LIO PROCEDURES MANUAL July 2010. 2 Premise Job Descriptions Procedures.

LIO PROCEDURES MANUAL July 2010

2 Premise Job Descriptions Procedures

 Procedures  Premise  Job Descriptions 4 The aim of the Lloyd’s Italian Office (hereafter LIO) Procedures Manual is collecting:  Job Descriptions and  Procedures related to the main Office Divisions identifying:  competent Managers’ key responsibilities and  core processes’ operative and control activities. Job Descriptions are to be considered as the top level of the organisational model detailed into Procedures describing the Office processes.

 Procedures  Premise  Job Descriptions 6 Office Manager & Events General Manager Regulatory & Compliance Operations Support Market Support Financial Control

 Procedures  Premise  Job Descriptions 7 General Representative Enrico Bertagna Office Manager & Events Carola Pisani Regulatory & Compliance Nicoletta Andreotti Executive Sabrina Colzani Financial Control Galliano Gioacchini General Manager Filippo Dubini Operations Support Giovanni Toniutti Executive Francesca Pomati Executive Silvia Ussi Executive Ilaria Ferretti Market Support Antonio Tomasone Executive Mauro Carini Executive Cristina Panigada Executive Riccardo Tronnolone Executive Francesca Zuliani PA to Enrico Bertagna Barbara den Dubbelden

 Procedures  Premise  Job Descriptions 8 General Representative Enrico Bertagna Office Manager & Events Carola Pisani Market Development: Events, Communication & Media, EU projects Office Management: Health & Safety Law, Privacy Law, Law 231, risk Management Regulatory & Compliance Nicoletta Andreotti General Counsel: Compliance, Regulatory Affairs, Legal, Litigations, Complaints CH and OMC: training, approval, data management Financial Control Galliano Gioacchini General Manager Filippo Dubini Relationships Management Associations Business Planning Operations Support Giovanni Toniutti HR: Payroll, Benefits, Training, Insurances Financial: Budget, general accounting, suppliers Flows: Premiums taxes reporting and payment and coinsurance claims handling Market Support Antonio Tomasone IT projects: development, maintenance and assistance for Mocha and other electronic certificates/contracts issuing systems Information management: data flows, reporting, analysis, database management and anagrafe tributaria Market services: public tenders, policy checking and signing, assistance and advising Market intelligence: Regional Watch, Market Presentation, Focus, Crystal PA to Enrico Bertagna Barbara den Dubbelden

 Number of EE Supervised  Organizational Chart  Responsibilities 10  Relations General Representative Office Manager & Events Regulatory & Compliance Financial Control General Manager Operations Support Market Support PA to General Representative  Office Manager & Events

 Number of EE Supervised  Organizational Chart  Responsibilities 11  Relations Key Responsibilities Office Manager & Events is responsible for: supporting the General Representative in all office activities and EU projects; supporting Divisional Managers; managing events and marketing initiatives Managing communication and media relations managing employees health & safety issues managing issues relating to privacy and 231 laws managing BCP and BIA  Office Manager & Events

 Number of EE Supervised  Organizational Chart  Responsibilities 12  Relations Main Internal Relations Reports directly to the General Representative. Cooperates with Divisional Managers. Main External Relations All Third Parties Media Consultants  Office Manager & Events

 Number of EE Supervised  Organizational Chart  Responsibilities 14  Relations  General Manager General Representative Office Manager & Events Regulatory & Compliance Financial Control General Manager Operations Support Market Support PA to General Representative

 Number of EE Supervised  Organizational Chart  Responsibilities 15  Relations Key Responsibilities General Manager is responsible for: implementing the Lloyd’s strategy, coordinating Divisional Managers; overseeing the correct activities Development; Market development; evaluating Coverholders and Open Market Correspondents applications; defending the inappropriate use of the Lloyd’s brand; managing Human Resources (pro-tempore) ; For more detailed responsibilities description, please refer to the specific Procedures in the second part of “LIO Procedures Manual”.  General Manager

 Number of EE Supervised  Organizational Chart  Responsibilities 16  Relations  General Manager Regulatory & Compliance Financial Control General Manager Operations Support Market Support

 Number of EE Supervised  Organizational Chart  Responsibilities 18  Relations  Regulatory & Compliance General Representative Office Manager & Events Regulatory & Compliance Financial Control General Manager Operations Support Market Support PA to General Representative

 Number of EE Supervised  Organizational Chart  Responsibilities 19  Relations Key Responsibilities Regulatory & Compliance Manager is responsible for: identifying and circulating any relevant legislative provisions to ensure regulatory compliance; coordinating the management of the following processes: −Anagrafe Tributaria - Complaints Management; −Legal Proceedings Management; −Coinsurance Claims Management − Coverholder and Open Market Correspondent applications  Regulatory & Compliance

 Number of EE Supervised  Organizational Chart  Responsibilities 20  Relations Key Responsibilities (cont'd) Anagrafe Tributaria Regulatory & Compliance Manager is responsible for preparing the statutory periodic reporting to be submitted to the “Anagrafe Tributaria” in accordance with the Italian Legislative Decree 223/06, art. 35 and for complying with any other relevant legislative provision. Complaints management Regulatory & Compliance Manager is responsible for complying with “ISVAP Circolare 518/D” requirements in terms of managing complaints receipt and answering and is also responsible for quarterly statutory reporting to ISVAP. Legal Proceedings Management Regulatory & Compliance Manager is required to act as a facilitator between the Lloyd’s Managing Agents and the attorneys as regarding attorneys’ appointment and legal proceedings.  Regulatory & Compliance

 Number of EE Supervised  Organizational Chart  Responsibilities 21  Relations Key Responsibilities (cont'd) Coinsurance Claims Management Regulatory & Compliance Manager is responsible for granting complete and timely communication among the co-insurers participating in each Policy in order to facilitate funds collection and claims settlement. CH and OMC registrations Regulatory & Compliance Manager is responsible for ensuring that support is given to the General Manager in processing OMC and evaluation CH applications For more detailed responsibilities description, please refer to the specific Procedures in the second part of “LIO Procedures Manual”.  Regulatory & Compliance

 Number of EE Supervised  Organizational Chart  Responsibilities 22  Relations Regulatory & Compliance Executive Regulatory & Compliance Manager Regulatory & Compliance Executive  Regulatory & Compliance

 Number of EE Supervised  Organizational Chart  Responsibilities 23  Relations Main Internal Relations Reports directly to the General Manager. Cooperates with Financial Control Division and the Lloyd's Distribution Network. Main External Relations Insured Parties. ISVAP. Outsourcers. Legal advisors Prospective & existing Coverholders and Open Market Correspondents.  Regulatory & Compliance

 Number of EE Supervised  Organizational Chart  Responsibilities 25  Relations General Representative Office Manager & Events Regulatory & Compliance Financial Control General Manager Operations Support Market Support PA to General Representative  Operations support

 Number of EE Supervised  Organizational Chart  Responsibilities 26  Relations Key Responsibilities Operations Support Manager is responsible for managing: LIO hardware and software, as regarding: assets buying needs; Data Bases accessing and using. Mocha, as regarding: opening new Binders; performing help desk activities. Information management: Data flows, reporting and analysis Anagrafe Tributaria For more detailed responsibilities description, please refer to the specific Procedures in the second part of “LIO Procedures Manual”.  Operations support

 Number of EE Supervised  Organizational Chart  Responsibilities 27  Relations Main Internal Relations Reports directly to the General Manager. Cooperates with ITG (Corporation IT). Main External Relations Coverholders. Lloyd ’ s Broker. Managing Agents  Operation Support

 Number of EE Supervised  Organizational Chart  Responsibilities 29  Relations  Market Support General Representative Office Manager & Events Regulatory & Compliance Financial Control General Manager Operations Support Market Support PA to General Representative

 Number of EE Supervised  Organizational Chart  Responsibilities 30  Relations Key Responsibilities Market Support Manager is responsible, for coordinating the management of the following processes: Public Tenders; Policy Checking and Signing; Contracts Cancellation. Market Intelligence Public Tenders Market Support Manager is responsible for facilitating the Lloyd's Distribution Network in participating in Italian Public Tenders through: preparing and submitting bids to Public Body and analysing, in case of contract awarding, related Cover Notes and Policies accuracy.  Market Support

 Number of EE Supervised  Organizational Chart  Responsibilities 31  Relations Key Responsibilities (cont'd) Policy Checking and Signing Market Support Manager is in charge of checking for accuracy the Open Market Policies before committing Lloyd’s Underwriters through the General Representative signature. Contracts Cancellation Market Support Manager is also responsible for enabling timely policy cancellation as requested by both Insured Parties and Underwriters. For more detailed responsibilities description, please refer to the specific Procedures in the second part of “LIO Procedures Manual”.  Market Support

 Number of EE Supervised  Organizational Chart  Responsibilities 32  Relations Market Support Executive Market Support Market Support Executive  Market Support

 Number of EE Supervised  Organizational Chart  Responsibilities 33  Relations Main Internal Relations Reports directly to the General Manager. Cooperates with the Lloyd's Distribution Network. Main External Relations Public Bodies as Public Tenders and related Brokers. Insured Parties. Managing Agents  Market Support

 Number of EE Supervised  Organizational Chart  Responsibilities 35  Relations  Financial Control General Representative Office Manager & Events Regulatory & Compliance Financial Control General Manager Operations Support Market Support PA to General Representative

 Number of EE Supervised  Organizational Chart  Responsibilities 36  Relations Key Responsibilities Financial Control Manager is responsible for coordinating the management of the following processes: Premiums and Premium Taxes Cash Flow; Financial Statement Preparation; Cash Management Premiums and Premium Taxes Cash Flow Financial Control Manager is responsible for managing premiums receipt for “Freedom of Establishment” policies only and for managing premium tax return submission and payment for both “Freedom of Establishment” and “Freedom of Services“ policies in compliance with the fiscal legislation applicable. Financial Statement Preparation Financial Control Manager is in charge of preparing, supported by the Outsourcer, the LIO Financial Statement for tax payment purposes granting its correctness and accuracy.  Financial Control

 Number of EE Supervised  Organizational Chart  Responsibilities 37  Relations Key Responsibilities (cont'd) Cash Management Financial Control Manager is responsible for managing bank accounts and petty cash in order to guarantee that all payments and incomings be completely, accurately and timely recorded. In addition to the above mentioned responsibilities, Financial Control Manager is responsible for: supporting the General Representative in preparing the Budget; translating in Italian, for filing at the Italian Chamber of Commerce purposes, the Corporation-related Lloyd’s Annual Report supporting the General Manager in HR management managing supplier relatioships For more detailed responsibilities description, please refer to the specific Procedures in the second part of “LIO Procedures Manual”.  Financial Control

 Number of EE Supervised  Organizational Chart  Responsibilities 38  Relations Premiums Executive Financial Control Claims Executive  Financial Control

 Number of EE Supervised  Organizational Chart  Responsibilities 39  Relations Main Internal Relations Reports directly to the General Manager. Cooperates with the Lloyd's Distribution Network. Main External Relations Banks. Outsourcers. Suppliers.  Financial Control

 Procedures  Premise  Job Descriptions 41 Roles Matrix Legend Regulatory & Compliance Financial Control Market Support Operations Support Brand & Information Management Office Management & HR

 Procedures  Premise  Job Descriptions 42 Roles Matrix Legend Regulatory & Compliance Financial Control Market Support Operations Support Brand & Information management Office Management & HR

 Procedures  Premise  Job Descriptions 43 GR Office Manager General Manager Regulatory & Compliance Operations Support Market Support Financial Control PA to GR Anagrafe Tributaria√√√ Complaints Management√√ Legal Proceedings Management√√ Coinsurance Claims Management√√ Premiums and Premium Taxes Cash Flow Management√√ Budget√√√ Financial Statement Preparation√ Cash Management Procedure√√√  Roles Matrix

 Procedures  Premise  Job Descriptions 44 GR Office Manager General Manager Regulatory & Compliance Operations Support Market Support Financial Control PA to GR Public Tenders √√ Policies Checking and Signing √√√√ Contracts Cancellation Management √√√ IT Management √√√√ Mocha Management √ CH & OMCs √√√ Protection of Lloyd’s Trade Mark √√√ Information Management √√√√  Roles Matrix

 Procedures  Premise  Job Descriptions 45 GR Office Manager General Manager Regulatory & Compliance Operations Support Market Support Financial Control PA to GR Privacy and Safety √√√ Human Resources Training and Management √√√√  Roles Matrix

47 ! Activity owner Activity External input XXXXXXActivity to be implemented Statutory Document–back up paper evidence Data Bases and Accounting/Management Systems Control Activity (if red, control activity relevant ex Italian Legislative Decree 231/2001) Ref. to other procedures included in the Manual Ref. to a specific paragraph included in the procedure Outsourcers performing activities on behalf of LIO B  Legend

 Procedures  Premise  Job Descriptions 49 Anagrafe Tributaria

50  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Scope The aim of this Procedure is identifying roles, responsibilities and activities related to the periodic reporting to Anagrafe Tributaria Responsibilities The Process involves: Regulatory & Compliance Manager; Regulatory & Compliance Executive; Operations Support Manager. General Representative  Anagrafe Tributaria

51  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List ! Regulatory & Compliance Manager Regulatory & Compliance Executive General Representative Operations Support Manager 1.Informs both Italian and Lloyd’s markets on the law provision 4.. Receives the information quarterly /annually from Lloyd’s Correspondents/ Lloyd’s Brokers and loss adjusters regarding: claims settled; payee tax-payer’s code; Third parties defendants fees settled by underwriters for statutory reporting purposes and related to the previous quarter period verifying the correctness of the operation. 5.. Prepares the annual report to “Anagrafe Tributaria”. 6.. Checks on the completeness and accuracy of the report using the adequate audit techniques. 2.Extracts automatically form Iassicur the information needed for statutory reporting purposes. 3.Double checks the accuracy of the extraction. 7. Analyses the statutory annual report for accuracy and authorises the sending. 8. Statutory annual report dispatch to the Outsourcer for formal transmission to “Anagrafe Tributaria”.  Anagrafe Tributaria

52  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Statutory periodic reporting to “Anagrafe Tributaria” (!) / 1 LIO’s calendar Operations Support Manager 2.IASSICUR extraction of all payments related to claims settlement of the fiscal year (Lloyd’s Correspondent’s). 3.Double check of the extraction before forwarding it to Regulatory & Compliance Manager. Iassicur Lloyd’s Correspondent/ Lloyd’s Broker/loss adj. List of payments related to claims settled during the quarter Regulatory & Compliance Executive 1.Information to the markets about law provision 4. Receives list of payments from the markets Iassicur Next page D 3.2. 1.  Anagrafe Tributaria

53  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 3. Statutory periodic reporting to “Anagrafe Tributaria” (!) / 2 Regulatory & Compliance Manager 5. Annual reporting to “Anagrafe Tributaria” preparation. 6. Checks on the completeness and accuracy of the report through a systematic audit activity (random sampling). 7. Analysis and authorises the sending of the statutory annual report to “Anagrafe Tributaria”. General Representative F Previous page 8. Statutory annual report dispatch to Outsourcer for formal transmission to “Anagrafe Tributaria” through Entratel software. Regulatory & Compliance Executive Out-mail DB E ! Transmission to “Anagrafe Tributaria” through Entratel software. Outsourcer 3.2. 1.  Anagrafe Tributaria

54  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List D E F  Anagrafe Tributaria ReferenceControl activityOwnerTiming Financial Control Manager double checks the extraction performed for the statutory reporting purposes before forwarding it to Regulatory & Compliance Manager. Financial Control Manager Quarterly Regulatory & Compliance Manager and Operations Manager verifies the completeness and accuracy of the statutory report through a systematic audit activity (random sampling) properly documented. Regulatory & Compliance Manager and Operations Manager Annually General Representative or others granted the power of attorney analyses and authorises the sending of the statutory annual report to “Anagrafe Tributaria”. General Representative or others granted the power of attorney Annually

55 Complaints Management

56  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Context According to the “ISVAP Circolare 518/D ”, it is mandatory for Insurance Companies receiving complaints from insured parties to manage them timely (within 45 days from the receipt date) providing complete information. In case of incomplete or no response, the insured party is allowed to address the complaint to ISVAP who is entitled to enquire asking the Insurance Company for details to be provided timely (within 30 days from the receipt date) and completely in order to avoid fine notification. Any complaint, enquiry and response has to be timely recorded into ISVAP Complaints Data Base and filed.  Complaints Management

57  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Scope The aim of this Procedure is identifying roles, responsibilities and activities related to LIO (hereinafter also called “LIO”) Complaints Management. In detail, this Procedure regulates: ISVAP enquiries and insured parties complaints receipt; LIO direct response to ISVAP or insured party; Lloyd’s Correspondent / Loss Adjuster direct response to ISVAP or insured party; periodic statutory reporting to ISVAP. Roles The Process involves: General Representative; Regulatory & Compliance Manager; Regulatory & Compliance Executive.  Complaints Management

58  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 5. Correspondent/Loss Adjuster unsatisfactory response 4. Correspondent/Loss Adjuster direct response 3. LIO response Regulatory & Compliance Manager 1.Receives the complaints from insured parties and analyzes them in order to identify level of urgency. 2.Returns to the sender complaints incorrectly addressed to LIO. 6.Follows up the Lloyd’s Correspondent / Loss Adjuster responses. Regulatory & Compliance Executive 3.Records in-coming mail. 4.Identifies Lloyd’s Correspondents/Loss Adjusters and forwards them the complaint in order to obtain information. 5.Updates the ISVAP Complaints Data Base. 6.Follows up the Lloyd’s Correspondents/Loss Adjusters responses. 1.Receives ISVAP enquiries and analyzes them in order to identify level of urgency. 2.Analyses whether replying instantly to ISVAP stating the enquiry is in course of analysis. 3.Identifies competent Lloyd’s Correspondents/Loss Adjusters and forwards them the enquiry in order to obtain the information. 4.Assigns the answer responsibility. 6.Follows up the Lloyd’s Correspondent / Loss Adjuster responses. 5.Updates the ISVAP Complaints Data Base. 6.Follows up the Lloyd’s Correspondent / Loss Adjuster responses. 1.Performs cross checks between ISVAP enquiry/ insured party complaint and Lloyd’s Correspondents/ Loss Adjusters response. 2.Supports the parties in solving the issues organizing meetings at LIO’s if considered helpful. 4.Analyses the formal response before signing-off. General Representative or his delegated 5.Signs the formal response to ISVAP/insured party. 3.Prepares formal response to ISVAP/insured party. 6.Dispatches the formal response and related attachments. 7.Records out-going mail. 2. ISVAP enquiry 1. Insured party complaint receipt 2.Analyses accuracy of the note prepared by the Executive and signs-off. 2.In case of fine paying, claims back the amount paid from the responsible Lloyd’s Correspondent / Loss Adjuster. 1.Decides, together with Underwrites, between appeal filing and fine payment. ! 3.Signs the note addressed to ISVAP. 1.Prepares a note addressed to ISVAP referring to the Lloyd’s Correspondents/ Loss Adjusters answer as the one to be considered in response to the enquiry. 4.Dispatches the formal response and records out-going mail. Complaints receiptComplaints management  Complaints Management

59  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Out mail DB Insured party Complaint. 1. Insured party complaint receipt 6.Standard e-mail feedback request to Lloyd’s Correspondents/Loss Adjusters and Correspondents Database out-going mail recording. 1.In-coming mail receipt and prioritization. Regulatory & Compliance Executive/Manager Regulatory & Compliance Manager In mail DB ISVAP Complaints DB 3.In-coming mail recording. 4.Lloyd’s Correspondents/ Loss Adjusters identification and complaint forwarding. 5.ISVAP Complaints DB updating and out-going mail recording. Regulatory & Compliance Executive ! 6.5.4.3.2. 1. Complaint s belonging to LIO 2.Return to sender. Regulatory & Compliance Manager A NO Out mail DB 3. 4.  Complaints Management

60  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List ISVAP ISVAP enquiry. Regulatory & Compliance Manager 2. ISVAP enquiry 1.In-coming mail prioritization. 2.Decision whether reply instantly to ISVAP (copy to the Insured Party) stating that the enquiry is being examined. 3.Competent Lloyd’s Correspondents/ Loss Adjusters identification and ISVAP enquiry forwarding. 4.Analysis of the enquiry and decision on who is responsible for answering. 5.ISVAP Complaints DB updating and out-going mail recording. 6.Standard e-mail feedback request to Lloyd’s Correspondent and out-going mail recording. 3. 4. Regulatory & Compliance Executive ISVAP Complaints DB Out-mail DB ! 6.5.4.3.2. 1.  Complaints Management

61  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 3. LIO response Lloyd’s Correspondent/ Loss Adjuster Enquiry/complaint response. 2. 1. Regulatory & Compliance Manager 1.Cross check between ISVAP enquiry/insured party complaint and Lloyd’s Correspondent/ Loss Adjuster response. 2.Supporting the parties in meetings in order to find an agreement. General Representative or his delegated 5.Response sign-off. 6.Response and attachments dispatch ISVAP complaints. 7.Database out-going mail recording. Regulatory & Compliance Executive ISVAP Complaints DB ! B D 6.5.4.3.2. 1. Regulatory & Compliance Executive 3.Formal letter preparation and cross check with ISVAP enquiry. Regulatory & Compliance Manager 4.Formal letter analysis and sign-off. C  Complaints Management

62  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 4. Correspondent/Loss Adjuster direct response Lloyd’s Correspondent/ Loss Adjuster Enquiry response to ISVAP/ insured party, copy to LIO. 1.Note stating that the response has already been sent by Lloyd’s Correspondent/Loss Adjuster. Regulatory & Compliance Executive 2. 1. 4.Note dispatch and ISVAP Complaints Database out-going mail recording. Regulatory & Compliance Executive ISVAP Complaints DB 3.Note analysis and sign-off. General Representative or his delegated ! F 6.5.4.3.2. 1. 2.Note review and sign-off. Regulatory & Compliance Manager E  Complaints Management

63  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 5. Correspondent/Loss Adjuster unsatisfactory response ISVAP Summary of the proceedings and fine notification. General Representative or his delegated 1.Decision, together with Lloyd’s Underwriters, between paying the fine and appeal filing. Legal Proceedings Management Cash Management Unsatisfactory response to ISVAP Underwriters 6.5.4.3.2. 1. Regulatory & Compliance Manager 2.Consequent fine claiming back from the Lloyd’s Correspondent/ Loss Adjuster responsible for the fine.  Complaints Management

64  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List ReferenceControl activityOwnerTiming Regulatory & Compliance Manager analyzes in-coming mail and identifies the complaints incorrectly addressed to LIO in order to return them to the sender (out-going mail recording). No Complaints Data Base update is required. Regulatory & Compliance Manager Daily Regulatory & Compliance Manager cross checks ISVAP enquiry/insured party complaint against Lloyd’s Correspondents/ Loss Adjusters response in order to guarantee information relevance and signs as check evidence. Regulatory & Compliance Manager Ad hoc Regulatory & Compliance Manager letter/note review for accuracy and sign-off. Regulatory & Compliance Manager Ad hoc General Representative, or other granted the power of attorney, signs-off the responses/notes to ISVAP/insured party after having analyzed the correctness of its contents. General Representative or others granted the power of attorney Ad hoc A B D F As a general rule, any documentation addressed to ISVAP or Public Administration needs to be double checked and signed before dispatching by either the General Representative or the General Manager. C E  Complaints Management

65 Legal Proceedings Management  Legal Proceedings Management

66  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Scope The aim of this Procedure is identifying roles, responsibilities and activities related to LIO (hereinafter also called “LIO”) Legal Proceedings Management. In detail, this Procedure regulates: the legal proceedings notification; the attorney appointment; Please consider that LIO mainly acts as a facilitator between the Managing Agent and the attorneys. Roles The Process involves: General Representative; Regulatory & Compliance Manager; Regulatory & Compliance Executive.  Legal Proceedings Management

67  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Regulatory & Compliance Manager 1.Receives and analyses the service of suit rejecting those containing significant faulty drafting and those related to the freedom of services. 2.Highlighting main information contained in the service of suit such as: loss adjusters involved; court hearing date; policies; underwriters involved; etc. 3.Forwards the service of suit to Regulatory & Compliance Executive Regulatory & Compliance Executive 4.Updates lawsuits log and n-coming writs recording and scanning. 5.Identifies the Managing Agent/ Loss Adjuster involved in the policy the service of suit refers to and forwards document immediately with request of acknowledgement.. If not present, forwards this to the Legal Services Department in London. 6.Updates Mulan, the legal proceeding dedicated software internally built, with the service of suit electronic copy and all related information. 7.Launches the automatic Mulan procedure for asking all involved to select an attorney. 8.With the help of the calendar in Mulan and considering the court hearing date, asks for feed back about the attorney selection to Managing Agent/Loss Adjuster. 1.Appoints the attorney in accordance with Managing Agent/Loss Adjuster selection. 2.In case of missing attorney selection within the due term involves Lloyd’s Legal Services for the selection/appointment of an attorney.. 4.Forwards the service of suit to one of the newly appointed attorney/attorneys General Representative or his delegated 3.Signs the power of attorney verifying that the appointment is in line with Managing Agents instructions and internal policies. 2. Attorney appointment 1. Legal proceeding notification 5.Scans the documentation and updates Mulan.  Legal Proceedings Management

68  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Insured party Service of Suit (Freedom of establishment only). 1. Legal proceeding notification 1.Writ service acceptance, rejecting all those containing significant faulty drafting and FOS 2.Writs analysis and highlighting of main contents 3.Writ forwarding to R&C Executive 8. In case of lack of feedback from MA/Adjuster, selection of attorney in agreement with Lloyd’s Legal Services (not to prejudice Lloyd’s position). Regulatory & Compliance Manager 3.2. 1. In-mail DB Mulan Out-mail DB 4.Writs scanning and recording and log updating. 5.Identification of the relevant Managing Agent/Loss Adjuster involved and forward documentation with request of acknowledgment. 6.Mulan (database) update. 7.Letter for defendant selection automatically issued and sent to involved MAs 9. Activity recording into database (Mulan). Regulatory & Compliance Executive A B  Legal Proceedings Management

69  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Mulan Out-mail DB 2. Attorney appointment MA or Loss Adjuster Attorney selection. 1.Attorney appointment in accordance with the selection. Regulatory & Compliance Manager * In case of more attorneys, one of them will be forwarded the service of suit while the others will be asked to prepare the documentation needed for participating in the legal proceeding. 3.Power of attorney signature. General Representative or his delegated 4.Writs forwarding to attorney*. Regulatory & Compliance Manager C ! Attorney selection receipt Yes NO 2.Attorney appointment in agreement with Lloyd’s Legal Services. Regulatory & Compliance Manager 5.Documentation scan, Mulan update and out-mail recording. Regulatory & Compliance Executive 3.2. 1.  Legal Proceedings Management

70  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List ReferenceControl activityOwnerTiming Regulatory & Compliance Manager analyses the in-coming mail rejecting Services to Suit with significant faulty drafting and those relating to the freedom of services. Regulatory & Compliance Manager Ad hoc Regulatory & Compliance Executive requires feedback for legal proceedings lacking input from the interested parties. Regulatory & Compliance Executive Daily General Representative, or others granted the power of attorney, signs the power of attorney after cross checking it against the Managing Agent/Loss Adjusters selection or, if instructions missing, liaising with Lloyd’s Legal Service for identification of defendant. General Representative or others granted the power of attorney Ad hoc A B C  Legal Proceedings Management

71 Coinsurance Claims Management

72  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Context Coinsurance is the sharing of risks between two or more Insurance Companies based on agreed percentages. As a consequence of the percentage held, Insurance Companies taking part in the policy might be leader or followers. The former is responsible for administering various aspects of the insurance policy (e.g.: premium, claims, insurance documents) while the latter receives his part of the premium and is required to cooperate with the leader in case of claim settlement.  Coinsurance Claims Management

73  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Scope The aim of this Procedure is identifying roles, responsibilities and activities related to LIO (hereinafter also called “LIO”) Coinsurance Claims Management in the sole case of Lloyd’s being a follower. This Procedure regulates: Co Insurance statement of accounts receipt and funds collection; funds receipt and claims settlement; related to policies issued by Open Markets Correspondents only and where Lloyd’s is a follower. Any other Co Insurance policy, since less frequent, is to be considered out of scope. Roles The Process involves: Regulatory & Compliance Manager; Regulatory & Compliance Executive; Financial Control Division.  Coinsurance Claims Management

74  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Regulatory & Compliance Manager 1.Receives the leading insurer statement of accounts and forwards it to the Regulatory & Compliance Executive. 4.Analyses the Bordereaux investigating the oldest/strange situations and signs it (sample check allowed). Regulatory & Compliance Executive 2.Performs the match between the statement of accounts received and the Lloyd’s Broker that issued the policy in order to prepare the Bordereaux for fund collection purposes. 3.Prepares the Lloyd’s Brokers Bordereaux for cash collection from the Syndicates. 5.Dispatches the Bordereaux. 6.Records the out-going mail. 7.Periodically, requests (via e-mail) feedback to the Lloyd’s Brokers in case of late/missing payments. 2. Funds receipt and claims settlement 1. Funds collection Financial Control Division 2.Communicates cash in claims settlement related to Regulatory & Compliance Executive. 1.Receives the Broker e-mail referring to future money transfer. 3.Cross checks the funds received from Lloyd’s Brokers/Syndicates against the related Bordereaux in order to verify the completeness of the cash received. 4.Updates the Bordereaux. 5.Periodically cross checks the Bordereaux against the leading insurance companies reserves statement of accounts and adjusts the claims to the leading insurance company reserve. 6.Analyses the cross check performed by the Regulatory & Compliance Executive and authorizes/rejects (sign-off) the claims adjustments.  Coinsurance Claims Management

75  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 1. Funds collection Leading Insurer Statements of accounts Regulatory & Compliance Manager 1.Statement of accounts receipt and Regulatory & Compliance Executive forwarding. Regulatory & Compliance Manager 4.Bordereaux analysis and oldest/strange situations investigation and sign- off (sample check allowed). Regulatory & Compliance Executive 5.Bordereaux dispatch to competent Lloyd’s Broker for Syndicates funds collection purposes. 6.Out-going mail recording. 7.Periodic e-mail feedback request to competent Lloyd’s Broker. Out mail DB A 2. 1. Regulatory & Compliance Executive 2.On the basis of statement of accounts, definition of competent Lloyd’s Broker. 3.Bordereaux preparation.  Coinsurance Claims Management

76  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 2. Funds receipt and claims settlement Lloyd’s Broker Funds transfer Regulatory & Compliance Executive 3.Cross check between funds received and related Bordereaux and back up documentation sign-off. 4.Bordereaux updating. 5.Cross checks the Bordereaux against the leading insurance companies reserves statement of accounts and differences adjustments. Iassicur 2. 1. Regulatory & Compliance Executive 1.Lloyd’s Broker e-mail receipt about the money transfer and Bordereaux reference. Financial Control Division 2.Cash in communication. Regulatory & Compliance Manager 6.Analyses of the reserve cross check in order to authorize/reject the adjustments performed signing the back up documentation. B  Coinsurance Claims Management

77  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List ReferenceControl activityOwnerTiming Regulatory & Compliance Manager analyses the Bordereaux investigating the oldest/strange situations and sign-off (sample check allowed). Regulatory & Compliance Manager Ad hoc Regulatory & Compliance Manager analyses the periodic reserve cross check performed by the executive in order to authorize/reject the adjustments signing the back up documentation. Regulatory & Compliance Manager Annually A B  Coinsurance Claims Management

OMC registration and CH approval

79  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Scope The aim of this Procedure is identifying roles, responsibilities and activities related to Registration of Open Market Correspondent and Approval of Coverholders Responsibilities The Process involves: General Representative; General Manager.  OMC registration and CH approval

80  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Open Market Correspondent Coverholders General Manager supported by Regulatory & Compliance General Representative 1.Receives notification of OMC to be registered from Lloyd’s Brokers, who is supposed to have already verified it. 3.After the authorization receipt, prepares the welcome kit, informs the General Representative and meets the new OMC for contract signing. 4.Files all documentation. 2.Authorizes a new relationship with the incoming Open Market Correspondent (herein after also “OMC”). 1.Receives the documentation of ingoing CH from Lloyd’s Broker, who is supposed to have already verified it. 3.Meets the ingoing CH to evaluate the Head Office and the people. 4.Completes the check list with all information needed by the application form. 6.After the General Manager authorization, asks CH the professional indemnity insurance extension. 7.After the authorization receipt, prepares the welcome kit, informs the General Representative and asks the Corporation the Approval confirmation. 8.At insurance receipt, meets the new CH to sign the contract. 9.Files all documentation. 10.Uploads the Correspondents Database. 2.Authorizes the a new relationship with the incoming Coverholder (herein after also “CH”).. 5.Evaluates the check list information and authorizes the new relationship with the CH.  OMC registration and CH approval

81  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 1. Application for Open Market Correspondent / 1 General Representative 3.Relationship authorization. General Manager 1.Details check. A B Third Intermediary Identification of the Lloyd’s Broker as a Sponsor. Request of registration by an OMC Application Form. Lloyd’s Broker Verify the documentation and submit request with OMC details. A Next page  OMC registration and CH approval

82  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Copy Contract signed by General Representative Covering Letter with the OMC’s Code and agreement’s date of expire Circular letters from ISVAP to Correspondents Procedure Handbook LIO Organization Chart Brochures General Manager 5.Prepare the welcome kit and communicate to General Representative the turn out well of the application. 1. Application for Open Market Correspondent / 2 General Manager 6.Documentation filing. 7.Upload Correspondents Database. D Lloyd’s London Authorize the relationship and assign a OMC identification number. C Third Intermediary General Manager to sign the contract during meeting. Previous page  OMC registration and CH approval

83  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 1. Application for Coverholders / 1 General Representative 2.Relationship authorization. General Manager 1.Documentation check. Application Form Balance Sheet Business Resume Business Plan A General Manager 3.Request to ingoing Coverholder a meeting to evaluate the Head Office and the People Lapse of time: Three Weeks Third Intermediary Identification of the Lloyd’s Broker as a Sponsor. Request of registration by an Application Form. Lloyd’s London Documentation check. A B Next page  OMC registration and CH approval

84  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List General Manager 4.Checklist completion. General Representative 5.Relationship authorization. E 1. Application for Coverholder / 2 General Manager 6.Request to ingoing CH the extension of professional indemnity insurance and a €25.000. General Manager 7.Documentation collection. General Manager 8.Meet new Coverholder. 9.Documentation filing. 10.Upload Correspondents Database. Lapse of time: Three Weeks Lloyd’s London Approval confirmation. Third Intermediary New insurance policy copy. B D Previous page  OMC registration and CH approval

85  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List ReferenceControl activityOwnerTiming Documentation check.General ManagerAd hoc Authorizes the relationship (he is aware of). General Representative Ad hoc Authorizes the relationship.Lloyd’s LondonAd hoc Tracks the operations and files of information.General ManagerAd hoc Check List creation by Lloyd’s London for the specific Application Form. General ManagerAd hoc A B C D E  OMC registration and CH approval

87 Premiums and Premium Taxes Cash Flow Management

88  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Scope The aim of this Procedure is identifying roles, responsibilities and activities related to LIO (hereinafter also called “LIO”) Premiums and Premium Taxes Cash Flow Management. The Procedure regulates premiums receipt relating to “Freedom of Establishment” policies only and tax payment for both “Freedom of Establishment” and “Freedom of Services“ policies. Responsibilities The Process involves: General Representative; Financial Control Manager; Financial Control Executive.  Premiums and Premium Taxes Cash Flow Management

89  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Financial Control Manager 7.Checks the accuracy of the premium taxes to be paid as extracted automatically from Iassicur analysing, in an excel spreadsheet to be filed, the tax rate per single line of business. 8.Prepares the monthly premium tax payment. 9.Prepares the monthly premium tax return for submission to the competent tax agency (freedom of services only). 10.Prepares the annual premium tax return for submission to the competent tax agency (freedom of establishment only). Financial Control Executive 1.Records in-coming mail. 2.Processes the premium taxes and premiums statement of accounts and records them in Iassicur. 3.Analyses the cash-in as resulting from the on-line banking. 4.Records in Iassicur the cash-in daily received. 5.Automatically extracts the premiums from Iassicur for weekly premiums analyses purposes and reconciles them against the cash received through a dedicated form to be signed and filed. 6.Submits the weekly premiums analyses to Lloyd’s Brokers. General Representative or his delegated 1. Premiums and Premium Taxes Cash Flow Management 11.Analyses and signs the tax returns. 12.Transmits formally the premium tax returns to the competent tax agency (freedom of establishment only). 13.Submits the premium tax returns to the outsourcer for formal transmission to the competent tax agency (freedom of services only).  Premiums and Premium Taxes Cash Flow Management

90  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 1. Premiums and Premium Taxes Cash Flow Management / 1 Lloyd’s Correspondent Premiums and premium taxes statement of accounts and money Financial Control Executive 1.In-coming mail recording. 2.Premiums and premium taxes statement of accounts processing and Iassicur recording (partly manually and partly automatically). 3.Daily cash in analysis. 4.Daily cash in recording in Iassicur. In-mail DB Iassicur Financial Control Executive (cont'd) 5.Weekly Reconciliation through a dedicated form to be signed-off and filed: - Iassicur automatic extraction against the cash received - Bank Figures Analysis: relate with each Iassicur item. 6.Weekly premiums analysis submission to Lloyd’s Brokers. Next page A Iassicur  Premiums and Premium Taxes Cash Flow Management

91  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Cash Management Financial Control Manager 7.Monthly premium taxes to be paid accuracy check through automatic extraction and tax rate analysis per single line of business. 8.Monthly premium tax payment preparation. 9.Monthly premium tax return to the competent tax agency preparation (freedom of services only). 10.Annual premium tax return to the competent tax agency preparation (freedom of establishment only). 1. Premiums and Premium Taxes Cash Flow Management / 2 Previous page 11.Analysis and sign-off of the premium tax returns. 12.Premium tax returns formal transmission to the competent tax agency (freedom of establishment only). 13.Premium tax returns submission to the outsourcer for formal transmission to the competent tax agency (freedom of services only). General Representative or his delegated C B Transmission to competent tax agency (freedom of services only). Outsourcer  Premiums and Premium Taxes Cash Flow Management

92  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List ReferenceControl activityOwnerTiming Financial Control Executive extracts automatically from Iassicur the premiums recorded during the previous week and reconciles them against the cash received (and recorded by the Financial Control Executive) filling and signing the dedicated form. Financial Control Executive Weekly Financial Control Manager verifies the accuracy of the premium taxes to be paid extracting automatically the report from Iassicur and verifying the correctness of the tax rate applied using an excel spreadsheet (Pivot) organized per single line of business and filed. Financial Control Manager Monthly General Representative, or others granted the power of attorney, analyses the correctness of the premium tax returns before signing and submitting them to the outsourcer for formal transmission to the competent tax agency. General Representative or others granted the power of attorney Monthly/Annually A B C As a general rule, any documentation addressed to Public Administration needs to be double checked and signed before dispatching by either the General Representative or others granted the power of attorney.  Premiums and Premium Taxes Cash Flow Management

93 Budget

94  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Scope The aim of this Procedure is identifying roles, responsibilities and activities related to LIO (hereinafter also called “LIO”) Budget and Forecast Preparation and Management. In detail, this Procedure regulates: Budget preparation; unbudgeted expenditures; Forecast preparation. Roles The Process involves: General Representative; Financial Control Manager; Divisional Manager;  Budget

95  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 1. Budget preparation 2. Unbudgeted expenditures 3. Forecast preparation Financial Control Manager Divisional Manager General Representative 1.Receives budget instructions, relevant excel templates and timetable. 2.Defines Budget assumptions. 3.Prepares, with the Financial Control Manager support, the Budget in line with the instructions received. 4.Files all the back up documentation. 6.Checks Budget accuracy against the instructions received and files the Budget final version. 7.Submits the Budget to Lloyd’s Corporation. 8.Records out-going mail. 5.Supports the General Representative in preparing the Budget. 1.Analyses the unbudgeted expenditures and authorises the request (sign-off) as evidence of the expense real need. 2.Analyses the unbudgeted expense request. 3.In case of unbudgeted expenses amounting to less than € 20.000, authorises/rejects the expense. 4.In case of extra-budged expenses amounting to more than € 20.000, forwards the authorization request to Lloyd’s Corporation. 5.Out-going mail recording. 1.Receives Forecast instructions, relevant excel templates and timetable. 2.Prepares, with the Financial Control Manager support, the Forecast in line with the instructions received including all unbudgeted expenses already committed to and analysing all main differences vs. Budget. 3.Files all the back up documentation. 5.Checks the Forecast accuracy against the instructions received and files the Forecast final version. 6.Submits the Forecast to Lloyd’s Corporation. 7.Records out-going mail. 4.Supports the General Representative in preparing the Forecast.  Budget

96  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Lloyd’s Corporation Instructions, relevant excel templates and timetable. 1. Budget preparation General Representative 1.Instructions, relevant excel templates and timetable receipt. 2.Budget assumptions definition. 3.Budget preparation supported by Financial Control Manager and in line with the instructions received. 4.Back up documentation/ excel computation filing. Financial Control Manager 5.Budget preparation support. Server General Representative 6.Budget accuracy check against the instructions received and final version filing. 7.Budget submission to Lloyd’s Corporation. 8.Out-going mail recording. Server Lloyd’s Corporation Budget changes. Lloyd’s Executive Team Budget approval. July - AugustNovember A 3.2. 1.  Budget

97  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 2. Unbudgeted expenditures Unbudgeted expenditures request. Divisional Manager 1.Unbudgeted expenditures real need analysis and formal authorization. General Representative 2.Unbudgeted expense request analysis. 3.In case of unbudgeted expenses amounting to less than € 20.000, formal authorization/rejection. 4.In case of unbudgeted expenses amounting to more than € 20.000, authorization requested to Lloyd’s Corporation supported by Business Case. 5.Out-going mail recording. Lloyd’s Corporation Unbudgeted expenditures authorization/denial. Out mail DB B C 3.2. 1.  Budget

98  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Lloyd’s Corporation Instructions, relevant excel templates and timetable. 3. Forecast preparation General Representative 1.Instructions, relevant excel templates and timetable receipt. 2.Forecast preparation including expenses already committed to not included in Budget and main differences vs Budget analysis and explanation. 3.Back up documentation/ excel computation filing. Financial Control Manager 4.Forecast preparation support. Server General Representative 5.Forecast accuracy check against the instructions received and final version filing. 6.Forecast submission to Lloyd’s Corporation. 7.Out-going mail recording. Server Lloyd’s Corporation Forecast play back. D 3.2. 1.  Budget

99  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List ReferenceControl activityOwnerTiming General Representative analyses the Budget accuracy and its compliance with Lloyd’s Corporation instructions, filing the final version. General Representative Annually Divisional Manager analyses the real need of the unbudgeted expenditures request authorizing/rejecting it (sign-off). Divisional ManagerAd hoc General Representative analyses the extra budget expense request authorizing/rejecting it or, in case of unbudgeted expenses amounting to more than € 20.000, forwarding the request and related Business Case to Lloyd’s Corporation. General Representative Ad hoc General Representative analyses the Forecast accuracy and its compliance with Lloyd’s Corporation instructions, filing the final versions. General Representative Half-yearly A B C D  Budget

100 Financial Statement Preparation

101  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Context Under Italian legal framework, the LIO is not required to file its own Financial Statement at the Italian Chamber of Commerce but it is, on the other hand, required to file the translated Corporation Results as of Lloyd’s Annual Report. Scope The aim of this Procedure is identifying roles, responsibilities and activities related to LIO Financial Statement Preparation for tax computation purposes only. Responsibilities The Process involves the Financial Control Manager.  Financial Statement Preparation

102  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Financial Control Manager 1. Financial Statement preparation 1.Receives the suppliers invoices. 2.Records payroll costs. 3.Submits all accounting information to the outsourcer for Financial Statement preparation purposes. 4.Records out-going mail. 5.Records the year-end entries prepared by the outsourcer. 6.Analyses the main variations of the Financial Statement vs budget figures signing the F/S before filing it.  Financial Statement Preparation

103  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 1. Financial Statement preparation Financial Control Manager 1.Suppliers invoices receipt. 2.Payroll costs recording. 3.Accounting information dispatch to the outsourcer. 4.Out-going mail recording. Cash Management Financial Control Manager 5.Year end closing entries recording in Iassicur. Iassicur Financial Control Manager 6.Financial Statement main variations vs budget figures analysis, sign-off and filing A Premiums and Premium Taxes Cash Flow Management In/out-mail DB Documentation receipt and invoices recording. Preparation of year- end closing entries. Outsourcer P/L, B/S and related explanatory note. Outsourcer  Financial Statement Preparation

104  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List ReferenceControl activityOwnerTiming Financial Control Manager analyses the main variations of the Financial Statement vs budget figures signing it as evidence of the checks performed. Financial Control Manager Annually A  Financial Statement Preparation

105 Cash Management Procedure

106  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Scope The aim of this Procedure is identifying roles, responsibilities and activities related to LIO (hereinafter also called “LIO”) Cash Management. The Procedure regulates both bank accounts and petty cash management, there including the maintenance and the control activities. Responsibilities The Process involves: General Representative; General Manager; Financial Control Manager; Financial Control Executive; Divisional Manager; Employee.  Cash Management Procedure

107  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 5. Petty cash management: count of cash 4. Petty cash management: cash in and cash out 3. Banks account management: bank reconciliation Financial Control Manager 1.Detects the need of opening/closing a bank account or of changing the signatures specimen. 3.Prepares the documentation in line with the Corporation instructions received. General Representative and/or his delegated 2. Banks account management: cash in and cash out 1. Banks account management: opening/ closing bank accounts and signature specimen changing 2.Seeks authorization from Lloyd’s Financial Control Division. 4.Analyses the documentation before undersigning it. 1.Detects a payment need. 2.Prepares the bank transfer. 6.Records the cash incomes in Iassicur. 3.Analyses and authorizes invoices; 4.Analyses and authorizes the bank transfers in line with his power of attorney; 5.Sign-in in the on-line bank for paying purposes. 1.Performs the bank reconciliations. 4.Dispatches the Monthly Financial Report to Lloyd’s Corporation. 5.Records out-going mail. 3.Verifies the existence of the bank reconciliations and signs the Monthly Financial Report. Employee 1.Fills the request for cash form. Divisional Manager 2.Authorises the cash withdrawal (less than €200) signing the request for cash form. 3.Authorises the cash withdrawal (more than €200) signing the request for cash form. 8.Analyses and authorises the reinstatement request signing the cheque. 4.Records cash withdrawals and reinstatements. 5.Analyses the petty cash need of reinstatement. 6.Prepares the reinstatement request. 7.Prepares the cheque. 1.Counts the patty cash on a monthly bases. 2.Prepares the count of cash report. 3.Reconciles monthly the petty cash counted against the cash account. 6.Dispatches the Monthly Financial Report to Lloyd’s Corporation. 7.Records out-going mail. 5.Verifies the existence of the petty cash reconciliation and signs the Monthly Financial Report. General Manager 2.Verifies accuracy and completeness of the bank reconciliations. 4.Verifies accuracy and completeness of the cash reconciliations.  Cash Management Procedure

108  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 1.Banks account management: opening/closing bank accounts and signature specimen changing / 1 Financial Control Manager 1.Opening/closing bank accounts or changing signature specimen need. General Representative 2.Authorization seeking from Lloyd’s Financial Control Division for opening/closing bank accounts or changing signature specimen. Lloyd’s Financial Control Division Authorization. Next page A 5.4.3.2. 1.  Cash Management Procedure

109  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Financial Control Manager 3.Preparation of the documentation needed for the operation. 4.Analysis and sign-off of the documentation prepared. General Representative or his delegated Previous page B 1.Banks account management: opening/closing bank accounts and signature specimen changing / 2 5.4.3.2. 1.  Cash Management Procedure

110  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 2.Banks account management: cash in and cash out Financial Control Manager 1.Payment need. 2.Bank transfer preparation. 3.Invoices to be paid authorization: − General Manager - invoices amounting to less than € 2.000; − General Representative - invoices amounting to more than € 2.000. 4.Payment authorization : − Two managers granted the power of attorney jointly - payment amounting to less than € 12.000; − General Representative/London signatories jointly with a manager granted the power of attorney - payment amounting to more than € 12.000. 5.On line/fax authorization. General Representative and/or others delegated C Financial Control Manager 6.Payments/incomings recording*. TLQ Iassicur Bank Incomings. 5.4.3.2. 1. * Premiums and premium taxes related incomes are recorded by the Financial Control Executive.  Cash Management Procedure

111  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 3.Banks account management: bank reconciliation Financial Control Manager 1.Monthly bank reconciliations and Bank Figures analysis: relate with each items of Iassicur (e.g. premiums, premium taxes and claims). 3.Reconciliation existence check and Monthly Financial Report signature. General Representative E Financial Control Manager 4.Monthly Financial Report dispatch to Lloyd’s Corporation. 5.Out-going mail recording. Out-mail DB 5.4.3.2. 1. 2.Reconciliation accuracy and completeness check and sign-off. General Manager D  Cash Management Procedure

112  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 4.Petty cash management: cash in and cash out Employee 1.Cash need 2.Cash need analysis and authorization (written request sign- off). Divisional Manager G Over €200? Yes No 3.Cash need analysis and authorization (written request sign- off). General Representative F Financial Control Manager 4.Cash recording. Iassicur Financial Control Manager 5.Reinstate petty cash need. 6.Request for reinstate. 7.Cheque preparation. H 8.Reinstate request analysis and authorization signing the cheque. General Representative and/or others delegated I Petty cash payments Petty cash reinstatement 5.4.3.2. 1.  Cash Management Procedure

113  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 5.Petty cash management: count of cash Financial Control Manager 1.Monthly count of cash. 2.Count of cash report. 3.Monthly cash reconciliation against cash account. 5.Reconciliation existence check and Monthly Financial Report signature. General Representative L Financial Control Manager 6.Monthly Financial Report dispatch to Lloyd’s Corporation. 7.Out-going mail recording. Out-mail DB 5.4.3.2. 1. N 4.Reconciliation accuracy and completeness check and sign-off. General Manager M  Cash Management Procedure

114  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List ReferenceControl activityOwnerTiming Financial Control Manager, in case of management changes, verify the need of changing signatures specimen. Financial Control Manager Ad hoc General Representative, or others granted the power of attorney, analyses for accuracy the documentation prepared for the bank account opening, closing and for the signature specimen updating before signing. General Representative or others granted the power of attorney Ad hoc General Representative and/or others delegated analyse and authorize the invoices to be paid and authorize the payment orders. General Representative and/or others granted the power of attorney Ad hoc General Manager analyses the bank reconciliations in order to verify accuracy and completeness of bank bookkeeping. General ManagerMonthly General Representative verifies the existence of banks reconciliations and signs the Monthly Financial Report addressed to Lloyd’s Corporation. General Representative Monthly Divisional Manager or General Representative, depending on the amount of the cash requested by each employee, authorizes the cash withdrawal request signing the authorization form. Divisional Manager or General Representative Ad hoc A B C D E F G  Cash Management Procedure

115  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List ReferenceControl activityOwnerTiming Financial Control Manager analyses weekly the need of cash reinstatement and decides whether fill in the cheque. Financial Control Manager Weekly General Representative and/or others granted the power of attorney analyse the reinstate request and authorize it signing the cheque. General Representative and/or others granted the power of attorney Ad hoc Financial Control Manager weekly performs the count of cash and prepares the count report. Financial Control Manager Monthly General Manager analyses the reconciliations between the count of cash and the cash account. General ManagerMonthly General Representative verifies the existence of bank reconciliations and singes the Monthly Financial Report addressed to Lloyd’s Corporation. General Representative Monthly H I L M As a general rule: money deposited in LIO bank accounts cannot be used for any other aim but the one it is dedicated to; no one is allowed to authorize a payment for his own benefit; no cash payments are allowed, a part from those relating to: −stationery; −coffee and similar; −revenue stamps; −public tender related taxes −other little office expenses. N  Cash Management Procedure

117 Public Tenders

118  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Context Under the Italian legal framework, procedures relating to the awarding by public bodies of contracts for insurance services are regulated primarily by the provisions set forth in Legislative Decree 163/2006 (public contracts for services). Scope The aim of this Procedure is identifying roles, responsibilities and activities related to LIO Public Tenders Management which consists of assisting Underwriters, Lloyd’s Brokers, Lloyd’s Coverholders and Correspondents participating in public tenders in Italy through: submitting bids and signing insurance policies and contracts in case of contract awarding. Both bids and contracts/policies are signed by the General Representative in the name of and on behalf of Underwriters.  Public Tenders

119  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Scope (cont'd) In detail, this Procedure regulates: the call for bid receipt and the invitation request; the offer preparation and dispatch; the tender awarding and subsequent obligations management. Roles The Process involves: General Representative; Market Support Manager; Market Support Executive.  Public Tenders

120  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 3. Awarding of contract, subsequent obligations Market Support Manager 3.Checks the accuracy of the application prepared by the Market Support Executive and signs it as check evidence. Market Support Executive 1.Records the call for bid in-coming mail. 2.Prepares the formal application for requesting the invitation to the tender. 5.Dispatches the application signed by the General Representative. 6.Records the out-going mail. 6.Analyses the completeness and accuracy of the Standard Offer Form and verifies that the Lloyd’s Correspondent is different from the Public Body Broker. Signs the Standard Offer Form as evidence of the check performed. General Representative or his delegated 8.Signs the Formal Offer after having cross checked it against the Standard Offer Form. 2. Application to participate and offer submission 1. Call for bids and request for invitation 4.Verifies the additional information prepared by the Executive before signing it. 8.Cross check the policy and the Cover Note against the contract signed by the General Representative and, if needed, the Offer. 1.Forwards the award notification to the competent Lloyd’s Broker. 2.Records the in and out-going mail (contract award notification). 3.Prepares the additional information requested by the Public Body. 5.Dispatches the additional information and records out-going mail. 7.Records in-coming mail (Cover Note). 10.Dispatches to the Public Body, through the Lloyd’s Correspondent, three copies of the policy for signing purposes. 11.Records the out-going mail. 12.Records and files the signed copy of the bid. 4.Analyses the application for the tender before authorizing it (sign-off). 1.Records the in-coming mail (invitation to the tender). 2.Enters the tender information in the Tender Data Base. 3.Quarterly, checks the completeness and accuracy of the information uploaded in the Tender Data Base. 5.Records in-coming mail (Standard Offer). 7.Transposes the Standard Offer Form information in the Formal Offer. 9.Dispatches the offer. 10.Updates the Tenders Data Base and records the out- going mail. Tender Data Base 4.Through a properly profiled access management, allows all interested to view tender information and download the invitation. 6.Signs the contract after having cross checked it against the tender offer. 9.Signs the draft policy after having cross checked the existence of the Market Support Manager sign-off.  Public Tenders

121  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Lloyd’s Correspondent/ Lloyd’s Brokers/ Underwriters Call for bids. 1. Call for bids and request for invitation 1.In-coming mail recording. 2.Formal application preparation for tender invitation purposes. Market Support Executive 3.2. 1. 3.Application check for accuracy and application sign-off. Market Support Manager In-mail DB 4.Application analysis and sign-off. General Representative or his delegated B 5.Application dispatch. 6. Out-going mail recording. Market Support Executive A In-mail DB 2. Lloyd’s Correspondent/ Lloyd’s Brokers/ Underwriters Documentation needed for the application.  Public Tenders

122  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Public Body/ Broker Invitation. 1.In-coming mail recording. 2.Tender Data Base input of: − interested Lloyd’s Correspondents/ Lloyd’s Brokers/ Underwriters; − call for bids; − bid invitation. 3.Completeness and accuracy check of the Tender Data Base through a systematic audit activity (quarterly random sampling). Market Support Executive 3.2. 1. 4.Automatic access granting to Lloyd’s Correspondents/ Lloyd’s Brokers/ Underwriters who are interested in the tender. Data Base access is properly profiled. Tender Data Base In-mail DB D C 2. Application to participate and offer submission / 1 Tender DB Next page 1.  Public Tenders

123  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 2. Application to participate and offer submission / 2 Lloyd’s Correspondent/ Lloyd’s Brokers/ Underwriters Standard Offer Form. Previous page 6.Completeness and accuracy Standard Offer Form analysis and check that Lloyd’s Correspondent is different from the Public Body Broker (form sign-off as evidence of the check performed). Market Support Manager E 5.In-coming mail recording. Market Support Executive In-mail DB Next page 3.2. 1.  Public Tenders

124  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 2. Application to participate and offer submission / 3 Previous page 8.Formal Offer sign-off after having verified its accuracy and having performed the cross check against the Standard Offer Form filled by the sender. General Representative or his delegated 9.Formal Offer dispatch as required in the call for bid. 10.Tender Data Base updating and out- going mail recording Market Support Executive Tender Data Base Out-mail DB 3. F 2. 1. 7.Formal Offer preparation transposing the Standard Offer Form. Market Support Executive  Public Tenders

125  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 3. Awarding of contract, subsequent obligations / 1 Public body Contract award notification. Market Support Executive 1.Lloyd’s Broker notification forward. 2.Out and in-coming mail recording. 3.Preparation of the additional information requested. Market Support Executive In-mail DB Out-mail DB 3.2. 1. 2.2. Lloyd’s Broker Additional information required by the Public Body forwarding to LIO Market Support Manager 4.Additional information request accuracy and completeness analysis and sign-off. Next page G 5. Document dispatch and out-going mail recording. Market Support Executive Out-mail DB  Public Tenders

126  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 3. Awarding of contract, subsequent obligations / 2 Previous page Public body Contract draft, if required. 6.Contract cross check against tender Offer and contract signature. General Representative or his delegated* *In most cases, the General Representative gives specific power of attorney to lawyers for signing on his behalf the contracts. Next page H Lloyd’s Correspondent Contract draft. Lloyd’s Broker Contract draft, if required. Underwriter Contract draft analysis and approval Lloyd’s Correspondent Contract approval. Lloyd’s Broker Contract approval. 3.2. 1.  Public Tenders

127  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 3. Awarding of contract, subsequent obligations / 3 Previous page Lloyd’s Correspondent Cover Note and draft policy. Market Support Executive 7.Cover Note and draft policy receipt. In-mail DB Market Support Manager 8.Policy and Cover Note cross check against the contract previously signed and, if useful, against the Formal Offer and sign-off. 9.Draft policy sign-off after having verified the existence of the Local Services Manager sign-off and performing sample check. General Representative or his delegated Next page I L 3.2. 1.  Public Tenders

128  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 3. Awarding of contract, subsequent obligations / 4 Previous page Market Support Executive 10.Policy (three copies) dispatch to Public Body, through competent Lloyd’s Correspondent, for signature. 11.Out-going mail recording. In-mail DB Public body Policy signature. Market Support Executive 12.Signed bid record and filing. In-mail DB 3.2. 1. Lloyd’s Correspondent Policy dispatch.  Public Tenders

129  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List ReferenceControl activityOwnerTiming Market Support Manager checks the accuracy of the formal application signing it as evidence of the check performed. Market Support Manager Ad hoc General Representative, or others granted the power of attorney, analyses for accuracy the application before signing it. General Representative or others granted the power of attorney Ad hoc Market Support Executive checks for completeness and accuracy the information contained in the Tender Data Base through a systematic and documented audit activity (random sampling). Market Support Executive Quarterly Tender Data Base grants automatic and properly profiled access to those Lloyd’s Correspondents/ Lloyd’s Brokers/ Underwriters who had shown interest in participating in the bid. Tender Data BaseContinuous Market Support Manager verifies the completeness and accuracy of the Standard Offer Form and checks that Lloyd’s Correspondent is different from the Public Body Broker signing the form as evidence of the check performed. Market Support Manager Ad hoc General Representative, or others granted the power of attorney, signs the Formal Offer after having verified its accuracy and having performed the cross check against the Standard Offer Form filled by the sender. General Representative or others granted the power of attorney Ad hoc A B C D F E  Public Tenders

130  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List ReferenceControl activityOwnerTiming Market Support Manager analyses the accuracy and completeness of the additional information to be provided to the Public Body and signs them off as check evidence. Market Support Manager Ad hoc General Representative, or others granted the power of attorney, cross checks the contract against tender Offer before signing it. General Representative or others granted the power of attorney Ad hoc Market Support Manager cross checks the draft policy and Cover Note received against the contract previously signed and, if necessary, against the tender Offer and signs it off as check evidence. Market Support Manager Ad hoc General Representative, or others granted the power of attorney, signs off the draft policy after having verified the existence of the Market Support Manager sign-off and. General Representative or others granted the power of attorney Ad hoc G H I L As a general rule, any documentation addressed to Public Body needs to be double checked and signed before dispatching by either the General Representative or others granted the power of attorney. Only the General Representative or others granted the power of attorney and the Market Support Manager are allowed to contact – always in writing – the Public Body or his Broker for obtaining further detail on the bid. Any information obtained in such a manner has to be timely circulated to all Lloyd’s Correspondents/ Lloyd’s Brokers/ Underwriters interested in the bid.  Public Tenders

131 Policies Checking and Signing

132  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Scope The aim of this Procedure is identifying roles, responsibilities and activities related to LIO Policies Checking and Signing. It regulates Open Market insurance contracts only For public tenders contract signing please refer to the dedicated procedure. Roles The Process involves: General Representative; Market Support Manager; PA to GR  Policies Checking and Signing

133  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 3. Cross check negative result Market Support Manager 2.Cross checks the policy against the Cover Note and other documentation provided signing it as check evidence. PA to GR 1.Records in-coming mail. General Representative or his delegated 1.Signs the policy after the Market Support Manager sign-off. 2. Cross check positive result 1. Policies receipt and analysis 1.Sends the Lloyd’s Correspondents an e-mail listing the mistakes encountered in the cross check performed and requiring them to accept correcting. 2.Records in-coming mail (formal corrections acceptance). 3.Updates the Correspondents Data Base with the formal corrections acceptance received. 4.Records in-coming mail (formal corrections acceptance and corrected daft policy page). 5.Cross checks the corrected draft policy against the mail requesting the corrections to be performed. 6.Updates the Correspondents Data Base. 2.Updates the Correspondents Data Base with the policy signed. 3.Dispatches the policy signed to the Lloyd’s Correspondents for their signature and records the out-going mail. 4.Records in-coming mail (signed policy). 5.Updates the Correspondents Data Base with the signed policy.  Policies Checking and Signing

134  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Lloyd’s Correspondent Cover Note, draft policy and other back up documentation (three copies). 1. Policies receipt and analysis 1.In-coming mail recording. PA to GR In mail DB 2.Draft policy cross check against the Cover Note and other documentation provided and sign- off as evidence of the check performed. Market Support Manager Cross check positive result Yes No 2. 3. A  Policies Checking and Signing

135  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 2. Cross check positive result 2.Correspondents Data Base updating. 3.Policy dispatch to Lloyd’s Correspondent and out-going mail recording. PA to GR In mail DB Correspondents DB Lloyd’s Correspondent Policy signing. 4.In-coming mail recording. 5.Correspondents Data Base updating. Receptionist In mail DB Correspondents DB ! 1.Policy signature after the Market Support Manager sign-off*. General Representative or his delegated ! *The signature might be performed using the “General Representative signature stamp”, tool created with the specific purpose of helping the General Representative in performing the policies signing tasks. 1. 3.  Policies Checking and Signing

136  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 3. Cross check negative result / 1 1.Lloyd’s Correspondent e- mail sending listing: − mistakes; − corrections; − request of formal acceptance of the above mentioned corrections. Market Support Manager Out mail DB Correspondents DB Formal and irrelevant mistakes Yes No Lloyd’s Correspondent Corrections formal acceptance. 2.In-coming mail recording. 3.Correspondents Data Base updating. Market Support Manager In mail DB Correspondents DB 2. Next page B 1.  Policies Checking and Signing

137  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 3. Cross check negative result / 2 Lloyd’s Correspondent Receive back policy from Market Support Manager; correct it and sends to LIO for signature 4.Check new policy against original email listing errors and sign-off. 5.Correspondents Data Base updating. Market Support Manager In mail DB Correspondents DB Previous page C 2.  Policies Checking and Signing

138  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List ReferenceControl activityOwnerTiming Market Support Manager cross checks the draft policy against the Cover Note and other documentation received by the Lloyd’s Correspondents and Lloyd’s Broker and signs as evidence of the check performed. Market Support Manager Ad hoc Market Support Manager updates the Correspondents Data Base at corrections acceptance receipt previously to the General Representative signing the policy. Market Support Manager Ad hoc Market Support Manager cross checks the corrected draft policy page against the mail requesting the correction/s and signs it off as evidence of the check performed. Market Support Manager Ad hoc A B C As a general rule, any documentation addressed to Public Administration needs to be double checked and signed before dispatching by either the General Representative or others granted the power of attorney.  Policies Checking and Signing

139 Contracts Cancellation Management

140  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Scope The aim of this Procedure is identifying roles, responsibilities and activities related to LIO Contracts Cancellation Management. This Procedure regulates the cancellation of any contract, even undersigned out of a public tender. Roles The Process involves: General Representative; Market Support Executive; PA to GR.  Contracts Cancellation Management

141  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Market Support Executive 2.Identifies the Lloyd’s Broker/Correspondent competent for the contract to be cancelled and requires further information, if needed and if applicable: − policy number; − cancellation reason; − copy of the contract article referring to the contract cancellation. 5.Analyses the information received by Lloyd’s Brokers/ Correspondents and prepares the cancellation. 6.In case the cancellation is not applicable (for time or other constraints) prepares an explanatory note to be sent to those having requested the cancellation. PA to GR 1.Receives and records in-coming mail (cancellation request). 3.Records out-going mail (request for information). 4.Receives and records in-coming mail (information receipt). 8.Dispatches the cancellation/explanatory note signed to the Lloyd’s Broker / Insured Party. 9.Records the out-going mail (cancellation/ explanatory note). General Representative or his delegated 1. Insurance contract cancellation 7.Analyses and signs the cancellation/ explanatory note after having cross checked it against the cancellation request and other information available.  Contracts Cancellation Management

142  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Insured party/Underwriter Contract cancellation. 1. Insurance contract cancellation / 1 1.In-coming mail receipt and recording. PA to GR In mail DB 2.Identification of the competent Lloyd’s Broker/ Correspondent and, if necessary and to the extent applicable, information request: − policy number; − reason of cancellation; − copy of the contract article referring to the contract cancellation. Market Support Executive 3.Out-going mail recording. Pa to GR Out mail DB Lloyd’s Broker/Correspondent Information requested. Next page  Contracts Cancellation Management

143  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 1. Insurance contract cancellation / 2 4.In-coming mail receipt and recording. PA to GR In mail DB 5.Information analysis and, if possible considering time constraints, cancellation preparation. 6.In case time constraints are too short for allowing the cancellation, preparation of the explanatory note. Market Support Executive 7.Cancellation/ explanatory note signing after cross checking it against the cancellation request and the additional information. General Representative or his delegated Previous page 8.Cancellation/ explanatory note dispatch to the competent Lloyd’s Broker/ Insured Party. 9.Out-going mail recording. PA to GR Out mail DB A  Contracts Cancellation Management

144  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List ReferenceControl activityOwnerTiming General Representative, or others granted the power of attorney, signs the cancellation/explanatory note after having cross checked it against the cancellation request and the additional information. General Representative or others granted the power of attorney Ad hoc A As a general rule, any documentation addressed to Public Administration needs to be double checked and signed before dispatching by either the General Representative or others granted the power of attorney.  Contracts Cancellation Management

146 Operations Support

147  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Scope The aim of this Procedure is identifying roles, responsibilities and activities related to LIO Back Up and Recovery Management. The Procedure regulates: Need and Buying of assets; Choose the Suppliers; Assignment, inventory and maintenance; Access and Using of Data Bases; Roles The Process involves: General Representative; General Manager; Operations Support Manager; Financial Control; Users.  Operations Support

148  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 7.Files offer and order documentation 8.Cross checks the invoice against the delivery note. 9.Prepares the payment or Credit Note. 11.Records the invoice. 13.Submits the documentation to the Corporation for accounting purposes. 1. Need and Buying 2. Suppliers not in the Golden List General Manager User Operations Support Financial Control 1.Explains the need to Operations Support Manager writing an e-mail. 2.Evaluates the request and decides to buy. 3.In case of request reject, writes User an e-mail. 4.Researches the best offer from the habitual suppliers (Golden List). 5.Submits the total cost for General Manager's approval. 6.Performs the order. 8. Cross checks the order against the delivery note. 10. Draws up the Inventory General Representative 12. Authorizes (sign-off) the payment. 5. Authorizes (sign-off) the order to supplier. 1.Collects information about a new supplier (e.g.: prices, time of delivery, technical assistance). In case of supplier tied to a Public Body, explains the need of introducing the supplier in the Golden List and creates a dossier for General Manager analysis. 4.Updates the Golden List of Suppliers. 5.Files the Golden List to be at users' disposal. 2.Verifies new supplier credentials and the necessity of having a supplier tied to a Public Body. 3. Authorizes a new business relationship. 3. Assignment, inventory and maintenance. 1.Requests a new computer or software (or maintenance) to the Operations Support Manager by e-mail. If it’s not possible, his Manager writes e-mail on his behalf. 6.Signs and provides the Operations Support manager with the maintenance voucer. 2.Evaluates hardware/software to be installed at the user’s work station. 3.Assigns hardware/software to the user. 4.Evaluates asset disposal possibility. 5.Evaluates the trouble and decides to help or calling the outsourcing maintenance. 8.Files the maintenance documentation. 10.Performs the asset stock taking of both hardware and software. 7.Authorizes assets disposal.  Operations Support

149  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 4. Access and Using of Data Bases General Manager User Operations Support Manager 1.Asks for the assignment of User Profile. 2.Defines users profiles and permissions, accordingly with the job description. 4. e 6. Assign the User Profile. 3.Authorizes the permission of the new user profile or main users. Divisional Manager 5.Asks Operations Support Manager to create a DB or a folder in the LAN network and to define the permissions for other users.  Operations Support

150  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 1. NO Operations Support Manager 2. Request evaluation. YES 1. Need and Buying / 1 Users 1. E-mail request. 3. E-mail to Users. 4. Best offer research in Golden List Suppliers. 5. Offer submission and General Manager order approval. 6. Order. General Manager Habitual Supplier If the Supplier is not in the Golden List, please see paragraph 2. 7. Storage of offers and order documentation. Financial Control 5.4.3.2. A B Next page  Operations Support

151  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Financial Control NO OS Managers YES 1. Need and Buying / 2 8. Check and sign the accordance within goods, delivery note and invoice. 9. Reject goods or request of Debit / Credit Note. Product, delivery note and invoice. General Representative Habitual Supplier Financial Control 12. Authorization for payment. 11. Storage of documentations and payment. OS Manager 10. Inventory. Lloyd’s London 13. Accounting on Balance Sheet. 5.4.3.2. 1. C D E F Previous page  Operations Support

152  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Operations Support Managers 1. During the research of best offers, he finds a supplier not in the Golden List. He has to collect more information than possible about the new supplier. (Prices, time of delivery, technical assistance, and so on. If this supplier is tied with a Public Administration, OS Manager has to explain the relationship and the reason of the necessity of having this supplier in the Golden List. He has to create a dossier and bring it to the General Manager. 2. Choosing a Supplier General Manager 2. He has to verify the credential of the new supplier. If present, verify the necessity to have a supplier tied with a PA. General Representative 3. He has to authorize the new business relationship. 4. He write down the supplier in the Golden List. 5. The Golden List is filed to be at users' disposal. Financial Control 5.4.3.2. 1. G  Operations Support

153  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 10. Inventory of Hardware & Software vs Users. OS Manager 3. Assignment, inventory and maintenance 2. Decisions about what type of hardware & software. 3. Assignment to the Users. 4. Alienation of Asset. 1. Request to Operations Support Manager. New User or PC Damaged 5. Request to the Outsourcers for maintenance. Outsourcer Intervention. User 6. Delivery and/or install of PC. OS Manager 8. Storage of documentations about the maintenance. 7. Authorize Alienation of Asset. Lloyd’s London 9. Accounting on Balance Sheet. 5.4.3.2. 1. D H F General Manager  Operations Support

154  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 4. Access and Using of Data Base IASSICUR MULAN DB Correspondents DB Claims DB Complaints MOCHA LAN network E-Mail Server All of these have the access for personnel only by default OS Manager User 1. Request to have a log in. 2. Define the User Profile. General Manager 3. Authorization. OS Manager 4. Assign the User Profile and Permissions. OS Manager Divisional Manager 5. Request to create a DB or a folder in the LAN Network. Define the permission for the other users. 6. Assign the User Profile. User Profile Full Control or only for: Read Write Delete 5.4.3.2. 1. I  Operations Support

155  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List ReferenceControl activityOwnerTiming Verifies the existence of the supplier in the Golden List and perform the order. General Manager & Financial Control Ad hoc Files both offers and order documentation for decision making purposes. Financial ControlAd hoc Verifies accordance between goods, delivery note and invoice. Financial Control & Operations Support Manager Ad hoc Takes inventory of Hardware and Software assets. Operations Support Manager Ad hoc and Records the operation and cross checks it against Inventory.ITGAd hoc A B C D F  Operations Support

156  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List ReferenceControl activityOwnerTiming Verifies the credentials of the supplier and possible ties with Public Bodies. General ManagerAd hoc The user profile has to be consistent with job description.General ManagerAd hoc I G  Operations Support

157 Mocha Management

158  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Scope The aim of this Procedure is identifying roles, responsibilities and activities related to LIO Mocha Management. The Procedure regulates the creation of a new Binder in Mocha. Responsibilities The Process involves the Operations Support Manager.  Mocha Management

159  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List New Binder Operations Support Manager 1.Receives a request to open a new Binder from a Coverholder with enclosed the text of the binder, the rules and the examples of insurance policy. Informs the General Representative to obtain the authorization in case of a new Coverholder applying to Mocha Sends the Coverholder the agreement and waits for the sign-off. 2.Files the documentation as evidence of the beginning of the job. 3.Creates the new Binder in Mocha using the texts, rules and examples received from the Coverholder. Together with Coverholders, tests the new Binder in the application. 4.Files the test done as test result evidence. 5.When receiving the User List from the Coverholder, Requests to ITG authorization to create a new user group and then confirms the password for the User List. 6.Creates the Underwriting Sheet Approval Form and requests Underwriters the Coverholder approval. 7.At the form signed receipt, completes the procedure with the information received from the BAR System. 8.Files all documentation about the new Binder. 9.Files the new Binder in Mocha for users profile.  Mocha Management

160  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 1. New Binder / 1 OS Manager 1.Underwriting Sheet and the User Agreement creation. OS Manager 2.Underwriting Sheet and the User Agreement filing. OS Manager 3.Binder in Application Mocha creation. General Representative New Coverholder authorization. A B OS Manager 4.Underwriting Sheet and the User Agreement filing. Coverholder New Binder request: copy of Binder, rules, text and examples of insurance policy. Coverholder Performance testing. Coverholder User Agreement signature.  Mocha Management

161  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 1. New Binder / 2 OS Manager 6.Underwriting Sheet Approval Form creation. OS Manager 7.Underwriting Sheet completion inputting from BAR System. 8. Underwriting Sheet Approval Form filing. OS Manager 9.Binder Activation in Mocha OS Manager 5.IT Group request for new user group creation. D Coverholder List the Authorized Users (Password) Coverholder Approval request by Underwriters. Underwriting Sheet Approval Form signed. IT Group C  Mocha Management

162  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List ReferenceControl activityOwnerTiming Authorizes the new Coverholder applying to use the system.General RepresentativeAd hoc Files the documentation for starting the operations. Operations Support Manager Ad hoc Authorizes the user list.IT GroupAd hoc Files the documentation after having completed the operation. Operations Support Manager Ad hoc A B C D  Mocha Management

163  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Roles Matrix Legend Regulatory & Compliance Financial Control Market Support Operations Support Office Management & HR Brand & Information Management

164 Protection of Lloyd’s Brand

165  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Scope The aim of this Procedure is identifying roles, responsibilities and activities related to LIO for the Protection of Lloyd’s Brand. The Procedure regulates the instructions for use and the precautionary measure to protect the Lloyd’s Brand. Responsibilities The Process involves: General Representative; General Manager; Employees.  Protection of Lloyd’s Brand

166  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Brand General Representative 3. Authorizes the use through a written letter of commitment to the third party regarding what in use, the expiration date and the limitation. Following Protection Presentations & Official Communications 1 & 2. In case of wrong use of Lloyd’s name communication, creates a dossier: users, way of use, risks and consequences and evaluates, together with the General Representative, the possible future actions to take. General Manager 1.Evaluates third parties request of using Lloyd’s name: evaluates the reasons and the respectability 2.Evaluates the image and reputation risk and consequences. 4 & 5. Gives third parties the Official Policy, logo and Crest and the commitment letter. Receives a signed copy of the letter. 6. Files all documentation to prove the analysis and the commitment. 7. Verifies the correct use and the respect of the commitment. 3. & 4. Evaluates the correct use of the Style Guide, the contents and the communications addressees (only the General Representative or General Manager can issue to Third Part). 5. Authorizes communication circulation. Employees 3.Receives the dossier and evaluates the following actions: no response (low or without risk), a friendly written letter or mandate to attorneys. 1. & 2. Creates a presentation or an official communication (for internal use or for Group) using the standard template of Lloyd’s Group. 6. & 7. Issues the communication and files the document, the addressees and the General Manager authorization.  Protection of Lloyd’s Brand

167  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 1. Trade Mark 1. General Manager 1.Information about the Third Part and the reason research. 2.Request and the risks (image and reputation) evaluation. Third Part Request to use the Lloyd’s Name 1.Nobody can use Lloyd’s name and brand without authorization by Lloyd’s Italian Office 2.Only the General Representative can authorize the use of Lloyd’s name to Third Parties. 3.See also the procedure issued by Lloyd’s Official Policy as style guide. General Representative General Manager 4.Submission to third party of letter and Official Policy. 5.Submission to third party of logo and crest. 6.Documentation filing (including signed letter). 7.Checks for future correct use of Lloyd’s Nome (back up documentation filing for evidence). 2.3. 3.Usage authorization through a written letter explaining the terms: - Period - Use - Limit A B  Protection of Lloyd’s Brand

168  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List General Manager 1.Communication receipt about improper use of brand. 2.Dossier creation about the user, the way of use and the possible consequences/ risks. Third Part Unauthorized use of name, logo or crest of Lloyd’s Group. General Representative 3.Dossier receipt and evaluation with the General Manager about the possible actions to undertake. 2. Following Protection What type of respons e? Friendly written Communication Appointment to defend Lloyd’s Brand Legal Adviser 1.2.3. C None  Protection of Lloyd’s Brand

169  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Employee 1.Creation of presentation or official communication. 2.Usage of standard template of Lloyd’s Group. General Manager 3.Evaluation of the correct use of the Style Guide. 4. Evaluation of the list of the addressees. 5.Authorization of spreading. 3. Presentations & Official Communications 1.2.3. Employee 6.Communication issuance. 7. Document filing ( including addressees and authorization). D  Protection of Lloyd’s Brand

170  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List ReferenceControl activityOwnerTiming Verifies uses and risks. Authorizes with a written letter. General RepresentativeAd hoc Deliveries the policy for using and the letter. Verifies the effective use and files the documentation. General ManagerAd hoc Verifies the uses and the risks. Decides the action to undertake. General RepresentativeAd hoc Evaluates the contents, the style and the addressees. Authorizes employees to use. General ManagerAd hoc A B C D  Protection of Lloyd’s Brand

Information Management

172  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Scope The aim of this Procedure is identifying roles, responsibilities and activities related to LIO relations with press agencies, journalists, trading associations, public bodies, local authorities. The Procedure regulates: official relations to Public Authority as Supervisory Body (for public tenders, please refer to the dedicated procedure); press attaché and press releases; code of practice in case of public authorities’ inspections. Responsibilities The Process involves: General Representative; General Manager; Office Manager Divisional Managers; PA to GR  Information Management

173  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 1. Official reports to public authority 2. Press attaché and press release General Manager &/or Office Manager PA to GR Divisional Managers General Representative 3. Code of practice during an inspections by Authority 1.Records in-coming mail. 6.Records out-going mail. 2.Evaluates Public Administrations request and asks the Divisional Managers for information in order to answer. 4.Prepares the written answer and signs in full to validate the letter. 3.Prepare the information about their divisions. 5.Sign the answer letter so to prove the segregation of duty. Is informed by General Manager of any Public Authority request. Receives a copy of any letter to Public Authority. 1.Submits any pressmen or press agency request to the General Manager, who is the only one that may have relationships with the Press (together with the General representative). 2.Contacts Pressman and verifies the opportunity of issuing a statement or an interview and informs the General Representative. 4.Takes part to the interview. 5.Gives a feed back to General Representative about the contents of the article. 6.Evaluates the possibility to issue a press release and prepares the text. 8.Contacts a press agency to issue the release. 3.Authorizes the interview and receives feed back from the General Manager. 7.Authorizes the text of the issue. 1.Records in-coming mail. 2.Contacts Inspectors and receives any request from them 3.Receives the requests list from Inspectors and assigns the tasks to Divisional Managers accordingly to the object. 5.Collects the answers and cross checks it against the Inspectors request. 7.Deliveries the documentation and requires the check list signature. 4.Prepare all documentation needed for answering and sign the check list as segregation of duty evidence. 6.Authorizes any delivery to Public Authorities.  Information Management

174  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Receptionist 1. Official reports to Public Authority Public Authority Official Request. General Manager 2.Question analysis and submission to other Divisions and General Representative information. 1)Every written request by a Public Authority has to be considered as an official request. 2)To a written request, LIO has to replay with a written answer; to an unofficial question, LIO answers in a unofficial way (e.g.: by telephone). 3)For requests arisen during a public tender, please refer to the dedicated procedure. 1.In-coming mail recording. Divisional Managers 3.Data and information for the answer preparation. General Manager 4.Written answer preparation and signature (Copy to General Representative). Divisional Managers 5.Sign-off as data input proof. PA to GR 6.Out-going mail recording. Public authority Official Request. A B C A 3.2. 1.  Information Management

175  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List PA to GR or Anyone in LIO 2. Press attaché and press release / 1 Pressman Request for information or appointment. Office Manager 2.Pressman contact: description of contents. Only the General Manager, Office Manager or General Representative are allowed to have relationships with Press or issue a press release. 1.Communicate to Office Manager General Representative 3.Interview authorization. D 4.Taking part in the Interview. 5.Feed Back to General Representative. Office Manager 3.2. 1. If the request is for having an interview with General Representative, he informs General Manager about the contents and possible answers to give.  Information Management

176  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 2. Press attaché and press release / 2 Office Manager 6.Evaluation of issuing a press release and preparation of a text for example. Only the General Manager, Office Manager or General Representative are allowed to have relationships with Press or issue a press release. General Representative 7.Authorization of the text. D 8.Contact press agencies for issuing the release. Office Manager 3.2. 1.  Information Management

177  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Receptionist 3. Code of practice during inspections by Authority / 1 Public Authority Communication of beginning inspection General Manager 2.Inspectors contact. Only the General Manager or General Representative can have relationships with Inspector of Public Authority. 1.In-mail recording and General Manager information. List of requests Public Authority General Manager 3.Divisional Managers support (check list). Physic Presence in LIO Office 3.2. 1. A E B  Information Management Next page

178  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List General Manager 3. Code of practice during inspections by Authority / 2 Divisional Manager 4.Documentations about own task and check list signature. Only the General Manager or General Representative can have relationships with Inspector of Public Authority 5. Collect the answers and verify the correspondence with the request. 7.Check list and delivery the documents preparation. 7.Answers Check List signature. Public Authority General Representative 6. Delivery authorization. B F F 3.2. 1.  Information Management Previous page

179  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List ReferenceControl activityOwnerTiming In-coming and out-going mail has to be recorded.ReceptionistAd hoc Evaluates the request and informs the General Representative. For the Segregation of Duty, he asks to Divisional Manager for the information to delivery, preparing a check list. General ManagerAd hoc Sign in short the letter to Public Authority to prove the segregation of duty. Divisional ManagersAd hoc Any communication to third parties has to be approved by General Representative. General RepresentativeAd hoc Any request by Public Authority has to be in writing.General ManagerAd hoc Prepares a check list of documentation delivered to Inspectors and ask for a signature for delivery evidence. General ManagerAd hoc A B C D E F  Information Management

181 Privacy and Safety

182  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Scope The aim of this Procedure is identifying roles, responsibilities and activities related to LIO Privacy and Security Management. The Procedure regulates: Safety of employees; Security of information. Responsibilities The Process involves: General Representative; Office Manager Divisional Managers; Operations Support Manager (who maintains contact with ITG) Employees.  Privacy and Safety

183  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Safety General Representative 3.Authorizes in writing the use of commitment for the third part, about what in use, the period of expire and the limit (approach to not kind arguments) Privacy 1.For each Division asks ITG to create permissions to access LAN network and folders for the employees. Office Manager 1.Receives a communication from third party or Employees and evaluate the related risk. 2.Communicates to General Representative the problem and the possibilities to resolve it. 4.Decides intervention with or without outsourcers. 5.Files the documentation to prove the intervention and the resolution. Employees 4.Verify restricted access to the Divisional Data Base. 7.Verify the correct preservation of documents and authorized access. Operations Support Manager Divisional Managers 5.Create dossiers, binders and archives to support jobs and operations. 6.Files all documents in locked filling cabinet compliantly with Privacy Law.  Privacy and Safety

184  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 1. Safety 1. Office Manager 1.Evaluation of the communication and the related risks. 2.General Representative communication about how he intends to solve the problem. Communication to Office Manager about a bad working or a “sensation” of dangerous situations. General Representative 2. 3.Communication receipt and course of events analyses. Intervention and report to Office Manager. Outsourcer Office Manager 4.Intervention request to outsourcer or decision to do without. 5.Files the documentation of the event. A  Privacy and Safety

185  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 2. Privacy 1.2. Divisional Managers 4. Verify that the access to the Divisional Data Base is for authorized only. Operations Support Manager 1.Permissions to access to LAN network creation (to ITG). B Electronic Format Resources Paper Format Resources Employees 5.Dossiers, binders, archives for job supporting creation. 6. Filing all documents in reserved locked filling or drawers. Divisional Managers 7. Verify that the information are preserved and for authorized only. C The responsibility of managing, preserving and accessing electronic resources belongs to Operations Support Manager. The responsibility of managing, preserving and accessing paper resources belongs to each Divisional Manager.  Privacy and Safety

186  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List ReferenceControl activityOwnerTiming Files all documents to prove the communication/request and the intervention. General RepresentativeAd hoc Verify the restricted access to Divisional Data Base.Divisional ManagersAd hoc Verify correct preservation of documents.Divisional ManagersAd hoc A B C  Privacy and Safety

187 Human Resources Training & Management

188  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Scope The aim of this Procedure is identifying roles, responsibilities and activities related to LIO Human Resourcer Management. The Procedure regulates: Recruiting; Performance; Resignation; Disciplinary Sanctions; Statutory Training; Development Training. Roles The Process involves: General Representative; General Manager; Financial Control; Divisional Manager; Employee.  Human Resources Training & Management

189  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 1. Recruiting 2. Performance Financial Control Employees General Representative 3. Resignation 1.At the beginning of the new fiscal year, meets her/his Divisional Manager to discuss her/his performance and objectives. 5.At the end of the fiscal year, meets his Divisional Manager to discuss the targets reached or missed. 1.Requests a new employee for the Division and creates a Business Case. 2.Prepares the job description and the profile researched. 3.Sends the Business Case (job description) to the General Representative. 8.Together with Office Manager, meet and evaluate the candidates (previously selected by an Employment Agency) and choose the adequate one. 6.Contacts an Employment Agency. 7.Receives Direct or Self Presentations (Resumes) and forwards them to the Employment Agency. 8.Together with General Manager and Divisional Manager, meets and evaluates the candidates (previously selected by the Employment Agency) and chooses the adequate one. 9.Introduces the Candidate and provides General Representative with details General Representative wage level. 10.Communicates to Outsourcer the name of the new employee. 11.Creates an Employee’s Dossier. 4.Evaluates Business Case. 5.Sends Business Case to the Office Manager. 9.Meets the Candidate in the final interview and offers him/her a position (hire letter congaing wage level and job description). 2.Cross checks the Individual Plan against Lloyd’s performance& objective guidance. 4.Records the Individual Plan in the employee’s Dossier. 6.Asks the General Representative a confirmation about bonus or wage increase assignment. 8.Communicates the new levels of salary and bonus to Outsourcer. 9.Files the back up documentation in the Employees’ Dossier. 3.Accepts the Beginning Individual Plans and decides whether assigning bonus or wage increase. 7.Receives from Lloyd’s London the bonus amount to be distributed and decides about bonus/wage increase assignment. 1.Writes a resignation letter and provides it to the General Manager. 2.Discusses the reason of the resignation. 3.Evaluates the counteroffer possibility in order to encourage the resignation withdrawal. 4.Confirms the acceptance of the resignation letter. 1.At the beginning of the new fiscal year, meets employees to discuss her/his performance and objectives. 5.At the end of the fiscal year, meets employees to discuss the targets reached. 2.Discusses the resignation reason. 5.Communicates the resignation details to the Outsourcer. General Manager and/or Divisional Manager  Human Resources Training & Management

190  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 5. Statutory Training 6. Development Training General Manager and Financial Control Employees General Representative 2.Attends the course. 4.Verifies whether the communication is correct and provides authorization 1.Interviews and selects the employees interested in attending to statutory trainings. 3.Communicates the Public Authority the name of employees attending the course. 1.Receives the Skill Gap Analysis. 6.Attends a course. 7.Presents a Feed Back to the General Manager. 5.Authorizes the course. 9.Verifies the Feed Back. 10.Authorizes the Payment. 2.Evaluates the relevance of the course vs the Skill Gap Analysis. 3.Lists the names of participants (only employees can take part of). 4.Requests a detailed estimate to the Outsourcer. 5.Authorizes the course. 9.Verifies the Feed Back. 10.Authorizes the Payment. Financial Control 8.Verifies the names of course attendees. 4. Disciplinary Sanctions 1.Requests LIO to take measures against an employee due to relevant and documented reasons. 2.In accordance with the General Representative, takes in consideration the legal opinion received from the Legal Advisor and evaluates the solutions. 3.Writes or receives from lawyers an official letter about the Disciplinary Sanctions. 5.Records the letter in the Employee’s Dossier. 4.Signs the official Disciplinary Sanction letter. 6.Informs the HR Outsourcer and General Manager. 7.Meets the employee and gives him/her the Disciplinary Sanction letter. 7.Receives the Official Disciplinary Sanction Letter. Divisional Manager  Human Resources Training & Management

191  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Financial Control 4. Request to an Employment Agency. 1. Recruiting General and Divisional Managers 1. Request for a new candidate. 2. Business Case and Job Description. Lloyd’s London Business Case authorization. General Representative 3. Business Case evaluation. A 6.5.4.3.2. 1.  Human Resources Training & Management Next page

192  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 1. Recruiting / 2 Employment Agency List resumes of Candidates 7.Exploratory talk with Candidates. 8.Candidate introduction to the General Representative. Office Manager, General and Divisional Managers General Representative 9. Last employment interview. Third Parties 5. Direct and Self Presentations Financial Control 10. Communications to the Outsourcer about the Administrative procedure initiation. 11. Employee’s Dossier creation. LIO 6. Resumes collection. B 6.5.4.3.2. 1. Z Lloyd’s London Employment authorizing. C A  Human Resources Training & Management Previous page

193  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 2. Performance Divisional Manager 1. Performances and Objectives discussion with Employees (Individual Plan). Beginning of the fiscal year Ending of the fiscal year Divisional Manager 5. Analysis of the targets achievement by the Employees. General Representative 7. Proposal of bonus and new wage level to the Employees 8. Communication of the Administrative procedure to the Outsourcer 9. Employee’s Dossier recording 3. Acceptance of the Individual Plan. Lloyd’s London Wages and Bonus Budget Financial Control Financial control 2. Individual Plan cross check against Lloyd’s performance & objectives guidance. Financial Control 4. Employee’s Dossier recording. General Manager 6. Employees’ target achievement cross check against beginning Individual Plan. 6.5.4.3.2. 1. Z  Human Resources Training & Management

194  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 3. Resignation Employee 1. Resignation Letter. 2. Primary discussion about the resignation reasons. 3. Communication to the Outsourcer. General Representative 4. Ultimate discussion about the resignation reasons and decision about encouraging the worker to withdraw the resignation letter or accepting it. 5. Acceptance of the resignation letter. 6. Communication of the Administrative procedure initiation to the Outsourcer. Financial Control General Manager or Office Manager D 6.5.4.3.2. 1. Z  Human Resources Training & Management

195  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 4. Disciplinary Sanctions Divisional Manager 1. Request of taking the measures against an employee. 2. Evaluation of the disciplinary sanction form i.e. official form warning, disciplinary sanction, suspension, discharge. General Representative and General Manager 3. Legal Opinion and Official Letter. Legal Adviser 7. Official Letter receipt. Employee 4. Signature of the Official Letter. General Representative General Manager 5. Employee’s Dossier recording, 6.5.4.3.2. 1. Z  Human Resources Training & Management 6.Administrative procedure initiation. Outsourcer Z

196  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List Employee 4. Statutory Training Financial Control 1. Development plan discussions External Course Certificate of attendance. 2. Acceptance of course attending. Financial Control 3. Public Authority communication. General Representative 4. Communication analysis. E 6.5.4.3.2. 1.  Human Resources Training & Management

197  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List 6. Course attendance. 7. Feedback to Office Manager 5. Development Training Employee Financial Control 2. Course relevance analysis. 3. List of participants’ names. 4. Detailed estimate to Outsourcer request. External Course List of participants and Invoice. 1. Skill Gap Analisys General Representative 5. Course authorization. Employee Financial Control 8. Participants‘ nominatives check. General Representative 9. Payment authorization. 10. Feedbacks check. Feedback to Office Manager F 6.5.4.3.2. 1.  Human Resources Training & Management

198  Process Summary  Process Flow  Table of Contents  Scope  Key Controls List ReferenceControl activityOwnerTiming Verifies the Business Case and authorizes the employment.Lloyd’s LondonAd hoc Verifies that in the CV received there are Privacy Law references, otherwise the CV has to be eliminated. Office ManagerAd hoc List of Candidates: more persons to evaluate. Memoranda of Interviews: decision tracking. Level of Salary: preferential term. Financial ControlAd hoc Verifies the reason of the resignation, understanding if there is the possibility of a proceedings against LIO. General RepresentativeAd hoc For statutory communications, there is a check for the respect of time sending and text contents. General RepresentativeAd hoc Verifies the list of the nominatives, to assure that there are only LIO employees. Financial ControlAd hoc Where there is an outsourced activity, all of them are checked twice by LIO: on the input to the Outsourcers and on the output from the Outsourcer. Financial ControlAd hoc A B C Z D E F  Human Resources Training & Management

List of policies and other supporting documentation Available on C-Net Compliance Manual Whistleblowing Policy Handling Price Sensitive Information Guide Documents retention policy Information Security policy and Standards Information Security guidelines, procedures and other useful information Computer usage Diversity and equal opportunities Anti money laudering employee policy Clear desk policy All employees must read and comply with the content of the following policies and other supporting documentation:

List of policies and other supporting documentation Available on request to the Office Manager These documents are regularly sent to the employees by email with relevant instructions BCP BIA Piano di esodo DPS posta elettronica e email Modelli organizzativi – L. 231

LIO PROCEDURES MANUAL July 2010. 2 Premise Job Descriptions Procedures.

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LIO PROCEDURES MANUAL July 2010. 2 Premise Job Descriptions Procedures.

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