DMGT Pensions application of the FRC Stewardship Code 2010
DMGT Pensions˙ policy is to apply the Stewardship Code through its contracts with trustee-appointed external investment managers and through its membership of the NAPF.
DMGT Pensions is not authorised by the FSA to make direct investments on behalf of the pension schemes of DMGT. Therefore the discharge of stewardship responsibilities is delegated to the external investment managers.
DMGT Pensions will regularly review the statements of application of the Stewardship Code made by the external investment managers. Their implementation of the code will be reviewed during regular DMGT Pensions˙ performance monitoring meetings.
DMGT Pensions is not authorised by the FSA to make direct investments on behalf of the pension schemes of DMGT. Therefore the discharge of stewardship responsibilities is delegated to the external investment managers.
DMGT Pensions will regularly review the statements of application of the Stewardship Code made by the external investment managers. Their implementation of the code will be reviewed during regular DMGT Pensions˙ performance monitoring meetings.
DMGT Pensions has clear policies which address the identification, management and disclosure of conflicts of interest that may arise for trustees and employees when making decisions for the DMGT pension schemes.
DMGT Pensions encourages the external investment managers to have effective policies addressing potential conflicts of interest in matters of stewardship. These will be reviewed during regular DMGT Pensions˙ performance monitoring meetings.
DMGT Pensions encourages the external investment managers to have effective policies addressing potential conflicts of interest in matters of stewardship. These will be reviewed during regular DMGT Pensions˙ performance monitoring meetings.
DMGT Pensions is not authorized by the FSA to make direct investments on behalf of the pension schemes of DMGT. Day-to-day responsibility for the management of the pension schemes˙ equity holdings is delegated to the trustee-appointed external investment managers. DMGT Pensions expects them to monitor companies, intervene where necessary, and to report back regularly on activity undertaken.
As stated in Principle 3, responsibility for day-to-day interaction with companies is delegated to the appointed external investment managers, including the escalation of engagement when necessary. DMGT Pensions expects that the external managers˙ guidelines for such activities are disclosed in their own statements of adherence to the Stewardship Code.
DMGT Pensions supports the work of the NAPF on corporate governance and would only normally expect to be involved in collective engagement via the NAPF.
Voting activity is delegated to trustee-appointed external investment managers.
DMGT Pensions requires all of the appointed external investment managers to report regularly and disclose all voting activity undertaken on behalf of the DMGT pension schemes.
Summary voting information is supplied to the trustees and reviewed by them in the context of the wider governance environment. Public disclosure of aggregate voting records for the schemes presents significant practical problems, due to the use of numerous external investment managers and the absence of a suitable means of publishing such data.
DMGT Pensions requires all of the appointed external investment managers to report regularly and disclose all voting activity undertaken on behalf of the DMGT pension schemes.
Summary voting information is supplied to the trustees and reviewed by them in the context of the wider governance environment. Public disclosure of aggregate voting records for the schemes presents significant practical problems, due to the use of numerous external investment managers and the absence of a suitable means of publishing such data.
DMGT Pensions will provide the pension scheme trustees with regular reports on the stewardship and voting activities undertaken by the external investment managers. It is not DMGT Pensions˙ current intention to seek an independent audit opinion on its stewardship activities.
DMGT Pensions believes that the use of AAF01/06 or SAS 70 reports can provide a useful independent audit of the engagement and voting processes of the external investment managers, although it should be noted that they provide no assurance as to the effectiveness of a firm˙s stewardship of its client˙s investments. Such reports are requested from the external investment managers and are used as part of DMGT Pensions˙ regular performance monitoring meetings.
DMGT Pensions believes that the use of AAF01/06 or SAS 70 reports can provide a useful independent audit of the engagement and voting processes of the external investment managers, although it should be noted that they provide no assurance as to the effectiveness of a firm˙s stewardship of its client˙s investments. Such reports are requested from the external investment managers and are used as part of DMGT Pensions˙ regular performance monitoring meetings.