Agenda item

This paper sets out in Appendix 1 the requirements of the Hammersmith & Fulham Pension Fund in complying with the Pension Regulator’s general code of practice.

Eleanor Dennis (Head of Pensions) introduced the report which sets out the requirements of the Hammersmith & Fulham Pension Fund in complying with the Pension Regulator’s general code of practice. The Fund asked consultancy, Barnett Waddingham to carry out a gap analysis of the requirements versus what the Fund had in place and present an overview including any recommendations.

Gavin Paul (Barnett Waddingham) gave a presentation on the general code of practice compliance review. He showed slides that highlighted the following key aspects: 

• Background to the general code and general code of practice.
• The review used a RAG rating to highlight areas of compliance, non-compliance and areas for improvement. Overall, 75% of the modules meet the TPR’s expectations for Fund (highlighted in green) and noted that there were no red ratings (i.e. non-compliance).
• Some of the Fund’s documents were understandingly not publicly available, and in those areas a level of assumptions had been factored into the rating.
• The next steps recommended for the Fund were:

o   Update key documents and policies to ensure continued full compliance with the requirements of the general code.

o   Build in review cycles for each module to ensure policies, processes and procedures remained relevant and continued to meet the expectations.

It was noted that the document would be updated as and when required and would therefore continue to evolve.

Councillor Adam Peter Lang thanked Barnett Waddingham for their clear presentation and regarding the amber warnings, asked who would be responsible for carrying out the required actions. In response Gavin Paul explained that it was the officer’s responsibility to fill in the gaps and report back to the Committee.

Councillor Florian Chevoppe-Verdier noted that the presence of 40 green indicators, only 2 ambers and no red was something to be celebrated, as it demonstrated the consistent quality and dedication of those ensuring ‘round the clock’ compliance. He also requested further clarification regarding the inability to locate certain documentation. Gavin Paul reassured the Committee that while the documents did exist, they were not in the public domain due to the inclusion of sensitive information and for good reason were not suitable for public disclosure.

Councillor Florian Chevoppe-Verdier asked for further clarification to be provided on the pension scam strategy. Eleanor Dennis noted that this had been contracted to LPPA, who were compliant with the regulator in issuing scam notices. She added that any amber or red flags would be referred to for a decision. While a process was in place, it could be further developed and formalised into an explicit policy.

David Hughes (Director of Audit, Fraud, Risk and Insurance) further noted that officers worked closely with LPPA’s internal auditors, who maintained an internal audit programme. He added that they provided officers with the results of their work and that an update on the Council’s internal audit programme would be presented at the June meeting.

Sam Gervaise-Jones (Independent Investment Advisor) asked for further clarification regarding the one item that had not been assessed. In response Gavin Paul reassured the Committee that this was merely an introductory module that was already covered in other modules in the document.

Councillor Ashok Patel enquired whether there were plans to expand the training to members in due course. Eleanor Dennis explained that the Treasury and Investment colleagues already provided training twice a year, and she had also circulated any relevant conference courses to both Board and Committee members.

The Chair thanked Gavin Paul (Barnett Waddington) and congratulated the officers on the many positive, green outcomes highlighted in the review.

RESOLVED

The Pension Fund Committee noted the report.