PensionBee Code of Conduct and Business Ethics Policy

Scope and Compliance
Workforce Standards
Whistleblowing
Anti-Bribery and Corruption
Economic Crime and Money Laundering
Tax Strategy
Privacy & Digital Security
Environmental Policy

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 and Business Ethics Policy (‘the Policy’) outlines PensionBee’s business ethics and sets the minimum standards in relation to business ethics, including, but not limited to, workforce standards, approach to whistleblowing, anti-bribery and corruption, and economic crime.

1. Scope and Compliance

PensionBee maintains a robust set of Compliance policies that are documented and managed on a dedicated platform.

PensionBee’s Code of Conduct applies to all employees 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).

We expect any other person or persons associated or doing business for or with PensionBee that they use to abide by all applicable laws, regulations and other legal requirements in jurisdictions where they operate.

2. Workforce 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, as detailed in PensionBee Human Rights Policy.

At PensionBee we do not tolerate the use of child labour and expect our supply chain and investee companies not to use children in their operations or their value chains. PensionBee has a zero-tolerance approach to modern slavery, which is a crime and a violation of fundamental human rights. We also respect an employee’s right to leave their employment freely upon reasonable notice, and we do not tolerate forced labour or involuntary prison labour in our value chain

Fair Treatment

At PensionBee, we are committed to upholding the human rights of all employees and all those we do business with, treating them with dignity and respect.

PensionBee is an investor signatory and disclosing company of the Workforce Disclosure Initiative (WDI). We encourage all suppliers and investee companies to improve their transparency and accountability on workforce issues by disclosing under the WDI.

Paying a Living Wage

PensionBee pays all its employees at least a London Living Wage, regardless of where they are based. We do this to ensure fair and appropriate compensation for all our employees. PensionBee formalised its commitment to the Living Wage in February 2020 by becoming an accredited Living Wage Employer. 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 to ensure employees are protected from retaliation or reprisal for speaking up or lodging grievances relating to their rights as workers and working conditions. PensionBee’s grievance policy encourages employees to address concerns through several channels: direct informal feedback, supported conversations or conflict coaching for complex issues, and raising issues informally with managers.

A formal grievance procedure is in place for unresolved or serious matters, with options for appeal. Confidentiality is protected throughout, and anonymous feedback can be provided via Officevibe, a platform that enables employees to provide anonymous feedback. A formal Whistleblowing Policy, overseen by a Non-Executive Director, is also available.

3. Whistleblowing

Whistleblowing is an important activity that helps firms to learn about and resolve problems before they escalate further. Whistleblowing also helps the FCA regulate the financial services sector and information provided by whistleblowers has contributed to fines, permissions changes and other interventions.

The aim of our Whistleblowing Policy is to ensure PensionBee has a fit-for-purpose whistleblowing framework that gives our colleagues confidence about raising their concerns knowing that if they do, they will be protected from retaliation as a result of doing so. The Policy encourages employees to come forward with disclosures without fear of reprisal and that ensures a whistleblowing case is effectively dealt with.

Whistleblowing approach at PensionBee

All of us at PensionBee have a responsibility to speak up if we see or become aware of something wrong or if we have a concern that this could affect PensionBee, its employees, customers, shareholders or the general public.

We will investigate all concerns raised and, depending on the investigation’s findings, take appropriate action to address any issues identified. We will keep the person raising the concern informed when the investigation has been completed and, where appropriate and subject to any applicable laws and regulations, we will share its outcome and any follow up actions.

Whistleblowing approach at PensionBee is communicated to employees as part of the onboarding process and once annually during the mandatory company-wide Compliance test, where employees are informed of our whistleblowing policy. The full Whistleblowing Policy is easily accessible by all PensionBee employees at any time.

Whistleblowing process at PensionBee

PensionBee takes the making of reportable concerns seriously. PensionBee employees can raise their concerns internally with their manager, their manager’s manager, or a member of our People Team, if they are comfortable discussing their concerns with them. They can also report a concern anonymously via Officevibe, an online platform where they can submit anonymous feedback.

Employees can also make a disclosure to PensionBee’s whistleblowing champion, Michelle Cracknell (Non-Executive Director and Chair of the Audit and Risk Committee). The whistleblower can decide to make a report anonymously or using their full name, either electronically (via email) or by post. If the report is anonymous, PensionBee will not seek to uncover the whistleblower identity.

The whistleblowing champion will log the disclosure, assess the reported concern and escalate, if appropriate, to the Board of Directors and the Financial Conduct Authority. The whistleblowing champion will provide feedback to the whistleblower, where and as appropriate. The whistleblowing champion will consider any relevant conflicts of interest, in line with the PensionBee Conflicts of Interest Policy.

PensionBee’s whistleblowing reporting process is also available to customers, suppliers and other third parties. No whistleblowing incidents have been reported (as of December 2023).

4. Anti-Bribery and Corruption

PensionBee is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented in line with our legal obligations under the Bribery Act 2010.

PensionBee has zero-tolerance for bribery and corrupt activities, as outlined in our Anti-Bribery and Corruption Policy, which applies to all directors, officers, employees, consultants, contractors, interns, or any other person or persons associated with us (including third parties), no matter where they are located (within or outside of the UK).

The Policy strictly prohibits the giving or receiving of bribes. All employees are required to report actual, suspected or attempted bribery immediately. Reports can be made to a member of the Executive Team, including the Chief Risk Officer, or anonymously via Officevibe. Employees can also report in accordance with our Whistleblowing Policy.

Anti-Bribery and corruption approach at PensionBee

Employees are educated on bribery and anti-corruption. In fact, all PensionBee employees must complete anti-corruption, anti-bribery and economic crime training, as part of their annual Compliance test. They must complete this within a month of joining the Company and at least annually. Training is compulsory for employees at all levels, including the Board. Training is updated annually to reflect changes in legislation and best practice. Employees are required to pass a test on each unit with a minimum pass mark of 80%. Employees must also learn the rules of our gifts and hospitality policy.

PensionBee does not accept and will not make any form of facilitation payments (a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action) or kickbacks (typically made in exchange for a business favour).

PensionBee will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage. Furthermore, PensionBee will not engage in any boycott activity with a view to expressing a political opinion through its business choices.

5. Economic Crime and Money Laundering

PensionBee complies with the Economic Crime and Corporate Transparency Act 2023 and has a regulatory and legal responsibility to assist the authorities in countering the perpetration of economic crimes. Economic crimes include but are not limited to money laundering, terrorist financing and fraud. Economic crime is perpetrated by individuals and therefore this policy is closely linked to the Group’s Know Your Customer Policy. Fraud can lead to highly damaging outcomes for customers and is particularly relevant when transactions are being processed out of the PensionBee Personal Pension. Fraud risks are therefore also closely linked to the Transfer Out Policy and the Banking Policy, which cover the risks of making inaccurate payments.

All PensionBee employees are educated on what is an economic crime and how to try to prevent economic crimes occurring, including anti-money laundering practices, as part of our annual Compliance test. The course prepares all employees to recognise the stages of the money laundering cycle, be aware of the offences and penalties under anti-money laundering legislation, and fulfil their obligations in relation to customer due diligence and suspicious activity reporting. Training is mandatory for employees at all levels, including the Board, and a minimum pass mark of 80% is required to complete the training. They must complete this within a month of joining the Company and at least annually.

6. 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.

7. 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.

8. Environmental Policy

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, as detailed in PensionBee Environmental, Social & Governance (ESG) Policy.

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

Last edited: 27-06-2024