2025 Responsible Business Report

Responsible Business Report 2025

1. ‌St. James's Place plc Responsible business report 2025 | sjp.co.uk

   
   
   

   03

   Welcome to our Responsible Business Report 2025

   01

   Welcome to the St. James's Place (SJP) Group Responsible Business Report. This is our home page, where you can navigate to all sections by selecting the desired heading.

   Throughout this report you will find indicators to additional content, data and insights, denoted by these icons:

   Additional content in this report
   
   

   Page 04

   
   
   Additional content from external resources
   
   

   This Responsible Business Report is part of our 2025 reporting suite which are referenced throughout.

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   Financial wellbeing

   Investing responsibly

   
   
   05
   
   

   People

   Pages 15 to 17

   
   
   

   Climate Report

   Climate-related financial disclosures for St. James's Place 2025

   See our Climate Report here

   
   
   

   Real lives, real advice

   St. James's Place Annual Report and Accounts 2025

   See our Annual Report and Accounts here

   
   
   
   
   

   Page 05

   
   
   

   Page 06

   
   
   

   Pages 07 to 14

   
   
   

   Pages 18 to 20

   
   
   

   Frameworks

   Pages 21 to 24

   
   
   

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   Community impact

   Climate change

   Good governance

   
   
   
   
   
   
   

   Financial wellbeing

   Community impact

   Investing responsibly

   Climate change

   People

   Good governance

   Frameworks

2. ‌St. James's Place plc Responsible business report 2025 | sjp.co.uk

   Responsible and sustainable decision-making

   Memberships and partnerships

   We collaborate with external initiatives for guidance on various sustainability issues. This has influenced our investment strategy, engagement activities, colleague education, and the assessment of our overarching responsible business goals.

   We are proud members and supporters of many organisations advancing positive change, including climate change mitigation, as displayed below.

   Signatory of

   
   
   

   "Every action we take has an impact on others; it's our collective responsibility to try and leave things better than

   we found them and apply this lens to the work we do across the entire business."

   Sandra Mould

   Head of Responsible Business

   We are committed to taking responsibility for our actions and strive to have a positive impact on our people and communities. We have both the opportunity and responsibility to use our voice to drive change.

   Our approach

   The SJP Group aims to take a holistic approach to being a responsible business with our Responsible Business (RB) framework acting as a blueprint for our key areas of influence. We understand that our present actions can lead to long-term implications. Embedding sustainability considerations helps to create value for our clients and the business.

   For consistency and comparability, we align our reporting to the UN Sustainable Development Goals and the Sustainability

   Accounting Standards Board (SASB) standards. We are preparing for upcoming regulations, for example the UK Sustainability Reporting Standards (UK SRS). We welcome the opportunity these new standards bring to align and streamline existing sustainability related reporting requirements. They are also an opportunity to continue to build trust with

   our stakeholders through enhanced transparency and accountability.

   
   
   

   Read more about our approach to the UN Sustainable Development Goals on pages 21 and 22

   
   
   

   Read more about our approach to the SASB standards on pages 23 and 24

   Policy influence

   By building on the trusted relationships we have established with policy stakeholders, such as at the FCA, HM Treasury and with other Government departments, we have a voice at the table on issues that matter to us and society. This helps us to shape the public policy agenda, mitigate risks, and drive meaningful change.

   In 2025 a policy priority for the UK Government, the FCA and the wealth management sector remained addressing the advice gap and encouraging greater retail investing. We have played an integral role in the development of policy proposals, including through working with the FCA and Government on the Advice Guidance Boundary Review industry working group. This year we also actively engaged with the evolution of sustainability reporting requirements, including responding to the Government's consultation on the UK SRS.

   In 2026, a key priority for us will be supporting greater retail investment. We will be part of the sector-wide UK Retail Investment Campaign to build a stronger investing culture in the UK. We are also part of an industry working group on risk warnings

   for mainstream investments.

   
   
   
   
   
   
   

   Financial wellbeing

   Community impact

   Investing responsibly

   Climate change

   People

   Good governance

   Frameworks

3. ‌St. James's Place plc Responsible business report 2025 | sjp.co.uk

   Our responsible business framework

   We know we can't tackle everything. Our responsible business framework helps us focus on the areas where we can have the greatest impact.

   Pages 18 to 20

   Pages 07 to 14

   Page 05

   Good governance

   Helping us to build trust and effectively manage responsible-business-related risks and opportunities.

   Climate change

   Taking action on climate change with the aim of achieving Group net zero by 2050.

   Community impact

   Giving back to support local communities and regeneration.

   Pages 15 to 17

   Page 06

   Page 04

   People

   Investing in long-term relationships so we can create success together.

   Investing responsibly

   Considering material environmental, social and governance (ESG) factors through our investment process.

   Financial wellbeing

   Enhancing financial wellbeing for our clients, employees and communities.

   
   
   

   Our material topics

   This year we have continued to consolidate the findings of our 2024 double materiality assessment (DMA) as we started a review of our RB framework.

   The DMA builds upon the financial materiality exercises we have undertaken since 2019.

   It was aligned to the European Sustainability Reporting Standards and considered the impact of our business operations on both:

   ⬥ our stakeholders, society and the environment (impact materiality), and

   ⬥ the financial risks and opportunities that societal and environmental changes represent to us (financial materiality).

   The DMA identified material topics which are the sustainability issues most significant for SJP. These material topics are incorporated into our RB framework, as shown on the right. During 2026, we will continue to review our RB

   Material topics

   Responsible business framework

   References

   Affected communities

   Business conduct

   page 05

   pages

   19 and 20

   Climate change

   page 06

   pages 07 to 14

   Consumers and end users

   page 06

   page 04

   
   
   

   Our own workforce

   
   
   
   
   

   pages 15 to 17

   framework, and material topics, with the aim

   
   
   
   
   

   of ensuring we focus our efforts on the areas where we can make the greatest positive

   Workers in the value chain

   page 19

   change.

   
   
   
   
   
   
   

   Financial wellbeing

   Community impact

   Investing responsibly

   Climate change

   People

   Good governance

   Frameworks

4. ‌St. James's Place plc Responsible business report 2025 | sjp.co.uk‌

   Financial wellbeing

   Enhancing financial wellbeing for our clients, employees, and communities

   Goal

   Improve societal financial wellbeing

   Performance highlights

   1,194

   Chartered financial planners

   (2024: 1,182)

   14,726

   Young people reached through financial education

   (2024: 16,618)

   Our financial education programme won the Communication and Education Award. The judges were particularly impressed by the way our work inspires the next generation.

   Focus for 2026

   We will work to support impactful financial education for young people through a streamlined strategy and collaboration with industry and charity partners.

   
   
   

   Our 2025 Real Life Advice Report found that people receiving ongoing advice are more than twice as likely to have a comprehensive financial plan with timelines and clear life goals compared to those who are not. Most importantly, 85% of those with ongoing advice say they are on track or ahead of their savings and investment targets, compared with 64% of those without.

   We are proud to play an important role in improving people's financial lives. Our advisers provide invaluable advice to their clients and empower them to realise their ambitions.

   However, our focus doesn't stop at our clients, because we believe financial wellbeing is a key component of a thriving society. Through our advice proposition, strategic partnerships, and financial education programmes, we aim to ensure that our business promotes financial resilience across our communities.

   Our clients

   Our greatest impact on financial wellbeing

   is delivered through the trusting relationships our professional, highly qualified advisers build with their clients, and the invaluable advice provided. This can lead to both financial and non-financial benefits. More detail on

   the value of financial advice and the part we play can be found in our 2025 Annual Report and Accounts.

   We recognise that people are all unique, with different needs and ambitions. Our advisers seek to understand their clients' individual circumstances, including how much knowledge they have about money and what financial wellbeing means to them.

   We continue to enhance our support for clients in vulnerable circumstances. Specialists across the business have continued to develop our adviser training and resources to help us better meet the needs of vulnerable clients and prevent foreseeable harm. Our adviser training curriculum also includes case studies to guide advisers in tailoring advice for additional vulnerability needs.

   Our employees

   We all experience major life events or milestones, and these are often the biggest prompts for people to seek financial advice. With this in mind we support our employees on their own financial journeys by providing them with access to knowledge and guidance.

   A new dedicated page on our internal rewards platform explains how employees can engage with a selected panel of our advisers. They can also access training and resources to help them be mindful in their spending, saving and financial planning.

   Our communities

   Our research found that 40% of parents fear their children will never get on the property ladder and 38% worry they will not build sufficient savings. We have consistently advocated for providing financial education at the early stages of life and welcomed the Government's announcement that it will be added to the primary school curriculum. This is because we know that building a solid understanding of personal finances is an opportunity to build resilience for the future.

   Our approach is a combination of funding strategic partnerships and face-to-face volunteering in schools.

   In 2025, we were delighted to gift £500,000

   of unclaimed dividends to the SJP Charitable Foundation. This funding is to primarily focus on supporting disadvantaged individuals and communities with their financial wellbeing over the next three years. This reflects our ongoing commitment to financial wellbeing and belief in its positive wider societal impact. In addition, our passionate advisers and employees engaged with 14,726 students on

   Young Enterprise (YE)

   Our three-year strategic partnership with YE has helped them to reach over 100,000 young people through a variety of financial education initiatives. We are particularly proud to have enabled 23 schools to start their Centres of Excellence Programme journey, including a special education needs and disabilities (SEND) setting. Of these 23, six have achieved accreditation so far with a further three expected in 2026. Our funding has also widened access to quality financial education through free lesson plans for schools in the lowest indices of deprivation (IMD 1-4), alongside supporting SEND settings with tailored resources and lesson plans. We will review our

   strategic partnerships during 2026.

a range of financial education topics. 71% of the young people who responded to our feedback survey felt more confident managing their money day to day after attending one of our workshops (2024: 77%).

1. ‌St. James's Place plc Responsible business report 2025 | sjp.co.uk‌

   Community impact

   Giving back to support local communities and regeneration

   Goal

   Generate community impact through adviser and employee engagement

   Performance highlights

   £6.7m

   Total amount raised by the SJP community for the Charitable Foundation including company matching

   (2024: £9.0m)

   59.7%

   Of Group employees involved in supporting our communities and good causes

   (2024: 76.7%)

   496

   Total number of employees who volunteered in work time giving 4,139 hours

   (2024: 1,012 employees volunteering

   10,065 hours)

   Focus for 2026

   Continue to engage with the SJP community and deliver impact.

   As a business, giving back to our communities has always been a core part of our culture.

   Individuals and teams volunteer their time and skills through a wide range of activities, including via our strategic financial education programmes and supporting the SJP Charitable Foundation. Although this year's metrics have fallen, as outlined on this page, overall we

   are pleased with these results in a period of significant change in the business, and completion of our organisational redesign, which is referenced in our Annual Report and Accounts.

   We know that volunteering experiences benefit those giving their time as well as the communities they support. That is why we encourage all employees to volunteer two days a year in work time and provide

   ongoing opportunities on our internal website.

   
   
   

   Supporting communities through our Charitable Foundation

   The Charitable Foundation has been at the heart of our business for more than 30 years. Its ambition of making a positive and lasting difference to people's lives has helped numerous charities to achieve transformational impact. 76% of people supported through the Charitable Foundation report a substantive or transformational impact on their life (2024: 79%).

   We are proud to match all donations and fundraising from the SJP community to the Charitable Foundation. We have also worked collaboratively with our partner charities to support the development of their people through the allocation of some of our Government Apprenticeship Levy funding.

   The Charitable Foundation's grant-making is focused on supporting small and medium sized charities, where its funding can reach

   people and communities most disadvantaged and have a lasting impact. The Foundation's core funding themes are: children and young people; end of life care and support; living well with cancer; supporting mental health; and,

   from 2026, financial wellbeing. It also works to enhance charity sector capacity building,

   by enabling funded charities to increase their organisational resilience, and where relevant expand their services.

   
   
   

   Thank you from the Charitable Foundation

   We rely upon the generosity of the SJP community in the UK, Ireland, Middle East and Asia and our success is a result of this ongoing dedication. Committed members of the SJP community volunteer their time

   to run our Regional Foundation Committees, organising fundraising events and creating connections with their local charities.

   Without these deep connections and the ongoing commitment to matched funding, our grant-making programme would not be possible. The willingness to give back to our communities through fundraising, donations and volunteering runs deep across the SJP community. Thank you so much, we couldn't do it without each and every one of you.

   7.1 million

   Total number of people supported through the Charitable Foundation since 19921

   1 2024: 12.8 million, we have adjusted our calculation methodology since last year's report removing indirectly supported beneficiaries.

Read more about the Charitable Foundation sjpfoundation.co.uk

1. ‌St. James's Place plc Responsible business report 2025 | sjp.co.uk‌

   Investing responsibly

   "Our approach to responsible investment continues to evolve with the aim of delivering the best possible

   client outcomes"

   Andy Ford

   Head of Responsible Investing

   Considering material environmental, social and governance (ESG) factors through our investment process

   Goal

   Ensure responsible investment practices are embedded in our processes.

   Performance highlight

   ⬥ Began using a Sustainability Focus label under the new Sustainability Disclosure Requirements for our Sustainable and Responsible Equity unit trust

   Focus for 2026

   Continue to deepen the oversight of our investment managers, with an emphasis on their engagement activities

   Responsible investing

   ESG risks and

   opportunities

   +

   Engagement

   ESG risks and opportunities can be an important driver of returns. We are committed to ensuring that our investment managers are focused on this key source of potential value for our clients. We apply this focus across our entire fund range.

   =

   Our Sustainable and Responsible Equity (SRE) unit trust1 goes further and has adopted the FCA's 'Sustainability Focus' label. It aims to generate returns by investing in companies that make a positive contribution to the environment and society through what they sell and/ or how they are managed. In addition, our Discretionary Fund Management (DFM) service enables our clients to invest according to their specific values and objectives, such

   as excluding high carbon-emitting industries.

   Key developments over 2025

   Over the year we continued to monitor and engage with our investment managers. We also deepened our oversight in the following ways:

   ⬥ We identified climate change and human and labour rights as areas of priority.1 These two issues have been a key focus of our conversations with investment managers over the year.

   ⬥ The weighted average carbon intensity (WACI) of our investments2 has reduced

   by 37.5% since 2019, as at 31 December 2025 (2024: 43.9%). This exceeds our target of

   a 25% reduction by 2025, even though

   this year saw an increase. Reasons for this increase include sector exposure changes with increased allocations to carbon-intensive sectors such as industrials and materials. Over half the increase came from exposure to three cement producers, emphasising the disproportionate influence highly carbon-intensive companies can have.

   ⬥ We deepened our oversight of our investment managers' stewardship activities, examining topics they engaged on and challenging them on their approach to macro stewardship i.e. how they are trying to influence policymakers, particularly on the issue of climate change. Engagement will remain a key focus in 2026.

   ⬥ We published our first entity sustainability report for SJP Unit Trust Group Limited1.

   This report covers our approach to sustainability across the pillars of governance, strategy, risk management, and metrics and targets.

   ⬥ We announced changes to our Global Equity fund which have strengthened governance around the fund's carbon targets. From February 2026, the fund will be called the Lower Carbon Equity fund and will aim to have a carbon footprint at least 25% below that of its benchmark. New key performance indicators and exclusions will also be introduced.

   
   
   

   Read about our responsible investment approach

   1. For more information see UTG's Sustainability Report.

   2. The scope of the data represented is limited to our equity and debt for listed companies. It does not include real estate or DFM data. This covers 82.4% of our overall FUM as at 31 December 2025.

   
   
   
   
   
   
   

   Financial wellbeing

   Community impact

   Investing responsibly

   Climate change

   People

   Good governance

   Frameworks

2. ‌St. James's Place plc Responsible business report 2025 | sjp.co.uk‌

   Climate change

   Taking action on climate change with the aim of achieving Group net zero by 2050

   Goal

   Group net zero by 2050

   Performance highlight

   Set new 2030 interim targets for our combined Scope 1 and Scope 2

   emissions, and the carbon intensity of our investments

   37.5%

   tCO2reduction in our investments1

   (2024: 43.9%)

   Since our baseline year, 2019, we have reduced the weighted average carbon intensity of our investments1 by 37.5% (2024: 43.9%).

   Focus for 2026

   Continue to strengthen our sustainability data and assess the feasibility of setting targets for our remaining Scope 3 emissions

   Our climate transition planning

   This year marked an important evolution in our climate approach, with the launch of our new 2030 interim targets. We aim to reduce our combined Scope 1 and Scope 2 emissions by 65% by 2030 (baseline year: 2023) and the carbon intensity of our investments by 50%

   by 2030 (baseline year: 2019). Our investment target reflects the strong progress already made in reducing emissions across our portfolio. As a result, we recognise that further reductions will become increasingly challenging over time and require more fundamental changes in the wider economy. Both targets are critical milestones on our journey to net zero as a Group, which we remain fully committed to achieving by 2050.

   The targets were set following extensive data-driven modelling. We engaged with key subject matter experts (SMEs) across the business to understand the different factors and initiatives that are likely to impact our footprint, for example energy efficiency measures. This enabled us to understand the level of reductions that are stretching but achievable. Our Scope 1 and 2 target was approved by our Board2 in December 2025. Our investment target was approved by our Investment Committee in May 2025.

   Last year, we committed to reducing our reliance on carbon offsets. Our new targets are a crucial step in that direction, because our ambition is to meet these through direct emissions reductions by:

   1. Reducing our reliance on fossil fuels: switching from natural gas to electric heating and continuing the electrification of our fleet of company cars.

   2. Increasing resource efficiency: implementing cost-saving energy efficiency initiatives in our UK offices -with many already planned.

   3. Transitioning to renewables: exploring the use of onsite generation, Power Purchase Agreements (PPAs) and Renewable Energy Guarantees of Origin (REGOs).

      However, we recognise that action beyond our value chain can still play an important role in the short-term. As a result, in 2025, we voluntarily neutralised our operational emissions3 using 5,740 tCO2e of offsets certified to recognised global standards such as the Verified Carbon Standard.

      This enhances, but does not replace, our emissions reduction priorities above.

      Key progress in 2025

      We are proud to have also taken large strides in our broader approach to climate change this year. Some highlights are:

      ⬥ reducing our Scope 1 emissions by 45%, driven mainly by our targeted efforts to improve energy efficiency in our offices

      ⬥ reporting our financed emissions and employee commuting emissions for the first time, strengthening transparency

      ⬥ measuring emissions from our investment managers and Academy travel for the first time, closing key data gaps

      ⬥ leveraging our voice by contributing to significant public consultations on climate, such as the Department for Business and Trade's consultation regarding the UK SRS.

      In 2026, we plan to build on this momentum with purpose. We will continue improving our emissions data and aim to use it to test the feasibility of setting targets for our remaining Scope 3 emissions.

      
      
      

      Read more about our evolving climate approach in our Climate Report 2025

      
      
      

      1. The scope of the data represented in this metric is limited to our equity and debt for listed companies. It does not include real estate or DFM data. This covers 82.4% of our overall FUM as at 31 December 2025.

      2. Refers to the Board of Directors at St. James's Place plc.

      3. As of 2025, our operational emissions include our Scope 1, Scope 2, and Scope 3 (categories 3, 5, 6 and 7) emissions.

   
   
   
   
   
   
   

   Financial wellbeing

   Community impact

   Investing responsibly

   Climate change

   People

   Good governance

   Frameworks

3. ‌St. James's Place plc Responsible business report 2025 | sjp.co.uk

   Our climate-related risk management

   Details of our Group-wide Risk Management and Control Framework are available in the

   Timeframes

   S

   M

   L

   Timeframes refer to when we believe a risk/opportunity is most likely to have a potentially material impact. Our short-term timescale is aligned with our business planning horizon; our long-term timescale is calibrated to the Science Based Targets initiative's recommended definition of 10+ years. We use 'medium-term' to cover the period between the two.

   Principal risk amplified	Underlying climate-related risk(s) identified in Climate Report 2025	Timeframes		Description of risk and impacts	Example mitigation (see full list in our Climate Report 2025)
   Transition risks
   Strategy and change	Reputation risk -greenwashing & action failure	S	M	Loss of existing or prospective clients due to negative publicity caused by greenwashing or perceived failure to contribute to tackling climate change. This could reduce our market share and revenue.	We review our corporate fund marketing materials to ensure they align with anti-greenwashing rules.
   Client proposition	Client offering	M		Loss of existing or prospective clients if they have climate-related preferences that our products do not or cannot suitably meet. This could reduce our market share and revenue.	We adopted the FCA 'Sustainability Focus' label for our Sustainable and Responsible Equity Unit Trust. Clients with an ESG focus are made aware of this product.
   Regulatory and legislative	Policy & legal risk -cost of regulatory compliance	S	M	Increased costs for continued compliance given enhanced climate-related disclosure, governance and risk management obligations. Regulatory fines if we fail to comply, which would also increase costs.	We have begun preparatory work towards alignment with aspects of emerging regulations, such as the UK SRS.
   Financial	Market risk -investment values	M	L	Climate-related physical and transition risks could negatively impact the value of the companies we invest in and the assets we hold on behalf of clients.	The solvency risk is largely minimised by matching our assets to policyholder liabilities (asset-liability matching). Our investment managers also consider climate risk as part of their investment decision-making.

   2025 Annual Report and Accounts. Climate-related risks and opportunities are fully integrated into our broader risk management approach. We therefore identify, assess, monitor and manage them using the policies and processes referenced in that report.

   Our material climate-related risks and opportunities

   We engage SMEs from across the business at least annually to identify climate-related risks to the business at Group level. As part of this process, we consider both transition risks (such as changes in regulations) and physical risks (such as flooding), as well as potential opportunities. We then assess the timeframes and materiality of each of the risks, prioritising mitigations for those that score the highest.

   Our most material transition risks and opportunities are shown in the tables on the right. We have described the potential impact of these and provided examples of the actions we take to mitigate each risk and help capture each opportunity. We have also shown the four principal risks to the business that are amplified by these climate-related risks.

   These principal risks are detailed further in our 2025 Annual Report and Accounts.

   Type of opportunity & timeframes	Description	Examples of actions taken
   Opportunities
   Client offering S M L	The client attraction and retention	⬥	We monitor our investment managers to ensure that
   The potential impact on the business includes	opportunity arising from developing		they are taking all material ESG factors into account.
   the ability to attract new clients and retain or	sustainable investment solutions to	⬥	We regularly review our offering to consider whether
   grow our market share.	meet the potentially increasing demand		there is demand for further sustainable products.
   	for sustainable products.
   Reputation benefits S M	The opportunity to increase trust and	⬥	All of our investment managers remain Principles
   The potential impact on the business includes	client satisfaction by aligning more		for Responsible Investment signatories.
   strengthening client trust, which could increase	closely with clients' expectations in	⬥	We have set transparent, data-driven interim emissions
   retention and gross inflows, helping to grow	relation to climate action.		targets for our investments and for our Scope 1 and 2
   market share and revenue.			emissions. We have also reduced our reliance on
   			carbon offsetting.

   Physical risks were deemed immaterial to us given the nature of our business and the mitigations we have in place. For example, each of our managed UK offices has appropriate buildings insurance. This helps

   protect against flood risks arising from severe climate-related weather events. We also have a detailed business continuity plan and operational resilience programme, which ensure that key services can continue in the event of climate-related disruptions.

   
   
   

   For a more detailed breakdown of our climate-related risks, opportunities and impacts, please see our Climate Report 2025

   Short-term - 0-5 years

   Medium-term - 6-9 years

   Long-term - 10+ years

   
   
   
   
   
   
   

   Financial wellbeing

   Community impact

   Investing responsibly

   Climate change

   People

   Good governance

   Frameworks

4. ‌St. James's Place plc Responsible business report 2025 | sjp.co.uk

Climate scenario analysis

We use climate scenario analysis annually as a tool to help us assess the potential impacts of climate-related risks and opportunities on our business.

Our analysis uses three contrasting climate scenarios (shown below) constructed by the Network for Greening the Financial System (NGFS), Phase V. These scenarios are widely used across the industry (including by the Bank of England).

They are designed to highlight the potential impact of both physical and transition risks across a wide range of future climate scenarios.

Modelling limitations and assumptions

We believe climate scenario analysis is useful for strategic planning and risk mitigation. This is because it provides an indication of the resilience of our business to climate change - allowing us to strengthen our mitigations where appropriate.

However, scenario analysis is not an exact science. For example, it is based on a snapshot of our current investment holdings, which change over time. It does not account for how we

(or the companies we invest in) would adapt to changing conditions.

Impacts and resilience

Our analysis assesses the climate value at risk of our investments. This is simply an estimate of how much value a company's assets could lose due to climate change.

We considered the impact on our overall portfolio, as well as by sector and geography.

The results showed that transition risks to our investments were highest in the Orderly scenario, which disproportionately impacts companies sensitive to rapid decarbonisation.

In contrast, the risk was greatest in the Hot House World scenario for sectors and geographies vulnerable to physical risks such as extreme weather events.

As our income is largely generated as a percentage of funds under management, a reduction in the value of our investments could decrease our revenue. This impact was possible under all scenarios tested. However, our modelling shows that once mitigating controls are taken into account, our business remains resilient in all three scenarios tested. Examples of

the mitigations driving our resilience to climate risks are:

⬥ Asset-liability matching: our liabilities to clients are fully matched by our invested assets, which means they rise and fall in tandem. This protects us from solvency risk.

⬥ Diversification: we offer a wide range of products, resulting in a diversified portfolio across geographies and sectors.

This reduces the risk that climate impacts in one specific area disproportionately affect our overall performance.

⬥ Asset manager monitoring: we assess all investment managers annually to ensure their investment processes and decision-making appropriately consider climate-related risks.

Read more about our scenario analysis, climate-related risks and resilience in our Climate Report 2025

Our scenarios

+1.5°C

Orderly - Net Zero 2050

Approximate global warming by 2100: +1.5°C

An optimistic scenario that assumes ambitious climate policies are introduced immediately and implemented smoothly, reflecting our ambition as a Group.

+1.5°C to +2°C

Disorderly - Delayed Transition

Approximate global warming by 2100:

+1.5°C to +2°C

Assumes global emissions do not decrease until 2030, followed by an ambitious policy response thereafter.

+3°C

Hot House World

Approximate global warming by 2100: +3°C

Assumes only current policies are preserved, resulting in continued emissions increases and a minimum of 3°C warming.

‌10 St. James's Place plc Responsible business report 2025 | sjp.co.uk

Our climate change metrics and targets

The table below shows the key metrics we use to monitor our exposure to climate-related risks and opportunities. It outlines the specific risk or opportunity that each metric helps us track, any targets we have set for those metrics, and our progress against them.

1. The scope of the data captured in this metric is limited to our equity and debt for listed companies. It does not include real estate or DFM data. This covers 82.4% of our overall FUM as at 31 December 2025.

2. The most recent TCFD Product Report is for the year ended 31 December 2024, and was published in June 2025.

‌11 St. James's Place plc Responsible business report 2025 | sjp.co.uk

Summary of our operational emissions

We continue to track and disclose the annual consolidated greenhouse gas emissions

and energy usage for which St. James's Place is responsible. The table below summarises our gross operational emissions for the 2025 reporting year. Our full emissions disclosure is overleaf and provides a complete breakdown of all our applicable Scope 3 categories.

This includes non-operational emissions such as our financed emissions and supply chain (which are excluded below).

Our operational emissions

1. Energy consumption figures include all energy related to both Scope 1 and Scope 2.

2. This table includes only operational emissions, which captures the following Scope 3 categories: 3, 5, 6 and 7. We track and disclose additional Scope 3 emissions categories in our full emissions disclosure overleaf. That section also includes the following Scope 3 categories: 1, 2 and 15.

3. Total emissions for 2024 have been restated from 3,035 to 10,771 (location-based) and from 2,126 to 9,861 (market-based) for the reasons described under 'Re-baselining'.

The table above sets out mandatory reporting on greenhouse gas emissions and global energy use pursuant to the Large and Medium-sized Companies and Groups (Accounts and Reports) Regulations 2008, as amended by the Companies Act 2006 (Strategic Report and Directors' Report) Regulations 2013 and the Streamlined Energy and Carbon Reporting (SECR) under the Companies (Directors' Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018.

We are pleased to report progress across both Scope 1 and Scope 2 emissions. Our Scope 1 emissions decreased by 44.7%, primarily reflecting our efforts to reduce natural gas consumption across our offices through targeted energy efficiency measures.

Our Scope 2 (market-based) emissions fell by 14.2%. This was driven by an increased proportion of our offices using renewable energy, combined with implementing new energy efficiency measures such as putting building management systems into additional offices.

We are also encouraged by the reduction in our operational Scope 3 emissions, which was largely due to declines across most categories of business travel, including hotel stays, rail travel and car mileage. In 2025, we continued our efforts to reduce business travel and embed more efficient ways of working, delivering emissions reductions for a second consecutive year. We also reported a 15.4% improvement in emissions from employee commuting. While waste-related emissions increased slightly, this mainly reflects data limitations rather than a material increase in the amount of waste we generate. We will explore opportunities to improve the quality of waste and other Scope 3 emissions data in 2026.

A full breakdown of our 2025 and baseline year numbers is available overleaf

Methodology

To maximise comparability and accuracy, we follow all requirements of the Greenhouse Gas Protocol's Corporate Accounting and Reporting Standard. Our financed emissions calculations are also aligned with the Partnership for Carbon Accounting Financials (PCAF). We apply the operational control consolidation approach.

We collect and report our climate data on a one-quarter lag, so this year's reporting includes data from 1 October 2024 to

30 September 2025. Any estimates included in our totals are derived from actual data which has been extrapolated to cover the full reporting period. Where accurate data

was not available, we have relied on emissions factors from recognised sources, such as the Department for Energy Security and Net Zero (DESNZ) and the Department for Environment, Food & Rural Affairs (DEFRA).

Re-baselining

We have publicly reported our emissions for over a decade as part of our commitment to transparency. We have worked hard to strengthen the quality of our emissions data during that time.

In 2025, to support the development of our new interim targets, we took further steps to strengthen our emissions disclosures by closing

key data gaps. For example, this year we are reporting employee commuting emissions for the first time. As a result, we have changed our baseline year from 2018 to 2023, as it is the earliest year with fully comparable data.

For consistency, emissions from the comparison year (2024) have been restated below

to reflect this updated approach.

This ensures we can monitor and report progress against our new climate targets more accurately moving forward. The change in base year does not impact our commitment to achieve net zero as a Group by 2050.

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Full emissions disclosure

Progress against absolute emissions targets

The table below shows our progress against our new 2030 interim target.

Actual emissions in

ID Scope

year (tonnes

CO2e)

% of target

achieved Comment

Abs4

Scope 1 and

Scope 2

1,061

16% Absolute Scope 1 emissions fell by 45% this year, with Scope 2 (market-based) emissions decreasing by 14%. These reductions were

supported by our targeted energy efficiency

initiatives, which we aim to continue in 2026.

Normalised emissions

Normalised emissions in prior year

Normalised emissions in current year

Scope

(tonnes CO2e per '000 sq ft)

(tonnes CO2e

per '000 sq ft) Comment

1 0.95 0.63 Our normalised emissions show our emissions

2 (market-based) 1.36 1.39 intensity relative to the size of our estate. Normalised

1. Category 1 emissions have been restated for 2022/23 (from 68,383 to 135,622) and 2023/24 (from 74,289 to 143,796) to include emissions from our investment managers and Partnership of financial advisers.

2. Category 7 emissions have been reported for the first time this year, which includes figures for 2022/23 and 2023/24.

3. Category 15 emissions have been restated for 2022/23 (from 43,723 to 15,295,929) and 2023/24 (from 42,237 to 10,394,073) to follow the revised methodology used this year. This now accounts for our financed emissions in addition to emissions from our investment properties, which provides a more complete picture of the impact of our portfolio. Our financed emissions figure is calculated excluding real estate and DFM assets and covers 82.8% of AUM.

4. Total emissions have been updated to reflect the specific changes in footnotes 1-3 above.

Absolute emissions targets

We remain committed to achieving net zero as a Group by 2050. This year, we set the below interim target for 2030 as an important part of that journey. This replaces our previous Scope 1 and 2 targets, which expired in 2025. For more details about our expired targets, please see the Appendix section of our Climate Report 2025.

3 10.61 5.88

Scope 1 emissions and operational Scope 3 emissions (that is, excluding investments and supply chain) improved this year. This encouragingly reflects emissions reductions across various aspects of our operations. In particular, business travel emissions fell considerably and we continued to reduce our reliance on natural gas. Unfortunately, our normalised Scope 2 emissions increased marginally this year. However,

we hope to bring Scope 2 emissions intensity back on track in 2026. We aim to achieve this through the renewable energy Power Purchase Agreement implemented across ten of our offices in Q4 2025.

ID Scope Description

% of emissions in scope

% decrease from base

year

Base year

Base year emissions

Target year

Abs4 Scope 1 and

Scope 2

65% combined reduction in absolute emissions

100%

65% 2023

1,262 2030

‌13 St. James's Place plc Responsible business report 2025 | sjp.co.uk

Our Climate Report

Our comprehensive Climate Report 2025, covers all Task Force on Climate-related Financial Disclosures (TCFD) recommendations and recommended disclosures and can be found separately here: sjp.co.uk/ClimateReport2025. To aid readers of the Responsible Business Report, we provide a summary of the key Group disclosures from that report below and have signposted to relevant sections for reference.

Summary of our TCFD-aligned disclosure

We are fully consistent with the TCFD recommendations. We have also considered the TCFD's All Sector Guidance and relevant sector-specific guidance and consider SJP to be aligned with these.

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While climate change remains the focus of our approach to the environment, we recognise that environmental stewardship goes further than reducing carbon. This section highlights some of the broader areas we are trying to drive progress beyond climate change. Although we have made progress we know there is a still a lot to do and we are committed to making a difference.

Energy efficiency

We continue to implement energy efficiency initiatives across our UK managed sites. For example, we launched Building Management Systems (BMS) in several offices, which aim to reduce electricity and natural gas consumption from heating. In October 2025, we also

switched ten of our offices to a Power Purchase Agreement (PPA). This PPA is powered by 100% renewable energy which supports our commitment to reduce our reliance on fossil fuels.

Environmental education

In 2025, we delivered several sustainability-themed sessions to help upskill key stakeholders. In February, our Responsible Business Advisory Group was provided with a detailed overview of our emissions, enabling them to better understand the impact of their own business areas. In May,

we hosted an interactive workshop with 15 practices from our Partnership of advisers. This session aimed to increase their understanding of sustainability topics such as renewable energy and greenwashing. Throughout the year, we also provided the Board and its sub-committees with tailored environmental updates including on our new 2030 climate targets.

Volunteering

Our employees are each offered two paid volunteering days every year, empowering them to contribute to their communities and the causes they care about. In 2025, this led to more than 4,100 hours of volunteering across a wide range of worthy initiatives. This included 395 hours of volunteering for environmental projects. For example, in July, employees volunteered to tackle an invasive plant species that was damaging native plants in local waterways. This was done in collaboration with the Stroud Valleys Project, a charity that aims to protect and enhance the environment by working with local communities to embrace sustainable development

and biodiversity.

Water efficiency

Protecting biodiversity relies on safeguarding freshwater resources and the ecosystems they support.

To manage water use effectively across our managed estate, we apply established good practice by routinely tracking our water consumption, installing efficient technologies (including low-flow fixtures and aerators) and maintaining a proactive programme to detect and repair leaks quickly. We also work closely with our mechanical and electrical supplier to explore new water-saving solutions, adopting these across our sites where they are practical and cost-efficient.

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Investing in long-term relationships so we can create success together

Goal

A place where people can thrive

Performance highlight

72%

employee survey response rate Of those who responded:

87%

understand how their role, and their team's role, contributes to delivering good outcomes for clients

86%

find that their manager promotes an inclusive environment at work

Focus for 2026

Activating our new organisational design, alongside the development and delivery of our culture strategy, driving engagement and advocacy across our whole community.

People are central to how we grow and deliver impact. This is why we invest in long-term relationships with our clients, employees, advisers within our Partnership and their support staff. We understand that how we make connections, and the environment

we create, are essential to our success. Therefore meaningful engagement with all of our stakeholders is important to us.

Client satisfaction and retention

In 2025, we revised our methodology for collating client feedback from an annual survey to quarterly surveys. More frequent touch-points allow an average reading for the year, removing some of the highs and lows experienced when taking readings at a single point in time. This means we can see what impact the delivery of our business strategy has on clients; especially important during this transformational period in SJP's history.

This year we have received responses from 19,300 clients that are selected to be representative of our total client base.

As shown on the following charts metrics have dipped slightly, however, we are pleased overall with these results in a period of significant change in the business (more details in the Annual Report and Accounts).

We continue to work closely with our client community. A group of over 4,000 clients have agreed to participate in our research projects and focus groups throughout the year. This helps us to ensure that the voice of the client is central in the development of our products and services. We have strong engagement with this cohort of clients and are grateful for their active involvement with our continuous programme of research.

Value for money

65%

68%

63%

62%

83%

2021 2022 2023 2024 2025

79%

82%

81%

87%

94%

Overall satisfaction

2021 2022 2023 2024 2025

77%

79%

79%

78%

90%

Client advocacy

2021 2022 2023 2024 2025

Employee engagement

Engagement with employees has been maintained through the year through a series of mechanisms including, but not limited to, hybrid townhalls, our internal digital communication platform and intranet, an annual engagement survey, sessions with the Group's Workforce Engagement Non-executive director and informal touchpoints with Group Executive Committee (GEC) members. In addition, employees have been supported through the Group's change programme and collective consultation via a dedicated support hub.

Through this variety of engagement means, employees have been able to share insights that have led to activity in the business driving an inclusive and effective workplace underpinned by listening and feedback loops.

Employee wellbeing

Throughout the period of change in the business this year, we shared continual reminders of all the wellbeing resources and support available. The GEC encouraged their teams to set clear priorities, have open

conversations about workload, and maintain a healthy work-life balance. Ultimately, our goal is to ensure employees feel empowered to focus on what really matters without compromising their wellbeing.

We offer our employees a range of wellbeing benefits, such as a 24-hour employee assistance programme and private medical insurance. We are a member of the Compassionate Employers Programme giving employees access to a range of support when dealing with bereavement, caring responsibilities or a life changing diagnosis.

This year we launched a new family hub that provides resources and guidance on all things family-related, from fertility information and family leave, to health and wellbeing support.

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We are a Disability Confident employer, accredited with Leader status. For those employees with a disability, impairment or long-term condition, we consider reasonable adjustments that can be made to areas such as working environment or pattern. This is guided by our workplace adjustment policy. Options are discussed in conjunction with the employee and occupational health to ensure they feel supported in their role and to help manage any barriers they may be facing.

Reward and benefits

This year, as part of our annual remuneration review, we increased the minimum salary level for our most junior graded staff in addition to those on our early careers apprenticeship scheme. This builds upon the approach taken in 2024 where we prioritised those who were below the market median and our lower-paid colleagues.

We are working towards improving our ethnicity and gender pay gaps, which we disclose in our annual Pay Gap Report. This is available on our website1 and on the Government's gender pay gap service.

Share participation creates a strong sense of ownership and interest in the performance of the business. We had 67% employee participation in our all-employee Share Incentive Plan and Sharesave Plan following the invitation period to eligible employees.

We provide a comprehensive benefits package for employees, including a minimum pension contribution of 10%, protection benefits such as life cover, critical illness and income protection, alongside salary sacrifice and payroll benefits. We are proud that our maternity and paternity leave is an enhanced benefit of 26 weeks at full pay. This information is summarised to employees in their Total Reward Statement.

See our latest pay gap report here

Learning and development

We invest in the personal development

of our people to enhance their knowledge, abilities and individual skills essential for high performance. Our in-house learning platform drives learning initiatives throughout our organisation and caters to all employees, advisers within our Partnership, and their support staff. We provide engaging learning experiences, with a focus on peer-to-peer learning, on-demand digital content, instructor-led sessions, and collaboration with internal coaches. During 2025 the average number of hours dedicated to mandatory training per employee was

8.5 hours (2024: 5.5 hours).

Our in-house platform supports learners with additional needs by blending a mix of text, audio, face-to-face, video, and interactive content. All our video content has closed captions and transcripts compatible with screen readers. Our learning and development content design team conducts accessibility audits to ensure our training content is understandable for all. We continue to improve our learning offerings and seek feedback to inform our methods and to meet diverse needs. We track learners' satisfaction through a net promoter score. Due to changes in software, it was not possible to track this fully in 2025 and we intend to resume reporting against this metric next year.

This year we ran Korn Ferry Leadership Assessment work with the GEC and will roll this out further in 2026. This is a globally recognised employee assessment tool designed to evaluate leadership potential and performance. This is part of a wider Leadership Development strategy which will continue next year. We continued to run leadership development, team effectiveness and psychological safety

sessions in support of newly forming teams. These will be an ongoing focus as we continue to drive towards high performance, healthy corporate culture and good client outcomes.

In 2025, our early careers programmes trained 13 graduates and 22 apprentices. We also offer employees Apprenticeship-Levy-funded programmes as part of their professional development, with 33 employees enrolling during the year.

We are focused on attracting diverse talent into our early careers pool and have evolved our engagement strategy for 2026. To raise awareness of our apprenticeship opportunities we will engage with a wider range of nearly 70 secondary schools. We will continue to partner with RARE recruitment to attract applicants from lower socio-economic backgrounds for our graduate programmes.

We also continued to work with the Aleto Foundation to connect mentors from across our business with young talent from either ethnically diverse or lower socio-economic backgrounds.

Diversity, equity and inclusion (DEI)

During 2025 we started to refresh our DEI strategy, providing the opportunity to be

more deliberate and targeted in our approach. We have worked to understand more deeply the lived experiences of our female and ethnically diverse employees. This took place through working groups, to test ideas and support change in this space, and through listening sessions hosted by GEC members.

We also launched a new Management Hub, which sets the expectations for managers and guides them through day-to-day processes with inclusion woven throughout. In addition, we reviewed sponsorship of our employee networks ensuring they all have a senior sponsor at GEC level, with regular touchpoints.

Our employee networks are an integral part of our DEI strategy and part of the lived

experience of our employees. This year they celebrated key events such as Black History month, International Women's Day, Inclusion Week, Pride month, and ADHD awareness month, amongst many others. These help

to raise awareness of issues and provide an opportunity for employees to learn and share their experiences.

Our DEI policy recognises diversity as a strength. Our approach to DEI remains focused on attracting, retaining and developing diverse talent. This includes giving full and fair consideration to all applications for employment, fostering an inclusive environment with equal opportunities for all employees to build their careers, irrespective of their background or characteristics.

We have also worked to ensure that our values of inclusivity are reflected across

our community by extending our mandatory Equality Act training to our Partnership of advisers and their support staff. Further details on our approach to DEI can be

found in our Pay Gap Report.

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Our DEI public commitments1

We believe DEI is essential to creating a high-performing organisation where

employees feel motivated and comfortable

to be their authentic selves. We are committed to improving our diversity representation and are working towards the following targets:2

⬥ 40% female representation on the Board

At 31 December 2025 we had 2,859 employees in the Group, of whom 2,601 were in the UK (31 December 2024: 3,334 employees, of whom 3,060 were in the UK). Headcount has reduced as part of our organisational redesign, for more information see our Annual Report and

The following figures and charts for race and ethnicity, gender, sexual orientation and disability are based on voluntary employee diversity disclosures for our core employee base3 as at 31 December 2025.

Minority ethnic representation8

Gender7

Female 52.3%

Male 46.0%

Non-binary 0.4%

Other 0.0%

by 2025 (44.4% as at 31 December 2025,

2024: 50.0%).

⬥ 40% female representation in senior roles4,7 by 2028 (42.5% as at 31 December 2025,

2024: 37.3%).

Accounts. A breakdown of our workforce by gender is shown below.

Gender7

GEC and their senior direct reports5

GEC and their senior direct reports5

White

All employees9

White

Sexual orientation

Prefer not

to say (PNS) 1.3%

⬥ 10% minority ethnic representation in our GEC and their senior direct reports5 by 2027 (see figures on the right).

⬥ 12% minority ethnic representation8 by 2028 (see figures on the right).

Female

2024: 25

Male

2024: 46

2024: 90.6%

Asian, Black,

2024: 89.4%

Asian, Black,

Heterosexual 92.4%

Bisexual 1.6%

Gay/lesbian 1.9%

We have met our 2025 target of 40% female

Managers and decision-makers6

Mixed, Other

Mixed, Other

Other 0.4%

PNS 3.7%

representation on the Board. This aligns with the aspirations of FTSE Women Leaders, a Government supported framework to achieve gender balance.

We are currently ahead of our women in senior roles target; however, the margin is small therefore deliberate focus is needed to maintain this representation.

We recognise that more needs to be done in relation to our minority ethnic representation. Having a strong pipeline of diverse talent remains a priority for us, and a dedicated

Female

2024: 127

Total employees

Female

2024: 1,769

Male

2024: 248

Male

2024: 1,565

2024: 9.4%

Prefer not to say

2024: 0%

2024: 9.5%

(see ethnicity graph on the right for breakdown)

Prefer not to say

2024: 1.1%

Ethnicity

White 88.6%

Asian 6.5%

Mixed 1.8%

Black 1.6%

Other 0.3%

PNS 1.2%

campaign will be run in the coming year to encourage all employees to share their

diversity-related information. Our voluntary diversity data survey captures information relating to nationality, age, ethnicity, gender, caring responsibilities, socio-economic background, religion/ belief, and disabilities. The current disclosure rate of our core employee base is 70.7% (2024: 75.3%) and informs our deliberate actions to drive positive change.

1. Employees may appear in more than one of the data points and graphs presented on this page.

2. Apart from the Board composition, these targets relate to our core employee base.3

3. Core employee base are employees of our main employing entity in the UK, St. James's Place Management Services.

4. We have defined senior roles within our core employee base as a combination of GEC and their senior direct reports5 and managers and decision-makers.6

5. The GEC and their senior direct reports; this includes the Company Secretary and excludes administrative and executive support staff such as personal assistants and executive assistants.

6. Managers and decision-makers are defined as employees who have responsibility for planning, directing or controlling activities of the Company,

   or a strategically significant part of the Company. The Company refers to St. James's Place plc, which is also referred to as 'St. James's Place' and 'SJP' in this report.

7. Gender information is an evolving area of reporting and there are a variety of different frameworks requiring disclosures under different definitions and calculation methodologies. As a result, not

   all of our statistics will align to each other.

8. Relates to our core employee base.3

9. Includes GEC and their senior direct reports.

Disability

disability 86.1%

disability 10.9%

‌18 St. James's Place plc Responsible business report 2025 | sjp.co.uk‌

Helping us to build trust and effectively manage responsible business-related risks and opportunities.

Good governance helps us deliver good outcomes for our clients by making sure we remain accountable for the commitments we make.

It underpins our RB approach with the overall strategy, including for climate, determined at Group level.1

The Board

sets the strategic direction in relation to our RB approach. This covers our entire Framework with a focus on financial wellbeing, investing responsibly, climate change, community

impact, people and good governance. The accountable Board Director for our RB approach is the Chief Executive Officer.

Accountability for managing climate-related risks and opportunities is owned by the Board and the accountable Board Director for our climate approach is the Chief Executive Officer. Collectively the Board considers RB-related opportunities and risks, such as climate change and modern slavery, when reviewing our Group risk appetite statement. This statement considers the Group's strategic objectives and the risks which might materially

Group Nomination and Governance Committee

reviews our RB approach with a diversity, equity and inclusion focus.

Group Executive Committee (GEC)

Group Audit Committee reviews key regulatory reports, including the Climate Report. The committee meets regularly

during the year with at least one meeting covering climate change.

Group Risk Committee provides guidance and advice to the Board in relation to

RB-related risks.

Group Remuneration Committee

reviews key regulatory reports, including our Pay Gap Report. This discloses both gender-and ethnicity-related data.

impact on our ability to meet those objectives.

Key climate-related updates are presented to the Board, and the Board approved our new Scope 1 and 2 interim target this year. We report regularly on our DEI targets to the Board, GEC and the Group Nomination and Governance Committee. The accountability

of our collective GEC is evidenced through their objectives which include measures around DEI.

Chief Risk Officer

is supported by accountable individuals at entity level, oversees the efficacy of Group risk management, including climate-related risks and opportunities.

Chief Financial Officer

holds the senior management function for climate and has oversight of our RB approach and related policies. She is supported by the Responsible Business Advisory Group.

Group Investment Director ensures ESG considerations, including climate change, are considered in our

investment strategy. He is supported by

the Investment Committee.

See our Annual Report and Accounts for information on our overarching governance framework.

Sustainability governance framework

We have specific governance forums which

Responsible Business Advisory Group

is responsible for providing guidance on our RB ambitions, including on climate change. The group reviewed our new interim climate targets twice during the year ensuring robust challenge. They also reviewed all RB-related regulatory reports.

Working groups

Investment Committee

validates the responsible investment considerations embedded into our investment processes, including those linked to climate. The Investment Committee also approves our responsible investment policy and climate targets.

oversee and manage RB-related risks and opportunities for the wider Group, as outlined on the right.

There are a number of working groups consisting of subject matter experts from across the business that provide guidance and recommendations on their respective key RB topics. These include environment and climate change, DEI, and modern slavery and human trafficking.

1 Subsidiary boards play an important part in the oversight of the delivery of the Group's strategy, including on climate, operating in line with the Group's governance framework.

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Human rights

The European Convention on Human Rights, incorporated into UK law via the Human Rights Act 1998, sets out the fundamental rights and freedoms that everyone in the UK is entitled to. We are committed to respecting and supporting the protection of internationally proclaimed human rights and managing our business in an ethical manner, with no tolerance for the abuse of human rights (including modern slavery). Our Board approved human rights policy is available on our website.1

Our approach to human rights includes:

⬥ Our focus on DEI and employee wellbeing, as discussed earlier in this report, provides detail on how we work to prevent negative impacts on these human-rights-related topics.

⬥ All employees have access to our code

of ethics and equal opportunities policies, which make it clear that we oppose all forms of unfair discrimination or victimisation.

⬥ Our bullying and harassment policy makes it clear these behaviours are unacceptable, and we take proactive steps to prevent them. We monitor workplace culture through surveys, exit interviews and case data.

This year, we introduced listening and rising talent sessions to hear wider perspectives, attended by an executive committee member and a Non-executive Director.

All employees, advisers within our Partnership, and their support staff are required to complete Equality Act

Training which covers harassment and discrimination.

⬥ We respect the dignity of individuals and support the right of employees to freedom of association and to join, and

be informed of the right to join, trade unions in accordance with local law. This includes, once in force, the Employment Rights Bill.

⬥ Everyone has the right to a private life, including the right to have their private and confidential information protected. See the data protection section on the next page for more information on our approach to this.

⬥ We are committed to respecting the

health and safety of our workers. We gather accident and illness data which is reported to the Health and Safety Committee quarterly. Due to our office environment the risk of accidents remains low.

⬥ More broadly, our supply chain due diligence and ongoing oversight seek to secure evidence of good practice in

relation to human rights. Recognising the impact of payment practices on workers in the value chain we are signatories of the Fair Payment Code. This is encouraged by the Department for Business and Trade and demonstrates our commitment to good payment practices between ourselves and our suppliers. During 2025 we engaged Slave Free Alliance to support the development of culturally appropriate

modern slavery due diligence questions for our Asia and Middle East operations. These will be implemented during 2026.

Responsible procurement

Our procurement process is designed to ensure we meet our regulatory and business obligations. Our outsourcing and supplier management policy requires effective,

risk-based due diligence to be conducted on all new suppliers and outsourcers.

Where applicable this includes an assessment of their approach to compliant, responsible, and sustainable procurement. This includes, but is not limited to, their environmental sustainability, ethical and fair treatment of workers (including human rights, and health and safety), information security and financial crime prevention (including anti-corruption and bribery). This year we have streamlined our due diligence process to ensure efficiencies both for us, and for our suppliers and outsourcers. We have reduced the length of our due diligence question set by 26%, ensuring that suppliers are only asked for information relevant to their level of risk or impact on the business.

We continue to engage business owners

and relationship managers to provide regular oversight. This is supported by periodic reassessment of the due diligence throughout the term of the relationship. We remain a Living Wage Foundation accredited employer and assess, where applicable, how our third parties remunerate their workforce. In some cases, we have ensured our commercial agreements reflect this requirement and we provide the supplier with the correct support to do so.

We expect our suppliers and outsourcers to abide by all applicable laws, statutes and regulations in force (including the Bribery Act and Equality Act in the UK), and seek to include clauses in our contracts with direct business relationships to this effect. As part of updating our investment manager contract templates this year we included specific clauses on

anti-bribery and anti-corruption. These will be standard going forward.

Anti-bribery and corruption

In line with the Group's risk appetite statement, we will not tolerate any act of bribery, corruption or improper influence. We take all reasonable measures to prevent these.

Where products and services pose a risk of facilitation of bribery or inducement we seek to minimise this risk. We do this through the implementation of a comprehensive anti-bribery and inducement training programme throughout the Group which meets relevant legal and regulatory requirements. We apply the 'Home Country Standards' principle as set out by the Financial Action Task Force, i.e. where a standard applicable to a local entity differs from that applicable in the jurisdiction in which the Group is headquartered, the higher of the two standards will apply.

Our Board is responsible for the oversight of the Group's financial crime prevention policy, which includes anti-bribery and corruption, and reviews this annually. All employees, advisers within our Partnership, and their support staff complete mandatory annual training on anti-money laundering and mandatory biennial training regarding other financial crimes including preventing fraud, bribery and corruption, and facilitation of tax evasion.

In 2025 we were not issued with any associated fines or penalties relating to corruption. Our anti-bribery and corruption policy statement is available on our website.2

1. sjp.co.uk/shareholders/esg-reporting-hub/responsible-business

2. sjp.co.uk/shareholders/about-us/corporate-governance