Effective system of governance (ESoG) and Own Risk Assessment (ORA) – the ‘new normal’ for pension scheme governance
The role of the trustee board is fundamentally straightforward: pay the right benefits to the right members at the right time. However, if any elements of a scheme’s governance are not operating effectively, what once seemed straightforward can quickly seem quite challenging.
The Pension Regulator’s (TPR) new general code of practice has brought big changes for pension scheme governance.
Previously, trustees had to establish and operate internal controls which were adequate for the administration and management of the scheme and the safe custody and security of the assets.
Now, trustees must establish and operate an effective system of governance (ESoG) including internal controls, which must be proportionate to the size, nature, scale and complexity of the activities of the scheme.
More than ever before, trustee boards are reaching out to professional trustees for assistance. At Dalriada, we are ideally placed to help as we have oversight of the complete governance spectrum. Our team of over 200 pensions professionals includes colleagues who helped construct the legislation relating to the ESoG and ORA. In our role as professional trustee for more than 300 schemes, we have a holistic view of the whole system of governance and can support your scheme’s Risk Management and Internal Evaluation Functions.
Dalriada can help ensure an effective system of governance
evaluate your scheme risks
apply proportionality
prevent conflicts of interest and
ensure the trustee board has the appropriate Trustee Knowledge and Understanding (TKU) to challenge advisers.
While other professional services firms can also assist trustees with the risk management function, they can do this only within their specific area of expertise. As an independent professional trustee, Dalriada sees the bigger picture across a wide variety of pension schemes, approaches scheme governance through a trustee lens and works in the best interests of pension schemes and their members, to ensure effective governance and better outcomes.
For example, our team encompasses a variety of personal, educational and professional backgrounds, and a wide range of disciplines that can bring real diversity of representation and thought to trustee boards, helping to avoid decision making bias. And our experience and knowledge of working with schemes and advisers across the pensions industry means we understand what is required proportionately for each scheme’s specific circumstances, can evaluate the performance of advisers and provide challenge where appropriate.
Find out more about risk management and internal controls.
Own risk assessment (ORA) – not a ‘one and done’ exercise
Trustees of schemes with 100 or more members must also “carry-out and document an own risk assessment [ORA]”. In TPR’s words, “The ORA is a substantial process, and the governing body may need to expand its risk assessments to fulfil our expectations.”
So, not only will trustees need to ensure that the governance and administration of their scheme is effective they will also need to evidence this and, for schemes with 100 or more members, record their assessment of it.
Ongoing requirements
And don’t forget, the requirement for an effective, evidence-based and proportionate system of governance for your scheme is an ongoing requirement. Dalriada can help carry out and document subsequent ORAs at regular intervals and review these whenever there is a material change in the risks facing the scheme, or to its governance processes.
We’ll help ensure your normal governance is the ‘new normal’. Read our blog series on the new normal for scheme governance.
