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About us

Slavery and Human Trafficking Statement

This is AXA Global Healthcare (UK) Limited’s sixth annual Modern Slavery Statement. It is  made in accordance with section 54 of the UK Modern Slavery Act 2015 (the “Act”) and  covers the financial year ending 2025. The statement is made on behalf of AXA Global  Healthcare (UK) Limited and its associated companies, (together, “AGH” and part of the AXA  Group). This statement covers AGH’s direct operations and supply chains.

Modern slavery is a fundamental violation of human rights. We have zero tolerance for these  practices in any part of our business or supply chain. AXA’s purpose is to act for human  progress by protecting what matters. What matters has always included the communities we  live in and work with across the globe. We are committed to protecting people, supporting  our communities and working responsibly with all our partners, and we welcome the  transparency promoted by the Act.

AXA has a long history of promoting human rights and responsible business practices. We  support international standards such as the UN Guiding Principles on Business and Human  Rights, the International Labour Organisation’s conventions and the UN Global Compact,  which AXA Group has been a signatory to since 2003. This statement sets out the steps we  have taken in 2025 to reduce the risk of modern slavery in our operations and supply chains,  and our plans to continue strengthening our approach.

At a glance

We are committed ensuring there is no place for modern slavery in our business or supply  chain. We have:

  • Continued to train our people so they know how to spot and report concerns.
  • Supported international standards on human rights and responsible business.

We know there is always more to do. In 2025 we have built on this work by deepening  supplier engagement, enhancing our risk assessments, and increasing transparency in how  we report progress.

Reporting Companies’ Structure and Business

AGH is part of the AXA Group, one of the world’s leading insurance and asset management  companies. In the UK, we employ around 400 people. AGH is an intermediary supporting the  distribution, administration and coordination of international private medical insurance  activities direct to the customer as well as to the SME, mid-market and large corporate  sectors, via agents, brokers, aggregators and in conjunction with corporate partners. The product offer also includes a range of health and well-being services.

Reporting Companies’ Supply Chains 

Our supply chain is wide-ranging and supports the delivery of these products and services. It  includes thousands of suppliers providing IT, professional services, facilities management,  property services, health services and claims-related services such as repair and  replacement of goods.

Behind every service we deliver is a network of suppliers we rely on.

AGH’s supply chains include suppliers of IT and communications, data, property, facilities  management, office equipment and supplies, catering, marketing services and professional  services such as legal, auditing, banking and personnel recruitment. These suppliers range  from global strategic partners to local service providers who play a vital role in helping us  serve our customers.

We recognise that some suppliers, particularly those providing manual or outsourced  services, may present higher risks of labour exploitation. That is why we set clear standards  for all our suppliers and monitor compliance with our requirements.

Engagements and policies in relation to modern slavery and human trafficking

We are committed to respecting human rights and making sure modern slavery has no place  in our business or supply chain. Our approach is shaped by international standards,  including the UN Guiding Principles on Business and Human Rights, the International  Labour Organisation’s core conventions, and the UN Global Compact, which AXA has  supported since 2003.

To put these commitments into practice, we have a number of policies and codes that guide  how we work:

  • AXA Group Human Rights Policy – (updated in 2026) which is based on an  assessment AXA uses to identify the human rights that could be impacted by the  business activities of insurance companies (i.e. insurance, investment, own  operations) and to define priority areas for human rights due diligence at AXA. The  policy aims at preventing human rights abuses and reflects AXA’s adherence to the  general and sectoral international standards mentioned above. The Policy sets up  AXA’s approach to human rights with respect to its different activities: as a  responsible company (as an employer and as a business partner), insurer and  investor.
  • AXA Group Compliance and Ethics Guide – (updated in 2024) which applies to all  employees and subsidiaries worldwide establishes guiding principles to treat its  customers fairly and professionally by being honest and accountable when promoting  products and services. Senior Officers at AGH are required to submit an annual  certification confirming that they comply with the Guide, and they ensure their teams  are aware of its contents. Employees are encouraged to raise any concerns through  local whistleblowing channels if they believe behaviours fall short of the standards in  the Guide.
  • AXA Group Vigilance Plan (the “Vigilance Plan”), adopted by AXA S.A. to comply  with the requirements of the French "devoir de vigilance" law, sets out the reasonable  vigilance measures established and implemented by AXA to identify risks and prevent  serious violations to human rights and fundamental freedoms, health and safety of  individuals and the environment resulting from AXA’s activities and those of the  companies it controls, directly or indirectly, as well as from the activities of  subcontractors or suppliers with which AXA entities have an established business  relationship, when these activities are related to this relationship. The Vigilance Plan  describes AXA’s existing system of internal control and risk management which  includes a number of tools and procedures implemented within AXA to support  enforcement of AXA standards and policies in operating entities and compliance with  applicable regulations and describes AXA’s procurement processes. The monitoring of  the implementation of vigilance measures and assessing their effectiveness, is carried  out, at a high level, by AXA’s system of internal controls and in addition, AXA relies on  a self-assessment reporting process for certain AXA entities. For more information on  procurement processes and the gaps identified by the self-assessment conducted in  2025, please refer to the Vigilance Plan set out at Section 4.7 of the 2024 AXA  Universal Registration Document (URD)1.
  • AXA Global Healthcare Whistleblowing Policy - allows employees to raise  concerns confidentially, including any concerns about modern slavery. This is  overseen by our Whistleblowers’ Champion, Ian Johnson, Non-Executive Director  and Chair of the AGH Audit, Risk & Compliance Committee.

The AXA Group Human Rights Policy, the Guide and the principles and standards mentioned  above all apply to AGH. These policies are more than documents – they shape how we  expect our people and partners to act every day. For example, suppliers must agree to our  Sustainability Clause, which explicitly prohibits the use of child or forced labour.

These commitments reflect our belief that protecting our communities is everyone’s  responsibility – from the way our employees act, to the standards we set for our suppliers.

Management of the modern slavery and human trafficking risk in our supply chain

We know that some areas of our business and supply chain carry higher risks of modern  slavery than others. These risks are most likely where work is outsourced or where services  involve manual labour - for example cleaning, catering, security or facilities management.

As part of the updated Sustainability Procurement Guidelines introduced in 2024, AGH must  carry out risk assessments across all IT, General Expenses and Insurance Procurement  contracts. These assessments categorise suppliers as high, medium or low risk, depending  on the type of contract, the country where services are provided, and how suppliers recruit  and manage their workforce.

Our supply chain plays a vital role in helping us deliver for our customers, and we want to  work with partners who share our values. The AXA Group Sustainability Clause is mandatory  in all supplier contracts and requires suppliers to respect human rights, including a clear  prohibition on the use of child labour and forced labour. In accordance with the above  process, the Companies’ applicable standard contractual terms with suppliers include  specific reference to AXA’s sustainability requirements and appropriate provisions are  included requiring suppliers to comply with applicable laws and regulations, including  applicable human rights and modern slavery legislation. Any material challenges by the  supplier to the standard wording is reviewed by AGH’s Procurement Team and other subject  matter experts to consider how best to ensure the supplier has appropriate controls in place.

For higher-risk suppliers with significant spend, we use independent third-party reviews  through EcoVadis. These assessments review labour standards, human rights, and wider  ESG performance. Any detection of a direct or indirect violation by the supplier of the AXA  sustainability requirements would be discussed directly with the supplier with a view to  establishing a mutually agreed and documented corrective action plan. Where any issue is  not resolved satisfactorily, the standard AGH provision includes a right to end its relationship  with the supplier.

We have strengthened our risk assessment processes by:

  • Requiring 100% of AGH Procurement team members to sign our Code of Ethics,  which covers confidentiality, fairness, objectivity and transparency.
  • Including AXA’s Sustainability Clause in GenX and IT contracts, enhancing our  engagement with suppliers on a wider range of sustainability topics.

Due diligence in our own operations

Our approach to managing human rights risks within AGH is guided by the AXA Group  Compliance and Ethics Guide, which sets out the principles we expect all employees to  follow. This includes acting with integrity, respecting people’s rights, and creating a safe and  fair workplace.

In practice, this means:

  • Freedom of association – employees have the right to join a union, to collective  bargaining and to open, constructive dialogue with management.
  • Fair working conditions – we comply with all employment regulations, ensuring just  and favourable terms of work, including health and safety protections. We provide  training and information so that employees understand and can manage health,  safety and wellbeing risks.
  • Diversity and inclusion – through our Diversity and Equal Opportunities Policy, we  prohibit discrimination of any kind. We seek annual feedback from all employees  through our inclusion survey, which is used to drive our D&I actions and initiatives,  overseen by our Executive Committee.

We are committed to applying the same high standards to third-party staff working on our  sites as to our own employees, ensuring they are treated fairly and in line with our values. All  of our third-party recruitment providers on our Preferred Supplier List are contractually  required to align their practices to internationally recognised standards such as the UN  Universal Declaration of Human Rights, the International Labour Organisation's core  standards (including conventions on child labour, forced labour, and non-discrimination), the  UN Guiding Principles on Business and Human Rights, the UN Global Compact, and the  OECD Guidelines for Multinational Enterprises.

This statement has been approved by the Board of AXA Global Healthcare (UK) Limited on  4th June 2026 and constitutes their slavery and human trafficking statement for the financial  year ending 31 December 2025.

Xavier Lestrade Chief Executive Officer and Director AXA Global Healthcare (UK) Limited

1AXA Universal Registration Document 2024