Agenda item

COMPLIANCE CHECKLIST

Minutes:

The following sections were discussed and points noted:

 

Section B – Knowledge and Understanding

 

B8 – Are all pension board members investing sufficient time in their learning and development? Members agreed that the requirement was fully compliant.  Members of the Pensions Committee needed to complete a skills audit prior to a training plan being drawn up, however training was undertaken prior to consideration of specialist decisions.

 

B12 – Have the pension board members completed the Pension Regulator’s toolkit for training on the Code of Practice number 14?  It was requested that all members should complete the Pensions Regulator toolkit within 6 months.  Members were requested to forward any certificates of training completed to the Pensions Manager to ensure completeness of the training register.

 

Section C – Conflicts of Interest

 

C7 – Is appropriate information included in the register? New members to complete the conflicts register.

 

Section D – Publishing Information about Schemes

 

D2 – Does the Administrating Authority publish other useful related information about the Pension Board? The website required updating to include job titles and any other relevant roles held by members.  Once completed, the requirement would be compliant.

 

Section E – Managing Risk and Internal Controls

 

E1 – Is there an agreed process for identifying and recording scheme risks? The pending audit would ensure that all checks were in place.  Once the audit had been completed, the requirement would be compliant.

 

E2 – Does the Fund have an adequate process to evaluate risks and establish internal controls? The pending audit would ensure that all checks were in place.  Once the audit had been completed, the requirement would be compliant.

 

E4 – Does the Administrating Authority review the effectiveness of the risk management and internal control systems of the Fund? The pending audit would ensure that all checks were in place.  Once the audit had been completed, the requirement would be compliant.

 

E6 – Is there a standing item on the Pension Board agenda to review scheme risks? Although the review of scheme risks was not a standing item on agendas, the risk register would be reviewed on an annual basis.

 

E7 – Does the Administrating Authority have adequate systems, arrangements and procedures (internal controls) in place for the administration and management of the Fund and are they documented? The pending audit would ensure that all checks were in place.  Once the audit had been completed, the requirement would be compliant.

 

E8 – Do these procedures apply equally to outsourced services, are internal controls reflected in contracts with third party providers and is there adequate reporting in relation to those controls? The pending audit would ensure that all checks were in place.  Once the audit has been completed, the requirement would be compliant.

 

Section F – Administration and Scheme Record Keeping

 

F2 – Does the Fund have the appropriate processes in place so employers can provide timely and accurate information? Members agreed that the requirement was compliant and further agreed that the requirement would be monitored as a KPI.  ‘Your Fund’ was in place and appropriate training had been offered to all scheme employers; and the Pensions Committee had delegated the approval of the Charging Policy to the Section 151 Officer. 

 

F3 – Does the Fund keep records of and reconcile transactions as required by the Record Keeping Regulations? Reconciliation was done on a quarterly basis.  Due to there being no interface between Altair and Oracle, there may be discrepancies.  Confirmation was sought on whether there was a requirement in the Record Keeping Regulations.

 

F7 – Does the Administrating Authority have policies and processes to monitor data on an ongoing basis?  The pending audit would ensure that all checks were in place.  Once the audit had been completed, the requirement would be compliant.

 

F9 – Is a data improvement plan in place which is being monitored with a defined end date? There was currently no formal data improvement plan.  Members requested that a date be inserted for the provisional plan to be submitted.  Members further requested that a report on the data score be presented to the next meeting.

 

Section H – Providing Information to Members and Others

 

H9 – Is all other information provided in accordance with the legal timescales? Checks to be undertaken to ensure compliance with Disclosure Regulations; and to be written into monitoring checklists.  Action outstanding.

 

Section I – Internal Dispute Resolution

 

I4 – Has the Administering Authority ensured that employers who make first stage decisions also have IDRP in place? A discretion review was being undertaken and a report would be submitted to the Committee in March.

 

Members requested that timescales be included on all actions highlighted either red or amber.

 

Actions:

 

i)          C7 - New members to complete the conflicts register – Denise Broom.

 

ii)         D2 - The website required updating to include job titles and any other relevant roles held by members – Caroline Berry.

 

iii)       E1, E2, E4, E7, E8 and F7 to be reviewed as part of Internal Audit  process.

 

iv)       E6 - The board agreed to include the risk register as a standing item going forward.

 

v)        F3 – Confirmation to be sought on the reconciliation requirements in the Record Keeping Regulations – Caroline Berry.

 

vi)       F9 – Pension Board Regulator draft plan and a report on the data score to be presented to the next meeting – Caroline Berry / Victoria Freeman.

 

vii)      H9 – Is all other information provided in accordance with the legal timescales? Checks to be undertaken to ensure compliance with Disclosure Regulations; and to be written into monitoring checklists.  Action outstanding – Caroline Berry.

 

viii)    Timescales to be included on all actions highlighted either red or amber.

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