QUARTERLY NEWSLETTER    OCTOBER 2019

Energy and
Power Newsletter
Focus On: Analytics – Risk Finance Optimisation
Energy and Power Newsletter
 MARSH JLT SPECIALTY ENERGY    OCTOBER 2019

Energy and
Power Newsletter

We are pleased to provide our existing,

and potential clients with our 4th Energy
CONTENTS
Insurance Quarterly Newsletter of 2019.
1 General State of the Market Overview
In addition to our regular features, in this
edition we focus on Analytics: Risk Finance
Optimisation.
8 Recent Quotes

We hope that readers will find this 11 Market Moves/People In The News
newsletter interesting and informative
and would welcome any feedback
you may have, which you can email to:
12 What’s New?
John.Cooper@Marsh.com
or pass on to any of your usual 13 Briefly
Marsh JLT Specialty contacts.

If you are reading this in hard copy or have

been forwarded it electronically, and would
like to be added to our electronic mailing
list, or you wish to unsubscribe, please
email John.Cooper@Marsh.com.
15 Security Ratings Changes
16 Legal Roundup
18 Demystifying Common Clauses

John Cooper ACII

Global Chief Client Officer
Special Articles:
Marsh JLT Specialty | Energy & Power
19 Marsh JLT Specialty Training Courses

20  arsh JLT Specialty Energy Industry

M
Conference 2020

21 Atlantic Named Windstorm Forecasts

22 F ocus on: Analytics – Risk Finance

Optimisation
iv • Energy and Power Newsletter
General State of the
Market Overview
General Backdrop
The divergence of Upstream and
Downstream Energy markets that we
have reported for the past two quarters
continues. Whilst the Upstream market
continues to struggle to achieve
Upstream Energy
Upstream Energy is now the one safe
harbour class that energy clients have
across the specialty insurance spectrum.
Marine Hull & Cargo, Downstream,
Casualty, Aviation, Directors and Officers,
and Onshore Construction are all showing
extreme stress in providing capacity and
also generally imposing rate rises.
Whilst their sister classes are
demonstrating dramatically improved
economics, Upstream insurers were
typically seeking rate increases of circa
5% in early 2019. By the mid-year this
target had slid to plus 2.5%. Terms
and conditions, including pricing, may
be achievable for accounts that can
demonstrate a robust and embedded
risk management process if they have not
experienced claims.
The big news in the upcoming quarter
sees Steve Hawkins (formerly Axa XL
Upstream underwriter) start writing
business at the Steven Catlin and Paul
Brand start up Convex. Convex can deploy
USD 350 million capacity and therefore
joins QBE, AIG and Axa XL among the
larger carriers. This will be the largest ever
Downstream Energy
Traditionally the third quarter is a slower
period in terms of renewals. However,
this year activity in the sector has
continued with budgeting, customer
briefings, strategy preparations and
coverage reviews.
Offshore
meaningful increases, Downstream,
construction
Power, and Bermuda Casualty markets rates continue
are gaining more traction, driven by
withdrawals and cutbacks in capacity to increase as
deployed in those classes.
more and more
underwriters take
new entrant into the Upstream space.
a negative view of
Whilst broker and client relationships
mean this is unlikely to have a large scale
the sector.
pricing impact in the short term, the
underwriting team at Convex will place
pressure on the medium to smaller sized
carriers. This will exacerbate the pressure
on renewal rates to get to expiring terms.
There is continuing distress in the US
onshore shale sector as losses (from both
contractor equipment and blowouts) and
reduced drilling activity make the loss
ratios on the business unattractive.
Offshore construction rates continue to
increase as more and more underwriters
take a negative view of the sector.
There is definitely more activity offshore
around the world, but the reduced
values most drilling rigs now have, and
overhanging soft OEE pricings, mean that
there are not significant cost increases.
We therefore see that for the balance
of the year clients should encounter a
positive pricing environment.
Clearly customers and their brokers
have been employing wider marketing
strategies. Some of this is to counter
insurers taking advantage of increased
rates to proportionately de-risk
their portfolios and also to stabilise
placements that have previously taken
Marsh • 1
advantage of avarice insurer appetite leaving placements too narrowly exposed. A
number of insurers, as a consequence, are looking to staff up to handle the workload
generated by this broadening of opportunity and for the analytics required by more
intensive management scrutiny as they look to turn the sector back into profit.

Part of the initiative to work towards a positive outcome for insurers is the tightening
of coverage scope particularly around managing business interruption exposures and
affirmation of cyber coverages.

In respect of the business interruption exposures, a number of insurers are looking

for more disclosure and accuracy on forecasts, and the imposition where possible
of restrictions on indemnity in the event loss amounts deviate wildly from forecasts.
Whereas premium adjustment to business interruption exposures ensure the
risk exposure is rated correctly, insurers fear the quantum of the unexpected loss
exposure can cause problems to their own specific retention appetite. Whereas this
is understandable and logical, (particularly if the margins for deviation are generous
and any exposures beyond the limitation exempt from adjustment), refining spreads
can be particularly fickle and short lived and customer risk management does not like
the possibility of justifying to senior management restricted recoveries through the
imposition of caps. Justifiably, customers feel that a proven track record of accuracy in
business interruption forecasts should ensure differentiation of the customer base.

Cyber continues to be somewhat of an enigma in terms of fit in the energy space. Cost,
scope, value and capacity all pull customers in different directions. With the established
NMA2914 and NMA2915 clauses it has been broadly felt that the Downstream and
Midstream markets have successfully addressed the resultant physical damage aspect.
Whereas regulatory and authoritative bodies are pushing for affirmative coverage across
the broader energy piece, the largest area of dispute in Downstream and Midstream
has been the breadth of the peril write back. A recent and well known case involving the
application of a war exclusion has muddied the waters, and it is likely that further work
will be done to amend the established clauses to ensure clarity.

So finally, where is the market in terms of the 2019 venture? As it stands the underwriting
result to date somewhat depends on the crystallisation of a June refining loss in the USA.
Should that loss come close to current reserves then, coupled with the other established
year to date losses and prior year deterioration, it will be the near equivalent of the
Downstream markets annual global premium. Nonetheless, the loss in question has
a myriad of complications and uncertainties and the quantum is unlikely to be known
for some time. In the meantime Downstream rates remain disparate but as a rule of
thumb are running between a 20% and 30% uplift, with Midstream 10 points under that.
Capacity is relatively static but being deployed in conjunction with the prevailing bearish
sentiment. An unfortunate dynamic to the pricing matrix is the continued opportunist
behaviour by a few markets that consistently undermine pricing established between
clients and leading markets. Fortunately this is a limited contingent and can generally be
managed with a robust marketing strategy.

Cyber continues to be somewhat of

an enigma in terms of fit in the Energy
space. Cost, scope, value and capacity
all pull customers in different directions.

2 • Energy and Power Newsletter

Power increase of a 12.5%-15%. Accounts with catastrophe exposure
or those that have experienced losses are seeing higher rate
increases as well as deductible level increases.
We are seeing an adjustment and tightening across the whole
of the London Power market. There have been some recent
In Lloyds the situation is compounded with markets limited to
withdrawals of capacity as carriers realign to more profitable
income limits for the underwriting year. Hence, fourth quarter
areas of their book. Power losses invariably outpace premiums
renewals might be tricky for some as insurers get close to their
for most insurers.
annual income limits.

Good broking helps mitigate overall impact with relayering and

Generally, deductibles are not increasing, but we do expect some
restructuring programme along with vertical placements (each
fringe coverage to disappear or be limited such as extended
carrier on their own slip with their own terms).
cyber, limited terrorism, and construction within a policy.

The fourth quarter is a busy time in London and our markets will
Our recommendation is to enter preliminary discussions with
not consider reviewing this until mid-November. Underwriters
markets as soon as prudent to avoid rushed negotiations. Insurers
are working through over a hundred submissions that incept
are taking significantly more time to review schedules and are
before the year end; limited resource means it is currently
delaying quoting until very close to inception as they look to
difficult to get the required focus accounts which incept in 2020.
achieve the best outcome. This can cause a lot of frustration for
brokers and clients. Above all be prepared for a change in terms.
Straight forward renewals with a clean loss record and no
catastrophe exposure are generally experiencing an average

Sabotage & Terrorism and Political Violence

The recent drone attacks on Saudi oil facilities are likely to throw
up questions about the dividing line between War, and Sabotage
& Terrorism risks. Terrorism buybacks in ‘All Risks’ polices or
in standalone policies typically cover “the use of force … of any
person or group(s) of persons, whether acting alone or on behalf
of or in connection with any organisation(s) or government(s),
committed for political, religious, ideological or similar
purposes”, whereas the dedicated “Political Violence” (PV)
market will include the wider perils of War and Civil War risks -
typically defined as “war,…acts of foreign enemies, hostilities
(whether war be declared or not)…”.
There is likely to be increased interest in purchasing PV polices
after this event, but whilst this loss may not hit PV insurers the
perceived increase in threat is likely to see a tightening in that
market in available capacity, breadth of cover and pricing.

Marsh • 3
Energy Casualty
Generally speaking, for the first time in many years the idea of a transitioning Energy Casualty market has become more apparent,
caused by escalating losses and non-profitable underwriting. Although there haven’t been any market-turning energy liability losses
in the past few years, there have been some meaningful claims and incidents arising from the energy and non-energy sector that
have the attention of insurers. Underwriter caution has been accentuated by the ever inflating costs of remediation and cleanup in
various jurisdictions. Over the last five years the market has shown, on average, a steady decline in rate to the point that is deemed
unsustainable. This has led to stringent reviews of insurers books and extensive approval processes from Lloyd’s in respect to
syndicates business plan approvals.

The end result of the events of the past 12-18 months is that, essentially, reductions are very hard to come by. Increasingly, insurers are
looking to charge rises commensurate with exposure increases. While significant rate rises are only being applied to poorly performing
accounts, or else to specific niche classes (US Wildfire, Canadian midstream), there is meaningful pressure to increase rates across
all Energy Casualty risks, and this is particularly true in Bermuda where the majority of markets are looking to cut back their capacity
deployed. More time, more imagination and more sourcing of available capacity (when available) are becoming necessary courses of
action, when before renewals on the current basis with expiring markets were more prevalent.

4 • Energy and Power Newsletter

International Downstream/
Power/Mining
The continuing good liability loss
experience in the refining and petro-
chemical sectors means we do not expect
significant rises in this sector (unless
the market views an account’s current
rates as inadequate). Some markets have
exited the space; however there is a good
capacity level available for most risks.
The challenging loss experience in the
downstream property sector has had the
effect of reminding liability underwriters
how close they could have come to market
turning losses, and also meant that their
company’s overall loss record may have
been negatively impacted even though
the liability class results may be fairly
healthy; this could result in pressure from
management to deliver increased rate
performance. Continued events in the
power and mining sectors involving dams,
both engineered conventional and tailings
dams, means this is a hot topic requiring
significant information and review.
International Upstream
A positive few years in this class has
continued in 2019 and there have been
almost zero meaningful losses to talk about.
Unlike the downstream sector, however, the
property part of this class has also run very
well, so there is far less pressure on cross
class companies to impose increases on
their liability book. Reductions are few and
far between.
US Downstream/Power/
Mining
2018 was generally a good year for this
sub-class, however the wildfire losses in
California (estimated at circa USD11bn)
means that underwriters in this space
are suffering from a very poor loss
experience in general. This exposure is
ring-fenced to a certain extent; however,
insurers will be looking to address a very
poor performance in this by looking
for opportunities the US Casualty
space. Wildfire is all but uninsurable in
a conventional fashion now, and many
insurers are re-evaluating their view of US
utility accounts in general, irrespective
of their exposure to Wildfire. There is a
similar concern about tailings dams.
US Upstream
A very similar story to the International
Upstream segment, with excellent
loss experience meaning rates are not
significantly increasing. Again, it is rare
to find markets that are solely exposed to US Auto is
US upstream without exposure to other
classes that have suffered losses (Marine,
being looked
Cargo, Downstream Energy) and so aren’t
aware of the general unease of the London
at increasingly
market; however, there is tangibly less
pressure on this class. US Auto is being
as a source of
looked at increasingly as a source of outlying losses,
outlying losses, due to some extraordinary
court awards and settlements in the last due to some
24 months.
extraordinary
Bermuda court awards and
The beginning of 2019 saw a number of
Bermuda casualty markets signalling
settlements in the
capacity reductions and a push for rate last 24 months.
increases. However, the momentum
increased significantly at the start of the
second quarter when markets aggressively
pushed rates further and in some cases did
not renew business where the offered rate
was deemed to be unsustainable.
Last year major carriers started taking
corrective action on limits deployed
and rates required. This has been adopted
by other carriers, especially those with
substantial limits deployed across the
marketplace. We have seen some carriers
offer various options for limits at differing
prices – generally larger rate increases for
larger limits.
Moving into the third quarter the market
continued to transition with reduction in
limits and increase in rates being seen
across all classes.
The thought is that this could get worse
as the year progresses and as we move
into 2020.
Marsh • 5
 The news of Swiss Re closing its London office and
writing hull insurance from their Genoa office has
also demonstrated quite clearly that this change of
mindset is not the sole preserve of the Lloyd’s market.

6 • Energy and Power Newsletter

Marine Exposures
Heading towards the end of the year, the Marine Market is still
readjusting to the Lloyd’s review of Syndicates profitability with
the unfortunate closure of more dedicated marine syndicates
concentrating the mind as to just what is at stake if pricing
remains at current levels.
The further reduction in hull capacity in the last month, has
not only created a shrinking of available carriers, but has sent a
clear message that management teams are still analysing their
portfolios, and underperforming lines will not be shown the
same sympathy as in previous years. The constant erosion of the
premium base in the soft cycle has naturally taken its toll, which,
as we are seeing, has led to reduced returns on investment and a
retraction of capacity.
The news of Swiss Re closing its London office and writing hull
insurance from their Genoa office has highlighted that this
change of mind set is not the sole preserve of the Lloyd’s market.
In addition to the reduction in capacity, we are seeing insurers
adopt a more stringent approach to their renewal books,
with most seeking to impose minimum premium levels for
their lines as well as withdrawing from certain vessel types
in a bid to increase their premium base and stop claims from
underperforming vessel types. Insurers are using data to review
and analyse their core book down to a very granular level.
The overseas markets are also seeing a reduction in capacity,
especially with the Singapore markets losing many hull carriers,
which has strengthened the insurers’ resolve to gain rate
increase and adjust terms to reverse years of soft market policy
upgrades.
Tensions in the Gulf of Oman remain at a critical level and, whilst
the actual number of attacks may have fallen, the situation is still
giving cause for concern for underwriters, owners and charterers
alike. The cargo insurance market has reacted to the change in
political tension by imposing additional premiums for war and
strikes risks coverage, predominantly on hydrocarbon products
transiting the Gulf, which in many cases is higher than and in
addition to the previous “All Risks” rate that would have applied.
This has led to the increased use of Cargo War Facilities to insure
war and strikes risks, where the insured volumes warrant it, as a
means of reducing the premium cost.
The marine liability market remains consistent and robust when
compared to the hull market. There has not been any significant
retraction of capacity and insurers have sought to push for
nominal rate rises on increased exposures.
Marsh • 7
Recent Quotes
The following quotes are taken from speeches public, statements or articles by
prominent market figures about the insurance market and whilst we have tried not to
take their words out of context, the excerpt may not be the entire speech or article.

Evan Greenberg, lines altogether. We’re seeing tightening of terms and

Chubb CEO
“Pricing continued to tighten in the quarter while
spreading to more classes and segments of business,
particularly in the US and London wholesale market.
We’re also seeing early signs that market-firming
conditions are spreading to more territories around
the world. The improvement in market conditions is
income and balance sheet driven and not happening
because there’s a dearth of capital. There’s plenty
of capital around, but it is more disciplined at this
moment and it’s deployed when the rate and terms
are more adequate. Just simply, the rate has not kept
pace with loss cost trend and that puts pressure
on income and it puts pressure, ultimately, on
reserves. The balance sheets over time have less
redundancy in them, and for some are adequate,
and become negative for others. And you have a
loss cost environment that, in many ways, in the
headlines, is stable, but you have areas of casualty
and catastrophes and other areas within the business
where there is volatility and there is trend pressure. In
my judgement, given some of the market dislocation
we’ve observed, including a reset of risk appetite on
the part of some, this firming trend is sustainable and
will likely to continue to accelerate and spread”.
conditions. Perhaps the most meaningful from our
perspective is we see a developing trend of business
getting kicked out of the standard market and making
its way into the specialty/E&S [excess and surplus
lines] market. In addition to that, there is an increasing
demand for facultative reinsurance – all historically
signs or classic indicators of a firming market,
particularly when you have all of these pieces lining
up the way they seem to be.”
From WR Berkley 2nd Quarter earnings call.
Andrew Horton
Beazely CEO
“Big losses in recent years, combined with a
crackdown by Lloyd’s on underperforming syndicates,
have contributed to a hardening market after several
years of rate decline. There has been a material
change in sentiment in the market in the past nine
months as heavy losses have driven prices higher.
Lloyd’s underwriting remediation efforts have
bolstered the overall upward movement. Margins now
look healthier than they have been for some years.”
From Beazley 2nd Quarter earnings call.

From comments made during Chubb 2nd Quarter William Berkley

earnings call. WRB Chairman

Rob Berkley “We are expecting rates in the casualty and

professional indemnity markets to move upward,
WR Berkley CEO
partly as a result of sustained pressure from larger
“The transitioning market is being driven by jury awards [in the US]. It’s what we and others have
increasing pain emerging across the industry, and labelled ‘social inflation’ where you’re seeing awards
will likely continue to gain momentum from here. coming out of juries where not only are they looking
The fact is, this industry responds to pain, and there to compensate the affected or the injured, but they’re
is a growing amount of pain. That is what’s driving also looking to punish.”
the change in behaviour. There is a growing amount
From Speech at KBW annual insurance conference.
of evidence that pain is going to increase or build
from here, which undoubtedly will drive the market
to tighten further. We are seeing a growing number
of carriers reducing their capacity or their line size,
and also in addition to that, a growing number of
examples of more people actually exiting product

8 • Energy and Power Newsletter

Dennis Langwell,
President of Liberty Mutual’s
Global Risk Solution
“The general liability book is suffering significantly
from an uptick in litigation financing and more
millennials on juries”.
From Speech at KBW annual insurance conference.
Richard Brindle Fidelis CEO
“The cat market is highly sensitive to an additional
event, with widespread dislocation possible post-
loss. One decent-sized loss by the end of the year and
we’re off to the races. The agent for change is the ILS
[insurance-linked securities] market, which has been
the key driver of pricing since 2012. Because it’s just
a load more trapped capital, a load more discredited
ILS managers who told their investors some cock and
bull story about 2019 – Oh we’ve re-underwritten the
book and you’re not going to respond to a medium-
sized event. They’ll then get trapped capital from
whatever it is and then it’s just another nail in the
coffin of these unaligned ILS managers that have no
skin in the game. The received wisdom on post-event
capital formation through the ILS market does not
reflect the jaundiced views of the hedge funds and
pension funds, and misses the point that money is
bleeding away from activist managers. The traditional
fundraises will struggle to command any credibility.
Even a USD 10bn loss event before year-end would
change the landscape given the amount of capital
cedants would trap, and the near-impossibility of
a third reload. However, there would be a delayed
impact on reinsurance pricing from the locking up
of the retro markets, which are 75% written by ILS
money. It’s like the roadrunner running off the end of
the cliff and continuing to run on thin air for a while.
They’ll go through 1 January as if nothing has really
changed but history suggests that it’s always at the
end of Q1 that the roadrunner finally crashes to earth,
and then you have the big corrections. It happened
in 2002, happened in 2006, happened in 2012 and I
think it will happen next year if we get another loss.
If the rest of the year runs clean, even the weaker ILS
funds will get away with it and the market may lose
its backbone. Change comes from some authority
imposing discipline on front line underwriters.
This can be senior management reducing available
aggregate limits that can be deployed, or a move from
Lloyd’s or AM Best. The ability of cat underwriters to
self-regulate is minimal, in my experience.”
From Interview with Insurance Insider published
10 September 2020.
The quotes referenced above are included herein to provide
readers with a broad overview and insight into what is currently
being said in the marketplace, however the inclusion of such do not
mean Marsh JLT Specialty , Marsh, or Marsh & McLennan Company
endorse or agree with any of the foregoing.

truism for a decade was that if you get a big event,

some people get burnt and disappear, but there will
be a wave of new capital looking to come in. Well, I
don’t think that’s supported by the facts. The ILS guys
are horribly on the ropes. Investors are unsettled by
climate change and the industry has no answer at this
point to the increased risk in the system, as wildfires in
Brazil and Siberia follow the 2017/18 conflagrations.
We’ve spoken to investors that said they had guys
saying California in 2017 was a 1-in-100-year event
and then it happens again the next year and they say
– it’s a 1-in-100 year event. Their response to that is:
don’t insult my intelligence and get out of my office.
Until the models have been revised convincingly, firms
that rely on model output to project returns for their

Marsh • 9
10 • Energy and Power Newsletter
Market Moves / People in the News
•• Nick Burkinshaw has joined Apollo
Syndicate Management as their Chief
Underwriting Officer, a newly created
board-level position. Burkinshaw
most recently served as Chairman of
Specialty at Fidelis and prior to that he
had a long career at Catlin.
•• Graham Kirk has resigned from Oil
Casualty Insurance Limited (OCIL) in
Bermuda in order to relocate back to
the UK with his family.
•• Geoff Hunt who retired from XL Catlin
has come out of retirement to join
Convex on a part time basis.
•• James McDonald has resigned from
AIG owned Talbot where he was
Global Head of Marine and Energy,
to join Sompo International to lead its
upstream energy business (replacing
Tom Houston, who recently left the
business to join Convex).
•• Simon Urry is to retire from StarStone
Syndicate 1301 later this year where he
is currently the active underwriter.
•• Ben Wilson, StarStone’s Head of
Power and Onshore energy has
resigned from the business. David
Message will oversee the power and
onshore team until a replacement
is found.
•• Mark Sullivan is leaving Barbican to
join IGI.
•• Tom Davies has joined The West
of England P&I Club’ Fixed P&I
underwriting team. He was previously
at Lodestar, where he serviced
European, Middle East and South East
Asian business.
•• Paul Bland has resigned from AmTrust
(where he wrote US utility casualty/
energy crossover business) to go
to Aspen.
•• Nick Waddell, Hiscox general
liability underwriter has resigned
to join Convex.
•• Patrick Kenahan, Kimberly Pursell, •• Christine Mello has resigned from
Michael Watkins, and Jason Pugi Sompo Bermuda to join Chubb
have resigned from Allied World Bermuda.
(AWAC)’s Bermudian casualty team to •• John Mohs has joined Sompo
join Ascot Bermuda. Bermuda from Liberty Specialty
•• James Langdon has resigned from (IronStarr) Bermuda.
Chubb to join AIG in London as their •• Maria Costello has joined Liberty
Head of Energy. Specialty (IronStarr).
•• Lyndsey Picton is returning to
•• April Andruczyk has left Chubb
Chaucer London in October from Bermuda.
Chaucer Singapore, continuing
Upstream underwriting but also taking •• Andrew Watson has moved to AIG
on a more strategic role. Scott Ho will Bermuda from Chubb Bermuda.
continue to write the Upstream book in •• Mike Southgate, Head of Marine,
Chaucer Singapore. Energy and Engineering at Canopius, is
•• Ian Picton has resigned from reported to be leaving Lloyd’s insurer.
Argenta Singapore.
•• Ian Simons is returning from Amlin
Singapore to Amlin London.
•• Ben Giddings is to join Marsh JLT
Specialty’s Singapore Upstream team
from THB.
•• Steve Farr was promoted to Global
Head of Upstream Energy at Axa XL,
the role left vacant by the departure of
Steve Hawkins to Convex.
•• Bob Clarkson is to join the Fidelis
London underwriting team. He was
most recently Class Underwriter for
Marine Hull and War at Brit Insurance.
He had previously worked at QBE
and Lloyd’s Claims Office in both
underwriting and claims roles.
•• Charles Franks Tokio Marine Kiln CEO
is to take on a new unspecified role
within Tokio Marine Group, while CUO
Paul Culham is to step down after 32
years with the company. Franks will be
succeeded by deputy CEO Brad Irick as
of 1 January, with Franks remaining on
the TMK board.
Marsh • 11
What’s New?
New Products and Market Developments
The London Joint Rig Committee
(JRC) has issued a new CL 380
buyback, which looks to address
some of the issues with the WRB/XLC
sponsored ‘CABBE’ CL 380 buyback.
To address the issue of aggregation,
CABBE only applies to a ‘Targeted
Attack’. One of the many criticisms of
CABBE was that even if only one oil
company suffers a loss from a virus
such as ‘NotPetya’, the fact that it
may infect other companies in other
industry sectors by definition makes it
a non-targeted attack (and therefore
is excluded). This has been taken on
board, to a degree, by the JRC (under
the chairmanship of WRB underwriter
Chris Walker). This new buy-back now
uses a broader definition of ‘Isolated
Attack’ that excludes a loss that occurs
at one location and any other location.
This is broader since there has to be
a loss at another location, not just an
attack. Unlike CABBE, if the loss falls
outside of an ‘Isolated Attack’ there
is not an absolute exclusion, rather a
different limit is to apply. We believe
insurers intention will be to grant up
to full policy limits for an ‘Isolated
Attack’, but for a ‘Non-isolated Attack’
the intention of insurers will be to
offer a much lower limit that they can
monitor against a total syndicate/
company aggregate (such as they do
for Gulf of Mexico Named Windstorm
losses). This therefore offers another
12 • Energy and Power Newsletter
option to the ‘QBE’ CL 380 buyback
where the intention was to offer
less than full policy limits to control
aggregation.
The London Joint Rig Committee
(JRC) have undertaken a review of
their Offshore Construction Marine
Warranty Survey (MWS) previously
published documentation. This has
led to an overall update of various
documents. The main changes include:
•• Introduction of the JR2019-
003 Property Values Guideline
document.
•• Consistent referencing to the
Society of Offshore Marine
Warranty Surveyors (SOMWS).
•• Alignment of the various Warranty
Endorsements and Codes of
Practice to ensure consistency.
•• Review and update of the Scopes
of Work.
•• Introduction of the JR2010-009
MWS Information Form to allow
MWS to demonstrate competence
when not accredited by SOMWS.
Lloyd’s is mandating that all first-
party property damage policies
incepting from January 2020 provide
clarity on cyber coverage by either
specifically excluding or giving an
explicit coverage grant. The same
requirement will come into effect in
2021 for liability business. One issue,
however, is that whilst the Upstream
market currently generally excludes
malicious cyber-attacks (via CL 380),
the Lloyd’s mandate is broader and
imposes specific coverage grants or
exclusions on non-malicious cyber
events (such as accidental failure of
computer systems causing physical
damage). We are talking to the Lloyd’s
Market Association (LMA) and Joint
Rig Committee (JRC) on this and will
advise further when more clarity is
obtained around standard clauses
to address this issue. Downstream
exclusion and buybacks (NMA 2914
and 2914) do not limit the clause’s
application to malicious event, so this
sector is not impacted in the same way
as the Upstream sector.
Marsh JLT Specialty has issued a
Risk Management bulletin on LNG
Paint, Coatings and Insulation, which
is of significant relevance for LNG
projects today. It provides advice on
how to confront insurance market
concerns in this area and how
companies can promote the quality
of their risk management in this
area. For a copy of this bulletin
please contact, Paul Nicholson
(Paul.T.Nicholson@marsh.com).
Briefly
Lloyd’s innovation team, working with experts at the Centre for Commercial Law Studies
at Queen Mary University, has produced a report that showcases how smart contract
solutions could be implemented across a range of products. It explores the technology,
design choices, and legal and regulatory considerations that insurers will need to think
about to make it happen. The report invites us to imagine a world where a claim is paid
before the customer realises they have experienced a loss by using smart contracts and
parametric insurance.

Pool Re, the UK state terrorism
reinsurance scheme, has secured a
GBP 40mm retro placement for non-
damage business interruption (NDBI)
after the Counter-Terrorism and Border
Security Bill gained royal assent. The
law included an amendment that made
Pool Re the first scheme in the world to
provide for terrorism-related BI losses
where there is no property damage.
The cover, placed by Guy Carpenter, sits
excess of both a GBP 15mm placement
attachment and member retentions.
Pool Re said the placement returns
the majority of the NDBI risk, based
on in-house modelling, to the private
market. The new NDBI placement is
additional to its main retro programme,
which Pool Re expanded by GBP 200mm
to GBP 2.3bn at its 1 March renewal.
Lloyd’s first half of 2019 earnings
report showed a return to profitability
following its underwriting performance
remediation work. Profit before tax for the
period was GBP 2.3bn, underpinned by
a combined ratio of 98.8% (2018 full year
was a loss of just over GBP 1bn). However,
several classes including Marine, Casualty
and Aviation all posted losses. Energy
contributed the largest profit at GBP
83mm, whilst Marine and Casualty lost
GBP 99mm and GBP 105mm respectively.
Energy saw premiums increase by 15% to
GBP 447mm resulting in an underwriting
gain of GBP 46mm over the same period
last year (up 124%) with a reduction in
operating expenses (down 10%) offsetting
a slight increase in claims (up 6%).
The World Energy Council (WEC)
in conjunction with Oliver Wyman
and Marsh & McLennan Insights has
released the flagship 2019 World Energy
Trilemma, examining the last 20 years of
government efforts to balance the policy
objectives of energy security, affordability
and sustainability. This year’s Trilemma
entailed a significant methodological
refresh and the introduction of historical
calculations that allow historical
performance since 2000 to be assessed
on a country-by-country basis.
Alongside the report, there is a new
interactive online tool, powered by Oliver
Wyman Labs, that includes individual
country profiles which is available under
the same link.  

Marsh • 13
14 • Energy and Power Newsletter
Security Rating Changes
The following rating changes affecting insurers writing energy business have occurred in the past 3 months or so.

Insurers Name Previous Rating Upgrade/Downgrade New Rating Effective Date

PartnerRe AM Best A Upgrade AM Best A+ 5 August 2019

International General AM Best A- Upgrade AM Best A 4 September 2019

Insurance Holdings (IGI)

NOTE
The above rating moves are not necessarily all rating changes that have occurred in the past 3 months affecting insurers that write
energy business and do not include changes in individual Lloyd’s syndicate’s rating (as Lloyd’s as a whole continues to be rated as an
overall entity).

Marsh • 15
Legal Roundup
The US Supreme Court Resolves Split
Regarding Punitive Damages
As reported in our July 2019 newsletter, the United States
Supreme Court held 6-3 that an injured Jones Act seaman may
not recover punitive damages on a claim for unseaworthiness.
The case made its way to the Supreme Court when a split in
authority arose between the United States Fifth Circuit and
Ninth Circuit Courts of Appeals. Specifically, the Ninth Circuit
expressly disagreed with the Fifth Circuit and found that punitive
damages were recoverable for Jones Act seamen for a claim
of unseaworthiness. The Supreme Court granted certiorari
(allowing appeal) to resolve the conflict between the two circuits
and addressed whether a mariner may recover punitive damages
on a claim that he was injured as a result of the unseaworthy
condition of the vessel.
In concluding that punitive damages are not recoverable in
an unseaworthiness claim, the Court based its reasoning
on three grounds. First, the Court found that, unlike
maintenance and cure, the overwhelming historical evidence
suggests that punitive damages are not available for claims
of unseaworthiness. Second, the promotion of a uniform rule
applicable to all sanctions for the same injury, whether under the
Jones Act or the general maritime law, commands conformity
with the statutory scheme established by the Jones Act. Lastly,
the Court was not persuaded that, in the absence of everything
else, punitive damages are warranted as a matter of policy. In
this regard, the Court noted that allowing punitive damages
would place American shippers at a significant competitive
disadvantage to their foreign counterparts and would discourage
foreign-owned vessels from employing American seamen.
16 • Energy and Power Newsletter
The UK Supreme Court holds ‘SCOPIC’
expenses not to be taken into account
in establishing whether a vessel is a
Constructive Total loss
Further to our report in our April 2019 newsletter of the UK
Court of Appeal’s referral to the Supreme Court of a case to
establish what salvage costs can be used to establish a vessel’s
constructive total loss, the UK Supreme Court has now held
salvage and other costs incurred before tender of notice of
abandonment should be taken into account for the purpose
of assessing whether a vessel is a constructive total loss, but
special compensation protection and indemnity clause (SCOPIC)
expenses should not.
SCOPIC is a bolt-on clause to the Lloyd’s Open Form of
Salvage Contract (LOF) that effectively guarantees the salvor
a reasonable remuneration for the personnel and material
deployed in attempting to salve the casualty. The main difference
between SCOPIC and salvage remuneration is the identity of the
insurer that funds it: salvage is ultimately paid by the property
insurer (hull and machinery in the case of the ship), but SCOPIC
is a P&I matter. That is because the liabilities avoided by a
successful salvage of a valueless ship (i.e., wreck removal and
pollution) are P&I risks.
The Supreme Court was unanimous in holding “the cost of
repairing the damage” included all the reasonable costs of
salving and safeguarding the vessel from the time of the casualty
onwards, together with the prospective cost of repairing it. These
costs were not reduced by being incurred before the notice of
abandonment and are therefore to be taken into account for the
purposes of s60(2)(ii) of the Marine Insurance Act 1906.
The court was also unanimous in holding SCOPIC remuneration
should not be taken into account. SCOPIC charges protect an
entirely separate and distinct interest of the shipowner – potential
liability for environmental pollution – which has nothing to do with
reinstatement of the vessel.

The lower courts had accepted the assured’s arguments that SCOPIC
costs were indivisible as part of the costs of recovery. The Supreme
Court disagreed. The costs are divisible because they relate to an
entirely different interest and are separately insured.

In light of this judgment, the case was remitted back to the

Commercial Court to determine whether or not there was a
constructive total loss on the facts.

Marine Warranty Surveyor held to be an ‘Other

Insured’ under WELCAR Offshore Construction
wording
Insurers have lost a case in a Texas court against the Marine Warranty
Surveyor (MWS) on the 2014 ‘Big Foot’ Construction project in the Gulf
of Mexico project. Whilst technically underwriters pay or contribute to
the costs of the MWS, in practice they are appointed by, and enter into
a contract with the insured, thus automatically making them an ‘Other
Insured’. WELCAR has a specific Waiver of Subrogation against “any
Principal Assured and/or Other Assured”. However insurers claimed
they were not subrogating in the name of the Insured, but directly in
tort against the MWS which owed them a duty of care that was not
fulfilled, and the MWS was therefore negligent to insurers. The Court’s
opinion confirms the established principle that an insurer may not sue
an insured to recover money paid for the risk that the insurer promised
to insure. It also alludes to the fact that insurers failed to prove damages
were caused by the breach of the duty MWS’s owed to underwriters,
and that whilst insurers “clothed damages in a negligence dress” they
are damages insurers paid the Insured (and therefore can only be
claimed via subrogation, which was clearly waived by insurers to all
‘Other Insureds’).

A standard WELCAR requires compliance by contracting parties with

Quality Assurance/Quality Control requirements of the insured to
qualify as ‘Other Insured’ and to be granted a waiver of subrogation.
However, in this case those provisions were deleted from the WELCAR
policy, so did not come into question.

The court went on to state that insurers were paid about USD 30mm
to assume the risks specified in the Offshore Construction Policy
(including damage caused by negligence), with one of those risks
becoming a reality, and, negligence or not, the insurers had to pay the
insured (again enforcing the fact that insurers action could only be in
subrogation).

Insurers also tried to claim that the MWS were not an ‘Other Insured’
as the WELCAR policy in question only covered physical damage, not
liabilities, and that the service contract required the MWS to indemnify
the insured for up to USD 5mm and purchase liability insurance that
was specifically non-contributory, which underwriters argued waived
or abrogated their ‘Other Insured’ status under WELCAR. The Court did
not agree with insurers on this point.

Marsh • 17
Demystifying Common Clauses
In this regular feature we take a look at common clauses found in Energy Insurance that
are often not well understood and try to look at what their intentions are, and what they
cover or exclude.
In this article we look at 72-hour clauses/occurrence definitions. We have provided
a general overview from our experience and encourage you to read the terms and
conditions of your particular policy.

Insurance policies typically require there to be an ‘Occurrence’ to trigger a loss

under the policy. The policy limit and the policy deductible or retention will also
normally be referenced as ‘per Occurrence’ or ‘each Occurrence’ (although in some
policies it can be aggregated over the policy period).

In the event that a covered event may result in a number of individual losses it is
important that the policy is clear and unambiguous as to how the limit, deductible
or retention applies to those individual losses. Therefore policies will usually contain
a definition of the word ‘Occurrence’ and that definition will normally include, within
the definition itself or as a separate clause, a ’72-hour’ provision.

A typical Occurrence definition will state that “the term ‘Occurrence,’ wherever
used, shall mean one loss, accident, disaster or casualty or series of losses,
accidents, disasters or casualties arising out of one event.”

However where weather related events (such as windstorms) occur over a period of
time causing several losses, it is often not possible to determine whether damage
caused was from one event or from multiple events. Therefore a 72-hour clause will
allow the aggregating of all losses within a 72-hour period commencing during the
policy period that arise from “windstorm, all tornadoes, cyclones, hurricanes, similar
storms and systems of winds of a violent and destructive nature, arising out of the
same atmospheric disturbance” to be treated as one event.

Similarly, an earthquake or volcanic eruption can result in several separate

earthquakes or eruptions where it may not be clear whether damage was caused by
one of the quakes or eruptions, or by two or more quakes or eruptions. Again, there
will usually be a 72-hour clause that aggregates all losses arising from more than
one earthquake, shock or volcanic eruption within a 72-hour period commencing
during the policy period to be treated as one event.

Whilst the 72-hour provision is normally limited to Windstorms and Earthquake/

Volcanic eruptions, some policy wordings will also include the perils of Hail, Strikes,
Riots & Civil Commotions; Flood or Storm Surge.

CONTACT US
If readers have particular clauses
they would like us to consider
including in this newsletter in the
future, or have any comments
on the above please contact
John.Cooper@Marsh.com

18 • Energy and Power Newsletter

Marsh JLT Specialty Training Courses

Marsh JLT Specialty runs three FOUNDATION LEVEL INTERMEDIATE LEVEL

Chartered Insurance Institute Location Location
(CII) accredited Energy Training London, England Dubai
Courses each year.
Dates: Dates:
These consist of a foundation level Energy
February 10-14, 2020 October 24-27, 2021
Insurance Diploma Course, an intermediate
and July 6-10 2020
level Energy Insurance Risk and Management
Course, and an advanced level Energy Risk Fee Fee
Management Course. £1,500 plus VAT per delegate* 10,500AED*

High level details of the upcoming

courses are as follows: INTERMEDIATE LEVEL ADVANCED LEVEL

Location Location
London, England London, England

Dates: Dates:
May 11-15, 2020 September 7-11 2020
and October 5-9, 2020

Fee Fee
£2,400 plus VAT per delegate* £2,400 plus VAT per delegate*

For a more detailed overview please request our

Energy Insurances Course 2020 Programme from
Sarah Verzola (Sarah.Verzola@Marsh.com)
*Travel, accommodation and allied expenses to be borne by the delegate.

Marsh • 19
Marsh JLT Specialty Energy
Industry Conference 2020
Marsh JLT Specialty will be hosting the 8th biennial Energy Industry Conference (EIC)
March 3–5, 2020.

The EIC (formerly known as the National Oil Companies Conference) is a global platform that brings together industry
leaders, key influencers and international experts from more than 50 countries. Over the course of the event delegates
discuss the challenges facing the world’s energy industry, opportunities for improvement and the risks faced by energy
companies exploring the fields of hydrocarbons, power generation and transmission, and renewable energy sectors.
The conference will also review the most advanced tools and methods of risk management. The conference will provide
a forum to discuss ideas and experiences and look at vital industry issues such as operational, financial and strategic
risk in energy operations.

Energy
Industry
Conference
2020
Staying ahead
of the curve
3 – 5 MARCH, 2020
INTERCONTINENTAL HOTEL
DUBAI , UAE

20 • Energy and Power Newsletter

Atlantic Named
Windstorm Forecasts
The hurricane activity in the Atlantic Basin for 2019 (as of 16 September) is shown below,
plotted against the pre-season predictions from various commentators and against the
69-year average.

FIGURE 2019 Atlantic Hurricane Season Activity/Forecasts

1

14

12

10

NHC (mid range) CSU TSR 69-year average Actual to date

Tropical Storms Hurricanes Intense Hurricanes

Marsh • 21
Focus on: Analytics –
Risk Finance Optimisation
Insurance is a source of capital that can be used to help manage and mitigate volatility;
it should be viewed in the context of capital, alongside other capital sources available to
finance insurable losses for example debt and equity.

22 • Energy and Power Newsletter

When designing an optimal insurance
strategy, i.e, the most financially efficient
blend of retention and premium spend,
two things should be considered:
1. Balance sheet retention – Using the
company’s capital to retain risk. Risk
retention introduces a level of volatility
to your balance sheet. The cost
associated with this can be measured
using the company’s Weighted Average
Cost of Capital (WACC).
2. Buying insurance – This uses the
insurer’s capital to mitigate losses at a
cost of rate on line (transfer premium).
Using insurance markets carries with it
liquidity risk, basis risk and counter party
credit risk which can be cost effective:

FIGURE Post Loss Sources of Capital

1

nce
gp refere
easin
er of decr
d in ord
Sorte

Source
of Funds
Budget Cash Debt Offering Sell Assets Total
Insurance Line of Dividend Cut Equity Offering
Credit

FIGURE Relative Cost of Capital: Insurance vs Other Sources

2
Insurance Capital
Energy ABC capital

PD OEE TPL
Cost of Debt Cost of equity
100 150 100

WACC 800BPS
Blended Rate* <125BPS

Marsh JLT Specialty’s Risk Finance Optimisation process allows companies to optimise
their insurance strategy by:
•• Calculating Risk Tolerance. •• Calculating loss costs and associated volatility through
Risk Analytics.
•• Understanding Risk Appetite.
•• Having our actuaries and placement strategists produce
Optimal Programme Design.

Marsh • 23
Risk Tolerance and Risk Appetite
The first step in optimising an insurance
programme is to understand the current
programme and potential exposures in
the context of the company’s financial
ability to retain risk, its Risk Tolerance.
Marsh JLT Specialty’s proprietary model
analyses balance sheet and income
statement Key Performance Indicators
(KPIs) to determine the financial ‘cushion’
available to withstand negative outcomes
over a twelve-month period. The Risk
Tolerance analysis also provides context
for measuring results, both against
internal and external (industry and
investor community) base lines. This
highlights a background against which
various risk retentions can be compared
and contrasted for appropriateness.
Risk Tolerance is an indicative figure used
to initiate discussion towards finding
your Risk Appetite, the amount of risk
the business is willing to retain. Marsh
JLT Specialty’s Risk Financing directors
undertake a series of interviews with the
leadership team to determine:
•• The business landscape.
•• Risk culture and reasons for buying
insurance.
•• Materiality thresholds and insurable
Risk Appetite.

Risk Analytics
The low frequency and high severity nature of claims in Oil & Gas
limits the effectiveness of standard actuarial techniques. For this FIGURE Analytics Virtous Circle
reason we have a team of actuaries specialising in quantifying
Energy Risks that supplements Marsh’s Loss Data Lake (LDL) 3
with academic research and statistics from third-party
organisations like SINTEF to build robust models reflective of a
company’s underlying risk. Our Virtuous Circle approach brings
in Claims, Engineering and Actuarial to challenge, refine and
enhance loss models.
ACTUARIAL

Using the expertise in the Virtuous Circle allows us to build large

loss and clash scenarios to estimate loss potential of events not in
data. A good example of such an event is the Macondo incident
in which a single event resulted in Property Damage, Loss of
Production Income, Control of Well and Third Party Liability losses. CLAIMS ENGINEERING

These events present an existential threat to the organisation and

need to be identified. However, given their low frequency nature
these events are typically not present in historical claims data and
need expert judgement to compute and model.

FIGURE Large Loss Correlation and Clash Scenario Modelling

4
Coverage View Scenario View

Property Damage (PD) Large loss and scenario modelling

is informative in testing the:
Operator’s Extra Expense (OEE)
•• Adequacy of insurance limits.
Third Party Liability (TPL)
•• The likelihood of insurance limits
PD OEE TPL LOPI P&I being exhausted.
Loss of Production Income (LOPI) PD
OEE M
TPL M H •• The magnitude of retained losses
Protection & Indemnity (P&I) LOPI H M M
excess of insurance limits.
P&I L L M M

24 • Energy and Power Newsletter

Optimal Programme Design FIGURE Evaluating Efficiency of
The final stage of the process involves identifying the most
financially efficient insurance programme structure. Using 5 Insurance Structures ECOR

loss modelling results from Risk Analytics, the Marsh JLT

Specialty placement team identify market realistic programme TCOR
structures, which sit within your Risk Appetite. For each of
Insurance
these programmes our models will determine the budget losses is a cost
expected each year (burn rate) and the cost of keeping insurance
risk on your own balance sheet, i.e, how much it would cost to
fund losses using business capital. We call this calculation the
Implied Risk Charge (IRC) and it’s determined by the Weighted $ $
Average Cost of Capital (WACC) No Current Option Option No
Insurance Programme A B Insuranc

ECOR
This approach enables companies to compare the cost of using their
ECOR
own capital and insurance in alternative programme structures. For Value
Creation Value
each programme a Total Cost of Risk (TCoR) and Economic Cost Creation
TCOR TCOR
of Risk (ECoR) are calculated. The benefit of the ECoR calculation Expected Loss Premium Implied Risk Charge
Insurance
Insurance
over TCoR, is thatisitaincludes
cost a capital charge (IRC) for retained and is a cost

uninsured coverage layers (i.e, losses in excess of policy aggregates

and limits). This recognises that there is a real, though not obvious,
$ $
financial cost to an organisation created by funding unexpected No Current Option Option No Current Option Option
Insurance Programme A B Insurance Programme A B
losses. ECoR calculates
$ the true cost of retaining and transferring $
risk and the volatilityNosurrounding expectedOption
Current Option
losses, as well as No Current Option Option
Insurance Programme A B Insurance Programme A B
demonstrating the value of buying insurance. The programme with
the lowest ECoR is the optimum structure. Expected Loss Premium Implied Risk Charge Optimised Programme

Oil Price and Expected

Its impact
Loss
On Programme
Premium Implied Risk Charge
Design
Optimised Programme

Capital decisions in the Oil and Gas sector
are heavily dependent on the price of oil
– the optimal insurance programme is no
different. Marsh JLT Specialty’s actuaries
have developed predictive models that
consider how key risk finance levers
change with oil price. This allows us to
design risk management programmes
that are robust and immunised from
small, frequent changes in the price of oil.
Risk Tolerance
Risk Tolerance is a measure of the financial
ability to retain risk. It is a function of
financial KPIs such as Free Cash, Net
Assets, Net Income (to name a few), which
are heavily dependent on the price of the
oil. From studying Risk Tolerance from a
random sample of integrated oil and gas
companies, we found it more sensitive to a
decrease in price than an increase.
Impact on WACC
A change in the cost of capital affects the
cost of balance sheet retention relative to
using an insurer’s capital. Our analysis of
WACC and the price of oil showed there
is a direct correlation between the two
meaning an increase in oil price leads to
an increase in the cost of capital for an
oil and gas company. As a result, balance
sheet retentions become more expensive
against buying insurance and as the oil
price decreases the opposite is true. This
reflects the need for your capital to work
harder when oil price is high.
Loss Costs
Our actuaries have analysed the
relationship between cost of materials
in the energy sector and changes in the
oil price. A regression analysis of oil price
movement against IHS Markit Capital
Indices allows us to predict the estimated
rebuild and replacement costs at a given
price point. In the event of an increase in the
oil price, demand for materials increases as
development activities increase. This means
the costs of the real value of deductibles,
EMLs and limits are eroded as the average
cost of claims increases.

Summary
Risk Finance Optimisation helps companies determine and By pricing these using our Economic Cost of Risk model, we can
design the optimal insurance programme. Marsh JLT Specialty identify the optimal insurance programme structure while providing
experts work with businesses to build an understanding of their valuable governance evidencing how decisions were taken.
appetite for insurance risk. They apply advanced, industry-
For more details on Risk Finance Optimisation please contact
specific risk analytics and insurance market knowledge to
your usual Marsh JLT Specialty Account Executive.
create alternate, viable policy structures.

Marsh • 25
26 • Energy and Power Newsletter
INTRODUCING MARSH JLT SPECIALT Y
We are specialists who are committed to delivering
consulting, placement, account management and
claims solutions to clients who require specialist advice
and support. We consider problems from every angle
and challenge the status quo with entrepreneurial ideas
and solutions.

With unparalleled breadth, our Marsh JLT Specialty global

team is united by a determination to bring the most
experienced and relevant specialist resources to our clients,
regardless of where in the world they are located. This
approach means our local specialists work seamlessly with
global experts, together creating and delivering tailor-made
risk and insurance solutions which address each client’s
unique challenges.

Our service offering is enhanced with insight-driven advice

supported by tailored data, analytic and consultancy
capabilities to support clients in making important decisions
about their complex risks.

Exceptional service combined with transparency, integrity,

and accessibility underpins our partnerships with clients.
For further information, please contact:

JOHN COOPER ACII

Global Chief Client Officer,
Marsh JLT Specialty | Energy & Power
+44 (0)20 7466 6510
John.Cooper@Marsh.com

Marsh JLT Specialty

The St Botolph Building
138 Houndsditch
London EC3A 7AW
www.marsh.com

Services provided in the United Kingdom by Marsh JLT Specialty, a trading name of Marsh Ltd and JLT Specialty Limited (together “MMC”). Marsh Ltd is authorised and regulated by the Financial
Conduct Authority for General Insurance Distribution and Credit Broking (Firm Reference No. 307511). JLT Specialty Ltd is a Lloyd’s Broker, authorised and regulated by the Financial Conduct
Authority for General Insurance Distribution and Credit Broking (Firm Reference No. 310428).

This newsletter is not legal advice and is intended only to highlight general issues relating to its subject matter. Whilst every effort has been made to ensure the accuracy of the content of this
document, no MMC entity accepts any responsibility for any error, or omission or deficiency. The information contained within this document may not be reproduced. If you are interested in utilising
the services of MMC you may be required by/under your local regulatory regime to utilise the services of a local insurance intermediary in your territory to export insurance and (re)insurance to us
unless you have an exemption and should take advice in this regard.

Copyright © 2019 All rights reserved.

© October 2019 . 280921