1. BTPSM - Modern Slavery Statement

BT Pension Scheme Management (BTPSM) and its subsidiary BT Pension Scheme Administration (BTPSA) have a zero-tolerance approach to modern slavery. We are fully committed to preventing slavery and human trafficking in any of our business dealings and endeavour to uphold high ethical principles and to respect human rights.
Our objective is to ensure that there is no modern slavery or human trafficking in any of our business dealings.
We are committed to complying with all aspects of the Modern Slavery Act 2015.
BTPSM has undergone a period of business transformation with a new CEO appointed in September 2018 and a new Chair appointed in February 2019. A number of key appointments have also been made during 2019 & 2020 to enhance our business practices and operations. We are committed to continue to look at ways we can further improve these on an ongoing basis.

2. About BTPSM – our business and our people

The BT Pension Scheme is the largest private sector pension scheme in the UK, with approximately 280,000 members and assets of c.£57bn. It is a defined benefit scheme for employees, former employees and dependants of BT plc and some of its associated companies.
The Trustee Board has delegated responsibility for day-to-day management of the Scheme to BTPSM. BTPSM is the primary service provider to BTPS. BTPSM provides fiduciary management services, member services, operational, and secretariat services to BTPSM. BTPSM is also the investment advisor to the Scheme.
BTPSM is also required to ensure that the Trustee is compliant with all applicable laws and the Scheme rules and can properly exercise its powers and duties.
We employ c.230 people across two sites: London and Chesterfield. The London office employs c.70 people and there are c.160 people in Chesterfield which is home to BTPSA which has responsibility for member services.

3. Our supply chains

BTPSM has outsourced certain functions to services providers and in some cases this involves employees of service providers working onsite in our offices. We also purchase a variety of products including stationery, IT hardware and office supplies. Like many of our peers, our supply chain is large and complex with multiple layers.
High level analysis of our supply chain suggests that as most of our suppliers are UK based and provide professional services, risk of modern slavery is low.
We ensure that we engage only reputable contractors and suppliers who adhere to the relevant regulations and legislation in the provision of their goods and services. A new Supplier Management Framework has been designed and implemented which provides oversight of the suppliers conduct.

4. Due diligence and risk assessment

As part of our commitment to eliminating modern slavery in our supply chains we undertake initial and ongoing checking of suppliers.
New suppliers are subject to due diligence from Finance and Risk & Compliance including being screened against relevant sanctions and regulatory enforcement lists. Risk & Compliance also reviews any adverse media results as part of this check. As part of the RFP ‘Request for Price’ process we have built in a request for potential suppliers to provide copies of their ‘Code of Conduct’.
Where suppliers are based in countries which are deemed to be high risk as per our Anti-Money Laundering, Fraud Prevention and the Avoidance of Terrorist Financing Policy, enhanced due diligence (EDD) is carried out. This may include, for example, a visit to the 3rd party supplier premises.
In addition to initial due diligence we also conduct ongoing due diligence through annual reviews whereby we require our suppliers, including our investment managers, to attest they are Modern Slavery Act compliant. The results from this are presented to the BTPS Audit Committee.

5. Policies and training

Our Employee Handbook outlines the expectation of employees at BTPSM to treat everyone we work with fairly and with dignity and respect on a day to day basis. We are currently developing a clearly stated purpose alongside an articulation of our values and the behaviours we expect from our employees.

1. a. Code of Ethics

   BTPSM’s Code of Ethics (“CoE”) sets out certain minimum expectations that BTPSM has for all employees, partners, consultants or contractors (‘employees’). Employees are expected to conduct the firm's business in full compliance with both the letter and the spirit of the law and any other policies and procedures that may be applicable to them. We are currently reviewing the CoE to align with our purpose, values and behaviours.

2. b. Whistleblowing Policy

   BTPSM has a Whistleblowing Policy that sets out our l procedures and guidance on this subject. We are committed to conducting our business activities with the highest standards of honesty and integrity, observing all applicable laws and regulations. Failure to achieve these standards is regarded as a serious matter, and we expect all our employees to maintain the same standards in their work and to actively support BTPSM’s control framework.
   As part of this commitment, we support and promote open communications and a culture in which employees are encouraged and empowered to raise legitimate concerns about the organisation and its operations. This policy explains the different ways in which employees can raise legitimate concerns they may have and the arrangements in place to ensure that they will be treated in confidence and will be properly escalated and evaluated, with appropriate actions taken.

3. c. Equal opportunity and diversity

   BTPSM is committed to ensuring genuine equality of opportunity and respect to all staff. We are committed to promoting fairness and equality throughout the employment lifecycle and ensuring that no job applicant, employee or worker receives less favourable treatment either directly or indirectly, on the grounds of gender, disability, race, age, marital status, religion or faith, sexual orientation, pregnancy or parental responsibilities. In addition, BTPSM does not discriminate against part-time or fixed-term workers in relation to their terms and conditions of employment and/or benefits. The Company will ensure that employees are recruited, promoted, transferred and selected for training on the basis of the qualifications, skills, abilities and aptitudes and will continue to review its recruitment and employment policies and practices ensuring they are compliant with the above objectives.
   BTPSM recognises that diversity in the workforce is one of our greatest assets and that an inclusive culture allows us to continue to grow as a strong and innovative organisation.

4. d. Employee Assistance Programme

   All employees and any live-in family members (including spouse, partner, parent, brother, sister and any other legal dependant under the age of 21 years in full time education) have access to a confidential, personal support line, which provides information and guidance on personal and practical matters. This confidential service is available 24 hours a day, 365 days a year.

5. e. Training

   A copy of this Modern Slavery Statement will be provided to all members of staff, and will be included in all new staff joiner packs.
   We intend to introduce more detailed training for all staff who procure services.

6. Investments

BTPS has a long history of being a responsible investor and was a founding signatory of the Principles for Responsible Investment (PRI) in 2006.

The Trustee of the Scheme has articulated its commitment to this with the following responsible investment mission statement: “As a responsible investor we will best manage the Scheme’s assets by seeking the optimal long-term risk-adjusted return while limiting outcomes which may harm our beneficiaries shared interests.”

The implications of this statement in terms of governance, investment strategy, portfolio management and reporting are set out in our Responsible Investment Policy, which can be found in this document.

Our responsible investment strategy is based around three core areas:

1. 1. Understanding the risks and opportunities that may face the Scheme because of its long-term investment horizon.
2. 2. Integrating financially material environmental, social and governance (ESG) factors into the Scheme’s investment process, including in the design of investment mandates, new manager searches and ongoing monitoring of managers.
3. 3. Ensuring that the Scheme is delivering long-term value through responsible ownership. The Scheme is committed to be a responsible steward of its assets, including engaging with the companies in which it owns shares to hold management to account and ensure companies consider long term risks and opportunities, including those relating to environmental, social and governance matters, that contribute to long-term, sustainable value. The Scheme also exercises its voting rights at annual meetings on key governance matters such as executive pay. The majority of the Scheme’s stewardship activities are undertaken by Hermes EOS, one of the world’s foremost providers of collaborative stewardship services. More detail on the Scheme’s engagement and proxy voting activity through Hermes EOS, including a record of voting decisions, can be found in this document.

The Scheme actively considers other factors affecting long-term value, as part of its commitments to responsible investment and stewardship. We ensure, where appropriate, that new and existing managers are properly integrating responsible investment into their investment processes.

This means consideration is given to both risks and opportunities relating to ESG factors in most of the Scheme’s active and passive mandates. We influence the content of Hermes EOS’s annually-refreshed Engagement Plan, which guides its engagement with companies on a wide range of topics, such as natural resource use, waste and packaging, human rights, bribery and corruption, business strategy and purpose and executive pay. In 2020, Hermes EOS engaged with 1245 companies to promote positive change on these issues and many more.

Finally, as climate change is one of the biggest risks posed to the Scheme, in late 2020 the Scheme Trustees agreed on a long-term climate change goal, Net Zero 2035, to address risks posed to the Scheme by climate change and for the Scheme to play a role in financing the journey to a net zero global emissions world. For more information please visit the ‘About us’ section of btps.co.uk

Approval

This Modern Slavery Statement was approved by the BTPSM Board and will be reviewed and updated annually in line with the Modern Slavery Act 2015.