PensionBee UK Inclusion, Equality and Diversity Policy

PensionBee UK Inclusion, Equality and Diversity Policy

Our approach

At PensionBee, the principles of inclusion, equality and diversity align closely with our:

• vision of a world where everyone can enjoy a happy retirement;
• mission to build pension confidence;
• values of love, quality, innovation, simplicity and honesty.

Our vision, mission and values form the blueprint for everything we do. In particular, our focus on everyone and our value of love, reflect our desire for both our team and our customers, to include those who may not have been traditionally well represented within the finance industry, and improve our ability to deliver on our vision, mission and values more generally.

At PensionBee, we lead our approach with inclusion and equality, with the belief that when we’re delivering these principles in everything we do, diversity that’s reflective of industry and society will follow.

Aim

Our aim is a team where everyone can thrive.

Goals

Our goals are to provide:

• a tailored and rewarding career;
• fair and equitable access to opportunities;
• a safe, respectful and enjoyable working environment.

As well as, to:

• have a positive impact on the wider community;
• learn from others and share progress externally.

Our policy sets out in more detail our initiatives to promote each of these areas of focus.

Measuring success

Annual Culture Report - we review our team’s feedback, movement and demographics annually against our inclusion, equality and diversity approach, looking for trends and use the findings to create a report, which sets out our:

• progress against the aim and goals of our policy;
• progress against the goals set by the FCA;
• progress from the current year’s Culture Program;
• plans for responding within the next year’s Culture Program.

Our policy sets out in more detail how we measure success.

Applicable standards, definitions and concepts

Defining our values

At PensionBee our team gives high priority to our values, with more than 80 people taking part in a process of co-creation for our 10 year anniversary in 2024. Together, we defined our values:

• Love - act with care, empathy and respect.
• Quality - strive for excellence through accuracy, reliability and teamwork.
• Innovation - lead with vision, embrace change and create a positive impact
• Simplicity - provide clarity in a world of complexity
• Honesty - communicate openly, be authentic and act with integrity

The principles of inclusion, equality and diversity demonstrate love for our team and our customers; facilitate the honesty we need to drive innovation; and enable us to attract, develop and retain a quality team, in turn supporting our broader vision.

Defining inclusion, equality and diversity

Inclusion - means feeling included, as opposed to excluded. It recognises that we all thrive in a safe, respectful and enjoyable working environment that supports our individual needs, and values our development, so that everyone can be successful as their authentic self. This includes both those traditionally underrepresented within the finance industry, as well as those feeling less included within traditional diversity initiatives.

Equality - means treating everyone fairly. Sometimes this means treating everyone with the same approach; such as when making hiring, performance, promotion, pay and disciplinary decisions using consistent, evidence or skills-based criteria. Sometimes it means treating people differently, to offer equal access to opportunities; such as when providing reasonable adjustments or flexible working arrangements.

Diversity - means respecting and valuing our differences, whether these be related to personal demographics, beliefs, circumstances or characteristics. It’s about simultaneously recognising our equal worth and commonality as humans, as well as the fact we all have unique needs, skills, and qualities to contribute based on our experiences.

Applicable legal standards

The law is clear:

• We must not discriminate, directly, or indirectly against anyone on the basis of a protected characteristic, such as age, disability, gender reassignment, marriage or civil partnership, pregnancy or maternity, race, nationality, ethnic, or national origin, religion or belief, sex or sexual orientation (Equality Act 2010).
• We have a duty of care to provide a safe working environment, including protection from discrimination, harassment and bullying (Protection from Harassment Act 1997).
• With a specific additional duty to take reasonable steps to prevent sexual harassment (Worker Protection (Amendment of Equality Act 2010) Act 2023)).
• We must make reasonable adjustments to support people with disabilities to overcome barriers to finding, and staying in employment (Equality Act 2010).
• As well as, give serious consideration, from day one, to any flexible working requests that enable people to balance work and personal responsibilities (Flexible Working (Amendment) Regulations 2023)).
• We’re also required to report our gender pay gap once we exceed 250 employees (Equality Act 2010 (Gender Pay Gap Information) Regulations 2017)), and new guidance has been published on ethnicity pay gap reporting, with a possibility of disability pay gap reporting to follow soon.

Failure to comply with the above, alongside creating a non-inclusive working environment, may result in costly employment tribunals with both reputational and financial risks attached, as well as court orders and fines from the Equality and Human Rights Commission (EHRC) for failure to follow gender pay gap reporting legislation.

Applicable regulatory standards (‘FCA’)

To drive change in the industry, the Financial Conduct Authority (‘FCA’) has set specific requirements for publicly listed companies. These are to:

• Report on gender and ethnicity representation at Board and Executive level in a standardised format using the tables provided.
• Provide an explanation of the company’s approach to collecting the data used for making the disclosures.

• Report on a comply, or explain basis in the company’s annual report and financial statements whether the company has met the following ‘FCA Targets’ on its chosen reference date within the accounting period:

  • at least 40% of individuals on the Board of Directors are women;
  • one senior Board position is held by a woman (Chair, CEO, SID or CFO);
  • one Board member is from an Asian/Black/Mixed/Multiple/Other ethnic background.

• Consider a wide range of diversity aspects including gender, age, ethnicity, disability, socio-economic status and sexual orientation.

Our policy

In order to reach our five goals, our policy is to provide management structures and initiatives such as the following.

1. A tailored and rewarding career

We want to tailor work to meet individual needs, as much as is reasonably possible, recognising the value this brings to creating an environment where everyone can thrive.

We aim to achieve this by creating plentiful opportunities for personal growth and development, through supportive management and feedback practices, personal development budgets, our Bee Connected mentoring program, and prioritising internal hiring where possible and appropriate.

We are committed to providing supportive adjustment to overcome barriers to thriving through tools such as reasonable adjustments, flexible working requests, and wellbeing action plans. As well as, offering a support hub of external resources in our People Handbook covering a variety of personal issues ranging from divorce, domestic abuse, and menopause to fertility struggles, gender transition and becoming a carer.

We aim to provide a rewarding and inclusive compensation and benefits package which is transparent, regularly benchmarked and covers a range of provisions for differing needs such as paid time off for carers, disability leave and gender inclusive paid parental leave.

2. Fair and equitable access to opportunities

We believe in the importance of clear, and consistently applied policies, to ensure opportunities at PensionBee are given free from bias and based on skills-based evidence and criteria.

We do this through clear, consistent pay and performance policies. For example, we use a skills and evidenced based approach to reviewing performance annually, with all promotion decisions based on successful completion of clear Bee Promoted Goals. Managers are required to share Bee Promoted Goals for consistency, and senior, or rapid promotions must be approved by the Promotions Panel. We also run calibration reporting of performance scores by manager, department, gender, ethnicity and social mobility, and discuss significant anomalies in trends with managers.

We have a clearly defined approach to remuneration with our salary ranges shared transparently internally, and externally on job adverts. Salary increases and end of year bonuses are linked to performance reviews and must go through an approval process for consistency, and we take steps to monitor both our gender and ethnicity pay gaps internally.

Alongside the above, we also ensure clear and consistent hiring policies. For internal hiring, when a permanent role becomes newly available at PensionBee for which current employees are qualified, we aim to follow certain guidelines that enable a degree of consistency and fairness, although hiring for each role may require a slightly different process. To reduce biases as much as possible, we’ve made the majority of the process anonymous. However, certain roles may require a presentation or interview as part of their tasks. The structure is held to the same standards and expectations for all candidates; multiple assessors will be involved and decisions will be solely based on how well the candidates do on the tasks using a scoring system.

Several processes are also in place to ensure fair external hiring procedures. The first screening of applications is normally anonymised. From there, the hiring process must have at least two stages, and more than one person should be involved in decision making. It’s strongly recommended that one stage is a task-based assessment which simulates the work the candidate would be doing and can be anonymised to reduce bias. All hiring decisions should be recorded and where practicable details given for the reasons behind decisions should be included for candidates advancing beyond any anonymous stage to the extent necessary to demonstrate unbiased hiring procedures. Where recruiters are used, they should be briefed on the importance of inclusion, equality and diversity to PensionBee.

3. A safe, respectful and enjoyable working environment

Everyone thrives when our working environment aligns with our values.

We aim to ensure this through a program of regular training and events to build awareness, understanding and connection. Such as our ‘Hive & Thrive’ program of executive sponsored events, regular socials and Bee A Leader manager training covering topics relevant to inclusion, equality and diversity. As well as, annual training through our compliance test, reminding our team of their rights and responsibilities, and clear guidance set out in our People Handbook.

We also work to consistently uphold our culture for both new and existing colleagues. We aim to ensure that all new joiners understand the importance of our values through values based interview questions, and a culture based interview for senior hires. New Bees take part in an induction session on our values, culture and approach to inclusion, equality and diversity, and are required to complete our most recent annual compliance test within their first few weeks of joining.

We encourage a culture where people feel comfortable to speak up, and informally feedback to each other, or their manager when they see, or experience something that doesn’t feel right. We operate a formal Whistleblowing Policy and grievance procedures, where an informal approach is no longer appropriate. We offer an anonymous feedback tool year round, which comes through directly to our CEO, COO, and senior People and Culture team members and the opportunity to provide anonymous feedback through our Annual Engagement Survey. We use the results of this survey to understand the scale of unreported non-inclusive workplace behaviour, as well as people’s comfort reporting this behaviour to their manager, and the efficacy of any support they received.

We have a zero-tolerance approach to bullying, harassment, victimisation and discrimination against colleagues, customers and suppliers or any other persons in the course of an individual’s employment by PensionBee or otherwise in the conduct of PensionBee’s business. Any reports of these acts will be investigated as misconduct following formal investigation and disciplinary procedures and appropriate action will be taken should a complaint be upheld. This process includes case by case review from our People Committee, and may also include internal and/or external legal advice. Particularly serious complaints or repeated instances of unacceptable conduct by individual members of the team could amount to gross misconduct and lead to dismissal without notice.

We take action to protect our team from bullying, harassment or discrimination by any third parties in the course of their employment with us. Nobody should have to tolerate abuse, even if it’s from a customer or supplier. More information is available in our public Abusive Behaviour Policy.

4. A positive impact on the wider community

In order to achieve our vision of a world where everyone can enjoy a happy retirement, we need to listen to and engage with the wider communities in which we operate, and play our part in influencing positive change based on their needs.

We aim to achieve this by listening to, and amplifying community voices through initiatives run by our ESG team such as surveys and focus groups and using the insights gathered to feed into public campaigns to raise awareness about consumer needs and experiences to make change.

As well as taking part in volunteering and other outreach work we offer our team one paid volunteering day per year to dedicate to a cause relevant to PensionBee, and aim to take part in annual events promoting the pensions industry to local school children.

5. Learn from others and share progress externally

We recognise the importance of working together to build change, we believe that transparency is fundamental to driving better standards.

We’re part of a variety of networking groups and collaboratorions, and our Culture team aim to attend a variety of external training annually to share best practice and learn from others.

We’ve also signed up to a variety of commitments, charters and pledges which we review annually. We’re a Level 2 Disability Confident Employer as part of the Governments Disability Confident Employer Scheme. As well as an Accredited Living Wage Employer.

We commit to voluntary disclosure on numerous frameworks such as the Workforce Disclosure Initiative (WDI), as well as the Sustainability Accounting Standards Board (SASB) and Global Reporting Initiative (GRI).

We’re also committed to sharing our policies transparently wherever possible such as through the ABI Making Flexible Work Charter, ABI Transparent Parental Leave and Pay Initiative and publicly committing to the aims, goals, and terms of this policy.

Measuring success

Annual Culture Report

At the end of each year we review our team’s feedback, movement and demographics against our inclusion, equality and diversity approach to look for trends.

We use this data to create a report which we publish internally. In this report we set out:

• progress against the aim and goals of our inclusion, equality and diversity approach;
• progress against the goals set by the FCA;
• progress from the current year’s Culture Program;
• plans for responding within the next year’s Culture Program.

Some of the high-level metrics we consider in relation to our aim are as follows:

*Dependent on meeting our anonymity threshold of 10

**Dependent on reliable data set availability

Note on demographic data

We believe that equally talented people exist across all demographics, and that demographics don’t define someone’s potential or capability. Therefore, we use our demographic data as a metric of success, as we feel that when we’re focused on our inclusion and equality goals, with time, our team will represent the demographics of the areas where we hire across all levels of the company.

We benchmark ourselves to industry and census data, where available, to give us an idea of where to focus our approach. If we’re below industry averages, this could be more indicative of a PensionBee specific issue for us to review and plan for. If we’re at, or above industry averages, but below census levels, this could be more indicative of a societal, or structural barrier which we can still aim to collectively, and gradually, address.

For the most part what we measure is related directly, or indirectly, to protected characteristics defined within the Equality Act 2010. One exception to this is social mobility, which we measure using occupation of the main household earner at age 14. We include this as we agree with the Government-backed Social Mobility Commission, that the circumstances of someone’s birth shouldn’t determine their outcomes in life.

We ask our team to review their demographic data upon joining, and annually thereafter, within their HR portal. They have access to their data at all times and can edit or delete it whenever they wish to. Data sharing is optional. We provide transparent information on how data will be stored and used. We ask for explicit consent to general reporting and ethnicity pay gap reporting separately.

Note on Annual Engagement Survey

We ask everyone to complete an anonymous annual survey to answer questions related to feeling:

• Engaged - with our values, recommending us, and staying with us;
• Included - through a sense of belonging and ability to succeed as yourself;
• Equal - based on our inclusion, equality and diversity initiatives and goals;
• Confident - in management, and management process;
• Safe - about the scale of non-inclusive workplace behaviours and resolution support;
• Supported - with the pace of work and wellbeing;
• Connected - to your immediate team, and the wider company;
• Heard - on feedback and survey responses;
• Valued - through remuneration and progression.

The questions are predominately rated on a 5 point scale with space to provide detailed written feedback. We pay particular attention to our strongest scoring areas, as well as any questions which fall below our ‘area of focus’ threshold of 3.75 out of 5, and general written feedback themes.

Culture Program

Each year we use our Annual Engagement Survey and Culture Report to identify areas of focus and develop projects to address these priorities. Examples of previous Culture Projects include the development of our Culture Code and People Committee, our Bee Connected! mentoring program and the launch of our ‘Hive & Thrive’ events.

Board and Executive Management

Aims

PensionBee’s approach to Board and Executive Management inclusion, equality and diversity aligns with our wider vision of a world where everyone can enjoy a happy retirement, the achievement of which is underpinned by our Values.

The Company’s aims for Board and Executive Management composition mirror that of the wider business, namely, to build a team where everyone can thrive.

Policy Statement

PensionBee’s Board is committed to promoting inclusion, equality and diversity in the boardroom and aims to meet industry targets and recommendations wherever possible. The selection of candidates to join the Board will continue to be based on merit and the appointee’s ability to contribute to the Board’s effectiveness.

The Board, with the support of the Nomination Committee, will continue to develop its succession plans and provide oversight of Executive Management succession arrangements, a key factor of which will be ensuring that it seeks to achieve the Company’s goals concerning inclusion, equality and diversity.

Recruitment Approach

For Board and Executive Management appointments, we will seek a diverse range (across multiple criteria) of credible, qualified candidates for both non-executive and executive roles. Specifically, where appropriate, we will consider candidates for appointment as non-executive directors from a broader pool including those with little or no prior publicly listed company board experience. These same criteria would be required in circumstances where an executive search firm is engaged. We will only engage with firms that have adopted the Voluntary Code of Conduct for Executive Search Firms from the Department for Business & Trade and Department for Business, Energy & Industrial Strategy in respect of diversity.

Board and Committee Review and Responsibilities

The Board, supported by the Nomination Committee, is also committed to:

• Ensuring that the Board and its committees have a good balance of skills, experience, knowledge, perspective and varied backgrounds.
• Ensuring that Board appointments consider a wide pool of candidates with an array of experience and backgrounds including all aspects of diversity while not compromising on the calibre of candidates for appointment consideration.
• Ensuring the development of a diverse pipeline for director succession.

The Nomination Committee will report annually on Board and Executive Management diversity, including progress against the FCA Targets, within the Corporate Governance Section of the Company’s Annual Report and Financial Statements.

Review of the Policy

The Board and Nomination Committee will keep this Policy under review to ensure its effectiveness and alignment with best practice and the requirements of the UK Corporate Governance Code and relevant legislation. The Nomination Committee reviews the Policy annually with any changes recommended to the Board.

Last edited: 20-02-2025