Statement on Modern Slavery, Human Trafficking and Child Labour for the year ended 31 December 2025

This statement is made in relation to the group of companies which sit under the holding company Spitfire TopCo Limited (together “BMS”). This includes BMS Group Limited and DR&P Group Limited both of which are required to make a statement pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”).

BMS is committed to social and environmental responsibility and to the fair and humane treatment of people in its employment and supply chains. This statement sets out the steps that BMS has taken to ensure that modern slavery and human trafficking is not taking place in any part of its business or in its supply chains.

Organisational structure and supply chains

BMS is an international insurance and reinsurance broking business headquartered in London. It operates across Europe, the Middle East, Latin America, the USA, Canada, Australia, New Zealand and Asia, employing over 2,000 people. Its subsidiary DR&P Group Limited is a UK specialty insurance broking business with offices in the UK and Europe.

BMS is an organisation which provides professional services and, as such, its operations and supply chain consist primarily of office-based professionals. There is limited exposure to areas with a greater risk of modern slavery and human trafficking such as cleaning services and travel and accommodation providers. Notwithstanding this, BMS operates rigorous policies and processes to minimise the risk of the abhorrent practices of modern slavery and human trafficking in its own business and supply chains, which will not be tolerated.

BMS’s organisational structure provides layers of oversight, with Group corporate functions providing oversight and support to local leadership, who monitor adherence to local laws and regulations. This is mirrored through the BMS governance structure, which continues to enhance and reflect the structure of the business.

Policies in relation to Modern Slavery

In order to ensure commitment across the business to ethical working, BMS operates a ‘top down’ approach to compliance with policies, headed by leadership, with senior level accountability.

BMS has in place a code of conduct, which commits the organisation and its employees to conduct themselves in accordance with applicable laws and regulations, and to act with honesty, integrity and trust. We also have a Supplier Code of Conduct which makes clear the standards and expectations regarding the ethical, sustainable, and socially responsible practices we expect our suppliers to uphold. All new suppliers are required to accept this code.

BMS is committed to the welfare of all of its employees, including in terms of pay, working hours, environment, health & safety and wellbeing. BMS has implemented various policies and processes aimed to minimise the risk of occurrence of modern slavery and human trafficking, including but not limited to ESG, Dignity at Work, Anti-Bribery and Whistleblowing. Our Risk & Compliance Committees review and approve these policies on a regular basis. In the UK, BMS is a Living Wage employer, ensuring that all employees and any dedicated contractors, such as cleaners, are paid the living wage.

BMS has in place procurement policies and an independent annual benchmarking of its ESG credentials which encompasses a review of its approach to risks within the supply chain. BMS is committed to striving for continuous improvement to its policies, processes and practices in relation to its employees and supply chains, including those pertaining to modern slavery and human trafficking, and these are subject to ongoing review.

Assessing and Managing Risk

BMS carries out ongoing assessment of the risk, both external and internal, of modern slavery and human trafficking, including country risks, sector risks and business partnership risks within its operations and supply chain. In 2025, each business, through their risk and compliance leads, assessed their adherence to the Group policy suite. This self-assessment of adherence was reported to the relevant Risk & Compliance Committees and the Group Audit and Risk Committee.

Through the three lines of defence model, we test controls through Internal Audit, Compliance Monitoring and other External Assurance. Actions arising from these activities are monitored through to completion, which helps drive continuous improvement.

Specific procedures to further mitigate risk include employment screening conducted in collaboration with Vero in line with relevant employment laws and annual salary benchmarking, ensuring reward is aligned with the expected standards of conduct, and wellbeing initiatives to support employees’ physical and mental health.

Due Diligence

BMS trades with over 2,000 suppliers world-wide and operates a supplier risk management system to perform thorough due diligence across a range of indicators including suppliers’ modern slavery policies. All suppliers are regularly reviewed to reconfirm their compliance with modern slavery legislation. Using an external third-party service provider (Moody’s), we conduct adverse media screening for indicators of modern slavery risk, we monitor publicly available information relating to human rights concerns, and we assess suppliers for potential red flags, including allegations of forced labour.

Monitoring and Evaluation

There have been no reported incidents, across any disclosure routes, related to suspected modern slavery, or human trafficking at BMS during 2025.BMS distributes an annual Culture Survey to monitor progress towards its goals and evaluate employee feedback. The 2025 survey indicated that employees feel confident in reporting risks and concerns to the business and are well-informed about the procedures for doing so.

Training

BMS has implemented Inclusive leadership training in collaboration with The Communication Practice, alongside Sexual Harassment Training delivered by the law firm Clyde & Co, as part of its mandatory training programme for senior leadership. BMS also provides inclusive recruitment training for recruiting managers, in collaboration with The Clear Company. In conjunction with the acquisition and integration of David Roberts & Partners into BMS, a dedicated workstream has been established to ensure the rollout of BMS’s mandatory training programme across the wider group. The mandatory training modules are reviewed and updated on an annual basis.

During 2025, BMS also provided ‘Speaking Up’ training sessions, led by the Communication Practice, to employees globally. One of the aims of these sessions was to give employees confidence in calling out inappropriate behaviour.

Future steps

Under the leadership of the Group Head of Procurement, BMS will continue to refine its procurement strategy and due diligence procedures to embed ESG, including modern slavery risks. We will continue to ensure all Procurement staff are trained in recognising and responding to indicators of modern slavery.

As BMS continues to grow as a business, the number of relationships in its supply chains will increase. BMS will continue to build out and improve its processes to accommodate such changes and to ensure that appropriate steps continue to be taken to manage the risk of modern slavery and human trafficking

We will develop standard terms of business including obligations for suppliers to comply with legislation pertaining to the fundamental human rights of their employees, including but not limited to the provisions of the Act and where possible to extend those provisions to their sub-contractors. Modern slavery issues will also be addressed in contracts where it is not possible to contract on our standard terms.

In addition, BMS will continue to embed both Employee and Supplier Codes of Conduct in our day-to-day operations, both of which serve as statements of our commitment to honesty, integrity and the highest ethical standards within the organisation and its supply chain.

During 2026, BMS will implement a formal annual policy attestation where each CEO will attest to their adherence to the Group policy universe.

This statement has been approved and authorised by the Board of Directors of Spitfire TopCo Limited and of BMS Group Limited.

Nick Cook

Director

Spitfire TopCo Limited