This statement outlines the steps that Apollo Syndicate Management Limited (ASML) and all managed entities have undertaken to ensure that human trafficking and modern slavery are not taking place within its business or supply chains.

1. ASML Business
ASML is an independent specialist insurer and reinsurer across a number of specialty lines. Apollo offers adaptable and flexible underwriting services at Lloyd’s and leads a number of London market consortia, through an empowered, inclusive and diverse team.

Apollo’s market-leading talent has allowed the business to spearhead sharing economy initiatives such as ibott (“insuring businesses of tomorrow, today”), as well as to form a diverse portfolio of long term partnerships. Apollo creates value through innovation, creativity and service excellence, as well as through a sustainable approach to the community and environment. ASML manages three syndicates, 1969, 1971, and 1994, as well as a special purpose arrangement syndicate 6133. Syndicate 1969 writes across a range of classes of business including Property Binding Authority, Property Direct & Facultative, Property Treaty, Crisis Management, Cargo & Specie, Marine & Energy Liability, Casualty/Liabilities, Speciality Disruption, Product Recall, Marine Hull, and Energy & Aviation. Syndicate 1971 is a market leader specialising in the sharing economy. Syndicate 1994 provides legacy reinsurance solutions and has been created through a strategic partnership with Compre Group. SPA 6133 is currently being managed to an orderly run off and no longer writes business with effect from January 2022.ASML has one office located within the UK with staff primarily being based in the UK.

ASML utilises outsourced business processing and operational services from RMS and WNS who operate from India, and Compre also have an office in Malta. Both ASML and Lloyd’s of London are regulated by the Financial Conduct Authority and the Prudential Regulation Authority.

1.2 ASML Approach
Part of ASML’s vision is to achieve market-leading returns through a sustainable approach to our community and environment. These are further supported by the ASML ESG strategy which is publicly available and aims to hold the ASML Board accountable for all ESG-related issues as well as to drive positive action.

The ASML vision and purpose are underpinned by a set of Values which are at the heart of everything ASML does.



These values aim to ensure we continue to develop, challenge and remain committed to creating a diverse and inclusive workplace.

‘Taking responsibility for our impact on others’ is one of the key values and clearly aligns with a commitment to preventing modern slavery both within ASML operations and its broader supply chain. The ASML Board has an ‘ESG Group’ whose purpose is to help to steer ASML’s ESG strategy and identify areas for development. The ASML ESG Strategy is aligned to five of the 17 UN Sustainable Development Goals, three of which are supported by helping eradicate modern slavery:

  • Good health and well-being
  • Decent work and economic growth
  • Reduced inequalities

1.3 Polices and Governance

ASML operates under the three lines of defence model which includes a full suite of policies as well as a mature Risk Management framework embedded throughout the organisation to ensure ASML effectively identifies, controls and mitigates risks throughout the business.

All ASML employees are required to confirm that they have read the Employee Handbook as part of their induction process. The Employee Handbook includes sections on;

Employee Conduct;

  • Apollo Code of Conduct and Ethics;
  • Zero Tolerance Bullying, Harassment & Discrimination Policy;
  • Inclusion & Equal Opportunities Policy; and
  • Whistleblowing Policy

Within the Whistleblowing Policy Employees are expected and encouraged to report promptly to management any actual or suspected:

Violations of the law, company policy or business controls;
Behaviour that harms or is likely to harm the reputation or financial well-being of Apollo

Instances of financial crime (including facilitation of tax evasion, sanctions breaches, fraud, bribery and corruption and money laundering)
Unfair treatment of any Apollo customer by Apollo or any of its appointed third parties.

The policy also includes information on how employees can raise any concerns externally should they not feel able to do so via the internal channels.

In addition to the Employee Handbook ASML has several other relevant policies:

  • Compliance Policy
  • Conduct Policy
  • Delegated Authority Policy
  • Operational Resilience Policy
  • Financial Crime Policy
  • Outsourcing Policy
  • Recruitment Policy

1.4 supply chain

ASML has a wide range of suppliers that provide a variety of services. As an insurance company the principal supply chains are not ones that would be regularly associated with modern slavery practices. However, ASML still conducts a due diligence process when onboarding all new suppliers and material suppliers will undergo a regular audit process. ASML is committed to ensuring that modern slavery and human trafficking are not part of any of our supply chains.

1.5 Training

All ASML employees have a responsibility to report any suspicious activity or if they believe a law may have been violated. In addition to this the members of the ESG Group have undergone specialist Modern Slavery Training provided by Unseen. ESG Group members as well as executive committee members and employees who engage directly with suppliers have also received an online training module relating to modern slavery to help them identify and report any potential modern slavery or human trafficking activity more effectively. ASML encourages an open office and communicative culture among all employees and suppliers’ staff to help identify any signs of exploitation.

1.6 Approval

This statement was approved by the ASML Board on 29.06.22. This statement forms part of the ASML and subsidiary entity financial reporting statements.

Signed by:

David Ibeson
Chief Executive Officer