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TPR's final General Code: governance duties, ORA timing, remuneration policy scope, removal of 20% illiquid limit, added climate/D&I—practical steps and deadlines for trustees from March 2024

Published on: 17 January 2024

Published by a LexisNexis Pensions expert
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Article summary

What is the background to TPR's consultation on its new General Code?

Statutory requirements and consultation process:

Under the 2018 Regulations:

  • Trustees and other governing bodies must establish and operate an effective system of governance (ESOG). For simplicity, this article refers only to trustees. The General Code applies to all occupational pension schemes, with ESOG exemptions for public service schemes, authorised master trusts and authorised collective money purchase schemes.
  • To this end, TPR must issue a Code of Practice covering ESOG and, for schemes with 100 or more members, related areas, including an own-risk assessment of the governance system and a remuneration policy.

The General Code has been some time in development. The 2018 Regulations (SI 2018/1103) took effect in January 2019. TPR issued a draft Code for consultation in March 2021; the consultation closed in May 2021, and an interim response followed three months later.

What was the outcome following the consultation? Have any significant changes been made?

The finalised General Code, released on 10 January 2024, closely resembles the draft. However, various provisions...

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