ModernSlavery
Statement
2023
Reinsurance Group of America,Incorporated

Page 0 of 7Introduction
At Reinsurance Group of America, Incorporated (“RGA”), we pride ourselves on ourcontinuing dedication to conducting our global business fairly and ethically. We follow astrict equality and fairness ethos and do not tolerate acts of modern slavery and human
trafﬁcking.
We are committed to the identiﬁcation, assessment and elimination of modern slavery risks
in the management of our business operations and our supply chains. We are similarlycommitted to working with and encouraging our suppliers, customers and other business
relationships to address the risks of modern slavery and human trafﬁcking in their supply
chains.
This Modern Slavery Statement covers the calendar year from January 1, 2023 to December
31, 2023.

Our Structure and Operations
RGA, a Fortune 500 company, is a leading global provider of life reinsurance and ﬁnancialsolutions. Founded in 1973, RGA is recognized for its deep technical expertise in risk andcapital management, innovative solutions, and commitment to serving its clients.
With headquarters in St. Louis, Missouri, RGA serves clients from operations in 26 markets
around the world, delivering expert solutions in individual life insurance, individual living
beneﬁts reinsurance, group reinsurance, ﬁnancial solutions, facultative underwriting andproduct development.
As of December 31, 2023, RGA had approximately $3.7 trillion of life reinsurance in force andassets of $97.6 billion.
This Statement is made pursuant to Section 54(1) of the United Kingdom Modern Slavery
Act 2015 and is provided on behalf of RGA and its global subsidiaries, speciﬁcally RGA
International Reinsurance Company dac, RGA UK Services Limited and Omnilife Insurance
Company Limited (together “RGA UK”). This Statement has been prepared in consultation
with representatives of RGA UK (further details below under Consultation and Approvals).

Our Supply Chains
RGA procures goods and services to enable our delivery of life reinsurance and ﬁnancial
solutions services to our clients.

1During 2023, RGA engaged a number of suppliers including professional associations,consulting services and investment management services, as well as suppliers of buildings
and maintenance, professional education, desktop tools (phones, computers, printers,
software and other supplies), information technology, record and data storage, travel, andmiscellaneous freight, mail and postage.

We have identified the following key supply chain
categories:•

Professional services•

Premises and facilities•

Banking•

Travel and accommodation•

Information technology (software and hardware)•

Human resources and stafﬁng services•

Print and mail management•

Investment management•

Claims administration (only applicable to Omnilife Insurance Company Limited)

Modern Slavery Risks in our Supply Chains
Due to the nature of RGA’s business, we are not exposed to high-risk supply chains and therisk of slavery occurring in these supply chains is low.
However, as with all supply chains, our supply chains are multi-layered and we
acknowledge that there are certain sectors, geographic locations, services and products
which carry a higher risk of modern slavery or human trafﬁcking than others. We havesought to address these risks through the actions articulated below and are committed tomaintaining and improving our rigorous procurement standards.
Should RGA become aware that business relationships do not adequately manage their
human rights impacts, we will reconsider our supply arrangement and implement
remedies available to us. RGA will consider on an individual basis what steps should betaken in relation to our suppliers, and ensure our workforce members are aware of the risks
and the mitigating factors put in place.

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Actions Taken to Assess and Address Modern
Slavery Risks
RGA has implemented a governance framework that is reviewed and approved by the
Executive Committee, updated regularly and applied consistently across all global
subsidiaries.

Code of Conduct
The principles and rules contained within our Code of Conduct have been developed as aset of practical rules and standards to serve as a guide for conducting business on RGA’sbehalf. The Code of Conduct applies globally to all workforce members throughout RGA,
and all of its subsidiaries and afﬁliates.
A core value required of our Code of Conduct is integrity, which requires honesty, fairness,trustworthiness, obeying laws and regulations and reporting concerns about compliance.
Instilling such values in our workforce members assists RGA to address and eliminate therisks of modern slavery in our business operations.
Our workforce members are required to complete the online Code of Conduct training oncommencement with RGA, and annually thereafter. This training includes an individual
attestation by each workforce member that he or she understands the responsibility tocomply with the rules and principles (including issues relating to human rights) listed in theCode of Conduct. Failure of any workforce member to comply with the Code of Conduct
may result in disciplinary measures up to and including termination.
To ensure that it is up to date with emerging issues, including modern slavery, RGA’s Codeof Conduct is reviewed at minimum every two years (with the next review due to take placein 2024) and was last updated in March 2023.

Speak-Up Policy
Our Speak-Up Policy ensures RGA adheres to the highest ethical standards in all its businessdealings by encouraging our workforce members to report any violation of law, rule,regulation, RGA policy or RGA’s Code of Conduct either online, by phone or by email.
The Speak-Up Policy aims to encourage all workforce members to challenge all improper,
unethical, or inappropriate behaviour identiﬁed at RGA or within our supply chains throughthe availability of anonymous reporting. The objective of this policy is to provide a
consistent mechanism for reporting and investigating any suspected breaches, which
would include those relating to modern slavery or human trafﬁcking.

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If a RGA workforce member witnesses or suspects illegal or unethical behaviour involving
RGA activities, or needs help making an ethical decision, workforce members can make a
conﬁdential report to the Speak-Up Hotline, which is managed by a third party andoverseen by RGA.
RGA values and relies on workforce members identifying potential issues and concernsthat may need to be addressed and will make every reasonable effort to maintainconfidentiality. Accordingly, RGA does not tolerate any retaliation in any form, at any levelof the organisation.
RGA’s Speak-Up Policy is reviewed at minimum every two years (with the next review due
to take place in 2024) and was last updated in May 2022.

Human Rights Policy
RGA recognises the importance of maintaining and promoting fundamental human rights
everywhere we operate and do business. Our Human Rights Policy details our expectations
for our actions and behaviour concerning human rights, including modern slavery andhuman trafﬁcking, in accordance with applicable laws and regulations, our Code ofConduct and RGA policies.
RGA provides training for workforce members about the standards and principles in our
Human Rights Policy. Following our mandatory training escalation process, these training
modules are administered during initial training sessions for new workforce members andon an annual basis thereafter.
RGA’s Human Rights Policy is reviewed at minimum every two years (with the next review
due to take place in 2024) and was last updated in September 2022.

Vendor Risk Management Policy
RGA retains accountability for all business risks inherent in the business processes that ourvendors and suppliers support. Our Vendor Risk Management Policy provides
accountability within RGA and a formal process for carrying out vendor due diligence andescalating high-risk ﬁndings.
RGA expects its vendors to follow RGA’s high standards and conduct their business in an
ethical manner (further details below under Vendor Code of Conduct).
RGA’s Vendor Risk Management Policy is reviewed at minimum every two years (with thenext review due to take place in 2024) and was last updated in January 2023.

4Vendor Code of Conduct
RGA ﬁnalised its Vendor Code of Conduct in 2023. We expect all new and existing vendors
to meet the expectations set forth in the Vendor Code of Conduct, aspire to continuously
improve upon existing processes, and innovate new processes. Vendors may be asked toprovide written attestation that they have reviewed and agreed to abide by the Vendor
Code of Conduct.
The Vendor Code of Conduct requires our vendors to protect all human rights and to fullycomply with all applicable slavery, forced labor and human trafﬁcking laws; to adopt anapproach to human rights consistent with the United Nations Universal Declaration of
Human Rights, the United Kingdom Modern Slavery Act 2015 and the Australian ModernSlavery Act 2018; and to comply with applicable laws regulating the minimum legal age towork. The Vendor Code of Conduct also requires that all business dealings of our vendors
be performed in accordance with applicable laws and regulations, including anticorruption laws.
RGA’s Vendor Code of Conduct is reviewed at minimum every two years (with the next
review due to take place in late 2025) and was ﬁrst published in October 2023.

Anti-Money Laundering Policy
Although RGA is generally exempt from anti-money laundering (AML) requirements due tothe nature of its business as a reinsurer, RGA implements an Anti-Money Laundering Policy
to assist in the prevention of activity that may facilitate money laundering, proliferation
ﬁnancing or the funding of terrorist or criminal activity, including modern slavery andhuman trafﬁcking.
RGA’s workforce members are required to undertake AML training, which is administeredduring the initial training for new workforce members, and annually thereafter.
RGA’s Anti-Money Laundering Policy is reviewed at minimum every two years (with the next
review due to take place in 2024) and was last updated in May 2022.

RGA UK Additional Measures
While we can perform due diligence in relation to our immediate suppliers, we have lessvisibility and control over the business operations of the suppliers of our suppliers. In aneffort to address this, RGA UK request the insertion of a clause into all new supplier contracts
requiring suppliers to agree to take reasonable measures to ensure that modern slavery
and human trafﬁcking practices do not occur in their supply chains.

5Assessing the Effectiveness of Our Actions
RGA acknowledges that the assessment of the effectiveness of our actions is an ongoingand evolving process.
We continue to monitor the effectiveness of the policies and procedures we have
implemented in order to address the risk of modern slavery and we review these policies
and processes on a regular basis.
In assessing the effectiveness of the actions taken by RGA and its subsidiaries to assess
and address the risks of modern slavery, RGA has relied on the fact that no material modernslavery incidents or increased risks were identiﬁed within our immediate supply chains
during the reporting period. We will continue to work collaboratively with suppliers and otherexternal partners to identify and address the risk of modern slavery within our supply chains.

Looking Ahead
As part of RGA’s ongoing commitment to addressing the risk of modern slavery in ouroperations and supply chains, we intend to:•continue to develop our supplier due diligence framework, including through theimplementation of a new third party risk management application that facilitates
the existing risk assessments conducted when RGA enters into vendor
engagements. This application forms part of a multi-year, multi-phase program
intended to strengthen the management of our vendors and our procurement
practices; and commit to continually improving the identiﬁcation and managementof modern slavery risk across our business operations and raising awareness of themodern slavery and human rights measures in our governance framework.

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