PensionBee Whistleblowing Policy

Background

Introduction and Aims

This policy sets out PensionBee's standards in relation to speaking up or 'whistleblowing' about actions or statements which are, may be, or may have been wrong, illegal, or in breach of PensionBee policies and procedures, or any applicable laws and regulations.

PensionBee views whistleblowing as an important activity that helps it surface, learn about and resolve problems before they escalate further. Whistleblowing also helps PensionBee and our various regulators to enforce legal and regulatory requirements.

This policy sets out what you should do when raising a ‘whistleblowing’ matter’, how PensionBee will respond and how PensionBee will protect you from any retaliation for speaking up.

PensionBee’s whistleblowing process exists in order to give you confidence about raising your concerns and knowing that if you do so in good faith you will be protected from retaliation as a result of doing so.

PensionBee is required to investigate a qualifying disclosure (the formal legal name for a whistleblowing disclosure, described more fully below) in the public interest even if you later ask us to withdraw it.

Anonymity and Confidentiality

You can make a whistleblowing disclosure under this policy, at your own election, either:

• anonymously (without ever revealing your identity); or
• non-anonymously (by identifying yourself either when you make the disclosure or at a later point in time in the process).

Disclosing anonymously

PensionBee will fully investigate anonymous disclosures in accordance with this policy and will not try to find out your identity. You can choose to reveal your identity at any later point if you no longer wish to remain anonymous.

You can choose to provide anonymised contact details (for example, an anonymous email address, or contact through a representative) so that PensionBee can follow up with you while keeping your identity hidden. If PensionBee does not have an effective means to communicate with you we may not be able to ask follow-up questions, progress the investigation as fully, or report back to you on its outcome.

When making a disclosure and you identify yourself

If you identify yourself, PensionBee will keep your identity strictly confidential. It will only be shared, on a need-to-know basis, with those persons directly involved in investigating your concern such as compliance, legal, senior management or the Board.

PensionBee may need to disclose your identity more widely, or may be unable to progress an investigation without doing so, where:

• we are legally required to, for example when notifying the FCA, reporting to the National Crime Agency, or notifying the Health and Safety Executive, law enforcement or a court;
• the investigation cannot proceed without your personal evidence, for example, if you are the only witness, hold evidence no one else can provide, or are the only person who can substantiate concerns such as bullying, harassment or falsified records;
• disciplinary or legal proceedings require it, the subject of such proceedings has a right to know the case against them, which may reveal the source of a disclosure, particularly where only a small number of people could have known about it; or
• there is an overriding public interest in acting, for example, an imminent risk to someone's safety or wellbeing, a safeguarding or environmental concern, or a serious risk to customers' retirement savings.

Where practicable, PensionBee will discuss this with you first and seek your agreement. If that is not possible, for example, because of a legal obligation or the rights of the person concerned, the investigation will proceed and your identity may be disclosed without your consent. PensionBee will tell you this has happened, and why, as soon as we reasonably can.

Everyone involved in handling a disclosure is under a strict duty of confidentiality; any breach will be treated as a serious disciplinary matter.

Applicable standards, definitions and concepts

Applicable standards

This policy is implemented by PensionBee in compliance with thefollowing applicable laws andstandards with respect to whistleblowing that impact PensionBee, namely:

• The UK’s Public Interest Disclosure Act 1998: this Act protects whistleblowers when making protected disclosures (see definitions below).
• The FCA’s SYSC 18: which sets out the requirements in relation to the adoption and communication of appropriate internal procedures for handling reportable concerns made by whistleblowers (which is currently a voluntary standard as regards PensionBee).
• The Employment Rights Act 2025: which amended PIDA with effect from 6 April 2026 to expressly include disclosures relating to sexual harassment as a category of qualifying disclosure, meaning that workers who report concerns about sexual harassment in the workplace are entitled to the same protections against detriment and unfair dismissal as those making any other qualifying disclosure under PIDA.

Definition of whistleblowing

The Public Interest Disclosure Act 1998 (“PIDA”), enshrines in legislation protections for employees who disclose information concerning specified categories of wrongdoing (known as a “qualifying disclosure”), made in the public interest, of information which, in the reasonable belief of the person making the disclosure, tends to show that one or more of the following (a "failure") has been, is being, or is likely to be, committed:

• a criminal offence; or
• a failure to comply with any legal obligation; or
• a miscarriage of justice; or
• the putting of the health and safety of any individual in danger; or
• damage to the environment; or
• deliberate concealment relating to any of the above

It is immaterial whether the relevant failure occurred, occurs or would occur in the United Kingdom or elsewhere, and whether the law applying to it is that of the United Kingdom or of any other country or territory.

Protection of whistleblowers

PIDA states that individuals who make qualifying disclosures of information in the public interest have the right not to suffer detriment by any act or omission of their employer because of the disclosure. PIDA protects employees in making a disclosure to their employer where the disclosure meets the requirements and is made in good faith. More information on what is protected by PIDA and how best to raise your concern is available here: Whistleblowing for employees.

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 want you to feel confident about raising any concerns you have, and to know you will be protected from any retaliation as a result of doing so.

We will investigate all concerns raised and, depending on the investigation's findings, take appropriate action to address any issues identified.

The types of concerns you should raise are matters which you reasonably believe may be or have been:

• possible or actual breaches of laws, regulations, rules or other legal requirements
• possible or actual breaches of applicable PensionBee policies
• possible actual breaches of other professional standards or actions.

These reportable concerns include but are not limited to the below categories:

• equal opportunity, diversity and respect in the workplace
• employee relations
• retaliation for speaking up
• environmental, health and safety
• financial and accounting
• misuse of assets or information
• business integrity (e.g. conflicts of interest, market abuse)
• modern slavery

Some alternative reporting paths should be noted as follows:

• Any suspicious transactions or money laundering concerns, unless circumstances described above exist, should be escalated in accordance with the PensionBee Compliance Manuals,
• Cyber security incidents e.g. receiving suspicious or 'phishing' emails should be reported in accordance with the Incident Management Policy.
• Human resources grievances, complaints or concerns should be escalated in accordance with the People Handbook (excluding Sexual Harassment).

The whistleblowing process is described in the next section.

Principal Responsibilities

PensionBee’s whistleblowing approach is communicated to employees as part of onboarding and once annually during the compliance test, where employees are informed of our whistleblowing policy:

1. PensionBee takes the making of reportable concerns seriously.
2. Employees can raise their concerns internally with their manager, their manager’s manager, or a People Team member, if they are comfortable discussing the concerns with them.
3. If an employee does not believe our internal channels can resolve the issue of concern, they should make a qualifying disclosure to the whistleblowing champion, Susan Holliday (Non-Executive Director, PensionBee Group plc). If an employee is raising a concern anonymously, they will be able to do so by contacting the whistleblowing champion via an anonymised email address set up by the person making the qualifying disclosure.

4. A qualifying disclosure is made in the public interest (i.e. not a personal grievance) in relation to:

4.1. a criminal offence; or

4.2. a failure to comply with any legal obligation; or

4.3. a miscarriage of justice; or

4.4. the putting of the health and safety of any individual in danger; or

4.5. damage to the environment; or

4.6. deliberate concealment relating to any of the above.

5. Examples of a qualifying disclosure are:

5.1. Another employee committing a criminal activity

5.2. The company breaking the law

5.3. A serious fault with the lifts that could cause employees physical harm

6. A report may be made anonymously or using full name electronically by email or phone. If employees choose to make a disclosure anonymously, PensionBee will not seek to uncover their identity (although the whistleblowing champion may invite them to come forward if they wish).
7. Impartial information is available on the government’s website: Whistleblowing for employees
8. The whistleblowing champion will log the disclosure, assess the reported concern and escalate, if appropriate, to relevant members of management, the Board of Directors and / or the Financial Conduct Authority or other external regulatory body.
9. The whistleblowing champion will provide feedback to the whistleblower, where and as appropriate.
10. The whistleblowing champion will consider any relevant conflicts of interest, in line with the PensionBee Conflicts of Interest Policy.
11. The FCA encourages whistleblowers to use the whistleblowing procedures in their own workplace, but employees can contact the FCA if they do not believe the internal procedures will work or the internal procedures have been followed but are concerned by the nature or lack of response by the firm. More information on how the FCA deals with whistleblowers is available here: Whistleblowing | FCA

Settlement agreements with workers

The ability to make a qualifying disclosure is not prevented by an individual’s contract of employment with PensionBee being terminated, which in addition to the terms of this policy is made clear in standard contracts of employment with PensionBee and in any departure agreement which make clear that nothing in such an agreement prevents a worker from making a protected disclosure.