The much-delayed TPR General Code

Commenting on the much-delayed TPR General Code laid before Parliament today, Laura Andrikopoulos, Head of Governance Consulting, Hymans Robertson, said:

“After a lengthy delay, during which Trustees may have put ‘pens down’ on their projects to ramp up scheme governance, the laying of the General Code means these important projects can now be resurrected. Delayed effectiveness and governance reviews can now be performed with greater confidence on the actual requirements. The laying of the Code heralds an important step-up in the governance of occupational pension schemes, particularly Defined Benefit schemes, which have not been subject to the same regulatory requirements as DC schemes have seen in recent years, such as the Chair Statement.

“The biggest change for schemes will be the ‘Own Risk Assessment’ (ORA) requirement, and we are pleased that this final version of the Code recognises, in line with the underlying legislation, that a report once every three years is sufficient. This is in line with other major requirements such as the triennial actuarial valuation, and will save schemes from what could have been a substantial annual process. The clarifications in the final version of the Code are also helpful – for example, that the ORA can be a collation of other relevant documents. Trustees may also be relieved to see the enhanced emphasis on proportionality in relation to the Risk Management Function and the assurance requirements.

“Before the Code comes into force in the spring, schemes should now dust off their gap analyses and proceed with identified policy gaps, a review of their risk management and preparation for their first ORA.”