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Company Registration Number: C 5553
MAPFRE MIDDLESEA p.l.c.
Annual Report
31 December 2024
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Contents
Page
Page
Remuneration Statement and Report of the
  Remuneration Committee to the Shareholders
24.    Insurance contract assets, insurance contract     
            liabilities, reinsurance contract assets and       
            reinsurance contract liabilities
24.1  Composition of statement of financial
            position
24.2  Short-term insurance contracts under PAA
            model
  2.9    Financial instruments
  2.10  Insurance and investment contracts issued
              and reinsurance contracts held
  24.6 Long term contracts - inputs assumptions
              and estimation techniques
26.    Trade and other receivables
i
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Chairman’s Statement
Last year I said that I felt an obligation to become more succinct in my report looking into the
key messages from the financial year ended 31 December 2024, with the report of the
President & Chief Executive Officer which follows and the full Annual Report delving into
the details of the operations. As reported last year the adopted International Financial
Reporting Standard (IFRS) 17 has now been entrenched in the Group’s processes achieving
stability in the ongoing reporting.
Results
The Group results comprise of MAPFRE Middlesea p.l.c. (“MAPFRE Middlesea”, “MMS”
or “Company”), which is principally a General Insurance company (writing mainly Motor,
Health, Home, Travel, Hull and others (including a small element of Group Life). MAPFRE
Middlesea also has a 50% interest in MAPFRE MSV Life p.l.c. (“MAPFRE MSV Life”,
“MMSV”), which is a Life and Savings Investment company – the other 50% being owned
by our partner Bank of Valletta p.l.c.. Other Group companies include the subsidiary BEE
Insurance Management Limited and the associate Middlesea Assist Limited. whose positive
results, though not material, contribute to these financial statements.
Both MMS and MMSV have delivered a satisfactory result exceeding set targets delivering to
the Group an improved result on the already significant 2023 result. The Group’s €24.8
million profit before tax represents a healthy pre-tax return on equity of 14.0% marginally
lower than the previous year 14.6% as the Group, particularly MAPFRE MSV Life continued
to strengthen its balance sheet to consolidate further their Solvency position for the benefit of
policyholders and shareholders alike.
Dividends
MAPFRE Middlesea is declaring a net dividend of €4.8 million (2023 €4.5 million) out of
the net attributable profit after tax of €7.1 million. This translates into a net dividend per
share of €0.052174. The dividends received from MAPFRE MSV Life may be seen as low in
comparison to its profit (€1.0 million for FY 2023 and none for FY2022 compared to profits
after tax of €9.6 million and €2.1 million respectively, of which MAPFRE Middlesea would
be entitled to 50%). The retaining of profits by MAPFRE MSV Life maintains a good level
of liquidity and solvency which is required for the capital guarantee provided on the with
profits investment fund. The funds are retained at MAPFRE MSV Life and form part of the
shareholders' funds.
Corporate Social Responsibility
In 2024, MAPFRE Malta successfully achieved its CSR goals by partnering with various
entities to organize numerous activities, including food and blood donations, environmental
initiatives, and contributions to several charitable organizations and NGOs. Among the
beneficiaries were Caritas, Hospice, Puttinu Cares, Dar Bjorn, Dar il-Kaptan, and YMCA.
ii
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Chairman’s Statement - continued
Corporate Social Responsibility - continued
Fundación MAPFRE allocated over €150,000 for projects in Malta, covering areas such as
road safety awareness, health campaigns, and social actions. The Foundation also continued
its collaboration with Caritas Malta, supporting the Adventure Therapy Cycling Project,
which provides therapeutic outdoor activities for adolescents dealing with substance abuse
issues. Throughout 2024, Fundación MAPFRE maintained its efforts to promote road safety
by educating young adults and the general public. In addition to its ongoing campaign with
Malta Public Transport, the Ministry of Education, and the Road Safety Council, Fundación
MAPFRE partnered with Doctors for Road Safety (D4RS) to address this critical national
issue.
Governance
You will read elsewhere in this report that the Board meets regularly and is supported by
board committees for Risk and Compliance, Audit, and Remuneration. This allows the board
to set strategy, challenge management, and ensure adherence with the highest standards of the
group, relevant regulation and best practice.
We maintain an open and transparent relationship with the Malta Financial Services
Authority, our regulator, and we strive to be best in class when navigating the welter of
regulation which has come our way in recent years. On the near horizon we continue to see
various updated or new regulations which will continue to take up resources and effort, and
of course add costs to our operation.
Distribution
The Group remains committed to maintaining the highest standards of service to its ultimate
customers, through its staff, as well as through its Tied Insurance Intermediaries, its agents
and brokers.
The MAPFRE Middlesea business model is somewhat different from our competitors, as we
rely on 6 agents, over 60 Tied Insurance Intermediaries and Brokers to bring in the bulk of
our insurance premium. Only 9% of our business is written directly by us.
It is our business to not only provide cover to the insured, but also to provide the products,
correct pricing and technical support to our intermediaries. IT has proved the bug bear of
progress and yet again this year I need to report that we have not achieved the goals we have
set ourselves, albeit progress has been achieved. We are now at a critical point in the digital
transformation of the Company and we look to our distributors to take this final effort with us
before we reach the sunny uplands of this transformation in the coming months.
With MAPFRE MSV Life, Bank of Valletta remains by far the single largest producer for the
company, for term assurance as well as investment products. The bank has proved to be an
excellent partner, as well as shareholder in the group. I cannot emphasise the importance of
the Bank to the Malta group, which has in no small way contributed to the results reported
here. This is a partnership which has stood the test of time and has delivered results for
customers and shareholders alike.
iii
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Chairman’s Statement - continued
Directors and shareholders
MAPFRE Middlesea p.l.c. is a listed entity regulated by the Malta Financial Services
Authority. It is a subsidiary of MAPFRE Internacional S.A.. Being part of one of the largest
insurance companies in the world allows us to access technical know how and expertise
which is at the cutting edge of the industry. It has allowed us to develop the business to the
latest standards by providing relevant support in all sectors. MAPFRE Internacional S.A. has
a shareholding of 55.83% in the Company.
Bank of Valletta p.l.c. is the other major institutional shareholder with 31.08% of the
shareholding and is a 50% co-shareholder in MAPFRE MSV Life p.l.c.. The bank has proved
to be a steady partner throughout the years, providing not only input and insight at board
level and the relationship remains strong. 13.09% of the shareholding in MAPFRE Middlesea
is held by the so-called smaller shareholders, of which we have some 3,700.
I have the privilege to work with a dedicated board of professionals who have provided
direction and support to the Company’s executives. The Board comprised of Eduardo Perez
de Lema, CEO International Insurance at MAPFRE S.A., Jose Luis Jimenes, Jose Maria del
Pozo, and Etienne Sciberras, who represented the MAPFRE shareholding. Gordon Cordina,
who is the chair at Bank of Valletta, and Godfrey Swain were appointed by Bank of Valletta.
The smaller shareholders elected Antoinette Caruana and Paul Testaferrata Moroni Viani. I
work with a board which has a full range of skills, and intellectual capability to grapple with
the tasks before it. To all of them I am very grateful for their contribution and support.
Javier Moreno our CEO at MAPFRE Middlesea has resigned on the 31 December 2024 to
take up an important post at MAPFRE S.A. We will still remain in his sphere of influence
since he is now in charge of the EMEA region. Javier has spent four years with us and his
reforming zeal has put the Company on a firmer footing, better able to face the challenges of
the future. Whilst wishing him well in his new post, I can record our thanks for his
dedication, and leadership and the tangible results achieved during his tenure. He has been
replaced by Etienne Sciberras, who, as you are aware comes from MAPFRE MSV Life
where he was CEO. He has done an impressive job of guiding the Company through some of
its most turbulent days including Covid and the impact of negative interest rates, and the
massive market fluctuations we have seen in recent years. He has now been appointed CEO
of MAPFRE Middlesea as well as CEO of MAPFRE Malta group.
We also welcome Elvira López de Lara Merida from MAPFRE S.A. who comes with an
impressive CV and track record, and will be the new CEO of MAPFRE MSV Life.
To our Chief officers, managers, and all staff who form part of this group of companies,
together with the board I salute their hard work without which we would not have achieved,
indeed continue to achieve, the desired results.
Signed by Martin Galea (Chairman) on 25 March 2025
iv
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
President & Chief Executive Officer’s Statement
MAPFRE Middlesea Group highlights
It is with great pleasure that I am writing to you for the first time as President and CEO of
MAPFRE Middlesea p.l.c. (“MAPFRE Middlesea”, “MMS”, “Company”). Before delving
into the business and financial performance, I would like to start off by thanking my
predecessor Javier Moreno for the sterling work he carried out over the past 4 years. His
leadership, commitment and professionalism were instrumental not only for the achievement
of the excellent results registered in 2024 but also for the way the MAPFRE Malta Group has
continued to develop and grow during globally challenging times.
The Political and Economic Context
The global backdrop remains uncertain. Persisting geopolitical headwinds, governments’
policy uncertainty and stickier inflation continue to complicate global Central Banks path
towards monetary policy normalization. Notwithstanding, global economies continued to
show great resiliency, most notably in the US. In Europe, economic growth continues to be
anemic and is expected to remain so, at least, in the near term.
Global financial markets remained volatile particularly credit markets. In general, equity
markets did well but performance varied across geographies and sectors. US equities
outperformed European equities, with the technology sector being the best performing sector.
During 2024, the so-called magnificent seven US companies lifted major US indices to new
highs as AI promises to transform the world we live in and those companies’ better
positioned to usher in this new era saw exponential growth in their quoted prices. As an asset
class, equity outperformed fixed income.
In Malta, the post COVID -19 pandemic recovery continued. The economy continued to
grow and registered the best GDP growth in the EU while inflation has been gradually
coming down amid a very tight labour market with unemployment rates in the low single
digit. However, inflationary pressures continued in the service industry mainly through
second order impacts as increases in wage demand persisted. This sustained positive
economic activity continues to spur demand for various insurance products.
Group Financial Performance
The total business written has been €309.5 million (2023: €297.0 million). Both MAPFRE
Middlesea and MAPFRE MSV Life p.l.c. (“MAPFRE MSV Life”, “MMSV”) registered
year-on-year increases in terms of total business written. MAPFRE Middlesea registered
growth in gross premium earned across all its classes of business with the exception of
marine cargo.
On the other hand, MAPFRE MSV Life’s total business written grew to  €205.8 million,
representing an increase compared to the previous year end close of €201.3 million. Both
single and regular premium business performed better than last year. The single premium
segment continued to evidence a good mix between With-Profits and Unit Linked business.
On the other hand, regular premium business growth is attributable to both a stronger demand
for life protection and long-term regular savings. The strong local economy remains the key
driver behind this evolution. As for long term regular savings, pension savings continues to
spur demand. MAPFRE MSV Life continues to be a leading player in the pension provision
space.
v
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
President & Chief Executive Officer’s Statement - continued
Group Financial Performance - continued
The consolidated MAPFRE Group's result in Malta for the year under review have been
excellent with a pre-tax profit of €24.8 million. The reported profitability is marginally above
last year reported figure of  €24.0 million. This equates to Earnings per share of 13c6 an
increase of 10.7% over 2023 corresponding figure.
The Premium written figure for MAPFRE Middlesea including group life reached a total of
€103.7 million at the end of 2024, representing an increase of 8.3% over 2023.  MMS
registered a profit before tax of €10.5 million. This is 6.8% above the 2023 reported
profitability.
The insurance service results saw a marginal improvement from previous year,
notwithstanding a small deterioration in the net combined ratio which has moved to 86.4%
compared to 85.6%. The diversification of our business helped to offset a deterioration in net
combined ratio for health and other classes of business through an improved motor combined
ratio. 
Regarding the long-term business, the challenging financial markets conditions persisted,
leading to the continued strong competition for our savings and investments products. These
are disclosed in a specific section within this report.
General Business
Premium Written in 2024 reached €101.7 million, representing an increase of 9.4% over
2023.
For the first time in our history premium written exceeded the €100 million mark. Premium
growth was achieved across all the main lines of business.
In our comparison with the rest of the market, we still maintain a clear leadership position
with a market share of 31.8% in 2024, which is a slight drop from the 31.9% we had in 2023.
We maintain proportionate leadership in most business lines.
Motor, health and property remain the main classes of business written. Together these three
lines of business represent over 73% of the gross written premium. Commercial lines have
also been very solid throughout the year.
The trust of our clients is reflected in the high policy and client retention levels registered
across the various lines of business. Our reputation, build over many years of service is based
on trust and respect towards our customers. We continue to earn the trust of our customers
through the values we embrace, our customer centric approach, financial soundness,
professional workforce, the breadth and depth of our product offering and our wide
distribution footprint. This together with other aspects make the MAPFRE Middlesea value
proposition unique. This is why MAPFRE Middlesea remains the local insurer of choice for
thousands of clients. Our customer base has exceeded 130,000 with more than 270,000
policies in force. However, we are cognizant of the highly competitive market so any
business contraction which is not the result of our risk management strategy is timely and
closely analyzed and evaluated for possible corrective measures.
vi
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
President & Chief Executive Officer’s Statement - continued
General Business - continued
Our partners, Brokers, Agents and TIIs have demonstrated once again that a relationship
based on mutual trust and commitment is the basis for excellent service to our clients,
offering agile and personalised attention. Our agents had an excellent year, showing that this
model generates profitable and sustainable growth. The agents network has increased
premium by 11.1%, a remarkable figure. I would like to highlight the consistent and excellent
performance achieved by Laferla Insurance Agency.
MMS continues to maintain an excellent professional relationship with brokers and the strong
figures show this year has been a good one. Considering Commercial lines, reinsurance
restrictions and higher costs are generating more complexity as this type of business requires
more protection capacity to meet concrete customer´s needs.
Our direct business, consisting of our regional offices and TIIs, has also performed
positively. As a Company, we believe this channel has further potential. The measures taken
last year together with other ongoing ones, are meant to unlock this potential where we
expect to start seeing the first benefits of these measures accruing in the current year. 
We firmly believe that to better serve the needs of our customers we need to be as accessible
as possible. We are also cognizant that different clients have different preferences on when
and how they interact with us. We continue to invest to improve accessibility. While we
remain committed towards digitalization, we believe that in person interaction continues to be
highly valued by our customers. To this effect, in 2024 we opened two important centers.
One is a sales office in San Gwann whereby the direct offices now total four and a modern,
state of the art vehicle inspection center in Naxxar. This is yet another tangible manifestation
of our commitment to serve our clients in the most convenient way. 
The overall net Combined Ratio (COR) which is the key performance indicator in our
business closed at a positive 86.4% albeit a slight deterioration on the already very positive
85.6% registered a year earlier.
The main contributor to the positive combined ratio was the motor class of business. The
performance of the Motor business portfolio significantly impacts the financial performance
of our Company. This is not surprising given that motor represents 48.2% of the non-life
portfolio. The already very positive evolution registered in 2023 was sustained and improved
upon in 2024. The motor portfolio performance was excellent but unlikely to be repeated in
the short term. The motor net combined ratio in 2024 was 85.0%, a further improvement on
the 90.2% reported in 2023.    This was the result of a combination of factors including a
disciplined underwriting approach, the tail effect of the price correction initiated in 2023, a
reduction in claims and frequency, a relatively contained average claim cost and an unusual
low incident of large claims. Particularly the latter left a significant positive impact compared
to normal experience. As can be appreciated, some of these factors are not within the
Company’s control. Having said this, a healthy motor portfolio is critical for the sustained
profitability of our Company. Therefore, we continue investing in data analysis tools that
help us to achieve this objective.
vii
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
President & Chief Executive Officer’s Statement - continued
General Business - continued
On the other hand, the Health business and other classes of business registered a deterioration
in the respective net combined ratio compared to the previous year from 87.6% and 72.2% to
89.8% and 87.1% respectively. The health portfolio experienced a higher loss ratio and lower
premium compared to a year earlier. Under other classes, we saw general deterioration in the
various classes. Of particular mention, Marine hull given that the combined ratio was above
100% following the impact of some large losses.
This highlights the resilience derived from our business model which is based on
diversification across various classes of business. This allows us to mitigate negative
movements in specific asset classes and hence reducing the volatility in our balance sheet.
Finance Income
Investment income was €2.6 million an increase over the €2.0 million reported in the
previous period. While the return from the investment portfolio was lower than in 2023, the
higher dividends from Group companies more than offset this reduction.
Capital Management
A sustainable profitable business enables us to generate internal capital for investment
purposes and to finance business growth. A prudent but consistent dividend policy is also key
in ensuring adequate capital resources. This together with the investment and risk
management policy shape to a great degree the risk profile of the Company. Within the risk
management tool kit, the reinsurance aspect continues to be one of the main levers in
maintaining the Company risk profile within the established risk appetite. This means that
during normal years we forego a certain level of profitability to ensure we are better protected
in case of less frequent but more severe events or what we refer to as catastrophic events. The
risk profile and solvency position of an insurance company is measured by the solvency ratio.
Once again, the Company continues to maintain a solvency ratio significantly above the
regulatory requirements.
Long Term Business
MMSV offers a wide range of protection, savings, investments and retirement solutions
addressing the diverse needs of individual clients, companies as well as other organisations.
This business performance is influenced by both internal and external factors. The internal
factors are those normally considered within management control. These depend on the
business model of the company, its strategy and effective and efficient execution. On the
other hand, the external factors include the health of the local economy, the performance of
global capital markets and Central banks’ monetary policy. These elements influence the
demand and purchasing capacity of the consumer, the investors’ appetite and sentiment and
the competitive landscape.
MAPFRE MSV Life registered a profit before tax of €15.0 million for the year ended 31
December 2024, compared to a profit of €14.6 million registered for the previous year. Profit
after tax is at €11.0 million, compared to a €9.6 million for the previous year.
viii
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
President & Chief Executive Officer’s Statement - continued
Long Term Business - continued
These results are underpinned by a positive contribution both from the insurance activities
and financial income.
In terms of the insurance activities, the release of the Contractual Service Margin (CSM)
remains the main determinant of reported profitability. Most of the release in CSM relates to
business written in prior years. New profitable business being written adds to the stock of
CSM for future release. Thus, normally, in life insurance, as long as business written is
profitable, a lower volatility in insurance performance from one year to the next is observed.
During 2024, the CSM release represented  €10.8 million (2023:  €9.8 million).
Total business written for financial year 2024 totalled €205.8 million, an increase of 2.3%
over the prior year. Single premium business was marginally better than 2023 as demand for
With-profits business improved. On the other hand, regular business continued to perform
well with strong demand for life protection business and sustained pension business. The
strong local economy performance and the prevailing high levels of liquidity in the economy
remain supportive for savings and investment products. 
Net claims incurred decreased to €249.0 million through the year compared to a prior year
€261.6 million, largely as a result of a decline in maturing contracts. A proportion of these
maturing contracts were subsequently re-invested in new medium to long-term contracts.
Total assets increased by 1.6% to €2,357.2 million by the end of 2024.
Total shareholders’ funds at the close of 2024 amounted to €174.3 million (2023: €165.4
million), an increase of 5.4% over the previous year.
The MMSV With-Profits fund Assets Under management remained practically at the same
level when compared to previous year. The MMSV With-Profits fund closed at €1.86 billion
as at 31 December 2024 (2023: €1.91 billion). The appreciation in asset values and the
income generated almost completely offset the impact of the net funds outflow due to
maturing policies. Over the past year, we continued to see increased debt issuance,
particularly in Malta Government stock issues. This heightened debt issuances coupled with
time deposits continue to compete directly with the With-Profits product offering.
The With-Profits Fund registered a total investment gain of €81.2 million generating a
positive return of 4.3%. The investment return was lower than in 2023, which had amounted
to €165.8 million following the steep fall in mainstream asset classes in 2022. While all asset
classes, contributed positively to the overall investment return, their performance varied
significantly. Equities outperformed fixed income assets, while even with the equity space
significant diversion in performance could be observed with US equities outperforming
European equities with growth outperforming value stocks.
ix
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
President & Chief Executive Officer’s Statement - continued
Long Term Business - continued
The investment strategy of the MMSV’s With-Profits fund is to hold a diversified range of
quality assets, spread across different geographies and currencies to mitigate market and
concentration risk. This asset diversification together with the robust investment management
process, the expertise of the asset managers engaged, and the Company’s track record of
investment management continue to be fundamental in managing policyholders’ assets in this
challenging and ever more volatile investments market environment.
While the demand for With-Profits single premium contracts remained lower when compared
to previous years, though mainly in line with this year expectation, sustained demand was
registered for Unit Linked single premium products. The launch of two short-term, capital
and income guaranteed Unit-Linked products, in the first quarter of 2024, was well received
by the retail investors.
An increase over last year was registered in terms of Life protection business written . This
line of business benefitted from a robust mortgage market since locally demand for life
protection continues to be strongly correlated with the demand for home loans.
Unfortunately, this highlights, that the need to have life protection as a basic element of
financial planning remains underappreciated. Promoting the importance of having adequate
levels of insurance is also part of our responsibility to build more financially secure and
resilient communities.
Regular savings business remains a core component of our business strategy. Through our
regular savings products we aim to serve the need of the broader market through long-term,
accessible, flexible and efficient solutions. While pensions savings is seen as a growth area,
promoting savings for retirement is also an obligation and responsibility. We want to support
our future generations of pensioners in building and maintaining their financial wellbeing and
aspirations. While we have continued to see demand for retirement products the level of
market penetration remains well below European averages. In this respect the latest
government measures announced in the budget are welcome in terms of the pensions
developments in the area of voluntary pensions occupational schemes (VOPS).
Statement of Financial Position
The group's total assets increased by 1.7% and totaled €2.5 billion at year end. As highlighted
previously, The MMSV With-Profits fund’s Assets Under Management (AUM) at €1.9
billion as at 31 December 2024 represent a significant portion of the total assets. The
reduction in associated undertakings reflects the divestment of MMSV’s With-Profit fund
holding in Tigne Mall plc. On the other hand, the increase in cash and cash equivalent
represents the tactical With-Profits fund investment positioning at year end.
On the liabilities side, 98.0% of the balance pertains to Insurance, investment and reinsurance
contracts liabilities. MMSV’s Insurance contract liabilities decreased as With-profits policy
maturities outweighed new fund flows into the With-Profits fund. Investment contract
liabilities continued to increase as further unit linked products were issued in the year under
review. MMS’s insurance contracts liabilities remained practically flat compared to the
previous year.
x
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
President & Chief Executive Officer’s Statement - continued
Statement of Financial Position - continued
Total equity increased by €12.7 million or 7.4% including the minority with the profit for the
year partly mitigated by the dividends paid.
Dividend Recommendation
The board of directors will be proposing for shareholders’ approval the payment of a net
dividend of €0.052174 per share. The Company's payout will be 67.4% of this year’s profit
after tax of the Company.
While the Board of Directors is committed to provide an adequate return to its shareholders
on their invested capital,  the dividend recommendation makes consideration of the future
capital needs of the Company and the need to maintain sufficient capital buffers to be able to
withstand any negative market shocks.
Our People
Our people are our biggest asset, and we are committed to retaining our talent by driving our
comprehensive people agenda. This year, we have focused on several key areas to support
and develop our workforce.
Training and Development: Training has been a cornerstone of our people agenda. We have
placed significant emphasis on leveraging group learning resources to enhance the skills and
knowledge of our employees. Our investment in a robust leadership program has been pivotal
in driving transformation within the organization, preparing our leaders to navigate future
challenges effectively.
Health and Well-being: We recognize the importance of our employees' physical and mental
health. Throughout the year, we have continued to invest in initiatives that promote well-
being, ensuring our people have access to the resources and support they need to thrive both
personally and professionally.
Equality and Inclusion: We are proud to have achieved the NCPE Equal Pay Mark and the
FHRD HR Quality Mark, reflecting our commitment to equality and inclusion in the
workplace. These accolades underscore our dedication to providing a fair and supportive
environment for all employees.
Employee Benefits: To further demonstrate our commitment to our people, we have signed a
generous collective agreement for the next three years. This agreement ensures that our
employees receive the best benefits, reinforcing our position as the employer of choice. By
offering competitive compensation and comprehensive benefits, we aim to attract and retain
top talent in the industry.
xi
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
President & Chief Executive Officer’s Statement - continued
Our People
Prioritizing our people, investing in their development, and promoting a healthy, inclusive
work environment have been instrumental in driving our success. We remain dedicated to
fostering a culture where our employees feel valued, supported, and empowered to achieve
their full potential and be the best version of themselves.
Our Contribution to our community
We understand that we have a social responsibility towards the society we form part. As a
Group we are committed to bring about positive change and to support the advancement of
our society. During the year, we supported various organizations in their respective mission.
Sometimes this support takes the form of financial assistance, to making our premises
available to upcoming artists or educational events. We are very proud that through our
initiatives we manage to reach many noble causes ranging from philanthropy to arts, culture,
education and the environment. However, I would like to make a special mention to the
volunteering activities our staff and their families participated in during the year. In 2024, our
employees participated in 13 activities. For this I am very grateful and thankful. This is also a
reflection of the values we embrace at MAPFRE.
I cannot fail not to mention, Fundación MAPFRE which continues to be actively engaged in
Malta. During 2024, Fundación MAPFRE continued its activities on the "Street Smart
Campaign" promoting road safety among school children. The primary goal of the campaign
is to raise awareness about road safety for all road users, including pedestrians, cyclists,
drivers, and passengers, emphasizing the importance of each person's role. The campaign also
consisted of workshops for 6th Form students in collaboration with Doctors For Road Safety
(D4RS). Additionally, Fundación MAPFRE has also signed a new agreement for the
"Logging Off" campaign, addressing internet addiction among school children. The
campaign will be conducted in partnership with the Malta Trust Foundation.
As MAPFRE, we strongly believe in a more inclusive, equitable and sustainable world. We
believe that we have a responsibility to safeguard the right of future generations to enjoy a
world where people are not judged or disadvantaged because of their religious creed, race,
sex or sexual orientation. A world where future generations can enjoy a clean, healthy and
safe environment. In this regard, we continue to embrace policies which promote these values
and goals. Our remuneration policy also includes sustainability objectives. We continue to
introduce measures which aim to lower our carbon footprint, promote an inclusive and safe
workplace which promotes opportunity based on talent and values. Our workforce is diverse
and boasts over twenty different nationalities with an almost equal gender mix. Our senior
management benefits from a strong and talented female representation. We are very satisfied
with the results we are achieving in terms of carbon footprint emission, gender pay equality
and ESG aligned investments.
xii
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
President & Chief Executive Officer’s Statement - continued
Looking forward
At the end of 2024, we closed the strategic plan for the period 2022-2024. The level of
execution of this plan was satisfactory considering also the need to have a flexible and
dynamic approach given the challenges and uncertainty which characterized this period.
Looking ahead, we have defined a new strategic plan for the period 2025-2027. This new
strategic cycle will build on the foundations laid in prior years. The new plan has four key
pillars namely growth and profitability, efficiency and productivity, transformation and
culture and sustainability. We believe that by driving this agenda, we will continue to create
value to our shareholders, meet the evolving needs of our customers through an enhanced
customer experience, strengthen our rewarding business partners relationships and provide
great growth opportunities to our talent while contributing to a better, fairer and more
inclusive society through our sustainability commitment. 
Signed by Etienne Sciberras (President & CEO) on 25 March 2025
1
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Directors’ Report
The Directors present their annual report for the year ended 31 December 2024.
Principal activities
The principal activities of the Group consist of the business of insurance. The Group is
licensed to carry on general and long-term business. The Group is also authorised to provide
insurance management services.
Review of business
The Company
MAPFRE Middlesea p.l.c. (the ‘Company’) registered a profit before tax of €10.5 million
during the financial year ended 31 December 2024 (“FY 2024”) compared to the €9.9 million
registered in the previous financial year (“FY 2023”) with post-tax profits of €7.1 million,
compared to €6.7 million in FY 2023. 
Premiums written by the Company reached €103.6 million (2023: €95.7 million), an 8.3% 
increase over FY2023, with growth in all classes of business but notably in Motor, Health and
Property. MAPFRE Middlesea p.l.c. remained the leader of the non-life market although the
Company’s market share reduced marginally from the previous year, following the receipt of
provisional market data collated by the Insurance Association Malta, as the market registered
a growth above that of  the Company's.
The insurance service result increased to €12.3 million from €12.2 million of FY 2023, a
1.3% growth.  Insurance revenue grew by 7.6% reflecting the growth in premium written.
Claims frequency improved in Motor with reported current year occurring average claim cost
marginally lower than in  the previous year, whilst Health registered a deterioration in loss
ratio through increases in both frequency and severity.
The Company’s net investment return amounted to €2.6 million compared to the €2.0 million 
in FY 2023 as a result of a net dividend of €1.0 million received from MAPFRE MSV Life
p.l.c. with no comparative in the previous year. Fair value movements on the fair value
through profit or loss portfolio though positive were significantly lower than in FY 2023
which had seen the market recovering from the losses incurred in the prior year. Revaluation
of investment property held by the Company rendered a marginal loss of €0.2 million against
a marginal gain of €0.1 million for 2023.
The Shareholder’s Funds of the Company at €84.4 million saw an increase of 3.4% during
FY 2024 resulting from the profit for the year exceeding the payment of dividend for FY
2023 and positive investment value movements in equity. Net Asset Value per share as at 31
December 2024 amounted to €0.92.
MAPFRE Middlesea p.l.c.’s solvency position remained strong with net assets remaining
adequately above the capital requirements under Solvency II with the cover being reported in
the Solvency and Financial Condition Report (SFCR) to be published by the Company later
in the year. 
2
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Directors’ Report - continued
Review of business - continued
MAPFRE MSV Life p.l.c.
MAPFRE MSV Life p.l.c. (“MAPFRE MSV Life” and “MMSV”) registered a profit before
tax of €15.0 million for FY 2024, as compared to the €14.6 million registered for the previous
year. Profit after tax is recorded at €11.0 million, compared to a €9.6 million in the previous
year.
Total business written for financial year 2024 totaled €205.8 million, an increase of 2.3%
over the prior year. While the demand for With-Profits single premium contracts remained
lower when compared to previous years, though mainly in line with this year expectation,
sustained demand was registered for Unit Linked single premium products. The launch of
two short-term, capital and income guaranteed Unit-Linked products, in the first quarter of
2024, was well received by the retail investors.
The MMSV With-Profits fund closed at €1.9 billion as at 31 December 2024 (2023: €1.9
billion) registering a total investment gain of €81.2 million generating a positive return of
4.3%.  The investment return was lower than in 2023, which had amounted to €165.8 million
following the steep fall in mainstream asset classes in 2022.
Total assets increased by 1.6% to stand at €2,357.2 million by the end of 2024.
Total shareholders’ funds at the close of 2024 amounted to €174.3 million (2023: €165.4
million), an increase of 5.4% over the previous year.
Other subsidiaries
The other subsidiaries within the Group, though not significant to the size of the Group, had a
mixed contribution to the results of the year.
During the year BEE Insurance Management Limited (‘BEE’) and its subsidiary Euro Med
Risk Solutions Limited ("EuroMed") which offer Insurance and Non-Insurance management
services transferred their third-party clients to another local operator with BEE remaining
servicing the Group’s insurance entities in the Information Technology sphere. A combined
profit of €0.5 million was registered compared to the €0.2 million in the comparative period.
EuroMed has surrendered its Corporate Service Provider (CSP) license in January 2025, the
first step towards the liquidation of the company.
Church Wharf Properties Limited holds a property within the Regeneration of the Grand
Harbour Area. A negligible loss was recorded in the year, compared to a loss of €0.4 million
registered at the end of 2023. The directors continue to monitor the evolution of this project
which gives a potential future increase in value of this investment.
3
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Directors’ Report - continued
Review of business - continued
The Group
The Group registered a profit before tax of €24.8 million in FY 2024 compared to €24.0
million achieved in FY 2023. Profit after tax for FY 2024 closed at €18.0 million as
compared to the €15.9 million achieved in FY 2023. Group business written reaching €309.5
million saw an increase of 4.2% against that registered in FY 2023, with both insurance
companies remaining leaders in their respective markets.
MAPFRE Middlesea’s Group capital and reserves attributable to shareholders at 31
December 2024 amounted to €96.3 million (2023: €88.2 million) on a consolidated basis with
a net asset value per share of €1.05 as at 31 December 2024 mainly as the result for the year
outweighed the payment of dividend by MAPFRE Middlesea and MAPFRE MSV Life.
A review of the business of the Group for the year ended 31 December 2024 and an
indication of future developments are provided in the Chairman’s Statement and the President 
and CEO Statement, which can be found in the front section of this Annual Report.
Whilst as a Group we have an important role to provide our customers with prosperity and
peace of mind, we acknowledge that we have a wider commitment to society by also
supporting those who are not our customers. Over the years we have developed a Corporate
Social Responsibility (CSR) policy framework which encompasses shareholders, the
environment, people, communities and customers. Through our CSR programme we
cooperate with and assist a number of public and private institutions, NGOs, museums,
foundations and associations who share similar goals and values as us.
Sustainability is also very high in our agenda. In line with the MAPFRE Group's
Sustainability Plan, the Group is committed to be carbon neutral by the end of 2030. To this
effect a number of initiatives are being implemented and more will be formulated as we move
towards this important goal. Good progress is also being registered in terms of the
environment, social and governance (ESG) dimensions.
4
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Directors’ Report - continued
Principal Risks and Uncertainties
The Group’s principal risks and uncertainties are further disclosed in Note 4 dealing with
management of risk as supplemented by Note 3 relating to the use of accounting estimates
and judgements in applying accounting policies, and Note 24 on insurance contract liabilities,
reinsurance contract assets and investment contracts liabilities covering assumptions
underlying their valuation.
Results and dividends
The consolidated profit or loss account is set out on page 39.  A gross dividend in respect of
year ended 31 December 2024 of €0.080268 per share amounting to a total dividend of
€7,384,615 is to be proposed by the Directors at the forthcoming annual general meeting. 
This is equivalent to a net dividend of €0.052174 per share amounting to a total net dividend
of €4,800,000 (2023: €4,500,000).
Directors
The Directors of the Company who held office during the period under review were:
Martin Galea  
Antoinette Caruana
Gordon Cordina
Jose Maria del Pozo
Jose-Luis Jimenez
Eduardo Perez de Lema (appointed from 1 January 2024)
Etienne Sciberras
Godfrey Swain
Paul Testaferrata Moroni Viani
In accordance with the Articles of Association of the Company, all Directors retire from
office at the Annual General Meeting and are eligible for re-election or re-appointment.
Further information is given in the Statement of Corporate Governance.
5
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Directors’ Report - continued
Statement of Directors’ responsibilities for the financial statements
The Directors are required by the Insurance Business Act, 1998 and the Companies Act, 1995
to prepare financial statements which give a true and fair view of the state of affairs of the
Group and the Company as at the end of each reporting period and of the profit or loss for
that period.
In preparing the financial statements, the Directors are responsible for:
• ensuring that the financial statements have been drawn up in accordance with
International Financial Reporting Standards as adopted by the EU;
• selecting and applying appropriate accounting policies;
• making accounting estimates that are reasonable in the circumstances;
• ensuring that the financial statements are prepared on the going concern basis unless it
is inappropriate to presume that the Group and the Company will continue in business
as a going concern
The Directors are also responsible for designing, implementing and maintaining internal
control as the Directors determine is necessary to enable the preparation of financial
statements that are free from material misstatement, whether due to fraud or error, and that
comply with the Insurance Business Act, 1998 and the Companies Act, 1995.  They are also
responsible for safeguarding the assets of the Group and the parent Company and hence for
taking reasonable steps for the prevention and detection of fraud and other irregularities.
The financial statements of MAPFRE Middlesea p.l.c. for the year ended 31 December 2024
are included in the Annual Report 2024, which is published in hard-copy printed form and
also made available on the Company’s website. The Directors are responsible for the
maintenance and integrity of the Annual Report on the website in view of their responsibility
for the controls over, and the security of, the website. Access to information published on the
Company’s website is available in other countries and jurisdictions, where legislation
governing the preparation and dissemination of financial statements may differ from
requirements or practice in Malta.
The directors confirm that, to the best of their knowledge:
• the financial statements give a true and fair view of the financial position of the Group
and Company as at 31 December 2024, and of its financial performance and its cash
flows for the year then ended in accordance with International Financial Reporting
Standards as adopted by the European Union on the basis explained in Note 1 to the
financial statements; and
• the Annual Report includes a fair review of the development and performance of the
business and the position of the Group and Company, together with additional
information of the principal risks and uncertainties that the Group and Company face.
6
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Directors’ Report - continued
Information pursuant to Capital Markets Rule 5.64
The Company has an authorised share capital of €31,500,000 divided into 150,000,000
ordinary shares with a nominal value of €0.21 each.  The issued share capital of the Company
is €19,320,000 divided into 92,000,000 ordinary shares of €0.21 each. The issued shares of
the Company consist of one class of ordinary shares with equal voting rights attached.
The directors confirm that as at 31 December 2024, only MAPFRE Internacional (55.83%)
and Bank of Valletta p.l.c. (31.08%) held a shareholding in excess of 5% of the total issued
share capital.
Pursuant to the Company’s Articles of Association, the appointment of Directors to the Board
is reserved exclusively to the Company’s shareholders (in line also with general and
commonly accepted practice in Malta).  Shareholders with 11% or more of the shares in issue
are entitled to appoint one director for every 11% holding, whilst the other shareholders are
entitled to appoint the remaining Board members at the Annual General Meeting in
accordance with the provisions of the Articles of Association. The Chairman shall be
appointed by the Board of Directors.
The rules governing the appointment and replacement of the Company’s directors are
contained in Articles 93 to 102 of the Company’s Articles of Association.
The Directors can only issue shares following an extraordinary resolution passed in the
General Meeting. This and other powers vested in the Company’s Directors are contained in
Articles 84 to 90 of the Company’s Articles of Association.
The Memorandum and Articles of the Company may be amended by means of an
extraordinary resolution of the Company during general meetings.
There are no agreements between the Company and the Directors on the Company’s Board or
employees providing for compensation on termination or cessation of their office for any
reason whatsoever.
It is hereby declared that as at 31 December 2024, information required under Capital
Markets Rules 5.64.2, 5.64.4, 5.64.5, 5.64.6, 5.64.7 and 5.64.10 is not applicable to the
Company.
7
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Directors’ Report - continued
Going concern
The Directors, as required by Capital Markets Rule 5.62 have considered the Group’s and
Company’s operational performance, the statement of financial position as at year end as well
as the business plans for the coming year, and declare that they have a reasonable expectation
that the Group and the Company have adequate resources to continue in operational existence
for the foreseeable future. For this reason, in preparing the financial statements, the Group
and Company are in a position to continue operating as a going concern for the foreseeable
future.
Auditors
The auditors, KPMG, have indicated their willingness to continue in office and a resolution
for their re-appointment will be proposed at the Annual General Meeting.
Information pursuant to Capital Markets Rule 5.70
There were no material contracts in relation to which a Director of the Company was directly
or indirectly interested.
Information pursuant to Capital Markets Rule 5.70.2
The Company Secretary is Dr Daphne Sims Dodebier and the registered office is Middle Sea
House, Floriana, Malta.
Information pursuant to Capital Markets Rule 5.68
We, the undersigned, declare that to the best of our knowledge, the financial statements
prepared in accordance with the requirements of International Financial Reporting Standards
as adopted by the EU, give a true and fair view of the assets, liabilities, financial position and
profit or loss of the Company and its subsidiaries and that this report includes a fair review of
the development and performance of the business and the position of the Company and its
subsidiaries, included in the consolidation taken as a whole, together with a description of the
principal risks and uncertainties that they face.
Signed on behalf of the Company’s Board of Directors on 25 March 2025 by Martin Galea
(Chairman) and Godfrey Swain (Director) as per the Directors Declaration on ESEF Annual
Financial Report submitted in conjunction with the Annual Report and Accounts 2024.
8
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Corporate Governance Statement
1. Introduction
In accordance with Rule 5.94 of the Capital Markets Rules, an issuer whose securities are
admitted to trading on the Malta Stock Exchange should endeavour to adopt the principles as
promulgated within Appendix 5.1 of the Capital Markets Rules entitled The Code of
Principles of Good Corporate Governance (‘the Code’). Moreover, the issuer is obliged to
prepare a report disclosing both compliance and non-compliance with the said principles and
the Company’s auditors are to include a report on the Corporate Governance Statement in the
Annual Financial Report of the Company.
Although the Board of Directors (‘the Board’) of MAPFRE Middlesea plc (the ‘Company’ or
‘MMS’) notes that compliance with the said Code is not mandatory, it however
acknowledges that the principles are designed to serve as a guide for the Board and the
Company’s Management in the pursuit of objectives that are in the interests of both the
Company and its stakeholders. The Board, therefore, firmly upholds the principles therein
contained as guaranteeing the standards of accountability, transparency and integrity inherent
to good Corporate governance. The Board continues to strive to adhere to the Code as well as
to maintain the highest standards of disclosure both in relation to compliance with the code as
well as in relation to explaining the rationale behind the instances of non-compliance. 
As shall be evidenced by the information set out in this Statement and that contained in the
Remuneration Statement and the Report of the Remuneration Committee to the Shareholders,
the Company believes that it has, save as otherwise indicated herein, not only complied with
the provisions of the Code throughout the accounting period under review but also acted in
accordance with the spirit of the Code.  In the Non-Compliance Section, the Board then
outlines the limited instances where there has been a departure from, or non-application of,
the principles as contained within the Code and the reasons therefore, in accordance with the
same Code.
2. Compliance with the Code
Principle 1 – The Board
Good business, well done, is a force for good in society. Within this context, the Board’s role
and responsibility is to lead the Company, to discuss and approve the strategy for long-term
sustainable value and to exercise good oversight, challenging the Management and Internal
Control Functions where necessary to this end. 
As at 31 December 2024 the Board was composed of a non-executive Chairman and eight
non-executive Directors. The Directors, appointed in terms of the Memorandum and Articles
of Association of the Company, are all competent, trustworthy and solvent individuals and
thus fit and proper to direct the business of the Company. The maximum number of Directors
pursuant to the Memorandum and Articles of Association is ten. Martin Galea was re-
appointed as a non-executive Chairman during the Board meeting held on the 30 April 2024,
which followed the Annual General Meeting (AGM) held on the same day.
9
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Corporate Governance Statement - continued
2. Compliance with the Code - continued
Principle 1 – The Board - continued
During the said AGM the two institutional shareholders re-appointed the retiring Directors 
Gordon Cordina, Martin Galea, Jose-Luis Jimenez, Jose Maria del Pozo, Etienne Sciberras
and Godfrey Swain, while the other shareholders re-appointed the retiring Directors
Antoinette Caruana and Paul Testaferrata Moroni Viani during the election for directors.
Eduardo Perez de Lema was newly appointed by the shareholder MAPFRE Internacional
S.A. in order to bring the total number of Directors to nine. 
All of the Directors of the Company are approved by the Regulator further to a detailed
Personal Questionnaire process as being fit and proper to direct the business of the Company
and are deemed to conduct themselves with honesty, competence and integrity. Both on an
individual level and collectively, the Members of the Board possess the necessary skills and
experience to make effective contribution to the leadership and decision-making processes of
the Company as reflected within the Company’s strategy and policies. Moreover, the Board
exercises prudent and effective controls in order to achieve both short and long-term
sustainability of the business and assesses the compatibility of the MAPFRE Group policies
with local legal and regulatory requirements, adapting them where appropriate.
Effective boards ensure that the Company operates with a clear sense of purpose and
collective vision and the Board liaises closely with the President and Chief Executive Officer
(‘CEO’) of the Company in a consistent and continuing manner in order to ensure that the
Board receives timely and complete information in relation to the business and performance
of the Company. This enables the Board to maintain effective oversight of the decision-
making process and to exercise the aforementioned controls. Javier Moreno, appointed CEO
on the 31 March 2021, continued to hold the position of CEO throughout 2024 although
submitting his resignation as at 31 December 2024 in order to take up new responsibilities
within the MAPFRE Group. His successor as from 1 January 2025 is the current Director
Etienne Sciberras. 
As was customary in previous years, at the Board Meeting held subsequent to the AGM, the
Board delegated specific responsibilities to a number of Board Committees, namely the Audit
Committee, the Risk and Compliance Committee, the Investments Committee and the
Remuneration Committee, each of which operated under their respective formal terms of
reference as approved by the Board.
Further detail in relation to the Committees and the responsibilities of the Board is provided
under Principles 4 and 5 of this Statement.
10
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Corporate Governance Statement - continued
2. Compliance with the Code - continued
Principle 2 – Chairman and CEO
The positions of Chairman and CEO were held by different individuals throughout 2024 with
a clear demarcation between the leading of the Board by the former and the CEO’s
management of the business of the Company, despite the strong cooperation between the two.
The Chairman is independent and is responsible for the overall effectiveness of the Board,
promoting open debate and facilitating constructive discussion. Through the Office of the
Company Secretary, the Chairman sets the Board agenda and ensures that all the Board’s
decisions are supported by comprehensive and timely information. The Chairman also
ensures that the Board discusses the pertinent issues with adequate depth, that the opinions of
all the Directors are taken into account and  encourages active engagement by all the
members of the Board to constructively challenge Management where necessary and
generally promote the effective functioning of the Board.
The CEO, on the other hand, is charged with the leadership of the Management team with the
main role and responsibility of managing the Company’s business in line with its Strategy
and informing and making recommendations to the Board. Within this context, 2024 was the
third and final year of the Company's three-year Strategic Plan as developed by Management,
discussed with the Chairman and approved by the Board. A new three-year Strategic Plan
then started to be formulated in Q4 2024 for the period 2025 to 2027. This was extensively
discussed during a Board Briefing meeting held in October 2024, as detailed further below.
Within the parameters of the Board-approved Strategy, the CEO develops and drives
performance and leads the decisions on all matters affecting the operations, technical
performance and stakeholders of the business save for those matters specifically reserved to
the Board or its' delegated Committees. The Company also has Technical Committees
composed of senior members of the relative technical areas that hold regular meetings and a
Management Committee, bringing together the Chief Officers within MMS under the
Chairmanship of the CEO on a monthly basis.
The positions of the Chairman of the Board and CEO are distinguished accordingly within
the Terms of Reference of the Board of Directors and in practice, there is also a clear division
of responsibility between the former who oversees the Board and the latter's responsibility in
managing the daily business of the Company. Thus the positions remain completely
independent from one another to avoid concentration of authority and power within a single
individual, to differentiate leadership from the running of the business and to maintain clear
lines of accountability and responsibility. 
Principle 3 – Composition of the Board
The Board considers and history has shown, that the number of Members as stipulated in the
Memorandum and Articles of the Company are appropriate relative to the size of the
Company and its operations. 
11
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Corporate Governance Statement - continued
2.Compliance with the Code - continued
Principle 3 – Composition of the Board - continued
The combined and varied knowledge, experience and skills of the Board members, including
a broad knowledge of the business of the Company and awareness of statutory and regulatory
requirements, provide a balance of competences, as required, and add value both to the
functioning of the Board and to the direction given to the Company. In this regard the
Company remains committed to non-discrimination, not least in its Boardroom, promoting a
diverse and inclusive culture where Directors’ views are heard, concerns are attended to and
the environment does not tolerate bias, discrimination or harassment of any kind.
The Company’s Articles of Association determine the composition of the Board. The
appointment of Directors to the Board is accordingly reserved exclusively to the Company’s
shareholders, except in so far as an appointment may be made to fill a casual vacancy. All
Directors, as well as some key officials, are required to fulfil the fit and proper regime
prescribed by the Malta Financial Services Authority (‘MFSA’) in line with standard
regulatory due diligence procedures. Moreover, all Directors are required to apply the
necessary time and attention to their duties and limit the number of directorships held in other
companies, thereby also ensuring the proper performance of their functions.
In 2024 the Board was composed exclusively of non-executive Directors, of which eight
were male and one was female. Although not a Director of MMS, the CEO is invited to
attend Board meetings with a view to ensuring a full understanding and appreciation of the
Company's policies and strategy and to provide direct input as may be required for the
Board’s deliberations. In addition, certain members of Senior Management are invited to
report to the Board as and when required, thereby securing effective information flows as
well as fostering a culture of continuous dialogue between the Board and the Company’s
Management. 
As at the date of this review, the Board consists of five independent Directors (including the
Chairman) and four non-independent Directors (as indicated on page 14 of the Annual
Report) as defined by the Code.
In determining the independence or otherwise of its Directors, the Board considers, amongst
others, the principles relating to independence of directors contained in the Code, the
Company’s own policies, as well as general principles of good corporate governance.
In relation to Code Provision 3.2.5 specifically the Code requires that the Board states its
reasons if it determines that a director is independent notwithstanding inter alia if the
director: “has served on the board for more than twelve consecutive years”.
12
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Corporate Governance Statement - continued
2.Compliance with the Code - continued
Principle 3 – Composition of the Board - continued
It is noted in this regard that Paul Testaferrata Moroni Viani (as from April 2022) has served
on the Board for a period of more than twelve consecutive years. The Company however,
retains that Paul Testaferrata Moroni Viani has sufficient experience and maturity to remain
independent of character and objective in his judgment at all times notwithstanding the lapse
of the recommended twelve years. Similarly, the Board Chairman Martin Galea (as from his
re-appointment in April 2024) has also served on the Company's Board for a period of more
than twelve years but the Company is of the opinion that his knowledge and experience of the
business remain invaluable while further transition at this stage, given the appointment of
new CEOs for both the Company and its main subsidiary as from 1 January 2025, would not
be of benefit to any of the stakeholders. Martin Galea is moreover highly competent and
astute and will undoubtedly remain entirely unbiased in his judgement despite his service
over the years, continuing to act in accordance with the highest principles of governance. 
In terms of Code provision 3.4 each non-executive director has moreover submitted his / her
confirmation in writing that he / she undertakes:
i. to maintain in all circumstances his independence of analysis, decision and action;
ii. not to seek or accept any unreasonable advantages that could be considered as
compromising his / her independence; and
iii. to clearly express his / her opposition in the event that he /she finds that a decision of
the Board may harm the Company.
Principle 4 – The Responsibilities of the Board
The Board acknowledges its statutory mandate to establish and maintain corporate
governance practices that provide clear lines of accountability and responsibility to support
effective decision-making and to monitor the implementation thereof. The Board fulfils this
mandate and discharges its responsibilities through the execution of the four basic principles
of corporate governance namely, accountability, monitoring, strategy formulation and policy
development.
The Board continually and consistently reviews all the different aspects of the Company
within the parameters of the relevant laws, regulations and codes of best practice. It seeks to
ensure adherence to high ethical standards whilst taking into account all stakeholders’
interests, maintaining an effective dialogue with all stakeholders, monitoring the application
of management policies and motivating Company Management.
Principle 5 – Board Meetings
The Board of Directors sets and supervises the strategy and the policies of the Company, both
of which are discussed on a regular basis, and the Board's agenda as well as its' business are
managed in such a way so as to ensure effective supervision of the Company’s operations in
accordance therewith.
13
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Corporate Governance Statement - continued
2. Compliance with the Code - continued
Principle 5 – Board Meetings - continued
The Board meets as often as required to discharge its duties effectively but no less than five
times a year. As aforementioned, specific members of the Management team are invited to
attend Board meetings from time to time, to update and provide the Directors with a direct
report relative to the items on the agenda. A detailed review of the Company's Management
Accounts and Key Performance Indicators (as promulgated by the MAPFRE Group in line
with industry norms) is carried out at every Board Meeting and the background information
on various subjects provided, particularly those requiring the approval of the Board. An
update is also provided at every Board Meeting in terms of the various Company projects and
accomplishments by Area, as well as on regulatory and other relevant events amongst others.
Apart from setting the strategy and collectively promoting the success of the Company, the
Board is actively involved in monitoring progress against the set Budget and Strategy and in
approving material or significant transactions.
The Chairman in conjunction with the Company Secretary ensures that all relevant issues are
on the Board agenda and supported by relevant and complete information.  The agenda for
each meeting seeks to strike a balance between long-term strategic objectives and shorter-
term performance matters. 
Notices of the dates of forthcoming Board meetings are circulated well in advance of the
relative meetings and meeting packs containing all relevant information, including the
minutes of the previous Board Meeting, are circulated to the Directors ahead of each meeting
by the Company Secretary. In issuing these communications, regard is had to the timing in
order to be sure to allow sufficient opportunity for the Directors to review the information
and prepare for the next Board or Committee meeting as scheduled within the annual meeting 
calendar.
Minutes are taken of each and every Board meeting faithfully recording attendance, matters
discussed, action points and resolutions. These minutes are subsequently made available to
all Directors for review, prior to sign off by the Chairman.
Decisions of the Board are taken by majority of those present subject to the Chairman’s
casting vote as may be necessary.
14
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Corporate Governance Statement - continued
2. Compliance with the Code - continued
Principle 5 – Board Meetings - continued
During financial year 2024, the Board of Directors of the Company held seven Board
Meetings which were attended as per below.
Martin Galea (Chairman) (NED, I)7
Antoinette Caruana (NED, I)6
Gordon Cordina (NED , I)5
Jose Maria del Pozo (NED)6
Jose-Luis Jimenez (NED)3
Eduardo Perez de Lema (NED - appointed as from 1 January 2024)*6
Etienne Sciberras (NED)7
Godrey Swain (NED, I)6
Paul Testaferrata Moroni Viani (NED, I)6
NED – Non-executive Director
I – Independent
* With regulatory approval as from 4 June 2024;
The MMS CEO attended all the Board meetings by invitation.
Moreover, during 2024 a Board Briefing was also held in order to provide the Directors with
more detailed information on the subject matter identified as well as to allow opportunity for
deeper discussions of pertinent issues. The focal point of the Directors’ Briefing in October
was to carry out an in-depth review of the developments in the Strategic projects over the
three-year plan culminating in 2024 and to discuss the first draft of the new Strategic Plan for
the period 2025 to 2027 including the relative Budget requirements.
Principle 6 – Information and Professional Development
Although no Induction Briefing was delivered in 2024 as the only Director newly appointed
to the Company's Board had been an employee of the MAPFRE Group since 1993 and a
Board Director of MAPFRE Espana since 2019 and thus familiar with the strategy and
operations of the MAPFRE Group in Malta, this was an exception to the general rule. In all
other cases where a new Director is appointed a formal and structured induction programme
consisting in a series of presentations and meetings with members of the Management team
of the Company is conducted to enable new incumbents to familiarise themselves with the
Company’s strategy, risk appetite and operations. New Directors also receive a MAPFRE
Corporate comprehensive guide that includes, amongst others, Directors’ duties and
responsibilities.
15
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Corporate Governance Statement - continued
2. Compliance with the Code - continued
Principle 6 – Information and Professional Development - continued
During 2024 the members of the Company's Board continued to benefit from the MAPFRE
Group structured Board training and development programme including a full on-line
training schedule available for subscription covering twelve sections with a range of topics
ranging from Operational to Technical and Risk to AML matters. The key objective of the
programme is to contribute to the continued professional development of the Directors and
the Board’s collective awareness of corporate governance, solvency, insurance finance,
strategy and operations. 
Moreover, Directors are at liberty to take independent professional advice on any matter at
the Company’s expense where they deem it necessary in order to better discharge their duties
as Directors and have open access to the advice and services of the Office of the Company
Secretary and that of all other Chief Officers. The Company Secretary remains mindful at all
times of the responsibility of ensuring adherence to Company policies, Board procedures as
well as the facilitation of continual and consistent information flow within the Board and its
Committees. 
The CEO is appointed by and enjoys the full confidence of the Board and ensures that
systems are in place to cater for, amongst others, consistent and continuous support and
monitoring of Management, development and training of employees and Directors, as well as
succession planning, as required by the provisions of principle 6.4 of Appendix 5.1 of the
Capital Markets Rules. The CEO, although responsible for the recruitment and selection of
Senior Management, consults with and acts on the advice of the Remuneration Committee
and the Board generally relative to appointments and succession for Senior Management.
Training (both internal and external) of management and employees is prioritised and is
implemented through the Human Resources Department. Several training sessions, both on-
line and live, were also held on various topics during the course of 2024 including on Cyber
Security, Inclusion, Mental Health and Environmental, Social and Governance (ESG)
Awareness.
Indeed during 2024 the Company ran an intense and specialised training initiative for the
CEO, Chief Officers and Heads in conjunction with external specialists referred to as the
Transformational Leadership Programme. The Programme represented a significant
investment in the leadership team intended to boost collaboration, competence and encourage
positive transformation across the Management team with initiatives including individual and
team coaching sessions commencing in Q4 2023 and set to run over a period of eighteen
months.
16
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Corporate Governance Statement - continued
2. Compliance with the Code - continued
Principle 7 – Evaluation of the Board’s Performance
During the year under review, the Board once again undertook an evaluation of its own
performance, the Chairman’s performance and that of its Committees. The evaluation was
not conducted externally, but rather, the evaluation exercise was conducted through a Board
Effectiveness Questionnaire prepared by the Compliance Function in cooperation with the
Company Secretary and the Chairman. The outcome of the exercise was summarised into a
Report based on the replies of each individual Director that was then submitted to the
Chairman before being circulated amongst all Board members. The Report was then
discussed during an informal meeting amongst the Directors and the Company Secretary and
an action plan developed and committed to address gaps identified. 
No requirement for material changes in the governance structure or processes resulted from
this evaluation exercise, however, the emerging action points and recommendations were
implemented within 2024 as co-ordinated by the Company Secretary and overseen by the
Chairman.
Principle 8 – Committees
The activities of the Board and of the Company’s Senior Management team are additionally
supported by the Company’s Board Committees structured in such a way so as to assist in the
guiding and monitoring of particular business processes and specific governance issues. The
said Board Committees are the Audit Committee, the Risk and Compliance Committee, the
Investments Committee and the Remuneration Committee.
The Terms of Reference of all the Board Committees have been set out and approved by the
Board of Directors and by the MFSA. 
Audit Committee
The Audit Committee’s terms of reference are modelled on the recommendations of statutory
directives, the Capital Markets Rules and the principles of Corporate Governance, whilst also
reflecting the provisions of the relevant MAPFRE Group principles. The responsibilities of
the Audit Committee include the following:
• monitoring of the financial reporting process
• monitoring of the independence and effectiveness of the Company’s internal control,
internal audit and risk management systems
• monitoring of the audit of the annual and consolidated accounts
• maintenance of communication on such matters between the Board, management, the
external Auditors and the internal Auditors
• making of recommendations to the Board in relation to the appointment of the
external Auditor and the approval of the remuneration and terms of engagement of the
external Auditor following appointment by the Shareholders in general meeting
17
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Corporate Governance Statement - continued
2. Compliance with the Code - continued
Principle 8 – Committees - continued
Audit Committee - continued
• monitoring and reviewing of the external Auditor’s independence and in particular the
provision of additional services
• development and implementation of a policy on the engagement of the external
Auditor to supply non-audit services
• reviewing of actuarial reports
• management of financial risks
• analysis and endorsement of the Annual Internal Audit Plan
• arm’s length nature of related party transactions and
• oversight over the statutory audit process including the setting of the relative fees in
discussion with the external auditors in accordance with the provisions of the
Statutory Regulations governing statutory audits of public interest entities within the
European Union.
The Committee generally protects the interests of the stakeholders and the shareholders in
particular and assists Directors in ensuring the accuracy of the Company’s financial results
and reporting. It ensures that the Company’s accounting and finance function are robust and
transparent, advises the Board on financial reporting in terms of both the financial statements
and announcements relative to performance and also has oversight of the Internal Audit
Function to ensure adequate resources, independence and follow up on any pertinent audit
recommendations. 
In regard to the latter, Internal Audit is an independent appraisal function established to
examine and evaluate the activities of the Company and its subsidiaries. The Internal Auditor
reports to the Audit Committee and attends its meetings. The Internal Auditor is charged by
the Audit Committee with the conducting of business process risk-based audits aimed at
assessing the adequacy of controls and business process efficiency. The Internal Audit Area
also liaises closely with the MAPFRE Group Internal Audit Area to this end.
The Audit Committee moreover ensures co-operation between the internal and external
auditors of the Company.
Furthermore, although no such instances arose within 2024, the Audit Committee also
reviews related party transactions, considering their nature and materiality and approves them
if it deems fit, as well as overseeing the implementation of the Company’s Whistleblower
Policy. 
18
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Corporate Governance Statement - continued
2. Compliance with the Code - continued
Principle 8 – Committees - continued
Audit Committee - continued
The composition of the Company’s Audit Committee is regulated by the Capital Markets
Rules and the Malta Financial Services Authority is kept informed as to any changes in its
composition. In terms of Capital Markets Rule 5.117.3, Jose Maria del Pozo and Martin
Galea are the members of the Audit Committee with the necessary qualifications, experience
and knowledge to render them competent in accounting and auditing. Jose Maria del Pozo
having held the position of Chief Financial Officer of the MAPFRE Group since 2018 and a
consultant professor for accounting and financial analysis, while Martin Galea is qualified in
accounting and audit with years of experience in company management.
Godfrey Swain was appointed re-appointed for a second term as Chairman of the Audit
Committee by the Board of Directors in accordance with Capital Markets Rule 5.117.4 as of
30 April 2024.  Of the four Directors making up the Audit Committee, three are considered
Independent Directors in accordance with the criteria set out in Capital Markets Rule 5.119.
The Audit Committee held seven meetings during 2024. In accordance with Capital Markets
Rule 5.117.2, three out of four members are considered independent in line with the criteria
set out in Capital Markets Rule 5.119. These are Godfrey Swain, Antoinette Caruana and
Martin Galea. The Audit Committee members and relative attendance at meetings is listed
below.
Godfrey Swain (Chairman)            7
Antoinette Caruana                                                                            6
Martin Galea                                                                                      7
Jose Maria del Pozo                                                                            6
In accordance with Capital Markets Rule 5.118, the Board considers the four Audit
Committee members as having the required competence individually and jointly as a
Committee, due to their professional background and experience in the financial sector, as
well as in other sectors, including the insurance sector, at both national and international
level.
The CEO, the Chief Financial Officer and the Internal Auditor, amongst other members of
Management, attend the Audit Committee meetings by invitation. The Whistleblower
Reporting Officer reports to the Audit Committee as and when required. The external
auditors are invited to attend meetings of the Audit Committee and are entitled to convene a
meeting of the Committee if they consider that it is necessary. The Company Secretary also
acts as Secretary to the Audit Committee.
19
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Corporate Governance Statement - continued
2. Compliance with the Code - continued
Principle 8 – Committees - continued
Audit Committee - continued
The Chairperson of the Audit Committee reports to the Board at every Board meeting
providing a summary of the salient matters discussed at Committee level thus ensuring
transparency and fostering communication and continuity between the said Board Committee
and the other members of the Board.
Risk and Compliance Committee
The Board has responsibility for the Company's overall approach to strategic decision-
making and effective risk management (financial and non-financial including reputational).
Thus the Board exercises oversight of risk and how it is managed with appropriate
accountability to stakeholders.
The Risk and Compliance Committee has a two-fold function: it assists the Board in
overseeing the Company’s compliance with the obligations imposed by legislation, codes,
rules and regulations, relevant to the Company and its business; and it maintains oversight for
review and proper implementation of the Company’s Risk policies and assessing and
advising the Board on high-level risk-related matters, including the different types of Risk
which the Company and its subsidiaries may be exposed to from both a financial and non-
financial perspective.
To this end the Committee ensures that the Company’s strategy and risk appetite are aligned
and monitors the stress testing framework, governance and internal control structures.
Furthermore, the Committee approves the annual plan for the Compliance Function and is
updated at every meeting on progress in relation to the said plan and other matters referring
to regulatory compliance risk including the relationship with the Company’s Regulator.
The Money Laundering Reporting Officer, the Complaints Officer and the Anti-Fraud
Officer report directly to this Committee. The Money Laundering Reporting Officer and the
Compliance Officer of the subsidiary companies Bee Insurance Management Ltd. and
EuroMed Risk Solutions Ltd. also report to this Committee at every meeting.
The Risk and Compliance Committee held six meetings during 2024. The Committee, as re-
elected during the Board Meeting held after the AGM on 30 April 2024, comprised the
following members and their relative attendance at the meetings held were as detailed:
Martin Galea (Chairman)                                                      6
Diane Bugeja                                                                          5
Jose Maria del Pozo                                                                3
Etienne Sciberras                                                                    6
20
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Corporate Governance Statement - continued
2. Compliance with the Code - continued
Principle 8 – Committees - continued
Risk and Compliance Committee - continued
The CEO, the Chief Financial Officer, the Chief Compliance Officer and the Chief Risk
Officer, amongst others as may be required, attend the Committee meetings by invitation.
The Company Secretary also acts as Secretary to the Committee.
The Chairperson of the Risk and Compliance Committee reports to the Board at every Board
meeting providing a summary of the salient matters discussed at Committee level thus 
ensuring transparency and fostering communication and continuity between the said Board
Committee and the other members of the Board.
Investment Committee
The Investment Committee is a joint Committee composed of Directors of the Company and
Directors of its subsidiary MAPFRE MSV Life p.l.c.. The Investment Committee oversees
the investment activities of the Company and its subsidiaries, executes its policies and
guidelines, scrutinises and approves material transactions and monitors results.
Although the Investment Committee meets on a monthly basis the business of the Company
was discussed at three meetings during 2024. The Committee members and relative
attendance to meetings is listed below.
Simon Azzopardi   
3
Romeo Cutajar (Chairman)   
3
Jose-Luis Jimenez       
-
Jose Maria del Pozo 
1
Javier Moreno   
3
Patrick Spiteri Swain   
2
Godfrey Swain
1
Paul Testaferrata Moroni Viani 
3
The CEO of the subsidiary MAPFRE MSV Life p.l.c., the Chief Financial Officer both of the
Company and of its subsidiary MAPFRE MSV Life p.l.c., the MAPFRE Regional Chief
Financial Officer, amongst others as may be required, attend the Committee meetings by
invitation. The Company Secretary of the subsidiary MAPFRE MSV Life p.l.c. acts as
Secretary to the Committee.
Remuneration Committee
The Board of Directors approves the remuneration of Directors and Chief Officers on the
recommendation of the Remuneration Committee. The maximum aggregate directors’
emoluments are established and approved by the shareholders during General Meetings as
and when required.
21
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Corporate Governance Statement - continued
2. Compliance with the Code - continued
Principle 8 – Committees - continued
Remuneration Committee - continued
Further detail on the various aspects of how the Company remunerates its employees, the
workings of this Committee and information relative to its’ meetings in 2024 are considered
in the Remuneration Statement and Report to the Shareholders. 
The Remuneration Committee held five meetings during the period under review and the
attendance was as follows:
Antoinette Caruana (Chairperson)
5
Gordon Cordina
5
Martin Galea
5
The CEO for MAPFRE Middlesea p.l.c., the CEO for MAPFRE MSV Life p.l.c., the Chief
Officer, Human Resources for MAPFRE Middlesea p.l.c., amongst others as may be
required, attend the Remuneration Committee meetings by invitation. The Company
Secretary also acts as Secretary to the Committee.
The 2024 Annual Report includes a separate Remuneration Statement in terms of Code
Provisions 8.A.3 and 8.A.4 and Remuneration Report in terms of Code Provision 12.26K.
Principle 9 – Relations with Shareholders and with the Market
The Company recognises the importance of maintaining a dialogue with its shareholders and
of keeping the market informed to ensure that its strategies, as well as performance, are not
merely transparent but also understood. The Board is of the view that during the period under
review the Company has communicated effectively with the market through a number of
company announcements and press releases.
The Company also communicates with its shareholders through the Company’s Annual
General Meeting (‘AGM’) concerning which further detail is provided under the section
entitled General Meetings. The Chairman ensures that all relevant individuals including the
Chairpersons of the Board Committees are present at the AGM to answer any questions as
may arise.
Apart from the AGM, the Company communicates with its shareholders through the Annual
Report, as available for review and downloading from the Company’s website. The
Company’s website (https://www.mapfre.com.mt) also contains information about the
Company and its business, including the six-monthly financial statements and all issued
company announcements together with a section entirely dedicated to investor relations for
the benefit of all Shareholders and the general public. 
22
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Corporate Governance Statement - continued
2. Compliance with the Code - continued
Principle 9 – Relations with Shareholders and with the Market - continued
Furthermore, the Chairman ensures that constant and consistent communication is maintained
with all stakeholders including the shareholders to discuss matters of significant importance
or to address particular issues or concerns. To this end, the Chairman and CEO maintain open
dialogue with the major shareholders and the Chairman, CEO and Company Secretary hold
an annual meeting with representatives of the Malta Association of Small Shareholders to
discuss various matters in the interests of the minority shareholders.
Individual shareholders can raise matters relating to their shareholding and the business of the
Company at any time throughout the year via the Office of the Company Secretary, a facility
which is well availed of and functions very well in practice. Shareholders are also given the
opportunity to ask questions at the AGM or submit written questions in advance and the
Company recognises their statutory right to request the convening of an extraordinary general
meeting in accordance with Article 52 of the Articles of Association of the Company and
Article 129 of the Companies Act (Cap. 386 of the Laws of Malta). 
Principle 10 – Institutional Shareholders
The Company’s Institutional shareholders keep the market updated on issues related to their
respective companies through company announcements and press releases and their web site.
During the year under review, the Company issued various press releases related to the
controlling shareholder, namely MAPFRE S.A, in connection with the latter’s operations
abroad. The other institutional shareholder, namely Bank of Valletta plc, is a listed company
on the Malta Stock Exchange and consequently a steady flow of information is maintained as
aforementioned. In addition, the six monthly and annual results include a section on the
insurance interests of institutional shareholders.
Principle 11 – Conflicts of Interest
The Directors are strongly aware of their responsibility to act in the interest of the Company
and its stakeholders including its shareholders at all times, irrespective of whom appointed
them to the Board, and of their obligation to avoid conflicts of interest. During the period
under review, the Board maintained its practice that in the event of a real or potential conflict
of interest arising in respect of a Director in connection with any transaction or other matter,
the interest is to be declared and the individual concerned shall refrain from taking part in
proceedings or decisions relating to the matter. The Board minutes evidence such
declarations as and they arise.
In accordance with the MAPFRE Corporate Governance Policy and the Policy for Managing
Conflicts of Interest, a Director is to avoid situations in which he could have a conflict of
interest, whether direct or indirect, actual or potential, with the interest of the Company and
shall ensure that personal interests of any nature do not take precedence over the interests of
the Company and its stakeholders.
23
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Corporate Governance Statement - continued
2. Compliance with the Code - continued
Principle 11 – Conflicts of Interest - continued
The Company also has an Internal Code of Conduct Relating to Listed Securities addressed
to all directors and selected officers of the Company and its Subsidiary undertakings.  The
aim behind this Code is to ensure compliance with the Prevention of Market Abuse
Regulatory Framework as well as the recommendations and principles contained in the
Capital Markets Rules. The Company keeps a record of all advance notices received in
connection with permitted dealings by directors and selected officers and acknowledgements
of such advance notices. The Company reminds all Directors and senior officers of their
obligation to conform to the Code on an annual basis.
As required by principle 11.3 of Appendix 5.1 of the Capital Markets Rules a Directors’
beneficial interest in the share capital of the Company as at 31 December 2024 has been
declared by Paul Testaferrata Moroni Viani stemming from his indirect shareholding in the
Company’s shares through his shareholding in family businesses. 
Principle 12 – Corporate Social Responsibility
During 2024, MAPFRE Malta once again met its CSR objectives collaborating with a
number of different entities to organize several activities, ranging from food and blood
donations, environmental activities and donations to various charitable organisations and
NGOs. Caritas, Hospice, Puttinu Cares, Dar Bjorn, Dar il-Kaptan and YMCA were some of
the beneficiaries of these donations to mention a few.
As per previous years, Fundación MAPFRE allocated over €150,000 for projects in Malta in
various areas including road safety awareness, health campaigns and social actions.
Moreover, the Foundation has collaborated with Caritas Malta, supporting an Adventure
Therapy Cycling Project in order to provide therapeutic outdoor activities for adolescents
dealing with substance abuse issues. Throughout 2024, Fundación MAPFRE also continued
in their efforts to generate awareness towards road safety measures by contributing to the
education of young adults and the public in general in this regards. Besides its ongoing
campaign in collaboration with Malta Public Transport, Ministry of Education  and the Road
Safety Council, Fundación MAPFRE teamed-up with Doctors for Road Safety (D4RS), who
share the same concerns on this important immediate national issue.
MAPFRE Malta also joined the fight against breast cancer with a variety of awareness-
raising activities through their #ThinkPink campaign, as well as by collaborating with the
Action for Breast Cancer Foundation as per previous years.
24
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Corporate Governance Statement - continued
3.Non-compliance with the code
Principle 3 – Composition of the Board
The Code recommends that the Board of Directors be composed of executive and non-
executive Directors, including independent non-executives. The Company’s Board, as
explained in Section 2 – Principle 3 of this Statement, is composed exclusively of non-
executive Directors. The appointment of Directors to the Board is a matter reserved
exclusively to the Company shareholders (except in the case of the filling of a casual
vacancy) and each Director retires from office at the AGM. Therefore, the composition of the
Board of Directors is determined by the shareholders during the AGM. Moreover the CEO of
the Company attends and reports during all meetings of the Board and various Senior
Managers attend by invitation to report on salient matters thereby ensuring a constant and
effective flow of information between the Company’s Management and Board of Directors.
Principle 4 – The Responsibilities of the Board
Code Provision 4.2.7 recommends: “the development of a succession policy for the future
composition of the Board of Directors and particularly the executive component thereof, for
which the Chairman should hold key responsibility”.
Regard being had to the non-executive role of the Company’s Directors and in view of the
facts explained above, particularly that the appointment of Directors is a matter reserved
exclusively to the Company’s shareholders and that every director retires from office at the
Annual General Meeting, the Company has not felt the necessity to date to formalise a
succession policy for the Board of Directors. That said, the Company and its Board remain
mindful of the recommendation and this view would potentially be re-visited in the event of a
change in Board composition or other circumstances.
Insofar as the management of the Company, the Human Resources Area maintains a
succession plan for the key executives which plan is monitored and discussed by the
Remuneration Committee as aforementioned.
Principle 7 – Evaluation of the Board’s Performance
Code Provision 7.1 recommends: “the Board should appoint a committee chaired by a non-
executive Director in order to carry out a performance evaluation of its role”.
As explained above the Board has not appointed a specific committee to carry out a
performance evaluation but has rather opted to have an annual performance evaluation
exercise carried out under the auspices of the internal Compliance Area through the
compilation of a Board Effectiveness Questionnaire by each individual Director.
25
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Corporate Governance Statement - continued
3.Non-compliance with the code - continued
Principle 7 – Evaluation of the Board’s Performance - continued
The questionnaire is particularly robust and is structured into eight sections with a total of 63
statements covering several aspects of Board membership including the understanding of the
workings of the Board and its Committees, the Company’s products and services, distribution
channels, strategy and risk, as well as governance, training requirements, subsidiaries and
contingent liabilities.  Directors are also invited to elaborate further on any of the statements
at the end of the questionnaire.
An objective and independent report as to the overall outcome of the findings is then drawn
up by the Compliance Area and shared with the Chairman to co-ordinate further individual or
group discussion with the Directors based on the replies. In 2024 a group discussion of the
final report was facilitated by a specific off-site meeting presided over by the Chairman and
recommendations were noted for implementation by the Company Secretary.
For these reasons the process is deemed to be comprehensive and sufficient to meet the
intended aims.
Principle 8B – Nomination Committee
Pursuant to the Company’s Articles of Association and as aforementioned the appointment of
Directors to the Board is reserved exclusively to the Company’s shareholders, in line with the
general commercial practice in Malta.  Shareholders holding 11% or more of the issued
shares are entitled to appoint one director for every 11% holding, whilst the other
shareholders are entitled to appoint the remaining Board members at the Annual General
Meeting in accordance with the provisions of the Articles of Association.
Thus the Company considers that the procedure is already sufficiently defined and the
requirements of transparency are also well-met without the need for the establishment of a
formal Nomination Committee.
Principle 9 – Relations with Shareholders and with the Market
Code Provision 9.3 recommends the Company having a mechanism in place to resolve
conflicts between minority shareholders and controlling shareholders.
The Board is mindful of its duty to act in the interest of all stakeholders, independent of
whom appoints them and the balance between the interests of all shareholders is of
paramount consideration at all times. To this end the Board seeks to make available a fair,
balanced and understandable assessment of the Company's position and prospects, publish all
relevant information on its web site and ensures there are channels to receive feedback from
stakeholders including shareholders.
26
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Corporate Governance Statement - continued
3.Non-compliance with the code - continued
Principle 9 – Relations with Shareholders and with the Market - continued
To this end, although the Company does not have a specific mechanism in place there is open
dialogue between Management and all the non-Executive Directors of the Company. The
Company also ensures a good relationship with the Malta Association for Small Shareholders
maintaining an open-door policy with them, as well as with any individual shareholders who
may be interested in making direct submissions to the Company, through the Office of the
Company Secretary.
In light of this, and as the Company is mindful of the protection granted to minority
shareholders in terms of the Companies Act (Cap. 386 of the Laws of Malta) by which it
would necessarily be bound to abide, the Company is of the opinion that no formal
procedures to resolve conflict between minority and controlling shareholders are necessary at
this stage.
Internal Control and Risk Management System
This information is being provided in terms of Capital Markets Rule 5.97.4.
While authority to manage the daily business of the Company is delegated to the CEO within
the limits set by the Board, the Board is ultimately responsible for the Company’s internal
control systems and for ensuring their effectiveness. Such systems are designed to manage,
rather than eliminate, the risks associated with achieving business objectives and can only
provide reasonable (as opposed to absolute) assurance against material misstatement or loss.
27
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Corporate Governance Statement - continued
3.Non-compliance with the code - continued
Internal Control and Risk Management System - continued
The Company manages its internal risk through the ‘three lines of defence’ approach,
ensuring achievement of commercial aims while continuing to meet all legal and regulator
requirements. These then feed into the Board through the Audit Committee and the Risk and
Compliance Committee in order for the Board to maintain oversight of the processes and
procedures ensuring the effectiveness of the systems of internal control.
The key features of the Company’s systems of internal control are as follows:
Organisation - The Company has clear reporting lines from the Boards of Directors of
subsidiary and associated companies. The MMS Chairman is also kept informed as to the
operations of the subsidiary companies either by sitting directly on the respective Boards or
through the other Company Directors and Senior Management who sit on the Company and
subsidiary boards, Management and Operational Committees.
Risk Identification - The respective Management of each of the Group companies is
responsible for the identification and evaluation of key risks applicable to their areas of
business.  The Board reviews its Risk Management policies and strategies and oversees their
implementation to ensure that identified key risks are properly assessed and managed. The
risk based nature of the Solvency II regime requires the company to have an effective risk
management system in place to identify, measure, manage, monitor and report on the main
risks which could impact the entity. This process is embodied in the annual ORSA (Own
Risk and Solvency Assessment) process. Expert judgements, stress testing and sensitivity
analysis are important elements in the Company’s risk identification framework embedded in
the ORSA process. The ORSA report is submitted to the competent Authority on an annual
basis after approval of the Risk and Compliance Committee and ultimately of the Board of
Directors.
Reporting - Functional, operating and financial reporting standards are applicable to all
entities of the Group. Systems and procedures are in place to identify, control and report on
the major risks. The Board receives periodic management information giving comprehensive
analysis of financial and business performance including variances against budgets.
General Meetings
This information is being provided in terms of Capital Markets Rule 5.97.6. 
The General Meeting is the Company’s most supreme decision-making organ and its
functions are governed by, and conducted in accordance with, the Company’s Articles of
Association.  The General Meeting is called with not less than twenty-one days’ notice in
writing.  In addition to any matters which are deemed to constitute ’special business’, the
annual general meeting deals with matters of a recurring nature namely, the declaration of a
dividend, the consideration of the accounts, statement of financial position and reports of the
directors and auditors, the election of directors, the appointment of  the auditors and the
28
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Corporate Governance Statement - continued
General Meetings - continued
authorisation of the directors to set their remuneration. The Memorandum and Articles of the
Company may be amended by means of an extraordinary resolution (as defined in the
Articles) of the Company during general meetings.
The Board of Directors is responsible for developing the agenda for the AGM and sending it
to the shareholders.
Shareholders’ rights can be exercised in accordance with the Articles of the Company, the
Companies Act and the Capital Markets Rules. Accordingly, all shareholders registered in the
Shareholders’ Register on the Record Date as defined in the Capital Markets Rules, have the
right to attend, participate and vote in the general meeting. A shareholder or shareholders
holding not less than 5% of the nominal value of all the shares entitled to vote at the General
Meeting may request the Company to include items on the agenda of a General Meeting and /
or table draft resolutions for items included in the agenda of a general meeting. Such requests
are to be received by the Company at least forty-six days before the date set for the relative
General Meeting.
A shareholder who cannot participate in the General Meeting can appoint a proxy by written
or electronic notification to the Company. Every shareholder represented in person or by
proxy is entitled to ask questions which are pertinent and related to items on the agenda of the
General Meeting and to have such questions answered by the Directors or such persons as the
Directors may delegate for that purpose.                                             
In 2024 the Company held its AGM on 30 April to enable active participation by all those
having an interest in doing so and to allow the shareholders proper opportunity to engage
with the Company Directors and members of Management.
Signed by Martin Galea (Chairman) and Antoinette Caruana (Director) on the 25 March
2025.
29
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Remuneration Statement and Report of the Remuneration Committee to
the Shareholders
1. Terms of Reference and Membership
In accordance with Section 8A of The Code of Principles of Good Corporate Governance
(Appendix 5.1 of the Capital Markets Rules under Chapter 5 on Continuing Obligations), the
Remuneration Committee ('the Committee') of MAPFRE Middlesea p.l.c. ('MMS' or 'the
Company') hereby submits its Remuneration Statement and Report to the shareholders of
MMS.
The Committee’s main task, in accordance with its Terms of Reference, is to ensure that the
MMS Remuneration Policy is implemented and to propose appropriate remuneration
packages for Directors and Chief Officers in accordance therewith. The Remuneration
Committee also monitors the level and structure of the remuneration packages for Directors
and Chief Officers based on the information presented by Management from time to time.
As at 1 January 2024, the Committee Members were Antoinette Caruana (Chairperson),
Martin Galea and Gordon Cordina. These individuals stood for re-election as Directors at the
Company's Annual General Meeting ("AGM") held on the 30 April 2024 and, at the Board
meeting held directly after the AGM, the said individuals were again appointed as members
of the Remuneration Committee. Antoinette Caruana was once again appointed Chairperson.
All the Committee Members are non-Executive Directors of MMS with no personal financial
interest as recommended by Code provision 8.A.1. The MMS President & Chief Executive
Officer ("CEO"), Javier Moreno, the MAPFRE MSV Life p.l.c (MMSV) Chief Executive
Officer, Etienne Sciberras and other members of senior management, including Ines Silva in
her capacity as Chief Officer Human Resources for both companies, were invited to attend
the Committee meetings held throughout the year as and when required. The Company
Secretary, Dr Daphne Sims Dodebier, acted as the Secretary to the Committee.
Code provision 8.A.1 recommends that an independent non-Executive Director (NED) chair
the Committee and indeed Antoinette Caruana is an independent NED. Nonetheless, the
Committee takes decisions by the unanimous agreement of its Members further to open and
transparent discussions. 
30
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Remuneration Statement and Report of the Remuneration Committee to
the Shareholders - continued
2. Meetings
The Remuneration Committee held five meetings during the period under review and the
attendance was as follows:
MemberAttended
Antoinette Caruana (Chairperson)  5
Gordon Cordina    5
Martin Galea                            5
The Committee determined and/or discussed the following matters:
• Senior Management Appointments:
• HR Reports;
• Proposed Performance Bonus Pay-Out for FY2023 & Salary increase for 2024;
• 2024 Management by Objectives Variable remuneration framework;
• Collective Agreement Amendments;
• Implementation of the Transformational Leadership Programme;
• Succession Planning;
• Outcome of the eNPS 2024 Survey;
• Remuneration Statement for the Annual Report
3.    Remuneration Statement
a. Remuneration Policy - Senior Management
The MMS Remuneration (also sometimes referred to as Compensation) Policy framework is
set by the Board of Directors acting through the Remuneration Committee. It is based on the
guidelines and principles contained within the MAPFRE Group Compensation Policy which
was most recently approved by the majority of shareholders during the MAPFRE Middlesea
p.l.c Annual General Meeting held on 28 April 2023.
The Committee reviews and approves the individual remuneration arrangements for Senior
Management, namely, the CEO, the Chief Financial Officer, the Company Secretary, the
Chief Officers and the Internal Auditor. 
The Committee has access to both internal and independent external advice on remuneration
matters as and when required.
31
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Remuneration Statement and Report of the Remuneration Committee to
the Shareholders - continued
3.    Remuneration Statement - continued
a. Remuneration Policy – Senior Management - continued
The Committee deems the current Senior Management remuneration packages to be in line
with the local market equivalents and holds them to be fair, reasonable and commensurate to
the responsibilities involved. The Committee also believes that the remuneration packages
are such as to enable the Company to attract, retain and motivate employees having the
appropriate skills and qualities to ensure the proper management of the organisation.
There have been no significant changes to the Company’s Remuneration Policy for Senior
Management during the financial year under review. The Pension Scheme implemented in
the second half of Financial Year 2022 continues with good take up from employees. 
As previously explained, the Pension Scheme is voluntary and intended to provide employees
with an opportunity to build up their retirement savings during their employment. All
employees of the Company, including Senior Management, but excluding Directors, are
eligible to be enrolled in the Pension Scheme, provided that they have been in employment
with the Company for at least two years. Those employees who opt to participate in the
Pension Scheme, determine their own monthly contribution between the minimum and
maximum amounts established by the Pension Scheme’s Terms and Conditions. In return, the
Company then makes contributions into the accounts of these employees who would have
opted to participate in the Pension Scheme and contributes twice the amount contributed by
the employee subject to a maximum based on duration of service, which is also established in
the Pension Scheme’s Terms and Conditions. Please refer to Note 11 in the Financial
Statements for further information with regard to the contribution made by the Company for
Financial Year 2024 relative to the said Scheme.
The performance appraisal system underpinning the Company’s remuneration structure as
implemented in 2013 and the performance bonus scheme implemented in 2014 also
continued to apply in 2024, with the latter being reviewed and further enhanced as necessary
on an annual basis.
The said performance bonus scheme is still based on the achievement of Group, Company
and Departmental objectives and was further enhanced in 2019 to give some weight to the
adherence to Corporate Values. In Financial Year 2020 the performance appraisal system was
upgraded to a new tool which allows for the generation of 360 degree feedback between
peers and internal clients and continuous communication between employees and their direct
managers throughout the year making the performance evaluation a lot more holistic.
32
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Remuneration Statement and Report of the Remuneration Committee to
the Shareholders - continued
3.    Remuneration Statement - continued
a. Remuneration Policy – Senior Management - continued
The terms and conditions of employment for Senior Management are set out in their
respective contracts of employment.  In principle, these contracts do not contain provisions
for termination payments or other amounts linked to early termination nor have there been
any cases of early termination in practice. Share options, pension benefits and profit sharing
are not part of the MMS Remuneration Policy for Senior Management. Indeed Senior
Management, is not entitled to any compensation of a variable nature except the performance
bonuses set out hereunder.
The MMS CEO is eligible for an annual bonus entitlement calculated with reference to the
attainment of pre-established objectives and targets as recommended by the Remuneration
Committee and approved by the Board of Directors.
Insofar as the performance bonus for Senior Management as aforementioned, this is
calculated in accordance with the percentage achievement of the Group and Departmental
objectives referred to above. The performance bonus is inter alia approved by the
Remuneration Committee and  determined in accordance with the performance appraisal
process. No supplementary pension or other pension benefits are payable to Senior
Management. Additionally, in 2022, a right of clawback was introduced in the Remuneration
Policy for Key Staff where, if the relevant Variable Remuneration attains one of two
quantitative criteria, 30% of the applicable Variable Remuneration would be deferred over
three years to provide for the potential of such clawback..
Both in the case of the MMS CEO and for Senior Management, the Remuneration Committee
is of the view that the proportion of fixed remuneration to performance bonus is also
reasonable and appropriate.
Non-cash benefits to which Senior Management are entitled include the use of a company car
and health insurance. The death-in-service benefit also forms part of the non-cash benefits
and the same terms are applicable to all other Company employees.
Total emoluments received by Senior Management during Financial Year 2024 are deemed
to be of a commercially sensitive nature and are thus not being disclosed in this Report in line
with Code Provision 8.A.6.
b. Remuneration Policy – Directors
As at 31 December 2024, the Board of Directors of MAPFRE Middlesea p.l.c. was composed
of nine non-Executive directors.  Three Directors, namely Eduardo Perez de Lema, Jose-Luis
Jimenez and Jose Maria del Pozo, did not receive a fee in accordance with the established
policy of the MAPFRE Group with which they are employed and which appointed them.
Etienne Sciberras also did not receive a fee since during Financial Year 2024 he occupied the
position of Chief Executive Officer of MAPFRE MSV Life p.l.c. (a subsidiary of MMS). 
33
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Remuneration Statement and Report of the Remuneration Committee to
the shareholders - continued
3. Remuneration Statement - continued
b. Remuneration Policy – Directors - continued
Based on the recommendations of the Committee, the current Directors’ fees, for each
Director as applicable, and as approved by the Board are as follows:
Directors’ Fees including Board Committees as applicable
Chairman€60,000 per annum (2023: €60,000)
Other Directors (per Director)€40,000 per annum (2023: €40,000)
Audit Committee Fees
Chairman€7,000 per annum (2023: €7,000)
Member (per member)€5,000 per annum (2023: €5,000)
Subsidiary Fees
Chairman€7,000 per annum (2023: €7,000)
Member (per member)€5,000 per annum (2023: €5,000)
None of the Company’s Directors had any service contracts with either the Company or any
of its subsidiaries as at the end of the Financial Year. 
Directors’ emoluments are established to reflect the responsibility and time committed by
Directors to the affairs of the Company, including the Board Committees of which a Director
may be a member save for the Audit Committee that is additionally remunerated as detailed
above. None of the Directors, in their capacity as Director of the Company and/or Committee
members, are entitled to profit sharing, share options, pension benefits, participation in the
Employee Pension Scheme or any other remuneration.
34
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Remuneration Statement and Report of the Remuneration Committee to
the Shareholders - continued
3. Remuneration Statement - continued
c.Code Provision 8.A.5
Directors' Emoluments 2024
Fixed Remuneration
Variable Remuneration
Share Options
Others
€249,753
None
None
None
Fees payable to directors in respect of 2024 amounted in total to €249,753 (2023: €264,083).
The emoluments of Senior Management are not being disclosed in line with Code Provision
8.A.6 since these are deemed to be of a commercially sensitive nature. This decision will
continue to be reviewed on an annual basis.
d.Code Provision 12.26K
In addition to the information provided above and with reference to Appendix 12.1 of the
Capital Markets Rules it is noted that the maximum annual aggregate emoluments that may
be paid to the Directors are approved by the shareholders in the General Meeting in terms of
Article 81 of the Company’s Articles of Association. This amount was established by the
Board of Directors after consultation with the MAPFRE Group and based on the guidelines
as set forth in the Compensation Policy relative to the fixing of compensation for the non-
Executive members of the governance bodies having regard to the Company’s financial
situation, profitability and sustainability. The maximum annual aggregate amount was then
confirmed in the total sum of €350,000 per annum at the forty-second Annual General
Meeting held on the 30 April 2024, which has remained consistent since 2018.
The amount paid to each Director by the Company for attendance at meetings of the Board or
of the Board Committees, when due as explained above, is not tied to the Company’s
performance or other performance criteria but is a pre-determined, fixed annual amount as
indicated below:
35
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Remuneration Statement and Report of the Remuneration Committee to the Shareholders - continued
3. Remuneration Statement - continued
d.Code Provision 12.26K - continued
Director
2024 Fees
€
2023 Fees
€
Percentage Annual Change of Remuneration
%
2023-2024
2022-2023
2021-2022
2020-2021
Martin Galea (NED & Board Chairman)
65,000
65,000
0.00
-10.55
4.81
1.96
Antoinette Caruana (NED)
45,003
45,000
0.00
0.00
4.65
0.00
Gordon Cordina (NED)1
50,000
52,333
-12.28
0.00
n/a
n/a
Jose Maria del Pozo (NED)
nil
nil
n/a
n/a
n/a
n/a
Jose Luis Jimenez (NED)
nil
nil
n/a
n/a
n/a
n/a
Eduardo Perez de Lema (NED from 1
January 2024)
nil
nil
n/a
n/a
n/a
n/a
Etienne Sciberras (NED)2
nil
nil
n/a
n/a
n/a
n/a
Godfrey Swain (NED)
49,750
48,417
2.88
n/a
n/a
n/a
Paul Testaferrata Moroni Viani (NED)
40,000
40,000
0.00
0.00
0.00
(6.98)
Total
249,753
250,750
1The amount includes €50,000 paid to Dr Gordon Cordina as Chairman of the subsidiary Board.
2Total emoluments for 2024 paid to Mr Etienne Sciberras as CEO of MAPFRE MSV Life amounted to €381,492 (2023: €239,530). This amount
includes €60,959 being the value of 70% of the MAPFRE S.A. shares entitlement that were delivered on the 20 March 2025 the value of which
was determined by the closing price on 19 March 2025 of €2.898. The amount does not include the value of  9,015 shares in MAPFRE S.A.
whose value will only be determined when such shares will be delivered over the coming three years.
* Percentage annual change of remuneration were based on annualised remuneration for the years compared, as applicable, to allow for a
meaningful comparison.
36
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Remuneration Statement and Report of the Remuneration Committee to
the Shareholders - continued
3. Remuneration Statement - continued
d.Code Provision 12.26K - continued
Remuneration paid to Directors as shown in the above table are all fixed in nature and thus
the ratio of fixed and variable remuneration was 100%-0% for both years being reported. The
changes in the total remuneration of Non-Executive Directors is to be considered with the
information included in the table, further down in this report, showing a comparison between
the percentage annual change of remuneration of CEO against company performance metrics
and percentage annual change of the Company’s employees’ average remuneration employed
on a full-time basis equivalent.
None of the Directors and Members of the Board Committees held any service contracts with
the Company or any of its subsidiary undertakings and no Director is entitled to share
options, profit sharing, pension benefits or any other type of emoluments save for the
provision of cover under a Group Life scheme. It is also confirmed that no other fees were
payable or paid to any of the Directors or Committee Members during the financial year
under review.
By reference to Capital Markets Rule 12.2A no other person is deemed to be in charge of the
operations or the activities of the Company, and thus fall within the definition of director,
beyond the members of the Board and the Chief Executive Officer.
In this respect and relative to Appendix 12.1 the total emoluments paid by the Company to
the Chief Executive Officer in office during Financial Year 2024 were as follows:
Financial Year
2024
2023
2022
2021
€
€
€
€
President & CEO
Javier Moreno Gonzalez
Fixed Salary
201,474
191,880
184,500
135,000
Defined pension contribution
63,553
58,601
41,985
30,375
Other fringe benefits
105,831
102,551
106,644
84,262
Total Fixed remuneration
370,858
353,032
333,129
249,637
Variable remuneration
In cash *
244,350
135,674
116,320
97,817
In MAPFRE S.A. shares
  (31,556 shares)**
91,449
—
—
—
Total variable remuneration
335,799
135,674
116,320
97,817
Total remuneration
706,657
488,706
449,449
347,454
Fixed Variable Proportion
52%-48%
72%-28%
74%-26%
72%-28%
37
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Remuneration Statement and Report of the Remuneration Committee to
the Shareholders - continued
3. Remuneration Statement - continued
d.Code Provision 12.26K - continued
* The amounts are 70% paid immediately after the respective financial year with the
remaining 30% being settled in three equal installments in the following three years.
** The amount is for the 70% of the shares entitlement that were delivered on the 20 March
2025 the value of which was determined by the closing price on 19 March 2025 of €2.898.
The value of the remaining 30% (13,524 shares in MAPFRE S.A.) will be determined based
on the share price when such shares will be delivered over the coming three years.
In respect of Variable Remuneration, deferred or otherwise, paid or pending payment, a
partial or total reduction is possible if particular circumstances arise including in the event of
a restatement of annual accounts other than resulting from a change in legislation and in the
event of fraud. No such occurrence took place in 2024.
Variable remuneration for the CEO is based on Global, Regional and Country results together
with Country premium written targets, with the highest weighting given to the Country
results and premiums respectively.  The main objective of the Group is profitable Growth and
the targets are aligned with such objectives. As part of a Global Group it is expected that as a
Country we contribute towards the profitability of both the Region and the Global Group
results and accordingly part of the variable remuneration is attached to the achievement of the
higher Group results. The achievement percentage follows a set scale going from complete
non-achievement, to pro-rata if not fully achieved, to accelerated achievement if targets are
exceeded. These scales are in line with the Remuneration Policy and approved accordingly
by the Remuneration Committee.
In terms of the requirements within Appendix 12.1 of the Capital Markets Rules, the
following table presents the annual change of remuneration of the CEO, of the Company’s
performance, and of average remuneration on a full-time equivalent basis of the Company’s
employees over the four most recent financial years:
Performance indicators
% Difference
FY2024-
FY2023
% Difference
FY2023-
FY2022
% Difference
FY2022-
FY2021
% Difference
FY2021-
FY2020
Company's profit after tax
6.45%*
59.86%
45.30%
(36.64)%
Company's gross premium written
8.27%
9.88%
8.75%
6.64%
Remuneration of Company's
  President & CEO
44.60%**
8.73%
(2.98)%
1.90%
Company's employees' average
  remuneration on full time
  equivalent
6.98%
1.34%
3.39%
6.44%
Group's employees' average
  remuneration on full time equivalent
4.29%
2.90%
3.01%
5.54%
38
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Remuneration Statement and Report of the Remuneration Committee to
the Shareholders - continued
3. Remuneration Statement - continued
d.Code Provision 12.26K - continued
* The increase arose mainly from a €1.00 million net dividend received from MAPFRE MSV
Life p.l.c. in 2024 with no comparative. Technical results were generally in line with those of
2023.
** The increase arose mainly from the variable component of the remuneration of the CEO
following the achievement of MAPFRE S.A. long-term targets for the period 2022-2024
becoming payable at the end of 2024. The amount excludes payment by way of 13,524
MAPFRE S.A. shares that can only be determined when the shares are delivered over the
coming three years.
In terms of the requirements within Appendix 12.1 (f) there has been no deviation from the
procedure for the implementation of the remuneration policy as defined in Chapter 12 of the
Capital Markets Rules.
As required by provision 12.26N of the Capital Markets Rules the Company’s auditors have
verified that the information that needs to be included in the Remuneration Report as per
Chapter 12 and Appendix 12.1 of the Capital Markets Rules, has been included.
Signed by Antoinette Caruana (Director and Remuneration Committee Member) on 25
March 2025.
39
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Statement of profit or loss
Year ended 31 December
Group
Company
2024
2023
2024
2023
Notes
€’000
€’000
€’000
€’000
Insurance revenue
146,692
140,580
99,922
92,869
Insurance service expenses
(112,029)
(91,444)
(78,496)
(68,455)
Net expenses from reinsurance contracts held
(11,840)
(15,844)
(9,096)
(12,247)
Insurance service result
22,823
33,292
12,330
12,167
Interest revenue calculated using the effective
  interest method
5,440
5,222
355
221
Other investment revenue
98,141
176,758
2,245
1,742
Net credit impairment gains/(losses)
9
(22)
1
—
Net investment return
103,590
181,958
2,601
1,963
Net change in investment contract liabilities
(13,131)
(8,194)
—
—
Finance expense from insurance
  contracts issued
(83,192)
(176,871)
(818)
(1,320)
Finance (expense)/income from reinsurance
  contracts held
(515)
(2,227)
182
486
Net financial result
(96,838)
(187,292)
(636)
(834)
Net insurance and investment results
29,575
27,958
14,295
13,296
Other income
1,282
1,903
—
—
Other operating expenses
(6,053)
(5,842)
(3,764)
(3,432)
Profit before tax
24,804
24,019
10,531
9,864
Tax expense
(6,810)
(8,076)
(3,412)
(3,176)
Profit for the year
17,994
15,943
7,119
6,688
Attributable to:
- owners of the Company
12,519
11,309
7,119
6,688
- non-controlling interests
5,475
4,634
—
—
17,994
15,943
7,119
6,688
The Notes on pages 47 to 209  are an integral part of these financial statements.
40
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Statement of profit or loss and other comprehensive income
Year ended 31 December
Group
Company
2024
2023
2024
2023
Notes
€’000
€’000
€’000
€’000
Profit for the financial year
17,994
15,943
7,119
6,688
Other comprehensive income:
Items that are or may be reclassified
  subsequently to profit or loss
Net gains on investments in debt
  securities measured at FVOCI
163
273
159
287
Debt securities measured at FVOCI
  reclassified to profit or loss on disposal
—
14
—
14
Items that will not be reclassified  to
  profit or loss
Re-measurement actuarial loss on
  provision for other liabilities and charges
(5)
(68)
(5)
(68)
Total other comprehensive income, net of tax
158
219
154
233
Total comprehensive income for the year
18,152
16,162
7,273
6,921
Attributable to:
- owners of the Company
12,677
11,528
- non-controlling interests
5,475
4,634
Total comprehensive income for the year
18,152
16,162
Items disclosed in the statement above are disclosed net of tax.
The Notes on pages 47 to 209 are an integral part of these financial statements.
41
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Statement of financial position
Notes
Group
Company
As at 31 December
As at 31 December
2024
2023
2024
2023
€’000
€’000
€’000
€’000
ASSETS
Intangible assets
34,411
30,732
10,573
10,391
Property, plant and equipment
17,115
17,183
4,063
4,209
Right-of-use assets
1,702
1,601
1,616
1,509
Investment properties
105,806
105,619
13,712
13,809
Investment in associated undertakings
5,226
23,923
399
403
Investment in subsidiary undertakings
—
—
77,214
77,214
Other investments
2,159,560
2,136,313
19,086
16,290
Deferred income tax asset
2,532
2,118
1,248
1,260
Insurance contract assets
7,080
8,945
—
—
Reinsurance contract assets
11,815
13,359
11,815
13,359
Trade and other receivables
24,457
25,490
19,693
21,189
Current income tax receivable
2,290
7
—
—
Cash and cash equivalents
81,899
47,975
13,908
10,780
Total assets
2,453,893
2,413,265
173,327
170,413
EQUITY
Capital and reserves attributable to
  owners of the Company
Share capital
19,320
19,320
19,320
19,320
Share premium account
688
688
688
688
Other reserves
800
637
34,712
34,553
Retained earnings
75,538
67,524
29,722
27,108
96,346
88,169
84,442
81,669
Non-Controlling Interest
87,169
82,694
—
—
Total equity
183,515
170,863
84,442
81,669
LIABILITIES
Deferred income tax liabilities
14,340
14,079
2,565
2,447
Provisions for other liabilities and charges
889
923
889
923
Insurance contract liabilities
2,027,446
2,063,844
72,968
72,467
Investment contract liabilities
179,685
123,253
—
—
Reinsurance contract liabilities
17,073
15,493
—
—
Derivative financial instruments
6,816
—
—
—
Lease liabilities
1,790
1,661
1,694
1,575
Other payables
19,899
19,349
9,134
9,314
Current income tax liabilities
2,440
3,800
1,635
2,018
Total Liabilities
2,270,378
2,242,402
88,885
88,744
Total equity and liabilities
2,453,893
2,413,265
173,327
170,413
The Notes are an integral part of these financial statements. 
These financial statements on pages 39 to 209 were approved by the Board of Directors and
authorised for issue on 25 March 2025 and signed on its behalf by Martin Galea (Chairman) and
Godfrey Swain (Director) as per the Directors' Declaration on ESEF Annual Financial report
submitted in conjunction with the Annual Report 2024.
42
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Statement of changes in equity
Group
Attributable to owners of the Company
Share
capital
Share
premium
account
Other
reserves
Retained
earnings
Total
Non-
controlling
interests
Total
equity
Notes
€’000
€’000
€’000
€’000
€’000
€’000
€’000
Balance as at 1 January 2023
19,320
688
350
59,783
80,141
78,060
158,201
Comprehensive income
Profit for the year
—
—
—
11,309
11,309
4,634
15,943
Other comprehensive income:
Net change in fair value of 
  debt securities measured
  at FVOCI
  29
—
—
273
—
273
—
273
FVOCI investments -
  reclassified to profit
  or loss
  29
—
—
14
—
14
—
14
Re-measurement actuarial
  loss on provision for
  other liabilities and
  charges
—
—
—
(68)
(68)
—
(68)
Total other comprehensive
  income, net of tax
—
—
287
(68)
219
—
219
Total comprehensive income
—
—
287
11,241
11,528
4,634
16,162
Transactions with owners
Dividends for 2022
—
—
—
(3,500)
(3,500)
—
(3,500)
Total transactions with
  owners
—
—
—
(3,500)
(3,500)
—
(3,500)
Balance as at 31 December
  2023
19,320
688
637
67,524
88,169
82,694
170,863
43
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Statement of changes in equity - continued
Group - continued
Attributable to owners of the Company
Share
capital
Share
premium
account
Other
reserves
Retained
earnings
Total
Non-
controlling
interests
Total
equity
Notes
€’000
€’000
€’000
€’000
€’000
€’000
€’000
Balance as at 1 January 2024
19,320
688
637
67,524
88,169
82,694
170,863
Comprehensive income
Profit for the year
—
—
—
12,519
12,519
5,475
17,994
Other comprehensive income:
Net change in fair value of
  debt securities
  measured at FVOCI
  29
—
—
163
—
163
—
163
Re-measurement actuarial
  loss on provision for
  other liabilities and
  charges
—
—
—
(5)
(5)
—
(5)
Total other comprehensive
  income, net of tax
—
—
163
(5)
158
—
158
Total comprehensive income
—
—
163
12,514
12,677
5,475
18,152
Transactions with owners
Dividends for 2023
—
—
—
(4,500)
(4,500)
(1,000)
(5,500)
Total transactions with
  owners
—
—
—
(4,500)
(4,500)
(1,000)
(5,500)
Balance as at 31 December
  2024
19,320
688
800
75,538
96,346
87,169
183,515
The Notes on pages 47 to 209 are an integral part of these financial statements.
44
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Statement of changes in equity - continued
Company
Share
Share
premium
Other
Retained
capital
account
reserves
earnings
Total
Notes
€’000
€’000
€’000
€’000
€’000
Balance as at 1 January 2023
19,320
688
34,252
23,988
78,248
Comprehensive income
Profit for the financial year
—
—
—
6,688
6,688
Other comprehensive income:
Net change in fair value of debt
  securities measured at FVOCI
  29
—
—
287
—
287
FVOCI investments - reclassified to
  profit or loss
—
—
14
—
14
Re-measurement actuarial loss on
  provision  for other liabilities and
  charges
—
—
—
(68)
(68)
Total other comprehensive
  income, net of tax
—
—
301
(68)
233
Total comprehensive income
—
—
301
6,620
6,921
Transactions with owners
Dividend for 2022
—
—
—
(3,500)
(3,500)
Total transactions with
  owners of the  Company
—
—
—
(3,500)
(3,500)
Balance as at 31 December
  2023
19,320
688
34,553
27,108
81,669
45
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Statement of changes in equity - continued
Company - continued
Share
Share
premium
Other
Retained
capital
account
reserves
earnings
Total
Notes
€’000
€’000
€’000
€’000
€’000
Balance as at 1 January 2024
19,320
688
34,553
27,108
81,669
Comprehensive income
Profit for the financial year
—
—
—
7,119
7,119
Other comprehensive income:
Net change in fair value of debt securities
  measured at FVOCI
  29
—
—
159
—
159
Re-measurement actuarial loss on provision
  for other liabilities and charges
—
—
—
(5)
(5)
Total other comprehensive
  income, net of tax
—
—
159
(5)
154
Total comprehensive income
—
—
159
7,114
7,273
Transactions with owners
Dividend for 2023
—
—
—
(4,500)
(4,500)
Total transactions with
  owners of the  Company
—
—
—
(4,500)
(4,500)
Balance as at 31 December
  2024
19,320
688
34,712
29,722
84,442
The Notes on pages 47 to 209 are an integral part of these financial statements.
46
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Statement of cash flows
Year ended 31 December
Group
Company
2024
2023
2024
2023
Notes
€’000
€’000
€’000
€’000
Cash flows from operating activities
Cash (used in)/generated from operations
(47,789)
(75,143)
14,949
10,779
Dividends received
18,328
12,131
1,502
229
Interest received
28,384
20,805
198
205
Income tax paid
(10,671)
(44,892)
(3,669)
(1,653)
Net cash (used in)/generated from operating
  activities
(11,748)
(87,099)
12,980
9,560
Cashflow from investing activities
Sale of associated undertaking
20,800
—
—
—
Purchase of investment property
(934)
(1,614)
(100)
(344)
Disposal of investment property
1
—
1
—
Purchase of financial investments
(1,444,839)
(1,767,486)
(6,180)
(3,531)
Disposal of financial investments
1,485,885
1,778,156
3,910
381
Purchase of property, plant and equipment and
  intangible assets
(9,741)
(7,768)
(2,983)
(2,916)
Net cash generated from/(used in) investing
  activities
51,172
1,288
(5,352)
(6,410)
Cash flows from financing activities
Dividends paid to owners of the Company
(4,500)
(3,500)
(4,500)
(3,500)
Dividends paid to minority interests
(1,000)
—
—
—
Cash used in financing activities
(5,500)
(3,500)
(4,500)
(3,500)
Net movement in cash and cash equivalents
33,924
(89,311)
3,128
(350)
Movement in cash and cash equivalents
Cash and cash equivalents at beginning of year
47,975
137,286
10,780
11,130
Cash and cash equivalents at end of year
81,899
47,975
13,908
10,780
The Notes on pages 47 to 209 an integral part of these financial statements.
47
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
Notes to the financial statements
1.      Basis of preparation
The financial statements of MAPFRE Middlesea p.l.c. are prepared in accordance with
International Financial Reporting Standards as adopted for use in the European Union
and the Companies Act, 1995. The financial statements of the Group to which the
Company is parent are prepared in accordance with Article 4 of Regulation (EC)
1606/2002 on the application of international accounting standards (the “Regulation”)
which requires that, for each financial period starting on or after 1 January 2005,
companies governed by the law of an EU Member State shall prepare their consolidated
financial statements in conformity with IFRS as adopted by the EU if, at their reporting
date, their securities are admitted to trading on a regulated market of any EU Member
State. The Regulation prevails over the provisions of the Companies Act, 1995 to the
extent that the said provisions of the Companies Act, 1995 are incompatible with the
provisions of the Regulation. Both sets of financial statements as referred to in the
Annual Report relate to both those of the Company and the Group and have also been
prepared in accordance with the Insurance Business Act, 1998.
The financial statements are prepared under the historical cost convention as modified
by the revaluation of property, investment property and financial assets and financial
liabilities (including derivatives) at fair value through profit or loss (FVTPL) or at fair
value through other comprehensive income (FVOCI).  Investment in associated
undertaking is measured using equity method, that is, cost plus or minus net income or
loss of associate.
The preparation of financial statements in conformity with the above reporting
framework requires the use of certain critical accounting estimates. It also requires
management to exercise its judgement in the process of applying the Group’s
accounting policies.  The areas involving a higher degree of judgement or complexity,
or areas where assumptions and estimates are significant to the consolidated financial
statements, are disclosed in Note 3.
The statement of financial position is organised in increasing order of liquidity, with
additional disclosures on the maturity analysis of the Group’s assets and liabilities
provided within the Notes to the financial statements. All amounts in the Notes are
shown in thousands of euro, rounded to the nearest thousand, unless otherwise stated.
Amendments to published standards effective in 2024
In 2024, the Group adopted amendments to existing standards that are mandatory for
the Group’accounting period beginning on 1 January 2024. The adoption of these
amendments  to standards as per the requirements of IFRSs as adopted by the EU did
not result in material changes to the Group’s accounting policies.
48
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
1.Basis of preparation - continued
Standards and amendments to published standards that are not yet effective
A number of new standards and amendments to existing standards are effective for
annual periods beginning on or after 1 January 2025. However, the Group has not early
adopted the new standards or amendments in preparing these financial statements and
management are of the opinion that there are no requirements that are expected to have
a material impact on the Group’s financial statements in the period of initial application.
2.Accounting policies
The material accounting policies adopted in the preparation of these consolidated
financial statements are set out below. These policies have been consistently applied to
all the years presented, unless otherwise stated.
2.1Consolidation
(a) Subsidiary undertakings
The consolidated financial statements incorporate the assets, liabilities and results of
the Company and its subsidiary undertakings drawn up to 31 December each year. 
Subsidiary undertakings are those companies over which the Group has control, either
by way of majority shareholding, through contractual agreements with the other vote
holders of the investee or rights arising from other contractual agreements, giving it the
power to govern the financial and operating policies of the investee. Specifically, the
Group controls an investee if and only if the Group has:
– Power over the investee (i.e. existing rights that give it the current ability to direct
the relevant activities of the investee);
– Exposure, or rights, to variable returns from its involvement with the investee; and
– The ability to use its power over the investee to affect its returns.
The Group re-assesses whether or not it controls an investee if facts and circumstances
indicate that there are changes to one or more of the three elements of control.
Consolidation of a subsidiary begins when the Group obtains control over the
subsidiary and ceases when the Group loses control of the subsidiary. Assets, liabilities,
income and expenses of a subsidiary acquired or disposed of during the year are
included in the statement of financial position and the statement of comprehensive
income from the date the Group gains control until the date the Group ceases to control
the subsidiary.
The Group applies the acquisition method to account for business combinations. The
consideration transferred for the acquisition of a subsidiary is the fair value of the assets
transferred, the liabilities incurred to the former owners of the acquiree and the equity
interests issued by the Group. The consideration transferred includes the fair value of
any asset or liability resulting from a contingent consideration arrangement. Identifiable
assets acquired and liabilities and contingent liabilities assumed in a business
combination are measured initially at their fair values at the acquisition date. The Group
49
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.Accounting policies - continued
2.1Consolidation - continued
(a) Subsidiary undertakings - continued
recognises any non-controlling interest in the acquiree on an acquisition-by-acquisition
basis, either at fair value or at the non-controlling interest’s proportionate share of the
recognised amounts of acquiree’s identifiable net assets.
Acquisition-related costs are expensed as incurred.
If the business combination is achieved in stages, the acquisition date fair value of the
acquirer’s previously held equity interest in the acquiree is re-measured to fair value at
the acquisition date through profit or loss.
Goodwill is initially measured as the excess of the aggregate of the consideration
transferred and the fair value of non-controlling interest over the net identifiable assets
acquired and liabilities assumed. If this consideration is lower than the fair value of the
net assets of the subsidiary acquired, the difference is recognised in profit or loss.
Profit or loss and each component of other comprehensive income are attributed to the
equity holders of the parent of the Group and to the non-controlling interests, even if
this results in the non-controlling interests having a deficit balance. When necessary,
adjustments are made to the financial statements of subsidiaries to bring their
accounting policies in line with the Group’s accounting policies. All intra-group assets
and liabilities, equity, income, expenses and cash flows relating to transactions between
members of the Group are eliminated in full on consolidation. A list of the Group’s
subsidiaries is set out in Note 20.
(b)  Associated undertakings
An associate is an entity over which the Group has significant influence.  Significant
influence is the power to participate in the financial and operating policy decisions of
the investee, but is not control or joint control over those policies.  The considerations
made in determining significant influence are similar to those necessary to determine
control over subsidiaries. Except for investment-linked insurance funds, interests in
associated undertakings are accounted for by the equity method of accounting and are
initially recognised at cost and the carrying amount is increased or decreased to
recognise the investor’s share of profit or loss of the investee after the date of
acquisition.
The Group’s investment in associates includes goodwill (net of any accumulated
impairment loss) identified on acquisition. Equity accounting involves recognising in
the profit or loss the share of the associated undertaking’s post-acquisition profits or
losses.  The interest in the associated undertaking is carried in the statement of financial
position at an amount that reflects the share of the net assets of the associated
undertaking.  When the Group’s share of losses in an associate equals or exceeds its
interest in the associate, including any other unsecured receivables, the Group does not
50
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.      Accounting policies - continued
2.1Consolidation - continued
(b) Associated undertakings - continued
recognise further losses, unless it has incurred obligations or made payments on behalf
of the associate.
Intra-group gains on transactions between the Group and its associates are eliminated to
the extent of the Group’s interest in the associates. Intra-group losses are also
eliminated unless the transaction provides evidence of an impairment of the asset
transferred. Accounting policies for associated undertakings are changed where
necessary to ensure consistency with the policies adopted by the Group. A list of the
Group’s associated undertakings is set out in Note 21.
Interests in associated undertakings that are allocated to the insurance fund are
designated as financial assets at fair value through profit or loss.  They are accounted
for in accordance with the recognition and measurement principles described in Note
2.9.
2.2Segment reporting
Operating segments are reported in a manner consistent with the internal reporting
provided to the chief operating decision-maker.  The chief operating decision-maker,
responsible for allocating resources and assessing performance of the operating
segments, has been identified as the executive management which implements the
strategic decisions taken by the Board.  In identifying the Group’s business segments,
the chief operating decision-maker has considered the different categories of insurance
classes of business.  
2.3Foreign currency translation
Functional and presentation currency
Items included in the financial statements of each of the Group’s entities are measured
using the currency of the primary economic environment in which the entity operates
(the ‘functional currency’). The euro is the Group’s and Company’s functional and
presentation currency.
Transactions and balances
Transactions in foreign currencies have been converted into the functional currency at
the rates of exchange ruling on the date of the transaction or valuation where items are
re-measured.  Foreign exchange gains and losses resulting from the settlement of such
transactions and from the translation at year-end exchange rates of monetary assets and
liabilities denominated in foreign currencies are recognised in the profit or loss account.
All other foreign exchange gains and losses are presented in the profit or loss account
within ‘Other investment revenue’.
51
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.Accounting policies - continued
2.3    Foreign currency translation - continued
Transactions and balances - continued
Translation differences on non-monetary items, mainly arising on equities held at fair
value through profit or loss, are reported as part of 'Other investment revenue'.
2.4Intangible assets
(a)Computer software
Acquired computer software licences are measured at cost less any accumulated
amortization and any accumulated impairment losses. Acquired computer software
licenses are capitalised on the basis of the costs incurred to acquire and bring to use the
specific software.  These costs are amortised using the straight-line method over their
useful lives, not exceeding a period of ten years.  All costs associated with maintaining
computer software programmes are recognised as an expense as incurred.
(b) Deferred policy acquisition costs
Incremental costs that are incurred in acquiring new investment contracts without DPF
are capitalised as deferred acquisition costs (DAC).
The DAC is subsequently amortised over the life of the contracts as follows:
– For long-term investment contracts with a fixed maturity date, DAC is amortised
over the life of the contract.
– For long term investment contracts with no fixed date of maturity, DAC is
amortised over the estimated life of the contract. This basis is reviewed periodically
with reference to the historical experience of surrenders for these contracts.
2.5Property, plant and equipment
All property, plant and equipment is initially recorded at historical cost. Freehold land
and buildings are subsequently shown at revalued amount being its fair value at the end
of the revaluation less accumulated depreciation for buildings and any accumulated
impairment losses. Fair value is based on periodic valuations by qualified valuers to
ensure that the carrying amount of property does not differ materially from that which
would be determined using fair values at the end of the reporting period. Any
accumulated depreciation at the date of revaluation is eliminated against the gross
carrying amount of the asset, and the net amount is restated to the revalued amount of
the asset.  All other property, plant and equipment is stated at historical cost less
depreciation and impairment losses.  Historical cost includes expenditure that is directly
attributable to the acquisition of the items.
52
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2. Accounting policies - continued
2.5Property, plant and equipment - continued
Subsequent costs are included in the asset’s carrying amount or recognised as a separate
asset, as appropriate, only when it is probable that future economic benefits associated
with the item will flow to the Group and the cost of the item can be measured reliably.
The carrying amount of the replaced part is derecognised. All other repairs and
maintenance costs are charged to the profit or loss account during the financial period
in which they are incurred.
Increases in the carrying amount arising on revaluation of land and buildings are
credited to other comprehensive income as other reserves in shareholders’ equity. 
Decreases that offset previous increases of the same asset are charged against other
comprehensive income as other reserves directly in equity; all other decreases are
charged to the profit or loss account.  Each year the difference between depreciation
based on the revalued carrying amount of the asset charged to the profit or loss account
and depreciation based on the asset’s original cost is transferred from ‘other reserves’ to
‘retained earnings’. 
Freehold land is not depreciated as it is deemed to have an indefinite life.  Depreciation
on other assets is calculated using the straight-line method to allocate their cost or
revalued amounts to their residual values over their estimated useful lives as follows:
Buildings
100 years
Leasehold improvements
10 - 40 years
Motor vehicles
5 years
Furniture, fittings and equipment
3 - 10 years
The assets’ residual values and useful lives are reviewed at the end of each reporting
period and adjusted if appropriate.
An asset’s carrying amount is written down immediately to its recoverable amount if
the asset’s carrying amount is greater than its estimated recoverable amount (accounting
policy 2.16).
Gains and losses on disposals are determined by comparing proceeds with carrying
amounts and are included in the profit or loss account. When revalued assets are sold,
the amounts included in other reserves relating to the assets are transferred to retained
earnings.
53
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2. Accounting policies - continued
2.6Investment property
Freehold and leasehold properties treated as investment property principally comprise
office and other commercial buildings that are held for long term rental yields and that
are not occupied by the Group or Company respectively. Investment property is initially
measured at cost and subsequently carried at fair value.  Fair value is based on active
market prices, adjusted, if necessary for any difference in the nature, location or
condition of the specific asset. If this information is not available, the Group uses
alternative valuation methods such as discounted cash flow projections or recent prices
in less active markets. These valuations are reviewed annually by qualified valuers. 
Investment property that is being redeveloped for continuing use as investment
property, or for which the market has become less active, continues to be measured at
fair value.  Changes in fair values are reported in the profit or loss account.
If an investment property becomes owner-occupied, it is reclassified as property, plant
and equipment, and its fair value at the date of reclassification becomes its cost for
subsequent accounting purposes.
2.7Investments in subsidiary undertakings
In the Company’s financial statements, investments in subsidiary undertakings are
accounted for by the cost method of accounting less impairment. 
Provisions are recorded where, in the opinion of the directors, at the end of a reporting
period, there is an impairment in value. Where there has been an impairment in the
value of an investment, it is recognised as an expense in the period in which the
impairment is identified or has occurred.  If in a subsequent period, the amount of the
impairment loss decreases and the decrease can be related objectively to an event
occurring after the impairment was recognised, the previously recognised impairment
loss is reversed by adjusting the allowance account.  The amount of the reversal is
recognised in the profit or loss account.
The dividend income from such investments is included in the profit or loss account in
the accounting year in which the Company’s rights to receive payment of any dividend
is established. 
On disposal of an investment, the difference between the net disposal proceeds and the
carrying amount is charged or credited to the profit or loss account and included within
'Other investment revenue'.
54
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2. Accounting policies - continued
2.8Investments in associated undertakings
In the Company’s financial statements, investments in associated undertakings are
accounted using the equity method. They are initially recognised at cost which includes
transaction costs. Subsequent to initial recognition the carrying amount is increased or
decreased to recognise the investor’s share of profit or loss. Distributions received from
an investee reduce the carrying amount of the investment. The changes in the investee’s
proportionate interest arising from changes in the investee’s other comprehensive
income, such as those arising from revaluation of property, plant and equipment and
from exchange translation differences are recognised in the other comprehensive
income.
2.9Financial instruments
(a) Summary of measurement categories
The Group classifies its financial assets and financial liabilities into the following
categories:
Classification
Reason
Cash and cash equivalents
Amortised Cost
SPPI, hold to collect business model
Other investments
FVTPL
Trading or portfolio managed at FV
Other investments
FVOCI
SPPI, hold to collect and sell business model
Other investments
Amortised Cost
SPPI, hold to collect business model
Trade and other receivables
Amortised Cost
SPPI, hold to collect business model
Other payables
Amortised Cost
Not managed at FV
Investment contract liabilities
FVTPL
Managed at FV
The Group does not apply hedge accounting.
(b)Initial recognition and measurement       
Financial assets and financial liabilities are recognised when the Group becomes a party
to the contractual provisions of the instrument. Regular way purchases and sales of
financial assets are recognised on the trade date (that is, the date on which the Group
commits to purchase or sell the asset).
At initial recognition, the Group measures a financial asset or financial liability at its
fair value, plus or minus, in the case of a financial asset or financial liability not at
FVTPL, transaction costs that are incremental and directly attributable to the acquisition
or issue of the financial asset or financial liability, such as fees and commissions.
Transaction costs of financial assets and financial liabilities carried at FVTPL are
expensed in profit or loss. Immediately after initial recognition, an ECL allowance is
recognised for financial assets measured at AC and investments in debt instruments
measured at FVOCI.
55
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2. Accounting policies - continued
2.9Financial instruments - continued
(b)Initial recognition and measurement - continued        
When the fair value of financial assets and liabilities differs from the transaction price
on initial recognition, the entity recognises the difference as follows:
a. When the fair value is evidenced by a quoted price in an active market for an
identical asset or liability (that is, a Level 1 input) or based on a valuation technique
that uses only data from observable markets, the difference is recognised as a gain
or loss.
b. In all other cases, the difference is deferred and the timing of recognition of
deferred day one profit or loss is determined individually. It is either amortised over
the life of the instrument, deferred until the instrument’s fair value can be
determined using market observable inputs, or realised through settlement.
(c) Amortised cost and effective interest rate
Amortised cost (AC) is the amount at which the financial asset or financial liability is
measured at initial recognition minus the principal repayments, plus or minus the
cumulative amortisation using the effective interest method for any difference between
the initial amount and the maturity amount and, for financial assets, adjusted for any
loss allowance.
The effective interest rate (EIR) is the rate that exactly discounts estimated future cash
payments or receipts through the expected life of the financial asset or financial liability
to the gross carrying amount of a financial asset (that is, its AC before any impairment
allowance) or to the AC of a financial liability. The calculation does not consider the
ECL and includes transaction costs, premiums or discounts and fees and points paid or
received that are integral to the EIR.
When the Group revises the estimates of future cash flows, the carrying amount of the
respective financial asset or financial liability is adjusted to reflect the new estimate
discounted using the original EIR. Any changes are recognised in profit or loss. 
Interest revenue is calculated by applying the EIR to the gross carrying amount of
financial assets recognised at AC or FVOCI.
56
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2. Accounting policies - continued
2.9Financial instruments - continued
2.9.1 Financial assets
(a) Business model
The business model reflects how the Group manages assets in order to generate cash
flows. That is, it reflects whether the Group’s objective is solely to collect the
contractual cash flows from assets or to collect both the contractual cash flows and cash
flows arising from the sale of assets. If neither of these is applicable (for example,
financial assets are held for trading purposes), the financial assets are classified as part
of the other business model and measured at FVTPL.
Factors considered by the Group in determining the business model for a group of
assets include past experience on how the cash flows for these assets were collected,
how the asset’s performance is evaluated and reported to key management personnel,
how risks are assessed and managed, and how managers are compensated. For example,
the business model for the investments underlying investment contracts with DPF is to
hold to collect and sell contractual cash flows. The proceeds from the contractual cash
flows of the financial assets are used to settle insurance contract liabilities as they
become due.
(b) Solely payments of principal and interest ('SPPI')
Where the business model is to hold assets to collect contractual cash flows or to collect
contractual cash flows and sell, the Group assesses whether the financial instruments’
cash flows represent SPPI (the SPPI test). In making this assessment, the Group
considers whether the contractual cash flows are consistent with a basic lending
arrangement (that is, interest includes only consideration or the time value of money,
credit risk, other basic lending risks and a profit margin that is consistent with a basic
lending arrangement). Where the contractual terms introduce exposure to risk or
volatility that are inconsistent with a basic lending arrangement, the related financial
asset is classified and measured at FVTPL.
(c)  Debt instruments
Debt instruments are those instruments that meet the definition of a financial liability
from the issuer’s perspective, such as government and corporate bonds.
The classification and subsequent measurement of debt instruments depend on:
– the Group’s business model for managing the asset; and
– the cash flow characteristics of the asset (represented by SPPI).
57
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2. Accounting policies - continued
2.9Financial instruments - continued
2.9.1 Financial assets - continued
(c)  Debt instruments - continued
Based on these factors, the Group classifies its debt instruments into one of the following
three measurement categories:
a. AC: Assets that are held for collection of contractual cash flows where those cash flows
represent SPPI, and that are not designated at FVTPL, are measured at AC. The carrying
amount of these assets is adjusted by any ECL allowance recognised and measured, as
described further below. Interest revenue from these financial assets is included in the
profit or loss under interest revenue calculated using the effective interest method.
b. FVOCI: Financial assets that are held for collection of contractual cash flows and for
selling the assets, where the assets’ cash flows represent SPPI, and that are not
designated at FVTPL, are measured at FVOCI. Movements in the carrying amount are
taken through OCI, except for the recognition of impairment gains or losses, interest
revenue and foreign exchange gains and losses on the instrument’s AC, which are
recognised in profit or loss. When the financial asset is derecognised, the cumulative
gain or loss previously recognised in OCI is reclassified from equity to profit or loss and
recognised in other investment revenue. Interest revenue from these financial assets is
included in interest revenue calculated using the effective interest method.
c. FVTPL: Assets that do not meet the criteria for AC or FVOCI are measured at FVTPL.
Also, some assets are voluntarily measured at FVTPL, because this significantly reduces
an accounting mismatch. A gain or loss on a debt investment that is subsequently
measured at FVTPL is recognised and presented in the consolidated statement of profit
or loss within other investment revenue in the period in which it arises.
The Group reclassifies debt instruments only when its business model for managing
those assets changes. The reclassification takes place from the start of the first reporting
period following the change. Such changes are expected to be very infrequent, and none
occurred during the period.
(d) Equity instruments
Equity instruments are instruments that meet the definition of equity from the issuer’s
perspective (that is, instruments that do not contain a contractual obligation to pay and
that evidence a residual interest in the issuer’s net assets). Examples of equity
instruments include basic ordinary shares.
The Group subsequently measures all equity investments at FVTPL. Gains and losses on
equity investments at FVTPL are included in the line ‘Other investment revenue’ in the
consolidated statement of profit or loss.
58
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.    Accounting policies - continued
2.9Financial instruments - continued
2.9.1 Financial assets - continued
(e) Cash and cash equivalents
Cash and cash equivalents include cash balances and financial instruments with original
maturities of three months or less from the date of acquisition that are subject to an
insignificant risk of changes in their fair value, and are used by the Group in the
management of its short-term commitments. Cash and cash equivalents are carried in the
statement of financial position at AC net of ECL.
(f) Fair Value Measurement
For financial instruments traded in active markets, the determination of fair values of
financial assets and financial liabilities is based on quoted market prices or dealer price
quotations. This includes listed equity securities and quoted debt instruments on major
exchanges. The quoted market price used for financial assets held by the Group is the
current bid price or closing price as appropriate. A financial instrument is regarded as
quoted in an active market if quoted prices are readily and regularly available from an
exchange, dealer, broker, industry group, pricing service or regulatory agency, and those
prices represent actual and regularly occurring market transactions on an arm’s length
basis. If the market for a financial asset is not active, the Group establishes fair value by
using valuation techniques.  These include the use of recent arm’s length transactions,
reference to other instruments that are substantially the same or valued by reference to
the net assets of the underlying investment. 
(g) Impairment
(i) Debt instruments and cash and cash equivalents
The Group assesses the ECL associated with its debt instruments measured at AC and
debt instrument assets carried at FVOCI. The Group recognises a loss allowance for
such losses at each reporting date. The measurement of the ECL reflects:
a. an unbiased evaluation of a range of possible outcomes and their probabilities of
occurrence;
  b. discounting for the time value of money; and
  c. reasonable and supportable information that is available without undue cost or effort
at the reporting date about past events, current conditions and forecasts of future
economic conditions
59
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2. Accounting policies - continued
2.9Financial instruments - continued
2.9.1 Financial assets - continued
(g) Impairment - continued
(i) Debt instruments and cash and cash equivalents- continued
However, IFRS 9 emphasises that estimating ECL may not necessarily need to be a
complex process and that an entity need not identify every possible scenario. In some
cases, relatively simple modelling may be sufficient without the need for many detailed
simulations or scenarios.
The Group calculates the ECL at an instrument level, using three main components:
– a probability of default (‘PD’),
– a loss given default (‘LGD’),
– and the exposure at default (‘EAD’).
At initial recognition, an allowance is required for ECL resulting from default events
that are possible within the next 12 months, or less, where the remaining life is less than
12 months (‘12-month ECL’).
In the event of a ‘significant increase in credit risk’ (SICR), an allowance is required for
ECL resulting from all possible default events over the expected life of the financial
instrument (‘Lifetime ECL’). In the case of a non-maturity deposit, the Group assumes a
lifetime of 1 month.
Financial assets where 12-month ECL is recognised are considered to be ‘stage 1’;
financial assets which are considered to have experienced a SICR are classified as ‘stage
2’; and financial assets for which there is objective evidence of impairment, and which
are so considered to be in default or otherwise credit impaired, are classified as ‘stage 3’.
The ECL allowance and any changes to it are recognised by recognising impairment
gains and losses in profit or loss.
(ii) Trade receivables
For trade receivables, the Company applies the simplified approach required by IFRS 9,
which requires expected lifetime losses to be recognised from initial recognition of the
receivables. An impairment analysis is performed at each reporting date using a
provision matrix to measure expected credit losses. The provision rates are based on
days past due for groupings of various customer segments with similar loss patterns. The
Company considers trade receivables in default when contractual payments are past their
credit terms.
60
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2. Accounting policies - continued
2.9Financial instruments - continued
2.9.1 Financial assets - continued
(g) Impairment - continued
(ii) Trade receivables - continued
Trade receivables are written off when there is no reasonable expectation of recovery.
Indicators that there is no reasonable expectation of recovery include, among others, the
probability of insolvency or significant financial difficulties of the debtor. 
(h) Derecognition
Financial assets, or a portion thereof, are derecognised when the contractual rights to
receive the cash flows from the assets have expired, or when they have been transferred
and either (i) the Group transfers substantially all of the risks and rewards of ownership;
or (ii) the Group neither transfers nor retains substantially all of the risks and rewards of
ownership and the Group has not retained control.
The Group enters into transactions where it retains the contractual rights to receive cash
flows from assets but assumes a contractual obligation to pay those cash flows to other
entities and transfers substantially all of the risks and rewards. These transactions are
accounted for as pass-through transfers that result in derecognition if the Group:
a. has no obligation to make payments unless it collects equivalent amounts from the
assets;
b. is prohibited from selling or pledging the assets; and
c.  has an obligation to remit any cash that it collects from the assets without material
delay
(i)  Modification
If cash flows are modified when the debtor is in financial difficulties, then the objective
of the modification is usually to maximise recovery of the original contractual cash
flows rather than to originate a new asset with substantially different terms. If the Group
plans to modify a financial asset in a way that would result in forgiveness of cash flows,
then it first considers whether a portion of the asset should be written off before the
modification takes place.
2.9.2 Financial liabilities
(a)  Classification and subsequent measurement
Financial liabilities are classified and subsequently measured at AC, except for
derivatives and investment contracts without DPF, which are measured at FVTPL.
61
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2Accounting policies - continued
2.9Financial instruments - continued
2.9.2 Financial liabilities - continued
(a)  Classification and subsequent measurement - continued
Investment contracts without DPF are financial liabilities whose fair value is dependent
on the fair value of underlying financial assets and are designated at inception at
FVTPL. The Group designates these investment contracts to be measured at FVTPL,
because it eliminates or significantly reduces a measurement or recognition
inconsistency (that is, an accounting mismatch) that would otherwise arise from
measuring assets or liabilities or recognising the gains and losses on them on different
bases.
The Group’s main valuation techniques incorporate all factors that market participants
would consider and make maximum use of observable market data. The fair value of
financial liabilities for investment contracts without DPF is determined using the
current unit values in which the contractual benefits are denominated. These unit values
reflect the fair values of the financial assets contained within the Group’s unitised
investment funds linked to the financial liability. The fair value of the financial
liabilities is obtained by multiplying the number of units attributed to each contract
holder at the end of the reporting period by the unit value for the same date.
When the investment contract has a surrender option, the fair value of the financial
liability is never less than the amount payable on surrender.
Changes in the fair value of financial liabilities measured at FVTPL are presented in the
statement of profit or loss.
(b)  Derecognition
Financial liabilities are derecognised when they are extinguished (that is, when the
obligation specified in the contract is discharged, is cancelled or expires). The Group
also derecognises a financial liability when its terms are modified and the cash flows of
the modified liability are substantially different, in which case a new financial liability
based on the modified terms is recognised at fair value.
On derecognition of a financial liability, the difference between the carrying amount
extinguished and the consideration paid (including any non-cash assets transferred or
liabilities assumed) is recognised in profit or loss.
(c) Modification
If a financial liability measured at amortised cost is modified but not substantially, then
it is not derecognised.
62
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2Accounting policies - continued
2.9Financial instruments - continued
2.9.2 Financial liabilities - continued
(d)  Derivatives
Derivatives are initially recognised at fair value on the date on which the derivative
contract is entered into and are subsequently remeasured at fair value. All derivatives
are carried as assets when fair value is positive and as liabilities when fair value is
negative. Fair values are obtained from quoted market prices in active markets, and
other valuation techniques, as appropriate.  Subsequent changes in the fair value of any
derivative instruments are recognised immediately in profit or loss.
2.10  Insurance and investment contracts issued and reinsurance contracts held
The Group issues contracts that transfer insurance risk or financial risk or both.
(a)Definition and classification
The following table provides an overview of the Group’s assessment of its products
and whether these fall in scope of IFRS 17:
63
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.Accounting policies - continued
2.10 Insurance and investment contracts issued and reinsurance contracts held -
continued
(a)Definition and classification - continued
Type of
contract
Contracts
issued
Within scope
of IFRS 17
Measurement
model
Description of benefit
Short-term
insurance
contracts
Insurance
contracts -
Non-Life and
Group Life 
contracts
Yes
PAA
Pure insurance contracts carrying
significant insurance risk where the
obligation of the Group towards the insured
is the payment for loss incurred if the
insured event occurs whilst the policy is in
force.
Long-term
insurance
contracts -
Life risk
Insurance
contracts -
Term
assurance
including
term riders
Yes
General
Measurement
Model
('GMM')
Pure insurance contracts carrying
significant insurance risk where the
obligation of the Group towards the insured
is the payment of a death benefit, if the
death occurs whilst the policy is in force.
Long-term
insurance
contracts -
Life risk
Unit-linked –
Maximum
Investment
Plan
Yes
GMM
A unit-linked contract with significant
insurance risk is one that incorporates a
material sum assured within the contract
(i.e. the sum assured/minimum death
benefit provided, exceeds the investment
value of the product).
Direct
participating
contracts
With-profits
(Investment
contracts
with DPF)
Yes
Variable Fee
Approach
('VFA')
Investment contracts with DPF where the
obligation of the Group towards the
insured also includes an annual
discretionary investment return (declared
bonus rate).
Direct
participating
contracts
Hybrids
(Investment
contracts
with DPF)
Yes
VFA
These are mainly unit-linked products
including with-profits components
(investment contract with DPF).
Investment
contracts
Unit-linked -
others
(Investment
contracts
without DPF)
No
FVTPL
Investment contracts which pays the
policyholder 1% of the fund value at the
time of death, this component is deemed to
be immaterial to the overall value of the
fund and therefore, no significant insurance
risk is deemed to arise from it. Therefore,
these contracts are  valued in line with
IFRS 9 'Financial Instruments'.
64
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.Accounting policies - continued
2.10Insurance and investment contracts issued and reinsurance contracts held
        - continued
(a)Definition and classification - continued
Insurance contracts are contracts under which the Group accepts significant insurance
risk from a policyholder by agreeing to compensate the policyholder if a specified
uncertain future event adversely affects the policyholder. In making this assessment, all
substantive rights and obligations, including those arising from law or regulation, are
considered on a contract by contract basis. Judgement is used to assess whether a
contract transfers insurance risk and whether the accepted insurance risk is significant.
Generally, the Group defines as significant insurance risk the possibility of having to
pay benefits on the occurrence of an insured event that at least 5% more than the
benefits payable (on a present value basis) if the insured event did not occur. The
Group accounts for these contracts under IFRS 17.
The Group also issues term riders which represent an add-on to a basic policy that
provides additional benefits to policyholders (at additional cost). They can be
purchased by a policyholder concurrently to a basic policy or at a subsequent date, i.e.
a date after the inception of the basic policy. The addition of a term rider triggers
medical underwriting at the point in time the rider is added, giving the Group the
ability to reprice the policy at that point in time. The Group has concluded that term
riders are to be separated from the host contract and will form part of the term
portfolio.
Contracts that have a legal form of insurance but do not transfer significant insurance
risk and expose the Group to financial risk are classified as investment contracts, and
they follow financial instruments accounting under IFRS 9, unless they have DPF as
described below, in which case they are accounted for as insurance contracts.
A number of investment contracts contain a DPF. This feature entitles the holder to
receive, as a supplement to guaranteed benefits (i.e. amounts not subject to the Group's
deiscretion), additional benefits or bonuses:
– that are likely to be a significant portion of the total contractual benefits;
– whose amount or timing is contractually at the discretion of the Group; and
– that are based on realised and/or unrealised investment returns on specified pools
of underlying assets held by the Group.
The Group also issues a ‘hybrid’ product which is a unit-linked product that gives
policyholders the possibility to initially allocate, and subsequently switch, a portion of
the premium to a ‘with-profits’ DPF holding as well as a unit-linked holding. This
product was deemed to fall within scope of IFRS 17 when the policyholder allocates a
percentage holding in the with-profits fund as at inception or transition date.
Furthermore, management concluded that the unit-linked component of the product
does not constitute a distinct investment component, given that both elements of the
‘hybrid’ product cannot be measured and presented separately and are interdependent
on each other.
65
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.Accounting policies - continued
2.10Insurance and investment contracts issued and reinsurance contracts held
        - continued
(a)Definition and classification - continued
Since this product is primarily a unit-linked product with the option to hold a
percentage of the holding in the with-profits fund, management has determined that for
such a contract to be in scope of IFRS 17, it needs to hold a 5% level of significant
discretionary benefit.
Local statutory regulations and the terms and conditions of both investment contracts
with DPF and hybrids set out the basis for the determination of the amounts on which
the additional discretionary benefits are based (the DPF eligible surplus), and within
which the Group may exercise its discretion as to the quantum and timing of their
payment to contract holders, also considering the advice of the Approved Actuary.  The
Group accounts for these contracts under IFRS 17, as it also issues insurance contracts.
The Group assesses investment contracts that qualify as having direct participation
features as a result of the nature of their design (i.e. they are primarily investment
related contracts where the investment risk is substantially borne by the policyholder) to
ascertain whether or not they meet the VFA eligibility criteria.
IFRS 17 requires these criteria to be assessed at the individual contract level. The
Group assessed the criteria at the product level. The assessment is carried out based on
the Group's expectations at inception, and is not reassessed subsequently, unless the
product is modified.
The with-profits policies are ring fenced, meaning, a barrier clearly segregates the
policyholder assets participating in the fund from the shareholders’ ones. Therefore, the
pool of assets is clearly identifiable. The ‘underlying items’ in this case would be the
with-profits assets.
Investment contracts with direct participation features are viewed as creating an
obligation to pay policyholders an amount that is equal to the fair value of the
underlying items, less a variable fee for service. The variable fee comprises the amount
of the Group’s share of the fair value of the underlying items less the fulfillment cash
flows ('FCF') that do not vary based on the returns on underlying items. Therefore, on
an average probability-weighted basis, the Group considers that the amount it expects to
pay to policyholders comprises a substantial portion of the fair value returns on
underlying items.
The variability in cash flows is assessed over the duration of the insurance contracts and
on the basis of the average of the probability-weighted present value. The duration of
the contract takes into account all the cash flows in the contract boundary. The major
component of the liability (the present value of the future net cash outflows) is made up
of claims which vary substantially with the underlying items.
66
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.Accounting policies - continued
2.10Insurance and investment contracts issued and reinsurance contracts held
        - continued
(a)Definition and classification - continued
In the normal course of business, the Group uses reinsurance to mitigate its risk
exposures. A reinsurance contract transfers significant risk if it transfers substantially
all of the insurance risk resulting from the insured portion of the underlying insurance
contracts, even if it does not expose the reinsurer to the possibility of a significant loss.
For short-term insurance contracts, the Group uses the PAA simplified method to
measure groups of contracts. All short-term insurance contracts originated by the
Group, are without direct participation features.
All references to insurance contracts in these consolidated financial statements apply to
insurance contracts issued or acquired, reinsurance contracts held and investment
contracts with DPF, unless specifically stated otherwise.
(b)    Unit of account
The Group manages insurance contracts issued by product type, where each product
type includes contracts which are subject to similar risks and are managed together. The
Group has determined that contracts have similar risk and are managed together if they
are priced together, have the same underwriting process, have common reporting, and
claims and risks underlying the contracts are managed together. All insurance contracts
of the same product type represent a portfolio. Each portfolio is further disaggregated
into groups of contracts that are issued within a calendar year (annual cohorts) and are
at initial recognition:
– contracts that are onerous; or
– all remaining contracts.
In variation to the above, as further described below, in contrast with all other contracts
in scope of IFRS 17, investment contracts with DPF are not grouped by annual cohort.
As per Article 2 of the Commission Regulation (EU) 2021/2036 and 2023/1803, a
Group may choose not to apply the annual cohorting requirement to groups of
investment contracts with discretionary participation features and with cash flows that
affect or are affected by cash flows to policyholders of other contracts.
The Group’s with-profits fund is a pool of policies sharing in the same pool of
underlying items. Therefore, the risk that a particular policy becomes onerous (i.e. the
possibility of the with-profits fund assets being lower than the present value of its future
liabilities) is shared between the policyholders within this pool. In such instances,
policies, which do not exhibit such onerosity, will make good for those policies which
are onerous.
67
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.Accounting policies - continued
2.10Insurance and investment contracts issued and reinsurance contracts held
        - continued
(b) Unit of account - continued
Given that the Group’s with-profits fund has all mutualisation features described above,
the Group has chosen to apply the option to avoid allocating policies to annual cohorts
as these are groups of investment contracts with DPF and with cash flows that affect or
are affected by cash flows to policyholders of other contracts. All with-profits and
hybrid policies will therefore be allocated to a single cohort.
Portfolios of reinsurance contracts held are assessed for aggregation separately from
portfolios of insurance contracts issued. Separate portfolios for reinsurance contracts
held were therefore established and the Group has a number of reinsurance portfolios.
In groups of reinsurance contracts held, the amount an entity pays generally exceeds the
expected present value of the cash flows generated by that reinsurance contract plus the
risk adjustment for non-financial risk and thus the Group is usually in a net cost
position. The Group has determined that the reinsurance contracts held will be grouped
by calendar or underwriting year (annual cohorts) depending whether they are loss
occurring or risk attaching under the category ‘all remaining contracts’ which includes
reinsurance contracts held with an initial net cost but with a possibility of a future net
gain.
Transition approaches that were applied by the Group on adoption of IFRS 17 with
respect to contracts aggregation requirements are included in Note 6.
Before the Group accounts for an insurance contract based on the guidance in IFRS 17,
it analyses whether the contract contains components that should be separated. IFRS 17
distinguishes three categories of components that have to be accounted for separately:
-    cash flows relating to embedded derivatives that are required to be separated;
-    cash flows relating to distinct investment components; and
-  promises to transfer distinct goods or distinct services other than insurance contract
services.
The Group applies IFRS 17 to all remaining components of the contract. The Group
does not have any contracts that require further separation (except for term riders – refer
to note 2.10(a). The Group also does not have any contracts that require combination.
68
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.      Accounting policies - continued
2.10Insurance and investment contracts issued and reinsurance contracts held
        - continued
(c)    Recognition, modification and derecognition
Recognition
Groups of insurance contracts issued are initially recognised from the earliest of the
following:
-    the beginning of the coverage period;
-    the date when the first payment from the policyholder is due or actually received, if
there is no due date; and
-    when the Group determines that a group of contracts becomes onerous.
Investment contracts with DPF are initially recognised at the date when the Group
becomes a party to the contract.
Reinsurance contracts held are recognised from the later of the following:
        -  the beginning of the coverage period of the group; and
-    the initial recognition of any underlying insurance contract;
Unless the Group entered into the reinsurance contract held at or before the date when
an onerous group of underlying contracts is recognised prior to the beginning of the
coverage period of the group of reinsurance contracts held, in which case the
reinsurance contract held is recognised at the same time as the group of underlying
insurance contracts is recognised. 
Only contracts that individually meet the recognition criteria by the end of the reporting
period are included in the groups. When contracts meet the recognition criteria in the
groups after the reporting date, they are added to the groups in the reporting period in
which they meet the recognition criteria, subject to the annual cohorts restriction.
Composition of the groups is not reassessed in subsequent periods.
Modification and derecognition
An insurance contract is derecognised when it is extinguished (that is, when the
obligation specified in the insurance contract expires or is discharged or cancelled), or
when the contractual terms are modified in a way that would have changed the
accounting for the contract significantly had the new terms always existed, in which
case a new insurance contract is recognised.
If a contract modification is not significant, the changes in cash flows caused by the
modification are treated as changes in estimates of FCF.
69
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.      Accounting policies - continued
2.10Insurance and investment contracts issued and reinsurance contracts held
        - continued
(c)    Recognition, modification and derecognition - continued
Modification and derecognition - continued
When an insurance contract is derecognised from within a group of insurance contracts, the
Group:
– adjusts the FCF to eliminate the present value of future cash flows and risk adjustment
for non-financial risk relating to the rights and obligations removed from the group;
– adjusts the CSM; and
– adjusts the number of coverage units for the expected remaining insurance contract
services, to reflect the number of coverage units removed.
On the other hand, when an insurance contract accounted for under the PAA is
derecognised, adjustments to the future cash flows to remove related rights and
obligations to account for the effect of the derecognition result in the following amounts
being charged immediately to profit or loss:
a. if the contract is extinguished, any net difference between the derecognised part of
the Liability for Remaining Coverage (LRC) of the original contract and any other
cash flows arising from extinguishment.
b. if the contract is transferred to the third party, any net difference between the
derecognised part of the LRC of the original contract and the premium charged by
the third party; or
c. if the original contract is modified resulting in its derecognition, any net difference
between the derecognised part of the LRC and the hypothetical premium that the
entity would have charged if it had entered into a contract with equivalent terms as
the new contract at the date of the contract modification, less any additional
premium charged for the modification.
(d)Measurement
Fulfilment cash flows
Fulfilment cash flows (‘FCF’) are the current estimates of the future cash flows within
the contract boundary of a group of contracts that the Group expects to collect from
premiums and pay out for claims, benefits and expenses, adjusted to reflect the timing
and the uncertainty of those amounts.
Estimates of future cash flows:
a. are based on a probability-weighted average of all possible outcomes;
b. are reflective of the Group’s perspective, provided estimates of any relevant market
variables are consistent with observable market prices for those variables; and
c. are reflective of conditions existing at measurement date.
70
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.      Accounting policies - continued
2.10Insurance and investment contracts issued and reinsurance contracts held
        - continued
(d)Measurement - continued
Fulfilment cash flows - continued
An explicit risk adjustment for non-financial risk is estimated separately from the other
estimates for Assets for Remaining Coverage ('ARC') and Liability for Remaining
Coverage ('LRC'). For contracts measured under the PAA, unless the contracts are
onerous, the explicit risk adjustment for non-financial risk is only estimated for the
measurement of the Liability for Incurred Claims ('LIC').
The estimates of future cash flows are also adjusted using current discount rates to
reflect the time value of money and financial risks relating to these cash flows. The
discount rates reflect the characteristics of the cash flows arising from the groups of
insurance contracts, including timing, currency and liquidity of cash flows. The
determination of the discount rate that reflects the characteristics of the cash flows and
liquidity characteristics of the insurance contracts requires judgement and estimation.
Risk of non-performance is not included in the measurement of groups of insurance
contracts issued. In the measurement of reinsurance contracts held, the probability-
weighted estimates of the present value of future cash flows include the potential credit
losses and other disputes of the reinsurer to reflect the non-performance risk of the
reinsurer.
The Group estimates certain FCF at the portfolio level or higher and then allocates such
estimates to groups of contracts.
The Group uses consistent assumptions to measure the estimates of the present value of
future cash flows for the group of reinsurance contracts held and such estimates for the
groups of underlying insurance contracts.
Contract boundary
The Group uses the concept of contract boundary to determine what cash flows should
be considered in the measurement of groups of insurance contracts.
Cash flows are within the boundary of an insurance contract if they arise from
substantive rights and obligations that exist during the reporting period in which the
Group can compel the policyholder to pay the premiums or in which the Group has a
substantive obligation to provide the policyholder with insurance contract services.
71
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.      Accounting policies - continued
2.10Insurance and investment contracts issued and reinsurance contracts held
        - continued
(d)Measurement - continued
Contract boundary - continued
A substantive obligation lasts until:
a) the Group has the practical ability to reassess the risks of a particular policyholder,
and hence, can set a price to fully reflect those risks; or
b) both of the following criteria are satisfied:
i. the Group has a practical ability to reassess the risks of the portfolio of insurance
contracts, as a result of which it can set a price to fully reflect those risks; and
ii. the pricing of premiums up to the date when the risks are reassessed does not take
into account the risks that relate to periods after the reassessment date.
In assessing the practical ability to reprice, risks transferred from the policyholder to the
Group, such as insurance risk and financial risk, are considered; other risks, such as
lapse or surrender and expense risk, are not included.
For contracts issued under the PAA, riders, representing add-on provisions to a basic
insurance policy that provide additional benefits to the policyholder at additional cost,
that are issued together with the main insurance contracts, form part of a single
insurance contract with all the cash flows within its boundary.
Cash flows outside the insurance contracts boundary relate to future insurance contracts
and are recognised when those contracts meet the recognition criteria.
Cash flows are within the boundaries of investment contracts with DPF if they result
from a substantive obligation of the Group to deliver cash at a present or future date.
For groups of reinsurance contracts held, cash flows are within the contract boundary if
they arise from substantive rights and obligations of the Group that exist during the
reporting period in which the Group is compelled to pay amounts to the reinsurer or in
which the Group has a substantive right to receive insurance contract services from the
reinsurer.
The Group's quota share, surplus and facultative reinsurance contracts have an annual
term and cover underlying contracts issued within the term on a risk-attaching basis.
Meaning that they cover policies ceded for the entire duration of the contract, even if
this duration exceeds that of the reinsurance contract itself.
72
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.      Accounting policies - continued
2.10Insurance and investment contracts issued and reinsurance contracts held
        - continued
(d)Measurement - continued
Contract boundary - continued
The Group treats such reinsurance contracts as a series of annual contracts that cover
underlying business issued within a year. Estimates of future cash flows arising from all
underlying contracts issued and expected to be issued within the reinsurance contracts’
one-year boundary are included in the measurement of the reinsurance contracts.
The excess of loss contracts held provide coverage for claims incurred during an
accident year. Thus, all cash flows arising from claims incurred and expected to be
incurred in the accident year are included in the measurement of the reinsurance
contracts held. Some of these contracts include mandatory reinstatement reinsurance
premiums, which are included within the respective reinsurance contracts’ boundaries.
Cash flows that are not directly attributable to a portfolio of insurance contracts are
recognised in other operating expenses as incurred.
Insurance acquisition costs
Insurance acquisition cash flows are cash flows arising from the costs of selling,
underwriting and starting a group of insurance contracts that are directly attributable to
the portfolio of insurance contracts to which the group belongs. Insurance acquisition
cash flows for the Group comprise commission paid to intermediaries for new business
and salaries of employees whose efforts are directly related to the acquisition of new
insurance business.
Insurance acquisition cash flows that are directly attributable to a group of insurance
contracts shall be allocated to that group. IFRS 17 requires that insurance acquisition
cash flows are also allocated to groups that will include insurance contracts that are
expected to arise from renewals of the insurance contracts in that group. The latter does
not apply to the Group as it does not incur acquisition costs in relation to future
renewals.
Insurance acquisition cash flows not directly attributable to a group of contracts but
directly attributable to a portfolio of contracts are allocated to groups of contracts in the
portfolio or expected to be in a portfolio.
The Group does not incur any material directly attributable acquisition cash flows, or
other inflows or outflows, before a group of insurance contracts is recognised.
Consequently, it does not recognise any ‘pre-recognition cash flows’.
73
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.      Accounting policies - continued
2.10Insurance and investment contracts issued and reinsurance contracts held
        - continued
(d)Measurement - continued
Risk adjustment for non-financial risk
The risk adjustment for non-financial risk is applied to the present value of the
estimated future cash flows, and it reflects the compensation that the Group requires for
bearing the uncertainty about the amount and timing of the cash flows from non-
financial risk as the Group fulfils insurance contracts.
For reinsurance contracts held, the risk adjustment for non-financial risk represents the
amount of risk being transferred by the Group to the reinsurer.
Methods and assumptions used to determine the risk adjustment for non-financial risks
are discussed in Note 24.
Contracts not measured under the PAA
Initial measurement and CSM
The CSM is a component of the carrying amount of the asset or liability for a group of
insurance contracts issued representing the unearned profit that the Group will
recognise as it provides insurance contract services in the future. At initial recognition,
the CSM is an amount that results in no income or expenses arising from:
-    the initial recognition of the FCF;
-    cash flows arising from the contracts in the group at that date;
When the above calculation results in a net outflow, the group of insurance contracts
would be onerous. A loss arising from onerous insurance contracts is recognised
immediately in profit or loss, with no CSM recognised in the statement of financial
position and a loss component is established in the amount of loss recognised.
No onerous contracts have been identified by the Group.
For groups of reinsurance contracts held, any net gain or loss at initial recognition is
recognised as the CSM unless the net cost of purchasing reinsurance relates to past
events, in which case the Group recognises the net cost immediately in profit or loss.
For reinsurance contracts held, the CSM represents a deferred gain or loss that the
Group will recognise as a reinsurance expense as it receives insurance contract services
from the reinsurer in the future.
74
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.      Accounting policies - continued
2.10Insurance and investment contracts issued and reinsurance contracts held
        - continued
(d)Measurement - continued
Contracts not measured under the PAA - continued
Subsequent measurement
The carrying amount at the end of each reporting period of a group of insurance contracts
issued is the sum of:
– the LRC, comprising:
– the FCF related to future service allocated to the group at that date; and
– the CSM of the group at that date; and
– the liability for incurred claims ('LIC'), comprising the FCF related to past service
allocated to the group at the reporting date.
The carrying amount at the end of each reporting period of a group of reinsurance contracts
held is the sum of:
– the remaining coverage, comprising:
– the FCF related to future service allocated to the group at that date; and
– the CSM of the group at that date; and
– the incurred claims, comprising the FCF related to past service allocated to the group at
the reporting date.
i. Changes in fulfilment cash flows
The FCF are updated by the Group for current assumptions at the end of every reporting
period, using the current estimates of the amount, timing and uncertainty of future cash
flows and of discount rates.
The way in which the changes in estimates of the FCF are treated depends on which
estimate is being updated:
– changes that relate to current or past service are recognised in profit or loss; and
– changes that relate to future service are recognised by adjusting the CSM or the loss
component within the LRC as per the policy below.
75
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.      Accounting policies - continued
2.10Insurance and investment contracts issued and reinsurance contracts held
        - continued
(d)Measurement - continued
Contracts not measured under the PAA - continued
Subsequent measurement - continued
i. Changes in fulfilment cash flows - continued
For insurance contracts measured under the General Measurement Model (‘GMM’), the
following adjustments relate to future service and thus adjust the CSM:
a. experience adjustments – arising from premiums received in the period that relate to
future service and related cash flows;
b. changes in estimates of the present value of future cash flows in the LRC, except
those described in the following paragraph;
c. differences between any investment component expected to become payable in the
period and the actual investment component that becomes payable in the period; and
d. changes in the risk adjustment for non-financial risk that relate to future service.
Adjustments a. and b. above are measured using discount rates determined on initial
recognition (the locked in discount rates).
For insurance contracts under the GMM, the following adjustments do not adjust the
CSM:
a. changes in the FCF for the effect of the time value of money and the effect of
financial risk and changes thereof;
b. changes in the FCF relating to the LIC;
c. experience adjustments arising from premiums received in the period that do not
relate to future service and related cash flows; and
d. experience adjustments relating to insurance service expenses (excluding insurance
acquisition cash flows).
When measuring a group of investment contracts with DPF, the Group adjusts the
fulfilment cash flows for the whole of the changes in the obligation to pay policyholders
an amount equal to the fair value of the underlying items. These changes do not relate
to future services and are recognised in profit or loss. The Group then adjusts any CSM
for changes in the amount of the Group’s share of the fair value of the underlying items,
which relate to future services, as explained below.
76
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.      Accounting policies - continued
2.10Insurance and investment contracts issued and reinsurance contracts held
        - continued
(d)Measurement - continued
Contracts not measured under the PAA - continued
Subsequent measurement - continued
i. Changes in fulfilment cash flows - continued
For contracts measured under the VFA, the following adjustments relate to future
service and thus adjust the CSM:
– changes in the amount of the Group’s share of the fair value of the underlying
items; and
– changes in the FCF that do not vary based on the returns of underlying items:
a. changes in the effect of the time value of money and financial risks including the
effect of financial guarantees;
b. experience adjustments arising from premiums received in the period that relate to
future service and related cash flows;
c. changes in estimates of the present value of future cash flows in the LRC, except
those described in the following paragraph;
d.differences between any investment component expected to become payable in the
period and the actual investment component that becomes payable in the period;
and
e.  changes in the risk adjustment for non-financial risk that relate to future service.
Adjustments b. to e. are measured using the current discount rates.
For contracts under the VFA, the following adjustments do not adjust the CSM:
– changes in the obligation to pay the policyholder the amount equal to the fair value
of the underlying items;
– changes in the FCF that do not vary based on the returns of underlying items:
– changes in the FCF relating to the LIC; and
– experience adjustments arising from premiums received in the period that do not
relate to future service and related cash flows; and
– experience adjustments relating to insurance service expenses (excluding
insurance acquisition cash flows).
The Group does not have any products with complex guarantees and does not use
derivatives as economic hedges of the risks.
77
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.      Accounting policies - continued
2.10Insurance and investment contracts issued and reinsurance contracts held
        - continued
(d)Measurement - continued
Contracts not measured under the PAA - continued
Subsequent measurement - continued
ii  Changes to the contractual service margin
For insurance contracts issued, at the end of each reporting period the carrying amount
of the CSM is adjusted by the Group to reflect the effect of the following changes:
a. The effect of any new contracts added to the group.
b. For contracts measured under the GMM, interest accreted on the carrying amount of
the CSM.
c. Changes in the FCF relating to future service are recognised by adjusting the CSM.
Changes in the FCF are recognised in the CSM to the extent that the CSM is
available. When an increase in the FCF exceeds the carrying amount of the CSM,
the CSM is reduced to zero, the excess is recognised in insurance service expenses
and a loss component is recognised within the LRC. When the CSM is zero,
changes in the FCF adjust the loss component within the LRC with correspondence
to insurance service expenses. The excess of any decrease in the FCF over the loss
component reduces the loss component to zero and reinstates the CSM.
d. The effect of any currency exchange differences.
e. The amount recognised as insurance revenue for insurance contract services
provided during the period, determined after all other adjustments above.
For a group of reinsurance contracts held, the carrying amount of the CSM at the end of
each reporting period is adjusted to reflect changes in the FCF in the same manner as a
group of underlying insurance contracts issued.
iii. Interest accretion on the CSM
Under the GMM, interest is accreted on the CSM using discount rates determined at
initial recognition that are applied to nominal cash flows that do not vary based on the
returns of underlying items. The Group uses the discount curves at the middle of each
quarter during the year. MMSV will be assuming equal weighting per quarter given the
stability of new business written.
78
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.      Accounting policies - continued
2.10Insurance and investment contracts issued and reinsurance contracts held
        - continued
(d)Measurement - continued
Contracts not measured under the PAA - continued
Subsequent measurement - continued
iv. Adjusting the CSM for changes in the FCF relating to future service
The CSM is adjusted for changes in the FCF, measured applying the discount rates as
specified in the Changes in fulfilment cash flows section above.
v. Release of the CSM to profit or loss
The amount of the CSM recognised in profit or loss for insurance contract services in
the period is determined by the allocation of the CSM remaining at the end of the
reporting period over the current and remaining expected coverage period of the group
of insurance contracts based on coverage units.
The coverage period is defined as a period during which the entity provides insurance
contract services. Insurance contract services include coverage for an insured event
(insurance coverage), the generation of an investment return for the policyholder, if
applicable (investment-return service) for the contracts under the GMM, and the
management of underlying items on behalf of the policyholder (investment-related
service) for the contracts under the VFA. The period of investment-return service or
investment-related service ends at or before the date when all amounts due to current
policyholders relating to those services have been paid. Investment-return services are
provided only when an investment component exists in insurance contracts or the
policyholder has a right to withdraw an amount, and the Group expects these amounts
to include an investment return that is achieved by the Group by performing investment
activities to generate that investment return.
For contracts issued, the Group determines the coverage period for the CSM
recognition as follows:
-  for investment contracts with DPF (including hybrids), the coverage period
corresponds to the period in which investment-return services are expected to be
provided; and
-    for term life risk contracts, no investment-return services are provided and, thus, the
coverage period is determined by insurance coverage;
79
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.      Accounting policies - continued
2.10Insurance and investment contracts issued and reinsurance contracts held
        - continued
(d)Measurement - continued
Contracts not measured under the PAA - continued
Subsequent measurement - continued
v. Release of the CSM to profit or loss - continued
The total number of coverage units in a group is the quantity of service provided by the
contracts in the group over the expected coverage period. The coverage units are
determined at each reporting period-end prospectively by considering:
– the quantity of benefits provided by contracts in the group;
– the expected coverage period of contracts in the group; and
– the likelihood of insured events occurring, only to the extent that they affect the
expected coverage period of contracts in the group.
The Group determines coverage units as follows:
– for term life insurance contracts, coverage units are determined based on the
policies’ face values that are equal to the fixed death benefit amounts in force and
– for investment contracts with DPF, including with-profits and unit-linked hybrids,
coverage units are based on the fund assets and value of the fund.
The Group does not reflect the time value of money in the allocation of the CSM to
coverage units.
For reinsurance contracts held, the CSM is released to profit or loss as insurance
contract services are received from the reinsurer in the period.
Coverage units for the proportionate term life reinsurance contracts held are based on
the insurance coverage provided by the reinsurer, and they are determined by the ceded
policies’ fixed face values in force, taking into account new business projected within
the reinsurance contract boundary.
The coverage period for these contracts is determined based on the coverage period of
all underlying contracts whose cash flows are included in the reinsurance contract
boundary.
80
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.      Accounting policies - continued
2.10Insurance and investment contracts issued and reinsurance contracts held
        - continued
(d)Measurement - continued
Contracts measured under the PAA
The Group uses the PAA for measuring contracts with a coverage period of one year or
less. In addition to the contracts with coverage of less than one year, the PAA can be
used for measurement of groups of contracts where the entity reasonably expects that
such a simplification would produce a measurement of the LRC that would not differ
materially from the one that would be produced by applying the GMM.
For insurance contracts issued, insurance acquisition cash flows allocated to a group are
deferred and recognised over the coverage period of contracts in a group.
For insurance contracts issued, on initial recognition, the Group measures the LRC at
the amount of premiums received, less any acquisition cash flows paid.
For reinsurance contracts held, on initial recognition, the Group measures the remaining
coverage at the amount of ceding premiums paid.
The carrying amount of a group of insurance contracts issued at the end of each
reporting period is the sum of:
a. the LRC; and
b. the LIC, comprising the FCF related to past service allocated to the group at the
reporting date.
The carrying amount of a group of reinsurance contracts held at the end of each
reporting period is the sum of:
a. the remaining coverage; and
b. the incurred claims, comprising the FCF related to past service allocated to the
group at the reporting date.
For insurance contracts issued, at each of the subsequent reporting dates, the LRC is:
a. increased for premiums received in the period;
b. decreased for insurance acquisition cash flows paid in the period;
c. decreased for the amounts of expected premium receipts recognised as insurance
revenue for the services provided in the period; and
d.increased for the amortisation of insurance acquisition cash flows in the period
recognised as insurance service expenses.
81
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.Accounting policies - continued
2.10Insurance and investment contracts issued and reinsurance contracts held
        - continued
(d)Measurement - continued
Contracts measured under the PAA - continued
For reinsurance contracts held, at each of the subsequent reporting dates, the remaining
coverage is:
a. increased for ceding premiums paid in the period;
b. decreased for the expected amounts of ceding premiums, net of reinsurance
commissions, recognised as reinsurance expenses for the services received in the
period.
The Group does not adjust the LRC for insurance contracts issued and the remaining
coverage for reinsurance contracts held for the effect of the time value of money,
because insurance premiums are due within the coverage period of contracts, which is
one year or less.
For contracts measured under the PAA, the LIC is measured similarly to the LIC’s
measurement under the GMM. Future cash flows are adjusted for the time value of
money, since insurance contracts issued by the Group and measured under the PAA
may have a settlement period of over one year.
If facts and circumstances indicate that a group of insurance contracts measured under
the PAA is onerous on initial recognition or becomes onerous subsequently, the Group
increases the carrying amount of the LRC by the loss component which is determined
by the percentage of onerosity as a function of the LRC for the remaining period.
Subsequently, the loss component is remeasured at each reporting date as the change in
the percentage of onerosity as a function of the LRC for the remaining period.
Movements in the loss component are recorded in the insurance service expenses.
Onerosity of a group of insurance contracts does not automatically indicate that a
reinsurance contract held, protecting such onerous underlying group of contracts will
result in a net gain at initial recognition. However, for reinsurance contract held for
which there is a net gain at initial recognition or becomes so subsequently, the carrying
amount of the asset for remaining coverage (ARC) for reinsurance contracts held
measured under the PAA is increased by the amount of loss-recovery component.  The
loss-recovery component is calculated by multiplying the percentage of onerosity as a
function of reinsurance ARC for the remaining period. Movements in the loss-recovery
component are recorded in the net reinsurance expenses.
The Company does not have any reinsurance contracts held measured under the PAA
with underlying contracts measured under the GMM.
82
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.Accounting policies - continued
2.10Insurance and investment contracts issued and reinsurance contracts held
        - continued
(e)  Amounts recognised in profit or loss
Insurance revenue
As the Group provides insurance contract services under the group of insurance
contracts, it reduces the LRC and recognises insurance revenue. The amount of
insurance revenue recognised in the reporting period depicts the transfer of promised
services at an amount that reflects the portion of consideration that the Group expects to
be entitled to in exchange for those services.
For contracts not measured under the PAA, insurance revenue comprises the following:
• Amounts relating to the changes in the LRC:
a. claims and other directly attributable expenses incurred in the period measured
at the amounts expected at the beginning of the period, excluding: 
– repayments of investment components and policyholder rights to withdraw an
amount;
– amounts of transaction-based taxes collected in a fiduciary capacity;
– insurance acquisition expenses; and
– amounts related to the risk adjustment for non-financial risk (see (b));
b. changes in the risk adjustment for non-financial risk, excluding:
– changes included in insurance finance income (expenses);and
– changes that relate to future coverage (which adjust the CSM);
c. amounts of the CSM recognised for the services provided in the period;
d. experience adjustments – arising from premiums received in the period other
than those that relate to future service; and
e. other amounts.
• Insurance acquisition cash flows recovery is determined by allocating the portion of
premiums related to the recovery of those cash flows on the basis of the passage of
time over the expected coverage of a group of contracts.
For groups of insurance contracts measured under the PAA, the Group recognises
insurance revenue based on the passage of time over the coverage period of a group of
contracts.
83
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.Accounting policies - continued
2.10Insurance and investment contracts issued and reinsurance contracts held -
continued
(e)  Amounts recognised in profit or loss - continued
Insurance service expense
Insurance service expenses include the following:
a. incurred claims and benefits, excluding investment components;
b. other incurred directly attributable expenses;
c.insurance acquisition cash flows amortisation;
d. changes that relate to past service – changes in the FCF relating to the LIC; and
e.  onerous contract losses or reversals of those losses.
For contracts measured under the PAA, amortisation of insurance acquisition cash
flows is based on the passage of time.
Other expenses that do not meet the above criteria are included as other operating
expenses in the consolidated statement of profit or loss.
Net income (expenses) from reinsurance contracts held
The Group presents financial performance of groups of reinsurance contracts held on a
net basis in net income (expenses) from reinsurance contracts held, comprising the
following amounts:
a. reinsurance expenses;
b. incurred claims recovery;
c. other incurred directly attributable expenses;
d. changes that relate to past service i.e. changes in the FCF relating to incurred
claims recovery; and
e. effect of changes in the risk of reinsurers’ non-performance.
Reinsurance expenses are recognised similarly to insurance revenue. The amount of
reinsurance expenses recognised in the reporting period depicts the transfer of received
insurance contract services at an amount that reflects the portion of ceding premiums
that the Group expects to pay in exchange for those services.
84
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.Accounting policies - continued
2.10Insurance and investment contracts issued and reinsurance contracts held -
continued
(e)Amounts recognised in profit or loss - continued
Net income (expenses) from reinsurance contracts held - continued
For contracts not measured under PAA, reinsurance expenses comprise the following
amounts relating to the changes in the remaining coverage:
a. claims and other directly attributable expenses recovery in the period, measured at
the amounts expected to be incurred at the beginning of the period, excluding
amounts related to the risk adjustment for non-financial risk (see b);
b. changes in the risk adjustment for non-financial risk, excluding:
– changes included in finance income (expenses) from reinsurance contracts held;
and
– changes that relate to future coverage (which adjust the CSM); 
c. amounts of the CSM recognised for the services received in the period; and
d. experience adjustments arising from premiums paid in the period other than those
relating to future service.
For groups of reinsurance contracts held measured under the PAA, the Group
recognises reinsurance expenses based on the passage of time over the coverage period
of a group of contracts.
Ceding commissions that are not contingent on claims of the underlying contracts issued
reduce ceding premiums and are accounted for as part of reinsurance expenses. Ceding
commissions that are contingent on claims of the underlying contracts issued reduce
incurred claims recovery.
Insurance finance income or expenses
Insurance finance income or expenses comprise the change in the carrying amount of
the group of insurance contracts arising from:
a. the effect of the time value of money and changes in the time value of money; and
b. the effect of financial risk and changes in financial risk.
For contracts measured under the PAA, the main amounts within insurance finance
income or expenses are:
a. interest accreted on the LIC; and
b. the effect of changes in interest rates and other financial assumptions.
The Group disaggregates changes in the risk adjustment for non-financial risk between
insurance service result and insurance finance income or expenses.
For contracts measured under the GMM, the main amounts within insurance finance
income or expenses are:
a. interest accreted on the FCF and the CSM; and
b. the effect of changes in interest rates and other financial assumptions.
85
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.Accounting policies - continued
2.10Insurance and investment contracts - continued
(e)Amounts recognised in profit or loss - continued
Insurance finance income or expenses - continued
For contracts measured under the VFA, insurance finance income or expenses comprise
changes in the value of underlying items (excluding additions and withdrawals).
The Group has opted to include all its insurance finance income and expenses in profit
or loss for all of its insurance contracts. The Group does not issue insurance contracts
that generate cash flows in a foreign currency.
2.11Current and deferred income tax
The tax expense for the period comprises current and deferred tax. Tax is recognised in
the profit or loss account, except to the extent that it relates to items recognised in other
comprehensive income or directly in equity. The amount of current tax payable or
receivable is the best estimate of the tax amount expected to be paid or received that
reflects uncertainty related to income taxes, if any.
The current income tax charge is calculated on the basis of the tax laws enacted or
substantively enacted at the statement of financial position date in the countries where
the Company’s subsidiaries and associates operate and generate taxable income. 
Management periodically evaluates positions taken in tax returns with respect to
situations in which applicable tax regulation is subject to interpretation and establishes
provision where appropriate.
Deferred income tax is recognised in respect of temporary differences arising between
the tax bases of assets and liabilities and their carrying amounts in the financial
statements.  However, if the deferred income tax arises from initial recognition of an
asset or liability in a transaction other than a business combination that at the time of
the transaction affects neither accounting nor taxable profit or loss, it is not accounted
for.  Deferred income tax is measured at the tax rates that are expected to be applied to
temporary differences when they reverse, using tax rates (and laws) that have been
enacted or substantively enacted at the reporting date and reflect uncertainty relating to
income taxes, if any. Deferred tax is expected to apply when the related deferred tax
asset is realised or the deferred tax liability is settled.
Deferred tax assets are recognised only to the extent that future taxable profit or taxable
capital gains will be available such that realisation of the related tax benefit is probable.
Deferred income tax is provided on temporary differences arising on investments in
subsidiaries and associates, except where the Group controls the timing of the reversal
of the temporary difference and it is probable that the temporary difference will not
reverse in the foreseeable future.
86
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.Accounting policies - continued
2.11Current and deferred income tax - continued
If the amount of taxable temporary differences is insufficient to recognise a deferred tax
asset in full, then future taxable profits, adjusted for reversals of existing temporary
differences are considered. Deferred tax assets are reviewed at each reporting date and
are reduced to the extent that it is no longer probable that the related tax benefit will be
realised; such reductions are reversed when the probability of future taxable profit
improves.
Deferred income tax assets and liabilities are offset when there is a legally enforceable
right to offset current tax assets against current tax liabilities and when the deferred
income tax assets and liabilities relate to income taxes levied by the same taxation
authority on either the same taxable entity or different taxable entities where there is an
intention to settle the balance on a net basis.
Deferred tax related to fair value re-measurements charged or credited directly in other
comprehensive income or to equity, is also credited or charged directly to equity and
subsequently recognised in the profit or loss account together with the deferred gain or
loss.
2.12Provisions for pension obligations
Provisions are recognised when the Group has a present legal or constructive obligation
as a result of past events, it is probable that an outflow of resources will be required to
settle the obligation, and a reliable estimate of the amount can be made.
A defined benefit plan defines an amount of pension that an employee will receive on
retirement.  In the Group’s case, this amount is dependent upon an employee’s final
compensation upon retirement.
The liability recognised in the statement of financial position is the present value of the
defined benefit obligation at the end of the reporting period.  The present value of a
defined benefit obligation is determined by discounting the estimated future cash
outflows using interest rate yields of government or high-quality corporate bonds that
are denominated in the currency in which the benefits will be paid, and that have terms
to maturity approximating to the terms of the related pension liability. Actuarial gains
and losses arising from experience adjustments and changes in assumptions are charged
or credited to other comprehensive income in the period in which they arise.
2.13  Revenue recognition
Revenue comprises the fair value of the consideration received or receivable for the
sale of services in the ordinary course of the Group’s activities. The Group recognises
revenue when the amount of revenue can be reliably measured, it is probable that future
economic benefits will flow to the entity and when specific criteria have been met as
described below.
87
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.Accounting policies - continued
2.13  Revenue recognition - continued
Rendering of services
Insurance revenue recognition is described in Note 2.10 dealing with insurance
contracts and investment contracts with DPF.
Revenue arising from the issue of investment contracts without DPF and other related
services offered by the Group, is recognised in the accounting period in which the
services are rendered.
Fees include investment management fees arising from services rendered in
conjunction with the issue and management of investment contracts where the Group
actively manages the consideration received from its customers to fund a return that is
based on the investment profile that the customer selected on origination of the
instrument.  The Group recognises these fees on a straight-line basis over the estimated
life of the contract.
The Group charges its customers for management and other related services using the
following different approaches:
– Front-end fees are charged to the client on inception.  The consideration received is
deferred as a liability and recognised over the life of the contract on a straight-line                     
basis.
– Regular fees are charged to the customer periodically (monthly, quarterly, half
yearly or annually) either directly or by making a deduction from invested funds. 
Regular charges billed in advance are recognised on a straight-line basis over the
billing period.
Other revenue receivable by the Group mainly comprises commission or trailer fees
receivable on account of investment or other services provided in an intermediary
capacity which is accounted for on an accruals basis.
2.14Investment return
Investment return includes dividend income, net gains or losses on financial assets at
fair value through profit or loss, interest income from financial assets not classified as
fair value through profit or loss, rental income receivable, share of associated
undertaking’s result, and other fair value movements of investment properties, and is
net of other investment expenses.
(a)  Dividend income
Dividend income from subsidiary and associated undertakings is recognised in the
profit or loss account as part of investment income when the right to receive payment is
established.
88
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.Accounting policies - continued
2.14Investment return - continued
(b)  Net fair value gains/(losses) from financial assets at fair value through profit or
loss
This category includes gains or losses arising from changes in the fair value of the
financial assets at fair value through profit or loss in the year in which they arise,
dividend income recognised when the right to receive payment is established and
interest income received on financial assets at fair value through profit or loss.
(c)  Interest income
Interest income from financial assets not classified as fair value through profit or loss is
recognised using the effective interest method.
(d)  Investment income from investment properties
Rental income from investment property is accounted for on an accruals basis in
accordance with the substance of the relevant lease agreements.
2.15Leases
At inception of a contract, the Group assesses whether a contract is, or contains, a lease.
A contract is or contains a lease if the contract conveys the right to control the use of an
identified asset for a period of time in exchange for consideration. To assess whether a
contract conveys the right to control the use of an identified asset, the Group uses the
definition of a lease in IFRS 16.
At commencement or on modification of a contract that contains a lease component, the
Group allocates the consideration in the contract to each lease component on the basis
of its relative stand-alone price.
(a) As a lessor
When the Group acts as a lessor, it determines at lease inception whether each lease is a
finance lease or an operating lease.
To classify each lease, the Group makes an overall assessment of whether the lease
transfers substantially all of the risks and rewards incidental to ownership of the
underlying asset. If this is the case, then the lease is a finance lease; if not, then it is an
operating lease. As part of this assessment, the Group considers certain indicators such
as whether the lease is for the major part of the economic life of the asset.
The Group recognises lease payments received under operating leases as income on a
straight-line basis over the lease term as part of ‘other income’ – Note 9.
89
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.Accounting policies - continued
2.15Leases - continued
(b) As a lessee
A lessee recognises a right-of-use asset representing its right to use the underlying asset
and a lease liability representing its obligation to make lease payments. As described
later in this note there are recognition exemptions for short-term leases and leases of
low-value items.
The Group recognises a right-of-use asset and a lease liability at the lease
commencement date. The right-of-use asset is initially measured at cost, which
comprises the initial amount of the lease liability adjusted for any lease payments made
at or before the commencement date, plus any initial direct costs incurred and an
estimate of costs to dismantle and remove the underlying asset or to restore the
underlying asset or the site on which it is located, less any lease incentives received.
The right-of-use asset is subsequently depreciated using the straight-line method from
the commencement date to the end of the lease term, unless the lease transfers
ownership of the underlying asset of the Group by the end of the lease term or the cost
of the right-of-use asset reflects that the Group will exercise a purchase option. In that
case the right-of-use asset will be depreciated over the useful life of the underlying
asset, which is determined on the same basis as those of property, plant and equipment.
In addition, the right-of-use asset is periodically reduced by impairment losses, if any,
and adjusted for certain remeasurements of the lease liability.
The lease liability is initially measured at the present value of the lease payments that
are not paid at the commencement date, discounted using the interest rate implicit in the
lease or, if that rate cannot be readily determined, the Group’s incremental borrowing
rate. Generally, the Group uses its incremental borrowing rate as the discount rate.
The Group determines its incremental borrowing rate by using interest rate curves by
country and termination dates, coordinated in a centralized manner, in which the
interest rate calculation is obtained by adding the differential related to the asset’s
nature. Interest rate curves are reviewed twice a year.
Lease payments included in the measurement of the lease liability comprise the
following:
– fixed payments (including payments which are essentially fixed), minus any
incentive to lease to be paid;
– the price for exercising a purchase option which the lessee is reasonably certain to
exercise; and
– payments for early cancellation.
90
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.Accounting policies - continued
2.15Leases - continued
(b) As a lessee
The lease liability is measured at amortised cost using the effective interest method. It is
remeasured when there is a change in future lease payments arising from a change in
rate, if there is a change in the Group’s estimate of the amount expected to be payable
under a residual value guarantee, if the Group changes its assessment of whether it will
exercise a purchase, extension or termination option or if there is a revised in-substance
fixed lease payment.
When the lease liability is remeasured in this way, a corresponding adjustment is made
to the carrying amount of the right-of-use asset or is recorded in profit or loss if the
carrying amount of the right-of-use asset has been reduced to zero.
The Group presents right-of-use asset that do not meet the definition of investment
property in ‘Right-of-use assets’.
The Group has elected not to recognise right-of-use assets and lease liabilities for leases
of low-value assets and short-term leases. The Group recognises the lease payments
associated with these leases as an expense on a straight-line basis over the lease term.
A lease modification is defined as a change in the scope of a lease, or the consideration
for a lease, that was not part of the original terms and conditions of the lease. A lease
modification includes adding or terminating the right to use one or more underlying
assets, or extending or shortening the contractual lease term.
A lease modification is accounted for in one of two ways;
• It is treated as a separate lease; or
• It is not treated as a separate lease.
A modification will only be treated as a separate lease if it involves the addition of one
or more underlying assets at a price that is commensurate with the standalone price of
the increase in scope. All other modifications are not treated as a separate lease.
91
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
2.Accounting policies - continued
2.16Impairment of non-financial assets
Assets that have an indefinite useful life and are not subject to amortisation, or assets
not yet available for use, are tested annually for impairment.  Assets that are subject to
amortisation or depreciation are reviewed for impairment whenever events or changes
in circumstances indicate that the carrying amount may not be recoverable.  An
impairment loss is recognised for the amount by which the asset’s carrying amount
exceeds its recoverable amount. The recoverable amount is the higher of an asset’s fair
value less costs to sell and value in use. For the purposes of assessing impairment,
assets are grouped at the lowest levels for which there are separately identifiable and
independent cash flows (cash-generating units).
2.17Offsetting
Financial assets and liabilities are offset and the net amount reported in the statement of
financial position when, and only when the Group currently has a legally enforceable
right to set-off the recognised amounts and it intends to settle them on a net basis, or to
realise the asset and settle the liability simultaneously. Income and expenses are
presented on a net basis only when it is required or permitted by a standard – e.g. gains
and losses arising from a group of similar transactions such as the gains and losses on
financial assets measured at FVTPL.
2.18Dividend distribution
Dividend distribution to the Company’s shareholders is recognised as a liability in the
period in which an obligation to pay a dividend is established.
2.19Share capital
Shares are classified as equity when there is no obligation to transfer cash or other
assets. Incremental costs directly attributable to the issue of new shares are shown in
equity as a deduction from the proceeds net of tax.
3.Use of accounting estimates and judgements in applying accounting policies
The Group makes estimates and assumptions concerning the future.  Estimates and
judgements are continually evaluated and are based on historical experience and other
factors, including expectations of future events that are believed to be reasonable under
the circumstances.
Information about judgements made in applying accounting policies that have the most
significant effects on the amounts recognised in the financial statements is included in
the following notes, which also include information about assumptions and
uncertainties at 31 December 2024 that have a significant risk of resulting in a material
adjustment in the carrying amounts of assets and liabilities in the next financial year.
92
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
3.Use of accounting estimates and judgements in applying accounting policies -
continued
(a) Long-term contracts - insurance contract assets, insurance contract liabilities and 
reinsurance contract liabilities
Insurance contract assets, insurance contract liabilities and reinsurance contract
liabilities are subject to an annual valuation using generally accepted accounting and
actuarial practice.
Different principles and valuation methodologies are adopted depending on the type
and generation of products.  The key assumptions used in determining the measurement 
of insurance contract assets, insurance contract liabilities and reinsurance contract
liabilities are described in Note 24.6 to the financial statements.
b)  Short-term insurance contracts under PAA - liability for incurred claims
Liability of incurred claims (LIC) of short-term business insurance contracts, measured
under the PAA, comprise of the estimates of future cash flows. The estimates of future
cash flows is derived using a standard actuarial claims projection technique, the Chain
Ladder method, other than for non-motor large losses. The key assumptions underlying
this technique is that past claims development experience can be used to project future
claims development.
Claims reserves which exceed a certain quantum (large losses), particularly those
involving fatalities and/or serious bodily injuries, are initially reserved at the case-by-
case reserve estimate. The measurement of claim payments due by the Group involves
the assessment of future settlements and is therefore dependent on assumptions around
determining such reserves based on, among others, legal precedent and current trends in
compensation awards. Specifically for Motor large losses, the Chain Ladder Method is
subsequently used to project the ultimate cost of these claims.
More detail on the key assumptions used in determining the LIC in respect of short-
term insurance contracts under PAA are described in Note 24.2 (a) to the financial
statements.
(c) Consolidation of entities in which the Group holds less than majority of voting
rights
The Group considers that it controls MAPFRE MSV Life p.l.c. (‘MMSV’) even though
it does not own more than 50% of the voting rights. This is because strategic, operating
and financing policies of MMSV are directed by means of shareholders’ agreement
which provides MAPFRE Middlesea p.l.c. with the right to select, appoint and remove
the key management personnel of MMSV and approve its business plan and capital
expenditure.
93
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
3.Use of accounting estimates and judgements in applying accounting policies -
continued
c) Consolidation of entities in which the Group holds less than majority of voting rights
- continued
For all the financial years up to 31 December 2010, MMSV was considered to be an
associate and was accounted for using the equity method.  Following the shareholders’
agreement, on 29 July 2011, MAPFRE Middlesea p.l.c. acquired control over MMSV
based on the factors explained in this note and started consolidating MMSV as from
that date.
4.      Management of risk
The Group is a party to contracts that transfer insurance risk and/or financial risk. This
section summarises these risks and the way that the Group manages them.
The following table describes the composition of the underlying items for long-term
contracts with direct participation features:
2024
2023
€'000
€'000
Cash at bank and in hand
21,490
8,910
Deposits with banks and credit institutions
9,108
—
Debt securities
955,212
844,145
Equity securities and units in unit trusts
823,008
926,282
Assets held to cover linked liabiliites - collective investment
  schemes
36,330
31,762
Investments in associated undertakings
5,793
24,508
Investment property
93,127
92,844
Forward foreign exchange contracts and swaps
—
1,970
1,944,068
1,930,421
Insurance contract liabilities
(1,948,078)
(1,984,889)
Foreign forward exchange contracts and swaps
(6,816)
—
4.1Insurance risk
The risk under any one insurance contract is the possibility that the insured event occurs
and the uncertainty of the amount of the resulting claim.  By the very nature of an
insurance contract, this risk is fortuitous, however, it can be predicted with a certain
disclosed level of reliability.
94
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
4.      Management of risk - continued
4.1Insurance risk - continued
For a portfolio of insurance contracts where the theory of probability is applied to
pricing and provisioning, the principal risk that the Group faces under its insurance
contracts is that the actual claims and benefit payments are significantly different to the
amounts included within insurance/reinsurance contract liabilities and assets.  This
could occur because the frequency or severity of claims and benefits are greater than
estimated.  Insurance events are fortuitous and the actual number and amount of claims
and benefits may vary from year to year from the estimate established using statistical
and actuarial techniques. 
Experience shows that the larger the portfolio of similar insurance contracts, the smaller
the relative variability of the expected outcome will be.  In addition, a more diversified
portfolio is less likely to be affected across the board by a change in any subset of the
portfolio.  The Group manages this risk through adequate reinsurance arrangements and
proactive claims handling.
The Group has developed its insurance underwriting strategy to diversify the type of
insurance risk accepted and within each of these categories to achieve a sufficiently
large population of risks to reduce the potential variability of the expected outcome.
The objective of the underwriting strategy is to ensure that the underwritten risks are
well diversified in terms of type and amount of risk. The variability of risks is improved
by the careful selection and implementation of underwriting strategies, which are
designed to ensure that risks are diversified in terms of type of risk and level of insured
benefits.
Key risks arising from insurance contracts issued:
Contract
Key risks
Risk mitigation
Short-term contracts
Insurance risk – frequency and
  severity of claims
Underwriting strategy, adequate
reinsurance arrangements and
proactive claim handling
Life risk - Term
Mortality risk: death of
  policyholder earlier than expected
Reinsurance with financially
strong reinsurer and adequate
underwriting
Investment contracts with DPF
Market risk: investment return on
  underlying items falling below
  guaranteed minimum rates
Management discretion to
determine amount and timing of
policyholder bonus rates
Interest rate risk: difference in
  duration and yield of assets and
  liabilities
Matching of asset and liability
cash flows
Unit-linked
Lapse risk: insufficient charges to
  cover acquisition expenses
Surrender penalties and review of
charges
95
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
4.Management of risk - continued
4.1Insurance risk - continued
Factors that aggravate insurance risk include lack of risk diversification in terms of type
and amount of risk and lack of geographical spread. The Group is largely exposed to
insurance risk in one geographical area, Malta and in one currency, the Euro.
(a) Short-term business insurance contracts
Frequency and severity of claims
The terms and conditions of the contracts set out the bases for the determination of the
Group’s liability should the insured event occur.  The risks underwritten include motor
(including third party liability), health, fire and other damage to property, other classes
and group life.  Details of insurance revenue as well as insurance service expenses
analysed by segment are provided in the “Segment information” (Note 7).
The frequency and severity of claims can be affected by several factors.  The following
are considered by the Group to be the most significant:
-The increasing levels of court awards in cases where damages are suffered as a
result of injuries, the divergence of awards that is dependent on the territory of the
claim and the jurisdiction of the court, the effect of inflation due to the prolonged
period typically required to settle such cases; and
- The risk of a single event that can extensively affect a multiple of individual risks
to which the Group is exposed.
The Group manages these risks through its underwriting strategy, adequate reinsurance
arrangements and proactive claims handling.
The underwriting strategy ensures that the risks underwritten are well diversified in
terms of type and amount of risk. The Group follows strict underwriting guidelines and
sets limits on the overall retention of risk that it carries. Any risk in excess of this limit
is either reinsured under a facultative cover note or is declined. Underwriting limits are
in place to enforce appropriate risk selection criteria. In certain circumstances, certain
exclusions to risks are included within these guidelines. For example, the Group does
not insure US risks unless they are incidental. The Group can impose deductibles to
help manage its costs.  It also uses its experience and expertise to mitigate the risk of
fraudulent claims.  Insurance contracts also entitle the Group to pursue third parties for
payment of some or all of the costs (i.e. subrogation). A significant portion of the
Group’s business is underwritten through an agency distribution network. 
Underwriting authority limits are set for individual agencies or branches, and any
contracts through which the Group is committed to cover risks in excess of these
authority limits require head office approval.
96
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
4.Management of risk - continued
4.1Insurance risk - continued
(a)  Short-term business insurance contracts - continued
Frequency and severity of claims - continued
The Group has reinsurance protection in place for all classes of business.  The type of
reinsurance cover, and the level of retention, is based on the Group’s internal risk
management assessment which takes into account the risk being covered, the sums
assured and the geographical location of the risk.  The Board approves each reinsurance
programme on an annual basis. The reinsurance arrangements include a mix of
proportional, facultative and non-proportional covers, which limit the liability of the
Group to any one individual claim or event. Generally, the Group’s policy is to place
reinsurance with listed multinational reinsurance companies whose credit rating is not
less than BBB. No rating limitation shall apply to treaty placements with MAPFRE Re
or any MAPFRE Group company designated to write any or all of the MAPFRE Group
Reinsurance treaties. At 31 December 2024, MAPFRE Re’s rating stood at A. The
Board monitors the security rating of MAPFRE on a periodic basis.
The Group has specialised claims units dealing with the mitigation of risks surrounding
known claims.  These units investigate and adjust claims as appropriate.  Claims are
individually reviewed regularly, and are adjusted to reflect the latest information on the
underlying facts, current law, jurisdiction, contractual terms and conditions and other
factors.  The Group actively manages and pursues early settlement of claims to reduce
its exposure to unpredictable developments.  Authority limits are set for the settlement
of claims through the individual agents. Any claims incurred above these limits are
referred to head office for handling. In addition, all claims involving bodily injury are
referred to head office irrespective of their amount.
Concentration of insurance risk
Up until 31 December 2024, 100% of the Group’s business was written in Malta (2023:
100%). The portfolio is diversified in terms of type of business written, with motor
business comprising 47% (2023: 46%) and health comprising 17% (2023: 17%) and fire
and other property damage 19% (2023: 18%) of the total portfolio (including short-term
Group Life business).  The remaining 17% (2023: 19%) of premium revenue is
generated across a spread of classes including marine, income protection, general
liability, travel and short-term group life.  Further information on insurance revenue,
and insurance service expenses by insurance business class is provided in Note 7 to
these financial statements. 
97
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
4.Management of risk - continued
4.1Insurance risk - continued
(a)  Short-term business insurance contracts - continued
Sources of uncertainty in the estimation of future claim developments and payments
Claims on contracts are accounted for on a claims-occurrence basis.  The Group is
liable for all insured events that occurred during the term of the contract, even if the
loss is discovered after the end of the contract term.  Certain classes of business, most
notably those exposed to liability, can take several years to develop and are therefore
subject to a greater degree of uncertainty than other classes of business which are
typically settled in a shorter period of time.
The estimated cost of claims includes direct expenses to be incurred in settling claims,
net of the expected subrogation value and recoveries.  The Group takes all reasonable
steps to ensure that it has appropriate information regarding its claims exposures. 
However, given the uncertainty in establishing the liability for incurred claims, it is
possible that the final outcome will prove to be different from the original liability
established.
In calculating the estimated cost of unpaid claims, the Group considers the results of
estimation techniques that are based partly on known information at year-end and partly
on statistical analysis of historical experience. 
Further details on the process of estimation is provided in Note 24.2 which also presents
the development of the estimate of future cash flows for claims incurred in a given year.
Sensitivity analysis to underwriting risk variables
The following tables present information on how reasonably possible changes in
assumptions made by the Company with regard to underwriting risk variables impact
product line insurance liabilities and profit or loss and equity before and after risk
mitigation by reinsurance contracts held. The analysis is based on a 5% upwards and
downwards change in the ultimate loss amount while holding all other assumptions
constant. In practice, this is unlikely to occur, and changes in some of the assumptions
might be correlated.
98
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
4.Management of risk - continued
4.1Insurance risk - continued
(a)  Short-term business insurance contracts - continued
Sensitivity analysis to underwriting risk variables - continued
31 December 2024
Impact on profit
before income tax
Impact on equity
Gross
Net
Gross
Net
€'000
€'000
€'000
€'000
Non-life
Ultimate loss – 5% increase
(385)
(334)
(250)
(217)
Ultimate loss – 5% decrease
385
334
250
217
31 December 2023
Impact on profit
before income tax
Impact on equity
Gross
Net
Gross
Net
€'000
€'000
€'000
€'000
Non-life
Ultimate loss – 5% increase
(427)
(379)
(278)
(246)
Ultimate loss – 5% decrease
427
379
278
246
(b) Long term business insurance contracts
Frequency and severity of claims (Mortality risk)
For contracts where death is the insured risk, the most significant factor that could
increase the overall frequency of claims are epidemics or wide spread changes in
lifestyle resulting in earlier or more claims than expected.
At present these risks do not vary significantly in relation to the location of the risk
insured by the Group. However, undue concentration by amounts could have an impact
on the severity of benefit payments on a portfolio basis.
For contracts with fixed and guaranteed benefits and fixed future premiums, there are
no mitigating terms and conditions that reduce the insurance risk accepted.  For
investment contracts with DPF, the participating nature of the contracts results in a
portion of the insurance risk being reduced over the term of policy.  Investment
contracts with DPF carry negligible mortality risk.
The Group manages these risks through its underwriting strategy and reinsurance
arrangements. The underwriting strategy is intended to ensure that the risks
underwritten are well diversified in terms of type of risk and level of insured benefits.
Medical selection is also included in the Group’s underwriting procedures with
premiums varied to reflect the health condition and life expectancy of the applicants.
99
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
4.Management of risk - continued
4.1Insurance risk - continued
(b) Long term business insurance contracts - continued
Frequency and severity of claims (Mortality risk) - continued
The Group has reinsurance protection in place to cover death claims.  The type of
reinsurance cover and the level of retention for each risk are based on the Group’s
internal risk management assessment, which takes account of the nature of the risk
covered and the sum assured. The reinsurance programme is approved by the Board of
Directors ("the Board") annually. The reinsurance arrangements in place include a mix
of quota share, facultative, excess of loss and catastrophe protection, which limits the
liability of the Group to any one individual life or event.  The Group’s reinsurance is
placed with listed multinational reinsurance companies whose rating is not less than A.
The mortality assumptions applied are disclosed in Note 24.
Policyholder lapse risk
Higher lapses than expected cause a loss of future profits and possibility of non-
recovery of sales expenses.
The amount of insurance risk is also subject to contract holder behaviour. On the
assumption that policyholders will make decisions rationally overall underwriting risk
can be assumed to be aggravated by such behaviour. For example, it is likely that
contract holders whose health has deteriorated significantly will be less inclined to
terminate contracts insuring death benefits than those contract holders remaining in
good health. This results in an increasing trend of expected mortality as the portfolio of
insurance contracts reduces due to voluntary terminations.
Unit-linked and with-profits policies, can be surrendered before maturity for a cash
surrender value specified in the contractual terms. Cash surrender value equals the
policyholder account/investment value at the time of termination, less any surrender
penalties. Through these penalties, policyholders are discouraged from surrendering
contracts earlier than policy maturity. As such, penalties mitigate the expense risk
arising from acquisition and other costs incurred when policies were issued, because
such costs were originally assumed to be spread over a longer period, since early
surrender was not expected.
The lapse assumptions applied are disclosed in Note 24.
100
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
4.Management of risk - continued
4.1Insurance risk - continued
(b) Long term business insurance contracts - continued
Expense Risk
Expense risk is the risk of unexpected increases in policy maintenance, claim handling
and other costs relating to fulfilment of insurance contracts. The risk is managed
through budgeting and periodic cost evaluations. Investment contracts with DPF carry
negligible expense risk.
The expense assumptions applied are disclosed in Note 24.
Market Risk
This risk is covered in Note 4.2 (a). The investment assets return and discount rate
assumptions are disclosed in Note 24.
Sensitivity analysis to underwriting risk variables
The following tables present information on how reasonably possible changes in
assumptions made by the Group with regard to underwriting risk variables impact
product line insurance liabilities and profit or loss and equity before and after risk
mitigation by reinsurance contracts held. The analysis is based on a change in an
assumption while holding all other assumptions constant. In practice, this is unlikely to
occur, and changes in some of the assumptions might be correlated.
101
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
4.Management of risk - continued
4.1Insurance risk - continued
(b) Long term business insurance contracts - continued
Sensitivity analysis to underwriting risk variables - continued
31 December 2024
Impact on CSM
Impact on profit
before income
tax
Impact on equity
Gross
Net
Gross
Net
Gross
Net
€'000
€'000
€'000
€'000
€'000
€'000
Life Risk (Net)
Mortality rate – 10% increase
(4,274)
(1,870)
(174)
(63)
(113)
(41)
Mortality rate – 10% decrease
4,269
1,872
172
63
112
41
Lapse rates – 10% increase
(1,652)
(171)
149
118
97
77
Lapse rates – 10% decrease
1,652
171
(149)
(118)
(97)
(77)
Expenses – 10% increase
(1,649)
(2,045)
(86)
(108)
(56)
(70)
Expenses – 10% decrease
1,649
2,045
86
108
56
70
Investment contracts with DPF
Mortality rate – 10% increase
(311)
(311)
—
—
—
—
Mortality rate – 10% decrease
311
311
—
—
—
—
Lapse rates – 10% increase
53
53
98
98
64
64
Lapse rates – 10% decrease
(53)
(53)
(98)
(98)
(64)
(64)
Expenses – 10% increase
(1,707)
(1,707)
(116)
(116)
(76)
(76)
Expenses – 10% decrease
1,707
1,707
116
116
76
76
31 December 2023
Impact on CSM
Impact on profit
before income
tax
Impact on equity
Gross
Net
Gross
Net
Gross
Net
€'000
€'000
€'000
€'000
€'000
€'000
Life Risk (Net)
Mortality rate – 10% increase
(4,155)
(1,852)
(59)
(15)
(39)
(10)
Mortality rate – 10% decrease
4,151
1,854
57
14
37
9
Lapse rates – 10% increase
(1,775)
(288)
192
124
125
80
Lapse rates – 10% decrease
1,775
288
(192)
(124)
(125)
(80)
Expenses – 10% increase
(1,566)
(1,812)
(48)
(57)
(31)
(37)
Expenses – 10% decrease
1,566
1,812
48
57
31
37
Investment contracts with DPF
Mortality rate – 10% increase
(391)
(391)
3
3
2
2
Mortality rate – 10% decrease
391
391
(3)
(3)
(2)
(2)
Lapse rates – 10% increase
123
123
93
93
60
60
Lapse rates – 10% decrease
(178)
(178)
(89)
(89)
(58)
(58)
Expenses – 10% increase
(1,179)
(1,179)
(71)
(71)
(46)
(46)
Expenses – 10% decrease
1179
1179
71
71
46
46
102
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
4.Management of risk - continued
4.1Insurance risk - continued
(b) Long term business insurance contracts - continued
Sensitivity analysis to underwriting risk variables - continued
Changes in underwriting risk variables mainly affect the CSM, profit or loss and equity
as follows.
GMM
VFA
a. CSM
Changes in fulfilment cash flows, other than those
  recognised as  insurance finance income or expenses
Changes in fulfilment
  cash flows
b. Profit or
      loss
Changes in fulfilment cash flows that are
  recognised as insurance finance income or expenses
  in profit or loss and change in CSM release and /or
  coverage units
Changes in CSM
  release and /or
  coverage units
c. Equity
The effect on profit or loss under b.
  after tax
The effect on profit or
  loss under b. after tax
4.2    Financial risk
The Group is exposed to financial risks through its financial assets, financial liabilities
and insurance contract assets and liabilities and reinsurance contracts assets and
liabilities.  In particular, the key risk is that in the long term, the proceeds from its
financial assets are not sufficient to fund the obligations arising from its insurance and
investment contracts.  The components of financial risks for the Group are market risk
(including cash flow and fair value interest rate risk, equity price risk and currency
risk), credit risk and liquidity risk. These risks arise from open positions in interest rate,
currency and equity products, all of which are exposed to general and specific market
movements.  The risks that the Group primarily faces due to the nature of its assets and
liabilities are interest rate risk and equity price risk.
The Group has developed its Asset/Liability management framework to further support
the manner in which these risk positions are managed.  It actively manages its assets to
achieve a competitive rate of return within risk objectives delineated by asset liquidity
measures, duration targets and credit quality parameters.  The respective Investment
Committees review and approve investment strategies on a periodic basis ensuring that
assets are managed efficiently and within approved risk mandates.
(a)  Market risk
Market risk comprises interest rate, equity price and foreign currency risks. These risks
arise from variability in fair values of financial instruments or related future cash flows,
as well as from variability of the FCF of insurance contracts due to variability in market
risk variables.
103
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
4.Management of risk - continued
4.2    Financial risk - continued
(a)  Market risk - continued
(i)  Cash flow and fair value interest rate risk
Insurance and investment contracts with DPF at Group level have benefit payments that
are fixed and guaranteed at the inception of the contract (for example, sum assured), or
as annual discretionary bonuses are declared. The Group’s primary financial risk on
these contracts is the risk that interest income and capital redemptions from the
financial assets backing the liabilities are insufficient to fund the guaranteed benefits
payable.
The Group does not guarantee a positive fixed rate of return to its long-term contract
policyholders at the inception of a contract. The declaration of discretionary bonuses is
guided by the bonus philosophy of the Board. Once a reversionary bonus is declared, it
is guaranteed to be paid in full at maturity or on the prior death of the life assured. Also
policyholders have the option to withdraw their current year’s bonus without any
charges following the date the bonus is declared.
The bonus philosophy considers historic and current rates of return generated by the
Group’s investment portfolio as well as the Group’s expectations for future investment
returns. The impact of interest rate risk is mitigated by the presence of the DPF. These
guaranteed benefits increase as discretionary benefits are declared and allocated to
contract holders. The current rates of regular and final bonuses are determined by the
Board in consultation with the Approved Actuary.  Different bonus rates are declared
on different generations of contracts depending on the type of product, cost structure,
past investment performance and premium rates.  Different bonuses are declared to
maintain equity between different generations of contract holders and products with
different characteristics. Future bonus rates are not guaranteed and the assumptions are
set to allow for a fair and orderly run-off of the fund.
All unit-linked and investment contracts with a DPF feature can be surrendered before
maturity for a cash surrender value that is always less than the actual contract liability.
Cash surrender values are determined at the discretion of the Group, and can be varied
from time to time.
The primary factor affecting the level of cash surrender value is the investment return
earned on the assets of the Group. In addition, the cash surrender value is affected by
the expenses, tax and the cost of risk benefits (such as life cover) borne by the Group,
deductions to provide a return to shareholders, as well as profits and losses arising on
other contracts. The expenses include payment of commission, medical report expenses,
office administration costs and other expenses incurred in the setting up and
maintenance of the contract. At most, the cash surrender value will be the amount of the
actual liability reduced by the surrender charge (where applicable).
104
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
4.      Management of risk - continued
4.2    Financial risk - continued
(a)  Market risk - continued
(i)    Cash flow and fair value interest rate risk - continued
Furthermore, in respect of all with-profits (with the exception of some contracts that
have been in force more than a certain number of years), the Group reserves the right to
increase the level of the surrender charge and, if necessary, to apply a Market Value
Reduction (‘MVR’). A MVR is a deduction which the Group may make on surrender of
a contract with DPF. For example, if the underlying investment return, after allowing
for expenses, tax, risk benefits, shareholder returns and adjustment for profits or losses
on other contracts is less than the return already provided for in the form of
reversionary bonuses, the Group may decide to apply a MVR.
The MVR serves to protect the interests of remaining investors and the Group, who
would otherwise have to subsidise the amount paid on surrendering contracts. The
Group does not apply a standard percentage deduction on all contracts but determines
the deduction to apply to each individual surrender at the time the surrender is made.
The amount depends on a number of factors including the length of time the contract
has been in force and the underlying investment return over the same time period. There
will be no MVR at maturity or on death. This means that at maturity or on death the
payment of the actual contract liability is guaranteed.
The cash surrender value may also be less than the total amount of premiums paid up to
the date of surrender.  The Group is not required to, and does not, measure the effect of
the above embedded derivative at fair value. 
The Group matches its insurance contract liabilities with a diversified portfolio of assets
which includes equity, debt securities and property.  The return from debt and cash-
based securities is subject to interest rate risk. 
In general, the Group is exposed to risk associated with the effects of fluctuations in the
prevailing levels of market interest rates. Assets/liabilities issued at variable rates
generally expose the Group to cash flow interest risk.  Assets/liabilities issued at fixed
rates generally expose the Group to fair value interest rate risk. Group investment
parameters exist to limit exposure to any one particular issuer and any one particular
security. Periodic reports are prepared at portfolio, legal entity and asset class level that
are circulated to the Group’s key management personnel. Note 22 incorporates maturity
information with respect to the Group's investments.
105
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
  4.      Management of risk - continued
4.2    Financial risk - continued
(a)  Market risk - continued
(i)  Cash flow and fair value interest rate risk - continued
The total assets and liabilities exposed to interest rate risk are the following:
Group
Company
2024
2023
2024
2023
€’000
€’000
€’000
€’000
Assets at floating interest rates
93,884
70,570
—
—
Assets at fixed interest rates
1,290,280
1,306,182
18,773
15,804
1,384,164
1,376,752
18,773
15,804
Reconciled to the notes to the financial statements as follows:
Group
Company
2024
2023
2024
2023
€’000
€’000
€'000
€'000
Debt securities (Note 22)
1,020,445
937,669
16,273
13,804
Deposits with banks and credit institutions
  (Note 22)
39,657
75,977
—
—
A component of equity securities and units
  in unit trusts
321,387
360,935
—
—
Interest bearing cash and cash equivalents
2,675
2,171
2,500
2,000
1,384,164
1,376,752
18,773
15,804
Group
Company
2024
2023
2024
2023
€’000
€’000
€'000
€'000
Insurance and reinsurance contracts
Liabilities
(1,920,554)
(1,969,216)
(37,710)
(40,446)
Assets
19,783
22,024
9,203
10,734
(1,900,771)
(1,947,192)
(28,507)
(29,712)
106
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
  4.      Management of risk - continued
4.2    Financial risk - continued
(a)  Market risk - continued
(i)  Cash flow and fair value interest rate risk - continued
Interest rate risk in relation to hybrid contracts, amounting to €35.2 million (2023:
€30.6 million) has been excluded as the directors consider the exposure to be
insignificant.
In managing its portfolio, the Group entered into fixed income security futures
contracts.  Accordingly, it is exposed to movements in interest rates in the respective
markets of the underlying, which comprise short, medium and long-term sovereign
debt.  The notional amount of futures contracts outstanding at 31 December is shown
below:
Group
2024
2023
€’000
€’000
Long positions
- Federal Republic of Germany
65,488
23,146
- United States Government
17,884
25,155
83,372
48,301
Short positions
- Federal Republic of Germany
78,096
90,016
- United States Government
18,601
18,352
96,697
108,368
Up to the reporting date, the Group did not have any hedging policy with respect to
interest rate risk other than as described in note 2.9.
107
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
  4.      Management of risk - continued
4.2    Financial risk - continued
(a)  Market risk - continued
(i)  Cash flow and fair value interest rate risk - continued
Sensitivity analysis – interest rate risk
An analysis of the Group’s sensitivity to a 1% increase or decrease in market interest rates
at the reporting date, assuming that all other variables remain constant, is presented below.
An explanation of the method used in preparing such sensitivity analysis and the main
parameters and assumptions underlying the information provided is found in Note 4.1.
Group
CSM
Profit or loss before
tax
Equity
Increase
Decrease
Increase
Decrease
Increase
Decrease
€’000
€’000
€’000
€’000
€’000
€’000
31 December 2024
Insurance and reinsurance
  contracts (net)
406
(449)
183
(284)
119
(185)
Investment contracts with
  DPF
6,483
(19,019)
552
(1,714)
359
(1,114)
Other investments
—
—
—
—
(301)
281
6,889
(19,468)
735
(1,998)
177
(1,018)
31 December 2023
Insurance and  reinsurance
  contracts (net)
370
(408)
(40)
(104)
(26)
(68)
Investment contracts  with
  DPF
11,131
(27,317)
952
(2,363)
618
(1,536)
Other investments
—
—
—
—
(289)
268
11,501
(27,725)
912
(2,467)
303
(1,336)
Company
Profit or loss before tax
Equity
Increase
Decrease
Increase
Decrease
€’000
€’000
€’000
€’000
31 December 2024
Insurance  and reinsurance contracts (net)
554
(517)
360
(336)
Other investments
—
—
(301)
281
554
(517)
59
(55)
31 December 2023
Insurance  and reinsurance contracts (net)
362
(372)
235
(242)
Other investments
—
—
(289)
268
362
(372)
(54)
26
108
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
  4.      Management of risk - continued
4.2    Financial risk - continued
(a)  Market risk - continued
(ii)    Equity price risk
The Group’s financial assets are susceptible to the risk of decreases in value due to
changes in the prices of equities. The directors manage the risk of price volatility by
entering into a diverse range of investments including equities and collective
investment schemes.  In addition, the Group’s investments are spread geographically in
a diverse number of different countries.  The Group has active Investment Committees
that have established a set of investment guidelines that are also approved by the Board
of Directors.  Investments over prescribed limits are directly approved by the respective
Boards.  These guidelines provide parameters for investment management, including
contracts with external portfolio managers.  They include, inter alia, reference to an
optimal spread of the investment portfolio, assessment of equity issuers and maximum
exposures by the Group to any one issuer and its connected parties (with the exception
of investments in Government paper). These parameters also consider solvency
restrictions imposed by the Regulator.
Management structures are in place to monitor all the Group’s overall market positions
on a regular basis.  Reports are prepared at portfolio, legal entity and asset and liability
class level that are circulated to the Group’s relevant key management personnel. These
are also reviewed by the respective Investment Committees and Boards.
109
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
4.      Management of risk - continued
4.2    Financial risk - continued
(a)  Market risk - continued
(ii)  Equity price risks - continued
The total assets subject to equity price risk are the following:
                  Group
              Company
2024
2023
2024
2023
€’000
€’000
€’000
€’000
Assets subject to equity price risk
561,742
622,434
2,813
2,486
The above includes:
Component of  investments in associated 
  undertakings (Note 21)*
4,805
23,212
—
—
A component of equity securities and units
  in unit trusts
556,937
599,222
2,813
2,486
561,742
622,434
2,813
2,486
*Investments in associates (Note 21) amounting to €0.4 million (2023:€0.4 million) for
the Group and €0.4 million (2023 : €0.4 million) for the Company have been excluded
from equity price risk since they are accounted for under the equity method.
In the case of assets held to cover unit-linked liabilities the exposure is carried by the
contract holder.  In the case of capital guaranteed products any shortfalls guaranteed
upon maturity are mitigated by a back-to-back guarantee with international financial
service providers as further referred in 4.2 (a) (i). 
The sensitivity for equity price risk illustrates how changes in the fair value of equity
securities (excluding investments in associated undertakings) will fluctuate because of
changes in market prices, whether those changes are caused by factors specific to the
individual equity issuer, or factors affecting all similar equity traded in the market.
110
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
      4.      Management of risk - continued
4.2    Financial risk - continued
(a)  Market risk - continued
(ii)  Equity price risks - continued
An analysis of the Group’s sensitivity to a 10% decrease in equity prices at the
reporting date, assuming that all other variables remain constant, is presented below. An
explanation of the method used in preparing such a sensitivity analysis and the main
parameters and assumptions underlying the information provided is found in Note 4.1.
Group
CSM
Profit or loss
before tax
Equity
€’000
€’000
€’000
31 December 2024
Investment contracts with DPF
(3,580)
(381)
(248)
Other investments
—
(281)
(241)
(3,580)
(662)
(489)
31 December 2023
Investment contracts with DPF
(3,869)
(353)
(229)
Other investments
—
(249)
(211)
(3,869)
(602)
(440)
Company
Profit or loss
before tax
Equity
€’000
€’000
31  December 2024
Other investments
(281)
(241)
31  December 2023
Other investments
(249)
(211)
111
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
    4.      Management of risk - continued
4.2    Financial risk - continued
(a)  Market risk - continued
(iii) Currency risk
The Group’s and Company’s liabilities are substantially denominated in euro.  The
Group’s exposure to foreign currency risk arises primarily from both equity and debt
securities denominated in major foreign currencies. The Group hedges its foreign
currency denominated debt securities using foreign exchange forward contracts in order
to mitigate the risk that principal cash flows for these investments fluctuate as a result
of changes in foreign exchange rates.
The table below summarises the Group’s exposure to foreign currencies other than
euro.
Group
31  December 2024
Net exposure
before
hedging
Notional
amount of
currency
derivatives
Net exposure
after hedging
€’000
€’000
€’000
Currency of exposure:
USD
307,311
178,616
128,695
CHF
15,318
—
15,318
GBP
12,142
6,121
6,021
SEK
7,337
—
7,337
DKK
8,318
951
7,367
HKD
1,987
—
1,987
Others
20,521
(239)
20,760
372,934
185,449
187,485
112
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
4.      Management of risk - continued
4.2    Financial risk - continued
(a)  Market risk - continued
(iii)  Currency risk - continued
Group
31  December 2023
Net exposure
before
hedging
Notional
amount of
currency
derivatives
Net exposure
after hedging
€’000
€’000
€’000
Currency of exposure:
USD
255,326
101,730
153,596
CHF
18,203
—
18,203
GBP
10,236
805
9,431
SEK
37,777
24,421
13,356
DKK
13,166
30
13,136
HKD
3,456
—
3,456
Others
12,786
(15)
12,801
350,950
126,971
223,979
 
Within the table above, €185.8 million of the unhedged exposure relates to equity
investments (2023: €190.9 million).  Due to an increasingly globalised economy, the
Group’s equity investments are diversified across various currencies. The directors
consider that the exposure to currency risk is appropriately captured in the equity price
risk sensitivity (Note 4.2(a)(ii)). Any residual currency exposure relating to non-equity
investments is not considered to be significant.
The table below summarises the Company’s exposure to foreign currencies other than
euro. 
Company     
31  December 2024
Net exposure
before
hedging
Notional
amount of
currency
derivates
Net exposure
after hedging
€’000
€’000
€’000
Currency of exposure:
USD
34
—
34
GBP
29
—
29
Other
16
—
16
79
—
79
113
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
      4.      Management of risk - continued
4.2    Financial risk - continued
(a)  Market risk - continued
(iii) Currency risk - continued
          Company
31  December 2023
Net
exposure
before
hedging
Notional
amount of
currency
derivates
Net exposure
after hedging
€’000
€’000
€’000
Currency of exposure:
USD
(155)
—
(155)
GBP
(33)
—
(33)
Others
2
—
2
(186)
—
(186)
The Company’s foreign exposure relates to foreign operations now in run-off.
(b)    Credit risk
Credit risk is the risk of decreases in value when counterparties are not capable of
fulfilling their obligations or when a change in their credit status takes place. The Group
has exposure to credit risk, which is the risk that a counterparty will be unable to pay
amounts in full when due. Key areas where the Group is exposed to credit risk are:
• Investments and cash and cash equivalents
• Reinsurance contract assets
• Amounts due from insurance intermediaries
• Counterparty risk with respect to forward foreign exchange contracts
The Group places limits on the level of credit risk undertaken from the main categories
of financial instruments. These limits also take due consideration of the solvency
restrictions imposed by the relevant regulations. The investment strategy of the Group
considers the credit standing of the counterparty and control structures are in place to
assess and monitor these risk thresholds.
114
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
    4.      Management of risk - continued
4.2    Financial risk - continued
(b) Credit risk - continued
The Group structures the levels of credit risk it accepts by limiting as far as possible its
exposure to a single counterparty or groups of counterparties. The Group has in place
internal control structures to assess and monitor credit exposures and risk thresholds.
The Group’s cash is placed with a number of core domestic credit institutions and
investment grade international banks, thereby reducing the concentration of
counterparty credit risk to an acceptable level.
Reinsurance is used to manage insurance risk. This does not, however, discharge the
Group’s liability as primary insurer. If a reinsurer fails to pay a claim for any reason,
the Group remains liable for the payment to the policyholder.  The creditworthiness of
reinsurers is monitored on a quarterly basis by reviewing credit grades provided by
rating agencies and other publicly available financial information, thereby ensuring the
continuous financial strength of the reinsurer. At the same time that the Board approves
the overall reinsurance protection of the Group, it ensures that the reinsurers’ credit
rating (either Standard & Poor’s or equivalent) is within the parameters set by it.
The Group is exposed to contract holders and intermediaries for insurance revenue. 
Credit agreements are in place in all cases where credit is granted, and in the case of
certain larger risks, premium payment warranties are in place.  This limits the liability
of the Group towards the insured or any third party if the premium remains unsettled
after the credit period granted and allows the Group to cancel the policy ab initio, if
considered necessary. Records are kept of the payment history for significant contract
holders and intermediaries with whom regular business is conducted.  Credit is not
granted to contract holders whose payment history is not satisfactory.  Credit risk with
respect to debtors is further limited due to the large number of customers comprising
the Group’s debtor base.
The exposure to individual counterparties is also managed by other mechanisms, such
as the right to offset where counterparties are both debtors and creditors of the Group.
Management information reported to the Group includes details of provisions for
impairment on receivables and subsequent write-offs.  The Company performs risk-
based reviews to assess the degree of compliance with the Group’s procedures on credit
and take action accordingly.  In the case of MMSV, it is not normal for credit to be
extended to insurance policyholders due to the nature of their business, unless
automatic policy loans are advanced up to the surrender value of the contract.
The Group does not trade in derivative contracts, with the exception of forward
contracts and exchange traded futures. All derivative contracts are placed with quality
financial institutions within the parameters of a hedging policy approved by the Board.
 
115
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
     
      4.      Management of risk - continued
4.2    Financial risk - continued
(b)  Credit risk - continued
The total assets bearing credit risk are the following:
Group
Company
2024
2023
2024
2023
€’000
€’000
€’000
€’000
Debt securities
1,020,445
937,669
16,273
13,804
Deposits with banks and credit institutions
39,657
75,977
—
—
Forward foreign exchange contracts and
swaps
—
1,970
—
—
A component of reinsurance contract assets
8,084
9,701
8,084
9,701
Trade and other receivables
  (excluding prepayments)
22,039
22,362
18,788
19,645
Cash and cash equivalents
81,899
47,975
13,908
10,780
Total
1,172,124
1,095,654
57,053
53,930
The carrying amounts disclosed above represent the maximum exposure to credit risk.
The component of reinsurance contract assets exposed to credit risk is analysed in the
table below using Standard & Poor’s rating (or equivalent).
Group and Company
2024
2023
€’000
€’000
AA
122
385
A
7,446
9,293
Below BBB or not rated
516
23
8,084
9,701
116
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
4.      Management of risk - continued
4.2    Financial risk - continued
(b)  Credit risk - continued
These assets other than the reinsurance contract assets are analysed in the table below
using Standard & Poor’s rating (or equivalent).
Group
Company
2024
2023
2024
2023
€’000
€’000
€’000
€’000
AAA
84,353
109,154
4,085
1,383
AA
232,871
188,328
2,522
2,824
A
440,982
412,833
7,690
7,764
BBB
317,688
248,171
13,013
8,790
Below BBB or not rated
88,146
127,467
21,659
23,467
1,164,040
1,085,953
48,969
44,228
Debt securities, receivables and cash and cash equivalents that are not rated are
primarily held with highly reputable financial institutions.
The Group does not hold any collateral as security to its credit risk.
117
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
4.      Management of risk - continued
4.2    Financial risk - continued
(b)  Credit risk - continued
Financial assets that are past due but not impaired
The following other assets are classified as past due but not impaired:
Group and Company
2024
2023
€’000
€’000
Within credit terms
10,737
10,501
Not more than three months
3,821
4,100
Within three to twelve months
1,875
2,442
Over twelve months
1,063
762
17,496
17,805
IFRS 7 defines a financial asset as being past due when the counterparty has failed to
make a payment when contractually due. It goes further to stipulate that full disclosure
must be made of all balances due from this particular counterparty, including those,
which are still within credit terms and therefore not contractually due.
The overall exposure of the Group and Company in terms of IFRS 7 is €17.5 million
(2023: €17.8 million), of which €10.7 million (2023: €10.5 million) is not contractually
due. It is the view of the directors that no impairment charge is necessary, due to the
following reasons:
1. Settlements after year-end.
2. In cases where the amount has not been settled, agreement for settlement has been
reached or is being negotiated.
Trade receivables at 31 December 2024 did not comprise any amounts (2023: nil)
whose terms had been renegotiated from the original terms and which were classified as
fully performing.
Financial assets that are impaired
Within trade receivables are the following receivables that are classified as impaired
against which a provision for impairment has been provided as per Note 26:
Group and Company
2024
2023
€’000
€’000
Over twelve months (Note 26)
717
535
118
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
      4.      Management of risk - continued
4.2    Financial risk - continued
(b)  Credit risk - continued
A decision to impair an asset is based on the following information that comes to the
attention of the Group:
• Significant financial difficulty of the debtor.
• It becoming probable that the debtor will enter bankruptcy or other financial
reorganisation.
• A breach of contract, such as protracted default in payments
• The debtor has been referred to the in-house legal office.
(c)  Liquidity risk
The Group is exposed to daily calls on its available cash resources mainly from claims
and benefits arising from insurance contracts.  Liquidity risk is the risk that cash may
not be available to pay obligations when due at a reasonable cost. The Group manages
its funds in such a manner as to ensure an adequate portion of available funds to meet
such calls. With respect to life insurance contracts this is principally managed through
limits set by the Board of MMSV on the minimum proportion of maturity funds
available to meet such calls. Furthermore, the Group invests a majority of its assets in
listed investments that can be readily disposed of.
The following table indicates the expected timing of cash flows arising from the
maturity or settlement of Group’s liabilities. The expected cash flows do not consider
the impact of early surrenders on life insurance contracts.
119
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
  4.      Management of risk - continued
4.2    Financial risk - continued
(c)  Liquidity risk - continued
Group expected cash flows (€ millions) 2024
Payable on
demand
0-1 yr
1-2
yrs
2-3
yrs
3-4
yrs
4-5
yrs
>5 yrs
Total
Undiscounted
Discounted
Discounted
Discounted
Discounted
Discounted
Discounted
Discounted
Insurance contract assets -
  Life insurance contracts
4.0
(9.0)
(8.0)
(7.0)
(6.0)
(5.0)
(25.0)
(56.0)
Insurance contract liabilities
  - Life insurance contracts
56.0
175.0
163.0
133.0
152.0
171.0
984.0
1,834.0
Reinsurance contract
  liabilities
6.0
3.0
2.0
2.0
2.0
2.0
20.0
37.0
Insurance contract liabilities
  – liabilities for incurred
  claims short- term
  contracts under PAA
—
18.2
6.3
3.4
2.9
2.2
3.8
36.8
Lease liabilities
—
0.4
0.3
0.3
0.2
0.2
0.4
1.8
Other payables
18.2
—
—
—
—
—
—
18.2
   
Group expected cash flows (€ millions) 2023
Payable on
demand
0-1 yr
1-2
yrs
2-3
yrs
3-4
yrs
4-5
yrs
>5 yrs
Total
Undiscounted
Discounted
Discounted
Discounted
Discounted
Discounted
Discounted
Discounted
Insurance contract assets -
  Life insurance contracts
2.0
(8.0)
(7.0)
(6.0)
(6.0)
(5.0)
(26.0)
(56.0)
Insurance contract liabilities
  - Life insurance contracts
50.0
199.0
169.0
156.0
124.0
145.0
1,039.0
1,882.0
Reinsurance contract
  liabilities
5.0
2.0
2.0
2.0
2.0
2.0
19.0
34.0
Insurance contract liabilities
  – liabilities for incurred
  claims short-term  contracts
  under PAA
—
27.8
5.3
1.2
3.1
0.6
1.4
39.4
Lease liabilities
—
0.4
0.4
0.3
0.3
0.2
0.4
2.0
Other payables
18.0
—
—
—
—
—
—
18.0
Expected cash flows on unit linked liabilities, presented under investment contract
liabilities amounting to €179.7 million (2023: €123.3 million) and as part of insurance
contract liabilities €39.2 million (2023: €34.8 million), have not been included as the
directors consider that there is limited exposure to liquidity risk given that these are
principally backed by unit linked assets.
The amounts which are undiscounted and payable on demand mainly consist of long-
term contracts claims outstanding.
120
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
4.      Management of risk - continued
4.2    Financial risk - continued
(c)  Liquidity risk - continued
Company expected cash flows (€ millions) 2024
Payable on
demand
0-1 yr
1-2
yrs
2-3
yrs
3-4
yrs
4-5
yrs
>5 yrs
Total
Undiscounted
Discounted
Discounted
Discounted
Discounted
Discounted
Discounted
Discounted
Insurance contract liabilities
  – liabilities for incurred
  claims short-term contracts
  under PAA
—
18.2
6.3
3.4
2.9
2.2
3.8
36.8
Lease liabilities
—
0.3
0.3
0.3
0.2
0.2
0.4
1.7
Other payables
9.1
—
—
—
—
—
—
9.1
Company expected cash flows (€ millions) 2023
Payable on
demand
0-1 yr
1-2
yrs
2-3
yrs
3-4
yrs
4-5
yrs
>5 yrs
Total
Undiscounted
Discounted
Discounted
Discounted
Discounted
Discounted
Discounted
Discounted
Insurance contract liabilities
  – liabilities for incurred
  claims short-term contracts
  under PAA
—
27.8
5.3
1.2
3.1
0.6
1.4
39.4
Lease liabilities
—
0.4
0.4
0.3
0.3
0.2
0.4
2.0
Other payables
9.3
—
—
—
—
—
—
9.3
121
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
4.      Management of risk - continued
4.2    Financial risk - continued
(c)  Liquidity risk - continued
The table below analyses the Group’s derivative financial instruments that will be
settled on a gross basis. The amounts disclosed in the table are the contractual
undiscounted cash flows. Balances due within 12 months equal their carrying balances,
as the impact of discounting is not significant.
Group
2024
2023
€’000
€’000
At 31 December
Foreign exchange contracts
- outflow
(211,300)
(140,177)
- inflow
204,484
142,147
At 31 December 2024 and 2023, the above derivatives were due to be settled within
three months after year end.
122
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
4.Management of risk - continued
4.3Fair values
The following table presents the assets measured in the statement of financial position
at fair value by level of the following fair value measurement hierarchy at 31 December
2024:
• Quoted prices (unadjusted) in active markets for identical assets or liabilities
(Level 1);
• Inputs other than quoted prices included within Level 1 that are observable for
the asset or liability, either directly (that is, as prices) or indirectly (that is,
derived from prices) (Level 2); and
• Inputs for the asset or liability that are not based on observable market data
(that is, unobservable inputs) (Level 3).
The Group recognises transfers between levels of the fair value hierarchy at the end of
the reporting period during which the change has occurred.
The following tables present the assets and liabilities measured at fair value at 31
December 2024.
Group
Level 1
Level 2
Level 3
Total
€'000
€'000
€'000
€'000
Assets
Financial assets at fair value through profit or
  loss
- Equity securities, units in unit trusts and
  collective investment schemes
874,858
123,120
101,480
1,099,458
- Debt securities
567,135
388,077
—
955,212
Debt securities at FVOCI
8,946
7,327
—
16,273
Investment in associated undertakings
—
4,805
—
4,805
Total assets
1,450,939
523,329
101,480
2,075,748
Liabilities
Investment contract liabilities
—
179,685
—
179,685
Forward foreign exchange contracts and
  swaps
—
6,816
—
6,816
Total liabilities
—
186,501
—
186,501
123
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
4.Management of risk - continued
4.3Fair values - continued
Company
Level 1
Level 2
Total
€'000
€'000
€'000
Assets
Financial assets at fair value through profit or loss
- Equity securities, units in unit trusts and collective
  investment schemes
762
2,051
2,813
Debt securities at FVOCI
8,946
7,327
16,273
Total assets
9,708
9,378
19,086
The following tables present the assets measured at fair value at 31 December 2023.
Group
Level 1
Level 2
Level 3
Total
€'000
€'000
€'000
€'000
Assets
Financial assets at fair value through
  profit or loss
- Equity Securities, units in unit trusts and
    collective investment schemes
934,308
91,550
94,839
1,120,697
- Debt Securities
532,525
316,536
—
849,061
Debt securities at FVOCI
7,204
6,600
—
13,804
Forward foreign exchange contracts and 
  swaps
—
1,970
—
1,970
Investment in associated undertakings
—
23,346
—
23,346
Total assets
1,474,037
440,002
94,839
2,008,878
Liabilities
Investment contract liabilities
—
123,253
—
123,253
Total liabilities
—
123,253
—
123,253
124
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
4.Management of risk - continued
4.3Fair values - continued
Company
Level 1
Level 2
Total
€'000
€'000
€'000
Assets
Financial assets at fair value through profit or loss
-Equity securities, units in unit trusts and
  collective investment schemes
667
1,819
2,486
Debt securities at FVOCI
7,204
6,600
13,804
Total assets
7,871
8,419
16,290
Fair value measurements classified as Level 1 include government debt securities, units
in unit trusts and collective investments schemes and foreign listed equities.
Corporate debt securities are classified as Level 2 in view of their trading
characteristics. The financial liabilities for unit-linked contracts were also classified as
Level 2. The fair value of these contracts is determined using the current unit values
that reflect the fair values of the financial assets (classified as Level 1) linked to the
financial liability.  Derivative foreign exchange forward contracts have been classified
as Level 2.  The fair value of these instruments is determined by reference to market
observable forward currency rates and interest rates. Domestic equities are classified as
Level 2 in view of their trading characteristics.
At 31 December 2024, 4.9% (2023:4.7%) of the financial assets measured at fair value
on a recurring basis were classified as Level 3.  They constitute investment in unlisted
equities. The Group has €101.5 million (2023:€94.8 million) assets classified as Level
3, the valuation of which has been determined by reference to the latest available net
asset values of the underlying investment or the latest transaction price.
The analysis of freehold land and buildings and investment property are included
within Note 18 and  Note 19 respectively.
125
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
4.Management of risk - continued
4.3Fair values - continued
The following table presents the changes in Level 3 instruments for the year ended 31
December:
Group
2023
Equity securities
€'000
Opening balance
61,609
Additions
30,252
Total gains recognised in profit or loss
2,978
Closing balance
94,839
2024
Equity securities
€'000
Opening balance
94,839
Additions
5,300
Disposals
(1,749)
Total gains recognised in profit or loss
3,090
Closing balance
101,480
At 31 December 2024 and 2023, the carrying amount of the Group’s and Company’s
other financial assets and liabilities approximated their fair values.
126
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
5.Capital management
The Group’s policy is to maintain a strong capital base to support its business growth
plans and comply with all regulatory requirements on an ongoing basis whilst assessing
the impact of shareholder returns on its capital employed and safeguarding the Group's
and individual companies ability to continue as a going concern.  The Group defines
capital as shareholders’ equity.
The Group’s objectives when managing capital are to:
• comply with the obligations to hold Eligible Own Funds to cover the Solvency
Capital Requirement and Minimum Capital Requirement in terms of the Insurance
Business Act, 1998, (Chapter 403, Laws of Malta) and the applicable Insurance
Rules issued under the Insurance Business Act (‘Insurance Rules’) by the Malta
Financial Services Authority (‘MFSA’);
• provide for the capital requirements of the companies within the Group;
• safeguard the Group’s and individual component companies’ ability to continue as a
going concern and provide returns for shareholders and benefits for other
stakeholders; and
• to provide an adequate return to shareholders by pricing insurance contracts
commensurate with the level of risk.
The individual insurance Group companies are required to hold regulatory capital for
their non-life and life assurance business in compliance with the Insurance Rules issued
by the MFSA. The minimum capital requirements must be maintained at all times
throughout the period. The individual Group companies monitor the level of their own
funds on a regular basis.  Any transactions that may potentially affect the individual
company’s own funds and solvency position are immediately reported to their
respective directors and shareholders for resolution.
The Company’s Minimum Capital Requirement Absolute Floor stands at €8,000,000 as
per paragraph 5.6.4 of Chapter 5 (‘Valuation of assets and liabilities, technical
provisions, own funds, Solvency Capital Requirement, Minimum Capital Requirement
and investment rules’) of Part B of the Insurance Rules.
Based on management calculations to date, the Company is sufficiently capitalised and
was compliant at all times with the regulatory capital requirements as stipulated by the
MFSA which are in line with the Solvency II requirements. All other companies within
the Group were also compliant with the respective minimum regulatory requirements
throughout the financial period as per management calculations to date.
127
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
6.      Amounts determined on transition to IFRS 17
Transition approach
At 1 January 2022, the Group applied the following approaches to identify and measure
certain groups of contracts on transition to IFRS 17.
Year of issue of contracts
Transition approach
After 2016 – term business including
  reinsurance
Full retrospective approach
Before 2016 – term business including
  reinsurance
Fair value approach
All with-profits and unit-linked business
Fair value approach
The transition approach was determined at the level of a group of insurance contracts
and affected the approach to calculating the CSM on initial adoption of IFRS 17.
The Group applied judgement in determining the transition amounts and the pre-
transition FCF and experience were not considered under this approach.
Applying the fair value approach, the Group determined the CSM to be the difference
between the fair value of a group of insurance contracts, measured in accordance with
IFRS 13 ‘Fair Value Measurement’ and its FCF at the transition date.
The fair value of an insurance liability is the price that a market participant would be
willing to pay to assume the obligation and the remaining risks of the in-force contracts
as at the transition date. A present value technique was used to value groups of
contracts.
In estimating the fair value of groups of insurance contracts, the following
considerations were applied:
– only future cash flows within the boundaries of the insurance contracts were
included in the fair value estimation, excluding future renewals and new business
that would be outside the contract boundary of the contracts under IFRS 17;
– assumptions about expected future cash flows and risk allowances, including
operational risk were adjusted for the market participant’s view, as required by
IFRS 13;
– profit margins were included to reflect what a market participant would require
for accepting obligations under insurance contracts, beyond the risk adjustment
for non-financial risk; and
– diversification between market risk and life risk. Although market risk is
considered as a hedgeable risk, it was assumed that a buyer will be able to capture
this diversification from its other own modules.
128
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
6.      Amounts determined on transition to IFRS 17 - continued
Analysis by transition approach - insurance revenue and contractual service margin
For insurance contracts issued by the Group and reinsurance contracts held, an analysis
of insurance revenue for insurance contracts issued and the CSM by transition method
is included in the following tables.
31  December 2024
Life Risk
Investment
contracts
with  DPF
Total
€'000
€'000
€'000
Insurance contracts issued
Insurance revenue
New contracts and contracts measured
  under the full retrospective approach at
  transition
(13,182)
(4,116)
(17,298)
Contracts measured under the fair value
  approach at transition
(128)
(29,344)
(29,472)
(13,310)
(33,460)
(46,770)
CSM
New contracts and contracts measured
  under the full retrospective approach at
  transition
27,337
12,012
39,349
Contracts measured under the fair value
  approach at transition
6,214
65,596
71,810
33,551
77,608
111,159
31  December 2024
Life Risk
€’000
Reinsurance contracts held
CSM
New contracts and contracts measured
  under the full retrospective approach at
  transition
(9,957)
Contracts measured under the fair value
  approach at transition
(4,067)
(14,024)
129
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
6.      Amounts determined on transition to IFRS 17 - continued
Analysis by transition approach - insurance revenue and contractual service margin -
continued
31  December 2023
Life Risk
Investment
contracts
with  DPF
Total
€'000
€'000
€’000
Insurance contracts issued
Insurance revenue
New contracts and contracts measured
  under the full retrospective approach at
  transition
(12,905)
(3,241)
(16,146)
Contracts measured under the fair value
  approach at transition
(138)
(31,427)
(31,565)
(13,043)
(34,668)
(47,711)
CSM
New contracts and contracts measured
  under the full retrospective approach at
  transition
24,909
8,770
33,679
Contracts measured under the fair value
  approach at transition
7,285
62,957
70,242
32,194
71,727
103,921
31  December 2023
Life Risk
€’000
Reinsurance contracts held
CSM
New contracts and contracts measured
  under the full retrospective approach at
  transition
(8,806)
Contracts measured under the fair value
  approach at transition
(4,157)
(12,963)
130
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
6.      Amounts determined on transition to IFRS 17 - continued
Expected recognition of the contractual service margin
An analysis of the expected recognition of the CSM remaining at the end of the
reporting period in profit or loss is provided in the following table:
As at 31
December 2024
Insurance contracts issued
Reinsurance contracts held
Life Risk
Investment
contracts with
DPF
Total CSM for
insurance
contracts
issued
Life Risk
Total CSM for
reinsurance
contracts held
€’000
€’000
€’000
€’000
€’000
1
(3,576)
(7,025)
(10,601)
1,555
1,555
2
(3,313)
(6,454)
(9,767)
1,433
1,433
3
(3,054)
(5,904)
(8,958)
1,313
1,313
4
(2,811)
(5,466)
(8,277)
1,202
1,202
5
(2,586)
(4,943)
(7,529)
1,100
1,100
6 – 10
(10,071)
(16,401)
(26,472)
4,226
4,226
> 10
(14,637)
(31,415)
(46,052)
5,753
5,753
Total
(40,048)
(77,608)
(117,656)
16,582
16,582
As at 31
December 2023
Insurance contracts issued
Reinsurance contracts held
Life Risk
Investment
contracts with
DPF
Total CSM for
insurance
contracts
issued
Life Risk
Total CSM for
reinsurance
contracts held
€’000
€’000
€’000
€’000
€’000
1
(3,418)
(6,027)
(9,445)
1,421
1,421
2
(3,144)
(5,560)
(8,704)
1,302
1,302
3
(2,888)
(5,120)
(8,008)
1,193
1,193
4
(2,645)
(4,704)
(7,349)
1,089
1,089
5
(2,424)
(4,374)
(6,798)
994
994
6 – 10
(9,400)
(15,485)
(24,885)
3,823
3,823
> 10
(13,994)
(30,457)
(44,451)
5,394
5,394
Total
(37,913)
(71,727)
(109,640)
15,216
15,216
131
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
7.Segment information
Management has determined the operating segments based on the reports reviewed by
the Executive Management team that are used to make strategic decisions. 
The segment results for the years ended 31 December 2024 and 2023 are indicated
below.
(i)  Insurance revenue and insurance service result
Short-term insurance contracts under PAA
Group and Company
At 31 December 2024
Motor
Fire and
other
property
damages
Health
Other
classes
Group
Life
Total
€’000
€’000
€’000
€’000
€’000
€’000
Insurance revenue
47,166
18,531
17,037
15,220
1,968
99,922
Insurance service expenses
(38,405)
(10,918)
(15,198)
(12,628)
(1,347)
(78,496)
Net expenses from reinsurance contracts held
(1,467)
(6,441)
(96)
(1,002)
(90)
(9,096)
Insurance service result
7,294
1,172
1,743
1,590
531
12,330
At 31 December 2023
Motor
Fire and
other
property
damages
Health
Other
classes
Life
Total
€’000
€’000
€’000
€’000
€’000
€’000
Insurance revenue
42,997
16,830
15,808
14,522
2,712
92,869
Insurance service expenses
(35,577)
(10,255)
(14,012)
(6,578)
(2,033)
(68,455)
Net expenses from reinsurance contracts held
(2,742)
(5,721)
143
(3,913)
(14)
(12,247)
Insurance service result
4,678
854
1,939
4,031
665
12,167
132
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
7.Segment information - continued
(i)  Insurance revenue and insurance service result - continued
Long-term and linked long-term business
In the opinion of the directors, the subsidiary MAPFRE MSV Life p.l.c. primarily
operates in a single business segment being that of long-term and linked long-term
insurance business.
An analysis of insurance revenue, insurance service expenses and net expenses from
reinsurance contracts held by contract type for 2024 and 2023 is included in the
following tables.
2024
Life Risk
Investment
contracts
with DPF
Total
€’000
€’000
€’000
Insurance revenue
Contracts not measured under PAA
Amounts relating to change in the LRC
-   Expected incurred claims and other directly attributable expenses
7,789
21,733
29,522
-   Changes in risk adjustment for non-financial risk for the risk expired
1,596
228
1,824
-   CSM recognised for the services provided
3,664
7,128
10,792
-   Experience adjustments  – arising from premiums received in the
      period other than those that relate to future service
170
33
203
Insurance acquisition cash flows recovery
91
4,338
4,429
13,310
33,460
46,770
Insurance service expenses
Incurred claims and other directly attributable expenses
(7,259)
(21,845)
(29,104)
Insurance acquisition cash flows amortization
(91)
(4,338)
(4,429)
(7,350)
(26,183)
(33,533)
Net income (expenses) from reinsurance contracts held
Amounts relating to the changes in the remaining coverage
-   Expected incurred claims and other directly attributable expenses
      recovery
(2,006)
—
(2,006)
-   Change in the risk adjustment for non-financial risk for the risk
      expired
(283)
—
(283)
-   CSM recognised for the services provided
(1,651)
—
(1,651)
-   Experience adjustments – arising from ceded premiums paid in the
      period other than those that relate to future service
(143)
—
(143)
Reinsurance expenses
(4,083)
—
(4,083)
Other incurred directly attributable expenses
(519)
—
(519)
Incurred claims recovery
1,858
—
1,858
(2,744)
—
(2,744)
Total insurance service result
3,216
7,277
10,493
133
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
7.Segment information - continued
(i)  Insurance revenue and insurance service result - continued
Long-term and linked long-term business - continued
2023
Life Risk
Investment
contracts
with DPF
Total
€’000
€’000
€’000
Insurance revenue
Amounts relating to change in the LRC
-   Expected incurred claims and other directly attributable expenses
7,945
24,576
32,521
-   Changes in risk adjustment for non-financial risk for the risk expired
1,397
140
1,537
-   CSM recognised for the services provided
3,589
6,178
9,767
-   Experience adjustments  – arising from premiums received in the
      period other than those that relate to future service
61
18
79
Insurance acquisition cash flows recovery
51
3,756
3,807
13,043
34,668
47,711
Insurance service expenses
Incurred claims and other directly attributable expenses
(5,471)
(13,711)
(19,182)
Insurance acquisition cash flows amortization
(51)
(3,756)
(3,807)
(5,522)
(17,467)
(22,989)
Net income (expenses) from reinsurance contracts held
Amounts relating to the changes in the remaining coverage
-   Expected incurred claims and other directly attributable expenses
      recovery
(2,309)
—
(2,309)
-   Change in the risk adjustment for non-financial risk for the risk
      expired
(242)
—
(242)
-   CSM recognised for the services provided
(1,516)
—
(1,516)
-   Experience adjustments – arising from ceded premiums paid in the
      period other than those that relate to future service
(122)
—
(122)
Reinsurance expenses
(4,189)
—
(4,189)
Other incurred directly attributable expenses
(382)
—
(382)
Incurred claims recovery
974
—
974
(3,597)
—
(3,597)
Total insurance service result
3,924
17,201
21,125
100% (2023: 100%) of consolidated insurance revenue emanate from contracts
concluded in or from Malta. All premiums emanate from external customers and there
is no business transacted between segments other than as disclosed in Note 35.
134
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
8.Investment return
An analysis of net investment return and net financial result by product line is presented below:
Group
Company
31  December 2024
Life
Risk
Investment
contracts
with DPF
Investment
contracts
without
DPF
Short-Term
contracts
measured
under the PAA
Other
Total
Short-Term
contracts
measured
under the PAA
€’000
€’000
€’000
€’000
€’000
€’000
€’000
Net investment income/(expenses)
Share of profit of other associated
  undertaking, net of tax
—
—
—
—
105
105
—
Dividend income from group
  companies
—
—
—
—
—
—
1,323
Interest revenue from financial assets
  not measured at FVTPL
—
1,153
—
355
3,932
5,440
355
Interest expenses from financial
  assets not measured at FVTPL
—
—
—
(27)
—
(27)
(27)
Net gains on FVTPL instruments
625
83,210
13,131
445
1,179
98,590
445
Other investment income
—
322
—
2
—
324
2
Net (losses)/gains from fair value
  adjustments to investment
  properties  
—
(533)
—
(196)
150
(579)
(196)
Investment income from investment
  properties
—
5,980
—
821
—
6,801
821
Expenses arising from investment
  properties
—
(437)
—
(15)
—
(452)
(15)
Other investment expenses
—
(6,493)
—
(31)
(20)
(6,544)
(31)
Net credit impairment losses  
—
8
—
1
—
9
1
Interest on lease liabilities
—
—
—
(77)
—
(77)
(77)
Net investment income
625
83,210
13,131
1,278
5,346
103,590
2,601
Finance income/(expenses) from
  insurance contracts issued
Changes in value of underlying assets
  of  contracts measured under VFA
—
(83,210)
—
—
—
(83,210)
—
Interest accreted
1,577
—
—
—
—
1,577
—
Effect of changes in interest rates and
  other financial assumptions
(765)
—
—
(818)
—
(1,583)
(818)
Effect of changes in FCF at current
  rates  when CSM is unlocked at
  locked-in rates
24
—
—
—
—
24
—
Finance income/(expense) from
insurance contracts issued
836
(83,210)
—
(818)
—
(83,192)
(818)
Finance income/(expenses) from
  reinsurance contracts held
Interest accreted
(818)
—
—
—
—
(818)
—
Effect of changes in interest rates and
  other financial assumptions
73
—
—
182
—
255
182
Effect of changes in FCF at current
  rates  when CSM is unlocked
  at locked-in rates
48
—
—
—
—
48
—
Finance (expense)/income from
  reinsurance contracts held
(697)
—
—
182
—
(515)
182
Net change in investment contract
  liabilities
—
—
(13,131)
—
—
(13,131)
—
Net investment return and net
financial result
764
—
—
642
5,346
6,752
1,965
135
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
8.  Investment return - continued
Group
Company
31 December 2023
Life
Risk
Investment
contracts
with DPF
Investment
contracts
without
DPF
Short-Term
contracts
measured
under the PAA
Other
Total
Short-Term
contracts
measured
under the PAA
€’000
€’000
€’000
€’000
€’000
€’000
€’000
Net investment income/(expenses)
Share of profit of other associated
  undertaking, net of tax
—
—
—
—
110
110
—
Dividend income from group
companies
—
—
—
—
—
—
147
Interest revenue from financial assets
  not measured at FVTPL
—
1,257
—
221
3,744
5,222
221
Interest expenses from financial
  assets not measured at FVTPL
—
—
—
(32)
—
(32)
(32)
Net gains on FVTPL instruments
500
170,178
8,194
812
714
180,398
812
Other investment income
—
425
—
9
—
434
9
Net (losses)/gains from fair value
  adjustments to investment
  properties  
—
(3,925)
—
61
(409)
(4,273)
61
Investment income from investment
  properties
—
5,698
—
817
—
6,515
817
Expenses arising from investment
  properties
—
(368)
—
—
—
(368)
—
Other investment expenses
—
(5,927)
—
(23)
(27)
(5,977)
(23)
Net credit impairment losses  
—
(37)
—
—
15
(22)
—
Interest on lease liabilities
—
—
—
(49)
—
(49)
(49)
Net investment income
500
167,301
8,194
1,816
4,147
181,958
1,963
Finance income/(expenses) from
  insurance contracts issued
Changes in value of underlying assets
  of contracts measured under VFA
—
(178,200)
—
—
—
(178,200)
—
Interest accreted
1,542
—
—
—
—
1,542
—
Effect of changes in interest rates and
  other financial assumptions
2,871
—
—
(1,320)
—
1,551
(1,320)
Effect of changes in FCF at current
  rates  when CSM is unlocked at
  locked-in rates
(1,764)
—
—
—
—
(1,764)
—
Finance income/(expense) from
  insurance contracts issued
2,649
(178,200)
—
(1,320)
—
(176,871)
(1,320)
Finance (expenses)/income from
  reinsurance contracts held
Interest accreted
(752)
—
—
—
—
(752)
—
Effect of changes in interest rates and
  other financial assumptions
(2,680)
—
—
486
—
(2,194)
486
Effect of changes in FCF at current
  rates when CSM is unlocked at
  locked-in  rates
719
—
—
—
—
719
—
Finance (expense)/income from
  reinsurance contracts held
(2,713)
—
—
486
—
(2,227)
486
Net change in investment contract
  liabilities
—
—
(8,194)
—
—
(8,194)
—
Net investment (losses)/return and
net financial result
436
(10,899)
—
982
4,147
(5,334)
1,129
136
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
9.      Other income
Group
2024
2023
€'000
€'000
Investment management fees
786
1,222
Management fees
125
644
Other income
371
37
1,282
1,903
10.Profit before tax
The profit before tax is stated after charging:
Group
Company
2024
2023
2024
2023
€’000
€’000
€’000
€’000
Employee compensation (Note 11)
16,579
15,218
9,238
8,295
Depreciation/amortisation:
- intangible assets (Note 16)
5,080
4,549
2,226
2,147
- property, plant and equipment (Note 18)
1,125
1,079
626
616
Impairment of receivables
10
61
10
61
Increase in provision for impairment on
receivables (Note 26)
182
41
182
41
The financial statements include fees, exclusive of VAT, charged by the Company's
auditors for services rendered during the financial years ended 31 December 2024 and
2023, relating to entities that are included in the consolidation amounting to:
137
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
10.Profit before tax - continued
Group
Company
2024
2023
2024
2023
€’000
€’000
€’000
€’000
Annual statutory audit
911
741
336
320
IFRS 17 Transition Audit
—
810
—
300
Solvency II audit
118
113
51
49
Paid during the year:
for financial year 2024
413
—
168
—
for financial year 2023
1,497
—
674
—
for financial year 2022
—
160
—
—
for financial year 2021
—
410
—
181
11.    Employee compensation
Group
Company
2024
2023
2024
2023
€’000
€’000
€’000
€’000
Salaries
15,587
14,332
8,677
7,799
Social security costs
790
726
457
420
Contributions to Employee Voluntary
  Occupational Pension Scheme
202
160
104
76
16,579
15,218
9,238
8,295
The average number of persons employed during the year was:
Group
Company
2024
2023
2024
2023
No.
No.
No.
No.
Key management personnel
26
27
14
14
Managerial
41
34
25
20
Technical
229
232
141
142
Administrative
18
15
11
9
314
308
191
185
138
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
12.    Income tax expense
Group
Company
2024
2023
2024
2023
€'000
€'000
€'000
€'000
Current tax expense
6,967
6,061
3,286
3,588
Deferred tax expense (Note 23)
(157)
2,015
126
(412)
Income tax expense
6,810
8,076
3,412
3,176
The tax on the Group’s and Company’s profit before tax differs from the theoretical
amount that would arise using the basic tax rate as follows:
Group
Company
2024
2023
2024
2023
€’000
€’000
€’000
€’000
Profit before tax
24,804
24,019
10,531
9,864
Tax at 35%
8,681
8,407
3,686
3,452
Adjusted for tax effect of :
Net exempt income and disallowed
  expenses
(826)
(410)
(111)
(118)
Property withholding tax at 8% or10%
(815)
321
59
20
Other
(230)
(242)
(222)
(178)
Income tax expense
6,810
8,076
3,412
3,176
13.    Directors’ emoluments
Group
Company
2024
2023
2024
2023
€'000
€'000
€'000
€'000
Directors' fees
250
264
187
170
Group Directors’ fees include fees payable to the Company’s directors both from the
Company and from other Group Companies where applicable.
139
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
14.Earnings per share
Earnings per share are based on the net profit for the year divided by the weighted
average number of ordinary shares in issue during the year.
Group
2024
2023
€'000
€'000
Profit attributable to owners of the Company
12,519
11,309
Number of ordinary shares in issue (Note 28)
92,000
92,000
Basic and diluted earnings per share attributable to owners of the
  Company (€)
0.136
0.123
15.Dividends
A final gross dividend in respect of year ended 31 December 2024 of €0.080268
(2023 : €0.073057) per share amounting to a total dividend of €7,384,615 (2023 :
€6,721,231) is to be proposed by the directors at the forthcoming annual general
meeting. This is equivalent to a net dividend of €0.052174 (2023: €0.048913) per
share amounting to a total net dividend of €4,800,000 (2023: €4,500,000).
140
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
16.Intangible assets
Group
Computer
Software
Deferred
Acquisition
cost (i)
Total
€’000
€’000
€’000
At 1 January 2023
Cost or valuation
51,749
3,874
55,623
Accumulated amortisation and impairment
(23,908)
(3,566)
(27,474)
Net book amount
27,841
308
28,149
Year ended 31 December 2023
Opening net book amount
27,841
308
28,149
Additions
6,581
551
7,132
Amortisation charge
(4,502)
(47)
(4,549)
Closing net book amount
29,920
812
30,732
At 31 December 2023
Cost or valuation
58,330
4,425
62,755
Accumulated amortisation and impairment
(28,410)
(3,613)
(32,023)
Net book amount
29,920
812
30,732
Year ended 31 December 2024
Opening net book amount
29,920
812
30,732
Additions
7,448
1,311
8,759
Disposal
(2,906)
—
(2,906)
Amortisation charge
(4,960)
(120)
(5,080)
Amortisation released on derecognition
2,906
—
2,906
Closing net book amount
32,408
2,003
34,411
At 31 December 2024
Cost or valuation
62,872
5,736
68,608
Accumulated amortisation and impairment
(30,464)
(3,733)
(34,197)
Net book amount
32,408
2,003
34,411
(i)  This intangible asset relates to investment contracts without DPF only.
141
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
16.Intangible assets - continued
Company
Computer
Software
€’000
At 1 January 2023
Cost
21,032
Accumulated amortisation
(11,065)
Net book amount
9,967
Year ended 31 December 2023
Opening net book amount
9,967
Additions
2,571
Amortisation charge
(2,147)
Closing net book amount
10,391
At 31 December 2023
Cost
23,603
Accumulated amortisation
(13,212)
Net book amount
10,391
Year ended 31 December 2024
Opening net book amount
10,391
Additions
2,408
Disposal
(6)
Amortisation charge
(2,226)
Amortisation released on disposal
6
Closing net book amount
10,573
At 31 December 2024
Cost
26,005
Accumulated amortisation
(15,432)
Net book amount
10,573
No amortisation (2023: nil) is included in acquisition costs and €2.2 million (2023:
€2.2 million) is included in administrative expenses.
Computer software mainly represents amounts capitalised relating to the development
of the Group and Company’s IT system by related companies forming part of the
MAPFRE S.A. Group.
142
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
17. Leases
(a)Leases as the lessee
The Group leases property and motor vehicles. Property leases generally run for a
period of five to seven years without the option to renew, whilst motor vehicle leases
typically run for a period of seven years. Lease payments are subsequently renegotiated
to reflect market rates.
i.        Right-of-use assets
Right-of-use assets related to leased motor vehicles and properties that do not meet the
definition of investment property are presented as a separate line item on the face of the
Statement of Financial Position.
2023
Group
Property
Motor
vehicles
Total
€’000
€’000
€’000
Balance on 1 January
992
469
1,461
Addition
437
40
477
Derecognition of right-of-use assets
—
(29)
(29)
Depreciation charge for the year
(219)
(118)
(337)
Depreciation released on derecognition
—
29
29
Balance on 31 December
1,210
391
1,601
2024
  Group
Property
Motor
vehicles
Total
€’000
€’000
€’000
Balance on 1 January
1,210
391
1,601
Additions
346
179
525
Derecognition of right-of-use assets
—
(65)
(65)
Depreciation charge for the year
(271)
(128)
(399)
Depreciation released on derecognition
—
39
39
Gain on derecognition
—
1
1
Balance on 31 December
1,285
417
1,702
143
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
17. Leases - continued
(a)Leases as the lessee - continued
i. Right-of-use assets - continued
2023
Company
Property
Motor
vehicles
Total
€’000
€’000
€’000
Balance on 1 January
992
386
1,378
Addition
437
—
437
Depreciation charge for the year
(219)
(87)
(306)
Balance on 31 December
1,210
299
1,509
2024
Company
Property
Motor
vehicles
Total
€’000
€’000
€’000
Balance on 1 January
1,210
299
1,509
Additions
346
131
477
Depreciation charge for the year
(271)
(99)
(370)
Balance on 31 December
1,285
331
1,616
ii.Amounts recognised in profit or loss
2023
  Group
Property
Motor
vehicles
Total
€’000
€’000
€’000
Depreciation of right-of-use assets
219
118
337
Interest expense on lease liabilities
30
24
54
144
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
17. Leases - continued
(a)Leases as the lessee - continued
ii.Amounts recognised in profit or loss - continued
2024
Group
Property
Motor
vehicles
Total
€’000
€’000
€’000
Depreciation of right-of-use assets
271
128
399
Interest expense on lease liabilities
58
27
85
2023
  Company
Property
Motor
vehicles
Total
€’000
€’000
€’000
Depreciation of right-of-use assets
219
87
306
Interest expense on lease liabilities
30
19
49
2024
  Company
Property
Motor
vehicles
Total
€’000
€’000
€’000
Depreciation of right-of-use assets
271
99
370
Interest expense on lease liabilities
58
19
77
145
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
17. Leases - continued
(b)  Leases as the lessor
The Group and the Company lease out certain property. Note 19 sets out information
about investment property. The Group has classified these leases as operating leases
because they do not transfer substantially all the risks and rewards incidental to the
ownership of the assets.
The following table sets out a maturity analysis of lease payments receivable, showing
the undiscounted lease payments to be received after the reporting date.
Operating leases
Group
Company
2024
2023
2024
2023
€’000
€’000
€’000
€’000
Less than one year
5,655
5,815
666
660
One to two years
3,068
4,079
545
445
Two to three years
2,027
2,000
138
386
Three to four years
1,393
1,401
4
38
Four to five years
900
1,052
—
—
More than five years
2,457
3,113
—
—
Total
15,500
17,460
1,353
1,529
146
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
18.Property, plant and equipment
Group
Freehold
Furniture
land and
Leasehold
fittings and
buildings
improvements
equipment
Total
€’000
€’000
€’000
€'000
At 1 January 2023
Cost
13,900
4,223
9,142
27,265
Accumulated depreciation
(253)
(2,390)
(6,996)
(9,639)
Closing net book amount
13,647
1,833
2,146
17,626
Year ended 31 December 2023
Opening net book amount
13,647
1,833
2,146
17,626
Additions
170
158
308
636
Depreciation charge
(104)
(230)
(745)
(1,079)
Closing net book amount
13,713
1,761
1,709
17,183
At 31 December 2023
Cost
14,070
4,381
9,450
27,901
Accumulated depreciation
(357)
(2,620)
(7,741)
(10,718)
Net book amount
13,713
1,761
1,709
17,183
Year ended 31 December 2024
Opening net book amount
13,713
1,761
1,709
17,183
Additions
72
276
634
982
Disposals
—
(1,153)
(922)
(2,075)
Revaluation gain to profit or loss
168
—
—
168
Depreciation charge
(104)
(319)
(702)
(1,125)
Depreciation released on disposal
—
1,063
919
1,982
Closing net book amount
13,849
1,628
1,638
17,115
At 31 December 2024
Cost
14,310
3,504
9,162
26,976
Accumulated depreciation
(461)
(1,876)
(7,524)
(9,861)
Net book amount
13,849
1,628
1,638
17,115
147
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
18.Property, plant and equipment - continued
Company
Freehold
Furniture
land and
Leasehold
fittings and
buildings
improvements
equipment
Total
€'000
€'000
€'000
€'000
At 1 January 2023
Cost
1,734
3,635
3,735
9,104
Accumulated depreciation
(32)
(1,809)
(2,783)
(4,624)
Net book amount
1,702
1,826
952
4,480
Year ended 31 December 2023
Opening net book amount
1,702
1,826
952
4,480
Additions
—
158
187
345
Depreciation Charge
(17)
(228)
(371)
(616)
Closing net book amount
1,685
1,756
768
4,209
At 31 December 2023
Cost
1,734
3,793
3,922
9,449
Accumulated depreciation
(49)
(2,037)
(3,154)
(5,240)
Net book amount
1,685
1,756
768
4,209
148
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
18.Property, plant and equipment - continued
Company - continued
Freehold
Furniture
land and
Leasehold
fittings and
buildings
improvements
equipment
Total
€’000
€’000
€’000
€’000
Year ended 31 December 2024
Opening net book amount
1,685
1,756
768
4,209
Additions
—
276
299
575
Disposal
—
(603)
(854)
(1,457)
Depreciation charge
(17)
(317)
(292)
(626)
Amortisation released on disposal
—
512
850
1,362
Closing net book amount
1,668
1,624
771
4,063
At 31 December 2024
Cost
1,734
3,466
3,367
8,567
Accumulated depreciation
(66)
(1,842)
(2,596)
(4,504)
Net book amount
1,668
1,624
771
4,063
Freehold land and buildings transferred from investment property are transferred at the
fair value at the point of transfer and are subsequently depreciated. Transfers to
investment property are made at the depreciated value at the point of transfer. If the fair
value of the freehold land and buildings is significantly different as compared to its
carrying amount then a revaluation adjustment is recorded.
Depreciation charge has been included in administrative expenses.
The Group’s and Company’s Land and buildings are shown at fair value (level 3).
A valuation of land and buildings was carried out by external qualified valuers in 2024.
The fair value movements were debited to profit or loss. The carrying amount of land
and buildings that would have been included in the financial statements had these assets
been carried at cost less accumulated depreciation for the Group is €13.7 million (2023:
€13.7 million) and for the Company €0.8 million (2023: €0.8 million).
149
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
18.    Property, plant and equipment - continued
Valuation processes
Periodically, the Group engages qualified valuers to determine the fair value of the
Group’s land and buildings.  As at 31 December 2024, the fair value of the land and
buildings of the subsidiary was determined by PwC Malta. No valuation was performed
in 2022 and 2023 on the land and building of the subsidiary. The Company’s land and
buildings were revalued by PwC Malta in 2024 with no significant change to the
carrying amount.
Whenever a valuation is carried out the finance department:
• verifies all major inputs to the valuation report prepared by the qualified valuer;
• assesses property valuation movements when compared to the prior valuation
report; and
• holds discussions with the qualified valuer.
Valuation techniques
The fair value of the Group’s and the Company’s land and buildings, with a total
carrying amount of €13.9 million and €1.7 million respectively (2023: €13.7 million
and €1.7 million respectively), was determined by capitalizing future net income
streams based on significant unobservable inputs.  These inputs include:
Valuation technique
Significant unobservable
inputs
Inter-relationship between
key unobservable inputs and
fair value measurement
Discounted cash flows: The
valuation model considers the
present value of net cash
flows potentially generated
from the property, taking into
account the expected rental
growth rate, void periods and
costs not paid for by the
tenants. The expected net
cash flows are discounted
using the risk-adjusted
discount rates. Among other
factors, the discount rate
estimation considers the
quality of a building and its
location (prime vs
secondary), lease terms,
property risk premium and
inflation.
– Risk-adjusted discount
rate varying between
6.2% and 6.6% (2023:
6.2% and 7.9%)
– The valuation provides
for a void factor
varying between 2.5% 
and 5.5% (2023: 2.5%
and 4.5%) on rental
income.
– A benchmark lease
market rate was
applied once current
lease terms expired.
– Expected market rental
growth rate of 2.0%
(2023: 2.0%) in line
with the implied
inflation rate IRR
(Internal Rate of
Return).
The estimated fair value
would increase/(decrease) if:
– The risk-adjusted
discount rate were
lower/(higher);
– Void factor were
lower/(higher)
– The market rate were
higher/(lower);
– Expected market
rental growth were
higher/(lower).
150
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
18.    Property, plant and equipment - continued
Valuation techniques - continued
Although the properties are currently being used by MMS as its Floriana Regional
Office and MMSV as its head office, for the purpose of the valuation, it was assumed
that the property’s highest and best use would be rental to a third party, assuming same
use.  Although the Market Approach was considered, its applicability is limited, due to
the illiquidity of the commercial property market in Malta and therefore, the limited
number of transactions available.  Moreover, it is inherently difficult to find
transactions including office blocks that are directly comparable to the property.
19.    Investment property
Group
Company
€’000
€’000
At 1 January 2023
Cost
66,412
7,541
Accumulated fair value gains
41,866
5,863
Net book amount
108,278
13,404
Year ended 31 December 2023
Opening net book amount
108,278
13,404
Additions
1,614
344
Net fair value (losses)/ gains
(4,273)
61
Net book amount
105,619
13,809
At 31 December 2023
Cost
68,026
7,885
Accumulated fair value gains
37,593
5,924
Net book amount
105,619
13,809
151
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
19.    Investment property - continued
Group
Company
€’000
€’000
Year ended 31 December 2024
Opening net book amount
105,619
13,809
Additions
934
100
Net fair value losses
(746)
(196)
Disposals
(1)
(1)
Net book amount
105,806
13,712
At 31 December 2024
Cost
68,959
7,984
Accumulated fair value gains
36,847
5,728
Net book amount
105,806
13,712
Transfers to or from property, plant & equipment and disposals are inclusive of
accumulated fair value gains at the point of transfer.
Fair value of investment property
A valuation of the Group’s and Company’s investment property was performed by
external qualified valuers to determine the fair value of the land and buildings as at 31
December 2024 and 2023. The fair value movements were credited to profit or loss and
are presented within ‘investment return’ (Note 8).
The Group’s and the Company’s investment property, comprising mainly office
buildings, have been determined to fall within level 3 of the fair valuation hierarchy. 
The different levels in the fair value hierarchy have been defined in Note 4.3.
The Group’s and the Company’s policy is to recognise transfers into and out of fair
value hierarchy levels as of the date of the event or change in circumstances that caused
the transfer.  There were no transfers between levels during the year.
Valuation processes
On an annual basis, the Group and Company engage external, independent property
valuers, having appropriate recognised professional qualifications and recent
experience in the location and category of the properties being valued to determine the
fair value of the land and buildings. As at 31 December 2024 and 2023, the fair values
of the land and buildings have been determined by PwC Malta and DHI Periti.
152
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
19.    Investment property - continued
Valuation processes - continued
At each financial year end the investments department:
• verifies all major inputs to the valuation report prepared by the qualified valuer;
• assesses property valuation movements when compared to the prior year valuation
report; and
• holds discussions with the qualified valuer.
The valuation techniques used for investment properties were the discounted cash flow
valuation, market approach, comparative transaction method and income capitalisation
method to provide accuracy and consistency in arriving at a fair value that reflects a
price that would be reasonably expected to be received in an orderly transaction
between market participants at the measurement date.
Valuation technique - Discounted cash flow
The following tables shows the valuation technique used in measuring the fair value of
investment property using the discounted cash flow technique, as well as the significant
unobservable inputs used. These inputs include:
Group
Valuation technique
Significant unobservable
inputs
Inter-relationship between key
unobservable inputs and fair
value measurement
Discounted cash flows: The
valuation model considers the
present value of net cash
flows generated from the
property, taking into account
the expected rental growth
rate, void periods and costs
not paid for by the tenants.
The expected net cash flows
are discounted using the risk-
adjusted discount rates.
Among other factors, the
discount rate estimation
considers the quality of a
building and its location
(prime vs secondary), lease
terms, property risk premium
and inflation.
– Risk-adjusted discount rate
varying between 6.3% and
8.3%% (2023: 7.0% and
8.6%%).
– A void factor varying
between 1.0% to 5.5%
(2023: 1.0% and 5.0%) on
rental income.
– Lease market rate was
applied once current lease
terms expired.
– Expected market rental
growth rate of 2.0% (2023:
2.0%) in line with the
general inflation rate
– Construction costs for
undeveloped airspace and
re-developable land varying
between €673/sqm and
€1,621/sqm (2023: €671/
sqm and €1,592/sqm)
The estimated fair value would
increase/(decrease) if:
– The risk-adjusted
discount rate were
lower/ (higher);
– Void factor were lower/
(higher);
– The market rate were
higher/(lower);
– Expected market rental
growth were higher/
(lower). 
– Constructions costs
were lower/(higher).
153
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
19.    Investment property - continued
Valuation technique - Discounted cash flow - continued
Company
Valuation technique
Significant unobservable inputs
Inter-relationship between
key unobservable inputs and
fair value measurement
Discounted cash flows: The
valuation model considers
the present value of net cash
flows generated from the
property, taking into account
the expected rental growth
rate, void periods and costs
not paid for by the tenants.
The expected net cash flows
are discounted using the risk-
adjusted discount rates.
Among other factors, the
discount rate estimation
considers the quality of a
building and its location
(prime vs secondary), lease
terms, property risk premium
and inflation.
– Risk-adjusted discount rate
varying between 6.6% and
7.6% (2023: 7.9% and 8.4%).
– A void factor of 5.5% (2023:
4.5%) on rental income.
– Lease market rate was applied
once current lease terms
expired.
– Expected market rental growth
rate of 2.0% (2023: 2.0%) in
line with general inflation rate.
The estimated fair value would
increase/(decrease) if:
– The risk-adjusted discount
rate were lower/(higher);
– Void factor were lower/
(higher);
– The market rate were
higher/(lower);
– Expected market rental
growth were higher/
(lower).
The fair value of investment property determined by external, qualified property
valuers on the basis of the discounted cash flow method amounted to €101.8 million
(2023: €101.2 million) for the Group and €12.8 million (2023: €12.5 million) for the
Company.
No transfers were made to or from Investment Property during 2023 and 2024.
Valuation technique – Market approach
One property held by the Group situated within the Grand Harbour Local Plan has been
valued using the Market Approach.
The property is valued with reference to parameters for comparable properties in terms
of either actual prices from recent transactions or advertised prices for properties
currently available for sale. Through the Market Approach, the property is valued in its
existing state.
154
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
19.    Investment property - continued
Valuation technique – Market approach - continued
Market Value Technique
Valuation technique
Significant unobservable inputs
Inter-relationship between key
unobservable inputs and fair
value measurement
Market value : The valuation
model comprises:                         
The estimation of an average
sales rate based on information
obtained from either actual
prices of recent transactions or
advertised prices for properties
currently available for sale.
– Average sales rate of €1,105/
sqm (2023: €1,355/sqm)
– Reduction in average sales
rate of 70% (2023: 70%) to
allow for potential negotiation
in rates between what is being
advertised to what is actually
contracted.
The estimated fair value would
increase/(decrease) if:
– The average sale rate were
higher/(lower);
– The reduction in average
sales rate were higher/
(lower);
The fair value of investment property determined by external, qualified property
valuers on the basis of market approach method amounted to €2.3 million for the Group
in 2024 (2023: €2.3 million).
Valuation technique - Comparative transactions method
The fair value of the Group’s investment properties determined on the basis of the
market comparison method amounted to €0.7 million in 2024 and 2023. The
comparative method is based on an expected sales value per square metre based on an
average/ median of values derived from observable market transactions for comparable
properties.
Valuation technique - Income Capitalisation Method
The valuation for all other investment property with a total carrying amount of €0.9
million (2023: €1.3 million) for the Group and Company, was determined by
capitalising future net income streams based on significant unobservable inputs.  These
inputs include:
Future rental cash inflows
based on the actual location, type and quality of the
properties and supported by the terms of any existing
lease, other contracts or external evidence such as
current market rents for similar properties;
Capitalisation rates
based on actual location, size and quality of the
properties and taking into account market data at the
valuation date.
155
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
19.    Investment property - continued
Valuation technique - Income Capitalisation Method - continued
Information about fair value measurements using significant unobservable inputs (level
3)
Group & Company
Significant unobservable  Inputs
Fair value at 31
December 2024
Valuation
technique
Rental value
Capitalisation
rate
Description
€
€
%
Office buildings
0.94m
Capitalisation of
future net income
streams
0.04m
5
Group & Company
Significant unobservable  Inputs
Description
Fair value at 31
December 2023
Valuation
technique
Rental value
Capitalisation
rate
€
€
%
Office buildings
1.34m
Capitalisation of
  future net income
  streams
0.05m
3.25-5.00
For each valuation for which rental value and capitalisation rate have been determined
to be the significant unobservable inputs, the higher the rental value and the lower the
capitalisation rate, the higher the fair value. Conversely, the lower the rental value and
the higher the capitalisation rate, the lower the fair value.
In the absence of future rental cash inflows, fair value is based on active market prices,
adjusted, if necessary for any difference in the nature, location or condition of the
specific asset.
156
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
19.    Investment property - continued
Sensitivity analysis
Sensitivity analysis was carried out to assess the impact of changing the risk-adjusted
discount rate (0.5 percentage point increase/decrease), or the market rental rate growth
(5.0 percentage point increase/decrease) in the case of the discounted cash flow, and
market approach (5.0 percentage point increase/decrease), and the capitalisation rate for
the income capitalisation method. The tables below show the changes in the valuation
arising from such changes:
Group
2024
2024
2023
2023
-0.5%
+0.5%
-0.5%
+0.5%
€ million
€ million
€ million
€ million
Discount rates
8.4
(8.7)
8.3
(7.3)
2024
2024
2023
2023
-5%
+5%
-5%
+5%
€ million
€ million
€ million
€ million
Market rates
(5.7)
5.5
(5.4)
5.1
Company
2024
2024
2023
2023
-0.5%
+0.5%
-0.5%
+0.5%
€ million
€ million
€ million
€ million
Discount rates
1.0
(1.0)
0.9
(0.9)
2024
2024
2023
2023
-5%
+5%
-5%
+5%
€ million
€ million
€ million
€ million
Market rates
(0.7)
0.5
(0.6)
0.5
The impact on profit or loss would be a maximum increase of €8.4 million (2023: €8.3
million) or a maximum decrease of €8.7 million (2023: €7.3 million) for the Group and
a maximum increase of €1.0 million (2023: €0.9 million) or a maximum decrease of
€1.0 million (2023: €0.9 million) for the Company.
157
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
20.Investment in subsidiary undertakings
Company
€’000
Year ended 31 December 2023
Opening net book amount
77,214
Closing net book amount
77,214
Year ended 31 December 2024
Opening net book amount
77,214
Closing net book amount
77,214
The subsidiary undertakings at 31 December are shown below:
Subsidiary undertakings
Registered office
Class of shares held
Percentage of shares held
2024
2023
Euro Globe Holdings
Limited (Struck off -
Effective 06-03-2025 )
Middle Sea House
Floriana FRN1442
Malta
Ordinary shares
100%
100%
Euromed Risk Solutions
Limited
4th Floor
Development House
St. Anne Str
Floriana FRN9010
Malta
Ordinary shares
100%
100%
Bee Insurance Management
Limited
4th Floor
Development House
St. Anne Str
Floriana FRN9010
Malta
Ordinary shares
100%
100%
MAPFRE MSV Life plc
The Mall, Triq Il-
Mall,  Floriana
FRN1470 Malta
Ordinary shares
50%
50%
Church Wharf Properties
Limited
Middle Sea House
Floriana FRN1442
Malta
Ordinary shares
75%
75%
158
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
20.Investment in subsidiary undertakings - continued
The Group’s aggregated assets and liabilities and the results of its subsidiary
undertakings that have non-controlling interest, before elimination entries, are as
follows:
2024
% Held by
non-
controlling
interests
Assets
Liabilities
Revenues
Profit
before tax
Net cash
€’000
€’000
€’000
€’000
€’000
MAPFRE MSV Life p.l.c.
50%
2,357,236
2,182,904
205,847
14,983
31,053
Church Wharf
Properties Limited
25%
2,301
368
—
(43)
—
2023
% Held by
non-
controlling
interests
Assets
Liabilities
Revenues
Profit
before tax
Net cash
€’000
€’000
€’000
€’000
€’000
MAPFRE MSV Life p.l.c.
50%
2,319,702
2,154,321
201,271
14,572
(88,713)
Church Wharf
Properties Limited
25%
2,301
325
—
(400)
—
The amount of dividends that can be distributed in cash by MAPFRE MSV Life p.l.c. is
restricted by the solvency requirements imposed by the MFSA Regulations.
During 2011, the Company acquired control of MAPFRE MSV Life p.l.c. following a
shareholders’ agreement. MAPFRE MSV Life p.l.c. had previously been accounted for
as an associated undertaking. 
As a result of this business combination, Church Wharf Properties Limited, which was
previously classified as an associated undertaking, also became a subsidiary in view of
the fact that the remaining interest in this company is held by MAPFRE MSV Life
p.l.c.
159
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
21.    Investment in associated undertakings
Group
Company
€’000
€’000
At 1 January 2023
Cost
14,480
294
Accumulated share of associated undertaking's equity
95
95
Accumulated fair value movements
8,452
—
Net book amount
23,027
389
Year ended 31 December 2023
Opening net book amount
23,027
389
Share of associated undertaking's movement in equity
14
14
Fair value movement
882
—
Closing net book amount
23,923
403
At 31 December 2023
Cost
14,480
294
Accumulated share of associated undertaking's equity
109
109
Accumulated fair value movements
9,334
—
Net book amount
23,923
403
Year ended 31 December 2024
Opening net book amount
23,923
403
Disposals
(17,900)
—
Share of associated undertaking's movement in equity
(4)
—
Fair value movement
(793)
(4)
Closing net book amount
5,226
399
At 31 December 2024
Cost
4,480
294
Accumulated share of associated undertaking's equity
105
105
Accumulated fair value movements
641
—
Net book amount
5,226
399
160
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
21.    Investment in associated undertakings - continued
The Group’s aggregated assets and liabilities and the share of the results of its
associated undertaking, which is unlisted is as follows:
2024
Registered office
Assets
Liabilities
Revenues
Profit
% of
interest
held
€’000
€’000
€’000
€’000
Middlesea
Assist Limited
4th Floor, Development
House,
St. Anne Street,
Floriana FRN9010,
Malta
1,507
520
3,208
309
49%
2023
Registered office
Assets
Liabilities
Revenues
Profit
% of
interest
held
€’000
€’000
€’000
€’000
Middlesea
Assist Limited
4th Floor, Development
House,
St. Anne Street,
Floriana FRN9010,
Malta
1,423
600
3,063
224
49%
In addition to the associated undertakings above, MAPFRE MSV Life p.l.c. also held
the following investments in associated undertakings:
Associated
undertakings
Registered
office
Class of
shares held
Percentage of shares held
MSV
Group
2024
2023
2024
2023
Plaza Centres
p.l.c.
The Plaza
Commercial
Centre
Bisazza Street
Sliema
SLM1640
Malta
Ordinary
shares
31.42%
31.42%
31.42%
31.42%
Tigne' Mall
p.l.c.
Management
Suite, The
Point
Shopping Mall
Pjazza Tigne
Point Sliema
TP01, Malta
Ordinary
shares
0.00%
35.46%
0.00%
35.46%
Plaza Centres p.l.c. and Tigne Mall p.l.c. are listed on the Malta Stock Exchange and
their share price as at 31 December 2024 was €0.60 and €1.00 respectively (31
December 2023: €0.68 and €0.90 respectively).
161
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
22.    Other investments
The investments are summarised by measurement category in the table below.
Group
Company
2024
2023
2024
2023
€’000
€’000
€’000
€’000
Fair value through profit or loss
2,054,670
1,971,728
2,813
2,486
Fair value through OCI
16,273
13,804
16,273
13,804
Amortised Cost
88,617
150,781
—
—
2,159,560
2,136,313
19,086
16,290
  (a)    Investments at fair value through profit or loss
Analysed by type of investment as follows:
Group
Company
2024
2023
2024
2023
€’000
€’000
€’000
€’000
Equity securities, and units in unit trusts
878,325
960,157
2,813
2,486
Debt securities
955,212
849,061
—
—
Assets held to cover linked liabilities
  - collective investment schemes
221,133
160,540
—
—
Forward foreign exchange contracts
—
1,970
—
—
Total investments at fair value
  through profit or loss
2,054,670
1,971,728
2,813
2,486
At 31 December 2024, the Group had €31.9 million financial commitments in respect
of uncalled capital (2023:  €35.8 million).
Equity securities and collective investment schemes are considered to be substantially
non-current assets in nature.
162
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
22.    Other investments - continued
(a) Investments at fair value through profit or loss - continued
The movements for the year are summarised as follows:
Group
Company
Fair value
through
profit & loss
Fair value
through
profit & loss
€’000
€’000
Year ended 31 December 2023
Opening net book amount
1,856,701
1,756
Additions
1,499,134
—
Disposals
(1,514,034)
—
Net fair value gains (excluding net realised gains)
122,094
730
Movement in accrued interest receivable
1,879
Accrued interest on initial application of IFRS 9
5,954
—
Closing net book amount
1,971,728
2,486
Year ended 31 December 2024
Opening net book amount
1,971,728
2,486
Additions
1,384,408
61
Disposals
(1,355,184)
—
Net fair value gains (excluding net realised
  gains)
45,299
266
Movement in accrued interest receivable
1,603
—
Closing net book amount
2,047,854
2,813
Derivative financial liabilities amounting to €6.8 million (2023: €nil), included in the
table above, are classified within liabilities in the statement of financial position.
The maturity of fixed income debt securities is summarised below:
Group
2024
2023
€'000
€'000
Within one year
19,239
25,650
Between 1 and 2 years
66,756
50,064
Between 2 and 5 years
246,539
238,481
Over 5 years
622,678
534,866
Closing net book amount
955,212
849,061
163
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
22.    Other investments - continued
(b)Fair value through OCI
Group and Company
2024
2023
€’000
€’000
Listed debt securities
16,273
13,804
The movement for the year is summarised as follows:
Listed debt securities
Group and Company
2024
2023
€’000
€’000
Year ended 31 December
Opening net book amount
13,804
10,341
Additions
6,120
3,530
Disposals
(3,909)
(379)
Net fair value gains
258
312
Closing net book amount
16,273
13,804
164
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
22.    Other investments - continued
(b)Fair value through OCI - continued
Group and Company
2024
2023
€’000
€’000
Within one year
6,347
3,847
Between 1 and 2 years
4,272
4,668
Between 2 and 5 years
4,312
2,772
Over 5 years
1,342
2,517
16,273
13,804
The movement for the year are summarised as follows:
Rating of fixed income debt securities
Group and Company
2024
2023
€’000
€’000
AAA
4,047
1,366
AA
2,517
2,821
A
5,032
5,541
BBB
4,677
4,076
BB or lower
—
—
16,273
13,804
  (c)Amortised cost
Analysed by type of investment as follows:
Group
2024
2023
€’000
€’000
Deposits with banks or credit institutions
39,657
75,977
Debt securities
48,960
74,804
88,617
150,781
165
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
22.Other investments - continued
(c)Amortised cost - continued
Analysed by type of investment as follows:
Group
2024
2023
€’000
€’000
The movements for the year are summarised as follows:
Opening net book amount
150,781
116,988
Interest income earned
4,892
4,818
Interest income collected
(5,854)
(3,032)
Additions
54,311
264,821
Redemptions and disposals
(115,521)
(232,792)
ECL
8
(22)
Closing net book amount
88,617
150,781
Maturity of investments at amortised cost:
Group
2024
2023
€’000
€’000
Within 3 months
—
61,159
Within 1 year  but exceeding 3 months
—
10,009
Between 1 and 5 years
80,442
71,431
Over 5 years
8,175
8,182
88,617
150,781
The above investments earn interest as follows:
Group
2024
2023
€’000
€’000
At fixed rates
88,617
150,781
166
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
23.  Deferred income tax
Group
Company
2024
2023
2024
2023
€’000
€’000
€’000
€’000
Balance at 1 January
11,961
10,038
1,187
1,644
Initial application of IFRS 9
—
(66)
—
(19)
Movements during the year:
Profit or loss account (Note 12)
(157)
2,015
126
(412)
Other comprehensive income
4
(26)
4
(26)
Balance at 31 December - net
11,808
11,961
1,317
1,187
Deferred income taxes are calculated on all temporary differences using a principal tax
rate of 35% (2023: 35%) with the exception of investment property and freehold and
other property, for which deferred income taxes may be calculated using a principal tax
rate of 8% or 10% of the carrying amount (2023: 8% or 10%), if appropriate.  The
analysis of deferred tax (assets)/liabilities is as follows:
Group
Company
2024
2023
2024
2023
€’000
€’000
€’000
€’000
Temporary differences on property, plant
  and equipment
6,358
5,627
1,240
1,127
Temporary differences attributable to
  investment property, unrealised capital
  losses and fair value adjustments on
  financial assets
10,523
10,455
1,191
1,182
Temporary differences attributable to
  unabsorbed tax losses and allowances                 
  carried forward
(4,840)
(3,878)
(933)
(933)
Temporary differences attributable to other
  provisions
(233)
(243)
(181)
(189)
Balance at 31 December - net
11,808
11,961
1,317
1,187
167
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
23.  Deferred income tax  - continued
Deferred income tax assets and liabilities are offset when there is a legally enforceable
right to set off a current tax asset against a current tax liability.  The following amounts
determined after appropriate offsetting are shown in the statement of financial position:
Group
Company
2024
2023
2024
2023
€’000
€’000
€’000
€’000
Deferred tax asset
(2,532)
(2,118)
(1,248)
(1,260)
Deferred tax liability
14,340
14,079
2,565
2,447
11,808
11,961
1,317
1,187
The deferred income tax assets and liabilities are, principally, recoverable after more
than 12 months.
Deferred income tax assets are recognised for tax loss carry-forwards to the extent that
the realisation of the related tax benefit through future taxable profits is probable. 
The Group and Company have unutilised capital gains of €18.7 million (2023: €23.2
million), which give rise to a deferred tax asset of €6.5 million (2023: €8.1 million) that
has not been recognised in these financial statements. The Group also has unutilised
trading losses of €0.7 million (2023: €2.5 million) giving rise to a deferred tax asset of
€0.2 million (2023: €0.9 million) which has not been recognised in these financial
statements.
The Group’s and Company’s deferred tax asset and liability were established on the
basis of tax rates that were substantively enacted as at the financial year end.
168
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.  Insurance contract assets, insurance contract liabilities, reinsurance contract assets
and reinsurance contract liabilities
24.1  Composition of statement of financial position
An analysis of the amounts presented on the statement of financial position for
insurance contracts assets, insurance contract liabilities, reinsurance contract assets and
reinsurance contract liabilities, is shown in the table below:
Group
Life Risk
Investment
Contracts
with DPF
Total long-
term business
Short-term
Under PAA
Total
€’000
€’000
€’000
€’000
€’000
As at 31 December 2024
Insurance contract assets
7,080
—
7,080
—
7,080
Insurance contract liabilities
6,400
1,948,078
1,954,478
72,968
2,027,446
Reinsurance contract assets
—
—
—
11,815
11,815
Reinsurance contract liabilities
17,073
—
17,073
—
17,073
Group
Life Risk
Investments
Contracts
with DPF
Total long-
term business
Short-term
Under PAA
Total
€’000
€’000
€’000
€’000
€’000
As at 31 December 2023
Insurance contract assets
8,945
—
8,945
—
8,945
Insurance contract liabilities
6,488
1,984,889
1,991,377
72,467
2,063,844
Reinsurance contract assets
—
—
—
13,359
13,359
Reinsurance contract liabilities
15,493
—
15,493
—
15,493
Company
2024
2023
€’000
€’000
Insurance contract liabilities
72,968
72,467
Reinsurance contract assets
11,815
13,359
Insurance liabilities and reinsurance assets in relation to short-term insurance contracts
are classified as current liabilities, in that, liability for incurred claims represent events
that happened and which would normally be settled within the normal operating cycle.
The timing of payment can be dependent on factors, like court cases, that could defer
such payment to beyond a year from the reporting date. Insurance and investment
contract liabilities in relation to long-term contracts are substantially non-current.
169
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.2  Short-term insurance contracts under PAA
Reconciliation of the liability for remaining coverage and the liability for incurred claims
The following tables present reconciliations from the opening to the closing balances of the
liability for remaining coverage (LRC) and liability for incurred claims (LIC).
Group and Company
2024
LRC
LIC
Excluding
loss
component
Loss
component
Present
value of
future cash
flows
Risk
adjustment
for non-
financial
risk
Total
€’000
€’000
€’000
€’000
€’000
Insurance contract liabilities at
  1 January
32,021
—
39,436
1,010
72,467
Insurance revenue
(99,922)
—
—
—
(99,922)
Insurance service expenses
Incurred claims and other directly
  attributable expenses
—
—
48,602
325
48,927
Changes that relate to past  service -
  changes in FCF relating to the LIC
—
—
1,260
(438)
822
Losses on onerous contracts and reversals of
  those losses
—
186
—
—
186
Insurance acquisition cash flows
  amortisation
28,562
—
—
—
28,562
Insurance service expenses
28,562
186
49,862
(113)
78,497
Insurance service result
(71,360)
186
49,862
(113)
(21,425)
Finance expenses from insurance contracts
  issued
—
—
797
21
818
Total amount recognised in
  profit or loss
(71,360)
186
50,659
(92)
(20,607)
Cash flows
Premiums received
103,808
—
—
—
103,808
Claims and other directly attributable 
  expenses paid
—
—
(53,303)
—
(53,303)
Insurance acquisition cash flows
(29,397)
—
—
—
(29,397)
Total cash flows
74,411
—
(53,303)
—
21,108
Insurance contract liabilities at
  31 December
35,072
186
36,792
918
72,968
Insurance contract liabilities at
  31 December
35,258
37,710
72,968
170
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.2  Short-term insurance contracts under PAA - continued
Reconciliation of the liability for remaining coverage and the liability for incurred
claims - continued
Group and Company
2023
LRC
LIC
Excluding
loss
component
Loss
component
Present
value of
future cash
flows
Risk
adjustment
for non-
financial
risk
Total
€’000
€’000
€’000
€’000
€’000
Insurance contract liabilities at
  1 January
29,789
402
51,374
1,399
82,964
Insurance revenue
(92,869)
—
—
—
(92,869)
Insurance service expenses
Incurred claims and other directly
  attributable expenses
—
—
50,008
445
50,453
Changes that relate to past  service -
  changes in FCF relating to the LIC
—
—
(8,121)
(869)
(8,990)
Losses on onerous contracts and reversals of
  those losses
—
(402)
—
—
(402)
Insurance acquisition cash flows
  amortisation
27,394
—
—
—
27,394
Insurance service expenses
27,394
(402)
41,887
(424)
68,455
Insurance service result
(65,475)
(402)
41,887
(424)
(24,414)
Finance expenses from insurance contracts
  issued
—
—
1,285
35
1,320
Total amount recognised in
  profit or loss
(65,475)
(402)
43,172
(389)
(23,094)
Cash flows
Premiums received
95,723
—
—
—
95,723
Claims and other directly attributable 
  expenses paid
—
—
(55,110)
—
(55,110)
Insurance acquisition cash flows
(28,016)
—
—
(28,016)
Total cash flows
67,707
—
(55,110)
—
12,597
Insurance contract liabilities at
  31 December
32,021
—
39,436
1,010
72,467
Insurance contract liabilities at
  31 December
32,021
40,446
72,467
171
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.2  Short-term insurance contracts under PAA - continued
Reconciliation of the asset for remaining coverage and the asset for incurred claims
The following tables present reconciliations from the opening to the closing balances of the
asset for remaining coverage (ARC) and asset for incurred claims (AIC).
Group and Company
2024
ARC
AIC
Remaining
coverage
excluding
loss
component
Present
value of
future cash
flows
Risk
adjustment
for non-
financial
risk
Total
€’000
€’000
€’000
€’000
Reinsurance contract assets at 1 January
2,625
10,467
267
13,359
Net income/(expense) from reinsurance contracts
  held
Reinsurance expenses
(12,763)
—
—
(12,763)
Incurred claims recovery
—
3,739
56
3,795
Changes that relate to past service - changes in FCF
  relating to the AIC
—
23
(120)
(97)
Effect of changes in the risk of reinsurers' non-
  performance
—
(30)
—
(30)
Net expense from reinsurance contracts
  held
(12,763)
3,732
(64)
(9,095)
Finance income from reinsurance contracts held
—
176
5
181
Total amount recognised in  profit or loss
(12,763)
3,908
(59)
(8,914)
Cash flows
Premiums paid net of ceding commissions and other
  directly attributable expenses paid
12,750
—
—
12,750
Recoveries from reinsurance
—
(5,380)
—
(5,380)
Total cash flows
12,750
(5,380)
—
7,370
Reinsurance contract assets at 31 December
2,612
8,995
208
11,815
172
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.2  Short-term insurance contracts under PAA - continued
Reconciliation of the asset for remaining coverage and the asset for incurred claims -
continued
Group and Company
2023
ARC
AIC
Remaining
coverage
excluding
loss
component
Present
value of
future cash
flows
Risk
adjustment
for non-
financial
risk
Total
€’000
€’000
€’000
€’000
Reinsurance contract assets at 1 January
1,250
21,683
657
23,590
Net income/(expense) from reinsurance contracts
  held
Reinsurance expenses
(11,326)
—
—
(11,326)
Incurred claims recovery
—
4,635
127
4,762
Changes that relate to past service - changes in FCF
  relating to the AIC
—
(5,202)
(532)
(5,734)
Effect of changes in the risk of reinsurers' non-
  performance
—
51
—
51
Net expense from reinsurance contracts held
(11,326)
(516)
(405)
(12,247)
Finance income from reinsurance contracts held
—
471
15
486
Total amount recognised in  profit or loss
(11,326)
(45)
(390)
(11,761)
Cash flows
Premiums paid net of ceding commissions and other
  directly attributable expenses paid
12,701
—
—
12,701
Recoveries from reinsurance
—
(11,171)
—
(11,171)
Total cash flows
12,701
(11,171)
—
1,530
Reinsurance contract assets at 31 December
2,625
10,467
267
13,359
173
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.2  Short-term insurance contracts under PAA - continued
Short-term insurance contracts – liability for incurred claims
The gross claims reported are net of expected recoveries from salvage and subrogation. 
The liability for incurred claims are largely based on claims incurred data. A Chain
Ladder approach using the Development Factor Method has been used projecting
separately each portfolio of contracts. In choosing the development factors, outliers that
would unrealistically favourably or adversely impact the estimation of the ultimate cost
are excluded. Large losses within each portfolio other than for Motor have not been
projected given the small and infrequent number of such claims over time and have
been taken at the case reserve. In the case of Motor, large losses, in the main involving
fatalities or serious bodily injury, are projected separately from attritional claims given
their severity and different development patterns.
The development tables in this note give an indication of the time it takes to settle
certain claims.  This is attributable to certain classes of business taking several years to
develop and is also due to the length of time it takes for the respective cases to be
resolved in court.
The top half of the tables below illustrates how the Company’s estimate of the ultimate
total undiscounted claims cost for each accident year has changed at successive year-
ends on a gross and net basis. The bottom half of the table reconciles the cumulative
claims to the amount appearing in the statement of financial position on a gross and net
basis. The accident-year basis is the most appropriate for the general business written
by the Company.
The Group provides separately information on the gross and net basis the claims
development for the current reporting period and nine years prior to it. The diagonals
for financial years 2021 till 2024 show the undiscounted projected ultimate claims
incurred inclusive of claims related expenses as restated upon implementation of IFRS
17. The directors have considered that this does not detract the user from adequate
information as to how the claims have evolved from the particular accident year to the
current reporting period.
174
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract assets and reinsurance contract liabilities
- continued
24.2  Short-term insurance contracts under PAA - continued
Insurance contracts under the PAA – gross liability for incurred claims
Group and Company
Accident year
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
Total
€’000
€’000
€’000
€’000
€’000
€’000
€’000
€’000
€’000
€’000
€’000
Estimate of the ultimate claim cost undiscounted
-at end of accident year
26,677
34,704
38,545
43,006
43,700
32,634
37,770
42,727
44,496
43,317
-one year later
26,748
35,127
39,334
44,264
47,172
32,240
37,618
41,788
44,452
-two years later
27,591
33,780
39,377
44,724
47,326
32,727
35,321
43,365
-three years later
27,946
33,211
39,741
45,831
49,511
32,333
35,384
-four years later
27,665
33,159
38,328
46,109
48,483
32,465
-five years later
27,605
33,045
38,099
46,392
48,291
-six years later
27,908
32,750
37,715
46,843
-seven years later
27,789
31,792
37,756
-eight years later
25,413
31,799
-nine years later
25,395
Current estimates of cumulative claims
25,395
31,799
37,756
46,843
48,291
32,465
35,384
43,365
44,452
43,317
389,067
Cumulative payments to date
(25,098)
(31,554)
(36,788)
(43,267)
(46,430)
(30,869)
(33,395)
(38,349)
(38,657)
(28,442)
(352,849)
Cumulative claims liabilities - accident years from
2015 to 2024
297
245
968
3,576
1,861
1,596
1,989
5,016
5,795
14,875
36,218
Claims liabilities - prior accident years
2,022
Claims liabilities - Group Life
226
Effect of discounting
(1,674)
Liability for incurred claims for the contracts
originated
36,792
175
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract assets and reinsurance contract liabilities
-  continued
24.2  Short-term insurance contracts under PAA - continued
Insurance contracts net of reinsurance contracts assets under the PAA – net liability for incurred claims
Group and Company
Accident year
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
Total
€’000
€’000
€’000
€’000
€’000
€’000
€’000
€’000
€’000
€’000
€’000
Estimate of the ultimate claim cost undiscounted
-at end of accident year
23,216
30,079
33,106
33,539
33,848
28,126
34,463
39,334
40,287
40,049
-one year later
23,350
30,320
33,951
33,645
35,714
27,881
34,094
38,818
39,942
-two years later
22,442
29,171
33,638
33,846
36,367
28,372
32,035
40,309
-three years later
22,786
28,863
33,325
32,704
37,032
28,358
32,087
-four years later
22,551
29,038
32,961
32,524
36,587
28,499
-five years later
22,489
28,994
32,732
33,182
36,591
-six years later
22,596
28,746
32,680
33,222
-seven years later
22,707
28,382
32,624
-eight years later
22,420
28,391
-nine years later
22,328
Current estimates of cumulative claims
22,328
28,391
32,624
33,222
36,591
28,499
32,087
40,309
39,942
40,049
334,042
Cumulative payments to date
(22,207)
(28,208)
(32,039)
(32,908)
(35,881)
(26,959)
(30,311)
(35,543)
(34,879)
(27,520)
(306,455)
Liability recognised in  statements of financial
position
121
183
585
314
710
1,540
1,776
4,766
5,063
12,529
27,587
Liability in respect of prior years
1,202
Liability in respect of life risk claims
226
Discounting element
(1,218)
Total reserve included in the  statements of the
financial position
27,797
176
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.2  Short-term insurance contracts under PAA - continued
(a)  Assumptions
Discount rates
The bottom-up approach was adopted by the Group in determining a suitable discount
rate. Under this approach, the discount rate is determined as the risk-free yield. Given
the short-term nature of its insurance contracts liabilities and liquidity of cash flows, the
Group has selected the risk-free rates as published by EIOPA as appropriate for the
nature of its liabilities taking a zero illiquidity premium.
The yield curves used to discount the estimates of future cash flows that do not vary
based on the returns of the underlying items are as follows:
2024
2023
No. of years
No. of years
1
5
10
1
5
10
Short term insurance contracts
  issued and reinsurance
  contracts held
2.2%
2.1%
2.3%
3.4%
2.3%
2.4%
Risk adjustment for non-financial risk
Non-financial risk adjustment valuation reflects the compensation that the Group needs
to manage uncertainty regarding the amount and timing of future cash outflows, which
arise from non-financial risks from fulfilling insurance contract obligations.
Underwriting risks as well as other non-financial risks like portfolio expenses and
lapses are taken into consideration when determining this.
The non-financial risk adjustment has been estimated using a confidence-interval-based
approach, using Value at Risk (VaR) metrics for the probability distribution of the
current value of future cash flows, in line with Solvency II capital requirements, and
calibrating the target percentile confidence interval to 65 percentile. The Group
estimates an adjustment for non-financial risk separately from all other estimates.
177
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
        24.2 Short-term insurance contracts under PAA - continued
(a)  Assumptions - continued
Estimates of future cash flows to fulfil insurance contracts
LIC of short-term business insurance contracts, measured under the PAA, comprise of
the estimates of future cash flows. The estimates of future cash flows is derived using a
standard actuarial claims projection technique, the Chain Ladder method, other than for
non-motor large losses. The key assumptions underlying this technique is that past
claims development experience can be used to project future claims development.
Claims reserves which exceed a certain quantum (large losses), particularly those
involving fatalities and/or serious bodily injuries, are initially reserved at the case-by-
case reserve estimate. The measurement of claim payments due by the Group involves
the assessment of future settlements and is therefore dependent on assumptions around
determining such reserves based on, among others, legal precedent and current trends in
compensation awards. Specifically for Motor large losses, the Chain Ladder Method is
subsequently used to project the ultimate cost of these claims.
(b)  Sensitivity analysis
The directors have considered the sensitivity of the key variables underlying the liability
for short-term contracts.  The most sensitive assumptions are the development factors
and discount rate changes. Development factors can be impacted by claims inflation,
increase in claims frequency and severity. Sensitivity analysis for insurance risk has
been disclosed in Note 4 . Sensitivity analysis for interest rate risk has also been
disclosed in Note 4.
178
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.3  Long-term insurance contracts - Life risk
Reconciliation of the asset or liability for remaining coverage and the liability for
incurred claims
The following tables present reconciliations from the opening to the closing balances of
the LRC (ARC) and LIC excluding any insurance acquisition cash flows assets and
other pre-recognition cash flows.
Group
2024
LRC (ARC)
LIC
Total
€’000
€’000
€’000
Insurance contract assets at 1 January
(10,686)
1,741
(8,945)
Insurance contract liabilities at 1 January
6,441
47
6,488
Insurance revenue
(13,310)
—
(13,310)
Insurance service expenses
Incurred claims and other directly attributable
  expenses
—
7,259
7,259
Insurance acquisition cash flows amortization
91
—
91
Insurance service expenses
91
7,259
7,350
Insurance service result
(13,219)
7,259
(5,960)
Finance income from insurance contracts
  issued
(836)
—
(836)
Total amounts recognised in profit or loss
(14,055)
7,259
(6,796)
Investment components
(934)
934
—
Cash flows
Premium received
16,076
—
16,076
Claims and other directly attributable expenses
—
(7,012)
(7,012)
Insurance acquisition cash flows
(491)
—
(491)
Total cash flows
15,585
(7,012)
8,573
Insurance contract assets at 31
  December
(9,978)
2,898
(7,080)
Insurance contract liabilities at 31
  December
6,329
71
6,400
179
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.3  Long-term insurance contracts - Life risk - continued
Reconciliation of the asset or liability for remaining coverage and the liability for
incurred claims - continued
Group
2023
LRC (ARC)
LIC
Total
€’000
€’000
€’000
Insurance contract assets at 1 January
(9,423)
1,023
(8,400)
Insurance contract liabilities  at 1 January
6,281
76
6,357
Insurance revenue
(13,043)
—
(13,043)
Insurance service expenses
Incurred claims and other directly attributable
  expenses
—
5,471
5,471
Insurance acquisition cash flows amortization
51
—
51
Insurance service expenses
51
5,471
5,522
Insurance service result
(12,992)
5,471
(7,521)
Finance income from insurance contracts
  issued
(2,648)
—
(2,648)
Total amounts recognised in profit or loss
(15,640)
5,471
(10,169)
Investment components
(575)
575
—
Cash flows
Premium received
15,510
—
15,510
Claims and other directly attributable expenses
—
(5,357)
(5,357)
Insurance acquisition cash flows
(398)
—
(398)
Total cash flows
15,112
(5,357)
9,755
Insurance contract assets at
  31 December
(10,686)
1,741
(8,945)
Insurance contract liabilities at
  31 December
6,441
47
6,488
180
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.3  Long-term insurance contracts - Life risk - continued
Reconciliation of the measurement components of insurance contract balances
Group
2024
Present
value of
future cash
flows
Risk
adjustment
for non-
financial risk
CSM 
Total
€’000
€’000
€’000
€’000
Insurance contract  assets at
  1 January
(56,044)
14,905
32,194
(8,945)
Insurance contract liabilities at
  1 January
6,488
—
—
6,488
Changes that relate to current service
CSM recognised for the services provided
—
—
(3,664)
(3,664)
Change in the risk  adjustment for non-
  financial risk for risk expired
—
(1,596)
—
(1,596)
Experience adjustment relating to insurance service
  expenses
(700)
—
—
(700)
(700)
(1,596)
(3,664)
(5,960)
Changes that relate to future  service
Changes in estimates that  adjust the CSM
(1,810)
450
1,360
—
Contracts initially recognised  in the period
(4,940)
1,783
3,157
—
(6,750)
2,233
4,517
—
Insurance service result
(7,450)
637
853
(5,960)
Finance (income)/expense from insurance contracts
  issued
(1,340)
—
504
(836)
Total amounts recognised in profit or loss
(8,790)
637
1,357
(6,796)
Cash flows
Premium received
16,076
—
—
16,076
Claims and other directly attributable expenses paid
(7,012)
—
—
(7,012)
Insurance acquisition cash flows
(491)
—
—
(491)
Total cash flows
8,573
—
—
8,573
Insurance contract assets at 31
  December
(56,173)
15,542
33,551
(7,080)
Insurance contract  liabilities at
  31 December
6,400
—
—
6,400
181
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.3  Long-term insurance contracts - Life risk - continued
Reconciliation of the measurement components of insurance contract balances - continued
Group
2023
Present value
of future cash
flows
Risk
adjustment
for non-
financial risk
CSM 
Total
€’000
€’000
€’000
€’000
Insurance contract assets  at 1 January
(46,144)
13,269
24,475
(8,400)
Insurance contract  liabilities at 
  1 January
6,357
—
—
6,357
Changes that relate to current service
CSM recognised for the  services provided
—
—
(3,589)
(3,589)
Change in the risk  adjustment for non-
  financial risk for risk expired
—
(1,397)
—
(1,397)
Experience adjustment relating to insurance service
  expenses
(2,535)
—
—
(2,535)
(2,535)
(1,397)
(3,589)
(7,521)
Changes that relate to future  service
Changes in estimates that adjust the CSM
(11,341)
1,872
9,469
—
Contracts initially recognised  in the period
(2,695)
1,161
1,534
—
(14,036)
3,033
11,003
—
Insurance service result
(16,571)
1,636
7,414
(7,521)
Finance (income)/expense from insurance contracts
  issued
(2,953)
—
305
(2,648)
Total amounts recognised in profit or loss
(19,524)
1,636
7,719
(10,169)
Cash flows
Premium received
15,510
—
—
15,510
Claims and other directly  attributable expenses paid
(5,357)
—
—
(5,357)
Insurance acquisition cash flows
(398)
—
—
(398)
Total cash flows
9,755
—
—
9,755
Insurance contract assets at 31 December
(56,044)
14,905
32,194
(8,945)
Insurance contract liabilities at 31 December
6,488
—
—
6,488
182
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.3  Long-term insurance contracts - Life risk - continued
Impact of contracts recognised in the year
Group
2024
2023
Non-onerous
contracts originated
Non-onerous contracts
originated
€’000
€’000
Estimates of present value of future cash outflows
-  Insurance acquisition cash flows
520
383
-  Claims and other directly attributable expense
8,793
7,088
9,313
7,471
Estimates of the present value of future cash inflows
(14,253)
(10,166)
Risk adjustment for non-financial risk adjustment
1,783
1,161
CSM
3,157
1,534
Increase in insurance contract liabilities from
  contracts recognised in the period
—
—
183
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.4  Life risk - Reinsurance contracts held
Reconciliation of the remaining coverage and incurred claims
Group
2024
2023
Remaining
coverage
Incurred
Claims
Total
Remaining
coverage
Incurred
Claims
Total
€’000
€’000
€’000
€’000
€’000
€’000
Reinsurance contract
  liabilities at 1 January
19,171
(3,678)
15,493
14,239
(3,489)
10,750
Net expenses from
reinsurance
  contracts held
Reinsurance expenses
4,083
—
4,083
4,189
—
4,189
Other directly
  attributable expenses
—
519
519
—
382
382
Incurred claims
  recovery
—
(1,858)
(1,858)
—
(974)
(974)
Net expense(/income)
  from reinsurance
  contracts held
4,083
(1,339)
2,744
4,189
(592)
3,597
Finance expenses from 
  reinsurance contracts
  held
697
—
697
2,713
—
2,713
Total amounts
  recognised in
  profit or loss
4,780
(1,339)
3,441
6,902
(592)
6,310
Cash flows
Premium paid net of
  ceding commission and
  other directly attributable
  expenses paid
(2,163)
(519)
(2,682)
(1,970)
(382)
(2,352)
Recoveries from
  reinsurance
—
821
821
—
785
785
Total cash flows
(2,163)
302
(1,861)
(1,970)
403
(1,567)
Reinsurance contract
  liabilities at 31
  December
21,788
(4,715)
17,073
19,171
(3,678)
15,493
184
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.4  Life risk - Reinsurance contracts held - continued
Reconciliation of the measurement components of reinsurance contract balances
Group
2024
Present
value of
future cash
flows
Risk
adjustment
for non-
financial
risk
CSM
Total
€’000
€’000
€’000
€’000
Reinsurance contract liabilities at 1 January
34,081
(5,626)
(12,962)
15,493
Changes that relate to current service
CSM recognised for the services received
—
—
1,651
1,651
Change in the risk adjustment for non- financial
  risk for risk expired
—
283
—
283
Experience adjustment –  relating to incurred
  claims and other directly  attributable expenses     
  recovery and reinsurance  premium
810
—
—
810
810
283
1,651
2,744
Changes that relate to future service
Changes in estimates that adjust the CSM
2,276
(36)
(2,240)
—
Contracts initially recognised in the period
587
(286)
(301)
—
2,863
(322)
(2,541)
—
Finance expenses/(income) from reinsurance
  contracts held
869
—
(172)
697
Total amounts recognised in profit or loss
4,542
(39)
(1,062)
3,441
Cash flows
Premium paid net of ceding commission and
  other directly attributable expenses paid
(2,682)
—
—
(2,682)
Recoveries from insurance
821
—
—
821
Total cash flows
(1,861)
—
—
(1,861)
Reinsurance contract liabilities at 31
  December
36,762
(5,665)
(14,024)
17,073
185
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.4  Life risk - Reinsurance contracts held - continued
Reconciliation of the measurement components of reinsurance contract balances -
continued
Group
2023
Present
value of
future cash
flows
Risk
adjustment
for non-
financial
risk
CSM
Total
€’000
€’000
€’000
€’000
Reinsurance contract liabilities at
  1 January
25,404
(4,800)
(9,854)
10,750
Changes that relate to current service
CSM recognised for the  services received
—
—
1,516
1,516
Change in the risk  adjustment for non-
  financial risk for risk expired
—
242
—
242
Experience adjustment – relating to incurred
  claims and other directly  attributable expenses
  recovery and reinsurance premium
1,839
—
—
1,839
1,839
242
1,516
3,597
Changes that relate to future  service
Changes in estimates that adjust the CSM
5,186
(841)
(4,345)
—
Contracts initially recognised in the period
400
(227)
(173)
—
5,586
(1,068)
(4,518)
—
Finance expense/(income) from reinsurance
  contracts held
2,819
—
(106)
2,713
Total amounts recognised in profit or loss
10,244
(826)
(3,108)
6,310
Cash flows
Premium paid net of ceding commission and
  other directly attributable expenses paid
(2,352)
—
—
(2,352)
Recoveries from insurance
785
—
—
785
Total cash flows
(1,567)
—
—
(1,567)
Reinsurance contract liabilities at 31
  December
34,081
(5,626)
(12,962)
15,493
186
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.4  Life risk - Reinsurance contracts held - continued
Impact of contracts recognised in the year
Group
2024
2023
€’000
€’000
Estimates of the present value of future cash inflows
(3,632)
(2,860)
Estimates of the present value of future cash outflows
4,219
3,260
Risk adjustment for non-financial risk
(286)
(227)
CSM
(301)
(173)
Increase in reinsurance contract assets from
  contracts recognised in the period
—
—
187
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.5  Investment contracts with DPF
Reconciliation of the liability for remaining coverage and the liability for incurred
claims
Group
2024
2023
LRC
Excluding
Loss
Component
LIC
Total
LRC
Excluding
Loss
Component
LIC
Total
€’000
€’000
€’000
€’000
€’000
€’000
Insurance contract liabilities
at 1 January
1,935,970
48,919
1,984,889
1,914,851
46,601
1,961,452
Insurance revenue
(33,460)
—
(33,460)
(34,668)
—
(34,668)
Insurance service expenses
Incurred claims and other
  directly attributable
  expenses
—
21,845
21,845
—
13,711
13,711
Insurance acquisition cash
  flows amortization
4,338
—
4,338
3,756
—
3,756
Insurance service expenses
4,338
21,845
26,183
3,756
13,711
17,467
Insurance service result
(29,122)
21,845
(7,277)
(30,912)
13,711
(17,201)
Finance expenses from
insurance contracts
  issued
83,210
—
83,210
178,200
—
178,200
Total amounts recognised in
profit or loss
54,088
21,845
75,933
147,288
13,711
160,999
Investment components
(233,487)
233,487
—
(255,819)
255,819
—
Cash flows
Premium received
142,452
—
142,452
135,175
—
135,175
Claims and other directly
  attributable expenses
—
(250,210)
(250,210)
—
(267,212)
(267,212)
Insurance acquisition cash
  flows
(4,240)
—
(4,240)
(3,721)
—
(3,721)
increase in policy loans
(746)
—
(746)
(1,804)
—
(1,804)
Total cash flows
137,466
(250,210)
(112,744)
129,650
(267,212)
(137,562)
Insurance contract liabilities
at 31 December 
1,894,037
54,041
1,948,078
1,935,970
48,919
1,984,889
188
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.5  Investment contracts with DPF - continued
Reconciliation of the measurement components of contract balances
Group
2024
Present
value of
future cash
flows
Risk
adjustment
for non-
financial
risk
CSM 
Total
€’000
€’000
€’000
€’000
Insurance contract liabilities at 1 January
1,910,347
2,815
71,727
1,984,889
Changes that relate to current service
CSM recognised for the services provided
—
—
(7,128)
(7,128)
Change in the risk adjustment for non-financial risk for risk
  expired
—
(228)
—
(228)
Experience adjustment relating to insurance service
expenses
79
—
—
79
79
(228)
(7,128)
(7,277)
Changes that relate to future service
Changes in estimates that adjust the CSM
(8,215)
669
7,546
—
Contracts initially recognised in the period
(3,095)
223
2,872
—
Experience adjustments - arising
  from premiums received in the
  period that relate to future
  service
(2,591)
—
2,591
—
(13,901)
892
13,009
—
Insurance service result
(13,822)
664
5,881
(7,277)
Finance expense from insurance contracts issued
83,210
—
—
83,210
Total amounts recognised in profit or loss
69,388
664
5,881
75,933
Cash flows
Premium received
142,452
—
—
142,452
Claims and other directly attributable expenses paid
(250,210)
—
—
(250,210)
Insurance acquisition cash flows
(4,240)
—
—
(4,240)
Increase in policy loans
(746)
—
—
(746)
Total cash flows
(112,744)
—
—
(112,744)
Insurance contract liabilities at 31 December
1,866,991
3,479
77,608
1,948,078
189
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.5  Investment contracts with DPF - continued
Reconciliation of the measurement components of contract balances - continued
Group
2023
Present
value of
future cash
flows
Risk
adjustment
for non-
financial
risk
CSM 
Total
€’000
€’000
€’000
€’000
Insurance contract liabilities at 1 January
1,904,544
2,199
54,709
1,961,452
Changes that relate to current service
CSM recognised for the services provided
—
—
(6,178)
(6,178)
Change in the risk adjustment for non-financial risk for risk
  expired
—
(140)
—
(140)
Experience adjustment relating to insurance service
expenses
(10,883)
—
—
(10,883)
(10,883)
(140)
(6,178)
(17,201)
Changes that relate to future service
Changes in estimates that adjust the CSM
(18,202)
612
17,590
—
Contracts initially recognised in the period
(2,489)
144
2,345
—
Experience adjustments - arising from premiums received
  in the period that relate to future service
(3,261)
—
3,261
—
(23,952)
756
23,196
—
Insurance service result
(34,835)
616
17,018
(17,201)
Finance expense from insurance contracts issued
178,200
—
—
178,200
Total amounts recognised in profit or loss
143,365
616
17,018
160,999
Cash flows
Premium received
135,175
—
—
135,175
Claims and other directly attributable expenses paid
(267,212)
—
—
(267,212)
Insurance acquisition cash flows
(3,721)
—
—
(3,721)
Increase in policy loans
(1,804)
—
—
(1,804)
Total cash flows
(137,562)
—
—
(137,562)
Insurance contract liabilities at 31 December
1,910,347
2,815
71,727
1,984,889
190
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.5  Investment contracts with DPF - continued
Impact of contracts recognised in the year
Group
2024
2023
Investment contracts with DPF
Non-onerous
contracts originated
Non-onerous contracts
originated
€’000
€’000
Estimates of present value of future cash outflows
-    Insurance acquisition cash flows
4,014
4,001
-    Claims and other directly attributable expense
149,277
144,823
153,291
148,824
Estimates of the present value of future cash inflows
(156,386)
(151,313)
Risk adjustment for non-financial risk adjustment
223
144
CSM
2,872
2,345
Increase in insurance contract liabilities from
contracts recognised in the period
—
—
24.6  Long term contracts - inputs, assumptions and estimation techniques
In applying IFRS 17 measurement requirements, the below inputs, assumptions and
estimation techniques were used.
(a)Estimation techniques
Best estimate of future cash flows
The best estimate liability is the present value of expected future cash flows, discounted
using a  yield curve (i.e. interest rates at different maturities at a given point in time).
The estimates of these future cash flows are based on probability-weighted expected
future cash flows. The Group estimates which cash flows are expected and the
probability that they will occur as at the measurement date. The projections allow for all
expected decrements and policyholder actions, including lapses. Future premiums are
taken into account up to the contract boundary. Allowance for future expenses take into
account both overheads and directly attributable expenses, and future expense inflation.
The cash flow projections is performed on a policy by policy basis.
Investment contracts with DPF liabilities include the cost of financial guarantees and
options. A market consistent stochastic valuation is used to calculate these costs.
Representative model pointing is used in these stochastic runs. For such contracts,
discretionary benefits are allowed for separately in the investment contract liabilities.
The calculations reflect a pre-defined set of realistic management actions and
policyholder behaviour. The best estimate liability does not include the value of
shareholder transfers.
191
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.6  Long term contracts - inputs, assumptions and estimation techniques - continued
(a)Estimation techniques - continued
Best estimate of future cash flows - continued
For unit-linked business, the unit and non-unit components are unbundled for the
purposes of determining the best estimate liability.
Risk adjustment for non-financial risk
The risk adjustment for non-financial risk is the compensation that is required for
bearing the uncertainty about the amount and timing of cash flows that arises from non-
financial risk as the insurance contract is fulfilled. Because the risk adjustment
represents compensation for uncertainty, estimates are made on the degree of
diversification benefits and expected favourable and unfavourable outcomes in a way
that reflects the Group’s degree of risk aversion. The Group estimates an adjustment for
non-financial risk separately from all other estimates. The Group considers separately
the effect of reinsurance in the risk adjustment for non-financial risk of the underlying
insurance contracts. The risk adjustment applied by the Group only includes mortality
risk, lapse risk, and expenses risk and catastrophic risk.
The risk adjustment was calculated at the issuing entity level and then allocated down to
each group of contracts in accordance with their risk profiles. The value at risk (‘VaR’)
method was used to derive the overall risk adjustment for non-financial risk, whereby
the maximum loss that a portfolio can experience within a one year time horizon at a
confidence level of 85 percent is determined. This technique discounts future cash flows
of the best estimate liabilities under different possible scenarios to produce a risk
distribution. The risk adjustment is taken to be equal to the VaR with that confidence
interval less the value of the best estimate of the discounted cash flows.
(b)  Assumptions
All assumptions are best estimate, with no prudential margins. The Group takes into
account all relevant available data, both internal and external, when arriving at
assumptions that best reflect the characteristics of the underlying insurance portfolio.
In calculating estimates of fulfilment cash flows, the Group uses information about past
events, current conditions and forecasts of future conditions. The Group’s estimate of
future cash flows is the mean of a range of scenarios that reflect the full range of
possible outcomes. Each scenario specifies the amount, timing and probability of cash
flows.
Assumptions used to develop estimates about future cash flows are reassessed at each
reporting date and adjusted where required.
192
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.6  Long term contracts - inputs, assumptions and estimation techniques - continued
(b)Assumptions - continued
Investment assets returns
For with-profits contracts, assumptions about future underlying investment returns are
made. Due to the measurement models applied and the nature of the products,
particularly the determination of the discount rates used to discount future estimates of
cash flows that vary with returns on underlying items, assumptions about future
underlying investment returns do not impact contract measurement significantly. There
are limited financial guarantees in these products. The liabilities associated with these
guarantees are measured using a market-consistent stochastic model. The interest rate
guarantee embedded in investment contracts with DPF was measured using stochastic
modelling, because the guarantee does not move symmetrically with different interest
rate scenarios. The guarantee was measured using a full range of scenarios representing
possible future risk-free interest rate environments published by European Insurance
and Occupational Pensions Authority (‘EIOPA’). Stochastic investment returns reflect
the volatility of the underlying assets.
For a sensitivity analysis, refer to Note 4.2(a).
Discount rates
The bottom-up approach was adopted by the Group in determining a suitable discount
rate. This approach was used to derive the discount rate for the cash flows that do not
vary based on the returns on underlying items in the investment contracts with DPF.
Under this approach, the discount rate is determined as the risk-free yield, adjusted for
differences in liquidity characteristics between the financial assets used to derive the
risk-free yield and the relevant liability cash flows (known as an ‘illiquidity premium’).
The risk-free rates used were as published by EIOPA and the Group evaluates the
illiquidity premium on a yearly basis.
Management uses judgement to assess liquidity characteristics of the liability cash
flows. The Group’s insurance contracts do not have a cash surrender value and hence,
its liabilities can be considered as illiquid which allows the Group to reflect the
illiquidity characteristics of these products via the illiquidity premium. The Group
decided to use a reference portfolio as an appropriate proxy for the term liabilities.
193
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.6  Long term contracts - inputs, assumptions and estimation techniques - continued
(b)Assumptions - continued
Discount rates - continued
On the other hand, the Group’s investment contracts with DPF have surrender value and
therefore, liabilities can be considered highly liquid. Thus, these are discounted using
the risk-free rates without applying any illiquidity adjustment. Cash flows varying based
on underlying items are discounted using a discount rate that reflects the volatility of the
underlying assets.
For a sensitivity analysis, refer to Note 4.2(a).
The yield curves used to discount the estimates of future cash flows that do not vary
based on the returns of the underlying items are as follows:
2024
2023
No. of years
No. of years
Product
5
10
5
10
Life risk (issued and
  reinsurance held)
2.3%
2.4%
2.4%
2.5%
Investment contracts
  with DPF
2.1%
2.3%
2.3%
2.4%
Policy acquisition and maintenance expenses
The Group projects estimates of future expenses relating to fulfilment of contracts
within the scope of IFRS 17 using current expense levels adjusted for inflation, non-
recurring expenses and new budgeted expenses that the Group is expected to incur in
the future. Expenses comprise expenses directly attributable to the groups of contracts,
including an allocation of fixed and variable overheads.
The short-term expense inflation assumption is based on forecasts issued by the Central
Bank of Malta, adjusted for the Group’s own experience. The long-term expense
inflation assumption is based on the Central Bank of Malta long-term inflation target.
Expense inflation is considered to be a non-financial risk.
Where estimates of indirect expenses-related cash flows are determined at the portfolio
level or higher, they are allocated to groups of contracts on a systematic basis, such as
number of policies in force. A renewal per policy maintenance expense including
claims is derived for all portfolios.
194
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.6  Long term contracts - inputs, assumptions and estimation techniques - continued
(b)Assumptions - continued
Policy acquisition and maintenance expenses - continued
2024
2023
Life Risk
48.5
41.7
Investment contracts with DPF
76.5 - 102.3
50.7 - 86.6
Acquisition cash flows are typically allocated to the groups of contracts from which
they arise or to which they relate. This includes an allocation of acquisition cash flows
among existing new business. An acquisition expense per new business policy is
derived for all portfolios.
The Group provides investment-return services for the investment contracts with DPF
to manage assets in policyholder accounts and investment-related services for the
contracts measured under the VFA. An investment expense per asset under management
is derived.
For a sensitivity analysis, refer to Note 4.1.
Mortality rates
Mortality experience is reviewed annually and assumptions are set separately for term
and investment contracts with DPF having regard to past experience, events not in data 
and future expected mortality trends. The Group makes reference to the following
standard mortality table. This UK mortality table is based on male assured lives of
combined smoker status
2024
2023
Life Risk
44% TMC00
44% AMC00
Investment contracts with DPF
48% AMC00
50% AMC00
The Group fits its own experience as a percentage of the TMC00 and AMC00 (2023:
AMC00) mortality table and uses this as a basis for its mortality assumption.
For a sensitivity analysis, refer to Note 4.1.
195
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
24.Insurance contract assets, insurance contract liabilities, reinsurance contract
assets and reinsurance contract liabilities - continued
24.6  Long term contracts - inputs, assumptions and estimation techniques - continued
(b)Assumptions - continued
Lapse rates
The Group derives assumptions about lapse and surrender rates based on the Group's
own experience. Historical lapse and surrender rates are derived from the Group’s
policy administration data. An analysis is then performed of the Group’s historical rates
in comparison to the assumptions previously used. Statistical methods are used to derive
adjustments to reflect the Group’s own experience and any trends in the data, to arrive
at the probability-weighted expected lapse and surrender rates. Analysis is performed
and assumptions are set by major product lines.
For investment contracts with DPF, the Group incorporates dynamic lapsing. For these
products lapse experience also vary by market conditions and outlook.
The following assumptions about lapse and surrender rates were used. Methods used to
derive these assumptions have not changed in 2024.
2024
2023
Life Risk
3.0% - 7.0%
3.0% - 7.0%
Investment contracts with DPF
0.5% - 6.0%
0.5% - 7.0%
For a sensitivity analysis, refer to note 4.1.
196
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
25.Investment contract liabilities
The table shows a reconciliation of the opening to closing balance for the investment
contract liabilities.
Group
2024
2023
€’000
€’000
Opening balance – 1 January
123,253
69,054
Contributions received
47,684
50,266
Benefits paid
(4,308)
(3,582)
Investment return from underlying assets
13,131
8,194
Asset management fees charged
(75)
(679)
Closing balance – 31 December
179,685
123,253
In the above reconciliation, the investment return from the underlying assets represents
changes in the fair value of the investment contract liabilities due to changes in market
conditions. Asset management fees charged in the profit or loss also includes trailer
fees .
The above liabilities are substantially non-current in nature.
26.  Trade and other receivables
Group
Company
2024
2023
2024
2023
€’000
€’000
€’000
€’000
Receivables from intermediaries
18,313
19,410
18,313
19,410
Other prepayments and receivables:
- prepayments and other receivables
5,269
5,635
905
1,544
- accrued interest and rent
1,161
758
342
179
- receivables from subsidiary undertakings
—
48
624
532
- receivables from associated
  undertaking
226
59
226
59
- other debtors
205
115
—
—
Provision for impairment of receivables
(717)
(535)
(717)
(535)
24,457
25,490
19,693
21,189
Current portion
24,457
25,490
19,693
21,189
Balances due from subsidiary undertakings, associated undertaking and other
receivables are unsecured and non-interest bearing.
197
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
26.Trade and other receivables - continued
Movements in the provision for impairment of receivables are as follows:
Group and Company
2024
2023
€’000
€’000
Balance as at 1 January
535
440
Adjustment on initial application of IFRS 9 for impairment losses
—
54
Increase in provision for impairment
182
41
Balance as at 31 December
717
535
27.Cash and cash equivalents
For the purpose of the statement of cash flows, the year-end cash and cash equivalents
comprise the following:
Group
Company
2024
2023
2024
2023
€’000
€’000
€’000
€’000
Cash at bank and in hand
79,399
45,975
11,408
8,780
T-Bills
2,500
2,000
2,500
2,000
81,899
47,975
13,908
10,780
As at 31 December 2024 an amount of €6.2 million (2023: €2.8 million) within
deposits with banks or credit institutions, was held in a margin account as collateral
against exchange traded futures.
28.Share capital
Group and Company
2024
2023
€’000
€’000
Authorised
150 million ordinary shares of €0.21 each
31,500
31,500
Issued and fully paid
92 million ordinary shares of €0.21 each
19,320
19,320
198
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
29.  Other reserves
Group
Freehold
land and
buildings
FVOCI
investments
Total
€'000
€'000
€'000
Balance at 1 January 2023
856
(506)
350
Fair value movements -gross
—
284
284
Fair value movements -tax
—
(11)
(11)
FVOCI investment - reclassified to profit or loss
—
14
14
Balance at 31 December 2023
856
(219)
637
Balance at 1 January 2024
856
(219)
637
Fair value movements -gross
—
170
170
Fair value movements -tax
—
(7)
(7)
Balance at 31 December 2024
856
(56)
800
The above reserves are not distributable reserves .
199
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
29.Other reserves - continued
        Company
Investment
in subsidiary
undertakings
Investment
in associated
undertakings
FVOCI
investments
Total
€’000
€’000
€’000
€’000
Balance at 1 January 2023
34,663
95
(506)
34,252
Fair value movements -gross
—
—
284
284
Fair value movements -tax
—
—
(11)
(11)
FVOCI investment - reclassified to
  profit or loss
—
—
14
14
Other
—
14
—
14
Balance at 31 December 2023
34,663
109
(219)
34,553
Balance at 1 January 2024
34,663
109
(219)
34,553
Fair value movements -gross
—
—
170
170
Fair value movements -tax
—
—
(7)
(7)
Other
—
(4)
—
(4)
Balance at 31 December 2024
34,663
105
(56)
34,712
The above reserves are not distributable reserves.
30.    Provision for other liabilities and charges
The Group and Company operate a defined benefit plan in favour of a former Executive
Chairman.  The pension plan defines an amount of pension benefit that he receives on
retirement. The liability recognised in the statement of financial position is the present
value of the obligation determined by discounting estimated future cash outflows.
The following table shows the changes in the present value of the pension obligation
and amounts shown in the profit or loss and other comprehensive income:
200
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
30.    Provision for other liabilities and charges - continued
Group and Company
2024
2023
€’000
€’000
At 1 January
923
854
Interest expense - profit or loss
27
32
Settlements
(69)
(67)
Re-measurement actuarial loss - other comprehensive income
8
104
At 31 December
889
923
The following payments as expected in the future years:
Group and Company
2024
2023
€’000
€’000
Within one year
67
66
After more than one year
822
857
889
923
The significant assumptions used in determining the pension obligation are shown
below:
Group and Company
2024
2023
Mortality
AMC00
AMC00
Discount rate
3.1%
3.1%
Inflation rate
2.4%
2.4%
A quantitative analysis of the impact on the pension obligation for the significant
assumptions is shown below:
Group and Company
2024
2023
€’000
€’000
Discount Rate - 1% point increase
(64)
(69)
Discount Rate - 1% point decrease
73
79
Inflation Rate - 1% point increase
67
73
Inflation Rate - 1% point decrease
(61)
(66)
201
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
31.Other payables
Group
Company
2024
2023
2024
2023
€’000
€’000
€’000
€’000
Creditors arising out of insurance operations
211
260
211
260
Amount owed to associated undertakings
236
242
236
242
Amount owed to subsidiary undertakings
—
—
1,177
999
Social security and other tax payables
4,364
5,293
1,761
1,765
Accruals and other payables
12,020
11,760
5,609
6,008
Deferred income
1,352
1,366
140
40
Other creditors
1,716
428
—
—
19,899
19,349
9,134
9,314
Current
19,644
19,094
9,134
9,314
Non-current
255
255
—
—
19,899
19,349
9,134
9,314
Balances due to subsidiary undertakings and associated undertaking are unsecured and
non-interest bearing.
Deferred income for the Group includes front-end fees received from holders of
investment contracts without DPF as a prepayment for asset management and related
services and rental income received in advance. These amounts are non-refundable and
are released to income as the services are rendered.
202
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
32.Cash generated from operations
Reconciliation of profit before tax to cash (used in)/ generated from operations:
Group
Company
2024
2023
2024
2023
€’000
€’000
€’000
€’000
Profit before tax
24,804
24,019
10,531
9,864
Adjustments for:
Depreciation (Note 18)
1,125
1,079
626
616
Adjustment on initial application of IFRS 9
for impairment losses
—
(55)
—
(55)
Increase in provision for impairment of
  receivables (Note 26)
182
41
182
41
Settlement of provision for liabilities and
  charges (Note 30)
(69)
(67)
(69)
(67)
Amortisation (Note 16)
5,080
4,549
2,226
2,147
Depreciation of right-of-use assets
411
334
370
306
Lease payments against lease liabilities
(463)
(398)
(434)
(359)
Investment return adjustments
(106,057)
(185,695)
(1,826)
(1,160)
Loss on sale of property, plant and
equipment
92
—
93
—
Property revaluation
(168)
—
—
—
Movements in:
  Trade and other receivables
1,151
(2,410)
1,385
(2,303)
  Insurance and reinsurance contracts
(31,407)
27,497
2,046
(267)
  Investment contract liabilities
56,432
54,199
—
—
  Other payables
1,098
1,764
(181)
2,016
Cash (used in)/generated from operations
(47,789)
(75,143)
14,949
10,779
203
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
33.Commitments
Capital commitments
Commitments for capital expenditure not provided for in these financial statements are
as follows:
Group
Company
2024
2023
2024
2023
€’000
€’000
€’000
€’000
Authorised and not contracted for
-  property, plant and equipment
1,222
629
638
—
-  intangible assets
2,657
4,485
714
528
-  investment property
320
853
170
—
4,199
5,967
1,522
528
Authorised and contracted for
-  property, plant and equipment
359
182
269
140
-  intangible assets
2,864
3,273
2,053
2,340
-  investment property
2,256
1,219
—
50
-  other investments
31,935
35,835
—
—
37,414
40,509
2,322
2,530
Operating lease commitments – where a Group company is a lessor
The Group and the Company lease out certain premises under operating leases. The
future minimum lease payments receivable under non-cancellable operating leases are
disclosed in Note 17.
Rental income from operating leases recognised in profit or loss during the year is
disclosed in Note 8.
34.Contingencies
The Group and Company have given guarantees to third parties amounting to €0.1
million ( 2023: €4,600) not arising under contracts of insurance.
204
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
35.Related party transactions
In the normal course of business, the Group enters into various transactions with related
parties.  Related parties are defined as those that have an ability to control or exercise
significant influence over the other party in making financial and operational decisions. 
These include directors, key management personnel and shareholders, and their close
family members, who hold a substantial amount of the votes able to cast at general
meetings. Parent undertaking refers to MAPFRE S.A. and/or companies owned by
MAPFRE S.A.. Bank of Valletta p.l.c. is a related undertaking in light of its
shareholding in the Company and in MAPFRE MSV Life p.l.c.. Subsidiary
undertakings and associated undertakings refer to the companies listed in Notes 20 and
21 respectively.
Relevant particulars of related party transactions are as follows:
Group
2024
2023
€’000
€’000
Sales of insurance contracts and other services
Transactions with a parent undertaking:
  Commission received
5,266
5,328
  Claims recoverable
5,705
12,377
Transactions with related undertaking:
  Trailer fees receivable
1
1
  Sale of insurance contracts
246
1,086
  Dividends received and interest income
1,611
637
  Rental income on investment property
255
248
Transactions with associated undertaking:
  Sale of insurance contracts
31
20
  Dividends received
170
147
  Rental income on investment property
44
44
  Reimbursement of expenses for back office support services
23
19
205
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
35.Related party transactions  - continued
Group - continued
2024
2023
€’000
€’000
Purchase of products and services
Transactions with a parent undertaking:
Reinsurance premium ceded
19,522
17,997
Staff development training & Fringe Benefits
2
4
Expat staff benefits and services
97
105
Computer maintenance, Group IT shared services
1,440
1,920
Capitalisation of software development
1
9
Other back office support services
720
647
Investment management services
27
20
Commission payable
96
82
Transactions with other related undertaking:
Acquisition costs payable
3,449
2,638
Bank charges
223
207
Investment management services
45
49
Claims paid
556
148
Transactions with associates undertaking:
Road side assistance and other back office support services
2,819
2,856
Claims paid
8
4
206
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
35.Related party transactions  - continued
        Company
2024
2023
€’000
€’000
Sales of insurance contracts and other services
Transactions with a parent undertaking:
Commission received
5,266
5,328
Claims recoverable
4,550
11,075
Transactions with related undertaking:
Sale of insurance contracts
246
1,086
Dividends received and interest income
91
26
Trailer fees receivable
1
1
Transactions with subsidiary undertaking:
Sale of insurance contracts
352
190
Dividends received
1,154
—
Rental income on investment property
29
52
Rental income from sub-letting of shared premises
44
32
Reimbursement of expenses for back office support services
1,226
1,013
Transactions with associated undertaking:
Sale of insurance contracts
31
20
Dividends received
170
147
Rental income on investment property
44
44
Reimbursement of expenses for back office support services
23
19
207
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
35.Related party transactions - continued
Company - continued
2024
2023
€’000
€’000
Purchase of products and services
Transactions with a parent undertaking:
Reinsurance  premium ceded
17,217
15,860
Staff development training & fringe benefits
2
4
Expat staff benefits and services
97
105
Computer maintenance, Group IT shared services
605
824
Capitalisation of software development
1
9
Other back office support services
519
458
Investment management services
27
20
Transactions with other related parties:
Bank charges
126
111
Bank interest payable
—
—
Claims paid
556
148
Transactions with subsidiaries
Reimbursement of expenses for back office support services
2,348
2,490
Claims paid
4
135
Employer's contribution to defined contribution work pension scheme
104
76
Transactions with associates
Road side assistance and other back office support services
2,819
2,856
Claims paid
8
4
Key management personnel during 2024 and 2023 comprised the President & Chief
Executive Officer, Chief Executive Officers, General Manager, Chief Financial Officer,
Chief Officers and Chief Underwriters. Total remuneration paid by the Group to key
management personnel amounted to €3.9 million (Company: €2.0 million). 
Corresponding figures for 2023 were €3.6 million paid by the Group and €1.8 million
paid by the Company.
208
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
35.Related party transactions - continued
Year-end balances arising from the above transactions:
Group
Company
2024
2023
2024
2023
€’000
€’000
€’000
€’000
Financial assets at amortised cost
-Related undertaking
144
244
144
244
-Parent undertaking
159
128
159
128
Financial liabilities at amortised cost
-Parent undertaking
693
738
495
337
-Related undertaking
353
160
—
—
Amounts owed to
-Associated undertaking
236
245
236
245
-Subsidiary undertaking
—
—
1,014
1,011
Amounts owed by
-Associated undertaking
226
59
226
59
-Subsidiary undertaking
—
—
447
545
-Parent undertaking
—
—
—
—
Accruals - Parent undertaking
325
378
216
268
Reinsurance contract assets
-Parent undertaking
16,858
17,867
16,057
17,183
-Related undertaking
188
476
188
476
-Subsidiary undertaking
—
—
5
—
-Associated undertaking
3
10
3
10
Investment in related undertakings
17,064
14,088
969
800
Cash and cash equivalents with related
  undertakings
55,879
31,085
8,795
4,828
All balances above have arisen in the course of the Group’s and Company’s normal
operations. Balances due from/to subsidiary and associated undertakings are unsecured
and non-interest bearing.
209
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2024
36.    Statutory information
        MAPFRE Middlesea p.l.c. is a public limited company and is incorporated in Malta. 
The Group is 55.83% owned by MAPFRE Internacional S.A. (the “immediate parent”),
a company registered in Spain, the registered office of which is situated at Carretera de
Pozuelo 52, Majadahonda 28222, Madrid, Spain.
The Group’s ultimate parent is Fundación MAPFRE, the registered office of which is
situated at Paseo de Recoletos 23, 28004, Madrid, Spain.
The Group’s results are consolidated at MAPFRE S.A. level of which Fundación
MAPFRE is the parent and MAPFRE Internacional S.A. is the subsidiary. MAPFRE
S.A. is a company the registered office of which is situated at Carretera de Pozuelo 52,
Majadahonda 28222, Madrid, Spain.
KPMG, a Maltese civil partnershipand a member firm of the KPMG global The firm is registered as a A list of partners and directors of
organisation of independent member firms affiliated with KPMGpartnership of Certified Publicthe firm is available at Portico
International Limited, a private English company limited guarantee.Accountants in terms of theBuilding, Marina Street, Pietà,
Accountancy Profession ActPTA9044, Malta.
KPMG
92, Marina Street
Pietà, PTA 9044
Malta
Telephone(+356) 2563 1000
Fax (+356) 2566 1000
Websitewww.kpmg.com.mt
Independent Auditors’ Report
To the Shareholders of MAPFRE Middlesea p.l.c.
1    Report on the Audit of the Financial Statements
Opinion
We have audited the financial statements of MAPFRE Middlesea p.l.c (the “Company”) and of the
Group of which the Company is the parent, which comprise the statements of financial position as at
31 December 2024, the statements of profit or loss and other comprehensive income, changes in
equity and cash flows for the year then ended, and notes, comprising material accounting policies and
other explanatory information.
In our opinion, the accompanying financial statements:
(a) give a true and fair view of the financial position of the Company and of the Group as at 31
December 2024, and of their financial performance and their cash flows for the year then
ended in accordance with International Financial Reporting Standards (“IFRS”) as adopted by
the EU; and
(b) have been properly prepared in accordance with the provisions of the Companies Act, 1995
(Chapter 386, Laws of Malta) (the “Act”) and the Insurance Business Act, 1998 (Chapter 403,
Laws of Malta) (the “Insurance Business Act”) and, additionally, specifically in relation to
those of the Group, with the requirements of Article 4 of Regulation (EC) 1606/2002 on the
application of international accounting standards (the “Regulation”).
Basis for opinion
We conducted our audit in accordance with International Standards on Auditing (“ISAs”).  Our
responsibilities under those standards are further described in the Auditors’ responsibilities for the
audit of the financial statements section of our report.  We are independent of the Company and the
Group in accordance with the International Ethics Standards Board for Accountants’ International
Code of Ethics for Professional Accountants (including International Independence Standards)
(“IESBA Code”), together with the ethical requirements that are relevant to our audit of the financial
statements in accordance with the Accountancy Profession (Code of Ethics for Warrant Holders)
Directive issued in terms of the Accountancy Profession Act (Chapter 281, Laws of Malta) (“APA”),
and we have fulfilled our other ethical responsibilities in accordance with these requirements and the
IESBA Code.  We believe that the audit evidence we have obtained is sufficient and appropriate to
provide a basis for our opinion.
KPMG, a Maltese civil partnershipand a member firm of the KPMG global The firm is registered as a A list of partners and directors of
organisation of independent member firms affiliated with KPMGpartnership of Certified Publicthe firm is available at Portico
International Limited, a private English company limited guarantee.Accountants in terms of theBuilding, Marina Street, Pietà,
Accountancy Profession ActPTA9044, Malta.
KPMG
92, Marina Street
Pietà, PTA 9044
Malta
Telephone                  (+356) 2563 1000
Fax                              (+356) 2566 1000
Website                      www.kpmg.com.mt
Independent Auditors’ Report (continued)
To the Shareholders of MAPFRE Middlesea p.l.c
Key audit matters
Key audit matters are those matters that, in our professional judgement, were of most significance in
our audit of the financial statements of the current year (selected from those communicated to the
audit committee), and include a description of the most significant assessed risks of material
misstatement (whether or not due to fraud) identified by us, including those which had the greatest
effect on: the overall audit strategy; the allocation of resources in the audit; and directing the efforts of
the engagement team.  These matters were addressed in the context of our audit of the financial
statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion
on these matters.
We summarise below the key audit matters, together with our response by way of the audit
procedures we performed to address those matters in our audit, and key observations arising with
respect to such risks of material misstatement.
Estimates of the liability for incurred claims (“LIC”) with respect to short-term contracts
Accounting policy note 2.10 to the financial statements and notes 3 and 24 for further disclosures
LIC for short-term contracts (€37,710 thousand) within ‘Insurance Contract Liabilities’
The liability for incurred claims is measured as the total of the expected fulfilment cash flows relating
to insurance events that occurred by the financial reporting date, which comprise estimates of future
cash flows, adjusted to reflect the time value of money and a risk adjustment for non-financial risks.
We have considered the estimate of future cash flows as a key audit matter in view of the significant
assumptions that drive the estimate, being the subjectivity surrounding: the determination of the
development factors for the estimates of future cash flows derived using actuarial claims projection;
and the claims handlers’ judgement for specific claims reserves which exceed a certain quantum.
Due to the degree of such inherent estimation uncertainty underlying the estimate of future cash
flows, the amounts recognised in the statement of financial position may be different to those
eventually settled. Those differences may be material.
KPMG, a Maltese civil partnershipand a member firm of the KPMG global The firm is registered as a A list of partners and directors of
organisation of independent member firms affiliated with KPMGpartnership of Certified Publicthe firm is available at Portico
International Limited, a private English company limited guarantee.Accountants in terms of theBuilding, Marina Street, Pietà,
Accountancy Profession ActPTA9044, Malta.
KPMG
92, Marina Street
Pietà, PTA 9044
Malta
Telephone(+356) 2563 1000
Fax (+356) 2566 1000
Websitewww.kpmg.com.mt
Independent Auditors’ Report (continued)
To the Shareholders of MAPFRE Middlesea p.l.c
Key audit matters (continued)
Estimates of the liability for incurred claims (“LIC”) with respect to short-term contracts
(continued)
Our response
Our procedures include:
• With respect to the actuarial claims projected, we used our own actuarial specialist to develop
an independent expectation using actuarial standard techniques, as well as industry
knowledge and experience, and;
• In relation to the specific claims reserves which exceed a certain quantum, we evaluated the
judgements made by the claims handlers based on the information available to the Company
at the financial reporting date.
Key observation
We have no key observations to report, specific to this matter.
Measurement of assets and liabilities for remaining coverage (“ARC” and “LRC”) for
insurance contracts and reinsurance contracts held in relation to long-term contracts carried
out by the main subsidiary of the Group, MAPFRE MSV Life p.l.c. (MMSV)
Accounting policy note 2.10 to the financial statements and notes 3 and 24 for further disclosures
ARC and LRC for long-term contracts within the 'Insurance contract assets' (€7,080 thousand),
'Insurance contract liabilities’ (€1,954,478 thousand) and 'Reinsurer’s contract liabilities’ (€17,073
thousand)
MMSV enters into insurance contracts which comprise term and unit-linked contracts with significant
insurance risk and investment contracts with discretionary participation features (“DPF”). MMSV also
holds reinsurance contracts to cover its term business.
MMSV applies the general measurement model on its insurance contracts and reinsurance contracts
held, and the variable fee approach on investment contracts with DPF.
KPMG, a Maltese civil partnershipand a member firm of the KPMG global The firm is registered as a A list of partners and directors of
organisation of independent member firms affiliated with KPMGpartnership of Certified Publicthe firm is available at Portico
International Limited, a private English company limited guarantee.Accountants in terms of theBuilding, Marina Street, Pietà,
Accountancy Profession ActPTA9044, Malta.
KPMG
92, Marina Street
Pietà, PTA 9044
Malta
Telephone(+356) 2563 1000
Fax (+356) 2566 1000
Websitewww.kpmg.com.mt
Independent Auditors’ Report (continued)
To the Shareholders of MAPFRE Middlesea p.l.c
Key audit matters (continued)
Measurement of assets and liabilities for remaining coverage (“ARC” and “LRC”) for
insurance contracts and reinsurance contracts held in relation to long-term contracts carried
out by the main subsidiary of the Group, MAPFRE MSV Life p.l.c. (MMSV) (continued)
ARC and LRC are measured as the total of (i) the expected fulfilment cash flows (“FCF”), which
comprise estimates of future cash flows within the contract boundary, adjusted to reflect the time
value of money and the associated financial risks, and a risk adjustment for non-financial risks; and
(ii) the contractual service margin (“CSM”), which represents the unearned profit that MMSV will
recognise as it provides insurance contract services in the future. The measurement of ARC and LRC
involves use of current and historic data, actuarial methods and models, and significant assumptions
for the estimation of future cash flows.
We have considered the measurement of ARC and LRC as a key audit matter in view of the nature
and subjectivity of the estimate, and its overall inherent estimation uncertainty. The subjectivity
involved relates mainly to the judgement involved in the selection of actuarial assumptions. Due to the
degree of such inherent estimation uncertainty, the ultimate total settlement value may be different
from the amounts provided, and the amount of CSM may be different from the amounts recognised as
profit in the future. Those differences may be material.
Our response
As part of our procedures, we evaluated the ARC and LRC by performing audit procedures which
included:
• the involvement of our actuarial specialist to assist us in:
◦ assessing and challenging the significant assumptions selected by applying our
experience, industry knowledge, and reference to the related accounting standards;
and
◦ evaluating MMSV’s estimate of ARC and LRC by assessing the overall liability
movements based on the assumptions and data applied;
• testing of the underlying data elements by reference to MMSV’s actual cash flows and policy
data; and
• considering the adequacy of the related disclosures to the financial statements.
Key observation
We have no key observations to report, specific to this matter.
KPMG, a Maltese civil partnershipand a member firm of the KPMG global The firm is registered as a A list of partners and directors of
organisation of independent member firms affiliated with KPMGpartnership of Certified Publicthe firm is available at Portico
International Limited, a private English company limited guarantee.Accountants in terms of theBuilding, Marina Street, Pietà,
Accountancy Profession ActPTA9044, Malta.
KPMG
92, Marina Street
Pietà, PTA 9044
Malta
Telephone(+356) 2563 1000
Fax (+356) 2566 1000
Independent Auditors’ Report (continued)
To the Shareholders of MAPFRE Middlesea p.l.c
Other information
The directors are responsible for the other information. The other information comprises the
• ‘Chairman’s Statement’;
• ‘President & Chief Executive Officer’s Statement’;
• ‘Directors’ Report’;
• ‘Corporate Governance Statement'; and
• 'Remuneration Statement and Report of the Remuneration Committee to the Shareholders’,
but does not include the financial statements and our auditors’ report thereon.
Our opinion on the financial statements does not cover the other information and, other than in the
case of the directors’ report on which we report separately below in our ‘Opinion on the Directors’
Report’, we do not express any form of assurance conclusion thereon.
In connection with our audit of the financial statements, our responsibility is to read the other
information, and, in doing so, consider whether the other information is materially inconsistent with the
financial statements or our knowledge obtained in the audit, or otherwise appears to be materially
misstated. If, based on the work we have performed, we conclude that there is a material
misstatement of this other information, we are required to report that fact. We have nothing to report
in this regard.
Responsibilities of the directors for the financial statements
The directors are responsible for the preparation of financial statements that (a) give a true and fair
view in accordance with IFRS as adopted by the EU, and (b) are properly prepared in accordance
with the provisions of the Act and the Insurance Business Act and additionally, specifically in relation
to those of the Group, with the requirements of Article 4 of the Regulation. The directors are also
responsible for such internal control as they determine is necessary to enable the preparation of
financial statements that are free from material misstatement, whether due to fraud or error.
In preparing the financial statements, the directors are responsible for assessing the Company’s and
the Group’s ability to continue as a going concern, disclosing, as applicable, matters related to going
concern and using the going concern basis of accounting unless the directors either intend to liquidate
the Company and/or the Group or to cease operations, or have no realistic alternative but to do so.
The directors are also responsible for overseeing the financial reporting process.
KPMG, a Maltese civil partnershipand a member firm of the KPMG global The firm is registered as a A list of partners and directors of
organisation of independent member firms affiliated with KPMGpartnership of Certified Publicthe firm is available at Portico
International Limited, a private English company limited guarantee.Accountants in terms of theBuilding, Marina Street, Pietà,
Accountancy Profession ActPTA9044, Malta.
KPMG
92, Marina Street
Pietà, PTA 9044
Malta
Telephone(+356) 2563 1000
Fax (+356) 2566 1000
Websitewww.kpmg.com.mt
Independent Auditors’ Report (continued)
To the Shareholders of MAPFRE Middlesea p.l.c
Auditors’ responsibilities for the audit of the financial statements
Our objectives are to obtain reasonable assurance about whether the financial statements as a whole
are free from material misstatement, whether due to fraud or error, and to issue an auditors’ report
that includes our opinion. ‘Reasonable assurance’ is a high level of assurance, but is not a guarantee
that an audit conducted in accordance with ISAs will always detect a material misstatement when it
exists.  Misstatements can arise from fraud or error and are considered material if, individually or in
the aggregate, they could reasonably be expected to influence the economic decisions of users taken
on the basis of these financial statements.
As part of an audit in accordance with ISAs, we exercise professional judgement and maintain
professional scepticism throughout the audit. 
We also:
• Identify and assess the risks of material misstatement of the financial statements, whether
due to fraud or error, design and perform audit procedures responsive to those risks, and
obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion.  The
risk of not detecting a material misstatement resulting from fraud is higher than for one
resulting from error, as fraud may involve collusion, forgery, intentional omissions,
misrepresentations, or the override of internal control.
• Consider the extent of compliance with those laws and regulations that directly affect the
financial statements, as part of our procedures on the related financial statement items. For
the remaining laws and regulations, we make enquiries of directors and other management,
and inspect correspondence with the regulatory authority, as well as legal correspondence.
As with fraud, there remains a higher risk of non-detection of other irregularities (whether or
not these relate to an area of law directly related to the financial statements), as these may
likewise involve collusion, forgery, intentional omissions, misrepresentations, or the override
of internal controls.
• Obtain an understanding of internal control relevant to the audit in order to design audit
procedures that are appropriate in the circumstances, but not for the purpose of expressing
an opinion on the effectiveness of the Company’s and the Group’s internal control. 
• Evaluate the appropriateness of accounting policies used and the reasonableness of
accounting estimates and related disclosures made by the directors.
KPMG, a Maltese civil partnershipand a member firm of the KPMG global The firm is registered as a A list of partners and directors of
organisation of independent member firms affiliated with KPMGpartnership of Certified Publicthe firm is available at Portico
International Limited, a private English company limited guarantee.Accountants in terms of theBuilding, Marina Street, Pietà,
Accountancy Profession ActPTA9044, Malta.
KPMG
92 Marina Street
Pietà, PTA 9044
Malta
Telephone(+356) 2563 1000
Fax (+356) 2566 1000
Websitewww.kpmg.com.mt
Independent Auditors’ Report (continued)
To the Shareholders of MAPFRE Middlesea p.l.c
Auditors’ responsibilities for the audit of the financial statements (continued)
• Conclude on the appropriateness of the directors’ use of the going concern basis of
accounting and, based on the audit evidence obtained, whether a material uncertainty exists
related to events or conditions that may cast significant doubt on the Company's and the
Group’s ability to continue as a going concern.  If we conclude that a material uncertainty
exists, we are required to draw attention in our auditors’ report to the related disclosures in
the financial statements or, if such disclosures are inadequate, to modify our opinion.  Our
conclusions are based on the audit evidence obtained up to the date of our auditors’ report. 
However, future events or conditions may cause the Company and/or the Group to cease to
continue as a going concern.
• Evaluate the overall presentation, structure and content of the financial statements, including
the disclosures, and whether the financial statements represent the underlying transactions
and events in a manner that achieves fair presentation.
• Obtain sufficient appropriate audit evidence regarding the financial information of the entities
or business activities within the Group to express an opinion on the financial statements of
the Group.  We are responsible for the direction, supervision and performance of the Group
audit.  We remain solely responsible for our audit opinion.
We communicate with those charged with governance regarding, among other matters, the planned
scope and timing of the audit and significant audit findings, including any significant deficiencies in
internal control that we identify during our audit.
We also provide those charged with governance with a statement that we have complied with relevant
ethical requirements regarding independence, and communicate with them all relationships and other
matters that may reasonably be thought to bear on our independence, and where applicable, actions
taken to eliminate threats or safeguards applied.
From the matters communicated with those charged with governance, we determine those matters
that were of most significance in the audit of the financial statements of the current period and are
therefore the key audit matters. We describe these matters in our auditors' report unless law or
regulation precludes public disclosure about the matter or when, in extremely rare circumstances, we
determine that a matter should not be communicated in our report because the adverse
consequences of doing so would reasonably be expected to outweigh the public interest benefits of
such communication.
KPMG, a Maltese civil partnershipand a member firm of the KPMG global The firm is registered as a A list of partners and directors of
organisation of independent member firms affiliated with KPMGpartnership of Certified Publicthe firm is available at Portico
International Limited, a private English company limited guarantee.Accountants in terms of theBuilding, Marina Street, Pietà,
Accountancy Profession ActPTA9044, Malta.
KPMG
92, Marina Street
Pietà, PTA 9044
Malta
Telephone(+356) 2563 1000
Fax (+356) 2566 1000
Websitewww.kpmg.com.mt
Independent Auditors’ Report (continued)
To the Shareholders of MAPFRE Middlesea p.l.c
2    Opinion on the Directors’ Report
The directors are responsible for preparing a directors’ report in accordance with the provisions of
article 177 of the Act and other applicable legal requirements, and are to include a statement that the
Company is a going concern with supporting assumptions or qualifications as necessary, as required
by Rule 5.62 of the Capital Markets Rules issued by the Malta Financial Services Authority (the
“Capital Market Rules”).
We are required to consider whether the information given in the directors’ report for the accounting
period for which the financial statements are prepared is consistent with those financial statements;
and, if we are of the opinion that it is not, we shall state that fact in our report.  We have nothing to
report in this regard.
Pursuant to article 179(3) of the Act, we are also required to:
• express an opinion on whether the directors’ report has been prepared in accordance with the
applicable legal requirements;
• state whether, in the light of the knowledge and understanding of the entity and its
environment obtained in the course of our audit of the financial statements, we have identified
material misstatements in the directors’ report, giving an indication of the nature of any such
misstatements.
Pursuant to Rule 5.62 of the Capital Markets Rules, we are required to review the directors’ statement
in relation to going concern.
In such regards:
• in our opinion, the Directors’ Report has been prepared in accordance with the applicable
legal requirements;
• we have not identified material misstatements in the Directors’ Report; and
• we have nothing to report in relation to the statement on going concern.
KPMG, a Maltese civil partnershipand a member firm of the KPMG global The firm is registered as a A list of partners and directors of
organisation of independent member firms affiliated with KPMGpartnership of Certified Publicthe firm is available at Portico
International Limited, a private English company limited guarantee.Accountants in terms of theBuilding, Marina Street, Pietà,
Accountancy Profession ActPTA9044, Malta.
KPMG
92,Marina Street
Pietà, PTA 9044
Malta
Telephone(+356) 2563 1000
Fax (+356) 2566 1000
Websitewww.kpmg.com.mt
Independent Auditors’ Report (continued)
To the Shareholders of MAPFRE Middlesea p.l.c
3    Report on Other Legal and Regulatory Requirements
Matters on which we are required to report by the Act, specific to public-interest entities
Pursuant to article 179B(1) of the Act, we report as under matters not already reported upon in our
‘Report on the Audit of the Financial Statements’:
• we were first appointed as auditors by the shareholders on 15 July 2015, and subsequently
reappointed at the Company’s general meetings for each financial year thereafter. The period
of total uninterrupted engagement is ten years;
• our opinion on our audit of the financial statements is consistent with the additional report to
the audit committee required to be issued by the Audit Regulation (as referred to in the Act);
and
• we have not provided any of the prohibited services as set out in the APA.
Matters on which we are required to report by exception by the Act
Pursuant to articles 179(10) and 179(11) of the Act, we have nothing to report to you with respect to
the following matters:
• proper accounting records have not been kept; or
• the financial statements are not in agreement with the accounting records; or
• we have not obtained all the information and explanations which, to the best of our knowledge
and belief, we require for the purpose of our audit.
KPMG, a Maltese civil partnershipand a member firm of the KPMG global The firm is registered as a A list of partners and directors of
organisation of independent member firms affiliated with KPMGpartnership of Certified Publicthe firm is available at Portico
International Limited, a private English company limited guarantee.Accountants in terms of theBuilding, Marina Street, Pietà,
Accountancy Profession ActPTA9044, Malta.
KPMG
92, Marina Street
Pietà, PTA 9044
Malta
Telephone(+356) 2563 1000
Fax (+356) 2566 1000
Websitewww.kpmg.com.mt
Independent Auditors’ Report (continued)
To the Shareholders of MAPFRE Middlesea p.l.c
Report on compliance of the Annual Report with the requirements of the Commission
Delegated Regulation (EU) 2018/815 supplementing Directive 2004/109/EC (the “European
Single Electronic Format Regulatory Technical Standard” or “ESEF Regulation”), by reference
to Capital Markets Rule 5.55.6 issued by the Malta Financial Services Authority
We have undertaken a reasonable assurance engagement in accordance with the requirements of
Directive 6 issued by the Accountancy Board in terms of the Accountancy Profession Act, 1979
(Chapter 281, Laws of Malta), the Accountancy Profession (European Single Electronic Format)
Assurance Directive, on the Annual Report for the year ended 31 December 2024, prepared in a
single electronic reporting format.
Responsibilities of the directors for compliance with the requirements of the ESEF Regulation
As required by Capital Markets Rule 5.56A, the directors are responsible for the preparation of the
Annual Report in XHTML format, including the relevant mark-ups, in accordance with the
requirements of the ESEF Regulation.
In addition, the directors are responsible for such internal control as they determine is necessary to
enable the preparation of the Annual Report that is in compliance with the requirements of the ESEF
Regulation.
Auditors’ responsibilities to report on compliance with the requirements of the ESEF Regulation
Our responsibility is to obtain reasonable assurance about whether the Annual Report in XHTML
format, including the relevant mark-ups, comply in all material respects with the ESEF Regulation
based on the evidence we have obtained. As part of our work, we obtain an understanding of the
Company’s controls relevant to the preparation of the Annual Report in compliance with the said
requirements, but not for the purpose of expressing an opinion on the effectiveness of the controls in
place.
KPMG, a Maltese civil partnershipand a member firm of the KPMG global The firm is registered as a A list of partners and directors of
organisation of independent member firms affiliated with KPMGpartnership of Certified Publicthe firm is available at Portico
International Limited, a private English company limited guarantee.Accountants in terms of theBuilding, Marina Street, Pietà,
Accountancy Profession ActPTA9044, Malta.
KPMG
92, Marina Street
Pietà, PTA 9044
Malta
Telephone(+356) 2563 1000
Fax (+356) 2566 1000
Websitewww.kpmg.com.mt
Independent Auditors’ Report (continued)
To the Shareholders of MAPFRE Middlesea p.l.c
Report on compliance of the Annual Report with the requirements of the Commission
Delegated Regulation (EU) 2018/815 supplementing Directive 2004/109/EC (the “European
Single Electronic Format Regulatory Technical Standard” or “ESEF Regulation”), by reference
to Capital Markets Rule 5.55.6 issued by the Malta Financial Services Authority (continued)
Auditors’ responsibilities to report on compliance with the requirements of the ESEF Regulation
(continued)
In discharging that responsibility, we:
• obtain an understanding of the entity's financial reporting process, including the preparation of
the Annual Report, in accordance with the requirements of the ESEF Regulation;
• perform validations to determine whether the Annual Report has been prepared in
accordance with the requirements of the technical specifications of the ESEF Regulation; and
• examine the information in the Annual Report to determine whether all the required mark-ups
therein have been applied and whether, in all material respects, they are in accordance with
the requirements of the ESEF Regulation.
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our
conclusion.
Conclusion
In our opinion, the Annual Report for the year ended 31 December 2024 has been prepared, in all
material respects, in accordance with the requirements of the ESEF Regulation, by reference to
Capital Markets Rule 5.55.6.
The Principal authorised to sign on behalf of KPMG on the audit resulting in this independent auditors’
report is Thane Micallef.
KPMG                                                                                                25 March 2025
Registered Auditors
KPMG, a Maltese civil partnershipand a member firm of the KPMG global The firm is registered as a A list of partners and directors of
organisation of independent member firms affiliated with KPMGpartnership of Certified Publicthe firm is available at Portico
International Limited, a private English company limited guarantee.Accountants in terms of theBuilding, Marina Street, Pietà,
Accountancy Profession ActPTA9044, Malta.
KPMG
92, Marina Street
Pietà, PTA 9044
Malta
Telephone(+356) 2563 1000
Fax (+356) 2566 1000
Websitewww.kpmg.com.mt
Independent Assurance Report
To the Shareholders of MAPFRE Middlesea p.l.c.
Report required by Capital Markets Rules 5.98 and 12.26N issued by the Malta Financial
Services Authority (the “MFSA”)
We were engaged by the Directors of MAPFRE Middlesea p.l.c.(the “Company”) to report on the
disclosures of specific elements in the Corporate Governance Statement and the Remuneration
Report (the “Disclosures”) as at 31 December 2024,  in the form of an independent reasonable
assurance conclusion, as to whether they are, in all material respects, in compliance with the
corporate governance regulations and information to be provided in the Remuneration Report set out
in the Capital Markets Rules issued by the MFSA (the “Capital Market Rules”). More specifically, we
are required to report on the Disclosures in the form of an independent reasonable assurance
conclusion about whether:
(a) in light of our knowledge and understanding of the Company and its environment obtained in
the course of the statutory audit, we have identified material misstatements with respect to
the information referred to in Capital Markets Rules 5.97.4 (dealing with the Company’s
internal control and risk management systems in relation to the financial reporting process)
and 5.97.5 (where a takeover bid applies). Where material misstatements are identified in
relation to those requirements, we shall, in addition to our conclusion, provide an indication of
the nature of such misstatements;
(b) the Disclosures include the other information required by Capital Markets Rule 5.97, insofar
as it is applicable to the Company; and
(c)the Disclosures include the information required by Appendix 12.1, ‘Information to be provided
in the Remuneration Report’, to Chapter 12 of the Capital Markets Rules (as applicable).
Responsibilities of the Directors
The Directors are responsible for preparing and presenting the Disclosures that are free from material
misstatement in accordance with the requirements of the Capital Market Rules and for the information
contained therein.
This responsibility includes designing, implementing and maintaining internal control as they
determine is necessary to enable the preparation and presentation of the Disclosures that are free
from misstatement, whether due to fraud or error.
The Directors are also responsible for preventing and detecting fraud and for identifying and ensuring
that the Company complies with laws and regulations applicable to its activities. The Directors are
responsible for ensuring that personnel involved in the preparation and presentation of the
Disclosures are properly trained, systems are properly updated and that any changes in reporting
relevant to the Disclosures encompass all significant business units.
KPMG, a Maltese civil partnershipand a member firm of the KPMG global The firm is registered as a A list of partners and directors of
organisation of independent member firms affiliated with KPMGpartnership of Certified Publicthe firm is available at Portico
International Limited, a private English company limited guarantee.Accountants in terms of theBuilding, Marina Street, Pietà,
Accountancy Profession ActPTA9044, Malta.
KPMG
92, Marina Street
Pietà, PTA 9044
Malta
Telephone(+356) 2563 1000
Fax (+356) 2566 1000
Websitewww.kpmg.com.mt
Independent Assurance Report (continued)
To the Shareholders of MAPFRE Middlesea p.l.c.
Our Responsibilities
Our responsibility is to examine the Disclosures prepared by the Company and to report thereon in
the form of an independent reasonable assurance conclusion based on the evidence obtained. We
conducted our engagement in accordance with International Standard on Assurance Engagements
3000 (Revised), Assurance Engagements Other Than Audits or Reviews of Historical Financial
Information (“ISAE 3000”) issued by the International Auditing and Assurance Standards Board. That
standard requires that we plan and perform our procedures to obtain reasonable assurance about
whether the Disclosures are properly prepared and presented, in all material respects, in accordance
with the requirements set out in the relevant Capital Markets Rules.
The firm applies International Standard on Quality Management 1, which requires the firm to design,
implement and operate a system of quality management including policies or procedures regarding
compliance with ethical requirements, professional standards and applicable legal and regulatory
requirements.
We have complied with the independence and other ethical requirements of the International Ethics
Standards Board for Accountants’ International Code of Ethics for Professional Accountants (including
International Independence Standards) (IESBA Code), together with the ethical requirements that are
relevant to our assurance engagement in accordance with the Accountancy Profession (Code of
Ethics for Warrant Holders) Directive issued in terms of the Accountancy Profession Act (Chapter 281,
Laws of Malta), and we have fulfilled our other ethical responsibilities in accordance with these
requirements and the IESBA Code. The IESBA Code is founded on fundamental principles of integrity,
objectivity, professional competence and due care, confidentiality and professional behavior.
The procedures selected and our determination of the nature, timing and extent of those procedures,
will depend on our judgment, including the assessment of the risks of material misstatement of the
preparation and presentation of the Disclosures whether due to fraud or error.
In making those risk assessments, we have considered internal control relevant to the preparation
and presentation of the Disclosures in order to design assurance procedures that are appropriate in
the circumstances, but not for the purposes of expressing a conclusion as to the effectiveness of the
Company’s internal control over the preparation and presentation of the Disclosures. Reasonable
assurance is less than absolute assurance.
KPMG, a Maltese civil partnershipand a member firm of the KPMG global The firm is registered as a A list of partners and directors of
organisation of independent member firms affiliated with KPMGpartnership of Certified Publicthe firm is available at Portico
International Limited, a private English company limited guarantee.Accountants in terms of theBuilding, Marina Street, Pietà,
Accountancy Profession ActPTA9044, Malta.
KPMG
92, Marina Street
Pietà, PTA 9044
Malta
Telephone(+356) 2563 1000
Fax (+356) 2566 1000
Websitewww.kpmg.com.mt
Independent Assurance Report (continued)
To the Shareholders of MAPFRE Middlesea p.l.c.
Our Responsibilities (continued)
We are not required to, and we do not, consider whether the Directors’ statements on internal control
and risk management systems cover all the risks and controls in relation to the financial reporting
process or form an opinion on the effectiveness of the Company’s corporate governance procedures
or its risks and control procedures, nor on the ability of the Company to continue in operational
existence. Our opinion in relation to the disclosures pursuant to Capital Markets Rules 5.97.4 and
5.97.5 (as appropriate) is based solely on our knowledge and understanding of the Company and its
environment obtained in forming our opinion on the audit of the financial statements.
As part of this engagement, we have not performed any procedures by way of audit, review or
verification of the Disclosures nor of the underlying records or other sources from which the
Disclosures were extracted.
Other Information
We also read the other information included in the Annual Report that contains the Disclosures, and
our report thereon, in order to identify material inconsistencies, if any, with the Disclosures. We have
nothing to report in this regard.
Conclusion
Our conclusion has been formed on the basis of, and is subject to, the matters outlined in this report.
We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our
conclusion.
KPMG, a Maltese civil partnershipand a member firm of the KPMG global The firm is registered as a A list of partners and directors of
organisation of independent member firms affiliated with KPMGpartnership of Certified Publicthe firm is available at Portico
International Limited, a private English company limited guarantee.Accountants in terms of theBuilding, Marina Street, Pietà,
Accountancy Profession ActPTA9044, Malta.
KPMG
92, Marina Street
Pietà, PTA 9044
Malta
Telephone(+356) 2563 1000
Fax (+356) 2566 1000
Websitewww.kpmg.com.mt
Independent Assurance Report (continued)
To the Shareholders of MAPFRE Middlesea p.l.c.
Conclusion (continued)
In our opinion:
(a) in light of our knowledge and understanding of the Company and its environment obtained in
the course of the statutory audit, we have not identified material misstatements with respect
to the information requirements referred to in Capital Markets Rules 5.97.4 and 5.97.5;
(b)the Disclosures include the other information required by Capital Markets Rule 5.97; and,
(c)  the Disclosures include the information required by Appendix 12.1 to Chapter 12 of the Capital
Markets Rules.
The Principal authorised to sign on behalf of KPMG on the work resulting in this assurance report is
Thane Micallef.
KPMG                                                                                25 March 2025
Registered Auditors