Modern Slavery Act Statement

Modern Slavery Act (the “Act”)

Introduction:

JAB Life & Pensions is committed to working towards the eradication of slavery and human trafficking. We are a provider of insurance and savings solutions in the UK. We also help pension schemes to de-risk by providing bulk purchase annuities.

As a business that places corporate and social responsibility at the heart of its values, we recognise that respecting human rights is the right thing to do and ensures that appropriate actions are taken to manage risks relating to modern slavery.

This statement sets out the steps taken or actions underway during the financial year ended 31 December 2025 and to date, to assist in the detection and prevention of modern slavery across our business operations and supply chains.

Our policies on slavery and human trafficking:

We are committed to preventing modern slavery or human trafficking in our supply chains or in any part of our business, and to conducting business responsibly and upholding the highest standards of governance throughout our operating businesses. We have in place Corporate Governance documentation and a Policy Suite framework, which alongside this statement contains relevant policies, such as our Corporate Social Responsibility Policy and Outsourcing Management Policy, which set out the necessary principles to manage and mitigate key risks and safeguard the business and all its stakeholders, including employees, suppliers, and customers.

Our approach to human rights extends beyond our supply chain, to employees and contracted staff and we are committed to paying at least the national living wage in the UK. The system of internal controls implemented by our operating businesses includes: -

- Protecting employees and whistleblowers

- Identifying and assessing potential risk areas in our supply chains.

- Mitigating the risk of slavery and human trafficking occurring in our supply chains.

Our employees:

We follow the principles of good corporate governance and Enterprise Risk Management and do not tolerate any malpractice, whether committed by senior managers, employees, suppliers, or contractors acting on our behalf.

Our Group Code of Conduct (“Code”) applies to all directors, officers, and employees, requiring that they adhere to the Code. Our employees are encouraged to report any practices or actions where they believe these to be inappropriate or inconsistent with the Code or that may compromise the ethical standards or integrity of the organisation.

Our Whistleblowing Policy sets out requirements for reporting inappropriate, unethical, or otherwise activities that are inconsistent with the Code. This policy enables an employee to report any improper conduct or unethical behaviour via line management, senior management, the relevant Chief Risk Officer, Company Secretary, Head of HR or Chair of the Audit Committee. This Policy and the associated Guidance Notes are communicated to all employees at least annually and are easily accessed.

Where employees feel that they cannot raise a concern with these individuals, they may report via Safecall’s confidential hotline or make contact on a confidential basis with the Chairman of the Audit Committee. Employees may also wish to contact the applicable external regulator. At all times during any investigation the whistleblower’s identity will be kept confidential. All employees are reminded annually of their right to raise concerns under the Whistleblowing Policy, and to consult with associated guidance.

Our suppliers

It is important to us that our commitment to human rights is shared by our suppliers. We accept a range of goods and services from suppliers located across the globe, although the majority of suppliers have their operations locally in the United Kingdom. Goods and services utilised by the company and its subsidiaries primarily consist of investment and other professional services, catering, cleaning, office furniture and stationery, electrical equipment, IT software, property maintenance and utilities.

As we operate in the financial services sector, the risk of being exposed to modern slavery is considered lower than in other industries. However, we recognise that financial services firms cannot be complacent as to the risks that exist in their supply chains and a risk-based approach is taken to identify any high-risk suppliers and prioritise them for review.

Where we enter or renew a contract with a supplier, we will negotiate terms to include standard contractual obligations seeking to ensure that the supplier confirms they have adequate training and policies in place to comply with the Act and avoid slavery.

Our ongoing approach and next steps:

There is a commitment throughout the company to ensure that we respect human rights and continue to act as a responsible business. To achieve this, there is a Corporate Social Responsibility Policy in place which ensures that all employees are provided with ongoing training to ensure that there is the appropriate level of awareness and consistency across the entire business to detect and ultimately prevent modern slavery from occurring anywhere in our supply chain.

This statement has been approved by the Board and signed on its behalf by the Chief Executive Officer.