On February 22, 2023, the Regulator launched a new campaign to ensure that trustees are complying with their environmental, social and governance and climate change reporting duties. Under the new reporting duties, trustees of schemes with 100 or more members are required to publish their statement of investment principles and implementation statement on a publicly available, free to access, website. Additionally, schemes with relevant assets of £1bn or more, as well as authorised master trusts and collective money purchase schemes, must publish an annual climate change report (the TCFD report).
The Regulator will check whether trustees are publishing their SIPs and that these contain the policies in relation to ESG and climate change factors. The Regulator will also monitor compliance by analysing scheme return data and review a cross-section of SIPs and implementation statements. The outcome of this review will be published to highlight good practice.
Subsequently, the Regulator published a review of a selection of pension schemes’ annual climate reports, which has revealed several areas for improvement for schemes and some emerging good practice.
Some of the common areas for improvement across the scheme reports were a lack of sufficient background information on the scheme, disclosures of strategy and scenario analysis. There were also various accessibility issues that could make it difficult for savers and others to find and the reports online.
However, several reports contained examples of trustees taking appropriate action, including:
- Planning climate and sustainability training for trustees and those involved in the governance of climate-related risks and opportunities.
- Developing a trustee policy on investment beliefs in relation to climate change.
- Working with investment managers to obtain better data.
- Allocating more funds to sustainable investments.
- Using stewardship to manage climate-related risk.
- Switching to climate-tilted pooled funds.
The Regulator sees climate change as continuing to pose a core financial risk to savers’ pensions for the foreseeable future, and it urges trustees in scope of the regulations to read the review and consider how they can improve their governance and reporting of climate-related risks and opportunities. Smaller schemes, not currently in scope, may also find the results of the review useful in improving their management of climate-related risk and opportunities.
Separately, the Society of Pension Professionals has updated its ESG guidance aimed at pension scheme trustees. The ESG Guide 2023 “aims to give a high-level overview…, including possible approaches for different investment structures, details of the underlying legal obligations and how to engage with investment managers and advisers”.
Issues covered in the guide include how the scheme’s investments are held and trustees' legal obligations. The guide also outlines a suggested approach/framework for trustees.
