Implementation Statement for the Federated Pension Scheme for Imperial - Covering 1 April 2022 to 31 March 2023

Introduction

This Implementation Statement reports on the extent to which, over the Scheme Year, the Trustees have followed their policy relating to the exercise of rights (including voting rights) attaching to the Scheme’s investments.
In preparing this statement, the Trustees have considered guidance from the Department for Work & Pensions which was updated on 17 June 2022.

Relevant Investments

The Scheme’s assets are invested in pooled funds, none of which include an allocation to equities. As such, the investment manager does not have an entitlement to vote so there are no voting records for the Trustees to analyse.

The Trustees’ Policy Relating to the Exercise of Rights

Summary of the Policy
The Trustees’ policy in relation to the exercise of rights (including voting rights) attaching to the investments is set out in the SIP. A summary of this wording is as follows:

•  The Trustees believe that their main duty, reflected in their investment objectives, is to protect the financial interests of the Scheme’s members. The Trustees believe that ESG considerations (including but not limited to climate change) and stewardship in the selection, retention and realisation of their investments are an integral part of this duty and can contribute to the generation of good investment returns.
• The Trustees believe that stewardship is important, through the exercising of rights (including voting rights) attaching to investments. However, this is less straightforward in bond investments where there are no voting rights. The Trustees are keen that their manager can explain when, and by what practical methods, they monitor and engage with relevant persons about relevant matters in this area, and to the extent that it is
  feasible the Trustees will report annually on this. 
• The Trustees are aware that ESG and stewardship considerations involve an ongoing process of education for themselves and engagement with their investment manager. To that end they dedicate time regularly to the discussion of this topic and intend to review and renew their approach periodically with the help of their investment consultants, where required.
• The Trustees have elected to invest predominantly in pooled, passive government and corporate bond funds and not in equities. Consequently, it is difficult to directly influence the ESG policies of the funds in which they invest.
• The Trustees will consider the manager policies in all future selections and will seek to deepen their understanding of their existing manager policies by reviewing these at least annually.
• The Trustees are keen that all their managers are signatories of the UN Principles of Responsible Investment and the UK Stewardship Code.
• In cases where the Trustees are dissatisfied with a manager’s approach to ESG and voting rights, they will take this into account when reviewing them. 

Has the Policy Been Followed During the Scheme Year?

The Trustees’ opinion is that its policy relating to the exercise of rights (including voting rights) attaching to the investments has been followed during the Scheme Year. In reaching this conclusion, the following points were taken into consideration:

• There has been no change to the Trustees’ belief regarding the importance of good
  stewardship.
• The Scheme’s invested assets remained invested in pooled funds over the period.
• The Trustees did not select any new funds during the period.
• The Trustees did not consider the voting records of the investment manager since none of the assets held include an allocation to equities.
• The investment manager used by the Scheme is an UNPRI and UK Stewardship Code signatory.

Conclusion

None of the assets held by the Scheme over the period included an allocation to equities so there are no voting rights attached. The Trustees will continue to assess the Scheme’s strategy over the next period should this change.