Modern Slavery Act Statement

MODERN SLAVERY ACT TRANSPARENCY STATEMENT FOR FINANCIAL YEAR ENDING 31 DECEMBER 2018

MODERN SLAVERY ACT 2015
The Modern Slavery Act 2015 (the "Act") came into force in March 2015 and has helped clearly define and codify offences relating to modern slavery and human trafficking.

This statement is made on behalf of Willis Limited and provides information about our business and supply chain and the steps we have taken to investigate and mitigate the risk of modern slavery and human trafficking both within our business and our supply chain.

We have explained our approach with specific regard to the six areas identified in section 54(5) of the Act and in light of the relevant official guidance.

OUR ORGANISATION
Willis Limited is based in the UK and is part of the Willis Towers Watson global group of companies. Willis Limited provides risk management, insurance and reinsurance broking services to clients in the UK and worldwide, and is regulated by the Financial Conduct Authority. Willis Limited coordinates with other Willis Towers Watson group companies in order to combat modern slavery and human trafficking.

SUPPLY CHAIN OVERVIEW
As part of the Willis Towers Watson group of companies, we have continued to take steps to identify and manage those areas in our supply chain where we believe modern slavery and human trafficking are a possibility. Our goal is to identify and minimise the risk wherever possible and to continually monitor and improve in our efforts.

We believe that the nature of our business, as a provider of professional services predominantly to corporate clients, means that we are not directly exposed to a high risk of modern slavery and human trafficking. We are nonetheless keenly aware that the possibility does exist within our global supply chains, particularly in the context of certain of our intra-group shared service suppliers located in countries considered to be of higher risk in the context of modern slavery and human trafficking.

In order to mitigate this risk we work alongside our intra-group shared services suppliers and endeavour to establish adequate procedures to tackle the risk of modern slavery and human trafficking in their supply chains and ensure their policies reflect appropriate standards for their business.

The Willis Towers Watson group of companies have taken a coordinated approach to tackling the risk of modern slavery in our business structure; and our cross-function modern slavery working group continues to coordinate a group-wide approach to the matter.

POLICIES AND GUIDANCE
The Willis Towers Watson group of companies observe a number of policies and guidance in order to ensure we conduct our business responsibly and in compliance with all applicable laws and regulations. The Willis Towers Watson group of companies expect and require our colleagues to act with the highest possible standards of ethical conduct and integrity. The policies and guidance can be accessed by our employees through the group intranet site and include the following:

  • Code of Conduct Reporting and Whistleblowing Guidance;

Training in relation to the Act, modern slavery risks and their practical implications for the procurement process has been provided to relevant personnel in key departments in both 2016 and 2017.

We continue to work with our online training partner to finalise appropriate training on modern slavery and ethical purchasing with a view to rolling this out across the Willis Towers Watson group of companies in order to improve the level of understanding of the issues throughout the business. We intend to launch this training during 2019.

FUTURE DEVELOPMENTS
We will review and develop our processes and guidance, training and supplier approach towards the detection and prevention of modern slavery and human trafficking as our business evolves.


This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2018, and has been approved by the Board of Directors of Willis Limited and is signed below by one of the company's Directors.

Nicolas Aubert

WILLIS LIMITED
Date: 20/06/2019