1. Introduction
The Plan is required to produce a yearly statement to describe how governance requirements have been met in relation to:
- the investment options in which members’ funds are invested (this means the default arrangements and other funds members can select or have assets in, such as “legacy” funds);
- the requirements for processing financial transactions;
- the charges and transaction costs borne by members;
- an illustration of the cumulative effect of these costs and charges;
- a ‘value for members’ assessment; and
- Trustee knowledge and understanding.
This statement has been prepared in accordance with the Occupational Pension Schemes (Charges and Governance) Regulations 2015 and covers the period 1 January 2020 to 31 December 2020.
2. The default investment arrangements
The Plan has an Auto-enrolment section, which is used as a Qualifying scheme for auto-enrolment, and the Money Purchase 2003 (“MP03”) section, which is not. Together these are the Defined Contribution (‘DC’) sections of the Plan. Members who do not opt in to or are not eligible for the Money Purchase 2003 section are auto-enrolled into the Auto-enrolment section. Members of both sections are given the same investment choices and have the same default investment strategies.
Some members of the DC Sections of the Plan make their own investment choices from the range of investment options made available by the Trustee, but those who do not make an explicit choice regarding the investment of their funds are placed automatically into a default lifecycle arrangement. After taking advice, the Trustee decided to make the default lifecycle arrangements, which means that members’ assets are automatically moved between different investment funds within the default lifecycle arrangement as they approach their target retirement date.
There are three separate default lifecycle strategies, the ‘Drawdown Lifecycle’, the ‘Cash Lifecycle’ and the ‘Annuity Lifecycle’. Details of how member contributions are invested into the different default lifecycle strategies are set out below.
Where an explicit choice has not been made by the member, contributions into the DC sections are invested into the ‘Drawdown Lifecycle’. The asset allocations in the years leading up to retirement for the Drawdown lifecycle is shown below:
Members who make additional voluntary contributions (AVCs) have the same investment fund choices, but if they do not make an explicit choice their AVC assets are placed into the ‘Cash Lifecycle’, which is the default arrangement for AVCs. The asset allocations in the years leading up to retirement for the Cash lifecycle is shown below:
The Plan also has a legacy default lifecycle arrangement, the ‘Annuity Lifecycle’, into which the assets of a number of members close to retirement were transferred into as part of the last investment strategy review. The strategy is also open for members to select if they wish to. The asset allocations in the years leading up to retirement for the Annuity lifecycle is shown below:
The Trustee is responsible for investment governance, which includes setting and monitoring the investment strategy for the default lifecycle arrangements.
Details of the objectives and the Trustee’s policies regarding the default arrangements can be downloaded in the ‘Statement of Investment Principles’ (“SIP”) PDF (PDF 368KB).
The objective of the default lifecycle arrangement, as stated in the SIP, is as follows:
“The objective of the main default option for the DC sections, the Drawdown Lifecycle, is to generate returns above inflation whilst members are some distance from retirement, but then to switch automatically and gradually to lower risk investments as members near retirement.”
The objectives of the Cash default arrangement and the Annuity default arrangements, as stated in the SIP, are as follows:
“The aim of all the default Lifecycle strategies (specifically the Cash and Annuity strategies) is to provide members with the potential for higher levels of growth during the accumulation of their retirement savings though exposure to equity and diversified growth funds and then to gradually diversify their investments in the years approaching retirement, in order to reduce volatility while still providing suitable exposure to growth assets. The asset allocation throughout the default Lifecycle strategies and the phasing of the gradual switching of investments takes into account members’ greater capacity for risk early on and reduced capacity for risk in later years. In the initial growth phase, the above lifecycle options (including the legacy default, the Annuity Lifecycle) are invested to target a return above inflation, and then in the 15 years before retirement, they switch gradually into less risky assets, with the asset allocation at retirement being designed to be appropriate for members wishing to access drawdown (in the case of the Drawdown Lifecycle), take their pot as cash (the Cash Lifecycle) or purchase an annuity at retirement (Annuity Lifecycle).”
The default lifecycle arrangements are described above and each of the asset allocation tables can be found in the Booklets and leaflets section of the Library.
The Trustee considers these approaches to be in the best interest of relevant members and relevant beneficiaries. The default lifecycle arrangements meet the requirements for social environmental and governance considerations set out in the SIP.
The Threadneedle Pensions Property Fund was suspended by the manager in May 2020 due to pricing uncertainty caused by the Covid-19 crisis. Member contributions were redirected into the BlackRock Sterling Liquidity Fund until the Property Fund reopened in September 2020. As members’ contributions were directed into the BlackRock Sterling Liquidity Fund without them making an active selection, this fund will be treated as a default for the purpose of fulfilling legislative requirements. As members’ contributions are still being held in the BlackRock Sterling Liquidity Fund it will continue to be treated as a default fund for legislative purposes. The aims and objectives of the strategy are that the fund aims to maximise current income consistent with the preservation of capital and liquidity through the maintenance of a portfolio of high quality short-term “money market” instruments and to achieve an investment return that is in line with its benchmark.
On a quarterly basis after charges the performance of funds (which can be found on page 19 of the Report and Financial Statements (PDF 1.9MB)) comprising the default arrangements are reviewed by the Investment Committee. Throughout the year ended 31 December 2020, investment returns for passive funds have generally tracked benchmarks, and have performed in accordance with the objectives of the fund as set out in the SIP. The performance of the active funds within the lifecycle arrangements has been more varied, which is expected as the benchmark is less likely to be an exact match for the fund given the active management. Where performance is not in line with benchmarks or objectives, the Investment Committee have investigated the deviation with the investment consultants and investment managers in order to establish if any further action is necessary. The reviews that took place during the year concluded that the default lifecycle arrangements were performing broadly as expected. There was a change made to one of the underlying funds that make up the lifecycle arrangements, but this was not as a direct result of the performance of that fund. The change made was to the underlying funds used within the white-labelled Blended Multi Asset Fund. On 30 June 2020, the underlying allocation to the BlackRock DC Diversified Growth Fund was removed and the allocation to the Newton Real Return Fund was reduced. The Schroder Life Dynamic Multi-Asset Fund and Baillie Gifford Multi Asset Growth Fund were introduced as replacements, with equally weighted allocations to the three funds.
The default lifecycle arrangements and self-select funds are formally reviewed to assess the ongoing suitability and strategy of the default lifecycle arrangement at least every three years or immediately following any significant change in investment policy or the Plan’s membership profile. The default lifecycle and fund arrangements were formally reviewed during the period covered by this Statement. The review took place over the course of several meetings, commencing on 1 June 2020. Following this review, the Trustee agreed several enhancements to the default lifecycles. It decided to replace the use of corporate bonds within the lifecycles with an allocation to lower risk short dated credit, using the BlackRock Sterling Short Duration Credit Fund. It also agreed to introduce a new white-labelled fund within the Annuity Lifecycle, called the Annuity Targeting Fund, incorporating a small allocation to fixed interest gilts alongside the current index linked gilts allocation to better align the allocation to the In Plan Pension. With regard to members holding both DC and AVC benefits, the Trustee decided to change the default strategy for the AVC portion of their pot from the Cash Lifecycle to the Drawdown Lifecycle (so the DC and AVC benefits are considered as a whole for these members). The Trustee also undertook a review of the Plan’s ESG offerings following the Plan year end which is still underway. The Trustee concluded in this review that it was comfortable that all default arrangements and self-select options remain appropriate subject to the changes above being implemented.
The resulting investment transition will take place during 2021, and the next full triennial review of the investment arrangements is due to take place in June 2023.
3. Core financial transactions
The Trustee has a specific duty to secure that core financial transactions (including the investment of contributions, transfer of member assets into and out of the Plan, transfers between different investments within the Plan and payments to and in respect of members) relating to the DC Sections are processed promptly and accurately.
The Trustee delegates responsibility for this to the staff of the Plan and the Plan’s DC provider, Aviva. The agreement the Trustee has in place with Aviva incorporates specific service level agreements (SLAs) which include targets for the accurate and timely processing of core financial transactions. The Trustee monitors the performance against these SLAs via quarterly reports.
The staff of the Plan and Aviva have set up various controls to ensure the accuracy of processing core financial transactions, for example:
- a reconciliation to ensure all contributions were processed using monthly Aviva reporting data;
- a reconciliation of monies disinvested for member refunds to amounts returned to the Plan by Aviva; and
- an annual reconciliation of membership using data supplied from Aviva against membership held on the pension administration database.
The Trustee has received assurance from the Plan’s DC provider, Aviva, from management reporting that they have adequate internal controls, including review procedures, and inbuilt automated controls within their systems, to ensure that core financial transactions relating to the Plan were processed promptly and accurately during the year. Any issues identified by the Trustee as part of its review processes (set out below) would be raised with the administrators immediately, and steps would be taken to resolve the issues.
The processes the Trustee has in place for monitoring of core financial transactions are as follows:
- Review of quarterly SLA reporting from Aviva, covering reporting on each type of transaction for number of cases processed, and how many days each has taken. It has been noted that throughout the year there have still been instances where the performance has fallen below target. Management have continued to work closely with Aviva to ensure that measures have been put in place to rectify the issues.
- Review of quarterly management reporting against agreed SLAs from management, detailing what activities have taken place, and what, if any, exceptions have occurred.
- The Trustee have appointed the Audit and Risk Committee to review the Breaches Register half yearly, where any statutory or legal breaches would be reported.
- External auditors perform some limited controls testing for the purposes of their statutory audit and report back any issues via their Management report.
Based on its review process, the Trustee is satisfied that over the period covered by this statement:
- Both the Plan and the DC provider were operating appropriate procedures, checks and controls and operating within the agreed SLAs;
- There have been no material administration errors in relation to processing core financial transactions; however, Aviva has been dealing with an error over the year regarding the fees charged to members. Four Plan schemes had the wrong fee applied for certain funds up until 2019, at which point Aviva applied the correct charge. Throughout the last year Aviva has been calculating a loss/gain for the members affected. Aviva has shared details of loss/gain with the Plan and discussed and agreed with them on how to rectify these issues; and
- Whilst SLA performance has at times been lower than the SLA target (as noted above), the Trustee is satisfied that this is being addressed and will continue to monitor performance of Aviva’s services over the remainder of 2021 and into 2022.
4. Member-borne charges and transaction costs
Regulations also require the Trustee to make an assessment of ongoing charges borne by members of the DC Sections and the extent to which those charges and costs represent good value for members.
These are annual fund management charges plus any additional fund expenses, such as custody costs, but excluding transaction costs; this is also known as the total expense ratio (“TER”). The TER is paid by the members and is reflected in the unit price of the funds. The stated charges include administration costs, since these are met by the member.
The Trustee is also required to separately disclose transaction cost figures that are borne by members. In the context of this Statement, the transaction costs shown are those incurred when the Plan’s investment
managers buy and sell assets within investment funds but are exclusive of any costs incurred when members invest in and switch between funds. The transaction costs are borne by members.
The charges and transaction costs have been supplied by Aviva (the Plan’s platform provider), and by the Plan’s legacy AVC providers. When preparing this section of the Statement the Trustee has taken account of the relevant statutory guidance. Due to the way in which transaction costs have been calculated it is possible for figures to be negative; since transaction costs are unlikely to be negative over the long term the Trustee has shown any negative figure as zero.
4.1 Default arrangements
The default arrangement for the MP03 and Auto-enrolment sections is the Drawdown lifecycle arrangement. For the period covered by this Statement, annualised charges and transaction costs are set out in the following table:
| Years to selected retirement date (SRA) | TER | Transaction costs |
|---|---|---|
| 15 | 0.29% | 0.03% |
| 10 | 0.37% | 0.17% |
| 5 | 0.35% | 0.18% |
| At retirement | 0.35% | 0.18% |
The default arrangement for AVC contributions is the Cash lifecycle arrangement. For the period covered by this Statement, annualised charges and transaction costs are set out in the following table:
| Years to SRA | TER | Transaction costs |
|---|---|---|
| 15 | 0.29% | 0.03% |
| 10 | 0.37% | 0.17% |
| 5 | 0.35% | 0.18% |
| At retirement | 0.18% | 0.01% |
The Annuity lifecycle arrangement is a legacy lifecycle arrangement and an alternative option for members, for the period covered by this Statement, annualised charges and transaction costs are set out in the following table.
| Years to SRA | TER | Transaction costs |
|---|---|---|
| 15 | 0.29% | 0.03% |
| 10 | 0.37% | 0.17% |
| 5 | 0.35% | 0.18% |
| At retirement | 0.18% | 0.05% |
From May 2020 the BlackRock Sterling Liquidity Fund is also considered to be a default investment option due to redirection of member contributions without explicit consent, during the temporary suspension of dealing of the Threadneedle Pensions Property Fund.
The TER for this Fund is 0.18% with transaction costs over the period covered by this statement at 0.01%. The TERs for all of these arrangements are much lower than the maximum allowed of 0.75% and the Trustee is satisfied that it has negotiated good terms for members taking account of the expected growth in the size of the DC Sections.
4.2 Self-select options
In addition, there is a range of 11 separate funds which may be chosen by members as an alternative to the default lifecycle arrangement. These funds allow members to take a more tailored approach to managing their own pension investments.
Annual management charges for each fund for 2020 are shown below. Download the Current Charges PDF (PDF 198KB) for the up to date rates. The underlying funds used within the default arrangement are shown in bold.
| Fund Name | TER 2020 | Total transaction costs 2020 |
|---|---|---|
| Blended Global Equity Fund | 0.29% | 0.03% |
| BlackRock UK Equity Index Fund | 0.18% | 0.38% |
| BlackRock World ex UK Equity Index Fund | 0.19% | 0.04% |
| Jupiter Ecology Fund | 1.16% | 0.00% |
| Threadneedle Pensions Property Fund | 0.91% | 0.10% |
| Blended Index Linked Gilt Fund | 0.18% | 0.07% |
| BlackRock Over 15 year Corporate Bond Index Fund | 0.18% | 0.14% |
| BlackRock Over 15 year Gilt Index Fund | 0.18% | 0.03% |
| BlackRock Institutional Sterling Liquidity Fund | 0.18% | 0.01% |
| Blended Multi Asset Fund | 0.65% | 0.47% |
| MFS Meridian Global Equity Fund | 0.96% | 0.12% |
The fee of the Blended Multi Asset Fund is shown following changes to the underlying funds over the Plan year in June 2020 which resulted a reduction in fee.
Legacy AVC fund charges and transaction costs
The following funds were available to members as legacy options for AVCs. These options are now closed to future contributions. Transaction costs listed in the table below are subject to a floor of zero so as not to assume a negative cost over the longer term.
| Fund Name | TER 2020 | Total transaction costs 2020 |
|---|---|---|
| Utmost Life and Pensions Secure Cash Fund | 0.50% | 0.00% |
| Prudential – Cash Accumulation With-Profits | 1.20% | 0.11% |
| Prudential – Deposit Fund* | 0.00% | 0.00% |
| Clerical Medical – With-Profits Fund** | 0.50% | 0.24% |
| Clerical Medical – Balanced Pension Fund | 0.50% | 0.41% |
| Clerical Medical – Cash Fund | 0.50% | 0.01% |
| Clerical Medical – Far Eastern Pension Fund | 0.50% | 0.56% |
| Clerical Medical – UK Equity Tracker Fund | 0.50% | 0.00% |
| Clerical Medical – Ethical Fund | 0.50% | 0.04% |
| Royal London – Crest Secure Fund* | 1.45% | 0.00% |
| Chelsea Building Society** | N/A | N/A |
| Phoenix Life – Managed Pension Fund | 1.03% | 0.24% |
| Phoenix Life – With-Profits Fund | 1.04% | 0.24% |
* There are no explicit charges and/or transaction costs for this fund, but charges are deducted before the bonus is declared. The Trustee is working with the provider to confirm these charges.
** The Trustee is working with the provider to confirm which funds the Plan has assets invested in over the Plan year and the charges for these funds.
The Utmost Life and Pensions Secure Cash Fund is listed in italics above as members were all moved out of this Fund and into the Cash Lifecycle (AVC default strategy) arrangement with Aviva on 26 June 2020. There are also no longer any member investments remaining with Chelsea Building Society from August 2020, hence this is also listed in italics.
4.3 Illustration of charges and transaction costs
The illustrations show how different costs and charges can impact the pension pot over certain periods of time, based on a selection of investment funds. Statutory guidance from The Pensions Regulator has been taken into account in the preparation of these illustrations. Under each default lifecycle arrangement or investment fund, there are two columns. The first shows the projected pension values assuming no charges are taken. The second shows the projected pension values after costs and charges are taken. By comparing these scenarios, it is possible to identify how much the charges over the years will impact the pension value.
The “before costs” figures represent the savings projection assuming an investment return with no deduction of member borne charges or transaction costs. The “after costs” figures represent the savings projection using the same assumed investment return but after deducting member borne charges (ie the TER) and an allowance for transaction costs.
The transaction cost figures used in the illustration are those provided by the managers over the past three years, subject to a floor of zero (so the illustration does not assume a negative cost over the long term). We have used the average annualised transaction costs over the past three years as this is the longest period over which figures were available, and should be more indicative of longer-term costs compared to only using figures over the Plan year.
The illustration is shown for the Drawdown Lifecycle, since this is the arrangement with the most members invested in it, as well as the two alternative lifecycles, the AVC default (the Cash Lifecycle) and the legacy default (the Annuity Lifecycle) and also four funds from the Plan’s self-select fund range. The four self-select funds shown in the illustration are:
- the fund with the highest before costs expected return – this is the BlackRock UK Equity Index Fund
- the fund with the lowest before costs expected return – this is the BlackRock Institutional Sterling Liquidity Fund
- the fund with highest annual member borne costs – this is the Jupiter Ecology Fund
- the fund with lowest annual member borne costs – this is the Blended Index Linked Gilt Fund. The Blended Index Linked Gilt Fund has the second lowest annual member borne costs (using transaction costs averaged over a 3 year period) after the BlackRock Institutional Sterling Liquidity Fund. It is shown here within the illustration since the BlackRock Institutional Sterling Liquidity Fund is already shown as the fund with the lowest before costs expected return.
Illustration of effect of costs and charges for typical funds within the Plan
Projected pension pot in today’s money
| Years invested | Default option (Drawdown Lifecycle) |
AVC default option (Cash Lifecycle) |
Legacy default option (Annuity Lifecycle) |
|||
|---|---|---|---|---|---|---|
| Before costs £ |
After costs £ |
Before costs £ |
After costs £ |
Before costs £ |
After costs £ |
|
| 1 | 4,000 | 4,000 | 4,000 | 4,000 | 4,000 | 4,000 |
| 3 | 8,000 | 8,000 | 8,000 | 8,000 | 8,000 | 8,000 |
| 5 | 12,200 | 12,100 | 12,200 | 12,100 | 12,200 | 12,100 |
| 10 | 23,400 | 23,000 | 23,400 | 23,000 | 23,400 | 23,000 |
| 15 | 35,700 | 34,800 | 35,700 | 34,800 | 35,700 | 34,800 |
| 20 | 49,300 | 47,600 | 49,300 | 47,600 | 49,300 | 47,600 |
| 25 | 64,300 | 61,600 | 64,300 | 61,600 | 64,300 | 61,600 |
| 30 | 79,400 | 74,900 | 79,400 | 74,900 | 79,400 | 74,900 |
| 35 | 92,200 | 85,600 | 92,200 | 85,600 | 92,200 | 85,600 |
| 40 | 104,000 | 95,100 | 97,600 | 89,700 | 98,100 | 90,400 |
Projected pension pot in today’s money
| Years invested | BlackRock UK Equity Index Fund | BlackRock Sterling Liquidity Fund | Jupiter Ecology Fund | Blended Index Linked Gilt Fund | ||||
|---|---|---|---|---|---|---|---|---|
| Before costs £ |
After costs £ |
Before costs £ |
After costs £ |
Before costs £ |
After costs £ |
Before costs £ |
After costs £ |
|
| 1 | 4,000 | 4,000 | 3,900 | 3,900 | 4,000 | 4,000 | 3,900 | 3,900 |
| 3 | 8,000 | 8,000 | 7,400 | 7,400 | 8,000 | 7,900 | 7,500 | 7,500 |
| 5 | 12,200 | 12,100 | 10,800 | 10,800 | 12,200 | 11,800 | 11,000 | 10,900 |
| 10 | 23,400 | 22,900 | 18,700 | 18,500 | 23,400 | 21,900 | 19,300 | 19,000 |
| 15 | 35,700 | 34,600 | 25,900 | 25,500 | 35,700 | 32,400 | 26,900 | 26,500 |
| 20 | 49,300 | 47,400 | 32,300 | 31,700 | 49,300 | 43,300 | 34,000 | 33,300 |
| 25 | 64,300 | 61,200 | 38,200 | 37,300 | 64,300 | 54,700 | 40,600 | 39,600 |
| 30 | 80,800 | 76,200 | 43,400 | 42,300 | 80,800 | 66,500 | 46,700 | 45,400 |
| 35 | 99,100 | 92,500 | 48,200 | 46,700 | 99,100 | 78,900 | 52,300 | 50,600 |
| 40 | 119,300 | 110,100 | 52,500 | 50,700 | 119,300 | 91,700 | 57,600 | 55,500 |
Notes
- Values shown are estimates and are not guaranteed. The illustration does not indicate the likely variance and volatility in the possible outcomes from each fund. The numbers shown in the illustration are rounded to the nearest £100 for simplicity.
- Projected pension pot values are shown in today’s terms, and do not need to be reduced further for the effect of future inflation.
- Annual salary growth and inflation is assumed to be 2.5%. Salaries could be expected to increase above inflation to reflect members becoming more experienced and being promoted.
- However, the projections assume salaries increase in line with inflation to allow for prudence in the projected values.
- The starting pot size used is £2,100. This is the approximate average (median) pot size for active members aged 25 years and younger in the MP03 and Auto-enrolment sections (as these members can be expected to have around 40 years to retirement)
- The projection is for 40 years, being the approximate duration that the youngest Plan member has until they reach the Plan’s Normal Pension Age.
- The starting salary is assumed to be £23,500. This is the approximate median salary for active members aged 25 or younger.
- Total contributions (employee plus employer) are assumed to be 8.0% of salary per year. This is the median total contributions for active members aged 25 or younger.
- The projected annual returns used are as follows:
- Drawdown Lifecycle: 2.0% above inflation for the initial years, gradually reducing to a return of 0.5% above inflation at the ending point of the lifecycle.
- Cash Lifecycle: 2.0% above inflation for the initial years, gradually reducing to a return of 2.0% below inflation at the ending point of the lifecycle.
- Annuity Lifecycle: 2.0% above inflation for the initial years, gradually reducing to a return of 1.6% below inflation at the ending point of the lifecycle.
- BlackRock UK Equity Index Fund: 2.0% above inflation
- BlackRock Sterling Liquidity Fund: 2.0% below inflation
- Jupiter Ecology Fund: 2.0% above inflation
- Blended Index Linked Gilt Fund: 1.5% below inflation
- No allowance for active management outperformance has been made.
- While these costs are important, they should not be looked at in isolation but should be viewed within the context of the performance of the fund or funds chosen as these costs are, ultimately, reflected in the performance of the fund.
5. Value for members assessment
The Trustee has assessed the extent to which member borne charges and transaction costs detailed above represent good value for money to members.
The Trustee reviews all member-borne charges (including transaction costs where available) annually, with the aim of ensuring that members are obtaining value for money given the circumstances of the Plan. The date of the last review was the date of this report, 19 May 2021. The Trustee notes that value for money does not necessarily mean the lowest fee, and the overall quality of the service received has also been considered in this assessment. The Trustee’s investment advisers have confirmed that the fund charges are competitive for the types of fund available to members.
The Trustee assesses the performance of the Plan’s investment funds (after all charges) in the context of their investment objectives on a quarterly basis. The returns on the investment funds members can choose during the period covered by this Statement have broadly been consistent with their stated investment objectives. Where the Trustee has any concerns that a fund is not providing returns in line with its objective, a review is carried out to assess whether any change is required, noting however, that short term performance is not used as a criteria for the Trustee to change an investment option.
In carrying out the assessment, the Trustee also considers the other benefits members receive from the Plan, which include (amongst other aspects):
- The design of the default lifecycle arrangements and how these reflect the interests of members.
- The range of investment options and strategies.
- The efficiency of administration processes, the quality of communications, support services and Plan governance, including the additional benefit of an in-house pensions team, solely focussed on the Plan’s arrangements.
- Access to retirement planning tools through Aviva’s secure online portal, MyWorkplace.
- Access to factsheets and guidance provided on the Plan website.
- Additional ill health and death benefits for Plan members.
The Trustee has taken advice from its investment advisers, who have analysed the Plan against their benchmark. The results of the Trustee’s assessment, on a scale from ‘very good’ to ‘poor’ are as follows:
- Charges – Very good – Members bear the cost of administration charges but fees are reasonably competitive. The Trustee will continue to monitor fees following any changes implemented in the investment strategy and will look for opportunities to negotiate lower fees for members wherever possible.
- Administration – Good – The administration services provided by Aviva are of a good standard. The Trustee is considering increasing its engagement with the administrator to improve performance relative to SLAs.
- Governance – Very good – The Trustee and pensions team are very committed to the Plan, demonstrated by the dedicated level of resources and commitment to training.
- Communications – Very good – The Trustee and the administrator issue timely and relevant information to members. Members receive bespoke targeted communications at certain key stages and as they approach retirement.
- Default investment arrangement – Very good – The strategies broadly achieved their objectives over the year. The Trustee reviewed this over the year and will implement any agreed changes. The next review will be in June 2023.
- Investment range – Very good – The self-select fund range provides access to most asset classes, some specialist options and alternative lifestyle strategies. The Trustee reviewed these over the year and will implement any agreed changes.
- At-retirement services – Good – Support and guidance offered to members are reasonable. The Trustee is considering enhancing the support on offer for members nearing retirement.
- Plan design – Good – The Plan’s design and contribution structure are reasonable and encourage members to take advantage of the extra matching contributions.
Having considered the various aspects of the Plan, the Trustee is comfortable that the Plan is offering good value to members for costs and charges they incur and will continue to monitor this. In addition to value provided by the Plan to members, members also benefit from employer contributions, which in the case of the Money Purchase 2003 Section, provides £2 of contributions by the employer for every £1 contributed by the employee, up to the employer contributing a maximum of 16% of the employee’s uncapped salary, depending on age. Contributions provided by the employer for the Auto-enrolment section of the Plan are in line with legislation. Most members of the Auto-enrolment section have the option to switch into the Money Purchase 2003 section, subject to meeting the eligibility criteria.
6. Trustee knowledge and understanding
The Plan’s Trustee is required to maintain appropriate levels of knowledge and understanding to run the Plan effectively. The Trustee has measures in place to comply with the legal and regulatory requirements regarding knowledge and understanding of relevant matters, including investment, pension and trust law. Details of how the knowledge and understanding requirements have been met during the period covered by this Statement are set out below.
As set out in the Trustee’s Report, a review of the governance of the Plan, including arrangements with respect to Defined Contribution members, their contributions and benefits, is undertaken by the Trustee through its board and committees.
The Trustee’s priority is to provide a strong and stable pension scheme which operates in the interests of its members and to achieve this the Trustee Board and its Committees meet regularly to develop and agree strategy, monitor performance, discuss and explore issues relevant to the governance and administration of the DC arrangements and make appropriate decisions.
The Plan’s Trustee Directors are required to maintain appropriate levels of knowledge and understanding to run the Plan effectively. Each Trustee Director must:
- Be conversant with the trust deed and rules of the Plan, the Plan’s statement of investment principles and any other document recording policy for the time being adopted by the Trustee relating to the administration of the Plan generally,
- have, to the degree that is appropriate for the purposes of enabling the individual to exercise properly his or her functions as a trustee director, knowledge and understanding of the law relating to pensions and trusts and the principles relating to the investment of the assets of occupational pension schemes.
The Trustee has measures in place to comply with the legal and regulatory requirements regarding knowledge and understanding of relevant matters, including investment, pension and trust law. The Pensions Director aims to identify training needs on any topics that become relevant, as well as the trustee directors themselves raising any training needs informally in meetings and other communications, and more formally via the annual Trustee evaluation questionnaire. Any Trustee Knowledge & Understanding (TKU) requirements are shared with the Chairman each year and incorporated into the Trustee Action Plan. In addition, the trustee directors also receive various legal updates from the Plan’s lawyers. Some of the trustee directors have also undertaken individual training across a range of topics which has been recorded within TKU records held by the Pensions Director.
Documents and guidance with Plan specific information, including Plan Rules, are provided via the digital board book system to all trustee directors and committee members. All changes to Plan rules are approved by the Trustee and is also regularly discussed in Trustee and committee meetings. The Statement of Investment Principles PDF (PDF 286KB) is available to download.
All new trustee directors are asked to complete the Pension Regulator’s trustee toolkit (an online learning programme, designed to help trustees of occupational pension schemes meet the minimum level of knowledge and understanding required by law), and receive detailed briefings from both the Pensions Director and key advisers, as well as other Plan staff as required, which are tailored to the individuals’ existing knowledge and expertise.
The Trustee believes that the combined knowledge and understanding of the trustee directors, the independent members of certain committees and the staff of the Plan, together with external advice where appropriate, enables the Trustee to exercise properly its functions by providing collectively experience of governance, pension fund management, administration, investment, finance, audit and member representation.
The Chairman’s Defined Contribution Governance Statement was approved by the Trustee on 19 May 2021 and signed on its behalf by:
J A B Joll
Chairman
