Pension Fund
Investment Strategy Statement
31 March 2019
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1 Introduction
The Local Government Pension Scheme (Management and Investment of Funds)
Regulations 2016 (‘the 2016 Investment Regulations’) require administering authorities to
formulate and to publish a statement of its investment strategy, in accordance with
guidance issued from time to time by the Secretary of State.
This Investment Strategy Statement (ISS) has been designed to be a living document and
is an important governance tool for the Durham County Council Pension Fund (‘the Pension
Fund’). This document sets out the investment strategy of the Pension Fund, provides
transparency in relation to how the Pension Fund investments are managed, acts as a risk
register, and has been kept as short in order to be read in as user-friendly manner as is
possible. This document replaces the Pension Fund’s Statement of Investment Principles.
This statement will be consulted on at least every three years and reviewed by the
Pension Fund Committee (‘the Committee’) more frequently should any significant change
occur.
2 Investment Responsibilities
The County Council, as Administering Authority for the Pension Fund, has delegated the
investment arrangements of the Pension Fund to the Pension Fund Committee (the
“Committee”) who decide on the investment policy most suitable to meet the liabilities of
the Pension Fund and the ultimate responsibility for the investment policy lies with it. The
Committee is made up of elected representatives of the County Council, Darlington
Borough Council, Further Education Colleges, Other Statutory Bodies, Admitted Bodies
and Member Representatives.
The Committee has full delegated authority to make investment decisions.
2.1 The Pension Fund Committee has responsibility for:
•
Determining overall investment strategy and strategic asset allocation and ensuring
that investments are sufficiently diversified, are not over concentrated in any one type
of investment, and that the Pension Fund is invested in suitable types of investments;
•
Preparing policy documents including the ISS and Funding Strategy Statement (FSS).
Monitoring compliance with the ISS and reviewing its contents following any strategic
changes and at least every three years;
•
Appointing the investment managers, and custodian until such time as all of the Fund’s
assets are transitioned to Border to Coast Pension Partnership Limited (BCPP);
•
Appointing the Pension Fund actuary and any independent external advisers felt to be
necessary for the good stewardship of the Pension Fund;
•
Reviewing on a regular basis the investment managers’ performance against
established benchmarks, and satisfying themselves as to the investment managers’
expertise and the quality of their internal systems and controls;
•
Reviewing on a regular basis the performance of the independent external advisers;
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•
In cases of unsatisfactory performance of the investment managers and independent
external advisers, taking appropriate action;
•
Reviewing policy on social, environmental and ethical matters and on the exercise of
rights, including voting rights; and
•
Reviewing the funds allocated to investment managers on a regular basis to ensure
that the strategic asset allocation is maintained (rebalancing).
2.2 The investment managers are responsible for:
•
The investment of the Pension Fund assets in respect of which they are appointed in
compliance with applicable rules and legislation, the constraints imposed by this
document and the detailed Investment Management Agreement covering their portion
of the Pension Fund’s assets;
•
Stock selection within asset classes;
•
Preparation of quarterly reports, including a review of investment performance;
•
Attending meetings of the Committee as requested;
•
Where specifically instructed, voting in accordance with the Pension Fund’s policy.
2.3 The Global Custodian is responsible for:
•
Its own compliance with prevailing legislation;
•
Providing the administering authority with quarterly valuations of the Pension Fund’s
assets and details of all transactions during the quarter;
•
Collection of income, tax reclaims, exercising corporate administration and cash
management;
•
Such other services as the Pension Fund shall procure, for example, in connection
with performance measurement and reporting or fund accounting.
2.4 The Investment Advisers are responsible for:
•
Assisting the Corporate Director Resources and the Committee in determining the
overall investment strategy, the strategic asset allocation and that the Pension Fund is
invested in suitable types of investment, and ensuring that investments are sufficiently
diversified.
•
Assisting the Corporate Director Resources and the Committee in the preparation and
review of Policy documents;
•
Assisting the Corporate Director Resources and the Committee in their regular
monitoring of the investment managers’ performance;
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•
Assisting the Corporate Director Resources and the Committee, where required, in the
selection and appointment of investment managers, custodians and Pension Fund
Actuary;
•
Advising and assisting the Corporate Director Resources and the Committee on other
investment related issues, which may arise from time to time; and
•
Providing continuing education and training to the Committee.
2.5 The Actuary is responsible for:
•
Providing advice as to the structure of the Pension Fund’s liabilities, the maturity of the
Pension Fund and its funding level in order to aid the Committee in balancing the short
term and long-term objectives of the Pension Fund.
•
Carrying out its responsibilities as set out in the FSS.
•
Undertaking the statutory triennial valuation of the Pension Fund’s assets and
liabilities.
2.6 The Corporate Director Resources is responsible for:
•
Ensuring compliance with this document and bringing breaches thereof to the attention
of the Committee;
•
Ensuring that this document is regularly reviewed and updated in accordance with the
2016 Investment Regulations;
•
Exercising delegated powers granted by the County Council to:
o Administer the financial affairs in relation to the County Council’s functions as a
pension fund administering authority;
o Exercise those discretions under the Local Government Pension Scheme
Regulations 2013 as appear from time to time in Pension Fund Statements of
Policy; and
o Authorise, in cases of urgency, the taking of any action by an investment manager
of the Pension Fund which is necessary to protect the interests of the Pension
Fund.
•
Managing the cash balances of the Pension Fund which the Investment Managers
have not invested
3 Investment Beliefs and Objectives
The Pension Fund has the following investment beliefs which help to inform the investment
strategy derived from the decision making process:
•
Funding, investment strategy and contribution rates are linked
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•
The strategic asset allocation is the key factor in determining the risk and return
profile of the Pension Fund’s investments
•
Investing over the long term provides opportunities to improve returns
•
Diversification across asset classes can help to mitigate against adverse market
conditions and assist the Pension Fund to produce a smoother return profile due to
returns coming from a range of different sources
•
Managing risk is a multi-dimensional and complex task but the overriding principle is
to avoid taking more risk than is necessary to achieve the Pension Fund’s objectives
•
Environmental, Social and Governance are important factors for the sustainability of
investment returns over the long term
•
Value for money from investments is important, not just absolute costs.
•
Asset pooling will help reduce costs whilst providing more choice of investments and
will therefore be additive to Pension Fund returns
•
High conviction active management can add value to returns
The Administering Authority's primary aim is long-term solvency. Accordingly, employers’
contributions will be set to ensure that 100% of the liabilities can be met over the long
term. The Solvency Target is the amount of assets which the Fund requires to hold to
meet its objective of paying all benefits arising as they fall due.
3.1 Investment strategy and the process for ensuring suitability of investments.
The Pension Fund’s objective is to pay benefits as they fall due. The Pension Fund is
currently assessed to have a deficit in respect to previously accrued liabilities, and so the
strategy is focused on recovering this deficit as well as maintaining affordable contributions
for future benefit accrual, without taking undue risks. Having a thorough understanding of
the risks facing the Pension Fund is crucial and these are covered later in the statement.
The Pension Fund’s asset strategy, along with an overview of the role each asset plays is
set out in the table below:
Allocation
Benchmark &
Asset class
Role (s) within the strategy
%
Performance Target
Global
MSCI All Country World
40.0
Equities
Index +2%
Long term growth in excess of
inflation expected; Generate
Emerging
MSCI Emerging
investment income i.e.
Market
7.0
Markets Net Index
dividends.
Equities
+2.5%
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Allocation
Benchmark &
Asset class
Role (s) within the strategy
%
Performance Target
FTSE Over 5 Year
Provide protection from
Index Linked
Index-Linked Gilt Index
changes in inflation both in
20.0
Gilts
+0.5%
terms of capital value and
income
UK 3-month LIBOR
Diversified source of income
+3.0%
and provides a degree of
Global Bonds
15.0
protection from changes in
interest rates. Some growth
above gilts expected
Dynamic Asset
UK 3-month LIBOR
Diversification and Tactical
0.0
Allocation
+3.0%
Asset Allocation
UK Retail Price Inflation Diversification; Generate
Global
+5.0%
investment income; Provide
8.0
Property
some inflation-sensitive
exposure; Illiquidity premium
tbc
Long term growth in excess of
Private
inflation expected;
10.0
Markets
Diversification; Illiquidity
premium
The Committee is responsible for the Pension Fund’s asset allocation which is determined
via a triennial strategy review as part of the valuation process. The review is both qualitative
and quantitative and is undertaken by the Committee in conjunction with the actuary, officers
and investment adviser. The review considers:
• The required level of return that will mean the Pension Fund can meet its future
benefit obligations as they fall due
• The level of risk that the Pension Fund can tolerate in absolute terms, and in
relation to its funding level and deficit
• An analysis of the order of magnitude of the various risks facing the Pension Fund
is established in order that a priority order for mitigation can be determined
• The desire for diversification across asset class, region, sector, and type of security.
4 Risk measurement and management
The Committee assesses risks both qualitatively and quantitatively, with the starting point being the
triennial strategy review. Risks are considered, understood and then prioritised accordingly.
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(a) Investment risks
The Committee uses Risk Attribution Analysis to determine the order of magnitude of the
main investment risks the Pension Fund is facing. The chart below shows the VaR (Value
at Risk, essentially the minimum losses that would occur in a 1-in-20 event) facing the
Pension Fund, split into major risk categories.
As an additional illustration of risk, the table below shows how a range of events (in isolation)
could impact the Pension Fund:
Event
Event movement
Estimated Impact on
Deficit
Fall in equity markets
30% fall in equities
£395m
Rise in Inflation
0.5%
increase
in £250m
inflation
Fall in discount rate
0.5% fall in the discount £296m
rate
Active Manager underperformance 3% underperformance
£84m
from all active
managers
As shown in both the Value-at-Risk attribution chart and the table above, the most significant
risk that the Pension Fund is running is in relation to equities. Whilst not immaterial the risks
being run by the use of active management is far smaller.
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Equities
The largest risk that the Pension Fund is running is in relation to its equity holdings.
Should equity market conditions deteriorate significantly this will have a negative
impact on the funding level. The Pension Fund holds equities in order to provide the
necessary returns to ensure that the Pension Fund remains affordable. The
Committee believes that the extra returns that are expected to be generated by
equities compensates the level of risk equities bring to the Pension Fund, but does
believe in diversification, and looks to mitigate equity risk by investing significantly in
bonds and alternatives. The Pension Fund is a long term investor but does require
income over and above contributions received in order to pay pensions.
Inflation
Another significant risk that the Fund faces is in relation to inflation.The Pension
Fund’s liabilities are impacted by inflation both explicitly and implicitly. The Pension
Fund will seek to invest in a range of assets that provide returns in excess of inflation
and in some cases provide an inflation linked income, subject to a tolerable level of
volatility.
Alternatives
The Pension Fund has a significant amount of assets allocated to a range of
alternatives; previously via a dynamic asset allocation fund, but also through property.
Going forward, the Fund will have a strategic allocation to Private Markets. The level
of diversification these assets provide helps to reduce the Funds reliance on returns
from equities. Illiquid assets such as property can also be a valuable source of
income.
Active Manager Risk
Investment Managers are appointed to manage the Pension Fund’s investments on
its behalf, until such time as all of the Fund’s assets are transitioned to BCPP. This
risk is small relative to other risks; however the Pension Fund still addresses this
risk. Extensive due diligence is used before managers are selected, with a number
of different managers chosen to prevent concentration risk The investment
managers are also monitored regularly by the Committee, Officers and by the
Pension Fund’s investment adviser.
The Pension Fund’s portfolio is well diversified across asset classes, geography and asset
managers. As different asset classes have varying correlations with other asset classes, the
Pension Fund by investing in a range of different investments can minimise the level of risk
run to a degree.
(b) Demographic Risks
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The Pension Fund is subject to a range of demographic risks, but with particular reference
to investment strategy, the Committee is aware of the potential for the Pension Fund to
mature over time as the pensioner liability increases. A mature pension fund is likely to take
less investment risk over time and this is considered at each strategy review. The more
mature a pension fund, the more likely it is that disinvestments would need to be made to
pay benefits. The Pension Fund is not in that situation at present as income from
contributions and investments are greater than benefit payments. However, this situation is
monitored regularly and formally as part of the actuarial valuation and strategy review.
(c) Cashflow Management Risks
The Pension Fund is becoming more mature and although it is cashflow positive after taking
investment income into account, managing cashflow will become an increasingly important
consideration in agreeing the investment strategy. Should this position change and cash
outflows exceed cash inflows, mitigating actions would be taken such as investing in assets
which produce cashflows.
(d) Governance Risks
The Pension Fund believes that there is a benefit to the Pension Fund to be gained from
good governance in the form of either or both of an increased return and/or decreased
risk. Poor governance could lead to opportunities and risks being missed, and have a
detrimental effect on the funding level and deficit.
(e) Environmental, Social and Governance (‘ESG’) Risks
The Committee believes that ESG risks should be taken into account on an ongoing basis
and are an integral part of the Pension Fund’s strategy and objective of being a long term
investor.
The Committee believes that engagement is key in relation to strong corporate
governance, which in turn will enhance returns. Details of the Pension Fund’s policies can
be found later in this statement.
5 Approach to asset pooling
In order to satisfy the requirements of the Local Government Pension Scheme: Investment
Reform and Guidance issued by the Department for Communities and Local Government
(DCLG) in November 2015, the Administering Authority has elected to become a
shareholder in BCPP Limited. BCPP was created in 2017 as a wholly owned private limited
company registered in England and Wales, authorised and regulated by the Financial
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Conduct Authority (FCA) as an alternative investment fund manager (AIFM). BCPP has 12
equal shareholders who are the administering bodies of the following 12 Funds:
•
Bedfordshire Pension Fund
•
Cumbria Pension Fund
•
Durham Pension Fund
•
East Riding Pension Fund
•
Lincolnshire Pension Fund
•
North Yorkshire Pension Fund
•
Northumberland Pension Fund
•
South Yorkshire Pension Fund
•
South Yorkshire Passenger Transport Pension Fund
•
Surrey Pension Fund
•
Teesside Pension Fund
•
Tyne and Wear Pension Fund
•
Warwickshire Pension Fund
The partner Funds submitted their proposal to Government on 15th July 2016 and have
received written confirmation from the Secretary of State to confirm that the proposal meets
the criteria laid down in the guidance issued in November 2015 and set out below:
a)
Asset pool(s) that achieve the benefits of scale;
b)
Strong governance and decision making;
c)
Reduced costs and excellent value for money; and
d)
An improved capacity to invest in infrastructure.
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5.1 Assets to be invested in BCPP Ltd
The Pension Fund’s intention is to invest its assets via BCPP Ltd as and when suitable sub-
funds become available. An indicative timetable for participating administering authorities to
invest through BCPP Ltd was set out in the July 2016 submission to Government.
The key criteria for the Pension Fund’s assessment of a BCPP Ltd sub-funds will be as
follows:
• that the sub-fund enables access to an appropriate investment that meets the objectives
and benchmark criteria set by the Pension Fund; and
• that there is financial benefit to the Pension Fund in investing in the sub-fund offered by
BCPP Ltd.
The Fund’s intention is to invest its assets through the BCPP pool as and when suitable
investment solutions become available. At the time of preparing this statement, the Fund is
planning to transition the first of its assets to BCPP. The first transition will be the Fund’s
investments in Global Equities. The Fund has also committed to develop a Private Market
portfolio through BCPP. As the detailed parameters and objectives of BCPP sub funds are
finalised, the Fund plans to transition further assets in line with the key criteria above.
Any assets not invested in BCPP Ltd will be reviewed at least every three years to determine
whether the rationale remains appropriate, and whether it continues to demonstrate value
for money. The next such review will take place no later than 2020.
The Pension Fund will retain the decision making powers regarding asset allocation and will
delegate the investment management function to BCPP Limited.
5.2 Structure and governance of BCPP Ltd
The 12 Partner Funds and BCPP work collaboratively to build the investment capabilities
required to ensure that the Partner Funds are able to efficiently and effectively deliver their
Strategic Asset Allocations in line with the following guiding principles:
• Meeting central Government’s aims for governance, responsible investing,
infrastructure and value for money
• One fund, one vote
• Funds retaining governance role and ownership of asset allocation
• Generating improved net-of-fees risk adjusted performance
• Border to Coast internal management capability
• Improved resilience and capacity over existing structures
• A shared team in one location
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In order to hold BCPP to account, and to meet FCA requirements for a regulated asset
manager, the Partner Funds stand at arms-length to Border to Coast during implementation
and ongoing management of the sub-funds. The investment performance and capability of
BCPP is overseen on a day to day basis by senior officers at each partner fund, and more
formally on a quarterly basis by the Joint Committee, which is constituted of elected
members from each partner fund. BCPP’s performance as a company is overseen by
shareholder representatives from the twelve administering authorities both on an ongoing
basis and formally once a year at its AGM
The governance structure of BCPP is as follows:
The following groups support the governance of BCPP:
•
Joint Committee – the Joint Committee is constituted from the 12 Pension Fund
Chairs and will meet quarterly now that BCPP is established and functioning. It is
the collaborative vehicle through which the individual Partner Funds provide
collective oversight of the performance and direction of BCPP. Its remit includes
oversight of progress towards the pooling of Partner Fund assets as a whole.
•
Officer Groups - The Joint Committee is supported by the respective Authority
s151 and Monitoring Officers and the Officer Operations Group (OOG), constituted
from the 12 Senior Pension Fund Officers. These groups meet to discuss issues
and give input to both Elected Members and BCPP as required. It is anticipated that
the OOG will meet monthly, part of the meeting being attended by Border to Coast,
part in closed session. The OOG work collaboratively together to ensure that due
diligence over BCPP investment capabilities is carried out effectively on behalf of
the Pension Committees.
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•
Local Pension Boards - In line with their role in other administrative and
governance matters, the local pension boards provide support and challenge to the
Pension Committee’s decisions and decision-making process in relevant investment
areas, and look to ensure appropriate governance is in place to provide effective
monitoring.
•
Advisers - Regulations require that Pension Funds take professional advice in
respect of any investment decisions, and this is generally provided through Funds
appointing Independent Investment Advisors and/or Investment Consultants. They
will work with the Pension Committee and Officers to ensure that the strategic asset
allocation can be effectively implemented through the use of the sub-funds available
at BCPP.
6 Environmental, Social and Corporate Governance policy and policy of the
exercise of rights (including voting rights) attaching to investments
The Committee must act with the best financial interests of the beneficiaries, present and
future, in mind. The Committee believes that companies should be aware of the potential
risks associated with adopting practices that are socially, environmentally or ethically
unacceptable. As part of the investment decision-making process, Investment Managers are
required to consider such practices and assess the extent to which this will detract from
company performance and returns to shareholders.
Investment Managers are required to exercise voting rights on behalf of the Pension Fund
when it is in the best interests of the Pension Fund. The quarterly report from investment
managers should include details of voting activity.
The Pension Fund has never sought to implement a policy that explicitly excludes certain
types of investments, companies or sectors except where they are barred by UK law. The
Pension Fund believes that its influence as a shareholder is better deployed by engaging
with companies, in order to influence behaviour and enhance shareholder value. The
Pension Fund believes that this influence would be lost through a divestment or screening
approach. The Pension Fund actively engages with companies through its investment
managers.
Ultimately the Pension Fund will always retain the right to disinvest, where it is possible to
do so, from certain companies or sectors in the event that all other approaches are
unsuccessful and it is determined that the investment is no longer aligned with the interests
of the Pension Fund or that the issue poses a material financial risk.
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6.1 Myners Principles
Although not specifically referenced in the Regulations, the Committee feels that
assessment of compliance with the Myners Principles is a valuable governance tool. A copy
of the Pension Fund’s
Myners Compliance Statement can be found in Appendix 1.
7 Responsible Investing with BCPP
The purpose of BCPP is to make a difference to the investment outcomes for partner funds
through pooling, by creating a stronger voice and investing responsibly now and into the
future to enable sustainable performance. The LGPS (Management and Investment of
Funds) 2016 regulations state that the responsibility for stewardship, which includes
shareholder voting, remains with individual Funds. Stewardship, day-to-day administration
and implementation is delegated by the Fund to BCPP for any assets managed by Border
to Coast, with appropriate monitoring and challenge to ensure this continues to be in line
with the Fund’s requirements.
To leverage scale and for operational purposes, BCPP has, in conjunction with partner
funds, developed a Responsible Investment Policy and accompanying Corporate
Governance & Voting Guidelines to ensure clarity of approach on behalf of partner funds.
The Pension Fund Committee and the committees of all 11 other partners in BCPP agreed
to adopt BCPP’s Responsible Investment (RI) Policy into their ISS. The policy is monitored
with regular reports to BCPP’s Chief Investment Officer (CIO), Investment Committee,
Board, Joint Committee and partner funds. It is reviewed at least annually, or whenever
revisions are proposed and updated as necessary.
BCPP believes that businesses that are governed well and run in a sustainable way are
more resilient, able to survive shocks and have the potential to provide better financial
returns for investors. ESG issues can have a material impact on the value of financial assets
and on the long-term performance of investments, and therefore need to be considered
across all asset classes in order to better manage risk and generate sustainable, long term
returns. Well-managed companies with strong governance are more likely to be successful
long-term investments.
BCPP is an active owner and steward of its investments, both internally and externally
managed, across all asset classes. The commitment to RI is communicated in BCPP’s UK
Stewardship Code compliance statement. As a long-term investor and representative of
asset owners, BCPP will therefore, hold companies and asset managers to account
regarding ESG factors that have the potential to impact corporate value. BCPP will
incorporate such factors into investment analysis and decision making, enabling long-term
sustainable investment performance for partner funds. As a shareowner, BCPP has a
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responsibility for effective stewardship of the companies it invests in, whether directly or
indirectly through mandates with fund managers. It will practice active ownership through
voting, monitoring companies, engagement and litigation.
BCPP’s full approach to sustainability, including Voting and Engagement, Responsible
Investment Policies, Collaborations, and Corporate Policies can be found online at
https://www.bordertocoast.org.uk/sustainability/.
8 Advice Taken
In creating this statement, the Pension Fund has taken advice from its Investment Adviser.
Also, in relation to each of the constituent parts, such as the asset allocation and risk
mitigation, the Pension Fund has taken advice from its Investment Adviser, Mercer, and the
Scheme Actuary, Aon Hewitt. In providing investment advice, Mercer is regulated by the
Financial Conduct Authority.
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Appendix 1 – Myners Principles
This appendix sets out the extent to which Durham County Council as the Administering
Authority of the Durham County Council Pension Fund complies with the six principles of
investment practice set out in the document published in November 2012 by CIPFA, the
Chartered Institute of Public Finance and Accountancy, and called "Principles for
Investment Decision Making and Disclosure in the Local Government Pension Scheme in
the United Kingdom 2012”, in future, compliance with guidance given by the Secretary of
State will be reported.
Principle 1 —Effective decision-making
Fully compliant: Investment decisions are made by those with the skill, information and
resources necessary to take them effectively. A programme covering investment issues is
being developed for new members joining the Committee and training is provided to all
members.
Principle 2 –Clear objectives
Fully compliant: The overall investment objective for the Pension Fund is set out in the
Funding Strategy Statement.
Principle 3 –Risk and Liabilities
Fully compliant: The overall investment objective is considered by the Pension Fund. The
risks associated with the major asset classes in which the Pension Fund’s assets are
invested is regularly considered. A risk register has been completed for the Pension Fund
and reports from Internal and External Audit are considered by the Committee.
Principle 4 –Performance Assessment
Partial compliance: Appropriate benchmarks have been set in consultation with the
investment adviser and the actuary. Benchmarks are considered regularly as part of the
review of the Strategic Asset Allocation. Performance against benchmarks is considered
quarterly at the Committee. Investment Managers’ performance is measured quarterly.
Separate monitoring of Committee performance and investment adviser performance has
yet to be established.
Principle 5 –Responsible Ownership
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Partial compliance: The Pension Fund’s policy for socially responsible investing is set out
in the Statement of Investment Principles and (from April 2017) the Investment Strategy
Statement. Explicit written mandates agreed with all investment managers. Investment
Managers are required to exercise voting rights on behalf of the Pension Fund when it is in
the best interests of the Pension Fund. Normal practice is to allow the Investment
Managers to follow their in-house voting policy unless otherwise instructed by the
Committee. The mandates do not specifically incorporate the principle of the US
Department of Labor Interpretative Bulletin on activism.
Principle 6 –Transparency and Reporting
Fully compliant: The Committee acts in a transparent manner, communicating with its
stakeholders on issues relating to their management of investment, its governance and
risks, including performance against stated objectives through the publication of
Committee reports and Minutes on the County Council website. The Funding Strategy
Statement and the Statement of Investment Principles are also available on the internet
and are included in the Pension Fund’s Annual Report and Accounts. The Annual Report
and Accounts includes the statutory documents that the Pension Fund is required to
provide.
The Pension Fund provides regular communication to scheme members in a Newsletter and
Annual Statements which are considered the most appropriate form.
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