Exhibit
      10.1

     

    EXECUTIVE
      EMPLOYMENT AGREEMENT

     

    EMPLOYMENT
      AGREEMENT (this “Agreement”), dated as of September 1st 2007 by
      and between
      Partner Reinsurance Company Ltd., a company incorporated under the laws of
      Bermuda (the "Company"), and Costas Miranthis (the "Executive").

     

    W
      I T N E S S E T H:

     

    WHEREAS,
      the Company desires to memorialize the terms of employment of the Executive
      as
      Deputy CEO PartnerRe Global; and

     

    WHEREAS,
      the Executive is willing to serve the Company on the terms and conditions herein
      provided.

     

    NOW,
      THEREFORE, in consideration of the foregoing and of the mutual promises and
      covenants herein contained, the receipt and sufficiency of which are hereby
      acknowledged, the parties hereto agree as follows:

     

     1.           EMPLOYMENT

     

    The
      Company agrees to employ the Executive and the Executive agrees to serve the
      Company on the terms and conditions set forth herein.

     

     2.           EFFECTIVE
      DATE

     

    This
      Agreement shall be effective, and the Executive's employment as contemplated
      hereunder shall commence (subject to any immigration considerations), as of
      September 1, 2007 (the “Effective Date”).

     

     3.           POSITION
      AND DUTIES

     

    
      	
               

            	
              (a)

            	
              The
                Executive shall serve as Deputy CEO of PartnerRe Global and shall
                report
                directly to the Chief Executive Officer of the PartnerRe Global (“CEO
                PartnerRe Global”).  The Executive shall perform such duties and
                exercise such supervision and powers over and with regard to the
                business
                of the Company as are consistent with such position, as well as such
                other
                reasonable duties and services consistent with such position with
                a
                multi-national reinsurance company as may be prescribed from time
                to time
                by the CEO PartnerRe Global of the Company.    The
                Executive’s performance of any duties and responsibilities shall be
                conducted in a manner consistent with all Company policies and any
                other
                reasonable guidelines provided to the Executive by the CEO PartnerRe
                Global.

            


    

     

    
      	
               

            	
              (b)

            	
              Except
                during customary vacation periods and periods of illness, the Executive
                shall, during his employment hereunder, devote substantially his
                full
                business time and attention to the performance of services for the
                Company.

            


    

     

     4.           PLACE
      OF PERFORMANCE

     

    
      
        
        

      

      
        
        

        
          

        

      

      
        
        

      

    

     

    In
      connection with the Executive's employment by the Company, the Executive shall
      generally perform his duties in Ireland except for reasonably necessary travel
      on the Company's business and in connection with the performance of his duties
      hereunder, or may perform his duties hereunder at such places as are mutually
      agreed upon with the CEO PartnerRe Global.

     

     5.           COMPENSATION
      AND RELATED MATTERS

     

    
      	
            	
              (a)

            	
              Base
                Salary. During
                the term of this Agreement, the Company shall pay to the Executive
                a base
                salary at an aggregate initial rate as further detailed in the attached
                Schedule, which shall be approved by the Compensation Committee of
                the
                Board (the "Compensation Committee") (which salary, as adjusted from
                time
                to time, is referred to herein as "Base Salary").  Base Salary
                shall be paid in equal installments in accordance with normal payroll
                practices of the Company but not less frequently than
                monthly.  Base Salary may be increased (but not decreased)
                annually at the discretion of the Compensation Committee.  Base
                Salary payments (including any increased Base Salary payments) hereunder
                shall not in any way limit or reduce any other obligation of the
                Company
                hereunder, and no other compensation, benefit or payment hereunder
                shall
                in any way limit or reduce the obligation of the Company to pay the
                Executive's Base Salary hereunder.

            


    

     

    
      	
               

            	
              (b)

            	
              Annual
                Incentive. During the term of the Executive’s employment hereunder,
                the Executive will be entitled to receive annual incentive compensation
                in
                an amount for the Company’s fiscal year determined in the sole discretion
                of the Compensation Committee in accordance with the Company’s Annual
                Incentive Guidelines.

            


    

     

    
      	
               

            	
              (c)

            	
              Equity.
                The Executive will be eligible to participate in the equity
                plans of
                the Company (the "Plans"). The Executive shall receive equity awards
                at
                the sole discretion of the Compensation Committee and in accordance
                with,
                and subject to, the terms of the Plans, and any agreement executed
                by the
                Executive in connection therewith.

            


    

     

    
      	
               

            	
              (d)

            	
              Expenses.  During
                the term of this Agreement, the Executive shall be entitled to receive
                prompt reimbursement from the Company of all reasonable expenses
                incurred
                by the Executive in promoting the business of the Company and in
                performing services hereunder, including all expenses of travel and
                entertainment and living expenses while away from home on business
                or at
                the request of, or in the service of, the Company, provided that
                such
                expenses are incurred and accounted for in accordance with the policies
                and procedures established by the Company from time to
                time.

            


    

     

     6.           TERMINATION

     

    The
      Executive's employment hereunder may be terminated under the following
      circumstances, subject to the effective "Date of Termination" described in
      Section 6(e) hereof:

     

    
      
        
        

      

      
        2

        
          

        

      

      
        
        

      

    

     

    (a)           Death,
      Disability or Retirement.

     

    
      	
               

            	
              (i)

            	
              The
                Executive's employment hereunder shall terminate upon his
                death.

            


    

     

    
      	
               

            	
              (ii)

            	
              If
                the Executive shall have qualified for long-term disability benefits
                under
                any long-term disability insurance arrangement in which he is
                participating and the Executive qualifies for the Company’s long-term
                disability benefit, then the Company may at any time after the date
                of
                such qualification, give to the Executive a Notice of Termination
                (as
                defined in Section 6(d) hereof) of the Executive's employment hereunder
                and the Executive's employment hereunder shall terminate on the date
                provided in Section 6(e) hereof.

            


    

     

    
      	
               

            	
              (iii)

            	
              The
                Executive's employment hereunder shall terminate upon his retirement.
                Retirement shall be defined by the policy in place in the Executive’s
                country of employment.

            


    

    


    
      	
               

            	
              (b)

            	
              Termination
                by the Company. The Company may terminate the Executive's
                employment hereunder i) with Cause at any time or ii) without cause
                by
                providing six  months written notice to the
                Executive.  For purposes of this Agreement, the Company shall
                have "Cause" to terminate the Executive's employment hereunder upon
                (A)
                the engaging by the Executive in serious negligence or willful misconduct
                which is demonstrably injurious to the Company and its subsidiaries
                on a
                consolidated basis, or (B) the conviction of the Executive of a serious
                criminal act. For purposes of this paragraph, no act, or failure
                to act,
                on the Executive's part shall be considered "willful" unless done,
                or
                omitted to be done, by him not in good faith and without reasonable
                belief
                that his action or omission was in the best interest of the
                Company.

            


    

     

    
      	
               

            	
              (c)

            	
              Termination
                by the Executive.  The Executive may terminate his
                employment hereunder i) with Good Reason at any time or ii) without
                Good
                Reason by providing six months written notice to the Company. Non-renewal
                of this contract by the Executive shall be considered to be termination
                without Good Reason except where the Executive becomes eligible for
                retirement as defined in Section 6(a)(ii) during the Extension Period.
                For
                purposes of this Agreement, "Good Reason" shall mean (A) a failure
                by the
                Company to comply with any material provision of this Agreement (B)
                the
                assignment to the Executive by the Company of duties inconsistent
                with the
                Executive's position, authority, duties, responsibilities or status
                with
                the Company as in effect immediately after the date of execution
                of this
                Agreement including, but not limited to, any reduction whatsoever
                in such
                position, authority, duties, responsibilities or status, or a change
                in
                the Executive's titles as then in effect, except in connection with
                the
                termination of his employment on account of his death, disability,
                or for
                Cause, (C) any reduction in Base Salary or benefits without the
                Executive's prior written consent, (D) any other material change
                in the
                conditions of employment or (E) 

            


    

     

    
      
        
        

      

      
        3

        
          

        

      

      
        
        

      

    

    
       

      
        	
                 

              	
                 

              	
                any
                  purported termination of the Executive's employment which is not
                  effected
                  pursuant to a Notice of Termination satisfying the requirements
                  of
                  subsection 6(d) hereof

              


      

    

     

    
      	
               

            	
              (d)

            	
              Notice
                of Termination.   Any termination of the Executive's
                employment by the Company or by the Executive shall be communicated
                by
                written Notice of Termination to the other party hereto. For purposes
                of
                this Agreement, a "Notice of Termination" shall mean a notice which
                shall
                indicate the specific termination provision in this Agreement relied
                upon
                and the Date of Termination and shall set forth in reasonable detail
                the
                facts and circumstances, if any, claimed to provide a basis for
                termination of the Executive's employment under the provision so
                indicated.

            


    

     

    
      	
               

            	
              (e)

            	
              Date
                of Termination.  "Date of Termination" shall mean (i) if
                the Executive's employment is terminated by his death, the date of
                his
                death, (ii) if the Executive's employment is terminated by disability
                pursuant to Section 6(a) (ii) hereof, the date specified in the Notice
                of
                Termination, (iii) if the Executive's employment is terminated by
                the
                Company without Cause or by the Executive without Good Reason, the
                date
                specified in the Notice of Termination which shall be not less than
                six
                months after such Notice is delivered, (iv) if the Executive’s employment
                is terminated by the Company for Cause or if the Executive voluntarily
                terminates his employment with Good Reason, the date specified in
                the
                Notice of Termination which can be
                immediate.

            


    

     

    
      	
            	
              (f)

            	
              Payment
                in lieu of
                notice.
                In
                lieu of providing notice of
                termination of employment in accordance with section 6d and 6e of
                this
                Agreement, the Company may, at its discretion pay the Executive a
                sum
                equal to the wages and remuneration and confer on him all other benefits
                that would have been due up to the expiry of the Date of
                Termination.

            


    

    


     

     7.           COMPENSATION
      UPON TERMINATION

     

    In
      the
      event that the Executive’s employment is terminated, the provisions of this
      Section 7 shall determine the Executive’s entitlement to compensation and
      benefits in connection with and subsequent to such termination.

     

    
      	
            	
              (a)

            	
              Upon
                retirement the Company shall pay the Executive (i) all accrued salary
                and
                benefits through the Date of Termination (ii) a pro rata annual incentive
                for the fiscal year in which the Date of Termination occurs, based
                on the
                average annual incentive  received by the Executive for the
                three calendar years prior to the Date of Termination under Section
                5(b),
                and the number of days elapsed in the current fiscal year as of the
                Date
                of Termination and (iii) any other benefits that may be approved
                by the
                Board. All equity awards will be treated in accordance with the terms
                laid
                down in the Equity Award
                Agreements.

            


    

     

     

    
      
        
        

      

      
        4

        
          

        

      

      
        
        

      

    

     

    
      	
               

            	
              (b)

            	
              If
                (i) the Company terminates the employment of the Executive under
                Section 6
                (b) for Cause, or (ii) the Executive terminates employment without
                Good
                Reason, the Executive shall be paid all accrued salary and benefits
                through the Date of Termination and the Company shall have no further
                obligations to the Executive after the Date of
                Termination.

            


    

     

    
      	
               

            	
              (c)

            	
              If
                the Executive’s employment terminates for any reason other than those
                reasons described in subsection (a) or (b) of this Section
                7:  (i) the Executive shall continue to receive his Base
                Salary from the Company at the rate in effect hereunder on the Date
                of
                Termination periodically, in accordance with the Company's prevailing
                payroll practices, for 6 months (the “Severance Period”) (ii) 1/12th
                of the average annual incentive  received by the Executive for
                the three calendar years prior to the Date of Termination under Section
                5(b) or such lesser number of years immediately preceding the Date
                of
                Termination for which the Executive shall have received an annual
                incentive  from the Company, or if there are no such years, the
                annualized target incentive  of the year in which the Date of
                Termination occurs shall be paid to the Executive by the Company
                for each
                full calendar month for the duration of the Severance Period (iii)
                all
                vested options granted to the Executive under the Plans will remain
                exercisable for the duration of the Severance Period or until expiration
                whichever is sooner (iv) all deliver restrictions on vested equity
                awards
                granted to the Executive under the Plans will be lifted (v) and any
                portion of an equity award  granted to the Executive that would
                either vest or become exercisable in accordance with its terms during
                the
                Severance Period shall so vest or become so exercisable and
                notwithstanding any provisions of the Plans or the Equity Award Agreement
                to the contrary shall remain exercisable for the duration of the
                Severance
                Period or until expiration whichever is sooner  (vi) the Housing
                Allowance shall be paid to the Executive for the period ending on
                the
                earlier of the date the Executive leaves Zurich or 3 months after the
                date of Termination and (vii) the Executive and his beneficiaries,
                as
                applicable, shall continue to be eligible to participate in the Company’s
                health and welfare plans on the same basis as an active employee
                of the
                Company for the duration of the Severance Period or, if shorter,
                until the
                Executive becomes entitled to participate in or receive coverage
                under
                health and welfare plans of a subsequent employer.  In addition,
                the Executive shall be paid (i) all accrued salary and benefits through
                the Date of Termination and (ii) a pro rata annual incentive for
                the
                fiscal year in which the Date of Termination occurs, based on the
                average
                annual incentive received by  the Executive for the three
                calendar years prior to the Date of Termination under Section 5(b)
                or such
                lesser number of years immediately preceding the Date of Termination
                for
                which the Executive shall have received an annual incentive from
                the
                Company, or if there are no such years, the annualized target incentive
                of
                the year in which the Date of Termination occurs, and the number
                of days
                elapsed in the current fiscal year as of the Date of
                Termination.  Except as provided in this Section 7(c) and in
                Sections 7 (d) and (e) hereof, the Company shall have no further
                obligations to the Executive after the Date of
                Termination.

            


    

     

    
      
        
        

      

      
        5

        
          

        

      

      
        
        

      

    

     

    
      	
               

            	
              (d)

            	
              Notwithstanding
                the foregoing, if the Executive’s employment terminates for any reason
                other than those reasons described in sub section (a) or (b), of
                this
                Section 7 in connection with a Change of Control as defined in Section
                20,
                the provisions of Section 20 shall
                govern.

            


    

     

    
      	
               

            	
              (e)

            	
              Upon
                any termination of the Executive's employment hereunder, the Company
                will
                allow the Executive to receive all accrued benefits to which the
                Executive
                was entitled under the provisions of the Benefit Plans, and the Company
                shall have no further obligations to the Executive, except as may
                be
                provided under the express terms of this Agreement or of any such
                Benefit
                Plans or under the express terms of any option agreements entered
                into
                during the term of this Agreement, or in accordance with the survivorship
                provisions of Section 14 of this
                Agreement.

            


    

    


    


     8.           INDEMNIFICATION

     

    The
      Company shall indemnify the Executive (and his legal representatives or other
      successors and heirs) to the fullest extent permitted (including payment of
      expenses in advance of final disposition of the proceeding) by the laws of
      Bermuda, as in effect at the time of the subject act or omission; and the
      Executive shall be entitled to the protection of any insurance policies the
      Company may elect to maintain generally for the benefit of its directors and
      officers, against all costs, charges and expenses whatsoever incurred or
      sustained by him or his legal representatives in connection with any action,
      suit or proceeding to which he (or his legal representatives or other successors
      and heirs) may be made a party by reason of his being or having been a director,
      officer or Executive of the Company or any of its subsidiaries.  If
      any action, suit or proceeding is brought or threatened against the Executive
      in
      respect of which indemnity may be sought against the Company pursuant to the
      foregoing, the Executive shall notify the Company promptly in writing of the
      institution of such action, suit or proceeding and the Company shall assume
      the
      defense thereof and the employment of counsel and payment of all fees and
      expenses, provided however, that if a conflict of interest exists between the
      Company and the Executive such that it is not legally practicable for the
      Company to assume the Executive’s defense, the Executive shall be entitled to
      retain separate counsel reasonably acceptable to the Company at the Company’s
      expense.

     

     9.           TAXES

     

    The
      Company shall deduct all taxes required by law in the place of employment from
      all amounts payable under this Agreement.

     

    10.           CONFIDENTIALITY

     

    Unless
      otherwise required by law or judicial process, the Executive shall retain in
      confidence after termination of the Executive's employment with the Company
      pursuant to this Agreement all confidential information known to the Executive
      concerning the 

     

     

    
      
        
        

      

      
        6

        
          

        

      

      
        
        

      

    

     

    Company
      and its business for the shorter of (i) one year following such termination
      or
      (ii) until such information is publicly disclosed by the Company or otherwise
      becomes publicly disclosed other than through the Executive's actions. Violation
      by the Executive of this clause will give the Company the right to immediately
      terminate all future severance payments including any post termination exercise
      periods.

     

    11.          COVENANTS
      NOT TO COMPETE OR INTERFERE

     

    In
      consideration of the benefits and entitlements provided by this Agreement the
      Executive agrees that, during his employment hereunder and for the duration
      of
      the Severance Period he will not, other than on behalf of the Company, directly
      or indirectly, as a sole proprietor, agent, broker or intermediary, member
      of a
      partnership, or stockholder, investor, officer or director of a corporation,
      or
      as an employee, agent, associate or consultant of any person, firm or
      corporation:

     

    
      	
               

            	
              (a)

            	
              Solicit
                or accept business (i) from any clients of the Company or its affiliates,
                (ii) from any prospective clients whose business the Company or any
                of its
                affiliates is in the process of soliciting at the time of the Executive's
                termination, or (iii) from any former clients which had been doing
                business with the Company within one year prior to the Executive's
                termination;

            


    

     

    
      	
               

            	
              (b)

            	
              Solicit
                any employee of the Company or its affiliates to terminate such employee's
                employment with the Company; or

            


    

     

    
      	
               

            	
              (c)

            	
              Nothing
                contained in this Section shall prohibit the Executive from making
                investments in or from serving as an officer or employee of a firm
                or
                corporation which is not directly or indirectly engaged in the same
                type
                of business as the Company.

            


    

     

    It
      is the
      desire and intent of the parties that the provisions of this Section 11 shall
      be
      enforced to the fullest extent permissible under the laws and public policies
      applied in each jurisdiction in which enforcement is
      sought.  Accordingly, if any particular portion of this Section 11
      shall be adjudicated to be invalid or unenforceable, this Section 11 shall
      be
      deemed amended to delete therefrom the portion thus adjudicated to be invalid
      or
      unenforceable, such deletion to apply only with respect to the operation of
      this
      Section 11 in the particular jurisdiction in which such adjudication is
      made.  The Executive acknowledges that he has received good and
      valuable consideration for the non-competition obligation contained in this
      Section 11. Violation by the Executive of any of the Covenants will give the
      Company the right to immediately terminate all future severance payments
      including any post termination exercise periods.

     

    12.           SUCCESSORS;
      BINDING AGREEMENT

     

    
      	
               

            	
              (a)

            	
              This
                Agreement is personal to the Executive and without the prior written
                consent of the Company shall not be assignable by the Executive otherwise
                than by will or the laws of descent and distribution.  This
                Agreement shall inure to the benefit of and be enforceable by the
                Executive's legal representatives or
                heirs.

            


    

     

    
      
        
        

      

      
        7

        
          

        

      

      
        
        

      

    

     

    
      	
               

            	
              (b)

            	
              This
                Agreement shall inure to the benefit of and be binding upon the Company
                and its successors and assigns.

            


    

     

    
      	
               

            	
              (c)

            	
              The
                Company will require any successor (whether direct or indirect, by
                purchase, merger, consolidation or otherwise) to all or substantially
                all
                of the business and/or assets of the Company (a "Successor Company")
                to
                assume expressly and agree to perform this Agreement in the same
                manner
                and to the same extent that the Company would be required to perform
                if no
                such succession had taken place; provided, however, that no such
                succession shall relieve the Company of its obligations hereunder
                unless
                the assumption of this Agreement by a Successor Company is approved
                in
                writing by the Executive.

            


    

     

     13.         NOTICE

     

    For
      the
      purposes of this Agreement, notices, demands and all other communications
      provided for in the Agreement shall be in writing and shall be deemed to have
      been duly given when hand delivered or (unless otherwise specified) when mailed
      by registered mail, return receipt requested, postage prepaid, addressed as
      follows:

     

               If
      to the Executive:

    At
      the
      address maintained in the Company’s employment records.

    


     

    If
      to the Company:

    Partner
      Reinsurance Company Ltd.

    Attn:  Chief
      Executive Officer

    Wellesley
      House

    90
      Pitts
      Bay Road

    Pembroke  HM
      08

    Bermuda

     

    or
      to such
      other address as any party may have furnished to the other in writing in
      accordance herewith, except that notices of change of address shall be effective
      only upon receipt.

     

    14.           GOVERNING
      LAW AND JURISDICTION

     

    This
      Agreement shall be governed by and construed and enforced in accordance with
      the
      laws of Bermuda, without regard to the principles of conflict of
      laws.  The Executive submits to the non-exclusive jurisdiction of
      Bermuda in respect of matters arising hereunder.


    


    15.           SURVIVORSHIP

     

    The
      respective rights and obligations of the parties hereunder, including, without
      limitation, the rights and obligations set forth in Sections 5 through 8 and
      10
      through 12 

     

    
      
        
        

      

      
        8

        
          

        

      

      
        
        

      

    

     

    of
      this
      Agreement, shall survive any termination of this Agreement to the extent
      necessary to the intended preservation of such rights and
      obligations.

     

    16.           ARBITRATION

     

    Should
      any
      dispute arise in connection with this agreement the aggrieved party may submit
      a
      notice of arbitration to the other party in accordance with the Bermuda
      Conciliation and Arbitration Act 1993. Procedures shall be governed by the
      UNCITRAL arbitration rules. The number of arbitrators shall be
      one.  If the parties cannot agree on the identity of the sole
      arbitrator within 7 days of the delivery of the notice of arbitration then
      the
      appointing authority shall be the nominating committee of the Chartered
      Institute of Arbitrators, Bermuda Branch. The place of arbitration shall be
      Bermuda and the language of the arbitration shall be English. Judgment on the
      award rendered by the arbitrator may be entered in any court having jurisdiction
      thereof.  The costs of the arbitrator shall be borne by the Company
      and each party shall bear its own legal fees and expenses.  The
      arbitral award shall be in writing, shall state reasons for the award, and
      shall
      be final and binding on the parties.  The arbitrator shall have the
      authority to award any remedy or relief that a court of competent jurisdiction
      could order or grant, including, without limitation the issuance of an
      injunction.  However, either party may, without inconsistency with the
      arbitration provision, apply to any court having jurisdiction over such dispute
      or controversy and seek interim provisional, injunctive or other equitable
      relief until the arbitration award is rendered or the controversy is otherwise
      resolved.  Except as necessary in court proceedings to enforce this
      arbitration provision or an award rendered hereunder, or to obtain interim
      relief, neither a party nor an arbitrator may disclose the existence, content
      or
      results of any arbitration hereunder without the prior written consent of the
      Company and the Executive.

     

    17.           MISCELLANEOUS

     

    The
      parties hereto agree that this Agreement contains the entire understanding
      and
      agreement between them, and supersedes all prior understandings and agreements
      between the parties respecting the employment by the Company of the Executive
      or
      respecting the employment by the Company of the Executive other than the
      provisions of any Plan or Benefit Plan or award or other instrument entered
      into
      thereunder.  The parties further agree that the provisions of this
      Agreement may not be modified, waived or discharged unless such waiver,
      modification or discharge is agreed to in writing signed by the parties
      hereto.  No waiver by either party hereto at any time of any breach by
      the other party hereto of, or compliance with, any condition or provision of
      this Agreement to be performed by such other party shall be deemed a waiver
      of
      similar or dissimilar provisions or conditions at the same or at any prior
      or
      subsequent time.  The form and timing of all payments under this
      Agreement shall be made in a manner which complies with all applicable laws,
      rules and regulations. Except as set forth in the Plans, Equity Award Agreements
      or Benefit Plans, no agreements or representations, oral or otherwise, express
      or implied, with respect to the subject matter hereof have been made by either
      party which are not set forth expressly in this Agreement.  The
      validity, interpretation, 

     

    
      
        
        

      

      
        9

        
          

        

      

      
        
        

      

    

     

    construction
      and performance of this Agreement shall be governed by the laws of Bermuda
      without giving effect to the conflict of laws principles thereof.

     

    18.           VALIDITY

     

    The
      invalidity or unenforceability of any provision or provisions of this Agreement
      shall not affect the validity or enforceability of any other provision or
      provisions of this Agreement, which shall remain in full force and
      effect.

     

    19.           COUNTERPARTS

     

    This
      Agreement may be executed in one or more counterparts, each of which shall
      be
      deemed to be an original but all of which together will constitute one and
      the
      same instrument.

     

    20.           CHANGE
      OF CONTROL

     

    The
      terms
      of the Change in Control Policy (the “CIC Policy”) as approved by the
      Compensation Committee in November 2004, or such amendment thereto, shall apply
      to the Executive.  The CIC Policy shall be incorporated in this
      contract and shall be binding on the Executive as if such CIC Policy were
      contained herein verbatim.

    
 

    IN
      WITNESS
      WHEREOF, the Company has caused its name to be ascribed to this Agreement by
      its
      duly authorized representative and the Executive has executed this Agreement
      effective as of the date set forth in Section 2 hereof.

     

    PARTNER
      REINSURANCE COMPANY LTD.

     

    


    
      	 	Date: 
              September
              26, 2007	 	 	 
	 	 	 	 	 
	 	
              Name:
                Costas Miranthis

            	
              Signature:
                

            	/s/
              Costas Miranthis	 
	 	
              Title:   Deputy
                CEO, Global

            	 	 	 


    

    
 

    
      	 	Date: 
              September
              26, 2007	 	 	 
	 	 	 	 	 
	 	
              Name:
                Patrick Thiele

            	
              Signature:
                

            	/s/
              Patrick Thiele	 
	 	
              Title:  President
                and CEO

            	 	 	 


    

    
 

    
      
        
        

      

      
        10

        
          

        

      

      
        
        

      

    

     

    Schedule

    


    Costas
      Miranthis

    Deputy
      CEO, Global

    


    
      	
              Annual
                Salary:

            	
              US$515,000,
                delivered in Swiss Francs at the agreed exchange rate.

            
	
              Annual
                Incentive:

            	
              Target
                100%.

            
	
              School
                Fees:

            	
              100%
                of actual school fees incurred in Switzerland for first 3 academic
                years

            
	
              Housing
                Allowance:

            	
              Swiss
                Franc equivalent of US$140,000  per year for 3 years commencing
                on 1 July 2007. Executive retains any underspend if actual housing
                costs
                fall below US$140,000.

            
	
              Relocation
                allowance:

            	
              US$20,000,
                net of applicable taxes

            
	
              Annual
                tax filing assistance:

            	
              Actual
                costs incurred in filing tax returns in Switzerland and
                Ireland

            
	
              Tax
                planning advice:

            	
              Actual
                one off costs incurred for personal financial planning capped at
                US$6,000.

            
	
              Contribution
                to Retirement Plan:

            	
              Employer
                contribution equal to 15% of annual salary, inclusive of contributions
                into the Swiss Pension Plan.  The excess contribution over and
                above the Swiss Pension Plan contributions’ will be paid into the Bermuda
                Pension Plan.

            
	
              Tax:

            	
              Company
                pays all Irish income tax, Irish social security and Swiss Social
                Security
                contributions payable as a consequence of employment in
                Ireland

            
	 	 
	
              Life
                insurance:

            	
              3
                times annual salary.

            
	 	 
	
              Health
                Care Benefits

            	
              Executive
                and Family Members

            


    

     

    
 

    11