MODERN SLAVERY ACT 2015 SECTION 54 STATEMENT

This statement sets out the steps Pacific Life Re has taken during the financial year ending 31 December 2018 to ensure that modern slavery, servitude, forced or compulsory labour and human trafficking ('modern slavery') is not taking place in its business or supply chain.

Overview of Pacific Life Re's business and supply chain

Pacific Life Re relies on professionally managed offices and related supplies and services, and professional and financial services such as those provided by insurance companies, banks, consultancies and IT providers. Our supply chains are relatively simple.

In this statement, Pacific Life Re refers to the businesses of Pacific Life Re Holdings Limited, Pacific Life Re Services Limited, and Pacific Life Re Limited. The business of Pacific Life Re is conducted on a global basis across the UK, Europe, Asia and North America.

Risk assessment

Due to the nature of our business, we consider that the risk of modern slavery in our business and supply chain is low.

The objectives of the Modern Slavery Act 2015 are aligned with our values. We periodically assess our business and supply chain in order to identify those areas in which we consider the risk of modern slavery to be highest. At present, we consider that the risk of modern slavery occurring is somewhat higher in the supply chain related to our office-related services and supplies as opposed to the professional and financial services used by Pacific Life Re. As a result, our anti-modern slavery policies and procedures are focused on this part of our supply chain.

Pacific Life Re policies in relation to modern slavery

Pacific Life Re does not tolerate or condone the practice of modern slavery in any form and is committed to ensuring that there is no modern slavery in its business or supply chain. We maintain policies and procedures, with which all Pacific Life Re employees must comply, in order to ensure that no such practices occur. Activities include the following measures:

• Due diligence relating to modern slavery carried out on suppliers identified as being at higher risk of involvement in modern slavery.
• A periodic risk assessment of Pacific Life Re's business and supply chain to identify suppliers where the risk of modern slavery is highest.
• A policy requiring employees who suspect, or become aware of, any instances of modern slavery in Pacific Life Re's business or supply chain, to report such incidents to management and/or make use of Pacific Life Re's anonymous whistle-blowing channels (as appropriate).
• Training on Pacific Life Re's policies and procedures in relation to modern slavery provided to all relevant Pacific Life Re staff.

The Board of Directors of Pacific Life Re Holdings Limited, Pacific Life Re Services Limited, and Pacific Life Re Limited approved this statement on 18 April 2019.

George Scott, Director, General Counsel & Chief Risk Officer 18 April 2019