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Modern Slavery Statement

This Statement (1) has been published in accordance with the Modern Slavery Act 2015 (the “Act”) and relates to the financial year ending 31 December 2025.  It outlines the steps that MSIG Europe has taken and is taking to prevent modern slavery and human trafficking as defined in Appendix A of the Government’s 2017 Guidance (2) issued under s. 54 (9) of the Act and includes activities undertaken during the course of 2025 to address the risks of potential slavery in MSIG Europe’s supply chains or in its business operations. MSIG Europe may publish this statement on the UK Government’s online modern slavery statement registry.

Organisation structure and supply chains

    MSIG Europe SE is part of the top 10 global insurance provider MS&AD and has a long-standing legacy of providing insurance solutions to companies of all sizes around the world. 

    As a wholly owned subsidiary of Mitsui Sumitomo Insurance Company, MSIG Europe is a member of the MS&AD Group, headquartered in Tokyo. This affiliation enables to exchange expertise with experienced colleagues worldwide, ensuring financial stability and the ability to provide comprehensive insurance protection to customers across the globe.

    Headquartered in Brussels, Belgium, MSIG Europe operates from Belgium, France, Germany, Italy, the Netherlands, Slovakia, Spain and the UK. The Company offers a comprehensive portfolio of insurance solutions for small businesses up to major industrial players, backed by international expertise and tailored to local needs.

    MSIG Europe underwriting is organised and managed through distinct operating segments as follows: 

    1. Marine:Marine & various other specialty lines are managed by MSIG Specialty Marine (‘MSM’; previously MS Amlin Marine NV), an in-house Managing General Agent focusing on cargo, hull, liability, fixed premium protection & indemnity, yacht, political violence and other specialist areas such as specie. MSIG Specialty Marine is a subsidiary of MSIG Europe. 
    2. Property & Casualty (P&C): Providing insurance coverage in four main areas – property, casualty, engineering and motor – for clients in France, Germany, the Netherlands, Belgium, The United Kingdom, Italy, Spain and Slovakia. 

    MSIG Europe’s supply chain: 

    As an insurance company, the key suppliers are service providers, offering key inputs for the functioning of the organisation. Examples of key suppliers and outsourcing partners include: 

    • Asset management partners 
    • IT systems providers and related contractors and service providers 
    • (Other) material outsourcing partners in e.g. claims handling, IT and operations and facilities management

    The supply of physical products is more limited in terms of financial materiality, and includes IT hardware, furniture, office supplies and other minor purchases.

    Policies in relation to slavery and human trafficking 

    MSIG Europe has two key policies in place in relation to slavery and human trafficking, namely the Human Rights Policy and its whistleblowing policy Speak Up.

    Human Rights Policy: 

    MSIG Europe is committed to respecting human rights across its operations and business relationships. Its Human Rights Policy is aligned with international standards including the UN Guiding Principles on Business and Human Rights and ILO conventions, applies to all employees, contractors, suppliers, clients and distribution partners. 

    The policy sets a zero-tolerance approach to modern slavery, including forced labour, human trafficking and child labour, and requires the same standards to be upheld throughout its supply chain. 

    It establishes minimum expectations to ensure: 

    • Fair treatment, non-discrimination and a workplace free from harassment 
    • Freedom of association and collective bargaining 
    • Safe working conditions and protection of worker dignity 
    • Lawful employment terms and fair remuneration 
       

    MSIG Europe seeks to prevent, identify and mitigate human rights risks in its own operations and in its supply chain, and to avoid contributing to adverse impacts through its business activities. Where issues arise, it is committed to supporting or cooperating in remediation. Compliance is overseen by MSIG Europe’s Management Committee, with operational responsibility delegated to its Human Resources department. Concerns can be raised through confidential Speak Up mechanisms, with protection against retaliation. 

    Speak-up Policy: 

    MSIG Europe operates a Speak Up framework to enable employees and third parties, including suppliers, to raise concerns about wrongdoing in a safe and confidential manner. 

    The policy promotes a culture of openness and accountability, encouraging individuals to report concerns relating to legal or regulatory breaches, unethical conduct, human rights violations (including modern slavery), health and safety risks, or breaches of company policies.

    Key features include: 

    • Multiple reporting channels, including internal routes, an independent external provider (Safecall), and a Group-level whistleblowing service 
    • Confidentiality and anonymity, with individuals able to raise concerns anonymously if preferred 
    • Non-retaliation commitment, ensuring protection for those who raise concerns in good faith 
    • Independent oversight, with a Speak Up Committee (Compliance and Internal Audit) responsible for managing and investigating reports 
    • Board-level oversight, including an independent Non-Executive Director acting as Speak Up Champion 

    All reports are taken seriously, investigated appropriately, and followed by corrective action where required. The framework also supports remediation and continuous improvement of controls. 

    Due diligence processes

    Due Diligence is an important mechanism to identify, prevent and mitigate adverse impacts across the value chain. It is also an important process to inform the Impacts,  Risks and Opportunities of a company. MSIG Europe has a general due diligence process in place that informs its Double Materiality Assessment and is an integral part of the identification and monitoring of material Impacts, Risks and Opportunities across the entire organisation. It has not formally adopted the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises but will consider it for future reporting periods. However, the company’s current Human Rights policy is aligned with the aforementioned international instruments. MSIG Europe has conducted a due diligence in various forms. More general due diligence conducted includes: 

    1. Own workforce: MSIG Europe engages its workforce through structured processes, including numerous activities such as biannual Engagement Surveys and quarterly Pulse Surveys, to identify, assess, and mitigate/prevent actual and potential impacts on its workforce. Regular meetings with local works council committees and employee representatives further inform this process, addressing topics like organisational changes and employee well-being. Additionally, communication channels like the Change Ambassador Network and town hall sessions ensure transparency and foster a shared understanding of priorities across the entire organisation. 
    2. Customers: Customers are assessed on a case-by-case basis through a comprehensive set of know-your-customer procedures. These include, inter alia, screenings for the applicability of sanctions as well as a number of exclusions and conditions linked to activities with high environmental or social impacts, e.g. in the energy and defence sector. MSIG Europe has, for example, general exclusions in place regarding underwriting or investments in new coal-powered power plants and the production of controversial weapons.  
    3. Suppliers: The company’s Human Rights policy is also applicable to contractors, consultants, agency workers, seconded workers and suppliers working for MSIG Europe or on its behalf in any capacity. It addresses the safety of workers, precarious work, human trafficking, and the use of forced labour or child labour and is aligned with ILO standards. 
    4. Investees: To work with MSIG Europe, asset managers are expected to adhere to the United Nations Principles for Responsible Investment for investments managed by MS Amlin Investment Limited (MS AIML). Additionally, the company engages with asset management partners on sustainability-related topics, integrating both financial and non-financial ESG risk assessments into investment decisions in alignment with the Group’s sustainability policy, which, for example, excludes investments in companies involved in cluster munitions, new coal-fired power plants, and coal mining projects. 

    The existing due diligence processes mitigate the risk of modern slavery and trafficking occurring within the company’s value chain. 

    Risk assessment and management

    In FY2025, MSIG Europe completed a Double Materiality Assessment (DMA), which identified Impacts, Risks and Opportunities (IROs) across its value chain.  

    Its DMA did not assess the company to have a material impact on modern slavery and human rights, nor were these topics assessed as representing a material risk.  

    While our core underwriting activities present lower inherent risk, we recognise elevated risks in outsourced services such as facilities management, IT supply chains, and third-party operations, and will monitor these risks on an ongoing basis and reassess if deemed necessary.

    Key performance indicators to measure effectiveness of steps being taken

      Speak-Up Channel offers a confidential channel for grievances to be raised, including on modern slavery and trafficking, as well as any other breaches in human rights. No cases were raised in FY2025 with regards to modern slavery and trafficking. 

      This reflects the lower inherent risks of modern slavery and trafficking within MSIG Europe and its supply chain, but also the effectiveness of actions taken around stakeholders. 

      Nevertheless, the absence of cases raised does not mean the absence of modern slavery and trafficking, and MSIG will continue to actively improve in its prevention, mitigation and remediation efforts.

      Other KPI’s include the employee completion rate for the training on Human Rights, which supports awareness-raising and helps ensure that employees are able to identify and respond appropriately to potential human rights risks, including modern slavery.

      Training on modern slavery and trafficking

      In 2025 MSIG Europe’s employees had to complete several mandatory trainings, including on Human Rights and diversity & inclusion, anti-bribery and corruption, and conduct rules. The mandatory training on conduct rules includes a section on modern slavery and human trafficking. The training is delivered as part of onboarding and via annual mandatory e-learning programmes, based on a rolling multi-year training cycle. 

      This Statement was approved on behalf of MSIG Europe by the Board of MSIG Europe on 19 June 2026 and signed on its behalf by Klaus M. Przybyla, Chief Executive Officer, MSIG Europe.