Modern Slavery Act Statement

MODERN SLAVERY ACT 2015

The Modern Slavery Act 2015 (the "Act") came into force in March 2015 and has helped clearly define and codify offences relating to modern slavery and human trafficking.

This statement provides information about our business and how we have taken steps to investigate and mitigate the risk of modern slavery and human trafficking within our supply chain.

OUR APPROACH

Willis Limited is based in the UK as part of the Willis Towers Watson group of companies. Willis Limited provides risk management, insurance and reinsurance braking services to clients in the UK and worldwide, and is regulated by the Financial Conduct Authority. Willis Limited coordinates with Willis Towers Watson group companies to combat modern slavery and human trafficking.

Whilst we believe that the nature of our business as a provider of professional services to corporate clients means that we are not directly exposed to a high risk of modern slavery and human trafficking, we are nonetheless keenly aware that the possibility does exist within our global supply chains.

As part of the Willis Towers Watson group we are committed to maintaining and improving our practices to combat the human rights violations of slavery and human trafficking. We have therefore taken steps to identify and manage those areas in our supply chain where slavery and human trafficking are a possibility. Our goal is to minimise the risk wherever possible, and continually monitor and improve in our efforts.

We have taken a coordinated approach to tackling the risk of modern slavery in our business structure and have set up a cross-function working group to coordinate a group-wide approach to the matter.

POLICIES ON MODERN SLAVERY

We have a global Code of Conduct, also known as the Code of Business Conduct and Ethics.  Our Code applies to all our staff.  We are intending to launch training for staff on the Code and its key messages as part of an annual exercise. We review the Code regularly and are considering the extent to which we need to supplement its messages to include more details on modern slavery and human trafficking.

We are also in the process of amending our principles and approach to procurement and supplier on­ boarding. Our proposed processes will focus on assessing and analysing the risk of modern slavery in relation to the supplier and any potential subcontractors. This approach, when it is finalised, is intended to apply to new supply contracts and renewals of existing contracts.

TRAINING

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business and our supply chains, we have introduced training for key departments so that relevant employees are aware of the nature of the risks and what warning signs they should look for. During 2016 we brought in a leading London law firm to provide this training to key personnel in our Procurement,  Compliance and Legal teams.  The training focused on the offences under the Act, the reporting obligations for certain entities, general guidance on combating the risk of modern slavery and human trafficking, and some practical case studies.

We intend to review the need for additional or supplementary training during 2017.

DUE DILIGENCE, ON-BOARDING AND MONITORING IN RELATION TO OUR SUPPLY CHAIN

The group has certain intra-group shared service suppliers located in countries considered to be of higher risk in the context of modern slavery and human trafficking. In addition to this, we have a multitude of smaller external suppliers located across the globe.

We have commenced investigations into our supply chain to ensure a standardised approach to assessing the risk of modern slavery and human trafficking. Although we are satisfied there is minimal risk, to ensure a coordinated approach going forward we are formulating standardised modern slavery and human trafficking requirements for our suppliers. To encourage compliance in our supply chain with our values, we expect all future external supply contracts to include appropriate provisions dealing with the risk of modern slavery.

To accompany these investigations, we are also reviewing our tender processes, and have formulated modern slavery enquiries to include within tender packs sent to prospective suppliers. These enquiries, alongside our existing due diligence processes, will help us to appropriately assess the modern slavery and human trafficking risk in relation to a potential supplier as part of our general consideration of their tender.

FUTURE DEVELOPMENTS

We intend to review and develop our anti-Modern Slavery policies, training and supplier approach as our business evolves.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 2016, and has been sent to the Board for approval, as reflected by the Director's signature below.