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, unethical or in breach of PensionBee policies and procedures, or any applicable laws and regulations.

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

The 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.

Applicable standards, definitions and concepts

Applicable standards

This policy is implemented by PensionBee in compliance with the following applicable laws and standards with respect to whistleblowing that impact PensionBee, namely:

• The UK’s Public Interest Disclosure Act 1998: 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).

Definition of whistleblowing

The Public Interest Disclosure Act 1998 (“PIDA“), enshrines in legislation protections for employees who disclose information concerning specified categories of wrong doing (known as a ‘qualifying disclosure’), made in the public interest, of information which, in the reasonable belief of the worker 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 employers 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.

Where a concern has not been reported anonymously, 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, its outcome and any follow up actions.

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, or

• statements or behaviour which may be wrong, unethical or in breach of applicable laws and regulations.

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.

Some exceptions 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 Financial Crime Policy,

• Cyber security incidents e.g. receiving suspicious or ‘phishing’ emails should be reported in the incident-log channel immediately.

The whistleblowing process is described in the next section.

First line 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, Michelle Cracknell (Non-Executive Director).

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 which can be set up for this purpose.

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, either electronically (on email) or in the post. 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 the Board of Directors and the Financial Conduct Authority.

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

PensionBee includes a term in any departure agreement with a worker that makes clear that nothing in such an agreement prevents a worker from making a protected disclosure. PensionBee uses wording which has substantively the same meaning as the following:

“For the avoidance of doubt, nothing precludes [name of worker] from making a “protected disclosure” within the meaning of Part 4A (Protected Disclosures) of the Employment Rights Act 1996. This includes protected disclosures made about matters previously disclosed to another recipient.”