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Bupa Group Solvency and Financial Condition Report 2018 1

2018 Bupa Group

Solvency and Financial Condition Report


Contents

A. Business and Performance................................................................................................................................. 6

A.1 Business ........................................................................................................................................................... 6

A.2 Underwriting performance .............................................................................................................................. 11

A.3 Investment performance ................................................................................................................................. 13

A.4 Performance from other activities ................................................................................................................... 14

A.5 Any other information ...................................................................................................................................... 15

B. System of Governance ..................................................................................................................................... 16

B.1 General information on the system of governance ......................................................................................... 16

B.2 Fit and proper requirements ........................................................................................................................... 21

B.3 Risk management system including Own Risk and Solvency Assessment ................................................... 21

B.4 Internal control system .................................................................................................................................... 24

B.5 Global Internal Audit function ......................................................................................................................... 25

B.6 Actuarial function ............................................................................................................................................ 25

B.7 Outsourcing .................................................................................................................................................... 26

B.8 Any other information ...................................................................................................................................... 27

C. Risk Profile ....................................................................................................................................................... 28

General information ............................................................................................................................................... 28

C.1 Underwriting risk ............................................................................................................................................. 29

C.2 Market risk ...................................................................................................................................................... 31

C.3 Credit risk........................................................................................................................................................ 33

C.4 Liquidity risk .................................................................................................................................................... 33

C.5 Operational risk .............................................................................................................................................. 34

C.6 Other material risks ........................................................................................................................................ 34

C.7 Any other information ..................................................................................................................................... 36

D. Valuation for Solvency Purposes ..................................................................................................................... 37

D.1 Assets ............................................................................................................................................................. 38

D.2 Technical provisions ....................................................................................................................................... 45

D.3 Other liabilities ................................................................................................................................................ 48

D.4 Alternative methods for valuation ................................................................................................................... 52

D.5 Any other information ..................................................................................................................................... 52

E.1 Own Funds ..................................................................................................................................................... 53

E.2 Solvency Capital Requirement and Minimum Capital Requirement .............................................................. 56

E.3 Use of the duration-based equity risk sub-module in the calculation of the SCR .......................................... 57

E.4 Differences between the standard formula and any internal model used ...................................................... 57

E.5 Non-compliance with the Minimum Capital Requirement and Solvency Capital Requirement ...................... 57

E.6 Any other information ...................................................................................................................................... 57

Directors’ responsibility statement ........................................................................................................................ 58

Audit Opinion ......................................................................................................................................................... 59

Annex – Reporting Templates............................................................................................................................... 62


Summary

(Unaudited)

INTRODUCTION

The purpose of the Solvency and Financial Condition Report (“SFCR”) is to provide information about the capital

position at 31 December 2018 of the British United Provident Association Limited (“the Company”) and its

subsidiaries which comprise the Bupa Group (“Bupa” or “the Group”) based on the Solvency II requirements.

The report includes information regarding the Group’s business and performance, system of governance, risk

profile, valuation methods used for solvency purposes and its capital management practices.

BUSINESS AND PERFORMANCE SUMMARY

Bupa’s purpose is helping people live longer, healthier, happier lives. Bupa is a company limited by guarantee with

no shareholders, with profits reinvested in the business. We reinvest profits into providing more and better

healthcare for the benefit of current and future customers.

Globally, health insurance revenue accounts for 73% of our business, with 15.7m insurance customers. We directly

provide healthcare to around 15m people in our health clinics, hospitals and dental centres. We look after around

23,000 aged care residents in Australia and New Zealand, the UK and Spain.

We directly employ 80,000 people, principally in the UK, Australia, Spain, Poland, Chile, New Zealand, Hong Kong,

Turkey, the US, Brazil, the Middle East and Ireland. We also have associate businesses in Saudi Arabia and India.

Section A provides further details about the Group’s business structure, key operations and financial performance

over the reporting period.

SYSTEM OF GOVERNANCE SUMMARY

Bupa has around 100 Association members (“AMs”), including all Board Directors, who exercise oversight normally

provided by shareholders. The Board is responsible for the long-term success and sustainability of Bupa for the

benefit of current and future customers. It does this by providing clear leadership in setting strategy and risk appetite

and by overseeing management’s implementation of strategy within a prudent and effective governance structure.

As part of our commitment to excellence, we aim, where appropriate, to operate to the same governance standards

as are required of UK FTSE 100 companies. The Board closely monitors governance developments and assesses

how these can be applied to Bupa.

Solvency II mandated key functions are embedded throughout Bupa with clear responsibilities and segregation of

duties. We employ a “three lines of defence” governance model to support effective risk management and

appropriate decision making. This includes accountability for risk management and compliance in the first line, with

second line Risk function oversight and challenge, supported by an independent Internal Audit (“IA”) function.

Section B describes the system of governance by which the operations of the Group are overseen, directed,

managed and controlled and explains compliance with the requirements of Solvency II.

RISK PROFILE SUMMARY

Bupa accepts risks as part of our business operation. Some risks are avoidable (e.g. certain financial risks) and

others are inherently part of Bupa’s business model (e.g. operational risks).

Solvency capital is held to ensure that the Group can meet its obligations to policyholders as they fall due, in all but

the most extreme circumstances. The Group Solvency Capital Requirement (“SCR”) is calculated using the

standard formula specified in the Solvency II legislation, modified by a Group Specific Parameter (“GSP”) for

premium risk SCR. Bupa has obtained approval from the Prudential Regulatory Authority (“PRA”) to substitute the

insurance premium risk parameter in the standard formula with a GSP, which reflects Bupa’s own loss experience.


The SCR profile of the Group has not changed materially over the past 12 months. The distribution of the Group’s

quantifiable risks, as reflected in the SCR, is as follows:

Analysis of the SCR (diversified)1 2018 2017

Market risk 57% 57%

Property risk 34% 32%

Currency risk 11% 13%

Pension scheme risk 7% 6%

Spread risk 3% 3%

Equity risk 2% 3%

Underwriting risk 18% 18%

Operational risk 12% 12%

Participations (associates) 10% 8%

Credit risk 3% 5%

Total 100% 100% 1 IFRS 16 is effective 1 January 2019 and is estimated to increase the Group SCR by £0.2bn. Section C of this report provides further detail on

the analysis of the SCR post IFRS 16.

Section C further describes the risks to which the Group is exposed and how we monitor and mitigate these risks,

including any changes in the year to our risk exposures.

VALUATION FOR SOLVENCY PURPOSES SUMMARY

Solvency II requires an economic market consistent approach to the valuation of assets and liabilities. Certain

assets and liabilities require different valuation methods to those used in the financial statements prepared under

International Financial Reporting Standards (“IFRS”) as adopted by the EU. The valuation differences are

summarised as follows:

Reconciliation of IFRS equity to Solvency II excess of assets

over liabilities

2018

£m

2017

£m

Equity attributable to Bupa in IFRS financial statements 7,510 7,288

Valuation differences:

Assets

Goodwill and intangibles (4,261) (4,287)

Equipment (117) (83)

Investments (410) (338)

Other (65) (42)

Liabilities

Technical provisions 281 238

Deferred tax liabilities 219 159

Financial and subordinated liabilities (39) (49)

Solvency II excess of assets over liabilities 3,118 2,886

Section D includes information on the valuation basis adopted for each class of assets and liabilities and provides

an explanation of valuation differences arising when moving from the valuation basis used in the Group’s financial

statements to the Solvency II valuation basis.


CAPITAL MANAGEMENT SUMMARY

The Group’s capital management objective is to maintain sufficient capital to protect the interests of its customers,

investors, regulators and trading partners while deploying capital efficiently and managing risk to enable Bupa to

continue to deliver its purpose in a sustainable manner. We do not pay dividends and hence our profits are

reinvested to develop the Group’s business for the benefit of current and future customers.

Eligible Own Funds to cover the SCR

2018

£m

2017

£m

Unrestricted Tier 1 2,587 2,426

Restricted Tier 1 - subordinated perpetual bonds 356 370

Tier 2 - subordinated unguaranteed bonds 921 925

Tier 3 – deferred tax asset 52 6

Eligible Own Funds 3,916 3,727

SCR (2,050) (2,071)

Surplus 1,866 1,656

Solvency Ratio 191% 180%

At 31 December 2018, the Group’s eligible Own Funds, determined in accordance with the Solvency II valuation

rules, were £3,916m (2017: £3,727m), which was in excess of our SCR of £2,050m (2017: £2,071m). This

represented a solvency coverage ratio of 191% (2017: 180%).

The Group’s capital resources are managed in line with the Group Capital Management Policy. While the Group is

subject to the Solvency II requirements at a consolidated level, all regulated entities within the Group maintain

sufficient capital resources to more than meet any minimum capital requirement required by respective local

regulators. In addition, the Group and individual regulated entities maintain a buffer over the regulatory minimum

requirements in line with their capital risk appetites. During the year, the Group and its subsidiaries complied with

all externally imposed capital requirements to which they were subject. The capital position of the Group and its

regulated insurance entities are kept under constant review.

IFRS 16 Leases will apply from 1 January 2019. While this accounting change does not change our risk profile, it

requires all our operating lease assets and liabilities to be capitalised on the IFRS and Solvency II balance sheet.

The estimated value of both lease assets and liabilities at 1 January 2019 is £1.0bn. The lease assets attract a

property risk charge under the Solvency II Standard Formula. This, together with interest rate risk on the liability, is

estimated to increase the SCR charge by £0.2bn. The impact on the solvency coverage ratio on transition is

estimated to have reduced our coverage ratio by 16 percentage points.

On 18 January 2019, we completed the acquisition of Bupa Acıbadem Sigorta in Turkey. This acquisition is

estimated to reduce our coverage ratio by 6 percentage points. After the inclusion of lease assets and liabilities and

this acquisition, our solvency coverage ratio is estimated to be 169%.

Section E further describes the policies and processes employed by the Group for managing its Own Funds. The

section also covers information on the structure of Own Funds and calculation of SCR.

OTHER INFORMATION

In line with PRA requirements, Sections D. Valuation for Solvency Purposes and E. Capital Management of the

SFCR have been subject to audit by the Group’s external auditor. Sections A. Business and Performance, B. System

of Governance and C. Risk Profile are unaudited.


A. Business and Performance

(Unaudited)

A.1 Business

A.1.1 Company information

The Company, the ultimate parent entity of the Group, is a private company limited by guarantee without share

capital, incorporated in England and Wales under the company registration number 432511. The Company does

not have shareholders. The Company is managed in line with the corporate governance safeguards and commercial

principles that would be expected to be found in a UK listed company. Bupa has around 100 Association Members

(“AMs”), including all Board Directors, who exercise oversight normally provided by shareholders. The AMs vote at

the Annual General Meeting (“AGM”) on director reappointments and remuneration of the executive directors. AMs

have no equity holding in Bupa and, consequently, no right to dividends. No individual has 10% or more voting

rights or any other mechanism of control of the Company.

The Group supervisor is the Prudential Regulation Authority (“PRA”), Bank of England, 20 Moorgate, London EC2R

6DA.

The Group’s external auditor is KPMG LLP, Chartered Accountants, 15 Canada Square, London, E14 5GL.

A copy of the Group’s Annual Report and Accounts is available on the Group’s website at:

www.bupa.com/Corporate/our-performance/annual-report.

In addition to the Group SFCR, the individual regulated undertakings within the European Economic Area (“EEA”)

produce solo entity SFCRs: Bupa Insurance Limited, Sanitas S.A. de Seguros (“Sanitas Seguros”), LMG

Försäkrings AB and Bupa Global Designated Activity Company.

A.1.2 Business

Bupa's purpose is helping people live longer, healthier, happier lives. With no shareholders, our customers are our

focus. We reinvest profits into providing more and better healthcare for the benefit of current and future customers.

Health insurance is the core of what we do with 15.7m customers across the world. We also deliver certain health

services where they complement our position in health insurance; giving us greater insight into how health systems

work and enabling us to deliver excellent customer experiences. We look after around 23,000 aged care residents

in Australia and New Zealand, the UK and Spain. As a service business, everything we do for our customers is

delivered through our people. We can only succeed through them.

We are an international company, with strong local businesses. This ensures we adapt to and connect with local

health systems and customer needs.

We directly employ around 80,000 people, principally in the UK, Australia, Spain, Poland, Chile, New Zealand, Hong

Kong, Turkey, the US, Brazil, the Middle East and Ireland. We also have associate business in Saudi Arabia and

India.

A.1.3 Legal Structure

Information is provided below on the Group’s principal insurance and non-insurance undertakings. A full list of the

Group’s subsidiaries and other material undertakings is included on the quantitative reporting template (“QRT”)

S.32.01.22 ‘Undertakings in the scope of the group’, included in the attached Annex. For each undertaking, the

QRT provides a description of the type of undertaking, country and proportion of ownership interest held.

All subsidiary companies controlled by Bupa are considered to be: (i) insurance or reinsurance undertakings; (ii)

insurance holding companies; or (iii) ancillary services undertakings. Therefore, all companies are subject to full

consolidation. Investments in associates and joint ventures are accounted for using the adjusted equity method with

assets and liabilities valued using Solvency II valuation methods.

https://www.bupa.com/Corporate/our-performance/annual-report


Simplified Group structure chart

The simplified Group structure chart below provides information on the ownership and the country of the Group’s

material subsidiary insurance entities and relevant holding companies, as at 31 December 2018. Please note, this

is not the full Group structure and does not include the Group’s non-insurance entities:

A.1.4 Organisational structure

Our organisational structure consists of four Market Units, enabled through Global Functions covering Medical,

People, Information Systems, Finance, Customer and Corporate Affairs, Risk & Compliance and Legal, each

headed by a Global Function Director. We also have an Internal Audit function led by the Chief Audit Officer (“CAO”)

who reports to the Chair of the Audit Committee.


Each Market Unit has an executive team headed by a Chief Executive Officer (“CEO”). Each Market Unit includes

a number of Business Units that provide our services, with each Business Unit headed by a General Manager.

The Bupa Executive Team (“BET”) comprises the Group CEO, the Chief Financial Officer (“CFO”), the CEOs of the

four Market Units and Global Function Leaders. The BET meets regularly throughout the year focusing on

performance, risks, talent and the delivery of the strategic agenda. Further information on the Group’s governance

structure is provided in Section B.1: General information on the system of governance.

Market Unit structure chart

The Market Unit structure chart below provides information on the four Market Units within the Group. The Group is

managed through four Market Units based on geographic locations and customers.

Australia and New Zealand (“ANZ”)

• Bupa Health Insurance, with four million customers, is the leading health insurance provider in Australia and

also offers health insurance for overseas workers and visitors;

• Bupa Health Services is a health provision business, comprising dental, optical, medical visa services, and

therapy;

• Bupa Villages and Aged Care Australia and New Zealand cares for around 6,700 residents across 72 homes in

Australia, and for around 3,500 residents in 49 homes and 7 rehabilitation centres and provide independent

living in over 30 retirement villages in New Zealand.

Europe and Latin America (“ELA”)

• Sanitas Seguros is the second largest health insurance provider in Spain, with 1.7 million customers;

• Sanitas Hospitales and New Services comprises four private hospitals, 35 private medical clinics, 18 fertility

clinics (in Spain and Portugal) and one public-private partnership in Spain;

• Sanitas Dental provides dental services through 179 centres and third-party networks in Spain;

• Sanitas Mayores cares for around 6,000 people in 46 care homes and operates five day care centres in Spain;

• LUX MED is the largest private healthcare business in Poland, operating in health funding and provision through

seven hospitals and 201 private clinics;

• Bupa Chile is a leading health insurer and provider with four hospitals and 39 medical clinics;

United Kingdom (“UK”)

• Bupa UK Insurance is the UK’s leading health insurer, offering health insurance to 2.2 million people;

• Bupa Dental Care is the leading provider of private dentistry in the UK, with around 2.4 million patients. Bupa has 477 dental practices across the UK and Ireland;

• Bupa Care Services has around 6,800 residents in 138 care homes, and seven Richmond care villages;


• Bupa Health Services comprises 49 health clinics, and the Bupa Cromwell Hospital.

International Markets (“IM”)

• Bupa Global serves around 900,000 international private medical health insurance (“IPMI”) customers and

administers travel insurance and medical assistance for individuals, small businesses and corporate customers.

This includes Care Plus, the leading premium health insurance company in Brazil;

• Bupa Arabia, in which Bupa has a 39.25% stake, is the largest health insurance business in Saudi Arabia;

• Bupa Acıbadem Sigorta, acquired in January 2019, Turkey’s second largest health insurer, with products for

both corporate and individual customers, and over 550,000 lives covered;

• Bupa Hong Kong is a health insurance specialist in Hong Kong, with over 400,000 customers, and Quality

HealthCare is Hong Kong’s leading private clinic network in the territory;

• Max Bupa, covering 2.3 million customers, is a private health insurer in India in which Bupa holds a 49% stake;

• Bupa China is our Representative Office in Beijing and operates a medical centre in Guangzhou.

Insurance Revenue by Market Unit

The table below shows the earned premium net of reinsurance generated by Market Unit as reported in the Group’s

financial statements by value and as a proportion of the Group’s total insurance revenue.

2018 2018 2017 2017

Market Unit £m % £m %

Australia and New Zealand 3,829 44% 4,031 46%

Europe and Latin America 1,896 22% 1,798 20%

United Kingdom 1,534 17% 1,535 17%

International Markets 1,469 17% 1,493 17%

Total 8,728 100% 8,857 100%

Non-Insurance Revenue by Market Unit The table below shows non-insurance revenue generated by Market Unit as reported in the Group’s financial

statements by value and as a proportion of the Group’s total non-insurance revenue.

Non-insurance revenue includes fees receivable from the operation of care homes, hospitals, dental centres and

other healthcare and wellbeing centres. In addition, this includes revenue from insurance service contracts, rental

income and amenities fees.

2018 2018 2017 2017

Market Unit £m % £m %

Europe and Latin America 1,145 37% 1,272 37%

United Kingdom 1,002 32% 1,071 32%

Australia and New Zealand 827 26% 896 26%

International Markets 157 5% 154 5%

Total 3,131 100% 3,393 100%

Branches

Bupa Insurance Limited is wholly owned by The British United Provident Association Limited and is part of the Bupa

Group. The Bupa Malta branch, within Bupa Insurance Limited, is the only branch in the Group which falls within

the Solvency II definition of significant branches. Bupa Malta acts as an insurance agent selling non-life international

health insurance and is regulated by the Malta Financial Services Authority. For the year ended 31 December 2018,

Bupa Malta’s gross written premium was £7m (2017: £7m).

A.1.5 Significant events in the year

The Group’s results reflect the decision to divest part of our UK aged care business at the end of 2017 and early

2018 and the challenges in our Australian aged care and health insurance businesses. In 2018, our insurance

businesses in the UK and Spain continued to perform well.


We are investing in strength and depth within our existing markets and geographies and selectively expanding into

new markets, to ensure strong and sustainable performance. For example, in Spain, we acquired digital health

insurance provider Nectar Seguros, as well as Ginemed a leading provider of fertility services. In August, we

increased our stake in Bupa Arabia by a further 5% to 39.25% and we entered the Turkish health insurance market

through the acquisition of Bupa Acıbadem Sigorta in January 2019.

We set up a new insurance entity in Ireland to maintain service for our international private medical insurance

customers living in the European Union (“EU”) (but outside the UK), once the UK leaves the EU.

We continue to invest in the dental sector, including acquiring 24 practices in the UK and Ireland. We now have

over 900 dental centres across the UK, Ireland, Australia, Spain, Chile, New Zealand, Poland, Brazil and Hong

Kong.

Organisation changes in the year

Roger Davis was appointed as Chairman from 1st January 2019, having been an independent Non-Executive

Director since July 2015, succeeding Lord Leitch who stepped down as Chairman at the end of 2018.

Clare Thompson became Senior Independent Director (“SID”) in May 2018, following the retirement of Lawrence

Churchill CBE. Caroline Silver became the Chair of the Risk Committee in October. We have welcomed Paul Evans,

Nicholas Lyons, Matías Rodríguez Inciarte, Michael Hawker and Professor Melvin Samsom to the Board as Non-

Executive Directors. Simon Blair stepped down from the Board at the end of his term in January 2019 and became

Chair of the Bupa Chile Board.

Hisham El-Ansary, was appointed as CEO of Bupa Australia and New Zealand from April 2019, having previously

held the position of Chief Financial and Strategy Officer of that Market Unit. This appointment follows Richard

Bowden taking retirement after over two decades with Bupa.

A.1.6 Summary of performance in the year

Revenue was £11.9bn, flat on prior year (£11.9bn at constant exchange rates (“CER”)) while statutory profit

decreased by 19% to £502m (2017: £620m at actual exchange rates (“AER”)). Underlying profit of £613m was down

12% (2017: £698m CER)1. When excluding the divestment of UK care homes, revenue grew 3% and underlying

profit fell on prior year by 6%.

Overall, Group revenue remained stable against prior year. Our Spanish health insurance business grew 2%,

through increased membership on 2017, including the acquisition of Néctar Seguros, a book of around 34,000

customers. The revenue in our Australian and UK health insurance businesses remained stable on last year.

International Markets increased revenue by 4% largely due to Bupa Global and Bupa Hong Kong.

Our healthcare provision businesses grew revenue by 9%, reflecting an additional two months trading following the

acquisition of Oasis Dental Care in February 2017, strong performance in LUX MED’s corporate subscription

business, and the opening of the Clínica Bupa Santiago hospital in Chile.

In aged care, revenue declined by 1% on 2017, excluding the impact of the sale of a number of UK Care homes in

December 2017 and February 2018. In Australia, revenue fell following the effect of government funding pressures

along with lower average occupancy 94%; (2017 96%) and one-off provisions associated with refunds related to

service discrepancies. Good performance in our aged care business in Spain partially offset this and it maintained

its high average occupancy rate of 95%. In the UK, average occupancy remained relatively stable on last year at

84.5%.

Sections A.2 to A.4 of the SFCR provide a summary of performance across three categories: underwriting activities,

investment activities and other. Other includes non-insurance business such as fees receivable from operation of

1 Underlying profit reflects our trading performance and excludes a number of items included in statutory profit, to facilitate year-on-year

comparisons. The methodology for calculating underlying profit was refined from the half year to provide a better representation of underlying performance. The key restatement item is the inclusion of amortisation of intangible assets arising on business combinations as part of underlying profit. Other refinements have been made to the definition but are not material to the reportable segment or Group.


care homes, hospitals, dental centres and other healthcare and other revenues (including rental income and

revenue from insurance service contracts).

The following table explains how the Group’s income and expenses, as reported in the Group’s financial statements,

is analysed across the three categories. The table below is presented on statutory profit basis under IFRS.

Performance by category 31

December 2018 Total Underwriting Investment Other

Section £m £m £m £m

Revenues

Gross insurance premiums A.2 8,791 8,791 - -

Premiums ceded to reinsurers A.2 (63) (63) - -

Net insurance premiums earned 8,728 8,728

Revenues from service contracts A.4.1 14 - - 14

Care, health and other revenues A.4.2 3,117 - - 3,117

Total revenues 11,859 8,728 - 3,131

Claims and expenses

Insurance claims incurred A.2 (6,912) (6,912) - -

Reinsurers’ share of claims incurred A.2 44 44 - -

Net insurance claims incurred (6,868) (6,868) - -

Amortisation of intangibles (141) - - (141)

Impairment of intangible assets (39) - - (39)

Depreciation (185) - - (185)

Other operating expenses (4,063) (1,207) - (2,856)

Operating expenses A.4.4 (4,428) (1,207) (3,221)

Share of post-taxation results of

equity accounted investments A.4.3 33 - - 33

Other income and charges A.4.5 (53) - - (53)

Total claims and expenses (11,316) (8,075) - (3,241)

Financial income and expenses

Financial income A.3.1 70 - 70 -

Financial expenses A.3.2/A.4.6 (103) - (103) -

Net impairment on financial assets (8) - (8) -

Net financial expense (41)

Profit before taxation expense 502

Taxation expense (190)

Profit for the financial year 312

A.2 Underwriting performance

The Group’s insurance business is predominantly private medical insurance (“PMI”) and IPMI. For Solvency II

reporting, all insurance business is classified as ‘Medical Expense’ in the QRT S.05.01.02 ‘Premiums, claims and

expenses by line of business’ (refer to the attached Annex) as other lines of business are not material.

The summary of underwriting performance below is presented in accordance with the QRT S.05.01.02 ‘Premiums,

claims and expenses by line of business’. The summary of underwriting performance represents the performance

of the Group’s wholly owned insurance businesses. Information on the Group’s share of profits of equity accounted

insurance undertakings is provided in section A.4.3.


The principal difference between the information provided on QRT S.05.01.02 and that reported in the Group’s

financial statements is that claims handling costs are recognised within expenses on the QRT, in compliance with

Solvency II reporting requirements, but are recognised in the claims figure in the financial statements. Claims

handling costs amounted to £170m for the year ended 31 December 2018 (2017: £168m). In addition, Solvency II

reporting requirements exclude amortisation and impairment of intangibles and other non-technical expenses.

Underwriting performance by geographical area

The following table presents the Group’s underwriting performance split by geographical risk location in accordance

with the S.05.02.01 ‘Premiums, claims and expenses by country’ QRT.

In Australia, in a challenging trading year, we delivered stable revenue. Affordability pressures have impacted the

take-up of health insurance in recent years. In response, the Government has been restricting price increases at a

lower rate than claims inflation. This impacted the profitability of our health insurance business in 2018 and will

continue in 2019. Our customer numbers fell by 1.6% in a market which is contracting due to cost of living and

affordability pressures. Our health insurance transformation programme focused on delivering benefits for

customers, including real-time claims payment and online benefit statements. We introduced initiatives to reduce

indirect operating costs, while also working with government to continue to support health reform to address

affordability challenges.

1 The geographic split of the Group’s underwriting performance differs to the disclosures made within the respective solo entity regulatory

filings due to a number of factors (e.g. the elimination / presentation of inter-Group transactions, the impact of policies written across geographic risk locations etc).

Underwriting performance

2018

£m

2017

£m

Premiums:

Gross insurance premiums 8,791 8,920

Premiums ceded to reinsurers (63) (63)

Net insurance premiums earned 8,728 8,857

Claims:

Insurance claims incurred (6,742) (6,944)

Reinsurers’ claims incurred 44 46

Net insurance claims incurred (6,698) (6,898)

Expenses (1,377) (1,356)

Underwriting profit before investment income 653 603

2018

Australia

£m

UK

£m

Spain

£m

Chile

£m

Hong

Kong

£m

Others

£m

Total

£m

Net insurance premium earned 3,835 1,592 1,167 723 302 1,109 8,728

Net insurance claims incurred (3,222) (1,110) (811) (633) (217) (706) (6,698)

Expenses (320) (311) (209) (87) (58) (392) (1,377)

Underwriting profit/(loss)1 293 171 147 3 27 11 653

2017

Australia

£m

UK

£m

Spain

£m

Chile

£m

Hong

Kong

£m

Others

£m

Total

£m

Net insurance premium earned 4,037 1,595 1,102 689 289 1,145 8,857

Net insurance claims incurred (3,381) (1,152) (792) (611) (214) (748) (6,898)

Expenses (320) (314) (196) (78) (49) (399) (1,356)

Underwriting profit/(loss) 336 129 114 - 26 (2) 603


Our UK health insurance business closed the year with 2.2m customers. It remains the market leading health insurer

in the country, with a market share of 37.5%. We launched Business Mental Health Advantage, offering our

corporate customers the most extensive mental health coverage in the market. We also partnered with digital

healthcare provider, Babylon, giving business customers access to face-to-face GP care around the clock.

In Spain, where we operate under the Sanitas brand, performance was good. This was driven by successful

partnerships with BBVA and Santa Lucía, along with Clínica Universitaria de Navarra, a leading hospital provider.

We reinforced our number two position in the health insurance market with the acquisition of Néctar Seguros, a

digital insurance player. Our Blua digital proposition continues to drive growth. By the end of 2018, over 93% of

insurance claims were managed digitally.

In IM, our focus on stabilising the business began to show results. We made progress in improving customer

retention and customer satisfaction. We established an authorised insurer in Ireland, in order to continue to serve

customers living in the EU (but outside the UK), after Brexit. We made investments both in organic growth and

acquisitions during the year. In Colombia, we launched our first IPMI products in partnership with the country’s

leading insurer, Seguros Bolivar. In Brazil, the integration of Care Plus continues to progress well.

We also announced the acquisition of Bupa Acıbadem Sigorta, Turkey’s second largest health insurer, in August,

completing the transaction in January 2019. Additionally, in August, we increased our stake in our Bupa Arabia

associate business to 39.25%.

A.3 Investment performance

A.3.1 Investment income

Investment income for the year, as reported in the Group’s financial statements, was as follows:

Investment income

2018

£m

2017

£m

Investments at amortised cost (IFRS 9) 47 -

Loans and receivables - 45

Investments held to maturity - 7

Investments designated as available for sale - 4

Investments designated at fair value through profit and loss 5 -

Net realised gains on financial investments designated at fair value through profit

and loss 8 2

Net increase in fair value:

Investments designated at fair value through profit and loss (8) 22

Investment property 21 22

Net foreign exchange translation (losses) (3) (12)

Investment income by asset class 70 90

The Group’s investments are primarily held in cash and cash equivalents, but also include a portfolio of non-cash

assets; principally corporate and government bonds, collective investment undertakings including loans. Hedging

instruments are used to manage the foreign exchange risks from non-sterling investments.

Included within financial income is a net loss, after hedging, on the Group’s return-seeking asset portfolio of £1m

(2017: net gain of £18m).


Investment income by Solvency II asset class is presented in the table below.

Investment income by asset class

2018

£m

2017

£m

Government bonds 6 5

Corporate bonds 13 10

Equity 1 (2)

Investment funds 2 11

Cash and deposits 42 21

Mortgages and loans 4 6

Property 5 121

Hedging instruments (15) 7

Other investments - 2

Investment income by asset class 58 181

The difference between investment income in the Group’s financial statements and Solvency II financial income by

asset class relates to gains or losses on property disposals, impairments and revaluations which are recognised in

Solvency II financial income but shown under operating income for IFRS.

A.3.2 Investment expenses

Investment expenses in the year amounted to £3m (2017: £3m), covering investment management fees and other

costs of investment related activities.

A.3.3 Gains and losses recognised directly in equity

Gains and losses recognised directly in equity for the year, as reported in the consolidated statement of

comprehensive income in the financial statements, are as follows:

Gains and losses recognised directly in equity

2018

£m

2017

£m

Remeasurement gain on pension schemes 21 94

Unrealised gains on revaluation of property 23 233

Foreign exchange translation differences on goodwill (73) (14)

Other foreign exchange translation differences (11) (10)

Net gain/(loss) on hedge of net investment in overseas subsidiary companies 1 (7)

Change in fair value of underlying derivative of cash flow hedge - 5

Reclassification of foreign exchange translation differences to profit or loss on

disposal of subsidiary - (4)

Unrealised gains on available-for-sale assets - 1

Taxation on income and expenses recognised directly in other comprehensive

income (22) (68)

Total gains and losses recognised directly in equity (61) 230

The remeasurement gain of £21m (2017: gain of £94m) on pension schemes is predominantly due to changes in

financial assumptions used in valuing the liabilities within the pension schemes.

Unrealised gains of £23m (2017: gains of £233m) on the revaluation of property are based on external valuations.

Foreign exchange translation losses on goodwill of £73m (2017: losses of £14m) are due to a relative weakening

of sterling against Euro and Hong Kong Dollar, partly offset by strengthening of the sterling against Australian Dollar.

A.4 Performance from other activities

A.4.1 Revenue from insurance service contracts

Contracts entered into by the Group’s insurance entities that do not result in the transfer of significant insurance risk

to the Group are accounted for as insurance service contracts. These contracts mainly relate to the administration


of claims funds on behalf of corporate customers. Revenues from service contracts are recognised as the services

are provided. In 2018, revenues from insurance service contracts amounted to £14m (2017: £22m).

A.4.2 Care, health and other revenue

The Group generates income from the operation of its care homes, hospitals, dental centres and other healthcare

and wellbeing operations. In 2018, this revenue amounted to £3,117m (2017: £3,370m).

A.4.3 Share of post-taxation results of equity accounted investments

The Group’s share of post-taxation results of equity accounted investments was £33m (2017: £28m) for the year

ended 31 December 2018, comprising a £32m (2017: £27m) profit from Bupa Arabia and an aggregate profit of

£1m (2017: £1m) from other associates and joint ventures.

A.4.4 Operating expenses

Operating expenses as reported in the Group’s financial statements are £4,428m (2017: £4,485m).

Operating expenses include £1,207m (2017: £1,188m) which relate directly to insurance activities (excluding claims

handling costs of £170m). The balance of £3,221m (2017: £3,297m) represents costs relating to health and care

provision activities, amortisation and impairment of intangible assets and costs incurred by Group functions.

A.4.5 Other income and charges

Other income and charges comprise income or expenses that are related to the investing and divesting activities of

the Group.

Other income and charges

2018

£m

2017

£m

Net (loss) / gain on disposal of businesses (31) 36

Deficit on revaluation of property (21) (34)

Write down of property - (100)

Net loss on disposal of property, plant and equipment - (1)

Movement in provision for equity accounted investments (1) -

Other income and charges (53) (99)

The 2018 loss on disposal of business (£31m) includes a £22m loss on disposal of Torrejón Salud on 28 December

2018, £20m of losses relating to ongoing completion costs with respect of the disposal of UK care homes to HC-

One and Advinia, profits of £8m on disposal of a 33.33% share of Forsikringens Datacentre A/S on 3 January 2018

and a net £3m profit on other disposals. 2017 includes a £36m profit on disposal of Bupa Thailand to Aetna on 25

July 2017.

A.4.6 Financial expense

Financial expense

2018

£m

2017

£m

Interest expense on financial liabilities at amortised cost (100) (94)

Finance charges in respect of finance leases - (1)

Other financial expenses (3) (3)

Total financial expense (103) (98)

A.4.7 Leasing arrangements

Information on leasing arrangements is included at Section D.3.12 Leasing arrangements.

A.5 Any other information

There is no other material information to be disclosed.


B. System of Governance

(Unaudited)

B.1 General information on the system of governance

B.1.1 Association members

Bupa has around 100 AMs, including all Board Directors, who perform the kind of key governance role ordinarily

undertaken by shareholders. AMs normally serve for an initial term of ten years which can be extended for further

terms of five years. AMs have no equity holding in Bupa and, consequently no right to dividends, only receiving

reasonable expenses for travelling to meetings or events. They are eminent individuals in their own field, coming

from a diverse range of sectors, including health and social care, business, regulatory, academia, charities and the

public sector. Their expertise enables them to challenge the Board on matters of performance and strategy.

Fundamentally, the role of AMs is to hold the Board to account in delivering on Bupa’s purpose of helping people

live longer, healthier, happier lives. AMs are selected using criteria including recent and relevant experience in their

field, independence from Bupa, the capacity to make a contribution and experience in the key overseas markets in

which Bupa operates.

B.1.2 Bupa’s governance framework and the role of the Board

The Board is responsible for the long-term success and sustainability of Bupa for the benefit of its current and future

customers. It does this by setting strategy and risk appetite and by overseeing management’s implementation of

strategy within a prudent and effective governance structure. The diagram in B.1.3 shows how the Board and its

Committees oversee the business through the ‘three lines of defence’ model. The Board delegates certain activities

to its Committees to ensure that there is sufficient time to discuss and provide challenge in these areas, and to allow

the Board to focus on key strategic decisions.

There is a schedule of matters reserved for the Board which includes strategy and management; structure and

capital; financial reporting and controls; internal control and risk management; M&A; and material contracts and

various corporate governance matters. The schedule is reviewed annually and is available on bupa.com. All other

matters are delegated to the Group CEO, who has put in place a Delegated Authority Framework to cascade levels

of authority through the business. This is regularly reviewed and updated.

The Board believe Bupa’s existing governance structure is appropriate for the size and complexity of Bupa.


B.1.3 Board structure, roles and responsibilities

The role of the Senior Independent Director

The role of the Independent Director is to serve as a conduit for AMs and Directors who may have concerns that

have not been resolved through other channels, to act as a sounding board for the Chairman and Group CEO on

Board and AM matters and to lead the annual review of the Chairman’s performance.

The roles of the Chairman and Group CEO

The roles of the Chairman and the Group CEO are separate and defined in role profiles. The Chairman is

responsible for leading the Board and focusing it on strategic matters, overseeing the Group’s business and setting

high governance standards. He plays a pivotal role in fostering the effectiveness of the Board and individual

Directors, both inside and outside the board room. The Chairman is also responsible for ensuring that there is

effective communication with the AM’s, acting as a sounding board for the Group CEO and representing the Group

externally. With the support of the Company Secretary, he ensures that the Board receives accurate, timely and

clear information.

The Group CEO is responsible for the day-to-day leadership and management of the business, in line with the

strategic framework, risk appetite and long-term and annual objectives approved by the Board. The Group CEO

may make decisions in all matters affecting the operations, performance and implementation of strategy of Bupa’s

businesses, except for those matters reserved for the Board or specifically delegated by the Board to its


Committees, executive committees or subsidiary company boards. The Group CEO leads the BET in driving the

performance of the business and setting the overall strategic agenda.

The role of the NEDs and independence

Our NEDs provide an external and independent view on the running of our business, governance and boardroom

best practice. They oversee and constructively challenge management in its implementation of strategy within the

Group’s system of governance and the risk appetite set by the Board. The Board considers each of the current

NEDs to be independent in character and judgement and that there are no relationships or circumstances which

are likely to affect, or could appear to affect, each of their judgement. The Nomination & Governance Committee

has examined the link between Martin Houston and Caroline Silver at Moelis & Company, at which Caroline is a

Managing Director and Martin chairs the Global Energy Group. This potential conflict has been cleared by the

Committee. The Board is clear in its view that Professor Sir John Tooke remains independent of character and

judgement despite having served on the Board for over nine years, and that he makes an important contribution to

the Board on medical matters.

The Board comprises a majority of independent NEDs, and all Directors offer themselves for annual re-election by

the AMs. NEDs are appointed for an initial three-year term, and any term beyond six years is subject to particularly

rigorous review. A copy of the standard NED Terms of Appointment, setting out their expected time commitment, is

available on bupa.com and at Bupa’s registered office, and is also available for inspection before and during the

AGM. During the year, four meetings of the NEDs were held without management present, one of which was led by

the Senior Independent Director in the absence of the Chairman and Chairman Designate.

Board and Committee performance

This year, we carried out an internal questionnaire-based evaluation of the Board and its Committees. The

questionnaire was undertaken using an online tool provided by Independent Audit Limited, who carried out our last

externally facilitated evaluation in 2016. An external evaluation will be commissioned in 2019. The questionnaires

were completed by all Directors on the Board at 31 December 2018 except Paul Evans and Nicholas Lyons

(exempted since they only joined the Board on 1 November 2018). In addition, a number of standing attendees and

advisers to the Committees were asked to complete the appropriate Committee questionnaires. The Board and

each Committee analysed the results of the questionnaires and agreed appropriate actions to further enhance

effectiveness during 2019.

The Board concluded that, overall, the Board and Committees had operated effectively during the year. In particular,

it was found that Board members work well together with an open and trusting atmosphere and have a good mix of

skills, knowledge and experience. The Board clearly sets and contributes to the execution of strategy, focusing on

people as a lever to delivery. The Board also has a clear picture of the key risks and uncertainties facing the

business.

Lord Leitch led the evaluation of each Director’s performance in 2018 and concluded that each Director had carried

out their duties effectively during the year and contributed to the Board’s performance, devoting sufficient time to

the Company’s business and constructively challenging management.

Lord Leitch’s performance during the year was also assessed and the Board agreed that he was an excellent

Chairman who led inclusive discussions.


The agreed actions from the 2018 Board evaluation are set out in the adjacent table and progress against these will

be reported on in the 2019 Annual Report and Accounts.

Topic Agreed action Linkage to strategy

Considering the big trends Enhancing the content of Board

papers to include future trend in

more detail.

Inviting contributions from external

experts to challenge the Boards

thinking.

Putting out customers front and

centre.

Information security Closely monitor the Information

Security Transformation

Programme.

Digital transformation and

continuous improvement.

The Board reviewed progress against the 2017 evaluation actions during the year and a summary of progress made

is set out in the table below.

Topic Agreed action Progress made

Clarity on long-term strategy Keep Bupa’s long-term ambitions

and strategy under review.

The Board held a two-day strategy

session in June 2018 and additional

strategic matters have been

considered by the Board throughout

the year.

Focus on NED succession planning Finalise appointment of new

Chairman. Commence process to

recruit NEDS with international

financial services and medical

expertise respectively.

Roger Davis was appointed as

Chairman from 1 January 2019.

Four NEDs with financial services

experience have been recruited,

one with existing experience of our

Spanish business.

Professor Melvin Samsom was

appointed as a NED in April 2019,

bringing extensive medical

experience to the Board.

BET leadership succession Significant focus on further

strengthening of succession

planning in a number of specific

areas by the Board in December

2017.

An executive talent session was

held by the Board in September

2018. In particular, the Board

endorse the appointment of Hisham

El-Ansary as CEO, Australia and

New Zealand to succeed Richard

Bowden who will be retiring later

this year.

B.1.4 Committee structure

Audit Committee

The principal function of the Audit Committee is to monitor the integrity of Bupa’s financial statements, the

effectiveness of our internal control systems, and to monitor the effectiveness, performance, objectivity and

independence of the internal and External Auditors. The Committee also reviews regulatory reporting and disclosure

requirements.

The Group CEO, CFO, Group Financial Controller, CAO, Chief Risk Officer (“CRO”) and External Auditor are

routinely invited to attend meetings. The Committee meets at least annually with each of the External Auditor, CAO

and Chief Actuary in the absence of management. All of the Committee members have recent and relevant financial

experience.


Risk Committee

The principal role of the Committee is to assist the Board in its leadership and oversight of risk across Bupa. This

includes understanding current and future risk exposures, recommending overall risk appetite and tolerance to the

Board, reviewing the consistency of corporate strategy with the Company’s risk appetite, reviewing the Risk

Management Framework, considering the risk aspects of major transactions, and promoting a risk awareness

culture throughout Bupa. The Committee comprises independent NEDs. The Group CEO, CFO, CRO, Chief Medical

Officer (“CMO”), CAO and the External Auditor are invited to attend all meetings. The CRO has unrestricted access

to all members of the Committee and regular private meetings of the Committee with the CRO, in the absence of

management, are held during the year to ensure an opportunity for the CRO to raise any concerns he may have.

The Committee Chairman has recently been appointed as a member of the Remuneration Committee to ensure

that risk management and culture are taken into account in remuneration decisions. Each year, the Committee

provides a letter to the Remuneration Committee stating whether the Committee believes that variable remuneration

should be reduced to reflect risk or control concerns.

Nomination and Governance Committee

The Committee reviews the balance, structure and composition of the Board and its Committees and leads the

Board appointments process, making recommendations to the Board. It regularly considers succession planning to

ensure that the Board has the skills and expertise it needs to lead and manage the Company in the future. The

Committee also takes the Board Diversity Policy into account in both succession planning and recruitment. It leads

the selection and appointment of AMs and approves the appointment of Non-Executive directors and Non-Executive

chairmen of major subsidiaries in the Group. The Committee keeps Bupa’s governance structures under review and

makes appropriate recommendations to ensure that, where appropriate, Bupa’s arrangements are consistent with

best practice.

Remuneration Committee

The Committee is responsible for ensuring that Bupa adheres to high standards of governance and best practice in

remuneration matters. The remuneration policy is structured to promote the long-term success of the Company and

link reward to Bupa’s strategic goals and purpose.

B.1.5 Key functions

The Solvency II mandated key functions are embedded throughout Bupa with clear responsibilities and segregation

of duties. They are risk management, compliance, internal audit and the actuarial function. The roles and

responsibilities of these functions are described in Sections B.3: Risk management system, B.4: Internal control

system, B.5: Internal Audit function and B.6: Actuarial function.

B.1.6 Remuneration policy and practices

Bupa’s remuneration policy is designed to deliver market competitive reward to help attract, retain and motivate

high calibre employees and promote a prudent approach to risk.

The Bupa Remuneration Committee has responsibility for setting remuneration policy, approving the design of the

annual bonus scheme, the management bonus scheme and Long-Term Incentive Plan, choosing an appropriate

balance of performance measures and setting appropriate targets and maximums for all such incentive schemes.

The Committee reviews the ongoing appropriateness and relevance of the remuneration policy annually. In doing

so, the Committee takes into account all relevant factors including regulatory requirements, the provisions and

recommendations of the UK Corporate Governance Code and associated guidance, the views of AMs and other

stakeholders, the risk appetite of Bupa and input from the Risk Committee. It also takes independent external advice.

The Committee itself comprises NEDs. There is cross-membership between the Risk Committee, Audit Committee

and the Remuneration Committee.

In determining incentive outcomes, the Bupa Remuneration Committee consider if results have been achieved in a

way that aligns with our values, underlying business performance and approach to risk management, which includes

consideration of risk assessments summarised in annual letters from the Risk Committee and Risk Review Panel.

All incentive payments are subject to a risk adjustment which allows for downward adjustments in the event of poor

risk decision-making or risk management, including any breaches of Bupa’s risk appetite.


The Bupa reward package includes salary, pension, benefits, Management Bonus Scheme and eligibility for awards

under the Long-Term Incentive Plan if appropriate. Depending on the nature of an individual’s role, the size and

balance of the package may differ to ensure that the total package is competitive and encourages the right

behaviours, including avoiding undue risk. The remuneration mix for each employee broadly reflects market practice

for their role.

The Remuneration Report on pages 59 to 69 of the 2018 Annual Report includes detailed information on:

• The remuneration policy;

• The components of remuneration;

• Performance criteria on which entitlements are based;

• Pension arrangements for executive directors;

• The directors’ 2018 entitlements.

B.2 Fit and proper requirements

Bupa implements policies and procedures to ensure persons who effectively run the Group and subsidiary

undertakings or have other key functions are fit and proper to do so. Before appointment, and on an annual basis,

directors and senior managers are assessed with reference to the specific requirements of their particular role.

Certain individuals holding roles of significant influence are required to have received prior approval from the

appropriate regulator before they can perform their role.

An individual’s fitness to perform their role refers to their competence and capability including skills, knowledge and

expertise applicable. Assessments of fitness are tailored to the individual’s particular role, including the individual’s

knowledge and understanding of:

• The markets in which they operate (i.e. insurance/financial services and/or care provision);

• Business strategy and business model;

• System of governance;

• Financial and, where relevant, actuarial analysis;

• Regulatory framework and requirements.

Individuals are required to maintain their fit and proper status which would include arranging for further professional

training as necessary, so that the individual is also able to meet changing or increasing requirements of their

particular responsibilities.

Appointments are subject to background screening checks, which include verification of ID, previous employment

including references and relevant qualifications; directorship searches; screening against publicly available

information such as the global watch list; disclosure and barring service check; credit checks; and adverse media

searches.

Individuals are regularly monitored to ensure that they maintain fit and proper status for their role. This includes performance management and annual screening checks.

B.3 Risk management system including Own Risk and Solvency Assessment

B.3.1 Risk management framework

Our Risks

The risk profiles within our health insurance provision and aged care activities are different. Our broad geographical

reach also means that our local businesses are exposed to a wide range of political, regulatory, legal and economic

risks. We manage these by understanding the factors behind the risks to each individual business and to our balance

sheet, and by assessing how these risks interact. By understanding the risks we face - including emerging and

strategic risks - we can make sure we are best placed to manage and diversify them.

We accept risks as part of our business. Some risks are avoidable while others are part and parcel of our business

model. We have an effective risk management system and internal controls in place to mitigate these risks.


We maintain significant economic capital as a means of mitigating against certain inherent risks. This reflects the

nature of our operations and the level of risk associated with them. The most significant are:

• The risk of the volatility in values or the devaluations in properties held for own use (including owned care

provision properties), or for investment purposes, resulting in adverse impacts;

• Risks relating to Bupa’s insurance businesses. Risk of inadequate pricing and/or underwriting of insurance

policies, and of claims experience being materially adversely different to expectations;

• Risk arising from changes in the level, or volatility, of currency exchange rates impacting on cash flows and

assets held in currencies other than sterling, and on the financial statements.

Other significant risks to Bupa cannot be effectively mitigated through capital. Our Market Unit Executive Risk

Committees regularly review these residual risks and the mitigating actions taken to reduce them. They also inform

the Risk Committee (“BRC”) and Bupa Enterprise Risk Committee (“BERC”) about key areas of specific concern.

This provides management with a view of the priority areas in which resources should be focused. These include

information security including cyber resilience, privacy, people risks, changes in governmental and regulatory policy,

external market conditions and UK exit from the EU. This list and the residual risks for each have remained relatively

stable throughout 2018.

There are also other risks which capital cannot appropriately mitigate and which always remain a priority issue for

management. These include liquidity risks, strategic risks and environmental risks.

Further information on Bupa’s risk profile is provided at Section C: Risk profile.

Risk governance

Executive governance

We use a ‘three lines of defence’ approach to risk management.

The first line of defence covers management and employees across all of our businesses worldwide. Market Unit

CEOs are responsible for the identification and management of the risks within each Market Unit. Executive Risk

Committees, chaired by the CEOs, scrutinise the risk profiles and take mitigating action where necessary. The

culmination of this process is a meeting of the BERC, chaired by the Group CEO, which provides Group-level risk

oversight. For some key risks we’ve set up specific first-line risk forums, such as the Clinical Governance and

Solvency Capital Committee.

The second line of defence brings together our risk, compliance and clinical governance functions. We have a

Group Risk function led by the CRO and the CROs in each Market Unit. As well as leading the risk function in the

Market Units, the Group Risk Function advises, challenges and oversees first-line risk management activities and

keeps the BET and the Board informed of their independent view on risk issues.

The third line of defence is Internal Audit. We have a Global Internal Audit function led by the CAO. This function is

responsible for assessing the effectiveness and adequacy of governance and risk and controls. This includes

activities performed by the first and second lines of defence, in accordance with the Global Internal Audit Plan. An

Internal Audit Charter is in place setting out the function’s role, authority and independence. The function operates

in accordance with the Global Institute of Internal Auditors’ international standards.

Non-executive governance

We have non-executive governance processes at subsidiary board level for our main insurance subsidiaries as well

as at Group Board level.

Each of our large insurance entities is overseen by a local Risk Committee consisting mainly of independent NEDs

who oversee the risk management framework. Subsidiary boards receive regular reports from local management

and CROs.


The Risk Committee receives reports from the CRO, CMO and other Bupa executives as appropriate, and sees

minutes from the major insurance subsidiary boards’ BRC and the Group level executive BERC. The BERC is

responsible for the leadership and oversight of risk across the Group and recommends risk appetite to the Risk

Committee. The BERC is chaired by the Bupa Group CEO and provides Group-level executive risk oversight.

Risk appetite

Our Board risk appetite is a measure of the degree of risk we are prepared to accept in our work to deliver on our

strategy. Our core risk appetite statements focus on:

• Management of our financial strength;

• The treatment of customers and employees;

• The sustainability of our business;

• Operational risk.

The risk appetite statements are reviewed annually, with the Risk Committee recommending any changes to the

statements to the Board for approval.

Risk management framework

We manage risk across both our funding and provision businesses in line with our Board-approved Risk

Management Framework, which sets out the principles behind a robust and continuous risk management system

in our first line of defence.

This ensures that:

• Current and emerging risks to the businesses and strategy are identified and potential consequences are

understood;

• We have clear and established risk appetites within which we operate (these are discussed further below);

• We take appropriate and effective steps to mitigate and manage identified risks;

• We use risk management information to help inform risk-based decisions across the business;

• There is clear ownership of, and accountability for, risk;

• We have a culture in which:

• appropriate risk behaviours are encouraged and rewarded

• inappropriate behaviours are challenged with appropriate consequences

• risk events are communicated quickly without fear of blame.

We have well-established regular reporting systems in place to make sure that major risks to our businesses are

identified, escalated, managed and mitigated.

Our Enterprise policies define the way we do business. They cover all key areas of risk for our funding and provision

businesses and are implemented by our Market Units, which check our compliance against the requirements. These

policies are reviewed annually and have designated owners with defined roles and responsibilities at both the

enterprise and local levels.

The processes we use to identify, measure, manage, monitor and report risks include a stress and scenario testing

(“SST”) programme. We also carry out detailed reviews and in-depth analysis on particular risks where needed.

We test how effectively we are putting the Risk Management Framework into practice through our Internal Control

and Risk Management Assessment (“ICRMA”). This assesses how well internal control and risk management

practices and policy compliance are working across Bupa. It’s a self-assessment conducted by the first line of

defence and reviewed and challenged by the second and third lines. We run this assessment annually and the

results are presented to the Risk Committee.


Risk Management Function

The CRO leads the Bupa Risk and Compliance function and reports to the Group CEO. The CRO has unfettered

access to the Board Chairman and the Chairman of the BRC. The BRC has responsibility for approving the

appointment and removal of the CRO.

The Risk and Compliance function is split across each Market Unit and a team at the Centre (the Group Risk

function). Each Market Unit has a Chief Risk Officer who is responsible for the operation of the function. They have

a direct line of reporting into the Market Unit CEO.

B.3.2 Own Risk and Solvency Assessment

Bupa’s Own Risk and Solvency Assessment (“ORSA”) comprises the series of activities by which it assesses all

the risks inherent in its business and determines the corresponding capital needs. It therefore includes inter alia the

following activities:

• The projection of Own Funds and future capital requirements as part of the three-year business plan presented

to the Board for approval annually;

• The Economic Capital Assessment (“ECA”) in which Bupa makes its own quantification of how much capital is

required to support its risks. The ECA is used to assess how well the standard formula Solvency Capital

Requirement (“SCR”) reflects the Group’s actual risk profile. The ECA is presented to the BRC for approval in

April each year;

• The annual review of capital risk appetite which is approved by the BRC each year;

• The quarterly review of risks and risk appetite contained in the CRO’s report;

• SST and reverse stress testing carried out at least annually and approved by the BRC.

The outputs of the above activities are set out in papers and reports to the Board or relevant Board Committee and

summarised in the annual ORSA report which is approved by the Board. The conclusions of the ORSA are a key

input into Board strategy sessions.

The ORSA activities covered by this report are carried out in accordance with the Group Solvency II ORSA Policy

which sets out the high-level process for carrying out the ORSA. The processes and analysis are enhanced in light

of experience and feedback received and periodically the policy is updated to reflect these enhancements.

In addition to the regular ORSA report prepared at least annually, an ad-hoc ORSA report may be required if there

is a significant change in the risk profile and/or capital position of the Group. The ORSA policy sets out examples

of potential trigger events for an ad hoc ORSA. The capital position is kept under constant review and is reported

quarterly to the Board.

Bupa determines its own solvency needs by reference to the projected Own Funds and future capital requirements,

reflecting the risk profile of the Group, its policy of maintaining a substantial buffer over the capital requirements,

potential acquisitions and disposals which might take place over the planning horizon and the availability of

management actions.

B.4 Internal control system

B.4.1 Internal control

In line with the three lines of defence model, internal controls are the responsibility of business management. Internal

controls are implemented as part of the embedding of the suite of Enterprise Policies to:

• Promote the effectiveness and efficiency of operations;

• Ensure the reliability of financial reporting;

• Ensure Bupa operates to industry best practice and complies with applicable laws and regulations;

• Enable the Board and BRC to validate that Bupa is operating within its risk appetite;

• Support the embedding of a strong risk culture throughout the business.

As mentioned in section B.3.1 we test the effectiveness of our implementation of internal controls and policy

compliance through our ICRMA.


B.4.2 Compliance function

The Compliance function operates wholly within the second line of defence, both at Group and in the Market Unit

Risk and Compliance teams.

The Compliance function is concerned with financial services legislative and regulatory requirements and

expectations including:

• Customer outcome standards, e.g. customer fair treatment, training and competence, pre-sales, point-of-sales

and post-sales;

• High level controls, e.g. governance, skills and competency, systems and controls, conflicts of interest,

regulatory relationships, record keeping, complaints management, strategic risk, market conduct;

• Solvency and capital (EU, UK and individual territory prudential requirements);

• Regulatory processes, e.g. authorisations and licensing, individual approvals, fines and litigation, breach

management.

B.5 Global Internal Audit function

The Global Internal Audit team provides assurance over the effectiveness of governance, risk management and

internal controls. It reviews the effectiveness of controls by undertaking a programme of internal audit activity

approved by the Audit Committee each year. Internal Audit operates within Bupa’s three lines of defence model. As

the third line of defence, it supports Bupa in accomplishing its purpose by helping the Board to protect the assets,

reputation and sustainability of the organisation, and ensure risks to the customer and the Bupa business are

appropriately managed. It reports its findings to the Audit Committee and assists both the Board and management

to improve the effectiveness of governance, risk management and internal controls.

In order to maintain the function’s independence and objectivity, the CAO reports directly to the Chair of the Audit

Committee. Bupa’s internal auditors have no direct operational responsibility or authority over any of the activities

audited. Across our Global Internal Audit function there is a diverse skill set with many of the team holding relevant

professional qualifications, as well as having gained experience in insurance, health provision, transformation or

technology assurance. Where specific skills are not available in-house, the CAO and the Chair of the Audit

Committee can procure the services of expert external advisers.

The function acts in accordance with the Global Institute of Internal Auditors’ International standards and adopts the

guidance on effective internal audit outlined in the UK Chartered Institute of Internal Audit’s Financial Services Code.

In addition to a periodic external assessment on the effectiveness of the function, Global Internal Audit maintains a

quality assurance and improvement programme that continually enhances the effectiveness of the function and its

adherence to these standards. The outcomes of the programme, together with the results of internal audit activity,

are regularly reported to the Audit Committee to enable them to monitor the appropriateness of the quality,

experience and expertise of the function

B.6 Actuarial function

Bupa’s actuarial function activities, at the Group level, are conducted by qualified actuaries in our Centre Actuarial

function under the leadership of the Chief Actuary.

Key activities, including all mandatory tasks prescribed under Solvency II, are as follows:

• Coordinating and consolidating Group technical provisions (for IFRS and Solvency II reporting);

• Assessing the appropriateness of technical provision methodology and assumptions used;

• Setting the Group-wide methodologies and ensuring consistency of use across the Group;

• Ensuring that data quality and information technology systems meet the required standards;

• Reporting to the BRC on the adequacy of technical provisions, the overall underwriting policy and the adequacy

of reinsurance arrangements;

• Contributing to Bupa’s risk management activities by undertaking the SCR calculation, periodic monitoring and

annual calculation of the Group Specific Parameter (“GSP”) for premium risk and validation of standard formula

appropriateness through development of the ECA;


• Contributing to the stress and scenario testing and capital planning by calculating the projected Group technical

provisions and SCR under the base and stressed projections for ORSA;

• Overseeing the management of insurance risk across Group, including monitoring policy compliance for

underwriting, reserving and reinsurance arrangements;

• Coordinating group-wide actuarial community development activity, such as leading and sharing actuarial best

practices, and contributing to group-wide risk management practices.

An actuarial function report containing the Chief Actuary’s opinions, recommendations and an account of key

activities is provided to the BRC annually.

In each Market Unit, a senior actuary is responsible for the actuarial function of its insurance businesses, reporting

into Market Unit management.

The actuarial functions for Bupa Insurance Limited and Sanitas Seguros have performed all mandatory tasks set

out in the Solvency II Directive during the reporting period. The Chief Actuaries responsible for the entities have

reported their findings to their respective BRCs.

Qualified actuaries in Bupa’s Centre Actuarial function conduct both the Group level and Bupa Insurance Limited’s

actuarial function activities under the leadership of Bupa’s Chief Actuary. Bupa’s Chief Actuary is also the appointed

Chief Actuary for Bupa Insurance Limited.

Bupa’s Centre Actuarial function is separate from the Market Unit actuarial functions. This separation effectively

eliminates any potential conflicts of interest arising from the commercial responsibilities of Market Unit actuarial

functions.

B.7 Outsourcing

The Group has implemented an Enterprise Suppliers Policy. The purpose of this policy is to ensure that the Group

has effective processes for the selection, contracting and management of all external suppliers, allowing the risks

posed by external suppliers to be managed throughout the supplier relationship lifecycle. The policy is based on

four main principles: knowing our suppliers, selecting our suppliers, contracting with suppliers and managing our

suppliers.

All key, critical or important outsourced arrangements are required to be identified and managed with additional

rigour. The appointment of these arrangements must follow supplier selection criteria, with appropriate due diligence

and robust contracts in place following legal terms. Contingency measures must be in place and the relationships

managed by a named supplier relationship manager. The arrangements are reported to the local risk and

compliance team to assess the need for regulatory notification.

Each Market Unit in the Group is required to comply with the Enterprise Suppliers Policy and to have local policies

and procedures in place to meet these requirements.

Bupa chooses to outsource services where it is in the best interest of Bupa; it conforms to its regulatory standards

and ensures the correct customer outcomes. Bupa’s strategy is to form long term strategic partnerships with

suppliers who share the same values, focus on customer service and have an understanding of the current

regulatory and risk landscape.

Bupa continues to assess the need for outsourcing on an ongoing basis. Each outsourced activity is viewed on its

own merits against in-house capability, activity already outsourced and activity being undertaken. This allows Bupa

to leverage the relevant external expertise to undertake the activity efficiently and effectively. With robust oversight

(systems & controls) from Bupa this ensures the correct customer outcomes are achieved with reduced risks and

cost to serve.

Each outsourced supplier has a named supplier relationship manager. This individual is responsible for the oversight

of the arrangement and relationships, ensuring appropriate safeguards are in place, such as termination clauses,


continuity plans and agreed service levels. The relationship manager is also responsible for holding regular

meetings to manage the relationship. Comprehensive dashboards have been created to manage the outsourced

suppliers. The performance of Bupa’s outsourced relationships is fed into the Conduct Risk Dashboard which is

reviewed at the executive risk committee for the relevant Market Unit.

The Group has chosen to outsource a range of operational functions and activities. These include investment

management, IT services including data hosting and application support, claims processing and other customer

servicing operations (including telephony for customer servicing). The providers of investment management

activities are based in the UK, the IT service providers are based in the UK, India, Denmark and the USA, and the

service provider for claims processing is based in India. The providers of other customer servicing operations are

based in a range of jurisdictions including the UK, India, Cyprus, Malta, Jordan, Lebanon, the Czech Republic,

Singapore, USA, Kenya and Malaysia.

Intra-group outsourcing

Bupa Insurance Limited outsources customer-facing insurance administration and mediation activities to a fellow

wholly owned group company, Bupa Insurance Services Limited, via an Intra-Group Services Agreement. Bupa

Insurance Services Limited services all UK PMI and a large proportion of the IPMI contracts that are written by Bupa

Insurance Limited. In addition Bupa Insurance Limited has outsourcing arrangements with Bupa Worldwide

Corporation, USA Medical Services Corporation and Bupa Denmark Services A/S in respect of elements of its

International PMI business.

B.8 Any other information



C. Risk Profile

(Unaudited)

General information

The distribution of the Group’s quantifiable risks, as reflected in the SCR, is as follows:

The SCR risk profile is analysed further below to show the specific components of Market risk, split by Property,

Currency, Pension Scheme, Spread and Equity risks.

IFRS 16 Leases will apply from 1 January 2019. While this accounting change does not change our risk profile, it

requires all our operating lease assets and liabilities to be capitalised on the IFRS and Solvency II balance sheet.

The estimated value of both lease assets and liabilities at 1 January 2019 is £1.0bn. The lease assets attract a

property risk charge under the Solvency II Standard Formula. This, together with interest rate risk on the liability, is

estimated to increase the SCR charge by £0.2bn. See below for the estimated impact to the analysis of diversified

SCR.

Analysis of the SCR (diversified)

IFRS 16 Impact

01 Jan 2019

31 Dec 2018

31 Dec 2017

Market risk 62% 57% 57%

Property risk 42% 34% 32%

Currency risk 10% 11% 13%

Pension scheme risk 5% 7% 6%

Spread risk 3% 3% 3%

Equity risk 2% 2% 3%

Underwriting risk 15% 18% 18%

Operational risk 11% 12% 12%

Participations (associates) 9% 10% 8%

Credit risk 3% 3% 5%

Total 100% 100% 100%

Information on each of the risk categories is provided in Sections C.2 to C.6 below. Information is also provided on

liquidity risk in Section C.4. Liquidity risk does not form part of the standard formula SCR as this risk is not managed

by holding capital but by holding liquid assets and through appropriate controls.

Information on the calculation of the SCR is provided in Section E.2 Solvency Capital Requirement and Minimum

Capital Requirement.

Risk mitigation

As noted in Section B.3.1 we manage risks according to a Board approved Risk Management Framework covering

funding and provision businesses and we test the effectiveness of our implementation of the Risk Management

Framework through our ICRMA. Specific risk mitigations are identified in Section C.1 to C.6 where relevant.


C.1 Underwriting risk

Underwriting risk refers to the potential deviation from the actuarial assumptions used for setting insurance premium

rates which could lead to premium inadequacy. Underwriting risk is therefore concerned with both the setting of

adequate premium rates (pricing risk) and the management of claims (claims risk) for insurance policies

underwritten by the Group.

Pricing risk

Pricing risk relates to the setting of adequate premium rates taking into consideration the volume and characteristics

of the insurance policies issued. External influences on pricing risk include (but are not limited to) competitors’

pricing and product design initiatives, and regulatory environments. The level of influence from these external factors

can vary significantly between regions and largely depends on the maturity of health insurance markets and the

role of the regulator.

In every insurance company in the Group, the dominant product or policy category is an annually renewable health

insurance contract. This permits insurance premium rate revisions to respond quickly to changes in customer risk

profiles, claims experience and market considerations.

Mitigation

Actuarial analysis performed on a regular basis combined with an understanding of local market dynamics and the

ability to change insurance premium rates, when necessary, are effective risk mitigations.

The ability to review premium rates is a significant mitigation to pricing risk. The Group does not underwrite material

general insurance business that commits it to cover risks at premiums fixed beyond a 12-month period from

inception or renewal.

Claims risk

Claims risk is the risk of claims exceeding the amounts assumed in the premium rates. This can be driven by

adverse fluctuations in the amount and incidence of claims incurred, and external factors such as medical inflation.

Adverse claims experience, for example, which is caused by external factors such as medical inflation, will affect

cash flows.

Generally, the Group’s health insurance contracts provide for the reimbursement of incurred medical expenses,

typically in-hospital, for treatment related to acute, rather than chronic, medical conditions. The contracts do not

provide for capital sums or indemnified amounts. Therefore claims experience is underpinned by prevailing rates of

illness events giving rise to hospitalisations.

Mitigation

Claims risk is managed and controlled by means of pre-authorisation of claims, outpatient benefit limits, the use of

consultant networks and agreed networks of hospitals and charges. Specific claims management processes vary

across the Group depending on local requirements, market environment and practice.

Claims risk is generally mitigated by insurers having processes to ensure that both the treatments and the resulting

reimbursements are appropriate.

Reserving risk

Reserving risk is the risk that provisions made for claims prove to be insufficient in light of later events and claims

experience. There is a relatively low exposure to reserving risk compared to underwriting risk due to the very short-

term nature of our claims development patterns. The short-term nature of the Group’s general insurance contracts

means that movements in claims development assumptions are generally not significant.

The amount of claims provision at any given time that relates to potential claims payments that have not been

resolved within one year is relatively small in the context of the Group. The small provisions that relate to longer

than one year can be calculated with reasonable confidence.


Mitigation

The development of claims settlement patterns are kept under constant review to maintain the validity of the

assumptions and hence the validity of the estimation of recognised general insurance liabilities.

Underwriting risk sensitivities

Sensitivity analysis

Coverage ratio post

stress

Base case solvency coverage ratio 191%

GSP + 0.2% 188%

Loss ratio worsening by 2% 182%

The GSP sensitivity is based on a 20 basis points increase in the GSP parameter for insurance premium risk. The impact on the solvency coverage ratio is immaterial.

Other risks related to underwriting health insurance business

Claims provisions are not discounted and their short-term nature means that changes in interest rates have no

impact on reserving risk. In addition, the future premium income and claims outflows of health insurance premium

liabilities are largely unaffected by changes in interest rates. However, changes to inflationary factors such as wage

inflation and medical cost inflation affect the value of future claims outflows.

None of the Group’s general insurance contracts contain embedded derivatives so the contracts do not give rise to

interest rate risk.

The Group is exposed to foreign currency risk through some of the insurance liabilities which are settled in a local

currency.

Mitigation

Where possible, these liabilities are matched to assets in the relevant currency to hedge this exposure.

Concentrations of risk

The majority of the Group’s general insurance activities are single line health portfolios. Even though only one line

of business is involved, the Group does not have significant concentration of insurance risk for the following reasons:

• Broad geographical diversity across several markets – across the UK, Spain, Australia, Latin America, the Middle East and Hong Kong;

• Product diversity between domestic and expatriate, and individual and corporate health insurance; • A variety of claims type exposures across diverse medical providers, consultants, clinics, individual

hospitals and hospital groups.

Mitigation

The Group as a whole, and its principal general insurance entities, are well diversified geographically in respect of

insurance risk. Only in selected circumstances does the Group use reinsurance. The reinsurance used does not

give rise to a material counterparty default credit risk exposure for the Group. Restrictions are in place on the credit

quality and amount of reinsurance ceded to individual counterparties.

Catastrophe risk

A natural disaster or a man-made disaster could potentially lead to a large number of claims and thus higher than

expected claims costs.

Mitigation

Generally, the Group’s health insurance contracts do not provide for the reimbursement of incurred medical

expenses following a catastrophe. Therefore, in the majority of jurisdictions, Bupa is not liable for such claims and

this risk is not material for the Group.


C.2 Market risk

Market risk is the risk of adverse financial impact due to changes in fair values or future cash flows of financial

instruments arising from fluctuations in interest rates, foreign exchange rates, commodity prices, credit spreads and

equity prices. The focus of the Group’s long-term financial strategy is to facilitate growth without undue balance

sheet risk.

Mitigation

In order to reduce the risk of assets being insufficient to meet future policyholder obligations, the Group actively

manages assets using an approach that balances duration, quality, diversification, liquidity and investment return.

The Group invests in limited portfolio of return-seeking assets (principally bonds and loans) via our regulated entities

in the UK and Australia. These assets totalled £452m as at 31 December 2018 (2017: £404m). These entities use

value at risk analysis (“VaR”) to quantify risk, taking account of asset volatility and correlation between asset classes.

In addition to local VaR analysis, the Group’s overall cash and investment portfolio is managed by limiting the

contribution of the combined investment risk charge to maximum percentage of the Group’s SCR.

The approach to investment decision making is governed by the Board. The Board determines the overall risk

appetite for the Group which is articulated through the risk parameters contained in the Group’s Treasury Policy.

Responsibility for treasury activities is delegated through the Group Level Authorisation Matrix in the Treasury Policy

with key accountabilities residing with local Finance Directors and investment committees of material insurance

subsidiaries.

C.2.1 Property risk

Property risk is the risk of volatility in values or the devaluation of properties held for own use (including owned care

provision properties), or for investment purposes, resulting in adverse impacts. We generally own rather than rent

property, which keeps lease commitments down but leaves us exposed to falls in property values.

Care home valuations are based on underlying profitability of the individual homes (information on the valuation

methodology is included in section D.1.6.1). Property risk is the single largest risk component of our SCR. The SCR

risk principally relates to our care home portfolio in the UK, Australia, New Zealand and Spain. The majority of these

care homes are not in insurance entities and therefore our policyholders are largely protected against the volatility

of the property values. The property risk charge under the standard formula SCR has remained relatively stable

during the year, however this charge will increase in 2019 following the implementation of IFRS 16 (Leases).

Mitigation

By maintaining a geographic spread of businesses across a number of countries, we are able to diversify exposure

to individual property markets.

C.2.2 Currency risk

Currency risk arises from changes in the level, or volatility, of currency exchange rates impacting on cash flows and

assets held in currencies other than sterling, and on the financial statements.

The Group is exposed to foreign exchange risks arising from commercial transactions and from recognising assets,

liabilities and investments in overseas operations. The Group is exposed to both transaction and translation risk.

The former is the risk that a company’s cash flows and realised profits may be impacted by movements in foreign

exchange rates. The latter arises from translating the financial statements of a foreign operation into the Group’s

functional currency.

Transactional exposures arise primarily in International Markets businesses as a result of differences between the

currency of local revenues and claims. The currency exposures are deemed to be acceptable but are kept under

review by management.


Under Solvency II key exposures are to Australian dollar, Euro, United States Dollar, New Zealand Dollar, Chilean

Pesos and Hong Kong Dollar.

Mitigation

The Group manages its exposure to foreign exchange risk by entering into hedging transactions using derivative

financial instruments. The hedging relationship between a hedging instrument and a hedged item is formally

documented. Documentation includes the risk management objectives and the strategy in undertaking the hedge

transaction.

C.2.3 Pension scheme risk

Bupa has market and longevity risk exposure in respect of defined benefit pension schemes, principally the UK

based Bupa Pension Scheme. Although pension scheme risk represents a material part of the Group SCR, the

pension scheme has sufficient assets to absorb the risks of the scheme and therefore the risk to policyholders and

the wider group is very limited.

C.2.4 Interest rate risk

Interest rate risk is the risk that the fair value or future cash flows of a financial instrument will fluctuate because of

changes in market interest rates.

The Group is exposed to interest rate risk arising from fluctuations in market rates. This affects the return on variable

rate assets, the cost of variable rate liabilities and the balance sheet value of its investment in fixed rate bonds.

Interest rate risk forms an immaterial part of the Group SCR.

Mitigation

Variable rate assets represent a natural hedge for variable rate liabilities. The Group has also used interest rate

swaps to manage interest rate exposure whereby the requirement to settle interest at fixed rates has been swapped

for variable rates. This increases the ability to match variable rate assets with variable rate liabilities.

C.2.5 Market risk sensitivities

The following analysis is provided to show the relative sensitivity of our estimated solvency coverage ratio as at 31

December 2018 to changes in market conditions. Each sensitivity is an independent stress of a single risk and does

not take into account management actions. The selected scenarios do not represent our expectations for future

market and business conditions.

Sensitivity analysis Coverage ratio post stress

Base case solvency coverage ratio 191%

Interest rate +100bps 190%

Credit spreads +100bps 190%

Equities markets -20% 191%

Property values -10% 180%

Sterling appreciates by 10% 187%

Pension risk +10% 190%

Credit spreads are the differences between risk free rates and the yields achieved on both corporate and sovereign

bonds.

Interest rate and credit spreads sensitivities do not have a material impact on the solvency coverage ratio due to

the short-term nature of the Group’s non-pension assets and liabilities and the fact that investments are held with

highly rated credit institutions. Equities form a very small proportion of Group’s assets hence the equity sensitivity

also has a limited impact.


The property value sensitivity indicates the impact from a 10% fall in property values. The single largest risk

component of our SCR is property risk, most of which relates to freehold properties owned by care home businesses

in the UK, Australia and New Zealand. These properties are owned by separate companies which are not

subsidiaries of insurance entities. Therefore our insurance policyholders are not directly exposed to the volatility of

the value of these properties.

The pension risk sensitivity indicates the likely impact from a 10% rise in the pension risk SCR contribution to the

Group SCR. Pension risk mainly consists of market risks (i.e. spread risk and interest rate risk) which affect the

funding position of the pension scheme due to investment market conditions. The Group solvency capital position

is largely unaffected by the changes to the pension funds market risk SCR under the stressed scenarios because

the pension scheme surplus is sufficient to absorb the sensitivity analysis stress such that the Group solvency

capital surplus is unchanged.

C.3 Credit risk

Credit risk is the risk that those that are in debt to the Group default on their obligation. Examples of credit risk would

be non-payment of a trade receivable or a corporate bond failing to repay the capital sum and related interest.

Mitigation

Investment exposure with external counterparties is managed by ensuring there is a sufficient spread of investments

and that all cash and investment counterparties are rated at least A by two of the three key rating agencies used by

the Group (unless specifically approved by the Corporate Finance Executive Committee). Other factors are also

monitored including credit default swap levels and counterparty specific information. Risk of counterparties failing

to meet obligations is considered through the Company’s SST programme.

C.4 Liquidity risk

Liquidity risk is the risk that we hold insufficient financial resources to enable us to meet our obligations as they fall

due or to take advantage of potential opportunities, or of being able to secure such resources only at excessive

cost, resulting in adverse impacts. The Group's main source of short-term funding is via an £800m revolving credit

facility which was drawn down by £170m (2017: £226m) at 31 December 2018. This facility matures in 2022.

The Group monitors funding risk as well as compliance with existing financial covenants within the banking

arrangements. There were no concerns regarding bank covenant coverage in 2018 and that position is not expected

to change in the foreseeable future.

The Group enjoys a strong liquidity position and adheres to strict liquidity management policies as set by the Bupa

Risk Committee as well as adhering to liquidity parameters for the Group’s regulated entities. Regular stress testing

is conducted to assess liquidity risk.

Mitigation

Liquidity risk is addressed not by capital but by holding liquid assets and through appropriate controls. With

Policyholder liabilities are predominantly backed by liquid assets, so our liquidity risk exposure primarily relates to

the funding risk associated with borrowings. This is mitigated by the Treasury function actively managing

borrowings, for which the amount and timing of outflows are known, and maintaining a portion of the bank facility

undrawn. Liquidity risk is considered as part of the SST. For further details refer to Section C.7.2.

Expected profits in future premiums

Under Solvency II, expected profit relating to future premiums is recognised in the calculation of technical provisions

and therefore it is included in Own Funds. Expected profit relating to future premiums does not form part of the

liquidity position as at 31 December 2018 but is taken into consideration when assessing the Group’s future liquidity.

The expected profit included in future premiums as at 31 December 2018 has been calculated as £322m (2017:

£280m).


C.5 Operational risk

Operational risk is the risk of loss arising from inadequate or failed internal processes, or from personnel, systems

or external events. This risk also includes customer risk (the risk that our behaviours, actions or controls result in

detriment or unfair outcomes for our customers); and clinical risk (the risk of injury, loss or harm to customers in

receipt of healthcare).

Operational risk does not lend itself to sensitivity analysis. We conduct operational risk scenario analysis exercises

which allow us to understand the specific risks that Bupa faces, the likelihood of them occurring and the severity of

the impact if they were to occur. This understanding allows for a more focused allocation of resources into mitigating

or controlling the more material exposures.

Mitigation

We are committed to managing operational risk effectively. This includes continued close attention to management

of regulatory risk and proactive engagement with regulators. Maintaining robust internal control processes and

governance frameworks, approving risk policies, and assessing compliance helps mitigate this risk.

All Market Units have a Medical Director responsible for ensuring clinical quality and governance within the

business. They are accountable to the CMO for clinical governance.

C.6 Other material risks

C.6.1 Other risks

Other significant risks to Bupa cannot be effectively mitigated through capital. Our Market Unit Executive Risk

Committees regularly review these residual risks and the mitigating actions in place to reduce them. They also

inform BRC and BERC about key areas of specific concern. This provides management with a view of the areas of

priorities to focus resources. The table below reflects the themes of the most significant risks currently facing Bupa.

This list and the residual risks for each have remained relatively stable throughout 2018.

Risk Comment and outlook Mitigating actions

Information security including

cyber-resilience

The risk of significant financial and reputational impacts due to a failure to appropriately secure information (including personal information).

Businesses are increasingly being targeted by cyberattacks.

We have a detailed programme of activities across Bupa to appropriately mitigate this risk.

We have also set up Bupa’s Enterprise Information Security and Privacy Committee, a subcommittee of the BERC, to specifically focus on both information security and privacy risks while delivered continual service improvement through our digital transformation.

Privacy

The risk of adverse impacts due to failure to handle personal information fairly, lawfully and securely.

Regulatory requirements and expectations in relation to privacy are increasing globally.

This is also true of customer expectations as people become increasingly aware of the value and risks associated with their personal information.

We continually review and improve our controls over the management and security of personal information.

We have appointed Data Protection Officers, privacy experts as part of our enterprise-wide privacy Risk Management Framework activities to help manage this risk.


Risk Comment and outlook Mitigating actions

People – impacting our growth

agenda

The risk that we do not have the appropriate levels of capacity and capability of people to deliver our strategic objectives.

As a business with an international footprint it’s critical to our strategy that our people have the appropriate knowledge, skills and experience to identify and manage risk and to deliver on objectives.

This is an area of significant focus for the Bupa Executive Team.

We are focussing on ensuring we have the right experience and succession plans to run our businesses and manage change, supported by a simple operating model and improved ways of delivering training.

Where we acquire businesses these bring additional resources to the Company,

Changes in government and

regulatory policy

The risk that we fail to anticipate, respond to, or influence changes in the government and regulatory environment which may impact the viability or profitability of the business

Our funding and healthcare provision businesses are subject to government and regulatory policy including minimum wage requirements, prudential requirements, changes to tax regimes and the interpretation of existing tax practices, pricing controls in some of our funding businesses and clinical care requirements for our healthcare provision businesses.

All our markets have defined key activities to make sure we can continue to monitor and assess the strategic implications on our businesses of any future changes in policy or regulation, and to lobby for appropriate change in these areas.

We continue to work with the Australian Government to support a broader health reform to help address the sector challenges.

External market conditions

The risk of geopolitical volatility, changing consumer dynamics and competitor activity having an adverse impact on the viability of the business model.

This includes structural market changes (e.g. political change or medical inflation) and economic volatility.

We review our strategy and processes to ensure that they are flexible enough to cope with changing external conditions.

UK exit from the EU

The UK’s decision to leave the EU has led to uncertainty for our business.

Bupa’s key financial metrics remain strong. While uncertainty around Brexit may negatively impact sterling, as a Group with

significant operations outside of the UK this would lead to higher reported profits. Operationally, currency risk is actively managed.

Liquidity is robust and the investment portfolio is largely case-based and low risk in bonds and cash.

We have established a new entity in

Ireland to provide continuity for our

Bupa Global customers within the

European Economic Area.

We have monitoring and risk management plans in place to protect Bupa’s position from a customer, people and performance perspective, whilst recognising that the impacts of Brexit are likely to crystallise over time at an operational level and will be dependent on a range of political and economic factors.

There are also other risks where capital is not an appropriate mitigant and even though they are not highlighted in

the table above are always a priority issue for management. This includes liquidity risk which is considered in Section

C.4.

The remaining risk relates to Strategic Risk, which is the risk that we are unable to design or implement appropriate

business plans and strategies, to make decisions, to allocate resources, or to adapt to changes in the business

environment. This includes the risks associated with acquisitions and disposals and their implementation. Through

the identification and assessment of emerging risks, we can react to issues in a timely and appropriate manner.

C.6.2 Risk concentrations

Bupa has a small number of significant risk concentrations in its two largest markets (the UK and Australia).


Bupa’s investment strategy is conservative, and we prefer low-risk asset classes. These assets are predominantly

money market instruments held with banking counterparties, hence there is a significant risk concentration to the

Australian banking sector. These counterparties are highly rated and Bupa has internal limits in place to monitor

and manage exposure to individual counterparties.

Bupa has significant property risk concentrations in the UK and Australia. Property values in the UK and Australia

as at 31 December 2018 were £900m and £964m respectively. We generally own rather than rent property. This

could leave us exposed to a fall in property values. By maintaining a geographic spread of businesses across a

number of countries, we are able to diversify exposure to national or regional property markets.

C.7 Any other information

C.7.1 Prudent person principle

Bupa operates in accordance with the prudent person principle. Bupa’s approach to investment decision-making is

governed by the Bupa Board of Directors who:

• Determine the overall risk appetite for the Group to be articulated through investment risk limits and other

metrics identified in the Treasury Policy;

• Approve the Treasury Policy document on at least an annual basis;

• Oversee Group wide investment risk and performance against targets;

• Delegate responsibility for treasury activities through the Group level Authorisation Matrix.

C.7.2 Stress and scenario testing

A key part of Bupa’s risk management framework is to identify scenarios that could adversely impact Bupa and

assess our ability to withstand them. SST is also a requirement of many of our regulators including the UK PRA and

the Australian PRA. In a Solvency II context, the European Insurance and Occupational Pensions Authority

(“EIOPA”) guidelines for both systems of governance and the ORSA require SST to be carried out.

SST impacts are quantified and fed into the ORSA which, amongst other things, assesses the ability of Bupa under

current plans to withstand adverse scenarios and still have sufficient capital resources to cover both its own

assessment of risks and regulatory minimum capital requirements. As such, SST is a key element of the ORSA.

Our SST programme considers a number of scenarios based on macro and microeconomic impacts on the business

in addition to stress testing of a range of single risk factors e.g. premium volume. Scenario analysis generally relates

to combinations of risks tied to a single event e.g. economic recession triggering higher lapses and falling property

values. The Group also conducts reverse stress testing which starts at the point of failure of the Bupa business

model and aims to identify a scenario that may result in such a failure.

Under each of the scenarios tested, the Group continues to have a surplus in excess of its SCR over the business

planning period without the need for management actions.


D. Valuation for Solvency Purposes

(Audited)

Solvency II requires an economic market consistent approach to the valuation of assets and liabilities. A number of

assets and liabilities require different valuation methods to those used in the financial statements included in Bupa’s

Annual Report and Accounts for the year ended 31 December 2018. The financial statements are prepared under

IFRS. The table below summarises the Solvency II and the IFRS valuation of assets and liabilities, based on the

Solvency II balance sheet headings and the Solvency II approach to classifying assets and liabilities. An explanation

of the Solvency II valuation methods and assumptions, including key differences to those used under IFRS is

provided in the subsequent sections.

Solvency II IFRS Variance

Assets

Section

2018

£m

2017

£m

2018

£m

2017

£m

2018

£m

2017

£m

Goodwill D.1.1 - - 2,955 2,963 (2,955) (2,963)

Deferred acquisition costs D.1.2 - - 139 117 (139) (117)

Intangible assets D.1.3 - - 1,307 1,324 (1,307) (1,324)

Deferred tax assets 52 6 52 6 - -

Pension benefit surplus D.1.4 602 577 602 577 - -

Property, plant and equipment held for own

use

D.1.5 605 570 722 653 (117) (83)

Investments D.1.6 5,981 5,939 6,374 6,268 (393) (329)

Loans and mortgages 83 69 97 81 (14) (12)

Reinsurance recoverables 6 7 23 18 (17) (11)

Insurance and intermediaries receivables D.1.7 184 258 1,174 1,082 (990) (824)

Reinsurance receivables 4 13 12 13 (8) -

Receivables (trade, not insurance) D.1.8 348 490 345 490 3 -

Cash and cash equivalents D.1.9 1,257 1,122 1,254 1,118 3 4

Any other assets, not elsewhere shown D.1.10 280 291 348 353 (68) (62)

Total assets 9,402 9,342 15,404 15,063 (6,002) (5,721)

Technical provisions D.2 1,420 1,428 2,753 2,637 (1,333) (1,209)

Provisions other than technical provisions D.3.2 178 132 178 132 - -

Pension benefit obligations D.3.3 62 67 62 67 - -

Deposits from reinsurers D.2 6 6 6 6 - -

Deferred tax liabilities D.3.4 136 151 355 310 (219) (159)

Derivatives (liabilities) D.3.5 52 20 47 19 5 1

Debts owed to credit institutions D.3.6 356 465 356 465 - -

Financial liabilities other than debts owed to

credit institutions

D.3.7 717 727 700 704 17 23

Insurance and intermediaries payables D.3.8 61 95 146 95 (85) -

Reinsurance payables 4 16 21 16 (17) -

Payables (trade, not insurance) D.3.9 388 365 388 367 - (2)

Subordinated liabilities not in Basic Own

Funds

D.3.10 - 35 - - - 35

Subordinated liabilities in Basic Own Funds D.3.10 1,277 1,295 1,255 1,303 22 (8)

Any other liabilities, not elsewhere shown D.3.11 1,627 1,654 1,627 1,654 - -

Total liabilities 6,284 6,456 7,894 7,775 (1,610) (1,319)

Excess of assets over liabilities 3,118 2,886 7,510 7,288 (4,392) (4,402)

Solvency II methodology changes were made in the year relating to insurance and reinsurance related receivable

and payable balances, reclassifying additional insurance balances that are ‘not past due’ to Technical Provisions.

This has no impact on the net excess of assets over liabilities and is explained further in section D.2.5.


The overall difference between the IFRS and Solvency II excess of assets over liabilities is due to the following

valuation differences:

Valuation differences

2018

£m

2017

£m

Assets (4,853) (4,750)

Liabilities 461 348

Total valuation differences (4,392) (4,402)

Other differences between individual asset and liability classes relate to IFRS to Solvency II reclassifications, as

noted in the respective sections below.

Preparation of the Group’s consolidated Solvency II balance sheet

All companies in the Group that are controlled by Bupa are considered to be (i) insurance or reinsurance

undertakings; (ii) insurance holding companies; or (iii) ancillary services undertakings. Therefore, all companies are

fully consolidated. Investments in associates are accounted for using the adjusted equity method with assets and

liabilities valued using Solvency II valuation methods.

D.1 Assets

D.1.1 Goodwill

Goodwill in the IFRS financial statements represents the excess of the cost of a business combination over the fair

value of the Group’s share of identifiable assets, liabilities and contingent liabilities of the acquired entity. Goodwill

is valued at £nil within the Solvency II balance sheet as it is not a separable and saleable asset.

D.1.2 Deferred acquisition costs

Acquisition costs represent commissions payable and other expenses related to the acquisition of insurance

contract revenues written during the financial year. The assets arising from the deferral of these costs are valued

at £nil within the Solvency II balance sheet as they are not a separable and saleable asset.

D.1.3 Intangible assets

Intangible assets recognised in the IFRS financial statements include computer software, customer relationships,

bed licences, brands and trademarks, licences to operate care homes and leases. Intangible assets are valued at

£nil in the Solvency II balance sheet as no active markets have been identified for the assets.

D.1.4 Pension benefit surplus

The Group operates several funded defined benefit and defined contribution pension schemes for the benefit of

employees and directors. The Group also has unfunded defined benefit pension arrangements and an unfunded

post-retirement medical benefit scheme. The pension schemes and the unfunded post-retirement medical benefits

are fair valued under IFRS, hence no adjustment is required from IFRS to Solvency II as at 31 December 2018.

Further details on the capital treatment of the pension benefit surplus are provided in Section E.1.4.

Please refer to Note 7 post-employment benefits in the Group 31 December 2018 Annual Report and Accounts for

detailed information on the basis, method of valuation as well as key assumptions.


D.1.5 Property, plant and equipment held for own use

Property, plant and equipment held for own use includes the physical assets used by the Group to carry out

insurance business or office buildings carrying on normal office activities.

Solvency II IFRS Variance

2018

£m

2017

£m

2018

£m

2017

£m

2018

£m

2017

£m

Freehold and leasehold properties 148 126 148 126 - -

Equipment 457 444 574 527 (117) (83)

Total property, plant and equipment 605 570 722 653 (117) (83)

Freehold and leasehold properties

In the IFRS financial statements properties are held using the revaluation method under IAS 16 which is consistent

with the valuation requirements under Solvency II. Hence no adjustment is required from IFRS to Solvency II. Refer

to Section D.1.6.1 for significant assumptions relating to property valuations.

Equipment

In the IFRS financial statements equipment is stated at historical cost less subsequent depreciation and impairment

losses.

Equipment is valued at fair value under Solvency II. For equipment held in freehold or long leasehold properties,

fair value is established as part of the valuation of the properties performed by external independent valuers, using

a discounted cash flow valuation. Refer to Section D.1.6.1 for significant assumptions relating to property valuations.

In the absence of market data being available for similar assets, equipment held outside freehold or long leasehold

properties is valued on a Solvency II basis using an income approach to valuation. This is based on the value in

use of the equipment from the perspective of a third-party buyer. Where market data is not easily obtained these

balances are valued at £nil.

IT hardware is valued for Solvency II purposes using replacement cost adjusted for obsolescence as quoted market

prices for the same or similar assets are not available. Where these are deemed to not be transferable to a third

party they are written down to nil.

In calculating the valuations of property and equipment, the material assumptions used include the future cash

inflows and outflows generated by the assets (which include assumptions on quantifying a fair, maintainable level

of trade and profitability; levels of competition; and assumed ability to renew existing licences, consents, certificates

or permits), inflation, terminal values and the discount rate. An element of uncertainty is inherent in such valuations.


D.1.6 Investments

The Group generates cash from its underwriting, trading and financing activities and invests the surplus cash in

financial investments. These include property, participations, government bonds, corporate bonds, collective

investment undertakings and deposits with credit institutions.

Solvency II

2018 2017

£m £m

Property (other than for own use) D.1.6.1 2,939 3,042

Participations D.1.6.2 279 207

Equities D.1.6.3 20 20

Government bonds D.1.6.3 229 281

Corporate bonds D.1.6.3 1,011 719

Collective investments undertakings D.1.6.3 312 439

Derivative assets D.1.6.3 30 50

Deposits other than cash equivalents D.1.6.3 1,161 1,181

Total investments 5,981 5,939

D.1.6.1 Property (other than for own use)

Property (other than for own use) is recognised in the Group’s Solvency II balance sheet at fair value and includes

properties classified as property, plant and equipment in the IFRS financial statements, properties classified as

investment property in the IFRS financial statements and also properties classified as held for sale in the financial

statements. The IFRS financial statements apply either the revaluation method under IAS 16 Property, Plant and

Equipment, or the fair value model per IAS 40 Investment Property, which are consistent with the valuation

requirements for the Solvency II balance sheet. Hence no adjustment is required from IFRS to Solvency II as at 31

December 2018.

The Solvency II fair valuation guidelines indicate that maximum use must be made of market data. In the absence

of quoted market prices for the same or similar assets, alternative valuation methods are allowed. Details of the

valuation basis and assumptions used for these assets are set out below.

Revaluation of properties

Valuations are performed with sufficient regularity to ensure that the carrying value does not differ significantly from

fair value at the balance sheet date. The external revaluation of properties in 2018 were performed independently

by Alia Tasaciones S.A. in Spain and Phi Partners Consultores in Chile. Revaluations were effective as of 31

December in the year in which they were undertaken. Directors’ valuations were performed in the year where it was

identified that carrying value differed significantly from fair value.

Freehold and leasehold property

Care homes and hospitals are valued with regard to their trading potential based on discounted cash flow

techniques, the principal assumptions are: quantifying a fair, maintainable level of trade and profitability; levels of

competition; and assumed ability to renew existing licences, consents, certificates or permits.

The valuations of care homes in the Group and hospitals in Spain, Chile and Poland are determined based on a

capitalisation of earnings approach. A multiple is applied to each facility’s earnings to project the financial

performance of the facility to determine its value in use. The multiple applied for each facility is set based on

qualitative and quantitative indicators of the facility’s current and future performance and assumes normal prudent

management of the facility. Unobservable inputs for these properties include the average capitalisation rate which

is the average rate of return on a property based on the income that the property is expected to generate. It

considers trends in earnings and land values. For all properties except those in Poland, the average occupancy is

also an unobservable input. All other properties are valued by external valuers based on observable market values

of similar properties.


The sensitivity analysis below considers the impact on the year end valuation of properties and is based on a change

in assumption while holding all other assumptions constant. In practice, this is unlikely to occur and changes in

assumptions may be correlated.

Freehold and leasehold property

0.5% absolute

increase

0.5% absolute

decrease

Australia

Average occupancy rate £5m increase £5m decrease

Average capitalisation rate £18m increase £20m decrease

New Zealand



UK



Spain



Chile

Average occupancy rate N/A N/A


Poland

Average occupancy rate N/A N/A


Investment properties

The carrying value of investment properties of £454m (2017: £399m), primarily consisting of the Group’s portfolio

of retirement villages in New Zealand, was valued by management using internally prepared discounted cash flow

projections, supported by the terms of any existing lease and other contracts, and when possible, by external

evidence such as current market rents for similar properties in the same location and condition. Discount rates are

used to reflect current market assessments of the uncertainty in the amount or timing of the cash flows. The

discounted cash flow projections are reviewed by an independent valuer, Deloitte.

Significant assumptions used in the valuation include:

Australia and New Zealand

Discount rate 9.5%

Capital growth rate 2.6%

Provision for capita replacement 0.4%

Vacancy period 3 months

Turnover in apartments and villas 4 - 6 years

The sensitivity analysis below considers the impact on the year end valuation of investment properties, and is based

on a change in assumption while holding all other assumptions constant. In practice, this is unlikely to occur and

changes in assumptions may be correlated.


0.5% absolute

increase

0.5% absolute

decrease

Australia and New Zealand

Discount rate £10m decrease £21m increase

Capital growth rate £52m increase £46m decrease

D.1.6.2 Participations

Participations comprise investments in associated companies and are recognised using Solvency II values. The

Group’s material participations, as at 31 December 2018, are:

Business

activity

Share of issued

share capital

Principally

operates in

Country of

incorporation

Bupa Arabia for Cooperative Insurance

Company

Insurance 39.25% Saudi Arabia Saudi Arabia

Highway to Health, Inc. Insurance 49.00% USA USA

Max Bupa Health Insurance Company Limited Insurance 49.00% India India

Participations are accounted for using the adjusted equity method and are valued at the Group’s share of the

participation’s assets less liabilities, valued on a Solvency II basis. In the Group’s IFRS financial statements,

associates and joint ventures are accounted for using the equity method however they are initially recognised at

cost and subsequently adjusted for the Group’s share of any post acquisition profits or losses.

Bupa Arabia Highway to Health Max Bupa

2018

£m

2017

£m

2018

£m

2017

£m

2018

£m

2017

£m

Solvency II net asset value 521 438 76 63 27 26

Group’s share 220 154 37 31 13 13

In addition to the interests in participations described above, the Group also has interests in a number of individually

immaterial associates which are recognised in the Solvency II balance sheet at their IFRS carrying value. The

aggregate carrying amount of these associates is £9m (2017: £9m).

The Group’s share of Bupa Arabia, Highway to Health and Max Bupa net assets under Solvency II are £270m

(2017: £198m). The net assets under IFRS are £684m (2017: £543m). The adjustment between IFRS and SII is

higher, principally due to the value of implied goodwill recognised in the IFRS carrying value, which is not recognised

under Solvency II valuation rules and the 5% increase in Bupa’s holding in Bupa Arabia during the year.


D.1.6.3 Financial investments

Solvency II

2018 2017

£m £m

Equities 20 20

Government bonds 229 281

Corporate bonds 1,011 719

Collective investments undertakings 312 439

Derivative assets 30 50

Deposits other than cash equivalents 1,161 1,181

Total investments 2,763 2,690

Reclassification - IFRS to Solvency II

Classification differences exist between Solvency II and IFRS for certain financial investment balances. Investments

(including derivatives) held in segregated funds are reported separately as assets and liabilities for Solvency II

purposes, whereas under IFRS these are reported as a single line within the balance sheet.

Derivatives

Derivative assets and liabilities under Solvency II and IFRS are presented on a net basis if the offsetting criteria are

met as set out in IAS 32 ‘Financial Instruments: Presentation’.

Collective investments undertakings and deposits other than cash equivalents

Cash and cash equivalents are classified differently between IFRS and Solvency II. Under IFRS an investment

normally qualifies as a cash and cash equivalent if it has a short maturity of three months or less from the date of

acquisition. Money market funds and Deposit less than 90 days are classified as cash and cash equivalents under

IFRS; however, they are classified as collective investments undertakings and deposits other than cash equivalents

respectively for Solvency II reporting.

Fair value – IFRS to Solvency II

The Group has adopted IFRS 9: Financial Instruments with a date of initial application of 1 January 2018. In the

IFRS financial statements, the Group has classified its financial investments into the following categories: at

amortised cost, at fair value through profit or loss and at fair value through other comprehensive income (“FVOCI”).

Financial investments classified as fair value through profit and FVOCI are held at fair value. The IFRS fair value

measurement principles are considered to be consistent with Solvency II requirements and therefore no adjustments

are made for Solvency II reporting.

Financial investments classified as at amortised cost in the IFRS financial statements are calculated using the

effective interest method, less impairment losses. In the Solvency II balance sheet the carrying value of these assets

is adjusted to fair value.

At 31 December 2018, £1m was adjusted from amortised cost to obtain the fair value recognised in the Solvency II

balance sheet.

Equities

In the Solvency II balance sheet the fair value of unlisted equities are valued using earnings multiples of comparable

companies.


Government bonds, corporate bonds, collective investment undertakings and deposits other than cash

equivalents

In the Solvency II balance sheet the fair value for Government bonds, corporate bonds, collective investment

undertakings and deposits other than cash equivalents are calculated using quoted prices if available (or if not,

quoted prices of similar assets) or discounted expected future principal and interest cash flows based on observable

data in active markets. The fair values of quoted investments in active markets are based on current bid prices. A

market is considered active when there are listed prices publicly available at which trades can be made without

significant delay and when transactions take place with sufficient frequency and volume to provide pricing

information on an ongoing basis.

Fair values in the Solvency II balance sheet for derivatives are calculated as follows:

• The fair values are obtained from market observable pricing information including interest rate yield curves;

• The fair value of currency forward contracts, swaps and options is determined using forward exchange rates

derived from market sourced data at the balance sheet date, with the resulting value discounted back to present

value;

• The fair value of interest rate swaps is determined as the present value of the estimated future cash flows based

on observable yield curves.

Over 95% of the Group’s financial investments are valued with reference to quoted market prices for the same or similar assets.

D.1.7 Insurance and intermediaries receivables

Under IFRS, receivables are valued at undiscounted amortised cost less any adjustment for impairment losses.

As required in the Solvency II guidance, the portion of insurance and intermediary receivables, recognised as an

asset on the IFRS balance sheet, that are not yet due at the reporting date, are transferred to technical provisions

in the Solvency II balance sheet.

Past due receivables remain within ‘insurance and intermediaries receivables’ in the Solvency II balance sheet.

Given that these receivables are materially due within 12 months, the IFRS valuation policy is considered to be a

close approximation to fair value, and therefore no valuation adjustments are made for Solvency II reporting

purposes.

D.1.8 Receivables (trade, not insurance)

Under IFRS, receivables are valued at undiscounted amortised cost net of provisions for expected credit losses.

Given the short-term maturity of these assets, the IFRS valuation policy is considered to be a close approximation

to fair value and therefore no adjustments are made for Solvency II reporting purposes.

The Group also has service concession receivables of £69m (2017: £232m) in relation to one Public Private

Partnership (“PPP”) with a Spanish regional government. The reduction in the year is due to the impact of the

Torrejon disposal. The receivables relate to fees earned from running one hospital on behalf of the regional

government. The Group has opted to account for the service concession receivables within its IFRS financial

statements as a financial asset valued at amortised cost (with an effective interest rate) less ECL provisions. The

IFRS carrying value is assessed at each reporting period to determine whether it is a materially accurate

approximation of fair value.

As there is no active market for such assets, fair value is determined using discounted cash flows. This involves

taking the sum of the future cash flows due from the Spanish regional governments, with the timing and amount

calculated in accordance with the PPP agreements, and discounting them to present value using an appropriate

weighted average cost of capital. Material assumptions used in this valuation include the timing and amount of cash

flows receivable and the discount rate. These assumptions introduce a level of uncertainty into the valuation.

Based on the assessments made, the IFRS valuation at 31 December 2018 is considered to be a close approximation to fair value and so no adjustments are made for Solvency II valuation purposes.


D.1.9 Cash and cash equivalents

Cash and cash equivalents in the Solvency II balance sheet consist of deposits that can be exchanged for currency

on demand at par value and are valued at their par value. Cash and cash equivalents are classified differently

between IFRS and Solvency II. No valuation differences exist between IFRS and Solvency II. Refer to D.1.6 for

additional information.

D.1.10 Any other assets, not elsewhere shown

These balances include prepayments, inventory, accrued income and other assets. Under IFRS, prepayments are

carried at cost. Given the short-term nature of these assets, this is considered to be a close approximation to the

Solvency II fair value except for prepayments that cannot be transferred to a third-party, which are written down to

£nil.

Inventories include drugs, prostheses, consumables and housing stock. Solvency II requires inventories to be

measured at fair value which equates to the net realisable value, whereas under IFRS inventories are measured at

the lower of cost and net realisable value. In practice the first-in-first out method of stock valuation is applied and

includes the cost of acquiring inventory, as well as bringing it to its current location and physical condition. Based

on materiality and its short-term nature the IFRS value is considered to be a close approximation to fair value.

Under IFRS accrued income and other assets are measured at undiscounted amortised cost less any adjustment

for impairment losses. Given the short-term maturity of these assets, this is considered to be a close approximation

to fair value and therefore no adjustments are made for Solvency II reporting purposes. Materially all other

receivables are due within 12 months.

D.2 Technical provisions

D.2.1 Summary

The technical provisions for Solvency II purposes are an estimate of the cost at which insurance contracts could be

transferred to another knowledgeable insurer in an arm’s length transaction.

2018 2017

Technical provisions

Gross

£m

Re-

insurance

£m

Net

£m

Gross

£m

Re-

insurance

£m

Net

£m

Claims provision – health (similar to non-life) 899 (8) 891 896 (8) 888

Premium provision – health (similar to non-

life) 476 2 478

489 2 491

Risk margin 45 - 45 43 - 43

Technical provisions 1,420 (6) 1,414 1,428 (6) 1,422

The technical provisions are not calculated as a whole but rather are calculated as the sum of the Best Estimate

Liability (“BEL”) and a risk margin. The BEL comprises a claims provision (for claims and expenses incurred prior

to the valuation date) and a premium provision (for claims and expenses expected to be incurred between the

valuation date and the contract boundary). The risk margin is estimated using the Solvency II ‘cost of capital’

approach, which is intended to reflect the total consideration (when included with the BEL) that would be required

by a third-party insurer to take over the full liability.

All of Bupa’s technical provisions have been disclosed under the medical expense line of business. There are

immaterial amounts of life and other non-life insurance written across the Group.

The total gross technical provisions as at 31 December 2018 were £1,420m (2017: £1,428m). The decrease of £8m

is due to a reduction in the gross best estimate premium provision of £13m, offset by an increase in the gross best

estimate claims provision of £3m and an increase in the risk margin of £2m.


The reinsurance arrangements that Bupa has in place are not material; the recoverable from reinsurance contracts

amounted to £6m as at 31 December 2018 (2017: £6m). Bupa has no special purpose vehicles.

The technical provisions calculations do not apply the matching adjustment, volatility adjustment or transitional

measures referred to in Articles 77(b), (d) and 308 (c), (d) of the Solvency II Directive.

D.2.2 Claims provision

The claims provision represents the estimated cost of claims incurred but not settled as at the balance sheet date.

The provision includes an allowance for claims management and claims handling expenses.

The ultimate cost of outstanding claims is estimated using a range of standard actuarial claims projection

techniques, such as the Chain Ladder and Bornhuetter-Ferguson methods. The key assumption for these methods

is that past claims settlement patterns are an appropriate predictor of expected future claims settlement patterns.

These are also adjusted where appropriate using expert judgement.

The methods and data for the claims provision are the same as those used for the outstanding claims provision

(“OCP”) reported in the financial statements under IFRS, with a small difference arising from the exclusion of

prudence margin. Under IFRS, a best estimate is determined on an undiscounted basis and then a margin of

prudence is added. The Solvency II claims provision is also undiscounted. Almost all outstanding claims are settled

within a year, hence the impact of discounting is immaterial.

Bupa’s insurance entities’ OCP processes are subject to annual review by the Group actuarial function against the

Group’s claims reserving standards. The year end 2018 review concluded that the OCP was appropriate and that

the processes met the standards in all material respects.

D.2.3 Premium provision

The premium provision represents the estimated cost of future claims and expenses arising from current insurance

contracts net of future premium receipts. The premium provision is the expected present value of all future cash

flows relating to risk exposure after the valuation date.

Under Solvency II, IFRS balances that relate to future claims exposure are adjusted to the best estimate of future

cash flows. A number of adjustments are applied, the most material being:

• Deferred acquisition costs are not recognised;

• Not yet due insurance and reinsurance receivables and payables are recognised as a future cash flow in

technical provisions rather than as a separate asset in the balance sheet;

• The IFRS unearned premium provision and any unexpired risk provision are adjusted to remove future profits

in excess of deferred acquisition costs.

The cost of future claims and expenses is estimated using actuarial projections of members covered by current

insurance contracts and assumptions for expected claims and expenses incurred per member. These assumptions

are based on current year experience appropriately adjusted for trends, inflation and discounting.

Where relevant, the projection of future cash flows allows for the expected lapse behaviour of members (mid-term

lapses and non-renewal lapses) in the period until the contract boundary.

A pure risk cost assumption is used to project claims expected to be paid. Expected claims are derived for the claim

cost per member for each homogeneous risk group and appropriately adjusted for claims inflation and any expected

changes in the mix of business.

Future claims are expected to increase in line with claims inflation.


The allowance for expenses in the technical provision is on a going concern basis, indirect overhead expenses are allocated on the assumption that the entity continues writing new business and volumes continue at the same level. Expense allowance includes:

• Claims management and handling expenses for future claims;

• Commission;

• Administrative expenses incurred in the servicing of policies;

• Overheads.

New business costs that are incurred before the contract recognition date are excluded, e.g. general marketing,

lead generation and medical underwriting costs.

Claims management expenses are expressed as a percentage of projected paid claims amounts. The percentage

is consistent with the claims provision calculation.

D.2.4 Risk margin

A risk margin is added to the best estimate provisions to allow for the inherent uncertainty of future cash flow

projections. This uncertainty generally relates to the risk that past claims trends may not apply in the future; for

example, as a result of changes in public healthcare provision, economic conditions or claims management

procedures.

The risk margin is estimated using the Solvency II ‘cost of capital’ approach, which is intended to reflect the total

consideration (when included with the BEL) that would be required by a third-party insurer to take over the full

liability. This was estimated by applying a 6% cost-of-capital charge to the sum of the present value of projected

non-hedgeable SCR in each future year until the liabilities have been discharged. The rate of 6% is prescribed in

Solvency II regulations.

D.2.5 Methodology and assumption changes

The Group regularly reviews the methodology and assumptions used in the calculation of technical provisions. The

assumptions to project future claims and expense have been updated to reflect the current year experience together

with expected changes in trends and inflation. Many of these assumptions only have minor impacts on the technical

provisions reported.

We have also revised our application of the methodology to classify (re)insurance and intermediary receivables and

payables, that are not yet due at the reporting date. This has resulted in the transfer of additional (re)insurance and

intermediary receivables and payables, to technical provisions in the Solvency II balance sheet.


D.2.6 Reconciliation to financial statements

The key differences in the valuation of insurance contracts for Solvency II purposes relate to the use of best estimate

assumptions together with a risk margin compared with the use of prudent assumptions under IFRS. In addition,

IFRS insurance receivables are not recognised under Solvency II but are instead transferred to technical provisions

for Solvency II purposes.

Reconciliation to IFRS financial statements

2018

£m

2017

£m

IFRS Technical provisions – net of reinsurance 2,730 2,618

Deferred acquisition costs (139) (117)

Technical provisions for financial statements – net of reinsurance and deferred

acquisition costs

2,591 2,501

Reclassification:

Insurance and reinsurance receivables and payables (not overdue) D.2.3 (896) (841)

Fair value adjustments:

Recognition of IFRS future profit within premium provision D.2.3 (307) (281)

Removal of IFRS prudence margin – claims provision D.2.2 (41) (41)

Risk margin D.2.4 45 43

Refinement in Solvency II claims provision for Ispare Cruz Blanca 9 18

Other valuation adjustments 13 23

Solvency II Technical provisions – net of reinsurance 1,414 1,422

D.2.7 Level of uncertainty

Technical provisions are calculated using actuarial models that include the use of key assumptions, based on

historical and current year experience. Future claims payments, related expenses and lapse rates are subject to

uncertainty, which may lead to actual experience differing from that implied by these assumptions.

The inherent uncertainty of future cash flows is low, which is reflected in the level of risk margin held. This low level

of uncertainty reflects the short-tailed nature of Bupa’s insurance business, and the relatively predictable claims

pattern in its major health insurance portfolios.

D.3 Other liabilities

D.3.1 Contingent liabilities

In the IFRS balance sheet, contingent liabilities are not disclosed. When it is more probable than not that there will

be an out flow of economic benefits, a provision is recognised. Contingent liabilities are recognised in the Solvency

II balance sheet when they are material. They are measured at fair value, using probability weighted cash flow

calculations, discounted where the impact of discounting would be material. At 31 December 2018 the Group did

not have any material contingent liabilities (2017: £nil).

D.3.2 Provisions other than technical provisions

Provisions other than technical provisions are valued in accordance with IAS 37 ‘Provisions, contingent liabilities

and contingent assets’. Under this standard, provisions are valued at the best estimate of the expenditure required

to settle the present obligation at the balance sheet date. There is therefore no difference in value between the

Solvency II and IFRS balance sheets.

These provisions include provisions for long service awards and annual leave, as well as deferred consideration

arising from the acquisition of dental practices in Australia and the UK. Uncertainty with respect to the amount and

timing of cash out flows is dependent on the rate of employee turnover and whether employees take annual leave

within defined periods and, for the deferred consideration provision, dependent on whether or not the acquired

business meets specified earnings targets. Other provisions include provisions for interest and penalties associated

with an in-principle agreement with the Australian Taxation Office see note 26(iii) Contingent assets and contingent

liabilities of the Annual Report and Accounts for further detail.


Of the total provisions of £178m (2017: £132m) recognised in the Solvency II balance sheet, £123m (2017: £82m)

is due within 12 months and £55m (2017: £50m) is due after 12 months.

D.3.3 Pension benefit obligations

Please refer to D.1.4 for information relating to pension benefit obligations. Pension benefit obligations are

recognised and valued as per IAS 19 and therefore there is no difference between IFRS and Solvency II.

D.3.4 Deferred tax liabilities

All valuation differences between the IFRS and Solvency II balance sheets are considered and deferred tax is

calculated, where appropriate, using the tax rate applicable to these differences in accordance with IAS 12. Deferred

tax assets or liabilities are recognised on temporary differences where it is probable that they will reverse in future

periods, and in the case of deferred tax assets these are only recognised to the extent that it is probable that future

taxable profits will be available against which the asset can be utilised. Deferred tax assets and liabilities are offset

where applicable, in accordance with IAS 12, where these relate to the income taxes levied by the same tax

authority.

D.3.5 Derivatives

Derivatives liabilities are measured at fair value under IFRS which is consistent with Solvency II requirements and

therefore no adjustment is made for any changes to the Group’s own credit standing. For further information on

Derivatives see D.1.6.3 investments for further detail.

D.3.6 Debts owed to credit institutions

Debts owed to credit institutions are measured at amortised cost under IFRS. Bupa deems there to be no material

difference between the carrying value of debts owed to credit institutions and the fair value, excluding changes in

value arising from changes in Bupa’s own credit standing, as required under Solvency II. The Group’s credit standing

has minimal or no impact on the valuation of bank loans and overdrafts.

Debts owed to credit institutions predominantly consists of bank loans of £157m (2017: £198m) and balances drawn

under the Group’s revolving credit facility of £170m (2017: £226m). Please refer to Note 17 Borrowings in the Group

31 December 2018 Annual Report and Accounts for detailed information on the valuation as well as key

assumptions.

D.3.7 Financial liabilities other than debts owed to credit institutions

In the IFRS balance sheet financial liabilities are carried at amortised cost but are recognised in the Solvency II

balance sheet at fair value. Their fair value is calculated on a discounted projected cash flows basis using a market

yield adjusted to remove the effects of any change in Bupa’s credit standing. This requires an assumption to be

made with respect to the portion of the coupon payable on each instrument that relates to Bupa’s credit risk and is

derived by comparing the coupon to that of government bonds of similar duration and currency.

Differences between the Solvency II and IFRS values are shown in the following table, as well as the key features

of each of the Group’s financial liabilities.

Solvency II value IFRS value

Instrument

Par

value Maturity Coupon 2018 2017 2018 2017

£m £m £m £m £m

5 April 2017 Senior unsecured

bonds

300 05 April 2024 2% 297 298 294 297

17 June 2014 Senior

unsecured bonds

350 17 June 2021 3.375% 363 371 349 349

30 June 2012 Inflation linked

senior unsecured bonds

50 30 June 2033 4.23% 51 52 51 52

Total 711 721 694 698


Financial liabilities other than debts owed to credit institutions also includes finance leases with a Solvency II value

of £4m (2017: £6m) and non-pooled overdrafts of £2m (2017: £2m).

D.3.8 Insurance and intermediaries payables

Under IFRS, payables are valued at undiscounted amortised cost less any adjustment for impairment losses.

As required in the Solvency II guidance, the portion of insurance and intermediary payables, recognised as a liability

on the IFRS balance sheet, that are not yet due at the reporting date, are transferred to technical provisions in the

Solvency II balance sheet.

Past due payables remain within ‘insurance and intermediaries payables’ in the Solvency II balance sheet. Given

that these payables are materially due within 12 months, the IFRS valuation policy is considered to be a close

approximation to fair value, and therefore no valuation adjustments are made for Solvency II reporting purposes.

D.3.9 Payables (trade, not insurance)

The IFRS trade payables are carried at amortised cost using the effective interest method. Given the short-term

maturity of these liabilities, this is considered to be a close approximation to fair value. Therefore no adjustment is

required from IFRS to Solvency II. Materially all trade payables are due within 12 months.

D.3.10 Subordinated liabilities

Bupa holds two subordinated unguaranteed debt instruments of £500m and £400m. Bupa also holds £330m

subordinated perpetual guaranteed bonds.

In the IFRS balance sheet, subordinated liabilities are valued at amortised cost using the effective interest method.

These are recognised in the Solvency II balance sheet at fair value. Fair value is calculated on a discounted

projected cash flows basis, using a market yield adjusted to remove the effects of any change in the Group’s credit

standing. The valuation requires an assumption to be made with respect to the portion of the coupon payable on

each instrument that relates to Bupa’s credit risk at the time at which the debt was issued and is derived by

comparing the coupon to that of government bonds of similar duration and currency. The level of valuation

uncertainty arising from this method is considered low on the basis that there is an active market for corporate

bonds against which reference can be made. Further details on the capital treatment of these subordinated loans

and bonds are provided in section E.1.

During 2018, the sale of Torrejon Salud S.A. resulted in the disposal of £35m of subordinated debt. This did not

meet the criteria to be recognised as available Own Funds in 2017.

A summary of Bupa’s subordinated liabilities is provided in the following table:

Solvency II value IFRS value

Instrument

Par

value Maturity Coupon 2018 2017 2018 2017

£m £m £m £m £m

Callable subordinated perpetual

guaranteed bonds

330 No fixed maturity1 6.125% 356 370 357 371

Subordinated unguaranteed

bonds

500 25 April 2023 5.0% 514 517 502 501

Subordinated unguaranteed

bonds

400 8 December 2026 5.0% 407 408 396 396

Other subordinated debt

35

31 December 2022

EURIBOR

+6.0%

-

35

-

35

Total 1,277 1,330 1,255 1,303 1. Bupa has the option to redeem on 16 September 2020.


D.3.11 Any other liabilities, not elsewhere shown

Any other liabilities are made up of the following items:

2018 2017

Solvency II balance sheet £m £m

Accruals 634 588

Accommodation bond liabilities 596 617

Other payables 343 361

Deferred income 54 88

Total 1,627 1,654

As noted within D.2.5, methodology changes have occurred in the year relating to the reclassification of insurance

and reinsurance related receivable and payable balances. In line with these changes £29m of deferred insurance

related income has been reclassified to Technical Provisions.

Accommodation bonds are non-interest-bearing deposits paid by some residents of care homes held in Bupa Aged

Care Australia as payment for a place in the care home facility. These deposits are repayable when the resident

leaves the facility. Under IFRS, the bonds are recorded as the proceeds received, net of retention and any other

amounts deducted at the election of the bondholder. Other liabilities are held at amortised cost under IFRS.

Given the short-term nature of these liabilities, this is considered to be a close approximation to fair value. Therefore,

no adjustment is made for Solvency II purposes. All material liabilities recognised in this balance are due within 12

months.

D.3.12 Leasing arrangements

D.3.12.1 Operating leases

The Group has operating lease commitments primarily relating to the rental of care homes, hospital properties,

dental and medical clinics and office buildings occupied by the Group’s health and care provision businesses. The

total value of future non-cancellable operating lease rentals payable as at 31 December 2018 was £1,295m (2017:

£1,206m). Future rental payables are disclosed under commitments in note 26 to the Group’s 2018 financial

statements.

Lease payments are reviewed regularly in accordance with the terms and conditions of the individual lease

agreements and in certain instances there is an option to renew at the end of the lease. None of the leases include

contingent rentals. The Group has paid security deposits of £16m (2017: £12m) in respect of the operating leases.

The Group has only one material individual operating lease arrangement as at 31 December 2018. This relates to

a leased building used in the health and care provision business in the United Kingdom with annual lease payments

amounting to £8m for 2018 and future lease rentals payable of £187m. The lease was incepted on 20 May 2011

and has 366 months duration. The property is not recognised as an asset in the Group’s balance sheet as there

has been no transfer of risks and rewards from the lessor.

Operating leases as lessor

A small number of the leased properties described above have been sub-let by the Group. Both the leased

properties and the sub-leases expire between 2019 and 2024. In addition, the Group leases out some of its

investment properties as a lessor. The total income expected to be received over the next twelve months in respect

of these leasing arrangements is nil (2017: nil).

IFRS 16 (effective 1 January 2019)

IFRS 16 Leases applies to Bupa from 1 January 2019. The change in accounting will bring approximately £1.0bn

of both lease assets and liabilities onto the Group solvency balance sheet. The lease assets attract a property risk

charge under the Solvency II Standard Formula. This, together with interest rate risk on the liability, is estimated to

increase the SCR charge by £0.2bn.


D.3.12.2 Finance leases

Leases are classified as finance leases when the terms of the lease substantially transfer all the risks and rewards

of ownership to the lessee. All other leases are classified as operating leases. Assets obtained under finance leases

are capitalised within property, plant and equipment. As at 31 December 2018, the Group’s financial liabilities under

finance leases amounted to £4m (2017: £7m).

The Group does not have any finance leasing arrangements as lessor.

D.4 Alternative methods for valuation

Alternative methods for valuation are used for certain items of equipment (section D.1.5), property (section D.1.6.1),

receivables (section D.1.8), any other assets, not elsewhere shown (Section D.1.10), financial liabilities (section

D.3.7) and subordinated liabilities (section D.3.10).

D.5 Any other information

The Group has no material off balance sheet liabilities.

At 31 December 2018, £107m (2017: £76m) of the Group’s cash is subject to legal restrictions. This includes cash

deposited to secure a charge over a non-registered pension arrangement and claims funds held on behalf of certain

corporate customers. This cash is recognised in the Group’s Solvency II balance sheet at face value but are netted

off against the corresponding liabilities within the Solvency II balance sheet.

There are no material differences in the valuation bases, methods and assumptions used in the Group Solvency II

balance sheet and those used by its subsidiaries.


E. Capital Management (Audited)

E.1 Own Funds

E.1.1 Summary of Own Funds

Bupa’s Own Funds represent net assets valued on a Solvency II basis, together with eligible subordinated liabilities,

subject to adjustments for non-available assets and non-controlling interests.

2018 2017

Own Funds Section £m £m

Assets D.1 9,402 9,342

Liabilities D.3 (6,284) (6,456)

Excess of assets over liabilities E.1.2 3,118 2,886

Subordinated liabilities E.1.3 1,277 1,295

Non-available capital E.1.4 (465) (440)

Non-available minority interests at group level E.1.4 (14) (14)

Eligible Own Funds E.1.3 3,916 3,727

Information on the valuation of assets and liabilities is provided in Section D: Valuation for solvency purposes. The

balance sheet is prepared using the accounting consolidation method, set out as ‘method 1’ in the Solvency II

Directive. The consolidation process eliminates all intra group transactions.

The subordinated liabilities, consisting of subordinated perpetual guaranteed bonds and 5% subordinated

unguaranteed bonds issued by Bupa Finance Plc, are accounted for as liabilities in the financial statements but are

treated as solvency capital for regulatory purposes. The perpetual guaranteed bonds were classified as upper Tier

2 under the Solvency I regime and by virtue of the transitional provisions qualify as Tier 1 capital under Solvency II

for ten years from 1 January 2016. Further information on the subordinated liabilities is provided in Section E.1.3.

The 5% subordinated guaranteed bonds qualify as Tier 2 capital for Solvency II purposes because they satisfy the

eligibility criteria for Own Funds set out in the Solvency II regulations, including a deferral of both coupons and

redemptions in the event of a breach of capital requirements.

E.1.2 Comparison with IFRS equity

Reconciliation of IFRS equity to Solvency II excess of assets

over liabilities Section

2018

£m

2017

£m

Total equity in IFRS financial statements 7,510 7,288

Valuation differences:

Assets D.1 (4,853) (4,750)

Technical provisions D.2 281 238

Other liabilities D.3 180 110

Solvency II excess of assets over liabilities 3,118 2,886

The valuation differences at 31 December 2018 are as follows:

• Assets: goodwill and intangible assets are valued at £nil in the Solvency II balance sheet, resulting in a £4,262m

valuation difference (See Sections D.1.1 and D.1.3). In addition, there is a £411m valuation difference arising

on the Group’s participations offset by valuation difference of £1m relating to financial investments (See D.1.6.2)

giving rise to a total valuation adjustment to investments of £410m. A further £117m difference is driven by the

valuation of equipment (see D.1.5) and other adjustments of £64m predominantly relate to prepayment

valuation differences.


• Technical provisions: under IFRS technical provisions include an Outstanding Claims Provision, an unearned

premium provision and, if required, an unexpired risk provision. Solvency II technical provisions are made up of

future best estimate cash flows (claim payments, expenses and future premiums) in relation to the insurance

and/or reinsurance obligations. Solvency II technical provisions also consist of a risk margin which is the balance

over and above the BEL that another insurer would require, to assume the liabilities as at the valuation date.

The net impact of applying the different bases is £281m.

• Other liabilities: the majority of this balance relates to deferred tax which is calculated on the temporary

differences between tax base values and IFRS balances. Adjustments from IFRS to Solvency II give rise to a

£219m decrease in deferred tax liabilities. Under IFRS the Group holds financial and subordinated liabilities at

amortised cost on an effective interest basis. This is adjusted to fair value under Solvency II excluding changes

in Bupa’s credit risk, giving rise to a £39m increase in liabilities.

E.1.3 Capital structure

Capital structure

Notes

2018

£m

2017

£m

Unrestricted Tier 1 E.1.3.1 2,587 2,426

Restricted Tier 1 - subordinated perpetual bonds E.1.3.2 356 370

Tier 2 - subordinated unguaranteed bonds E.1.3.3 921 925

Tier 3 – deferred tax asset E.1.3.4 52 6

Eligible Own Funds 3,916 3,727

The value of the subordinated debt is within the tiering limits contained in the Solvency II regulations. Therefore, the

tiering restrictions have no impact on eligible Own Funds available to meet the Group SCR and all available Own

Funds are eligible to cover the Group SCR. Eligible Own Funds to meet the Minimum Consolidated Group SCR are

subject to a restriction in that the eligible amount of Tier 2 capital shall not exceed 20% of the Minimum Consolidated

Group SCR. Eligible Own Funds to meet the Minimum Consolidated Group SCR as at 31 December 2018 are

£3,052m, comprising £2,587m unrestricted Tier 1, £356m restricted Tier 1 and £109m Tier 2.

Eligible Own Funds have increased in the year to £3,916m (2017: £3,727m) due to strong ongoing generation from

operating activities offset by M&A activity.

Solvency II distinguishes between basic Own Funds and ancillary Own Funds. Bupa’s eligible Own Funds are all

basic Own Funds.

E.1.3.1 Unrestricted Tier 1

The unrestricted Tier 1 capital of £2,587m (2017: £2,426m) represents the reconciliation reserve of £3,118m (2017:

£2,886m), being the excess of assets over liabilities, less deferred tax asset of £52m recognised in Tier 3 capital

and non-available assets of £465m (£2017: £440m). It also includes non-controlling interests’ share of assets of

£14m (2017: £14m).

E.1.3.2 Restricted Tier 1 - subordinated perpetual bonds

In December 2004, Bupa Finance Plc issued £330m of callable subordinated perpetual guaranteed bonds, which

are guaranteed by Bupa Insurance Limited. Interest is payable on the bonds at 6.125% pa. The bonds have no

fixed maturity date but a call option is exercisable by Bupa Finance Plc to redeem the bonds on 16 September

2020. The Solvency II value at 31 December 2018 was £356m (2017: £370m).

These bonds, classified as upper Tier 2 under the Solvency I regime, qualify under the transitional provisions as

Tier 1 capital under Solvency II for ten years from 1 January 2016


E.1.3.3 Tier 2 - 5% subordinated unguaranteed bonds

During April 2013, Bupa Finance Plc issued £500m of unguaranteed subordinated bonds which mature on 25 April

2023. Interest is payable on the bonds at 5.0% per annum. The Solvency II value at 31 December 2018 was £514m

(2017: £517m).

In December 2016, Bupa Finance Plc issued £400m unguaranteed subordinated bonds which mature on 8

December 2026. Interest is payable on the bonds at 5.0% per annum. The Solvency II value at 31 December 2018

was £407m (2017: £408m).

E.1.3.4 Tier 3 – deferred tax asset

The Tier 3 assets represent the net deferred tax asset recognised within the Solvency II balance sheet. At 31

December 2018, the deferred tax asset was £52m (2017: £6m). Please refer to Note 11 Deferred taxation assets

and liabilities in brief in the Group 31 December 2018 Annual Report and Accounts for detail on the increase in

deferred tax assets.

E.1.4 Exclusion of non-available funds from Group Own Funds

For the purpose of the Solvency II Group solvency calculation, the following items are excluded from Group Own

Funds on the basis that they cannot effectively be made available to cover the Group SCR.

Non-available Own Funds

2018

£m

2017

£m

Pension surplus in excess of pension risk element of Group SCR 465 440

Minority interests’ share of Own Funds 14 14

Total non-available Own Funds 479 454

The excess of the UK pension scheme surplus over the pension scheme element of the group SCR is deducted

from Group Own Funds as it is not transferable.

E.1.5 Capital management policy and processes

The Group’s capital resources are managed in line with the Group Capital Management Policy. While the Group is

subject to the Solvency II requirements at a consolidated level, all regulated entities within the Group maintain

sufficient capital resources to meet any minimum capital requirement required by respective local regulators. In

addition, the Group and individual regulated entities maintain a buffer over the regulatory minimum requirements in

line with their capital risk appetites. During the year, the Group and its subsidiaries complied with all externally

imposed capital requirements to which they were subject. The capital position of the Group and its main regulated

insurance entities are kept under constant review and are reported quarterly to the Board.

The Group has target ranges for solvency, leverage and interest cover ratios with a view to maintaining an A-/A3

long-term senior credit rating for Bupa Finance plc. The Bupa Group as a whole is not rated by any rating agency.

Individual debt issues and certain subsidiaries within the Group have public ratings.

At least annually, the Group carries out an ECA in which it makes its own quantification of how much capital is

required to support its risks. The ECA is used to assess how well the Standard Formula SCR reflects the Group’s

actual risk profile.

The ECA forms part of the Own Risk and Solvency Assessment ORSA which comprises all the activities by which

the Group establishes the level of capital required to meet its solvency needs over the planning period given the

Group’s strategy and risk appetite. The conclusions from these activities are summarised in the ORSA report which

is reviewed by the Risk Committee, approved by the Board and submitted to the PRA at least annually.

Other than disclosed above there have been no changes to what is managed as capital or to the Group’s capital

management objectives, policies or procedures during the year.


E.2 Solvency Capital Requirement and Minimum Capital Requirement

The table below shows the breakdown of the SCR by the standard formula risk modules:

SCR by risk module

2018

£m

2017(1)

£m

Market risk excluding pension risk 1,198 1,222

Insurance risk 610 622

Credit risk 152 217

Pension scheme - market risk 149 150

Basic SCR before diversification 2,109 2,211

Diversification (446) (491)

Basic SCR after diversification 1,663 1,720

Operational risk 264 268

Loss absorbency of deferred tax (72) (82)

Total SCR diversified 1,855 1,906

SCR for participations 195 165

Group consolidated SCR 2,050 2,071 1. The impact of diversification within the market risk module, between pension and non-pension market risk, is now

included in the Basic SCR before diversification.

The calculation of the Group SCR has been carried out on the basis of consolidated data. The SCR for participations

of £195m (2017: £165m) represents the SCR for equity-accounted entities.

The Group SCR has been calculated using the standard formula specified in the Solvency II legislation, modified

by a GSP for premium risk SCR. Bupa has obtained approval from the PRA to substitute the insurance premium

risk parameter in the standard formula with a GSP, which reflects Bupa’s own loss experience.

The PRA does not require the impact of a Group Specific Parameter to be disclosed during a transitional period,

which includes the year ended 31 December 2018.

Bupa does not use simplification calculations, as allowed for under the Solvency II Directives, in determining the

standard formula SCR.

The main source of diversification benefit relates to the low correlations between insurance risks and market risks. The Solvency II SCR is held to protect against an instantaneous 1-in-200 years loss. In the same way that a large

profit typically creates a tax liability, a large loss could potentially create a tax asset. In the context of Solvency II,

this is called a notional deferred tax asset, which can be used to reduce the SCR. The reduction in the SCR arising

from the recognition of this notional deferred tax asset is referred to as loss absorbency of deferred tax. At present,

the Group allows for the deferred tax liabilities and the amount of paid taxes that can be recovered from carrying

back losses, according to the respective local tax regimes. However, no allowance is made for the notional amount

of deferred tax assets that can be carried forward to offset taxes on anticipated future profits.

Since 31 December 2017 the Group’s SCR has remained stable at £2,050m (2017: £2,071m).

Minimum consolidated group SCR

The Minimum Consolidated Group SCR is the absolute floor of the capital requirement for the Group, which must

be covered by the Group eligible Own Funds. As at 31 December 2018, this amount was £545m (2017: £525m).

The Minimum Consolidated Group SCR is based on:

• The minimum capital requirements of the Group’s EEA authorised insurance undertakings;

• The local capital requirements, at which level authorisation would be withdrawn, for the Group’s insurance

undertakings outside the EEA.


In the case of non-EEA requirements, the local requirement has been taken to be the amount of Own Funds, valued

on a Solvency II basis, which would be sufficient to meet the local requirement.

For non-EEA participations, the proportional consolidated method has been used in determining the Minimum

Consolidated Group SCR for the Group.

The Minimum Consolidated Group SCR of £545m as at 31 December 2018 (2017: £525m) comprised £501m (2017:

£481m) relating to the group’s insurance subsidiaries and £44m (2017: £44m) relating to participations.

E.3 Use of the duration-based equity risk sub-module in the calculation of the SCR

Bupa does not use the duration-based equity risk sub-module.

E.4 Differences between the standard formula and any internal model used

This section is not applicable to Bupa. The Group SCR has been calculated using the standard formula specified in the Solvency II legislation, modified by a GSP for determining premium risk SCR.

E.5 Non-compliance with the Minimum Capital Requirement and Solvency Capital

Requirement

The Group maintained sufficient capital to exceed both the SCR and the Minimum Consolidated Group SCR

throughout the reporting period.

E.6 Any other information

IFRS 16 Leases applies to Bupa from 1 January 2019. The change in accounting will bring approximately £1.0bn

of both lease assets and liabilities onto the Company’s Solvency II balance sheet. The associated property and

interest rate risk charges will impact the Company’s Solvency II coverage by 16 percentage points.

On 18 January 2019, we completed the acquisition of Bupa Acıbadem Sigorta. This transaction is estimated to

reduce our coverage ratio by 6 percentage points. After the inclusion of lease assets and liabilities and this

acquisition, our solvency coverage ratio is estimated to be 169%.



Directors’ responsibility statement

We acknowledge our responsibility for preparing the SFCR in all material respects in accordance with the PRA Rules and the Solvency II Regulations. We are satisfied that: a) throughout the financial year in question, the Group has complied in all material respects with the requirements of the PRA Rules and the Solvency II Regulations applicable to the Group; and b) it is reasonable to believe that the Group has continued to so comply subsequently and will continue to so comply in future. Joy Linton Chief Financial Officer 7 May 2019


Audit Opinion

Report of the external independent auditor to the Directors of The British United Provident Association

Limited (‘the Company’) pursuant to Rule 4.1 (2) of the External Audit Part of the PRA Rulebook applicable

to Solvency II firms

Report on the Audit of the Relevant Elements of the Group Solvency and Financial Condition Report

Opinion

Except as stated below, we have audited the following documents prepared by The British United Provident

Association Limited as at 31 December 2018:

• The ‘Valuation for solvency purposes’ and ‘Capital Management’ sections of the Group Solvency and

Financial Condition Report of The British United Provident Association Limited as at 31 December 2018,

(‘the Narrative Disclosures subject to audit’); and

• Group templates S02.01.02, S23.01.22, S25.01.22, S32.01.22 (‘the Templates subject to audit’).

The Narrative Disclosures subject to audit and the Templates subject to audit are collectively referred to as the

‘Relevant Elements of the Group Solvency and Financial Condition Report’.

We are not required to audit, nor have we audited, and as a consequence do not express an opinion on the Other

Information which comprises:

• The ‘Business and performance’, ‘System of governance’ and ‘Risk profile’ sections of the Group Solvency

and Financial Condition Report;

• Group templates S05.01.02, S05.02.01;

• The written acknowledgement by the Directors of their responsibilities, including for the preparation of the

Group Solvency and Financial Condition Report (‘the Responsibility Statement’);

• Information which pertains to an undertaking that is not a Solvency II undertaking and has been prepared

in accordance with PRA rules other than those implementing the Solvency II Directive or in accordance

with an EU instrument other than the Solvency II regulations. (‘the sectoral information’).

To the extent the information subject to audit in the relevant elements of the Group Solvency and Financial Condition

Report includes amounts that are totals, sub-totals or calculations derived from the Other Information, we have

relied without verification on the Other Information.

In our opinion, the information subject to audit in the Relevant Elements of the Group Solvency and Financial

Condition Report of The British United Provident Association Limited as at 31 December 2018 is prepared, in all

material respects, in accordance with the financial reporting provisions of the PRA Rules and Solvency II regulations

on which they are based, as modified by relevant supervisory modifications, and as supplemented by supervisory

approvals and determinations.

Basis for opinion

We conducted our audit in accordance with International Standards on Auditing (UK) (ISAs (UK)) including ISA (UK)

800 and ISA (UK) 805, and applicable law. Our responsibilities under those standards are further described in the

Auditor’s Responsibilities for the Audit of the Relevant Elements of the Group Solvency and Financial Condition

Report section of our report. We are independent of The British United Provident Association Limited in accordance

with the ethical requirements that are relevant to our audit of the Group Solvency and Financial Condition Report in

the UK, including the FRC’s Ethical Standard as applied to public interest entities, and we have fulfilled our other

ethical responsibilities in accordance with these requirements. We believe that the audit evidence we have obtained

is sufficient and appropriate to provide a basis for our opinion.


Emphasis of Matter – special purpose basis of accounting

We draw attention to the ‘Valuation for solvency purposes’ and ‘Capital Management’ sections of the Group

Solvency and Financial Condition Report, which describe the basis of accounting. The Group Solvency and

Financial Condition Report is prepared in compliance with the financial reporting provisions of the PRA Rules and

Solvency II regulations, and therefore in accordance with a special purpose financial reporting framework. The

Group Solvency and Financial Condition Report is required to be published, and intended users include but are not

limited to the Prudential Regulation Authority. As a result, the Group Solvency and Financial Condition Report may

not be suitable for another purpose. Our opinion is not modified in respect of this matter.

Conclusions relating to going concern

We have nothing to report in respect of the following matters in relation to which the ISAs (UK) require us to report

to you if:

• The Directors’ use of the going concern basis of accounting in the preparation of the Group Solvency and

Financial Condition Report is not appropriate; or

• The Directors have not disclosed in the Group Solvency and Financial Condition Report any identified

material uncertainties that may cast significant doubt about the Company’s ability to continue to adopt the

going concern basis of accounting for a period of at least twelve months from the date when the Group

Solvency and Financial Condition Report is authorised for issue.

Other Information

The Directors are responsible for the Other Information.

Our opinion on the Relevant Elements of the Group Solvency and Financial Condition Report does not cover the

Other Information and, accordingly, we do not express an audit opinion or any form of assurance conclusion thereon.

In connection with our audit of the Group Solvency and Financial Condition Report, our responsibility is to read the

Other Information and, in doing so, consider whether the Other Information is materially inconsistent with the

Relevant Elements of the Group Solvency and Financial Condition Report, or our knowledge obtained in the audit,

or otherwise appears to be materially misstated. If we identify such material inconsistencies or apparent material

misstatements, we are required to determine whether there is a material misstatement in the Relevant Elements of

the Group Solvency and Financial Condition Report or a material misstatement of the Other Information. If, based

on the work we have performed, 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 Directors for the Group Solvency and Financial Condition Report

The Directors are responsible for the preparation of the Group Solvency and Financial Condition Report in

accordance with the financial reporting provisions of the PRA rules and Solvency II regulations which have been

modified by the modifications, and supplemented by the approvals and determinations made by the PRA under

section 138A of FSMA, the PRA Rules and Solvency II regulations on which they are based.

The Directors are also responsible for such internal control as they determine is necessary to enable the preparation

of a Group Solvency and Financial Condition Report that is free from material misstatement, whether due to fraud

or error; assessing the Company’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 they either intend to liquidate the

Company or to cease operations, or have no realistic alternative but to do so.

Auditor’s Responsibilities for the Audit of the Relevant Elements of the Group Solvency and Financial

Condition Report

It is our responsibility to form an independent opinion as to whether the Relevant Elements of the Group Solvency

and Financial Condition Report are prepared, in all material respects, with financial reporting provisions of the PRA

Rules and Solvency II regulations on which it they based, as modified by relevant supervisory modifications, and as

supplemented by supervisory approvals and determinations.


Our objectives are to obtain reasonable assurance about whether the Relevant Elements of the Group Solvency

and Financial Condition Report 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 it is not a

guarantee that an audit conducted in accordance with ISAs (UK) 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 decision making or the judgement of the users taken on the

basis of the Relevant Elements of the Group Solvency and Financial Condition Report.

A further description of our responsibilities for the audit of the financial statements is located on the Financial

Reporting Council’s website at: www.frc.org.uk/auditorsresponsibilities.

Report on Other Legal and Regulatory Requirements.

Sectoral Information

In our opinion, in accordance with Rule 4.2 of the External Audit Part of the PRA Rulebook for Solvency II firms, the

sectoral information has been properly compiled in accordance with the PRA rules and EU instruments relating to

that undertaking from information provided by members of the group and the relevant insurance group undertaking.

Other Information

In accordance with Rule 4.1 (3) of the External Audit Part of the PRA Rulebook for Solvency II firms we are also

required to consider whether the Other Information is materially inconsistent with our knowledge obtained in the

audit of The British United Provident Association Limited’s statutory financial statements. If, based on the work we

have performed, 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.

The purpose of our audit work and to whom we owe our responsibilities

This report of the external auditor is made solely to the Company’s directors, as its governing body, in accordance

with the requirement in Rule 4.1 (2) of the External Audit Part of the PRA Rulebook for Solvency II firms and the

terms of our engagement. We acknowledge that the directors are required to submit the report to the PRA, to

enable the PRA to verify that an auditor’s report has been commissioned by the Company’s directors and issued in

accordance with the requirement set out in Rule 4.1 (2) of the External Audit Part of the PRA Rulebook for Solvency

II firms and to facilitate the discharge by the PRA of its regulatory functions in respect of the Company, conferred

on the PRA by or under the Financial Services and Markets Act 2000.

Our audit has been undertaken so that we might state to the Company’s directors those matters we are required to

state to them in an auditor’s report issued pursuant to Rule 4.1 (2) 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 through its governing

body, for our audit, for this report, or for the opinions we have formed.

Philip Smart, for and on behalf of KPMG LLP

Statutory Auditor

15 Canada Square

London E14 5GL

7 May 2019

http://www.frc.org.uk/auditorsresponsibilities


Annex – Reporting Templates

The following QRTs are included within this Annex:

S.02.01.02 Balance sheet

S.05.01.02 Premiums, claims and expenses by line of business

S.05.02.01 Premiums, claims and expenses by country

S.23.01.22 Own Funds

S.25.01.22 Solvency Capital Requirement – for undertakings on standard formula

S.32.01.22 Undertakings in the scope of the group

Values disclosed within the above QRTs are stated in £000’s

S.02.01.02 - Balance Sheet

Assets

Intangible assets R0030

Deferred tax assets R0040 51,705

Pension benefit surplus R0050 602,173

Property, plant & equipment held for own use R0060 605,063

Investments (other than assets held for index-linked and unit-linked contracts)

R0070 5,981,052

Property (other than for own use) R0080

2,938,870

Holdings in related undertakings, including participations R0090 278,747

Equities R0100 20,493 Equities - listed R0110

Equities - unlisted R0120 20,493

Bonds R0130 1,239,841 Government Bonds R0140 228,835

Corporate Bonds R0150 1,011,006

Structured notes R0160

Collateralised securities R0170

Collective Investments Undertakings R0180 311,604

Derivatives R0190 30,054

Deposits other than cash equivalents R0200 1,161,445

Other investments R0210

Assets held for index-linked and unit-linked contracts R0220

Loans and mortgages R0230 82,802

Loans on policies R0240 568

Loans and mortgages to individuals R0250

Other loans and mortgages R0260 82,234

Reinsurance recoverables from: R0270 5,652

Non-life and health similar to non-life R0280 5,652

Non-life excluding health R0290

Health similar to non-life R0300 5,652

unit-linked R0310

Health similar to life R0320

Life excluding health and index-linked and unit-linked R0330

Life index-linked and unit-linked R0340

Deposits to cedants R0350

Insurance and intermediaries receivables R0360 184,027

Reinsurance receivables R0370 3,948

Receivables (trade, not insurance) R0380 347,931

Own shares (held directly) R0390

not yet paid in R0400

Cash and cash equivalents R0410 1,257,059

Any other assets, not elsewhere shown R0420 279,817

Total assets R0500 9,401,229

S.02.01.02 - Balance Sheet

Liabilities

Technical provisions - non-life R0510 1,420,063

Technical provisions - non-life (excluding health) R0520

TP calculated as a whole R0530

Best estimate R0540

Risk margin R0550

Technical provisions - health (similar to non-life) R0560 1,420,063


Best estimate R0580 1,375,533

Risk margin R0590 44,530

TP - life (excluding index-linked and unit-linked) R0600

Technical provisions - health (similar to life) R0610


Best estimate R0630

Risk margin R0640

TP - life (excluding health and index-linked and unit-linked) R0650


Best estimate R0670

Risk margin R0680

TP - index-linked and unit-linked R0690


Best estimate R0710

Risk margin R0720

Contingent liabilities R0740

Provisions other than technical provisions R0750 178,112

Pension benefit obligations R0760 61,687

Deposits from reinsurers R0770 5,536

Deferred tax liabilities R0780 135,692

Derivatives R0790 52,362

Debts owed to credit institutions R0800 356,117

Financial liabilities other than debts owed to credit institutions R0810 716,557

Insurance & intermediaries payables R0820 60,506

Reinsurance payables R0830 3,812

Payables (trade, not insurance) R0840 388,368

Subordinated liabilities R0850 1,277,487

Subordinated liabilities not in BOF R0860 0

Subordinated liabilities in BOF R0870 1,277,487

Any other liabilities, not elsewhere shown R0880 1,627,228

Total liabilities R0900 6,283,528

Excess of assets over liabilities R1000 3,117,701

S.05.01.02 - Premiums, claims and expenses by line of business

Medical expense insurance Total

C0010 C0200

Premiums written

Gross - Direct Business R0110 8,691,446 8,691,446

Gross - Proportional reinsurance accepted R0120 221,526 221,526

Gross - Non-proportional reinsurance accepted R0130

0

Reinsurers' share R0140 65,853 65,853

Net R0200 8,847,119 8,847,119

Premiums earned




0


Net R0300 8,728,253 8,728,253

Claims incurred




0


Net R0400 6,697,594 6,697,594

Changes in other technical provisions

Gross - Direct Business R0410 0

Gross - Proportional reinsurance accepted R0420 0


0

Reinsurers' share R0440 0

Net R0500 0

Expenses incurred R0550 1,376,701 1,376,701

Other expenses R1200

Total expenses R1300 1,376,701

S.05.02.01 - Premiums, claims and expenses by country

Home Country Top 5 countries (by amount of gross premiums written) - non-life obligations Total Top 5 and home

country

C0010 C0020 C0030 C0040 C0050 C0060 C0070 R0010 AU ES CL HK BR

C0080 C0090 C0100 C0110 C0120 C0130 C0140

Premium written

Gross - Direct Business R0110 1,617,056 3,874,224 1,189,783 722,840 329,853 197,165 7,930,921

Gross - Proportional reinsurance accepted R0120 0 2,698 5,377 0 0 8,075

Gross - Non-proportional reinsurance accepted R0130 0

Reinsurers' share R0140 25,182 123 8,601 360 2,380 77 36,722

Net R0200 1,591,874 3,876,799 1,186,560 722,480 327,472 197,089 7,902,274

Premium earned

Gross - Direct Business R0210 1,617,542 3,831,678 1,170,438 723,151 303,685 196,725 7,843,219

Gross - Proportional reinsurance accepted R0220 0 3,030 5,377 0 0 8,407



Net R0300 1,592,191 3,834,602 1,167,219 722,767 301,838 196,660 7,815,278

Claims incurred

Gross - Direct Business R0310 1,130,894 3,220,570 806,778 633,376 220,780 134,068 6,146,467

Gross - Proportional reinsurance accepted R0320 0 1,790 5,199 6,989



Net R0400 1,108,718 3,222,288 810,936 633,026 217,370 133,847 6,126,185

Changes in other technical provisions

Gross - Direct Business R0410 0

Gross - Proportional reinsurance accepted R0420 0


Reinsurers' share R0440 0

Net R0500 0

Expenses incurred R0550 311,132 320,121 209,173 87,280 57,853 49,029 1,034,587

Other expenses R1200

Total expenses R1300 1,034,587

S.23.01.22 - Own Funds Group

Total

Tier 1 - unrestricted

Tier 1 - restricted

Tier 2

Tier 3

C0010 C0020 C0030 C0040 C0050

Basic own funds before deduction for participations in other financial sector

Ordinary share capital (gross of own shares) R0010

Non-available called but not paid in ordinary share capital at group level R0020

Share premium account related to ordinary share capital R0030

undertakings R0040

Subordinated mutual member accounts R0050

Non-available subordinated mutual member accounts at group level R0060

Surplus funds R0070

Non-available surplus funds at group level R0080

Preference shares R0090

Non-available preference shares at group level R0100

Share premium account related to preference shares R0110

Non-available share premium account related to preference shares at group level R0120

Reconciliation reserve R0130 2,601,316 2,601,316

Subordinated liabilities R0140 1,277,487 355,778 921,709

Non-available subordinated liabilities at group level R0150

An amount equal to the value of net deferred tax assets R0160 51,705 51,705

The amount equal to the value of net deferred tax assets not available at the group level R0170

Other items approved by supervisory authority as basic own funds not specified above R0180

Non available own funds related to other own funds items approved by supervisory authority R0190

Minority interests (if not reported as part of a specific own fund item) R0200

Non-available minority interests at group level R0210 14,072 14,072

Own funds from the financial statements that shall not be represented by the reconciliation reserve and

do not meet the criteria to be classified as Solvency II own funds

Own funds from the financial statements that shall not be represented by the reconciliation reserve and do not meet

the criteria to be classified as Solvency II own funds

R0220

Deductions

Deductions for participations in other financial undertakings, including non-regulated undertakings carrying out

financial activities

R0230

whereof deducted according to art 228 of the Directive 2009/138/EC R0240

Deductions for participations where there is non-availability of information (Article 229) R0250

Deduction for participations included by using D&A when a combination of methods is used R0260

Total of non-available own fund items R0270 14,072 14,072

Total deductions R0280 14,072 14,072

Total basic own funds after deductions R0290 3,916,436 2,587,245 355,778 921,709 51,705

Ancillary own funds

Unpaid and uncalled ordinary share capital callable on demand R0300

mutual - type undertakings, callable on demand R0310

Unpaid and uncalled preference shares callable on demand R0320

A legally binding commitment to subscribe and pay for subordinated liabilities on demand R0330

Letters of credit and guarantees under Article 96(2) of the Directive 2009/138/EC R0340

Letters of credit and guarantees other than under Article 96(2) of the Directive 2009/138/EC R0350

Supplementary members calls under first subparagraph of Article 96(3) of the Directive 2009/138/EC

R0360

Supplementary members calls - other than under first subparagraph of Article 96(3) of the Directive 2009/138/EC

R0370

Non available ancillary own funds at group level R0380

Other ancillary own funds R0390

Total ancillary own funds R0400

Own funds of other financial sectors

Credit institutions, investment firms, financial institutions, alternative investment fund managers, financial institutions

- Total

R0410

Institutions for occupational retirement provision R0420

Non regulated entities carrying out financial activities R0430

Total own funds of other financial sectors R0440

Own funds when using the D&A, exclusively or in combination of method 1

Own funds aggregated when using the D&A and combination of method R0450

Own funds aggregated when using the D&A and a combination of method net of IGT R0460

Total available own funds to meet the consolidated group SCR (excluding own funds from other financial

sector and from the undertakings included via D&A ) R0520

3,916,436

2,587,245

355,778

921,709

51,705

Total available own funds to meet the minimum consolidated group SCR R0530 3,864,731 2,587,245 355,778 921,709 Total eligible own funds to meet the consolidated group SCR (excluding own funds from other financial

sector and from the undertakings included via D&A ) R0560

3,916,436

2,587,245

355,778

921,709

51,705

Total eligible own funds to meet the minimum consolidated group SCR R0570 3,051,928 2,587,245 355,778 108,905

Minimum consolidated Group SCR R0610 544,527

Ratio of Eligible own funds to Minimum Consolidated Group SCR R0650 560%

Total eligible own funds to meet the group SCR (including own funds from other financial sector and from the undertakings included via D&A ) R0660 3,916,436 2,587,245 355,778 921,709

Group SCR R0680 2,050,432

Ratio of Eligible own funds to group SCR including other financial sectors and the undertakings included via D&A R0690 191%

C0060

Reconciliation reserve

Excess of assets over liabilities R0700 3,117,701

Own shares (included as assets on the balance sheet) R0710

Foreseeable dividends, distributions and charges R0720

Other basic own fund items R0730 51,705

Adjustment for restricted own fund items in respect of matching adjustment portfolios and ring fenced funds R0740

Other non available own funds R0750 464,680

Reconciliation reserve before deduction for participations in other financial sector

R0760

2,601,316

Expected profits

Expected profits included in future premiums (EPIFP) - Life Business R0770

Expected profits included in future premiums (EPIFP) - Non- life business R0780 322,185

Total EPIFP R0790 322,185

S.32.01.22 - Undertakings in the scope of the group

Country

Identification code of the undertaking

Type of code of the ID of the

undertaking

Legal Name of the undertaking

Type of undertaking

Legal form

Category (mutual/non mutual)

Supervisory Authority

% capital share

% used for the

establishment of

consolidated accounts

% voting rights

Other criteria

Level of influence

Proportional share used

for group solvency

calculation

Yes/No

Date of decision if art. 214 is

applied

Method used and under method 1, treatment of the

undertaking

C0010 C0020 C0030 C0040 C0050 C0060 C0070 C0080 C0180 C0190 C0200 C0210 C0220 C0230 C0240 C0250 C0260

GB

549300T5K5C5DBHXMC67GB10131

2 - Specific code

Bupa Secretaries Limited

10 - Ancillary services undertaking as defined in Article 1 (53) of Delegated Regulation (EU) 2015/35

Company limited by shares or by

guarantee or unlimited

2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%

1 - Included in the scope

1 - Method 1: Full consolidation

GB


2 - Specific code

Bupa Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Healthcare Services Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



US

549300T5K5C5DBHXMC67US10237

2 - Specific code

Highway to Health, Inc

5 - Insurance holding company as defined in Article 212(1) (f) of Directive 2009/138/EC



2 - Non-mutual

49.00%

49.00%

49.00%

2 - Significant

49.00%


3 - Method 1: Adjusted equity method

GB


2 - Specific code

Healthbox Europe 1 LP


Limited Partnership

2 - Non-mutual

37.04%

37.04%

0.00%

2 - Significant

37.04%



GB


2 - Specific code

Bridge Health Investments Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



IE

5493006072O6UJMFL807

1 - LEI

Bupa Global Designated Activity Company

2 - Non life insurance undertaking



2 - Non-mutual

Central Bank of Ireland

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

A4 Health Group Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Apex Holding Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Avsan Cove Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Avsan Dental Edinburgh Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Avsan Ferryburn Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Avsan Fleet Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Avsan Gloucester Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Avsan Halstead Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Avsan Holdings Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Avsan Knebworth Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Avsan Kseat Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Avsan Queenscross Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Avsan Queensroad Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Avsan Visage Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

BASDAC (2011) LLP


Limited Liability Partnership

2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

BE White Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Ceracryl Laboratories Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Clive Zane Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Colchester Dental Referral Centre Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Cranmore Excellence in Dentistry Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Croft Dental Care Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

DE (Belmont Road) Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Den Dental Group Practice LLP



2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Dentalign Colwyn Bay Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Dentalign Eastbourne Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Dentalign Orthodontics Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Dentalign Orthodontics LLP



2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Dentalign Wrexham Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Derwent House Orthodontics Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Devon Smiles Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Dr J.D. Hull & Associates (Physiotherapy & Osteopathy) Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Duke Street Capital Oasis Acquisitions Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Duke Street Capital Oasis Midco Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Duke Street Capital Oasis Orthodontics Holdings Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Duke Street Capital Oasis Orthodontics Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Eurodontic Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

G & M Moynes Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Goodteeth Dental Surgeries Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Harbour Way Surgery Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



Country



undertaking


Type of undertaking

Legal form

Category (mutual/non

mutual)


% capital share

% used for the

establishment of


% voting rights

Other criteria

Level of influence

Proportional share

used for group

solvency calculation

Yes/No


applied

Method used and under method 1, treatment of

the undertaking


GB


2 - Specific code

Highland Dental Care Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Hillington Park Dental Practice Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

J & M Dental Care Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

J A Jordan & Associates Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

James Taylor and Partners Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Kidson Orthodontics Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Metrodental Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

MFM Community Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Milehouse Dental Care Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Mojo-D Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Nigel Reynolds Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

North Devon Orthodontic Centre Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Oasis Dental Care (Central) Holdings Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Oasis Dental Care (Central) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Oasis Dental Care (Southern) Holdings Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Oasis Dental Care (Southern) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Oasis Dental Care Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Oasis Healthcare Bidco Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Oasis Healthcare International Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Oasis Healthcare Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Oasis Healthcare Midco 1 Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Oasis Healthcare Midco 2 Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Oral Hygiene Innovations Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Oral Implantology Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Ortho 2008 Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Orthoscene Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Partick Dental Ltd.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Pembury TM Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Peter Baldwin (VHO) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Quantum Ortho Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Quest Dental Care LLP



2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Richley Dental Ceramics Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Rise Park Dental Practice Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Smile Lincs Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Smiles Dental Practices North Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Stop the Clock Dental Care Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Synergy Ceramics Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

T C Patel Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

The Exeter Dental Centre Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Tidge and Lou Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Windmill Dental Surgery Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Windslade Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

TDK Dental Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



IE

549300T5K5C5DBHXMC67IE10420

2 - Specific code

Xeon Dental Services Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Wylye Valley Dentistry Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Creative Designs Dental Laboratory Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Dencraft (South Yorkshire) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



Country



undertaking


Type of undertaking

Legal form


mutual)


% capital share

% used for the

establishment of


% voting rights

Other criteria

Level of influence

Proportional share

used for group


Yes/No


applied


the undertaking


GB


2 - Specific code

Deysbrook Dental Surgery Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

FACE (Facial Aesthetic Centres of Excellence) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Grosvenor Orthodontic Clinic (Beckenham) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Highwoods and St Johns Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



IE


2 - Specific code

Hugh Bradley Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

J.J. Thompson (Orthodontic Appliances) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

JDH Holdings Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Lawrence Street Dental Practice Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Mark Fazakerley (VHO) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Nadir Khan Surgical Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



IE


2 - Specific code

Oasis Healthcare Holdings Ireland Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Oswestry Dental Laboratory Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Priors Croft Dental Practice Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Roberts-Harry Clinic Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Smile Dental Care Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Steeple Grange Smiles Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

The Adams & Lee Dental Practice Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

The Oasis Healthcare Group Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Total Orthodontics Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Winning Smiles (Gillingham) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Wylde Green Orthodontics LLP



2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Xeon Smiles UK Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Aesthetic Dental Laboratory Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Apex Dental Care Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Avsan Fife Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Blueapple Dental and Implant Team Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Cheshire Cat Orthodontics Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Caring Dentistry Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Christopher F. Stafford Holdings Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Linden Dental Centre Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Victoria Reese Dental Practice Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Eckington Dental Practice Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Fairfield Dental Surgery Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

The Tutbury Dental Practice Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

B Dental Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Belfast Orthodontic Clinic Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Dental Confidence Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Dental Excellence - Harewood Practice LLP



2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Hospital Lane Dental Clinic Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Martin and Martin Dental Care Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Morrison Shenfine Holdings Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

North Lakeland Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Oasis Group EBT Trustee Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Private Dental Services Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Stob Dearg Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

The Dental Solutions Centre Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Tooth Fixer Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



Country



undertaking


Type of undertaking

Legal form


mutual)


% capital share

% used for the

establishment of


% voting rights

Other criteria

Level of influence

Proportional share

used for group


Yes/No


applied


the undertaking


GB


2 - Specific code

Victoria Oral Clinic Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Wessington Way Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Wimborne Total Dental Care Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Fortwilliam and Ballymena Specialist Dental Clinics Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

The Spire Halifax Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

King Lane Dental Care Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Luke Barnett Clinic Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Luke Barnett Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



IE


2 - Specific code

Lisa Creaven Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Occupational Health Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Occupational Health Care Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Health at Work Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Wellness Group Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Dental Services Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Personal Effectiveness Centre Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

BHS (Holdings) 2006 Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Ultimate Smile Spa Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

In Store Dental Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Store Dental Care Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Cranbrook Dental Practice Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

The Smile Centres Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Aqua Dental Spa Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Lab 53 Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Perlan Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Paul Coulthard Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

David Row Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Andrew Greenwood Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Stephen E B Jones Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

K R Postlethwaite Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (BNH) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (BNHP) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Services Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (GL) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Fulford Grange Medical Centre Limited




2 - Non-mutual

50.00%

100.00%

50.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (CFG) plc




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes Group Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GG

549300T5K5C5DBHXMC67GG10117

2 - Specific code

Bupa LeaseCo. (Guernsey) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (Bedfordshire) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (CFCHomes) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (CFHCare) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (Partnerships) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (Developments) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (AKW) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (Carrick) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

ANS 2003 Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

ANS Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (ANS) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



Country



undertaking


Type of undertaking

Legal form


mutual)


% capital share

% used for the

establishment of


% voting rights

Other criteria

Level of influence

Proportional share

used for group


Yes/No


applied


the undertaking


GB


2 - Specific code

Calverguild Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Ebbgate Nursing Homes (London) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Ebbgate Nursing Homes Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Belmont Care Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU

549300T5K5C5DBHXMC67AU10044

2 - Specific code

Bupa Aged Care Australia Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Bupa ANZ Healthcare Holdings Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Bupa Aged Care Holdings Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Bupa Aged Care Australasia Pty Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Bupa Aged Care Australia Holdings Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Bupa Aged Care Property Trust


Unit Trust

2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Bupa Aged Care Property No.2 Trust


Unit Trust

2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Bupa Aged Care Property No.3 Trust


Unit Trust

2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Bupa Aged Care Property No.3A Trust


Unit Trust

2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Bupa Care Villages Australia Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Richmond Care Villages Holdings Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Richmond Nantwich Developments Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Richmond Nantwich Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Richmond Nantwich Properties Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Richmond Coventry Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bede Village Management Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Richmond Villages Operations Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Richmond Painswick Management Company Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Richmond Care Villages (Property) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Richmond Northampton Management Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Richmond Northampton Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Richmond Letcombe Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (HH) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (HH Leeds) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (HH Northumberland) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (HH Scunthorpe) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (HH Hull) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (HH Bradford) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Watertight Investments Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (Holdings) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (PT) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (PT Lindsay Prop) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (PT Lindsay) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (PT Links Prop) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes (PT Links) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Care Homes Investments (Holdings) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB

5493009SHFMBK8L6PM06

1 - LEI

Bupa Investments Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa International Markets Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



SA

549300T5K5C5DBHXMC67SA10292

2 - Specific code

Nazer Bupa Medical Equipment Company Limited




2 - Non-mutual

50.00%

100.00%

50.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Europe Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB

213800KA5DH8W46SEF79

1 - LEI

Healthcode Limited




2 - Non-mutual

20.00%

20.00%

20.00%

2 - Significant

20.00%



GB

ZIMCVQHUFZ8GVHENP290

1 - LEI

Bupa Finance plc




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Plainprime Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



Country



undertaking


Type of undertaking

Legal form


mutual)


% capital share

% used for the

establishment of


% voting rights

Other criteria

Level of influence

Proportional share

used for group


Yes/No


applied


the undertaking


GB

549300X3NSW1ENRVER87

1 - LEI

Bupa Investments Overseas Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GG


2 - Specific code

Bupa Holdings (Guernsey) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GG


2 - Specific code

Bupa LeaseCo Holdings Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Financial Investments Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Holdings (Jersey) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GI

549300T5K5C5DBHXMC67GI10120

2 - Specific code

Bupa Malta Investments No. 1 Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GI

549300T5K5C5DBHXMC67GI10121

2 - Specific code

Bupa Malta Investments No. 2 Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GG

549300YS59OPBS1YI584

1 - LEI

Bupa Guernsey No 2 Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Europe Investments Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Bupa Global Holdings Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Cromwell Health Group Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Medical Services International Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB


2 - Specific code

Health Dialog UK Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



ES

959800J2A2QS6C0ANF48

1 - LEI

Sanitas S.A. de Seguros




2 - Non-mutual

Direccion General de Seguros y Fondos

de Pensiones

99.91%

100.00%

99.91%

1 - Dominant

100.00%



ES

549300T5K5C5DBHXMC67ES10363

2 - Specific code

Sanitas, S.A. de Hospitales S.U.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



ES


2 - Specific code

Sanitas S.L. de Diversificacion S.U.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



ES


2 - Specific code

Sanitas Mayores S.L.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



ES

549300B21HAPJC758Y46

1 - LEI

Grupo Bupa Sanitas S.L.U.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



ES


2 - Specific code

Foren Project S.L.




2 - Non-mutual

20.00%

20.00%

20.00%

2 - Significant

20.00%



ES

5493001X2SP61R4I0P73

1 - LEI

Especializada y Primaria L’Horta-Manises, S.A.U.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



ES


2 - Specific code

Sanitas Emision S.L.U.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



ES


2 - Specific code

Sanitas Mayores Navarra S.L.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



ES


2 - Specific code

Sanitas Mayores Pais Vasco S.A.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



ES


2 - Specific code

Sanitas Nuevos Negocios S.L.U.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



CL

549300T5K5C5DBHXMC67CL10229

2 - Specific code

Grupo Bupa Sanitas Chile Uno, SpA




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



ES

549300R3TMT64MKBV434

1 - LEI

Sanitas Holding, S.L.U.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



CL


2 - Specific code

Centro De Diagostico Avanzado San Jose S.A.




2 - Non-mutual

68.96%

100.00%

68.96%

1 - Dominant

100.00%



CL


2 - Specific code

Centro De Imagenes Medicas Avanzadas San Jose S.A.




2 - Non-mutual

48.28%

48.28%

48.28%

2 - Significant

48.28%



CL


2 - Specific code

Centro Medico Antofagasta S.A.




2 - Non-mutual

85.88%

100.00%

85.88%

1 - Dominant

100.00%



CL


2 - Specific code

Clinica Renaca S.A.




2 - Non-mutual

91.88%

100.00%

91.88%

1 - Dominant

100.00%



CL


2 - Specific code

Corporacion Medica De Arica S.A.




2 - Non-mutual

68.97%

100.00%

68.97%

1 - Dominant

100.00%



CL


2 - Specific code

Desarrollo E Inversiones Medicas S.A.




2 - Non-mutual

91.88%

100.00%

91.88%

1 - Dominant

100.00%



CL


2 - Specific code

Inmobiliaria Centro Medico Antofagasta S.A.




2 - Non-mutual

85.89%

100.00%

85.89%

1 - Dominant

100.00%



CL


2 - Specific code

Inmobiliaria Somequi S.A.




2 - Non-mutual

85.88%

100.00%

85.88%

1 - Dominant

100.00%



CL


2 - Specific code

Inmobiliaria Y Constructora CBS S.A.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



CL


2 - Specific code

Inversiones Clinicas CBS S.A.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



CL


2 - Specific code

Inversiones Clinicas Pukara S.A.




2 - Non-mutual

85.88%

100.00%

85.88%

1 - Dominant

100.00%



CL


2 - Specific code

Promotora De Salud S.A.




2 - Non-mutual

67.03%

100.00%

67.03%

1 - Dominant

100.00%



CL


2 - Specific code

Bupa Servicios Clínicos S.A.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



CL


2 - Specific code

Servicios De Personal Clinico CBS Dos S.A.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



CL


2 - Specific code

Servicios Y Abastecimiento A Clinicas S.A.




2 - Non-mutual

85.88%

100.00%

85.88%

1 - Dominant

100.00%



CL


2 - Specific code

Sociedad De Inversiones Pacasbra S.A.




2 - Non-mutual

69.19%

100.00%

69.19%

1 - Dominant

100.00%



CL


2 - Specific code

Sociedad De Resonancia Magnetica Del Norte S.A.




2 - Non-mutual

85.88%

100.00%

85.88%

1 - Dominant

100.00%



CL


2 - Specific code

Sociedad Instituto De Cardiologia Del Norte Limitada




2 - Non-mutual

42.94%

42.94%

42.94%

2 - Significant

42.94%



CL


2 - Specific code

Sociedad Medica Imageneologia Clinica Renaca Limitada




2 - Non-mutual

73.51%

100.00%

73.51%

1 - Dominant

100.00%



CL


2 - Specific code

Sociedad Medico Quirurgica De Antofagasta S.A.




2 - Non-mutual

85.88%

100.00%

85.88%

1 - Dominant

100.00%



CL


2 - Specific code

Isapre Cruz Blanca S.A.




2 - Non-mutual

Superintendencia de Salud

99.06%

100.00%

99.06%

1 - Dominant

100.00%



Country



undertaking


Type of undertaking

Legal form


mutual)


% capital share

% used for the

establishment of


% voting rights

Other criteria

Level of influence

Proportional share

used for group


Yes/No


applied


the undertaking


CL


2 - Specific code

Bupa Servicios de Salud SpA




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



CL


2 - Specific code

Examenes De Laboratorio S.A.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



CL


2 - Specific code

Integramedica S.A.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



CL


2 - Specific code

Recaumed S.A.




2 - Non-mutual

58.40%

100.00%

58.40%

1 - Dominant

100.00%



CL


2 - Specific code

Sonorad I S.A.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



CL


2 - Specific code

Sonorad II S.A.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



PE

549300T5K5C5DBHXMC67PE10010

2 - Specific code

Anglolab S.A




2 - Non-mutual

70.00%

100.00%

70.00%

1 - Dominant

100.00%



CL


2 - Specific code

Bupa Inversiones Latam S.A.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



PE


2 - Specific code

Integramedica Peru S.A.C.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



PE


2 - Specific code

MediPeru S.A.C




2 - Non-mutual

99.97%

100.00%

99.97%

1 - Dominant

100.00%



CL


2 - Specific code

Bupa Compania de Seguros de Vida S.A.




2 - Non-mutual

Superintendencia de Valores y Seguros

100.00%

100.00%

100.00%

1 - Dominant

100.00%



CL


2 - Specific code

Bupa Chile S.A.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



ES


2 - Specific code

Elegimosalud S.L.U




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



ES


2 - Specific code

Clinica Londres, S.L.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



ES


2 - Specific code

Sahna-E, Servicios Integrales de Salud, S.A. de Seguros y

Reaseguros (Unipersonal)




2 - Non-mutual

Direccion General de Seguros y Fondos

de Pensiones

99.91%

100.00%

99.91%

1 - Dominant

100.00%



ES


2 - Specific code

Investigacion Y Promocion Sanitaria S.A.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



ES


2 - Specific code

Clinicas Ginemed S.L.




2 - Non-mutual

70.00%

100.00%

70.00%

1 - Dominant

100.00%



BO

549300T5K5C5DBHXMC67BO10111

2 - Specific code

Bupa Insurance (Bolivia) S.A




2 - Non-mutual

Autoridad de Fiscalizacion y Control de

Pensiones y Seguros (APS)

100.00%

100.00%

100.00%

1 - Dominant

100.00%



DK

549300T5K5C5DBHXMC67DK10089

2 - Specific code

Bupa Denmark Services A/S




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GG


2 - Specific code

UK Care No.1 Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



HK

549300T5K5C5DBHXMC67HK10112

2 - Specific code

Bupa International Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



HK


2 - Specific code

Bupa Limited (HK)




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



HK


2 - Specific code

Bupa (Asia) Limited




2 - Non-mutual

Hong Kong Insurance Authority

100.00%

100.00%

100.00%

1 - Dominant

100.00%



CN

549300T5K5C5DBHXMC67CN10087

2 - Specific code

Bupa Consulting (Beijing) Co. Ltd.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



SG

549300T5K5C5DBHXMC67SG10137

2 - Specific code

Bupa Singapore Holdings Pte Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



IN

549300T5K5C5DBHXMC67IN10278

2 - Specific code

Max Bupa Health Insurance Company Limited




2 - Non-mutual

Insurance Regulatory and Development

Authority

49.00%

49.00%

49.00%

2 - Significant

49.00%



PL

549300T5K5C5DBHXMC67PL10158

2 - Specific code

Centrum Edukacji Medycznej Sp. z.o.o.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



PL


2 - Specific code

Centrum Opieki Medycznej Comed Sp. z.o.o.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



PL


2 - Specific code

Diagnostic - Med. Centrum Diagnostyki Radiologicznej Sp.

z.o.o.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



PL


2 - Specific code

Lux Med Lodz Sp. z.o.o.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



PL

259400F4L9MD7NSTX890

1 - LEI

LUX MED Sp. z.o.o.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



PL


2 - Specific code

Lux Med Tabita Sp. z.o.o.




2 - Non-mutual

88.00%

100.00%

88.00%

1 - Dominant

100.00%



PL


2 - Specific code

Medicor Sp. z.o.o.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



PL


2 - Specific code

Medika Uslugi Medyczne Sp. z.o.o.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



PL


2 - Specific code

Megamed Sp. z.o.o.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



PL


2 - Specific code

Niepubliczny Zaklad Opieki Zdrowotnej Przychodnia

Lekarska "POGORZE" Sp. z.o.o.




2 - Non-mutual

88.15%

100.00%

88.15%

1 - Dominant

100.00%



PL


2 - Specific code

Tomograf Sp. z.o.o.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



PL


2 - Specific code

Poluk Sp. z.o.o.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



PL


2 - Specific code

Nzoz Ultramedic Centrum Medyczne Sp z.o.o.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



PL


2 - Specific code

Centrum Edukacji Medycznej CEMED Sp. z.o.o.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



PL


2 - Specific code

Centrum Edukacyjne Medycyny Sportowej Sp. z.o.o.




2 - Non-mutual

50.00%

100.00%

50.00%

1 - Dominant

100.00%



PL


2 - Specific code

Sport Medica S.A.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



PL


2 - Specific code

Pory 78 Sp. z.o.o.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



PL


2 - Specific code

LUX-MED Investment S.A.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



SE

549300RLIK8ZJSRA1W02

1 - LEI

LMG Forsakrings AB




2 - Non-mutual

Finantsinspektsioon

100.00%

100.00%

100.00%

1 - Dominant

100.00%



PL


2 - Specific code

Magodent Sp. z.o.o.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



PL


2 - Specific code

Endoterapia PFG Sp. z.o.o.




2 - Non-mutual

40.00%

40.00%

40.00%

2 - Significant

40.00%



Country



undertaking


Type of undertaking

Legal form


mutual)


% capital share

% used for the

establishment of


% voting rights

Other criteria

Level of influence

Proportional share

used for group


Yes/No


applied


the undertaking


PL


2 - Specific code

Elba 1 Sp. z.o.o.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



PL


2 - Specific code

Elblaska Sp. z.o.o.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Bupa ANZ Insurance Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Bupa Health Services Pty Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Bupa HI Holdings Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Bupa Optical Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU

549300S83ZXPGM3RU407

1 - LEI

Bupa HI Pty Ltd




2 - Non-mutual

Australian Prudential Regulation

Authority

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Bupa Telehealth Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Bupa Wellness Pty Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Bupa Dental Corporation Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Australia Fair Dental Care Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

DC Holdings WA Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Dental Care Network Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



NZ

549300T5K5C5DBHXMC67NZ10182

2 - Specific code

Dental Corporation (NZ) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Dental Corporation Australia Fair Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Dental Corporation Cox Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Dental Corporation Gerber Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Dental Corporation Holdings Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Dental Corporation Levas Pty.Ltd.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Dental Corporation Petrie Pty.Ltd.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Dental Corporation Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Dr Chris Hardwicke Pty.Ltd.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Gerber Dental Group Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Larry Benge Pty Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Mobile Dental Pty Ltd




2 - Non-mutual

49.00%

49.00%

49.00%

2 - Significant

49.00%



AU


2 - Specific code

Scott Petrie (Dental) Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Bupa Medical Services Pty Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Bupa Medical (GP) Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Bupa ANZ Finance Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Bupa Innovations (ANZ) Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Whitecoat Holdings Pty Ltd




2 - Non-mutual

23.48%

23.48%

23.48%

2 - Significant

23.48%



AU


2 - Specific code

Bupa ANZ Group Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AU


2 - Specific code

Bupa Disability Services Pty Ltd




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



NZ


2 - Specific code

Bupa Care Services NZ Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



NZ


2 - Specific code

Bupa Retirement Villages Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



SA

558600B2WJHD5P31XS68

1 - LEI

Bupa Arabia For Cooperative Insurance Company




2 - Non-mutual

Saudi Arabian Monetary Agency

(SAMA); The Council of Cooperative

Health Insurance (CCHI)

39.25%

39.25%

39.25%

2 - Significant

39.25%



BH

549300T5K5C5DBHXMC67BH10125

2 - Specific code

Bupa Middle East Holdings Two W.L.L.




2 - Non-mutual

75.00%

100.00%

75.00%

1 - Dominant

100.00%



EG

549300T5K5C5DBHXMC67EG10095

2 - Specific code

Bupa Egypt Insurance S.A.E.




2 - Non-mutual

Financial Regulatory Authority

100.00%

100.00%

100.00%

1 - Dominant

100.00%



AE

549300T5K5C5DBHXMC67AE10102

2 - Specific code

Bupa Global Middle East (DIFC) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



HK


2 - Specific code

Allied Medical Practices Guild Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



HK


2 - Specific code

Alpha Medical MRI (TST) Limited




2 - Non-mutual

65.00%

100.00%

65.00%

1 - Dominant

100.00%



VG

549300T5K5C5DBHXMC67VG10005

2 - Specific code

Altai Investments Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



VG


2 - Specific code

Berkshire Group Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



HK


2 - Specific code

Case Specialist Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



HK


2 - Specific code

Central Medical Diagnostic Centre Limited




2 - Non-mutual

74.49%

100.00%

74.49%

1 - Dominant

100.00%



HK


2 - Specific code

Central MRI Centre Limited




2 - Non-mutual

74.49%

100.00%

74.49%

1 - Dominant

100.00%



HK


2 - Specific code

Central PET/CT Scan Centre Limited




2 - Non-mutual

74.49%

100.00%

74.49%

1 - Dominant

100.00%



Country



undertaking


Type of undertaking

Legal form


mutual)


% capital share

% used for the

establishment of


% voting rights

Other criteria

Level of influence

Proportional share

used for group


Yes/No


applied


the undertaking


HK


2 - Specific code

DB Health Services Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



VG


2 - Specific code

Dynamic People Group Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



HK


2 - Specific code

Great Option Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



HK


2 - Specific code

Jadeast Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



HK


2 - Specific code

Jadefairs International Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



HK


2 - Specific code

Jadison Investment Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



HK


2 - Specific code

Jadway International Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



HK


2 - Specific code

Marvellous Way Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



HK


2 - Specific code

Megafaith International Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



MO

549300T5K5C5DBHXMC67MO10330

2 - Specific code

Quality EAP (Macau) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



HK


2 - Specific code

Quality HealthCare Dental Services Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



HK


2 - Specific code

Quality HealthCare Medical Centre Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



MO

549300T5K5C5DBHXMC67MO10333

2 - Specific code

Quality Healthcare Medical Services (Macau) Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



HK


2 - Specific code

Quality HealthCare Medical Services Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



HK


2 - Specific code

Quality HealthCare Nursing Agency Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



HK


2 - Specific code

Quality HealthCare Physiotherapy Services Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



HK


2 - Specific code

Quality HealthCare Professional Services Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



HK


2 - Specific code

Quality HealthCare Psychological Services Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



HK


2 - Specific code

Quality Healthcare TPA Services Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



CN


2 - Specific code

Guangzhou Bupa Hospital Management Company Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



CN


2 - Specific code

Guangzhou Bupa Quality HealthCare General Outpatient

Department Company Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



US

549300C3T51F4EVYDC86

1 - LEI

Bupa Insurance Company




2 - Non-mutual

Florida Office of Insurance Regulation

100.00%

100.00%

100.00%

1 - Dominant

100.00%



US


2 - Specific code

Bupa Worldwide Corporation




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



US


2 - Specific code

U.S.A. Medical Services Corporation




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



BM

549300T5K5C5DBHXMC67BM10006

2 - Specific code

Amedex Insurance Company (Bermuda) Limited

1 - Life insurance undertaking



2 - Non-mutual

Bermuda Monetary Authority

100.00%

100.00%

100.00%

1 - Dominant

100.00%



US


2 - Specific code

Bupa Investment Corporation, Inc.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



EC

549300T5K5C5DBHXMC67EC10094

2 - Specific code

Bupa Ecuador S.A. Compania de Seguros




2 - Non-mutual

Superintendencia de Compañías Bancos

y Seguros

100.00%

100.00%

100.00%

1 - Dominant

100.00%



DO

549300T5K5C5DBHXMC67DO10093

2 - Specific code

Bupa Dominicana, S.A.




2 - Non-mutual

Superintendencia de Seguros de la

República Dominicana

100.00%

100.00%

100.00%

1 - Dominant

100.00%



KN

549300T5K5C5DBHXMC67KN10008

2 - Specific code

Amedex Services Ltd. (St Kitts)




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



DO

549300T5K5C5DBHXMC67DO10007

2 - Specific code

Amedex Medical Group, S.R.L.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GT

549300T5K5C5DBHXMC67GT10103

2 - Specific code

Bupa Guatemala, Compania de Seguros, S.A.




2 - Non-mutual

Superintendencia de Bancos de

Guatemala

100.00%

100.00%

100.00%

1 - Dominant

100.00%



PA

549300T5K5C5DBHXMC67PA10128

2 - Specific code

Bupa Panama S.A.




2 - Non-mutual

Superintendencia de Seguros y

Reaseguros de Panama

100.00%

100.00%

100.00%

1 - Dominant

100.00%



BR

549300T5K5C5DBHXMC67BR10146

2 - Specific code

Care Plus Medicina Assistencial Ltda




2 - Non-mutual

Superintendecia de Seguros Privados

100.00%

100.00%

100.00%

1 - Dominant

100.00%



BR


2 - Specific code

Personal System Serviços Médicos e Odontológicos Ltda



2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



BR


2 - Specific code

Care Plus Negócios Em Saúde Ltda




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



US


2 - Specific code

Bupa U.S. Holdings, Inc.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



MX

549300T5K5C5DBHXMC67MX10124

2 - Specific code

Bupa Mexico, Compania de Seguros, S.A. de C.V.




2 - Non-mutual

Comisión nacional de seguros y fianzas

100.00%

100.00%

100.00%

1 - Dominant

100.00%



MX


2 - Specific code

Bupa Servicios Administrativos de Salud, S. de R.L. de C.V.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



MX


2 - Specific code

Bupa Servicios de Evaluacion Medica, S. de R.L. de C.V.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



MX


2 - Specific code

Bupa Servicios Ejecutivos de Salud, S. de R.L. de C.V.




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB

549300INUTLX8PYTQR63

1 - LEI

Bupa Insurance Limited




2 - Non-mutual

The Prudential Regulation Authority

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB

549300ICHHHGHZ0T8T47

1 - LEI

Bupa Insurance Services Limited




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



GB

549300T5K5C5DBHXMC67

1 - LEI

The British United Provident Association Limited




2 - Non-mutual

#N/A



EG

549300T5K5C5DBHXMC67EG10096

2 - Specific code

Bupa Egypt Services LLC




2 - Non-mutual

100.00%

100.00%

100.00%

1 - Dominant

100.00%



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