National Communications Union Staff
Background and Implementation Statement
Background
The Department for Work and Pensions (‘DWP’) is increasing regulation to improve disclosure of financially material risks. This regulatory change recognises Environmental, Social and Governance (ESG) factors as financially material and schemes need to consider how these factors are managed as part of their fiduciary duty. The regulatory changes require that schemes detail their policies in their Statement of Investment Principles (SIP) and demonstrate adherence to these policies in an implementation report.
Statement of Investment Principles (SIP)
The Scheme has updated its SIP in response to the DWP regulation to cover:
policies for managing financially material considerations including ESG factors and climate change
policies on the stewardship of the investments
The SIP can be found online at the web address here. Changes to the SIP are detailed on the following pages.
Implementation Report
This Implementation Report is to provide evidence that the Scheme continues to follow and act on the principles outlined in the SIP. This report details:
actions the Trustees have taken to manage financially material risks and implement the key policies in its SIP
the current policy and approach with regards to ESG and the actions taken with managers on managing ESG risks
the extent to which the Trustees have followed policies on engagement, covering engagement actions with its fund managers and in turn the engagement activity of the fund managers with the companies they invest
voting behaviour covering the reporting year up to 31 December 2020 for and on behalf of the Scheme including the most significant votes cast by the Scheme or on its behalf
Summary of key actions undertaken over the Scheme reporting year
No changes were made to the Scheme’s investments during the year.
Implementation Statement
This report demonstrates National Communications Union Staff Superannuation Scheme has adhered to its investment principles and its policies for managing financially material considerations including ESG factors and climate change.
Signed Brian Healy
Position Chair, NCUSSS
Date 5 April, 2021
Managing risks and policy actions DB
Changes to the SIP
Implementing the current ESG policy and approach
ESG as a financially material risk
The SIP describes the Scheme’s policy with regarding to ESG as a financially material risk. This page details how the Scheme’s ESG policy is implemented, while the following page outlines Isio’s assessment criteria as well as the ESG beliefs used in evaluating the Scheme’s managers’ ESG policies and procedures. The rest of this statement details our view of the managers, our actions for engagement and an evaluation of the stewardship activity.
The below table outlines the areas which the Scheme’s investment managers are assessed on when evaluating their ESG policies and engagements. The Trustees intend to review the Scheme’s ESG policies and engagements periodically to ensure they remain fit for purpose. Implementing the Current ESG Policy
ESG summary and engagement with the investment managers
Engagement
As the Scheme invests via fund managers the managers provided details on their engagement actions including a summary of the engagements by category for the 12 months to 31 December 2020.
Voting (for equity/multi asset funds only)
As the Scheme invests via fund managers the managers provided details on their voting actions including a summary of the activity covering the reporting year up to 31 December 2020. The managers also provided examples of any significant votes.
This report has been prepared for the sole benefit of the Trustees of National Communications Union Staff Superannuation and based on their specific facts and circumstances and pursuant to the terms of Isio Group Limited’s services contract. It should not be relied upon by any other person. Any person who chooses to rely on this report does so at their own risk. To the fullest extent permitted by law, Isio Group Limited accepts no responsibility or liability to that party in connection with the Services
Document classification: Public
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