Transcript

Hello, everyone. Welcome to the New York Pensions Board meeting for November. I'm Tejan Edy Karshev. I'm the chair of the board. So we have a packed agenda today. So I'll take names of people and then if you can just raise your hands and introduce yourselves or just acknowledge that it is you and we can we proceed. Yeah, so I'll just go with the order in front of me. So, Philippa. Hi, yes, I'm here. Philippa, employer rep from Juniper Ventures. Thank you. And then, Catherine. Catherine Hanlon-Chambe, employee. Bless you. Thank you. Thank you. Christine. Christine. Christine Lander, Unison Rep. representing members. Thanks, Christine. Then, let's look at the officers. I can see the screen now. Rakesh. Yeah, good evening. My name is Rakesh Rajan and I manage the pension fund for New. Hi, Rakesh. James. James Cox, AD for Transactional People's Service. Here for Pensions Admin. Thank you. Christine. Hello, Christine Alsasser, Dems Services. Christine. And Jackie. Jackie Andres, Pensions Contracts Manager, the other side. Hi, Jackie. And I see, no, I can't make out if the others are external or, I know James is an officer. So, we'll go to James first. James Grafton. James Grafton. Yeah, James Grafton, Pensions Admin Officer. Hello. Hello. And I'm not aware of Mainier. Would you want to introduce yourself, please? Hello. Sorry, I'm driving. I'm Mainier Hall and I'm the Head of Financial Control. Thank you. And finally, we have a guest today, Janet. Janet Morville- Good evening. Yes, Janet Morville-Smith. I'm Head of Briskin Compliance for Local Pensions Partnership Admin. Hi, Janet. Thank you for making the time for this meeting. Okay. Let's look at the agenda. Item three is declarations of interest. Would anyone like to declare any disclosable pecuniary interests or non-pecuniary interests which are relevant to this meeting? No. Let's note it as that. And then, the minutes of the last meeting. So, I wasn't there in the meeting. Would the board agree that the minutes are a record of the meeting? Could I actually get people to raise your hands? Yes, I would agree. Raise your hands. Yeah, I agree. Okay. The other voting members. So, that's Christine and Catherine. Yeah. Okay. Thank you. So, now let's move on to the presentation from our guest, Janet. So, that's on pages 11 to 42. So, the purpose of this report is to provide the board with an update on the internal control assurance. And I think the last year's meeting is attached to this. And I think, Jackie, you also sent us the current year's meeting in an email. Janet, would you like us to have that version open or would you like to review the last year's review the last year's report? And it's there for your information. So, happy for you to just note those reports. Okay. Thank you. So, do you want to make the presentation now? Yep, certainly. Thank you. So, yeah. Within your pack, there is a copy of the internal control assurance report, which is a report that I have created for the past few years for all of the clients that LPPA do pension admin for. We are moving away from that. So, I wanted to do a presentation to you today about AAF reporting, which is audit assurance faculty and the future reports that the board can expect to see going forwards. So, if I can share my screen, I will run through the information that I have for you. Sure. Are you able to see that now? Yeah. Thank you. I can't see you guys anymore. So, if you do have any questions, please just shout up. Sure. Okay. So, LPPA have been doing a lot of work over the last period, the last 12 months with KPMG, who we have chosen as our independent assurance body, the auditors that will be doing this piece of work for us going forwards. And the reason that we've gone down this route is that whilst I've been providing the annual assurance reports that you have in your pack at the moment, I am conscious that, you know, a board such as yourselves could say that isn't truly an independent assurance, because it is being created by myself in-house within LPPA. So, it's my assurance to you that LPPA is doing what they should be doing and meeting the controls to mitigate the risks around the administration of the pension scheme. So, we took that on board and we are moving towards what is called AAF0120, which is an independent assurance. It's independently tested and signed off by KPMG, who, as I say, is the auditor that we have chosen to engage with for this piece of work. And the reason we're going down this route is more and more customers are wanting assurances and transparency over the controls that we operate. And it also is intended to help with future audit requirements. As you can imagine, LPPA administer pension schemes for 18 different clients. So, each year we have 18, at least 18 auditors wanting to come and look at what we do to give you that assurance that we are providing the service that we should be providing to you. So, once we move towards AAF, the provision of this report should satisfy a lot of your audit requirements and will hopefully reduce the number and volumes of audits that we have to manage. And because, as I'm sure you can appreciate, we have, you know, we have so many members of staff, so much resource that is there to do the pensions admin service provision. And it's those exact same staff that get pulled to do audit work as well. So, it does have an impact on, you know, the SLAs and the, you know, the work that gets processed. There's a lot of assurance out there. There's different reports, different types of audits and assurances that can be provided. We chose AAF because it is more closely aligned with pensions administration. The SSAE type and ISAE type of audits and assurances is more around the control of financial reporting. And on the other side of the scale, there are, you know, service operating models that look at, they focus on bespoke items such as trust services and umbrella framework. So, the AAF 0120 was the subject matter that more closely fit with the services that we provide to yourselves. So, that was the reason that we went down this route. As I said at the beginning, we've done an awful lot of work over the last 12 months. So, we started in, well, more than 12 months now. We started in 2022 with all of this, where we, we did a piece of diagnostic work where we, we assessed where we were against the controls required for AAF. And we carried that through. We received a gap analysis and some actions that needed to be completed. And we carried that through throughout 2022 to do some remedial action, to remediate those gaps and to make sure that we were aligned in, you know, with, with the controls that we have around the processes that we manage in order to set us up in a good light to actually go through a full-blown assessment against the AAF standards. In 2023, KPMG came in and, and did what they call a Type 1 assessment. And what Type 1 means is they assessed us at a point in time. So, as at that point in time, they tested our controls to make sure that as at that point, our controls were effective and they were working as intended. And in February last, sorry, February this year, we received their Type 1 report. And I'll come on in, in a little bit more detail of the results of that in a, in a little while, but that was shared with yourselves and with our other clients. And what we are now working towards this year, and we started this work earlier on in the year is a, what they call a Type 2 AAF report. And what Type 2 means, what the difference between a Type 1 and a Type 2 is that Type 2 will look at the whole year, the whole period. So the audit starts from the 1st of April this year, and it will span through to the end of March next year. So it will be the whole financial year that this audit will cover. And KPMG will test our controls throughout that period to make sure that they know that they worked at a point in time with the Type 1 report, but now they're testing them to make sure that they continually work across that whole period. And then that Type 2 report will be issued in May 2025. And again, that will be shared with, with yourselves and the rest of our clients. And that will give you a, a whole year's assurance that in, in the previous financial year, all of our controls were effective, hopefully, and, and working as, as they should work. And then we're going to continue that on a regular annual cycle so that every year you will receive this AAF report and that will replace the internal assurance report that I have been previously providing to you. So the, the various control objectives that sit within AAF and, and if you, if you compare these objectives to the objectives that I have been using in my internal reports, they are the same. I based mine on a benchmark of AAF controls originally. So, you know, we, we were quite well ahead of the curve when we started this piece of work because we'd already been working on that as best practice, but we're now formally being tested and assessed against these standards. So there are various objectives for pensions administration itself, which, which covers accepting new clients. So that, that would come into play if we were to take on a new client. But it covers processing transactions. It's maintaining financial and other records. So all of the, the record keeping that we do, safeguarding the assets, managing and monitoring compliance and outsourcing and reporting to clients. There are also objectives that cover the information technology that we use in order to provide the pension admin services to yourselves. So that looks at the security of, of the technology that we use and the recovery processes of, of any interruptions to, to those systems and all that type of, of objectives are covered. And they are tested to make sure that, for instance, our disaster recovery plans are documented and, and tested to make sure that, should anything happen, they, they are, you know, fit for purpose. With the reporting that KPMG do, they have, they have three qualifications for their reports, which are the, the, the usual red, amber, green type ratings. But they use the, the, the, the audit opinion of unqualified, which is the, the best results that that's what everybody aspires to, to achieve. So if it's an unqualified opinion, that means that, that there are no or only minor exceptions within their testing and none of those, those control objectives have affected the, the quality of the control itself. A qualified rating would be where there are some exceptions and, and it has had limited impact on the testing. So, so some of the testing may have not worked as, as intended. And then an adverse qualification is basically the, you know, the controls are, are not working or they have found excessive exceptions, um, that mean that, that there are issues that need to be addressed, um, and, and to be rectified. So that's, that's the way that KPMG will rate the reports that you will be seeing in the future. The type one report that we received earlier this year, we, we did receive an unqualified rating, which is the equivalent to the green, um, red, amber, green type rating, which was good. They tested 112 unique controls. Um, and I use the word unique because we actually have about 150 controls in place around all of the administration processes that we undertake. But we use the word unique because some controls are duplicate controls that would be used in multiple processes for, for example, the, the payments are, you know, the payroll, uh, process to pay out benefits would, they would have the same control, whether the benefits are paid to a UK resident or an overseas resident, um, or it's, it's a one-off payment as, as a refund to somebody leaving the scheme, for example. So, so that, those, those controls, regardless of the type of payment going out, it would be the same control around the payroll process. So, so it's multiple controls rather than a unique control, if, if you understand my meaning. So they tested 112 unique controls. We provided them with 384 items of evidence in order for them to do that testing and for them to, um, you know, get themselves the assurance that they need, that we are doing what we should be doing. The results showed 107 of the 112 unique controls passed the testing with no exceptions at all. We had five of those controls that had minor exceptions, but those minor exceptions didn't affect the qualification of the rating. And, and I'll come on to those five exceptions in a, in a minute so that you can see the, you know, the idea of, of what their, their findings were. Um, and then the next steps I've just said, we are working through the type two. Um, so what happens with type two is because it spans a whole 12 month period, KPMG have already been in and tested our controls from April to the end of July. So they've tested those. They've gone away to document their findings. They will be coming back in at the end of the financial year. So early, early on in, in the new year, they will be coming back in to test the controls from August to the end of March. So they will have tested those controls throughout that 12 month period. And then they can, um, uh, pull their findings together and create their, their report and let us know what, what their opinion is and, and what assurance they can give to, to you as our clients on the controls that, that they have tested. So that's, that's the work that's, that's happened to create the type one report and, um, is now ongoing towards receiving the type two report. The five exceptions that KPMG found in their type one testing, um, were issues with, um, for instance, um, it was things where we actually did what the control required us to do. Where we fell down was the, the department that did that control didn't always document it. So we could see on the system that, that the, the control had happened, but there was nothing to evidence who had done it, when it had been done. And, and, you know, and that, that kind of evidence is necessary for an external auditor to come in and provide that full-blown assurance that that control is happening and is happening on a regular basis. You know, if, if for instance, the control is that on a monthly basis, the operations manager will review so many cases and make sure that, you know, that, um, the, the team are following the correct, uh, processes, that's fine. But that operations manager needs to document the cases that they have checked and the outcomes of those checks and the date that those, those checks were done. So it, it was things like that. Um, the, we had, um, another exception whereby we have a company called Hugh Simmons, um, where they are the company that we engage with for our outgoing post. So when, sorry, for our incoming post, I beg your pardon. Um, so Hugh Simmons are the, when somebody sends us a piece of post, it goes to Hugh Simmons, who then scan the post onto our systems, um, and, and, you know, make sure that we, we get all of the, the documentation that is sent through the post physically to us. So, so what happened with that one was the, the control was that there should have been a regular, uh, review meeting with Hugh Simmons to make sure that they were meeting their SLAs, that, that they were, uploading the, the documentation to our systems as they should have done and in a timely manner. Um, and it transpired that those review meetings were not happening as frequently as they should have done. So that was one thing that KPMG picked up on and we have corrected that immediately and we now have monthly meetings with them to make sure that they are fulfilling their duties as, as they should do. So that, that's really, um, uh, kind of a whistle stop tour through what AAF is and why we're moving towards that. Um, and, and I hope you would agree that that would give you much more of an independent assurance of the, um, the pension administration services that LPPA are providing to you and that we are providing those services in line with, with these, um, control mechanisms that we are mitigating the risks around the, the administration processes that we perform. Um, and that it's part of it is also checking that we are in line with, you know, the, the regulations and, and the code of practice as well. Happy to take any questions. Thank you, Janet. Thank you for that. Yeah, I agree. I think it's, it's a very good step to have independent assurance on controls. Uh, may, may I ask if, uh, what may I ask what the primary driver was to put this in place? Is there a new requirement or was it something pushed, you've seen pushed by, uh, this scheme and maybe other schemes? It's, it's something since I joined LPPA, it's something that we've been aspiring to do, um, for, for a few years, um, because, um, a lot of our clients were asking, were asking for this assurance, uh, before I joined LPPA there, there was no assurance, um, about the, the service that was being provided. Um, there was no assurance that, you know, that the, the risks around pensions admin work were being mitigated and controlled effectively. So that's why I introduced my internal report that I created on an annual basis. But my intention was to move towards AAF, um, as soon as we were possibly able to do to give, because clients were asking for independent assurance. Um, and as I said at the beginning, I was very conscious that my assurance could be deemed by a pension board or a pension committee as not being truly independent. It's, it's kind of marking my own homework, if you will. So it was always the intention, but it has taken a little while for us to get there. Right. Thank you. And, uh, I have one, one more question. So the, uh, type two assurance, which KPMG is doing is, are they going to look at the same 112 controls or are they looking at it from different lenses as well? They, they will look at, yes, they will look at the same controls. Um, those controls may not be identical to the controls that were in the type one report, because as we, uh, as we change, sometimes we change processes. We, we improve the way we do things. We're introducing automation within the new UPM system that would, that we use. So as, as things evolve, the control might change. So therefore they will be, they will be looking at the current controls for that 12 month period that they are reviewing. Okay. Understood. So, so I, I suppose in, in the previous type one testing, you were still in the period of transition between your previous system and this current system. Correct. Many, many, many controls may be replaced or may redundant. Yes. Yes. Okay. Thank you. I just had those two questions. Any, uh, I'll, I'll open it up to my, my, uh, my colleagues. Thank you. Any, any questions for Janet? Okay. It's all away Janet. That's what it is. Yeah. I've done my job well then. No, no, no questions from me. Thank you. Thank you very much. Thank you, Janet. Uh, I'm just, uh, I think is, is that the only agenda item with Janet's, uh, involvement? So I think, um, I think Janet, thank you. Thank you very much for making that presentation. We'll, we'll, uh, keep an eye out on, on, uh, on this testing and you can share with us any interim results, which KPMG tell you, uh, but we'll, we'll all be looking for the, um, the report next year. In the meantime, we'll also look, review the reports which we have here and we'll get back to you if you have any questions. Thank you very much. That's fine. Okay. Thank you very much, everyone. Bye. Bye. Thank you. Okay. So let's move to the next agenda item, which is the pensions action log. Uh, James and Jackie, is that with you? Sorry. Yeah. Just scrolling down through my, um, paperwork. That's pages 43. Um, I'm afraid I don't know, um, if there's been, uh, um, any movement on, um, PB 47. Um, James, do you have any, uh, anything for that? But the, uh, internal audit one, so yeah, the internal audit, that's, that's the stand that's been left as a standing item on the action log until, uh, we kind of sit down with internal audit to see their plans for the 25, 26 year, um, in relation to sort of any audit they want to do in relation, um, the launch of the new general code of practice and our compliance with that. But that's one where we're obviously working with Barnet and Wadden to get kind of our action plan set up. So possibly it's, it's one that's on the action log. It's, it's possibly just one that we just didn't want to lose sight of, but I'm kind of, you know, I don't see possibly being in the 25, 26 internal audit, if I'm honest, because the general code of, uh, sorry, would have only have just, uh, oh, it's only just sort of come out this year and we're obviously going to implement our action plan from the new year. So I'm not sure that internal audit will, but we'll keep it as the, the action if you want, uh, chair. Could I, uh, could I request that a new action for that specific point is opened? Because if someone looks at this, it looked like it's been open for two and a half years. So it looks like, you know, we're not moved on that. So I think you can close it with the comment you just made and have a new action just for, uh, open item for 2025 or, uh, you want, you want to wait for the code of practice to get embedded and then you won't have it. No worries. I will put words to that effect and then, uh, put a new one in. That's fine. So, uh, PB63, I, uh, did, admittedly it was only, um, yesterday, but I did, I did send out, um, resend the, uh, the, the missing, um, logins for the Barnett-Waddingham, um, Enlighten, um, portal, training portal, um, and, um, Philippa and, um, uh, Catherine have, uh, acknowledged receipt of those and actually, I believe both of them, uh, you managed to, to log into that. So, um, if you could please try and find some time and, and go through that, um, it does seem to be fairly good. Actually, can I just jump in a minute? Oh, yes. So I did log into it today. Yeah. Well, um, I had a bit of a break and on one of them, I got to like 40% and then I weren't sure where else to start clicking to get any further. But is it, is there, um, tasks that you have to do on this? Um, I'm, I'm not sure, um, I haven't actually gone through that. If you want to give me, um, uh, a call when you can. Yeah. Um, and we'll see if we can go through it together. Is that all right? Okay. Yeah, that's fine. Thanks, Jackie. No problem. Oh, sorry, Jackie. Um, Catherine, you have to make sure you click on every video because that also accounts to the percentage. Yeah. As well as answering the questions, if that makes sense. I clicked on the video. So if you don't watch every video, it will give you 40% or 50%, but you have to look, you have to see every video to get 100%. So, and then it, there was a bit that you had to trial, there was a trial test thing. Yeah, and then you have to read the, yeah, and answer those questions. Yeah. After you've watched every video, if you don't watch every video, or at least listen to it, it, um, then you won't, it won't, the percentage won't change. Right. Okay. I'll have, I'll have another little go of it. Right. Okay. Thanks, Christine. All right. Um, uh, PB 64, um, I'm afraid I've, uh, neglected to, to look into that. So I will, um, try and look into that this week and get something out to you on, on that one. So sorry about that. Um, 65, um, this was, uh, uh, an action for Rakesh and Stephen. So I don't know, Rakesh, if, if you've got anything to, to add to this. Yeah, I, um, I think myself and Stephen reached out with the response from the investment advisor. Uh, I think, uh, James has that, so gone through to Tej, I think it was sent to you. Sorry, I, I forgotten what this is about. Okay. I think it was in my absence, um, uh, Stephen, I think you asked Stephen a question regarding investments in India. You may recall. So we reached out to our investment advisor to get, uh, uh, a lead on that. So that's a reply that we got from them, just in terms of what we're doing on our investments going forward. And, uh, I think, I think that's right. I think we did have a presentation from Stephen, two meetings back in response to this. It was possibly not the investments in India too. So I think the liability driven investing related question, I think something about that. Okay, so yeah, um, yeah, that action has been. But I think we, we did, yeah, we did, we did have that so we can close. Okay. Wonderful. Um, and with regards to PP66, um, I, uh, have been nagging LPPA to, um, give us further details on the breaches being put those into the, yeah, the, the normal monthly reports. Um, so I'm not going to shut up about those at our meetings until I get those details. There's, there's other things we want added to the reports as well. So it's all part of and parcel of me nagging for further details. I'm afraid that is still open, but I am working on it. Can I just clarify just for the minutes that it's the ICO, it's not the ACO, um, just in terms of when GDPR, GDPR breaches are reportable, it's the ICO. So just notice that on the log. Thank you. Who knows? The ACO might be a completely different organisation. Okay. Okay. Great. Thanks Jackie. Um, let's move on to the next agenda item, which is the pensions administration report. Uh, that's pages 45 to 6. Uh, Mr. Grafton. So, oh no, that's, that's my one. I'm getting confused about which ones we've got. I do apologise. Um, okay. So the, the legislative update, um, so yeah, the start off with, we've, obviously we, we've been, um, I've spoken about the, uh, the code of practice before, um, and, um, we, uh, we, we, we got the, uh, we got our actuaries Barnett-Waddingham to, uh, to run a, um, a report and they have, um, yeah, we've, we've, we've got, um, um, the, the initial report, which is that we are not doing too badly, but there are obviously some areas to, uh, to, to, um, to improve on. We have been working towards getting together a, uh, a proper plan to, to make sure that we comply with everything, but that's not quite ready yet. Um, uh, we've got, um, with regards to McLeod, so that's the, uh, the, um, age discrimination case. Um, we, um, there are still some further, um, um, improvements that need to go into, um, LPPA's pension administration system, UPM, um, and they are to be expected, um, within the next, uh, next few months there. They should be going into the test system in January, I believe, with going live in February, so that should be just about everything that, um, is needed to do to run all the various different calculations, um, especially, you know, checking back over past calculations that have been, that have been done and were thought completed, but now have to be checked again to see if they're compliant, so that should be, um, sorting, being sorted out soon. We are still asking them for further details, you know, proper details of, of who in the Newham fund has actually received a, uh, a pensions uplift as part of the McLeod remedy, um, and we're still waiting for those to be added into our reports, as I said, with regards to, on the, the action log, there's a number of things I'd like added, and I will knack until I get them. Um, so, um, with regards to exit cab, there, there's been no, no talk about this at all. It's not something that has currently been, um, appears to have been spoken about by the, the, the new government, um, and actually at the, uh, the, the last, um, committee meeting, it was requested that, um, I just pare down the information that I report back to, to committee on, on, um, the, uh, the exit cap, and I wondered if you'd want me to do that here, because there's, there's quite a lot of details in there that are there, this, every, every report haven't changed. I could just sort of, you know, pare it down a little bit and, uh, um, just leave it there in case there is going to be, um, an update. I don't know if you want me to do that. Yeah, I think, I think that's a good idea. You can probably just summarize the, what the exit cap, uh, regulation is, and then just say that there's no update, and maybe the, the period when you do get an update, then you can bring back the whole thing. Yeah, that, that, that, that, that's the idea with the committee as well, so that's lovely. I will, make sure that's put in place for, for my report for the, for next time. Um, with regards to, um, pensions dashboard, um, um, everything seems to be moving quite smoothly on that. There's been no changes on, um, any of the, the legislative, um, steps, so we still need to be, um, ready to, to, to upload onto the, um, uh, upload onto the, the dashboard by, um, um, October next year. That's, that's our own, um, personal, uh, sort of time for, time frame for getting out there, but that's just making sure that we are updated, um, uh, uh, online at that point. Um, the, the actual dashboard will not be going live until, until much later. Um, but, uh, we had, LPPA had a, uh, round table discussion, um, last month about the current progress and everything. They're, they're committed, yeah, they're, they're confirming that everything's still on track. Their own timetable is still working, and, um, they don't have, don't foresee any difficulty in, um, meeting the deadlines for that. Um, we had the last pensions community meeting on the 16th of October. Um, those, uh, the, uh, one of the appendix should be the, the, the, the minutes for that full meeting, um, but, uh, the, the main topics are, we, as normal, we had a, uh, an update on the pensions administration, um, they, uh, covered, um, an update on the, the pension fund business plan, and also, they, there was an awful lot of talk about the investment strategy implementation as well. Was there any, um, I didn't see in the minutes, was there any, um, action for the board or any escalation or comments? Um, it has to be stated that, um, unfortunately, the, uh, the last committee meeting had to be caught, uh, um, cut rather short due to, um, committee members having to go off to a different meeting. So, the, uh, the, um, the pensions administration update, which included the details from the board, was kind of moved around in the agenda, and we didn't really have time to present it properly. So, no, nothing really came out of that, I'm afraid. Um, it said, yeah, we should have had another, uh, at least another hour of the meeting, and it was, it was just an hour long, I'm afraid. So, sorry, that was, there wasn't anything particularly that could have come out of that. And last thing on, on this, um, the, uh, we are, the, the, the, in, as part of the Maldishan House, um, uh, discussion, the, uh, the Chancellor has talked about creating pension mega funds, um, and exactly what that means for the, uh, the LGPS. Well, at first we thought it was going to be, um, they wanted every pension fund, um, in the LGPS to merge together and become one giant super fund. Um, it's not the same as merging the administration, it was just the, the, the fund itself, but apparently that's not quite the plan, um, and, uh, we believe that it's actually, they're planning on creating, um, a num, they're, they, they really, really want us to merge our, pool our funds together, um, over sort of local districts, um, but there's a consultation out on how that would actually work. Um, and there's also, you know, pooling being asked to be done in the, uh, the private sector as well. So it's not just the, the public sector or local government scheme that's being asked to, to pool, it's the private sector as well. In fact, they've got possibly, uh, going to be mandatory, whereas, um, the local government is just a bit more sorted out yourselves before we tell you exactly how to do it. Um, but we're going to be expecting, so the, the, the consultation with that doesn't, uh, is still open. Um, and when, you know, full results come in for that, I will present that again at a further, um, so with that, are we, are we saying that the fund has to change its strategic asset allocation? Uh, so I think right now we have, I have, we have an investment in the, the London sale, right? Which is sort of like, uh, like a, uh, what do you call it? A pool? Uh, well, is, is that expected to be like unmounted and invested in a bigger fund or what was the... Well, how, exactly how it's going to work, we're not quite sure. Um, I don't know if, if Rakesh can give any more details on this as well, but, um, as far as I can tell, it's, it's, it's sort of like the London Seaf, but bigger. So at this moment in time, um, the key thing is, um, working with the pools in terms of providing the response to the consultation, which I think closes on the 16th of January. Uh, we've, uh, been to a number of meetings with the London sale and all the authorities are engaged with that. And obviously there will be some areas within the response where there will be some questions and further questions asked from the local authorities and the pools in terms of how this is going to work practically. Uh, so I think the key thing is, um, the strategic asset allocation and the decision making process will still stay with the actual, uh, local authorities, but once those assets are pooled and the way that the, as they do at the moment, all the assets would need to be pooled. They're hoping by 2026, I think that'll be very tight if you've got, um, private market assets to move across so quickly, cause there's a huge transaction cost on that. So it's just about providing a market for those assets as well. That's right. Indeed. So yeah, it's, it's really in its, uh, early stages, but they are, uh, expecting responses from all the local authorities. And then subsequent to that, we'll get further replies back from them. And then obviously we can take this further. But it's very early days. Yeah. There is a, there's, uh, a lot of debate going on at this moment in time. So it's obviously, uh, it's the first stage. I think that it may be after the consultation responses come through, they may look at other ways, but at this moment in time, it's really, um, the, the time constraints that you have in terms of moving all assets will have to be probably revisited. And I think that's the only thing that local authorities can be keen and not having additional expenses can understand the whole pooling aspect. I think for Newham, we are quite way down that line already. We have, we have over 60% pooled and we are also looking at our property mandate to be pulled over. So, which was part of the plan by 2025 next year. So we'll have about 75% of our assets pooled. The 25% remaining are the illiquid assets, which are, again, as I've said, they will take a bit of time. So it will require a lot more consultation and development and processes in terms of how we can do that. And, uh, just one more question about that. Do we know if the consultation says something about the actual administration of the fund? Are we still going to have the administration piece or is that going to be pooled as well? I think, James, sorry. I was going to say sort of, it's kind of, it's not necessarily explicitly stated whether that's the plan. It's something that's being reviewed anyway, but it's kind of as part of almost the, um, good governance. It's almost kind of looking at sort of the administration as a whole. So it's not ruled out. I know there's a separate work stream going on, uh, the aising with sort of different, uh, local government, uh, pension administrators to try and look at the options of pooling. Um, but I think the main priorities around the investment side, but I think the admin is still, it has a, it's not a, it's not a case of it won't happen or it will happen. It's just a case of it's, it's being explored. Um, I don't think there's a commitment either way yet. Um, we're, obviously we already part, you know, working with LPPA. So in theory, we're kind of already, um, sort of we've outsourced that function largely. So it's more of the, I suppose the small, you know, the in-house ones, which will be more impacted, uh, depending on the situation, but like I said, it's, it's at the stage now where they're just exploring. Um, so yeah, we don't really have any firm information at this stage. Okay. Thanks. Thanks James. Thanks. So Jackie, I think if, uh, if we can, uh, probably include this as a standing agenda item, uh, going forward, I think maybe early, early next year, there may be more movement as, as and when people respond to those consultations and we get more feedback. So I think if you can include this as a standing agenda item for next year, at least, I'll, I'll put that down share. No worries. Thank you. Any, any questions for Jackie on the pensions admin update or, or to Rakesh? No, I've got none. Okay. Thank you. Thanks Jackie. Thanks Rakesh. Thanks James. So let me just go back to the first page. Right. Uh, then let's move on to the performance update. Is that, uh, James or you Jackie? Yeah. Oh, sorry. James. Oh, James, uh, Rakesh. So hi. Um, evening everyone. So, uh, the performance report in your packs focuses on quarter two, um, of 2024, so July to September. Um, there's eight key points, um, in that report. The membership of the fund has increased over the quarter. Um, we've seen a, the performance against the SLA stabilized. Um, they remain, LPPA remain above SLA, which is average out across all case types. Um, there was a slight decrease from Q1 to Q2, um, from 98.1 to 97.8%. Um, in quarter one, all case types except estimates were above that 95% SLA target in Q2, all cases, except for retirements, uh, from active status were above that 95%, which sits at 94.4. Um, so just under the 95% for that. Um, we've seen, there's been an increase in the number of cases from Q1 to Q2, um, up by 204. Um, the help desk performance has fluctuated as well. Um, 78, 78 and a half percent of calls, uh, answer within four minutes in July, 79.9 in August and 76.2 in September. Um, that is a slight decline from, uh, May and June's numbers as well. Um, along with the help desk performance, customer satisfaction, um, is fluctuating as well. Um, it ended 81.8% in September. Um, and that was up 71, up from 71.1% in June. Um, there's an increase in the members registered for LPBA's pension point, uh, that's the online portal, uh, for members where they can change details, uh, estimates and stuff like that. Um, we ended the quarter, um, with a total of 5,503 members, uh, 3,504 of those were active. Um, that's a total increase of 524 across the quarter. Um, the conditional data of the scheme remains steady. Um, at the time of writing this report, the latest monthly report we received from LPPA, um, was September, 2024. Um, in September, there were three complaints. All three were, uh, related to general service. Uh, one complaint was a death. The other was a refund. Um, and the other was a transfer case. That's all. That brings a total number of complaints to 21 for the year. Um, and we have our volume of complaints per member, uh, per thousand members is 1.6 and that's on a rolling 12 month basis. It's down, um, from 1.8 in the previous update, uh, to 1.6, which is still unfortunately higher than, um, LPPA's case, LPPA's target of one. Um, and in the, in Q2, we had one IDRP case received. It's currently still at stage one. Um, and that was surrounding a death case. And then to finish up, we had no data breaches across the quarter. Thanks, James. Uh, a question. So it looks like the service levels in the quarter were sort of going down, but the customer satisfaction levels went up. So do we know why we have that decoding? Um, I'm not too sure to be honest. Um, I don't believe that was included on the, um, on the report. I think overall it looks like it's moving up. Yeah. Um, but, but I think is it, is it possible that the people who were so serviced had a better feedback versus, uh, the people who missed, missed out on, or let's say they, they hung up because the call wasn't answered in time or something like that. Possible. Maybe, maybe it's a, possibly a question to ask the, uh, administrator. Yeah. James, am I able just to ask in terms of the total number of members that have signed up for the portal, is there any way of seeing who those members are? So from my perspective, um, I'd just be interested to know if it's possible, not names, but for example, how many Juniper staff have signed up to the portal, because, um, I certainly think that that number will be quite low and it would be good for us to do some comms out to our staff, encouraging them, reminding them of the portal and how they can sign up and register. I just wondered if there's any way that data can be split down further to show us who the members are or their employer. Yeah. Um, it's something that we can request. I'm not sure if we can run it, um, ourselves on LPP system, but it's definitely something that we can, we can request. Okay. Thank you. Any, any other questions for James? Okay. Thanks James. Thanks. Thanks very much. Thank you. Okay. Let's move on to the pensions admin strategy. Um, so that's, that's me. Um, we, um, so we do, um, it is, um, sensible to, uh, to periodically review our pensions administration strategy, which, um, we, uh, we sort of, uh, put through just over a year ago. Um, it's, it's, it's a document that, um, was not currently absolutely compulsory. It's something that's very, very strongly suggested as, as to be had by the, uh, the code of practice. Um, so we, we, uh, certainly got that in beforehand. Um, we've made a few amendments to it, nothing, um, nothing enormous, nothing that, that the change is fundamentally what the, uh, the, the pension, pension administration, sorry, nothing that changes fundamentally the basis of the strategy itself. We've just made a few updates to, uh, to keep in line with the current, um, technological improvements that we've had. So, um, I've put in there that we, we, uh, we have, um, amended, um, details about, you know, the, the duties of, of the employer needing to submit, leave and join the forms via, um, LPPA's, um, online employer portal. Um, and that they, employers must also, um, submit a monthly return to LPPA and still send us, us, Newham, um, details of the, uh, the monthly contributions that they've, they've paid over to us, um, so that we can keep track through, uh, the, the amounts that are being put into, to our, our, our bank account. Um, um, and, uh, also drawing, um, people's attention to the fact that we are charging policy so that if, if employers are not, um, complying with, with their, their, their duties, um, that, you know, that we will start, um, charging forms. The charging strategy is, is, just details the costs that, um, we, as a, as a, as an, as an, as an administrating authority, um, will go through if the employers are not providing us with, um, the right information. Um, so we've got the strategy there, um, and we're just asking, um, for, for the board members to, to, um, note and agree to the, the, the changes that we have made so that we can implement this and run it past a committee before sending it out to our employers to actually fully implement the, the, the, um, amendments made to the strategy. So are there any questions with regards to that? Is this, is this document going to be approved by the board or the committee? It's, it's, um, it's, it's sent to, yeah, sorry, in relation to policies, it's, policies are approved by a committee, um, but they're taken to board before it goes to committee for feedback and engagement prior to it being approved. So thank you, James. So if there are any comments on it, please, please do let me know. Um, so Jackie, just out of interest, um, one thing that's quite relevant obviously to us is the, um, admissions agreement for, uh, schools that are outsourcing services. So where you've got a performance standard detailed, what's the, um, if they're not compliant. So further on, I've seen obviously a table looking at how long some, uh, contractors have had a contract in place without having admitted body status. So one of these, um, 1.32 sets out that within 90 days of receipt, uh, insure admission agreements are in place. Now, some of those on that list are well beyond 90 days. So what, what's the actual, not, if there's non-compliance, what are you proposing then as a result of that? So just to, just to make, uh, just to chip in there, Philippa. So the part around the employer is just the exempt time. So I won't necessarily talk at the individual employer cases, but just using the example, uh, employers administering authorities are not complying with the various aspect of the past. So it kind of just goes down an escalation route. So the initial part, if we're using, uh, take end of year, end of year returns or, uh, sort of monthly returns, sort of being up to date with that. So you would kind of start with the initial stage of engaging with an employer, then you would kind of go down the route of having the next escalation route that you would be writing to and then meeting with, and then you would kind of start going down the route of levying, uh, sort of a charge if you're having to do kind of an admin task. And that's what I was wondering, is that actually set out in this document? So that escalation process of ultimately, if this doesn't happen, you know, you would be subject to a 300 pounds administration fee. Is that part of this then? That's why, yeah, that's why there's a corresponding charging policy sort of linked to it. So the, the past should outline kind of route charging policy gives the mechanism to charge, but ultimately depending on what potentially is a breach is what could go as far as being actually reported to the regulator. Um, so there's each varying kind of degrees is where it kind of goes from, but yes, the PAS is kind of there to outline the responsibilities and it should be kind of just covering off routes that kind of we go down. Uh, but the charging policy is there because the supporting mechanism. So is that charging policy in our pack? Yes. Apologies. Yeah, I'm just scrolling up to find it. So the administration strategy starts on page 117. And the charging strategy starts on, yeah, that's it. 107 is, there's, there's 10 pages of the charging strategy and then follows on the administration strategy. I actually don't see the administration strategy. Oh, that's 117. Oh, okay. Sorry, but again, forgive me. That's what I was kind of flicking through, but there's no sort of financial values as in this could be at the very top end of escalation because as an employer, this is potentially the document that I'm going to get. So when I'm talking to my payroll and pensions team about making sure that the monthly return is submitted on time, it's having that, you know, this is worst case. If we don't do this, we could be subject to a fine of X, Y, Z. I think because where the, the idea of the fine is not to kind of, I suppose it's, it's a last form of where we're kind of looking to get to. So normally the fine is more about putting something right. So if an employer is not submitting the monthly returns and we're having to essentially do the admin behind it, it would actually be recharging the work involved in it. It wouldn't necessarily be a case of a flat £1,000 or £5,000 for not doing something. No, I appreciate that James, but you know, ultimately it's like, you know, if I don't report to HMRC on our PAYE, if it's one day late, I start paying interest on it and that's made very clear from the get go. So the idea that there is a financial penalty, I do think that that's important to set that out so that people ultimately are aware that it shouldn't come to that, but ultimately that is the potential here if some of these people are not meeting their obligations. That's just my view anyway. No, no, that's, no, it's good to, like I said, this is, you know, as I kind of said at the start, this is kind of why FINS are taken to BALD. It's, you know, you, BALD's role is a critical challenge to officers and the administering authority. So we certainly have a, take that kind of point away. So I don't know if, I think Cathy's got her hand up. I think she's got something as well to say. Can I just say that there are examples here, things like on page 115 to say about, you know, if contributions are received late, it will immediately occur a £50 penalty. I think it's more of how it would escalate up. I think Philippa's kind of one is what would be worst case. And I think it might just be having to articulate because it would be variable about, depending on what it is, it wouldn't necessarily be a fixed amount that we would kind of go because partly some of it may be recharging actuarial fees, which you would be notified of when it's kind of submitted to the actuary on a, you know, on a day rate or depending on their work size. And then obviously there'll be time that internal officer time. Catherine. Catherine. I think just jumping on from what Philippa just said, from a union point of view, I mean, I don't know about Christine, but we get many calls just regarding, I've got some at the minute where they're thinking of taking their retirement, but obviously their pension has not been paid through, the admitted body status has not gone through, it's taken too long. How will they get their figures? Where's the money? Where's the interest? It's just, we get unindated sometimes with certain amounts of calls and you can't answer, you can't answer them all because it's a lengthy process. So I think by what Philippa is saying, it would make it a lot easier from, from our point of view as well, if something was put in place. It's fine. We'll look at the, the wording in relation to me and a bit more explicit around the potential costs that a employer may be subject to. But yeah, we'll take that point away. Christine. Yeah, sorry, just in agreeance with both actually. And sometimes the lateness is not just from the employer. It's, there's like paperwork that needs to go in place because they haven't got the right paperwork when they're joining the scheme, like, especially when we've had people to pee out and things like that. The new company, the people want that, you know, the employee wants to stay with the same pension, but they haven't got enough paperwork or the right paperwork. And that causes delays. But in a, you know, in addition, there, there are so many members that we're getting calls from, um, that are retiring and it's taken like four or five months for them to get their final payment. And it's a long, long time to wait when you're not getting no other funding, no other money coming in. So, you know, maybe. No, I think they're the kind of ones, they're the cases we all obviously want to be cited on. Obviously we'll pick up the employer stuff in the exempt item. Um, but yeah, in relation to just general cases of time lapse between someone announcing retirement and actually receiving their pension, that's something that, you know, we would like to be made aware of because we can at least work with LPP to see where the timeline of events took place, where the holdup was, you know, in relation to an admission, we'd be aware of that. But if it's a case of it's just a genuine retirement case, and that's potentially is a holdup within some part of the overall process, we need to kind of be made aware of that in order to do the relevant challenge. Um, because although we'd have the, the, the PAS in place, it's the case of, you know, monitoring where these issues kind of take place in relation to, you know, employers delay and sending a lever form, for instance, or LPP, not necessarily, uh, turning round queries or, uh, uh, following, completing the process on time. So yeah, it's, as you, you know, as, you know, as, you know, as, and when you're kind of made aware, please obviously make us aware, uh, when feed for us internally as well, um, we'll obviously pick them up as well. Um, but yeah, so we definitely look at the wording, um, that's very, it's come very strongly across, um, and yeah, we'll look at that. And then we'll still have to obviously circulate the, the documents to employers, um, for their input as well. So they can obviously put in this, they, you know, if we update the wording, uh, following, you know, we'll probably say, we'll circulate to board, circulate to employers before it kind of goes to committee, cause we'll have another chance. So it might be a bit too late to get it across the line for the December committee. Um, and we'll have to sort of revert to the March committee, but then we've also got a board in February. I'm going to take a stab at, um, so then we can hopefully have a, a pad and a charging policy that's gone through, um, sort of any update and got some employer engagement in it as well before it goes to committee. Great. Thank you. That sounds good. Thanks. Thanks. James and Jackie. So, um, if there are no further questions on that, let's move to the next topic, which is the risk register. Cool. Uh, that'd be me, uh, picking that one up chair. Um, so the risk register. So what I've just done, um, it's just put a, just the covering note just attached to just provide a little bit of background to why we have to have it. We have a risk register in place and also kind of just to kind of pick up on the points raised last month at our last board meeting. So updated the three columns. So now we have the risk prior risk level prior to mitigating actions, the current risk taken into account, current mitigating actions and the target risk for any few further mitigations that we have in place. Um, then taking it through just in relation to any updates that were kind of made off the back of last committee or the changes between the two, um, um, uh, committee meetings. Uh, so yeah, so the first, uh, kind of item was risk one, those charged with the governance of the fund unable to feel their responsibility effectively, either through loss of experience committee and board members and officers. So kind of reducing the, the target rating based on the, the assumption that, or the, the hope and the push for actually improving member completion rates on the final one enlightened system. Um, cause obviously a couple of you haven't yet to receive or only recently received login. So obviously it's not something we could have had in place earlier in the year. Um, so that's just a target that's just come in, uh, that we've just put in place, uh, risk six, uh, poor administration by the fund employers and payroll providers in the fund. Uh, this is all to do with just how we're going to be bringing in the communication plan just to talk, do a lot more target messaging, um, uh, with employers. And this will just enable sort of hopefully some targeted messaging. Uh, so obviously we kind of touched on admissions and we touched on leavers and monthly returns. That's where we're looking just to target some of the key employers or some of the employers with messaging at key times of the year. Um, and that's hopefully going to reduce the, uh, target risk in relation to that. And we'll certainly be working on that for the remaining four months as we come into the year. Um, uh, risk number nine, a lack of technical specialist knowledge held by officers to implement new legislation. Um, so obviously we've got the cover from having, um, sort of LPP and their sort of compliance team, but it's source and their technical team. Uh, this is again, it's just kind of promoting the enlightened system that hopefully will help improve knowledge of officers as well as, uh, members of both the committee and the board. Um, so yeah, keep plugging the enlightened system. I know you guys are on there from conversations earlier. Um, risks. So we have a separate risk just for communication with stakeholders. And that's obviously where we're looking at, or we've obviously brought the policy, which will hopefully get approved by committee ready to start the year. So we have a three year plan, a three year policy with a one year action plan. Again, just looking to reduce the target risks at just moderate possible on that. Uh, risk 22 delay not admitting a new employee into the fund. So this is, um, one that kind of, it's kind of being reviewed and I'll kind of pick it up in the next item a little bit further as well, as this one's just going to be expanded upon. Um, and then risk 23 is a new one. Uh, we're just obviously working to implement the general code of practice. Um, and so that's where we're working with Barnet Wadden in relation to the various, um, sort of an action plan essentially is where a gap analysis is, um, in relation to current compliance with the information that we currently have with the policies that we currently have and the processes that we do in place as well. Um, so that kind of covers off changes in relation to the, the risk register. Um, my view, and this is the kind of one that we've, we've had conversations in the, in previous ones is how we take it forward, um, during each board meeting, uh, whether we'd like for the interim just to discuss the items that are kind of on, uh, each risk within the register and we kind of run for it from there or whether board, um, are kind of looking just to kind of select a number of risks per meeting to kind of run through. Um, I just wanted to kind of give you the update on what's changed, but obviously I'm conscious that it's good to have the critical challenge and conversations around our risks, uh, from board. Um, my view is if, um, the officers can highlight what has changed. So some risk parameters for certain risks may change in a period. We may not be aware of that. So if you can flag that. Yeah, that's, that's what the initial overarching paper kind of does. Um, and I suppose the, with that in, with that in point. Is this going to be a standing agenda item? Yes. This sheet? This, rich register will always be in the standing item. I meant this sheet. The, uh, Do you mean the covering paper? The, the covering paper, yeah. Yes. Yeah. There will always be, and kind of how I want to kind of work with things going forward is every item that we kind of present to board. There is a covering report layout in front of it, which basically tries to just either make the key points, uh, that we're making or just kind of supporting information that's substantiates kind of an item. So obviously, as you see for the performance update, there's the covering paper that goes alongside the, the LPPA data that's submitted. Um, so yeah, that was the kind of one. And then, so if that's how you want to operate as a board, then it's more of a case of, um, continuing in the way that I've just done. They're presenting, uh, paper of what's changed between periods. I, I stressed that the meeting did take place between admin and finance, uh, last, uh, late last week, just to kind of review some of the categories cause in light of some, uh, operational, uh, changes within Newham, um, couple of the risks may have increased around, um, uh, sort of knowledge within sort of the organization. So some things will change. So there will be a number of updates, um, raised as part of the next board's paper. Um, and agreement I've made with, uh, Stephen and Rakesh is that next, uh, so the committee in March, uh, the risk register will be presented there as well. And that would be an annual, uh, presentation of the risk register to, uh, committee for their, uh, sort of their tape and also their view and oversight in relation to the risks. And if they've got anything in particular about how they want the risk to be managed going forward, the risk register to be presented, uh, monitored going forward, which may mean that they may give a little bit of direction around, you know, how, uh, board they would like forward necessary to focus on particular items or whether it is a case of we report as we do, obviously I'll provide feedback around how we're currently monitoring, but it's, uh, anything that kind of changes from there. Sure. And apart from the board and committee, who else, uh, apart from, you know, the discussion you said with finance, who else will change the risks here? So essentially it's a conversation that happens between admin and finance. Um, and then it's obviously taking the board, uh, for any comments, uh, challenge in relation to it and obviously highlighted there is taken, it will be taken to committee once a year. And the conversation I'm having is whether we submit our register to, uh, yeah, uh, to an independent, just to kind of assess whether our risk, we feel our risk, uh, kind of on par for the average fund within the LGPS. Um, and that may be something that we may engage by wanting to do. Um, but that's just something I'm having conversations internally before kind of getting an idea of cost associated with getting an external, external review. It may be worth a once in a period review, uh, rather than an annual, uh, kind of one. Um, but I think the main thing is, is that we just get the governance going in relation to us is that it's a standing item. It gives board enough oversight to kind of challenge or make questions on items. Um, and as I said, um, there was only the meeting with admin and finance last week. So hopefully there are a number of updates that will be coming off the back of that meeting. Um, so yeah, so there will, you know, it will, it's kind of evolving. It's not been something that I think has been scrutinized enough, um, sort of, um, kind of, because it hasn't necessarily been discussed and kind of raised every single board, um, prior to this year. So hopefully we're just getting the governance in place and obviously taking it to committee again. It's another sign of another eyes, another challenge on it just so, you know, we're not, it's, it's not a case of marking your own homework as officers. Sure. That makes sense. Yes, Christine. Yeah, I was just going to say, I think it's really important that we do review it, um, regularly because you never know what's going to happen with the economy or changes. Um, and if we are going to like, if we leave it for a year, it's, it's, it's too late. So I think the updates and things that you're providing is important that we do look at it regularly. Thank you, Christine. But yeah, that, that's where we're, we're kind of looking to try and get to is a bit, you know, best practice in relation to kind of having clear oversight. And like I said, that's, I'm kind of keen to kind of look at the exploring the external review of it, because I would like to make sure that we've kind of got everything that we feel covered, because then it's easier to kind of present these, these documents to, to your, um, so yeah, thank, thank you for that, Christine. Thanks, James. Any, any questions? Any other questions to James? Thank you. No, no, we can move on. So I see that the next item is about exclusion of present public. So I suggest we carry out the item 13 and then we can, uh, close the recording of this and then carry out that discussion separately. Yeah, that makes sense. Okay. So the next meeting is most likely on 18th February, which is, uh, Tuesday, um, any changes to that we'll, uh, circulate it. Okay. Thank you. And now for item 11. So this is the, uh, I just read this. So in accordance with section hundred a four of the local government act, the committee is asked to resolve that the present public be excluded from the meeting for specific items of business on the grounds that they may involve the likely disclosure of exempt information. Um, so this is relate in relation with the item 12, which is the employer update report. So if the board agrees that we can exclude the present public, that is we stop the recording, then we can move to that item. So can I ask the voting members to raise their hands to just say, or state it on, on audio. Thanks. Thanks. Philippa. And yeah, we have, okay. Two online.