Aspen Modern Slavery Act Statement

This statement is published in accordance with the UK’s Modern Slavery Act 2015 (“the Act”). It sets out the steps taken by Aspen Insurance UK Limited and other relevant group companies [1] (collectively “Aspen”) to ensure that slavery and human trafficking do not exist in our business or supply chains.

Introduction

Aspen Insurance UK Limited (‘‘AIUK’’) is a London based, wholly-owned subsidiary of Aspen European Holdings Limited (‘‘AEHL’’). AEHL is a wholly-owned subsidiary of Aspen Insurance Holdings Limited (‘‘AIHL’’).

Through Aspen Insurance UK Services Limited (AIUKSL), 448 staff are employed within AIUK and there are 907 employees within the entire Aspen group of companies.

Throughout the Aspen group, including our subsidiaries and Branches, any form of modern slavery and/or human trafficking will not be tolerated.  Aspen is fully committed to operating its business ethically and fairly and we have robust frameworks and processes in place to minimize the risk of modern slavery in our business operations and supply chains.

Our Business

Aspen is a leading specialty insurance and reinsurance company, and we have the insight, expertise and confidence to bring clarity from complexity.  At Aspen, we are one team with a defined vision to transform complex risks through the most efficient and innovative solutions.

Aspen is recognized for taking complex circumstances and providing bespoke ideas by utilizing outstanding team work collaboratively across a diverse range of disciplines to look at problems from every angle.

Our three business units – InsuranceReinsurance and Capital Partners – make us a leader in our fields, giving our customers support and confidence, and each has a unique set of capabilities to create advantage for our partners.

The group’s core platforms, in the UK, US, and Bermuda, are supported by strong balance sheets. They give us the grounding to build long-term relationships that we value by offering a footprint that meets our clients’ distinct requirements. From Syndicate 4711 at Lloyd’s of London, our experts also bring clarity to complex risks across a range of classes.

Our group is financially strong and for the year ended December 31, 2020, we reported US$13.2 billion in total assets, US$7.2 billion in gross reserves, US$3.0 billion in total shareholders’ equity and US$3.7 billion in gross written premiums. Our operating subsidiaries have been assigned a rating of “A-” by Standard & Poor’s and an “A” (“Excellent”) by A.M. Best.

Whatever approach we deploy, we empower our people to keep close to our customers across the markets in which we operate while harnessing the strength and support that comes from being part of a diverse global team.

Our business model is supported by our culture, which prizes collaboration, open communication and empathy to reach mutually beneficial, clear resolutions that don’t come ready packed.

Our service-led approach spans the entire operation and we act with speed, efficiency and agility to respond to the needs of our customers throughout the cycle of our partnership.

The pursuit of clarity underpins everything we do as a business, from underwriting to our claims excellence. We offer clear perspectives however challenging and complex the situation.

Our teams value diversity and inclusion and we treat each other, our customers and members of our communities with respect. Whatever the circumstances, we hold ourselves and each other to account and our goals for a better world are clear through our support for our communities and as an advocate for change whether environmental or social.

Our Policies

We have prepared and implemented an amendment to our Code of Business Conduct and Ethics (“the Code”), applicable to all employees within the Aspen group to state that Aspen takes a zero tolerance approach to slavery and human trafficking and is committed to ensuring that there is no slavery or human trafficking in our business or supply chains. This is reflective of the Code’s general commitment to integrity in the conduct of our business and the requirement that all Aspen employees perform their duties in a manner, which is legally, ethically and morally irreproachable.

Other relevant policies, including our Group Outsourcing Policy and Group Procurement Policy, have also been reviewed and amended to highlight the need to consider slavery and human trafficking issues when selecting and engaging with suppliers.

We have a Whistleblowing Policy under which employees can report any issues or concerns they may have regarding slavery or human trafficking in our business or supply chains.

Employment

Our recruitment processes comply with UK, US and Bermudian employment legislation, and we ensure that ‘right to work’ document checks and contracts of employment are in place for both permanent and temporary employees.

Our Assessment

In 2020, we continued to outsource recruitment to a third party. Our agreement with this third party has full modern slavery provisions and the third party in turn continues to have robust policies and procedures in place to counter slavery and human trafficking.

We have further reviewed our spend data to assess the number of suppliers, their location and the nature of the goods or services being provided, in order to assess which suppliers represent the greatest risk to managing slavery and human trafficking in our supply chain. For those higher risk suppliers, we have reviewed their policies and statements to ascertain that they are ensuring compliance with the requirements of the Act.

Our tender template includes a statement that Aspen is committed to ensuring slavery and human trafficking do not exist in our business or supply chains. Bidding suppliers are required to include their relevant policies and procedures as part of their tenders.

Our standard purchasing terms require that a supplier must comply with the provisions of the Act in relation both to its direct employees and to its suppliers and ensure that neither it nor its supply chain makes use of slavery, forced or bonded labour or human trafficking.

In 2020, we continued to hold global outsourcing agreements with two Indian-based suppliers for the provision of a range of back and middle office services, including IT. As suppliers to the Aspen group, their services also encompass our global and Branch operations.  The evaluation of the suppliers includes a full assessment of their approach to modern slavery, as well as their ethical and social policies. This includes reviews of the organisations’ United Nations report based on the Global Reporting Initiative, covering the organisations’ approach to issues such as human rights practice, ethical supply chains and operating ethically. The agreements with the suppliers contain a range of clauses to prevent and detect modern slavery, for example, clauses covering the Act, minimum wage obligations and extensive audit rights. We have undertaken several site visits to the organisations’ delivery locations since the inception of the agreements in 2018 and these visits have continued after signing of the agreements and subject to Covid-19 restrictions, will continue to be carried out when it is safe to do so.

Awareness and training

All Aspen employees have been made aware of the Act, the changes to our policies and the commitments these represent. More in-depth training has been given to our Procurement team and to key spending departments.  Ongoing training will be given to those departments where we believe there is a direct connection to the potential exposure to modern slavery and human trafficking in order that they are aware of what to look for and feel comfortable in reporting any such potential issues.

All new employees to Aspen will be provided with a copy of this Statement as part of their “New Starter” package so that they are aware that Modern Slavery and Human Trafficking will not be tolerated within our operations.

Approval of this statement

This statement is made pursuant to Section 54 (1) of the Act and constitutes Aspen’s slavery and human trafficking statement for the financial year-end 2020. This statement was approved by the Boards of Aspen Insurance UK Limited, Aspen Managing Agency Limited, Aspen Insurance UK Services Limited, Aspen UK Syndicate Services Limited and Aspen Risk Management Limited.

Richard Milner

CEO, Aspen Insurance UK Limited

June 2021

[1] This statement sets out the steps taken by Aspen Insurance UK Limited Aspen Managing Agency Limited, Aspen Insurance UK Services Limited, Aspen UK Syndicate Services Limited and Aspen Risk Management Limited (including our Branches, and where applicable, we will provide a copy of specific Branch Statements upon request).