Local Pension Board - Monday 4 November 2024, 11:30am - Wandsworth Council Webcasting

Local Pension Board
Monday, 4th November 2024 at 11:30am 

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Well, Marianna's doing that, colleagues, just so that everybody knows that this is being webcast. So I'm sure everybody I can see on the screen is polite and respectful at all times during our meetings anyway, but just to make sure we treat it as if we were all present and getting on famously together.
so language and phraseology you might not want others to see or hear of is overly controversial
if we can avoid all that that will be very good thank you. Okay Chuck I can confirm we're now
live you may begin the meeting. Lovely thanks Marianna and thanks everybody to this meeting
or pretending this meeting of the local pension board on Monday 4th of November and as we all know
this is being run as a virtual meeting so we're all in our various offices, homes, holidays abroad,
whatever locations where people are at. Welcome to this particular meeting. A particular welcome
for Paul Giannotti who's joining us today, observing really but contributing largely under
item five. So thank you for that Paul and you're welcome obviously to be present for the whole
meeting so thank you for joining us. Thanks everybody else for attending today and please
as usual do feel free to contribute. It's always good that with the board members particularly
chip in on various bits to make sure that anything we're unclear about we ask for explanation on
or anything that we don't think is quite right.
Might be asking a few probing questions on that.
That is our role to see that everything
is being done appropriately.
And we're in the fortunate position
that the vast majority of the time
that is very much the case.
So long may that continue.
First things first, declarations of interest.
So I take it no, there are no other declarations
beyond which the weave or previously declared
in terms of the various acts that we have and the various roles that we play.
And I, having scanned the agenda, believe that that should be fine for this particular meeting,
but if anybody feels that there are items that we'll be discussing today where there are interests that need to be declared,
please do say so now.
And welcome Chris, nice to see you, I hear you when you're there, thank you.
So no declarations, fine.
Before the training item today, let's just go through the minutes from the last meeting.
Anybody have any comments, points of inaccuracy or anything that's on those that won't be coming up elsewhere on the agenda today?
The only thing I can see that isn't particularly an agenda item is where there's the reference to the register of interests.
I know the intention was to bring that to the board for this particular meeting.
Coral, did you want to add anything on that?
I'll just say thank you very much to everyone who has actually confirmed in writing that they have no interest.
We are unfortunately awaiting one response here.
So I am happy to follow up again with the board member we're waiting for, but I cannot present a complete register at this moment until I have that response unfortunately.
Okay, yeah if you could follow that up again that would be great. Perhaps give a deadline
at the end of the week? Certainly. Say we've noted it at the meeting and
hopefully we'll get that response through and then we can add it in next time.
All right thanks for that and any other items on the minutes from last time round?
Okay, so we can move straight into item three, which is training on the discretion's policy.
Is that you leading that, Martin?
Yes, that's right, Chair.
I shall lead on that.
Over to you.
Thank you.
We have got elsewhere on the agenda the revised discussions which were approved at the Joint
Pensions Committee in October.
The revision was really substantively just for job title changes, so it wasn't a big
change in October, but we felt it was a useful prompt to look at
discretions and there are administering authority, the
pension fund discretions, the administering authority for ones with
pension funders, ones with council and there are also scheme employer
discretion. So, one's with council as a partner in the Better Service Partnership is also an employer
in the fund. So, two separate sets of discretion policies that the council needs to have.
So we do have a national pension scheme, the LGPS, with regulations approved by Parliament.
But within the structure of the scheme, there are discussions for employers and pension
funds on how it applies the scheme in certain situations when certain events happen, usually
around retirement, the payment of benefits. The scheme does allow some discretion.
And when we talk about those discussions, it's not only the current employees that the
discussions apply to, it's also previous employees when they ask the pension fund or
their former employer for a decision, the discretion policies still apply.
So the both fund and scheme employers have to have a written statement on how
they will exercise their discretions and that's part of the LGPS regulations 2013.
And there is a general requirement that both the pension fund and employers will act with
prudence and proprietary in making their decisions.
And the LGPS legislation mentions that when devising a policy, both the fund and the employers
have to have regard that the policy that they're setting doesn't amount to a loss of
public confidence and there's also requirement that they keep their policies
under review so if there are any material changes that they will review
and change the policies. So as I say both the Monty Council's pension fund and
as an employer reviewed their policies
and got those changes approved by the JPC in October 2024.
So there are things to consider when devising a policy.
In general, in public law,
all public bodies have to follow
what was initially called the Wensbury Principles,
back from a court case in 1947,
where the public bodies, when exercising decision -making,
have to make sure they have that power in law,
and then when they're exercising that power,
have to just consider the relevant factors
and exclude any non -relevant factors
while making their decision,
and then they are free to exercise their discretion. But there is a process and it
has to be a transparent process that is followed so it's not challenged.
And we're making our discretion's policies. We have to bear in mind that it can't be discriminatory.
So setting a age -related criteria, say over 55s can get extra extra years or
something that's only relevant to a certain age group or perhaps an indirect
sex discrimination if you're talking about a service that has a quite balanced
gender in one direction. If you're thinking about a policy that will only
affect certain people or certain services, it may be indirectly a sexual
discrimination case. But also look to avoid fettering the discretion. So we
shouldn't be saying in any discretion that in no circumstances will this
exercise be this discretion be exercised because that no longer becomes a
discretion that is a a uniform statement that the discretion will never be used.
And also avoid being overly prescriptive. You want to leave the opportunity to
exercise discretions differently in a range of situations. So don't make the
discretion too narrow. Try and make it so that the decision maker can look at a
of evidence before making the decision.
And there are a lot of interests to balance
when making a decision.
We've got the funds interests,
individual employer financial interests,
which may be backed up by the taxpayer.
Also, we've got the interests of the member
that we have to bear in mind.
And whether that decision is going to have an impact
on the administration of the scheme? Will it cause a lot of administration issues?
And finally, the process, when we're making a discretion, we should look at the likelihood
of complaints and appeals, because there's something in the discretion's policy that
may be looked at as unfair and will it right at the outset, you think this will eventually lead to complaints and appeals.
So those are the kind of factors that are looked at when devising a discretion's policy and when revising it as well, based on the previous experience moving forward.
So as I said at the start, there's the pension fund have their set of
discretions and the scheme employers have their set of discretions and
just looking at some of the key discretions that the pension fund the
administering authority has. Firstly whether or not to abate pensions upon
local government re -employment. And this was a policy for the Wandsworth Fund right up
to 2016 so that if a pensioner, Wandsworth pensioner re -entered local government there'd
be an earnings test on their pension in payment. If the new salary was high enough in the new
employment, it would trigger an abatement, a reduction or restriction in the pension
that was being paid. This was found to be quite prohibitive for trying to re -recruit
pensioners into the workplace and it was stopped in 2016. So from 2016 the pension fund does
not abate or restrict pensions for ones of pensioners re -entering local government employment.
Other key discussions that the council has, well it can refuse transfers into the pension fund,
so not from another local government scheme or another public big public sector scheme,
but for private pensions, the Executive Director of Finance can refuse pensions coming in if it's felt that the transfer value doesn't cover all the resulting liabilities from that inward transfer of pension rights.
And the third pension fund discretion to highlight is that the pension fund can issue an employer with a notice to recover additional admin costs incurred as a result of that employer's level of performance.
and since we've used our pensions admin strategy,
we have been charging employers
where their level of performance and producing data
has been poor and poor quality data has come in.
We have started charging employers
for the additional admin costs of processing data
when we have to go backwards and forwards
to get clean data and timely data.
So the head of the pension share service
can now issue those requests for additional costs from employers.
Do give me any questions or comments as we go along.
So those are the key pension fund discussions
and there's also, as I said, employer discussions
in the regulations. And we do say to employers don't just follow the main
employer, in this case ones with councils set of discretion policies, because the
big employers, the councils, have a different membership base and funding
levels to other employers. So we do look for individual scheme employers to
to devise their own discretion's policy.
The maintained schools will largely follow
the main council discretion's policy.
So scheme employers would be non -maintained schools,
academies, and things like charities, housing associations,
other bodies in the pension fund.
In all, throughout the regulations, covering all previous levers and covering compensation
payments on redundancy and injury allowances as well as the main LGPS discretions, there
are 87 potential decisions that employers have to make.
where the regulations say an employer may do this,
or may do that in the circumstances.
So across all the regulations,
there's about 87 times where there's some flexibility
for an employer to make a decision
on how the employer applies the regulations.
But there are only five mandatory discretions,
and we've had that since April 2014,
where each employer must have a policy on five key discretions how it will
apply the regulations in five distinct cases and the first is whether to award
additional pension so at a cost of the employer will they will employees be
awarded additional pension that can go up to about £8 ,300 per year annual pension that can be awarded to
an employee.
Looking at the councils, one of the councils
discretion policy as part of the
partnership with Richmond
it will only award additional pension if it's in the councils
financial and or operational interests.
So financial and operational interest is quite a wide category that it would make
a business case to make that offer to an employee and it can be something
like if a key employee decides to stay on to complete a particular project, that could
be an instance where it would be in the financial and or operational interest to award additional
pension.
And secondly, whether to contribute to the cost of purchasing additional pension.
similar policy but this is through a shared cost additional pension contribution.
And in those circumstances the council's policy is only to allow in exceptional circumstances.
So again that can be different circumstances but it would have to be quite a compelling case to
to give a reason to do that.
Whether to allow flexible retirement for staff age 55 or over,
who with the agreement of their employer reduces
their working hours or grade.
So flexible retirement is a phased retirement
where a member of staff continues to work for their employer
but at that point receives their pension.
All other types of retirement,
you have to leave your employment
to receive your pension benefits,
but flexible retirement is where you can carry on working
in a position of a lower grade or lower, fewer hours,
and receive your pension.
But again, the councils would only allow it
if it's in its financial and or operational interest
So a business case looking at the effect on the service if the member was allowed to flexibly retire.
And the next discretion for all employers is whether to waive all or part of any actuarial reduction where a member takes their pension benefits before their normal pension age, before their state pension age.
So they would normally voluntarily retire and it's before their normal pension age.
So the council as an employer does have the option to waive all or part of those reductions that would otherwise apply.
But there would be an upfront cost to the council.
So the question criteria for release would be, would it be in the council's financial and or operational interest to allow that, to pay for that reduction to be waived?
And the final mandatory discretion for all employers is whether to switch on the 85 year
rule for a member voluntarily drawing their benefits on or after the age of 55 and before
60. The 85 year rule applies automatically at age 60 but the council does have an option
to apply it before the age of 60.
But again, the Council will only exercise that option
if it's in its financial and or operational interests.
Just an explanation, some of you may not be aware of the 85 -year rule
So just to recap what the 85 -year rule is,
in some ways it's becoming less relevant
because anybody who joined the councils
or the pension scheme from October,
1st of October 2006, it no longer applies.
So if they were to retire, they would have their –
if they're below their normal pension age,
the full reductions will apply
there's no protection from those reductions. But if they join the scheme before 2006,
then the 85 -year rule does apply and everyone who's reaching age 60 after 31st of March 2020,
it is automatically applied from the age of 60. So anybody who's retiring from the age of 60
has the 85 year rule but it will only apply to their membership that they've
built up before April 2008. Any membership that they built up after
April 2008 is reduced and they will have the full reductions
applied. But it gives the protection for all the membership up to
April 2008, the 85 year rule will apply to that membership.
And as I said before, it kicks in automatically at age 60,
but for those who are under age 60, between 55 and 60,
they can ask the employer whether to switch it on.
So the 85 year rule, it is if you meet it,
if your age plus your membership adds up to 85,
So if you reach age 60 and you have 25 years membership that adds up to 25 and at age 60
there'll be no reduction to your benefits accumulated up to April 2008.
Age plus membership must equal 85 to get the benefit of the 85 year old.
So Jo at age 61 with 22 years membership, does she reach, meet the 85 year rule at age 61 at that point?
Would she be able to get that protection from reductions? No, because her membership does not, her membership pledge age does not add up to 85, adds up to 83.
So when will Jo meet the 85 year rule? It will be next year. Next year she will be
aged 62 and have 23 years membership so if she left next year at age 62 she would
meet the 85 year rule and there'd be no reductions to her benefits that have
accrued up to April 2008. Any membership
that we make sure that they have a legal requirement to produce those discretion policies and they should register them with us at the pension shared service. Were there any questions on that?
Thank you Martin. If I could just throw one in there. Do you, does the council have any
influence over any of the employers on their discretion policies if they're a bit rogue
with what they're putting within them? I know a lot of the costs would naturally default
to the employers were they to say be very lenient on some of their
discretion but are there any occasions where Wandsworth would say perhaps you
need to rethink this because ... What we do is we send them a
template and give them tips on that template and try and guide them
beforehand and how they should do it. We don't police what they actually
put in their discretion's policy. So we do give them freedom to produce what they
you know what they think is best for their for that employer and as I said
tell them not just to follow what the main council is doing but actually have
give it a thought in what they're doing. And just to add to that obviously the
employer pays the strain cost so we'd be getting them to pay the strain cost up
front. Yeah. So the fund won't be impacted so that's why it's an
employer discretion. So when obviously if Martin came to me on that one I'll be
saying right if they want to put this in place I'd want the payment in. We look
at the risk of the employer but the likelihood is we want it before any
payments were made out. Chris, you got your hand up?
It's a small one really. Did McLeod, that's my dog, my apologies, the postman's just
gone. Did McLeod, did you think about McLeod in relation to whether you needed to or we
needed to look at the distractions at all, given the fact I suppose some of those things
that are coming in which are going to be quite complicated?
The, I mean, McLeod isn't discretionary.
It will change, it has changed the regulations
and the calculation of benefits.
Although it has a small effect
in terms of the number of people that it affects.
So no, it's not really directly affecting this area
because the numbers of people who are affected
by McLeod are very small anyway.
And up to the implementation of McLeod,
the actuaries had already input on the balance sheet a figure for McLeod so it hasn't affected
this area. Yeah I'm assuming also that there might be kind of I suppose increased use of
discretion perhaps given the fact that the dashboard for members are coming is it next year
where you can actually investigate whether you've got other pensions elsewhere and what have you
potential strain in terms of work load?
Yes, we might get more traffic coming in from previous employers, from previous employees.
They might realise they've got pension rights and try to access them, say through ill health.
but at the moment we're seeing quite level numbers of requests for payment, early payment.
Okay, anybody else? Any comments on the presentation?
If not, could we smoothly move into the paper that was submitted with the updated discretion
for Wandsworth, both as the scheme employer and as the administering authority?
I think you already said, Martin, this has been passed by the JPC for both elements.
I have read through it.
I have no comments on it.
perfectly in order to me but anybody else any of my colleagues got any questions?
No that's all good so we can move on to the next item which is item five which is titled
next steps on ethical investment decisions and we have the painter that's come with that which
I know Paul is going to talk to. So Paul can I hand over to you at this point? Yeah certainly
Richard so for those who don't know you would see from the content of the report there was a
petition put in from two groups one based in Richmond and one based in Wandsworth that was
seeking to get the pension fund to take a different stance on its investment strategy,
mainly looking at those that are invested in Israeli -based organisations.
So the committee heard those petitions from the relevant groups and there was a large
and lengthy, in -depth discussion that took place around options and ways that we could,
if we wish to make changes and adapt our current approaches.
It was highlighted that the regulations do enable the funds to make decisions that are
not purely based on financial outcomes, but in order to do that there had to be three
conditions met. One is that they would sort proper advice. Two, that the advice that they
received had shown that the impact on the investment changes would not be
significant and three that the committee had reason to believe that their members
would support the decision that they made. It was also we went through the
processes around how we invest and you'll know that we don't do things on
our own right you know we have to be invest through pooling which is a London
So any products that we would seek to invest in would need to be done either through that or through a dotted line passive style investment.
It was also highlighted that whilst the amount of money invested in those underlying companies is relatively small,
we don't have the ability just to sell those singular companies, you have to sell out of the whole entire fund.
So the cost to do so would be quite large and where would we deploy the money when there
aren't those funds at the moment that has a screening in place that would disinvest
from those singular style companies.
So the outcome of the debate was that officers would bring back an options paper to a future
committee.
But the likelihood is that any decisions that we was the committee would seek to do would be reliant upon a pan -london style approach whereby we would do things more collaboratively and working across the relevant options within London so it can be operated through the SIV.
So I think that probably sums up what happened and where we are today but happy to answer any questions.
Anybody like to chip in?
One thing for me then Paul on this is that this plays its course and outcomes are reached.
What process then is an outside body able to pursue?
Were they unhappy with the outcomes?
Well, the committee made the decisions.
That's the structure and the nature of the regulations.
Like any decision that's made in local government,
people can put in a judicial review if they believe that the approach that we take is not legal.
But the style of what I led to and what I outlined is exactly what the regulations stipulate.
That is what the scheme advisory boards stipulate.
So if we go through that due process the outcome of those decisions should be
compliant with the relevant legislation. You know there is a difference between
here because it was cited we've done things with our climate approach so how
how is that different or what it is fundamentally different in the sense
that we got proper advice there was in -depth training provided we did
in -depth analysis and that analysis demonstrated that had we not made the changes that we were
seeking to make the fund would be detrimentally affected. So it ultimately was a financial
decision to set that pathway towards net zero. There are no disinvestment strategies in our
portfolio when it comes to the climate so we weren't disinvesting from particular companies
but we were looking to set the fund on an energy transition pathway to reducing the carbon
footprint and the evidence that we had demonstrated that was in the financial
interest so therefore the non -financial route was not triggered so because we
had that evidence that backed it up that's what we're saying needs to be
like to be done on these occasions. Picking a singular companies to disinvest
from is highly improbable that that would be in the you know demonstrate
that it would be financially beneficial so the likelihood is is that if we were
to go down certain routes, we would need to look at the impact and potentially go out
and canvas member views. But a lot of that would depend upon the shift and change in
the current strategy and the impact it would have on performance. Because if it is non -negative,
i .e. neutral or positive, there's no reason to get any member support. That's what the
committee are able to make those decisions. It would only be if we thought that it would
have a negative impact on performance that we would potentially need to seek
to get wider support and if you've done all of that then it's fully compliant
and that's the whole process is you shouldn't go out and just arbitrarily
make a decision without following those due process follow that due process
according to the regulations at the moment it would be fully compliant but
like anything until some if something's tested in court you don't know how well
that would stand up.
Yeah, okay. Anything from anybody else?
The only thing that I wanted to say, because I wanted to know
what other local authorities views were on this issue. So
it's good to hear that you're going to canvas that and see
what comes out of it. The other thing I want I wasn't clear
about was was the pension committee arts board asking us to do anything other than read the
petitions? Was that all they were asking us to do at this stage? I just want you to be clear.
For the board's perspective you know you might get questions coming from various different campaign
groups but the board doesn't have a decision -making process in this
aspect so you're not asked to be make any decisions. This time you're not asked
for any advice and we're not asking and canvassing your views because until such
point where we've got proposals available that isn't the case. Now
clearly if there was you know concern about the approach that the board felt
that the committee was taken that would be brought up to committee and that's
why you've got it here today, to let you know exactly what the processes that we are following.
And if you thought that this process was fundamentally flawed, then clearly the committee would want
to understand why you thought that process wasn't the correct direction to take.
So yes, that's where it is.
The petition was seeking to try to get the committee to not invest in certain activity.
And what we're saying is that that would not be in the...
To take that decision now would not be in line with regulations because the committee
do not have all of the information available to them.
And they won't have for a reasonable period of time because it needs to be done because
the way that we invest through London CIV there needs to be approaches that are available.
So we are in discussion with the CIV, we are in discussion with other London boroughs.
I sit on the pension leaders group which is representatives from 151 officers, deputy
one five one officers and pension managers to try to come up with
approaches that may well be acceptable to the 32 London boroughs to make it
viable there need to be options that people can work within there you know
there were 32 in two separate independent funds at the moment in
London and there has to be some commonality to make it a viable option
for the sieve to put on that platform
My question is very similar to Hillary's, which is, Paul, what are other local authorities,
are other local authorities under similar pressures and getting similar petitions being
handed in? Because I can see what you're saying and the process sounds absolutely right. You
can assume that if it's a sort of London wide pressure, or a
pressure being put London wide to authorities, that there's
kind of kind of more probability that something's going to kind
of happen, something's going to change, then there becomes a
question about, you know, what do you do I vest in or divest
off, because there are some kind of pressures that are being put
on bodies to divest in organisations
which may have fairly limited kind of investment
or interest in providing services to Israel
or whatever it might be.
So in a sense, that's quite an important question, isn't it?
About whether there is a kind of London -wide
or a pressure being put London -wide.
So it's wider than London -wide.
It covers all 80 odd funds.
The vast majority of them would have received petitions similar to this.
And each fund will take their own approach, how they deem appropriate.
To the best of my knowledge, I only know of one fund out of the whole of England and Wales
that is currently seeking to put together something that they think they potentially could be in a position
to put to their members in the foreseeable future.
Others are saying we need a collaborative approach.
Seems sensible.
Anything else Hilary?
Was there something else you were going to come on?
No, it's been covered.
Thank you.
Okay.
All right.
That being done, thank you very much Paul
for leaning on that item.
We now move on to item six,
which is the pensions administration update.
Thanks, Chair.
Great from you, Martin. Thank you.
I'll take the report and the KPIs as being read
and take any questions on that.
In terms of a verbal update of what we're doing,
So we've sent out all the annual, or sorry, published annual statements to active members
and deferred members to the regulatory deadline, 31st of August is the deadline every year
to get all the annual statements published for members.
So we've done that and also newsletters for all our categories of members have been published.
And in terms of annual allowance, we've also got a deadline of 5th of October to tell anybody
affected by annual allowance that there has been a, have gone over the allowance. So we've done that
for our affected members as well to the deadline.
We've sent deadline, sorry, data to the Cabinet Office.
We have every two years a national fraud initiative
amongst all public bodies who pay out monies
or the payrolls and share information.
So it's particularly useful to share information
with the DWP because they have a wide database
and they may get informed of deaths before us.
So we share with DWP and other councils
our payroll and pensions information on a two -year basis.
So that's been sent out.
And we usually find out early in the new year
whether there are any unnotified deaths
amongst our database, and then we can act on that.
Life certificates for overseas members.
every April we write to all our overseas members because they're not covered by
that national fraud initiative it's the UK only wide so we have to go through an
extra step with our overseas pensioners to get a proof of life certificate back
from them. In the ones with the fund we have 383 overseas pensioners and we give
them about six months to reply with their life certificate. 19 haven't so
their pensions have been suspended in October.
And now we wait to hear from whether we get the next kin
or the member contacting us,
and then we can reinstate their pensions.
Employee and employer webinars.
We try to run these twice a year.
And this month we'll be having both employee
and employer webinars.
It gives us a chance to communicate about the current issues and work with employers to improve performance.
So those are our current tasks.
And I say, if any had any questions about what they've read in the report, do share those.
Thank you, Martin.
Anybody like to kick off at all?
In the nicest possible way. Just on that last bit Martin, we were talking about the overseas
pensions and the life certificates where we work on a six monthly cycle with those.
So in theory somebody could have been overpaid by six months if day one of not having checked
something happens to them that died, nobody's contacted you and eventually you get in touch
with somebody and they've responded to your follow -up at some point but that six months
has elapsed. Is there a recovery situation that's followed at that point? Is there a leniency
period of up to a month or how does it work? Is it an overpayment and overpayment and that's
aim to be recovered regardless of whether it's a day or six months? Yes so we have a write -off
limit which I think is £100 for the, if Carrie I don't know whether you know the
the write -off limit? I think it's £250. £250 and so yes we do have a write -off amount
for overpayments, kind of balancing the kind of situation
that you're in with bereavement.
And in terms of six months, yes, we
have to leave plenty of time for not only our initial letter
to go out and reach somebody overseas,
but also our reminders to go out and nudge responses.
and for those responses sometimes be posted back to us.
So we can reduce that timescale by less than six months
without being unfair to the members.
But yes, we do recover overpaid pensions.
Okay, thank you.
One I've picked on before,
in terms of customer satisfaction levels on completed cases.
You mentioned every completed case,
there's a customer quality questionnaire that goes out.
So regardless of in that table, you go on page 37,
regardless of the category,
every single one of those will get a quality questionnaire.
Is that correct?
Yeah, we give them a link to fill out
a form but yes every completed case they get a link to and complete the form.
Okay so that's taking the figures from April to September I've tallied that we sent something
in the order of 3400 of those and got nine people click the link. It's quite depressing but
I still hold the view that if somebody was unhappy they'd click the link and if people are
blissfully happy with the service they receive they forget to do so but
it's still a very poor number despite all that. Yes, yes it's a low
uptake and it was even lower with the when we sent out paper copies so a lot of paper was being used
and not a lot of results but yes I take the positive view like you said that if there was
an issue they would use that facility. Okay and turning on to the complaints received,
just got a couple of questions on a couple of those five complaints that were received
from April through to now. The second one where there is a member who was not brought into the
scheme in her previous employment with Wandsworth and complained that she was not auto enrolled
and that it's been found that she should have been. What happens in that situation? Is it
backdated to the very first point that the person could have been enrolled and how does
that process work in terms of their contributions, the council's contributions and what happens
do that process? Yes, so payroll should monitor earnings. So if somebody hasn't earned, in this case,
this is to do with auto -enrolment regulations that provided you're a certain age, that there is a
bottom age limit. So you have to be, I think, over 18 and you have to be earning a sufficient amount.
and then under the DWP's also enrollment regulations,
you have to be brought into a pension scheme.
So it's a separate system to the government pension scheme.
Whereas if you have it under government pension scheme,
if you have a contract over three months
and you're brought in, this is where you,
this is based on your age and your earnings.
And initially, she opted not to join the LGPS, and she was earning less than the auto -enrollment
criteria.
And then she reached a point where her earnings were sufficient, that she should have been
automatically enrolled into the pension scheme.
Because even if you opt out, you are brought in after three years under the auto -enrollment
regulations.
So I think it's what you were saying once you meet those triggers for auto enrollment payroll should have brought her in
But that was missed and payroll don't know why it was missed in her case
and so
Now to rectify it
Yes, the employer would be paying the contributions that they should have paid at that point and the member
has been asked whether she wanted to pay the
member contributions from that point. And then her complaint was that she didn't feel as though she
should have to pay anything for her membership. But the council position is, well, yes, that's
what the regulations say. Employees and employers have to pay in. So at the time of writing the
We hadn't concluded and we still haven't quite colluded with the member, but I think she has asked for some more information about how much you would get if she did pay her contribution. So I think we're going to resolve, hopefully resolve that.
Okay.
goes ahead. So she has to do her part before the employer has to do theirs.
It has to be combined. Only so over a period of time? It's I think about three years or less.
It's not a long period of time and she was part -time so we're not
talking significant amounts of monies.
Cari, were you going to?
I was just going to say,
often the arrangement that we would come to is that the employer pays up front.
If the member decided to go ahead, the employer would pay the employer
and employee contributions up front to the fund,
and then it's up to the employer to make a repayment arrangement
with the employee to pay that back.
Okay, anybody else got any questions on the administration update?
I've got a couple. The first of course is I think as we should always do as a board
is to recognise what really good performance overall is, you know, for the pension service.
I think it's, I mean, it's again excellent. And I do take your point, Richard, I think
inevitably satisfaction surveys are always going to have a fairly low
response but I think you also look at the complaints and you know the other
issue you know the other kind of elements of performance and it all looks
I think very good and I think you know recognizing that both you know in terms
of the fact that you know over the recent I think about a year maybe
slightly longer there's been some sort of staff turnover and recruitment. My
second point is really related to that slightly, but also
looking at the work plan. And I think, you know, now that
McLeod is in its, I suppose, implementation phase, I wonder,
you know, as a board, whether we should get sort of making more
regular updates about where where things are in terms of
kind of preparation, but also, you know, some of those kind of
deadline dates for things to happen a kind of fairly close,
I know they're in 2025, but they move for, you know, things will move along quite quickly.
I think the work plan sort of tends to, we don't overlook it, but it doesn't really,
it isn't a smart work plan.
It's a work plan that doesn't really show deadlines or when things are being done to.
So it's quite difficult to judge whether things are on track with things like the cloud.
and also, you know, what I mentioned,
the kind of setting up these dashboards.
And I know that there is some kind of,
particularly the dashboards, I'm assuming,
kind of very much we're relying on,
on kind of other parties as well.
But to kind of understand those kind of work streams really,
you know, given the fact
that they're quite a significant impact,
you know, is something I think the board would,
we should no doubt as a board be certainly aware of and whether there are any particular
risks and what have you.
Yes, that is a good point. We will include those in the updates. In terms of MacLeod,
it has become law from October of last year, so it is in place. Excuse me. So all our businesses
as usual, all our cases now have a McLeod calculation done on every calculation that
goes out as a McLeod calculation. So we are complying with McLeod as we speak.
We do have, in terms of people who have left previously, we are following our software
developments. So it's going hand in hand with our software supplier as we change
the system to being able to do bulk retrospective calculations for levers.
Then we will roll that out to our levers. So yeah, we can update as our
software allows us to give us more capability functionality. So yeah,
but something we'll take up on board.
And with dashboards, similarly, we're going in tandem
with our project that we have with our software supplier.
We have now a contract with a,
or we're just signing a contract with our software supplier
for a renewal of our main pensions admin software contract.
contract and part of that is to have a
to the board. And we also, I meant to say, when we're talking about McLeod, we also will be
including McLeod in our future annual benefit statements. So our intention is from the next
annual statements next year to have a McLeod figure on their potential uplift to pensions
moving forward. But yeah, it's a good point. We will keep that as a standing agenda items.
Thanks for that Chris. Yeah maybe then in the next meeting Martin if we can have sort of like
a paragraph or a couple paragraphs whatever's needed just as a sort of a move forward on those
items and perhaps adding the GMP reconciliation progress as well.
Maybe even the National Fraud Initiative,
if there's anything more to be said on that.
So if we can maybe have those four areas
with just a couple of paragraphs on them to give us an update,
that will be quite useful.
Yeah, yeah.
Any more comments at all on Martin's section?
If not, let's move on to item 7, the patron fund annual report and accounts.
You can see it's in two parts. There's the report itself and the audit side.
Very good to read the executive summary of the audit report,
which seems to be giving a nice clean bill of health in pretty much all areas,
as far as I can comment at this particular stage.
so great news on that side and almost great news that they seem to be getting further forward in
terms of being able to be in a position to sign off 22, 23 and then 23 and 24 but they
usefully put back stop dates in their report as a we must do buy. Is everybody aware that they're
likely to comply with those. Obviously the 13th of December isn't too far away to be able to sign
off 22 -23 Corals. So how do you think they're doing? So in terms of 22 -23 my understanding for
me why is that that is pretty much with their team both in doing so when you complete an audit
you do the work during the audit but there's some things that they are required by their
regulations to do at the point of signing. So there'll be some
they'll need to check that we're still going concern, for
example, that nothing material has changed, they need
assurances from key officers to the effect that nothing's gone
on since the year end that they're about to sign off on. So
there are things that they can't literally do until there will be
about 20 emails back and forth on the day they want to sign
everything off. So these are I think these are the only things
that are outstanding on 22 -23. However, they do need to sort
out for themselves the paperwork that's needed for signing off
the council's audit for 22 -23. So this is the first year that
they are signing off without having completed an audit. So
they recently, the regulations that they needed to allow them
to do this was recently passed. They're probably waiting for
some proforma wording and things like that. So it should be just
last minute checks and then getting the wording to allow
them to comply with the new regulations to let them sign off
the council and the pension fund at the same time. So it should
be possible if we can get everyone available to sign the
relevant bits of paper before that. I'm not aware that there's
anything other than the last minute checks outstanding for the pension fund.
And because they're not properly auditing the council, there should be minimal work required on that one.
So it is possible.
Okay. Anybody got any other comments on the external audit report?
all seems certainly good in terms of how they view where the Wandsworth van is. Great news on that.
The report itself then, if we turn to that, which is in the papers, is page 73 onwards through until, where are we, pretty much 160, page 160.
so the the meat of the paperwork is within the pension financial report. Anybody got any comments
on the report itself in terms of any of the wording or any of the figures?
um I have a few just really just at the front um in the introductory bit which is page 74
I think if you read the second paragraph we talk about a new required KPI where the data is now
being collected for publication.
But I don't think it actually states what that KPI is,
unless I've missed it.
You see where I'm talking about, Corals,
but it's the fifth line of paragraph two.
Yeah.
The notable exception being the new required KPI,
where data is now being collected for publication.
I thought we would put in there any required KPI on whatever it is, just so that the reader knows what that particular KPI is. Is that okay?
Yeah, we can go back and add that.
Page 75, the contents are nicely numbered, but my version of the annual report didn't have the page numbers at the bottom.
Maybe it's just the one that's the draft one that's come through to us, but the contents pages got the numbers, but the pages themselves don't.
So that might just be a version of the report that's been sent through.
Yeah it's a bit tricky when you have the document number and then the page number for the agenda item.
Yeah, presumably it's still to be signed off.
So just that version.
Page 78 being a real bugbear here, Richard Perry chair of Ashford Academy, if that could be Ashcroft that would be very nice please.
Ashford's very nice, I'd like to go and work in Ashford.
Yes, it made me smile.
Page 80.
Deliberate mistake.
Yeah, you thought you'd get away with one.
uh page 80 where what do I got here um I haven't got many so please just do bear with me um
yeah one two three third paragraph down starts risk risk management I don't think that final
sentence is finished um which is now yeah that might just need a bit finishing off
And then being a bit picky, one, two, three, four, fifth one down, fifth paragraph down, the roles of the fund investment advisor, etc.
It then says all of the above have legally binding contracts. Now all of the above could just be the fund investment advisor and the fund actuary.
Is that true or are we also talking about the external fund managers?
Yes we are talking about the managers as well.
Right so maybe that should say because all of the above includes a local because if you go
further up you've got the JPC and the local pensions board now you're referring to all of
us in those paragraphs yet we don't all have legally binding contracts I don't think I've got
one. So just refer to which ones are covered by that if you could. Page 82, real quibble.
The third paragraph membership of the committee board and senior officer supporting the fund are
listed in zero above. I don't know what zero above is. Yeah that's
And I think the other bits are very even more trivial just minor
typos or something so I'll send you those through but
other than that it reads exceptionally well and we have a very good a very good year for the fund so
That's all I wanted to comment. Anybody else wish to chip in? No? Nobody else wants to be looked at badly by a coral.
I welcome all constructive, helpful criticism.
No, it's actually very, I mean it's a, who put this together, is it you?
Guilty I'm afraid, yes.
No, no, that's not me criticising, it's a hell of a document to put together, so I think you've done a very commendable job there and I'm glad I've contributed with just a couple of little points.
Well, I pull it together, I do have assistance from Martin's team as well, so they have done chunks of it.
No, no, I'll give all the praise to you.
No, no, it's a team effort, it's a team effort but I will take responsibility for the typos because I suspect they are all mine.
Right, yes, so thanks all. Nothing else on that. Can we move on to the risk management paper?
And you have kindly given us a steer as to where the updates were made from last time round, which is all good.
and also a hint that there will be some others to potentially take into account going forward with the good governance arrangements etc.
So we'll await for those. I've read through our sections, I always do, in advance of each meeting and can't think there's any others at this point that we need to look at either the risk scoring or add in extra wording on.
The only bit I wanted to talk about really was again going back to the Pension Fund Report where it talks about our particular role in respective risk as a local pensions board.
And obviously there is reference to the fact that we receive the service department risk registers as well as that of just the fund and you provide that in the paperwork each and every time.
And I know those don't get reviewed so often or updated so often, but they do get reviewed.
Could I ask that where there are any changes to any of those three, that as we do with the one with our fund, that there are tracked changes put through,
So that if we are scanning through it and paying some attention to that, but probably less than the one that's specific to us, that will be helpful in just seeing where those changes are or where there's any wording adaptations.
If we don't get that already, if we do get that already, then fine.
I don't think you get that already. What we do have is I think that the format and the layout of
these documents are tweaked every year. So there will be some things marked up just purely because
we've added, we've changed the layout. So presumably you're not interested if it's gone
on a different page or just interested if it's substantially changing what the risk is or the
or those sort of things.
Yeah, so I don't know either that or a paragraph of this particular section in terms of the, your area for example.
We've changed this risk because of X reason and or we've changed the scoring because circumstances have changed etc etc.
I would find that useful and helpful if we are supposed to be reviewing those.
I would find it very difficult to review it if there weren't those prompts.
I don't know how doable that is but...
I think we've just updated them so I would have to go back and...
Well from this point onwards.
Don't worry about what's just gone through. I just think I'd feel more comfortable if we are knowing where they've changed so that we can play our part in just seeing it. That seems sensible.
I mean, the departmental ones are provided for information, not for review. So they are more to inform, to help your understanding of what the funds risks are, because of how the teams are working within that.
But fair comment, you'd want to see if we are improving or worsening in any areas on those.
So, yeah, I'll look into a way to get updates on those so you can see what has changed and if it's substantially changed or a new category, etc.
Yeah, the goal is just take it away and think about it and discuss it.
And if there are limitations to it, then fine.
But yeah, I think if only just to know that they are being reviewed and there's evidence
of them being reviewed, then that's good to know.
Because in theory, unless I compared that with the one last time round, I won't know
where there's been any changes at all.
And I don't think any of us really have the time to do that.
but if there is some change on them and it's noted somewhere,
then that will be a good halfway house, I think.
Yeah, fair enough.
Anybody else?
Anything on risk, on our particular one
or the risk area as a whole?
Chris?
I mean, I did think when I looked at the
e -service specific objectives of risks,
I mean, again, I might be kind of reading what should be here incorrectly, but I would
have thought you might have something in relation to, again, I do go back to it, but I think
it's probably quite an important area of new work.
McLeod, just as a key service activity, and whether you need to kind of represent that
there I'm not absolutely sure but it's not you know it's not represented there
at the moment. So I'll answer that one I mean McLeod was reviewed as a risk base
by the actuary and not deemed to be significant so that's why it's not
needed to be there. Absolutely Paul but you don't I mean a risk register doesn't
mean that you don't put the risk in. And we we do also comment on sorry we do
also comment on regulatory changes more generally, which
would cover McLeod as a risk. So that taken with the review that
says it's not a material risk for us now. We could argue that
it is in there.
Yeah, as I say, I know it's reported elsewhere, it's just
whether, you know, it should be something that was represented
in the risk register. As I said, I'm not, it's more of an
observation than a comment.
I mean, I could we could add eg McLeod under regulatory
changes if that
that will be good, I think or just as it's it's noted that
that's been on the radar it's been dealt with. Yeah. Anything
else anybody? No. I think that's it then. Any other business anybody wants to raise?
If not all shakes of the head which is... I just wondered if there's anything about budgets,
you know, national budgets since we had the Labour Party with all the changes that they want to make
in terms of finances was there anything in relation to our pensions at all? Yes,
basically the, fundamentally yes, the government have changed the way that they will record
assets and liabilities and when they're setting up for what they can borrow.
As a result of that assets and liabilities of the LGPS pension fund are now on the balance sheet
of national government. And there will be an announcement on the 15th of November at
Mansion House that may significantly impact on the way the LGPS is run going forward,
but we won't know what that is until the Mansion House speech. It could be there's only one
pension fund now.
Thank you.
Anything else from anybody else in the hope that we meet next time, representing the Wandsworth Pension Fund?
No. Right. Well, thanks, colleagues, very much. Thank you all for your attendance.
thanks Marianna for organising and getting us all together and see you all again soon.
Thanks a lot.
Thank you.
Goodbye.
Bye.
Bye.