In light of the Pensions Regulator (TPR) consultation on conflicts of interest trustees of defined-benefit and defined contribution schemes may want to consider implementing a conflicts policy for their pension scheme.
Conflicts of interest for individual trustees and directors of trustee companies may arise as result of a trustee having another role such as where the trustee is also a scheme member, trade union officer, director or senior employee of the employer. Conflicts of interest may also arise in certain situations such as when a trustee holds a senior role in the employer.
In February 2008 TPR published its consultation on conflicts of interest. One of the key principles recommendations contained in the consultation document was for schemes to adopt a conflicts of interest policy.
TPR commented that: “A key to any successful conflicts management programme will be the production of a policy (or protocol) outlining the processes for identifying, monitoring and managing conflicts.”
Please see our client briefing for background on the issues that trustees may want to consider in light of TPR’s consultation document.