Assessing your Fidelity Workplace Pension - Acting in your best interests - The Independent Governance Committee's 2020 report - AWS
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Assessing your Fidelity Workplace The Independent Pension Governance Committee’s 2020 report Acting in your best interests
Contents Executive summary........................................................................................................... 3 Value for money................................................................................................................ 5 Investment strategy........................................................................................................... 7 Costs and charges........................................................................................................... 12 Customer experience..................................................................................................... 16 Improving inputs for better retirement outcomes....................................................... 21 Security............................................................................................................................. 23 Support for the IGC.......................................................................................................... 27 Have your say.................................................................................................................. 28 Members of the IGC and independence criteria....................................................... 29 Contact us........................................................................................................................ 33 2 IGC Report 2020
Executive summary Executive summary Dear pension plan member, When we assess for Value for Money, we use the following criteria: Welcome to your Independent Governance Committee’s annual report for 2020. • The suitability of your pension plan’s investment strategy It’s been a full and busy year for us, and there • The costs and charges you pay has been progress in many of the areas we • The level and quality of service that you raised with Fidelity in our previous reports. receive – your customer experience We’re here to work in your best interests, and • The level and quality of benefits that you those of all members of Fidelity’s workplace receive, compared with the contributions pension schemes, and to assess whether you you make (improving inputs for better receive value for money from your pension outcomes) plan. We do this using the criteria set out in our • The security of your investments Value for Money framework (see separate You can find out more about each of these Value for Money booklet). criteria in the summaries at the start of the following sections. The Value for Money framework We are working hard on your behalf to assess After reviewing these areas, and in detail the value for money you get from comparing them with the charges you Fidelity. As we explained in our 2019 report, pay, we have concluded that, overall, this year we have focused on monitoring the changes made to Fidelity’s systems and the Fidelity has met our expectations and developing digital experience, reviewing continues to offer you value for money. how costs and charges are presented, looking at the communications you receive There are some areas where Fidelity has met from Fidelity and getting members’ views on or exceeded our expectations: sustainable investment. • There is a robust procedure and controls framework in place to ensure your funds are closely monitored and your personal data is secure • The process for monitoring and reviewing default investment strategies is working well • Members are at the heart of Fidelity’s offering and significant progress has been made in improving service levels and process automation over the year IGC Report 2020 3
There are also some areas where we feel To fill the spaces on the board, we ran an open Executive summary Fidelity has only partly met our expectations. recruitment process in conjunction with Fidelity We will be working with Fidelity in the during the last three months of 2019 and have coming year to enhance and improve your appointed Dianne Day and Gerald Wellesley. experiences. These areas are: They bring a wealth of experience and expertise to the board, and their appointments • Clear communications sent to you at will allow us to continue to put your best relevant times, so you can make informed interests at the heart of everything we do. decisions about your retirement plans, with Welcome, Dianne and Gerald! a particular focus on digital communications • The availability of income drawdown There was also a change to the Fidelity in retirement representation on the board, as Paul Mason • Current contribution levels and how easy resigned from the company. Paul is replaced they are to change by James Carter, Head of Pension Products • Communicating about costs and charges in and Policy in UK Workplace Investing. James pounds and pence has many years’ experience in the pensions field and we have already benefited from The Financial Conduct Authority (FCA) his contributions. Thank you to Paul, for all announced in 2019 that our remit would be your support in the creation of the IGC, and expanded from 6 April 2020. This means that in welcome to James. 2020 we will be taking a close look at: • Fidelity’s policies on environmental, social, How can I get in touch with and governance (ESG) issues within the IGC? investment choices and default strategies, We are always delighted to hear from member concerns, and stewardship members, and we will use any feedback • The introduction of investment pathways in you give us to inform our conversations and retirement and how they will link to Fidelity’s proposed activities with Fidelity. default investment strategy, FutureWise If you would like to get in touch with us, there Where can I find out more? are a couple of ways you can do this: We have made a short video that explores the By email: FidelityIGCchair@ptluk.com results of our value for money assessment. You can watch it here. By post: Fidelity IGC Chair, PTL, Park House, Park Square East, Leeds, LS1 2PW In addition, you can also view last year’s report, together with profiles of the IGC members here. We look forward to hearing from you. Changes to the board Two of our independent members left the board during the year; Rachel Brougham in October 2019 and David Felder at the end of Kim Nash March 2020. On behalf of the rest of the board, Chair, Independent Governance Committee Fidelity, and all our members, I’d like to extend our grateful thanks to Rachel and David for April 2020 their tireless efforts on your behalf. 4 IGC Report 2020
Value for money Value for money Introduction To assess whether you are receiving Value for Money from your pension plan, we monitor the As Chair of Fidelity’s Independent Governance performance of Fidelity and the companies Committee (IGC), I am delighted to present our managing the funds your pension savings annual report for 2020. are invested with. This is done against the We were set up in 2015, after the Financial criteria described in this report. We then use Conduct Authority made this a requirement for this information to challenge Fidelity when we every insurance company providing workplace identify ways to improve its service or products. personal pension plans. We must have a As we finalise this report in late March 2020, majority that is independent of the pension the coronavirus outbreak is having an provider, so of our five members, three are impact on every aspect of our daily lives, independent (including the Chair) and two are including our finances. We have checked representatives from Fidelity. with Fidelity that your pension continues to be Our job is to: well managed during this challenging time. This includes answering your calls as quickly • Act independently of Fidelity as possible and providing you with the up-to- • Always act in members’ best interests date online information you need about your • Scrutinise Fidelity’s Group Personal Pension pension investments. and stakeholder plans, to see if they provide members with Value for Money We can report that the restrictions we are all having to deal with as a result of the pandemic This report gives you our assessment of Value have not affected the administration of your for Money, along with an update on the pension. As an international organisation, improvements to your pension plan that we Fidelity has benefited from the experience of its have been working on with Fidelity. offices in China, Hong Kong and Japan, which were affected by the pandemic several weeks At the end of 2019, the IGC was looking across prior to the UK. We do not yet know the long 185 Group Personal Pension and Stakeholder term effects of the coronavirus on the economy plans, representing the best interests of 276,000 and investment markets, but will continue to members with £8.3 billion of retirement savings. carefully monitor your Fidelity pension on your behalf throughout 2020 and beyond. Each pension plan has been established by its sponsoring employer to meet its own If you would like more information after reading requirements. This means there are different this report, or have questions or feedback for contribution levels and often different us, please get in touch. investment strategies being used, aiming for different types of retirement provision. IGC Report 2020 5
Value for money In determining value for money, we assess: Value for money To be considered good value for money, we • The suitability of your pension plan’s expect a pension plan to achieve certain investment strategy standards. These standards are set out in our • The costs and charges you pay Value for Money framework (explained here), • The level and quality of service that you which was created with help from member receive – your customer experience feedback. This enabled us to take your interests • The level and quality of benefits that you into account. receive, compared with the contributions you make (improving inputs for We regularly check these standards to ensure better outcomes) they are still relevant and are stringent enough • The security of your investments to make certain you are getting the best from Fidelity. We also review the features of Fidelity’s pension plans against these standards, so we Following our assessment this year, and can see where Fidelity is performing well and after examining each of these criteria, where it needs to do more. we have concluded that Fidelity has met our expectations and continues to offer you value for money. The following pages explain how we have reached our conclusions. When assessing each section, we have looked to provide a view of how Fidelity has done against the expectations we had at the beginning of this review period: • Not met – Where Fidelity has failed to meet our expectations • Partly met – Where Fidelity has met some of our expectations, but we would like to see greater progress • Met – We are happy that Fidelity has achieved the standard we expect • Exceeded – Fidelity has out-performed our expectations 6 IGC Report 2020
Investment strategy Investment strategy We expect you to have access to a good quality default fund, which is where your money will be invested if you do not make an investment choice. This could be the Fidelity standard default called FutureWise or it might be one designed by your employer. We also want you to have a good range of other funds to choose from. What we look for: Investment strategy Standard fund that needs no decisions and is Exceeded designed with the needs of members in mind Investment objectives are set, reviewed regularly Met and met Option to choose higher-risk, higher-cost funds Met Access to a range of funds Met Responsible investment Environmental, social and governance factors (ESG) Partly met Overall conclusion We believe that Fidelity provides access to a wide range of good quality funds. FutureWise is performing well, and we are satisfied with the robust governance that surrounds it and the other (advised) bespoke default arrangements. We recognise the work that Fidelity has undertaken around ESG and we are particularly pleased with the response rate from our recent member survey. However, there is clearly more to do in this space and we will be focusing on that in 2020/21. We believe that Fidelity has met our expectations in this area. IGC Report 2020 7
A good-quality default fund Objectives are being set and met Investment strategy FutureWise changes FutureWise FutureWise is a default investment strategy that While we regularly review the performance puts a member’s pension pot into a range of and suitability of FutureWise with Fidelity appropriate funds during their working life. as part of our governance, we also sought an additional assessment last year from an Last year, we highlighted that Fidelity had independent investment consultant, Redington. made some changes to FutureWise. These were Our aim was to see if there were any aspects of applied in the first half of 2019 to all pension FutureWise that required further consideration. plans that were established before 1 July 2018 and were using FutureWise. The investment consultant reviewed how the strategy had performed in the past and In the same report, we spoke about older- evaluated whether the strategy may deliver style and bespoke default strategies. Where a good outcome in the years ahead based an employer had established a bespoke on their in-house investment assumptions. default strategy and was not receiving regular The analysis reviewed four stages in the investment advice, we said Fidelity would glidepath of FutureWise against independently move members using this default strategy into deemed criteria. FutureWise. This allows Fidelity to ensure that all members are offered a default investment • FutureWise scored well on the forward- strategy that is governed and monitored on an looking assessment, as well as across all ongoing basis to ensure it remains suitable and parts of the glidepath. in line with regulations. • FutureWise also passed the backward- looking assessment. This also involved This project is underway and is due to be assessing the underlying funds within completed later in 2020. If you are affected FutureWise against their benchmarks by the transition, you will receive a letter explaining the changes and the points you This independent analysis has helped need to consider, so you can decide if it is right us conclude that FutureWise is meeting for you. expectations. However, we will continue to monitor the strategy on an ongoing basis Members who have chosen their own taking account of regulatory, market and funds and don’t have any assets in default economic developments. investment strategies are not affected by this move but will have the option to choose FutureWise performance FutureWise if they feel it is suitable for their Although we’re not responsible for setting the retirement goals. strategy that members invest in, we monitor default funds and wider fund ranges to ensure they are appropriate and perform well against their objectives. This covers employer-designed default strategies, FutureWise and all self-select funds. Overall, we believe Fidelity’s approach to investment governance has exceeded our expectations 8 IGC Report 2020
Over your working life, FutureWise takes what is known as a ‘lifestyle’ approach. In other words, Investment strategy during the early years of your working life, Fidelity invests your money in a way that has the potential for long-term growth. When you’re closer to retirement, it aims to protect the value of your savings by gradually moving your money into more cautious investments. With FutureWise, this changeover starts to happen 18 years from your retirement date. The table and graph show the performance of the FutureWise strategy over the last five years for different age groups. As the strategy was revised in 2018, some of these figures are based on underlying fund performance and back-tests, which we have highlighted below. FutureWise strategy – Returns to 31 December 2019, gross of fees Age One year Three years Five years (% per annum) (% per annum) 25 20.0% 8.9% 10.5% 35 20.0% 8.9% 10.5% 45 20.0% 8.9% 10.5% 55 13.8% 6.0% 6.4% 65 8.4% 4.0% 4.3% Inflation – Retail Price 2.2% 3.0% 2.5% Index (RPI) * * Included for comparison purposes only FutureWise cumulative returns over five years (Starting pot of £1,000) £1,700 £1,600 £1,500 £1,400 £1,300 £1,200 £1,100 £1,000 £900 31/12/14 31/12/15 31/12/16 31/12/17 31/12/18 31/12/19 Age 45 Age 55 Age 65 Inflation - Retail Price Index Bank of England Base Rate Source: Fidelity International December 2019. Performance is gross of fees. Performance is based on an assumed retirement age of 65. Three-year return figures for ages 45 and 55 are based on the strategy’s underlying fund performance. Five-year return figures for ages 45, 55 and 65 are based on back-tests of the strategy’s underlying funds and investments. These figures do not include the impact of contributions. Past performance is not a reliable indicator of future results. The value of investments may go up as well as down and investors may get back less than they invest. IGC Report 2020 9
Bespoke sections Investment strategy We regularly review the investment strategies We also want Fidelity to write to all self-select of bespoke sections to ensure they have members every three years to remind them been designed and executed in members’ of their investment choices and explain how interests and have clear statements of aims important it is to keep the funds under review. and objectives. Fidelity has committed to doing this through the member engagement program, but This includes assessing the performance of due to the slow roll out of the initiative, we the strategies on a quarterly basis to ensure want Fidelity to issue letters to members until the funds are performing in line with their a greater number of email addresses have objectives and the design remains suitable. been collected. We also challenge advice from the relevant investment advisers for the schemes where Responsible investment strategies are not designed as we would have FutureWise ESG analysis expected (such as targeting an annuity at ESG stands for environmental, social and retirement) and we ensure advice is provided governance. It is a way of looking at how to the schemes on an ongoing basis. businesses work to see if they are socially responsible. Last year, we explained how Access to a range of funds and the we were working with Fidelity and a third party to assess how FutureWise looks from option to choose different funds an ESG perspective; in other words, how well While it is important to ensure the default FutureWise scores for the companies and funds investment strategy is suitable, we believe it invests in. The analysis showed that it has an it is also essential to have a broad range of average ESG rating. investment options for people who wish to self- select. We have reviewed Fidelity’s fund range We’ve now evaluated this analysis and have and believe it offers: asked Fidelity to look at ways to improve ESG integration across the strategy. It is currently • A wide range of cheaper passive funds that considering how to make a meaningful look to track the market difference without detracting from the • More expensive options where fund strategy’s overall risk and return expectations. managers are looking to beat the market Fidelity will provide us with regular updates • A range of specialist asset classes, such as and is currently working with fund managers ethical or socially responsible funds and others within the market to see how an In addition, we will be working with Fidelity to improved ESG outcome can be achieved ensure new funds are offered to all members for members. of a pension plan, together with adequate Current approach to ESG and stewardship choice in key areas, such as ethical and As a fund platform, Fidelity delegates voting responsible investing including Environmental, decisions and engagement to the underlying social and governance factors (ESG). fund managers. This means that both Fidelity We will continue to review the performance and the IGC expect managers to explain how of all the funds available to members on a they engage with companies about ESG – and quarterly basis to ensure they are meeting their carry out monitoring and engagement in line stated objectives and providing value on a with their stewardship policies. We want to net-of-fees basis. Any concerns will be picked know how they measure the effectiveness of up with Fidelity for further review. the strategy while considering the long-term financial interests of members. 10 IGC Report 2020
In addition, we regularly speak with key fund Member ESG survey Investment strategy managers about their current position and We understand that many people have strong future plans for ESG policies. This includes views about sustainable investing and ESG. In managers from BlackRock and Fidelity, as January 2020, we sent out a survey with Fidelity they offer the funds used by many members, to learn more about the aspects of sustainable including those within the FutureWise strategy. investing our members care about and how much the topic matters to them. We received These meetings aren’t just an opportunity over 4,000 responses across 109 pension plans to understand the managers’ policies, we administered by Fidelity. These told us that: can challenge them too – and explore the ways they measure success. We have found • 69% of members agreed that organisations that both Fidelity and BlackRock are taking have a wider social responsibility than simply steps to integrate sustainability and improve making a profit transparency. This includes: • 33% of members would increase their contributions if they knew their pension was • Both are signatories to the UN Principles for being invested sustainably Responsible Investment and have A+ ratings • 14% of members would be willing to for ESG strategy and governance pay more for a fund that invested in a • Both have a dedicated team that integrates socially responsible way. A further 32% ESG into their core investment process and were undecided provides us with regular information about day-to-day fund management We are currently evaluating the results of the • Both are actively encouraging companies survey and will use this feedback to guide our to disclose climate-related risks in line with engagement with Fidelity on the development the Task Force on Climate-related Financial of ESG in the investment proposition. Disclosures (TCFD) recommendations. This includes operational plans in the event We see this as an area of improvement for that the Paris Agreement’s goal of limiting Fidelity and will ensure there is more focus on global warming to less than two degrees is including ESG options within the default and fully realised self-select range. Fidelity will also be collating reports on Extension of IGC remit its voting and engagement policies to As a final point, in December 2019 the FCA (our ensure managers are staying true to regulator) confirmed the formal extension of their sustainability objectives – and it is our remit for oversight of Fidelity’s ESG policies, working on providing the full sustainable so we can aim to ensure your investments are investment policies of all fund managers on exposed to suitable ESG risks and opportunities. the platform. This will require us to consider and report on While we are keen to ensure more the adequacy and implementation of ESG transparency around company policies (including climate change), member engagement, we also want enough funds concerns and stewardship. We will include on the platform with an ESG focus, so we our views on how Fidelity and the underlying can meet a wide variety of member views. managers have responded on these issues in There are currently nine and Fidelity is looking our 2021 report. to add more. In addition, it is exploring the idea of an ESG tool that could help you see how effectively individual funds are integrating ESG and compare different elements of ESG consistently. IGC Report 2020 11
Costs and charges Costs and charges The costs you pay will affect your retirement savings over the years, so we want to make certain that all charges are appropriate. This is why we check that Fidelity’s charges are in line with the market and are reasonable when compared with similar funds. What we look for: Reasonability Charges in line with the market Met Level of transaction costs Met Overall conclusion: We believe Fidelity’s charges are reasonable. Indeed, in a recent independent benchmarking exercise, Fidelity had one of the lowest charges for their default investment option. There is a simple and clear Annual Management Charge structure in place and there are no exit charges, so you can transfer your funds away from Fidelity without incurring any penalty if you wish to do so. We would like to see costs and charges expressed as £ and pence, as we believe this will help members understand them and we are working with Fidelity to achieve this. We did challenge Fidelity’s methodology for calculating transaction costs and it has reviewed its processes in response to bring them in line with other managers’. We believe that Fidelity has met our expectations in this area. Charges in line with market Included within the Transaction costs – We thought it would be helpful to start with a total expense ratio Not included in the definition of the charges that you pay: (TER) total expense ratio (TER) Total expense ratio: The main charge you pay Annual management Broker fees to invest in a fund is the total expense ratio charge (TER), which is applied to the value of your Legal fees Commission costs investment. For example, a TER of 0.20% means a charge of 20p a year for every £100 invested. Trading fees Stamp duty The total expense ratio combines the annual ‘Slippage’ or ‘swing management charges and other expenses. pricing’ Transaction costs: Highlighted in the table on the right. 12 IGC Report 2020
As summarised above, we believe Fidelity’s Despite the FCA’s requirements, some Costs and charges charges are reasonable. Indeed, in a recent managers have struggled to provide the independent benchmarking exercise, information in a consistent and comparable Fidelity had one of the lowest charges for their format. However, further progress has been default investment option. There is a simple made since last year and Fidelity continues to and clear Annual Management Charge work with its external fund manager partners to structure in place and there are no exit obtain this information. charges, so you can transfer your funds away from Fidelity without incurring any penalty if Transaction costs in Fidelity’s FutureWise strategy you wish to do so. All costs and charges have a bearing on the returns a member can achieve from their Charges in pounds and pence – update pension investments. These costs have been We believe it is important that you can calculated for the year to 31st December 2019 understand the costs and charges you pay and assume you retire at age 65. and the impact they have on your pension savings. That’s why we are disappointed that Fidelity’s FutureWise default strategy is Fidelity has not made more progress towards made up of four underlying funds, with showing costs and charges as monetary the investments in each fund managed by amounts in their annual benefit statements and either Fidelity or BlackRock. These funds other key communications. incur different levels of transaction costs. The proportion of a member’s investments that The Government and Regulators are also is invested in each fund will change as they concerned about the transparency of costs approach retirement, so the amount they pay and charges and they want annual benefit in transaction costs will also change over the statements to be more consistent, shorter and course of their working life. simpler in style. An industry-standard approach is likely to be published soon, which is In our analysis undertaken during the year, something we welcome. From 2021, we will also our review highlighted that one of the four provide more information about the impact underlying FutureWise funds, managed of costs and charges in this statement – and by Fidelity, was quoting higher average we will continue to work with Fidelity to ensure transaction costs than the other three when these developments are prioritised. comparing the level of costs to that quoted by other pension providers. As an IGC, we wanted to know why this was the case. Level of transaction costs Although it’s relatively easy for you to invest in a There are different ways in which transaction fund, there is a lot going on behind the scenes costs can be measured, and consensus has for a manager to meet the fund’s objectives. been reached across the industry on an Shares are bought and sold, for example, approach that should be used. Among other and this is where transaction costs come in. things, this approach includes measuring They can be made up of several elements. ‘slippage cost’, which is the implicit cost resulting from the difference between the Costs such as broker fees, commission costs market price when an order is placed and the and stamp duty are specific and easy to eventual execution price. identify. ‘Slippage’ or ‘swing pricing’ refers to any change in price that may happen The availability of the data that we need between placing a trade and actually carrying investment managers to send us so that we can it out. This can be much harder to quantify. calculate slippage costs has not been as good as it should be, but it is gradually improving. As we indicated in last year’s report, the Financial Conduct Authority (FCA) now demands far more transparency around these costs. It requires all investment managers to provide the detail of these costs to trustees, plan managers and IGCs, so they can share the information with you. IGC Report 2020 13
When Fidelity investigated the issue, they This is work in progress and we expect that over Costs and charges found that the higher costs were largely the coming year we will see further changes due to the way slippage costs were being as a result of the FCA’s recent clarification calculated for futures (Futures are financial of its policies. We welcome these changes contracts committing a buyer to purchase an and believe they will help pave the way for asset or the seller to sell an asset and have a a more meaningful comparison of funds’ predetermined future date and price), which transaction costs. accounted for a relatively high proportion of the assets in this particular fund. In this Fidelity has now provided updated figures case, slippage for futures was calculated by for FutureWise transaction costs, which are comparing execution price to the market price based on your age. This is because the from the previous day. Given the significant asset allocation changes, through the use difference in time, market movements had of different funds, as you progress through distorted the slippage values, which in reality, your working life and invest in FutureWise. were minimal. These costs have been calculated as at December 2019 and assume you retire at 65. Fidelity also found that some investment managers were using different calculation Age Transaction In £ and methods for such assets. As a result, they cost pence have recalculated the transaction costs on Up to age 47 0.03% 3p per £100 FutureWise, and we are pleased that this has invested produced more comparable figures, making it 55 0.03% 3p per £100 easier for members to compare our costs and invested charges with those on other pension plans. 65 0.03% 3p per £100 As an IGC, we are comfortable with the invested analysis that has been undertaken on this Source: Fidelity, February 2020 issue but recognise there is still more work to be done to assess value for money across all funds. We appreciate that fund managers are FutureWise is a default investment strategy going through a period of establishing how that puts a member’s pension pot into a they can provide accurate transaction costs range of appropriate funds during their for a range of assets, while complying with the working life. Fidelity has also provided figures FCA’s regulations. for the transaction costs of the funds used in FutureWise. These are a mix of actively and passively managed funds. FutureWise fund Asset class Aggregate transaction cost In £ and pence Fidelity FutureWise Passively managed 0.03% 3p per £100 invested Equity Fund equity funds Fidelity Diversified Actively managed 0.02% 2p per £100 invested Markets Fund multi-asset funds Fidelity UK Actively managed 0.06% 6p per £100 invested Aggregate Bond bond funds Fund Fidelity Cash Cash funds 0.00% N/A Pensions Fund Source: Fidelity, February 2020 14 IGC Report 2020
All these aggregate transaction cost figures are Transaction costs for other funds Costs and charges either in line with or below the average for their Although some fund managers are still asset class, with the exception of the Fidelity struggling to provide usable transaction cost FutureWise Equity Fund which is marginally data, there are enough now doing it for us to above the average transaction cost. Based carry out an initial analysis of the self-select on this analysis from a third-party review, we funds offered on the platform. We have split believe the transaction costs for the funds the funds by asset class (such as equity, bonds used in the FutureWise strategy are reasonable and cash) as well as management style, so we compared with their peer group in the wider can give you more detailed information. Just market. We will be working with Fidelity on a to note, in the table below, 0.01% is the same as framework for assessing transaction costs over 1p per £100 invested. the coming year. Transaction cost range 0.01% is the same as 1p per £100 invested. Asset class Coverage Average 0.5% (number aggregate 0.25% 0.5% of funds) transaction cost figures Actively managed 59 0.26% 18 16 17 8 equity funds Passively managed 51 0.02% 48 3 0 0 equity funds Actively managed 15 0.07% 10 5 0 0 fixed income funds Passively managed 12 0.02% 12 0 0 0 fixed income funds Actively managed 27 0.17% 14 5 7 1 multi-asset funds Passive mixed asset 6 0.05% 5 1 0 0 Property 2 0.05% 2 0 0 0 Cash funds 7 0.00% 7 0 0 0 Source: Fidelity, February 2020 Our analysis covers 179 funds from 26 different managers on the platform. As you can see, there is a relatively large difference between different asset classes and management styles. We will be working with Fidelity to assess the value for money provided by transaction costs for 2020. IGC Report 2020 15
Customer Experience Customer experience We want you to be happy with your interactions with Fidelity, whether they are by letter, email or telephone. This builds trust, which can encourage you to continue saving with Fidelity – or maybe even increase your rate of savings. Remember, higher savings generally mean better retirement outcomes for you! What we look for: Helping you make decisions Clear and understandable communications Partly met and plan for retirement Administration quality, Ease of administration Met accuracy, and timeliness Accurate administration and reporting Met Net Promoter Score (NPS) Met Contact points for members Online tools Partly met and account accessibility Phone support Met Overall conclusion We have observed that Fidelity has a strong customer focus. Service levels are generally good, with steady improvements in the areas that had previously been identified as somewhat weaker. That said, we do feel there is more it can do in the education and engagement area of communications, and Fidelity has several innovations under development to watch. Fidelity continues to work on improving its services, based on feedback from members, employers, pension professionals and the IGC. We believe that overall Fidelity has met our expectations in this area. 16 IGC Report 2020
Helping you make decisions and Technological change Customer Experience With so many members working remotely or plan for retirement flexibly, Fidelity continues to innovate, so it We recognise there is still work to be done can ensure all members receive the same on developing communications that are level of information in a way that suits their timely, relevant to your needs and provided circumstances. For example, the augmented in a media that will engage you. Fidelity is reality function in the Your Plan Explained and working on a number of projects to improve Key Features documents provides a popular communication and engagement tools, so it three-minute video – accessible by phone – can make sure its communications are clear that highlights the key elements of a member’s and engaging. We have highlighted some of pension booklet. these projects below. Fidelity is looking to use digital technology Timely and relevant communications in other ways during 2020. In particular, it We expect Fidelity to provide you with clear, will be targeting members who rarely have concise and relevant communications and access to PCs during their working day by support, when you need it. This year, we have using technology accessed from their smart been working with Fidelity to improve the phone. In another example, it successfully ran a information it provides around making an virtual reality pilot last year which encouraged informed choice about how much you should people to use Fidelity’s Power of Small Amounts be saving and how to manage your finances in tool and it will be rolling this out more widely a joined-up way. this year Fidelity has a new initiative, Workplace Fidelity is also looking at using QR codes Workout, which sends communications in 2020, as these can offer an easy way to relevant to your personal situation, based on direct members to further information or specific life events or decisions you have made. educational materials. We will assess its success However, we are disappointed about how in future reports. slowly this initiative has been rolled out and we have raised this with Fidelity. We will continue Accessibility to monitor progress, as we believe it can really We raised the topic of information accessibility help you understand your options when you in last year’s report. Documents are available retire, as well as what you might need to do to in large print or braille versions on request, make sure you have the kind of retirement you and all of Fidelity’s videos produced in 2019 want. We will also keep an eye on the take- include subtitles. It is also adding subtitles up of the programme and how quickly email to their existing video catalogue. Member addresses are collected for members. feedback told us that some of Fidelity’s letters to members were not easy to understand, so it has started a review of the communications it sends out when a member makes a change to their account or holdings, with the aim of improving the quality. This project will take some time and we will be keeping a close watch on it, so we can ensure it makes progress and delivers a better experience for members. IGC Report 2020 17
Administration quality, accuracy We have spoken at length with Fidelity about Customer Experience the work being undertaken and made clear and timeliness that we do not want an indefinite deferral We believe that you must receive timely of the external audit. While we understand and accurate information in order to make Fidelity’s approach and position, we believe informed decisions about your pension. this is an important facet of good governance, As a result, we have been keeping a close so we will keep it on our agenda. We have watch on service levels, particularly as there asked for, and Fidelity has committed to were some issues last year, and we are providing us with, regular updates on the continuing to press Fidelity to agree to an progress of the programme. external audit of administration processes. We have also reviewed complaints received Complaints update throughout the year, so we can assess Fidelity’s Member issues or complaints must be dealt performance fully. with quickly, proactively, professionally and empathetically. When this happens, it can Service levels improve people’s confidence in Fidelity and As we reported last year, Fidelity had been their own pension plans. facing some challenges over the volume of work received, but it had generally improved Since the last report, Fidelity has moved its service levels during the preceding year. its complaints on to an industry-leading The exception was the provision of retirement complaints management system. This means quotations, where a further increase in it can track and monitor any complaints demand was still causing some difficulty. received and give feedback to the relevant teams. In turn, this is expected to lead to a This general improvement in service levels better member experience, as the feedback is continued in 2019 and, in particular, the used to refine its processes. delivery of retirement packs reached the expected service level in May 2019 Thanks to this work, the continued good and has broadly remained there since service levels and a rise in automation that then. We will continue to monitor service reduces risk and increases accuracy, we levels closely and we welcome the further are pleased to report that the number of automation of processes to reduce risk and complaints has reduced from 0.7% in 2018 improve accuracy. to 0.5% of total membership in 2019. We will continue to monitor the level of complaints and External audit of administration processes how quickly they are resolved in our ongoing We asked Fidelity to consider an external audit assessment of Fidelity. of administration processes. While Fidelity is continuing its programme of investment in technology and automation, having reviewed our written request, it has deferred a decision until the end of 2020. 18 IGC Report 2020
Net Promotor Score (NPS) employer feedback to comprehensive changes Customer Experience Fidelity uses NPS, a globally recognised in products, services and delivery (based on independent feedback methodology, to the aggregate feedback from all responses). measure loyalty and use customer feedback. The score relates to a member’s or employer’s With NPS, Fidelity can gauge how members overall experience with Fidelity. They are asked and employers rate their relationship – and the how likely they are to recommend Fidelity as a scores are regularly shared with us. company on a 0 to 10 scale, where 0 is “not at When getting employers’ views, a number of all likely” and 10 is “extremely likely”. contacts for each employer receive personal Responses are combined to calculate invitation emails with a link to the short online the Net Promoter Score, using the process questionnaire. This makes it possible to gather below. People are also asked for wider a broad range of responses. For members’ feedback on the relationship, including their views, people are invited to contribute two satisfaction with the service and the telephone weeks after they have contacted Fidelity’s representative. NPS plays a key role in Fidelity’s Service Centre. future developments, such as improving All feedback is carefully reviewed by Fidelity customer documentation, simplifying member and, where appropriate, acted on. This can journeys and reducing the time it takes to range from individual action plans based on process queries. DETRACTORS PASSIVES PROMOTERS 0 1 2 3 4 5 6 7 8 9 10 Net Promoter Score % Promotors % Detractors Member NPS (real-time reporting) Year 2017 2018 2019 Quarter Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 NPS +25 +27 +39 +41 +43 +46 +52 +50 +55 +57 +54 +54 Average NPS +33 +48 +55 Employer NPS (annual reporting) Year 2017 2018 2019 NPS +53 +51 +64 We recognise that Fidelity focuses on providing a positive experience for both members and employers, and we’re pleased that the scores have been rising each year. IGC Report 2020 19
Contact points for members and There is now a PlanViewer app for your Apple Customer Experience or Android smart phone. The log-in area gives account accessibility you personalised information, while retirement Online tools planning tools can help you see if your PlanViewer is Fidelity’s online member portal. savings are on track for your retirement goals. Members told us that they were finding it difficult An in-app browser then allows you to use the to access PlanViewer, so Fidelity has upgraded full PlanViewer suite, so you can do things such the login process to make it simpler and more as changing your investments. Fidelity will be secure. PlanViewer now uses market-leading telling members about this app during 2020. security, including two-factor authentication and one-time passcodes (OTP) that can be sent Phone support to email addresses or through text messages. We have received positive feedback on the support provided by Fidelity’s pension service There were some teething problems when centre which receives queries from members. the new process was rolled out, but they were We believe that providing strong phone resolved quickly and Fidelity continues to support remains important alongside other develop the service. We believe this change engagement tools. has helped members, as PlanViewer access increased by over 20% in the last year. There Vulnerable customers are now around 40,000 people logging on We believe the way Fidelity treats all its each month. We are looking at other ways to customers is really important, but this is encourage members to log into PlanViewer. particularly key for those who are vulnerable. Fidelity has an established vulnerable Another advantage to upgrading the customer policy, but it continues to enhance PlanViewer login process is that the new its approach in line with developments in this security authentication process requires a area. For example, it recently explored how personal email address, which means Fidelity the policy is working in reality and is now can do more to communicate digitally. planning ways to strengthen its approach. This isn’t just good news from a sustainable, Developments will be shared with us in 2020, environmental perspective. It means Fidelity which we will evaluate and then tell you about is more able to stay in touch with you if you in our 2021 report. move house, which is good from a retirement N outcomes perspective. Your broader financial picture In our 2019 Report, we looked at how Fidelity Fidelity’s next generation of PlanViewer includes has been developing its financial wellness better navigation, making it easier for you to capabilities through initiatives such as its find what you need, with responsive pages Personal Money Check Up and Retirement Savings for mobile and tablet viewing, improved core rules of thumb and tools. journeys and new online transfer capabilities. Future phases will then add even more Fidelity is now working on the next generation functionality. There is clearly more to do and we of financial wellness guidance, which will introduce look forward to seeing these developments. the Fidelity Financial Wellness Score. This will cover all four areas of financial wellness PlanViewer also contains a number of tools – planning; budgeting, debt and spending; saving to help with retirement planning. It will soon and investing; and protecting. include a real-time retirement projection tool that provides a potential retirement value The score will help you benchmark your based on current contribution levels and financial wellness, so you can see if you need investment choices. This will be updated daily to take action. It will also help you explore the effect and automatically presented to you every that a change you make now could time you log-on. The information is shown in have on your retirement savings. We recognise that today’s terms, so you can see how it compares pension saving is part of your wider with current income and possible needs in financial planning and hope you will find this retirement – and easily spot any income gap or tool valuable, as it can help you understand topics excess. We will monitor member feedback and across the financial spectrum. usage of these tools to review the impact they are having on the understanding of expected retirement outcomes. 20 IGC Report 2020
I mproving Improving inputs for better retirement outcomes inputs for better retirement outcomes The money you receive from your pension pot in retirement will reflect your contributions and the decisions you make. We expect Fidelity to provide you with the tools you need to plan and manage your retirement savings effectively. It must also have systems and processes that are not just robust, but easy for you to use and follow. What we look for: Education Likelihood that members will get back on retirement at Met least as much as they put in Tax relief on contributions Partly met Engaged Employer pays in as much as members do Met employers Easy to change the amount paid in Partly met Systems Easy to transfer old pensions into the current pension pot Met Flexible options for how to take pension income Partly met Overall We are satisfied that Fidelity has adequate protections in place against the risk of the value of your investments falling, and while there are never any guarantees, FutureWise is structured to reduce risk as members get older. Its performance is covered in more detail in the Investment Strategy section, but it is performing in line with expectations. That said, Fidelity has more to do around education, as we want it to ensure members understand how tax relief contributes to their pension pot. We would also like it to do more in updating the functionality and ease of use of its systems, including progress in the ease of changing contribution levels. We believe Fidelity has partly met our expectations in this area. IGC Report 2020 21
Education Systems Improving inputs for better retirement outcomes In last year’s report, we explained that Ease of bringing in other pension pots we were working with Fidelity to improve In the past, if you wanted to transfer an old the educational information available to pension pot into your current employer’s members. We expected there to be a mix of pension plan, you had to complete a suite new media content to help you understand the of application forms and supply various value of tax relief in pension contributions and other pieces of documentation. We received the security of your pension during uncertain feedback that this process was frustrating market conditions. for members. Fidelity has advised us that these pieces will Fidelity has worked to improve and streamline be available in the middle of this year, but we this process, as it observed that almost half are disappointed progress has not been faster. of members began their transfer process We will continue to discuss it with Fidelity and by visiting PlanViewer to download a form ask that delivery is brought forward as much or calling the service centre to request this as possible. form. It has now upgraded its systems to move the transfer process online, which includes Engaged employers automated communication with other pension providers. This makes it much faster, with many The level of contributions made to your transfers finishing in around five days. retirement savings is a key part of the retirement income you could receive. We think it’s important that you, and all members, can bring together pension pots Employer contributions with ease, as it can help everyone manage The level of contributions both employers and access their retirement savings. It’s very and members make helps members to fund helpful that this process has been reviewed, their future retirement. Fidelity can provide strengthened and made easier to follow. employers with benchmarking which may indicate whether their employees’ average Flexible options for how to take contribution rates are below those of their pension income peers. Fidelity then works with the employer The Financial Conduct Authority (FCA) to assist with solutions such as targeted has been taking a close look at retirement member communication. outcomes since 2015 and it has made new rules requiring non-advised members to be Ease of changing contribution rates offered four ‘Investment Pathways’ when Currently, Fidelity’s PlanViewer can allow starting income drawdown. These pathways you to adjust your contribution rates, if your must be in place by August 2020. employer’s internal systems don’t offer this. However, many employers decide not to We want to ensure that members are use this functionality, because they manage supported at this crucial time. As a result, we their benefit structures via other platforms. will be working with Fidelity to offer simple, We believe this functionality should be objective-based investment options when available to all members via PlanViewer so entering drawdown or taking cash, so you can we are asking Fidelity to talk to all employers make better investment choices. This will be about this, as we believe that being unable integrated into Fidelity’s retirement journeys. to increase contributions via PlanViewer, or having to do so via another external tool, In addition, Fidelity is developing the capability could be a barrier to members making positive to allow members to take a regular income changes to their contributions. We will keep in retirement from an existing account these developments under review and report through income drawdown (from September back on progress in 2021. 2020) without having to transfer to a new arrangement. We are monitoring progress on investment pathways and the retirement support provided around them. It will then form part of our Value-for-Money assessment in 2021. 22 IGC Report 2020
Security Security We review the controls and safeguards that Fidelity has in place to monitor the security of your investments and manage any operational risk. As a reputable and financially strong pension provider, Fidelity must also demonstrate how it keeps your personal information secure. What we look for: Asset security Controls and safeguards Met Liquidity Met Data security Data security Met Reputation A reputable, financially strong pension provider Met Overall conclusion We believe Fidelity has robust procedures in place to understand and manage operational risks, and we are updated on the current strategic direction every year by Fidelity. We have also visited Fidelity’s cyber security team and been reassured by the work they undertake. We have no concerns around Fidelity’s strength, and are convinced that its continued investment in the business means it will be a long-term player in the pensions provider market. We believe that Fidelity has met our expectations in this area. IGC Report 2020 23
Asset security We have observed that FIL Life appoints and Security monitors fund providers with care. For all fund Many things in life involve risk of some kind and providers, Fidelity assesses: this includes saving for a pension. There is the risk you may not save enough by retirement to • how they meet the regulations that exist to take care of your needs, or that the funds you protect you choose don’t perform as you hope they will. • their governance procedures • the internal controls they have in place There is also the risk of exceptional events, such • their financial strength as losing money because of the bankruptcy • the performance of their funds in or negligence of a fund provider. While the comparison to benchmarks and similar funds chances of this happening are very low, and regulatory bodies have protections in place to This assessment happens before Fidelity reduce the risk even further, you do still need decides to appoint a fund provider and then to understand it and what Fidelity does to help continues on an ongoing basis. Fund providers protect your savings against it. must sign agreements to stick to specific investment criteria and supply Fidelity with ongoing information and support. Fidelity Fidelity and the fund providers available in monitors their operational effectiveness and if it your pension plan are regulated in the UK by identifies areas for improvement, it has a clear the Financial Conduct Authority (FCA) and the process in place to raise it with them and work Prudential Regulation Authority (PRA). These towards making those improvements. organisations set out the rules that Fidelity must operate under and the ways it must manage If one of these fund providers or Fidelity lost the investments of pension plans. To protect part or all of the money invested in one or more our members’ money, there are strict rules of their funds because of an exceptional event, that govern Fidelity’s financial soundness, and your pension account was invested in and the systems and controls used to protect the affected Fidelity fund(s), the value of your your investments. investment in that fund would fall. The value of your pension account would be adjusted to These regulatory bodies have many powers, take account of any losses. If the exceptional including the ability to inspect Fidelity’s event was severe enough, you could lose operations and risk controls. Fidelity also some or all of the money you had invested in has to report regularly to the PRA on their that fund. financial strength. Once again, while the chances of this There are different types of underlying happening are very low, and regulatory bodies investment funds, so they operate, and are have protections in place to reduce the risk regulated, in different ways. For example, if the even further, Fidelity would pursue the fund manager of some funds became insolvent, the provider or appointed receiver (the person assets would be protected, because regulations responsible when a company becomes require them to be held by an independent insolvent) for the full amount owed. However, custodian separate from the fund provider. Fidelity cannot guarantee the amount you received back. The UK Financial Services Compensation Scheme (FSCS) is an independent body set up by the Government and funded by the financial services industry. It pays compensation when it’s satisfied that an insolvent fund provider can’t pay the claims against it. In certain circumstances, you may be entitled to compensation from the FSCS. 24 IGC Report 2020
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