This statement is made on behalf of White Bear Capital, including its subsidiaries Blenheim Underwriting Limited, Blenheim Partnerships Ltd, White Bear Corporate Services Ltd and White Bear Corporate Capital Limited, collectively referred to within this statement as “White Bear” pursuant to Section 54(1) of the Modern Slavery Act 2015 (the Act).
This statement sets out the steps we have taken to ensure that slavery and human trafficking is not occurring in any of our supply chains, or in any arears of our business for the year ending 31 December 2025. We have and will continue to have a zero tolerance approach to slavery and human trafficking.
Our group is an independent hub for underwriting expertise. The group holding company, White Bear Capital Limited, has four UK based subsidiaries: Blenheim Underwriting Limited (BUL), Blenheim Partnerships Limited (BPL), White Bear Corporate Services Ltd (WBCS) and White Bear Corporate Capital Limited (WBCC) collectively referred to as “White Bear” or “the group”.
Blenheim Underwriting Limited (BUL) is the Lloyd’s managing agent for Blenheim Syndicate 5886 and is authorised by the Prudential Regulation Authority (PRA) and regulated by the Financial Conduct Authority (FCA) and the PRA as well as Lloyd’s.
Blenheim Partnerships Limited (BPL) is a UK insurance intermediary, authorised and regulated by the FCA in the UK, and authorised by the Guernsey Financial Services Commission as an Insurance Manager in Guernsey. BPL acts as Managing General Agent (MGA) for several (re)insurance entities.
White Bear Corporate Capital Limited (WBCC) is a Lloyd’s Corporate Member which participates on Syndicate 5886.
White Bear Corporate Services Ltd (Services) is a UK limited company providing group services to all White Bear group companies and employs all group staff.
The group is a provider of (re)insurance services to its clients and does not produce, manufacture, or sell physical goods and has no supply chain in relation to such products. We provide (re)insurance services through various wholesale brokers, Lloyd’s brokers, insurance agents and intermediaries which present as low risk for modern slavery and human trafficking. We believe our supply chains are limited and comprise mainly of third-party suppliers for office management, IT infrastructure, professional advisory services, and recruitment. Our risk assessment remains unchanged for this year.
We work with reputable suppliers. In line with our Outsourcing Policy and supplier onboarding procedures, proportionate supplier due diligence is performed on all new and renewing contracts. As part of our initiative to identify and minimise the risk of slavery and human trafficking occurring within our business and supply chain, we:
Suppliers are expected to adhere to all local laws and regulations.
All workers are recruited directly or via approved and vetted agencies that have confirmed compliance with our anti-slavery code of conduct. Our pre-mployment checks include Right-to Work checks, and employment referencing prior to the commencement of work to prevent forced labour and human trafficking. If we employ from overseas, we will ensure that, where applicable, the correct visa is in place to ensure we comply with immigration laws.
There were no issues which related to modern slavery or human trafficking identified by the group or raised through the Speak up/Whistleblowing procedures in 2025.
Our companies operate in a highly regulated, financial services environment and we are fully committed to addressing the risks of modern slavery in our own operations and supply chain.
We expect all employees, officers and directors to comply with the group’s policies and procedures which set out a developed set of values and behaviours to mitigate the risk of modern slavery within our organisation and supply chain. All board level policies are subject to at least annual review and re-approval.
We are committed to the highest principles of personal and professional conduct, and our staff training is designed to ensure that these standards of behaviour are communicated to every individual who works for the group.
Our Anti Modern Slavery Policy was reviewed and re-approved in December 2025. A new Code of Conduct and Ethics Statement was published in May 2024, and all staff were assigned Ethics e-learning in May 2025.
All new employees receive awareness training on Modern Slavery and Human Trafficking as part of their new starter training e-learning package. This module was also issued to all staff in 2025 as part of their refresher training.
Furthermore, as part of the group’s performance management process, staff are assessed against meeting the group’s values and behaviours, which include treating people fairly and with respect and compliance with law and regulations.
Our Speak up policy is well publicised within the organisation, and all employees received e-learning on Speak up/ Whistleblowing in 2025. Anyone within the group who has concerns about modern slavery or human trafficking in or relating to the group or any of its suppliers is encouraged to report their concerns without fear of reprisals.
This Statement has been approved on behalf of the White Bear Group by the Board of White Bear Corporate Services Ltd on 22nd June 2026, and signed on its behalf by John Lynch, Director, White Bear Corporate Services Ltd.