1. Introduction
This statement has been published in accordance with the Modern Slavery Act 2015 (the “Act”) and in line with the UK government Home Office statutory guidance. This statement applies to the Resolution Life entities set out in Annexure A (separately and together, “Resolution Life”), each a member of the Resolution Life group of entities (“Resolution Life Group”). This statement sets out the steps taken by Resolution Life during the year ending 31 December 2025 to prevent modern slavery and human trafficking occurring in its business and supply chains. The statement will be subject to an annual review each year. We will uphold all laws relevant to countering money laundering and terrorist financing in all the jurisdictions in which we operate.
2. Statement
Resolution Life is committed to actioning practices that combat modern slavery and human trafficking. We do not tolerate modern slavery or human trafficking within our business or within our supply chain. Our third-party service provider selection and governance policies and processes are designed to help ensure we deal with ethical, credible suppliers who share similar values.
3. Our Business and Organisational Structure
The Resolution Life Group serves as a long-term custodian of the life insurance and annuity portfolios that we acquire or reinsure for the primary market. This stewardship removes stranded costs and reduces long-term risk, allowing insurers to release capital and reinvest in innovation, growth and the future needs of policyholders globally. Through this model, we enable the primary market to grow while ensuring promises are honoured and financial security is protected for generations to come.
Our main customers are primary life insurers in mature markets, including the US, Asia, Europe and the UK. We serve them through our teams in the US, Singapore, the UK and Bermuda, providing bespoke solutions including:
in-force reinsurance
legal entity acquisition
flow reinsurance
transfer of operations
We invest the assets and pay the claims and, in certain instances, administer the policies.
As part of our acquisition by Nippon Life Insurance Company (“Nippon Life”), we established Acenda Group, a joint venture between Nippon Life (51%) and Resolution Life (49%). A new primary life insurer open to new business, Acenda Group includes the former MLC Life Insurance business, Resolution Life Australasia, and Asteron Life New Zealand.
History: Resolution Life Group
Since 2003 to date, prior Resolution entities together with the Resolution Life Group have deployed c.$20bn of equity in the global insurance industry and served the needs of c.14m policyholders.
Now part of the Nippon Life group, Japan’s largest life insurer, the Resolution Life Group manages c.$80bn of assets and has operations in Bermuda, the U.S., the U.K., and Singapore.
Backed by a single, well-capitalised parent, the Resolution Life Group is a safe and reliable partner for insurers. The group is focused on:
Providing capital for growth and mitigating long-term risk so the industry can respond to the needs of policyholders;
Supporting primary insurers with new sales; and
Serving existing policyholders and delivering benefits in a secure environment.
4. Outsourcing, “Supply Chains” and use of third parties
The Resolution Life Group operates in a business environment that benefits from the use of expert third parties and outsourcing arrangements. We have robust procurement processes in place that also covers Third Party Risk Management (TPRM) a full end to end cycle. We have a zero-tolerance policy on slavery and human trafficking and expect that those in our supply chain comply with our principles and core values.
We believe that the nature of our business activities results in a lower risk that a third-party service provider has involved slavery or human trafficking. That is, as an asset manager and insurance firm, the Resolution Life Group does not have extensive or distant “supply chains”, nor do we manufacture goods. We also communicate our message on responsible supply chain activities via our Supplier Code of Conduct which is published on our website. This applies to all our suppliers and their sub-contractors wherever they are based in the world.
5. Our policies and procedures applicable to slavery and human trafficking
All Resolution Life employees are required to meet the standards set within the Resolution Life Group Code of Conduct; ensuring employees make responsible decisions and achieve results using the highest ethical standards.
Further, we have a Sustainability Policy which reflects our commitment to guard against the risk of modern slavery and human trafficking issues.
The Principles for Responsible Investment (“PRI”) is a United Nations-supported initiative which promotes sustainability being incorporated into investment decisions, ownership and asset management. On 22 September 2022, the Resolution Life Group became a signatory to the UN-supported PRI, demonstrating the Resolution Life Group’s commitment to responsible investing. The Resolution Life Group has a Responsible Investment Policy which establishes the principles and minimum standards for responsible investment within the Resolution Life Group and the framework and controls for managing any associated risks. The Responsible Investment Policy lists modern slavery and human rights as a strategic priority when investing.
Employees are advised to report any suspected act of human trafficking or modern slavery, on a confidential basis, to Resolution Life Group’s Chief People, Partnerships and Legal Officer. A Whistleblowing Standard is in place which protects disclosures.
The Resolution Life Group also has a Global Outsourcing and Third-Party Policy, including a Third Party Risk Management (“TPRM”) process, which recognises the need to conduct third party management activity in an ethical and socially responsible fashion.
6. Due diligence processes in relation to slavery and human trafficking
Our TPRM process follows a defined due diligence process for any significant service providers. This process includes assessing the potential financial, legal and regulatory exposures of the business relationship. It also gives insight into the third party’s structure, operations, culture, human resources, supplier and customer relationships, competitive positioning and future outlook. Our processes are intended to:
identify and assess potential risk areas in our ‘critical’ or essential supply chains (those supply chains critical to our day-to-day operations);
mitigate the risk of slavery and human trafficking occurring in our supply chains;
monitor potential risk areas in our supply chains; and
protect whistle-blowers.
A governance framework is in place for the efficient management of our suppliers and is reviewed on an annual basis.
Our supply chain management process incorporates various departments within the Resolution Life Group including the Transformation/Operations team, the Legal and Compliance team, and Human Resources (“HR”).
7. Training
The Resolution Life Code of Conduct is based on practicing high ethical, legal and professional standards. These principles are reinforced annually through mandatory Code of Conduct training for all employees. As part of our Compliance training, we highlight our sustainability initiatives and direct employees to our Sustainability Policy, which outlines our commitment to mitigating risks related to modern slavery and human trafficking. In addition, we host an annual Global Ethics Awareness Week to further promote and embed a culture of integrity, encouraging employees to uphold high ethical standards in all aspects of their work.
8. Our effectiveness in combating slavery and human trafficking
On an annual basis, we review the effectiveness of our approach to track modern slavery by evaluating and updating the following:
Internal HR policies and processes;
Internal training and support materials (including our Code of Conduct); and
Procurement and governance processes that oversee our supply chain.
Following a review of the effectiveness of the steps we have taken this year to ensure that there is no slavery or human trafficking in our business and supply chains, we intend to continue to develop and improve our approach to respecting human rights and preventing modern slavery.
This Statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and has been approved by the relevant board(s) of Resolution Life on 23 May 2026.
Claire Singleton
Director
Resolution Life Group Services Ltd.
23 May 2026
Annexure A
This statement applies to the following Resolution Life entities:
Resolution Life Group Services Ltd.