The Pensions Fund Committee of West Northamptonshire Council met on Tuesday 9 December 2025 to discuss a range of important financial and governance matters relating to the Northamptonshire Pension Fund. Key decisions included the approval of the Northamptonshire Pension Fund Annual Report for the year ended 31 March 2025 and the Data Matching Policy.

Final Statement of Accounts 2024-2025

The Committee approved the Northamptonshire Pension Fund Annual Report for the year ended 31 March 2025. The report detailed the Fund's financial performance and position, including the final Statement of Accounts. External auditors Grant Thornton provided an unqualified opinion on the financial statements, noting that the work was substantially complete. Two key matters were identified during the audit: an overstatement of investment management expenses by £3.6 million, which was corrected, and a net misstatement of £9.8 million in Level 2 and 3 investments due to estimates used, which was also corrected. There were no recommendations for management from the Audit Findings Report, and a new process had been implemented to address a prior year recommendation regarding IT audit findings. The total audit fee for the year was £136,134.

Governance and Compliance Report

The Committee received an update on significant current issues impacting the governance, management, and administration of the Northamptonshire Pension Fund. Key points included ongoing consultations regarding the Local Government Pension Scheme (LGPS) in England and Wales, concerning councillor access to the scheme, academies, and new Fair Deal arrangements. The Pensions Dashboards Programme was progressing, with the Fund connected to the dashboard system in an embargoed state and scheduled for activation. The Scheme Advisory Board had published statements and legal advice on pooling governance and conflicts of interest. The Pensions Regulator (TPR) had launched a consultation on its new enforcement strategy. Updates were also provided on the Pension Schemes Bill and recent ministerial appointments. The report also detailed immaterial amendments made to policies and strategies following officer reviews.

Conflicts of Interest Policy

The Committee was asked to approve updates to the Northamptonshire Pension Fund Conflicts of Interest Policy. The proposed amendments aimed to align the policy with the General Code of Practice requirements on managing conflicts of interest, update wording related to the transition from the ACCESS asset pool to Border to Coast Pension Partnership (BCPP), and clarify procedures for declaring minor gifts and hospitality. The policy applies to Committee members, the Local Pension Board, the Section 151 Officer, and all advisers and suppliers to the Fund.

Pension Dashboards Update and Matching Policy

The Committee noted the progress made in connecting to the Pension Dashboard infrastructure by the deadline of 31 October 2025. The Fund had successfully connected to the infrastructure and uploaded scheme and membership data. User Acceptance Testing (UAT) of the Integrated Service Provider (ISP) was successfully undertaken. However, there was a delay in establishing dataflow for Additional Voluntary Contribution (AVC) data from Prudential, which was noted as an immaterial breach. The Fund's UK address tracing provider had also gone into liquidation, causing a delay in that area. The estimated costs for ISP implementation and maintenance were outlined.

Northamptonshire Pension Fund Committee Effectiveness Review

The Committee received the results of its effectiveness review, which indicated that the Committee is largely effective, with 86% of all responses showing agreement or strong agreement with the survey statements. The highest scoring area was Knowledge and Training (97%). The Equality, Diversity and Inclusion (EDI) section showed lower levels of agreement compared to other areas. Specific areas for improvement were identified, including enhancing collaboration between the Pension Committee and Pension Board, clarifying the Pension Board's role, and ensuring sufficient time for discussions within meetings. Proposed actions included establishing an escalation log, organising joint training events, and highlighting time management to the Chair. The report also noted that the Fund's approach to Responsible Investment and ESG factors was considered secondary to fiduciary duty by some members, and clarity was sought on the legal minimum requirements for climate reporting.

Administration Strategy Review

The Committee was asked to approve draft changes to the Administration Strategy. The strategy had been reviewed and updated to align with changes to the Fund's objectives, key performance indicators, and CIPFA guidance. Key risks were also updated to reflect the latest version of the risk register. New wording was included to clarify that the i-Connect system does not validate employer data, emphasising the importance of employers having their own quality assurance processes. A requirement was added for employers to pay AVCs promptly to the AVC provider to avoid loss of investment growth for members. The policy and escalation processes for data queries were also updated. The draft strategy would be subject to a 30-day consultation with scheme employers before final approval.

Administration Report

The Committee received an update on the administration performance of the Northamptonshire Pension Fund for the period 1 August to 30 September 2025. Overall performance against Key Performance Indicators (KPIs) was less than desired, with 18% rated Red. Additional staff had been reassigned to the Operations team to improve turnaround times for retirement and estimate casework. Employer contributions were received on time, maintaining a 100% annual compliance rate. No new material breaches or data breaches were reported. However, there were delays in issuing some annual benefit statements. The processing of undecided leaver records remained amber due to competing priorities, with support from Hymans Robertson to address the backlog. Two new employers were admitted to the Fund, and one ceased participation. Three new mitigations were added to the risk register, and two were updated.

Northamptonshire Pension Fund Committee Forward Agenda Plan

The Governance and Regulations Manager presented the Forward Agenda Plan. It was confirmed that outstanding items, including EDI policy submissions, the Climate Action Plan, and an active versus passive equity review, would be scheduled for future meetings. The Committee noted the Forward Agenda Plan.

The meeting also included private sessions to discuss exempt information relating to the valuation report, strategic asset allocation, and investment pool updates.