Norway Transparency Act

Introduction

This statement is made pursuant to section 5 of the Act relating to enterprises' transparency and work on fundamental human rights and decent working conditions ("The Transparency Act"). It constitutes Arthur J. Gallagher (Norway) Holdings AS (the "Company"), its subsidiaries and associate companies' (together the "Organisation", "our", "we" or "us") statement on fundamental human rights and decent working conditions.

This statement sets out the steps that we have taken, and continue to take, to ensure that fundamental human rights and decent working conditions are upheld and respected in every part of our business, including throughout our supply chains and other business relationships.

Our ethics

We have zero tolerance to any form of abuse of, or adverse impact on, fundamental human rights and decent working conditions, and are committed to enforcing effective systems and controls to ensure neither is taking place in any part of our business or in any of our supply chains. Social impact is an important part of our ongoing commitment to ethics and has been since Arthur J. Gallagher was founded in 1927. Our leadership sets the tone for our distinct culture and senior level accountability demonstrates commitment to ensuring we do what is right for our customers and the communities that we operate in. Since 1927, Gallagher has led with integrity, ethics and purpose — consistently recognized by organizations such as JD Powers & Associates, Forbes, Fortune 500, Ethisphere and the Human Rights Campaign.

Group structure

The Organisation is part of the Arthur J. Gallagher & Co's group of companies (the "Group") that provides insurance brokerage and consulting services, and third party claims settlement and administration services to clients globally. The Group has approximately 71,000 employees worldwide and approximately 35 employees in Norway.

Our business

The main operating companies are; Gallagher Norway AS and Gallagher Re Nordic AS, each a regulated insurance intermediary firm in Norway. Gallagher Norway AS is an insurance brokerage, serving clients in Norway and internationally within shipping, offshore, energy, and renewable industries. Gallagher Re Nordic AS provides reinsurance risk placement, risk consulting, underwriting services, and claims management, across a wide spectrum of insurance classes.

Our supply chain

Being a financial services organisation, that does not produce, manufacture or retail goods, we do not operate in an industry where adverse impacts on fundamental human rights and decent working conditions are prevalent. We do employ external service providers for maintenance and support of our offices, including cleaning and technical support services for office infrastructure and IT, and for outsourcing certain functions ordinarily performed by the Company.

Common with other financial services organisations, the Organisation utilises business process outsourcing services from India. An important difference, is that the service provider in India (known as the ”Gallagher Centre of Excellence” or ”GCOE”) is part of the Gallagher Group rather than a third-party business process outsourcer and all staff are Gallagher employees. They perform various functions that are essential to the delivery of services to our clients. GCOE continues to subscribe to how we manage the risk of adverse impacts on fundamental human rights and decent working conditions and integration of our policies and training is ongoing covering, amongst other things employee well-being and risk management.

Our policies and governance

The Organisation is also committed to adhering to the highest standards of moral, professional, and ethical behaviour, and acting with integrity and transparency in all our business relationships. We therefore expect our supplier network, or those involved in procurement for the Organisation, to comply with the Gallagher Global Standards of Business, which is available to view by accessing https://www.ajg.com/us/about-us/global-standards/.

A Professional Standards Manual ("PSM") is in place and accessible by all staff. This suite of core policies reflects the shared values of the Gallagher Way, and Gallagher Global Standards of Business, reinforcing the Organisation's commitment to upholding the highest professional standards, and ethics, both in the workplace and in business dealings with others.

In addition to the Gallagher Global Standards of Business and PSM, the Organisation has various policies and processes in place that aim to minimise the risk of adverse impacts on fundamental human rights and decent working conditions, and encourage reporting of any related concerns, including:

• Procurement Policy that implements a proportionate supplier assessment process and establishes due diligence requirements.
  • The Organisation includes a specific requirement for compliance with modern slavery legislation in its standard terms and conditions and contractual arrangements.
  • In addition, the Organisation utilises its Outsourcing & Critical Supplier Committee (that performs an oversight function) to set the standards for material supplier performance and assessment of suppliers' approach to social responsibility.
• A Supplier ESG Attestation Questionnaire, which includes Modern Slavery and Labour Standards. Through this, the Organisation gains assurance of third party compliance with applicable regulations and richer insights into the policies and practices applied throughout our critical supply chain.
• Third Party and Client Vetting Policy for business relationships other than suppliers establishes a proportionate risk assessment process and due diligence requirements.
• A Whistleblowing Policy that ensures all employees know how to raise concerns about how colleagues are being treated or regarding practices within our business or supply chain, without fear of reprisal.
• Recruitment Policies that, amongst other things, mitigate the use of external agencies that do not adequately safeguard individuals offered for roles or are employed by the agency. Important elements include robust Right to Work checks and background and criminal records checks.
• The 'Gallagher Way' a statement of Gallagher shared values which acts as the foundation that underpins the Group culture.

Risk assessment and management

We actively assess, prevent, and manage risks related to human rights and working conditions. Our Outsourcing & Critical Supplier Committee and Supplier ESG Attestation Questionnaire play crucial roles in identifying and assessing risks. We prevent and manage risks through structured measures, regular assessments, and employee support resources.

Training

Our global "Leading with Integrity" training module, which is assigned to all new and existing employees on an annual basis, includes a segment on modern slavery.

It includes information on who staff should contact should they have any concerns about modern slavery. Staff are also encouraged to report any concerns or suspicions about modern slavery within the supply chain.

In the past year we have developed tailored Modern Slavery training for colleagues in procurement, human resources and recruitment to raise awareness of modern slavery, specific risks to identify and the effective reporting of any human trafficking concerns.

Looking ahead, continuous improvement and ambition

We regularly evaluate our operations and supply chain to identify any risks or areas for improvement. Gallagher embraces a culture of continuous improvement and the implementation of best practices, and our ESG Committee leads efforts to shape policies.

Looking ahead, we aim to perform gap analyses, consultancy, training, and site assessments, utilising external risk consultants when required. We remain vigilant in monitoring and reporting any suspected instances of non-compliance and encourage colleagues to report through appropriate whistleblowing channels.

Psychosocial work environment compliance

Effective January 1, 2026, The Working Environment Act has updated the requirements concerning the documentation on compliance with the legal requirements for the psychosocial work environment. These updates emphasize the importance of preventing work-related stress, bullying, and harassment, while also promoting well-being and collaboration within the workplace. The law now requires employers to implement more structured measures to assess and improve the psychosocial conditions of their work environment.

The company has long been committed to maintaining a positive psychosocial work environment, and we are well-prepared to meet these updated requirements. While we already have robust strategies in place, we are dedicated to further enhancing our efforts to comply with these legal requirements. We regularly conduct assessments of our workplace environment and foster an inclusive culture that encourages open communication and mutual respect among employees. Mental health and stress management were the topic of our all hands meeting Q2 2025, Underscoring their importance within our organization.

Our commitments include:

• Regular assessments: We will maintain our practice of conducting periodic evaluations of the psychosocial work environment to identify areas for improvement and ensure ongoing compliance.
• Support resources: We provide employees with access to Employee Assistance Programs, flexible work arrangements, and regular check-ins with line management to support them in managing stress, preventing bullying and harassment, and promoting overall well-being and collaboration.
• Inclusive culture: We continue to promote a workplace culture that values diversity, inclusion, and open dialogue, ensuring all employees feel supported and respected.

In addition, our ambition is to achieve the following:

This statement has been approved by the Directors of the Board for and on behalf of Arthur J. Gallagher (Norway) Holdings AS, its subsidiaries and associate companies, on 30th June 2025.