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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
1
.
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
1
.
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
8%
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
1
.
In2025 72% of Standard Life logins
were via the app, up from 66% in 2024.
Read more on our website
Read more in the
Sustainability Report
£1k
single flat initial fee for
advice regardless of your
pension pot size
2
Social impact target
In 2026 we committed to help three
million more customers achieve
better retirement outcomes over the
next 10 years. By providing support
and solutions we will ensure more
people are on track to be financially
secure in later life. Thistarget
provides a clear strategic focus,
reinforcing our commitment to
prioritise the actions which will drive
meaningful change for our customers.
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
7
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
2
in the
carbon intensity of our listed
equity and debt credit portfolio
relative to our 2019 baseline.
2019 2025
105
tCO
2
e/£m
44
tCO
2
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
1
.
Opportunities for
better returns
Our long-term ambition is to invest up
to £40 billion in sustainable, transition
and UK-focused productive assets
3
.
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 our Net Zero
Transition Plan
Read more on the FGC website
In total FGC aims to deploy
£10–20bn
of investor funds
into private markets
over the next decade
1. EVIC intensity metric. 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.
2. EVIC intensity metric. Relative to 2019 baseline, where we exercise influence and control.
3. Where market and regulatory conditions allow and it’s in customers’ best interests.
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
1
.
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
recommended policy solutions.
Empowering
our customers
and driving
change
We are committed to 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.
KPIs
12m
customers
(2024:12m)
£317bn
total assets under
administrationAPM
(2024: £292bn)
Sir Nicholas Lyons
Chair of the Group Board
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
2
, 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
1
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
1
.
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
2
. 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
2
(2024: +60)
70%
Expected growth in long-term
savings and retirement market
over the next decade
1
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
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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
1
.
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
2
c.10% take
financial advice
3
Workers have
multiple pension pots
Individuals want
simplicity and
control of income
Workplace
Retail
c.£80bn
annual market flows
4
c.£150bn
annual market flows
5
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
6
c.£8–9bn
annual market flows
8
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
7
.
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 Pensions
andSavings on pages 24 to 25
See Our strategic priorities
onpages 28 to 35
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
1
2
4
3
1.
2.
3.
4.
Pensions and Savings
£396m
Retirement Solutions
£879m
Europe and Other
£123m
With-Profits
£76m
1.
2.
3.
4.
1
2
4
3
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’)
1
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
1
Top-10 player
2
£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
3
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
1.
2.
3.
4.
1
2
4
3
Pensions and Savings
£212bn
Retirement Solutions
£42bn
Europe and Other
£28bn
With-Profits
£35bn
1
2
4
3
1.
2.
3.
4.
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
2
Top-5 player
1
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 30 to 31
Read more on pages 32 to 33
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
1
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
1
.
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
2
, 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
1
,
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
2
.
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
1
, 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
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%
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%
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
2
e/£m
52 tCO
2
e/£m
62 tCO
2
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
33
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
£1,474m £1,403m +5%
Total cash generation
1
£1,711m £1,779m -4%
Solvency II capital Group Solvency II surplus £3.6bn £3.5bn +2%
Group Shareholder Capital Coverage Ratio
1
176% 172% +4%pts
Solvency II leverage ratio
1
33% 36% -3%pts
IFRS Adjusted operating profit
1
£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
1
£3,098m £3,656m -15%
Assets Assets under administration
1
£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
74
75
129
131
76
1,403
1,146
1,474
With-Profits
Corporate Centre
FY2024FY2023 FY2025
474
378
629
563
316
190
144
96
83
41
10
389
24
(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
11
17
19
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
2
(2024: £15.4 billion
1
)
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
2
(2024: £18.7 billion
1
), 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
2
strong (£bn) Retail flows
2
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
1
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
1
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
2
1,117 1,012
Operating Cash Generation 1,474 1,403
Non-operating cash generation 237 376
Total cash generation
1
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
2
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
1
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
2
(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
1
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
1
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
2
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
22
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.
3m
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
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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
1
81%
reduction and carbon neutral
in our operational absolute
emissions achieved
2
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
2
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
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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
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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
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
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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
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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
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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
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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
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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
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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
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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
2
.
• Experienced a 42% reduction in
absolute emissions across our
investment portfolio relative to the
baseline, from 24.6 MtCO
2
e (YE2019)
to14.3 MtCO
2
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
2
e at YE2025
(vs97MtCO
2
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)
1
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
2
14.3^
-42%
+7%
20232021 2024 2025
Real estate
Illiquid credit
Equity release mortgages
Listed credit
Listed equity
Sovereign debt
25
20
15
10
5
MtCO
2
e
250
200
150
100
50
tCO
2
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%
52
2
44^
73
2
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
2
e
(YE2019) to 14.3 MtCO
2
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
2
e (YE2024)
2
to 14.3 MtCO
2
e^
(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
2
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
2
e to 13.4 MtCO
2
e, driven by absolute emissions
of listed equity increasing from 4.3 MtCO
2
e to 4.7 MtCO
2
e and listed credit increasing from 1.5 MtCO
2
e to 2.0 MtCO
2
e.
Economic emissions intensity of the assets in scope of 2030 target increased from 72 tCO
2
e/£m to 73 tCO
2
e/£m, driven
by listed equity and credit increasing from 51 tCO
2
e/£ to 52 tCO
2
e/£m (due to listed equity increasing from 47 tCO
2
e/£m
to 49 tCO
2
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
1
22
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
90
80
70
60
50
40
30
20
10
%
28%
25%
22%
13%
24%
22%
27%
9%
12%
18%
Industrials
Energy
Financials
Materials
Other
2024 2025
21%
11%
22%
21%
10%
29%
31%
15%
27%
13%
100
80
60
40
20
%
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
2
e at YE2024 to 99
MtCO
2
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
1
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
1
. 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
2
1.9
1.5
5.6
0.6
9
46
53
42
1
6
0 1 3 4 5
Holding count
6
5
4
3
2
1
60
50
40
30
20
10
% 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-
35
30
25
20
15
10
5
% 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
2
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
1
Absolute energy consumption in GWh
Consumption (GWh)
1
from: 2025 2024
3
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
2
e
Emissions
2
(tCO
2
e) from:
2025 2024
3
(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
3
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
4
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
2
e to 2,887
tCO
2
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
2
e/FTE
20202019 20222021 2023 2024 2025
-3%
tCO
2
e/FTE
2.0
1.5
1.0
0.5
1.7
-67%
0.57
0.59
20202019 20222021 2023 2024 2025
kgCO
2
e/m
2
56
59
101
-45%
-5%
120
150
100
50
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
2
e (YE2024)
(restated) to56,099 tCO
2
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
2
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
2
e/m
2
)
28^ 56 34 59
Scope 1 and 2 emissions from occupied
premises per full-time equivalent
employee (tCO
2
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
2
) 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
2
e (YE2024) to
0.28 tCO
2
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
2
)
(location-based) decreased slightly from
59 tCO
2
e/m
2
in YE2024 to 56 tCO
2
e/
m
2
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
2
e
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%
74
72
65^
101
tCO
2
e/£m
120
90
60
30
20232022 20252024
Emissions intensity
(Scope 3 emissions – categories 1 and 2 on a per £ spend intensity)
20232022
70
9 9
52
57
48
-33%
47^
36
11
8
6060
20252024
80,000
70,000
60,000
50,000
40,000
30,000
20,000
10,000
tCO
2
e
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
2
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
2
e/£m), relative to the baseline, from
101 tCO
2
e/£m (YE2022) to 65 tCO
2
e/£m^
(YE2025); and a 33% reduction in the
absolute supplier base total emissions
(tCO
2
e), relative to thebaseline, from
69,861 tCO
2
e (YE2022) to 47,116 tCO
2
e^
(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
1
Female 7 58%
Male 5 42%
Senior managers
2
Female 28 43%
Male 37 57%
All employees
3
Female 2,726 49%
Male 2,793 51%
Senior managers and
theirdirectreports
4
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
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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
1
, 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 97
Board performance review
The 2025 Board performance review was facilitated externally.
Read more on pages 106 to 107
Compliance with the 2024 UK Corporate Governance Code
Read more on page 92
Group Board education sessions
Read more on pages 108 to 109
Group Board engagement with the wider workforce
Through Maggie Semple, Designated Non-Executive Director
forWorkforce Engagement (‘DNED’).
Read more on pages 104 to 105
Culture
The Big Three and how the Group Board assesses and monitors culture.
Read more on pages 98 to 99
Management of conflicts of interest
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:
N
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
A
Audit
N
Nomination
Re
Remuneration
Ri
Risk
S
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:
N
Re
Ri
S
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
1
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
1
. 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:
A
Ri
N
Re
Chair of the Group Board and Life
Companies Board Risk Committees
Committee:
A
Ri
Committee:
Re
N
Chair of the Group Board
RemunerationCommittee
Committee:
Ri
S
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:
Re
S
Designated NED for
WorkforceEngagement (‘DNED’)
Committee:
A
N
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
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
1
7/7 – 6/7 7/7 7/7 5/5
Siobhan Boylan
2
3/3 – – – – –
Eleanor Bucks
3
7/7 3/3 5/5 – – –
Karin Cook
4
3/3 – 3/3 – – 2/2
Sherry Coutu
5
4/5 – – 5/5 3/3 –
Mark Gregory
6
7/7 8/8 7/7 – 7/7 –
Hiroyuki Iioka 7/7 – – – – –
Katie Murray 7/7 8/8 – – 7/7 –
Belinda Richards
7
4/4 – 4/4 4/4 – –
David Scott
8
4/4 – – – – –
Maggie Semple 7/7 – – 7/7 – 5/5
Nicholas Shott
9
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.
O
E
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.
O
Received a deep dive
onthe Group’s ongoing
migrations.
Oversight of the Group’s migration
programme and movement to Wipro.
E
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.
E
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.
G
E
Q2 Outcome
Hosted the Group’s AGM. Delivered effective shareholder
engagement and developed
relationships ahead of the 2025
Remuneration Policy review.
G
E
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.
G
O
E
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.
O
E
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.
G
O
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.
G
O
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.
G
O
E
Approved the
Consumer Duty
Annual Assessment.
Reinforced customer-centric
compliance culture.
O
E
Approved the ORSA. Enhanced risk management
andcapital planning.
O
Q4 Outcome
Approved the Strategic
Financial Business
Planand Annual
Operating Plan.
Confirmed forward-looking
financialresilience.
G
O
E
Approved a new
CapitalRisk Appetite
Framework.
Ensuring appropriate risk appetite.
O
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.
G
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.
G
Strategic priorities key
G
Grow
O
Optimise
E
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
G
O
E
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
O
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
G
E
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
G
O
E
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
G
O
E
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
G
E
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
G
O
E
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
O
E
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
E
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
G
O
E
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
G
O
E
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
O
E
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
O
E
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
G
O
E
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
G
O
E
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
G
O
E
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
G
O
E
Strategic priorities
G
Grow
O
Optimise
E
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
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
2
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)
7
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
1
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
2
of
ExCo
Number of total
employees
2,3
Percentage
oftotal
employees
As at 13 March 2026
1
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
1
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
90
Executive Director who is a Committee Chair or
has two Committee memberships
24
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
50
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
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
1
(including Shareholder
Nominated Directors)
Male (5) 42
%
Female (7) 58
%
Board ethnicity
1
(including Shareholder
Nominated Directors)
White British/English (6) 50%
White Irish (2) 1
7%
White Scottish (1)
8%
White Canadian (1)
8%
Asian (Japanese) (1)
8%
Black (Caribbean) (1)
8%
Non-Executive
Director tenure
1
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)
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
60
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
1
25 August 2025 3/3 100%
Nicholas Shott
2
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)
8
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
1
13 September 2024 6/7 86%
Belinda Richards
2
1 October 2017 4/4 100%
Eleanor Bucks
3
12 May 2025 5/5 100%
Karin Cook
4
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)
7
128 Standard Life plc Annual Report and Accounts 2025
Corporate governance
Q1
Risk Committee reporting cycle
Q2
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
1 April 2025 1/1 100%
Karin Cook
2
25 August 2025 1/1 100%
Belinda Richards
3
1 January 2024 1/1 100%
Maggie Semple 1 January 2024 2/2 100%
Nicholas Shott
4
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)
2
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
1 December 2020 3/3 100%
Maggie Semple 1 September 2022 5/5 100%
Karin Cook
2
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)
5
133Standard Life plc Annual Report and Accounts 2025
Corporate governance
Sustainability Committee report
Q1
Sustainability Committee reporting cycle
Q2
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
1 May 2025 5/5 100%
Nicholas Shott
2
20 October 2016 4/4 100%
Karen Green 1 July 2017 7/ 7 100%
Belinda Richards
3
2 July 2019 4/4 100%
Maggie Semple OBE 1 January 2024 7/ 7 100%
Mark Gregory
4
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)
7
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%
Q1
Remuneration Committee review cycle
Q2
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
90
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
2%
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
3%
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%
100%
100%
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%
100%
50%
0%
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
3
Pension
4
Total
fixed pay
Annual
incentive
5
Long-term
incentives
6,7
Total
variable pay Total
£000 2025 2024 2025 2024 2025 2024 2025 2024 2025 2024 2025 2024
7
2025 2024
7
2025 2024
7
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 (%)
1
86.0% 88.0% 90.0% 88.4% 5.0% 3.0%
Customer Satisfaction – Digital (%)
2
92.0% 94.0% 96.0% 93.3% 5.0% 1.6%
Claims Experience (% in SLA)
3
89.0% 92.0% 95.0% 94.7% 5.0% 4.7%
Service Experience (% in SLA)
4
90.0% 93.0% 96.0% 93.8% 5.0% 3.2%
Complaints Volume per 1,000 Customers
5
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
5
Sustainable Multi Asset funds
into SDR
6
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
1
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
2
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.
3
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.
3
Decarbonisation
– Operations
Target range of 75% to 85%
reduction pre-offset, plus net
zero post-offset.
n/a n/a
Relative TSR
4
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
1
Vesting date
Performance
measures
1
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
1
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
1
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)
1
Shareholding
held as at 31
December 2025
(% of salary)
2
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
1
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
2
– – – – – –
Eleanor Bucks
3,11
117 96 1 5 118 101
Karin Cook
4,11
60 – 6 – 66 –
Sherry Coutu
5
73 – 4 – 77 –
Mark Gregory
6,11
160 133 – 4 160 137
Hiroyuki Iioka
7
– – 1 8 1 8
Katie Murray 113 108 – 3 113 111
Belinda Richards
8
87 134 1 4 88 138
David Scott
9
– – 3 2 3 2
Maggie Semple 132 142 1 3 133 145
Nicholas Shott
10
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
50
£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’)
1
2025 Andy Briggs 4,866 84.8% 68.4%
2024 Andy Briggs 3,610
1
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
2
2020 Andy Briggs
3
1,706 83% 0.0%
4
Clive Bannister
3,5
321 81% n/a
6
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
1
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
2
1100 n/a
3
– – – 2897 n/a
3
– – – 1133 n/a
3
– – –
Non-Executive Chair
Sir Nicholas Lyons 8.1 1,100 (87.5) (17.1) 13.8 8.8 n/a
3
(100) 897.6 0.0
n/a
5
n/a
5
Non-Executive Directors
4
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
3
– – – –
Eleanor Bucks 22.3 n/a
3
– – – (83.4) n/a
3
– – –
Karin Cook n/a
3
– – – – n/a
3
– – – –
Sherry Coutu n/a
3
– – – – n/a
3
– – – –
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
3
0.0 0.0 0.0
Katie Murray 4.7 0.7 45.4 n/a
3
– (95.2) 124.1 (3.3) n/a
3
–
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
3
– – –
Maggie Semple (6.5) 10.4 102.8 n/a
3
– (53.8) 28.6 106.4 n/a
3
–
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
1
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
2
14 August 2025 1 May 2027
2
1
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
54
65
35
42
50
58
51
8
10
2.6
2.9
62
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%
97%
3%
3%
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.
207Annual Report and Accounts 2025
Financials
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
Financials
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
209Annual Report and Accounts 2025
Financials
Standard Life plc
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
211Annual Report and Accounts 2025
Financials
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.
212 Annual Report and Accounts 2025
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Standard Life plc
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
213Annual Report and Accounts 2025
Financials
Standard Life plc
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
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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
Financials
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
Financials
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
Financials
Standard Life plc
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
Financials
Standard Life plc
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
Financials
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
Financials
Standard Life plc
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
Financials
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
Financials
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
Financials
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
Financials
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
Financials
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
Financials
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

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
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.