HSB UK&I Group Statement on the UK Modern Slavery Act

Munich Re Group is one of the world’s leading risk carriers and provides both insurance and reinsurance under one roof. This enables the Group to cover large stretches of the value chain in the risk market. The majority of the reinsurance units operate under the uniform brand of Munich Re. The majority of the investments of both Munich Re and HSB UK&I are mainly managed by MEAG³, which also offers its expertise to private and institutional investors outside the Munich Re Group.

HSB UK&I comprises HSB Engineering Insurance Limited (HSBEIL) and its wholly owned subsidiaries. HSBEIL is a leading engineering and technology insurer in the UK, providing (Re)insurance across a broad range of technologies and industry sectors - including construction and manufacturing as well as leisure, retail, commercial and public sectors. MD Insurance Services Limited (MDIS) is an authorised insurance intermediary and managing general agency (MGA) specialising in building structural defects insurance in the UK. HSB Engineering Insurance Services Limited (HSBEISL) is a leading engineering inspection service provider in respect of workplace plant, machinery and equipment, whereas MD Warranty Inspection Services Limited (MDWIS) and MD Warranty Support Services Limited (MDWSS) provide building surveying and building control inspection services respectively.

Munich Re operates in life, health and property-casualty insurance business. Under reinsurance, Munich Re also includes specialised primary insurance activities that are handled by the reinsurance organisation and business from MGAs. Munich Re does business with over 4,000 corporate clients from more than 160 countries. We write our business in direct collaboration with primary insurers, but also via brokers and within the framework of strategic partnerships. In addition to traditional reinsurance business, we participate in insurance pools, public-private partnerships, business in specialist niche segments, and also as a primary insurer.

As a globally operating organisation, Munich Re Group procures many different goods and services throughout the world and including in the UK and the Republic of Ireland for and on behalf of HSB UK&I. In our procurement decisions and activities at HSB UK&I, we aim to assume corporate responsibility along the value chain. Environmental, social and governance (ESG) criteria play an important role for us in the procurement of goods and services.

All relevant Munich Re processes and rules described below also apply to HSB UK&I.

Responsible behaviour is the foundation on which Munich Re and HSB UK&I creates value for and with all its stakeholders. HSB UK&I’s Board of Management believes in the importance of human rights as a high priority for the Company, which is also explicitly enshrined in the Munich Re Code of Conduct which HSB UK&I has adopted. In our view, respect for human rights is a fundamental part of successfully implementing our business model by making choices based on a long-term, sustainable perspective. Accordingly, we are committed to respecting and upholding human rights in line with internationally accepted principles and the United Nations Guiding Principles on Business and Human Rights, including but not limited to the following international guidelines and standards:
 

• the International Bill of Human Rights, which consists of the:
  • Universal Declaration of Human Rights
  • International Covenant on Civil and Political Rights
  • International Covenant on Economic, Social and Cultural Rights
• ILO (International Labour Organization) Declaration on Fundamental Principles and Rights at Work
• United Nations Guiding Principles on Business and Human Rights
• the 10 Principles of the UN Global Compact
• Principles for Sustainable Insurance (PSI)
• Principles for Responsible Investment (PRI).

Munich Re has defined a set of fundamental human rights based on its business model and supply chain, listed below which HSB UK&I expects its employees and suppliers to uphold. These are established in alignment with the above mentioned guidelines and standards, as well as applicable legal requirements.

1. The right to healthy, safe and dignified working conditions: these include the prohibition of the worst forms of child labour as well as forced labour, modern slavery and human trafficking, freedom of movement of migrant workers, the right to the payment of a living wage, a limit on working hours, the right to health and safety at work, as well as respect for the right to freedom of association.
2. The right to equality and non-discrimination: we do not tolerate discrimination on the grounds of disability, age, gender, ethnic origin, nationality, sexual identity, political views, race, religion or similar aspects. In employment and occupation, this applies in particular to the areas of recruitment, job assignment, dismissal, remuneration and promotion. Further, we do not tolerate sexual or other personal harassment, offensive or socially inappropriate behaviour, intimidation, violence or the threat of violence.
3. The right to adequate living conditions by protecting the habitats of local communities and/or indigenous peoples, avoiding environmental hazards and seeking to prevent or reduce their negative health impacts.

Our goal is, to the best of our knowledge and ability, to prevent or mitigate any potentially adverse impacts of our business on human rights compliance. To ensure fulfilment of our due diligence obligations, we have therefore established processes for identifying risks concerning the infringement of human rights and for addressing them with appropriate measures.

Our corporate due diligence requirements are set out in various guidelines, codes and work instructions. The processes include the following components:
 

• A risk management system with clearly defined processes and responsibilities:
  • Regularly conducting risk analyses
  • Embedding preventive and remedial measures in our business units
  • Monitoring and reviewing the effectiveness of measures
• Whistleblowing management system
• Documentation and reporting

In order to embed this risk management company-wide, Munich Re has adopted a policy on respecting human rights. The policy sets out the basic human rights compliance requirements for employees and suppliers and defines how human rights risks are addressed in its business operations and to ensure that human rights are respected within the Munich Re Group.

With the help of a structured risk analysis along our value chain, Munich Re systematically checks which business units or activities could be prone to an increased risk of human rights violations or environmental harm.

Based on the results, Munich Re have identified the following four risk areas for HSB UK&I:
 

• Employees
• Procurement
• Core business of primary insurance and reinsurance
• Investments

Processes have been implemented in these areas to reinforce existing ESG requirements and to facilitate the identification of potential human rights risks.

In addition, risk analyses are carried out by Munich Re on an ad hoc basis in response to significant changes in the risk situation, such as expansions into new business areas or product offerings, or if we become aware of related breaches of duty on the part of our direct and indirect suppliers. The risk analysis is based on a country-and-sector list, which is compiled and regularly updated on the basis of external indices. We also use this list to screen new and existing business relationships and, if necessary, initiate preventive or remedial measures.

HSB UK&I strives to reject business relationships with and investments in companies that have been involved in confirmed and substantial human rights violations. For this purpose, a list of companies with which we want to exclude business has been developed in a multi-stage process based on information from external data providers. This list is regularly reviewed, updated and adopted as part of our ESG governance. The implementation of these regulations includes our investments, procurement and single-risk business in primary insurance and facultative reinsurance.

As an employer, we undertake to comply with international standards of human rights and to provide adequate working conditions for our staff.

The Munich Re Code of Conduct for employees, which HSB UK&I has also adopted, defines our standards for respecting human rights. The Munich Re risk analysis has determined that, despite the global presence of the Munich Re Group, it is exposed only to isolated risks of human rights violations in a few countries. These are potential risks of discrimination or unequal treatment, as well as potential risks relating to the right of freedom of association in regions where this right is limited.

Our goal in procurement, when making decisions and taking action, is to adhere to Munich Re’s compliance principles and thus assume corporate responsibility along the supply chain. Avoiding ESG risks is pivotal in our procurement of goods and services.

We expect our suppliers to comply with our extensive “Code of Conduct for suppliers”, with defined principles for the protection of human rights and the environment. Furthermore, as part of our procurement process, we require suppliers to confirm their adherence to the UN Global Compact. The Munich Re Group risk analysis determined that, given the nature of the goods and services we procure, there is an increased risk of human rights violations among our suppliers only in a few product groups. We reserve the right to carry out case-by-case reviews with suppliers of these product groups, from which we can derive and implement corrective measures if necessary.

As part of a globally active (re) insurance Group, we are aware that we have to be vigilant regarding a multitude of possible human rights violations and potential environmental hazards in our business.

In our underwriting guidelines for our single-risk business in primary insurance and facultative reinsurance, we have therefore incorporated an enhanced risk analysis for certain large commercial business clients. The focus here is on client groups for which – given their geography and sector – structural factors contribute to an increased risk of human rights violations.

MunichRe defines in its underwriting guidelines how underwriters should deal with Human Rights risks in the insurance business. The existing framework will be expanded if necessary.

Our Responsible Investment Guideline contains sustainability criteria that help us identify risks and opportunities. In order to evaluate investments according to sustainability criteria, we use e.g. ESG ratings from external data providers.

The Munich Re Group also support the international conventions in the controversial weapons context (including but not limited to the weapon categories anti-personnel mines and cluster munition), and address this in corresponding guidelines for our investments and for (re) insurance.

Human rights-related risks and breaches of human rights-related duties can also be reported using the Munich Re compliance whistleblowing portal. Whistleblowers can access the portal via our Intranet or the publicly available Munich Re websites. Accordingly, relevant information can be shared securely, confidentially and, on request, anonymously – globally and round the clock. Evidence of potential human rights violations that reaches us via other channels is handled using the same principles and processes.

All information received is handled in accordance with the risk management process described above and in collaboration with the respective department. Every reported case of potential misconduct is carefully reviewed and confirmed violations are, if necessary, duly punished. When human rights violations within our remit are brought to our attention, we enter into a dialogue with the parties in question and pursue remedial measures.

How HSB UK&I and Munich Re fulfils their respective obligations with regard to human rights is detailed in the following documents:
 

• Combined non-financial statement
• Reporting on the Principles for Responsible Investment (PRI)
• Statement on the UK Modern Slavery Act 2015

In order to raise staff awareness and familiarise our staff with the key compliance rules and help them understand the importance of following these rules at work at all times, employees re-certify their knowledge of the Munich Re Code of Conduct regularly. This training course includes information on equal treatment, reporting of infringements, data protection and corruption. Furthermore, special training courses on human rights due diligence have been established for employees in the procurement units.

In the reinsurance sector, Munich Re’s sustainability experts coordinate the implementation of the Principles for Sustainable Insurance (PSI) and the integration of ESG aspects in its reinsurance business. With this in mind, these experts provide relevant training for managers, underwriters and client managers in the different divisional units. In addition, a network of ESG Multiplier was established in the reinsurance segment.

Human rights officers within the Munich Re Group regularly attend external seminars and webinars in order to deepen their knowledge.

We will continue to work on the implementation of human and labour rights aspects and to consider our obligations under the UK Modern Slavery Act 2015.

Munich Re has published its first annual report on fulfilling the Group’s due diligence obligations for the 2023 reporting year. No significant risks or violations in relation to human rights were identified.

The risk analyses conducted to ensure the due diligence for the workforce across all Munich Re Group companies, both in the UK and internationally, as well as in global supplier management, did not indicate any significant changes compared to the previous year. No serious human rights-related complaints were received via Munich Re’s globally accessible whistleblowing channels.

Munich Re Group’s due diligence processes were continuously monitored by the Human Rights Officer of Munich Re Group and by other responsible Group functions and further developed as required. As part of the regular training sessions on the Munich Re Group's Code of Conduct, employees were again made aware of the importance of respecting human rights.

Our goal is to continuously improve our compliance-related processes and expand our risk assessment. Our risk management processes and risk analysis are reviewed periodically.

This Statement has been approved by the Board of Management of HSBEIL and all applicable subsidiaries on 29 July 2025.

Andrew Burke
Interim CEO
HSB UK & Ireland