STATEMENT OF INVESTMENT PRINCIPLES
for theNomura London Retirement Benefits Plan
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August 2022
1.

Introduction

1.1. What is the purpose of this Statement of Investment Principles?
This Statement of Investment Principles (“SIP”) sets out the policy of the Trustee of the
Nomura London Retirement Benefits Plan (the “Plan”) on various matters governing
decisions about the investments of the Plan.
1.2. Who has had input to the SIP?
This SIP has been formulated after obtaining and considering written professional advice
from Lane Clark & Peacock LLP, the Plan’s investment adviser, who the Trustee believe
to be suitably qualified and experienced to provide such advice. The advice takes into
account the suitability of investments and the need for diversification, given thecircumstances of the Plan and the principles contained in this SIP.
The investment managers are required to carry out their investment responsibilities in amanner consistent with this SIP.
1.3. What is the legal and statutory background to the SIP?
The SIP is designed to meet the requirements of Section 35 (as amended) of thePensions Act 1995 (“the Act”) and the Occupational Pension Schemes (Investment)
Regulations 2005 (“the Regulations”). The SIP also reflects the Trustee’s response to
the Myners voluntary code of investment principles.
The Plan’s assets are held in trust by the Trustee. The investment powers of theTrustee are set out in the Plan’s Trust Deed.
2.

What are the Trustee’s overall investment objectives for the Defined Benefit(“DB”) Section?

The majority of the Plan’s promised DB benefits have been secured with bulk annuity
policies with Aviva and PIC. Given this position, the Trustee’s objectives are:that the Plan should meet all benefit payments as they fall due;that the Plan’s overall funding position (ie the total value of its insurance policies
and its residual assets relative to the assessed value of its secured and unsecured
liabilities) should remain at an appropriate level. The Trustee is aware that there
are various measures of funding, and have given due weight to those consideredmost relevant to the Plan.

3.

What risks does the Trustee consider and how are these measured andmanaged?

When deciding how to invest the Plan’s assets, the Trustee considers a wide range ofrisks, including, but not limited to, those set out in Appendix A. Some of these risks are
more quantifiable than others, but the Trustee has tried to allow for the relative
importance and magnitude of each risk.
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4.

Trustee’s investment beliefs

The Trustee’s key investment beliefs, which influenced the setting of the investment
arrangements, are as follows:

asset allocation is the primary driver of long-term returns;

risk-taking is necessary to achieve return, but not all risks are rewarded;equity, credit and illiquidity are the primary rewarded risks;risks that do not have an expected reward should generally be avoided, hedged ordiversified;

investment markets are not always efficient and there may be opportunities for good
active managers to add value;

environmental, social and governance (ESG) factors are likely to be one area ofmarket inefficiency and so managers may be able to improve risk-adjusted returns bytaking account of ESG factors;



investment managers who can consistently spot and profitably exploit market
opportunities are difficult to find and therefore passive management, where available,
is usually better value;

long-term environmental, social and economic sustainability is one factor thattrustees should consider when making investment decisions; and

costs have a significant impact on long-term performance and therefore obtaining
value for money from the investments is important.

The Trustee’s key investment beliefs and understanding of the Plan’s membership arereflected in the range of funds made available to members.
5.

Summary of the Plan’s investment strategy for the DB Section

5.1. How is the investment strategy determined?
The Trustee, with the help of its advisers and in consultation with the employer,
undertakes reviews of the investment strategy from time to time, taking into account theobjectives described in Section 2 above.
5.2. What is the investment strategy?
The Plan holds two annuity policies. These policies match the majority of the DB
benefits payable to the Plan’s members. The annuity policies are “buy-ins” and therefore
remain an asset of the Plan.

The Trustee invests its remaining assets in a number of passive gilt funds and a sterling
liquidity fund to broadly match unsecured liabilities that are not currently covered by theannuity policies, and hold a reserve over and above these liabilities. This includes
liabilities where there remains some uncertainty regarding the precise benefit due (egrelating to GMP equalisation and GMP underpin of DC benefits) and some past
discretionary pension increases.
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The Trustee considers gilts to be matching assets, although it recognises that in practicethe degree of liability matching these assets provide varies considerably.
5.3. What does the Trustee consider in setting the Plan’s investment strategy?
In setting the strategy for the DB section, the Trustee took into account:the Plan’s investment objectives, including the target return required to meet theTrustee’s investment objectives;the Plan’s cash flow requirements in order to meet benefit payments in the near to
medium term;

the best interests of all members and beneficiaries;the circumstances of the Plan, including the profile of the benefit cash flows (and theability to meet these in the near to medium term), the funding level, and the strengthof the employer covenant;the risks, rewards and suitability of a number of possible asset classes andinvestment strategies and whether the return expected for taking any given
investment risk is considered sufficient given the risk being taken;

the need for appropriate diversification between and / or within different asset classes
to ensure that both the Plan’s overall level of investment risk and the balance ofindividual asset risks are appropriate;

any other considerations which the Trustee considers financially material over thetime horizon that the Trustee considers is needed for the funding of future benefits by
the investments of the Plan; and

the Trustee’s investment beliefs about how investment markets work, and which
factors are most likely to impact investment outcomes.

In determining the investment arrangements for the DC Section, the Trustee took into
account:the best interests of all members and beneficiaries;the profile of the membership and what this is likely to mean for the choices members
might make upon reaching retirement;

the risks, rewards and suitability of a number of possible asset classes and lifestyle
strategies and whether the return expected for taking any given investment risk is
considered sufficient given the risk being taken;

the need for appropriate diversification within the investment options offered tomembers;

any other considerations which the Trustee considers financially material over theperiods until members’ retirement, or any other timeframe which the Trustees
believes to be appropriate; and

the Trustee’s investment beliefs about how investment markets work and which
factors are most likely to impact investment outcomes.

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5.4. What assumptions are made about the returns on different asset classes?
The Trustee considered a wide range of asset classes for investment, taking account of
the expected returns and key individual risks associated with those asset classes as well
as how these risks can be mitigated where appropriate.
6.

Appointment of investment managers for the DB Section

6.1. How many investment managers are there?
The Trustee has decided to appoint Legal and General Investment Management(“LGIM”) to manage the remaining non-annuity assets of the Plan.
The annuity providers are Aviva Annuity UK Limited (“Aviva”) and Pensions Insurance
Corporation plc (“PIC”). These annuities remain assets of the Plan.
6.2. What formal agreements are there with investment managers?
The Trustee has entered into an insurance policy with Legal & General Assurance(Pensions Management) Limited. The insurance policy sets out details of the terms
under which the Plan’s assets are managed. Legal & General Assurance (Pensions
Management) Limited delegates investment management responsibilities to Legal &General Investment Management Limited.
For the purpose of this SIP, Legal & General Investment Management Limited is defined
as an “investment manager”.
Details of the investment manager and its investment benchmarks and guidelines are
given in Appendix B.
6.3. What do the investment managers do?
The investment manager’s primary role is the day-to-day investment management of thePlan’s investments. The manager is authorised under the Financial Services andMarkets Act 2000 to carry out such activities.
The Trustee has limited influence over the investment manager’s investment practices
because all the Plan’s assets are held in pooled funds, but it encourages its manager toimprove their practices where appropriate.
The Trustee’s view is that the fees paid to the investment manager, and the possibility of
their mandate being terminated, ensure they are incentivised to provide a high quality
service that meets the stated objectives, guidelines and restrictions of the fund.
However, in practice managers cannot fully align their strategy and decisions to the(potentially conflicting) policies of all their pooled fund investors in relation to strategy,
long-term performance of debt/equity issuers, engagement and portfolio turnover.
It is the Trustee’s responsibility to ensure that the manager’s investment approaches are
consistent with its policies before any new appointment, and to monitor and to consider
terminating any existing arrangements that appear to be investing contrary to thosePage 5 of 15

policies. The Trustee expects the investment manager, where appropriate, to makedecisions based on assessments of the longer term financial and non-financial
performance of debt/equity issuers, and to engage with issuers to improve theirperformance. It assesses this when selecting and monitoring managers.
The Trustee evaluates investment manager performance by considering performanceover both shorter and longer-term periods as available. Except in closed-ended funds
where the duration of the investment is determined by the fund’s terms, the duration of amanager’s appointment will depend on strategic considerations and the outlook for future
performance. Generally, the Trustee would be unlikely to terminate a mandate on shortterm performance grounds alone.
The Trustee’s policy is to evaluate its investment manager by reference to the manager’s
individual performance as well the role it plays in helping the Plan meet its overall longterm objectives, taking account of risk, the need for diversification and liquidity. The
manager’s remuneration, and the value for money it provides, is assessed in light ofthese considerations.
The Trustee recognises that portfolio turnover and associated transaction costs are anecessary part of investment management and that the impact of portfolio turnover costs
is reflected in performance figures provided by the investment manager. The Trustee
expects its investment consultant to incorporate portfolio turnover and resulting
transaction costs as appropriate in its advice on the Plan’s investment mandates.
7.
7.1.

Defined Contribution (“DC”) Section
Background

The Trustee recognises that individual members have differing investment needs andthat these may change during the course of their working lives. It also recognises thatmembers have differing attitudes to risk. The Trustee believes that ideally members
should make their own investment decisions based on their individual circumstances.
7.2.

Policy for choosing investments

The Trustee regards their duty as making available a range of investment funds thatenable members to tailor strategy to their own needs. It is for each member to decide
which vehicle(s) they wish to use at any time.
The Trustee has considered the long-term performance characteristics of various asset
classes, in terms of their expected returns and the variability of those returns, in deciding
on the range of investment vehicles to make available to members.

7.3.

Investment strategy and managers

The Trustee has established Insurance Policies with Legal & General Assurance(Pensions Management) Limited (“L&G”) and Schroder Pension Management Limited(“Schroders”). Under these Policies, L&G and Schroders offer members a range ofinvestment options, as specified by the Trustee. The available funds are provided inAppendix B.
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8.

Other matters8.1. What is the Trustee’s policy on the realisation of investments?
The investment managers have discretion over the timing of realisation of investments of
the Plan and in considerations relating to the liquidity of investments. When appropriate,
the Trustee, on the administrators’ recommendation, decides on the amount of cash
required for benefit payments and other outgoings and informs the investment managers
of any liquidity requirements.
For the DC Section, the Trustee’s policy is to invest in funds that offer daily dealing toenable members to readily realise and change their investments.
8.2. Consideration of financially material and non-financial matters
The Trustee has considered how environmental, social, governance (“ESG”) and ethicalfactors should be taken into account in the selection, retention and realisation of
investments, given the time horizon of the Plan and its members.
The Trustee expects its investment managers to take account of financially material
considerations (including climate change and other ESG considerations). The Trustee
seeks to appoint managers that have appropriate skills and processes to do this, andfrom time to time reviews how its managers are taking account of these issues inpractice.
The Trustee has limited influence over managers’ investment practices where assets areheld in pooled funds, but it encourages its managers to improve their practices whereappropriate.
The Trustee does not take into account any non-financial matters (ie matters relating to
the ethical and other views of members and beneficiaries, rather than considerations offinancial risk and return) in the selection, retention and realisation of investments.
8.3. What is the Trustee’s policy on stewardship practices?
The Trustee recognises its responsibilities as owners of capital, and believes that goodstewardship practices, including monitoring and engaging with investee companies, andexercising voting rights attaching to investments, protect and enhance the long-termvalue of investments. The Trustee has delegated to its investment managers theexercise of rights attaching to investments, including voting rights, and engagement withissuers of debt and equity and other relevant persons about relevant matters such as
performance, strategy, risks and ESG considerations.

The Trustee does not monitor or engage directly with issuers or other holders of debt orequity. It expects the investment managers to exercise ownership rights and undertake
monitoring and engagement in line with the managers’ general policies on stewardship,as provided to the Trustee from time to time, taking into account the long-term financial
interests of the beneficiaries. The Trustee has limited influence over managers’
stewardship practices where assets are held in pooled funds, but it encourages its
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managers to improve their practices where appropriate
8.4. What are the responsibilities of the various parties in connection with thePlan’s investments?
Appendix C contains brief details of the respective responsibilities of the Trustee, theiradvisers, and the investment managers. Appendix C also contains a description of thebasis of remuneration of the investment adviser and the investment managers.
8.5. Does the Trustee make any investment selection decisions of its own?
Before making any investment selection decision, it is the Trustee’s policy to obtainwritten advice. The written advice considers the suitability of the investment, the needfor diversification and the principles contained in this SIP. It is also the Trustee’s policy
to review its own investment selection decisions on a regular basis, based on written
advice.
9.

Review

The Trustee will, from time to time, review the appropriateness of this SIP with the helpof their advisers, and will amend the SIP as appropriate. These reviews will take place
as soon as practicable after any significant change in investment policy, and at least
once every three years.
For and on behalf ofTrustee of the Nomura London Retirement Benefits Plan

The Trustee’s policy towards risk, risk
measurement and risk management
1.
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DB Section

The Trustee considers that there are a number of different types of investment risk thatare important for the Plan. These include, but are not limited to:
A.1.

Strategic riskThis is the risk that the performance of the Plan’s assets and liabilities diverges in certain
financial and economic conditions. This risk has been taken into account in the
Trustee’s investment strategy review, and will be monitored by the Trustee on a regularbasis.
The Trustee will review the Plan’s investment strategy at least every three years in lightof the various risks faced by the Plan.
A.2.

Inadequate long-term returns

A key objective of the Trustee is that, over the long-term, the Plan should have adequate
resources to meet its liabilities as they fall due. The Trustee therefore invests the assetsof the Plan to produce an adequate long-term return.
For the passive gilt funds, an adequate return is understood to be a return in-line with theunderlying gilt benchmark for each fund. For the Sterling Liquidity Fund an adequate
return is understood to be a return in-line with SONIA.
A.3.

Investment manager riskThis is the risk that investment managers fail to meet their investment objectives. The
Trustee monitors the investment managers on a regular basis.
A.4.

Risk from lack of diversification

This is the risk that failure of a particular investment, or the general poor performance ofa given investment type, could materially adversely affect the Trustee’s ability to meet its
investment objectives.
The Trustee believes that the need for the Plan’s assets to be adequately diversified
within the Sterling Liquidity Fund has been met by the guidelines agreed with theinvestment managers.
A.5.

Liquidity/marketability riskThis is the risk that the Plan is unable to realise assets to meet benefit cash flows as
they fall due. The Trustee is aware of the Plan’s cash flow requirements and believes
that this risk is managed appropriately via the measures described in Section 7.1.

Appendix A

A.6

Credit riskThis is the risk that one party to a financial instrument will cause a financial loss for theother party by failing to discharge an obligation.
The Plan invests in pooled funds and is therefore directly exposed to credit risk inPage 9 of 15

relation to solvency of the investment manager and custodian of those funds.
The manager of the Sterling Liquidity Fund manages credit risk by having a suitably
diversified exposure to issuers, conducting thorough research on the probability ofdefault of those issuers, and by typically having only a limited exposure to credit
instruments rated below investment grade. The magnitude of credit risk within the fundwill vary over time, as the manager changes the underlying investments in line with its
views on markets, asset classes and specific bonds.
There is also credit risk associated with the annuity policies with Aviva and PIC which theTrustee considered before the policies were taken out.
A.7

Currency risk

The Plan is subject to currency risk because some of the Plan’s investments within the
Sterling Liquidity Fund are classified as overseas assets. The Trustee manages theamount of currency risk by investing in pooled funds that hedge currency exposure (or in
the case of the passive gilt funds held, take no exposure in the first place).
A.8

Interest rate risk

Some of the Plan’s assets are subject to interest rate risk. However, the overall interest
rate exposure of the Plan’s assets hedges part of the corresponding risks associatedwith the Plan’s liabilities. The net effect will be to reduce the volatility of the funding
level, and therefore the Trustee believes that it is appropriate to have exposure tointerest rate risk in this manner.
A.9.

Environmental, social and governance (ESG) risks

Environmental, social and corporate governance (ESG) factors are sources of risk to thePlan’s investments, some of which could be financially material, over both the short andlonger term. These potentially include risks relating to factors such as climate change,
unsustainable business practices, and unsound corporate governance. The Trustee
seeks to appoint investment managers who will manage these risks appropriately on
their behalf and from time to time reviews how these risks are being managed inpractice.
A.10.

Other non-investment risks

The Trustee recognises that there are other, non-investment, risks faced by the Plan.
Examples include:

mortality risk (the risk that members live, on average, longer than expected);

sponsor risk (the risk that, for whatever reason, the sponsoring employer is unable
to support the Plan as anticipated). The Trustee has taken into account thestrength of the employer’s covenant in setting the Plan’s investment strategy; andlitigation risk (the risk that legal action or activity results in a deterioration in the
Plan’s financial position or has other negative effects).

Page 10 of 15 Together, the investment and non-investment risks give rise generally to funding risk.
This is the risk that the Plan’s funding position falls below what is considered an
appropriate level. By understanding and considering each of the risks that contribute tofunding risk, the Trustee believes that they have addressed and are positioned to
manage this general risk.
2.
A.1.

DC Section
The Trustee’s policy towards risk

The Trustee considers that there are a number of different types of investment risk thatneed to be considered in relation to the DC Section. These include, but are not limited
to:
A.2.

Risk of inadequate long term returns

As members’ benefits are dependent on the investment returns achieved, it is importantthat investment vehicles are available which can be expected to produce adequate real
returns over the longer term.
A.3.

Risk of deterioration in investment conditions near retirement

For a given amount of money, the level of pension secured for a member will depend
upon investment conditions at retirement. A sharp deterioration in these conditions in
the period just prior to retirement will have a substantial impact on the benefits provided.
A.4.

Risk from unsuitable investments

The Trustee has considered the kinds of investments that could be offered to membersof the DC Section and assessed whether they are suitable or otherwise. The Trustee
has considered the various investment characteristics of the funds offered by LGAS andSchroders, and believe that the funds offered to members of the DC Section are suitable.
A.5.

Risk from excessive charges

If the investment management charges together with other charges levied on, forexample, transfers or early retirement are excessive, then the value of a member’s
account will be reduced unnecessarily. The Trustee is comfortable that the charges
applicable to the Plan are in line with market practice and assess regularly whether these
represent good value for members.
A.6.

Risk from lack of diversification

This is the risk that failure of a particular investment, or the general poor performance ofa given investment type, could materially adversely affect the Plan’s assets. The
Trustees believes that the DC options provide a suitably diversified range for members tochoose from. This was a key consideration when determining the Plan’s investment
arrangements and is monitored by the Trustee on a regular basis.
A.7.

Liquidity/marketability risk

For the DC Section, this is the risk that core financial transactions, such as investing
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members’ contributions, are not processed promptly due to lack of liquidity in theinvestments. The Trustee manages this risk by only using pooled funds with daily
dealing within the options available to members.
A.8.

Environmental, social and governance (ESG) risks

Environmental, social and corporate governance (ESG) factors are sources of risk to thePlan’s investments, some of which could be financially material, over both the short andlonger term. These potentially include risks relating to factors such as climate change,
unsustainable business practices, and unsound corporate governance. The Trustee
seeks to appoint investment managers who will manage these risks appropriately on
their behalf and from time to time reviews how these risks are being managed inpractice.
A.9.

Other non-investment risks

There are a number of other risks that arise from certain investment activities, such as
operational risk. The investment managers place controls on such activities whereappropriate and these are set out in the trust document appropriate to each fund.

Investment manager arrangements
B.1.

Appendix B

DB Section

The Trustee has selected LGIM as the investment manager for the Plan’s DB assets.
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LGIM’s objective for its passive gilt funds is to provide a return in-line with the underlying
gilt benchmark for each fund. LGIM’s objective for its Sterling Liquidity Fund is toprovide a return in-line with SONIA. The funds are priced weekly. The funds are openended and unlisted.
B.2.

DC Section

Fund name/asset class

Benchmark index

Active or Passive

L&G UK Equity Index

FTSE All-Share Index

Passive

A combination of Global FTSE equity indices

Passive

50% FTSE A All Stocks Gilts Index

ActiveL&G Global Equity Fixed Weights
50:50 Index (GBP Hedged)
L&G Active Aggregate All Stocks
50:50 Fixed Interest
L&G Over 5-year Index-Linked Gilts

50% Markit iBoxx Sterling Non-Gilts Index
FTSE A Over 5 Year Index-Linked Gilts Index

Passive

7 day LIBID

Active35% FTSE All Share Total Return, 15% S&P 500

ActiveIndex
L&G CashSchroders Managed Balanced

Total Return Index, 15% FTSE World Series Europe
ex UK TR, 5% Tokyo Stock Exchange 1st Section
Index (TOPIX) TR, 5% MSCI Pacific ex Japan TR
Gross, 5% MSCI Emerging Markets TR, 7.5% iBoxx
GBP Gilts TR, 7.5% iBoxx GBP Non-Gilts TR, 5% UK
SONIA
Schroders Global Equity

MSCI World (NDR) Index

ActiveSchroders QEP Global CoreMSCI World (NDR) Index

ActiveThe objective of the passive funds offered within the DC Section is to track thebenchmark indices closely
B.3.

Additional Voluntary Contributions (“AVCs”)

Schroders and L&G are the Plan’s money purchase AVC providers, with the same funds
as offered in the DC Section above being made available to members.

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Responsibilities and fees
C.1.

Responsibilities and investment decision-making structure

The Trustee has decided on the following division of responsibilities anddecision-making for the Plan. This division is based upon the Trustee’s understanding of
the various legal requirements placed upon it, and its view that this division allows for
efficient operation of the Plan overall, with access to an appropriate level of expert
advice and service.
C.2.

TrusteeIn broad terms, the Trustee is responsible in respect of investment matters for:

developing a mutual understanding of investment and risk issues with theemployer;setting the investment strategy, in consultation with the employer;formulating a policy in relation to financially material considerations, such as thoserelating to ESG considerations (including but not limited to climate change);formulating a policy on taking account of non-financial matters in the selection,
retention and realisation of investments;

setting the policy for rebalancing between asset classes;setting a policy on the exercise of rights (including voting rights) and undertaking
engagement activities in respect of the investments;putting effective governance arrangements in place and documenting thesearrangements in a suitable form;

appointing (and, when necessary, dismissing) investment managers, investment
advisers, actuary and other service providers;monitoring the exercise of the investment powers that they have delegated to theinvestment managers and monitoring compliance with Section 36 of the Act;

communicating with members as appropriate on investment matters, such as theTrustee’s assessment of its effectiveness as a decision-making body, the policies
regarding responsible ownership and how such responsibilities have beendischarged;

reviewing the investment policy as part of any review of the investment strategy;reviewing the content of this SIP from time to time and modifying it if deemed
appropriate; and

consulting with the employers when reviewing the SIP.

Appendix C

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C.3.

Investment managers

In broad terms, the investment managers will be responsible for:

managing the portfolios of assets according to their stated objectives, and within
the guidelines and restrictions set out in their respective investment manager
agreements and/or other relevant governing documentation;

taking account of financially material considerations (including climate change andother ESG considerations) as appropriate when managing the portfolios of assets;



exercising rights (including voting rights) attaching to investments and undertaking
engagement activities in respect of investments;

providing the Trustees with regular information concerning the management andperformance of their respective portfolios; andhaving regard to the provisions of Section 36 of the Act insofar as it is necessary to
do so.

The custodians of the portfolios (whether there is a direct relationship between thecustodian and the Trustee or not) are responsible for safe keeping of the assets andfacilitating all transactions within the portfolios.
C.4.

Investment adviser

In broad terms, the investment adviser will be responsible, in respect of investment
matters, as requested by the Trustee, for:

for the DB Section, advising on how material changes within the Plan’sbenefits, membership, and funding position may affect the manner in which
the assets should be invested and the asset allocation policy;

for the DC Section, advising on a suitable fund range for the Plan, and how
material changes to legislation or within the Plan’s benefits and membershipmay impact this;C.6

advising on the selection, and review, of the investment managers; andparticipating with the Trustee in reviews of this SIP.
Mandates given to advisers, and investment managers

The Trustee has in place signed agreements with each of the Plan’s advisers, andinvestment managers. These provide details of the specific arrangements agreed by theTrustee with each party.
C.7.

Fee structures

The Trustee recognises that the provision of investment management, dealing, andadvisory services to the Plan results in a range of charges to be met, directly or
indirectly, by deduction from the Plan’s assets.

3562116

The Trustee has agreed Terms of Business with the Plan’s actuarial and investment
advisers, under which charges are calculated on a “time-cost” basis or agreed fixed fees.

Page 15 of 15
The investment managers receive fees calculated by reference to the market value of
assets under management. The fee rates are believed to be consistent with the
managers’ general terms for institutional clients and are considered by the Trustee to bereasonable when compared with those of other similar providers.
The fee structure used in each case has been selected with regard to existing custom
and practice, and the Trustee’s view as to the most appropriate arrangements for thePlan. However, the Trustee will consider revising any given structure if and when it isconsidered appropriate to do so.
C.8.

Performance assessment

The Trustee is satisfied, taking into account the external expertise available, that there
are sufficient resources to support its investment responsibilities. The Trustee believes
that it has sufficient expertise and appropriate training to carry out its role effectively.
It is the Trustee’s policy to assess the performance of the Plan’s investments, investment
providers and professional advisers from time to time. The Trustee will also periodicallyassess the effectiveness of its decision-making and investment governance processes
and will decide how this may then be reported to members.
C.9

Working with the Plan’s employer

When reviewing matters regarding the Plan’s investment arrangements, such as the SIP,
the Trustee seeks to give due consideration to the employer’s perspective. While therequirement to consult does not mean that the Trustee needs to reach agreement withthe employer, the Trustee believes that better outcomes will generally be achieved if theTrustee and employer work together collaboratively