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Final response to the consultation on a new code of practice

The final response to the consultation on a new code of practice that brings together and updates 10 existing codes of practice into a single set of clear, consistent expectations on scheme governance and administration.

Published: 10 January 2024

General code of practice – introduction

There were several ideas behind our work to merge 10 of our existing codes of practice into a single new code. Among these was the aim to provide all types of governing bodies with consistent expectations, regardless of scheme type and so far as legislation permits. This in turn should lead to improved awareness of our expectations and from there better governance. It also gave us the opportunity to update several of our expectations and refresh them in line with current legislation and practice. In carrying out this work, we have created a modern, succinct code of practice which should be more accessible and useful for the user, whether they are a member of a governing body, or someone tasked to assist them.

This is the final response to our consultation on the new code of practice, which ran from 17 March 2021 to 26 May 2021. We published an interim response on 24 August 2021. Since the consultation, we have named the code that we consulted on as our general code of practice.

During the consultation period, which took place during a period of national lockdown, we made full use of remote communication and were able to hear the views of over 1,000 members of the pensions community. This was a more diverse group than we might otherwise have reached, and we hope those that we spoke with found the engagement as useful as we did.

The objective of the consultation on this code was to seek the views of those who would be using it. This applied not just to the content, but also the style and flow of the code. The new code is designed first and foremost to be a digital product. We received positive feedback from those who engaged with the draft digital version of the code that was available on our website.

Consultation responses

Our consultation was rewarded with over 100 formal responses, comprising of some 17,400 separate answers. We would like to thank those who took the time to respond to what was an in-depth and wide-ranging consultation that touched on almost every aspect of running a pension scheme. The answers we have received have each been reviewed and considered, in some cases at great length. While some respondents were nervous or critical about our proposals, we found that they were no different in offering constructive and helpful feedback for the final version.

Many of the suggestions and comments we have received are reflected in this final version of the code. In this response we seek to address the principal changes that we have made in response to the consultation. However, because of the sheer volume of small changes, we cannot highlight, nor credit, every difference from the consultation draft. This is especially true where we have remodelled or retired modules. Mainly, the changes we have made are for clarity and have not affected the expectations we have set out. In such cases we have generally not commented on them. However, we have set out to highlight any instances where a change has adjusted an expectation. In addition, where the law has changed, we have amended modules as necessary to reflect the law as it stood in October 2022.

Questions asked

In consulting on the draft code, we wanted to get value in the responses received, and to ensure that no issue overshadowed comments on any other part of the code. To this end, we had a small number of overarching questions that applied generally to the whole code. We then sought answers to the same five questions on each module that comprises the code. These are listed below and gave respondents the opportunity to comment on any features of the module that required it. 

We asked:

  1. Is the title of the module a fair reflection of the content provided within it? If not, what would be a clearer description of this content?
  2. Is it clear from the module what our expectations are, and does this content provide governing bodies with a clear sense of how expectations may be applied to their scheme’s own circumstances?
  3. Has the subject matter of the module been covered in sufficient detail and is there any further information or guidance that would assist governing bodies in meeting our expectations?
  4. Are there any expectations that may be considered a disproportionate and/or unreasonable burden for a well-run scheme, or for certain types of scheme or governing body?
  5. Do you have any further comments on the module that have not been covered by the previous questions?

We received some long and detailed responses to some questions on certain modules. While some respondents chose not to answer most questions, few respondents attempted to provide detailed answers to all our questions. A significant number of respondents also commented in one block rather than in response to a specific question.

Some modules carried a sixth question that related to a particular aspect of what we had presented. While respondents did often attempt to answer this question, we found that most comments appeared in the text responding to the usual five questions.

One of the overarching questions concerned the frequency with which we review and update the new code. One of the ideas behind the new code is that it’s simpler and easier to update. This means that we should be less likely to see areas of the code go stale in the way that several of our existing codes of practice have. Respondents were generally supportive of the idea of regular updates, particularly given the pace of legislative change. However, many were concerned that the code could be updated without them noticing. All our codes of practice must go through a formal process of consultation before the final version is laid in Parliament for 40 days. We feel this should assuage any fears of us updating a code in any way secretly. Most respondents were happy with an annual or biennial cycle of updates. Some expressed a desire for two updates a year.

Many modules received responses that asked us to clarify which schemes they applied to. This may have been for a variety of reasons, but often it was because it was not necessarily clear from the opening paragraphs whether it applied to a particular governing body. This was a fair criticism, as often such applicability wasn’t clear or, contrary to the design principles we had adopted and buried within the module contents. We have therefore taken efforts to make the applicability of each module clear in the opening paragraphs, and in a consistent way. We hope that this is a significant help for users.

Although not something we probed directly, several respondents expressed views on the numbering scheme used for modules. This was something we had used during the development of the code to help us keep track of the modules we were drafting. This was especially true where module names were likely to change. We included these numbers in the consultation draft to see if there were any views on it. If for example, they might be seen as a useful shorthand instead of a title. Where thoughts were expressed, they were generally wary of the reference numbers. Some could see that they would be useful as a shortcut when navigating the web. Others were confused by the numbers not always being consecutive. The first three modules being TGB001, TGB014 and TGB044 provides evidence of this. This is a legacy of the drafting process and the way in which we moved modules around so that they fitted together in a more logical fashion. On balance we have decided to remove them from the final version.

We also raised an overarching question about our duties under the Public Sector Equality Duty We did not receive many responses to this question, and those who did respond considered that the new, predominately web-based code would aid accessibility. A couple of respondents did mention that the requirement to gain the necessary knowledge and understanding in relation to a role in a scheme’s governing body might be onerous to someone with family or caring responsibilities. In this case the time limits set out are driven by legislation, rather than being in our control.

Responses to questions on individual modules

In this section we cover the answers we received in relation to each module. As noted above, we received close to 17,400 separate answers to questions about modules and so cannot reflect every opinion that we received here. We can, however, assure readers that every answer was read and given consideration.

Board structure and activities

TGB001 – Role of the governing body

You said:

The introduction of a new term for those in charge of the scheme received a mixed response. While most respondents in the private sector had no problems with the terminology, it met with substantial criticism from those in public sector schemes. They pointed out that combining the roles of scheme manager and pension board made the obligations placed on the parties difficult to disentangle. This was even more so in the case of locally administered schemes.

Several respondents made the point, in this and other modules, that there was an opportunity to say more about diversity and inclusion in the governing body.

Some respondents from the public sector, felt that it would be worthwhile embedding the Nolan principles for those with public responsibilities into our expectations for governing bodies.

We had set an expectation that those acting as trustee in a professional capacity should have indemnity insurance. This was carried over from our existing expectations of those wanting to appear on our trustee panel. It was pointed out that where a professional trustee is self-employed, it is very difficult, or very expensive to buy indemnity insurance. This expectation would therefore severely limit the availability of professional trustees to schemes who wanted to appoint them.

Some respondents took the opportunity in this first module to express a desire for a unified glossary that is applicable to all modules.

Our response:

In response to criticisms of the definition of the governing body, we have taken the route suggested by one respondent; to remove the pension board from the definition of governing body. This makes sense, as many of the public service scheme obligations fall on the scheme manager. Where expectations do fall on pension boards, for example in relation to knowledge and understanding, we have called this out in the specific module.

While our diversity and inclusion work are ongoing, we have added some words to encourage governing bodies to consider diversity and how they can better represent the demographics of their members.

We considered whether to take steps to reflect the Nolan principles more explicitly in the code. However, many, if not all the principles are already present in the code, while others are implicit in the role of the governing body. So, we have not progressed with this option.

We have removed the expectation that trustees acting in a professional capacity should have indemnity insurance. We wish to allow those schemes that want to appoint and retain professional trustees to have the greatest choice available to them for the expertise they require. Indemnity insurance remains part of our expectations for those professional trustees wishing to appear on our trustee panel.

We welcome the suggestion of a unified glossary, and this was something that we attempted to develop. However, because some terms are reused in legislation with different meanings, it is not possible to get a unified definition. Wherever possible we have retained consistent definitions in the glossary section. Overall though each glossary definition is relevant to the module it is attached to.

TGB014 – Recruitment and appointment to the governing body

You said:

Several respondents asked for the title of this module to be changed to reflect that it covers not just recruitment, but also trustee appointments.

As with the module for the governing body, we have received requests for more consideration on diversity.

Some respondents highlighted that the governing body would not always have the power of appointment, as this might sit with an employer, or a separate body.

Our original draft of this module included a comment that the fitness and propriety of candidates for the governing body should be considered before appointment. This received strong criticism from some respondents who felt it was regulatory creep.

Our response:

We agreed that the title suggested that the module had a narrower scope than it did. So, we have renamed it from ‘recruiting to the governing body’ to ‘recruitment and appointment to the governing body’.

We have added lines to this module to encourage governing bodies to consider equality and diversity.

We have made some amendments to the modules to deal with situations where a governing body is not able to make appointments to its membership. In these situations, we have suggested that the governing body seeks to influence the selection to the extent that it is able to.

We have removed the reference to assessing the fitness and propriety of members of the governing body. We are content that schemes should be sufficiently well run for other members of the governing body to raise concerns, where there are concerns, about the conduct of one of their members.

TGB044 – Arrangements for member-nominated trustee appointments

You said:

As with the module for the governing body, we have received requests for more consideration on diversity.

The processes for election and appointment of member nominated trustees (MNTs) are now well established in most schemes. As a result, most comments we received for this module were about improving the processes set out in our existing code of practice.

Several respondents asked for further guidance and case studies to accompany the expectations provided in the code. This was partly in response to their removal from the code text.

Our response:

We have added lines to this module to encourage governing bodies to consider equality and diversity.

We have added some clarity to the module about the potential recruitment of MNTs who are not members or active members of the scheme. We have also added some detail about steps that the scheme may take where there are sustained problems in recruiting suitable or sufficient MNTs.

We think that most MNT processes should be sufficiently embedded by now, that most governing bodies will be comfortable with the circumstances of their scheme. We have no immediate plans to reproduce any guidance left out from the transposition of the codes.

TGB015 – Appointment and role of the chair

You said:

Some respondents implied that the scope of this module is wider than the title suggests, as it covers both their appointment and role.

The appointment and role of the chair is a new set of expectations for some schemes. Despite, or perhaps because of this, many respondents sought clarification on the points we were expecting schemes to comply with.

Our response:

Listening to responses, we have changed the title of this module to appointment and role of the chair.

Perhaps the most significant change to this module was the insertion of new sub-headings that clearly separate the elements in the table from the paragraphs that apply to relevant schemes.

TGB006 – Meetings and decision-making

You said:

There were few material comments made about this module, with respondents generally recognising that it would impose no new behaviours on them.

Some respondents believed that our expectation that governing bodies should meet at least quarterly to ensure good governance, was either too much, or too rigid.

One respondent asked if we could reflect more flexible ways of working and holding meetings that have become the norm since the pandemic.

We included a suggestion that governing bodies consider publishing the minutes of their meetings to improve transparency and member engagement. This suggestion received many negative responses. While respondents supported the idea of transparency, they reasoned that in many instances redacted minutes would be required to retain an appropriate level of confidentiality. Producing such redacted minutes would take a lot of time, for little relative benefit for members.

Our response:

We have considered the comments from those who questioned whether it was appropriate for us to set an expectation that governing body meetings should be held quarterly. We accept that some smaller schemes may be able to run effectively with fewer meetings. Similarly, we accept that in some instances it may be desirable for schemes to cluster some meetings to deal with a specific matter in a timely fashion. However, we stand by the expectation that quarterly meetings are a baseline for most schemes.

We have added a line to our expectations for governing bodies to consider how meetings can be held, and the circumstances under which that might change. This reflects that it is often more convenient and flexible if meetings can be held online. Such arrangements also allow more frequent targeted meetings, rather than drawn-out single day sessions which may ultimately be less productive.

We have considered the responses we received on the publication of minutes. While we believe that transparency into the workings of their pension scheme will increase member confidence, we do accept the arguments that we’ve received. As a result, we’ve changed the expectation to simply seek to engage with members about their activity.

TGB016 – Remuneration and fee policy

You said:

We received many constructive, although generally negative comments about this module. There were no comments arguing against the principle of the remuneration policy, but we did get a lot of comments about our proposals. We considered that these were productive and have revised our expectations as a result.

The first points raised were over the scope of any remuneration policy. Our original proposals covered all scheme costs and several respondents felt that this went too far. Many respondents pointed out that scheme costs are often paid by sponsoring employers and were not under the control of the governing body.

We suggested the governing body publish their remuneration policy. This was not welcomed. Many respondents, especially those representing service providers, felt that disclosing levels of remuneration might be a breach of confidentiality and potentially anti-competitive. Others felt that it was just unwise and would be used as a basis on which to attack the work of the governing body.

Our response:

We have clarified the scope of the module to make it clear that the remuneration policy should only cover those costs that the governing body is directly responsible for. This means that the scope of each remuneration policy is likely to be much more specific to each scheme than had originally been envisaged. However, it also means that in some instances, where the employer bears all costs, that the remuneration policy will be very short. It is not in any way intended to cover the way in which service providers remunerate their own staff.

We have also taken steps to make it clear that the remuneration policy is a policy. It doesn’t have to set out the levels of remuneration paid. This was never intended to be a feature of a remuneration policy, but some read the module as requiring full disclosure. We have taken steps to revise the module accordingly. The policy should still contain sufficient information or provide a framework to help the governing body assess whether they are getting value for money.

We have also removed the expectation to publish the remuneration policy. We accepted the arguments that this would add little value to members and might be a source of criticism. While those arguments were mostly based on an incorrect assumption that we were expecting levels of remuneration to be disclosed, we accept the general concerns behind them and have therefore dropped the expectation.

Knowledge and understanding

TGB017 – Knowledge and understanding

You said:

Respondents suggested that the title of this module, originally ‘working knowledge of pensions’ would be better understood if renamed.

This was another module where people felt that it was appropriate to add comments about diversity and inclusion, and to encourage diversity of experience and knowledge within a governing body. Respondents also welcomed the introduction of a collective and shared responsibility for knowledge and understanding in the governing body.

Several respondents felt that our expectations of professional trustees should be strengthened, to reflect the higher standard to which we hold them. They also felt that there should be greater awareness and promotion of the industry’s professional trustee standards.

Some respondents noted that the contents of our table on expectations of knowledge and understanding were quite broad and onerous for new recruits to a governing body. Some also felt that the expectations we were setting might discourage lay trustees from taking on the role. Others noted a few areas where our tabulated expectations didn’t match those set elsewhere in the code.

Our response:

We agreed that, while the original title was accurate in terms of legislative requirements, it would be more familiar to users if described as ‘knowledge and understanding’.

In response to requests, we have added some small additional content concerning diversity and shared responsibility across the governing body. Many schemes had already adopted policies that achieve the aim of increased diversity of thought on the governing body. We hope that this may further this aspiration ahead of the delivery of our work relating to diversity and inclusion.

As this is one of the modules most affected by the redefinition of ‘governing body’, we have highlighted that within public service schemes, it is the pension board that must meet the requisite knowledge requirements.

We have strengthened our wording around professional trustee accreditation, encouraging professional trustees to work towards it.

The expectations set in the table are almost exclusively those that were already in place for new trustees. They had not been revised for some time and we did not feel that it was appropriate to revise them at this time. However, the components are likely to be reconsidered as part of our general work towards improving governance standards. In the table we have added elements that reflect measures introduced elsewhere in the code. An example of this is familiarity with the governing body’s remuneration policy, own risk assessment and cyber security policies. We have also inserted an expectation on awareness of how member preferences and beliefs might affect investment choices. While we recognise that the volume of knowledge expected of a trustee is significant, it should be noted that we are now more focussed on collective knowledge, so are not expecting everyone to be an expert on everything. Nor do we expect anything more than a basic familiarity with the material from lay trustees just entering the role, instead they should develop their knowledge and understanding as detailed in the code.

TGB005 – Governance of knowledge and understanding and TGB003 – Building and maintaining knowledge

You said:

We received several comments that this module, and the following module on building and maintaining knowledge, covered much the same ground and that there did not need to be three modules covering the topic of knowledge and understanding.

Several respondents wanted us to stress the importance of the trustee role, and to emphasise this to employers. Their concerns were driven by the feeling that the trustee role is undervalued by some employers, meaning that trustees are torn between their responsibilities to the employer and to the scheme.

Our response:

On review we agreed that the split on the topic content into three modules was artificial and unnecessary. We took the step of merging the modules covering governance of knowledge and understanding and building and maintaining knowledge into one. Some small elements were also transferred into the knowledge and understanding module.

Those carrying out any aspect of scheme governance are fulfilling an important role.  It is one that needs time given to it beyond simply attending meetings. Occupational pension scheme trustees are allowed time off by law to perform their duties. Those commenting on this point felt that the employers’ interpretation of the law does not go far enough. We have sympathy with this view and believe that there should be a balance between scheme governance duties and duties as an employee. We did not feel that the code is necessarily the right place to set out any expectations or guidance. However, this is an issue that we would like to explore further in due course.

Many of the themes from the module on knowledge and understanding also came through here. We have reinforced the principles of developing knowledge and understand over time, according to the needs of the scheme and individuals. We have also continued the theme of collective knowledge and understanding across the governing body.

Value for scheme members

TGB009 – Value for members

You said:

We received comparatively few responses on this module. Those that we did receive almost exclusively requested additional guidance about how value for money assessments should be made.

Our response:

The additional detail requested by respondents would only be suitable for guidance. In the months following the consultation, further statutory guidance has been published (along with guidance from TPR) and we have highlighted this for readers in the revised module.

Advisers and service providers

TGB010 – Selecting and managing advisers and service providers

You said:

We received several different points of commentary on this module, with no overriding themes. The most significant comment was the suggestion that appointments should be reviewed every two years. Respondents felt that this did not give enough time for a service provider to become established, or for issues that were identified to be fully challenged and remedied before a full review of the service. Other respondents on the same point were concerned that it might drive a revolving door approach to appointing service providers, with few opportunities for any to settle.

Some of the respondents representing local government schemes reminded us that they have their own government procurement rules, in addition to the expectations set by us.

In common with several other modules, some commentators here asked us to explain the principles of proportionality and how they apply to smaller schemes. It was felt that reviewing the service providers’ performance would be beyond the ability and/or resources of a small scheme.

Our response:

We agree that the two-year period for reviewing service appointments was too short. We were particularly swayed by arguments that such a short period might drive governing bodies towards shifting providers rather than seeking to improve performance. This kind of rotation could lead to a spiral of poor customer service, with members in particular bearing the brunt of poor service. So, we have extended the review period by one year, to three years, which is in line with the suggestions we received.

As a result of comments from local government pension scheme funds, we have referred to overriding legislation that may affect how a scheme operates.

We took no action to clarify how our expectations would apply to small schemes in the code. If needed, this may be dealt with in guidance. However, we were concerned by the suggestion that small schemes would be unable to assess the quality of, for example, their administration. We strongly believe that the governing body of any scheme should be able to ask its service provider questions and seek reassurance that they are receiving a good quality service, and where this is not the case, are able to seek improvements or ultimately change provider.

Risk management

TGB031 – Identifying, evaluating and recording risks, TGB032 – Internal controls and TGB033 – Assurance reports on internal controls

You said:

Overall, we received relatively little feedback on the detail of our expectations for internal controls. Aside from asking for occasional pieces of clarification, most respondents were broadly content with the principles we set out and had few adverse comments about the direction we had taken.

We received extensive feedback on the usefulness of the three main modules dealing with internal controls: identifying and assessing risks, managing risk using internal controls, and assurance of governance and internal controls. Because of this, we have restructured the three modules to present a more ordered set of explanations. This restructuring meant that sections were moved around between modules in a way that makes them difficult to trace to the version that was consulted upon. This section deals with the comments received on all three modules.

One item that some felt deserved additional examination was the outsourcing of risk management. This is relevant to governing bodies large and small, as no governing body is likely to have all the necessary skills to assess the risks for all aspects of scheme operations. Also, many schemes will rely on the output of risk experts commissioned themselves, or by a service provider.

Some noticed that we had adopted a poor choice of wording around risks. The original wording suggested that risks could be closed. This is unlikely to be possible for most risks since it is rare that a risk can be completely removed.

Some made observations regarding the new risk management function. This function was only loosely sketched out in these modules. As a result, many sought additional clarification on the function and how it would carry out the functions delegated to it.

Some asked if it was possible for us to produce templates. These requests appeared to express a desire for consistency of operation between schemes in their assurance of internal controls.

Some expressed concerns about proportionality and what governing bodies might be able to or expected to undertake in terms of risk management.

Our response:

We have made it clear that risk management activities can be carried out by a wide range of individuals, functions, and service providers, and we are not prescriptive about who should perform such duties.

Recognising that most risks cannot ever be completely removed, only mitigated or reduced, we have changed the wording in these modules and throughout the code to reflect this.

The observations about the risk management function were well made and as a result we have created a new module to deal with it. The matters raised in relation to it are dealt with later in this response.

We are very reluctant to produce templates for schemes for several reasons. Firstly, it will be difficult to address the sheer variety of sizes, structures and arrangements present in schemes. Secondly, we feel that templates are more likely to lead to a box ticking culture, whereby if something does not appear on a template it is not examined. The intention of the code is to provoke questions and drive consideration of scheme issues, which will differ from scheme to scheme. We feel producing a template would run counter to this.

We have set a broad, principle-based risk management framework. It is intended to give users the sense of what we expect in terms of risk management, but not to dictate how that is achieved. This will allow governing bodies to address their own scheme risks, in their own way. It will also allow them to place appropriate weight to processes and assurance conducted by themselves, service providers or third parties.

TGB022 – Scheme continuity planning

You said:

Several concerns were raised around the degree that our expectations might impose an unsustainable burden on smaller schemes. Some of these concerns were about the potential compliance costs, while others were about whether small schemes would have sufficient influence with service providers to improve their business continuity plan provision.

We received requests about clarifying which schemes should follow this module. As mentioned elsewhere, we have taken steps to remedy this generally. We also received requests to clarify the risks that should be covered in a continuity plan. The general theme was that any planning should be broad based and include consideration of a wide variety of risks and their potential impacts.

Alongside requests for guidance from some respondents, a few others made helpful suggestions for resources to assist with business continuity planning.

Our response:

We are careful about placing potential burdens on small schemes. This is particularly the case for schemes that wish to meet our expectations and deliver value to their members. For that reason, we have introduced an element of proportionality to this module. This will provide some leeway, especially in the cases where services are provided by third parties. We hope that this approach will encourage smaller schemes to find their collective voices with service providers and demand improvements where they are needed.

We accept the requests we received about clarity. It is important that schemes consider a wide variety of impacts when carrying out their continuity planning. Recent global events have shown the value of planning for a range of possibilities, from temporary disruptions to systemic upheavals. We have sought to make that clearer within the module. However, this is balanced by the need to acknowledge the proportionality that must exist, especially for smaller schemes.

We have no intention of providing additional guidance on this module now, as the resources available to governing bodies from third parties are already significant. But we have adopted one suggestion and now point to the relevant British ISO standard for resources to assist schemes in their continuity planning.

TGB039 – Conflicts of interest

You said:

Our approach to including expectations for conflicts of interest was generally well received, with few negative comments. We had several comments asking us to clarify the applicability and improve the layout to reduce some confusion between paragraphs.

We also received several comments where we were asked not to expect any register of conflicts to be published.

We were also asked for guidance on the identification and handling of conflicts of interest.

Our response:

As a result of the comments received, we have restructured the module and removed or reworded some references that might have caused confusion.

We have retained our expectation about publishing the register of conflicts. Importantly, this only requires the governing body to consider whether to publish the register. We do not consider that this presents an onerous requirement as we only expect governing bodies to give due consideration to whether they publish the register.  Governing bodies can still decide not to publish.

Requests for guidance were common to almost all modules. We already have extensive and longstanding guidance on conflicts of interest. In the final web version of the code, we will provide clearer links to guidance to help users access relevant associated materials.

TGB045 – Own risk assessment

You said:

Some suggested changing the module title to reflect the focus of the own risk assessment (ORA) on governance.

Most comments were about making the ORA simpler for schemes to complete. Specifically, requesting further guidance and in many cases a template.

Several respondents pointed out that as drafted, the ORA would have required governing bodies to redo work that had already taken place. This might be because of effective systems of governance (ESOG) requirements, or through regular governance work that was already being undertaken.

We received a lot of commentary on our proposed timescale for producing the first and successive ORAs. Some respondents acknowledged that there was flexibility in the legislation for us to set our own expectations on the frequency of the ORA. Others felt that we did not have this flexibility and that the ORA should be produced in accordance with the timings set out in the legislation. Both groups tended to agree that our proposed timetable was too onerous. Several felt that an annual cycle would be too much work for an average governing body. Some also commented on the replication of work that was implied by having to produce an ORA that covered areas that were already the subject of governance reviews.

There was little consensus on whether the ORA should be carried out as a single piece of work, or as an ongoing process throughout the available time. Some consultancies reported a preference for a single piece of work where this aligned with another scheme event. Examples given included scheme year ends and actuarial valuations.

Our response:

We have retained the original module title. The own risk assessment is an obligation set out in legislation and is now well known within the industry. Changing the title does not seem to make any real sense from a user perspective.

In response to various smaller queries, we have clarified the purpose of the ORA. These have resulted in a clearer objective for the ORA, and a more flexible approach allowing schemes to shape their ORA so that it is a useful governance product. We have also made it clearer that there is a difference between the ORA and ordinary business as usual risk processes.

The original wording of the module suggested that the work involved in producing the ORA would be significant. This was aimed at those governing bodies whose governance was not meeting expected standards. Unfortunately, the wording used did not convey this. While we do believe that the ORA may represent a significant piece of work for some governing bodies, we believe that in the final form, the ORA should be a more straightforward project for any well-run scheme. Whilst the ORA is important, we believe that the focus of governance activities should be on maintaining an effective system of governance. The ORA is a review of the ESOG and therefore cannot be carried out without an ESOG in place.

We do not have any current plans to produce guidance on completing the ORA. The aim of the ORA is for the governing body to assess how well their system of governance is working. Given the high degree of variability in the implementation of an ESOG and what might be considered proportionate in each case, it is difficult for us to envisage which areas might need further guidance. However, we will monitor the situation and if we see a genuine demand then we will reconsider whether guidance is needed.

We considered whether it was necessary, or possible, to produce a standard template to aid governing bodies in completing their ORA. The ORA applies to schemes of vastly different scales and is highly tailored to the circumstances of each scheme. We concluded that any template would simply end up repeating the various topic headings from the module itself. As a result, we have no current plans to produce a template for the ORA.

Our intention had always been that the ORA should be a piece of work that built on existing processes and added value. We cannot see any value added from replicating work simply to fulfil one of our requirements. Therefore, we have confirmed that the ORA can reuse material that examines the same areas covered by the schemes existing risk assessment processes. This only applies where that material is within a timeframe relevant to the production of the ORA. In this vein, we have also relaxed our expectations for the frequency of the ORA. While we believe that a regular review of processes is a key feature of good governance, it can also mean that other work is not prioritised appropriately. We have therefore allowed schemes to complete an ORA on their own timetable, and in part or in whole, provided it is carried out in its entirety at least every three years. We have also chosen to relax the point at which the first ORA needs to be published. We are adopting the maxima as set out in legislation as the timescale. However, we believe that governing bodies should still try to review their ORA as an ongoing process as part of their regular governance oversight.

TGB052 – Risk management function

You said:

The risk management function was first discussed in the internal controls modules. Respondents had several questions regarding our minimalist approach to explaining the function.

Concerns about small and medium schemes led a few respondents to ask how independent the risk management function needed to be from the rest of the governing body, or the functions of the scheme. Similarly, there was interest in who and which bodies could carry out the risk management function. There were also concerns that for smaller schemes, establishing a separate and stand-alone risk management function might not be practically possible.

Our response:

As a result of the consultation responses, we provided more detail on the risk management function and gave it its own module, which links back to other modules dealing with risks.

The risk management function is an important one and it is vital that it is an integral part of scheme governance. We recognise the concerns expressed about the proportionality and practicality of some smaller schemes being required to establish a separate, stand alone, risk management function. Consequently, we have not been prescriptive about who should perform the function, or how they should perform it. Instead, we have focussed on what they should be doing. This will enable governing bodies to design a risk management function to suit their scheme, the way they run it and the resources they have available.

Scheme governance

TGB046 – Systems of governance

You said:

As this module is almost totally focussed on effective systems of governance, we received several comments suggesting that we rename to that.

A couple of respondents were concerned about the burden of maintaining the necessary policies and procedures that form the ESOG. However, they did not present alternatives to this documentation.

Some felt that the ESOG was something that would lead to box-ticking governance. This was also the case where the ESOG appeared to be duplicating processes that schemes would already be running.

Our response:

We considered renaming the module. However, we believe that it represents a useful starting point for any scheme looking to establish good governance, whether they are required to maintain an ESOG or not. We have therefore chosen not to amend the title.

Documenting policies that form the ESOG is a legislative requirement. We also remain concerned that a lack of documentation could lead to a failure to properly follow procedures for good governance because of, for example, loss of key staff who knew the procedures or members of the governing body with historic knowledge of issues.

We consider that the ESOG is predominately a rebadging of things that the governing bodies of well-run schemes should be doing already. For other schemes, it may highlight aspects of governance that they do not currently meet. There will also be some new requirements that most schemes do not yet have in place, such as the remuneration policy. the work that governing bodies already do, we have made it clear that the ESOG can incorporate existing policies and procedures in the same way that the own risk assessment does. Our intention is that governing bodies will use our bulleted expectations as questions to start a dialogue on whether and how they meet an expectation, and whether it is operating as intended, or could be improved. We recognise that some governing bodies may wish to pursue a tick-box compliance with the code, which is their choice. In such instances however, we hope that tick-box compliance will represent a greater degree of governance than such a scheme currently receives.


FAI001 – Investment governance

You said:

While we received various points of commentary on this module, there were no standout themes as such. Some concerns were raised about specific expectations, and these were also echoed in linked funding and investment modules, where that expectation held more context. For example, various respondents commented that quarterly monitoring could prove a burden – a key theme we saw among the responses to the investment monitoring module.

It was also highlighted that not all governing bodies of defined benefit (DB) or defined contribution (DC) schemes are required to produce a statement of investment principles (SIP), or an implementation report – which we now refer to as an implementation statement.

Others fed back how specific expectations could be misinterpreted due to the wording we had chosen, or in some cases, difficult to meet under certain circumstances.

Our response:

We have aligned our expectation on regular investment monitoring with our amended expectation within the investment monitoring module. More details on this amendment can be found in our full response to that module below.

We agree the module could have been clearer in highlighting that some governing bodies will be exempt from the SIP and implementation statement requirements. We have now included lines to highlight this, while details of the specific exemptions remain within linked modules and/or through the corresponding legislative footnotes. More information on how we have harmonised terminology with industry on implementation statements can be found in our responses to the implementation report module, which has now been retired.

We noted some confusion around the meaning of our expectation for having written policies covering the use of advisers, we have now amended the wording slightly for clarity, but no material changes have been made to what we expect of governing bodies.

There were some suggestions that having policies covering when to use advisers could be an unnecessary burden. However, we maintain that such policies are key to mitigating the risk of decisions being made by those with insufficient knowledge or lack of legal authority. In addition to improving overall governance of the scheme, this process should also help governing bodies identify where their strengths and weaknesses lie in relation to investment.

One area that we have relaxed an expectation is around value for members (VFM), during the replacement or modification of existing investment arrangements in a scheme with a DC element. Previously, we had set out that governing bodies should manage transition costs in this process ‘to maintain’ VFM. Respondents correctly highlighted that such costs only form one aspect of VFM, and that ‘to maintain’ could mean to not reduce members’ funds at all, because of such costs – even where necessary and appropriate. VFM should be a key consideration during this process and our amended expectation now reflects this.

FAI003 – Investment decision-making

You said:

Of the large number of responses we received, a significant majority focused on, or referred to the expectation we had set out on unregulated investments – often referred to as the 80% or 20% rule.

We also received some feedback about our choice of words in some areas of the module. Most notably, a few respondents raised concerns about our introductory paragraphs – questioning the meaning of specifying lesser requirements on governing bodies of schemes with less than 100 members.

Our response:

As explained in our interim response to the consultation, we recognise that in setting out the expectation relating to unregulated investments, we had inadvertently created a position that could negatively impact well governed schemes that hold such assets as part of well-managed investment strategies.

We listened to the strongly argued comments we received while we explored options for achieving our policy objective, that is – to protect members of poorly run, and typically small schemes from investments in poor quality or inappropriate assets. Having done so, we have decided to re-align our policy in this new code of practice with the one in our previous DC code of practice. We will continue to monitor its effectiveness as the new code embeds through our regulated community.

As consulted, the introductory paragraphs included wording relating to investment requirements for trust-based schemes of different membership sizes. These requirements haven’t changed, however for clarity, we've now presented these in list form for schemes with 100 members or more. While we see the benefit of schemes with fewer than 100 members following the same principles. They are not required to do so by law, and therefore we cannot stipulate such requirements. But we have listened to respondents’ concerns that our initial wording might have led to smaller schemes dismissing the value of following these principles and as a result, have now highlighted them as good practice.

We also agreed with respondents that our glossary definition of decumulation was overly simple and have reworded this for clarity – a definition for the term bespoke arrangement has also been included as requested.

FAI004 – Implementation report

You said:

We received many constructive, though generally negative comments about this module. These mainly focused on, or were linked to, the title name ‘implementation report’, namely how this was unfamiliar to respondents. There was some confusion over whether we were really referring to, as known as in our regulated community, the implementation statement. Most assumed this was our intent but felt the requirements had been oversimplified in our aim of keeping our code succinct.

Our response:

We recognise that by naming this module implementation report, we had created confusion in a relatively new area for industry, that is, implementation statements, which respondents were hoping for clear information from us. We accept our mistake in that regard, and now adopt the term ‘implementation statement’ throughout the code, bringing it in line with industry.

While this module no longer appears within the code, the implementation statement requirements themselves are still present. These now sit within the stewardship module where the intent of the implementation statement is overall clearer. We have also taken on board respondents’ comments relating to the oversimplification of requirements, now providing greater detail to these in a more structured format, while further practical details can be found in the TPR and DWP guidance linked within the module.

FAI005 – Investment monitoring

You said:

Some raised concerns about how we had set out some of our expectations, specifically under the subheading ‘governing bodies should set expectations for their investment managers to’. They felt it was unclear whether we were suggesting governing bodies should be setting the listed expectations for their investment managers to meet, or that the listed expectations were for the governing bodies to meet themselves.

Many noted that we had not made a direct reference to the Competition and Markets Authority’s (CMA) strategic objectives requirements and sought further guidance on this. Others requested more general guidance to accompany the content, including practical details on how our expectations could be met.

While most respondents understood the basis and need for the expectations we had set out, some felt we had been too prescriptive in places, particularly in relation to quarterly investment monitoring. Others questioned whether the module focused or could lead to the focus leaning too heavily on, short-term performance.

Our response:

We have sought to clarify the intent and meaning behind various expectations. The expectations we set out are for governing bodies to meet. And governing bodies should set their own expectations for their investment managers where relevant – for the governing bodies to meet our listed expectations of them.

We have brought all our expectations under the preceding line of ‘governing bodies should’. By separating out our expectation that governing bodies should set expectations for their investment managers where relevant, we have removed the ambiguity around who needs to meet those expectations and how they can be met.

Some expectations have been broadened or loosened in response to the feedback we received. For example, where we had previously listed stress tests or scenario tests as means to assess the impact of changing circumstances on scheme assets, we have now expanded to allow for other relevant risk assessment information to be relied upon.

As with other modules in the code, where the CMA requirements would seem relevant, we intentionally excluded detail to these requirements in this phase of the code. The Department for Work and Pensions (DWP) brought certain duties from the CMA Order into pension legislation from October 22, and we will be able to provide details of our expectations in a later phase of the code. For now, we have updated the guidance on our website.

Investment monitoring is most effective when it’s prioritised and frequent. We see the value of regular monitoring in helping to identify issues where governing bodies might need to act. However, we have, following the feedback we received, decided to allow some further flexibility to the frequency of which governing bodies should be reviewing their investments.

We no longer prescribe that a review should be carried out at least quarterly, instead we expect this to be done regularly. Regularly may mean quarterly for some schemes, depending on their circumstances. But we acknowledge that many well governed schemes’ trustees are more likely to meet every four months, and therefore, quarterly reviews could likely prove to be practically unachievable.

Nevertheless, we still believe that monitoring information should be prepared quarterly to ensure governing bodies have the necessary information to perform effective reviews – as also highlighted by some respondents.

We encourage governing bodies not to be unduly distracted by short-term performance issues, if they have concluded there is a good explanation, and we do not expect our expectations would invertedly lead to this. We do agree with the various respondents who suggested including reference to long-term performance within the module would make this clearer, and we have therefore done so.

FAI006 – Stewardship

You said:

Most respondents felt the title ‘stewardship’ to be appropriate in the context of the module content. Overall, those who felt a disconnect between the title and the content gave the lack of a comprehensive stewardship definition as the reason.

Linked to this, we received various comments that questioned the general cohesion of the module, with many feeling there to be a disjointed and unclear connection between stewardship and environmental, social and governance (ESG) matters – noting that the introductory paragraphs focused directly on ESG issues.

Respondents felt the module would also benefit from more links and connections between it and other relevant areas of the code. There was a clear call for further guidance within the responses too, with many commenting on the likely barriers governing bodies would face when taking on an active role as stewards for their scheme investments. Some of these barriers were also highlighted in respect of the expectations we had set out in the module.

Nevertheless, most respondents seemed to welcome, in principle, the introduction of expectations and recommendations for governing bodies in relation to stewardship, reflecting the increasing importance of the governing body’s role in encouraging, developing, and supporting practices throughout the investment chain to deliver sustainable value for their members.

Our response:

While we have retained the original title of the module, we have listened to concerns and suggestions with the aim to increase its relevance and appropriateness.

As requested, the module now begins with an introduction to stewardship along with clear details on how considering ESG matters forms part of effective stewardship more generally. We have also now defined stewardship more clearly and comprehensively by bringing it in line with the Financial Reporting Council’s (FRC) own definition, which was endorsed by respondents.

Beyond this, we have also worked to provide more useful and in-depth information in areas that form part of stewardship more broadly. For example, where we had previously included a short line on the relevant policy from the SIP, we now expand in greater detail to help readers better understand the requirements that apply. More information on the SIP and default arrangement SIP, including how we expect these to be prepared and maintained, can then be found by following the link to the statement of investment principles module itself.

Due to the nature and intent of the implementation statement, details of the requirements relating to it now appear within the stewardship module too. More information on how we’ve harmonised terminology with industry on implementation statements, referred to as implementation reports in the draft code, can be found in our response to the implementation report modules, which has now been retired.

It was always our intention to signpost, and where possible provide links to relevant internal and external guidance in the final version of the code, and we now do this. Some of the concerns raised by respondents are addressed and covered in detail in the guidance available. For example, the ’s guidance provides detail to some of the reported barriers in relation to stewardship, such as how trustees, even when invested in pooled funds, can seek to influence their investment manager’s stewardship practices. And we encourage governing bodies to look beyond our code and seek professional advice where necessary or appropriate.

We have amended the wording of some of our expectations in response to feedback. Overall, these amendments seek to clarify the intent behind them, but in places some amendments will have resulted in a slight change to what our expectation means in practice. In one instance, rather than expecting that governing bodies seek to follow the FRC’s stewardship code, we now set out that governing bodies should consider following the principles in that code. Similarly, we have adjusted the expectation for governing bodies to engage with investee companies and industry initiatives.  This is now an example where governing bodies should seek to participate in such engagement. In both cases we agreed with respondents that this is a more pragmatic approach. 

We also received various suggestions, ideas, and signposting to external resources for consideration in the development of our policy in this area, which we would like to thank respondents for.

FAI011 – Climate change

You said:

The dominant theme we saw within the responses to this module surrounded the Task Force on Climate-Related Financial Disclosure requirements. Overall, these responses questioned why we hadn't ’t made any reference to these requirements, given that at the time of the consultation it was clear the regulations would be coming into force in due course.

Respondents requested that we include details of these requirements in the code, and that we provide further guidance on how governing bodies can meet the requirements.

Our response:

At the time of drafting the new code of practice prior to the consultation period, the DWP were still in their own consultation and development stage for the climate-related governance and disclosures requirements proposals.

While there were indicative timelines for when the regulations would come into force and a relatively clear view of what they would look like, it is the case that there ’t complete certainty. As such, it would not have been appropriate for us to include details to these then prospective requirements in the draft code.

We had intended to include this in a later phase of the code. However, having considered the feedback and recognising that the code would be coming into force later than initially anticipated, we decided to do so now instead. We have set these out at high level and included the relevant legislative references within the footnotes of the module.

Since consulting on the code, DWP have issued statutory guidance, which governing bodies subject to these requirements must have regard to also developed guidance which we encourage reading alongside the statutory guidance. Links to both pieces of guidance have been provided in the code, and they provide more practical details on what the requirements mean for those in scope.

As we also saw with the stewardship module responses, we received various suggestions, ideas, and signposting to external resources for consideration in the development of our policy in this area, which we’d again like to thank respondents for.

FAI008 – Statement of investment principles

You said:

We received a few comments on various areas of the module content with no key themes as such. A few respondents questioned the relevance of some of the expectations we had set out – specifically as to how they would apply in the context of preparing the SIP. Others suggested tweaks to some of the wording we had chosen to improve the overall readability of the module.

Some comments were made on the intent behind our expectations relating to ESG considerations, highlighting that as worded, we had narrowed their scope to only where a pooled fund is chosen.

Certain respondents felt the expectation that governing bodies should take account of types of investments that members prefer to be unreasonable and beyond legal requirements.

Our response:

We have restructured the module in areas and amended some of the wording to improve the usability and to provide additional context to the expectations we set out. One main way in which we have done this is through linking our expectations to the process of maintaining the SIP, as well as to the process of preparing the SIP. The relevance of each of the expectations we have set out in relation to the SIP should now be clearer by framing them in this way, which remains in line with our initial intent.

In the preparation and ongoing maintenance of their SIP, governing bodies should understand the ESG approach of all available funds and consider this in the selection criteria for new funds. They should also monitor how investment managers consider ESG factors in practice. It was highlighted that the way in which we had set this out meant it wasn’t clear whether this expectation applied exclusively in situations where a pooled fund is chosen.

We recognise the reported barriers in meeting these expectations where a pooled fund is chosen. We singled out pooled funds with the aim of highlighting that our expectations do, irrespective of the reported barriers, still apply. We agree that this had invertedly created some ambiguity on the scope, and therefore have reworded the expectations to clarify that they apply where any type of funds is chosen, including pooled funds.

While we do not expect governing bodies to consult with members on every aspect of their investment preferences, we remain convinced that governing bodies should consider representations that members make about their preferences. It should also be possible to make assumptions based on the information governing bodies may already know about their membership profile. Understanding member views and preferences, particularly to inform the design of investment strategies, are key to achieving good outcomes for members, and so we have not amended this expectation.

FAI010 – Default arrangements and charge restrictions

You said:

While in general, respondents felt that what we had set out was clear, various comments did say that the module would benefit from additional detail. This was the case both for the default arrangement section, as well as the charges and cost restrictions section of the module.

A few suggested including information on the identification of default arrangements within a scheme where they may have been created inadvertently. For example, because of a temporary closure of existing funds (gating), or when an investment mapping exercise takes place.

Additionally, there was a clear request for further links and references to other relevant areas of the code and guidance material.

Our response:

When drafting this module, we sought to keep things succinct and focused on what governing bodies must be doing and considering in relation to their default arrangements and charges and cost restrictions.

We recognise that this is a different approach to that taken in some of the other modules of the code, however it would not have been practical, or appropriate, to outline or detail all the complexities and nuances of the requirements for both topic areas. Partly due to scale of content that would be required, partly due to the intricacies within legislation that dictate what governing bodies must do in different circumstances – intricacies that will often mean governing bodies need to seek out scheme specific professional advice, which we cannot provide. Principally however, we considered that the topics are covered sufficiently in existing TPR and DWP guidance.

Replicating detailed information that exists already in guidance would have been counter to part of the intent behind the code – that is to reduce unnecessary repetition. It is also the case that this level of detail is better suited in guidance – where practical details and examples exist – including on the issues of gating and fund mapping. Links to relevant guidance material will be provided in the live code.

Nevertheless, we do agree that the module could have had a greater number of links and references to other areas of the code. We have now included this, while also rewording some of the content for additional clarity.

Scheme administration

ADM001 – Planning and maintaining administration

You said:

The greatest number of responses on a single topic on this module were in relation to the title. Many felt that it would be better described in relation to governance or supervision.

Other respondents noted that there is comparatively little guidance available to governing bodies to understand what is expected of them and their administrators.

Our response:

We feel that the current title is broader than the alternatives suggested, which focusses on just one aspect of the module contents. For that reason, we have kept the original title.

We do not totally agree that there is little guidance on administration. We have highlighted the importance of administration and record keeping at various points, and in relation to specific tasks. These items would be a good place to start when considering where to focus scrutiny of administration, along with existing administration guidance on our website . There are also third-party organisations such as Pensions Administration Standards Association (PASA), who produce their own materials on good administration practices.

Information handling

ADM002 – Financial transactions

You said:

This module attracted many comments, mostly from those concerned about the degree of governance expected. Some noted delays to certain processes might be outside of the direct control of the governing body. Certain comments also sought to distance the governing body from the responsibility of administration where it is outsourced.

Our response:

We accept the argument, that governing bodies may not be able to control everything related to their scheme. But they can bring pressure on service providers and employers where expectations are not being met. Even where it is outside of the governing body’s direct control, poor administration should not be tolerated or considered unavoidable. It is always the case that the governing body is ultimately accountable for the activity of its scheme, even where functions are outsourced. As a result, we have sought to clarify several of our expectations to make it clear where there are responsibilities that trustees should make clear to other parties.

ADM014 – Transfers out

You said:

This module attempts to summarise the responsibilities of trustees in relation to transfers from their scheme. There are few expectations presented, with most content being legal requirements. Consequently, there were few issues raised with the expectations that we have set. However, several respondents felt that the original title, transfers, did not accurately represent the content of the module. They felt that there could be confusion about whether this presented expectations for treatment of transfers into a scheme as well.

Several noted that we had made a mistake in the time permitted to provide a statement of entitlement, an error that we were pleased to correct.

Some also noticed that there was no direct link between this module and the one dealing with scams.

Our response:

We agree with the comments, the title of the module was too broad and have therefore retitled it, to make it clear that we are only considering the matter of transfers out of a scheme.

We have added more direct links between this module and the one dealing with scams. We have also taken some steps to reflect the change in transfer regulations after this consultation. These changes allow trustees to refer savers to guidance, or to block a transfer where they have suspicions about the receiving scheme. We have set no additional expectations about the legislation in the code, and instead refer to both the legislation itself and our guidance.

ADM003 – Record keeping

You said:

The principal theme of comments was the fact that in most cases the governing body does not actually carry out the administration itself. As a result, some respondents felt that it was inappropriate to place too much of a burden directly on the governing body.

The consultation draft retained earlier expectations that schemes maintain 100% data accuracy and seek to immediately correct any deficiencies found. Several people pointed out that total data accuracy was an unlikely achievement for any scheme. Similarly, it would be disproportionate to update certain information regularly, for example when it wasn’t likely to be needed for several years.

Our response:

We have made it clear throughout the code that the responsibility for carrying out any scheme function ultimately rests on the governing body. We recognise that most bodies delegate many functions, not least administration, to other parties. It remains though, the responsibility of the governing body to ensure that the scheme is administered correctly. So, it needs to make sure that the relevant processes and procedures are in place to ensure this.

We have made it clear that governing bodies should seek to maintain their data. However, they can prioritise data cleansing to focus on those things that are most important, for example, whatever is necessary to pay and value benefits. We have retained an expectation that data cleansing should be carried out as soon as feasible to limit the amount of remedial work that needs to be carried out at any one time. A key future driver for this work, acknowledged by some respondents, will be the new pensions dashboards which will require schemes to have accurate data, not just to identify benefits, but also to correctly display their values.

ADM006 – Data monitoring improvement

You said:

We received relatively few comments on this module, with most being on general matters. Several respondents highlighted the title of the module as being misleading, while others felt that it would be better to merge it with the preceding module on record keeping.

Some made specific reference to the use of decumulation, which could be confusing if it is not in general use. Other respondents noticed that it was not clear to whom some of our expectations referred.

Our response:

In response to the feedback received, we have changed the title of the module from ‘data monitoring’ to ‘data monitoring and improvement’. We have kept the module separate from the associated module on record keeping because the application of our expectations is different. Keeping the modules separate allows us more freedom to update them in the future.

We have considered the comments we received about ambiguous or unclear wording in this module and have sought to revise it accordingly. We have also added references to common and conditional data and existing expectations from the current code, 14 relating records of meetings and proportionality of data monitoring processes.


ADM015 – Maintenance of IT systems

You said:

The comments we received on this module focused almost exclusively on one area, the need for it to work where administration is outsourced to a third party.

Our response:

As a result of the feedback received, we have made it clearer that our expectations apply to governing bodies in a way that they should be satisfied that our expectations are being met. In this way the focus is broadened and made more appropriate for most schemes that do not carry out their own administration.

ADM016 – Cyber controls

You said:

As with the previous module, this was another one where respondents highlighted the need to rely on third parties. This reliance came in two distinct areas: in the application of the controls themselves, and in testing, validating, and assessing those controls.

Some respondents suggested that we should go further in our expectations and highlight specific issues or mitigations.

Our response:

We recognise both areas of reliance highlighted by respondents and had done from the outset of our work. However, we accept that this could have been clearer in the first draft of this module. We have therefore sought to clarify that we do not necessarily expect the governing body to have the requisite expertise, and that reliance on third parties is entirely acceptable, although we have stopped short of making it a recommendation.

We agree that there is a lot more that could be said about cyber security. However, other bodies have greater expertise in this area and it is not our core function as a regulator. The web version of the code will highlight organisations and resources that are useful when considering cyber security.


ADM007 – Receiving contributions

You said:

Overall, respondents agreed that our expectations were clear and transferable to their arrangements. Some did query how these would apply to public service pension schemes (PSPS) and whether the content on reporting and remedial actions was relevant to this module.

Most agreed that the subject matter had been covered sufficiently. There were some requests for expectations to be added to this module about investing contribution, as well as requests for the code related guidance to be updated and include case studies.

Some felt that greater clarity was needed in areas that should be considered materially significant and reported to us.

Several requests were made for further terms to be added to the glossary for this module.

Our response:

Further to the feedback received, we have taken steps to clarify the application to PSPS and we have moved content relating to remedial actions and reporting payment failures to the appropriate modules.

Our design of the code modules is intended to be bitesize and focus on a particular matter. For this reason, we do not believe it would be appropriate to move or otherwise duplicate our existing expectations from the funding and investment category within this module. We are considering what updates are necessary to our existing code related guidance so that it may continue to support those using the code further to this redevelopment.

The content relating to reporting has now been removed from this module and a new module titled ‘reporting payment failures’ has been introduced to provide more detail and clarify our expectations on this matter.

We agreed it would be helpful to define the items requested and further terms have been added to the glossary.

ADM008 – Monitoring contributions

You said:

Most respondents confirmed our expectations were clear from the content. There were some queries on whether a contribution monitoring record needs to be separate from a contribution schedule and whether one would need to be created for each employer associated with a scheme.

Several stated it would be helpful for there to be more detail on reporting payment failures in this module. Some also questioned whether existing code related guidance would be retained. One respondent suggested it would be helpful for wording in paragraph 150 of code of practice No.14, to be carried over to this module.

It was also noted that most expectations within this module have been in place for some time. However, several responses highlighted that the 14-day period in which governing bodies should report employers, that fail to provide the necessary information when requested, as being an unreasonably short period of time. They suggest that if this period were extended, then this would avoid several reports for matters that were resolved just outside of the 14-day period from being made.

Requests were made to add the definition of payment schedule to the glossary. Further respondents suggested combining this content with receiving contributions and resolving overdue contributions.

Most agreed the timescales were appropriate. There were also several responses mirroring the feedback from question 4, that the 14-day period for governing bodies to report employers that fail to provide information was too short. Others also commented that reference to working days had been replaced by days.

Our response:

No changes were made to our expectations considering the comments received for this question. Whether a contribution monitoring record needs to be separate from a contribution schedule or if one is required per employee – the governing body will need to consider the specific circumstance of their scheme and exercise its discretion as to what is proportionate and effective for their scheme.

Following a few responses relating to reporting across the three contributions modules, a new module has been added to the reporting to TPR section about reporting payment failures. The existing code related guidance for code 5 and 6 will be reviewed and updated as necessary in due course. We have also made amendments to the opening of this module so that it better aligns to paragraph 150 of code No. 14.

Further to feedback that the 14-day period for reporting employers who fail to provide payment information was too short – we have reviewed this and agree that the expectation is now outdated. We have extended the period to 28 days.

We have added definitions for both payment schedules and schedules of contributions from the relevant legislation. By design of the new code, we have broken down content to more digestible modules. There is a high level of interaction between the three modules consulted on. We expect an easy transition between these, in the final online version, by using links. This may not have translated as well in the draft PDF copy.

As stated above, we have already extended the 14-day period to 28 days for governing bodies to report failures to provide information. Further to this, we have replaced references to working days with days to be consistent across the new code.

ADM011 – Resolving overdue contributions

You said:

Several respondents highlighted that module contents would be made clearer by adding ‘unpaid’ or ‘overdue’ to the title.

Many felt our expectations for reporting payment failures were unclear and helpful information regarding what we view as materially significant had not come across from the original content. Further to this, we were also asked to provide a definition of ‘payment failures’.

Like responses for the previous question, it was highlighted that more information should be given as to when a payment failure would need to be reported.

Our response:

Further to comments received, we agree the heading for this module could be clearer and we have now renamed this ‘resolving overdue contributions’.

We have removed the content on reporting payment failures from this module and used this to form a separate module under reporting to TPR. This new module, titled ‘reporting payment failures’, contains the content consulted on, as well as examples of situations we consider materially significant that would need to be reported and common examples of matters we do not consider as materially significant. We have also added the definition of ‘payment failure’ to the glossaries of both modules.

Issues resolved by creating a specific code module for reporting payment failures.

Information to members

CAD001 – General principles for member communications

You said:

Respondents raised that some expectations could not be applied to all types of arrangements. Further to this, some respondents felt it would be helpful to summarise all exemptions to legal requirements within the module. Several also suggested it would be helpful to detail all disclosures required by legislation.

Many highlighted that this module should have a link to our guidance produced in association with the FCA, the ‘guide for employers and trustees on providing support with financial matters without needing to be subject to FCA regulation’, as well as our communicating and reporting guide. In addition to this, several requests were made for specific case studies to explore the development of communications for specific requirements.

No specific expectations were identified as disproportionate or unreasonable burdens by respondents. However, one respondent suggested that it may not be practical for governing bodies to apply these principles where they have delegated communication activities to a third-party administrator.

Many suggestions were made to link this module to specific sections of the new code.

Our response

We have made changes to make clear expectations regarding the impact of contributions only apply to certain scheme types. We have included additional considerations about inclusivity when designing communications and factors that may trigger a review of them.  When we considered the design of the new code of practice, we felt it would be appropriate to include exemptions by legislative reference, so that we could focus on communicating our expectations. While we appreciate that a summary of all disclosures required by law may benefit governing bodies, we do not believe such an inclusion would meet our intent for this module, which is to set general expectations for communicating with members. There are several other areas of the code that set expectations for specific disclosures, which also signpost to this module.

The links to guidance and relevant information will be included and operational when the new web-based version goes live. While we do not believe our code is the appropriate location for detailed guidance, we can in future consider the inclusion of case studies in our existing guidance.

As with all expectations set by us within the code of practice, it is for the governing body to determine how to meet these proportionately based on their specific circumstances. In the case of meeting our expectation where the activity has been delegated beyond the governing body, they should ensure they act according to the expectations expressed in managing and appointing service providers module of the code. As in most cases, ultimate responsibility for meeting expectations will rest with the governing body.

We were unable to activate links within the PDF draft of the code provided with the consultation. However, this module will be linked to from other modules of the code, that set expectations in relation to required communications, when the web-based version goes live. 

CAD003 – Annual pension benefit statements (DC)

You said:

Most respondents suggested using more commonly used terms for the three modules that had previously been labelled ‘financial statements’ to avoid confusion with other scheme documentation.

Many respondents agreed the expectations are made clear within the content and suggested it would be helpful to provide a link to the DWP guidance for simpler annual benefit statements. Further to this, some felt it would be helpful to summarise all exemptions to legal requirements within the module.

Again, many in response to this question suggested including a link to DWP’s simpler annual benefit statements.

Several requested more content in relation to producing digital communications.

Our response

We have amended the title of the three ‘financial statement’ modules, to make this more readily identifiable for users.

A link to the DWP’s guidance will be included in the web-based version of the code when this goes live. When we considered the design of the new code of practice, we felt it would be appropriate to include exemptions by legislative reference, so that we could focus on communicating our expectations.

While we do not believe this code to be the appropriate location for providing guidance for producing digital communications, we will consider the request.

CAD011 – Summary funding and pension benefit statements (DB)

You said

Most respondents suggested using more commonly used terms for the three modules that had previously been labelled ‘financial statements’, to avoid confusion with other scheme documentation.

Several commented that the time frame provided in the introductory paragraph was unclear. Some also suggested an imbalance between the level of detail provided for the summary funding statement and the benefit statement. Further to this, some respondents felt it would be helpful to summarise all exemptions to legal requirements within the module. It was also highlighted that the first point in the list relating to summary funding statements should refer to both actuarial valuations and actuarial reports.

Similarly, to responses to the previous question, many of the respondents requested more detail to be included on the requirements for benefit statements.

Several terms were requested to be added to the glossary for this module, along with an amendment to the definition given for recovery plans.

Our response:

We have amended the title of the three ‘financial statement’ modules to make this more readily identifiable for users.

We have made an amendment to clarify the summary funding statement must be provided within a reasonable timeframe from the date when the trustees must receive each actuarial valuation or actuarial report. To address the reported imbalance between the summary funding and benefit statement sections, we have added further detail for benefit statement requirements. When considering the design of the new code of practice, we felt it would be appropriate to include exemptions by legislative reference, so that we could focus on communicating our expectations. The list or requirements for the summary funding statements has been updated to refer to actuarial reports.

All terms requests have been added to the glossary and the issue identified for the definition given for recovery plans has been resolved.

CAD012 – Benefit information statements (PSPS)

You said:

Most respondents suggested using more commonly used terms for the three modules that had previously been labelled ‘financial statements’ to avoid confusion with other scheme documentation.

Most respondents agreed our expectations were clear within the module but commented that it would be appropriate to include pension credit members in the list of those who must receive annual benefit information statements. Further to this, some felt it would be helpful to summarise all exemptions to legal requirements within the module.

Several requested a link to be included to HM Treasury Directions and our existing guidance for statements.

One respondent requested more information about statement requirements for defined contribution benefits.

Our response:

We have amended the title of the three ‘financial statement’ modules to make this more readily identifiable for users.

In response to suggestions made, we agreed it would be appropriate to include pension credit members. When considering the design of the new code of practice, we felt it would be appropriate to include exemptions by legislative reference, so that we could focus on communicating our expectations.

Both links requested will be present in the final web-based version of the code when it goes live.

Rather than duplicate existing content within this code, we have included a link to the annual pension benefit statement (DC) module, we have adopted this approach throughout the new code, and you will find links to related content.

CAD004 –Retirement risk warnings and guidance

You said:

Most respondents agreed the title is a fair reflection of the content for this module. Several respondents suggested adding ‘DC’ to the title.

A few commented that the layout of this module could be improved to make expectations clearer. We were also informed of an error in appendix one of the consultation documents, on the application of this module to scheme types.

Several respondents requested links to both our existing guidance as well as to the government’s service.

A few made comments on the definitions given in the glossary, where these have been inconsistent across the code, such as beneficiary.

Our response:

After considering the responses received, we have not made a change to the title at this time, as the module is relevant to other types of arrangements as set out within the content. However, we continue to investigate options for users to filter and search within the new web-based code to better suit user needs.

After a review, we have made amendments to the content layout, including the addition of subheadings to help users navigate between our expectations for risk warnings and retirement guidance. Regarding the error in appendix one of the consultation document, the appendix was provided for the purpose of the consultation only and is not expected to form part of the new code. However, we have noted the issue, as we continue to investigate options to provide filters for the web-based version.

Links to both our guidance and external guides will be made available in the final web-based version when this goes live. We have included these within the content when there is a direct connection, other related guidance will presented as such on the webpage.

Definitions provided in the glossaries are given in the context of the module and, in many cases, are deliberately inconsistent because the underlying legislation uses inconsistent definitions.  We have reviewed these and adopted changes to make them more consistent where possible.

CAD016 – Notification or right to cash transfer sum or contribution refund

You said:

Most responses agreed that ‘short service refunds’ reflected the content.

Many respondents reported difficulties in understanding how this module could be applied to their schemes. Particularly, a lack of clarity in how our expectations for reasonable periods related to legislative requirements. Others also suggested that links to the three modules relating to benefit statements were unnecessary.

Several suggested it would be helpful to retain the flow charts from code of practice 04.

We received several requests to add further terms to the glossary.

Similarly, to responses to question two, respondents indicated difficulties in how this module could be applied by the type of scheme.

Our response:

While there was agreement that the title was well suited to the module, due to a narrowing of scope on the content, following other responses to the consultation, we have amended the title accordingly.

In response to suggestions to bring clarity to the expectations set in this module, amendments have been made to solely focus content on the requirements under section 101AA of the Pension Schemes Act 1993. We have also removed links to other modules that we agree are not necessary.

In our design of the new code, we have chosen to focus on the expectations that we set, considering legal requirements and link to guidance where appropriate. While the flow charts will not feature in the code going forward, we will consider these in due course for further guidance.

Considering the overall changes to this module, the terms suggested for the glossary were no longer relevant to the content.

As this module focusses specifically on our expectations for complying with the requirements under section 101AA of the Pension Schemes Act 1993, we hope the application of this module has become clearer.

CAD008 – Chair’s statement

You said:

Several responses suggested ‘governance statement’ would be a more appropriate title and that there should be some indication that the module relates to schemes that provide defined contribution benefits.

Respondents suggested the module opening sentence should be amended to clarify the type of benefit that is provided, to determine whether the requirement to prepare a statement applies, as the draft consulted upon implied the type of governing body would determine this. One respondent felt our expectations could be more explicit for smaller schemes.

Many requested links to both our guidance and the DWP’s statutory guidance be included in the module.

While it was acknowledged that there has been no change in our expectations for this requirement, several report that the requirements are overly burdensome and the penalty for noncompliance is disproportionate.

Several suggested making it clear that governing bodies should take steps to conceal or remove the chair’s signature from the statement when publishing this online, due to concerns for potential misuse of this.

Our response:

We have chosen to remain with the current module title as we believe this is the most used term for the statement. Furthermore, we continue to investigate options for users to filter code content by the type of scheme they manage.

We have amended the module opening to clarify that it is the type of benefits provided that determine if the requirement applies. By design of the code, we have chosen to focus on setting expectations broadly for all users of the code, where requirements change based on size of scheme, we may set differing expectations. Generally, it is for the governing body to consider the scheme’s circumstances and exercise their judgement on how to meet our expectations, although in some cases, we may produce additional guidance to assist governing bodies.

We will ensure links to the appropriate guidance will be made available in the final web-based version of the module.

We have now highlighted governing bodies should consider removing any sensitive information before publishing the statement.

CAD005 – Scams

You said:

Most respondents found the title appropriate, there were some further suggestions that ‘combatting’ or ‘preventing’ would be useful additions.

A few suggested it would be helpful to make a clearer reference to the pledge to combat pension scams and the Pension Scams Industry Group.

Some suggested that consequences of failing to meet our expectations should be detailed within the module.

No comments were made to suggest that our expectations presented a burden to governing bodies, but some reported that our expectations should be stronger.

Requests were made for more detailed guidance on engaging membership on this topic.

Our response:

On review of responses, we agree with most responses, that the title remains appropriate for the content.

We have now highlighted the reference to the Pension Scams Industry Group and included a link to our guidance.

In the design of the new code, we have sought to remove content relating to the failure to meet legislation or the failure to comply with requirements, so that we may focus on and bring greater clarity to our expectations. Firstly, by clarifying our expectations we hope to better facilitate governing bodies to meet these. Secondly, we now operate and maintain compliance and enforcement policies separate to this code of practice.

No further changes were made in relation to responses on this module. Further to our review, we are content our expectations are appropriate considering existing legislation.

We will take into consideration specific requests made for additional guidance on this topic.

Public information

CAD010 – Publishing scheme information (PSPS)

You said:

Respondents suggested it would be helpful to refer to pension boards within the title and that the module may fit better in another section of the code.

We received responses that suggested it was unclear how the expectations applied to governing bodies, as the makeup differs between public service pension schemes.

Further requests for clarity on the definition of the governing body were received in response to these questions. One respondent questioned why we do not extend expectations set in this module to private sector schemes.

Our response:

We have made small changes to the title to make this shorter but have chosen not to include pension boards at this time, as this could be misconstrued by other users of the code not involved with PSPS. Regarding the current placement of the module within the code, we are content with this based on findings of user testing.

Referring to scheme managers has been an issue across several modules.  We have updated our general definition of the governing body to refer to scheme managers, and we have also replaced references to ‘governing bodies’ in this module with ‘scheme manager’.

As stated above, changes have been made to make it clear that these expectations apply to scheme managers. These expectations have been set considering specific requirements that apply to public service pension schemes only. However, broadly speaking, our expectations for publications remain largely similar across the varying requirements.

CAD014– Audit requirements

You said:

Responses suggest this module would better suit another section of the code, as it does not fit well under the subcategory heading of ‘public information’.

Some respondents felt it would be helpful to summarise all exemptions to legal requirements within the module.

A suggestion was made to expand the module to set expectations for annual reports. We were also asked to clarify whether we expect scheme accounts to be published on a publicly accessible website.

Our response:

On reflection, this module has now been moved to the ‘information for members’ subcategory.

When considering the design of the new code of practice, we felt it would be appropriate to include exemptions by legislative reference, so that we could focus on communicating our expectations.

We will not at this time be introducing new expectations for annual reports, but we may consider if it would be appropriate in future updates of the code. Further to this, we have amended our expectation to make it clear that when governing bodies deem it appropriate to publish scheme accounts, the location of these accounts should be free to access for scheme members.

CAD015 – Dispute resolution procedures

You said:

Several respondents highlighted those regulations for local government pension schemes (LGPS), set different time periods for managing disputes compared to those expressed in this module. Concerns were also raised around possible implications that dispute procedures could be used to resolve exempted disputes. Otherwise, most respondents agreed our expectations were clear.

Most agreed the subject was covered in sufficient detail. However, a few suggested further guidance and examples would be useful for developing dispute resolution procedures.

A respondent suggested it would be disproportionate for the resolution procedure to state in advance of a dispute, all the information that would be needed to resolve a matter, as the range of potential disputes is so large. Another also suggested the consequences of failing to comply with requirements should be detailed in this module.

Several felt further clarity was needed for the time periods in which applicants could raise disputes.

Our response:

We accept that legislation governing the LGPS sets different time periods and now set out within the module that where this legislation applies it will override expectations set in this module. The sentence that raised concern about exempted disputes has been removed.

Based on the responses received, we are comfortable that the matter has been covered sufficiently but take into consideration requests for guidance and case studies for this area.

We agree with the observation that it would be disproportionate to state all information required to resolve a dispute within the dispute resolution procedure and as such we have removed this expectation. Further, by design we have where possible removed content relating to the consequences of failure to comply with requirements and where appropriate we have signposted our separate regulatory and enforcement policies.

We have revisited the drafting for reasonable periods to make applications, to make clear that trustee should accept applications for at least six months after the applicant’s interest in the scheme had ceased.

Regular reports

RTT001 – Registrable information and scheme returns

You said:

The majority felt our expectations were clear and that expressing the reasonable period of five working days from the governing body becoming aware of a change to registrable information to updating the register, was helpful. One respondent was unclear how expectations applied to, in the case of a public service pension scheme.

Some expressed that it would be helpful to include examples of registrable information and timings for scheme return cycles. Respondents questioned the relevancy of the glossary terms provided. Another asked whether an explanation of the consequences of non-compliance could be given within the module.

Several questioned the introduction of the five working days period to inform us of changes to registrable information.

Respondents noted that the five working day period to update changes to registrable information may not be sufficient for sectionalised schemes.

Our response:

No direct change to content, definition of governing body has been amended to refer to PSPS managers only to assist with application of our expectations.

Links to our existing guidance for registrable information and the scheme return, will be available in the final online version. On further review, the glossary has been removed from this module, as the terms defined within had been removed from an earlier draft prior to the consultation. Except for mandatory enforcement activities, we have chosen not to detail consequences of the failure to comply with requirements expressed in the code. The reason for this is that we have already communicated our approach to enforcement within the regulatory and enforcement strategies and policies section of our website.

Over the years, we have observed a trend in registrable information only being updated further to a scheme return notice being issued. The requirement in legislation is that registrable information must be updated as soon as reasonably practicable, and we would expect to observe updates to registrable information to be made outside of the period of an active scheme return. Therefore, we believe by expressing our general interpretation of ‘as soon as reasonably practicable’ as five working days from the governing body becoming aware of the change, we help bring greater clarity to the requirement, understanding of course that there may be reasonable exceptions to this.

We have amended the module to make it clear that updates must be made as soon as reasonably practicable and that we expect in most cases a period of five working days from the governing body becoming aware of the change will be reasonable. However, we accept there are circumstances where a longer period may be reasonable and that there will be circumstances where five days may be too long.

Whistleblowing – Reporting breaches of the law

RTT003 – Who must report

You said:

As is the case for all modules in this subcategory, most respondents did find the title to be a fair reflection, some felt it was not clearly linked to breaches of law.

A few respondents suggested the reporting requirements may apply to roles that have not been detailed within this module. One reporter requested that the content on whistle-blower protection be strengthened for the role types listed within the module.

One respondent suggested it was not clear that both limbs set out in paragraph one of the modules are required for the duty to apply. We were also asked to clarify how the duty to report applies in relation to corporate trustees, due to a deviation in language from the original codes. A respondent also highlighted the duty to report may not override all other duties, as set out in the following paragraph, an example of this would be legal privilege. Some asked for this module to include a link to our existing guidance for reporting breaches of law.

Several respondents noted that, while custodians of scheme assets were listed as potential reporters, in the original code the role had been omitted from the draft module.

Our response:

In the final version of the online code subcategory heading of ‘Whistleblowing – Reporting breaches of the law’ will appear within the navigation panel to provide context for the modules within this section.

Amendments have been made to the module to make it clear that the list of reporters given is not exhaustive and it may be appropriate to seek advice if it is unclear whether the duty applies in some cases. Detail of the protection available has been provided within the limits of legislation made to date, where a reporter is unclear what protection may apply in their circumstances, they should consider seeking legal advice.

An amendment has been made to clarify that both limbs set out in paragraph one is required for the duty to report to apply. On reflection we have also reverted to the original wording for the duty to report for corporate trustees and replaced ‘directors’ with ‘trustee company’. We updated the module to clarify that the duty to report may override certain duties a reporter has. The existing code related guide for code of practice 01 reporting breaches of the law, has been identified as a priority and we expect an updated version of this to be published on or shortly after the new code of practice coming into force.

On review of the original code, we found no material reason for custodians to be omitted from the module and reinstated this role to the list of potential reporters.

RTT004 – Decision to report and RTT005 – How to report

You said:

Respondents suggested expectations in the context of payment failures were missing from this module, as well as information regarding the consequences of failing to report.

Several respondents suggested it would be helpful to maintain the existing traffic light guidance for reporting breaches of the law. A few respondents also suggested it would be helpful to include details about the failure to report notifiable events within this module.

Two respondents requested clarification that not all effects listed under paragraph 6 are required for a breach to be considered materially significant.

Our response:

We have acted on feedback from this module and others relating to reporting payment failures. We have introduced a further module in which we set out our expectations as well as examples of material significance. In designing the new code, we have focused on setting our expectations for certain requirements and avoiding the duplication of existing material where possible. To this extent we have largely removed information relating to consequences of failing to comply with legal requirements across the code, as we have already communicated our approach to enforcement within the regulatory and enforcement strategies and policies section of our website.

The existing code related guide for code of practice 01 reporting breaches of the law has been identified as a priority and we expect an updated version of this to be published on or shortly after the new code of practice coming into force. The existing code of practice 02 notifiable events was not included in the 10 codes we identified to form the initial phase of this new web-based code. However, we do expect code 02 to form part the code in future, which would be subject to further consultation at that time.

We have amended the wording to help clarify that where any of the effects listed are present, we would consider the matter to be materially significant.

RTT006 – Reporting payment failures

This is a new module developed further following suggestions made by respondents in relation to ADM011, resolving overdue contributions.

Appendix: consultation respondents


Allen & Overy LLP




ARC Benefits

Association of Consulting Actuaries

Atkin Trustees Limited


Avon Pension Fund


BA Pensions

Baker & McKenzie

Barnett Waddingham




Cheshire Pension Fund

Client Earth

Clwyd Pension fund


Coal Pension Trustees Investment Limited


Cumbria LGPS

Dalriada Trustees

East Sussex Pension Board


Essex Pension Fund

Eversheds Sutherland

Gowling WLG

Greater Manchester Pension Fund

Hargreaves Lansdown

Herbert Smith Freehills


Hymans Robertson LLP



ICI Pension fund

Inside Pensions





L & G

Law Society of Scotland

Law Debenture



Linchpin Advisory Limited

Linklaters LLP

Local Pension Partnership

London Borough Of Hillingdon

London Pension Fund Authority

Marks and Spencer


Muse Advisory



Nest Corporation


NI Civil Service Pension Scheme







PH Collins






Scottish Public Pensions Agency

Scottish Teachers' Pension Scheme

Scottish Widows


Shepherd and Wedderburn

Society of Pensions Professionals

South Yorkshire Pensions Authority

Squire Boggs

Stagecoach Group Pension Scheme

Surrey Pension Fund

Teacher's Pension Scheme

The Investment Association

Tyne and Wear Pension Fund

United Utilities


West Midlands Pension Fund

West Sussex Pension Fund

Westminster City Council

Willis Towers Watson