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. 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 2020.
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 2020 new business success:
- £49.648 million of assets under management
- c.24% share of buy-in/buyout sector long term
- 273,500 pension fund members insured
- More than 210 pension funds insured including two of the largest full buyouts in the UK
We currently have over 300 employees and have an annual turnover of £5,649 million.
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, outsourced administrators, asset managers, reinsurers and other financial services providers.
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 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 Slavery and Human Trafficking Policy statement describes how we are committed to acting ethically and with integrity in all our business relationship, 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 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 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.
As part of our initiative 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; and
- 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. In 2021 we intend to add further questions to help us identify these potential risks and understand what steps suppliers have taken to mitigate these risks.
Supplier adherence to our values
We have zero tolerance to slavery and human trafficking. 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.
Environmental, Social and Governance (“ESG”) factors have always been an inherent part of PIC’s credit 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 2020 we continued to increase our focus on integrating ESG factors into our investment decisions and engaging with the investee companies in our bilateral debt portfolio, for example:
- In 2020 PIC invested a further £11.4 billion in socially beneficial direct debt investments, including £2.7 billion in social housing and £1.0 billion in renewable energy (meaning we now have more invested in renewable energy than in oil and gas);
- In 2020 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; and
- PIC receives ESG data from Sustainalytics and has established a risk-based methodology with which to assess investments on ESG criteria.
Human rights considerations, including modern slavery, will already be an important element of the ESG factors we consider. All PIC’s key external asset managers have modern slavery statements and will actively engage on the topic with investee companies.
In 2021 and going forward we intend to go further to investigate and mitigate the risk of any indirect links to modern slavery through our debt funding and investment portfolio.
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 intend to make this training compulsory for those employees most likely to come across potential risk areas, including those in our facilities team and asset liability management team. We expect all employees to provide an attestation to our Slavery and Human Trafficking Policy, and this policy is flagged to new employees in PIC’s induction process.
All employees 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 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.
Throughout the Covid-19 pandemic we continued our efforts described in this statement to ensure there is no slavery or human trafficking within our business and supply chains.
PIC responded early and proactively to the emerging Covid-19 crisis. Our business continuity planning included extensive preparations with our key outsourcing providers and suppliers, so we were confident in their resilience and therefore our ability to maintain high service levels for all our stakeholders.
PIC was proactive in its approach to employee welfare from the start of the crisis, prioritising it and helping employees to continue to deliver over a sustained and challenging period. This included providing access to counselling where needed. To ensure the health and safety of our employees and contractors, we carried out risk assessments, followed Government policies and recommendations, obtained additional assurances from the cleaning company we use and our pensions administrator, and our Covid-19 health and safety procedure was independently audited. Employees continued to have access to the usual grievance and whistleblowing procedures.
Key Performance Indicators
The Key Performance Indicators (“KPIs”) below help summarise the effectiveness of the steps we’ve taken this year 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
- Suspicions of slavery or human trafficking disclosed via our whistleblowing procedures: None
- Employees who have completed training on whistleblowing and financial crime: all new and existing employees
- Number of existing supplier risk reviews carried out: 43
Next year we will report on additional KPIs measuring our progress on the additional steps explained in this statement that we intend to take to combat modern slavery.
This statement was approved by the Board of Pension Insurance Corporation plc.
Chairman of Pension Insurance Corporation plc
Date: 4 March 2021
Please click here to download the 2020 Modern Slavery Statement
Please click here to download the 2019 Modern Slavery Statement
Please click here to download the 2018 Modern Slavery Statement