PensionBee Diversity, Inclusion and Equality Policy

PensionBee’s approach to diversity


At PensionBee our mission is to live in a world where everyone can look forward to a happy retirement. To help us achieve this as we grow, we’ve chosen values that stand the test of time: love, quality, innovation, honesty and simplicity.

We have two main aims in our approach to diversity, inclusion & equality:

  • Build a team that’s reflective of all areas of society, across all levels of the business. Not only is this a moral imperative, it also enables us to better reflect, represent and serve a diverse customer base. This supports our mission to live in a world where everyone can look forward to a happy retirement.
  • Create an inclusive working environment where everyone has equal access to opportunities and is treated with fairness and dignity. Not only do we have a legal duty to protect people from discrimination, inclusivity also ensures everyone’s able to reach their full potential in line with our values of love, quality, innovation, honesty and simplicity.


In 2023, we continued working towards the following broad goals, which we reaffirm for 2024:

  • Gender balance and representation at all levels
  • Representation of Asian/Black/Mixed/Multiple/Other ethnic backgrounds to match the UK population across all levels

We’ll also continue to work towards the goals set by the FCA requirements for publicly listed companies which are outlined further below.

Applicable standards, definitions and concepts

Applicable standards

Discrimination is the unjust treatment of someone because of their personal characteristics. It can take many forms, including in pay and benefits, terms and conditions of employment, dealing with grievances and discipline, dismissal, redundancy, parental leave, requests for flexible working, and selection for employment, promotion, training or other opportunities.

The Equality Act 2010 recognises the following protected characteristics: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality, and ethnic or national origin), religion or belief, sex and sexual orientation. It is illegal to discriminate against someone based on these characteristics. PensionBee recognises that this list is not exhaustive, and our code of conduct also specifically bans discrimination based on someone’s size.

The Protection from Harassment Act 1997 makes it an offence to behave in a way which is intended to cause another person distress, over more than one occasion.

By law, all employers are required to make reasonable adjustments to ensure that people with disabilities, or physical or mental health conditions, are not substantially disadvantaged from doing their jobs.

Defining Diversity, Inclusion and Equality

Diversity is about recognising and respecting the differences between us. Our customer base includes people from a wide range of cultures and backgrounds, and our workforce should reflect this in order to allow us to represent our customers’ interests more fairly. Listening to a wide range of perspectives helps us to create innovative solutions which drive us towards our vision of a world where everyone can look forward to a happy retirement.

Inclusion involves making sure that everyone working for PensionBee knows that their differences are valued. Every PensionBee employee deserves to feel as though they can be successful as themselves, that their contributions matter, and that they’re supported in reaching their full potential.

Equality means that we want to treat every employee fairly. In some cases this means making sure that we hold each employee to the same standard, and that we administer pay, benefits and disciplinary action consistently and in an evidence-based manner. However, we must also recognise that systemic inequalities mean that rather than equal opportunities we should provide equal access to opportunities, and support every member of our team in developing the skills they need to succeed.

Board and Executive Management


PensionBee’s approach to Board and Executive Management diversity, inclusion and equality aligns with our wider mission to live in a world where everyone can look forward to a happy retirement, the achievement of which is underpinned by our Values.

The Company’s aims for Board and Executive Management composition mirror that of the wider business, namely, to build a team that is reflective of society as a whole, and creating an inclusive working environment where everyone has equal access to opportunities and is treated with fairness and dignity.

Policy Statement

PensionBee’s Board is committed to promoting diversity, inclusion and equality in the boardroom and aims to meet industry targets and recommendations wherever possible. The selection of candidates to join the Board will continue to be based on merit and the appointee’s ability to contribute to the Board’s effectiveness. All appointments and succession plans will promote diversity of gender and age, ethnicity, disability, socio-economic status and sexual orientation.

The Board, with the support of the Nomination Committee, will continue to develop its succession plans and provide oversight of Executive Management succession arrangements, a key factor of which will be ensuring that it seeks to achieve the Company’s aims concerning diversity, inclusion and equality.

Recruitment Approach

For Board and Executive Management appointments, we will seek a diverse range (across multiple criteria) of credible, qualified candidates for both non-executive and executive roles. Specifically, where appropriate, we will consider candidates for appointment as non-executive directors from a broader pool including those with little or no prior publicly listed company board experience. These same criteria would be required in circumstances where an executive search firm was engaged. We will only engage with firms that have adopted the Voluntary Code of Conduct in respect of diversity.

Financial Conduct Authority Targets and Objectives

To drive change in the industry, the Financial Conduct Authority (‘FCA’) has set specific requirements for publicly listed companies. These are to:

  • Report on gender and ethnicity representation at board and executive level in a standardised format using the tables provided.
  • Provide an explanation of the company’s approach to collecting the data used for making the disclosures.
  • Report on a comply or explain basis in the company’s annual report and financial statements whether the company has met the following targets on its chosen reference date within the accounting period:
    • at least 40% of individuals on the board of directors are women;
    • 1 senior board position being held by a woman (Chair, CEO, SID or CFO);
    • 1 board member being from an Asian/Black/Mixed/Multiple/Other ethnic background. (together the ‘FCA Targets’).
  • Consider a wide range of diversity aspects including:
    • Gender and age, ethnicity, disability, socio-economic status and sexual orientation.

Board and Committee Review and Responsibilities

The Board, supported by the Nomination Committee, is also committed to:

  • Ensuring that the Board and its committees have a good balance of skills, experience, knowledge, perspective and varied backgrounds.
  • Ensuring that Board appointments consider a wide pool of candidates with an array of experience and backgrounds including all aspects of diversity while not compromising on the calibre of candidates for appointment consideration.
  • Ensuring the development of a diverse pipeline for Executive Director succession. The Nomination Committee will report annually on Board and Executive Management diversity, including progress against the FCA Targets, within the Corporate Governance Section of the Company’s Annual Report and Financial Statements.

Review of the Policy

The Board and Nomination Committee will keep this Policy under review to ensure its effectiveness and alignment with best practice and the requirements of the UK Corporate Governance Code and relevant legislation. The Nomination Committee reviews the Policy annually with any changes recommended to the Board.

Our policy in practice

1. We Have a Zero-Tolerance Approach to Bullying, Harassment, Victimisation and Discrimination

We have a zero-tolerance approach to bullying, harassment, victimisation and discrimination against colleagues, customers and suppliers or any other persons in the course of an individual’s employment by PensionBee or otherwise in the conduct of PensionBee’s business. Any reports of these acts will be investigated as misconduct following the investigation and disciplinary procedures outlined in the accountability section under “PensionBee Culture” in our People Handbook, and appropriate action will be taken should the complaint be upheld. Particularly serious complaints could amount to gross misconduct and lead to dismissal without notice.

Each member of staff working at PensionBee could be held individually liable for acts of bullying, harassment, victimisation and unlawful discrimination in the course of their employment. Further information on recognising and avoiding these behaviours can be found in the inclusion commitment section of our People Handbook.

We encourage people to speak up if they experience or witness bullying, harassment, victimisation or discrimination either through giving direct feedback, speaking to a manager or raising a grievance. Further information can be found in the speaking up section of our People Handbook.

Our annual Diversity, Inclusion and Engagement Survey and bi-annual managers survey ask questions to help us track the scale of unreported bullying and harassment behaviours, as well as people’s comfort reporting these to their manager, and the efficacy of any support they received. The results of the survey are used to guide where improvements can be made to further support inclusion and a respectful working environment.

2. We Train All Employees on Promoting Diversity and Inclusion

The whole company must complete an annual compliance test, which includes sections on diversity and inclusion. This reminds our team of their rights and responsibilities, including helping the organisation provide equal opportunities in employment, and working to actively prevent bullying, harassment, victimisation and discrimination.

When employees first join the company they are enrolled in the compliance test, which covers the above. They also take part in an induction session which covers our values and a read through of our People Handbook, which further outlines our culture code, inclusion commitment, speaking up and accountability processes.

Managers are enrolled in our Bee A Leader training program which includes sessions linked to inclusion, such as values, emotional intelligence, feedback, coaching, happiness and reasonable adjustments. From 2024, this will include sessions on resolving issues informally and formally, and using our disciplinary and performance management procedures appropriately.

From 2024, the Head of Culture, Inclusion and Wellbeing will continue with interactive company-wide training sessions as part of the culture program. This training will be refreshed regularly, particularly in advance of large events.

From 2023, the D&I program has been further expanded to include involvement from Executive Sponsors, allies and volunteers. This commitment now forms part of each Executive’s performance objectives which are linked to remuneration.

3. We Regularly Monitor our Progress, Take on Board Feedback, and Develop Initiatives to Improve

To build a diverse and inclusive organisation, we know that we need data to better understand representation and experiences within our team, and hold ourselves accountable to our commitments.

Annual Diversity, Inclusion, Equality & Support Survey

We ask everyone to complete an anonymous annual survey to answer questions about how they feel about diversity, inclusion, engagement and support at PensionBee.

The questions are predominately rated on a 5 point scale with space to provide detailed written feedback.

This data is used for anonymised reporting to help us better understand employee experiences, what’s going well and where we need to focus our improvements.

Other Qualitative Feedback

We collect a variety of feedback throughout the year in formats such as focus groups, town halls, anonymous feedback on Officevibe, exit interviews and management working groups.

Other Quantitative Reporting

We have several other reports that we run to monitor progress these are:

  • Gender pay gap reporting
  • Ethnicity pay gap reporting
  • Calibration reporting of performance matrix scores by a variety of groupings, including gender, ethnicity and social mobility
  • Employee diversity data for external diversity charters such as the Workforce Disclosure Initiative, Tech Talent Charter and Social Mobility Employer Index 2023

    We use this data to prepare initiatives such as our Culture Program, and report on our progress in our Annual Report and external diversity charters. We also prepare an annual update on Diversity, Inclusion & Equality which includes setting out a program of suggested actions for the following year.

    We now publish our annual update in the People Handbook each year. Annual updates from before 2022 are available in Clausematch and the Google Drive and are linked in the 2022 update in the People Handbook. Links to more information on how we collect and store diversity data are also available in the People Handbook.

Diversity Data Collection

We ask everyone to complete the diversity data section of their HiBob profile and to let us know whether they consent to this data being used for anonymised reporting. We ask for consent on reporting on ethnic background separately.

We gather data on gender, gender identity, ethnic group or background, disability, neurodiversity, social mobility, education, sexual orientation, caretaker status, religion and language.

This data is used for anonymised reporting to help us build a diverse organisation, and monitor progress against our aims. Our approach to data collection and data usage is further outlined in our Pay Gap & Diversity Reporting Policy.

4. We Are Signed up to a Variety of Charters, Pledges and Social Impact Initiatives Aligned to our Diversity, Inclusion and Equality Aims

In 2023 we were involved with the following:

  • ABI Making Flexible Work Charter
  • ABI Transparent Parental Leave and Pay Initiative
  • Accredited London Living Wage Employer
  • Better Bankside
  • Careers & Enterprise Company work experience program
  • Disability Confident Employer (Committed Level 1)
  • Make My Money Matter campaign
  • Mental Health First Aiders
  • Makers Apprenticeship Scheme for technology careers
  • Mer-IT donating used laptops to anyone who needs one for a vocational course
  • Partnership with Langdon Park School
  • Race at Work Charter
  • Social Mobility Commission
  • Social Mobility Pledge
  • Social Mobility Employer Index
  • Tech Talent Charter
  • The Diversity Project
  • Workforce Disclosure Initiative
  • Time to Talk
  • Good With Money’s “Good Egg” Accreditation

5. We are Committed to Providing Reasonable Adjustments and Other Forms of Support

Whilst many people with a disability are able to carry out their work without the need for any particular support, others may be put at a substantial disadvantage and require additional support or adaptations to access the same opportunities as those who are not disabled.

The purpose of reasonable adjustments is to remove, reduce or prevent these barriers, and enable people to access and thrive in work. These may be changes relating to the physical environment such as needing wheelchair access, or to processes and policies such as part-time working hours, or benefiting from additional support such as mentoring or training. Many changes are free and easy to make, and government funded support is often available through Access to Work.

Reasonable adjustments are also available during the application process, for example by providing interview questions in advance or requesting a quiet room for an interview to accommodate sensory issues. The availability of reasonable adjustments is listed on each job advert.

Our full process for requesting reasonable adjustments is available in the People Handbook and this also provides more information on Access to Work grants and occupational health assessments.

For people who are not eligible for reasonable adjustments, other forms of support are available such as:

  • Action plans to make temporary adjustments e.g. short-term mental health crisis or returning to work after a bereavement
  • Flexible working requests
  • Informal discussions with a manager during happiness or weekly feedback meetings

6. We are Committed to Hiring and Promotion Practices That Support and Promote Diversity, Inclusion and Equality

Internal hiring

At PensionBee we’re committed to nurturing internal talent, in line with our company values. We prioritise internal hiring and career development over external hiring wherever possible. This allows us to boost engagement, increase retention and encourage high performance at all levels of the company. Our current employees understand our expectations and PensionBee’s culture, and already know our customers, product and processes in detail.

When a permanent role becomes newly available at PensionBee, we aim to follow certain guidelines that enable a degree of consistency and fairness across hiring, although hiring for each role may require a slightly different process. To reduce biases as much as possible, we have made the majority of the process anonymous. However, certain roles may require a presentation or interview as part of their tasks. The structure is held to the same standards and expectations for all candidates; multiple assessors will be involved and decisions will be solely based on how well the candidates do on the tasks using a scoring system.

More information on our internal hiring process is available in the People Handbook.

Entry Level Roles

We don’t ask for any prior experience, or particular education levels, in our entry level roles in our Customer Success Team, as we heavily invest in training so that all team members start with the same understanding of the pensions industry. We aim to encourage people, who may not usually do so, to enter the pensions industry. Over half of our new hires in 2022 were recruited into our Customer Success Team, with 92% of our Junior Management Team having progressed from our Customer Success Team.

External hiring

Several processes are in place to ensure fair hiring procedures and all hiring should follow our Hiring and Promotions Policy.

The hiring process must have at least two stages, and more than one person should be involved in decision making. It’s strongly recommended that one stage is a task-based assessment which simulates the work the candidate would be doing and can be anonymised to reduce bias.

All hiring decisions should be recorded in Workable and details given for the reasons behind decisions. It’s important we keep a record to ensure fair hiring procedures.

Where recruiters are used, they should be briefed on the importance of diversity, inclusion & equality to PensionBee.


All promotions and pay rises are decided based on the factors outlined in the Performance section of the People Handbook and our Remuneration Policy.

These decisions are made based on performance matrix scores which are run through a calibration process to report on any significant trends across groupings such as gender, ethnicity, social mobility or manager/team.

Last edited: 25-01-2024

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