The agenda for the Pension Committee meeting included a business update on the Gloucestershire Pension Fund ¹, covering governance, operations, funding and investment. The committee was also scheduled to note the draft minutes of the Pension Board meeting held on 23 October 2025.

Gloucestershire Pension Fund Business Update

Matthew Trebilcock, Head of Pensions, was scheduled to present a report to update the committee on governance and operational matters since the last meeting. The report covered:

• Draft Pension Board minutes
• Audit Outcomes Report
• Consultations
• Pension Schemes Bill update
• Risk Register
• Data Improvement
• Key Performance Indicators
• Business Plan 2025/26

Consultations

The committee was scheduled to note updates on consultations relating to the Local Government Pension Scheme (LGPS). These included:

LGPS Scheme Improvements

The government has launched a consultation on a range of issues, following on from the Access and Fairness consultation covered in the September committee meeting. The consultation closes on 22 December 2025, and key areas include:

• Normal Minimum Pension Age (NMPA) - The consultation proposes how the increase to the NMPA to 57 from 6 April 2028 would be implemented in the LGPS. > If an LGPS member (active or deferred) was in the LGPS immediately before 4 November 2021, they would have a PPA and retain their right to take their pension from age 55 after 6 April 2028.
• LGPS access for councillors and mayors - The government is proposing that councillors and mayors in England should have access to the LGPS. > All English mayors and deputy mayors as well as councillors of principal English local authorities would have access to the LGPS. This will also apply to the Mayor of London and London Assembly Members.
• Academies - The government is proposing changes to the LGPS employer consolidation rules, driven by the growth in multi-academy trusts (MATs).
• New Fair Deal - The government is seeking to implement new Fair Deal in local government, and is consulting on regulations to achieve this. > Scheme members working for Fair Deal employers would retain a right to LGPS membership after being outsourced to a contractor under the new regulations.

LGPS: Fit for Future - Technical Consultation

A technical consultation relating to two draft statutory instruments relating to Fit for the Future reforms for the LGPS was scheduled to be discussed. The consultation has 29 questions on two new sets of draft regulations, with a 6-week deadline of 2 January 2026.

The draft regulations aim to put into place the Pooling and Local Investment chapters of the 'Fit for the Future' consultation. The key parts of which will be to:

• Require a Fund to participate in a pool, and only one pool.
• Require a Fund to delegate the implementation of their investment strategy to their asset pool and for pools to have the abilities to properly implement the investment strategies.
• Require Funds to take principal investment advice from their pool and that pools must have the ability to provide proper advice and include a list of what would constitute investment strategy.
• Set out requirements as to the contents of an investment strategy.
• Require that investment strategy reviews must be undertaken within 18 months of the actuarial valuation date.
• Require pools to take all reasonable steps to implement a fund's investment strategy.
• Require all assets to be controlled and managed by the relevant asset pool.
• Establish minimum standards for pools, including FCA authorisation and capacity to manage local investments.
• Require compliance from 1 April 2026, subject to passage of the Pension Schemes Bill through Parliament and with limited flexibility in specific cases

The regulations put into place the Governance chapter of the 'Fit for the Future' consultation. The key points are summarised below.

• Regulations will require a Fund to prepare and publish a governance strategy, a training strategy, and a conflict of interests policy.
• Regulation will require each Administering Authority to appoint a senior LGPS officer by 1 October 2026.
• Regulation will require each Fund to appoint an independent person as a non-voting member of their committee by 1 October 2026.
• Regulation will require that committee members and officers carrying out a delegated function must be conversant with the rules of the Scheme.
• Regulation will require a Fund to prepare an administration strategy which must be reviewed every three years.
• Regulation will require each Fund to undergo an independent governance review at its own cost.

Pension Schemes Bill

The Pension Schemes Bill is part of the UK government's broader pensions reform agenda, aiming to:

• Accelerate LGPS asset pooling
• Enhance governance
• Stimulate UK investment
• Improve member outcomes

The Bill is scheduled for a sitting on 3 December 2025 at report stage in the House of Commons.

Risk Register

Progress and activity in managing risks will continue to be monitored and recorded on a risk register and key information will be provided on a quarterly basis to the Pension Committee. The reporting information will include as a minimum:

• a summarised version of the risk register
• a summary of the main changes since the previous report
• the Fund's risk dashboard showing the score of all existing risks and any changes as part of that dashboard.

All risks have been reviewed, and the following risk remains above their risk target and will be tracked through the dashboard:

• Governance
  • Risk 1 remains above risk target. Recent knowledge assessment showed good progress but also highlights areas for further deployment of the training strategy/plan.
  • Risk 7 remains above risk target. Until a recommendation of a new pooling partner has been considered and access to the new pooling partner confirmed, the risk will remain elevated.
• Funding & Investment
  • Risk 17 – new risk identified and added and is above risk target. The risk is around the transitioning of assets to the new pool, the costs incurred with this and also the potential cost of exiting our Shareholding in Brunel.

Operations

Data Improvement

Following the introduction of a new Data Improvement Strategy and Plan in 2024, officers have reviewed the progress made against the 2024 actions, and drafted a new plan.

Key Performance Indicators

The key performance indicators (KPIs) are based on the targets as agreed by the Committee as part of its approval of the latest Administration Strategy.

Business Plan 2025/26

The key tasks contained in the business plan for Q3 2025/26 have all been completed.

Core projects tracking from 2025/26 business plan:

• Cyber Security Strategy Implementation - Activities have been delayed by a quarter.
• Pensions Dashboard - Completed – Fund is connected to the dashboard ahead of the 31 October 2025 deadline
• Employer Portal (i-Connect) - Operating to target – project has commenced, pilot employers in testing phase
• McCloud - Completed - Compliance by 31 August 2025 met in accordance with statutory requirements.
• The Pension Regulator – General Code of Practice - Activities have been delayed by a quarter.
• Actuarial Services Contract - Operating to target. Procurement process in commencement stage.

Gloucestershire Pension Fund - Funding and Investment

The committee was scheduled to receive an update on the Gloucestershire Pension Fund’s funding position, market value, asset allocation, investment performance, responsible investment activity and engagement activity since the previous committee meeting.

As the 2025 triennial valuation process is underway, the usual quarterly funding update will not be available during the remainder of this process. Normal funding level monitoring will recommence from 1 April 2026, once the new valuation assumptions are formally adopted.

Over the quarter to 30 September 2025, the Fund's total market value increased by £200.520m, to £3,928.604m. Over the previous 12 months, total Fund assets underperformed the strategic benchmark by 2.0%, with a return of 10.0%. Performance over the 3 years to 30 September 2025 was 10.30% annualised, which is slightly behind the strategic benchmark by 0.50%.

During the Quarter the following investment activity took place:

• During the quarter there has been a number of calls into the private markets (exc property) asset classes of:
  • Infrastructure - c£0.1m
  • Social & Affordable Housing - c£20.8m
  • Private Equity - c£2.9m
  • Private Debt - c£1.5m

At quarter ending 30 September 2025, the overall strategic allocations are outside target allocations, mainly due to the strong performance of equity markets.

Responsible Investment Update

The Fund is a member of The Local Authority Pension Fund Forum (LAPFF) ². The report contains a summary of LAPFF's engagement activities over the quarter, along with a company progress report detailing all engagements undertaken over the quarter, and the outcomes. In order to provide members with more in-depth analysis of the fund holdings within the specific portfolios, an analysis of the Equity holdings at whole Fund level held as at 30 September 2025 was scheduled to be provided.

Since the previous quarter the following have moved into the top 20 holdings:

• Prudential PLC - Life & Health Insurance - Hong Kong
• Broadcom Inc - Semiconductors - US

The following are now longer in the top 20 holdings, although exposure to them may remain in the portfolio:

• SAP SE - Application Software - Germany
• RELX PLC - Research & Consulting - UK

Faith Ward, Chief Responsible Investment Officer at Brunel, has received her MBE at Windsor Castle for services to pensions and the environment .

Independent Advisors Fund Report and Analysis

John Arthur has prepared a report, which he will deliver at the meeting, in his role as independent advisor to the Fund.

The report provides further detailed analysis on the overall performance of the Fund, the underlying managers and investment mandates held by the Fund and the Long-term Capital Market Assumptions used in establishing the SAA.