Anti-Slavery Statement

Xceedance is committed to conducting its business with the highest level of legal, professional, and ethical standards, in compliance with the applicable laws based on a strong foundation of integrity.

Slavery of any kind is a heinous crime and a morally reprehensible act that deprives a person’s liberty and dignity for another person’s gain. It is a real problem for millions of people around the world, including in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chain.

In line with its aforesaid commitment, Xceedance honors and follows laws related to prevention of slavery and human trafficking in all the jurisdictions it operates in. Xceedance has zero-tolerance for any form of slavery and human trafficking.

Failing to recognize and avoid slavery can have a devastating impact on Xceedance’s reputation, business, and can create criminal and/or civil liability for Xceedance and the individuals involved.

The purpose of this Policy is to:

This Policy applies to any Xceedance company, subsidiary, affiliate, division, and other controlled business entity and operation, including Xceedance Limited as well as the directors, officers, executives, senior leaders, and employees and temporary workers thereof (collectively, “Xceedance”). Moreover, the principles set forth in this Policy extend to its Business Partners through the application and acceptance of Xceedance’s Business Partner code of conduct.

This Policy shall be applicable on all the Members, and relevant Business Partners. This Policy must be communicated to them at the outset of their relationship with Xceedance.

This Policy applies in all territories where Xceedance operates. Wherever local customs, standards, laws, or other local policies apply, that are stricter than the provision of this Policy, the stricter rules must be complied with. However, if this Policy stipulates stricter rules than local customs, standards, laws or other local policies, the stricter provisions of this Policy shall apply.

Xceedance is an insurance-focused consulting, technology, and managed services group, which supports insurers, reinsurers, brokers, program administrators and managing general agents (MGA’s) worldwide. It supplies comprehensive, knowledgeable services to reinforce insurance operations which is the unique value proposition of the group and has operations across various geographies including India, the United States of America, the United Kingdom, Poland, Australia, Bermuda, Canada etc.

Xceedance establishes a relationship of trust and integrity with all its Business Partners, which is built upon mutually beneficial factors. Xceedance endeavours to select and onboard such Business Partners who have impeccable market reputation, respect for the law, compliance with health, safety and environmental standards and respect for human rights.

Xceedance aims to work in partnership with all its Business Partners to ensure that they share and work towards the same values that Xceedance holds against slavery and human trafficking. To manage this,

as part of Xceedance’s contracting processes, Xceedance has specifically included the aspect of compliance with Applicable Laws, thereby prohibiting the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. Xceedance expects all its Business Partners to hold their own employees and suppliers to the same standards or higher.

Xceedance’s anti-slavery policy is available to all the Members via the company intranet, and all the Business Partners are apprised of Xceedance’s commitment to preventing modern slavery through the contracts that are entered into with Xceedance.

Xceedance urges anyone to approach and notify them immediately as and when they suspect or have knowledge of any activity related to slavery or human trafficking, whether at organizational level or at the Business Partners’ end.

Xceedance has various policies in place which act as guidelines for those associated with Xceedance and emphasize its commitment to highest standard of professional conduct, ethics, and compliance with laws. These policies are reviewed and updated from time to time, in line with Xceedance’s evolving values, approach and the Applicable Laws.

Xceedance’s Code encourages Members and Business Partners to do the right thing by affirming the behaviour expected of them when representing Xceedance or working for Xceedance as the case maybe. The Code covers various areas pertaining to human rights including anti-harassment, anti-discrimination, and equal opportunities.

Xceedance’s whistleblower policy encourages all employees, customers, and Business Partners to report inter-alia any violation of a policy, Code and Applicable Laws without fear of any retaliation.

As a part of its responsible supply chain efforts, Xceedance:

Xceedance has defined a set of key indicators and controls to combat modern slavery and human trafficking within the organization and its supply chain. These include:

Xceedance shall continue to identify ways to improve its Members’ and Business Partners’ awareness of its commitment to respect human rights and efforts to prevent modern slavery and human trafficking.

Xceedance is committed to ensuring that all Members receive an appropriate level of training on prevention of modern day slavery, as and when required.

All Members and relevant Business Partners are required to understand and acknowledge Xceedance’s commitment to anti-slavery and prevention of human trafficking. In addition to creating awareness around anti-slavery and prevention of human trafficking, Xceedance shall ensure to roll out the requisite trainings around the same to the relevant Members and make the Business Partners aware of Xceedance’s commitment to prevention of slavery and human trafficking.

Any violations of this Policy must be reported in accordance with Xceedance’s whistleblower and anti-fraud policy at report@xceedance.com.

If the Members and/ or Business Partners come across any red flags while working for Xceedance, they must raise concerns and report them to their manager and the Compliance Team.

Members who refuse to take part in the activities prohibited under this Policy, or report in good faith under this Policy their suspicion, that an actual or potential violation of the Applicable Laws has taken place or may take place in the future, will be protected from any sort of victimization.

Violation/circumvention of the Applicable Laws can result in civil or criminal liability, fines, and prohibitions on future business as well reputational damage for association with activities pertaining to slavery and human trafficking. Companies can also incur significant costs associated with investigations of allegations of such activities, be debarred from government contracting, as well as be subject to civil suits by shareholders, customers, and competitors.

Members who violate this Policy will be subject to disciplinary action up to and including termination of employment. In addition, Members may be held personally liable for engaging in the aforesaid activities or for violating the Applicable laws. Xceedance may refer suspected violations to the appropriate law enforcement or regulatory authorities, which could lead to penalties, fines, and/or imprisonment for Members found liable for violating the Applicable Laws.

If Xceedance determines that a Business Partner has not complied with the provisions of this Policy, it will take appropriate action, which may include termination of the Business Partner’s contract, initiating proper legal action, and/or notifying the proper authorities regarding the violation.

All the Members shall acknowledge Xceedance’s commitment to prevention of slavery and human trafficking.

The People Function Team shall have the sole authority to interpret, amend, modify, or revise the provisions of this Policy, as and when deemed fit, subject to the approval of the board of directors of the respective Xceedance entity, wherever required under the Applicable Laws.

Any queries under this Policy can be addressed to the People Function Team at people.culture_uk@xceedance.com.