WEBVTT

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Hi, I’m Adam Whitehead,

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Senior Associate at
Independent Governance Group (IGG).

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This case study involves
supporting a large UK pension scheme

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through a significant governance review,

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following the introduction of The Pension
Regulator's General Code.

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IGG supported a scheme with approximately

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£1.5 billion in assets
and around 7,000 members.

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The trustee board comprised eight
trustees, including three

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professional trustees,
supported by three sub-committees

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overseeing key areas of governance
and delivery.

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Following the introduction
of the General Code,

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the scheme's internal team was facing
a significant increase in workload

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alongside the need to maintain
business-as-usual governance,

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including full trustee
and sub-committee meeting cycles.

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They therefore sought to outsource
their General Code requirements to IGG.

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The trustee wanted to ensure compliance
with the General Code in a way

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that was practical, proportionate
and sustainable, while also establishing

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a strong foundation as it looked towards
completing its first Own Risk Assessment,

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or ORA. The challenge was not simply
implementing the requirements

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of the General Code,

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but doing so without introducing
unnecessary complexity or

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creating a governance framework that would
be difficult to operate in practice.

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The primary risk was non-compliance, driven

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by both the scale of the new requirements
and internal capacity constraints.

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The trustee was clear that any solution
needed to be proportionate, practical

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and manageable for both the pensions
manager and the wider trustee board.

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At the same time, governance improvements
needed to be delivered alongside

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existing trustee responsibilities,
ensuring that regulatory requirements

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could be met without disrupting day-to-day
scheme governance.

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IGG's approach
focused on working with the in-house team

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to build a strong understanding
of how the scheme operated in practice,

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investing time upfront
to ensure that priorities

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were aligned with both the pensions
manager and trustee board;

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and delivering
training to the trustee board

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to ensure they understood
the enhanced governance obligations.

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A structured gap analysis was undertaken
to assess existing governance

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documentation against the requirements
of the General Code.

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Rather than overhauling documentation,

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the focus was on targeted updates
and enhancements, ensuring alignment

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without unnecessary duplication,
and a resulting governance framework

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that was fit for purpose
for where the scheme was in its journey.

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Delivery was structured

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across the scheme year, with policies
introduced and reviewed in phases.

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This enabled trustees to engage
with and challenge each policy effectively,

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avoided overwhelming the Board
with a large volume of changes

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at one time, and ensured governance
improvements were embedded

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progressively rather than delivered
as a single exercise.

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As part of this process,
nine new policies were introduced,

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while existing documentation was streamlined
to maintain a proportionate

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and coherent governance framework.
Throughout the project,

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the focus remained
on creating a governance framework

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that was practical to operate,
proportionate to the scheme's needs

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and aligned with future regulatory
requirements.

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The scheme achieved compliance
with the requirements of the General Code

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within the required timeframe, without
disrupting existing governance processes.

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The approach resulted in a strengthened
and more structured governance framework,

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improved clarity
and usability of governance documentation,

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and delivery of regulatory requirements
in a cost-efficient and proportionate way.

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Importantly, trustees remained
actively engaged throughout the process

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without creating an unnecessary time
burden on the Board.

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The ESOG review also established
a clear foundation

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of the scheme's Own Risk Assessment,
ensuring the trustee board is

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well positioned to complete
the ORA efficiently and with confidence.

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This case study demonstrates
the value of outsourcing the requirements

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of the General Code

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to a trusted partner, who can help
and support an in-house pensions team

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Who are time and resource
constrained, alongside undertaking

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a structured and proportionate approach
to governance enhancement.

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By building on the existing governance
arrangements, focusing on targeted

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improvements
and aligning delivery to trustee capacity,

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the scheme was able to meet
the requirements of the General Code,

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while establishing a strong and sustainable
foundation for future ORA delivery.