MODERN SLAVERY STATEMENT

This Statement has been published in accordance with the Modern Slavery Act 2015 and relates to the financial year ending 31 December 2025. It outlines the steps that Apollo Syndicate Management Limited (ASML), a Lloyd’s managing agent, and all entities in the Apollo group have taken and are taking to ensure that human trafficking and modern slavery are not taking place within its business or supply chains.

1.1 ASML Business

ASML is an independent specialist insurer and reinsurer operating across a number of specialty lines. ASML offers adaptable and flexible underwriting services at Lloyd’s and leads a number of London market consortia, through an empowered, inclusive and diverse team. ASML’s parent company, Apollo Group Holdings Limited (“Apollo”) was acquired on 1 January 2026 by Skyward Specialty Insurance Group Inc which is headquartered in Houston, Texas, United States of America.

ASML’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. ASML creates value through innovation, creativity and service excellence, as well as through a sustainable approach to the community and environment. ASML manages eight syndicates 1969, 1971, 1972, 3939, 2454, 1100, 2546 and 1994, as well as a special purpose arrangement SPA 1925. 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 1972, Reshare, provides follow only capacity on the outwards reinsurance programmes for Apollo managed syndicates, specifically 1969 and 1971.

ASML also provides bespoke third-party managing agency services. ASML provides syndicate management services for the following: Syndicate 3939, NormanMax, aims to close the insurance gaps left by traditional insurance by providing parametric solutions across diverse international jurisdictions. Syndicate 2454, Africa Specialty Risks, is the first Africa-focussed syndicate at Lloyd’s. Syndicate 1100 is the first captive at Lloyd’s and provides first party and related third party cover for an International Tech Company. Syndicate 2546, Coface, is a short-term trade credit insurance specialist. Syndicate 1994, Compre, provides legacy reinsurance solutions. SPA 1925, Envelop, is a leader in Cyber reinsurance. ASML has one office located within the UK with staff primarily being based in the UK. Within the Apollo group, ASML outsources its operational functions to Apollo Partners LLP.

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.

‘Aligned to our purpose’ 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. ASML has an ‘ESG Committee’ whose purpose is to help 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 Apollo 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;
  • 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;

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.

1.5 Training

All Apollo employees have a responsibility to report any suspicious activity or if they believe a law may have been violated. ESG Committee 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.

1.6. Modern Slavery KPIs

ASML has the following Modern Slavery KPIs in place to monitor anti-slavery action:

  • Number of modern slavery training sessions given to employees.
  • Number of suppliers (catering, cleaning, office maintenance, IT support, IT software development) engaged and due diligence processes.
  • Number of cases of modern slavery discovered in our supply chain via our due diligence work and assessments.
  • Number of modern slavery or related complaints actual or alleged raised via formal or informal channels.
  • Number of speak-up cases related to modern slavery or related issues.

These KPIs are regularly reported to the ASML Board.

1.6 Approval

This statement was approved by the ASML Board on 14th May 2026.  This statement forms part of the ASML and subsidiary entity financial reporting statements.

Signed by:

David Ibeson

Chief Executive Officer