The General Code – mind the gaps

Find the gaps

Are you wondering where to start or to resume work relating to the General Code?  There’s no need to panic!  Many schemes will already be operating policies, procedures and other governance tools, and completing a gap analysis checklist can be a useful exercise in working out what’s already in place.

Work out your priorities

Where a completed gap analysis checklist indicates there are a number of gaps to be filled, we suggest identifying a priority order in which to plug those gaps to help break up the task of gap-filling into manageable chunks. There are different ways a scheme might choose to go about this depending on their key risks and priorities. However, as a starting point, it could be helpful to identify:

  • if are there any policies or procedures that are required under the General Code to form part of the ESOG (eg a remuneration policy) that are not already in place or that are not currently written down
  • whether any of the “missing” policies and procedures relate to a legal obligation or a key risk for the scheme, and
  • if are there any areas that appear to be sizable gaps in terms of the work that will need to be done to fill them. These could be areas that it makes sense to prioritise, but it may also be necessary to plan the work so that it can be done effectively.

Look at the content of what you already have

Once gaps have been filled (which will be the topic of our next instalment of General Code Corner), schemes can then turn to considering if any existing policies or procedural documents are significantly out-of-date.  This could be because the legal position or scheme practice has moved on.  During the review stage, it also makes sense to consider other reasons for review, including whether there are areas of scheme governance where there would be a genuine benefit to the scheme if improvements are made.  As with filling gaps, reviews and updates should reflect the scheme’s priorities and key areas of risk.

It can also be helpful to remember that the ESOG is intended to evolve over time with the scheme’s circumstances, so it’s unlikely that every document will ever be “finished”. Trustees should focus resources on what is most needed in the context of their scheme’s governance framework, its key risks and its goals for the future.

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