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Industrial clients’ Liability Navigator tool – environmental liability assessment

Organisation: If P&C Insurance Company Ltd

Time: 12/11/2014 – 12/1/2015



As an insurance company If P&C is exposed to our clients’ losses and damages caused by the deteriorated state of the environment and extreme weather phenomena. With insurance products it is possible to even out between the policyholders the negative economic impacts stemming from environmental risks but nothing can compensate the long-term deterioration of the environment itself.
The specialists working in the Industrial Risk Management unit conduct risk assessments of our clients’ risks with various tools and methods. The tool for liability risks is the Liability Navigator based on a question set and an interview of the company management. The liability risks are divided into eleven risk areas, which include e.g. management commitment, information of liability matters and product liability. Environmental liability is one of the risk areas. The questions examine among other risks factors whether the company has identified and assessed its environmental risks, what are the required actions according to the environmental permit, is there a risk of environmental damage through sudden or gradual emissions from the company’s operation, what are the supervision, control and maintenance functions and measures and are the necessary and sufficient preventive measures in place.
If’s risk specialist writes a report of the results and gives there recommendations for improving the client’s liability risk management.
If P&C commits to develop this risk management tool in a way, where among the environmental liability risks it will be also asked what is the company’s policy regarding the operation’s wider environmental impacts such as discharges finally entering the Baltic Sea.

The Commitment was first introduced publicly in the Responsible Liability Day 18.9.2014 at Hotel Palace, Helsinki, Finland.

The Baltic Sea specific questions in the Liability Navigator questions are:

Has the company identified and assessed the environmental risks of its operation?
Does the company have an environmental license or a discharge permit?
What are the required actions according to the license or the permit to limit pollution and does the company comply with them? What are the analysis and reporting practices required by the authorities?
Has the company assessed the consequences of possible environmental accidents to the surrounding areas including:
– Schools, recreation or residential areas?
– Nature conservation areas (Natura 2000 or others)?
– Industrial, commercial, administrative or other areas with vulnerability to environmental hazards?
– Baltic Sea (e.g. port or water system which is in direct or indirect contact with the Baltic Sea)
Are there emergency plans for major catastrophes with advice to the exposed people and businesses in the surrounding areas? How have they been communicated to those affected?
Is there a possibility that the long term accumulation in the environment of chemicals regularly used by the company e.g. phosphorus and nitrogen containing substances, or Hazardous substances and litter could cause deterioration of the state of the environment – land or water system like the Baltic Sea?
Is there a risk of gradual pollution resulting from discharges of treated waste water or emissions of cleaned gases?
Has the company arranged in compliance with the regulations a safe terminal storage or treatment process for Hazardous substances and litter separated from the waste water or from other process?
Does the company have underground or aboveground storage tanks for liquids?
Is there a risk of major emissions, due to failure in treatment plants or sudden leaks from storage tanks etc?
Are there necessary and sufficient preventive measures in place? What are they?
What are the company’s supervision, control and maintenance functions and measures?