A new general code by The Pensions Regulator (TPR) will improve member outcomes and governance, according to Anthony Raymond, general counsel and director of governance risk and assurance at the regulator.

TPR is due to publish its new General Code in the coming months, consolidating 10 of the existing codes into one documents.

The new code will introduce new pension scheme governance responsibilities. Trustees and governing bodies will need to identify the required changes to their current processes, check current policies and procedures are fit for purpose, and implement changes where necessary.

The code was initially expected to be effective in the Autumn of 2022, however it was delayed due to political upheaval and the COVID-19 pandemic.

Speaking at the Pensions Aspect Live conference on 21 June, Raymond said  the publication of the new code is “subject to a parliamentary timetable” and out of the regulator’s “hands” but it is “ready to go” after two years of consultation.

In terms of what the new code will involve, Raymond acknowledged that there is an expectation building but he believes that those who provided feedback to the consultation will be “pleased” in terms of what the regulator is doing, offering no further details.

And while there was a concern in the audience of how smaller schemes will be able to cope with the added responsibility, Raymond said that the new code “reflects what already exists”.

He said it was about “applying it to the right circumstances in the right areas and to the right schemes” and he “hopes” that it’s “clear on the face of the modules which one applies to whom”.

He added: “I see it more as an opportunity to improve the outcome for members, because if that’s really clear as to what you should be doing, that does translate into better governance.”

Keeping it simple

Carolyn Stanton, consultant and scheme secretary at First Actuarial, agreed that a lot of the aspects of the new code including administration, investment, communication are already in place.

And even for the policies on the governance section, she said, a lot of schemes will have “a lot of those in place as well” but they might need to be “refreshed, reviewed or updated”.

For the new elements, she said, those will need to be considered or policies put in place for things like renumeration of trustees and advisors, for example.

She said: “It’s just bringing it all together, trying to make it effective in order to improve the governance [of a] scheme.”

She continued: “The work that we’ve been doing to build that solution to put effective systems governance and do the audit and risk assessment, we build it on what we’ve got. We’re keeping it simple.

“That’s what we’ve been trying to do to help make that process as painless as possible for trustees when it comes to looking at what they’ve got, looking at where the gaps are and trying to fill those gaps, but also not just ticking boxes.”

She added: “It’s about trying to tighten governance and be more secure so that the members are going to benefit.”

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