Vote reporting template for pension scheme implementation statement

ENSION SCHEME

IMPLEMENTATION

GUIDANCE

VOTE REPORTING TEMPLATE

FOR ASSET OWNERS

THE STANDARD RAISING

Vote reporting template for pension scheme implementation statement - Guidance for Trustees 
© 2020 Pensions and Lifetime Savings Association  2 
CONTENTS 
INTRODUCTION  3 
ABOUT THIS GUIDANCE  5 
QUICK START VS. DEEPER DIVES  5 
WHAT IS THE PLSA VOTE REPORTING TEMPLATE?  7 
WHAT DO TRUSTEES NEED TO DO BEFOREHAND?  8 
WHAT HAPPENS ONCE YOU GET THE COMPLETED TEMPLATE?  8 
THE STEPS TRUSTEES NEED TO TAKE  9 
HOW TO PRESENT THE DATA  16 
ANNEX 1 | VOTING TEMPLATES  18 
ANNEX 2 | REGULATORY BACKGROUND  23 
VOTING OPPORTUNITIES BEYOND LISTED EQUITIES – REGULATORY EXPECTATIONS  24 
ANNEX 3 | SEGREGATED OR INTERMEDIATED ARRANGEMENTS  25 
POOLED FUNDS  25 
SEGREGATED MANDATES  27 
FIDUCIARY MANAGEMENT  27 
ANNEX 4 | PLSA CRITERIA FOR “MOST SIGNIFICANT” VOTES  29 
ANNEX 5 | THE IMPORTANCE OF (STEWARDSHIP) CONFLICT IDENTIFICATION AND MANAGEMENT  31 
ANNEX 6 | FURTHER READING  32 
ACKNOWLEDGMENTS  33 
DISCLAIMER  34 
   
 
   

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

INTRODUCTION

Although good stewardship of assets extends beyond voting, the PLSA believes that effective use of

a vote to demonstrate support for, or to sanction, a company on its approach and behaviour is a

vital tool for investors.

Even where trustees have investments in pooled arrangements as opposed

to segregated mandates, there are still ways in which they can influence their managers on their

voting behaviour.

Recent changes to the law

mean trustees of both DB-only and DC/hybrid schemes are now

required to produce annual Implementation Statements describing how (and the extent to which)

their policies on exercising rights (including voting rights) and undertaking engagement in respect

of their investments have been followed during the year.

These disclosures will include describing

the voting behaviour by trustees themselves, as well as by those voting on their behalf (including

the most significant votes and the use of any proxy voting services).To produce this, trustees may

need voting information from their equity managers,

as well as managers who hold equities as

part of a multi-asset fund (or hold other assets with attached voting rights, such as some private

market assets). We clarify throughout this document key points and mechanisms for trustees’

engagement, influence and (where applicable) challenge of their managers on voting, across

different investment arrangements.

These new regulations require that trustees’ voting behaviour disclosures must relate back to their

own portfolio. However, asset managers are currently only required to produce a “general

description” of their voting and engagement behaviour – likely to happen at a firm-wide level

rather than at the mandate/fund-level which trustees need.

Trustees will also want the voting

information from their managers to be presented in a way which allows them to compare the

information when, for example, deciding which were the “most significant votes” were cast and

which aligns with their own stewardship policy.

This is why the PLSA has worked with its cross-industry Voting and Implementation Statement

Working Group (VISWG) and Stakeholder Group to produce a first version Vote Reporting

Template which asset managers are encouraged to fill in to provide this information to pension

scheme trustees.

We cover the role which effective exercise of a vote can play in ensuring effective scheme stewardship of assets in much greater depth in

our PLSA Stewardship Guide and Voting Guidelines 2020.

The PLSA has produced several guides outlining how trustees and scheme investment decision-makers can do this, including

Engaging the Engagers.

Please see the Occupational Pension Schemes (Investment and Disclosure) (Amendment) Regulations 2019.

Please see Annex 2 for a summary of the relevant regulatory background.

The trustees may cast votes themselves.

The relevant rules for asset managers are COBS 2.2B.7B and for platform providers SYSC 3.4.7B(2). In addition to a general

description of voting behaviour, an explanation of the most significant votes and reporting on the use of the services of proxy advisers,

firms must (subject to not disclosing votes which are insignificant) disclose how it has cast votes in the general meetings of companies

in which it holds shares. Please also see our Vote Reporting Template – Guidance for Asset Managers for further explanation around

the duties placed on asset managers under the Second Shareholder Rights Directive.

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

Asset managers providing more consistent reporting to their clients at a mandate/fund level will in

turn mean that:

 Trustees will be able to receive the information in the same format for every fund or mandate,

which will make it easier to disclose this in a consistent format

 Trustees will have information on voting which is more “decision-useful”

 Trustees will be able to better compare the service and approach provided by different

managers

 Trustees who are signatories to the UK Stewardship Code will be able to use these disclosures to

help meet their reporting requirements.

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

ABOUT THIS GUIDANCE

This guidance sets out:

 An overview of the Vote Reporting Template

 Where the Template ‘fits in’ as part of the trustees’ broader work to scrutinise their managers’

voting behaviour undertaken on their behalf

 The steps trustees need to take before presenting the Template to managers

 What information trustees will get from the Template

 How to use this information.

It is designed to be used alongside our PLSA Implementation Statement Guidance, which includes

a specific chapter on how to produce clear, effective and meaningful disclosures on voting

behaviour in the Implementation Statement; this is the ‘next step’ which trustees need to take after

reading this guidance and gathering the relevant information.

The PLSA has produced similar guidance for asset managers on how to fill out the Template

, and

this may also be worthwhile for trustees and their advisers to read.

Although the primary purpose of following the guidance should be to ensure voting behaviour is

consistent with the trustees’ investment objectives, we note that any significant decisions which are

taken by trustees using the structure below could also be used in any descriptions of trustees’

voting behaviour in their Implementation Statements.

Please note: we have tested this template with asset managers and recognise that it will need to

evolve as the market develops. Some managers’ systems and processes will require changes to be

able to provide the information required for trustees to make their own regulatory disclosures,

particularly in relation to the “most significant” votes on trustees’ behalf.

However: we think it remains worthwhile even at this stage to produce something ‘ready-made’ for

trustees to ask their managers to fill out. As we make clear later in the guide, the Template is just

one piece in the puzzle and we encourage trustees to consider how to use it as part of an overall

strategy of seeking to engage with, influence and – where necessary – challenge their managers on

their voting decisions and approach.

QUICK START VS. DEEPER DIVES

The main part of the document is designed to be a ‘quick start’ guide for trustees in facilitating the

use of the Template with their asset managers.

Please see Vote Reporting Template – Guidance for Asset Managers

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

 We strongly recommend that trustees also read the Annexes as these do ‘deeper dives’ into

issues such as:

 Regulatory background

 The detail of the Template

 Voting disclosures for non-listed equities

 The importance of (managing) voting conflicts

Although we anticipate that the Vote Reporting Template will evolve over time – this is just the

‘first version’ and the PLSA will consider how to build on this in future. We hope that this will

provide a good starting point and additional tool in the dialogue between trustees and their

managers on the voting behaviour and how they can work together to ensure effective scheme

stewardship.

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

WHAT IS THE PLSA VOTE REPORTING TEMPLATE?

The Template is also not intended to be merely a one-way communication flow from fund manager

to clients. Instead, trustees should use it to facilitate scrutiny and to create a more efficient and

robust dialogue between trustees and their managers and advisers.

The Template takes the form of an Excel spreadsheet and asks managers (or platform providers) to

fill in information about voting behaviour either at the fund- or mandate-level, depending on

whether they are filling in the information from a pooled fund or segregated mandate perspective.

This information should then be provided to the trustees and/or their advisers who will be able to

help trustees assess and review the information, before deciding how they should disclose the data.

All implementation statements must contain a description of the voting behaviour by, or on behalf

of, trustees (including the most significant votes cast). In many cases, for example where trustees

invest through pooled funds or via fund platforms, the voting rights might be held by the fund

rather than the trustee. However, such votes are still cast by the manager of the fund “on behalf of”

the fund’s investors in a broader sense and the policy intent is therefore that such voting behaviour

should be covered by the implementation statement. Trustees should assume that any regulatory

approach will follow this principle.

Where investments are held through multiple layers (for example where trustees invest in funds of

funds) it is reasonable for trustees to expect that managers operating such fund of funds are able to

report on ultimate votes cast by underlying managers, as part of their own engagement activities

and trustees should seek this information from their manager(s) for inclusion in their

implementation statement.

There are two elements for managers to fill out. A summary of all the manager’s voting behaviour

at the fund- or mandate-level and information on each of the 10 (at a minimum) “Most Significant

Votes” – which will have been decided by the manager with reference to PLSA criteria

(and any

voting policies or issues highlighted by the trustees).

The templates are included in Annex 1. Some of the questions asked are as follows:

 Details around voting policies: e.g. description of the voting process, use of any proxy voting

services

 Quantitative information for the fund or mandate: e.g., number of meetings eligible to vote at,

number of votes cast in total, number of votes cast for/against/abstained, whether the manager

voted contrary to the recommendation of any proxy advisor for each fund

 Details of the “most significant” votes cast for each fund (including rationale for the vote and

outcome of the vote)

 Information on how the manager has managed and mitigated any stewardship conflicts.

Please see Annex 4 for these criteria.

The PLSA has included conflicts in our templates because we are aware that currently there is variable level and quality of disclosure on

conflicts from managers. Although managers will have a firm-wide approach to conflicts generally, there will be a specific range of

stewardship-relevant conflicts which managers are asked to disclose. We explore this further on p 26.

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

WHAT DO TRUSTEES NEED TO DO BEFOREHAND?

Trustees need information from their managers to produce compliant – but also meaningful and

relevant – voting behaviour disclosures in their Implementation Statements.

Although our Template is designed to make life easier for trustees in gathering relevant voting

behaviour information, filtering out any voting ‘noise’, comparing (and influencing) asset manager

approaches and producing disclosures which are meaningful and relevant, it is not designed to be

used in isolation.

The PLSA has recently produced practical guidance for trustees on how to produce their

Implementation Statement, which includes a specific section on how – and what – to disclose on

voting behaviour over the course of the year. We strongly encourage trustees to read this chapter

first. Once this has been read, we think that the trustees should take the following steps in the run

up to giving the template to their asset managers (further details below):

1. Ascertain which funds/mandates have voting opportunities

2. Understand their investment arrangements – and how this could influence voting

3. Agree the process for maximising influence

4. Communicate expectations to managers/platform providers

5. Ask managers to complete the Vote Reporting Template

After giving their template to asset managers, trustees should take the following steps to work with

them to confirm and validate the collection of the information.

6. Assess and discuss any gaps in the information

7. Consider validation or assurance of data

8. Interpret the data

Managers will not necessarily be aware of their clients’ scheme year end dates, when clients will

first ask them to disclose this information or, in some cases if invested via a platform, which clients

hold which fund. As such, the sooner trustees start the process, the better.

WHAT HAPPENS ONCE YOU GET THE COMPLETED TEMPLATE?

Trustees should have already agreed timescales for reporting this information and they should also

have a good idea of what information they will be able to expect from their managers.

If trustees are not able to get the relevant voting information from their managers or other service

providers, they should include as much detail as they can in their Implementation Statement in

these circumstances. Trustees should also explain what information is missing, why the

information is missing and how they intend to rectify the situation.

See PLSA Implementation Statement Guidance (July 2020). We understand that the Regulator’s response to any breaches of the

legislation will depend on the particular facts of a specific case – and that it will adopt a reasonable approach in relation to any

enforcement. TPR’s power to fine for such a breach will arise in circumstances where “there is no reasonable excuse”.

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

THE STEPS TRUSTEES NEED TO TAKE

After reading the PLSA Implementation Statement Guidance and agreeing the trustees’ approach

generally to implementation statements, trustees should:

1. Ascertain which funds/mandates have voting opportunities

The majority of voting activity will take place across listed equity, including listed equities held in

multi-asset funds, but this is not the only asset class where voting opportunities may arise. Certain

bonds, property and private equity may also have carried voting opportunities over the course of

the year. Because in many cases these voting rights are triggered by a crisis or unusual

circumstances, these votes may be of particular importance to value preservation.

2. Understand their investment arrangements – and how this impacts voting

influence

Trustees will have different mechanisms for holding managers to account on voting depending on

whether they hold assets in pooled or segregated arrangements, either directly or via a platform

provider. They should discuss with their advisers and lawyers the precise nature of their

investment arrangements, but we can generally say the following:

 Pooled funds: voting entitlements (where they arise) generally – although not exclusively – lie

with the asset manager, as the legal owner of the securities in the fund.

 Platform provider: trustees’ direct legal relationship is with the platform provider and not with

the underlying managers themselves. The platform provider may retain the voting rights or, on

occasion delegate them to the managers.

 Custodian arrangements: these may also have an impact depending on whether the underlying

investments are held by a global custodian in a separate designation for the investment

manager, or whether they are held in an ‘omnibus’ structure, mixed in with the assets of many

other investors.

Trustees should ensure that they work with their advisers and managers to clarify roles,

responsibilities and timescales for reporting.

Please also see Annex 3 for further details on some of the differences of approach required for

schemes with investments in segregated mandates and those invested in more intermediated

arrangements.

3. Agree the process for maximising influence

Trustees are responsible for scheme investment decisions – and this includes the voting activities

undertaken by the managers they appoint. Schemes with segregated arrangements will have the

most opportunity to direct voting behaviour. However, trustees are not expected to take an in-

depth and specific decision on how to vote on every resolution at every company in which they have

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

a holding – and if the scheme’s assets are invested in pooled arrangements or on a platform, they

may not have the power to direct how individual votes are exercised.

Nonetheless, trustees

invested in pooled arrangements still have avenues for engaging with and influencing their asset

managers’ approach to voting – even if their governance budget is limited.

As with any other investment issues, trustees should clearly articulate their expectations on voting

behaviour (and stewardship generally) to their asset managers and advisers. They should also think

about how they will hold their managers and advisers to account. To do so, we would urge trustees

to consider the following to help them maximise their influence over manager voting behaviour:

Build a voting policy

 Producing a voting policy

does not have to be a time- or resource- intensive exercise, and it

can be helpful not only in providing a benchmark for measuring manager behaviour, but also as

a ready-to-use tool for making trustees’ expectations clear to both prospective and current

managers.

 The least resource-intensive way of doing so is to adopt, or build upon, generic Voting

Guidelines which are already available. This includes the PLSA’s Stewardship Guidance and

Voting Guidelines which are updated in Q1 each year and provide detailed guidance on how

trustees (and their managers) should consider voting on specific issues and resolutions.

 Trustees could also consider producing their own voting policy by working with their advisers,

to consider what issues, companies, themes or geographies are most material for their fund –

including explicit linkages to investment objectives and stewardship beliefs – and what this

means for both their own voting disclosures and their expectations of their managers.

 Trustees may also want to consider how this aligns with new requirements to disclose asset

manager arrangement policies in their Statement of Investment Principles (SIP) – this can be a

useful additional tool in setting out trustees’ voting expectations with managers and to assist

with the governance framework for producing the implementation statement.

Set/revise objectives for investment consultants

 Given the key role that investment advisers play in strategic asset allocation, manager selection

and the request and evaluation of information from asset managers, it is important that trustees

have an appropriate benchmark against which to measure their consultants on supporting the

trustee board on stewardship (including voting) activity.

Although we know of several managers who do allow client-directed voting in their pooled funds. We have long encouraged trustees in

their manager selection process to ask whether the manager allows for this (for relevant mandates) and if not, what their approach to

voting in pooled funds or discussion with clients is.

Please see the PLSA’s 2020 Stewardship Guidance and Voting Guidelines for much more detailed guidance on how to build a

meaningful voting policy, and how it should fit in with the trustees’ approach to stewardship and engagement, as well as with trustees’

investment objectives.

We also encourage trustees to explore the AMNT’s Red Line Voting Initiative.

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

 The CMA’s

recent requirement for trustees to agree objectives for their investment consultants

provide a useful additional tool. Trustees should incorporate specific consultant objectives

around stewardship (and voting) and review them periodically.

Agree principles around “most significant” votes

 A key disclosure that trustees will have to make is on the “most significant” votes which have

been cast on their behalf. Asset managers are currently debating what constitutes a “most

significant” vote from their perspective but the votes that managers would select if asked to

report on a “most significant” vote may not be the ones that trustees want disclosed to them.

Trustees should therefore:

 Agree with their advisers some high-level principles around what constitutes “most

significant” (this will likely be heavily influenced by the trustees’ voting policy, where

available). Please also see Annex 4 for details of the PLSA’s suggested criteria

for “most

significant” votes.

 Document the rationale for their approach and the criteria used

 Assess both their managers’ voting behaviour (and rationale) and their vote reporting,

including where they have not reported against the scheme’s “most significant” votes or

criteria.

Incorporate into manager selection

 The appointment process for a new manager is a vital opportunity for trustees to evaluate

whether the manager’s voting policy (where relevant) aligns with their own, and to set

requirements around voting disclosure.

 The due diligence process – from Request For Proposals (where used) to manager visits and

discussions – should include questions around:

 the approach to client-directed voting, or discussions with clients, in pooled funds

 their approach to stock lending or recalling stock before a vote

 their approach to management of stewardship conflicts

 case studies of successful voting (and engagement)

 approach across assets and geographies

and much more which is beyond the scope of this guidance but is explored in depth in other

PLSA guides.

We also encourage trustees to consider whether and how they can state their expectations

regarding voting (and stewardship) across the contractual relationship with the manager

Please also see TPR’s draft guidance for trustees on setting objectives for their investment consultants.

Please see Annex 4 for possible criteria for schemes to use when thinking about their own definition of “most significant”. The PLSA is

also considering whether there is value upon building on its annual Voting Guidelines by highlighting each year what we consider to be

the most important votes taking place during the next AGM season.

Engaging the Engagers, Stewardship guide and voting guidelines, PLSA Implementation Statement guidance.

We encourage trustees to consider the ICGN’s Model Mandate work (written in 2012 but being reviewed in 2020) and the IA’s work on

Productivity Mandates (ongoing).

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

During manager monitoring and review

 It is harder to backfill new expectations into an existing asset manager relationship. The first

step could be to share the voting policy, views on “most significant votes” and other

expectations with existing managers, then discussing how they fit with the manager’s own

existing policy.

 This should lead to a clear understanding of what the manager should deliver, in terms of

substance and reporting, and over what time period.

 We do not expect that an agreement with a manager might be automatically terminated solely

on the basis of a disappointing voting policy or reporting approach, but this would be a

reasonable decision for trustees to take – given the growing body of evidence of the materiality

of stewardship to investment outcomes.

4. Communicate expectations to managers/platform providers

Manager selection and formal (or informal) manager review opportunities are excellent

opportunities for influencing managers and communicating trustees’ expectations. The

requirement for trustees to produce their Implementation Statements will present another avenue

for discussion and communication. Once trustees have progressed through the steps above (with

advisers, where relevant) they should begin the conversation with their managers.

We recognise that trustees in segregated mandates will have scope for greater influence than those

in pooled or intermediated arrangements. However, we are aware that some schemes invested in

pooled funds have successfully influenced manager behaviour on voting and engagement simply by

‘asking the question’ and then challenging their managers accordingly and consistently (instead of

raising as a ‘one-off’ with no follow-up or agreed timetable for review and discussion).

5. Ask managers to complete the vote reporting template

Trustees will get the most value out of the Template if all of their asset managers use it to report the

information, as it will allow for easier comparison of voting approaches and behaviour.

Trustees should, as with any other investment issue, be clear about why and how they need this

information presented at a fund- or mandate-level and their own legal responsibilities. However,

we also acknowledge that most managers will need to overhaul their systems and processes to get

this information to trustees in the right format – which will take time. Trustees should balance

their responsibility to act as a demanding client while allowing managers some flexibility and space

to adapt – at least in the first year.

Trustees should also ensure that they give their managers any additional information that they will

need to complete the template. This includes the trustees’ SIP, any standalone voting, stewardship

or engagement documents, as well as any required information about the value of trustees’ assets

in the strategy or fund at the relevant period end (if this information is not already held by the

manager).

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

Trustees should have already agreed timescales for reporting this information and they should also

have a good idea of what information they will be able to expect from their managers.

If trustees are not able to get the relevant voting information from their managers or other service

providers, they should include as much detail as they can in their Implementation Statement in

these circumstances. Trustees should also explain what information is missing, why the

information is missing and how they intend to rectify the situation

Once trustees have received the completed Templates, they should consider taking the following

steps:

6. Assess and discuss any gaps in information

It will be important for trustees and their advisers to quickly gauge what information is missing

(this will be particularly key in the first year) and discuss any gaps with their managers. Bearing in

mind the regulatory requirements and expectations of trustees, they should engage further and

challenge where necessary.

7. Consider validation or assurance of data

This could be through reviewing the responses in the Template with the trustees’ usual or specialist

advisers, or schemes with significant resources could consider third party data sources against

which to check the data given. There are points which trustees should particularly consider:

 Standard data checks such as checking that: all of the information requested has been provided;

the data has been provided on the correct fund as some managers have very similar funds; the

number of AGMs is consistent with the number of holdings; the dates of the votes are

applicable to your scheme year.

8. Interpret the data

Although using our Vote Reporting Template – and setting clear expectations on managers from

the outset – will reduce much of the burden of sifting through overwhelming amounts of

information by trustees, trustees will still need to work with their advisers to assess and interpret

the data given. A non-exhaustive list of issues trustees should consider includes:

 The proportion of votes exercised. Although there may be technical and practical reasons

why managers are unable to exercise all votes, particularly in some jurisdictions, it is typical for

We discuss this further in our PLSA Implementation Statement Guidance (July 2020) but we understand that the Regulator’s

response to any breaches of the implementation statement legislation will depend on the particular facts of a specific case – and that

they will adopt a reasonable approach in relation to any enforcement. TPR’s power to fine for such a breach will arise in circumstances

where “there is no reasonable excuse”.

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

over 95% of votes to be exercised. Trustees should probe the reasons if voting levels fall short of

expectations

 The proportion of votes against management. Although it is tempting to think “voting

against management = good”, “voting for management = bad”, the reality may be more

nuanced. For instance, active managers may be more inclined towards supporting a company

overseen by a board and management that they have actively chosen to invest in and may

believe that they can be more effective through dialogue than through the binary mechanism of

a vote. In most passive mandates, however, managers cannot make an active decision to divest.

Where managers have low proportions of votes against management, trustees should enquire

more closely on voting behaviour. This may include looking beyond asset managers’ chosen

case studies to press on the rationale for voting decisions on trustees’ own significant votes.

 The proportion of votes contrary to the recommendation of proxy voting advisory

services. Asset managers may use a range of research services to inform their assessment

process but should ultimately use their own judgement based on their knowledge of the

company, engagement process and the outcomes they are seeking to achieve on clients’ behalf.

For example, voting contrary to the advice of a proxy advisory service may well be a sign of good

process and intelligent thought applied to the vote decision that is tailored to a company’s

individual circumstances. However, trustees may be wary of situations where the vote contrary

to advice coincides with a conflict of interest faced by the fund manager.

 The manager has not engaged or communicated with the company before voting

against management. Voting decisions should be made in the context of a managers’

ongoing communication with the company and after consideration of any progress made. To

use voting as an effective route to influence will likely require some form of engagement or

communication from the manager.

A vote ‘in isolation’ without any rationale given to the

company beforehand will be unlikely to change minds or behaviour.

 Information on conflicts. The quality and level of information and transparency around

managers’ approach to, and management of, stewardship conflicts varies widely. Trustees will

naturally be alive to the impact and implications of conflicts of interest from their own

experience of scheme governance and will therefore understand the serious impediment that

poorly-managed conflicts pose to managers’ ability to act in the best interests of their clients.

Trustees should scrutinise both the information given – including that it pertains to

stewardship specifically,

and is not just the firm’s overall conflicts management policy – and

the responsiveness of the manager in providing it.

There are a number of different ways in which engagement, either individual or collaborative, can take place. We cover this in much

greater detail in the joint PLSA/Investor Forum Guidance Engaging the Engagers: A practical toolkit for achieving good stewardship

outcomes through your asset managers (June 2020).

A stewardship-related policy on conflicts will be different from a firm’s broader conflicts policy as conflicts may arise in additional

forms for a manager’s engagement and voting activities.

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

 Approach to stock-lending. When securities are lent, the manager loses the voting rights

attached. Given that much lending occurs around the time of AGMs (for dividend-related

reasons) this can mean managers lose voting influence. Some managers recall all stock in order

to vote, some ensure that they always retain a proportion of their holding so that they can

express their views through voting, while others will recall only on an ad hoc basis where they

deem the vote particularly important. Managers should be expected to have a considered

process for recalling stock lent and be transparent about their approach.

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

HOW TO PRESENT THE DATA

If not already done so, we strongly encourage trustees to read the PLSA Implementation Statement

Guidance (and particularly Chapter 5 on Voting Disclosures in the Implementation Statement).

This covers exactly what trustees should disclose, as well as what they could disclose.

Additional points to consider in terms of presentation of information from the Vote Reporting

Template:

 Combining voting statistics from different mandates, which may have very different numbers or

value of holdings, or be managed by firms with different voting practices, may not be

meaningful. Schemes may therefore wish to present data separately for each mandate.

 When looking across the “most significant votes” from all your asset managers and thinking

about which to prioritise, you may wish to refer back to:

 The SIP, including your investment objectives and voting policies

 Any separate policies on voting, stewardship or engagement policy

 Documented criteria for “most significant votes”

 Any survey of member views which indicates topics of particular concern

 The relative size of scheme holdings in the companies involved – taking account of the

size of the mandates and the companies’ weights within them

 Think about what may be most important to disclose in your first Implementation Statement,

and then how it might evolve with more information over time

 For trustees with significant resource: you may find that you hold a company in more than one

mandate; where you receive a vote for that company reported as “most significant” for one

mandate and not under the others, you may think about whether there needs to be a direct

comparative process: asking Manager A whether how they voted on the resolutions that

Manager B considered significant, and vice versa.

 The impact of comparative analysis on key areas of scheme or regulatory focus, such as

managing climate risk, is likely to be particularly beneficial.

https://www.thepensionsregulator.gov.uk/en/trustees/managing-dc-benefits/investment-guide-for-dc-pension-schemes-

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

ANNEX 1 | VOTING TEMPLATES

VOTING QUESTIONNAIRE

RESPONSE

POINTS TO CONSIDER WHEN RESPONDING

Scheme Name

To be completed by the trustees

Employer name

To be completed by the trustees

Investment Manager name

To be completed by the trustees

Fund name

To be completed trustees and should not be changed by the

manager

Amended Fund Name (if different to the above)

To be completed by managers if they have a different name to the

above fund name

Scheme year end date

To be completed by the trustees

Start of Reporting Period

To be completed by the trustees. This is normally the start of the

scheme year, or the inception date in the Fund / mandate if later.

End of Reporting Period

To be completed by the trustees. This is normally the end of the

scheme year, or entire redemption date from the Fund / mandate if

earlier.

The following sections should be completed at the fund/mandate (if segregated) level

FUND/MANDATE INFORMATION

RESPONSE

ADDITIONAL COMMENTS

What is the Fund's Legal Entity Identifier (LEI) (if applicable)

What is the Fund's International Securities Identification Number (ISIN) (if

applicable)

What was the total size of the fund/mandate as at the end of the Reporting

Period?

Total size of Scheme assets invested in the fund/mandate as at the end of the

Reporting Period (if known)?

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

FUND/MANDATE INFORMATION

RESPONSE

ADDITIONAL COMMENTS

What was the number of equity holdings in the fund/mandate as at the end of

the Reporting period?

VOTING POLICIES

RESPONSE

ADDITIONAL COMMENTS

What is your policy on consulting with clients before voting?

Please provide an overview of your process for deciding how to vote.

How, if at all, have you made use of proxy voting services?

What process did you follow for determining the “most significant” votes?

Did any of your “most significant” votes breach the client’s voting policy (where relevant)?

[Y/N]

If ‘Y’ to the above. Please explain where this happened and the rationale for the action taken.

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

VOTING POLICIES

RESPONSE

ADDITIONAL COMMENTS

Are you currently affected by any of the following five conflicts, or any other conflicts, across any of your

holdings?

1) The asset management firm overall has an apparent client-relationship conflict e.g. the manager provides

significant products or services to a company in which they also have an equity or bond holding;

2) Senior staff at the asset management firm hold roles (e.g. as a member of the Board) at a company in which

the asset management firm has equity or bond holdings

3) The asset management firm’s stewardship staff have a personal relationship with relevant individuals (e.g. on

the Board or the company secretariat) at a company in which the firm has an equity or bond holding

4) There is a situation where the interests of different clients diverge. An example of this could be a takeover,

where one set of clients is exposed to the target and another set is exposed to the acquirer

5) There are differences between the stewardship policies of managers and their clients

Please include here any additional comments which you believe are relevant to your voting activities or processes

VOTING STATISTICS (APPLICABLE TO THE SCHEME'S REPORTING PERIOD)

RESPONSE

ADDITIONAL COMMENTS

POINTS TO CONSIDER WHEN

RESPONDING

How many meetings were you eligible to vote at?

How many resolutions were you eligible to vote on?

What % of resolutions did you vote on for which you were eligible?

Of the resolutions on which you voted, what % did you vote with management?

Of the resolutions on which you voted, what % did you vote against

management?

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

Of the resolutions on which you voted, what % did you abstain from voting?

The totals of these 3 questions

should add up to 100%.

In what % of meetings, for which you did vote, did you vote at least once

against management?

Which proxy advisory services does your firm use, and do you use their

standard voting policy or created your own bespoke policy which they then

implemented on your behalf?

What % of resolutions, on which you did vote, did you vote contrary to the

recommendation of your proxy adviser? (if applicable)

Most Significant Votes

IN RELATION TO THE FUND NAMED ABOVE, WHICH 10 VOTES

(AT A MINIMUM) DURING THE REPORTING PERIOD DO YOU

CONSIDER TO BE MOST SIGNIFICANT FOR THE SCHEME?

VOTE 1

VOTE 2

VOTE 3

VOTE 4

VOTE 5

VOTE 6

VOTE 7

VOTE 8

VOTE 9

VOTE 10

Company name

Date of vote

Approximate size of fund's/mandate's holding as at the

date of the vote (as % of portfolio)

Summary of the resolution

How you voted

Where you voted against management, did you

communicate your intent to the company ahead of the

vote?

Rationale for the voting decision

Outcome of the vote

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

IN RELATION TO THE FUND NAMED ABOVE, WHICH 10 VOTES

(AT A MINIMUM) DURING THE REPORTING PERIOD DO YOU

CONSIDER TO BE MOST SIGNIFICANT FOR THE SCHEME?

VOTE 1

VOTE 2

VOTE 3

VOTE 4

VOTE 5

VOTE 6

VOTE 7

VOTE 8

VOTE 9

VOTE 10

Implications of the outcome eg were there any lessons

learned and what likely future steps will you take in

response to the outcome?

On which criteria have you assessed this vote to be

"most significant"?

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

ANNEX 2 | REGULATORY BACKGROUND

The 2019 changes to the Occupational Pension Schemes (Investment) Regulations 2005 and the

Occupational and Personal Pension Schemes (Disclosure of Information) Regulations 2013

set

out new disclosure requirements for private sector scheme trustees in relation to their investment

strategy, approach to stewardship and arrangements between asset owners and asset managers.

They are:

 Policy regarding asset manager arrangements. By 1 October 2020, trustees will be

required to have a policy on the arrangements that they have with their asset managers and

include this in their SIP. These policies must cover how the arrangements in place facilitate

alignment between the managers’ actions and the trustees’ investment approach in relation to,

amongst other things: investment strategy, decision-making, issuer engagement, performance

evaluation and remuneration. They must also explain how the manager is incentivised to make

decisions that focus on medium-to-long term performance, set out the duration of the

arrangement and explain how the trustees monitor portfolio turnover costs. Trustees may need

input from advisers and managers to help formulate and further these policies.

 Report on manager voting and engagement activities. From 1 October 2020, pension

scheme trustees will have to include a statement in their annual report and accounts and on

their website which demonstrates how their policies on exercising rights (including voting

rights) and undertaking engagement activities have been followed during the year.

They will

also have to describe the voting behaviour by them, or on their behalf, during the year

(including the most significant votes cast by trustees or on their behalf) and state any use of the

services of a proxy voter during that year.

 The references to a year are in respect of the “scheme year” applicable to the pension

scheme in question.

 As a result, trustees will need information on the votes cast on their behalf at least annually

to comply with their statutory requirements (and their fiduciary duty).

 Review of voting information by managers should become a key feature of trustees’

monitoring activities. In our view, trustees should take a keen interest in voting and

engagement policies when going through a manager selection exercise, as well as in the

monitoring and review of their managers.

Please see: Occupational Pension Schemes (Investment and Disclosure) (Amendment) Regulations 2019

Managers have their own new reporting duties under the FCA’s equivalent transposition of the EU’s Second Shareholder Rights

Directive (SRD II). Further details can be found in our Vote Reporting Template – Guidance for Asset Managers.

The regulations have additional reporting and disclosure requirements for DC and Hybrid schemes which trustees should observe.

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

VOTING OPPORTUNITIES BEYOND LISTED EQUITIES – REGULATORY EXPECTATIONS

Multi-asset funds

The legislation above applies to any voting rights. As such, trustees are also required to report on

votes cast on the applicable underlying holdings within multi-asset funds.

Beyond listed equities

The legislation above does not make any distinction between public and private assets when it

comes to the requirement to disclose voting behaviour, and neither does the legislation requiring

disclosure of voting policies. There may also be instances for some asset classes

beyond

traditional private equity where significant votes can arise in relation to these holdings as well.

By its very nature, voting in relation to private market assets tends to occur when the votes are

significant.

As such, non-listed equity managers should be able to provide a narrative

commentary – at a minimum – to trustees where there were significant engagement activities over

the year and to set out any instances where significant votes were cast.

Examples of some of these asset classes are: fixed income (public and private), property, renewables, distressed debt, infrastructure.

For instance: private equity – the manager is a co-owner and there is a vote to sell an asset, or whether to refinance or sell component

parts of the business; property – votes on rental deferrals or concessions; conversion rights or debt options in the event of default for

infrastructure or renewables.

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

ANNEX 3 | SEGREGATED OR INTERMEDIATED ARRANGEMENTS

The UK investment chain is highly intermediated but the PLSA does not believe that the level of

information required by trustees on how votes are exercised on their behalf should change

significantly depending on the degree of intermediation.

Trustees should make sure they work with their legal and investment advisers, as well as their

managers, to understand precisely who ‘owns’ the vote, who in the governance structure is legally

responsible for making the voting decision, and how they should maximise their influence over the

voting policies and the decisions made on their behalf.

The following is a non-exhaustive list of some possible considerations for trustees with different

investment arrangements to consider.

Trustees should be aware that asset managers will likely be providing voting data in a new and

different way as a result of the new regulations and this will initially pose challenges for them.

However, should trustees feel that their managers are failing to take what would be considered

reasonable steps to providing them with relevant data, they should take this into account in their

review and retention decisions.

POOLED FUNDS

It is estimated that around 39% of private sector UK scheme assets – and the majority of DC assets

– are invested in pooled arrangements,

primarily through an entity-pooling approach, such as a

collective investment scheme. This pool of assets has a separate legal personality of its own and

therefore while a participating investor may retain the beneficial ownership, they do not own the

legal entitlement to the underlying portfolio of securities. The trustees’ rights will typically pertain

only to owning units in the pool.

This currently makes the ability to exercise influence over how a vote is cast on a particular issue

more complicated. However, it is a common misperception that trustees therefore cannot exercise

any influence over the general voting approach of their managers. There are a couple of key issues

– and opportunities for exercising influence, perhaps the most important of which is during the

manager selection or any formal review process – which we would encourage trustees to consider

below.

The PLSA considers it good practice for managers to have a process for considering their clients’

views in their voting policy and behaviour. This approach is supported by the FRC’s Stewardship

Code, Principle 6, which requires signatories to explain how they have sought and received clients’

views and the reason for their chosen approach, as well as how assets have been managed in

alignment with clients’ stewardship and investment policies.

https://www.ons.gov.uk/economy/investmentspensionsandtrusts/articles/ukpensionsurveys/redevelopmentand2019results

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

 Some managers allow client-directed voting in their pooled funds. During the manager

selection process, trustees should ask managers whether they offer client-directed voting in

their pooled funds.

 Some managers have formal (or informal) discussions with clients around their voting and

engagement approach. We would expect trustees to consider in a manager selection process

whether the potential manager’s formal voting and engagement policies, and their broader

approach, align with their own. They should ask whether the manager has a process or

framework for seeking their clients’ views on voting and engagement, and how often – and if

not, why not, and how they intend to meet the requirements of the Stewardship Code. More

generally, trustees should take opportunities to discuss voting and engagement with their

managers when these arise.

 Trustees should explicitly clarify their expectations around voting behaviour and approach in

their legal contracts. This includes through side letters as well as in any other Service Level

Agreements (SLAs). Trustees should also consider corresponding/additional targets and SLAs

for the investment advisers who support them on stewardship and voting. Trustees should also

agree the voting information and funds on which reporting is due, including the reporting

period and frequency. This information should be informed by the specific circumstances. For

example:

 A DC scheme with 95% of assets invested in the default arrangement may feel it is

appropriate to request data solely on the default arrangement funds. However, if a

significant proportion of beneficiaries are invested in one or more self-select funds, the

trustees may also wish to review data on these funds.

 A scheme may also consider requesting voting behaviour on any ethical or sustainable self-

select funds, recognising that beneficiaries who have opted to be in one of these funds will

be particularly interested in this information.

 Trustees should ask about their manager’s approach to stock lending. Please see the PLSA’s

2020 Stewardship Guidance and Voting Guidelines for further details. Although the trustees

will not be able to control the securities lending arrangements in pooled funds, trustees should

conduct the appropriate due diligence and monitoring of their asset managers’ securities

lending approach.

 Trustees should always ‘ask the question’. We understand from trustees that, where they have

sought to challenge their manager’s approach to voting on a particular issue – such as climate

change – in a pooled fund they have had some success in changing the approach. We recognise

that some trustees and their advisers will have more leverage with their managers than others,

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

but trustees should – as with any other material issue which impacts member outcomes –

challenge where they have particular concerns

SEGREGATED MANDATES

Schemes invested in segregated mandates will retain the legal ownership of the underlying

securities and will therefore have more influence over how votes are cast and over the manager’s

securities lending activities. They are also able to explicitly clarify related expectations in the

Investment Management Agreement (IMA). A number of the principles and issues outlined above

for pooled fund investors also apply to segregated mandates, but there are some further points

worth highlighting:

 Trustees should ensure they feel comfortable their vote has been cast appropriately. Segregated

accounts have more parties and responsibilities involved, and it will be important for trustees to

check that their vote has reached the issuer. It is also the case that global markets may have

different rules on split voting and use of abstentions, as well as different legal and practical

timescales involved.

 Expectations must be clarified in the IMA. This includes voting reporting dates and timescales,

as well as reporting format and frequency. It will be particularly important for time-lags to be

captured in the IMA. Trustees may require that some or all votes are cast in alignment with

their policies as a contractual condition.

FIDUCIARY MANAGEMENT

We would expect the fiduciary manager to obtain the necessary information from the underlying

managers on behalf of the trustees. Depending on the terms of their arrangement with the trustees,

the fiduciary manager may just pass this information to the trustees, or they may first collate

information across the scheme’s funds and form a view on the subset of significant votes to be

reported.

Fiduciary managers should ensure that they make clear to both prospective and, at regular

intervals, their current clients where they direct how votes are exercised instead of delegating this

to the underlying managers. In these cases, it will be the fiduciary manager rather than any

underlying managers who is the source of the voting information that trustees are required to

disclose.

Similar considerations to those set out above for fund managers apply to the appointment of

fiduciary managers in relation to stewardship, voting and vote reporting, especially where the

fiduciary manager is proposing to direct voting.

For those schemes with less governance capacity or lower AUM, we would encourage them to collaborate with other schemes – either

through the collaborative forums provided by organisations such as the PLSA, the Investor Forum, LAPFF and others, or through

exploring AMNT’s Red Line Voting Initiative.

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

ASSETS HELD ON A PLATFORM

As with fiduciary managers, platform providers may direct how votes are exercised instead of

delegating this to the underlying managers.

Trustees will be required to produce annual voting behaviour disclosures regardless of how their

scheme’s assets are held. As trustees do not have direct contractual arrangements with the

underlying managers when the assets are held on a platform, and those managers often do not

know which schemes are invested in their funds via the platform, it is likely that the platform

provider will need to obtain voting information on behalf of the trustees. This can be done by the

platform provider asking the managers to complete the PLSA Voting Information Template for the

relevant period.

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

ANNEX 4 | PLSA CRITERIA FOR “MOST SIGNIFICANT” VOTES

Asset managers are currently trying to get to grips with the meaning of “most significant” and are

using a wide variety of criteria to do so. Given that asset managers are exercising votes on behalf of

their clients, the PLSA expects that the views of the asset owner community generally – and client

interest specifically – should be taken into account.

Given the likelihood that asset managers and their clients will have different perspectives regarding

what constitutes a “most significant vote” for a scheme’s portfolio, the PLSA and our cross-industry

Voting and Implementation Statement Working Group (VISWG) suggest that the following criteria

should be used by managers.

Please note: we would expect client interest or policies on particular issues, themes or companies

to be the primary determinant of a manager’s approach to disclosing their “most significant votes”

to schemes. We note that Principle 6 in the 2020 UK Stewardship Code creates the presumption

that asset managers will align their approach with the objectives of their clients, on an “Apply and

Explain” basis. We think that it is good practice for managers of pooled funds to consider having a

process for consulting with clients, or mechanisms for seeking client views on issues and voting

approach. We would also expect the fund manager to disclose where the vote breaches the client’s

voting policy on the issue, particularly if the manager was aware of the voting policy in advance of

the vote.

Other criteria for both managers and trustees to consider (both pooled and segregated):

 Whether/where trustees have indicated a particular interest in the vote. Trustees – particularly

those invested in segregated mandates – should expect that where they have raised their

interest in a company, a theme, or have explicit expectations outlined in a voting policy (or their

IMA, or other relevant documents) that will be taken into account by managers. While this is

particularly pertinent for segregated mandates, the PLSA believes that it is good practice for

managers of pooled funds as well as segregated mandates to consider having a process for

consulting with clients, or mechanisms for regularly seeking client views on issues or the

managers’ voting approach and policy.

 Potential impact on financial outcome. This would include votes which the manager considers

might have a material impact on future company performance, for example approval of a

merger or a requirement to publish a business strategy that is aligned with the Paris Agreement

on climate change.

 Potential impact on stewardship outcome. This could include any decision which may reduce

the investor voice (e.g. around shareholder rights), such as a debt for equity swap, management

buyout of a significant share of equity, a downgrading of voting rights.

 Size of holding in the fund/mandate. Please note that we would not expect this to be the only

significant determinant used by managers in any explanation, rather this should be an

additional factor.

See Build a voting policy.

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

 Whether the vote was high-profile or controversial. This could be judged using any or all of the

following: a significant level of opposition from investors to the company resolution; a

significant level of support for an investor resolution; level of media interest; level of political or

regulatory interest; level of industry debate.

 Where the manager was subject to a conflict of interest. Please see p26 on the importance of

effective and transparent management of any stewardship or voting conflicts.

 Any vote in non-listed equity asset classes. Where there is a voting opportunity in private

equity, infrastructure or other asset classes – it is very likely that by its nature alone, it will be a

significant vote. Please also see Annex 4 for further details.

Additional considerations for segregated mandates include:

 Existing trustee policies and information. This should include the trustees’ SIP as well as any

standalone stewardship, engagement or voting policies.

 Consultation and discussion with client. It is possible that a theme, issue or company which was

not previously considered important by the client has risen up the scheme agenda by the time

voting discussions and decisions need to be taken.

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

ANNEX 5 | THE IMPORTANCE OF (STEWARDSHIP) CONFLICT IDENTIFICATION AND

MANAGEMENT

Asset managers are required to disclose their policy on conflicts of interest

and how this has been

applied in the context of their voting and engagement behaviour in both Principle 3 of the UK

Stewardship Code and the Principles for Responsible Investment (PRI) reporting.

This is important information and good disclosures are necessary for trustees to be able to

ascertain how well the manager is able to align its interests with those of its clients when it comes

to undertaking effective stewardship (for example engagement and voting).

Stewardship conflicts can arise in different ways, but trustees should be aware of the following

sources of conflict:

 The asset management firm overall has an apparent client-relationship conflict e.g. the

manager provides significant products or services to the company in which they also have an

equity or bond holding

 Senior staff at the asset management firm hold roles at a company, e.g. as a member of the

Board, in which the asset management firm has an equity or bond holding

 The asset management firm’s stewardship staff have a personal relationship with relevant

individuals at a company in which there is also an equity or bond holding

 There is a situation where the interests of different clients diverge. An example of this could be

a takeover, where one set of clients is exposed to the target and another set is exposed to the

acquirer

 There are differences between the stewardship policies of managers and their client(s).

Should the manager consider that any of their voting activities on behalf of trustees are subject to

any of the conflicts above – or any other conflicts – then they should disclose on which companies

or resolutions these conflicts have arisen. They should also describe whether and how they have

managed the conflict and the outcome from doing so. There should be a presumption that any vote

in relation to a conflict is a “significant” vote and therefore gives rise to detailed disclosure

expectations.

In our accompanying Vote Reporting guide for Implementation Statements for asset managers, we

have encouraged managers to proactively communicate as early as possible to their clients whether

there are likely to be any conflicts, or more broadly any restrictions placed upon them by, for

instance, their securities lending policies and approach to recalling stock before votes.

Please note: a stewardship-related policy on conflicts will be different from a firm’s broader conflicts policy as conflicts may arise in

additional forms for a manager’s engagement and voting activities.

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

ANNEX 6 | FURTHER READING

 Active Ownership 2.0: the Evolution Stewardship Urgently Needs (PRI, 2020)

 AGM Annual Voting Review (PLSA 2020)

 Aligning your pension scheme with the TCFD recommendations (Pensions Climate Risk

Industry Group, 2020)

 Engaging the Engagers: How to achieve effective stewardship outcomes through your asset

managers (PLSA/Investor Forum, 2020)

 ESG and Stewardship: A practical guide to trustee duties (PLSA, 2019)

 ESG Made Simple Guide (PLSA, 2019)

 Investment Association Responsible Investment Framework (IA, 2019)

 Model Mandate (ICGN, 2012 - soon to be updated)

 Red Line Voting Initiative (AMNT - ongoing)

 Stewardship Disclosure Framework (PLSA, forthcoming)

 Stewardship Guidance and Voting Guidelines 2020 (PLSA, 2020)

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

ACKNOWLEDGMENTS

The PLSA would like to thank all the members of the Voting and Implementation Statements

Working Group (VISWG) who contributed their time, expertise and enthusiasm to the production

of this guide.

 Laura Myers (LCP, VISWG Chair)

 Claire Jones (LCP)

 Rebecca Green (seconded to the PLSA, LCP)

 Chris Anker (Columbia Threadneedle Investments)

 Jocelyn Brown (T. Rowe Price)

 Anna Copestake (ARC Pensions Law)

 Naomi L’Estrange (20-20 Trustees)

 Simon Jones (Hymans Robertson)

 Elspeth McKinnon (The Cheviot Trust)

 Stuart O’Brien (Sackers)

 Chris Reilly (The People’s Pension)

 Colin Richardson (PTL)

 Sheila Stefani (Church of England Pension Board)

 Owen Thorne (Merseyside Pension Fund)

We are also grateful to members of our PLSA Policy Board and Advisory Groups, as well as to our

Stakeholder Group: John Belgrove (Aon), Kate Brett (Mercer), Claudia Chapman (FRC), Leanne

Clements (AMNT), Joe Craig (Quietroom), David Crum (Minerva Analytics), Joanne Etherton

(ClientEarth), David Farrar (DWP), Cosmo Gibson (FCA), Adam Gillett (Willis Towers Watson),

Robert Holloway (LGA), Melanie Jarman (TPR), Michael Jones (Pinsent Masons), Amanda

Latham (Barnett Waddingham) and Sarah Woodfield (the Investment Association (IA).

Vote reporting template for pension scheme implementation statement - Guidance for Trustees

DISCLAIMER

You must not reproduce, keep, or pass on any part of this publication in any form without

permission from the publisher.

Material provided in this publication is meant as general information on matters of interest. This

publication is not meant to give accounting, financial, consulting, investment, legal, or any other

professional advice.

The publisher (The Pensions and Lifetime Savings Association) or sponsoring company cannot

accept responsibility for any errors in this publication, or accept responsibility for any losses

suffered by anyone who acts or fails to act as a result of any information given in this publication.

Vote reporting template for pension scheme implementation statement - Guidance for Trustees