At a meeting of the Clwyd Pension Fund Committee on 10 September 2025, members reviewed the Audit Wales plan, discussed the draft annual report and accounts, and considered proposed changes to the Communications Strategy. The committee also agreed to delay the review of the Governance Policy and Compliance Statement.

Here's a more detailed look at the key discussion points:

Draft Clwyd Pension Fund Annual Report and Accounts 2024/25

The committee reviewed the draft Clwyd Pension Fund Annual Report and Accounts for 2024/25, which is required to be published before 1 December 2025. The report, which includes the Fund's draft Statement of Accounts, was written in accordance with guidance from the Scheme Advisory Board (SAB)¹, the Chartered Institute of Public Finance and Accountancy (CIPFA)² and the Ministry of Housing, Communities and Local Government (MHCLG). Key features of the annual report included information on:

• governance, including compliance against the Pension Regulator's new General Code of Practice³, succession planning, and cyber security strategy
• funding and investments, highlighting the fully funded position and focus on responsible and sustainable investments
• administration and communication, noting the implementation of the Communications Strategy and progress on regulatory changes like McCloud⁴ and the National Pensions Dashboard The committee was asked to provide comments on the draft report, with the audited annual report and accounts scheduled for approval at the November meeting.

Administration and Communications Update

The committee considered an update on administration and communication matters, including proposed amendments to the Communications Strategy. The report included:

• progress against administration and communications related matters in the Fund's 2025/26 Business Plan
• updates on the Fund's McCloud and National Pension Dashboard programmes
• monitoring against the Administration Strategy in relation to day-to-day tasks and key performance indicators
• results of this year's scheme member and employer surveys
• administration and communication risks on the Fund's risk register

The committee was asked to approve proposed amendments to the Communications Strategy.

Investment, Funding and Pooling Update

The committee received a summary update on funding and investment matters.

Audit Wales Audit Plan 2025

The committee reviewed and commented on the Audit Wales Audit Plan 2025.

Governance Update and Consultations

The committee was provided with an update on governance related matters and approved a delay in the review of the Governance Policy and Compliance Statement.

Project Snowdon

The committee discussed Project Snowdon, the Wales Pension Partnership's (WPP) plan to create a Wales Pension Partnership Investment Management Company (WPP IMCo). Councillor Alasdair Ibbotson and Mr Steve Hibbert expressed concerns about the draft recommendations, specifically regarding member representation, risk management, responsible investment, climate policy, and local investment in Wales. The committee agreed to recommend to Flintshire County Council that it approves the recommendations set out within the WPP joint report attached, with the stipulation that the delegation to the Deputy Section 151 Officer be replaced with the Head of Clwyd Pension Fund, and also to add a sixth recommendation that the Council does not consider the case proven for mandatory pooling.

Responsible Investment

The committee discussed the Fund's responsible investment policy, including the possibility of divesting from companies listed on the United Nations High Commission for Human Rights (OHCHR) database. Mr Hibbert raised concerns about focusing on a specific area of concern rather than the principles upon which the Fund should divest. Councillor Ibbotson expressed the view that members should be included in decision-making as much as possible, and a broad consultation with members should be taken. The committee agreed to seek legal advice on whether a de minimis level of disinvestment could be implemented without requiring consultation with members.