Embedding the General Code with BW CORE

When the trustee of a large UK defined benefit (DB) pension scheme wanted to move from a high-level gap analysis to a fully documented and practical Effective System of Governance (ESOG), they turned to Barnett Waddingham’s governance specialists, supported by our BW CORE system.

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By using BW CORE to bring together their governance calendar, risk register and existing practices – all aligned to The Pensions Regulator’s General Code – the trustee has strengthened oversight of operational, funding and investment risks and made future Own Risk Assessments (ORAs) significantly more straightforward.

The client

• Client: UK DB pension scheme
• Members: 10,000-20,000
• Assets: c. £0.5bn–£1.0bn 

The scheme had already carried out a high-level gap analysis against the General Code and had many of the required procedures and practices in place. However, these were not consistently documented or structured into a single, coherent ESOG, making it harder to demonstrate compliance and to prepare for the upcoming ORA requirement.

The governance challenge

The trustee’s objective was to turn good practice into a clear, well-evidenced governance framework that:

• Moved beyond a high-level review to a more detailed assessment of the General Code requirements.
• Captured existing practices and procedures in a proportionate policy framework.
• Put in place the building blocks for a repeatable ORA process.

Without a framework to link the governance calendar, risk register and day-to-day practices back to the General Code modules, there was a risk of fragmented documentation, duplicated effort and less effective oversight. The trustee wanted confidence that governance was robust, well-documented and scalable for future reviews.

Our approach

Using existing strengths

We started from the scheme’s existing gap analysis and governance materials, rather than beginning again from scratch. These were reviewed, rationalised and structured into a baseline view against the General Code.

Workshops with the trustee board were used to explore each area of the ESOG in turn. This helped to:

• Clarify how responsibilities were discharged.
• Identify where informal practices already existed.
• Decide which elements should be formalised in policy.

Bringing governance together in BW CORE

We used our BW CORE governance system as the central hub for all General Code-related activity, bringing together:

• ESOG documentation.
• The scheme’s risk register and tolerance ranges.
• The trustee’s governance calendar and forward plan.

This meant the trustee could see, in one place, how governance, risk and operational processes connected back to the General Code requirements.

Turning analysis into a live ESOG

A suite of template policies was then tailored to the size, nature and complexity of the scheme. This avoided a blank-page exercise and kept the focus on documentation that would genuinely support decision-making, rather than generating unnecessary paperwork.

Policies, controls and actions were captured within BW CORE, creating a single, visible record of how each relevant General Code expectation is met. Reporting from the system now gives the trustee meeting-ready summaries and action tracking, replacing earlier spreadsheet-based tools.

Outcomes for the scheme

A robust, visible ESOG

The project delivered a well-documented ESOG, covering the key areas of governance and risk. The trustee now has:

• Clear evidence of how the scheme meets General Code expectations.
• Direct links between risk management, operational processes and board oversight.
• A shared system that the whole board and its advisers can use and understand.

Stronger risk oversight and ORA readiness

By integrating the risk register, tolerance ranges and governance calendar, the trustee can more effectively assess operational, funding and investment risks. BW CORE now underpins preparation for the ORA, providing:

• Improved visibility of priority risks and controls.
• Targeted action tracking, so agreed improvements are implemented and monitored.
• A structured evidence base for ORA discussions and reporting.

More focused trustee meetings

BW CORE reporting provides concise dashboards and action summaries ahead of each meeting. Instead of working through multiple documents, the trustee can quickly see:

•    Where controls are operating effectively.

•    Where additional mitigation or documentation is needed.

•    How governance and risk actions are progressing over time.

This keeps board time focused on the most important issues.

Future-proofed governance

Because the scheme’s ESOG, risk register and governance calendar are now held in an online system, updates and regulatory developments can be reflected quickly and consistently. This reduces the administrative burden on the trustee and helps ensure the governance framework keeps pace with future changes.

Client perspective

The Independent Trustee Chair said: “The scheme has utilised the BW CORE system to ensure that it meets the requirements of the General Code of Practice.

"By doing so, the scheme now has a robust and well-documented governance structure in place. This has allowed the trustee to better assess the operational, funding and investment risks, resulting in a more resilient and well-run scheme.”

How we can help other schemes

For many schemes, the requirement to build and document an ESOG under the General Code can feel daunting. This case study shows how a structured approach, supported by BW CORE, can turn existing good practice into a clear, joined-up governance framework.

Whether you are at the start of your General Code journey or refining current arrangements, our Pension Management team can help you:

• Bring your ESOG, risk register and governance calendar together in one place.
• Evidence compliance with the General Code in a clear, proportionate way.
• Prepare for the ORA with confidence, using robust, repeatable processes.

Find out more about our BW CORE governance system.