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Barnett Waddingham
0333 11 11 222
There is a legal requirement in the Pensions Act 2004 ('the 2004 Act') that trustees of an occupational pension scheme establish and operate adequate internal controls.

The Pensions Regulator (TPR) has issued guidance on Internal Controls for Pension Schemes which is designed to complement and be read in conjunction with the Code of Practice on Internal Controls (Code of Practice No. 9 – Internal Controls (the Code) that came into force in November 2006.

Internal controls are described as systems, arrangements and procedures:

  • to be followed in the administration and management of the scheme;
  • for monitoring that administration and management process; and
  • to be followed for the safe custody and security of the assets of the scheme.

Purpose and outline scope of the audit

TPR has recently enhanced its focus on pension scheme governance as it sees this as a key factor in increasing the likelihood of good member outcomes.  The benefit of this audit will be to give the trustees reassurance that they have the appropriate internal controls in place and are compliant with legislation.  It will also highlight any areas where action may need to be taken to address any deficiencies or to enhance the governance structure in place.

  1. Internal controls (including risk register and business plans)
  2. Conflicts of interest
  3. Anti-bribery policy
  4. Member nominated trustee arrangements
  5. Delegation and adviser appointments
  6. Trustee knowledge and understanding
  7. Internal dispute resolution procedure
  8. Notifiable events
  9. Document signing authority and scheme payment limits
  10. Document storage, security, retrieval and accessibility

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