The new Code of Practice for Professional Corporate Sole Trustees of Pension Schemes (PCTSs) was published on 1 January 2021. The Code of Practice sets out guidance as to the processes and procedures which firms as acting as a PCST should implement and maintain these obligations falling on APPT members in relation to PCST appointments.
We’ve recorded a webinar on ‘How to comply with AAF requirements for the APPT PCST Code relating to sole trusteeships’ which you can access here.
Initial Appointment – Due diligence procedures should be put in place ensuring the sponsoring employer can decide whether to accept or not accept the appointment as a PCST.
Evolving from Joint Trustee to PCST – Due diligence procedures should also be performed where a trustee becomes a PCST through the death, retirement, resignation or removal of other trustees.
Removal and/or resignation of a PCST – Where required, the removal/resignation should be drawn to the attention of The Pensions Regulator.
Independence from the sponsoring employer – A Sponsoring Employer Independence Policy should be maintained.
Negotiations with the Employer – Procedures should be in place for when negotiations with the sponsoring employer to ensure they are conducted accurately.
There should be a documented Decision Process outlining how decisions are taken and recorded so there is no influence from external individuals. Where there is a material decision to be made, at least two Accredited Professional Trustees should be involved.
Diversity and inclusion should be considered by the PCST firm during their decision-making.
Appointment – Appointments of advisers and service providers should be based on the needs of the scheme which should be documented.
Review – Reviews should be performed once every three years.
Conflicts of interest – If appointed on multiple connected schemes, there should be appropriate processes in place to manage the conflicts.
It is a requirement of the Standards that PCST firms provide assurance reporting on internal controls in accordance with “ICAEW Relevant Trustee Supplement AAF 02/07 (TECH 04/13 AAF)”
Would you like to know more about how the requirements outlined within AAF can help support you meet the new Code of Practice, we’ve prepared a webinar on ‘How to comply with AAF requirements for the APPT PCST Code relating to sole trusteeships’ which you can access here.