Modern Slavery Statement 2026

This statement is made pursuant to Section 54(1) of the UK Modern Slavery Act 2015 and outlines how the Clara-Pensions Group operates to prevent modern slavery and human trafficking throughout its business and its wider supply chain.

Our modern slavery programme aligns with the UN Guiding Principles on Business and Human Rights and the OECD Due Diligence Framework, following the principles of assessing, acting, tracking, and communicating risks.

This Statement reports on facts, circumstances, and controls that were apparent during our most recent financial year (ending on 31 December 2025) that collectively function to provide us with confidence that slavery and human trafficking is not taking place in our own business supply chains or in any part of our own business.

Applicability
This policy is applicable to Clara-Pensions Group Limited, Clara-Pensions Limited and other companies within the Clara group.

Our Business
Clara-Pensions is the member-first consolidator for defined benefit pension schemes. It acts as a bridge-to-buyout for pension scheme members, from the company that currently supports their pension to a long-term insured future.

Clara provides a safer pension promise today by combining its own capital and robust governance with additional contributions from sponsors, who can transfer the burden of their pension liabilities to Clara. This frees up companies to focus on their future growth.

Clara provides a managed journey to an insured buyout, giving members the security of a fully insured pension earlier. Only once all members have their full benefits secured will Clara provide a long-term return on capital for investors.

For more information, please visit our website at www.clara-pensions.com.

Our Workforce
Clara’s workforce are employed directly on a permanent or fixed term basis. All employees who join us are subject to background checks. These include verification of identity, references, evidence of qualifications, residency rights, criminal and financial checks.

We believe that there is negligible risk of modern slavery in our workforce. Our workforce consists almost entirely of skilled professionals, many of whom are subject to professional regulation and regulatory oversight. We also maintain rigorous hiring practices.

All employees are regularly required to complete training on modern slavery, thereby raising awareness of what modern slavery is, who is affected, how to spot, and what to do if you spot, the signs of modern slavery.

The Clara policy on Anti-Slavery and Human Trafficking is also flagged to new employees in Clara’s induction process.

All employees are regularly required to complete training on whistleblowing, to ensure they are aware of the appropriate reporting mechanisms if they do have any suspicions of any wrongdoing, including modern slavery.

All employees are regularly required to complete training on financial crime which includes anti-money-laundering (noting that the proceeds of crime could include the proceeds of modern slavery) and counter terrorist financing, to ensure all employees can identify the signs of suspicious activity and understand our due diligence and suspicious activity reporting processes.

Clara’s Supply Chains
Our supply chains include our facilities management, outsourced administrators, asset managers, other financial services providers and consultancies including IT related firms.

Our supply chain is categorised based on the risks they pose to our business and it was confirmed in 2025 that all our Tier 1 Critical Third Parties have appropriate Modern Slavery Statements in place which aligns with Clara’s approach to protecting against modern slavery both directly and within their supply chains.

We believe the risk of modern slavery in our business and supply chain is low. We operate in a regulated industry and our business is located in the UK with our suppliers also predominately located in the UK.

Management of Clara assets are delegated to Van Lanschot Kempen (VLK) with the majority of assets invested in the UK with a proportion invested in overseas Bonds. An important factor when constructing portfolios is considering non-financial factors, including social factors such as modern slavery. VLK have a number of policies which they adhere to when investing on behalf of clients and are set out in the policies below:

• Human Rights & Labour Rights Policy
• Responsible Procurement Policy
• Voting Policy, which includes guidelines on how to vote proxies, for example that companies VLK invest in are expected to pay living wages, and have zero tolerance for forced labour and modern slavery in their operations and supply chains.

Our Policies on Slavery and Human Trafficking
We are committed to ensuring that there is no slavery or human trafficking in our supply chains or in any part of our business. Our zero-tolerance approach is supported by Clara’s policies, which are embedded in our culture, are communicated on our internal intranet, are integral to all new employees’ inductions to Clara and are part of the Compliance annual training cycle.

Our Recruitment Policy includes provisions to safeguard against modern slavery in our business, including that only approved recruitment agencies may be used, and all candidates must evidence their eligibility to work in the UK.

Our Whistleblowing Policy is designed to encourage employees to promptly report any suspected wrongdoing or dangers at work, including any suspicions of modern slavery or human trafficking, in the knowledge that their concerns will be taken seriously and investigated appropriately and confidentially.

Our Anti-Slavery and Human Trafficking Policy statement describes how we are committed to acting ethically and with integrity in all our business relationships, and how this is implemented and enforced through effective systems and controls.

The Clara-Pensions Group Board has overall responsibility for our Anti-Slavery and Human Trafficking Policy. The COO has primary responsibility for implementing the policy with Managers at all levels responsible for their direct reports understanding and compliance to the policy.

Due Diligence Processes for Modern Slavery and Human Trafficking
Due diligence, by way of ‘Know Your Customer’ checks, are carried out at the initial on-boarding stage for any new supplier with enhanced due diligence for our Critical Tier 1 Third Parties. These checks are then refreshed in accordance with our Third Party Oversight Policy with our Critical Third Parties receiving annual reviews which includes re-checking of their modern slavery position.

As part of our initiative to identify and mitigate risk:

• We consider any potential risk areas in our supply chains and assess any identified;
• We monitor potential risk areas in our supply chains, if identified;
• We mitigate the risk of slavery and human trafficking occurring in our supply chains and expect all those in our supply chain and our contractors to comply with our values and to contractually agree to comply with modern slavery legislation.
• We have in place systems to encourage the reporting of concerns and to protect whistleblowers.

Approach If Modern Slavery Is Identified

If modern slavery is identified, we will:

• Prioritise the safety and wellbeing of affected individuals;
• Engage relevant authorities (GLAA) and specialist NGOs;
• Suspend supplier relationships pending investigation;
• Require corrective action plans;
• Report transparently on actions taken.

Key Performance Indicators
The Key Performance Indicators (“KPIs”) below help summarise the effectiveness of the steps we’ve taken in 2025 to ensure modern slavery and human trafficking are not taking place in our business or supply chains:

• Cases of slavery or human trafficking discovered internally or in our supply chain: Target 0% which was met
• Suspicions of slavery or human trafficking disclosed via our whistleblowing procedures: Target 0% which was met
• Employees who have completed training on modern slavery, whistleblowing and financial crime: Target 100% which was met

Critical Third Parties assessed within the last 12 months for modern slavery: Target 100% which was met.

Lawrence Churchill
Chairman, Clara-Pensions Group Limited
January 2026