Memorandum submitted by the Pension Protection
Fund
1. INTRODUCTION
1.1 The Pension Protection Fund is a statutory
fund run by the board of the Pension Protection Fund, a statutory
corporation established under the Pensions Act 2004. The Pension
Protection Fund became operational on 6 April 2005.
1.2 The Pension Protection Fund is an executive
non-departmental public body governed by a board, consisting of
a chair (appointed by Secretary of State for Work and Pensions),
a chief executive (the initial appointment is also made by the
Secretary of State) and a minimum of five other members, two of
whom must be from the staff of the Pension Protection Fund. There
are currently five non executive members and two executive members
(in addition to the chair and chief executive). A list of board
members is at Appendix A.
1.3 As a public body, the Pension Protection
Fund is accountable to Parliament. This includes producing an
annual report which is submitted to the Secretary of State for
Work and Pensions, who then lays the report before Parliament.
In addition, the annual accounts are sent to the Comptroller and
Auditor General, head of the National Audit Office, who must examine,
certify and report on each statement of accounts. The accounts
and reports are laid before Parliament with the annual report.
1.4 The mission of the board of the Pension Protection
Fund is to promote increased confidence and set reasonable expectations
for members of UK defined benefit pension schemes by:
— paying the right amount of compensation
to the right people at the right time;
— setting and collecting a levy which
is appropriate and proportionate; balancing employer and member
interests;
— prudent and effective management
of its investments to meet future obligations; and
— communicating clearly what the Pension
Protection Fund does and why.
1.5 Extensive information about the board
and its operations can be found on its website at www.pensionprotectionfund.org.uk,
including information and guidance for industry professionals
and scheme members.
2. BACKGROUND
2.1 Employees join occupational defined
benefit pension schemes expecting that they will receive the pension
that they have been promised. This promise is realised if there
are sufficient scheme assets to meet pension liabilities as they
fall due, or the sponsoring employer is able to make good any
shortfall. In most cases members receive the pension they have
been promised.
2.2 However, if an employer becomes insolvent,
there are sometimes insufficient funds in the pension scheme to
meet the liabilities in full. In some cases employees contributed
to a pension scheme for many years, only to find that when the
scheme was wound up in the immediate run-up to their retirement,
they received a much lower pension than they had expected. In
the light of this, the Government decided that measures were needed
to restore confidence in occupational pension provision.
2.3 The Pension Protection Fund was therefore
established to pay compensation, at statutorily determined rates
to members of eligible defined benefit occupational pension schemes
and the defined benefit elements of hybrid schemes (a scheme with
both defined benefit and defined contribution elements).
2.4 Compensation is payable: where there
is a qualifying insolvency event in relation to the sponsoring
employer on or after 6 April 2005 with no possibility of a scheme
rescue; the scheme did not commence wind up; the trustees have
not compromised the pensions debt and there are insufficient assets
in the pension scheme to cover Pension Protection Fund levels
of compensation. This provides members of eligible schemes with
the assurance that they will receive a meaningful level of income
even in the event of their sponsoring employer becoming insolvent.
2.5 The running costs of the Pension Protection
Fund are financed indirectly by the administration levy. The amount
of the 2005-06 administration levy is based on the estimated initial
start up costs and ongoing administrative costs of the Pension
Protection Fund for 2005-06. This levy is raised by the Secretary
of State for Work and Pensions and collected by the Pensions Regulator.
There is a charge per member. Schemes are banded according to
the size of their membership. The amount to be paid per member
depends on the band into which the scheme falls (subject to a
minimum amount per band).
| Number of members |
Amount of levy
calculated by reference
to number of members (M)
|
Minimum amount
of levy |
2-11 |
|
£24 |
| 12-99 |
£2.50 x M |
|
| 100-999 | £1.80 x M |
£250 |
| 1,000-4999 | £1.40 x M
| £1,800 |
| 5,000-9,999 | £1.06 x M
| £7,000 |
| |
|
3. KEY FUNCTIONS
OF THE
BOARD
Paying Compensation
3.1 A key objective for the board is to "pay the
right amount of compensation to the right people at the right
time".
3.2 The Pension Protection Fund will provide two levels
of compensation, each laid down in statute:
(i) For individuals that have reached their pension scheme's
normal pension age or, irrespective of age, are either already
in receipt of survivors' pension or a pension on the grounds of
ill health, the Pension Protection Fund will pay 100% level of
compensation.
In general terms, this means a starting level of compensation
that equates to 100% of the pension in payment immediately before
the assessment date (subject to a review of the rules of the scheme
by the Pension Protection Fund).
The part of this compensation that is derived from pensionable
service on or after 6 April 1997 will be increased each year in
line with the Retail Prices Index capped at 2.5%. This could,
potentially, result in a lower rate of increase than the scheme
would have provided.
(ii) For the majority of people below their scheme's normal
pension age, the Pension Protection Fund will pay a 90% level
of compensation.
In broad terms and in normal circumstances, this means 90%
of the pension an individual had accrued immediately before the
assessment date (subject to a review of the rules of the scheme
by the Pension Protection Fund) plus revaluation (up to a 5% ceiling)
in line with the increase in the Retail Prices Index between the
assessment date and the commencement of compensation payments.
This compensation is subject to an overall cap, which equates
to £25,000 at age 65 (the cap will be adjusted according
to the age at which compensation comes into payment and will increase
annually in line with earnings).
Once compensation is in payment, the part that derives from
pensionable service on or after 6 April 1997 will be increased
each year in line with the Retail Prices Index capped at 2.5%.
Again, this could result in a lower rate of increase than the
scheme would have provided.
3.3 In addition there will also be compensation for certain
survivors.
3.4 There exists statutory provision for the Pension
Protection Fund to reduce the indexation of its existing levels
of compensation and revaluation, or to seek the Secretary of State's
agreement to reduce the level of compensation it pays, by Affirmative
Order.
3.5 The board anticipates that the first compensation
payments to scheme members of pension schemes that transfer into
the Pension Protection Fund will be made towards the end of 2006.
3.6 The objective in 3.1 above encapsulates the board's
desire to ensure that the delivery of services to scheme members
is both efficient and cost effective. It covers the payment of
compensation once a scheme is transferred to the Pension Protection
Fund, and the actions and behaviours of trustees of schemes during
an assessment period. In particular, the board considers it critical
that data transferred from schemes is as accurate and complete
as possible to best facilitate correct payment of compensation
on an ongoing basis.
Scheme Assessment
3.7 The assessment period starts after the occurrence
of a qualifying insolvency event in relation to a sponsoring employer
of an eligible occupational pension scheme. During this period
the Pension Protection Fund determines whether the protected liabilities
of a pension scheme are greater than the scheme's assets, and
hence whether the board of the Pension Protection Fund is required
to assume responsibility for the pension scheme. This valuation
requirement is set out under section 143 of the Pensions Act 2004
with supporting actuarial guidance published by the board.
3.8 During the assessment period, the trustees remain
responsible for the pension scheme and are obliged to pay pensions
at Pension Protection Fund levels of compensation. The trustees
are encouraged by the Pension Protection Fund to communicate progress
to scheme members at regular and appropriate times throughout
the assessment.
3.9 The board is committed to working in partnership
with trustees to ensure that this objective is met. It has produced
guidance setting out what is expected of trustees during an assessment
period, and as part of the board's ongoing commitment to communicate
effectively, it is soon to publish a tool kit for trustees. This
should provide additional support for them during the assessment
period.
3.10 The key tests undertaken to determine whether the
Pension Protection Fund will assume responsibility for a pension
scheme are:
— can the pension scheme can be rescued; and
— does the actuarial valuation of the pension scheme
as at the assessment date show that the value of the assets exceed
the Pension Protection Fund level of protected liabilities.
The protected liabilities are the cost of securing pension
scheme members' benefits which correspond to a level that does
not exceed the compensation payable to them should the Pension
Protection Fund assume responsibility for the pension scheme.
3.11 The assessment period ends when: there is a withdrawal
event; a transfer notice is issued by the board; or the s143 valuation
shows that the value of the assets exceeds the value of the protected
liabilities. A withdrawal event occurs where the pension scheme
has been rescued, or where the board of the Pension Protection
Fund has decided that the scheme is not eligible. The following
diagram provides an overview of the assessment period process:
Overview of the Assessment process
3.12 A transfer notice is issued by the Pension Protection
Fund where a rescue of the pension scheme is not possible and
the s143 valuation shows that the value of the pension scheme's
assets are less than the value of protected liabilities. A transfer
notice cannot be issued for at least 12 months after the assessment
date to take into account any fraud compensation applications
(see below). The activities undertaken by the trustees and the
board during the assessment period are similar to the activities
involved in winding up a pension scheme, a process that can typically
take between two and four years depending on the complexity and
size of the pension scheme.
3.13 The length of the assessment period does not affect
the financial position of scheme members, who will receive benefit
payments at the Pension Protection Fund level from the scheme
during the assessment period. However, the Pension Protection
Fund's objective is to work in partnership with trustees to move
schemes through the assessment period as quickly and efficiently
as possible.
3.14 The following table shows the cumulative number
of schemes in an assessment period at the end of each quarter
from the board's inception to the most recently available figures
(February 2006).
Date |
Schemes in assessment |
Number of scheme members |
30 June 2005 |
9 |
6,734 |
| 30 September 2005 | 22
| 18,464 |
| 31 December 2005 | 40
| 21,575 |
| 28 February 2006 | 53
| 25,906 |
| |
|
A list of the schemes in assessment is included in Appendix
B.
Setting and collecting a levy
3.15 Compensation payments are financed partly by the
assets transferred from schemes for which the Pension Protection
Fund has assumed responsibility (including any recoveries from
employers and third parties), and partly by an annual levy raised
on eligible pension schemes.
3.16 The initial levy introduced from 1 April 2005 has
been set by the Secretary of State for Work and Pensions and will
apply only for one year. The initial levy is a scheme based levy
only, where schemes are charged £15 for each active member,
pensioner member and person receiving a survivor's pension and
£5 for each deferred member. The initial levy rates and levy
structure are detailed in The Occupational Pension Schemes (Levies)
Regulations 2005. The initial levy is collected by the Pensions
Regulator on behalf of the board.
3.17 The pension protection levy, which consists of a
scheme based levy and a risk based levy, replaces the initial
levy from the financial year 2006-07 and will be set annually
by the board of the Pension Protection Fund. The board must consider
the level of a pension scheme's liabilities and may consider the
number of members and the amount of pensionable earnings in respect
of active members, when setting the scheme based levy. The scheme
based levy may be up to 20% of the total estimated amount of pension
protection levy to be collected across all schemes in any one
year. The board must consider the level of scheme underfunding
and the likelihood of sponsoring employer insolvency and may also
consider asset allocation and any other risk factors that may
be prescribed in regulations when setting the risk based pension
protection levy. The risk based levy must be at least 80% of the
total estimated amount of pension protection levy to be collected
across all schemes in any one year, except during the transitional
period.
3.18 The board decided to introduce a pension protection
levy that is 80% risk-based for all schemes as quickly as possible—in
practice, from the 2006/07 financial year onwards—due to
the widespread support among pension schemes and sponsoring employers
for the early introduction of a levy basis properly reflecting
these risks. The risk-based levy ensures that those schemes posing
the greatest risk of becoming a charge on the Pension Protection
Fund will pay a fair share of the levy (a levy based purely on
numbers of scheme members clearly requires large, well-funded
schemes to subsidise smaller, poorer-funded ones).
3.19 The introduction of a risk-based levy marks a major
stage in the development of the Pension Protection Fund. The board
issued three substantial statements about the new levy structure
during the second half of 2005:
— a consultation document in July setting out its
preliminary thinking and initial proposals;
— an update in October setting out further thinking
in a number of important technical areas;
— a summary of consultation responses in December
and specific proposals on the use of contingent assets (first
raised in the October update) and final proposals on the pension
protection levy taking responses from the earlier consultation
into account.
These documents are designed to give eligible schemes, sponsoring
employers and others a comprehensive understanding of all the
key elements of the levy—how much it will be in aggregate;
how it will be calculated for each individual scheme; which factors
will be taken into account in determining the risk; the requirements
for valuations necessary for the levy calculation and the procedures
for appeals.
3.20 The board recognises the significance for pension
schemes and their sponsoring employers of its proposals for a
risk-based levy. It has therefore sought to take forward its levy
consultation on a step by step basis, giving careful consideration
to responses and, where appropriate, modifying earlier proposals
in order to ensure a levy structure which is fair, simple and
proportionate, that strikes the right balance between affordability
for pension schemes and security for pension scheme members. The
board consulted on its proposals in total for 17 weeks and received
over 250 written responses from employers, trustees, advisers
and industry groups. Key specific areas where the outcome of the
consultative process has been reflected in the final proposals
include:
— the risk-based levy will be capped at 0.5% of
a scheme's Pension Protection Fund liabilities to help weaker
schemes;
— schemes over 125% funded on the basis of Pension
Protection Fund benefits will not have to pay the risk-based element
of the levy at all;
— the inclusion of contingent assets as an additional
risk factor (subject to regulations) such as parental guarantees,
letters of credit from third parties and security over securities;
— recognising special "deficit repair"
contributions; and
— no schemes will have to conduct out-of-cycle valuations.
3.21 The board's pension protection levy estimate for
2006-07 is £575million. The table below sets out the split
between the risk based levy and scheme based levy.
| Risk based levy
| Scheme based levy |
Amount |
£460 million |
£115 million |
| Percentage | 80% | 20%
|
| Factors | — Underfunding
— Insolvency
— Contingent assets |
— Liabilities
|
| |
|
The Pension Protection Fund has the ability to alter the
total amount of pension protection levy to meet its liabilities
although by statute it may not increase the levy by more than
25% in any one year. In addition, the total amount of levy the
board may raise in any financial year is limited by the levy ceiling
set by the Treasury. The regulations setting the levy ceiling
are currently being debated by Parliament with a proposed ceiling
of £775 million.
3.22 The board published its final determination on 28
February 2006 setting out:
— the factors which the board will consider when
assessing the pension protection levies;
— the time by which those factors will be assessed;
— the rate of the levies; and
— the date when the levies become payable.
The determination will formally take effect following the
appropriate regulations coming into force.
3.23 The board believes that its final proposals are
a fair, simple and proportionate basis for the first risk-based
levy. They provide pension schemes and their sponsoring employers
with a powerful set of incentives to reduce their risks which
would lead to reduced levy invoices for their schemes.
3.24 However, going forward the board expects that both
the amount and distribution of risk will change year on year,
and as such the board expects to recalibrate the Pension Protection
Fund's risk models annually and consult each year on its proposals
for the pension protection levy.
Prudent investment of assets
3.25 In June 2005, the board published its "Statement
of Investment Principles", setting out the principles and
policies governing the investment of the 2005-06 initial levy.
The Statement is a legislative requirement and demonstrates the
Pension Protection Fund's commitment to managing its assets effectively
and appropriately to protect the interests of both levy payers
and beneficiaries of compensation.
3.26 The board's investment objective is to have sufficient
funds to pay compensation to scheme members of eligible schemes
transferred into the Pension Protection Fund. To help achieve
this objective, the board will be adopting a proactive approach
to asset management, seeking to match the Pension Protection Fund's
assets as closely as possible to the fund's liabilities. The board
will review its Statement of Investment Principles annually, or
earlier in the event of any significant change in the capital
markets, or the liabilities of the fund.
3.27 The Pension Protection Fund has appointed three
fund managers to oversee the day to day management of its assets.
These managers are Insight Investments, PIMCO and Goldman Sachs
Asset Management. The Pension Protection Fund was helped in its
search for fund managers by Mercer Investment Consulting who provided
the board with investment advice. These fund managers were appointed
for a term of three years following a comprehensive and detailed
selection process under the OJEU procurement framework. A benchmark
has been set, against which the performance of the fund managers
will be measured. Their performance will be reviewed regularly
by the board's investment committee. Details of this benchmark
are set out in the board's Statement of Investment Principles.
This also includes details of strict guidelines issued to the
fund managers limiting the percentage of the fund's assets that
can be invested in any one economic sector, credit rating class
or in any one bond issue or issuer.
3.28 Currently, Insight Investment and PIMCO each manage
50% of the board's assets. The third fund manager, Goldman Sachs
Asset Management, will start to manage assets in 2006. The investments
of the fund comprise the initial levy received in respect of 2005-06.
The Pension Protection Fund currently invests in government bonds
(issued by the UK and overseas governments), corporate bonds (issued
by companies) and index linked bonds (where the payments are linked
to inflation) and other types of bonds such as mortgage backed
securities and asset backed securities (where there are specific
assets backing the payments and capital). The fund is also able
to invest in derivatives. These can be used to reduce risk and
also to gain exposure to some markets in a more cost effective
way or engineer cash flow profiles that could not be created by
limiting investments to the existing bond markets.
3.29 In future years the Pension Protection Fund's assets
will include the pension protection levy proceeds, investment
returns and any assets received from eligible pension schemes
(including recoveries from employers of statutory debt) at the
point they transfer to the Pension Protection Fund. The Pension
Protection Fund is likely to appoint other specialist fund managers
in the future to manage investments in other asset classes and
to help transition the assets of those pension schemes that are
transferred to it to be consistent with its longer term investment
strategy of liability driven investment.
Effective communications
3.30 Effective proactive communications is at the heart
of the Pension Protection Fund. Through open and transparent consultation
we have demonstrated that we are an organisation that listens
to its stakeholders, and have delivered proposals for the risk
based levy that strike the right balance between affordability
for pension schemes and security for scheme members.
3.31 The Pension Protection Fund is also committed to
informing and educating its stakeholders through: holding industry
workshops, such as the six risk based levy workshops held across
the country in February 2006; public speaking platforms; guidance
published on the Pension Protection Fund's website and meetings.
The Pension Protection Fund also has a dedicated helpline which
deals with queries from a wide range of industry stakeholders
and interested parties.
3.32 Through an annual stakeholder perception audit,
the Pension Protection Fund is keen to learn how industry and
individuals want to receive information so that the Pension Protection
Fund can continue to meet the information needs of its stakeholders.
Fraud compensation
3.33 The Fraud Compensation Fund is a statutory fund
run by the board of the Pension Protection Fund. It was established
under the Pensions Act 2004 to provide compensation to occupational
pension schemes that suffer a loss that can be attributable to
dishonesty. It became operational on 1 September 2005 and replaces
the former Pensions Compensation Board set up under the 1995 Pensions
Act. The Fraud Compensation Fund applies to most defined benefit
and defined contribution occupational pension schemes.
3.34 Compensation from the Fraud Compensation Fund may
be paid where an occupational pension scheme's assets have been
reduced and the board is satisfied that the loss can be attributable
to an act of dishonesty. Before fraud compensation can be paid,
the board must be satisfied that the trustees or managers of the
pension scheme have made attempts to seek recoveries of the loss
from other sources to the extent that they might do so without
disproportionate cost and within a reasonable time. Each application
and payment decision must be considered on a case by case basis.
3.35 A levy may be imposed by the Secretary of State
on all eligible occupational pension schemes to ensure that the
fund's assets are sufficient to cover its liabilities. It is not
currently planned to impose a levy in 2006-07. There have
been no new applications for compensation from the fund since
the board took responsibility for it on 1 September 2005. At
the dissolution of the Pensions Compensation Board, six existing
applications were transferred to the Pension Protection Fund and
work is progressing on these cases.
4. REVIEWS AND
APPEALS
4.1 The board operates a two-stage internal review process
to deal with applications for reviews and complaints of maladministration.
A leaflet—How we deal with your concerns— sets
out details of this process and lists matters which are reviewable
under Schedule 9 of the 2004 Act. If, following this two stage
process, applicants are not content, they can apply to the Pension
Protection Fund Ombudsman (an additional statutory role, performed
by David Laverick, who is also the Pensions Ombudsman)—in
respect of reviewable matters or complaints.
5. CONCLUDING COMMENTS
5.1 Working in partnership with the pensions industry
has been fundamental to the successful establishment of the Pension
Protection Fund during the first year of operations, a practice
that will continue into the future as the organisation and its
policies continue to evolve.
5.2 By putting in place a robust and effective operational
framework, and through working in partnership with the pensions
industry, the Pension Protection Fund can deliver real security
in retirement for thousands of UK pension scheme members.
Appendix A
MEMBERS OF THE BOARD OF THE PENSION PROTECTION FUND
Chair—Lawrence Churchill
Before joining the Pension Protection Fund, Lawrence Churchill
was chief executive of Zurich Financial Services, UK Irish and
International Life from 2002-04. Prior to this appointment he
was chairman and managing director of UNUM Ltd, the UK arm of
UNUM Provident Inc, the world's largest disability insurer. Between
1991 and 1998 Lawrence was working for Nat West Bank. He joined
initially to set up Nat West Life Assurance Ltd and his responsibilities
were expanded in 1995 by the addition of Nat West's regulated
sales force and its stockbroking and portfolio management business
Chief Executive—Myra Kinghorn
Before taking on the role of chief executive of the Pension
Protection Fund, Myra Kinghorn was a non-executive director of
the Serious Fraud Office and a member of the board of the Occupational
Pensions Regulatory Authority. Myra has a wide range of experience
working within the pensions and financial services environment
with a focus on investor protection. She was chief executive of
the Investors Compensation Scheme for over 11 years from its inception.
Non-executive members
Ian Abrams
Since April 2003, Ian Abrams has been a non-executive director
of Mizuho International plc, chairman of Theta Enhanced Asset
Management Ltd and a member of the Financial Services and Markets
Tribunal. Prior to this Ian was managing director of Mizuho International
plc where he was responsible for all activities in debt and equity
markets, derivatives and treasury.
Mark Baker CBE
Mark Baker was formerly chairman of Magnox Electric plc.
He has been chairman of Electricity Pensions Ltd since 1996 and
has been actively involved with the management and evolution of
the Electricity Supply Pension Scheme since 1989. He was deputy
independent chairman of the Police Negotiating Board from 2000
to 2005 and is a member of the Senior Salaries Review Body.
Michael Deakin
Since October 2003 Michael Deakin has been director and founder
of Michael Deakin Consultancy Limited. He was also appointed as
a non-executive director of Manifest Information Services Ltd
in April 2004. Prior to this Michael was chief investment officer
and an executive director of Insight Investment (formerly Clerical
Medical Investment Group) where he controlled over £65 billion
of assets and managed and built a team of 150 investment professionals
covering equity, fixed income and property fund management. He
is currently the chairman of the trustees of the London Pension
fund Authority.
Jeannie Drake OBE
Since 1995, Jeannie Drake has been a deputy general secretary
of the Communications Workers Union. Prior to this, she was deputy
general secretary of the National Communication Union. Jeannie's
current portfolio career includes membership of the board of the
Occupational Pensions Regulatory Authority, the Sectors Skills
Development Agency, the Equal Opportunities Commission, the Pensions
Commission and membership of the Employment Appeal Tribunal. She
has recently completed her term as president of the TUC.
Christopher Hughes
Christopher Hughes is head of international at the solicitors'
practice of Wragge & Co LLP, of which he was formerly the
managing partner. Christopher has also been a board member of
Severn Trent Water Authority and the chairman of Newman Tonks
Group plc, a manufacturer and distributor of industrial and domestic
hardware.
Executive members
Partha Dasgupta
Partha Dasgupta is director of investment and finance and
has responsibility for directing and overseeing the investments,
finances and levy arrangements of the Pension Protection Fund.
Prior to taking on his current role, Partha was managing director
at Barclays Global Investors, responsible for the European Fixed
Income and ALM business (representing £50 billion in assets
under management). During his 10 years at Barclays Global Investors,
Partha held a number of roles encompassing fixed income, equity
and derivatives. Partha started his career in 1991 at Prudential
as a valuation analyst.
Alan Duncan
Alan Duncan is director of operations. Alan started his career
in 1977 with Coopers and Lybrand. In 1984 Alan joined Fidelity
Investments, undertaking a series of international roles—from
financial controller in Bermuda, to director of finance in Australia
& Europe, to vice-president for Pensions, Finance & Operations
in Canada and finally to vice-president for Business Development
& Strategic Planning. Alan left Fidelity Investments in 2002
to take up the position of director of operations at INVESCO Pensions
Limited.
Appendix B
SCHEMES GOING THROUGH AN ASSESSMENT PERIOD AS AT 28 FEBRUARY
2006
— MG Rover Contract Related Pension scheme
— Padiham Retirement Benefits Plan
— Bristol Community Sport Limited Retirement and
Death Benefits Scheme
— Pattern Equipment Company Limited Pension &
Life Assurance Scheme
— Bloxwich Engineering limited (1978) Retirement
Benefits Scheme
— John Millar & Sons (1844) Limited Retirement
& Death Benefits Scheme
— Unifi Dyed Yarns Limited Pension Scheme
— AIPS Clean Brite Pension & Life Assurance
Scheme
— Motor Industry Pension Plan (PMEL section)
— The Heath Lambert Group Pension Scheme
— The Lambert Fenchurch Staff Pension Scheme
— Morgan Insurance Brokers Limited RBS
— Chilton Scotland Pension scheme
— Beaujersey Limited Retirement Benefits Scheme
— International Bottle Company Limited Pension and
Life Assurance Scheme
— Akzo Nobel (CPS) Pension Scheme
— HHT Plc Retirement Benefits Scheme
— Solid State Logic Group Pension Scheme
— BDH Retirement Benefits Scheme
— Newton Derby Pension & Life Assurance Scheme
— North Eastern Farmers Limited Pension Plan
— Thermal Engineering Executive Pension Scheme
— Thermal Engineering Pension Scheme
— Holmes Group Retirement Benefits Scheme
— Collins & Aikman Automotive Systems (St Neots)
Pension Scheme
— W&J Pye limited Pension Fund
— Sheffield Forgemasters Pension Scheme
— The Wiggins Group Plc Retirement Life Assurance
& Disability Plan
— Waddie & Company Limited Pension & Life
Assurance Scheme
— MG Rover Group Pension Scheme
— MG Rover Group Senior Pension
— Instem Technologies Pension Scheme
— The Pearce Group Staff Pension Scheme
— Fiege Merlin Pension Scheme
— Moorland Poultry Pension Scheme
— Lionweld Kennedy Group Pension and Life Assurance
Scheme
— E Walters (Ludlow) Ltd Retirement Benefits Scheme
— Marlow Ropes Pension Scheme (Marlow Ropes Ltd)
— Marlow Ropes Pension Scheme (The Rope Company
Ltd)
— Tomkinsons Carpets Limited Pension Scheme
— SR Gent Ltd Pension Scheme
— SR Gent (International) Ltd Pension Scheme
— Drummond Parkland of England
— Marsden VanPlan Section
— Kemutec Group Pension & Benefit Scheme
— E Walters (Ludlow) Ltd Retirement Benefits Scheme
— Haden Staff Pension Scheme
— Walsall Print Group Pension Scheme
— Blacks Equipment Ltd Pension Scheme
— New Berners Pension Scheme
— JW Arrowsmith Pension & Life Assurance Scheme
| 
