Modern Slavery Act 2015

Organisation Structure, Business and Supply Chain

Sompo Japan Nipponkoa Insurance Inc. ("SJNK") is the largest Non-Life insurance company in Japan, with a history stretching back to 1888. SJNK is a wholly owned subsidiary of Sompo Holdings, Inc. a listed company in the Tokyo Stock Exchange. SJNK has been serving clients in Europe for over 50 years since it first set up a representative office in London in 1955.

Sompo Japan Nipponkoa Insurance Company of Europe Limited ("SJNKE") is a wholly owned subsidiary of SJNK. SJNKE provides general insurance products and services mainly to large commercial clients.

With SJNKE's offices in the U.K., Belgium, France, Germany, Italy, Spain and underwriting agencies in the Netherlands and France, SJNKE is able to provide insurance throughout the European Economic Area.

We are fully integrated into the global network of SJNK and its subsidiaries which form the global Sompo Holdings Group. The Sompo Holdings Group operates from 211 cities in 32 countries and regions and SJNKE works closely with other group companies. Together we deliver client-focused products and services through commitment, innovation and expertise.

SJNKE's supply chain can be categorised into internal and external suppliers. Internally, for example, we have a team of IT developers who build and maintain the software the company uses for its business systems. Externally, we have suppliers who provide goods and services in order for the business to function, such as supplying stationary and cleaning services for example.

Policy on Slavery and Human Trafficking

As a regulated firm we always work to the highest professional standards and comply with all laws and regulations applicable to our business. We expect the same high standards from those parties we engage with and we are committed to ensuring that there is no modern slavery or human trafficking in our supply chain. This commitment is detailed in the SJNKE 2016-2020 Business Plan.

We work to embed a robust risk management framework throughout our operations to ensure we analyse and manage the risks to our business effectively; this includes analysing the risk of inadvertently working with suppliers who do not share our commitment to Anti-Slavery and Human Trafficking.

Due Diligence

As suppliers are partners in our business success, they are expected to comply with all local laws and regulations as well as the SJNKE's Supplier Code of Conduct Policy. We routinely request information concerning, amongst other things, Health & Safety, environmental, equality, anti-corruption and insurance protection to enable us to verify their commitment to our corporate values and company policies.

We request suppliers to complete an evaluation questionnaire annually and, if necessary, also request a statement to further provide evidence of compliance with the Modern Slavery Act.

Whistleblowing

We encourage anyone (including employees, sub-contractors, suppliers and clients) to report in good faith any issues or concerns about potential ethics, human rights, legal or regulatory violations, including improper or unethical business practices such as fraud or bribery.

This statement is made on behalf of Sompo Japan Nipponkoa Insurance Company of Europe Limited (“SJNKE”) pursuant to Section 54, part 6 of the Modern Slavery Act 2015 and sets out the steps the Company has taken to ensure that Slavery and Human Trafficking is not taking place in our supply chains or in any part of our business.

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