As a trustee of a defined benefit scheme you should be ready for any employer events that could cause concern to pension scheme members and which may also prompt them to think about transferring their benefits.
If members become concerned about an employer event they may make decisions about their pension that are not in their best interests.
At these times you may need to communicate quickly with members and other stakeholders. You should have an overall plan in place to inform and educate members in these situations.
Important
If you think a situation is already occurring, you should take steps to deal with an employer event that causes concern to members.
Events that could cause concern
Members may become particularly concerned when the employer supporting the scheme is in financial distress or is restructuring as part of insolvency.
Make sure you have a good plan in place to monitor the employer covenant and that you are aware of the early warning signs of an employer restructuring event.
Members may also be concerned by certain events where the employer is not in financial difficulty. This includes:
- reorganisations when the employer is solvent
- corporate transactions
- exercises to redesign employee benefits
- where the employer decides to run an incentive exercise
You should have risk management controls in place to identify the various employer events which could adversely impact on members’ benefits.
Communicating as part of contingency planning
Preparing for the need to communicate rapidly with members and other stakeholders should form an integral part of your contingency planning. Your planning should cover a range of possible situations that could affect the scheme.
You could consider:
- shortlisting professional communications and media relations advisers to help you
- having training for trustees on possible scenarios, and communications and media strategies
- dedicated media training for one or more trustees who could be required to act as a spokesperson
You may also need to communicate with a range of other stakeholders including employee representatives and trade unions, the media and politicians.
Your contingency planning should factor in the size, demographic and geographic distribution of the scheme’s members.
For further information, read:
Record-keeping
You should make sure that your scheme has accurate and up-to-date member records. This includes contact details for all members.
It could be very problematic if you leave a member tracing exercise until an employer event occurs that requires rapid communication.
Read more about record-keeping duties.
Information-sharing protocol
You should negotiate a robust information-sharing protocol with the employer. You may need the support of your professional advisers to do this. The protocol should help by:
- providing you with early warning of corporate events before they appear in public
- creating extra time to plan and prepare communication materials
- giving you the chance to participate on an equal footing with other financial stakeholders if the employer restructures
You will need information such as:
- financial performance
- prospective changes to the capital structure of the employer group
- other corporate events that could affect the financial strength or ultimate control of the employer
The protocol should allow you to share information with your advisers and ideally to stakeholders in any restructuring that impact the scheme, such as PPF and us.
If unpublished price-sensitive information is involved, you should consider having a small sub-set of the trustees enter into non-disclosure agreements. This will allow them to access the information.
Trustee toolkit online learning
The Trustee toolkit contains information on running a defined benefit scheme. This includes corporate transactions and record-keeping. You must log in or sign up to use the Trustee toolkit.