This statement is made on behalf of Railpen Limited (“Railpen”) and Railway Pension Investments Limited (“RPIL”) pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 March 2026. This statement will be published on Railpen’s website and uploaded to the UK Modern Slavery Statement Registry.
This statement was reviewed and approved by the Boards of Railpen and RPIL on 10 June 2026 and is signed by our CEO Andy Bord.
Introduction
Modern slavery – including forced labour, servitude, and human trafficking – is a serious crime and a fundamental violation of human rights. It deprives individuals of their freedom through exploitation for personal or commercial gain.
Railpen has zero tolerance for any activity defined as modern slavery or human trafficking in any form. We are committed to conducting our business responsibly, ethically and with integrity, and to working to prevent modern slavery within our operations and, where we have influence, across our supply chains and investments. Transparency and accountability are central to our approach, and we expect the same high standards from our suppliers, contractors, partners and investee companies.
About Railpen
Railpen’s purpose is to secure our members’ future. We manage over £34bn in assets for more than 350,000 members, delivering pension administration and investment services across DB, DC, and hybrid schemes, including the Railways Pension Scheme. Everything we do as an organisation, our culture, values, operations, policies and governance, supports us in our purpose to secure our members’ future.
Built on heritage. Since 1965, we have evolved from the British Rail Pension Scheme office to support the changing needs of the rail industry and its members.
Focused on better outcomes. Operating on behalf of our Trustee, we prioritise members’ interests in all aspects, from scheme management to investment decisions and aim to maximise long-term savings value.
Agile and innovative. Our integrity and member-first mindset enables us to work with policymakers and industry leaders to support sustainable pension policy and long‑term value creation.
Different from the norm. All profits are reinvested into paying pensions securely and sustainably, embracing long-term investments that benefit communities, promote innovation, and strengthen the UK economy.
Railpen is a subsidiary of Railways Pension Trustee Company Limited (“the Trustee”), which is the corporate trustee of the principal UK railways industry-wide pension schemes. Railpen provides a full range of pension services, including pension administration, investment management, fiduciary and trustee support and advisory services, for the railway pension schemes.
The Trustee wholly owns Railway Pension Investments Limited (“RPIL”), a company authorised by the Financial Conduct Authority (“the FCA”) to carry out investment management and related activities on behalf of the Trustee. RPIL, which currently manages approximately £34bn of scheme assets for the Trustee, does not employ its own employees; colleagues, and other resources, are procured from Railpen.
RPIL, its subsidiaries and all entities associated with the Trustee, must use Railpen’s centralised procurement and recruitment policies and processes, which take into account modern slavery risk.
Our policies and processes
Our policies and processes are designed to ensure effective risk assessment, including in relation to slavery and human trafficking risks.
We have implemented policies and procedures, designed to mitigate the risk of modern slavery, including:
A Modern Slavery Policy
Recruitment Policy – ensuring fair and equitable recruitment, fair pay, and appropriate screening.
A Code of Conduct for our colleagues – setting clear expectations.
Whistleblowing Policy – enabling concerns to be raised confidentially and without fear of retaliation.
Procurement and Supplier Ongoing Due Diligence Policies – setting robust expectations regarding operational standards and ethical behaviour.
Screening processes for listed equity investments, and due diligence (incorporating modern slavery) within other asset classes, supporting us to appropriately assess and address any concerns within our investment business.
While the inherent risk of modern slavery within our workforce is assessed as low, these controls form part of a broader culture that encourages ethical behaviour, vigilance and the escalation of concerns.
These policies and processes are reviewed regularly and are communicated to employees and relevant third parties.
Our people
Railpen has a strong people‑centric culture, underpinned by clear values, robust recruitment practices, comprehensive training and wellbeing support.
In the last year 100% of our colleagues have completed training on modern slavery. Our network of Mental Health First Aiders, alongside our holistic range of health and wellbeing support programmes provide support to colleagues across the business, both face-to-face and online. In addition to this, we also have a confidential 24-hour Employee Assistance Programme.
We comply with all applicable employment legislation relating to colleague terms and conditions, including payroll, and we invest in supporting the health and wellbeing of our colleagues.
Fair Pay
We’re committed to building a resilient business and a secure environment for our people, working together to secure our members’ future. We review the remuneration paid to each colleague across the business annually, ensuring all colleagues continue to receive fair remuneration for the job they perform, compared to the market.
The ‘Railpen Living Wage’, introduced in 2021, is reviewed annually and guarantees that the minimum salary we pay remains ahead of the National Living Wage.
Recruitment
Through our Recruitment Policy we implement fair, transparent and robust recruitment processes. We ensure that our recruitment agencies adhere to these standards through regular meetings where practices and compliance are reviewed and the recruitment agencies engaged by Railpen are vetted by our Procurement team. All agencies must agree to Railpen's terms of business, thereby complying with all applicable laws related to slavery, servitude, forced or compulsory labour, or human trafficking, including the Modern Slavery Act 2015, for both colleagues and contingent workers.
Right-to-work checks are performed before agencies submit candidates to Railpen. Candidates are also vetted by our third-party partner following an offer. Additionally, the Talent Acquisition Team validates the right to work for candidates applying directly to Railpen before progressing them.
Training and awareness
We deliver communication and training to colleagues across Railpen to raise awareness of key policies, including:
Mandatory Anti-Financial Crime training, updated in 2025 to include content on modern slavery. This update reinforces awareness that proceeds of crime may derive from exploitation. The training supports colleagues in identifying potential red flags, recognising indicators of suspicious activity, and understanding Railpen’s due diligence and reporting processes.
A voluntary standalone modern slavery awareness module has been made available to employees to promote broader understanding across the organisation.
Information on modern slavery and the modern slavery policy is included within the induction process for new joiners. In addition, all colleagues are required to complete mandatory whistleblowing training as part of the annual Code of Conduct training, ensuring that clear reporting channels and protections, including whistleblowing routes for modern slavery concerns, are understood across the organisation.
Our supply chain, onboarding and ongoing due diligence
Our supply chain is predominantly UK-based and service-focused. However, we recognise that modern slavery risks can arise in any sector and geographical location. We therefore apply a structured, risk-based approach to supplier due diligence and oversight.
Our supply chain primarily comprises third-party providers across the following categories:
Communications and IT equipment services
Temporary/Agency staff
Various professional services
Office equipment and supplies
Utilities
Facilities management services
Our supply chains are predominantly straightforward, with limited tiering and minimal exposure to manufactured or processed goods from jurisdictions typically assessed as high risk. Any potential exposure identified in any of the categories, as mentioned, is managed with a risk-based approach.
Procurement, onboarding and ongoing supplier management
We operate a formal procurement policy and clear due diligence framework, alongside a robust supplier onboarding framework, to ensure all third-party providers adhere to our code of conduct, ethical standards and legal obligations.
Our contracts provide us with specific adherence to the Modern Slavery Act 2015 and the right to audit suppliers or undertake on-site assessments, dependent on the nature of the goods or services being provided and in the industry sector in which the supplier operates. If an audit reveals modern slavery risks, this triggers escalation, further investigation and ultimately could lead to the termination of the supplier’s contract.
We encourage anyone, including colleagues, subcontractors, suppliers and customers to report, in good faith, any issue or concerns about potential unethical business practices, such as fraud and bribery or slavery and human trafficking through our confidential whistle-blowing procedure.
During 2025, the Supplier Ongoing Due Diligence policy and process was rolled out, including:
Scheduled supplier assurance against supplier performance and risk awareness.
Specific and ongoing due diligence questionnaires are now being rolled out across all suppliers across Railpen with implementation over the course of 2026.
To date, we have not identified any instances of modern slavery within our own operations. Should any such instances be identified, we are committed to taking prompt, appropriate and proportionate action, including escalation, remediation and, where necessary, termination of relationships.
We continue to develop our approach to measuring the effectiveness of the steps we take to address modern slavery risk. This includes:
monitoring supplier compliance through onboarding and review processes
reviewing reported concerns or incidents
periodic reviews of relevant policies and procedures
Employees involved in procurement, supplier management, the People Team and operational oversight, receive information appropriate to their roles, to enable them to identify and escalate potential modern slavery risks
Together, these measures support our ability to identify potential modern slavery risks early, ensure appropriate escalation where required, and continuously improve the effectiveness of our controls.
Our investment business
Railpen invests across a broad spectrum of assets, including public and private markets and real assets, in the UK and globally. We expect our portfolio companies to operate within the parameters of widely accepted business practices, such as the Ten Principles of the UN Global Compact (UNGC). This includes Principle 4 of the UNGC: the elimination of all forms of forced and compulsory labour.
From an investment perspective, the way companies treat their people, supply chain and wider stakeholders can have a significant impact on their operational performance. Modern slavery is a system-wide risk and can be financially material due to costs incurred as a result of reputational damage, trade sanctions, and reduced supply chain resilience.
We screen our listed equities portfolio annually to identify companies involved in severe governance and/or conduct controversies, including cases of modern slavery. In 2024, we enhanced the data used in this process to better identify companies that may be highly exposed to modern slavery risks. This includes factors such as previous involvement in controversies, sector, location of operations, and key commodities used in supply chains. Where concerns are identified, our Sustainable Ownership team requests engagement with companies to discuss ongoing issues and areas for improvement. On an exceptional basis, we will exclude companies from our listed equities portfolios for severe governance and conduct controversies, where concerns have not been adequately addressed.
We are working to incorporate human rights risks, including modern slavery, within due diligence processes for asset classes beyond listed equities. Cross-departmental discussions on this topic can facilitate progress, as described below.
As an investor in real assets, including new property developments, we understand the prevalence of modern slavery within the construction sector. We continue to include clauses requiring compliance with the Modern Slavery Act 2015 in construction contracts for our property investments. [1]
Case study: Managing modern slavery risk in construction
In 2025, we applied a multi-tiered social auditing approach to help us identify and manage modern slavery risks at Railpen’s office-led, mixed-use 180,000sqft development, Mill Yard in Cambridge.
Tier 1 contractors underwent the Workforce Assured accreditation, assessing employment practices both on-site and throughout their supply chains. Topics explored included worker onboarding, subcontractor management, and incident reporting processes. Where areas for improvement were identified, contractors strengthened their procedures to enhance protections for workers.
Findings were logged in a risk tracker and shared with the development manager to support transparency, continuous improvement, and remediation (if required).
In alignment with the UK Independent Anti-Slavery Commissioner Office’s recommendations for the finance sector, we recognise that combining our expertise and voice with peer investors can enable more effective engagement with portfolio companies. [2] This is particularly the case for system-wide risks such as modern slavery. We remain a member of two investor-led initiatives: the CCLA’s ‘Find it, Fix it, Prevent it’ coalition and Rathbones-led ‘Votes Against Slavery’.
As a member of ‘Find it Fix it Prevent it’, we engage with high-risk portfolio companies to understand how they investigate supply chains to identify and eradicate modern slavery. As a member of ‘Votes Against Slavery’, we expect portfolio companies in the UK market to fulfil annual reporting requirements under Section 54 of the Modern Slavery Act 2015. Where FTSE 350 companies fail to address the minimum legal requirements of the Act, we will continue to vote against the approval of their annual report and accounts.
[1] ILO & Walk Free Foundation (2022). Global Estimates of Modern Slavery: Forced Labour and Forced Marriage, p31. Access here
[2] Office of the Independent Anti-Slavery Commissioner (2021) Dame Sara Thornton’s recommendations to the financial sector, p.2. Access here
Looking forward
We recognise that Railpen can be exposed to modern slavery risks in both its direct operations and investment portfolio. The Modern Slavery Working Group, along with members of the Procurement and Sustainable Ownership teams, identified overlaps in due diligence, prompting ongoing discussions to align procedures. The goal is to ensure consistent due diligence across business areas, with work underway to address barriers and set priorities for action.
In 2026 we will continue to review our modern slavery risk assessment and associated controls to ensure they remain proportionate to the nature and scale of our operations. We will ensure consistent application of due diligence processes and procedures across our procurement and investment business, with appropriate controls in place. We’ll monitor the effectiveness of our training and awareness measures, maintain appropriate oversight of our supplier base, and keep our policies under periodic review in light of evolving guidance and best practice.
Andy Bord, Chief Executive Officer
Date: 18 June 2026