Ensuring
Disaster
How insurance companies areaccomplices in climate crimes

Briefing by Greenpeace Nordic
May 2023
Ensuring Disaster – How insurance companies are accomplices in climate crimes

1Companies
ensuring disasterGreenpeace is an independent global campaigning network thatacts to change attitudes and behaviour, to protect and conserve
the environment and to promote peace.
© Greenpeace Nordic, May 2023
Box 15164, 104 65 Stockholm, Sweden
www.greenpeace.se

This report is endorsed by Insure our Future, Urgewald andReclaim Finance. We are grateful for the valuable input andfeedback.

Ensuring Disaster – How insurance companies are accomplices in climate crimes

SUMMARYThis report, for the first time, presents a comprehensive mapping of how the finance and insurance industry is enabling new oil and gas projects in Norway. By
underwriting insurance policies they are making themselves accomplices of the climate crimes committed
by the oil and gas industry and ensuring disaster.
By law, companies operating in the Norwegian oil andgas sector are obliged to submit documents declaringthat their operations are insured, Certificates of Insurance, to the authorities. Using Freedom of Information,
Greenpeace Nordic obtained copies of the certificates
for all large companies operating in Norway as of 2022.
Based on this information we identified 69 insurancecompanies that are, directly or through Lloyd’s syndicates, insuring oil companies planning to establish newoffshore oil and gas fields in Norway.
Together the new fields hold about 3 billion barrels ofoil equivalent. In terms of greenhouse gas emissions,they represent some 1.3 billion tons of CO2 when combusted, excluding emissions from production.

No new oil and gas
Opening new oil and gas projects is contradictory toreaching the 1.5 degree target of the Paris Agreement.
The International Energy Agency (IEA), United Nations
Environment Programme (UNEP), United Nations
Intergovernmental Panel on Climate Change (IPCC)
and many others have shown that each new oil andgas field increases the risk of making large parts ofEarth uninhabitable for humans and causing ecologicaldevastation.
In a key report from 2021, IEA concludes “there can be
no new investments in oil, gas and coal, from now –from this year.” On the same note, UNEP demonstrates
that between now and 2030 global production of oil
and gas must decline by 4% and 3% per year respectively, with developed economies such as Norway reducing supply most rapidly. UNEP urges governments
to implement initiatives to “end of fossil fuel production
and the end of financing fossil fuel infrastructure”.
Many researchers and think-tanks have come to thesame conclusion: there is no room for new oil and gas
fields, not anywhere in the world and certainly not inrich countries, such as Norway.

Accomplices
The main responsibility lies with the Norwegian
government and the oil companies that disregard theeffects of their business on the climate. The companies
include the usual suspects; Equinor, Aker BP, Vår Energi, Petoro, Shell, TotalEnergies and so on.
But there are also accomplices in this crime against theclimate, not least in the finance sector. One of the mostimportant businesses in this respect, acting behind thescenes, are the insurance companies. None of the new
projects could be realised if they honoured the Paris
Agreement and followed the recommendations of IEA,UNEP and IPCC by refusing to underwrite insurance
and reinsurance policies for companies that pursue toopen new oil and gas fields.
By accepting to underwrite, they are in fact enabling
the wrongdoing and thereby become accomplices of
the government and the fossil fuel industry in climate
crimes.
Among the culprits we find some of the largest insurance companies in the world, such as Lloyd’s, Allianz,
Zurich, SCOR and AIG. They have known about climatechange, and their role in it, for decades, but still they
seem to value cash over climate.
Lloyd’s deserves a special note. 51 of its syndicates,
managed by 28 companies, are involved in 35 out of
the 38 new projects. Among the insured companies is
Aker BP, which by itself owns 30% of the resources in
the projects being planned and operates half of them.
This makes Lloyd’s the most important actor in the
new oil and gas projects.

Time to move away
The world has found far more fossil fuels than we canever use to avoid catastrophic climate change above
1.5°C. The Norwegian government’s policy of continued
exploration for even more fossil fuels, and its approvalof new oil fields, is a clear violation of their own commitments to tackle climate change.
But the Norwegian government is not the only actor
responsible for the continued expansion of fossil fuels:
It is dependent on finance and insurance from externalsources in order to realise the plans.
The time is well overdue for insurance companies andother financial actors to move away from fossil fuels.

Ensuring Disaster – How insurance companies are accomplices in climate crimes3

69 companies ensuring disaster
Aegis

Energy Insurance Oslo

Oman Insurance

AIG

ENI Insurance

OpEnergy

Allianz

Equinor Insurance

Pan

Amlin

Everen

Polski Gaz TUWAntares

FidelisQBE Marine

Apollo

Gard

Scor

Arch

Hamilton

SI Insurance

Argenta

Hardy

SiriusArgo

HDI Global

Sompo International

Ark

Helvetia

SoonerAspen

HiscoxStarr

AtriumHudsonStarr

AXAInternational General Insurance

Swiss Re

Axis

IQUW

TalbotBarbicanKerseyThe Hartford

Beazley

Korean Re

Thomas Miller Specialty

Berkley

Lancashire Insurance

Thomas Miller, Lloyd’ Consortium

Brit

Liberty Mutual

Tokio Marine

Canopius

Lloyd’s Insurance Company

Travelers

CatlinLloyd’s of London

Vienna Insurance

ChaucerMarkelWarta

Conopius

Navigators

Zurich Insurance

ConvexNOA

DB Insurance

Odyssey

Ensuring Disaster – How insurance companies are accomplices in climate crimes

4Ensuring
Disaster
How insurance companies areaccomplices in climate crimes

CONTENT
Background............................................6
The North Sea. History, status and developments in
Norwegian oil and gas sectors, politics etc.

Fossil phase-out ...................................9
The Paris Agreement, IEA Net Zero Report and otherreports with the same message.

Passing the tipping point ..................11
New permits for oil and gas in Norway, companies,
areas, amounts, timeline etc.

The accomplices ................................ 15
The insurance companies enabling crimes against theclimate.

Findings and demands .................... 21
Key findings and Greenpeace Nordic demands on
insurance companies, oil industry and politicians.

Ensuring Disaster – How insurance companies are accomplices in climate crimes

5Greenwich meridian

BACKGOUNDThe North Sea region contains the majority of Europe’s
oil and gas reserves and is one of the largest nonOPEC producing regions in the world. While there aresome reserves in the waters of Germany, Denmarkand the Netherlands, the vast majority belong to theUnited Kingdom and Norway.

Barents Sea

Norwegian Sea

Arctic circle

Combined, oil and gas extraction in the North Sea,
Norwegian Sea and Barents Sea (hereafter referred toas NNB) currently produce approximately 4% of global
oil and gas, almost exclusively from Norway and theUK.1 This puts the region and these countries among
the most important producers of hydrocarbons in theworld, meaning huge national revenues.

North Sea

Early days
The existence of fossil deposits in the North Sea has
been known for centuries, evidenced by oil seeps fromcoal beds on either side of the sea. Extraction of gas on
an industrial scale started onshore in the Netherlandsin the late 1950’s. Soon it became evident that thegas fields extended into the North Sea and offshore
extraction started in the early 1960’s, eventually leading
to the discovery of oil.
Extraction of oil started in the Netherlands and UK, but
was limited. Offshore drilling was difficult and expensive while oil prices were low throughout the 1960’s
and the first years of the 70’s. Then the oil crisis hit
Europe and meant increasing prices, leading to a boomin North Sea oil and gas extraction.
According to the International Hydrographic Organization, the North Sea stretches from Dover and Calais in
the southwest, along the coasts of Belgium, the Netherlands, Germany, Denmark, eastern UK and Norway.
The northern limit officially follows the 61st parallelfrom the Shetland Islands to the Norwegian coast
north of Bergen. In the oil and gas industry, however,the limit is commonly set a bit further north, at the 62ⁿd
parallel.
In the 1990’s exploration and drilling expanded into theNorwegian Sea and since the early 2000’s exploitation
has moved on to Arctic waters and the Barents Sea.
Together with minor fields in the Irish Sea, these areas
are sometimes referred to as the extended North Sea
region.

The NNB region, Greenpeace Nordic

Reserves
The major oil and gas reserves in the region are locatedin the northern part of the North Sea, between thenorthern UK and Norway, while the southern part ofthe sea predominantly carries gas.
Today the region holds approximately 0.6% of theworld’s proven reserves of oil and 1% of gas reserves.2
Most of it – 70% of the oil and 90% of the gas – islocated in Norwegian territory and primarily in the geographic North Sea. Proven reserves in the Norwegian
Sea and Barents Sea are minor by comparison: 20% of
Norway's oil reserves and 30% of its gas.3
Turning to the three NNB countries with smaller reserves, Denmark, Germany and the Netherlands havebeen reducing production, meaning reserves could lasta decade or two. In the Netherlands’ exclusive economic zone (EEZ) there is very little oil and 80 percent of thegas reserves have been extracted, leaving gas that may
also last a decade.4 German reserves consist mostly ofgas and will only last a few years at the current rate ofproduction. See table 1.
However, the amount of proven reserves changes overtime as oil and gas are extracted and new fields are
discovered. It is believed that the central and northernparts of the NNB hold large amounts of oil and gas thathave not yet been discovered or proven.

Ensuring Disaster – How insurance companies are accomplices in climate crimes

6Figure X. Production by country 1972–2020, billion cubic metregas and oil. (DE figures now include onshore extraction.)
Barents Sea
UK

Even though the NNB only holds 0.6% of the world’s
known oil reserves, production in the region was 3.1
billion barrels in 2020, 3.6% of global output. Similarly,
the production of gas was proportionally much greaterthan the proven reserves: 4.5% of global production.8

Norway

Nor
we
gia
nS

ea

100

50

NL

DE

DK

1972

1996

than 50% and deliveries of gas are down by almost
40%, figure 1.

2020

Source: bp Statistical Review of World Energy 2021.

North Sea

North Sea Region EEZ borders and 61st parallel. Source: Marine Regions

Table 1: Proven NNB reserves of oil and gas by country, (billion
barrels oil equivalent, boe), 2020. Figures include onshore.5
Country

Oil

Gas

Sum

Norway

7.9

9.2

17.1

United Kingdom

2.5

1.3

3.8

Netherlands

n.a.

0.7

0.7

Denmark

0.4

<0.3

<0.7

Germany

n.a.

<0.3

<0.3

Total

10.8

<11.8

<22.6

Denmark, Germany, Netherlands and the UK are net
importers of oil and gas. The amounts produced inthese countries are insufficient to supply the national
consumption.
Only Norway is a net exporter, sending 92 percent of
its production abroad, representing more than half ofthe country’s exports.9, 10 Norway is the third largest
exporter of fossil gas in the world, behind Russia andQatar. In Europe, North Sea oil and gas production
corresponds to 20% and 27%, respectively, of oil andgas consumption.11
All coastal states have the right to exploit natural
resources within their EEZ, but the level of regulationdiffers between countries. Since extraction of oil started
in the early 1970's, Norway has aimed to control andmaximise extraction through strong regulation, primarily by participation and ownership through the stateowned company Equinor.12
Figure 1. Production by country 1972–2020, billion cubic metregas and oil. (DE figures include onshore extraction.)

Source: BP Statistical Review of World Energy 2021.

Thus, the Norwegian Petroleum Directorate claims that
there are approximately 17 billion boe of oil and gas thatcan be extracted in the country's EEZ, almost half of itin the Barents Sea.6
By comparison, unproven reserves in Denmark,
Netherlands and Germany are expected to be small,possibly enabling a minor extraction in decades tocome. The potential is not significant given the limited
EEZ of these countries.

Production
Production in the NNB peaked in the early 2000’s,
reaching a daily production of 6.4 million barrels of oilin the year 2000 and 4.8 million boe of gas in 2004.7
Since then, production of oil has decreased by more

UK

Norway

100

50
NL
DE
1972

DK
1996

2020

Source: BP Statistical Review of World Energy 2021.

Essentially, the Norwegian state controls the industry
and there is a requirement that fields must be fully
exploited as long as there is any recoverable oil or gas
left.13 This approach creates long term stability.
All of the five nations extracting gas and oil from the
NNB operate tax and royalty licensing regimes, dividing
their respective EEZ’s into squares, or quadrants, by

Ensuring Disaster – How insurance companies are accomplices in climate crimes

7median lines agreed in the late 1960's. The schemes
vary between nations to some degree.
Each such quadrant is then divided into a number ofblocks where the governments can approve exploration. Such a license gives the owner, the licensee,
exclusive rights to exploration and extraction, but often
there are several owners to each license. The exploration and extraction is then carried out by operators.
Figure 2. Production of NNB oil and gas 2020 by country, thousand boe per day. Includes some onshore, Germany and UK.

majors and public exploration- and production companies (E&P) have been pulling out of the region for overa decade. To some extent a new breed of companies
are picking up the pieces in what the Financial Times19
calls a changing of the guards: private E&P backed bydeep-pocketed and opportunistic private equity funds.

Revisiting the treasure trove
With energy prices soaring in the wake of the war in
Ukraine and disruption of deliveries of Russian fossil
fuels, it has become tempting for some investors to engage in the post-invasion scramble to replace Russian
oil and gas with NNB production.
The European Union has adopted a strategy to ramp
up the speed of the transition away from fossil fueldependency altogether. As put by the Executive
Vice-President for the European Green Deal, Frans
Timmermans: “Let’s dash into renewable energy atlightning speed.” 20

Source: BP Statistical Review of World Energy 2021

Industry
Today it is estimated that there are 8,200 wells and
1,350 offshore installations14 15 and despite the fall in
production, the industry still plays a major part in theregion, employing tens of thousands of people. In the
UK and Norway alone, it is estimated that there are
more than 3,000 companies involved in the value
chain. In Norway, UK and Denmark the industry
employs approximately 385,000 persons directly or indirectly.16 In Norway about 20,000 persons are directly
engaged with extraction.17

On the other hand, some governments in European
countries with fossil fuel reserves, most notably Norway, have thrown caution to the wind and are issuing
new licenses for extraction of gas and oil in new
areas.21
Undoubtedly money is a key driver. Oil and gas havemade Norway one of the richest nations on Earth, but it
still has large and tantalising fossil reserves lying in theshallow waters of the choppy North Sea, Norwegian
Sea and in the Arctic. Prices are high and the government sees a last chance to plunder the treasure trove.

The NNB oil and gas industry has experienced years,
even decades, of uncertainty and turbulence. When the"never-ending" output from the region started to slow
down twenty years ago, questions about the potentialof the sea area started to trouble oil and gas companies.
Extraction had been among the most cost-efficientin the world, but in the late 2000's and early 2010's
costs were sky-rocketing while oil-prices were low,or at best, volatile.18 The new economic environment
caused an exodus of oil majors from the region. Oil
Ensuring Disaster – How insurance companies are accomplices in climate crimes

8

FOSSIL PHASE-OUT
Since fossil fuels are the main culprit of climatechange, attempts are being made globally to reduce
the use of gas, oil and coal. In 2015 a legally binding
international treaty on climate change was adopted
by 196 Parties at the UN Climate Change Conference(COP21) in Paris, France. Deemed the Paris Agreement, it entered into force on 4 November 2016.
The overarching goal is to hold “the increase in the
global average temperature to well below 2°C above
pre-industrial levels” and pursue efforts “to limit thetemperature increase to 1.5°C above pre-industrial
levels.”In recent years, scientists and conscientious world
leaders have stressed the need to limit global warming to 1.5°C by the end of this century. That’s because
the UN’s Intergovernmental Panel on Climate Change(IPCC) indicates that crossing the 1.5°C threshold risks
unleashing far more severe climate change impacts,
including more frequent and severe droughts, heatwaves and rainfall.
According to the United Nations, limiting global warming to 1.5°C means that greenhouse gas emissions
must peak before 2025 at the latest, and decline 43%
by 2030.22
Subsequently, the IPCC assessed what the 1.5°C
commitment means in terms of climate effects andmitigation. Its findings were published in the Special
Report on 1.5°C in 2018 and stated that 600 gigatons of
CO2 may be released when settling for a 50/50 chanceof limiting heating to 1.5°C.23 That more or less equals
the amount released in 14 years at the present level ofglobal emissions.

The IEA Net Zero Report
While that was definitely an important and alarming
message, it was not very conclusive on what thebudget for energy production and the use of oil and gas
is. On 18 May 2021, the International Energy Agency(IEA) published a roadmap – the IEA Net Zero Emissions report (NZE) – outlining how to reach global net
zero emissions by 2050 and the 1.5°C target, including
what it meant in reality for energy production.24
The IEA is an intergovernmental body established in1974 by the OECD, today with 31 member countries and9 associate member countries over the entire world. It
is considered by governments, authorities and industry
worldwide to be the foremost experts on global energy
issues, mostly known for its annual hallmark report
Energy Outlook.
To keep warming in line with 1.5°C, the IEA urges that
there can be no new investments in oil and gas fields
after 2021. It also states that by 2050 gas production
must decline by 55% and oil production by 75%.
Put clearly, the verdict from the global authority on energy is that the present wellbores pumping up reservesin licensed fields may go on. But, no new oil and gas
fields may be developed from 2021. Or, in the words ofthe IEA chief Fatih Birol: “If governments are serious
about the climate crisis, there can be no new investments in oil, gas and coal, from now – from this year.”25
Some nations have already seen the writing on the walland decided to enforce national bans on exploration or
extraction (table 2). But apparently Norway has decided
to neglect the advise from the IEA and is still issuinglicenses for new developments and extensions of old
ones.26

Echoes
The conclusions in the IEA NZE report have been confirmed and echoed by other organisations, reports andscientific studies. In October 2021 the United Nations
Environmental Programme (UNEP) concluded that"[g]overnments plan to produce more than twice theamount of fossil fuels in 2030 than would be consistent
with limiting warming to 1.5°C." 27 The international
body also stated that "Governments have a primaryrole to play in closing the production gap and in ensuring that the transition away from fossil fuels is just andequitable."
The UNEP report demonstrated that between now and2030, global production of oil and gas must decline
by 4% and 3% per year respectively, with developed
economies such as the NNB countries reducing supply
most rapidly.
Similarly, an assessment28 published by the Tyndall
Centre for Climate Research found that the 1.5°C target
in the Paris Agreement requires "immediate and deep
cuts in the production of all fossil fuels. There are no
exceptions; all nations need to begin a rapid and justphaseout of existing production."

Ensuring Disaster – How insurance companies are accomplices in climate crimes

9The report makes it absolutely clear that there is no
capacity in the carbon budget for opening new production facilities of any kind, and adds: "A transition basedon principles of equity requires wealthy, high-emitting
nations to phase out all oil and gas production by
2034 while the poorest nations have until 2050 to end
production."and that the window is closing. The organisation urges
governments to “initiate, sign and implement international initiatives on coal phase-out, the end of fossil
fuel production and the end of financing fossil fuelinfrastructure”.30

According to Tyndall, all NNB countries are considered
to belong to the wealthiest group of producer nations,also having the highest capacity to achieve a just transition. For these countries "output of oil and gas needs
to be cut by 74% by 2030, with complete phase out by
2034."
Also, a scientific paper in Nature29 found that globally
nearly 60% of oil and fossil methane gas must remain
unextracted to keep the world within a 1.5°C carbon
budget.
In the paper, the scientists estimate that oil and gas
production must decline globally by 3% each year until
2050 and state that "[t]his implies that most regions
must reach peak production now or during the next
decade, rendering many operational and planned fossil
fuel projects unviable."
For Europe, including the NNB, the paper estimatesthat 72% of the known reserves of oil and 43% of gas
reserves must be left in the ground.
In an assessment of the gap between what measures
are needed to achieve the Paris Agreement and what
is happening on the ground, UNEP concludes thatmuch more needs to be done to reach the 1.5°C target

Table 2: Country announcements of moratoria or sunsets of oil and gas exploration or extraction.
Country

Commitment

Fossil gas production
global ranking in 2019

Crude oil production
global ranking in 2019

BelizeExploration ban from 2017

n/a

82

Costa Rica

Moratorium on exploration and exploitation

n/a

n/a

DenmarkPhase-out extraction by 2050

56

42FrancePhase-out by 2040

90

70

Greenland

Exploration ban from 2021

n/a

n/a

Ireland

Fracking ban from 2017 and offshore from 2018

58

n/a

New Zealand

Exploration ban from 2018i

52

73

Spain

Exploration ban from 2021 and phase out by 2042

78

78

SwedenExtraction ban from July 1, 2022

n/a

n/a

Source: Stockholm Environment Institute, North Sea Oil and Gas Transition (2022)

Ensuring Disaster – How insurance companies are accomplices in climate crimes

10

PASSING THE TIPPINGPOINT
In accordance with the findings of the IEA and scientific evidence, no new oil and gas fields should be
developed anywhere in the world from 2021 in order toreach the UN 1.5°C target. Doing so will jeopardize thetarget and risks throwing the world into a potentiallydisastrous climate chaos.
Norway leads one of the world’s most aggressive policies of fossil fuel expansion. Over the past ten years,
the Norwegian government has exponentially increased exploration licenses – even pursuing oil drillingin the vulnerable Arctic.31
The International Energy Agency, the IPCC’s sixth assessment report, as well as a number of other scientificpublications, all highlight that the world has alreadyfound more oil, coal and fossil gas than can ever beused when limiting global warming to 1.5°C. Licensing new fields for investments is a blatant violation ofclimate science and ambitions.

Norwegian government enacted a Covid Crisis Package
in 2020, including a temporary tax subsidy with the aimof increasing oil drilling even further.35 The policy guaranteed tax breaks for petroleum projects that coulddeliver Plans for Development and Operation (PDO) by
the end of 2022, causing a historic influx of applications.
Since 2021 the government is issuing new permits as
if it were living in the 1960’s. In 2023 the number ofapplications for new installations is expected to be awhopping 32, more than three times higher than everbefore (figure 3).
Figure3. Historic and expected number of new installations by
40
year of license, 1971–2023.
30

20

10

1971

2023

Source: WWF/Rystad Energy, NRK.

Norway’s fossil bonanza
Research from UNEP indicates that Norway is the bestequipped nation in the world to start a just transition
away from oil.32 With a highly educated population,huge capital, democratic institutions and an enormous
potential for renewable energy production, Norway
should be the first country to phase out fossil fuels
once and for all.
But Norway is going the other way. While committing
to reduce its own emissions in line with the Paris
Agreement, the Norwegian government is encouraging the oil industry to ramp up production of fossil
fuels, mainly for exports. According to data from the UN
Development Programme (UNDP), Norway was thelargest per capita exporter of CO2 emissions in 2021.33
Over the past 10 years, the Norwegian government
has awarded 700 exploration licenses. The oil and gas
within fields that are licensed, but not yet developed,
could lead to an additional 3 billion tons (Gt) of CO2
emissions.34 This equals 60 times Norway’s annual
domestic emissions.
Disregarding the effects on Earth’s climate and warnings from the IPCC and many other institutions, theDefying science
This policy is in contempt of the conclusions of the
IPCC AR6, the Paris Agreement and what the world’s
most prestigious energy experts, IEA, concluded in May
2021: The road to 1.5°C requires that all nations refrainfrom allowing new gas and oil developments after
2021.

Scope 3 emissions
Emissions of greenhouse gases can be disclosed in threeways, scope 1, 2 and 3. Scope 1 shows the direct emissions
from the activity, scope 2 shows emissions from upstream
activities, such as power consumption etc. Scope 3 reveals
emissions downstream, i.e. the emissions released when
the product is consumed.
Oil companies are keen top point out that emissions fromtheir production (scope 1 and sometimes also scope 2) arebeing reduced. However, emissions from the use of theirproducts (oil and gas) are proportionate to production.
For example: According to Equinor’s Sustainability Hub,the company’s scope 1 and 2 emissions have been reduced
from 15.7 million tons of CO2 in 2016, to 11.4 million tons
in 2022. During the same period, scope 3 emissions haveincreased from 239 to 243 million tons.

Ensuring Disaster – How insurance companies are accomplices in climate crimes

11

As a result of the new policy, 38 applications for licenses concerning new fields were submitted before theend of 2022. According to the Norwegian Directorateof Petroleum, one of the projects, Gråsel, was up andrunning already in 2021. A few of the remaining projects
have started to operate since 1 January 2022, but mostare still developing or waiting for approval. All are expected to start operations before 2028. Their expected
production lifetimes vary depending on size, with thelargest predicted to last until the year 2059.
According to specifications from the Directorate, theseprojects hold approximately 3.1 billion barrels of oil
equivalent. In terms of greenhouse gas emissions, they
represent about 1.3 billion tons of CO2 when used for
combustion.36
A total of 21 oil and gas companies,37 forming partnerships with 2 to 5 partners in each project, stand behind

Table 3: Companies, number of involvements, reserves asowners and number as operator in fields with licenses granted
or pending from January 1, 2022, million boe and number ofprojects. (Check and update)Company

Projects

Owner

Operator

Aker BP

20

944.8

19

Equinor

18

812.9

10

Petoro

15

371.3

–

Vår Energi

10

290.9

1

PGNiG

8

135.6

–

Wintershall Dea

10

128.6

3

TotalEnergies

6

109.1

–

ConocoPhillips

5

80.9

2

Shell

2

61.9

1

Sval

6

48.9

–

Lotos

2

39.8

–

Pandion

2

24.6

–

OMV

3

20.7

1

Neptune

2

17.9

–

DNO

3

17.3

–

Mime

1

16.4

–

Wellesley

1

16.2

–

Lime

2

6.5

–

OKEA

1

4.8

1

Spirit1

3.0–

M Vest2

1.0–

3,153.1

38

Total

the applications, table 3. The companies are of varying
size, from minor operators to huge multinationals suchas Shell, Equinor and ConocoPhillips. They each own
large or small shares of the licenses and assign one ofthe partner companies as the operator of the field.
Our assessment shows that the Norwegian oil company Aker BP has the biggest ownership of licenses
for new oil and gas fields, holding 944.8 million boe.
In second place comes Equinor, owning resources
amounting to 812.9 boe. Together, these two companies are owners of 56% of the resources, see table 3.
Aker BP is also the biggest operator. With 19 fields, it
operates, or will operate, half of the planned projects.
Tables 3 and 4.
Most of the projects, 20 of them, are located in the
North Sea, while 17 are in the Norwegian Sea and one
is in the Barents Sea (figure 4). The dominant role ofplanned operations in the North Sea is also reflectedin the amount of reserves, where the three areas hold2,046, 971 and 133 mboe respectively.

Figure 4: Areas where licenses for start-ups from 2022 have been approved or are in the process of approval, April 2023. Greenpeace Nordic.

Source: Greenpeace Nordic/Energi24

Ensuring Disaster – How insurance companies are accomplices in climate crimes

12Table 4: New license applications with start-up after 1 January 2022.
Area

Project name

Owners and operators, (percent)North Sea

Tommeliten Alpha

Norwegian Sea

Size, mboe

Approval

Start

ConocoPhillips (28.3), PGNiG (42,2),
TotalEnergies (20.2), Vår Energi (9.1)

133.7

08.07.2022

2024

Frosk

Aker BP (80), Vår Energi (20)14.8

08.07.2022

2023

Kobra Øst and Gekko

Aker BP (80), ConocoPhillips (20)45.2

10.02.2022

2024

Breidablikk

Equinor (39), Vår Energi (34.4), Petoro(22.2), ConocoPhillips (4.4)

200

29.06.2021

2024

HOD

Aker BP (90), Pandion Energy (10)39.4

08.12.2020

2022

Eldfisk Nord

ConocoPhillips (35.1), TotalEnergies(39.9), Vår Energi (12.4), Sval (7.6),
Petoro (5)55.9

01.11.2022

2024

Balder FutureVår Energi (90), Mime Petroleum (10)16418.06.2020

2024

Solveig phase 2

Aker BP (65), OMV (20), WintershallDea (15)

29.7

Pending2026

Oseberg phase 2

Equinor (49.3), Petoro (33.6),
TotalEnergies (14.7), ConocoPhillips
(2.4)

196.2

01.12.2021

2026

Tyrving

Aker BP (61.3), PGNiG (11.9), Petoro(26.8)

25

Pending2025

Valhall PWP

Aker BP (90), Pandion Energy (10)207

Pending2027

Fenris, Valhall

Aker BP (77.8), PGNiG (22.2)

160

Pending2027

Hugin, Yggdrasil

Aker BP (87.7), Lotos (12.3)

238.9

Pending2027

Munin, Yggdrasil

Aker BP (50), Equinor (50)330.3

Pending2027

Fulla, Yggdrasil

Aker BP (45.5), Equinor (40), Lotos(12.3)

84.9

Pending2027

Symra, Utsirahøyden

Aker BP (50), Equinor (30), Sval (20)87

Pending2027

Troldhaugen, Utsirahøyden

Aker BP (80), OMV (20)

Included above

Pending

2026

Hanz

Aker BP (35), Equinor (50), Spirit
Energy (15)20

Pending2024

TelestoEquinor (53.2), Petoro (30),
ConocoPhillips (9.1), Repsol (7.7)

9.8

Pending2022

Talisker Øst

Wintershall Dea (35.2), Lime (33.8),
DNO (14,3), Vår Energi (12.3), M
Vest (4.4)

4Pending2022

Ormen Lange phase 3

Shell (17.8), Petoro (36.5), Equinor(25.3), PGNiG (14), Vår Energi, 6.3)

210.1

08.07.2022

2025

Kristin Sør

Equinor (52), Petoro (27), Vår Energi(15), TotalEnergies (6)58.2

02.02.2022

2024

Hasselmus

OKEA (44.6), Petoro (47.9), M Vest
Energy (7.6)

10.8

05.11.20212023GråselAker BP (23.8), Equinor (36.2),
Wintershall Dea (28.1), PGNiG (11.9)

15

30.04.2021

2021

Halten Øst

Equinor (57.7), Petoro (5.9), Vår Energi(24.6), Spirit Energy (11.8)

100

13.02.2023

2025

Ensuring Disaster – How insurance companies are accomplices in climate crimes

13

Table 4 (continued): New license applications with start-up after 1 January 2022.
Area

Barents Sea

Project name

Owners and operators, (percent)Dvalin Nord phase 1

Wintershall Dea (55), Petoro (35),
Sval (10)Alve Nord, Skarv

Size, mboe

Approval

Start

84

Pending

2026

Aker BP (88), PGNiG (12)26

Pending2025

Ørn, Skarv

Aker BP (30), Equinor (40),Wellesley Petroleum AS (30)54

Pending

2025

Shrek, Skarv

Aker BP (35), Lime Petroleum (30),PGNiG (35)17

Pending

2025

Idun Nord, Skarv

Aker BP (30), PGNiG (40), Equinor
(30)

Minor

Pending

2025

Idun Tunge, Skarv

Aker BP (23.8), Equinor (36.2),
PGNiG (11.9), Wintershall Dea (28.1)

6.6

Pending2023

Cape Vulture, Alve Nord Øst

Equinor (59.3 ), Petoro (22.4), Vår
Energi (10.5), Aker BP (7.0), PGNiG
(0.8)

50.6

Pending

2025

Irpa, Asterix

Equinor (51), Petoro (20), WintershallDea (19), Shell (10)245

Pending2026

Maria phase 2

Wintershall Dea (50), Petoro (20),
Sval (20)22.3

Pending2025

Smørbukk Nord

Equinor (35), Petoro (34.5), Vår Energi(22.6), TotalEnergies (7.8)

13.1

Pending2023Blåbjørn

Equinor (36.8), Petoro (30),
TotalEnergies (18.4), Neptune
Energy (12), Wintershall Dea (2.8)

15.6

Pending

2023

Berling, Hades-Iris

OMV (30), Equinor (40), DNO (30)49.3

Pending2026

Askeladd Vest

Equinor (36.8), Petoro (30),
TotalEnergies (18.4), Neptune (12),Wintershall Dea (2.8)

133.5

Pending

2024

Source: Greenpeace Nordic,/Energi24

Ensuring Disaster – How insurance companies are accomplices in climate crimes

14

THE ACCOMPLICES
Insurance companies play a crucial role in facilitating
the ongoing quest to establish new oil and gas projects, in spite of warnings from experts and scientists.
Without insurance, most new fossil fuel projects could
not proceed. By supplying insurance and reinsurance
for new gas and oil projects, insurance companies,
syndicates and brokers are making themselves accomplices and partners in climate crimes.
Exploration and extraction of offshore oil and gas has
always been associated with risks, not least financially.
A number of insurers offer tailored insurance programs
to help offshore energy operators protect their physicalassets as well as their legal liability. Key insurance
coverages include:• Physical Damage• Business Interruption/Loss of Production Income• Operators’ Extra Expense (Control of Well)• Offshore Construction• Liability• Environmental/Pollution Liability
While there are many insurance companies in the oiland gas insurance market, it is highly concentrated anddominated by a small number of very large companies.
Many have backed away from insuring new coal projects, but when it comes to oil and gas the momentum
is only starting in the insurance industry’s shift awayfrom fossil fuels. As of October 2022 the number ofcompanies excluding tar sands has risen from 14 to 22,
and the number of restrictions on conventional oil andgas has increased from 3 to 13 in the last year.38
According to Insure our Future, the scope and quality of these restrictions are uneven. While industry
heavyweights such as Allianz, Munich Re and Swiss
Re have adopted significant exclusions, other insurers,
including AIG, Lloyd’s of London, SCOR, Zurich and AXA
continue to insure new oil and gas projects in defianceof climate science and evidence.39

small, but weather, accidents and unforeseen incidents
can cause huge damages that would prove intolerable
for the companies carrying the insurance.
For example, the disastrous accident with BP Deepwater Horizon in the Gulf of Mexico 2010, reportedly cost
the oil company at least $65 billion.40
Insurance companies are, as a rule, very aware of risks
and contingencies and want to minimise their exposure. This may be done by only accepting a small partof the liability, setting a limit in the contracts and by, inturn, insuring themselves.
Insurance companies purchase reinsurance from otherinsurance companies to insulate themselves (at leastin part) from the risk of a major claims event. With reinsurance, the company passes on some part of its own
insurance liabilities to other insurance companies.
Generally there are many insurers and reinsurers,
which are in turn reinsured and in the end there aremany companies involved through a complex web of
insurance companies. For example, in the assessment
for this report we found that the operations of Vår Energi involve at least 53 companies.
Some major oil companies are insured by companies
they own, also known as “captive” insurance companies. These are wholly owned subsidiaries formed toprovide insurance for its parent company or related
entities, but still need reinsurance.
In this report there are five captive insurance companies: Equinor Insurance, ENI Insurance (ENI and Vår
Energi), Polski Gaz TUW (belonging to Polish stateowned PNK Orlen who in turn owns PGNiG and Lotos),
Sooner (ConocoPhillips), and PAN (TotalEnergies).
These companies are reinsured by other companies.
Additionally, Petoro is a wholly Norwegian state-owned
company, which manages the Norwegian state’s
portfolio of directly owned petroleum resources. Petoro
does not operate any petroleum licenses, and it isself-insured by the Norwegian state.

Insurance and reinsurance

The accomplices

Generally, companies that sign insurances with
offshore operations accept full coverage of the risks involved. Typically they cover physical loss or damage toinstallations, removal of wreck, cost of well control andthird party liability. Under normal conditions the risk is

Historically and globally it has been very difficult forcivil society and media to access information concerning the companies involved in underwriting insurances and reinsurances of fossil fuel projects. With thisreport, Greenpeace Nordic has for the first time been

Ensuring Disaster – How insurance companies are accomplices in climate crimes

15

able to create a detailed, although not complete, list of
many companies involved in insuring new gas and oil
projects in Norway.
By law, companies operating in Norway are obliged
to submit details about their insurance coverage,
Certificates of Insurance, to the authorities.41 Using theFreedom of Information, Greenpeace Nordic requested
to obtain copies of the certificates for all 21 companies
that were participating in the quest to open new oil andgas projects as of 2022.
Between November 2022 and May 2023 we received
17 certificates. Four companies had failed to fulfil their
obligation to submit the required documentation to theauthorities. The quality of the information in the ones
we received also varied a lot. See table 5.
Most of the certificates do not give specific names of
the insurers and reinsurers. Instead they simply statethat the insurance is supplied by “Lloyd’s Syndicatesand Insurance Companies”, “Various underwriters/insurers”, “First class international insurance companies
and Lloyd’s syndicates” etc. Others reveal a name ortwo, followed by “et al” or the same generic description
as above.
Of the 21 companies that are pursuing new oil and gas
fields in Norway, only one, Vår Energi, a Norwegiansubsidiary of the Italian oil company ENI, submitted acomprehensive list with details of insurers and reinsurers. Additionally PGNiG, which belongs to the Polishstate-owned company Orlen, and thus has a captive
insurance company, Polski Gaz TUW, submitted a list ofreinsurers. For the other 19 companies, the certificates
only reveal fragments.
The fact that many of the oil companies only submitted
scant information, or none at all, implies that many
more insurance companies than the ones we havebeen able to identify may be involved.

Table 5. Oil companies behind license applications with start-up after 1 January 2022. As stated in documents.
Oil company

Insurance

Reinsurance

Aker BP

Lloyd’s Insurance Company S.A. AFB 5361 et al

Not stated

ConocoPhillips

Sooner (captive)

Not stated

DNO

First class international insurance companies and Lloyd’s syndicatesNot statedEquinorEquinor Insurance (captive)

Everen

Lime

Not submitted

Not submitted

Lotos

Not submitted

Not submitted

LundinMerged operations with Aker BP

Not stated

M VestInternational Oil & Gas Underwriters

Not stated

Mime

Insurers in the London, Norwegian, European, Asian, and American markets.
Beazley (Lloyd’s syndicate AFB 2623 & AFB 623) being the Leading Insurer.

Not stated

Neptune

Lloyd’s syndicatesNot stated

OKEA

Not submitted

Not submitted

OMVFirst class international insurance companies and Lloyd’s syndicates / Vienna
Insurance GroupNot statedPandion

Lloyd’s syndicatesNot stated

PGNiG

Polski Gaz TUW (captive)

Extensive list

PetoroNorwegian state

Norwegian state

Shell

AIG

Not stated

Sval

Lloyd’s Insurance Company S.A. NOA 5375 and others

Not statedTotalEnergies

Pan Insurance DAC. For third party liability: Various Underwriters / Insurers (captive)

Not statedVår Energi

Extensive list

Extensive list

Wintershall DEA

O’Farrell Lloyd’s Syndicate 1036 and others

Not statedWellesley

Not submitted

Not submitted

Ensuring Disaster – How insurance companies are accomplices in climate crimes

16

Nevertheless the information obtained is the mostdetailed mapping of the insurance and reinsurance provided to oil and gas companies in any country, and thefirst of this type in Europe. It contrasts with the refusal
to provide information about insurance certificates inmany other European countries.
Transparency is crucial since it allows civil society, citizens and relevant local authorities to ensure that certificates of insurance, required by law, have indeed been
provided and that the oil and gas operators are able
to withstand even major accidents and have access to
sufficient resources to cover the potential damage tothe environment and livelihoods.
Without adequate insurance, the public risks paying
the damage when accidents related to operations
occur. Therefore the public has the right to know how
oil companies are insured.
Transparency is also vital to holding the finance sector,
including the insurance sub-sector, accountable to theprojects they are enabling. This is only becoming morepressing as the Norwegian oil sector is creeping closer

to the vulnerable ecosystems in the Arctic. Although
we recognise that the Norwegian government is now
providing basic insurance information, we hope to also
uncover more of the actors involved, hiding behind
formalistic smokescreens.

Insurers and reinsurers
Assessing the information in the certificates, we found
38 companies providing insurance for the oil companies involved in the new oil and gas projects. Additionally 22 insurance companies manage insurances
through syndicates with Lloyd’s Insurance Company
and, ultimately, Lloyd’s of London.
Regarding reinsurance, 19 insurance companies are reinsuring the projects, joined by another 23 companies
acting as syndicate managers through Lloyd’s Insurance Company and Lloyd’s of London. Some appear as
insurers as well as reinsurers, making the final numberof insurance companies involved 69. Many of them
are hardly known to the public, while others are wellknown and belong to the biggest in the world. Tables
6 and 7.

Image: Pavel Czerwinski
Ensuring Disaster – How insurance companies are accomplices in climate crimes

17

Table 6: Insurance companies and Lloyd’s syndicate managers
involved in insurance of new oil and gas projects in Norway withstart-ups from January 1, 2022.
Insurance; companies and Lloyd’s syndicates
Insuring company
AIG

Insurance; companies and Lloyd’s syndicates
InsuredShell, Vår Energi

Insuring company

InsuredLloyd’s syndicates, managers

AllianzVår Energi

Amlin, AML 5344

Vår Energi

Arch Insurance

Vår Energi

Antares, AUL 5323

Vår Energi

Axis

Vår Energi

Apollo, APL 5341

Vår Energi

Chaucer Insurance

Vår Energi

Argo, AMA 5319

Vår Energi

ConvexVår Energi

Aspen, ASP 5383

Vår Energi

DB Insurance

Vår Energi

Ark, ARK 5377

Vår Energi

ENI Insurance

Vår Energi

Ark, NOA 5375

Sval

Energy Insurance OsloVår Energi

Atrium, AUW 5310

Vår Energi

AXA, XLC 5345

Vår Energi

Equinor Insurance

EquinorFidelisVår Energi

Beazley, AFB 5361

Aker BPGardVår Energi

Beazley, AES 2623

Mime

HamiltonVår Energi

Beazley, AES 623

HDI Global

Vår Energi

Brit, BRT 5365

Vår Energi

Helvetia

Vår Energi

Brit, BRT 5366

Vår Energi

HudsonVår Energi

Catlin (AXA), XLC 5345

Vår Energi

International General Insurance

Vår Energi

Canopius CNP 5380

Vår Energi

KerseyVår Energi

Hardy, HDU 5303

Vår Energi

Korean Re

Vår Energi

Hiscox, HIS 5299

Vår Energi

Lancashire Insurance

Vår Energi

IQUW, IQU 5330

Vår Energi

Liberty MutualVår Energi

Navigators, HIG 5321

Vår Energi

Markel Insurance

Vår Energi

NOA, NOA 5375

Vår Energi

Lloyd’s Insurance Company

Many, see syndicates

QBE Marine, COF 1036

Mime

Wintershall Dea

Odyssey

Vår Energi

Sirius, SII 5338

Vår Energi

Oman Insurance

Vår Energi

Talbot, TAL 5318

Vår Energi

OpEnergy

Vår Energi

Thomas Miller, Consortium 7656

Vår Energi

Travelers, TRV 5000

Vår Energi

Pan
Polski Gaz TUW

TotalEnergies
PGNiG

QBE

Vår Energi

ScorVår Energi

Sompo International

Vår Energi

Sooner

ConocoPhillips

StarrVår Energi

Swiss ReVår Energi

Thomas Miller Specialty

Vår Energi

Tokio Marine HCC

Vår Energi

Vienna Insurance

OMV

Zurich Insurance

Vår Energi

Ensuring Disaster – How insurance companies are accomplices in climate crimes

18

Table 7: Insurance companies and Lloyd’s syndicate managers
involved in reinsurance of new oil and gas projects in Norway
with start-ups from January 1, 2022.
Reinsurance; companies and Lloyd’s syndicates

Reinsurance; companies and Lloyd’s syndicates
Company and syndicate

InsuredCompany and syndicate

Arch

PGNiG

Sirius, SII 1945

Vår Energi

Berkley

PGNiG

Talbot, TAL 1183

PGNiG, Vår Energi

ConvexPGNiG

Tokio Marine Kiln, TMK 0510

PGNiG

EverenEquinor

Tokio Marine Kiln, TMK 1880

PGNiG

Fidelis

PGNiG

Travelers, TRV 5000

Gard

PGNiG

Hamilton Insurance

PGNiG

International General Insurance

PGNiG

Liberty Mutual Insurance

PGNiG

Lloyd’s Insurance Company

InsuredVår Energi

Many, see syndicates

KerseyPGNiGMarkel

PGNiG

QBE

PGNiG

Scor

PGNiG

SI Insurance

PGNiG

Starr

PGNiG

Swiss Re

PGNiG

Tokio Marine

PGNiG

Warta

PGNiG

Lloyd’s syndicates, managers
Aegis, AES 1225

PGNiG

Amlin, AML 2001

PGNiG, Vår Energi

Antares, AUL 1274

PGNiG, Vår Energi

Apollo, APL 1969

PGNiG, Vår Energi

Argenta, ARG 2121
Ark, ARK 4020

PGNiG
Vår Energi

Aspen, ASP 4711

PGNiG, Vår Energi

Atrium, AUW 609

Vår Energi

AXA, XLC 2003

Vår Energi

Axis, AXS 1686

PGNiG

IQUW, IQU 1856

PGNiG, Vår Energi

Beazley, AFB 2623
Beazley, AFB 623

PGNiG
PGNiG

Brit, BRT 2987

PGNiG, Vår Energi

Brit, BRT 2988

Vår Energi

Brit, KII 1618
Canopius, CNP 4444 /5331
Hardy, HDU 382
The Hartford, HIG 1221
Hiscox, HIS 33
Lancashire, LRE 3010
NOA, NOA 3902

PGNiG
Vår Energi
PGNiG, Vår Energi
PGNiG
PGNiG, Vår Energi
PGNiG
PGNiG, Vår Energi

Ensuring Disaster – How insurance companies are accomplices in climate crimes

19

Lloyd’s of London
Strictly speaking, Lloyd’s of London, generally known
as Lloyd’s, is not an insurance company. Instead it isa society offering a market where members may poolinvestments to spread risk, grouped in syndicates.
Lloyd’s itself does not underwrite insurance business,leaving that to its members. Instead, the society operates as a regulator, setting rules under which members
operate and offering centralised administrative services
to its members.

This makes Lloyd’s the most important insurance partner in the quest for new oil and gas fields in Norway.
Table 8: New gas and oil projects from January 1, 2022. Company
insured by Lloyd’s and share in project, %.
Project insured

Company (operator)

Tommeliten

PGNiG, Vår Energi

Alve Nord
Frosk
Kobra Øst and Gekko
Breidablikk

Since Brexit in 2019, Lloyd’s has set up a company
in Brussels to allow the London-based syndicates tocontinue underwriting within the European Economic
Area (EEA). The company, Lloyd’s Insurance Company,
is based in Brussels and underwrites risks from all
EEA countries, that will then be reinsured back to thesyndicates in the Lloyd’s of London market.

HOD

In its first Environmental, Social and Governance (ESG)
Report, presented in 2020, the chairman stated that
Lloyd’s “will start to phase out insurance cover for,and investments in, thermal coal-fired power plants,
thermal coal mines, oil sands, or new Arctic energy
exploration activities. From 1 January 2022, Lloyd’s
managing agents will be asked to no longer provide
new insurance coverages or investments in these
activities.”42This promise was repeated in Lloyd’s second ESG
report in 2022, where it was also stated that existing
cover for such activities will not be phased out before
2030.43
A report by London based insurance broker Alesco
noted that while many Lloyd’s members have adopted
the policy, others continue to accept new coal business.44 According to Insure Our Future, Lloyd’s policy
on underwriting fossil fuel projects is ranked 25 among
the world’s 30 leading fossil fuel insurers.45
The documents retrieved by Greenpeace Nordic revealthat 51 Lloyd’s syndicates, managed by 28 insurancecompanies, are currently underwriting insurance andreinsurance polices for companies that are pursuing
new offshore projects.

Aker BP, PGNiG
Aker BP, Vår Energi
Aker BPVår Energi
Aker BP

Eldfisk Nord

Sval, Vår Energi

Balder Future

Mime, Vår Energi

Solveig phase 2
Tyrving

Aker BP, OMV, WintershallAker BP, PGNiG

Valhall PWP

Aker BP

FenrisAker BP

Hugin

Aker BP

Munin

Aker BP

Fulla

Aker BP

Symra

Aker BP, Sval

Troldhaugen

Aker BP, OMV

Hanz
Talisker Øst
Ormen Lange phase 3
Kristin SørGråselHalten Øst
Dvalin Nord phase 1

Aker BPVår Energi, DNO
PGNiG, Vår Energi
Vår Energi
Aker BP, PGNiG, WintershallVår Energi
Sval, Wintershall Dea

Ørn

Aker BP

Shrek

Aker BP

Idun Nord

Aker BP

Idun Tunge

Aker BP, Wintershall Dea

Cape Vulture

Aker BP, PGNiG, Vår Energi

Irpa
Maria Phase 2
Smørbukk NordBlåbjørn
Berling
Askeladd Vest

Wintershall Dea
Wintershall Dea, Sval
Vår Energi
Wintershall Dea
DNO, OMV
Wintershall Dea

They also show that syndicates have signed insurancewith companies that participate in 35 out of the 38
new gas and oil projects. The majority, 20, of theseunderwritings are with Aker BP, the biggest owner ofresources in new projects, and the largest operator.
Ensuring Disaster – How insurance companies are accomplices in climate crimes

20

Key findings and demands
The insurance certificates outlined in this report showthat a number of international insurance actors are
responsible for insuring a large number of Norwegianoil fields that clearly violate the aims of the Paris
agreement. By providing insurance coverage for thesecatastrophic oil projects, companies like Lloyd’s ofLondon, Allianz, Zurich, SCOR and AIG are enabling
climate crimes - ensuring a disaster.
The main responsibility of Norway’s immoral policy ofcontinued expansion of the oil and gas sectors lies with
the Norwegian government and the oil companies thatcarry it out. But there are also accomplices in this crime
against the climate. The finance sector profits heavily
from oil drilling, both in Norway and otherwise. Until
now, insurance providers have been a mostly anonymous part of that sector.
The insurance sector is a key actor in realizing, andprofiting from, new oil projects. This also presents anopportunity for change. While this report has identified
a total of 69 individual insurance companies, we findthat a small number of actors are responsible for alarge amount of the insurance realizing huge amountsof new oil drilling. Further, the certificates we uncovered show that the insurance agreements in question
are often short term; normally between one and three
years. If the insurance sector began valuing their responsibilities to the public over short term profits, they
could effectively reduce oil companies’ ability to wreak
havoc on the climate.
By far the most important insurance actor identified inthis report is Lloyd’s of London. Although Lloyd’s is not
an insurance company, but rather an insurance market,
the society operates as a regulator, setting rules underwhich members operate and offering centralised administrative services to its members.

Greenpeace Nordic demands that all insurance andreinsurance companies operating in Norway and therest of Europe that provide underwriting or reinsurance
to the oil and gas sector:
1. Immediately cease insuring new and expanded coal,oil, and gas projects.
2. Immediately stop insuring any new customers fromthe fossil fuel sector which are not aligned with acredible 1.5ºC pathway, and stop offering any insurance
services which support the expansion of coal, oil andgas production at existing customers. Within two years,
phase out all insurance services for existing fossil fuelcompany customers which are not aligned with such apathway.
3. Immediately divest all assets, including assets managed for third parties, from coal, oil, and gas companies
that are not aligned with a credible 1.5ºC pathway.
4. By July 2023, define and adopt binding targets for
reducing their insured emissions which are transparent, comprehensive and aligned with a credible 1.5ºC
pathway.
5. Immediately establish, and adopt as policy, robust
due diligence and verification mechanisms to ensureclients fully respect and observe all human rights,
including a requirement that they obtain and document the Free, Prior, and Informed Consent (FPIC) of
impacted Indigenous Peoples as articulated in the UN
Declaration on the Rights of Indigenous Peoples.
These policies should be applied by both insurance
and reinsurance companies at the group level. Reinsurance companies should apply the policies to direct,
facultative and treaty business.

It’s long overdue for the board of Lloyd’s of London toenact and enforce an ESG policy that is in line with theParis agreement’s goal of limiting global warming to
1,5 degrees. This involves not providing insurance to oilcompanies that plan new oil and gas fields.

Ensuring Disaster – How insurance companies are accomplices in climate crimes

21

NOTES

22  United Nations, The Paris Agreement.

1   BP Statistical Review of World Energy 2021, tables.

24  International Energy Agency, IEA (2021). Net Zero by 2050 – A
Roadmap for the Global Energy Sector.

2  BP Statistical Review of World Energy 2021. Proved reserves
are defined as "those quantities that geological and engineering
information indicates with reasonable certainty can be recoveredin the future from known reservoirs under existing economic andoperating conditions."
3  Norwegian Petroleum Directorate. Resources per Sea Area.
Accessed 4 May 2023.
4  Statistics Netherlands (CBS). Energy Reserves. Accessed May
4 2023.
5  Figures in BP Statistical Review include onshore oil and gas
reserves. However, in Norway, Denmark and the UK this does notaffect the total since they are marginal.
6  Norwegian Petroleum Directorate. Resources per Sea Area.
Accessed May 10 2023.
7  BP Statistical Review of World Energy – all data 1965–2021.
8  BP Statistical Review of World Energy 2021.
9  US Energy Information Administration , EIA. Country analysis.
Accessed May 4 2023.
10  Norwegian Petroleum Directorate. Exports of oil and gas.
Accessed May 2 2023.

23  Carbon Brief. Analysis: What the new IPCC report says about
when world may pass 1.5C and 2C. Accessed May 10 2023.

25  The Guardian. No new oil, gas or coal development if world
is to reach net zero by 2050, says world energy body. Accessed on
May 3 2023.
26 See for example round 10.05.23 https://www.regjeringen.no/
no/aktuelt/utlysning-av-leteareal-gjennom-tfo-2023/id2976636/
27  United Nations Environmental Programme, UNEP (2021).
The Production Gap Report.
28  Tyndall Centre for Climate Research, University of Manchester (2022). Phaseout Pathways for Fossil Fuel Production Within
Paris-compliant Carbon Budgets.
29  
D Welsby, J Price, S Pye, & P Ekins, (2021). Unextractable
Fossil Fuels in a 1.5 °C World, 597 Nature 230.
30  United Nations Environment Programme, UNEP (2022).
Emission Gap Report 2022: The Closing Window, p 22.
31 OilChange International. New briefing exposes Norway as
Europe’s most aggressive oil and gas explorer. Accessed May 19
2023.
32  UNEP (2021). Production Gap Report 2021.
33  Scope 3 emissions of CO2. Sustainable Development Report.

11  Stockholm Environment Institute, SEI. North Sea oil and gas
transition from a regional and global perspective.

34 OilChange International (2022). New briefing exposes Norway as Europe’s most aggressive oil and gas explorer.

12 Petroleum law § 1.2: https://lovdata.no/lov/1996-11-29-72/§12 and the most recent white paper on ownership https://www.
regjeringen.no/no/dokumenter/meld.-st.-6-20222023/id2937164/

35  Det kongelige finansdepartement, Prop. 113L, (2019-2020),
Midlertidige endringer i petroleumsskatteloven.

13  The Petroleum law § 3.8 gives the government the right torequire companies to use the licenses they own: https://lovdata.
no/lov/1996-11-29-72/§3-8

36  United States Environmental Protection Agency (EPA).
Greenhouse Gases Equivalencies Calculator -– Calculations andReferences, Barrels of oil consumed. Accessed 12 May 2023

14  OSPAR Commission, Offshore installations. Accessed on May
3 2023.

37  In this assessment we include companies with license
shares exceeding 1 million boe. Below this threshold, Repsol has
license shares in Telesto amounting to 0.8 million boe.

15  Arup (2014). Decommissioning in North Sea.

38

16  Oil and gas transitions, Co-creating evidence to accelerate
policy action in the North Sea. Accessed May 4 20223.

39  Ibid.

17  Oil and Gas Transitions (2022). Norwegian Oil and Gas Transition: Building Bridges Towards a Carbon Neutral Future.
18  McKinsey & Company (2014). Oil & gas practice. Meeting thechallenge of increasing North Sea costs.

Insure Our Future, Scorecard report.

40 Financial Times (2018). BP to take further $1.7bn charge for
Deepwater Horizon disaster. Accessed May 10 2023.
41  
Forskrift til lov om petroleumsvirksomhet § 73: https://lovdata.no/forskrift/1997-06-27-653/§73

19  Financial Times. The new North Sea players riding the wakeof the retreating majors. Accessed May 14 2023.

42  Lloyd’s (2020). Environmental, Social and Governance Report2020 – Our plan for becoming a truly sustainable insurance marketplace, Foreword, p 2.

20  EU Commission, published 8 March 2022. REPowerEU: Joint
European action for more affordable, secure and sustainableenergy. Accessed on May3 2023.

43 Lloyds (2022). Environmental, Social and Governance Report
2021 – Building a more resilient, sustainable and inclusive insurance market and society, p 22.

21  New licenses are issued every year. See for example round10.05.2023: https://www.regjeringen.no/no/aktuelt/utlysning-av-leteareal-gjennom-tfo-2023/id2976636/

44  Insure Our Future (2022). Lloyd’s new ESG report: greenwashing, not climate action.
45  Insure Our Future (2023). 2022 Scorecard on Insurance, Fossil Fuels and the Climate Emergency. . Accessed May 10 2023.

Ensuring Disaster – How insurance companies are accomplices in climate crimes

22

46  Equinor Insurance (2022). Annual report 2021.
47  Lloyd’s (2020). Environmental, Social and Governance Report2020 – Our plan for becoming a truly sustainable insurance marketplace, Foreword, p 2.
48 Lloyds (2022). Environmental, Social and Governance Report
2021 – Building a more resilient, sustainable and inclusive insurance market and society, p 22.
49  Insure Our Future (2023). 2022 Scorecard on Insurance,
Fossil Fuels and the Climate Emergency.
50 Central Bank of Ireland (2018). Pan Insurance DAC, Solvency& Financial Condition Report (SFCR)
51  PGNiG, Overview. Accessed on May 2 2023.
52  Vienna Insurance Group, Fact sheet. Accessed 2 May 2023.
53  Vienna Insurance Group, Corporate responsibility – Environmental and social investment criteria. Accessed on May 2 2023.
54  Insure Our Future (2023). 2022 scorecard on insurance, fossil
fuels and the climate emergency.

Ensuring Disaster – How insurance companies are accomplices in climate crimes

23