Item 9B. OTHER INFORMATION

Disclosures Required Pursuant to Section 13(r) of the Securities Exchange Act of 1934

Set forth below is a description of a matter reported pursuant to Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 and Section 13(r) of the Exchange Act. Concurrently with this Annual Report on Form 10-K, we are filing a notice pursuant to Section 13(r) of the Exchange Act that the matter has been disclosed herein.

Willis Limited, WTW’s main broking entity in the U.K., at the request and on behalf of certain reinsured clients, has obtained reinsurance coverage from the F.A.I.R. Aviation Pool (‘the Pool’), which is managed by Société Centrale de Réassurance, a Moroccan entity (‘SCR Maroc’). The membership of the Pool changes each policy year, but has in some, but not all, years included Iranian (re)insurance carriers, namely Bimeh Markazi Iran, Bimeh Asia (Asia Insurance Co), and Bimeh Iran (Iran Insurance Co) (collectively, the ‘Iranian Carriers’). As a broker, Willis Limited has, on behalf of its reinsured clients, made premium payments to SCR Maroc (acting on behalf of the Pool) and received claims payments from SCR Maroc (acting on behalf of the Pool), at times offset against premium payments owed to the Pool. Willis Limited has not made any payments to or received any payments from the Iranian Carriers directly. However, based on currently known information, our belief is that SCR Maroc may have paid to (or received from) Iranian Carriers a portion of those amounts corresponding to their share of the Pool for the relevant underwriting year. We do not believe, based on current information, that the Company teams working on the placement understood or intended the connections with Iranian Carriers described above.

Since 2013, Willis Limited has made seven premium or netted premium/claim payments to SCR Maroc where Iranian Carriers were members of the Pool for the relevant policy year, in amounts equal to $134,728.12 plus EUR 7,242.40 in the aggregate. From these payments, Willis Limited retained commission of $21,860.71 plus EUR 2,566.86 in the aggregate.

An affiliate of Willis Limited has submitted a voluntary self-disclosure to the U.S. Office of Foreign Assets Control (‘OFAC’) in relation to the above-described U.S. dollar transactions. It intends to cooperate fully with any investigation by OFAC.

The Company does not intend to engage in future transactions or dealings with the Iranian Carriers.