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MAPFRE MIDDLESEA p.l.c.
Annual Report
31 December 2021
Company Registration Number: C 5553
Contents
Page
Page
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
Chairman’s Statement
2021 saw the pandemic continue throughout the world and its impact on businesses was
profound, mitigated to some extent by Government intervention but hitting some industries
harder than others. Quantitative easing, in the more developed economies softened the harsher
impact of this phenomena, the like of which has had no precedent in the modern world.
However, Governments, companies and indeed the world population at large has had to adapt
and live with the effects of the global pandemic – and what is perhaps surprising is the speed and
relative efficiency with which all have changed in order to combat, and to some extent live with
its restrictions and limitations. As I write we are looking to the future with some optimism that
the worst may be over, and that we may again be able to return to normality after more than two
years.
The insurance industry has been no exception to this upheaval and has been greatly affected by
the pandemic. Whilst the effects of the almost total shutdown in 2020 had kept claims low in
non-life insurance, especially motor, as restrictions were relaxed, claims increased to their
normal levels, with motor still marginally below the pre-COVID level. Our results in MAPFRE
Middlesea p.l.c. (“MAPFRE Middlesea”, “MMS” or “Company”) were therefore affected and
our profit decreased from record levels in 2020 where profit before tax was €6.4 million, to a
more average result of €4.1 million. With the life company, MAPFRE MSV Life p.l.c.
(“MAPFRE MSV Life”), the effect was more complex. The volatility of the markets greatly
affected that company’s solvency, mainly brought about by the company’s best-selling
investment product, which generally gives stable returns but where the capital of the investor is
guaranteed by the company. In this case the fluctuations in share prices coupled with the very
low returns on fixed interest bonds meant that the company needed to bolster its capital buffer
which had necessitated an injection of capital of some €40m by the company’s shareholders –
MAPFRE Middlesea and Bank of Valletta p.l.c. in early 2021. Whilst the company continued to
register increasing profits, it was deemed prudent not to issue dividends to those shareholders last
year, but to retain those profits to ensure a comfortable solvency ratio.
As MAPFRE MSV Life did not issue dividends in 2020, and 2021, MAPFRE Middlesea could
only pay dividends out of its own earnings. I must inform you therefore that for the second year
the dividend pay-out is at a reduced level.
Results 
MAPFRE Middlesea returned a profit of €4.1 million. Whilst premiums continued to increase,
the Company was hit by high claims especially in motor, which impacted the profitability of the
Company. Net non-life claims increased from €29.8 million in 2020 to €34.9 million in 2021 an
increase of 16.9% whilst net earned premiums increased to  €60.7 million or an increase of 5.7%.
The result was that profit fell to €4.1 million from €6.4 million.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
i
Chairman’s Statement - continued
With the Company’s principal subsidiary, MAPFRE MSV Life, premium income continued to
increase to record levels with premium turnover reaching €325.1 million, up from €269.6
million, an increase of 20.6%. The main driver for this was the sale of the company’s Single
Premium investment product which continues to remain popular, having a track record of
delivering good returns whilst setting the investors mind at ease that the capital is guaranteed.
MAPFRE MSV Life’s profit before tax increased from €15.0 million to €16.7 million. However,
as noted above, in spite of the increased profit, the directors have adopted a prudent approach. In
2020 the dividend was cancelled, whilst in 2021 no dividend was declared. As stated, this means
that there were no distributable dividends released to MAPFRE Middlesea which means that
there was no onward transmission of dividends to you the ultimate shareholders.
Dividends
MAPFRE Middlesea is declaring a net dividend in respect of the profit earned in 2021 of €2.4
million which translates into a net dividend per share of €0.026087. This compares to the
dividend declared last year of €3.2 million.
I should also inform you that the Directors of MAPFRE MSV Life are determined to resume
dividend payments albeit prudently in the near future. It is difficult for me to predict with any
certainty when this will occur or indeed the rate of pay-out as this is subject to the prevailing
economic situation which on a global level remains highly uncertain, but is likely to be prudent
and having due regard to the solvency of the company.
Solvency
2020 saw the solvency ratio of MAPFRE MSV Life fall to 101% in March. This was brought
about by the onset of the pandemic which brought havoc on the world markets. The company
took immediate remedial action, repositioning its investments to a more defensive position and
cancelling the declared dividend declared for that year. The capital injection of €40m by its
shareholders MAPFRE Middlesea and Bank of Valletta further bolstered its solvency which is
now in what we term, the green zone, and well in excess of 200% (provisional). The Group
continues to monitor the solvency of the group, but more specifically that of MAPFRE MSV life,
very closely in view of the continued volatility in the markets but the Board remains confident
that the steps taken, ensure the Group’s resilience in the face of this.
Operational developments
In spite of the pandemic, MAPFRE Middlesea and MAPFRE MSV Life, continued to transform
their respective businesses to meet the exigencies of the future. Both companies are in the middle
of transforming their IT systems and processes and significant improvements have been
registered in the past year. We view this as key to the development of both companies and indeed
we hope to reap great efficiencies in the near future as a result of this.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
ii
Chairman’s Statement - continued
Both companies are developing new products and especially in the case of MAPFRE MSV Life,
which should have significant long term benefits. This includes the new pension schemes which
are being rolled out and which will help provide additional income to those taking up pension
plans on retirement. For the company this will constitute a new diversified source of income.
Challenges
The economic situation remains unstable. As the effects of the pandemic recede, new
geopolitical risks, specifically in the Ukraine, have taken centre stage, whilst the potential effects
of the withdrawal of quantitative easing have yet to be seen. All this makes for the roller-coaster
effect on the markets likely to continue.
In Malta the short term effects of grey listing seem to have been weathered, however the longer
term impact of this in attracting new business has yet to be seen. Further, the global minimum tax
rate set at 15% which is due to be implemented will impact our financial services.
We look to the Government to seek out new sustainable industries whilst ensuring that public
finances are carefully expended and invested wisely in the best way possible and rendering value
for money. The Government needs to work hard to restore the country’s reputation and remove
its name from the Grey List and do its utmost to ensure that Malta is a place to do business, with
a highly skilled flexible workforce, where the rule of law is applicable to everyone without fear
or favour.
On the environment side, we have seen that climate change is a reality. As insurers we are often
at the sharp end of its effects with ever increasing pay-outs due to storms, drought, floods, and
crop failures. We will continue to pay for our inaction, and can only urge our own and other
governments to work towards resolving this existential problem.
Caution remains the watchword when looking forward but this does not mean we need be
pessimistic. We have the means to resolve these issues but require the will.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
iii
Chairman’s Statement - continued
Regulation
The MFSA, as regulator, has become increasingly active and placed onerous demands on
companies operating in the financial services sector. This is not only a national issue as
regulators the world over are becoming increasingly intrusive. Combating financial crime,
implementing complex reporting, solvency and accounting standards have meant that we have
continued to invest heavily in skills and technology to ensure that we fulfil our obligations in this
regard. I must say that in five short years the landscape has entirely changed and the group has
built up a team of highly skilled professional personnel in finance, compliance, risk management,
actuarial and anti-financial crime departments. The cost of compliance is indeed high but is an
investment necessary to do business in the modern landscape.
2023 will see the introduction of IFRS 17, an accounting standard which will revolutionise the
way we account for and report our results. This will be seen in the 2023 statutory accounts but of
course the 2022 figures, as comparatives need to be computed including a restatement of the
opening position for that year.. We are well prepared to achieve this milestone and in this I must
acknowledge the great assistance we are receiving from MAPFRE S.A..
Our employees
2021 saw a reduction in the number of employees working from home. As the pandemic receded,
many preferred to work from the office which of course has its advantages. However, in this the
world has changed and the company has become, where possible, more flexible, more family
friendly than in the past. As always, our primary aim is the health and safety of our employees.
In 2022 we are looking to increase our staff training, which had proved difficult during the
pandemic and on which we place much importance.
Employment has grown in line with turnover and the increasing regulatory requirements. We
now employ some 295 staff in the Group. Together with the Board I should like to thank them
for their sterling efforts, especially during the pandemic, but also due to the additional demands
brought about by the IT transformation and the increased regulatory structures.
Distribution
MAPFRE Middlesea distributes business with a multi-channel approach which means that  many
of the policies sold are generated through a network of Agents, Brokers and Tied Insurance
Intermediaries. Over 35% of our income comes from 6 agents, whilst 22% comes from our own
Tied Insurance Intermediaries of which we have around 60. Clearly therefore they remain critical
to the success of the Company. We maintain close links with all of our distributors who have
also felt the brunt of increased regulation whilst maintaining their businesses and selling our
products to the market. We remain grateful for the hard work they put in and reiterate our
committment to them to continue to improve our service as well as ensuring that our product
offering remains competitive and innovative.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
iv
Chairman’s Statement - continued
Corporate Social Responsibility
During 2021, despite the challenging times caused by the pandemic, MAPFRE Malta
endeavoured, as part of the MAPFRE Group, in its committment in environmental, social and
governance (ESG) matters by once  again meeting our CSR objectives collaborating with a
number of different entities to organize various activities ranging from food and blood donations,
environmental activities and clean-ups.
Fundación MAPFRE allocated over €100k for projects in Malta across different areas (road
safety, health and social actions). The Foundation has once again funded the provision of
specialized services to children and adults with disabilities to enable them to lead a more
independent life.
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.
Shareholders
MAPFRE Middlesea p.l.c. is a listed entity regulated by the Malta Financial Services Authority.
It is a subsidiary of MAPFRE Internacional. Being part of one of the largest insurance companies
in the world allows us to access technical know-how which is at the cutting edge of the industry.
In 2021 MAPFRE Internacional increased its shareholding from 54.56% to 55.83% through the
purchase of 1,168,140 ordinary shares.
Bank of Valletta p.l.c. is the other major corporate 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 but is the main
generator of turnover in MMSV. The commercial relationship between the Bank and the
company remains very strong which is critical to the evolution of the company.
13.09% of the shareholding in MAPFRE Middlesea is held by the so-called smaller shareholders,
of which we have some 3,750.
I have the privilege to work with a board which is professional in its dealings and technically
competent. Joseph F.X. Zahra, Jose Ramon Alegre, Jose Luis Jimenez and Jose Maria del Pozo
were appointed by Mapfre whilst Taddeo Scerri and John Cassar White were appointed by Bank
of Valletta. The smaller shareholders elected Antoinette Caruana and Paul Testaferrata Moroni
Viani. I am grateful to them for their focused insight in helping to resolve the many issues which
arose during the year and in providing direction and perspective to management.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
v
Chairman’s Statement - continued
I already reported last year that Javier Moreno was appointed the President and CEO of
MAPFRE Middlesea. It was an eventful year which he handled intelligently and skillfully at full
tilt. He took over in early 2021 a year which proved what I might say eventful.
2021 also saw the retirement of David Curmi who was CEO of MAPFRE MSV Life for 19
years. The company, with the assistance of MAPFRE SA made an international call to find a
replacement and I am pleased to say that after a rigorous selection process Etienne Sciberras was
appointed in his stead. He was formerly the Group Risk Chief Officer and has moved into his
new role as CEO seamlessly. I am grateful for the work, professionalism and dedication of the
two new CEOs and their immense contribution to the Group. They are ably supported in this by
the whole team of chief officers and staff who have ensured the Group’s continued progress in
these unprecedented times.
Signed by Martin Galea (Chairman) on the 23 March 2022
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
vi
President & Chief Executive Officer’s Statement
MAPFRE Middlesea Group highlights
Once again, 2021 has been a complex year in our lives. The continuing pandemic has brought
about  restrictions in mobility and has affected the country’s normal social and economic
development. We started the year with wave 4 and closed it with wave 5 of this pandemic.
Our objective as MAPFRE Malta Group (“Group”) has been twofold: to preserve the health and
safety of our employees, clients, intermediaries and other stakeholders, and to maintain at all
times the high level of service to our policyholders and distributors. I must say that we have
shown complete flexibility in adapting our service format to the changing circumstances. This
has been thanks to our technological capacity to work virtually and above all, to the total
commitment of each and every employee in our organisation.
Though uncertainty is not conducive to business development, our financial performance has
been very good thanks to the remarkable effort made by all our teams, by our intermediaries and
strategic partners.
Premiums written amounted to €405.2 million, with significant growth in both Long term
business and non-life. The increase compared to 2020 is remarkable at 17.6%, mainly due to our
strong distribution capacity and more favourable economic conditions.
In addition to the growth in the managed business, our profit before tax reached €20.4 million,
slightly below the exceptional result of 2020 where we were able to obtain a higher technical
result than usual. In any case, we are very pleased to have even exceeded the targets we set
ourselves.
Long term business once again experienced high volatility, but unlike the previous year, the
highest tensions in the international financial markets occurred in the last quarter. Fortunately,
our successful diversification strategy and our active management of the portfolio, has led to
good investment results at the end of the year. In addition, we have a solvency position
reinforced by the increase in capital and by appropriate management, which has enabled us to
continue growing the savings business. The growth in premiums was magnificent, as was the
result, exceeding in both cases the 2020 figures. These are discussed in more detail later in this
report.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
vii
President & Chief Executive Officer’s Statement- continued
MAPFRE Middlesea Group highlights - continued
Non-Life business has returned to growth in almost all our lines, despite the abnormal situation,
with the low tourist activity and reduced international mobility, still affecting automobile and
travel. The technical performance, with a Net Combined Ratio (“COR”) of 91.8%, was good
overall, though not reaching the excellent and atypical 86.1% of 2020 that was due to the drop in
claims associated with the lack of mobility caused by the pandemic. This performance was not
evenly spread in all sectors, with a better performance in personal and commercial lines
compared to motor and health. However, our risk model, where diversification is key, has
enabled us to once again perform well.
Premium written for MAPFRE Middlesea p.l.c. (“MAPFRE Middlesea”,“MMS” or “Company”)
including group life reached the €80.0 million mark for the first time at €80.1 million and profit
before tax  closed at €4.1million, lower than the excellent atypical result in 2020 but above the
targets set for the year.
On balance, this year has been clearly positive despite the persistent effects of the pandemic. As
a Group we have managed to grow in almost all businesses and maintain a good level of
profitability, rising to the challenge set by Company's strategy of transforming ourselves to grow
profitably.
The experience gained in 2020 enabled us to face 2021 with renewed capabilities. The great
assets of our Company have once again proved to be the key to our clients' trust and we continue
to maintain and reinforce a leading position in the insurance industry in Malta.
We again reassert our commitment to strong, sustainable development and value creation for our
shareholders.
Finally, it is important to note that the planned transition of the Chief Executive Officer positions
in MAPFRE Middlesea and MAPFRE MSV Life p.l.c. (“MMSV”) have been carried out
successfully.
General Business
Premiums in 2021 reached €77.6 million, representing a growth of 6.9% over 2020. Since the
beginning of the year, we have made a constant effort to recover the growth that we have
enjoyed in recent years and that was brought to an abrupt halt in 2020 by the shock of the
pandemic. Preliminary figures show that we have managed to grow our local non-life risk
business in line with the rest of the market, and marginally strengthening our leading position to
33.23%.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
viii
President & Chief Executive Officer’s Statement - continued
General Business - continued
We have achieved clear and balanced growth across all business lines except travel and marine
cargo, which are still impacted by the effects of COVID19. Of note was the return to growth in
motor, with increases of 3.3%, the magnificent result in health, and the consistency of the rest of
the personal and commercial lines.
With 109,031 customers and 213,439 policies, we have achieved increases of 1.26% and 4.69% 
respectively over 2020. This good news confirms that more and more clients are placing their
trust in MAPFRE.
Commercial activity has been intense and more than 54,000 new policies have been issued, a
significant figure that has been possible thanks to our large distribution network and the
attractive value proposition that the Company offers to its clients.
Our retention ratio is 81.2%, a very good figure in general terms but one that needs to be
optimized in the coming years. Our ambition and business culture must drive us to consistently
keep our customers satisfied, loyal and open to placing greater trust in us with more insurance
products.
Regarding our product offering, MMS has continued to innovate and develop new insurance
solutions, with important launches such as the Electric Vehicle (EV) policy, a pioneer in our
market, simplified more adaptable offerings for SMEs, and the COVID coverage in our travel
policies. Without a doubt, MMS has the widest coverage of insurance solutions that allow our
intermediaries to always meet the needs of each family, company or organisation.
Regarding our distribution, our partners, brokers, agents and TIIs have demonstrated once again
this year 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 have developed a formidable year, showing that this model generates profitable and
sustainable growth. They have increased by 6.8%, a remarkable figure, and a significant
contribution to the diversification that is always part of our strategy.
MMS has always maintained an excellent professional relationship with brokers and this year has
been no exception as the strong figures show.
Our direct business, consisting of our regional offices and TIIs, has also performed very
positively. As a Company, we want to continue to promote this channel further as we still see
more potential to be opened up. MMS continues to develop this channel and during 2021 has
struck three additional agreements with three established partners which will surely contribute in
delivering higher sales figures in the coming years.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
ix
President & Chief Executive Officer’s Statement - continued
General Business - continued
Motor business evolution this year was complicated by two factors: a higher frequency of serious
claims, concentrated mainly in Q4, and an upturn in the average cost of claims associated with
the higher cost of vehicle repairs. The net COR reached 100.3%, and Management has already
taken steps to improve in 2022, and will continue to monitor closely its development. Health
business performed very well with net COR holding at a very positive 75.9%, higher than 2020
but still more than adequate. The rest of the business lines had a net COR of 83.4%, which is
very satisfactory and allowed us to maintain the good overall technical result.With Motor already
below 50% of the non-life portfolio, the diversification of businesses ensures greater stability in
our technical performance.
Special mention should be made of the high control of management expenses, which has enabled
us to slightly reduce our internal expenditure by 0.7%.
With a headcount at the end of 2021 of 194 employees, MMS has suffered a variation of 1.6%,
with a turnover of 9.4%. The commitment to our employees and society remains unchanged and
embedded in our corporate culture and this is a strategic pillar for the coming years as we face a
difficult labour market, with very low levels of unemployment, rising wage pressure and high
mobility in the market.
The solvency of MMS continues to be very high, as provisionally determined by management at
257.9%, are 2.6 times the minimum legal requirement. The reinsurance protection offered to the
Company by MAPFRE Re, the MAPFRE Group reinsurance company, ensures an adequate
cover for significant losses that ensures that our Solvency is not negatively impacted by such
occurrences. Taking advantage of the MAPFRE Group purchasing power ensures that such cover
is obtained at an optimal cost for the Company.
Investment return at €0.4 million, is higher than in 2020 but conditioned by the slightly negative
adjustment of the valuation of our main real estate investment, Development House.
Long Term Business
2021 has again been a challenging year for MMSV. The first months were in particular more
hesitant due to the uncertainty of the pandemic but in the end, in close collaboration with our
strategic partner Bank of Valletta p.l.c. (“BOV”), MMSV has achieved premium figures of
€325.1 million across all lines of business. This represents a very significant increase of 20.6%
and the highest premium income year in the Company's history.
The growth was mainly driven by savings products and in particular by our well-known With-
Profits product in Single Premium mode. Again, our main distributor was BOV.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
x
President & Chief Executive Officer’s Statement - continued
Long Term Business - continued
The other business lines: protection, pension plans, periodic premium savings, investment bond
and unit-linked, also performed very well in all cases.
Of particular note is that despite parting ways with two important distributors this year, MMSV
was able to offset those losses and even grow above our initial estimates including through a new
agreement with a financial institution that will further strengthen its distribution network. Our
direct distribution channel, shared with MMS, has performed extraordinarily well and almost
doubled its turnover. Finally, other TIIs have also continued to contribute to the Company's
strong business development.
MMSV has continued to work on improving the performance of With-Profits products, with
special offers and with additional services included in protection policies. MMSV offers the
widest range of protection, savings and retirement solutions on the market, suitable for families,
companies and diverse organisations.
Investment management has again been key and thanks to our diversified investment strategy
MMSV has achieved a very positive financial result for its policyholders, resulting in the
allocation of a Regular Bonus of 2%. In addition, certain investments have been adjusted to focus
more on assets that generate returns with lower volatility over the long term. 
Funds under management increased to €2,253 million, an increase of 3.5% over 2020, thanks to
the With-Profit's excellent sales figures as well as a return of the fund of €93.6 million,
representing a gross investment return of 4.2%, despite the volatility experienced especially in
Q4.
Operating expenses were closely controlled. The 1.1% reduction below 2020 was mainly due to
a reduction in internal expenses of 6.3% which compensated the higher acquisition expenses
from new business.
The protection business delivered an excellent technical result, strongly supported by an
improvement in interest rates, mortality rate adjustments and optimisation of reinsurance
protection.
As a consequence of the above, MMSV's profit before tax reached €16.7M, an excellent figure
exceeding 2020 and contributing decisively to Group consolidated results of over €20.0 million.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
xi
President & Chief Executive Officer’s Statement - continued
Long Term Business - continued
Solvency is a key aspect of MMSV. Our ratios are further reinforced, rising from 189% to more
than 228% (provisional) in 2021. This increase is due not only to the capital injection made in
March 2021 but also to a continuous improvement of those aspects of the With-Profit products
that most penalise capital requirements.
Regarding the MMS group life business, 2021 has been a better year than expected as the
increased competition in the market finally had a low impact and the premiums figure has
remained broadly similar to 2020 at €2.5 million with a 0.5% reduction. In addition, the
profitability of this business line has been very positive, €0.9 million, outperforming 2020 by
85.1%.
Consolidated Results
In 2021, the group registered a profit before tax of €20.4 million, 3.8% lower compared to the
previous year. After tax, the Group generated a profit of €12.9 million or 9.5% lower than the
previous year. The tax expense of 2021 is more than the 35% corporate rates closing at 36.6%
compared to 32.6% in the previous year due to a lower impact of Property gains that are taxed at
10%. Earnings per share attributable to shareholders have been reduced to 8c3. The profit
attributable to shareholders was reduced by the lower result achieved by MMS. MMS is
committed to returning value to its shareholders and will continue to dedicate an important part
of its profit to remunerate the shareholder.
After a complex few years and still maintaining a prudent policy in line with discussions with
our regulator, MMS will propose to the board of directors to pay a net dividend of €0.026087 per
share. The Company's payout will be 92.02% of this year’s profit after tax of the Company. It is
envisaged that MMSV will return to pay a dividend to its shareholders in 2022 at a level that
would safeguard a good level of Solvency.
In parallel, we continue to increase the value through both companies’ capitalisation to manage
stressed scenarios as we still face complex years with significant levels of uncertainty.
Statements of Financial Position
The group's total assets increased by 5.4% and totalled €2.83 billion. More than 92.7% of them
are return-seeking assets (investments and cash and cash equivalents) derived from the increase
in MMSV’s funds under management. These funds are invested in diversified securities (local
and foreign), managed in-house or externally by highly reputable entities. The Group also has a
portfolio of rented property investments and property-related shares.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
xii
President & Chief Executive Officer’s Statement - continued
Statement of Financial Position - continued
On the liabilities side, 97.0% of the balance pertains to technical provisions. Life technical
provisions increased as a result of inflows exceeding outflows from the Fund, whilst non-life
business saw an increase both in unearned premium provision from increased sales and in claims
outstanding provision from higher claim frequency and severity.
Total equity increased by €40.7 million or 22.4% including the minority interest mainly driven
by the injection of €20.0 in MMSV’s capital by BOV, the profit for the year and the increase in
the value of the in-force business.
Review of operations
During 2021 MAPFRE Malta has continued to drive forward its omnichannel approach,
introducing improvements across the board. At MAPFRE we want to accompany clients and
engage with them based on their preferences.
Starting with the website, we have developed an integrated site for the local Group,
mapfre.com.mt. This provides the customer with a global vision of the solutions and services that
our Group offers in both Life and Non-Life, undoubtedly the widest insurance offer in the
country. We continue to promote direct services to policyholders to make regular processes, such
as quotations, renewals, and notification of claims, easier and simpler. The ‘My Insurance’
customer portal gives access to the excellent offers of MAPFRE’s Insure&Save loyalty
programme. We cannot forget Emma, our chatbot, which continues to handle a growing volume
of interactions with our policyholders.
But we also continue to provide a first-class contact centre through our associate company
MAPFRE Middlesea Assist, a company specialising in road and home assistance services, which
are being digitalised for the convenience of our customers. Of course, communications via
WhatsApp are fully operational.
It is important to mention that all our intermediaries and regional offices play a key role in
creating a good customer experience, a situation that MAPFRE evaluates through studies based
on NPS (Net Promoter Score) methodology and where this year MMS has obtained the best
rating in the market.
We constantly strive for greater operational efficiencies, which is why several operational
processes have been optimised this year with RPA technology.
In 2021, we made organisational adjustments in MMS to strengthen the technical and operations
functions and those that are shared between MMS and MMSV.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
xiii
President & Chief Executive Officer’s Statement - continued
Review of operations - continued
Regarding digital transformation, progress in the implementation of the new core systems of both
companies has been remarkable, reaching important milestones, although we have again suffered
some delays in some projects. The main products of both companies can now be issued through
the new platforms, providing underwriting and operational improvements and a solid pillar on
which to build the digital ecosystem of the companies.
Subsidiaries and Associates
BEE Insurance Management Limited
BEE Insurance Management Limited and Euromed Risk Solutions Limited, our subsidiaries
dedicated to the provision of insurance services to third party companies, have managed to
maintain business with their existing clients, but have again encountered difficulties in acquiring
new clients due to the pandemic. Malta's grey-listing status has also resulted in potential clients
delaying their decision to establish themselves in Malta.
Due to these circumstances we made a small loss of €0.1 million. Nevertheless, we continue to
explore new opportunities that will allow us to maintain the sustainable development of this
activity within MAPFRE Malta.
Middlesea Assist Limited
MAPFRE Middlesea Assist Ltd, our joint venture between MMS and MAPFRE Asistencia,
generated a profit of €0.18 million, a reduction of 2.2% compared to 2020.
Its principal role is to be MAPFRE Malta's arm in developing services for our clients. As a leader
in roadside and home assistance services, it is perfectly aligned with our service ethos: we prefer
to solve our clients' problems rather than pursue a compensation process. Once again this year,
the evaluation of these services has been highly rated by our customers and we have also made
progress in the digitalisation of services with the MIA (MAPFRE Intelligence Assistance) Drive
project, which will allow smartphone access to the assistance service.
Middlesea Assist continues to develop its telephone customer care services, using WhatsApp.
CSR and Sustainability
We are a socially responsible business Group committed to the environment. We believe that the
development of our Company must be accompanied by absolute respect for all the stakeholders 
with whom we interact. We aspire to contribute to the well-being of society, which we are a part
of. MAPFRE is a company with a heart, whose pulse supports our social strength as an
organisation.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
xiv
President & Chief Executive Officer’s Statement - continued
CSR and Sustainability - continued
We are actors of social commitment through volunteering and through Fundacion MAPFRE
activities. Our employees, ourselves, are the protagonists collaborating in social tasks that help
others, something that, if in normal circumstances is very important, this year has become
fundamental. Our volunteers have participated in activities that have benefited a lot of people in
need, giving them food and a helping hand whenever possible.
Building a better, fairer, safer, more equal, more prosperous world is what MAPFRE aims to
achieve with #playingourpart, a concept targeting people and based on deeds and actions. It
revolves around what each one of us can do, those thousands of small gestures that contribute to
the common goal of protecting the planet and building a better today and tomorrow for everyone.
MAPFRE is a committed company that is concerned about its social print and fosters economic
and social development in the countries in which it operates. MAPFRE believes that business
development also entails a demanding social, environmental and governance commitment to
protect the legacy handed down to our future generations.
Looking forward
The year 2021 is over and with it our current strategic cycle and so we need to take stock. In
2019 we set out to transform ourselves to grow profitably. There have been clear advances in our
customer focus, in the technical and operational management of our businesses and culture and
talent as fundamental pillars of our business development.
It has definitely not been a normal period with the pandemic hitting us all through 2020 and 2021
but, despite adjustments to some of our projects to address more urgent needs, we have been able
to achieve most of our objectives and KPIs for the period.
Now it is time to look to the future, and we have defined a new strategic plan for MAPFRE
Malta 2022-2024, with specific developments for each company generating important synergies.
Briefly, our lines of action will have very clear drivers.
Customer focus. Our mission is to provide the best protection and the best service to our
customers. We have a magnificent starting point, but we are not satisfied. We want to be leaders
in customer experience in Malta and for this, we must listen more, understand all their needs and
their preferred form of relationship. We want to accompany clients in their lives and be there
with them, supporting them, at all times being reliable and trustworthy. The value proposition
must serve this great principle and promote a holistic view of the customer, differentiating
individuals and families from corporate customers.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
xv
President & Chief Executive Officer’s Statement - continued
Looking forward - continued
Distribution and diversification. While maintaining and reinforcing all our current distribution
agreements with our important commercial and strategic partners, we must continue to
strengthen the direct relationship with our customers when they require it, either in person or
digitally. We remain committed to a multi-channel distribution model, adapted to the needs of
our customers. We shall continue to offer the widest range of insurance products, diversifying
towards those insurance solutions that best suit our customers and which are also aligned from a
technical and capital management point of view.
Gaining efficiency. Offering the best solutions and services is all well and good, but we also
have to do it at the lowest possible cost, driving towards simplicity and agility.  This means
transforming many processes, and we are taking on the challenge determined to achieve this
ambitious goal.
We cannot and must not forget that the regulatory environment will continue to be very intense
in the coming years and as MAPFRE Malta we welcome all these changes. We will maintain the
same fluid, transparent and cooperative relationship with the different bodies that regulate our
activity, mainly the MFSA. We always aim to strike the balance between proper control and
business development on behalf of our intermediaries, providers and other stakeholders. We
must all cooperate to achieve full regulatory compliance without affecting commercial and
competitive activity.
Any business strategy requires a favourable and predictable environment to be successful and we
must defend Malta's excellent prospects. Together, we must continue to work towards making
our country increasingly transparent in financial practices so that situations such as the current
grey-listing can be remedied quickly. We must also find solutions to the growing shortage of
qualified professionals in a market of full employment. 
As an insurance Group, we reiterate our total commitment to collaborating with other institutions
in the promotion of road safety. As a society, we cannot accept that serious avoidable accidents
continue to occur. We must raise awareness of the risks of drug consumption, the use of mobile
phones and inappropriate speed. We must act in education, legislation, infrastructure and vehicle
fleets to rise to the challenge of Zero Fatalities in cars.
ESG is already deeply embedded in our strategy, in our commitment to society here at MAPFRE
Malta. We take specific action on environmental sustainability, in society and governance. We
are not starting from scratch, these activities were already part of our corporate DNA and were
already present in our daily business, but now we will promote them more directly and visibly.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
xvi
President & Chief Executive Officer’s Statement - continued
Looking forward - continued
We are an insurance Group committed to our shareholders, customers, distributors, employees
and Maltese society and we will continue to work hard every day to be Your Trustworthy
Company.
Signed by Javier Moreno Gonzalez (Chief Financial Officer) on 23 March 2022
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
xvii
Directors’ report
The Directors present their annual report for the year ended 31 December 2021.
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 investment
services and insurance management services.
Review of business
The Company
MAPFRE Middlesea p.l.c. (the ‘Company’) registered a profit before tax of €4.1 million during
the financial year ended 31 December 2021 (“FY 2021”) compared to €6.4 million registered in
the previous financial year (“FY 2020”) with post-tax profits of €2.6 million, compared to €4.1
million in FY 2020.  Whilst COVID-19 pandemic remained with us, a level of normality returned
impacting our technical performance through increased claims in the non-life business. On the
other hand group life business returned a stronger result than the comparative year. Negative fair
value movements, particularly in investment property, together with the non-payment of dividend
from the subsidiary MAPFRE MSV Life p.l.c. resulted in a modest financial contribution from
investments to the profits of the Company.
Premiums written by the Company reached €80.1 million (2020: €75.1 million), a 6.6%  increase
with growth in all main non-life classes of business with a marginal drop in Group Life. MAPFRE
Middlesea p.l.c. remained the leader of the non-life market with the Company’s market share
increasing marginally from the previous year following the receipt of provisional market data as
the market registered a growth in line with the Company's.
Technical results for general business dropped to €5.3 million from the €7.9 million of FY 2020, a
33.7% reduction.  Premium growth was encouraging although the growth in Motor was subdued
compared to other classes. Travel premium continued with negative trends as the Company
stopped offering the product to individual travellers for most of the year until the approval of the
COVID cover rolled out towards the end of 2021. Claims frequency, which was in 2020
significantly reduced particularly in Motor and Health business returned to normality with the
easing of restrictive measures during 2021. An increase in average claim cost in Motor was also
experienced which, together with a higher impact from major large losses saw the net combined
ratio in Motor increase to 100.3%, well above the 89.3% registered in FY 2020, and above set
targets. The whole non-life portfolio closed with a net combined ratio of 91.8% up from the 86.1%
registered the previous year. Group Life business although retracting marginally in premiums
recorded a strong result contributing €0.9 million, above the €0.5 million in FY 2020 mainly due
from a reduction in reinsurance cost emanating from reduced claim severity.
As the economy partially recovered from the contraction experienced in 2020 and with GDP
growth projections showing a reducing trend, the quest for profitable growth remains at the core of
the MAPFRE Group strategy to ensure adequate returns to its shareholders even at such a
turbulent period. The Company continues to monitor each line of business, ensuring pricing
adequacy whilst introducing changes in the products offered, taking on risk that is within its risk
appetite to maximise profit.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
1
Directors’ report - continued
Review of business - continued
The Company – continued
Business and client retention remains a major challenge as clients seek insurance cover that suits
their needs at the right price. The Company remains focused on offering its clients a better service
directly or through its numerous intermediaries, even if remotely.  The Company continues to roll-
out its implementation of its new insurance IT system whilst upgrading its technological platforms
that bring the Company closer to its clients. As progress is made in rolling further products onto
the new system, the Company is aware of the inherent risks that an overhaul of the core IT system
brings about both to resources and operations and Management plans to ensure transition is done
in a way to mitigate such risks.
The Company’s net investment return amounted to €0.4 million compared to the €0.1 million  in
FY 2020. In both financial years MAPFRE MSV Life p.l.c. did not pay any dividends to its
shareholders. As reported last year  due to the financial market crises which was at its worst during
March 2020, the Solvency ratio of MAPFRE MSV Life p.l.c. had reduced significantly though
remaining within regulatory requirements. Management took the necessary action to restore the
Solvency position to a more adequate level, including by not paying dividends and by increasing
its issued and paid up share capital. Local financial securities continued on the negative trend of
the previous year. During 2021, the Company disposed of its foreign equity holdings and
appointed MAPFRE ASSET MANAGEMENT as its investment manager to actively monitor the
portfolio and take the necessary actions to improve returns. Revaluation of property investments
rendered a loss of €0.5 million for 2021 compared to a gain of €0.1 million the previous year.
The Shareholder’s Funds of the Company at €76.4 million saw a reduction of 0.8% during FY
2021 resulting from the payment of dividend for FY2020, which exceeded the profit for the year.
Net Asset Value per share as at 31 December 2021 amounted to €0.83.
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. 
MAPFRE MSV Life p.l.c.
MAPFRE MSV Life p.l.c. (“MAPFRE MSV Life” and “MAPFRE MSV Group”) registered a
profit before tax of €16.7 million for FY 2021, up 11.3% on the previous year where a €15.0
million profit before tax was generated. Profit after tax is recorded at €10.6 million, up 2.9% on
the €10.3 million in the previous year.
Operating results benefited from the strong economic recovery and the significant liquidity in the
local market. Consumer sentiment continued to improve as unemployment levels went down as
concerns related to COVID-19 continued to abate as vaccination rates increased
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
2
Directors’ report - continued
Review of business - continued
MAPFRE MSV Life p.l.c. - continued
During the year, governments and Central Banks’ accommodative fiscal and monetary policy
continued to support asset prices, driving major equity indices to record highs. Notwithstanding
the supply chain issues and the spike in commodities prices, equities continued to outperform
while fixed income securities suffered some losses as inflation surged across many countries
fuelling interest rates increase expectations. In the US, the Federal Reserve System took centre
stage in communicating that interest rate will have to rise in 2022 to manage the increase in
inflation while the asset purchase programme will be gradually withdrawn. On the other hand, the
ECB has been more cautious not to derail the economic recovery and is thus expected to start the
interest rate normalization cycle later when compared to his US and UK counterparts.
Gross premiums written for FY 2021 totalled €325.1 million, an increase of 20.6% over the prior
year €269.6 million, driven by a strong demand across all lines of business. The economic
recovery, the high levels of liquidity in the local economy and the low interest rates characterizing
the market were the main catalysts behind the increased demand for MMSV’s products. Both
single and regular premium business benefited from this environment. The With Profits Single
Premium Plan contributed significantly towards the gross premium written in 2021. In terms of
regular business, personal pension plans continued to experience a sustained demand. 
Net claims incurred increased to €305.0 million through the year compared to a prior year €261.2
million largely as a result of a continuing trend which sees an increase in maturing medium-term
single premium contracts. A large proportion of maturing contracts were subsequently re-invested
in new medium to long-term contracts.
In aggregate, the balance on the long term business technical account increased to €18.1 million
from a prior year €14.9 million as a result of slow but steady growth in the volume of With Profit
funds throughout the year as well as life assurance protection business driven by good
underwriting performance.
The MAPFRE MSV Group’s total assets increased by 6.2% from €2,563.7 million at the end of
2020 to €2,721.4 million at the end of 2021, whilst net technical provisions (including investment
contracts without DPF) increased by 3.8% from €2,349.3 million in 2020 to €2,437.6 million in
2021.
The value of in-force business, which projects future transfers to shareholders arising from policies
in force at the end of the year, increased by 12.8%, up from €77.2 million in 2020 to €87.1 million
in 2021. This is attributable to the impact of new business inflows, improved technical margins
and improved mortality performance when comparing actual mortality to assumed mortality
updated run rates.
Total shareholders’ funds at the close of 2021 amounted to €221.9 million (2020: €161.4 million),
an increase of 37.5%over the previous year and well ahead of minimum solvency guidelines. In
March 2021, MMSV’s shareholders increased the issued and paid up share capital by €40.0
million
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
3
Directors’ report - continued
Review of business - continued
MAPFRE MSV Life p.l.c. – continued
The shareholders of MAPFRE MSV Life are wholly committed to ensuring that the company
remains adequately capitalised at all times to sustain business growth and to meet Solvency
Capital Requirements in line with the Solvency II framework. 
The MAPFRE MSV With Profits Fund stood at €2.25 billion at 31 December 2021 (2020€2.18
billion) with growth in the fund driven both by operational cash flows arising from new business
as well as market returns on the differing asset classes held within the portfolios.
Notwithstanding new COVID-19 virus variants, inflationary pressures, supply chain disruption
and geopolitical concerns, markets continued to trend broadly higher in 2021 on favourable
economic, financial market and policy conditions.The total investment return of the With Profits
Fund amounted to €93.6 million generating a return of 4.2%.
The investment strategy of the MAPFRE MSV With Profits Fund is to hold a diversified range of
quality assets and currencies that mitigates against market risk. This asset diversification together
with the robust investment management process, the quality of the asset managers engaged, and
the Company’s strong track record of investment management continue to be fundamental in
deriving value in a challenging and more volatile investment market environment.
In March 2022, the Board of Directors of MAPFRE MSV Group approved a resolution whereby
differential rates of Regular Bonuses were declared in respect of With Profits plans held with
MAPFRE MSV Life for the year ended 31 December 2021. These amounted to 1.90% for the
Comprehensive Life Plan (regular and single premium policies), 2.00% in respect of the
Comprehensive Flexi Plan (regular and single premium policies), 2.00% under the Single
Premium Plan and 1.90% under the With-Profits options of the Investment Bond, Retirement Plan
and of the Personal Pension Plan. On the ‘Old Series’ Endowment and Whole Life policies, a
Regular Bonus of 1.50% of the basic sum assured plus bonuses was declared.
In addition, the Board also announced the declaration of a Final Bonus in respect of
Comprehensive Life Plans (single and regular premium), Comprehensive Flexi Plans (single and
regular premium) and Single Premium Plans that have been in force for more than 10 years. For
Regular Premium policies, the Final Bonus is expressed as a percentage for every year in force
after the 10th year of the policy whilst, for the Final Bonus on Single Premium policies is being
expressed as a combination of a flat percentage plus an additional percentage for every year in
force after the 10th year of the policy. Final Bonuses will be paid on the value of the Policy
Account as at the date of death or maturity between 1 April 2022 and the next bonus declaration in
accordance with the following table:
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
4
Directors’ report - continued
Review of business - continued
MAPFRE MSV Life p.l.c.  - continued
Product
Final Bonus Flat Rate
%
Rate per Year in Force >10 years
%
Comprehensive Life Plan ( Regular Premium)
Nil
0.50%
Comprehensive Flexi Plan (Regular Premium)
7.50%
0.25%
Single Premium Plan
9.00%
Nil
Comprehensive Life Plan (Single Premium)
Nil
2.50%
Comprehensive Flexi Plan (Single Premium)
10.00%
1.50%
The Board of MAPFRE MSV Life also approved a Regular Bonus of 1.90% on those Secure
Growth policies which formed part of the portfolio of business transferred to MAPFRE MSV Life
from Assicurazioni Generali S.p.A. during 2000. Finally the Board also approved a Regular Bonus
of 1.25% on the ALICO 78 policies and a Regular Bonus of 1.25% on the ALICO 66 polices
which formed part of the portfolio of business transferred to MAPFRE MSV Life in 2011 from
American Life Insurance Company (“ALICO”).
Notwithstanding the prudent investment policy adopted by MAPFRE MSV Life, past performance
is no guarantee for the future. Although MAPFRE MSV Life’s With Profits investments have
generally provided policyholders with stable and satisfactory returns when compared with other
similar investment products, in the light of the current uncertainty in the capital markets,
investment returns could fluctuate further. Fair value movements and investment returns impinge
directly on the rates of bonuses declared by the company. Regular Bonuses are therefore expected
to vary over the lifetime of the policy whilst Final Bonuses are likely to be highly volatile and very
dependent on the investment performance of the company. 
In 2021, the life insurance market in Malta continued to recover from the significant challenges
brought about by the outbreak of the pandemic in 2020 and by the continuing climate of low
interest rates. The 2021 regular bonus rates represent an increase of 0.50% from the 2020
declaration. This reflects the improved investment performance of 2021.
During the year, the company continued to follow health and safety measures to mitigate the
potential business disruptions associated with COVID-19. The company followed local
authorities’ protocols and internal policy to minimize the risk of virus exposure to the employees,
customers and other stakeholders. A hybrid working model has been maintained with continued
investment in information technology infrastructure to better support remote working. The
digitilization effort continues to be paramount not only to enhance the customer experience but
also to improve operational resiliency.
There were no significant insurance or financial risks impacting the portfolios of business, during
the year, and mortality assumptions used in the valuation of policyholder obligations remained
appropriate.
The single premium contracts saw a very strong demand in the first and last quarter of the year.
Pent up demand and a more subdued first quarter in terms of local capital market issues are
believed to have contributed to this improved performance. Whilst demand was moderated in the
second and third quarter, it picked up significantly during the last quarter a driven by the Single
Premium special offer that was launched at that time.     
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
5
Directors’ report - continued
Review of business - continued
MAPFRE MSV Life p.l.c.  - continued
The demand for new retirement savings products continues to be encouraging and the Group saw
improved turnover in regular savings contracts and protection business. We continued to be very
active in the voluntary personal pensions market and continued to successfully promote our
Voluntary Occupational Pension Scheme in the market.
As a result, MAPFRE MSV Life continue to see good take up of all its product groupings as
customers continue to choose the company, trusting in its brand and in the quality of its service
proposition.
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.
BEE Insurance Management Limited (‘BEE’) and its subsidiary Euro Med Risk Solutions Limited
which offer Insurance and Non-Insurance management services saw a pick-up in revenue as a new
client was onboarded. A combined loss of €0.1 million was registered a decrease of 48.2% on the
previous year’s loss.
Church Wharf Properties Limited holds a property within the Regeneration of the Grand Harbour
Area. A loss of €0.4 million was registered at the end of 2021 following a change in methodology
applied for the valuation of property. The directors continue to monitor the evolution of this
project which gives a potential future increase in value of this investment.
The Group
The Group registered a profit before tax of €20.4 million in FY 2021 compared to €21.2 million
achieved in FY 2020. Profit after tax for FY 2021 closed at €12.9 million a 9.6% drop from the
€14.3 million achieved in FY 2020. Group premiums written saw a strong recovery reaching
€405.3 million,17.6% above that registered in FY 2020 with both insurance companies remaining
leaders in their respective markets.
MAPFRE Middlesea’s Group capital and reserves attributable to shareholders at 31 December
2021 amounted to €111.0 million (2020: €100.6 million) on a consolidated basis with a net asset
value per share of €1.21 as at 31 December 2021  mainly as a result of good results the increase in
the value of in-force business and the non-payment of dividend by MAPFRE MSV Life.
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.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
6
Directors’ report - continued
Review of business - continued
The Group – continued
Sustainability is also very high in our agenda. In line with the MAPFRE Group objective, the
Group is aiming to be carbon neutral by end 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. Our
investment policies and processes are being reviewed and updated to promote Responsible
Investing principles, initiatives have been rolled out to reduce our carbon footprint while the
Group can also boast to have a diverse multinational workforce with high levels of female
participation in senior management positions.
Training and development of our people continued to feature high on our agenda during 2021
notwithstanding the pandemic. We value our people and seek to help them achieve their full
potential by providing them with internal and external training opportunities in Malta as well as
overseas. In order to ensure the well-being and ongoing development of our people, we are
continuously reviewing and updating our HR policies and implementing new policies and
employment practices.
The Board expresses its gratitude and appreciation to the management and staff of all the Group
companies for their commitment and contribution to another satisfactory year, to intermediaries
for their continued support and to the many loyal customers for placing their trust in MAPFRE
Middlesea p.l.c. and MAPFRE MSV Life p.l.c..
Going forward we will maintain strong focus on our customers by continuously assessing our
business processes and operations in order to provide good value and excellent service. To this
end, we will continue to invest and innovate in information technology. During 2021 we
progressed on our major IT programmes in both insurance companies. MAPFRE Middlesea,
whilst suffering some delays achieved a number of goals in its plan for the year and is heading for
critical milestones in its roll-out in the coming months. MAPFRE MSV Life achieved a number of
important milestones related to the current phase of the new Life Administration System
implementation. Over the next year, the company looks forward to consolidate on these
achievements and to further deliver in terms of the customer journey experience and its digital
transformation.
We consider our distribution footprint in Malta to be one of our key strengths. We are going to
persist on the multichannel approach, we want the client to receive the same price from the
Company whatever channel he chooses to approach the Company: Direct, Agents, Tied Insurance
Intermediaries or Brokers. In MAPFRE MSV Life, whilst bancassurance remains the most
important distribution channel, to ensure that we provide our customers with greater accessibility
and a better service, we are continuously seeking to strengthen all other distribution channels.
The Group continues to seek growth in its core business lines and believes that its increasing
integration with MAPFRE Group strategies will further strengthen and consolidate business
prospects.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
7
Directors’ report - continued
Outlook
The outlook of the Board of Directors for 2022 remains one of cautious optimism. The global
economic recovery experienced in 2021 should be sustained into 2022 though the growth rate will
not benefit from the low base effect of 2020. High liquidity and a still supportive fiscal and easy
monetary policy should continue to underpin growth.  However, down side risks persist in the
form of structural inflationary pressures, supply side bottlenecks, new COVID-19 variants and
geopolitical risk. The insurance market has not been effected as negatively as other sectors of the
economy although the pinch felt by the rest of the economy is having its side effects on our sector
both in the sale of certain products and through inflationary pressures on claims. Within this
context, demand for general business is expected to grow at a lower rate experienced in the last
pre-pandemic years and in the context of Malta’s high savings ratio, the demand for the protection,
savings and investments products in life is expected to remain strong.
Changing customer behaviours, dramatic technological developments, product innovation and the
disruption that is taking place in the insurance industry will require insurance companies to adapt
to be in a position to exploit the many opportunities that will certainly arise.
In terms of prudential and conduct regulation, in 2022 we are looking at a number of important
reviews in the context of Packaged Retail and Insurance- Based Investment Products (PRIIPS), the
Insurance Distribution Directive and Solvency II. Increased regulation in the form of
sustainability-related disclosures emanating from the Sustainable Finance Disclosure Regulation
(SFDR) and the new Corporate Sustainability Reporting Directive (CSRD) is also expected. Of
particular relevance will be the Technical Advice of EIOPA to the European Council on aspects
relating to Retail Investor Protection. The prevailing Anti-Money Laundering Directive will also
feature prominently in the evolving regulatory landscape.
Russia’s invasion of Ukraine is a great human tragedy. This event has significantly increased the
level of political, economic and market risks. Prior to the military escalation witnessed over the
last few weeks, the general outlook was one of a return to pre-pandemic economic and market
conditions driven by a consolidation of the global recovery and the renewed hope for an end to the
pandemic. The latter being dependent on a broad population immunity and from the absence of
any new more vaccine resilient virus strains. Inflationary pressure was expected to lessen in the
second half of the year while monetary policy remains relatively easy. This would normally lead to
a strong cyclical recovery, a return of global mobility and a release of pent-up demand from
consumers and corporates. This backdrop would be supportive of equities but negative for bonds.
However, an aggressive interest rate policy approach would derail the economic recovery and
negatively impact equity asset prices. Certain sectors would be more vulnerable should Central
Banks’ expected tighter monetary policy move faster and further than what the market is currently
pricing in.  However, the latest developments, which crystalizing the geopolitical risk have
significantly increased the level of uncertainty. Economic growth is expected to be lower, with
growth in Europe being impacted the most. The economic magnitude of this will depend on how
the conflict unfolds. Different scenarios present different economic outcomes in terms of impact
magnitude and on the eventual recovery. Capital markets are expected to remain volatile and
Central Bank’s policy will need to balance the need to contain inflation and to support the
economic recovery.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
8
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, Note 16 on intangible assets covering details on the
Group’s value of in-force business, Note 19 on investment property discussing significant
unobservable inputs used, and Note 24 discussing the assumptions underlying the technical
provisions.
Events after the financial reporting date
The transfer of the portfolio of funds held by the subsidiary of MAPFRE MSV Life, Growth
Investments Limited to Bank of Valletta p.l.c., as contemplated under the Transfer of Business
Agreement (TOBA) with BOV Asset Management Ltd and Bank of Valletta p.l.c. signed on 6
February 2020 was finalised subsequent to the balance sheet date.
The consideration of €0.30 million was settled in February 2022. The remainder of the subsidiary's
portfolio is expected to be transferred to MAPFRE MSV Life p.l.c. by end of the first half of 2022.
The subsidiary has engaged the services of a highly reputable consultant to advise on the
liquidation process. The directors expect the subsidiary to wind down by end of 2022.
There were no further important events or transactions which took place after the financial
reporting date which would require disclosure or adjustment to this annual report and financial
statements.
Results and dividends
The consolidated profit or loss account is set out on page 44.  A gross dividend in respect of year
ended 31 December 2021 of €0.030401 per share amounting to a total dividend of €2,796,910 is to
be proposed by the Directors at the forthcoming annual general meeting.  This is equivalent to a
net dividend of €0.026087per share amounting to a total net dividend of €2,400,000 (2020:
€3,200,000).
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
9
Directors’ report - continued
Directors
The Directors of the Company who held office during the period under review were:
Martin Galea  
Jose Ramon Alegre
Alfred Attard (resigned as of 30 April 2021)
Antoinette Caruana
John Cassar White (appointed as from 30 April 2021)
David G.Curmi (resigned as of 31 January 2021)
Jose Maria del Pozo
Jose-Luis Jimenez
Taddeo Scerri
Paul Testaferrata Moroni Viani
Joseph F.X. Zahra
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.
The Board of Directors (acting in accordance with Article 100 of the Memorandum and Articles of
Association) re-appointed Jose Maria del Pozo.
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.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
10
Directors’ report - continued
Statement of Directors’ responsibilities for the financial statements - continued
The financial statements of MAPFRE Middlesea p.l.c. for the year ended 31 December 2021 are
included in the Annual Report 2021, which is published in hard-copy printed form and also made
available on the parent 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 2021, 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.
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 2021, 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.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
11
Directors’ report - continued
Information pursuant to Capital Markets Rule 5.64 - continued
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 2021, 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.
Going concern
The Directors, as required by Capital Markets Rule 5.62 have considered the Group’s and
Company’s operational performance, the statements 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 23 March 2022 by Martin Galea
(Chairman) and Taddeo Scerri (Director) as per the Directors Declaration on ESEF Annual
Financial Report submitted in conjunction with the Annual Report and Accounts 2021.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
12
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’) and is, moreover, obliged to prepare
a report disclosing both compliance and non-compliance with the said principles. In addition,
the Company’s auditors are to include a report on the Corporate Governance Statement in the
Annual Financial Report of the Company.
The Board of Directors (‘the Board’) of MAPFRE Middlesea plc (the ‘Company’ or ‘MMS’)
acknowledges that compliance with the said Code is not mandatory, however notes that the
principles are designed to serve as a guide for the Board and the Company’s Management in
their pursuit of objectives in the interests of both the Company and its shareholders. The
Board, therefore, firmly upholds the principles therein contained as guaranteeing the required
standards of accountability and transparency and strives, to adhere to the Code as well as to
maintain the highest standards of disclosure insofar as both compliance and explaining the
rationale behind the instances of non-compliance. 
As evidenced by the information set out in this Statement and that contained in the
Remuneration Statement and Report of the Remuneration Committee to the Shareholders, the
Company believes that it has, save as indicated herein in the section entitled Non-Compliance
with Code, applied the principles and complied with the provisions of the Code throughout
the accounting period under review.  In the Non-Compliance Section, the Board outlines and
explains the instances where there has been a departure from, or non-application of,the
principles as contained within the Code, in accordance with the same Code.
2.Compliance with the Code
Principle 1 – The Board
The Board’s role and responsibility is to lead the Company, to discuss and approve strategy
and to exercise good oversight, challenging the Management and Control Functions where
necessary to this end.
As at the 31 December 2021 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, honest 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 2021,
which followed the Annual General Meeting (AGM) held on the same day.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
13
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
Jose Ramon Alegre, Taddeo Scerri, David Curmi, Martin Galea, Jose-Luis Jimenez and
Joseph F. X. Zahra, while the other shareholders re-appointed the retiring Directors
Antoinette Caruana and Paul Testaferrata Moroni Viani during the election for directors. John
Cassar White was newly appointed by the shareholder Bank of Valletta p.l.c and Jose Maria
del Pozo was co-opted to the Board of Directors in accordance with Article 100 of the
Memorandum and Articles of Association, at the Board Meeting immediately following the
AGM.
In the interim period David Curmi tendered his resignation from the MAPFRE Group as of
31 January 2021 and consequently from the Company’s Board in order to take up other
employment. David Curmi was not replaced and thus the Board was reduced to the nine non-
Executive members as aforementioned.   
All of the Directors of the Company are approved by the Regulator 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 are deemed to 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. The Board moreover 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.
The Board liaises closely with the President & Chief Executive Officer (‘CEO’) of the
Company at all times in order to ensure that the Board receives timely and complete
information in relation to the business of the Company and management performance. This
enables the Board to contribute effectively to the decision-making process and to exercise the
aforementioned controls. Javier Moreno, appointed CEO on the 31 March 2021, after a
robust hand over process from the outgoing CEO Felipe Navarro who had been at the helm of
the Company since 1 October 2015, continued to hold the position of CEO throughout the
rest of 2021.
As is customary, during the year 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 approved by the Board. 
Further detail in relation to the Committees and the responsibilities of the Board is explained
under Principles 4 and 5 of this Statement.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
14
Corporate Governance Statement - continued
2.Compliance with the Code - continued
Principle 2 – Chairman and CEO
The positions of Chairman and CEO are occupied by different individuals with a clear
demarcation between the leading of the Board 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 leadership of the Board and for the
setting of its agenda. He ensures that the Board’s discussions on any issue put before it are
addressed with adequate depth, that the opinions of all the Directors are taken into account,
and that all the Board’s decisions are supported by comprehensive and timely information.
He encourages active engagement by all the members of the Board with constructive
challenging of the Management where necessary and generally promotes and ensures the
effective functioning of the Board.
The CEO advises and makes recommendations to the Board while leading the Senior
Management team, with the main role and responsibility of managing the Company’s
business in line with its Strategy. The CEO develops and drives performance within the
Strategy approved by the Board and makes decisions on all matters affecting the operations,
performance and strategy 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 as well as in practice. In practice, there is a
clear division of responsibility between the overseeing of the Board and the CEO’s
responsibility in managing the business of the Company rendering these positions completely
independent from one another to avoid concentration of authority and power within a single
individual and to differentiate leadership from the running of the business.
Principle 3 – Composition of the Board
The Board considers and experience has shown, that the number of Members as stipulated in
the Memorandum and Articles of the Company to be appropriate relative to the size of the
Company and its operations.
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.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
15
Corporate Governance Statement - continued
2.Compliance with the Code - continued
Principle 3 – Composition of the Board - continued
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 required to limit the number of directorships
held in other companies thereby also ensuring the proper performance of their functions.
The Board is composed exclusively of non-executive Directors. 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 Board’s policies and strategy and to provide direct
input to 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 six independent Directors (including the
Chairman), and three non-independent Directors (as indicated on page 18 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”.
It is noted in this regard that Joseph F. X. Zahra has served on the board for more than twelve
consecutive years, however, the Board was of the opinion that Joseph F. X. Zahra had
immeasurable experience and sufficient maturity to remain independent of character and
objective in judgment at all times notwithstanding the lapse of the recommended twelve
years. That said, in light of the provision, the Company has taken proactive steps in the
interim period to identify a suitable replacement
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.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
16
Corporate Governance Statement - continued
2.Compliance with the Code - continued
Principle 4 – The Responsibilities of the Board
The Board acknowledges its statutory mandate to set policy and to provide direction as well
as to monitor the implementation thereof. The Board fulfills 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, applies
high ethical standards whilst taking into account stakeholders’ interests, maintains an
effective dialogue with all stakeholders, monitors the application of management policies and
motivates 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 business of the Board as well as its agenda
are managed in such a way so as to ensure effective supervision of the Company’s operations
in accordance therewith.
The Board meets as often as required to discharge its duties effectively. Specific members of
the Management team are invited to update and provide the Directors with a direct report at
each Board Meeting depending on the items on the agenda, however, 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. The
Board is also updated at every meeting in terms of Management’s comments on the results
and on relevant events and decisions and background information on various subjects
including any matter requiring the approval of the Board.
Apart from setting the strategy and direction of the Company, the Board is actively involved
in monitoring progress against 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 agenda and are supported by all available information.  The agenda for each meeting
seeks to strike a balance between long-term strategic objectives and shorter-term performance
matters. Notice of the dates of forthcoming Board meetings together with all relevant
documentation are circulated in advance to all Directors in order to give them opportunity to
consider the information and prepare well in advance of the relative Board meeting.
During Board meetings members of Management are often invited to present on the subject
matter being discussed while the Chairman facilitates discussion and ensures that all
Directors are given ample opportunity to discuss issues set on the board agenda and convey
their opinions thereon.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
17
Corporate Governance Statement - continued
2.Compliance with the Code - continued
Principle 5 – Board Meetings - continued
Minutes are taken of each and every Board meeting faithfully recording attendance, matters
discussed, action points and resolutions. These minutes are subsequently circulated for
review to all Directors 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 in the case of parity.
During financial year 2021, the Board of Directors of the Company held seven Board
Meetings with attendance as follows:
Martin Galea  (Chairman) (NED I)7
Jose  Ramon Alegre (NED)6
Alfred Attard (NED - resigned as from 30 April 2021)2
Antoinette Caruana (NED I)7
John Cassar White (NED - appointed as from 30 April 20211)                6
David G. Curmi (NED - resigned as from 31 January 2021)-
Jose Maria del Pozo (NED)7
Jose-Luis Jimenez (NED)6
Taddeo Scerri (NED I)7
Paul Testaferrata Moroni Viani (NED I)7
Joseph F.X. Zahra (NED I)
NED – Non-executive Director
I – Independent
1 With approval communicated by the Regulator on 21 June 2021.
The MMS CEO attended all the Board meetings by invitation.
During 2021 two Board Briefings were 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 February
was to review the Financial Highlights of the previous financial year including the
achievement of Key Performance Indicators and to take a deeper look at Claims Reserving
relative to the actuarial calculations on the attritional claims and the treatment of larger
losses. During the Directors’ Briefing held in February the Board also discussed the
comparative figures for the insurance market in Malta based on the financial data submitted
by competitors to the Regulator within the annual Solvency and Financial Condition Report. 
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
18
Corporate Governance Statement - continued
2.Compliance with the Code - continued
Principle 5 – Board Meetings - continued
During the second Briefing held in May the Board reviewed the information that would feed
into the Own Risk & Solvency Assessment and held an in-depth discussion on the pertinent
risks of the Company. In addition, a presentation was also delivered to kick off preparatory
discussions for the new three-year Strategic Plan for the period 2022 to 2024. An on-line
MAPFRE Group training syllabus covering twelve sections with a range of topics including
Operational, Technical and AML matters was also made available to all Directors by way of
continued professional development for Directors in the discharge of their functions on the
Board and Committees.
Notices of meeting dates were circulated well in advance of the relative meetings and
meeting packs containing all relevant information, including the minutes of the previous
Board Meeting, were circulated to the Directors ahead of each meeting by the Company
Secretary. Each communication allowed ample opportunity for the Directors to review the
information and prepare for the next scheduled Board or Committee meeting.
Principle 6 – Information and Professional Development
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 for newly
appointed Directors to enable new incumbents to familiarise themselves with the Company’s
strategy, risk appetite and operations. Directors also receive a MAPFRE Corporate
comprehensive guide which includes, amongst others, Directors’ duties and responsibilities.
That said, no induction programme was conducted in 2021 given that John Cassar White,
who was appointed to the Board in April 2021 as an Independent Director, had previously
served for many years on the Board of a Company subsidiary and was thus already very well
acquainted with the business of the Company, not least due to also having been a member of,
as well as chairing, the Joint Investment Committee for various periods since 2014.
In the second half of 2020 a structured Board training and development programme was also
launched for Directors in Malta by the MAPFRE Group including both awareness sessions
facilitated by members of the Management team as well as a full on-line training schedule
available for subscription. The key objective of the programme being to contribute to 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 they have open access to the advice and services of the Office of the
Company Secretary. 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.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
19
Corporate Governance Statement - continued
2.Compliance with the Code - continued
Principle 6 – Information and Professional Development - continued
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, the on-going monitoring of Management,
the development and training of both Senior Management and Directors, as well as
succession planning, as required by the provisions of clause 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 the Remuneration Committee and with the Board on the
appointment of, and on the succession plan, for Senior Management. Training (both internal
and external) of management and employees is prioritised and is implemented through the
Human Resources Department. Several on-line training sessions were also held on various
topics during the course of 2021 including on Prevention of Financial Crime, Ethics,
Leadership, the Digital Environment and Cyber Security.
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 outcome was discussed
during an informal off-site meeting.
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 2021 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 approved by the Board of Directors and by the MFSA. 
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
20
Corporate Governance Statement - continued
2.Compliance with the Code - continued
Principle 8 – Committees - continued
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
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
the audit process.
The Committee generally protects the interests of the shareholders 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, 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.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
21
Corporate Governance Statement - continued
2.Compliance with the Code - continued
Principle 8 – Committees - continued
Audit Committee
Furthermore, although no such instances arose within 2021, 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. 
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, Martin Galea and Taddeo Scerri are
the members of the Audit Committee with the necessary qualifications, experience and
knowledge to render them competent in accounting and auditing. Both Directors are also
considered Independent Director in accordance with the criteria set out in Capital Markets
Rule 5.119 and Martin Galea was appointed Chairman of the Audit Committee by the Board
of Directors in accordance with Capital Markets Rule 5.117.4 as of 30 April 2021, taking
over from Alfred Attard.
The Audit Committee held seven meetings during 2021. 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 Taddeo Scerri (replacing Alfred Attard as of
30 April 2021), Antoinette Caruana and Martin Galea. The Audit Committee members and
relative attendance at meetings is listed below.
Alfred Attard (Chairman until 30 April 2021)4
Antoinette Caruana7
Martin Galea (Chairman as from 30 April 2021)7
Jose Maria del Pozo 7
Taddeo Scerri (as of 30 April 2021)3
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.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
22
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 thus
ensuring good communication and continuity between the said Board Committee and the
other members of the Board.
Risk and Compliance Committee
This 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 plan and other matters referring to
regulatory compliance risk and 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 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 2021. The Committee
members and relative attendance to meetings is listed below.
Antoinette Caruana (Chairperson, until 30 April 2021)6
Diane Bugeja (as of 30 April 2021)3
Albert Frendo (until 30 April 2021)  3
Martin Galea6
Jose Maria del Pozo6
Joseph F X Zahra (as of 30 April 2021)3
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 thus ensuring good communication and continuity between the said Board
Committee and the other members of the Board.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
23
Corporate Governance Statement - continued
2.Compliance with the Code - continued
Principle 8 – Committees – continued
Investments 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 Investments 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 four meetings during 2021. The Committee members and relative
attendance to meetings is listed below.
Simon Azzopardi2
John Cassar White (Chairman until 23 March 2021)1
Romeo Cutajar (Chairman as of 23 March 2021)4
Jose-Luis Jimenez3
Felipe Navarro Lopez de Chicheri (until 31 March 2021)1
Jose Maria del Pozo4
Javier Moreno (as of 1 April 2021)3
Patrick Spiteri Swain4
Paul Testaferrata Moroni Viani3
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.
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 2021 are considered in
the Remuneration Statement and Report to the Shareholders
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
24
Corporate Governance Statement - continued
2.Compliance with the Code - continued
Principle 8 – Committees – continued
Remuneration Committee - continued
The Remuneration Committee held three meetings during the period under review and the
attendance was as follows:
Jose Ramon Alegre2
Antoinette Caruana (as from 30 April 2021)1
John Cassar White (as from 30 April 2021)1
Martin Galea (until 30 April 2021)2
Taddeo Scerri (until 30 April 2021)2
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 2021 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 well
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
Company’s Annual Report, as available for review and downloading from the Company’s
website. The Company’s website (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.   
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
25
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 the major shareholders particularly to discuss matters of significant importance or to
address particular issues or concerns. In addition, 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.
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. 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 p.l.c., is a listed company on the
Malta Stock Exchange and consequently a steady flow of information is maintained through
company announcements and press releases. 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 shareholders as a whole 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 would include a record of such
declarations and of the action taken by the individual director concerned as and when
required.
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 shareholders.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
26
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 a regular basis.
As required by clause 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 2021 has been
declared by Joseph F. X. Zahra who has a very minor shareholding whereas Paul Testaferrata
Moroni Viani has declared an indirect shareholding in the Company’s shares through his
shareholding in other companies. 
Principle 12 – Corporate Social Responsibility
Despite the challenging times caused by the COVID-19 pandemic, MAPFRE Malta has
remained committed to its Corporate Social Responsibility objectives, namely to protect the
health of its employees, collaborators, clients and other individuals. In addition, to assist
entities that were negatively affected by the COVID-19 crisis through its commitment to the
implementation of several social welfare projects carried out by Fundación MAPFRE
throughout the year.
During 2021, MAPFRE Malta once again met its CSR objectives collaborating with a
number of different entities to organize various activities ranging from food and blood
donations, environmental activities and clean-ups.
Fundación MAPFRE allocated over €100k for projects in Malta across different areas (road
safety, health, and social actions). The Foundation has once again collaborated with Inspire
and Equal Partners Foundation, funding the provision of specialized services to children and
adults with disabilities (€53,000 to cover the running costs of Inspire’s therapeutic facilities
Multi-Sensory Rooms and over €30,000 to Equal Partners Foundation to support their efforts
to enable children who suffer from a disability to lead a more independent life).
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.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
27
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 opted not to formalise a succession policy for the
Board of Directors. That said, the Company and its Board remain mindful of the
recommendation as contained within the Capital Markets Rules and frequently reviews the
current position.
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.
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.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
28
Corporate Governance Statement - continued
3.Non-compliance with the code - continued
Principle 7 – Evaluation of the Board’s Performance - continued
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.
For these reasons the process is deemed to be comprehensive and sufficient to meet the
intended aims.
Principle 8A – Remuneration Committee: Code Provision 8.A.1
Code Provision 8.A.1 recommends that the Board of Directors “should establish a
Remuneration Committee composed of non-executive Directors with no personal financial
interest other than as shareholders in the Company, one of whom shall be independent and
shall chair the Committee”.
The Remuneration Committee is made up of Jose Ramon Alegre (Chairman), Antoinette
Caruana and John Cassar White. The composition has seen a reshuffle relative to the previous
year, to utilize the expertise of Antoinette Caruana in associated matters as well as to ensure
independence and objectivity in the functioning of the Committee, while decisions continue
to be passed with the consensus of all members present.
The fact that decisions are taken by the unanimous agreement of all members present also
implies that the final outcome of discussions and decisions taken by the Remuneration
Committee are not affected by the director holding the Chair even though the Committee is
not chaired by an independent non-executive Director.Committee document packs are also
circulated to all Members well in advance of the meeting allowing all Members ample
opportunity to informally discuss any matters in anticipation of the Meeting and / or to
represent their views.
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 at this stage.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
29
Corporate Governance Statement - continued
3.Non-compliance with the code - continued
Principle 9 – Relations with Shareholders and with the Market
Code Provision 9.3 requires the Company to have in place a mechanism to resolve conflicts
between minority shareholders and controlling shareholders
The balance between the interests of all shareholders is a matter that is kept under continuous
review by the Board and is consistently evaluated in the interest of all shareholders.
Therefore, 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 to this
end. The Company also has a good relationship with the Malta Association for Small
Shareholders and the Board maintains an open door policy with them, as well as with any
individual shareholders who may be interested in making direct submissions to the Company,
at all times 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.
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 Group’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.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
30
Corporate Governance Statement - continued
Internal Control and Risk Management System - continued
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 would be 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, statements of financial position and reports of
the directors and auditors, the election of directors, the appointment of the auditors and the
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.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
31
Corporate Governance Statement - continued
General Meetings - continued
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 view of the pandemic environment in 2021, particularly bearing in mind health and safety
aspects and the restrictions in place, the AGM was held remotely on 30 April 2021 in
accordance with Legal Notice 288 of 2020 and live streamed.
Signed by Martin Galea (Chairman) and Antoinette Caruana (Director) on the 23 March
2022
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
32
Remuneration Statement and Report of the Remuneration Committee to
the Shareholders
1.Terms of Reference and Membership
The MAPFRE Middlesea p.l.c. (“MMS”) Remuneration Committee (the “Committee”)
hereby submits its Remuneration Statement to the shareholders 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 Committee’s main task 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 2021 the Committee Members were Jose Ramon Alegre (Chairman), Martin
Galea and Taddeo Scerri. Jose Ramon Alegre was appointed as of 1 January 2021 in lieu of
Jaime Tamayo who tendered his resignation from the MMS Board of Directors, and
consequently from the MMS Remuneration Committee, as of the same date in order to take
up other responsibilities within the MAPFRE International Group. Thereafter, at the Annual
General Meeting of the Company held on 30 April 2021, Jose Ramon Alegre (Chairman),
Antoinette Caruana and John Cassar White were appointed as the members of the
Remuneration Committee.
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 & CEO, Javier
Moreno, the MAPFRE MSV Life p.l.c (MMSV) CEO, Etienne Sciberras and other members
of senior management were invited to attend Committee meetings 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 chairs the
Committee. The Committee takes decisions by the unanimous agreement of its Members.
Therefore, even though the Committee is not chaired by an independent non-Executive
Director, the Director chairing the Committee is non-Executive and his vote does not sway
the outcome of discussions and decisions taken by the Committee.
2.Meetings
The Remuneration Committee held three meetings during the period under review and the
attendance was as follows:-
MemberAttended
Jose Ramon Alegre (Chairman)                                                  2
Antoinette Caruana (Member as from 30 April 2021)                1
John Cassar White (Member as from 30 April 2021)                  1
Martin Galea (Member until 30 April 2021)                                2
Taddeo Scerri (Member until 30 April 2021)                              2
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
33
Remuneration Statement and Report of the Remuneration Committee to
the Shareholders - continued
2.Meetings - continued
The Committee determined and/or discussed the following matters:
Succession Planning;
New Senior Management Appointments;
HR Reports;
Remuneration for Directors, CEO and Senior Management for 2021;
2021 Variable remuneration framework;
Remuneration Statement for the Annual Report
3.    Remuneration Statement
a.Remuneration Policy - Senior Management
The MMS Remuneration Policy framework is set by the Board of Directors acting through
the Remuneration Committee and is based on the guidelines and principles contained within
the MAPFRE Group Compensation (Remuneration) Policy which was approved by the
majority of shareholders during the Annual General Meeting held on 27 October 2020.
The Committee reviews and approves the individual remuneration arrangements for Senior
Management, namely, the President & CEO, Chief Financial Officer, Company Secretary,
Chief Officers and the Internal Auditor. 
The Committee has access to both internal and independent external advice on remuneration
matters as and when required.
The Committee deems the current Senior Management remuneration packages to be in line
with 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.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
34
Remuneration Statement and Report of the Remuneration Committee to
the Shareholders - continued
3.Remuneration Statement - continued
a.Remuneration Policy – Senior Management - continued
The performance appraisal system underpinning the Company’s remuneration structure was 
implemented in 2013 and the performance bonus scheme implemented in 2014. The latter
was further enhanced in 2015 and both remain in place. 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. 
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
bonus set out hereunder.
The MMS President & 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.
Senior Management are eligible for a performance bonus calculated in accordance with the
percentage achievement of the Group and Departmental objectives as per the performance
bonus scheme aforementioned which 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.
Both in the case of the MMS President & 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 2021 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.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
35
Remuneration Statement and Report of the Remuneration Committee to
the shareholders - continued
3.Remuneration Statement – continued
b.Remuneration Policy – Directors
As at 31 December 2021, the Board of Directors of MAPFRE Middlesea p.l.c. was composed
of nine non-Executive directors.  Three Directors, namely Jose Ramon Alegre, 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.
David G. Curmi, who was the tenth Director of the Company, resigned from his position as
the CEO of MAPFRE MSV Life p.l.c. (a subsidiary of MMS) and consequently from his
position as Director of the Company with effect from 31 January 2021 and was not replaced.
Mr Curmi did not receive a fee for his service given his then employment within the
MAPFRE Group as detailed below.
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
Chairman60,000 per annum (2020: €60,000)
Other Directors (per Director)40,000 per annum (2020: €40,000)
Audit Committee Fees
Chairman5,000 per annum (2020: €5,000)
Member (per member)3,000 per annum (2020: €3,000)
Subsidiary Fees
Chairman5,000 per annum (2020: €5,000)
Member (per member)3,000 per annum (2020: €3,000)
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 or any
other remuneration.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
36
Remuneration Statement and Report of the Remuneration Committee to
the Shareholders - continued
3.Remuneration Statement – continued
c.Code Provision 8.A.5
Directors' Emoluments 2021
Fixed Remuneration
Variable Remuneration
Share Options
Others
283,500
None
None
None
Fees payable to directors in respect of 2021 amounted in total to €283,500(2020: €279,000).
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 fortieth Annual General Meeting
held on the 30 April 2021, 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:
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
37
Remuneration Statement and Report of the Remuneration Committee to
the Shareholders - continued
3.Remuneration Statement – continued
d.Code Provision 12.26K - continued
Director
2021 Fees
2020 Fees
Percentage Annual
Change of Remuneration
(2020-2021)
%
Alfred Attard (NED until 30 April 2021)*
15,000
45,000
0.00**
Antoinette Caruana (NED)
43,000
43,000
0.00
John Cassar White (NED from 30 April 2021)***
34,167
nil
n/a
David G. Curmi (NED until 31 January 2021)
nil
nil
n/a
Martin Galea (NED) ***
69,333
68,000
1.96
Jose Luis Jimenez (NED)
nil
nil
n/a
Taddeo Scerri (NED)*
42,000
40,000
5.00
Paul Testaferrata Moroni Viani (NED)***
40,000
43,000
-6.98
Joseph F.X. Zahra (NED)
40,000
40,000
0.00
Jose Maria del Pozo (NED from 15 July 2020)
nil
nil
n/a
Total
283,500
279,000
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 President & CEO against company
performance metrics and percentage annual change of the Company’s employees’ average
remuneration employed on a full-time basis equivalent.
* In the case of Mr Alfred Attard  €7,917 of the amount (2020: €25,000) was paid to Bank of
Valletta p.l.c as Mr Attard’s employer based on a separate agreement for services rendered.
In the case of Mr Taddeo Scerri €7,500 of the 2020 amount was paid to Bank of Valletta
p.l.c. ‘pro-rata’ as Mr Scerri’s employer until 15 May 2020 based on a separate agreement
for services rendered;
** Percentage annual change of remuneration (2020-2021) was based on annualised
remuneration for 2021 to allow for a meaningful comparison.
*** amount includes €7,500 paid to John Cassar White  for his position as Chairman of the
subsidiary Board till 31 March 2021;
€5,000 (2020: €5,000) were paid to Martin Galea for the position as Chairman of the
subsidiary’s Audit Committee and;
€3,000 were paid to Paul Testaferrata Moroni Viani in 2020 for being a member of the
subsidiary’s Investment Committee.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
38
Remuneration Statement and Report of the Remuneration Committee to
the Shareholders - continued
3.Remuneration Statement – continued
d.Code Provision 12.26K - continued
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 two Chief Executive Officers in office during Financial Year 2021 were as follows:
President & CEO
Financial
Year
Fixed
Salary
Fringe
benefits
Total Fixed
remuneration
Variable
remuneration
Total
remuneration €
Fixed  Variable
Proportion
%
Felipe Navarro
Lopez de
Chicheri
2021
49,654
67,962
117,616
57,767
175,383
67%-33%
2020
198,615
212,383
410,998
224,231
635,229
65%-35%
Javier Moreno
Gonzalez
2021
135,000
114,637
249,637
97,817
347,454
72%-28%
Felipe Navarro Lopez de Chicheri terminated his appointment as President & CEO on the 31
March 2021 and was replaced by Javier Moreno as from the 1 April 2021.
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 2021.
Variable remuneration for the President & 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.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
39
Remuneration Statement and Report of the Remuneration Committee to
the Shareholders - continued
3.Remuneration Statement – continued
d.Code Provision 12.26K - continued
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 President & CEO, of the
Company’s performance, and of average remuneration on a full-time equivalent basis of the
Company’s employees over the two most recent financial years:
Percentage annual
change of the
remuneration of the
President & CEO *
(2020-2021)
%
Percentage annual
change of the
Company's
performance - Profit
after tax ** (2020-2021)
%
Percentage annual
change of the
Company's
performance - Gross
premiums written
(2020-2021)
%
Percentage annual
change in Employee's
Average
Remuneration in
Company's employees
on a full-time
equivalent basis
(2020-2021)
%
Percentage annual change
in Employees' Average
Remuneration in Group's
employees on a full-time
equivalent basis
(2020-2021)
%
1.9%
-36.6%
6.6%
6.44%
5.54%
* The percentage increase relates only to Felipe Navarro Lopez de Chicheri being the
President & CEO employed in both years being compared. For comparison purpose, since
Felipe Navarro Lopez de Chicheri’s appointment ended on 31 March 2021, his 2021
remuneration has been annualized.
** The reduction arose from 2020 being favourably impacted by the onset of the pandemic
which had resulted in significantly lower claims particularly in Motor and Health both in
frequency and severity.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
40
Remuneration Statement and Report of the Remuneration Committee to
the Shareholders - continued
3.Remuneration Statement – continued
d.Code Provision 12.26K - continued
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 23
March 2022
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
41
Statement of profit or loss
Technical account - general business
Year ended 31
December
Group and Company
2021
2020
Notes
€’000
€’000
Earned premiums, net of reinsurance
Gross premiums written
6
77,613
72,611
Outward reinsurance premiums
(15,350)
(15,035)
Net premiums written
62,263
57,576
Change in gross provision for unearned
premiums
(2,979)
(464)
Change in the provision for unearned
premiums, reinsurers' share
1,434
326
(1,545)
(138)
Earned premiums, net of reinsurance
60,718
57,438
Allocated investment return transferred
from the non-technical account
  8
307
(58)
Total technical income
61,025
57,380
Claims incurred, net of reinsurance
Claims paid
  -  gross amount
37,134
38,247
  -  reinsurers' share
(5,524)
(5,619)
31,610
32,628
Change in the provision for claims
  -  gross amount
2,964
(1,816)
  -  reinsurers' share
313
(967)
3,277
(2,783)
Claims incurred, net of reinsurance
34,887
29,845
Net operating expenses
7
20,878
19,603
Total technical charges
55,765
49,448
Balance on the technical account for
general business (page 44)
5,260
7,932
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
42
Statement of profit or loss
Technical account - long term business
Year ended 31 December
Group
Company
2021
2020
2021
2020
Notes
€’000
€’000
€’000
€’000
Earned premiums, net of reinsurance
Gross premiums written
6
327,632
272,091
2,497
2,509
Outwards reinsurance premiums
(3,390)
(4,010)
(211)
(355)
Earned premiums, net of reinsurance
324,242
268,081
2,286
2,154
Investment return
Return from investments
8
97,458
62,497
(11)
(28)
Other technical income, net of reinsurance
9
788
707
Total technical income
422,488
331,285
2,275
2,126
Claims incurred, net of reinsurance
Claims paid
  -  gross amount
305,907
251,462
1,250
1,207
  -  reinsurers' share
(1,859)
(1,436)
(122)
(349)
304,048
250,026
1,128
858
Change in the provision for claims
  -  gross amount
2,339
12,401
(143)
316
  -  reinsurers' share
(319)
(118)
113
(60)
2,020
12,283
(30)
256
Claims incurred, net of reinsurance
306,068
262,309
1,098
1,114
Change in other technical provisions, net
of reinsurance
Long term business provision  -  gross
(24,367)
(26,450)
(67)
142
Investments contracts with DPF - gross
103,203
61,259
78,836
34,809
(67)
142
Net operating expenses
7
18,572
18,814
328
375
Total technical charges
403,476
315,932
1,359
1,631
Balance on the technical account for long
term business (page 44)
19,012
15,353
916
495
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
43
Statement of profit or loss
Non-technical account
Year ended 31 December
Group
Company
2021
2020
2021
2020
Notes
€’000
€’000
€’000
€’000
Balances on technical accounts
General business (page 42)
5,260
7,932
5,260
7,932
Long term business (page 43)
19,012
15,353
916
495
Total income from insurance activities
24,272
23,285
6,176
8,427
Other investment income
8
956
1,319
1,107
1,153
Investment expenses and charges
8
(675)
(1,143)
(659)
(1,075)
Allocated investment return transferred
to the general business technical account
8
(307)
58
(307)
58
Revaluation loss on property
18
(1,521)
Other income
9
1,438
1,296
Administrative expenses
7
(3,773)
(3,624)
(2,254)
(2,175)
Profit for the financial year before tax
20,390
21,191
4,063
6,388
Tax expense
12
(7,467)
(6,905)
(1,455)
(2,271)
Profit for the financial year
12,923
14,286
2,608
4,117
Attributable to:
-  owners of the Company
7,643
9,123
2,608
4,117
-  non-controlling interests
5,280
5,163
12,923
14,286
2,608
4,117
Earnings per share attributable to owners
of the Company
14
0.083
0.099
The Notes on pages 52 to 176 are an integral part of these financial statements.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
44
Statement of comprehensive income
Year ended 31 December
Group
Company
2021
2020
2021
2020
Notes
€’000
€’000
€’000
€’000
Profit for the financial year
12,923
14,286
2,608
4,117
Other comprehensive income:
Items that are or may be reclassified
  subsequently to profit or loss
Change in fair value of available-for-sale
  investments
29
53
(216)
51
(211)
Available-for-sale investments reclassified to
  profit or loss
29
(102)
333
(102)
333
Revaluation gain on
  freehold land and buildings
18
1,081
Items that will not be reclassified  to
  profit or loss
Re-measurement actuarial gain/(loss) on
  provision for other liabilities and charges
2
(8)
2
(8)
Increase in value of in-force business
16
9,912
3,698
Total other comprehensive income, net of tax
10,946
3,807
(49)
114
Total comprehensive income for the year
23,869
18,093
2,559
4,231
Attributable to:
- owners of the Company
13,633
11,081
- non-controlling interests
10,236
7,012
Total comprehensive income for the year
23,869
18,093
Items disclosed in the statement above are disclosed net of tax.
The Notes on pages 52 to 176 are an integral part of these financial statements.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
45
Statement of financial position
At 31 December
Notes
Group
Company
2021
2020
2021
2020
€’000
€’000
€’000
€’000
ASSETS
Intangible assets
16
109,729
94,836
9,146
7,762
Property, plant and equipment
18
17,657
17,913
4,542
2,252
Right-of-use assets
17
1,802
931
1,685
766
Investment property
19
110,016
111,518
13,529
16,205
Investment in subsidiary undertakings
20
77,214
57,214
Investment in associated undertakings
21
22,831
25,174
383
385
Other investments
22
2,421,911
2,262,757
8,382
5,354
Deferred income tax
23
2,313
2,350
1,268
1,332
Reinsurers' share of technical provisions
24
33,247
31,807
32,314
31,306
Deferred acquisition costs
25
8,427
8,080
8,427
8,080
Insurance and other receivables
26
32,069
33,828
19,222
19,584
Income tax receivable
308
1,174
Cash and cash equivalents
27
71,443
97,060
11,575
31,432
Total assets
2,831,753
2,687,428
187,687
181,672
EQUITY
Capital and reserves attributable to owners of
the Company
Share capital
28
19,320
19,320
19,320
19,320
Share premium account
688
688
688
688
Other reserves
29
44,817
38,829
34,935
34,986
Retained earnings
46,211
41,766
21,468
22,058
111,036
100,603
76,411
77,052
Non-Controlling Interest
110,932
80,696
Total equity
221,968
181,299
76,411
77,052
LIABILITIES
Deferrred income tax
23
42,599
37,467
1,989
2,230
Provision for other liabilities and charges
30
997
1,057
997
1,057
Technical provisions
-  Insurance contracts and investment contracts
with DPF
24
2,470,668
2,383,550
93,005
87,272
- investment contracts without DPF
24
60,869
53,531
Derivative financial instruments
22
775
168
Lease liabilities
1,866
1,021
1,745
849
Insurance and other payables
31
31,173
27,491
13,401
11,975
Income tax payable
838
1,844
139
1,237
Total liabilities
2,609,785
2,506,129
111,276
104,620
Total equity and liabilities
2,831,753
2,687,428
187,687
181,672
The Notes are an integral part of these financial statements.
These financial statements on pages 42 to 176 were approved by the Board of Directors and authorised for issue on  23
March 2022 and signed on its behalf by Martin Galea (Chairman) and Taddeo Scerri (Director) as per the Directors'
Declaration on ESEF Annual Financial report submitted in conjunction with the Annual Report 2021.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
46
Statement of changes in equity
Group
Attributable to owners of the Company
Share
Non-
Share
premium
Other
Retained
controll-
ing
Total
capital
account
reserves
earnings
Total
interests
equity
Notes
€’000
€’000
€’000
€’000
€’000
€’000
€’000
Balance as at 1 January
2020
19,320
688
36,863
32,634
89,505
73,684
163,189
Comprehensive income
Profit for the financial year
9,123
9,123
5,163
14,286
Other comprehensive
  income:
Change in
  available-for- sale
  investment's fair value
29
(216)
(216)
(216)
Available-for-sale
  investments re-classified
  to profit or loss
29
333
333
333
Re-measurement actuarial
  loss on provision for other
  liabilities and charges
(8)
(8)
(8)
Increase in value of
  in-force business
16
1,849
1,849
1,849
3,698
Total other comprehensive
  income, net of tax
1,966
(8)
1,958
1,849
3,807
Total comprehensive
  income
1,966
9,115
11,081
7,012
18,093
Transactions with owners
Write-back of prior year
  dividends
17
17
17
Total transactions with
  owners
17
17
17
Balance at 31 December
  2020
19,320
688
38,829
41,766
100,603
80,696
181,299
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
47
Statement of changes in equity - continued
Group - continued
Attributable to owners of the Company
Share
Non-
Share
premium
Other
Retained
controll-
ing
Total
capital
account
reserves
earnings
Total
interests
equity
Notes
€’000
€’000
€’000
€’000
€’000
€’000
€’000
Balance at 1 January 2021
19,320
688
38,829
41,766
100,603
80,696
181,299
Comprehensive income
Profit for the financial year
7,643
7,643
5,280
12,923
Other comprehensive
  income:
Change in available-for-
  sale investments' fair
  value
29
53
53
53
Available-for-sale
  investments- reclassified
  to  profit or loss
29
(102)
(102)
(102)
Revaluation gain on
  freehold land and
  buildings
18
1,081
1,081
1,081
Re-measurement actuarial
  gain on provision for
  other liabilities and
  charges
2
2
2
Increase in value of
  in-force business
16
4,956
4,956
4,956
9,912
Total other comprehensive
  income, net of tax
5,988
2
5,990
4,956
10,946
Total comprehensive
  income
5,988
7,645
13,633
10,236
23,869
Transactions with owners
Increase in share capital of
  group undertaking
20,000
20,000
Dividend for 2020
(3,200)
(3,200)
(3,200)
Total transactions with
  owners
(3,200)
(3,200)
20,000
16,800
Balance at 31 December
  2021
19,320
688
44,817
46,211
111,036
110,932
221,968
The Notes on pages 52 to 176 are an integral part of these financial statements.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
48
Statement of changes in equity - continued
Company
Share
Share
premium
Other
Retained
capital
account
reserves
earnings
Total
Notes
€’000
€’000
€’000
€’000
€’000
Balance at 1 January 2020
19,320
688
34,864
17,932
72,804
Comprehensive income
Profit for the financial year
4,117
4,117
Other comprehensive income:
Change in available-for-sale
  investments' fair value
29
(211)
(211)
Available-for-sale
  investments- reclassified to profit
  or loss
29
333
333
Re-measurement actuarial loss on
  provision for other liabilities and
  charges
(8)
(8)
Total other comprehensive income,
  net of tax
122
(8)
114
Total comprehensive income
122
4,109
4,231
Transactions with owners
Write-back of prior years' dividends
17
17
Total transactions with owners of
  the Company
17
17
Balance at 31 December 2020
19,320
688
34,986
22,058
77,052
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
49
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 at 1 January 2021
19,320
688
34,986
22,058
77,052
Comprehensive income
Profit for the financial year
2,608
2,608
Other comprehensive income:
Change in available-for-sale
  investments' fair value
29
51
51
Available-for-sale investments-
  reclassified to profit or loss
29
(102)
(102)
Re-measurement actuarial gain on
  provision for other liabilities and
charges
2
2
Total other comprehensive income, net
  of tax
(51)
2
(49)
Total comprehensive income
(51)
2,610
2,559
Transactions with owners
Dividend for 2020
(3,200)
(3,200)
Total transactions with owners of the
  Company
(3,200)
(3,200)
Balance as at 31 December 2021
19,320
688
34,935
21,468
76,411
The Notes on pages 52 to 176 are an integral part of these financial statements.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
50
Statement of cash flows
Year ended 31 December
Group
Company
2021
2020
2021
2020
Notes
€’000
€’000
€’000
€’000
Cash flows from operating activities
Cash generated from operations
32
9,360
8,098
12,414
4,458
Dividends received
9,572
6,693
168
179
Interest received
21,296
19,636
96
223
Interest paid
(66)
(135)
(66)
(135)
Income tax paid
(2,501)
(1,130)
(2,742)
(1,309)
Net cash generated from operating activities
37,661
33,162
9,870
3,416
Cash flows from investing activities
Purchase of investment property
19
(1,627)
(2,059)
(4)
(6)
Disposal of investment property
16
93
16
93
Increase in investment in group undertaking
(20,000)
Purchase of financial investments
(1,382,857)
(1,870,200)
(5,131)
Disposal of financial investments
1,312,522
1,873,696
2,116
3,778
Purchase of property, plant and equipment and
  intangible assets
(8,227)
(8,731)
(3,524)
(3,006)
Disposal of property, plant and equipment and
  intangible assets
95
95
95
Net cash (used in)/ generated from investing
activities
(80,078)
(7,106)
(26,527)
954
Cash flows from financing activities
Increase in share capital of group undertaking
20,000
Dividends (paid)/ cancelled  to owners of the
Company
(3,200)
17
(3,200)
17
Cash generated from/ (used in) financing
activities
16,800
17
(3,200)
17
Net movement in cash and cash equivalents
(25,617)
26,073
(19,857)
4,387
Cash and cash equivalents at beginning of year
97,060
70,987
31,432
27,045
Cash and cash equivalents at end of year
27
71,443
97,060
11,575
31,432
The Notes on pages 52 to 176 are an integral part of these financial statements.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
51
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 1606/2002/EC (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 measurement at fair value of: investment property, financial assets and
financial liabilities (including derivatives) at fair value through profit or loss, and
available-for-sale investments. Investment in associated undertaking is measured
using equity method, that is, cost plus or minus net income or loss of associate.
As permitted by IFRS 4 'Insurance Contracts' the Group continues to apply existing
accounting practices for value of in-force business, insurance and participating
investment contracts, modified as appropriate to comply with the IFRS framework
and applicable standards.  Further details are given in the respective accounting
policies.
The preparation of financial statements in conformity with the above reporting
framework requires the use of certain 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 statements of financial position are 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.
Standards, interpretations and amendments to published standards effective in 2021
In 2021, the Group adopted new standards, amendments and interpretations to
existing standards that are mandatory for the Group’s accounting period beginning on
1 January 2021.  The adoption of these revisions to the requirements of IFRSs as
adopted by the EU did not result in substantial changes to the Group’s accounting
policies.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
52
1.Basis of preparation - continued
Standards, interpretations and amendments to published standards effective before
2021 for which the Group elected for the temporary exemption
IFRS 9 - ‘Financial instruments’
IFRS 9, ‘Financial instruments’, addresses the classification, measurement and
recognition of financial assets and financial liabilities. It replaces the guidance in IAS
39 that relates to the classification and measurement of financial instruments.  IFRS 9
retains but simplifies the mixed measurement model and establishes three primary
measurement categories for financial assets: amortised cost, fair value through other
comprehensive income and fair value through profit or loss. The basis of classification
depends on the entity’s business model and the contractual cash flow characteristics of
the financial asset. Investments in equity instruments are required to be measured at fair
value through profit or loss with the irrevocable option at inception to present changes
in fair value in OCI not recycling.
The new expected credit losses model replaces the incurred loss impairment model
used in IAS 39. For financial liabilities there were no changes to classification and
measurement except for the recognition of changes in own credit risk in other
comprehensive income, for liabilities designated at fair value through profit or loss. The
Group is considering the implications of the standard and its impact on the financial
results and position once adopted.  For those assets which are not measured at fair value
through profit or loss, the Group is assessing the impact of the new impairment model
introduced by the standard. As at the time of issue of these financial statements, the
impact is not yet known or reasonably estimable.
IFRS 9 became effective for years beginning on or after 1 January 2018. However in
September 2016, the International Accounting Standards Board issued amendments to
IFRS 4 which provide optional relief to eligible insurers in respect of IFRS 9. The
options permit entities whose predominant activity is issuing insurance contracts within
the scope of IFRS 4, a temporary exemption to defer the implementation of IFRS 9.
Entities that apply the optional temporary relief were initially required to adopt IFRS 9
on annual periods beginning on or after 1 January 2021. However, on 14 November
2018 and subsequently on 17 March 2021, the IASB deferred both the effective date of
IFRS 17, ‘Insurance Contracts’, and the expiry date for the optional relief in respect of
IFRS 9 to 1 January 2022 and subsequently by another year. Therefore, entities that
apply the optional temporary relief will be required to adopt IFRS 9 on 1 January 2023
which aligns with the new effective date of IFRS 17.
The Group evaluated its liabilities at 31 December 2015, the prescribed date of
assessment under the optional temporary relief provisions and concluded that all of the
liabilities are predominantly connected with insurance. More than 90% of the Group’s
liabilities at 31 December 2015 are liabilities arising from contracts within the scope of
IFRS 4. As at the same date the Company’s predominant activities were also
established to be insurance related as evidenced through revenues reported in the
Annual Report of that year.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
53
1.Basis of preparation - continued
Standards, interpretations and amendments to published standards effective before
2021 for which the Group elected for the temporary exemption  - continued
Further to the above, the Group has not previously applied IFRS 9. Therefore the Group
is an eligible insurer that qualifies for optional relief from the application of IFRS 9.
As at 1 January 2018, the Group has elected to apply the optional temporary relief
under IFRS 4 that permits the deferral of the adoption of IFRS 9 for eligible insurers.
The Group will continue to apply IAS 39 until the financial reporting period ending 31
December 2022.
However, the subsidiaries and associates of the Group, not having their activities
predominantly in insurance, have applied IFRS 9 from 1 January 2018.  The
subsidiaries disclose references to IFRS 9 information that is not provided in the
consolidated financial statements, but is publicly available for the relevant period in the
individual financial statements of the subsidiaries or associates.
Standards, interpretations and amendments to published standards that are not yet
effective
Certain new standards, amendments and interpretations to existing standards have been
published by the date of authorisation for issue of these financial statements but are
mandatory for the Group’s accounting periods beginning after 1 January 2021. The
Group has not early adopted these revisions to the requirements of IFRSs as adopted by
the EU and the Group’s directors are of the opinion that, with the exception of the
standards discussed below, there are no requirements that are expected to have a
significant impact on the Group’s financial statements in the period of initial
application.
IFRS 17 - ‘Insurance Contracts’
From 1 January 2023, IFRS 17 will replace the current standard IFRS 4, fundamentally
changing the accounting and reporting practices for insurance companies.
IFRS 17, ‘Insurance Contracts’, establishes principles for the recognition,
measurement, presentation and disclosure of insurance contracts, reinsurance contracts
and investment contracts with discretionary participation features. It introduces a model
that measures groups of contracts based on the Group’s estimates of the present value
of future cash flows that are expected to arise as the Group fulfills the contracts, an
explicit risk adjustment for non-financial risk and a Contractual Service Margin. In
addition, a simplified measurement approach is permitted for short-duration contracts in
which the coverage period is approximately one year or less.
The Group is considering the implications of the standard and its impact on the Group’s
financial results and position. The quantitative impact that the application of the new
IFRS will have on the Group’s financial statements in the period of initial application is
not known or reasonably estimable.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
54
2.Accounting policies
The principal accounting policies adopted in the preparation of these 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 (or group) 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
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.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
55
2.Accounting policies - continued
2.1Consolidation – continued
(a)Subsidiary undertakings - continued
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 statements 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
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.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
56
2.Accounting policies - continued
2.1Consolidation - continued
(b)Associated undertakings - continued
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 is also guided by the Regulations under the
Insurance Business Act, 1998 (“Insurance Regulations”) on the disclosure requirements
relevant to specified 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 foreign exchange gains and losses that relate to net claims incurred are presented in
the technical profit or loss account within ‘claims incurred’. All other foreign exchange
gains and losses are presented in the profit or loss account within ‘investment income’
or ‘investment expense’.
Translation differences on non-monetary items held at fair value through profit or loss,
are reported as part of the fair value gain or loss in the profit or loss.  Translation
differences on non-monetary financial assets, such as equities classified as other
available-for-sale financial assets, are included in the fair value reserve in other
comprehensive income.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
57
2.Accounting policies - continued
2.4Intangible assets
Value of in-force business
The value of in-force business is determined by the directors after considering the
advice of the Group’s Approved Actuary. The valuation represents the discounted value
of projected future transfers to shareholders from contracts in force at the year end, after
making a provision for taxation.  In determining this valuation, assumptions relating to
future mortality, persistence and levels of expenses are based on experience of the type
of business concerned.
Gross investment returns and asset allocations assumed vary depending upon the mix of
investments held by the Group and expected market conditions.  Annual movements in
the value of the in-force business are credited or debited to other comprehensive
income. Note 16 contains further information in relation to this asset.
Value of business acquired
The value of business acquired is amortised using the straight-line method over a period
not exceeding five years.  The carrying value is assessed yearly for impairment by
projecting the profitability of the portfolio acquired over the life of the asset having
considered projected combined ratios and retention patterns.
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.
Deferred policy acquisition costs – long term contracts
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 useful life of the contract. This basis is reviewed periodically with
reference to the historical experience of surrenders for these contracts.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
58
2.Accounting policies - continued
2.5Property, plant and equipment
All property, plant and equipment is initially recorded at historical cost. Freehold land
and buildings are subsequently shown at fair value based on periodic valuations by
external independent valuers, less subsequent depreciation for buildings. Valuations are
carried out on a regular basis such 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 re-
valued 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.
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 2.10).
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
59
2.Accounting policies - continued
2.5Property, plant and equipment - continued
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.
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.  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 prepared annually by a qualified valuation expert.  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
investment expense or income.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
60
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 assets
The Group classifies its financial assets (other than its investment in subsidiaries) into
the following categories: financial assets at fair value through profit or loss, other
available-for-sale investments and loans and receivables. The directors determine the
appropriate classification of financial assets at the time of purchase and re-evaluate such
designation at every reporting date.
Classification
Financial assets at fair value through profit or loss are part of a group of
investments that is managed on a portfolio basis and whose performance is
evaluated and reported internally on a fair value basis to the Board and relevant
key management personnel in accordance with a documented investment strategy.
Assets that are part of these portfolios are designated upon initial recognition at fair
value through profit or loss. Financial assets that are held to match insurance and
investment contracts liabilities are also designated at inception as fair value
through profit or loss to eliminate or significantly reduce the accounting mismatch
that would otherwise arise from measuring insurance assets or liabilities, or
recognising the gains and losses on them on different basis.  Derivatives are also
classified at fair value through profit or loss. 
Loans and receivables are non-derivative financial assets with fixed or
determinable payments that are not quoted in an active market, other than those
that the Group has designated at fair value through profit or loss.  They include,
inter alia, reinsurers’ share of technical provisions, insurance and other
receivables, cash and cash equivalents in the statements of financial positions as
well as other financial investments (comprising deposits with credit institutions,
and loans) classified as loans and receivables within Note 22.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
61
2.Accounting policies - continued
2.9Financial assets - continued
Classification - continued
Available-for-sale investments are those non-derivative financial assets that are
designated as available-for-sale or are not classified as (a) loans and receivables,
(b) held-to-maturity or (c) financial assets at fair value through profit or loss. 
Recognition and measurement
All purchases and sales of investments are recognised on the trade date, which is the
date that the Group commits to purchase or sell the assets.  All investments are initially
recognised at fair value plus, in the case of all financial assets not carried at fair value
through profit or loss, transaction costs that are directly attributable to their acquisition. 
Financial assets are de-recognised when the rights to receive cash flows from them
have expired or where they have been transferred and the Group has also transferred
substantially all risks and rewards of ownership.
Financial assets at fair value through profit or loss and other available-for-sale
investments are subsequently re-measured at fair value. Loans and receivables are
carried at amortised cost using the effective interest method, less any provision for
impairment.
Realised and unrealised gains and losses arising from changes in the value of the
‘financial assets at fair value through profit or loss’ category are presented in the profit
or loss account in the period in which they arise.
Changes in the fair value of monetary and non-monetary securities classified as
available-for-sale are recognised in other comprehensive income. When securities
classified as available-for-sale are sold or impaired, the accumulated fair value
adjustments recognised in other comprehensive income are included in the profit or loss
account within investment income.
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. 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 and discounted cash flow analysis. 
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2.Accounting policies - continued
2.9Financial assets - continued
Recognition and measurement - continued
Derivatives are recognised at fair value on the date on which a derivative contract is
entered into and are subsequently re-measured at their fair value. 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 the profit or loss account.  All derivatives are carried as
assets when fair value is positive, and as liabilities when fair value is negative.
The Group enters into currency forward contracts to hedge the foreign exchange risk
arising on its investments denominated in a foreign currency. These transactions
provide effective economic hedges under the Group’s risk management policies. 
However, hedge accounting under the specific rules in IAS 39 is not required because
the change in the value of the hedged financial instrument is recognised in the profit or
loss account.
2.10Impairment of assets
(a)Impairment of financial assets at amortised cost
The Group assesses at the end of each reporting period whether there is objective
evidence that a financial asset or group of financial assets is impaired.  A financial asset
or group of financial assets is impaired and impairment losses are incurred only if there
is objective evidence of impairment as a result of one or more events that have occurred
after the initial recognition of the asset (“a loss event”) and that loss event (or events)
has an impact on the estimated future cash flows of the financial asset or group of
financial assets that can be reliably estimated.
Objective evidence that a financial asset or group of assets is impaired includes
observable data that comes to the attention of the Group about the following events:
i.significant financial difficulty of the issuer or debtor;
ii.a breach of contract, such as a default or delinquency in payments;
iii.it becoming probable that the issuer or debtor will enter bankruptcy or other
financial reorganisation;
iv.the disappearance of an active market for that financial asset because of
financial difficulties; or
v.observable data indicating that there is a measurable decrease in the estimated
future cash flow from a group of financial assets since the initial recognition
of those assets, although the decrease cannot yet be identified with the
individual financial assets in the Group.
MAPFRE MIDDLESEA p.l.c.
Annual Report - 31 December 2021
63