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Sustainability policy

1. Introduction

PIC is committed to building a long-term, sustainable business, based on the company’s purpose, which is to pay the pensions of our current and future policyholders. Amongst other benefits, this will provide employment across the economy, and generate wider benefit in an environmentally and socially responsible manner.

For us, the term 'sustainability' is used to encompass broader responsible business practices such as those linked to its Sustainability strategy, while the term ESG (Environmental, Social and Governance) is used to highlight specific ESG related factors that measure the sustainability performance of a company or our investments. 

We consider our key ESG factors to include, although not limited to, the following:


  • climate change and greenhouse gas emissions
  • emissions to air, water and land, pollution and waste 
  • biodiversity, deforestation and land use 
  • energy efficiency 
  • resource depletion (including water)  


  • human rights (including modern slavery and child labour)
  • health and safety 
  • diversity and Inclusion, and equal pay 
  • well-being and development of staff 
  • stakeholder and community engagement 
  • responsible relationships with suppliers 
  • delivering good outcomes for our policyholders/customers  


  • anti-bribery and anti-corruption
  • stewardship 
  • executive pay and other incentives 
  • board independence, diversity, and structure 
  • conflicts of interest 
  • anti-money laundering 
  • outsourced and third-party management 
  • maintaining the integrity & stability of the financial system  

PIC’s approach to sustainability

PIC’s sustainability activities are the responsibility of each business function enacting the activity. The governance is provided by various Board-level Committees which determine how PIC should embed the monitoring of ESG into day-to-day activities as well as ensuring compliance with legal and regulatory requirements. The Head of Responsible Investing chairs the Sustainability Oversight Forum which comprises over 15 senior representatives from across the business, including three Executive Committee members. The Sustainability Oversight Forum meets monthly and discusses all things ESG across the business.

PIC’s approach to sustainability is covered in several annual reports, including:

  • Annual report
  • Sustainability report 
  • TCFD report 
  • UK Stewardship Code Application 
  • UNRPI Transparency report 
  • Net Zero Asset Owners Alliance Progress report 
  • Modern Slavery statement 
  • Gender Pay Gap report  

Regulatory Requirements

PIC complies with all statutory and regulatory requirements relating to sustainability matters. The PRA’s regulatory requirements are currently in Supervisory Statement: Enhancing banks' and insurers' approaches to managing the financial risks from climate change (SS3/19), the Dear CEO letter from July 2020 on managing climate-related financial risks and the Dear CEO letter from October 2022 on the PRA supervision of climate-related financial risk.

PIC discloses climate-related financial information in line with the Task Force on Climate-related Financial Disclosures (TCFD) framework, which is a UK Government requirement for accounting periods starting after 6th April 2022.

PIC must publish an annual statement setting out the steps we take to prevent modern slavery in our business and our supply chains. This is a requirement under section 54 of the Modern Slavery Act 2015. Our Modern Slavery Statement is published on our website  and also on the Government's Modern Slavery Registry

The Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 require PIC to report annually on our gender pay gap.

HMT’s Sustainable Finance Roadmap has committed to a new set of Sustainability Disclosure Requirements for corporates and asset managers/owners, a UK Green Taxonomy, and to incorporate the ISSB requirements. We are monitoring the evolution of these standards.

2. Sustainability policy statements


PIC embeds the risk of climate change within its overall strategy and is committed to playing its part in the transition to a low carbon economy. Considering climate change risk is crucial as it helps us anticipate and prepare for potential challenges stemming from environmental shifts. By doing so, we not only safeguard our business but also contribute to a more sustainable future. Our commitment to participating in the transition to a low carbon economy is vital because it aligns our operations with global efforts to combat climate change, reducing our carbon footprint and ensuring long-term resilience in a changing world.

We are committed to continuously improving the environmental performance of our own business, as well as reducing the environmental impact of our investment portfolio. Actions we have taken demonstrating our environmental performance and improvements are reported in our annual TCFD report

PIC has committed to becoming Net Zero by 2050 for all its emissions and carbon neutral by 2025 for its own scope 1 & 2 operational emissions. Our interim targets are to decrease our public credit investment portfolio emissions 25% by 2025 and our entire portfolio emissions by 50% by 2030 from 2019 levels (where data is available). More information about our climate commitments can be found in our TCFD report.

We continue our progress to becoming carbon neutral by 2025 and we have already undertaken multiple corporate initiatives towards this target. These include removal of single use plastic utensils, installing communal bins and recycling bins in strategic locations, using energy efficient LED lights, and providing energy efficient laptops to staff.

We endeavour to minimise pollution generated from our business and any associated travel. We keep travelling to a minimum and where necessary, trains are a preferred travel option rather than flights. Employees are encouraged to decrease their own carbon footprint through a cycle-to-work scheme and a season ticket loan facility.

PIC will use engagement and collective action to help achieve our environmental goals where appropriate including engaging with the companies that we invest in and collaboration with sustainability bodies, industry groups and wider sector initiatives to drive action. Engagements with investee companies is done by the Investment team while engagement with suppliers is done via our Third Party Management team. More information about our stewardship and engagement activities can be found in our UK Stewardship Code Application.

We have embedded climate risk within our various Risk Management frameworks and policies. More information about this is found in our TCFD report.


PIC’s purpose is to pay the pensions of our current and future policyholders. This purpose governs our business culture and activities. PIC considers the creation of long-term social value by the business and within the investment portfolio to be a core part of fulfilling that purpose. We believe that the greater the socially beneficial outcomes generated, the higher the likelihood of the long-term stability needed to pay future pension payments.

PIC’s commitment to very high standards of customer service and keeping customers and the creation of social value central to our business strategy is reflected in the PIC values of ‘valuing our customers’, ‘doing the right thing’, ‘striving to be the best’, ‘providing security’, ‘embracing new ideas’ and ‘being a team’.

We believe our people are PIC’s most important asset and engage with employees on a regular basis. PIC seeks to hire and retain the right people to support our strategic and business objectives. We believe that to thrive as a company we must ensure our culture is one that is inclusive, diverse, safe and provides employees with opportunities to learn and grow.

A formal employee engagement survey Is performed annually to help us understand how deeply our values and culture are embedded throughout the organisation and to gather feedback from employees about their experience of working at PIC. We are committed to active promotion of Diversity and Inclusion in our relations with employees and others. Our approach comes from our values and capabilities framework.

We are committed to the Equality Act although our approach goes beyond that. We believe in consistency and fairness across all people, policies, procedures and practices.  

PIC is transparent regarding its gender pay gap, recognising the crucial role this disclosure can play in fostering equity and fairness. We believe that openly reporting this data annually is not only essential for accountability but it also promotes a workplace culture of equality and diversity. This information is available within PICG's annual report.

As stated in our Modern Slavery Statement PIC has a zero-tolerance approach to slavery or human trafficking and is committed to acting ethically and with integrity in all its business dealings and relationships. We implement and enforce effective systems and controls to ensure slavery is not taking place anywhere in our own business or in any of its supply chains.

As with environmental factors, PIC will continue to engage on social issues with the companies that we invest in or work with and where needed will rely on collaboration with other investors to drive action. More information about our stewardship and engagement activities can be found in our UK Stewardship Code Application.

PIC strives to be a good corporate citizen and supports initiatives which align with our values and role model best practices. PIC’s Charity Committee ensures that charitable actions and giving are part of the firm’ culture. It continues to embark in various charitable actions on a yearly basis and details of these are reported annually within our annual report and sustainability report.  


PIC’s Board commitment to sustainability is reflected in its Section 172 considerations. Section 172 of the Companies Act 2006 requires company directors to act in good faith and in a way that is aligned to promote the success of the company for the benefit of its members as a whole. PIC believes that to enable alignment, all its stakeholder relationships need to be considered and managed appropriately over the long-term including that of the environment, employees, policyholders, the regulator, suppliers, and the community.

There is no place for bribery or corruption within our business, investments, or supply chains. We believe in paying the tax we owe and believe in conducting all our business in an honest and ethical manner. PIC takes a zero-tolerance approach to the facilitation of tax evasion, whether under UK law or under the law of any foreign country.

PIC has aligned its remuneration structure so that it works in the best interest of our investors, policyholders, and other stakeholders. Staff are rewarded for long-term value creation while making sure they are not incentivised to take unnecessary risks.

We believe that our success is rooted in the diverse nature of the environment in which we operate and is dependent on our ability to leverage differences, collective experiences, variety of backgrounds, talents, skills and knowledge.

PIC recognises and values the benefits that diversity in all forms, can bring to its Boards. PIC recognises that conflicts of interest can occur although these should be avoided, wherever possible. All staff are alert to the fact that they may be in a position where a conflict may arise and provided with training on the process of identifying such a conflict and reporting it and we have processes in place to manage such a conflict.

3. ESG within investments

PIC defines ESG integration as the investment analysis of ESG factors alongside financial factors in the investment decision-making process.

We believe that the integration of ESG risks and opportunities leads to a broader assessment of the environment in which companies operate and their performance in managing different stakeholders, giving a fuller understanding of risks over the long-term than traditional financial analysis alone.

PIC integrates ESG analysis into the assets it manages in-house and delegates most of the ESG integration to its managers for the portion of its assets managed indirectly.

We use both third party ESG data as well as our own proprietary ESG methodology to guide investment decisions. Our ESG analysis is based on information gathered through our own due diligence process and by the use of specific third-party providers.

PIC imposes investment restrictions on selected sectors, including but not limited to: coal extraction, tar sands, oil and controversial weapons. 

Stewardship activities including engagement are covered by our standalone Stewardship Policy and UK Stewardship Code Application.

Details of PIC’s application of ESG within investments can be found in our Responsible Investment Approach document.

4. Industry initiatives

PIC is a signatory to the United Nations’ Principles for Responsible Investment (“UNPRI”), as are all of PIC’s key external asset managers that help manage the credit portfolio. As a signatory to the UNPRI we commit to enact the following six principles:

  • to incorporate ESG issues into investment analysis and decision-making processes
  • to be active owners and incorporate ESG issues into our ownership policies and practices 
  • to seek appropriate disclosure on ESG issues by the entities in which we invest 
  • to promote acceptance and implementation of the Principles within the investment industry 
  • to work together to enhance effectiveness in implementing the Principles 
  • to report on activities and progress towards implementing the Principles  

PIC is a member of the UN PRI Advance Collaborative Engagement initiative on Human Rights. We support the Task Force for Climate Related Financial Disclosures (TCFD) guidelines and publish our report annually. PIC is also an active member of the Net Zero Asset Owners Alliance and of the ABI’s Climate Change Working group. PIC is a supporter of Lawyers for Net Zero and PIC’s legal team are all members.

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