group trustees’ statement on dc governance - aegon uk · 2019-11-29 · and governance)...

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1 Group Trustees’ Statement on DC Governance The Occupational Pension Schemes (Scheme Administration) Regulations 1996 (“the Administration Regulations”), as amended by the Occupational Pension Schemes (Charges and Governance) Regulations 2015, require the Group Trustees to include an annual statement regarding governance in the Annual Report. This looks at the default arrangement, the way scheme transactions are processed, transaction costs and value for money. This document sets out the Statement covering the period 1 April 2018 to 31 March 2019. This Statement will be published on a publically available website and will be signposted in the annual benefit statements. Default Arrangement In accordance with the Administration Regulations, the Trustee has appended the latest copy of the Statement of Investment Principles (the ‘SIP’) prepared for the Scheme in compliance with Section 35 of the Pensions Act 1995 (the ‘1995 Act’) and regulation 2 / regulation 2A of the Occupational Pension Schemes (Investment) Regulations 2005 (the ‘Investment Regulations’). The Trustee has made this available on the site URL: https://lwp.aegon.co.uk/io/western_power Members of the Defined Contribution (“DC”) Sections of the Group who do not make an explicit choice regarding the investment of their funds use a lifestyle strategy as a default arrangement. The objective of this strategy is to provide investment growth by investing in return seeking assets in a diversified portfolio, with gradual switching of assets over the five years before a member’s expected retirement date, towards a final position of 25% Cash, 30% Pre- Retirement and 45% Diversified Growth. The lifestyle strategy invests in a series of funds managed by BlackRock, Invesco and Schroders, which meet the requirements for social, environmental and ethical considerations set out as an appendix to the Group Trustees’ Statement of Investment Principles. The Group Trustees reviewed how the funds within the Group’s default investment arrangement and the wider fund options performed against their targets at quarterly meetings, taking input from their professional advisers. The Group Trustees also reviewed the suitability of the default arrangements on a quarterly basis. The Group Trustees have had concerns over the performance of the BlackRock Global Equity 50/50 Fund, as returns were not being generated at the level the Group Trustees had anticipated in their SIP. Throughout 2018, the Group Trustees decided to introduce a new fund for the Scheme, which comprised of underlying funds of 10% emerging markets equity, 10% small cap equity, 30% UK equity and 50% Overseas Equity. The new equity fund replaced the previous global equity fund component within the lifestyle strategy.

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Page 1: Group Trustees’ Statement on DC Governance - Aegon UK · 2019-11-29 · and Governance) Regulations 2015, require the Group Trustees to include an annual statement regarding governance

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Group Trustees’ Statement on DC Governance

The Occupational Pension Schemes (Scheme Administration) Regulations 1996 (“the Administration Regulations”), as amended by the Occupational Pension Schemes (Charges and Governance) Regulations 2015, require the Group Trustees to include an annual statement regarding governance in the Annual Report. This looks at the default arrangement, the way scheme transactions are processed, transaction costs and value for money. This document sets out the Statement covering the period 1 April 2018 to 31 March 2019. This Statement will be published on a publically available website and will be signposted in the annual benefit statements. Default Arrangement In accordance with the Administration Regulations, the Trustee has appended the latest copy of the Statement of Investment Principles (the ‘SIP’) prepared for the Scheme in compliance with Section 35 of the Pensions Act 1995 (the ‘1995 Act’) and regulation 2 / regulation 2A of the Occupational Pension Schemes (Investment) Regulations 2005 (the ‘Investment Regulations’). The Trustee has made this available on the site URL: https://lwp.aegon.co.uk/io/western_power Members of the Defined Contribution (“DC”) Sections of the Group who do not make an explicit choice regarding the investment of their funds use a lifestyle strategy as a default arrangement. The objective of this strategy is to provide investment growth by investing in return seeking assets in a diversified portfolio, with gradual switching of assets over the five years before a member’s expected retirement date, towards a final position of 25% Cash, 30% Pre-Retirement and 45% Diversified Growth. The lifestyle strategy invests in a series of funds managed by BlackRock, Invesco and Schroders, which meet the requirements for social, environmental and ethical considerations set out as an appendix to the Group Trustees’ Statement of Investment Principles. The Group Trustees reviewed how the funds within the Group’s default investment arrangement and the wider fund options performed against their targets at quarterly meetings, taking input from their professional advisers. The Group Trustees also reviewed the suitability of the default arrangements on a quarterly basis. The Group Trustees have had concerns over the performance of the BlackRock Global Equity 50/50 Fund, as returns were not being generated at the level the Group Trustees had anticipated in their SIP. Throughout 2018, the Group Trustees decided to introduce a new fund for the Scheme, which comprised of underlying funds of 10% emerging markets equity, 10% small cap equity, 30% UK equity and 50% Overseas Equity. The new equity fund replaced the previous global equity fund component within the lifestyle strategy.

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During the Scheme year, the Group Trustees also reviewed the de-risking of the default lifestyle strategy and decided to make some changes, namely reducing the cash allocation at retirement to 25% from the previous 30% and to transfer 5% of the allocation to Diversified Growth. By investing in this manner, the Group Trustees expect to deliver growth over the member’s lifetime within the Group without excessive risk taking, with an increased focus in the final five years of reducing volatility to enable members approaching retirement to make financial plans for the period after retirement. The Group Trustees consider this approach to be in the best interests of members and beneficiaries. The principles noted above relating to the default arrangement were last reviewed by the Group Trustees in November 2018, and are due to be reviewed every three years thereafter.

Processing Scheme Transactions The Group Trustees have a specific duty to ensure that core financial transactions (including the investment of contributions, transfer of member assets into and out of the Group, transfers between different investments within the Group and payments to and in respect of members) relating to the DC Section are processed promptly and accurately. These transactions are undertaken on the Group Trustees’ behalf by the Group Administrator, and its investment managers Blackrock, Invesco and Schroders. The Group Trustees have reviewed the processes and controls implemented by those organisations and consider them to be suitably designed to achieve these objectives. The Group Trustees have also agreed service levels and reporting of performance against those service levels. The service level agreement covers the accuracy and timeliness of all core financial transactions. The Scheme has a service level agreement in place for investing contributions in relation to the DC Sections. The service level agreement was met for the Scheme year. Contributions are paid within the timescales detailed in the Contribution Schedule. Money held in bank accounts is minimised with contributions invested in a timely manner. All contributions are invested at the next available dealing date after receipt. The Group Administrator conducts regular checks to ensure that the common and conditional data is complete and accurate. The Group administrator undertakes annual data cleansing exercises to ensure that the data held is accurate. The Group administrators raise any issues with the data with the Group Trustees. Group Trustees receive quarterly reports which they use to review and monitor the timely investment of contributions. The Group Trustees maintain the core financial transactions promptness and accuracy under regular review.

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In addition, the Group Trustees have commissioned an outsourced internal audit function to perform additional testing to support their assessment of whether the controls are operating effectively. The Group Trustees also have a Risk Register in place which outlines the main risks to the Scheme including operational, financial and risks to the members. The Risk Register is monitored and reviewed as needed, and in any event at least annually. In light of the above, the Group Trustees consider that the requirements for processing core financial transactions specified in the Administration Regulations have been met and core financial transactions have been processed promptly and accurately, with one exception during the Scheme year. In February 2019, contributions relating to the Central Networks Group of the Electricity Supply Pension Scheme had been incorrectly added by Aegon to the total units for another scheme within the sponsoring employer's corporate group. The position was rectified and the error corrected by the end of the month. Aegon has confirmed that an additional check had been put in place to avoid this issue recurring in the future and that no member losses occurred as a result of this error. The Group Trustees have delegated the day to day management of the Additional Voluntary

Contribution (“AVC”) assets to Aviva, Standard Life, Equitable Life and Prudential.

Charges and Transaction Costs The Administration Regulations require the Group Trustees to make an assessment of charges and transaction costs borne by the DC Sections’ members and the extent to which those charges and costs represent good value for money for members. We note that while transaction costs and charges are an important consideration, they are

not the only criteria the Group Trustees assess. A number of other qualitative and

quantitative factors are also considered in a holistic manner when making strategic

decisions in relation to investment strategy with good outcomes for members being the

ultimate goal for the Scheme.

Fund charges

The Group Trustees have taken account of statutory guidance when preparing this section

of the statement and have not deviated from the approach set out in that guidance.

Charges relating to investment management are deducted from the funds in which Scheme

members are invested.

The costs borne by members are in two forms – the annual management charge (“AMC”)

and the total expense ratio (“TER”). The AMC is the core charge that covers the cost of

accessing and managing a fund. The TER includes the AMC plus variable costs (Additional

Expenses “AE”) associated with managing a fund such as administrative, audit and legal

fees.

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The Scheme complies with the regulations on charge controls introduced from April 2015.

Specifically, the Scheme’s default has a Total Expense Ratio (‘TER’) that is well below the

charge cap of 0.75% p.a. at each stage of the lifestyling process.

The default arrangement attracts a total expense ratio (TER) of between 0.38% per annum and 0.45% per annum of assets under management for all members. This is lower than the maximum allowed of 0.75% and the Group Trustees are satisfied that they have negotiated a good deal for members. The Group Trustees also make available a range of three alternative lifestyle options and eight pooled funds which may be chosen by members as an alternative to the default arrangement. These funds attract annual charges of between 0.11% and 0.67%. The TERs were set out in the member announcements on the fund changes. These funds allow members to take a more tailored approach to managing their own investments.

Fund Name AMC % p.a. AE % p.a. TER % p.a.

Aegon BlackRock 50/50 Global Equity Index 0.13 0.01 0.14

Aegon BlackRock Cash 0.10 0.03 0.13

Aegon BlackRock Corp Bond All-Stocks Index 0.13 0.02 0.15

Aegon BlackRock Over 15 Years Gilt Index 0.10 0.01 0.11

Aegon BlackRock Over 5 Year Index Linked Gilt Index

0.10 0.01 0.11

Aegon BlackRock Pre-Retirement 0.15 0.01 0.16

WPD Diversified Growth 0.64 0.03 0.67

WPD Global Equity 0.21 0.02 0.23

Source: Aegon, as at 31 March 2019. Transaction Costs In addition to investment management charges and the additional fund expenses included in the TER, investment funds are subject to other implicit costs, such as the investment manager’s expenses associated with trading a fund’s underlying securities, including commissions and stamp duty. These expenses are not explicitly deducted from the fund but are captured by a reduction in investment returns.

The Financial Conduct Authority has provided guidance (PS17/20) to investment managers regarding calculations and disclosures of transaction costs which comply with the updated Administration Regulations. The Group Trustees have requested this information from the underlying fund managers, through the Scheme’s investment platform provider, details of the transaction costs, where received, can be found in Appendix A (and where it has not been possible to obtain this information, Appendix A also sets this out along with the steps we are taking to obtain it). The Group Trustees have made this information accessible to members on the site URL:

https://lwp.aegon.co.uk/io/western_power

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AVCs The Scheme has holdings in with profits AVC policies with Prudential, Standard Life, Equitable Life and Aviva. The holdings are relatively small in scale relative to the size of the Scheme’s main arrangements held with Aegon.

With respect to the with-profits policies, payouts on surrender and maturity will reflect all charges incurred, though they are not separately identified. Moreover, the actual performance received by members, net of charges, is only known upon maturity/surrender, after any augmentation for guaranteed terms and after the effect of any ‘smoothing’.

The unit linked AVC charges incurred by members will vary depending on the funds members are invested in with Prudential, Standard Life, Equitable Life, Aegon and Aviva.

The Trustee has sought to quantify the charges and transaction costs associated with the holdings in these policies by requesting the information from the provider in line with the prescribed transaction cost disclosure methodology. Details of the AVC transaction cost and member charge information, where received, is found in Appendix A (and where it has not been possible to obtain this information, Appendix A also sets this out along with the steps we are taking to obtain it).

Transaction Cost Illustrations

Using the charges and transaction cost data provided by the relevant parties and in accordance with regulation 23(1)(ca) of the Administration Regulations, as inserted by the 2018 Regulations, the Group Trustees have prepared an illustration detailing the impact of the costs and charges typically paid by a member of the Scheme on their retirement pension savings. The statutory guidance has been considered when providing these examples. The illustrations that follow take into account the following elements:

- Initial pension savings size; - Real terms investment return gross of costs and charges; - Adjustment for the effect of costs and charges; and - Time.

To illustrate the impact of charges on a typical member’s pension savings, we have provided examples below. The illustrations account for all estimated member costs, including the Total Expense Ratio, transaction costs and inflation. The gross growth rate assumptions are taken from the Statutory Money Purchase Illustrations for the Scheme, as at 31 March 2019. Given that there is only one active member within the Scheme, projection illustrations have only been provided for deferred members in order to preserve the one active member’s personal information.

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Illustration 1: Average Deferred Member

Year

Most Popular Fund:

Default

TER, 0.38-0.45% p.a.

Transaction Cost,

0.22-0.25% p.a.*

Cheapest Fund:

Over 15 Years Gilt

Index

TER, 0.11% p.a.

Transaction Cost,

0.00% p.a.

Most Expensive

Fund: WPD DGF

TER, 0.67% p.a.

Transaction Cost,

0.477% p.a.

Lowest Expected

Investment Return

Fund: Cash

TER, 0.13% p.a.

Transaction Cost,

0.02% p.a.

Highest Expected

Investment Return

Fund: 50/50 Global

Equity Index

TER, 0.14% p.a.

Transaction Cost,

0.01% p.a.

Fund (£) Fund (£) Fund (£) Fund (£) Fund (£)

Savings

Size with

no

Charges

Incurred

Savings

Size with

Charges

Incurred

Savings

Size

with no

Charges

Incurred

Savings

Size with

Charges

Incurred

Savings

Size with

no Charges

Incurred

Savings

Size with

Charges

Incurred

Savings

Size with

no Charges

Incurred

Savings

Size with

Charges

Incurred

Savings

Size with

no Charges

Incurred

Savings

Size with

Charges

Incurred

47 £18,000 £18,000 £18,000 £18,000 £18,000

48 £18,495 £18,367 £17,820 £17,800 £18,450 £18,238 £17,820 £17,793 £18,540 £18,512

49 £19,004 £18,741 £17,642 £17,603 £18,911 £18,480 £17,642 £17,589 £19,096 £19,039

50 £19,526 £19,123 £17,465 £17,408 £19,384 £18,725 £17,465 £17,387 £19,669 £19,581

55 £22,363 £21,152 £16,609 £16,464 £21,931 £19,998 £16,609 £16,411 £22,802 £22,530

60 £25,612 £23,396 £15,795 £15,571 £24,813 £21,358 £15,795 £15,490 £26,434 £25,923

65 £27,586 £24,381 £15,021 £14,727 £28,074 £22,810 £15,021 £14,621 £30,644 £29,827

*Transaction cost information for the WPD Global Equity fund was not available from Aegon as at the time of writing. We have used the same transaction cost value as the 50/50 Global Equity Index for indicative illustration purposes.

Notes

1. Values shown are estimates and are not guaranteed. 2. Projected pension savings values are shown in today’s terms. 3. The starting pension savings size is assumed to be £18,000 and this member joined at

age 47. 4. Inflation increases is assumed to be 2.5% per annum. 5. The projected real gross growth rates for each fund are as follows:

Details on the aggregate transaction costs incurred by each fund can be found in Appendix A.

Fund: Default 2.8% p.a. above inflation for members further than 5 years from retirement

0.7% p.a. above inflation for members at or beyond retirement

Fund: Over 15 Years Gilt Index 1.0% p.a. below inflation

Fund: WPD DGF 2.5% p.a. above inflation

Fund: Cash 1.0% p.a. below inflation

Fund: 50/50 Global Equity Index 3.0% p.a. above inflation

Page 7: Group Trustees’ Statement on DC Governance - Aegon UK · 2019-11-29 · and Governance) Regulations 2015, require the Group Trustees to include an annual statement regarding governance

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Illustration 2: Youngest Deferred Member

Year

Most Popular Fund:

Default

TER, 0.38-0.45% p.a.

Transaction Cost,

0.22-0.25% p.a.*

Cheapest Fund:

Over 15 Years Gilt

Index

TER, 0.11% p.a.

Transaction Cost,

0.00% p.a.

Most Expensive

Fund: WPD DGF

TER, 0.67% p.a.

Transaction Cost,

0.477% p.a.

Lowest Expected

Investment Return

Fund: Cash

TER, 0.13% p.a.

Transaction Cost,

0.02% p.a.

Highest Expected

Investment Return

Fund: 50/50 Global

Equity Index

TER, 0.14% p.a.

Transaction Cost,

0.01% p.a.

Fund (£) Fund (£) Fund (£) Fund (£) Fund (£)

Savings

Size with

no

Charges

Incurred

Savings

Size with

Charges

Incurred

Savings

Size with

no

Charges

Incurred

Savings

Size with

Charges

Incurred

Savings

Size with

no

Charges

Incurred

Savings

Size with

Charges

Incurred

Savings

Size with

no

Charges

Incurred

Savings

Size with

Charges

Incurred

Savings

Size with

no

Charges

Incurred

Savings

Size with

Charges

Incurred

35 £3,500 £3,500 £3,500 £3,500 £3,500

36 £3,596 £3,571 £3,465 £3,461 £3,588 £3,546 £3,465 £3,460 £3,605 £3,600

37 £3,695 £3,644 £3,430 £3,423 £3,677 £3,593 £3,430 £3,420 £3,713 £3,702

38 £3,797 £3,718 £3,396 £3,385 £3,769 £3,641 £3,396 £3,381 £3,825 £3,807

39 £3,901 £3,794 £3,362 £3,347 £3,863 £3,689 £3,362 £3,342 £3,939 £3,916

40 £4,008 £3,871 £3,328 £3,310 £3,960 £3,738 £3,328 £3,304 £4,057 £4,027

45 £4,591 £4,282 £3,165 £3,131 £4,480 £3,992 £3,165 £3,118 £4,704 £4,634

50 £5,258 £4,737 £3,010 £2,961 £5,069 £4,264 £3,010 £2,943 £5,453 £5,331

55 £6,021 £5,239 £2,863 £2,800 £5,735 £4,553 £2,863 £2,778 £6,321 £6,134

60 £6,896 £5,795 £2,722 £2,648 £6,489 £4,863 £2,722 £2,622 £7,328 £7,058

65 £7,581 £6,158 £2,589 £2,505 £7,341 £5,194 £2,589 £2,475 £8,495 £8,121

*Transaction cost information for the WPD Global Equity fund was not available from Aegon as at the time of writing. We have used the same transaction cost value as the 50/50 Global Equity Index for indicative illustration purposes.

Notes

1. Values shown are estimates and are not guaranteed. 2. Projected pension savings values are shown in today’s terms. 3. The starting pension savings size is assumed to be £3,500 and this member joined at

age 35. 4. Inflation increases is assumed to be 2.5% per annum. 5. The projected real gross growth rates for each fund are as follows:

Details on the aggregate transaction costs incurred by each fund can be found in Appendix A.

Fund: Default 2.8% p.a. above inflation for members further than 5 years from retirement

0.7% p.a. above inflation for members at or beyond retirement

Fund: Over 15 Years Gilt Index 1.0% p.a. below inflation

Fund: WPD DGF 2.5% p.a. above inflation

Fund: Cash 1.0% p.a. below inflation

Fund: 50/50 Global Equity Index 3.0% p.a. above inflation

Page 8: Group Trustees’ Statement on DC Governance - Aegon UK · 2019-11-29 · and Governance) Regulations 2015, require the Group Trustees to include an annual statement regarding governance

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The Group Trustees fully support transparency of costs for members. We also reiterate that while costs and charges are an important consideration, they are not the only criteria the Group Trustees assess. A number of other qualitative and quantitative factors are typically considered in a holistic manner when making strategic decisions in the best interests of the Sections’ members. These factors include, but are not limited to, wider market trends, pension savings sizes, distance to retirement, and look through analysis of investments. Value for Money Considerations The Group Trustees are committed to ensuring that members receive good value from the Scheme. In conjunction with their professional advisers, the Group Trustees undertook a value for money assessment as part of the DC Section’s annual manager fee review in May 2019. The Group Trustees concluded that the DC Section’s charges and transaction costs represent good value for money. The reasons underpinning this conclusion include:

Charges for the DC Section’s default investment arrangement are significantly below the charge cap of 0.75% per annum;

Charges and transaction costs on funds have been assessed by the Group Trustees’ advisers as comparing favourably with those of peer funds;

The funds used by the DC Section are highly rated by the Group Trustees’ investment advisers as having good prospects of achieving their risk and return objectives;

The performance of the DC Section’s funds, where available over the 3 years to 31 March 2019, compare favourably relative to the benchmarks set by the Group Trustees. The WPD Diversified Growth Fund and WPD Global Equity Fund do not have sufficient track record to comment on 3 year performance;

Members benefit from Group Trustee oversight;

Members are supported by a suite of communications, which focus on providing members with the information they need in simple plain English; and

A good fund range is offered to members, with funds across the risk/return spectrum

to cater for a range of member needs.

Additionally, the Company pays for all administration, member communication and advisory costs associated with operating the DC Sections.

The Group Trustees undertake annual assessments and the next formal Value for Money assessment will be take place for the year ending 31 March 2020.

DC Section Governance As Group Trustees of the Central Networks Group of the Electricity Supply Pension Scheme, we have reviewed and assessed that our systems, processes and controls across key governance functions are consistent with those set out in The Pension Regulator’s:

Code of Practice 13: Governance and administration of occupational defined contribution trust-based schemes; and

Page 9: Group Trustees’ Statement on DC Governance - Aegon UK · 2019-11-29 · and Governance) Regulations 2015, require the Group Trustees to include an annual statement regarding governance

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Regulatory guidance for defined contribution schemes. Based on our assessment we believe that we have adopted the standards of practice set out in the DC code and DC regulatory guidance. These help demonstrate the presence of DC quality features, which we believe will help deliver better outcomes for members at retirement. Trustee knowledge and understanding Sections 247 and 248 of the Pensions Act 2004, requires individual Trustee board members to have appropriate knowledge and understanding of the law relating to pensions and trusts and the investment of the assets. A corporate trustee must ensure that its directors have appropriate knowledge and understanding as if they were individual Trustees. The degree of knowledge and understanding required is that appropriate for the purposes of enabling the Group Trustees to exercise their functions as Group Trustees. Trustee training is of high importance to the good running of the Scheme. The Group Trustees acknowledge how vital it is that they maintain their knowledge of pension law, trust law, investment principles and are conversant with the Scheme documentation including the Trust Deed and Rules, SIP and Scheme policies. The Group Trustees are also required to explain how their combined knowledge and understanding, together with the advice which is available to them, enables them properly to exercise their functions as Group Trustees of the Scheme. The Group Trustees, having considered the points set out in the remainder of this section, and assessed their position against the Scheme’s business plan do consider that they are able to properly exercise those functions. Training In order to maintain this high level of knowledge, the Group Trustees have procedures and policies in place to ensure that the Trustees take personal responsibility for keeping up to date with relevant developments:

- The Group Trustees have completed the Pension Regulator’s Trustee Toolkit and new Trustee Board members are encouraged to complete this;

- New Trustee Board members are provided with induction training, including sessions from the Scheme’s legal, actuarial and investment advisers (which was run for a new member in May 2018);

- Group Trustees undertake additional training to ensure that they keep up to date with changes in legislation, current issues and the latest developments relating to DC Schemes;

- The Group Trustees are satisfied that they have the appropriate knowledge for their role. Group Trustees carry out self-assessment of training needs. The Group Administrator reviews the self-assessments and arranges for training to be made available to individual Group Trustees or the whole Trustee body as appropriate; and

- Formal training is provided from time to time.

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Over the course of last year, the Group Trustees have demonstrated their continuous commitment to learning by undertaking the following training:

- Ongoing training on issues relating to the introduction of the GDPR throughout the period;

- Legal issues update on case law, Pensions Ombudsman determinations and other legal developments (September 2018);

- GMP equalisation training from the Scheme’s legal adviser (November 2018); - Environmental, Social and Governance training (March 2019); and - Current DC issues – Mercer provides an update on these as part of the quarterly

trustee meetings. Examples Demonstrating Trustee Knowledge and Understanding

The Group Trustees undertook a number of activities over the past year which demonstrates how they have a working knowledge of pension and trust law and funding and investment principles. These activities include:

- The SIP is reviewed from time to time and updated when investment strategy changes are made; This demonstrates their knowledge of the Scheme SIP; and

- The investment arrangements are reviewed and monitored, this demonstrated knowledge of the Scheme investments; and The Risk Register is reviewed and updated as needed, and in any event at least

annually. This demonstrates that the Group Trustees have the required knowledge

of the Pensions Regulator’s DC Code and hold relevant knowledge on DC specific

internal controls and the regulatory requirements.

The Group Trustees also have a working knowledge of all trustee policies in place and of the

Scheme’s trust deed and rules.

Utilising Advisors

The Group Trustees believe that the best run Schemes utilise the combined skill and knowledge of both the Trustees and their professional advisors. The relevant skills and experience of those advisors are key criteria when evaluating advisor performance and selecting new advisors. Additionally, the following measures have applied during the period:

- The Group Trustees’ professional advisors attend their formal meetings; - The Group Trustees have wide ranging skills and experience, including pension

experience; and - The Group Trustees receive briefings from their advisors on all legislative and

regulatory developments at each meeting.

Assessing Effectiveness

The Group Trustees understand that having knowledge and professional advice available needs to be used effectively in order for the Trustees to act properly. The Trustees will review and assess, on an ongoing basis, whether the systems, processes and controls across key governance areas are consistent with those set out in the Pensions Regulator’s Code of Practice 13.

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I confirm that the above Statement has been produced by the Group Trustees to the best of

their knowledge.

Signature: ___________________________________

Name: ___________________________________

Position: ______Chair of Trustee________________

Date: ___________________________________

Appendix

Appendix A – Transaction Cost Information

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Appendix A – Transaction Costs

Aggregate transaction costs The next table shows the aggregate transaction costs based upon the information supplied by Aegon. Aggregate transaction costs represent annualised transaction costs incurred by the fund manager within the underlying fund. Figures do not currently contain impacts of dilution adjustments incurred at the Aegon fund level when Aegon deals in the underlying funds.

Fund Name Transaction Costs % p.a.*

Aegon BlackRock 50/50 Global Equity Index 0.01

Aegon BlackRock Cash 0.02

Aegon BlackRock Corp Bond All-Stocks Index 0.13

Aegon BlackRock Over 15 Years Gilt Index 0.00

Aegon BlackRock Over 5 Year Index Linked Gilt Index 0.02

Aegon BlackRock Pre-Retirement 0.01

WPD Diversified Growth 0.47

WPD Global Equity - Source: Aegon, as at 31 March 2019. *Aegon were unable to provide transaction cost information for the WPD Global Equity Fund at the time of writing. We will continue to request the missing data quarterly, until received.

Additional Voluntary Contributions (AVCs): Transaction Costs and member charges

Prudential

Fund AMC (% p.a.)

Prudential Deposit -

Prudential Discretionary 0.75

Prudential With Profits -

Source: Prudential as at 31 March 2019.

Prudential were unable to provide transaction cost information for the reporting period at

the time of writing. Transaction cost information from the year to 31 March 2019 will be

available October 2019. Looking ahead, Prudential expect to be able to refresh transaction

cost data at the start of each quarter, reporting on the most recently available information.

Aviva

Aviva were unable to provide transaction cost and member charge information for the

reporting period at the time of writing. We will continue to request the missing data

quarterly, until received.

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Equitable Life

Equitable Life were unable to provide transaction cost and member charge information for

the reporting period at the time of writing. We will continue to request the missing data

quarterly, until received.

Standard Life

Fund TER (% p.a.)*

Standard Life Pension Millennium With Profits Fund -

Standard Life Pension With Profits Fund -

Standard Life UK Equity Select Pension Fund 1.01

Standard Life iShares UK Equity Index Pension Fund 0.62

Standard Life Global Equity Unconstrained Pension Fund 1.12

Standard Life Far East Equity Pension Fund 0.70

Standard Life North American Equity Pension Fund 0.61

Standard Life Aberdeen Life Sterling Credit Bond Pension Fund

1.03

Standard Life Money Market Pension Fund 0.61

Standard Life Stock Exchange Pension Fund 0.63

Standard Life Deposit and Treasury Pension Fund 0.61

Standard Life Global Absolute Return Strategies Pension 1.11

Standard Life Corporate Bond Pension Fund 0.62

Standard Life Managed Pension Fund 0.62

Source: Standard Life as at 31 March 2019. *Members of the scheme benefit from discounts of 0.4% to the standard charges, the table above incorporates these discounts. Standard Life were unable to provide transaction cost and member charge information for

the reporting period at the time of writing. We will continue to request the missing data

quarterly, until received.