This statement has been published in accordance with the Modern Slavery Act 2015 (‘MSA’). It sets out the steps taken by Helios Underwriting Plc and its subsidiary companies (together referred to as ‘HUW’) to prevent modern slavery, human rights violations and trafficking in its business and supply chains during the year ended 31 December 2025. This is the seventh statement prepared by HUW and we aim to progress and develop our work in this area as appropriate over the coming years.
Our Business
The principal activity of HUW is to provide a limited liability investment for its shareholders in the Lloyd’s insurance market and HUW participates in the Lloyd’s insurance market through its participation in a portfolio of Lloyd’s syndicates.
Commitment
As a UK business listed on AIM, we accept we have a responsibility and are committed to upholding human rights and will do our utmost to ensure there is no slavery, servitude, forced or compulsory human labour, abuse of power over vulnerable individuals, human trafficking or any other form of exploitation contemplated by the MSA in any part of our business.
Our Principles
HUW adheres to a high standard of ethics, values and corporate social responsibility and these principles underpin our governance procedures and the strategic and management decisions that we make.
The Chairman, Finance and Operations Director and the Head of Portfolio Strategy are in regular contact with the managing agents not only to review performance of the portfolio, but also to consider governance matters and compliance with Lloyd’s Minimum Standards and principles for doing business.
Our Policies
HUW has a number of policies to mitigate the risk of modern slavery and set out steps to be taken to prevent slavery and human trafficking in its operations.
Recruitment and Selection
Our employment procedures require that all employees have the necessary documentation to legally work and no-one will be employed without providing the necessary evidence. This will helps prevent employing people are forced to work against their will, are trafficked or are under the legal minimum age to work.
Vendor Supply Chain
Our vendor supply chain primarily consists of professional, IT, consulting services, along with property and purchased equipment, facilities management and our use of hospitality and travel providers.
Assessment of Risk
HUW has assessed the relationships that it has with suppliers based predominately within the UK, together with the highly regulated underwriting sector within which it operates, and concluded that its business and supply chain present minimal opportunity and a very low risk in terms of modern slavery, human rights violations and trafficking. Nevertheless, we will implement remedial measures should any concern be identified.
Similarly, HUW has no partnerships with businesses based in regions of the worldwhere labour laws are non-existent or are not enforced, and therefore the risk in terms of modern slavery, human rights violations and trafficking is considered low.
HUW believes that its risk is further mitigated due to the unique nature of its business. Through its subsidiaries the Company owns a portfolio of underwriting capacity interests at Lloyd’s and, whilst it has no direct responsibility for the management of those businesses, they are managed by highly regulated managing agents that in turn have responsibility for managing the businesses, their staff and employment policies, and their environmental impact. Furthermore, for a managing agent to operate at Lloyd’s there are ‘statements of business conduct’ (‘Lloyd’s Minimum Standards’) and principles for doing business with which the managing agent must comply. These encompass matters such as claims management, treating customers fairly, governance, culture, inclusion, diversity and ESG and while not directly related to modern slavery, point to a highly prescriptive, regulated and scrutinised environment. The managing agents and senior managers within them are also subject to regulation by the Financial Conduct Authority (‘FCA’) and the Prudential Regulatory Authority (‘PRA’) and must comply with their stringent and regular reporting requirements. Together, these rules and regulations set a high bar for conduct and helps foster a culture which is not conducive to modern slavery.
Due Diligence
HUW does not support or deal with any businesses believed to be involved in or linked to modern slavery, human rights violations or trafficking and we will implement remedial measures should any concern about a particular investor or business contact be identified. We have identified our highest risk as the supply of cleaning staff in our offices and have thoroughly diligence the supplier by reviewing their policies and responses to our due diligence questionnaire.
Continuous Improvement
We note the new guidance (issued in March 2025) on how businesses should comply with the letter and spirit of section 54 of the Modern Slavery Act 2015. We will look to incorporate this updated guidance into our Modern Slavery Statement for 2025.
We are also incorporating modern slavery training in our induction plans for new directors appointed in 2025 so that our Board members can improve their oversight of modern slavery.
This statement was approved by the Company’s Board of Directors on 30 June 2025.