Helios Underwriting plc is a public limited company quoted on the AIM segment of the London Stock Exchange (company number 05892671), with its registered office at 1st Floor, 33 Cornhill, London EC3V 3ND. In 2025, Helios had nine employees including the Executive team. The Board of Directors (the ‘Board’) has ultimate responsibility for the Company’s approach to modern slavery and is committed to continuous improvement in their approach to identifying, assessing and mitigating modern slavery and human trafficking risks.
This statement has been published in accordance with section 54(1) of the Modern Slavery Act 2015 (‘MSA’). It sets out the steps taken by Helios Underwriting Plc and its subsidiary companies (together referred to as ‘Helios’ or the ‘Group’) to prevent modern slavery, human rights violations and trafficking in its business and supply chains during the year ended 31 December 2025.
This policy applies to all persons working for us or on our behalf in any capacity including employees, directors, officers, interns, agents, contractors, suppliers, external consultants and advisers.
Our Business
The principal activity of Helios is to provide a limited liability investment for its shareholders in the Lloyd’s insurance market. Helios participates in the Lloyd’s insurance market through its participation in a portfolio of Lloyd’s syndicates.
The syndicates are managed by independent Lloyd’s managing agents who are separately regulated by the Financial Conduct Authority (‘FCA’) and the Prudential Regulation Authority (‘PRA’) and must comply with the “Principles for doing business at Lloyd’s”.
Commitment
As a UK business listed on AIM, Helios accepts that it has a responsibility and is committed to upholding human rights and will do its best 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
Helios 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 made.
The Chief Executive Officer, the Director of Finance and Operations and the Chief Underwriting Officer 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 the “Principles for doing business at Lloyd’s”.
Our Supply Chain
Given the nature and scale of Helios’ operations as a capital provider with a team of nine, the Group’s direct supply chain is limited in size and complexity. Our vendor supply chain primarily consists of professional advisory services, IT services, consulting services, property and facilities management services, purchased equipment, and hospitality and travel providers.
Our Policies
Helios maintains a number of policies designed 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 helps prevent employing people who are forced to work against their will, are trafficked or are under the legal minimum age to work.
Risk Assessment and Management
Helios 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, remedial measures would be implemented should any concern be identified.
Similarly, Helios has no partnerships with businesses based in regions of the world where 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.
Helios 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 help foster a culture which is not conducive to modern slavery.
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
Helios does not support or deal with any businesses believed to be involved in or linked to modern slavery, human rights violations or trafficking and will implement remedial measures should any concern about a particular investor or business contact be identified. Helios has identified our highest risk as the supply of cleaning staff in our offices and has thoroughly diligenced the supplier by reviewing their policies and responses to our due diligence questionnaire.
Helios encourages employees and others to raise concerns in confidence regarding any suspected unethical conduct, including concerns relating to modern slavery. The Company is committed to ensuring that no individual suffers retaliation for raising a genuine concern.
Training
Helios has training on modern slavery and anti-bribery and corruption available to all employees. All employees are made aware of Helios’ commitment to combating modern slavery and the channels available to raise concerns.
Monitoring and Effectiveness
Helios monitors the effectiveness of its approach to modern slavery through the following indicators: (a) the number of modern slavery concerns raised through internal reporting channels (2025: nil) and (b) completion of due diligence on higher-risk suppliers. No incidents of modern slavery were identified during the year ended 31 December 2025.
Continuous Improvement and Future Developments
As Helios enters a new phase of growth under its strengthened leadership team and evolving governance framework, the Board recognises the importance of ensuring that its approach to modern slavery continues to develop alongside the business. With a growing team, an expanding co-investor base and the ongoing maturation of the Group’s operational infrastructure, Helios will continue to review its policies, supplier relationships and risk assessments to ensure they remain proportionate and effective. The Board is also mindful of the broader regulatory landscape, including developments in international supply chain due diligence standards, and will consider how these may inform the Group’s approach over time.
This statement was approved by the Company’s Board of Directors on 22 June 2026.