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Modern Slavery Act Transparency Statement

Travelers Europe

Introduction

Travelers Europe has zero tolerance of slavery and human trafficking. We are committed to taking appropriate steps to ensure that slavery and human trafficking does not occur in any part of our business or our supply chains.

Purpose of this statement

This statement is made on behalf of Travelers Management Limited, Travelers Insurance Company Limited, Travelers Syndicate Management Limited, Travelers Insurance Designated Activity Company in Ireland, Travelers London Limited, and Travelers Underwriting Agency Limited (together, “Travelers Europe”) and sets out the steps that Travelers Europe is continuing to take to ensure that slavery and human trafficking is not taking place in any part of its business or its supply chains.

About Travelers Europe

Travelers Europe offers customers a wide range of insurance coverage through Travelers Insurance Company Limited and Travelers Insurance Designated Activity Company, which underwrites general insurance business from various locations in the UK and Ireland, Travelers Syndicate Management Limited, a company that manages Syndicate 5000 at Lloyd’s, which underwrites specialist global insurance), and Travelers Underwriting Agency Limited, which operates as an underwriting agent.

Travelers London Limited is our in-house law firm for claims against Travelers Europe policyholders, representing and protecting their interests.

Travelers Management Limited is a service company which employs staff in the UK and Ireland and provides the services of such staff and other services to the companies within Travelers Europe.

The Travelers Companies, Inc., incorporated in Minnesota, USA, is the ultimate parent of the companies within Travelers Europe. It is a leading provider of property liability insurance for motor, home, and business.

Supply chains

Our suppliers are businesses which supply certain services and products to support our core insurance business. Services and products relate, but are not limited, to, the outsourcing of ancillary data entry and software development, the running of our offices (cleaning, security, and maintenance services), and our IT infrastructure (supply and maintenance of systems, software, and equipment).

Supplier due diligence

Services and products are procured in accordance with our Procurement and Supplier Engagement Policy, which ensures that we enter into supplier arrangements knowingly and with appropriate levels of review and approval. Suppliers are provided with our Supplier Code of Conduct and must fully comply with all applicable labour, health and safety and other workplace laws, including those addressing slavery and human trafficking. The ongoing monitoring and oversight of our supplier arrangements is carried out in accordance with our Supplier Risk Management Policy. 

In addition, we assess and record the likelihood of the existence of modern slavery within our supplier relationships. Modern slavery risk is low in the insurance industry and in the geographical areas we primarily operate in, and where we have identified a particular risk, we undertake enhanced due diligence by asking specific questions of the suppliers’ staff and management during site visits regarding their terms of employment and their working environment. In addition to our existing contractual provisions that require suppliers to adhere to local employment laws, we continue to incorporate provisions into the supplier contracts regarding compliance with the Modern Slavery Act 2015 (the “Act”), where appropriate.

Over the last year we have strengthened our supplier due diligence by creating a new team to further enhance the oversight process, including assessment of modern slavery risks.

Labour supply chain

We take appropriate steps to ensure the human rights of everyone who works for us.  We conduct comprehensive pre-employment and right to work checks on anyone we recruit. Our Human Resources team is available to employees regarding any aspects of the terms and conditions of their employment. Our policies and procedures are designed to ensure that we are supportive to our employees at all times.

Policies

We require all employees, officers, and directors to comply with our Code of Business Conduct and Ethics, which reflects our commitment to conduct business with honesty, integrity, and accountability. This is reinforced by various policies including the Equal Employment Opportunities Policy and Whistleblowing and Non-Victimisation Policy, which encourages employees to report concerns about any conduct they believe to be unlawful, fraudulent, or unethical. We also provide a confidential Ethics Helpline (administered by an independent third-party provider) that can be used to disclose ethical concerns with guaranteed anonymity if requested.

Raising awareness

Individuals within Travelers Europe responsible for managing higher risk suppliers have been reminded of the requirements of the Act.

Monitoring and effectiveness

During 2025 no cases of modern slavery were identified through the Ethics helpline or other disclosure channels available.

Further steps

During the next financial year, as part of our ongoing work in relation to supplier onboarding, we will review and update our due diligence questionnaires and make available guidance to higher risk suppliers on Modern Slavery.

Additionally, we will review and make appropriate modification of our internal training and provide it to key staff.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Travelers Europe’s anti-slavery and human trafficking statement for the financial year ending 31 December 2025. This statement is approved by the board of directors of Travelers Europe entities cited at “Purpose of this Statement.”.

Peter McConnell, CFO - Travelers Europe

Previous versions

You can view Travelers Europe’s previous anti-slavery and human trafficking statements here:

Financial Year ending 31 December 2016.

Financial Year ending 31 December 2017.

Financial Year ending 31 December 2018.

Financial Year ending 31 December 2019.

Financial Year ending 31 December 2020.

Financial Year ending 31 December 2021.

Financial Year ending 31 December 2022.

Financial Year ending 31 December 2023

Financial Year ending 31 December 2024