Modern Slavery Act Statement

Introduction

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 (the “Act”) and constitutes Ark Syndicate Management Limited (“ASML”) slavery and human trafficking statement for the financial year ended 31 December 2025.

It sets out the actions taken by ASML to understand potential modern slavery risks related to its business and to implement measures aimed at ensuring that its business and supply chain are free from modern slavery and human trafficking.

ASML is committed to combating all forms of slavery, human trafficking and forced labour. The ASML Board and senior management believe that, because of the nature of ASML’s business and the related supply chains, the risk of the company becoming involved in the support or encouragement of such practices is minimal.

ASML’s human resources, outsourcing and compliance policies and procedures are designed to ensure that the company is supportive of its employees and contractual staff at all times. The company’s suppliers and business partners are expected to operate to a similar level of high ethical and business standards.

Organisational Structure

ASML is incorporated in the UK and employs a total of approximately 230 permanent staff. ASML’s ultimate parent company is Ark Insurance Holdings Limited, incorporated in Bermuda. Ark Corporate Member Limited (ACML), Ark Corporate Member (No. 2) Limited (ACM2L) and Ark Corporate Member (No. 3) Limited (ACM3L) are capital providers to the underwriting syndicates managed by ASML. They are wholly owned by AIHL and do not have any employees or suppliers.

Business Operations

ASML is a managing agency for Lloyd’s Syndicates ARK 4020 and NOA 3902. The business consists entirely of underwriting insurance and reinsurance, along with associated management and claims activities. ASML does not act as a producer or retailer of physical goods, and has no supply chains relating to such activities. As a service organisation, ASML relies heavily on people and intellectual property rather than physical assets. Accordingly, ASML invests in its people as well as in the people of its business partners and suppliers.

Supply Chains

As a provider of insurance and reinsurance solutions, ASML’s supply chains are limited. It outsources specific functions supporting underwriting and claims activities to reputable professional firms in areas such as IT, claims servicing, internal audit, HR and investments. It also indirectly uses third parties for office management services such as security and cleaning.

ASML conducts proportionate due diligence on its suppliers and outsourced service providers. This includes reviewing relevant policies, contractual commitments and, where appropriate, supplier responses to onboarding questionnaires. Suppliers are expected to operate to the highest professional and ethical standards and to comply with all local and national laws and regulations.

As a Lloyd’s market participant, ASML makes use of a number of central services including market processing, Lloyd’s corporation oversight and banking arrangements. These services are subject to Lloyd’s central negotiation and review, which will include an assessment of the policies and procedures of the respective suppliers.

Policy on Slavery and Human Trafficking

ASML aims to ensure that there is no slavery, human trafficking or forced labour in any part of its business or supply chains. This reflects ASML’s determination to act ethically and with integrity in its relationships with suppliers and business partners, and to promote the same high standards in their operations.

ASML operates a comprehensive set of risk management policies and procedures designed to identify and mitigate a wide range of risks, including the company’s Outsourcing Policy, Whistleblowing Policy, Compliance Policy and Financial Crime Policy.

Whilst it recognises that the overall risk of modern slavery in its operations is low, ASML will continue to monitor and review the potential for such risks in its outsourced services, particularly in areas such as facilities management. Any identified concerns will be addressed through engagement, contractual controls and, where necessary, escalation.

Training and Awareness

In order to promote awareness of the risks of slavery and human trafficking, management will communicate this policy to all ASML staff, include it as part of the induction materials provided to all new employees and make it available on the ASML website.

Board Approval

This statement was approved by the Board of Directors of Ark Syndicate Management Limited on 5th November 2025.

The Group Chief Executive has approved this statement on behalf of the entities listed below.

Signed: Neil Brothers, Risk and Compliance Director
Signed on behalf of the ASML, ACML, ACM2L and ACM3L Boards

5th November 2025