Introduction
This modern slavery and human trafficking statement ("statement") is made pursuant to section 54 of the Modern Slavery Act 2015. It applies to Arthur J. Gallagher Holdings (UK) Limited, each of the companies listed in Appendix 1, and the UK branch of Arthur J. Gallagher Nordic AB, a company incorporated and regulated in Sweden (together referred to as the "Companies", "our", "we", or "us").
This statement is in respect of the financial year ending 31 December 2025 and outlines the steps that we have taken and continue to take to ensure that modern slavery and human trafficking are not taking place within any part of our business or in our supply chain.
Our Ethics
We remain focused on ensuring that neither slavery nor human trafficking takes place in any part of our business or supply chains. Integrity and ethical conduct have been at the centre of the ultimate parent of the Company, Arthur J. Gallagher & Co.'s culture since its founding in 1927.
Our leadership sets the tone for our distinct culture, promoting that we act responsibly and uphold professional standards in our interactions with clients, colleagues and the communities in which we operate.
Group Structure
Arthur J. Gallagher & Co., its subsidiaries and affiliates (the "Group"), employs over 70,000 employees worldwide, of which over 9,000 are based in the United Kingdom.
Our Business
The services we offer encompass (re)insurance risk placement, risk consulting, underwriting services, and (re)insurance claims management. These services span a wide spectrum of insurance classes and are provided to both commercial and personal lines customers as well as insurers.
Our Supply Chain
We maintain governance and control framework for supplier oversight. This framework includes an auditable sourcing and evaluation processes for supplier selection, the agreement of transparent contractual terms, and continuous monitoring of supplier performance and risk.
Suppliers used by the Companies include providers of office maintenance, facilities management, cleaning, IT infrastructure support, consultancy, HR services and the outsourcing of operational functions which are outsourced operational functions ordinarily performed by the Companies.
The Companies also utilise business process outsourcing services in India and Sri Lanka. These operations are part of the Group, and all staff supporting our work are Group employees rather than third-party business process outsourcers. They are focused on meeting our standards and align with our management approach on modern slavery, labour practices, employee wellbeing and risk reporting and have ongoing training in these areas. This includes addressing employee well-being, risk management, with processes established for risk event reporting.
In 2025, we undertook a physical review of our India operations as part of an ongoing programme to verify the working environment. Gallagher's India based Operational Centre of Excellence ("GCOE"), conducted a modern slavery risk assessment of its supplier base and issued a modern slavery attestation questionnaire to its top 24 suppliers, achieving a 100% response rate.
Due Diligence Process
Our procurement team require new suppliers to complete a Request for Information ("RFI"), as part of the selection and on-boarding process, to assess their ability to comply with a range of requirements including legal, regulatory and financial. This includes compliance with modern slavery and human trafficking reporting requirements.
As determined by spend and risk, our critical service suppliers to the Companies are also required to provide comprehensive information and disclosures through a Supplier Attestation Questionnaire. This includes modern slavery, human trafficking and labour standards, and aids us in continuously improving our approach to supply chain management and the prevention of modern slavery and human trafficking.
Our supplier attestation process is designed to assess how well our critical suppliers embed ESG principles across areas such as ethical conduct, labour standards, health and safety, whistleblowing, and governance and was expanded in 2025 from 64 to 85 questions. The framework now spans 13 risk domains, following the 2025 addition of operational resilience and fourthparty management.
The Insights gathered support our continuous improvement of supplier oversight and alignment with responsible business practices.
Our Policies and Governance
The Companies are focused on upholding the highest standards of moral, professional, and ethical behaviour. We prioritise acting with integrity and transparency in all our business relationships. We therefore expect our suppliers to comply with the Gallagher Global Standards of Business. These standards can be accessed by visiting:https://www.ajg.com/about-us/global-standards/.
The 'Gallagher Way' serves as a statement of our shared values and forms the foundation that underpins the Group culture. In addition, a Professional Standards Manual ("PSM") is in place and accessible by all staff. We consider that this suite of core policies promotes the highest professional standards and ethics, both within the workplace and in our business dealings with others.
The Companies have various policies and processes aimed at minimising the risk of modern slavery and human trafficking. These measures also encourage the reporting of any concerns related to these issues. Some of these policies and processes include:
- A Modern Slavery Policy, which outlines the expected behaviours for all employees and provides guidance on the reporting procedure and obligations.
- A Procurement Policy, which implements a proportionate supplier assessment process and establishes due diligence requirements.
- Supplier Code of Conduct, which is issued to all critical service suppliers to the Companies, outlines our expectations in terms of ethical conduct, human rights, labour practices, and environmental stewardship. By adhering to these principles, we aim to foster a responsible and sustainable supply chain.
- A Whistleblowing Policy, that ensures all employees are aware of how to raise concerns about the treatment of employees or any practices within our business or supply chain, without fear of reprisal.
- Recruitment Polices that, amongst other things, mitigate against the use of external agencies that do not adequately safeguard individuals offered for roles. Important elements include robust Right to Work checks, as well as background and criminal records checks.
- Where relevant, we aim to incorporate a requirement for compliance with modern slavery legislation into our standard terms and conditions and contractual arrangements.
- Our Outsourcing & Critical Supplier Committee, which performs an oversight function and sets the standards for material supplier performance and assessment of suppliers' approach to social responsibility.
- In 2025, we introduced comprehensive supplier audits for critical suppliers. These audits incorporated ESG and modern slavery elements, providing a strengthened layer of supply chain assurance and oversight.
Training
All new employees undergo training as part of their induction programme, which includes information on who they should contact if they have any concerns about modern slavery or human trafficking. Employees are also encouraged to report any concerns or suspicions regarding the presence of modern slavery or human trafficking within the supply chain.
In 2026 and beyond, we plan to:
- Engage with an external organisation, such as Slave Free Alliance or a similar body, to benchmark Gallagher against industry peers and identify further opportunities for control enhancements.
- Conduct an onsite assessment of our newly opened Manila operation centre.
- Progress any actions and opportunities identified through the India 4th party Modern Slavery Attestation responses.
- Extend UK modern slavery training to all GCOE people managers.
- Continue our ongoing work with the Companies' critical service suppliers, including addressing any improvement actions that arise from the Supplier Attestation Questionnaires.
- Periodically review and update our Supplier Attestation, Supplier Code of Conduct and other governance frameworks.
- Continue to work alongside our partnerships and to collaborate with industry.
- Conduct additional audits on our critical suppliers.
- Undertake modern slavery due diligence checks where we explore intra-group services from new overseas territories.
Approval
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and was approved by the Board of Arthur J. Gallagher Holdings (UK) Limited on 7 May 2026.
Appendix 1
- Arthur J. Gallagher (UK) Limited
- Arthur J. Gallagher Insurance Brokers Limited
- Alesco Risk Management Services Limited
- Pen Underwriting Limited
- Arthur J. Gallagher Services (UK) Limited
