Pension Board of City of Bradford Metropolitan District Council for West Yorkshire Pension Fund

1. Introduction
1.1 City of Bradford Metropolitan District Council (the Council), as Scheme Manager, as defined under section 4 of the Public Service Pensions Act 2013, has delegated legal and strategic responsibility for West Yorkshire Pension Fund (WYPF) to the Governance and Audit Committee. The Council has established two bodies to assist and support the Governance and Audit Committee in overseeing the Fund, namely the WYPF Investment Advisory Panel and the WYPF Joint Advisory Group.

1.2 In accordance with section 5 of the Public Service Pensions Act 2013 (the Act) and under 106 of the Local Government Pension Scheme Regulations 2013 (as amended) (the Regulations), the Council is required to establish a Pension Board. The Pension Board is separate from WYPF Investment Advisory Panel and the WYPF Joint Advisory Group.

1.3 This document sets out the terms of reference for WYPF Pension Board.

2. Objectives
2.1 The role of The Pension Board, as defined by sections 5(1) and (2) of the Public Service Pensions Act 2013 is to assist the Council as Scheme Manager in ensuring the effective and efficient governance and administration of the LGPS including:

2.1.1 securing compliance with the Local Government Pension Scheme regulations and any other legislation relating to the governance and administration of the LGPS;
2.1.2 securing compliance with the requirements imposed in relation to the LGPS by the Pensions Regulator; and
2.1.3 any other such matters as the LGPS regulations may specify.
3. Establishment
The Board is established on 1 April 2015 subsequent to approval by the Governance and Audit Committee on 20 March 2015.

4. Membership and Appointment for Pension Board members
4.1 Membership of the Pension Board shall be eight (8) in number. The Pension Board will consist of an equal numbers of member and employer representatives.

4.2 Pension Board representatives must not participate in or act as members of the Joint Advisory Group or Investment Advisory Panel.

Employer representatives
4.3 Employers who participate in the Fund will nominate four (4) representatives to sit on the Pension Board as Employer Representatives from the following sources:

4.3.1 Three (3) representatives will be from West Yorkshire councils, one (1) of these three (3) will be appointed in accordance with 4.6 below.
4.3.2 One (1) representative will be from the other employing bodies. This representative shall be selected by City of Bradford MDC following a process where all employers will be asked to submit their interest in undertaking this role.
Member representatives
4.4 Member representatives shall either be scheme members or have capacity to represent scheme members of WYPF

4.5 Relevant Trade Unions, who have agreed to represent all categories of the membership, will nominate four (4) representatives to sit on the Pension Board as member representatives.

The Chair
4.6 The Council as Scheme Manager will appoint one Councillor from the City of Bradford Metropolitan District Council, independent of Joint Advisory Group, Investment Advisory Panel or Governance and Audit Committee, to sit as the Chair on the Pension Board

4.7 The Chair of the Board shall:

(a) ensure that the Board delivers its purpose as set out in these Terms of Reference;
(b) ensure that meetings are productive and effective and that opportunity is provided for the views of all members to be expressed and considered; and
(c) seek to reach consensus and ensure that decisions are properly put to a vote when it cannot be reached. Instances of a failure to reach a consensus position will be recorded and published.
Attendance at meetings
4.8 Each Pension Board member should endeavour to attend all Pension Board meetings during the year. In the event of consistent non-attendance by any Pension Board member then the tenure of the membership should be reviewed at the next Pension Board meeting.

5. Term of Office/Appointment
5.1 Subject to paragraph 5.2, Pension Board representatives will normally serve for a period of four (4) years and may be reappointed to serve further terms so long as they remain relevant members (pursuant to paragraph 4 above).

5.2 Upon initial establishment of the Board in 2015 50% of members (comprising of two (2) member representatives and two (2) employer representatives) shall be appointed for a term of only two years in order to establish appointment on a rolling basis.

5.3 Employer bodies and organisations retain the right to withdraw representatives and identify replacements on occasion.

5.4 Pension Board members may be reappointed without limitation on terms subject to the Pension Board being satisfied as to the transparency and proper application of the appointment process in use.

6. Termination
6.1 Other than by ceasing to be eligible a Pension Board member may normally only be removed from office during a term of appointment by the agreement of the Board.

6.2 Board membership may be terminated prior to the end of the term of office due to:

6.2.1 A member representative no longer being a representative of the body on which their appointment relied
6.2.2 An employer representative no longer holding the office or employment or being a member of the body on which their appointment relied.
6.2.3 A board member no longer being able to demonstrate their capacity to attend and prepare for meetings or participate in required training.
6.2.4 The representative being withdrawn by the nominating body and a replacement identified.
6.2.5 A board member has a conflict of interest which cannot be managed in accordance with the Board’s conflict policy.
6.2.6 A Board member who is an elected member becomes a member of Joint Advisory Group and Investment Advisory Panel.
6.2.7 A Board member who is an officer of City of Bradford MDC becomes responsible for the discharge of any function of the Administering Authority under the LGPS regulations.
7. Number of Meetings
7.1 The Pension Board will normally meet four times a year. The Chair may call meetings more frequently if deemed necessary or if requested on matters considered urgent.

7.2 In exceptional circumstances, meetings can be conducted via communications between members of the Board including telephone conferencing and emails.

8. Creation of Working Groups/Sub Boards
The Pension Board may establish sub-committees and working groups as and when required. The Pension Board will be responsible for developing and agreeing the terms of reference and membership of any sub-committees. The Pension Board will also be responsible for outlining the purpose of any working group, its membership and detailing when and how that working group should report back.

9. Code of Conduct and Conflicts of Interest policy
9.1 The principles included in the Council’s Code of Conduct for Members applies to all member of the Pension Board. The Code of Conduct is set out in Part 4 of the Council’s Constitution.

9.2 No person may be appointed to the Pension Board that has a significant conflict of interest. A conflict of interest is defined as a financial or other interest which is likely to prejudice a person’s exercise of functions as a member of the Pension Board. It does not include a financial or other interest arising merely by virtue of that person being a member of the scheme or any connected scheme for which the board is established.

9.3 All voting members of the Pensions Board must complete a Declaration of Acceptance of Office Form, and Disclosure of Financial and other interest form.

9.4 At each meeting any interests which may lead to conflicts in specific agenda items must be declared.

10. Voting Rights
All representatives on the Pension Board have equal voting rights. Decisions made by the Pensions Board shall be on a majority basis. In the event of there not being a majority the Chair shall have the casting vote.

11. Other Attendees
The Pensions Board will extend an invitation to attend to other members of staff and advisers as it may from time to time consider appropriate.

12. Secretariat Services to the Board
Pension Board meetings will be administered by City of Bradford MDC Committee secretariat in accordance with the rules and procedures of City of Bradford MDC “Constitution of the Council and Executive Arrangements”. All reasonable costs will be met by the Fund.

13. Agenda
Prior to each meeting the Director of West Yorkshire Pension Fund will arrange to supply all members of the Board with an agenda and relevant information. The agenda and any relevant documents will be issued at least five working days in advance of the meeting, except in exceptional circumstances with the agreement of the Chair.

14. Quorum
The quorum of the Pension Board shall be three. (Chair plus one employer representative and one member representative).

15. Publication
In accordance with the Act the Council shall publish information about the Board to include:

(a) The names of Board members and their contact details
(b) The representation of employers and member on the Board
(c) The role of the Board
(d) These Terms of Reference
16. Allowances/Expenses
No member or representative of the Pension Board shall be remunerated for undertaking this role. However, expenses incurred in attending meetings of the Board and attending training events, shall be reimbursed to all members and the cost will be met by the Fund.

17. Knowledge and Understanding and Capacity of Representative Members
17.1 Every individual who is a member of the Pension Board must be conversant with:

(a) the rules of the LGPS, in other words the Regulations and other regulations governing the LGPS (such as the Transitional Regulations and the Investment Regulations); and
(b) the requirements of the Pensions Regulator; and
(c) any document recording policy about the administration of the Fund which is for the time being adopted in relation to the Fund, and have knowledge and understanding of:
(d) the law relating to pensions; and
(e) such other matters as may be prescribed.
17.2 A Knowledge and Understanding Policy and Framework will be maintained by WYPF.

17.3 Pension Board members shall attend and participate in training arranged in order to meet and maintain the requirements set out in the Knowledge and Understanding Policy and Framework.

17.4 Employer and member representatives should be able to demonstrate their capacity to attend and complete the necessary preparation for meeting and participate in training as required.

18. Accountability
18.1 The Board should in the first instance report its requests, recommendations or concerns to the committee. In support of this any member of the Board may attend a Committee meeting as an observer.

18.2 The Board should report any concerns over a decision made by the Committee subject to the agreement of at least 50% of voting Board members provided that all voting members are present. If all voting members are not present then the agreement should be of all voting members who are present, where the meeting remains quorate.

18.3 On receipt of a report the Committee shall within a reasonable period, consider and respond to the Board.

18.4 Where the Board is not satisfied with the response received it may request that a notice of its concern be placed on the website and in the Fund's annual report.

18.5 Where the Board is satisfied that there has been a breach of regulation which has been reported to the Committee and has not been rectified within a reasonable period of time it is under an obligation to escalate the breach.

18.6 The appropriate internal route for escalation is to the Administering Authority Monitoring Officer.

19. Budget
The Pension Board is to be provided with adequate resources to fulfil its role. The Council will allocate an annual budget to cover the expenses of the board.

20. Core Functions:
20.1 The first core function of the Board is to assist the Council in securing compliance with the Regulations, any other legislation relating to the governance and administration of the Scheme, and requirements imposed by the Pensions Regulator in relation to the Scheme.

20.2 The second core function of the Board is to assist the Council to ensure the effective and efficient governance and administration of the Scheme.

20.3 In support of its core functions the Board may make a request for information to the Committee with regard to any aspect of the Council’s function. Any such request should be reasonably complied with in both scope and timing.

20.4 In support of its core functions the Board may make recommendations to the Committee which should be considered and a response made to the Board on the outcome within a reasonable period of time.

21. Data Protection
21.1 The Pensions Board is considered a committee of and part of the Council’s legal entity. The Council is and remains the data controller responsible for DPA compliance, including for processing carried out by the Pension Board, where processing is carried out as a data controller, or where personal data use by the Pension Board is not carried out for and on behalf of any other separate legal entity.

21.2 The Pension Board will therefore adhere to the data protection policies of the Council.

22. Review of Terms of Reference
22.1 These Terms of reference shall be reviewed on each material change to those parts of the Regulations covering local pension boards and at least every two (2) years.

22.2 These terms of reference were adopted on:

20th March 2015 - On behalf of the Council (Governance and Audit Committee)

1. Introduction

1.1 City of Bradford Metropolitan District Council (Bradford), as Scheme Manager, has delegated legal and strategic responsibility for West Yorkshire Pension Fund (WYPF) to the Governance and Audit Committee. The Council has established two bodies to assist and support the Governance and Audit Committee in overseeing the Fund, namely the WYPF Investment Advisory Panel and the WYPF Joint Advisory Group.

1.2 In accordance with the regulations, Bradford is required to establish a Pensions Board. The Pension Board is separate from WYPF Investment Advisory Panel and the WYPF Joint Advisory Group.

2. Objectives of the Pension Board
2.1 The role of the Pension Board, as defined by sections 5(1) and (2) of the Public Service Pensions Act 2013 is to assist City of Bradford Metropolitan District Council as Scheme Manager in ensuring the effective and efficient governance and administration of the LGPS including:

secure compliance with the Local Government Pension Scheme regulations and any other legislation relating to the governance and administration of the LGPS;
secure compliance with the requirements imposed in relation to the LGPS by the Pensions Regulator; and
In such other matters as the LGPS regulations may specify.
2.2 The role of the representative is to represent the interests of the employers or members within the Fund and channel information back to them effectively.

3. Undertakings
3.1 Board Members will be required to:

Prepare for all meetings in advance, including reading all papers and minutes
Contribute to setting the agenda for meetings
Actively participate in meetings
Have due regard for members and employers when making decision
Comply with the Nolan Principals
3.3 Board Members will have the capacity and will endeavour to attend all meetings.

3.4 Board Members will have the capacity and will undertake and attend the necessary knowledge and understanding training.

3.5 Board Members will abide by the Pension Boards Terms of Reference and wider constitutional documents.

4. Conflicts of Interest
4.1 Board Members will be required to adhere to the Conflicts of Interest Policy.

4.2 The Regulations place a duty on the Administering Authority to satisfy itself that those appointed to its Pension Board do not have an actual conflict of interest prior to appointment and from time to time. Any conflicts of interest must be declared on appointment to the Board and if or when they occur.

5. Training and Knowledge
5.1 Board Members will be required to undertake a personal training needs analysis and to regularly review their skills, competencies and knowledge to identify gaps or weaknesses.

5.2 Board Members are expected to attend training opportunities.

5.3 Board Members must be conversant with:

the rules of the scheme, and
any document recording policy about the administration of the scheme.
5.4 Board Members must have knowledge and understanding of:

the law relating to pensions,
the requirements of the Pensions Regulator in relation to public sector schemes,
any other matters which are prescribed in the regulations.
6 Expected Qualities
6.1 The following are expected qualities Board Members should have:

Commitment to the role,
Integrity, vision and good, independent judgment
A willingness to devote the necessary time and effort to their duties as a Board Member
Ability to help formulate recommendations
Good communication skills
Tact and diplomacy
Understanding of the legal responsibilities of West Yorkshire Pension Fund.
7 Desirable experience and knowledge
7.1 Board Members should have:

Knowledge and experience of governance or management of work based pension schemed and the regulatory bodies involved.
Knowledge of local government pension schemes,
An awareness of the practices and policies of the LGPS including:
Pension fund administration and governance
Pension fund investment management
Pension fund liability management
Law relating to pensions
7.2 Board Members will be expected to undertake training to address any gaps in their experience and knowledge as soon as possible.

8 Time Consideration
8.1 The Board meets four times a year. In addition to meetings, contact electronically or by telephone may be necessary.

8.2 In addition regular training will be required and the time commitment of this will fluctuate dependant on representatives needs but may equate to up to 10 days per year.

1. Introduction

1.1 This document sets out the procedures to be followed by certain persons involved with the West Yorkshire Pension Fund (WYPF), the Local Government Pension Scheme managed and administered by City of Bradford MDC, in relation to reporting breaches of the law to the Pensions Regulator.

1.2 Breaches can occur in relation to a wide variety of tasks normally associated with the administrative function of a scheme such as keeping records, internal controls, calculating benefits and making investment or investment-related decisions.

1.3 This procedure applies, in the main, to:

all members of the Joint Advisory Group, Investment Advisory Panel and Pension Board;
all officers involved in the management of the Pension Fund;
any professional advisers including auditors, actuaries, legal advisers and fund managers; and
officers of employers participating in the West Yorkshire Pension Fund who are responsible for pension matters.
2. Requirements
2.1 This section clarifies the full extent of the legal requirements and to whom they apply.

2.2 Pensions Act 2004
Section 70 of the Pensions Act 2004 (the Act) imposes a requirement on the following persons:

a trustee or manager of an occupational or personal pension scheme;
a member of the pension board of a public service pension scheme;
a person who is otherwise involved in the administration of such a scheme an occupational or personal pension scheme;
the employer in relation to an occupational pension scheme;
a professional adviser in relation to such a scheme; and
a person who is otherwise involved in advising the trustees or managers of an occupational or personal pension scheme in relation to the scheme, to report a matter to The Pensions Regulator as soon as is reasonably practicable where that person has reasonable cause to believe that:

(a) a legal duty relating to the administration of the scheme has not been or is not being complied with, and
(b) the failure to comply is likely to be of material significance to The Pensions Regulator.
The Act states that a person can be subject to a civil penalty if he or she fails to comply with this requirement without a reasonable excuse. The duty to report breaches under the Act overrides any other duties the individuals listed above may have. However the duty to report does not override ‘legal privilege’. This means that, generally, communications between a professional legal adviser and their client, or a person representing their client, in connection with legal advice being given to the client, do not have to be disclosed.

2.3 The Pension Regulator's Code of Practice
Practical guidance in relation to this legal requirement is included in The Pension Regulator’s Code of Practice including in the following areas:

implementing adequate procedures.
judging whether a breach must be reported.
submitting a report to The Pensions Regulator.
whistleblowing protection and confidentiality.
3 Reporting Breaches Procedure
The following procedure details how individuals responsible for reporting and whistleblowing can identify, assess and report (or record if not reported) a breach of law relating to the West Yorkshire Pension Fund. It aims to ensure individuals responsible are able to meet their legal obligations, avoid placing any reliance on others to report. The procedure will also assist in providing an early warning of possible malpractice and reduce risk.

3.1 Clarification of the law
Individuals may need to refer to regulations and guidance when considering whether or not to report a possible breach. Some of the key provisions are shown below:

Section 70(1) and 70(2) of the Pensions Act 2004:
www.legislation.gov.uk/ukpga/2004/35/contents
Employment Rights Act 1996:
www.legislation.gov.uk/ukpga/1996/18/contents
Occupational and Personal Pension Schemes (Disclosure of Information) Regulations 2013 (Disclosure Regulations):
www.legislation.gov.uk/uksi/2013/2734/contents/made
Public Service Pension Schemes Act 2013:
www.legislation.gov.uk/ukpga/2013/25/contents
Local Government Pension Scheme Regulations (various):
www.lgpsregs.org/timelineregs/Default.html (pre 2014 schemes)

www.lgpsregs.org/index.php/regs-legislation (2014 scheme)
The Pensions Regulator’s Code of Practice

In particular, individuals should refer to the section on ‘Reporting breaches of the law’, and for information about reporting late payments of employee or employer contributions, the section of the code on ‘Maintaining contributions’.
Further guidance and assistance can be provided by the Director – WYPF provided that requesting this assistance will not result in alerting those responsible for any serious offence (where the breach is in relation to such an offence).

3.2 Clarification when a breach is suspected
Individuals need to have reasonable cause to believe that a breach has occurred, not just a suspicion. Where a breach is suspected the individual should carry out further checks to confirm the breach has occurred. Where the individual does not know the facts or events, it will usually be appropriate to check with the Director - WYPF, a member of the Joint Advisory Group, Investment Advisory Panel or Pension Board or others who are able to explain what has happened. However there are some instances where it would not be appropriate to make further checks, for example, if the individual has become aware of theft, suspected fraud or another serious offence and they are also aware that by making further checks there is a risk of either alerting those involved or hampering the actions of the police or a regulatory authority. In these cases The Pensions Regulator should be contacted without delay.

3.3 Determining whether the breach is likely to be of material significance
To decide whether a breach is likely to be of material significance an individual should consider the following, both separately and collectively:

cause of the breach (what made it happen);
effect of the breach (the consequence(s) of the breach);
reaction to the breach; and
wider implications of the breach.
Further details on the above four considerations are provided in Appendix A to this procedure. Individuals should use the traffic light framework described in Appendix B to help assess the material significance of each breach and to formally support and document their decision.

3.4 A decision tree is provided at this linked page to show the process for deciding whether or not a breach has taken place and whether it is materially significant and therefore requires to be reported.

3.5 Referral to a level of seniority for a decision to be made on whether to report
Director – WYPF is designated to ensure this procedure is appropriately followed. The Director is considered to have appropriate experience to help investigate whether there is reasonable cause to believe a breach has occurred, to check the law and facts of the case, to maintain records of all breaches and to assist in any reporting to The Pensions Regulator, where appropriate. If breaches relate to late or incorrect payment of contributions or pension benefits, the matter should be highlighted to the Director – WYPF at the earliest opportunity to ensure the matter is resolved as a matter of urgency. Individuals must bear in mind, however, that the involvement of the Director - WYPF is to help clarify the potential reporter's thought process and to ensure this procedure is followed. The reporter remains responsible for the final decision as to whether a matter should be reported to The Pensions Regulator.

The matter should not be referred to any officer if doing so will alert any person responsible for a possible serious offence to the investigation (as highlighted in section 2). If that is the case, the individual should report the matter to The Pensions Regulator setting out the reasons for reporting, including any uncertainty – a telephone call to the Regulator before the submission may be appropriate, particularly in more serious breaches.

3.6 Dealing with complex cases
The Director - WYPF may be able to provide guidance on particularly complex cases. Information may also be available from national resources such as the Scheme Advisory Board or the LGPC Secretariat (part of the LG Group -www.lgpsregs.org/ ). If timescales allow, legal advice or other professional advice can be sought and the case can be discussed at the next Board, Joint Advisory Group, Investment Advisory Panel or Management meeting.

3.7. Timescales for reporting
The Pensions Act and Pension Regulators Code require that if an individual decides to report a breach, the report must be made in writing as soon as reasonably practicable. Individuals should not rely on waiting for others to report, nor is it necessary for a reporter to gather all the evidence which The Pensions Regulator may require before taking action. A delay in reporting may exacerbate or increase the risk of the breach. The time taken to reach the judgements on “reasonable cause to believe” and on “material significance” should be consistent with the speed implied by ‘as soon as reasonably practicable’. In particular, the time taken should reflect the seriousness of the suspected breach.

3.8 Early identification of very serious breaches
In cases of immediate risk to the scheme, for instance, where there is any indication of dishonesty, The Pensions Regulator does not expect reporters to seek an explanation or to assess the effectiveness of proposed remedies. They should only make such immediate checks as are necessary. The more serious the potential breach and its consequences, the more urgently reporters should make these necessary checks. In cases of potential dishonesty the reporter should avoid, where possible, checks which might alert those implicated. In serious cases, reporters should use the quickest means possible to alert The Pensions Regulator to the breach.

3.9 Recording all breaches even if they are not reported
The record of past breaches may be relevant in deciding whether to report a breach (for example it may reveal a systemic issue). WYPF will maintain a record of all breaches identified by individuals and reporters should therefore provide copies of reports to the Director – WYPF. Records of unreported breaches should also be provided as soon as reasonably practicable and certainly no later than within 20 working days of the decision made not to report. These will be recorded alongside all reported breaches. The record of all breaches (reported or otherwise) will be included in the next Joint Advisory Group meeting, and this will also be shared with the Pension Board.

3.10 Reporting a breach
Reports must be submitted in writing via The Pensions Regulator’s online system at www.tpr.gov.uk/exchange or by post, email or fax, and should be marked urgent if appropriate. If necessary, a written report can be preceded by a telephone call. Reporters should ensure they receive an acknowledgement for any report they send to The Pensions Regulator. The Pensions Regulator will acknowledge receipt of all reports within five working days and may contact reporters to request further information. Reporters will not usually be informed of any actions taken by The Pensions Regulator due to restrictions on the disclosure of information.

As a minimum, individuals reporting should provide:

full scheme name (West Yorkshire Pension Fund);
description of breach(es);
any relevant dates;
name, position and contact details;
role in connection to the scheme; and
employer name or name of scheme manager (the latter is City of Bradford MDC).
If possible, reporters should also indicate:

the reason why the breach is thought to be of material significance to The Pensions Regulator;
scheme address (provided at the end of this procedures document);
scheme manager contact details (provided at the end of this procedures document);
pension scheme registry number; and
whether the breach has been reported before.
The reporter should provide further information or reports of further breaches if this may help The Pensions Regulator in the exercise of its functions. The Pensions Regulator may make contact to request further information.

3.11 Confidentiality
If requested, The Pensions Regulator will do its best to protect a reporter’s identity and will not disclose information except where it is lawfully required to do so. If an individual’s employer decides not to report and the individual employed by them disagrees with this and decides to report a breach themselves, they may have protection under the Employment Rights Act 1996 if they make an individual report in good faith.

3.12 Reporting to Joint Advisory Group and Pension Board
A report will be presented to the Joint Advisory Group and Pension Board setting out:

all breaches, including those reported to The Pensions Regulator and those unreported, with the associated dates;
in relation to each breach, details of what action was taken and the result of any action (where not confidential);
any future actions for the prevention of the breach in question being repeated; and
highlighting new breaches which have arisen in the last year/since the previous meeting.
This information will also be provided upon request by any other individual or organisation (excluding sensitive/confidential cases or ongoing cases where discussion may influence the proceedings). An example of the information to be included in the quarterly reports is provided in Appendix C to this procedure.

3.13 Review
This Reporting Breaches Procedure was originally developed in June 2015. It will be kept under review and updated as considered appropriate. It may be changed as a result of legal or regulatory changes, evolving best practice and ongoing review of the effectiveness of the procedure.

Appendix A
1. Determining whether a breach is likely to be of material significance
1.1 To decide whether a breach is likely to be of material significance individuals should consider the following elements, both separately and collectively:

cause of the breach (what made it happen);
effect of the breach (the consequence(s) of the breach);
reaction to the breach; and
wider implications of the breach.
2. The cause of the breach
2.1 Examples of causes which are likely to be of concern to The Pensions Regulator are provided below:

acting, or failing to act, in deliberate contravention of the law;
dishonesty;
incomplete or inaccurate advice;
poor administration, i.e. failure to implement adequate administration procedures;
poor governance; or
slow or inappropriate decision-making practices.
2.2 When deciding whether a cause is likely to be of material significance individuals should also consider:

whether the breach has been caused by an isolated incident such as a power outage, fire, flood or a genuine one-off mistake.
whether there have been any other breaches (reported to The Pensions Regulator or not) which when taken together may become materially significant.
3. The effect of the breach
3.1 Examples of the possible effects (with possible causes) of breaches which are considered likely to be of material significance to The Pensions Regulator in the context of the LGPS are given below:

Joint Advisory Group, Investment Advisory panel or Board members not having enough knowledge and understanding, resulting in pension boards not fulfilling their roles, the scheme not being properly governed and administered and/or scheme managers breaching other legal requirements.
Conflicts of interest of Joint Advisory Group, Investment Advisory panel or Board members, resulting in them being prejudiced in the way in which they carry out their role and/or the ineffective governance and administration of the scheme and/or scheme managers breaching legal requirements.
Poor internal controls, leading to schemes not being run in accordance with their scheme regulations and other legal requirements, risks not being properly identified and managed and/or the right money not being paid to or by the scheme at the right time.
Inaccurate or incomplete information about benefits and scheme information provided to members, resulting in members not being able to effectively plan or make decisions about their retirement.
Poor member records held, resulting in member benefits being calculated incorrectly and/or not being paid to the right person at the right time.
Misappropriation of assets, resulting in scheme assets not being safeguarded.
Other breaches which result in the scheme being poorly governed, managed or administered.
4. The reaction to the breach
4.1 A breach is likely to be of concern and material significance to The Pensions Regulator where a breach has been identified and those involved:

do not take prompt and effective action to remedy the breach and identify and tackle its cause in order to minimise risk of recurrence;
are not pursuing corrective action to a proper conclusion; or
fail to notify affected scheme members where it would have been appropriate to do so.
5. The wider implications of the breach
5.1 Reporters should also consider the wider implications when deciding whether a breach must be reported. The breach is likely to be of material significance to The Pensions Regulator where the fact that a breach has occurred makes it more likely that further breaches will occur within the Fund or, if due to maladministration by a third party, further breaches will occur in other pension schemes.

Appendix B
Traffic light framework for deciding whether or not to report
It is recommended that those responsible for reporting use the traffic light framework when deciding whether to report to The Pensions Regulator. This is illustrated below:

Where the cause, effect, reaction and wider implications of a breach, when considered together, are likely to be of material significance.

These must be reported to The Pensions Regulator.

Example: Several members’ benefits have been calculated incorrectly. The errors have not been recognised and no action has been taken to identify and tackle the cause or to correct the errors.

Where the cause, effect, reaction and wider implications of a breach, when considered together, may be of material significance. They might consist of several failures of administration that, although not significant in themselves, have a cumulative significance because steps have not been taken to put things right. You will need to exercise your own judgement to determine whether the breach is likely to be of material significance and should be reported.

Example: Several members’ benefits have been calculated incorrectly. The errors have been corrected, with no financial detriment to the members. However the breach was caused by a system error which may have wider implications for other public service schemes using the same system.

Where the cause, effect, reaction and wider implications of a breach, when considered together, are not likely to be of material significance. These should be recorded but do not need to be reported.

Example: A member’s benefits have been calculated incorrectly. This was an isolated incident, which has been promptly identified and corrected, with no financial detriment to the member. Procedures have been put in place to mitigate against this happening again.

All breaches should be recorded even if the decision is not to report.

When using the traffic light framework individuals should consider the content of the red, amber and green sections for each of the cause, effect, reaction and wider implications of the breach, before you consider the four together. Some useful examples of this is framework is provided by The Pensions Regulator at the following link:

www.thepensionsregulator.gov.uk/codes/code-related-report-breaches.aspx 

Where the cause, effect, reaction and wider implications of a breach,

1. Introduction

1.1 Conflicts of interest have always existed for those with Local Government Pension Scheme (LGPS) administering authority responsibilities as well as for advisers to LGPS funds. This simply reflects the fact that many of those managing or advising LGPS funds will have a variety of other roles and responsibilities, for example as a member of the scheme, as an Elected Member of an employer participating in the LGPS or as an adviser to more than one LGPS administering authority. In addition, they may have an individual personal, business or other interest which might conflict, or be perceived to conflict, with their role managing or advising LGPS funds.

1.2 It is generally accepted that LGPS administering authorities have both fiduciary and public law duties to act in the best interests of both the scheme beneficiaries and participating employers. This, however, does not preclude those involved in the management of the fund from having other roles or responsibilities which may result in an actual or potential conflict of interest. Accordingly, it is good practice to document within a policy, such as this, how any such conflicts or potential conflicts are to be managed.

1.3 This is the Conflicts of Interest Policy of the West Yorkshire Pension Fund (WYPF), which is managed by City of Bradford MDC (CBMDC). The Policy details how actual and potential conflicts of interest are identified and managed by those involved in the management and governance of the WYPF whether directly or in an advisory capacity.

1.4 This Conflicts of Interest Policy is established to guide Joint Advisory Group, Investment Advisory Panel, Pension Board members, officers and advisers. Along with other constitutional documents, including the various Codes of Conduct, it aims to ensure that they do not act improperly or create a perception that they may have acted improperly. It is an aid to good governance, encouraging transparency and minimising the risk of any matter prejudicing decision making or management of the Fund otherwise.

2. Aims and Objectives
2.1 In relation to the governance of the Fund, the Administering Authority's objectives are to ensure that:

all staff and Joint Advisory Group, Investment Advisory Panel and Pension Board members charged with the financial administration and decision-making with regard to the Fund are fully equipped with the knowledge and skills to discharge the duties and responsibilities allocated to them
the Fund is open in all its dealings and readily provides information to interested parties
all relevant legislation is understood and complied with
the Fund is at the forefront of best practice for LGPS funds
all Conflicts of Interest are managed appropriately
The identification and management of potential and actual conflicts of interest is therefore integral to the Administering Authority achieving its governance objectives.

3. Application of this policy
3.1 This Conflicts of Interest Policy applies to all Joint Advisory Group, Investment Advisory Panel and Pension Board member, including scheme member and employer representatives, whether voting members or not. It applies to all members of WYPF Management Team.

3.2 This Policy and the issue of conflicts of interest in general must be considered in light of each individual's role, whether this is a management, advisory or assisting role.

3.3 Director - WYPF will monitor potential conflicts for less senior officers involved in the daily management of the Pension Fund and highlight this Policy to them as appropriate.

3.4 This Policy also applies to all advisers and suppliers to the Fund, whether advising the Joint Advisory Group, Investment Advisory Panel, Pension Board or Fund officers, in relation to their role in advising or supplying the Fund.

3.5 In this Policy, reference to advisers includes all advisers, suppliers and other parties providing advice and services to the Administering Authority in relation to pension fund matters. This includes but is not limited to actuaries, investment consultants, independent advisers, benefits consultants, third party administrators, fund managers, lawyers, custodians and AVC providers. Where an advisory appointment is with a firm rather than an individual, reference to "advisers" is to the lead adviser(s) responsible for the delivery of advice and services to the Administering Authority rather than the firm as a whole.

3.6 In accepting any role covered by this Policy, those individuals agree that they must:

acknowledge any potential conflict of interest they may have;
be open with the Administering Authority on any conflicts of interest they may have;
adopt practical solutions to managing those conflicts; and
plan ahead and agree with the Administering Authority how they will manage any conflicts of interest which arise in future.
The procedures outlined later in this policy provide a framework for each individual to meet these requirements.

4. Legislative and related context
4.1 There are a number of requirements relating to the management of potential or actual conflicts of interest for those involved in LGPS funds which are included in legislation or guidance. These are summarised in Appendix 1.

5. Other administering Authority Requirements
5.1 Individuals to whom this policy applies may also be required to adhere to other requirements in relation to conflicts of interest. This includes:

Joint Advisory Group, Investment Advisory Panel and Pension Board members who are required to adhere to the CBMDC Members’ Code of Conduct
employees who are required to adhere to the CBMDC Employees’ Code of Conduct
advisers who are expected to have their own policies or protocols.
Further information is provided in Appendix 2.

6. What is a Conflict or potential Conflict and how will it be managed?
6.1 The Public Service Pensions Act 2013 defines a conflict of interest as a financial or other interest which is likely to prejudice a person’s exercise of functions.

Therefore, a conflict of interest may arise when an individual:

has a responsibility or duty in relation to the management of, or provision of advice to, the LGPS fund administered by CBMDC, and
at the same time, has:
a separate personal interest (financial or otherwise) or
another responsibility in relation to that matter,
giving rise to a possible conflict with their first responsibility. An interest could also arise due to a family member or close colleague having a specific responsibility or interest in a matter.

Some examples of potential conflicts are included in Appendix 3.

6.2 CBMDC encourages a culture of openness and transparency and encourages individuals to be vigilant; have a clear understanding of their role and the circumstances in which they may have a conflict of interest, and of how potential conflicts should be managed.

6.3 CBMDC will evaluate the nature of any dual interests or responsibilities that are highlighted and assess the impact on Pension Fund operations and good governance were an actual conflict of interest to materialise.

Ways in which conflicts of interest may be managed include:

the individual concerned abstaining from discussion, decision-making or providing advice relating to the relevant issue
the individual being excluded from the meeting(s) and any related correspondence or material in connection with the relevant issue
a working group or sub-committee being established, excluding the individual concerned, to consider the matter outside of the formal meeting (where the terms of reference permit this to happen)
Provided that the Administering Authority (having taken any professional advice deemed to be required) is satisfied that the method of management is satisfactory, CBMDC shall endeavour to avoid the need for an individual to resign due to a conflict of interest. However, where the conflict is considered to be so fundamental it cannot be effectively managed, or where a Pension Board member has an actual conflict of interest as defined in the Public Service Pensions Act 2013, the individual will be required to resign from their role.

7. Responsibility
7.1 The Administering Authority for the WYPF Fund must be satisfied that conflicts of interest are appropriately managed. For this purpose, the Director - WYPF is the designated individual for ensuring the procedure outlined below is adhered to.

However, it is the responsibility of each individual covered by this Policy to identify any potential instances where their personal, financial, business or other interests might come into conflict with their pension fund duties.

8. Operational procedures
8.1 Declaration at Appointment

8.1.1 On appointment to their role or on the commencement of this Policy if later, all individuals will be provided with a copy of this Policy and be required to complete a Declaration of Interest form. The information contained in this declaration will be collated into the Pension Fund's Register of Conflicts of Interest.
8.2 Declaration at Meetings

8.2.1 At the commencement of any Joint Advisory Group, Investment Advisory Panel, Pension Board or other formal meeting where pension fund matters are to be discussed, the Chair will ask all those present who are covered by this Policy to declare any new potential conflicts.
8.2.2 These will be recorded in the Fund's Register of Conflicts of Interest. In addition, the latest version of the register will be made available by the Director - WYPF to the Chair of every meeting prior to that meeting.
8.2.3 Any individual who considers that they or another individual has a potential or actual conflict of interest which relates to an item of business at a meeting, must advise the Chair and the Director - WYPF prior to the meeting, where possible, or state this clearly at the meeting at the earliest possible opportunity. The Chair, in consultation with the Director - WYPF, should then decide whether the conflicted or potentially conflicted individual needs to leave the meeting during the discussion on the relevant matter or to withdraw from voting on the matter.
8.2.4 If such a conflict is identified outside of a meeting the notification must be made to the Director – WYPF and where it relates to the business of any meeting, also to the Chair of that meeting. The Director - WYPF, in consultation with the Chair where relevant, will consider any necessary action to manage the potential or actual conflict.
8.2.5 Where information relating to any potential or actual conflict has been provided, the Director - WYPF may seek such professional advice as he or she thinks fit (such as legal advice from the Monitoring Officer) on how to address any identified conflicts.
8.2.6 Any such potential or actual conflicts of interest and the action taken must be recorded in the Fund's Register of Conflicts of Interest.
8.3 Annual Declaration

8.3.1 Every 12 months all individuals will complete a new Declaration of Interest confirming that their information contained in the Register is correct or highlighting any changes that need to be made to the declaration.
8.4 Conduct at Meetings

8.4.1There may be circumstances when a representative of employers or members wishes to provide a specific point of view on behalf of an employer (or group of employers) or member (or group of members). The Administering Authority requires that any individual wishing to speak from an employer's or member's viewpoint must state this clearly, e.g. at a Pension Board or Joint Advisory Group or Investment advisory Panel meeting, and that this will be recorded in the minutes.
9. Operational procedures for advisers
9.1 Although this policy applies to all of the key advisers, the operational procedures outlined in 8.1 and 8.3 above relating to completing declarations do not apply to advisers. Instead all advisers must:

be provided with a copy of this Policy on appointment and whenever it is updated
adhere to the principles of this Policy
provide, on request, information to Director - WYPF as to how they will manage and monitor actual or potential conflicts of interests relating to the provision of advice or services to CBMDC as Administering Authority
notify the Director – WYPF immediately should a potential or actual conflict of interest arise.
All potential or actual conflicts notified by advisers will be recorded in the Fund’s Register of Conflicts of Interest.

10. Monitoring and reporting
10.1 The Fund's Register of Conflicts of Interest may be viewed by any interested party by appointment during normal business hours. In addition information relating to conflicts of interest will be published in the Fund's Annual Report and Accounts.

10.2 In order to identify whether the objectives of this Policy are being met the administering authority will review the Register of Conflicts of Interest on an annual basis and consider whether there has been any potential or actual conflicts of interest that were not declared at the earliest opportunity.

11. Key Risks
11.1 The key risks to the delivery of this Policy are outlined below all of which could result in an actual conflict of interest arising and not being properly managed. The Director - WYPF will monitor these and other key risks and consider how to respond to them, taking advice from the City Solicitor where required.

The key risks are:

Insufficient training or poor understanding in relation to individuals’ roles on pension fund matters
Insufficient training or failure to communicate the requirements of this Policy
Absence of the individual nominated to manage the operational aspects of this Policy and no one deputising or failure of that individual to carry out the operational aspects in accordance with this Policy
Failure by a chair to take appropriate action when a conflict is highlighted at a meeting.
12. Costs
12.1 All costs related to the operation and implementation of this Policy will be met directly by WYPF. However, no payments will be made to any individuals in relation to any time spent or expenses incurred in the disclosure or management of any potential or actual conflicts of interest under this Policy.

Appendix 1
Legislation, Regulation and Guidance on Conflicts of Interest
The requirements in relation to the management of potential or actual conflicts of interest for those involved in LGPS funds are contained in various elements of legislation and guidance.

The Public Service Pensions Act 2013
Section 5 of this Act requires that the scheme manager (in the case of the LGPS, this is the administering authority) must be satisfied that a local pension board member does not have a conflict of interest at the point of appointment and from time to time thereafter. It also requires local pension board members (or nominated members) to provide reasonable information to the scheme manager for this purpose.

The Act defines a conflict of interest as “a financial or other interest which is likely to prejudice the person’s exercise of functions as a member of the board (but does not include a financial or other interest arising merely by virtue of membership of the scheme or any connected scheme).”

Further, the Act requires that scheme managers must have regard to any such guidance that the national scheme advisory board issue.

The Local Government Pension Scheme Regulations 2013
Regulation 108 of these Regulations applies the requirements of the Public Service Pensions Act (as outlined above) to the LGPS, placing a duty on each administering authority to satisfy itself that local pension board members do not have conflicts of interest on appointment or whilst they are members of the board. It also requires those pension board members to provide reasonable information to the administering authority in this regard.

Regulation 109 states that each administering authority must have regard to guidance issued by the Secretary of State in relation to local pension boards. Further, regulation 110 provides that the national scheme advisory board has a function of providing advice to administering authorities and local pension boards. At the point of writing this Policy, the shadow LGPS national scheme advisory board has issued guidance relating to the creation of local pension boards including a section on conflicts of interest. It is expected that this guidance will be adopted by the scheme advisory board when it is established and possibly also by the Secretary of State. This Conflicts of Interest Policy has been developed having regard to that guidance. The guidance can be viewed at: www.lgpsboard.org/index.php/about-the-board/board-guidance

The Pensions Act 2004
The Public Service Pensions Act 2013 added a number of provisions to the Pensions Act 2004 related to the governance of public service pension schemes and, in particular, conflicts of interest.

Section 90A requires the Pensions Regulator to issue a code of practice relating to conflicts of interest for pension board members. The Pensions Regulator has issued such a code and this Conflicts of Interest Policy has been developed having regard to that code. The code can be viewed at www.thepensionsregulator.gov.uk/guidance/guidance-conflicts-of-interest.aspx

Further, under section 13, the Pensions Regulator can issue an improvement notice (i.e. a notice requiring steps to be taken to rectify a situation) where it is considered that the requirements relating to conflicts of interest for Pension Board members are not being adhered to.

The Localism Act 2011
Chapter 7 of this Act requires councillors to comply with the code of conduct of their local authority and that code of conduct must be consistent with the Seven Principles of Public Life (set out below). In addition the Act requires that the code of conduct must include provisions requiring the disclosure and registration of pecuniary interests and interests other than pecuniary interests.

The Seven Principles of Public Life
Otherwise known as the ‘Nolan Principles’, the seven principles of public life apply to anyone who works as a public office-holder. This includes people who are elected or appointed to public office, nationally and locally, and all staff in:

the civil service
local government
the police
the courts and probation services
non-departmental public bodies
health, education, social and care services
The principles also apply to all those in other sectors that deliver public services.

Many of the principles are integral to the successful implementation of this Policy. The principles are as follows:

selflessness
integrity
objectivity
accountability
openness
honesty
leadership.
Advisers’ Professional Standards
Many advisers will be required to meet professional standards relating to the management of conflicts of interest, for example, the Fund Actuary will be bound by the requirements of the Institute and Faculty of Actuaries. Information about these requirements can be viewed at: www.actuaries.org.uk/regulation/pages/conflicts_of_interest

Any Protocol or other document entered into between an adviser and the Administering Authority in relation to conflicts of interest, whether as a requirement of a professional body or otherwise, should be read in conjunction with this Policy.

Appendix 2
Other Administering Authority Requirements
In addition to the requirements of this Policy, Joint Advisory Group, Investment Advisory Panel and Pension Board members and co-opted members (including non-voting co-opted members) are required to adhere to the CBMDC Members’ Code of Conduct or the CBMDC Code of Conduct for Employees.

Pension Board Members
In addition to the requirements of this Policy, Pension Board members are required to adhere to the Terms of Reference of the Pension Board.

Employees
In addition to the requirements of this Policy, officers of CBMDC are required to adhere to the CBMDC Code of Conduct for Employees.

Advisers
The Administering Authority appoints its own advisers. There may be circumstances where these advisers are asked to give advice to CBMDC or other scheme employers, or even to scheme members or member representatives such as the Trades Unions, in relation to pension matters. Similarly, an adviser may also be appointed to another administering authority which is involved in a transaction involving the WYPF and on which advice is required. An adviser can only continue to advise the Administering Authority and another party where there is no conflict of interest in doing so.

Where the Pension Board decides to appoint an adviser, this can be the same person, or organisation as is appointed to advise the Investment advisory Panel or joint advisory Group or Fund officers as long as there is no conflict of interest between the two roles.

The key advisers are all expected to have their own policies or protocols on how conflicts of interest will be managed in their relationships with their clients, and these must be shared with the Fund.

Appendix 3
Examples of potential Conflicts of Interest:

a) An elected member on the Joint Advisory Group or Investment Advisory Panel is asked to provide views on a funding strategy which could result in an increase in the employer contributions required from the employer he or she represents.
b) A member of the Joint Advisory Group or Investment Advisory Panel is on the board of a Fund Manager that is being considered for appointment.
c) An officer of the Fund or member of the Joint Advisory Group or Investment Advisory Panel accepts a dinner invitation from a service provider who has submitted a bid as part of a tender process.
d) An employer representative on the Pension Board is employed by a company to which the administering authority has outsourced its pension administration services and the Pension Board is reviewing the standards of service provided by that company.
e) The person appointed to consider internal disputes is asked to review a case relating to a close friend or relative.
f) An officer of the Fund is asked to provide guidance to the Pension Board on the background to an item considered at the Joint Advisory Group or Investment Advisory Panel. This could be a potential conflict as the officer could consciously or sub-consciously avoid providing full details, resulting in the Board not having full information and not being able to provide a complete view on the appropriateness or otherwise of that item.
g) An employer representative employed by the administering authority and appointed to the Pension Board to represent employers generally could be conflicted if he or she only acts in the interests of the administering authority, rather than those of all participating employers. Equally, a member representative, who is also a trade union representative, appointed to the pension board to represent the entire scheme membership could be conflicted if he or she only acts in the interests of their union and union membership, rather than all scheme members.
h) A Fund adviser is party to the development of a strategy which could result in additional work for their firm, for example, providing assistance with monitoring the covenant of employers.
k) An employer representative has access to information by virtue of his or her employment, which could influence or inform the considerations or decisions of the Joint Advisory Group, Investment Advisory Panel or Pension Board. He or she has to consider whether to share this information in light of their duty of confidentiality to their employer. Their knowledge of this information will put them in a position of conflict if it is likely to prejudice their ability to carry out their functions as a member of the Joint Advisory Group, Investment Advisory Panel or Pension Board.

1. Legislative requirements

1.1 In accordance with the Pensions Act 2004, every individual who is a member of a pension board must be conversant with:

• the rules of the Local Government Pension Scheme (LGPS) , in other words the rsegulations and other regulations governing the LGPS (including the Transitional Regulations, earlier regulations and the Investment Regulations); and
• any document recording policy about the administration of the Fund which is for the time being adopted in relation to the Fund,

1.2 Board members should also have knowledge and understanding of:

• the law relating to pensions; and
• such other matters as may be prescribed.

1.3 Board members' legal responsibilities begin from the day they take up their role and therefore they should immediately start to familiarise themselves with the documents as referred to in Appendix A and the law relating to pensions.

1.4 Board members must ensure they have the appropriate degree of knowledge and understanding to enable them to properly exercise their functions as a member of the board.

1.5 Board members are required to be able to demonstrate their knowledge and understanding and to refresh and keep their knowledge up to date. Board members should maintain a written record of relevant training and development.

1.6 The Scheme Manager is required to maintan and develop the framework.

2. Degree of knowledge and understanding

2.1 Being conversant with the rules of the LGPS and any documents recording policy about the administration of the Fund means having a working knowledge so they can be used effectively when carrying out their role of assisting the administering authority.

2.2 Board members should understand the rules and documents in enough detail to know where they are relevant to an issue and where a particular provision or policy may apply. Details of West Yorkshire Pension Fund’s (WYPF) policies etc. can be found at Appendix A

2.3 The rules of the LPGS include the LGPS Regulations, Investment Regulations, Transitional Regulations (including earlier regulations as defined in the Transitional regulations) to the extent they remain applicable and any statutory guidance referred to in the regulations.

2.4 To ensure knowledge and understanding of the pension board is maintained 50% of the board will be appointed on a two year rolling basis. Any member replaced before the expiry of their normal term will serve for the remainder of that term only, when they will be eligible to service for further full terms in accordance with the Terms of Reference.

3. Induction training

As part of the induction training, board members are required to undertake the Pensions Regulator’s online toolkit training. This training will enable board members to meet the minimum level of knowledge and understanding introduced in the Pensions Act 2004

The toolkit included nine Essential Learning for Trustee compulsory modules and seven Public Sector toolkit compulsory learning modules.

The nine Essential Learning for Trustees compulsory models test Pension Board member knowledge in the following areas:

• Introducing pension schemes
• The trustee’s role
• Running a scheme
• An introduction to investment
• How a defined benefit scheme works
• Funding your defined benefit scheme
• Defined benefit recovery plans. Contributions and funding principles
• Investment in a defined benefit scheme

The seven Public Sector Toolkit compulsory modules test Pension Board member knowledge in the following key areas:

• Conflicts of Interest
• Managing Risk and internal controls
• Maintaining accurate member data
• Maintaining member contributions
• Providing information to members and others
• Resolving internal disputes
• Reporting breaches of the law

The Pensions Regulators website is: www.thepensionsregulator.gov.uk/public-service-schemes.aspx

4. Training

4.1 Board members are expected to attend regular training events.

4.2 In addition to the Pensions Regulator Toolkit. Pension Board members will be invited to undertake training and development as detailed in the CIPFA Knowledge and Skills framework.

4.3 Training will be delivered through a variety of methods including:

• in-house training days provided by officers and/or external providers
• training as part of meetings provided by officers and/or external advisers
• external training events
• circulation of reading material
• attendance at seminars and conferences offered by industry- wide bodies, and
• links to on-line training

5. CIPFA Knowledge and Skills Framework

5.1 In an attempt to determine the right skill set involved in decision making CIPFA has developed a technical knowledge and skills framework

5.2 In total there are six areas of knowledge and skills identified as the core technical requirements for those working in public sector pensions These are:

• Pensions legislative and governance context
• Pensions accounting and auditing standards
• Financial services procurement and relationship management
• Investment performance and risk management
• Financial markets and products knowledge
• Actuarial methods, standards and practices.

5.3 Training Needs Analysis can be used to help assist Board members and the scheme managers to identify areas of the CPIFA Knowledge and understanding framework where training is required.

Appendix A

You must have a working knowledge of the following policies:

You can find minutes of meetings at bradford.moderngov.co.uk.