Tower reports record FY25 result, increased dividends

Full Year Results26 November 2025TWRFinancials

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27 November 2025
Tower Limited
FY25 Full Year Results for Announcement to Market
In accordance with NZX Listing Rule 3.5.1 we enclose the following for release to the market in
relation to Tower Limited’s (NZX/ASX: TWR) FY25 Full Year Results:

1 Media Release
2 Results Announcement
3 Annual Report (including Financial Statements)
4 Results Announcement Presentation
5 Results Announcement Call Script
6 NZX Distribution Notice
7 Climate Statement

Tower’s Chairman Michael Stiassny, Chief Executive Officer Paul Johnston and Interim Chief Financial
Officer Angus Shelton will discuss the full year results at 10:00am New Zealand time today.
Tower’s Board confirms for the purposes of ASX Listing Rule 1.15.3 that Tower continues to comply
with the NZX Main Board Listing Rules.

ENDS

This announcement has been authorised by the Tower Board.

Paul Johnston
Chief Executive Officer
Tower Limited

For media enquiries, please contact in the first instance:
Emily Davies
Head of Corporate Affairs and Sustainability
+64 21 815 149
emily.davies@tower.co.nz

For investor queries, please contact in the first instance:
James Silcock
Head of Strategy, Planning and Investor Relations
+64 22 395 9327
james.silcock@tower.co.nz

Market Information
NZX Limited
Level 1, NZX Centre
11 Cable Street
Wellington
New Zealand
Company Announcements Office
ASX Limited
Exchange Centre
Level 6, 20 Bridge Street
Sydney NSW 2000
Australia

---

Level 5, 136 Fanshawe Street
Auckland 1142, New Zealand
ARBN 645 941 028
Incorporated in New Zealand
Incorporated in New Zealand
27 November 2025
Tower reports record FY25 result, increased dividends
Kiwi insurer, Tower Limited (NZX/ASX: TWR) today announced a record underlying profit
performance for the year ended 30 September 2025, delivering an underlying NPAT of $107.2m
and a reported profit of $83.7m. The result was driven by low large events costs and a significantly
reduced business-as-usual (BAU) claims ratio, alongside customer growth.
Reported profit reflects adjustments for increased Canterbury earthquake claims cost estimates,
the ongoing cost of customer remediations and a provision for software impairment.
FY25 highlights:
• Underlying NPAT: $107.2m (up from $83.5m in FY24)
• Reported profit: $83.7m (up from $74.3m in FY24)
• Gross written premium (GWP): $600m, up 2%
• Customer numbers: 318,000 (up 4%)
• BAU claims ratio: 41% (improved from 48%)
• Combined operating ratio (COR): 74.1% (vs 79%)
• Management expense ratio (MER): steady at 31.4%

Reflecting the positive results, Tower’s Board has declared a fully imputed final dividend of 16.5
cents per share. This brings total dividends for FY25 to 24.5 cents per share.

Tower CEO Paul Johnston says, "This is an exceptional result, underpinned by Tower’s
transformation, driven by investment in our digital platform and continued focus on underwriting
discipline, technology, data, and efficiency. These actions demonstrate Tower’s commitment to
delivering sustainable growth and building a resilient, customer-focused business for the future.

“However, it is worth noting that we expect conditions that influenced the FY24 and FY25 results,
such as relatively benign weather, and prior-year rating flowing through the portfolio, to normalise
in the coming year.”

Strategic growth in home insurance portfolio
Tower’s customer base grew 4% to 318,000, with home insurance policies up 11%, reinforcing its
strategic focus on the house portfolio.

GWP growth of 2% reflects strong policy volumes, tempered by lower average premiums as Tower
prioritised growth from low-risk customers and competitive pricing. GWP from the house portfolio
grew 10%, driven by volume growth, while motor GWP declined 5% due to lower pricing, partially
offset by renewed motor volume growth.

In FY25, Tower strengthened its foundations for future growth through key initiatives, including a
new partnership with Westpac NZ to offer general insurance products to the bank’s retail customers

Level 5, 136 Fanshawe Street
Auckland 1142, New Zealand
ARBN 645 941 028
Incorporated in New Zealand
Incorporated in New Zealand
from July 2026. Tower also launched a refreshed brand positioning and advertising campaign that
resonated strongly with Kiwi audiences and was recognised with Kantar’s June 2025 Ad Impact
Award.

Claims and operational performance
The BAU claims ratio reduced substantially to 41.3%, driven by a continuation of relatively benign
weather, lower inflation, reduced motor theft as well as underwriting improvements, process
enhancements and prior year rating adjustments.

Tower’s investments in address-level risk-based pricing continue to reduce Tower’s risk exposure,
with 91% of new house policies rated low or very low flood risk, up from 87% in FY24. Tower also
expanded its risk-based pricing to include sea surge and landslide risks in the year.

The MER remained stable at 31.4%, as improvements resulting from increased scale were
reinvested in technology and growth initiatives to boost efficiency and customer acquisition. In
FY25, Tower launched Amazon Connect, an AI-enabled contact centre platform that streamlines
processes and reduces frontline effort, with key operational metrics already showing positive
improvements.

Large events costs
Tower continues to support customers through large events, recording $7m in large events costs in
FY25 due to Dunedin flooding in October 2024 and Cyclone Tam in April 2025.

The storms across New Zealand in late October 2025 will be recorded as a large event in FY26 with
an estimated cost of $4.5m.

FY26 guidance
In FY26 Tower expects underlying NPAT to be in the range of $55m to $65m, assuming full
utilisation of an updated $45m large events allowance. GWP is anticipated to grow between 5% and
10%, supported by continued customer growth and strategic partnerships. While Tower expects to
see benefits from digitisation and efficiency initiatives, ongoing investment in growth, technology
and customer experience are expected to keep the MER between 31% and 32%.

Ends
This announcement has been authorised by Tower Limited CEO, Paul Johnston.

For media enquiries, please contact:
Emily Davies
Head of Corporate Affairs and
Sustainability
+64 21 815 149
emily.davies@tower.co.nz
For investor enquiries, please contact:
James Silcock
Head of Strategy, Planning and Investor
Relations
+64 22 395 327
James.silcock@tower.co.nz

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Updated as at June 2023

Please do not amend or delete individual rows. As this template relates to prescribed content, changes to content
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Results for announcement to the market
Name of issuer Tower Limited
Reporting Period 12 months to September 2025
Previous Reporting Period 12 months to September 2024
Currency NZD
Amount (000s) Percentage change
Revenue from continuing
operations
$594,348 7%
Total Revenue $594,348 6%
Net profit/(loss) from
continuing operations
$83,673 18%
Total net profit/(loss) $83,673 13%
Interim/Final Dividend
Amount per Quoted Equity
Security
16.5 cents
Imputed amount per Quoted
Equity Security
6.416667 cents
Record Date 15 January 2026
Dividend Payment Date 29 January 2026
Current period Prior comparable period
Net tangible assets per
Quoted Equity Security
$0.78 $0.73
A brief explanation of any of
the figures above necessary
to enable the figures to be
understood
Increased revenue reflect growth in insurance policies sold, partly
offset by lower average premiums.

BAU claims ratio improved from rating and underwriting actions
and relatively benign weather.

The growth in profit was driven primarily by revenue growth and
a lower BAU claims ratio.

Please refer to the 2025 full year results announcement
presentation for further information.

Authority for this announcement
Name of person

authorised
to make this announcement
Tania Pearson, General Counsel & Company Secretary
Contact person for this
announcement
Emily Davies, Head of Corporate Affairs and Sustainability
Contact phone number +64 21 815 149
Contact email address emily.davies@tower.co.nz
Date of release through MAP

27 November 2025

---

2025
Annual Report

2025 in review 1
2025 snapshot 2
Update from the Chair and CEO 4
Delivering on our strategy 8
Our purpose, vision and strategy 9
Leading customer experience 10
Innovative & operationally excellent 16
Sustainable growth 21
Effective & distinctive culture 27
Environmental, social and governance performance 32
Board of Directors 38
Consolidated financial statements 40
Financial statements 41
Notes to the consolidated financial statements 46
Independent auditor’s report 84
Appointed actuary’s report 88
Underlying profit reconciliation 89
Corporate governance at Tower 90
Global Reporting Initiative content index 102
Tower directory 108
Registry details 109
ANNUAL REPORT 2025 ContentsGRI content index Corporate governanceConsolidated financial statementsSustainabilityOur strategy2025 in review

2025 in review
1ANNUAL REPORT 2025 ContentsGRI content index Corporate governanceConsolidated financial statementsSustainabilityOur strategy2025 in review

Reported profit
after tax vs. $74.3m
in FY24
Underlying profit after
tax
1
vs. $83.5m in FY24
$
83.7
M
$
107.2
M
Management
expense ratio (MER)
1

in line with FY24
Gross written premium
(GWP)
1
, up 2%
2
from
$595m in FY24
31.4
%
$
600
M
Combined operating
ratio
1
(COR) vs. 79%
in FY24
Business as usual
(BAU) claims ratio
1
vs
48% in FY24
74
%
41
%
Shareholders
Total FY25 dividends
per share declared
3

Capital returned
to shareholders
24.5
C
$
45
M
Performance
2025 snapshot
1 Underlying Profit, GWP, MER, BAU claims ratio and COR are non-GAAP financial information. Consequently, they may not be comparable to similar measures presented by other reporting entities and are not subject to audit or independent review.
GWP is a component of Insurance Service Revenue. MER is the ratio of underlying management expenses, including claims handling expenses, to underlying Insurance Service Revenue. BAU Claims Ratio is the ratio of underlying claims expense,
excluding large events, to underlying Insurance Service Revenue. Underlying Profit includes large events but excludes certain large or non-recurring items. A reconciliation of these items to GAAP financial information can be found on page 89.
2 Excluding divested portfolios.
3 HY25 dividend 8c, FY25 dividend declared 16.5c.
2
ANNUAL REPORT 2025 ContentsGRI content index Corporate governanceConsolidated financial statementsSustainabilityOur strategy2025 in review

Community
Customers
Customers vs.
305,000 in FY24
Claims incurred across
NZ and the Pacific vs.
59,813 in FY24
318,00059,582
Volunteer hours in our
communities in FY25
vs. 2,300 in FY24
Tower Climate Change
Scholarships Awarded
to University of Waikato
students
3,1973
of Tower staff
are members
of an employee
representative group
Employee engagement
score
1
vs. 8.1 in FY24
31
%
8.2
People
1 As at 12 September 2025, based on Tower’s latest staff engagement survey. Employee diversity and inclusion score in the top 10% of the global finance sector.
3
ANNUAL REPORT 2025 ContentsGRI content index Corporate governanceConsolidated financial statementsSustainabilityOur strategy2025 in review

Update from the Chair and CEO
In FY25, we continued to progress
our strategy, strengthening our
foundations and driving resilience
and efficiency to position Tower for
sustainable growth and profitability.
Accelerating strategic transformation
for sustainable growth
Our strategy – centred on digital innovation, operational
excellence, and a culture of customer centricity –
continued to guide our journey to become the leading
direct personal lines and SME insurer in New Zealand
and our chosen Pacific markets.
We grew the right risks using initiatives such as our
risk-based pricing strategy and enhanced underwriting,
while making strategic investments to boost efficiency,
further strengthen the business, and provide good
customer experiences: all of which underpin our long-
term growth strategy.
Key milestones this financial year included launching our
AI-enabled contact centre platform, continued progress
in our claims transformation programme, and achieving
our highest-ever employee engagement score of 8.2.
Importantly, we also expanded our customer base
by 4% and were proud to be named Canstar’s Home
and Contents Insurer of the Year for the second
consecutive year.
Delivering a strong business performance
For the year to 30 September 2025, Tower delivered an
underlying profit of $107.2m (up from $83.5m in FY24)
and a reported profit of $83.7m (up from $74.3m in
FY24). Gross written premium (GWP), excluding divested
portfolios, increased by 2% year-on-year to $600m.
The result was driven by relatively benign weather, with
only two large events in FY25 and $7.2m in large events
costs, allowing us to return $30.8m after tax of our large
events allowance to underlying NPAT. Benign weather,
together with lower motor claims and prior-year targeted
underwriting actions – such as tightening our risk
appetite for high-theft-risk vehicles – also contributed
to a reduction in NZ business-as-usual (BAU) claims,
from 57,783 in FY24 to 56,825 in FY25, while customers
and policy count grew in the year. Our BAU claims ratio
improved to 41% in FY25, down from 48% in FY24.
ANNUAL REPORT 20254 ContentsOur strategySustainabilityConsolidated financial statementsCorporate governanceGRI content index 2025 in review

Policy growth of 6% in our core New Zealand portfolio
was another key driver of Tower’s very positive result.
This occurred predominantly in the New Zealand house
insurance portfolio, which saw 11% policy growth in the
same period, reflecting Tower’s strategic focus on the
house insurance market.
Overall, we increased our customer base from 305,000
in FY24 to 318,000 in FY25.
While policy and customer volumes have continued
to grow, average premiums have reduced. This is
due to a higher proportion of lower-risk new policies,
consistent with Tower’s risk-based pricing approach,
and more competitive pricing in the New Zealand
market. These factors are delivering value for
customers while supporting growth.
Our management expense ratio (MER) remained
stable at 31.4% in FY25, reflecting lower GWP from
reduced average premiums together with ongoing
and necessary investment in technology and growth
initiatives, including for customer acquisition.
Tower’s reinsurance programme is designed to protect
the business from the financial impact of large-scale
events, and to ensure the continued strength of our
solvency and capital positions. Tower’s NZ parent
solvency margin was $89m at 30 September 2025,
and its solvency ratio was 143%.
In accordance with Tower’s ordinary dividend policy
to pay 60-80% of adjusted earnings, where prudent
to do so, the Board declared a final dividend of 16.5 cents
per share, bringing total dividends for FY25 to 24.5 cents
per share.
In considering this dividend, the Board wanted to
distribute the benefit from lower large events costs
to shareholders. The 16.5 cents per share dividend is
made up of 7.5 cents per share from adjusted earnings
excluding large events; and an additional 9 cents per
share reflecting the under-utilisation of the $50m large
events allowance in FY25.
Introducing sea surge and landslide
risk-based pricing
We continued to strengthen our portfolio by leveraging
data to inform and automate pricing and underwriting
decisions for greater precision and efficiency.
As part of this, in August 2025, we expanded our risk-
based pricing strategy to include landslide and sea
surge risks, building on our existing earthquake and
flood risk models.
The introduction of sea surge and landslide risk-based
pricing enables more targeted premium calculations
and aims to further reduce cross-subsidisation. Starting
from October 2025, as policies renew over the year, 90%
of existing customers will see a reduction in the natural
hazards portion of their premium, averaging NZD $70 per
policy
1
, while increases for higher-risk properties will be
phased in over up to four years to support affordability.
Tower remains a vocal advocate for nationally consistent,
bipartisan adaptation planning and greater data
transparency. Insurers play a vital role in New Zealand’s
climate adaptation response and expanding our risk-
based pricing model is one way in which Tower is playing
its part to achieve practical change.
We welcome the Government’s recent commitment
to introduce climate adaptation legislation under
its Climate Adaptation Framework, requiring local
authorities to develop adaptation plans in the highest-
priority risk areas. This is a critical step toward long-term
certainty for communities and the insurance sector.
There is still a lot to be done, and we will continue to
advocate for actions to protect communities as the
Government’s plans continue to develop.
Partnering for growth
Tower’s partnership model thrived in FY25, contributing
$115m in GWP.
We deepened our relationship and referral partnership
with Kiwibank, as part of our retail and advisory referral
partnerships model. Overall, partnerships’ GWP
increased 12% in FY25 compared to the year prior.
We were also pleased to announce a new partnership
with Westpac NZ, under which Tower will underwrite
and supply general insurance products for Westpac
NZ’s retail customers from July 2026. This model will
integrate risk-based pricing and natural hazard data into
Westpac NZ’s digital banking experience. This long-term
agreement aligns with our strategic focus on growing
our home insurance portfolio and supports our future
growth targets.
1 For policy renewals during the 12 months from 19 August 2025.
ANNUAL REPORT 20255 ContentsOur strategySustainabilityConsolidated financial statementsCorporate governanceGRI content index 2025 in review

Forward thinking, future ready
In FY25, we launched our new brand platform: forward
thinking, future ready.
This evolution reflects our commitment to simplifying
insurance and helping customers prepare for life’s
uncertainties. Our campaign, The Misses, introduced
‘Miss Haps’, ‘Miss Takes’, and ‘Miss Fortune’ to personify
life’s unexpected events. This creative campaign
resonated strongly with Kiwi audiences and was
recognised with Kantar’s June 2025 Ad Impact Award.
Enhancing the customer experience
through efficiencies
Our claims transformation programme and digital
service initiatives further simplified processes and
delivered measurable improvements in FY25.
My Tower saw increased registrations and uptake
with more customers checking their claims’ status
and accessing claims manager contact details online.
In FY25, digital service task completion in New Zealand
rose to 51% (up from 44% in FY24), while the proportion
of claims lodged via My Tower, increased to 70%
(from 63% in FY24).
This commitment to automation allowed us to transition
one-third of our claims’ lodgement staff into claims
manager roles, thereby increasing the support available
for complex claims and improving efficiency.
The programme is already delivering tangible results,
directly supporting our strategic focus on growing
our home insurance market share and enhancing
our customers’ experience. This year, 55% of house
claims were submitted digitally via My Tower, with
70% automatically referred to assessors or suppliers
(up from 49% and 65%, respectively, in FY24).
Planning for the future with AI
In FY25, we advanced our AI-enabled insurer journey
by strengthening our data foundations, defining our
AI strategy, and launching our first AI operating model.
We also created the Tower AI Design Forum to ensure
safe, responsible adoption of AI and prioritisation of
AI-use cases.
Delivered in partnership with Deloitte and Amazon
Web Services (AWS), in August 2025 we launched our
AI-enabled contact centre platform. Built on Amazon
Connect, the platform integrates customer data, call
routing, real-time transcription, sentiment analysis, and
summarisation to provide faster, more consistent service. It
is a tangible and important example of how AI is enhancing
both the customer and employee experience at Tower.
Further enhancements to the platform are planned
for FY26, with new capabilities to be introduced
progressively to unlock its full potential.
Putting things right for our customers
Earlier in the year, Tower advised the market that despite
investments in improvement to systems and processes,
the complexity of accurately assessing multi-policy
discounts (MPD) still presented a risk of error for some
customers. As this fell short of Tower’s commitment
to high standards in customer experience and was
unacceptable for meeting regulatory requirements,
Tower discontinued the discount.
In 2024, Tower announced that the Financial Markets
Authority had commenced proceedings in the High
Court in relation to Tower’s misapplication of MPDs. This
followed Tower’s self-reporting of the issue. Tower and
the FMA have reached a settlement in relation to Tower’s
misapplication of its MPD and we are awaiting the final
decision from the High Court.
We accept and regret the impact this has had on our
customers and apologise unreservedly to those who
were charged inaccurately.
To put things right for our customers, we have undertaken
a comprehensive MPD remediation programme to
compensate affected customers, which is now nearing
completion. Once complete, Tower will have paid around
$12m to affected customers including interest.
Tower is focused on continuous improvement with the
aim of preventing future errors.
Our people
In May, we welcomed Naomi Ballantyne to the
Tower Board. Naomi’s experience is proving invaluable
to Tower as we continue to focus on our strategy to be
the best direct personal lines and SME insurer in our
selected markets.
We also appointed Dr. Stephen Hastings as Chief Data
and Analytics Officer, and Micheal Maclean joined Tower
as Chief Digital and Technology Officer in November
2025. These appointments underscore our focus on
digital and data capabilities as drivers of customer
experience and business growth.
ANNUAL REPORT 20256 ContentsOur strategySustainabilityConsolidated financial statementsCorporate governanceGRI content index 2025 in review

None of this year’s achievements would be possible
without our people. From New Zealand and across
our Pacific markets, their dedication and hard work
throughout the year has delivered good customer
outcomes and a strong result for shareholders.
Our people truly live our value ‘our people come
first’, exemplified in our latest staff engagement survey,
with peer relationships scoring 9 – placing Tower in the
top 5% of the global finance sector.
Looking ahead
As we look to FY26, Tower remains focused on
growth, efficiency, and delivering on our purpose:
to inspire, shape, and protect the future for the good
of our customers and communities.
With a clear strategic direction, passionate team, and
ongoing investment in technology and innovation, Tower
continues to be well-positioned to deliver sustainable
premium growth and long-term value for shareholders.
Michael Stiassny
Chair
Paul Johnston
CEO
“On behalf of the Board, I would like to congratulate
Paul on his appointment as CEO in June 2025. His
extensive international, strategic, and operational
experience - combined with a sharp focus on
insurance profitability and proven ability to navigate
complex market conditions as Tower’s CFO since
January 2022 - makes him the ideal leader to drive
Tower’s continued success.”
- Michael Stiassny.
“Tower has a fantastic culture and team in place,
who truly believe in the role we play in supporting
Kiwi and Pacific communities. I am very proud to
be a part of Tower, a company that inspired my
return to New Zealand after many years offshore.
I’m committed to further elevating Tower’s
performance through a focused approach on
insurance fundamentals and delivering sustainable,
profitable growth.”
- Paul Johnston.
ANNUAL REPORT 20257 ContentsOur strategySustainabilityConsolidated financial statementsCorporate governanceGRI content index 2025 in review ContentsGRI content index Corporate governance

Delivering on
our strategy
8ANNUAL REPORT 2025 ContentsGRI content index Corporate governanceConsolidated financial statementsSustainability2025 in reviewOur strategy

Our purpose
To inspire, shape and protect the future for the
good of our customers and communities.
Our vision
Ta tātou kaupapa
To deliver beautifully simple and rewarding experiences
that our people and our customers rave about.
Our strategy
To be the best direct personal lines and SME insurer in
our selected markets differentiated through digital and
data, fair and transparent, and with customer care in
everything we do.
Our values
We do
what’s right
Our people
come first
Our customers
are our compass
Progress
boldly
Our strategic pillars
LEADING
CUSTOMER
EXPERIENCE
Customer centricity
with a focus on
fairness and
transparency
INNOVATIVE &
OPERATIONALLY
EXCELLENT
Empowering
innovation and
decision-making
through use of
technology, data, and
digital capability
SUSTAINABLE
GROWTH
Growing a more
resilient Tower
through targeted
pricing, risk selection
and improved
customer retention,
underpinned by risk
management
EFFECTIVE & DISTINCTIVE CULTURE
9ANNUAL REPORT 2025 ContentsGRI content index Corporate governanceConsolidated financial statementsSustainability2025 in reviewOur strategy

Leading
customer
experience
ANNUAL REPORT 202510 Contents2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Our strategy

Transforming the claims process
Tower’s claims transformation
programme is simplifying processes
for customers, improving the
claims experience, and driving
operational efficiency. Launched in
FY23, the initiative seeks to leverage
data and technology to enable
seamless, end-to-end claims and
repair experiences.
In FY25 customers increasingly turned to our self-service
digital platform, My Tower, to lodge and manage their
claims during the last financial year. Throughout the
year 79,000 customers checked their claim status and
7,378 customers accessed their claims manager’s details
through the platform.
In FY25 we further improved our motor and
house claims journeys. We increased specialist
internal assessing resources, reduced reliance on
third-party assessors, and delivered a more efficient
customer experience.
Claims now lodged
via My Tower vs. 63%
in FY24
70
%
BAU claims ratio
vs. 48% in FY24
41
%
Customer Net Promoter
Score (NPS) up from +38
in FY24
1
+
44
1 Three-month averages as at 30 September 2025 and 2024.
ANNUAL REPORT 202511 Contents2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Our strategy ContentsGRI content index Corporate governance

Straight-through-repair motor journey
now complete
This year, we finalised our claims transformation motor
workstream by adding reserving
1
and payments to
complement the existing automated claims lodgement,
assessing, repairer referrals and repairs process.
Overall, 70% of motor claims were lodged via My Tower
2

in FY25.
Tower further advanced its claims process by completing
the integration of the Hello Claims assessing and repair
management platform into our online systems. As a
result, in New Zealand, 89% of motor claims lodged
via My Tower with our Tower Repair Partner Network
were automatically referred to a repairer or assessor –
eliminating the need for manual review.
In the year, Hello Claims integrated with PanelQuote,
a repairer management platform. Now, Tower Repair
Partners who use PanelQuote can complete quotes,
invoices, and file notes in the platform, then seamlessly
upload them to Hello Claims. This significantly reduces
the amount of administration required by repairers. Once
submitted, the integration also automates the invoicing
process between repairers and Tower to enable faster,
more accurate payments.
By focusing on automation and operational efficiency, we
were able to transition one third of our claims lodgement
staff into claims manager positions. This shift has
increased support for customers with complex claims
and needs, sped up the claims process, and created
efficiencies for both Tower and our repair partners.
of motor claims lodged via My Tower
2

with our Tower Repair Partner Network
were automatically referred to a
repairer or assessor, without the need
for manual overview
89
%
of motor claims were lodged via
My Tower
2
70
%
1 Claims reserving is the process insurers use to estimate and set aside funds for
future payments on claims that have been lodged but are not yet settled.
2 All My Tower data refers to NZ business only.
ANNUAL REPORT 202512 Contents2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Our strategy

NZ My Tower users,
up 11.5% in FY25
175,005

of house claims submitted via
My Tower were automatically referred
directly to an assessor or supplier,
without the need for manual review,
up from 65% in FY24
70
%
Driving scalability for house insurance customers
continuity through automation
Tower further streamlined the claims experience in FY25
by improving our straight-through-repair journey for
house claims, which delivered faster customer service.
Tower customers lodged 13,534 house insurance claims
in FY25 55% were submitted via My Tower, up from 49%
last year.
Of the house claims submitted via My Tower, 70% were
automatically referred directly to either an assessor or
supplier without the need for manual review, up from
65% in FY24.
Pleasingly, My Tower lodgement of weather claims
1
rose
from 58% in FY24 to 71% in FY25.
We bolstered online uptake by sending targeted
text messages that encouraged customers to claim
online using My Tower during weather events.
This helped keep our phone lines free for customers
with more complex needs and funnelled additional
claims through our straight-through-repair process.
Over 75% of weather claims
1
lodged via My Tower were
automatically accepted.
Customers requiring urgent repairs, such as for
broken windows or water damage, benefit from Tower’s
automated referrals to glazier and drying suppliers.
We also improved the experience for suppliers by
introducing automated payments.
During the year, Tower appointed Sedgwick, a global
loss adjuster to help ensure continuity of service for
Tower customers during periods of high claims volumes
in New Zealand and across the Pacific.
1 All weather-related claims including large weather events.
All My Tower data refers to NZ business only.
ANNUAL REPORT 202513 Contents2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Our strategy

Expanding our risk-based pricing model
to include sea surge and landslide risks
In FY25, Tower expanded our address-
level risk-based pricing model and
risk ratings to include sea surge and
landslide risks across New Zealand
1
.
Tower was the first New Zealand insurer to introduce
risk-based pricing for earthquakes in 2018, followed
by inland flooding in 2021. We expanded this model to
include landslide and sea surge risks in August 2025,
enabling more targeted premium calculations for natural
hazard risks for Kiwi homes, and aiming to reduce cross-
subsidisation.
Tower’s risk-based pricing strategy aims to provide
information to Kiwi about the extent to which Tower sees
these four natural hazard risks impacting their house, and
to show how these natural hazard risks are reflected in
Tower’s insurance premiums. The expansion also allows
Tower to offer targeted pricing to lower risk homes in a
competitive market, supporting long-term growth.
As a result of the introduction of landslide and sea
surge risk-based pricing, over 90% of Tower’s existing
customers
2
will receive a reduction in the natural hazards
portion of their premium at renewal over the year starting
from October 2025, when the first customers will renew
following launch – with average savings of approximately
NZD $70 per policy.
Fewer than 10% of properties – those with higher risks
– will see increases to the natural hazards portion of
their premiums. For some customers, Tower will smooth
increases over up to four years to support affordability and
customer retention.
Tower has engaged with globally recognised risk
modelling firms to develop our risk-based pricing
models: Moody’s for flood and earthquake, Haskoning
for sea surge, and Swiss Re for landslide.
Risk ratings are publicly accessible via Tower’s online
quote tool
1
. For Tower customers, risk ratings can also
be found in My Tower, either at policy purchase or
renewal for existing customers
2
.
Since launch, Tower has met with various central and
local government officials to share insights from our
landslide and sea surge risk-based pricing projects.
We look forward to continuing to do our part to support
climate adaptation for Kiwi communities through these
presentations and discussions.
Average savings in the natural hazards
premium portion, per policy
2
$
70
More than 90% of Tower customers
receiving reductions in the natural
hazards portion of their premium
2
90
%
1 Address-level risk-based pricing and risk ratings are available through Tower’s
online quote journey for New Zealand properties that meet our criteria for New
Zealand house and landlord policies, excluding some addresses requiring referral
to a Tower customer agent (which includes rural lifestyle block policies). For
policies that require referral to a Tower customer agent, address-level risk-based
pricing and risk ratings are available as part of a referral conversation.
If no risk data exists for one or more of the hazards at a specific address,
community-level data is used to calculate the natural hazard portion of the policy
premium instead and the risk rating will display ‘unknown’. ‘Community-level data’
means aggregated risk insights within a specific geographic area or community.
2 Over the year commencing October 2025.
ANNUAL REPORT 2025142025 in reviewSustainabilityConsolidated financial statementsOur strategy ContentsGRI content index Corporate governance

Committed to improving our customer experience
Over the past few financial years,
we’ve worked hard to put things right
for customers who did not receive
the discounts or benefits they were
entitled to, or experienced other policy
errors. Throughout FY25, we remained
focused on delivering positive
customer outcomes and experiences.
We have apologised to customers who have been
affected by errors in applying our multi-policy discounts
(MPD) and we have undertaken a comprehensive
remediation programme to compensate affected
customers.
During the year, Tower made the decision to discontinue
MPD. Despite ongoing investment in system and
process improvements, the complexity of accurately
calculating MPD continued to pose a risk of error for
some customers. This fell short of Tower’s commitment
to high standards in customer experience and was
unacceptable for meeting regulatory requirements.
In 2024, Tower announced that the Financial Markets
Authority had commenced proceedings in the High
Court in relation to Tower’s misapplication of MPD. This
followed Tower’s self-reporting of the issue. Tower and
the FMA have reached a settlement in relation to Tower’s
misapplication of its MPD and we are awaiting the final
decision from the High Court.
Tower’s MPD remediation programme is nearing
completion. Once finalised, Tower will have paid
approximately $12m to affected customers, including
interest. Payments to customers for the MPD
remediation have been in line with the amounts
previously provided for.
As at the end of FY25, Tower had provisioned
$10.3 million for compliance and remediation activities,
including the provision for the MPD penalty.
We accept and regret the impact these mistakes have
had on our customers and apologise unreservedly to
those whose premiums were charged inaccurately or who
have experienced other errors.
Significant investment has already been made in systems
and processes – embedding Conduct of Financial
Institutions (CoFI) principles, mapping clear processes, and
strengthening decision-making across the business.
Looking ahead, we’ll continue to review our pricing to remain
competitive, as well as focusing on continuous improvement,
with the aim of preventing future errors and ensuring all
customers receive the benefits they are entitled to.
15ANNUAL REPORT 2025 ContentsGRI content index Corporate governanceConsolidated financial statementsSustainability2025 in reviewOur strategy

Innovative &
operationally
excellent
ANNUAL REPORT 202516 Contents2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Our strategy

Building the foundations for an AI-enabled future
In FY25, Tower took steps towards
becoming an AI-enabled insurer
by further strengthening our data
foundations, incorporating AI into our
strategy, and creating Tower’s first
AI operating model.
By incorporating AI into our strategy, we aim to
unlock greater business and customer value through
technologies such as agentic AI and generative AI, and
increased use of machine learning.
Key opportunities include continued claims
transformation, enhancing the customer experience,
service optimisation, enabling more granular risk-based
pricing, and improving data quality, governance and
management.
A key example of this future-focused work is Tower’s
AI-enabled contact centre. More information can be
found on page 18.
This financial year, we appointed our first Chief Data and
Analytics Officer, and announced the appointment of
our new Chief Digital and Technology Officer, who joined
Tower in November 2025.
We also launched the Tower AI Design Forum. The
forum’s role is to ensure safe, responsible adoption of
AI, while overseeing the evaluation and prioritisation
of AI-use cases across the business.
FY25 marked an important year in laying a solid
foundation for the responsible and effective use of AI in
FY26 and beyond.
ANNUAL REPORT 202517 Contents2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Our strategy

Enhancing the contact centre experience with AI
In FY25, Tower launched an
AI-enabled contact centre platform,
marking a key milestone in our
digital transformation and reinforcing
our commitment to innovation and
operational efficiency.
We partnered with Deloitte and Amazon Web Services
(AWS), to modernise our contact centre to better support
customers, particularly during periods of increased
demand.
We ran a small pilot project in FY24, collaborating with
Deloitte New Zealand’s AI Institute and using Amazon
Bedrock to explore how emerging AI technologies could
enhance customer service. Following this, we worked
with Deloitte and AWS to launch a new AI-driven contact
centre platform on 14 August 2025, built on Amazon
Connect. The platform brings together customer data,
improved call routing, real-time transcription, sentiment
analysis, and summarisation, enabling agents to deliver
faster, more consistent service across channels.
While the AI-driven contact centre platform is in the
early stages of implementation, operational efficiencies
are already allowing customers to receive quicker, more
tailored support.
We expect the new platform to embed and realise its full
potential throughout FY26, with additional features rolled
out across the year.
ANNUAL REPORT 202518 Contents2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Our strategy

Elevating customer experience through digitisation
and more efficient operations
Throughout FY25, Tower continued
its investment in self-service
digitisation as part of our ongoing
digital transformation. By combining
these advancements with our
ability to leverage our Suva hub, we
improved efficiency, effectiveness,
and customer experience –
strengthening our resilience during
peak claims periods and supporting
our sustainable growth.
of NZ sales and service
calls answered by Suva
hub vs. 55% in FY24
of NZ customers now
registered for My Tower,
up from 53% in FY24
Customer NPS for My Tower,
up from +36 in FY24
83
%
59
%
+42
Sales and service
calls in FY25,
down from
329,000 in FY24.
317,300
NZ sales and service abandonment
rate, improved from 8% in FY24
7
%
NZ sales online, in line with FY24
of NZ service tasks completed
in digital self-service channels,
vs. 44% in FY24
1
63
%
51
%
1 Digital service tasks are any policy, payment, or account related tasks made through
the My Tower portal divided by the total number of policy adjustments made across
all channels.
of Tower’s NZ service
experience now digitally
enabled, up from 73% in FY24
79
%
ANNUAL REPORT 202519 Contents2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Our strategy

Changing the way we operate
In April 2024, we launched
Foundations First, a strategic
programme focused on
strengthening our business
fundamentals.
Key workstreams included:
• Carrying out all customer remediations
• Investigating root causes of various incidents with
a view to developing strategies to address those
root causes
• Enhancing delivery and project execution
• Improving end-to-end customer data management
at Tower.
Each workstream has delivered principles which are now
being embedded across Tower – to achieve more robust
consideration and analysis, bigger picture thinking, and
improved collaboration.
Work undertaken as part of this programme also
culminated in a decision to cease offering a multi-policy
discount.
An update on Tower’s remediation programme can be
found on page 15. An overview of work in the year to
further uplift our risk culture can be found on page 31.
As we continue to strengthen our foundations, we are
incorporating new ways of working into our everyday
operations, to build a culture of process excellence.
20ANNUAL REPORT 2025 ContentsGRI content index Corporate governanceConsolidated financial statementsSustainability2025 in reviewOur strategy

Sustainable
growth
ANNUAL REPORT 202521 Contents2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Our strategy

Building a stronger, more resilient portfolio
to deliver sustainable growth
Tower is focused on achieving
sustainable, profitable growth through
ongoing portfolio improvements. This
includes targeting lower-risk properties
and using data to automate and inform
pricing and underwriting decisions.
Managing volatility and responding to
change for shareholders and customers
A range of factors influenced premium increases over
recent years including reinsurance costs, crime rates,
inflation, supply chain pressures, and weather events.
In FY25, particularly the 2025 calendar year, pressure
from these factors began to subside and we continued
to reduce premiums.
Our agile pricing and underwriting capabilities allow us
to adjust pricing quickly in response to macroeconomic
conditions. This enables us to remain competitive, while
delivering shareholder value through sustainable growth.
For example, we continuously monitor the pricing
and performance of vehicles at a make and model
level. Throughout FY25, these reviews delivered pricing
reductions for 96 of the 100 most common makes
and models in Tower’s motor portfolio, at an average
premium decrease of approximately 5%. This included
targeting some of the most popular lower-risk
vehicles in New Zealand, such as the Toyota RAV4 and
Mitsubishi Outlander, with premium reductions higher
than the 5% average.
In total, we made 42 pricing and underwriting
adjustments across FY25, down from 68 in FY24. We
continue to manage market volatility and claims costs
by enhancing operational efficiency through risk-based
pricing, advancing our claims transformation initiatives,
and automating our underwriting processes.
House policy growth driven by strategic focus
on high-quality risk selection
In FY25, Tower achieved strong growth in house
insurance policies, growing the portfolio by 11%,
compared to 5% net policy growth in FY24. Our customer
base grew by 4% to 318,000.
This growth was reflective of our strategic focus
on the house insurance market, targeted at attracting and
retaining customers with high-quality, lower-risk properties.
ANNUAL REPORT 202522 Contents2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Our strategy

$
443
M
Tower Direct GWP flat
2
with
FY24, 22% increase in policies
sold in FY25
House policy growth in FY25
11
%
1 Adjusted to exclude FY24 divested portfolios which include the Solomon Islands
business and Vanuatu subsidiary.
2 Adjusted to exclude the New Zealand commercial rural portfolio, divested in FY24.
As shared with the market in the year, customer
numbers continued to grow, while average premiums
reduced. This is due to a higher proportion of lower-
risk new policies, consistent with Tower’s risk-based
pricing approach, and more competitive pricing in the
New Zealand market.
In line with our strategy, expected average annual loss
from flooding reduced by 21% on a per-policy basis, and
16% overall, compared to the previous year, improving
portfolio resilience and sustainability.
Alongside our commitment to risk-based pricing and a
sharpened focus on lower-risk property segments, our
forward-thinking, future-ready brand platform resonated
with New Zealanders and aims to attract new customers.
Through these initiatives, we’ve aimed to deliver value
for customers and further assist Tower to remain well-
positioned for sustainable growth.
Streamlining our commercial offering
in the Pacific
Following comprehensive reviews of commercial
accounts across Samoa, American Samoa, Tonga, the
Cook Islands, and Fiji throughout FY24 and FY25, Tower
has streamlined its commercial property policies and
products in the Pacific. This aligns with our strategy to
tighten our risk appetite in-region and focus on personal
lines and SMEs. This aligns with our strategy to tighten
our risk appetite in the region and focus on personal
lines and SMEs.
This shift has contributed to flat underlying
1
Pacific GWP
at $42m in FY25. By strengthening our Pacific portfolio
and focusing on our core personal lines and SME offering,
we aim to increase Tower’s resilience to large weather
events in the region while creating a more consistent
customer experience across countries.
ANNUAL REPORT 202523 Contents2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Our strategy

Our strategic partners
Tower’s retail and advisory referral
partnerships continued to drive
growth in FY25.
In FY25, we were pleased to see partnerships’ GWP
increase by 12% compared to the year prior.
We continued to work with our partners, including
Trade Me Insurance, and referral partners such as
New Zealand Financial Services Group, Kiwi Adviser
Network, New Zealand Home Loans, and the
New Zealand Defence Force, all of which continue
to introduce new customers to Tower.
In the year, we further digitised our customer
experience, introducing online quote completion for
customers referred to Tower through our advisor model.
Since 14 August 2025, customers who are unable to
finish a quote during the initial referral call have received
a unique link, with pre-populated details, to complete
their quote and purchase a policy online – rather than
needing to call back to progress their insurance. This
streamlined experience is aligned with our Tower Direct
online journey.
We also built on the success of our bank partnerships
model, which delivers tailored support to Kiwibank
and TSB home loan customers, announcing a new
partnership with Westpac NZ in September 2025, to
provide general insurance products to the bank’s retail
customers from July 2026.
Under this agreement, we will underwrite and supply
house, contents, motor, and landlord insurance products,
which Westpac NZ will offer under its own brand. We will
also establish a referral arrangement for Tower’s broader
suite of insurance offerings.
Through this partnership, we’ll deliver data-driven
insurance experiences integrated into Westpac NZ
digital banking. This includes the ability for customers
to purchase, manage, and claim on policies online, as
well as access Tower’s risk-based pricing and natural
hazard risk information about their homes, all within their
Westpac NZ online banking experience.
The partnership supports Tower’s strategic focus on
growing our home insurance portfolio and will contribute
to our future growth targets.
Partnerships’ GWP, up 12%
from FY24
$
115
M
Increase in total partnerships’
policies vs. FY24
18
%
ANNUAL REPORT 202524 Contents2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Our strategy

Forward thinking,
future ready
In FY25, Tower launched our
new brand platform and tagline:
forward thinking, future ready.
This evolution reflects our commitment to making
insurance simple and accessible, while helping Kiwi
prepare for whatever life brings. It also marks our shift
from traditional insurance to a progressive, digitally-led
approach.
To support this refreshed direction, we launched The
Misses in June 2025. Inspired by customer insights, the
campaign introduced ‘Miss Haps’, ‘Miss Takes’, and ‘Miss
Fortune’ - playful characters that personify life’s mishaps.
Through humour and reassurance, we aim to show
customers Tower is here to help when things go wrong.
We were proud to receive Kantar’s June 2025 Ad
Impact Award, recognising the campaign’s creativity and
resonance with Kiwi audiences.
For Tower, forward thinking, future ready is more than a
tagline. As a Kiwi company, it reflects our commitment
to innovation and customer-centricity. From simplifying
products and digitising experiences to offering
competitive pricing and upholding our values, every
initiative supports our brand vision: we do the forward
thinking, so our customers can be future ready.
ANNUAL REPORT 202525 Contents2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Our strategy

Reinsurance programme underpins growth
ambitions and supports strong solvency
Tower’s reinsurance arrangements
help us to maintain competitive
pricing for customers while protecting
the business from the financial impact
of large events.
We renewed our reinsurance programme for FY26 with
comprehensive reinsurance cover at competitive rates
for home, motor, boat, and commercial portfolios across
New Zealand and our Pacific markets.
Overall, reinsurance premiums for FY26 are expected to
be lower compared to FY25, due to more attractive rates
and a structural change in protection for large individual
property risks, from proportional to excess of loss cover
1
.
Tower’s FY26 reinsurance programme includes:
• Increased catastrophe upper limit of $915m for the
first two events, up from $800m in FY25
• Cover for a third catastrophe event up to $85m,
unchanged from FY25
• Reinsurance excess of $20m for the first two events,
up from $18.75m in FY25, due to the expiry of multi-
year arrangements
• $20m excess for a third event, unchanged from FY25.
Tower’s risk-based pricing strategy, our ability to
dynamically adjust rates and a more competitive
reinsurance market enabled us to secure favourable
terms for FY26.
We continued to strengthen partnerships with global
reinsurers, with several committing to new multi-year
agreements. These arrangements offer greater certainty
around future reinsurance costs and catastrophe
excesses, supporting our resilience.
Cover in place for a third
catastrophe event in FY26
$
85
M
Cover in place for first two
catastrophe losses in FY26
$
915
M
1 Proportional reinsurance means the insurer and reinsurer share premiums and
claims in agreed proportions. Excess of loss reinsurance means Tower retains
responsibility for claims up to a certain threshold, with the reinsurer covering losses
above that amount.
ANNUAL REPORT 202526 Contents2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Our strategy

Effective &
distinctive
culture
27ANNUAL REPORT 2025 ContentsGRI content index Corporate governanceConsolidated financial statementsSustainability2025 in reviewOur strategy

Empowering our people to achieve great things
Our people come first
One of our core values is ‘our people come first’. We live
up to this value by creating a workplace where our team
members can bring their whole selves to work.
On top of fostering career progression and opportunities
for growth at Tower, we offer a range of benefits. To help
ensure we continue to attract and retain top talent, in FY25
we increased our parental leave benefit in New Zealand
from 16 weeks to 26 weeks full pay for primary care
givers. In the Pacific, we continue to offer 16 weeks full
pay parental leave for primary caregivers and across all
countries, four weeks full pay for partners. Tower also has
seven employee representative groups (ERGs), which
reflect the makeup of our people and work to enhance
the employee experience for our teams – 31% of Tower
staff are members of an ERG.
In FY25, our ERGs led important events such as:
Te Wiki o te Reo Māori, Matariki, Lunar New Year, Diwali,
World Inclusion Day, Hoods Up for Autism Acceptance
Month, Te Maeva Nui 2025 – the 60th anniversary of
self-governance in the Cook Islands and Fiji Day, the
Auckland Pride Parade, and Sweat with Pride.
In our latest engagement survey in September 2025,
we were proud to record our highest ever employee
engagement score, at 8.2, up from 8.1 at the end of FY24.
Additionally, our overall diversity and inclusion score was
8.7, and our wellbeing score was 8.4 – both scores rank in
the top 25% of the global finance sector.
We were delighted that our score for peer relationships
was 9, placing Tower in the top 5% of the global
finance sector.
Top 5% for peer relationships in
the global finance sector, with an
employee score of 9
1
5
%
Employee engagement score
1
8.2
Driving a high-performance culture
In the year, our Talent & Culture Group (TCG),
comprised of diverse senior leaders, including our
executive leadership team (ELT), worked with the
business to define 11 cultural levers.
These levers include collaboration and connection,
empowerment and growth, innovation and growth
mindset, and wellbeing and balance.
Our cultural levers will be assessed against business
priorities and projects and dialled up or down to assist with
delivery. Overall, they will be used alongside our strategy
and values to help drive a high-performance culture.
1 As at 12 September 2025, based on Tower’s latest staff engagement survey.
ANNUAL REPORT 202528 Contents2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Our strategy

Our people come first
ANNUAL REPORT 202529 Contents2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Our strategy

New Zealand’s ‘Mind the Gap’
register tracks and publishes
pay gap data for participating
businesses. Tower was among
the first 50 companies to join the
register in 2022, publicly reporting
our pay gap data. To the right is our
FY25 pay equity data.
Gender pay gap
When we take the total salary for all women employed by Tower, and divide that by the number
of women, and the total salary of all men employed by Tower and divide that by the number
of men, we have a gap of 16.5% for our workforce in New Zealand. For our workforce in Fiji we
have a gap of 11.9%. For the most part, this is because we have a larger proportion of women in
frontline roles in both New Zealand and Fiji.
Gender pay equity gap
When we compare like-for-like roles for women and men, our pay equity gap is 0.3% for our
workforce in New Zealand, and 0.8% for our workforce in Fiji (men are paid 0.3% more than
women for the same role in New Zealand and 0.8% more in Fiji).
Leadership gender pay gap
Comparing our senior leadership population and the average pay gap between men and
women, our New Zealand leadership pay gap is -3.9% (women are paid 3.9% more than men.
This is because there is a higher proportion of men in lower-level senior leadership roles, which
impacts the overall weighted average).
Leadership gender pay equity gap
When we compare like-for-like roles for our leadership population at Tower in New Zealand, our
leadership pay equity gap is 4.0% (men are paid 4.0% more than women for the same role).
16.5
%
0.3
%
-3.9
%
4.0
%
ANNUAL REPORT 202530 Contents2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Our strategy

Continuously advancing our risk culture
Having a strong risk culture is key
to Tower’s resilience and vital for
customers. Core to this is ‘tone
from the top’ from Tower’s Board of
Directors and Executive Leadership
team, underpinned by Tower’s
enterprise-wide Risk Management
Framework (RMF).
During the year, we advanced our Three Lines of
Defence Model
1
to uplift risk capabilities across
business units, including at our Suva Hub and across
major strategic initiatives. This extension bolsters risk
identification and assessment, control testing and quality
assurance outcomes.
Tower’s CoFI fair conduct programme strengthened the
focus on fair customer outcomes in line with Tower’s
drive to be more customer-centric. Implementing
CoFI was a whole-organisation effort, with significant
emphasis on product governance, communication,
complaints, and vulnerable customers.
Work continues to find and fix root causes of
incidents reported by the business. This work is enabled
by a speak-up culture actively encouraged from the
top down.
To help ensure we get things right for our customers,
we continued to address historical root cause factors
through our ways of working project and process
excellence practice, as part of the Foundations First
programme. More information can be found on page 20.
We also expanded leadership training and development,
and instituted ‘the Tower way’ to address incidents of
root causes linked to people and culture.
Tower was pleased to once again see a positive risk
culture score in FY25 as a result of our continued efforts
2
.
Risk Culture employee score,
consistent with FY24
2
8.3
1 The Three Lines of Defence (3LOD) model is a framework for managing risk within
an organisation. It is a widely used model across many industries and worldwide.
2 Employee engagement surveys are run twice yearly, in March and September,
scores are compared from our September 2024 survey and our latest survey,
completed September 12 2025.
ANNUAL REPORT 202531 Contents2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index Our strategy

Environmental,
social and
governance
performance
32ANNUAL REPORT 2025 ContentsGRI content index Corporate governanceConsolidated financial statementsOur strategy2025 in reviewSustainability

Looking after our business, communities,
and environment
Our FY20-FY25 sustainability
strategy
Tower’s FY20-FY25 sustainability strategy outlined our
most material sustainability impacts and priorities for the
2020 to 2025 financial years.
Developed in 2021, the strategy supported Tower’s
purpose: to inspire, shape and protect the future for our
customers and communities. Its core pillars were:
• Diverse and inclusive to the core
• Thinking ahead for our planet
• People’s go-to trusted insurance partner
• Helping communities navigate climate change
Our FY20-FY25 material impacts
We’re pleased to report strong progress across all key
areas of our environmental, social, and governance (ESG)
performance during the FY20-FY25 period.
Key achievements in the five-year period include:
• Introduction of risk-based pricing in New Zealand for
inland flooding, sea surge, and landslide risks
• Launch of Cyclone Response Cover, our first
parametric product, in Fiji, Samoa, and Tonga
• Exceeding our science aligned five-year greenhouse
gas (GHG) emissions reduction target by 3%, achieving
a total reduction of 24%
• Transition of our New Zealand vehicle fleet to hybrid
vehicles
• Introduction of employee volunteer leave
• Strengthening of diversity and inclusion initiatives
• Improvements in employee engagement scores and
introduction of employee representative groups to
celebrate and support diversity and inclusion at Tower.
Materiality is an assessment of how the activities of
a business impact society, the environment, specific
stakeholders and the business itself. That business may
have caused these impacts, contributed to them or have
links to the impacts.
Our 12 most material impacts during FY20-FY25 are
detailed in the FY25 Material Impacts Table, available in
the sustainability section of our website, which includes
progress against each material impact target.
Introducing our FY26-FY30
material impacts
Ahead of introducing our new Sustainability Strategy for
FY26-FY30, Tower undertook a comprehensive review
of our material topics in FY25. This updated Materiality
Assessment was guided by the Global Reporting
Initiative (GRI) Standard 3 and incorporates the principle
of double materiality – considering both Tower’s impact
on environmental and social conditions, and how these
conditions affect our operations.
We tested material topics, impacts, and priorities through
workshops with Tower senior leaders and staff, as well
as interviews with external stakeholders and industry
representatives, shareholders, and government relations
experts.
Input from our internal customer relations teams
enabled us to consider customer priorities, as well as
publicly available market research, including the Kantar
Better Futures Report 2025. We also reviewed our
existing sustainability commitments and affiliations, and
memberships with the Sustainable Business Council,
Climate Leaders Coalition, and Toitū Tahua: Centre for
Sustainable Finance.
Each identified material topic was assessed using
a structured impact scoring methodology, allowing
us to prioritise topics based on their significance to
stakeholders and the scale of their impact on our
business and society.
For the FY26-FY30 strategy period, our 11 most material
impacts are below:
• Climate change resilience
• Affordable, accessible insurance
• Transparent and fair insurance services
• Customer experience
• Data protection
• Greenhouse gas emissions
• Environment & Nature
• Te Ao Māori
• Employee wellbeing
• Employee development
• Corporate community citizenship
ANNUAL REPORT 202533 ContentsOur strategy2025 in reviewConsolidated financial statementsCorporate governanceGRI content index Sustainability

Introducing our FY26-FY30
sustainability strategy
After identifying our most material topics, we developed
a refreshed Sustainability Strategy for FY26 – FY30.
This strategy is designed to support the delivery of
Tower’s broader business strategy, outlined on page 9.
In FY26, we will finalise our associated Sustainability
Strategy Action Plan, including targeted initiatives,
performance metrics, and measurable goals to ensure
we effectively implement and track progress against our
sustainability objectives.
• Providing no-surprises, easy to understand
insurance that is accessible and affordable.
• Provide an efficient claims process to support
recovery after a large event.
• Actively collaborate on issues affecting
customers, the insurance industry and
communities we serve.
• Focus on supporting a climate resilient
future for New Zealand and the Pacific.
• Support initiatives that benefit nature and
the environment.
• Mitigate the carbon footprint of our
business including our supply chain.
Our BusinessOur Environment
• Focus on leadership development to foster a
culture of good business ethics and develop
talent to support our customers and partners.
• Foster the mental and physical wellbeing of all
employees including continued improvement
in DEI metrics.
Our People
• Contribute to collective advocacy on climate
change, resilience and data resources.
• Demonstrate good corporate citizenship
through our sponsorship and volunteering
programmes.
• Education on risks and preparedness.
Our Customers & Community
ANNUAL REPORT 202534 ContentsOur strategy2025 in reviewConsolidated financial statementsCorporate governanceGRI content index Sustainability

FY25 Climate Statement
In FY24, Tower published our first Climate Statement
in response to the NZ Aotearoa Climate Standards. In
our second year of disclosure, we have provided an
update on our climate-related risks, opportunities and
governance, and introduced the transition planning
aspects of our strategy.
Tower’s FY25 Climate Statement, which includes
detailed information about our governance of climate
change and ESG issues, can be accessed in the
sustainability section of our website.
GHG emissions performance
FY25 marks the final year of our first greenhouse gas
(GHG) emissions reduction target period. Our absolute,
science-aligned target for Scope 1 and 2 emissions,
set against a 2020 baseline, aimed for a 21% reduction
by 2025.
A comprehensive review of our 2020 emissions
inventory and the completion of our first year of
limited assurance confirmed that we have achieved
a total emissions reduction of 24%, exceeding our
target by 10 tCO₂e. This reduction was primarily driven
by our move to a 6 Green Star-rated head office in
Auckland and the transition of our New Zealand fleet
to hybrid vehicles.
The review also identified restatements to previous
years’ reporting as well as opportunities to improve
our data collection and calculation methodologies,
which we implemented during the financial year.
Our FY25 Climate Statement details our GHG
emissions target for the FY26-FY35 period for Scope
1 & 2 emissions. We will develop a detailed reduction
plan in FY26 to establish a clear pathway to achieving
this target.
ESG governance
Tower’s Board supports the development of Tower’s
ESG practices, monitoring progress and performance
via periodic updates from management. We formalise
ESG governance through an executive-level steering
committee, chaired by our Interim CFO, which oversees
progress on our initiatives and monitors environmental
and social risks.
Our Head of Corporate Affairs and Sustainability
coordinates our ESG performance, supported by our
Sustainability Manager.
ANNUAL REPORT 202535 ContentsOur strategy2025 in reviewConsolidated financial statementsCorporate governanceGRI content index Sustainability

Partnering with communities in New Zealand and
the Pacific to help inspire, shape and protect the future
Tower was proud to partner with our
communities across New Zealand and
the Pacific in FY25.
Tower New Zealand Local Hero of the
Year Award Te Pou Toko o te Tau
In FY25, Tower became the sponsor of the New Zealand
Local Hero of the Year Award Te Pou Toko o te Tau. The
award is part of the Kiwibank New Zealander of the Year
Awards Ngā Tohu Pou Kōhure o Aotearoa.
The Tower New Zealand Local Hero of the Year Award
recognises 100 local heroes across the country. We’re
pleased to have deepened our relationship with Kiwibank
via this new flagship sponsorship, which presents a unique
opportunity to strengthen our ties to our communities.
The first New Zealander of the Year Awards with Tower as
a key sponsor will take place in March 2026.
“ The Tower New Zealand Local Hero of the
Year Award celebrates the quiet champions
who uplift our people and places every day.
It’s a treasured category in the Kiwibank
New Zealander of the Year Awards and we’re
so pleased to welcome Tower as the new kaitiaki
of this award – helping us continue to honour
the everyday heroes shaping their corner of
Aotearoa for the better.”
– Miriama Kamo, Te Koruru Patron of the Kiwibank
New Zealander of the Year Awards.
ANNUAL REPORT 202536 ContentsOur strategy2025 in reviewConsolidated financial statementsCorporate governanceGRI content index Sustainability

Supporting future climate leaders
and everyday Kiwi
In the year, Tower also reached four years of supporting
Coastguard New Zealand to help bring Kiwi home safe
and five years of the Tower Climate Change Scholarship.
The scholarship supports up to three students annually
with $5,000 towards their Bachelor of Climate Change
degree studies at the University of Waikato. This year,
three students were awarded scholarships.
Bolstering insurance uptake and awareness in
the Pacific with parametric insurance
In the Pacific, we continued to increase insurance
awareness and accessibility, with 52 villages visited
across Fiji’s islands in partnership with the InsuResilience
Investment Fund, during roadshows for Cyclone
Response Cover, Tower’s parametric product.
In the year, Tower also took part in the 53rd Pacific
Islands Forum Leaders Meeting in Tonga, the 2024
Commonwealth Heads of Government Meeting
Business Forum (CHOGM) in Samoa and the Climate
Finance Dialogue for a Resilient Asia-Pacific in Thailand.
Tower staff presented and participated in roundtable
and panel discussions at these global events, speaking
about Tower’s Cyclone Response Cover journey
and the power of parametric insurance to reach
underserved communities.
Cyclone Response Cover is available in Fiji, Samoa,
and Tonga. It’s a lower-cost insurance product designed
to help customers recover from a high wind-speed
event. Tower launched its second parametric product,
Rainfall Response Cover, in Fiji in mid-November 2025.
More information can be found in the ‘news’ section
of tower.co.nz.
3,197 hours of volunteering across New Zealand
and the Pacific
All permanent, full-time Tower employees receive one
annual volunteer leave day to support a cause they are
passionate about.
In FY24, our teams recorded 2,300 volunteer hours
across New Zealand, Fiji, Tonga, Samoa, American
Samoa, and the Cook Islands – exceeding our target
of 1,000 hours.
Building on this effort, we set a target of 2,500 volunteer
hours for FY25. We are proud to share that we reported
3,197 hours for the year.
ANNUAL REPORT 202537 ContentsOur strategy2025 in reviewConsolidated financial statementsCorporate governanceGRI content index Sustainability

Board of Directors
Michael Stiassny
LLB, BCom, CFInstD
Chairman
Non-Executive Director
Director from:
12 October 2012
Michael holds both a Commerce and Law degree
from the University of Auckland and is a Chartered
Fellow and past President of the Institute of Directors.
Michael has enjoyed a high-profile governance career
and is currently Chairman of 2 Cheap Cars Group
Limited, and director of Tegel Group Holdings Limited,
and New Talisman Gold Mines Limited.
Michael resides in Auckland – New Zealand.
Marcus has significant insurance industry experience.
For a decade he has performed senior leadership
roles for Zurich in Europe and globally. In his last role
at Zurich, he served as the Chief Executive Officer of
Zurich Germany managing both life insurance and
general insurance businesses.
Marcus holds a Master’s Degree in Banking and
Finance from Goethe University in Frankfurt, Germany
and Master of International Management from the
Arizona State University Thunderbird School of Global
Management in Arizona, United States of America.
Marcus was initially nominated by Bain Capital Credit
LP in 2019 (Bain Capital) to represent Bain Capital’s
stake in Tower (Bain Capital held 20.00% of Tower’s
ordinary shares at the time of his appointment, which
was supported by the Tower Board). However, following
the sale of Bain’s stake in Tower in FY25, the Board
determined that Marcus is independent pursuant to the
NZX Listing Rules and Corporate Governance Code.
Marcus resides in Schindellegi – Switzerland.
Geraldine has extensive governance and technology
industry experience, having performed Board and
senior leadership roles both in New Zealand and
internationally, with Sky Network Television Limited,
SAP, Dell, IBM, National Australia Bank and Fisher &
Paykel Healthcare. Geraldine is the founder and CEO
of MyWave. Geraldine holds a Bachelor of Science
from Victoria University and is a Chartered Member
of the NZIOD.
Geraldine resides in Christchurch – New Zealand.
Geraldine McBride
BSc
Non-Executive Director
Director from:
1 October 2022
Marcus Nagel
MBA (International
Management),
MBA (Banking and Finance)
Non-Executive Director
Director from:
14 January 2019
ANNUAL REPORT 202538 ContentsOur strategy2025 in reviewConsolidated financial statementsCorporate governanceGRI content index Sustainability

Naomi Ballantyne
PGDipBUS
Non-Executive Director
Director from:
21 May 2025
Naomi Ballantyne brings a wealth of experience and
expertise in the financial services sector, particularly
in the New Zealand insurance industry. In 2023, Ms
Ballantyne sold Partners Life Limited, the highly
successful insurance company she founded in 2010.
An entrepreneur with both executive and governance
skills, Ms Ballantyne is currently the Managing Director of
KNK Consulting Limited, Chair of insurance distribution
group TAP Group Limited, and a Director of Dai-ichi Life
Asia Pacific Limited - the regional office of International
Life Insurance Corporation.
Prior to this, Ms Ballantyne founded and was the
Managing Director of Unique Solutions and Advice
Limited and ING Life (NZ) (now Chubb) and served as
Chief Operating Officer of Sovereign Limited (now AIA)
for 12 years. Her previous directorships include Accuro
Health Insurance, Newpark Financial Services Limited,
Club Life Limited, and New Zealand Superannuation
Services Limited.
Naomi is a graduate of the London Business School and
holds a Post Graduate Diploma in General Management
from the University of Auckland.
Naomi was appointed by the Board to fill a casual
vacancy. She will retire at the Annual Shareholders
Meeting in February 2026 and is eligible for re-election.
Naomi resides in Whangārei – New Zealand.
Mike has significant experience in a range of
financial services businesses in Australia, New Zealand,
Asia and Europe. He is the Chair of PF Bid Co. and
Fairway Group Limited, and a Non-Executive Director
of Pepper Money and Revolut Payments Australia
Pty Ltd. He is the co-founder of Kadre, a credit risk
management consultancy.
Mike has recently served as interim Managing Director
for Bambora Aus and was previously the Group
Managing Director for Equifax ANZ. Before this he held
various senior roles with GE, ANZ, Wesfarmers/OAMPS
Insurance Brokers, Halifax/BankOne and NAB.
Mike is a Senior Fellow of Financial Services Institute
of Australia and Graduate of the Australian Institute
of Company Directors. He has served on the Boards
of the Women’s Cancer Foundation, Ovarian Cancer
Institute, the Australian Finance Congress, the National
Insurance Brokers Association and the Australian
Retail Credit Association.
Mike resides in Melbourne – Australia.
Mike Cutter
BSc (Hons) GAICD
Non Executive Director
Director from:
17 November 2023
ANNUAL REPORT 202539 ContentsOur strategy2025 in reviewConsolidated financial statementsCorporate governanceGRI content index Sustainability

Consolidated
financial
statements
40ANNUAL REPORT 2025 ContentsGRI content index Corporate governanceConsolidated financial statementsSustainabilityOur strategy2025 in review

Financial Statements
Consolidated statement of comprehensive income
42
Consolidated balance sheet43
Consolidated statement of changes in equity44
Consolidated statement of cash flows45
Notes to the consolidated financial statements
1Overview46
1.1About this report46
1.2Consolidation46
1.3Critical accounting judgements and estimates48
1.4Changes in accounting policies and disclosures48
1.5Segmental reporting48
2Insurance and reinsurance contracts50
2.1Insurance and reinsurance contracts accounting policies50
2.2Insurance service expense and other operating expenses52
2.3Net insurance finance expense53
2.4Insurance and reinsurance assets and liabilities53
2.5Receivables60
2.6Payables61
2.7Provisions61
3Investments and other income62
3.1Investment income62
3.2Investments62
3.3Other income63
4Risk management63
4.1Risk management overview63
4.2Strategic risk64
4.3Insurance risk64
4.4Credit risk65
4.5Market risk67
4.6Liquidity risk68
4.7Capital management risk69
4.8Operational risk70
4.9Regulatory and compliance risk70
4.10Conduct risk70
4.11Cyber risk70
4.12Environment, Social and Governance (ESG) risk71
5Capital structure71
5.1Contributed equity71
5.2Reserves72
5.3Net tangible assets per share72
5.4Earnings per share72
5.5Dividends72
6Other balance sheet items73
6.1Property, plant and equipment73
6.2Intangible assets74
6.3Leases76
7Tax 78
7.1Tax expense78
7.2Current tax78
7.3Deferred tax79
7.4Imputation credits80
8Other information80
8.1Notes to the consolidated cash flow statement80
8.2Related party disclosures81
8.3Auditor’s remuneration82
8.4Discontinued operations82
8.5Tower Long-Term Incentive Plan82
8.6Contingent liabilities83
8.7Capital commitments83
8.8Subsequent events83
Independent Auditor’s report, and Appointed Actuary’s report
Independent Auditor’s report84
Appointed Actuary’s report88
41ANNUAL REPORT 2025 ContentsOur strategy2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index

Consolidated statement of comprehensive income
FOR THE YEAR ENDED 30 SEPTEMBER 2025
NOTE
2025
$000
2024
$000
Insurance revenue594,348555,818
Insurance service expense2.2(411,648)(381,608)
Insurance service result before reinsurance contracts held182,700174,210
Net expense from reinsurance contracts held(77,505)(91,364)
Insurance service result105,19582,846
Investment income3.119,76921,800
Investment expense(548)(250)
Net investment income19,22121,550
Finance expense from insurance contracts issued2.3(2,158)(5,592)
Finance income from reinsurance contracts held2.35713,020
Net insurance finance expense(1,587)(2,572)
Net insurance and investment result122,829101,824
Other income3.34,4444,064
Other operating expenses2.2(8,782)(2,348)
Finance costs(744)(882)
Profit before taxation from continuing operations117,747102,658
Tax expense from continuing operations7.1(34,074)(31,774)
Profit after taxation from continuing operations83,67370,884
Profit after taxation from discontinued operations8.4–3,401
Profit after taxation for the year83,67374,285
NOTE
2025
$000
2024
$000
Items that may be reclassified to profit or loss
Currency translation differences2,501(1,308)
Reclassification of the foreign currency translation reserve–410
Other comprehensive profit/(loss) net of taxation2,501(898)
Total comprehensive profit for the year86,17473,387
Earnings per share:
Basic earnings per share (cents) for continuing operations5.423.318.7
Diluted earnings per share (cents) for continuing operations5.423.018.6
Basic earnings per share (cents) for profit attributable to
shareholders5.423.319.6
Diluted earnings per share (cents) for profit attributable to
shareholders5.423.019.5
The above statement should be read in conjunction with the accompanying notes
42ANNUAL REPORT 2025 ContentsOur strategy2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index

Consolidated balance sheet
AS AT 30 SEPTEMBER 2025
NOTE
30 SEPT 2025
$000
30 SEPT 2024
$000
Assets
Cash and cash equivalents8.171,04775,390
Investments3.2389,225367,506
Receivables2.512,78019,799
Current tax assets7.2a1,03113,222
Reinsurance contract assets2.4a20,90035,503
Deferred tax assets7.3a1,367382
Right-of-use assets6.3a17,15719,990
Property, plant and equipment6.15,9666,735
Intangible assets6.293,46096,621
Total assets612,933635,148
Liabilities
Payables2.627,00532,287
Insurance contract liabilities2.4b155,627177,569
Current tax liabilities7.2b20,605606
Provisions2.720,90221,959
Lease liabilities6.3a25,54628,855
Deferred tax liabilities7.3b12,58313,716
Total liabilities262,268274,992
Net assets350,665360,156
NOTE
30 SEPT 2025
$000
30 SEPT 2024
$000
Equity
Contributed equity5.1417,224460,734
Retained earnings35,9464,428
Reserves5.2 (102,505)(105,006)
Total equity350,665360,156
The above statement should be read in conjunction with the accompanying notes.
The financial statements were approved for issue by the Board on 27 November 2025.
Michael P Stiassny Naomi Ballantyne
Chairman Director
43ANNUAL REPORT 2025 ContentsOur strategy2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index

Consolidated statement of changes in equity
YEAR ENDED 30 SEPTEMBER 2025
ATTRIBUTED TO SHAREHOLDERS
NOTE
CONTRIBUTED
EQUITY
$000
RETAINED
EARNINGS/
(LOSSES)
$000
RESERVES
$000
TOTAL EQUITY
$000
Year Ended 30 September 2025
Balance as at 30 September 2024460,7344,428(105,006)360,156
Comprehensive income
Profit for the year–83,673–83,673
Currency translation differences––2,5012,501
Total comprehensive income–83,6732,50186,174
Transactions with shareholders
Dividends paid5.5–(52,155)–(52,155)
Share rights issued under Tower Long-Term Incentive Plan8.52,038––2,038
Capital return5.1(45,548)––(45,548)
Total transactions with shareholders(43,510)(52,155)–(95,665)
At the end of the year417,22435,946(102,505)350,665
Year Ended 30 September 2024
Balance as at 30 September 2023460,315 (58,473)(104,108)297,734
Comprehensive loss
Profit for the year – 74,285 – 74,285
Currency translation differences – – (1,308)(1,308)
Reclassification of foreign currency translation reserve to profit or loss8.4 – – 410410
Total comprehensive income – 74,285 (898)73,387
Transactions with shareholders
Dividends paid5.5 – (11,384) – (11,384)
Share rights issued under Tower Long-Term Incentive Plan8.5419 – – 419
Total transactions with shareholders419 (11,384) – (10,965)
At the end of the year460,734 4,428(105,006)360,156
The above statement should be read in conjunction with the accompanying notes.
44ANNUAL REPORT 2025 ContentsOur strategy2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index

Consolidated statement of cash flows
FOR THE YEAR ENDED 30 SEPTEMBER 2025
NOTE
2025
$000
2024
$000
Cash flows from operating activities
Premiums received for insurance contracts issued593,413560,514
Insurance acquisition costs paid(75,292)(68,119)
Reinsurance paid(87,989)(72,944)
Interest received17,19817,606
Fee and other income received5,6982,857
Insurance claims paid and other insurance service expenses(331,406)(386,791)
Reinsurance recoveries received25,19791,551
Other operating payments(1,764)(2,348)
Income tax paid(1,293)(1,011)
Operating activities cash flow from discontinued operations–3,872
Net cash inflow from operating activities 8.1 143,762145,187
Cash flows from investing activities
Proceeds from sale of interest bearing investments529,930404,097
Payments for purchase of interest bearing investments(554,892)(503,035)
Payments for purchase of intangible assets(20,896)(17,395)
Proceeds from sale of property, plant & equipment 6930
Payments for purchase of property, plant & equipment (1,165)(2,360)
Net proceeds from sale of discontinued operations–2,019
Investing activities cash flow from discontinued operations–76
Net cash outflow from investing activities (46,954)(116,568)
NOTE
2025
$000
2024
$000
Cash flows from financing activities
Dividends paid5.5(52,155)(11,384)
Payments for capital return5.1(45,548)–
Payments relating to lease liabilities6.3c (5,138)(5,064)
Financing activities cash flow from discontinued operations–(25)
Net cash outflow from financing activities (102,841)(16,473)
Net (decrease)/increase in cash and cash equivalents(6,033)12,146
Effect of foreign exchange rate changes1,690(2,067)
Cash and cash equivalents at the beginning of the year75,39065,311
Cash and cash equivalents at the end of the year71,04775,390
Cash and cash equivalents at the end of the year from
continuing operations71,04775,390
The above statement should be read in conjunction with the accompanying notes.
45ANNUAL REPORT 2025 ContentsOur strategy2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index

1 Overview
This section provides information that is helpful to an overall understanding of the financial statements
and the areas of critical accounting judgements and estimates included in the financial statements. It also
includes a summary of Tower’s operating segments.
1.1 About this Report
a. Entities reporting
The financial statements presented are those of Tower Limited (the Company) and its subsidiaries.
The Company and its subsidiaries together are referred to in these financial statements as Tower or the Group.
The address of the Company’s registered office is 136 Fanshawe Street, Auckland, New Zealand.
During the periods presented, the principal activity of the Group was the provision of general insurance. The
Group predominantly operates in New Zealand with some of its operations based in the Pacific Islands region.
The financial statements were authorised for issue by the Board of Directors on 27 November 2025.
b. Statutory base
Tower Limited is a company incorporated in New Zealand under the Companies Act 1993 and listed on the
NZX Main Board and the Australian Securities Exchange. The Company is a reporting entity under Part 7 of the
Financial Markets Conduct Act 2013.
c. Basis of preparation
The Company is a for-profit entity and the financial statements have been prepared in accordance with
New Zealand Generally Accepted Accounting Practice (NZ GAAP). They comply with International Financial
Reporting Standards Accounting Standards (IFRS Accounting Standards), New Zealand Equivalents to
International Financial Reporting Standards (NZ IFRS) and other applicable financial reporting standards, as
appropriate for Tier 1 for-profit entities.
The financial statements of the Group have been prepared in accordance with the requirements of Part 7 of the
Financial Markets Conduct Act 2013 and the NZX Main Board Listing Rules.
They have been prepared in accordance with the historical cost basis except for certain financial instruments
that are stated at their fair value.
Notes to the consolidated financial statements
1.2 Consolidation
a. Principles of consolidation
The Group financial statements incorporate the assets and liabilities of all subsidiaries of the Company at
reporting date and the results of all subsidiaries for the year.
Subsidiaries are those entities over which the consolidated entity has control, being 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 the amount of the investor’s returns.
The results of any subsidiaries acquired during the year are consolidated from the date on which control
was transferred to the consolidated entity and the results of any subsidiaries disposed of during the year are
consolidated up to the date control ceased.
Intercompany transactions and balances between Group entities are eliminated on consolidation.
b. Foreign currency
(i) Functional and presentation currencies
The financial statements of each Group entity are presented in the currency of the primary economic
environment in which the entity operates. Tower Limited’s functional and presentation currency is
New Zealand dollars (NZD). All amounts in the financial statements are presented in New Zealand dollars
and have been rounded to the nearest thousand dollars, unless otherwise indicated.
(ii) Transactions and balances
In preparing the financial statements of the individual entities, transactions denominated in foreign currencies
are translated into the entities functional and reporting currency using the exchange rates in effect at the
transaction dates. Monetary items receivable or payable in a foreign currency are translated at reporting date
at the closing exchange rate.
Translation differences on non-monetary items such as financial assets held at fair value through profit or loss
are reported as part of their fair value gain or loss.
Exchange differences arising on the settlement or retranslation of monetary items at year end exchange rates
impact profit after tax in the consolidated statement of comprehensive income unless the items form part of
a net investment in a foreign operation. In this case, exchange differences are taken to the foreign currency
translation reserve (FCTR) and recognised (as part of comprehensive profit) in the consolidated statement of
comprehensive income and the consolidated statement of changes in equity.
46ANNUAL REPORT 2025 ContentsOur strategy2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index

(iii) Consolidation
For the purpose of preparing consolidated financial statements, the assets and liabilities of subsidiaries
with a functional currency different to the Company are translated at the closing rate at the reporting date.
Income and expense items for each subsidiary are translated at a weighted average of exchange rates over
the period, as a surrogate for the spot rates at transaction dates. Foreign currency translation differences
are taken to the FCTR and recognised in the consolidated statement of comprehensive income and the
consolidated statement of changes in equity.
Goodwill and fair value adjustments arising on the acquisition of a foreign operation are treated as assets
and liabilities of the foreign operation and are translated at the closing rate with movements recorded
through the FCTR in the consolidated statement of changes in equity.
On disposal of a foreign entity, the deferred cumulative amount recognised in equity relating to that
particular foreign operation is recognised in the consolidated statement of comprehensive income.
c. Subsidiaries
The table below lists Tower Limited’s principal subsidiary companies and controlled entities. All entities have a
reporting date of 30 September.
HOLDINGS
NAME OF COMPANYINCORPORATION20252024
Parent Company
New Zealand general insurance operations
Tower LimitedNZParentParent
Subsidiaries
Overseas general insurance operations
Tower Insurance (Cook Islands) LimitedCook Islands100%100%
Tower Insurance (Fiji) LimitedFiji100%100%
National Pacific Insurance LimitedSamoa100%100%
National Pacific Insurance (Tonga) LimitedTonga100%100%
National Pacific Insurance (American Samoa)
Limited
American Samoa100%100%
Management service operations
Tower Services LimitedNZ100%100%
Tower Group Services (Fiji) Pte LimitedFiji100%100%
1.2 Consolidation (continued)
b. Foreign currency (continued)
47ANNUAL REPORT 2025
Notes to the consolidated financial statements (continued)Notes to the consolidated financial statements (continued)
ContentsOur strategy2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index

1.3 Critical accounting judgements and estimates
In preparing these financial statements management is required to make estimates and related assumptions
about the future. The estimates and related assumptions are based on experience and other factors that are
considered to be reasonable, and are reviewed on an ongoing basis. Revisions to the estimates are recognised
in the period in which they are revised, or future periods if relevant. The key areas in which estimates and
related assumptions are applied are as follows:
—Insurance and reinsurance contracts
Premium allocation approach (PAA) eligibility note 2.1b
Identification of groups of onerous contracts note 2.1d
Liability for incurred claims and reinsurance asset for incurred claims,
including risk adjustment and the confidence level used note 2.4
—Compliance and remediation provision note 2.7
—Intangible assets note 6.2
1.4 Changes in accounting policies and disclosures
There have been no changes in accounting policies during the year ended 30 September 2025.
No new standards, amendments, or interpretations have been adopted during the year that have had a material
impact on the Group’s financial statements.
Future changes in accounting standards
NZ IFRS 18 is effective for periods commencing after 1 January 2027 and will supersede the current NZ IAS 1
Presentation of Financial Statements. The purpose of IFRS 18 is to improve the comparability and transparency
in the presentation of the financial statements. Some key new requirements include further guidance on
when disaggregation is required to provide users of the financial statements with useful level of information,
disclosure of management-defined performance measures that provide management’s view of an aspect of
the entity’s financial performance as a whole and a new structure for the income statement that requires the
presentation of profit and loss items by operating, investing and financing activities.
The Group will adopt the standard in the period it becomes effective. It is expected that the adoption of this
standard will have a material impact on the presentation of the primary financial statements and disclosures
in notes to the financial statements. However, it will not impact the recognition and measurement of items
disclosed.
1.5 Segmental reporting
a. Operating segments
Information is provided by operating segment to assist an understanding of the Group’s performance.
Tower operates in two geographical segments, New Zealand and the Pacific region. New Zealand comprises
the general insurance business underwritten in New Zealand. Pacific Islands comprises the general insurance
business underwritten in the Pacific by Tower subsidiaries. Other contains balances relating to Tower Services
Limited and group diversification benefits.
The Group does not derive revenue from any individual or entity that represents 10% or more of the Group’s
total revenue.
The financial performance for the Pacific Islands operating segment excludes balances related to previously
disposed operations. Intercompany transactions with those entities have been eliminated within continuing
operations.
b. Financial performance of continuing operations
NEW ZEALAND
$000
PACIFIC
ISLANDS
$000
OTHER
$000
TOTAL
$000
Year Ended 30 September 2025
Insurance revenue551,496 42,852 – 594,348
Insurance service expense(379,643)(32,153)148 (411,648)
Net expense from reinsurance
contracts held
(72,226)(5,159)(120)(77,505)
Insurance service result99,627 5,540 28 105,195
Net investment income18,645 576 – 19,221
Net insurance finance expense(1,587)– – (1,587)
Net insurance and investment result116,685 6,116 28 122,829
Other income3,953 491 – 4,444
Other operating expenses(8,677)(105) – (8,782)
Finance costs(569)(175) – (744)
Profit/(loss) before taxation from
continuing operations111,392 6,327 28 117,747
Tax (expense)/benefit(32,215)(1,831)(28)(34,074)
Profit/(loss) after taxation from
continuing operations79,177 4,496 – 83,673
48ANNUAL REPORT 2025
Notes to the consolidated financial statements (continued)
ContentsOur strategy2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index

b. Financial performance of continuing operations (continued)
NEW ZEALAND
$000
PACIFIC ISLANDS
$000
OTHER
$000
TOTAL
$000
Year Ended 30 September 2024
Insurance revenue513,566 42,252 – 555,818
Insurance service expense(356,693)(24,553)(362)(381,608)
Net (expense)/income from reinsurance
contracts held
(86,029)(5,398)63 (91,364)
Insurance service result70,844 12,301 (299)82,846
Net investment income20,666 884 – 21,550
Net insurance finance expense(2,572)– – (2,572)
Net insurance and investment result88,938 13,185 (299)101,824
Other income3,873 191 – 4,064
Other operating expenses(2,307)(41) – (2,348)
Finance costs(722)(160)– (882)
Profit/(loss) before taxation from continuing
operations89,782 13,175 (299)102,658
Tax (expense)/benefit(25,716)(6,101)43 (31,774)
Profit/(loss) after taxation from continuing
operations64,066 7,074 (256)70,884
1.5 Segmental reporting (continued)
c. Financial position of continuing operations
NEW ZEALAND
$000
PACIFIC ISLANDS
$000
OTHER
$000
TOTAL
$000
Additions to non-current assets
30 September 2025
21,674 728 – 22,402
Additions to non-current assets
30 September 2024
18,702 2,175 – 20,877
Total assets 30 September 2025549,932 63,532 (531)612,933
Total assets 30 September 2024579,079 56,580 (511)635,148
Total liabilities 30 September 2025231,269 31,840 (841)262,268
Total liabilities 30 September 2024250,337 25,478 (823)274,992
Additions to non-current assets include additions to property, plant and equipment, right-of-use assets and
intangible assets.
Definition
An operating segment is a group of assets and operations engaged in providing products or services
that are subject to risks and returns that are different to those of other operating segments. Operating
segments are reported in a manner consistent with the internal reporting provided to the chief operating
decision-maker (the Chief Executive Officer) who reviews the operating results on a regular basis and
makes decisions on resource allocation and assessing performance.
49ANNUAL REPORT 2025
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ContentsOur strategy2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index

2 Insurance and reinsurance contracts
This section provides information on Tower’s underwriting activities.
Tower collects premiums from customers in exchange for providing insurance coverage. These
premiums are recognised as insurance revenue when they are earned by Tower, reducing the liability for
remaining coverage on the consolidated balance sheet.
When customers suffer a loss that is covered by their policy, Tower will make payments to customers or
suppliers, which it recognises as insurance expenses. To ensure that Tower’s obligations to customers are
properly recorded within the financial statements, Tower recognises a liability for incurred claims on the
consolidated balance sheet.
To manage Tower’s risk and optimise its returns, Tower reinsures some of its exposure with reinsurance
companies. Net expense from reinsurance contracts is measured as an allocation of reinsurance
premiums paid plus any other directly attributable expenses, less amounts recovered from reinsurers
and any change in risk from reinsurer non-performance.
Tower also discloses the nature and extent of risks arising from insurance and reinsurance contracts,
including sensitivity analyses and risk mitigation strategies.
2.1 Insurance and reinsurance contracts accounting policies
a. Recognition
Tower recognises insurance contracts at the earlier of the commencement of the coverage period, or when the
first premium for a group of insurance contracts is due. At inception of insurance contracts, Tower analyses and
identifies any distinct contract components that may need to be accounted for under another NZ IFRS instead
of NZ IFRS 17. Currently, Tower does not have any product groups that include distinct components that require
separation.
Insurance revenue is recognised based on passage of time over the coverage period of the contract, resulting
in a linear allocation of revenue for each contract across its coverage period. Revenue earned excludes taxes
and levies collected on behalf of third parties.
Insurance service expenses arising from insurance contracts are generally recognised in profit or loss as they
are incurred, except for insurance acquisition cash flows.
Insurance finance income and expenses comprise changes in the carrying amounts of groups of insurance and
reinsurance contracts arising from the effects of, and changes in, the time value of money and financial risk.
Tower has elected to present all insurance finance income and expenses in profit or loss.
b. Measurement Model - Insurance Contracts
NZ IFRS 17 contains three measurement models:
1) The general measurement model (GMM) measures insurance contracts based on the fulfilment cash flows
(the present value of estimated future cash flows with an explicit risk adjustment for non-financial risk) and
the contractual service margin (the unearned profit that will be recognised as services are provided over the
coverage period)
2) A modified version of the general model (the variable fee approach, or VFA) is applied to insurance contracts
with direct participation features
3) A simplified measurement model (the PAA) is permitted in certain circumstances.
The majority of Tower’s insurance portfolios have a coverage period of one year or less, which allows for
application of the PAA. The coverage period, or contract boundary, is the period during which Tower has a
substantive obligation to provide customers with insurance contract services. The substantive obligation ends
when Tower can reprice insurance contracts to reflect reassessed risk.
For any insurance groups with coverage periods greater than one year, Tower has assessed that the resulting
liability for remaining coverage as measured under the PAA would not differ materially from the result of
applying the GMM. Therefore Tower has applied the PAA to all its insurance groups. Refer to note 2.1(i) for
discussion around reinsurance PAA eligibility assessment.
Tower does not issue any insurance contracts that provide an investment return, or have direct participating
contracts, therefore the VFA does not apply to Tower.
c. Level of aggregation
Tower manages insurance contracts issued by aggregating them into portfolios. Insurance contracts for
product lines with similar risks that are within the same geographical area, and managed together, are
considered to be in the same portfolio. The geographical areas for portfolio purposes are New Zealand and the
Pacific, and within each geographical area there are a number of separate portfolios based on product type.
Each portfolio will contain annual cohorts which contain contracts that are issued within a financial year. Annual
cohorts can be further disaggregated into three groups at inception: onerous contracts, contracts with no
significant risk of becoming onerous, and the remainder.
d. Onerous contracts
The profitability of groups of contracts is assessed by actuarial valuation models. All insurance contracts are
measured under the PAA, and therefore Tower assumes that no contracts in a group are onerous at initial
recognition unless facts and circumstances indicate otherwise.
To determine which facts and circumstances are indicative of onerous contracts management considers future
profitability for a group of contracts, as well as factors that may be internal to Tower (e.g., pricing decisions) or
external (e.g., sudden and unexpected changes to the economic or regulatory environments). When facts and
50ANNUAL REPORT 2025
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circumstances indicate a set of contracts may be onerous, Tower will perform an additional assessment to
distinguish onerous contracts from non-onerous contracts. Onerous contract testing will involve determining
the estimation of the fulfilment cash flows in relation to that group of onerous contracts.
Tower will recognise a loss in profit or loss for onerous contracts, which is measured as the difference between
fulfilment cash flows related to the remaining coverage of the group using the general model, and liability for
the remaining coverage using the PAA. The increase to the liability for remaining coverage resulting from the
recognition of onerous contracts will be tracked separately as a loss component. In subsequent periods, Tower
will reassess previously onerous contracts then remeasure fulfilment cash flows. The impact from changes in
fulfilment cash flows will be recorded in profit or loss, and the liability for remaining coverage will reflect the
remeasured fulfilment cash flows. When fulfilment cash flows are incurred, they are allocated systematically
between the loss component and the liability for remaining coverage. The systematic allocation is based on the
loss component relative to the total estimated present value of future cash outflows.
e. Liability for remaining coverage
The liability for remaining coverage (LRC) reflects insurance coverage expected to be provided by Tower after
the reporting date. This is measured inclusive of any taxes and levies collected on behalf of third parties. On initial
recognition of each group of contracts, the carrying amount of the LRC is measured as the premiums received
less any insurance acquisition cash flows allocated to the group at that date, and adjusted for any amount arising
from the derecognition of any assets or liabilities previously recognised for cash flows related to the group.
Subsequent measurement of the carrying amount of the LRC is increased by any premiums received and
the amortisation of insurance acquisition cash flows recognised as expenses, and decreased by the amount
recognised as insurance revenue for services provided and any additional insurance acquisition cash flows
allocated after initial recognition.
On initial recognition of each group of contracts, Tower expects that the time between providing each part of
the services and the related premium due date is no more than a year. Accordingly, Tower has chosen not to
adjust the LRC to reflect the time value of money and the effect of financial risk.
f. Insurance acquisition cash flows
Insurance acquisition cash flows (IACF) comprise the costs of selling, underwriting and starting a group of
insurance contracts (which are issued or expected to be issued) that are directly attributable to portfolios of
insurance contracts.
Tower has elected to defer IACF and recognise as insurance expenses across the coverage period of contracts
issued, rather than to expense them when incurred. The amortisation period for IACF begins at the later of when
the costs are incurred or when the underlying insurance contracts are recognised, and are expected to be
amortised within 12 months on a straight-line basis. All IACF are allocated to groups of insurance contracts.
g. Liability for incurred claims
Liability for incurred claims (LIC) relate to claims that have occurred prior to reporting date but have not
been paid. This is measured as the present value of the estimated future cash outflows plus a specific risk
adjustment (RA) factor to account for non-financial risks. Tower has elected to discount the LIC to reflect the
time value of money.
Tower does not disaggregate changes in the RA between the insurance service result and insurance finance
income or expenses. All changes in the RA are included in the insurance service result.
h. Insurance modification and derecognition
Tower derecognises insurance contracts when rights and obligations relating to the contract are extinguished,
or when the contract is modified in a way that would have changed the accounting for the contract significantly
had the new terms been included at contract inception. In such a case a new contract based on the modified
terms is recognised.
i. Measurement Model - Reinsurance Contracts
Some reinsurance contracts held by Tower have a three year contract boundary, however the result of applying
the PAA model does not result in a material difference from applying the GMM model. Therefore all reinsurance
contracts held by Tower are measured using the PAA measurement model.
Quantitative PAA eligibility testing has been performed over these contracts, where the following key
assumptions and estimates are modelled:
—Expected future cash flows
—Risk adjustment
— Contractual service margin (CSM), the balancing component to result in nil profit or loss impact at inception.
The CSM represents the net cost of purchasing reinsurance, which will be released over the coverage period.
—Expected variability in assumptions used, such as changes in discount rates.
Tower measures its reinsurance assets on the same basis as insurance contracts issued, however these are
adapted to reflect the features of reinsurance contracts held that differ from insurance contracts held.
j. Reinsurance contracts - level of aggregation
Tower manages all reinsurance contracts held together and the contracts held provide coverage for similar
risks. All reinsurance contracts held by Tower are considered as a single portfolio.
2.1 Insurance and reinsurance contracts accounting policies (continued)
d. Onerous contracts (continued)
51ANNUAL REPORT 2025
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k. Reinsurance contract assets - recognition and measurement
A reinsurance asset for remaining coverage (RI ARC) is recognised at the start of the coverage period of the
reinsurance contract where the contract provided non-proportionate coverage, or when the underlying
insurance contract is recognised where the contract provides proportionate coverage. The asset is measured
as premiums paid, adjusted for any acquisition cash flows.
A loss-recovery component is established within the RI ARC for the gain recognised in profit or loss when
the Group has recognised a loss on underlying groups of onerous contracts that are covered by reinsurance
contracts held. The gain is calculated by multiplying the loss recognised on underlying insurance contracts
by the percentage of claims on underlying insurance contracts that the Group expects to recover from the
reinsurance contracts held that are entered into before or at the same time as the loss is recognised on the
underlying insurance contracts.
This loss-recovery component is adjusted to reflect changes in the loss component of the onerous group of
underlying contracts and is further adjusted, if required, to ensure that it does not exceed the portion of the
carrying amount of the loss component of the onerous group of underlying insurance contracts that Tower
expects to recover from the reinsurance contracts held.
Reinsurance asset for incurred claims (RI AIC) is recognised when a claim is made on an underlying contract
and a reinsurance contract was held to cover the risks on the underlying insurance contract. This is measured
based on estimated future cash flows, adjusted to reflect the time value of money, and a RA factor for any non-
financial risks.
Net (expense)/income from reinsurance contracts held is measured as an allocation of reinsurance premiums
paid plus any other directly attributable expenses, less amounts recovered from reinsurers, and any change in
risk from reinsurer non-performance.
Reinsurance premiums paid reflect premiums ceded to reinsurers and are recognised as an expense in
accordance with the pattern of reinsurance service received. Commission revenue from reinsurance contracts
held by Tower that are not contingent on claims for underlying insurance contracts is treated as a reduction in
premiums paid.
Tower also has profit-share commission arrangements for some proportional reinsurance contracts, where
the commission is contingent on claims. Commission from the profit-share arrangements will offset against RI
claims recoveries in RI AIC.
Amounts recovered from reinsurers are recognised when a claim has been incurred and the basis for
measurement is the expected future cash inflows.
l. Discount rates
Tower discounts future cash flows related to insurance liabilities for incurred claims and reinsurance assets for
incurred claims to recognise the impact of the time value of money. Tower has adopted a ‘bottom-up’ approach to
derive the discount rate. The risk-free yield is derived from observable secondary market prices for NZ government
bonds. Nil illiquidity premium has been assumed on the basis that it would not have a material impact.
2.2 Insurance service expense and other operating expenses
Composition
2025
$000
2024
$000
Claims expenses 259,776 245,048
Losses/(reversals) on onerous insurance contracts148 (223)
Commission expenses amortised 13,629 13,022
Management expenses:
People costs102,984 92,671
People costs capitalised during the year(11,134)(10,824)
Technology18,610 17,189
Amortisation19,512 19,269
Depreciation5,914 5,962
External fees23,319 20,128
Marketing14,069 14,792
Communications3,337 3,852
Other management expense7,703 3,605
Movement in non-commission deferred insurance acquisition
cash flows
(2,784)(6,011)
Claims related management expenses reclassified to claims
expense
(43,435)(35,756)
Service fees charged to discontinued operations– (1,116)
Total insurance service expense411,648 381,608
Other operating expenses8,782 2,348
Total insurance service expense and other
operating expenses420,430 383,956
2.1 Insurance and reinsurance contracts accounting policies (continued)
52ANNUAL REPORT 2025
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2.3 Net insurance finance expense
2025
$000
2024
$000
Interest accreted(2,077)(5,314)
Effect of changes in interest rates and other financial
assumptions
(81)(278)
Finance expense from insurance contracts issued(2,158)(5,592)
Interest accreted551 2,877
Effect of changes in interest rates and other financial
assumptions
20 143
Finance income from reinsurance contracts held571 3,020
Net insurance finance expense(1,587)(2,572)
2.4 Insurance and reinsurance assets and liabilities
a. Insurance and reinsurance contracts
2025
$000
ASSETSLIABILITIES
CURRENT
PORTION
NON-
CURRENT
PORTIONTOTAL
Liability for remaining coverage– 37,254 37,254 – 37,254
Liability for incurred claims– 118,373 94,774 23,599 118,373
Total insurance contracts issued– 155,627 132,028 23,599 155,627
Total reinsurance contracts held20,900 – 17,694 3,206 20,900
2024
$000
ASSETSLIABILITIES
CURRENT
PORTION
NON-
CURRENT
PORTIONTOTAL
Liability for remaining coverage– 42,042 42,042 – 42,042
Liability for incurred claims – 135,527 110,169 25,358 135,527
Total insurance contracts issued– 177,569 152,211 25,358 177,569
Total reinsurance contracts held35,503 – 28,854 6,649 35,503
53ANNUAL REPORT 2025
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b. Reconciliation of insurance assets and liabilities
2025
$000
LIABILITIES FOR REMAINING COVERAGELIABILITIES FOR INCURRED CLAIMSTOTAL
EXCLUDING LOSS
COMPONENTLOSS COMPONENT
ESTIMATES OF THE
PRESENT VALUE
OF FUTURE CASH
FLOWSRISK ADJUSTMENT
Opening insurance contract liabilities41,658 384 122,348 13,179 177,569
Insurance revenue(594,348) – – – (594,348)
Insurance service expense:
Incurred claims and other insurance service expenses*– –323,792 4,818 328,610
Amortisation of IACF71,617 – – – 71,617
Changes relating to past service– – (11,532)(2,550)(14,082)
Loss on onerous contracts– 148 – – 148
Finance expense from insurance contracts issued– – 2,158 – 2,158
Effect of movements in exchange rates327 26 845 – 1,198
Amounts included in consolidated statement of comprehensive income(522,404)174 315,263 2,268 (204,699)
Cash flows:
Premiums received593,413 – –– 593,413
Claims and other insurance service expenses paid– – (334,685)– (334,685)
Insurance acquisition cash flows(75,292)– – – (75,292)
Amounts included in consolidated statement of cash flow518,121 – (334,685)– 183,436
Pre-recognition cash flows derecognised and other changes(679)– – – (679)
Insurance contract liabilities at 30 September 202536,696558102,92615,447155,627
* Excludes $25m of insurance service expenses for depreciation and amortisation, which do not form part of insurance contract liabilities on the consolidated balance sheet..
Certain cash flows presented above may be on a deemed basis in respect of movements through the insurance contract liabilities, and certain amounts may be recognised in other receivable, payable and provision balances,
so they may differ from the actual cash flow amounts reported in the consolidated statement of cash flows.
2.4 Insurance and reinsurance assets and liabilities (continued)
54ANNUAL REPORT 2025
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b. Reconciliation of insurance assets and liabilities (continued)
2024
$000
LIABILITIES FOR REMAINING COVERAGELIABILITIES FOR INCURRED CLAIMSTOTAL
EXCLUDING LOSS
COMPONENTLOSS COMPONENT
ESTIMATES OF THE
PRESENT VALUE
OF FUTURE CASH
FLOWSRISK ADJUSTMENT
Opening insurance contract liabilities43,994620223,56517,630285,809
Insurance revenue(555,818)– – – (555,818)
Insurance service expense:
Incurred claims and other insurance service expenses*– – 314,1303,666317,796
Amortisation of IACF62,835– – – 62,835
Changes relating to past service– – (15,950)(8,117)(24,067)
Losses and reversals on onerous contracts– (223)– – (223)
Finance expense from insurance contracts issued– – 5,592– 5,592
Effect of movements in exchange rates(272)(13)(348)– (633)
Amounts included in statement of comprehensive income(493,255)(236)303,424(4,451)(194,518)
Cash flows:
Premiums received559,383– – – 559,383
Claims and other insurance service expenses paid– – (404,641)– (404,641)
Insurance acquisition cash flows(68,119)– – – (68,119)
Amounts included in statement of cash flow491,264– (404,641)– 86,623
Pre-recognition cash flows derecognised and other changes(345)– – – (345)
Insurance contract liabilities at 30 September 202441,658384122,34813,179177,569
* Excludes $25m of insurance service expenses for depreciation and amortisation, which do not form part of insurance contract liabilities on the balance sheet.
Certain cash flows presented above may be on a deemed basis in respect of movements through the insurance contract liabilities, and certain amounts may be recognised in other receivable, payable and provision balances, so
they may differ from the actual cash flow amounts reported in the consolidated statement of cash flows. Pre-recognition cash flows derecognised and other changes also includes the derecognition of liabilities that moved to
liabilities held for sale during the period.
2.4 Insurance and reinsurance assets and liabilities (continued)
55ANNUAL REPORT 2025
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c. Reconciliation of reinsurance assets and liabilities
2025
$000
ASSETS FOR REMAINING
COVERAGE
ASSET FOR
INCURRED CLAIMSTOTAL
EXCLUDING
LOSS RECOVERY
COMPONENT
LOSS RECOVERY
COMPONENT
ESTIMATES OF THE
PRESENT VALUE
OF FUTURE CASH
FLOWSRISK ADJUSTMENT
Year ended 30 September 2025
Opening reinsurance contract assets(11,690)–44,5472,64635,503
Reinsurance premiums(77,188)–––(77,188)
Amounts recoverable from reinsurers:
Amounts recoverable for incurred claims––11,477(790)10,687
Changes relating to past service––(10,333)(671)(11,004)
Finance income from reinsurance contracts held––571–571
Effect of movements in exchange rates(204)–(257)–(461)
Amounts included in statement of comprehensive income(77,392) – 1,458 (1,461)(77,395)
Cash flows:
Premiums paid net of ceding commissions87,989–––87,989
Reinsurance recoveries (net of profit share commissions)––(25,197)–(25,197)
Amounts included in statement of cash flow87,989–(25,197)–62,792
Reinsurance contract assets at 30 September 2025(1,093) – 20,808 1,185 20,900
2.4 Insurance and reinsurance assets and liabilities (continued)
56ANNUAL REPORT 2025
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c. Reconciliation of reinsurance assets and liabilities (continued)
2024
$000
ASSETS FOR REMAINING
COVERAGE
ASSET FOR
INCURRED CLAIMSTOTAL
EXCLUDING
LOSS RECOVERY
COMPONENT
LOSS RECOVERY
COMPONENT
ESTIMATES OF THE
PRESENT VALUE
OF FUTURE CASH
FLOWSRISK ADJUSTMENT
Year ended 30 September 2024
Opening reinsurance contract assets(4,229)–146,3275,138147,236
Reinsurance premiums(79,587)–––(79,587)
Amounts recoverable from reinsurers:
Amounts recoverable for incurred claims––6,5276427,169
Changes relating to past service––(15,812)(3,134)(18,946)
Finance income from reinsurance contracts held––3,020–3,020
Effect of movements in exchange rates101–25–126
Amounts included in statement of comprehensive income(79,486)–(6,240)(2,492)(88,218)
Cash flows:
Premiums paid net of ceding commissions72,025–––72,025
Reinsurance recoveries (net of profit share commissions)––(95,540)–(95,540)
Amounts included in statement of cash flow72,025–(95,540)–(23,515)
Reinsurance contract assets at 30 September 2024(11,690)–44,5472,64635,503
Certain cash flows presented above may be on a deemed basis in respect of movements through the reinsurance contract assets, and certain amounts may be recognised in other receivable, and payable balances, so they may
differ from the actual cash flow amounts reported in the consolidated statement of cash flows.
2.4 Insurance and reinsurance assets and liabilities (continued)
57ANNUAL REPORT 2025
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d. Development of claims
The following table shows how estimates of cumulative claims have developed over time on a net of reinsurance basis.
Tower considers the probability and magnitude of future experience being more adverse than assumed. This uncertainty is reflected in the risk adjustment. In general, the uncertainty associated with the ultimate cost of settling
claims is greatest when the claim is at an early stage of development. As claims develop, the ultimate cost of claims becomes more certain.
ULTIMATE CLAIMS COST ESTIMATE
PRIOR
$000
2021
$000
2022
$000
2023
$000
2024
$000
2025
$000
TOTAL
$000
At end of incident year181,849 197,830 262,053 229,826 227,506
One year later180,386 204,450 253,812 219,725 –
Two years later181,928 206,682 253,799 – –
Three years later181,609 207,938 – – –
Four years later181,951 – – – –
Ultimate claims cost181,951 207,938 253,799 219,725 227,506
Cumulative payments(180,529)(207,078)(252,156)(213,074)(160,544)
Net estimates of the undiscounted amount of the claims14,7671,422 860 1,643 6,651 66,962 92,305
Third party recoveries outstanding(9,345)
Claims handling expense7,692
Effect from discounting(1,021)
Effect from risk adjustment14,262
Reinsurance outstanding on paid claims(7,513)
Total net liabilities for incurred claims96,380
2.4 Insurance and reinsurance assets and liabilities (continued)
58ANNUAL REPORT 2025
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d. Development of claims (continued)
NOTE
ESTIMATES OF
THE PRESENT
VALUE OF FUTURE
CASH FLOWS
$000
RISK
ADJUSTMENT
$000
TOTAL
$000
Insurance contract liabilities2.4b102,926 15,447 118,373
Total gross liabilities for incurred claims102,926 15,447 118,373
Reinsurance contract assets2.4c(20,808)(1,185)(21,993)
Total net liabilities for incurred claims82,118 14,262 96,380
Tower has limited exposure to long-tail classes of business. Long-tail classes have increased uncertainty of the
ultimate cost of claims due to the additional period of time to settlement.
Prior year numbers have been restated at current year exchange rates to reflect the underlying development of
claims.
e. Liability for incurred claims
Future cash outflows are estimated using data specific to each portfolio, relevant industry data and general
economic data. The estimation process factors in the risks to which the business is exposed to at a point in
time, claim frequency and severity, historical trends in the development of claims as well as legal, social and
economic factors that may affect Tower.
Assumption
20252024
Expected future claims development50.2%64.0%
Claims handling expense ratio7.5%7.9%
Risk adjustment13.8%10.7%
Discount rate2.8%4.4%
Future Canterbury Earthquakes overcap property claims$8.1m$5.2m
Expected future claims development proportion
This is the proportion of additional claims cost that is expected to be recognised in the future for claims that
have already been reported. The assumption is expressed as a proportion of current case estimates for open
claims and the resulting amount is recognised in the consolidated balance sheet as a liability for incurred
claims. The ratio has reduced over the year due to a strategic focus on improving case reserving accuracy and
claims handling processes.
2.4 Insurance and reinsurance assets and liabilities (continued)
Claims handling expense ratio
This reflects the expected cost to administer future claims. The ratio is calculated based on historical
experience of claims handling expenses.
Discount rate
The discount rates determined for 30 September 2025 were between 2.7% and 3.5% (2024: 3.6% and 5.0%).
The table below summarises the yield curves used to discount Tower’s liability for incurred claims.
As at 30 September 2025
%1 year2 years3 years4 years5+ years
New Zealand2.7%2.9%3.1%3.3%3.5%
As at 30 September 2024
%1 year2 years3 years4 years5+ years
New Zealand4.2%3.7%3.6%3.7%3.8%
Risk adjustment
The risk adjustment is the compensation Tower requires for bearing uncertainty about the amount and timing of
the cash flows that arises from non-financial risk related to a group of insurance contracts.
The determination of the appropriate level of risk adjustment takes into account:
— the level of economic capital that Tower requires to support the insurance business and the weighted
average cost of servicing that capital;
—the run-off profile and term to settlement of the net discounted cash flows;
—class of business; and
—the benefit of diversification between geographic locations
The Group determines the risk adjustment for non-financial risk at the Group level and allocates it to groups of
insurance and reinsurance contracts in a systematic and rational way.
Tower determines the risk adjustment for non-financial risk using a confidence level approach. The probability
of sufficiency (PoS) is calibrated to the amount of compensation Tower requires for bearing uncertainty in cash
flows, by using a cost of capital analysis.
A cost of capital analysis was performed using a 11.4% required return on capital (net of reinsurance) applied to
projected capital requirements. A 75% PoS was adopted for New Zealand (excluding Canterbury earthquakes),
and for Pacific. A higher confidence level of 90% was adopted for Canterbury earthquakes reflecting the higher
risk and uncertainty associated with the future cashflows.
A diversification benefit is also included to reflect the spread of risk across geographies, consistent with the
entity’s required compensation for bearing diversified non-financial risk.
59ANNUAL REPORT 2025
Notes to the consolidated financial statements (continued)
ContentsOur strategy2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index

f. Sensitivity Analysis
The impact on profit or loss before tax, and the impact on equity for any reasonable changes at period end
have been summarised below. Each change has been calculated in isolation from the other variables.
Liability for incurred claims
IMPACT ON PROFIT OR
LOSS GROSS OF
REINSURANCE
IMPACT ON PROFIT OR
LOSS NET OF
REINSURANCE
MOVEMENT IN
ASSUMPTION
2025
$000
2024
$000
2025
$000
2024
$000
Expected future claims development + 10%(3,529)(4,805)(3,102)(3,434)
- 10%3,529 4,805 3,102 3,434
Claims handling expense ratio + 10%(788)(970)(769)(854)
- 10%788 970 769 854
Risk adjustment + 10%(1,545)(1,318)(1,426)(1,053)
- 10%1,545 1,318 1,426 1,053
Discount rate + 1.75%911 1,128 801 806
- 1.75%(911)(1,128)(801)(806)
Number of future Canterbury
Earthquake overcap claims*
20 more
overcaps/+50%
(6,700)(4,100)(6,700)(4,100)
Earthquake overcap claims
20 fewer
overcaps/-50%
6,600 4,100 6,600 4,100
* Comparative represents +50%/-50%
2.4 Insurance and reinsurance assets and liabilities (continued)2.5 Receivables
Composition
2025
$000
2024
$000
Prepayments9,450 13,969
Other receivables3,330 5,830
Receivables12,780 19,799
Receivable within 12 months11,070 16,168
Receivable in greater than 12 months1,710 3,631
Receivables12,780 19,799
Recognition and measurement
Receivables (inclusive of GST) are recognised at fair value and are subsequently measured at amortised
cost, less any expected credit loss (ECL). Tower applies the simplified approach in calculating ECL.
The ECL calculation is based on a provision matrix which is based on historical credit loss experience,
adjusted for forward looking factors specific to the receivables and the economic environment.
60ANNUAL REPORT 2025
Notes to the consolidated financial statements (continued)
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2.6 Payables
Composition
2025
$000
2024
$000
Trade payables 16,470 16,747
Pre-coverage liability 2,361 2,035
GST payable 2,833 3,497
Unsettled investment purchases– 5,400
Other 5,341 4,608
Payables 27,005 32,287
Payable within 12 months 27,005 32,287
Payable in greater than 12 months– –
Payables27,00532,287
Recognition and measurement
Payables are recognised where goods or services that have been received or supplied and have been
invoiced or formally agreed with the supplier. Payables are stated at the fair value of the consideration to
be paid in the future inclusive of GST. GST payable represents the net amount payable to the respective
tax authorities.
Tower receives some premiums in advance of the initial recognition date of an insurance contract. For
these premiums received in advance Tower recognises a separate pre-coverage liability (PCL). When the
coverage period for the contract starts, the PCL is reduced and the value of the premiums is transferred
to the liability for remaining coverage.
2.7 Provisions
Composition
2025
$000
2024
$000
Annual leave and other employee benefits 10,573 12,771
Compliance and remediation 10,329 9,188
Provisions 20,902 21,959
Payable within 12 months 20,902 20,926
Payable in greater than 12 months – 1,033
Provisions 20,902 21,959
The annual leave and other employee benefits provision has increased by $8.3m during the period, offset by
payments to employees of $10.5m.
Tower and the FMA have reached a settlement in relation to Tower’s misapplication of its multi-policy discounts
and we are awaiting the final decision from the High Court.
A compliance and remediation provision has been recognised and is reassessed at each reporting period.
A range of possible outcomes is considered, and the re-assessment has resulted in an additional $2.8m being
recognised in the current period, which has been offset by payments made during the period. The resulting
provision allows for amounts to be repaid to customers and costs associated with the FMA’s action.
Recognition and measurement
Tower recognises a provision when it has a present obligation as a result of a past event and it is more
likely than not that an outflow of resources will be required to settle the obligation. Tower’s provision
represents the best estimate of the expenditure required to settle the present obligation at the end of
the reporting period.
61ANNUAL REPORT 2025
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3 Investments and other income
Tower invests funds collected as premiums and provided by shareholders to ensure it can meet its
obligations to pay claims and expenses and to generate a return to support its profitability. Tower has
a low risk tolerance for investment and credit risk and therefore the majority of its investments are in
investment grade supranational and government bonds, and term deposits.
3.1 Investment income
2025
$000
2024
$000
Interest income16,418 17,767
Net realised gain2,891 1,626
Net unrealised gain460 2,407
Investment income 19,769 21,800
Recognition and measurement
Tower’s investment income is primarily made up of realised and unrealised interest income on fixed
interest investments and fair value gains or losses on its investment assets. Both are recognised in the
period that they are earned through profit or loss.
3.2 Investments
Tower designates its investments at fair value through profit or loss in accordance with its Treasury policy.
It categorises its investments into three levels based on the inputs available to measure fair value:
Level 1 Fair value is calculated using quoted prices in active markets. Tower currently does not have any
Level 1 investments.
Level 2 Investment valuations are based on direct or indirect observable data other than quoted prices
included in Level 1. Level 2 inputs include: (1) quoted prices for similar assets or liabilities;
(2) quoted prices for assets or liabilities that are not traded in an active market; or (3) other
observable market data that can be used for valuation purposes. Tower investments included
in this category include government and corporate debt, where the market is considered to be
lacking sufficient depth to be considered active, and part ownership of a property that is rented
out to staff.
Level 3 Investment valuation is based on unobservable market data. Tower currently does not have any
Level 3 investments.
LEVEL 1
$000
LEVEL 2
$000
LEVEL 3
$000
TOTAL
$000
As at 30 September 2025
Fixed interest investments– 389,191 – 389,191
Property investment– 34 – 34
Investments– 389,225 – 389,225
As at 30 September 2024
Fixed interest investments– 367,472 – 367,472
Property investment– 34 – 34
Investments– 367,506 – 367,506
There have been no transfers between levels of the fair value hierarchy during the current period (2024: nil).
62ANNUAL REPORT 2025
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Recognition and measurement
Tower’s investment assets are designated at fair value through profit or loss. Investment assets are
initially recognised at fair value and are remeasured to fair value through profit or loss at each reporting
date. Tower’s approach to measuring the fair value of these assets is covered above.
Purchases and sales of investments are recognised at the date which Tower commits to buy or sell
the assets (i.e. trade date). Investments are derecognised when the rights to receive future cash flows
from the assets have expired, or have been transferred, and substantially all the risks and rewards of
ownership have transferred.
3.3 Other income
2025
$000
2024
$000
Agency fees*1,767 1,705
Gain on disposal of property, plant and equipment69 30
Other2,608 2,329
Other income 4,444 4,064
* Agency fees include fees received for managing claims on behalf of the Natural Hazards Commission.
4 Risk Management
Tower is exposed to multiple risks as it works to set things right for its customers and their communities
whilst maximising returns for its shareholders. Everyone across the organisation is responsible for driving
a positive risk culture and ensuring that Tower’s risks are appropriately managed.
4.1 Risk management overview
Tower’s approach to achieving effective risk management is to embed a risk-aware culture where everyone
across the organisation (including contractors and third parties) is responsible for managing risk.
Tower’s Board expresses its appetite for risk in a Risk Appetite Statement, which:
(i) Gives clear concise guidance to management of parameters for risk taking.
(ii) Embeds risk management into strategic and decision-making processes.
(iii) Facilitates risk to be managed at all levels of the organisation through a structured process to identify
risk, and the allocation of clear, personal responsibility for management of identified risks by assigned risk
owners.
The Board then approves and adopts: (i) the Risk Management Framework (RMF) which is the central document
that explains how Tower effectively manages risk within the business; and (ii) the Reinsurance Management
Strategy (ReMS) which describes the systems, structures, and processes which collectively ensures Tower’s
reinsurance arrangements and operations are prudently managed. These documents are approved annually by
the Board.
The Board has delegated its responsibility to the Board Risk Committee to provide oversight of risk
management practices and provide advice to the Board and management when required. In addition, the
Board Risk Committee also monitors the effectiveness of Tower’s risk management function which is overseen
by the Chief Risk Officer (CRO). The CRO provides regular reports to the Board Risk Committee on the operation
of the RMF.
Tower has embedded the RMF with clear accountabilities and risk ownership to ensure that Tower identifies,
manages, mitigates and reports on all key risks and controls through the three lines of defence model.
(i) First line: Operational management has ownership, responsibility and accountability for directly identifying,
assessing, controlling and mitigating key risks which prevent them from achieving business objectives.
(ii) Second Line: Tower’s Risk, Advice and Assurance function is responsible for developing and implementing
effective risk, compliance and conduct management processes; providing advisory support to the first
line of defence and constructively challenging operational management and risk and obligation owners to
ensure positive assurance.
3.2 Investments (continued)
63ANNUAL REPORT 2025
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(iii) Third line: Internal Audit is responsible and accountable for providing an independent and objective view
of the adequacy and effectiveness of the Group’s risk management, governance and internal control
framework. Internal audit, along with other groups such as external audit, report independently to the
Board and/or the Audit Committee.
The RMF is supported by a suite of policies that address the risks and compliance obligations covered in this
section.
4.2 Strategic risk
Strategic risk is the risk that internal or external factors compromise Tower’s ability to execute its strategy or
achieve its strategic objectives. Strategic risk is managed through:
(i) Monitoring and managing performance against Board approved plan and targets.
(ii) Board leading an annual strategy and planning process which considers our performance, competitor
positioning and strategic opportunities.
(iii) Identifying and managing emerging risks using established governance processes and forums.
4.3 Insurance risk
Insurance risk is the risk that for any class of risk insured, the present value of actual claims payable will exceed
the present value of actual premium revenues generated (net of reinsurance). This risk is inherent in Tower’s
operations and arises and manifests through underwriting, insurance concentration and reserving risk.
a. Underwriting risk
Underwriting risk refers to the risk that claims arising are higher (or lower) than assumed in pricing due to bad
experience including catastrophes, weakness in controls over underwriting or portfolio management, or claims
management issues. Tower has established the following key controls to mitigate this risk:
(i) Use of comprehensive management information systems and actuarial models to price products based
on historical claims frequencies and claims severity averages, adjusted for inflation and modelled
catastrophes, trended forward to recognise anticipated changes in claims patterns after making allowance
for other costs incurred by the Group.
(ii) Passing elements of insurance risk to reinsurers. Tower’s Board determines a maximum level of risk to be
retained by the Group as a whole. Tower’s reinsurance programme is structured to adequately protect the
solvency and capital position of the insurance business. The adequacy of reinsurance cover is modelled
by assessing Tower’s exposure under a range of scenarios. The plausible scenario that has the most
financial significance for Tower is a major earthquake. Each year, as part of setting the coming year’s
reinsurance cover, comprehensive modelling of the event probability and amount of the Group’s exposure
is undertaken.
(iii) Underwriting limits are in place to enforce appropriate risk selection criteria and pricing with specific
underwriting authorities that set clear parameters for the business acceptance.
Tower has not experienced significant changes in exposure to underwriting risk during the period, and no
significant changes to underwriting risk management have been implemented in the current period.
b. Concentration risk
Concentration risk refers to the risk of underwriting a number of like risks, where the same or similar loss events
have the potential to produce claims from many of Tower’s customers at the same time. Tower is particularly
subject to concentration risks in the following variety of forms:
(i) Geographic concentration risk – Tower purchases a catastrophe reinsurance programme to protect against
a modelled 1-in-1000 years whole of portfolio catastrophe loss.
(ii) Product concentration risk - Tower’s business is weighted towards the NZ general insurance market where its
risks are concentrated in house insurance (Home & Contents) and motor insurance. Tower limits its exposure
through proportional reinsurance arrangements, where Tower transfers its exposure on any single insured
asset (for example, a house) above a set amount, in exchange for ceding portion of the premium to reinsurers.
Refer to note 4.3a for exposure of underwriting risk at reporting date. Liability for incurred claims (LIC) is the key
component of insurance liability sensitive to possible changes in underwriting risk, and we have performed
sensitivity analysis over all variables that could reasonably change and impact the measurement of LIC in note
2.4f.
Tower has not experienced significant changes in exposure to concentration risk during the period, and no
significant changes to concentration risk management have been implemented in the current period.
4.1 Risk management overview (continued)
64ANNUAL REPORT 2025
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b. Concentration risk (continued)
The table below illustrates the diversity of Tower’s operations.
% of Insurance Revenue
20252024
NZPACIFIC*TOTALNZPACIFIC*TOTAL
Home40%2%42%38%2%40%
Contents14%0%14%14%0%14%
Motor36%3%39%38%2%40%
Other3%2%5%3%3%6%
Total93%7%100%93%7%100%
* The Pacific operating segment excludes the disposal groups.
c. Reserving risk
Reserving risk is managed through the actuarial valuation of insurance liabilities and monitoring of the
probability of adequacy booked reserves. The valuation of the liability for incurred claims is performed by
qualified and experienced actuaries. The liability for incurred claims is subject to a comprehensive review
at least annually.
Tower has not experienced significant changes in exposure to reserving risk, and no significant changes
to reserving risk management have been implemented in the current period.
Refer to note 4.3c for exposure of reserving risk at reporting date. Liability for incurred claims (LIC) is the
key component of insurance liability sensitive to possible changes in reserving risk, and we have performed
sensitivity analysis over all variables that could reasonably change and impact the measurement of LIC in
note 2.4f.
4.3 Insurance risk (continued)4.4 Credit risk
Credit risk is the risk of loss that arises when a counterparty fails to meet their financial obligations to Tower
in accordance with the agreed terms. Tower’s exposure to credit risk primarily results from transactions with
security issuers, reinsurers and policyholders and is set out below.
a. Investment and treasury
Tower manages its investment and treasury credit risks in line with limits set by the Board:
(i) New Zealand cash deposits that are internally managed are limited to banks with a minimum Standard &
Poor’s (S&P) AA- credit rating or equivalent.
(ii) Cash deposits and investments that are managed by external investment managers are limited to
counterparties with a minimum S&P A- credit rating or equivalent.
(iii) Tower holds deposits and invests in Pacific regional investment markets through its Pacific Island
operations to comply with local statutory requirements and in accordance with Tower investment policies.
These deposits and investments generally have low credit ratings representing the majority of the value
included in the ‘Below BBB’ and ‘not rated’ categories in the following table. This includes deposits and
investments with Australian bank subsidiaries that comprise 34% (2024: 33%) of the ‘not rated’ category.
CASH AND CASH EQUIVALENTSFIXED INTEREST INVESTMENTSTOTAL
2025
$000
2024
$000
2025
$000
2024
$000
2025
$000
2024
$000
AAA– – 99,303 121,497 99,303 121,497
AA 57,466 62,106 230,186 188,655 287,652 250,761
A– – 53,192 55,240 53,192 55,240
Below BBB 7,436 10,466 5,568 1,948 13,004 12,414
Not rated 6,145 2,818 976 166 7,121 2,984
Total 71,047 75,390 389,225 367,506 460,272 442,896
65ANNUAL REPORT 2025
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b. Reinsurance
Tower manages its reinsurance programme in line with the ReMS. Tower seeks to manage the quantum and
volatility of insurance risk in order to reduce exposure and overall cost.
Tower’s policy is to only deal with reinsurers with a credit rating of S&P A- or better unless local statutory
requirements dictate otherwise. Additional requirements of the policy are for no individual reinsurer to have
more than 25% share of the overall programme and Tower is prohibited from offering inwards reinsurance to
external entities.
Tower has not experienced significant changes in exposure to reinsurance risk during the period, and no
significant changes to reinsurance risk management have been implemented in the current period.
The following table provides details on Tower’s maximum exposure to reinsurance contract assets.
REINSURANCE AIC
2025
$000
2024
$000
AA 18,121 34,592
A 3,673 11,768
BBB 41 70
Not rated 158 763
Total 21,993 47,193
4.4 Credit risk (continued)
Tower’s receivables for insurance contracts primarily relates to policies which are paid on either a fortnightly or
monthly basis. Payment default or policy cancellation - subject to the terms of the policyholder’s contract – will
result in the termination of the insurance contract eliminating both the credit risk and the insurance risk.
The following table provides details on Tower’s maximum exposure to credit risk for insurance contracts and
other receivables:
PAST DUE
NOT
PAST DUE*
$000
1 MONTH
$000
1 TO 2
MONTHS
$000
2 TO 3
MONTHS
$000
OVER 3
MONTHS
$000
TOTAL
$000
As at 30 September 2025
Net premiums receivable 279,673 4,963 987 226 137 285,986
Other receivables 3,330 – – – – 3,330
As at 30 September 2024
Net premium receivable 270,422 4,559 1,665 683 257 277,586
Other receivables 5,830 – – – – 5,830
* This includes premiums that are less than 30 days outstanding (which are owed but not past due) of $5.4m (2024: $5.2m).
The remaining balance is related to the provision of future insurance services to customers.
c. Insurance and other credit risk
66ANNUAL REPORT 2025
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4.5 Market risk
Market risk is the risk of adverse impacts on investment earnings resulting from changes in market factors.
Tower’s market risk is predominately as a result of changes in the value of the New Zealand dollar (currency
risk) and interest rate movements. Tower's approach to managing market risk is underpinned by its Treasury
Policy as approved by the Board.
a. Currency risk
Tower’s currency exposure arises from the translation of foreign operations into Tower’s functional currency
(currency translation risk) or due to transactions denominated in a currency other than the functional currency
of a controlled entity (operational currency risk). The currencies giving rise to this risk are primarily the US dollar,
Fijian dollar and Papua New Guinea (PNG) Kina.
Tower’s principal currency risk is currency translation (where movement impacts equity). Tower generally elects
not to hedge this risk as it is difficult given the size and nature of the currency markets in the Pacific. Tower
seeks to minimise its net exposure to foreign operational risk by actively seeking to return surplus cash and
capital to the parent company.
Operational currency risk impacts profit and generally arises from:
(i) Procurement of goods and services denominated in foreign currencies. Tower may enter into hedges for
future transactions, using authorised instruments, provided that the timing and amount of those future
transactions can be estimated with a reasonable degree of certainty.
(ii) Investment assets managed by the external investment manager that are denominated in foreign
currencies. Tower’s Board set limits for the management of currency risk based on prudent asset
management practice. Regular reviews are conducted to ensure that these limits are adhered to.
Tower has not experienced significant changes in exposure to currency risk during the period, and no
significant changes to currency risk management have been implemented in the current period.
The following table demonstrates the impact of the New Zealand dollar weakening or strengthening against
the most significant currencies for which Tower has foreign exchange exposure before tax, holding all other
variables constant.
DIRECT IMPACT ON
EQUITY THROUGH CURRENCY
TRANSLATION RESERVEIMPACT ON PROFIT OR LOSS
2025
$000
2024
$000
2025
$000
2024
$000
New Zealand Dollar - USD
Currency strengthens by 10%(731)(619)10 905
Currency weakens by 10%894756 (12)(1,106)
New Zealand Dollar - Fijian Dollar
Currency strengthens by 10%(960)(1,182)(10)(8)
Currency weakens by 10%1,1731,445 13 9
New Zealand Dollar - PNG Kina
Currency strengthens by 10%– – (513)(674)
Currency weakens by 10%– – 708 822
67ANNUAL REPORT 2025
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b. Interest rate risk
Tower is exposed to interest rate risk through its holdings in interest-bearing assets and discounted insurance
cashflows. Interest-bearing assets with a floating interest rate expose Tower to cash flow interest rate risk,
whereas fixed interest investments expose Tower to fair value interest rate risk.
Tower’s interest rate risk primarily arises from fluctuations in the valuation of fixed-interest investments
recognised at fair value and from the underwriting of general insurance contracts, which have interest rate
exposure due to the use of discount rates in calculating the value of insurance liabilities.
Fixed-interest investments are measured at fair value through profit or loss. Movements in interest rates impact
the fair value of interest-bearing financial assets and therefore impact profit or loss (there is no direct impact
on equity). The impact of a 1.75% increase or decrease in interest rates on fixed interest investments and
discounted insurance cashflows, after tax, is shown below (holding everything else constant).
IMPACT ON PROFIT OR LOSS
2025
$000
2024
$000
Interest rates increase by 1.75%(3,408)(2,032)
Interest rates decrease by 1.75%3,4082,032
Tower manages its interest rate risk through Board-approved investment management guidelines that give regard
to policyholder expectations and risks, and to target surplus for solvency as advised by the Appointed Actuary.
Tower has not experienced significant changes in exposure to interest rate risk during the period, and no significant
changes to interest rate risk management have been implemented in the current period.
4.5 Market risk (continued)4.6 Liquidity risk
Liquidity risk arises where liabilities cannot be met as they fall due as a result of insufficient funds and/or
illiquid asset portfolios. Tower mitigates this risk through maintaining sufficient liquid assets to ensure that it can
meet all obligations on a timely basis.
Tower is primarily exposed to liquidity risk through its obligations to make payment for claims of unknown
amounts on unknown dates. Fixed-interest investments can generally be readily sold or exchanged for cash to
settle claims and are managed in accordance with the policy of broadly matching the overall maturity profile to
the estimated pattern of claim payments.
Tower has not experienced significant changes in exposure to liquidity risk during the period, and no significant
changes to liquidity risk management have been implemented in the current period.
The following table presents the estimated amount and timing of the remaining contractual discounted cash
flows arising from investment assets and insurance liabilities.
LIABILITY FOR INCURRED CLAIMSCASH AND INVESTMENTS
2025
$000
2024
$000
2025
$000
2024
$000
Floating interest rate (at call)– – 71,107 75,446
Within 3 months 51,934 62,412 64,650 124,629
3 to 6 months 22,267 25,556 44,431 46,598
6 to 12 months 20,574 22,201 143,623 81,257
1 to 2 years 14,419 14,623 18,378 48,178
2 to 3 years 4,780 5,083 65,427 19,025
3 to 4 years 3,328 4,471 10,521 19,671
4 to 5 years 1,257 616 23,367 13,977
5+ years(186) 565 18,768 14,115
Total 118,373 135,527 460,272 442,896
68ANNUAL REPORT 2025
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4.7 Capital management risk
Capital risk is the risk that capital is insufficient or not of the best form to provide a buffer against losses arising
from unanticipated events, while also maximising the efficient use of capital with a view to enhancing growth
and returns, and adding long-term value to Tower’s shareholders.
Tower has a documented description of its capital management process which sets out Tower’s principles,
approaches, and processes in relation to capital management that enables it to operate at an appropriate level
of target solvency capital which is within the bounds of Tower’s risk appetite.
The capital management process allows the Board, management, rating agencies and the regulator to
understand Tower’s approach to capital management, including requirements for formulating capital targets,
and monitoring, reporting and remediating capital as required.
The operation of the capital management process is reported annually to the Board together with a forward-
looking estimate of expected capital utilisation and capital resilience. In addition, Tower carries out stress,
reverse stress and scenario testing to ensure the level of capital is appropriate given its risk appetite.
a. Regulatory solvency capital
The Reserve Bank of New Zealand (RBNZ) is the prudential regulator and supervisor of all insurers carrying on
insurance business in New Zealand, and is responsible for administering the Insurance (Prudential Supervision)
Act 2010. Tower measures the adequacy of capital against the Solvency Standards published by the RBNZ
alongside additional capital held to meet RBNZ minimum requirements and any further capital as determined
by the Board.
Foreign operations are subject to regulatory oversight in the relevant jurisdiction. It is Tower’s policy to ensure
that each of the licenced insurers in the Group maintain an adequate capital position within the requirements of
the relevant regulator.
During the year ended 30 September 2025 the Group complied with all externally imposed capital
requirements (2024: complied).
Tower has applied the RBNZ’s new Interim Solvency Standard (ISS) from 1 October 2023, and calculated its
solvency position in accordance with the updated ISS effective from 1 March 2025, which represents the
mandatory regulatory framework currently in force. Any future amendments to the ISS will be adopted once
issued and effective.
Tower Limited’s Group and Parent solvency margin are illustrated in the table below.
2025
$000
2024
$000
PREPARED UNDER ISSPREPARED UNDER ISS (PRIOR VERSION)
PARENTGROUPPARENTGROUP
Solvency capital 296,427 314,579 323,834 339,139
Adjusted prescribed capital
requirement (2024: Minimum
solvency capital)207,410 205,487 152,474148,547
Adjusted solvency margin
(2024: Solvency margin)89,017 109,092171,360190,592
Adjusted solvency ratio
(2024: Solvency ratio)143%153%212%228%
The 30 September 2024 comparative is per the prior period audited financial statements prepared in
accordance with the previous version of the RBNZ’s ISS. The current amended version became effective on
1 March 2025.
b. Financial strength rating
Tower Limited has an insurer financial strength rating of “A- (Excellent)” and a long-term issuer credit rating of
“a-” as affirmed by international rating agency AM Best Company Inc. in April 2025.
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4.8 Operational risk
Operational risk is the risk of loss due to inadequate or failed internal processes or systems, human error or
from external events.
Tower’s approach is to proactively manage our operational risks to mitigate potential customer detriment,
regulatory or legal censure, financial and reputational impacts.
Tower has in place appropriate operational processes and systems, including prevention and detection
measures. These include processes which seek to ensure Tower can absorb and/or adapt to internal or
external occurrences that could disrupt business operations.
Management and staff are responsible for identifying, assessing, recording and managing operational risks
in accordance with their roles and responsibilities. Associated controls actively monitored and managed
through our enterprise risk management system (ERMS). Incidents are managed by the first line of defence
and overseen by the second line of defence, with ongoing reporting to management and the Board Risk
Committee.
Tower also maintains and regularly updates its Crisis Management, Business Continuity and Disaster Recovery
Plans to minimise the impact of material incidents or crisis events and to support continuity of critical systems
and processes.
4.9 Regulatory and compliance risk
Regulatory and compliance risk is defined as the risk of legal, regulatory or reputational impacts arising from
failure to manage compliance obligations, or failure to anticipate and prepare for changes in the regulatory
environment.
Tower, via its ERMS, has in place an obligations management framework. The framework provides operational
and managerial oversight of applicable and relevant regulatory compliance obligations to Tower and supports
Tower in discharging its obligations under legislation across NZ and the Pacific.
Tower engages with regulators and regularly monitors developments in regulatory requirements to support
ongoing compliance.
4.10 Conduct risk
Conduct risk is defined as the risk of not meeting customers’ reasonable expectations.
Tower manages Conduct risk through a number of measures including undertaking ongoing product reviews to
ensure products meet the requirements and objectives of customer, reviewing customer feedback to identify
conduct trends or issues, completing quality assurance reviews, supporting vulnerable customers, embedding
and monitoring controls across the business to deliver fair customer treatment.
Tower’s approach to delivering fair customer treatment is outlined in Tower’s Fair Conduct Programme,
developed in accordance with requirements in the Financial Markets (Conduct of Institutions) Amendment
Act 2022.
4.11 Cyber risk
Cyber risk is any risk associated with financial loss, disruption or damage to the reputation of Tower resulting
from either the failure, or unauthorised or erroneous use of its information systems.
Tower’s approach to Cyber risk is to proactively protect against, monitor for and respond to those cyber threats
seen to be targeting the organisation. Tower continues to monitor evolving key cyber risks, which are discussed
and reviewed on a monthly basis through our Management Risk and Conduct Committee and on a quarterly
basis with the Risk Committee. Risk mitigation is achieved through ongoing investment in Tower’s security
programme and Tower’s dedicated security function.
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4.12 Environment, Social and Governance (ESG) risk
Tower Limited’s ESG risks and opportunities are identified and prioritized through our Materiality Assessment
and Risk Management Framework (RMF). They form the basis for Tower’s Sustainability Framework and include
climate-related risk outlined below.
a. Climate-related risk
Climate- related risk relates to the physical and transitional impacts of climate change. Physical risks are
associated with an increasing frequency and severity of severe weather events, sea level rise and coastal
inundation. Transitional risks are related to potential social, political and economic changes as New Zealand
and the World transition to low emission and climate resilient economies.
As a listed, licensed New Zealand insurer Tower qualifies as a climate reporting entity (CRE) under the Financial
Markets Conduct Act 2013 and the Aotearoa New Zealand Climate Standards (NZ CS 1, NZ CS 2 and NZ CS 3)
published by the XRB in December 2022 (CRD Regime). Tower’s climate statement was prepared alongside the
FY25 financial statements and annual report. These disclosures have been made available on Tower’s website,
the New Zealand Stock Exchange (NZX), and the Australian Stock Exchange (ASX). The climate statement
covers Tower’s New Zealand and Pacific operations and responds to the XRB Aotearoa New Zealand Climate
Standards.
Tower’s RMF considers climate-related risks, which are regularly reported to the Board. Tower’s approach to
managing climate-related risk includes continuing to expand our risk-based pricing strategy for climate-related
hazards, maintaining a robust reinsurance programme to provide protection from volatility in weather events,
planning for increasing large events over time in our budget process to limit financial impacts, and supporting
communities through climate change via product development.
Other than the impact on liability for incurred claims, Tower considers that climate change risk does not
materially impact the valuation of Tower’s assets and liabilities, where these assets or liabilities are expected to
be realised in one year or less. For non-current assets, Tower has looked to its short-medium term forecasting,
which implicitly includes allowances for the risk of climate change in forecasts of the severity and frequency
of future claims, including large events. These forecasts show continued profitability for Tower, which supports
the carrying value of non-current assets. Accordingly, Tower does not consider that climate change risk has a
material impact on the assets and liabilities recorded in these financial statements, as at 30 September 2025
(2024: no impact).
5 Capital Structure
This section provides information about how Tower finances its operations through equity. Tower’s capital
position provides financial security to its customers, employees and other stakeholders whilst operating
within the capital requirements set by regulators.
5.1 Contributed equity
NOTE
2025
$000
2024
$000
Opening balance460,734 460,315
Capital return (including costs of the capital return)(45,548)–
Share rights issued under Tower Long-Term Incentive Plan8.52,038 419
Total contributed equity417,224 460,734
Represented by:
Opening balance (number of shares)379,483,987 379,483,987
Issue of new shares under Tower Long-Term Incentive Plan1,128,138 –
Cancellation of shares on capital return(38,060,062)–
Total shares on issue342,552,063 379,483,987
Ordinary shares issued by the Company are classified as equity and are recognised at fair value less direct issue
costs. All shares rank equally with one vote attached to each share. There is no par value for each share.
1,128,138 Ordinary shares were issued during the period to the Group’s former CEO as part of the Company’s
Long Term Incentive Plan. This constituted a modification to the plan as per note 8.5.
On 20 March 2025 the Group implemented its capital return which resulted in 38.1m shares being cancelled.
Total payments in relation to the capital return included $45.1m paid to shareholders, plus transaction costs.
As part of the capital return $0.1m was paid to related parties, being key management personnel, on the same
basis as other shareholders of Tower Limited.
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5.2 Reserves
2025
$000
2024
$000
Opening balance(3,996)(3,098)
Currency translation differences arising during the year2,501 (898)
Foreign currency translation reserve(1,495)(3,996)
Capital reserve11,990 11,990
Separation reserve*(113,000)(113,000)
Reserves(102,505)(105,006)
* The separation reserve was created in 2007 at the time of the demerger of the New Zealand and Australian businesses in
accordance with a ruling provided by the Australian Tax Office (ATO). It will be carried forward indefinitely as a non-equity reserve
to meet the requirements of the ATO.
Recognition and measurement
The assets and liabilities of entities whose functional currency is not the New Zealand dollar are
translated at the exchange rates ruling at reporting date. Income and expense items are translated at a
weighted average of exchange rates over the period approximating spot rates at the transaction dates.
Exchange rate differences are taken to the foreign currency translation reserve.
5.3 Net tangible assets per share
2025
CENTS
2024
CENTS
Net tangible assets per share7873
Net tangible assets per share have been calculated using the net assets as per the consolidated balance sheet
adjusted for intangible assets (including goodwill) and deferred tax divided by total shares on issue.
5.4 Earnings per share
20252024
Profit from continuing operations attributable to shareholders
($ thousands)
83,673 70,884
Profit from discontinued operations attributable to shareholders
($ thousands)
– 3,401
Total profit attributable to shareholders ($ thousands)83,673 74,285
Weighted average number of ordinary shares for basic
earnings per share
359,813,701 378,217,127
Weighted average number of dilutive potential ordinary shares issued
under the Tower Long-Term Incentive Plan
3,938,032 3,225,794
Weighted average number of ordinary shares for diluted
earnings per share
363,751,733 381,442,920
Basic earnings per share (cents) for continuing operations23.3 18.7
Diluted earnings per share (cents) for continuing operations23.0 18.6
Basic earnings per share (cents)23.3 19.6
Diluted earnings per share (cents)23.0 19.5
Basic earnings per share is calculated by dividing the net profit attributable to shareholders by the weighted
average number of fully paid shares.
Diluted earnings per share includes shares that would be issued if unvested share rights were exercised. The
weighted average number of shares is adjusted by the number of outstanding rights to executive shares that
are assessed to be vested at their future vesting dates.
5.5 Dividends
On 30 January 2025, Tower paid a final dividend of 6.5 cents per share in respect of the 2024 financial year,
totalling $24.7m.
On 26 June 2025, Tower paid an interim dividend of 8.0 cents per share, in respect of the 2025 financial year,
totalling $27.4m.
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6 Other consolidated balance sheet items
This section provides information about assets and liabilities not included elsewhere.
6.1 Property, plant and equipment
30 September 2025
OFFICE
EQUIPMENT &
FURNITURE
$000
MOTOR
VEHICLES
$000
COMPUTER
EQUIPMENT
$000
TOTAL
$000
Composition:
Cost7,436 1,545 5,407 14,388
Accumulated depreciation(3,176)(1,199)(4,047)(8,422)
Property, plant and equipment4,260 346 1,360 5,966
Reconciliation:
Opening balance4,770 326 1,639 6,735
Depreciation(744)(205)(1,050)(1,999)
Additions181 250 783 1,214
Disposals(125)(32)(67)(224)
Foreign exchange movements178 7 55 240
Closing Balance4,260 346 1,360 5,966

30 September 2024
OFFICE
EQUIPMENT &
FURNITURE
$000
MOTOR
VEHICLES
$000
COMPUTER
EQUIPMENT
$000
TOTAL
$000
Composition:
Cost7,261 1,524 4,646 13,431
Accumulated depreciation(2,491)(1,198)(3,007)(6,696)
Property, plant and equipment4,770 326 1,639 6,735
Reconciliation:
Opening balance4,123 608 1,549 6,280
Depreciation(623)(241)(1,002)(1,866)
Additions1,360 33 1,092 2,485
Disposals(1)(26)– (27)
Foreign exchange movements(89)(48)– (137)
Closing Balance4,770 326 1,639 6,735
Recognition and measurement
Property, plant and equipment (PPE) is initially recorded at cost including transaction costs and
subsequently measured at cost less any accumulated depreciation and impairment losses.
Depreciation is calculated using the straight line method to allocate the asset’s cost or revalued
amounts, net of any residual amounts, over their useful lives. The assets’ useful lives are reviewed and
adjusted if appropriate at each reporting date. An asset’s carrying amount is written down immediately to
its recoverable amount if it is considered that the carrying amount is greater than its recoverable amount.
Furniture & fittings 5-9 years
Leasehold property improvements 3-12 years
Motor vehicles 5 years
Computer equipment 3-5 years
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6.2 Intangible assets
a. Amounts recognised in the consolidated balance sheet
30 September 2025
GOODWILL
$000
SOFTWARE AND
WORK IN PROGRESS
$000
CUSTOMER
RELATIONSHIPS
$000
TOTAL
$000
Composition:
Cost17,744 123,227 40,674 181,645
Accumulated amortisation – (61,388)(26,797)(88,185)
Intangible Assets17,744 61,839 13,877 93,460
Reconciliation:
Opening balance17,744 60,855 18,022 96,621
Amortisation– (15,367)(4,145)(19,512)
Additions*– 21,188 – 21,188
Impairment**– (4,545)– (4,545)
Transfers to property,
plant and equipment
– (292)– (292)
Closing Balance17,744 61,839 13,877 93,460
* During the year ended 30 September 2025, additions to software assets primarily related to continued investment in Tower’s
core insurance platform, particularly, digitisation of claims processes. The overall claims transformation programme expected to
complete in FY26 and deliver significant value to Tower through more efficient claims handling and cost control. Other noticeable
additions relate to the implementation of an address transformation solution, risk based pricing and contact centre platform
uplift, which are expected to deliver value by way of GWP growth, better underwriting outcomes by avoiding high-risk areas and
improving overall accuracy, improved customer experience and operational savings through automation.
** During the year, an impairment loss was recognized on computer software and work-in-progress assets within the Tower New
Zealand segment. The recoverable amount of these assets was assessed in accordance with IAS 36 Impairment of Assets and
determined to be nil as at the reporting date. Consequently, the carrying amount of these assets has been fully written down to
zero.

30 September 2024
GOODWILL
$000
SOFTWARE AND
WORK IN PROGRESS
$000
CUSTOMER
RELATIONSHIPS
$000
TOTAL
$000
Composition:
Cost17,744 107,977 40,674 166,395
Accumulated amortisation– (47,122)(22,652)(69,774)
Intangible Assets17,744 60,855 18,022 96,621
Reconciliation:
Opening balance17,744 57,326 23,454 98,524
Amortisation– (13,837)(5,432)(19,269)
Additions*– 18,392 – 18,392
Disposals – (47)– (47)
Transfers to property,
plant and equipment
– (979) – (979)
Closing Balance17,74460,85518,02296,621
* During the year ended 30 September 2024, additions to software assets primarily related to continued investment in Tower’s core
insurance platform and website, and digitisation of claims processes. Total software additions in the year ended 30 September
2024 includes $10.8m (2023: $9.6m) of internally generated assets.
74
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Recognition and measurement
Intangible assets are assets without physical substance. They are recognised as an asset if it is probable
that expected future economic benefits attributable to the asset will flow to Tower and that costs can be
measured reliably.
Application software and customer relationships are recorded at cost less accumulated amortisation and
impairment. Application software is amortised on a straight line basis over the estimated useful life of
the software. Customer relationships are amortised over the estimated useful life in accordance with the
pattern of economic benefit consumption.
Internally generated intangible assets are recorded at cost which comprise all directly attributable costs
necessary to create, produce and prepare the asset to be capable of operating in the manner intended
by management. Amortisation of internally generated intangible assets begins when the asset is
available for use and is amortised on a straight line basis over the estimated useful life.
The useful lives for each category of intangible assets with a finite life are as follows:
- capitalised software: 3-5 years for general use computer software and 3-10 years for core operating
system software
- customer relationships: 5-10 years
Goodwill (i.e. assets with an indefinite useful life) generated as a result of business acquisition is initially
measured as the excess of the purchase consideration over the fair value of the net identifiable assets
and liabilities acquired. Goodwill is not subject to amortisation but is tested for impairment annually or
more frequently where there are indicators of impairment.
Critical accounting estimates and judgements
The customer relationships asset predominantly consists of customer relationship assets with a useful
life equivalent to the customer base’s expected lifespan of ten years with the exception of one asset
(acquired in 2021) with an additional non-compete component that has a contracted useful life of five
years.
Where applicable the estimated capitalised cost related to the customer relationships asset has been
apportioned between the two asset components by valuing the non-compete at the differential in net
present value of the asset from improved customer retention over the non-compete period, pro-rated
over the full asset value.
b Impairment testing
An impairment charge is recognised in profit or loss when the carrying value of the asset, or cash-generating
unit (CGU), exceeds the calculated recoverable amount.
(i) Software and customer relationships
Software and customer relationships are reviewed at each reporting date by determining whether there is an
indication that the carrying values may be impaired. If an indication exists, the asset is tested for impairment.
A loss is recognised for the amount by which the carrying value exceeds the asset’s recoverable value.
Certain software assets and work in progress were written off during the year as they are no longer expected
to have future benefits, due to operational changes. Apart from this, there were no indications of impairment
during the year and therefore other assets were not tested for impairment (2024: no indications).
6.2 Intangible assets (continued)
a. Amounts recognised in the balance sheet (continued)
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(ii) Goodwill
Goodwill is deemed to have an indefinite useful life and is tested annually for impairment or more frequently
where there is an indication that the carrying value may not be recoverable.
Goodwill is allocated to cash generating units (CGUs) expected from synergies arising from the acquisition
giving rise to goodwill. Tower’s goodwill is allocated to the New Zealand general insurance CGU.
Tower undertook an annual impairment review and no impairment has been recognised as a result (2024: nil).
Critical accounting estimates and judgements
The recoverable amount of the New Zealand general insurance business is assessed by determining
its value in use by discounting the future cash flows generated from the continuing use of the CGU.
A discount rate of 11.4% was used in the calculation (2024: 11.9%). The cash flows are based on Board-
approved management plans and forecasted profits for FY26 - FY28 (2024: FY25 - FY27). The projected
cash flows are determined based on past performance and management’s expectations for market
developments with a terminal growth rate of 2.5% (2024: 2.5%).
The overall valuation is sensitive to a range of assumptions including management’s forecasted profits,
the discount rate and the terminal growth rate. Reasonable changes to these assumptions would not
result in an impairment.
6.2 Intangible assets (continued)
b. Impairment testing (continued)
6.3 Leases
a. Amounts recognised in the balance sheet
(i) Right-of-use assets
OFFICE SPACE
2025
$000
2024
$000
Composition:
Cost30,628 29,814
Accumulated depreciation(13,471)(9,824)
Right-of-use assets17,157 19,990
Reconciliation:
Opening balance19,990 23,204
Depreciation(3,910)(4,096)
Additions65 65
Disposals– (89)
Revaluations318 518
Net foreign exchange movements694 388
Right-of-use assets17,157 19,990
Recognition and measurement
Right-of-use assets are recognised when Tower has the right to use the corresponding assets. Right-
of-use assets are measured at cost comprising the initial measurement of the lease liability adjusted for
any lease payments made at or before the commencement date less any lease incentives received; and
indirect costs; and restoration costs. Right-of-use assets are generally depreciated over the shorter of the
asset’s useful life and the lease term on a straight line basis.
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a. Amounts recognised in the balance sheet (continued)
(ii) Lease liabilities
2025
$000
2024
$000
Composition:
Current5,197 4,909
Non-current20,349 23,946
Lease liabilities25,546 28,855
Due within 1 year5,197 4,909
Due within 1 to 2 years5,135 4,782
Due within 2 to 5 years13,116 13,309
Due after 5 years3,742 8,114
Discount(1,644)(2,259)
Lease liabilities25,546 28,855
Recognition and measurement
Lease liabilities are recognised at the date Tower has the right to use the corresponding asset.
Lease liabilities are initially measured as the present value of expected lease payments under lease
arrangements. Lease liability will include any option to extend where it is reasonably certain that the
option will be exercised. The lease payments are discounted using the incremental borrowing rate as the
interest rate in the lease cannot be readily determined.
Subsequent repayments are split between principal and interest cost where the finance cost represents
the time value of money and is charged to the profit or loss over the lease period. The discount rate
applied is unchanged from that applied at the initial recognition of the lease, unless there are material
changes to the lease.
6.3 Leases (continued)
b. Amounts recognised in the consolidated statement of comprehensive income
CLASSIFICATION
2025
$000
2024
$000
Depreciation and impairmentInsurance service expense(3,910)(4,096)
Interest expenseFinance costs(744)(882)
Lease expense(4,654)(4,978)
c. Amounts recognised in the consolidated statement of cash flows
2025
$000
2024
$000
Total cash out flow for lease principal payments(5,138)(5,064)
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7 Tax
This section provides information on Tower’s tax expense during the year and its position at reporting date.
7.1 Tax expense
Composition
2025
$000
2024
$000
Current tax35,311 2,948
Deferred tax (benefit)/expense(1,346)29,274
Adjustments in respect of prior years109 11
Tax expense34,074 32,233
Tax expense from continuing operations34,074 31,774
Tax expense from continuing operations – 459
Reconciliation of prima facie tax to income tax expense
2025
$000
2024
$000
Profit before tax from continuing operations117,747 102,658
Profit before tax from discontinued operations– 3,860
Profit before taxation 117,747 106,518
Prima facie tax expense at 28% (2024: 28%)32,969 29,825
Adjustments in respect of prior years109 11
Tax effect of non-deductible expenses and non-taxable
income
(462)1,641
Foreign tax credits written off359 218
Other1,099 538
Tax expense34,074 32,233
Recognition and measurement
Tax expense is calculated on the basis of the applicable tax rates that have been enacted or
substantively enacted at the end of the reporting period in the jurisdictions Tower operates in. There
have been no tax rate changes during the year in these jurisdictions. Current tax expense relates to tax
payable for the current financial reporting period while deferred tax will be payable in future periods.
7.2 Current tax
a. Current tax asset
2025
$000
2024
$000
Excess tax payments in New Zealand* – 11,766
Excess tax payments in the Pacific Islands1,031 1,456
Current tax asset1,031 13,222
* Historic New Zealand tax payments are fully recovered in 2025.
b. Current tax liability
2025
$000
2024
$000
Tax payable to the tax authorities in the Pacific Islands (31)(606)
Tax payable to the New Zealand tax authority(20,574)–
Current tax liabilities(20,605)(606)
Recognition and measurement
Current tax are measured at the amount expected to be recovered from or payable to the tax authorities,
using the tax rates and tax laws that have been enacted or substantively enacted by the end of the
reporting period.
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7.3 Deferred tax
a. Deferred tax assets
Composition
2025
$000
2024
$000
Tax losses recognised571 1,079
Software, property, plant, equipment and other300 1,041
Leases7,123 8,080
Provisions and accruals4,557 3,828
Recognised in profit or loss12,551 14,028
Impact through other comprehensive income772 –
Recognised in comprehensive profit or loss13,323 14,028
Set-off of deferred tax liabilities pursuant to NZ IAS 12(11,956)(13,646)
Deferred tax asset1,367 382
Deferred tax asset from continuing operations1,367 382
Reconciliation of movements
2025
$000
2024
$000
Opening balance14,028 42,948
Movements recognised in other comprehensive income772 –
Movements recognised in profit or loss(1,477)(28,920)
Deferred tax asset pre NZ IAS 12 set off13,323 14,028
b. Deferred tax liability
Composition
2025
$000
2024
$000
Insurance acquisition cash flows(10,374)(9,211)
Customer relationships(3,087)(4,002)
Software, property, plant and equipment(3,601)(6,079)
Leases(6,326)(7,362)
Other*(1,151)(708)
Recognised in profit or loss(24,539)(27,362)
Set-off of deferred tax liabilities pursuant to NZ IAS 1211,956 13,646
Deferred tax liability(12,583)(13,716)
* Primarily relates to deferred tax items in the Pacific islands.
Reconciliation of movements
2025
$000
2024
$000
Opening balance(27,362)(27,008)
Movements recognised in profit or loss2,823 (354)
Deferred tax liabilities pre NZ IAS 12 set off(24,539)(27,362)
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b. Deferred tax liability (continued)
Recognition and measurement
Deferred tax is income tax which is expected to be payable or recoverable in the future as a result of
the unwinding of temporary differences. These arise from differences in the recognition of assets and
liabilities for financial reporting and from the filing of income tax returns. Deferred tax is recognised on all
temporary differences, other than those arising from (i) goodwill or (ii) from the initial recognition of assets
and liabilities in a transaction (other than in a business combination) that affects neither the accounting
nor taxable profit or loss.
At the reporting date, the Group has recognised deferred tax assets in respect of its unused tax losses of
$0.6m in the Pacific Islands (2024: $3.8m).
Deferred tax is calculated at the tax rates that are expected to apply to the year when the liability is
settled or the asset realised, based on tax rates and tax laws that have been enacted or substantively
enacted at reporting date.
Deferred tax assets and liabilities are offset when there is a legally enforceable right to set off current
tax assets against current tax liabilities and when they relate to income taxes levied by the same tax
authority and the Group intends to settle its current tax assets and liabilities on a net basis.
7.4 Imputation credits
The Group imputation credit account reflects the imputation credits held by the Company as the representative
member of the Group.
2025
$000
2024
$000
Imputation credits available for use in subsequent reporting periods10,893–
7.3 Deferred tax (continued)
8 Other information
This section includes additional required disclosures.
8.1 Notes to the consolidated statement of cash flows
Composition
2025
$000
2024
$000
Cash at bank71,047 51,931
Deposits at call – 23,459
Cash and cash equivalents*71,047 75,390
* The average interest rate at 30 September 2025 for deposits is 2.56% (2024: 4.24%).
Tower operates in countries in the Pacific Islands that are subject to foreign exchange restrictions, which may
restrict the ability for immediate use of cash by the parent or other subsidiaries. As at 30 September 2025, this
included NZD 3.7m (2024: NZD 7.4m) held in Papua New Guinea and NZD 3.8m (2024: NZD 3.3m) held in the
Solomon Islands following the sale of the disposal groups. This cash is not currently available for use outside of
these countries.
In accordance with the amendments to IAS 21, Tower assessed the exchangeability of the Papua New Guinean
Kina (PGK) and the Solomon Islands Dollar (SBD) at the reporting date. Although observable exchange rates
were available at each month-end, restrictions on the timely conversion and transfer of funds were identified,
indicating that these currencies were not fully exchangeable in practice.
Where exchangeability was deemed lacking, Tower used the observable spot exchange rate without
adjustment, as it was considered to reflect the rate at which an orderly transaction could occur between
market participants under prevailing conditions.
Risks: Tower is exposed to risks including delays in repatriating funds, potential devaluation, and limitations on
the use of cash for group-wide liquidity purposes.
Management continues to monitor developments in these jurisdictions and has implemented controls to
mitigate financial exposure.
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8.1 Notes to the consolidated statement of cash flows (continued)
Reconciliation of profit for the year to cash flows from
operating activities
2025
$000
2024
$000
Profit after taxation83,67374,285
Adjusted for non-cash items
Depreciation of property, plant and equipment1,9331,866
Depreciation and disposals of right-of-use assets3,9104,096
Impairment and amortisation of intangible assets24,05719,269
Financing costs744885
Fair value losses on financial assets(3,351)(4,034)
Share rights issued under Tower Long-Term Incentive Plan1,982419
Change in deferred tax(2,119)29,280
Change in foreign exchange814759
Adjusted for investing activities
Loss on disposal of fixed assets(69)(30)
Loss on disposal of discontinued operation–(1,988)
Investment expenses547250
Adjusted for movements in working capital
Change in receivables7,726(4,379)
Change in payables and provisions(3,646)19,613
Change in insurance contract liabilities(21,941)(113,363)
Change in reinsurance contract assets14,603116,317
Change in taxation payable34,8991,942
Net cash inflow from operating activities143,762145,187
Net cash inflow from operating activities from continuing operations143,762141,315
Net cash inflow from operating activities from discontinued
operations–3,872
8.2 Related party disclosures
Tower considers key management personnel to consist of the Board of Directors, Chief Executive Officer and
executive leadership team. Information regarding individual director and executive compensation is provided in
the Corporate Governance section of the annual report.
2025
$000
2024
$000
Salaries and other short term employee benefits7,7084,974
Long term benefits525428
Termination benefits340215
Director fees634648
Related party remuneration 9,207 6,265
Tower insurance products are available to all key management personnel on the same terms as available to
other employees. In addition, Tower purchases indemnity insurance for all directors both past and present
covering liabilities and legal expenses incurred whilst in office.
The amounts presented above do not include premiums for directors’ indemnity insurance or transactions
relating to insurance products provided on standard employee terms.
The Board implemented a share-based long-term incentive plan with effect from 7 December 2022.
Refer note 8.5.
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Notes to the consolidated financial statements (continued)
ContentsOur strategy2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index

8.3 Auditor’s remuneration
a. Fees incurred for services provided by PwC New Zealand
2025
$000
2024
$000
Audit and review of the financial statements of the Group570 838
Audit or review related services*48 55
Other assurance services**58 30
Total fees incurred for services provided by PwC New Zealand676 923
* Fee in relation to assurance over the annual solvency return of Tower Limited
** Fee in relation to assurance services over scope 1 and 2 greenhouse gas (GHG) emissions disclosure. (2024: Includes fees in
relation to GHG emissions assurance preconditions assessment.)
b. Fees incurred for services provided by Grant Thornton Fiji (2024 - PwC Fiji)
2025
$000
2024
$000
Audit of the financial statements of subsidiaries134 159
Audit related services*7 23
Total fees incurred for services provided by Grant Thornton Fiji
(2024 - PwC Fiji)
141 182
* This include fees in relation to assurance over the regulatory returns of Tower Insurance (Fiji) Limited. (2024: includes assurance
over the regulatory returns of Tower Insurance (Fiji) Limited and Solomon Island branch).
8.4 Discontinued operations
The Group completed the sale of its Solomon Islands and Vanuatu operations during the year ended
30 September 2024. These operations were classified as discontinued in FY24, and full disclosures were
provided in Note 8.4 of the prior year financial statements.
During the year ended 30 September 2025, the Group finalised completion accounting related to these
disposals. The resulting adjustments to the gain on sale have been recognised in the current period.
No operations have been classified as discontinued in the current financial year.
8.5 Tower Long-Term Incentive Plan
The Group has a long-term incentive plan which is intended to align the interests of management and
shareholders.
Recognition and measurement
The Tower Long-Term Incentive Plan is considered to be an equity settled scheme under NZ IFRS 2
Share-based Payments and the vesting conditions for the scheme include both service and performance
conditions.
The costs associated with this plan are measured at fair value at grant date and are recognised as an
expense in profit or loss over the vesting period, with a corresponding entry to a reserve in equity. The
estimate of the number of rights for which the service conditions are expected to be satisfied is revised
at each reporting date, with any cumulative catch-up adjustment recognised in profit or loss in the period
that the change in estimate occurred. Any rights not vested after the expiry date are cancelled.
The plan provides selected eligible employees with Restricted Share Rights (RSR’s), which ‘vest’ over a three-
year period, during which participants must remain employed by the Group and performance conditions must
be met as follows.
Share Rights vest if Tower’s Total Shareholder Return (TSR) sits at or above the 50th percentile of the NZX 50
index ranked by TSR over the same period:
(i) Where the Company TSR equals the 50th percentile TSR of the index companies over the performance
period, 50% of the share rights will vest.
(ii) Where the Company TSR equals or exceeds the 75th percentile TSR of the index companies over the
performance period, 100% of the share rights will vest
(iii) Where the Company TSR over the performance period exceeds the 50th percentile TSR of the index
companies but does not reach the 75th percentile, then between 50% and 100% of the share rights will
vest as determined on a straight line progression basis.
82ANNUAL REPORT 2025
Notes to the consolidated financial statements (continued)
ContentsOur strategy2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index

During the year the following movements of rights to shares occurred in accordance with the rules of the plan:
20252024
NUMBER OF SHARE
RIGHTS (RSR’S)
NUMBER OF SHARE
RIGHTS (RSR’S)
Share Rights outstanding at the beginning of the period4,411,5801,946,557
Share Rights granted during the period1,206,9872,612,452
Share Rights forfeited during the period(967,211)(147,429)
Share Rights vested and settled during the period(1,128,138)–
Share Rights outstanding at the end of the period3,523,2184,411,580
The weighted average remaining contractual life for share rights outstanding under the plan is 1.3 years (2024:
1.8 years).
During the year, following the resignation of the former CEO, the Board exercised its discretion under the plan
rules to allow unvested awards to vest on a pro-rata basis, subject to the following modifications:
(i) Awards vested pro-rata on 31 January 2025.
(ii) TSR performance hurdles were retained but evaluated as at 31 January 2025.
(iii) A restriction was placed on selling shares on the NZX for six months, except to fund any tax obligations.
The restriction on sale was imposed on 13 February 2025 and did not confer any additional benefit to the
former CEO. Therefore, no further consideration is required under NZ IFRS 2. The other modifications were
determined to have occurred on 8 November 2024. Valuations performed before and after the modification
using a Monte Carlo simulation determined that no incremental fair value was created. Accordingly, the
remaining cost of the original awards was accelerated, resulting in an expense of $0.3 million recognised
during the year (2024: Nil).
The assessed fair value of the rights granted during the year was 79 cents (2024: 40 cents). This was calculated
using a Monte Carlo share price simulation model and key inputs to model are as below:
Assumptions20252024
Share price at grant date (dollars)1.410.69
10 Day volume weighted average price (dollars)1.330.59
Exercise PriceNilNil
Option life3 years3 years
Risk-free rate3.83%4.51%
Expected volatility23%20%
The expected price volatility is based on annualised price volatility for the four years prior to the grant date.
The total share-based payment expense during the year was $0.7m (2024: $0.4m).
There were no liabilities arising from share-based payment transactions at reporting date (2024: nil).
The plan allows participants to request a PAYE Election, under which they may ask Tower to make payment to
the IRD to settle their PAYE liability subject to Tower being reimbursed by the participant. Tower is not required
to accept any participant’s request for a PAYE Election. Tower has not entered into any agreed PAYE Election
arrangements during the year.
8.6 Contingent liabilities
Claims and disputes
The Group is occasionally subject to claims and disputes as a commercial outcome of conducting insurance
business. Provisions are recorded for these claims or disputes when it is probable that an outflow of resources
will be required to settle any obligations. Best estimates are included within claims reserves for any litigation
that has arisen in the usual course of business.
The Group has no other contingent liabilities.
8.7 Capital commitments
As at 30 September 2025, Tower has nil capital commitments (2024: nil).
8.8 Subsequent events
On 27 November 2025, the Board approved a final dividend of 16.5 cents per share, with the dividend being
payable on 30 January 2026 for approximately $56.5m. There were no other subsequent events.
8.5 Tower Long-Term Incentive Plan (continued)
83ANNUAL REPORT 2025
Notes to the consolidated financial statements (continued)
ContentsOur strategy2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index

Independent auditor’s report
To the shareholders of Tower Limited
Our opinion
In our opinion, the accompanying consolidated financial statements (the financial statements) of
Tower Limited (the Company), including its subsidiaries (the Group), present fairly, in all material
respects, the financial position of the Group as at 30 September 2025, its financial performance,
and its cash flows for the year then ended in accordance with New Zealand Equivalents to
International Financial Reporting Standards (NZ IFRS) and International Financial Reporting
Standards Accounting Standards (IFRS Accounting Standards).
What we have audited
The Group’s financial statements comprise:
• the consolidated balance sheet as at 30 September 2025;
• the consolidated statement of comprehensive income for the year then ended;
• the consolidated statement of changes in equity for the year then ended;
• the consolidated statement of cash flows for the year then ended; and
• the notes to the consolidated financial statements, comprising material accounting policy
information and other explanatory information.
Basis for opinion
We conducted our audit in accordance with International Standards on Auditing (New Zealand)
(ISAs (NZ)) and International Standards on Auditing (ISAs). Our responsibilities under those
standards are further described in the Auditor’s responsibilities for the audit of the financial
statements section of our report.
We believe that the audit evidence we have obtained is sufficient and appropriate to provide a
basis for our opinion.
Independence
We are independent of the Group in accordance with Professional and Ethical Standard 1
International Code of Ethics for Assurance Practitioners (including International Independence
Standards) (New Zealand) (PES 1) issued by the New Zealand Auditing and Assurance Standards
Board and the International Code of Ethics for Professional Accountants (including International
Independence Standards) issued by the International Ethics Standards Board for Accountants
(IESBA Code), and we have fulfilled our other ethical responsibilities in accordance with these
requirements.
In our capacity as auditor and assurance practitioner, our firm also provides other assurance
services. Certain partners and employees of our firm may deal with the Group on normal terms
within the ordinary course of trading activities of the business. The firm has no other relationship
with, or interests in, the Group.
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Key audit matters
Key audit matters are those matters that, in our professional judgement, were of most significance in our audit of the financial statements of the current year. These matters were addressed in the
context of our audit of the financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters.
Description of the key audit matterHow our audit addressed the key audit matter
Valuation of the liability for incurred claims (2025: $118,373,000; 2024: $135,527,000)
We considered the valuation of the liability for incurred claims a key audit matter as it
involves an estimation process combined with significant judgements and assumptions,
made by the Group, to determine the balance.
The liability for incurred claims relates to claims incurred under groups of insurance contracts,
as at and prior to the reporting date, which have not been paid. The liability includes:
• an estimate of the present value of future cash outflows to settle claims; and
• a risk adjustment for non-financial risk.
There is uncertainty over the amount that reported claims, and claims incurred at the
reporting date but not yet reported to the Group, will ultimately be settled at. The estimation
process relies on the quality of underlying claims data and the use of informed estimates to
determine the quantum of the ultimate future cash flows.
Key actuarial assumptions applied in the valuation of future cash flows include:
• expected future claims development;
• claims handling expense ratios;
• future Canterbury Earthquake overcap property claims; and
• discount rate.
Changes in assumptions can lead to significant movements in the liability for incurred claims.
A risk adjustment allows for the inherent uncertainty in the amount and timing of the
cash flows that arise from non-financial risk related to a group of insurance contracts. In
determining the risk adjustment, the Group makes judgements about the level of required
capital to support the insurance business, claims experience of business classes, volatility of
each class of business written and the correlation between different geographical locations.
Refer to note 2.4 to the financial statements.
Our audit procedures included obtaining an understanding of key claims and actuarial processes and
controls, including key data reconciliations and the Group’s review of the actuarial estimates of the
liability for incurred claims.
Claims data is the key input to the actuarial estimate. Accordingly, we evaluated the design
effectiveness and tested key controls over claims processing.
On a sample basis, we:
• assessed claim case estimates at year end to check that they were supported by an appropriate
management assessment and documentation, and correctly classified to relevant claim type;
• assessed the accuracy of the previous claim case estimates by comparing to the actual amount
settled during the year and assessed the changes in the claim case estimate to determine whether
such change was based on new information available during the year;
• inspected claims paid during the year to confirm that they are supported by appropriate
documentation;
• agreed key attributes of insurance contract information to each underlying contract to determine
the level of aggregation and groups used for valuation purposes; and
• tested the integrity of data used in the actuarial models by agreeing relevant model inputs, such as
claims data, to source data.
Together with our actuarial experts, we:
• considered the work and findings of the Group’s Actuaries;
• evaluated the actuarial models and methodologies used, by comparing to generally accepted
models and methodologies applied in the sector and to the prior year, seeking justification for any
variances;
• assessed key actuarial judgements and assumptions and challenged them by comparing with our
expectations based on the Group’s historical claims experience, our own sector knowledge and
independently observable industry trends (where applicable);
Independent auditor’s report (continued)
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Independent auditor’s report (continued)
Description of the key audit matterHow our audit addressed the key audit matter
• tested on a sample basis, the underlying calculations in certain valuation models;
• evaluated the relevant underlying calculation used to derive the risk adjustment, including the
significant assumptions, against our own knowledge of the Group’s business and independently
observable market inputs (where applicable); and
• assessed the appropriateness of presentation and disclosures in the financial statements against
the requirements of the accounting standards.
Our audit approach
Overview
Overall Group materiality: $5.9 million, which represents approximately
1% of Insurance revenue.
We chose insurance revenue as the benchmark because, in our view, it
is the benchmark against which the performance of the Group is most
commonly measured by users, and is a generally accepted benchmark
for insurance companies. The application of approximately 1% is based
on our professional judgement, noting that it is also within the range of
commonly accepted revenue related thresholds.
A full scope audit was performed for the Company based on its financial
significance to the Group. Specified audit procedures were performed
on financial statement line items of certain subsidiaries and analytical
review procedures were performed on remaining Group entities.
As reported above, we have one key audit matter, being:
• Valuation of the liability for incurred claims.
Materiality
Group scoping
Key audit
matters
As part of designing our audit, we determined materiality and assessed the risks of material
misstatement in the financial statements. In particular, we considered where management made
subjective judgements; for example, in respect of significant accounting estimates that involved
making assumptions and considering future events that are inherently uncertain. As in all of our
audits, we also addressed the risk of management override of internal controls, including among
other matters, consideration of whether there was evidence of bias that represented a risk of
material misstatement due to fraud.
Materiality
The scope of our audit was influenced by our application of materiality. An audit is designed
to obtain reasonable assurance about whether the financial statements are free from material
misstatement. Misstatements may arise due to fraud or error. They are considered material if,
individually or in the aggregate, they could reasonably be expected to influence the economic
decisions of users taken on the basis of the financial statements.
Based on our professional judgement, we determined certain quantitative thresholds for
materiality, including the overall Group materiality for the financial statements as a whole as set
out above. These, together with qualitative considerations, helped us to determine the scope
of our audit, the nature, timing and extent of our audit procedures, and to evaluate the effect of
misstatements, both individually and in the aggregate, on the financial statements as a whole.
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Independent auditor’s report (continued)
How we tailored our group audit scope
We tailored the scope of our audit in order to perform sufficient work to enable us to provide
an opinion on the financial statements as a whole, taking into account the structure of the Group,
the accounting processes and controls, and the industry in which the Group operates.
Other information
The Directors are responsible for the other information. The other information comprises the
information included in the Annual report, but does not include the financial statements and our
auditor’s report thereon.
Our opinion on the financial statements does not cover the other information and we do not
express any form of audit opinion or assurance conclusion thereon.
In connection with our audit of the financial statements, our responsibility is to read the other
information and, in doing so, consider whether the other information is materially inconsistent
with the financial statements or our knowledge obtained in the audit, or otherwise appears
to be materially misstated. If, based on the work we have performed on the other information
that we obtained prior to the date of this auditor’s report, we conclude that there is a material
misstatement of this other information, we are required to report that fact. We have nothing to
report in this regard.
Responsibilities of the Directors for the financial statements
The Directors are responsible, on behalf of the Company, for the preparation and fair presentation
of the financial statements in accordance with NZ IFRS and IFRS Accounting Standards, and for
such internal control as the Directors determine is necessary to enable the preparation of financial
statements that are free from material misstatement, whether due to fraud or error.
In preparing the financial statements, the Directors are responsible for assessing the Group’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 the Directors either intend to liquidate
the Group or to cease operations, or have no realistic alternative but to do so.
Auditor’s responsibilities for the audit of the financial statements
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 an
auditor’s report that includes our opinion. Reasonable assurance is a high level of assurance,
but is not a guarantee that an audit conducted in accordance with ISAs (NZ) and ISAs will always
detect a material misstatement when it exists. Misstatements can arise from fraud or error and
are considered material if, individually or in the aggregate, they could reasonably be expected to
influence the economic decisions of users taken on the basis of these financial statements.
A further description of our responsibilities for the audit of the financial statements is located at
the External Reporting Board’s website at:
https://www.xrb.govt.nz/standards/assurance-standards/auditors-responsibilities/audit-report-1-1/
This description forms part of our auditor’s report.
Who we report to
This report is made solely to the Company’s shareholders, as a body. Our audit work has been
undertaken so that we might state those matters which 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 shareholders, as
a body, for our audit work, for this report, or for the opinions we have formed.
The engagement partner on the audit resulting in this independent auditor’s report is Lisa Crooke.
For and on behalf of:
PricewaterhouseCoopers Auckland
27 November 2025
87ANNUAL REPORT 2025 ContentsOur strategy2025 in reviewSustainabilityConsolidated financial statementsCorporate governanceGRI content index

27 November 2025
The Directors
Tower Limited
136 Fanshawe Street
Auckland 1010
Dear Directors
Review of Actuarial Information contained in the financial statements
Finity Consulting Pty Limited (Finity) has been asked by Tower Limited (Tower) to carry out a
review of the 30 September 2025 Actuarial Information contained in the financial statements and
used in their preparation and to provide an opinion as to the appropriateness of this information.
This letter sets out the findings of our review, as required under Section 78 of the Insurance
(Prudential Supervision) Act 2010 (the Act).
Geoff Atkins is an employee of Finity and is the Appointed Actuary to Tower. Finity has no
relationship with Tower apart from being a provider of actuarial services.
We prepared the actuarial valuation of liabilities remaining from the Canterbury Earthquakes and
reviewed the actuarial valuations of incurred claims liabilities and reinsurance recoverables for
the New Zealand business and the Pacific Islands businesses. We also reviewed the assessment
of onerous contracts. The scope of our review was as required by Section 77 of the Act.
Having carried out the review, nothing has come to our attention that would lead us to believe
that the Actuarial Information used in the financial statements or their preparation, or the
determination of the solvency position for Tower as at 30 September 2025 is inappropriate.
In our opinion the company has maintained a solvency margin in excess of the minimum required
as at 30 September 2025.
Geoff Atkins (Appointed Actuary)
Fellow of the New Zealand Society
of Actuaries
Anagha Pasche
Fellow of the New Zealand
Society of Actuaries
Appointed actuary’s report
No limitations were placed on us in performing our review and all data and information requested
was provided.
The report is being provided for the sole use of Tower for the purpose stated above. It is not
intended, nor necessarily suitable, for any other purpose and should only be relied on for the
purpose for which it is intended..
Yours sincerely
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Underlying profit reconciliation
Reconciliation between underlying profit after tax and reported profit after tax*
FY25
UNDERLYING
PROFIT
$M
NON-
UNDERLYING
ITEMS
(1)
$M
MANAGEMENT
EXPENSE
RECLASSES
(2)
$M
RECLASS OF
REINSURANCE
EXPENSES
(3)
$M
RECLASS OF
REINSURANCE &
OTHER RECOVERY
REVENUES
(4)
$M
FY25
REPORTED
PROFIT
$M
Gross written premium599.8
Insurance revenue597.1(2.7)594.3
Reinsurance expense(80.1)80.1
Net insurance revenue517.0(2.7)0.080.10.0
BAU claims expense(213.6)(11.0)(29.8)1.8
Large event claims expense(7.2)
Management expenses(153.0)(13.9)28.8
Net commission expense(9.2)(4.4)
Insurance service expense(383.1)(24.9)(1.0)0.0(2.6)(411.6)
Net expense from reinsurance
contracts held
(80.1)2.6(77.5)
Insurance service result133.9(27.6)(1.0)0.00.0105.2
Net investment income19.219.2
Net insurance finance expense(1.6)(1.6)
Other income and expenses(1.5)(4.6)1.0(5.1)
Underlying profit before tax150.0
Income tax expense(42.8)8.7(34.1)
Underlying profit after tax107.2
Canterbury impact(7.9)7.9
Other non-underlying costs(15.7)15.7
Reported profit after tax83.70.00.00.00.083.7
Underlying and reported profit:
— “Net insurance revenue”, “net insurance service expense” and
“underlying profit” do not have a standardised meaning under
Generally Accepted Accounting Practice (GAAP). Consequently,
they may not be comparable to similar measures presented by
other reporting entities and are not subject to audit or independent
review.
— Tower uses underlying profit as an internal reporting measure as
management believes it provides a better measure of Tower’s
underlying performance than reported profit, as it excludes large or
non-recurring items that may obscure trends in Tower’s underlying
performance, and is useful to investors as it makes it easier to
compare Tower’s financial performance between periods.
— Tower has applied a consistent approach to measuring which items
are excluded from underlying profit in the current and comparative
periods.
— “Reported profit after tax” is calculated and presented in
accordance with GAAP
* This reconciliation is unaudited and provided for informational purposes only.
(1) Non-underlying items include net impact of customer remediation provision increase and related costs, Canterbury earthquake valuation update, regulatory and
compliance projects such as Financial Markets (Conduct of Institutions) Amendment Act).
(2) Reclassification of claims handling expenses from management expenses to claims expense; and FX gains/losses from other income to management expenses.
(3) Reclassification of reinsurance expenses to present as net income from reinsurance contracts held for statutory purposes.
(4) Reclassification of reinsurance and other recoveries to present as net income from reinsurance contracts held for statutory purposes.
89
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Corporate
governance
at Tower
90ANNUAL REPORT 2025 ContentsGRI content index Consolidated financial statementsSustainabilityOur strategy2025 in reviewCorporate governance

This section of the Annual Report provides an overview
of the corporate governance principles, policies and
processes adopted and followed by Tower’s Board (Board)
during the year ending 30 September 2025 (FY25).
The Board is committed to achieving high standards of corporate governance, ethical
behaviour, and accountability. When there are developments in corporate governance
practices, the Board reviews these against Tower’s practices and updates them
where appropriate, including seeking external advice to encourage an environment of
continuous improvement in Board performance.
For the reporting period to 30 September 2025, the Board considers that Tower’s
corporate governance practices have materially adhered to the NZX Corporate
Governance Code (NZX Code). Further information about the extent to which Tower has
complied with each of the NZX Code recommendations is set out in Tower’s corporate
governance statement, available on Tower’s website at tower.co.nz/investor-centre.
Statutory disclosures
Diversity
Gender diversity
The below table provides a quantitative breakdown as to the gender composition of
Tower’s Directors and Officers, and other employee groups as at 30 September 2025,
compared to 30 September 2024, including subsidiaries. The Executive Leadership Team
includes the Chief Executive Officer and those employees who report directly to him.
The Senior Leadership Team refers to employees in remuneration band 8 and above. Total
company figures exclude the Board of Directors, and include permanent and fixed term
employees, and the employees of Tower’s Pacific Island subsidiaries:
30 SEPTEMBER 202530 SEPTEMBER 2024
GROUP% GROUPNUMBER% GROUPNUMBER
Board of Directors
Males60%380%4
Females40%220%1
Gender Diverse0%00%0
Executive Leadership team
Males50%550%5
Females40%450%5
Gender Diverse0%00%0
Prefer not to disclose0%00%0
Did not disclose10%10%0
Senior Leadership team
Males51%2660%29
Females39%2033%16
Gender Diverse2%10%0
Prefer not to disclose4%26%3
Did not disclose4%20%0
Employees
Males34%30734%294
Females63%56762%532
Gender Diverse1%61%6
Prefer not to disclose2%143%25
Did not disclose1%110%0
Total company
Males35%33836%328
Females61%59160%553
Gender Diverse1%71%6
Prefer not to disclose2%163%28
Did not disclose1%140%0
Total employees966915
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Evaluation from the Board on Tower’s performance with respect
to diversity and inclusion
Tower has a Diversity Equity and Inclusion Policy, which outlines Tower’s commitment
to diversity, equity and inclusion, and provides principles and approaches to cultivate a
respectful and inclusive environment.
The Policy notes that the Company actively seeks to increase diversity in all its forms,
including but not limited to race, ethnicity, gender identity, experience, education, sexual
orientation, age, disability, neurodiversity, socio-economic status and cultural background.
The Board has delegated to its People, Remuneration and Appointments Committee the
responsibility to review the Company’s performance against measurable objectives for
achieving diversity and inclusion, pursuant to the Diversity, Equity and Inclusion policy.
In furtherance of those goals, in FY25, the Company included performance objectives
attached to inclusion, equity and diversity goals for senior leadership.
Employee Representative Groups continued to strengthen engagement and broaden
opportunities for sharing diverse perspectives, supported by investment in the two new
Fiji groups during FY25. Tower aimed to:
• Maintain diversity and inclusion engagement target of 8.8 for both ethnic and gender
diverse populations. The Company achieved an engagement result of 8.8 for the year
ending 30 September 2025.
• Have 25% of employees engaged in at least one Employee Representative Group.
31% of employees participated in a Tower Employee Representative Group this year.
• Maintain our 0.0% (+/- 0.9%) Pay Equity gap. Tower has maintained this with a Pay
Equity gap of 0.3% (men are paid 0.3% more than women for the same role in New
Zealand).
• Reduce overall New Zealand pay gap by 1% (from 20.2%). This goal was achieved,
with Tower’s New Zealand pay gap reducing by 3.7% to 16.5%.
• Continued reporting and analysis of Māori and Pacific pay equity analysis for
New Zealand based employees for the People, Remuneration and Appointment
Committee.
• Improve retention of diverse talent. This year Tower elected to focus entirely on Fiji
with 100% of participants on our Talent Acceleration Programme being Pasifika.
62% of participants identify as female. Overall retention of participants in the talent
programmes is 100%, compared to 85% in FY24.
The Board considers that in FY25, the Company has continued to increase diversity in
all its forms across the business.
Board and Committee Composition
During FY25 the Board comprised the following members:
Michael Stiassny (Chair)
Graham Stuart (retired 11 February 2025)
Marcus Nagel
Geraldine McBride
Mike Cutter
Naomi Ballantyne (from 21 May 2025)
Director independence
The Board has determined, based on information provided by directors regarding
their interests, and criteria for independence benchmarked against the FMA, RBNZ
and NZX independence requirements, that at 30 September 2025, all directors were
independent. The Board had previously considered that Mr Nagel was not independent
due to his relationship with Tower’s largest shareholder. However, following the sell-
down of that shareholding, the Board has determined that there are no factors which
create a Disqualifying Relationship in terms of the Listing Rules or Corporate Governance
Code which apply to Mr Nagel, and he is now considered to be independent.
The Board has also considered the independence of Mr Stiassny, noting that his tenure
as director now exceeds 12 years. Having regard to tenure, and other factors which may
tend to imply a Disqualifying Relationship, including relationships with shareholders and
management, the Board remains satisfied that Mr Stiassny is independent.
ANNUAL REPORT 202592 ContentsOur strategy2025 in reviewSustainabilityConsolidated financial statementsGRI content index Corporate governance

Board Committees
During FY25 the Board had the following Committees:
Audit Committee
Members: Graham Stuart (Chair) until 11 February 2025, Mike Cutter (Chair) from 12
February 2025, Naomi Ballantyne from 21 May 2025, Geraldine McBride, Marcus Nagel,
Michael Stiassny
Risk Committee
Members: Geraldine McBride (Chair), Naomi Ballantyne from 21 May 2025, Mike Cutter,
Marcus Nagel, Michael Stiassny, Graham Stuart until 11 February 2025
People, Remuneration & Appointments Committee
Members: Michael Stiassny (Chair), Naomi Ballantyne from 21 May 2025, Mike Cutter,
Geraldine McBride, Marcus Nagel, Graham Stuart until 11 February 2025
Results Sub-Committee
Members: Michael Stiassny (Chair) 28 November 2024, 20 May 2025,
Graham Stuart 28 November 2024, Mike Cutter 20 May 2025
Board and Committee meeting attendance
Director attendance at Board and Committee meetings held from 1 October 2024 to
30 September 2025 is set out below:
BOARD
AUDIT
COMMITTEE
RISK
COMMITTEE
PEOPLE, REMUNERATION
AND APPOINTMENTS
COMMITTEE
RESULTS SUB-
COMMITTEE
Meetings held 105552
Michael Stiassny 104452
Graham Stuart23321
Marcus Nagel10555
Geraldine McBride10555
Mike Cutter105551
Naomi Ballantyne4111
In addition to meetings, the Board held a two-day strategy session in July, attended by
Directors, members of the Executive Leadership Team and various speakers and experts.
Remuneration
Director Remuneration
The Board’s approach is to remunerate directors at a similar level to comparable
Australasian companies, with a small premium to reflect the complexity of the insurance
and financial services sector. At the Annual Shareholders’ Meeting in February 2004
shareholders approved a maximum payment of NZ$900,000 per annum for director fees.
Tower seeks external advice when reviewing Board remuneration. The Remuneration
and Appointments Committee is responsible for assisting directors with the review
of directors’ fees. Remuneration is considered through the lens of the Director and
Executive Remuneration Policy to ensure that directors and executives are remunerated
in a fair and reasonable manner, and that such remuneration is transparently
communicated to relevant stakeholders.
Annual fees as approved by the Board with effect from 1 October 2020 are:
TOWER LIMITED BOARD/COMMITTEE FEESCHAIR (NZ$)MEMBER (NZ$)
Base fee – Board of directors180,000100,000
Audit Committee10,000(included in base Director fee)
Risk Committee10,000(included in base Director fee)
People, Remuneration and Appointments Committee–(included in base Director fee)
The total remuneration received by each director for the year ended 30 September
2025 is set out below (NZ$, and exclusive of GST, if any):
REMUNERATION AND BENEFITS RECEIVED BY TOWER LIMITED DIRECTORS
IN THE YEAR ENDED 30 SEPTEMBER 2025
Michael Stiassny180,000
Graham Stuart47,596
Geraldine McBride110,000
Marcus Nagel 100,000
Mike Cutter*112,053
Naomi Ballantyne37,499
* Mr Cutter received an inadvertent overpayment when he became Chair of the Audit Committee. This overpayment has been
corrected, and the correction will be reflected in the FY26 annual report.
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REMUNERATION AND BENEFITS RECEIVED BY TOWER SUBSIDIARY DIRECTORS
IN THE YEAR ENDED 30 SEPTEMBER 2025
Isikeli Tikoduadua, Director Tower Insurance (Fiji) Limited and Southern
Pacific Insurance Company (Fiji) Limited18,000 Fijian Dollars
Barry Whiteside, Director Tower Insurance (Fiji) Limited and Southern
Pacific Insurance Company (Fiji) Limited, Tower Insurance (Fiji) Limited20,000 Fijian Dollars
Michael Yee Joy*, Director, Tower Insurance (Fiji) Limited & Chair of the
Audit & Risk Committee, Tower Insurance (Fiji) Limited22,500 Fijian Dollars
* Mr Yee Joy received an additional payment for services provided in FY24, for which remuneration had not previously been paid.
Directors of Tower Limited and its subsidiaries are reimbursed for out of pocket
expenses incurred in the course of their activities as directors, including travel and other
expenses. As these expenses are not in the nature of remuneration or benefits, they are
not listed here.
No employee of Tower Limited or its subsidiaries who acts as a director of a subsidiary
receives any remuneration for their role as a director of that subsidiary. The number
of employees who receive remuneration of more than $100,000 is included in the
remuneration table on page 96 of this report.
CEO and Senior Executive Remuneration
In FY25, Tower received external and independent advice from EY on the CEO’s
remuneration, including market benchmarking against comparable New Zealand
companies. EY’s advice was sought in order to gauge actual and forecast movements
within the market, and to assess the levels of fixed and target total remuneration to pay
its CEO. EY reported to the board on this advice.
The Chief Executive Officer remuneration package consists of base salary, a Short Term
Incentive (STI) and a Long Term Incentive (LTI).
Mr Turnbull’s Remuneration
Former Chief Executive Officer Blair Turnbull resigned effective 12 February 2025.
No increase was made to his FY24 base salary, which was $681,575, plus a 3% KiwiSaver
contribution. In addition, he received Life Insurance and Income Protection Insurance
as part of Tower’s group scheme available to all permanent employees working at least
15 hours a week.
Mr Turnbull’s exit package comprised: the base salary until 12 February 2025; six months
salary in lieu of notice ($340,787.50); plus any accrued/entitled holiday pay and
KiwiSaver. He also received pro-rated outcomes based on months completed (through
31 January 2025) for his FY22, FY23 and FY24 LTI schemes, which are summarised in
the table below.
CEO’s Long Term Incentives
GRANT
YEAR
PERFORMANCE
PERIOD
NUMBER OF
SHARE RIGHTS
ISSUED
VALUE OF
GRANT ON
GRANT DATE ($)
1
PRO-RATA
VESTING TO
31 JAN 2025
NUMBER OF
SHARE RIGHTS
VESTED
VALUE OF
VESTED LTI
OUTCOMES
2
FY247 Dec 2023 to
6 Dec 2026
1,155,509 $657,888 40.00% 449,365 $638,098
FY237 Dec 2022 to
6 Dec 2025
939,840 $986,832 73.33% 678,773 $963,858
FY221 Oct 2021 to
30 Sept 2025
N/A – Cash
scheme
$650,00083.33%N/A – Cash
scheme
$541,667
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Mr Johnston’s Remuneration
Paul Johnston commenced as Chief Executive Officer on 16 June 2025, after acting as
Interim Chief Executive Officer between 13 February 2025 and 15 June 2025 following
Mr Turnbull’s departure.
Mr Johnston’s FY25 base salary in respect of his role as Chief Executive Officer is
$681,000, plus a 3% employer KiwiSaver contribution. In addition, Mr Johnston receives
Life Insurance and Income Protection Insurance as part of Tower’s group scheme
available to all permanent employees working at least 15 hours a week.
Variable Remuneration
Mr Johnston is eligible for a maximum STI of $322,090 (reflecting his CFO, Acting CEO
and CEO roles) based on performance against a company scorecard that includes
financial targets, customer metrics and employee engagement. In FY25, Mr Johnston
was awarded an STI payment of $277,992 based on a company scorecard against
targets of 71.6%, as detailed below:
PILLARMEASURE%
THRESHOLD
(30%)
TARGET
(60%)
MAXIMUM
(100%)
FY25
ACTUAL
SCORECARD
OUTCOME
Financial
(75%)
Underlying
NPAT45%$50m $54m $65m $107.2m45%
GWP10%$645m $656m $675m $600m -
MER10%29.5%

28.8% 27.8% 31.4% -
BAU Claims
Ratio10%50.5% 49.2% 48.4% 41.0% 10%
Customer
(20%)
NPS10% 37 41 44 44 10%
Retention
10% 78% 79% 80% 78.2% 3.6%
People
(5%)
Engagement5% 8.1 8.2 8.3 8.2 3.0%
Company Outcome71.6%
The STI was calculated based on a blended salary pro-rated for Mr Johnston’s time in
role as Chief Financial Officer, Acting Chief Executive Officer and Chief Executive Office
throughout the year. As allowed in the scheme rules, the Board exercised its discretion
to apply a multiplier of 1.2x to the scheme outcomes, reflecting NPAT being above
threshold. A multiplier ranging from 1.2x to 1.4x was applied to all scheme participants.
As Chief Financial Officer, Mr Johnston received 218,606 unvested share rights pursuant
to the FY25 LTI plan that vests based on Tower’s Total Shareholder Return performance
relative to the performance of companies within the NZX50 index. The details of the LTI
scheme are included in the Corporate Governance Statement.
No further LTI grants were made to him in respect of his appointment as CEO.
Mr Johnston’s Long Term Incentives
GRANT
YEARPERFORMANCE PERIOD
NUMBER OF
SHARE RIGHTS ISSUED
ON GRANT DATE
VALUE OF
SHARE RIGHTS
ON GRANT DATE ($)STATUS
FY25 12 December 2024 to
11 December 2027
218,606 $290,745 Unvested
FY24 7 December 2023 to
6 December 2026
462,712 $273,000 Unvested
FY23 7 December 2022 to
6 December 2025
222,858 $156,000 Unvested
ANNUAL REPORT 202595 ContentsOur strategy2025 in reviewSustainabilityConsolidated financial statementsGRI content index Corporate governance

Employee remuneration
The table below sets out the number of employees or former employees of Tower and
its subsidiaries (excluding directors and former directors) who received remuneration
and other benefits valued at or exceeding $100,000 for the years ended 30 September
2024 and 2025. Tower has not previously included its subsidiaries in this reporting.
Remuneration includes base salary, performance payments and redundancy or
other termination payments. The 2025 figures include company contributions of 3%
of gross earnings for those individuals who are members of a KiwiSaver scheme.
The remuneration bands are expressed in New Zealand Dollars:
FROMTOFY25FY24
100,000109,9993636
110,000119,9993631
120,000129,9992235
130,000139,9993831
140,000149,9993429
150,000159,9992928
160,000169,9992514
170,000179,999194
180,000189,99978
190,000199,99995
200,000209,99934
210,000219,99925
220,000229,99933
230,000239,99922
240,000249,99942
250,000259,99930
260,000269,99954
270,000279,99924
280,000289,99933
290,000299,99911
300,000309,99901
310,000319,99901
320,000329,99921
330,000339,99911
340,000349,99900
FROMTOFY25FY24
350,000359,99921
360,000369,99910
370,000379,99910
380,000389,99910
390,000399,99910
410,000419,99922
420,000429,00021
430,000439,99910
440,000449,99902
450,000459,00031
470,000479,99901
600,000609,99910
610,000619,99901
640,000649,00010
650,000659,99901
660,000669,00010
670,000679,99910
680,000689,99901
700,000709,00000
730,000739,99910
740,000749,99910
880,000889,00010
1,100,0001,109,99910
1,600,0001,609.99910
Total306264
Auditor fees paid on behalf of Tower and its subsidiaries are disclosed in the financial
statements.
Security Holder Information
Substantial product holders (as at 30 September 2025)
The names and holdings of Tower’s substantial product holders based on notices filed
with Tower under the Financial Markets Conduct Act 2013 at 30 September 2025 are:
NAMETOTAL ORDINARY SHARES
Accident Compensation Corporation27,464,356
Pacific International Insurance Pty Limited20,925,211*
Forsyth Barr Investment Management Limited17,151,296
* Pacific International insurance Pty Limited filed an initial substantial holder notice, noting a holding of 22,072,615 shares.
Tower Limited notes the capital return of March 2025, together with other trades not required to be disclosed, has reduced the
shareholding from that initially disclosed..
These totals may differ from the shareholdings described in other sections on this report.
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Largest shareholders (30 September 2025)
The names and holdings of the 20 largest registered Tower shareholders on
30 September 2025 were:
UNITS% UNITS
1 HSBC Nominees (New Zealand) Limited – NZCSD <Hkbn90>33,349,9799.74
2 Accident Compensation Corporation – NZCSD <Acci40>26,176,9277.64
3 Pacific International Insurance Pty Limited20,925,2116.11
4 Forsyth Barr Custodians Limited <1-Custody>19,934,3965.82
5 Citibank Nominees (New Zealand) Limited – NZCSD <Cnom90>16,889,0354.93
6 BNP Paribas Nominees (Nz) Limited – NZCSD <Bpss40>16,733,4274.88
7 Custodial Services Limited <A/C 4>14,545,7014.25
8 Masfen Securities Limited12,500,0003.65
9 Lennon Holdings Limited11,890,7653.47
10 HSBC Nominees A/C NZ Superannuation Fund Nominees Limited –
NZCSD <Supr40>
10,111,9452.95
11 New Zealand Depository Nominee Limited <A/C 1 Cash Account>9,476,1812.77
12 HSBC Custody Nominees (Australia) Limited9,088,2652.65
13 JBWere (NZ) Nominees Limited <NZ Resident A/C>8,566,2372.50
14 HSBC Nominees (New Zealand) Limited A/C State Street – NZCSD
<Hkbn45>
7,672,7682.24
15 Tea Custodians Limited Client Property Trust Account – NZCSD
<Teac40>
6,873,6492.01
16 Forsyth Barr Custodians Limited <Account 1 E>5,363,4961.57
17 JP Morgan Nominees Australia Limited4,381,9581.28
18 JPMorgan Chase Bank Na NZ Branch-Segregated Clients Acct –
NZCSD <Cham24>
4,064,5181.19
19 Queen Street Nominees Ltd No.4 – NZCSD3,319,2580.97
20 Pt (Booster Investments) Nominees Limited3,277,2240.96
Securities held by directors
Until Tower’s shareholders adopted a revised constitution at the annual shareholder
meeting held in February 2024, directors were required to hold shares in the Company.
At 30 September 2025, directors, or entities related to them held relevant interests (as
defined in the Financial Markets Conduct Act 2013) in Tower Limited shares as follows:
Ordinary shares
DIRECTORBENEFICIAL
Mike Cutter31,253
Wongaling Pty Limited (Geraldine McBride)4,929
Marcus Nagel50
Michael Stiassny562,407
Director trading in Tower securities
In FY25, directors who owned shares in Tower had shares cancelled as part of the
capital return to shareholders. There were no other acquisitions or disposals of Tower
shares by its directors.
NUMBER OF SHARES CANCELLED
ON 20 MARCH 2025
CONSIDERATION ($NZ)
($1.1858 PER SHARE)
Mike Cutter3,4734,118.28
Wongaling Pty Limited (Geraldine McBride)548649.82
Marcus Nagel67.11
Michael Stiassny62,49074,100.64
Total voting securities
ORDINARY SHARESNUMBER OF HOLDERS
30 September 2025342,552,06322,610
Tower’s ordinary shares each carry a right to vote on any resolution on a poll at a meeting
of shareholders. Holders of ordinary shares may vote at a meeting in person, or by proxy,
representative or attorney.
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Shareholder analysis
Tower’s shares are quoted on both the NZSX and ASX. At 30 September 2025 9,718
Tower shareholders held less than A$500 of Tower shares (i.e., less than a marketable
parcel as defined in the ASX Listing Rules), amounting to a total of 2,118,013 of the Tower
shares on issue.
In comparison, a ‘minimum holding’ under the NZX Listing Rules means a holding
of shares having a value of at least NZ$1,000. At 30 September 2025 14,313 Tower
shareholders held less than NZ$1,000 of Tower Shares (being a parcel size of 572 at
$1.75 per share), amounting to a total of 4,094,569 of the Tower shares on issue.
HOLDING RANGETOTAL HOLDERSUNITS% UNITS
1 – 1,00017,3796,403,8081.87%
1,001 – 5,0003,4677,208,4692.10%
5,001 – 10,0006064,358,0571.27%
10,001 – 100,00094729,042,0758.48%
100,001 and over176295,539,65486.28%
Total22,575342,552,063100%
The address and telephone number of the office at which the register of Tower
securities is kept is set out in the directory at the back of this Annual Report.
Interests register
Tower and its subsidiaries are required to maintain an interests register in which the
particulars of certain transactions and matters involving the directors must be recorded.
The interests register for Tower Limited is available for inspection on request by
shareholders. Tower’s constitution provides that an ‘interested’ director may not vote on a
matter in which he or she is interested unless the director is required to sign a certificate
in relation to that vote pursuant to the Companies Act 1993, or the matter relates to a
grant of an indemnity pursuant to section 162 of the Companies Act 1993.
During the year to 30 September 2025 pursuant to section 140 of the Companies Act
1993 Tower’s directors disclosed new interests and cessations of interest as noted in the
table below.
Marcus Nagel
New Interests
MyLife Lebensversicherungs AG, Göttingen, GermanyNon-Executive Board Member
LegalHero, Berlin, GermanyNon-Executive Board Member
Summitas Beteiligungs GmbH, Munich, GermanyChairman
Yarowa AG, Zug, SwitzerlandSenior Advisor to the Board
Naomi Ballantyne
TAP Group LimitedDirector
DLI Asia Pacific LimitedDirector
KNK Group LimitedDirector
Mike Cutter
New Interests
Revolut Payments Australia LimitedDirector
Chair of Risk Committee
Member of Remuneration & Nomination Committee
Member of Audit Committee
Revolut Australia NOHC Pty LimitedDirector
Chair of Risk Committee
Member of Remuneration & Nomination Committee
Member of Audit Committee
Fairway GroupChair
Michael Stiassny
New Interests
Skyline Healthcare Group LimitedDirector
Being AI LimitedChairman
Momentum Life LimitedDirector
Ceased Interests
Morgan HoldCo LimitedDirector
New Zealand Automotive Investments LimitedDirector
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Specific disclosures of interest
Directors also disclosed the monetary value of dividends received during the year.
Tower Limited Final Dividend – declared 28 November 2024
NATURE OF INTERESTMONETARY VALUE* NZD
Michael StiassnyShareholder of 624,897 shares in Tower Limited $40,618.31
Graham StuartShareholder of 202,500 shares in Tower Limited $13,162.50
Mike CutterShareholder of 34,726 shares in Tower Limited $2,257.19
Wongaling Pty Limited
(Geraldine McBride)
Shareholder of 5,477 shares in Tower Limited $356.01
Marcus Nagel**Shareholder of 56 shares in Tower Limited $3.64
* Based on a Dividend of NZ$0.065 per share (declared on 28 November 2024)
** Mr Nagel was nominated by Bain Capital Credit LP (Bain Capital) to represent Bain Capital’s stake in Tower and his appointment
was supported by the Tower Board. Bain Capital held a beneficial interest in 75,896,447 ordinary shares in Tower Limited, and will
receive an interim dividend with a monetary value of ~NZD 4,933,269.
Tower Limited Interim Dividend – declared 20 May 2025
NATURE OF INTERESTMONETARY VALUE* NZD
Michael StiassnyShareholder of 562,407 shares in Tower Limited$44,992.56
Marcus NagelShareholder of 50 shares in Tower Limited $4.71
Mike CutterShareholder of 31,253 shares in Tower Limited$2,941.46
Wongaling Pty Limited
(Geraldine McBride)
Shareholder of 4,929 shares in Tower Limited $394.32
* Based on a Dividend of NZ$0.080 per share (declared on 20 May 2025)
Subsidiary company directors’ interests
Directors of Tower’s subsidiary companies made the following new entries into the
interests register during FY25.
Andrew Hambleton
College Woods LimitedDirector
Atawhai Apartments LimitedDirector
G & A Investments LimitedDirector
FPD Investments LimitedDirector
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Tower subsidiary company directors
Directors of Tower’s subsidiary companies during the year to 30 September 2025 were:
TOWER SUBSIDIARY COMPANY DIRECTORS
Tower Services Limited Blair Turnbull (until 12 February 2025)
Paul Johnston
Angus Shelton
The National Insurance Company of New Zealand LimitedBlair Turnbull (until 12 February 2025)
Paul Johnston
Angus Shelton
Tower Group Services (Fiji) Pte Ltd
Previously known as National Insurance
Company (Holdings) Pte Limited
Andrew Hambleton (until 26 September 2025)
Jajeena Bhan
Shannon Dooley
Marina Elliott
Joanne Rasmussen
Steve Wilson
Southern Pacific Insurance Company (Fiji) LimitedBlair Turnbull (until 12 February 2025)
Isikeli Tikoduadua
Barry Whiteside
Paul Johnston
Ronald Mudaliar
Tower Insurance (Fiji) LimitedBlair Turnbull (until 12 February 2025)
Isikeli Tikoduadua
Paul Johnston
Barry Whiteside
Ronald Mudaliar
Michael Yee Joy
Angus Shelton (from 13 February 2025)
TOWER SUBSIDIARY COMPANY DIRECTORS
Tower Insurance (Cook Islands) LimitedBlair Turnbull (until 12 February 2025)
Paul Johnston
Ronald Mudaliar
Angus Shelton (from 13 February 2025)
National Pacific Insurance LimitedBlair Turnbull (until 12 February 2025)
Paul Johnston
Ronald Mudaliar
Angus Shelton (from 13 February 2025)
National Pacific Insurance (Tonga) LimitedBlair Turnbull (until 12 February 2025)
Paul Johnston
Ronald Mudaliar
Angus Shelton (from 13 February 2025)
National Pacific Insurance (American Samoa)Blair Turnbull (until 12 February 2025)
Ronald Mudaliar
Paul Johnston
Angus Shelton (from 13 February 2025)
Indemnity and insurance
In accordance with section 162 of the Companies Act 1993 and Tower’s constitution,
Tower has provided insurance for and indemnities to, directors and employees of Tower
for losses from actions undertaken in the course of their duties. The insurance includes
indemnity costs and expenses incurred to defend an action that falls outside the scope
of the indemnity. Particulars have been entered in the Interests Register pursuant to
section 162 of the Companies Act 1993.
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Other matters
Donations
During the financial year ended 30 September 2025, Tower Limited made a donation
of $10,000 to the University of Waikato Foundation Trust, and a donation of $304.35 to
Fair Food Trust.
Credit rating
In April 2025, global rating organisation A.M. Best Company re-affirmed Tower Limited’s
financial strength rating of A- (Excellent).
Waivers
Tower Limited did not rely on, or make any applications for, waivers from the NZX Listing
Rules or the ASX Listing Rules in the financial year ending on 30 September 2025.
Trading Halts
In March 2025, the company implemented a capital return by way of a scheme
of arrangement approved by the High Court. The arrangement returned $45m to
shareholders, with 1 ordinary share for every 10 ordinary shares held on the record date
being cancelled. To facilitate the share cancellation, a trading halt on both NZX and
ASX was required during the Ex-Date (18 March 2025) and Record Date (19 March 2025)
NZX applied a trading halt as an operational matter to facilitate the corporate action,
while ASX agreed to grant a trading halt at Tower’s request.
On 31 March 2025, Tower requested a trading halt to be applied, having been advised
that Bain Capital was proposing to sell its shareholding in Tower. Tower applied for
a trading halt to ensure an orderly and informed market during Bain’s sale process.
The application for trading halt was granted, commencing prior to opening of the market
on 31 March 2025, and continuing until market open on 1 April 2025.
Limits on acquisition of securities
Tower undertook to the ASX, at the time it granted Tower a full listing in July 2002 to
include the following information in its annual report. Except for the limitations detailed
below, Tower securities are freely transferable under New Zealand law.
The New Zealand Takeovers’ Code prohibits a person (including associates) from
increasing their shareholding to more than 20% of the voting rights in Tower except
in accordance with the Takeovers Code. The exceptions include a full or partial takeover
offer in accordance with the Takeovers Code, a scheme of arrangement (under the
Companies Act 1993), an acquisition or an allotment approved by an ordinary resolution
of shareholders, a creeping acquisition (in defined circumstances) and a compulsory
acquisition once a shareholder owns or controls 90% or more of the voting rights in
Tower.
The New Zealand Overseas Investment Act 2005 and related regulations determine
certain investments in New Zealand by overseas persons. Generally, the Overseas
Investment Office’s consent is required if an ‘overseas person’ acquires Tower shares
or an interest in Tower shares of 25% or more of the shares on issue or, if the overseas
person already holds 25% or more, the acquisition increases that holding.
The New Zealand Commerce Act 1986 is likely to prevent a person from acquiring
Tower shares if the acquisition would, or would be likely to, substantially lessen
competition in a market.
Tower is incorporated in New Zealand and therefore not subject to Chapters 6, 6A,
6B or 6C of the Corporations Act 2001 (Australia) dealing with the acquisition of shares
(such as substantial holdings and takeovers).
The Annual Report is signed on behalf of the Board by:
Michael Stiassny Mike Cutter
Chair Director
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Global Reporting
Initiative content
index
102ANNUAL REPORT 2025 ContentsCorporate governanceConsolidated financial statementsSustainabilityOur strategy2025 in reviewGRI content index

Tower has reported the information cited
in this GRI content index for the period
1 October 2024 to 30 September 2025,
in accordance with the GRI Standards.
GRI 1: Foundation 2021GRI 1 used:
Statement of use:
Global Reporting
Initiative (GRI)
content index
DISCLOSURELOCATION/INFORMATION
GRI 2: General Disclosures 2021
2-1 Organisational details
Pg 108 Tower Directory.
2-2 Entities included in the
organisation’s sustainability
reporting
See pg 108 Tower Directory, as well as our FY25 Pacific operations in
Fiji, Tonga, Samoa, American Samoa, the Cook Islands.
2-3 Reporting period,
frequency and contact
point
Tower reports sustainability information annually. This report covers
the period 1 October 2024 – 30 September 2025. This report was
published on 27 November, 2025. Questions about this report can be
directed to Emily.Davies@tower.co.nz
2-4 Restatements of
information
This is Tower’s fourth report in accordance with the GRI Standard.
2-5 External assurance
External assurance approach is covered in our Corporate Governance
Statement which can be found in this link: https://www.tower.co.nz/
investor-centre/corporate-governance/policies/
Our External Audit Independence Policy can also be found in this link:
https://www.tower.co.nz/investor-centre/corporate-governance/
policies/
Scope 1 & 2 greenhouse gas emissions are subject to assurance as
required by the Climate-related Disclosures regime and detailed
within our FY25 Climate Statement.
We have not sought external assurance on our sustainability
information.
2-6 Activities, value chain
and other business
relationships
https://www.tower.co.nz/about-us/
2-7 EmployeesTower has 966 employees across New Zealand and the Pacific,
63% of whom are women, 36% are men, 1% are gender diverse,
non- binary, or transgender. This is based on the 98% of staff who
chose to disclose their gender. Out of the 63% population of women,
94% are permanent full-time employees, 3% are permanent part-
time employees, and 3% are fixed term employees. Out of the 36%
population of men, 95% are permanent full-time employees, 3% are
permanent part-time employees and 2% are fixed term employees.
Out of the 1% gender diverse, non- binary, or transgender employees,
86% are permanent full-time employees and 14% are permanent
part-time employees.
DISCLOSURELOCATION/INFORMATION
2-8Workers who are not
employees
As at 30 September 2025, Tower had 48 contingent workers who are
predominantly independent contractors on either direct or agency
contracts engaged in technology or project-based work. There were
no significant fluctuations in this number during the reporting period.
2-9Governance structure
and composition
Our Governance structure and composition, along with a list of
committees of the highest governance body, and our Corporate
Governance Statement can be found in this link: https://www.tower.
co.nz/investor-centre/corporate-governance/policies/
2-10Nomination and selection
of the highest governance
body
Tower’s Constitution and Board Renewal Policy can be found in
this link https://www.tower.co.nz/investor-centre/corporate-
governance/policies/
2-11Chair of the highest
governance body
Pg 38.
2-12Role of the highest
governance body
in overseeing the
management of impacts
Pg 38-39.
2-13Delegation of responsibility
for managing impacts
The board delegates day-to-day management of the company to
the CEO and does not currently provide for any additional specific
delegation of ESG impacts.
2-14Role of the highest
governance body in
sustainability reporting
Pg 38-39.
2-15Conflicts of interest
Our Code of Conduct Policy and Conflict of Interest Policy can
be found in this link: https://www.tower.co.nz/investor-centre/
corporate-governance/policies/
2-16Communication of critical
concerns
See Corporate Governance Statement in this link: https://www.tower.
co.nz/investor-centre/corporate-governance/policies/
Communication of critical concerns regarding ESG topics is
unavailable.
See Corporate Disclosure Policy in this link: https://www.tower.co.nz/
investor-centre/corporate-governance/policies/
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DISCLOSURELOCATION/INFORMATION
2-17Collective knowledge of
the highest governance
body
See Corporate Governance Statement in this link: https://www.tower.
co.nz/investor-centre/corporate-governance/policies/
Actions to advance the collective knowledge, skills, and experience
of the highest governance body on sustainable development will
continue to be undertaken in FY26.
Tower’s 2025 Climate Statement can be found in the investor
section of our website, here: https://www.tower.co.nz/investor-
centre/reports/
2-18Evaluation of the
performance of the highest
governance body
See Corporate Governance Statement in this link: https://www.tower.
co.nz/investor-centre/corporate-governance/policies/
2-19Remuneration policies
See Corporate Governance Statement in this link: https://www.tower.
co.nz/investor-centre/corporate-governance/policies/
2-20Process to determine
remuneration
See People, Remuneration and Appointments Committee Charter,
and Director and Executive Remuneration Policy in this link: https://
www.tower.co.nz/investor-centre/corporate-governance/policies/
Pg 93.
2-21 Annual total
compensation ratio
Not disclosed: information on annual compensation ratio is not
reported externally.
2-22 Statement on sustainable
development strategy
Pg 33-34.
2-23 Policy commitments
Relevant policies currently in place can be found here: https://www.
tower.co.nz/investor-centre/corporate-governance/policies/
Tower also has an Internal Procurement Policy and a Procurement
Engagement Framework, a Supplier Relationship Management
Framework and a Supplier Code of Conduct. In FY25 Tower became
the first New Zealand insurer to obtain The Chartered Institute of
Procurement & Supply (CIPS) Ethics Mark.
2-24Embedding policy
commitments
See Corporate Governance Statement in this link: https://www.tower.
co.nz/investor-centre/corporate-governance/policies/
2-25Processes to remediate
negative impacts
https://www.tower.co.nz/contact-us/complaints-and-compliments/
Our material impacts table can be found here: https://www.tower.
co.nz/about-us/sustainability/
Our material impacts process is covered under the relevant topics.
DISCLOSURELOCATION/INFORMATION
2-26 Mechanisms for seeking
advice and raising
concerns
See Code of Conduct Policy in this link: https://www.tower.co.nz/
investor-centre/corporate-governance/policies/
Through our internal Whistleblower Policy, staff are encouraged
to raise concerns with their manager, or a senior leader. Tower’s
whistle blower service provides a confidential avenue to report any
serious concerns.
2-27Compliance with laws
and regulations
For an update on Tower’s progress in the year, regarding remediating
customers who did not receive the discounts or benefits they were
entitled to, or experienced other policy errors, please see page 15.
In this reporting period, Tower has not been fined, nor has it incurred
any non-monetary sanctions for breaches or non-compliance with
laws and regulations during the reporting period, or in any previous
reporting period.
2-28Membership associationsTower is a member of Insurance Council of New Zealand and is active
in ICNZ’s Climate Change committee. Tower is also a member of the
Sustainable Business Council, a signatory of the Climate Leaders
Coalition and associate partner of the Centre for Sustainable Finance:
Toitū Tahua.
2-29Approach to stakeholder
engagement
Tower takes a collaborative approach to stakeholder engagement.
Our company purpose and values consider stakeholder interests, see
page 9. Similarly, our Southern Star drives outcomes for customers
and our people, see ‘our vision’ page 9. Our ESG strategy was
developed in consultation with a range of stakeholders and considers
our impacts on various stakeholder groups.
2-30Collective bargaining
agreements
None.
Global Reporting Initiative (GRI) content index
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DISCLOSURELOCATION/INFORMATION
GRI 3: Material Topics 2021
3-1Process to determine
material topics
Pg 33.
3-2List of material topics
Pg 33.
3-3Management of material
topics
See our material impacts table via our website for all:
https://www.tower.co.nz/about-us/sustainability/
GRI 305: Emissions 2016
305-1 Direct (Scope 1) GHG
emissions
Pg 35.
Scope 1 emissions includes refrigerant top-ups and vehicle fleet fuel
in New Zealand and the Pacific.
Tower applies the operational control approach and has chosen
FY20 as the baseline year as this was the first year Tower measured
its emissions.
New Zealand emissions factors used were sourced from Ministry
for the Environment’s (MfE) 2025 Measuring Emissions: A Guide for
Organisations.
Quantities of each greenhouse gas are converted to tonnes CO
2
e
using the global warming potentials from the Intergovernmental
Panel on Climate Change (IPCC) Fourth-Sixth Assessment Report
(AR4-6). The time horizon is 100 years. For further detailed
information on the methodology, assumption, and uncertainties refer
to our FY25 Climate Statement.
Our full greenhouse gas emissions inventory is provided in our 2025
Climate Statement, which is in the investor section of our website,
here: https://www.tower.co.nz/investor-centre/reports/
The Statement contains our Scope 1, Scope 2 and operational Scope
3 emissions data, as well as information about our work to identify
and assess our climate-related risks, opportunities and business
impacts.
DISCLOSURELOCATION/INFORMATION
305-2Energy indirect (Scope 2)
GHG emissions
Pg 35.
Scope 2 emissions include electricity consumption from all business
premises. See 305-1 for relevant disclosures on baseline year,
emissions factors and methodology and assumptions.
Emission factors for New Zealand were sourced from Ministry
for the Environment’s (MfE) 2025 Measuring Emissions: A Guide
for Organisations. For the Pacific they were sourced from the IEA
2025 emission factors and the Oceania (UN) factor was used for all
countries. Emissions from purchased heating and cooling at the Suva
Retail Branch and in Samoa have been assessed as immaterial and
excluded from the FY25 inventory.
Our full greenhouse gas emissions report is provided in our 2025
Climate Statement, which is in the investor section of our website,
here: https://www.tower.co.nz/investor-centre/reports/
305-3Other indirect (Scope 3)
GHG emissions
Scope 3 emissions included in our FY25 disclosure are transmission
and distribution losses for electricity, and well-to-tank emissions
for electricity and vehicle fuel, air travel, hotel stays, rental cars, taxi
travel, employee commutes, working from home, paper purchased
(NZ only), waste to landfill (NZ only), wastewater (NZ only) and water
supply (NZ only).
The following Scope 3 emissions sources have been excluded from
our reporting; employee vehicle claims NZ; waste, wastewater,
and water supply from Pacific operations; value chain emissions
from purchased goods and services, capital goods, upstream
transportation and distribution, insurance-associated emissions, and
our investment portfolio.
Emission factors have primarily been sourced from Ministry for
the Environment’s (MfE) 2025 Measuring Emissions: A Guide for
Organisations, and Department for Environment Food & Rural Affairs
(DEFRA) 2025 ‘Greenhouse gas reporting: conversion factors’ (UK).
For Information on the methodology, assumptions, and uncertainties
refer to our 2025 Climate Statement, which is in the investor section of
our website, here: https://www.tower.co.nz/investor-centre/reports/
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DISCLOSURELOCATION/INFORMATION
305-5 Reduction of GHG
emissions
Pg 35.
Our full greenhouse gas emissions inventory is provided in our 2025
Climate Statement, which is in the investor section of our website,
here: https://www.tower.co.nz/investor-centre/reports/
The Statement contains our Scope 1, Scope 2 and a subset of
operational Scope 3 emissions data, as well as information about our
work to identify and assess our climate-related risks, opportunities
and business impacts.
GRI 401: Employment 2016
401-1 New employee hires and
employee turnover
In FY25 Tower hired 201 new employees to address growth and
attrition. These comprised permanent and fixed term new hires.
New hires by Gender: Female: 113, Male: 77, Gender Diverse: 1, Not
disclosed: 10. New hires by region: New Zealand: 125, Pacific: 76.
Number and rate of new employees by age is currently unavailable.
Over the period employee numbers increased by 82 full-time
equivalent staff, from 872 in FY24 to 954 in FY25, with our total head
count of 966 staff, due to continuous development of our frontline
teams. Employee attrition was 15.1% in FY25.
401-2 Benefits provided to full-
time employees that are
not provided to temporary
or part-time employees
Benefits are offered to both full-time and part-time permanent
employees. Tower benefits include Group Insurances, parental leave,
ability to buy additional leave, birthday leave, domestic violence
leave, gender affirmation leave, volunteer leave, discretionary leave,
free flu vaccinations, Tower insurance discounts, health insurance
discounts, partner discounts, eyesight testing, and study assistance.
401-3 Parental leaveFrom July 2025, all Tower New Zealand employees have enjoyed 26
weeks paid leave for primary carer leave. In the Pacific, employees
enjoy 16 weeks paid leave for primary carers Since (or maternity leave
as it’s referred to in the Pacific). Across all countries, Tower offers four
weeks paid partner’s leave for partners of primary carers.
We also offer all employees compassionate leave and flexible
working on return. Additionally, any annual leave taken on the
employee’s return from parental leave will be paid at their usual rate.
This is more generous than the current Holidays Act legislation and
means take home pay is not affected when the employee takes paid
annual leave.
In FY25: 62 employees took parental leave (54 female and 8 Male)
versus 35 in FY24. 52 employees returned to work from parental
leave during FY25 (44 female and 8 Male); of these 46 are still
employed (39 female and 7 Male).
DISCLOSURELOCATION/INFORMATION
GRI 403: Occupational Health and Safety 2018
403-1 Occupational health
and safety management
system
See Health and Safety Policy in this link:
https://www.tower.co.nz/investor-centre/corporate-governance/
policies/
403-2 Hazard identification, risk
assessment, and incident
investigation
Tower’s H&S Management System has an incident register where
incidents are reported. When reporting, it is mandatory that all
incidents are assessed and each incident must have corrective
actions identified and implemented before being closed. Once
reported, incidents are then reviewed by the Health and Safety
Officer, who investigates all incidents.
Workers are encouraged to report hazards and hazardous situations
through the H&S system. Tower’s H&S Policy is in line with New
Zealand’s Health and Safety at Work Act 2015. All workers have
access to the Health and Safety Policy on Tower’s intranet.
403-3 Occupational health
services
Tower workers have access to Employee Assistance Programme
EAP counselling sessions provided by external trained counsellors.
These sessions are arranged by workers independently. If employees
choose to use counselling or health and wellbeing services via EAP,
these services are strictly confidential between the worker and
healthcare provider.
403-4 Worker participation,
consultation, and
communication on
occupational health and
safety
As per the NZ Health and Safety at Work Act 2015, Tower has a
team of Health and Safety Committee Members from across the
NZ business. In the Pacific we have also have Health and Safety
committee members in each country. These Committee Members
engage and consult with workers regularly and report any concerns
to the Health and Safety Officer and/or at the regular Health and
Safety meeting. Tower’s H&S Management system is continuously
reviewed by the Health and Safety Officer to ensure risks are kept up
to date.
Tower has two Health and Safety committees that meet monthly
– one New Zealand committee and one Pacific committee, with
representatives from our Fiji, Tonga, Samoa, American Samoa, Cook
Islands teams. Committee members are allocated specific time
each month to undertake their responsibilities. Their responsibilities
include but are not limited to; office inspections, disseminating H&S
updates from the meetings to relative teams, ensuring H&S is on
the agenda at team meetings and promotion of health, safety and
wellbeing education and activities.
Global Reporting Initiative (GRI) content index
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DISCLOSURELOCATION/INFORMATION
403-5 Worker training on
occupational health and
safety
Tower offers training to workers who volunteer to be First Aiders, Fire
Wardens, Mental Health First Aiders and Domestic Violence First
Responders. Building Assessors are asbestos awareness trained.
403-6 Promotion of worker healthTower works with ACC to support its employees that have non-work-
related accidents by offering workstation assessments to ensure
they have the necessary equipment to undertake their job. Where
a return-to-work plan is required, Tower will work alongside ACC
to facilitate a satisfactory solution for the employee. Health checks
in the Pacific are done through a local General Practitioner, and the
results are confidential and not shared with Tower.
Tower offers employees access to several health promotion services
including; EAP (online and in person), discounted flu vaccinations,
access to trained Mental Health First Aiders and trained Domestic
Violence first responders (online and in-person).
Tower promotes prevention of communicable diseases in the
Pacific through education on symptoms, prevention and treatment.
Our Rainbow network supports education on AIDS awareness
and prevention.
DISCLOSURELOCATION/INFORMATION
GRI 405: Diversity and Equal Opportunity 2016
405-1 Diversity of governance
bodies and employees
Pg 91-92.
405-2 Ratio of basic salary and
remuneration of women
to men
Pg 30.
GRI 418: Customer Privacy 2016
418-1 Substantiated complaints
concerning breaches of
customer privacy and
losses of customer data.
During the reporting period, one substantiated customer privacy
breach was identified. This was assessed as a one-off incident rather
than indicative of a systemic issue, and it did not result in serious
harm. We remain committed to upholding the highest standards of
data protection and continuously enhancing our practices to prevent
future occurrences.
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Tower directory
Enquiries
For customer enquiries, call Tower on 0800 808 808
or visit www.tower.co.nz
For investor enquiries:
Telephone: +64 9 369 2000
Email: investor.relations@tower.co.nz
Website: www.tower.co.nz
Board of Directors
Michael Stiassny (Chair)
Marcus Nagel
Geraldine McBride
Mike Cutter
Naomi Ballantyne (from 21 May 2025)
Chief Executive Officer
Paul Johnston
Company Secretary
Tania Pearson
Executive leadership team (at 30 September 2025)
Paul Johnston, Chief Executive Officer
Angus Shelton, Chief Financial Officer (Interim)
Sharyn Reichstein, Chief Risk Officer
Michelle Finch, Chief Customer and Marketing Officer
Ronald Mudaliar, Chief Underwriting Officer
Steven Wilson, Chief Claims Officer
Liz Cawson, Chief Digital and Technology Officer (Acting)
Dr. Stephen Hastings, Chief Data and Analytics Officer
Emma Atherton, Head of People and Culture (Acting)
Mike Skeens, Head of Customer Contact Centre
Registered office
New Zealand
Level 5, 136 Fanshawe Street, Auckland
PO Box 90347
Auckland
Telephone: +64 9 369 2000
Facsimile: +64 9 369 2245
Australia
c/- Peter Davison
18 Korinya Road
Castle Cove
Sydney NSW 2069
Australia
Auditor
PricewaterhouseCoopers
Lawyers
MinterEllisonRuddWatts
Banker
Westpac New Zealand Limited
Company numbers
Tower Limited
(Incorporated in New Zealand)
NZ Incorporation 143050
NZBN 9429040323299
ARBN 645 941 028
Stock Exchanges
The Company’s ordinary shares are listed on the NZSX and the ASX. On
Wednesday 18 May 2016, Tower’s ASX admission category changed to
“ASX Foreign Exempt Listing”.
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Registry details
Shareholders should make enquiries in respect of their shareholdings,
notify changes of details or address administrative queries to Tower’s
Share Registrar.
Direct payment to a bank account is the only way in which dividend
payments are made. Shareholders are strongly encouraged to ensure
that the Registrar has up to date bank account details.
Tower also encourages shareholders to receive communications
electronically, to minimise cost, ensure quicker communication, and to
reduce environmental impacts.
New Zealand
Computershare Investor Services Limited
Level 2, 159 Hurstmere Road
Takapuna, Auckland
Private Bag 92119
Auckland 1142
Freephone within New Zealand: 0800 222 065
Telephone New Zealand: +64 9 488 8777
Australia
Computershare Investor Services Pty Limited
Yarra Falls, 452 Johnston Street
Abbotsford VIC 3067
GPO Box 3329
Melbourne Vic 3000
Freephone within Australia: 1800 501 366
Telephone Australia: +61 3 9415 4083
Email: enquiry@computershare.co.nz
Website: www.computershare.com/nz
insightcreative.co.nz TOW009
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tower.co.nz

---

2025 Full Year
Results
1 October 2024 to 30
September 2025
2 7 N o ve m b e r 2 02 5

AGENDA
Chairman’s update
Michael Stiassny,
Chairman
Business update
Paul Johnston,
Chief Executive Officer
Financial performance
Angus Shelton,
Interim Chief Financial
Officer
Looking forward
Paul Johnston,
Chief Executive Officer

Competitive advantages set Tower apart
•Address level risk-based pricing
•Disciplined execution of Tower’s focused strategy
•Strategic partnerships and brand momentum underpin future growth
•Investing in innovation, technology and AI
Chairman’s update
Tower delivers record FY25 performance and positions for future growth
Strong, resilient business delivering shareholder value
•Capital return of $45m delivered
•Final dividend declared 16.5 cents per share; full year dividends of 24.5 cents per share – fully
imputed
•Shareholder returns supported by sustainable profit growth
•Strong capital and solvency

TOWER FY25 RESULTS
Business
update
Paul Johnston,
Chief Executive
Officer

Overview
Record FY25 result
•Relatively benign claims environment – claims ratio historically low
•Strong policy growth whilst soft rating cycle lowers GWP
Strategic horizon 1: Focus on foundations
•Foundations strengthened with key initiatives delivered in FY25
•Improvements in digitisation, efficiencies, and underwriting
•Profitability improved through the cycle
Entering strategic horizon 2
•Primed for growth, innovation, and leading customer experience
•5-10% GWP CAGR expected across FY26-FY28

Entering the next phase of growth
Foundations laid to deliver Horizons 2 and 3
E x p a n d e d G r o w t h a n d
L e a d e r s h i p
T r a n s f o r m a n d
I n n o v a t e
R e s i l i e n c e a n d
E f f i c i e n c i e s
We are
entering
Horizon 2 of
our strategic
plan
H O R I Z O N 1
2 0 2 4-2 0 2 5
•Building foundational strength
•Well-managed risk exposure
•Operational efficiencies
•Technology investments
•Improving customer experience
•Effective and distinctive culture
H O R I Z O N 2
2 0 2 6 - 2 0 2 7
•Sustainable growth
•Leading customer experience
•Investment in customer data,
digitisation, and innovation
•Embedding AI
•Consistently improving earnings
H O R I Z O N 3
2 0 2 8 - 2 0 3 0
•Broadening growth through new
channels and innovative
products
•Market challenger  market
leader
•Leading brand
•Highly automated/digital
•Personalised customer
experiences

Our performance
Strong operational and business performance
24.5 cents
41%
vs 48% in FY24
BAU claims ratio
(Business as usual)
MER
(Management expense ratio)
31.4%
vs 31.4% in FY24
Large event costs
$7.2m
vs -$2.3m in FY24
Reported profit
$83.7m
vs $74.3m in FY24
Note 1: Excluding divested portfolios which include the Solomon Islands business and Vanuatu subsidiary, and the New Zealand commercial rural portfolio
Note 2: Large event costs were negative in FY24 due to the absence of large events in the financial year and a favourable revision to prior year large events costs
Note 3: Definition of underlying profit and a reconciliation to reported profit is included in the appendices
GWP growth
(Gross written premium)
2% | $600m
vs $595m in FY24
$107.2m
vs $83.5m in FY24
Underlying profit
318,000
vs 305,000 at FY24
Customers
2
3
Dividend per share
Total FY25 declared dividends
vs 9.5 cents, $45m capital
return announced in FY24
1

•Large event claims costs of $7.2m well
below historical 10-year average of $15m
•Competitive environment reduced motor
premiums
•Inflation now at historical averages
•Motor theft frequency back to pre-Covid
levels
•OCR decrease reduces investment income
yields
External factors influencing FY25 result
TOWER TOTAL CLAIMS RATIO
•Effective average premium highlights impact of change in technical premium, excesses, and
sum insured on GWP
TOWER EFFECTIVE AVERAGE PREMIUM
(ANNUAL CHANGE)

Sustained profitability improvement
•Through-the-cycle (FY21 – FY25) profitability has
increased through business improvements:
•Targeted growth enabling scale
•Risk selection and risk-based pricing improvements
(Flood, Sea Surge, Landslide)
•Expense efficiencies from technology & Suva Hub
•Foundational risk and resilience improvement
•Assisted by benign BAU claims experience in last two
years
•FY26 guidance assumes soft rating cycle continues and
normalisation of BAU claims ratio
UNDERLYING NPAT
EXCLUDING LARGE EVENTS¹
Note 1: The net cost to Tower of large event costs after tax for each financial year is as follows: FY21 $10m, FY22 $13.3m, FY23 $40.1m, FY24 -$1.6m, FY25 $5.2m

Policy growth in a competitive market
•+13k new customers to 318k
•6% growth in NZ policies (house 11%, motor 2%,
contents 7%)
•Strategic focus towards house is providing
results
•Improved risk quality - Tower's expected
average annual loss from flood reduced 21% on
a per policy basis and 16% overall
•New brand campaign “The Misses” launched
winning Kantar’s June 2025 Ad impact award
NZ HOUSE MOVEMENT IN RISK COUNT (000’s)
NZ MOTOR MOVEMENT IN RISK COUNT (000’s)

Investing for future value
•Launched Amazon Connect - AI enabled
contact centre platform, streamlining
processes and reducing frontline effort
•Integrated motor assessing system - reducing
assessment time, manual effort on claims
handling, and repair costs
•Digitisation build nearing completion – digital
service capability at 79%
•Risk based pricing enhancements - Landslide
and sea surge delivering improved risk quality
•AI enablement – strengthened foundations to
deliver AI efficiencies across FY26-FY27

Elevating customer experience
•Net promoter score improved to +44 (FY24: +38)
•Sales and service abandonment rate reduced
by 1% to 7%
•Digital efficiency: New Zealand digital tasks¹ –
63% sales, 51% service; 70% claims lodgement
•59% of NZ customers registered for MyTower
(FY24: 53%)
•Suva Hub answering 83% of NZ sales and
service calls (FY24: 55%)
•CRM Contact Centre Awards (NZ): Insurance
sector award winner 2025
Note 1: Sales tasks are all New Zealand new business policies sold online (previously reported as Tower Direct only). Service tasks are either digital (actioned by the customer through the My Tower portal online) or assisted
(through Tower’s call centre). In prior years, multiple tasks completed on the same call were reported as one assisted transaction - these are now reported individually. Digital claims tasks refer to claim lodgement only.
.

TOWER FY25 RESULTS
Financial
performance
Angus Shelton,
Interim Chief
Financial Officer

Group underlying performance
•Gross written premium growth of 2%
1
•BAU claims ratio reduced to 41.3% due to
targeted rate increases, risk selection and
relatively benign weather
•Large event costs of $7.2m
•Management expense ratio of 31.4% in line with
FY24
•Underlying NPAT
2
including large events of
$107.2m
•Reported profit of $83.7m impacted by
Canterbury earthquakes strengthening, costs of
customer remediations and software impairment
Note 1: Adjusted to exclude sold portfolios: Solomon Islands, Vanuatu, and NZ commercial rural
Note 2: Definition of underlying profit and a reconciliation to reported profit is included in the appendices
Reported profit/(loss) after tax
74.39.483.7
Underlying profit before tax
119.430.6150.0
Non-underlying items
(9.3)(14.3)(23.6)
107.283.523.7
(42.8)(35.8)(6.9)
Net commission expense
(8.6)(0.6)(9.2)
21.6(2.4)19.2
(3.8)
Insurance service expense
(383.1)(379.4)
Net insurance revenue
480.436.6517.0
Management expenses
(142.1)(10.9)(153.0)
Large event claims expense
2.3(9.5)(7.2)
BAU claims expense
(230.9)17.3(213.6)
Change
Gross written premium
595.34.5599.8
$ millionFY25FY24
Income tax expense
Underlying profit after tax

Insurance service result
101.032.8133.9
Net investment income

Net insurance finance expense
(2.6)1.0(1.6)
Other income and expenses
(0.6)(0.9)(1.5)
Insurance revenue
566.230.9597.1
Reinsurance
(85.8)5.7(80.1)
Key ratios (% of Net insurance revenue)FY25FY24Change
Claims ratio excluding large events
41.3%48.1%(6.8)%
Large event costs ratio
1.4%(0.5)%1.9%
Management expense ratio
31.4%31.4%0.0%
Combined ratio
C

C
74.1%79.0%(4.9)%

•Underlying NPAT
1
of $107.2m vs $83.5m in
FY24
•Business growth reflects higher net insurance
revenue less theassociated growth in claims
and management expenses
•BAU claims ratio improved from rating and
underwriting actions, relatively benign weather,
and lower motor frequency
•Large event costs in FY25 of $7.2m before tax
versus a release of $2.3m before tax in FY24
•Strategic investments to deliver future growth
and efficiency
Movement in underlying NPAT
Note 1: A definition of underlying profit and a reconciliation to reported profit is included in the appendix

Note 1: Adjusted to exclude sold portfolios: Solomon Islands, Vanuatu, and NZ commercial rural
•2%
1
premium growthreflects softer rating
environment
•NZ House GWP growth 10%; 11% policy growth
•NZ Motor GWP growth -5%; 2% policy growth
offset by rate reductions to balance margin and
growth
•Partnerships GWP growth of 12%
•NZ retention rate of 78% (FY24: 77%)
GROSS WRITTEN PREMIUM ($m)
Rating pressure impacts GWP growth

Note 1: Severity is defined as the cost of claims (excluding large events, large house, windscreen) divided by the count of claims
Note 2: Frequency is defined as the number of claims (same exclusions as above) divided by risks in force
The historical severity and frequency numbers are current estimates as at 30 September 2025 reflecting development of prior
year claims in their respective incurred periods
•BAU claims ratio of 41.3% (FY24: 48.1%) due to
high premium earning through as well as
severity and frequency flattening off
•Prior period high theft motor off-risking has
lowered frequency and severity of motor
claims
•Reduction of external assessing usage has
lowered motor handling costs
•House frequency impacted by increase in small
weather claims
•Large event costs of $7.2m
Lower frequency and severity of claims
NZ HOUSE SEVERITY & FREQUENCY
NZ MOTOR SEVERITY
1
& FREQUENCY
2

•Management expense ratio (MER) remained at
31.4%
•Scale efficiencies from business growth
contributes 2.2% reduction in MER
•Strategic and foundational investments are
being made to improve growth, efficiency, and
resilience
•Timing differences related torecognition of
deferred acquisition costs increases MER by
0.7%
•Staff and other costs increasing from inflation
and to drive growth
Stable management expense ratio

•Net investment income $19.2m; $2.4m lower
than FY24
•Running yield on the core investment portfolio
is 3.1% as at 30 September 2025
•Conservative investment strategy with low
duration (target of 6 months)
•Yields expected to remain suppressed in line
with OCR
Conservative investment strategy
C O R E I N V E S T M E N T P O R T F O L I O
1

Y I E L D
I N V E S T M E N T A S S E T P R O F I L E
Note 1: Core investment portfolio refers to Tower’s fixed income investment portfolio in NZ. It excludes cash held for operational purposes in NZ and cash and short-term deposits held by Tower’s Pacific subsidiaries. Subsidiaries of
banking groups with a credit rating have been grouped under their parent bank’s credit rating, even if unrated themselves

Canterbury earthquakes (CEQ)
•FY25 charge of $7.9m after tax, treated as a
non-underlying item
•13 properties open as at 30 September 2025
•22 new over cap or reopened claims from NHC
in the year (+7 vs FY24), with an average cost
higher than historical levels, drove an increase
in valuation assumption for future claims
Customer remediation
•FY25 charge of $10.9m after tax, treated as a
non-underlying item
•Includes further provision for payments to
customers, plus remediation programme costs
O P E N C E Q C L A I M S
CEQ and customer remediation

Reinsurance programme
•Successfully renewed FY26 programme with a
lower cost to GWP ratio reflecting changes to risk
profile, structure, and global market ratings
•Catastrophe reinsurance of up to $915m for two
events, (FY25: $800m) and an additional prepaid
third event cover up to $85m
•Increase in retention for catastrophe event to $20m
(FY25: $18.75m) from expiring multi-year contracts
•Reinsurance programme also includes:
•Excess of loss
1
for large single property claims
•General accident and marine cover
FY26 large event allowance
•Improved risk selection reduces large event
allowance to $45m
•One large event incurred in FY26 to date at an
estimated cost to Tower of $4.5m
Note 1: Excess of loss reinsurance means Tower retains responsibility for claims up to a certain threshold, with the reinsurer covering losses above that amount.
$915m
$85m
1st Cat loss
(retention $16.9m)
2nd Cat loss
(retention $16.9m)
1st Cat event2nd Cat event3rd Cat event
3rd Cat loss
(retention $20m)
Reinsurance
coverage of
$895m
Reinsurance
coverage of
$895m
Reinsurance
coverage of
$65m
1st Cat Loss
(retention $20m)
2nd Cat Loss
(retention $20m)
3rd Cat Loss
(retention $20m)

Note 1: SR = Solvency ratio – the ratio of solvency capital to adjusted prescribed capital
Note 2: Based on Tower’s ordinary dividend policy to pay a sustainable annual dividend in the range of between 60-80% of adjusted earnings where prudent to do so
•Solvency ratio
1
of 143%
•Tower’s regulatory solvency position is
calculated under the second amendment to the
Interim Solvency Standard (ISS), effective 1
March 2025
•30 September 2024 solvency position has been
recalculated under the new ISS for comparative
purposes
•Adjusted solvency margin as at 30 September
2025 is $89m - stated net of final dividend of
16.5 cents per share
2
•A- financial strength rating reaffirmed in April
2025 by AM Best
TOWER SOLVENCY
NZ PARENT ($m)
Capital and solvency position

TOWER FY25 RESULTS
Looking
forward
Paul Johnston,
Chief Executive
Officer

•Targeting >$750m GWP in FY28 through organic growth
•Partnership agreement with Westpac NZ
•Referral of Kiwibank back book
•Investing further in Tower brand marketing
•Sea surge and landslide risk ratings improve targeting of lower
risk properties
•Multi-policy discount removal simplifies pricing offering
Strategic initiatives for growth

Customer experience and efficiency
through innovation
•Targeting 80% of sales, service, and claims lodgement
tasks to be through digital channels by FY28
•Customer data platform to enable hyper-personalised
service in future
•AI enablement roll out to streamline processes
•Claims transformation – house assessing platform
•Partnership with Amazon Connect enabling best-in-
class enhancements to new contact centre platform
•Product innovation to meet emerging customer needs

FY26 guidance and future targets
•Any unused portion of the large events allowance (after tax) at year end will increase underlying
NPAT to improve the full year result.
•Reported NPAT will be impacted by non-underlying items for remediation activity and costs
associated with regulatory change
FY25
Actual
FY26
Guidance
FY28
Target
GWP growth
$600m
(2%)
$630m - $660m
(5-10%)
>$750m
(>7.5% CAGR)
Management expense ratio31.4%31% - 32%28% - 30%
Underlying NPAT
(excluding large events)
$112m$87m - $97m
Large events$7m$45m
Combined operating ratio74%86% - 88%85% - 87%
Underlying NPAT
(assuming full utilisation of large events allowance in FY26)
$107m$55m - $65m

TOWER FY25 RESULTS
Questions?

TOWER FY25 RESULTS
Appendices

Business unit distribution
TOWER DIRECT
•No underlying growth
1
in
FY25 due to policy growth
offset by premium rate
reductions
•New risks sold +22% vs
FY24
PACIFIC
•No underlying growth
1
in
FY25 due to risk review in
Samoa
•Solomon Islands & Vanuatu
businesses sold in FY24;
PNG in FY23
PARTNERSHIPS
•Underlying growth of 12%
•Total in force risks
increased 18% to 129,000
TOWER DIRECT GWP ($m)PARTNERSHIPS GWP ($m)PACIFIC GWP ($m)
Note 1: Excluding divested portfolios which include the Solomon Islands business and Vanuatu subsidiary, and the New Zealand commercial rural portfolio

Reconciliation between underlying profit after
tax and reported profit after tax
Underlying and reported profit:
•“Net insurance revenue”, “net insurance service expense”
and “underlying profit” do not have a standardised meaning
under Generally Accepted Accounting Practice (GAAP).
Consequently, they may not be comparable to similar
measures presented by other reporting entities and are not
subject to audit or independent review.
•Tower uses underlying profit as an internal reporting
measure as management believes it provides a better
measure of Tower’s underlying performance than reported
profit, as it excludes large or non-recurring items that may
obscure trends in Tower’s underlying performance, and is
useful to investors as it makes it easier to compare Tower’s
financial performance between periods.
•Tower has applied a consistent approach to measuring
which items are excluded from underlying profit in the
current and comparative periods.
•“Reported profit after tax” is calculated and presented in
accordance with GAAP
(1) Non-underlying items include net impact of customer remediation provision increase and related costs, Canterbury earthquake valuation update, provision for software
impairment, regulatory and compliance projects such as Financial Markets (Conduct of Institutions) Amendment Act
(2) Reclassification of claims handling expenses from management expenses to claims expense; and FX gains/losses from other income to management expenses
(3) Reclassification of reinsurance expenses to present as net income from reinsurance contracts held for statutory purposes
(4) Reclassification of reinsurance and other recoveries to present as net income from reinsurance contracts held for statutory purposes
$ million
FY25
underlying
profit
Non-
underlying
items (1)
Management
expense
reclasses (2)
Reclass of
reinsurance
expenses (3)
Reclass of
reinsurance &
other recovery
revenues (4)
FY25
reported
profit
Gross written premium
599.8
Insurance revenue
597.1
(2.7)
594.3
Reinsurance expense
(80.1)
80.1
Net insurance revenue
517.0
(2.7)
0.0
80.1
0.0
BAU claims expense
(213.6)
(11.0)
(29.8)
1.8
Large event claims expense
(7.2)
Management expenses
(153.0)
(13.9)
28.8
Net commission expense
(9.2)
(4.4)
Insurance service expense
(383.1)
(24.9)
(1.0)
0.0
(2.6)
(411.6)
Net expense from reinsurance contracts held
(80.1)
2.6
(77.5)
Insurance service result
133.9
(27.6)
(1.0)
0.0
0.0
105.2
Net investment income
19.2
19.2
Net insurance finance expense
(1.6)
(1.6)
Other income and expenses
(1.5)
(4.6)
1.0
(5.1)
Underlying profit before tax
150.0
Income tax expense
(42.8)
8.7
(34.1)
Underlying profit after tax
107.2
Canterbury impact
(7.9)
7.9
Other non-underlying costs
(15.7)
15.7
Reported profit after tax
83.7
0.0
0.0
0.0
0.0
83.7

This presentation has been prepared by Tower Limited to provide shareholders with information on Tower’s business. This document
is part of, and should be read in conjunction with an oral briefing to be given by Tower. A copy of this webcast of the briefing is
available at http://www.tower.co.nz/investor-centre/ It contains summary information about Tower as at 30 September 2025 which
is general in nature, and does not purport to contain all information a prospective investor should consider when evaluating an
investment. It is not an offer or invitation to buy Tower shares. Investors must rely on their own enquiries and seek appropriate
professional advice in relation to the information and statements in relation to the proposed prospects, business and operations of
Tower. The data contained in this document is for illustrative purposes only. Past performance is not a guarantee of future
performance and must not be relied on as such. The information in this presentation does not constitute financial advice.
Forward looking statements
This document contains certain forward-looking statements.
Such statements relate to events and depend on circumstances
that will occur in the future and are subject to risks, uncertainties
and assumptions. There are a number of factors which could
cause actual results and developments to differ materially from
those expressed or implied by such forward-looking statements,
including, among others: the enactment of legislation or
regulation that may impose costs or restrict activities; the re-
negotiation of contracts; fluctuations in demand and pricing in
the industry; fluctuations in exchange controls; changes in
government policy and taxation; industrial disputes; and war and
terrorism. These forward-looking statements speak only as at
the date of this document.
Disclaimer
Neither Tower nor any of its advisers or any of their respective
affiliates, related bodies corporate, directors, officers, partners,
employees and agents (other persons) makes any
representation or warranty as to the currency, accuracy,
reliability or completeness of information in this presentation. To
the maximum extent permitted by law, Tower and the other
persons expressly disclaim any liability incurred as a result of the
information in this presentation being inaccurate or incomplete in
any way. The statements made in this presentation are made
only as at the date of this presentation. The accuracy of the
information in this presentation remains subject to change
without notice.
Disclaimer

---

1

Tower FY25 Results Announcement Investor Presentation Script
Slide 1 – 2025 Full Year Results
Michael Stiassny
Good morning and thank you for making the time to join us for this investor
call and presentation of our 2025 full year results.
Slide 2 - Agenda
With me in Auckland is our Chief Executive Officer, Paul Johnston, and Interim
Chief Financial Officer, Angus Shelton, who will take you through the results
and answer your questions.
Slide 3 – Chairman’s update
I think we can all agree it has been a great year for Tower shareholders.
FY25’s record underlying result demonstrates a strong business delivering
value today while continuing to build for tomorrow.
This year, we returned $45 million of capital to shareholders, and I am pleased
to announce that we have declared a fully imputed final dividend of 16.5 cents
per share. Combined with our interim dividend, this brings total dividends for
the year to 24.5 cents per share.
In considering this dividend, the Board wanted to distribute the benefit from
lower large events costs to shareholders. The 16.5 cents per share dividend is
made up of:
• 7.5 cents per share from adjusted earnings excluding large events;

2

• and an additional 9 cents per share reflecting the under-utilisation of the
$50m large events allowance in FY25.
These decisions underscore our commitment to consistently deliver returns,
backed by sustainable profit growth and a robust capital and solvency position.
[pause]
While we celebrate these achievements, we remain mindful of the future. The
unusually kind weather conditions and the absence of significant natural
hazard events have undoubtedly contributed to our success both this year and
last. However, we know such conditions are not permanent.
That is why we will continue to focus on what we can control: investing in our
digital platform, maintaining rigorous underwriting discipline, product
innovation, and leveraging technology, data, and efficiency to drive
performance. Our goal is clear—to build a business that is not only resilient but
also deeply customer-focused, ensuring we are well-prepared for whatever lies
ahead.
We were the first insurer in New Zealand to announce the introduction of
address-level risk-based pricing. Risk-based pricing enables lower pricing for
low-risk customers while effectively managing exposure. We have maintained
disciplined execution of our strategy, strengthened by strategic partnerships
with the likes of Trade Me, Kiwibank and from mid-next year, Westpac, and
brand momentum with a new campaign that will help drive future growth.
At the same time, we are investing in innovation, technology, and AI to
position Tower for its next growth phase. These investments will enhance

3

efficiency and deliver better customer experiences, ensuring Tower remains
competitive and relevant in a rapidly changing market.
[pause]
Before I hand over to Paul, I’d like to add a few additional words about Tower’s
risk-based pricing strategy and approach to public advocacy and sharing hazard
information with customers. We see these as a competitive advantage for
Tower, and they’re increasingly driving ‘real world’ action.
As an example, the South Dunedin Futures project is an excellent model of
community-led adaptation planning. The project actively sought to incorporate
insurance considerations, including from Tower, into its planning processes
which, in my view, should be applauded.
I was not surprised to read the results of a recent nationwide survey by ICNZ
that found 67% of respondents knew that natural hazards impacted their
insurance premiums, and almost 25% felt they did not have access to clear
information about those hazards when owning or buying a property. This
tallies with Tower’s research which found that 86% of people surveyed
consider it important to have information about their property’s risk profile.
While the National Adaptation Framework aims to provide a way forward, by
the time the details – and who pays – are hashed out, for the average
homeowner or buyer it could be too little, too late. They need certainty – and
access to information – now.
The reality is that a lot of that data is already available – at a cost – and most
insurers are using it when they price risk. The Tower difference – and this is
what I believe we should be very proud of – is that we have chosen to make

4

our insurance assessment of earthquake, flood, sea surge and landslide risks
visible and accessible.
For us, it’s the right thing to do.
[Pause]
Our experience aligns with the recent statement by ICNZ Chief Executive Kris
Faafoi: global reinsurers have made it clear that climate adaptation in New
Zealand is not optional.
Our view remains that risk based pricing provides the strongest, clearest
indication of where adaptation measures are critical. That is why we have also
shared insights and demonstrated our hazard model to both local councils and
central government to contribute meaningfully to the national climate
adaptation conversation.
Ultimately, I would like to see a New Zealand-wide database created that
becomes the single source of truth and is accessible by everyone. A
centralised, authoritative data source to truly understand the perils our
country faces at a granular and regional level.
It would be a most-powerful tool to really drive and focus climate adaptation
action. If used to guide smarter land-use decisions and resilient infrastructure
investment, it could help maintain cost effective reinsurance and therefore
long-term insurance accessibility in New Zealand.
Most importantly, it would empower people and communities to make
informed choices about where they live and how they build their families’
futures.

5

Food for thought.
[pause]
Back to today ... FY25 has been an exceptional year. We remain focused on
building a business that is sustainable and resilient through the cycle, and one
that continues to deliver attractive returns for shareholders.
I’ll now hand over to Paul and Angus, who will take you through the results and
outlook before we open for questions.
Paul Johnston
Slide 4 – Business update
Kia ora, and good morning, everyone.
Thank you for joining us for our 2025 full year results.
Slide 5 – Overview
Here is an overview of our presentation today, which will include the details of
our record FY25 underlying result and its key drivers.
We’ll also provide an update on our strategic plan and the next phase of
Tower’s growth, which I’ll begin with now.
Slide 6 - Entering the next phase of growth
FY24 and FY25 were all about continuing to build strong foundations under
Horizon 1 of our strategic plan. During this phase, we focused on resilience and
efficiency to position Tower for sustainable growth.

6

We strengthened our core by building foundational strength, managing risk
exposure carefully, driving operational efficiencies, and investing in technology
to improve processes and customer experience. At the same time, we worked
hard to create an effective and distinctive culture that empowers our people
and supports long-term success.
These efforts — which I’ll talk about in more detail shortly — have created a
solid platform for the next stage of our strategy. We are now entering Horizon
2, where the focus shifts to innovation and transformation to accelerate
growth.
Slide 7 – Our performance - strong operational and business performance
Tower has seen strong operational and business performance in the year.
Gross written premium increased to $600 million and customer numbers grew
strongly to 318,000. We also saw a substantial reduction in the BAU claims
ratio, while the MER remained stable and large event costs were low.
These factors combined have led to a record underlying profit after tax of
$107.2m.
Reported profit for FY25 is $83.7m.
On the basis of these results Tower will pay a fully imputed final dividend of
16.5 cents per share, bringing full year dividends to 24.5 cents per share. This
compares to 9.5 cents per share last year, in addition to a $45m capital return.

7

Slide 8 – External factors influencing FY25 result
FY25 was an exceptional year for Tower, driven by favourable external
conditions and the disciplined execution of our strategy. While the conditions
provided a strong tailwind, we expect these to normalise in FY26.
Large event claims costs were just $7.2 million, significantly below the
historical 10-year average. This benign weather environment also supported
improvements in our BAU claims ratio and overall profitability.
We delivered strong policy growth; however, the soft rating cycle, lower
inflation, and reduced claims from a lower-risk portfolio led to a decline in
average premiums.
As shown in the chart on the right, effective average premiums fell sharply
over the year as we moved quickly to adjust pricing to attract and retain
quality risks in what remains a highly competitive market. This is welcome
relief for customers after the premium increases driven by COVID-related
supply chain challenges and the 2023 weather events.
Inflation has also come back, returning to historical averages. This contributed
to improvements in our claims performance.
Motor theft frequency has reverted to pre-COVID levels, following actions
taken in prior years to reduce exposure to high-theft vehicles, helping to lower
claims frequency and severity in the motor portfolio.
Finally, reductions in the Official Cash Rate (OCR) have reduced investment
income.

8

These conditions, combined with our transformation initiatives, created a
unique environment for FY25.
Slide 9 – Sustained profitability improvement
This chart provides context to Tower’s performance over a five-year cycle in
which we’ve delivered consistent and sustainable improvements in underlying
profitability, driven by disciplined execution and strategic investment.
When we remove the cost of large events from underlying NPAT, the
underlying trend is clear: profitability has strengthened year after year,
reflecting the impact of improvements we’ve made to the business.
Profit has also been helped by more recent benign BAU claims experience in
the last two years.
Our FY26 guidance for underlying net profit after tax of between $87m and
$97m, excluding large events assumes the current soft rating cycle continues
and the BAU claims ratio begins to return to more normal levels.
Slide 10 – Policy growth in a competitive market
Despite a soft rating cycle and intense competition, Tower achieved strong
policy growth in FY25. We welcomed 13,000 new customers, bringing our total
to 318,000, and delivered 6% policy growth in New Zealand core products,
with strong 11% growth in house policies.
This performance reflects our strategic focus on the house portfolio. House
insurance customers typically hold more policies and stay longer, so prioritising
this segment strengthens both retention and profitability.

9

Importantly, growth has come with improved risk quality. Our risk-based
pricing strategy means we’re growing in lower-risk customers. As a result,
Tower’s expected average annual loss from flooding has reduced by 21% on a
per-policy basis and 16% overall - a significant improvement in portfolio
resilience.
We also strengthened our brand presence. Our new campaign, “The Misses,”
launched during the year and resonated strongly with Kiwi audiences, winning
Kantar’s June 2025 Ad Impact Award.
Looking at the graphs, you can see the shift in risk count over the past five
years. House policies have grown consistently, with a sharp increase in FY25,
while the motor portfolio has now returned to growth after a drop in FY24
following actions to tighten risk appetite in late FY23.
This reflects our deliberate strategy to focus on high-quality risks and build a
stronger, more resilient portfolio.
Slide 11 - Investing for future value
In FY25, we leveraged the benefits of increased scale by investing in strategic
initiatives designed to deliver long-term value for Tower and our customers.
These initiatives focus on driving greater efficiency, enhancing customer
experience, and supporting sustainable growth.
This included the launch of Amazon Connect, improving customer interactions
and service delivery. We also introduced an integrated motor assessing
system, which is cutting assessment times, reducing manual effort on claims
handling, and lowering repair costs.

10

Our digitisation programme is nearing completion, with 79% of tasks now able
to be completed online, making it easier and more efficient for customers to
manage policies and lodge claims.
We expanded risk-based pricing to include two new perils and started work on
building our AI capability. These steps position us for greater efficiency and
innovation in FY26 and FY27.
Our innovative approach was recognised with the Insurance Business 5-Star
Insurance Innovator Award for the second year running in 2025.
Slide 12 – Elevating customer experience
Delivering simple and rewarding experiences for our customers remains a core
priority, and in FY25 we made strong progress.
Our Net Promoter Score rose to +44, up from +38 in FY24, reflecting the
impact of our digitisation programme and operational improvements.
We also improved telephony performance, with sales and service
abandonment rates dropping to an average of 7%, down 1% year-on-year, as
we streamlined processes and expanded digital capability.
Digital adoption overall continues to improve: in New Zealand, 63% of sales,
51% of service tasks, and 70% of claims lodgments are now completed online.
At the same time, 59% of customers are registered for My Tower, up from 53%
last year, showing strong engagement with our digital platform.
Our Suva Hub continues to deliver efficiency benefits, now handling 83% of
New Zealand sales and service calls, compared to 55% in FY24. This scale
improvement is helping us deliver faster, more consistent service.

11

Finally, we were proud to be recognised as the Insurance Sector Award winner
at the 2025 CRM Contact Centre Awards (NZ), reinforcing our customer focus.
Slide 13 - Financial performance
I will now hand you over to our interim Chief Financial Officer, Angus Shelton
who will talk you through the details of our financial performance this year.
Slide 14 – Group underlying performance
Thank you, Paul.
Gross Written Premium grew by 2% compared to FY24, driven by strong policy
volumes. This growth was tempered by lower average premiums as Tower
prioritised attracting low-risk customers and maintaining competitive pricing.
The BAU claims ratio improved significantly to 41.3%, driven by a range of
factors, including: targeted rate increases from the prior year flowing through
the portfolio, improved risk selection, reduced motor theft, and relatively
benign weather conditions throughout the year.
Large event costs for the full year were $7.2m.
The MER remained stable at 31%, as we reinvested improvements from
increased scale into technology and growth initiatives.
We are reporting an underlying NPAT including large events of $107.2m, a
strong uplift from the prior year, and a reported profit after tax of $83.7m, up
from $74.3m in FY24. Reported profit includes strengthening of provisions for
Canterbury earthquake claims, customer remediation costs and software
impairment.

12

Slide 15 – Movement in underlying NPAT
Here is the bridge between underlying NPAT in FY24 of $83.5m and underlying
NPAT of $107.2m in FY25.
You can see that business growth, driven by higher net insurance revenue,
contributed $9.5m.
BAU claims improvements due to prior year rating and fewer than expected
claims, due to weather and lower motor frequency, added a further $25.1m.
Partly offsetting these gains were the movement in large events costs year on
year, and $4.1m after tax of increased strategic investments aimed at
delivering future growth and efficiency.
Overall, these factors have driven a strong uplift in underlying NPAT year-on-
year.
Slide 16 – Rating pressure impacts GWP growth
Despite strong volume growth the softer rating environment impacted GWP
growth which was 2% year on year.
Within this, house GWP grew strongly at 10%, driven by a 11% increase in
policies, reflecting our strategic focus on the house portfolio.
On the other hand, Motor GWP declined by 5%. While motor policies grew by
2%, we reduced premium rates to balance margin and growth in a competitive
market.
Our Partnerships channel delivered 12% GWP growth, and overall NZ retention
improved to 78%, up from 77% in FY24.

13

On the right, you can see the growth in total GWP over time, which has
increased steadily from $404m in FY21 to $600m in FY25.
Slide 17 - Lower frequency and severity of claims
In FY25, we saw a significant improvement in claims performance, with the
BAU claims ratio reducing to 41.3%, down from 48.1% in FY24. This
improvement reflects prior year premium growth earning through and a
flattening of both severity and frequency trends.
As shown in the graphs:
• Motor claims frequency eased to 11.8%, and severity moderated to
$3,156 per claim, following prior actions to reduce exposure to high-
theft motor policies. Efficiency initiatives, such as reducing reliance on
external assessors, also helped contain costs.
• House claims frequency increased to 7.4%, driven by more small
weather-related claims, while severity remained stable at $3,954 per
claim, supported by a less inflationary environment and improved risk
selection.
Finally, large event costs for the year were $7.2m, reflecting the relatively
benign weather conditions.
Slide 18 – Stable management expense ratio
We can see that the management expense ratio remained at 31.4% in FY25,
consistent with FY24.

14

While we saw improved efficiencies of scale from business growth, which
contributed a 2.2% reduction in MER, this was offset by increased investment
in strategic and foundational initiatives to improve growth, efficiency, and
resilience, which added 1.1%.
There was also a 0.7% increase from timing differences related to deferred
acquisition costs, and a further 0.3% increase from staff and other costs. These
cost increases are largely linked to inflation and growth initiatives, but
importantly, they remain below the rate of inflation thanks to efficiencies from
digitisation and the Suva Hub.
Slide 19 – Conservative investment strategy
In FY25, net investment income was $19.2m, which is $2.4m lower than FY24.
Tower continues to maintain a conservative investment strategy, focused on
high credit quality and liquidity, with a target duration of around six months for
the core investment portfolio.
This approach has helped mitigate volatility from macroeconomic factors and
mark-to-market movements, while allowing us to benefit from higher interest
rates earlier in the cycle.
However, as you can see on the left, the running yield on the core portfolio has
declined steadily, finishing the year at 3.1% as at 30 September 2025, down
from its peak of over 6% in early FY24.
With interest rates now well past their peak, we expect yields to remain
suppressed and continue to trend lower in line with OCR movements.

15

Slide 20 – CEQ and customer remediation
The two key non-underlying items which impacted reported profit in FY25
were Canterbury earthquake provisions and customer remediation costs.
Starting with Canterbury earthquakes:
We continue to settle claims, with 25 claims closed during the year, but we
also received 22 new overcap or reopened claims from the NHC, which is seven
more than FY24. This higher-than-expected inflow resulted in the total number
of open claims only falling slightly from 30 September 2024, to 13 at 30
September 2025.
Because these new claims came in at a higher rate than we’ve seen recently,
and with average costs trending above historical levels, we’ve strengthened
our outstanding claims provision to allow for the possibility of more new or
reopened claims in the future. As a result, FY25 includes an adverse Canterbury
earthquake charge of $7.9m after tax, recorded as a non-underlying item.
We continue to work closely with the NHC to identify potential overcap claims
earlier, and with our specialist team to finalise outstanding Canterbury claims
as efficiently as possible.
On customer remediations: we incurred a $10.9m after-tax charge, which
includes further provision for remediating customers and costs associated with
delivering the remediation programmes.
Investigating and resolving historical errors remains complex and resource-
intensive, often requiring as much investment in analysis and confirmation as
the remediation payments themselves. That’s why we’re investing in systems
and processes to ensure we get it right for the future.

16

Slide 21 – Reinsurance programme
In FY26, Tower successfully renewed its reinsurance programme, securing
comprehensive cover at competitive rates.
The programme includes catastrophe reinsurance of up to $915 million for two
events, an increase from $800 million in FY25 to meet the requirements of our
growing house portfolio, and continued cover for a third event of up to $85
million.
Retention for catastrophe events has increased slightly to $20 million,
following the expiry of multi-year arrangements. We’ve also made a structural
change for large individual property risks, moving from proportional cover to
excess of loss, which reduces reinsurance premiums while maintaining strong
protection for large claims.
As a result of these changes, reinsurance premium expense is expected to
reduce to an estimated 11.3% of GWP in FY26, down from 13.4% in FY25. This
reduction will be partly offset by lower recoveries on property risks previously
ceded under proportional treaties.
We’ve also deepened partnerships with global reinsurers, with several
committing to new multi-year agreements, providing greater certainty around
future costs and catastrophe excesses.
For FY26 we have set a large event allowance of $45m, down from $50m in
FY25, to reflect our improved risk selection. The storms across New Zealand in
late October 2025 will be recorded as a large event in FY26 with an estimated
cost of $4.5m.

17

Slide 22 - Capital and solvency position
Tower’s capital and solvency position remains strong, supported by prudent
capital management and a reaffirmed A- financial strength rating by AM Best in
April 2025.
During the year we transitioned to the second amendment to the Reserve
Bank’s Interim Solvency Standard, and our solvency ratio is now 143%. The
change from last year includes the $45m capital return to shareholders, profit
and regulatory capital movements and FY25 dividends.
Adjusted solvency margin as at 30 September 2025 is $89m, net of the final
dividend of 16.5 cents per share.
Tower continues to maintain a strong capital position and financial flexibility to
support growth, while meeting regulatory requirements.
Slide 23 – Looking forward
Thank you. I will now hand back to Paul who will provide an update on our
guidance and near-term priorities.
Paul Johnston
Thank you, Angus.
Slide 24 – Entering the next phase of growth
We are now moving into the next phase of our strategic plan - one centred on
innovation and transforming our offerings.

18

Horizon 2, spanning FY26 and FY27, is focused on sustainable growth and
delivering a leading customer experience, supported by investment in
customer data, digitisation, and innovation. We will embed AI where it adds
value and efficiency, while carefully managing risks.
As always, we remain committed to consistently improving earnings while
leveraging the efficiencies and resilience we’ve built in Horizon 1.
Looking further ahead to FY28 - FY30, our ambition is to broaden growth
through new channels and innovative products, moving from being a market
challenger to a market leader. This means continuing to build a leading brand,
driving a highly automated and digital business model, and delivering
personalized customer experiences at scale.
I’ll take you through some of the specific initiatives that will drive this
transformation in the following slides.
Slide 25 – Strategic initiatives for growth
We’re targeting more than $750 million in GWP by FY28 through organic
growth, and in FY25 we delivered a number of initiatives to get us there.
A major milestone is our new partnership with Westpac NZ, starting July 2026.
This partnership will expand our reach and support our future growth.
We will also be offering insurance to a portfolio of Kiwibank customers,
currently insured by Ando, during the next 18 months.
On the brand side, we’ve launched a bold new campaign, ‘The Misses’. This
campaign reinforces Tower’s position as a modern, digital-first insurer and
builds emotional connection with customers.

19

We’ve also implemented sea surge and landslide risk based pricing, which we
expect to help attract new customers and improve retention through lower
pricing.
Finally, removing the multi-policy discount will help simplify our policy sales
and management processes. Tower remains committed to providing fair,
transparent, and competitive pricing and we will continue to review our pricing
to deliver value to customers.
Slide 26 - Customer experience and efficiency through innovation
Innovation is central to our strategy for delivering a simpler, smarter, and more
rewarding experience for customers, while driving efficiency across the
business.
By FY28, we’re targeting 80% of sales, service, and claims lodgement tasks to
be completed through digital channels. This shift will make interactions faster
and easier for customers while reducing cost and complexity for Tower.
Our investments in digitisation will be key to achieving this goal. We plan to
build a customer data platform that lays the foundation for our vision of hyper-
personalised service — a future where we can surface relevant insights about
each customer to suggest products, services, and benefits tailored to their
unique needs and situation. This will help customers get the best cover and
value for their circumstances.
Alongside this, we plan to roll out AI-driven process automation to streamline
workflows and transform claims management with a new house assessing
platform.

20

Our partnership with Amazon Connect will help deliver best-in-class
enhancements to our contact centre.
Finally, we will invest in product innovation to meet emerging customer needs,
particularly in the context of climate change.
Slide 27 – FY26 guidance and future targets
Looking ahead to FY26, we are targeting Gross Written Premium growth of
between 5% and 10%, with the management expense ratio expected to remain
between 31% and 32%. This will deliver underlying NPAT (excluding large
events) of between $87 million and $97 million. Our FY26 large events
allowance is $45 million.
We are targeting a combined operating ratio of between 86% and 88%,
supporting strong underlying profitability. Assuming full utilisation of the large
events allowance, underlying NPAT is expected to be between $55 million and
$65 million, with any unused portion of the large events allowance flowing
rough to improve the full-year result. Reported NPAT will be impacted by non-
underlying items related to remediations and costs associated with regulatory
change.
Looking further ahead, we have disclosed medium-term targets for FY28. As
the insurance cycle stabilises and strategic initiatives deliver, we expect GWP
to reach $750 million or more, representing a Cumulative Annual Growth Rate
over the next 3 years of over 7.5%. We also expect the management expense
ratio to improve to between 28% and 30%, and a combined operating ratio
target of between 85% and 87%.

21

These targets reflect our confidence in the strategy and the strong foundations
we have built, positioning Tower for sustainable growth and long-term value
creation.
Thank you for your time this morning, I will now hand back to the operator to
ask for questions.

---

Distribution Notice

[Draft Note: all cash amounts in this form should be provided to 8 decimal places]

Section 1: Issuer information
Name of issuer Tower Limited
Financial product name/description Ordinary Shares
NZX ticker code TWR
ISIN (If unknown, check on NZX
website)
NZTWRE0011S2
Type of distribution
(Please mark with an X in the
relevant box/es)
Full Year X Quarterly
Half Year Special
DRP applies
Record date 15/01/2026
Ex-Date (one business day before the
Record Date)
14/01/2026
Payment date (and allotment date for
DRP)
29/01/2026
Total monies associated with the
distribution
1
(as at the date of this
form)
56,521,090
Source of distribution (for example,
retained earnings)
Retained earnings
Currency NZD
Section 2: Distribution amounts per financial product
Gross distribution
2
$0.22916667
Gross taxable amount
3
$0.22916667
Total cash distribution
4
$0.16500000
Excluded amount (applicable to listed
PIEs)
N/A
Supplementary distribution amount
$0.02911765
Section 3: Imputation credits and Resident Withholding Tax
5

1
Continuous issuers should indicate that this is based on the number of units on issue at the date of the form
2
“Gross distribution” is the total cash distribution plus the amount of imputation credits, per financial product, before the deduction of
Resident Withholding Tax (RWT).
3
“Gross taxable amount” is the gross distribution minus any excluded income.
4
“Total cash distribution” is the cash distribution excluding imputation credits, per financial product, before the deduction of RWT.
This should include any excluded amounts, where applicable to listed PIEs.
5
The imputation credits plus the RWT amount is 33% of the gross taxable amount for the purposes of this form. If the distribution is
fully imputed the imputation credits will be 28% of the gross taxable amount with remaining 5% being RWT. This does not constitute
advice as to whether or not RWT needs to be withheld.

Is the distribution imputed Yes
If fully or partially imputed, please
state imputation rate as % applied
6

28%
Imputation tax credits per financial
product
$0.06416667
Resident Withholding Tax per
financial product
$0.01145833
Section 4: Distribution re-investment plan (if applicable)
DRP % discount (if any)
N/A
Start date and end date for
determining market price for DRP

Date strike price to be announced (if
not available at this time)

Specify source of financial products to
be issued under DRP programme
(new issue or to be bought on market)

DRP strike price per financial product

Last date to submit a participation
notice for this distribution in
accordance with DRP participation
terms

Section 5: Authority for this announcement
Name of person

authorised to make
this announcement
Paul Johnston
Contact person for this
announcement
Emily Davies
Contact phone number +64 21 815 149
Contact email address emily.davies@tower.co.nz
Date of release through MAP

27/11/2025

6
Calculated as (imputation credits/gross taxable amount) x 100. Fully imputed dividends will be 28% as a % rate applied.

---

Tower Limited
Climate Statement
2025

Executive summary 2
Tower’s business model and strategy 5
Tower’s value chain 7
Tower’s FY25 operational footprint
1
8
Tower’s approach to climate 9
Current climate-related impacts 10
Understanding our possible futures 12
Tower’s climate-related scenarios 15
Material climate-related risks and opportunities 18
Climate-related risks 19
Material climate-related opportunities 24
Anticipated impacts 25
The transition planning aspects of our strategy 26
Our greenhouse gas (GHG) emissions 30
GHG emissions 32
GHG emissions target 34
Our emissions reductions initiatives 35
Measuring our performance 36
Risk management 37
Integration of climate risks in Tower’s Risk Management Framework 38
Governance 40
Governance framework 40
Climate-related skills and capabilities 45
Appendices 46
Contents
1 ContentsCLIMATE STATEMENT 2025

Tower’s Board and Management remain
committed to navigating the changing
climate in support of our customers and
communities in New Zealand and the
Pacific, and in the long-term interests
of our shareholders.
This executive summary highlights the key activities
Tower has undertaken in FY25 to support a low-
emissions, climate-resilient future for our business,
customers, and the wider insurance sector.
Further detail is available in the full report, which covers
the period from 1 October 2024 to 30 September 2025.
Reviewed and refined climate-related
risks and opportunities
Tower conducted a comprehensive review of its climate-
related risks, consolidating the number from 26 to 22.
This refinement reflects improved alignment of scenario
drivers, ownership, and mitigation strategies. The five
inherently high risks remain unchanged and continue
to be managed under Tower’s Risk Management
Framework. Tower’s key climate-related risks relate
to operational and financial stress from increasingly
frequent and severe weather events; rising reinsurance
costs that may limit access and affordability; and
the potential for climate impacts - both physical and
transitional - to evolve faster than Tower’s ability to
respond and adapt.
Tower’s material climate-related opportunities remain
unchanged and focus on strengthening brand and
reputation through the development of new products
and competitive pricing, as well as building a more
resilient insurance industry by forming partnerships
that deliver benefits to communities.
Developed the transition planning aspects
of our strategy
Tower progressed its climate strategy by integrating
transition planning into its FY25 business planning
process. The work to articulate Tower’s approach
towards a climate resilient and low emissions future was
led through cross-functional collaboration and oversight
by the Board.
While Tower has outlined its direction beyond FY30,
we expect that detailed planning will evolve in the
preceding periods as climate and socio-economic
conditions become clearer. At this stage, there is
considerable uncertainty inherent beyond that period,
which means that our approach may evolve.
Executive summary
CLIMATE STATEMENT 20252 Contents

Expanded risk-based pricing to new perils
In FY25 Tower expanded our risk-based pricing model to
include sea surge and landslide risks. To support greater
customer transparency, Tower introduced individual
property risk ratings for these hazards, accessible via its
online quote tool for residential addresses across New
Zealand. At launch Tower communicated with a range
of stakeholders including representatives from local and
central government to help broaden understanding of
risk-based pricing and advocate for improved climate
change adaptation planning. This engagement for better
adaption planning is aimed to support Tower’s strategic
position of maintaining our social license to operate.
In FY25 Tower procured climate conditioned flood
and sea surge data from our data partners to further
understand potential climate risks related to each
scenario. The data assisted Tower to better understand
the implications of our climate change scenarios.
Revised estimates show fewer properties at high risk of
flooding in the future than initially projected, indicating
that Tower’s risk-based pricing strategy is effectively
reducing exposure to physical climate risks.
Large event response
In FY25, Tower developed and implemented a Large
Event Response Plan to enhance operational readiness
and customer support during major events. The plan
establishes a structured, customer-focused approach
to managing significant surges in claims, ensuring clear
communication and continuity of service. It provides
detailed guidance for minimising disruption to business-
as-usual operations during large-scale events, including
those involving Natural Hazards Commission (NHC) Toka
Tū Ake cover claims. The plan outlines a coordinated,
company-wide response and enables the timely
mobilisation of resources when required.
Strengthened GHG emissions management,
exceeded target
During FY25 Tower undertook a detailed review of our
greenhouse gas inventory, resulting in restatements in
the period from FY20 to FY24, and implementation of
a new GHG Management Framework which included
improvements to our emissions data identification and
calculation controls.
Tower has obtained limited assurance for Scope 1 & 2
emissions in this Climate Statement. Tower has exceeded
our five-year emissions reduction target, achieving a 24%
reduction against a 21% goal.
A revised target to FY35 is provided in the GHG
emissions section of this Climate Statement.
Maintained strong governance
and risk management
Tower’s ongoing management of climate-related risks
and opportunities continues to be supported by strong
governance and risk management. The Board and
Executive Leadership Team continue to oversee our
climate strategy, supported by cross-functional teams
that integrate climate considerations into decision-
making processes.
Scope of the climate statement and
statement of compliance
This report is Tower’s second group climate statement
and is prepared in accordance with section 461ZA of the
Financial Markets Conduct Act 2013 and the Aotearoa
New Zealand Climate Standards (NZ CS 1, NZ CS 2
and NZ CS 3). It covers our New Zealand and Pacific
operations
1
and outlines the steps we are taking in
support of a low emissions and climate-resilient business
for the future. This climate statement has been prepared
for our primary users, who we have identified as primarily
being potential and existing shareholders (including
asset managers). All financial information is provided in
NZD. Our corporate structure is further explained under
the Governance Section on page 40.
1 The subsidiaries of Tower Limited are: Tower Services Limited, National Pacific
Insurance Limited (Samoa), National Pacific Insurance (Tonga) Limited, National
Pacific Insurance (American Samoa) Limited, Tower Group Services (Fiji) Pte
Limited, Tower Insurance (Fiji) Limited, Southern Pacific Insurance Company
(Fiji) Limited, Tower Insurance (Cook Islands) Limited, The National Insurance
Company of NZ Limited.
CLIMATE STATEMENT 20253 Contents

Chair,
Michael Stiassny
Audit Committee Chair,
Mike Cutter
Tower has chosen to use the following adoption provisions in our second Climate Statement
Adoption provision Rationale
Adoption provision 2: Anticipated
financial impacts
Adoption provision 2 has been extended to include the second reporting
period. Tower have adopted this provision for the FY25 Climate Statement
as it develops its methodologies to assess potential climate -related
anticipated financial impacts.
Adoption provision 4. Scope 3
greenhouse gas (GHG) emissions
Selected operational Scope 3 emissions have been included to
maintain consistency with previous Annual Report and Climate
Statement inclusions.
Adoption provision 5. Comparatives
for Scope 3 GHG emissions
As described above, our material Scope 3 inclusions are in development.
Adoption provision 6. Comparatives
for metrics
This adoption provision permits Tower to provide one year of comparative
information for each metric disclosed in this Climate Statement.
Adoption provision 7. Analysis for trendsTrend analysis will be conducted as part of the ongoing development
of metrics.
Adoption provision 8: Scope 3 GHG
emissions assurance
In FY25 Tower has sought assurance of Scope 1 & 2 GHG emissions only.
Scope 3 emissions disclosed in this Climate Statement have not been
included in FY25 assurance, as permitted under this adoption provision.
Statement of Compliance
These climate-related disclosures comply with the Aotearoa New Zealand Climate Standards issued by the XRB.
This Climate Statement is dated 27 November 2025 and is signed on behalf of Tower by:
CLIMATE STATEMENT 20254 Contents

Tower’s products cover:
House
Contents
Motor
CaravanLandlord
Boat
Pet
Travel
Business
MotorbikeMotorhome
Parametric cover
(for cyclone and rainfall -
only in the Pacific)
Tower’s business model is customer-focused. We deliver
general insurance products and services directly to
customers via digital platforms and phone, using data
to enhance customer service and streamline processes.
Our aim is to provide fair and transparent services, with
customer care at the heart of everything we do.
Operationally Tower is structured around the ways our
customers interact with our business: via claims, service
(renewal, payments and queries) and new business (new
and existing customers), both via our digital channels
and our phone lines.
Tower provides general insurance products to customers
in New Zealand, Fiji, Cook Islands, Samoa, American
Samoa and Tonga.
Tower’s business model and strategy
5 ContentsCLIMATE STATEMENT 2025

Tower’s value chain
Tower’s full value chain is depicted in the diagram below.
Content within our Climate Statement related to our
scenario analysis, assessment of climate-related risks and
opportunities, and governance encompasses all aspects
of our value chain, across our New Zealand and Pacific
operations. Content relating to GHG emissions excludes
partners, reinsurers and shareholders.
Inspire, shape and protect
the future for the good
of our customers and
communities.
We pay claims directly
to customers or pay
suppliers to fulfil
customers’ claims.
Shareholders receive
shares in the company
and Tower aims to
provide an appropriate
return on investment.
Customers pay
premiums to
protect their risks
or assets
Our shareholders
provide capital,
enabling us to
grow and operate.
OUR PEOPLE
& EXPERTISE
Our reinsurers compensate
us when large events occur.
We pay annual premiums
to purchase reinsurance
protection.
Our people enable
us with their skills,
expertise and
commitment.
We provide our people with
a positive culture, attractive
benefits and career
development.
OUR CUSTOMERS
REINSURERS

S
k
i
l
l
s

a
n
d

c
a
p
a
b
i
l
i
t
i
e
s

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i
s
k

m
a
n
a
g
e
m
e
n
t

C
o
m
p
l
i
a
n
c
e

D
a
t
a

a
n
d

t
e
c
h
n
o
l
o
g
y

D
i
g
i
t
a
l

p
l
a
t
f
o
r
m
s

U
n
d
e
r
w
r
i
t
i
n
g

S
e
r
v
i
c
e

S
a
l
e
s

C
l
a
i
m
s

We invest premiums (less
costs) to hold in reserve
for potential future claims.
We hold capital to meet
solvency requirements to
ensure customer claims
are met.
We build mutually beneficial
partnerships with data,
technology, servicing and
banking partners.
We work closely with our
claims suppliers to provide
customers with swift, quality
resolution.
Partnerships enable new
products and services and
drive service, efficiency
and quality gains.
OUR PARTNERS
& SUPPLIERS
SHAREHOLDERS
INVESTMENTS/
CAPITAL
CLIMATE STATEMENT 20257 Contents

Map not to scale
1
All figures are as at 30 September 2025.
2
Gross Written Premium (GWP) includes all operations during the year.
3
Scope 1 and 2 greenhouse gas emissions tonnes of carbon dioxide equivalent (tCO
2
e).
4
Excludes the Board of Directors, and includes permanent and fixed term employees of
Tower and Tower’s Pacific Island subsidiaries.
Pacific
New Zealand
Tower’s FY25 operational footprint
1
GWP
2
GWP
2
customers
customers
employees
4
tCO
2
e
3
tCO
2
e
3
employees
4
$42m
$558m
20,000
298,000
355
157
121
611
New Zealand
Samoa &
American
Samoa
Tonga
Fiji
Cook
Islands
8 ContentsCLIMATE STATEMENT 2025

Additionally a core part of our business model and
value chain requires an ability to respond effectively to
large events. This includes holding sufficient levels of
capital and reinsurance as well as development and
implementation of our Large Event Response Plan.
Tower’s approach to climate
As the global and domestic economy transitions
towards a low-emissions, climate-resilient future, Tower
recognises the need to develop a climate resilient
business for the long term.
Our strategy for managing climate-related risks and
leveraging opportunities aligns with our broader
business strategy, including its transition planning
elements, and builds on our sustainability strategy.
That strategy centres on four main approaches:
Reducing our emissions is an important aspect of our
sustainability strategy and our Scope 1 and 2 greenhouse
gas (GHG) emissions have reduced by 24% from our
FY20 base year. FY25 is the final year in our emissions
target period. Our target for our FY26 to FY35 period and
further details on emissions inventory are provided in the
Measuring our performance section on page 30.
Risk-based pricing – managing risk at an
increasingly granular level. In FY25 Tower
expanded our risk-based pricing model to
include sea surge and landslide risks. To
support greater customer transparency, Tower
introduced individual property risk ratings for
these hazards, accessible via its online quote
tool for residential addresses across New
Zealand. At launch Tower communicated with a
range of stakeholders including representatives
from local and central government to help
broaden understanding of risk-based pricing
and advocate for improved climate change
adaptation planning.
1.
Product innovation – developing new products
to help address affordability challenges and
support the transition to lower emissions assets.
Maintaining our social licence to operate
– upholding strong relationships with our
shareholders, reinsurers, government
representatives and industry stakeholders, and
keeping pace with the changing expectations of
customers and communities.
Data and technology – investing in enhanced
data and technology to continually improve our
underwriting and pricing and to better support
customers through large events.
2.
4.
3.
CLIMATE STATEMENT 20259 Contents

FY25FY24FY23FY22FY21FY20FY19FY18FY17FY16FY15FY14
$10m$10m
$7m$7.m
$12m$10m
$7m
$9m
$25m
$0m$0m$0m$0m
$10m
$14m
$13m$14m
$19m
$18m
$54m
$18m
$12m
$222m
$5m
$7m$7m
Current climate-related impacts
Catastrophic and large weather events
Material physical impacts
In the FY25 period Tower did not experience any material
physical impacts from climate-related weather events.
While New Zealand, Fiji and Samoa experienced severe
weather events, overall claims costs related to large
events in FY25 was $6.9m, substantially below the
five- and ten-year rolling average shown in the graph
adjacent and well within the allocated large event
allowance of $50m for FY25.
Over the past ten years Tower has experienced an
increasing frequency and severity of large weather
events that may be linked to a changing climate.
This volatility presents challenges for Tower in our
modelling and financial planning. We continue to
take a conservative approach to these to support our
financial resilience.
As indicated in the graph the five-year rolling average of
large events costs for Tower in the financial year ending
30 September 2025 was $12.2m.
Net costs
Gross costs
5-yr average – net cost
10-yr average – net cost
NB Tower measures large events as those which have a net cost to Tower of more than $2m. Division of net and gross values are approximate, based on internal records.
Tower’s net large event claims costs are subject to reinsurance structures during the reporting periods and the overall growth of our business. The historical large event
claim costs are current estimates as at 30 September 2025, any development in prior year event costs are reflected in their respective incurred periods.
In the prior year, the FY23 net large event costs were previously reported as excluding any catastrophe reinsurance reinstatement costs, this is now included within the
net cost of the FY23 events to be consistent with the basis on which Tower’s other financial disclosures are made. There is no change to the gross cost of the event.
CLIMATE STATEMENT 202510 Contents

Material transition impacts
During the FY25 reporting period, Tower did not identify
or experience any material transition impacts. However,
consistent with our strategic focus, we continued to
invest in strengthening our response to large and/
or frequent weather events and risk-based pricing
and transparency.
A key development was the adoption of a Large Event
Response Plan, overseen by the recently established
role of Head of Tower Natural Disaster Response. This
initiative enhances our operational readiness and aligns
with our broader climate resilience strategy. There was
no financial impact of this development which was
completed using internal resources in FY25.
In FY25, Tower also advanced its risk-based pricing
framework by incorporating new hazard data and
modelling capabilities in New Zealand. This enabled
the extension of our public risk ratings tool to include
landslide and sea surge risks. The inclusion of these
hazards aims to improve transparency around how
climate and natural hazard risks are reflected in
customer premiums.
This expansion builds on our introduction of risk-based
pricing for earthquakes (2018) and floods (2022),
alongside the launch of a tool that provides customers
with individual risk ratings for their properties.
The financial impact of this pricing extension is not
yet able to be quantified, because it will only become
evident over the next 12 months as customer policies are
renewed. With the addition of landslide and sea surge
risk ratings, over 90% of Tower customers will receive a
reduction in the natural hazards portion of their premium,
with average savings of $70 per property. Fewer than
10% of properties—those with higher exposure to
sea surge or landslide risks—will see a proportionate
increase in this element of their premium.
To support affected customers, Tower will smooth
premium increases over a period of up to four years,
ensuring a fair and manageable transition.
Tower has previously identified a potential transition
risk related to customer perceptions of insurance
affordability and accessibility. In FY25, Tower conducted
consumer research alongside the expansion of risk-
based pricing to monitor this potential risk. The findings
indicate that, at present, this risk remains low.
The research, Weathering Change: Attitudes to Climate
Risk and Resilience in New Zealand, provided a snapshot
of public awareness of climate-related risks and natural
hazards. It found that nearly one-third of New Zealanders
are concerned about the impact of climate-related
weather events on their homes, despite 79% not having
experienced a major event at their property in the
past decade.
This research supports Tower’s understanding of
customer and community concerns and informs our
ongoing assessment of potential material transition
impacts. While the cost was not material, the research is
included here to demonstrate how Tower identifies and
responds to issues that matter most to our customers.
CLIMATE STATEMENT 202511 Contents

The NZ CS 1 requires disclosure of the scenario analysis
process Tower has undertaken to identify climate-related
risks and opportunities. Scenario-based analysis explores
how uncertain, forward-looking variables might logically
interact to create plausible future states. The purpose
of Tower’s scenarios is not to predict the future, but to
identify and interrogate the assumptions underlying
critical decisions.
Tower’s climate-related scenarios are based on the
Insurance Council of New Zealand’s (ICNZ) shared
climate scenarios for the insurance sector. In 2022,
Tower participated in a New Zealand insurance industry
initiative to co-design these industry scenarios.
Scenario development
In 2023 Tower engaged KPMG to facilitate the entity-
level scenario development and analysis process with
a cross functional working group of executives and
senior leaders. Through a series of workshops, this
group translated the ICNZ climate scenarios to Tower’s
business, strategy and operations in New Zealand and
our Pacific markets in line with XRB guidance.
Tower’s climate-related scenarios use, as a base,
the same framework architecture, quantitative and
qualitative parameters, and narrative storylines as the
ICNZ scenarios. However, they were adapted in FY23 to
better reflect our business operations, focusing on:
• The potential physical impacts of climate in the
Pacific, given our geographic distribution.
• Navigating financial markets during disruption to
highlight possible impacts on our investment portfolio.
We consider these scenarios continue to be appropriate
for FY25.
Understanding our possible futures
2022
Summary of scenario development process
2023
20242025
Management level
and Board approvals
of scenarios and
climate-related risks
and opportunities
Procured climate
conditioned hazard data
to assess potential future
climate-related business
risk and effectiveness of
strategy
ICNZ collaboration to
develop Insurance
Sector scenarios for NZ
Scenario analysis to
identify climate-related
risks and opportunities
Workshops with Senior
leaders to test scenarios
Tower senior leader
workshops to develop
Tower-specific scenarios
1.2.3.4.5.6.
CLIMATE STATEMENT 202512 Contents

Analysis undertaken
These scenarios were analysed in a series of workshops
by a selected cross-functional group of Tower executives
and senior leaders in FY23. The group assessed Tower’s
strategy and operations against the three climate-related
scenarios, identifying a range of physical and transitional
impacts. These impacts were then assessed against
the three identified time horizons and prioritised by
likelihood and potential impact.
Through this process, Tower identified a long list of 42
impacts and implications, which were further assessed
via our climate-related risk management and strategy
processes to develop the climate-related risks and
opportunities outlined later in this section.
Tower’s climate-related scenarios and climate-related
opportunities were reviewed by the Sustainability and
Climate Steering Committee and approved by the
Tower Board in FY24. Tower’s climate-related risks were
reviewed by the executive-level Management Risk and
Compliance Committee (MRCC) and the Board Risk
Committee in FY24. The scenarios were considered
sufficient and were not revisited in FY25. Board and
Audit Committee input will be sought for scenario
review in FY26.
The scenario analysis was a standalone process
designed specifically to address the CRD Regime
requirements. While the scenarios informed Tower’s
transition planning, they were not directly incorporated
into business strategy development which typically
operates on shorter time horizons. However,
consideration of the risks and opportunities associated
with climate change formed a key element of the FY25
Board Strategy sessions.
Analysis of climate conditioned data
In FY25 Tower procured climate conditioned flood
and sea surge data from our data partners to further
understand potential climate risks related to each
scenario. The data was based on the Representative
Concentration Pathways (RCP) and Intergovernmental
Panel on Climate Change (IPCC) Shared Socioeconomic
Pathways (SSP) used for each of our climate-related
scenarios and across our long-term time horizon.
The data assisted Tower to better understand the
implications of our chosen scenarios.
This enabled us to improve our assessment of potential
future risks to our customers’ properties and our
business and to test our strategy settings. The resulting
revised estimates of properties at high risk of future flood
and sea surge is lower than initial conservative estimates.
This suggests that our strategic approach of flood risk
based pricing has contributed to successfully lowering
our exposure to climate-related physical risks associated
with our portfolio. The FY25 expansion of risk based
pricing to include landslide and sea surge is recent and
yet to have shown an impact.
The above process and data were considered during
the development of the transition planning elements of
our strategy (page 26). They will also be used to inform
our future scenario review (FY26), climate-related risk
reviews and anticipated financial impacts.
CLIMATE STATEMENT 202513 Contents

Scenario architecture, socioeconomic pathways and rationale for selection
Tower’s climate-related scenarios build upon the ICNZ scenarios which were based, in turn, on the Network for Greening the Financial System (NGFS) scenarios. The below table sets
out Tower’s scenario architecture, how Tower’s scenarios align with relevant local and international socioeconomic pathway parameters and the rationale for selection.
Tower’s scenario architecture
ParametersOrderly 1.5ºCDisorderly >2ºCHothouse >3ºC
Global emissions and
socioeconomic pathway
parameters
Representative Concentration Pathway
(RCP) 2.6
Intergovernmental Panel on Climate Change
(IPCC) Shared Socioeconomic Pathway
(SSP) 1-2.6
RCP4.5
IPCC SSP2-4.5
RCP6.0
IPCC SSP3-7.0
Global physical risk
pathway parameters
Network for Greening the Financial System
(NGFS) Net Zero 2050
NGFS Delayed TransitionNGFS Current Policies
New Zealand-specific
emissions, transition and
socioeconomic pathway
parameters
NZ Treasury Shadow Price ‘High’ Pathway
Climate Change Commission (CCC) ‘Tailwinds’
Shared Policy Assumptions for New Zealand
(SPANZ) ‘100% Smart’
NZ Treasury Shadow Price ‘Medium’
Pathway
CCC ‘Headwinds’
SPANZ ‘Kicking, screaming’
NZ Treasury Shadow Price ‘Low’ Pathway
CCC ‘Current Policy Reference’
SPANZ ‘Homo Economicus’
Rationale for selectionMost commonly used scenario by financial
institutions globally.
Aligned with scenarios already selected by
ICNZ for the General Insurance Sector (and
other sectors).
Meets XRB’s requirement for a 1.5ºC aligned
scenario.
Commonly used scenario by financial
institutions globally.
Aligned with scenarios already selected by
ICNZ for the General Insurance Sector (and
other sectors).
Meets XRB’s requirements for a third
climate-related scenario.
Commonly used scenario by financial
institutions globally.
Aligned with scenarios already selected by
ICNZ for the General Insurance Sector (and
other sectors).
Meets XRB’s requirements for a
>3ºC scenario.
CLIMATE STATEMENT 202514 Contents

Tower’s climate-related scenarios
Our climate-related scenarios are summarised in the high-level data points and narratives below.
Orderly scenario – Net Zero 2050
This scenario explores Tower’s readiness to rapidly
transform its business in the short term towards
a low-emissions and climate-resilient future, and
envisions that by 2050...
New Zealand has invested in adapting to climate change
conditions, building the country’s resilience. As a result,
reinsurers remain in the region and view the growing
population as a growth opportunity.
The requirement to decarbonise and build resilience
rapidly put strain on some customers, resulting in
financial challenges. However, governments and the
financial sector helped to educate the general public on
climate, coupling innovative products and services with
transparency around pricing increases. This meant most
were open to new products that reflected different risks,
and social policies were in place to support those who
struggled to afford them.
The Pacific has benefitted from international support and
funding to improve its resilience, but sea level rise and
extreme weather events have impacted most nations.
Migration has meant that new talent with regional
knowledge has entered New Zealand’s workforce.
Collaboration across the Pacific region has been an
important driver of action against climate by government
and businesses, as has emerging technology.
Across the region, offerings like parametric insurance
and risk-based pricing emerged quickly, allowing
insurers to better cost their risk and provide realistic
cover to customers. New Zealand’s substantiated
‘clean, green’ reputation, alongside its embrace of new
technology such as AI, helped attract international and
domestic talent.
Organisations that were early, vocal actors in the
transition to a net zero economy benefitted from
positive sentiment from customers, communities
and stakeholders. Those that were able to fulfil and
substantiate their commitments enjoyed increased
market share. However, the window was small; those
that didn’t move quickly had to work harder to catch up
and transition.
While capital markets underwent a sharp-but-short
period of volatility and loss, organisations that prioritised
climate-smart resilience in their investment portfolios
were well-positioned to ride the post-transition wave.
Organisations that stepped into the challenge of climate
and diversified their offerings early were attractive
for investors.
Policy ambition:2050 warming:
<1.5°C1.6°C
NZ Pacific
Mean annual temperature
change 2050
1.6°C1.8°C
Mean sea level rise22cm20.4cm
Low
Moderate
Immediate & smooth
Medium
Fast
Medium
International and domestic policy settings aim
to limit total warming by end-of-century to less
than 1.5°C.
Severity of physical risk
Severity of transition risk
Policy reaction
Regional policy variation
Technology change
Carbon dioxide removal
CLIMATE STATEMENT 202515 Contents

Disorderly scenario – delayed transition
Global emissions peak in 2030, then drop sharply.
As a result of delayed action, deeply destabilising
policies are required to keep total warming below
potentially catastrophic levels.
The disorderly, delayed transition scenario explores
Tower’s resilience to an especially condensed and
disruptive transition in the medium term and depicts
a future whereby 2050...
The region (New Zealand and Pacific) is just starting
to recover from a costly, painful and profoundly
disruptive global transition to our low emissions,
climate-resilient economy.
General Insurers were deeply bruised by the scope
and scale of extreme flooding in 2037. However, most
business models cope with the physical impacts
of climate.
Without leadership from, and timely investment by
government, small insurers struggle to compete with
more innovative peers with global backing, in terms
of products, pricing models, regulatory compliance,
or reputation.
Some organisations were slower than others to
acknowledge or address the enterprise level risks that
climate posed to their business model and strategy.
Where different countries moved at different speeds,
those taking a compliance-led approach found their
response fragmented. Most organisations took several
years to understand the full potential of transition
plans and failed to achieve any first-mover (or even
fast-follower) advantage. This also meant customers
struggled to compare providers and understand how
to improve the resilience of their assets until later in
the transition.
Difficult decisions had to be made by organisations
that suffered reputational damage during the transition.
Streamlining business models and focusing on larger
markets meant insuring higher risk areas like the Pacific
became less feasible.
Policy ambition:2050 warming:
<2.0°C1.8°C
High
Low
Continuation of
current policies
Slow change
Low use
Low variation
NZ Pacific
Mean annual temperature
change 2050
1.8°C2.0°C
Mean sea level rise25cm22cm
Climate technology change
Severity of physical risk
Severity of transition risk
Policy reaction
Carbon dioxide removal
Regional policy variation
CLIMATE STATEMENT 202516 Contents

Current climate policies in New Zealand and
abroad are sporadic and weak. Any policy
changes are insufficient to limit total warming
to 2.0°C.
The hot house, current policies scenario was
designed to explore how the collective failure to
cut emissions might steadily erode value in the long
term. This scenario depicts that by 2050...
Startling new technologies (enabled by advances in
AI) have benefited insurers, their customers, and the
global economy. However, this formidable ‘tailwind’
has been overpowered by the cumulative impact of
increasingly intense and frequent natural disasters and
has not always been used for good.
Some assets have become stranded due to global
changes to climate policies and insurers that
were slow to capitalise on the opportunities that
presented themselves during the climate transition
are responsible for underwriting these with expensive
insurance products.
General Insurers have been particularly hard hit – though
less so in countries like New Zealand that benefit from a
relatively benign climate (as compared, for example, to
Australia). New Zealand also benefitted from the way in
which its government facilitated early adaptation to the
physical impacts of climate.
Customer needs are more bespoke due to the changed
environment with a greater need for specialist advice
and specialist policies. Offerings in regional markets
differ across insurance providers as the market for
insurance becomes increasingly unprofitable and
unaffordable for the average family. Data has become a
commodity and has increased drastically in price.
Insurers withdrew early on from high-risk areas in
New Zealand, leaving some communities stranded.
After some time and concurrent natural disasters, the
same approach is taken with the Pacific nations as they
become less viable and the long-term outlook is poor.
Policy ambition:2050 warming:
+3.0°C+2.0°C
High
Low
Slow change
Low use
Low variation
NZ Pacific
Mean annual temperature
change 2050
2.0°C2.0°C
Mean sea level rise39cm23cm
Hot house scenario – current policies
Climate technology change
Severity of physical risk
Severity of transition risk
Policy reaction
Carbon dioxide removal
Regional policy variation
Continuation of
current policies
CLIMATE STATEMENT 202517 Contents

Material climate-related
risks and opportunities
In the FY24 Climate Statement, Tower outlined the
development of climate-related risks and opportunities,
along with the assessment methodology. In FY25,
these risks were reviewed by the Climate Forum and
relevant risk owners. As a result of the review, minor
updates were made to risk descriptions, ownership and
responsibilities. Additionally, the consolidation of lower-
rated risks reduced the total number from 26 to 22.
Alongside the development of our three scenarios,
Tower selected three time horizons to assess the
related risks and opportunities. These time horizons
were selected to align with the ICNZ scenarios and
are independent of our business strategy and planning
cycles, which are based on a three-year forward-looking
view and reviewed annually. The time horizons chosen
were incorporated in the approach to the transition
planning elements of our strategy.
Time horizonPeriod
Short2023-2025
Medium2026-2035
Long2036-2050
CLIMATE STATEMENT 202518 Contents

Climate-related risks
In FY24 Tower identified 26 climate-related risks.
Following a review in FY25 by the Climate Forum
and designated risk owners, we consolidated those
to 22 climate-related risks. The change reflects the
consolidation of risks with overlapping scenario drivers,
ownership and mitigation strategies. Importantly, the five
inherently high risks disclosed, assessed in accordance
with our Risk Management Framework (see page 37 Risk
Management) remain unchanged. These risks continue
to represent the most material risks for the business and
its primary users and are included in the table below on
page 20.
Physical and transition risks
Physical risks, as defined in NZ CS 1, relate to the
physical impacts of climate. These risks can be:
• Acute, such as those related to large weather events
• Chronic, due to longer-term shifts in weather patterns,
such as changes in precipitation, temperature, or sea
level at a regional or national level.
Tower does not directly own or lease assets that are
materially vulnerable to acute or chronic climate-related
physical risks. However, our customers do, and the
potential risks to their assets – and the subsequent risks
to our business – have been identified and assessed
for disclosure. The customer-related risks comprise
the largest proportion of Tower’s material physical and
transition risks.
As New Zealand and the world transitions to a low
emission, climate-resilient economy, the context for
insurance will likely alter and present new challenges.
These challenges, defined as transition risks, include
changes in government policy, legislation, markets,
technology and societal behaviours and expectations.
Transition risks make up a larger proportion by number
of Tower’s climate risks than physical risks (59%). One
medium transition risk has been included as a sixth
risk alongside the five inherently high risks in the table
below. It was not rated as inherently high during the
original risk assessment in FY24 or subsequent review in
FY25 because it is considered current and ongoing with
established mitigation strategies to effectively manage
the risk. The likelihood of the risk arising is considered
to be in the medium term with early warnings likely.
However, it has been included in recognition of the
highly regulated environment for the insurance sector.
Tower will continue to monitor these risks and reassess
their materiality in line with our Risk Management
Framework. We also recognise that some risks can be
categorised as both physical and transition and this is
reflected in the material risks table below.
The following graph shows the distribution of risks
according to risk type and severity
Physical
& Transitional
TransitionalPhysical
3
2
1
2
1
1
8
4
Distribution of risks
High
Medium
Low
CLIMATE STATEMENT 202519 Contents

Identified climate-related risks and associated anticipated impacts
A description of our inherently high risks, their risk type, anticipated impact, existing mitigations and assessed magnitude
against each scenario and time horizon are detailed in the table below.
RiskRisk typeDescription
Anticipated
business impact
Current strategies
Regions
affected
Scenario
Time horizons
ShortMedLong
Operational stress
from climate
impacts.
High
Physical
Increasing extreme
weather events
subject Tower
to substantial
operational stress
related to resources
and overwhelm of
claims processes,
that reduces its
ability to adapt.
Operational stress
due to volume and
complexity of claims.
Reputational damage.
Lack of specialist
resource may affect
operational response.
Prioritising events
responses over
progressing business
strategy.
FY25 Head of Tower Natural
Disaster Response appointed
and dedicated event
response team in Claims
including dedicated Natural
Hazards Commission (NHC)
roles and training against
NHC for all claims roles.
Tower Large Event Response
Plan implemented and
tested against Scenarios.
New
Zealand
Pacific
Orderly
Disorderly
Hothouse
Significantly
larger scale and
more frequent
extreme weather
events in the
Pacific region.
High
Physical
Extreme weather
resulting in repeated
large loss events.
Providing
comprehensive
insurance in Pacific
markets becomes
unviable due to reduced
confidence of reinsurers,
and cost of insurance
cover.
Tower’s Underwriting
guidelines and risk appetite.
Introduction of Pacific Risk
surveys.
Parametric insurance
to diversify offering.
Efficient digital operations
to manage costs.
Divestment of Pacific
subsidiaries at high risk from
weather related large events.
Tower reinsurance program.
Pacific
Orderly
Disorderly
Hothouse
Legend:
Risk remains the same
Risk increasesContinuing to assess change
CLIMATE STATEMENT 202520 Contents

RiskRisk typeDescription
Anticipated
business impact
Current strategies
Regions
affected
Scenario
Time horizons
ShortMedLong
Financial stress
from climate
impacts.
High
Physical
Repeated large-scale
extreme weather
events subject
Tower to substantial
financial stress due
to high volume and
costs of claims.
Accumulated financial
losses.
Insufficient reinsurance.
Insufficient resources.
Higher costs of capital.
Reduced investor
support.
Enhanced hazard data
and risk selection, risk-
based pricing extended
to landslide and sea
surge in FY25 to minimise
exposure to high-risk
assets and communication
with reinsurers regarding
improvements to risk profile.
Including an allowance for
large events in financial
planning.
Ensuring we have adequate
reinsurance cover.
Product innovation such
as parametric to diversify
offering.
New
Zealand
Pacific
Orderly
Disorderly
Hothouse
Affordability
of reinsurance
diminishes
High
Transition
Reduced access to
reinsurance for all or
specific perils and at
short notice leads to
price increases.
Increased reinsurance
premiums.
Increased product
development costs to
offer alternative cover.
Risk based pricing –
as above.
Underwriting controls.
Multi-year catastrophe
reinsurance.
New
Zealand
Pacific
Orderly
Disorderly
Hothouse
Legend:
Risk remains the same
Risk increasesContinuing to assess change
CLIMATE STATEMENT 202521 Contents

RiskRisk typeDescription
Anticipated
business impact
Current strategies
Regions
affected
Scenario
Time horizons
ShortMedLong
Scope, speed and
scale of climate
physical and/or
transition impacts
outpaces Tower’s
ability to adapt.
High
Physical/
Transition
New Zealand and the
Pacific experience
multiple large
weather events in
quick succession,
flood risks and
coastal hazards
become frequent
occurrences
in increasing
geographies.
Diminished customer
experience leads to
brand and reputational
impacts.
Difficulty retaining
staff due to increased
workloads.
Financial impacts
resulting from claims
errors and/or reduced
customer growth.
Substantial increase in
operational costs for
data and technology,
models.
Capital shortages pose
challenges in optimising
opportunities.
Geographical distribution
of operations.
Digitisation to automate
processes and improve
customer experience.
Developing an agile culture.
Robust strategic and
financial planning to mitigate
financial risks.
New
Zealand
Pacific
Orderly
Disorderly
Hothouse
Legend:
Risk remains the same
Risk increasesContinuing to assess change
CLIMATE STATEMENT 202522 Contents

RiskRisk typeDescription
Anticipated
business impact
Current strategies
Regions
affected
Scenario
Time horizons
ShortMedLong
Government
intervention and/
or societal shifts
in behaviour.
Medium
Transition
High levels of
government
intervention.
Attraction and
attrition of skilled
employees.
Changes in
technology.
Changing motor
vehicle ownership
trends.
Changes in banks’
lending criteria.
Reputational damage
from unintended
consequences of
interventions.
Customer needs/
expectations outpace
product design as NZ
transitions to net zero.
Comprehensive
insurance cover becomes
unviable leading to
customer impacts.
Increased regulatory
pressure adding to
financial and human
resource constraints.
Closely monitor societal
trends such as Tower’s FY25
research ‘Weathering change:
attitudes to climate risk and
resilience in New Zealand.’
Product innovation/customer
propositions.
Participate in submissions on
government proposals.
Engagement with local
and central government
representatives directly and
via ICNZ.
Pricing transparency.
New
Zealand
Pacific
All
Legend:
Risk remains the same
Risk increasesContinuing to assess change
Medium Transition Risk
CLIMATE STATEMENT 202523 Contents

Material climate-related opportunities
While climate-related risks are front of mind when
developing climate strategy and mitigation, the scenario
analysis process also identified potential opportunities
for Tower. The material opportunities are outlined below
and have not changed from our FY24 Climate Statement.
These apply to all Tower’s climate-related scenarios,
across all time horizons in New Zealand and our
Pacific markets.
Our strategy to innovate will be increasingly important
as the transition to a low emission, climate resilient
economy presents the need for new products that
reflect societal and economic shifts. This is a key aspect
of the transition planning aspects of our strategy as set
out on page 26 below. One example of our innovation
is parametric insurance in the Pacific, which aims to
enhance insurance affordability and accessibility in this
market. While parametric insurance is currently only a
small part of our business and revenue, Tower sees an
opportunity to expand its market share in the future, both
in New Zealand and the Pacific.
We have also identified the opportunity to develop
industry partnerships that benefit customers and other
stakeholders, which could strengthen the insurance
industry’s future resilience. Examples of this include:
• ICNZ’s collaboration on government proposal
responses for climate adaptation and resilience.
• ICNZ’s collaboration to estimate emissions from
motor repairers, reducing the reporting burden
on these suppliers.
Tower FY25 climate-related opportunities
OpportunityOpportunity typeDescriptionBusiness impactCurrent strategiesTime horizons
Enhanced brand and
reputation.
TransitionNew products and
attractive pricing that
address affordability
issues and / or support
the transition to lower
emissions assets.
Supports growth
Enhanced brand
reputation
Parametric insurance
Risk-based pricing.
Working towards B-Corp certification.
Contributing to public discourse on climate impacts
directly and via sustainability and climate-change
focused corporate memberships.
Product innovation.
Short
Medium
Long
A more resilient
insurance industry.
TransitionIndustry partnerships that
may benefit customers
through efficiencies and
cost savings.
Supports efficiency for
insurers, ability to offer
improved pricing.
ICNZ collaboration on responses to Government
proposals i.e. Climate Adaptation Framework.
Completed ICNZ pilot to estimate emissions from
motor repairers.
Short
Medium
Long
CLIMATE STATEMENT 202524 Contents

Anticipated impacts
In FY24 Tower disclosed that we had begun working with
data suppliers to scientifically estimate the anticipated
increase in climate-related claims costs through to
2050. In FY25 we progressed this work and updated our
scenario analysis (as described on page 12 relating to
climate aligned sea surge and flood data) to model the
expected impacts on our future business.
The modelling used a ‘top down’ approach, taking
external data and trends from Tower’s climate-related
scenarios and applying these to Tower’s business with
assumptions spanning out to 2050 relating to:
• Population growth
• Dwelling growth
• Transition to Electric Vehicles (EVs) and vehicle
ownership rate assumptions
• Tower’s expected market share of target markets
• Growth of multi-unit dwellings
• Stormwater infrastructure investments
• Potential government interventions in the general
insurance market
Tower notes there is significant uncertainty in
assumptions spanning out to 2050. The benefit of using
a top-down modelling approach is to identify the factors
most likely to significantly impact Tower’s business
performance over the period. This model presented a
practical solution, considering available data, extended
time horizons, and systemic variables. This analysis was
applied across the three Tower scenarios.
The potential impacts for Tower to monitor are
summarised below:
• Financial and operational impacts from increased
frequency and severity of weather events across
NZ and the Pacific.
• Customer affordability challenges due to increasing
insurance costs (through increased weather
events, BAU frequency, increasing return on
investments costs).
• Government intervention to mitigate affordability
and/or insurance retreat.
• Societal shift in demand for products through
changing transportation trends such as increased
use of public transportation and uptake of EVs.
• Tower has continued working with data suppliers
to scientifically estimate the anticipated increase
in climate change-related claims costs through
to 2050.
CLIMATE STATEMENT 202525 Contents

Our approach
In FY25 Tower further developed our approach to
positioning the business as the world and more
specifically the markets we operate in transition towards
a low emissions, climate-resilient future state.
Tower’s approach to developing transition planning has
the following key foundations:
• Tower’s climate-related scenarios – our orderly,
disorderly and hothouse scenarios provided an insight
into the potential changes that could impact Tower’s
business as a result of a changing climate.
• Time horizons – Tower established short, medium and
long term horizons.
• Climate-related risks and opportunities – as noted
earlier in this report Tower has developed climate-
related risks and opportunities across each scenario
and timeline. These are central to our understanding
of strategic priorities across a long term outlook.
The timelines and process for Tower’s transition planning
development is outlined below:
• 2023/2024 Development of climate-related
scenarios, risks and opportunities and FY24 Climate
statement.
• July/August 2024 External training for key employees
on transition planning.
• November 2024 Legislation and literature review
(repeated periodically during FY25 based on
legislative or guidance updates and available
disclosures).
• November 2024 Sustainability and Climate Steerco
established a transition planning working group
and lead.
Identified
impacts
across
scenarios and
timelines.
Tower’s
current
climate
related
strategy
Risk &
Opportunity
Heat Map
Back casting
and Strategy
review
Priority
Transition
Topics
Vs
++=
• December 2024 ELT and Senior Leader training in
transition planning.
• February 2025 ELT transition planning workshop.
• March 2025 Board update and discussion on
transition planning.
• June 2025 2nd ELT Transition Planning Workshop.
• July 2025 Board Strategy days including a draft
overview of the transition planning aspects of Tower’s
strategy alongside a review of climate-related risks
and opportunities.
• November 2025 Final transition planning Audit
Committee and Board approval.
The process has been overseen by Tower’s Climate
and Sustainability Steerco with meetings held monthly.
Within the ELT Transition Planning workshops, the
following steps were taken:
The transition planning aspects of our strategy
CLIMATE STATEMENT 202526 Contents

Transition planning aspects of Tower’s strategy
Climate change presents material risks and opportunities for Tower. By continuing to strengthen our data and insights, we
can advance our climate commitments and unlock innovative solutions that better meet the evolving needs of our customers.
Furthermore, as customers increasingly seek climate-conscious brands. Tower’s commitment to climate action positions us to
align more closely to their values and expectations. Set out below are the actions we are targeting in each time period.
• Develop climate-related risks
and opportunities, strategy
and transition.
• Introduction of risk-based
pricing (flood, sea-surge,
landslide).
• Transparent hazard ratings.
• Large events resilience/
processes.
• Operational/geographical
diversification.
• Operational, claims,
efficiency, digitisation & BCP –
enhancements.
• Pacific Parametric.
• Plain English policies.
• 1st sustainability strategy
period/Forsyth-Barr “Fast
Follower” C&ESG rating.
FY20 – FY25
• Expand risk-based pricing &
customer transparency.
• Supply chain digitisation &
procurement strategy uplift.
• Government policy & public
engagement.
• Scope 1 & 2 emissions
reduction plan, Scope 3 data
visibility.
• 2nd Sustainability strategy
FY26 – FY30.
• Expand risk-based pricing
customer transparency.
• Evolve products &
propositions.
• Proposition to support
adaptation/managed retreat.
• Implement emissions
reduction plan.
• Climate adaptation public
engagement.
• Demonstrate improvement in
operational footprint.
FY26 – FY27FY28 – FY29
• Propositions to support low
emissions & resilient NZ &
Pacific economies.
• Propositions to support
continued provision of
affordable insurance.
• Further improve systems &
data collection, to improve
value chain visibility &
resilience.
FY30 – FY39
• Low emissions & climate
resilient:
• operations
• underwriting portfolios
• supply chain
• Investment portfolio supports
low emissions economy.
FY40 – FY50
Climate hazard data & capability
Innovative, adaptive, flexible culture
Climate innovation
Climate resilient value chainResilience & efficiencyTransform & innovateLow emissions value chain
CLIMATE STATEMENT 202527 Contents

The transition planning work and development of Tower’s approach supported the existing business strategy direction in providing a good foundation for a climate-resilient future. In
the Tower Business Model and Strategy section of this climate statement we highlight four main approaches which remain the core components of the transition planning aspects of
our strategy:
Time horizonDetail
FY26-FY29
Transform & innovate
Over this four-year period, Tower intends to build on its existing strategic direction to support a low-emissions, climate-resilient future. In the
first 12 months, Tower will continue implementing its expanded risk-based pricing model, which now includes sea surge and landslide risks. As
customers renew their policies, they receive updated pricing aligned to their individual property’s sea surge and landslide risks. Alongside this,
we will continue to enhance customer transparency by providing individual property risk ratings through our online quote tool. At launch Tower
communicated with a range of stakeholders including representatives from local and central government to help broaden understanding of risk-
based pricing and advocate for improved climate change adaptation planning and will continue these conversations.
Tower also plans to investigate further enhancements to risk-based pricing, including the potential inclusion of windstorm risk, a rollout of the
pricing strategy across Pacific markets, and the extension of risk-based pricing for natural hazards to contents insurance.
This period is expected to see continued investment in digitisation and streamlining the customer experience across the insurance lifecycle.
Tower plans to maintain active engagement with government agencies and policymakers. Tower is committed to providing expert advice and
insurance insights to government representatives on the likely impacts of proposed interventions in New Zealand and the Pacific and support
informed decision making. We intend to advocate for sensible actions that safeguard our customers and communities.
In the latter part of this strategy period, Tower intends to continue evolving its product and proposition offerings to incorporate low-emissions
and climate-resilient features. We will also explore new opportunities for innovation and collaboration that support climate adaptation. Alongside
this, Tower expects to advance its data and technology capabilities to improve pricing, underwriting, and operational efficiency—particularly
during large-scale events—and continue developing initiatives that help address affordability challenges.
FY30-FY39
Climate resilient
value chain
This period has been identified for the continued development of initiatives introduced in the prior period, with a focus on enhancing products
and propositions that support customer and community resilience across all operating regions. Potential initiatives developed in the prior period
will be reviewed and refined periodically to enable implementation when market conditions are appropriate. In this period Tower expects
to also step up its focus on exploring opportunities to reduce emissions within its supply chain, with further detail to be developed over the
coming period.
FY30-FY40
Low emissions
value chain
Tower’s long term ambition is to support a low emissions value chain from customer policies to our claims and operational supply chains. We
expect that the foundations to support a low emissions economy will have been established in our FY20 to FY25 period as illustrated above and
will be continued over the subsequent strategy periods.
CLIMATE STATEMENT 202528 Contents

Capital expenditure and investment
As a general insurer, managing climate-related risk is a
core component of Tower’s business as usual activities.
Tower invests in enhancing our natural hazard modelling
and pricing capabilities annually.
During Tower’s annual strategic planning process,
executive leaders evaluate material risks and
opportunities, and strategic decisions. These are then
escalated to the Board for oversight, guidance and
investment decisions. This process includes assessing
climate-related risks and opportunities, which in recent
years has led to investments in parametric insurance
and risk-based pricing. The Board approves funding for
further proposition, investigation and development, and
considers initiatives for inclusion in the business strategy
and annual business plan.
Tower’s transition plan includes initiatives that require
capital expenditure or project funding, which is allocated
as part of Tower’s annual planning cycle. Transition
aspects of Tower’s strategy that are aligned with its
internal capital deployment and funding decision-
making processes will likely change annually but
are expected to include: investments that improve
Tower’s ability to respond to insurance claims arising
from weather related events, purchase of reinsurance
to mitigate insurance risks of weather related events,
investments in developing risk-based pricing and
climate related product innovation, memberships
and subscriptions to groups that advocate for climate
related policies, investment in upgrades to Tower’s
workspaces or equipment to lower emissions,
expenditure on systems that allow for better climate-
related reporting and changes to procurement policies
and processes to better engage with supply chains on
climate-related matters.
Underlying each period of transition planning are key
internal capability uplift and innovation periods. Looking
forward these are:
Climate hazard data and capability – Tower continues
to invest in up to date hazard data in order to uplift our
risk based pricing approach and customer transparency.
Alongside our customer focused work we will continue
to build our internal capability, skills and understanding.
This includes providing and supporting employee
training and upskilling relating to climate science, large
events, risk-based pricing and customer communication.
Innovative, adaptive and flexible culture – Tower
recognises that a key element of climate resilience and
low emissions operations is an informed and adaptive
culture. This requires us to support innovative thinking
and the capability to move swiftly with a changing
climate and the potential for large and frequent weather
events or changes in policy and regulation.
Climate innovation – in order to move towards a low
emission future it will be crucial to find innovative and
novel methods to remove emissions from Tower’s value
chain. We will continue to monitor opportunities in
this area.
Tower will continue with our existing core business
model and strategy with the key elements integrated
into our transition planning. Initiatives included in time
horizons beyond FY28 will be reviewed alongside
strategic planning development.
The annual purchase of reinsurance to manage the
financial impacts of large events, including potential
climate-related events, is considered under Tower’s
reinsurance strategy and approved by the Board.
Tower’s capital level is influenced by loss history, which
in turn can be influenced by climate related risks
and impacts. Capital requirements are determined
by the products we develop and sell, and the risk
levels associated with those assets. For instance, a
house insurance policy requires Tower to hold more
capital than a motor insurance policy, due to higher
replacement costs. As the industry transitions to a
low-emissions, climate resilient future, expanding into
different asset classes, will result in different capital
requirements. These decisions are made in accordance
with Tower’s capital management process.
Tower has an annual operational budget for sustainability
initiatives and compliance with the Climate-related
Disclosures (CRD) regime. This includes the costs of
measuring emissions, consultancy support, and climate
and sustainability training.
CLIMATE STATEMENT 202529 Contents

Our greenhouse gas (GHG) emissions
Tower has been measuring its GHG emissions since
FY20 in accordance with the requirements of the
‘Greenhouse Gas Protocol – A Corporate Accounting
and Reporting Standard (2004)’. Tower applies the
operational control consolidation approach to account
for emissions, with emissions reported in tonnes of CO
2
equivalents, in line with the requirements of the Aotearoa
New Zealand Climate Standards.
Updates to the GHG Inventory methodology
in FY25
1
To date our GHG inventory has included Scope 1 and
2 emissions for New Zealand and Pacific operations
and selected Scope 3 emissions as detailed below.
During FY25, the data quality and methodologies
associated with the development of our FY20 base
year and subsequent periods were reviewed and the
associated improvements and restatements are detailed
in Appendix 4. This review has allowed us to understand
keys trends in our emissions value chain and identify
opportunities for future efficiencies and reductions. A
Greenhouse Gas Management Framework and Standard
Operating Procedures have also been developed to
improve the control environment surrounding the
collection, and processing of activity data. We have
continued to apply adoption provision 4 of NZCS 2 which
exempts Tower from disclosing all Scope 3 material
GHG emissions. Tower has chosen to disclose a subset
of Scope 3 emissions in line with previous annual report
inclusions – please see Appendix 4 for the sources that
have been excluded this year. The methods, assumptions
and estimations used in calculating our GHG emissions
are also included in Appendix 4.
Boundary approach
Tower applies the operational control approach to
its organisation and includes emissions generating
activities from all operating countries. This approach
has been developed in line with the guidance outlined
in the Greenhouse Gas Protocol. With respect to leased
buildings, Tower has included the direct emissions under
its operational control.
Materiality
During FY25 a materiality assessment was conducted
to understand our value chain further, this has allowed
us to identify material emission sources and develop
methodologies to obtain data for future reporting
periods. We have set our materiality threshold at 5% of
total emissions for the applicable Scope.
1 Total Scope 1 and Total Scope 2 GHG emissions for the year ended 30 September 2025 as disclosed in the table on page 32, are subject to limited assurance by PwC.
Refer to the PwC assurance report on page 59.
CLIMATE STATEMENT 202530 Contents

Business travel: flights and accommodation –
NZ and Pacific, taxis and rental vehicles – NZ
only
Employee commute – NZ and Pacific
Work from home – NZ and Pacific
Waste – NZ only
Purchased goods and services: paper use –
NZ only
Water supply – NZ and Pacific
Calculation of emissions relating to our
underwriting portfolio
Purchased goods and services – ICNZ
collaboration to pilot the assessment of
motor repair provisions related to claims
Assessment of investment emissions
Purchased goods and services – assessment
of supply chain emissions
The following illustration summarises relevant emissions sources for Tower’s operations (it does not depict all potential
emissions sources and includes sources that may be reported in future years).
Scope 3 Upstream indirect emissions
Scope 3 Downstream indirect emissions
CLIMATE STATEMENT 202531
Legend for icons provided in following tables.
Scope 3
Upstream
Indirect Emissions
Scope 1 & 2
Direct Emissions
& Purchased electricity
(heating and cooling)
Scope 3
Downstream
Indirect Emissions
Contents

The following table summarises Tower’s Greenhouse gas emissions (tCO
2
e
1
) from our FY20 baseline year to the FY25 reporting period.
FY20FY21 FY22 FY23 FY24FY25
Scope 1
Mobile Combustion129 115 120 140 136 131
Stationary Combustion19 17 - - -
Fugitive Emissions- - - - 28 11
Total Scope 1
2
148 132 120 140 164 142
Scope 2
Purchased Electricity
(location-based)
217 176 146 158 147 136
Total Scope 2
2
217 176 146 158 147 136
Total Scope 3
3, 4
209295202183742859
1 Tonnes of Carbon Dioxide equivalent (tCO
2
e) = unit of measurement for combined GHG emissions represented as carbon dioxide.
2 Total Scope 1 and Total Scope 2 GHG emissions for the year ended 30 September 2025 as disclosed in above table, are subject to limited assurance by PwC. Refer to the PwC assurance report on page 59.
3 NZCS 2 Adoption Provision 4 has been applied, with Scope 3 Categories 2, 4, 8 and 15 excluded and Scope 3 category 1 partially excluded due to current data limitations, evolving methodologies, and standards.
4 FY20-23 no employee commute emissions, work from home, Pacific water, Pacific wastewater, and Pacific T&D losses. FY20-24 no well-to-tank emissions.
Scope 3 emissions have been aggregated to provide a total for our reported subset of operational emissions. This includes paper usage, water supply, wastewater, business travel,
employee commute and work from home and fuel and energy related activities not included in Scope 1 & 2.
GHG emissions
CLIMATE STATEMENT 202532 Contents

In FY25 the largest proportion of Tower’s GHG emissions
were related to how we travel. In our second year
of undertaking an employee commute survey we
calculated associated emissions at 45% of our total
footprint. The operation of our New Zealand and Pacific
fleet vehicles accounted for 11% of total emissions while
20% is associated with business travel including flights,
accommodation, taxis and rental cars.
We also added well-to tank emissions for purchased
electricity and fuel this year which increased fuel and
energy related activities not included in Scope 1 and 2 to
7% of total emissions.
The chart below shows the breakdown of
Tower’s GHG emissions by source.
Employee commute
Business travel
Purchased electricity
Vehicle fleet
Fuel- and energy-related
activities (Scope 3)
Working from home
Refrigerants
Paper
Waste and water
Scope 1 and 2 emissions are also calculated as an intensity figure using our total risk numbers as the key indicators
1
.
The intensity results from our baseline year, FY24 and FY25 are outlined in the table below.
2
The Group emissions
intensity per policy show a gradual decrease to FY25. The decrease is related to maintaining policy numbers while
reducing emissions.
Emissions intensity in
tCO
2
e/risks insured (000s)
FY20FY24FY25
NZ intensity0.320.220.21
Pacific intensity 4.484.744.03
Group intensity0.660.500.44
1 Calculated as Scope 1 & 2 emissions divided by average risk count for the year. In this context risk refers to the specific addressable property or risk covered by an insurance
policy, e.g., the house, the motor vehicle, or a period of overseas travel. The Pacific intensity figures include emissions for the Suva hub which provides services in relation to
NZ policies.
2 Intensity figures for the financial year FY21 to FY23 were included in the FY24 Climate Statement. In FY25 Tower has decided to disclose the required base year, current and
previous years figures. Tower do not believe the intervening years add materially to primary users’ understanding of performance.
In Tower’s FY24 Climate Statement we outlined our participation in an ICNZ/Cogo pilot to calculate claims emissions
from motor repair services. The pilot with Cogo has been concluded and the working group is considering the next
stage of the collaboration.
Our fleet vehicles are crucial for our claims and assessing
teams to meet the needs of our customers. Our business
travel enables us to remain connected across our
geographical locations with colleagues and business
partners and our employee commute emissions reflect
our people’s journeys to work. As a result, our approach
to emissions reduction needs to maintain our service
value in these areas. Initiatives to reduce emissions
associated with these sources are provided in the table
on page 35.
CLIMATE STATEMENT 202533 Contents

Tower set an absolute, science-aligned reduction target
of 21% for our Scope 1 and 2 emissions by the end of
FY25, using FY20 as the base year. We are happy to
report we have met our reduction target, with a 24%
reduction of Scope 1 and 2 emissions from the FY20
base year and an 11% reduction since FY24.
During FY25 we revised our target for the period FY26
to FY35 against a 1.5°C global warming ambition using
a science-based methodology. Our new absolute
target for FY26 to FY35 is a 63% reduction of Scope
1 and 2 emissions on a base year of FY20. The nine
year target period was selected to enable us to adopt
evolving technologies and capabilities particularly in our
Pacific territories.
Our FY20-25 target and our new FY26-FY35 target
were established based on the Paris Agreement goal to
limit global warming to 1.5ºC. The Paris Agreement goal
(UNFCCC 2015) requires emissions to peak before 2025
at the latest and decline 42% by 2030. Tower calculated
our reduction trajectory to 2035 on the basis of this
ambition and utilising the Science-based Target Initiative
publicly available Corporate Near-Term Target Setting
Tool (version 2.3).
In taking responsibility for our emissions, our preferred
approach is to invest in initiatives to reduce gross
emissions as much as possible. Therefore, there are no
offsets applied to our FY20-FY25 target, and our revised
FY26 target does not rely on offsets.
In our FY24 Climate Statement Tower indicated that
we would explore the viability of an intensity-based
metric and target and consider extension to Scope 3
emissions. In the development of our FY26 to FY35
target intensity-based options were considered but were
not found to adequately represent Tower’s operational
footprint. Tower has opted to use the extended adoption
provisions related to Scope 3 emissions and will not be
setting targets against these.
0
50
100
150
200
250
300
350
400
450
FY25FY24FY23FY22FY21FY20
tCO
2
e
Scope 1 & 2 target
Actual emissions
Current GHG target and tracking scopes 1 & 2
GHG emissions target
CLIMATE STATEMENT 202534 Contents

ScopeInventory itemDetailFY24FY25
1
Vehicle fleet fuelTower Policy to only purchase or lease hybrid, plug in hybrid or fully electric vehicles. NZ
vehicles fully transitioned to hybrid in FY25. This corrects our disclosure of FY24 in which
we indicated full transition to hybrid following the availability of more detailed information
regarding leased vehicles within our contract. Pacific Island vehicles partially transitioned.
Full transition in the Pacific is limited by the current cost of hybrid vehicles as well as
charging and servicing infrastructure for EVs and a requirement to access isolated areas.
136 tCO
2
e131 tCO
2
e
2
ElectricityGreenstar Auckland office, Suva meter recently installed and actual data obtained for all
offices since April 2025.
147 tCO
2
e136 tCO
2
e
3
Business travelTower’s Sustainable Travel Policy includes an intention (without a target) to reduce air
travel. Tower makes efforts to travel to the Pacific only when necessary.
197 tCO
2
e228 tCO
2
e
Waste (landfill)Employee initiatives such as Plastic Free July to encourage waste minimalisation.
Permanent soft plastic recycling, bottle cap and lid recycling now available at the
Fanshawe Street office. Waste volumes have increased in line with increased staff
numbers and office attendance.
8 tCO
2
e7 tCO
2
e
Employee commute/
WFH
Second year employee commute survey completed providing average emissions per
employee related to both commute and work from home.
501 tCO
2
e (employee
commute)
29 tCO
2
e (WFH)
521 tCO
2
e (employee
commute)
38 tCO
2
e (WFH)
2nd & 3rd year supply
chain
In FY24 we indicated a review of existing ESG supplier requirements to include material
emissions reporting. This work is progressing through engagement with key suppliers to
support year 3 disclosures.
2nd & 3rd year
underwriting
In FY24 we disclosed our work to develop underwriting emissions with Generate Zero. This
work is progressing in preparation for future disclosure requirements.
Tower has continued working towards reducing our
Scope 1 & 2 emissions. A key focus of FY25 was to
improve the quality of emissions reporting to drive future
efficiencies and reductions. Since 2022, Tower has had
a policy commitment to purchase and lease only EVs or
hybrid vehicles in New Zealand. In our Pacific locations,
our fleet remains primarily internal combustion engine
(ICE) vehicles.
Our emissions reductions initiatives
We recognise that electricity generation in the Pacific
Islands is primarily fossil fuel-based and therefore
conversion to hybrid or EVs is unlikely to generate the
same emission reductions as our New Zealand fleet.
However, there are parallel benefits to moving away
from petrol or diesel vehicles in all locations, including
lower running costs and supporting improvements in
local air quality.
The table below outlines completed or ongoing
emissions calculation and reductions initiatives for
FY24 and FY25. Initiatives slated for completion in
financial year FY25 and disclosure in our second climate
statement are highlighted in cyan.
CLIMATE STATEMENT 202535 Contents

TypeDescriptionMetricFY24 estimatesFY25 estimates
Transition risksAmount or % of assets or business activities vulnerable to
transition risks
% of vehicles insured that are internal combustion
engines (ICEs)
91%88%
Physical risksAmount or % of assets or business activities vulnerable to
physical risks.
% of homes insured that are high flood risk13%2.6%
Opportunities –
Current
Amount or percentage of assets, or business activities aligned
with climate-related opportunities.
% of electric vehicle (EV) and plug-in hybrid (PHV)
vehicles covered
9%12%
Capital
deployment
Capital deployment has been calculated as the operational and
capital expenditure in FY25 on specific projects/initiatives that
the Sustainability and Climate Steerco has determined as being
climate-related activities, including the expansion of risk-based
pricing to cover sea surge and landslide perils, the transition
of Tower’s motor vehicle fleet and the preparation of climate-
related disclosures. This expenditure does not include salaries
for permanent staff who may spend part of their time generally
working on sustainability and climate topics.
Capital or operating expenditure deployed towards:
• Risk Based Pricing
• Parametric
• Sustainability
• CRD
• Fleet transition
Approx $769KApprox $4.1m
Internal emissions
price
Price per metric tonne of CO2e used internally by an entity.In FY24 Tower indicated that no internal emissions price was established. Following review in
FY25 no internal emission price will be set.
RemunerationManagement remuneration linked to climate-related risks and
opportunities in the current period – %, weighting, description
or amount of overall management remuneration.
ELT objectives and targets include climate-related measures where relevant to the
responsibilities of their business units. Select executives’ short-term incentives incorporate
climate-related objectives, including delivery of climate-related financial disclosures,
integration of ESG goals into procurement and supplier management, development of risk-
based pricing for climate hazards, and creation of sustainable insurance products for Pacific
markets. A proportion of select executives; remuneration is also linked to initiatives that
reduce emissions, improve climate data reporting, and help to model future climate impacts
on portfolios. A specific weighting, percentage or amount is not provided as this varies
according to the executive role and responsibilities.
1 Limitation for use of flood risk ratings - the definition of “High Flood Risk” is Tower’s own definition and not necessarily a consistent definition with any other public source. Specifically, it relates to insurance risk and cost to repair or replace property relative to the risk of
flooding and not just the chances of flooding happening alone. It also relates to Tower’s own risk appetite and what we consider is “High”, which may differ to others risk appetites or interpretation of the level of risk.
Tower uses various metrics and tools to manage our business risk indicators, including those relevant to climate-related risks and opportunities and our GHG emissions. Our approach
to establishing metrics is described in our FY24 Climate Statement.
The metrics remain unchanged and have been updated for the FY25 period. There are no New Zealand insurance industry based metrics.
Targets related to GHG emissions are provided in Section 5 above.
Measuring our performance
CLIMATE STATEMENT 202536 Contents

Risk management is central to Tower’s strategic and operational activities and is
underpinned by Tower’s enterprise-wide Risk Management Framework (RMF). The RMF
is approved by the Tower Board and applies to all Tower employees and operations. The
RMF was reviewed in October 2024 with minor updates made.
Risk management
Risk appetite statement
People
Risk & control
assessments
Obligations
management
Risk governance
Processes
Risk
registers
Fraud risk
management
Capital management process
Systems
Incident reporting
& remediation
Operational
resilience
Primary risk
framework enablers:
Secondary risk
framework enablers:
Risk management
process:
Enabling foundations:
Respond to riskMonitor, assure,
escalate
Assess riskMeasure riskIdentify risk
The RMF sets out guiding principles to enable Tower to identify, assess, monitor and
manage its risk exposures to pursue its strategic objectives. The RMF and its key
components are depicted below:
CLIMATE STATEMENT 202537 Contents

Fundamental to the application of the RMF is Tower’s
Risk Appetite Statement (RAS), which outlines the
Board’s risk appetite against key categories defined in
the RMF. Tower’s Board Risk Committee is responsible for
monitoring the adequacy of the RMF, receiving reports
on key risks, exposures and their management against
the RAS.
The primary executive governance forum for the
RMF is the Tower Management Risk and Compliance
Committee (MRCC) which meets monthly and is
governed by an annually reviewed Charter overseen by
the Chief Risk Officer (CRO).
The RMF is implemented through risk, compliance,
conduct and internal audit processes across each
business function. The executive, senior management
and staff must demonstrate that reasonable steps have
been taken to effectively manage Tower’s risks in line
with the RMF. Responsibilities are assigned to individuals
to manage identified risks, and material changes to
Tower’s risk profile are monitored.
Each business unit within Tower maintains a risk register
that records the likelihood and consequence of risks,
actively identifying, assessing and monitoring the risks
and associated controls. These risks are recorded,
maintained and managed within our Protecht risk
management software platform with clear identification
of the risk owner, inherent risk, risk mitigation(s) and
residual risk scores.
Risk owners are responsible for updating their risks
whenever changes occur that may alter the inherent or
residual risk score. To ensure regular reviews, each risk
is assigned an agreed time period for review. These time
periods may range between 6-monthly and 2-yearly.
The Protecht platform also enables the prioritisation
of all risks, ensuring appropriate escalation in a timely
manner. Risks are prioritised as Low, Medium or High
residual risk status. High residual risks are given priority
for suitable mitigation and raised to the Board for
acceptance or deployment of capital if the risk cannot be
effectively mitigated, and then closely monitored.
Integration of climate risks
in Tower’s Risk Management
Framework
Tower revised its RMF in February 2024 to include
climate-related physical and transition risks as a specific
risk category along with the other key risks facing
Tower across its full value chain. Tower also introduced
a dedicated Climate Risk Forum to regularly review
and monitor its climate risk profile. Additionally, in early
2025 Tower revised its risk assessment matrix to enable
a more focused approach to risk assessment across
the business.
In FY25, the process undertaken by Tower to assess
climate-related risks followed the approach outlined
under the RMF, as follows:
1. Identify
2. Measure and Assess
3. Respond
4. Monitor, assure and escalate
Identify
In 2024, Tower conducted a cross-functional workshop
to consider the climate risks and opportunities as part
of the climate scenario development and analysis. The
workshop and subsequent internal analysis included all
material elements of Tower’s value chain, covering both
New Zealand and Pacific-based operations, as well as
our core supply chain. Some 42 climate related risks and
opportunities were identified during this exercise.
Measure and assess
The identified risks served as the basis for further internal
stakeholder meetings to:
• Refine the risks
• Assign ownership
• Identify key impacted business units
• Complete initial risk and control assessments across
the short, medium and long-term time horizons with
the same duration outlined in the Strategy section.
• Agree appropriate controls against each risk to
mitigate the impact of the risks occurring
CLIMATE STATEMENT 202538 Contents

The data was also divided into specific areas to illustrate
Tower’s overall climate risk profile across each scenario
and time horizon (as detailed within the Strategy section):
• Key Impacted Business Units – by climate related risks
• Climate Risk Categories – Transition & Physical Risks
• Climate Risk Ratings – high, medium, low
• High Inherent Risks – measured under the three
climate-related scenarios and three time horizons.
Respond
Tower’s response considered each of the climate-related
risks and assigned controls against them to arrive at
a residual risk rating. In line with Tower’s RMF, where a
residual risk is High and cannot be managed through the
control environment, it is reported to the Tower Board
for risk acceptance or otherwise. No climate-related
risks have been identified as unable to be managed
effectively through appropriate controls and actions.
Accountability for managing these risks is assigned to
Tower’s executives and senior management. The suite of
risks provides an overall climate-related risk profile for
Tower and facilitates the monitoring of those risks over
time. Where the nature of the risk changes, the response
to managing that risk may change also.
Monitor, assure and escalate
Due to the nature of Tower’s business and our risk-based
pricing approach, climate-related risks make up five of
our high residual risks. All five of these climate-related
risks have actions in place to monitor and help mitigate.
All material climate-related risks across each of the
identified scenarios and time horizons (as detailed
within the Strategy section) have been recorded in
Protecht and are reviewed as part of the usual cycle of
risk reviews within each business unit. The Climate Risk
Forum will assist in regular monitoring of the climate risk
landscape and is described on the right.
A comprehensive review of identified risks and
opportunities will be undertaken annually and following
any updates to Tower’s climate-related scenarios.
The Climate Risk Forum
The purpose of the Climate Risk Forum (CRF) is to
facilitate discussion, collaboration, and action on
climate-related risks and opportunities.
The CRF convenes internal stakeholders from
various teams to review and share knowledge,
best practices, and innovative solutions. Its goal
is to ensure identified climate-related risks and
opportunities remain current and relevant, and to
address the challenges posed by climate.
The CRF is composed of climate risk owners
and the Sustainability Manager, with subject
matter experts (SMEs) attending as required. In
FY25 The CRF met on two occasions to review
Tower’s climate-related risks and opportunities.
As identified on page 18 the review resulted in
minor updates to risk ownership and mitigation
tools. In addition low and medium risks were
consolidated to reduce the overall number of risks
from 26 to 22.
Climate-related risks are considered over the
short, medium and long-term time horizons
identified in the Strategy section page 5.
CLIMATE STATEMENT 202539 Contents

Strong governance underpins our management of
climate-related risks and opportunities.
Tower’s Board of Directors provides leadership within
a framework of prudent and effective controls,
enabling the assessment and management of Tower’s
risks and opportunities, including those that are climate-
related. The Board composition is provided in our 2025
Annual Report.
Details of our governance of climate-related topics in
FY25 are detailed in the table on page 42.
Governance
Governance framework
The Board is responsible for approving and overseeing
Tower’s ESG strategy and reporting. This includes
considering sustainability strategies and oversight of
Tower’s climate-related risks, including physical and
transition risks, and climate-related opportunities
as relevant to Tower’s broader business strategy.
Our material climate-related risks and opportunities
were included in the July Board Strategy sessions
through discussions relating to risk based pricing,
large events preparedness and transition planning.
The Board retains overall accountability for the
development and ownership of climate-related
strategy, transition planning, metrics and targets and
climate-related disclosures.
The Board is assisted in its oversight by its Audit, Risk and
People, Remuneration and Appointments Committees.
Additionally, Tower’s Executive Leadership Team
(ELT) led by our CEO, and topic specific management
committees and forums, sponsor and direct key
elements of our climate statement development. The
roles and responsibilities of each of these bodies,
along with key milestones over the reporting period are
provided in the table on page 42.
In FY24, the Board approved a Climate and Sustainability
Governance Framework, establishing the Company’s
structures and processes for effective oversight and
management of climate-related risks and opportunities.
The framework was revised in FY25 to reflect changes
to management forums and approved in March with the
addition of the Portfolio Performance and Investment
Committee (PPIC). The following diagram illustrates the
key roles, responsibilities, communication, and decision-
making processes that support the Board in fulfilling its
climate-related governance obligations.

CLIMATE STATEMENT 202540 Contents

Climate, sustainability governance framework
Submits
workstream
outputs for
approval and
feedback.
Provide
updates on
performance
against
strategy
development,
metrics and
targets,
submit draft
disclosures
for approval.
FeedbackFeedbackFeedback
Tower Board - overall accountability for overseeing climate-related risks and opportunities, and Tower’s strategy
Audit Committee

Recommends approval on:
Climate change & ESG, scenarios, risks
and opportunities, metrics and targets,
performance and disclosures.

Recommends approval
on: Climate change
& ESG related risks.

Assists with: Board
and Management
and competencies.
Risk Committee
People, Remuneration
and Appointment Committee

Submit Strategy, risks,
opportunities and climate
statement.

Submit Strategy, risks,
opportunities and climate
statement.

Inform intentions for
training and resourcing.
Executive Leadership Team
Sustainability and Climate Change Steerco
Management Forums and Committees
CLIMATE STATEMENT 202541 Contents

Governance bodyRoles and responsibilitiesActivity
Tower Limited Board
of Directors
Provide oversight and approval for the Company’s environmental and social governance
obligations, including consideration of sustainability strategies, climate-related
physical and transitional risks and opportunities and all disclosures in the company’s
Climate Statement.
Monthly progress update on sustainability and CRD through
regular content in the CEO report. This includes updates
on workstream activities, risks, opportunities, strategy and
transition planning, resourcing, and updates from the Steerco
on performance against metrics and targets.
March 2025 CRD update including intended FY25 Board
and Committee schedule, progress to delivering FY25
Climate Statement, approach to transition planning approval
of reviewed CRD Governance Framework and delivery of
Board training material on Tower’s climate-related legal
requirements and GHG emissions requirements.
May 2025 Update on Sustainability, Climate and GHG
emissions progress against plan.
July 2025 Draft transition planning aspects of Tower’s strategy
submitted for approval.
Director annual skills and capabilities survey (including ESG
and climate capabilities) completed.
November 2025 Approval of the FY25 Climate
Statement, transition planning, metrics and targets on the
recommendation of the Audit Committee.
Tower Limited Pacific
subsidiary Boards
Part of Tower Group GHG emissions reporting covers Pacific activities. As Tower’s
approach matures, Management is increasing its engagement with the Tower Limited
Pacific subsidiary Boards on climate-related topics.
May 2025 Overview of CRD and Sustainability provided
which included legislative obligations and key climate and
sustainability updates for Tower Limited.
Audit CommitteeThe Audit Committee assists the Board by:
• Overseeing climate-related disclosures and the adequacy of control systems for
climate-related reporting.
• Reviewing climate-related scenarios, risks and opportunities, metrics and targets, and
disclosures, and recommending Board approval.
• Agreeing on the scope of the external auditor’s limited assurance of GHG emissions
for the climate statement.
May 2025 Approval of GHG assurance auditor appointment.
November 2025 Recommend approval of FY25 transition
planning, metrics and targets and GHG restatements and
disclosures to the Tower Board.
No reviews or approvals were required for climate-related
scenarios, risks and opportunities in FY25 as no material
changes were made.
The Board reviewed and approved an updated Climate and Sustainability Governance Framework in March 2025. Throughout the year, the full Board considered elements of the
climate-related disclosure development on behalf of its committees to ensure progress within desired timeframes. The requirements of the framework were put in place in FY25.
Table of Governance bodies, frequency of meetings, their roles and responsibilities
CLIMATE STATEMENT 202542 Contents

Governance bodyRoles and responsibilitiesActivity
Risk CommitteeThe Risk Committee assists the Board by:
• Monitoring climate-related risks.
• Assessing the effectiveness of Tower’s Risk Management Framework, strategy, risk
appetite, and risk profile. Ensuring compliance with relevant prudential regulatory
requirements, including climate-related transition risks.
Monthly Chief Risk Officer (CRO) report to Risk Committee
or Board includes climate and increased frequency of large
events as both a key strategic risk and a compliance risk. This
report provides updates on work on climate-related risks.
November 2025 Update provided on amendments to climate
related risks and opportunities.
People, Remuneration
and Appointment
Committee
The People, Remuneration and Appointment Committee assists the Board in its
oversight of remuneration strategy by:
• Recommending whether climate metrics should be included in reward frameworks,
and recommending potential metrics.
• Recommending required skills, capabilities and experience for Board members to
ensure the Board can effectively manage risks and opportunities arising from climate.
May 2025 Results of Tower’s Sustainability and Climate Skills
and Capabilities Assessment for employees provided to the
Committee, along with an update on Management’s approach
to ensuring appropriate climate-related skills and capabilities.
Information provided on the disclosure requirements
for incorporating climate-related targets into executive
remuneration.
Climate-related performance metrics included in Executive
remuneration where the roles are central to our climate-
related disclosures as included on page 36.
Executive Leadership
Team
With respect to the Climate Statement, the Executive Leadership Team is
responsible for:
• The development and execution of Tower’s climate strategy and transition plan;
• Ensuring that sustainability and climate-related risks and opportunities are considered
as part of investment, underwriting, product design, customer experience, pricing,
supply chain and claims processes;
• Ensuring that all employees are aware of their responsibilities for the identification of
climate risks and opportunities;
• Ensuring that employees have relevant climate and sustainability skills
and capabilities.
Monthly updates on climate and sustainability progress
via the People and Capability dashboard report to the ELT.
These include GHG inventory development and performance,
transition planning development, climate-related risks and
opportunities and disclosure developments.
February 2025 First Transition Planning workshop
June 2025 Second Transition Planning workshop
May/June 2025 Sustainability Materiality Assessment
workshops (including climate)
Management
Sustainability and
Climate Steerco
This Executive-level committee is chaired by the Head of Corporate Affairs and
Sustainability and includes the CRO, Chief Underwriting Officer and Deputy CFO.
It oversees:
• Tower’s progress and performance against sustainability strategy and climate
strategy/ transition plan/ metrics and targets.
• The assignment of resources to ensure sustainability and climate outcomes
are achieved.
• Delivery of Tower’s sustainability reporting and climate-related disclosures to the
Board and its Committees.
Minimum monthly meeting.
In FY25 the position of chair was transferred from the acting
CFO to the Head of Corporate Affairs and Sustainability.
Updates on Steerco activities are provided to the Board in the
monthly CEO report.
Key climate-related decisions and information are raised
through appropriate governance committees as required.
CLIMATE STATEMENT 202543 Contents

Governance bodyRoles and responsibilitiesActivity
Management Risk
and Compliance
Committee
The Management Risk and Compliance Committee (MRCC) assists Tower Limited to
discharge its management and governance responsibilities for risk including climate-
related risk. The primary purpose of the MRCC is to oversee, manage and approve
Tower-wide risk, compliance, and conduct management practices.
Monthly meetings with summary of Board CRO report
discussed. Climate-related matters were included in the
MRCC agenda on two occasions in August and September.
The roll out of Risk Based Pricing to seasurge and landslide
was considered as part of the climate elements of our
adaption strategy.
Climate Risk ForumThe Climate Risk Forum is comprised of senior leaders from key functions including
claims, sales and service, underwriting, pricing, finance and technology. in FY25 the
Forum met twice and is dedicated to identifying, assessing, and monitoring climate-
related risks and opportunities and ensuring appropriate mitigating actions are
incorporated into Tower’s strategy and operating plan.
May and June 2025 Two sessions held with risk owners to
complete review of climate-related risks. Follow up sessions
with risk owners were undertaken to complete revisions.
Product, Pricing
& Underwriting
Committee
This Committee oversees monitoring, reporting and management of emissions from
Tower’s underwriting portfolios. It will be responsible for:
• Recommending targets for underwriting portfolio emissions reduction to the
Sustainability & Climate Steering Committee.
• Directing underwriting, product and pricing actions to achieve Tower’s sustainability
strategy, climate strategy, and transition plan.
• Ensuring alignment of sustainability and climate underwriting and pricing actions with
Tower’s business strategy and operations.
Monthly meeting
The roll out of Risk Based Pricing to seasurge and landslide
and Pacific Parametric cover was considered by this
committee as part of the climate adaptation elements
of our strategy.
Claims CommitteeThe Claims Committee will oversee monitoring, reporting and management of emissions
from Tower’s claims supply chain. It will:
• Recommend targets for claims supply chain emissions reduction to the Sustainability
& Climate Steering Committee.
• Recommend claims actions that will achieve Tower’s sustainability strategy and
climate strategy, and transition plan (once developed) to the ELT/Sustainability
Steering Committee.
Monthly meeting
The Claims committee considered and responded on the
development and roll out of the Large Event Response Plan
and Risk Based Pricing to seasurge and landslide as part of the
climate adaptation elements of our strategy throughout FY25.
This committee’s contribution to climate-related disclosures is
expected to be largely related to measurement, management
and disclosure of claims supply chain related Scope 3
emissions. In line with amendments to adoption provisions for
Scope 3 emissions the committee’s contribution was deferred
from FY25 and will commence when Tower’s approach to
claims supply chain related emissions is more evolved.
Portfolio Performance
and Investment
Committee (PPIC)
The PPIC is an Executive-level committee that was established in FY25 responsible for
enterprise-wide project governance. It prioritises and oversees investment decisions
across key investment categories, balancing priorities, including incorporating transition
risk considerations into decision-making.
Climate related reporting to be undertaken on an as need
basis. No reports in FY25.
However the roll out of Risk Based Pricing to seasurge and
landslide was considered as part of the climate adaptation
elements of our strategy.
CLIMATE STATEMENT 202544 Contents

Board climate skills and capabilities
The Board aims to have an appropriate mix of relevant
skills, with particular competencies in the insurance and
financial services sector.
In FY25, Tower Directors received refresher climate
legal obligations and greenhouse gas emissions training
material as part of the March Board paper, having
received formal training in FY24 and having completed a
survey on ESG and climate capabilities. These combine
to provide the Board with appropriate knowledge
to consider all climate-related communications and
provide the required oversight.
In FY25, Directors completed an annual skills matrix
including ESG and climate-related topics.
Management climate-related skills
and capabilities
As an insurer, Tower’s teams have existing skills and
capabilities that are highly relevant to managing climate-
related risks and opportunities including general risk
management, actuarial, data management, natural
hazard modelling, finance, governance, and strategy.
Tower has dedicated sustainability roles, including within
senior management. Reporting to the Sustainability and
Climate Steering Committee, Tower’s Head of Corporate
Affairs and Sustainability is responsible for:
• Developing and delivering Tower’s sustainability
strategy, incorporating climate-related goals and
initiatives for the period 2020-2025.
• Leading the delivery of climate-related disclosures,
with support from Tower’s Sustainability Manager and
the new Sustainability Analyst role.
ELT and Senior Leaders received climate training
material as part of the transition planning workshop
and foundational sustainability (including basic
climate science, GHG emissions sources, calculation
and reporting) training as part of the FY25 materiality
assessment workshops. Three Climate Fresks (IPCC
based climate science training) have been held for
employees during the course of FY25 providing an in
depth insight into climate science.
Climate-related skills and capabilities
Senior leaders actively working on Tower’s Climate
Statement have included objectives in their FY25
performance plans related to resourcing and completing
their contributions.
Tower also has access to a range of external consultants
for specialist expertise and advice which has been noted
in Board updates throughout the year as appropriate.
CLIMATE STATEMENT 202545 Contents

Appendices
Index – CRD way finder
Appendix 1
CRD sectionsCRD disclosuresTower disclosureAdoption provisions
NZ CS 1
Governance - To enable primary
users to understand both the role
an entity’s governance body plays
in overseeing climate-related risks
and climate-related opportunities,
and the role management plays
in assessing and managing
those climate-related risks and
opportunities.
7 (a) the identity of the governance body responsible for oversight of climate-related
risks and opportunities;
(b) a description of the governance body’s oversight of climate-related risks and
opportunities (see paragraph 8); and
(c) a description of management’s role in assessing and managing climate-related
risks and opportunities (see paragraph 9).
Governance
framework pg 40
Strategy - To enable primary users to
understand how climate is currently
impacting an entity and how it may
do so in the future. This includes
the scenario analysis an entity has
undertaken, the climate-related
risks and opportunities an entity has
identified, the anticipated impacts
and financial impacts of these, and
how an entity will position itself as
the global and domestic economy
transitions towards a low-emissions,
climate-resilient future.
11 (a) a description of its current climate-related impacts;
(b) a description of the scenario analysis it has undertaken
(c) a description of the climate-related risks and opportunities it has identified over
the short, medium, and long term
(d) a description of the anticipated impacts of climate-related risks and opportunities;
and
(e) a description of how it will position itself as the global and domestic economy
transitions towards a low-emissions, climate-resilient future state.
Strategy
Pg 10
Pg 12
Pg 18-24
Pg 25
Pg 26-29
Adoption provision 2:
Anticipated Financial
impacts
CLIMATE STATEMENT 202546 Contents

CRD sectionsCRD disclosuresTower disclosureAdoption provisions
Risk management - To enable
primary users to understand how
an entity’s climate-related risks
are identified, assessed, and
managed and how those processes
are integrated into existing risk
management processes.
18 (a) a description of its processes for identifying, assessing and managing climate-
related risks (see paragraph 19); and
(b) a description of how its processes for identifying, assessing, and managing
climate related risks are integrated into its overall risk management processes.
19 An entity must include the following information when describing its processes for
identifying, assessing and managing climate-related risks:
(a) the tools and methods used to identify, and to assess the scope, size, and impact
of, its identified climate-related risks;
(b) the short-term, medium-term, and long-term time horizons considered, including
specifying the duration of each of these time horizons;
(c) whether any parts of the value chain are excluded;
(d) the frequency of assessment; and
(e) its processes for prioritising climate-related risks relative to other types of risks.
Risk management
pg 37
Metrics and Targets: To enable
primary users to understand how
an entity measures and manages
its climate-related risks and
opportunities. Metrics and targets
also provide a basis upon which
primary users can compare entities
within a sector or industry.
21 To achieve the disclosure objective, an entity must disclose:
(a) the metrics that are relevant to all entities regardless of industry and business
model;
(b) industry-based metrics relevant to its industry or business model used to measure
and manage climate-related risks and opportunities;
(c) any other key performance indicators used to measure and manage climate-
related risks and opportunities; and
(d) the targets used to manage climate-related risks and opportunities, and
performance against those targets
GHG emissions
pg 30
Measuring our
performance
pg 36
Adoption provision 4:
Scope 3 GHG emissions
Adoption provision 5:
Comparatives for Scope 3
GHG emissions
Adoption provision 6:
Comparatives for metrics
Adoption provision 7:
Analysis of trends
Adoption provision 8:
Scope 3 GHG emissions
assurance
NZ CS 3
Methods and assumptions, and data
and estimation uncertainty
49 (a) a description of the methods and assumptions used in the preparation of its
climate-related disclosures where they are not apparent, including the limitations
of those methods.
(b) aspects of its disclosure (including amounts) that involve data and estimation
uncertainty, disclosing the sources and nature of data and estimation
uncertainties.
Appendix 5
pg 58
CLIMATE STATEMENT 202547 Contents

CRD sectionsCRD disclosuresTower disclosureAdoption provisions
NZ CS 3
Scenario analysis methods and
assumptions
51 (a) the climate-related scenarios it has used, including:
i a brief description of each scenario narrative;
ii. the time horizons considered, including endpoints and whether the endpoints
are determined by a year or a temperature target;
iii. a description of the various emissions reduction pathways in each scenario
and the assumptions underlying pathway development over time, including
the scope of operations covered, policy and socioeconomic assumptions,
macroeconomic trends, energy pathways, carbon sequestration from
afforestation and nature-based solutions and technology assumptions
including negative emissions technology;
iv. an explanation of why the entity believes the chosen scenarios are relevant
and appropriate to assessing the resilience of the entity’s business model and
strategy to climate-related risks and opportunities; and
v. the sources of data used to construct each scenario.
(b) how the scenario analysis process has been conducted, including:
vii. whether scenario analysis is a standalone analysis or integrated within the
entity’s strategy processes;
viii. the governance process used to oversee and manage the scenario analysis
process, including the role of the governance body and management;
ix. if modelling has been undertaken, a clear description of what modelling was
undertaken and why the model was chosen as the appropriate model; and
x. which external partners and stakeholders are involved
Understanding
our Possible
Futures
pg 12
Appendix 3
Scenario
Development
pg 49
GHG emissions methods,
assumptions and estimation
uncertainty
52 a description of the methods and assumptions used to calculate or estimate GHG
emissions, and the limitations of those methods. When choices between different
methods are allowed, or entity-specific methods are used, an entity must disclose
the methods used and the rationale for doing so.
53 uncertainties relevant to the entity’s quantification of its GHG emissions, including the
effects of these uncertainties on the GHG emissions disclosures.
54 an explanation for any base year GHG emissions restatements.
Our greenhouse
gas (GHG)
emissions pg 30
Appendix 4
GHG emissions
methodology,
restatements
and notes to
restatements
pg 52
Statement of compliance55 An entity whose climate-related disclosures comply with Aotearoa New Zealand
Climate Standards must include an explicit and unreserved statement of compliance.
Executive
summary pg 4
CLIMATE STATEMENT 202548 Contents

APPENDIX B: Source data
Boundary condition factor2022-20252026-20352036-2050Data source
ORDERLY: NET ZERO 2050
– NEW ZEALAND
Physical climate changes (RCP 2.6)
Average NZ temperature (1986-2006
baseline + .7°C)
+1.3°C+1.5°C+1.6°C
NGFS Climate impact explorer. ‘Absolute change in air temperature in New Zealand. RCP 2.6’.
Labourproductivity due to heat stress (lower
bound)
-0.1%-0.2%-0.3%
NGFS Climate impact explorer. ‘Change in labour productivity due to heat stress in New Zealand. RCP 2.6’.
NZ land exposed to flooding (1986-2006
baseline) (upper bound)
0.08%0.15%0.2%
NGFS Climate impact explorer. ‘Change in land annually exposed to river floods in New Zealand RCP 2.6’.
Snowfall (1986-2006 baseline)-41%-45%-48%
NGFS Climate impact explorer. ‘Relative change in snowfall in New Zealand RCP 2.6’. Retrieved from:
Sea level rise NZ (1996-2006 baseline)10cm17cm22cm
Ministry for the Environment.(2017). ‘Coastal Hazards and Climate Change. Guidance for
Local Government.’.pp.105.
Days above 25°C
Estimated. Estimated.40%
Climate Change Projections for New Zealand
Ministry for the Environment.(2018). Climate Change Projections for New Zealand: Atmosphere
Projections Based on Simulations from the IPCC Fifth Assessment, 2nd Edition. Wellington: Ministry
for the Environment. Table 1. pp.17.
Social, economic factors
NZ GDP (Billion US$2022/year)232.41 (NZD 355.15)297.55 (NZD 454.69)438.18 (NZD 669.58)
Riahi, K et al.(2017). ‘The Shared Socioeconomic Pathways and their energy use, land use and greenhouse
gas emissions implications: an overview. Global Environmental Change, Volume 42.
NZ population (million)5.15.56.0
As above
Carbon price (NZ$ 2021) $132$230$343
New Zealand Treasury.(2021). CBAx Tool User Guidance. CBAx Tool User Guidance - September 2021
(treasury.govt.nz)
(Orderly follows a high price path) (Assumptions taken from price path noting this is not a market indication
of supply and demand)
Travel by EVs (light passenger vehicles)3%46%100%Climate Change Commission.(2021). ‘Draft advice report charts data and scenario dataset. Tailwinds’.
Change in person-km travel (greatest modal
increase)
Public railCycleCycle As above
Global governance and institutionsStrong and flexible, focus on mitigation and adaptation
Climate Scenarios. ‘To The Toolkit, ‘Socioeconomic Development’. Retrieved from: Primer to Climate
Scenarios
(Orderly follows SSP1)
Market access and trade settingsModerate free-trade, balanced between globalisation and local communities
LifestyleHuman wellbeing
Consumer preferencesSelect for corporates with more sustainability attributes
Technology and innovationMedium. High uptake in sustainable technologies
Land useStrong land use regulation. Tropical deforestation strongly reduced.
Tiriti o WaitangiIndigenous wellbeing and property rights are protected
Frame, B, et al.
(2018). ‘Adapting global shared socio-economic pathways for national and local scenarios’.
Climate Risk Management. Volume 21. Retrieved from: https://doi.org/10.1016/j.crm.2018.05.001
(Orderly follows ‘100% Sustainability’)
APPENDIX B: Source data
Boundary condition factorLocation2025 (short-term)
2035 (medium-
term)
2050 (long-
term)
Data Source
ORDERLY: NET ZERO 2050
– PACIFIC
Physical risk data
Mean Annual Temperature Change
(Average annual temperature (°C) change from pre-
industrial baseline)
Pacific
1
1.5°C1.7°C1.8°C
NGFS Climate impact explorer. ‘Absolute change in mean air temperature in Fiji.’ RCP
2.6’. Retrieved from: NGFS Climate Impact Explorer plus 0.87 °C (Global average
temperature change pre-industrial baseline)
Temperature Days Above 35.0°C
(Annual average number)
Pacific0.250.522.06
Climate change knowledge portal (World bank). Projected Days with Heat
Index Exceeding 35°c – Fiji RCP2.6.
Precipitation (Median)
(% increase in precipitation per year vs 1986-2006
baseline)
Pacific+6.1%+6.1%+6.2%
NGFS Climate impact explorer. ‘Relative change in precipitation (%) in Fiji. RCP 2.6’.
Mean Sea Level Rise
(Centimetres vs 1986-2006 baseline)
Pacific5.5cm10.4cm20.4cm
The IPCC AR6 Sea-Level Rise Projections. SSP1-2.6 2020, 2030 and 2050 Fiji (Suva) .
Retrieved from: Sea Level Projection Tool – NASA Sea Level Change Portal
Expected Damage from River Flooding
(% change vs 2015 baseline)
2
Pacific-8.4%23.7%38.3%
NGFS Climate impact explorer. ‘Relative change in annual expected damage from
river floods in Fiji. RCP 2.6’.
Socioeconomic data
Population
(Millions)
Pacific0.89m0.88m0.82mFIJI population, SSP1.
GDP
(Billion US$2005/year)
Pacific$5.07(NZD 8.57b)$7.71b (NZD 13.04b)
$14.02b (NZD
23.71b)
FIJI GDP, OECD Env-Growth – SSP1. Exchange rate of 1.69 was used to convert
US dollar to NZ dollar
Productivity due to Heat Stress (lower bound)
(% change vs 1986-2006 baseline)
Pacific-5.2%-6.5%-8.1%
NGFS Climate impact explorer. ‘Relative change in labour productivity due to heat
stress in Fiji.’
1.Fiji used as an index for the Pacific to avoid gaps in data availability
2.Expected Damage from River Flooding 1986-2006 baseline data was not available
Consideration of materiality
The NZ Climate Standards require disclosure of
information if it is material according to the definition in
NZ CS 3.
The information provided in our climate disclosure is
material to Tower’s primary users, who we have defined
as existing and potential shareholders and asset
managers. Contextual information is also provided as it
supports the key elements of the climate statement.
Considerations we use when determining
materiality:
• Primary users – existing and potential shareholders
and asset managers
• Geographical distribution of our operations
• Level of influence
• Level of impact or anticipated impact
• Combined effects
Scenario sources of data
Appendix 2Appendix 3
CLIMATE STATEMENT 202549 Contents

Boundary condition factor2022-20252026-20352036-2050Data source
DISORDERLY: DELAYED TRANSITION
– NEW ZEALAND
Physical climate changes (RCP 4.5)
Average NZ temperature (1986-2006 baseline + .7°C) +1.3°C+1.6°C+1.8°C
NGFS Climate impact explorer. ‘Absolute change in air temperature in New Zealand. RCP 4.5’.
Labour productivity due to heat stress (lower bound)-0.1%-0.2%-0.4%
NGFS Climate impact explorer. ‘Change in labour productivity due to heat stress in New Zealand.
RCP 4.5’.
NZ land exposed to flooding (1986-2006 baseline) (upper
bound)
0.06%0.1%0.2%
NGFS Climate impact explorer. ‘Change in land annually exposed to river floods in New Zealand
RCP 4.5’.
Snowfall (1986-2006 baseline)-41%-45%-56%
NGFS Climate impact explorer. ‘Relative change in snowfall in New Zealand RCP 4.5’.
Sea level rise NZ (1996-2006 baseline)10cm17cm25cm
Ministry for the Environment. (2017). ‘Coastal Hazards and Climate Change. Guidance for
Local Government.’.pp.105.
Days above 25°C
Estimated. Estimated.Estimated.
Ministry for the Environment.(2018). Climate Change Projections for New Zealand: Atmosphere
Projections Based on Simulations from the IPCC Fifth Assessment, 2nd Edition. Wellington: Ministry
for the Environment. Table 1. pp.17.
Social, economic factors
NZ GDP (Billion US$2022/year)220.57 (NZD 337.05)
247.22 (NZD
377.78)
293.11 (NZD447.9)
Climate Change Commission. (2021). ‘Draft advice report charts data and scenario dataset. Headwinds’.
NZ population (million)5.35.86.2
Carbon price (NZ$ 2021)$99$173$343
New Zealand Treasury.(2021). CBAx Tool User Guidance. CBAx Tool User Guidance - September 2021
(treasury.govt.nz)
(Disorderly follows a central price path till 2035 then high price path onwards)
(Assumptions taken from price path noting this is not a market indication of supply and demand)
Travel by EVs (light passenger vehicles)2%28%94%
Climate Change Commission.(2021). ‘Draft advice report charts data and scenario dataset. Headwinds’.
Change in person-km travel (greatest modal increase) Public railPublic railCycle As above
Global governance and institutionsGlobal and national institutions make slow progress towards SDGs.
Climate Scenarios. ‘To The Toolkit, ‘Socioeconomic Development’. Retrieved from: Primer to Climate
Scenarios
(Disorderly follows SSP2)
Market access and trade settingsCurrent trends, intermediate globalization.
LifestyleCurrent trends, some consumerism but also lifestyle
Consumer preferences
Current trends, general push for ESG and climate but intention to
action gap
Technology and innovationModerate technology development, disparities between regions.
Land useCurrent trends, land use incompletely regulated
Tiriti o WaitangiAd-hoc protection for indigenous rights
Frame, B, et al.(2018). ‘Adapting global shared
socio-economic pathways for national and local
scenarios’. Climate Risk Management. Volume 21. Retrieved from:
https://doi.org/10.1016/j.crm.2018.05.001
(Disorderly follows ‘Kicking, screaming’).
APPENDIX B: Source data cont.
APPENDIX B: Source data cont.
Boundary condition factor
Location2025 (short-term)2035 (medium-term)2050 (long-term)Data source
DISORDERLY: DELAYED TRANSITION
- PACIFIC
Physical risk data
Mean Annual Temperature Change
(Average annual temperature (°C) change from pre-industrial
baseline)
Pacific
1
1.5°C1.7°C2.0°C
NGFS Climate impact explorer. ‘Absolute change in mean air
temperature in Fiji.’ RCP 4.5’. Retrieved from: NGFS Climate Impact
Explorer plus 0.87 °C (Global average temperature change pre-
industrial baseline)
Temperature Days Above 35.0°C
(Annual average number)
Pacific0.551.473.18
Climate change knowledge portal (World bank). Projected Days with
Heat Index Exceeding 35°c – Fiji RCP4.5. Retrieved from:
https://climateknowledgeportal.worldbank.org/country/fiji/cmip5
Precipitation (Median)
(% increase in precipitation per year vs 1986-2006 baseline)
Pacific+6.1%+6.1%+7.8%
NGFS Climate impact explorer. ‘Relative change in precipitation
(%) in Fiji. RCP 4.5’.
Mean Sea Level Rise
(Centimetres vs 1986-2006 baseline)
Pacific5.3cm10.1cm22cm
The IPCC AR6 Sea-Level Rise Projections. SSP2-4.5 2020, 2030
and 2050 Fiji (Suva). Retrieved from: Sea Level Projection Tool –
NASA Sea Level Change Portal
Expected Damage from River Flooding
(% change vs 2005 baseline)
2
Pacific-8.4%23.7%57.9%
NGFS Climate impact explorer. ‘Relative change in annual
expected damage from river floods in Fiji.’ RCP 4.5’.
Socioeconomic data
Population
(Millions)
Pacific0.94m0.97m0.97m
FIJI GDP, OECD Env-Growth – SSP2.
GDP
(Billion US$2005/year)
Pacific$5.01b (NZD 8.47b)$7.01b (NZD 11.85b)$11.33b (NZD 19.16b)
FIJI GDP, OECD Env-Growth – SSP2. Exchange rate of 1.69
was used to convert US dollar to NZ dollar.
Productivity due to Heat Stress (lower bound)
(% change vs 1986-2006 baseline)
Pacific-5.2%-6.5%-9.7%
NGFS Climate impact explorer. ‘Relative change in labour
productivity due to heat stress in Fiji.’ RCP 4.5.
1.Fiji used as an index for the Pacific to avoid gaps in data availability
2.Expected Damage from River Flooding 1986-2006 baseline data was not available
CLIMATE STATEMENT 202550 Contents

Boundary condition factor2022-20252026-20352036-2050Data source
HOT HOUSE WORLD: CURRENT POLICIES
– NEW ZEALAND
Physical climate changes (RCP 6.0)
Average NZ temperature (1986-2006 baseline + .7°C) +1.3°C+1.6°C+2.0°C
NGFS Climate impact explorer. ‘Absolute change in air temperature in New Zealand.
RCP 6.0’.
Labour productivity due to heat stress (lower bound)-0.1%-0.2%-0.4%
NGFS Climate impact explorer. ‘Change in labour productivity due to heat stress in
New Zealand. RCP 6.0’.
NZ land exposed to flooding (1986-2006 baseline) (upper bound)0.06%0.09%0.2%
NGFS Climate impact explorer. ‘Change in land annually exposed to river floods in
New Zealand RCP 6.0’.
Snowfall (1986-2006 baseline)-41%-45%-56%
NGFS Climate impact explorer. ‘Relative change in snowfall in New Zealand RCP 6.0’.
Sea level rise NZ (1996-2006 baseline)10cm17cm30cm
Ministry for the Environment. (2017). ‘Coastal Hazards and Climate Change.
Guidance for Local Government.’.pp.105.
Days above 25°C
Estimated. Estimated.Estimated.
Ministry for the Environment. (2018). Climate Change Projections for New Zealand:
Atmosphere
Projections Based on Simulations from the IPCC Fifth Assessment, 2nd Edition.
Wellington:
Ministry for the Environment. Table 1. pp.17.
Social, economic factors
NZ GDP (Billion US$2005/yr)242.77 (NZD 370.98)339 (NZD 518.03)577.33 (NZD 882.22)Riahi, K et al. (2017). ‘The Shared Socioeconomic Pathways and their energy use, land
use and greenhouse gas emissions implications: an overview. Global Environmental
Change, Volume 42.
NZ population (million)5.35.96.9
Carbon price $67$116$173
New Zealand Treasury. (2021). CBAx Tool User Guidance. CBAx Tool User Guidance -
September 2021 (treasury.govt.nz)
(Hot House World follows a low price path) (Assumptions taken from price path noting this
is not a market indication of supply and demand)
Travel by EVs (light passenger vehicles)2%15%81%
Climate Change Commission. (2021). ‘Draft advice report charts data and scenario
dataset. Current Policy Reference’. Retrieved from: Climate Change Commission
Change in person-km travel (greatest modal increase) Public railPublic railPublic railAs above
Global governance and institutions
Strong investment in institutions globally and nationally to enhance
human and social capital
Climate Scenarios. ‘To The Toolkit, ‘Socioeconomic Development’. Retrieved from: Primer
to Climate Scenarios
(Hot House World follows SSP5)
Market access and trade settingsHighly globalised trade
LifestyleConsumerism driven, disjoint from nature
Consumer preferencesEconomic and social preferences
Technology and innovationHigh rates of technology and innovation, including in adaptation
Land useIncomplete regulation, historic trends followed
Tiriti o WaitangiLacking commitment from Government
Frame, B, et al. (2018). ‘Adapting global shared socio-economic pathways for national
and local scenarios’. Climate Risk Management. Volume 21. Retrieved from:
https://doi.org/10.1016/j.crm.2018.05.001
(Hot House World follows “Homoeconomicus”).
APPENDIX B: Source data cont.
APPENDIX B: Source data cont.
Boundary condition factorLocation2025 (short-term)2035 (medium-term)2050 (long-term)Data source
HOT HOUSE WORLD: CURRENT POLICIES
– PACIFIC
Physical risk data
Mean Annual Temperature Change
(Average annual temperature (°C) change from pre-
industrial baseline)
Pacific
1
1.5°C1.7°C1.9°C
NGFS Climate impact explorer. ‘Absolute change in mean air temperature in
Fiji. RCP 6.0’.
Temperature Days Above 35.0°C
(Annual average number)
Pacific0.280.264.34
Climate change knowledge portal (World bank). Projected Days with Heat
Index Exceeding 35°c – Fiji RCP6.0.
Precipitation (Median)
(% increase in precipitation per year vs 1986-2006
baseline)
Pacific+6.1%+6.1%+7.1%
NGFS Climate impact explorer. ‘Relative change in precipitation (%) in Fiji.
RCP 6.0’.
Mean Sea Level Rise
(Centimetres vs 1986-2006 baseline)
Pacific5.1cm10cm23cm
The IPCC AR6 Sea-Level Rise Projections. SSP3-7.0 2020, 2030 and 2050 Fiji
(Suva). Retrieved from: Sea Level Projection Tool – NASA Sea Level Change
Portal
Expected Damage from River Flooding
(% change vs 2005 baseline)
2
Pacific-8.4%23.7%55.9%
NGFS Climate impact explorer. ‘Relative change in annual expected damage
from river floods in Fiji.’ RCP 6.0’.
Socioeconomic data
Population
(Millions)
Pacific0.97m1.04m1.12mFIJI GDP, OECD Env-Growth – SSP3.
GDP
((Billion US$2005/year)
Pacific$5.07b (NZD 8.57b)$6.52b (NZD 11.02b)$9.17 (NZD 15.51b)
FIJI GDP, OECD Env-Growth – SSP3. Exchange rate of 1.69 was used to convert
US dollar to NZ dollar
Productivity due to Heat Stress (lower bound)
(% change vs 1986-2006 baseline)
Pacific-4.7%-6.5%-9.2%
NGFS Climate impact explorer. ‘Relative change in labour productivity due to
heat stress in Fiji.’ RCP 6.0.
1.Fiji used as an index for the Pacific to avoid gaps in data availability
2.Expected Damage from River Flooding 1986-2006 baseline data was not available
CLIMATE STATEMENT 202551 Contents

The CSR software uses a calculation methodology for
quantifying the emissions inventory using emissions
source activity data multiplied by emission or
removal factors.
Emission factors are utilised from a range of sources to
calculate our GHG emissions:
• Ministry for the Environment (MfE) 2023 ‘Measuring
Emissions: A guide for organisations’ (NZ)
• Ministry for the Environment (MfE) 2025 ‘Measuring
Emissions: A guide for organisations’ (NZ)
• Department for Environment Food & Rural Affairs
(DEFRA) 2025 ‘Greenhouse gas reporting: conversion
factors’ (UK)
• International Energy Agency (IEA) 2025 ‘IEA Emission
Factors – 2025 Edition’
• Environment Protection Authority Victoria (EPA)
2021 ‘Greenhouse Gas Emission Factors for Office
Copy Paper’
The emission factor sources are based on global
warming potentials (GWPs) varying from AR4-AR6.
The time horizon is 100 years.
Measurement standards and
consolidation approach
Tower has been measuring its GHG emissions since
FY20 in accordance with the requirements of the
‘Greenhouse Gas Protocol – A Corporate Accounting
and Reporting Standard (2004)’.
1
Tower applies the
operational control consolidation approach
1
to account
for emissions, with emissions reported in tonnes of CO
2

equivalents, in line with the requirements of the Aotearoa
New Zealand Climate Standards.
Guidance from the following sources has also been used
to develop our GHG inventory methodology:
• Greenhouse Gas Protocol – Scope 2 Guidance
1
• Greenhouse Gas Protocol – Categorising GHG
Emissions Associated with Leased Assets Appendix
F to the GHG Protocol Corporate Accounting and
Reporting Standard – Revised Edition June 2006
(version 1.0)
1
• Greenhouse Gas Protocol – Corporate Value Chain
(Scope 3) Accounting and Reporting Standard
• Greenhouse Gas Protocol -Technical Guidance for
Calculating Scope 3 Emissions (version 1.0)
GHG emissions methodology
Tower has contracted the services of Bravegen to assist
with the collation and loading of emissions source data
into their online Corporate Sustainability Reporting
(CSR) tool.
Bravegen CSR has been developed to meet the
requirements of the GHG Protocol.
Appendix 4
1 Subject to assurance. As relevant to Scope 1 and Scope 2 GHG emissions, the disclosures of the measurement standards applied and the consolidation approach used are subject to assurance.
CLIMATE STATEMENT 202552 Contents

Restatements
FY20-24 emissions disclosures have been restated to correct errors and to enhance the consistency of comparative information between reporting periods. In line with NZ CSs, Tower
has restated all material changes which have occurred due to mix of changes in organisational structure, changes in calculation methodologies, errors, and improvements in data
accuracy. As required by NZ CS 3 paragraph 54, we have provided an explanation for FY20 base year GHG emissions restatements totaling -21 tCO
2
e Scope 1: Mobile Combustion
and 10 tCO
2
e Scope 2 as presented in column FY20 Adjustment in the table below, and as described in the accompanying Notes to restatements on page 54. We have also provided
explanations for restatements to other comparative periods. However, only the numerical restatements and supporting descriptions to the base year are subject to assurance.

Note
FY20
Base Year
(Restated)
FY20
Adjustment
FY20
Base Year
(Previously
reported)
FY21
(Restated)
FY21
Adjustment
FY21
(Previously
reported)
FY22
(Restated)
FY22
Adjustment
FY22
(Previously
reported)
FY23
(Restated)
FY23
Adjustment
FY23
(Previously
reported)
FY24
(Restated)
FY24
Adjustment
FY24
(Previously
reported)
Scope 1:
Mobile
Combustion
1, 2a, 3,
4, 5
129-211501151798120-180300140-25165136-24160
Scope 1:
Stationary
Combustion
19–1917–17–––––––––
Scope 1:
Fugitive
Emissions
2b––––––––––––2828–
Total Scope 1148-2116913217115120-180300140-251651644160
Scope 2
Purchased
Electricity
1, 2c,
2d, 5,
6, 7
21710207176-3179146-146158-81661475142
Total Scope 221710207176-3179146-146158-81661475142
Total Scope 1
& Scope 2
365-1137630814294266-180446298-333313119302
Scope 3 (all
categories)
4b, 5209–209295_295202_202183_183742-117859
CLIMATE STATEMENT 202553 Contents

1. Structural changes due to divestment
Certain subsidiaries were divested in previous periods.
In accordance with the GHG Protocol Corporate
Standard, emissions from these facilities should have
been removed from the amounts reported in the year of
disposal and base year. Restating amounts for periods
between the base year and the disposal year is optional
under the protocol but is to be applied consistently.
Tower have corrected this error for base year and the
years of disposal and have determined our policy is
to restate the intervening years. This resulted in the
following adjustments:
Scope 1: Mobile combustion
• Papua New Guinea (Sold 27/10/2022); -23tCO
2
e in
FY20, -9tCO
2
e in FY21, -9tCO
2
e in FY22, and -1tCO
2
e
in FY23.
• Soloman Islands (Sold 29/01/2024); -4tCO
2
e in FY20,
-4tCO
2
e in FY21, -10tCO
2
e in FY22, -36tCO
2
e in FY23,
and -13tCO
2
e in FY24.
• Vanuatu (Sold 30/08/2024); -81tCO
2
e in FY20.
Scope 2: Purchased electricity
• Papua New Guinea (Sold 27/10/2022); -3tCO
2
e in
FY20, -5tCO
2
e in FY21, -8tCO
2
e in FY22, and -1tCO
2
e
in FY23.
• Soloman Islands (Sold 29/01/2024); -14tCO
2
e in
FY20, -15tCO
2
e in FY21, -14tCO
2
e in FY22, -7tCO
2
e in
FY23, and -3tCO
2
e in FY24.
• Vanuatu (Sold 30/08/2024); -3tCO
2
e in FY20,
-9tCO
2
e in FY22, -7tCO
2
e in FY23, and -4tCO
2
e
in FY24.
2. Omitted emission sources
a. Restatement to correct and include fuel
suppliers identified in Fiji and New Zealand that
were previously unreported in Scope 1: Mobile
Combustion. This resulted in a correction of 81tCO
2
e
in FY20, 34tCO
2
e in FY21, and 6tCO
2
e in FY23.
b. Restatement to correct and include refrigerants from
Scope 1: Fugitive Emissions for the Rotorua office in
FY24 which were previously unreported, this resulted
in an adjustment of 28tCO
2
e.
c. Purchased heating and cooling from landlord-
controlled HVAC systems was previously excluded
from Tower’s Scope 2 GHG inventory. Tower has
estimated the electricity used for the generation of
heating and cooling for the period of FY20-FY24. This
resulted in a correction of 21tCO
2
e in FY20, 17tCO
2
e in
FY21, 22tCO
2
e in FY22, 27tCO
2
e in FY23, and 22tCO
2
e
in FY24.
d. Restatement to correct and include electricity
from the Fanshawe Street office in FY22 which was
previously unreported, this resulted in an adjustment
of 9tCO
2
e.
3. Activity data conversion error
Fleet fuel for American Samoa was previously calculated
assuming a metric system volume. The volumes
invoiced are measured using an imperial measure, which
led to Scope 1: Mobile Combustion emissions being
understated. This resulted in a correction of 6tCO
2
e in
FY20, 7tCO
2
e in FY21, 4tCO
2
e in FY22, 5tCO
2
e in FY23,
and 6tCO
2
e in FY24.
4. Transposition error
a. Restatement of fleet fuel usage to correct manual
transposition errors, this resulted in a Scope 1: Mobile
Combustion correction of -11tCO
2
e in FY21, -165tCO
2
e
in FY22, 1tCO
2
e in FY23, and -12tCO
2
e in FY24.
b. Wastewater for Fanshawe Street was previously
calculated on the basis data was provided as
m3 however it was reported in litres causing an
overstatement. This resulted in a correction of
-99tCO
2
e in FY24.
5. Emission factor correction
Following the release of the FY24 Climate Related
Disclosures, an error in the updating of emission
factors by the carbon accounting software was
identified by Tower. This resulted in the ‘Ministry for
the Environment (MfE) 2023 ‘Measuring Emissions: A
guide for organisations’ being applied to the inventory,
instead of the 2024 updated factors. This resulted in an
overstatement of Scope 1: Mobile Combustion and a
correction of -5tCO
2
e in FY24.
Scope 3 was overstated due to the error in emission
factors, with a correction of -18tCO
2
e.
6. Incorrect classification of emission source
Reclassification of shared space electricity not under
direct control from Scope 2 to Scope 3 Category 8, this
resulted in an adjustment of Scope 2 of -20tCO
2
e in
FY23, and -30tCO
2
e in FY24. Scope 3 Category 8 has
been excluded from reporting in FY25.
7. Improvement in methodology
Restatement of FY24 purchased electricity in Suva
offices to improve accuracy following enhanced data
collection and estimation methods. Actual metered
data was used where available, and updated estimation
methods were applied for one unmetered site. This
resulted in an adjustment of Scope 2 of 20tCO
2
e in FY24.
Notes to the restatements
CLIMATE STATEMENT 202554 Contents

CategoryGHG emissions source Country Data source
Calculation methodology,
assumptions and uncertainty (Qualitative)
Source of
Emission Factor
Scope 1
Mobile CombustionVehicle fleet fuel All countriesSupplier dataNZ – Fuel-based method. Low uncertainty.
Fiji, Cook Islands, & American Samoa – Fuel-based
method. Low uncertainty.
Tonga & Samoa – Spend-based method. Supplier
fuel spend is obtained from finance system with the
average fuel price for each month obtained from
government sources. Low uncertainty.
MfE (2025)
GWP: AR5

Fugitive EmissionsRefrigerants All countriesSupplier dataTop-up method. Top-ups of HVAC systems under
Tower’s operational control. Low uncertainty.
MfE (2025)
GWP: AR5
Scope 2
ElectricityElectricity consumption All countriesSupplier data &
estimation
Location-based method. Where possible, metered
kwh of electricity consumption and location-specific
emissions factors are used to measure emissions. In
FY25, electricity consumption for the Suva Head Office
was estimated for the first six months, prior to the
installation of a meter on one floor. For the remaining
six months, metered data from that floor was used to
estimate electricity consumption for the second floor.
The Oceania total emission factor from IEA is used for
all Pacific nations, this is an average of emissions factor
of Australia; New Zealand; Cook Islands; Fiji; French
Polynesia; Kiribati; New Caledonia; Palau; Papua New
Guinea; Samoa; the Solomon Islands; Tonga;Vanuatu.
Low uncertainty.
NZ – MfE (2025)
GWP: AR5
Pacific – IEA (2025)
GWP: AR6
Heating and coolingElectricity consumptionNZ (Fanshawe
Street) & Fiji
(Suva Head
Office)
EstimationLocation-based method. Heating and cooling acquired
from central HVAC systems under landlord control
Fanshawe Street was estimated as 45% of shared
space usage (which includes central HVAC). For Suva
Head Office, Fanshawe Street was used as a proxy to
obtain the proportion of energy from central HVAC to
metered electricity. This proportion was applied to Suva
to obtain the estimated HVAC electricity based on the
metered electricity. High uncertainty.
NZ – MfE (2025)
GWP: AR5
Fiji – IEA (2025)
GWP: AR6
Methodology, assumptions, uncertainties and emissions factors for all Scopes
CLIMATE STATEMENT 202555 Contents

CategoryGHG emissions source Country Data source
Calculation methodology,
assumptions and uncertainty (Qualitative)
Source of
Emission Factor
Scope 3
Category 1: Purchased
goods and services
Office paper purchasedNew Zealand Supplier dataAverage-data method. Supplier report outlines total
office paper purchased (kg). Moderate uncertainty.
EPA Victoria (2019)
GWP: AR5
Category 1: Purchased
goods and services
Water supplyAll countriesSupplier dataAverage-data method. Reports provided for Auckland
office, water is apportioned based of net lettable area
(17.3%). Moderate uncertainty
MfE (2025)
GWP: AR5
Category 3: Fuel- and
energy-related activities
not included in Scope 1
or Scope 2
Electricity transmission
and distribution losses
(T&D)
New ZealandSupplier data Average-data method. Emissions from T&D losses are
estimated based on Scope 2 data. Low uncertainty.
NZ – MfE (2025)
GWP: AR5
Pacific – IEA (2025)
GWP: AR6
Electricity, T&D, and fuel
well-to-tank (WTT)
New Zealand Supplier DataAverage-data method. Emissions from WTT losses are
estimated based on Scope 1 & 2 data. Low uncertainty.
DEFRA (2025)
GWP: AR5
Category 5: Waste
generated in operations.
Waste to landfillAll Countries Supplier dataAverage-data method. Reports provided for Auckland
office, waste is attributed based of net lettable area
(17.3%). For other offices waste per FTE is calculated
and applied to total FTEs across all locations.
Moderate uncertainty.
MfE (2025)
GWP: AR5
Category 6: Business
Travel
Air travel & Hotel StaysAll countriesSupplier data Air Travel – Distance-based method used for air
travel. Supplier report outlines distance, domestic and
international, and class of travel.
Hotel Stays – Nights-stayed method. Supplier report
outlines location and length of stay.
For flights and hotel stays booked outside of the
primary travel agent, invoices are extracted from the
finance system, and the above approach is applied.
Air Travel –
MfE (2025) – With
radiative forcing.
GWP: AR5
Hotel stays –
MfE (2025)
GWP: AR5
MfE (2023)
GWP: AR5
Category 6: Business
Travel
Rental carsAll countriesSupplier data
Finance System
Distance-based method used for rental cars. Supplier
report outlines distance travelled and vehicle type.
Spend-based method used for bookings made
with other providers. Expense data extracted from
finance system.
MfE (2025)
GWP: AR5
CLIMATE STATEMENT 202556 Contents

CategoryGHG emissions source Country Data source
Calculation methodology,
assumptions and uncertainty (Qualitative)
Source of
Emission Factor
Category 6: Business
Travel
Taxi travelAll countriesSupplier data
Finance System
Distance-based method used for Corporate Cabs & Taxi
Charge. Supplier reports outline distance travelled and
vehicle category.
Spend-based method used for other taxis booked with
other providers. Expense data extracted from finance
system. Moderate uncertainty.
MfE (2025)
GWP: AR5
Category 7: Employee
Commuting
Employee Commute All countriesThird-party
survey
Average-data method used to calculate total employee
commute emissions for each transport category.
Estimated emissions per employee extrapolate to total
FTEs, 48% survey response rate across NZ and Pacific.
Moderate uncertainty.
MfE (2025)
GWP: AR5
Working from homeAll CountriesThird-party
survey
Average-data method used to calculate total WFH days
based on employee commute survey. 48% response
rate across NZ and Pacific. Moderate uncertainty.
MfE (2025)
GWP: AR5
Footnote: There are inherent data uncertainties with emissions data due to the limited availability of information and Tower’s reliance on external sources, which means that there may be a lag in the data, the data is over or understated, and/or the quantification may be
unreliable. The Quality score is assigned based on the availability, certainty and completeness of data. GHG quantification is subject to inherent uncertainty because of incomplete scientific knowledge used to determine emissions factors and the values needed to combine
emissions of different gases.
Scope
GHG emission
source
Reason for exclusion
1Stationary diesel related to back up generators
(Pacific)
1

Insufficient data available to calculate related emissions.
2Purchased heating and cooling sourced from
landlord-controlled assets (Samoa & Suva
Retail Branch)
1
Insufficient data available to calculate related emissions. We do not believe this is a material emission source outside
of the Fanshawe and Suva Head Offices.
3Employee vehicle claims (NZ)In previous years these emission sources were calculated to be less than 1% and continue to remain an immaterial
emissions source.
3Waste generated in operations (Pacific) We have been unable to obtain data for waste generated in our Pacific Island operations as illustrated on page 8 in
FY25. We do not believe this will be a significant emissions source.
3Value chain emissions from:
• Purchased goods & services
• Capital goods
• Upstream transport and distribution
• Investments
We have not yet developed our whole of value chain reporting processes. We have included working from home
and paper for our NZ operations in FY24 and FY25.
In FY24, we commenced workstreams to capture broader Scope 3 and continued this work in FY25. These will
include emissions from our underwriting portfolios, supply chain and investment portfolios.
1 Scope 1 and 2 exclusions are subject to assurance.
CLIMATE STATEMENT 202557 Contents

Assumptions, Methodologies and
Limitations Statement
Forward-looking statements
This climate statement contains climate-related and
other forward-looking statements and metrics, which
are not and should not be considered guarantees,
predictions or forecasts of future climate-related
outcomes or financial performance.
There remains significant uncertainty in climate data,
metrics, and modelling. The forward-looking statements
are inherently subject to uncertainties, risks, and
assumptions, many of which are beyond our control.
These may include, but are not limited to, economic
conditions, market trends, regulatory developments, and
other known and unknown factors. The many underlying
risks and assumptions may cause actual outcomes to
differ materially.
As a result, readers are cautioned not to place undue
reliance on any forward-looking statements contained
within this climate statement. All information stated
within this climate statement is relevant at the date of
publication only.
Appendix 5
Further Clarifications
Current climate-related impacts have been derived from
internal categorization and quantification of claims data
alongside known catastrophic and large weather events.
Climate-related risks & opportunities were developed
on the basis of the ICNZ Climate-related scenarios,
Tower’s scenarios, internal expertise and knowledge and
guidance from scenario source data. These are limited
by the current lack of clear modelling.
Anticipated Impacts were derived using a combination of
internal and external data sources.
• Population growth – Projections for scenario
development as detailed in Appendix 3.
• Dwelling growth – Internal analysis based on
forecasted population growth above.
• Transition to EV vehicles and vehicle ownership
rate assumptions based on internal data and
market trends.
• Tower’s expected market share of target markets –
Management’s best estimate based on internal data
and knowledge.
• Growth of multi-unit dwellings – Management’s best
estimate based on internal data and knowledge
• Stormwater infrastructure investments –
Management’s best estimate based on internal data
and knowledge.
• Potential public interventions in the general
insurance market - Management’s best estimate
based on internal data and knowledge.
Measuring our Performance - Metrics
• Transition risks – % of vehicles insured that are
internal combustion engines (ICEs) derived from
categorised motor policies as sourced from the
underlying vehicle data obtained from RedBook.
• Physical risks – % of high flood risk homes insured.
The definition of ‘High Flood Risk’ is Tower’s own
definition and not necessarily consistent with other
public sources. Specifically it relates to insurance risk
and cost to repair or replace property relative to the
risk of flooding and not just the chances of flooding
occurring in isolation. It also relates to Tower’s own risk
appetite or interpretation of the level of risk.
• Opportunities current – % of EV and PHV vehicles
covered. Data is derived from categorised motor
policies as sourced from the underlying vehicle data
obtained from RedBook.
• Capital Deployment has been calculated based on
operational expenditure on climate-related activities
identified by the Sustainability and Climate Steerco.
CLIMATE STATEMENT 202558 Contents

Appendix 6
Independent Assurance Report
To the Directors of Tower Limited
Limited Assurance Report on Tower Limited’s Greenhouse Gas (GHG)
Disclosures
Our conclusion
We have undertaken a limited assurance engagement on the gross GHG emissions,
additional required disclosures of gross GHG emissions, and gross GHG emissions
methods, assumptions and estimation uncertainty (the GHG Disclosures), as outlined
within the Scope of our limited assurance engagement section below, included in the
Climate Statement of Tower Limited (the Company) and its subsidiaries (the Group) for
the year ended 30 September 2025.
Based on the procedures we have performed and the evidence we have obtained,
nothing has come to our attention that causes us to believe that the GHG Disclosures
are not fairly presented and are not prepared, in all material respects, in accordance with
the Aotearoa New Zealand Climate Standards (NZ CSs) issued by the External Reporting
Board (XRB), as explained on page 4 of the Climate Statement.
Scope of our limited assurance engagement
We have undertaken a limited assurance engagement over the following GHG
Disclosures on pages 32, 52 to 55 and 57 of the Climate Statement for the year ended
30 September 2025:
• gross GHG emissions:
—Total Scope 1 emissions of 142 tCO
2
e on page 32;
—Total Scope 2 (location-based) emissions of 136 tCO
2
e on page 32;
• additional required disclosures of gross GHG emissions on pages 52, 55 and 57; and
• gross GHG emissions methods, assumptions and estimation uncertainty on pages 53
to 55
Our assurance engagement does not extend to any other information included,
or referred to, in the Climate Statement on pages 1 to 54 and 56 to 58. We have
not performed any procedures with respect to the excluded information and,
therefore, no conclusion is expressed on it. The comparative information for the
years ended 30 September 2020 (base year), 30 September 2021, 30 September
2022, 30 September 2023, and 30 September 2024 disclosed in the Group’s Climate
Statement is not covered by the assurance conclusion expressed in this report.
Other matter – comparative information
The comparative GHG Disclosures (that is, GHG Disclosures for the years ended
30 September 2020 (base year), 30 September 2021, 30 September 2022, 30
September 2023, and 30 September 2024) have not been subject to assurance. As
such, these disclosures are not covered by our assurance conclusion.
CLIMATE STATEMENT 202559 Contents

Independent Assurance Report (continued)
Directors’ responsibilities
The Directors of the Company are responsible on behalf of the Company for the
preparation and fair presentation of the GHG Disclosures in accordance with NZ CSs.
This responsibility includes the design, implementation and maintenance of internal
controls relevant to the preparation of GHG Disclosures that are free from material
misstatement whether due to fraud or error.
Inherent uncertainty in preparing GHG Disclosures
As discussed on page 57 of the Climate Statement, the GHG quantification is subject
to inherent uncertainty because of incomplete scientific knowledge used to determine
emissions factors and the values needed to combine emissions of different gases.
Our independence and quality management
This assurance engagement was undertaken in accordance with New Zealand
Standard on Assurance Engagements 1 Assurance Engagements over Greenhouse Gas
Emissions Disclosures, issued by the External Reporting Board (XRB) (NZ SAE 1). NZ
SAE 1 is founded on the fundamental principles of independence, integrity, objectivity,
professional competence and due care, confidentiality and professional behaviour.
We have also complied with the following professional and ethical standards and
accreditation body requirements:
• Professional and Ethical Standard 1: International Code of Ethics for Assurance
Practitioners (including International Independence Standards) (New Zealand);
• Professional and Ethical Standard 3: Quality Management for Firms that Perform
Audits or Reviews of Financial Statements, or Other Assurance or Related Services
Engagements; and
• Professional and Ethical Standard 4: Engagement Quality Reviews.
In our capacity as auditor and assurance practitioner, our firm also provides audit
services. Certain partners and employees of our firm may deal with the Group on normal
terms within the ordinary course of trading activities of the business. The firm has no
other relationship with, or interests in, the Group.
Assurance practitioner’s responsibilities
Our responsibility is to express a conclusion on the GHG Disclosures based on the
procedures we have performed and the evidence we have obtained. NZ SAE 1 requires
us to plan and perform the engagement to obtain the intended level of assurance about
whether anything has come to our attention that causes us to believe that the GHG
Disclosures are not fairly presented and are not prepared, in all material respects, in
accordance with NZ CSs, whether due to fraud or error, and to report our conclusion to
the Directors of the Company.
As we are engaged to form an independent conclusion on the GHG Disclosures
prepared by management, we are not permitted to be involved in the preparation of the
GHG information as doing so may compromise our independence.
Summary of work performed
Our limited assurance engagement was performed in accordance with NZ SAE 1, and
ISAE (NZ) 3410 Assurance Engagements on Greenhouse Gas Statements. This involves
assessing the suitability in the circumstances of the Group’s use of NZ CSs as the basis
for the preparation of the GHG Disclosures, assessing the risks of material misstatement
of the GHG Disclosures whether due to fraud or error, responding to the assessed
risks as necessary in the circumstances, and evaluating the overall presentation of the
GHG Disclosures.
A limited assurance engagement is substantially less in scope than a reasonable
assurance engagement in relation to both the risk assessment procedures, including
an understanding of internal control, and the procedures performed in response to the
assessed risks.
The procedures we performed were based on our professional judgement and included
enquiries, observation of processes performed, inspection of documents, analytical
procedures, evaluating the appropriateness of quantification methods and reporting
policies, and agreeing or reconciling with underlying records. In undertaking our limited
assurance engagement on the GHG Disclosures, we:
• Obtained, through enquiries, an understanding of the Group’s control environment,
processes and information systems relevant to the preparation of the GHG
Disclosures. We did not evaluate the design of particular control activities, or obtain
evidence about their implementation;
CLIMATE STATEMENT 202560 Contents

Independent Assurance Report (continued)
• Evaluated the Group’s assessment of organisational and operational boundaries to
assess completeness of GHG sources;
• Evaluated whether the Group’s methods for developing estimates are appropriate
and had been consistently applied.
• Tested a limited number of items to, or from, supporting records, as appropriate;
• On a sample basis, we compared the underlying records to other information
sources in the Group for consistency and to establish that emission sources had not
been omitted;
• For a selection of locations, performed analytical procedures on particular emission
categories by comparing the actual activity data on a quarterly basis against an
average trend for the same period;
• Assessed all emission factor sources and reperformed the emissions calculations for
mathematical accuracy;
• Enquired with management on the nature of the restatements to the comparative
GHG Disclosures and inspected the supporting documentation and calculations that
we were provided with; and
• Considered the presentation and disclosure of the GHG disclosures.
The procedures performed in a limited assurance engagement vary in nature and
timing from, and are less in extent than for, a reasonable assurance engagement.
Consequently, the level of assurance obtained in a limited assurance engagement
is substantially lower than the assurance that would have been obtained had we
performed a reasonable assurance engagement and does not enable us to obtain
assurance that we would become aware of all significant matters that we otherwise
might identify. Accordingly, we do not express a reasonable assurance opinion on these
GHG Disclosures.
Inherent limitations
Because of the inherent limitations of an assurance engagement, together with the
internal control structure, it is possible that fraud, error or non-compliance may occur
and not be detected.
Who we report to
This report is made solely to the Company’s Directors, as a body. Our work has been
undertaken so that we might state those matters which we are required to state to them
in our assurance 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 Directors, as a body, for our procedures, for this report, or for the conclusions
we have formed.
The engagement partner on the engagement resulting in this independent assurance
report is Victoria Ashplant.
For and on behalf of:
PricewaterhouseCoopers Auckland
27 November 2025
CLIMATE STATEMENT 202561 Contents

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