Guy Carpenter is committed to providing our clients with the most professional service in the reinsurance industry. We believe transparency enables our clients to make more informed decisions regarding their reinsurance programs. We have, therefore, formulated specific policies and procedures to support full disclosure for clients with regard to treaty and facultative reinsurance transactions on a worldwide basis. This Global Disclosure Doctrine addresses all reinsurance placed by Guy Carpenter, and accounts for differences in business practices and customs that exist in various regions of the world.

In order to ensure transparency with regard to treaty reinsurance transactions, Guy Carpenter has implemented the following procedures:

• When Guy Carpenter is appointed broker of record, we will disclose to our clients the compensation that we anticipate receiving for the services to be provided on the client's behalf and provide a copy of our Global Disclosure Doctrine.
• Prior to subsequent renewals of reinsurance contracts, Guy Carpenter will review with our clients our expected compensation based on standard rates of brokerage.
• We will continue to strive for consistency in rates of brokerage to be earned by Guy Carpenter within a layer and will disclose any variation in rates to all parties within that layer.
• Consistent with prior practices, a summary of all formal and final quotes and declinations received from markets will be sent to clients before binding.
• Brokerage for each reinsurance transaction will be listed on the Cover Note (or equivalent) for all treaty business.

Guy Carpenter's longstanding practice is to conform to rates of brokerage in accordance with industry custom and usage. Following are the rates of brokerage that apply to the majority of business placed by Guy Carpenter. These rates are guidelines and are generally standard in the marketplace, but can vary depending on the details of a particular placement.

• Guy Carpenter generally receives brokerage on pro rata placements of between 1 percent and 2.5 percent of gross premium.
• For excess of loss placements, Guy Carpenter generally receives brokerage of between 5 percent and 10 percent of contract premium.
• When excess of loss placements are made with a wholesale broker, an additional 5 percent brokerage may be earned by the wholesale broker. A Guy Carpenter affiliated broker is often used on these placements.
• In some markets, Guy Carpenter receives brokerage of up to 5 percent on reinstatement premiums.
• On some placements a stated margin is part of the premium. In such cases, Guy Carpenter generally receives 20 percent of that portion of the premium as compensation.

Facultative reinsurance business varies in complexity, structure and variety of solutions offered to our clients, further complicated by line of business and geographic region. There is, therefore, no standard brokerage rate that can be applied to all facultative placements.

In order to ensure transparency with regard to facultative reinsurance transactions, Guy Carpenter has implemented the following procedures:

• Guy Carpenter will present all new clients with a copy of our Global Disclosure Doctrine when we begin working on new facultative business.
• We will disclose to clients a range of brokerage rates applicable to facultative reinsurance transactions in the regions of the world in which we operate.
• Any upward deviation in brokerage rates (see Rates of Brokerage - Facultative Reinsurance) will be disclosed to the client.
• Guy Carpenter will continue to strive for consistency in the terms of placements and total premiums charged the client. In some regions, however, the total deductions from the gross ceded reinsurance premium may vary within a placement in order to meet a client's needs.
• Guy Carpenter will not disclose underwriting or pricing information, our brokerage or other program information to any party not directly involved in the reinsurance placement (e.g. retail brokers) without approval of our clients.
• Guy Carpenter will only work on a reinsurance placement with a retail agent, broker or other representative of an insured when that agent, broker or representative confirms that the insured has agreed to our participation. In such transactions, we will also obtain agreement to our participation in the placement from our client, the reinsurance ceding entity. We will also disclose to that client if we share any revenue generated from the reinsurance placement with the retail agent, broker or representative of the insured.

As with treaty reinsurance placements, Guy Carpenter's practice is to conform to rates of brokerage in accordance with industry custom and usage within a geographic region. Due to the fast-paced, transactional nature of facultative placements, however, and the limited lead time clients typically have to make the purchase decision, brokerage rates for a given transaction may not be determined until after the placement is complete.

Guy Carpenter supports transparency with regard to disclosure of brokerage rates and sets forth below the rates of brokerage that apply for the majority of facultative business we place:

• In all geographic regions of the world, and for all lines of business except United States Casualty Facultative business, the standard maximum rate that Guy Carpenter will earn is 15 percent of ceded reinsurance premium.
• For United States Casualty Facultative business, the standard rate Guy Carpenter will earn is a maximum 10 percent of ceded reinsurance premium.
• Should Guy Carpenter earn less than the above rates on a particular placement, we will not report it to clients. If we earn more than the above rates on a given placement, however, we will disclose to the client the actual brokerage rate to be earned.
• Any upward deviation on the brokerage rate from an individual market on a placement, in a quote or at binding, will be disclosed to the client.
• On some facultative placements, a local or wholesale broker may be used to access a particular market. An additional 5 percent to 10 percent brokerage may be earned on such transactions. A Guy Carpenter affiliated broker is often used on these placements.
• Should a particular placement entitle Guy Carpenter, as a whole, to earn more than 20 percent in total compensation, this will also be disclosed to the client.
• Should a client request specific information on our compensation on a particular placement, we will provide it.

In certain jurisdictions and countries, legal and/or regulatory requirements may stipulate additional documentation or disclosure, such as:

• the client's written acceptance of brokerage rates
• client agreement to the use of a wholesale broker
• the disclosure of all quotes
• an annual broker compensation report
• reinsurance markets with which we have contractual arrangements
• ownership position in any insurer or reinsurer

We will provide this additional information as required, or as requested by our client.

In addition to traditional reinsurance intermediary services, Guy Carpenter also provides other "non-traditional" reinsurance related services for which we receive fees. Revenue from these activities represents a small portion of Guy Carpenter's annual revenue.

Examples of these services are provided by Reinsurance Solutions International, LLC (RSI), a Guy Carpenter subsidiary that receives fees for providing unbundled services such as policy administration, claims administration, premium/reinsurance collections, statutory/GAAP accounting, regulatory compliance and auditing. In addition, RSI provides specialized consulting services focusing on process re-engineering, benchmarking and performance management metrics and measures.

In accordance with common practice and general custom and usage within the reinsurance business, Guy Carpenter retains interest earned on fiduciary funds passing through our systems. Where applicable, we will obtain written agreement to retain interest income. This has always been our practice and such interest is viewed as part of our overall compensation.

We encourage clients to raise questions regarding any aspect of their Guy Carpenter relationship with their Account Executive. Should a client, market or any other person wish to raise issues, concerns or a complaint specifically with regard to compensation paid or payable to us by reinsurers, insurers or third parties, they are encouraged to contact the MMC Insurer Compensation Line twenty four hours a day, seven days a week from any country. The matter will be logged and referred to the appropriate resources for investigation. The telephone number is +1.800.420.5082.