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Modern Slavery Statement

1. BTPSM (trading as Brightwell) – Modern Slavery Statement

BT Pension Scheme Management (BTPSM) and its subsidiary BT Pension Scheme Administration (BTPSA) trading as Brightwell 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 began trading as Brightwell for 1 April 2023 extending its service to other defined benefit pension schemes. Prior to this, BTPSM was the exclusive service provider to the BT Pension Scheme (BTPS.)

Brightwell also has a majority stake in leading pensions administration software company, Procentia which BTPSM acquired in 2019.


2. About Brightwell – Our business and our people

We aim to provide high quality services to our clients cost effectively. Our services are tailored to the needs of each individual scheme we serve. 

Our fundamental belief is that through highly capable people, modern technology and leveraging our scale we can deliver market leading performance, innovative and progressive investment and funding solutions and high-quality member administration whilst keeping overall costs significantly below average comparable benchmarks.


3. Our supply chain

We have 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.  Our Supplier Management Framework 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 Compliance including being screened against relevant sanctions and regulatory enforcement lists. 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 and ‘Modern Slavery’’.

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 third-party investment managers, to attest they are Modern Slavery Act compliant.


5. Policies and training

Our Employee Handbook outlines the expectation of employees at Brightwell 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.

a. Whistleblowing Policy

Brightwell has a Whistleblowing Policy that sets out our 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.

b. Equity, Diversity and Inclusion

Brightwell is committed to ensuring genuine equality of opportunity and respect for 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, employment status, pregnancy or parental responsibilities. We will ensure that employees are recruited, promoted, transferred and selected for training on the basis of their qualifications, skills, abilities and aptitudes and will continue to review its recruitment and employment policies and practices to ensure that they are compliant with the above objectives. 

Brightwell recognises that diversity in the workforce is a valuable asset and that embedding an inclusive culture allows us to continue to grow as a strong and innovative organisation.  We have set up an independent Equity, Diversity & Inclusion (ED&I) working group to drive our ED&I agenda and are also an active member of the Diversity Project.

c. 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.

d. 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.


6. Investments

At Brightwell, we firmly believe that integrating sustainability into the investment process contributes to better investment outcomes through long-term value creation and better management of downside risks. We implement this via the overall investment strategy and asset allocation, the design of our investment mandates and the selection and ongoing monitoring of investment managers. Given the ever-increasing regulation in this area, we recognise the importance of collaborating and innovating with investment managers on this journey.

We also use our voice, representing our clients and acting as long-term stewards to optimise investment outcomes and drive better real-world outcomes.

Our sustainable investment approach is informed by three key beliefs:

a. Long-term investment horizon – A long-term investment horizon affords both a responsibility and an advantage. It gives us the ability to look through short-term market volatility; harvest the illiquidity premium offered by private assets and reduce the cost associated with portfolio turnover. All of which we believe produces better investment outcomes for our clients.

b. ESG integration – Integrating financially material environmental, social and governance factors into asset, manager and security selection processes helps to make better informed investment decisions. We believe that in any investment process, the application of ESG factors should be:

  • integrated throughout the investment process;
  • consistent with the wider investment approach; and
  • evidenced in both internal and external reporting.

c. Stewardship – Exercising ownership rights, collaborative engagement, as well as active management of physical assets on behalf of clients can improve long-term risk adjusted returns and create sustainable long-term value.


7. 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.