TPR Code Review - Updated Report July 2025
25th September 2025
TPR Code Review - Updated Report July 2025
REPORT TO: PENSION SUB-COMMITTEE OF THE CITY GOVERNANCE COMMITTEE & PENSION BOARD – 22 SEPTEMBER 2025
REPORT ON: THE PENSIONS REGULATOR - GENERAL CODE REVIEW
REPORT BY: EXECUTIVE DIRECTOR OF CORPORATE SERVICES
REPORT NO: 258-2025
1 PURPOSE OF REPORT
To inform members of the outcome of the review undertaken by Isio of the code requirements, following recommendation by Audit Scotland.
2 RECOMMENDATIONS
The Sub-Committee is asked to note the content of this report.
3 FINANCIAL IMPLICATIONS
There are no financial implications other than those highlighted in the risk register.
BACKGROUND
4 The External Auditors Annual Report on the Tayside Pension Find Accounts 2023/24 was previously considered by the Pension Sub-Committee and Board (Article VI of the Minute of the Meeting of Pension Sub-Committee and Pension Board 23 September 2024, report 273-2024 refers). The action plan to this report noted that the Pension Regulators General Code of Practice was introduced on 28 March 2024, and it was agreed a review of the code requirements would be undertaken during the year, following the advisory review of code readiness undertaken by PwC in June 2024 (Article V of the Minute of the Meeting of Pension Sub-Committee and Pension Board 24 June 2024, report 184-2024 refers).
5 OUTCOME OF REVIEW
Isio believe that the Fund is in a reasonable position, and that current policies and processes are thorough, with only one of the 39 areas non-compliant (exercise already scheduled with PwC), and 7 requiring adjustments. The full findings of the review are contained in Appendix A. Below is a summary of actions requiring address and intended remedies which will be actioned during the coming months:
|
Reference |
Workstream |
Missing requirements |
Actions required |
|
1 |
Appointment & Removal of Trustee(s) and Chair of Trustees |
Succession plan |
Member Policy required to incorporate all, and link to Council Standing Orders and other policies (e.g. Training & Attendance). |
|
Resignation & removal policy |
|||
|
5 |
Meeting / Decision Making Process |
Circumstances for extraordinary meetings |
|
|
Determine length of meetings |
|||
|
Process for rescheduling postponed meetings |
|||
|
8 |
Trustee Training and Knowledge |
Challenges of attendance and engagement for training - Recommendation to further formalise the training structure and review process, with consideration given to the resourcing of this. |
Strengthening of policy to make training mandatory. Alternative providers to be considered. |
|
15 |
Own Risk Assessment (ORA) |
The ORA is an assessment of how well governance systems are working, and the way potential risks are managed. |
PwC scheduled to undertake |
|
26 |
Record keeping |
Need to state that data is stored electronically within systems and retained in accordance with DCC retention policies. |
Amend Administration Strategy to include data storage, retention, review and improvement. |
|
27 |
Data Improvement Plan |
Need to state in policy how often data is reviewed. |
|
|
30 |
Financial transactions |
Process for rebalancing of portfolio and draw down from custodian to pay pensions not included in any policies. |
Amend Treasury Policy to incorporate. |
|
39 |
Reporting to TPR |
No specific breach policy. |
New policy required. |
6 POLICY IMPLICATIONS
This report has been subject to the Pre-IIA Screening Tool and does not make any recommendations for change to strategy, policy, procedures, services or funding and so has not been subject to an Integrated Impact Assessment. An appropriate senior manager has reviewed and agreed with this assessment.
7 CONSULTATIONS
The Chief Executive and Head of Democratic and Legal Services have been consulted in the preparation of this report.
8 BACKGROUND PAPERS
None.
PAUL THOMSON
EXECUTIVE DIRECTOR OF CORPORATE SERVICES 25 September 2025