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Comet Pension Scheme

We’re all professionals, right?

Consultation on the Association of Professional Pension Trustees (APPT) draft standards for professional trustees closed a short while ago. We all seem to be up for increasing professionalism and standards in the independent pension trustee world. I am, for sure. After all PSIT has been talking about it for years (I called for a code of conduct at the Professional Pensions Show back in 2011!) However, I want more than the APPT’s proposed standards offer.

Professional trustees have great responsibility and in many cases are well rewarded for this role, but it pains me when I hear a professional trustee say (as I did recently) that he “didn’t like people monitoring what he was doing” and “wanted more freedom”. Really? Are your scheme members best served by being some uncontrolled free spirit?

Evidence gives clients comfort and certainty – it also delivers better member outcomes

We sincerely hope the APPT’s proposed standards will have a positive impact – we fully support the ideals but it will be very difficult to test compliance against them. That’s probably why a ‘comply or explain’ approach is being suggested as an interim measure. However, where evidence is easy to provide we think it must be provided in the annual disclosures. A good example is providing evidence of adequate professional indemnity insurance.

Another example is how a professional pension trustee demonstrates they have in place ‘processes to maintain continuity of service and ensure peer review of key decisions where necessary’. Those professional trustees, like ourselves, who are on the Pensions Regulator’s register are already required to produce an annual assurance report that is externally audited. Any industry wide accreditation structure should use this as the base requirement so effort is not duplicated.

This annual AAF audit is another piece of hard evidence. As a minimum, it includes testing the following controls:

  • data security policy and adequate systems controls
  • keeping knowledge and learning requirements up to date
  • risk management framework, recording and escalating business risks as necessary
  • identifying and managing conflict of interests appropriately

These are critical to a professional trustee committed to high standards of conduct. Fail on any of these points and you are not doing your job properly.

This is serious

Professional trustees must accept they need to raise their standards, or some (possibly bad) standards will be imposed on us. Look at history and we can see the actuarial profession worked out long ago that the idea of an uncontrolled free spirit would not serve the industry well. They introduced professional standards for quality and peer review and have improved standards ever since.

Personally, I wouldn’t be happy if we ended up with the complexity that comes with the actuarial professional standards, but we are a long way off being even half way close to them! And actuaries don’t have to cover the full range of issues professional trustees need to deal with....

 

 

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