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Viewpoint COUNTDOWN TO The official journal of the Pensions and Lifetime Savings Association CONFERENCE: Issue 3 2020 OUR FLAGSHIP EVENT GOES VIRTUAL THE CHILDREN’S SOCIETY PENSIONS EXCELLENCE SUPERFUNDS IN FOCUS RETHINKING RETIREMENT DECISION-MAKING PENSIONS TAX RELIEF: GOLDEN GOOSE OR SITTING DUCK?
PROVIDING LONG TERM SECURITY The purpose of Pension Insurance Corporation plc (“PIC”) is to pay the pensions of its current and future policyholders. PIC provides secure and stable pensions through providing pension risk transfer solutions backed by leading customer service, comprehensive risk management and excellence in NEW LIABILITIES INSURED (HY 2020) asset and liability management. As of 30 June 2020, PIC has insured 237,600 £3.5 BILLION pension scheme members, backed by £47.7 billion of investments. Clients of PIC include FTSE 100 companies, ASSETS UNDER MANAGEMENT (HY 2020) multinationals and the public sector. For more information, £47.7 BILLION please visit www.pensioncorporation.com or call 0207 105 2000. Pension Insurance Corporation plc is registered in England and Wales under registration number 05706720. It is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority (FRN 454345). Its registered office is at Cornhill, London EC3V 3ND.
Contents C CONTENTS 04 06 09 08 10 CEO’S VIEWPOINT ANNUAL CONFERENCE POLICY IN PRACTICE SUPPORTING PENSIONS STEWARDSHIP TAX RELIEF NEW WAYS TO THRIVE 2020: PENSIONS, ECONOMY, PLSA RESPONSES NEW NOVOTING GOLDENGUIDELINES GOOSE SOCIETY 13 16 TERRY RITCHIE RETIREMENT SAVINGS TRUSTEE TRAINING TIME FOR A RETHINK PRIORITIES 18 22 FINANCIAL WELLBEING SURVEYING THE 20 10 PLSA Team: Maggie Williams, Editor A LIFELONG GOAL SUPERFUNDS Tel: 07876 823 716 Email: maggie.j.williams@googlemail.com Twitter: @mrsmaggiew Edward Bogira Tel: +44 (0)20 7601 1733 Email: edward.bogira@plsa.co.uk 27 31 34 Design arc-cs ltd www.arc-cs.com Advertising MEET THE MEMBER THE PENSIONS REGULATOR CEO NETWORK Adrian Messina Tel: +44 (0)20 7601 1722 HEIDI CATHERALL EMPLOYERS, SAVERS AND A NEW PLSA GROUP Email: adrian.messina@plsa.co.uk COVID-19 Claire Simmons Tel: +44 (0)20 7601 1735 Email: Claire Simmons ISSN 2398-7626 36 38 45 40 © Pensions and Lifetime Savings Association 2020. All rights reserved. Published by the Pensions and Lifetime Savings Association, a company registered THE CHILDREN’S SOCIETY A DIGITAL TOMORROW GENTLE GUIDANCE: TIME FOR A MORE in England and Wales. Company number PENSIONS EXCELLENCE PENSIONS AND MENTORING INCLUSIVEIN PENSIONS INDUSTRY 1130269. TECHNOLOGY 24 Chiswell Street London EC1Y 4TY The views expressed in this publication are not necessarily the views of the Pensions and Lifetime Savings Association. Viewpoint Issue 3 2020 3
C CEO’s Viewpoint CEO’S Viewpoint It’s a time of great change but the PLSA is working hard to meet the challenges, says Julian Mund AUTUMN IS ALWAYS A TIME OF CHANGE The theme of this year’s conference is how the pensions sector can prepare, invest and provide – AND NEVER MORE SO THAN THIS for the future, as the economy and our society YEAR. BACK TO SCHOOL FOR MANY, go through the most dramatic transformation in BACK TO THE OFFICE (OR NOT) FOR living memory. I’m looking forward to sharing with you some fascinating new research on the SOME, ANOTHER STEP FURTHER INTO evolution of workplace pensions in my WHAT CONTINUES TO BE THE UNKNOWN keynote address. FROM THE PERSPECTIVE OF COVID-19. I The world-class programme will cover HOPE YOU, YOUR FRIENDS AND FAMILY everything from investing for good, which continues to be an important theme, to Pension HAVE ALL STAYED SAFE AND WELL THIS Freedoms five years on. The global pandemic SUMMER. has shone a light on the challenge of providing 2020 has been an exceptionally difficult year financial wellbeing for savers and this will be for society, business and the pensions industry another key focus at conference. We’ll also alike. We have all faced new challenges and reveal new data and insight from the award- been forced to find new ways of working. winning Retirement Living Standards. Communications with savers worried about You can read a taster on these and other their future retirement, investment strategies conference sessions in this edition of Viewpoint. dealing with market shock, governance and administration carried out remotely and with PARADIGM SHIFT IN THE WAY a reduced workforce: these are just a few of the ORGANISATIONS WORK issues reported by PLSA members. Covid-19 has brought a digital revolution front and centre. We’re really excited to be embracing The PLSA has been extremely busy speaking to digital – a direction we believe the pensions our members, over video conference this year sector was taking anyway as shown by the rather than in person. While concerns remain launch of our brand new Tech Conference regarding interest rates and the employer later this year. covenant, it’s reassuring to hear that schemes have generally coped very well with the impact Technology has enabled us to continue doing of Covid-19. what we do best – bring people together. The remainder of our conferences this year will One aspect that has stood out is members’ be online, as will the first part of our trustee resilience and determination to continue training, which you can read more about in delivering the best possible outcomes for this issue. their schemes and pension savers. Here at the PLSA we’re continuing to work from JOIN US ONLINE FOR THE BIGGEST home, but we’re considering ways to capitalise EVENT IN PENSIONS on the benefits experienced during the world’s In July we announced that our events for the biggest and most successful home working rest of 2020 will be online, digital experiences, experiment. and that we aren’t planning to return to live events as we knew them until at least 2022. Across many sectors, like ours, there has been a huge emphasis placed on the wellbeing and This October the PLSA Annual Conference takes support of staff. The ability for employees to place online – the biggest pensions event in the work from home and personalise their daily UK. It will run over five shorter days instead routine can only be good from the perspective of the usual three, and will include all the of diversity and inclusion. networking opportunities you’ve come to expect, only this year with a digital twist. Learn about For the rest of this year there continues to be our networking tools and how the exhibition much uncertainty, many unknowns. I hope will work on the digital platform in our Digital you enjoy this issue of Viewpoint and Annual Conference Centre. Conference. But most importantly, stay safe. 4 Viewpoint Issue 3 2020
COST TRANSPARENCY INITIATIVE Open source and free to use, the Cost Transparency Initiative (CTI) templates are designed to help pension schemes understand and compare the cost of investment management.These templates and tools are free to download from www.plsa.co.uk. MARY USER SUM ARY v.1.0. USER SUMM MAIN AC INFORMA TION CO UNT TEMP 1. ACCOUNT LATE estor ACCOUN Client/Inv T LEVEL TE MPLATE v.1 er Portfolio issu 1. ACCOUNT .0. End INFORMA TION Fund Report per iod Start Client nam e PRIV ATE Currency of report Average val ue of Portfolio EQ identifier UITY e of client client hol Average valu ding holding Portfolio ACC Period of NT ACTIVITY issuer Orep Uort O INVESTME name NT LE V E Start: 2. PORTFOLI L TE M 1. AC value CO PLAT End: Start asset CurU NT E V.1 Portfolio Clien rep rency INFOof nam .0 share class e / R MA t/In ort TION End asset value vestor Portf olio issuer Purchases Fun nam d e Sales Portf olio 2. PORTF iden OLIO INV Repor tifyin (%) ESTMENT t per g dat FORMANCE ACTIVITY iod a ME NT GAIN / PER Base LL INVEST curr IMPLIE D OV ERA ency Curr of ac Star ency coun t of re t port Is th equities Listed e instrument inve fund wit Debt Pooled fun stmen derivatives h traded Exchange t per in it’s STS CTION CO derivatives Total OTC O TRANSA FX contrac Start asset iod? 3. PORTFOLI % instrument End Cash value assets Physical Yes/ markets Private 2. PO No s instrument End asset Other RTFO ds TEMPLATES INCLUDE: value LIO INVES TMEN ts Purchase T AC s s TIVIT Com Y URN (%) mitm s GROS S RET Sales ent % of tota The User Summary Inflows l com Start mitm asse ents Outflows t valu to fu End e nd The Main Account Template CHARGES asse 4. ONGOING t valu Paid e in ca Inve pital stor The Private Equity Sub-Template 3. PORTF OLIO TRA Distr from ’s Sh ement NSACTION Inve are* ibuti ment manag CO STS stor 4.1. Invest Explicit ons s to In tra nsactio vest n costs ors Transactio 3. PA Fun tration n ID / d 4.2. Adminis taxes DU E Coming soon, a preliminary Fiduciary 3.1 M TO TH a na E MA ge m NAG Brokernce e nt ER plia (Not tion & com commission Gross fees e: Exp ance, reg ula Management Template, look out for s man ense 4.3. Govern Tran agem ent fe s are show Transactio sactio e n as po n n an related ser vice sitive ns & client d oth further details. Other amou nicatio er fe nt n, commu ser vices rebat es off R ate s) 4.4 . Distributio es set (s % ee below Other exp ) licit 3.2. costs T to m ransa a na c tio 3.2 Implic ge r n transactio it and & othe Tran a mo r n costs sact unts fees pa ion fe offse id by 3.3 Indire Und es t p or ct er w ri tfoli transactio ting o n costs Mon fees itor in O ffse 3.4 Less: t% An g fees dilution offs ti- Direc Visit www.plsa.co.uk et tors’ fees Total Other fees tra nsact ion costs 3.3. Ca r r ied inte rest - Co mple te se c tio n6
F Feature ANNUAL CONFERENCE 2020 Rachel Pine looks forward to a flagship event with a big difference… WHEN OUR INDUSTRY LAST GATHERED, There were plenty of top-of-mind issues to future from a wide variety of perspectives. AT INVESTMENT CONFERENCE 2020 IN discuss at Annual Conference 2020 before With speakers including legendary political Covid ever reached our shores – the Pension broadcaster and publisher Andrew Neil on EDINBURGH IN MID-MARCH, NO ONE HAD Schemes Bill, the proposed DB funding code, our ‘New, new normal’ – the government, ANY IDEA THAT IT WAS TO BE THE LAST the pensions dashboards and an increasing Brexit and the American election; Money TIME A LARGE EVENT COULD BE CONVENED focus on climate, the environment and asset Saving Expert Martin Lewis, who’ll talk FOR THE FORESEEABLE FUTURE. OVER stewardship for schemes. If anything, the to us about his views on how the British THE COURSE OF THE CONFERENCE AND unfolding news over these past months public view their pension savings; and THE DAYS IMMEDIATELY FOLLOWING, THE has solidified the inextricable relationship David Olusoga, the noted historian and CORONAVIRUS MOVED FROM DISTANT between the economy, society and pensions broadcaster, discussing what history can tell – every single industry and employer has us about our potential future and the deeper THREAT TO IN-PERSON REALITY, WITH THE been impacted, and therefore every pension meaning behind the recent focus on societal UK’S LOCKDOWN FOLLOWING JUST scheme and fund. With many policy issues inclusion; our programme looks to engage, DAYS LATER. to cover, investment strategies to examine enlighten and inform the bigger picture. and ideas to share, at the heart of the AC20 And while there is no single industry that Guy Opperman, the Minister for Pensions, programme is the irrefutable fact that has been unchanged by the pandemic, the addresses the conference live on Wednesday the UK’s pensions industry has much to pensions sector – encompassing every single morning, giving us the latest on his priorities contribute to provide a safe and just future employer in the nation and nearly every and the Pension Schemes Bill, and we’ll for our society. working-age adult – is certainly central discuss the results of our ‘Facing the Future’ to the economic issues of the day, and will What you’ll see over the five days of the survey – research work in which many of you remain so in the coming months and years conference is our continued commitment to participated – with him. Charles Counsell, as we move toward recovery. questioning, examining and picturing that chief executive of The Pensions Regulator, is 6 Viewpoint Issue 3 2020
Feature F on hand to talk about what TPR has in store for schemes, for superfunds and for overall supervision. Over the days of the conference we will be presenting information on a raft of topics, including new ways to increase saver engagement, our latest thinking on DC decumulation, an update on the Retirement Living Standards, battling pension scams (featuring Stephen Timms MP, chair of the Work & Pensions Committee), new solutions to the not-small issue of small pots, and a presentation on our own Investing For RETIREMENT LIVING STANDARDS: ONE YEAR ON, Good work, which gets under the bonnet of schemes’ thinking about climate change, and TWO AWARDS climate-positive investing. We have a debate We’re delighted that the PLSA’s Retirement Living Standards campaign, on pensions tax relief where you’ll be able to launched at our Annual Conference 2019, has won two industry awards share your views, too, and let us know which this year: side of this contentious issue you’re on. Headlinemoney Our leap into digital started off slowly, Headlinemoney Awards 2020: Thought Leadership Initiative of the Year gathering momentum as we fully redesigned Annual Conference into a five-day online PIPA event brimming with ways for attendees to engage with content, speakers and sponsors. Pensions and Investment Provider Awards (PIPA) 2020: Innovation of We remain committed to providing up-to- the Year the-minute content on our industry to all of our fund and business members, at a time “Entries to the category demonstrated that the pensions industry is when disaggregation rules the day. catching up with the rest of financial services in its commitment to customer services and embrace of technology,” said PIPA. It described Retirement Living Standards as “A cross-industry effort…the standards translate desires and expectations about quality of life in retirement into a financial cost, helping savers to set achievable targets.” Throughout the conference we invite you “WHEN WE SET ABOUT LAUNCHING OUR RETIREMENT to get involved – take polls, play the digital game that’s part of the exhibition, chat with LIVING STANDARDS WE WANTED IT TO RESONATE WITH our session ‘whips’ in the chatbox that runs BOTH THE INDUSTRY AND SAVERS, AND THROUGH alongside every session, visit the sponsors in the networking channels and keep letting us A WELL-MANAGED AND PRECISE PR CAMPAIGN WE know your thoughts about the issues of the MANAGED TO GET THE TONE OF THE MESSAGE JUST day, and how this new way of meeting feels to you. RIGHT. I’D LIKE TO CONGRATULATE EACH AND EVERY ONE While we hope to be able to meet again in OF THE TEAM WHO MADE THIS LAUNCH A HUGE SUCCESS person in the very near future, the positives of the digital conference are difficult AND THANK THEM ALL FOR THEIR TIRELESS EFFORTS to ignore. We’ve broken our record of AND SLEEPLESS NIGHTS.” participating schemes this year, with 283 schemes registering, up from our previous Julian Mund, CEO, PLSA record of 226, a 25% increase in the number of schemes attending. We have 472 people attending who’ve not attended for at least the past three years and we are excited to welcome them back. The carbon footprint of the conference, without the travel, accommodation and shipping of stands, is much lower and this is an important MORE INFORMATION: consideration. It is likely that we will https://headlinemoneyawards.co.uk/headlinemoney-thoughtleadership-oty continue to include a digital element to many of our conferences in the future. content.yudu.com/web/43wcl/0A43wm7/PE-Pipa-App-Aug2020/html/ index.html?page=76&origin=reader See you on the other side! Viewpoint Issue 3 2020 7
F Feature Supporting you and your clients Our workplace solutions are designed to give control and flexibility, helping members feel confident to make the right choices for their financial future. With high-quality service and guidance at every step of the way, we support you and your clients in the moments that matter. Find out more at standardlifeworkplace.co.uk/employer/covid-19.page Standard Life Assurance Limited is owned by the Phoenix Group and uses the Standard Life brand under licence from the Standard Life Aberdeen Group. You can find more information about Standard Life Aberdeen plc’s strategic partnership with Phoenix at www.standardlife.com/partnership Standard Life Assurance Limited is registered in Scotland (SC286833) at Standard Life House, 30 Lothian Road, Edinburgh EH1 2DH. Standard Life Assurance Limited is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. www.standardlife.co.uk 8 Viewpoint Issue 3 2020 GEN3174_A4 1020 © 2020 Standard Life Aberdeen, reproduced under licence. All rights reserved. STA1020305688-001
Article A POLICY IN Luisa Ciavucco runs down some of PRACTICE the recent releases from the PLSA CURRENT CIRCUMSTANCES AREN’T DATA STANDARDS: CALL FOR INPUT – out in their Statement of Investment STOPPING US FROM DELIVERING A BUSY PLSA RESPONSE Principles. POLICY AGENDA AND ACHIEVING THE BEST The Pensions Dashboard Programme has DC DECUMULATION CALL FOR EVIDENCE OUTCOMES WE CAN FOR OUR MEMBERS. TO made significant progress and its work KEEP YOU UP-TO-DATE WITH WHAT WE’VE on data standards illustrates this. It is This set out a new framework to support essential that appropriate data standards savers and schemes in the member BEEN WORKING ON, HERE ARE SOME OF OUR are released as soon as possible to journey towards retirement. Key KEY RECENT POLICY DOCUMENTS: allow pension schemes sufficient areas of focus included the statutory time to prepare the data they hold for obligation, scheme impact, product PLSA RESPONSE TO THE TREASURY onboarding. mix, the default, signposting, the role SELECT COMMITTEE CALL FOR EVIDENCE: of IGCs and member communications TAX AFTER CORONAVIRUS PLSA RESPONSE TO THE DWP CALL FOR and engagement. Look out for our Questions were asked about the level EVIDENCE: REVIEW OF THE DEFAULT recommendations soon. of taxation the economy can bear and FUND CHARGE CAP AND STANDARDISED long-term pressures for the tax base, as COST DISCLOSURE ENGAGING THE ENGAGERS: A PRACTICAL well as the role of tax reliefs in rebuilding The PLSA supports the current charge TOOLKIT FOR SCHEMES TO ACHIEVE the economy. We believe it’s essential cap but does not believe it should be EFFECTIVE STEWARDSHIP THROUGH that government continues to provide reduced. Including transaction costs as THEIR MANAGERS support and incentives to help people Our joint guidance with the Investor a component of the charge cap would save enough for retirement. Forum supports schemes in holding act as a barrier to enabling schemes to act in members’ best interests and their asset managers to account on PROTECTING PENSION SAVERS CALL FOR would limit investment options. We also engagement and stewardship issues. In EVIDENCE: PLSA RESPONSE discuss in this submission the proposed this toolkit, we’ve included suggestions The PLSA shares the Work and Pensions limitations on the flat fee structure and for schemes to ask their managers, Select Committee’s desire to stamp out cost transparency. and provided a broader framework for pension scams. In this response, we assessing stewardship and engagement discuss measures taken by regulators, JOINT TREASURY/UKSA CONSULTATION: approaches. industry and government to tackle REFORM TO RETAIL PRICES INDEX (RPI) pension scams. We define types of METHODOLOGY: PLSA RESPONSE GMP EQUALISATION MADE SIMPLE pension scam and mis-selling, and set This guide, sponsored by Equiniti, The joint consultation from the out recommendations for combatting covers the history, the methods and the government and UKSA sought views on scams and protecting savers. roadmap for the future to help trustees the alignment of RPI to CPIH, including among other things, the issue of timing. prepare for and begin their GMP DB FUNDING CODE – PLSA RESPONSE We understand that RPI is a flawed equalisation project, a complex and Our response to TPR’s first consultation measure of inflation and support plans to long-term undertaking with significant on its DB funding code of practice develop a more robust measure. implications for many DB schemes. supports the principles and believes its aims and objectives to be practical, PLSA IMPLEMENTATION STATEMENT with the two compliance routes – ‘Fast- GUIDANCE FOR TRUSTEES To find out more about any of the track’ and ‘Bespoke’ – able to help Our guidance and vote reporting topics above, visit our website at smaller schemes achieve compliance templates provide practical support https://www.plsa.co.uk/Policy- as efficiently as possible. How the code for trustees of both DB and DC/hybrid and-Research-Document- can be adequately applied in Fast- schemes around the production of their library#/by-title and keep up to track is complex and requires further new Implementation Statements, where date with PolicyWatch. consideration. trustees must disclose how they have followed the objectives and policies set Viewpoint Issue 3 2020 9
A Article PENSIONS TAX RELIEF: NO GOLDEN GOOSE With a hole in the nation’s finances, Nigel Peaple, director of policy and research, PLSA, warns against cutting imaginary ‘costs’ and finding illusory ‘savings’ THE CORONAVIRUS PANDEMIC HAS OPENED more likely than not that the employers In 2016, the PLSA undertook a research UP A SUBSTANTIAL HOLE IN THE BUDGET involved might make up some or all of the project that examined the likelihood that AS THE GOVERNMENT HAS PROVIDED VITAL resulting fall in take-home pay for the senior current workers would have a pension SUPPORT FOR BUSINESSES, PUBLIC SERVICES nurses, doctors and headteachers affected, equivalent to the pension targets identified AND INDIVIDUALS. THERE HAS BEEN MUCH especially if we’re still battling COVID-19. by the 2006 Pensions Commission. SPECULATION IN RECENT WEEKS ABOUT HOW Obviously, any additional funding would Using the Commission’s targets, the PLSA’s have to come from the public purse. THIS WILL BE PAID FOR, AND PENSIONS TAX research found that just over 50% of the RELIEF IS REPORTEDLY UNDER REVIEW BY Around 20% of the sum is tax not levied on working population, or 13.6 million people, CHANCELLOR RISHI SUNAK. employers who are making up the pension were at high risk of failing to meet their deficits in traditional final salary schemes. target replacement rate. Moreover, it is Speaking from a pensions perspective, we’d These contributions are generally used to the middle-aged savers of Generation X, prefer that government find some other way make sure pension promises, to former and today aged around 40 to 55, and the young to find the funds. But if the government does current employees for work done in the past, millennials, aged around 25 to 39, who are choose to raise them from pensions, we’d like are honoured. Amending this part of the most likely not to be saving enough. to emphasise that the amounts available are regime would simply add a tax on business less than often quoted and the consequences So the government should think very and make the pensions of millions of people less appealing. carefully before reducing the amount of less secure. support it provides for pension saving. Under the current rules, which are designed The remainder goes to the minority of people to incentivise people to lock money away for However, if the government is determined in the private sector that are contributing to their retirement, most savers pay no income to alter pensions tax relief, then we’d urge a final salary pension and the many millions tax on any earnings they contribute towards them to ensure that any change is primarily of others, nearly all in the private sector, a pension. However, apart from a 25% tax- designed to help people save enough for who have a money purchase or defined free lump sum, they do pay income tax when retirement. Ideally, any change would also be contribution pension. We estimate the they come to draw it. So the figures quoted simple to adopt and administer, and should total savings to government available from are not all that they seem. be sustainable over the long term. Everyone this part of pension saving is under half of knows that the current system is not perfect, It’s often said that pensions tax relief “costs” the £40 billion so often quoted – and, of so the pensions sector is open to considering the government about £40 billion a year. The course, the government would not want to how it can be improved. But let’s keep implication is that if the government changed remove all support from people saving for our eyes on the prize: everyone having an the rules on pensions tax relief, they could retirement. So the total “savings” for the adequate income in retirement. save a significant proportion of this sum of public purse will be far, far lower. money. The reality is far from this. Reducing fiscal support might be a About 40% of the amount is allocated to reasonable approach if people in the UK public sector pension schemes so, if the were already saving enough for retirement. government did reduce fiscal support, it’s However, this is not the case. This piece originally appeared in Understanding Pensions, a special report produced by Raconteur in association with the Sunday Times, THE GOVERNMENT SHOULD THINK on 27 September 2020. VERY CAREFULLY BEFORE REDUCING THE https://www.raconteur. net/report/understanding- AMOUNT OF SUPPORT IT PROVIDES FOR pensions-2020/ PENSION SAVING 10 Viewpoint Issue 3 2020
Feature F THANK YOU TO ALL OUR EDUCATION PARTNERS FOR THEIR SUPPORT IN 2020 VIA WEBINARS AND THOUGHT LEADERSHIP ARTICLES, OUR PARTNERS FOCUS ON THE HOT TOPICS OF THE DAY TO BRING YOU UP-TO-DATE INFORMATION AND SHINE A SPOTLIGHT ON ISSUES AND OPPORTUNITIES TO SUPPORT YOU IN YOUR ROLE. www.plsa.co.uk/Events-and-training/Education-partners Bloomberg focuses on technology Phoenix runs through investment & data solutions for portfolio oversight only platforms Caceis drills down into data and Russell Investments investigates custody governance fiduciary management Equiniti explores GMP equalisation UBP navigates impact investing R GRIDSERVE focuses on sustainable World Gold Council discusses the role energy infrastructure of gold in a pension fund portfolio For our full webinar schedule please visit www.plsa.co.uk Viewpoint Issue 3 2020 11
THE MEMBER BACKING PENSIONS AND LIFETIME SAVINGS ASSOCIATION TRUSTEE TRAINING PROGRAMME ONLINE TRAINING PART 1 - THE THEORY 4 & 5 November 2020 100% OF DELEGATES WOULD Our trustee training programme helps new RECOMMEND THE trustees and people interested in becoming a trustee COURSES TO A to understand their role and responsibilities and the COLLEAGUE challenges they’ll face. OVER TWO MORNINGS, YOU’LL LEARN ABOUT • Pension trustee duties, responsibilities and powers • How trustees protect themselves against legal challenge • Types of advisers and advice • How workplace pension schemes are financed and how they value their assets and liabilities • Investment strategies • Accountability and communication • Good pension scheme governance Find out more: www.plsa.co.uk
Interview I TRUSTEE TRAINING Terry Ritchie introduces a new virtual approach to training at the PLSA and beyond as he explains to Maggie Williams Q Q Q HOW HAS THE COVID-19 CRISIS AFFECTED WHAT ARE THE KEY TOPICS THAT WE’VE SEEN ACCREDITATION TRUSTEE TRAINING? TRUSTEES NEED TO LEARN ABOUT? INTRODUCED THIS YEAR FOR PROFESSIONAL TRUSTEES – SHOULD A A MEMBER-NOMINATED TRUSTEES ALSO BE We’ve all had to change our mindset over Most core subjects – such as the role of the REQUIRED TO HAVE A QUALIFICATION? the last few months as a result of the pandemic. Face-to-face training still isn’t trustee, legal considerations, actuarial, governance, and understanding the annual A practical or desirable at the moment, and report and accounts – remain the same as The Trustee Knowledge and Understanding the PLSA has been developing its trustee ever. programme from the Regulator is very training so that it can be delivered virtually. user-friendly, and provides a lot of sensible However, there will be new and updated guidance. That is augmented with CPD In the longer term, when work and travel directives from The Pensions Regulator requirements which trustees should be practices have stabilised, learners could (TPR) linked to many of these areas. For addressing as part of their role. have a choice between face-to-face and example, the need to publish DB schemes’ virtual methods, as both have different Statement of Investment Principles online Beyond that, a qualification might be a advantages. Face-to-face training brings is new this year, as well as the requirement step too far for many member-nominated benefits such as enabling presenters to to produce an Implementation Statement trustees, especially as the demands of observe delegates’ body language and gauge for both DB and DC schemes. The content the role are becoming ever-greater and their level of understanding. Tasks that of the SIP is also changing, to include TPR more vigilant. Pensions are always require collaborative working in a group, information on how schemes are addressing complicated, but with the overlay of the such as case studies, can also be delivered ESG issues and stewardship. Investment pandemic and other factors, there is already more easily in person. And, of course, you strategies are also coming under the so much for trustees to consider and learn won’t have a problem with your wi-fi signal microscope, with changes to the Defined as part of their role. dropping out! Benefit Funding Code on the horizon. However, virtual training can offer greater Another key issue for DB trustees is the flexibility – there’s minimal travelling employer covenant. Even seemingly strong time, and training can be delivered more covenants could be severely tested by the cost-effectively. It also means that we can effects of Covid-19 and ongoing uncertainty deliver information in bite-sized chunks. over Brexit. I have focused a lot on the Rather than packing everything into a covenant recently in my own trustee work, Trusteeship – part 1: single day course, we can divide up the and we’re likely to see more emphasis from the theory is available as an materials and have, for example, a session TPR on making sure trustees review the on legal requirements and actuarial work, strength of the covenant regularly. online course in 2020. then cover governance, investment matters, 7-8 October 2020 One key message that is applicable for all and annual reports and accounts on trustees is to make sure that they remain up 4-5 November 2020 another day. to date with the latest requirements from Delegates also have more control over TPR. Both new and experienced trustees Our follow-on courses, part 2: the accessing training at a time that suits need to make sure they stay on top of these, practice and part 3: the expert will them. As technology develops and we get and we’ll always include a session in our return in 2021 more comfortable with it, we’ll be able to training to recap on recent changes. All replicate even more parts of the face-to-face trustees should also make sure they keep https://www.plsa.co.uk/ experience online. their continuous professional development Events-and-training/Trustee- (CPD) up to date, reflect on whether their Training/ knowledge is sufficiently current, and ask themselves if there’s any additional training they need from their advisers. Viewpoint Issue 3 2020 13
A Article THREE WAYS TO IMPROVE COST TRANSPARENCY Samuel Condry, Policy Lead: Standards, has a trio of tips for trustees BE PREPARED TO CHALLENGE made with the wider context of value for the PLSA runs on behalf of the pensions money (VFM) firmly in mind. And when it industry, alongside its partner organisations PRIORITIES comes to VFM, things are heating up. the Investment Association (IA) and the As we’ve moved through the intervening Local Government Pension Scheme Advisory The FCA has an open consultation on Board (SAB). months since the start of lockdown, many proposals to strengthen IGCs’ obligations people’s priorities have naturally focused on to assess the ongoing VFM of workplace The CTI framework is an industry standard funding and investment risks – as well as pensions (CP20/9 ‘Driving value for money for institutional investment cost data – juggling the myriad tasks needed to provide in pensions’). The proposals include a three- developed by industry, for industry. The an uninterrupted service to pensions savers. pronged approach to VFM assessments, framework consists of several templates and In such a turbulent environment, it has been incorporating charges and costs, investment tools which enable asset owners to view all all too easy to lose sight of some of the more performance, and services provided their costs and charges in a consistent and ‘hidden’ priorities. Investment costs can (including member communications). comparable way. These are all free to use and, often be overlooked at the best of times – While the FCA is unlikely to become overly if you’re a trustee or IGC member, you can yet Covid has provided a real opportunity prescriptive in this space, it’s apparent use this information to get a full and detailed for schemes to reassess their priorities that IGCs will need to examine the moving understanding of your investment costs. and to find unturned stones to peer under. parts of investment performance and costs Gaining such a detailed view of investment Investment costs are certainly worth a closer together, and to some level of detail. costs will allow you to make meaningful look, as poor investment performance means Similarly, pensions trustees are likely to have comparisons across investment mandates their basis points-impact can be magnified equivalent new obligations imposed on them, and across your different managers just now. with The Pensions Regulator (TPR) and the (including where in-house and external As dividend payments and other investment Department for Work and Pensions (DWP) managers are employed); facilitating returns are expected to be squeezed further making it clear that they will be bringing changes or other recommendations where over the coming months, some of the most forward proposals. At time of writing, the appropriate. progressive pension funds have already been DWP has just published a consultation The CTI framework has the benefit of finding significant monetary savings through paper which details new requirements for compatibility, as it has been designed to be renewed scrutiny of investment costs, as well small scheme trustees (schemes with less easily harmonised with other regulatory as helping to exert downward pressure on than £100 million in total assets) to assess or reporting requirements, such as ILPA fees, renegotiating where appropriate. key elements of value, including investment or MiFID II. The framework has also been performance and charges. This is no If you’re a trustee, or a member of an incorporated into the services provided by bloodless process – trustees must proactively independent governance committee (IGC), the leading information providers (utilities) identify and recommend whether it might this autumn will be a key time to ensure in the marketplace, as well as the LGPS be in scheme members’ interests to move you keep investment costs on the meeting Transparency Code. to a larger scheme (or an authorised master agenda. You should challenge your advisers trust), which provides better value. Whichever approach you take to scrutinise and investment managers to justify any investment costs, it’s vital to have open priorities, and be prepared to push back if DIG OUT THOSE DETAILS conversations with your investment you feel costs and charges might have been managers and advisers about your A thorough assessment of investment costs unduly relegated or dropped off the agenda. requirements – help them to help you and and charges can be onerous, especially While the focus for pensions remains long- when time and resources are stretched make sure cost transparency is kept high on term, the link between how individuals by competing priorities. Collecting the the agenda. manage their money today, and how they necessary data can be time-consuming at build up savings for the future, is becoming best, even before you begin to wrestle with ever stronger – and ever more important to data quality and comparisons. Yet it’s just members. those areas of detail – such as incidental costs, administration costs, or governance- Further information about the CTI ALWAYS CONSIDER THE related costs – which can really add up to framework is available on the website: WIDER CONTEXT impact on the net return on investment www.plsa.co.uk/Policy-and- performance. Research-Investment-Cost- However, too great a focus on simply cutting Transparency-Initiative back costs comes with its own risks. Any This is where I want to plug the Cost assessment of investment costs should be Transparency Initiative (CTI), which 14 Viewpoint Issue 3 2020
Integrated thinking. Better outcomes. Our multi-disciplinary team advises on all types of covenant and funding solutions. Join Travers Smith Head of Pensions Daniel Gerring and Lincoln Pensions Managing Director Matthew Harrison at a joint Trustee Learning Zone session on Assessing Employer Covenant in Uncertain Times. Location: The PLSA Digital Annual Conference Date: Tuesday 13 October Time: 11.15am Visit www.plsa.co.uk for further details and registration. traverssmith.com
F Feature RETHINKING RETIREMENT DECI Lizzy Holliday, Head of DC, Master Trusts and Lifetime Saving at the PLSA, assesses current issues and attitudes THE PENSION FREEDOMS GAVE SAVERS fluctuations, and potential diminished savers from poor outcomes. But the current GREATER CHOICE ABOUT HOW TO ACCESS decision-making capabilities needed to system also presents a variety of operational, THEIR RETIREMENT SAVINGS. manage their retirement income. litigation, and other risks for schemes, which results in many choosing to provide minimal Prior to the reforms, 90% of pension pots In the five years since the introduction of support (signposting savers to Pension Wise moved into annuities in the decumulation the pension freedoms, several attempts to and providing pre-retirement ‘wake up’ phase. By June 2018 FCA reported that twice improve savers’ knowledge, understanding packs). Among these risks is how schemes as many pots were moving into drawdown and level of engagement have had limited navigate the line between guidance and than annuities, with 2019 figures suggesting success, and there’s clearly room for advice. the downward trend in annuity sales improvement in the ‘at-retirement’ processes has continued. The total value of flexible to better serve savers. THE PLSA’S DECUMULATION PROPOSAL withdrawals has risen steadily, and now The PLSA has, over the last few weeks, been According to research by the PLSA, nearly exceeds £35 billion. getting input from the industry, consumer three-quarters (71%) of savers in defined But a significant body of evidence shows contribution (DC) funds want support groups and other stakeholders on its the confusing range of options and risks is when deciding how to access their pension, new proposal to help improve retirement potentially leading to poor decision-making including some wanting to be guided by their outcomes. that’s affecting the adequacy of people’s pension scheme to a ready-made retirement income option. At the heart of the proposal is a call to retirement living standards. establish a new regulatory regime that will What’s more, the new array of choices shift Pension schemes want to support savers require pension schemes to support their a number of risks onto the individual in more effectively by improving the help they members when making decisions about retirement: the possibility of running out of get when they’re thinking about drawing how to access their pensions – including by money, ongoing exposure to stock market their pension and setting a path that protects offering or ‘signposting’ to products. The 16 Viewpoint Issue 3 2020
Feature F provides a crucial function in their decision- making. Advisers know their clients and can make the bewildering range of choices they face comprehensible. Our solution doesn’t rely on members taking advice, but it encourages members to seek out further guidance and advice, not just at the start of their retirement journey, but also in the planning phase and, increasingly, during a management phase in retirement. Many of our pension scheme members tell us that finding ways to introduce or provide access to professional financial advice on behalf of their members demonstrates that they are best in class, particularly so that they can take a holistic view across the multiple IN THE FIVE YEARS SINCE pots they may hold across different schemes, THE INTRODUCTION OF THE or different kinds of benefits (e.g. DB). PENSION FREEDOMS, SEVERAL Retirement processes should work for all – those who arrive at their decumulation ATTEMPTS TO IMPROVE SAVERS’ options with little knowledge, or who do not engage, as well as those who are confident KNOWLEDGE, UNDERSTANDING and have detailed plans. Together, pension AND LEVEL OF ENGAGEMENT schemes and advice have central roles to play to help people achieve better incomes in HAVE HAD LIMITED SUCCESS retirement. ISION-MAKING PLSA DC DECUMULATION CALL FOR EVIDENCE CLOSES The PLSA DC Decumulation Call for Evidence closed on 4 September. It set out a new framework to support savers and schemes in the member journey towards retirement. During the Call for Evidence period we had some great discussions with highly engaged participants – including seven roundtables (one proposed framework would entail minimum obligations to provide guidance and of which was a consumer-focused standards for member engagement and ‘signposting’ to retirement income products session), covering more than 50 communications, products and scheme might impact their operations. It also individuals representing more than governance in relation to decumulation. examines how greater choice has exacerbated 40 organisations. We have also These standards would help protect savers by some risks to savers – of making poor received over 20 considered written maintaining the quality of a scheme’s offer decisions, of outliving their savings, of responses. and providing a safety net to protect savers investments not meeting expectations. against the worst consequences of inaction. Key areas of focus have included the THE ROLE OF ADVICE statutory obligation, scheme impact, The proposed framework is designed to One recurring theme we’ve been hearing product mix, the default, signposting, support all savers, and protect people who during our consultation has been about the role of IGCs, and member don’t engage with or fully understand the the important role of professional financial communications and engagement. choices they face when they move towards advice in securing adequate retirement semi- or full retirement. incomes. We’re very grateful for all the The PLSA’s call for evidence paper places views you’ve shared with us and Our proposal to enable, encourage and contributions made during this time. this proposal in the context of the ongoing support pension schemes to signpost certain evolution of the broader pensions landscape: We intend to refine our proposals pathways or develop retirement products is the growth of DC saving and master trusts, over the course of the next few not intended to diminish the vital part an the future consolidation of funds and the weeks and publish our final adviser can play in helping savers with at- impending delivery of pensions dashboards. recommendations at the PLSA’s retirement decisions. It considers schemes’ responses to the virtual Annual Conference. pension freedoms, the development of Schemes can only provide so much support solutions, and how proposed future to their members. For many savers, advice Viewpoint Issue 3 2020 17
F Feature PLAN FOR THE FUTURE, LIVE FOR TODAY £ How can the pensions industry help people with their broader financial wellbeing? Maggie Williams reports FINANCIAL WELLBEING HAS BEEN A QUIET their financial health daily, and only 19% term savings, so that different approaches REVOLUTION IN WORKPLACE SAVINGS AND of respondents said they never worry about to financial wellbeing don’t play off against money. The research also showed that one of each other.” EMPLOYEE BENEFITS. ON THE SURFACE the greatest causes of concern is how to fund IT MIGHT LOOK LIKE A MARKETING BUZZ- retirement. According to Close Brothers, “The first thing we can do to help with PHRASE TO ENCOURAGE EMPLOYEES TO 31% of respondents cited this as their biggest financial wellbeing is to be an exceptional SAVE MORE INTO THEIR PENSION, BUT money worry. pensions industry, continuing to innovate UNDERNEATH IT REPRESENTS A MUCH and providing good quality pensions at the Pensions have an obvious role to play in lowest cost,” says Will Sandbrook, Executive DEEPER RECOGNITION ABOUT HOW WE making sure savers are on track for a healthy Director, Nest Insight. VIEW OUR RELATIONSHIP WITH MONEY, financial future. But should the pensions INCLUDING RETIREMENT SAVINGS. industry have a wider remit when it comes to However, Sandbrook believes schemes can financial wellbeing? help to create an integrated way of saving According to the Money and Pensions that takes account of both short-term Service, financial wellbeing is “feeling secure “I think it depends who you’re talking accessible savings and long-term retirement and in control. It is knowing that you can pay to,” says Brian Henderson, Director of pots: Nest has been carrying out a ‘sidecar the bills today, can deal with the unexpected, Consulting at Mercer. “For example, the savings’ trial to explore this principle. and are on track for a healthy financial trustees of an in-house pension scheme future.” “As fiduciaries of people’s longer-term have a fiduciary duty to provide pensions financial wellbeing, [pension schemes] However, studies have shown that for many and to focus on their scheme. But if you’re should make sure individuals are in a good there is a lot of work to do to achieve that looking at bundled pension provision, then position in the short term. In the US, where goal. Recent research from Close Brothers, I think there’s more of an obligation to look there has been more of a focus on short- Changing Trends in Financial Wellbeing, at the wider picture. You have to think about term emergency savings, the pensions showed that 21% of employees worry about an integrated approach to short- and long- industry has been front and centre. Pension THE FIRST THING WE CAN DO TO HELP WITH FINANCIAL WELLBEING IS TO BE AN EXCEPTIONAL PENSIONS INDUSTRY 18 Viewpoint Issue 3 2020
Feature F THE BEST WAY TO BE FINANCIALLY £ WELL FOR THE LONG TERM IS TO BE WELL IN THE SHORT TERM schemes have good payroll integration and a ‘jam jar’ for their future,” says Rimmer. contributions where affordability is a real communications, and that can be helpful “We can apply that same idea to short-term issue, until they can get back on their feet.” when working with employers to set up savings as well, so that there’s a jar for He adds: “People’s finances tend to be so initiatives like sidecar savings.” emergencies, for example.” fragmented. A further opportunity is to 21% Rimmer also says that using techniques help employees to see all their financial such as sidecar savings can help to create a information, simply presented, in one place balance between immediate financial needs, – and to provide them with accessible help and building up retirement adequacy. “The and support.” theory is that savers might have zero money in their sidecar pot at retirement. That’s Henderson says that this ‘helicopter view’ positive if it means they haven’t built up debt of an individual’s finances can be hugely that they still need to pay off after beneficial. “Sometimes it’s not about they retire.” big steps such as an increase in pension OF EMPLOYEES WORRY ABOUT contributions. It’s also the small details, such However, the ongoing effect of the Covid-19 as helping people to save money day to day, THEIR FINANCIAL HEALTH DAILY, pandemic could mean some tough financial which all add up.” AND ONLY 19% OF RESPONDENTS decisions for individuals as redundancies, SAID THEY NEVER WORRY cuts in working hours and pay reductions Rimmer adds that building good financial ABOUT MONEY. bite. “Before Covid-19, managing day-to- habits, such as budgeting, is another key day bills and unexpected costs was already aspect of financial wellbeing. “When you’re a challenge for many,” says Ruston Smith, used to creating a budget and knowing what non-executive chair of the Tesco Pension you can afford and what to cut back on, it Scheme and former chair of the PLSA. “With gives you a better idea of what you’ll need to Could pensions lose out if people become increased unemployment, reduced pay spend when you give up work to retire.” more focused on building up short-term savings? In principle, Craig Rimmer, Policy and difficulties through lockdown I expect “The best way to be financially well for the Lead, Master Trusts at the PLSA doesn’t family households will struggle even more – long term is to be well in the short term,” think so. “Auto-enrolment has been such perhaps forcing a choice between managing concludes Sandbrook. a success because it has enabled people to today and saving for tomorrow.” While the focus for pensions remains long- save more easily for retirement. And, while Smith suggests that there are ways that term, the link between how individuals inertia might have played a part early on, schemes, providers and government could manage their money today, and how they most people know where their money is help: “We could consider giving people build up savings for the future, is becoming going and choose not to stop it going into alternatives to simply opting out by allowing ever stronger – and ever more important to their pension. It’s helped them to create them to save less or suspend – not stop – members.
A Article How ESG can help build resilience in Buy and Maintain credit strategies Responsible investment has always been about the long term. Equity investors want to know a company isn’t vulnerable to global shifts around environmental or social issues and fixed income investors, looking to more distant horizons and might need to ensure a business can be part of a resilient strategy for the next 20 years. raw data covering more and resilience – and the puts environmental, than 7,200 companies in results are tangible, social and governance 100 countries to deliver not aspirational. (ESG) factors at its a simple score from Exclusions based on heart. It’s not for show 0-10. This is the first ESG quality have allowed – the integration of hurdle. We will not buy us to avoid exposure ESG decisively shapes a bond from a company to ratings downgrades allocations. We believe that scores below a 2, and bankruptcy and we this can help deliver or which falls foul of expect the effects of such long-term performance baseline exclusions. examples will be seen in enhancement for An ESG score, performance over time. institutional investors. however, only reveals We believe the impact The reason is simple. its true value when of ESG can be magnified Companies that can’t combined with a full as downgrades and adapt to new realities qualitative assessment. defaults emerge over the have never made for It is, for example, hugely years. We want to lend to great investments, and important to track scores companies that will be Lionel Pernias, as the world responds through time. Where we thriving, and delivering to climate and social see a company heading cashflows, 15 years from AXA IM Head of Buy and change, this is becoming up or down the scale, the now. Maintain, London more important. So how real investment driver is F do we make sure our knowing what lies behind or asset managers strategies are prepared? seeking to build the trajectory. Companies with an ESG The goal is such fixed Scores and more score above 2 still face sustainability income strategies, it’s ESG scores are a very all about culture. At useful part of our detailed scrutiny from and resilience – AXA IM, we believe process, but they are our credit analysts who take care to factor in ESG and the results our Buy & Maintain the starting point, not risks, working closely are tangible, not business benefits from the destination. Our credit analysis that proprietary system1 uses with our equity analysts. aspirational The goal is sustainability 20 Viewpoint Issue 3 2020
Changing markets company, there is more imperative. One highlights our thirst for This isn’t only about value to be gained from global name gained an practical innovation. Our strategic allocations, active engagement with allocation, not simply own guidelines5 allowed it’s also about staying management. In 2019, because it issued a Green for a €100m issue of relevant in changing alongside intense activity Bond, but because it this new type of debt, fixed income markets. in equity markets, we specifically earmarked which allows carbon- Our view is that asset engaged with close to funds for sales leasing intensive companies to managers who take ESG 40 debt-only issuers2. A on hybrids. This kind finance decarbonisation seriously have better nuanced understanding of verifiable data projects. We are now prospects for allocations of a company’s ESG encourages us to invest. leading industry efforts when debt comes to progress allows us to to ramp up this asset market. build a strategy that Growing markets class6. We also have more At AXA IM we have is sustainable from New markets have than £2bn of exposure seen more and more all angles. amplified the role of to social housing where evidence that allocations Our pension fund responsible investment. we selectively lend to are affected by and insurance clients We have sought a leading Housing Associations responsible investment need to see how we are role in the growth with clear social characteristics. Our addressing ESG concerns of Green and Social3 development strategies. experience is that banks with companies and bonds – debt designed When you take ESG will allocate more to so we have enhanced to directly address ESG seriously in fixed income, what they see as real, reporting of milestones issues, and which is opportunities can active, long-term money and results. Clients can often anchored in the UN emerge. As the market – to asset managers who receive a line-by-line Sustainable Development adapts to the realities are “seen as green”. A report, with a timeline Goals (SDGs). of climate change and reputation as a major of engagement steps and The SDGs give issuers a other ESG challenges, player in this space themes where we are useful way to pitch debt we believe it pays for can therefore offer a seeking improvement. to responsible investors. asset managers to hard-earned edge and Our team is always on But they do not remove embed true responsible influence the nature of hand to give deeper the need for scrutiny – in investment techniques issuance. The market insights, and our twice- fact, engagement can be in their allocation is also moving towards yearly Stewardship more intense to meet process. Just as we seek standardisation of how report gives details technical and disclosure out companies that stay ESG is reflected (most of every engagement requirements. It is crucial ahead of the curve, so obviously in Green and we make. to avoid ‘greenwashing’, asset managers have a Social bonds) and those One example has been where companies pay lip duty to be at the leading with strong systems have to push oil companies service to targets, and as a edge as the investment a potential advantage. to make ‘net-zero’ proud active investor our industry evolves. commitments on focus is on tracking how Footnotes emissions as we seek to money is actually used. 1 AXA IM: Our Scoring Methodology Our protect the long-term Again, reputation 2 AXA IM 2019 Stewardship report 3 Rise in Covid-19 bond issuance fans experience interests of clients by influencing the future of matters. AXA IM’s leadership in Green fears over ‘social washing’ Financial Times, 30 June, 2020 is that banks the energy industry. bonds helps shape the 4 4 AXA IM: Our Green Bond framework 5 IPE, 12 June 2019: AXA IM calls for will allocate AXA IM lends to one sector. This includes ‘transition bonds’ to help companies more… to asset go green oil major on the basis membership of the 6 ICMA Working Group on Climate of a 2050 net-zero Green Bonds Principles managers Transition Finance commitment. Deviation Executive Committee who are ‘seen from that path could where we have helped as green’ prompt a refusal to participate in new provide industry guidelines to improve issuance. Among transparency. Transparent carmakers, we favour Our role in the Once we secure an those trying to transition development of allocation from a ahead of the regulatory Transition bonds For Professional Clients only. Not to be relied upon by retail clients. This communication is for informational purposes only and does not constitute an offer to buy or sell any investments, products or services and should not be considered as a solicitation or as investment advice. This communication is issued in the UK by AXA Investment Managers UK Limited, which is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales No: 01431068. Registered Office: 155 Bishopsgate, London EC2M 3YD (to 31/12/20); 22 Bishopsgate, London EC2N 4BQ (from 01/01/21). © AXA Investment Managers 2020.
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