Modern Slavery Statement 2024

Organizational Structure, Activities, and Supply Chains

Global Excel is one of the premier independent third-party administrators of travel, destination, and ex-patriot medical insurance in the world. Global Excel administrates policies of insurance for numerous insurance providers from all over the world, and controls subsidiaries throughout different regions the United States, Mexico, Europe, and Asia-Pacific.

Operating out of Sherbrooke, Quebec, as well as Windsor, Ontario (through its subsidiary Active Care Management (2018) Inc.), Global Excel employs over 1300 individuals in Canada.

All Global Excel subsidiaries and affiliates participate in and comply with our processes and strategies to prevent acts of modern slavery and human trafficking from taking place within their business and supply chains.

Global Excel’s spending on its supply chains primarily goes to suppliers of services and not goods. Where Global Excel procures goods, for its operations it does so from suppliers based either in Canada or the United States. Global Excel’s workforce is comprised overwhelmingly of office staff.

Modern Slavery Risks

Global Excel has assessed the potential for modern slavery and human trafficking in various sections of its supply chains. In terms of the procurement of goods this includes areas such as electronics, office furniture, and promotional materials. In terms of services this includes areas such as staffing agencies, offshoring services, and subcontractors.

Practices

Global Excel has implemented relevant policies and practices to help mitigate unlawful activities in its supply chains. As they relate to modern slavery, these apply not only to goods but also those parts of our supply chains that are related to services as well. As the fight against modern slavery is a continuing process, Global Excel reviews these policies and practices regularly to identify gaps and determine whether there are improvements to be made to ensure it is actively excluded from our supply chains.

In summary Global Excel’s policies to combat Modern Slavery include:
Educating relevant staff on existing policies and procedures and the importance of combating modern slavery in our supply chains;
Establishing procedures for vetting our supply chains;
Ensuring our partners and suppliers are aware of our stance on modern slavery and our expectation of adherence to said standards; and
Reviewing the policies of our partners and suppliers, where applicable.

Due Diligence and Internal Controls

More specifically Global Excel has in place the following policies to keep our supply chain free of modern slavery:

• Requiring all department heads involved in the procurement of goods and services to be aware of our statutory obligations to combat modern slavery and educated on our prevention policies and efforts;
• Assessing the origins of goods and services purchased from outside of Canada by Global Excel, where possible, to properly judge the risk of modern slavery or human trafficking being used in their creation;
• Taking various steps to vet suppliers of both goods and services for modern slavery and human trafficking issues/risks. These can include reputational searches against potential suppliers and/or requiring attestations on these (and other) issues from potential suppliers before they are approved;
• Ensuring that our Legal/Compliance team is aware and has ensure the appropriate vetting of all substantial suppliers;
• Ensuring all contracts with suppliers, where possible, contain sufficient language to ensure the absence of modern slavery, human trafficking, and other unlawful activities in our supply chains;
• Carrying out regular supplier checks on all key suppliers on an annual basis to reassure the integrity of our supply chains in this regard; and
• Maintaining a Whistleblower Policy to facilitate the ability of employees to raise concerns on these, and other, issues without fear of reprisal.

Continued Steps

Global Excel’s priority in the 2024-2025 fiscal year will be to ensure that all our referenced policies are being implemented properly and effectively. Internally these policies and procedures will be reviewed by our Governance, Risk, and Compliance Committee at their quarterly meetings. Relevant members of the committee (from our Legal/Compliance departments) are expected to provide the committee with updates on our efforts and identify challenges/gaps that have emerged in need of remediation.

Specific actions for the 2024-2025 year include:

• Implementation of specific training on our Modern Slavery practices for those employees directly involved in procurement and supplier relations.
• Ongoing review for our contractual relationships, in particular renewal of legacy contract to ensure the appropriate, up-to-date, wording has been included.
• Review of our internal policies to ensure they make specific reference to our modern slavery obligations where required.