Investment guidelines

1. Effective decision-making
Decisions should be taken only by persons or organisations with the skills, information and resources necessary to take them effectively. Where trustees elect to take investment decisions, they must have sufficient expertise to be able to evaluate critically any advice they take. Trustees should ensure that they have sufficient in-house staff to support them in their investment responsibilities. Trustees should also be paid, unless there are specific reasons to the contrary.
It is good practice for trustee boards to have an investment subcommittee to provide appropriate focus.
Trustees should assess whether they have the right set of skills, both individually and collectively, and the right structures and processes to carry out their role effectively. They should draw up a forward-looking business plan.

2. Clear objectives
Trustees should set out an overall investment objective for the fund that:
  • represents their best judgement of what is necessary to meet the fundís liabilities, given their understanding of the contributions likely to be received from employer(s) and employees; and
  • takes account of their attitude to risk, specifically their willingness to accept underperformance due to market conditions.
Objectives for the overall fund should not be expressed in terms which have no relationship to the fundís liabilities, such as performance relative to other pension funds, or to a market index.

3. Focus on asset allocation
Strategic asset allocation decisions should receive a level of attention (and, where relevant, advisory or management fees) that fully reflect the contribution they can make towards achieving the fundís investment objective. Decision-makers should consider a full range of investment opportunities, not excluding from consideration any major asset class, including private equity. Asset allocation should reflect the fundís own characteristics, not the average allocation of other funds.

4. Expert advice
Contracts for actuarial services and investment advice should be opened to separate competition. The fund should be prepared to pay sufficient fees for each service to attract a broad range of kinds of potential providers.

5. Explicit mandates
Trustees should agree with both internal and external investment managers an explicit written mandate covering agreement between trustees and managers on:
  • an objective, benchmark(s) and risk parameters that together with all the other mandates are coherent with the fundís aggregate objective and risk tolerances;
  • the managerís approach in attempting to achieve the objective; and
  • clear timescale(s) of measurement and evaluation, such that the mandate will not be terminated before the expiry of the evaluation timescale other than for clear breach of the conditions of the mandate or because of significant change in the ownership or personnel of the investment manager.
The mandate should not exclude the use of any set of financial instruments, without clear justification in the light of the specific circumstances of the fund. The mandate should incorporate a management fee inclusive of any external research, information or transaction services acquired or used by the fund manager, rather than these being charged to clients.

6. Activism
The mandate should incorporate the principle of the US Department of Labor Interpretative Bulletin on activism. Managers should have an explicit strategy, elucidating the circumstances in which they will intervene in a company; the approach they will use in doing so; and how they measure the effectiveness of this strategy.

7. Appropriate benchmarks
Trustees should:
  • explicitly consider, in consultation with their investment manager(s), whether the index benchmarks they have selected are appropriate; in particular, whether the construction of the index creates incentives to follow sub-optimal investment strategies;
  • if setting limits on divergence from an index, ensure that they reflect the approximations involved in index construction and selection;
  • consider explicitly for each asset class invested, whether active or passive management would be more appropriate given the efficiency, liquidity and level of transaction costs in the market concerned; and
  • where they believe active management has the potential to achieve higher returns, set both targets and risk controls that reflect this, giving managers the freedom to pursue genuinely active strategies.

8. Performance measurement
Trustees should arrange for measurement of the performance of the fund and make formal assessment of their own procedures and decisions as trustees. They should also arrange for a formal assessment of performance and decision-making delegated to advisers and managers.

9. Transparency
A strengthened Statement of Investment Principles should set out:
  • who is taking which decisions and why this structure has been selected;
  • the fundís investment objective;
  • the fundís planned asset allocation strategy, including projected investment returns on each asset class, and how the strategy has been arrived at;
  • the mandates given to all advisers and managers; and
  • the nature of the fee structures in place for all advisers and managers, and why this set of structures has been selected.

10. Regular reporting
Trustees should publish their Statement of Investment Principles and the results of their monitoring of advisers and managers and send them annually to members of the fund. The Statement should explain why a fund has decided to depart from any of these principles.

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