Funds should not, however, start a compliance assessment straight away. Instead, they should implement a four-step action plan that starts with training to ensure officers, committees and boards understand the regulator’s expectations. They are:
1. Training: Train Officers, Committees and Boards on the expectations specifically for LGPS Funds set out by TPR within the General Code.
2. Assessment: Assess current levels of compliance with the Code, prioritising the elements relevant to LGPS Funds denoted as “must” by the Regulator, followed by those areas highlighted as ‘should’ and ‘best practice’.
3. Identify: identify the steps required to achieve full compliance, for example what new policies or processes will be required, following the initial assessment
4. Plan: set out specific actions and assign these to individuals, with a realistic timescale to complete each action. This plan should be monitored to ensure progress is made.
To support LGPS Funds to self-assess, Hymans Robertson developed a TPR General Code of Practice compliance checker. The checker provides Funds with an approach to ascertain, track, and then implement any changes they need to make. It sets out the specific requirements for LGPS Funds, filtering out those issues which do not apply. The checker also provides easy progress reporting, including progress-tracking over time, and allows Funds to capture all General Code actions with owners assigned to each action.
Commenting on the need for Funds to be strategic in their approach to the General Code, Andrew McKerns, Senior Governance and Administration consultant, says: “The General Code covers such a vast area that Funds will need to be very organised in how they achieve compliance. Full or nearly full compliance will give them strong evidence that they operate with effective decision making, oversight, processes, and internal controls.
"However, even if there are actions which seem obvious to increase compliance, Funds should be careful not to make knee-jerk changes. Officers need to establish appropriate processes for their compliance requirements. That way, Officers can demonstrate a clear “before and after picture” to their Committee and Board, and the methodology they used for any changes made.
"Focusing on preparation and planning will put Funds in a better position to mitigate any issues, such as reputational damage, penalties or further scrutiny from TPR if non-compliant.
"To be successful in the long-run, Funds will need to carry out a fair bit of work. Being thorough and methodical is how they will see the benefits.”
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