ERGO Group AG Statement on the UK Modern Slavery Act

This statement is made pursuant to section 54 (1) of the UK Modern Slavery Act 2015 and constitutes ERGO Group AG‘s slavery and human trafficking statement for the financial year ending 31 December 2024.

The organisation’s structure, its business and its supply chains

ERGO is one of the major insurance groups in Germany and Europe. With operations in over 20 countries, the ERGO Group offers a comprehensive spectrum of insurance, provision and services.

In the financial year 2024, ERGO recorded a total premium income of 21 billion euros. It operates in all lines of primary insurance, with about 37,000 employees and sales agents throughout the world. At the end of 2024, the ERGO Group’s investments amounted to 138 billion euros.

ERGO Group procures many different goods and services throughout the world. In our procurement decisions and activities, we aim to assume corporate responsibility along the value chain. Environmental, social and governance (ESG) criteria play an important role for us in the procurement of goods and services.

Group policies in relation to slavery and human trafficking

Responsible behaviour is the foundation on which ERGO Group creates value for and with all its stakeholders. We are convinced that we can only successfully implement our business model by making choices based on a long-term, sustainable perspective.

Respect for human rights is fundamental. We are committed to upholding human rights in line with internationally accepted principles and the United Nations Guiding Principles on Business and Human Rights.

The following international guidelines and standards are recognised:

• The International Bill of Human Rights:
  • Universal Declaration of Human Rights
  • International Covenant on Civil and Political Rights
  • International Covenant on Economic, Social and Cultural Rights
• ILO Declaration on Fundamental Principles and Rights at Work
• United Nations Guiding Principles on Business and Human Rights
• 10 Principles of the UN Global Compact
• Principles for Sustainable Insurance (PSI)
• Principles for Responsible Investment (PRI)

Key human rights principles include:

• Safe and dignified working conditions: including prohibition of child labour, forced labour, modern slavery and human trafficking.
• Equality and non-discrimination: no discrimination based on disability, age, gender, ethnicity, nationality, religion or other factors.
• Adequate living conditions: protecting communities and minimising environmental harm.

Due diligence and risk management

We aim to prevent or mitigate adverse impacts on human rights through structured processes including:

• Risk management systems with defined responsibilities
• Regular risk analyses
• Preventive and remedial measures
• Monitoring effectiveness
• Whistleblowing systems
• Documentation and reporting

ERGO Group has adopted a human rights policy defining compliance requirements for employees and suppliers.

Governance

The ERGO Group Human Rights Officer oversees risk management and reports annually to the Board of Management.

Risk analysis

We conduct structured risk analyses across our supply chain. Key areas include:

• Employees
• Procurement
• Core insurance business
• Investments

Additional analyses are conducted when risks change or new activities arise.

Identified risks

Risks identified include:

• Freedom of association limitations in certain countries
• Potential discrimination or unequal treatment
• Supplier-related risks in specific product categories

Suppliers are required to follow ERGO’s Code of Conduct and may be subject to case-by-case reviews.

Whistleblowing management system

Human rights concerns can be reported via ERGO’s whistleblowing portal, accessible globally and confidentially.

All reports are investigated and appropriate action is taken where necessary.

Insurance

Enhanced risk assessments are applied to certain large commercial clients where higher risks of human rights violations may exist.

Preventative and remedial measures

Where risks or violations are identified, ERGO implements appropriate measures, potentially involving the Reputational Risk Committee.

Documentation and reporting

ERGO Group reports as part of Munich Re’s non-financial reporting and PRI disclosures.

Training and awareness

Employees receive regular training on the Code of Conduct, including human rights, equal treatment, and reporting mechanisms.

Progress in the financial year 2024

No significant human rights risks or violations were identified during 2024. Risk analyses and due diligence processes remain consistent with previous years.

No serious complaints were received via whistleblowing channels.

Approval

This statement was approved by the Board of Management of ERGO Group AG on 26 May 2025.

Düsseldorf, June 2025

Dr. Markus Rieß
Chairman of the Board of Management
ERGO Group