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Nucleus Life AG Solvency and Financial Condition Report for the financial year ended 31 December 2018 Nucleus Life AG l Bangarten 10 l FL-9490 Vaduz l Liechtenstein Tel +423 399 10 90 l Fax +423 399 10 97 l [email protected] l www.nucleus.li
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Page 1: Nucleus Life AG Solvency and Financial Condition Report Nucleus Life AG SFC… · Nucleus Life AG Solvency and Financial Condition Report for the financial year ended 31 December

Nucleus Life AG

Solvency and Financial Condition Report

for the financial year ended 31 December 2018

Nucleus Life AG l Bangarten 10 l FL-9490 Vaduz l Liechtenstein Tel +423 399 10 90 l Fax +423 399 10 97 l [email protected] l www.nucleus.li

Page 2: Nucleus Life AG Solvency and Financial Condition Report Nucleus Life AG SFC… · Nucleus Life AG Solvency and Financial Condition Report for the financial year ended 31 December

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Contents Executive Summary ................................................................................................................................. 4

A. Business and performance .......................................................................................................... 6

A.1 Business and external environment ........................................................................................ 6

A.1.1 Name and legal form of the undertaking ........................................................................ 6

A.1.2 Name of the responsible Supervisory Authority ............................................................. 6

A.1.3 Name of the external auditors ........................................................................................ 6

A.1.4 Holders of qualifying holdings in the undertaking .......................................................... 6

A.1.6 Lines of business and geographical areas ....................................................................... 6

A.2 Underwriting performance ..................................................................................................... 7

A.3 Performance from investment activities ................................................................................. 8

A.4 Expenses .................................................................................................................................. 8

B. System of governance ................................................................................................................. 9

B.1 General governance arrangements ......................................................................................... 9

B.1.1 System of Governance ..................................................................................................... 9

B.2 Fit and proper ........................................................................................................................ 10

B.3 Risk management system ...................................................................................................... 11

B.4 Own Risk and Solvency Assessment ...................................................................................... 12

B.5 Internal control system ......................................................................................................... 12

B.6 Internal audit function........................................................................................................... 12

B.7 Actuarial function .................................................................................................................. 13

B.8 Outsourcing ........................................................................................................................... 13

C. Risk profile ................................................................................................................................. 14

C.1 Underwriting risk ................................................................................................................... 14

C.2 Market risk............................................................................................................................. 14

C.3 Credit risk .............................................................................................................................. 15

C.4 Liquidity risk .......................................................................................................................... 15

C.5 Operational risk ..................................................................................................................... 16

D. Valuation for solvency purposes ............................................................................................... 18

D.1 Assets ..................................................................................................................................... 18

D.2 Technical provisions .............................................................................................................. 18

D.2.1 Key assumptions ............................................................................................................ 19

D.2.2 Technical provision calculation methodology ............................................................... 20

D.3 Other liabilities ...................................................................................................................... 20

E. Capital management ................................................................................................................. 21

E.1 Own funds ............................................................................................................................. 21

Page 3: Nucleus Life AG Solvency and Financial Condition Report Nucleus Life AG SFC… · Nucleus Life AG Solvency and Financial Condition Report for the financial year ended 31 December

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E.2 Solvency Capital Requirement and Minimum Capital Requirement ..................................... 21

Annexures: Quantitative Reporting templates ................................................................................. 23

Balance Sheet .................................................................................................................................... 24

Premiums, claims and expenses by line of business ......................................................................... 26

Premiums, claims and expenses by country ..................................................................................... 27

Life & Health Technical Provisions .................................................................................................... 28

Own funds ......................................................................................................................................... 29

Solvency Capital Requirement .......................................................................................................... 31

Page 4: Nucleus Life AG Solvency and Financial Condition Report Nucleus Life AG SFC… · Nucleus Life AG Solvency and Financial Condition Report for the financial year ended 31 December

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Executive Summary

Nucleus Life AG (“the Company”) is a life insurance company domiciled in Vaduz, Liechtenstein, and

regulated by the Financial Market Authority (FMA) Liechtenstein.

Business and performance

The Company writes mainly single premium Deposit-Linked business, targeting high net worth clients

and the mass-affluent market. It focuses on Germany where it sells policies local compliant products,

and international business (written according to Liechtenstein law), but also writes some business in

Austria, Belgium, Sweden and Norway.

Gross booked premiums in 2018 amounted to CHF 6’674’547 (2017: CHF 16’987’044), while the loss

for the year came to CHF 631’679 (2017: CHF 189’431).

System of Governance

The Board of the Company considers the system of governance to be adequate and proportionate to

the nature, scale and complexity of the risks inherent in its business.

The Company ensures that all persons, who effectively run the Company or fulfill other key functions,

are fit to provide sound and prudent management through their professional qualifications,

knowledge and experience, and are proper by being of good repute and integrity.

The Company’s system of governance has been designed around a Risk Management framework

together with the controls and processes. It employs the “three lines of defense” governance model:

▪ 1st Line of Defence: Management and staff

▪ 2nd Line of Defence: Risk management & Compliance (Oversight)

▪ 3rd Line of Defence: Internal Audit (Assurance)

It performs an Own Risk and Solvency Assessment (ORSA) at least once year, during which all risks

inherent to its business are assessed and the corresponding capital needs determined. As part of the

ORSA, “stress scenarios” are considered as well.

Its internal control system consists of four elements:

▪ Supervisory Board

▪ Compliance and Risk Management

▪ Internal Audit

▪ Controls over Outsourced Activities

The governance structure of the Company has not changed materially in the year to 31 December

2018.

Risk profile

The Company mainly assumes Deposit-Linked business whereby the policyholder bears the financial

risk. In accordance with the Prudent Person principle, the Company only invests policyholder funds in

assets and instruments the risks of which it can properly identify, measure, monitor, manage and

control. Shareholder assets are only invested in secure, non-volatile assets.

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The key risks the company are exposed to are the following:

▪ Lapse risk

▪ Inadequate new business risk

▪ Currency risk

▪ Liquidity risk

▪ Litigation risk

▪ Operational risk

Valuation for solvency purposes

As at 31 December 2018, the assets and liabilities of Company based were as follows:

Capital management

The objective of Own Funds management is to maintain, at all times, sufficient Own Funds to cover

the Solvency Capital Requirement (“SCR”) and Minimum Capital Requirement (“MCR”) with an

appropriate buffer. The Company’s Solvency II position as at 31 December 2018, and the

comparative position as at 31.12.2017, were as follows:

It can be seen that the Company’s solvency position deteriorated during the course of 2018, and as

at 31.12.2018 it failed to cover the Minimum Capital Requirement. A capital injection of CHF 563’750

in January 2019 restored its solvency position.

Vaduz 12 April 2019

Balance Sheet 31.12.2018

Solvency II

value

(CHF'000)

Statutory

value

(CHF'000)

Total assets 128'247.3 128'247.3

Total technical provisions 122'456.1 121'494.1

Other liabilities 2'079.2 2'079.2

Total liabilities 124'535.3 123'573.4

Excess of assets over liabilities (Ow n Funds) 3'712.0 4'673.9

Capital requirements

2018

CHF '000

2017

CHF '000

Solvency Capital Requirement (SCR) 1'519.78 2'134.50

SCR Ratio 244.2% 234.4%

Minimum Capital Requirement (MCR) 4'169.53 4'329.50

MCR Ratio 89.0% 115.6%

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A. Business and performance

A.1 Business and external environment

A.1.1 Name and legal form of the undertaking

Nucleus Life AG (“the Company”) is incorporated in Liechtenstein as a company limited by

shares (Aktiengesellschaft). Its registered offices are at:

Bangarten 10

FL-9490 Vaduz

A.1.2 Name of the responsible Supervisory Authority

The Financial Market Authority Liechtenstein (FMA) is responsible for the financial

supervision of the Company. The FMA’s address is:

Financial Market Authority Liechtenstein

Landstrasse 109

PO Box 279

FL-9490 Vaduz

A.1.3 Name of the external auditors

The Company’s external auditor is BDO (Liechtenstein) AG:

Wuhrstrasse 14

FL-9490 Vaduz

A.1.4 Holders of qualifying holdings in the undertaking

The Company is de facto controlled by Nucleus (Holdings) SCA, Luxembourg, even though

Plenum Holdings AG, Switzerland, legally held a 56.72% interest of the Company as at

31.12.2018. There are no other qualifying shareholders with an interest of 10% or more.

A.1.6 Lines of business and geographical areas

The Company is authorised to write the following classes of business:

Class 1. Life Insurance

Class 3. Unit-/Fund-linked Life Insurance

It is authorised to do business in Austria, Belgium, Germany, Ireland, Italy, Norway, Sweden

and Switzerland.

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A.2 Underwriting performance

The Company’s main markets are International (written according to Liechtenstein law) and

Germany, with modest volumes coming from Belgium and Norway. The Company’s gross

booked premiums per country in 2018 and the corresponding numbers for 2017 are depicted

in the table below (in CHF).

Gross booked premiums

2018 (CHF

2017 CHF)

Liechtenstein 3'965'815 12'121’761

Germany 2'689'750 3'956’534

Belgium 18'982 428’915

Norway - 479’834

Total 6'674'547 16'987’044

Financial statements are prepared in accordance with Liechtenstein GAAP. The salient items

of the profit and loss for the year ended 31 December 2018 are shown below.

Year ended 31 December 2018 2018 (CHF)

2017 (CHF)

Gross premiums 6'674'547 16‘987‘044

Gross claims -18'094'094 -4‘351‘645

Acquisition costs -707'850 -682‘470

Operating expenses -1'071'417 -984‘123

Change in provisions for Deposit-linked contracts 24'248'967 -20‘499‘583

Result -631'679 -189‘431

Lower than budgeted premium income and higher than expected surrenders, combined with

a strengthening of the Swiss Franc, lead to a substantial reduction in fee income and a

resultant increase in the loss for the year.

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A.3 Performance from investment activities

The Company writes only Deposit-Linked business, and does not provide any asset selection

advice. The investments linked to insurance policies are selected by policyholders or their

appointed advisers, or, where applicable, by asset managers selected by the policyholders

and appointed for this purpose by the Company. Assets and policyholder liabilities are

matched at all times.

The following assets* are held to cover technical provisions for linked liabilities.

Asset class 2018 (CHF)

2017 (CHF)

Equity 86’302’819 98'876'513

Fixed income 25’594’439 35'975'737

Cash, deposits and money market

9’581’297 10'876'510

Total 121’478’555 145‘728‘760

* Excluding assets of policies not yet issued and policies surrendered but not yet paid out.

Where assets are suspended or no market value is available, a fair value is calculated; if this is

not possible, the value of the asset is written down to zero.

Investment income comprises dividends, interest and other income receivable, realised gains

and losses on investments and unrealised gains and losses. Movements are recognised in the

profit and loss account in the period in which they arise.

The Deposit-Linked insurance policies are valued by reference to their linked asset values.

The performance of the policies therefore depends on the performance of the assets

selected and the application of policy related charges in line with the policy contract terms

and conditions.

A.4 Expenses

Expenses can be split into acquisition costs and operating expenses.

Expenses 2018 (CHF)

2017 (CHF)

Acquisition costs 707’850 682’470

Operating expenses 1'071’417 984’123

Acquisition costs will continue to vary according to type and size of business written, while

expense levels are expected to remain constant.

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B. System of governance

The Board of the Company considers the system of governance to be adequate and

proportionate to the nature, scale and complexity of the risks inherent in its business.

B.1 General governance arrangements

The Company’s system of governance has been designed around a Risk Management

framework together with the controls and processes.

B.1.1 System of Governance

The Management and the Supervisory Board, collectively the “AMSB” (Administrative,

Management or Supervisory Body), is responsible for the implementation and monitoring of

the governance of the Company.

The Supervisory Board is responsible for defining the Risk Appetite of the shareholders of the

Company by means of a Risk Statement, while the Management is required to manage the

Company in accordance with this Risk Appetite. In case of uncertainty, Management consults

with the Board.

Board of Directors

▪ Vincent Derudder (Chairman)

▪ Simon Colboc

▪ Markus Graf

Key Functions

The Company has established the four key independent control functions required under the

Corporate Governance Requirements for Insurance Undertakings under Solvency II. These

functions are responsible for providing oversight of and challenge the business, and for

providing assurance to the Board in relation to the Company’s control framework.

The following section provides a summary of the authority, resources and operational

independence of the key functions:

Compliance function (Internal Controls) - led by the Head of Compliance

▪ responsible for the Company’s Compliance Policy

▪ identifies, assesses, monitors and reports the compliance risk exposure

▪ tracks changes in the environment that could affect the Company’s compliance risk, and

monitors the appropriateness of the Company’s compliance procedures

▪ inputs into the ORSA process and report

The Compliance function considers and monitors the regulatory environment, financial

crime, data protection, and compliance. The findings of the Compliance function are

reported to the Management and the Board.

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Risk function - headed by the Risk Officer (“RO”)

▪ oversees and monitors the effective operation of the risk management system and ORSA

▪ identifies and assesses emerging risks

▪ maintains an entity-wide view on risk exposures and the Company’s risk profile

▪ ensures that material risk issues receive sufficient attention at Board level and that the

Board plays an active part in setting and reviewing the overall risk-appetite and tolerance

limits

▪ provides detailed reporting on risk exposures and advises on risk-management matters,

including strategic affairs such as corporate strategy, mergers and acquisitions, major

projects and investments

The Risk Officer prepares a quarterly Risk Assessment Matrix which is presented to Board,

giving it information gathered through the risk management process. The risk function

maintains independence by carrying out an oversight role in the major processes, allowing

for robust challenge of decisions and processes across the business.

Actuarial function - performed by an external actuary

▪ approves the methodologies and assumptions used for calculating technical provisions,

ensuring that they are appropriate for the line of business

▪ approves the underwriting policy and reinsurance arrangements

▪ analyses and evaluates data and results and reports to the Board

▪ contributes to the risk management system

Under Liechtenstein law, an insurance company is required to have an Appointed Actuary in

addition to the Actuarial function required under Solvency II. Considering the size of the

Company and the nature of its business, the same actuary performs both roles. Care has

been taken ensure that there is no conflict of interest, and that independent checks (4-eyes

principle) are at all times ensured.

Internal Audit function - performed by an external company

▪ evaluates the adequacy and effectiveness of the internal control systems and other

elements of governance

▪ reviews the ORSA process & report

▪ provides an independent assessment in a report to the AMSB

The Internal Auditor is an experienced auditor from an external organisation, providing the

required level of independence. The findings of the Internal Auditor are reported to the

AMSB.

B.2 Fit and proper

The Company ensures that all persons who effectively run the Company or perform key

functions are fit to provide sound and prudent management through their professional

qualifications, knowledge and experience, and are proper by being of good repute and

integrity.

The following persons are checked prior to commencement of their employment contracts:

▪ Directors

▪ Management

▪ Appointed Actuary

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▪ Risk Officer

▪ Compliance Function

▪ Actuarial Function

▪ Internal Auditor

Information required and checks performed include the following:

▪ Interview

▪ Passport or ID

▪ CV (educational background, professional qualifications, membership)

▪ References

▪ Criminal record check

▪ Credit check

▪ Bankruptcy check

▪ Financial Sanctions & Anti-money Laundering check

Recurring checks are performed on a regular basis.

B.3 Risk management system

Risk Management framework

The Risk Management framework consists of a set of policies covering all the possible risks

the Company could face, summarised in the form of a Risk Assessment Matrix and a Risk

Report. The Risk Assessment Matrix is updated on a regular basis, together with controls

which the Company uses to manage the specified risk.

Risk Appetite Statement

The Risk Appetite Statement is defined by the Board and describes the risk boundaries (and

hence the risks) the Company is willing to operate within. Overall the Company is risk averse,

which is reflected in the way it conducts its business.

“Three Lines of Defence” governance model

The Company’s Risk Management system follows the “three lines of defence” principle:

▪ 1st Line of Defence: Management and staff

The 1st line of defence is responsible for the day to day management of risk and control

within the business operations as well as delivering the strategy and optimising business

performance within the agreed governance and risk framework.

▪ 2nd Line of Defence: Risk management & Compliance (Oversight)

The 2nd line of defence is comprised of the Risk Management function and the

Compliance function. These are independent functions that provide assurance to the

Board with regards to the adequacy and effectiveness of the overall risk management

system.

▪ 3rd Line of Defence: Internal Audit (Assurance)

The 3rd line of defence is provided by the independent Internal Audit function which

validates the controls and performs an objective review of the risk management process.

This function provides assurance to the Management and the Board on assertions of the

Company’s risk exposure.

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B.4 Own Risk and Solvency Assessment

The main purpose of the Own Risk and Solvency Assessment (“ORSA”) is to ensure that the

Company assesses all risks inherent to its business and to determine the corresponding

capital needs – or, alternatively, to identify other methods to mitigate specific risks.

The ORSA takes a top-down approach, linking business objectives, business risks, business

planning and capital planning. It is performed at least once per annum, or on an ad hoc basis

if a new project or product that may impact on the capital of the Company is considered. It

can also be triggered by a sudden, unexpected adverse event.

As part of the ORSA, “stressed scenarios” are considered, as well as the capital needs and/or

mitigation measures necessary under such scenarios. The aim of these stress tests is to

ensure that the business is robust enough to weather adverse events without detriment to

policyholders.

The outcome of the ORSA is presented to the AMSB.

B.5 Internal control system

The purpose of the internal control system is to manage or mitigate, rather than eliminate,

the risk of failure to achieve business objectives, and can only provide reasonable, and not

absolute, assurance against material losses.

The Company is of the opinion that the internal control system is appropriate to the nature,

scale and complexity of its business.

The internal control framework has four elements:

▪ Supervisory Board

The Board has overall responsibility for ensuring that an adequate and effective system

of internal control is maintained in the Company.

▪ Compliance and Risk Management functions

These functions oversee internal controls, including drafting and implementing policies

and procedures, and monitoring against compliance with them.

▪ Internal Audit function

The Internal Audit function is an external appointment, providing a layer of independent

assurance.

▪ Controls over Outsourced Activities

The Company makes extensive use of outsourcing, and therefore pays particular

attention to the monitoring of these activities and ensures that these persons or entities

maintain at least the same standards as those of the Company.

B.6 Internal audit function

The independent (external) Internal Audit function provides an analysis and evaluation of the

adequacy, effectiveness, efficiency and quality of risk management, internal control and

governance systems and processes.

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An audit plan is created on an annual basis to ensure that sufficient evidence is obtained to

evaluate the effectiveness of the risk management and control processes across the

business.

The findings and recommendations of the Internal Auditor are discussed with Management,

after which it is presented to the Board.

B.7 Actuarial function

The Company has outsourced the Actuarial function to an external actuary; this additional

skilled (and independent) resource provides an additional layer of control and confidence.

Due to the size of the Company and the nature of its business, the Actuarial function also acts

as Appointed Actuary. Sufficient checks and balances have been built into the processes to

ensure that the Actuarial function remains objective and free from the influence of other

functions or from the Company’s AMSB.

The Actuarial functions drafts an annual Actuarial Report which is presented to the Board and

the Regulator.

B.8 Outsourcing

The Company outsources a number of important functions to independent external

providers. The rationale behind the decision is that outsourcing, if managed and monitored

properly, not only gives the Company access to a wider and better range of skills, but can also

be more cost-effective (as opposed to employing permanent staff).

The following important functions are outsourced:

▪ Appointed Actuary

▪ Actuarial function

▪ Internal Audit function

▪ Bookkeeping incl. payroll

The Compliance function is responsible for evaluating all new outsourcing partners, as well as

monitoring them on an ongoing basis, performing at least annual checks.

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C. Risk profile

The Company assumes mainly Deposit-Linked business whereby the policyholder bears the

financial risk. In accordance with the Prudent Person principle, the Company only invests

policyholder funds in assets and instruments the risks of which it can properly identify,

measure, monitor, manage and control. Shareholder assets are only invested in secure, non-

volatile assets.

The more significant financial risks to which the Company is exposed are set out below.

C.1 Underwriting risk

Mortality risk

The Company is exposed to the risk of mortality experience being higher than expected,

leading to higher than expected death claims.

As the Company writes only risk business with very low sums assured, this is a very limited

risk.

Suitable reinsurance arrangements are in place to reinsure the bulk of the mortality risk

commensurate with the Company’s risk profile and capital.

Lapse risk

The Company is exposed to the risk of surrenders being higher than expected, leading to a

loss in fee income.

The Company writes mainly single premium investment business, which typically shows a

relatively low and stable lapse rate.

The lapse risk is not always easy to manage, as policies are often surrendered for reasons

outside of the control of the Company, for example due to poor market performance, or

because the policyholder is in need of money.

The risk of one or two very large policies being surrendered for whatever reason, remains a

real risk that can result in a not insignificant reduction in fee income. It was, however,

assumed that the standard lapse stress scenarios under Solvency II (upward and downward

increase of 50%; immediate 40% mass lapse) are adequate, and that no further stress

scenarios are required.

C.2 Market risk

Market risk describes the risk of loss or of adverse change in the financial situation resulting,

directly or indirectly, from fluctuations in the level and in the volatility of market prices of

assets, liabilities and financial instruments.

As the Company writes mainly Deposit-Linked business where the investment risk is carried

by the policyholders, the key market risk is that of a fall in the value of policyholder assets,

resulting in lower fee income.

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Price risk

A change in the market value of the Deposit-Linked funds would affect the annual

management charges accruing to the Company, since these charges are based on the market

value of policyholder assets.

Currency risk

Similarly, due to the fact that the annual management charges are deducted from contracts

in contract currency, a change in foreign exchange rates relative to the Swiss Franc can result

in fluctuations in fee income.

The currency risk is a sizeable risk, as the bulk of its fee income is derived in Euro, while

almost all of its expenses are in Swiss Franc. The stress tests performed allow for a ±25%

change in exchange rates, which is deemed to be adequate.

Interest rate risk

The only interest rate risk that the Company faces is that of the interest earned on its own

capital, which is fully invested in cash. This capital already attracts a negative rate of interest,

and the risk is that the Swiss National Bank may increase this interest penalty even further.

C.3 Credit risk

Credit risk refers to the risk of loss, or of adverse change in the financial situation resulting

from fluctuations in the credit standing of issuers of securities, counterparties and any

debtors to which the Company is exposed.

Reinsurance counterparties

This is a negligible risk – as mentioned above the mortality risk is limited, while the

Company’s reinsurer is A-rated.

Banking counterparties

The defaulting of a policyholder custodian bank would not have a direct impact on the

financial situation of the Company, although there could be an indirect impact if the amount

of fee income from policyholder assets is reduced. The fact that policyholder assets are

spread across a number of European banks mitigates this risk.

The Company has the bulk of its own capital at an A-rated bank in Liechtenstein.

C.4 Liquidity risk

Liquidity risk refers to the risk that Company, though solvent, does not have sufficient

financial resources to enable it to meet its obligations as they fall due.

Short-term liquidity

Short-term liquidity assessments (for periods of less than one year) are performed at least

once per quarter. As the Company’s capital of CHF 5 Mio is being restricted by the FMA, this

is a potential risk – and one experienced in 2018 when fee income reduced as a result of low

new business volumes, high surrenders and a strengthening of the Swiss Franc.

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Long-term liquidity

Long-term liquidity is a limited risk, as the Company follows a very prudent investment

strategy, investing its capital only in high quality and liquid assets.

A key requirement for managing this risk is for the company to grow (increase in policyholder

assets under management) and to keep its expenses under control.

C.5 Operational risk

Operational risk is the risk of a change in value due to inadequate or failed internal

processes, people or systems, or from external events.

People risk

The Company operates with a very small team of experienced, skilled people. A person

leaving or falling ill may therefore have a detrimental impact on the business, in particular

over the short term.

This risk has been mitigated to some extent by increasing the notice periods of some of the

staff members, while a panel of external consultants who can provide assistance at short

notice has been identified. This does, however, remain a real risk.

Outsourcing risk

The outsourcing strategy of the Company actually reduces the people risk described above,

as it provides access to a wider range of skills. On the other hand, outsourcing comes with

the risk of failure, non-performance, ineffective management and/or oversight of the

outsourcing partner.

The Compliance function attends to the management and monitoring of outsourcing

partners.

Administration risk

As a result of the highly bespoke nature of the Company’s products, not all processes can be

fully automated, which, if combined with the small staff complement, poses some risk. All

processes and procedures have, however, been documented in detail, which will enable an

external resource to take over at short notice.

Litigation risk

A life insurance company focussing on investment business will always be subject to litigation

risk – even though the investment risk is supposed to remain with the policyholder. The most

typical reasons are poor investment performance or fraudulent activities (e.g. by

intermediaries or asset managers).

An incident of fraud dating back to 2015 whereby an external asset manager unlawfully

enriched himself with customer funds, became a legal case on 01.03.2019 through the

initiation of legal proceedings against Nucleus Life AG on behalf of the policyholder. The

lawyers of the Company are still in the process of gathering further information, but

according to current knowledge the chances of a successful claim appear to be rather low,

and it was therefore not deemed necessary to set up any additional provisions in this regard

as at 31 December 2018.

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Regulatory risk

The Company’s solvency situation combined with short term liquidity constraints could lead

to regulatory action.

Misselling risk

Whereas misselling is not a substantial risk when dealing with High Net Worth clients, it can

occur in the mass-affluent segment. Great care is therefore taken to make sure that

investments are not only assessed in terms of size, but also in terms of the needs and risk

profile of the policyholder.

Reputation risk

Any legal or regulatory breach, poor customer service, or local insurer failures can give the

Company a bad reputation, effecting its ability to write business or form new business

relationships. Whereas the Company takes care to mitigate legal and customer service risks,

external risks cannot be managed.

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D. Valuation for solvency purposes

D.1 Assets

The following table shows the Company’s assets as at 31 December 2018, as well as the

corresponding numbers for 2017:

Intangible assets

Intangible assets are made up only of sophisticated software, and do not include any

goodwill such as brands, trademarks or contractual relationships. The stated value, which is

well below the estimated market value, is not material and therefore assumed to be fair.

Equities

Listed equities have been valued at market value, while unlisted equities have been valued at

net asset value. Equities that cannot be traded at all are valued at zero.

Assets held for index-linked and unit-linked contracts

The valuations of these assets are mostly provided by the custodian banks where the assets

are held. If a custodian bank cannot determine a market value, it would typically value the

asset at zero. In rare instances the Company would value an asset based on the NAV on its

balance sheet, but if that is not possible it would value it at zero.

Receivables and other assets

The value of these assets is based on the best estimate of the recoverable or realisable value.

Cash and cash equivalents

Cash and cash equivalents are valued at the amount held at the period end, translated using

the year-end exchange rate where appropriate.

D.2 Technical provisions

The technical provisions comprise the Best Estimate of the Liabilities (“BEL”) and the Risk

Margin. The technical provisions as at 31 December 2018 and the corresponding values for

2017 are shown in the table below.

Assets

2018

(CHF'000)

2017

(CHF'000)

Intangible assets 6.9 11.6

Equities 1.6 29.2

Assets held for index-linked and unit-linked contracts 123'184.5 146'654.0

Insurance and intermediaries receivables 0.6 116.3

Receivables (trade, not insurance) 29.9 63.5

Cash and cash equivalents 5'002.7 5'431.3

Any other assets, not shown elsewhere 21.0 25.3

Total assets 128'247.3 152'331.2

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The decrease in the technical provisions without a corresponding decrease in expenses, led

to an increase in the present value of future losses, and hence a substantial increase in the

Risk Margin.

D.2.1 Key assumptions

Interest rate and inflation

The risk-free interest rate term structure used for discounting the projected cash flows in the

technical calculation is the CHF relevant risk-free structure as provided by European

Insurance and Occupational Pensions Authority (“EIOPA”).

The inflation assumption used is based on the Swiss Consumer Price Index (CPI).

Expenses

The expense assumption is based on a no new business scenario and consists of cost of

administration, claims management/handling and overhead expenses. An expense analysis is

performed to allocate expenses between initial and renewal, and variable and fixed

expenses, allowing for a gradual reduction in expenses under a run-off scenario.

Lapse assumptions

The lapse assumption is based on a lapse analysis of the actual lapse experience of the

Company, considering lapses by number of policies as well as lapses weighted for policy size.

As the Company experienced an increase in lapses in 2018, the lapse assumption was

increased from 5.0% to 7.5% per annum.

Projection term

The term used for cash flow projections has a substantial impact on the capital requirements

of a small company in the process of increasing its assets under management. Bigger

companies that have reached break-even, can use the present value of future profits (PVFP)

to increase its Own Funds. However, as the Company is still in a loss position, it has to set

aside additional capital to cover future losses. As such, in 2017 a limit was placed on the term

used for the cash flow projections, based on the point when assets management fall below

CHF 100 Mio; this resulted in a term of 6.5 years.

In addition to the above, the Board agreed to initiate procedures to transfer the book to

another carrier free of charge should the assets under management reach a level of CHF 120

Mio, and to have the transfer completed before the assets under management reach the

level of CHF 100 Mio.

Technical provisions

2018

(CHF'000)

2017

(CHF'000)

Technical provisions – life (excluding health and index-

linked and unit-linked) 15.6 17.4 Best estimate 15.6 17.4

Risk margin 0.0 -

Technical provisions – index-linked and unit-linked 122'440.5 146'030.0 Best estimate 121'478.6 145'728.8

Risk margin 962.0 301.2

Total assets 122'456.1 146'047.4

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Due to the reduction is policyholder assets in 2018, the comparable projection term fell

below 5 years (i.e. the point when the assets under management would reach the CHF 100

Mio level). As it would not have been prudent to perform the projections for less than 5

years, it was decided to cap the minimum projection term at 5 years.

D.2.2 Technical provision calculation methodology

The technical provisions represent a realistic estimate of the Company’s future obligations

with an allowance for some deviation for plausible changes in estimation in the form of the

risk margin. They are not expected to be sufficient to meet the Company’s obligations in all

scenarios.

Best Estimate Liabilities

The best estimate provision for index-linked and unit-linked contracts is equal to the value of

the underlying assets.

Risk Margin

The Risk Margin is an addition to the Best Estimate Liabilities to ensure that the technical

provisions as a whole are equivalent to the amount that another insurer would require to

take over the business and meet the insurance obligations. The Risk Margin is calculated as

the amount of capital needed to support the Solvency Capital Requirement over the lifetime

of the business at the prescribed cost of capital rate of 6% per annum (also see para D.2.1 –

Projection term).

D.3 Other liabilities

The table below summarises the other liabilities of the Company as at 31.12.2018, as well as

the corresponding values for 2017:

No adjustment is required to these valuations for the valuation for solvency purposes as the

amounts held under IFRS measurement principles are deemed to be approximations of fair

value.

Other liabilities

2018

(CHF'000)

2017

(CHF'000)

Other liabilities 1'983.8 1'140.8

Provisions other than technical provisions 1.8 31.8

Accruals 93.7 108.1

Total assets 2'079.2 1'280.7

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E. Capital management

E.1 Own funds

The objective of own funds management is to maintain, at all times, sufficient own funds to

cover the Solvency Capital Requirement (“SCR”) and Minimum Capital Requirement (“MCR”)

with an appropriate buffer.

The Company performs an Own Risk and Solvency Assessment (“ORSA”) exercise at least

annually, or when the risk profile of the Company changes. The ORSA exercise incorporates

the business planning process covering a three-year time horizon.

The Company’s own funds as at 31.12.2018 as well as the corresponding values for 2017 are

shown below:

The Company’s own funds are primarily invested in cash deposits at banks. The total amount

qualifies as Tier 1 unrestricted funds, and is therefore available to cover the SCR and MCR.

The following table reconciles the differences (reconciliation reserve) between the equity in

the financial statements and the excess of the assets over liabilities as calculated for solvency

purposes:

E.2 Solvency Capital Requirement and Minimum Capital Requirement

The Company uses EIOPA’s Solvency II Standard Formula. It does not use Company specific

parameters and does not use simplified calculations in its computations.

The Company’s SCR and MCR (as well as the corresponding ratios) as at 31 December 2018,

and the numbers for 2017, are shown in the table below.

The individual components of the SCR are shown in the Annexures.

Own funds

2018

CHF '000

2017

CHF '000

Ordinary share capital 5'730.0 5'730.0

Organisation fund (capital contributions) 3'400.0 3'400.0

Reconcil iation reserve -5'418.0 -4'126.9

Total own funds 3'712.0 5'003.1

Own funds reconciliation

2018

CHF '000

2017

CHF '000

Equity in financial statements 4'673.9 5'305.6

less items not recohnised in financial statrements - -1.2

less Risk Margins -962.0 -301.3

Solvency II - Ow n Funds 3'712.0 5'003.1

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It can be seen that the MCR Ratio (Own Funds / MCR) was 89.0% as at 31.12.2018.

The Risk Appetite laid down by the Board in the ORSA states the following: “The Board does

not accept any risk that may result in the SCR ratio of the Company falling below 125% or the

MCR ratio falling below 110%, as that would be the point when the shareholders would have

to inject additional capital.” A capital injection of CHF 563’750 was therefore made in

January 2019 to restore the solvency position.

It is clear that a substantial additional capital injection will be required during the course of

2018, and the Board is actively working on a solution.

Capital requirements

2018

CHF '000

2017

CHF '000

Solvency Capital Requirement (SCR) 1'519.78 2'134.50

SCR Ratio 244.2% 234.4%

Minimum Capital Requirement (MCR) 4'169.53 4'329.50

MCR Ratio 89.0% 115.6%

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Annexures: Quantitative Reporting templates

The following annual quantitative templates are attached as Annexures:

▪ Solvency II Balance Sheet

▪ Premiums, claims and expenses by line of business

▪ Premiums, claims and expenses by country

▪ Life and Health Technical Provisions

▪ Own funds

▪ Solvency Capital Requirement

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Balance Sheet

Solvency II value

C0010

Goodwill R0010

Deferred acquisition costs R0020

Intangible assets R0030 6'937.00

Deferred tax assets R0040 0.00

Pension benefit surplus R0050 0.00

Property, plant & equipment held for own use R0060 1'837.00

Investments (other than assets held for index-linked and unit-l inked contracts) R0070 1'634.19

Property (other than for own use) R0080 0.00

Holdings in related undertakings, including participations R0090 0.00

Equities R0100 1'634.19

Equities - l isted R0110 1'427.89

Equities - unlisted R0120 206.30

Bonds R0130 0.00

Government Bonds R0140 0.00

Corporate Bonds R0150 0.00

Structured notes R0160 0.00

Collateralised securities R0170 0.00

Collective Investments Undertakings R0180 0.00

Derivatives R0190 0.00

Deposits other than cash equivalents R0200 0.00

Other investments R0210 0.00

Assets held for index-linked and unit-l inked contracts R0220 123'184'451.87

Loans and mortgages R0230 0.00

Loans on policies R0240 0.00

Loans and mortgages to individuals R0250 0.00

Other loans and mortgages R0260 0.00

Reinsurance recoverables from: R0270 8'079.00

Non-life and health similar to non-life R0280 0.00

Non-life excluding health R0290 0.00

Health similar to non-life R0300 0.00

Life and health similar to l ife, excluding health and index-linked and unit-l inkedR0310

8'079.00

Health similar to l ife R0320 0.00

Life excluding health and index-linked and unit-l inked R0330 8'079.00

Life index-linked and unit-l inked R0340 0.00

Deposits to cedants R0350 0.00

Insurance and intermediaries receivables R0360 595.00

Reinsurance receivables R0370 0.00

Receivables (trade, not insurance) R0380 29'935.00

Own shares (held directly) R0390 0.00

Amounts due in respect of own fund items or initial fund called up but not yet paid

inR0400

0.00

Cash and cash equivalents R0410 5'002'717.10

Any other assets, not elsewhere shown R0420 11'105.00

Total assets R0500 128'247'291.16

Assets

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Solvency II value

C0010

Technical provisions – non-life R0510 0.00

Technical provisions – non-life (excluding health) R0520 0.00

Technical provisions calculated as a whole R0530 0.00

Best Estimate R0540 0.00

Risk margin R0550 0.00

Technical provisions - health (similar to non-life) R0560 0.00

Technical provisions calculated as a whole R0570 0.00

Best Estimate R0580 0.00

Risk margin R0590 0.00

Technical provisions - l ife (excluding index-linked and unit-l inked) R0600 15'606.41

Technical provisions - health (similar to life) R0610 0.00

Technical provisions calculated as a whole R0620 0.00

Best Estimate R0630 0.00

Risk margin R0640 0.00

Technical provisions – l ife (excluding health and index-linked and unit-l inked) R0650 15'606.41

Technical provisions calculated as a whole R0660 0.00

Best Estimate R0670 15'586.00

Risk margin R0680 20.41

Technical provisions – index-linked and unit-l inked R0690 122'440'505.22

Technical provisions calculated as a whole R0700 0.00

Best Estimate R0710 121'478'555.00

Risk margin R0720 961'950.22

Other technical provisions R0730

Contingent l iabilities R0740 0.00

Provisions other than technical provisions R0750 1'800.00

Pension benefit obligations R0760 0.00

Deposits from reinsurers R0770 0.00

Deferred tax liabilities R0780 0.00

Derivatives R0790 0.00

Debts owed to credit institutions R0800 0.00

Financial l iabilities other than debts owed to credit institutions R0810 0.00

Insurance & intermediaries payables R0820 1'706'036.00

Reinsurance payables R0830 0.00

Payables (trade, not insurance) R0840 277'726.00

Subordinated liabilities R0850 0.00

Subordinated liabilities not in Basic Own Funds R0860 0.00

Subordinated liabilities in Basic Own Funds R0870 0.00

Any other l iabilities, not elsewhere shown R0880 93'661.00

Total liabilities R0900 124'535'334.63

Excess of assets over liabilities R1000 3'711'956.53

Liabilities

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Premiums, claims and expenses by line of business

Health

insurance

Insurance

with profit

participation

Index-linked

and unit-l inked

insurance

Other life

insurance

Annuities

stemming

from non-life

insurance

contracts and

relating to

health

insurance

obligations

Annuities

stemming

from non-life

insurance

contracts and

relating to

insurance

obligations

other than

health

insurance

obligations

Health

reinsurance

Life

reinsurance

C0210 C0220 C0230 C0240 C0250 C0260 C0270 C0280 C0300

Gross R1410 0.00 0.00 6'673'078.11 1'468.68 0.00 0.00 0.00 0.00 6'674'546.79

Reinsurers' share R1420 0.00 0.00 144'941.25 0.00 0.00 0.00 0.00 0.00 144'941.25

Net R1500 0.00 0.00 6'528'136.86 1'468.68 0.00 0.00 0.00 0.00 6'529'605.54

Gross R1510 0.00 0.00 6'673'078.11 1'468.68 0.00 0.00 0.00 0.00 6'674'546.79

Reinsurers' share R1520 0.00 0.00 144'941.25 0.00 0.00 0.00 0.00 0.00 144'941.25

Net R1600 0.00 0.00 6'528'136.86 1'468.68 0.00 0.00 0.00 0.00 6'529'605.54

Gross R1610 0.00 0.00 18'094'093.76 0.00 0.00 0.00 0.00 0.00 18'094'093.76

Reinsurers' share R1620 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Net R1700 0.00 0.00 18'094'093.76 0.00 0.00 0.00 0.00 0.00 18'094'093.76

Gross R1710 0.00 0.00 -24'250'205.54 0.00 0.00 0.00 0.00 0.00 -24'250'205.54

Reinsurers' share R1720 0.00 0.00 -1'239.03 0.00 0.00 0.00 0.00 0.00 -1'239.03

Net R1800 0.00 0.00 -24'248'966.51 0.00 0.00 0.00 0.00 0.00 -24'248'966.51

Expenses incurred R1900 0.00 0.00 1'862'349.32 0.00 0.00 0.00 0.00 0.00 1'862'349.32

Other expenses R2500 0.00

Total expenses R2600 1'862'349.32

Claims incurred

Changes in other technical provisions

Line of Business for: l ife insurance obligations Life reinsurance obligations

Total

Premiums written

Premiums earned

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Premiums, claims and expenses by country

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Life & Health Technical Provisions

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Own funds

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Solvency Capital Requirement

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