Stuart O’Brien contributes to PLSA guide on new trustee investment disclosure duties


The PLSA has published guidance to help DB and DC trustees navigate the new requirements to publicly disclose their investment and responsible investment activity over the previous year in an “Implementation Statement”.

The new duties from the Department for Work and Pensions (DWP) require trustees to disclose how and to what extent their investment action over the course of the previous year follows the investment intent, as set out in the scheme’s Statement of Investment Principles (SIP).

The requirements differ for trustees of DC/hybrid and DB-only schemes, with DC/hybrid schemes required to disclose against all parts of their SIP and DB-only schemes required only to disclose on their voting and engagement behaviour.

The PLSA’s guidance offers practical, step-by-step support for trustees to produce meaningful and relevant disclosures.

This guidance builds upon the PLSA’s popular 2019 guide for trustees on ESG and stewardship although its scope is broader, covering the full investment implementation aspects of these new Statements. It sets out:

  • What the legislation requires and by when
  • Both general principles and more detailed possible considerations for trustees to produce good statements
  • The specific considerations around voting behaviour disclosures
  • ‘Top tips’ for investment and responsible investment communications.

The guidance was produced by the PLSA’s Voting and Implementation Statement Working Group (VISWG), a cross-industry group of experts, as well as by a Stakeholder Group comprised of representatives from government, regulators and industry organisations.

Stuart O’Brien, Sackers Partner and contributing member of VISWG, commented: “Implementation statements are going to be a new challenge for trustees. The content and timing requirements are complex, and trustees will also need to get to grips with what questions they should be asking their managers and how they can best present the required information for their members. The new PLSA Guide seeks to provide some clarity on these issues and some practical tips for trustees to get started. It’s been a privilege to work with such a great team in helping to put this helpful guide together.”

The guide can be downloaded here.

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