals and deferred income	G10	565	583
Other payables	G11	2,429	2,280
Liabilities classified as held for sale	H2	–	3,175
Total liabilities		330,949	305,611
Total equity and liabilities		332,241	307,857

Approved by the Board on 13 March 2026.

Andy Briggs Nicolaos Nicandrou

Chief Executive Officer Chief Financial Officer

Company registration number 11606773.

Statement of consolidated financial position

As at 31 December 2025

203Annual Report and Accounts 2025

Financials

Standard Life plc

			Shares
			held by
			employee	Foreign					Non-con-
	Share	Share	benefit	currency	Other			Tier 1	trolling
	capital	premium	trust	translation	reserves	Retained		Notes	interests	Total
	(note D1)	(note D1)	(note D2)	reserve	(note D3)	earnings	Total	(note D4)	(note D5)	equity
	£m	£m	£m	£m	£m	£m	£m	£m	£m	£m
At 1 January 2025	100	16	(18)	124	616	375	1,213	494	539	2,246
(Loss)/profit for the year	–	–	–	–	–	(443)	(443)	–	49	(394)
Other comprehensive income/
(expense) for the year	–	–	–	3	(22)	42	23	–	–	23
Total comprehensive income/
(expense) for the year	–	–	–	3	(22)	(401)	(420)	–	49	(371)
Issue of ordinary share capital, net of associated commissions
and expenses	1	4	–	–	–	–	5	–	–	5
Dividends paid on ordinaryshares	–	–	–	–	–	(548)	(548)	–	–	(548)
Dividends paid to non- controlling interests	–	–	–	–	–	–	–	–	(12)	(12)
Credit to equity for equity- settled share-based payments	–	–	–	–	–	26	26	–	–	26
Taxation on shares schemes	–	–	–	–	–	6	6	–	–	6
Reserve movement on exercise
of share scheme awards	–	–	13	–	–	(13)	–	–	–	–
Shares acquired by the employee benefit trust	–	–	(9)	–	–	–	(9)	–	–	(9)
Decrease in non-controlling interests	–	–	–	–	–	–	–	–	(22)	(22)
Coupon paid on Tier 1 Notes	–	–	–	–	–	(29)	(29)	–	–	(29)
At 31 December 2025	101	20	(14)	127	594	(584)	244	494	554	1,292

Statement of consolidated changes in equity

For the year ended 31 December 2025

204 Annual Report and Accounts 2025

Financials

Standard Life plc

			Shares
			held by
			employee	Foreign					Non-
	Share	Share	benefit	currency	Other			Tier 1	controlling
	capital	premium	trust	translation	reserves	Retained		Notes	interests	Total
	(note D1)	(note D1)	(note D2)	reserve	(note D3)	earnings	Total	(note D4)	(note D5)	equity
	£m	£m	£m	£m	£m	£m	£m	£m	£m	£m
At 1 January 2024	100	16	(15)	91	1,835	715	2,742	494	549	3,785
(Loss)/profit for the year	–	–	–	–	–	(1,090)	(1,090)	–	12	(1,078)
Other comprehensive income
for the year	–	–	–	33	7	73	113	–	–	113
Total comprehensive income/
(expense) for theyear	–	–	–	33	7	(1,017)	(977)	–	12	(965)
Dividends paid on ordinaryshares	–	–	–	–	–	(533)	(533)	–	–	(533)
Dividends paid to non- controlling interests	–	–	–	–	–	–	–	–	(12)	(12)
Credit to equity for equity- settled share-based payments	–	–	–	–	–	26	26	–	–	26
Reserve movement on exercise
of share scheme awards	–	–	13	–	–	(13)	–	–	–	–
Shares acquired by the employee benefit trust	–	–	(16)	–	–	–	(16)	–	–	(16)
Decrease in non-controlling interests	–	–	–	–	–	–	–	–	(10)	(10)
Coupon paid on Tier 1 Notes	–	–	–	–	–	(29)	(29)	–	–	(29)
Transfer of merger
reliefreserve	–	–	–	–	(1,226)	1,226	–	–	–	–
At 31 December 2024	100	16	(18)	124	616	375	1,213	494	539	2,246

Statement of consolidated changes in equity

For the year ended 31 December 2024

205Annual Report and Accounts 2025

Financials

Standard Life plc

		2025	2024
	Notes	£m	£m
Cash flows from operating activities
Cash (utilised)/generated by operations	I2	(920)	3,549
Taxation paid		(73)	(177)
Net cash flows from operating activities		(993)	3,372
Cash flows from investing activities
Capitalised development costs	G2	(10)	(29)
Net cash flows from investing activities		(10)	(29)
Cash flows from financing activities
Proceeds from issuing ordinary shares, net of associated commission and expenses		5	–
Acquisition of non-controlling interests	D5	(22)	(10)
Ordinary share dividends paid	B4	(548)	(533)
Dividends paid to non-controlling interests	D5	(12)	(12)
Repayment of policyholder borrowings	E5.2	(98)	(96)
Repayment of shareholder borrowings	E5.2	(398)	(643)
Repayment of lease liabilities	G9	(10)	(11)
Payment by the Employee Benefit Trust to acquire shares	D2	(9)	–
Proceeds from new shareholder borrowings, net of associated expenses	E5.2	–	390
Proceeds from new policyholder borrowings, net of associated expenses	E5.2	152	85
Coupon paid on Tier 1 Notes		(29)	(29)
Interest paid on policyholder borrowings		(12)	(8)
Interest paid on shareholder borrowings		(200)	(210)
Net cash flows from financing activities		(1,181)	(1,077)
Net (decrease)/increase in cash and cash equivalents		(2,184)	2,266
Cash and cash equivalents at the beginning of the year		9,486	7,220
Cash and cash equivalents at the end of the year 1		7,302	9,486

1 Includes cash and cash equivalents of £33 million classified as held for sale in the comparative period.

Statement of consolidated cash flows

For the year ended 31 December 2025

206 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements

A. Significant accounting policies

A1. Basis of preparation

The consolidated financial statements for the year ended 31 December 2025 set out on pages 200 to 316 comprise the financial

statements of Standard Life plc (formerly Phoenix Group Holdings plc) (‘the Company’) and its subsidiaries (together referred to

as ‘the Group’) and were authorised by the Board of Directors for issue on 13 March 2026.

The consolidated financial statements have been prepared under the historical cost convention except for investment property,

owner-occupied property, those financial assets and financial liabilities (including derivative instruments) that have been measured

at fair value and for insurance and reinsurance contracts that are measured using estimates of future cash flows, as explained in the

accounting policies below.

The consolidated financial statements are presented in sterling (£) rounded to the nearest million except where otherwise stated.

Assets and liabilities are offset and the net amount reported in the statement of consolidated financial position only when there is

a legally enforceable right to offset the recognised amounts and there is an intention to settle on a net basis, or to realise the asset

and settle the liability simultaneously. Income and expenses are not offset in the consolidated income statement unless required or

permitted by an International Financial Reporting Standard (‘IFRS’) Accounting Standard or interpretation, as specifically disclosed

in the accounting policies of the Group.

Statement of compliance

The consolidated financial statements have been prepared in accordance with UK-adopted international accounting standards

(‘IASs’) and the legal requirements of the Companies Act 2006.

Basis of consolidation

The consolidated financial statements include the financial statements of the Company and its subsidiary undertakings, including

collective investment schemes, where the Group exercises overall control. In accordance with the principles set out in IFRS 10

Consolidated Financial Statements, the Group controls an investee if and only if the Group has all of the following:

• 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 its returns.

The Group considers all relevant facts and circumstances in assessing whether it has power over an investee, including relevant

activities, substantive and protective rights, voting rights and purpose and design of an investee. The Group reassesses whether or

not it controls an investee if facts and circumstances indicate that there are changes to one or more of the three elements of control.

Further details about the consolidation of subsidiaries, including collective investment schemes, are included in note H1.

Going concern

The consolidated financial statements have been prepared on a going concern basis. The Directors have, at the time of approving the

consolidated financial statements, a reasonable expectation that the Company and the Group have adequate resources to continue

in operational existence for the period covered by the assessment having assessed the principal risks, forecasts, projections and

other relevant evidence for a period of at least, but not limited to, 12 months from the date of approval of these consolidated

financial statements, using the information available up to the date of issue of this Annual Report and Accounts. Further details of

the going concern assessment are included in the Directors’ Report on page 178.

A2. Adoption of new accounting pronouncements in 2025

In preparing the consolidated financial statements, the Group has adopted the following amendment effective from 1 January 2025

which has been endorsed by the UK Endorsement Board (‘UKEB’):

• Lack of Exchangeability (Amendments to IAS 21 The Effects of Changes in Foreign Exchange Rates).

The above amendment is not considered to have a material effect on these consolidated financial statements. The Group has not

early adopted any other standard, interpretation or amendment that has been issued but is not yet effective.

A3. Accounting policies

The principal accounting policies have been consistently applied in these consolidated financial statements. Where an accounting

policy can be directly attributed to a specific note to the consolidated financial statements, the policy is presented within that note,

with a view to enabling greater understanding of the results and financial position of the Group. All other significant accounting

policies are disclosed below.

A3.1 Foreign currency transactions

Items included in the financial statements of each of the Group’s entities are measured using the currency of the primary economic

environment in which the entity operates (the ‘functional currency’). The consolidated financial statements are presented in sterling,

which is the Group’s presentation currency.

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Standard Life plc

The results and financial position of all Group companies that have a functional currency different from the presentation currency

are translated into the presentation currency as follows:

• assets and liabilities are translated at the closing rate at the period end;

• income, expenses and cash flows denominated in foreign currencies are translated at average exchange rates; and

• all resulting exchange differences are recognised through the statement of consolidated comprehensive income.

Foreign currency transactions are translated into the functional currency of the transacting Group entity using exchange rates

prevailing at the date of the transaction. Foreign exchange gains and losses resulting from the settlement of such transactions and

from the translation of monetary assets and liabilities denominated in foreign currencies are recognised in the consolidated income

statement. Translation differences on non-monetary items at fair value through profit or loss are reported as part of the fair value

gain or loss.

A3.2 Other operating income

Other operating income includes income from all other operating activities which are incidental to the principal activities of the Group.

A4. Critical accounting estimates and judgements

The preparation of financial statements requires management to make judgements, estimates and assumptions that affect the

application of policies and reported amounts of assets and liabilities, income and expenses. Disclosures of judgements made by

management in applying the Group’s accounting policies include those that have the most significant effect on the amounts that are

recognised in the consolidated financial statements. Disclosures of estimates and associated assumptions include those that have a

significant risk of resulting in a material change to the carrying value of assets and liabilities within the next year. The estimates and

associated assumptions are based on historical experience and various other factors that are believed to be reasonable under the

circumstances, the results of which form the basis of the judgements as to the carrying values of assets and liabilities that are not

readily apparent from other sources. Actual results may differ from these estimates.

Critical accounting estimates are those which involve the most complex or subjective judgements or assessments. The areas of the

Group’s business that typically require such estimates are the measurement of insurance and investment contract liabilities with

discretionary participation features (‘DPF’), determination of the fair value of certain financial assets and liabilities, and valuation

of pension scheme assets and liabilities.

The application of critical accounting judgements that could have the most significant effect on the recognised amounts include

classification of contracts to be accounted for as insurance or investment contracts and amortisation of those contracts, the

determination of adjusted operating profit and determination of control with regard to underlying entities.

Details of all critical accounting estimates and judgements are included below and further consideration is also given to how climate

risk affects the accounting judgements and estimates applied.

A4.1 Insurance contract and investment contract with DPF liabilities

The Group applies significant judgement and estimation when classifying and measuring insurance contracts, including

determination of the inputs, assumptions and techniques it uses to determine the BEL, risk adjustment and CSM at each reporting

period to measure insurance contract and reinsurance contact liabilities/assets. The main areas where significant judgement and

estimation were required are:

Contract classification

Classification of contracts as insurance (or reinsurance) is based upon an assessment of the significance of insurance risk transferred

to the Group. Insurance contracts are defined by IFRS 17 as those containing significant insurance risk if, and only if, an insured event

could cause an insurer to make significant additional payments in any scenario, excluding scenarios that lack commercial substance,

at the inception of the contract.

Classification of contracts as investment with DPF is based upon an assessment of whether the discretionary amount of benefits

is expected to be a significant amount of the total benefits. Insurance contracts and investment contracts with such discretionary

participation features are accounted for under IFRS 17, while investment contracts without discretionary participation features

are accounted for as financial instruments under IFRS 9. Judgement is therefore required in order to establish whether any

additional benefits in an insurance or investment contract meet the above requirements for being considered discretionary

participation features.

Measurement of insurance contract liabilities

In applying IFRS 17 requirements for the measurement of insurance contract liabilities, the following inputs and methods were used

that include significant estimates:

• the present value of future cash flows is estimated using deterministic scenarios, except where stochastic modelling involves

projecting future cash flows under a large number of possible economic scenarios for market variables such as interest rates and

equity returns and where the cash flows reflect a series of interrelated options that are implicit or explicit;

• the approach and assumptions used to derive discount rates, including any illiquidity premiums (see note F9.2.1);

• the approach and confidence level for estimating risk adjustments for non-financial risk (see note F9.2.2); and

• the assumptions about future cash flows relating to mortality, morbidity, policyholder behaviour, and expense inflation (see

note F9.2.3).

Details of how insurance contract liabilities are accounted for are included within the accounting policies in note F1.

208 Annual Report and Accounts 2025

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Standard Life plc

Notes to the consolidated financial statements continued

Amortisation of the CSM

The Group applies judgements when determining the amount of CSM for a group of insurance contracts to be recognised in profit or

loss as insurance revenue in each period to reflect the insurance contract services provided in that period. The amount is determined

by considering for each group of contracts the quantity of benefits provided and the expected coverage period. Determining the

coverage unit requires significant judgement, taking into consideration a number of areas, including:

• identification of a coverage unit that is deemed to be a suitable proxy for the service provided. This is particularly relevant

for products that provide a combination of different types of insurance coverage, investment-related service and investment-

return service; and

• the allowance for time value of money in the release of the coverage unit (i.e. whether or not the coverage units should

be discounted).

For deferred annuities the weighting between the deferral phase and the payment phase coverage units is calculated so that the

services provided in the deferral phase reflect the investment return and those in the payment phase reflect the annuity payment

with the total services adjusted to provide a consistent level of service when transitioning between the deferral phase and the

payment phase.

Following an assessment, the Group has determined the quantity of the benefits provided under each contract to be a suitable proxy

for the service provided as follows:

Type of business/products	Coverage unit (quantity of benefits)
Term life assurance	Sum assured in force
Endowment
Non-participating whole-life
Other protection products
Immediate annuity	Annuity payments
Deferred annuity	Fund size during deferred period and annuity payments
	for the payment period
Unit linked	Annual management charge and insurance charges
Conventional with-profits (‘CWP’) & Unitised with-profits (‘UWP’)	Maximum of the guaranteed benefit and asset share

In relation to the application of discount rate in determining the coverage units, the Group has elected to apply discounting as this

gives a more even allocation of profit as services are provided over the life of a group of contracts. The discount rate is the locked-in

rate for insurance contracts measured under the general model (‘GM’) and current rates for insurance contracts measured under the

variable fee approach (‘VFA’).

A4.2 Fair value of financial assets and liabilities

A significant portion of the Group’s financial assets and liabilities are measured at fair value and accounted for as set out in the

accounting policies in note E1. Financial instruments valued where valuation techniques are based on observable market data at the

period end are categorised as Level 2 financial instruments. Financial instruments valued where valuation techniques are based on

non-observable inputs are categorised as Level 3 financial instruments. Level 2 and Level 3 financial instruments therefore involve

the use of estimates.

Further details of the estimates made are included in note E2. In relation to the Level 3 financial instruments, sensitivity analysis is

performed in respect of the key assumptions used in the valuation of these financial instruments. The details of this sensitivity

analysis are included in note E2.4.

A4.3 Pension scheme obligations

The valuation of pension scheme obligations is determined using actuarial valuations that depend upon a number of assumptions,

including discount rate, inflation and longevity. External actuarial advice is taken with regard to setting the financial assumptions

to be used in the valuation. As defined benefit pension schemes are long-term in nature, such assumptions can be subject to

significant uncertainty.

Further details of these estimates and the sensitivity of the defined benefit obligation to key assumptions are provided in note G1.

A4.4 Adjusted operating profit

Adjusted operating profit is the Group’s non-GAAP measure of performance and provides stakeholders with a comparable measure

of the underlying performance of the Group. The Group is required to make judgements as to the appropriate longer-term rates of

investment return for the determination of adjusted operating profit based on yields at the start of the financial year, as detailed in

note B2, and as to whether items are included within adjusted operating profit or excluded as an adjustment to adjusted operating

profit in accordance with the accounting policy detailed in note B1. Items excluded from adjusted operating profit are referred to as

‘non-operating items’.

A. Significant accounting policies continued

A4. Critical accounting estimates and judgements continued

A4.1 Insurance contract and investment contract with DPF liabilities continued

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A4.5 Control and consolidation

The Group has invested in a number of collective investment schemes and other types of investment where judgement is applied

in determining whether the Group controls the activities of these entities. These entities are typically structured in such a way that

owning the majority of the voting rights is not the conclusive factor in the determination of control in line with the requirements

of IFRS 10 Consolidated Financial Statements. The control assessment therefore involves a number of further considerations such as

whether the Group has a unilateral power of veto in general meetings and whether the existence of other agreements restrict the

Group from being able to influence the activities. Further details of these judgements are given in note H1.

A4.6 How climate risk affects our accounting judgments and estimates

In preparation of these financial statements, the Group has considered the impact of climate change across a number of areas,

predominantly in respect of the valuation of financial instruments, insurance and investment contract liabilities and goodwill and

other intangible assets.

Many of the effects arising from climate change will be longer-term in nature, with an inherent level of uncertainty, and have been

assessed as having a limited effect on accounting judgments and estimates for the current period.

The majority of the Group’s financial assets are held at fair value and use quoted market prices or observable market inputs in their

valuation. The use of quoted market prices and market inputs to determine fair value reflects current information and market

sentiment regarding the effect of climate risk. For the valuation of level 3 financial instruments, there are no material unobservable

inputs in relation to climate risk. Note E6 provides further risk management disclosures in relation to financial risks including

sensitivities in relation to credit and market risk. In addition, further details on managing the related climate change risks are

provided in the Task Force for Climate-related Financial Disclosures (‘TCFD’) on page 53 of the Annual Report and Accounts.

Insurance and investment contract liabilities with DPF use economic assumptions taking into account market conditions at the

valuation date as well as non-economic assumptions such as future expenses, longevity and mortality, which are set based on past

experience, market practice, regulations and expectations about future trends. Due to the level of annuities written by the Group,

it is particularly exposed to longevity risk. While the impact of climate change on longevity assumptions has been considered, as at

31 December 2025 there are no adjustments made to the longevity assumptions to specifically allow for the impact of climate

change on annuitant mortality. Further details as to how assumptions are set and of the sensitivity of the Group’s results to

annuitant longevity and other key insurance risks are set out in note F9.

The assessment of impairment for goodwill and intangible assets is based on value in use calculations. Value in use represents the

value of future cash flows and uses the Group’s three-year annual operating plan and the expectation of long-term economic growth

beyond this period, and for the impairment testing of the acquired value of in-force is based on the fair value of the underlying

contracts. The three-year annual operating plan reflects management’s current expectations on competitiveness and profitability

and reflects the expected impacts of the process of moving towards a low carbon economy. Note G2 provides further details on

goodwill and other intangible assets and on impairment testing performed.

A5. New accounting pronouncements not yet effective

The IASB has issued the following IFRS accounting standards or amended IFRS accounting standards and interpretations which apply

from the dates shown. The Group has decided not to early adopt any of these standards, amendments or interpretations where this

is permitted.

Amendments to the Classification and Measurement of Financial Instruments – Amendments to IFRS 9 and IFRS 7

(1 January 2026)

The IASB issued targeted amendments to IFRS 9 and IFRS 7 to respond to recent questions arising in practice. These amendments:

• clarify the date of recognition and derecognition of some financial assets and liabilities, with a new exception for some financial

liabilities settled through an electronic cash transfer system;

• clarify and add further guidance for assessing whether a financial asset meets the solely payments of principal and interest

(‘SPPI’) criterion;

• add new disclosures for certain instruments with contractual terms that can change cash flows (such as some financial

instruments with features linked to the achievement of environment, social and governance targets); and

• update the disclosures for equity instruments designated at fair value through other comprehensive income (‘FVOCI’).

The Group does not expect these amendments to have a material impact on its operations or consolidated financial statements.

Annual Improvements to IFRS Accounting Standards – Volume 11 (1 January 2026)

As part of the IASB’s Annual Improvements process it has issued minor amendments to address potential areas of confusion within

the following standards: IFRS 1 First-time Adoption of International Financial Reporting Standards – hedge accounting by a first-time

adopter; IFRS 7 Financial Instruments: Disclosures – gain or loss on derecognition and clarifications within implementation guidance;

IFRS 9 Financial Instruments – lessee derecognition of lease liabilities and transaction price; IFRS 10 Consolidated Financial

Statements – determination of a ‘de facto agent’; and IAS 7 Statement of Cash Flows – cost method.

The Group does not expect these amendments to have a material impact on its operations or consolidated financial statements.

210 Annual Report and Accounts 2025

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Standard Life plc

Notes to the consolidated financial statements continued

IFRS 18 Presentation and Disclosure in Financial Statements (1 January 2027)

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

make consequential amendments to other standards. IFRS 18 introduces new requirements that will help to achieve comparability

of the financial performance of similar entities and provide more relevant information and transparency to users, including

classification of all income and expenses within the statement of financial performance into one of five new categories, new

specified totals and sub-totals in the statement of financial performance and requirements for the identification and disclosure

of Management-defined Performance Measures (‘MPM’) within the financial statements. It will not impact the recognition or

measurement of items in the financial statements. Management has carried out an impact assessment during 2025 and is

progressing with work to prepare templates for financial statements on an IFRS 18 basis. From the progress to date, the following

potential impacts have been identified:

• Although the adoption of IFRS 18 will have no impact on the Group’s net profit, the Group expects that grouping items of income

and expenses in the consolidated income statement into the new categories will impact how IFRS-defined operating profit is

calculated and reported. The Group expects to specify investing activities as a main business activity which will result in income

and expenses from investing activities being presented within the operating category of the consolidated income statement and

therefore included in the operating profit sub-total. In addition, there will be a reclassification to the financing category of certain

interest expenses that are currently included in net investment income, from the operating category to the financing category.

• Furthermore, the line items in the primary financial statements might change to achieve the objective of a ‘useful structured

summary’ as defined in IFRS 18, and the Group may choose to include additional sub-totals, where permitted, in order to provide

more understandable information.

• The Group’s Alternative Performance Measure (‘APM’) of adjusted operating profit is considered to meet the definition in IFRS 18

of an MPM. Whilst the Group currently provides detailed information about adjusted operating profit, including a reconciliation to

the most directly comparable total in the consolidated income statement, the new defined sub-totals in the consolidated income

statement and prescriptive disclosure requirements for MPMs contained in IFRS 18 are expected to change the format of the

reconciliation currently provided. IFRS 18 does not mandate changes to the calculation of an APM that meets the IFRS 18

definition of an MPM.

• The calculation of additional earnings per share based on adjusted operating profit might change due to restrictions on the

amounts that may be used as the numerator.

• The Group does not expect there to be a significant change in the information that is currently disclosed in the notes because the

requirement to disclose material information remains unchanged; however, the way in which the information is grouped might

change as a result of the enhanced aggregation/disaggregation principles, particularly for items currently labelled as ‘other’.

For the first annual period of application of IFRS 18, a reconciliation is required for each line item in the consolidated income

statement between the restated amounts presented by applying IFRS 18 and the amounts previously presented applying IAS 1.

• From a cash flow statement perspective, the Group is required to use the operating profit sub-total as a starting point for the

statement of cash flows when presenting operating cash flows under the indirect method.

The Group will apply the new standard from its mandatory effective date of 1 January 2027. Retrospective application is required,

and so the comparative information for the financial year ending 31 December 2026 will be restated in accordance with IFRS 18,

including a reconciliation for each line item in the consolidated income statement between the restated amounts applying IFRS 18

and the amounts previously presented applying IAS 1.

During 2026 the Group will continue its preparations and implementation activities.

IFRS 19 Subsidiaries without Public Accountability (1 January 2027)

IFRS 19 allows for certain eligible subsidiaries of parent entities that report under IFRS Accounting Standards to apply

reduced disclosure requirements. The Group does not expect this standard to have an impact on its operations or consolidated

financial statements.

Sale or Contribution of Assets between an Investor and its Associate or Joint Venture (Amendments to IFRS 10 and IAS 28)

(Effective date deferred)

The amendments address the conflict between IFRS 10 and IAS 28 in dealing with the loss of control of a subsidiary that is sold or

contributed to an associate or joint venture. These amendments are not expected to have any impact on the Group.

The following amendments to standards listed above have been endorsed for use in the UK by the UK Endorsement Board:

• Lack of Exchangeability (Amendments to IAS 21 The Effects of Changes in Foreign Exchange Rates);

• Annual Improvements to IFRS Accounting Standards — Volume 11;

• Amendments to IFRS 9 and IFRS 7 – Amendments to classification and measurement of financial instruments; and

• IFRS 18 Presentation and Disclosure in Financial Statements.

A6. Future voluntary change in accounting policy

The Group intends to make a voluntary change in accounting policy in its 2026 consolidated financial statements in relation to its

issued insurance contracts with direct participation features accounted for using the Variable Fee Approach, once it has completed

the work to determine the impacts on its reported results with sufficient precision. The change is the adoption of the Risk Mitigation

Option ('RMO'). The Variable Fee Approach requires changes in fulfilment cashflows that adjust the entity’s share of underlying

items be recognised in CSM. However, as the Group holds derivative instruments held to mitigate financial risks associated with

those changes a mismatch arises because the fair value gains and losses of these derivative instruments are reported in profit or loss. 

A. Significant accounting policies continued

A5. New accounting pronouncements not yet effective continued

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Standard Life plc

This mismatch gives rise to volatility in the Group’s financial results which does not reflect the nature of the risk mitigation activities

undertaken by the Group in respect of these contracts. IFRS 17 introduced the RMO to allow entities to remove this mismatch.

The RMO will be applied for the Group’s equity risk hedging strategy and, as required, prior periods from 1 January 2022 will be

restated from the point the RMO conditions were met. The Group has determined that it meets all the RMO conditions in terms of

economic offset and documentation to make this voluntary election. The impact of this change at 31 December 2025 is estimated as

a £0.1 billion increase in retained earnings.

B. Earnings performance

B1. Segmental analysis

The Group defines and presents operating segments in accordance with IFRS 8 Operating Segments which requires such segments

to be based on the information which is provided to the Board, and therefore segmental information in this note is presented on

a different basis from profit or loss in the consolidated financial statements.

An operating segment is a component of the Group that engages in business activities from which it may earn revenues and incur

expenses, including revenues and expenses relating to transactions with other components of the Group. For management

purposes the Group is organised into value centres and has five operating segments comprising Retirement Solutions, Pensions &

Savings, With-Profits, SunLife & Protection, and Europe. Operating segments are aggregated where they share similar economic

characteristics including the nature of products and services, types of customers and the nature of the regulatory environment.

The SunLife & Protection operating segment has been aggregated with the Europe operating segment to form a single Europe &

Other reportable segment.

The Retirement Solutions segment includes new and in-force individual annuity and Pension Risk Transfer (‘PRT’) contracts written

in the UK within shareholder funds, with the exception of individual annuity contracts written as a result of Guaranteed Annuity

Options on with-profit contracts which are excluded. Such contracts remain in the With-Profits segment, as they fall within the

contract boundary of the original savings or pension contract. The Retirement Solutions segment also includes UK individual

annuity business written within the Standard Life Heritage With-Profits Fund as the profits are primarily attributable to the

shareholder through the Recourse Cash Flow mechanism established on demutualisation.

The Pensions & Savings segment includes new and in-force life insurance and investment unit-linked policies written in the UK in

respect of pensions and savings products that the Group continues to actively market to new and existing policyholders. This

includes products such as workplace pensions and Self-Invested Personal Pension (‘SIPPs’) distributed through the Group’s

strategic partnership with Aberdeen Group plc. In addition, it includes in-force insurance and investment unit-linked products from

legacy businesses which no longer actively sell products to policyholders and which therefore run-off gradually over time. The

Pensions & Savings segment also includes UK unitised business written in the Standard Life Heritage With-Profits funds, as profits

are primarily attributable to the shareholder through the Recourse Cash Flow mechanism.

The With-Profits segment includes all policies written in the UK by the Group’s with-profits funds, with the exception of Standard

Life Heritage With-Profits Fund contracts reflected in other segments as noted above for Retirement Solutions and Pensions &

Savings where profits are primarily attributable to the shareholder through the Recourse Cash Flow mechanism.

The Europe & Other segment includes business written in Ireland and Germany. This includes products that are actively being

marketed to new policyholders and legacy in-force products that are no longer being sold to new customers. The segment also

includes protection products and products sold under the SunLife brand.

The Corporate Centre segment, which is not a reportable segment, principally comprises central head office costs that are not

directly attributable to the Group’s insurance or investment contracts. Management services costs are allocated to the four

reportable segments.

Inter-segment transactions are set on an arm’s length basis in a manner similar to transactions with third parties. Segmental results

include those transfers between business segments which are then eliminated on consolidation.

Segmental measure of performance: Adjusted operating profit

The Group uses a non-GAAP measure of performance, being adjusted operating profit, to evaluate segmental performance.

Adjusted operating profit is considered to provide a comparable measure of the underlying performance of the business as it

excludes the impact of short-term economic volatility, one-off items and certain other items.

The following sets out the adjusted operating profit methodology:

For unit-linked business accounted for under IFRS 9, adjusted operating profit includes the fees collected from customers less

operating expenses including overheads.

For unit-linked and with-profits business accounted for under IFRS 17, adjusted operating profit includes the release of the risk

adjustment, amortisation of CSM, and demographic experience variances in the period.

For shareholder annuity, other non-profit business and with-profits funds receiving shareholder support accounted for under IFRS

17, adjusted operating profit includes the release of the risk adjustment, amortisation of CSM, and demographic experience

variances in the period. Adjusted operating profit also incorporates an expected return on the financial investments backing this

business and any surplus assets, with allowance for the corresponding movement in liabilities.

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Notes to the consolidated financial statements continued

Adjusted operating profit excludes the above items for non-profit business written in a with-profits fund where these amounts do

not accrue directly to the shareholder.

Adjusted operating profit includes the effect of experience variances relating to the current period for non-economic items, such

as mortality and expenses. It also incorporates the impacts of asset trading and portfolio rebalancing where not reflected in the

discount rate used in calculating expected return.

Adjusted operating profit is reported net of policyholder finance charges and policyholder tax.

Adjusted operating profit excludes the impacts of the following items:

Economic variances

• the difference between actual and expected experience for economic items recognised in the consolidated income statement,

impacts of economic assumptions on the valuation of liabilities measured under the General Model and the change in value of

loss components on Variable Fee Approach business resulting from market movements on underlying items;

• economic volatility arising from the Group’s hedging strategy which is calibrated to protect the Solvency II capital position and

cash generation capability of the operating companies;

• the accounting mismatch resulting from the application of IFRS 17 between the measurement of non-profit business in a

with-profits fund (noted above) and the change in fair value of this business included within the measurement of the with-

profits contracts under the Variable Fee Approach;

• the accounting mismatch resulting from buy-in contracts between the Group’s pension schemes and Phoenix Life Limited, the

Group’s main insurance subsidiary. The mismatch represents the difference between the unwind of the IAS 19 discount rate

calculated with reference to a AA-rated corporate bond and the expected investment returns on the backing assets; and

• the effect of the mismatch between changes in estimates of future cash flows on General Model contracts measured at current

discount rates and the corresponding adjustment to the CSM measured at the discount rate locked-in at inception.

Other

• amortisation and impairment of AVIF and brand intangible assets (net of policyholder tax);

• finance costs attributable to owners;

• gains or losses on the acquisition or disposal of subsidiaries (net of related costs);

• the financial impacts of mandatory regulatory change;

• the profit or loss attributable to non-controlling interests;

• integration, restructuring or other significant one-off projects impacting the income statement; and

• any other items which, in the Director’s view, should be disclosed separately by virtue of their nature or incidence to enable a full

understanding of the Group’s financial performance. This is typically the case where the nature of the item is not reflective of

the underlying performance of the operating companies.

The items excluded from adjusted operating profit are referred to as ‘non-operating items’. Whilst the excluded items are

important to an assessment of the consolidated financial performance of the Group, management considers that the presentation

of adjusted operating profit provides a good indicator of the underlying performance of the Group’s operating segments and the

Group uses this, as part of a suite of measures, for decision-making and monitoring performance. The Group’s adjusted operating

profit should be read in conjunction with the IFRS profit or loss before tax.

B1.1 Segmental result

		2025	2024
	Notes	£m	£m
Adjusted operating profit
Retirement Solutions		563	474
Pensions & Savings		389	316
With-Profits		24	41
Europe & Other		83	96
Corporate Centre		(114)	(102)
Total segmental adjusted operating profit		945	825
Economic variances	B2.2	(604)	(1,297)
Amortisation and impairment of intangible assets		(233)	(270)
Other non-operating items		(396)	(520)
Finance costs on borrowing attributable to owners		(193)	(204)
Loss before the tax attributable to owners of the parent		(481)	(1,466)
Profit before tax attributable to non-controlling interests		49	12
Loss before the tax attributable to owners		(432)	(1,454)

B. Earnings performance continued

B1. Segmental analysis continued

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Other non-operating items in respect of the year ended 31 December 2025 include:

• £80 million of costs associated with the delivery of the Group Target Operating Model for IT and Operations, including the

provision for costs associated with the strategic decision to migrate customer administration of ReAssure policies to Wipro.

Under IFRS 17, the expected costs in respect of this activity that are directly attributable to insurance contracts have been

included within the measurement of insurance contract liabilities;

• £94 million of costs associated with finance transformation activities, including the migration to cloud-based systems and

enhancements to actuarial modelling and reporting capabilities and the related control environment;

• £65 million of costs associated with strategic growth initiatives, including investment in digital and direct asset sourcing

capabilities, establishment of the Group’s integrated capital requirements model and transformation of the Group’s operating

model to support efficient growth;

• £24 million of costs associated with delivery of the Group’s 3-year cost saving programme;

• £20 million of costs associated with in-housing the management of annuity backing assets;

• £12 million of costs relating to mobilisation and the transition between offices, including implementation and

decommissioning activities;

• Residual corporate project costs and other one-off items totalling £101 million.

Other non-operating items in respect of the year ended 31 December 2024 include:

• £208 million loss reflecting the net loss from the derecognition of the IAS 19 defined benefit obligation and reimbursement rights

and the recognition of an insurance contract and associated reinsurance contracts following the completion of the PGL Pension

Scheme buy-out transaction. A gain of £108 million arose on the remeasurement of the BEL and risk adjustment using the discount

rate implicit in the buy-out transfer amount at initial recognition and the Group’s discount rate applied for the subsequent

measurement of annuity insurance and reinsurance contracts immediately after initial recognition. The resulting net loss of

£106 million also includes pension scheme wind up costs of £6 million incurred in the period to date. Note G1 provides more detail

on the derecognition of the IAS 19 balances;

• £134 million of costs associated with the delivery of the Group Target Operating Model for IT and Operations, including the

migration of policyholder administration onto the Tata Consultancy Services (‘TCS’) platform. Under IFRS 17, the expected costs in

respect of this activity that are directly attributable to insurance contracts have been included within insurance contract liabilities;

• costs of £93 million associated with finance transformation activities, including the migration to cloud-based systems and

enhancements to actuarial modelling and reporting capabilities and the related control environment;

• £80 million of costs associated with strategic growth initiatives, including development of the Group’s Internal Model, investment

in digital and direct asset sourcing capabilities, and transformation of the Group’s operating model to support efficient growth;

• £43 million of costs associated with delivery of the Group’s 3-year cost saving programme;

• £22 million of costs associated with ongoing integration programmes;

• Corporate project costs and net other one-off items totalling a cost of £42 million.

Further details of the investment return variances and economic assumption changes on long-term business, and the variance

on owners’ funds are included in note B2.

B1.2 Segmental revenue

		2025			2024
	Insurance	Fees and	Total segmental	Insurance	Fees and	Total segmental
	revenue	Commissions	revenue	revenue	Commissions	revenue
Revenue from external customers:	£m	£m	£m	£m	£m	£m
Retirement Solutions	4,373	–	4,373	3,918	–	3,918
Pensions & Savings	269	915	1,184	274	886	1,160
With-Profits	327	52	379	378	51	429
Europe & Other	543	105	648	569	90	659
Total segmental revenue	5,512	1,072	6,584	5,139	1,027	6,166

Of the revenue from external customers presented in the table above, £6,309 million (2024: £5,895 million) is attributable to

customers in the United Kingdom (‘UK’) and £275 million (2024: £271 million) to the rest of the world. No revenue transaction with

a single customer external to the Group amounts to greater than 10% of the Group’s revenue.

The Group has total non-current assets (other than financial assets, deferred tax assets, pension schemes and rights arising under

insurance contracts) of £4,390 million (2024: £4,325 million) located in the UK and £350 million (2024: £274 million) located in the rest

of the world.

214 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

B2. Investment return variances and economic assumption changes

The long-term nature of much of the Group’s operations means that, for internal performance management, the effects of

short-term economic volatility are treated as non-operating items. The Group focuses instead on an adjusted operating profit

measure that incorporates an expected return on investments supporting its long-term business. The accounting policy adopted in

the calculation of adjusted operating profit is detailed in note B1. The methodology for the determination of the expected

investment return is explained below together with an analysis of investment return variances and economic assumption changes

recognised outside of adjusted operating profit.

B2.1 Calculation of the long-term investment return

Adjusted operating profit for life assurance business is based on expected investment returns on financial investments backing

shareholder, annuity, other non-profit business, with-profits funds receiving shareholder support and surplus assets, with allowance

for the corresponding movements in liabilities.

The methodology to determine the expected investment returns on financial investments uses the 1-year risk-free rate for deriving

the expected investment return assumption on assets backing the insurance contract liabilities to reduce unintended economic

volatility as set out in note B1.

During the period the Group has refined the process used to segment the expected investment return on surplus assets, which is a

component of adjusted operating profit. Previously, expected investment return was allocated on a top-down basis whereas for the

current period the segmentation of expected investment return has been built up from a more granular fund-based segmentation of

the underlying investment assets.

The Group has assessed that this refinement is a change in estimate and as such the Group has not restated comparatives. The result

of this refinement in the current period results is an increase to the adjusted operating profit in the pensions and savings segment of

£40 million offset by a corresponding decrease of £28 million in retirement solutions and of £12 million in Europe and Other. This

refinement has not impacted total expected investment return.

The long-term risk-free rate used as the basis for deriving the long-term investment return is consistent with that set out in note

F9.2.1 at the 1-year duration for assets backing the insurance contract liabilities and surplus cash assets, and at the 15-year duration

for surplus non-cash assets.

A risk premium of 380 bps is added to the risk-free yield for equities (2024: 400 bps) and 160 bps for debt securities (2024: 170 bps).

The principal assumptions underlying the calculation of the long-term investment return for surplus assets are:

	2025	2024
	%	%
Equities	8.0	7.4
Debt securities	5.8	5.1

B2.2 Life assurance business

The economic variances excluded from the long-term business operating profit are as follows:

	2025	2024
	£m	£m
Economic variances	(604)	(1,297)

The net adverse economic variances of £604 million (2024: £1,297 million adverse) have primarily arisen as a result of rising global

equity markets and a decrease in inflation expectations. Movements in equity markets and inflation are hedged to protect our

Solvency II surplus from volatility, but our IFRS balance sheet is, in effect, ‘over-hedged’ as it does not recognise the additional Solvency

II balance sheet items such as future profits on investment contracts measured under IFRS 9 and the Solvency Capital Requirements.

B3. Earnings per share

The Group calculates its basic earnings per share based on the present shares in issue using the earnings attributable to ordinary

equity holders of the parent, divided by the weighted average number of ordinary shares in issue during the year.

Diluted earnings per share are calculated based on the potential future shares in issue assuming the conversion of all potentially

dilutive ordinary shares. The weighted average number of ordinary shares in issue is adjusted to assume conversion of dilutive

share awards granted to employees.

The basic and diluted earnings per share calculations are also presented based on the Group's adjusted operating earnings net of

financing costs. Adjusted operating profit is a non-GAAP performance measure that is considered to provide a comparable

measure of the underlying performance of the business as it excludes the impact of short-term economic volatility, one-off items

and certain other items.

B. Earnings performance continued

215Annual Report and Accounts 2025

Financials

Standard Life plc

The result attributable to ordinary equity holders of the parent for the purposes of determining earnings per share has been

calculated as set out below.

			Adjusted
			operating	Other
	Adjusted	Financing	earnings net of	non-operating
	operating profit	costs	financing costs	items	Total
2025	£m	£m	£m	£m	£m
Profit/(loss) before the tax attributable to owners	945	(193)	752	(1,184)	(432)
Tax (charge)/credit attributable to owners	(227)	48	(179)	217	38
Profit/(loss) for the year attributable to owners	718	(145)	573	(967)	(394)
Coupon paid on Tier 1 notes	–	(29)	(29)	–	(29)
Deduct: Share of result attributable to non-controlling interests	–	–	–	(49)	(49)
Profit/(loss) for the year attributable to ordinary
equity holders of the parent	718	(174)	544	(1,016)	(472)

			Adjusted
			operating	Other
	Adjusted		earnings net of	non-operating
	operating profit	Financing costs	financing costs	items	Total
2024	£m	£m	£m	£m	£m
Profit/(loss) before the tax attributable to owners	825	(204)	621	(2,075)	(1,454)
Tax (charge)/credit attributable to owners	(188)	51	(137)	513	376
Profit/(loss) for the year attributable to owners	637	(153)	484	(1,562)	(1,078)
Coupon paid on Tier 1 notes	–	(29)	(29)	–	(29)
Deduct: Share of result attributable to non-controlling interests	–	–	–	(12)	(12)
Profit/(loss) for the year attributable to ordinary equity holders of the parent	637	(182)	455	(1,574)	(1,119)

The weighted average number of ordinary shares outstanding during the period is calculated as follows:

	2025	2024
	Number	Number
	million	million
Issued ordinary shares at beginning of the year	1,003	1,002
Effect of ordinary shares issued	1	–
Effect of non-contingently issuable shares in respect of Group's long-term incentive plan	–	1
Own shares held by the employee benefit trust	(3)	(2)
Weighted average number of ordinary shares	1,001	1,001

The diluted weighted average number of ordinary shares outstanding during the period is 1,008 million (2024: 1,005 million). The

Group’s Long Term Incentive Plan, Deferred Bonus Share Scheme and ShareSave schemes increased the weighted average number

of shares on a diluted basis by 6,681,087 shares for the year ended 31 December 2025 (2024: 4,318,665 shares). As losses have an

anti-dilutive effect, none of the share-based awards had a dilutive effect in the calculation of basic earnings per share for either the

year ended 31 December 2024 or 31 December 2025.

Earnings per share disclosures are as follows:

	2025	2024
	pence	pence
Basic earnings per share	(47.1)	(111.8)
Diluted earnings per share	(47.1)	(111.8)
Basic adjusted operating earnings net of financing costs per share	54.3	45.4
Diluted adjusted operating earnings net of financing costs per share	54.0	45.3

B4. Dividends on ordinary shares

Final dividends on ordinary shares are recognised as a liability and deducted from equity when they are approved by the Group’s

owners. Interim dividends are deducted from equity when they are paid.

Dividends for the year that are approved after the reporting period are dealt with as an event after the reporting period. Declared

dividends are those that are appropriately authorised and are no longer at the discretion of the entity.

	2025	2024
	£m	£m
Dividends declared and paid in the year	548	533

216 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

On 16 March 2025, the Board recommended a final dividend of 27.35p per share in respect of the year ended 31 December 2024.

The dividend was approved at the Group’s Annual General Meeting, which was held on 13 May 2025. The dividend amounted to

£274 million and was paid on 21 May 2025.

On 5 September 2025, the Board declared an interim dividend of 27.35p per share for the half year ended 30 June 2025. The dividend

amounted to £274 million and was paid on 30 October 2025.

C. Other Income Statement notes

C1. Insurance revenue

The Group’s insurance revenue reflects the provision of services arising from a group of insurance contracts at an amount that

reflects the consideration to which the Group expects to be entitled in exchange for those services. Insurance revenue from a group

of insurance contracts is therefore the relevant portion for the period of the total consideration for the contracts, (i.e. the amount

of premiums paid to the Group adjusted for financing effect (the time value of money) and excluding any investment components).

The total consideration for a group of contracts covers amounts related to the provision of services and is comprised of:

• the release of the CSM;

• changes in the risk adjustment for non-financial risk relating to current services;

• claims and other insurance service expenses incurred in the period, generally measured at the amounts expected at the

beginning of the period;

• insurance acquisition cash flows recovery which is determined by allocating the portion of premiums related to the recovery of

those cash flows on the basis of the passage of time over the expected coverage of a group of contracts; and

• other amounts, including any other pre-recognition cash flow assets derecognised at the date of initial recognition.

The amount of the CSM of a group of insurance contracts that is recognised as insurance revenue in each year is determined by

identifying the coverage units in the group, allocating the CSM remaining at the end of the year equally to each coverage unit

provided in the year and expected to be provided in future years, and recognising in profit or loss the amount of the CSM allocated

to coverage units provided in the year.

The number of coverage units in a group is the quantity of service provided by the contracts in the group, determined by

considering for each contract the quantity of benefits provided under a contract and its expected coverage period. The coverage

units are reviewed and updated at each reporting date.

The Group consider the following when determining coverage units:

• the quantity of benefits provided by contracts in the group;

• the expected coverage period of contracts in the group;

• the likelihood of insured events occurring, only to the extent that they affect the expected coverage period of contracts in the group;

• for insurance contracts without direct participation features, the generation of an investment return for the policyholder, if

applicable (investment-return service); and

• for insurance contracts with direct participation features, the management of underlying items on behalf of the policyholder

(investment-related service).

The coverage units for groups of reinsurance contracts held are determined based on the quantity of coverage provided by the

reinsurance contracts held in the group but not the coverage provided by the insurer to its policyholders through the underlying

insurance contracts. However, where the reinsurance held is a 100% quota share arrangement, it is expected that the coverage

units would be consistent with the underlying insurance contracts. Where there is a change to the fulfilment cash flows of the

group of underlying policies that does not adjust the CSM, it also would not adjust the CSM of the group of reinsurance contracts.

	Retirement	Pensions &
	Solutions	Savings	With-Profits	Europe & Other	Total
2025	£m	£m	£m	£m	£m
Amounts relating to changes in liabilities for remaining coverage:
CSM recognised in period for services provided	323	33	45	44	445
Change in risk adjustment for non-financial risk	82	9	6	20	117
Expected claims and other insurance service expenses	3,961	195	246	463	4,865
Expected policyholder tax charges	–	32	30	4	66
Amounts relating to recovery of insurance acquisition cash flows	7	–	–	12	19
Insurance revenue	4,373	269	327	543	5,512
Comprising contracts measured using:
Fair value approach at transition	1,760	230	316	390	2,696
Fully retrospective approach at transition and new contracts	2,613	39	11	153	2,816

B. Earnings performance continued

B4. Dividends on ordinary shares continued

217Annual Report and Accounts 2025

Financials

Standard Life plc

	Retirement	Pensions &
	Solutions	Savings	With-Profits	Europe & Other	Total
2024	£m	£m	£m	£m	£m
Amounts relating to changes in liabilities for remaining coverage:
CSM recognised in period for services provided	278	36	74	56	444
Change in risk adjustment for non-financial risk	71	11	6	15	103
Expected claims and other insurance service expenses	3,568	194	262	487	4,511
Expected policyholder tax charges	–	33	36	–	69
Amounts relating to recovery of insurance acquisition cash flows	1	–	–	11	12
Insurance revenue	3,918	274	378	569	5,139
Comprising contracts measured using:
Fair value approach at transition	1,846	271	358	427	2,902
Fully retrospective approach at transition and new contracts	2,072	3	20	142	2,237

C2. Fees and commissions

Fees related to the provision of investment management services and administration services are recognised as services are

provided. Front end fees, which are charged at the inception of service contracts, are deferred as a liability and recognised over the

life of the contract. No significant judgements are required in determining the timing or amount of fee income or the costs

incurred to obtain or fulfil a contract.

Fee income from investment contracts without DPF does not include amounts related to policyholder tax. Policyholder tax is

collected through adjustments to unit prices and is therefore reflected in change in investment contract liabilities. The table below

disaggregates fees and commissions by segment.

2025

	Pensions &
	Savings	With-Profits	Europe & Other	Total
	£m	£m	£m	£m
Fee income from investment contracts without DPF	906	52	83	1,041
Initial fees deferred during the year and subsequent
amortisation of deferred income	–	–	(8)	(8)
Revenue from investment contracts without DPF	906	52	75	1,033
Other revenue from contracts with customers	9	–	30	39
Fees and commissions	915	52	105	1,072

2024

	Pensions &
	Savings	With-Profits	Europe & Other	Total
	£m	£m	£m	£m
Fee income from investment contracts without DPF	877	51	63	991
Initial fees deferred during the year and subsequent
amortisation of deferred income	–	–	(8)	(8)
Revenue from investment contracts without DPF	877	51	55	983
Other revenue from contracts with customers	9	–	35	44
Fees and commissions	886	51	90	1,027

Fee or commission income for the Retirement Solutions segment was £nil in both periods presented.

Remaining performance obligations

The practical expedient under IFRS 15 Revenue from Contracts with Customers has been applied and remaining performance

obligations are not disclosed as the Group has the right to consideration from customers in amounts that correspond with the

performance completed to date. Specifically management charges become due over time in proportion to the Group’s provision

of investment management services.

In the period, no amortisation or impairment losses from contracts with customers were recognised in the consolidated

income statement.

218 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

C3. Net investment income

Net investment income comprises interest, dividends, rents receivable, net interest income/(expense) on the Group defined

benefit pension scheme asset/(liability), fair value gains and losses on financial assets (except for reinsurers’ share of investment

contract liabilities without DPF, see note E1), financial liabilities and investment property at fair value and impairment losses on

loans and receivables.

Interest income is recognised in the consolidated income statement as it accrues using the effective interest method.

Dividend income is recognised in the consolidated income statement on the date the right to receive payment is established, which

in the case of listed securities is the ex-dividend date.

Rental income from investment property is recognised in the consolidated income statement on a straight-line basis over the term

of the lease. Lease incentives granted are recognised as an integral part of the total rental income.

Fair value gains and losses on financial assets and financial liabilities designated at fair value through profit or loss are recognised

in the consolidated income statement. Fair value gains and losses includes both realised and unrealised gains and losses.

	2025	2024
	£m	£m
Investment income
Interest income on financial assets at amortised cost	3	31
Interest income on financial assets at FVTPL	4,338	4,363
Dividend income	7,260	6,403
Rental income	267	329
Net interest expense on Group defined benefit pension scheme liability/asset	(60)	(56)
	11,808	11,070
Fair value gains/(losses)
Financial assets and financial liabilities at FVTPL	18,843	7,882
Investment property	11	(100)
	18,854	7,782
Net investment income	30,662	18,852

C4. Net finance expense from insurance contracts

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

the effects of the time value of money, financial risk and changes therein, unless any such changes for groups of direct participating

contracts are allocated to a loss component and included in insurance service expenses. They include changes in the measurement

of groups of contracts caused by changes in the value of underlying items. The Group presents insurance finance income or

expenses in profit or loss.

	Retirement	Pensions &
	Solutions	Savings	With-Profits	Europe & Other	Total
	£m	£m	£m	£m	£m
Insurance contracts issued
Changes in fair value of underlying items
of direct participating contracts	–	(1,812)	(1,402)	(552)	(3,766)
Group's share of changes in fair value of underlying items
or fulfilment cash flows that do not adjust the CSM	–	6	–	–	6
Unwind of discount on fulfilment cash flows	(2,347)	(964)	(1,151)	(752)	(5,214)
Interest accreted on the CSM	(113)	–	(9)	(3)	(125)
Effect of changes in interest rates and other financial assumptions	602	(3)	33	103	735
Insurance finance expense	(1,858)	(2,773)	(2,529)	(1,204)	(8,364)
Reinsurance contracts held
Unwind of discount on fulfilment cash flows	111	–	42	16	169
Interest accreted on the CSM	52	–	3	1	56
Effect of changes in interest rates and other financial assumptions	(159)	2	(25)	(15)	(197)
Reinsurance finance income	4	2	20	2	28
Net insurance finance expense	(1,854)	(2,771)	(2,509)	(1,202)	(8,336)

C. Other Income Statement notes continued

219Annual Report and Accounts 2025

Financials

Standard Life plc

	Retirement	Pensions &
	Solutions	Savings	With-Profits	Europe & Other	Total
2024	£m	£m	£m	£m	£m
Insurance contracts issued
Changes in fair value of underlying items
of direct participating contracts	–	(773)	(265)	(682)	(1,720)
Group's share of changes in fair value of underlying items
or fulfilment cash flows that do not adjust the CSM	–	14	–	–	14
Unwind of discount on fulfilment cash flows	(2,359)	(964)	(1,342)	(890)	(5,555)
Interest accreted on the CSM	(102)	–	(10)	(5)	(117)
Effect of changes in interest rates and other financial assumptions	2,997	1	495	229	3,722
Insurance finance income/(expense)	536	(1,722)	(1,122)	(1,348)	(3,656)
Reinsurance contracts held
Unwind of discount on fulfilment cash flows	296	–	50	19	365
Interest accreted on the CSM	45	–	3	1	49
Effect of changes in interest rates and other financial assumptions	(336)	–	(71)	(116)	(523)
Reinsurance finance income/(expense)	5	–	(18)	(96)	(109)
Net insurance finance income/(expense)	541	(1,722)	(1,140)	(1,444)	(3,765)

There is a close relationship between the net investment income in note C3, as it relates to assets backing contracts within the scope

of IFRS 17, and net insurance finance (expense)/income. Net investment income includes the results for all investment assets

including those backing investment contracts and surplus assets.

For Retirement Solutions the principal product is annuities. The insurance finance (expense)/income primarily reflects the unwind

of the discount rate on the liabilities. This is largely offset by the interest income earned, included within net investment income,

on the assets backing the annuity contracts which primarily consist of debt securities and equity release mortgages. Changes in the

discount rates used to discount the annuity cash flows in the measurement of the insurance contract liabilities are largely offset by

changes in the fair value of the backing assets, included in net investment income, in respect of the best estimate liability (‘BEL’)

and risk adjustment.

Mismatches between net investment income and insurance finance expense arises for the following reasons:

• the annuity business within the Retirement Solutions segment uses the General Model for measurement. As a result, the

contractual service margin (‘CSM’) is measured using discount rates locked in at inception, whereas the assets backing the CSM are

based on current economic assumptions;

• the discount rate for annuity business uses a reference portfolio constructed in line with the Group’s investment strategy as set

out in Note F9.2.1, and therefore insurance finance expenses are impacted by changes to the asset mix within this reference

portfolio. Net investment income is determined with reference to the actual assets held by the Group during the reporting period;

• changes in non-economic assumptions for General Model business impacts BEL and risk adjustment using current discount rates

and CSM using locked in discount rates. This gives rise to a mismatch for which there is no corresponding item within net

investment income;

For Pensions & Savings the principal products are unit-linked and hybrid contracts, which contain an element of unit-linked and

unitised with-profits within a single contract. These contracts are measured primarily using the variable fee approach (‘VFA’) as the

amounts payable to policyholders reflect a substantial share of the fair value returns on the backing assets. As a result, the change in

fair value of underlying items within insurance finance (expense)/income will be closely matched by changes in the value of backing

assets which are also measured at fair value.

The unwind of discount rate on cash flows within insurance finance (expenses)/income is offset by the investment income recognised

in respect of backing assets. The discount rate used for BEL and risk adjustment is determined on a bottom-up basis, as set out in

note F9.2.1, based on the liquidity characteristics of the liabilities rather than with reference to the backing assets and therefore a

mismatch occurs.

220 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

For With-Profits business there are differing impacts dependent on the nature of the liabilities within the fund. For with-profits

business without guarantees, the relationship between net investment income and insurance finance (expense)/income will be

consistent with that for the business within Pensions & Savings. In respect of guarantees, the value of these is typically influenced by

changes in interest rates. The Group hedges its interest rate risk in respect of these guarantees with derivatives such that the effect

of changes in interest rates on guarantees within insurance finance (expense)/income are largely offset by changes in the fair value

of the derivatives used for hedging in net investment income.

For non-profit business in a with-profits fund where profits from these contracts accrue to the with-profits policyholders or to the

with-profits fund estate, the non-profit contracts and their backing assets are considered to be an underlying item of the with-

profits contracts and therefore changes in their fair value are included within insurance finance (expense)/income.

The non-profit contracts will be measured based on their substance. For non-profit annuities which fall within the scope of IFRS 17

they are measured using the IFRS 17 General Model and the treatment of the non-profit contract is consistent with the non-profit

annuities within the Retirement Solutions segment. The effect of these non-profit annuities on the income statement, does not

match the change in fair value measurement used to measure their effect on the with-profits policyholders and therefore a

mismatch arises. For unit-linked business which falls within the scope of IFRS 9 the liabilities are measured in line with the Group’s

accounting policy for investment contracts with movements being taken through ‘change in investment contract liabilities’.

Movements in the related assets which are reflected in net investment income largely match the movements in the liabilities. The

assets backing the non-profit business in the with-profits fund are typically measured at fair value with investment income and

changes in fair value being included within net investment income.

The Europe & Other segment contains business consistent with that in the segments noted above and will mirror the relationships

between net investment income and insurance finance (expense)/income as noted above for the relevant type of business. In addition,

this segment contains protection business which uses a bottom-up discount rate based on the liability characteristics rather than being

based on the backing assets, which leads to mismatches between net investment income and insurance finance (expenses)/income.

C5. Expenses

Insurance service expenses

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

They exclude repayments of investment components and comprise the following items:

• adjustment to liabilities for incurred claims and benefits, excluding investment components reduced by loss

component allocations;

• other incurred directly attributable expenses, including amounts of any other pre-recognition cash flows assets

(other than insurance acquisition cash flows) derecognised at the date of initial recognition;

• insurance acquisition cash flows amortisation;

• insurance acquisition cash flows assets impairment; and

• reversal of impairment of assets for insurance acquisition cash flows.

Net income or expense from reinsurance contracts held

Income and expenses from reinsurance contracts are presented separately from income and expenses from insurance contracts.

Income and expenses from reinsurance contracts, other than insurance finance income or expenses, are presented on a net basis

as ‘net expenses from reinsurance contracts’ in the insurance service result.

Net expenses from reinsurance contracts comprise an allocation of reinsurance premiums paid less amounts recovered

from reinsurers.

The Group recognises an allocation of reinsurance premiums paid in profit or loss as it receives services under groups of

reinsurance contracts. The allocation of reinsurance premiums paid relating to services received for each period represents the

total of the changes in the asset for remaining coverage that relates to services for which the Group expects to pay consideration.

Administrative expenses

Administrative expenses are recognised in the consolidated income statement as incurred.

C. Other Income Statement notes continued

C4. Net finance expense from insurance contracts continued

221Annual Report and Accounts 2025

Financials

Standard Life plc

Total expenses are analysed by expenses type as follows:

	2025	2024
	£m	£m
Claims and benefits net of reinsurance contracts 1	1,304	1,458
Reversal of losses on onerous insurance contracts	(63)	(30)
Cost of retroactive cover on reinsurance contracts held	2	5
Employee costs	721	750
Outsourcer expenses	436	368
Professional fees	209	285
Temporary staff costs	96	143
Audit fees	29	26
Commission expenses	158	161
Office and IT costs	276	280
Investment management expenses and transaction costs	378	388
Direct costs of collective investment schemes	25	25
Depreciation	17	21
Pension administrative expenses	11	17
Advertising and sponsorship	49	58
Loss on completion of buy-out of PGL Pension Scheme liabilities (see note B1.1)	–	208
Regulatory fees	10	18
Other	93	65
	3,751	4,246
Acquisition costs deferred during the year	(28)	(29)
Amortisation of deferred acquisition costs	12	9
Amounts attributed to insurance acquisition cash flows incurred during the year	(180)	(179)
Amortisation of insurance acquisition cash flows	19	12
Total expenses	3,574	4,059
Reported within:
Insurance service expenses	4,743	4,493
Net expenses from reinsurance contracts 2	(2,710)	(2,259)
Administrative expenses	1,541	1,825
Total expenses	3,574	4,059

1 Claims and benefits are presented net of reinsurance recovery but stated gross in the consolidated income statement.

2 Reported as part of the ‘Net expenses from reinsurance contracts’ balance in the consolidated income statement.

	Employee costs comprise: 2025	2024
	£m	£m
Wages and salaries	643	677
Social security contributions	78	73
	721	750

	2025	2024
	Number	Number
Average number of persons employed	6,449	7,505

C6. Auditor’s remuneration

During the year the Group obtained the following services from its auditor at costs as detailed in the table below.

	2025	2024
	£m	£m
Audit of the consolidated financial statements	8.7	7.5
Audit of the Company’s subsidiaries	16.4	14.9
Total fee for audit services	25.1	22.4
Audit-related assurance services	3.3	3.0
Other assurance services	0.6	0.2
Total fee for assurance services	3.9	3.2
Total auditor’s remuneration	29.0	25.6

No services were provided by the Company’s auditors to the Group’s pension schemes in either 2025 or 2024.

222 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

Audit scope changes are finalised following the completion of the audit and recognised when agreed. The 2025 audit fee includes

£2.3 million (2024: £nil) relating to the previous year’s audit.

Audit-related assurance services include fees payable for services where the reporting is required by law or regulation to be provided

by an auditor, such as reporting on regulatory returns. It also includes fees payable in respect of reviews of interim financial

information and services where the work is integrated with the audit itself.

Other assurance services include fees payable in respect of comfort letters, reporting on ESG and sustainability and internal control

assurance services.

Further information on auditor’s remuneration and the assessment of the independence of the external auditor is set out in the

Audit Committee report on pages 120 to 126.

C7. Finance costs

Interest payable is recognised in the consolidated income statement as it accrues and is calculated using the effective interest method.

	2025	2024
	£m	£m
Interest expense
On financial liabilities at amortised cost	264	288
On leases	2	2
	266	290
Attributable to:
– policyholders	52	68
– owners	214	222
	266	290

C8. Tax charge

Income tax comprises current and deferred tax. Income tax is recognised in the consolidated income statement except to the

extent that it relates to items recognised in the statement of consolidated comprehensive income or the statement of

consolidated changes in equity, in which case it is recognised in these statements.

Current tax is the expected tax payable on the taxable income for the year, using tax rates and laws enacted or substantively enacted

at the date of the statement of consolidated financial position together with adjustments to tax payable in respect of previous years.

The tax charge is analysed between tax that is payable in respect of policyholders’ returns and tax that is payable on owners’ returns.

C8.1 Current year tax charge

	2025	2024
	£m	£m
Current tax:
UK corporation tax	110	42
Overseas tax	88	92
	198	134
Adjustment in respect of prior years	103	(6)
Total current tax charge	301	128
Deferred tax:
Origination and reversal of temporary differences	168	(154)
Change in the rate of UK corporation tax	–	1
Adjustment in respect of prior years	(55)	(4)
Total deferred tax charge/(credit)	113	(157)
Total tax charge/(credit)	414	(29)
Attributable to:
– policyholders	452	347
– owners	(38)	(376)
Total tax charge/(credit)	414	(29)

The Group, as a proxy for policyholders in the UK, is required to pay taxes on investment income and gains each year. Accordingly, the

tax credit or expense attributable to UK life assurance policyholder earnings is included in income tax expense. The tax charge

attributable to policyholder earnings was £452 million (2024: £347 million charge).

C. Other Income Statement notes continued

C6. Auditor’s remuneration continued

223Annual Report and Accounts 2025

Financials

Standard Life plc

The net of the above prior year tax adjustments of £48 million primarily arises due to a Court of Appeal ruling in 2025. The Group in

conjunction with a number of other companies challenged HMRC’s position on the corporation tax treatment of overseas portfolio

dividends from companies resident in the EU (‘EU dividends') using a Group Litigation Order (‘GLO’). The issue relates to whether the

UK tax rules, which taxed EU dividends received prior to 1 July 2009, was contrary to EU law given that dividends received from UK

companies were exempt from tax. In 2009 UK tax law was changed with both overseas and UK dividends being treated as exempt

from corporation tax. The Court of Appeal ruled in favour of HMRC in 2025 based on a procedural point concerning the validity of

claims made by taxpayers for double tax relief. Accordingly the tax receivable and the associated amount payable to policyholders

were derecognised in the period.

C8.2 Tax (credited)/charged to other comprehensive income

	2025	2024
	£m	£m
Current tax (credit)/charge	(5)	4
Deferred tax credit on exchange differences on translation of foreign operations	(8)	–
Deferred tax charge on defined benefit schemes	12	32
Total tax (credited)/charged to other comprehensive income	(1)	36

C8.3 Tax credited to equity

	2025	2024
	£m	£m
Deferred tax credit on share schemes	(6)	–
Total tax credit	(6)	–

C8.4 Reconciliation of tax charge

	2025	2024
	£m	£m
Profit/(loss) for the year before tax	20	(1,107)
Policyholder tax charge	(452)	(347)
Loss before the tax attributable to owners	(432)	(1,454)
Tax credit at standard UK rate of 25% (2024:25%) 1	(108)	(364)
Disallowable expenses	5	4
Prior year tax charge/(credit) for shareholders 2	22	(67)
Movement on acquired in-force amortisation at rates other than 25% (2024: 25%)	9	10
Profits taxed at rates other than 25% (2024: 25%) 3	53	51
Recognition of previously unrecognised deferred tax assets 4	(19)	(14)
Other	–	4
Owners’ tax credit	(38)	(376)
Policyholder tax charge	452	347
Total tax charge/(credit) for the year	414	(29)

1 The Standard Life operating segments are predominantly in the UK. The reconciliation of tax charge has therefore, been completed by reference to the standard rate of UK tax.

2 The prior year tax charge/(credit) relates principally to true-ups between group reporting and statutory reporting and reassessment of tax provisions.

3 Profits taxed at rates other than 25% relates to overseas profits, consolidated fund investments and UK life company profits subject to marginal shareholder tax rates.

4 Relates principally to reassessment of deferred tax assets recognition relating to losses.

D. Equity

D1. Share Capital

The Group has issued ordinary shares which are classified as equity. Incremental external costs that are directly attributable to the

issue of these shares are recognised in equity, net of tax.

	2025	2024
	£m	£m
Issued and fully paid:
1,006.3 million ordinary shares of £0.10 each (2024: 1,003.1 million)	101	100

The holders of ordinary shares are entitled to one vote per share on matters to be voted on by owners and to receive such dividends,

if any, as may be declared by the Board of Directors in its discretion out of legally available profits.

Movements in issued share capital during the year:

	2025	2025	2024	2024
	Number	£	Number	£
Shares in issue at 1 January	1,003,111,838	100,311,183	1,001,538,419	100,153,841
Ordinary shares issued in the year	3,140,405	314,041	1,573,419	157,342
Shares in issue at 31 December	1,006,252,243	100,625,224	1,003,111,838	100,311,183

224 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

During the year, the Company issued 3,140,405 shares (2024: 1,573,419) with a total share premium of £4 million (2024: £nil) in order

to satisfy obligations to employees under the Group’s share schemes (see note I1). This included 2,200,000 shares (2024: 1,500,000)

that were issued to the Group’s Employee Benefit Trust at nominal value.

D2. Shares held by the employee benefit trust

Where the Phoenix Group Employee Benefit Trust (‘EBT’) acquires shares in the Company or obtains rights to purchase its shares,

the consideration paid (including any attributable transaction costs, net of tax) is shown as a deduction from owners’ equity. Gains

and losses on sales of shares held by the EBT are charged or credited to the own shares account in equity.

The EBT holds shares to satisfy awards granted to employees under the Group’s share-based payment schemes.

	2025	2024
	£m	£m
At 1 January	18	15
Shares acquired or subscribed for by the EBT	9	16
Shares awarded to employees by the EBT	(13)	(13)
At 31 December	14	18

During the year 3,746,751 (2024: 2,267,832) shares were awarded to employees by the EBT, 1,367,221 (2024: 2,994,854) shares were

purchased on market and a further 2,200,000 (2024: 1,500,000) shares were issued to the EBT by the Company. The number of shares

held by the EBT at 31 December 2025 was 4,674,432 (2024: 4,853,962).

The Company provided the EBT with an interest-free non-recourse facility arrangement to enable it to purchase the shares.

D3. Other Reserves

The other reserves comprise the cash flow hedging reserve, merger relief reserve and the owner-occupied property

revaluation reserve.

Cash flow hedging reserve

Where a cash flow hedging relationship exists, the effective portion of changes in the fair value of derivatives that are designated

and qualify as cash flow hedges is recognised in other comprehensive income and accumulated under the heading of cash flow

hedging reserve. The gain or loss relating to the ineffective portion is recognised immediately in the consolidated income

statement and is reported in net investment income.

Amounts previously recognised in other comprehensive income and accumulated in equity are reclassified to profit or loss in the

periods when the hedged item affects profit or loss, in the same line as the recognised hedged item.

Hedge accounting is discontinued when the Group revokes the hedging relationship, when the hedging instrument expires or is

sold, terminated, or exercised, or when it no longer qualifies for hedge accounting. Any gain or loss recognised in other

comprehensive income and accumulated in equity at that time is recycled to profit or loss over the period the hedged item impacts

profit or loss or immediately where the hedged future cash flows are no longer expected to occur.

Further details of the Group’s hedge accounting policy are included in note E1.

Merger relief reserve

A merger relief reserve is created when the Company issues shares to secure at least a 90% equity holding in an acquired company

and applies the merger relief in section 612 of the Companies Act 2006. The difference between the value of the shares issued as

consideration and the nominal value of the shares issued is presented in a merger relief reserve as opposed to in share premium.

It is not a distributable reserve, as it represents an unrealised profit that is not part of the Company's capital, but may become

distributable, for example, if the Company’s investment in the acquired entity is written down for impairment.

The merger relief reserve arose upon the issuance of equity shares in 2020 as part consideration for the acquisition of the entire

share capital of ReAssure Group Limited (formerly ReAssure Group plc). The Group applied the relief in section 612 of the

Companies Act 2006 to present the difference between the value of the shares issued as consideration and the nominal value of

the shares issued of £1,819 million in a merger relief reserve as opposed to in share premium.

Owner-occupied property revaluation reserve

This reserve comprises the revaluation surplus arising on revaluation of owner-occupied property. When a revaluation loss arises on

a previously revalued asset it should be deducted first against the previous revaluation gain. Any excess impairment will then be

recorded as an impairment expense in the consolidated income statement.

D. Equity continued

D1. Share Capital continued

225Annual Report and Accounts 2025

Financials

Standard Life plc

		2025				2024
					Owner-oc-
					cupied
	Merger	Cash flow	Total	Merger	property	Cash flow
	relief	hedging	other	relief	revaluation	hedging	Total other
	reserve	reserve	reserves	reserve	reserve	reserve	reserves
	£m	£m	£m	£m	£m	£m	£m
At 1 January	593	23	616	1,819	2	14	1,835
Other comprehensive (expense)/income for the year	–	(22)	(22)	–	(2)	9	7
Transfer to retained earnings	–	–	–	(1,226)	–	–	(1,226)
At 31 December	593	1	594	593	–	23	616

During 2024, £1,226 million of the merger relief reserve was transferred to retained earnings following the impairment of the

Company’s investment in the ReAssure group of companies as a result of the distribution of dividends to the Company.

The Group has in place a number of cross currency swaps which have been designated as hedging instruments in order to effect cash

flow hedges of the Group’s Euro and US Dollar denominated borrowings.

On 4 February 2025, the Company redeemed the remaining US $250 million of the US $750 million Perpetual Contingent Convertible

Tier 1 notes leading to an unwinding of the US $250 million related swap arrangement.

On 12 June 2024, the Company issued US $500 million Perpetual Contingent Convertible Tier 1 notes and the cross currency swap

that was entered into at this time was designated as a hedging instrument. On 18 June 2024, US $500 million of the US $750 million

Perpetual Contingent Convertible Tier 1 notes were repurchased via a tender offer, leading to an unwinding of US $500 million of the

related swap arrangement, which was then treated as a partial discontinuance.

Hedge accounting has been adopted effective from the date of designation of the hedging relationships. The objective of the

hedging relationships is to hedge the risk of variability in functional currency equivalent cash flows with the foreign currency

denominated borrowings due to changes in forward rates. The hedge ratio (i.e. the relationship between the quantity of the hedging

instrument and the quantity of the hedged item in terms of their relative weighting) is such that there is an exact match in the

relative weightings of the hedged items and hedging instruments within each of the hedging relationships.

D4. Tier 1 notes

An equity instrument is a contract that evidences a residual interest in the assets of an entity after deducting all its liabilities.

Accordingly, a financial instrument is treated as equity if:

• there is no contractual obligation to deliver cash or other financial assets or to exchange financial assets or liabilities on terms

that may be unfavourable; and

• the instrument is a non-derivative that contains no contractual obligation to deliver a variable number of shares or is a derivative

that will be settled only by the Group exchanging a fixed amount of cash or other assets for a fixed number of the Group’s own

equity instruments.

The Fixed Rate Reset Perpetual Restricted Tier 1 Contingent Convertible Notes (‘Tier 1 Notes’) meet the definition of equity and

accordingly are shown as a separate category within equity at the proceeds of issue. The coupons on the instruments are

recognised as distributions on the date of payment and are charged directly to the statement of consolidated changes in equity.

	2025	2024
	£m	£m
Tier 1 Notes	494	494

The Tier 1 Notes, which were issued on 26 April 2018, bear interest on their principal amount at a fixed rate of 5.75% per annum up to

the ‘First Call Date’ of 26 April 2028. Thereafter the fixed rate of interest will be reset on the First Call Date and on each fifth

anniversary of this date by reference to a 5-year gilt yield plus a margin of 4.169%. Interest is payable on the Tier 1 Notes semi-

annually in arrears on 26 October and 26 April. The coupon paid in the year was £29 million (2024: £29 million).

The Tier 1 Notes have no fixed maturity date and interest is payable only at the sole and absolute discretion of the Company;

accordingly the Tier 1 Notes meet the definition of equity for financial reporting purposes and are disclosed as such in the

consolidated financial statements. If an interest payment is not made, it is cancelled and it shall not accumulate or be payable at any

time thereafter.

The Tier 1 Notes may be redeemed at par on the First Call Date or on any interest payment date thereafter at the option of the

Company and also in other limited circumstances. In respect of any redemption or purchase of the Tier 1 Notes, such redemption or

purchase is subject to the receipt of permission to do so from the PRA.

On 27 October 2020, the terms of the Tier 1 Notes were amended and the consequence of a trigger event, linked to the Solvency II

capital position, was changed. Previously, the Tier 1 Notes were subject to a permanent write-down in value to zero. The amended

terms require that the Tier 1 Notes would automatically be subject to conversion to ordinary shares of the Company at the

conversion price of £1,000 per share, subject to adjustment in accordance with the terms and conditions of the notes and all accrued

and unpaid interest would be cancelled. Following any such conversion there would be no reinstatement of any part of the principal

amount of, or interest on, the Tier 1 Notes at any time.

226 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

D5. Non-controlling interests

Non-controlling interests are stated at the share of net assets attributed to the non-controlling interest holder at the time of

acquisition, adjusted for the relevant share of subsequent changes in equity.

	2025	2024
	£m	£m
At 1 January	539	549
Profit for the year	49	12
Dividends paid	(12)	(12)
Decrease in non-controlling interests	(22)	(10)
At 31 December	554	539

The non-controlling interests of £554 million (2024: £539 million) reflects third party ownership of Patria Private Equity Trust plc

(‘PPET’) determined at the proportionate value of the third party interest in the underlying assets and liabilities. PPET is a UK

Investment Trust listed and traded on the London Stock Exchange. As at 31 December 2025, the Group held 55.4% (2024: 54.3%)

of the issued share capital of PPET.

The Group’s interest in PPET is held in the with-profits and unit-linked funds of the Group’s life companies. Therefore, policyholders

bear the majority of the investment risk associated with PPET.

Summary financial information showing the interest that non-controlling interests have in the Group’s activities and cash flows

is shown below:

	2025	2024
PPET	£m	£m
Statement of financial position:
Financial assets	611	529
Other assets	20	56
Total assets	631	585
Total liabilities	77	46
Income statement:
Net income	62	23
Profit after tax	49	12
Comprehensive income	49	12
Cash flows:
Net increase in cash and cash equivalents	7	1

E. Financial assets & liabilities

E1. Fair values

Financial assets

Financial assets are to be classified into one of the following measurement categories: Fair value through profit or loss (‘FVTPL’),

fair value through other comprehensive income (‘FVOCI’) and amortised cost. Classification is made based on the objectives of the

entity’s business model for managing its financial assets and the contractual cash flow characteristics of the instruments.

Financial assets are measured at amortised cost where they have:

• contractual terms that give rise to cash flows on specified dates, that represent solely payments of principal and interest on the

principal amount outstanding; and

• are held within a business model whose objective is achieved by holding to collect contractual cash flows.

These financial assets are initially recognised at cost, being the fair value of the consideration paid for the acquisition of the

financial asset. All transaction costs directly attributable to the acquisition are also included in the cost of the financial asset.

Subsequent to initial recognition, these financial assets are carried at amortised cost, using the effective interest method.

Equities, debt securities, collective investment schemes, derivatives and certain loans and deposits are measured at FVTPL as they

are managed and evaluated on a fair value basis.

Purchases and sales of financial assets are recognised on the trade date, which is the date that the Group commits to purchase or

sell the asset.

D. Equity continued

227Annual Report and Accounts 2025

Financials

Standard Life plc

Where derivative financial instruments are held to hedge the Group’s Euro and US Dollar borrowings, and are designated as cash

flow hedges, the effective portion of any gain or loss that arises on remeasurement to fair value is initially recognised in other

comprehensive income and is recycled to profit or loss as the hedged item impacts the profit or loss. For such instruments, the

timing of the recognition of any gain or loss that arises on remeasurement to fair value in profit or loss depends on the nature of

the hedge relationship.

The Group has treaties in place with third party insurance companies to provide reinsurance in respect of liabilities that are linked

to the performance of funds maintained by those companies. The contracts in question do not transfer significant insurance risk

and therefore are classified as financial instruments and are valued at fair value through profit and loss. These contracts are

disclosed under Reinsurers’ share of investment contact liabilities.

Impairment of financial assets

The Group assesses the expected credit losses associated with its loans and deposits, receivables, cash and cash equivalents and

other financial assets carried at amortised cost. The measurement of credit impairment is based on an Expected Credit Loss (‘ECL’)

model and depends upon whether there has been a significant increase in credit risk.

For those credit exposures for which credit risk has not increased significantly since initial recognition, the Group measures loss

allowances at an amount equal to the total expected credit losses resulting from default events that are possible within 12 months

after the reporting date (‘12-month ECL’). For those credit exposures for which there has been a significant increase in credit risk

since initial recognition, the Group measures and recognises an allowance at an amount equal to the expected credit losses over

the remaining life of the exposure, irrespective of the timing of the default (‘Lifetime ECL’). If the financial asset becomes ‘credit-

impaired’ (following significant financial difficulty of issuer/borrower, or a default/breach of a covenant), the Group will recognise

a Lifetime ECL. ECLs are derived from unbiased and probability-weighted estimates of expected loss.

The loss allowance reduces the carrying value of the financial asset and is reassessed at each reporting date. ECLs and subsequent

remeasurements of the ECL, are recognised in the consolidated income statement.

Fair value estimation

The fair values of financial instruments traded in active markets such as publicly traded securities and derivatives are based on

quoted market prices at the period end. The quoted market price used for financial assets is the applicable bid price on the period

end date. The fair value of investments that are not traded in an active market is determined using valuation techniques such as

broker quotes, pricing models or discounted cash flow techniques. Where pricing models are used, inputs are based on market

related data at the period end. Where discounted cash flow techniques are used, estimated future cash flows are based on

contractual cash flows using current market conditions and market calibrated discount rates and interest rate assumptions for

similar instruments.

For units in unit trusts and shares in open-ended investment companies, fair value is determined by reference to published bid

values. The fair value of receivables and floating rate and overnight deposits with credit institutions is their carrying value. The fair

value of fixed interest-bearing deposits is estimated using discounted cash flow techniques.

Associates

Investments in associates that are held for investment purposes are accounted for under IFRS 9 Financial Instruments as permitted

by IAS 28 Investments in Associates and Joint Ventures. These are measured at fair value through profit or loss.

Derecognition of financial assets

A financial asset (or part of a group of similar financial assets) is derecognised where:

• the rights to receive cash flows from the asset have expired;

• the Group retains the right to receive cash flows from the assets, but has assumed an obligation to pay them in full without

material delay to a third party under a ‘pass-through’ arrangement; or

• the Group has transferred its rights to receive cash flows from the asset and has either transferred substantially all the risks and

rewards of the asset, or has neither transferred nor retained substantially all the risks and rewards of the asset, but has

transferred control of the asset.

Financial liabilities

On initial recognition, financial liabilities are recognised when due and measured at the fair value of the consideration received less

directly attributable transaction costs (with the exception of liabilities at FVTPL for which all transaction costs are expensed).

Subsequent to initial recognition, financial liabilities (except for liabilities under investment contracts without DPF and other

liabilities designated at FVTPL) are measured at amortised cost using the effective interest method.

Financial liabilities are designated upon initial recognition at FVTPL where doing so results in more meaningful information

because either:

• it eliminates or significantly reduces accounting mismatches that would otherwise arise from measuring assets or liabilities or

recognising the gains and losses on them on different bases; or

• a group of financial assets, financial liabilities or both is managed and its performance is evaluated and managed on a fair value

basis, in accordance with a documented risk management or investment strategy, and information about the investments is

provided internally on that basis to the Group’s key management personnel.

228 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

Investment contracts without DPF

Contracts under which the transfer of insurance risk to the Group from the policyholder is not significant are classified as

investment contracts and accounted for as financial liabilities.

Receipts and payments on investment contracts without DPF are accounted for using deposit accounting, under which the

amounts collected and paid out are recognised in the statement of consolidated financial position as an adjustment to the liability

to the policyholder.

Investment contracts without DPF are measured at fair value which is determined using a valuation technique to provide a reliable

estimate of the amount for which the liability could be transferred in an orderly transaction between market participants at the

measurement date, subject to a minimum equal to the surrender value. The valuation of liabilities on unit-linked contracts are held

at the fair value of the related assets and liabilities. The liability is the sum of the unit-linked liabilities plus an additional amount to

cover the present value of the excess of future policy costs over future charges.

Movements in the fair value of investment contracts without DPF and reinsurers’ share of investment contract liabilities are

included in Change in investment contract liabilities in the consolidated income statement.

Investment contract policyholders are charged for policy administration services, investment management services, surrenders and

other contract fees. These fees are recognised as revenue over the period in which the related services are performed. If the fees

are for services provided in future periods, they are deferred and recognised over those periods. ‘Front end’ fees are charged on

some non-participating investment contracts. Where the non-participating investment contract is measured at fair value, such fees

which relate to the provision of future investment management services are deferred and recognised as the services are provided.

Net asset value attributable to unitholders

The net asset value attributable to unitholders represents the non-controlling interest in collective investment schemes which

are consolidated by the Group. This interest is classified at FVTPL and measured at fair value, which is equal to the bid value of the

number of units of the collective investment scheme not owned by the Group.

Obligations for repayment of collateral received

It is the Group’s practice to obtain collateral in stock lending and derivative transactions, usually in the form of cash or marketable

securities. Where cash collateral received is available to the Group for investment purposes, it is recognised as a ‘financial asset’

and the collateral repayable is recognised as ‘obligations for repayment of collateral received’. The ‘obligations for repayment of

collateral received’ are measured at amortised cost, which in the case of cash is equivalent to the fair value of the consideration

received. Further details of the Group’s collateral arrangements are included in note E4.

Derecognition of financial liabilities

A financial liability is derecognised when the obligation under the liability is discharged, cancelled or expires.

Offsetting financial assets and financial liabilities

Financial assets and liabilities are offset and the net amount reported in the statement of financial position only when there is a

legally enforceable right to offset the recognised amounts and there is an intention to settle on a net basis, or to realise the asset

and settle the liability simultaneously. Related income and expenses are not offset in the consolidated income statement unless

required or permitted by an IFRS Accounting Standard or interpretation, as specifically disclosed in an accounting policy.

Hedge accounting

The Group designates certain derivatives as hedging instruments in order to effect cash flow hedges. At the inception of the hedge

relationship, the Group documents the relationship between the hedging instrument and the hedged item, along with its risk

management objectives and its strategy for undertaking various hedge transactions. Furthermore, at the inception of the hedge

and on an ongoing basis, the Group documents whether the hedging instrument is highly effective in offsetting changes in fair

values or cash flows of the hedged item attributable to the hedged risk.

Where a cash flow hedging relationship exists, the effective portion of changes in the fair value of derivatives that are designated

and qualify as cash flow hedges is recognised in other comprehensive income and accumulated under the heading of cash flow

hedging reserve. The gain or loss relating to the ineffective portion is recognised immediately in profit or loss, and is included in net

investment income.

Amounts previously recognised in other comprehensive income and accumulated in equity are reclassified to profit or loss in the

periods when the hedged item affects profit or loss, in the same line as the recognised hedged item.

Hedge accounting is discontinued if: the Group’s hedging objective has changed (can result in a partial discontinuance); the hedged

item or hedging instrument no longer exists or is sold; there is no longer an economic relationship between the hedged item and

the hedging instrument; or the effect of credit risk starts to dominate the value changes that result from the economic

relationship. Any gain or loss recognised in other comprehensive income and accumulated in equity at that time is recycled to profit

or loss over the period the hedged item impacts profit or loss or immediately where the hedged future cash flows are no longer

expected to occur.

E. Financial assets & liabilities continued

E1. Fair values continued

229Annual Report and Accounts 2025

Financials

Standard Life plc

E1.1 Fair value analysis

The table below sets out a comparison of the carrying amounts and fair values of financial instruments:

		2025		2024
	Carrying value	Fair value	Carrying value	Fair value
	£m	£m	£m	£m
Financial assets
Financial assets mandatorily held at fair value through profit or loss (‘FVTPL’):
Loans and deposits	234	234	249	249
Derivatives	4,243	4,243	2,600	2,600
Equities 1	110,759	110,759	96,365	96,365
Debt securities	99,681	99,681	89,301	89,301
Collective investment schemes 1	83,446	83,446	83,700	83,700
Reinsurers' share of investment contract liabilities 1	10,657	10,657	9,297	9,297
Financial assets measured at amortised cost:
Loans and deposits	11	11	12	12
Total financial assets	309,031	309,031	281,524	281,524
Less amounts classified as financial assets held for sale (see note H2) 2	–	–	(1,985)	(1,985)
Total financial assets less financial assets classified as held for sale	309,031	309,031	279,539	279,539
Amounts due for settlement after 12 months	91,167		81,145

		2025		2024
	Carrying value	Fair value	Carrying value	Fair value
	£m	£m	£m	£m
Financial liabilities
Financial liabilities mandatorily held at FVTPL:
Derivatives	7,761	7,761	4,085	4,085
Financial liabilities designated at FVTPL upon initial recognition:
Borrowings	22	22	31	31
Net asset value attributable to unitholders 1	2,334	2,334	2,486	2,486
Investment contract liabilities 1	191,269	191,269	173,922	173,922
Financial liabilities measured at amortised cost:
Borrowings	3,212	3,309	3,591	3,599
Obligations for repayment of collateral received	839	839	849	849
Total financial liabilities	205,437	205,534	184,964	184,972
Less amounts classified as financial liabilities held for sale (see note H2) 3	–	–	(3,175)	(3,175)
Total financial liabilities less financial liabilities held for sale	205,437	205,534	181,789	181,797
Amounts due for settlement after 12 months	10,363		6,778

1 These assets and liabilities have no specified settlement date.

2 Amounts classified as financial assets held for sale in the comparative period include equities of £14 million, debt securities of £979 million, collective investment schemes of

£960 million and reinsurers’ share of investment contract liabilities of £32 million.

3 Amounts classified as financial liabilities held for sale in the comparative period include investment contract liabilities of £3,175 million.

E1.2 Impairment of financial assets held at amortised cost

The Group applies a forward-looking expected credit loss (‘ECL’) approach to the financial assets carried at amortised cost.

A significant portion of the Group’s financial assets are carried at FVTPL and are therefore not subject to ECL assessment.

The financial assets classified as amortised cost and subject to ECL mainly relate to certain loan assets, other receivables and

certain cash and cash equivalents balances.

For the in-scope financial assets at the reporting date either the lifetime expected credit loss or a 12-month expected credit loss

is provided for, depending on the Group’s assessment of whether the credit risk associated with the specific asset has increased

significantly since initial recognition. The Group’s current credit risk grading framework comprises the following categories:

230 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

Category	Description	Basis for recognising ECL
Performing	The counterparty has a low risk of default and	12-month ECL
	does not have any past-due amounts
Doubtful	There has been a significant increase in	Lifetime ECL – not credit impaired
	credit risk since initial recognition
In default	There is evidence indicating the asset is credit impaired	Lifetime ECL – credit impaired
Write-off	There is evidence indicating that the counterparty is in severe	Amount is written off
	financial difficulty and the Group has no realistic prospect of recovery

The financial assets held at amortised cost are assessed as at 31 December 2025 and 31 December 2024 as ‘performing’ and this

assessment is summarised below.

Loans and deposits – the Group has assessed the estimated credit losses of these loans and deposits as low due to the external credit

ratings of the counterparties resulting in low credit risk and there being no past-due amounts.

Other receivables – these balances relate to investment broker balances, cash collateral pledged and other regular receivables due

to the Group in the normal course of business. Expected credit losses are assessed as being immaterial given the typically short-term

nature of these balances.

Cash and cash equivalents – the Group’s cash and cash equivalents are held with banks and financial institutions, which have

investment grade credit ratings of ‘BBB’ or above. The Group considers that its cash and cash equivalents have low credit risk based

on the external credit ratings of the counterparties and, there being no history of default. The impact to the net carrying amount

stated in the table above is therefore not considered to be material.

Based on the above assessment, an immaterial credit loss balance has been determined in both periods presented due to these

financial assets being predominantly short-term and having low credit risk.

E2. Fair value hierarchy

E2.1 Determination of fair value and fair value hierarchy of financial instruments

Level 1 financial instruments

The fair value of financial instruments traded in active markets (such as exchange traded securities and derivatives) is based on

quoted market prices at the period end provided by recognised pricing services. Market depth and bid-ask spreads are used to

corroborate whether an active market exists for an instrument. Greater depth and narrower bid-ask spread indicate higher liquidity

in the instrument and are classed as Level 1 inputs. For collective investment schemes and reinsurers’ share of investment contract

liabilities, fair value is by reference to published bid prices.

Level 2 financial instruments

Financial instruments traded in active markets with less depth, or wider bid-ask spreads, which do not meet the classification as

Level 1 inputs, are classified as Level 2. The fair values of financial instruments not traded in active markets are determined using

broker quotes or valuation techniques with observable market inputs. Financial instruments valued using broker quotes are

classified as Level 2, only where there is a sufficient range of available quotes. The fair value of over-the-counter derivatives is

estimated using pricing models or discounted cash flow techniques. Collective investment schemes where the underlying assets are

not priced using active market prices are determined to be Level 2 instruments and will include collective investment schemes

which have a material underlying holdings within real estate/property. Where pricing models are used, inputs are based on market

related data at the period end. Where discounted cash flows are used, estimated future cash flows are based on management’s

best estimates and the discount rate used is a market related rate for a similar instrument. The fair value of investment contract

liabilities reflects the fair value of the underlying assets and liabilities in the funds plus an additional amount to cover the present

value of the excess of future policy costs over future charges. The liabilities are consequently determined to be Level 2 instruments.

Level 3 financial instruments

The Group’s financial instruments determined by valuation techniques using non-observable market inputs are based on a

combination of independent third-party evidence and internally developed models. In relation to investments in hedge funds and

private equity investments, non-observable third party evidence in the form of net asset valuation statements is used as the basis

for the valuation. Adjustments may be made to the net asset valuation where other evidence, for example recent sales of the

underlying investments in the fund, indicates this is required. Securities that are valued using broker quotes which could not be

corroborated across a sufficient range of quotes are considered as Level 3. For a small number of investment vehicles and debt

securities, standard valuation models are used, as due to their nature and complexity they have no external market. Inputs into

such models are based on observable market data where possible. The fair value of loans, derivatives and some borrowings with no

external market is determined by internally developed discounted cash flow models using appropriate assumptions corroborated

with external market data where possible.

For financial instruments that are recognised at fair value on a recurring basis, the Group determines whether transfers have

occurred between levels in the hierarchy by reassessing categorisation (based on the lowest level input that is significant to the fair

value measurement as a whole) during each reporting period.

E. Financial assets & liabilities continued

E1. Fair values continued

E1.2 Impairment of financial assets held at amortised cost continued

231Annual Report and Accounts 2025

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Standard Life plc

Fair value hierarchy information for non-financial assets measured at fair value is included in note G3 for owner-occupied property

and in note G4 for investment property.

E2.2 Fair value hierarchy of financial instruments

The tables below separately identify financial instruments carried at fair value from those measured on another basis but for which

fair value is disclosed.

	Level 1	Level 2	Level 3	Total fair value
2025	£m	£m	£m	£m
Financial assets measured at fair value
Financial assets at FVTPL (mandatory)
Loans and deposits	–	234	–	234
Derivatives	44	4,198	1	4,243
Equities	107,629	258	2,872	110,759
Debt securities	51,429	31,989	16,263	99,681
Collective investment schemes	79,223	3,763	460	83,446
Reinsurers' share of investment contract liabilities	10,657	–	–	10,657
Total financial assets measured at fair value	248,982	40,442	19,596	309,020
Financial assets measured at amortised cost
for which fair values are disclosed
Loans and deposits	–	11	–	11
	248,982	40,453	19,596	309,031

	Level 1	Level 2	Level 3	Total fair value
2025	£m	£m	£m	£m
Financial liabilities measured at fair value
Financial liabilities at FVTPL (mandatory)
Derivatives	96	7,663	2	7,761
Financial liabilities designated at FVTPL upon initial recognition:
Borrowings	–	–	22	22
Net asset value attributable to unitholders	2,334	–	–	2,334
Investment contract liabilities	–	191,269	–	191,269
Total financial liabilities measured at fair value	2,430	198,932	24	201,386
Financial liabilities measured at amortised cost
for which fair values are disclosed
Borrowings	–	3,309	–	3,309
Obligations for repayment of collateral received	–	839	–	839
Total financial liabilities measured at amortised
cost for which fair values are disclosed	–	4,148	–	4,148
	2,430	203,080	24	205,534

232 Annual Report and Accounts 2025

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Standard Life plc

Notes to the consolidated financial statements continued

	Level 1	Level 2	Level 3	Total fair value
2024	£m	£m	£m	£m
Financial assets measured at fair value
Financial assets at FVTPL (mandatory)
Loans and deposits	–	249	–	249
Derivatives	114	2,321	165	2,600
Equities	93,708	81	2,576	96,365
Debt securities	49,624	24,531	15,146	89,301
Collective investment schemes	79,921	3,292	487	83,700
Reinsurers' share of investment contract liabilities	9,297	–	–	9,297
Total financial assets measured at fair value	232,664	30,474	18,374	281,512
Less amounts classified as held for sale 1	(1,283)	(147)	(555)	(1,985)
Total financial assets measured at fair value, excluding amounts classified as held for sale	231,381	30,327	17,819	279,527
Financial assets measured at amortised cost
for which fair values are disclosed
Loans and deposits	–	12	–	12
	231,381	30,339	17,819	279,539

	Level 1	Level 2	Level 3	Total fair value
2024	£m	£m	£m	£m
Financial liabilities measured at fair value
Financial liabilities at FVTPL (mandatory)
Derivatives	70	3,882	133	4,085
Financial liabilities designated at FVTPL upon initial recognition:
Borrowings	–	–	31	31
Net asset value attributable to unitholders	2,486	–	–	2,486
Investment contract liabilities	–	173,922	–	173,922
Total financial liabilities measured at fair value	2,556	177,804	164	180,524
Less amounts classified as held for sale 2	–	(3,175)	–	(3,175)
Total financial liabilities measured at fair value, excluding amounts classified as held for sale	2,556	174,629	164	177,349
Financial liabilities measured at amortised cost
for which fair values are disclosed
Borrowings	–	3,599	–	3,599
Obligations for repayment of collateral received	–	849	–	849
Total financial liabilities measured at amortised
cost for which fair values are disclosed	–	4,448	–	4,448
	2,556	179,077	164	181,797

1 Amounts classified as held for sale includes £14 million of equities (Level 1), £32 million of reinsurers’ share of investment contract liabilities (Level 1), £960 million of collective

investment schemes (£956 million Level 1 and £4 million Level 2) and £979 million of debt securities (£281 million Level 1; £143 million Level 2; and £555 million Level 3).

2 Amounts classified as held for sale includes £3,175 million of investment contract liabilities.

E. Financial assets & liabilities continued

E2. Fair value hierarchy continued

E2.2 Fair value hierarchy of financial instruments continued

233Annual Report and Accounts 2025

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E2.3 Significant inputs and input values for Level 3 financial instruments

				Key unobservable input value
Description	Valuation technique	Significant inputs	2025	2024
Equities	Net asset value	Net asset statement	£2,872m	£2,576m
Debt securities
(see E2.3.1 for further details)
Loans guaranteed by export credit	DCF model 1	Credit spread	123bps	100bps 2
agencies & supranationals			(weighted average)	(weighted average)
Private corporate credit	DCF model 1	Credit spread	156bps	165bps 2
			(weighted average)	(weighted average)
Infrastructure loans	DCF model 1	Credit spread	162bps	174bps 2
			(weighted average)	(weighted average)
Loans to housing associations	DCF model 1	Credit spread	152bps	161bps 2
			(weighted average)	(weighted average)
Local authority loans	DCF model 1	Credit spread	145bps	142bps 2
			(weighted average)	(weighted average)
Equity Release Mortgage loans (‘ERM’)	DCF model and	Spread	184bps over SONIA	195bps over SONIA
	Black-Scholes	House price	+75bps adjustment to	+75bps adjustment to
	model 3	inflation	a flat RPI curve based	RPI
			on a 20-year term
		House prices	£396,168 (average)	£385,838 (average)
		Mortality	Average life	Average life expectancy
			expectancy of a male	of a male and female
			and female currently	currently aged 75 is 14.2
			aged 75 is 14.7 years	years and 15.8 years
			and 17.0 years	respectively
			respectively
		Voluntary	190bps to 400bps	190bps to 400bps
		redemption rate
Commercial real estate loans	DCF model 1	Credit spread	229bps	230bps
			(weighted average)	(weighted average)
Income strips 4	Income	Credit spread	–	674bps
	capitalisation
Collective investment schemes	Net asset value	Net asset	£460m	£487m
		statement
Borrowings
Property reversions loans (see note E5)	Internally	Mortality rate	130% IFL92C15	130% IFL92C15
	developed model		(Female) 5	(Female) 5
			130% IML92C15	130% IML92C15 (Male) 5
			(Male) 5
		House price	3-year RPI rate plus	3-year RPI rate plus
		inflation	75bps	75bps
		Discount rate	3-year swap rate plus	3-year swap rate plus
			170bps + 1.7% margin	170bps
		Deferred	370bps	370bps
		possession rate
Derivative assets and liabilities
Forward private placements,	DCF model 1	Credit spread	169bps	98bps
infrastructure and local authority loans 6			(weighted average)	(weighted average)
Longevity swaps 7	DCF model 1	Swap curve	swap curve	swap curve

1 Discounted cash flow (‘DCF’) model: Except where otherwise stated, the discount rate used is based on a risk-free curve and a credit spread. The risk-free rate is taken from

an appropriate gilt of comparable duration. The spread is derived from a basket of comparable securities.

2 The key observable input value has been restated to include additional debt securities within the weighted average calculation.

3 ERM loans: The loans are valued using a DCF model and a Black-Scholes model for valuation of the No-Negative Equity Guarantee (‘NNEG’). The NNEG caps the loan repayment

in the event of death or entry into long-term care to be no greater than the sales proceeds from the property. The future cash flows are estimated based on assumed levels of

mortality derived from published mortality tables, entry into long-term care rates and voluntary redemption rates. Cash flows include an allowance for the expected cost of

providing a NNEG assessed under a real world approach using a closed form model including an assumed level of property value volatility. For the NNEG assessment, property

values are indexed from the latest property valuation point and then assumed to grow in line with an RPI based assumption. Cash flows are discounted using a risk-free curve plus

a spread, where the spread is based on recent originations, with margins to allow for the different risk profiles of ERM loans.

4 Income strips are transactions where an owner-occupier of a property has sold a freehold or long leasehold interest to the Group, and has signed a long lease (typically 30-45 years)

or a ground lease (typically 45-175 years) and retains the right to repurchase the property at the end of the lease for a nominal sum (usually £1). The income strips are valued using

an income capitalisation approach, where the annual rental income is capitalised using an appropriate yield. The yield is determined by considering recent transactions involving

similar income strips. These assets were transferred to Aberdeen Group during the year as part of the Part VII (see note H2).

5 IFL92C15 and IML92C15 relate to immediate annuitant female and male lives and refer to the 92 series mortality tables produced by the Continuous Mortality Investigation (‘CMI’).

6 Derivative liabilities include forward investments of £1 million (2024: £33 million) which include a commitment to acquire or provide funding for fixed rate debt instruments at

specified future dates.

7 Included within derivative assets and liabilities are longevity swap contracts with corporate pension schemes with a fair value of £nil (2024: £165 million) and £nil (2024: £63 million)

respectively.

234 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

E2.3.1 Debt securities

2025 2024

Analysis of Level 3 debt securities	£m	£m
Unquoted corporate bonds:
Loans guaranteed by export credit agencies & supranationals	486	461
Private corporate credit	3,641	3,046
Infrastructure loans–project finance	1,028	1,011
Infrastructure loans–corporate	2,179	1,613
Loans to housing associations	1,202	1,172
Local authority loans	1,137	823
ERM	4,957	4,795
Commercial real estate loans	1,317	1,170
Income strips	–	555
Bridging loans to private equity funds	304	498
Other	12	2
Total Level 3 debt securities	16,263	15,146
Less amounts classified as held for sale	–	(555)
Total Level 3 debt securities excluding amounts classified as held for sale	16,263	14,591

E2.4 Sensitivities of Level 3 instruments

				2025		2024
			Impact from	Impact from	Impact from	Impact from
		Reasonable	increase	decrease	increase	decrease
	Key unobservable input	alternative	£m	£m	£m	£m
Equities	Net asset value statements	+/- 10%	287	(287)	258	(258)
Debt securities
Loans guaranteed by export credit	Credit spread	+/- 65bps	(15)	16	(11)	11
agencies & supranationals
Private corporate credit	Credit spread	+/- 65bps	(183)	199	(169)	181
Infrastructure loans	Credit spread	+/- 65bps	(146)	156	(121)	129
Loans to housing associations	Credit spread	+/- 65bps	(93)	101	(97)	106
Local authority loans	Credit spread	+/- 65bps	(88)	92	(62)	66
ERM	Credit spread	+/- 100bps	(442)	520	(416)	457
	House price inflation	+/- 1%	64	(89)	57	(80)
	House prices	+/- 10%	47	(73)	37	(55)
	Mortality	+/- 5%	20	(21)	18	(20)
	Voluntary redemption rate	+/- 15%	57	(60)	36	(38)
Commercial real estate loans	Credit spread	+/- 65bps	(62)	68	(52)	57
Income strips	Credit spread	+/- 65bps	–	–	(64)	68
Collective investment schemes	Net asset value statements	+/- 10%	46	(46)	49	(49)
Derivative assets and liabilities
Forward private placements, infrastructure and local authority loans	Credit spread	+/- 65bps	(6)	6	(8)	9
Longevity swap contracts	Swap curve	+/- 100bps	–	–	(14)	17

For the property reversions loans and bridging loans to private equity funds, there are no reasonably possible movements in

unobservable input values which would result in a significant movement in the fair value of the financial instruments.

E. Financial assets & liabilities continued

E2. Fair value hierarchy continued

235Annual Report and Accounts 2025

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E2.5 Transfers of financial instruments between Level 1 and Level 2

	From Level 1 to	From Level 2 to
	Level 2	Level 1
2025	£m	£m
Financial assets measured at fair value
Financial assets mandatorily held at FVTPL
Equities	26	15
Debt securities	251	386
Collective investment schemes	3	4

	From Level 1 to	From Level 2 to
	Level 2	Level 1
2024	£m	£m
Financial assets measured at fair value
Financial assets mandatorily held at FVTPL
Derivatives	21	–
Equities	21	2
Debt securities	1,319	244
Collective investment schemes	56	5

Consistent with the prior year, all the Group’s Level 1 and Level 2 assets have been valued using standard market pricing sources.

E2.6 Movement in Level 3 financial instruments measured at fair value

		Net						Unrealised
		(losses)/			Transfers			gains on
	At 1	gains in			from	Transfers to	At 31	assets held
	January	income			Level 1	Level 1 and	December	at end of
	2025	statement	Purchases	Sales	and Level 2	Level 2	2025	period
2025	£m	£m	£m	£m	£m	£m	£m	£m
Financial assets measured at fair value
Financial assets mandatorily held at FVTPL:
Derivatives	165	(164)	–	–	–	–	1	1
Equities	2,576	81	453	(238)	–	–	2,872	75
Debt securities	15,146	429	6,562	(5,927)	53	–	16,263	148
Collective investment schemes	487	(12)	81	(94)	–	(2)	460	–
Total financial assets
measured at fair value	18,374	334	7,096	(6,259)	53	(2)	19,596	224

								Unrealised
								(gains)/
		Net (gains)/						losses on
	At 1	losses in			Transfers	Transfers to	At 31	liabilities
	January	income		Sales/	from Level 1	Level 1 and	December	held at end
	2025	statement	Purchases	repayments	and Level 2	Level 2	2025	of period
2025	£m	£m	£m	£m	£m	£m	£m	£m
Financial liabilities measured at fair value
Financial liabilities mandatorily
held at FVTPL:
Derivatives	133	(92)	–	(39)	–	–	2	(35)
Financial liabilities designated at FVTPL upon initial recognition:
Borrowings	31	4	–	(13)	–	–	22	4
Total financial liabilities
measured at fair value	164	(88)	–	(52)	–	–	24	(31)

236 Annual Report and Accounts 2025

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Standard Life plc

Notes to the consolidated financial statements continued

								Unrealised
								(losses)/
		Net (losses)/						gains on
		gains in			Transfers	Transfers to	At 31	assets held
	At 1 January	income			from Level 1	Level 1 and	December	at end of
	2024	statement	Purchases	Sales	and Level 2 2	Level 2	2024 1	period
2024	£m	£m	£m	£m	£m	£m	£m	£m
Financial assets measured at fair value
Financial assets mandatorily held at FVTPL:
Derivatives	232	(67)	–	–	–	–	165	(67)
Equities	2,495	50	446	(415)	–	–	2,576	82
Debt securities	13,818	(335)	7,424	(6,027)	282	(16)	15,146	(259)
Collective investment schemes	401	6	140	(60)	2	(2)	487	5
Total financial assets
measured at fair value	16,946	(346)	8,010	(6,502)	284	(18)	18,374	(239)

								Unrealised
								(gains)/
		Net (gains)/			Transfers			losses on
		losses in			from	Transfers to	At 31	liabilities
	At 1 January	income		Sales/	Level 1 and	Level 1 and	December	held at end
	2024	statement	Purchases	repayments	Level 2	Level 2	2024	of period
2024	£m	£m	£m	£m	£m	£m	£m	£m
Financial liabilities measured at fair value
Financial liabilities mandatorily
held at FVTPL:
Derivatives	206	(56)	–	(17)	–	–	133	(67)
Financial liabilities designated at FVTPL
upon initial recognition:
Borrowings	45	2	–	(16)	–	–	31	2
Total financial liabilities
measured at fair value	251	(54)	–	(33)	–	–	164	(65)

1 Total financial assets of £18,374 million includes £555 million of assets classified as held for sale.

2 During 2024, £282 million of debt securities were transferred from Level 2 to Level 3 to harmonise the approach for determining the fair value hierarchy across the Group following

the acquisition of Phoenix Life CA Holdings Limited (formerly known as SLF of Canada UK Limited) in 2023.

Gains and losses on Level 3 financial instruments are included in net investment income in the consolidated income statement. There

were no gains or losses recognised in other comprehensive income in either the current or comparative period.

E3. Derivatives

The Group purchases derivative financial instruments principally in connection with the management of its insurance contract and

investment contract liabilities based on the principles of reduction of risk and efficient portfolio management. The Group does not

typically hold derivatives for the purpose of selling and repurchasing in the near term or with the objective of generating a profit

from short-term fluctuations in price or margin. The Group also holds derivatives which are designated as hedging instruments in

order to hedge the Group’s Euro and US Dollar borrowings. These hedging relationships qualify for hedge accounting under IFRS 9

and are designated as cash flow hedges.

Derivative financial instruments are recognised initially at fair value and are subsequently remeasured to fair value. The gain or loss

on remeasurement to fair value is recognised in the consolidated income statement where the derivatives are held for trading.

Where derivative financial instruments are held to hedge the Group’s Euro and US Dollar borrowings, the effective portion of any

gain or loss that arises on remeasurement to fair value is initially recognised in other comprehensive income and is recycled to

profit or loss as the hedged item impacts the profit or loss. See notes E1 and D3 for further details of the Group’s hedging

accounting policy.

E. Financial assets & liabilities continued

E2. Fair value hierarchy continued

E2.6 Movement in Level 3 financial instruments measured at fair value continued

237Annual Report and Accounts 2025

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E3.1 Summary

The fair values of derivative financial instruments are as follows:

	Assets	Liabilities	Assets	Liabilities
	2025	2025	2024	2024
	£m	£m	£m	£m
Forward currency	271	49	130	296
Interest rate swaps	2,258	4,297	1,526	2,605
Total return bond swaps	452	457	41	43
Swaptions	25	85	147	44
Inflation swaps	747	1,822	283	339
Equity options	38	43	36	187
Stock index and currency futures	31	92	79	32
Fixed income futures	13	5	23	71
Longevity swap contracts	–	–	165	63
Cross currency swaps	391	894	156	366
Other	17	17	14	39
	4,243	7,761	2,600	4,085

E4. Collateral arrangements

The Group receives and pledges collateral in the form of cash or non-cash assets in respect of stock lending transactions, derivative

contracts and reinsurance arrangements in order to reduce the credit risk of these transactions. The amount and type of collateral

required where the Group receives collateral depends on an assessment of the credit risk of the counterparty, but is usually in the

form of cash and marketable securities.

Collateral received in the form of cash, where the Group has contractual rights to receive the cash flows generated and is available

to the Group for investment purposes, is recognised as a financial asset in the statement of consolidated financial position with a

corresponding financial liability for its repayment. Non-cash collateral received is not recognised in the statement of consolidated

financial position, unless the counterparty defaults on its obligations under the relevant agreement.

Non-cash collateral pledged where the Group retains the contractual rights to receive the cash flows generated is not

derecognised from the statement of consolidated financial position, unless the Group defaults on its obligations under the

relevant agreement. Cash collateral pledged, where the counterparty has contractual rights to receive the cash flows generated,

is derecognised from the statement of consolidated financial position and a corresponding receivable is recognised for its return.

The Group is also party to reverse repurchase agreements under which securities are purchased from third parties with an

obligation to resell the securities. The securities are not recognised as financial assets on the statement of consolidated financial

position, unless the counterparty defaults on its obligations under the relevant agreement. The right to receive the return of any

cash paid as purchase consideration plus interest is recognised as a financial asset on the statement of financial position.

E4.1 Financial instrument collateral arrangements

The Group has no financial assets and financial liabilities that have been offset in the statement of consolidated financial position

as at 31 December 2025 (2024: none).

The table below contains disclosures related to financial assets and financial liabilities recognised in the statement of consolidated

financial position that are subject to enforceable master netting arrangements or similar agreements. Such agreements do not meet

the criteria for offsetting in the statement of consolidated financial position as the Group has no current legally enforceable right to

offset recognised financial instruments. Furthermore, certain related assets received as collateral under the netting arrangements

will not be recognised in the statement of consolidated financial position as the Group does not have permission to sell or re-pledge,

except in the case of default. Details of the Group’s collateral arrangements in respect of these recognised assets and liabilities are

provided below.

		2025					2024
		Related amounts not offset					Related amounts not offset
		Financial				Financial
	Amount of	instruments			Amount of	instruments
	recognised	and cash			recognised	and cash
	financial	collateral	Derivative	Net	financial	collateral	Derivative	Net
	assets	received	liabilities	amount	assets	received	liabilities	amount
	£m	£m	£m	£m	£m	£m	£m	£m
Financial assets
OTC derivatives	4,194	655	3,381	158	2,487	759	1,537	191
Exchange traded derivatives	49	1	7	41	113	68	17	28
Stock lending	1,101	1,101	–	–	1,156	1,156	–	–
Reverse repurchase arrangement	603	603	–	–	151	151	–	–
Total	5,947	2,360	3,388	199	3,907	2,134	1,554	219

238 Annual Report and Accounts 2025

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Standard Life plc

Notes to the consolidated financial statements continued

		2025					2024
		Related amounts not offset					Related amounts not offset
		Financial				Financial
	Amount of	instruments			Amount of	instruments
	recognised	and cash			recognised	and cash
	financial	collateral	Derivative	Net	financial	collateral	Derivative	Net
	liabilities	pledged	assets	amount	liabilities	pledged	assets	amount
	£m	£m	£m	£m	£m	£m	£m	£m
Financial liabilities
OTC derivatives	7,664	4,170	3,381	113	3,983	2,305	1,537	141
Exchange traded derivatives	97	54	7	36	102	7	17	78
Total	7,761	4,224	3,388	149	4,085	2,312	1,554	219

E4.2 Derivative collateral arrangements

Assets accepted

It is the Group’s practice to obtain collateral to mitigate the counterparty risk related to over-the-counter (‘OTC’) derivatives usually

in the form of cash or marketable financial instruments.

The fair value of financial assets accepted as collateral for OTC derivatives but not recognised in the statement of consolidated

financial position amounts to £44 million (2024: £377 million).

The amounts recognised as financial assets and liabilities from cash collateral received at 31 December are set out below.

	OTC derivatives
	2025	2024
	£m	£m
Financial assets	794	790
Financial liabilities	(794)	(790)

The maximum exposure to credit risk in respect of OTC derivative assets is £4,194 million (2024: £2,487 million) of which credit risk of

£4,036 million (2024: £2,296 million) is mitigated by use of collateral arrangements (which are settled net after taking account of any

OTC derivative liabilities owed to the counterparty).

Credit risk on exchange traded derivative assets of £49 million (2024: £113 million) is mitigated through regular margining and the

protection offered by the exchange.

Assets pledged

The Group pledges collateral in respect of its OTC derivative liabilities. The value of assets pledged at 31 December 2025 in respect

of OTC derivative liabilities of £7,664 million (2024: £3,983 million) amounted to £1,344 million (2024: £1,527 million) for cash

collateral pledged and £3,017 million (2024: £1,190 million) for non-cash collateral pledged.

E4.3 Stock lending collateral arrangements

The Group lends listed financial assets held in its investment portfolio to other institutions.

The Group conducts stock lending only with well-established, reputable institutions in accordance with established market

conventions. The financial assets do not qualify for derecognition as the Group retains all the risks and rewards of the transferred

assets except for the voting rights.

It is the Group’s practice to obtain collateral in stock lending transactions, usually in the form of cash or marketable financial instruments.

The fair value of financial assets accepted as such collateral but not recognised in the statement of consolidated financial position

amounts to £1,195 million (2024: £1,284 million).

The maximum exposure to credit risk in respect of stock lending transactions is £1,101 million (2024: £1,156 million) of which credit

risk of £1,101 million (2024: £1,156 million) is mitigated through the use of collateral arrangements.

E4.4 Other collateral arrangements

At 31 December 2025, the Group had entered into reverse repurchase transactions under which it purchased securities and had

taken on the obligation to resell the securities. The fair value of the financial assets accepted as collateral in respect of these

transactions, but not recognised in the statement of consolidated financial position, is £603 million (2024: £151 million).

The maximum exposure to credit risk in respect of reverse repurchase transactions is £603 million (2024: £ 151 million) of which credit

risk of £603 million (2024: £ 151 million) is mitigated through the use of collateral arrangements.

Details of collateral received to mitigate the counterparty risk arising from the Group’s reinsurance transactions is given in note F8.

Collateral has also been pledged and charges have been granted in respect of certain Group borrowings. The details of these

arrangements are set out in note E5.

E. Financial assets & liabilities continued

E4. Collateral arrangements continued

E4.1 Financial instrument collateral arrangements continued

239Annual Report and Accounts 2025

Financials

Standard Life plc

E5. Borrowings

The Group classifies the majority of its interest-bearing borrowings as financial liabilities carried at amortised cost and these

are recognised initially at fair value less any directly attributable transaction costs. The difference between initial cost and the

redemption value is amortised through the consolidated income statement over the period of the borrowing using the effective

interest method.

Certain borrowings are designated upon initial recognition at fair value through profit or loss and measured at fair value where doing so

provides more meaningful information due to the reasons stated in the financial liabilities accounting policy (see note E1). Transaction

costs relating to borrowings designated upon initial recognition at fair value through profit or loss are expensed as incurred.

Borrowings are classified as either policyholder or shareholder borrowings. Policyholder borrowings are those borrowings where

there is either no or limited shareholder exposure, for example, borrowings attributable to the Group’s with-profits operations.

E5.1 Analysis of borrowings

	Carrying value		Fair value
	2025	2024	2025	2024
	£m	£m	£m	£m
£400 million multi-currency revolving credit facility	162	90	162	90
Property reversions loan	22	31	22	31
Total policyholder borrowings	184	121	184	121
£428 million Tier 2 notes	–	197	–	199
US $500 million Tier 2 notes	371	399	376	399
€500 million Tier 2 notes	435	411	456	423
US $750 million Perpetual Contingent Convertible Tier 1 notes	–	199	–	200
£500 million 5.625% Tier 2 notes	492	490	506	485
US $500 million Fixed Rate Reset Callable Tier 2 notes	259	279	260	275
£500 million 5.867% Tier 2 notes	523	529	516	500
£250 million Tier 3 notes	251	252	250	246
£350 million Fixed Rate Reset Callable Tier 2 notes	348	347	385	367
US $500 million Perpetual Contingent Convertible Tier 1 notes	371	398	398	415
Total shareholder subordinated borrowings	3,050	3,501	3,147	3,509
Total borrowings	3,234	3,622	3,331	3,630
Amount due for settlement after 12 months	2,821	3,335

The Group has in place a £1.5 billion unsecured revolving credit facility (the ‘revolving facility’). During the year the maturity date was

extended from November 2029 to November 2030. This facility remains undrawn as at 31 December 2025.

Policyholder borrowings

Patria Private Equity Trust plc (’PPET’) has in place a syndicated multi-currency revolving credit facility, of which £162 million (2024:

£90 million) had been drawn down as at 31 December 2025. During the year, the facility term maturity was extended from December

2025 to February 2028 and the facility limit increased to £400 million from £300 million. Interest accrues at a margin of 2.6% over the

reference rate of the currency drawn.

The Property Reversions loan from Santander UK plc (‘Santander’) is recognised in the consolidated financial statements at fair value.

It relates to the sale of NPI Extra-Income Plan policies that Santander finances to the value of the associated property reversions. As

part of the arrangement Santander receives an amount calculated by reference to the movement in the Halifax House Price Index

and the Group is required to indemnify Santander against profits or losses arising from mortality or surrender experience which

differs from the basis used to calculate the reversion amount. During 2025, repayments totalling £13 million were made (2024:

£16 million). Note G4 contains details of the assets that support this loan. As part of the facility, security has been granted to the

lenders. This security may be utilised under certain conditions of the agreement, namely the event of default by the borrower. In the

event of default arising, the lenders would be entitled to offset subject to security against past due obligations, being loans drawn

under the facility.

240 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

Shareholder subordinated borrowings

The principal features of the Group’s subordinated borrowings are detailed in the table below.

2025	Nominal amount	Coupon	Maturity
US $500 million Tier 2 notes 1	US $500m	5.375%	6 July 2027
€500 million Tier 2 notes 1	€500m	4.375%	24 January 2029
£500 million 5.625% Tier 2 notes	£500m	5.625%	28 April 2031 (with optional redemption
			from 28 January 2031)
US $500 million Fixed Rate	US $350m 2	4.750% up to reset date	4 September 2031 (with optional redemption
Reset Callable Tier 2 notes		of 4 September 2026	between 4 June and 4 September 2026)
£500 million 5.867% Tier 2 notes 3	£500m	5.867%	13 June 2029
£250 million Tier 3 notes 3	£250m	4.016%	13 June 2026
£350 million Fixed Rate Reset	£350m	7.750% up to reset date	6 December 2053 (with optional redemption
Callable Tier 2 notes		of 6 December 2033 4	between 6 June and 6 December 2033)
US $500 million Perpetual Contingent	US $500m	8.500% up to first reset	Perpetual (with optional redemption between
Convertible Tier 1 notes		date of 12 June 2030 5	12 December 2029 and 12 June 2030)

1 The Company was substituted as issuer on 12 December 2018.

2 On 7 December 2023 the Company redeemed US $150 million of the original US $500 million principal amount.

3 The Company was substituted as issuer on 22 July 2020 on acquisition of ReAssure Group Limited (formerly ReAssure Group plc) and the notes were recognised at fair value.

4 Interest is deferrable at the discretion of the Company.

5 Interest is cancellable at the absolute discretion of the Company.

On 4 February 2025, the Company redeemed the remaining US $250 million of the original US $750 million Perpetual Contingent

Convertible Tier 1 notes at their principal amount together with interest accrued.

On 18 December 2025, the Company redeemed the remaining £197 million of the original £428 million principal amount of the Tier 2

notes at their principal amount together with interest accrued.

E5.2 Reconciliation of liabilities arising from financing activities

The table below details changes in the Group’s liabilities arising from financing activities, including both cash and non-cash changes

(with the exception of lease liabilities, which have been included in note G9). Liabilities arising from financing activities are those for

which cash flows were, or future cash flows will be, classified in the Group’s consolidated statement of cash flows as cash flows from

financing activities.

			2025			2024
	Total	Interest	Derivative		Total	Interest	Derivative
	borrowings	payable 1	assets 2	Total	borrowings	payable 1	assets 2	Total
	£m	£m	£m	£m	£m	£m	£m	£m
At 1 January	3,622	60	(106)	3,576	3,892	63	(118)	3,837
Cash movements
New borrowings, net of costs	152	–	–	152	475	–	–	475
Repayments	(496)	(212)	–	(708)	(739)	(218)	–	(957)
Non-cash movements
Changes in fair value	4	–	88	92	2	–	12	14
Movement in foreign exchange	(43)	–	–	(43)	(1)	–	–	(1)
Other movements 3	(5)	210	–	205	(7)	215	–	208
At 31 December	3,234	58	(18)	3,274	3,622	60	(106)	3,576

1 Other movement represents the non-cash movement in the interest liability on borrowings.

2 Cross currency swaps to hedge against adverse currency movements in respect of Group’s Euro and US Dollar denominated borrowings. These instruments are reported within the

derivative balances detailed within note E3.1.

3 Principally comprises amortisation under the effective interest method applied to borrowings held at amortised cost. No interest was capitalised in the year.

E. Financial assets & liabilities continued

E5. Borrowings continued

E5.1 Analysis of borrowings continued

241Annual Report and Accounts 2025

Financials

Standard Life plc

E6. Risk management – financial and other risks

This note forms one part of the risk management disclosures in the consolidated financial statements. An overview of the Group’s

approach to risk management is outlined in note I3 and the Group’s management of insurance risk is detailed in note F9.

E6.1 Financial risk and the Asset Liability Management (‘ALM’) framework

The use of financial instruments naturally exposes the Group to the risks associated with them, chiefly market risk, credit risk and

financial soundness risk.

Responsibility for agreeing the financial risk profile rests with the Board of the Life Companies, as advised by investment managers,

internal committees and the actuarial function. In setting the risk profile, the Board of each Life Company will receive advice from

the Chief Investment Officer, the relevant With-profits Actuary and the relevant actuarial function holder/Chief Actuary as to the

potential implications of that risk profile with regard to the probability of both realistic insolvency and of failing to meet the

regulatory Minimum Capital Requirement. The Chief Actuary will also advise the extent to which the investment risk taken is

consistent with the Group’s commitment to help people secure a life of possibilities, including meeting the FCA’s expectations under

Consumer Duty.

Derivatives are used in many of the Group’s funds, within policy guidelines agreed by the Board of each Life Company and overseen by

investment committees of the Boards of each Life Company supported by management oversight committees. Derivatives are primarily

used for risk hedging purposes or for efficient portfolio management, including the activities of the Group’s Treasury function.

More detail on the Group’s exposure to financial risk is provided in note E6.2 below.

The Group is also exposed to insurance risk arising from its Life, Pensions and Savings business. Life insurance risk in the Group arises

through its exposure to longevity, persistency, mortality and to other variances between assumed and actual experience. These

variances can be in factors such as administrative expenses and new business pricing. More detail on the Group’s exposure to

insurance risk is provided in note F9.

The Group’s overall exposure to market and credit risk is monitored by appropriate committees, which agree policies for managing

each type of risk on an ongoing basis, in line with the investment strategy developed to achieve investment returns in excess of

amounts due in respect of insurance contracts. The effectiveness of the Group’s ALM framework relies on the matching of assets and

liabilities arising from insurance and investment contracts, taking into account the types of benefits payable to policyholders under

each type of contract. Separate portfolios of assets are maintained for with-profits funds (which include all of the Group’s

participating business), non-linked non-profits funds and unit-linked funds.

E6.2 Financial risk analysis

Transactions in financial instruments result in the Group assuming financial risks. These include credit risk, market risk and financial

soundness risk. Each of these are described below, together with a summary of how the Group manages the risk, along with

sensitivity analysis where appropriate. The sensitivity analysis does not include second order impacts of market movements,

for example, where a market movement may give rise to potential indicators of impairment for the Group’s intangible asset balances.

Climate risk

The Group is exposed to financial risks (in particular market and credit risk) arising from the transition to a low carbon economy, and

the physical impacts resulting from climate change which could result in long-term market, credit, insurance, reputation, proposition

and operational implications.

Identification of climate related risks has been embedded into the Group’s Risk Management Framework. Significant progress has

been made in recent years in developing risk metrics and establishing appropriate governance and risk management processes. The

Group has adopted a proactive approach towards combatting climate change, with key net zero targets. Further details on these

targets and on managing the related climate change risks are provided in the Task Force for Climate-related Financial Disclosures

(‘TCFD’) within the Strategic Report.

E6.2.1 Credit risk

Credit risk is defined as the risk of reductions in earnings and/or value, through financial or reputational loss, as a result of the default

of a counterparty or an associate of such a counterparty to a financial transaction (i.e. failure to honour their financial obligations, or

failing to perform them in a timely manner), whether on or off balance sheet.

There are two principal sources of credit risk for the Group:

• credit risk which results from direct investment activities, including investments in debt securities, derivatives counterparties,

collective investment schemes, hedge funds and the placing of cash deposits; and

• credit risk which results indirectly from activities undertaken in the normal course of business. Such activities include premium

payments, outsourcing contracts, reinsurance agreements, exposure from material suppliers and the lending of securities.

242 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

The amount disclosed in the statement of consolidated financial position in respect of all financial assets, together with rights

secured under off balance sheet collateral arrangements, but excluding the minority interest in consolidated collective investment

schemes and those assets that back unit-linked policyholder liabilities, represents the Group’s maximum exposure to credit risk.

The credit risk borne by the shareholder on with-profits policies is dependent on the extent to which the underlying insurance fund

is relying on shareholder support.

The impact of non-government debt securities and, inter alia, the change in market credit spreads during the year is fully reflected

in the values shown in these consolidated financial statements. Credit spreads are the excess of corporate bond yields over gilt

yields to reflect the higher level of risk. Similarly, the value of derivatives that the Group holds takes into account fully the changes

in swap rates.

There is an exposure to spread changes affecting the prices of corporate bonds and derivatives. This exposure applies to supported

with-profits funds (where risks and rewards fall wholly to shareholders), non-profit funds and shareholders’ funds.

The Group holds £20,250 million (2024: £17,554 million) assets used to back annuity liabilities in non-profit funds which are subject

to credit default provision. These assets include corporate bonds, commercial real estate and infrastructure loans. Annuity liabilities

include an aggregate credit default provision of £581 million (2024: £330 million) to fund against the risk of default.

The credit spread sensitivity represents a 100bps widening of credit spreads, with no change in the risk-free interest rate curve.

Under this sensitivity it is also assumed that both expected and unexpected defaults remain unchanged. The illiquidity premium used

in the valuation of primarily annuity liabilities, and associated reinsurance contracts, is adjusted to reflect the impact of the change in

credit spreads arising on assets containing credit risk held within the reference portfolio.

A 100bps widening of credit spreads, with all other variables held constant and no change in assumed expected defaults, would

result in an increase in the profit after tax in respect of a full financial year of £27 million (2024: £14 million), an increase in equity

of £141 million (2024: £141 million), and an increase in CSM of £7 million (2024: a decrease of £3 million).

A 100bps narrowing of credit spreads, with all other variables held constant and no change in assumed expected defaults, would

result in a decrease in the profit after tax in respect of a full financial year of £7 million (2024: an increase of £42 million), a decrease in

equity of £144 million (2024: £113 million), and a decrease in CSM of £8 million (2024: an increase of £3 million).

Credit risk is managed by the monitoring of aggregate Group exposures to individual counterparties and by appropriate credit risk

diversification (including by industry, credit rating, asset class and country). The Group manages the level of credit risk it accepts

through an established Group Credit Limit and Counterparty Framework that includes the use of credit risk tolerances and limits.

Additional controls for illiquid asset concentration risk are set out via specific risk limits within the framework. Credit risk on

derivatives and securities lending is mitigated through the use of collateral with appropriate haircuts.

Credit quality of assets

An indication of the Group’s exposure to credit risk is the quality of the investments and counterparties with which it transacts. The

following table provides information regarding the aggregate credit exposure split by credit rating.

					BB and		Unit-
	AAA	AA	A	BBB	below	Non-rated	linked	Total
2025	£m	£m	£m	£m	£m	£m	£m	£m
Loans and deposits	–	1	10	–	–	234	–	245
Derivatives	–	2,174	1,776	–	–	271	22	4,243
Debt securities 1,2	6,213	34,670	23,282	16,487	1,996	10,505	6,528	99,681
Reinsurance contract assets	–	3,803	2,005	–	–	–	–	5,808
Reinsurers’ share of investment contract liabilities	–	–	–	–	–	–	10,657	10,657
Cash and cash equivalents	22	636	4,253	6	–	34	2,351	7,302
	6,235	41,284	31,326	16,493	1,996	11,044	19,558	127,936

1 For financial assets that do not have credit ratings assigned by external ratings agencies, the Group assigns internal ratings for use in management and monitoring of credit risk.

£58 million of AAA, £683 million of AA, £1,897million of A, £2,853 million of BBB and £152 million of BB and below debt securities are internally rated. If a financial asset is neither

rated by an external agency nor internally rated, it is classified as ‘non-rated’.

2 Non-rated debt securities includes equity release mortgages with a value of £4,957 million (further details are set out in note E2.3) and non-rated bonds.

E. Financial assets & liabilities continued

E6. Risk management – financial and other risks continued

E6.2 Financial risk analysis continued

E6.2.1 Credit risk continued

243Annual Report and Accounts 2025

Financials

Standard Life plc

									Less
									amounts
									classified
					BB and				as held for
	AAA	AA	A	BBB	below	Non-rated	Unit-linked	Total	sale	Total
2024	£m	£m	£m	£m	£m	£m	£m	£m	£m	£m
Loans and deposits	–	2	–	–	–	259	–	261	–	261
Derivatives	–	1,536	662	43	–	335	24	2,600	–	2,600
Debt securities 1,2	7,329	32,892	17,752	14,967	2,518	7,071	6,772	89,301	(979)	88,322
Reinsurance contract assets	–	3,131	2,056	–	–	–	–	5,187	–	5,187
Reinsurers’ share of investment
contract liabilities	–	–	–	–	–	–	9,297	9,297	(32)	9,265
Cash and cash equivalents	1	1,453	5,820	82	–	–	2,130	9,486	(33)	9,453
	7,330	39,014	26,290	15,092	2,518	7,665	18,223	116,132	(1,044)	115,088

1 For financial assets that do not do not have credit ratings assigned by external ratings agencies, the Group assigns internal ratings for use in management and monitoring of credit

risk. £55 million of AAA, £865 million of AA, £1,837 million of A, £2,266 million of BBB and £240 million of BB and below debt securities are internally rated. If a financial asset is

neither rated by an external agency nor internally rated, it is classified as ‘non-rated’.

2 Non-rated debt securities includes equity release mortgages with a value of £4,795 million (further details are set out in note E2.3) and non-rated bonds.

Credit ratings have not been disclosed in the above tables for the assets of the unit-linked funds since the shareholder is not directly

exposed to credit risks from these assets. Included in unit-linked funds are assets which are held as reinsured external fund links.

Under certain circumstances, the shareholder may be exposed to losses relating to the default of the reinsured external fund link.

Credit ratings have not been disclosed in the above tables for holdings in unconsolidated collective investment schemes and

investments in associates. The credit quality of the underlying debt securities within these vehicles is managed by the safeguards

built into the investment mandates for these vehicles.

The Group maintains accurate and consistent credit ratings across its asset portfolio. This enables management to focus on the

applicable risks and to compare credit exposures across all lines of business, geographical regions and products. The rating system

is supported by a variety of financial analytics combined with market information to provide the main inputs for the measurement

of counterparty risk. All credit ratings are tailored to the various categories of assets and are assessed and updated regularly.

The Group operates an Asset Management Risk Committee, a Rating Committee and a Portfolio Credit Committee to monitor and

control oversight of internal credit ratings for externally rated and internally rated assets. A variety of methods are used to validate

the appropriateness of credit assessments from external institutions and fund managers. Internally rated assets are those that do

not have a public rating from an external credit rating agency (‘CRA’) or from external asset managers (where the methodology and

framework is assessed as being CRA comparable). Instead, internal credit ratings are used by the Group which are provided by fund

managers, or for certain assets (in particular, illiquid assets, including internal securitised loan notes securitising holdings in equity

release mortgages) are determined by the Life Companies. The Committees review the policies, processes and practices to ensure

the appropriateness of the internal ratings, and to ensure they are in line with regulatory requirements.

Throughout 2025, the Group has continued to undertake actions to maintain the overall credit quality of its asset portfolio and

mitigate the impact of future downgrades on risk capital. Additionally, the key change to credit risk exposure in the shareholder

portfolio continues to be the increased investment in illiquid credit assets, including Commercial Real Estate Loans (‘CREL’), Local

Authority Loans, Corporate and Infrastructure Loans. This is as a result of Pension Risk Transfer (‘PRT’) transactions with the aim of

achieving greater diversification and investment returns, consistent with the Strategic Asset Allocation and Risk Appetite approved

by the Board. A rise in gilt yields in the shareholder portfolio has increased the Gilt exposure, contributing positively to portfolio

performance. A further indicator of the quality of the Group’s financial assets is the extent to which they are neither past due nor

impaired. All of the amounts in the table above for the current and prior year are neither past due nor impaired.

Additional life company asset disclosures are included on page 330 and include information on the Group’s market exposure analysed

by credit rating, sector and country of exposure for the shareholder debt portfolio.

Impact of credit risk on value of financial liabilities designated at FVTPL

The fair value of investment contracts and net asset value attributable to unitholders liabilities are determined based upon the

performance of the assets backing those liabilities. This has the effect that the fair value of the liability primarily reflects asset-

specific performance risk rather than credit risk. As a result, the impact of credit risk on the fair value of financial liabilities designated

at FVTPL is not considered to be significant.

244 Annual Report and Accounts 2025

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Standard Life plc

Notes to the consolidated financial statements continued

Concentration of credit risk

Concentration of credit risk might exist where the Group or its insurance subsidiaries has significant exposure to an individual

counterparty or a group of counterparties with similar economic characteristics that would cause their ability to meet contractual

obligations to be similarly affected by changes in economic and other conditions. The Group has most of its counterparty risk within

its life business and this risk is monitored by the Group Credit Limit and Counterparty Framework which is governed by the Group

Credit Risk Policy. Concentration of credit risk is further provided for in investment management agreements, overlaid by regulatory

requirements and the monitoring of aggregate counterparty exposures across the Group against additional Group counterparty

limits. Counterparty risk in respect of over-the-counter derivative counterparties is monitored using a Potential Future Exposure

(‘PFE’) value metric.

The Group is also exposed to concentration risk with outsource partners. The Group operates a policy to manage outsourcer service

counterparty exposures and the impact from default is reviewed regularly by executive committees and measured through stress

and scenario testing.

Reinsurance

The Group is exposed to credit risk as a result of insurance risk transfer contracts with reinsurers. The Group’s policy is to place

reinsurance only with highly rated counterparties. The Group restricts concentration with individual external reinsurers by specifying

limits on ceding and minimum conditions for acceptance and retention of reinsurers. The Group has made progress in increasing the

number of reinsurers it transacts with, however, an element of concentration remains due to the nature of the reinsurance market

and the restricted range of reinsurers available. The Group manages its exposure to reinsurance credit risk through the operation of

a credit policy, collateralisation, and regular monitoring of exposures at the Reinsurance Management Committee and other credit

focused committees.

Collateral

The credit risk of the Group is mitigated, in certain circumstances, by entering into collateral agreements. The amount and type

of collateral required depends on an assessment of the credit risk of the counterparty. Guidelines are implemented regarding the

acceptability of types of collateral and the valuation parameters. Collateral is mainly obtained in respect of reinsurance, OTC

derivatives and securities lending activity. Management monitors the market value of the collateral received, requests additional

collateral when needed, and performs an impairment valuation when impairment indicators exist. See note E4 for further

information on collateral arrangements.

E6.2.2 Market risk

Market risk is the risk of loss or of adverse change in the Group’s financial situation resulting, directly or indirectly, from

fluctuations in the level and in the volatility of market prices of assets, liabilities and financial instruments. The risk typically arises

from exposure to equity, property and fixed income asset classes and the impact of changes in interest rates, inflation rates and

currency exchange rates.

The Group is mainly exposed to market risk as a result of:

• the mismatch between liability profiles and the related asset investment portfolios;

• the investment of assets held to meet regulatory capital and solvency requirements;

• the investment of surplus assets including shareholder reserves yet to be distributed and surplus assets within the with-profits

funds; and

• the income flow of management charges derived from the value of invested assets of the business.

The Group manages the levels of market risk that it accepts through the operation of a market risk policy using a number of controls

and techniques including:

• defined lists of permitted securities and/or application of investment constraints and portfolio limits;

• clearly defined investment benchmarks for policyholder and shareholder funds;

• stochastic and deterministic asset/liability modelling;

• active use of derivatives to improve the matching characteristics of assets and liabilities and to reduce the risk exposure

of a portfolio; and

• setting risk limits for main market risks and managing exposures against these appetites.

All operations comply with regulatory requirements relating to the taking of market risk.

Assets in the shareholder funds are managed against benchmarks that ensure they are diversified across a range of asset classes,

instruments and geographies that are appropriate to the liabilities of the funds or are held to match the cash flows anticipated to

arise in the business. A combination of limits by name of issuer, sector, geographical region and credit rating are used where relevant

to reduce concentration risk among the assets held.

E. Financial assets & liabilities continued

E6. Risk management – financial and other risks continued

E6.2 Financial risk analysis continued

E6.2.1 Credit risk continued

245Annual Report and Accounts 2025

Financials

Standard Life plc

The assets of the with-profits business are principally managed to support the liabilities of the with-profits business and are

appropriately diversified by both asset class and geography, considering:

• the economic liability and how this varies with market conditions;

• the need to invest assets supporting with-profits business in a manner consistent with the with-profits policyholders’ reasonable

expectations and Principles and Practices of Financial Management (‘PPFM’); and

• the need to ensure that regulatory and capital requirements are met.

In practice, an element of market risk arises as a consequence of the need to balance these considerations, for example, in certain

instances with-profits policyholders may expect that equity market risk will be taken on their behalf, and derivative instruments may

be used to manage these risks.

Markets retain the potential to be volatile particularly given geopolitical instability, with escalation of regional conflicts and

increasing protectionist policies able to result in increased inflationary pressures due to global policy changes and supply change

disruption. More detail is covered within the Principal Risks section within the Strategic Report.

Interest rate and inflation risk

Interest rate risk is the risk that the fair value of future cash flows of a financial instrument will fluctuate relative to the respective

liability due to the impact of changes in market interest rates on the value of interest-bearing assets and on the value of future

guarantees provided under certain contracts of insurance. The paragraphs in this section also apply to inflation risk, but references

to fixed rate assets and liabilities would be replaced with index-linked assets and liabilities.

The Group is required to manage its interest rate exposures in line with qualitative risk appetite statements, quantitative risk metrics

and any additional hedging benchmarks. Interest rate risk is managed by matching assets and liabilities where practicable and by

entering into derivative arrangements for hedging purposes where appropriate. This is particularly the case for the non-participating

funds and supported participating funds. The market risks arising from participating business are born primarily by the with-profits

policyholders. Market risk exposures, including the exposure to interest rate risk, are set with the aims of (i) ensuring that the

with-profits funds are strong enough to honour guarantees and to smooth investment returns, and (ii) to optimise the risks and

returns for with-profits policyholders, taking into account previous undertakings made to policyholders as well as legal and

regulatory requirements. In practice, the life companies of the Group maintain an appropriate mix of fixed and variable rate

instruments according to the underlying insurance or investment contracts and will review this at regular intervals to ensure that

overall exposure is kept within the risk profile agreed for each particular fund. This also requires the maturity profile of these assets

to be managed in line with the liabilities to policyholders.

The sensitivity analysis for interest rate and inflation risk indicates how changes in the fair value or future cash flows of a financial

instrument arising from changes in market interest and inflation rates at the reporting date result in a change in profit after tax,

equity and CSM. It takes into account the effect of such changes in market interest and inflation rates on all assets and liabilities that

contribute to the Group’s reported profit after tax and in equity.

With-profits business and non-participating business within the with-profits funds are exposed to interest rate risk as guaranteed

liabilities are valued relative to market interest rates and investments include fixed interest securities and derivatives. For

unsupported with-profits business the profit or loss arising from mismatches between such assets and liabilities is largely offset by

increased or reduced discretionary policyholder benefits dependent on the existence of policyholder guarantees. The contribution

of unsupported participating business to the Group result is largely limited to the shareholders’ share of bonuses, which under IFRS

17 are recognised over the life of the contracts. The contribution of the supported participating business to the Group result is

determined in line with IFRS 17, which exposes the shareholder to changes in the value of the liabilities backed by shareholder assets

and the value of capital advanced to the with-profits funds.

In the non-participating funds, policy liabilities’ sensitivity to interest rates are matched primarily with debt securities and hedging if

necessary to match duration on a regulatory basis for the Group’s Solvency II position, with the result that sensitivity to changes in

interest rates is very low. The Group’s exposure to interest rates on an IFRS basis principally arises from the Group’s hedging strategy

to protect the regulatory capital position, which results in an adverse impact on profit following an increase in interest rates.

The Group is exposed to inflation risk through certain contracts, such as annuities, which may provide for future benefits to be paid

taking account of changes in the level of experienced and implied inflation, and also through the Group’s cost base. The Group seeks

to manage inflation risk within the ALM framework through the holding of derivatives, such as inflation swaps, or physical positions

in relevant assets, such as index-linked gilts, where appropriate.

The interest rate sensitivity reflects a 100bps change in risk-free yields at each time step on the risk-free curve applied to assets and

liabilities as at the balance sheet date. The illiquidity premium used in the measurement of insurance contracts, and associated

reinsurance contracts, as an addition to the risk-free curve does not change as a result of this sensitivity.

246 Annual Report and Accounts 2025

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Standard Life plc

Notes to the consolidated financial statements continued

			2025			2024
		Impact on			Impact on
		profit after	Impact on	Impact on	profit after	Impact on	Impact on
	Change in	tax	equity	CSM	tax	equity	CSM
	interest rate	£m	£m	£m	£m	£m	£m
Insurance contract and reinsurance contract balances	+100bps	3,877	3,877	5	3,717	3,717	3
Investment contract without DPF balances	+100bps	1,974	1,974	–	2,097	2,097	–
Financial assets subject to interest rate risk backing
insurance and reinsurance contract balances	+100bps	(4,167)	(4,167)	–	(3,991)	(3,991)	–
Financial assets subject to interest rate risk backing
investment contract without DPF balances	+100bps	(1,974)	(1,974)	–	(2,095)	(2,095)	–
Other financial assets subject to interest rate risk	+100bps	(182)	(182)	–	(168)	(168)	–
Pension scheme liability	+100bps	–	114	–	–	127	–
Total (decrease)/increase		(472)	(358)	5	(440)	(313)	3
Insurance contract and reinsurance contract balances	-100bps	(4,355)	(4,355)	2	(4,493)	(4,493)	(12)
Investment contract without DPF balances	-100bps	(2,191)	(2,191)	–	(2,431)	(2,431)	–
Financial assets subject to interest rate risk backing
insurance and reinsurance contract balances	-100bps	4,716	4,716	–	4,885	4,885	–
Financial assets subject to interest rate risk backing
investment contract without DPF balances	-100bps	2,191	2,191	–	2,428	2,428	–
Other financial assets subject to interest rate risk	-100bps	182	182	–	169	169	–
Pension scheme liability	-100bps	–	(137)	–	–	(155)	–
Total increase/(decrease)		543	406	2	558	403	(12)

The inflation sensitivity reflects a 100bps change in future inflation rates at each time step on the inflation curve, with no change in

the risk-free interest rate curve. The illiquidity premium used in the measurement of insurance contracts, and associated reinsurance

contracts, as an addition to the risk-free interest rate curve is adjusted to reflect the impact on values of inflation-linked instruments

included within the reference portfolio used to determine the illiquidity premium.

			2025			2024
		Impact on			Impact on
		profit after	Impact on	Impact on	profit after	Impact on	Impact on
	Change in	tax	equity	CSM	tax	equity	CSM
	inflation	£m	£m	£m	£m	£m	£m
Insurance contract and reinsurance contract balances	+100bps	(1,358)	(1,358)	(15)	(1,184)	(1,184)	(30)
Investment contract without DPF balances	+100bps	(18)	(18)	–	(16)	(16)	–
Financial assets subject to inflation risk backing
insurance and reinsurance contract balances	+100bps	1,775	1,775	–	1,673	1,673	–
Financial assets subject to inflation risk backing
investment contract without DPF balances	+100bps	18	18	–	16	16	–
Pension scheme liability	+100bps	–	(99)	–	–	(114)	–
Total increase/(decrease)		417	318	(15)	489	375	(30)
Insurance contract and reinsurance contract balances	-100bps	1,199	1,199	16	1,137	1,137	22
Investment contract without DPF balances	-100bps	15	15	–	14	14	–
Financial assets subject to inflation risk backing
insurance and reinsurance contract balances	-100bps	(1,491)	(1,491)	–	(1,393)	(1,393)	–
Financial assets subject to inflation risk backing
investment contract without DPF balances	-100bps	(15)	(15)	–	(14)	(14)	–
Pension scheme liability	-100bps	–	93	–	–	109	–
Total (decrease)/increase		(292)	(199)	16	(256)	(147)	22

E. Financial assets & liabilities continued

E6. Risk management – financial and other risks continued

E6.2 Financial risk analysis continued

E6.2.2 Market risk continued

247Annual Report and Accounts 2025

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Standard Life plc

Equity and property risk

The Group is exposed to the risk of reductions in the valuation of equities (or changes in the volatility) or property investments which

could result in reductions in asset values and losses for policyholders or shareholders. In this context, equity assets should be taken

to include shares, equity derivatives, equity collectives and unlisted equities. Property assets include direct property investment,

shares in property companies, property collectives and structured property assets.

The portfolio of marketable equity securities and property investments which is carried in the statement of consolidated financial

position at fair value has exposure to price risk. The Group’s objective in holding these assets is to earn higher long-term returns by

investing in a diverse portfolio of equities and properties. Portfolio characteristics are analysed regularly, and price risks are actively

managed in line with investment mandates. The Group’s holdings are diversified across industries and concentrations in any one

company or industry are limited.

Equity and property price risk is primarily borne in respect of assets held in with-profits funds, unit-linked funds or equity release

mortgages in the non-profit funds. For unit-linked funds this risk is borne by policyholders and asset movements directly impact

unit prices and hence policy values. For with-profits funds policyholders’ future bonuses will be impacted by the investment

returns achieved and hence the price risk, whilst the Group also has exposure to the value of guarantees provided to with-profits

policyholders. In addition, some equity investments are held in respect of shareholders’ funds. For the non-profit fund property price

risk from equity release mortgages is borne by the Group with the aim of achieving greater diversification and investment returns,

consistent with the Strategic Asset Allocation approved by the Board. The Group as a whole is exposed to price risk fluctuations

impacting the income flow of management charges from the invested assets of all funds; this is primarily managed through the

use of derivatives.

Equity and property price risk is managed through the agreement and monitoring of financial risk profiles that are appropriate for

each of the Group’s life funds in respect of maintaining adequate regulatory capital and Consumer Duty. This is largely achieved

through asset class diversification and within the Group’s ALM framework through the holding of derivatives or physical positions

in relevant assets where appropriate.

The shareholders’ exposure to equity risk principally arises from the Group’s hedging strategy to protect the regulatory capital

position, which results in an adverse impact on profit on an increase in equity prices.

The sensitivity analysis for equity and property price risk illustrates how a change in the fair value of equities and properties affects

the Group result. It takes into account the effect of such changes in equity and property prices on all assets and liabilities that

contribute to the Group’s reported profit after tax and in equity.

The equity sensitivity represents a 10% change in equity prices at the balance sheet date. This is applied to investment assets/

liabilities and to policyholder liabilities directly measured with reference to the value of backing equities, such as investment contract

liabilities, unit-linked insurance contracts and with-profits contracts, and associated reinsurance contracts. The illiquidity premiums

used in the measurement of insurance contracts do not change as a result of this sensitivity.

			2025			2024
		Impact on			Impact on
	Change in	profit after	Impact on	Impact on	profit after	Impact on	Impact on
	equity	tax	equity	CSM	tax	equity	CSM
	prices	£m	£m	£m	£m	£m	£m
Insurance contract and reinsurance contract balances	+10%	(2,552)	(2,552)	47	(2,239)	(2,239)	44
Investment contract without DPF balances	+10%	(9,993)	(9,993)	–	(8,197)	(8,197)	–
Financial assets subject to equity price risk backing
insurance and reinsurance contract balances	+10%	2,623	2,623	–	2,293	2,293	–
Financial assets subject to equity price risk backing
Investment contract without DPF balances	+10%	9,881	9,881	–	8,107	8,107	–
Other financial assets subject to equity price risk	+10%	(218)	(218)	–	(209)	(209)	–
Total (decrease)/increase		(259)	(259)	47	(245)	(245)	44
Insurance contract and reinsurance contract balances	-10%	2,571	2,571	(33)	2,274	2,274	(50)
Investment contract without DPF balances	-10%	10,071	10,071	–	8,301	8,301	–
Financial assets subject to equity price risk backing
insurance and reinsurance contract balances	-10%	(2,653)	(2,653)	–	(2,328)	(2,328)	–
Financial assets subject to equity price risk backing
Investment contract without DPF balances	-10%	(9,955)	(9,955)	–	(8,208)	(8,208)	–
Other financial assets subject to equity price risk	-10%	220	220	–	211	211	–
Total increase/(decrease)		254	254	(33)	250	250	(50)

The property sensitivity represents a 10% change in property prices at the balance sheet date. This is applied to investment assets/

liabilities and to policyholder liabilities directly measured with reference to the value of backing property assets, such as investment

contract liabilities, unit-linked insurance contracts and with-profits contracts, and associated reinsurance contracts. The illiquidity

premium used in the valuation of primarily annuity liabilities, and associated reinsurance contracts, is adjusted to reflect the impact

of property values on the change in spreads arising on equity release mortgage assets held within the reference portfolio.

248 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

			2025			2024
		Impact on			Impact on
	Change in	profit after	Impact on	Impact on	profit after	Impact on	Impact on
	property	tax	equity	CSM	tax	equity	CSM
	prices	£m	£m	£m	£m	£m	£m
Insurance contract and reinsurance contract balances	+10%	(143)	(143)	1	(121)	(121)	3
Investment contract without DPF balances	+10%	(297)	(297)	–	(291)	(291)	–
Financial assets subject to property price risk backing
insurance and reinsurance contract balances	+10%	209	209	–	181	181	–
Financial assets subject to property price risk backing
Investment contract without DPF balances	+10%	297	297	–	291	291	–
Total increase		66	66	1	60	60	3
Insurance contract and reinsurance contract balances	-10%	136	136	(1)	114	114	(4)
Investment contract without DPF balances	-10%	300	300	–	296	296	–
Financial assets subject to property price risk backing
insurance and reinsurance contract balances	-10%	(229)	(229)	–	(190)	(190)	–
Financial assets subject to property price risk backing
Investment contract without DPF balances	-10%	(300)	(300)	–	(296)	(296)	–
Total decrease		(93)	(93)	(1)	(76)	(76)	(4)

The sensitivity to changes in equity prices is primarily driven by the Group’s equity hedging arrangements over the value of future

management charges that are linked to asset values.

Currency risk

Currency risk is the risk that changes in the value of currencies could lead to reductions in asset values which may result in losses for

policyholders and shareholders. With the exception of Standard Life International business sold in Germany and the Republic of

Ireland and some historic business written in the Republic of Ireland, the Group’s principal transactions are carried out in sterling.

The assets for these books of business are generally held in the same currency denomination as their liabilities, therefore, any

foreign currency mismatch is largely mitigated. Consequently, the foreign currency risk relating to this business mainly arises when

the assets and liabilities are translated into sterling.

The Group’s financial assets are primarily denominated in the same currencies as its insurance and investment liabilities. Thus, the

main foreign exchange risk arises from recognised assets and liabilities denominated in currencies other than those in which

insurance and investment liabilities are expected to be settled and, indirectly, from the non-UK earnings of UK companies.

Both the with-profits and non-profit funds have some exposure to overseas assets which is not driven by liability considerations.

The purpose of this exposure is to reduce overall risk whilst maximising returns by diversification. This exposure is limited and

managed through investment mandates which are subject to the oversight of the investment committees of the Boards of each

insurance subsidiary, and in the case of the with-profits funds consistent with policyholders’ reasonable expectations and PPFM.

Fluctuations in exchange rates from certain holdings in overseas assets are hedged against currency risks.

The Group has in place a number of cross currency swaps which were designated as hedging instruments in order to effect cash flow

hedges of the Group’s Euro and US Dollar denominated borrowings.

E6.2.3 Financial soundness risk

Financial soundness risk is a broad risk category encompassing capital management risk, tax risk and liquidity and funding risk.

Capital management risk

Capital management risk is defined as the risk of reductions in earnings and/or value, through financial or reputational loss, due to

a failure to maintain sufficient capital to provide appropriate security for policyholders and meet all regulatory capital requirements

whilst not retaining unnecessary capital. The Group has exposure to capital management risk through the regulatory capital

requirements mandated by the PRA. The Group’s approach to managing capital management risk is described in detail in note I3.

Tax risk

Tax risk is defined as the risk of reductions in earnings and/or value, through financial or reputational loss, due to an unforeseen tax

cost, or by the inappropriate reporting and disclosure of information in relation to taxation. Tax risk can be caused by:

• the Group, or one of its subsidiaries, making a material error in its tax reporting;

• incorrect calculation of tax provisions;

• failure to implement the optimum financial arrangements to underpin a commercial transaction; and

• incorrect operation of policyholder tax requirements.

E. Financial assets & liabilities continued

E6. Risk management – financial and other risks continued

E6.2 Financial risk analysis continued

E6.2.2 Market risk continued

249Annual Report and Accounts 2025

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Standard Life plc

Tax risk is managed by maintaining an appropriately-staffed tax team who have the qualifications and experience to make

judgements on tax issues, augmented by advice from external specialists where required. In addition, the Group has a formal tax risk

policy, which sets out its risk appetite in relation to specific aspects of tax risk, and which details the controls the Group has in place

to manage those risks.

Liquidity and funding risk

Liquidity risk is defined as failure to maintain adequate levels of financial resources to meet obligations as they fall due. Funding risk

relates to the potential inability to raise additional capital or liquidity when required in order to maintain the resilience of the balance

sheet. The Group has exposure to liquidity risk as a result of servicing its external debt and equity investors, and from the operating

requirements of its subsidiaries. The Group’s subsidiaries have exposure to liquidity risk as a result of normal business activities,

specifically the risk arising from an inability to meet short-term cash flow requirements and to meet obligations to policy liabilities.

The Board of Standard Life plc has defined a number of governance objectives and principles and the liquidity risk frameworks of

each subsidiary are designed to ensure that:

• liquidity risk is managed in a manner consistent with the subsidiary company Boards’ strategic objectives, risk appetite and PPFM;

• cash flows are appropriately managed and the reputation of the Group is safeguarded; and

• appropriate information on liquidity risk is available to those making decisions.

The Group’s liquidity risk management strategy is based on a risk appetite of less than a 1 in 200 chance of having insufficient liquid

or tangible assets to meet financial obligations as they fall due and is supported by:

• holding appropriate assets to meet liquidity buffers;

• holding high quality liquid assets to support day to day operations;

• an effective stress testing framework to ensure survival horizons are met under different severe, but plausible scenarios;

• effective liquidity portfolio management including Early Warning Indicators; and

• liquidity risk contingency planning.

The Group’s funding strategy aims to maintain the appropriate level of debt and equity in order to support the Group’s organic and

inorganic growth ambitions, while maintaining sufficient headroom for hybrid capital under regulatory rules.

Liquidity forecasts showing headroom against liquidity buffers are prepared regularly to predict required liquidity levels over both

the short and medium-term allowing management to respond appropriately to changes in circumstances. In the event of a liquidity

shortfall, either current or projected, this would be managed in line with the Group’s Contingency Liquidity Plan where the latest

available contingency management actions would be considered.

In extreme circumstances, the Group could be exposed to liquidity risk in its unit-linked funds. This could occur where a high volume

of surrenders coincides with a tightening of liquidity in a unit-linked fund to the point where assets of that fund have to be sold to

meet those withdrawals. Where the fund affected consists of less liquid assets such as property, it can take several months to

complete a sale and this would impede the proper operation of the fund. In these situations, the Group considers its risk to be low

since there are steps that can be taken first within the funds themselves both to ensure the fair treatment of all investors in those

funds and to protect the Group’s own risk exposure.

The vast majority of the Group’s derivative contracts are traded OTC and have a two-day collateral settlement period. The Group’s

derivative contracts are monitored daily, via an end-of-day valuation process, to assess the need for additional funds to cover margin

or collateral calls.

Some of the Group’s commercial property investments, cash and cash equivalents are held through collective investment schemes.

The collective investment schemes have the power to restrict and/or suspend withdrawals, which would, in turn, affect liquidity.

The following table provides a maturity analysis showing the remaining contractual maturities of the Group’s undiscounted financial

liabilities and associated interest.

	1 year or			Greater
	less or on			than 10	No fixed
	demand	1–5 years	6–10 years	years	term	Total
2025	£m	£m	£m	£m	£m	£m
Investment contracts	191,269	–	–	–	–	191,269
Borrowings 1	583	2,172	1,212	–	22	3,989
Derivatives 1	219	301	983	23,205	–	24,708
Net asset value attributable to unitholders	2,334	–	–	–	–	2,334
Obligations for repayment of collateral received	839	–	–	–	–	839
Lease liabilities 1	12	37	18	1	–	68
Accruals and deferred income	526	26	13	–	–	565
Other payables	2,398	26	5			2,429

250 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

							Less
							amounts
	1 year or less						classified as
	or on			Greater than	No fixed		held for sale
	demand	1–5 years	6 –10 years	10 years	term	Total	(see note H2)	Total
2024	£m	£m	£m	£m	£m	£m	£m	£m
Investment contracts	173,922	–	–	–	–	173,922	(3,175)	170,747
Borrowings 1	483	2,767	1,303	–	31	4,584	–	4,584
Derivatives 1	641	245	745	8,372	–	10,003	–	10,003
Net asset value attributable to unitholders	2,486	–	–	–	–	2,486	–	2,486
Obligations for repayment
of collateral received	849	–	–	–	–	849	–	849
Lease liabilities 1	13	30	17	17	–	77	–	77
Accruals and deferred income	545	25	13	–	–	583	–	583
Other payables	2,280	–	–	–	–	2,280	–	2,280

1 These financial liabilities are disclosed at their undiscounted value and therefore differ from amounts included in the statement of consolidated financial position which discloses

the discounted value.

Investment contract policyholders have the option to terminate or transfer their contracts at any time and to receive the surrender or

transfer value of their policies. Although these liabilities are payable on demand, and are therefore included in the contractual maturity

analysis as due within one year, the Group does not expect all these amounts to be paid out within one year of the reporting date.

The following tables present the estimated amount and timing of the remaining contractual discounted cash flows arising from

insurance contract liabilities.

	Up to 1 year	1–2 years	2-3 years	3-4 years	4-5 years	>5 years	Total
2025	£m	£m	£m	£m	£m	£m	£m
Insurance contract liabilities	7,640	5,255	5,429	5,537	5,391	84,171	113,423

	Up to 1 year	1–2 years	2-3 years	3-4 years	4-5 years	>5 years	Total
2024	£m	£m	£m	£m	£m	£m	£m
Insurance contract liabilities	8,054	5,183	4,585	4,916	5,282	81,334	109,354

The following table sets out the amounts that are payable on demand and the carrying value of the related portfolios of insurance

contracts (shown net of reinsurance).

		2025		2024
	Amounts payable	Carrying value of	Amounts payable	Carrying value of
	on demand	portfolio	on demand	portfolio
	£m	£m	£m	£m
With-profits	(42,990)	(49,852)	(42,695)	(49,233)
Annuities	(7,781)	(36,560)	(6,564)	(36,513)
Unit-linked	(18,975)	(18,673)	(17,773)	(17,016)
Protection	(375)	(910)	(384)	(975)
Short-term payables and receivables (including deposits from reinsurers)	(4,462)	(4,462)	(3,248)	(3,248)
	(74,583)	(110,457)	(70,664)	(106,985)

A significant proportion of the Group’s financial assets are held in gilts, cash, supranationals and investment grade securities which

the Group considers sufficient to meet the liabilities as they fall due. The vast majority of these investments are readily realisable

immediately since most of them are quoted in an active market.

The Group has a set of established policies and processes to manage its exposure to liquidity risk, including impacts arising from the

economic environment, business developments and funding changes. Where liquidity risk is heightened, such as during periods of

significant market volatility, triggers are in place to enhance the frequency of liquidity monitoring and to implement available

contingency actions to ensure sufficient liquidity is maintained.

E6.2.4 Strategic risk

Strategic risks threaten the achievement of the Group strategy through poor strategic decision-making, implementation or response

to changing circumstances. The Group recognises that core strategic activity brings with it exposure to strategic risk. However, the

Group seeks to proactively review, manage and control these exposures.

The Group’s strategy and business plan are exposed to external events that could prevent or impact the achievement of the strategy;

events relating to how the strategy and business plan are executed; and events that arise as a consequence of following the specific

strategy chosen. The identification and assessment of strategic risks is an integrated part of the Risk Management Framework.

E. Financial assets & liabilities continued

E6. Risk management – financial and other risks continued

E6.2 Financial risk analysis continued

E6.2.3 Financial soundness risk continued

251Annual Report and Accounts 2025

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Standard Life plc

Strategic risk should be considered in parallel with the Risk Universe as each of the risks within the Risk Universe can impact the

Group’s strategy.

A Strategic Risk Policy is maintained and reported against regularly, with a particular focus on risk management, stakeholder

management, corporate activity and overall reporting against the Group’s strategic ambitions.

E6.2.5 Operational risk

Operational risk is the risk of reductions in earnings and/or value, through financial or reputational loss, from inadequate or failed

internal processes and systems, or from people-related or external events. Operational risk arises due to failures in one or more of

the following aspects of our business:

• indirect exposures through outsourcing service providers and suppliers;

• direct exposures through internal practices, actions or omissions;

• external threats from individuals or groups focused on malicious or criminal activities, or on external events occurring which are

not within the Group’s control; and

• negligence, malpractice or failure of employees to follow good practice in delivering operational processes and practices.

It is accepted that it is neither possible, appropriate nor cost effective to eliminate all operational risks from the business as

operational risk is inherent in any operating environment particularly given the regulatory framework under which the Group

operates. As such the Group will tolerate a degree of operational risk subject to appropriate and proportionate levels of control

around the identification, management and reporting of such risks. A set of operational risk policies are maintained that set out the

nature of the operational risk exposure and key controls in place to mitigate the risk.

E6.2.6 Customer risk

Customer risk is the risk of financial failure, reputational loss, loss of earnings and/or value through inappropriate or poor customer

treatment (including poor advice). It can arise as a result of:

• Customer Outcomes: The risk that our decisions, actions or behaviors individually or collectively result in a failure to act to deliver

good outcomes for our customers.

The Group has both a Conduct Risk appetite to focus on behaviours within the business, and a Customer Risk appetite to focus on

achieving good customer outcomes in accordance with Consumer Duty regulatory requirements. The behaviours and standards all

colleagues are expected to achieve are detailed in our Group Code of Conduct. For our customers, what represents a good outcome

is articulated in our Customer Standards and supporting Business Unit processes. In addition, the Group Conduct Strategy, which

overarches our Risk Universe and all risk policies is designed to help the Group meet its aim of helping people secure a lifetime of

possibilities. It seeks to do this by putting customers at the heart of our strategy and decision making, achieving good customer

outcomes and preventing foreseeable harm.

The Group also has a suite of supporting customer frameworks which set out how good customer outcomes are delivered.

The customer risks for the Group are regularly reported to management oversight committees.

F. Insurance contracts, investment contracts with DPF and reinsurance

F1. Liabilities under insurance contracts

Classification

Contracts under which the Group accepts significant insurance risk are classified as insurance contracts. Contracts held by the

Group under which it transfers significant insurance risk related to underlying insurance contracts are classified as reinsurance

contracts. Some contracts entered into by the Group have the legal form of insurance contracts but do not transfer significant

insurance risk and expose the Group to financial risk. These contracts are classified as financial liabilities and are referred to as

investment contracts.

All references in these accounting policies to insurance contracts and reinsurance contracts include contracts issued, initiated or

acquired by the Group, unless otherwise stated.

Insurance contracts are classified as direct participating contracts or contracts without direct participation features. Direct

participating contracts are contracts for which, at inception:

• the contractual terms specify that the policyholder participates in a share of a clearly identified pool of underlying items;

• the Group expects to pay to the policyholder an amount equal to a substantial share of the fair value returns on the underlying

items; and

• the Group expects a substantial proportion of any change in the amounts to be paid to the policyholder to vary with the change

in fair value of the underlying items.

All other insurance contracts and all reinsurance contracts are classified as contracts without direct participation features.

Some investment contracts issued by the Group contain discretionary participation features (‘DPF’), whereby the investor has the

right and is expected to receive, as a supplement to the amount not subject to the Group’s discretion, potentially significant

additional benefits based on the return of specified pools of investment assets. The Group accounts for these contracts under IFRS

17 consistent with insurance contracts.

252 Annual Report and Accounts 2025

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Standard Life plc

Notes to the consolidated financial statements continued

The classification assessment is made at the date of inception or for business combinations or portfolio transfers, as at the date of

acquisition. Once a contract is assessed as insurance, investment with DPF or reinsurance, the classification continues until the

contract is derecognised or modified.

When considering classification, and applying the provisions of IFRS 17, the Group identifies a contract as the smallest unit of

account. The Group also makes an evaluation of whether a series of contracts can be treated together in applying IFRS 17 based

on reasonable and supportable information, or whether a single contract contains components that need to be separated and

treated as if they were stand-alone contracts.

Accounting treatment

Separating components from insurance and reinsurance contracts

The Group assesses its insurance products to determine whether they contain components, which must be accounted for under

accounting standards other than IFRS 17 (distinct non-insurance components).

Where an insurance contract has a distinct investment component and meets the separation criteria established under IFRS 17,

the investment component is separated from the host contract and accounted for under IFRS 9. The assessment of whether a

contract has a distinct investment component is carried out at inception of the contract, or the date of acquisition in the case of

a business combination.

When assessing whether the investment component is distinct, the Group considers the following, which may indicate that the

insurance and investment component are highly interrelated:

• the value of one component varies with the other component;

• existence of an option to switch between the different components;

• discounts that span both elements e.g. a reduced asset management charge based on total size of contract; and

• other interacting features e.g. insurance risk from premium waivers and return of premium covering both elements of the policy.

After separating any distinct components, the Group applies the requirements of IFRS 17 to all remaining components of the

insurance contract or where distinct criteria are not met, the whole contract is accounted for within IFRS 17.

Level of aggregation

The Group is required to divide its business into groups for the purposes of recognition and measurement. The Group’s business is

firstly split into portfolios. Portfolios contain groups of contracts with similar risks, which are managed together. Portfolios are

further divided based on expected profitability at inception into three categories: onerous contracts, contracts that are profitable

at initial recognition and have no significant risk of becoming onerous, and the remaining profitable contracts. For reinsurance

contracts the same three groups would be identified with ‘onerous’ being replaced with ‘net gain’ and ‘profitable’ being replaced

with ‘net cost’. Contracts which are issued more than one year apart are not permitted to be included within the same group.

However as permitted by IFRS 17, the groups of contracts for which the Fair Value Approach (‘FVA’) has been adopted on transition

include contracts issued more than one year apart.

The Group has defined portfolios of insurance and reinsurance contracts issued broadly based on the predominant risks inherent in

the products/contracts, for example, longevity, persistency, mortality, and by considering whether groups of products are

managed together. These portfolios are further split by legal entity, with-profits fund and contracts subject to different IFRS 17

measurement models are grouped separately. The portfolios are allocated to cohorts based on whether they are onerous at

inception or based on their expected level of profitability using information available at inception.

For reinsurance contracts held, portfolios are based upon similar risks to those of the underlying contracts. The reinsurance

contracts held are assessed for aggregation requirements on an individual contract basis.

The grouping of the insurance contracts is determined at initial recognition and is not subsequently reassessed. Therefore,

a contract will remain within the assigned aggregation group until it is derecognised, either by expiry or modification.

Recognition

The Group recognises groups of insurance contracts that it issues from the earliest of the following:

• the beginning of the coverage period of the group of contracts;

• the date when the first payment from the policyholder in the group is due or actually received if there is no due date; or

• for a group of onerous contracts, as soon as facts and circumstances indicate that the group is onerous.

Investment contracts with DPF are initially recognised at the date when the Group becomes a party to the contract.

Insurance contracts acquired in a business combination within the scope of IFRS 3 Business Combinations or a portfolio transfer are

accounted for as if they were entered into at the date of acquisition or transfer.

F. Insurance contracts, investment contracts with DPF and reinsurance continued

F1. Liabilities under insurance contracts continued

253Annual Report and Accounts 2025

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Standard Life plc

Reinsurance contracts held are recognised from the earliest of the following:

• the beginning of the coverage period of the group of reinsurance contracts held. However, the Group delays the recognition of

a group of reinsurance contracts held that provide proportionate coverage (for example, through a quota share arrangement)

until the date when any underlying insurance contract is initially recognised, if that date is later than the beginning of the

coverage period of the group of reinsurance contracts held; and

• the date the Group recognises an onerous group of underlying insurance contracts if the Group entered into the related

reinsurance contract held in the group of reinsurance contracts held at or before that date.

The Group adds new contracts to the group in the reporting period in which that contract meets one of the criteria set out above.

Contract boundaries

The Group includes in the measurement of a group of insurance contracts all the future cash flows within the boundary of each

contract in the group. Cash flows are within the boundary of an insurance contract if they arise from the rights and obligations that

exist during the period in which the policyholder is obligated to pay premiums or the Group has a substantive obligation to provide

the policyholder with insurance contract services. A substantive obligation to provide insurance contract services ends when:

• the Group has the practical ability to reprice the risks of the particular policyholder or change the level of benefits so that the

price fully reflects those risks; or

• both of the following criteria are satisfied:

– the Group has the practical ability to reprice the contract or a portfolio of contracts so that the price fully reflects the

reassessed risk of that portfolio; and

– the pricing of premiums up to the date when risks are reassessed does not reflect the risks related to periods beyond the

reassessment date.

Where an expected premium or expected claim is not within the contract boundary, it is not recognised as a cash flow of the contract

and is instead considered to relate to a future insurance contract and recognised when those contracts meet the recognition criteria.

The contract boundary is reassessed at each reporting date to include the effect of changes in circumstances on the Group’s

substantive rights and obligations and, therefore, may change over time.

The contract boundary for a reinsurance contract is dependent on the terms and conditions of the reinsurance contract and

therefore may not necessarily be the same as for the underlying contracts. Where the reinsurance contract is open to new business

on agreed terms for a period of time, the contract boundary may include estimates of reinsurance on insurance contracts that have

not yet been issued or reported.

Measurement

The Group’s insurance contracts issued without direct participation features are grouped together under annuity, protection and

other non-linked insurance business. These groups of insurance contract are measured under the General Model (‘GM’).

Direct participating contracts issued by the Group are contracts with direct participation features where the Group holds the pool

of underlying assets. Direct participating insurance contracts are grouped together and reported primarily as either unit-linked or

with-profits business although some protection contracts are considered to have direct participation features. These groups of

contracts are measured using the variable fee approach (‘VFA’), unless they fail the eligibility test to be treated under this

approach, in such circumstances they are measured under the GM.

Reinsurance contracts held are measured under the GM irrespective of the measurement model used for the underlying contracts.

Certain with-profits funds within the Group hold non-profit insurance business such as annuities. This business will also be

measured under the GM.

Initial measurement – Insurance contracts

On initial recognition, the Group measures a group of insurance contracts as the total of (a) the fulfilment cash flows and a risk

adjustment for non-financial risk; and (b) the contractual service margin (‘CSM’). The fulfilment cash flows of a group of insurance

contracts do not reflect the Group’s non-performance risk.

The fulfilment cash flows comprise:

• unbiased and probability-weighted estimates of future cash flows that are within the contract boundary plus an adjustment to

reflect the time value of money and the financial risks related to future cash flows, to the extent that the financial risks are not

included in the estimates of future cash flows (‘BEL’); and

• a risk adjustment for non-financial risk.

The measurement of fulfilment cash flows includes insurance acquisition cash flows which are allocated as a portion of premium

to profit or loss (through insurance revenue) over the period of the contract in a systematic and rational way based on the passage

of time.

254 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

The risk adjustment for non-financial risk for a group of insurance contracts, determined separately from the other estimates, is

the compensation required for bearing uncertainty about the amount and timing of the cash flows that arises from non-financial

risk. The Group applies a confidence level technique. The risk adjustment is allocated to groups of contracts based on an analysis of

the risk profiles of the groups, reflecting the effects of the diversification benefits between Group entities to the extent that the

Group includes it when determining the compensation required to bear that risk. The Group includes diversification between

Group entities which use the Group Internal Model for management decision-making. Where a Standard Formula approach is used,

no diversification with other entities within the Group is allowed for. The Group determines the risk adjustment using a one-year

time horizon, consistent with the time horizon used for Solvency II, a key metric underlying how the Group is managed.

The CSM of a group of insurance contracts represents the unearned profit that the Group will recognise over the life of the

contract as insurance and investment-related services are provided. For profitable groups of insurance contracts the CSM is

established to ensure that no profit or loss is recognised at inception and consequently it offsets the net present value of the

expected cash flows (including initial premium and insurance acquisition cash flows) and the risk adjustment. For a group of

insurance contracts that are onerous, the CSM is set to nil and a loss is immediately recognised in profit or loss. A loss component

of the liability for remaining coverage (‘LRC’) is established for the amount of loss recognised.

The initial recognition of the CSM is consistent for insurance contracts applying the GM and VFA measurement approaches,

however there are key differences for subsequent measurement of the CSM under these measurement models.

For groups of contracts acquired in a transfer of contracts or a business combination, the consideration received for the contracts

is included in the fulfilment cash flows as a proxy for the premiums received at the date of acquisition. In a business combination,

the consideration received is the fair value of the contracts at that date.

With-profits estate

The Group has a number of with-profits funds where surpluses are shared between policyholders and shareholders. All such funds

are closed to new business. These funds typically have an estate, being a surplus of assets over those needed to meet the liabilities

of current policyholders. As these funds are closed to new business, the surplus is expected to be distributed to existing

policyholders over time and the Group has determined it appropriate to allocate the expected future policyholder payments from

the estate to specific groups of contracts within the measurement of the best estimate cash flows.

Subsequent measurement – Insurance contracts

The carrying amount of a group of insurance contracts at each reporting date is the sum of the LRC and the liability for incurred

claims (‘LIC’). The LRC comprises the BEL, risk adjustment and any remaining CSM at that date. The LIC includes the BEL and risk

adjustment (the fulfilment cash flows for incurred claims and expenses that have not yet been paid, including claims that have

been incurred but not yet reported). There is no CSM associated with the LIC, and as a result, any changes in the LIC are taken

directly to profit or loss.

The fulfilment cash flows of groups of insurance contracts are measured at the reporting date using current estimates of future

cash flows, current discount rates and current estimates of the risk adjustment for non-financial risk. Changes in fulfilment cash

flows are recognised as follows.

Changes relating to future insurance services Adjusted against the CSM (or recognised in the insurance service

result in profit or loss if the group is onerous)

Changes relating to current or past services Recognised in the insurance service result in profit or loss

Effects of the time value of money, financial risk Recognised in insurance finance income or expenses and changes

therein on estimated future cash flows

Where, during the coverage period, a group of insurance contracts becomes onerous, the Group recognises a loss in profit or loss

for the net outflow, resulting in the carrying amount of the liability for the group being equal to the fulfilment cash flows. A loss

component is established by the Group for the liability for remaining coverage for such groups of onerous contracts representing

the losses recognised.

The balance on the CSM at the end of the period is available for release to profit or loss. The amount of CSM recognised in

insurance revenue each period (the CSM amortisation) is determined by considering, for each group of contracts, coverage units

that reflect the quantity of the benefits provided in each period and the expected coverage period.

Benefits provided included those arising from both insurance and investment related services. Investment related services are only

included if the Group is deemed to be providing a significant investment service when providing an investment component, or

policyholder’s right to withdraw, that is expected to include an investment return generated by investment activity performed by

the Group. This includes contracts where the value of the investment return that the policyholder benefits from is not directly

related to the value of the underlying investments. Coverage units are discounted and are updated at each reporting date to

reflect the current best estimate of service expected to be provided in future periods. Coverage units for reinsurance contracts

held are typically consistent with the underlying gross contracts, adjusted for differences in the services provided.

F. Insurance contracts, investment contracts with DPF and reinsurance continued

F1. Liabilities under insurance contracts continued

255Annual Report and Accounts 2025

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Standard Life plc

The CSM of each group of contracts is calculated at each reporting date as follows:

Insurance contracts measured under GM

For insurance contracts measured under the GM approach, the CSM is adjusted by applying locked-in discount rates, while the BEL

and risk adjustment are adjusted using current discount rates.

The carrying amount of the CSM at each reporting date is the carrying amount at the start of the year, adjusted for:

• the CSM of any new contracts that are added to the group in the year;

• interest accreted on the carrying amount of the CSM during the year;

• changes in fulfilment cash flows that relate to future services, except to the extent that:

– any increases in the fulfilment cash flows exceed the carrying amount of the CSM, in which case the excess is recognised as

a loss in profit or loss and creates a loss component; or

– any decreases in the fulfilment cash flows are allocated to the loss component, reversing losses previously recognised in profit

or loss;

• the effect of any currency exchange differences on the CSM; and

• the amount recognised as insurance revenue because of the services provided in the year (see the ‘Insurance revenue’

accounting policy in note C1 for further details).

Changes in fulfilment cash flows relating to future service that adjust the CSM comprise:

• experience adjustments arising from the difference between premiums received and the expected amounts estimated at the

beginning of the period, that relate to future service, along with any associated acquisition costs;

• changes in estimates of the present value of future cash flows in the BEL and risk adjustment;

• differences between any investment component expected to become payable in the period and the actual investment

component that becomes payable; and

• changes in the risk adjustment for non-financial risk that relate to future service.

The impact of discounting the risk adjustment for business measured under GM is disaggregated and recognised within Net finance

income or expenses from insurance contracts within the consolidated income statement.

Insurance contracts measured under VFA model

Life business is considered to have direct participating features, and is required to be measured under the VFA model where:

• contractual terms evidence that policyholders participate in a pool of clearly identified underlying items, for example unit-linked

or with-profits funds;

• the policyholders expect to receive a substantial share of the returns on underlying items (defined by the Group as greater than

50% and further qualitative factors are considered where share of returns is less than 50%); and

• a substantial proportion of changes in amounts payable to policyholders varies with returns on the underlying items (where

substantial is defined consistently with the point above).

The Group’s unit-linked and with-profits business that meets the VFA eligibility criteria are direct participating contracts under

which the Group’s obligation to the policyholder is the net of:

• the obligation to pay the policyholder an amount equal to the fair value of the underlying items; and

• a variable fee in exchange for future services provided by the contracts, being the amount of the Group’s share of the fair value

of the underlying items less fulfilment cash flows that do not vary based on the returns on underlying items. The Group provides

investment services under these contracts by giving a return based on underlying items, in addition to insurance coverage.

For unit-linked and with-profits contracts that are measured under the VFA, interest is not accreted on the CSM using a locked-in

discount rate, instead it is determined with reference to the underlying items, reflecting that on these types of insurance contracts

the Group fees for providing investment-related services are determined with reference to the value of the investments associated

with the policyholder’s policy. For example, annual management charges (‘AMC’) are determined by reference to the value of the

policyholder’s fund value and the shareholder’s share of bonuses on a with-profits policy in a 90:10 fund is determined based on

the performance of the with-profits fund.

The variable fee earned by the Group is consequently the Group’s share of the fair value of underlying items less fulfilment cash

flows that do not vary based on returns of the underlying items.

For unit-linked contracts, the underlying items are funds that the unit price of the investment chosen by the policyholder varies with.

For with-profits contracts, the underlying items are typically the net assets of the relevant with-profits fund, including the estate

and the fair value of non-profit contracts within the fund. With-profits funds can vary in their nature and operation, therefore will

be dependent on facts and circumstances.

When measuring a group of unit-linked and with-profits contracts using the VFA, the Group adjusts the fulfilment cash flows for

the whole of the changes in the obligation to pay policyholders an amount equal to the fair value of the underlying items. These

changes do not relate to future services and are recognised in profit or loss. The Group then adjusts any CSM for changes in the

amount of the Group’s share of the fair value of the underlying items, which relate to future services, as explained below.

256 Annual Report and Accounts 2025

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Standard Life plc

Notes to the consolidated financial statements continued

The carrying amount of the CSM at each reporting date is the carrying amount at the start of the year, adjusted for:

• the CSM of any new contracts that are added to the group in the year;

• the change in the amount of the Group’s share of the fair value of the underlying items and changes in fulfilment cash flows that

relate to future services, except to the extent that:

– the Group has applied the risk mitigation option to exclude from the CSM changes in the effect of financial risk on the amount

of its share of the underlying items or fulfilment cash flows;

– a decrease in the amount of the Group’s share of the fair value of the underlying items, or an increase in the fulfilment cash

flows that relate to future services, exceeds the carrying amount of the CSM, giving rise to a loss in profit or loss (included in

insurance service expenses) and creating a loss component; or

– an increase in the amount of the Group’s share of the fair value of the underlying items, or a decrease in the fulfilment cash

flows that relate to future services, is allocated to the loss component, reversing losses previously recognised in profit or loss

(included in insurance service expenses);

• the effect of any currency exchange differences on the CSM; and

• the amount recognised as insurance revenue because of the services provided in the year (see the ‘Insurance revenue’

accounting policy in note C1 for further details).

Changes in fulfilment cash flows that relate to future service include the changes relating to future services specified above for

contracts without direct participation features (measured at current discount rates) and changes in the effect of the time value of

money and financial risks that do not arise from underlying items.

The Group does not currently apply the risk mitigation option to any material extent, however, intends to make a voluntary change

in accounting policy in this regard in its 2026 consolidated financial statements. Further information is provided in note A6.

Loss components

A loss component represents a notional record of the losses attributable to each group of onerous insurance contracts. The loss

component is released based on a systematic allocation of the subsequent changes relating to future service in the fulfilment cash

flows to (i) the loss component; and (ii) the liability for remaining coverage excluding the loss component. The loss component is

also updated for subsequent changes in estimates of the fulfilment cash flows and the risk adjustment relating to future service.

The systematic allocation of subsequent changes to the loss component results in the total amounts allocated to the loss

component being equal to zero by the end of the coverage period of a group of insurance contracts. The Group uses coverage units

as the method of systematic allocation.

Reinsurance contracts held – measurement

The carrying amount of a group of reinsurance contracts at each reporting date is the sum of the asset/liability for remaining

coverage and the asset/liability for incurred claims. The asset/liability for remaining coverage comprises (a) the fulfilment cash

flows that relate to services that will be received under the contracts in future periods and (b) any remaining CSM at that date.

The measurement of reinsurance contracts held at initial recognition follows the same principles as those for insurance contracts

issued, with the exception of the following:

• measurement of the cash flows includes an allowance on a probability-weighted basis for the effect of any non-performance by

the reinsurers, including the effects of collateral.

• the risk adjustment for non-financial risk is determined so that it represents the amount of risk being transferred to the

reinsurer, and

• the Group recognises both gains and losses at initial recognition in the statement of consolidated financial position as CSM and

releases this to profit or loss as the reinsurer renders services, except for any portion of a loss that relates to events before initial

recognition. Where the Group recognises a loss on initial recognition of an onerous group of underlying contracts, it establishes

a loss-recovery component of the asset for remaining coverage depicting the recovery of losses recognised.

• reinsurance contracts held are not eligible to apply the VFA.

To determine the risk adjustment for reinsurance contracts held, the Group will apply the approach set out above for insurance

contracts both gross and net of reinsurance and determine the amount of risk being transferred to the reinsurer as the difference

between the two results.

The loss-recovery component determines the amounts that are subsequently presented in profit or loss as reversals of recoveries

of losses from reinsurance contracts and are excluded from the allocation of reinsurance premiums paid. It is adjusted to reflect

changes in the loss component of the onerous group of underlying contracts, but it cannot exceed the portion of the loss

component of the onerous group of underlying contracts that the Group expects to recover from the reinsurance contracts.

The Group adjusts the CSM of the group to which a reinsurance contract belongs and as a result recognises income when it

recognises a loss on initial recognition of onerous underlying contracts, if the reinsurance contract is entered into before or at the

same time as the onerous underlying contracts are recognised. The adjustment to the CSM is determined by multiplying:

• the amount of the loss that relates to the underlying contracts; and

• the percentage of claims on the underlying contracts that the Group expects to recover from the reinsurance contracts.

F. Insurance contracts, investment contracts with DPF and reinsurance continued

F1. Liabilities under insurance contracts continued

257Annual Report and Accounts 2025

Financials

Standard Life plc

The subsequent measurement of reinsurance contracts held follows the same principles as those for insurance contracts issued,

with the exception of the following:

• changes in the fulfilment cash flows are recognised in profit or loss if the related changes arising from the underlying ceded

contracts have been recognised in profit or loss. Alternatively, changes in the fulfilment cash flows adjust the CSM; and

• changes in the fulfilment cash flows that result from changes in the risk of non-performance by the issuer of a reinsurance

contract held do not adjust the CSM as they do not relate to future service. The effect of the non-performance risk of the

reinsurer is assessed at each reporting date and the effect of changes in the non-performance risk is recognised in profit or loss.

Modification and derecognition

The Group derecognises insurance and reinsurance contracts when:

• the rights and obligations relating to the contract are extinguished (i.e. discharged, cancelled or expired); or

• the contract is modified such that the modification results in a change in the measurement model, or the applicable standard for

measuring a component of the contract. In such cases, the Group derecognises the initial contract and recognises the modified

contract as a new contract.

Disclosure groups

The Group disaggregates information for the purposes of making the disclosures required by IFRS 17 into the following

disclosure groups:

• Retirement Solutions;

• Pensions & Savings;

• With-profits; and

• Europe & Other.

The disclosure groups are aligned to the segments used for segmental reporting in note B1.

The table below shows a summary of the carrying amount of insurance contracts in the statement of consolidated financial position.

A summary of the carrying amount of the related reinsurance contracts is included in note F3.1.

	Retirement	Pensions &
	Solutions	Savings	With-Profits	Europe & Other	Total
2025	£m	£m	£m	£m	£m
Insurance contracts issued
Estimates of present value of future cash flows	40,203	22,398	25,732	25,090	113,423
Risk adjustment	828	78	76	180	1,162
CSM	4,452	306	657	326	5,741
Insurance contract liabilities issued	45,483	22,782	26,465	25,596	120,326

	Retirement	Pensions &
	Solutions	Savings	With-Profits	Europe & Other	Total
2024	£m	£m	£m	£m	£m
Insurance contracts issued
Estimates of present value of future cash flows	37,934	22,160	26,152	23,108	109,354
Risk adjustment	826	78	89	213	1,206
CSM	4,000	269	633	329	5,231
Insurance contract liabilities issued	42,760	22,507	26,874	23,650	115,791

258 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

F2. Insurance contracts

F2.1 Movements in present value of future cash flows, risk adjustment and CSM of insurance contracts

The reconciliations below provide a roll-forward of the net asset or liability for insurance contracts issued by measurement

component, showing estimates of the present value of future cash flows, the risk adjustment for non-financial risk and the CSM.

			2025				2024
	Estimates of				Estimates of
	the present				the present
	value of		Contractual		value of		Contractual
	future cash	Risk	service		future cash	Risk	service
	flows	adjustment	margin	Total	flows	adjustment	margin	Total
Retirement Solutions	£m	£m	£m	£m	£m	£m	£m	£m
Insurance contract liabilities as at 1 January	37,934	826	4,000	42,760	35,713	767	3,749	40,229
Insurance contract assets as at 1 January	–	–	–	–	–	–	–	–
Net insurance contract
liabilities as at 1 January	37,934	826	4,000	42,760	35,713	767	3,749	40,229
Changes in income statement:
CSM recognised for services provided	–	–	(323)	(323)	–	–	(278)	(278)
Risk adjustment for the risk expired	–	(82)	–	(82)	–	(71)	–	(71)
Experience adjustments	(8)	–	–	(8)	(3)	–	–	(3)
Total change relating to current service	(8)	(82)	(323)	(413)	(3)	(71)	(278)	(352)
Contracts initially recognised in the period	(494)	86	408	–	(488)	128	360	–
Changes in estimates that adjust the CSM	(152)	(102)	254	–	(93)	27	66	–
Changes in estimates that do not adjust the CSM	(11)	2	–	(9)	(12)	–	–	(12)
Total change relating to future service	(657)	(14)	662	(9)	(593)	155	426	(12)
Adjustments to liabilities for incurred claims (past service)	5	(1)	–	4	–	–	–	–
Insurance service result	(660)	(97)	339	(418)	(596)	84	148	(364)
Insurance finance expense/(income)	1,646	99	113	1,858	(614)	(25)	103	(536)
Total changes in income statement	986	2	452	1,440	(1,210)	59	251	(900)
Cash flows:
Premiums received	5,407	–	–	5,407	5,853	–	–	5,853
Claims and other expenses paid	(4,036)	–	–	(4,036)	(3,657)	–	–	(3,657)
Insurance acquisition cash flows	(82)	–	–	(82)	(73)	–	–	(73)
Total cash flows	1,289	–	–	1,289	2,123	–	–	2,123
Other movements 1	(6)	–	–	(6)	1,308	–	–	1,308
Net insurance contract liabilities
as at 31 December	40,203	828	4,452	45,483	37,934	826	4,000	42,760
Insurance contract liabilities
as at 31 December	40,203	828	4,452	45,483	37,934	826	4,000	42,760
Insurance contract assets
as at 31 December	–	–	–	–	–	–	–	–
Net insurance contract liabilities
as at 31 December	40,203	828	4,452	45,483	37,934	826	4,000	42,760

1 Estimates of the present value of future cash flows in 2024 includes £1,305 million of premium in respect of the PGL Pension Scheme buy-out.

F. Insurance contracts, investment contracts with DPF and reinsurance continued

259Annual Report and Accounts 2025

Financials

Standard Life plc

			2025				2024
	Estimates of				Estimates of
	the present				the present
	value of		Contractual		value of		Contractual
	future cash	Risk	service		future cash	Risk	service
	flows	adjustment	margin	Total	flows	adjustment	margin	Total
Pensions & Savings	£m	£m	£m	£m	£m	£m	£m	£m
Insurance contract liabilities as at 1 January	22,160	78	269	22,507	23,164	84	201	23,449
Insurance contract assets as at 1 January	–	–	–	–	–	–	–	–
Net insurance contract
liabilities as at 1 January	22,160	78	269	22,507	23,164	84	201	23,449
Changes in income statement:
CSM recognised for services provided	–	–	(33)	(33)	–	–	(36)	(36)
Risk adjustment for the risk expired	–	(9)	–	(9)	–	(11)	–	(11)
Experience adjustments	6	–	–	6	63	–	–	63
Expected policyholder tax charges	(32)	–	–	(32)	(33)	–	–	(33)
Total change relating to current service	(26)	(9)	(33)	(68)	30	(11)	(36)	(17)
Changes in estimates that adjust the CSM	(84)	14	70	–	(106)	(4)	110	–
Changes in estimates that do not adjust the CSM	(19)	(4)	–	(23)	(14)	8	–	(6)
Total change relating to future service	(103)	10	70	(23)	(120)	4	110	(6)
Adjustments to liabilities for incurred claims (past service)	(6)	–	–	(6)	(22)	–	–	(22)
Insurance service result	(135)	1	37	(97)	(112)	(7)	74	(45)
Insurance finance expense/(income)	2,774	(1)	–	2,773	1,724	1	(3)	1,722
Total changes in income statement	2,639	–	37	2,676	1,612	(6)	71	1,677
Cash flows:
Premiums received	329	–	–	329	377	–	–	377
Claims and other expenses paid	(2,730)	–	–	(2,730)	(2,999)	–	–	(2,999)
Total cash flows	(2,401)	–	–	(2,401)	(2,622)	–	–	(2,622)
Other movements	–	–	–	–	6	–	(3)	3
Net insurance contract liabilities
as at 31 December	22,398	78	306	22,782	22,160	78	269	22,507
Insurance contract liabilities
as at 31 December	22,398	78	306	22,782	22,160	78	269	22,507
Insurance contract assets
as at 31 December	–	–	–	–	–	–	–	–
Net insurance contract liabilities
as at 31 December	22,398	78	306	22,782	22,160	78	269	22,507

260 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

			2025				2024
	Estimates of				Estimates of
	the present				the present
	value of		Contractual		value of		Contractual
	future cash	Risk	service		future cash	Risk	service
	flows	adjustment	margin	Total	flows	adjustment	margin	Total
With-Profits	£m	£m	£m	£m	£m	£m	£m	£m
Insurance contract liabilities as at 1 January	26,152	89	633	26,874	27,700	104	589	28,393
Insurance contract assets as at 1 January	–	–	–	–	–	–	–	–
Net insurance contract
liabilities as at 1 January	26,152	89	633	26,874	27,700	104	589	28,393
Changes in income statement:
CSM recognised for services provided	–	–	(45)	(45)	–	–	(74)	(74)
Risk adjustment for the risk expired	–	(6)	–	(6)	–	(6)	–	(6)
Experience adjustments	14	–	–	14	11	–	–	11
Expected policyholder tax charges	(30)	–	–	(30)	(36)	–	–	(36)
Total change relating to current service	(16)	(6)	(45)	(67)	(25)	(6)	(74)	(105)
Changes in estimates that adjust the CSM	(14)	(46)	60	–	(98)	(12)	110	–
Changes in estimates that do not adjust the CSM	(54)	4	–	(50)	(36)	3	–	(33)
Total change relating to future service	(68)	(42)	60	(50)	(134)	(9)	110	(33)
Adjustments to liabilities for incurred claims (past service)	(88)	17	–	(71)	(38)	–	–	(38)
Insurance service result	(172)	(31)	15	(188)	(197)	(15)	36	(176)
Insurance finance expense	2,502	18	9	2,529	1,113	–	9	1,122
Total changes in income statement	2,330	(13)	24	2,341	916	(15)	45	946
Cash flows:
Premiums received	61	–	–	61	101	–	–	101
Claims and other expenses paid	(2,811)	–	–	(2,811)	(2,567)	–	–	(2,567)
Total cash flows	(2,750)	–	–	(2,750)	(2,466)	–	–	(2,466)
Other movements	–	–	–	–	2	–	(1)	1
Net insurance contract liabilities
as at 31 December	25,732	76	657	26,465	26,152	89	633	26,874
Insurance contract liabilities
as at 31 December	25,732	76	657	26,465	26,152	89	633	26,874
Insurance contract assets
as at 31 December	–	–	–	–	–	–	–	–
Net insurance contract liabilities
as at 31 December	25,732	76	657	26,465	26,152	89	633	26,874

F. Insurance contracts, investment contracts with DPF and reinsurance continued

F2. Insurance contracts continued

F2.1 Movements in present value of future cash flows, risk adjustment and CSM of insurance contracts continued

261Annual Report and Accounts 2025

Financials

Standard Life plc

			2025				2024
	Estimates of				Estimates of
	the present				the present
	value of		Contractual		value of		Contractual
	future cash	Risk	service		future cash	Risk	service
	flows	adjustment	margin	Total	flows	adjustment	margin	Total
Europe & Other	£m	£m	£m	£m	£m	£m	£m	£m
Insurance contract liabilities as at 1 January	23,108	213	329	23,650	23,195	217	244	23,656
Insurance contract assets as at 1 January	–	–	–	–	–	–	–	–
Net insurance contract
liabilities as at 1 January	23,108	213	329	23,650	23,195	217	244	23,656
Changes in income statement:
CSM recognised for services provided	–	–	(44)	(44)	–	–	(56)	(56)
Risk adjustment for the risk expired	–	(20)	–	(20)	–	(15)	–	(15)
Experience adjustments	28	–	–	28	–	–	–	–
Expected policyholder tax charges	(4)	–	–	(4)	–	–	–	–
Total change relating to current service	24	(20)	(44)	(40)	–	(15)	(56)	(71)
Contracts initially recognised in the period	(26)	4	22	–	(51)	6	45	–
Changes in estimates that adjust the CSM	14	(23)	9	–	(82)	2	80	–
Changes in estimates that do not adjust the CSM	5	(9)	–	(4)	3	15	–	18
Total change relating to future service	(7)	(28)	31	(4)	(130)	23	125	18
Adjustments to liabilities for incurred claims (past service)	(26)	4	–	(22)	(8)	–	–	(8)
Insurance service result	(9)	(44)	(13)	(66)	(138)	8	69	(61)
Insurance finance expense/(income)	1,193	8	3	1,204	1,336	(8)	20	1,348
Total changes in income statement	1,184	(36)	(10)	1,138	1,198	–	89	1,287
Cash flows:
Premiums received	2,025	–	–	2,025	1,720	–	–	1,720
Claims and other expenses paid	(1,900)	–	–	(1,900)	(2,249)	–	–	(2,249)
Insurance acquisition cash flows	(98)	–	–	(98)	(106)	–	–	(106)
Total cash flows	27	–	–	27	(635)	–	–	(635)
Other movements 1	771	3	7	781	(650)	(4)	(4)	(658)
Net insurance contract liabilities
as at 31 December	25,090	180	326	25,596	23,108	213	329	23,650
Insurance contract liabilities
as at 31 December	25,090	180	326	25,596	23,108	213	329	23,650
Insurance contract assets
as at 31 December	–	–	–	–	–	–	–	–
Net insurance contract liabilities
as at 31 December	25,090	180	326	25,596	23,108	213	329	23,650

1 Other movements in both periods presented principally relate to foreign currency.

262 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

F2.2 Movements in liabilities for remaining coverage and liabilities for incurred claims for insurance contracts

The following reconciliations show how the net carrying amounts of insurance contracts issued changed over the year as a result of

cash flows, amounts recognised in the consolidated income statement and other movements, analysed by remaining coverage and

incurred claims.

			2025				2024
	Liabilities for remaining				Liabilities for remaining
	coverage				coverage
	Excluding		Liabilities		Excluding		Liabilities
	loss	Loss	for incurred		loss	Loss	for incurred
	component	component	claims	Total	component	component	claims	Total
Retirement Solutions	£m	£m	£m	£m	£m	£m	£m	£m
Insurance contract liabilities as at 1 January	42,423	39	298	42,760	40,126	54	49	40,229
Insurance contract assets as at 1 January	–	–	–	–	–	–	–	–
Net insurance contract
liabilities as at 1 January	42,423	39	298	42,760	40,126	54	49	40,229
Changes in income statement:
Insurance revenue (note C1)	(4,373)	–	–	(4,373)	(3,918)	–	–	(3,918)
Insurance service expenses:
Incurred claims and other expenses	–	(4)	3,956	3,952	–	(4)	3,569	3,565
Amortisation of insurance
acquisition cash flows	7	–	–	7	1	–	–	1
Losses on onerous contracts and reversals of those losses	–	(8)	–	(8)	–	(12)	–	(12)
Changes to liabilities for incurred
claims (past service)	–	–	4	4	–	–	–	–
Insurance service result	(4,366)	(12)	3,960	(418)	(3,917)	(16)	3,569	(364)
Insurance finance expense/(income)	1,856	1	1	1,858	(552)	1	15	(536)
Total changes in income statement	(2,510)	(11)	3,961	1,440	(4,469)	(15)	3,584	(900)
Investment components	(384)	–	384	–	(301)	–	301	–
Cash flows:
Premiums received	5,407	–	–	5,407	5,853	–	–	5,853
Claims and other expenses paid	–	–	(4,036)	(4,036)	–	–	(3,657)	(3,657)
Insurance acquisition cash flows	(82)	–	–	(82)	(73)	–	–	(73)
Total cash flows	5,325	–	(4,036)	1,289	5,780	–	(3,657)	2,123
Other movements 1	–	–	(6)	(6)	1,287	–	21	1,308
Net insurance contract
liabilities as at 31 December	44,854	28	601	45,483	42,423	39	298	42,760
Insurance contract liabilities
as at 31 December	44,854	28	601	45,483	42,423	39	298	42,760
Insurance contract assets
as at 31 December	–	–	–	–	–	–	–	–
Net insurance contract
liabilities as at 31 December	44,854	28	601	45,483	42,423	39	298	42,760

Estimates of the present value of future cash flows in 2024 includes £1,305 million of premium in respect of the PGL Pension Scheme buy-out.

F. Insurance contracts, investment contracts with DPF and reinsurance continued

F2. Insurance contracts continued

263Annual Report and Accounts 2025

Financials

Standard Life plc

			2025				2024
	Liabilities for remaining				Liabilities for remaining
	coverage				coverage
	Excluding		Liabilities		Excluding		Liabilities
	loss	Loss	for incurred		loss	Loss	for incurred
	component	component	claims	Total	component	component	claims	Total
Pensions & Savings	£m	£m	£m	£m	£m	£m	£m	£m
Insurance contract liabilities as at 1 January	22,029	94	384	22,507	22,892	115	442	23,449
Insurance contract assets as at 1 January	–	–	–	–	–	–	–	–
Net insurance contract
liabilities as at 1 January	22,029	94	384	22,507	22,892	115	442	23,449
Changes in income statement
Insurance revenue (note C1)	(269)	–	–	(269)	(274)	–	–	(274)
Insurance service expenses:
Incurred claims and other expenses	–	(20)	221	201	–	(14)	271	257
Losses on onerous contracts and reversals of those losses	–	(23)	–	(23)	–	(6)	–	(6)
Changes to liabilities for incurred
claims (past service)	–	–	(6)	(6)	–	–	(22)	(22)
Insurance service result	(269)	(43)	215	(97)	(274)	(20)	249	(45)
Insurance finance expense	2,763	–	10	2,773	1,708	–	14	1,722
Total changes in income statement	2,494	(43)	225	2,676	1,434	(20)	263	1,677
Investment components	(2,439)	–	2,439	–	(2,679)	–	2,679	–
Cash flows:
Premiums received	329	–	–	329	377	–	–	377
Claims and other expenses paid	–	–	(2,730)	(2,730)	–	–	(2,999)	(2,999)
Total cash flows	329	–	(2,730)	(2,401)	377	–	(2,999)	(2,622)
Other movements	–	–	–	–	5	(1)	(1)	3
Net insurance contract
liabilities as at 31 December	22,413	51	318	22,782	22,029	94	384	22,507
Insurance contract liabilities
as at 31 December	22,413	51	318	22,782	22,029	94	384	22,507
Insurance contract assets
as at 31 December	–	–	–	–	–	–	–	–
Net insurance contract
liabilities as at 31 December	22,413	51	318	22,782	22,029	94	384	22,507

264 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

			2025				2024
	Liabilities for remaining				Liabilities for remaining
	coverage				coverage
	Excluding		Liabilities		Excluding		Liabilities
	loss	Loss	for incurred		loss	Loss	for incurred
	component	component	claims	Total	component	component	claims	Total
With-Profits	£m	£m	£m	£m	£m	£m	£m	£m
Insurance contract liabilities as at 1 January	25,972	238	664	26,874	27,520	312	561	28,393
Insurance contract assets as at 1 January	–	–	–	–	–	–	–	–
Net insurance contract
liabilities as at 1 January	25,972	238	664	26,874	27,520	312	561	28,393
Changes in income statement
Insurance revenue (note C1)	(327)	–	–	(327)	(378)	–	–	(378)
Insurance service expenses:
Incurred claims and other expenses	–	(39)	299	260	–	(43)	316	273
Losses on onerous contracts and reversals of those losses	–	(50)	–	(50)	–	(33)	–	(33)
Changes to liabilities for incurred
claims (past service)	–	–	(71)	(71)	–	–	(38)	(38)
Insurance service result	(327)	(89)	228	(188)	(378)	(76)	278	(176)
Insurance finance expense	2,518	1	10	2,529	1,098	1	23	1,122
Total changes in income statement	2,191	(88)	238	2,341	720	(75)	301	946
Investment components	(2,264)	–	2,264	–	(2,369)	–	2,369	–
Cash flows:
Premiums received	61	–	–	61	101	–	–	101
Claims and other expenses paid	–	–	(2,811)	(2,811)	–	–	(2,567)	(2,567)
Insurance acquisition cash flows	–	–	–	–	–	–	–	–
Total cash flows	61	–	(2,811)	(2,750)	101	–	(2,567)	(2,466)
Other movements	–	–	–	–	–	1	–	1
Net insurance contract liabilities
as at 31 December	25,960	150	355	26,465	25,972	238	664	26,874
Insurance contract liabilities
as at 31 December	25,960	150	355	26,465	25,972	238	664	26,874
Insurance contract assets
as at 31 December	–	–	–	–	–	–	–	–
Net insurance contract liabilities
as at 31 December	25,960	150	355	26,465	25,972	238	664	26,874

F. Insurance contracts, investment contracts with DPF and reinsurance continued

F2. Insurance contracts continued

F2.2 Movements in liabilities for remaining coverage and liabilities for incurred claims for insurance contracts continued

265Annual Report and Accounts 2025

Financials

Standard Life plc

			2025				2024
	Liabilities for remaining				Liabilities for remaining
	coverage				coverage
	Excluding		Liabilities		Excluding		Liabilities
	loss	Loss	for incurred		loss	Loss	for incurred
	component	component	claims	Total	component	component	claims	Total
Europe & Other	£m	£m	£m	£m	£m	£m	£m	£m
Insurance contract liabilities as at 1 January	23,306	140	204	23,650	23,055	142	459	23,656
Insurance contract assets as at 1 January	–	–	–	–	–	–	–	–
Net insurance contract
liabilities as at 1 January	23,306	140	204	23,650	23,055	142	459	23,656
Changes in income statement:
Insurance revenue (note C1)	(543)	–	–	(543)	(569)	–	–	(569)
Insurance service expenses:
Incurred claims and other expenses	–	(17)	508	491	–	(34)	521	487
Amortisation of insurance
acquisition cash flows	12	–	–	12	11	–	–	11
Losses on onerous contracts and reversals of those losses	–	(4)	–	(4)	–	18	–	18
Changes to liabilities for incurred
claims (past service)	–	–	(22)	(22)	–	–	(8)	(8)
Insurance service result	(531)	(21)	486	(66)	(558)	(16)	513	(61)
Insurance finance expense	1,192	1	11	1,204	1,326	18	4	1,348
Total changes in income statement	661	(20)	497	1,138	768	2	517	1,287
Investment components	(1,455)	–	1,455	–	(1,485)	–	1,485	–
Cash flows:
Premiums received	2,025	–	–	2,025	1,720	–	–	1,720
Claims and other expenses paid	–	–	(1,900)	(1,900)	–	–	(2,249)	(2,249)
Insurance acquisition cash flows	(98)	–	–	(98)	(106)	–	–	(106)
Total cash flows	1,927	–	(1,900)	27	1,614	–	(2,249)	(635)
Other movements 1	780	1	–	781	(646)	(4)	(8)	(658)
Net insurance contract liabilities
as at 31 December	25,219	121	256	25,596	23,306	140	204	23,650
Insurance contract liabilities
as at 31 December	25,219	121	256	25,596	23,306	140	204	23,650
Insurance contract assets
as at 31 December	–	–	–	–	–	–	–	–
Net insurance contract liabilities
as at 31 December	25,219	121	256	25,596	23,306	140	204	23,650

1 Other movements in both periods presented principally relate to foreign currency.

266 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

F3. Reinsurance contracts held

F3.1 Movements in present value of future cash flows, risk adjustment and CSM of reinsurance contracts held

The reconciliations below provide a roll-forward of the net asset or liability for reinsurance contracts held by measurement

component, showing estimates of the present value of future cash flows, the risk adjustment for non-financial risk and the CSM.

			2025				2024
	Estimates of				Estimates of
	the present				the present
	value of		Contractual		value of		Contractual
	future cash	Risk	service		future cash	Risk	service
	flows	adjustment	margin	Total	flows	adjustment	margin	Total
	£m	£m	£m	£m	£m	£m	£m	£m
Reinsurance contract liabilities
as at 1 January	(252)	34	60	(158)	(244)	37	60	(147)
Reinsurance contract
assets as at 1 January	2,621	652	1,914	5,187	2,410	596	1,870	4,876
Net reinsurance contract
assets as at 1 January	2,369	686	1,974	5,029	2,166	633	1,930	4,729
Changes in income statement:
CSM recognised for services received	–	–	(171)	(171)	–	–	(163)	(163)
Risk adjustment for the risk expired	–	(67)	–	(67)	–	(58)	–	(58)
Experience adjustments	(29)	–	–	(29)	(21)	–	–	(21)
Total change relating to current service	(29)	(67)	(171)	(267)	(21)	(58)	(163)	(242)
Contracts initially recognised in the period	(369)	89	280	–	(190)	116	74	–
Changes in estimates that adjust the CSM	264	(56)	(208)	–	(93)	17	76	–
Changes in estimates that do not adjust the CSM	(14)	(9)	–	(23)	(12)	9	–	(3)
Total change relating to future service	(119)	24	72	(23)	(295)	142	150	(3)
Net (expenses)/income from reinsurance contracts	(148)	(43)	(99)	(290)	(316)	84	(13)	(245)
Reinsurance finance (expense)/income	(110)	81	57	28	(130)	(28)	49	(109)
Total changes in income statement	(258)	38	(42)	(262)	(446)	56	36	(354)
Cash flows:
Premiums paid	3,156	–	–	3,156	2,658	–	–	2,658
Claims recovered and other expenses paid	(2,300)	–	–	(2,300)	(2,000)	–	–	(2,000)
Total cash flows	856	–	–	856	658	–	–	658
Other movements 1	(1)	3	3	5	(9)	(3)	8	(4)
Net reinsurance contract
assets as at 31 December	2,966	727	1,935	5,628	2,369	686	1,974	5,029
Reinsurance contract liabilities
as at 31 December	(266)	32	54	(180)	(252)	34	60	(158)
Reinsurance contract assets
as at 31 December	3,232	695	1,881	5,808	2,621	652	1,914	5,187
Net reinsurance contract
assets as at 31 December	2,966	727	1,935	5,628	2,369	686	1,974	5,029
Analysed by segment as follows:
Retirement Solutions	2,193	660	1,652	4,505	1,307	575	1,694	3,576
Pensions & Savings	4	–	10	14	4	1	6	11
With-profits	432	11	143	586	736	34	141	911
Europe & Other Net reinsurance contract	337	56	130	523	322	76	133	531
assets as at 31 December	2,966	727	1,935	5,628	2,369	686	1,974	5,029

1 Other movements in both periods presented include those relating to foreign currency. Please see note F3.2 for details of further amounts reported within Other movements for 2025.

F. Insurance contracts, investment contracts with DPF and reinsurance continued

267Annual Report and Accounts 2025

Financials

Standard Life plc

F3.2 Movements in assets for remaining coverage and assets for incurred claims for reinsurance contracts held

The following reconciliations show how the net carrying amounts of reinsurance contracts held changed over the year as a result of

cash flows, amounts recognised in the consolidated income statement and other movements, analysed by remaining coverage and

incurred claims.

			2025				2024
		Assets for remaining				Assets for remaining
		coverage				coverage
	Excluding				Excluding
	loss	Loss	Assets for		loss	Loss	Assets for
	recovery	recovery	incurred		recovery	recovery	incurred
	component	component	claims	Total	component	component	claims	Total
	£m	£m	£m	£m	£m	£m	£m	£m
Reinsurance contract liabilities
as at 1 January	(163)	–	5	(158)	(152)	–	5	(147)
Reinsurance contract assets
as at 1 January	7,076	40	(1,929)	5,187	7,147	37	(2,308)	4,876
Net reinsurance contract
assets as at 1 January	6,913	40	(1,924)	5,029	6,995	37	(2,303)	4,729
								–
Changes in income statement
Reinsurance expenses	(3,001)	–	–	(3,001)	(2,504)	–	–	(2,504)
Claims recoverable and other expenses incurred	–	–	2,734	2,734	–	–	2,267	2,267
Changes in the CSM due to recognition
and reversal of a loss-recovery component
from onerous underlying contracts	–	(22)	–	(22)	–	(3)	–	(3)
Cost of retroactive cover on reinsurance contracts held	–	(1)	–	(1)	–	(5)	–	(5)
Net (expense)/income from reinsurance contracts held	(3,001)	(23)	2,734	(290)	(2,504)	(8)	2,267	(245)
Reinsurance finance income/(expense)	35	–	(7)	28	(94)	1	(16)	(109)
Total changes in income statement	(2,966)	(23)	2,727	(262)	(2,598)	(7)	2,251	(354)
Investment components	(143)	–	143	–	(126)	–	126	–
								–
Cash flows:								–
Premiums paid	3,156	–	–	3,156	2,658	–	–	2,658
Claims recovered and other expenses paid	–	–	(2,300)	(2,300)	–	–	(2,000)	(2,000)
Total cash flows	3,156	–	(2,300)	856	2,658	–	(2,000)	658
Other movements 1	(1,494)	(1)	1,500	5	(16)	10	2	(4)
Net reinsurance contract assets as at 31 December	5,466	16	146	5,628	6,913	40	(1,924)	5,029
Reinsurance contract liabilities
as at 31 December	(185)	–	5	(180)	(163)	–	5	(158)
Reinsurance contract assets
as at 31 December	5,651	16	141	5,808	7,076	40	(1,929)	5,187
Net reinsurance contract
assets as at 31 December	5,466	16	146	5,628	6,913	40	(1,924)	5,029
Analysed by segment as follows:
Retirement Solutions	4,393	5	107	4,505	5,543	25	(1,992)	3,576
Pensions & Savings	14	–	–	14	7	–	4	11
With-Profits	570	–	16	586	879	–	32	911
Europe & Other Net reinsurance contract	489	11	23	523	484	15	32	531
assets as at 31 December	5,466	16	146	5,628	6,913	40	(1,924)	5,029

1 The Group has reinsurance arrangements where the premium is retained and held in financial assets which are not derecognised in the Group’s statement of consolidated financial

position. Both the reinsurance and deposit-back elements are treated as a single contract under IFRS 17. It has been identified that in 2024 certain amounts of the deposit-back

obligation were treated as Assets for Incurred Claims (‘AIC’), when appropriate treatment is to recognise within AIC only the portion of the deposit-backed arrangement that

relates to incurred claims, with the remainder being classified as Assets for Remaining Coverage (‘ARC’). This has resulted in a reclassification of £2,052 million between ARC and

AIC included within ‘Other movements’.

Also included within ‘Other Movements’ in ARC is £553 million that represents the non-cash settlement of the deposit-back obligation in relation to policyholder claims in the

period which are covered by these reinsurance arrangements.

The Group has assessed that the reclassification adjustment is not a material prior period error as the impact is limited to a disclosure misclassification of reinsurance assets

between AIC and ARC with no impact on reinsurance contract assets within the statement of consolidated financial position, net assets or profit and is not expected to impact on

economic decisions of the users of the financial statements. Therefore, the Group has not restated comparatives.

268 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

F4. Analysis of CSM by approach in determining CSM either at transition or post transition for new contracts

The tables below show an analysis of CSM for insurance contracts issued and reinsurance contracts held, showing separately

amounts determined using fair value approach at transition and the total of amounts determined using the fully retrospective

approach and amounts for new contracts incepted since transition.

F4.1 Insurance contracts

		2025			2024
		Fully			Fully
		retrospective			retrospective
	Fair value	approach at		Fair value	approach at
	approach at	transition and		approach at	transition and
	transition	new contracts	Total	transition	new contracts	Total
	£m	£m	£m	£m	£m	£m
CSM as at 1 January	2,152	3,079	5,231	1,977	2,806	4,783
Changes that relate to current service:
CSM recognised for services provided	(198)	(247)	(445)	(222)	(222)	(444)
Changes that relate to future service:
Contracts initially recognised in the period	–	430	430	–	405	405
Changes in estimates that adjust the CSM	168	225	393	347	19	366
Insurance service result	(30)	408	378	125	202	327
Insurance finance income	32	93	125	51	78	129
Total changes in income statement	2	501	503	176	280	456
Other movements	5	2	7	(1)	(7)	(8)
CSM as at 31 December	2,159	3,582	5,741	2,152	3,079	5,231
Analysed by segment as follows:
Retirement Solutions	1,145	3,307	4,452	1,199	2,801	4,000
Pensions & Savings	214	92	306	181	88	269
With-Profits	577	80	657	547	86	633
Europe & Other	223	103	326	225	104	329
CSM as at 31 December	2,159	3,582	5,741	2,152	3,079	5,231

F4.2 Reinsurance contracts held

		2025			2024
		Fully			Fully
		retrospective			retrospective
	Fair value	approach at		Fair value	approach at
	approach at	transition and		approach at	transition and
	transition	new contracts	Total	transition	new contracts	Total
	£m	£m	£m	£m	£m	£m
CSM as at 1 January	763	1,211	1,974	823	1,107	1,930
Changes that relate to current service:
CSM recognised for services received	(93)	(78)	(171)	(87)	(76)	(163)
Changes that relate to future service:
Contracts initially recognised in the period	–	280	280	–	74	74
Changes in estimates that adjust the CSM	93	(301)	(208)	5	71	76
Net expenses from reinsurance contracts	–	(99)	(99)	(82)	69	(13)
Reinsurance finance income	13	44	57	15	34	49
Total changes in income statement	13	(55)	(42)	(67)	103	36
Other movements	4	(1)	3	7	1	8
CSM as at 31 December	780	1,155	1,935	763	1,211	1,974
Analysed by segment as follows:
Retirement Solutions	507	1,145	1,652	489	1,205	1,694
Pensions & Savings	–	10	10	–	6	6
With-Profits	143	–	143	141	–	141
Europe & Other	130	–	130	133	–	133
CSM as at 31 December	780	1,155	1,935	763	1,211	1,974

F. Insurance contracts, investment contracts with DPF and reinsurance continued

269Annual Report and Accounts 2025

Financials

Standard Life plc

F5. Recognition of CSM in profit or loss

The following tables set out when the Group expects to recognise the carrying value of the CSM in the consolidated income

statement for insurance contracts issued and reinsurance contracts held. For General Model business this is shown after allowing for

future accretion of interest on the CSM at the locked in rate. The amounts presented represent the net impact in each period of

expected release of the CSM recognised in revenue less the accretion of interest on the CSM on General Model business recognised

in insurance finance expenses.

	Less than 1						More than
	year	1-2 years	2-3 years	3-4 years	4-5 years	5-10 years	10 years	Total
2025	£m	£m	£m	£m	£m	£m	£m	£m
Insurance contracts issued
Retirement Solutions	309	295	282	268	255	1,080	1,963	4,452
Pensions & Savings	26	24	23	21	19	79	114	306
With-Profits	56	52	48	42	39	153	267	657
Europe & Other	35	31	27	25	23	73	112	326
Total CSM	426	402	380	356	336	1,385	2,456	5,741
Reinsurance contracts held
Retirement Solutions	(125)	(118)	(111)	(105)	(99)	(406)	(688)	(1,652)
Pensions & Savings	(4)	(1)	(2)	(1)	(1)	(1)	–	(10)
With-Profits	(14)	(13)	(12)	(11)	(10)	(36)	(47)	(143)
Europe & Other	(12)	(11)	(11)	(10)	(10)	(40)	(36)	(130)
Total CSM	(155)	(143)	(136)	(127)	(120)	(483)	(771)	(1,935)

	Less than 1						More than
	year	1-2 years	2-3 years	3-4 years	4-5 years	5-10 years	10 years	Total
2024	£m	£m	£m	£m	£m	£m	£m	£m
Insurance contracts issued
Retirement Solutions	263	250	239	228	218	933	1,869	4,000
Pensions & Savings	30	26	24	21	19	68	81	269
With-Profits	65	56	49	43	37	139	244	633
Europe & Other	35	30	28	24	23	75	114	329
Total CSM	393	362	340	316	297	1,215	2,308	5,231
Reinsurance contracts held
Retirement Solutions	(120)	(113)	(107)	(101)	(96)	(401)	(756)	(1,694)
Pensions & Savings	(2)	(2)	–	–	–	(1)	(1)	(6)
With-Profits	(13)	(13)	(11)	(10)	(8)	(32)	(54)	(141)
Europe & Other	(10)	(10)	(10)	(10)	(10)	(43)	(40)	(133)
Total CSM	(145)	(138)	(128)	(121)	(114)	(477)	(851)	(1,974)

270 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

F6. Effect of contracts initially recognised in the year

The effect on the measurement components arising from the initial recognition of insurance and reinsurance contracts in the

year is disclosed in the tables below. Contracts issued comprise of pension risk transfer transactions completed in the year and

protection business.

F6.1 Insurance contracts

				2025					2024
	Retirement
	Solutions			Europe & Other			Retirement Solutions		Europe & Other
	Profitable	Onerous	Profitable	Onerous	Total	Profitable	Onerous	Profitable	Onerous	Total
Contracts Issued	£m	£m	£m	£m	£m	£m	£m	£m	£m	£m
Estimate of present value of future cash outflows:
Insurance acquisition cash flows	81	1	72	–	154	73	–	79	–	152
Claims and other directly
attributable expenses	4,112	77	155	–	4,344	6,320	–	156	22	6,498
Estimates of present value
of future cash outflows	4,193	78	227	–	4,498	6,393	–	235	22	6,650
Estimates of present value
of future cash inflows	(4,687)	(78)	(253)	–	(5,018)	(6,881)	–	(285)	(23)	(7,189)
Risk adjustment incurred	86	–	4	–	90	128	–	5	1	134
CSM	408	–	22	–	430	360	–	45	–	405
Losses on onerous contracts
at initial recognition 1	–	–	–	–	–	–	–	–	–	–

1 Losses on onerous contracts at initial recognition were less than £0.5 million in both periods presented.

F6.2 Reinsurance contracts

	2025	2024
	Without a loss	Without a loss
	recovery	recovery
	component	component
Contracts purchased	£m	£m
Estimate of present value of future cash inflows	4,870	5,597
Estimates of present value of future cash outflows	(5,239)	(5,787)
Risk adjustment incurred	89	116
CSM	280	74
Income recognised on initial recognition	–	–

All contracts purchased relate to the Retirement Solutions segment.

F7. Underlying items

The following table sets out the composition and the fair value of underlying items of the Group’s participating contracts which are

measured using the variable fee approach.

			2025				2024
	Pensions &		Europe &		Pensions &		Europe &
	Savings	With-profits	Other	Total	Savings	With-profits	Other	Total
	£m	£m	£m	£m	£m	£m	£m	£m
Collective investment schemes	17,943	23,619	16,626	58,188	17,753	21,736	14,598	54,087
Debt securities	2,487	6,385	5,157	14,029	2,554	6,569	4,881	14,004
Equities	1,685	3,337	1,084	6,106	1,753	3,987	1,135	6,875
Investment property	196	800	13	1,009	266	788	14	1,068
Derivative assets	4	150	926	1,080	1	159	893	1,053
Cash and cash equivalents	90	118	403	611	85	79	363	527
Loans and deposits	–	2	195	197	–	2	142	144
Other assets	80	688	548	1,316	75	806	621	1,502
Derivative liabilities	(1)	(477)	(615)	(1,093)	(3)	(494)	(152)	(649)
Obligation for repayment of collateral received	–	(69)	(20)	(89)	–	(90)	(181)	(271)
Deposits received from reinsurers	432	(15)	–	417	–	–	–	–
Insurance contract liabilities	–	(2,461)	(6)	(2,467)	–	(2,132)	(4)	(2,136)
Investment contract liabilities	–	(9,189)	–	(9,189)	–	(8,550)	–	(8,550)
Other liabilities	(48)	(1,352)	(912)	(2,312)	(38)	(1,171)	(855)	(2,064)
	22,868	21,536	23,399	67,803	22,446	21,689	21,455	65,590

F. Insurance contracts, investment contracts with DPF and reinsurance continued

271Annual Report and Accounts 2025

Financials

Standard Life plc

F8. Collateral arrangements

It is the Group’s practice to obtain collateral to mitigate the counterparty risk related to reinsurance transactions usually in the form

of cash or marketable financial instruments.

Where the Group receives collateral in the form of marketable financial instruments and cash held by external custodians, it is not

recognised in the statement of consolidated financial position. The cash collateral received is legally segregated from the Group and

consequently the Group does not have the contractual right to receive the cash flows, and the balances are not available for

investment purposes.

The fair value of financial assets accepted as collateral for reinsurance transactions but not recognised in the statement of

consolidated financial position amounts to £6,586 million (2024: £5,558 million).

F9. Risk management – insurance risk

This note forms one part of the risk management disclosures in the consolidated financial statements. An overview of the Group’s

approach to risk management is outlined in note I3 and the Group’s management of financial and other risks is detailed in note E6.

Insurance risk refers to the risk of reductions in earnings and/or value, through financial or reputational loss, due to experience

variations in the timing, frequency and severity of insured/underwritten events and to fluctuations in the timing and amount of claim

settlements. The Life businesses are exposed to the following elements of insurance risk:

Mortality	The risk of reductions in earnings, capital and/or value through a financial or reputational loss arising as
	a result of higher than expected number of death claims on assurance products, lower than expected
	improvements in mortality or adverse movement in mortality rates on Equity Release Mortgages.
Longevity	The risk of reductions in earnings, capital and/or value through a financial or reputational loss arising as
	a result of lower than expected number of deaths experienced on annuity products or greater than
	expected improvements in annuitant mortality.
Morbidity/Disability	The risk of reductions in earnings, capital and/or value through a financial or reputational loss arising as
	a result of higher than expected number of inceptions on critical illness or income protection policies and
	lower than expected recovery rates on income protection policies or adverse movements in morbidity
	rates on Equity Release Mortgages.
Expenses	The risk of reductions in earnings, capital and/or value through a financial or reputational loss arising as
	a result of unexpected timing or value of expenses incurred.
Persistency	The risk of reductions in earnings, capital and/or value through a financial or reputational loss arising as a
	result of adverse movements in surrender rates, guaranteed annuity option (‘GAO’) surrender rates, GAO
	take-up rates, policyholder retirement dates, the occurrence of a mass lapse event or adverse change in
	mortgage prepayment rates leading to losses.
Concentration of risk	The concentration of risk arising from insurance contracts might exist where the Group has significant
	exposure to specific demographic factors such as age, smoker status, geographical location. The Group’s
	exposure to insurance risk is spread across a diversified portfolio of products and approximately 12 million
	policyholders. Concentration risk might also arise from insurance contracts that expose the Group to
	financial risk as a result of options and guarantees contained within the product. Details of the Group’s
	approach to managing these features are contained in F9.3 Managing Product Risk.
	The Group sets individual risk limits as a key control within its Risk Appetite Framework. Risk limits are
	reviewed as part of approving the Group’s Business Plan and permit concentrations of certain risks only
	where the strategy can be demonstrated as affordable within risk appetite.

Objectives and policies for mitigating insurance risk

Insurance risks are managed by monitoring risk exposure against pre-defined appetite limits. If a risk is moving out of appetite, the Group

can choose to mitigate it via reinsurance in the case of longevity, mortality and morbidity risks, or by taking other risk reducing actions.

This is supported by additional methods to assess and monitor insurance risk exposures for both individual types of risks insured and

overall risks. These methods include internal risk measurement models, experience analyses, external data comparisons, sensitivity

analyses, scenario analyses and stress testing. Assumptions that are deemed to be financially significant are reviewed at least

annually for pricing and reporting purposes.

The profitability of the run-off of the Company’s legacy business depends, to a significant extent, on the values of claims paid in the

future relative to the assets accumulated to the date of claim. Typically, over the lifetime of a contract, premiums and investment returns

exceed claim costs in the early years and it is necessary to set aside these amounts to meet future obligations. The amount of such

future obligations is assessed on actuarial principles by reference to assumptions about the development of financial and insurance risks.

It is therefore necessary for the Directors of each life company to make decisions, based on actuarial advice, which ensure an

appropriate accumulation of assets relative to liabilities. These decisions include investment policy, bonus policy and, where

discretion exists, the level of payments on early termination.

In the Retirement Solutions operating segment, longevity risk exposures continue to increase as a result of the Pension Risk Transfer

deals it has successfully acquired, however the vast majority of these exposures are reinsured to third parties.

272 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

F9.1 Sensitivities

Insurance liabilities are sensitive to changes in risk variables, such as prevailing market interest rates, currency rates and equity prices,

since these variations alter the value of the financial assets held to meet obligations arising from insurance contracts and changes in

investment conditions also have an impact on the value of insurance liabilities themselves. Additionally, insurance liabilities are

sensitive to the assumptions which have been applied in their calculation, such as mortality and lapse rates. Sometimes allowance

must also be made for the effect on future assumptions of management or policyholder actions in certain economic scenarios. This

could lead to changes in assumed asset mix or future bonus rates. The most significant non-economic sensitivities arise from

mortality, longevity and lapse risk. The table below analyses how the CSM, profit after tax and equity would have increased or

(decreased) if changes in underwriting risk variables that were reasonably possible at the reporting date had occurred. This analysis

presents the sensitivities both before and after risk mitigation by reinsurance and assumes that all other variables remain constant.

			Impact on profit after tax	Impact on equity		Impact on CSM
		Gross of	Net of	Gross of	Net of	Gross of	Net of
	Change in risk	reinsurance	reinsurance	reinsurance	reinsurance	reinsurance	reinsurance
2025	variable	£m	£m	£m	£m	£m	£m
Assurance mortality	+5%	(61)	(42)	(61)	(42)	(54)	(45)
	-5%	36	12	36	12	92	87
Annuitant longevity	+5%	339	140	318	138	(1,281)	(466)
	-5%	(334)	(144)	(314)	(142)	1,236	461
Lapse rates	+10%	(27)	(34)	(27)	(34)	(17)	(7)
	-10%	31	33	31	33	23	17
Expenses	+10%	(65)	(65)	(65)	(65)	(192)	(192)
	-10%	38	38	38	38	227	227

			Impact on profit after tax	Impact on equity		Impact on CSM
		Gross of	Net of	Gross of	Net of	Gross of	Net of
	Change in risk	reinsurance	reinsurance	reinsurance	reinsurance	reinsurance	reinsurance
2024	variable	£m	£m	£m	£m	£m	£m
Assurance mortality	+5%	(53)	(25)	(53)	(25)	(55)	(54)
	-5%	28	6	28	6	92	82
Annuitant longevity	+5%	330	146	308	144	(1,236)	(452)
	-5%	(323)	(145)	(303)	(143)	1,183	433
Lapse rates	+10%	(39)	(47)	(39)	(47)	(8)	17
	-10%	33	48	33	48	26	(18)
Expenses	+10%	(63)	(63)	(63)	(63)	(251)	(251)
	-10%	43	43	43	43	277	277

F9.2 Assumptions

The assumptions used to determine the liabilities are updated at each reporting date to reflect recent experience, unless IFRS 17

requires otherwise. Material judgement is required in calculating these liabilities and, in particular, in the choice of assumptions

about which there is uncertainty over future experience. The principal assumptions are as follows:

F9.2.1 Discount rates

All cash flows are discounted using risk-free yield curves adjusted to reflect the timing and, where necessary, liquidity characteristics

of those cash flows. For the risk-free yield curve the Group uses those published by the PRA and EIOPA for regulatory reporting.

Where necessary, yield curves are interpolated between the last available market data point and the ultimate forward rate.

The Group uses a top-down approach primarily for annuities and a bottom-up discount rate for all other business. Under the

top-down approach, the discount rate is determined from the yield implicit in the fair value of an appropriate reference portfolio

of assets that reflects the characteristics of the liabilities.

For annuity business, the Group determines a reference portfolio which is constructed in line with the Group’s investment strategy.

The reference portfolio construction is based on the actual assets held by the Group backing annuity business at the valuation

date. Adjustment is made, where appropriate, to allow for the asset portfolio included in the pricing of policies where that has not

been fully deployed at the reporting date and there are no identified barriers to achieving the pricing asset mix, and to reflect any

strategic management actions actively underway to re-shape the annuity asset portfolio. In addition, excess assets are removed from

the portfolio where the level of assets exceeds those necessary to meet the future cash flows. The yield derived from the reference

portfolio is determined based on the fair value of assets in that class held by the Group at the valuation date.

F. Insurance contracts, investment contracts with DPF and reinsurance continued

F9. Risk management – insurance risk continued

273Annual Report and Accounts 2025

Financials

Standard Life plc

Adjustments are also made for differences between the reference portfolio and the insurance contract liability cash flows, including

an allowance for credit defaults. The credit default deduction comprises an allowance for both expected and unexpected defaults

and takes into consideration long-term historical data on actual defaults and an allowance for variability around these defaults. The

credit default deduction is determined based on the assets held at the valuation date.

The Group has developed a credit model for use in the Group Solvency UK Internal Model which was approved by the PRA in 2025.

The approved model sets out a structural model for credit defaults and allows for: (i) a best estimate view to be derived from

long-term historical actual default data; (ii) applies a stress to these long-term historical defaults to determine the variability of

defaults; and, (iii) the output is used to determine the assumption for unexpected credit defaults. Over 2025 the Group reviewed

credit risk assumptions which act as an input to the discount rate used to value IFRS 17 annuity liabilities. While the overall credit risk

assumption model structure remained unchanged, credit risk assumptions applied to the top-down reference portfolio were

strengthened.

Under the bottom-up approach, the discount rate is determined as the risk-free yield curve, adjusted for differences in liquidity

characteristics by adding an illiquidity premium. For with-profits business a single illiquidity premium is determined for each fund

based on the cash flow characteristics of the contracts within the fund and applied to all contracts within the fund.

The tables below set out the yield curves used to discount the cash flows of insurance contracts for major currencies.

			Risk-free rate (bps)
2025	1 year	5 years	10 years	20 years	30 years
GBP	354	367	404	454	459
Euro	208	248	286	321	320

			Risk-free rate (bps)
2024	1 year	5 years	10 years	20 years	30 years
GBP	446	404	407	430	423
Euro	224	214	227	226	200

		Illiquidity premium over risk-free rate
	2025	2024
	bps	bps
Annuities GBP	168	169
Annuities Euro	62	67
With-profits GBP – liquid liabilities	40	20
With-profits Euro – liquid liabilities	40	20
With-profits GBP – illiquid liabilities	119 – 168	104 – 169

F9.2.2 Risk adjustment

The Group has used the confidence level technique to derive the risk adjustment for non-financial risk. The risk adjustment percentile

is determined based on the Group’s view of the compensation required in respect of non-financial risk. The diversification benefit

included in the risk adjustment reflects diversification between contracts within the perimeter of the Group’s Internal Model. There

is no diversification allowed for between contracts measured under standard formula and the internal model. The confidence level

percentile is calculated on a one-year basis. The risk adjustment calibration is set at least annually, off-cycle, based on the Group’s

current view of risk. The risk adjustment calculation is reassessed at each reporting date, i.e. the risk adjustment is not locked-in at

initial recognition.

For with-profits business, the shareholder’s portion of non-financial risks (including an allowance for burn-through costs to the

shareholder) is allowed for in the derivation of the risk adjustment. For non-profit business held within a with-profits fund, the risk

adjustment takes into account the compensation required by both the shareholder and the participating policyholders.

Confidence level techniques are used to derive the overall risk adjustment for non-financial risk and this is allocated down to each

group of contracts in accordance with their risk profiles. The confidence level percentile input used to determine the risk adjustment

is as follows:

	2025	2024
Insurance contracts (gross of reinsurance)	80th	80th

The one-year confidence level used to determine the risk adjustment has been converted to an approximate lifetime confidence

level using an approach which involves dividing by the square root of the lifetime duration of the insurance business.

	Lifetime confidence level 2025	2024
Insurance contracts (gross of reinsurance)	61st	61st

274 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

F9.2.3 Other assumptions

Other assumptions such as policyholder behaviours (lapses and surrender rates), expense inflation and demographic assumptions

(i.e. longevity, mortality) are a key component of determining the cash flows related to the insurance contract liabilities. The

underwriting risk variables and assumptions are set based on past experience and/or relevant industry data, market practice,

regulations and expectations about future trends. Economic assumptions used in the measurement of fulfilment cash flows are

market consistent.

Expenses and expense inflation

Insurance contract liabilities include an allowance for the best estimate of future expenses associated with the administration of

in-force policies. This requires the allocation of the Group’s future expenses between those that relate to the administration of

in-force policies, those attributable to the acquisition of new business and other costs, such as corporate costs. There is a level of

judgement applied in the analysis that supports this allocation. Additionally, judgement is applied in the determination of the

projected costs of the Group, in particular where those projections include the impact of transition and integration activity.

Expenses are assumed to increase at either the rate of increase in the Retail Price Index (‘RPI’), or a rate derived from the UK inflation

swaps curve, plus fixed margins in accordance with the various management service agreements (‘MSAs’) the Group has in place with

outsource partners. For with-profits business the rate of RPI inflation is determined within each stochastic scenario. For other

business it is based on the Bank of England inflation spot curve. For MSAs with contractual increases set by reference to national

average earnings inflation, this is approximated as RPI inflation or RPI inflation plus 1%. In instances in which inflation risk is not

mitigated, appropriate margins are applied to reflect central expectations of earnings inflation in excess of RPI.

Mortality and longevity rates

Mortality rates are based on company experience and published tables, adjusted appropriately to take account of changes in the

underlying population mortality since the table was published, company experience and forecast changes in future mortality.

Annuitant mortality rates are adjusted to make allowance for future improvements in pensioner longevity.

Lapse and surrender rates (persistency)

The assumed rates for surrender and voluntary premium discontinuance depend on the length of time a policy has been in force and

the relevant company experience. Withdrawal rates used in the valuation are based on observed experience and adjusted when it is

considered that future policyholder behaviour will be influenced by different considerations than in the past. In particular, it is

assumed that withdrawal rates for unitised with-profits contracts will be higher on policy anniversaries on which Market Value

Adjustments do not apply.

Discretionary participating bonus rate

The regular bonus rates assumed in each scenario are determined in accordance with each company’s Principles and Practices of

Financial Management ('PPFM'). Final bonuses are assumed at a level such that maturity payments will equal asset shares subject to

smoothing rules set out in the PPFM and the value of guaranteed benefits.

Policyholder options and guarantees

Some of the Group’s products give potentially valuable guarantees, or give options to change policy benefits which can be exercised

at the policyholders’ discretion. These products are described below.

Most with-profits contracts give a guaranteed minimum payment on a specified date or range of dates or on death if before that

date or dates. For pensions contracts, the specified date is the policyholder’s chosen retirement date or a range of dates around that

date. For endowment contracts, it is the maturity date of the contract. For with-profits bonds it is often a specified anniversary of

commencement, in some cases with further dates thereafter. Annual bonuses when added to with-profits contracts usually increase

the guaranteed amount.

There are guaranteed surrender values on a small number of older contracts.

The fair value of the guaranteed annuity options, which is a component of the total insurance contract liability, are £739 million

(2024: £529 million) in the with-profits funds and £88 million (2024: £73 million) in the non-profit funds.

In common with other life companies in the UK which have written pension transfer and opt-out business, the Group has set up

provisions for the review and possible redress relating to personal pension policies. These provisions, which have been calculated

from data derived from detailed file reviews of specific cases and using a certainty equivalent approach, which give a result very

similar to a market consistent valuation, are included in liabilities arising under insurance contracts. The total amount provided in the

with-profits funds and non-profit funds in respect of the review and possible redress relating to pension policies, including

associated costs, are £133 million (2024: £155 million) and £4 million (2024: £2 million) respectively.

With-profits deferred annuities participate in profits only up to the date of retirement. At retirement, a guaranteed cash option

allows the policyholder to commute the annuity benefit into cash on guaranteed terms.

F. Insurance contracts, investment contracts with DPF and reinsurance continued

F9. Risk management – insurance risk continued

F9.2 Assumptions continued

275Annual Report and Accounts 2025

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Standard Life plc

Assumption changes

During the year a number of changes were made to assumptions to reflect changes in expected experience. The impact of material

changes during the year was as follows:

		2025		2024
	(Decrease)/	Increase/	Increase/	(Decrease)/
	increase	(decrease) in loss	(decrease)	increase in
	in CSM	component	in CSM	loss component
	£m	£m	£m	£m
For insurance contracts:
Change in longevity assumptions	(234)	3	100	(11)
Change in persistency assumptions	7	11	10	(5)
Change in mortality assumptions	(9)	5	–	3
Change in expenses assumptions	368	(74)	(74)	72
For reinsurance contracts:
Change in longevity assumptions	285	–	(31)	–
Change in persistency assumptions	5	–	–	–
Change in mortality assumptions	(1)	–	–	–
Change in expenses assumptions	(6)	–	(45)	–

2025:

Changes in longevity assumptions have given rise to a £51 million net of reinsurance increase in CSM and £3 million increase in loss

component which reflect updates to base and proportions married assumptions reflecting latest experience analyses.

Reflecting the latest experience from annual persistency updates has resulted in a £12 million net of reinsurance increase in CSM and

£11 million increase in loss component.

Changes in mortality assumptions are largely driven by latest experience analyses have resulted in a £10 million decrease in CSM and

£5 million increase in loss component.

Changes in expense assumptions have resulted in a £362 million net of reinsurance increase in CSM and £74 million decrease in loss

component principally reflecting expected cost savings attributable to strategic change activity. This includes the decision to

discontinue further migration of customer administration of ReAssure policies to the TCS BaNCS platform and their transfer to

Wipro under the new strategic partnership; the anticipated in-housing of the management of the majority of the Group’s

shareholder assets; and the ongoing refinements in the modelling of investment expense assumptions.

2024:

The £69 million inclusive of reinsurance increase in CSM and £(11) million decrease in loss component from changes in longevity

assumptions reflect updates to base and improvement assumptions reflecting latest experience analyses.

As well as annual persistency updates to reflect latest experience, assumption changes were made for late retirements and GAO

take-up rates during the year.

The £3 million increase in loss component from changes in mortality assumptions is largely driven by modelling change and partly

offset by a release in the mortality provision.

The £(119) million net of reinsurance decrease in CSM and £72 million increase in loss component from changes in expense

assumptions are driven by an increase in reserves principally in respect of delivery of the Group Target Operating Model for IT and

Operations included the migration of policyholder administration onto the TCS platform and Group expense provisions. This is partly

offset by changes in modelled expenses in relation to the Group’s cost saving programme together with investment expenses and

release of an investment manual.

276 Annual Report and Accounts 2025

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Standard Life plc

Notes to the consolidated financial statements continued

F9.3 Managing product risk

The following sections give an assessment of the risks associated with the Group’s main life assurance products and the ways in

which the Group manages those risks.

Product	Primary segment	Main insurance risks
With-profits:
Unitised & Traditional – without guarantees	With-profits	Longevity & Lapse
Unitised & Traditional – with guarantees	With-profits	Lapse
Annuities	With-profits	Longevity
Non-profit:
Deferred annuities – with guarantees	Retirement Solutions	Longevity
Deferred annuities – without guarantees	Retirement Solutions	Longevity
Immediate annuities	Retirement Solutions	Longevity
Protection	Europe & Other	Mortality, Morbidity & Lapse
Unit-linked – with guarantees	Pensions & Savings	Longevity & Lapse
Unit-linked – without guarantees	Pensions & Savings	Mortality, Morbidity & Lapse

The above products will also be exposed to market risk and further details are included in note E6.2.

£19,898 million (2024: £15,692 million) of liabilities are subject to longevity swap arrangements.

With-profits fund (unitised and traditional)

The Group operates a number of with-profits funds in which the with-profits policyholders benefit from a discretionary annual

bonus (guaranteed once added in most cases) and a discretionary final bonus. Non-participating business is also written in some

of the with-profits funds and some of the funds may include immediate annuities and deferred annuities with Guaranteed Annuity

Rates (‘GAR’).

The investment strategy of each fund differs, but is broadly to invest in a mixture of fixed interest investments and equities and/

or property and other asset classes in such proportions as is appropriate to the investment risk exposure of the fund and its

capital resources.

The Group has significant discretion regarding investment policy, bonus policy and early termination values. The process for

exercising discretion in the management of the with-profits funds is set out in the PPFM for each with-profits fund and is overseen

by with-profits committees. Advice is also taken from the with-profits actuary of each with-profits fund. Compliance with the PPFM

is reviewed annually and reported to the PRA, Financial Conduct Authority (‘FCA’) and policyholders.

The bonuses are designed to distribute to policyholders a fair share of the return on the assets in the with-profits funds together

with other elements of the experience of the fund. The shareholders of the Group are entitled to receive one-ninth of the cost of

bonuses declared for some funds and £nil for others. For the Heritage With-Profits Fund (‘HWPF’), under the Scheme of

Demutualisation, shareholders are entitled to receive certain defined cash flows arising on specified blocks of UK and Irish business.

Unitised and traditional with-profits policies are exposed to equivalent risks, the main difference being that unitised with-profits

policies purchase notional units in a with-profits fund whereas traditional with-profits policies do not. Benefit payments for unitised

policies are then dependent on unit prices at the time of a claim, although charges may be applied. A unitised with-profits fund price

is typically guaranteed not to fall and increases in line with any discretionary bonus payments over the course of one year.

Deferred annuities

Deferred annuity policies are written to provide either a cash benefit at retirement, which the policyholder can use to buy an annuity

on the terms then applicable, or an annuity payable from retirement. The policies contain an element of guarantee expressed in the

form that the contract is written in, i.e. to provide cash or an annuity. Deferred annuity policies written to provide a cash benefit may

also contain an option to convert the cash benefit to an annuity benefit on guaranteed terms; these are known as GAR policies.

Deferred annuity policies written to provide an annuity benefit may also contain an option to convert the annuity benefit into cash

benefits on guaranteed terms; these are known as Guaranteed Cash Option (‘GCO’) policies. In addition, certain unit prices in the

HWPF are guaranteed not to decrease.

Long-term interest rates remain relatively low compared to historical levels and life expectancy has increased more rapidly than

originally anticipated. The guaranteed terms on GAR policies are more favourable than the annuity rates currently available in the

market. The guaranteed terms on GCO policies are currently not valuable. Deferred annuity policies which are written to provide

annuity benefits are managed in a similar manner to immediate annuities and are exposed to the same risks.

The option provisions on GAR policies are particularly sensitive to downward movements in interest rates, increasing life expectancy

and the proportion of customers exercising their option. Adverse movements in these factors could lead to a requirement to

increase reserves which could adversely impact profit and potentially require additional capital. In order to address the interest rate

risk (but not the risk of increasing life expectancy or changing customer behaviour with regard to exercise of the option), insurance

subsidiaries within the Group have purchased derivatives that provide protection against an increase in liabilities and have thus

reduced the sensitivity of profit to movements in interest rates (see note E6.2.2).

F. Insurance contracts, investment contracts with DPF and reinsurance continued

F9. Risk management – insurance risk continued

277Annual Report and Accounts 2025

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Standard Life plc

The Group seeks to manage this risk in accordance with both the terms of the issued policies and the interests of customers, and has

obtained external advice supporting the manner in which it operates the long-term funds in this respect.

Immediate annuities

This type of annuity is purchased with a single premium at the outset, and is paid to the policyholder for the remainder of their

lifetime. Payments may also continue for the benefit of a surviving spouse or partner after the annuitant’s death. Annuities may be

level, or escalate at a fixed rate, or may escalate in line with a price index and may be payable for a minimum period irrespective of

whether the policyholder remains alive.

The main risks associated with this product are longevity and investment risks. Longevity risk arises where the annuities are paid for

the lifetime of the policyholder, and is managed through the initial pricing of the annuity and through reinsurance (appropriately

collateralised) or transfer of existing liabilities. Annuities may also be a partial ‘natural hedge’ against losses incurred in protection

business in the event of increased mortality (and vice versa) although the extent to which this occurs will depend on the similarity

of the demographic profile of each book of business. In addition, the Group has in place longevity swaps that provide downside

protection over longevity risk.

The pricing assumption for mortality risk is based on both historic internal information and external mortality experience, including

allowances for future mortality improvements. Pricing will also include a contingency margin for adverse deviations in assumptions.

Market and credit risk is influenced by the extent to which the cash flows under the contracts have been matched by suitable assets

which is managed under the ALM framework. Asset/liability modelling is used to monitor this position on a regular basis.

Protection

These contracts are typically secured by the payment of a regular premium payable for a period of years providing benefits payable

on certain events occurring within the period. The benefits may be a single lump sum or a series of payments and may be payable on

death, serious illness or sickness.

The main risk associated with this product is the claims experience and this risk is managed through the initial pricing of the policy

(based on actuarial principles), the use of reinsurance and a clear process for administering claims.

Market and credit risk is influenced by the extent to which the cash flows under the contracts have been matched by suitable assets

which is managed under the ALM framework. Asset/liability modelling is used to monitor this position on a regular basis.

G. Other statement of consolidated financial position notes

G1. Pension schemes

Defined contribution pension schemes

Obligations for contributions to defined contribution pension schemes are recognised as an expense in the consolidated income

statement as incurred.

Defined benefit pension schemes

The net surplus or deficit (the economic surplus or deficit) in respect of the defined benefit pension schemes is calculated by

estimating the amount of future benefit that employees have earned in return for their service in the current and prior years; that

benefit is discounted to determine its present value and the fair value of any scheme assets is deducted. The Group recognises a

pension surplus on the basis that it is entitled to the surplus of each scheme in the event of a gradual settlement of the liabilities,

due to its ability to order a winding up of the pension scheme trust.

The economic surplus or deficit is subsequently adjusted to eliminate on consolidation the carrying value of insurance policies

issued by Group entities to the defined benefit pension schemes (the reported surplus or deficit). A corresponding adjustment is

made to the carrying values of insurance contract liabilities and investment contract liabilities.

The Group determines the net interest expense or income on the pension scheme asset/liability for the period by applying the

discount rate used to measure the defined benefit obligation at the beginning of the annual period to the opening pension scheme

asset/liability. The discount rate is the yield at the period end on AA credit rated bonds that have maturity dates approximating to

the terms of the Group’s obligations. The calculation is performed by a qualified actuary using the projected unit credit method.

The movement in the pension scheme asset/liability is analysed between the service cost, past service cost, curtailments and

settlements (all recognised within administrative expenses in the consolidated income statement), the net interest cost on the

pension scheme asset/liability, including any reimbursement assets (recognised within net investment income in the consolidated

income statement), remeasurements of the pension scheme asset/liability (recognised in other comprehensive income) and

employer contributions.

The longevity swaps and quota share reinsurance arrangements in respect of the pension scheme buy-ins are treated as

reimbursement rights and are recognised at fair value.

This note describes the Group’s four main defined benefit pension schemes for its employees, the Pearl Group Staff Pension Scheme

(‘Pearl Scheme’), the Abbey Life Staff Pension Scheme (‘Abbey Life Scheme’) the ReAssure Staff Pension Scheme (‘ReAssure

Scheme’) and the Sun Life Assurance Company of Canada 1988 UK and Irish Employee Benefits Scheme (‘Sun Life of Canada

Scheme’), and explains how the pension scheme asset/liability is calculated.

278 Annual Report and Accounts 2025

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Standard Life plc

Notes to the consolidated financial statements continued

An analysis of the pension scheme (liability)/asset for each pension scheme is set out in the table below:

	2025	2024
	£m	£m
Pearl Group Staff Pension Scheme (G1.2)
Economic surplus	48	48
Adjustment for insurance policies eliminated on consolidation	(1,294)	(1,358)
Pension scheme liability, as reported	(1,246)	(1,310)
Add: value attributed to assets held by PLL within financial assets 1	1,261	1,348
Net reimbursement right in respect of reinsurance, as reported (G1.2.2)	163	147
Adjusted net pension scheme asset	178	185
Abbey Life Staff Pension Scheme (G1.3)
Pension scheme liability	(1)	(2)
ReAssure Staff Pension Scheme (G1.4)
Pension scheme asset	19	20
Sun Life of Canada Scheme (G1.5)
Pension scheme asset	14	15
Reimbursement right	2	2

1 The Pearl Scheme previously executed buy-in transactions with a Group life company and subsequently assets supporting the Group's actuarial liabilities were recognised on a

line-by-line basis within financial assets in the statement of consolidated financial position. Further details are included in note G1.2 below.

An adjusted net pension scheme asset has been presented in both the current and prior years in relation to the Pearl Scheme. The assets held by PLL supporting the buy-ins are not

ring-fenced and the value has been determined as the value of the insurance contract liability within the PLL financial statements less the value of the associated reinsurance

asset. Movements in these financial assets are reflected in the consolidated income statement within net investment income, however as noted in the accounting policy, the

movement in the net pension scheme liability (as shown in note G1.2) is primarily reflected in other comprehensive income.

G1.1 Defined benefit pension scheme risks and assumptions

Risks

The Group’s defined benefit schemes typically expose the Group to a number of risks, the most significant of which are:

Asset volatility – the value of the schemes’ assets will vary as market conditions change and as such is subject to considerable

volatility. The liabilities are calculated using a discount rate set with reference to corporate bond yields; if assets underperform this

yield, this will create a deficit. The majority of the assets are held within a liability driven investment strategy which is linked to the

funding basis of the schemes (set with reference to government bond yields). As such, to the extent that movements in corporate

bond yields are out of line with movements in government bond yields, volatility will arise.

Inflation risk – a significant proportion of the schemes’ benefit obligations are linked to inflation, and higher inflation will lead to

higher liabilities (although in most cases, caps on the level of inflationary increases are in place to protect against extreme inflation).

The majority of the assets are held within a liability driven investment strategy which allows for movements in inflation, meaning

that changes in inflation should not materially affect the surplus.

Life expectancy – the majority of the schemes’ obligations are to provide benefits for the life of the member therefore increases in

life expectancy will result in an increase in the liabilities. For the Pearl and Sun Life of Canada schemes, this is largely offset by the

buy-in policies that move in line with the liabilities. The Pearl Scheme buy-in policies are eliminated on consolidation (see note G1.2

for further details).

Other risk – A High Court legal ruling in June 2023 (Virgin Media Limited v NTL Pension Trustees II Limited) decided that certain

rule amendments were invalid if they were not accompanied by the correct actuarial confirmation. While the ruling only applied

to the specific pension scheme in question, it now forms part of case law and can therefore be expected to apply across other

pension schemes.

On 2 September 2025, the Government published draft amendments to the Pensions Scheme Bill which would give affected

pension schemes the ability to retrospectively obtain written actuarial confirmation that historic benefit changes met the necessary

standards. The draft legislation will need to be agreed by both Houses of Parliament before it passes into law. Management's

confidence that the ruling will not impact the value of liabilities in the Group’s defined benefit pension schemes has therefore

increased compared to their view at 31 December 2024, and no change to the pension scheme liabilities is expected in this regard

at 31 December 2025.

G. Other statement of consolidated financial position notes continued

G1. Pension schemes continued

279Annual Report and Accounts 2025

Financials

Standard Life plc

Principal assumptions

The principal financial assumptions used in the valuation of the Group’s defined benefit pension schemes are set out in the table below:

	2025	2024
	%	%
Rate of increase for pensions in payment (5% per annum or RPI if lower) 1	2.70	3.00
Rate of increase for deferred pensions 2	2.35	2.70
Discount rate	5.50	5.55
Inflation – RPI	2.85	3.20
Inflation – CPI 3	2.35	2.70
Rate of increase in salaries 4	3.35	3.70

1 Rate applicable to Sun Life of Canada Scheme is 2.70% (2024: 3.10%).

2 Rate applicable to Sun Life of Canada Scheme is 1.95% (2024: 2.20%).

3 Rate applicable to Sun Life of Canada Scheme is 2.05% (2024: 2.30%).

4 Applies to the ReAssure pension scheme only.

The discount rate and inflation rate assumptions have been determined by considering the shape of the appropriate yield curves and

the duration of the liabilities. This method determines an equivalent single rate for each of the discount and inflation rates, which is

derived from the profile of projected benefit payments.

The post-retirement mortality and future longevity improvement assumptions for the Group’s pension schemes are as follows:

• Pearl Scheme: post-retirement mortality assumptions are in line with a scheme-specific table which was derived from the actual

mortality experience in recent years based on the SAPS standard tables for males and for females based on year of use. In both

2025 and 2024, future longevity improvements from 1 January 2017 are based on amended CMI 2023 Core Projections and a

long-term rate of improvement of 1.6% per annum for males and 1.2% per annum for females. Under these assumptions, the

average life expectancy from retirement for a member currently aged 40 retiring at age 60 is 29.1 years and 30.4 years for male and

female members respectively.

• Abbey Life Scheme: post-retirement mortality assumptions are in line with a scheme-specific table which was derived from the

actual mortality experience in recent years, performed as part of the actuarial funding valuation as at 31 March 2024, using the

SAPS S4 ‘Light’ tables for males and for females based on year of use. In both 2025 and 2024, future longevity improvements from

1 January 2024 are based on amended CMI 2023 Core Projections and a long-term rate of improvement of 1.6% per annum for

males and 1.2% per annum for females. Under these assumptions the average life expectancy from retirement for a member

currently aged 45 retiring at age 65 is 24.6 years and 25.6 years for male and female members respectively.

• ReAssure scheme: post-retirement mortality assumptions are in line with SAPS Series 3 light base tables with a 102% multiplier for

males and a 95% multiplier for females, with CMI 2019 projections in line with a 1.5% pa long-term trend up to and including

31 December 2020. In both 2025 and 2024, future longevity improvements from 1 January 2021 onwards are in line with amended

CMI 2023 Core Projections with a long-term trend of 1.6% pa for males and 1.2% for females. Under these assumptions the

average life expectancy from retirement for a member currently aged 45 retiring at age 60 is 29.9 years and 31.5 years for male and

female members respectively.

• Sun Life of Canada Scheme: post-retirement mortality assumptions are in line with 2022 VITA Lite tables in both 2025 and 2024.

Future longevity improvements are in line with the 2023 CMI model with no weight on 2020, 2021, 2022 and 2023 experience

(2024: 2023 CMI model with no weight on 2020 and 2021 experience and 15% weighting on 2022 and 2023 experience), with a

long-term trend of 1.6% p.a. for males (2024: 1.5%) and 1.2% p.a. for females (2024: 1.5%). Under these assumptions the average

life expectancy from retirement for a member currently aged 45 retiring at age 65 is 23.9 years and 26.1 years for male and female

members respectively (2024: 23.1 years and 26.1 years for male and female members respectively).

G1.2 Pearl Group Staff Pension Scheme

G1.2.1 Scheme details

The Pearl Scheme comprises a final salary section, a money purchase section and a hybrid section (a mix of final salary and money

purchase). The Pearl Scheme is closed to new members and has no active members.

Defined benefit scheme

The Pearl Scheme is established under, and governed by, the trust deeds and rules and has been funded by payment of contributions

to a separately administered trust fund. A Group company, Pearl Life Holdings Limited (‘PeLHL’), is the principal employer of the Pearl

Scheme and meets the administration expenses of the Scheme.

The Pearl Scheme is administered by a separate trustee company, P.A.T. (Pensions) Limited, which is separate from PeLHL. The

trustee company is comprised of three representatives from the Group, three member nominated representatives and one

independent trustee in accordance with the trustee company’s articles of association. The trustee is required by law to act in the

interest of all relevant beneficiaries and is responsible for the investment policy with regard to the assets.

A triennial funding valuation of the Pearl Scheme as at 30 June 2024 was completed in 2025 by a qualified actuary. This showed

a surplus as at 30 June 2024 of £12 million, on the agreed technical provisions basis.

280 Annual Report and Accounts 2025

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Standard Life plc

Notes to the consolidated financial statements continued

Pension Scheme Commitment Agreement and buy-in transactions

On 17 November 2020, the Pearl Scheme entered into a Commitment Agreement with Pearl Group Holdings No. 2 Limited (‘PGH2’)

to complete a series of buy-ins with Phoenix Life Limited (‘PLL’) covering the Scheme’s pensioner and deferred member liabilities,

transferring the associated risks, including longevity improvement risk, to PLL. These transactions covering 100% of the in scope

liabilities were completed between 2020 and 2022.

Upon completion of each buy-in transaction the Scheme transferred plan assets to PLL and these assets are recognised in the

relevant line within financial assets in the consolidated statement of financial position. The economic effect of the buy-in

transactions in the Scheme is to replace the plan assets transferred with a single line policy insurance which is subsequently

eliminated on consolidation. The value of this insurance policy at 31 December 2025 was £1,294 million (2024: £1,358 million).

No contributions were paid to the Pearl Scheme in either the current or prior period. PeLHL meets the administrative and non-

investment running expenses of the Scheme as set out in the schedule of contributions.

Reimbursement right asset in respect of reinsurance arrangements

As part of the third buy-in arrangement, PLL entered into a quota share reinsurance arrangement with external reinsurers to reinsure

a total of approximately 91% of the liabilities. As PLL expects to use the claims received to pay for its obligations under the insurance

contract between it and the Pearl Scheme (i.e. to settle the defined benefit obligation) the reinsurance arrangement is considered to

be a non-qualifying insurance policy and is classified as a reimbursement right. The reinsurance arrangement is expected to match a

proportion of the defined benefit obligation of the Pearl Scheme therefore the valuation of the reimbursement right is consistent

with the valuation of the associated defined benefit obligation. The value of the reimbursement right asset amounted to

£173 million (2024: £181 million).

PLL also entered into longevity swap arrangements with external reinsurers to reinsure a proportion of the risks transferred as part

of the first, second and fourth buy-in transactions. The fair value of the reimbursement right liabilities amounted to £10 million

(2024: £34 million).

G1.2.2 Summary of amounts recognised in the consolidated financial statements

The amounts recognised in the consolidated financial statements are as follows:

			2025				2024
	Fair value of	Defined	Pension		Fair value of	Defined	Pension
	scheme	benefit	Scheme	Reimburse-	scheme	benefit	Scheme	Reimburse-
	assets	obligation	Liability	ment rights 1	assets	obligation	Liability	ment rights 1
	£m	£m	£m	£m	£m	£m	£m	£m
At 1 January	48	(1,358)	(1,310)	147	50	(1,507)	(1,457)	168
Interest income/(expense)	3	(72)	(69)	8	2	(67)	(65)	7
Included in profit or loss	3	(72)	(69)	8	2	(67)	(65)	7
Remeasurements:
Return on plan assets excluding
amounts included in interest income	3	–	3	–	(4)	–	(4)	–
Loss from changes in demographic assumptions	–	–	–	–	–	(9)	(9)	–
Gain from changes in financial assumptions	–	27	27	–	–	142	142	–
Experience gain/ (loss)	–	3	3	–	–	(17)	(17)	–
Movement in valuation of reimbursement right asset/liabilities	–	–	–	21	–	–	–	(15)
Included in other comprehensive income	3	30	33	21	(4)	116	112	(15)
Income received from insurance policies	100	–	100	–	100	–	100	–
Benefit payments	(106)	106	–	(13)	(100)	100	–	(13)
At 31 December	48	(1,294)	(1,246)	163	48	(1,358)	(1,310)	147

1 Reimbursement right asset £173 million and reimbursement right liabilities £(10) million (2024: £181 million and £(34) million respectively).

G. Other statement of consolidated financial position notes continued

G1. Pension schemes continued

G1.2 Pearl Group Staff Pension Scheme continued

G1.2.1 Scheme details continued

281Annual Report and Accounts 2025

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Standard Life plc

G1.2.3 Scheme assets

The distribution of the scheme assets at the end of the year was as follows:

		2025		2024
		Of which not		Of which not
		quoted in an		quoted in an
	Total	active market	Total	active market
	£m	£m	£m	£m
Private equities	3	3	3	3
Hedge funds	2	2	2	2
Cash and other	43	–	43	–
Reported scheme assets	48	5	48	5
Add back:
Insurance policies eliminated on consolidation	1,294	1,294	1,358	1,358
Economic value of scheme assets	1,342	1,299	1,406	1,363

G1.2.4 Defined benefit obligation

The calculation of the defined benefit obligation can be allocated to the scheme’s members as follows:

• Deferred scheme members: 26% (2024: 29%); and

• Pensioners: 74% (2024: 71%).

The weighted average duration of the defined benefit obligation at 31 December 2025 is 10 years (2024: 10 years).

G1.3 Abbey Life Staff Pension Scheme

G1.3.1 Scheme details

The Abbey Life Scheme is a registered occupational pension scheme, set up under trust, and legally separate from its principal

employer PeLHL. The scheme is administered by Abbey Life Trust Securities Limited (the trustee), a corporate trustee. There are four

trustee directors, two of whom are nominated by the Abbey Life Scheme members and two of whom are appointed by PeLHL. The

trustee is responsible for administering the scheme in accordance with the trust deed and rules and pensions laws and regulations.

The Abbey Life Scheme is closed to new entrants and has no active members.

The valuation has been based on an assessment of the liabilities of the Abbey Life Scheme as at 31 December 2025 undertaken by

independent qualified actuaries. The present values of the defined benefit obligation and the related interest costs have been

measured using the projected unit credit method.

Funding

The last funding valuation of the Abbey Life Scheme was carried out by a qualified actuary as at 31 March 2024 and showed a deficit

of £13 million. Following completion of the funding valuation a recovery plan was agreed between the Group and the trustee of

the Abbey Life Scheme for PeLHL to pay monthly contributions of £400,000 into the Scheme until 30 June 2026 to eliminate the

funding shortfall.

A new schedule of contributions was agreed effective from May 2025, for PeLHL to pay monthly contributions in respect of

administration expenses of £121,607 payable up to 31 March 2026, then increasing annually in line with the Retail Prices Index

assumption to 31 May 2030.

The final payment of £4 million into the New 2016 Charged Account agreed as part of the 2016 funding agreement has been

deferred until 2027.

The charged account is an Escrow account which was created to provide the trustees with additional security in light of the funding

deficit. The amount held in the charged account does not form part of the Abbey Life Scheme assets.

Under the terms of the New 2016 Funding Agreement the funding position of the Abbey Life Scheme will be assessed as at 31 March

2027. A payment will be made from the New 2016 Charged Account to the Scheme if the results of the assessment reveal a shortfall

calculated in accordance with the terms of the New 2016 Funding Agreement. The amount of the payment will be the lower of the

amount of the shortfall and the amount held in the New 2016 Charged Account.

282 Annual Report and Accounts 2025

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Standard Life plc

Notes to the consolidated financial statements continued

G1.3.2 Summary of amounts recognised in the consolidated financial statements

The amounts recognised in the consolidated financial statements are as follows:

		2025				2024
						Minimum
	Fair value of	Defined	Pension	Fair value of	Defined	funding	Pension
	scheme	benefit	scheme	scheme	benefit	requirement	scheme
	assets	obligation	liability	assets	obligation	obligation	liability
	£m	£m	£m	£m	£m	£m	£m
At 1 January	192	(194)	(2)	211	(218)	(2)	(9)
Interest income/(expense)	10	(11)	(1)	9	(9)	–	–
Administration expenses	(3)	–	(3)	(2)	–	–	(2)
Included in profit or loss	7	(11)	(4)	7	(9)	–	(2)
Remeasurements:
Return on plan assets excluding amounts
included in interest income	(4)	–	(4)	(19)	–	–	(19)
Gain from changes in financial assumptions	–	4	4	–	20	–	20
Experience loss	–	(1)	(1)	–	–	–	–
Change in minimum funding
requirement obligation	–	–	–	–	–	2	2
Included in other comprehensive income	(4)	3	(1)	(19)	20	2	3
Employer's contributions	6	–	6	6	–	–	6
Benefit payments	(12)	12	–	(13)	13	–	–
At 31 December	189	(190)	(1)	192	(194)	–	(2)

G1.3.3 Scheme assets

The distribution of the scheme assets at the end of the year was as follows:

		2025		2024
		Of which not		Of which not
		quoted in an		quoted in an
	Total	active market	Total	active market
	£m	£m	£m	£m
Diversified income fund	–	–	54	–
Fixed interest government bonds	129	–	131	–
Corporate bonds	73	–	86	–
Derivatives	(15)	(15)	(86)	(86)
Cash and cash equivalents	2	–	7	–
Scheme assets	189	(15)	192	(86)

G1.3.4 Defined benefit obligation

The calculation of the defined benefit obligation can be allocated to the scheme’s members as follows:

• Deferred scheme members: 35% (2024: 35%); and

• Pensioners: 65% (2024: 65%).

The weighted average duration of the defined benefit obligation at 31 December 2025 is 11 years (2024: 11 years).

G. Other statement of consolidated financial position notes continued

G1. Pension schemes continued

G1.3 Abbey Life Staff Pension Scheme continued

283Annual Report and Accounts 2025

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Standard Life plc

G1.4 ReAssure Life Staff Pension Scheme

G1.4.1 Scheme details

The ReAssure Scheme is a registered occupational pension scheme, set up under trust, and legally separate from the employer

ReAssure Midco Limited (‘RML’). The scheme is administered by ReAssure Pension Trustees Limited, a corporate trustee. There are six

trustee directors, two of whom are nominated by the ReAssure Scheme members and four of whom are appointed by RML. The

trustee is responsible for administering the scheme in accordance with the trust deed and rules and pensions laws and regulations.

The ReAssure Scheme is closed to new entrants and to future accrual for active members.

The valuation has been based on an assessment of the liabilities of the ReAssure Scheme as at 31 December 2025 undertaken by

independent qualified actuaries. The present values of the defined benefit obligation and the related interest costs have been

measured using the projected unit credit method.

Funding

The last funding valuation of the ReAssure Scheme was carried out by a qualified actuary as at 31 December 2023 and showed a

deficit of £32 million. Following completion of the 2023 valuation a recovery plan was agreed in February 2025 between the trustee

and RML in order to make good the deficit. The requirement to pay the final annual contribution in April 2025 agreed as part of the

2020 recovery plan was removed and it is anticipated that £26 million will be paid from the Custody Account on or shortly after 1 July

2026 to remove any remaining deficit at 31 December 2025.

The amounts held in this account do not form part of the Scheme’s plan assets and are instead held in the Custody Account and are

included within financial assets in the statement of consolidated financial position.

The Group agrees to cover the administrative expenses incurred by the ReAssure Scheme and the annual cost of the linked deferred

salary increases. Payments of £2 million (2024: £3 million) have been made during the year to cover these costs.

G1.4.2 Summary of amounts recognised in the consolidated financial statements

The amounts recognised in the consolidated financial statements are as follows:

		2025				2024
						Provision for
						tax on the
						economic
	Fair value of	Defined	Pension	Fair value of	Defined	surplus	Pension
	scheme	benefit	scheme	scheme	benefit	available as	scheme
	assets	obligation	asset	assets	obligation	a refund	asset
	£m	£m	£m	£m	£m	£m	£m
At 1 January	262	(242)	20	287	(273)	(5)	9
Interest income/(expense)	14	(13)	1	13	(12)	–	1
Administration expenses	(1)	–	(1)	(2)	–	–	(2)
Included in profit or loss	13	(13)	–	11	(12)	–	(1)
Remeasurements:
Return on plan assets excluding amounts
included in interest income	(9)	–	(9)	(29)	–	–	(29)
Gain from changes in financial assumptions	–	8	8	–	33	–	33
Experience loss	–	(2)	(2)	–	–	–	–
Change in provision for tax on the economic surplus available as a refund	–	–	–	–	–	5	5
Included in other comprehensive income	(9)	6	(3)	(29)	33	5	9
Employer's contributions	2	–	2	3	–	–	3
Benefit payments	(13)	13	–	(10)	10	–	–
At 31 December	255	(236)	19	262	(242)	–	20

G1.4.3 Scheme assets

The distribution of the scheme assets at the end of the year was as follows:

	2025	2024
	£m	£m
Equities	26	33
Government bonds	109	91
Corporate bonds	105	99
Other securities	11	33
Cash and cash equivalents	4	6
Scheme assets	255	262

In the current year equities, other securities and £32 million of corporate bonds are not quoted in an active market. In 2024 all

scheme assets were quoted.

284 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

G1.4.4 Defined benefit obligation

The calculation of the defined benefit obligation can be allocated to the scheme’s members as follows:

• Deferred scheme members: 55% (2024: 66%); and

• Pensioners: 45% (2024: 34%).

The weighted average duration of the defined benefit obligation at 31 December 2025 is 13 years (2024: 15 years).

G1.5 Sun Life Assurance Company of Canada 1988 UK and Irish Employee Benefits scheme

G1.5.1 Scheme details

The Sun Life Assurance Company of Canada 1988 UK and Irish Employee Benefits scheme (‘Sun Life of Canada Scheme’) was

consolidated within the Group financial statements following the acquisition of the Sun Life businesses on 3 April 2023. The Sun Life

of Canada Scheme is a registered occupational pension scheme, set up under trust, and legally separate from the principal employer

Phoenix Life CA Limited (formerly known as Sun Life Assurance Company of Canada (U.K.) Limited). The Scheme is administered by a

specialist third party administrator, Hymans Robertson LLP. A Trustee Board is responsible for ensuring the Scheme is run in

accordance with the Trust Deed and Rules and for ensuring compliance with legislation although certain tasks are delegated to third

parties. The Trustee Board is made up of three Trustees; an Independent Trustee who is also the Chair, a Principal Employer

appointed Trustee and a Member-Nominated Trustee. The Independent Trustee is Capital Cranfield Pension Trustees Limited.

The Sun Life of Canada Scheme is closed to new entrants and to future accrual for active members.

The valuation has been based on an assessment of the liabilities of the Sun Life of Canada Scheme as at 31 December 2025

undertaken by independent qualified actuaries. The present values of the defined benefit obligation and the related interest costs

have been measured using the projected unit credit method.

The economic surplus of the Scheme is anticipated to be used to cover future costs of the Scheme and will be fully utilised prior to

any winding-up of the Scheme. As a result, no provision for tax is deducted from the surplus.

Funding

The last funding valuation of the Sun Life of Canada Scheme was carried out by a qualified actuary as at 31 December 2022 and

showed a surplus of £6 million. No contributions are required to be paid by the employer into the Scheme.

G1.5.2 Summary of amounts recognised in the consolidated financial statements

The amounts recognised in the consolidated financial statements are as follows:

			2025				2024
	Fair value of	Defined	Pension		Fair value of	Defined	Pension
	scheme	benefit	scheme	Reimburse-	scheme	benefit	scheme	Reimburse-
	assets	obligation	asset	ment right	assets	obligation	asset	ment right
	£m	£m	£m	£m	£m	£m	£m	£m
At 1 January	267	(252)	15	2	297	(280)	17	2
Interest income/(expense)	14	(13)	1	–	14	(13)	1	–
Administration expenses	(1)	–	(1)	–	(2)	–	(2)	–
Included in profit or loss	13	(13)	–	–	12	(13)	(1)	–
Remeasurements:
Return on plan assets excluding
amounts included in interest income	(5)	–	(5)	–	(27)	–	(27)	–
(Loss)/gain from changes in demographic assumptions	–	(3)	(3)	–	–	1	1	–
Gain from changes in financial assumptions	–	9	9	–	–	27	27	–
Experience loss	–	(2)	(2)	–	–	(2)	(2)	–
Included in other comprehensive income	(5)	4	(1)	–	(27)	26	(1)	–
Benefit payments	(15)	15	–	–	(15)	15	–	–
At 31 December	260	(246)	14	2	267	(252)	15	2

G. Other statement of consolidated financial position notes continued

G1. Pension schemes continued

G1.4 ReAssure Life Staff Pension Scheme continued

285Annual Report and Accounts 2025

Financials

Standard Life plc

G1.5.3 Scheme assets

The distribution of the scheme assets at the end of the year was as follows:

		2025		2024
		Of which not		Of which not
		quoted in an		quoted in an
	Total	active market	Total	active market
	£m	£m	£m	£m
Debt securities	34	–	28	–
Cash and cash equivalents	1	–	8	–
Qualifying insurance contracts 1	225	225	231	231
Scheme assets	260	225	267	231

1 In 2018 and 2021 the Scheme completed two buy-in transactions with external parties which cover approximately 90% of the Scheme’s liabilities.

G1.5.4 Defined benefit obligation

The calculation of the defined benefit obligation can be allocated to the scheme’s members as follows:

• Deferred scheme members: 41% (2024: 40%); and

• Pensioners: 59% (2024: 60%).

The weighted average duration of the defined benefit obligation at 31 December 2025 is 12 years (2024: 12 years).

G1.6 PGL Pension Scheme

In January 2024, the trustees of the PGL Pension Scheme completed the buy-out of the scheme liabilities with PLL whereby the

existing annuity insurance policies between the two parties were exchanged for individual policies between PLL and the scheme’s

members. As a result, all the Group’s obligations under the pension scheme have now been fully extinguished and the defined

benefit obligation as at the settlement date of £1,097 million, reimbursement right assets of £11 million and reimbursement right

liabilities of £45 million were derecognised.

An additional premium (in excess of the value of the collateral assets transferred as premium for the original buy-in transactions) of

£18 million was prepaid by the Scheme to PLL in 2023 and has been recognised upon completion of the settlement. The difference

between the defined benefit obligation and associated reimbursement rights at this date and the total premium paid resulted in a

loss on settlement of £208 million being recognised within administration expenses in the consolidated income statement. This loss

reflects the difference between the measurement basis for the liabilities as prescribed by IAS 19 and the value prescribed for the

buy-out transfer in the original buy-in agreement which is primarily based on collateral determined using the best estimate

assumptions of PLL and the risk margin associated with those liabilities on a Solvency II basis. On completion of the buy-out, the

Scheme held minimal residual assets which were used during 2024 to cover wind-up expenses. Further details of the full impact of

the buy-out transaction are included in note B1.1.

G1.7 Sensitivity analysis

A quantitative sensitivity analysis for significant actuarial assumptions impacting the defined benefit obligation of the Group pension

schemes is shown below:

2025
Assumptions	Base	Discount rate			RPI	Life expectancy
Sensitivity level		25bps	25bps	25bps	25bps	1 year	1 year
£m		increase	decrease	increase	decrease	increase	decrease
Pearl Scheme	1,294	(31)	32	24	(23)	39	(40)
Abbey Life Scheme	190	(5)	5	4	(4)	6	(6)
ReAssure Scheme	236	(7)	8	6	(6)	6	(6)
Sun Life of Canada Scheme	246	(7)	7	6	(4)	6	(6)

2024
Assumptions	Base		Discount rate		RPI		Life expectancy
Sensitivity level		25bps	25bps	25bps	25bps	1 year	1 year
£m		increase	decrease	increase	decrease	increase	decrease
Pearl Scheme	1,358	(35)	34	19	(18)	37	(37)
Abbey Life Scheme	194	(5)	5	4	(4)	6	(6)
ReAssure Scheme	242	(9)	9	7	(7)	5	(5)
Sun Life of Canada Scheme	252	(7)	7	5	(5)	6	(6)

The above sensitivity analyses are based on a change in an assumption while holding all other assumptions constant. In practice, this

is unlikely to occur, and changes in some of the assumptions may be correlated. When calculating the sensitivity of the defined

benefit obligation to significant actuarial assumptions the same method has been applied as when calculating the defined benefit

obligation recognised within the statement of consolidated financial position.

286 Annual Report and Accounts 2025

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Standard Life plc

Notes to the consolidated financial statements continued

G2. Intangible assets

Goodwill

Business combinations are accounted for by applying the acquisition method. Goodwill represents the difference between the cost

of the acquisition and the fair value of the net identifiable assets acquired.

Goodwill is measured on initial recognition at cost. Following initial recognition, goodwill is stated at cost less any accumulated

impairment losses. Goodwill is not amortised but is tested for impairment annually or when there is evidence of possible

impairment. For impairment testing, goodwill is allocated to relevant cash generating units. Goodwill is impaired when the

recoverable amount is less than the carrying value.

In certain acquisitions an excess of the acquirer’s interest in the net fair value of the acquiree’s identifiable assets, liabilities,

contingent liabilities and non-controlling interests over cost may arise. Where this occurs, the surplus of the fair value of net assets

acquired over the fair value of the consideration is recognised in the consolidated income statement.

Acquired in-force business (‘AVIF’)

Investment contracts without DPF acquired in business combinations and portfolio transfers are measured at fair value at the time

of acquisition. At initial recognition the AVIF represents the difference between the fair value of the contractual rights acquired and

obligations assumed and the liability measured in accordance with the Group’s accounting policies. The liability measured in

accordance with the Group’s accounting policies is determined using a valuation technique to provide a reliable estimate of the

amount for which the liability could be transferred in an orderly transaction between market participants at the measurement date,

subject to a minimum equal to the surrender value. This acquired in-force business is amortised on a diminishing balance basis.

An impairment review is performed whenever there is an indication of impairment. When the recoverable amount is less than

the carrying value, an impairment loss is recognised in the consolidated income statement. The recoverable amount is determined

by reference to the value of future profits in accordance with Solvency II principles, adjusted to reflect a best estimate for the

contract boundary.

The acquired in-force business is allocated to relevant cash generating units for the purposes of impairment testing.

Brands

Brands are measured on initial recognition at cost. The cost of an intangible asset acquired in a business combination is the fair

value as at the date of the acquisition. The cost of an intangible asset acquired in exchange for a non-monetary asset is measured

at fair value as at the date of the transaction. Following initial recognition, the brand and other contractual arrangement intangible

assets are carried at cost less accumulated amortisation and any accumulated impairment losses.

Amortisation is calculated using the straight-line method to allocate the cost of brands over their estimated useful lives. They are

tested for impairment whenever there is evidence of possible impairment. For impairment testing, they are allocated to the

relevant cash generating unit. Brands are impaired when the recoverable amount is less than the carrying value.

Internally generated assets

Intangible assets arising from development costs are capitalised when it has been established that the project is technically and

financially feasible and the Group has both the intention and the ability to use the completed asset. Internally generated assets are

measured on initial recognition at cost which comprises all directly attributable costs necessary to create, produce and prepare the

asset to be capable of operating in the manner intended by management. Following initial recognition, the assets are carried at

cost less accumulated amortisation and any accumulated impairment losses.

Amortisation is calculated using the straight-line method to allocate the cost of the internally generated assets over their

estimated useful lives which is estimated to be between 3 and 10 years. They are tested for impairment whenever there is evidence

of possible impairment.

G. Other statement of consolidated financial position notes continued

287Annual Report and Accounts 2025

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Standard Life plc

			2025				2024
		Acquired				Acquired
		in-force	Other			in-force	Other
	Goodwill	business	intangibles1	Total	Goodwill	business	intangibles 1	Total
	£m	£m	£m	£m	£m	£m	£m	£m
Cost or valuation
At 1 January	57	4,196	160	4,413	57	4,196	131	4,384
Additions	–	–	10	10	–	–	29	29
At 31 December	57	4,196	170	4,423	57	4,196	160	4,413
Amortisation and impairment
At 1 January	(47)	(2,550)	(32)	(2,629)	(47)	(2,284)	(25)	(2,356)
Amortisation charge for the year	–	(230)	(8)	(238)	–	(266)	(7)	(273)
Impairment charge for the year	–	–	(2)	(2)	–	–	–	–
At 31 December	(47)	(2,780)	(42)	(2,869)	(47)	(2,550)	(32)	(2,629)
Carrying amount at 31 December	10	1,416	128	1,554	10	1,646	128	1,784
Amount recoverable after 12 months	10	1,213	116	1,339	10	1,417	118	1,545

1 The carrying amount other intangible assets includes £95 million (2024: £100 million) relating to brands and £33 million (2024: £28 million) relating to internally generated assets.

G2.1 Goodwill

The carrying value of goodwill has been tested for impairment at the year end and the results of this exercise are detailed below.

Goodwill with a carrying value of £10 million (2024: £10 million) was recognised on the acquisition of AXA Wealth during 2016 and has

been allocated to the Pensions & Savings and Europe & Other segments. This represents the value of the workforce assumed and the

potential for future value creation, which relates to the ability to invest in and grow the SunLife brand. Value in use has been

determined as the present value of certain future cash flows associated with that business. The cash flows used in the calculation are

consistent with those adopted by management in the Group’s operating plan, and for the period 2031 and beyond, assume a zero

growth rate. The underlying assumptions of these projections include market share, customer numbers, commission rates and

expense inflation. The cash flows have been valued at a risk adjusted discount rate of 15% (2024: 15%) that makes prudent allowance

for the risk that future cash flows may differ from that assumed.

This test demonstrated that value in use was greater than carrying value. Given the magnitude of the excess of the value in use over

carrying value, management does not believe that a reasonably foreseeable change in key assumptions would cause the carrying

value to exceed value in use.

G2.2 Acquired in-force business

AVIF on investment contracts without DPF is amortised in line with emergence of economic benefits over their expected term. AVIF

balances are assessed for impairment where an indicator of impairment has been identified and none were identified in either the

current or prior periods.

G2.3 Brands

On 23 February 2021, the Group entered into an agreement to acquire ownership of the Standard Life brand as part of a larger

transaction with Aberdeen Group plc, which transferred to the Group in May 2021. The Standard Life brand was initially recognised at

a value of £111 million which represented the fair value attributable to the brand as at the transaction date. The intangible asset was

valued on a ‘multi-period excess earnings’ basis and is being amortised over a period of 30 years. The carrying value of the Standard

Life brand as at 31 December 2025 is £93 million (2024: £97 million).

An intangible asset was recognised in 2016 on acquisition of AXA Wealth and represents the value attributable to the SunLife brand.

It is being amortised over a period of 10 years. The carrying value of the AXA Wealth brand as at 31 December 2025 is £2 million

(2024: £3 million).

G2.4 Internally generated assets

The Group’s strategic priorities are to ‘grow, optimise and enhance’ the business through investment. As a result of its investment

in new technology and software capability, the Group has met the requirements to capitalise these internally generated

development costs.

288 Annual Report and Accounts 2025

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Standard Life plc

Notes to the consolidated financial statements continued

G3. Property, plant and equipment

Owner-occupied property is stated at its revalued amount, being its fair value at the date of the revaluation less any subsequent

accumulated depreciation and impairment. Owner-occupied property is depreciated over its estimated useful life, which is taken as

20 – 50 years. Land is not depreciated. Accumulated depreciation as at the revaluation date is eliminated against the gross carrying

amount of the owner-occupied property and the net amount is restated to the revalued amount of the asset. Gains in owner-

occupied property are recognised in other comprehensive income. When a revaluation loss arises on a previously revalued asset it

is first deducted against any previous revaluation gain. Any excess impairment is then recorded as an impairment expense in the

consolidated income statement.

The right-of-use assets are initially measured at cost, and subsequently at cost less any accumulated depreciation and impairments,

and adjusted for certain remeasurements of the lease liability. The right-of-use assets are depreciated over the remaining lease

term which is between 1 and 15 years (2024: 1 and 8 years).

Equipment consists primarily of computer equipment and fittings. Equipment is stated at historical cost less deprecation. Where

acquired in a business combination, historical cost equates to the fair value at the acquisition date. Depreciation on equipment is

charged to the consolidated income statement over its estimated useful life of between 2 and 15 years.

			2025			2024
	Owner-	Right-of-use			Owner-	Right-of-use
	occupied	assets			occupied	assets
	properties	– property	Equipment	Total	properties	– property	Equipment	Total
	£m	£m	£m	£m	£m	£m	£m	£m
Cost or valuation
At 1 January	22	100	82	204	28	96	75	199
Additions	–	10	6	16	–	4	8	12
Revaluation losses	(1)	–	–	(1)	(6)	–	–	(6)
Disposals	–	–	(8)	(8)	–	–	(1)	(1)
	21	110	80	211	22	100	82	204
Less amounts classified
as held for sale (note H2)	(10)	–	–	(10)	–	–	–	–
At 31 December	11	110	80	201	22	100	82	204
Depreciation
At 1 January	–	(50)	(63)	(113)	–	(42)	(51)	(93)
Depreciation	–	(9)	(8)	(17)	–	(8)	(13)	(21)
Disposals	–	–	3	3	–	–	1	1
At 31 December	–	(59)	(68)	(127)	–	(50)	(63)	(113)
Carrying amount at 31 December	11	51	12	74	22	50	19	91

Owner-occupied properties have been valued by accredited independent valuers at 31 December 2025 on an open market basis in

accordance with the Royal Institution of Chartered Surveyors’ requirements, which is deemed to equate to fair value. The fair value

measurement for the properties, excluding amounts classified held for sale (see note H2), of £11 million (2024: £22 million) has been

categorised as Level 3 based on the non-observable inputs to the valuation technique used. Unrealised loss for the current year is

£1 million (2024: £6 million).

The fair value of the owner-occupied properties was derived using the investment method supported by comparison with similar

market transactions for similar properties. The significant non-observable inputs used in the valuations are the expected rental

values per square foot and the capitalisation rates.

The fair value of the owner-occupied properties valuation would increase (decrease) if the expected rental values per square foot

were to be higher (lower) and the capitalisation rates were to be lower (higher).

During the year, the Group has agreed to the sale of an owner-occupied building. The value of this property at 31 December 2025

was £10 million and no profit or loss is expected upon completion of the sale in January 2026 (see note H2).

G. Other statement of consolidated financial position notes continued

289Annual Report and Accounts 2025

Financials

Standard Life plc

G4. Investment property

Investment property, including right of use assets, is initially recognised at cost, including any directly attributable transaction

costs. Subsequently investment property is measured at fair value. Fair value is the price that would be received to sell a property

in an orderly transaction between market participants at the measurement date. Fair value is determined without any deduction

for transaction costs that may be incurred on sale or disposal. Gains and losses arising from the change in fair value are recognised

as income or an expense in the statement of comprehensive income.

Investment property includes right-of-use assets, where the Group acts as lessee. Leases, where a significant portion of the risks

and rewards of ownership are retained by the lessor, are classified as operating leases. Where investment property is leased out by

the Group, rental income from these operating leases is recognised as income in the consolidated income statement on a straight-

line basis over the period of the lease.

	2025	2024
	£m	£m
At 1 January	5,452	5,742
Additions	331	920
Improvements	73	81
Disposals	(1,346)	(1,173)
Movement in foreign exchange	11	(18)
Gains/(losses) on adjustments to fair value (recognised in consolidated income statement)	11	(100)
	4,532	5,452
Less amounts classified as held for sale (note H2)	(4)	(1,082)
At 31 December	4,528	4,370
Unrealised losses on properties held at end of year	(30)	(58)

As at 31 December 2025, a property portfolio of £4,462 million (2024: £5,368 million), including amounts classified as held for sale,

is held by the Life Companies in a mix of commercial sectors, spread geographically throughout the UK and Europe.

Investment property also includes £21 million (2024: £29 million) of property reversions arising from sales of the NPI Extra Income

Plan (see note E5 for further details) and £49 million (2024: £47 million) from the Group’s interest in the residential property of

policyholders who have previously entered into an Equity Release Income Plan (‘ERIP’) policy.

Certain investment properties held by the Life Companies possess a ground rent obligation which gives rise to both a right-of-use

asset and a lease liability. The right-of-use asset associated with the ground rent obligation is valued at fair value and is included

within the total investment property valuation. The value of the ground rent right-of-use asset as at 31 December 2025 was £nil

(2024: £8 million). There were disposals of £8 million (2024: £7 million) of ground rent right-of-use assets during the period.

Commercial investment property is measured at fair value by independent property valuers having appropriate recognised

professional qualifications and recent experiences in the location and category of the property being valued. The valuations are

carried out in accordance with the Royal Institute of Chartered Surveyors (‘RICS’) guidelines with expected income and capitalisation

rate as the key non-observable inputs.

The fair value measurement of the investment properties has been categorised as Level 3 based on the inputs to the valuation

techniques used. The following table shows the valuation techniques used in measuring the fair value of the investment properties,

the significant non-observable inputs used, the inter-relationship between the key non-observable inputs and the fair value

measurement of the investment properties:

			Weighted	Weighted
			average	average
Description	Valuation techniques	Significant non-observable inputs	2025	2024
Commercial	RICS valuation	Expected income per sq. ft.	£33.75	£25.46
Investment Property		Estimated rental value per hotel room 1	–	£6,026
		Estimated rental value per parking space	£1,448	£1,071
		Capitalisation rate	4.49%	4.91%

1 Estimated rental value per hotel room is no longer a significant non-observable input due to the related investment properties being disposed of during the year.

The estimated fair value of commercial properties would increase (decrease) if:

• the expected income were to be higher (lower); or

• the capitalisation rate were to be lower (higher).

290 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

Direct operating expenses (offset against rental income in the consolidated income statement) in respect of investment properties

that generated rental income during the year amounted to £35 million (2024: £35 million). The direct operating expenses arising

from investment property that did not generate rental income during the year amounted to £4 million (2024: £2 million).

Future minimum lease rental receivables in respect of non-cancellable operating leases on investment properties were as follows:

	2025	2024
	£m	£m
Not later than 1 year	211	259
Later than 1 year and not later than 5 years	589	830
Later than 5 years	612	2,305

G5. Other receivables

Other receivables are recognised when due and measured on initial recognition at the fair value of the amount receivable.

Subsequent to initial recognition, these receivables are measured at amortised cost using the effective interest rate method.

	2025	2024
	£m	£m
Investment broker balances	281	338
Cash collateral pledged and initial margins posted	1,896	1,995
Property related receivables	103	158
Deferred acquisition costs relating to investment contracts	119	98
Other	320	454
At 31 December	2,719	3,043
Amount recoverable after 12 months	103	91

G6. Cash and cash equivalents

Cash and cash equivalents comprise cash balances and short-term deposits with an original maturity term of three months or less

at the date of placement. Bank overdrafts that are repayable on demand and form an integral part of the Group’s cash

management are deducted from cash and cash equivalents for the purpose of the statement of consolidated cash flows. Balances

held within collective investment schemes to meet both short and long term liquidity requirements of the Group are excluded

from cash and cash equivalents.

	2025	2024
	£m	£m
Bank and cash balances	3,666	3,040
Short-term deposits (including notice accounts and term deposits)	3,636	6,446
	7,302	9,486
Less amounts classified as held for sale	–	(33)
At 31 December	7,302	9,453

Deposits are subject to a combination of fixed and variable interest rates. The carrying amounts of balances held at amortised cost

approximate to fair value at the period end. Cash and cash equivalents in long-term business operations and consolidated collective

investment schemes of £7,168 million (2024: £9,255 million) are primarily held for the benefit of policyholders and so are not

generally available for use by the owners.

The Group has a controlling interest in the abrdn Standard Liquidity Fund (a Luxembourg domiciled UCITS vehicle) and, as such,

consolidates this vehicle in accordance with the accounting policy described in note H1. This vehicle invests in a range of money

market instruments and related securities and represents assets managed on behalf of policyholders. During the year, it was

identified that £2.2 billion of securities held within the vehicle had been incorrectly classified as Cash and cash equivalents at

31 December 2024. Due to the maturity profile, these securities should have been classified as financial assets. The position at

31 December 2025 is not impacted.

The Group has assessed that this adjustment is not a material prior period error as the impact is limited to a mis-classification of

policyholder assets between cash and financial assets with no impact on net assets, net income or the return generated for

policyholders and is not expected to impact on economic decisions of the users of the financial statements. Therefore, the Group has

not restated comparatives. A consequential adjustment to correct the position is recognised in the statement of consolidated cash

flows with £2.2 billion of the ‘Increase in investments’ balance within the ‘Cash flow from operating activities’ (as shown in note I2)

relating to the correction of this mis-classification in the current period.

G. Other statement of consolidated financial position notes continued

G4. Investment property continued

291Annual Report and Accounts 2025

Financials

Standard Life plc

G7. Provisions

A provision is recognised when the Group has a present legal or constructive obligation, as a result of a past event, which is likely to

result in an outflow of resources and where a reliable estimate of the amount of the obligation can be made. If the effect is

material, the provision is determined by discounting the expected future cash flows at a pre-tax rate that reflects current market

assessments of the time value of money and, where appropriate, the risks specific to the liability.

A provision is recognised for onerous contracts when the expected benefits to be derived from the contracts are less than the

related unavoidable costs. The unavoidable costs reflect the net cost of exiting the contract, which is the lower of the cost of

fulfilling it and any compensation or penalties arising from failure to fulfil it. Costs that meet the requirements to be classified as

a provision but are determined to be directly attributable to insurance contracts and investment contracts with DPF are classified

within the insurance contract assets and liabilities. Additions and reductions to provisions are recognised within administrative

expenses within the consolidated income statement.

Where it is expected that a part of the expenditure required to settle a provision will be reimbursed by a third party the

reimbursement is recognised when, and only when, it is virtually certain that the reimbursement will be received. This

reimbursement is recognised as a separate asset within other receivables and will not exceed the amount of the provision.

							Restructuring provisions
							Transfer of
	Leasehold				Transition		ReAssure
	properties				and	Operational	policy
	dilapida-	Staff	Known	Indirect	Transforma-	simplifica-	administra-
	tions	related	incidents	Taxation	tion	tion	tion	Other	Total
2025	£m	£m	£m	£m	£m	£m	£m	£m	£m
At 1 January	12	9	15	50	54	17	34	15	206
Additions in the year	–	1	7	6	15	29	63	8	129
Utilised during the year	–	–	(9)	(1)	(16)	(30)	(63)	(13)	(132)
Released during the year	(2)	(1)	(2)	(1)	–	–	(7)	(4)	(17)
Discounting during the year	–	–	–	–	2	–	–	–	2
At 31 December	10	9	11	54	55	16	27	6	188

Known incidents

The known incidents provision was created for historical data quality, administration systems problems and process deficiencies on

the policy administration, financial reconciliations and operational finance aspects of business outsourced. These balances represent

the best estimates of costs payable to customers.

Indirect taxation

The indirect taxation provision relates to various indirect tax matters across operational taxes, employment taxes and VAT. During

the year, the provision was strengthened by £6 million (2024: £12 million), £1 million (2024: £6 million) was utilised and a further

£1 million (2024: £15 million) was released. The remaining balance at 31 December 2025 of £54 million (2024: £50 million) represents

the Group’s estimate of the maximum exposure as at the reporting date and is expected to be utilised in one to three years.

Restructuring provisions

Transition and transformation provision

Following the acquisition of the Standard Life Assurance businesses in August 2018, the Group established a transition and

transformation programme which aimed to deliver the integration of the Group’s operating models via a series of phases. During

2019, the Group announced its intention to extend its strategic partnership with Tata Consultancy Services (‘TCS’) to provide

customer servicing, to develop a digital platform and for migration of existing Standard Life policies to this platform which raised

a valid expectation of the impacts in those likely to be affected.

During 2025, following the Group’s announcement that it had entered into a new strategic partnership with Wipro and sold its

ALPHA platform to the outsource provider, the Group agreed to migrate a tranche of legacy policies within this programme to Wipro.

The accounting provision includes an element of migration costs, severance costs and other expenses not considered to be

directly attributable to insurance contracts and investment contracts with DPF. Migration costs are considered a direct expenditure

necessarily entailed by the restructuring and represent an obligation arising from arrangements entered into with TCS and Wipro.

No costs have been provided for that relate to the ongoing servicing of policies. Migration costs payable are subject to limited

uncertainty as they are largely fixed under the terms of the agreements entered into. The severance costs are subject to uncertainty

and will be impacted by the number of staff that transferred to TCS, the average salaries and number of years’ service of those

affected and the rates of natural attrition. Decommissioning costs associated with the restructure are subject to uncertainty and

will be impacted by the phasing of the decommissioning activities and any subsequent updates made to the best estimate view

of the costs.

During the year, the provision was increased by £15 million (2024: £29 million) and a further £16 million (2024: £17 million)

was utilised. The impact of discounting the provision was £2 million (2024: £(5) million) in the year. The remaining £55 million

(2024: £54 million) is expected to be utilised within one to three years.

292 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

Operational simplification

This Group-wide programme includes activity to take the Group from being a financial engineering business to a purpose led,

organically growing business over the next couple of years. As part of this, an operational simplification workstream is undertaking

activity to simplify the Group’s operating model such that the business is more efficient and focused on the Group’s new strategic

direction through review of the Group’s organisational structure and ultimately by reducing headcount in the business.

The initial provision was established in 2024 and represents the costs that are considered to be necessarily entailed by this

restructure. The severance costs are subject to uncertainty and will be impacted by the number of staff that leave the Group, and the

average salaries and number of years’ service of those affected.

During the year, the provision was increased by £29 million (2024: £34 million) and a further £30 million (2024: £17 million) was

utilised. The remaining £16 million (2024: £17 million) is expected to be utilised within one year.

Transfer of ReAssure policy administration

During 2023, the Group announced its intention to further extend its strategic partnership with TCS through the migration of all

ReAssure policies onto the TCS BaNCS platform and the consolidation of its operating locations.

Following a strategic review in 2025, and in light of emerging opportunities and advancements in the Group’s IT strategy, the Group

announced the appointment of Wipro as a new strategic partner under a Business Process Outsourcing arrangement. As part of this

partnership Wipro purchased ALPHA, the existing ReAssure platform, and assumed responsibility for the management and servicing

of the ALPHA platform.

The accounting provision includes the element of costs necessarily entailed by the restructuring and not considered to be directly

attributable to insurance contracts and investment contracts with DPF. These costs include outsource provider (‘OSP’) costs,

severance and associated implementation costs, in addition to exit costs related to the wind down of the TCS migrations.

The OSP and implementation costs payable to Wipro are subject to limited uncertainty as they are largely fixed under the terms of

the agreement entered into and the severance costs are subject to uncertainty and will be impacted by the number of staff that

transfer to Wipro, and the average salaries and number of years’ service of those affected. No costs have been provided for that

relate to the ongoing servicing of policies.

During the year, the provision was increased by £63 million (2024: £36 million), a further £63 million (2024: £nil) was utilised and

£7 million (2024: £nil) was released. The remaining £27 million (2024: £34 million) is expected to be utilised within one to two years.

Discounting

The impact of discounting on provisions during the year from either the passage of time or from a change in the discount rate has

been allowed for where the impact is considered to be material.

G8. Tax assets and liabilities

Deferred tax is provided for on temporary differences between the carrying amounts of assets and liabilities for financial reporting

purposes and the amounts used for taxation purposes. Deferred tax is not provided in respect of the initial recognition of goodwill

and the initial recognition of assets or liabilities in a transaction that is not a business combination and that, at the time of the

transaction, affects neither accounting nor taxable profit. The amount of deferred tax provided is based on the expected manner

of realisation or settlement of the carrying amount of assets and liabilities, using tax rates and laws enacted or substantively

enacted at the period end.

A deferred tax asset is recognised only to the extent that it is probable that future taxable profits will be available against which

the asset can be utilised. Deferred tax assets are reduced to the extent that it is no longer probable that the related tax benefit

will be realised.

	2025	2024
	£m	£m
Current tax:
Current tax assets	298	523
Current tax liabilities	(18)	(21)
Deferred tax:
Deferred tax assets	327	146
Deferred tax liabilities	(490)	(198)

G. Other statement of consolidated financial position notes continued

G7. Provisions continued

293Annual Report and Accounts 2025

Financials

Standard Life plc

Movement in deferred tax assets/(liabilities)

			2025					2024
			Recognised					Recognised
		Recognised	in other				Recognised	in other
		in income	comprehen-	Recognised	31		in income	comprehen-	31
	1 January	statement	sive income	in equity	December	1 January	statement	sive income	December
2025	£m	£m	£m	£m	£m	£m	£m	£m	£m
Trading losses	536	15	–	–	551	399	137	–	536
Capital losses	–	–	–	–	–	2	(2)	–	–
Expenses and deferred
acquisition costs
carried forward	245	(103)	–	–	142	422	(177)	–	245
Provisions and other temporary differences	3	17	–	6	26	4	(1)	–	3
Non-refundable pension
scheme surplus	(57)	14	(12)	–	(55)	(91)	66	(32)	(57)
Committed future
pension contributions	–	–	–	–	–	3	(3)	–	–
Transitional adjustment
relating to IFRS 9/17	15	(2)	–	–	13	10	5	–	15
Accelerated capital allowances	26	(1)	–	–	25	23	3	–	26
Intangibles	1	–	–	–	1	31	(30)	–	1
Acquired in-force business	(314)	41	–	–	(273)	(361)	47	–	(314)
Customer relationships	(25)	1	–	–	(24)	(27)	2	–	(25)
Unrealised gains	(412)	(160)	–	–	(572)	(361)	(51)	–	(412)
Actuarial liability differences
between local GAAP and IFRS	(69)	64	–	–	(5)	(242)	173	–	(69)
Exchange differences
on translation of foreign operations	–	–	8	–	8	–	–	–	–
Other	(1)	1	–	–	–	11	(12)	–	(1)
	(52)	(113)	(4)	6	(163)	(177)	157	(32)	(52)

The standard rate of UK Corporation tax for the year ended 31 December 2025 is 25% (year ended 31 December 2024: 25%).

Shareholder deferred tax assets and liabilities, where provided, are reflected at 25%. Deferred tax assets are recognised for tax

losses carried forward only to the extent that realisation of the related tax benefit is probable.

The deferred tax asset relating to trading losses has increased in 2025 from £536 million to £551 million, as shown in the table above

(2024: increase from £399 million to £536 million). This has arisen principally due to refinements of prior period tax calculations that

gave rise to additional tax losses. The increase in 2024 arose due to net taxable losses arising within the constituent entities of the

Group. The Group utilises profit forecasts to support recognition of a deferred tax asset in relation to the losses. The profit forecasts

are prepared for the Annual Operating Plan which is used for various purposes including target setting, dividend affordability

assessments and going concern. The Group considers the forecasts to be a reliable source of information to support the recognition of

a deferred tax asset in relation to the losses. The forecasts suggest that the losses will be utilised in full within 5 years (2024: 8 years).

	2025	2024
	£m	£m
Deferred tax assets have not been recognised in respect of:
Tax losses carried forward	49	54
Deferred tax assets not recognised on capital losses	103	116

A technical matter is currently being discussed with HMRC in relation to the L&G insurance business transfer to ReAssure Limited.

These discussions are not sufficiently progressed at this stage for recognition of any potential tax benefit arising.

The Group is continuing to monitor developments in relation to the G20-OECD Inclusive Framework, commonly referred to as Pillar

Two rules (‘Pillar Two’), as the Group is within the scope of the rules from 1 January 2024. Broadly, these rules seek to ensure that, on

a jurisdiction-by-jurisdiction basis, large multinational enterprises pay a minimum tax rate of 15% on worldwide profits arising after

31 December 2023.

In May 2023, the scope of IAS 12 Income Taxes was amended to clarify that the IFRS accounting standard applies to income taxes

arising from tax law enacted or substantively enacted to implement the Pillar Two model rules published by the OECD, including tax

law that implements qualified domestic minimum top-up taxes described in those rules. The amendments introduce a temporary

exception to the accounting requirements for deferred taxes in IAS 12, so that an entity would neither recognise nor disclose

information about deferred tax assets and liabilities related to Pillar Two income taxes. The Group confirms that it has applied this

exception during the period.

294 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

The main jurisdictions in which the Group may have exposures to Pillar Two income taxes are Ireland and the UK. As at 31 December

2025, the Group has accrued £nil (2024: £nil) in respect of Pillar Two income taxes based on its latest assessment. The Group also

notes that the Pillar Two income taxes legislation is expected to continue developing, the rules are inherently complex and can

potentially lead to arbitrary outcomes and therefore the Group is continuing to assess the impact of the Pillar Two income taxes

legislation on its operations.

G9. Lease Liabilities

The lease liability is initially measured at the present value of the lease payments that are not paid at the commencement date,

discounted using the Group’s incremental borrowing rate as the interest rate implicit in the lease cannot be readily determined.

For ground rent leases, the incremental borrowing rate of investment funds holding the associated investment properties is used

as the discount rate. The lease liability is subsequently increased by the interest cost on the lease liability and decreased by lease

payments made. It is remeasured when there is a change in future lease payments arising from, for example, rent reviews or from

changes in the assessment of whether a termination option is reasonably certain not to be exercised. The Group has applied

judgement to determine the lease term for some lease contracts with break clauses.

	2025	2024
	£m	£m
At 1 January	64	74
Leases incepted during the year	11	6
Termination of leases following the disposal of associated investment properties	(8)	(7)
Interest expense	2	2
Lease payments	(10)	(11)
At 31 December	59	64
Amount due within 12 months	12	13
Amount due after 12 months	47	51

Details of the related right-of-use assets are included in notes G3 and G4.

G10. Accruals and deferred income

This note analyses the Group’s accruals and deferred income at the end of the year.

	2025	2024
	£m	£m
Accruals	498	546
Deferred income	67	37
At 31 December	565	583
Amounts due for settlement after 12 months	39	38

G11. Other payables

Other payables are recognised when due and are measured on initial recognition at the fair value of the consideration payable.

Subsequent to initial recognition, these payables are measured at amortised cost using the effective interest rate method.

	2025	2024
	£m	£m
Investment broker balances	969	718
Property related payables	81	57
Investment management fees	13	18
Other	1,366	1,487
At 31 December	2,429	2,280
Amounts due for settlement after 12 months	31	–

G. Other statement of consolidated financial position notes continued

G8. Tax assets and liabilities continued

295Annual Report and Accounts 2025

Financials

Standard Life plc

H. Interests in subsidiaries and associates

H1. Subsidiaries

Subsidiaries are consolidated from the date that effective control is obtained by the Group (see Basis of consolidation in note A1)

which for operating entities is usually when the Group holds over 50% of the shareholding of that entity. Subsidiaries are excluded

from consolidation from the date they cease to be subsidiary undertakings and for those disposed of during the year, any

difference arising from the recognition of the net proceeds, recognition of the fair value of any retained interest and derecognition

of the carrying amount of the subsidiary including non-controlling interests, is recognised in the consolidated income statement.

The Group uses the acquisition method to account for the acquisition of subsidiaries. The cost of an acquisition is measured at the

fair value of the consideration. Any excess of the cost of acquisition over the fair value of the net assets acquired is recognised as

goodwill. In certain acquisitions an excess of the acquirer’s interest in the net fair value of the acquiree’s identifiable assets,

liabilities, contingent liabilities and non-controlling interests over cost may arise. Where this occurs, the surplus of the fair value of

net assets acquired over the fair value of the consideration is recognised in the consolidated income statement.

Directly attributable acquisition costs are included within administrative expenses, except for acquisitions undertaken prior to 2010

when they are included within the cost of the acquisition. Costs directly related to the issuing of debt or equity securities are

included within the initial carrying amount of debt or equity securities where these are not carried at fair value. Intra-group balances

and income and expenses arising from intra-group transactions are eliminated in preparing the consolidated financial statements.

The Group invests in a number of collective investment schemes such as Open-ended Investment Companies (‘OEICs’), unit trusts,

Société d’Investissement à Capital Variable (‘SICAVs’), investment trusts and private equity funds. These invest mainly in equities,

bonds, property and cash and cash equivalents. The Group’s percentage ownership in these collective investment schemes can

fluctuate according to the level of Group and third party participation in the structures.

When assessing control over collective investment schemes, the Group considers those factors described under the Basis of

consolidation in note A1. In particular, the Group considers the scope of its decision-making authority, including the existence of

substantive rights (such as power of veto, liquidation rights and the right to remove the fund manager) that give it the ability to

direct the relevant activities of the investee. The assessment of whether rights are substantive rights, and the circumstances under

which the Group has the practical ability to exercise them, requires the exercise of judgement. This assessment includes a

qualitative consideration of the rights held by the Group that are attached to its holdings in the collective investment schemes,

rights that arise from contractual arrangements between the Group and the entity or fund manager and the rights held by third

parties. In addition, consideration is made of whether the Group has de facto power, for example, where third party investments in

the collective investment schemes are widely dispersed.

Where Group companies are deemed to control such collective investment schemes they are consolidated in the Group financial

statements, with the interests of external third parties recognised as a liability (see the accounting policy for Net asset value

attributable to unitholders in note E1 for further details).

Certain of the collective investment schemes have non-coterminous period ends and are consolidated on the basis of additional

financial statements prepared to the period end.

Portfolio transfers

When completing an acquisition, the Group first considers whether the acquisition meets the definition of a business combination

under IFRS 3 Business Combinations. IFRS 3, and the use of acquisition accounting, does not apply in circumstances where the

acquisition of an asset or a group of assets does not constitute a business, and is instead a portfolio of assets and liabilities. In such

cases, the Group’s policy is to recognise and measure the assets acquired and liabilities assumed in accordance with the Group's

accounting policies for those assets and liabilities. The difference between the consideration and the net assets or liabilities

acquired is recognised in the consolidated income statement.

H1.1 Significant restrictions

The ability of subsidiaries to transfer funds to the Group in the form of cash dividends or to repay loans and advances is subject to

local laws, regulations and solvency requirements.

Each regulated company and the Group must retain sufficient capital at all times to meet the regulatory capital requirements

mandated by or otherwise agreed with the relevant national supervisory authority. Further information on the capital requirements

applicable to Group entities are set out in the Capital management section (note I3). Under UK company law, dividends can only be

paid if a UK company has distributable reserves sufficient to cover the dividend.

In addition, contractual requirements may place restrictions on the transfer of funds as follows:

• Pearl Life Holdings Limited (‘PeLHL’) is required to make payments of contributions into charged accounts on behalf of the Abbey

Life Scheme. These amounts do not form part of the pension scheme assets and at 31 December 2025, PeLHL held £20 million

(2024: £20 million) within debt securities and £20 million (2024: £19 million) within cash and cash equivalents in respect of these

charged accounts. Further details of when the remaining amounts may become payable to the pension scheme are included in

note G1.3.

• ReAssure Midco Limited (‘RML’) is required to make payments of contributions into a ring-fenced account on behalf of the

ReAssure Staff Pension Scheme. These amounts do not form part of the pension scheme assets and at 31 December 2025, RML

held £44 million (2024: £43 million) within debt securities in respect of this account. Further details of when these amounts may

become payable to the pension scheme are included in note G1.4.

296 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

H2. Assets and liabilities classified as held for sale

The Group classifies disposal groups as held for sale if their carrying amounts will be recovered principally through a sale

transaction rather than through continuing use. Disposal groups classified as held for sale are measured at the lower of their

carrying amount and fair value less costs to sell. Costs to sell are the incremental costs directly attributable to the disposal of the

disposal group, excluding finance costs and income tax expense. Assets and liabilities classified as held for sale are presented

separately in the statement of consolidated financial position.

H2.1 Transfer of business to Aberdeen Group plc

On 28 March 2025, the Group completed the Part VII transfer of the UK Trustee Investment Plan (‘TIP’) business to Aberdeen Group

plc. This business was classified as a disposal group held for sale prior to the transfer. The self-invested elements of the Wrap SIPP

business, which are held off-balance sheet, are expected to be transferred to Aberdeen Group plc. At 31 December 2025, there are

no assets or liabilities classified as held for sale.

In 2024, an agreement was reached with Aberdeen Group plc to enter into an External Funds Link (‘EFL’) reinsurance arrangement

upon completion of the Part VII to provide access to the retained pooled property funds. On completion of the Part VII in 2025, a

financial liability has been recognised in respect of the EFL arrangement. No profit or loss has been recognised during the year

following the Part VII and initial recognition of the EFL reinsurance arrangement.

H2.2 Disposal of Wythall Green site

During the year the Group finalised the details of the agreed sale of the Wythall Green site which includes land and an owner-

occupied building. The sale completed in January 2026 and at 31 December 2025 the land and buildings are measured at the value

of the expected net sales proceeds and are classified as held for sale.

The major classes of assets and liabilities reported as held for sale are as follows:

	2025	2024
	£m	£m
Property, plant and equipment	10	–
Investment property	4	1,082
Financial assets	–	1,985
Cash and cash equivalents	–	33
Assets classified as held for sale	14	3,100
Assets in consolidated funds 1	–	75
Total assets of the disposal group	14	3,175
Investment contract liabilities	–	(3,175)
Liabilities classified as held for sale	–	(3,175)

1 Included in assets of the disposal group at 31 December 2024 were assets in consolidated funds, which were held to back investment contract liabilities of the TIP business and

were disclosed within financial assets in the statement of consolidated financial position. The Group controlled these funds at 31 December 2024 and therefore consolidated 100%

of the assets with any non-controlling interest recognised as net asset value attributable to unit holders.

H3. Associates

Associates are entities over which the Group has significant influence, but which it does not control. Generally it is presumed that

the Group has significant influence if it holds between 20% and 50% of the voting rights of the entity. Investments in associates

that are held for investment purposes are accounted for under IFRS 9 Financial Instruments as permitted by IAS 28 Investments in

Associates and Joint Ventures. These are measured at fair value through profit or loss. Those held for strategic purposes are

accounted for using the equity method of accounting. Under the equity method, on initial recognition the investment in an

associate is recognised at cost. The carrying value is then updated to reflect the Group’s share of profit or loss of its associate and

that share is recognised in the consolidated income statement.

During 2024, the Group announced an agreement with Schroders, to launch Future Growth Capital (‘FGC’), the first private market

investment manager to be established in the UK to promote the objectives of the Mansion House Compact. The Company’s

investment in FGC is through a 49.9% holding in Future Growth Capital (Holdings) Limited and its wholly owned subsidiary

undertaking, Future Growth Capital Limited. This investment in the FGC associate is accounted for using the equity method in

the consolidated financial statements. At 31 December 2025, the Group’s share of the investment is £11 million (2024: £4 million).

The movement in the year arises from a capital injection into the associate of £10 million (2024: £5 million) and the Group’s share

of the loss from the associate of £(3) million (2024: £(1) million), included within net investment income in the consolidated

income statement.

H. Interests in subsidiaries and associates continued

297Annual Report and Accounts 2025

Financials

Standard Life plc

Summary consolidated financial information (at 100%) for Future Growth Capital Holdings Limited group is shown below:

	2025	2024
	£m	£m
Total assets	26	10
Total liabilities	(5)	(3)
	21	7
Loss for the year after tax	(7)	(2)

H4. Structured entities

A structured entity is an entity that has been designed so that voting or similar rights are not the dominant factor in deciding who

controls the entity, such as when any voting rights relate to administrative tasks only, and the relevant activities are directed by

means of contractual arrangements. A structured entity often has some or all of the following features or attributes: (a) restricted

activities; (b) a narrow and well-defined objective, such as to provide investment opportunities for investors by passing on risks and

rewards associated with the assets of the structured entity to investors; (c) insufficient equity to permit the structured entity to

finance its activities without subordinated financial support; and (d) financing in the form of multiple contractually linked

instruments to investors that create concentrations of credit or other risks (tranches).

The Group has determined that all of its investments in collective investment schemes are structured entities. In addition, a number

of debt security structures and private equity funds have been identified as structured entities. The Group has assessed that it has

interests in both consolidated and unconsolidated structured entities as shown below:

• unit trusts;

• OEICs;

• SICAVs;

• private equity funds;

• asset-backed securities;

• Collateralised Debt Obligations (‘CDOs’);

• other debt structures; and

• Phoenix Group Employee Benefit Trust (‘EBT’).

The Group’s holdings in the investments listed above are susceptible to market price risk arising from uncertainties about future

values. Holdings in investment funds are subject to the terms and conditions of the respective fund’s prospectus and the Group holds

redeemable shares or units in each of the funds. The funds are managed by internal and external fund managers who apply various

investment strategies to accomplish their respective investment objectives. All of the funds are managed by fund managers who are

compensated by the respective funds for their services. Such compensation generally consists of an asset-based fee and a

performance-based incentive fee and is reflected in the valuation of each fund.

H4.1 Interests in consolidated structured entities

The Group has determined that where it has control over funds, these investments are consolidated structured entities.

The EBT is a consolidated structured entity that holds shares to satisfy awards granted to employees under the Group’s share-based

payment schemes. During the year, the Group granted further loans to the EBT of £9 million (2024: £16 million).

As at the reporting date, the Group has no intention to provide financial or other support to any other consolidated structured entity.

H4.2 Interests in unconsolidated structured entities

The Group has interests in unconsolidated structured entities. These investments are held as financial assets in the Group’s

consolidated statement of financial position held at fair value through profit or loss. Any change in fair value is included in the

consolidated income statement in ‘net investment income’. Dividend and interest income is received from these investments.

A summary of the Group’s interest in unconsolidated structured entities is included below. These are shown according to the

financial asset categorisation in the consolidated statement of financial position.

	2025	2024
	Carrying value of	Carrying value of
	financial assets	financial assets
	£m	£m
Equities	1,654	1,398
Collective investment schemes	83,446	82,740
Debt securities	7,642	7,542
	92,742	91,680

The Group’s maximum exposure to loss with regard to the interests presented above is the carrying amount of the Group’s

investments. Once the Group has disposed of its shares or units in a fund, it ceases to be exposed to any risk from that fund. The

Group’s holdings in the above unconsolidated structured entities are largely less than 50% and as such the size of these structured

entities are likely to be significantly higher than their carrying value.

Details of commitments to subscribe to private equity funds and other unlisted assets are included in note I5.

298 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

H5. Group entities

The table below sets out the Group's subsidiaries (including consolidated collective investment schemes), associates and significant

holdings in undertakings (including undertakings in which the holding amounts to 20% or more of the nominal value of the shares or

units and they are not classified as a subsidiary or associate).

			If unincorporated,	Type of investment
		Registered address of	address of principal	(including class of
		incorporated entities	place of business	shares held)	% of shares /units held
Subsidiaries:
Phoenix Life Limited (life assurance company)		Birmingham¹		Ordinary Shares	100.00%
Phoenix Europe Operations (Stephen's Green)		Dublin²		Ordinary Shares	100.00%
Designated Activity Company (formerly Phoenix Life
Assurance Europe DAC) (non-trading company)
Phoenix Life CA Limited (life assurance company)		Birmingham¹		Ordinary Shares	100.00%
ReAssure Life Limited (life assurance company)		Telford³		Ordinary Shares	100.00%
ReAssure Limited (life assurance company)		Telford³		Ordinary Shares	100.00%
Standard Life Assurance Limited (life assurance		Edinburgh⁴		Ordinary Shares	100.00%
company – directly owned by the Company)
Standard Life International Designated Activity Company		Dublin²		Ordinary Shares	100.00%
(life assurance company – directly owned by the Company)
Pearl Group Services Limited		Birmingham¹		Ordinary Shares	100.00%
(management services company)
Phoenix Group Management Services Limited		Birmingham¹		Ordinary Shares	100.00%
(management services company)
PGMS (Ireland) Limited (management services company)		Dublin⁵		Ordinary Shares	100.00%
Phoenix Management Services (Bermuda) Limited		Bermuda⁶		Ordinary Shares	100.00%
ReAssure UK Services Limited		Telford³		Ordinary Shares	100.00%
(management services company)
PA (GI) Limited (non-trading company)		Birmingham¹		Ordinary Shares	100.00%
103	Wardour Street Retail Investment	Telford³		Ordinary Shares	100.00%
Company Limited (investment company)
3 St Andrew Square Apartments Limited		Edinburgh⁷		Ordinary Shares	100.00%
(property management company)
Abbey Life Assurance Company Limited		Birmingham¹		Ordinary Shares	100.00%
(non-trading company)
Abbey Life Trust Securities Limited		Birmingham¹		Ordinary Shares	100.00%
(pension trustee company)
Abbey Life Trustee Services Limited (dormant company)		Birmingham¹		Ordinary Shares	100.00%
Alba Life Trustees Limited (non-trading company)		Edinburgh⁴		Ordinary Shares	100.00%
Axial Fundamental Strategies (US Investments)		Wilmington⁸		Limited Liability	100.00%
LLC (investment company)				Company
Alba LAS Pensions Management		Edinburgh⁴		Ordinary Shares	100.00%
Limited (dormant company)
Barnwood Properties Limited (property		Birmingham¹		Ordinary Shares	100.00%
investment company)
BA (FURBS) Limited (dormant company)		Birmingham¹		Ordinary Shares	100.00%
BL Telford Limited (dormant company)		Telford³		Ordinary Shares	100.00%
Britannic Finance Limited (finance and insurance services company)		Birmingham¹		Ordinary Shares	100.00%
Britannic Group Services Limited (dormant company)		Birmingham¹		Ordinary Shares	100.00%
Britannic Money Investment Services		Birmingham¹		Ordinary Shares	100.00%
Limited (investment advice company)
CH Management Limited (investment company)		Wilmington⁸		Ordinary Shares	100.00%
Century Trustee Services Limited (dormant company)		Birmingham¹		Ordinary Shares	100.00%
CGE Management Company Limited		Edinburgh⁷		Ordinary Shares	100.00%
Cityfourinc (dormant company)		Birmingham¹		Unlimited with	100.00%
				Shares
G Assurance & Pensions Services		Telford³		Ordinary Shares	100.00%
Limited (non-trading company)
Patria Private Equity Trust plc (investment company)		Edinburgh⁹		Ordinary Shares	55.40%

H. Interests in subsidiaries and associates continued

299Annual Report and Accounts 2025

Financials

Standard Life plc

		If unincorporated,	Type of investment
	Registered address of	address of principal	(including class of
	incorporated entities	place of business	shares held)	% of shares /units held
Phoenix Group Holdings (non-trading company)	Cayman Islands¹⁰		Private Company 100.00%
Pearl (WP) Investments LLC (investment company)	Wilmington⁸		Limited Liability	100.00%
			Company
ERIP General Partner Limited (General	Telford³		Ordinary Shares	80.00%
Partner to ERIP Limited Partnership)
ERIP Limited Partnership (Limited Partnership)	Telford³		Ordinary Shares	100.00%
G Financial Services Limited (dormant company)	Telford³		Ordinary Shares	100.00%
G Life H Limited (holding company)	Telford³		Ordinary Shares	100.00%
G Trustees Ltd (trustee company)	Telford³		Ordinary Shares	100.00%
Gallions Reach Shopping Park (Nominee)	London¹¹		Ordinary Shares	100.00%
Limited (dormant company)
Gresham Life Assurance Society Limited (dormant company) Telford³			Ordinary Shares	100.00%
Iceni Nominees (No. 2) Limited (dormant company)	London¹¹		Ordinary Shares	100.00%
IH (Jersey) Limited (dormant company)	Jersey¹²		Ordinary Shares	100.00%
Impala Holdings Limited (holding company)	Birmingham¹		Ordinary Shares	100.00%
Inhoco 3107 Limited (dormant company)	London¹¹		Ordinary Shares	100.00%
Laurtrust Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
Standard Life Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
London Life Trustees Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
Namulas Pension Trustees Limited (trustee company)	Telford³		Ordinary Shares	100.00%
National Provident Institution (dormant company)	Birmingham¹		Unlimited	100.00%
			without Shares
National Provident Life Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
NM Life Trustees Limited (dormant company)	Telford³		Ordinary Shares	100.00%
NM Pensions Limited (dormant company)	Telford³		Ordinary Shares	100.00%
NP Life Holdings Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
NPI (Printworks) Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
NPI (Westgate) Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
Pearl (Covent Garden) Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
Pearl (Moor House) Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
Pearl AL Limited (dormant company)	Edinburgh⁴		Ordinary Shares	100.00%
Pearl Assurance Group Holdings	Birmingham¹		Ordinary Shares	100.00%
Limited (investment company)
Pearl Customer Care Limited (financial services company)	Birmingham¹		Ordinary Shares	100.00%
Pearl Group Holdings (No. 1) Limited (finance company)	London¹³		Ordinary Shares	100.00%
Pearl Group Holdings (No. 2) Limited (holding company)	Birmingham¹		Ordinary Shares	100.00%
Pearl Group Secretariat Services	Birmingham¹		Ordinary Shares	100.00%
Limited (dormant company)
Pearl Life Holdings Limited (holding company)	Birmingham¹		Ordinary Shares	100.00%
Pearl MP Birmingham Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
Pearl RLG Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
Pearl Trustees Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
PG Dormant (No 4) Limited) (dormant company)	Birmingham¹		Ordinary Shares	100.00%
PG Dormant (No 5) Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
PG Dormant (No 6) Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
PGMS (Glasgow) Limited	Edinburgh⁴		Ordinary Shares	100.00%
PGMS (Ireland) Holdings Unlimited	Dublin⁵		Unlimited with	100.00%
Company (holding company)			Shares
PGS 2 Limited (investment company)	Birmingham¹		Ordinary Shares	100.00%
Phoenix Life Assurance Limited (non-trading company)	Birmingham¹		Ordinary Shares	100.00%
Phoenix & London Assurance Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
Phoenix Advisers Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
Phoenix AW Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
Phoenix Customer Care Limited (financial	Birmingham¹		Ordinary Shares	100.00%
services company)

300 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

		If unincorporated,	Type of investment
	Registered address of	address of principal	(including class of
	incorporated entities	place of business	shares held)	% of shares /units held
Phoenix ER1 Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
Phoenix ER2 Limited (finance company)	Birmingham¹		Ordinary Shares	100.00%
Phoenix ER3 Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
Phoenix ER4 Limited (finance company)	Birmingham¹		Ordinary Shares	100.00%
Phoenix ER5 Limited (finance company)	Birmingham¹		Ordinary Shares	100.00%
Phoenix ER6 Limited (finance company)	Birmingham¹		Ordinary Shares	100.00%
Phoenix Group Employee Benefit Trust	Jersey¹⁴		Trust	100.00%
Phoenix Group Holdings (Bermuda) Limited (holding	Bermuda¹⁵		Ordinary Shares	100.00%
company – directly owned by the Company)
Phoenix Group CA Services Limited	Birmingham¹		Ordinary Shares	100.00%
Phoenix Group Management Ltd (dormant company)	Birmingham¹		Ordinary Shares	100.00%
PG Dormant (No 7) Limited (dormant company)	London¹³		Ordinary Shares	100.00%
Phoenix Life Holdings Limited (holding company	Birmingham¹		Ordinary Shares	100.00%
– directly owned by the Company)
Phoenix Management Services Holdings	Bermuda¹⁵		Ordinary Shares	100.00%
(Bermuda) Limited (holding company)
Phoenix Pension Scheme (Trustees)	Birmingham¹		Ordinary Shares	100.00%
Limited (dormant company)
Phoenix Pensions Trustee Services	Birmingham¹		Ordinary Shares	100.00%
Limited (dormant company)
Phoenix Real Estate Management GP Limited	London¹³		Ordinary Shares	100.00%
Phoenix Life Income Strips No.1 Limited	Birmingham¹		Ordinary Shares	100.00%
Partnership (finance company)
Phoenix SCP Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
Phoenix SCP Pensions Trustees Limited (trustee company)	Birmingham¹		Ordinary Shares	100.00%
Phoenix SCP Trustees Limited (trustee company)	Edinburgh⁴		Ordinary Shares	100.00%
Phoenix SL Direct Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
Phoenix SPV1 Limited (investment company)	Birmingham¹		Ordinary Shares	100.00%
Phoenix SPV2 Limited (investment company)	Birmingham¹		Ordinary Shares	100.00%
Phoenix SPV3 Limited (investment company)	Birmingham¹		Ordinary Shares	100.00%
Phoenix SPV4 Limited (investment company)	Birmingham¹		Ordinary Shares	100.00%
Phoenix ULA Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
Phoenix Unit Trust Managers Limited (unit trust manager)	Birmingham¹		Ordinary Shares	100.00%
Phoenix Wealth Holdings Limited (holding company)	Birmingham¹		Ordinary Shares	100.00%
Phoenix Wealth Services Limited	Birmingham¹		Ordinary Shares	100.00%
(financial services company)
Phoenix Wealth Trustee Services Limited (trustee company) Birmingham¹			Ordinary Shares	100.00%
Pilangen Logistik AB (investment company)	Stockholm¹⁶		Ordinary Shares	100.00%
Pilangen Logistik I AB (investment company)	Stockholm¹⁶		Ordinary Shares	100.00%
ReAssure Companies Services Limited	Telford³		Ordinary Shares	100.00%
ReAssure FS Limited (dormant company)	Telford³		Ordinary Shares	100.00%
ReAssure FSH UK Limited (holding company)	Telford³		Ordinary Shares	100.00%
ReAssure Group Limited (formerly ReAssure Group plc)	Telford³		Ordinary Shares	100.00%
(holding company – directly owned by the Company)
ReAssure Life Pension Trustees Limited (dormant company)	Telford³		Ordinary Shares	100.00%
ReAssure LL Limited (dormant company)	Telford³		Ordinary Shares	100.00%
ReAssure Midco Limited (holding company)	Telford³		Ordinary Shares	100.00%
ReAssure Nominees Limited (dormant company)	Telford³		Ordinary Shares	100.00%
ReAssure Pension Trustees Limited (dormant company)	Telford³		Ordinary Shares	100.00%
ReAssure PM Limited (dormant company)	Telford³		Ordinary Shares	100.00%
ReAssure Trustees Limited (dormant company)	Telford³		Ordinary Shares	100.00%
ReAssure Two Limited (dormant company)	Telford³		Ordinary Shares	100.00%

H. Interests in subsidiaries and associates continued

H5. Group entities continued

301Annual Report and Accounts 2025

Financials

Standard Life plc

		If unincorporated,	Type of investment
	Registered address of	address of principal	(including class of
	incorporated entities	place of business	shares held)	% of shares /units held
ReAssure UK Life Assurance Company	Telford³		Ordinary Shares	100.00%
Limited (dormant company)
Scottish Mutual Assurance Limited (dormant company)	Edinburgh⁴		Ordinary Shares	100.00%
Scottish Mutual Nominees Limited (dormant company)	Edinburgh⁴		Ordinary Shares	100.00%
Scottish Mutual Pension Funds Investment	Edinburgh⁴		Ordinary Shares	100.00%
Limited (trustee company)
SL (NEWCO) Limited (dormant company)	Edinburgh⁴		Ordinary Shares	100.00%
SL Liverpool Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
SLA Belgium No.1 SA (investment company)	Belgium¹⁷		Société Anonyme100.00%
SLA Denmark No.1 ApS (investment company)	Copenhagen¹⁸		Ordinary Shares	100.00%
SLA Denmark No.2 ApS (investment company)	Copenhagen¹⁸		Ordinary Shares	100.00%
SLA Germany No.1 S.à.r.l. (investment company)	Luxembourg¹⁹		Ordinary Shares	100.00%
SLA Germany No.2 S.à.r.l. (investment company)	Luxembourg¹⁹		Ordinary Shares	100.00%
SLA Germany No.3 S.à.r.l. (investment company)	Luxembourg¹⁹		Ordinary Shares	100.00%
SLA Coudray SAS	Paris²⁰		Ordinary Shares	100.00%
SLA Spain No.1 S.L.U.	Madrid²¹		Ordinary Shares	100.00%
SLA France SCI (investment company)	Paris²⁰		Ordinary Shares	100.00%
SLA Netherlands No.1 B.V. (investment company)	Amsterdam²²		Ordinary Shares	100.00%
SLACOM (No. 8) Limited (dormant company)	Edinburgh⁴		Ordinary Shares	100.00%
Phoenix Life CA Holdings Limited (holding	Basingstoke²³		Ordinary Shares	100.00%
company – directly owned by the Company)
SLIF Property Investment GP Limited (General	Edinburgh⁷		Ordinary Shares	100.00%
Partner to SLIF Property Investment)
Standard Life Financial Advice Services Limited	Birmingham¹		Ordinary Shares	100.00%
(financial services distribution company)
Standard Life Assurance (HWPF) Luxembourg	Luxembourg¹⁹		Ordinary Shares	100.00%
S.à.r.l. (investment company)
Standard Life Group Limited	Birmingham¹		Ordinary Shares	100.00%
Standard Life Investment Funds Limited	Edinburgh⁴		Ordinary Shares	100.00%
Standard Life Lifetime Mortgages Limited	Edinburgh⁴		Ordinary Shares	100.00%
(mortgage provider company)
Standard Life Master Trust Co. Ltd (dormant company)	Birmingham¹		Ordinary Shares	100.00%
Standard Life Mortgages Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
Standard Life Property Company	Edinburgh⁴		Ordinary Shares	100.00%
Limited (dormant company)
Standard Life Trustee Company Limited (trustee company)	Edinburgh⁴		Ordinary Shares	100.00%
Standard Life Assets and Employee Services Limited	Edinburgh⁴		Ordinary Shares	100.00%
Standard Life Pension Funds Limited	Edinburgh⁴		Limited by	100.00%
			Guarantee
PGH CA Limited (dormant company)	Birmingham¹		Ordinary Shares	100.00%
SunLife Limited (financial services distribution company)	Birmingham¹		Ordinary Shares	100.00%
The Heritable Securities and Mortgage Investment	Edinburgh⁴		Ordinary Shares	100.00%
Association Ltd (dormant company)
The London Life Association Limited (dormant company)	Birmingham¹		Limited by	100.00%
			Guarantee
The Pathe Building Management Company	Telford³		Ordinary Shares	100.00%
Limited (dormant company)
The Phoenix Life SCP Institution (dormant company)	Edinburgh⁴		Limited by	100.00%
			Guarantee
The Scottish Mutual Assurance Society (dormant company)	Edinburgh⁴		Limited by	100.00%
			Guarantee
The Standard Life Assurance Company of Europe B.V. (financial holding company)	Amsterdam²²		Ordinary Shares	100.00%
Vebnet (Holdings) Limited (holding company)	Birmingham¹		Ordinary Shares	100.00%
Welbrent Property Investment Company	London¹¹		Ordinary Shares	100.00%
Limited (dormant company)

302 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

		If unincorporated,	Type of investment
	Registered address of	address of principal	(including class of
	incorporated entities	place of business	shares held)	% of shares /units held
Phoenix Highvista Venture Capital Partners LP		Boston²⁴	Limited	80.00%
			Partnership
Pearl Private Equity LP		Edinburgh²⁵	Limited	100.00%
			Partnership
Pearl Strategic Credit LP		Edinburgh²⁵	Limited	100.00%
			Partnership
SLIF Property Investment LP		Edinburgh⁷	Limited	100.00%
			Partnership
Janus Henderson Institutional Short Duration Bond Fund		London²⁶	Unit Trust	100.00%
Janus Henderson Institutional Mainstream UK Equity Trust		London²⁶	Unit Trust	100.00%
Janus Henderson Institutional UK Equity Tracker Trust		London²⁶	Unit Trust	100.00%
Janus Henderson Institutional High Alpha UK Equity Fund		London²⁶	Unit Trust	90.88%
Janus Henderson Global Funds – Janus Henderson		London²⁶	OEIC, sub fund	99.11%
Institutional Overseas Bond Fund
Janus Henderson Strategic Investment		London²⁶	OEIC, sub fund	81.07%
Funds – Janus Henderson Institutional North
American Index Opportunities Fund
Janus Henderson Strategic Investment Funds		London²⁶	OEIC, sub fund	95.50%
– Janus Henderson Institutional Asia Pacific
ex Japan Index Opportunities Fund
Janus Henderson Strategic Investment Funds – Janus		London²⁶	OEIC, sub fund	84.64%
Henderson Institutional Japan Index Opportunities Fund
PUTM ACS Asia Pacific ex Japan Fund		Birmingham¹	Unit Trust	99.98%
PUTM ACS Emerging Markets Fund		Birmingham¹	Unit Trust	100.00%
PUTM ACS European ex UK Fund		Birmingham¹	Unit Trust	89.01%
PUTM ACS European ex UK Fund 2		Birmingham¹	Unit Trust	100.00%
PUTM ACS Japan Equity Fund		Birmingham¹	Unit Trust	100.00%
PUTM ACS Lothian European Ex UK Fund		Birmingham¹	Unit Trust	100.00%
PUTM ACS Lothian North American Equity Fund		Birmingham¹	Unit Trust	100.00%
PUTM ACS Lothian UK Gilt Fund		Birmingham¹	Unit Trust	100.00%
PUTM ACS Lothian UK Listed Smaller Companies Fund		Birmingham¹	Unit Trust	99.99%
PUTM ACS North American Fund 2		Birmingham¹	Unit Trust	100.00%
PUTM ACS North American Fund		Birmingham¹	Unit Trust	100.00%
PUTM ACS Sustainable Index Asia		Birmingham¹	Unit Trust	100.00%
Pacific ex Japan Equity Fund
PUTM ACS Sustainable Index Emerging Markets Equity Fund		Birmingham¹	Unit Trust	100.00%
PUTM ACS Sustainable Index European Equity Fund		Birmingham¹	Unit Trust	100.00%
PUTM ACS Sustainable Index Japan Equity Fund		Birmingham¹	Unit Trust	100.00%
PUTM ACS Sustainable Index UK Equity Fund		Birmingham¹	Unit Trust	100.00%
PUTM ACS Sustainable Index US Equity Fund		Birmingham¹	Unit Trust	100.00%
PUTM ACS UK All Share Listed Equity Multi Manager Fund		Birmingham¹	Unit Trust	100.00%
PUTM ACS US Dollar Credit Fund		Birmingham¹	Unit Trust	100.00%
PUTM ACS Sustainable Index Global		Birmingham¹	UCITS, sub fund	100.00%
Short Duration Credit Fund
PUTM ACS Sustainable Index Global		Birmingham¹	UCITS, sub fund	100.00%
All Maturities Credit Fund
PUTM Bothwell Asia Pacific (Excluding Japan) Fund		Birmingham¹	Unit Trust	100.00%
PUTM Bothwell Emerging Market Debt Unconstrained Fund		Birmingham¹	Unit Trust	100.00%
PUTM Bothwell Emerging Markets Equity Fund		Birmingham¹	Unit Trust	100.00%
PUTM Bothwell Euro Sovereign Fund		Birmingham¹	Unit Trust	100.00%
PUTM Bothwell European Credit Fund		Birmingham¹	Unit Trust	100.00%
PUTM Bothwell Floating Rate ABS Fund		Birmingham¹	Unit Trust	100.00%
PUTM Bothwell Global Bond Fund		Birmingham¹	Unit Trust	100.00%

H. Interests in subsidiaries and associates continued

H5. Group entities continued

303Annual Report and Accounts 2025

Financials

Standard Life plc

		If unincorporated,	Type of investment
	Registered address of	address of principal	(including class of
	incorporated entities	place of business	shares held)	% of shares /units held
PUTM Bothwell Global Credit Fund		Birmingham¹	Unit Trust	100.00%
PUTM Bothwell Index-Linked Sterling Hedged Fund		Birmingham¹	Unit Trust	100.00%
PUTM Bothwell Long Gilt Sterling Hedged Fund		Birmingham¹	Unit Trust	100.00%
PUTM Bothwell Short Duration Credit Fund		Birmingham¹	Unit Trust	100.00%
PUTM Bothwell Sterling Credit Fund		Birmingham¹	Unit Trust	100.00%
PUTM Bothwell Sterling Government Bond Fund		Birmingham¹	Unit Trust	100.00%
PUTM Bothwell Sub-Sovereign Bond Fund		Birmingham¹	Unit Trust	100.00%
PUTM Bothwell Tactical Asset Allocation Fund		Birmingham¹	Unit Trust	100.00%
PUTM Bothwell UK Equity Income Fund		Birmingham¹	Unit Trust	100.00%
PUTM Bothwell Ultra Short Duration Fund		Birmingham¹	Unit Trust	100.00%
PUTM Far Eastern Unit Trust		Birmingham¹	Unit Trust	99.65%
PUTM UK All-Share Index Unit Trust		Birmingham¹	Unit Trust	100.00%
PUTM UK Stock Market Fund		Birmingham¹	Unit Trust	100.00%
PUTM UK Stock Market Fund (Series 3)		Birmingham¹	Unit Trust	100.00%
PUTM ACS Sterling Credit Fund		Birmingham¹	Unit Trust	100.00%
PUTM ACS North American Fund 3		Birmingham¹	Unit Trust	100.00%
iShares Bloomberg Roll Select Commodity Strategy ETF		Wilmington²⁷	OEIC, sub fund	65.02%
RGI Institutional UK Listed Smaller Companies Fund		London²⁸	UCITS, sub fund	97.30%
ESP Scotland Ltd Loan		Edinburgh²⁹	Limited	100.00%
			Partnership
Schroders (Future Growth Capital) UK Private Assets LTAF		London³⁰	OEIC, sub fund	100.00%
Schroders (Future Growth Capital)		London³⁰	OEIC, sub fund	100.00%
Global Private Assets LTAF
abrdn (Lothian) Pacific Basin Trust		London¹¹	Unit Trust	99.65%
abrdn Emerging Markets Income Equity Fund		London¹¹	OEIC, sub fund	72.84%
abrdn Europe Ex UK Ethical Equity Fund		London¹¹	OEIC, sub fund	82.00%
abrdn MyFolio Managed I Fund		London¹¹	OEIC, sub fund	77.30%
abrdn MyFolio Managed II Fund		London¹¹	OEIC, sub fund	76.93%
abrdn MyFolio Managed III Fund		London¹¹	OEIC, sub fund	82.47%
abrdn MyFolio Managed V Fund		London¹¹	OEIC, sub fund	76.54%
abrdn Standard Liquidity Fund (Lux) –		Luxembourg¹⁹	UCITS, sub fund	100.00%
Seabury Euro Liquidity 1 Fund
abrdn Standard Liquidity Fund (Lux) –		Luxembourg¹⁹	UCITS, sub fund	99.77%
Seabury Sterling Liquidity 2 Fund
abrdn Standard Liquidity Fund (Lux) –		Luxembourg¹⁹	UCITS, sub fund	96.88%
Seabury Sterling Liquidity 3 Fund
abrdn Sustainable Index World Equity Fund		London¹¹	Unit Trust	76.89%
abrdn Sustainable Index American Equity Fund		London¹¹	OEIC, sub fund	77.41%
abrdn UK Real Estate Fund		London¹¹	Unit Trust	92.40%
abrdn UK Real Estate Feeder Fund		London¹¹	Unit Trust	75.74%
abrdn Phoenix Fund Financing SCSP		Luxembourg¹⁹	Special Limited	100.00%
			Partnership
Patria Phoenix Global Private Equity III LP		Edinburgh⁹	Limited	100.00%
			Partnership
European Strategic Partners LP		Edinburgh⁷	Limited	72.70%
			Partnership
North American Strategic Partners 2008 L.P.		Edinburgh²⁹	Limited	100.00%
			Partnership
North American Strategic Partners		Edinburgh²⁹	Limited	100.00%
(Feeder) 2008 Limited Partnership			Partnership
Ignis Private Equity Fund LP		Cayman Islands¹⁰ Limited		100.00%
			Partnership
Ignis Strategic Credit Fund LP		Cayman Islands¹⁰ Limited		100.00%
			Partnership
Ignis Strategic Solutions Funds plc –		Dublin³¹	OEIC, sub fund	100.00%
Fundamental Strategies Fund

304 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

		If unincorporated,	Type of investment
	Registered address of	address of principal	(including class of
	incorporated entities	place of business	shares held)	% of shares /units held
Ignis Strategic Solutions Funds plc –		Dublin³¹	OEIC, sub fund	100.00%
Systematic Strategies Fund
ESP General Partner Limited Partnership		Edinburgh²⁹	Limited	100.00%
			Partnership
ESP II General Partner Limited Partnership		Edinburgh²⁹	Limited	100.00%
			Partnership
HSBC Investment Funds – Balanced Fund		London³²	OEIC, sub fund	78.21%
iShares 350 UK Equity Index Fund UK		London³³	OEIC, sub fund	95.95%
Legal & General European Equity Income Fund		London³⁴	Unit Trust	72.11%
Partners Group Phoenix, L.P. Inc.		Guernsey³⁵	Limited	100.00%
			Partnership
Quilter Investors Global Dynamic Equity Fund		London³⁶	OEIC, sub fund	83.39%
Euro Government Bond Fund		Luxembourg¹⁹	SICAV, sub fund	74.27%
Global Infrastructure Equity Fund		Luxembourg¹⁹	SICAV, sub fund	99.92%
Stonepeak Core Fund (Lux) SCSp		Luxembourg³⁷	Special Limited	83.30%
			Partnership
Associates:
Future Growth Capital (Holdings) Limited	London³⁸		OEIC, sub fund	49.90%
Future Growth Capital Limited	London³⁸		OEIC, sub fund	49.90%
Significant holdings:
Janus Henderson Institutional Global		London²⁶	OEIC, sub fund	29.19%
Responsible Managed Fund
Janus Henderson Institutional UK Index Opportunities Fund		London²⁶	OEIC, sub fund	55.26%
Janus Henderson All Stocks Credit Fund		London²⁶	OEIC, sub fund	24.87%
Janus Henderson Emerging Markets Opportunities Fund		London²⁶	OEIC, sub fund	24.73%
Henderson Diversified Growth		London²⁶	OEIC, sub fund	64.14%
abrdn SICAV II – Global Equity Impact Fund		Luxembourg¹⁹	SICAV, sub fund	81.67%
abrdn SICAV II – Global Inflation–		Luxembourg¹⁹	SICAV, sub fund	80.39%
linked Government Bond Fund
abrdn SICAV II – Global Short Duration Corporate Bond Fund		Luxembourg³⁹	SICAV, sub fund	62.60%
abrdn SICAV II Absolute Return Global Bond Strategies Fund		Luxembourg¹⁹	SICAV, sub fund	37.10%
abrdn SICAV II Emerging Market Local Currency Debt Fund		Luxembourg¹⁹	SICAV, sub fund	70.81%
abrdn SICAV II Global Real Estate		Luxembourg¹⁹	SICAV, sub fund	92.21%
Securities Sustainable Fund
abrdn Standard Liquidity Fund (Lux) Sterling Fund		Luxembourg¹⁹	UCITS, sub fund	20.46%
abrdn American Equity Enhanced Index Fund		London¹¹	OEIC, sub fund	37.90%
abrdn Asia Pacific Equity Enhanced Index Fund		London¹¹	OEIC, sub fund	35.34%
abrdn Dynamic Distribution Fund		London¹¹	Unit Trust	67.20%
abrdn Short Duration Global Inflation-Linked Bond Fund		London¹¹	OEIC, sub fund	21.22%
abrdn Ethical Corporate Bond Fund		London¹¹	OEIC, sub fund	50.33%
abrdn European Equity Enhanced Index Fund		London¹¹	OEIC, sub fund	49.06%
abrdn Global Inflation-Linked Bond Tracker Fund		London¹¹	OEIC, sub fund	53.03%
abrdn Global Real Estate Fund		London¹¹	Unit Trust	44.78%
abrdn Global Smaller Companies Fund		London¹¹	OEIC, sub fund	30.40%
abrdn High Yield Bond Fund		London¹¹	OEIC, sub fund	21.72%
abrdn MyFolio Managed IV Fund		London¹¹	OEIC, sub fund	62.88%
abrdn MyFolio Multi-Manager II Fund		London¹¹	OEIC, sub fund	21.20%
abrdn MyFolio Multi-Manager III Fund		London¹¹	OEIC, sub fund	29.47%
abrdn MyFolio Multi-Manager IV Fund		London¹¹	OEIC, sub fund	42.27%
abrdn Short Dated Corporate Bond Fund		London¹¹	OEIC, sub fund	33.19%

H. Interests in subsidiaries and associates continued

H5. Group entities continued

305Annual Report and Accounts 2025

Financials

Standard Life plc

		If unincorporated,	Type of investment
	Registered address of	address of principal	(including class of
	incorporated entities	place of business	shares held)	% of shares /units held
abrdn SICAV I – Global Corporate Sustainable Bond Fund		Luxembourg¹⁹	SICAV, sub fund	39.25%
abrdn SICAV I – Japanese Sustainable Equity Fund		Luxembourg¹⁹	SICAV, sub fund	25.27%
abrdn Standard SICAV I – China Onshore Bond Fund		Luxembourg¹⁹	SICAV, sub fund	81.51%
abrdn SICAV II European Corporate Bond Fund		Luxembourg¹⁹	SICAV, sub fund	32.09%
abrdn SICAV II European Smaller Companies Fund		Luxembourg¹⁹	SICAV, sub fund	27.41%
abrdn SICAV II Global Corporate Bond Fund		Luxembourg¹⁹	SICAV, sub fund	70.86%
abrdn SICAV II Global High Yield Bond Fund		Luxembourg¹⁹	SICAV, sub fund	49.30%
abrdn Liquidity Fund (Lux) – Euro Fund		Luxembourg¹⁹	UCITS, sub fund	37.28%
abrdn Sterling Corporate Bond Fund		London¹¹	OEIC, sub fund	45.49%
abrdn Strategic Bond Fund		London¹¹	OEIC, sub fund	68.78%
abrdn UK Equity Enhanced Index Fund		London¹¹	OEIC, sub fund	35.18%
abrdn UK Mid-Cap Equity Fund		London¹¹	OEIC, sub fund	40.38%
abrdn SICAV I – Europe Ex UK Sustainable Equity Fund		Luxembourg¹⁹	SICAV, sub fund	92.06%
abrdn SICAV I – GDP Weighted Global		Luxembourg¹⁹	SICAV, sub fund	78.54%
Government Bond Fund
abrdn SICAV I – Global Bond Fund		Luxembourg¹⁹	SICAV, sub fund	99.88%
abrdn SICAV I – Global Government Bond Fund		Luxembourg¹⁹	SICAV, sub fund	83.76%
abrdn Emerging Markets Local Currency Bond Tracker Fund		London¹¹	OEIC, sub fund	23.33%
abrdn Future Real Estate UCITS ETF		Dublin⁴⁰	UCITS, sub fund	30.46%
abrdn UK Sustainable Equity Fund		London¹¹	OEIC, sub fund	20.98%
abrdn MyFolio Index V Fund		London¹¹	OEIC, sub fund	44.51%
abrdn MyFolio Index III Fund		London¹¹	OEIC, sub fund	29.67%
abrdn MyFolio Index II Fund		London¹¹	OEIC, sub fund	34.38%
abrdn MyFolio Index I Fund		London¹¹	OEIC, sub fund	39.78%
abrdn MyFolio Index IV Fund		London¹¹	OEIC, sub fund	30.48%
abrdn Evolve UK Equity Index Fund		London¹¹	OEIC, sub fund	26.44%
Amundi Index Solutions – Amundi MSCI		Luxembourg⁴¹	SICAV, sub fund	37.71%
China ESG Leaders Select
Emerging Markets Smaller Companies Fund		Luxembourg¹⁹	OEIC, sub fund	26.60%
abrdn Liquidity Fund (Lux) – US Dollar Fund		Luxembourg¹⁹	SICAV, sub fund	32.97%
abrdn Global Infrastructure Equity Fund		London¹¹	OEIC, sub fund	37.89%
Responsible Global High Yield Bond Fund		Luxembourg¹⁹	SICAV, sub fund	26.93%
Gallions Reach Shopping Park Limited Partnership		London¹¹	Unit Trust	100.00%
Gallions Reach Shopping Park Unit Trust		Jersey⁴²	Unit Trust	100.00%
AB SICAV I – Diversified Yield Plus Portfolio		Luxembourg⁴³	SICAV, sub fund	60.01%
AB SICAV I – Emerging Markets Low		Luxembourg⁴³	SICAV, sub fund	65.35%
Volatility Equity Portfolio
ACS World Multifactor Equity Tracker Fund		London³³	OEIC, sub fund	25.97%
Amundi Index Solutions – Amundi Global Corp SRI 1–5Y		Luxembourg⁴¹	SICAV, sub fund	47.77%
Amundi Index Solutions – Amundi MSCI		Luxembourg⁴¹	SICAV, sub fund	31.85%
Emerging Ex China ESG Leaders Select
Global Multi-Factor Equity Fund		Paris⁴⁴	UCITS, sub fund	74.60%
AQR Global Risk Premium UCITS Fund		Luxembourg⁴⁵	UCITS, sub fund	97.34%
Baillie Gifford Emerging Markets Leading Companies Fund		Edinburgh⁴⁶	OEIC, sub fund	30.89%
Baillie Gifford Investment Funds II ICVC –		Edinburgh⁴⁶	OEIC, sub fund	29.73%
Baillie Gifford UK Equity Core Fund
Baillie Gifford UK & Balanced Funds ICVC – Baillie		Edinburgh⁴⁶	OEIC, sub fund	34.95%
Gifford UK and Worldwide Equity Fund
Barings Emerging Markets Debt Short Duration Fund		Dublin⁴⁰	OEIC, sub fund	38.93%
BlackRock Global Funds – Sustainable World Bond Fund		Luxembourg⁴³	SICAV, sub fund	25.64%
BlackRock Market Advantage Fund		London³³	UCITS, sub fund	50.86%
BNY Mellon Global Equity Fund		London⁴⁷	OEIC, sub fund	28.42%
BNY Mellon Multi-Asset Global Balanced Fund		London⁴⁷	UCITS, sub fund	31.92%

306 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

		If unincorporated,	Type of investment
	Registered address of	address of principal	(including class of
	incorporated entities	place of business	shares held)	% of shares /units held
Fidelity Multi Asset Open Adventurous Fund		Tadworth⁴⁸	OEIC, sub fund	35.84%
Goldman Sachs SICAV – Emerging Markets		Luxembourg⁴⁹	SICAV, sub fund	82.84%
Total Return Bond Portfolio
Goldman Sachs SICAV – Goldman Sachs		Luxembourg⁴⁹	SICAV, sub fund	27.71%
Emerging Markets Debt Portfolio
iShares Environment & Low Carbon		London³³	SICAV, sub fund	37.03%
Tilt Real Estate Index Fund
Threadneedle Investment Funds ICVC		London⁵⁰	OEIC, sub fund	22.11%
– CT American Select Fund
Baillie Gifford Japanese Income Growth Fund		Edinburgh⁵¹	OEIC, sub fund	20.49%
Blackrock ACS US Equity Tracker Fund		London³³	OEIC, sub fund	26.83%
Legal & General Mixed Investment 20-60% Fund		London³⁴	SICAV, sub fund	28.20%
Invesco Managed Growth Fund		Henley-on-	OEIC, sub fund	51.65%
		Thames⁵²
L&G Absolute Return Bond Plus Fund		Luxembourg⁵³	SICAV, sub fund	22.30%
L&G Emerging Markets Bond Fund		Luxembourg⁵³	SICAV, sub fund	70.66%
L&G Multi-Asset Target Return Fund		Luxembourg⁵³	SICAV, sub fund	41.98%
Legal & General Active Sterling Corporate Bond Fund		London³⁴	Unit Trust	27.60%
Legal & General Emerging Markets		London³⁴	Unit Trust	28.84%
Government Bond USD Index Fund
Legal & General High Income Trust		London³⁴	Unit Trust	41.13%
Legal & General UK Smaller Companies Trust		London³⁴	Unit Trust	30.43%
Quilter Investors Cirilium Balanced Blend Portfolio		London³⁶	OEIC, sub fund	35.57%
Quilter Investors Ethical Equity Fund		London³⁶	Unit Trust	34.86%
Quilter Investors Global Equity Growth Fund		London³⁶	OEIC, sub fund	56.56%
Robeco – Phoenix Customized Multi Asset Fund		Rotterdam⁵⁴	SICAV, sub fund	98.92%
Schroder International Selection Fund		Luxembourg⁵⁵	SICAV, sub fund	32.94%
– Global Diversified Growth
Schroder UK Mid 250 Fund		London³⁸	Unit Trust	24.78%
Schroder International Selection Fund Global Bond		Luxembourg⁵⁵	Unit Trust	23.63%
Robeco QI Emerging Markets Sustainable		Luxembourg⁵⁶	SICAV, sub fund	97. 87%
Enhanced Index Equities II
AB SICAV I – Sustainable All Market Portfolio		Luxembourg⁴³	SICAV, sub fund	34.36%
Vanguard Common Contractual Fund – Vanguard		Dublin⁴⁰	UCITS, sub fund	70.87%
U.S. Equity Index Common Contractual Fund
Vanguard Investment Series plc – Vanguard U.K.		Dublin⁴⁰	UCITS, sub fund	20.58%
Short-Term Investment Grade Bond Index Fund
Vanguard Investments Common Contractual		Dublin⁴⁰	UCITS, sub fund	95.34%
Fund – Vanguard FTSE Developed Europe
ex UK Common Contractual Fund
Vanguard Investments Common Contractual		Dublin⁴⁰	UCITS, sub fund	47.31%
Fund – Vanguard FTSE Developed World
Common Contractual Fund
Vanguard Investments Common Contractual		Dublin⁴⁰	UCITS, sub fund	96.38%
Fund – Vanguard FTSE Developed World
ex UK Common Contractual Fund

H. Interests in subsidiaries and associates continued

H5. Group entities continued

307Annual Report and Accounts 2025

Financials

Standard Life plc

1 10 Brindleyplace, Birmingham, B1 2JB, United Kingdom

2 90 St. Stephen’s Green, Dublin, D2, Ireland

3 Windsor House, Telford Centre, Telford, Shropshire, TF3 4NB, United Kingdom

4 Standard Life House, 30 Lothian Road, Edinburgh, EH1 2DH, United Kingdom

5 Goodbody Secretarial Limited, International Financial Services Centre, 25/28 North Wall Quay, Dublin 1, Ireland

6 Canon's Court, 22 Victoria Street, Hamilton, HM12, Bermuda

7 1 George Street, Edinburgh, EH2 2LL, United Kingdom

8 Corporation Service Company, 251 Little Falls Drive, Wilmington, DE 19808, United States

9 New Clarendon House, 114-116 George Street, Edinburgh, EH2 4LH, United Kingdom

10 Ugland House, Grand Cayman, KY1-1104, Cayman Islands

11 280 Bishopsgate, London, EC2M 4AG, United Kingdom

12 22-24 New Street, St Pauls Gate, 4th Floor, JE1 4TR, Jersey

13 20 Old Bailey, London, England, EC4M 7AN, United Kingdom

14 44 Esplanade, St Helier, Jersey, Channel Islands, JE4 9WG, Jersey

15 9 Par-la-Ville Road, 3rd Floor, Hamilton HM 11, Bermuda

16 Citco (Sweden) Ab, Stureplan 4c, 4 Tr, 114 35 Stockholm, Sweden

17 Boulevard Louis Schmidt 87, 1040 Bruxell, Belgium

18 Nybrogade 12, 1203 Copenhagen K, Denmark

19 35a Avenue J.F. Kennedy, L-1855, Luxembourg

20 162 Boulevard Haussmann, 75008 Paris, France

21 C/Pinar 7, 1st floor, 28006, Madrid, Spain

22 Bright Offices, Building A, La Guardiaweg 58, 1043 BW Amsterdam, The Netherlands

23 Matrix House, Basing View, Basingstoke, Hampshire, RG21 4DZ, United Kingdom

24 Highvista Strategies LLC, 200 Clarendon Street 50th Floor, Boston, Massachusetts, 02116, United States

25 New Clarendon House, 114-116 George Street, Edinburgh, EH2 4LH

26 201 Bishopsgate, London, EC2M 3AE, United Kingdom

27 Corporation Trust Centre, 1290 Orange Street, Wilmington, 19801, United States

28 30 Coleman Street, London,EC2R 5AL, United Kingdom

29 50 Lothian Road, Festival Square, Edinburgh, EH3 9WJ, United Kingdom

30 1 Wall Place, London, EC2Y 5AU, United Kingdom

31 32 Molesworth Street, Dublin 2, Dublin, D02 Y512, Ireland

32 8 Canada Square, London, E14 5HQ, United Kingdom

33 12 Throgmorton Avenue, London EC2N 2DL, United Kingdom

34 One Coleman Street, London, EC2R 5AA, United Kingdom

35 St. Peter Port, Tudor House, Le Bordage, GY1 6BD, Guernsey

36 Senator House, 85 Queen Victoria Street, London, EC4V 4AB, United Kingdom

37 20, rue de la Poste, Grand Duchy of Luxembourg, L-2346, Luxembourg

38 1 London Wall Place, London, EC2Y 5AU, United Kingdom

39 6, Route De Trèves, Senningerberg, 2633, Luxembourg

40 70 Sir John Rogerson’s Quay, Dublin 2, Ireland

41 5, Allée Scheffer, L-2520 Luxembourg, Luxembourg

42 Ogier House, The Esplanade, St Helier, JE4 9WG, Jersey

43 2-4, Rue Eugène Ruppert, L-2453 Luxembourg, Luxembourg

44 91 Boulevard Pasteur, 91 A 93, Paris, 75015, France

45 Hesperange, 33, rue de Gasperich, L-5826, Luxembourg

46 Calton Square, 1 Greenside Row, Edinburgh, EH1 3AN, United Kingdom

47 160 Queen Victoria Street, London, EC4V 4LA, United Kingdom

48 Beech Gate, Millfield Lane, Lower Kingswood, Tadworth, Surrey, KT20 6RP, United Kingdom

49 49, Avenue J.F. Kennedy, L-1855 Luxembourg, Grand Duchy of Luxembourg

50 Cannon Place, 78 Cannon Street, London, EC4N 6AG, United Kingdom

51 Calton Square, 1 Greenside Row, Edinburgh, EH1 3AN, United Kingdom

52 Perpetual Park, Perpetual Park Drive, Henley-on-Thames, Oxfordshire, RG9 1HH, United Kingdom

53 10, Château d’Eau, L-3364 Leudelange, Grand Duchy of Luxembourg

54 Weena 850, 3014 DA, Rotterdam, Netherlands

55 Senningerberg, 5, Hohenhof, L-1736, Luxembourg

56 Senningerberg, 6, Route De Trèves, L-2633, Luxembourg

308 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

The following subsidiaries have been granted an audit exemption by parental guarantee by virtue of s.479A of the Companies Act 2006:

• 103 Wardour Street Retail Investment Company Limited

• Barnwood Properties Limited

• Britannic Finance Limited

• Britannic Money Investment Services Limited

• G Assurance & Pension Services Limited

• G Life H Limited

• Pearl Customer Care Limited

• Pearl Group Holdings (No. 1) Limited

• Pearl Group Holdings (No. 2) Limited

• PGH CA Limited

• PGMS (Glasgow) Limited

• Phoenix Customer Care Limited

• Phoenix ER6 Limited

• Phoenix Group CA Services Limited

• Phoenix Life Assurance Limited

• Phoenix Life CA Holdings Limited

• Phoenix SL Direct Limited

• Phoenix SPV 1 Limited

• Phoenix SPV 2 Limited

• Phoenix SPV 3 Limited

• Phoenix SPV 4 Limited

• Phoenix Wealth Holdings Limited

• ReAssure Companies Services Limited

• ReAssure FSH UK Limited

• Standard Life Pension Funds Limited

• Vebnet (Holdings) Limited

The following subsidiaries were dissolved during the period. The subsidiaries were deconsolidated from the date of dissolution:

• Impala Loan Company 1 Limited

• Pearl (Martineau Phase 1) Limited

• Pearl (Martineau Phase 2) Limited

• Phoenix (Barwell 2) Limited

• Phoenix (Chiswick House) Limited

• Phoenix (Moor House 1) Limited

• Phoenix (Moor House 2) Limited

• Phoenix (Printworks) Limited

• Phoenix (Stockley Park) Limited

• SLACOM (No. 9) Limited

• SLACOM (No. 10) Limited

• Vebnet Limited

• Standard Life Agency Services Limited

• Phoenix Re Limited

• Phoenix Holdings (Bermuda) Limited

• PGL Pension Trustee Limited

• abrdn (Lothian) Japan Trust

• abrdn (Lothian) North American Trust

• abrdn (Lothian) International Trust

• abrdn (Lothian) UK Equity General Trust

• abrdn MT American Equity Unconstrained Fund

The following subsidiaries were either fully disposed of or the Group was no longer deemed to control the subsidiary. The

subsidiaries were deconsolidated from either the date of disposal or from the date when the Group was deemed to no longer control

the subsidiary:

• abrdn Short Dated Sterling Corporate Bond Tracker Fund

• abrdn Short Dated Global Corporate Bond Tracker Fund

The Group no longer has significant holdings in the following undertakings:

• abrdn Europe ex UK Equity Fund

• abrdn North American Small & Mid-Cap Equity Fund

• abrdn UK Income Equity Fund

• abrdn American Equity Fund

• abrdn Asia Pacific Equity Fund

• abrdn Emerging Markets Equity Fund

H. Interests in subsidiaries and associates continued

H5. Group entities continued

309Annual Report and Accounts 2025

Financials

Standard Life plc

• abrdn Japanese Equity Fund

• abrdn Europe ex UK Income Equity Fund

• abrdn UK Smaller Companies Fund

• abrdn MyFolio Market I Fund

• abrdn MyFolio Market II Fund

• abrdn MyFolio Market III Fund

• abrdn MyFolio Market IV Fund

• abrdn MyFolio Market V Fund

• abrdn MyFolio Multi-Manager V Fund

• abrdn Japan Equity Enhanced Index Fund

• abrdn European Equity Tracker Fund

• abrdn Emerging Markets Equity Tracker Fund

• abrdn Global Government Bond Tracker Fund

• abrdn UK Value Equity Fund

• abrdn Global Inflation-Linked Bond Fund

• abrdn Emerging Markets Equity Enhanced Index Fund

• abrdn SICAV I – Diversified Income Fund

• abrdn SICAV I – North American Smaller Companies Fund

• abrdn SICAV I – Short Dated Enhanced Income Fund

• LGIM Sterling Liquidity Plus Fund

• Schroder European Fund

• Vanguard Investment Series plc – Vanguard Global Short-Term Corporate Bond Index

• Vanguard Investment Series plc – Vanguard Global Corporate Bond Index Fund

• Legal & General Emerging Markets Government Bond (Local Currency) Index Fund

• BlackRock UK Absolute Alpha Fund

• BlackRock Cash Fund

• Ninety One Funds Series i Global Macro Allocation Fund

• Amundi UCITS Funds – Amundi Global Multi-Factor Equity Fund

• Standard Life Investments UK Shopping Centre Trust

• Standard Life Investments Brent Cross LP

• Brent Cross Partnership

I. Other notes

I1. Share-based payments

Equity-settled share-based payments to employees are measured at the fair value of the equity instruments at the grant date. The

fair value excludes the effect of non-market-based vesting conditions. Further details regarding the determination of the fair value

of equity-settled share-based transactions are set out below.

The fair value determined at the grant date of the equity-settled share-based payments is expensed on a straight-line basis over

the vesting period, based on the Group’s estimate of equity instruments that will eventually vest. At each period end, the Group

revises its estimate of the number of equity instruments expected to vest as a result of the effect of non-market-based vesting

conditions. The impact of the revision of the original estimates, if any, is recognised in the consolidated income statement such

that the cumulative expense reflects the revised estimate with a corresponding adjustment to equity.

I1.1 Share-based payment expense

The expense recognised for employee services receivable during the year is as follows:

	2025	2024
	£m	£m
Expense arising from equity-settled share-based payment transactions	26	26

I1.2 Share schemes

The Group operates two discretionary schemes, the Long Term Incentive Plan and the Deferred Bonus Share Scheme, and two

approved schemes, the ShareSave and Share Incentive Plan.

Long Term Incentive Plan (‘LTIP’)

The purpose of the LTIP is to motivate and incentivise delivery of sustained performance over the long-term in line with our strategy

and purpose, and to promote alignment with shareholders’ interests. The awards under this plan are in the form of nil-cost options

to acquire an allocated number of ordinary shares and are subject to performance conditions tied to the Group’s performance.

Dividend equivalent shares will accrue for LTIP awards over the three-year performance period and are awarded as additional options

prior to vesting. Further details of the performance conditions and vesting dates are included in the Directors’ Remuneration Report.

A holding period applies to members of the Executive Committee. Once performance vesting requirements are satisfied, awards will

not be released for a further two years from the third anniversary of the original award date. Dividend equivalent shares accrue on

LTIP awards until the end of the holding period. There are no cash settlement alternatives.

310 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

The fair value of these awards is estimated at the average share price in the three days preceding the date of grant, taking into account

the terms and conditions upon which the instruments were granted. The fair value of the LTIP awards is adjusted in respect of the Total

Shareholder Return (‘TSR’) performance condition which is deemed to be a ‘market condition’. The fair value of the 2023, 2024 and

2025 TSR elements of the LTIP awards has been calculated using a Monte Carlo model. The inputs to this model are shown below:

	2025	2024	2023
	TSR performance	TSR performance	TSR performance
	condition	condition	condition
Share price (p)	574	553	559
Expected life (years)	3	3	3
Expected volatility (%)	23	22	23
Risk-free interest rate (%)	4	4	3.3

Expected dividend yield (%) Dividends are received by holders of the

awards therefore no adjustment to fair

value is required

LTIP Buy-out awards were granted to certain senior management employees. There are discrete vesting periods for these awards

and are made on the condition that employees remain in employment with the Group for the vesting period. Similar awards were

also issued in prior periods.

Deferred Bonus Share Scheme (‘DBSS’)

Each year, under the rules of the Annual Incentive Plan (‘AIP’) a percentage of the cash payment is deferred into shares of the

Company. The requirement to defer is specifically linked to senior management and the Executive Committee. The vesting of these

shares is conditional on the employee remaining in employment with the Group for a period of three years from the date of grant.

Good leavers will be able to, at the discretion of the Remuneration Committee, exercise their full award at vesting. Dividend

equivalent shares will accrue for DBSS awards over the three-year deferral period and are awarded as additional options prior to

vest. Further details of each award are included in the Directors’ Remuneration Report.

The fair value of these awards is estimated at the average share price in the three days preceding the date of the grant, taking into

account the terms and conditions upon which the options were granted.

ShareSave scheme

ShareSave allows participating employees in the UK to save up to £500 each month for a period of three years, and up to 2024 for

five years. Under the ShareSave arrangement, participants remaining in the Group’s employment at the end of the three or five year

saving period are entitled to use their savings to purchase shares at a discounted price (‘exercise price’). The exercise price is

calculated using the three-day average price, discounted by 20% prior to the date of invitation. Employees leaving the Group for

certain reasons are able to use their savings to exercise and purchase a prorated number of shares if they leave prior to the end of

their three or five year period.

The fair value of the options has been determined using a Black-Scholes valuation model. Key assumptions within this valuation

model include expected share price volatility and expected dividend yield.

The following information was relevant in the determination of the fair value of the 2021 to 2025 UK ShareSave options:

	2025	2024	2023	2022	2021
	ShareSave	ShareSave	ShareSave	ShareSave	ShareSave
Share price (£)	6.84	4.91	4.44	6.14	7.48
Exercise price (£)	5.21	4.18	3.78	5.09	5.89
Expected life (years)	3.1	3.1 and 5.1	3.1 and 5.1	3.25 and 5.25	3.25 and 5.25
Risk-free rate (%) – based on UK	3.5	4.2 (for 3 year	4.7 (for 3 year	2.0 (for 3 year	0.5 (for 3 year
government gilts commensurate with		scheme) and 4.1	scheme) and 4.5	scheme) and 1.9	scheme) and 0.7
the expected term of the award		(for 5 year	(for 5 year	(for 5 year	(for 5 year
		scheme)	scheme)	scheme)	scheme)
Expected volatility (%) based on the Company’s share price volatility to date	23	22	23	30	30
Dividend yield (%)	8.0	10.9	11.5	8.0	6.3

Share Incentive Plan

The Group operates two Share Incentive Plans (‘SIP’) available to UK and Irish employees. Each plan allows participating employees

to purchase ‘Partnership shares’ in the Group through monthly contributions from salary. In respect of the UK SIP, employees can

contribute up to £150 per month or 10% of salary (whichever is lower). For each Partnership share awarded, the Group awards

Matching shares on a 1:1 basis up to a maximum of £50. Dividend payments are reinvested into further shares. The Irish SIP allows

employees to contribute up to €40 per month or 7.5% (whichever is lower). Matching shares are awarded on a 1.4 basis up to a

maximum of €40. Dividends are paid in cash under the Irish SIP.

I. Other notes continued

I1. Share-based payments continued

I1.2 Share schemes continued

311Annual Report and Accounts 2025

Financials

Standard Life plc

The fair value of the Matching shares granted is estimated as the share price at date of grant, taking into account terms and

conditions upon which the instruments were granted. At 31 December 2025, 537,491 Matching shares (excluding unrestricted shares)

were conditionally awarded to employees (2024: 611,207).

I1.3 Movements in the year

The following tables illustrate the number of, and movements in, LTIP, ShareSave and DBSS share options during the year:

		2025			2024
	Number of share options				Number of share options
	LTIP	ShareSave	DBSS	LTIP	ShareSave	DBSS
Outstanding at the beginning of the year	12,487,594	6,971,478	5,268,400	11,111,405	6,844,865	3,367,966
Granted during the year	3,722,792	829,571	2,498,000	4,595,364	1,426,648	2,525,215
Forfeited during the year	(2,844,558)	(461,117)	(179,838)	(2,270,979)	(176,532)	(33,470)
Cancelled during the year	–	(177,173)	–	(4,258)	(471,709)	–
Exercised during the year	(2,295,489)	(938,389)	(1,414,582)	(1,545,139)	(75,229)	(730,869)
Expired during the year	(617)	(179,105)	(2,018)	(33,884)	(576,565)	(11,753)
Dividends on vested awards	931,294	–	314,507	635,085	–	151,311
Outstanding at the end of the year	12,001,016	6,045,265	6,484,469	12,487,594	6,971,478	5,268,400

The weighted average fair value of options granted during the year was £4.25 (2024: £3.98).

The weighted average share price at the date of exercise for the rewards exercised is £6.19 (2024: £5.18).

The weighted average remaining contractual life for the awards outstanding as at 31 December 2025 is 4.5 years (2024: 5.0 years).

I2. Cash flows from operating activities

Operating cash flows include purchases and sales of investment property and financial investments as the purchases are funded from

cash flows associated with the origination of insurance and investment contracts, net of payments of related benefits and claims.

The following analysis gives further detail behind the ‘cash (utilised)/generated by operations’ figure in the statement of

consolidated cash flows.

Notes

		2025	2024
		£m	£m
Profit/(loss) for the year before tax		20	(1,107)
Adjustments for non-cash movements in profit/(loss) before tax for the year:
Loss on PGL Pension Scheme buy-out transaction	B1.1	–	100
Fair value (gains)/losses on:
Investment property	G4	(11)	100
Financial assets and derivative liabilities		(18,804)	(7,884)
Change in fair value of borrowings	E5.2	(39)	1
Amortisation and impairment of intangible assets	G2	240	273
Depreciation of property, plant and equipment	G3	17	21
Share-based payment charge	I1.1	26	26
Finance costs	C7	266	290
Net interest expense on Group defined benefit pension scheme liability/asset	G1	60	56
Other costs of pension schemes	G1	5	12
Movement in assets and liabilities relating to operations:
Increase in investment assets		(5,051)	(913)
(Increase)/decrease in reinsurers’ share of investment contract liabilities		(1,392)	342
Increase in reinsurance contract assets/liabilities		(593)	(305)
Decrease in assets classified as held for sale		3,067	1,475
Increase/(decrease) in insurance contract liabilities		3,839	(166)
Increase in investment contract liabilities		20,202	13,405
Decrease in obligation for repayment of collateral received		(9)	(156)
Decrease in liabilities classified as held for sale		(3,175)	(1,606)
Net decrease/(increase) in working capital		420	(406)
Other cash movements relating to operations:
Contributions to defined benefit pension schemes	G1	(8)	(9)
Cash (utilised)/generated by operations		(920)	3,549

312 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

I3. Capital management

The Group’s capital management is based on the principles of Solvency II, as modified by the PRA’s 2024 reforms (‘Solvency UK’).

This involves a valuation of the Group’s Own Funds and a risk-based assessment of the Group’s Solvency Capital Requirement

(‘SCR’) in line with Solvency UK rules.

This note sets out the Group’s approach to managing capital and provides an analysis of Own Funds and SCR.

Risk and capital management objectives

The risk management objectives and policies of the Group are based on the requirement to protect the Group’s regulatory capital

position, thereby safeguarding policyholders’ guaranteed benefits whilst also ensuring the Group can meet its various cash flow

requirements. Subject to this, the Group seeks to use available capital to achieve increased returns, balancing risk and reward, to

generate additional value for policyholders and shareholders.

In pursuing these objectives, the Group deploys financial and other assets and incurs insurance contract liabilities and financial and

other liabilities. Financial and other assets principally comprise investments in equity securities, debt securities, collective investment

schemes, property, derivatives, reinsurance, trade and other receivables, and banking deposits. Financial liabilities principally comprise

investment contracts, borrowings for financing purposes, derivative liabilities and net asset value attributable to unitholders.

The Group’s Risk Management Framework is described in the risk management commentary on pages 78 to 85 of the Annual Report

and Accounts and the Risk Universe component of this framework summarises the comprehensive set of risks to which the Group is

exposed. The major risks (‘Level 1’ risks) that the Group’s businesses are exposed to and the Group’s approach to managing those

risks are outlined in the following notes:

• note E6: Credit risk, market risk, financial soundness risk, strategic risk, customer risk and operational risk; and

• note F9: Insurance risk.

The sections on capital management objectives and the Group’s hedging strategy are included below.

Capital Management Framework

The Group’s Capital Management Framework is designed to achieve the following objectives:

• to provide appropriate security for policyholders and meet all regulatory capital requirements under the Solvency UK regime while

not retaining unnecessary excess capital, operating within a Solvency II Shareholder Capital Coverage ratio (‘SCCR’) of 140-180%;

• to ensure sufficient liquidity to meet obligations to policyholders and other creditors;

• to manage the leverage position, including optimisation of the Solvency II leverage ratio and the Fitch leverage ratio to maintain an

investment grade credit rating;

• to monitor IFRS and UK GAAP metrics to ensure that accounting outcomes do not constrain strategic or dividend decisions; and

• to maintain a dividend policy to pay an ordinary dividend that is progressive and sustainable.

The framework comprises a suite of capital management policies that govern the allocation of capital throughout the Group to

achieve the framework objectives under a range of stress conditions. The policy suite is defined with reference to policyholder

security, creditor obligations, owner dividend policy and regulatory capital requirements.

Group capital

Group capital is managed on a Solvency UK basis, under which the primary sources of capital managed by the Group comprise the

Group’s Own Funds as measured under Solvency UK rules adjusted to exclude surplus funds attributable to the Group’s unsupported

with-profits funds and unsupported pension schemes.

A Solvency UK capital assessment involves valuation in line with Solvency UK rules of the Group's Own Funds and a risk-based

assessment of the Group's Solvency Capital Requirement ('SCR'). Solvency II surplus is the excess of Own Funds over the SCR.

The Group aims to maintain a Solvency II surplus at least equal to its Board-approved capital policy, which reflects Board risk appetite

for meeting prevailing solvency requirements.

The capital policy of each Life Company is set and monitored by each Life Company Board. These policies ensure there is sufficient

capital within each Life Company to meet regulatory capital requirements under a range of stress conditions. The capital policy of

each Life Company varies according to the risk profile and financial strength of the company.

The capital policy of each Group Holding Company is designed to ensure that there is sufficient liquidity to meet creditor obligations

through the combination of cash buffers and cash flows from the Group’s operating companies.

Own Funds and SCR

Basic Own Funds represents the excess of assets over liabilities from the Solvency II balance sheet adjusted to add back any relevant

subordinated liabilities that meet the criteria to be treated as capital items.

The Basic Own Funds are classified into three Tiers based on permanency and loss absorbency (Tier 1 being the highest quality and

Tier 3 the lowest). The Group’s Own Funds are assessed for their eligibility to cover the Group SCR with reference to both the quality

of capital and its availability and transferability. Surplus funds in with-profits funds of the Life Companies and in the pension schemes

are restricted and can only be included in Eligible Own Funds up to the value of the SCR they are used to support.

I. Other notes continued

313Annual Report and Accounts 2025

Financials

Standard Life plc

Eligible Own Funds to cover the SCR are obtained after applying the prescribed Tiering limits and availability restrictions to the

Basic Own Funds.

The SCR is calibrated so that the likelihood of a loss exceeding the SCR is less than 0.5% over one year. This ensures that capital

is sufficient to withstand a broadly ‘1 in 200-year event’.

The Group operates one single PRA approved Internal Model covering all Group entities with the exception of Standard Life

International Designated Activity Company, the ReAssure entities and Phoenix Life CA entities, which determine their capital

requirements in accordance with the Standard Formula. Phoenix Life Assurance Europe Designated Activity Company was

deauthorised in May 2025 and was a Standard formula entity in the comparative period.

Hedging strategy

The Group operates a comprehensive hedging strategy designed to mitigate exposure to unrewarded market risks that could

otherwise introduce significant volatility into its Solvency II capital position. These risks primarily include interest rate, inflation,

equity and currency risks.

The objective of the hedging programme is not to eliminate all market risk, nor to manage short-term accounting outcomes, but

to stabilise the Solvency II surplus and the Group’s capacity to generate sustainable cash. This, in turn, underpins the Group’s ability

to meet policyholder obligations, maintain capital resilience through market cycles and support a progressive dividend policy.

The strategy is implemented using a combination of derivative instruments and asset-liability management techniques and is actively

managed to reflect changes in the Group’s balance sheet, risk profile and market conditions.

This hedging strategy has been in place for many years and represents a long-standing and fundamental element of the Group’s risk

and capital management framework. It has been consistently applied through different economic environments, including periods

of significant market stress and interest-rate volatility.

Over time, the strategy has demonstrated its effectiveness in reducing volatility in the Solvency II surplus and SCCR, thereby

supporting management’s ability to make long-term decisions on capital allocation, investment and dividends with a high degree

of confidence.

The hedging strategy has been effective in achieving its primary objective of protecting the Solvency UK balance sheet and cash

generation. However, due to differences between the Solvency UK and IFRS measurement frameworks, the strategy gives rise to

accounting volatility in the IFRS statement of comprehensive income. Hedge accounting under IFRS is not applied to these

hedging relationships.

Impact of the Group’s hedging strategy on IFRS results

Under Solvency UK, the valuation of the Group’s balance sheet includes the recognition of future profit margins, including those

arising from investment contracts. Under IFRS, these future margins are not recognised upfront in the balance sheet unless they are

captured at the time of an acquisition. Movements in the fair value of hedging instruments—designed to offset changes in the

economic value, reflected in Solvency UK, of those future margins—are recognised immediately in IFRS profit or loss, without a

corresponding offsetting movement in recognised assets or liabilities. This creates an accounting mismatch, which can result in

material volatility in IFRS profit and shareholders’ equity, particularly during periods of market movement.

In addition to the different treatment of future profit margins from investment contracts, there are further valuation differences

between IFRS and Solvency UK, including the requirement under Solvency UK to hold a SCR. As the hedges are ‘right-sized’ to

Solvency UK rather than IFRS, this results in volatility remaining under IFRS.

These outcomes are a known and expected consequence of the Group’s capital-focused hedging strategy and do not reflect a

deterioration in the underlying economics of the business.

The two market risks that the Group is most exposed to are equity risk and interest rate risk. The Group expects that the IFRS

volatility arising from the hedging strategy in respect of equity risk will reverse over time as the underlying profit margins on

investment contracts are realised and recognised in the IFRS consolidated income statement.

As services are provided to policyholders and profit margins emerge through charges, investment margins and CSM releases, the

cumulative IFRS impact of the hedging instruments (excluding costs of the hedging programme) is expected to be offset by the

recognition of profits that are already reflected in the Solvency UK balance sheet but deferred or unrecognised under IFRS.

The Board and management consider that the Group’s capital management framework, including its hedging strategy,

remains appropriate and effective. The Group continues to manage capital primarily on a Solvency UK basis, and IFRS shareholders’

equity is not considered a constraint on the Group’s ability to pay dividends or execute its strategy. The Board and management

review the appropriateness and effectiveness of the framework at least annually to ensure it is calibrated to market and Group-

specific developments.

Further information on the Group’s risk management framework, Solvency UK sensitivities and hedging activities is provided in the

Risk Management section, the Solvency UK disclosures and the Group’s Pillar 3 reporting.

314 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

Group capital resources – unaudited

The Group capital resources presented on a shareholder basis, are based on the Group’s Eligible Own Funds adjusted to remove

amounts pertaining to unsupported with-profits funds and Group pension schemes:

	2025	2024
Unaudited	£bn	£bn
Group's Eligible Own Funds	10.3	10.4
Remove Own Funds pertaining to unsupported with-profits funds and pension schemes	(2.0)	(2.0)
Group capital resources	8.3	8.4

Reconciliation between IFRS equity and estimated Eligible Own Funds under Solvency UK

A reconciliation summarising the key differences between total IFRS equity and the Group’s Eligible Own Funds under Solvency UK is

shown in the following table:

	2025	2024
	£bn	£bn
Total IFRS equity	1.3	2.2
Deduct non-controlling interests	(0.6)	(0.5)
Deduct goodwill, intangible assets and deferred acquisition costs	(1.7)	(1.9)
Revaluation of subordinated liabilities 1	0.1	0.2
Net impact of valuing technical provisions, net of reinsurance recoverables, on Solvency UK basis 1	12.7	11.6
Deferred tax impact of valuation differences 1	(1.5)	(1.1)
Other valuation differences 1	0.2	(0.1)
Excess of assets over liabilities under Solvency UK	10.5	10.4
Subordinated liabilities 1	2.9	3.3
Ring-fenced fund restrictions 1	(2.4)	(2.5)
Other availability restrictions 1	(0.7)	(0.8)
Group's eligible own funds	10.3	10.4

1 These balances are unaudited and reflect Solvency II adjustments.

Reconciliation between IFRS total comprehensive income and estimated Solvency II surplus

A reconciliation summarising the key differences between IFRS total comprehensive income and the Group’s estimated Solvency II

surplus is shown in the following table:

	2025	2024
	£bn	£bn
IFRS Total comprehensive expense	(0.4)	(1.0)
Dividends and coupon on Tier 1 Notes	(0.5)	(0.6)
Change in IFRS equity	(0.9)	(1.6)
Amortisation of acquired in-force intangibles	0.2	0.2
Valuation differences
Annuity new business profits 1	0.1	0.2
Investment contract value of in-force (Solvency UK basis) 1	1.1	0.8
Other 1	(0.1)	–
Deferred tax 1	(0.4)	(0.1)
Other valuation differences 1	0.2	0.1
Subordinated liabilities 1	(0.4)	(0.2)
Ring-fenced funds restrictions 1	0.1	(0.4)
Other availability restrictions 1	–	0.4
Change in Group's eligible own funds	(0.1)	(0.6)
Change in Solvency Capital Requirements 1	0.2	0.2
Solvency II surplus emergence	0.1	(0.4)

1 These balances are unaudited and reflect Solvency UK adjustments.

I. Other notes continued

I3. Capital management continued

315Annual Report and Accounts 2025

Financials

Standard Life plc

I4. Related party transactions

In the ordinary course of business, the Group and its subsidiaries carry out transactions with related parties as defined by IAS 24

Related Party Disclosures, which comprise Group pension schemes, an associate and key management personnel.

I4.1 Related party transactions

During the year, the Group entered into the following related party transactions with a Group pension scheme and an associate:

	Transactions	Transactions
	2025	2024
	£m	£m
Pearl Group Staff Pension Scheme:
Payment of administrative expenses	(6)	(5)
Future Growth Capital Holdings Limited:
Investment in associate	(10)	(5)

In addition to the above, in 2024 Phoenix Life Limited completed the buy-out of the PGL Pension Scheme liabilities. Further details

are included in note G1.6.

I4.2 Transactions with key management personnel

The total compensation of key management personnel, being those having authority and responsibility for planning, directing and

controlling the activities of the Group, including the Executive, Non-Executive Directors and members of the Group’s Executive

Committee is as follows:

	2025	2024
	£m	£m
Salary and other short-term benefits	19	17
Equity compensation plans	10	10

Details of the shareholdings and emoluments of individual Directors are provided in the Remuneration report on pages 136 to 175.

Key management personnel and their close family members may invest in pensions and savings products sold by the Group on

equivalent terms to those available to all employees of the Group. In the current and prior periods, transactions with key

management personnel were not deemed to be significant. These transactions include contributions paid into the Group’s Master

Trust pension scheme.

I5. Commitments

This note analyses the Group’s other commitments.

	2025	2024
	£m	£m
To subscribe to private equity funds and other unlisted assets	1,631	2,425
To purchase, construct or develop investment property and income strips	11	16
For repairs, maintenance or enhancements of investment property	15	22

I6. Contingent liabilities

Where the Group has a possible future obligation as a result of a past event, or a present legal or constructive obligation but it is

not probable that there will be an outflow of resources to settle the obligation or the amount cannot be reliably estimated, this

is disclosed as a contingent liability.

Legal proceedings

Where the Group has a possible future obligation as a result of a past event, or a present legal or constructive obligation but it is not

probable that there will be an outflow of resources to settle the obligation or the amount cannot be reliably estimated, this is

disclosed as a contingent liability.

As a long-term savings and retirement business, the Group operates in a highly regulated environment. Therefore, in the normal

course of business the Group is exposed to certain legal issues, which can involve litigation and arbitration, complaints, and

regulatory and tax authority reviews. At 31 December 2025, the Group has a number of contingent liabilities in this regard, none

of which are considered by the Directors to be material.

316 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the consolidated financial statements continued

I7. Events after the reporting period

The financial statements are adjusted to reflect significant events that have a material effect on the financial results and that have

occurred between the period end and the date when the financial statements are authorised for issue, provided they give evidence

of conditions that existed at the period end. Events that are indicative of conditions that arise after the period end that do not

result in an adjustment to the financial statements are disclosed.

On 13 March 2026, the Board recommended a final dividend of 28.05p per share for the year ended 31 December 2025 (2024:

27.35p). Payment of the final dividend is subject to shareholder approval at the AGM. The cost of this dividend has not been

recognised as a liability in the consolidated financial statements for 2025 and will be charged to the statement of consolidated

changes in equity in 2026.

Sir Nicholas Lyons

Andy Briggs

Nicolaos Nicandrou

Eleanor Bucks

Siobhan Boylan

Karin Cook

Sherry Coutu, CBE

Karen Green

Mark Gregory

Hiroyuki Iioka

Katie Murray

Margaret Semple, OBE

13 March 2026

I. Other notes continued

317Annual Report and Accounts 2025

Financials

Standard Life plc

Parent company financial statements

2025 2024

Notes £m £m

ASSETS

Property, plant and equipment 3 14 15

Investments in Group entities 4 9,199 9,247

Financial assets

Loans and deposits 5 1,444 1,398

Derivatives 7 51 112

Debt securities 6 3 1

Collective investment schemes 6 816 1,095

Deferred tax 8 336 309

Prepayments and accrued income 43 47

Other amounts due from Group entities 19 156 105

Cash and cash equivalents – 1

Total assets 12,062 12,330

EQUITY AND LIABILITIES

Equity attributable to ordinary shareholders

Share capital 9 101 100

Share premium 9 20 16

Merger relief reserve 9 593 593

Other reserve 9 (4) (4)

Retained earnings

At 1 January 5,571 4,632

Profit for the year 9 780 249

Other movements in retained earnings (551) 690

Total retained earnings 5,800 5,571

Total equity attributable to ordinary shareholders 6,510 6,276

Tier 1 Notes 10 411 411

Total equity 6,921 6,687

Liabilities

Financial liabilities

Borrowings 11 4,557 4,926

Derivatives 7 18 4

Obligations for repayment of collateral received 7 33 37

Other amounts due to Group entities 19 299 341

Provisions 12 110 207

Lease liabilities 13 15 16

Accruals and deferred income 14 109 112

Total liabilities 5,141 5,643

Total equity and liabilities 12,062 12,330

The notes identified numerically on pages 320 to 329 are an integral part of these separate financial statements. Where items also

appear in the consolidated financial statements, reference is made to the notes (identified alphanumerically) on pages 206 to 316.

Approved by the Board on 13 March 2026.

Andy Briggs Nicolaos Nicandrou

Chief Executive Officer Chief Financial Officer

Company registration number 11606773.

Statement of financial position

As at 31 December 2025

318 Annual Report and Accounts 2025

Financials

Standard Life plc

capital

(note 9)

premium

(note 9)

Merger

relief

reserve

(note 9)

Other

reserve

(note 9)

Retained

earnings Total

Tier 1 Notes

(note 10)

Total

equity

£m £m £m £m £m £m £m £m

At 1 January 2025 100 16 593 (4) 5,571 6,276 411 6,687

Total comprehensive income for

the year attributable to owners – – – – 780 780 – 780

Issue of ordinary share capital, net of

associated commissions and expenses 1 4 – – – 5 – 5

Dividends paid on ordinary

shares (note B4) – – – – (548) (548) – (548)

Coupon paid on Tier 1 Notes – – – – (29) (29) – (29)

Credit to equity for equity-settled

share-based payments (note I1) – – – – 26 26 – 26

At 31 December 2025 101 20 593 (4) 5,800 6,510 411 6,921

For the year ended 31 December 2024

capital (note

premium

(note 9)

Merger

relief

reserve

(note 9)

Other

reserve

(note 9)

Retained

earnings Total

Tier 1 Notes

(note 10)

Total

equity

£m £m £m £m £m £m £m £m

At 1 January 2024 100 16 1,819 (4) 4,632 6,563 411 6,974

Total comprehensive income for

the year attributable to owners – – – – 249 249 – 249

Dividends paid on ordinary

shares (note B4) – – – – (533) (533) – (533)

Coupon paid on Tier 1 Notes – – – – (29) (29) – (29)

Credit to equity for equity-settled

share-based payments (note I1) – – – – 26 26 – 26

Transfer of merger reserve – – (1,226) – 1,226 – – –

At 31 December 2024 100 16 593 (4) 5,571 6,276 411 6,687

Statement of changes in equity

For the year ended 31 December 2025

319Annual Report and Accounts 2025

Financials

Standard Life plc

Notes

2025 2024

£m £m

Cash flows from operating activities

Cash utilised by operations 15 (212) (312)

Net cash flows from operating activities (212) (312)

Cash flows from investing activities

Loan and deposit advances to Group entities (47) (63)

Dividends received from Group entities 556 1,032

Interest received from Group entities 166 188

Net return of capital from subsidiaries 15 –

Derivative settlements 10 62

Net cash flows from investing activities 700 1,219

Cash flows from financing activities

Proceeds from issuing ordinary shares 5 –

Proceeds from new shareholder borrowings, net of associated expenses 11 1,162 1,579

Repayment of shareholder borrowings 11 (797) (1,621)

Ordinary share dividends paid 16 (548) (533)

Interest paid on borrowings (281) (301)

Lease payments 13 (1) (2)

Coupon paid on Tier 1 Notes 16 (29) (29)

Net cash flows from financing activities (489) (907)

Net decrease in cash and cash equivalents (1) –

Cash and cash equivalents at the beginning of the year 1 1

Cash and cash equivalents at the end of the year – 1

Statement of cash flows

For the year ended 31 December 2025

320 Annual Report and Accounts 2025

Financials

Standard Life plc

1. Accounting policies

(a) Basis of preparation

On 24 February 2026 the Company changed its name to Standard Life plc (formerly Phoenix Group Holdings plc).

The financial statements have been prepared on a going concern basis and under the historical cost convention, except for those

financial assets and financial liabilities (including derivative instruments) that have been measured at fair value.

The Company has taken advantage of the exemption in section 408 of the Companies Act 2006 not to present its own income

statement in these financial statements. Total comprehensive income for the year attributable to owners was £780 million (2024:

£249 million).

Statement of Compliance

The Company’s financial statements have been prepared in accordance with UK-adopted international accounting standards

asapplied in accordance with section 408 of the Companies Act 2006.

The financial statements are presented in sterling (£) rounded to the nearest million except where otherwise stated.

Assets and liabilities are offset and the net amount reported in the statement of financial position only when there is a legally

enforceable right to offset the recognised amounts and there is an intention to settle on a net basis, or to realise the assets and

settle the liability simultaneously.

(b) Accounting policies

Where applicable, the accounting policies in the separate financial statements are the same as those presented in the consolidated

financial statements on pages 206 to 316 with the exception of the one policy whereby the Company has not adopted the Group’s

policy of hedge accounting.

Where an accounting policy can be directly attributed to a specific note to the consolidated financial statements, the policy is

presented within that note. Each note within the Company financial statements makes reference to the note to the consolidated

financial statements containing the applicable accounting policy. The accounting policy in relation to foreign currency transactions

isincluded within note A3 to the consolidated financial statements.

Investments in Group entities

Investments in Group entities are carried in the statement of financial position at cost less impairment.

The Company assesses at each reporting date whether an investment is impaired by assessing whether any indicators of impairment

exist. If objective evidence of impairment exists, the Company calculates the amount of impairment as the difference between the

recoverable amount of the Group entity and its carrying value and recognises the amount as an expense in the income statement.

The recoverable amount is determined based on the cash flow projections of the underlying entities.

Critical accounting estimates are those which involve the most complex or subjective judgements or assessments. The area of the

Company’s business that typically requires such estimates and judgement is the impairment assessment for investments in Group entities.

Impairment of investments in Group entities

The Company conducts impairment reviews of investments in subsidiaries whenever events or changes in circumstances indicate

that their carrying amounts may not be recoverable. Determining whether an asset is impaired requires an estimation of the

recoverable amount, which requires the Company to estimate the value in use. The value in use is based on projections of future cash

flows and a suitable discount rate in order to calculate the present value. Where the actual future cash flows are less than expected,

an impairment loss may arise. Further details are included in note 4.

2. Financial information

New accounting pronouncements not yet effective

IFRS 18 Presentation and Disclosure in Financial Statements(1 January 2027)

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

make consequential amendments to other standards, including the cash flow statement. IFRS 18 introduces new requirements that

will help to achieve comparability of the financial performance of similar entities and provide more relevant information and

transparency to users, including classification of all income and expenses within the statement of financial performance into one of

five new categories, new specified totals and sub-totals in the statement of financial performance and requirements for the

identification and disclosure of Management-defined Performance Measures (‘MPM’) within the financial statements. It will

notimpactthe recognition or measurement of items in the financial statements.

IFRS 18 is not expected to have a significant impact on the Company’s financial statements, largely as a result of the Company not

being required to present a statement of financial performance.

Details of the other standards, interpretations and amendments to be adopted in future periods are detailed in note A5 to the

consolidated financial statements, none of which are expected to have a significant impact on the Company’s financial statements.

Notes to the parent company financial statements

321Annual Report and Accounts 2025

Financials

Standard Life plc

3. Property, plant and equipment

The accounting policy for property, plant and equipment is included in note G3 to the consolidated financial statements.

Property, plant and equipment with a carrying value of £14 million (2024: £15 million) includes the right-of-use asset relating to office

premises leased at 20 Old Bailey, London. Depreciation is being charged on a straight-line basis over the term of the lease and the

charge was £1 million in the year (2024: £2 million).

4. Investments in Group entities

2025 2024

£m £m

Cost

At 1 January 14,725 14,725

Net return of capital (15) –

At 31 December 14,710 14,725

Impairment

At 1 January (5,478) (4,189)

Charge for the year (33) (1,289)

At 31 December (5,511) (5,478)

Carrying amount

At 31 December 9,199 9,247

The in year movement in cost represents proceeds received on liquidation of subsidiaries by Phoenix Group Holdings (Bermuda)

Limited and the onward distribution of these proceeds to the Company as a return of capital.

Asat31 December 2025 and 31 December 2024, theGroup’s net asset value continued to belower than theCompany’snet asset

value. Thiswas considered to bean indicator that the Company’s investments in its subsidiaries maybeimpaired.Accordingly, an

impairment test has been performed to assess the recoverable amount of each investment against carrying value.

The recoverable amount of each subsidiary is based on its value in use. The value in use of the life insurance subsidiaries has been

calculated based onthe net present value of futureprojecteddividendsexpected to beappropriated bythese entities;

usingprojections set out in the Group’sBoard approved business plandiscounted to present value. These dividend projections

reflect the emergence of surplus from in-force business on a Solvency II basis, together with the impact of planned management

actions and anyanticipatednew business. The contribution to value in use of the non-life entities, which do not generate revenues

external to the Group, was based on their Solvency II Own Funds as at the balance sheet date. The value in use calculation has used a

discount rate of8.5% (2024:9.2%), calculated using arisk adjustedweighted average cost of capital approach.

For Phoenix Life Holdings Limited (‘PLHL’), which includes the vast majority of the Group’s new business franchise, an assumption for

the terminal rate of growth after theinitialfive-year business plan period was set at2%(2024: 2%).For all other subsidiaries of the

Company, whichpredominantly compriseclosed-book life insurance businesses, ten-year cash flow projections were utilised with a

value at the ten-year point determined with reference to projected Solvency II shareholder Own Funds.

At31 December2025,anaggregate impairment charge of£33millionwasrecognised. £19 million of this charge related to the

impairment of the Company’s investment in Phoenix Group Holdings (Bermuda) Limited and Phoenix Group Holdings(Cayman)

Limited.Both of these entities are dormant and have minimal residual capital.The remaining charge of £14 million is related to the

Company’s investment inPhoenix Life CA Holdings Limited (‘PLCAH’) andis consistent with the continued run-off of the underlying

closed book of business within this entity.

The value in use calculationis sensitive tothe discount rate,terminalvalueand cash flow assumptions adopted. Specific sensitivities

relevant to each investment are shown below.

• For PLHL, a 1% increase in the discount rate would reduce the recoverable amountof the Company’s investmentby £1,557

millionanda0.5% decrease in the terminalvaluegrowth rate would reduce the recoverable amount by£653 million. Neither

sensitivitywould have resulted in any impairment being recognised.

• For ReAssure Group Limited (formerly ReAssure Group plc), a 1% increase in the discount rate would decrease the value in useby

£68 million. In addition, sensitising the future cash flows by reducing the annual dividend projections by 10% for each year in the

forecast period would decrease the value in use by £148 million. Neither sensitivity would have resulted in anyimpairment being

recognised.

• For Standard Life International Designated Activity Company (‘SLIDAC’), a 1% increase in the discount rate would have decreased

the value in useand resulted in a£2 million impairment charge.

• For PLCAH, a 1% increase in the discount rate wouldhavedecreasedthe value in use and increasedthe impairment recognised bya

further£11million.

Fora list of principal Group entities, refer to note H5 of theconsolidatedfinancial statements in which the entities directly held by

the Company are separatelyidentified.

322 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the parent company financial statements continued

5. Loans and deposits

Carrying value Fair value

2025 2024 2025 2024

£m £m £m £m

Loans due from Phoenix Life Holdings Limited (note a) 1,335 1,327 1,350 1,349

Cash-pooling to other Group entities (note b) 85 53 85 53

Loan due from Phoenix Group Employee Benefit Trust (note c) 14 18 14 18

Loans and deposits due from Group entities 1,434 1,398 1,449 1,420

Cash on deposit 10 – 10 –

Total loans and deposits 1,444 1,398 1,459 1,420

Amounts due after 12 months 1,349 915

The loans and deposit balances due from Group entities are measured at amortised cost using the effective interest method.

(inaccordance with the accounting policy in note E1 to the consolidated financial statements). The fair value of these loans

anddeposits are also disclosed. None of the loans are considered to be overdue.

a On 12 December 2018, the Company assigned a £428 million subordinated loan to PLHL. The loan accrued interest at a rate of

6.675% and matured on 18 December 2025. This loan was initially recognised at fair value of £439 million and was amortised to

parover the period to maturity. On maturity the amount due was converted under a new loan to PLHL, with interest accruing

atacompounded rate of SONIA plus a margin of 1.17% being capitalised. During the year £1 million of interest was capitalised.

Thenew loan matures on 18 December 2030. At 31 December 2025, the carrying value of the loan was £429 million (2024:

£430million).

On 12 December 2018, the Company assigned a£450 million subordinated loan to PLHL. The loan accrues interest at a rate of

4.158% and matured on 20 July 2022. On 20 July 2022, the amount due on the maturity of the subordinated loan of £450 million

was advanced under a new loan to PLHL. The new loan accrues interest at a compounded rate of SONIA plus a margin of 1.30%

andis capitalised. During the year interest of £29 million (2024: £32 million) was capitalised. The loan matures on 31 December

2027. At 31 December 2025, the carrying value of the loan was £545 million (2024: £516 million).

On 12 December 2018, the Company assigned a US$500 million loan to PLHL due to mature in 2027 with a coupon of5.375%. This

loan was initially recognised at fair value of £349 million and is accreted to par over the period to 2027. At 31 December 2025, the

carrying value of the loan was £361 million (2024: £381 million).

b On 13 September 2022, the Company entered into an uncommitted intra-group cash-pooling facility with certain subsidiaries,

under which the Company will either borrow funds from, or lend funds to, the relevant subsidiary. All amounts due under the

facility attract interest at SONIA and are repayable on demand.

c On 18 June 2019, the Company was assigned an interest free facility arrangement with Phoenix Group Employee Benefit Trust

(‘EBT’). As at 31 December 2025, the carrying value of the loan was £14 million (2024: £18 million). The loan is fully recoverable

untilthe awards held in the EBT vest to the participants, at which point the loan is reviewed for impairment. Any impairments

aredetermined by comparing the carrying value to the estimated recoverable amount of the loan. During the year funding of

£9million (2024: £16 million) was provided to the EBT and £13 million of the loan was impaired (2024: £11 million).

For the purposes of the additional fair value disclosures for assets recognised at amortised cost, all loans and deposits are

categorised as Level 3 financial instruments. The fair value of loans and deposits with no external market is determined by internally

developed discounted cash flow models using a risk adjusted discount rate corroborated with external market data where possible.

Details of the factors considered in determination of fair value are included in note E2 to the consolidated financial statements.

6. Financial assets at fair value through profit or loss

2025 2024

£m £m

Financial assets at fair value through profit or loss

Derivatives (see note 7) 51 112

Debt securities 3 1

Collective investment schemes 816 1,095

870 1,208

Amounts due after 12 months 3 1

323Annual Report and Accounts 2025

Financials

Standard Life plc

Determination of fair value and fair value hierarchy of financial assets

The accounting policy for Financial Assets is provided in note E1 to the consolidated financial statements. Details of the factors

considered in determination of the fair value are included in note E2 to the consolidated financial statements.

Level 1 Level 2 Level 3 Total

2025 £m £m £m £m

Financial assets at fair value through profit or loss

Derivatives – 51 – 51

Debt securities – – 3 3

Collective investment schemes 816 – – 816

816 51 3 870

Level 1 Level 2 Level 3 Total

2024 £m £m £m £m

Financial assets at fair value through profit or loss

Derivatives – 112 – 112

Debt securities – – 1 1

Collective investment schemes 1,095 – – 1,095

1,095 112 1 1,208

There were no transfers between levels in either 2025 or 2024.

7. Derivatives

The accounting policy for derivatives is included in note E3 to the consolidated financial statements.

The Company has in place a number of cross currency swaps in order to hedge against adverse currency movements in respect of its

Euro and US Dollar denominated borrowings.

The Company also hedged certain Euro and, US Dollar exposures to adverse foreign currency movements in respect of underlying

business within its subsidiaries.

The fair value of the derivative financial instruments is as follows:

Asset Liability

2025 2024 2025 2024

£m £m £m £m

Cross currency swaps 36 106 – –

Foreign currency swaps 15 6 18 4

51 112 18 4

All derivative liabilities are categorised as Level 2 financial instruments.

Derivative collateral arrangements

The accounting policy for collateral arrangements is included in note E4 to the consolidated financial statements.

Assets accepted

The maximum exposure to credit risk in respect of third party over-the-counter (‘OTC’) derivative assets is £36 million (2024: £112

million) of which £33 million (2024: £37 million) is mitigated by use of cash collateral arrangements (which are settled net after taking

account of any OTC derivative liabilities owed by the counterparty).

Assets pledged

The Company has not pledged any collateral in respect of its OTC derivative liabilities.

324 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the parent company financial statements continued

8. Deferred tax

The accounting policy for tax assets and liabilities is included in note G8 to the consolidated financial statements.

Movement in deferred tax balances

1 January 2025

Recognised in

comprehensive

income

31 December

2025

£m £m £m

Provisions and other temporary differences 17 (10) 7

Trading losses 292 37 329

309 27 336

1 January 2024

Recognised in

comprehensive

income

31 December

2024

£m £m £m

Provisions and other temporary differences 25 (8) 17

Trading losses 160 132 292

185 124 309

The standard rate of UK corporation tax for the accounting period is 25% (2024: 25%).

9. Share capital, share premium, merger relief and other reserves

2025 2024

£m £m

Issued and fully paid:

1,006.3 million ordinary shares of £0.10 each (2024: 1,003.1 million) 101 100

2025 2025 2024 2024

Number £ Number £

Shares in issue at 1 January 1,003,111,838 100,311,183 1,001,538,419 100,153,841

Ordinary shares issued in the year 3,140,405 314,041 1,573,419 157,342

Shares in issue at 31 December 1,006,252,243 100,625,224 1,003,111,838 100,311,183

During the year, the Company issued 3,140,405 shares (2024: 1,573,419 shares) with a total share premium of £4 million (2024: £nil)

inorder to satisfy its obligations to employees under the Group’s share schemes. This included 2,200,000 shares (2024: 1,500,000

shares) that were issued to the Group’s Employee Benefit Trust at nominal value.

As outlined in the accounting policy note D3 in the consolidated financial statements the Company has applied the relief in section

612 of the Companies Act 2006 to present the difference between the value of the shares issued as consideration on acquisition

ofthe share capital of ReAssure Group Limited (formerly ReAssure Group plc) and the nominal value of the shares issued of

£1,819million in a merger reserve as opposed to in share premium. During 2024 £1,226 million of the reserve was transferred to

retained earnings following an impairment of the Company’s investment in the ReAssure group of companies as a result of the

distribution ofdividends to the Company.

On 12 December 2018, the Company became the ultimate parent undertaking of the Group by acquiring the entire share capital of

‘Old PGH’ (the Group’s ultimate parent company until December 2018) via a share for share exchange. The cost of investment in Old

PGH was determined as the carrying amount of the Company’s share of the equity of Old PGH on the date of the transaction. The

difference between the cost of investment and the market capitalisation of Old PGH immediately before the share for share

exchange of £4 million has been recognised as an Other reserve and is shown as a separate component of equity.

Profit for the year, included within retained earnings, primarily includes dividend income from subsidiaries of £1,326 million

(2024:£2,070 million), other net investment income of £92 million (2024: £240 million), administrative expenses of £471 million

(2024:£571 million), impairment of subsidiaries £33 million (2024: £1,289 million), impairment of loan to subsidiaries £13 million

(2024: £11 million), finance costs of £296 million (2024: £380 million) and a tax credit of £175 million (2024: £190 million).

10. Tier 1 notes

The accounting policy and details of the terms for the Tier 1 Notes are included in note D4 to the consolidated financial statements.

2025 2024

£m £m

Tier 1 Notes 411 411

On 12 December 2018, the Company was substituted in place of Old PGH as issuer of the Tier 1 Notes and these were recognised at

the fair value of £411 million in the form of an intragroup loan which was received as consideration. Further details of the tier 1 Notes

are included in note D4 to the consolidated financial statements.

325Annual Report and Accounts 2025

Financials

Standard Life plc

11. Borrowings

The accounting policy for borrowings is included in note E5 to the consolidated financial statements.

Carrying value Fair value

2025 2024 2025 2024

£m £m £m £m

Loans due to third-parties

£428 million Tier 2 notes – 197 – 199

US $500 million Tier 2 notes 361 381 376 399

€500 million Tier 2 notes 421 394 456 423

US $750 million Perpetual Contingent Convertible Tier 1 notes – 199 – 200

£500 million 5.625% Tier 2 notes 492 490 506 485

US $500 million Fixed Rate Reset Callable Tier 2 notes 259 279 260 275

£500 million 5.867% Tier 2 notes 523 529 516 500

£250 million Tier 3 notes 251 252 250 246

£350 million Fixed Rate Reset Callable Tier 2 notes 348 347 385 367

US $500 million Perpetual Contingent Convertible Tier 1 notes 371 398 398 415

3,026 3,466 3,147 3,509

Loans due to Group companies:

€100 million loan due to Standard Life International DAC (note a) 99 90 99 90

£130 million loan due to ReAssure Life Limited (note b) 103 98 103 98

€50 million loan due to Standard Life International DAC (note c) 47 44 47 44

£230 million loan due to ReAssure Limited (note d) 231 – 231 –

Cash-pooling with other Group entities (note e) 1,051 1,228 1,051 1,228

1,531 1,460 1,531 1,460

Total borrowings 4,557 4,926 4,678 4,969

Amount due for settlement after 12 months 3,255 3,457

1 Details of the principal features of loans due to third parties are included in note E5 to the consolidated financial statements.

a On 20 December 2022, SLIDAC issued a €100 million floating term loan to the Company with a maturity date of 30 June 2028.

Interest accrues on the term loan at a rate of EURIBOR, as defined in the agreement, plus 1.15%. As at 31 December 2025, the

interest rate was 3.26%.

b On 16 December 2022, ReAssure Life Limited (‘RLL’) issued a £130 million floating term loan to the Company for a term of 5 years.

Interest accrued on the term loan at a compounded rate of SONIA, as defined in the agreement, plus 1.49%. As at 31 December

2025, the interest rate was 5.56%.

c On 15 June 2023, SLIDAC issued a €50 million floating term loan to the Company with a maturity date of 31 March 2025. Interest

accrued on the term loan at a rate of EURIBOR, as defined in the agreement, plus 0.79%. This was re-termed during the period

with a revised maturity date of 30 June 2028 and interest accruing at a rate of EURIBOR, as defined in the agreement, plus 0.85%.

As at 31 December 2025, the interest rate was 3.16%.

d On 25 November 2025, ReAssure Limited (‘RAL’) issued a £230 million floating term loan to the Company with a maturity date of

24 November 2030. Interest accrues on the term loan at a compounded rate of SONIA, as defined in the agreement, plus 1.17%.

Asat 31 December 2025, the interest rate was 5.03%.

e On 13 September 2022, the Company entered into an uncommitted intra-group cash-pooling facility with certain subsidiaries,

under which the Company will either borrow funds from, or lend funds to, the relevant subsidiary. All amounts due under the

facility attract interest at SONIA and are repayable on demand.

The Group has in place a £1.5 billion unsecured revolving credit facility (the ‘revolving facility’). During the year the maturity date was

extended from November 2029 to November 2030. This facility remains undrawn as at 31 December 2025.

Borrowings initially recognised at fair value are being amortised to par value over the life of the borrowings.

For the purposes of the additional fair value disclosures for liabilities recognised at amortised cost, all borrowings have been

categorised as Level 2 financial instruments.

326 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the parent company financial statements continued

Reconciliation of liabilities arising from financing activities

The table below details changes in the Company’s liabilities arising from financing activities, including both cash and non-cash

changes. Liabilities arising from financing activities are those for which cash flows were, or future cash flows will be, classified inthe

Company’s statement of cash flows as cash flows from financing activities.

Loans due to

third parties

Loans due to

Group

companies

Total

borrowings

Derivative

assets

(note 7)

Accrued

interest Total

£m £m £m £m £m £m

At 1 January 2025 3,466 1,460 4,926 (106) 75 4,895

Cash movements

New borrowings, net of costs – 1,162 1,162 – – 1,162

Repayments (398) (399) (797) – (281) (1,078)

Non-cash movements

Dividend in specie payment – (770) (770) – – (770)

Movement in foreign exchange (48) 8 (40) – – (40)

Amortisation 6 – 6 – – 6

Capitalised interest – 70 70 – – 70

Movement in fair value – – – 70 – 70

Other movements

– – – – 262 262

At 31 December 2025 3,026 1,531 4,557 (36) 56 4,577

Loans due to

third parties

Loans due to

Group

companies

Total

borrowings

Derivative

assets

(note 7)

Accrued

interest Total

£m £m £m £m £m £m

At 1 January 2024 3,715 2,098 5,813 (118) 78 5,773

Cash movements

New borrowings, net of costs 390 1,189 1,579 – – 1,579

Repayments (643) (978) (1,621) – (301) (1,922)

Non-cash movements

Dividend in specie payment – (969) (969) – – (969)

Movement in foreign exchange 5 (8) (3) – – (3)

Amortisation (1) – (1) – – (1)

Capitalised interest – 128 128 – – 128

Movement in fair value – – – 12 – 12

Other movements

– – – – 298 298

At 31 December 2024 3,466 1,460 4,926 (106) 75 4,895

1 Cross currency swaps to hedge against adverse currency movements in respect of the Group's Euro and US Dollar denominated borrowings (see note 7 for further details).

2 Other movements represents the non-cash movement in the interest liability on borrowings.

12. Provisions

The accounting policy for provisions is included in note G7 to the consolidated financial statements.

Restructuring provisions

2025

Transition and

Transformation

Transfer of

ReAssure policy

administration Total

£m £m £m

At 1 January 73 134 207

Additions in the year 19 58 77

Utilised during the year (21) (59) (80)

Released during the year – (103) (103)

Discounting 2 7 9

At 31 December 73 37 110

11. Borrowings continued

327Annual Report and Accounts 2025

Financials

Standard Life plc

Transition and transformation

In 2019, the Company recognised a transition and transformation restructuring provision in relation to the acquired Standard Life

businesses, which included migration costs, severance costs and other expenses. During the year, £21 million (2024: £22 million) of

the restructuring provision was utilised and the provision was increased by £19 million (2024: increased by £39 million). The impact of

discounting the provision was £2 million (2024: £7 million) in the year. The remaining provision of £73 million (2024: £73 million) is

expected to be utilised within one to four years.

Transfer of ReAssure policy administration

During 2023, the Group announced its intention to migrate all ReAssure policies onto the TCS BaNCS platform and the consolidation

of its operating locations. Following a strategic review in 2025 the Group subsequently announced the appointment of Wipro as a

new strategic partner under a Business Process Outsourcing arrangement. As part of this partnership Wipro purchased ALPHA, the

existing ReAssure platform, and assumed responsibility for the management and servicing of the ALPHA platform.

During the year, the provision was increased by £58 million (2024: £30 million), £103 million released and £59 million was utilised

(2024: £46 million). The impact of discounting the provision was £7 million (2024: £9 million) in the year. The remaining provision

of£37 million (2024: £134 million) is expected to be utilised within one to four years.

See note G7 to the consolidated financial statements for further details and disclosures associated with each of these provisions.

13. Lease liabilities

The accounting policy for lease liabilities is included in note G9 to the consolidated financial statements.

Lease liabilities relate to office premises at 20 Old Bailey, London. The lease was assigned on 24 March 2021 for a term of 12 years

and 9 months, with an option to break the contract on 25 December 2028. It is currently not expected that the break clause will

beexercised.

2025 2024

£m £m

At 1 January 16 18

Lease payments (1) (2)

At 31 December 15 16

Amounts due after 12 months 13 14

14. Accruals and deferred income

The accounting policy for accruals and deferred income is included in note G10 to the consolidated financial statements.

2025 2024

£m £m

Accruals and deferred income 109 112

Amount due for settlement after 12 months 5 5

15. Cash flows from operating activities

2025 2024

£m £m

Profit for the year before tax 604 59

Non-cash movements in profit for the year before tax:

Impairment of loan due from subsidiary 13 11

Impairment of investments in Group entities 33 1,289

Investment income (1,477) (2,306)

Finance costs 296 373

Fair value losses on financial assets 75 10

Foreign exchange movement on borrowings at amortised cost (16) (10)

Share-based payment charge 26 26

Depreciation 1 2

Decrease/(increase) in investment assets 279 (77)

Net (increase)/decrease in working capital (46) 311

Cash utilised by operations (212) (312)

The accounting policy for cash and cash equivalents is included in note G6 to the consolidated financial statements.

328 Annual Report and Accounts 2025

Financials

Standard Life plc

Notes to the parent company financial statements continued

16. Capital and risk management

The Company’s capital comprises share capital, the Tier 1 Notes and all reserves as calculated in accordance with International

Financial Reporting Standards (‘IFRS’), as set out in the statement of changes in equity. Under English company law, dividends must

be paid from distributable profits. As the ultimate parent undertaking of the Group, the Company manages its capital to ensure that

it has sufficient distributable profits to pay dividends in accordance with its dividend policy. The distributable reserves of the

Company as at 31 December 2025 were £5,800 million (2024: £5,571 million).

At 31 December 2025, total capital was £6,921 million (2024: £6,687 million). The movement in capital in the year comprises the total

comprehensive income for the year attributable to owners of £780 million (2024: £249 million), dividends paid of £548 million (2024:

£533 million), coupon paid on Tier 1 Notes of £29 million (2024: £29 million) and credit to equity for equity-settled share-based

payments of £26 million (2024: £26 million).

In addition, the Group also manages its capital on a regulatory basis as described in note I3 to the consolidated financial statements.

The principal risks and uncertainties facing the Company are interest rate risk, liquidity risk, foreign currency risk and credit risk. The

Company hedges its currency risk exposure arising on foreign currency hybrid debt.

Details of the Group’s financial risk management policies are outlined in note E6 to the consolidated financial statements.

Credit risk management practices

The Company’s current credit risk grading framework comprises the categories detailed in note E1.2 to the consolidated financial

statements. The financial assets held at amortised cost are assessed at 31 December 2025 and 31 December 2024 as ‘performing’

and no loss allowance has been recognised in either period presented.

The Company considers reasonable and supportable information that is relevant and available without undue cost or effort to assess

whether there has been a significant increase in risk since initial recognition. This includes quantitative and qualitative information

and forward-looking analysis.

Loans and deposits – The Company is exposed to credit risk relating to loans and deposits from other Group companies, which are

considered to be of low risk. Given their low risk, the loss allowance has been set at less than £1 million. The Company assesses

whether there has been a significant increase in credit risk since initial recognition by assessing whether there have been any historic

defaults, by reviewing the going concern assessment of the borrower and the ability of the Group to prevent a default by providing

acapital or cash injection. Specific considerations for the loan to the Employee Benefit Trust are discussed in note 5.

Amounts due from other Group entities – The credit risk from activities undertaken in the normal course of business is considered

to be extremely low. Given their low risk, the loss allowance has been set at less than £1 million. The Company assesses whether

there has been a significant increase in credit risk since initial recognition by assessing past credit impairments, history of defaults

and the long-term stability of the Group.

Cash and cash equivalents – The Company’s cash and cash equivalents are held with bank and financial institution counterparties

which have investment grade ‘A’ credit ratings. The Company considers the associated credit risk is low based on the external credit

ratings of the counterparties, and there being no history of default, the impact to the net carrying amount stated in the table above

is therefore considered not to be material.

The Company writes off a financial asset when there is information indicating that the counterparty is in severe financial difficulty

and there is no realistic prospect of recovery, e.g. when the counterparty has been placed into liquidation or has entered into

bankruptcy proceedings. Financial assets written off may still be subject to enforcement activities under the Company’s recovery

procedures, taking into account legal advice where appropriate. Any recoveries made are recognised in profit or loss.

17. Share-based payments

Detailed information on the Long-term incentive plans, ShareSave schemes and Deferred bonus share schemes is contained in note

I1 in the consolidated financial statements.

18. Directors’ remuneration

Details of the remuneration of the Directors of Standard Life plc is included in the Directors’ Remuneration Report on pages 136 to

175 of the Annual Report and Accounts.

329Annual Report and Accounts 2025

Financials

Standard Life plc

19. Related party transactions

The Company has related party transactions with Group entities and its key management personnel. Details of the total

compensation of key management personnel, being those having authority and responsibility for planning, directing and controlling

the activities of the Group, including the Executive and Non-Executive Directors and members of the Group’s Executive Committee,

are included in note I4 to the consolidated financial statements.

During the year ended 31 December 2025, the Company entered into the following transactions with related parties.

2025 2024

£m £m

Dividend income from other Group entities 1,326 2,070

Interest income from other Group entities 102 124

1,428 2,194

Expense to other Group entities 471 589

Interest expense to other Group entities 91 162

562 751

Amounts due from related parties at the end of the year:

2025 2024

£m £m

Loans due from Group entities 1,434 1,398

Interest accrued on loans due from Group entities 20 24

Other amounts due from Group entities 156 105

1,610 1,527

Amount due for settlement after 12 months 1,349 915

Amounts due to related parties at the end of the year:

2025 2024

£m £m

Loans due to Group entities 1,531 1,460

Interest accrued on loans due to Group entities 10 11

Other amounts due to Group entities 299 341

1,840 1,812

Amount due for settlement after 12 months 480 188

20. Auditor’s remuneration

Details of auditor’s remuneration for Standard Life plc and its subsidiaries is included in note C6 to the consolidated financial

statements.

21. Events after the reporting period

Details of events after the reporting date are included in note I7 to the consolidated financial statements.

Sir Nicholas Lyons

Andy Briggs

Nicolaos Nicandrou

Eleanor Bucks

Siobhan Boylan

Karin Cook

Sherry Coutu, CBE

Karen Green

Mark Gregory

Hiroyuki Iioka

Katie Murray

Margaret Semple, OBE

13 March 2026

330 Annual Report and Accounts 2025

Financials

Standard Life plc

Additional life company asset disclosures

The analysis of the asset portfolio provided below comprises the assets held by the Group’s Life Companies, and it is stated net of

derivative liabilities. It excludes other Group assets such as cash held in the holding and management service companies and the

assets held by the non-controlling interests in consolidated collective investment schemes. The information is presented on a

look-through basis into the underlying funds.

The following table provides an overview of the exposure by asset category of the Group’s Life Companies’ shareholder and

policyholder funds:

31 December 2025

Shareholder and

non-profit funds

Participating

supported

Participating

non-supported

Unit-linked

Total

Carrying value £m £m £m £m £m

Cash and cash equivalents 3,700 894 4,691 8,626 17,911

Debt securities – gilts and foreign government bonds 13,179 406 12,926 6,169 32,680

Debt securities – other government and supranationals 2,715 106 2,179 13,306 18,306

Debt securities – infrastructure loans – project finance

1,008 – – – 1,008

Debt securities – infrastructure loans – corporate

2,185 – – – 2,185

Debt securities – local authority loans

1,191 – 5 1 1,197

Debt securities – loans guaranteed by export

credit agencies and supranationals

700 – – – 700

Debt securities – private corporate credit

3,675 – 110 1 3,786

Debt securities – loans to housing association

1,249 – 7 2 1,258

Debt securities – commercial real estate loans

1,293 – – – 1,293

Debt securities – equity release mortgages

4,948 – – – 4,948

Debt securities – other debt securities 10,507 838 11,111 30,472 52,928

42,650 1,350 26,338 49,951 120,289

Equity securities 124 48 18,206 139,025 157,403

Property investments 28 9 1,339 3,446 4,822

Other investments

(2,893) (627) 195 10,753 7,428

Total Life Company assets 43,609 1,674 50,769 211,801 307,853

Less assets held for sale

– – (4) – (4)

At 31 December 2025 43,609 1,674 50,765 211,801 307,849

Holding companies’ cash 846

Cash and financial assets in other Group companies 735

Financial assets held by the non-controlling interest

inconsolidated collective investment schemes 3,670

Total Group consolidated assets excluding amounts classified as held for sale 313,100

Comprised of:

Investment property 4,528

Financial assets 309,031

Cash and cash equivalents 7,302

Derivative liabilities (7,761)

313,100

1 Includes assets where shareholders of the life companies bear the investment risk.

2 Includes assets where policyholders bear most of the investment risk.

3 All infrastructure loans – project finance, commercial real estate loans and equity release mortgages held by the Group’s Life Companies are classified as Level 3 debt securities in

the fair value hierarchy.

4 Total infrastructure loans – corporate of £2,185 million include £2,179 million classified as Level 3 debt securities in the fair value hierarchy.

5 Total local authority loans of £1,197 million include £1,137 million classified as Level 3 debt securities in the fair value hierarchy.

6 Total loans guaranteed by export credit agencies and supranationals of £700 million include £486 million classified as Level 3 debt securities in the fair value hierarchy.

7 Total private corporate credit of £3,786 million include £3,641 million classified as Level 3 debt securities in the fair value hierarchy.

8 Total loans to housing associations of £1,258 million include £1,202 million classified as Level 3 debt securities in the fair value hierarchy.

9 Includes other loans of £183 million, net derivative liabilities of £(3,302) million, reinsurers’ share of investment contracts of £10,657 million and other investment related net

liabilities of £(110) million.

10 Represents investment property held for sale. See note H2 to the consolidated financial statements for further details.

331Annual Report and Accounts 2025

Financials

Standard Life plc

31 December 2024

Shareholder and

non-profit funds

Participating

supported

Participating

non-supported

Unit-linked

Total

Carrying value £m £m £m £m £m

Cash and cash equivalents 4,286 875 4,390 7,934 17,485

Debt securities – gilts and foreign government bonds 8,260 227 14,233 14,891 37,611

Debt securities – other government and supranationals 2,484 139 1,798 4,811 9,232

Debt securities – infrastructure loans – project finance

1,025 – – – 1,025

Debt securities – infrastructure loans – corporate

1,619 – 1 – 1,620

Debt securities – local authority loans

879 – 2 2 883

Debt securities – loans guaranteed by export

credit agencies and supranationals

688 – – – 688

Debt securities – private corporate credit

3,071 – 99 8 3,178

Debt securities – loans to housing associations

1,218 – 7 2 1,227

Debt securities – commercial real estate loans

1,170 – – – 1,170

Debt securities – equity release mortgages

4,795 – – – 4,795

Debt securities – other debt securities 13,207 1,107 11,786 26,930 53,030

38,416 1,473 27,926 46,644 114,459

Equity securities 116 51 16,901 122,304 139,372

Property investments 35 11 1,541 4,195 5,782

Income strips

– – – 555 555

Other investments

(726) (678) 629 10,299 9,524

Total Life Company assets 42,127 1,732 51,387 191,931 287,177

Less assets held by disposal groups

– – – (3,175) (3,175)

At 31 December 2024 42,127 1,732 51,387 188,756 284,002

Holding companies’ cash 1,117

Cash and financial assets in other Group companies 748

Financial assets held by the non-controlling interest

inconsolidated collective investment schemes 3,335

Financial assets in consolidated funds

held by disposalgroups

Total Group consolidated assets excluding amounts classified as held for sale 289,277

Comprised of:

Investment property 4,370

Financial assets 279,539

Cash and cash equivalents 9,453

Derivative liabilities (4,085)

289,277

1 Includes assets where shareholders of the life companies bear the investment risk.

2 Includes assets where policyholders bear most of the investment risk.

3 Total infrastructure loans – project finance of £1,025 million include £1,011 million classified as Level 3 debt securities in the fair value hierarchy.

4 Total infrastructure loans – corporate of £1,620 million include £1,613 million classified as Level 3 debt securities in the fair value hierarchy.

5 Total local authority loans of £883 million include £823 million classified as Level 3 debt securities in the fair value hierarchy.

6 Total loans guaranteed by export credit agencies and supranationals of £688 million include £461 million classified as Level 3 debt securities in the fair value hierarchy.

7 Total private corporate credit of £3,178 million include £3,046 million classified as Level 3 debt securities in the fair value hierarchy.

8 Total loans to housing associations of £1,227 million include £1,172 million classified as Level 3 debt securities in the fair value hierarchy.

9 All commercial real estate loans, equity release mortgages and income strips are classified as Level 3 debt securities in the fair value hierarchy.

10 Includes other loans of £133 million, net derivative liabilities of £(866) million, reinsurers’ share of investment contracts of £9,297 million and other investments of £960 million.

11 See note H2 to the consolidated financial statements for further details.

332 Annual Report and Accounts 2025

Financials

Standard Life plc

Additional life company asset disclosures continued

The following table provides a reconciliation of the total Life Company assets to the Assets under Administration (‘AUA’) as at

31 December 2025 detailed in the Business review on page 39.

2025 2024

£bn £bn

Total Life Company assets excluding amounts classified as held for sale 307.8 284.0

Off-balance sheet AUA

11.0 10.3

Less: Wrap SIPP and Onshore Bond assets

(2.2) (2.3)

Assets under Administration 316.6 292.0

1 Off-balance sheet AUA represents assets held in respect of certain Group Self-Invested Personal Pension products where the beneficial ownership interest resides with the

customer (and which are therefore not recognised in the consolidated statement of financial position) but on which the Group earns fee revenue.

2 Assets held in Wrap Self-Invested Personal Pension (‘Wrap SIPP’) and Onshore Bond products the associated profits of which accrue to Aberdeen Group plc under a profit transfer

arrangement have been excluded from AUA.

All of the Life Companies’ debt securities are held at fair value through profit or loss under IFRS 9 Financial Instruments, and therefore

already reflect any reduction in value between the date of purchase and the reporting date.

The Life Companies have in place a comprehensive database that consolidates credit exposures across counterparties, geographies

and business lines. This database is used for credit monitoring, stress testing and scenario planning. The Life Companies continue to

manage their balance sheets prudently and have taken extra measures to ensure their market exposures remain within risk appetite.

For each of the Life Companies’ significant financial institution counterparties, industry and other data has been used to assess the

exposure of the individual counterparties. As part of the Group’s risk appetite framework and analysis of shareholder exposure to a

potential worsening of the economic situation, this assessment has been used to identify counterparties considered to be most at

risk from defaults. The financial impact on these counterparties, and the contagion impact on the rest of the shareholder portfolio,

isassessed under various scenarios and assumptions. This analysis is regularly reviewed to reflect the latest economic outlook,

economic data and changes to asset portfolios. The results are used to inform the Group’s views on whether any management

actions are required.

The table below shows the Group’s market exposure analysed by credit rating for the shareholder debt portfolio, which comprises

ofdebt securities held in the shareholder and non-profit funds.

Sector analysis of shareholder and non-profit fund bond portfolio

AAA AA A BBB BB & below

Total

2025 £m £m £m £m £m £m

Industrials – 140 237 504 – 881

Basic materials – 3 74 17 – 94

Consumer, cyclical – 29 230 77 – 336

Technology and telecoms 1 163 236 265 – 665

Consumer, non-cyclical 7 85 308 137 – 537

Structured finance – – 35 – – 35

Banks

58 378 1,572 347 – 2,355

Financial services 54 140 126 47 31 398

Diversified – – 4 – – 4

Utilities – 196 898 1,371 – 2,465

Sovereign, sub-sovereign

andsupranational 1,442 15,335 1,321 80 – 18,178

Real estate 30 581 4,293 1,464 96 6,464

Investment companies – 177 255 262 – 694

Insurance – 313 453 162 6 934

Oil and gas – 188 192 36 – 416

Collateralised debt obligations – 8 – – – 8

Private equity loans – 2 43 – – 45

Equity release mortgages

2,805 929 1,214 – – 4,948

Infrastructure – 423 296 2,385 89 3,193

At 31 December 2025 4,397 19,090 11,787 7,154 222 42,650

1 Includes unrated holdings of £43 million.

2 The £2,355 million total shareholder exposure to bank debt comprised £1,796 million senior debt and £559 million subordinated debt.

3 The credit ratings attributed to equity release mortgages are based on the ratings assigned to the internal securitised loan notes.

333Annual Report and Accounts 2025

Financials

Standard Life plc

Sector analysis of shareholder and non-profit fund bond portfolio

AAA AA A BBB BB & below1 Total

2024 £m £m £m £m £m £m

Industrials – 251 177 713 18 1,159

Basic materials – – 104 10 – 114

Consumer, cyclical – 235 264 79 59 637

Technology and telecoms 31 115 297 421 1 865

Consumer, non-cyclical 103 357 548 150 7 1,165

Structured finance – – 36 – – 36

Banks

263 423 2,132 500 – 3,318

Financial services 50 278 239 140 19 726

Diversified – 3 19 – – 22

Utilities – 268 1,265 1,620 67 3,220

Sovereign, sub-sovereign

andsupranational 1,341 10,387 701 115 – 12,544

Real estate 29 481 4,092 1,352 107 6,061

Investment companies 1 94 82 – – 177

Insurance 57 382 218 117 – 774

Oil and gas – 297 306 62 – 665

Collateralised debt obligations – 6 – – – 6

Private equity loans – – 15 107 – 122

Equity release mortgages

2,675 948 1,172 – – 4,795

Infrastructure – 375 207 1,370 58 2,010

At 31 December 2024 4,550 14,900 11,874 6,756 336 38,416

1 Includes unrated holdings of £13 million.

2 The £3,318 million total shareholder exposure to bank debt comprised £2,624 million senior debt and £694 million subordinated debt.

3 The credit ratings attributed to equity release mortgages are based on the ratings assigned to the internal securitised loan notes.

The following table sets out the debt security exposure by country of the shareholder and non-profit funds of the life companies:

Sovereign,

sub-sovereign

and

supranational

Corporate and

other Total

Sovereign,

sub-sovereign

and

supranational

Corporate and

other Total

Analysis of shareholder debt security exposure by 2025 2025 2025 2024 2024 2024

country £m £m £m £m £m £m

UK 15,490 15,517 31,007 10,438 15,807 26,245

Supranationals 555 2 557 729 – 729

USA 495 3,519 4,014 293 3,949 4,242

Germany 165 924 1,089 156 1,010 1,166

France 380 1,350 1,730 195 1,769 1,964

Netherlands 79 278 357 83 273 356

Italy – 209 209 – 335 335

Ireland 47 32 79 39 48 87

Spain 24 49 73 7 232 239

Luxembourg 65 154 219 – 31 31

Belgium 88 99 187 113 53 166

Australia – 443 443 1 532 533

Canada 49 191 240 49 177 226

Japan – 142 142 – 221 221

Mexico 14 98 112 1 150 151

Other – non-Eurozone

514 1,040 1,554 329 953 1,282

Other – Eurozone 213 425 638 111 332 443

Total shareholder debt securities 18,178 24,472 42,650 12,544 25,872 38,416

1 There was no shareholder exposure to Russia, Ukraine and Belarus at 31 December 2025 and 31 December 2024.

334 Annual Report and Accounts 2025

Financials

Standard Life plc

Standard life plc Solvency II surplus

The estimated Standard Life plc Solvency II surplus at 31 December 2025 is £3.6 billion (2024: £3.5 billion).

31 December

2025

Estimated

31 December

2024

£bn £bn

Own Funds 10.3 10.4

SCR (6.7) (6.9)

Surplus 3.6 3.5

Composition of own funds

Own Funds items are classified into different Tiers based on the features of the specific items and the extent to which they possess

the following characteristics, with Tier 1 being the highest quality:

• availability to be called up on demand to fully absorb losses on a going-concern basis, as well as in the case of winding-up

(‘permanent availability’); and

• in the case of winding-up, the total amount that is available to absorb losses before repayment to the holder until all obligations

topolicyholders and other beneficiaries have been met (‘subordination’).

Standard Life plc’s total Own Funds are analysed by Tier as follows:

31 December

2025 31 December

Estimated 2024

£bn £bn

Tier 1 – Unrestricted 6.4 6.2

Tier 1 – Restricted 0.9 1.1

Tier 2 2.3 2.4

Tier 3 0.7 0.7

Total Own Funds 10.3 10.4

Standard Life plc’s unrestricted Tier 1 capital accounts for 63% (2024: 59%) of total Own Funds and comprises ordinary share capital,

surplus funds of the unsupported with-profits funds which are recognised only to a maximum of the notional SCR of the fund, and

the accumulated profits of the remaining business.

Restricted Tier 1 and Tier 2 capital comprises subordinated notes the terms of which enable them to qualify as capital in their

respective Tiers for regulatory reporting purposes.

Tier 3 items include the Tier 3 subordinated notes of £0.2 billion (2024: £0.2 billion) and the deferred tax asset of £0.5 billion

(2024:£0.5 billion).

Group capital resources

The Group capital resources, presented on a shareholder basis, are based on the Group's Eligible Own Funds adjusted to remove

amounts pertaining to unsupported with-profit funds and Group pension schemes:

2025 2024

Unaudited £bn £bn

Group's Eligible Own Funds 10.3 10.4

Remove Own Funds pertaining to unsupported with-profit funds and pension schemes (2.0) (2.0)

Group capital resources 8.3 8.4

Additional capital and segmental disclosures

335Annual Report and Accounts 2025

Financials

Standard Life plc

Breakdown of SCR

The Group operates one single PRA approved Internal Model covering all Group entities with the exception of the Irish life entity,

Standard Life International Designated Activity Company and the ReAssure and Phoenix Life CA Holdings businesses, which

determine their capital requirements in accordance with the Standard Formula. Phoenix Life Assurance Europe Designated Activity

Company was deauthorised in May 2025 and was a Standard formula entity in the comparative period. An analysis of the

prediversified SCR of the Group is presented below:

31 December 2025 Estimated 31 December 2024

Internal Model

Standard

Formula Internal Model

Standard

Formula

% % % %

Longevity 12 11 13 11

Credit 17 14 20 16

Persistency 24 31 21 31

Interest rates 8 5 7 4

Operational 6 5 6 4

Swap spreads 1 – 1 –

Property 7 1 7 1

Other market risks 12 22 11 20

Other non-market risks 13 11 14 13

Total pre-diversified SCR 100 100 100 100

The above table includes within each risk driver category the sum of each individual risk with no diversification between the

individual risks within a risk driver category.

The following table sets out the estimated Solvency II shareholder SCR by risk category. In this table diversification is included

between the individual risks within each risk driver. Therefore the diversification benefit shown is that between risk drivers.

31 December

2025

Estimated

31 December

2024

£bn £bn

Unrewarded market risks (hedged)

Interest rates 0.7 0.6

Equities 0.8 0.8

Currency 0.6 0.6

Inflation 0.2 0.2

Rewarded market risks

Credit 1.7 2.2

Property 0.7 0.7

Other market risks 0.2 0.2

Non-market risks

Longevity 1.3 1.4

Persistency 2.8 2.4

Operational 0.8 0.8

Other non-market risks 2.0 2.2

Loss absorbing capacity of deferred tax (1.2) (1.1)

Adjustments 0.3 0.4

Total undiversified shareholder SCR 10.9 11.4

Diversification benefit (6.2) (6.5)

Diversified shareholder SCR 4.7 4.9

Where market risks are considered unrewarded the Group enters into hedging arrangements to minimise exposure.

Rewarded market risks primarily includes credit risk in the shareholder credit portfolio, and property risk from equity release mortgages.

For non-market risks, longevity risk primarily arises from the annuity book and is managed through reinsurance. We retain

approximately half of this risk across our current in-force book, and reinsure most of this risk on new business. Persistency risk is

managed through our customer proposition.

336 Annual Report and Accounts 2025

Financials

Standard Life plc

Additional capital and segmental disclosures continued

Minimum capital requirements

Under the Solvency II regulations, the Minimum Capital Requirement (‘MCR’) is the minimum amount of capital an insurer is required

to hold below which policyholders and beneficiaries would become exposed to an unacceptable level of risk if an insurer was allowed

to continue its operations. For Groups this is referred to as the Minimum Consolidated Group SCR (‘MGSCR’).

The MCR is calculated according to a formula prescribed by the Solvency II regulations and is subject to a floor of 25% of the SCR or

£3.5 million, whichever is higher, and a cap of 45% of the SCR. The MCR formula is based on factors applied to technical provisions

and capital at risk. The MGSCR represents the sum of the MCRs of the underlying insurance companies.

The Eligible Own Funds to cover the MGSCR is subject to quantitative limits as shown below:

• the Eligible amounts of Tier 1 items should be at least 80% of the MGSCR; and

• the Eligible amounts of Tier 2 items shall not exceed 20% of the MGSCR.

Standard Life plc’s estimated MGSCR at 31 December 2025 is £2.4 billion (2024: £2.3 billion).

Standard Life plc’s estimated Eligible Own Funds to cover MGSCR is £7.4 billion (2024: £7.5 billion) leaving an excess of Eligible Own

Funds over MGSCR of £5 billion (2024: £5.2 billion), which transfers to an MGSCR coverage ratio of 304% (2024: 325%).

Reconciliation of IFRS shareholder equity to estimated shareholder Solvency II surplus

The following table provides a reconciliation of the Total equity attributable to owners of the parent as presented on the IFRS

balance sheet to the estimated shareholder Solvency II surplus at 31 December 2025. The shareholder view of estimated Solvency II

surplus excludes the Solvency II Own Funds and Solvency Capital Requirements (‘SCR’) of unsupported with-profits funds and

unsupported pension schemes. The resulting estimated Solvency II surplus aligns with the regulatory view.

31 December

2025

Estimated

£bn

31 December

2024

£bn

Total equity attributable to owners of the parent 0.2 1.2

CSM (net of tax) 2.9 2.5

IFRS Adjusted Shareholders Equity 3.1 3.7

Deduct Acquired in-force business intangible (net of tax) (1.1) (1.3)

Add Investment contract Value of In-Force ('VIF') (Solvency UK basis)

4.4 3.6

Other valuation differences

(1.5) (1.4)

Solvency II Own Funds (excluding Qualifying Debt) 4.9 4.6

Add Qualifying debt 3.4 3.8

Solvency II Own Funds (shareholder basis) 8.3 8.4

SCR (shareholder basis) (4.7) (4.9)

Solvency II surplus 3.6 3.5

1 Investment contract VIF is estimated from the Solvency II VIF for unit-linked contracts.

2 Other valuation differences include removal of other intangibles such as goodwill, brands and deferred acquisition costs from IFRS (£0.3 billion decrease), differences in technical

provision measurement including discount rate and allowance for risk (totalling a £0.9 billion decrease), valuation of debt (£0.1 billion increase), pension scheme availability

restrictions (£0.3 billion decrease) and the inclusion of the foreseeable dividend on a Solvency II basis (£0.3 billion decrease) and other items including tax on the valuation

differences (£0.2 billion increase).

Additional segmental analysis – IFRS adjusted operating profit

The table below provides an analysis of IFRS adjusted operating profit by segment and by driver:

Release of

CSM

Release of risk

adjustment

Expected

investment

margin

Operating

profit on

investment

contacts

Non-economic

experience

variances

Non-

attributable

expenses Other Total

2025 £m £m £m £m £m £m £m £m

Retirement Solutions 189 28 381 – 7 (37) (5) 563

Pensions & Savings 33 8 42 373 (4) (67) 4 389

With-Profits 15 3 6 (3) 9 (7) 1 24

Europe & Other 24 11 55 16 (25) (16) 18 83

Corporate Centre – – – – – – (114) (114)

Total 261 50 484 386 (13) (127) (96) 945

337Annual Report and Accounts 2025

Financials

Standard Life plc

Release of

CSM

Release of risk

adjustment

Expected

investment

margin

Operating

profit on

investment

contacts

Non-economic

experience

variances

Non-

attributable

expenses Other Total

2024 £m £m £m £m £m £m £m £m

Retirement Solutions 150 24 366 – (11) (60) 5 474

Pensions & Savings 33 12 – 349 9 (88) 1 316

With-Profits 19 1 9 (9) 29 (12) 4 41

Europe & Other 44 8 64 8 (11) (19) 2 96

Corporate Centre – – – – – – (102) (102)

Total 246 45 439 348 16 (179) (90) 825

A detailed analysis of our most significant segments, Retirement Solutions and Pensions & Savings is provided below.

2025 2024

Retirement Solutions £m £m

CSM release (note 1) 189 150

Risk adjustment release 28 24

Expected investment margin (note 2) 148 212

Trading profit (note 2) 233 154

Other insurance items 7 (11)

Insurance result 605 529

Non-attributable expenses (37) (60)

Other items (5) 5

IFRS adjusted operating profit (note 3) 563 474

Note 1

The CSM release reflects the recognition of service provided in the period. This can be expressed at a rate of CSM release with

reference to the closing CSM immediately before amortisation as follows:

2025 2024

CSM before amortisation (£m) 2,989 2,456

CSM release (%) 6.3% 6.1%

The CSM release has increased by £39 million to £189 million (2024: £150 million) primarily driven by new business and management

actions to improve profitability of this business.

Note 2

Expected investment return comprises:

2025 2024

£m £m

Long-term returns on Shareholder funds 101 149

Returns from asset backing liabilities 47 63

148 212

Long-term returns on Shareholder funds is determined as surplus assets multiplied by the long-term returns set out in Note B2.1 to

the consolidated financial statements.

2025 2024

Surplus assets (£bn) 2.0 3.0

Average long-term return on Shareholder funds 5.1% 5.0%

Expected investment return has decreased to £148 million (2024: £212 million) driven by a lower level of surplus assets, partly offset

by higher yields. Returns from assets backing liabilities of £47 million (2024: £63 million) include £67 million (2024: £84 million) arising

from differences where the CSM on general model business unwinds at locked in rates whereas the investment return on the backing

assets is earned at current rates and the unwind of credit default assumptions of £21 million (2024: £25 million). This is offset by the

temporary new business strain resulting from assets received as premium not yet having been deployed at their end state pricing

asset allocation amounting to £41 million (2024: £46 million).

Trading profits of £233 million (2024: £154 million) have benefited from the higher level of management actions undertaken.

338 Annual Report and Accounts 2025

Financials

Standard Life plc

Additional capital and segmental disclosures continued

Note 3

IFRS adjusted operating profits for the Retirement Solutions segment are equivalent to 140 bps (2024: 122 bps) on average assets

under administration (‘AUA’).

2025 2024

Average Assets under Administration (£bn) 40.2 39.0

IFRS adjusted operating profit margin (bps) 140 122

2025 2024

Pensions & Savings £m £m

CSM & risk adjustment release 41 45

Other insurance items 38 9

Insurance result (note 1) 79 54

Investment contract charges 887 868

Investment contract expenses (514) (519)

Investment result (note 2) 373 349

Non-attributable expenses (67) (88)

Other items 4 1

IFRS adjusted operating profit (note 3) 389 316

Note 1

The CSM and risk adjustment release has benefited from positive investment performance in the period increasing the value of the

CSM as these contracts are primarily measured using the Variable Fee Approach. Other insurance items in 2025 additionally include

investment margin on assets supporting this business.

Note 2

Average AUA has grown by 7% year-on-year, with positive investment performance more than offsetting net fund outflows, driving

an increase in investment contract charges, offset by the effects of business mix from business in run-off.

Investment contract expenses are lower, reflecting the Group’s cost efficiency drive and fee rate savings for investment management

services which offset higher investment management expenses driven by the increase in the average AUA.

Note 3

Overall IFRS adjusted operating margin for 2025 was 19 bps (2024: 17 bps) driven by positive investment returns and reduction in costs.

2025 2024

IFRS adjusted operating profit (£m) 389 316

Average AUA (£bn)

204.6 191.5

IFRS adjusted operating profit margin (bps) 19 17

1 Bonds AUA has been reallocated to Pensions & Savings from Europe for 2024 and 2025, and a held for transfer Corporate Trustee Investment Plan reclassified to Other from

Pensions & Savings in December 2025. No change has been made to segmental IFRS adjusted operating profit on grounds of materiality. The IFRS adjusted operating profit margin

has been updated accordingly.

339Annual Report and Accounts 2025

Financials

Standard Life plc

Additional segmental analysis – operating cash generation

Operating Cash Generation (‘OCG’) represents the emergence of cash as in-force business runs off over time and capital unwinds. It

includes day one surplus from writing new business (net of day 1 strain for fee-based business), group tax relief and increases in

profits from in-force business resulting from cost saving initiatives, as well as recurring management actions.

The table below provides an analysis of OCG by segment, expressed as a margin on average AUA:

2025 2024

Surplus

emergence

Recurring

management

actions

Operating

Cash

Generation

Surplus

emergence

Recurring

management

actions

Operating

Cash

Generation

£m £m £m £m £m £m

Retirement Solutions 435 444 879 412 438 850

Pensions & Savings 300 96 396 267 83 350

With-Profits 56 20 76 74 – 74

Europe & Other 123 – 123 113 16 129

Total 914 560 1,474 866 537 1,403

AUA

£bn bps bps bps

AUA

£bn bps bps bps

Retirement Solutions 40.2 108 111 219 39.0 106 112 218

Pensions & Savings 204.6 15 4 19 191.5 14 4 18

With-Profits 35.3 16 6 22 37.5 20 – 20

Europe & Other 20.8 59 – 59 19.4 58 8 66

Total 300.9 30 19 49 287.4 30 19 49

1 International Bonds AUA has been reallocated to Pensions & Savings from Europe for 2024 and 2025, and a held for transfer Corporate Trustee Investment Plan reclassified to

Other from Pensions & Savings in December 2025. Segmental OCG has been presented in line with this reallocation.

Pensions & Savings OCG grew by 13% to £396 million (2024: £350 million), equivalent to 19 bps (2024: 18 bps) on average assets

administered. Some 15 bps (2024: 14 bps) reflects the release of in-force profit based on real world returns, additions from new

business and the beneficial effect of cost saving actions. The remaining 4 bps (2024: 4 bps) relates to the effect on future profits of

fund simplification actions.

Retirement Solutions OCG grew by 3% to £879 million (2024: £850 million), equivalent to 219 bps on average assets administered

(2024: 218 bps). This margin is supported by our scale, efficiency and expertise in delivering sizeable recurring management actions,

dynamics which we consider to be enduring in nature. Some 108 bps (2024: 106 bps) reflects the steady release of capital and

investment spread margins as our annuity liabilities run-off, as well as the impact of cost savings actions. The remaining 111 bps

(2024: 112 bps) relates to annuity portfolio re-optimisation and capital improvement actions.

With-Profits and Europe & Other delivered stable contributions to OCG totalling £199 million (2024: £203 million).

Recurring management actions comprise:

2025 2024

£m £m

Annuity portfolio re-optimisation 363 323

Fund simplification 93 122

Capital improvements 104 92

Total 560 537

Annuity portfolio re-optimisation reflects actions taken to evolve our annuity-backing assets whilst staying cashflow and maturity

matched. We do this by investing in assets which outperform those assumed in our new business pricing and by carrying out trading

activity within our corporate and government bond portfolios to achieve higher yields without taking on more risk, unlocking value

for the Group. The Group’s investment in its asset management capabilities has allowed us to deliver recurring annuity portfolio

re-optimisation at scale.

Fund simplification reflects actions taken to increase the efficiency of fund management expense as the asset base grows. This is

achieved by reducing the number of funds offered and through fee reviews of investment management agreements.

Capital improvements reflect actions taken to improve our capital and balance sheet modelling as the investment universe evolves.

We do this by enriching our asset data and the granularity of the calculation of our capital requirements which allows us to more

accurately reflect the risk inherent in the asset portfolio we hold.

340 Annual Report and Accounts 2025

Financials

Standard Life plc

Alternative performance measures

The Group assesses its financial performance based on a number of measures. Some measures are management derived measures

ofhistoric orfuture financial performance, position or cash flows of the Group, which are not defined or specified in accordance

withrelevant financial reporting frameworks such as International Financial Reporting Standards (’IFRS’) or Solvency UK.

These measures are known as Alternative Performance Measures (’APMs’).

APMs are disclosed in the consolidated financial statements to provide stakeholders with further helpful information on the

performance of the Group and should be viewed as complementary to, rather than a substitute for, the measures determined

according to IFRS and Solvency II as modified by the PRA’s 2024 reforms (‘Solvency UK’)

. Accordingly, these APMs may not be

comparable with similarly titled measures and disclosures by other companies.

A list of the APMs used in our Annual Report and Accounts as well as their definitions, why they are used and, if applicable, how they

can be reconciled to the nearest equivalent GAAP measure is provided below. Further discussion of these measures can be found in

the business review from page 38.

APM Definition Why this measure is used Reconciliation to financial statements

APMs derived from IFRS

Annuity

premiums

written

Represents the aggregate,

gross of reinsurance, new

business premium volume

for annuity business, written

in the period and measured

at the risk transfer date.

Annuity premiums written

provides a measure of the

Group’s ability to deliver

new business growth.

Annuity premiums written is not

directly reconcilable to the consolidated

financial statements as premiums

are no longer reported in the IFRS

consolidated income statement.

Under IFRS 17, vesting annuities are

generally not recognised as new contracts;

where they arise from a pre-existing

deferred annuity or pension contracts,

they are typically treated as a continuation

of the original contract. Therefore, the

‘Premiums received’ reported within

insurance contract liabilities in note F2 will

not reconcile to Annuity premiums written.

Assets under

administration

The Group’s Assets under

Administration (‘AUA’)

represents assets administered

by or on behalf of the Group,

covering both policyholder

fund and shareholder assets. It

includes assets recognised in

the Group’s IFRS statement of

consolidated financial position

together with certain assets

administered by the Group for

which beneficial ownership

resides with customers.

AUA indicates the potential

earnings capability of the Group

arising from its insurance and

investment business. AUA

flows provide a measure of

the Group’s ability to deliver

new business growth.

A reconciliation from the Group’s IFRS

statement of consolidated financial position

to the Group’s AUA is provided within the

additional asset disclosures on page 332.

1 The Prudential Regulation Authority’s rules for Solvency UK became effective on 31 December 2024. The new regime has been referred to as ‘Solvency II’ in this section, unless

otherwise stated, as this is in line with current PRA guidance.

341Annual Report and Accounts 2025

Financials

Standard Life plc

APM Definition Why this measure is used Reconciliation to financial statements

Fitch leverage

ratio

The Fitch leverage ratio is

calculated by the Group

(using Fitch Ratings’ stated

methodology) as debt as a

percentage of the sum of debt

and equity. Debt is defined

as the IFRS carrying value

of shareholder borrowings

excluding subordinated liabilities

qualifying as Tier 1 Own Funds

under Solvency UK rules. Equity

is defined as the sum of equity

attributable to the owners of

the parent, non-controlling

interests, contractual service

margin (‘CSM’) (net of tax),

policyholders’ share of the

with-profits estate and the Tier

1 notes. Values for subordinated

liabilities are adjusted to allow

for the impact of currency

hedges in place over foreign

currency denominated debt.

The Group seeks to manage

the level of debt on its balance

sheet by monitoring its

financial leverage position.

One of the output metrics

used in this regard is the

Fitch leverage ratio. This is to

ensure the Group maintains its

investment grade credit rating

as issued by Fitch Ratings.

The IFRS adjusted shareholders’ equity

component of the Fitch leverage ratio is

as set out later in this section (see IFRS

adjusted shareholders’ equity metric).

Fitch leverage ratio

FY25

£bn

FY24

£bn

Total equity attributable

to owners 

of the parent 0.2 1.2

CSM (net of tax) 2.9 2.5

IFRS adjusted

shareholders’ equity 3.1 3.7

Non-controlling interests 0.6 0.5

Policyholder surplus in

with-profits funds 4.4 4.1

Tier 1 notes 0.8 1.1

Total Shareholders’

equity – Fitch basis (A) 8.9 9.4

Total Shareholder

debt(B) 2.7 2.8

Fitch leverage ratio

(B/A + B) 23% 23%

Non-controlling interests and Tier 1 notes

classified as equity are directly sourced from

the Group’s IFRS statement of consolidated

financial position, and the remaining

Tier 1 notes from within borrowings in

note E5. Policyholder surplus in with-

profits funds is a subset of ‘Estimates of

present value of future cash flows’ within

insurance contract liabilities in note F1.

Holding

companies’

cash

Represents the liquid assets

held within the Group

holding companies.

The amount reflects the

available liquidity within the

holding companies for recurring

and strategic use. This includes

cash remittances paid by the

operating companies to the

Group holding companies

which is used to fund the

Group’s operating costs, debt

interest and repayments,

planned investment across

our strategic priorities and

shareholder dividends.

FY25 FY24

£m £m

Parent company cash,

deposits and collective

investment schemes 826 1,096

Add cash and collective

investment schemes held

within other Group

holding companies 20 21

Holding companies’ cash 846 1,117

342 Annual Report and Accounts 2025

Financials

Standard Life plc

Alternative performance measures continued

APM Definition Why this measure is used Reconciliation to financial statements

IFRS adjusted

operating

profit

IFRS adjusted operating profit is

a financial performance measure

basedon expected long-term

investment returns in respect of

insurance business. It is stated

before tax and excludes the

impacts of economic volatility,

amortisation and impairments of

acquisition-related intangibles,

finance costs attributable to

owners and other non-operating

items which in the Directors’

view should be excluded by

their nature or incidence to

enable a full understanding

of financial performance.

Further details of the

components of this measure

and the assumptions inherent

in the calculation of the

long-term investment return

are included in note B2.

This measure provides a more

representative view of the

Group’s performance than

the IFRS result after tax as it

provides long-term performance

information unaffected by short-

term economic volatility and

other items including one-offs,

and is stated net of policyholder

finance charges and tax.

IFRS adjusted operating

profit is a key performance

indicator used by management

for planning, reporting and

executive remuneration.

It helps give stakeholders a

better understanding of the

underlying performance of

the Group by focusing on the

operating result and separately

identifying and analysing

non-operating items.

A reconciliation of IFRS adjusted

operating profit to the IFRS result

before tax attributable to owners

is included in note B1.1.

IFRS adjusted

operating

profit margin

This is reported for the

Retirement Solutions and

Pensions and Savings segments

and represents the IFRS

adjusted operating profit

divided by the average AUA.

This measure reflects the

underlying profitability of the

segments in relation to the size

of the portfolio being managed.

Retirement Solutions FY25 FY24

IFRS adjusted operating

profit (£m) 563 474

Average Assets under

Administration (£bn) 40.2 39.0

IFRS adjusted operating

profit margin (bps) 140 122

Pensions and Savings FY25

FY24

Restated

IFRS adjusted operating

profit (£m) 389 316

Average Assets under

Administration (£bn) 204.6 191.5

IFRS adjusted operating

profit margin (bps) 19 17

1. FY24 Average AUA has been restated to reflect the

reallocation of the International Bond from Europe and

Other to Pensions and Savings. FY25 Average AUA reflects

this view and also includes the reclassification of the

Corporate Trustee Investment Plan Held for Transfer

assets from Pensions and Savings to Europe and Other in

December 2025.

IFRS adjusted

shareholders’

equity

IFRS adjusted shareholders’

equity is calculated as IFRS

Total equity attributable

to owners of the parent

plus the CSM, net of tax.

IFRS adjusted shareholders’

equity provides a more

meaningful measure of the

value generated by the Group,

including the value held in the

CSM for IFRS 17 contracts.

IFRS adjusted shareholders’ equity reconciles

to the IFRS statement of consolidated

financial position asfollows:

FY25

£m

FY24

£m

Total equity attributable to

owners of the parent 244 1,213

Add: CSM 3,806 3,257

Less: Tax on CSM (952) (814)

IFRS adjusted

shareholders’ equity 3,098 3,656

Total equity attributable to owners of

the parent is directly sourced from the

condensed statement of consolidated

financial position. CSM is set out in

note F5. Tax is reflected at the deferred

tax rate which is currently 25%.

343Annual Report and Accounts 2025

Financials

Standard Life plc

APM Definition Why this measure is used Reconciliation to financial statements

Net fund flows Represents the aggregate

net position of gross AUA

inflows less gross outflows.

It is an in-year movement

in the Group’s AUA.

Net fund flows provide a

measure of the Group’s ability

to deliver new business growth.

Net fund flows are not directly reconcilable

to the financial statements as it includes

movements in AUA which do not flow

directly to the Group’s IFRS consolidated

income statement. However, a reconciliation

from the Group’s IFRS statement of

consolidated financial position to the

Group’s AUA is provided in the additional

asset disclosures on page 332.

Run-rate

costsavings

Represents the cumulative

estimate of annual cost

savings achieved since the

beginning of 2024, expressed

as the level of savings

expected to be generated

over a full 12-month period.

Our focus is on driving cost

efficiencies by moving to a

more efficient Group-wide

operating model, which in

turn supports better customer

outcomes. The Group has

set a target of delivering

c.£250 million of run-rate cost

savings by the end of 2026.

Run-rate cost savings is not directly

reconcilable to the financial statements

as it represents an annualised view of

savings expected to materialise, whereas

the Group’s IFRS consolidated income

statement will only reflect the absolute

in-period savings realised so far.

In 2025, the Group’s cost savings programme

delivered £117 million of run-rate savings,

which combined with the savings achieved

in 2024, brings the cumulative run-rate cost

savings total to £180 million across 2024-25.

Total cash

generation

Cash remitted by the Group’s

operating companies to the

Group’s holding companies.

The statement of consolidated

cash flows prepared in

accordance with IFRS combines

cash flows relating to

shareholders with cash flows

relating to policyholders, but

the practical management of

cash within the Group maintains

a distinction between the

two. The Group therefore

focuses on the cash flows of

the holding companies which

relate only to shareholders.

Such cash flows are considered

more representative of the

cash generation that could

potentially be distributed as

dividends or used for debt

repayment and servicing, and

group operating expense.

Total cash generation is a

key performance indicator

used by management for

planning, reporting and

executive remuneration.

Total cash generation is not directly

reconcilable to the statement of

consolidated cash flows as it includes

amounts that eliminate on consolidation.

Further details of holding companies’ cash

flows are included within the business

review on page 43, and a breakdown

of the Group’s cash position by type

of entity is provided in the additional

asset disclosures on page 330.

344 Annual Report and Accounts 2025

Financials

Standard Life plc

Alternative performance measures continued

APM Definition Why this measure is used Reconciliation to financial statements

APMs derived from Solvency II

Annuity Capital

Strain

Represents the capital

deployment on annuities

measured on a Solvency II basis,

expressed as a proportion

of the annuity premium.

It is calculated as the capital

deployed (being the Solvency

II Technical Provisions plus

SCR plus acquisition costs

plus reinsurance premium

less annuity premium, net

of tax) as a proportion of

the annuity premium.

Annuity Capital Strain reflects

how efficiently capital is

deployed on annuities to

deliver new business growth.

The capital deployed in writing

annuity business is included within

the holding companies’ cash flows on

page 43 within the business review.

Life Companies

Free Surplus

The Solvency II surplus of

the Life Companies that is in

excess of their Board approved

capital according to their

capital management policies.

This figure provides a view

of the level of surplus capital

in the Life Companies that is

available for distribution to

the holding companies, and

the generation of Free Surplus

underpins future Operating

Cash Generation (‘OCG’).

Life Companies Free Surplus is a subset

of the change in Solvency II surplus

over the period set out in the table on

page 43 within the business review.

It can be reconciled as follows:

FY25

£bn

FY24

£bn

Group Solvency II surplus 3.6 3.5

Less: Non-life components

and consolidation

adjustments (0.1) 0.1

Less: Capital Management

Policy (2.0) (1.7)

Life Companies

FreeSurplus 1.5 1.9

Operating

Cash

Generation

(‘OCG’),

Operating

Surplus

Generation

(‘OSG’)

And

Operating

Cash

Generation

Spread (‘OCG

Spread’)

Operating Cash Generation

(‘OCG’) is the emergence of

cash on a Solvency II basis as

surplus emerges (being the

in-force business run off over

time and capital unwind, plus

day one surplus from writing

new business (net of day 1

strain for fee based business)

plus group tax relief, plus the

recurring management actions,

plus the capitalised benefit

from delivery of our cost savings

programme. As a cash measure

it will be reported in line with

Life Companies Free Surplus

view and therefore is the

excess of their Board approved

capital according to their

capital management policies.

OCG before adjustment

to reflect the release of

capital management policy

is referred to as Operating

Surplus Generation (‘OSG’).

The OCG Spread is calculated

as OCG divided by average

Assets Under Administration.

The measure represents the

sustainable level of ongoing

cash generation from our

underlying business operations

that is remitted from our Life

Companies to the Group.

The components of OCG are:

FY25

£bn

FY24

£bn

Surplus generation 0.9 0.8

Recurring management

actions 0.5 0.5

OSG 1.4 1.3

Release of capital

management policy 0.1 0.1

OCG 1.5 1.4

OSG forms a component of the change

in Solvency II surplus in the period

as set out in the table on page43

within the business review.

345Annual Report and Accounts 2025

Financials

Standard Life plc

APM Definition Why this measure is used Reconciliation to financial statements

Recurring

management

actions

Recurring management

actions are measured on a

Solvency II basis and represent

the Day 1 impact on Own

Funds and SCR. They are

management actions that are

either genuinely repeatable,

repeatable in nature but subject

to diminishing returns, or are

not repeatable but benefits

are expected from similar

types of actions in the future.

The measure is a key component

of OCG and one of the sources

which can be used to support

sustainable cash remittances

from the Life Companies.

Recurring management actions are a

subset of the Solvency II surplus generated

in the period as shown in the table on

page 44 within the business review.

Shareholder

Capital

Coverage Ratio

(‘SCCR’)

Represents total Eligible Own

Funds divided by the Solvency

Capital Requirements (‘SCR’),

adjusted to a shareholder

view through the exclusion of

amounts relating to those ring-

fenced with-profits funds and

Group pension schemes whose

Own Funds exceed their SCR.

The unsupported with-profits

funds and Group pension funds

do not contribute to the Group

Solvency II surplus. However, the

inclusion of related Own Funds

and SCR amounts dampens the

implied Solvency II capital ratio.

TheGroup therefore focuses on

a shareholder view of the capital

coverage ratio which is

considered to give a more

accurate reflection of the capital

strength of the Group.

Further details of the Shareholder Capital

Coverage Ratio and its calculation are

included in the business review on page 44.

Solvency II

Leverage ratio

The Solvency II Leverage ratio

is calculated as the Solvency

II value of debt divided by

the value of Solvency II

Regulatory Own Funds.

Values for debt are adjusted to

allow for the impact of currency

hedges in place over foreign

currency denominateddebt.

The Group is committed to

reducing its leverage and has set

a SII Leverage ratio target of

c.30% by the end of 2026.

FY25

£bn

FY24

£bn

Regulatory Eligible Own

Funds 10.3 10.2

Total debt 3.4 3.7

Solvency II

leverageratio

33% 36%

1 Solvency II leverage ratio allows for currency hedges over

foreign current denominated debt.

Regulatory Eligible Own Funds is

a component of the calculation of

the Group’s regulatory Solvency II

surplus as set out in the additional

capital disclosures on page 334.

There are valuation differences between

IFRS and SII due to IFRS measuring the

debt on an amortised cost basis, with

SII reflecting the fair value which would

include movements in interest rates.

Both amounts are adjusted for the

value of the foreign currency hedges

used to hedge foreign currency

exposure on the Group’s borrowings.

Policy for making pro forma adjustments in the financial statements

Pro forma adjustments will be used in the financial statements where management considers that they allow the users to better

understand the financial performance, financial position, cash flows or outlook of the Group.

Examples of where pro forma adjustments may be used are in relation to acquisitions or disposals which are material to the Group,

changes to the Group’s capital structure or changes in reporting frameworks the Group applies such as Solvency II or IFRS. Where pro

forma adjustments are considered necessary for the understanding of the financial performance, financial position, cash flows or

outlook of the Group these will be clearly labelled as pro forma with a clear explanation provided as to the reason for the

adjustments and the Key Performance Indicators, Alternative Performance Metrics and other performance metrics impacted.

Shareholder information

Annual General Meeting (‘AGM’)

Our AGM will be held on 14 May 2026

at11:00am at Floor 9, 20Old Bailey,

London, EC4M 7AN.

Full details of the business to be

considered at the meeting willbe

included in the Notice of Meeting

which,along with allother details

relating to theAGM, will be available

at: www.standardlifeplc.com.

We encourage shareholders to submit

any questions to the Company in

advanceof the AGM by email to

Investor.Relations@standardlife.com

Please note thatquestions must

bereceived no later than 11:00am

on12 May 2026.

Following the meeting, the voting results

for our 2026 AGM, including proxy votes

and votes withheld will be available on

ourwebsite at: www.standardlifeplc.com

Shareholder services

Managing your shareholding

Our registrar, Computershare Investor

Services PLC (‘Computershare’), maintains

the Company’s register of members.

Shareholders may request a hard copy of

this AnnualReport and Accounts from

our registrar and should youhave any

queries in respect of your shareholding,

please contact Computershare directly

using the contact details setoutunder

the ‘Useful contact information’

section on the following page.

Online news

The Company has a dedicated

‘News and Views’ section on its

website, www.standardlifeplc.com,

to keep shareholders, investors,

journalists and employees up to

date and informed onnews.

Dividend information

Typically, the Company pays dividends

twice a year. The Interim dividend is

usually paid in October, and the

Finaldividend is paid in May following

approval by shareholders at the AGM.

Information about the 2025 Final

dividend has been included in the 2025

Full Year Results Announcement.

Payment method

From May 2027, we intend to change the

way we pay dividends to shareholders

and will no longer pay dividends by

cheque. We have already written to

shareholders advising them about this

change during January 2026 with

additional information.

If you haven’t already provided your

bankdetails to our Registrar, please

dosonow via the ‘Update your Details’

tab at www.investorcentre.co.uk to have

your dividends paid straight into your

bank account.

Scrip dividend alternative

The Company does not currently

offer a scrip dividend alternative.

Dividend reinvestment plan

The Company does not currently offer

a dividend reinvestment plan.

Investor Centre

The Investor Centre is an online

enquiry service, provided by

Computershare, which allows you to

manage your shareholding with ease.

Visit the Investor Centre at www-uk.

computershare.com/Investor/#Home

Once logged in, you can:

• view details of your Standard Life plc

shareholding;

• view your recent dividend payments;

• update your address details;

• change your payment method; and

• register for electronic communications.

You can also use Computershare’s

web-based enquiry service atwww-uk.

computershare.com/Investor/#Home

todownload forms such as a dividend

mandate form or submit dividend

mandate details online.

Alternatively, contact Computershare

using the details found under the ‘Useful

contact information’ section on the

following page.

Electronic communications

The Company is committed to

communicating to shareholders inthe

most efficient and sustainable way. We

encourage shareholders to opt to receive

electronic communications including the

Annual Report, Notice of Meeting and

dividend information. Shareholders can

update their communication preferences

by logging in to the Investor Centre at

www-uk.computershare.com/

Investor/#Home.

Shareholders are also able to access

awide range of information and

documentation on the ‘Investor’

sectionof the Group’s website at

www.standardlifeplc.com.

You can access electronic copies

of the Company’s financialreports

and presentations on the website

at: www.standardlifeplc.com.

346 Standard Life plc Annual Report and Accounts 2025

Additional information

2026 Financial calendar

Ordinary shares – 2025 Final dividend

Ex-dividend date 9 April 2026

Record date

10 April 2026

Payment date for

the recommended

Final dividend 20 May 2026

Group Financial calendar for 2026

Annual General

Meeting 14 May 2026

Announcement

ofunaudited

InterimResults Sept 2026

1. See website for announcement dates.

Share price

For a more detailed look at the share

price of Standard Life plc, including

current share price and the share price

over time, please see the ‘Share Monitor’

section of the Company’s website at

www.standardlifeplc.com.

Please be mindful that the share price

data on the website is delayed by

15minutes.

Share fraud warning

toshareholders

We continue to receive reports of share

scams, where fraudsters cold-call

investors offering a range of financial

propositions. Remember if it sounds

toogood to be true, it probably is.

Shareholders are advised to remain

vigilant at all times and if you are ever in

doubt, call the Computershare Investor

Service PLC dedicated Standard Life

shareholder enquiry line on

+44(0)800 370 709 0181.

To find out more information on how

youcan protect yourself, please visit

theFinancial Conduct Authority (‘FCA’)

website www.fca.org.uk/scamsmart

orcall the FCA consumer helpline on

+44 (0) 800 111 6768. You can also check

the firm on the Financial Services register

at www.fca.org/register.

To report a scam, please inform the

FCAusing the contact us form at

www.fca.org.uk/contact or call the

consumer helpline.

If you have lost money to investment

fraud, you should report it to Report

Fraud at www.reportfraud.police.uk or

call then on +44 (0) 300 123 2040.

Useful contact information

Computershare

Computershare Investor Services PLC

The Pavilions

Bridgwater Road

Bristol

BS99 6ZZ

United Kingdom

Shareholder helpline number:

+44 (0) 370 702 0181

Lines open from 8.30am to 5.30pm

Monday to Friday, excludingpublic

holidays in England and Wales.

Standard Life plc

For Company Secretariat

or Investor enquiries:

Kulbinder Dosanjh

Group Company Secretary

Telephone: +44 (0)20 4559 4513

Email: kulbinder.dosanjh@standardlife.com

Claire Hawkins

Director of Corporate Affairs

andBrand

Telephone: +44 (0)20 4559 3161

Email: claire.hawkins@standardlife.com

347Standard Life plc Annual Report and Accounts 2025

Additional information

Glossary

Acquired value in force (‘AVIF’)

The present value of future profits on

a portfolio of long-term investment

contracts with discretionary

participation features, acquired either

directly or through the purchase

of, or investment in, a business.

Alternative Performance

Measure (‘APM’)

A financial measure of historic or future

financial performance, financial position

or cash flows, other than a financial

measure defined under IFRS or under

Solvency UK rules. The Group uses

arange of these metrics to provide a

better understanding of the underlying

performance of the Group. All APMs are

defined within this glossary and the

APM section on pages 340 to 345.

Annuity policy

A policy that pays out regular benefit

amounts, either immediately and

for the remainder of a policyholder’s

lifetime (immediate annuity), or

deferred to commence at some

future date (deferred annuity).

Asset Backed Securities (‘ABS’)

A collateralised security whose value

and income payments arederived from

a specified pool of underlying assets.

Asset Liability Management

(‘ALM’)

The management of mismatches

between assets and liabilities within risk

appetite. The management of assets

using a structured approach to guide the

act of acquiring and disposing of assets,

with the objective of meeting defined

investment goals and maximising value

for investors, including policyholders.

Assets under administration

(‘AUA’)

Assets administered by or on behalf of

the Group, covering bothpolicyholder

funds and shareholder assets. This

includes assets recognised in the

Group’s IFRS statement of consolidated

financial position together with

certain assets administered by the

Group but for which beneficial

ownership resides withcustomers.

Climate-related opportunities

The potential positive impacts of climate

change on an organisation. Efforts to

adapt to climate change can produce

opportunities for organisations, such

as through resource efficiency and

cost savings and the development

of new products and services.

Climate (-related) risks

The potential negative impacts of

climate change on an organisation.

The risks consist of physical

risks and transition risks.

Climate solutions

Economic activities that contribute

substantially to climate change

mitigation or adaptation. The products

or services areeither produced

sustainably or allow others to do so.

Compound annual growth rate

(‘CAGR’)

The mean annual growth rate of an

investment over a specified period

of time longer than one year.

Contractual Service Margin

(‘CSM’)

Under IFRS 17, revenue and profit

recognition of day 1 gains onannuity

contracts is deferred into recognition at

a point in the future, by being added to

the CSM. The CSM therefore represents

a stock of future profits that will

unwind into the P&L in future years.

Customer

A customer could be a lead policyholder

on more than one policyand some

policies could have more than one

customer, therefore the customer

number is approximate. The

number ofcustomers is measured

as number of lead policyholders.

Decarbonising benchmarks

Climate aligned indices that aim to

deliver net zero by 2050 while meeting

our customer requirements. These are

investment benchmarks, that aim to

deliver a representative return for the

asset class (as measured by the existing

market cap benchmarks), but with

Group exclusions and built in systematic

decarbonisation pathway, consistent

with achieving net zero by 2050.

Assets under our control

andinfluence

Our definition of assets which are within

our control and influence is (i) product

componentry which are not external

fund links (i.e. we have an Investment

Management Agreement (‘IMA’)

with an Asset Management Partner, so

can control the terms of the investment

strategy), or (ii) where we have a default,

managed or blended vehicle which has

external fund link componentry and / or

directly held securities, and we have the

ability to substitute investments without

the need to secure explicit client approval

when they do not meet our needs.

Association of British Insurers

(‘ABI’)

A trade association made up of insurance

companies in the United Kingdom.

Auto-enrolment

Under the Pensions Act 2008, every

employer in the UK must put certain

staff into a workplace pensions

scheme and contribute towards it.

This is called auto-enrolment.

Carbon footprint

A carbon footprint is the total

greenhouse gas (‘GHG’) emissions caused

by an individual, event, organisation,

service, place orproduct, expressed

as carbon dioxide equivalent (CO

e).

Carbon neutral

When the carbon emissions generated

by an entity are fully compensated

for by removing an equivalent

amount of emissions somewhere

else through offsetting.

Carbon offsets

A reduction or removal of emissions

ofcarbon dioxide or other greenhouse

gases made in order to compensate

for emissions created elsewhere.

Climate scenario

A plausible representation of

future climate that has been

constructed for explicit use in

investigating the potential impacts

of anthropogenic climate change.

348 Standard Life plc Annual Report and Accounts 2025

Additional information

Defined benefit pension scheme

A pension scheme that defines

the benefits payable to members

irrespective of any contributions

paid or investment gains made.

Defined contribution

pensionscheme

A pension scheme where the

benefits depend on the amount and

frequency of contributions paid into

the scheme, the investment gain

on those contributions, and annuity

rates at the time of retirement. The

exact pension valuation will not be

known until the point of retirement.

Definition of assets within our

control and influence

(i) product componentry which are

not external fund links (i.e.we have an

Investment Management Agreement

with an Asset Management Partner, so

can control the terms of the investment

strategy), or (ii) where we have a default,

managed or blended vehicle which has

external fund link componentry and / or

directly held securities, and we have the

ability to substitute investments without

the need to secure explicit clientapproval

when they do not meet our needs.

Department for Business

andTrade

The Department for Business and Trade

(formerly the Department for Business,

Energy & Industrial Strategy (‘BEIS’) is

a ministerial department in the UK.

Digital Advisory Group

An ad hoc advisory group which meets to

provide expert guidance and challenge

on behalf of the Standard Life plc

Boardon cyber security and digital

(including customer) related items.

Economic assumptions

Assumptions related to future

interest rates, inflation, marketvalue

movements and tax.

Employee Benefit Trust (‘EBT’)

A trust is established to enable its

Trustee to purchase, hold and deliver

shares to satisfy employee share-

based incentive plan awards.

Equity release mortgage (‘ERM’)

An ERM product enables a home owner

aged over 55 to draw a lump sum or

regular smaller sums from the value of

the home, while remaining in their home.

Environmental, Social and

Governance (‘ESG’)

Environmental criteria consider how

a company performs as a steward of

nature and the climate. Social criteria

examine how itmanages relationships

with employees, suppliers, customers,

and the communities where it operates.

Governance deals with a company’s

leadership, executive pay, audits, internal

controls and shareholder rights.

Experience variances

Current period differences between

the actual experience incurred and the

assumptions used in the calculation

of IFRS insurance liabilities.

Financed emissions

Greenhouse gas (‘GHG’) emissions that

occur as a result of financing, including

lending and investment activity.

These activities fall within Scope 3,

category 15 of the GHG protocol.

Financial Conduct Authority

(‘FCA’)

The body responsible for supervising

the conduct of all financial services

firms and for the prudential regulation

of those financial services firms not

supervised by the Prudential Regulation

Authority (’PRA’), such as asset managers

and independent financial advisers.

Financial Ombudsman Service

(‘FOS’)

An ombudsman established in 2000,

and given statutory powers in 2001

by the Financial Services and Markets

Act 2000, to help settle disputes

between consumers and UK-based

businesses providing financial services.

Financial Reporting Council

(‘FRC’)

The UK’s independent regulator

responsible for promoting high-

quality corporate governance and

reporting to foster investment.

Fitch leverage ratio

The Fitch leverage ratio is calculated

(using Fitch Ratings’ stated methodology)

as debt as a percentage of the sum

of debt and equity. Debt is defined as

the IFRS carrying value of shareholder

borrowings excluding subordinated

liabilities qualifying as Tier 1 Own Funds

under Solvency UK rules. Equity is defined

as the sum of equity attributable to the

owners of the parent, non-controlling

interests, contractual service margin

(‘CSM’) (net of tax), policyholders’

share of the with-profits estate and

Tier 1 notes. Values for subordinated

liabilities are adjusted to allow for the

impact of currency hedges in place over

foreign currency denominated debt.

FTSE Women Leaders review

An independent, business-led framework

supported by the Government, which sets

recommendations for Britain’s largest

companies to improve the representation

of Women on Boards and in Leadership

positions. It continues the work of the

Hampton-Alexander and Davies Reviews.

Full-time equivalent (‘FTE’)

A measure that allows the Group

to calculate the equivalent

number of full-time employees

for all types of employees.

Greenhouse Gas (‘GHG’)

emissions

GHGs are atmospheric gases that

absorb and emit radiation within

the thermal infrared range and that

contribute to the greenhouse effect

and global climate change. They include

water vapour, carbon dioxide (CO

methane (CH

), nitrous oxide (N

O),

hydro chlorofluorocarbons (HCFCs),

ozone (O

), hydrofluorocarbons

(HFCs),and perfluorocarbons (PFCs).

Greenhouse Gas Protocol

Global standard for companies and

organisations to measure and manage

their GHG emissions. Group in-force

Long-term Free Cash (‘Group in-force

LTFC’) Group in-force LTFC is the cash

available to shareholders. It is defined as

the estimated lifetime cash generation

from our in-force business, plus Group

cash held in the Holding Company,

less outstanding shareholder debt,

committed M&A and transition costs,

and interest on debt until maturity.

The calculation for the 2023 LTIP

performance metric excludes any

future shareholder dividends and is

before interest on debt until maturity.

349Standard Life plc Annual Report and Accounts 2025

Additional information

Glossary continued

Guaranteed Annuity Rate

A rate available to certain pension

policyholders to acquire annuity at a

contractually guaranteed conversion rate.

HMRC

His Majesty’s Revenue and Customs.

Holding companies

Refers to Standard Life plc, Phoenix

Life Holdings Limited, PearlGroup

Holdings (No. 2) Limited, Impala

Holdings Limited, Pearl Life Holdings

Limited, ReAssure Group Limited

and ReAssure MidCo Limited.

IASB

International Accounting

Standards Board.

IFRS adjusted operating profit

A non-Generally Accepted Accounting

Principles (‘GAAP’) measure that is

considered a more representative

measurement of performance than

IFRS profit or loss after tax as it is based

on expected long-term investment

returns. This measure is included in

the 2025 AIP scheme. Cumulative IFRS

adjusted operating profit, being IFRS

adjusted operating profit over the 3-year

LTIP performance period is included

in the 2025 and 2026 LTIP grant.

In-force

Long-term business written before

the period end and which has not

terminated before the period end.

Inter-governmental Panel

onClimate Change (‘IPCC’)

The United Nations body created to

provide policymakers with regular

scientific assessments on climate

change, its implications and potential

future risks, as well as to put forward

adaptation and mitigation options.

Internal Model

The Internal Model is a risk measurement

system developed by an insurer

to analyse its overall risk position,

to quantify risks and to determine

the economic capital required to

meet those individual risks.

Internal rate of return (‘IRR’)

A metric used in financial analysis to

estimate the profitability ofpotential

investments. IRR is a discount rate

that makes the net present value

of all cashflows equal to zero in a

discounted cashflow analysis.

Master Trust

A defined contribution workplace

pension scheme that is established

under a trust. A master trust seeks to

provide a workplace pension that can

be used by several non-associated

employers, as opposed to traditional

schemes that are set up to provide a

workplace pension for a single employer.

Master trusts are supervised and

authorised by the Pensions Regulator.

Material suppliers

These are Suppliers who are Strategic

or Critical to the Group’soperations.

Strategic (also known as a Tier 1 supplier):

Of significant importance to the Group

where the services the supplier provides

support our strategic objectives and

are crucial in providing ongoing and

future services to our customers,

policyholders and shareholders. These

suppliers are highly likelyto be integrated

into the Group’s operating model and

willbe deemed as a Critical/Material

Arrangement for Solvency UK purposes.

Critical (also known as a Tier 2

supplier): Deemed as a Critical/Material

Arrangements, however, are not viewed

as a Strategic partner to Group. These

suppliers will perform a Critical function

and/or activity on behalf of the Group,

they could be crucial in providing

current services to our customers,

policyholders, and shareholders.

Minimum Capital Requirements

(‘MCR’)

The minimum amount of capital

that the Group needs to hold to

cover its risks under the Solvency

UK regulatory framework.

Natural capital

The stock of renewable and non-

renewable natural resources (e.g.

plants, animals, air, water, soils,

minerals) that combine to yield

a flow of benefits to people.

Nature dependencies

Aspects of environmental assets and

ecosystem services that an organisation

relies on to function. A company’s

business model, for example, may

be dependent on the ecosystem

services of water flow, water quality

regulation and the regulation of

hazards like fires and floods; provision

of suitable habitat for pollinators, who

in turn provide a service directly to

economies; and carbon sequestration.

International Financial

Reporting Standards (‘IFRS’)

Accounting standards, interpretations and

the framework adopted by the International

Accounting Standards Board.

Life Company

A subsidiary providing life

and pension products.

Life Companies Free Surplus

The amount of capital held in Life

Companies in excess of that needed to

support their regulatory Solvency Capital

Requirement (‘SCR’), plus the capital

required under the Board approved

Capital Management Policy (‘CMP’).

Longer Lives Index

The Longer Lives Index is the first piece of

research by Phoenix Insights, now known

as Standard Life Centre for the Future of

Retirement, the Group’s think-tank, and

was launched in 2022. The research

provides a rich picture of people’s financial

readiness for longer lives across the UK.

Long Term Incentive Plan (‘LTIP’)

The part of an executive’s remuneration

designed to incentivise long term

value for shareholders through

an award of shares with vesting

contingent on employment and the

satisfaction ofstretching performance

conditions linked to Group strategy.

M&A Advisory Committee

An ad hoc advisory group which meets

to consider proposed mergers and

acquisitions, including due diligence

activities undertaken by Management.

Management actions

Management actions are used to define

the financial impacts of programmes of

activity instigated and undertaken by the

Group to enhance shareholder outcomes.

Such actions will be undertaken to either

increase Shareholder Own funds (and

therefore increase future organic cash

generation) or to reduce SCR (therefore

accelerating expected cash generation).

Examples of management action

activities include investment into higher

yielding asset types, optimisation of

asset and liabilities matching positions,

and cost reduction initiatives. Certain

management actions are classified as

recurring and form part of Operating

Cash Generation (‘OCG’) – these are

actions which are either genuinely

repeatable, repeatable in nature but

subject to diminishing returns or not

repeatable but benefits are expected

from similar types of actions.

350 Standard Life plc Annual Report and Accounts 2025

Additional information

Nature impacts

Changes in the state of nature (quality or

quantity), which may result in changes to

the capacity of nature to provide social

and economic functions. Impacts can

be positive or negative. They can be the

result of an organisation’s or another

party’s actions and can be direct, indirect

or cumulative. A single impact driver may

be associated with multiple impacts.

Nature risks

Potential threats (effects of

uncertainty) posed to an organisation

that arise from its and wider society’s

dependencies and impacts on nature.

Net flows

Represents the difference between

the inflows (premiums) and outflows

and excludes market movements. Net

flows may be reported for the Group

as a whole, for a specific part of the

Group or for different time periods.

Cumulative net flows, being net flows

over the 3-year LTIP performance period,

are included in the 2024 LTIP grant.

Net operating cash receipts

This is a LTIP performance metric

in the 2023 and 2024 grants which

represents cash generation after

allowing for corporate expenses

and pension contributions.

Net zero

A state where no incremental greenhouse

gases are added to the atmosphere.

Emissions output is balanced with the

removal of carbon from the atmosphere.

Non-economic assumptions

Assumptions related to future

levels of mortality, morbidity,

persistency and expenses.

Non-profit fund

The portion of a life fund which is not a

With-Profit fund, where risks and rewards

of the fund fall wholly to shareholders.

Operating Cash Generation

(‘OCG’)

OCG is the emergence of cash as in-force

business runs off over time and capital

unwinds, plus day one surplus from

writing new business (net of day 1 strain

for fee-based business) plus group tax

relief, plus the recurring management

actions and the capitalised benefit from

delivery of our cost savings programme.

As a cash measure it is reported as the

excess of their Board approved capital

according to their CMPs. Cumulative

OCG, being OCG over the 3-year LTIP

performance period, is included in

the 2025 and 2026 LTIP grant.

Operating companies

Refers to the trading companies

within Standard Life plc.

Over-the-Counter (‘OTC’)

OTC financial instruments are traded

directly between two parties without

a broker or exchange market.

Own Funds

Under Solvency UK rules, Own Funds

refers to the regulatory capital available

to cover capital requirements. Basic Own

Fundscomprise the excess of assets

over liabilities valued in accordance

with the Solvency UK rules and

subordinated liabilities which qualify

to be included in Own Funds under the

Solvency UK rules. Eligible Own Funds

are the amount of Own Funds that are

available to cover the Solvency Capital

Requirements after applying prescribed

tiering limits and transferability

restrictions to Basic Own Funds.

Own Risk and Solvency

Assessment (‘ORSA’)

The processes undertaken to provide

a forward-looking assessment of the

Group’s risk and capital profile, under

normaland stress scenarios, as a result

of its proposed businessstrategy

and Annual Operating Plan.

Parker Review and guidance

An independent review which

considered how to improve the ethnic

and cultural diversity of UK boards to

better reflect their employee base

and the communities they serve. The

Parker guidance sets out objectives

and timescales to encourage greater

diversity, and provides practical tools

to help business leaders to address the

issue. Each FTSE 100 Board should have

at least one “director of colour” by 2021.

Partial internal model

The model used to calculate the Group

Solvency Capital Requirement where

permission is granted by the PRA under

Solvency UK. It aggregates outputs

from the harmonised internal model

and the standard formula with no

diversification between the two.

Part VII transfer

The transfer of insurance policies

under Part VII of Financial Services and

Markets Act 2000. The insurers involved

can be inthe same corporate group or

in different groups. Transfers require

the consent of the High Court, which

will consider the views of the PRA and

FCA and of an Independent Expert.

Participating business

See With-Profits fund on page 353.

Partnership for Carbon

Accounting Financials (‘PCAF’)

PCAF is a global partnership of

financial institutions that work

together to develop and implement

a harmonised approach toassess

and disclose the greenhouse gas

(GHG) emissions associated with

their loans and investments.

Pensions Risk Transfer (‘PRT’)

This is when a company moves the

financial risks of its pension plan to an

insurance company. This includes the

purchase of bulk annuities, which are

insurance policies purchased by pension

scheme trustees to secure members’

benefits and by removing investment,

inflation and longevity risk associated

with defined benefits pension schemes.

Persistency

This LTIP performance metric is set

for the specific Pensions and Savings

products only and based on a principle

of protecting value, with a target

based on the best estimate assumption

of persistency at the start of the

performance period. This is measured

on a product-by-product basis with the

average value of each product then used

to create a single weighted average

persistency rate. Further details of

persistency insurance risks are covered

in section F9 of the consolidated

financial statements. This is a LTIP

performance metric for the 2023 grant.

Physical risks

Risks related to the physical impacts

of climate change which can either

be acute or chronic. Acute physical

risks refer to those that are event-

driven, including increased severity

of extreme weather events, such as

cyclones, hurricanes or floods. Chronic

physical risks refer to longer-term

shifts in climate patterns (e.g.sustained

higher temperatures) that may cause

sea level rise or chronic heatwaves.

351Standard Life plc Annual Report and Accounts 2025

Additional information

Glossary continued

Priority locations

Described as either material locations

or sensitive locations. A material

location is where material nature-

related dependencies, impacts, risks

and opportunities are identified for

a given organisation and a sensitive

location is where business assets and

activities interface with nature in

areas important for biodiversity, of

high ecosystem integrity, of physical

water risks and of importance for

ecosystem service provision.

Protection Policy

A policy which provides benefits

payable on certain events. Thebenefits

may be a single lump sum or a series

of payments and may be payable on

death, serious illness or sickness.

Prudential Regulation Authority

(‘PRA’)

The body responsible for the prudential

regulation and supervision of banks,

building societies, credit unions,

insurersand major investment firms.

The PRA and FCA use aMemorandum of

Understanding to co-ordinate and carry

outtheir respective responsibilities.

ReAssure life companies

The companies comprising ReAssure

Limited and ReAssure Life Limited

which were acquired on 22 July 2020.

Relative policyholder outcomes

(pension fund value growth)

This 2026 LTIP performance metric

will track how the Group’s flagship

multi-asset default pension funds

(Sustainable Multi-Asset (‘SMA’)

and Multi-Asset Comparable funds)

deliver customer outcomes relative

to peers, as well as ensuring our

policyholders receive long-term real

returns above inflation (UK CPI).

Representative Concentration

Pathway (‘RCP’)

A GHG concentration trajectory adopted

by the IPCC. The pathways (RCP2.6,

RCP4.5, RCP6, and RCP8.5) describe

different climate futures, all of which

are considered possible depending on

the volume of GHGs emitted in the years

to come. RCP 2.6 is a very stringent

pathway. According to the IPCC, RCP 2.6

requires that carbon dioxide emissions

start declining by 2020 and go to zero

by 2100. In RCP 8.5, emissions continue

to rise throughout the 21st century.

It is generally taken as the basis for

worst-case climate change scenario.

Shareholder Capital Coverage

Ratio (‘SCCR’)

Represents total Eligible Own Funds

divided by the Solvency Capital

Requirements (‘SCR’), adjusted to

a shareholder view through the

exclusion of amounts relating to

those ring-fenced With-Profit funds

and Group pension schemes whose

Own Funds exceed their SCR.

Shareholder value

The Group’s Eligible Own Funds

adjusted to remove amounts pertaining

to unsupported With-Profit funds,

Group pension schemes, the value

of shareholder debt and adjusted to

removethe short-term impact economic

movements in the performance period.

Solvency II leverage ratio

Calculated as the Solvency II value of

debt divided by the value of Solvency

II Regulatory Own Funds. Values for

debt are adjusted to allow for the

impact of currency hedges in place over

foreign currency denominated debt.

Solvency II Shareholder Own

Funds Unrestricted Tier 1

Under Solvency UK rules, SII Shareholder

Own Funds Unrestricted Tier 1

refers to the highest quality tier of

regulatory capital available to cover

capital requirements. Itcomprises the

excess of assets (excluding deferred

tax assets)over liabilities valued in

accordance with the Solvency UKrules.

This measure, excluding the impact of

economics, is a performance measure

included in the 2026 AIP scheme.

Solvency II surplus

The excess of Eligible Own Funds over

the Solvency Capital Requirement.

This is a performance metric in

the 2025 and 2026 LTIP grant.

Solvency Capital Requirements

(’SCR’)

Relates to the risks and obligations

to which the Group is exposed, and

is calibrated so that the likelihood of

a loss exceeding the SCR is less than

0.5% over one year. This ensuresthat

capital is sufficient to withstand a

broadly ’1-in-200-year event’.

Responsible investment/

investing

Considering environmental, social

and governance (‘ESG’) risks and

opportunities when deciding where to

invest money with the aim of achieving

better financial outcomes for investors.

At a high level, it’s looking at how a

company is managing ESG risks and

opportunities, how that could affect its

performance over the long term and if

needed, encouraging the company to do

better through stewardship. There are

different types of responsible investor.

Return on Capital (‘RoC’)

Reflects the Own Funds component

of the Operating CashGeneration (i.e.

the in-force and new business surplus

generation and group tax relief),

less financing costs plus recurring

management actions divided by Opening

Unrestricted Core Tier 1 Shareholder

Capital plus Deferred tax assets. At a

high level, this could be more simply

described as the operating growth in

Own Funds less financing costs/opening

Own Funds excluding debt. This is a LTIP

performance metric forthe 2024 grant.

Run-rate cost savings

The cumulative estimate of annual cost

savings achieved since the beginning

of 2024, expressed as the level of

savings expected to be generated over

a full 12-month period. Cumulative

run-rate cost savings is a performance

measure for the 2025 AIP scheme.

Science-based Targets

An emissions reduction target is defined

as ‘science-based’ if itisdeveloped

in line with the scale of reductions

required to keep global warming

below 2C from pre-industrial levels.

Scope 1, 2 and 3 emissions

Greenhouse gas emissions are

categorised into three groups

or‘Scopes’. Scope 1 covers direct

emissions e.g. use of natural gas,

company car vehicle emissions. Scope

2 covers indirect emissions from the

generation of purchased electricity,

steam and heating. Scope 3 includes

15 other categories of indirect

emissions in a company’s value chain

e.g. business travel and investments.

352 Standard Life plc Annual Report and Accounts 2025

Additional information

Solvency UK

Solvency II as modified by the

PRA’s 2024 reforms.

Standard formula

A set of calculations prescribed by the

Solvency UK rules for generating the SCR.

Standard Life

Assurancebusinesses

Standard Life Assurance Limited,

Standard Life Pensions Fund Limited,

Standard Life International Designated

Activity Company, Vebnet (Holdings)

Limited, Standard Life Lifetime

Mortgages Limited, Standard Life

Assets and Employee Services Limited

and Standard Life Investment Funds

Limited (together known as the Standard

Life Assurance businesses) acquired

by the Group on 31 August 2018.

Sterling overnight interest

average (‘SONIA’)

The average of the interest rates that

banks pay to borrow sterling overnight

from other financial institutions

and other institutional investors,

administered by the Bank of England.

Stewardship

The use of the rights and position of

ownership to influence the activity

or behaviour of investee companies.

For listed equities it includes both

engagement and (proxy) voting (including

filing shareholder resolutions). For

other asset classes, engagement is still

relevant while voting is not. Engagement

is a two-way interaction between the

investor and investees in relation to

corporate business and ESG strategies

with the goal of influencing issuers’

practices when needed to unlock value.

Sustainable investing

Investment approaches that select and

include investments on the basis that

they fulfil certain sustainability criteria

and/or deliver on specific and measurable

sustainability outcomes. Financial

returns remain the primary objective.

Task Force on Climate-related

financial disclosures(‘TCFD’)

The TCFD was created in 2015 by the

Financial Stability Board (‘FSB’), now

incorporated into the International

Sustainability Standards Board

(‘ISSB’), to develop consistent climate-

related financial risk disclosures

for use by companies in providing

information to stakeholders.

Task Force on Nature-related

financial disclosures(‘TNFD’)

A market-led, science-based and

government backed initiative, providing

organisations with a framework and

tools to report and act on evolving

nature-related issues. This includes

the LEAP methodology, to help

Locate, Evaluate, Assess, and Prepare

to act on nature-related issues.

TCS BaNCS

TCS BaNCS is a Life and Pensions

administration platform operated by

Tata Consultancy Services (‘TCS’).

The Pensions Regulator (‘TPR’)

A non-departmental public body

which regulates work-based pension

schemes in the United Kingdom.

Total cash generation (‘TCG’)

Cash remitted by the Group’s

operating companies to the Group’s

holding companies. Thismeasure is

included in the 2026 AIP scheme.

Total shareholder return (‘TSR’)

TSR is the total return, over a fixed

period, to an investor in terms of share

price growth and dividends (assuming

that dividends paid are re-invested,

on the ex-dividend date, in acquiring

further shares). Relative TSR is a LTIP

performance metric and is measured

against the constituents of the FTSE

350 (excluding Investment Trusts).

Transition risk

Climate-related risks associated with

the transition to a low carbon economy.

They include risks related to policy and

legal actions, market and economic

responses, technology changes and

reputational considerations.

UK Endorsement Board (‘UKEB’)

The UKEB was established following

the UK’s exit from the EU. The board’s

purpose is to endorse and adopt

new and amended international

accounting standards issued by the

IASB for use by UK Companies and

has responsibility for influencing the

development of those standards.

Unit-linked policy

A policy where the benefits are

determined by the investment

performance of the underlying

assets in the unit-linked fund.

Windfall gains

A windfall gain may arise if the Company

has experienced a significant anomalous

fall in its share price at the point of

granting LTIP awards so the recipient

received significantly moreshare than

in previous years, and this is followed by

a subsequent increase in share price at

the point of vesting that isnot wholly

attributable to Company performance.

With-Profits fund

A fund where policyholders are entitled

to a share of the profits of the fund.

Normally, policyholders receive their

share of the profits through bonuses.

Also known as a participating fund

as policyholders have a participating

interest in the With-Profit fund

and any declared bonuses.

2024 UK Corporate

GovernanceCode

The current version of the UK Corporate

Governance Code published by the

Financial Reporting Council setting

out guidance on standards of good

corporate governance practice in the

UK relating to issues such as board

composition and development,

remuneration, accountability, audit

and relations with shareholders.

353Standard Life plc Annual Report and Accounts 2025

Additional information

Forward-looking statements

The 2025 Annual Report and Accounts

contains, and the Group may make

other statements (verbal or otherwise)

containing, forward-looking statements

and other financial and/or statistical

data about the Group’s current plans,

goals, ambitions, outlook, guidance

and expectations relating to future

financial condition, performance, results,

strategy and/or objectives. Statements

containing the words: ‘believes’, ‘intends’,

‘will’, ’may’, ‘should’, ‘expects’, ‘plans’,

‘aims’, ‘seeks’, ‘targets’, ’continues’

and ‘anticipates’ or other words of

similar meaning are forward looking.

Such forward-looking statements and

other financial and/or statistical data

involve known and unknown risks and

uncertainty because they relate to

future events and circumstances that are

beyond the Group’s control. For example,

certain insurance risk disclosures are

dependent on the Group’s choices

about assumptions and models, which

by their nature are estimates. As such,

actual future gains and losses could

differ materially from those that the

Group has estimated. Other factors

which could cause actual results to

differ materially from those estimated

by forward-looking statements

include, but are not limited to:

• domestic and global economic,

political, social, environmental

andbusiness conditions;

• asset prices;

• market-related risks such as

fluctuations in investment yields,

interest rates and exchange rates, the

potential for a sustained low-interest

rate or high-interest rate environment,

and the performance of financial or

credit markets generally;

• the regulations, policies and actions

ofgovernmental and/or regulatory

authorities including, for example,

climate change and the effect of the

UK’s version of the ‘Solvency II’

regulations on the Group’s capital

maintenance requirements;

• developments in the UK’s relationship

with the European Union;

• the direct and indirect consequences

ofthe conflicts in Ukraine and the

Middle East for European and global

macro-economic conditions and

related or other geopolitical conflicts;

• political uncertainty and

instabilityincluding the rise

inprotectionist measures;

• the impact of changing inflation

rates(including high inflation)

and/ordeflation;

• information technology (including

developments and use of Artificial

Intelligence) or data security breaches

(including the Group being subject

tocyber-attacks);

• the development of standards and

interpretations including evolving

practices in sustainability and

climatereporting with regard to

theinterpretation and application

ofaccounting;

• the limitation of climate scenario

analysis and the models that

analysethem;

• lack of transparency and comparability

of climate-related forward-looking

methodologies;

• climate change and a transition to a

low carbon economy (including the

riskthat the Group may not achieve

itstargets);

• the Group’s ability along with

governments and other stakeholders

to measure, manage and mitigate the

impacts of climate change effectively;

• the implementation of rules,

regulations or other actions with an

opposing stance to sustainability

matters or policies;

• market competition;

• changes in assumptions in pricing

andreserving for insurance business

(particularly with regard to mortality

and morbidity trends, gender pricing

and lapse rates);

• the timing, impact and other

uncertainties of any acquisitions,

jointventures, disposals or other

strategic transactions (including any

associated integration);

• risks associated with arrangements

with third parties;

• inability of reinsurers to meet

obligations or unavailability of

reinsurance coverage; and

• the impact of changes in capital and

implementing changes in IFRS 17 or

anyother regulatory, solvency and/or

accounting standards, and tax laws

andpractices and other legislation

andregulations in the jurisdictions in

which members of the Group operate.

As a result, the Group’s actual future

financial condition, performance and

results may differ materially from the

plans, goals, targets, ambitions, outlook,

guidance and expectations set out in the

forward-looking statements and other

financial and/or statistical data within

the 2025 Annual Report and Accounts.

No representation is made that any of

these statements will come to pass or

that any future results will be achieved.

As a result, you are cautioned not to

place undue reliance on such forward-

looking statements contained in this

2025 Annual Report and Accounts.

The Group undertakes no obligation

to update any of the forward-looking

statements or data contained within the

2025 Annual Report and Accounts or

any other forward-looking statements

or data it may make or publish. The

information in this report does not

constitute an offer to sell or an invitation

to buy securities in Standard Life plc or

an invitation or inducement to engage

in any other investment activities.

The 2025 Annual Report and Accounts

has been prepared for the members

of the Company and no one else.

TheCompany, its Directors or agents do

not accept or assume responsibility to

any other person in connection with this

document and any such responsibility

or liability is expressly disclaimed.

Nothing in the 2025 Annual Report

and Accounts is or should be construed

as a profit forecast or estimate.

Caution about climate and

sustainability related disclosures

Climate and sustainability disclosures

in the 2025 Annual Report and

Accounts use a greater number and

level of judgements, assumptions and

estimates, including with respect to

the classification of climate related

activities, than the Group’s reporting of

historical financial information. These

judgements, assumptions and estimates

are highly likely to change over time,

and, when coupled with the longer time

frames used in these disclosures, make

any assessment of materiality inherently

uncertain. In addition, the Group’s climate

risk analysis and net zero transition

planning will continue to evolve and the

data underlying the Group’s analysis

and strategy remain subject to change

over time. As a result, the Group expects

that certain climate and sustainability

disclosures made in the 2025 Annual

Report and Accounts are likely to be

amended, updated, recalculated or

restated in the future. Please also refer

to the 2025 Sustainability Report and the

cautionary statements contained therein.

354 Standard Life plc Annual Report and Accounts 2025

Additional information

Notes

355Standard Life plc Annual Report and Accounts 2025

Notes continued

356 Standard Life plc Annual Report and Accounts 2025

Additional information

Registered address

Standard Life plc

20 Old Bailey

London

England EC4M 7AN

Registered number: 11606773

standardlifeplc.com