QBE’s updated Environmental and Social Risk Framework permits continued insurance underwriting of new and expansionary oil and gas projects, and the companies developing them, without restriction until:
(a) at least 2029 for companies deriving >60% revenue from oil and gas extraction, and
(b) at least 2040 for companies deriving >30% revenue from oil and gas extraction,
after which services may be declined if a customer is assessed as ‘low transition maturity’. This leaves a long runway for insuring expansion.

By contrast, several domestic and international peers have introduced stronger policy restrictions on new oil & gas projects and companies, creating peer-positioning and reputational implications for QBE.

For example:
a) Allianz: Since 2023, Allianz has restricted new or renewed single-site/stand-alone P&C commercial insurance policies/coverages in exploration and development of new oil and gas fields, construction of new midstream infrastructure related to oil, and construction of new oil power plants. It also has company restrictions requiring commitment net-zero GHG by 2050, in alignment with science-based 1.5 degree pathways, across all three GHG emissions scopes for companies with the largest hydrocarbon production. Allianz uses credible, independent third-party sources such as the Transition Pathway Initiative and the Climate Action 100+ Net Zero Company Benchmark to assess the commitment.
b) Aviva: Aviva does not offer insurance for the development of new or expansion of existing oil or gas fields.
c) AXA: AXA will not provide new stand-alone, site-specific insurance policies for upstream greenfield oil and gas exploration or upstream development projects licensed after 31 December 2021. Underwriting restrictions apply to all lines of business for stand-alone insurance policies and facultative reinsurance (except for employee benefits and treaty reinsurance). Exceptions may be granted to companies with climate transition plans in place. A climate transition plan is a time-bound action plan that clearly outlines how an organization will pivot its existing assets, operations, and entire business model towards a trajectory that aligns with the latest and most ambitious climate science recommendations.
d) Zurich: To the extent permissible under law or regulation, Zurich excludes new single-site P&C insurance policies for new (upstream) oil and gas exploration and development projects, for sites where licences were approved after 31 December 2022.
e) IAG: IAG says it is in the process of phasing out underwriting for entities that are predominantly in the business of either: extracting fossil fuels, and/or generating power from fossil fuels.
f) Suncorp: Since 1 January 2025, Suncorp does not directly underwrite (new policies or renew existing policies) for companies with more than 10% revenue from oil and gas exploration and production.

Further, unlike some Australian financial institutions that disclose the criteria they apply when assessing client transition plans and explicitly rule out financing to clients that fail to meet expectations, QBE discloses limited detail about its “transition maturity” assessment and makes no concrete commitment to decline underwriting where customers do not meet those criteria.

Why governance disclosure is needed
The underwriting profit opportunity in oil and gas lines can create potential incentive misalignments between group and divisional levels. For example, premium growth goals may not be aligned with QBE’s broader strategic and reputational considerations. The proposed resolution therefore asks QBE to assess and disclose whether such potential misalignments exist between the incentives of the underwriting divisions exposed to new or expansionary oil and gas, and the broader interests of the company; what governance mechanisms (e.g., conflicts registers, committee oversight, independent advice, recusal protocols) are in place to identify and manage them, and whether those mechanisms are sufficient for the Board to satisfy itself that decisions on oil and gas insurance underwriting policy are made in the best interests of the company.
Investors also expect a clear explanation of how the Board identifies, evaluates and manages potential misalignment of interests where policy decisions could directly affect counterparties on whose boards QBE directors also serve. There are concerns that this has not been appropriately managed by QBE.

QBE director and incoming Chair, Ms Yasmin Allen, has also been serving on the board of Santos, a company that could be directly impacted by QBE’s oil and gas insurance underwriting policy settings. At QBE’s 2025 AGM, in response to investor questioning, Ms Allen confirmed she does not recuse herself from board-level discussions about QBE’s oil and gas policy. This raises questions about whether the company’s governance structures are equipped to manage misalignment of interests created by interlocking directorates.

We acknowledge that board composition evolves. The announced transition to appoint Ms Yasmin Allen as QBE Chair (effective 8 May 2026) coincides with her retirement from the Santos board (effective 21 Feb 2026). However QBE’s Environmental and Social Risk Framework was updated in 2025 when Ms Yasmin Allen served on both boards. The resolution focuses on the enduring principle that any board interlocks be identified and managed with transparency and rigor.

The requested disclosures are policy and process focused. They do not require disclosure of specific counterparties. They provide investors decision useful assurance that divisional incentive misalignment and board interlocks are appropriately managed in the best interests of our company. Transparent governance is particularly important in this context where QBE’s oil and gas underwriting approach grants longer eligibility for insuring expansion than many peers and has the potential to be inconsistent with the broader interests of the company. We therefore urge shareholders to vote  FOR Resolution 3.