Apollo Group – Section 172 statement

The AGHL Board has identified the following key stakeholders: capital providers to the Managed Syndicates, Apollo employees, the shareholders of AGHL, Lloyd’s and regulators, policyholders and brokers.

Throughout the year the AGHL Board considered the wider impact of strategic and operational decisions on its stakeholders. Examples include the development and execution of the business plans for the Managed Syndicates; the assessment and raising of capital; communications with capital providers; and changes to board composition. The AGHL Board considers that the interests of all stakeholders were aligned for these decisions.

The support and engagement of capital providers of the managed syndicate’s is imperative to the future success of our business. There are regular meetings with capital providers and members’ agents throughout the year to discuss the performance and future prospects for the syndicates which they support. Feedback received during these meetings enables the Board to factor the views of these key stakeholders into the development of business plans for future years.

Developing and maintaining relationships with brokers and policyholders is central to the success of the Managed Syndicates. Underwriters travel widely with our broking partners to visit clients and attend industry events to promote the syndicates and the Lloyd’s brand and to ensure we continue to provide an excellent service to our policyholders. In developing insurance propositions and marketing them with our broking partners and in settling claims, we always seek to ensure fair customer outcomes and provide products that deliver value.

We maintain open and transparent relationships with our regulators and Lloyd’s, which are managed through our compliance team. Regular meetings are held with representatives of Lloyd’s and the PRA and significant regulatory engagements are reported to the Board.

Apollo’s stated purpose is “Enabling a resilient and sustainable world”. Through 2024 we continued our work to develop and document our ESG principles and standards and assess our current business model against these standards. There is a defined referral process for underwriting risks to adhere to our ESG appetite and manage potential reputational risk. ESG considerations are integrated into the design of the investment strategy and asset allocation decisions, and ongoing attention given to staff engagement, particularly around Diversity, Equity & Inclusion (‘’DEI’’). Further work on ESG activities will continue through 2025.

We have put in place arrangements to assist in managing the financial risks and opportunities associated with the effects of climate change and to ensure that adequate oversight and control of this area in relation to underwriting, reserving, investment management and operations. The business meets the requirements for PRA Supervisory Statement 3/19. Whilst the Chief Risk Officer retains overall accountability for coordinating the approach and effectiveness within The Group, the responsibility is allocated to relevant managers of each business area. Further developments to ensure management of the risks and opportunities will continue through 2025.

Employee matters

Our business is built on the talent and dedication of our people. Attracting, retaining, and nurturing talent is essential to our success. We are committed to creating a work environment where employees feel engaged through communication, acknowledgment and ongoing growth opportunities. We promote diversity, equity, inclusion, and mental health and wellbeing so all staff feel valued, supported, and able to perform at their best. We live our values by fostering collaboration, innovation, and ethical behaviour throughout. The behaviours Framework embeds clear expectations for employees, managers, and leaders, ensuring alignment with our values in daily actions. The employee-led DEI Committee drives various initiatives which focused in 2025 on ethnicity and neurodiversity, alongside broader efforts to promote inclusion through awareness campaigns and employee discussions. Through hybrid working, regular engagement surveys, and open forums like town halls, we promote flexibility while maintaining strong
connections across teams. This approach supports an inclusive culture built on trust, respect, and shared accountability. Apollo is committed to providing equal opportunities for all employees, including those with disabilities. Recruitment processes are designed to ensure fair consideration based on skills and abilities. If an employee becomes disabled during their time with us, we make every effort to support them through appropriate workplace adjustments and retraining opportunities. Apollo’s people practices remain highly competitive in the London Insurance Market, providing compensation, benefits, and terms designed to attract and retain diverse talent. A key focus is on ensuring our employees perform at their best with opportunities to enhance their skills, to develop capabilities and advance their careers within Apollo. This is fundamental to our culture and business strategy.

Business operations

The Group continues to strive to maintain a lean and efficient operating model by leveraging advanced technology and strategic outsourcing arrangements, ensuring flexibility and scalability to meet evolving business demands. In 2025, we welcomed a new Chief Information Officer to our executive team, further strengthening our leadership in driving innovation and operational excellence. We have prioritised enhancements across claims, pricing, and underwriting, streamlining processes to boost efficiency and effectiveness while upholding the exceptional standards of service our stakeholders expect. Our hybrid working environment continued to thrive in 2025. Employees remain highly productive with seamless access to business systems both remotely and in-office.
Aligned with the FCA’s and PRA’s Operational Resilience policies, Apollo has maintained its disciplined approach to ensuring robust plans are in place to prevent, respond to, and recover from operational disruptions. In 2025, we placed particular emphasis on enhancing cybersecurity measures as part of our broader commitment to protecting customers’ interests and safeguarding business integrity. In addition to improving network security, a dedicated Information Security Manager has been recruited. Work has also commenced to align to ISO27001 and the National Institute of Standards and Technology. This is due to be completed during 2026.

Environmental, social and governance

Apollo’s Board approved Environmental, Social and Governance (ESG) strategy was reviewed in September 2025. The Apollo Board drives the strategy, which is aligned with our vision statement and
purpose; “Enabling a resilient and sustainable world”. Apollo’s ESG Committee reports directly to the Executive Committee and coordinates ESG-related activities within Apollo. The ESG Committee’s mandate is set out within Apollo’s ESG Policy, but at a
high-level seeks to identify areas of improvement and to ensure progress against the ESG strategy as
approved by the Board. Apollo is committed to a long-term sustainable approach to protecting the environment, balancing environmental considerations and social responsibility within our overall business goals. Apollo’s underwriting and investment practices are governed by ESG risk appetites and are reviewed at least annually. Apollo is also working to identify new opportunities that support the transition to a low carbon sustainable economy.

The ESG strategy is reviewed by the Board annually. During 2025, our key achievements have included:

•  Evolving Apollo’s approach to managing ESG risks in the underwriting process through
  enhancements to the Contentious Risks Procedure,
• Calculating Apollo’s baseline insurance-associated emissions through the Partnership for Carbon
  Accounting Financials (“PCAF”),
• Setting up a commuting survey to increase the accuracy of our GHG emission calculations,
• Continuing to ensure we avoid investing in sectors that do not align with the ESG risk appetites,
  and
• Submitting our first Energy Savings Opportunity Scheme (“ESOS”) report and action plan

At Apollo our people are at the heart of everything we do. We operate a zero-tolerance policy to bullying, harassment, and discrimination. This applies not only to the protected characteristics set out in the Equality Act of 2010, but also to neurodiversity, parental and caring responsibilities, socio economic status, and working patterns. Apollo is dedicated to fostering a diverse, equitable, and inclusive workplace, with a focus on inclusive hiring practices. We are proud sponsors and supporters of Lloyd’s market inclusion networks. As such, we have implemented inclusion initiatives and have a comprehensive Diversity, Equity, and Inclusion (DEI) strategy in place. Employees have access to mental health and wellbeing resources through independent partners, as well as additional support through private medical services. Apollo monitors gender and racial diversity metrics, employee satisfaction, and governance related metrics. This information is used by the AGHL Board to track progress against the ESG Strategy. From an environmental perspective, Apollo Group’s carbon footprint is monitored across different types of emissions sources, and we have separately aligned with GHG emissions protocol scopes 1 and 2 and several scope 3 categories (which cover purchased goods and services, fuel and energy-related activities, waste generated in operations, employee commuting, and upstream leased assets). GHG emissions currently exclude our scope 3 underwriting emissions as we look to advance the accuracy of our calculations. Our Scope 1 and 2 GHG emissions are reported to UK Companies House under the Streamline Energy and Carbon Reporting framework.