Governance & Workplace Pensions

For workplace pensions, the bodies tasked with this oversight are the Independent Governance Committees (IGCs) and Governance Advisory Arrangements (GAAs). With the FCA's eyes on assessing value for money (VFM), these bodies should scrutinise the VFM provided by workplace pensions schemes. 

Whilst GAAs are more appropriate for smaller and less complex products, oversight and appropriate governance arrangements are still crucial. 

There is a clear duty to act in the best interests of scheme members, including challenging the VFM of pension schemes.

The IGCs and GAAs need to be appropriately structured and resourced. Good corporate governance should also include processes and frameworks that enable oversight including timely management information. For example, consideration of what information is required to enable a good understanding of fees charged. 

FCA’s thematic review from 2020 identified that governing bodies had a positive impact upon member outcomes. It also identified some areas of concern: 

Governing bodies must demonstrate independence from the firms. Whilst GAAs are likely to be third parties and offer greater independence, evidence suggests that they are less effective in delivering VFM.

Effective Governance:

Some governing bodies have detailed frameworks and considered the needs of different members such as charges and investment strategies. Other governing bodies consider members collectively leading to poor outcomes for some members.

Effective governance requires the governing bodies to receive information in good time to complete analysis and enable decision making. The governing bodies may lack the right information to enable their analysis. This may be due to matters beyond a firm’s control. For example, the FCA introduced rules in 2018 requiring asset managers to provide information on transaction costs. This addressed a gap where relevant information was not provided to governing bodies.

In summary, good governance means having the following in place:

Assessing VFM:

The VFM assessment includes analysis of: 

VFM assessment should enable clear improvements, perhaps leading to cost reductions or better administration or more appropriate funds.

Steps for success:

IGCs and GAAs should review their composition and consider the levels of expertise, skills and experience of their membership. This should be an annual review to identify any emerging weaknesses and enable early engagement of external expertise when required.

The governing bodies should then review what information they require and where that information resides. Data may be required from multiple sources.

How do they access that information to enable informed decision-making and demonstrate oversight?

Ruleguard can help firms to collate third party information in one secure environment and facilitate management information and provide reassurance to the Board.

Ruleguard's Pensions Solutions

Our pensions compliance software helps you build rock-solid relationships with regulators, clients, and third-party suppliers while ensuring continued employee compliance and individual accountability.

If you’d like to learn more about the Ruleguard’s Pensions Solutions please contact us for further information on: Tel: 0800 408 3845 or hello@ruleguard.com.