OUR POLICIES AND PROCEDURES

This Statement sets out the practice and policy regarding key discretions that fall to the LPFA as an Administering Authority where an employer has become defunct. It will be reviewed on a biennial basis.

On an annual basis, LPFA is required to prepare an annual governance statement (AGS) outlining how the governance and internal control arrangements have performed.

The purpose of this policy is to outline how LPFA will manage new employer admissions and cessations in the Fund.

Our Climate Change Policy outlines the approach that we, working with our outsourced investment manager, LPPI, take in managing the risks of climate change.

The Communications Policy Statement describes how we communicate to our members, stakeholders, employers and potential members of the Fund.

Customer service is important to us. The LPFA and our outsourced pensions administration service provider, LPPA, want to ensure that LPFA member and employer complaints are dealt with in a fair and transparent manner. Members and employers have the right to have their complaint independently reviewed under the Internal Disputes Resolution Procedure (IDRP). Further information can be found on in the members’ section of this website.

We operate in accordance with our own legal constitutional document. This constitutional document sets out the corporate governance arrangements of how the LPFA operates, how decisions are made and the procedures which are followed to ensure that decision-making is transparent and accountable.

This document sets out our policy on amending the contribution rates payable by an employer (or group of employers) between formal Funding valuations.

The purpose of the Data Protection Policy is to set out London Pensions Fund Authority (LPFA) position in how it meets its legal obligations under the United Kingdom General Data Protection Regulation (UK GDPR) and Data Protection Act (DPA) 2018. Data protection introduces rules around how an organisation manages, processes and protects the data that it holds regarding individuals. It also gives individuals rights related to the information that is held by LPFA and its third party service providers.

This policy relates to discretionary powers that LPFA is able to decide in relation to applying certain aspects of the Local Government Pension Scheme.

This framework outlines how LPFA identifies, assesses, and manages the risk of an individual employer being unable to make payments to the Fund when required.  

The LPFA seeks to minimise our impact on the environment. Our Environmental Policy Statement outlines the Fund’s approach to our operations. We work with Planet Mark to continuously seek to improve our sustainability and to measure and, where possible, reduce our carbon footprint. For more information about our approach to responsible investment and our climate change policies, please click here.

We are committed to providing equality of opportunity and access in both our employment and service arrangements. Our Equal Opportunities, Diversity & Dignity at Work Policy sets out our guiding principles, roles and responsibilities.

Our Fraud Control Framework sets out the LPFA’s approach and commitment to fraud prevention and detection. The framework is a summary of our approach to the management of fraud prevention, detection and reporting. Codes of practice, procedures and policies are also available separately. As a body financed by public monies, we must ensure that the framework of internal control limits exposure to fraud and corruption.

We are required to publish details of our publication scheme as part of meeting our obligations under the Freedom of Information Act. If the information that you wish to request is not included in the publication scheme, email: legal@lpfa.org.uk. 

The publication scheme also details the LPFA’s charging structure which may be appropriate regarding some requests. We do not provide direct links to all the information it publishes, but it uses this website to hold the majority of the information.

The Gifts, Hospitality and Expenses Framework sets out our approach to gifts, hospitality and expense claims by Board members, Local Pension Board members and employees.

These registers record any gifts, hospitality or expenses claimed over the period.

The LGPS Governance Compliance Statement sets out how the administration of the Authority is governed. Each administering authority is required to publish a governance compliance statement in accordance with The Local Government Pension Scheme Regulations 2013 and set out how they comply with Regulation 55.

Our Health & Safety Policy outlines our intentions and arrangements for ensuring the health, safety and well-being of our employees whilst at work and other persons involved or affected by our business activities.

We are committed to preserving the confidentiality, integrity and availability of all the physical and electronic information assets throughout our organisation. The provision of Information Technology (IT) services are outsourced to LPPI, as part of a corporate services agreement. LPFA’s Information Security Compliance Statement sets our strategic approach to information security.

The LPFA Local Code of Corporate Governance sets out how the LPFA ensures a well-run and well governed fund. The code has been developed in line with the CIPFA (Chartered Institute of Public Finance and Accountancy) and SOLACE (The Society of Local Authority Chief Executives and Senior Managers) guidance contained in ‘Delivering Good Governance in Local Government Framework’. The Local Code of Corporate Governance articulates how the LPFA adopts the core principles of good governance.

Our Pay Policy Statement outlines our approach to providing transparency and fairness of pay. The policy describes our pay framework and approach to determining pay.

The Responsible Investment Policy sets out how the Fund aims to be a responsible investor by integrating environmental, social and governance issues into our investment process.

Risk management is the process of identifying, assessing, quantifying, monitoring, controlling and reporting the risks to which the LPFA Fund is exposed and determining how best to mitigate such risks and/or handle such exposure. The purpose of risk management is to ensure that LPFA is aware of and understands the risks involved in carrying out its activities and takes positive action to reduce and/or mitigate them where appropriate and possible. The LPFA risk management process is outlined in our Risk Management Principles.

As an appointed body responsible for the proper and prudent management of public monies, and the administration of a public sector pension scheme, the LPFA:

• is risk averse in terms of ensuring legal compliance, eradicating all forms of unfair discrimination, maintaining financial integrity and achieving effective delivery of operations; and
• has a greater appetite, in a controlled environment, for risk when pursuing new business development and attempting to maximise investment returns, having regard to its fiduciary duty acting in the long-term best interests of fund stakeholders.

This policy sets out our approach to social media including the channels that we use, how we respond and the sort of content that we share.

We are committed to openness, probity and accountability. Our Whistleblowing Policy is designed to reassure all those that work for us can raise any concerns internally knowing that we will treat them seriously and in confidence, taking reasonable steps to investigate any concerns.