PensionBee Code of Conduct

Contents

1. Scope and Compliance
2. Workforce Standards
3. Diversity, Inclusion & Equal Opportunities
4. Business Integrity, Ethics & Anti-Corruption
5. Environmental Policy
6. Tax Strategy
7. Privacy & Digital Security

At PensionBee we’re guided by five core values, so we always do the right thing by all our stakeholders. These values are Love, Honesty, Quality, Simplicity, and Innovation.

This Code of Conduct outlines PensionBee’s business ethics and sets the minimum standards in relation to workforce standards, human rights, diversity & inclusion, integrity & ethics, tax strategy and the environment.

Scope and Compliance

PensionBee’s Code of Conduct applies to all employees, suppliers or any other person or persons associated or doing business for or with PensionBee, no matter where they are located (within or outside of the UK).

Workforce Standards

Human Rights Commitment

PensionBee conducts business in accordance with the highest legal and ethical standards. Respect for human rights is fundamental for us and we strive to respect and promote human rights in accordance with international human rights principles encompassed by:

• United Nations (UN) Guiding Principles on Business and Human Rights
• United Nations (UN) Universal Declaration of Human Rights
• International Bill of Human Rights
• International Labour Organisation’s (ILO) Core Conventions
• OECD Guidelines for Multinational Enterprises (OECD Guidelines)

Fair Treatment

At PensionBee, we are committed to our values of Love, Honesty, Quality, Simplicity and Innovation. We act responsibly in all business dealings and expect our Suppliers to uphold these principles and urge them to adopt similar policies within their own businesses.

PensionBee is an investor signatory and disclosing company of the Workforce Disclosure Initiative (WDI). We encourage all Suppliers to improve their transparency and accountabilityon workforce issues and we encourage all Suppliers to disclose under the WDI.

Paying a Living Wage

PensionBee pays all its employees at least a London Living Wage, regardless of where they are based. PensionBee formalised its commitment to the Living Wage in February 2020 by becoming an accredited Living Wage Employer. PensionBee’s goal is to ensure fair and appropriate compensation for all its employees. Note, the UK Living Wage pays a real living wage based on the true cost of living and is different to the UK Minimum Wage.

Freedom of Association & Grievance Mechanisms

We recognise that freedom of association and the right to collective bargaining are fundamental rights. At PensionBee we uphold our colleagues’ rights to association and collective bargaining, in line with our core values of Love and Honesty.

We have grievance mechanisms in place through which all employees can raise complaints or concerns ensuring they are protected from retaliation or reprisal for speaking up or lodging grievances relating to their rights as workers and working conditions. All the relevant information about our colleagues’ rights is easily accessible to any employee.

No Child Labour and Modern Slavery

At PensionBee we do not tolerate the use of child labour and expect our Suppliers not to use children in their operations or their value chains. We also respect all employees’ right to leave their employment freely upon reasonable notice, and we do not tolerate any forced labour or involuntary prison labour in our value chain.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

PensionBee has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chain. We expect the same high standards from all of our contractors, suppliers and other business partners.

A Safe & Healthy Workplace

Health and Safety are a pivotal part of our continued commitment to a healthy and safe workplace. As a small organisation, we all share responsibility for highlighting and solving potential health and safety risks.

PensionBee will take reasonable steps to:

• Provide adequate control of any health and safety risks arising from its workplace activities
• Involve and consult where possible its employees on matters affecting their health and safety
• Provide and maintain safe equipment
• Provide information, instruction, and supervision for employees
• Prevent accidents and cases of work-related illness
• Maintain safe and healthy working conditions
• Review and revise this Health and Safety Policy and Procedure as necessary at regular intervals

PensionBee has a team of fully trained First Aiders and a team of qualified Mental Health First Aiders, trained to provide mental health support to our employees. PensionBee also has an Health and Safety Officer and an Employee Health and Safety Representative.

Risk assessments will be conducted by the Health and Safety Officer. Any actions required to remove or control the identified risks will be implemented in a timely manner. Risk assessments will be conducted annually or when the work activity or work location changes, whichever is the soonest. We review our fire safety risk assessment every 6 months, and after each evacuation. Any employee who is concerned about health and safety at work can raise a concern directly with our Health and Safety Officer.

We pride ourselves that since PensionBee’s inception, we have reported zero accidents, injuries and fatalities, resulting in no occupational diseases nor lost working days. This applies to all PensionBee colleagues, including contractors.

As part of our Health and Safety Policy, all employees must achieve a score of at least 80% to pass a Compliance Test within their first month of joining and then once annually. The general compliance test covers Healthy Working, for an average of 0.5 hours of training per employee.

Diversity, Inclusion & Equal Opportunities

PensionBee is committed to promoting equality, diversity and inclusion, preventing unlawful discrimination and ensuring that our colleagues all feel respected and safe at work. Our aim is for our team to be representative of all areas of society, across all levels of the business, to better reflect and represent our diverse customer base. We welcome everyone regardless of gender, race, origin, religion, size, age, sexuality or disability and will not tolerate any conduct which harms others.

PensionBee takes any necessary steps to provide equality, fairness and dignity for everyone, oppose and prevent all forms of unlawful discrimination, create a working environment free of bullying, harassment, victimisation and unlawful discrimination, where every person’s individual differences and contributions are valued and respected.

Business Integrity, Ethics & Anti-Corruption

PensionBee strives to maintain the highest standards of governance, personal and corporate ethics, and to comply with all applicable laws and regulations.

PensionBee’s Anti Bribery and Corruption Policy applies to all employees and others associated with our firm. As part of this, training is provided to all employees (including executive management) who must achieve a score of at least 80% to pass a Compliance Test within their first month of joining and then once annually. The general compliance test covers Bribery and Anti-corruption.

PensionBee expects its Suppliers to act and conduct themselves in the highest ethical manner in all business dealings and interactions. We rely on our Suppliers to disclose any potential or perceived conflicts of interest in relation to any ongoing service provided to our business.

Environmental Policy

As an online and paperless pension provider with a remote-first workforce of 208 employees (as of December 2022), a small office footprint and cloud-based web services, we have a relatively limited direct impact on the environment.

However, with Assets under administration of approximately £3.0bn at the end of 2022, we have the opportunity to have a greater influence and positive impact through the investment portfolios managed by our asset manager partners.

At PensionBee, we are committed to minimising our impact on the environment whilst improving our environmental performance wherever possible. Our Environmental Management System is proportionate to PensionBee’s operational scale and environmental risk profile.

In order to minimise our environmental impact:

• We only use cloud-hosted web services;
• Our website is powered by 100% renewable energy;
• Our office premises on Blackfriars Road used 100% renewable REGO sustainable green electricity;
• We continue to offer fully remote working to all employees;
• We are a paperless provider and all our communications are digital;
• We donate old working IT equipment to our partner school;
• We responsibly recycle all other unneeded office equipment.

PensionBee is currently participating in the Mayor’s Business Climate Challenge (‘BCC’), an ambitious energy efficiency programme which supports businesses to reduce their energy consumption, to accelerate building-decarbonisation efforts and contribute to London’s target of becoming a net zero city by 2030.

In 2022, PensionBee announced that it had achieved carbon neutrality of Scope 1 and Scope 2 (market-based) emissions in accordance with PAS 2060. We have also committed to achieving net zero emissions across the entire business by 2050. This commitment is applicable to all direct (Scope 1) and indirect (Scope 2) operational emissions, as well as emissions from our wider value chain (Scope 3).

In 2022, we continued disclosing under the Streamlined Energy & Carbon Reporting (‘SECR’) framework. We also began disclosing under the recommendations of the Taskforce for Climate-related Financial Disclosures (‘TCFD’) for the first time.

Tax Strategy

PensionBee is committed to being a responsible and compliant taxpayer in the United Kingdom. The United Kingdom is our operating location, as it is where PensionBee has its business activity and where 100% of employees in the company’s direct operations have their working location. Where we contract with suppliers we ensure that we correctly deal with our tax obligations in respect of payments to them.

Privacy & Digital Security

At PensionBee we take the security of our customers’ personal information very seriously. We take administrative, legal, technical and physical precautions to ensure the security of personal information in accordance with the UK General Data Protection Regulation (GDPR). We use personal information in accordance with our Privacy Policy.

The Company reserves the right to amend this policy at any time