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Member communications

CDC code in force: 1 August 2022

It is well understood that effective communications are critical to the success of a CDC scheme. It is imperative that members understand the risks and benefits of the scheme. Clear and accessible information for members on how their benefits may increase or decrease will be crucial.

We expect there to be a focus on producing member communications as well as the IT functionality needed. (Note that we will assess the functionality, quality and maintenance of the IT systems used for member communications on the same basis as the IT systems more generally.)

To produce effective communications, there must be appropriate systems and processes in place and individuals who have appropriate skills to undertake the planning and assessment workMM1. In assessing the scheme, we will expect to see the following:

Requirement Matters more likely to satisfy TPR

People
  • There is a responsible person with appropriate expertise.
  • There are individuals appointed who have the appropriate skills to develop, assess and implement effective communications. If outsourced, we expect the same due diligence to be conducted as for other external service providers.
  • The planned resources include all relevant parties, including the scheme actuary, administrator, employer and representative bodies such as unions.
  • The necessary individuals have enough capacity to do the work needed.
Communications plan
  • There is a plan for producing and issuing member communications.
  • The plan needs to set out activities for the year and must cover reviews of communications, member engagement and reporting. We do not expect all scheme communications to be reviewed each year but do expect regular reviews of key communications that impact members.
  • It should include a mechanism to measure the effectiveness of the member communications in increasing member engagement with the scheme (for example developing an engagement dashboard).
  • The plan covers all new and existing legal requirements in respect of member communications.
  • The plan includes the scheme actuary’s annual review for the viability certificate.
Quality assurance
  • There is an evidence-driven process for creating, reviewing (including that the content is accurate and not misleading) and maintaining member communications in a timely manner.
  • There is evidence that the distribution channels used are appropriate and accessible for the membership.
  • There is a clear process for proactively reviewing member communications, as well as reviews following feedback, to ensure they remain fit for purpose.
  • The process seeks and incorporates feedback from trustees, employers, members, unions or other representative bodies.
  • There is evidence of how the process has been used to develop key communications such as the member booklet and annual benefit statement.
Members
  • Members are actively encouraged to give feedback on communications and raise concerns.
  • There are clear and simple channels for members to give feedback.
  • As part of the process of developing and routinely maintaining communications, views must be sought from a range of members who are representative of the membership as a whole.
  • This process needs to test whether that range of representative members are able to understand the communication, including the description of any impact on their benefits and the level of risk involved. We will also want to understand how this work will be used to improve the effectiveness of member communications.
  • There is evidence of the methods used to gather member feedback and its outcomes. This could include surveys to establish members’ understanding of the risks and benefits.
  • Where ad hoc feedback is received from members it must be considered and, where appropriate, acted on.
ReportingMM2
  • A report must be provided to the trustees on how feedback from members has been taken into account.
    • This report should be provided quarterly, or at a different frequency to align with trustee meetings.
    • It should summarise the feedback from members (unless no feedback has been received in that quarter) and whether it was proactively sought from members or whether concerns had been raised by members.
    • It should set out any complaints received in respect of member communications.
    • It should set out how the feedback has been considered and what action will be taken. The rationale for making changes, or not, should be set out.
    • The purpose of the report is to enable trustees to monitor progress against the communications plan and identify any additional actions needed.
  • A report must be provided to members on how their feedback on communications has been taken into account.
    • This report should be provided at least annually.
    • It should summarise the feedback from members and any action that has been taken in response.
    • It should explain why changes have or haven’t been made.
    • It should summarise any planned work on communications over the next reporting period.
    • It should explain the importance of members reading and understanding communications from the scheme, and how they can raise concerns and give feedback.

Legal references

MM1 Paragraph 4 of Schedule 4 to the Regulations

MM2 Paragraph 6(d) of Schedule 4 to the Regulations

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