This statement sets out XPS Pensions Group plc’s zero-tolerance stance to modern slavery and human trafficking in our organisation and our supply chain. It applies to all businesses within the XPS Group, including third party suppliers with access to XPS Group or client property, systems or data and any other parties working on behalf of XPS Group. It relates to actions and activities undertaken during the financial year 1 April 2024 to 31 March 2025.

We acknowledge our responsibility to uphold ethical standards and are committed to work to the highest professional standards to ensure compliance with all laws and regulations applicable to the organisation. Our suppliers are expected to adhere to the same high standards.

Our business

XPS Pensions Group plc is listed on the London Stock Exchange Main Market and consists of several limited company subsidiaries. As a leading pensions, investment consulting and administration firm, XPS Group specialises in the UK pensions and insurance sectors. XPS combines expertise, insight and technology to support the needs of over 1,500 pension schemes and their sponsoring employers, both on an ongoing and project basis. We provide pensions administration services for over one million members and provide advisory services to schemes and corporate sponsors in respect of schemes of all sizes, including 88 with assets over £1bn.

We have over 1900 employees based in 15 locations across the UK.

Our Purpose and Values

At XPS, our mission is to shape and support safe, robust and well-understood pension schemes and other institutions that provide long-term financial security, for the benefit of individuals and society.

Our purpose is central to everything we do. It is reflected in our values, our culture, the investment we make in our people and our commitment to being a responsible business. This commitment is evident in our client relationships, our impact on the environment, and our engagement with local communities and suppliers.

Integral to our reputation is the necessity to act ethically and with full transparency to maintain our status as a leader in our market. Our actions and behaviours are guided by our shared Values, which are key to our commitment to being a responsible business. Our Values are below, and these ensure the absence of modern slavery within our organisation. We work diligently to prevent violations of human rights and uphold ethical standards within our operations and beyond.

We are ambitious
We are agile
We are helpful
We are experts, and
We do the right thing.

Our Supply Chain

XPS is committed to the highest standards of ethical and business conduct as it relates to the procurement of goods and services. Our relationships with our third-party providers, including our contract labour, are governed by legally compliant, ethical, fair and efficient contracts. 

We maintain a stable supplier base, the majority  of whom have agreed to comply with our Supplier Code of Conduct. As a result, we are confident that they uphold the same high standards that we set for ourselves. We continuously review our supplier verification process, ensuring that material new suppliers undergo checks, including assessments of their policies and their commitment to preventing bullying, harassment, human trafficking and modern slavery. We will not award or renew business with any supplier who fails to meet these standards. 
Given the nature of our business, and the outcome of our annual risk assessment process, we believe that the risk of modern slavery and human trafficking in our supply chain is low. However, we remain vigilant and continue to monitor and assess our supply chain to prevent complacency.

Our supplier on-boarding process has been strengthened, resulting in XPS having greater control over our supply chain and adherence by our suppliers to our Supplier Code of Conduct is now a mandatory condition for doing business with XPS.
During 2024, we updated the Supplier Code of Conduct to incorporate the “Worker Protection (Amendment of Equality Act 2010) Act 2023”, reinforcing our zero-tolerance stance on sexual harassment. This ensures that our supply chain shares our commitment to creating a safe and respectful workplace, where employees have the absolute right to speak out against bullying and harassment of any kind.

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 or compulsory labour, slavery or human trafficking in the course of our business activities either in our business or in any part of our supply chain. This will be achieved through the measures outlined in the sections below:

Inclusion, Equality and Diversity

At XPS our vision is to create a vibrant workplace where difference is recognised as a strength, allowing talented individuals to flourish and achieve their highest potential. We know that talent is not determined by race, ethnicity, gender, disability, sexual orientation, age, religion, social class or background. We value the contributions that people from diverse backgrounds bring to the workplace. As an employer, XPS Group is committed to implementing employment policies and practices that seek to eliminate unlawful and unfair discrimination and fulfil our legal obligations.

Our policies and working practices promote equal opportunities and diversity, ensuring a safe working environment. These policies include:

• Inclusion and Diversity, including equal opportunities and non-discrimination in the workplace, in recruitment, training and promotion irrespective of gender, age, religion or belief, disability, sexual orientation and employment status;
• Protection from bullying and harassment;
• 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.

To drive progress in these areas, we have an Inclusion and Diversity Committee made up of representatives from across the business and the Network Chair reports to the board of XPS Group plc, ensuring that these initiatives remain a priority. The Committee was set up to develop and improve policies and practices relating to inclusion, diversity and equality and to monitor performance and make recommendations for continued improvement. 

Additionally, we have 5 employee networks: the Women’s Network, Menopause and Health Network, LGBT+ network, Disability and Neurodiversity Network and Multi-Cultural Open Network. These networks aim to further support our goal of fostering an inclusive workplace culture while addressing the needs of our diverse workforce.

These networks play a vital role in creating a workplace where everyone feels valued, supported and empowered to succeed. 

Sustainability

We have a Sustainability Committee who oversee the alignment of XPS group’s sustainable future with employee wellbeing and ensuring that XPS continues to be a great place to work. We continue to provide mental health training for our managers; we have 60 mental health allies who support colleagues. Throughout the year we actively communicate with employees, to promote their wellbeing. In 2023, we launched a monthly XPS Wellbeing Hour, encouraging employees to take an hour out to explore wellbeing topics.

Additionally, XPS operates a Vulnerable Customers Policy, which, along with annual training, provides clear guidance to all employees around vulnerabilities our customers may face, and the barriers they encounter when dealing with professional services such as ours. We strive to make our service as accessible and inclusive as possible.

Recruitment

XPS has a strong recruitment and selection policy that reflects the Group’s commitment to attracting talent with the necessary skills from diverse backgrounds. This approach helps us maintain our status as an award-winning company within the industry. To support this policy, we have implemented a robust compliance checks process, ensuring the risk of forced and compulsory labour is eliminated. 
All newly hired employees, as well as and non-employees such as agency workers, undergo thorough background vetting checks before beginning employment with us. These checks include, right to work, credit history, criminal records, terrorist affiliations and reference checks. Any areas for concern are fully investigated before employment commences. 

Precautionary measures are also in place to reduce the risk of financial coercion; these precautions include random checking of bank accounts stored in our Human Resources Information System (HRIS). 

Additionally, any third-party provider is required to submit their own Modern Slavery Policy to ensure alignment with XPS’ ethical standards.

Remuneration

XPS considers the wider economic backdrop when setting the budget for the annual salary review process for example, external benchmarking, individual contribution to the business and the consumer price index are taken into account. XPS understands how important it is to pay employees appropriately and to ensure the salary review process is fair and equitable. XPS provides a programme of wellbeing initiatives throughout the year including financial education to ensure colleagues have relevant support from experts depending on their own circumstances.  

XPS also offers a comprehensive flexible benefits programme that allows colleagues to select various products such as personal protection benefits to tax efficient cycle to work and electric car schemes. We review our remuneration practices and benchmark them against industry standard and best practice annually.

Whistleblowing

XPS has a clear, formalised Whistleblowing Policy and procedure, providing all employees with a confidential way to raise concerns about perceived wrongdoing, non-compliance with our own standards, regulatory requirements and/or the law. We have a confidential helpline, run by a third party, Navex Global, which allows employees to report concerns without fear of sanction or disadvantage. This helpline is actively promoted through the XPS intranet and posters displayed in our offices. All incidents are reported and promptly reviewed by the Board at the next available meeting, or sooner if appropriate. The XPS Audit & Risk Committee reviews the whistleblowing policy and process annually to ensure that they remain fit for purpose. 

In addition, XPS has launched ‘Safe Space’, which is an independent mailbox designed for employees to report unethical conduct, discrimination or harassment. This provides employees with another confidential avenue to raise concerns. Employees are reassured that appropriate action will be taken and are they will be kept informed on how the matter is being addressed. 

Training

We provide modern slavery training to all employees annually, to ensure proper understanding of the risks of modern slavery and human trafficking, in the context of the firm’s business and supply chains and we encourage them to identify and report any suspicious activities. We ensure the training is completed by all employees. 

Future Developments

We acknowledge the ongoing commitment required to detect and prevent modern slavery and human trafficking within XPS and our supply chain. Over the upcoming financial year, we plan to further strengthen our approach in the following areas:

• Continue to enhance our Supplier Code of Conduct to better reflect our commitments to D, E&I IED and further embed our Values within the supply chain. 
• We plan to implement a new procurement to pay system to give us greater control over suppliers and ensure that we do not engage with any that we feel may contravene with our ESG policy.
• Strictly prohibiting business relationships with any organisation found to be involved in modern slavery or human trafficking.

Our commitment

We will not use any business or organisation which is involved in this activity and will review and update this policy annually to ensure it aligns with best practices. 

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 2024. It has been approved by the Board of Directors of XPS on 27 March 2025 as reflected by the Director’s signature below. 

 

Ben Bramhall
Co-Chief Executive Officer