Systems and processes

CDC code in force: 31 July 2026

1. Accurate promotional or marketing material is a fundamental part of a multi-employer CDC scheme as this will be used to induce an employer into joining or remaining within the scheme. It is also imperative that employers seeking to join the scheme fully understand the risks and benefits of the scheme.
2. There should be a focus on producing promotional or marketing material as well as the IT functionality needed. Note that we will assess the functionality, quality and maintenance of the IT systems used for promotional or marketing communications on the same basis as the IT systems more generally.
3. To produce effective promotional or marketing material, there must be appropriate systems and processes in place and individuals who have appropriate skills to undertake the planning and assessment work. Here we set out what we will be checking when we assess the scheme in respect of promotion and marketing.

People and skills

4. We will need to see evidence that:
   1. there is a responsible person with appropriate expertise, likely to be the scheme proprietor
   2. there are individuals appointed who have the appropriate skills to develop, create and implement promotional material – if outsourced, we expect the same due diligence to be conducted as for other external service providers
   3. the planned resources include all relevant parties, including the scheme actuary, administrator, employer, compliance and risk and legal advisers and representative bodies, such as unions
   4. the necessary individuals have enough capacity to do the work needed
5. Capacity could be monitored through service level agreements. If output is consistently below expected levels, then it may indicate a lack of resource. 

Promotion and marketing

6. We will check the following:
   1. There is a plan for producing and issuing promotional materials (usually annually, although there may be circumstances where it needs updating more regularly).
   2. There is evidence that the trustees are consulted and provide their approval for the plan and any ad-hoc updates to the plan. The plan sets out activities for the year and must cover reviews of all promotions and reporting.
   3. There is evidence that the trustees have appropriate oversight of the marketing materials and that they have the opportunity to review or challenge the content.

Promotion and marketing approvals processes (including quality assurance)

7. We will check that:
   1. there is an evidence-driven process for creating, reviewing (including that the content is accurate and not misleading) and maintaining promotional material in a timely manner
   2. there is evidence that the distribution channels used are appropriate
   3. there is a clear process for reviewing promotional and marketing material (including where minor amendments and extensions to approval periods are requested)
   4. there is a clear process for undertaking quality assurance on the approvals process to ensure promotional items are of sufficient high quality and consistent and that the personnel developing them remain competent

Systems and processes

8. We will check there is evidence that appropriate promotion and marketing approvals systems and processes exist to demonstrate a clear audit trail, and includes:
   1. confirmation of who developed the marketing material (the originator)
   2. confirmation of who approved the marketing material (this should be an independent person to mitigate the risk of conflicts of interest)
   3. how long the material is approved for and the expiry date of the approval for such item
   4. a final copy of the approved item that is being used for promotional activities must be retained
   5. any feedback provided to the originator of the item where changes were required to ensure the item was deemed clear and not misleading

Record-keeping

9. In respect of record-keeping:
   1. The approval file for each item should contain evidence that the material has been reviewed and signed of by an independent competent person (independent to the persons or team responsible for putting together the material) confirming it is clear and not misleading.
   2. The approval file should contain an expiry date of the approval which should usually be no more than one year from date of approval.
   3. Copies of relevant sign offs are obtained, and a clear audit trail of the approval process also needs to be kept ideally in electronic form and easily accessible.
   4. There must be an appropriate document retention period set for marketing or promotional material. Where the promotion relates to transfer activity, we would expect this to be kept indefinitely. For all other material we would expect records to be kept for at least six years.

Reporting

10. A report must be provided confirming how many promotional materials have been created and used. The report should be provided quarterly, or at a different frequency to align with trustee meetings. The report should:
    1. confirm the number of approvals made, whether quality assurance has been undertaken on the items, whether any complaints or feedback has been received on the items and subsequent action taken if needed
    2. show whether any rectifications have been made and how these were identified and how quickly they were undertaken and the rationale for making changes, or not
    3. include rectifications which identify financial loss to the scheme/members including full details of how this was identified and amounts paid – this should be highlighted in any financial reporting (such as scheme accounts)
    4. show whether any risks have been identified as a result of promotional activity and any mitigations for these and how ongoing risks resulting from all promotional activity are being monitored and mitigated

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