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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