This Applicant Privacy Notice Continental Europe is dated: July 2012 WILLIS.COM: PRIVACY NOTICE

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1 Applicant Privacy Notice for Positions in Willis Companies Located in the European Union and European Economic Area Excluding the United Kingdom ( Applicant Privacy Notice Continental Europe ) This Applicant Privacy Notice Continental Europe is supplemental to the Privacy Notice for Willis.com, available at and set out at the end of this Applicant Privacy Notice Continental Europe, and should be read in conjunction with that Privacy Notice. This Applicant Privacy Notice Continental Europe is for applicants for positions with a company in the Willis Group ( Willis ) located in the European Union and European Economic Area excluding the United Kingdom The types of information requested from you and the manners in which the information is handled are determined by the requirements of the country where the role is located, and not by the requirements of your country of residence. Information you provide to us in the context of an application is likely to include personal data. You must not provide personal data if you do not accept the terms and conditions set out below. The information you submit may be disclosed to our recruitment team, to those who interview you, to others involved in the recruitment process within the departments and business units of Willis global business, to service providers and as otherwise described in the Privacy Notice of Willis.com. This may include an office in a country outside the European Economic Area where Willis does business. For example, Willis data server is hosted on servers in the United States of America, by Willis North America Inc. Whether you submit an application form to us online, by post or by , we may scan a copy of the contents to be saved securely on our data server. If you are located outside the US, your provision of personal information constitutes your transfer of personal data to the US, a jurisdiction that may not provide an equivalent level of data protection to the laws in your own jurisdiction. For transfers to Willis North America Inc. ( WNA ) related to human resources, WNA is certified under the Safe Harbor privacy framework as set forth by the U.S. Department of Commerce, European Commission and Switzerland regarding the collection, storage, use, transfer and other processing of human resources personal data transferred from the EEA or Switzerland to the U.S. Please see WNA s HR Safe Harbor Privacy Policy set out at the end of this Applicant Privacy Notice. Willis maintains appropriate technical and organisational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. Despite this, the security of the transmission of information via the internet cannot always be guaranteed and you acknowledge this in your correspondence with us. If and when you submit details via an online application form, you will be asked to confirm acceptance of additional terms and conditions since our online job opportunities system is hosted in an application developed by JobScience, Inc. (a third party provider located in the U.S.) and built on the Salesforce platform. In accordance with applicable law, information which you provide to Willis during the recruiting process may be used in consideration of your application to work at Willis, and should you be successful for your future employment with Willis. Willis may anonymise your information and use it as part of internal Willis statistical

2 analysis in a recruitment context. The information that you submit to us as part of the recruitment process will be retained by us in accordance with applicable data protection legislation. Please note that we may retain your information on file even if you are unsuccessful in your application, unless you specifically request that we do not do so. Willis may further use your information to contact you regarding an alternative position to the one that you have applied for, if we think that this may be appropriate in the future. To the extent permitted by applicable law, Willis may do one or more of the following: (i) verify any information that you provide to Willis as part of the recruitment process; (ii) use an independent agent to verify your information if required or deemed advisable by Willis; (iii) obtain and review investigative and credit history reports for verification purposes in the location of the position for which you are applying, your country of residence, and if appropriate, in other jurisdictions. This may include, but is not limited to, sensitive personal data and may include seeking disclosure from applicable authorities of any criminal records relating to you. Willis will not do these things if they are prohibited by applicable law. By submitting an application to Willis, you acknowledge that you have read and understand this Applicant Privacy Notice Continental Europe, and that you consent to its terms and to the use of your personal data, including, if applicable, its transfer outside the EEA, as described above. This Applicant Privacy Notice Continental Europe is dated: July 2012 In this Privacy Notice we tell you: (a) who we are; WILLIS.COM: PRIVACY NOTICE (b) what we do with personal information you provide to us and/or which we collect through this website; (c) who it will be shared with. 1. WHO WE ARE This is the website of the Willis Group ( Willis ). Willis Group Holdings PLC, a company incorporated in the Republic of Ireland, is the ultimate holding company for the Group. The Willis Group operates worldwide with subsidiary and affiliate companies in the USA, Canada, Latin America, Asia-Pacific, Eastern and Western Europe, Russia, the Middle East, United Kingdom and Ireland. Keeping customer information secure is a priority for Willis. This website contains links to other websites. This Privacy Notice is specific to Willis.com. There are links from Willis.com to further Willis websites and to further web pages of Willis.com which may be subject to specific terms and conditions of use including separate

3 privacy notices and terms. You must not provide personal information if you do not accept those terms and conditions of use. Where links from Willis.com are provided to non-willis websites, Willis is not responsible for those websites. These third party websites will be governed by different privacy notices and policies and you are responsible for reviewing the relevant privacy policy for each website that you visit. 2. WILLIS WEBSITE Willis.com is hosted on servers in the United States. If you are located outside the US, your provision of personal information or other access to our website constitutes your transfer of personal data to the United States, a jurisdiction that may not provide an equivalent level of data protection to the laws in your own jurisdiction. Willis maintains appropriate technical and organisational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. Despite this, the security of the transmission of information via the internet cannot always be guaranteed and you acknowledge this in your access and use of this website. 3. INFORMATION WE MAY COLLECT FROM YOU The type of information we may collect includes: 1. your name, address, occupation and other contact information; 2. information regarding your dealings with us; 3. any interest you have in relation to our services or our practice areas; and 4. any information you may voluntarily submit to us by completing any form on this website. We may collect the information in various ways: 1. from forms you may fill in on our website (including in relation to any requests for marketing material or job information); 2. from feedback and inquiry forms completed, for example information collected from the Contact Us page of our website; 3. from the content of surveys that you may complete on our website; 4. from details of your visits to and usage of our website including the date and time of your visit, the internet address from which you visited and the resources on our website that you viewed; and 5. when you provide information as a client in connection with us providing professional services to you. Such information may be collected through Willis.com when clients access Willis client links within this website. Access will be subject to the terms of business we have with clients and any additional terms and conditions of use attached to those sites.

4 4. WHAT WE MAY DO WITH YOUR PERSONAL INFORMATION We may use information held about you in the following ways and for purposes specified in the relevant parts of the website: 1. to facilitate your participation in interactive features on our website, that you may choose to use; 2. to correspond with you, notify you of events or changes to our service, or otherwise to respond to your requests for information, which may include marketing to you; and 3. for the purposes of providing professional services to you via Willis applications: such services will be subject to additional terms and conditions of use including privacy. 5. DISCLOSURE OF YOUR INFORMATION Willis may disclose your personal data to any company within the Willis Group for the uses and purposes set out above. We may disclose your personal information to independent third parties: 1. if we are obliged to disclose your personal data under applicable law or regulation, or in order to enforce or apply our website terms of use, or to protect the rights of Willis, our clients, or other parties; and 2. in accordance with the separate terms and conditions of use that may attach to Willis website links. 6. INFORMATION COLLECTED FROM YOUR COMPUTER When you visit our website, our server may record your IP address for the purposes of systems administration. This IP address is not linked to any of your personal information. Willis may also gather other non-personal information from you (from which Willis cannot identify you), such as the type of your internet browser, which Willis uses to provide you with a more effective service. When you visit our website, Willis may store a cookie file on the hard drive of your computer. Cookies are small text files that a website transfers to your hard drive to store and sometimes track information about you. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you this may affect the functioning of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site. Cookies help us to improve our website and deliver a more efficient service more relevant to your needs. During your visit to our website, cookies enable us to speed up your searches, recognise your preferences and remember you during your visit. 7. SECURITY

5 Willis maintains appropriate technical and organisational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. Despite this, the security of the transmission of information via the internet cannot always be guaranteed and you acknowledge this in your access and use of this website. 8. CHANGES TO OUR PRIVACY POLICY From time to time, we may change our Privacy Notice and post those changes to our website located at The effective date of this Privacy Notice, as indicated below, indicates the last time this Privacy Notice was revised or materially changed. Checking the effective date below allows you to determine whether there have been changes since the last time you reviewed the policy. We will notify you of changes to this Privacy Policy by posting the revised Privacy Policy to our website. 9. CONTACT 10. DATE If you have any queries regarding Willis use of personal data through the website, please contact our Group Head of Compliance, at The Willis Building, 51 Lime Street, London, EC3M 7DQ, United Kingdom, or at This Privacy Notice is dated: April 2012 Willis North America Inc.: HR Safe Harbor Privacy Policy Willis North America Inc. ( WNA ) respects your concerns about privacy. WNA has certified that it abides by the Safe Harbor privacy principles, as set forth by the United States Department of Commerce, regarding the collection, storage, transfer, use and other processing of Personal Data (as defined below) transferred from the European Economic Area ( EEA ) or Switzerland to the United States. 1 This Policy outlines the company s general policy and practices for implementing the Safe Harbor privacy principles for Personal Data. For purposes of this Policy: Employee means any individual employed by Willis Group, any former or prospective employee of Willis Group, and any dependents, beneficiaries and other related individuals about whom they provide information to Willis Group in connection with the employment relationship. 1 WNA s Safe Harbor certification does not cover the Employee personal data that it receives from Willis Group affiliates in the United Kingdom. Instead, when the United Kingdom affiliates transfer Employee personal data to WNA, they will continue to do so on the basis of data transfer agreements.

6 Personal Data means any information that is (i) transferred to WNA in the United States from the EEA or Switzerland, (ii) recorded in any form, (iii) about, or relates to, an identified or identifiable Employee, and (iv) can be linked to that Employee. 2 Sensitive Data means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposal of such proceedings, or the sentence of any court in such proceedings. Willis Group means the subsidiaries and affiliates of Willis Group Holdings PLC. WNA s Safe Harbor certification can be found at https://safeharbor.export.gov/list.aspx. For more information about the Safe Harbor principles, please visit Safe Harbor Privacy Principles WNA s practices regarding the collection, storage, transfer, use and other processing of Personal Data comply with the Safe Harbor principles of notice, choice, onward transfer, access, security, data integrity, and enforcement and oversight. Notice WNA notifies Employees located in the EEA and Switzerland about the purposes for which it collects and uses Personal Data, the types of third parties to which it discloses the information (for example, service providers that process Personal Data on the company s behalf), certain privacy rights of Employees (such as the right to access Personal Data and the choices for limiting the use and disclosure of the information), and how to contact WNA about its practices concerning Personal Data. Purpose of Collection and Use of Personal Data WNA collects certain Personal Data from Employees, such as name, postal address, government identification information, employment details and bank account details. WNA collects and uses this Personal Data in connection with providing support services, including data storage, backup, and information technology infrastructure. In addition, WNA processes Personal Data in connection with Willis Group s human resources operations, including by facilitating (i) Employee communications, (ii) maintenance of a global directory, (iii) management of Employee headcount, (iv) recruiting and hiring of applicants, (v) management of Employee performance, (vi) determination of Employee compensation, (vii) management of the Employee termination process, (viii) disaster recovery and business continuity planning, and (ix) other general human resources functions. 2 As described in note 1, information transferred to WNA from Willis Group affiliates in the United Kingdom does not constitute Personal Data for purposes of this Policy.

7 Choice WNA may share Personal Data with its service providers and among its affiliated entities. In addition, WNA may disclose Personal Data (i) if the company is required to do so by law or legal process, (ii) to law enforcement authorities or other governmental officials, or (iii) when it believes disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. WNA also reserves the right to transfer Personal Data in the event it sells or transfers all or a portion of its business or assets (including in the event of a reorganization, dissolution or liquidation). Should such a sale or transfer occur, WNA will use reasonable efforts to direct the transferee to use the Personal Data in a manner that is consistent with WNA s privacy policies. Onward Transfer of Personal Data WNA may share Personal Data with service providers it has retained to perform services on its behalf. WNA requires service providers to whom it discloses Personal Data and who are not subject to laws based on the European Union Data Protection Directive 95/46 or the Swiss Federal Act on Data Protection to either (i) subscribe to the Safe Harbor principles or (ii) contractually agree to provide at least the same level of protection for Personal Data as is required by the relevant Safe Harbor principles. Access WNA provides Employees with reasonable access to the Personal Data maintained about them. WNA also provide a reasonable opportunity for Employees to correct, amend or delete that information where it is inaccurate. WNA may limit or deny access to Personal Data where providing such access is unreasonably burdensome or expensive under the circumstances, or as otherwise permitted by the Safe Harbor principles. Employees may request access to their Personal Data by contacting WNA as indicated in the How to Contact WNA section below. Security WNA takes reasonable precautions to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction. Data Integrity WNA takes reasonable steps to ensure that Personal Data the company collects is (i) relevant for the purposes for which it is to be used, (ii) reliable for its intended use, and (iii) accurate, complete and current. WNA depends on Employees to update and correct their Personal Data whenever necessary. Enforcement and Oversight WNA has established procedures for periodically verifying its implementation of and compliance with the Safe Harbor principles. The company conducts an annual self-

8 assessment of its practices with respect to Personal Data to verify that representations it makes about the company s privacy practices are true and that WNA s privacy practices have been implemented as represented. Employees may file a complaint concerning WNA s processing of their Personal Data under the Safe Harbor principles by contacting WNA as specified below. If WNA cannot resolve the complaint through its internal processes, the company will cooperate with the relevant data protection authorities in the EEA or Switzerland, as appropriate, in investigating and resolving complaints regarding Employees Personal Data. How to Contact WNA To address any questions or concerns regarding the company s Safe Harbor Privacy Policy or its practices concerning Personal Data, please send an to or write to: Willis North America Inc. 26 Century Blvd. Nashville, TN Attention: Legal Department

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