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Modern Slavery Statement 2021

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. Our employees are expected to report concerns and management are expected to act upon them. 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 2021.

Our business

Pension Insurance Corporation ('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 2021 new business success:

  • £44.1 billion of assets under management 
  • c.22% share of buy-in/buyout sector long-term 
  • 293,400 pension fund members insured 
  • 232 pension schemes insured, including the largest pension scheme buyout of 2021 
  • invested £90 million in its second Build-to-Rent project 
  • we currently have over 350 employees and have an annual turnover of £4,702 million.

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 Services 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, outsourced administrators, asset managers, reinsurers, other financial services providers, and developers and constructors on PIC’s Build-to-Rent projects. We believe the risk of modern slavery (which encapsulates slavery, servitude and forced or compulsory labour, and human trafficking) in our business and supply chain is low. We operate in a low-risk sector, and our business and most of our suppliers are located in the UK. We recognise that PIC can also help tackle modern slavery through our role as an investor and lender.

Our policies on slavery and human trafficking

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 PIC’s policies, which are embedded in our culture, are communicated on our internal intranet and are integral to all new employees’ inductions to PIC. Our Recruitment Policy includes provisions to safeguard against modern slavery in our business, including that only approved recruitment agencies may be used and all candidates must evidence their eligibility to work in the UK.

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, in the knowledge that their concerns will be taken seriously and investigated appropriately and confidentially. 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, and auditing our internal controls to ensure they are effective in countering modern slavery, and reports to the Board annually. Management at all levels are responsible for ensuring those reporting to them understand and comply with the policy. 

Due diligence processes for slavery and human trafficking

Due diligence, by way of Know Your Customer ('KYC') checks and risk assessments, are carried out at the initial onboarding 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 due diligence on our Build-to-Rent contractors and their supply chain, including questions on modern slavery.

As part of our initiatives to identify and mitigate risk:

  • we identify and assess potential risk areas in our supply chains
  • we monitor potential risk areas in our supply chains
  • we mitigate the risk of slavery and human trafficking occurring in our supply chains by seeking to ensure that our point of contact is preferably with a UK company or branch, and we expect entities to comply with modern slavery legislation and to have suitable policies and processes
  • we have in place systems to encourage the reporting of concerns and to protect whistle blowers

Our KYC and risk assessment processes are constantly under review to improve supplier vetting and to further minimise risks, including the risk of slavery and human trafficking. We are adding further questions to our KYC process to help us identify risks of modern slavery and understand what steps suppliers have taken to mitigate these risks, with more extensive questions for suppliers operating in jurisdictions or sectors at higher risk of modern slavery. In 2022 we intend to introduce ESG due diligence questionnaires for existing suppliers, starting with our most critical suppliers. We expect all those in our supply chain and our contractors to comply with our values and to contractually agree to comply with modern slavery legislation.

Responsible investment

Environmental, Social and Governance ('ESG') factors have always been an inherent part of PIC’s investment process when assessing the suitability of long-term investments, and are a natural consequence of PIC’s purpose of paying the pensions of its current and future policyholders.

In 2021 we continued to integrate ESG factors into our investment decisions to manage risk, but also view ESG investing as an opportunity:

  • in 2021 PIC invested a further £10.8 billion in ESG direct debt investments, including £2.9 billion in social housing and £1.1 billion in renewable energy (meaning we now have more invested in renewable energy than in oil and gas)
  • in 2021 PIC was a sponsor, and is a founding member, of the Good Economy’s “Building a Sector Standard Approach for ESG Reporting” for social housing
  • PIC and all of PIC’s key external asset managers are signatories to the United Nations’ Principles for Responsible Investment 
  • every member of PIC’s investment team fully integrate ESG factors when reviewing investments
  • PIC receives ESG data from MSCI and Sustainalytics and has established a risk-based methodology with which to assess investments on ESG criteria

Human rights considerations, including modern slavery, are an important element of the ESG factors we consider.

For our in-house managed investments we engage with the management of our privately sourced debt investments to understand their ESG risks, including how the borrower approaches social and governance factors such as how to balance the needs of all stakeholders, including their employees and society. Our long-term relationship with these borrowers allows us to engage with them closely to understand their overall sustainability efforts.

For our outsourced investments in 2021 we actively engaged with all four of PIC’s key external asset managers in relation to modern slavery; exploring how they research and monitor human rights issues in their investments, their participation in any modern slavery initiatives and what engagement they’ve had with investee companies in relation to modern slavery. We will continue to monitor our asset managers’ engagement in this area.

PIC has put in place a country risk framework, which sets a limit on (or in some cases prohibits) our exposure to each country, and which takes into account ESG factors.

In 2022 we intend to continue our efforts to investigate and mitigate the risk of any indirect links to modern slavery through our debt funding and investment portfolio. For example, we are developing sector specific ESG questionnaires for our new investments, which will include questions on modern slavery.


We have training on modern slavery available to all our employees. This is designed to raise awareness of what modern slavery is, who is affected, how to spot, and what to do if you spot, the signs of modern slavery. In 2021 we made this training compulsory for those employees in our facilities team and asset liability management team, who are most likely to come across potential risk areas.

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 PIC’s induction process.

All employees (including contractors) are regularly required 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 (including contractors) are regularly required to complete training on antimoney-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.

Key Performance Indicators

The Key Performance Indicators ('KPIs') below help summarise the effectiveness of the steps we’ve taken in 2021 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 (2020: None) 
  • suspicions of slavery or human trafficking disclosed via our whistleblowing procedures: None (2020: None) 
  • employees who have completed training on whistleblowing and financial crime: all new and existing employees (2020: all new and existing employees) 
  • employees who have completed training on modern slavery: all employees in our facilities team and asset liability management team (New KPI) 
  • number of existing supplier risk reviews carried out: 133 (2020: 43) 
  • number of PIC’s key external asset managers we’ve engaged with in relation to modern slavery: all 4 (New KPI)

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

Jon Aisbitt
Chairman of Pension Insurance Corporation plc
Date: 3 March 2022

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