Modern Slavery Statement


This statement sets out XPS Pensions Group zero-tolerance stance to modern slavery and human trafficking in our organisation and in our supply chain. This statement applies to all businesses within the Xafinity Plc group of companies including third party suppliers with access to Xafinity or client property, systems or data and any other parties working on behalf of Xafinity. It relates to actions and activities during the financial year 1 April 2018 to 31 March 2019.

We strive to work to the highest professional standards to help ensure that we comply with all laws and regulations applicable to the organisation. Our suppliers are expected to follow the same high standards.

Our Business

Xafinity Plc is a FTSE listed company and consists of a number of limited company subsidiaries. XPS Pensions Group is the largest pure pensions consultancy in the UK, specialising in pensions actuarial, investment consulting and administration.

The XPS Pensions Group business combines expertise, insight and technology to address the needs of both pension trustees and sponsoring companies for over 1,200 pension schemes and undertakes administers the pensions of over 500,000 scheme members.

We have around 900 employees based in 15 office locations across the UK.

Policy Statement

We are committed to ensuring that within our control there are no breaches appertaining to section 54 (1) of the Modern Slavery Act and we will not use or allow the use of forced, compulsory labour, slavery or human trafficking in the course of our business activities either in our supply chain or in any part of our business. This will be achieved by:

Equality and Diversity

We encourage a friendly, inclusive and supportive culture, are committed to being a fair employer and upholding the legal and human rights of our employees. Our policies and working practices promote equal opportunities and diversity and provide a safe working environment. These policies include:

  • Equal opportunities and non-discrimination in the work place, in recruitment, training and promotion irrespective of gender, age, religion or believe, disability, sexual orientation and employment status;
  • Protection from harassment or intimidation;
  • Flexible working and other family friendly policies;
  • Grievance and whistle-blowing practices and procedures;
  • Health and Safety policy and procedures to ensure we provide a healthy working environment where we take all reasonable steps to prevent injury and illness to our employees, visitors and contractors.


We only use specified, reputable employment agencies and have standard terms and conditions of business with each agency. We also request and review a copy of the agency’s modern slavery statement. Our employment procedures also ensure that we conduct appropriate checks on all staff including verification of identity, ensuring they can legally work in the United Kingdom, references, evidence of qualifications, criminal and financial checks.


We are committed to ensuring all employees and workers receive fair remuneration for the job they perform.


We encourage all of our employees to report any concerns related to the activities of the business. Our whistleblowing procedure is designed to ensure any matter raised will be investigated thoroughly, promptly and confidentially. Our compliance induction training for new employees includes a section highlighting our whistleblowing policy.


We provide training to all new employees as part of their induction process and through annual internal communication reminders to all employees in order to ensure proper understanding of the risks imposed by modern slavery and human trafficking in the context of the firm’s business and supply chains.


We have a stable list of suppliers and existing suppliers who are being contacted to confirm their positions with regard to human trafficking and slavery. We are reviewing our supplier verification process to include checks on material new suppliers including their commitment and policies regarding the prevention of human trafficking and slavery and we will not award or renew business with any supplier who fails this test.

Given the nature of our business, we believe that the risk of modern slavery and human trafficking in our supply chain is low.

Our commitment

We will not use any business or organisation which is involved in this activity and will review and update this policy annually.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending 31 March 2019.

Ben Bramhall CEO