Teesside Pension Fund. Statement of Investment Principles

Similar documents
Contents 1. INTODUCTION 3 2. INVESTMENT RESPONSIBILITIES 3 3. THE MYNERS PRINCIPLES 4 4. TYPES OF INVESTMENTS TO BE HELD 6

1. Introduction. 2. Investment Responsibilities

NORTH YORKSHIRE PENSION FUND STATEMENT OF INVESTMENT PRINCIPLES

Shetland Islands Council Pension Fund. Statement of Investment Principles

Statement of Investment Principles. London Borough of Harrow Pension Fund

West Midlands Pension Fund. Investment Strategy Statement 2017

NORTH YORKSHIRE PENSION FUND INVESTMENT STRATEGY STATEMENT

Investment Strategy Statement: September 2018

Falkirk Council Pension Fund

West Midlands Pension Fund. Statement of Investment Principles 2016

Statement of Investment Principles

Pensions Statement of Investment

NORTH YORKSHIRE PENSION FUND INVESTMENT STRATEGY STATEMENT

Nottinghamshire Pension Fund INVESTMENT STRATEGY STATEMENT. Introduction. Purpose and Principles. March 2017

LONDON BOROUGH OF HARROW PENSION FUND INVESTMENT STRATEGY STATEMENT

Statement of Investment Principles

The Co-operative Pension Scheme ( Pace )

STATEMENT OF INVESTMENT PRINCIPLES Feb 2017

RHONDDA CYNON TAF COUNTY BOROUGH COUNCIL RHONDDA CYNON TAF PENSION FUND INVESTMENT STRATEGY STATEMENT

THE LAFARGE UK PENSION PLAN STATEMENT OF INVESTMENT PRINCIPLES DEFINED BENEFIT SECTION

INVESTMENT STRATEGY STATEMENT September 2017

Kent County Council Superannuation Fund

STATEMENT OF INVESTMENT PRINCIPLES

LONDON BOROUGH OF NEWHAM PENSION FUND

LONDON BOROUGH OF HARINGEY PENSION FUND INVESTMENT STRATEGY STATEMENT. 1. Introduction

Statement of Investment Principles

STATEMENT OF INVESTMENT PRINCIPLES NEW AIRWAYS PENSION SCHEME

Statement of Investment Principles

Investment Strategy Statement (June 2018)

Myners Principles - Application Principle Best Practice Guidance (CIPFA) Havering Position/Compliance

New Airways Pension Scheme (NAPS) STATEMENT OF INVESTMENT PRINCIPLES

New Airways Pension Scheme (NAPS) STATEMENT OF INVESTMENT PRINCIPLES

Statement of Investment Principles

London Borough of Hackney Pension Fund. Investment Strategy Statement

The Royal Bank of Scotland Group Pension Fund Statement of Investment Principles

London Borough of Bexley Pension Fund. Statement of Investment Principles. Background. Contents

AGENDA ITEM 6 REPORT NO. PC/03/18

Statement of Investment Principles January 2017

Merchant Navy Officers Pension Fund (MNOPF) Statement of Investment Principles

BCF Pension Trust Statement of Investment Principles

LONDON BOROUGH OF REDBRIDGE PENSION FUND INVESTMENT PANEL

Trustee Statement of Investment Principles

eastsussex.gov.uk Investment Strategy Statement

Statement of Investment Principles University of Oxford Staff Pension Scheme (Defined Benefit)

Jones Lang LaSalle Retirement Benefits Scheme. Statement of Investment Principles August Background

3 The Trustee has sought written advice from the RBS Investment Executive Limited in preparing the SIP.

Statement of Investment Principles

P a g e 1

eastsussex.gov.uk Investment Strategy Statement

Milford Unit Trust PIE Funds. Statement of Investment Policy & Objectives

West Midlands PTA Pension Fund. Statement of Investment Principles

GSK Pension Fund ( the Fund ) Statement of Investment Principles

Guide to Risk and Investment - Novia

GW Contracted-out Money Purchase Scheme ( the Scheme ) Statement of Investment Principles

April Environment Agency Active Pension Fund Investment Strategy Statement

Statement of investment principles. April 2018 to March 2021

Milford KiwiSaver Plan Statement of Investment Policy & Objectives. Investment Policy. & Objectives. Statement of

Partners Group Global Value Fund (AUD) ARSN Annual report For the year ended 30 June 2018

LONDON BOROUGH OF LAMBETH PENSION FUND

Statement of Investment Principles

Investment Principles 2010

Information for investors

STATEMENT OF INVESTMENT PRINCIPLES (SIP) IN RESPECT OF EDS RETIREMENT PLAN and EDS 1994 PENSION SCHEME (Plans)

SmithKline Beecham Senior Executive Pension Plan ( the Plan ) Statement of Investment Principles

L1 Capital UK Residential Property Fund ARSN Annual report For the period 25 July 2017 to 30 June 2018

BBC Pension Scheme STATEMENT OF INVESTMENT PRINCIPLES

UNIVERSITY OF GUELPH PENSION PLANS. Statement of Investment Policies and Procedures. Effective September 27, 2012

PENSION SCHEME. Statement of Investment Principles

Kent County Council Superannuation Fund

Investment Strategy Statement

BBC Pension Scheme STATEMENT OF INVESTMENT PRINCIPLES

TREASURY MANAGEMENT POLICY The Association s Treasury Management Policy will be operated by the following principles:

Pensions. Investment Strategy. Statement. Your Guide to the London Borough of Croydon Investment Strategy. Statement

Partners Group Global Real Estate Fund (AUD) ARSN Annual report For the period 30 March 2016 to 30 June 2017

ESSEX PENSION FUND Statement of Investment Principles 25 March 2015

Kent County Council Superannuation Fund

Pensions. Investment Strategy. Statement. Your Guide to the London Borough of Croydon Investment Strategy. Statement

Vodafone UK Defined Contribution Pension Plan

INVESTMENT POLICY. January Approved by the Board of Governors on 12 December Third amendment approved with effect from 1 January 2019

Cambridge University Endowment Fund. Reports and financial statements 30 June 2014

STATEMENT OF INVESTMENT PRINCIPLES

The Nuclear Liabilities Fund. Statement of Investment Principles. 19 June 2018

What are the changes to the funds available to me (UP960)?

YOUR GUIDE TO OUR FUNDS NFU MUTUAL FUND GUIDE

Finance Services. London Borough of Redbridge Pension Fund Investment Panel. Annual Review 2005/06

Statement of Investment Principles University of Oxford Staff Pension Scheme (Defined Contribution)

eastsussex.gov.uk Responsible Investment Policy

Principle 1 Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities

THE LOCAL AUTHORITIES PROPERTY FUND

Treasury Management Framework v Page 1 of 28

1 SCOPE AND OBJECTIVES 1 2 RISK MANAGEMENT 1 3 DECISION MAKING AND ANALYSIS 1 4 APPROVED INSTRUMENTS, METHODS AND TECHNIQUES 1

BERMUDA MONETARY AUTHORITY THE INSURANCE CODE OF CONDUCT FEBRUARY 2010

Statement of Investment Principles

Cbus In this Policy 01 Purpose and objectives of the Policy 02 Application 03 Accountability 04 Key Legislative Obligations and Trustee Powers

Treasury and Investment Policy

ENHANCE - CONSTRUCTION PENSION SCHEME NORTHERN IRELAND CHAIRMAN S ANNUAL STATEMENT REGARDING DC GOVERNANCE

Responsible Investment Policy

Wilshire Australia Private Markets Pooled Superannuation Trust ABN Annual financial report - 30 June 2016

GANES FOCUSED VALUE FUND

Standard Life Stanplan A. Statement of Investment Principles

Transcription:

Teesside Pension Fund Statement of Investment Principles 2011

CONTENTS 1. INTRODUCTION... 2 2. INVESTMENT RESPONSIBILITIES... 3 3. THE MYNERS PRINCIPLES... 4 PRINCIPLE 1: EFFECTIVE DECISION-MAKING... 4 PRINCIPLE 2: CLEAR OBJECTIVES... 5 PRINCIPLE 3: RISKS AND LIABILITIES... 5 PRINCIPLE 4: PERFORMANCE ASSESSMENT... 5 PRINCIPLE 5: RESPONSIBLE OWNERSHIP... 5 PRINCIPLE 6: TRANSPARENCY AND REPORTING... 6 4. TYPES OF INVESTMENTS TO BE HELD... 6 5. THE BALANCE BETWEEN DIFFERENT TYPES OF INVESTMENT... 8 6. RISK... 9 7. INVESTMENT OBJECTIVES... 12 8. THE REALISATION OF INVESTMENTS... 12 9. INVESTMENT STRATEGY: ETHICAL, SOCIAL & ENVIRONMENTAL PERSPECTIVE... 12 10. SHAREHOLDER GOVERNANCE... 13 11. PERFORMANCE MEASUREMENT... 13 12. COMPLIANCE & MONITORING... 14 1. INTRODUCTION The Local Government Pension Scheme (Management and Investment of Funds) (Amendment) Regulations 1999 require that Local Government Pension Scheme administering authorities prepare, publish and maintain Statements of Investment Principles (SIP). 2 P a g e

This is the Statement of Investment Principals (SIP) of the Teesside Pension Fund ( the Fund ), which is administered by Middlesbrough Council ( the Administering Authority ). It has been prepared by the Administering Authority in collaboration with the Fund s actuary and after consultation with the Fund s employers and investment advisers. 2. INVESTMENT RESPONSIBILITIES The Teesside Pension Fund and Investment Panel (The Investment Panel) has responsibility for: Preparing the Statement of Investment Principles, Monitoring compliance with the Statement and reviewing its contents periodically, Appointing investment managers, advisors and external service providers, Reviewing on a regular basis the investment manager s performance against agreed benchmarks and satisfying themselves as to the manager s expertise, Ensuring that the terms of the Management Agreement have been complied with, Reviewing on an annual basis the internal systems and controls in place to monitor compliance with the Management Agreement. The Director of Resources is responsible for: Ensuring effective internal controls are in place, Overseeing the activity of the Head of Investments & Treasury Management and the Loans & Investment Section, Assisting the Investment Panel in the preparation and review of the SIP and ensuring compliance with its terms, Providing advice, after consultation with the Fund s Actuary, as to the maturity of the Scheme and its funding level in order to assist the Investment Panel in balancing the short term and long term objectives of the Fund. The Head of Investments & Treasury Management is responsible for: The investment of Fund assets in compliance with prevailing legislation and the requirements of the Management Agreement, Implementing the Investment Advisor s recommendations on asset allocation within the parameters laid down, Security selection within asset classes, Preparation of quarterly reports to the Investment Panel and an annual report on investment performance, Reviewing investment management, custodial and other external relationships and advising the Investment Panel as to future policy with a view to delivering continuing improvements within a Best Value regime, 3 P a g e

Implementing the Investment Panel s policies on Shareholder Governance and Ethical, Social and Environmental Investment, Assisting the Director of Resources and the Investment Panel in the preparation of the SIP, its regular review and compliance. The Fund Custodian is responsible for: Ensuring that the Fund s assets are secure and that the Fund is able in a timely fashion to meet its contractual obligations, Its own compliance with prevailing legislation, Providing the Investment Panel with quarterly valuations of the Fund s assets, Collection of all income due to the Fund, Carrying out the instructions received from the Head of Investments & Treasury Management in respect of voting actions. The Investment Advisors are responsible for: Advising the Investment Panel on the most appropriate short term asset allocation for the Fund, Advising the Investment Panel on the most appropriate long term asset allocation for the Fund as part of the Asset/Liability Study, Advising the Investment Panel in the preparation and review of the SIP, Advising the Investment Panel in their regular monitoring of the performance of the investment managers. Advising the Director of resources on matters relating to the strategic direction of the Fund. 3. THE MYNERS PRINCIPLES The Myners Principles have been promoted by the Government as representing best practice for institutional investors. Compliance with the six High Level Principles was agreed by the Investment Panel on 10 th June 2009. These Principles are supported by statutory guidance. The guidance contains examples of good practice, although not every element of the guidance is expected to be implemented, dependent on the circumstances of the particular fund. PRINCIPLE 1: EFFECTIVE DECISION-MAKING Trustees should ensure that decisions are taken by persons or organisations with the skills, knowledge, advice and resources necessary to take them effectively and monitor their implementation. 4 P a g e

Trustees should have sufficient expertise to be able to evaluate and challenge the advice they receive, and manage conflicts of interest. Full compliance PRINCIPLE 2: CLEAR OBJECTIVES Trustees should set out an overall investment objective for the Fund that takes account of the scheme s liabilities, the strength of the sponsor covenant, as well as the attitude to risk of both the trustees and the scheme sponsor, and clearly communicate these to advisors and investment managers. Full compliance PRINCIPLE 3: RISKS AND LIABILITIES In setting and reviewing their investment strategy, trustees should take account of the form and structure of the Fund s liabilities. These include the strength of the sponsor covenant, the risk of sponsor default and longevity risk. Full compliance PRINCIPLE 4: PERFORMANCE ASSESSMENT Trustees should arrange for the formal measurement of the performance of the investments, investment managers and advisors. Trustees should also periodically make a formal policy assessment of their own effectiveness as a decision-making body and report on this to scheme members. Performance of the investment managers is undertaken annually. In addition a fiveyearly review of investment management arrangements is carried out. The position of the advisors, including an assessment of performance, is undertaken periodically. The last such review of advisors was carried out in 2009. The Fund does not have a mechanism for trustees to assess formally their own effectiveness and to report that assessment to scheme members. PRINCIPLE 5: RESPONSIBLE OWNERSHIP Trustees should adopt, or ensure that their investment managers adopt, the Institutional Shareholders Committee Statement of Principles on the responsibilities of shareholders and agents. A statement of the scheme s policy on responsible 5 P a g e

ownership should be included in the Statement of Investment Principles. Trustees should report periodically to members on the discharge of such responsibilities. Full compliance PRINCIPLE 6: TRANSPARENCY AND REPORTING Trustees should act in a transparent manner, communicating with stakeholders on issues relating to their management of investments, its governance and risks, including performance against stated objectives. Trustees should provide regular communication to scheme members in the form they consider most appropriate. Full compliance 4. TYPES OF INVESTMENTS TO BE HELD The following categories of investment have been approved as suitable for investing Teesside Pension Fund monies: UK Equities Overseas Equities provide an equitable share in the assets and profits of public companies. Income is derived from dividends which, although variable in amount from year to year, have historically risen above the rise in inflation. Equities produce capital gains and losses as share prices reflect investors expectations of the prospects of a specific company, sector or market. are similar to UK Equities but allow greater diversification amongst industries and companies than would be available in UK quoted companies alone. They have exposure to the relationship between Sterling and the currency of the market where the share price is listed. Investment returns will be enhanced, or reduced, by fluctuations in that Exchange Rate. However, over the very long term, currencies are likely to reflect differentials in inflation rates and should, therefore, not affect returns on equities materially on such a time scale. Because of the likely excess return from equities (the so-called Equity Risk Premium ) a major proportion of the Fund s assets will probably be held in equities other than in exceptional economic or Fundspecific circumstances. 6 P a g e

UK Bonds Overseas Bonds UK Index Linked Bonds Overseas Index Linked Bonds Property Derivative Instruments Alternative Investments are debt instruments issued by Governments and other borrowers. Bonds provide a fixed rate of interest and are generally redeemed at a fixed price on a known future date. The price of Bonds primarily reflect the fixed level of interest, the period to redemption and the overall return demanded by investors. They are vulnerable to rising inflation and correspondingly benefit from falls in inflation. are similar to UK Bonds but have exposure to currency fluctuations. As with UK Bonds they are influenced by local inflation rates. are bonds issued by Government and other borrowers. They provide interest and redemption value directly linked to a measure of inflation, usually the Retail Price Index, or a measure of change in some other Index. Index Linked Bonds may prove useful in matching some of the Fund s liabilities. are similar to UK Index Linked Bonds but have exposure to currency fluctuations. is investment in land or buildings either directly by the Fund or indirectly through a pooled vehicle. Income comes from rents collected from tenants. Investment in property produces capital gains and losses as prices fluctuate in line with rental levels and investor demand. The contractual nature of rental agreements gives property some of the characteristics of bonds, whilst growth and inflation give it some of the characteristics of equities. It is, therefore, a useful diversifying asset class. such as Traded Options and Futures are mechanisms through which the Fund can be protected from sudden changes in share prices or Exchange Rates. Although not income producing they can produce capital gains and losses. They may be used conveniently to hedge the Fund s exposure to particular markets. are investments in companies, which typically are not listed on a recognised Stock Exchange. Such 7 P a g e

investments can produce income in the form of dividends and can produce capital gains and losses. Because of the inherent lack of liquidity such investments should be expected to produce higher returns. Exchange Traded Funds Pooled Investment Vehicles Cash Underwriting Securities Lending are traded funds (ETF s) usually designed to track an index. They allow investment in specific areas such as commodities. such as Unit Trusts, Limited Partnerships, Open-Ended Investment Companies (OEIC s) and Insurance Funds are an alternative way of investing in shares, bonds and property to provide specialist management expertise and greater diversification. They may permit participation in venture capital and private equity, and in infrastructure projects. is invested in authorised institutions in accordance with the treasury management policy of Middlesbrough Council and will attract interest at market rates. Although it can be adversely affected by inflation, its nominal value remains constant, while that of other asset classes can be volatile. the underwriting of the issue of shares by companies in which the Fund invests or wishes to invest, although not strictly an investment is permitted within the constraints contained within the Management Agreement. the use of securities lending (also known as stock lending), was approved by the Investment Panel, within agreed limits. In practice the Fund has not entered into any securities lending arrangements due to concern about counterparty risk and it is not intended to do so without a further report back to the Investment Panel. 5. THE BALANCE BETWEEN DIFFERENT TYPES OF INVESTMENT The LGPS Regulations require that administering authorities should have regard to the need for diversification of investments in order to reduce the risk of over concentration in one class of investment, which performs badly. 8 P a g e

The Asset/Liability Study, carried out every 3 years, establishes a Benchmark asset mix against which actual Fund performance can be measured. It is recognised that the Teesside Fund is a UK based Fund with the majority of its liabilities in the UK. As part of this process a maximum/ minimum range of % of the Fund to be held in the various categories of investment is determined and is reviewed as part of the Asset/Liability Study process. The range of permitted investment in each asset class, expressed as a % of the Fund, currently agreed, is as follows: Max % Min % GROWTH ASSETS Global Equities 90 50 Property 15 5 Alternatives 10 0 PROTECTION ASSETS Bonds 25 5 Cash 15 0 Because of the Asset/Liability Study the Investment Advisers and the Fund s Actuary recommend an asset mix designed to produce the long-term returns which the Fund requires to meet its future liabilities. On a quarterly basis the Advisors recommend a shortterm strategy to suit current Market conditions. Once accepted by the Investment Panel implementation of that strategy is delegated to the Head of Investments & Treasury Management, or, in his absence, the Fund Manager. 6. RISK There are three forms of risk: 9 P a g e

a) that associated with security of the Fund s assets; b) that associated with loss of value relating to those assets; c) that associated with the ability of those assets to provide required rates of return. a) Security of the Fund s Assets The Fund s Custodian, The Northern Trust Company, holds the majority of the Fund s Assets. An Agreement is in place protecting the Fund against fraudulent loss and regular checks are made by independent Auditors regarding the integrity of the Custodian s systems. In addition the Fund s Direct Property assets are registered in the name of Middlesbrough Council and the Title Deeds and documents held by the Fund s solicitors, Dechert. Cash balances belonging to the Fund are invested in accordance with agreed criteria, which take into account an appreciation of risk. b) Asset Risk The value of all investments can go down as well as up. Even investments in Gilts, securities issued by HM Government, are not without risk. Individual companies can cease to trade, with shareholders well down the list of creditors. The best way to protect the Fund against asset risk is by diversifying into a number of asset classes, a range of countries and a range of companies. The Local Government Pension Scheme (LGPS) Regulations 1986 imposed certain limits on the proportion of the value of the Fund which could be invested in different types of investment. The LGPS (Management and Investment of Funds) Regulations 1998, revised in 2004, introduced changes to these limits, subject to certain conditions being met. The Investment Panel on 11 March 2004 decided that advantage should not be taken of the increased flexibility provided by the changes. c) Investment Risk One of the Trustees most important duties is to make sure that the Fund has enough Assets to pay the benefits already earned by scheme members. On top of that they are looking to achieve sufficient return on those Assets to keep down the cost of building up future benefits. In order to meet these responsibilities the Trustees set a performance benchmark against which they can measure the progress of the Fund s investments. Funds which outperform their benchmark can reduce costs compared with those Funds which under-perform. For the Fund to significantly out-perform its benchmark it needs to have an Asset Mix which is different from that of its benchmark. The more out-performance is required the greater 10 P a g e

the differences will need to be. In other words out-performance cannot be achieved without taking risks. Measurement of risk can identify whether the risk profile is, on one hand, large enough to deliver the required relative returns or alternatively so great as to lead to the possibility of serious underperformance. The Teesside Pension Fund has an asset mix, which varies significantly from that of the Average Fund (as at 31 March 2011): Fund % Average % UK Equities 38 20 Overseas Equities 40 30 Bonds 9 34 Property 5 6 Cash 5 2 Alternatives 3 8 Total 100 100 The result of holding an asset mix, which differs significantly from that of the Average, is that investment performance returns can be volatile compared with those achieved by the Average Fund. This could result in periods of underperformance. The Asset/Liability Study, carried out every three years by the Fund Actuary in conjunction with the Fund s Investment Advisors, assesses the degree of risk which the Fund needs to incorporate into its investment strategy, mainly expressed as the split between bonds and equities, in order to meets its liabilities and in particular to achieve the goal of employer contribution rates which are both low and stable. The Fund's Funding Strategy Statement sets out the assumed real rate of return, that is the rate of return above the return on Government Index-linked bonds, on the various categories of investment: 11 P a g e

Return per annum % UK Equities 3.0 Overseas Equities 3.0 Bonds 2.5 Property 3.5 Cash 1.0 7. INVESTMENT OBJECTIVES The Fund invests monies received which are not immediately required to pay benefits. The long-term objective of this pool of investments is to have sufficient money available to meet future liabilities, in the form of benefits to its members, and at the same time to minimise the contribution payable by the Scheme employers. The Fund Actuary, as part of the triennial Valuation process, estimates the average annual rate of return which the Fund s investments would have to achieve, in the long term, in order to meet the Fund s liabilities. The triennial valuation includes a risk assessment in relation to the valuation of its liabilities and assets and the chief finance officer will report to the committee if, at any time, there is reasonable doubt about the valuation. 8. THE REALISATION OF INVESTMENTS The majority of investments should be readily marketable, so that the proceeds of sale should be available within two weeks. It is recognised that certain categories of investment, typically Property and unquoted securities are more difficult to sell. The Fund s cash balances will be managed in such a way as to ensure that sufficient balances are available to meet foreseeable demands, including payments to beneficiaries and monies which may be required to meet investment needs. 9. INVESTMENT STRATEGY: ETHICAL, SOCIAL & ENVIRONMENTAL PERSPECTIVE 12 P a g e

A report to the Investment Panel on 12 March 1999 established the Fund s position on Ethical, Social & Environmental investment and agreed revised Guidelines. As a responsible investor, the Teesside Pension Fund wishes to promote corporate social responsibility, good practice and improved company performance amongst all companies in which it invests. The Fund will therefore monitor investee companies to ensure they meet standards of best practice in relation to their key stakeholders. The Fund considers that the pursuit of such standards aligns the interests of Fund members and beneficiaries with those of society as a whole. In furtherance of this policy, the Fund will support standards of best practice on disclosure and management of corporate social responsibility issues by companies and will pursue constructive shareholder engagement with companies on these issues consistent with the Fund s fiduciary responsibilities. The Fund will explicitly consider climate change risks and opportunities in the investment process and engage with companies in which we invest to ensure that they are minimising the risks and maximising the opportunities presented by climate change and climate policy. The Fund has adopted the Institutional Shareholders Committee Statement of Principles and members will agree and periodically review its implementation. In accordance with this policy, the Fund will seek where necessary through its own efforts and in alliances with other investors to pursue these goals. To this end the Fund is an active member of the Local Authority Pension Fund Forum. 10. SHAREHOLDER GOVERNANCE The Fund believes that its role as shareholder requires it to exercise its voting rights in companies in which it invests. In furtherance of the policy the Investment Panel has agreed voting guidelines to enable the policy to be implemented. Following the appointment of PIRC as the Fund s service provider in 2008 revised guidelines were determined. These guidelines are available on the Fund s website www.teespen.org The Fund s shareholder governance policy is restricted to the Fund s UK holdings. 11. PERFORMANCE MEASUREMENT 13 P a g e

Fund performance is measured by the independent performance measurers, the WM Company and reported to the Investment Panel annually. Although this compares the performance of the Fund against other Funds and the customised benchmark, the key measure of performance is against the Fund s liabilities. This methodology is used when carrying out the Asset/Liability Study. 12. COMPLIANCE & MONITORING The Head of Investments & Treasury Management will submit a revised Statement to the Investment Panel when there has been a material change of policy or where circumstances require. Any interim changes necessary must be approved by the Investment Panel or, when circumstances dictate, by the Chair and will be incorporated in a revised Statement at the end of each year. The Statement is published on the Pension Fund website and copies are available, on request, to Scheme Members. 14 P a g e