SIP Implementation Statement
This is the Trustee’s statement prepared inaccordance with the requirements of the
Occupational Pension Schemes (Investment
and Disclosure) (Amendment) Regulations 2019.
This statement sets out how the Trustee hascomplied with the voting and engagement
policies detailed in the Scheme’s Statementof Investment Principles (SIP).

What is the Statement of Investment
Principles (SIP)?
Regulatory changes in 2018 and 2019 required trustees of UK
defined benefit pension schemes to disclose further informationin relation to how they undertake stewardship - exercising
voting rights and engaging with their investments - in their
SIP, and introduced the concept of an annual Implementation
Statement. The legislation states that the Implementation
Statement must be included in the annual report and accounts,
and that it must also be made publicly available online. To
reflect new regulatory requirements, the SIP was reviewed
and approved on 30 September 2020. Following the Scheme
year end, a revised SIP was approved on 30 September 2021.

The SIP sets out the investment principles and practices that
the Trustee follows when governing the Scheme’s investments.
It describes the rationale for selecting the investment strategy
and explains the risks and expected returns of the Scheme,
and the Trustee’s approach to responsible investing (including
climate change). This Implementation Statement is in respectof the Scheme’s SIPs that were in place from 1 July 2020 to thedate of signing this report. The purpose is to:• 
Set out the extent to which, in the opinion of the Trustees,

Changes to the SIP during the year
To reflect new regulatory requirements, during the year, the
SIP was reviewed and approved by the Trustee in September
2020. The previous SIP was approved in September 2019. This
Implementation Statement is in respect of the SIPs thatwere in place from 1 July 2020 to the date of signing thisreport, and therefore covers the 2019 and the 2020 SIP.
Following the Scheme year end, a revised SIP wasapproved on 30 September 2021.

the stewardship activities detailed in the Scheme’s SIP,
required under section 35 of the Pensions Act 1995 (asamended by the Pensions Act 2004 and regulations madeunder it), have been followed during the year;• 
Describe the voting behaviour by, or on behalf of, the Trustee
over the year (including most significant votes), and state
any use of services of a proxy voter during that year.
A copy of this implementation statement will be madeavailable on the BTPS website alongside the Scheme’s SIP:
https://www.btps.co.uk/RegulatoryReporting

BTPS SIP Implementation Statement 2021 1

SIP Implementation Statement
How the Scheme’s investments are governed
The main objective of the Trustee is to ensure that there
are sufficient assets to pay benefits to members and theirbeneficiaries as they fall due, and that all members andbeneficiaries receive the benefits to which they are entitledunder the Rules of the Scheme. In considering their approach
to meeting this objective, the Trustee considers the expected
progression of the Scheme’s total annual benefit payments
relative to the projected level of Scheme assets as the
proportion of retired members increases over time. The Trustee
takes an integrated approach to the management of risk in
the Scheme. The Trustee therefore invests the assets of the
Scheme consistent with funding a defined level of benefits
within an acceptable level of risk, having appropriate regard
to the affordability of both the immediate and longer term
cash cost to BT, and the funding obligations which BT (andother entities where relevant) may have from time to timeto the Scheme. The Trustee recognises the importance of
establishing and maintaining stability in the Scheme’s funding
position and understands that continued investment in risky
assets might, over the short to medium term, influence thevolatility of the funding level of the Scheme, and hence may
influence the level of future contributions that may be required
from BT.

The Trustee has established a core set of investment beliefs
that provide a framework for consistent and effective
investment decision making. This includes beliefs that are
related to the nature and characteristics of the Scheme,
such as the importance of having an appropriate
governance structure, the need to take into accountthe liabilities when setting investment strategy,
and having an understanding of both thecompetitive advantages and disadvantages
facing the Scheme. In addition, the investment
beliefs recognise the importance of being a
responsible investor and include marketrelated beliefs, such as those concerning
the relationship between risk and return,the importance of diversification,and the belief that markets can beinefficient. The Trustee, supported by
its Investment Committee and BTPSM,
regularly reviews its investment beliefs
against the investment outcomes
being delivered by the Scheme.

BTPS SIP Implementation Statement 2021 2

SIP Implementation Statement
The Trustees’ expectations of stewardship, engagement & voting
The following section of the Implementation Statement focuses on how, and the extent to which, the Scheme’s policies on stewardship have been followed during the Scheme year. It will also describe
the voting behaviour by, or on behalf of, the Trustee (including a selection of significant votes cast by the Trustee or on its behalf) during the year, stating any use of the services of a proxy voter
during that year.
In relation to stewardship activities, the Scheme’s Statement of Investment Principles (SIP) sets out policies across the following areas:

ESG integration

Emerging long-term risks

Reducing emissions & Net Zero 2035

Members views

Investment managers are expected
to consider both the risks andopportunities that arise from ESG
factors where appropriate in theselection, retention and realisationof the investments they manage on
behalf of the Scheme. As relevantto the asset class and strategy, they
are expected to provide evidence
and ongoing reporting on the ESG
integration process across, forexample, fundamental analysis, asset
valuation and portfolio construction
as well as engagement and voting
activities. The Trustee delegates
the exercise of voting right andengagement activities to Hermes
EOS, one of the world’s foremost
providers of collaborative stewardshipservices, and where they candemonstrate sufficient capabilities,
its investment managers.

Given the time horizon of the
Scheme, the Trustee recognises thatemerging, long-term risks, including,for example, climate and technology
disruption, may have a material
adverse impact on the Scheme. Theserisks are monitored by the Trustee
as part of their regular review of the
Scheme’s risk register. Day-to-day
implementation and monitoring of
the controls in place to manage theserisks is delegated to BTPSM.

The Trustee believes that reducing
exposure to carbon emissions
over time will improve investment
outcomes and reduce the impact
of potential adverse outcomes
associated with future climate
risk. Consequently, the Trustee has
established a goal for the Scheme’s
investment portfolio to achieve net
zero carbon emissions by 2035.

The Trustee believes in engaging with members tounderstand their views on different topics. There areseveral mechanisms in place that provide this linkincluding through:Integrating all financially material
considerations, including environmental,social and governance (ESG) factors,
throughout the investment process

Monitoring emerging long-term risks,such as climate change and technology
disruption, that may have a material
adverse effect on the Scheme

Reducing exposure to carbon emissions,and establishing a goal for the Scheme’s
investment portfolio to achieve net zerocarbon emissions by 2035

Considering the views of members to help inform theTrustees’ approach to ESG considerations and stewardship• BT’s recognised Trade Unions (CWU and Prospect)
and the National Federation of Occupational
Pensioners (NFOP) nominate Trustees• Providing an annual presentation by the Trustee
Board, BTPSM and its advisers to BT’s recognised
Trade Unions and NFOP• 
Updating members on the Scheme’s stewardship,
engagement and voting activities via quarterly
updates on the BTPS website, the Scheme’s reportand accounts, including TCFD disclosures, andthe Scheme’s annual PRI transparency andassessment report• 
Inviting feedback from members through the annual
member newsletter and annual member surveys andsupporting a ‘member panel’ who volunteer to takepart in more in-depth research with the Scheme.

BTPS SIP Implementation Statement 2021 3

SIP Implementation Statement
In January 2021, the results of BTPS’ member survey demonstrated that members continue
to expect BTPS to take into consideration the ESG impact of its investments, and to use its
investments to make a positive impact on the environment and society.

Trustee Stewardship Training76%

expect BTPS tocontinue taking into
consideration theenvironmental andsocial impact of theinvestments it makes.

67%

expect BTPS to use its
investments to makea positive impact on
the environment andsociety.

64%

expect BTPS to actively
avoid investmentsthat have a materiallynegative impact on
the environmentand society.

43%

expect BTPS to prioritise
financial performanceover the environmental
and social impact of its
investments.

To ensure the Trustee is kept informed of responsible
investment activities, during 2020-2021, the Trustee
Investment Committee (IC), which oversees the Scheme’s
RI strategy, received two presentations regarding net zeroand responsible investment activities within the portfolio
from BTPSM.

These results were also slightly more positive than in 2020 where members surveyed online said:

74%

expect BTPS tocontinue taking into
consideration theenvironmental andsocial impact of theinvestments it makes.

65%

expect BTPS to use its
investments to makea positive impact on
the environment andsociety.

62%

expect BTPS to actively
avoid investmentsthat have a materiallynegative impact on
the environmentand society.

48%

expect BTPS to prioritise
performance over theenvironmental andsocial impact of its
investments.

BTPS SIP Implementation Statement 2021 4

SIP Implementation Statement
Engagement

BTPS engagement activities

Before appointing an investment manager, BTPSM seeks
to understand the manager’s philosophy and approach todetermine their suitability for the mandate being awarded.
This includes an assessment of the alignment between
Trustees’ beliefs and goals with those of the manager. In
addition, clarity is sought on the manager’s investment
time horizon, approach to responsible investment, andengagement with underlying companies. It is the expectationof the Trustees that investment managers engage regularly
with their portfolios. BTPSM therefore actively monitorsand engages with investment managers to ensure their
ongoing resilience, adherence to mandate expectations andalignment with Trustee objectives. The monitoring processincludes ongoing evaluation of the environmental, social andgovernance characteristics of the portfolio, and managers’
engagement, stewardship and voting activities.

• 
During 2020-2021, on behalf of the Trustees, the Scheme’sfund managers with voting rights and engagement activity
applicable to their strategy were reviewed by BTPSM .
Managers were asked to outline the objectives of key
portfolio engagements and whether investment
decisions had been altered because of the discussions.

• BTPSM evaluated how its largest fund managers integrate
climate change risks and opportunities in their investment
process as part of the Trustees’ commitment to achieving
the Scheme’s Net Zero 2035 goal. Following this, BTPSM has
begun amending the Investment Management Agreements(IMAs) of its fund managers to incorporate explicit net zero
objectives into the mandates they manage for BTPS.

• 
BTPS also publicly and directly advocated for stronger
action on climate change through:• 
Engaging with key UK policy makers and signing publicstatements such as the 2021 Global Investor Statement
to Governments on the Climate Crisis, with a particularfocus on climate change governance in sovereign debt• Launching and chairing the Assessing Sovereign
Climate Opportunities and Risk (ASCOR) Project withother asset owners and international investor climatechange networks to develop an assessment frameworkthat enables the current and future climate change
governance and performance of sovereigns to be fairly
and appropriately measured, monitored and compared.

• 
Signing the Accounting 4 Sustainability (A4S) Pension
Fund Chair Net Zero Statement of Support• 
Signing the IIGCC’s statement on corporate net zeroalignment plans and, via its fund managers, supporting
collaborative engagement in Climate Action 100+.

• 
Joining the Net Zero Asset Owner Alliance and Transition
Pathways Initiative (TPI)

BTPS SIP Implementation Statement 2021 5

SIP Implementation Statement
Investment engagement activities
The following section provides insights and statistics on engagement activities undertaken in 2020 by Hermes EOS, the Scheme’s main stewardship services provider.

Engagement statistics

Engagement by ESG theme

In 2020, Hermes EOS engaged with 177 companies on
661 environmental, social, governance, strategy, risk andcommunication issues and objectives, to promote positivechange on a wide range of issues:

To ensure they achieve positive outcomes, Hermes EOS sets clear and specific objectives within all company engagements.
Each objective is tracked using milestones and regularly reviewed until they are completed, or when the company
has demonstrably implemented the change requested, or when the activity is discontinued. An example objective is:“development of a strategy consistent with the goals of the Paris Agreement, including setting science-based emissions
reduction targets for operating emissions (Scopes 1 and 2 emissions)”.

Hermes EOS engaged with177 companies over the last year

Environmental topics featured in 25.0%
of Hermes EOS engagements over the last year

Social and ethical topics featured in 24.2% ofHermes EOS engagements over the last year

GlobalEnvironment

Social andEthicalEnvironmental

25.0%

Climate change

73.9%

Bribery and corruption

Social and ethical

24.2%

Forestry and land use

6.1%

Conduct and culture

14.4%

Governance

32.6%

Pollution and waste management

13.4%

Diversity

18.8%

Strategy, risk, communication

18.2%

Supply chain management

1.8%

Human capital management

28.1%

Water

4.8%

Human rights

27.4%

Labour rights

5.0%

Tax

3.8%

2.5%

BTPS SIP Implementation Statement 2021 6

SIP Implementation Statement
Engagement by ESG theme

Governance topics featured in 32.7% ofHermes EOS’ engagements over the last year

Strategy, risk and communication topics featured in
18.2% of Hermes EOS’ engagements over the last year

Governance

Strategy, risk &communication

Board diversity, skills and experience

23.1%

Audit and accounting

7.5%

Board independence

16.7%

Business strategy

36.6%

Executive remuneration

40.3%

Cyber security

Shareholder protection and rights

15.7%

20.0%

Succession planning

4.2%

Integrated reporting andother disclosure
Risk management

29.2%

Further to Hermes EOS, the following pages set out
further engagement examples from a selection of BTPS’
other investment managers. For more examples and awider insight into the Scheme’s stewardship activities,
please refer to BTPS’ 2021 Responsible Investment and
Stewardship Report.

6.7%

BTPS SIP Implementation Statement 2021 7

SIP Implementation Statement
Mental health
Equity engagement via GQG
Partners

Accounting
Corporate credit engagement via
M&G Investment Management

Investor collaboration to improve mental
health support for content reviewers at a
US technology company

Changing asset accounting
assumptions at a UK oil & gas company

GQG and other like-minded asset managers wrote a
letter to an American technology company because
it had allegedly exposed content moderators in
the US to traumatic work and inadequate wages.
Reportedly, most of the company’s content reviewers
are employed by third-party firms, and their tasks
include filtering sensitive content posted on its
social media platforms, such as suicide, terrorism,rape, hate speech, murder and child pornography.
As a consequence of the emotionally intense work,some workers had developed post-traumatic stressdisorder (PTSD), anxiety and depression. On-sitemental health support is reportedly inadequate andnot provided to former workers, some of whom filed
a class action lawsuit against the company alleging
its failure to provide a safe working environment. In
response, the company stated that it requires its
partners to offer 24/7 on-site support with trained
practitioners, an on-call service, and access to
private healthcare from the first day of employment.
Despite the company’s assurances, the recurring
allegations remain a source of concern.

M&G co-signed a letter with other major
shareholders to support the changes to thecompany’s accounting assumptions, which saw
the oil and gas company write down the value of
assets based on a lower future expected oil price.
The letter was the culmination of a large amountof lobbying behind the scenes to get explorationand production companies to be realistic about
demand and pricing assumptions under a Paris
Agreement-aligned world. While there was notnecessarily a direct causal link between thispressure and the company’s changes, it is worth
noting how proactive these views have been
and that the changes, which are now becoming
standardised across the industry, support better
information for investors. This is also likely to help
companies make investment decisions that are
more aligned with climate targets.

BTPS SIP Implementation Statement 2021 8

SIP Implementation Statement
Human Rights
Infrastructure engagement
via Hermes Infrastructure
Strengthening human and worker
rights policies at a UK windfarm
At a Scottish windfarm, extensive engagementwith co-shareholders led to a comprehensive
review of the wind farm’s ESG policy with a focus
on managing risk. The policy was updated andexpanded to include the consideration of several
social matters, primarily on supply chain risks
in relation to health, safety and wellbeing, andforced, compulsory and child labour. The policy
enhancements and implementation thereof
contributed to an improved Global Real Estate
Sustainability Benchmark (GRESB) score from66 in 2019 to 83 in 2020, ranking 3rd out of 6 inits peer group and obtaining 5 GRESB stars.

VotingWhen an investor owns shares in a company, they become apart-owner of that business. Having a share also gives them
the right to vote at the company’s annual general meeting(AGM), which is where companies submit resolutions forshareholders to approve, such as executive remuneration.
BTPS believes that making full use of its voting rights is partof its fiduciary duty and requires Hermes EOS and, whereapplicable, asset managers to execute all votes for the
Scheme’s directly held public securities. It believes thatproxy voting activity should not be conducted inisolation but rather as part of a wider engagement
strategy. The Scheme’s investment managers andHermes EOS are afforded a measure of discretionand flexibility, and can follow their own voting
policy on most voting topics. BTPSM monitors
the investment managers’ and Hermes EOS’
voting activities and requests they highlight
key voting decisions regularly. The investment
managers and Hermes EOS are also regularly
asked about their approach to conflicts ofinterest, however there were no concerns
raised during the year. The Scheme does
not engage in stock lending. BTPS also
publishes Hermes EOS’ quarterly voting
statistics and activities on the Scheme
website - click here to see more.

BTPS SIP Implementation Statement 2021 9

SIP Implementation Statement
While the Scheme is invested in a diverse range of asset classes, this section focuses on the equity investments which havevoting rights attached. The Scheme’s equity holdings, as at the end of the year, are held in both segregated and pooled
investment funds and are managed on an active basis. The Scheme’s equity holdings are invested with five investment managers.

Manager:
GQG Investment Management

Voting activity:

Fund type:
Segregated active equity fundNumber of meetings at which the manager was eligible to vote: 50
Number of resolutions on which the manager was eligible to vote: 838
Number of votes cast: 838
Percentage of eligible votes cast: 100%
Percentage of votes (management resolutions) with management: 91%
Percentage of votes (management resolutions) against management: 9%
Percentage of votes (all votes) abstained from: 1%

Use of proxy advisor services:
GQG votes its proxies throughthe proxy advisor ISS and uses
bespoke voting policies basedon sustainability themes.

Votes for, against, abstain,
withold, no vote required

Votes against
management resolutions

Abstain1%

Amended articles

2%

Against7%

Board structure

57%

For

90%

Capital structure & dividends

7%

Withold

1%

Other

13%

No vote required

1%

Remuneration

21%

BTPS SIP Implementation Statement 2021 10

SIP Implementation Statement
Significant votes1
Company: Glencore Plc
Vote topic: Approve company’s climate action transition plan
Issue: Following the expiry of its 2020 GHG intensity target, the Company has not set any further
near-term emissions targets. There are also no clear commitments around thermal coal, which issaid to represent 10-15% of EBITDA in the medium-term. Finally, the company had not set targets
approved by the Science Based Targets Initiative. A stronger strategy is needed.
Significant votes are categorised
as a vote which can have a potential
impact on financial outcome; votes
which might have a material impact
on future company performance, forexample approval of a merger or arequirement to publish a businessstrategy that is aligned with theParis Agreement on climate change;potential impact on stewardshipoutcome; any decision which may
reduce the investor voice (e.g. aroundshareholder rights), such as a debt
for equity swap, management buyoutof a significant share of equity, adowngrading of voting rights; it
is a significant size of holding in
the mandate; it is a high-profile orcontroversial vote; a significant levelof opposition from investors to thecompany resolution; a significant levelof support for an investor resolution;level of media interest; level of politicalor regulatory interest; level of industry
debate; or any vote in non-listed equity
asset classes e.g. in private equity,
infrastructure or other asset classes.

1

Voting instruction: Against
Why a significant vote? There is a potential impact on financial outcome if the company does not
adopt a business strategy suitably aligned with the Paris Agreement on climate change.

Company: Amazon.com, Inc.
Vote topic: Shareholder request for company to oversee and report on a civil rights, equity, diversity
and inclusion audit
Issue: A vote for this resolution is warranted, as an independent racial equity audit would help
shareholders better assess the effectiveness of Amazon’s efforts to address the issue of racialinequality and its management of related risks, particularly in light of recent discrimination lawsuits.
Voting instruction: For
Why a significant vote? This is a high-profile vote, given ongoing scrutiny of the company’s employee
rights, and diversity and inclusion activities.

BTPS SIP Implementation Statement 2021 11

SIP Implementation Statement
Manager:
TCI Fund Management
Fund type:
Pooled fundUse of proxy advisor services:
No proxy advisory service used.

Voting activity:
Number of meetings at which the manager was eligible to vote: 16
Number of resolutions on which the manager was eligible to vote: 285
Number of votes cast: 285
Percentage of votes (management resolutions) with management: 97%
Percentage of votes (management resolutions) with management: 3%
Percentage of votes (total votes) abstained from: 0%

Votes for, against,
abstained, withhold

Votes against
management resolutions

Abstrain0%

Board structure

14%

Against3%

Shareholder resolution

86%

For

97%

Withold

0%

BTPS SIP Implementation Statement 2021 12

SIP Implementation Statement
Manager:
Magellan Investment Management
Fund type:
Segregated active equity fund

Voting activity:

Use of proxy advisor services:
Magellan votes its proxies throughGlass Lewis’ ViewPoint online voting
platform. As a result, Magellan has
access to Glass Lewis research, but
this analysis is based on Magellan’s
own voting decisions.

Number of meetings at which the manager was eligible to vote: 25
Number of resolutions on which the manager was eligible to vote: 380
Number of votes cast: 321
Percentage of eligible votes cast: 84%
Percentage of votes (management resolutions) with management: 97%
Percentage of votes (management resolutions) against management: 3%
Percentage of votes (all votes) abstained from: 0%

Votes against
management resolutions

Votes for, against,
abstain, withhold
Abstain0%

Board structure

80%

Against7%

Remuneration

20%

For

77%

Withold

16%

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SIP Implementation Statement
Significant votes
Company: McDonalds
Vote topic: Executive remuneration
Issue: Magellan voted against McDonald’s Compensation Committee members (Lloyd H. Dean,
Richard H. Lenny, John W. Rogers Jr and Paul S. Walsh) due to McDonald’s continued excessive useof stock options. Magellan believes escalation by voting against committee members was warranted
given their consistent vote against say-on-pay over a number of years and engagement with thecompany on this issue. Magellan voted against McDonald’s say-on-pay for the fifth year in a row.
Voting instruction: Against
Why a significant vote? Executive remuneration can have a material impact on future company
performance, therefore it is essential remuneration is aligned with the shareholder experience.

BTPS SIP Implementation Statement 2021 14

SIP Implementation Statement
Manager:
Hermes Investment Management
Fund type:Multiple segregated active equity funds

Voting activity:

Use of proxy advisor services:
Hermes EOS uses ISS to provide research and voting
recommendations. Voting recommendations are
based on ISS’ research using Hermes EOS’ voting
guidelines, overlaid with their voting approach, anduses Hermes EOS engagers to focus on key topics
and/or companies with significant holdings and/or contentious issues or ongoing engagement
objectives.

Votes for, against,
withold, abstain

Number of meetings at which the manager was eligible to vote: 307
Number of resolutions on which the manager was eligible to vote: 3131
Number of votes cast: 3131
Percentage of eligible votes cast: 100%
Percentage of votes (management resolutions) with management: 89%
Percentage of votes (management resolutions) against management: 10%
Percentage of votes (all votes) abstained from: 1%

Votes against
management resolutions

Abstain1%

Amended articles

9%

Against10%

Audit & accounts

13%

For

88%

Board structure

52%

Capital structure & dividends

9%Witheld

1%

Other

4%

Remuneration

13%

BTPS SIP Implementation Statement 2021 15

SIP Implementation Statement
Significant votes
Company: Alibaba Group Holding Limited
Vote topic: Election of a director
Vote instruction: Against
Issue: EOS wrote to the company to inform it of its AGM 2020 vote recommendations. EOS
recommended a vote for all items apart from the proposed election of a director. They explained thatthey recognise the contribution and capabilities that the proposed director brings to the company as
CFO. However, given the control structure and the influence of the partnership, they would like to see
the number of executives on the board reduce, so that the board can provide a strong oversight ofmanagement if needed.
Why a significant vote? Significant size of the investment holding.

BTPS SIP Implementation Statement 2021 16

SIP Implementation Statement
Manager:
Wellington Asset Management
Fund type:
Segregated active equity fund

Voting activity:

Use of proxy advisor services:
Wellington has policies and procedures designed
to ensure that they collect and analyse all relevant
information for each meeting, apply our proxy voting
guidelines accurately, and execute the votes in atimely manner. These policies and guidelines are
written to support the best economic interests of theclient, in accordance with regulatory and fiduciary
requirements. These policies and procedures arecontained in the firm’s Global Proxy Policy andProcedures and Global Proxy Voting Guidelines.

Votes for, against,
abstain, withhold

Number of meetings at which the manager was eligible to vote: 105
Number of resolutions on which the manager was eligible to vote: 1534
Number of votes cast: 1257
Percentage of eligible votes cast: 82%
Percentage of votes (management resolutions) with management: 94%
Percentage of votes (management resolutions) against management: 5%
Percentage of votes abstained from: 1%

Votes against types ofmanagement resolutions

Abstain1%

Amended articles

8%

Against5%

Board structure

49%

For

77%

Capital structure & dividends

5%

Withhold

17%

Other

3%

Remuneration

35%

BTPS SIP Implementation Statement 2021 17

SIP Implementation Statement
Significant votes
Company: Otsuka Corp.
Vote topic: Remuneration
Vote instruction: Against
Issue: We believe that the company should disclose the value of retirement bonuses proposed to be
paid to the recipients and provide a sufficient rationale and, where possible, include specific metrics
as to why the proposed payment is reasonable. This was not the case with Otsuka Corp.
Why a significant vote? Executive remuneration can have a material impact on future company
performance because executive compensation plans establish the incentive structure that plays
a role in strategy-setting, decision-making, and risk management.

BTPS SIP Implementation Statement 2021 18

SIP Implementation Statement
Implementation Statement conclusion
Overall, the Trustee is satisfied that throughout the last
Scheme year, the Scheme’s investments and stewardship
activities, specifically voting and engagement, have been
managed in accordance with the SIP at that time.

BTPS SIP Implementation Statement 2021 19