The Harrow Council Pension Board is scheduled to meet to discuss key updates and reviews, including a pensions administration update, a review of Pension Fund Committee items, and compliance with the Pensions Regulator (TPR) Code of Practice. The board, which is made up of employer and scheme member representatives, is expected to review these reports and provide feedback to the Pension Fund Committee.

TPR Code of Practice

The board is scheduled to scrutinise reports on the fund's compliance with the Pensions Regulator's (TPR) General Code of Practice (GCOP). The Pension Fund Committee has requested that the board review the appendices to the report, and provide feedback to the committee at a later date.

The General Code of Practice came into effect in March 2024, consolidating previous codes into a single code for all pension schemes. The code is divided into five sections and 14 chapters relevant to the Local Government Pension Scheme (LGPS), containing 37 modules and 135 requirements. According to the TPR Code of Practise Compliance Update, fund officers worked with consultants from Hyman Robertson's Governance team to assess the fund's compliance using their GCOP checker tool.

The report notes that the checker tool divides the checklist items into:

• regulatory requirement
• TPR expectation
• best practice

The Harrow GCOP Report - Final details the findings of the compliance review, and notes that Hymans Robertson supported officers in determining the level of compliance, but could not certify the self-assessment. The self-assessment found full compliance in the chapter relating to advisers and service providers, but identified areas of non-compliance in knowledge and understanding, risk management and scheme administration.

The TPR Code of Practise Compliance Update report lists actions that officers and members may need to take to achieve full compliance, including:

• Reviewing the terms of reference of the Pension Board and Pensions Committee
• Performing regular gap analysis of Pension Fund Committee skills and knowledge
• Updating the Pension Fund Training Policy
• Creating an induction pack for the Pension Board
• Specifying Pension Fund specific actions in the finance business continuity plan
• Adding conflict of interest to key risk register
• Considering adding administration risk to key risk register
• Developing a programme to review internal controls
• Developing a risk management policy to assist with the identification and classification of risks
• Changing the terms of reference of the Pension Fund Committee to include oversight of administration
• Ensuring compliance with the training policy
• Considering a formal RACI¹ matrix covering all decision making, to be included in the Investment Strategy
• Updating existing procedure notes for administration processes, information handling and contribution collection
• Reviewing the IDRP² policy and communications policy
• Creating procedures for completing scheme returns
• Updating the breaches policy and carry out training for committee and board

Review of Pension Fund Committee Items

The board is scheduled to review items considered by the Pension Fund Committee at its meeting on 17 November 2025. The Review of PF Committee Items report summarises these matters and invites the board to add comments they might wish to forward to the Pension Fund Committee.

The items include:

• A draft funding strategy statement
• An update on the London CIV³ and LGPS
• The pension fund key risk register
• Monthly fund valuations to 30 September 2025
• The Harrow PF Draft Responsible Investment Policy

Draft Funding Strategy Statement

The draft funding strategy statement is set out in appendix 1 of the Review of PF Committee Items report. The timetable for the remainder of the triennial valuation process is summarised as follows:

• Employer Forum – TBC January 2026
• Pension Fund Committee – 16 March 2026
• Final valuation report
• Approval of Funding Strategy Statement
• By 31 March 2026 (statutory deadline) – Final Report including Rates and Adjustments Certificate issued From 1 April 2026 onwards – new contribution rates payable by employers.

The funding strategy objectives are to:

• take a prudent long-term view to secure the regulatory requirement for long-term solvency, with sufficient funds to pay benefits to members and their dependants
• use a balanced investment strategy to minimise long-term cash contributions from employers and meet the regulatory requirement for long-term cost efficiency
• where appropriate, ensure stable employer contribution rates
• reflect different employers' characteristics to set their contribution rates, using a transparent funding strategy
• use reasonable measures to reduce the risk of an employer defaulting on its pension obligations
• use reasonable measures to manage exposure to environmental, social and governance risks, and their impact on long term employer funding
• the fund will engage with employers when developing funding strategy in a way which balances the risk appetite of stakeholders

LCIV and LGPS Update

The LCIV and LGPS Update report provides an update on the current position of the Fund's investments in context of the Government's requirements for pooling and on current developments within the London CIV and LGPS in general.

Fund officers are working with LCIV and other funds to establish an investment management agreement (IMA ) that will replace the old agreement between the Fund and LCIV. The new IMA is designed to effectively support transitioning off-pool assets to the pool, in line with the Government's target to have all assets pooled by March 2026.

Following a competitive selection process, London CIV has appointed Mercer to assist with the provision of Strategic Asset Allocation (SAA) advice. Mercer will offer a range of SAA tools to support the delivery of the Fit for the Future strategic plan.

At 30 September 2025, London Borough of Harrow had just under £606m (52.3%) of its investments in LCIV funds, and a further £371m (29.3%) in passive funds which are deemed pooled.

MHCLG have recently published another consultation which addresses access and fairness in the LGPS. In summary, the policy areas in this consultation are:

• Normal Minimum Pension Age – proposals to amend the Normal Minimum Pension Age to age 57, following the Finance Act 2022, and to ensure that members with a Protected Pension Age can still take pension benefits at that age except for members that have transferred benefits into the LGPS
• Mayors and councillors – proposals to extend access to the scheme for councillors and mayors in England
• Academies and applications for directions – proposals to put criteria for applications for directions into legislation, and to remove SoS consent where all criteria are met
• New Fair Deal – proposals to implement Fair Deal protections in the LGPS, aligning across government in ensuring continued access to the LGPS for outsourced workers.

Pension Fund Key Risk Register

The detailed risk register is attached as appendix 3 to the Review of PF Committee Items report. The register was noted by the committee.

Harrow PF Draft Responsible Investing Policy

The committee approved the policy with the request that consultants take it back and work on improving readability. The policy commits to the adoption of a net zero 2050 target and periodic review of climate metrics.

The Committee has sought advice on climate risk management and has committed to managing the Fund's assets in line with a net zero target by 2050 or sooner.

Monthly Fund Valuations to 30 September 2025

This report updated the Committee on the current position of the Fund's investments 30 September 2025.

In the quarter, the market value of investments increased by a net amount of by £46.9m to £1.16bn, with the Fund returning 4.3% net of fees. In the quarter, the Fund underperformed the benchmark by 0.9% net of fees.

Over a 12-month period to 30 September 2025, the Fund underperformed its benchmark net of fees by 3.2%, despite returning 8.4%. This underperformance can be largely attributed to the LCIV active equity funds.

Pensions Administration Update with Key Performances

The board is scheduled to receive an update on the administration performance of the fund over the quarter ending 30 September 2025.

The Pensions Administration Update with Key Performances report notes that for the quarter ending 30 September 2025, the Administration Team completed a total of 2,566 tasks. An average of 71% of all tasks were completed within the KPI⁴ target over this period.

By comparison, for the quarter previously reported to the board ending 30 June 2025, the Administration Team completed a total of 1,989 tasks with an average of 72% of all tasks completed within the KPI target over this period.

During this period there were no new complaints.

One Ombudsman letter was received during this quarter and is being progressed. A meeting with the Ombudsman to discuss it has been requested.

No new breaches occurred during the quarter.

The admin team have processed the responses to life certificate requests and have 413 remaining members who have not responded to either certificate request. The unresponsive pensioners will have their pension suspended from January 2026 onwards.

Work has started on procuring a new pensions admin system, as the current systems contract expires next year. Approval has been obtained from Cabinet and the National LGPS Framework will be used.