Modern Slavery Statement

Introduction from the Chairman of the Board

Slavery and human trafficking remain a hidden blight on our global society. We all have a responsibility to be alert to the risks, however small, in our business and in our wider supply chain. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending 31 December 2025.

Our business

Pension Insurance Corporation plc ('PIC') is a specialist insurer that provides tailored pension insurance buy-ins and buyouts to the trustees and sponsors of UK defined benefit pension schemes. PIC’s purpose is to pay the pensions of its current and future policyholders. PIC is committed to providing secure and stable retirement incomes through financial strength, leading customer service, comprehensive risk management and excellence in asset and liability management.  

PIC’s 2025 new business success:

• £54.8 billion of assets under management 
• c.438,000 pension fund members insured 
• 324 pension schemes insured 
• £6.8 billion of new business premiums (2024: £7.8 billion) - securing the pension benefits of c56,000 defined benefit pension scheme members 
• total defined benefit pension liabilities insured through buy-out and buy-ins since 2008 of £371 billion (2024: £331 billion) 
• total UK direct investments to FY25 £15.0 billion (2024: £13.8 billion), which includes £2.8 billion in social and affordable housing and £2.4 billion in student accommodation.

We currently have 705 employees and have an annual turnover of £6,840million.

Organisation’s structure

The group structure of PIC consists of two holding companies: our ultimate parent, Pension Insurance Corporation Group Limited, and PIC Holdings Limited.  PIC is our regulated entity and represents around 98% of group assets. Pension Service Corporation Limited is our service company (see below group structure).

PIC’s group is located in London and does not have any overseas branches. 

Our supply chains

Our supply chains include facilities management, policy administrators, IT providers, investment managers, reinsurers, other financial services providers, and developers and constructors on PIC’s built environment projects. The majority of our suppliers operate in the UK.

We believe the risk of modern slavery (which encapsulates slavery, servitude and forced or compulsory labour, and human trafficking) in our business and our supply chain is low. We do not believe that our business model may cause, contribute or directly result in modern slavery in our operations or supply chain.

We consider that the highest risk of modern slavery in our supply chains occurs in relation to our built environment projects (being our build to rent and affordable housing projects) and we’ve explained how we mitigate this risk below. We recognise that PIC can also help tackle modern slavery through our role as an investor and lender and we have explained this in ‘responsible investment’ below. 

Our policies on slavery and human trafficking

We have a zero-tolerance approach to modern slavery, and we are committed to ensuring that there is no slavery or human trafficking in our supply chains or in any part of our business. Our zero-tolerance approach is supported by our policies, which are embedded in our culture, are communicated on our internal intranet and are integral to all new employees’ inductions.

Our Third-Party and Outsourcing Management Policy defines the minimum requirements for the selection and appointment of suppliers. This includes requirements relating to inherent risk assessment, due diligence and contractual clauses. This criterion ensures that only approved suppliers, who meet standards relating to conduct, governance, location and more, are engaged to undertake work on behalf of PIC. The Chief Operating Officer has responsibility for this policy.

Our Recruitment Policy includes provisions to ensure that the recruitment process is fair, consistent and robust and is consistent with the Equality Act 2010. The policy includes a requirement that only approved recruitment agencies may be used, and all candidates must evidence their eligibility to work in the UK. This helps to safeguard against the risk of modern slavery in the recruitment process. The Head of Talent Acquisition on behalf of the Chief People Officer has responsibility for this policy.

Our Whistleblowing Policy is designed to encourage employees to promptly report any suspected wrongdoing or dangers at work, including any suspicions of slavery or human trafficking. Employees can make such reports in the knowledge that their concerns will be taken seriously and investigated appropriately and confidentially. Our Whistleblowing Policy takes account of the Whistleblowing Arrangements Code of Practice issued by the British Standards Institute and PROTECT (formerly Public Concern at Work). The Board has overall responsibility for the Whistleblowing Policy, and the Audit Committee has responsibility for reviewing the annual Whistleblowing Report and the effectiveness of actions taken in response to any concerns raised under the policy. The Whistleblowing Officer and the Whistleblowing Champion have day to day responsibility for this policy and overseeing its effectiveness.

Our Anti-Slavery and Human Trafficking Policy describes how we are committed to acting ethically and with integrity in all our business relationships, and how this is implemented and enforced through effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our business or our supply chains.

The Board has overall responsibility for our Anti-Slavery and Human Trafficking Policy. The General Counsel has primary day to day responsibility for implementing the policy, monitoring its use and effectiveness, dealing with any queries and auditing our internal controls to ensure they are effective in countering modern slavery. This modern slavery statement, describing the steps we’ve taken to ensure slavery and human trafficking are not taking place in our business or our supply chains, is provided to the Board annually.

Our employees are expected to report concerns, and management at all levels are responsible for ensuring those reporting to them understand and comply with the policy.

These policies are each updated every one or two years (or more frequently if required). We are currently updating our Anti-Slavery and Human Trafficking Policy to reflect the latest Transparency in Supply Chains Statutory Guidance and to ensure it aligns with United Nations Guiding Principles on Business and Human Rights. 

Assessing and managing the risk of slavery and human trafficking 

The risk of failing to meet our obligations under legislation such as the Modern Slavery Act is identified, assessed, and monitored through our core risk processes. Within our Enterprise Risk Management (ERM) framework, Modern Slavery risk specifically and risks around legal and regulatory compliance generally, are captured within our taxonomy under People Risk, Legal and Regulatory Risk and Third Party and Outsourcing Risk. Risk and Control Self‑Assessments (RCSAs) are routinely performed across the organisation, and this process assesses the adequacy of controls designed to mitigate the risk of non‑compliance with relevant laws and regulations.

We note that the updated guidance on the risk assessment for Modern Slavery requires specific risks be assessed, described, and disclosed. We will build on our existing risk framework to improve this risk assessment in 2027 as part of our RCSA refresh. 

Due diligence processes for slavery and human trafficking 

Due diligence, by way of Know Your Client ('KYC') checks and risk assessments, are carried out at the initial on-boarding stage for any new supplier. These checks and risk assessments are refreshed every two to five years depending on the type of supplier. We carry out detailed due diligence on our built environment contractors, and their supply chain and this due diligence includes questions on modern slavery.

Our supplier Code of Conduct, first rolled out in 2024, sets out the standards and values we expect our suppliers to follow, including in relation to Environmental, Social and Governance ('ESG') topics and modern slavery.

As part of the supplier due diligence process, suppliers are required to complete a controls assessment questionnaire. This includes sustainability focused questions that covers topics such as modern slavery.

We use LSEG World-Check reports as part of our KYC process to perform due diligence on all new suppliers at both company and director level, including for the purposes of detecting any modern slavery and illegal trafficking, as well as money laundering, financial crime, serious misconduct, unethical conduct and other criminal or unlawful activity.

Our due diligence processes allow us to identify, assess, monitor and therefore minimise potential risks of modern slavery in our supply chains. Our risk assessment, KYC and due diligence processes are constantly under review to improve supplier vetting and to further minimise risks, including the risk of slavery and human trafficking.

We further mitigate the risk of slavery and human trafficking occurring in our supply chains by seeking to ensure that we contract with a UK company or branch. We expect all of our suppliers and contractors to contractually agree to comply with modern slavery legislation, to have suitable policies and processes, and to comply with our Code of Conduct.

Responsible investment

Given the purpose of PIC is to pay the pensions of our current and future policyholders, it is our responsibility to protect our investment portfolio from the impact of all types of risks. Environmental Social and Governance ('ESG') risks and opportunities have always been an inherent part of PIC’s approach to assessing the suitability of long-term investments.

PIC is a signatory to the UN Principles of Responsible Investment ('UNPRI') and has been since early 2020.

PIC has maintained its signatory status to the UK Stewardship Code for a second consecutive year, which is a testament to the emphasis we put on our engagement activity. The first year of our five-year engagement strategy was implemented this year. The strategy, which runs from 2025-2030, is split between asset classes and formally expands our focus across six core topics, two of which in particular are relevant social topics:

1. human rights: Engaging with companies to ensure that they respect and uphold human rights throughout their operations and supply chains. This includes addressing issues such as forced labour, modern slavery and fair wages
2. human capital: Engaging with companies to promote employee well-being and opportunities for workforce development. The focus is on ensuring that companies invest in their employees and create positive working environments.

Some notable actions for our Responsible Investing team over 2025 with regards to modern slavery are: 

• we continued to be active participants in UNPRI-led collaborative engagements on human rights and social issues within the supply chains of energy, mining and renewable companies
• we engaged with 183 companies via our various engagement channels. Of those engagements, 14% had a focus on human rights and 12% on human capital, both of which cover the topic of modern slavery to various degrees.

Mitigating modern slavery in our built environment projects

As part of the forward funding stage, we have an ESG checklist which sets minimum standards for all properties at acquisition. This means that all counter parties must have a modern slavery policy which is maintained and audits are undertaken on the construction supply chain (sub/contractors). PIC does not accept properties from counter parties that cannot produce a modern slavery policy.

Our real assets in operation are managed by third party managing agents under the terms of a Property Management Agreement (PMA). Each PMA contains obligations for the managing agent to comply with relevant modern slavery legislation. Key third party suppliers, providing services under the direction of the managing agent, are onboarded through our Third Party and Outsourcing team, using the due diligence process described above, providing supply chain transparency and ongoing governance.

Training

We have training on modern slavery, which this year was compulsory for all our employees. This is designed to raise awareness of what modern slavery is, who is affected, how to spot the signs of modern slavery, and what to do if you spot the signs of modern slavery. The Modern Slavery Awareness training is an e-learning course developed and provided by QA. As at 31 December 2025, there was 100% completion rate (686 employees). New starters are required to complete the training within their probationary period.

We expect all employees to provide an attestation to our Anti-Slavery and Human Trafficking Policy, and this policy is flagged to new employees in the induction process.

All Employees are required annually to complete training on whistleblowing, to ensure they are aware of the appropriate reporting mechanisms if they do have any suspicions of any wrongdoing, including modern slavery.

All Employees are regularly required to complete training on anti-money-laundering (noting that the proceeds of crime could include the proceeds of modern slavery) and counter terrorist financing, to ensure all employees can identify the signs of suspicious activity and understand our due diligence and suspicious activity reporting processes. 

Monitoring and evaluation

The Key Performance Indicators ('KPIs') below help summarise the effectiveness of the steps we have taken in 2025 to ensure slavery and human trafficking are not taking place in our business or supply chains:

• cases of slavery or human trafficking discovered internally or in our supply chain: None (2024: None) (tracked by our Head of Business Services)
• suspicions of slavery or human trafficking disclosed via our whistleblowing procedures: None (2024: None) (tracked by our Whistleblowing Officer)
• employees who have completed training (or refresher training) on whistleblowing and financial crime prevention: all new and existing employees (2024: all new and existing employees) (tracked by our Human Resources department)
• employees who have completed training on modern slavery. This year we decided to make this training mandatory for all employees given our expanding business activities: 686, all new and existing employees (2024: all employees in our facilities team and investment team) (tracked by our Human Resources department)
• select number of PIC’s external managers we have engaged with in relation to social issues including modern slavery: We feel that social issues are particularly important for two of our asset managers given the geographic nature of the investments they make for us. 2 out of 3 (2024: 2 of 3) (tracked by our Head of Sustainability)
• the majority of Critical and High Risk Third Parties have completed the sustainability questions as part of the broader controls assessment questionnaire: (2024: 65) (tracked by our Third Party & Outsourcing Department)
• number of investee companies we have engaged with including a focus in human rights or human capital: 183 (2024: 130) (tracked by our Head of Sustainability).

Our goals for 2026 in relation to modern slavery include:

• update our Anti-Slavery and Human Trafficking Policy
• update out Third-Party and Outsourcing Management Policy, supplier inherent risk assessment and due diligence processes to improve supplier vetting and to further minimise the risk of modern slavery
• human rights is one of the six ESG themes in our five-year engagement strategy. To ensure we keep this important topic in focus, we decided to include a reasonable increase in the number of engagements with our underlying issuers on Human Rights from 14% in 2025 to 18% in 2026. Engagements in this area aim to ensure that companies respect and uphold human rights throughout their operations and supply chains.  This includes addressing issues such as forced labour, modern slavery, and fair wages. Priority sectors identified based on relevance, exposure, and potential influence include Manufacturing, Renewables, Consumer non-cyclical and Housing Associations
• build on our existing risk framework to improve our modern slavery risk assessment as part of our RCSA refresh.

This policy was drafted by the Company Secretariat team, with input from the Head of Sustainability, HR, Legal, Risk, TP&O and Built Environment teams across PIC. It was reviewed by the Head of Governance and the General Counsel/Company Secretary before being submitted for review and approval by the Pension Insurance Corporation plc Board. 

This statement was approved by the Board of Pension Insurance Corporation plc.

David Weymouth
Chairman of Pension Insurance Corporation plc
Date: 24 March 2026