Scheme governance

The governance of trust-based occupational pension schemes is the responsibility of the trustees, although trustees usually appoint a scheme administrator to look after the day-to-day running of the scheme. Trustees need to be aware of their statutory duties in relation to scheme governance.

The key statutory governance requirements of trustees include:

  1. to establish and operate an effective system of governance including internal controls

  2. to report certain scheme information to the authorities, including the Pensions Regulator

  3. to appoint certain professional advisers to the scheme

  4. to manage conflicts of interest

  5. to keep scheme records

  6. to identify the scheme’s statutory employers

  7. to run the scheme in compliance with the scheme’s trust deed and rules (as well as legislation). This involves (i) correctly interpreting the trust deed and rules, and (ii) taking steps to ensure the correct benefits are paid to members and beneficiaries in accordance with the scheme's rules (ie ensure no overpayments are made)

The Pensions Regulator also expects trustees to improve the scheme’s equality, diversity and inclusion (EDI) in the belief that EDI results in better decision-making, improved value for money for savers

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DWP to evaluate pension scheme climate disclosure regime as part of government’s modernisation of climate disclosure and transition planning in UK financial markets

As part of its efforts to modernise the UK’s sustainability reporting framework, the government has introduced three consultations intended to “unlock billions in clean energy investment”. In doing so, the government is consulting on how to implement its manifesto commitment to mandate UK-regulated financial institutions (including banks, asset managers, pension funds and insurers),  as well as FTSE 100 companies,  to develop and implement credible transition plans that align with the 1.5C goal of the Paris Agreement. The government sees transition planning as a vital part of its commitment to secure the UK’s position as the green finance capital of the world. Notably, one consultation from the Department for Energy Security and Net Zero, seeks views on how the government should implement this commitment by ensuring an orderly transition aligned with global climate goals, aiming to enhance transparency to facilitate efficient capital allocation, enabling companies to seize opportunities from the global net zero transition, and bolstering the growth and international competitiveness of the UK’s financial services industry.  In particular, the consultation from the Department for Energy Security and Net Zero indicates that during 2025, the Department for Work and Pensions (DWP) will conduct a review of the Occupational Pension Schemes (Climate Change, Governance and Reporting) Regulations 2021, SI 2021/839, utilising evidence provided by the Pensions Regulator (TPR). The DWP regards this review as a logical starting point to assess the effects of the current climate disclosure regime (put in place following the recommendations from the Taskforce on Climate-Related Financial Disclosures (TCFD)) and to consider future steps for climate change reporting. In parallel with the TCFD review, the DWP has tasked TPR with evaluating the feasibility of transition plans within pension schemes. Accordingly, TPR is organising an industry working group, including key stakeholders and major occupational pension schemes, and is set to deliver its findings to the DWP later in 2025.

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