Agenda item

Report attached and verbal update to be given by officers.

The following sections were discussed and points noted:

Section C – Conflicts of Interest

C2 – Do pension board members have a clear understanding of their role, the circumstances in which they may have a conflict of interest and how to manage potential conflicts? It was noted that Anne Giles, Virpi Raivio and Mark Holder had completed the TPR online toolkit module covering conflicts of interest, therefore it was agreed that the requirement was compliant.

C3 – Have all Pension Board members provided appropriate information for the Administering Authority to determine whether a conflict exists (on appointment and from time to time)?  As C2 above.

C4 – Does the appointment process for pension board members require disclosure of interest and responsibilities which could become conflicts of interest? Members agreed that the requirement was compliant as declarations were sought from members at each meeting.

C5 – Is the conflicts policy regularly reviewed? Members sought clarification on whom was responsible for the Conflicts Policy.

C6 – Does the Fund have a conflicts register and is it circulated for ongoing review and published? Members sought clarification as to whether their declarations should be published on the Council’s website.

C7- Is appropriate information included in the register? As C6 above.

C9 – Do those involved know how to report a conflict of interest? Members agreed that the requirement was compliant as consideration had been given to training session on conflict of interests to board members.

Section G – Maintaining Contributions

G1 – Does the Fund have procedures and processes in place to identify payment failures?  Member requested that an explanation be provided of the process in place to identify late payments.

G4 – Are these procedures regularly reviewed to ensure they are effective?  Members considered that the Council were compliant in this area as finances were checked on a monthly basis against schedules, payroll and the bank.  Furthermore, the situation was checked at year end.

G5 – Do the Administering Authority’s processes include managing overdue contributions in line with TPR’s suggested approach?  The Council had a Charging Policy, however it did not contain specific information regarding late payments, however regulations allowed for this.  Members suggested that when the Charging Policy was next reviewed, that reference be included to charging a fee for administration for processing late payments and interest charges.

G6 – Does the Fund maintain a record of any investigations and communications with employers? Members agreed that the Council would be compliant as of the 1 April 2018, when all communication between the pension fund and an employer regarding contributions would be held on a central record.

G8 – Is there a satisfactory process in place to assess the materiality of any payment failures and ensure that those which are material are reported to the Regulator within a reasonable period?  Members were advised that consideration to the process would be given during the review of the Charging Policy.

Actions:

C5 – Details of who hold responsibility for the Conflicts Policy to be provided to members, together with details of frequency of review – Victoria Freeman.

C6 – Clarification to be provided as to whether Local Pension Board members declarations should be published on the Council’s website – Lillian Thomas.

G1 - An explanation to be provided of the process in place to identify late payments – Caroline Berry.

G5 - Members suggested that when the Charging Policy was next reviewed, that reference be included to charging a fee for administration for processing late payments and interest charges – Caroline Berry.