Conflicts of interest policyrelating to [insert name of pension scheme]
Conflicts of interest policyrelating to [insert name of pension scheme]

The following Pensions guidance note provides comprehensive and up to date legal information covering:

  • Conflicts of interest policyrelating to [insert name of pension scheme]
  • Appendix 1TRUSTEES’ REGISTER OF CONFLICTS OF INTEREST
  • Appendix 2REGISTER OF CONFLICTS OF INTEREST FOR ADVISERS

Produced in partnership with John Hamilton of Blake Morgan

  1. 1

    Background

    1. 1.1

      This policy applies to the trustees (“the Trustees”) of the [insert name of pension scheme] (“the Scheme”).

    2. 1.2

      It is the duty of each Trustee to act impartially and in the best interests of the beneficiaries of the Scheme as a whole. Beneficiaries include employee members, pensioners, deferred members and those claiming through them, such as dependants and in some circumstances may also include [insert name of sponsoring employer] (the “Employer”).

    3. 1.3

      The Trustees also have a responsibility to pay due regard to the Employer, as the Scheme sponsor, in fulfilling their duty as a Trustee.

    4. 1.4

      The Trustees recognise that there are occasions where their personal interests or other fiduciary duties might conflict with, or might be seen by others to conflict with, their role as a Trustee of the Scheme. Possible areas that could give rise to conflicts of interest include:

      1. 1.4.1

        setting assumptions for actuarial valuations;

      2. 1.4.2

        setting contribution rates and a recovery plan for alleviating a funding deficit;

      3. 1.4.3

        assessing the strength of the employer covenant;

      4. 1.4.4

        considering benefit changes proposed by the Employer;

      5. 1.4.5

        considering the proper construction of Scheme documentation;

      6. 1.4.6

        agreeing the investment strategy and reviewing investment choices;

      7. 1.4.7

        assessing the impact of a corporate transaction;

      8. 1.4.8

        approving member benefit increases through exercise