Insurance has always been a data business. The entire model rests on the ability to
price risk accurately — to look at what you know about a counterparty and make a
defensible judgement about the likelihood and cost of something going wrong. For most
of the industry’s history, that meant financial data, claims history and actuarial tables.
That is no longer sufficient.
Insurers and reinsurers are now expected to factor sustainability and climate risk into
underwriting decisions, solvency assessments and regulatory disclosures. Frameworks
like SFDR, TNFD and ORSA are creating structured obligations around non-financial risk
that didn’t exist a decade ago. The question being asked — by regulators, by capital
markets, by internal risk committees — is a straightforward one: do you actually
understand the sustainability and resilience profile of the companies you’re insuring?
For most insurers, the honest answer is no. Not because they haven’t tried, but
because the information simply hasn’t existed in a usable form.
The companies that sit at the heart of this problem are private companies and SMEs —
the businesses that make up the bulk of commercial insurance portfolios but do not
publish structured non-financial data. Unlike large listed firms, they don’t publish
sustainability reports or emissions disclosures. What insurers typically collect comes
through proposals, renewals and periodic reviews — inconsistent, non-comparable,
and almost impossible to aggregate into a portfolio-level risk view. Traditional
sustainability data, where it exists at all, tends to be survey-driven, misaligned to
material underwriting factors, and not structured in a way that supports benchmarking
or defensible modelling.
This leaves underwriting decisions exposed to uncertainty and regulatory gaps that are
only going to widen as disclosure expectations increase.
TDH’s M3 framework was built specifically to fill this gap — without relying on the
companies themselves to provide the data.
Rather than sending yet another questionnaire into the market, TDH uses scalable,
automated analysis of public disclosures: company websites, sustainability reports,
policy documents, financial filings and certifications. This is assessed against M3, a
120-metric framework aligned with international sustainability standards and
structured across 11 sectors and 77 industries using SASB classification. Every
company in scope receives a score benchmarked against its sector, industry and
revenue peer group, with topic-level breakdowns that surface where the risk
concentration actually sits.
For underwriting teams, this means non-financial risk data that is consistent,
comparable and actually built around material factors — not a self-reported survey that
answers different questions for every respondent. For portfolio and capital
management, it means the ability to benchmark exposures across thousands of
insured counterparties with the same framework applied to all of them. For compliance
and ORSA reporting, it means a defensible, auditable data foundation rather than a
patchwork of manually assembled inputs.
The pressure on insurers to price non-financial risk properly is not easing. What has
been missing is not the intent but the data infrastructure to act on it. M3 provides that
infrastructure — at the scale the insurance market actually operates at.
