STEP Seven
Review
The Board of Trustees should review implementation of the IPS and other related policies on an annual basis.
The review process should refer to the pension fund’s overall Action Plan/Roadmap established in Step 2 - Setting Targets.
Step 7
Introduction
The Board of Trustees should review implementation of the IPS and other related policies on an annual basis as part of an iterative process that aims for continuous improvement.
The review process should refer to the pension fund’s overall Action Plan/Roadmap established in Step 2 – Setting Targets.
What Does The Regulation Say?
The FSCA Guidance Notice, paragraph 4.1(b) states that pension funds should reflect in the IPS how often it will be reviewed.
Paragraph 6.2(b) recommends that funds disclose any significant changes in its investment policy statement during the reporting period in its annual reports.
Review
While reviewing implementation should occur annually, review of the content of the IPS and other policies (if they are separate) may be revised every two to five years depending on the asset owner’s requirements and available resources.
The review process should include an evaluation of whether:
- The IPS has been complied with
- Implementation of the IPS has been effective
- The context for the IPS has changed
- The IPS remains relevant and up to date
The review process can be delegated to fund employees, Principal Officer or investment consultant, but the Board should maintain oversight of the process.
Information on the overall review process should be included in the annual reports.
Specific information on the IPS review should be provided, including any changes that were made in the reporting period.