SEC Form 3

FORM 3

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 INITIAL STATEMENT OF BENEFICIAL OWNERSHIP OF SECURITIES Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934 or Section 30(h) of the Investment Company Act of 1940

OMB APPROVAL OMB Number: 3235-0104 Estimated average burden hours per response: 0.5

1. Name and Address of Reporting Person* LONDON CHRISTOPHER M (Last) (First) (Middle) C/O WILLIS GROUP HOLDINGS LIMITED TEN TRINITY SQUARE (Street) LONDON ENGLAND EC3P 3AX (City) (State) (Zip)	2. Date of Event Requiring Statement (Month/Day/Year) 11/19/2003	3. Issuer Name and Ticker or Trading Symbol WILLIS GROUP HOLDINGS LTD [ WSH ]
		4. Relationship of Reporting Person(s) to Issuer (Check all applicable) Director 10% Owner X Officer (give title below) Other (specify below) COO - Global Specialties	5. If Amendment, Date of Original Filed (Month/Day/Year)
			6. Individual or Joint/Group Filing (Check Applicable Line) X Form filed by One Reporting Person Form filed by More than One Reporting Person

Table I - Non-Derivative Securities Beneficially Owned
1. Title of Security (Instr. 4)	2. Amount of Securities Beneficially Owned (Instr. 4)	3. Ownership Form: Direct (D) or Indirect (I) (Instr. 5)	4. Nature of Indirect Beneficial Ownership (Instr. 5)
Common Stock	125,870	D

Table II - Derivative Securities Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security (Instr. 4)	2. Date Exercisable and Expiration Date (Month/Day/Year)		3. Title and Amount of Securities Underlying Derivative Security (Instr. 4)		4. Conversion or Exercise Price of Derivative Security	5. Ownership Form: Direct (D) or Indirect (I) (Instr. 5)	6. Nature of Indirect Beneficial Ownership (Instr. 5)
	Date Exercisable	Expiration Date	Title	Amount or Number of Shares
Common Stock	12/18/2001	12/18/2008	Common Stock	45,000	3.31(1)	I	Right to Buy
Common Stock	12/18/2002	12/18/2008	Common Stock	45,000	3.31(1)	I	Right to Buy
Common Stock	12/18/2003	12/18/2008	Common Stock	45,000	3.31(1)	I	Right to Buy
Common Stock	12/18/2004	12/18/2008	Common Stock	45,000	3.31(1)	I	Right to Buy
Common Stock	08/01/2004	01/31/2005	Common Stock	393	13.5(2)	I	Right to Buy
Common Stock	07/01/2005	12/31/2005	Common Stock	197	28.2(3)	I	Right to Buy
Common Stock	07/01/2006	12/31/2006	Common Stock	98	30.7(3)	I	Right to Buy
Common Stock	03/24/2001	12/18/2008	Common Stock	4,130	1.65(4)	I	Right to Buy
Common Stock	02/27/2005	08/27/2005	Common Stock	1,821	26.84(5)	I	Right to Buy

Explanation of Responses:

1. The option exercise price was GBP 2.00 being the sterling equivalent at the date of grant.

2. The option exercise price was GBP 9.85 being the sterling equivalent at the date of grant.

3. The option exercise price was GBP 19.26 being the sterling equivalent at the date of grant.

4. The option exercise price was GBP 1.00 total being the sterling equivalent at the date of grant

5. The option exercise price was GBP 18.87 being the sterling equivalent at the date of grant

	CHRISTOPHER M. LONDON	11/19/2003
	** Signature of Reporting Person	Date
Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.
* If the form is filed by more than one reporting person, see Instruction 5 (b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
Note: File three copies of this Form, one of which must be manually signed. If space is insufficient, see Instruction 6 for procedure.
Persons who respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB Number.