Modern slavery

Our commitment

Modern slavery is a serious crime and a violation of fundamental human rights. We have a zero-tolerance approach to modern slavery and are committed to taking effective steps to prevent modern slavery within our supply chain and business. We ensure that  Smart Pension Limited and all members of the Smart Group act ethically and with integrity in all of our dealings and relationships by implementing effective and transparent systems and controls. We maintain the same standard for our suppliers, contractors and other business partners.

We have not identified any instances of modern slavery in our business or supply chain in the past 12 months.

Organisational structure 

We are a technology company providing our Keystone Platform to financial institutions for the management of retirement savings, as well as being the funder for the Smart Pension Master Trust which is one of the largest auto enrolment/workplace pension master trusts in the UK. 

We have offices in the UK, USA, Poland, Spain and Dubai employing over 350 employees.

Supply chain and due diligence

Our zero-tolerance approach to modern slavery is communicated to suppliers, contractors, third parties and business partners at the outset of our business relationship with them as part of our supplier due diligence and onboarding process.

We expect our suppliers to conduct their affairs in an ethical way including avoidance of modern slavery. Due diligence according to the materiality and nature of the service provided is carried out as part of our supplier onboarding process governed by our Procurement Operating Policy. 

As part of the onboarding process, suppliers of goods and services  are required to confirm that they: 

• Comply with legal obligations, in relation to modern slavery.
• Are committed to making sure that there is no modern slavery taking place in their business, or in any of their supply chains.

Policies

We have a full range of policies in support of our global compliance activities. The following policies directly support our commitment to preventing modern slavery: 

• Anti-Modern Slavery Policy
• Procurement Operating Policy
• Whistleblowing Policy
• General Code of Conduct
• Risk Management Framework

Risk assessment and management

We assess and manage the risk of modern slavery through our risk management framework including in relation to our own employment practices and those of our third-party suppliers and partners.

Training and awareness

We provide training on preventing modern slavery to all new employees including contractors. This training is repeated on an annual basis. All employees follow our code of conduct requiring them to behave ethically at all times. We maintain an anonymous third-party whistleblowing service and encourage employees to raise any concerns through this or internal channels.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and approved by the Group Risk and Compliance Committee on 25 November 2025 and signed by the Director of Risk & Assurance on behalf of the Board of Directors. For more information please contact us.