3.1 Investment Objectives
The Trustees’ primary objective is to act in the best interest of the members, and ensure that the obligations to beneficiaries of the Scheme can be met. In meeting this objective, the Trustees’ further objective is to reach a position such that in the long term the Scheme assets would be sufficient to buyout the members’ liabilities with an insurance company.
To control risk, the Trustees set the split between the Scheme’s growth and matching assets such that the expected return on the portfolio is expected to be sufficient to meet the Scheme’s long-term objectives. As the funding level improves, investments will be switched from growth assets into matching assets with the aim of reducing overall investment risk.
The Trustees recognise that a portfolio of bonds (or bond like instruments) is the strategy which will best protect against changes in the value of the liabilities and the Scheme’s ongoing and solvency positions. However, the Trustees and the Company have also considered the use of some growth asset investment within the portfolio and feel that some growth asset investment is appropriate to target the higher expected returns over bonds. The Trustees do recognise that holding growth assets (such as equities) investment will bring increased volatility in the ongoing and solvency levels in favour of potentially reduced Company contributions.
As an interim target, prior to buying out the Scheme liabilities, the Trustees will aim to target reaching a suitably strong funding level in order to move to an entirely bond (or bond like instrument) based investment strategy when a suitably strong funding level is achieved. The Trustees will monitor progress against this target. The Trustees will review the investment strategy on a regular basis and aim to de-risk the Scheme investment strategy over time.
The objectives set out above and the risks and other factors referenced in this Statement are those that the Trustees determine to be financially material considerations. Non-financial considerations such as member views are discussed in section 5.
3.2 Investment Risk
The Trustees regard “risk” as the likelihood of failing to achieve the objectives set out above and have, on the advice of Mercer, taken several measures which are set out in this Statement to minimise this risk, over the Scheme’s anticipated lifetime, so far as is possible.
The Trustees pay close regard to the risks which may arise through a mismatch between the Scheme’s assets and its liabilities, and the risks which may arise from the lack of diversification of investments. Subject to satisfying the risk from a mismatch of assets and liabilities, the Trustees believe that the asset allocation policy in place provides an adequately diversified distribution of assets.
The Trustees’ willingness to take on investment risk is dependent on the continuing financial strength of the Company and its willingness to contribute to the Scheme. The strength of the Company and its perceived commitment to the Scheme is monitored by the Trustees and risk will be reviewed if either of these deteriorates.
The degree of investment risk taken will also depend on the Scheme’s funding status and liability profile. The Trustees will monitor these with a view to altering the Scheme objectives and risk tolerances if there is a change in either.
There are various risks to which any pension scheme is exposed. The Trustees’ policy is to minimise these risks as far as possible, consistent with earning a satisfactory investment return to enable the Scheme to pay the benefits due to members.
The Trustees have considered the following risks:
- The primary risk upon which the Trustees focus is that arising through a mismatch between the Scheme’s assets and its liabilities.
- The Trustees recognise that whilst increasing risk increases potential returns over a long period, it also increases the risk of a shortfall in returns relative to that required to cover the Scheme’s accruing liabilities as well as producing more volatility in the Scheme’s funding position.
- The Trustees’ willingness to take on investment risk is dependent on the continuing financial strength of the Company and its willingness to contribute to the Scheme. The strength of the Company and its perceived commitment to the Scheme is monitored by the Trustees, and risk will be increased if either of these deteriorates.
- Whilst moving towards the target funding level, the Trustees recognise that even if the Scheme’s assets are invested in matching assets there may still be a mismatch between the interest-rate and inflation sensitivity of the Scheme’s assets and the Scheme’s liabilities due to the mismatch in duration between matching assets and actuarial liabilities.
- The Trustees recognise the risks that may arise from the lack of diversification of investments. Subject to managing the risk from a mismatch of assets and liabilities, and aim to ensure the asset allocation policy in place results in an adequately diversified portfolio.
- Investments may be made in securities that are not traded on regulated markets. Recognising the risks (in particular liquidity and counterparty exposure), such investments will only be made with the purpose of reducing the Scheme’s mismatch risk relative to its liabilities or to facilitate efficient portfolio management.
- In any event the Trustees will ensure that the assets of the Scheme are predominantly invested on regulated markets.
- There is a risk that the day-to-day management of the assets will not achieve the rate of investment return expected by the Trustees. The Trustees recognise that the use of active investment managers involves such a risk. However, for specific asset classes it believes that this risk is outweighed by the potential gains from successful active management. Likewise, passive management will be used for one of a number of reasons, namely to diversify and reduce risk and when investing in markets deemed efficient where the scope for added value is limited.
- The Trustees recognise that environmental, social and corporate governance concerns, including climate change, have a financially material impact on return. Section 5 sets out how these risks are managed.
- The Scheme is subject to currency risk because some of the investment vehicles in which the Scheme invests are denominated or priced in a foreign currency. To limit currency risk, the Trustees set a target non-Sterling currency exposure.
- Should there be a material change in the Scheme’s circumstances, the Trustees will advise Mercer, who will review whether and to what extent the investment arrangements should be altered.
- Responsibility for the safe custody of the Scheme’s assets is delegated to Mercer who has appointed State Street Bank and Trust Company (“State Street”) as custodian of the assets invested in their pooled vehicles. Mercer is responsible for keeping the suitability of State Street under ongoing review.
3.3 Investment Strategy
The Trustees, with advice from the Scheme’s investment consultant and Scheme Actuary, reviewed the Scheme’s investment strategy most recently in 2023. This review considered the Trustees’ investment objectives, their ability and willingness to take risk (the “risk budget”) and how this risk budget should be allocated and implemented (including de-risking strategies).
The Trustees’ investment strategy is to “de-risk” the Scheme’s assets relative to its liabilities over time using a dynamic trigger-based de-risking framework. Mercer implement the Trustees’ de-risking strategy by way of its Dynamic De-risking Solution. The approach undertaken relates to the asset allocation to the Scheme’s funding level (on an actuarial basis using a single discount rate of 0.25% p.a. in excess of the appropriate gilt yields i.e. “gilts + 0.25% basis”). The de-risking rule mandates the following practices:
- To hold sufficient growth assets to target full funding on a gilts +0.25% basis by 2030;
- To reduce the volatility in the funding level by reducing un-hedged liability exposures;
- To monitor the progress in the funding level and to capture improvements in the funding level promptly, if they arise.
The de-risking strategy takes account of the Scheme’s initial funding level on a gilts +0.25% basis and is based on a model of the progression of the Scheme’s funding level over the period to 2030.
The de-risking triggers which form the basis of the Scheme’s dynamic investment strategy are set out in a separate document – Investment Implementation Policy Document (“IIPD”).
Once the funding level has moved through a band, the asset allocation will not be automatically “re-risked” should the funding level deteriorate. The investment strategy will be reviewed on an annual basis to ensure that the triggers set remain appropriate and amended if required.
Responsibility for monitoring the Scheme asset allocation, and undertaking any rebalancing activity, is delegated to Mercer. Mercer reports quarterly to the Trustees on its rebalancing activities.
The Trustees have taken steps to satisfy itself that Mercer have the appropriate knowledge and experience to choose and combine the underlying investment managers and ensure that they are fit to manage the Scheme’s investments.
The Trustees regularly review the continuing suitability of the Scheme’s investments, including Mercer’s ability to select, appoint, remove and monitor the appointed managers. Mercer is regulated by the Financial Conduct Authority.
Full details of the Scheme’s investment strategy being implemented can be found in the IIPD.
The investment strategy is reviewed regularly by the Trustees to ensure that it remains appropriate for meeting the objectives set out in 3.1 and for controlling the risks identified in 3.2.
3.4 Consultation with the Company
As required by the Pensions Act 1995, and as a matter of good practice, the Trustees have consulted with the Company concerning the investment arrangements set out above.