Surrey Pension Fund Committee - Friday, 13 September 2024 11.15 am

September 13, 2024 View on council website Watch video of meeting
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Summary

The Surrey Pension Fund Committee met and made two decisions relating to the governance of the Fund. The first was to approve proposed changes to the Surrey County Council's Pension Fund Committee's terms of reference and scheme of delegations to be voted on at the next full council meeting. The second was to note the Surrey Pension Team's considerations of options for the future governance of the Fund.

Janice Baker's supplementary question about simplifying communications for pensioners.

Janice Baker asked a supplementary question to a response she had received about the Surrey Pension Fund's Responsible Investment Policy. She asked:

if, for the sake of pensioners who are looking at what their pension scheme is up to, if a very simple graphic or explanation can be given when they next are sent letters about their pension. Perhaps just a pie chart, but showing the amount of money that is invested, not only in fossil fuels, but in animal farms or community-built environment.

Councillor Nick Harrison responded by saying that the Surrey Pension Fund publishes a lot of information for those most interested. He added that the Surrey Pension Fund has summary newsletters, and they can look at taking Ms Baker's points on board to improve how they communicate with members. Mr Harrison finished by saying that the Surrey Pension Fund does look to improve our reporting as we go year by year in members' newsletters.

Jennifer Condit's supplementary question about lower carbon intensity funds.

Jennifer Condit asked a supplementary question about the Surrey Pension Fund's decision to invest in Legal & General's Future World fund. She asked:

Doesn't this bring into focus the desirability of investing in a fund with a lower carbon intensity benchmark? Is the Committee aware of the LNG Low Carbon Transition Global Equity Index Fund and the LNG Low Carbon Transition Developed Markets Equity Index Fund, each of which use the selective LNG Low Carbon Transition Family Index, because this index may be a lower carbon than that used for the Future World Fund?

Councillor Harrison replied by saying that when the Surrey Pension Fund decided to invest in the Legal & General Future World Fund three years ago, they looked at a range of possibilities and were advised accordingly. He finished by saying that the Surrey Pension Fund is aware of the other funds, and they will be looking at alternative strategies as part of their annual review.

Councillor George Potter asked a supplementary question to Mr Harrison's response, asking if the alternative funds had existed at the time that the Surrey Pension Fund had made their decision to invest in the Legal & General Future World fund. Councillor Harrison confirmed that they had looked at two or three options for investment in Legal & General funds, and that the company may have broadened its offer since then. Mr Harrison also clarified that the main alternative to the Future World fund was a Paris-aligned fund.

Jackie Macey's question about the government's plans for the LGPS.

Jackie Macey asked a supplementary question about the government's plans for the Local Government Pension Scheme. She said:

I do understand my question related to the pension scheme bill, which the government is planning, and I do understand that the outcomes of that are not really clear. And it was really just a comment, which was just our hope is that changes will not slow the progress the fund has made towards divestment from fossil fuels and the acquisition of funds in sustainable markets.

Councillor Harrison replied by saying that they never receive the detail till we get the detail.

Luciana Cole's supplementary question about deforestation engagement.

Luciana Cole asked a supplementary question about Surrey Pension Fund's approach to deforestation, saying:

It's welcoming to hear that ocean biodiversity has been launched as the next theme. Do you have the names of any of the companies that RABECO are engaging with on this issue?

Mr Harrison replied that he didn't think they had that information, but the Surrey Pension Fund would provide Ms Cole with a written answer.

Milo Kerr of Border to Coast Pensions Partnership added that the target companies for engagement would be identified once the engagement theme is finalised and the Surrey Pension Fund could follow up with a written response.

Kevin Clarke's supplementary question about demonstrating Paris Agreement alignment.

Kevin Clarke asked a supplementary question about the Surrey Pension Fund's alignment with the Paris Agreement. He asked:

Can this committee demonstrate what its portfolio meets these expectations every year and that the fossil fuel producers currently part of the portfolio have credible transition plans to make that a reality?

Mr Harrison replied that he didn't think the Surrey Pension Fund could offer an answer at this meeting, but would provide a written response.

Councillor Potter added:

one last point about the about credible transition plans from those who invested in. I think we know we have we know full well for instance that BP, for instance, far from having a credible transition plan, have actively backtracked from their previous transition plans, which is why our engagement approach involves voting against it for most recent meeting.

Mr Potter finished by saying:

on the fundamental question of no, we are not invested in fossil fuel companies which have credible transition plans across the board because we've got at least one clear cut example of where we are continuing to invest despite there being no credible transition plan in place.

The Pension Fund Committee's Action Tracker.

Councillor Potter expressed surprise that the Surrey Pension Team was not expected to provide a monthly snapshot of data to the Committee and Board members until the dashboard they are constructing is complete. Mr Mason replied that the data they currently have has some timing issues and that there have been some problems providing members with access. He added that he is happy to provide those monthly snapshots in his regular update.

Improving the governance of the Surrey Pension Fund.

Mr Mason introduced a paper about Improving the Governance of the Surrey Pension Fund explaining that the paper was originally referenced as a document that would be brought forward in the future and that it contains recommendations that will go to the full council. Mr Mason explained that they had thought they might need to call a special meeting to discuss the paper, but as the stars have aligned they did not need to.

Mr Mason summarised the paper, saying:

The crux of this paper is really to reflect more fully the relationship between Surrey County Council as a scheme employer in the fund and as the administrative authority and to more effectively manage some of the potential conflicts of interest that this presents. ... There are-- there's a minor change to the terms of reference of the pension fund committee which will provide a requirement to annually bring a conflict of interest policy to the committee to approve which formally understands that relationship between the council as a fund employer and as the administrative authority.

Mr Mason went on to explain that:

there are also some-- I describe them as tidying up of delegations whereby decisions around about the pension fund committee are made by officers who are in the employ of the pension funds team and also there is a further recognition of a role that was identified as being desirable in the scheme advisory boards for governance review which is the senior pensions officer. This enables a more focused pension fund management and also supports the section 151 officer in their role.

Councillor Harrison added that, in his view:

when you come down to it, it's in terms of the-- what we're taking to the county council is quite modest in many ways, but it's an important change and kind of reflects how the private sector pensions works with the distinction between trustees and the sponsoring company.

Mr Harrison went on to explain that the second recommendation in the paper deals with the services that are received by the pension fund from Surrey County Council, saying that the paper recommends:

what is termed a discovery process to understand the nature of all those charges and make sure they're appropriate and introduce service level agreements.

Councillor Potter welcomed paragraph 24 of the paper, which contains a commitment to benchmark costs and have clear service level agreements in place.

Councillor Potter asked about a point in the annexes to the paper, saying:

there's discussion in there about potential impacts of potential future legislation such as the-- one of the bills that failed due to general election but hasn't definitively been ruled out being brought back which is about the-- I forget the name of something, local authorities overseas investments impact or something like that, whatever it's called, yeah. And I think it identifies in there that one of the potential options around potential response to that if it were to come forward is amendments to schemes of delegation to delegate more investment decisions to officers and particularly around the implementation so as to avoid the potential for it to become controversial.

Mr Potter went on to ask if the changes made thus far are in response to this or whether the paper is simply talking about things we might need to consider doing in the future?. Mr Mason replied that there is no change in delegation to officers as part of this paper.

Councillor Potter then asked about the suggestion in the annexes of creating a single purpose combined authority to manage the Surrey Pension Fund, asking:

I just wondered 'cause I know there seems to be a fairly strong argument made here sort of what the benefits of that would be particularly in terms of completely resolving the conflict of interest side of things. I can't seem to find it mentioned one way or the other in the overall covering reports. I'm just wondering sort of where the thinking has got to on that because on the face of it that seems to me like it might be the most sensible long-term way forwards.

Mr Harrison replied that the paper was all encompassing and that:

we don't want to make changes that are irrevocable and take us down the line which subsequent guidance from government don't allow us to do or accelerate.

Councillor Potter asked about the suggestion of creating a single-purpose combined authority in relation to the government's desire for power consolidation, saying:

all the indications from the government are that combined authorities and equivalent bodies are their preferred route when it comes to local government in England in terms of simplifying structures and making life easier for Whitehall.

Mr Harrison replied that this is horizon scanning and that if there were a move to combined authorities, the creation of one to manage the Surrey Pension Fund would be one element of it. He added that:

I don't think we would want to take a step without knowing what the government might well do in the near future in relation to pooling and other matters.

Councillor Potter asked for clarification of Mr Harrison's answer, asking:

So to clarify what that answer effectively means is that this is sort of an FYI of what options exist at the moment. But in practical terms, they're all in the long grass until-- unless and until we get a clear direction of government in terms of pooling basically. Then we'll look again at what options would be most appropriate at that point.

Mr Mason replied that I think that's fair, adding that the suggestion of a single-purpose combined authority is not a nationwide solution as legislation in London does not allow for the formation of combined authorities, so there may need to be primary legislation to tackle this if that is indeed the way that the government wants to take this.

Councillor David Harmer expressed concern about the impact of any changes on the 300-odd organisations who use Surrey County Council as the basis for their pension arrangements, adding that I think it would be sensible to wait until we know what the government's position is at the very least. Mr Mason replied that:

frankly this is making-- this is best practice for current arrangements and there are no radical changes to anything contained in this report. This is just managing existing conflicts of interest better. If the environment changes, it isn't gonna be something that happens overnight anyway. My strong belief is that we can improve-- we should improve government's best practice immediately before waiting to see where the government might take that.

Mr Harmer said that he was concerned that the 300-odd organisations would be nervous about changes that are made, adding if we find ourselves changing things twice. Mr Mason replied that the organisations should be reassured by the changes as what this proposes is to ensure that the pension fund is treating them equally to Surrey County Council.

Councillor Trefor Hogg welcomed the proposals to benchmark the costs that the Surrey Pension Fund pays to Surrey County Council for services, saying he welcomed the statement in paragraph 24 with a commitment to benchmark costs and have clear service level agreements in place.

Summary of the Local Pension Board meeting on 26 July 2024.

Mr Evans introduced the Local Pension Board's Summary report. He highlighted the slight postponement to the Guaranteed Minimum Pension reconciliation work but said that this should be completed this year. Mr Evans went on to explain that a number of meetings have taken place since the Board meeting to discuss the Legacy Reduction Programme and that they had now received an iConnect file.

Tom Lewis, Head of Service Delivery for the Surrey Pension Fund, provided an update on the progress of the Annual Benefit Statements, saying that they were on track to issue them before the statutory deadline at the end of August. Mr Lewis said that there were still some data discrepancies which are being worked on, but progress had reduced the risk level.

Councillor Hughes mentioned that the Resources and Performance Select Committee had been looking at the new MySurrey/Unit 4 system and that recommendations from the Committee were due soon. He expressed concern that new starters were not being added to the pension system. Mr Lewis responded by saying that new starter packs have now been distributed.

Surrey Pension Team Overview - Quarter 1.

Mr Mason presented the Surrey Pension Team Overview report for Quarter 1 2024/25, highlighting that the funding ratio for the Surrey Pension Fund was 143%, that the Legacy Reduction work was progressing well, and that the third Pulse staff survey had closed on 30 June. Mr Mason also mentioned that they would be providing the Committee with more regular snapshots of the Surrey Pension Team's performance.

Councillor Harrison asked about the reduction of 10% in performance of retirements and survivor benefit payments over the quarter. Mr Lewis replied that:

we recognize that we've fallen below the standards we set ourselves and the performance of what was [inaudible] is that the immediate benefit team hasn't been consistent over the last 12 months. We recognize this and it's caused by a combination of the impacts of Unit 4. There has been some resourcing levels with absences in the team or vacancies that are open and in all honesty, there's been some inefficient processes and practices in place.

Mr Lewis went on to explain that they have blended the immediate and future benefits teams so there is a cross of them amongst the two teams. He added that the objectives of this are to:

  • allow for the development of staff to have a broader understanding of the case work
  • increase resilience for when they have absences and vacancies
  • allow them to deal with spikes of work and support in the closing week of payroll.

Change Management Update.

Nicole Russell, Head of Change Management for the Surrey Pension Team, presented the Change Management report for Quarter 1 2024/25. She highlighted the Communications Team's work on the Annual Benefit Statement, confirming that the team had sent out all planned communications within the agreed timelines. She said that the team had been nominated for a number of awards and that they had introduced new disability accessible templates for Board and Committee reports. Ms Russell also mentioned that the team had produced an LGPS Overview presentation for the LGA's Communications Working Group.

Ms Russell explained that they had launched the third staff survey in June, which had received an increased level of engagement for the third time in a row. She said that the Lunch and Learn programme had been well received, that a record number of Surrey Pension Team staff are being supported in their Certificate in Pensions Administration, and that they are developing a programme to upskill the leadership capability of the Extended Leadership Team.

Ms Russell said that the most significant projects being managed by the Project Management Group are the McCloud remedy and Guaranteed Minimum Pension reconciliation. Finally, she explained that they were making progress on a Digital Transformation Strategy, and that Mr Lewis is leading much of that work. She explained that they were looking to:

really use advances in technology across that are coming from all over the place, not just within the pension fund. How we can take some of those innovations and build them into the way that we are working so that we're really fit for the future

Ms Russell said that because her level of digital knowledge isn't strong enough they are looking at bringing in some external advice to support them in understanding what's happening in that dynamic world of digital innovation.

Draft Annual Report 2023/24.

Colette Hollands, Senior Pensions Programme Manager at the Surrey Pension Fund, explained that the draft Annual Report 2023/24 had been prepared in accordance with the MHCLG's statutory guidance and that it follows the format of the guidance exactly.

Ms Hollands explained that the new guidance includes new areas relating to fund management, governance and investment information and that there is now a standardised way of reporting Key Performance Indicators, making it easier to compare the Surrey Pension Fund to other funds.

Ms Hollands went on to explain that the most significant change in the report is that they are no longer required to include hard copies of our policies and strategies, although they can include links to policies and will add them to the Surrey Pension Fund's website.

Investment Manager performance and asset/liability update.

Lloyd Whitworth, Head of Investments and Stewardship for the Surrey Pension Fund, presented the Investment Manager Performance report, noting that the value of the fund had increased to £6bn and the funding ratio was 143%.

Councillor Eastoe asked about the BCPP Global Equity Alpha Fund, saying:

On the BCPP Global Equity Alpha, this is the single largest contributor to the fund underperformance. It mentions that this has been escalated to the chief investment officer, and I just wondered whether, you know, when we would like to get, I suppose, the feedback from that or how that was going to come, or whether you could update us on that.

Mr Whitworth said that officers had now had subsequent meetings with Border to Coast and that as of a meeting that I attended in Leeds last week there is going to be another workshop with all of the partner funds in the BCPP Global Equity Alpha Fund.

Councillor Potter said:

In relation to sort of the concerns and continuing frustrations that Steve has expressed and which I think, you know, have been-- has been going on for quite some time now. I think given what we've heard, you know, obviously, it makes sense to continue to give Border Coast a chance to see, you know, how these-- how they progress with this.

Mr Potter went on to ask about what the Fund's recourse would be if their concerns continued to go unaddressed, asking if it would be looking at potentially changing our pooling arrangements and moving to different pool or is this a situation where we don't actually really have any recourse?.

Mr Whitworth replied that:

There are other alternatives within the PCPP arrangement.

Councillor Potter asked about the alternative arrangements in relation to the government's desire for funds to be pooled, asking:

how-- but I mean, wouldn't that not put us in a difficult position in terms of the government's desire for a great proportion of funds to be pooled rather than independent?

Mr Mason replied:

You're exactly right, George, it would blow a bit of a hole in that. But I mean, it is a bit of a conflict, isn't it, really? If you're fully in the pool and you're committed to the pool, then what are the alternatives, you know, to leave the pool? An alternative is to get the fund manager to address the concerns which is I guess what we're trying to do.

Mr Mason added that with Legal & General funds:

we have a joint procurement with our 10 partner funds and Boulder to Coast also manage oversight-- some oversight for us on that.

He added:

Just to put the context of our relationship with Boulder to Coast, we're not a customer, we're an owner. So, for us to, you know, it will be beholden upon us and our partner funds if we felt there were fundamental issues with the company to challenge the board in the normal way.

Company engagement and voting update.

Mel Butler, Deputy Head of Investments and Stewardship for the Surrey Pension Fund, introduced the Company Engagement and Voting update. She explained that quarter 2 is the most active time of year for engagement with companies due to the high number of Annual General Meetings. Ms Butler highlighted that both LAPFF and Robeco are putting an increasing focus on financed emissions with LAPFF engaging with Canadian banks about their lending to oil and gas companies and Robeco extending their climate-related transition plan to include climate-related and nature-related aspects.

Councillor Potter asked about a point in Robeco's report where they state that their three-year engagement with financial institutions had not led to meaningful change at some North American institutions. He said:

But for us as a fund in our own right, where we have clear evidence like this of where the engagement on matters which are covered by our I policy have not led to success, it's the perennial question of what action are we going to take in these-- where we've got these examples based where engagement has not had the desired effect even after three years of targeted engagement.

Mr Kerr of Border to Coast replied:

I think the steps that we would take in terms of where an unsuccessful engagement would lead us to would be very specific to each company. In general, we do have, you know, a step of-- a stepped escalation approach to engagement and ongoing consideration of risk and, I guess, the outcome of that engagement with the companies that we invest in. How we work through those steps and work through those steps will very much be company specific.

Mr Potter replied that he was not suggesting that there was a problem with Robeco, but:

we seem to have-- repeatedly have these examples of where engagement concludes without the desired effect of engagement.

He went on to ask:

So the question is, we always talk about engagement with consequences, but where are the consequences in this case 'cause I've not heard any suggestion from what border codes have said, but off the back of, for example, paragraph 17, they're planning any consequences, any changes whatsoever.

Mr Kerr responded:

I think that some of the comments that are referred to in here are very much specific to RABECO's broader strategy, so some of their themes will cover companies that we invest in, but it may also cover companies that we don't invest in.

Mr Potter said he would welcome examples of companies that Border to Coast have engaged with, saying:

but I think the point I'd make though is I appreciate that this is an engagement and voting update in itself, so I understand why this is focusing particularly just on reporting on the engagement process and the voting itself, but if you're saying that, and indeed this is what I'd expect, that there will be actions taken, escalations taken off the back of the engagement, off the back of voting outcomes and things like that and responses, it would be very helpful if this report routinely reported on what those escalations are taking place and, you know, and things of that nature because I think at the moment we're only really seeing half a picture, we're seeing well here's the evidence base we're getting effectively. We're not seeing any indication of what decisions are being made off the back of it, which I think has been a recurring theme on this, but certainly the information mentioned will be helpful.

Mr Potter changed the subject, asking:

obviously a particular big area of investment at the moment globally is AI technology in particular, but of course one particular concern around with that is the incredibly high energy usage that goes along with it and the massive expansion of data centers. It's obviously, it's an emerging area, but I'm just wondering if it might be worth potentially suggesting that that could be a, that feels to me as a theme where there will be a need for engagement in the future to understand how the tradeoffs between the need to invest versus the ecological impacts are being managed.

Mr Harrison said that Let's ask questions about that of our advisors.

Councillor Harmer added that he thought that was premature and that the likely answer they would receive would be we don't know yet.

Responsible Investment Update.

Mr Whitworth introduced the Responsible Investment Update, saying that they are very pleased that the Fund had become a signatory to the UK Stewardship Code. Mr Whitworth also mentioned that the draft TCFD report for 2023/24 highlights that for all the metrics there's been significant falls, significantly ahead of the market and the benchmark changes on all the different metrics.

Mr Whitworth went on to explain that:

one of the most notable aspects is the impact from a fund switch where you'll recall last July, well 15 months ago in July we switched from a passive emerging markets fund to an active emerging markets fund. And that, emerging markets has been our biggest contributor to carbon throughout the portfolio.

Mr Whitworth finished by saying:

I think underlying all of that is that the trend has made some decent progress this year.

Asset class focus - real estate.

Mr Whitworth introduced the Asset Class Focus paper on real estate, saying that the Fund has received its first drawdown into Border to Coast's Global Real Estate fund. He also explained that Border to Coast is getting close to a go, no go decision for their UK real estate fund.

Adrian Brown was substituting for Anthony Fletcher and explained that Mr Fletcher had written a report on Real Estate which can be found on page 417 of the reports pack. Mr Brown went on to explain that:

CBRE, the global fund, which they manage for you, is going to be a significant part of the borders to coast global property offering. And indeed, I think that that holding will transfer in specie, which makes it more efficient.

He added:

On the UK, there are a number of funds. Performance on the UK has been slightly more challenging. The market here has been difficult, partly because of defined benefits, well, closed DB pension funds going for buyout and selling all their illiquid assets. And so a lot of property funds have seen significant sales pressure from DB funds that are aiming to de-risk, if I can put it like that.

Councillor Potter asked about the management of financial obligations around building standards, saying:

obviously one-- the question is what steps are being taken to manage the potential financial obligations in the future in terms of types and regulations around building standards particularly in terms of both commercial and non-commercial rental because I'm aware that that is a-- it's a fairly reasonable assumption to make that there will be increasing testing of obligations in the standards in the future.

Mr Brown replied:

one-- the main one is certainly energy efficiency, climate accreditation of legislation about not being able to rent buildings below a certain EPC rating and I can't speak for the explicit managers 'cause I don't know but all the managers that I have spoken to in the real estate space are absolutely migrating their portfolios. They've got plans about office books that are not efficient.

Mr Kerr of Border to Coast confirmed that they incorporate sustainability and future regulation into their due diligence processes when appointing managers for their Global Real Estate Fund. He explained that for their UK Real Estate Fund they will look at, one which is called BRIM and a second called GRESB which ultimately measures the sustainability of a building but also the overall building quality as well. Mr Kerr went on to explain that:

any new properties that we look at are focused in high quality, core dominant locations with very high quality GRESB and BRIM ratings which are kind of industry recognized for those sustainability characteristics.

Mr Kerr also explained that they have made one investment in Border to Coast's Global Real Estate fund and that there are five investments that are in the pipeline for the next 12 to 18 months to take us up to that fully committed position. Mr Kerr went on to confirm that they are aiming to launch the UK Real Estate fund on 1 October 2024 and that the transfer of existing properties will take place over the first six months.

Investment consultant update.

Mr Whitworth introduced the Investment Consultant Update, explaining that Mercer's initial three-year contract was up and that they have the option to extend the contract for a further two years. He added that:

we've reached that period now at three years. And so, the recommendation is to extend and use that option for two years on the basis of the knowledge of the fund as we move through the next evaluation as well.

Recent developments in the LGPS.

Mr Mason introduced the paper, saying that if the Committee had any technical questions, Sandy Armstrong, Technical Manager at the Surrey Pension Fund, was on hand to field them.

Mr Mason went on to highlight the Government's Pension Review, saying:

They issued that last Thursday. It has a response date of the 25th of September, so not a huge amount of time to respond to that call for evidence. And we are working with our pooling partners in Board of the Ghost and also independently and we will be sharing a response with senior stake-- yeah, we will be expecting to respond to that.

Mr Mason added that they are expecting to receive an invitation to speak to the Minister for Pensions about the Pension Review and that there will also be meetings next week between the minister and the pools.

Mr Mason went on to explain that the call for evidence on the Pension Review covers 10 questions covering three categories:

  1. Scale and further consolidation
  2. Cost versus value
  3. Investing more in the UK.

Mr Mason finished by saying that one would expect the budget to be a target date for the Pension Review to report.

Councillor Harmer asked if the Surrey Pension Fund's response to the Pension Review would be subject to our fiduciary duties, to which Mr Mason replied, Absolutely. Mr Harmer said he was concerned about the government using the Pension Fund to fund what I would regard as interesting new ideas. Mr Mason replied that:

if we manage it, we'll have a broad set of investments necessarily on the world stage.

Investment Benchmarking.

Mr Whitworth introduced the representatives from CEM Benchmarking who would be giving a presentation on their benchmarking work for the Surrey Pension Fund. He said that CEM Benchmarking had presented to the Committee for the first time last year and that if the Committee wished to go into the detailed report, they would need to move into part two of the report. Of the agenda, thank you.

Fleur Double Rule introduced herself and said that she was joined by her colleague Joao, who had worked on the Surrey pension fund report for the last couple of years. Ms Double Rule explained that CEM Benchmarking is a global benchmarking firm, saying that:

We are a global benchmarking firm providing investment and pension admin benchmark funds across the world. ... We've done this for about approximately 30 years. Our 30-year anniversary is two years ago. We serve more than 20 countries across the globe, and we tend to skew large, and this holds true for the LGPS group as well, which I think is probably the group that you're most interested in.

Ms Double Rule explained that they had worked with 36 of the LGPS funds last year and that this has been broadly stable. Ms Double Rule said that they are currently in the midst of conducting benchmarking for the year ending 31 March 2024.

Ms Double Rule explained why funds benchmark with CEM, saying:

I think an important thing, we're not consultants. We source the data from the funds directly, so these are not figures that are publicly communicated either by the pension funds themselves or the managers themselves. These are actually the facts and figures of what funds are paying for those particular assets and mandates and the returns recorded, and it also identifies opportunities to improve and deliver accountability either to the fund itself, but also in this particular case to the pool.

Ms Double Rule went on to explain that they have made two changes to the peer group comparison. She said that they have broadened the peer group from 20 peer funds to 37 global peer funds, but that they had compressed the banner of the funds that you compared with, saying that:

the banner of the funds that you compared with, excuse me, are now between 3.7 billion and 9.7 billion.

Ms Double Rule explained that they made these changes because:

we wanted to include a broader global peer group to really answer the question, you know, are the costs we incur reasonable for a fund of our size?

Ms Double Rule went on to explain that Surrey Pension Fund's total investment costs for 2022/23 were £37.8m (75.1 basis points), which was similar to the previous year. She said that the difference between those investments cost year on year can largely be attributed to a drop in performance fees, adding that this is not unusual.

Ms Double Rule said that Surrey Pension Fund's costs are in line with their peers, and:

if you were to take a sample fund, you take Surrey kind of straight in the line.

Councillor Eastoe asked about Surrey Pension Fund's overall allocation to private markets and if this was lower than average. Ms Double Rule replied that it was about, it's on par with the global average but a bit lower than the LGPS average.

Councillor Eastoe asked if the peer group benchmark is global or LGPS specific. Ms Double Rule replied that:

So, the peer group benchmark reference here is global. It's your whole group but it's not the whole banner.

Ms Double Rule explained that the peer group is adjusted to reflect Surrey's asset mix, saying:

So, the peer group has roughly the same allocation, asset allocation.

Councillor Eastoe noted that Surrey Pension Fund is not performing as well as some of their peers, asking if there are any particular characteristics that pick them out as to why they are actually performing better?. Ms Double Rule replied that

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