Conflicts of Interest Policy

Last updated: October 2025

1. Purpose of This Policy

PKL Pensions Ltd (“we”, “our”, “us”) is committed to maintaining the highest standards of integrity, transparency, and independence.
This Conflicts of Interest Policy sets out how we identify, manage, and prevent conflicts that could compromise the impartiality of our services or undermine trust in our operations.

2. What Is a Conflict of Interest?

A conflict of interest arises when an individual’s or organisation’s personal, financial, or professional interests could improperly influence — or appear to influence — their decisions or actions.

Conflicts may be:

• Actual: a real conflict exists.
• Potential: a conflict could arise in the future.
• Perceived: a situation could be seen by others as a conflict, even if none exists.

3. Our Business Model

PKL Pensions Ltd operates as an independent pensions platform, facilitating secure, compliant connections between workers, employers, and approved UK pension providers.

We are not affiliated with, owned by, or financially compensated by any pension provider, investment firm, or advisory network.
We do not receive commissions, referral fees, or other financial incentives from any organisation listed on our website or platform.

4. How We Identify and Manage Conflicts

To maintain impartiality, PKL Pensions Ltd has implemented the following measures:

• Independence: All service relationships are structured to prevent influence from any pension provider or external commercial interest.
• Disclosure: Any potential or perceived conflict identified by staff or management must be reported immediately to the Compliance Officer.
• Review: Our compliance team assesses potential conflicts and determines appropriate controls or mitigation steps.
• Prohibition: Staff and contractors are prohibited from accepting gifts, payments, or benefits that could influence decision-making.
• Segregation of Duties: Operational roles are designed to separate decision-making from financial or contractual negotiations.

Where a conflict cannot be fully avoided, it will be clearly disclosed to affected parties before any action is taken.

5. Employee Responsibilities

All employees, contractors, and consultants working with PKL Pensions Ltd must:

• Declare any personal or professional relationships that could create a conflict.
• Avoid situations that could impair objectivity or impartiality.
• Follow internal reporting procedures if they suspect a conflict exists.

Failure to declare a known conflict may be treated as a disciplinary matter.

6. Monitoring and Oversight

The Compliance Officer maintains a Conflict Register to record and review all reported conflicts.
The register and this policy are reviewed annually or whenever material changes to the business occur.

7. Reporting Concerns

If you believe PKL Pensions Ltd or one of its representatives may be acting in a way that conflicts with this policy, please report it confidentially to:

Compliance Officer
PKL Pensions Ltd
International House, 12 Constance Street, London E16 2DQ
Email: info@pkl-pensions.com
Telephone: 0208 064 3117

All reports are treated in confidence and will be investigated promptly.

8. Policy Review

This policy is reviewed annually to ensure ongoing compliance with The Pensions Regulator’s standards and general UK corporate governance principles.