Skip to main content

Your browser is out of date, and unable to use many of the features of this website

Please upgrade your browser.

Ignore

This website requires cookies. Your browser currently has cookies disabled.

Implementation report

Important

Early draft of the code of practice

This code is not in force yet. It is an early version for the new code of practice consultation.

To give us feedback on issues such as the design, usability and navigation of this code, email us at webfeedback@tpr.gov.uk.

You can also read more information about the consultation.

Published: 17 March 2021

The lawIM1 requires that trustees of certain trust based schemes, unless exempt, must produce an annual implementation report as part of their annual report.

This must set out the information contained in the table below, and some parts must be made publicly available free of charge on a website.

For all these schemes, the report must include the information set out in the Disclosure regulations.IM2 The report must cover or include, broadly:

  • a statement by the trustees giving details of any investments during the scheme year that were not made in accordance with the Statement of Investment Principles (SIP) and an explanation why
  • any action taken or proposed to remedy the deviation from the SIP
  • a review of the investments’ performance during the scheme year
  • an assessment of the type of investments covering their geographical location, liquidity, security and value of the scheme’s assets
  • how closely, in the opinion of the trustees, they have followed their policy in relation to the exercise of the rights (including voting rights) attaching to the investments
  • a description of the voting behaviour by, and on behalf of, the trustees in the preceding year, including the most significant votes cast by trustees
  • a statement of any use of the services of a proxy voter during that year
  • copies of the trustees’ policies in relation to:
    • financially material considerations and non-financial matters which are considered in the trustees’ investment activities
    • exercise of the rights attached to investment and undertaking engagement activities relating to the investments (including how and when trustees would monitor and engage with relevant persons about relevant matters)
    • the trustees’ arrangements with asset managersIM3

For relevant DC schemesIM4 the report must also include:

  • how the governing body has followed and acted upon the investment policies set out in their SIP
  • details of any review of the SIP during the year
  • any subsequent changes made and why
  • the date of the last SIP review (where no review was undertaken in the last year)
  • a description of the voting behaviour by or on behalf of the trustees, including the most significant votes cast by trustees in the scheme year
  • use of a proxy voter during the scheme year

The implementation report should:

  • not simply be a ‘tick box’ report - its purpose is so members can be sure that the scheme is being run as they expect it to be
  • follow the principles for communicating with members as set out in General principles for member communications

Legal references

IM1Schedule 3, Part 5, paragraph 30 Occupational and Personal Pension Schemes (Disclosure of Information) Regulations 2013
[Schedule 3, Part 5, paragraph 30 Occupational and Personal Pension Schemes (Disclosure of Information) Regulations (Northern Ireland) 2014]

IM2Schedule 3, Part 5, paragraph 30 Occupational and Personal Pension Schemes (Disclosure of Information) Regulations 2013
[Schedule 3, Part 5, paragraph 30 Occupational and Personal Pension Schemes (Disclosure of Information) Regulations (Northern Ireland) 2014]

IM3Regulation 2(3)(d) Occupational Pension Schemes (Investment) Regulations 2005
[Regulation 2(3)(d) Occupational Pension Schemes (Investment) Regulations (Northern Ireland) 2005]

IM4Regulations 1 or 2 of Occupational Pensions Schemes (Scheme Administration) Regulations 1996
[Regulation 1 or 2 of Occupational Pension Schemes (Scheme Administration) Regulations (Northern Ireland) 1997]