Standard Life Master Trust Co. Ltd

AAF 02/07 Assurance Report Internal controls for Standard Life Master Trust Schemes Report as at 31 December 2015

Contents 1. Introduction

3

2. Report of the Board of Standard Life Master Trust Co. Ltd

7

3. Report by reporting accountant

9

4. Control objectives and procedures

12

4.1 SAFETY OF ASSETS & RECORDS

13



4.1.1

Commercial & Business Risks

13



4.1.2

Business & Disaster Recovery

14



4.1.3

Data Quality & Security

15



4.1.4

Protection of assets

18

4.2 ASSESSING VALUE

20



4.2.1

Assessment of Value for Money

20



4.2.2

Communication of costs and charges

20

4.3 ASSESSMENT OF INVESTMENT OPTIONS

23



4.3.1

23



4.3.2 Appropriateness of the other investment options (i.e., non-default strategy investment options)

24



4.3.3

25

Appropriateness of the default strategies

Identification of investment objectives and assessment against them

4.4 PEOPLE

26



4.4.1

Conflicts of interest

26



4.4.2

Fit and proper trustees

26

4.5 GOVERNANCE

28



4.5.1

Resource planning

28



4.5.2

Scheme Management

28



4.5.3

Internal control framework

29



4.5.4

Core scheme transactions

30



4.5.5

Receipt of contributions

31



4.5.6

Retirement process

32

4.5.7 Communications

33

Appendix – Letter of Engagement

35

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1.

Introduction

The Directors (the Board) of Standard Life Master Trust Co Ltd (SLMTC) is pleased to present its report detailing the control procedures that are in place relating to the Standard Life DC Master Trust scheme and the Standard Life Stanplan A scheme (the “Mastertrust schemes”).

This report provides information and assurance on the design and description of governance and administrative control procedures in relation to the business operations of Standard Life Master Trust Co. Ltd for providing pensions trustee services.

The Board has adopted the framework provided by the Audit and Assurance faculty of the Institute of Chartered Accountants in England and Wales entitled Assurance Reporting On Master Trusts (Master Trust Supplement to ICAEW AAF 02/07), referred to hereafter as “The Master Trust Supplement to AAF 02/07”.

This report is at a point in time, dated 31 December 2015 in accordance with the Master Trust Supplement to AAF 02/07.

Standard Life Master Trust Co. Ltd Structure Standard Life Master Trust Co. Ltd (SLMTC)*

PTL (Chair) Richard Butcher Director

Francois Barker Director

Stella Girvin Director

Master Trust Schemes

DC Master Trust

Poisson Management Limited Director

Ruston Smith Director

Standard Life (Representatives as required)

Stanplan A

*Standard Life Master Trust Co. Ltd is a subsidiary of Standard Life Assurance Limited

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About the Board The trustee company (SLMTC), effective from April 2015, is managed by five independent directors; Pitmans Trustees Limited (PTL) has been appointed as a director of SLTMC and chair of the Board of directors. Pension secretarial services are provided to the Trustee by PTL. Standard Life provide company secretarial services to the SLMTC. PTL is a specialist and award winning Independent Pensions Trustee company. Its team delivers expert pensions governance advice to businesses across the UK. Richard Butcher is managing director of PTL, the trustee of Standard Life’s DC Master Trust scheme since its launch in 2012 and Stanplan A following changes in the composition of the previous Trustee board. Richard has worked in the pensions industry since 1985 for a variety of companies and is a trustee to a number of both DB and DC pension schemes. He is Chair of the Pension and Lifetime Savings Association (PLSA) DC Council and sits as a non-executive director on the PLSA Board, as well as being a fellow of the Pensions Management Institute and a member of the PMI Council. Richard acts as governor to several contract-based pension plans and as a pension scheme secretary. Before joining PTL in 2008, he ran his own independent trustee and consultancy business. Francois Barker is a partner and Head of Pensions at Eversheds LLP, where he leads pension advisory client work and the strategic development of the pensions practice. He has been involved in the pensions industry since 1995, working with trustees and employers on the full range of pensions issues. He is actively involved in the development of pension’s law, policy and strategy. Francois has been a member of the CBI’s Pensions Panel since 2000 and is an elected member of the PLSA’s DC Council.

Stella Girvin has worked in the pensions industry since 1982, covering a range of DB and DC schemes. At Mercer she headed up the Watford Office. At Travis Perkins Plc she qualified as a Company Secretary and held positions as Deputy Company Secretary and Head of Compliance and Standards in addition to leading the in house pension’s team from 2000 until leaving Travis Perkins in January 2015. During this period she was an active member of the CBI Pensions Panel. Travis Perkins Group Retirement Savings Plan, which forms part of the Master Trust, has around 18,000 members with assets of £100 million. In November 2015, Stella was appointed as a Client Director for Capital Cranfield Trustees.

René Poisson is an experienced pension fund trustee, a senior banking professional, and a lawyer by training. For 30 years he worked at JP Morgan in senior credit roles. His trustee experience includes both DB and DC trusteeships. Over the last 15 years he has been a trustee of JP Morgan’s London Office Retirement Plan and, latterly, chair of the Board and investment sub-committee of JP Morgan’s UK Pension Plan, one of the largest DC schemes in the UK. René also serves as Chairman of Standard Life’s Independent Governance Committee (IGC).

Ruston Smith has over 30 years’ experience in the pension industry and has extensive experience of pension fund governance and management of UK and International DB and DC schemes with members from over 350,000 to 1,000 – including as a Trustee. He is the Group Pensions, Reward, People Systems and Insurable Risk Director for Tesco where as CEO he also has responsibility for Tesco Pension Investment, the in house investment company that manages the £10bn of UK assets. He is also a former company secretary of a FTSE 250, has an MBA, is a Fellow of the Pensions Management Institute, a NED and immediate past Chairman of the National Association of Pension Funds, a Governor of the Pensions Policy Institute and a Director of GroceryAid.

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Standard Life Standard Life is responsible for a wide range of operational risks and has in place a framework of internal controls to manage and monitor these. They recognise that risk management and control are central to ensuring their processes and systems enable their people to deliver transactional excellence as part of everyday practice. The Management at Standard Life, who are engaged with SLMTC, maintains and develops this framework via clear ownership of processes and controls: ¬¬ Management of processes across operational boundaries and, where appropriate, with partners and suppliers; ¬¬ Leading the identification and analysis of risks at a functional and process level; ¬¬ Regular monitoring of process and people performance, including control self-assessment reviews; ¬¬ Implementation and monitoring of control actions to ensure that any ‘preventative’ or ‘detective’ steps strengthen the areas that need it.

The Standard Life Master Trusts Standard Life currently offers two defined contribution (DC) Master Trusts.

1. Stanplan A Stanplan A is a multi-employer occupational pension scheme similar to the more recently established Standard Life DC Master Trust. Each employer in the scheme has its own section within the master trust. The scheme was established by a declaration of trust and, therefore, the scheme is governed by a board of trustees. The current sole trustee of the scheme is Standard Life Master Trust Co Ltd, a corporate trustee with independent directors. The directors are independent from the scheme administrator and retain decision making powers, including the power to wind up the scheme or change administrators. A distinguishing feature of Stanplan A is the availability of With Profits; such investments offer valuable guarantees to the members of Stanplan A who hold them. Members of the Standard Life DC Master Trust do not have access to With Profits. No new schemes can be accepted into Stanplan A however new members can still join existing schemes.

2. T  he Standard Life DC Master Trust The Standard Life DC Master Trust is a multi-employer occupational pension scheme. Each employer in the scheme has its own section within the master trust. The scheme was established by trust deed and, therefore, the scheme is governed by a board of trustees. The current sole trustee of the scheme is Standard Life Master Trust Co Ltd, a corporate trustee with independent directors. The directors are independent from the scheme administrator and retain decision making powers, including the power to wind up the scheme or change administrators. Section 4 of this report describes the relevant control procedures for both the Master Trusts, referred to above, that satisfy the control objectives prescribed in The Master Trust Supplement to ICAEW AAF 02/07 (TECH 07/14AAF). Where control procedures vary for each Master Trust this is specifically highlighted.

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2.

 eport of R the Board of Standard Life Master Trust Co. Ltd

As the Board of Standard Life Master Trust Co. Ltd, we are responsible for the identification of control objectives relating to governance and administration in the operation of Stanplan A and the Standard Life DC Master Trust (the “Master Trusts”) and the design, implementation and operation of the control procedures to provide reasonable assurance that the control objectives are achieved. Those objectives are derived from the DC code of practice and DC regulatory guidance in force at the time of producing this report. In carrying out those responsibilities, we have regard not only to the interest of employers (who have entrusted their employees’ DC contributions to the Master Trusts, or are considering doing so) and members of the Master Trusts but also to the needs of the trust business and the general effectiveness and efficiency of the relevant operations. We have evaluated the effectiveness of the Master Trusts control procedures having regard to ICAEW’s Technical Release AAF 02/07 including its Master Trusts Supplement and the control objectives set out therein.

For the purposes of this assurance reporting exercise:¬¬ Control Objective 4 – The objective around ‘New business take ons are properly established in accordance with Master Trust’s rules and contractual arrangements’, is not relevant to Stanplan A and so has not been included – as it is closed and no new schemes can be accepted into Stanplan A. ¬¬ Control Objective 14 - Disclosure of information on costs and charges borne by members is provided to employers at the point of selection and is complete and accurate has been omitted for Stanplan A on the basis no new schemes can be accepted into Stanplan A and therefore this control objective is not relevant for Stanplan A. We set out in section 4 of this report a description of the relevant control procedures together with the related control objectives which operated as at 31 December 2015 to confirm that: (a) the report describes fairly the control procedures that relate to the control objectives referred to above which were in place as at 31 December 2015; and (b) the control procedures described were suitably designed such that there is reasonable assurance that the specified control objectives would be achieved if the described control procedures were complied with satisfactorily Trustee:

Date:

Signed on behalf of the Board of Standard Life Master Trust Co Ltd (SLMTC)

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3.

Report by reporting accountant

Reporting Accountant’s assurance report on the governance and administration control procedures of Master Trusts To the directors of Standard Life Master Trust Co Ltd (“the Board”) of Stanplan A and Standard Life DC Master Trust

Use of report Our report, subject to the permitted disclosures set out below, is made solely for the use of the Board of Stanplan A and Standard Life DC Master Trust, and solely for the purpose of reporting on the internal controls of Stanplan A and Standard Life DC Master Trust, in accordance with the terms of our engagement letter dated 22 May 2015 and attached in the Appendix. Our work has been undertaken so that we might report to the Board those matters that we have agreed to state to it in our report and for no other purpose. We permit the disclosure of our report, in full only, to verify to the recipient that a report by reporting accountants has been commissioned by the Board and issued in connection with the internal controls of Stanplan A and Standard Life DC Master Trust without assuming or accepting any responsibility or liability to the recipient on our part. To the fullest extent permitted by law, we do not and will not accept or assume responsibility to anyone other than the Board as a body for our work, for our report or the opinions we have formed.

Scope We have been engaged to report on the Board’s description and design of its governance and administration control procedures as at 31 December 2015.

Our responsibilities Our responsibility is to form an independent opinion, based on the work carried out in relation to the control procedures of Stanplan A and Standard Life DC Master Trust as described in section 4 of the Board’s report and report this to the Board. We conducted our engagement in accordance with International Standard on Assurance Engagements (ISAE) 3000 and with ICAEW Technical Release AAF 02/07 including its Master Trusts Supplement. ISAE 3000 and AAF 02/07 require, among other things, that we comply with ethical and other professional requirements. We planned and performed our procedures to obtain reasonable assurance about whether, in all material respects, the description is fairly presented and the control procedures were suitably designed. The criteria against which the control procedures were evaluated are the control objectives developed for Master Trusts as set out within the Master Trusts Supplement to AAF 02/07 and identified by the Board as control objectives to be applied for the purpose of governance and administration. The Board has explained in section 2 of its report why it considers control objectives 4 and 14 are not relevant to Stanplan A. Our work involved performing procedures to obtain evidence about the presentation of the Board’s description of the governance and administration control procedures and the design of those control procedures. Our procedures included assessing the risks that the description is not fairly presented, and that the controls procedures were not suitably designed. An assurance engagement of this type also included evaluating the overall presentation of the description and the suitability of the control objectives stated therein.

Board’s responsibilities The Board’s responsibilities and assertions are set out in section 2 of the Board’s report. The control objectives stated in the description include those control objectives set out in the Master Trusts Supplement to AAF 02/07 that are considered relevant by the Board.

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Inherent limitations

Opinion

The Board’s description of control procedures was prepared to meet the common needs of a broad range of users and may not, therefore, include every aspect of control procedures that may be relevant to each employer company or member of Stanplan A and Standard Life DC Master Trust. Also, because of their nature, control procedures may not prevent or detect and correct all errors or omissions in performing governance or administration activities.

In our opinion, in all material respects:

Our opinion is based on historical information. The projection of any evaluation of the fairness of the presentation of the description, or opinion about the suitability of the design or operating effectiveness of the control procedures to future periods would be inappropriate.

(i) section 4 of the Board’s report fairly presents the control procedures that relate to the control objectives referred to above which were in place as at 31 December 2015; and (ii) the control procedures described in section 4 of the Board’s report were suitably designed to provide reasonable, but not absolute, assurance that the specified control objectives would have been achieved if the described control procedures were complied with satisfactorily.

Crowe Clark Whitehill LLP Chartered accountants London Date:

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4.

Control objectives and procedures

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4.1 S  afety of Assets & Records 4.1.1 Commercial & Business Risks 1. Discontinuance plans, which address how member assets or entitlements are safeguarded in the event of the Master Trust or any key service provider failing, are documented, approved and maintained.

In the event that SLAL or the Prudential were to become unable to meet its claims, the Board would be able to claim compensation under the FSCS on behalf of scheme members. The level of cover for long term contracts of insurance is now 100% (it was 90% until July 2015).

Response

The governing principles of the Master Trust schemes are set out in the trust deeds (or declaration of trust as appropriate) and scheme rules. These rules contain provisions which govern any decision to wind up the scheme(s) by the Board and describe the process for the distribution of any assets and funds.

¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A

The Board reviews the position of the scheme’s investments at its quarterly board meetings.

The Standard Life DC Master Trust and Stanplan A are wholly-insured schemes invested in long term unitised investment-linked funds via a long term contract of insurance issued by SLAL. The Board, having taken advice, is satisfied that the range of investment options is suitably diverse. The Board also holds a paid up With Profits insurance policy issued by the Prudential Assurance Company Limited (the “Prudential”) in relation to one section of the Standard Life DC Master Trust.

Some members of Stanplan A benefit from guarantees in relation to With Profits investments. These guarantees are provided by SLAL rather than the SLMTC.

The Board has produced a Discontinuance Plan that applies to both the Master Trusts. This was tabled by the Board on 2 December 2015 and noted along with the action to continue to develop the plan throughout 2016, once the plan has been finalised it will be adopted fully by the Board. The discontinuance plan is scheduled to be reviewed by the Board at the December 2016 meeting as part of the ongoing review exercise to ensure it remains relevant. The Discontinuance Plan addresses certain actions the Board may need to take and considers how member entitlements are likely to be protected in the event that:-

SLMTC itself does not trade and does not hold any assets other than in its capacity as pension scheme trustee. However, the trust deeds of the Standard Life DC Master Trust and Stanplan A contain an indemnity whereby SLAL indemnifies the Trustee and the directors for any costs, charges, damages, expenses, losses, penalties or taxes incurred in connection with the plan for so long as the plan is a wholly insured scheme with SLAL as the relevant assurance company. The Discontinuance Plan is subject to annual review and has been added to the Master Trusts rolling ‘Scheme Calendar’. The Scheme Calendar documents key rolling agenda items and provides the Board with a rolling agenda of governance matters for discussion and approval. The Discontinuance Plan is scheduled to be reviewed by the Board on an annual basis.

¬¬ SLAL becomes insolvent ¬¬ SLAL withdraws from the pension market or ceases to offer either of the Master Trusts ¬¬ The Board decide to move the Scheme to another provider or scheme administrator ¬¬ The Board decide to wind up either of the Master Trusts ¬¬ Changes to the law make the Master Trusts untenable

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4.1.2 Business & Disaster Recovery 2. Data and systems are backed up regularly, retained off site and regularly tested for recoverability. Business and information systems recovery plans are documented, approved, tested and maintained.

¬¬ The SLAL Business Continuity Plan (BCP) was circulated to the Board for review and was noted by the Board at their meeting in December 2015. The BCP is scheduled to be reviewed by the Board at the December 2016 meeting as part of the ongoing review exercise to ensure it remains relevant.

Response

SLAL control procedures relating to the integrity and availability of client data and processing interruptions are considered in SLAL’s annual Pension Internal Control Statement, including procedures addressing data and systems backup, for example:-

¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A

¬¬ All production data is held on computer disk and mirrored between the two data centres.

Business recovery plans are incorporated within the SLAL business continuity framework. Controls currently in place area as follows:

¬¬ Monitoring of the successful completion of back-up routines is carried out daily.

¬¬ There are standards for the creation, review and updating of BCP’s. ¬¬ SLAL’s BC framework has clearly defined roles and responsibilities. ¬¬ SLAL’s framework is populated by staff who understand their processes and are able to populate plans with meaningful content. ¬¬ SLAL provide regular forums and consistent training for role holders which educate them on the importance of business continuity, their role and responsibilities. ¬¬ SLAL have a system (BCMS) and documented processes for the creation, storage and updating of BCP’s. ¬¬ The BCMS system has automated alerting which notifies plan reps when plans and testing dates are becoming due or are due and plan owners when they are overdue. ¬¬ SLAL Directors perform a sign-off of their areas recovery numbers. ¬¬ SLAL BC framework provides oversight at all levels with a hierarchy of role holders and stakeholders:

– Security & Resilience – Function Directors – BC Coordinators – BC Plan Owners – BC Plan Reps

¬¬ Quarterly scorecards are produced which detail compliance to minimum standards and an overall assessment of compliance/capability. ¬¬ Quarterly policy returns are completed by business areas which detail their compliance to minimum standards.

This Statement was reviewed by the Board on 2 December 2015. The next Statement will be presented to the Board in Q2 2016 in order to provide further detail in relation to IT and administrative controls addressed by the Statement that are relevant to this and other control objectives considered in this report. At the Board meeting on 2 December 2015 an action was agreed for SLAL to present a paper to the Board, on an annual basis, on its IT controls including those related to data and systems back up procedures. The paper will provide the Board with confidence that the controls currently in place are appropriate for Master Trusts. This is scheduled for the Q2 2016 Board meeting.

3. The capacity of an administration system to take on new business is assessed, approved and regularly monitored.

Response ¬¬ Control Objective principally applicable to Standard Life DC Master Trust as no new schemes are set up for Stanplan A Stanplan A is closed to new schemes, new members can still join existing schemes, and as a result overall membership of Stanplan A is gradually reducing. It is administered on a legacy administration platform; there haven’t been any recorded concerns of capacity challenges for Stanplan A. The Master Trust products are currently serviced through SLAL’s LPAS (Life and Pension Administration Platform). This platform is the strategic platform for Standard Life products and was developed in 2010. The LPAS platform was built to accommodate a large volume of business; the intention is that all modern pension products will be administered on this platform.

¬¬ On an annual basis SLAL review the contents of 100% of their critical BCP’s.

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As agreed at the Board meeting on 2 December 2015 as part of the quarterly submission of administration reporting to the Board, information is supplied in relation to matters relating to capacity, e.g. participating employers joining or leaving the scheme. This will commence from the Q1 Board meeting and at quarterly meeting thereafter.

4. New business take-ons are properly established in accordance with Master Trust’s rules and contractual arrangements.

Response ¬¬ Control Objective only applicable to Standard Life DC Master Trust as no new schemes are set up for Stanplan A Employers who join the Master Trust are required to complete and sign a Participation Agreement which sets out the responsibilities of the employer. SLAL will process any new take-ons in line with the Trust Deed and General Rules as well as the Special Rules that may be applicable. SLAL’s Pension Internal Control Statement, which was noted by the Board at the meeting in December 2015, provides details as to how this is achieved including details about the systems used to manage new take-ons, validation and quality assurance controls. Joining is a fully automated process with joining information being submitted via a secure online user interface – GroupPensionZone (GPZ). Validation exists within the online joining system to ensure that all new business complies with Master Trust rules. This validation is built into GPZ to ensure that SLAL receives all mandatory data items. The data is then validated against the rules (e.g. Default retirement age, Qualifying Workplace Pension Scheme, contribution structure, including default investment instruction, payment method & frequency and scheme/ employer preferences) which are recorded on SLAL’s administration platforms. Where a new scheme is implemented within the Master Trust, the Board are made aware during the quarterly Board meeting. If there are any significant new entrants then the Board will generally be made aware in advance of the meeting. SLAL control procedures relating to whether new members are properly set up according to scheme rules, policy documentation and individual elections are considered in SLAL’s annual Pension Internal Control Statement (page 14). This Statement was reviewed by the Board on 2 December 2015. The next Statement will be presented to the Board in Q2 2016 in order to provide a further detail to the Board in relation to IT and administrative controls addressed by the Statement that are relevant to this and other control objectives considered in this report.

At the Board meeting on 2 December 2015 an action was agreed for SLAL to present a paper addressing various aspects of scheme administration, managed through GPZ. This will include SLAL control procedures relating to the on boarding process and how the system ensures that the uploading of member data and ongoing administration system ensures alignment with the Deeds of Participations and other constitutional documentation. The paper will provide the Board with confidence that the controls currently in place are appropriate for Master Trusts. This is noted in the Boards business plan and is scheduled for the Q3 2016 Board meeting.

4.1.3 Data Quality & Security 5. Member data is complete and accurate and is subject to regular data evaluation. Data transmissions are secure and appropriate measures are implemented to counter the threat from malicious electronic attack.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A Master Trust records are tested for the existence of common data. Each time the scoring is run the output is reviewed by SLAL’s Customer Operations Technical team, any issues are fully investigated and where necessary data obtained/cleaned. The results of this exercise are scheduled to be provided to the Board on an annual basis. The Standard Life DC Master Trust scores were reviewed at the Board meeting on 2 December 2015 and the Stanplan A scores have been produced and will be reviewed at the Q1 2016 Board meeting. SLAL control procedures relating to whether member records consist of up to date and accurate information are documented in SLAL’s annual Pension Internal Control Statement. In particular:¬¬ Members’ records (including financial) are set up and altered in accordance with documented procedures. ¬¬ The quality assurance framework gives assurance that member records are accurately updated in line with client requests. This Statement was reviewed by the Board on 2 December 2015. The next Statement will be presented to the Board in Q2 2016 in order to provide a further detail to the Board in relation to IT and administrative controls addressed by the Statement that are relevant to this and other control objectives considered in this report.

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At the Board meeting on 2 December 2015 an action was agreed for SLAL to present a paper to the Board, on an annual basis, on its IT controls. The paper will provide the Board with confidence that the controls currently in place are appropriate for Master Trusts. This is scheduled for the Q2 2016 Board meeting and will include SLAL’s Protection of Information and Resilience policy (PIR) which covers information security, physical security and business continuity; it also includes data protection and records management. This policy, in combination with SLAL’s sub policies of their Group Operational Risk Framework, provides a clear structure for an effective internal control system to manage risks to the confidentiality, integrity and availability of information. The policy covers information held, processed and transmitted in electronic form. This policy requires SLAL’s business units to: ¬¬ Have an organisational framework for protection of information and resilience ¬¬ Comply with all legal and regulatory requirements for the protection of information and resilience including managing records and complying with data protection legislation ¬¬ Identify, understand and manage information and resilience risks and non-compliance with policy, controls and standards ¬¬ Identify, understand and manage their control environment including

– Incident management – Security of staff – Secure systems development and delivery – Access to information and systems – Business continuity management

Policy owners within each SLAL business unit are responsible for implementation and compliance with the PIR policy. They direct the Policy Implementation Managers who are responsible for the day to day implementation and controls and also monitor compliance with the policy. SLAL’s Director of Information & Technology Strategy, as Group Policy Owner for the PIR policy, maintains oversight of activities and compliance within all SLAL business units. Malware protection is run on all desktops, servers (Windows and Linux), browser and email proxies. SLAL also use software to block known malware sites and block certain attachment types e.g. exes. There is an ongoing education program advising users not to click on links from untrusted sources.

SLAL encrypt any sensitive data they need to transmit. They have a range of controls in place to prevent unauthorised data disclosure the key aspects being: ¬¬ Two layer firewall model in place, supplemented by a managed intrusion prevention system, ¬¬ Web applications firewall in blocking mode, ¬¬ Static code analysis and ¬¬ Penetration testing.

6. Physical and logical access to computer systems, and member and Master Trust records and data, is restricted to authorised persons.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A SLAL control procedures relating to whether access to client and corporate information is restricted to authorised internal or third parties (i.e. Logical and Physical Access controls) are considered in SLAL’s annual Pension Internal Control Statement. This Statement was reviewed by the Board on 2 December 2015. The next Statement will be presented to the Board in Q2 2016 in order to provide a further detail to the Board in relation to IT controls addressed by the Statement that are relevant to this and other control objectives considered in this report. At the Board meeting on 2 December 2015 an action was agreed for SLAL to present a paper to the Board, on an annual basis, on its IT controls. The paper will provide the Board with confidence that the controls currently in place are appropriate for Master Trusts. This is scheduled for the Q2 2016 Board meeting. Within SLAL access to various systems and transactions is controlled. A local systems administrator (LSA) has responsibility for maintaining and coordinating systems/ transaction access. A business justification must be provided for all requests for systems/transaction access and must be authorised by the user’s direct manager. SLAL’s physical security measures are designed to control access to and egress from SLAL’s premises and access to designated assets and materials. This includes but is not limited to: information, records, physical assets and Information Communications Technology (ICT) which enable or support SLAL’s business operations and customer services.

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Premises access and egress – SLAL ensure that access to and from any of their premises and designated secure areas, including but not limited to areas accommodating ICT assets, within these premises are protected from unauthorised access: ¬¬ Perimeter and site security measures including but not limited to Intruder Detection Systems (IDS), Closed Circuit Television (CCTV), lighting and guarding. ¬¬ Building access security controls including but not limited to ID cards, physical and electronic assess mechanisms; CCTV, lighting and guarding. ¬¬ Opening and lockdown procedures. ¬¬ IT Network Security Services response ¬¬ SLAL employs physical access controls across all their buildings which is identity card based. These identity cards also limit access to sensitive areas such as machine halls and communication rooms for those staff who have valid reasons for such access. SLAL employs Role Based Access Control as a means to limit staff to only the resources necessary to perform their role. SLAL also employs logging and monitoring for access to sensitive data and functions and they have an automated movers, leavers and joiners process. High Security areas (e.g. server halls) are restricted to designated staff only. All server components are racked and located within SLAL’s datacentre and continuity sites. Access to computer rooms are limited to authorised staff via the swipe card system. All access is reviewed/granted in advance. All external contract staff/companies are required to submit the appropriate security and health and safety pre-requisites prior to being granted access to SLAL’s premises. Logical access to SLAL computer systems, programs, data and parameters is restricted to properly authorised individuals based on their role and responsibilities. Users are required to maintain complex passwords to access applications and SLAL operate a “forced” requirement for these to be changed periodically. Access for leavers is revoked on termination date or request from management, followed by removal of access to all systems and deletion of their user account.

7. IT equipment is maintained in a controlled environment and the maintenance and development of systems, applications and software is authorised, tested approved and implemented.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A All SLAL’s core IT Equipment is contained within specialist machine halls and communication rooms which are only available to authorised personnel. SLAL has a well-defined and developed approach and software is managed throughout its lifecycle. SLAL has defined standards for software testing and all new software is introduced via a comprehensive change management system. SLAL control procedures relating to whether the development of new IT, or changes to existing systems, do not compromise the confidentiality, integrity or availability of client data are considered in SLAL’s annual Pension Internal Control Statement. This Statement was reviewed by the Board on 2 December 2015. The next Statement will be presented to the Board in Q2 2016 in order to provide further detail to the Board in relation to IT controls addressed by the Statement that are relevant to this and other control objectives considered in this report. Changes to systems are recorded, including details of testing performed, back out plans, risk levels etc. These changes are submitted and approved by a different individual. SLAL has Change Advisory Boards for each business unit to understand the potential impact of changes and if necessary make changes to their Change schedule. SLAL also has a Global Change Board that has an overview of the complete change schedule.

SLAL’s System Development Life Cycle Each stage in the lifecycle requires the previous stages tasks to be completed and signed off as accepted or has action plans before proceeding to the next stage. For a move to production any outstanding actions require an action plan to be included in the change management request. System Development is analysed by Fortify (a tool designed to highlight any systems vulnerability), all high findings are resolved and medium findings are audited. SLAL’s internal standards are based on ISO27001.

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SLAL’s System Maintenance SLAL’s security patches management process currently pre assesses and tests patches released by vendors, e.g. Microsoft. Alerts on known vulnerabilities are issued to the platform owners through various channels. At the Board meeting on 2 December 2015 an action was agreed for SLAL to present a paper to the Board, on an annual basis, on its IT controls. The paper will provide the Board with confidence that the controls currently in place are appropriate for Master Trusts. This is scheduled for the Q2 2016 Board meeting and will include SLAL’s Physical Security and Environmental Control Statement which refers specifically to environmental controls procedures including power supply, electrical plant and cooling facilities, as well as control testing.

4.1.4 Protection of assets 8. Member assets or entitlements are safeguarded from loss, misappropriation and unauthorised use in accordance with a defined policy.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A SLAL control procedures relating to whether member and scheme data is appropriately stored to ensure security and protection from unauthorised access and whether payments and transfers of assets are suitably authorised and controlled are considered in SLAL’s annual Pension Internal Control Statement. This includes:¬¬ Strong authentication at application level is performed using complex passwords which have a “forced” requirement to be changed periodically. ¬¬ Segregation of duties requires the payment authoriser to be different from the person entering the payment details. ¬¬ Authorisation of payment or transfer follows delegated authority limits. This Statement was reviewed by the Board on 2 December 2015 and aspects of it are being considered in connection with the Discontuance Plan. The next Statement will be presented to the Board in Q2 2016, annually thereafter, in order to provide a further detail to the Board in relation to IT controls addressed by the Statement that are relevant to this and other control objectives considered in this report.

Any significant failures will be highlighted in SLAL’s quarterly risk board assessment and highlighted to the SLMTC Board via SLAL Risk and Group Internal Audit quarterly briefing report; this will be incorporated into the suite of MI that the Board currently review at their quarterly board meetings. This is scheduled to be delivered for the Q1 2016 Board meeting and quarterly meetings thereafter. The Standard Life DC Master Trust and Stanplan A are wholly-insured schemes invested in long term unitised investment-linked funds via a long term contract of insurance issued by SLAL. The Board is satisfied that the range of investment options is suitably diverse. SLMTC also holds a paid up With Profits insurance policy issued by the Prudential in relation to one section of the Standard Life DC Master Trust. Assets are not held in a trustee bank account. Contributions are paid directly to SLAL and benefits are paid directly by SLAL to members, their dependants or the receiving scheme in relation to transfers. Some fund managers of insured funds available to Master Trust members may look to get a better return by lending some of the assets to certain financial institutions. This practice, also known as Stock Lending, happens at fund level rather than product or member level. Neither the Board or SLAL have direct oversight of Stock Lending that is carried out by other fund managers, this is the responsibility of the underlying fund manager.

9. Cash is safeguarded and all payments are suitably authorised and controlled.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A SLAL does not accept or deal with cash in any aspect of their processes; all payments in and out must be made via SLAL’s bank account in the form of CHAPS, BACS, Direct Debit or cheque payments. SLAL control procedures relating to whether payments and transfers of assets are suitably authorised and controlled are considered in SLAL’s annual Pension Internal Control Statement (page 18). This includes:¬¬ Segregation of duties requires the payment authoriser to be different from the person entering the payment details. ¬¬ Authorisation of payment or transfer follows delegated authority limits. Payment authorisations operate within SLAL’s administration team and follow delegated authority limits. The delegated authorities have been formally approved by the Board at its quarterly meeting on 11 May 2015. At the Board meeting on 2 December 2015 an action was

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agreed for SLAL to present a paper addressing various aspects of scheme administration. This will include SLAL control procedures relating to payment authorisation mandates, attributable to authorised personnel as listed in the Delegated Authorities Document operated by SLAL. The paper will provide the Board with confidence that the controls currently in place are appropriate for Master Trusts. This is scheduled for the Q3 2016 Board meeting.

10. Financial protection available to members in the event of default is assessed and documented, and communicated to employers and members on request.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A In the event that SLAL or the Prudential were to become unable to meet its claims, the Board would be able to claim compensation under the FSCS on behalf of scheme members. The level of cover for long term contracts of insurance is now 100% (it was 90% until July 2015). Where the Board invests in an insured fund run by an insurance company other than SLAL the Board is not eligible for compensation under the FSCS if that firm is unable to meet its claims. SLAL is also not eligible to make a claim. However, SLAL has not passed on the risk of that other insurer’s default (the ‘reinsurance credit risk’) to the Board. Therefore, in the unlikely event of a default by such an insurance company, SLAL would be expected to stand behind the failed insurer, as per the FCA Conduct of Business rules 21.3. Member protection is reviewed on a triennial basis and is tracked through the Scheme Calendar. As part of the Master Trusts’ communications package, Standard Life offers a range of employer & member guides and websites. Both the guide and website contain information on the risks of investing in various asset classes, as well as the obligations of Standard Life and the safeguards put in place. The Master Trust guides and website also detail investor protection by signposting members to www.standardlife.co.uk/ investor-protection.

11. Investment decisions relating to the selection of investments on regulated markets and unregulated investments are researched, authorised and monitored.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A The Board place reliance on SLAL’s investment governance processes. Standard Life requires all funds to be fully regulated by the FCA. No unregulated funds are offered. The funds offered through the Master Trusts are insured funds and, as such, will be in line with Standard Life Investments’ (SLI’s) Permitted Investment Universe (PIU) and the exclusions to the PIU as defined by SLAL’s Unit Linked Actuary. These funds will then be run within their Investment Manager Agreement (IMA) and mandates by SLI (or other fund manager if the fund is an external fund link (EFL)). SLAL maintains detailed guidelines in relation to a new fund approval process which is completed prior to launching any new insured external fund links in the UK. This forms part of SLAL’s internal fund governance which was reviewed as part of the Boards induction day in April 2015. The Board obtains advice from an authorised and regulated adviser, currently Barnett Waddingham, in respect of all investment decisions, e.g. suitability of default funds, the Statement of Investment Principles. The only exception is in respect of bespoke investment solutions within specific sponsoring employers’ sections of the scheme. Where such a scenario exists an adviser is appointed to advise the Board on a case by case basis. When the new pension freedoms were introduced in April 2015 Barnett Waddingham undertook a review to ensure any changes to the defaults remained appropriate, the advice provided by Barnett Waddingham was discussed and reviewed at the Board meeting in 11 May 2015. Barnett Waddingham have confirmed that an in depth review of all funds available to the Master Trusts will be conducted in 2016. Reviews of all investment options are diarised in the Scheme Calendar to take place at least every three years and are considered formally at relevant Board meetings. ¬¬ The Statement of Investment Principles (SIP) is currently under review and will be presented to the Board in 2016. ¬¬ The “off the shelf” non-default fund range is scheduled to be reviewed in 2016 ¬¬ The “off the shelf” default strategies are scheduled to be reviewed in 2018

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4.2 Assessing Value 4.2.1 Assessment of Value for Money 12. A value for money review is undertaken and this review is documented, approved and findings actioned.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A Each year the Board will carry out a Good Value assessment. The outcome of the assessment will be reported in a Chair’s Annual Statement within seven months of the scheme year end. The project timeline for carrying out a review is built into the Board’s annual work programme and the Good Value assessment is expected to be concluded in Q3 2016. The Good Value assessment will consider the costs and charges (including to the extent that data is provided, investment transaction costs) deducted from members fund’s and compare them against the benefits delivered by the Firm. The benefits, in this context, include certain prescribed items (for example, the timeliness and accuracy of core financial transaction processing) and other items considered by the Board to be of value to the members. The process of the review will be recorded in the minutes of Board meetings. The Board have formally discussed good value and what it may mean for the Master Trusts. Discussions will continue to ensure that good value and what it means for members of the Master Trusts can be incorporated into the Chair’s annual statement. Any formal discussions between the Board and the Firm, in this context, will be recorded in meeting minutes and or by letter or email. The outcome of the assessment will be documented in the Chair’s annual statement. The Chair’s annual statement will be approved by the Board before publication. Any actions for the Board will be recorded in subsequent minutes and matters arising reports.

4.2.2 C  ommunication of costs and charges 13. A complete and accurate list of the types of costs and charges incurred by members and employers is documented, monitored and approved.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A The Board reviewed SLAL’s control procedures around fund governance at their induction meeting in April 2015, including procedures managing charges attributable to the full range of investments offered across the SLAL investment platform. This was noted again at the Board meeting in May 2015 and again in December 2015. Fund management charges and additional expenses are the principal costs incurred by members within the Master Trusts. The Investment Solutions team within SLAL are responsible for ensuring that these remain accurate. Any changes are made in line with an agreed process and all relevant systems updated to reflect the new charges/costs. A complete and accurate list of the investment options available to both the Standard Life DC Master Trust and Stanplan A, including FMC and additional expenses, will be provided to the Board in Q1 2016 as part of the quarterly MI that is provided to the Board by SLAL. All scheme or individual member discounts are controlled through a central database. The ability to amend/update the database is managed through a user’s role profile with business justification required before access is approved by the appropriate manager. Where member communications for DC Master Trust or Stanplan A contains information relating to charges or costs there is a process in place to ensure that the information is accurate and up to date. All content is checked against controlled sources of truth and evidence must be provided as part of the quality assuring. At the Board meeting on 2 December 2015 an action was agreed for SLAL to present a paper addressing various aspects of communication. This will include SLALs control procedures relating to producing accurate member material including the completeness and accuracy of costs disclosed for investments. The paper will provide the Board with confidence that the controls currently in place are appropriate for Master Trusts. This is scheduled for the Q3 2016 Board meeting.

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Transaction Costs There is an action on the Business Plan for the SLMTC Board for January 2016 to request transaction cost information. The Board anticipates that the details may not necessarily be forthcoming in time for the 2015 Chairman’s annual statement. This is because:Standard Life does not currently disclose transaction cost information for unit-linked funds (internal funds, external fund links and blended funds). Both Standard Life and Standard Life Investments have committed to progress the systems build required in order to be able to produce this information however they have taken the decision not to initiate this work until such times as more detailed requirements are available from either the FCA or DWP. These requirements are needed as there are a number of different approaches which could be taken to calculating the transaction costs, and on what is defined as being a transaction cost. SLAL provided a joint response to the FCA’s request for information earlier on in 2015 and understand that the FCA have indicated that their response to this exercise has been delayed and it will now be Q1 2016 at the earliest. As a result, SLAL will be unable to put in place the necessary processes to fully disclose transaction costs in line with regulatory requirements as it is estimated that it would be around a 12 month build from the point at which the detailed requirements became available. In the meantime, SLAL have produced some indicative figures for some transaction costs categories for a small subset of unit-linked funds that are used within default investment solutions and will be sharing this information with the Board. These figures have been produced using what SLAL believes to be a reasonable approach for each cost category. Without a standardised methodology it is, however, difficult to draw any firm conclusions from these figures and they remain subject to change once the requirements are agreed.

14. Disclosure of information on costs and charges borne by members is provided to employers at the point of selection and is complete and accurate.

Response ¬¬ Control Objective only applicable to Standard Life DC Master Trust as no new schemes are set up for Stanplan A A robust process is followed for all new business enquires received into SLAL. This helps to ensure that the information provided to the employer is complete and accurate. All enquires are tracked from the point they are received through to completion, during each stage it’s clear who has responsibility for the task and when it will be delivered; oversight of the process is provided by SLAL’s new business team. Where terms are offered for a new business enquiry all information will be sourced from the appropriate subject matter experts (SMEs). As a final control all Request for Proposals (RFP) that are issued have a final sign off from SLAL Compliance; in advance of sign off Compliance will check that all information provided is evidenced in the file. As part of SLAL’s Control Self-Assessment (CSA) each month the new business team sample enquiries to make sure that the process is being followed and that the correct information is being provided; evidence is retained to support this. When terms are offered for a new scheme the terms summary will be accompanied with a list of the costs and charges applicable for the investment options available to the members of the scheme. This information is sourced from the subject matter experts and evidence to support the communication provided. At the Board meeting on 2 December 2015 an action was agreed for SLAL to present a paper addressing various aspects of communication. This will include SLAL control procedures relating to communicating costs and charges to new schemes. The paper will provide the Board with confidence that the controls currently in place are appropriate for Master Trusts. This is scheduled for the Q3 2016 Board meeting.

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15. Disclosure of information to members of costs and charges (rates (%) and amounts (£)) are complete and accurate.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A All of SLAL’s Annual Statements adhere to Financial Conduct Authority (FCA) Conduct of Business 16.3 (COBS) rules around periodic reporting. SLAL’s Calculations Compliance (Proposition Operations) area meet regularly with the FCA to ensure the latest set of rules/controls are being met. Annual Statements are issued on a minimum annual basis, but can be requested by the member at any stage on an ad-hoc basis. SLAL’s Document Development Services (DDS) team are responsible for ensuring this information is presented to members in a fair, easy to understand and consistent manner. All DDS Document Specifications require full sign-off by Legal, Compliance and business representatives before development can commence. All development will then be rigorously tested prior to implementation into production to ensure it matches the signed-off document specification. Charges can be detailed by SLAL in either rate (%) or monetary (£) amounts. Generally if the charge is variable or measured against units, these are shown in % format; however the exact monetary amount can be supplied on requests by contacting SLAL (phone or mail) or transacting online. The formats in which the charges are shown are in line with standards set out by the Pensions Regulator and the FCA. All post sale documentation (e.g. fund guides, access to tools which disclose information relating to costs and charges) is produced in accordance with the documented process for customer collateral. At the Board meeting on 2 December 2015 an action was agreed for SLAL to present a paper addressing various aspects of scheme administration and communication. This will include SLAL control procedures relating to Members’ fund holdings are accurate and up to date. The paper will provide the Board with confidence that the controls currently in place are appropriate for Master Trusts. This is scheduled for the Q3 2016 Board meeting. As noted above in control objective 13, in relation to transaction costs, there is an action on the Business Plan for the SLMTC Board for January 2016 to request transaction cost information.

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4.3 Assessment Of Investment Options 4.3.1 Appropriateness of the default strategies 16. The design and on-going suitability of the default strategies is regularly reviewed and monitored. This review is documented and approved.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A The Board, in conjunction with an authorised, regulated investment adviser, regularly reviews the suitability of the funds, default solutions and the Statement of Investment Principles; the reviews cover all funds for both the DC Master Trust and Stanplan A. There are entries in the Board’s Scheme Calendar to carry out the review at least every three years. The “Off the Shelf” default strategies are scheduled to be reviewed in 2018 by the Board. Barnett Waddingham undertook a review of the default profiles for SLAL DC Master Trust in April 2015 taking into account the proposed changes as a result of the introduction of pension freedoms. The defaults for Stanplan A were also reviewed. Barnett Waddingham has also conducted a review of the default arrangements for Stanplan A; this was completed in March 2015. The next scheduled review is in April 2018. As part of SLAL’s governance process, noted at the May 2015 Board meeting, a review of the default strategies, including bespoke solutions is carried out each year, with the underlying components looked at quarterly. The quarterly reporting ensures that funds are identified that are not performing as intended. The SLAL board have the option to take action or retain a watch on the funds. In addition the Fund Alignment Review (FAR) process looks to ensure that all funds are aligned to customer expectations. This is all part of SLAL’s Proposition Management Process.

17. The performance of the default strategies and funds within the default strategies are regularly reviewed and monitored. This review is documented and approved.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A The Board request that their investment advisers, Barnett Waddingham, review the default strategies and available investment options at least every 3 years to ensure their continued suitability for members, as part of the Boards review of the default strategies. In addition the Board place reliance on SLAL’s investment governance process to ensure that investment options are performing as expected. SLAL produce quarterly investment performance information for the Board which contains information about the performance of the funds compared with the total return of the relevant benchmark index. SLAL provides fund performance data on the available investment options for the SL DC Master Trust and Stanplan A; this is included in the quarterly meeting packs that are distributed to the Board in advance of the meeting. The data is reviewed by the Board and if any areas of concern are identified the appropriate action is taken, e.g. request more detailed reports, request SLALs attendance at a Board meeting for face to face discussions, ask our investment advisers to carry out an independent analysis, etc. The Board are currently in discussions with SLAL to develop the investment governance performance monitoring data for the “Off the Shelf” default strategies that is provided for their quarterly meetings. The new format is scheduled for delivery at the Q1 2016 Board meeting and an action agreed with the Board that this will be reviewed at all quarterly meetings.

Reviews of the customised defaults also take place annually and can be evidenced through the Conduct Risk Reviews.

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4.3.2 Appropriateness of the other investment options (i.e., non-default strategy investment options) 18. The range and risk profile of other investment options are documented, approved and regularly reviewed for suitability. This review is documented.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A The Board, in conjunction with an authorised, regulated investment adviser, regularly reviews the suitability of the funds; the reviews cover all investment options for both the DC Master Trust and Stanplan A. There are entries in the Board’s business plan to carry out the review at least every three years. Barnett Waddingham has confirmed that they will undertake an in-depth review of investment options, including self-select funds in 2016. The Board have an entry on the Scheme Calendar to review this again in 2018. In addition the Board place reliance on SLAL’s investment governance process to ensure that investment options are performing as expected. SLAL carry out a Conduct Risk Review (CRR) on an annual basis for their full fund range. The review assesses the full range against the six outcomes of conduct risk to ensure it remains suitable for the intended customers. Conduct risk is an integral part of the operational risk framework. There is a separate conduct risk policy to bring additional focus to ensure that appropriate measures and procedures are put in place across Standard Life in relation to the fair treatment of customers. Conduct risk is assessed as part of the operational risk capital assessment process. SLAL business units must have in place documented procedures to ensure that reviews are performed for all existing customer propositions to monitor key risks, profitability and ability to meet customer needs. At the Board meeting on 2 December 2015 an action was agreed for SLAL to present a paper addressing various aspects of communications and governance. This will include SLAL control procedures relating to the risk profile of investment options available to members. The paper will provide the Board with confidence that the controls currently in place are appropriate for Master Trusts. This is scheduled for the Q3 2016 Board meeting.

19. The performance of other investments options is regularly reviewed against relevant investment objectives and (where available) industry benchmarks. This review is documented and approved.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A The Board, in conjunction with an authorised, regulated investment adviser, regularly reviews the suitability of the funds, default solutions and the Statement of Investment Principles; the reviews cover all funds for both the DC Master Trust and Stanplan A. There are entries in the Board’s business plan to carry out the review at least every three years. The next review is scheduled for April 2018. In addition the Board place reliance on SLAL’s investment governance process to ensure that investment options are performing as expected. SLAL provides fund performance data on the available investment options for the SL DC Master Trust and Stanplan A; this is included in the quarterly meeting packs that are distributed to the Board in advance of the meeting. The data is reviewed by the Board and if any areas of concern are identified the appropriate action is taken, e.g. request more detailed reports, request SLALs attendance at a Board meeting for face to face discussions, ask our investment advisers to carry out an independent analysis, etc. The Board are currently in discussions with SLAL to develop the investment governance performance monitoring data for the “Non-Default” fund range that is provided for their quarterly meetings. The new format is scheduled for delivery at the Q1 2016 board meeting and an action agreed with the board that this will be reviewed at all quarterly Board meetings. The full SLAL fund range is reviewed as part of the Fund Alignment Review (FAR) and the Fund Analysis Review processes. The FAR process is a key component of the SLAL Investment Proposition Governance focus area, which itself is part of the Investment Solutions Forum (ISF) policy framework. The objective of the FAR process is to ensure the alignment of customer expectations with likely outcomes and is intended to mitigate potential business and reputational risks that may arise from any misalignment between customer expectations and the fund management process. The Fund Analysis Review process looks to ensure that funds are performing in line with their objectives (including benchmarks, volatility and assets). All funds are assigned a status (RAG) to identify how it is performing – Red (Issue raised), Amber (Under investigation) or Green (No concerns).

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4.3.3 Identification of investment objectives and assessment against them

21. A Statement of Investment Principles (SIP) is documented, approved and regularly reviewed.

20. A complete and accurate description of all investment options is maintained and approved.

¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A The Board place reliance on SLAL’s investment governance processes. As part of their procedures SLAL maintains a central database of all their pension funds which includes a full description of each fund. A new entry or a change to an existing entry needs to go through a rigorous sign off process. This is maintained as part of SLAL’s investment governance processes which the Board place reliance on and were provided an overview of at their induction day. The central database is used as a ‘single source of the truth’ by SLAL’s marketing function with regard to fund descriptions and when documentation is produced with fund descriptions this is required to be signed off by an appropriate fund expert.

Response A SIP was produced for the Standard Life DC Master Trust and agreed in October 2012 and for Stanplan A in July 2013. In October 2015 Barnett Waddingham were requested to undertake the review of the SIP document for the SLDCMT. This review is ongoing and is expected to be completed for consideration at the Q1 2016 board meeting. Barnett Waddingham is working to ensure that the SIP reflects the Boards updated investment advisory framework and meets the full statutory requirements. The SIP for Stanplan A is scheduled to be reviewed in 2016. The SIPs for both the SLDCMT & Stanplan A are scheduled to be reviewed on a triennial basis and this is recorded on the Scheme Calendar. The next scheduled review is in Q4 2018 for the SLDCMT and 2019 for Stanplan A.

A complete and accurate list of the investment options available to both Master Trust and Stanplan A, including FMC and additional expenses, will be provided to the Board in Q1 as part of the quarterly MI that is provided to the Board by SLAL.

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4.4 People 4.4.1 Conflicts of interest

4.4.2 Fit and proper trustees

22. Conflicts of interest are identified, recorded and managed in accordance with a defined policy which is regularly reviewed and approved.

23. Fitness and propriety requirements are recorded and managed in accordance with a defined policy which is regularly reviewed and approved.

Response

Response

¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A

¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A

The “Conflicts of Interest” Policy (CoI) previously in place was updated and the new version presented to the Board in December 2015. The board have asked for final amendments to be made to this prior to its approval. This is scheduled to be reviewed annually; the next review is scheduled for December 2016.

All Board directors have been appointed following a review process and took part in a skills assessment prior to appointment. Individual directors are expected to comply fully with the “Trustee Knowledge and Understanding” requirements set out in the Pensions Regulator’s codes of practice and regulatory guidance.

Conflicts of interest is a standing agenda item that is discussed at each quarterly Board meeting and any additional conflicts are raised at this point and recorded on the Conflicts of Interest Register. Specifically, reference to quarterly declarations of conflicts of interest has been added to quarterly entries on the Scheme Calendar. The register is reviewed and updated at each quarterly Board meeting.

A “Fitness and Propriety” Policy was noted by the Board in December 2015. The board suggested a number of further updates to this that will be included in a future version. This is scheduled to be reviewed annually; the next review is scheduled for December 2016.

The appointment documents for directors of SLMTC contain a clause pertaining to conflicts of interest. This clause imposes a duty on the director to notify the Board, in writing, of any conflicts which exist or arise. A duty is also imposed to disclose any direct or indirect interest in any matter being discussed at a Board meeting and to abstain from voting on that matter. The Chairman’s approval should be sought before a director accepts any additional external appointments or the terms of an existing appointment are changed and the director believes a conflict of interest will arise. Any conflicts of interest must be authorised by the Board. Outside appointments and potential or actual conflicts of interest are recorded in a register maintained by the Group Secretariat of Standard Life. Directors must also confirm annually that they continue to comply with the independence indicators outlined in the current UK Corporate Governance Code.

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24. The fitness and propriety of trustees is regularly reviewed and monitored prior to appointment and thereafter. This review is documented and approved.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A All Board directors have been appointed following a review process and took part in a skills assessment prior to appointment; any identified gaps were addressed as part of the induction training that was delivered to the Board in April 2015. The director’s letter of appointment clearly sets out their duties and what is expected of them as directors. Each year the directors of the Board are expected to undertake the skills assessment in advance of the quarter three Board meeting. This is scheduled to happen for the first time in 2016. The outcomes of this assessment will then be discussed and any actions agreed during the meeting. The timetable for this is recorded on the Scheme Calendar that is in place for the SLMTC. SLMTC monitor for changes to TPR “Trustee Knowledge and Understanding” requirements set out in the Pensions Regulator’s codes of practice and regulatory guidance. Where any changes are identified relevant training, where required will be supplied to the directors.

25. Trustee skills and knowledge are managed and maintained in accordance with an approved training programme. The training programme is regularly reviewed and updated.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A An assessment of the directors of the Board was carried out on appointment and is diarised for an annual review. This uses a skills matrix to identify areas for future director training. Training events are organised throughout the year to ensure that the Board have a working knowledge of SLAL and its products. The programme of training events is recorded and planned out in a high level business plan and this includes the proposed sessions that were discussed at the 2015 Q4 board meeting on SLAL’s administration processes, IT and their communication processes. Trustee training requirement are considered annually, the next review scheduled for Q1 2016. Further to this the Board members are able to request additional training in respect of specific areas that they are dealing with at any given time.

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4.5 Governance 4.5.1 Resource planning

4.5.2 Scheme Management

26. A plan is maintained and regularly reviewed to ensure that resources are properly allocated.

27. Roles, responsibilities and duties of all trustees, advisers and service providers are documented, approved and regularly reviewed.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A A high level business plan is in place and details in which quarterly meeting the Board will consider specific risks. This is maintained on a quarterly basis by the board secretary after approval of the Scheme Calendar review discussed below. A rolling Scheme Calendar is also in place and maintained by the board secretary and is regularly reviewed to make sure it includes all key areas of governance that need to be regularly considered by the Board, and to make sure resources are available to produce and present accompanying material to the Board. The Scheme Calendar is reviewed at all quarterly Board meetings.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A A letter of appointment is provided to each director when they assume their role on the Board. The letter details what their roles and responsibilities are and provides clarity on their responsibility whilst a director of the Board. The Board has copies of all engagement documentation in respect of all advisers. There is a scheduled annual review for adviser performance detailed in the Scheme Calendar and high level planner (next due Q1 2016). This process allows the Board to comment on the performance of advisers and determine whether improvements or a re-tender would be necessary. There is also a Roles & Responsibilities document in place that details the specific tasks that take place for the Master Trust schemes, how these are carried out and by whom. This document sets out various tasks and responsibilities and assigns an owner to each of those tasks. The owner of these tasks varies between the Board, SLAL, the Scheme auditors, etc. As well as designating an owner for each role and responsibility, each item is given a timescale for completion and, as appropriate, an overseer to monitor progress and compliance. This document is regularly reviewed and the last version was approved by the Board in September 2015. The Roles and Responsibilities document sets out accountabilities and includes those relevant to SLAL. To maintain services levels between the Board and Standard Life, service contracts are in place between the previous trustee (PTL) and SLAL. These were assigned to SLMTC as part of the migration process and the review and amendment of these service agreements is an ongoing process. Letters of engagement are required from third party advisers or contractors. Such letters are in place in respect of PwC as scheme auditor, DWF as legal adviser and Barnett Waddingham as investment adviser and Crowe Clark Whitehill LLP as Reporting Accountant. These terms of engagement set out the responsibilities of these organisations to the Master Trusts and are reviewed as part on the annual review of all advisers.

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28. Activities undertaken by all scheme advisers and service providers are properly managed and subject to regular performance reviews which are documented and approved.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A Service Level Agreements (SLAs) are in place in respect of the administration service via the administration agreement between SLMTC and SLAL. The Board reviews the performance of SLAL against the SLAs. It also considers member complaints raised by SLAL and remedial action taken as a result. The Board will undertake annual reviews of the performance of service providers, the next review scheduled in the Scheme Calendar is Q4 2016. A due diligence checklist is in place that requests basic due diligence information from all advisers prior to appointment. Additional due diligence requirements are determined by the Board for each case. SLAL, as the Scheme Administrator, maintains a Pensions Internal Control Statement (PICS) for occupational and personal pension schemes. The purpose of the statement is to describe the activities by Standard Life’s UK & Europe business to ensure the administration of its pension business is carried out in accordance with scheme rules, the requirements of the law and good standards of governance & internal control.

Risk Register Risk management is a key aspect of the governance of the Master Trust schemes. To allow the Board to document, monitor, mitigate and control the risks to the schemes, a ‘risk register’ has been drafted. It is scheduled to be reviewed in Q1 2016 in line with this document. The risk register is a standing agenda item for all quarterly board meetings and is tracked through the Scheme Calendar. Risks that are identified by the Board, their advisers or SLAL are each documented in the register under a ‘risk category’. These categories include financial risks to the scheme and its members as well as operational, regulatory or strategic risks amongst others. Each risk is given an owner who has responsibility for the monitoring and mitigating of the risk itself. The impact and likelihood of each risk (before any mitigants are accounted for) is estimated and documented and given an easy to read score. The register then lists how the risks are mitigated in any way and then provides a second estimation of impact and likelihood. Finally, a postmitigation score is provided to allow an easy assessment of how exposed to risk the scheme and its members are. Whilst the risk register is subject to regular review and amendment as required, each risk that is recorded in the register is given an individual review frequency and the next review date is documented. The risk register is subject to ongoing review.

Enterprise Risk Management Framework

The Board reviewed the current PICS at the Board meeting in December 2015 and have an entry on the Scheme Calendar to review it annually. There is also an entry in the business plan for Q2 2016 for SLAL to present to the Board on their administration processes.

An Enterprise Risk Management (ERM) framework is in place across the Standard Life Group and documented within the System of Governance (SoG). The SoG is assessed for effectiveness annually and signed off by Standard Life plc’s CEO and CRO.

4.5.3 Internal control framework

Components of the ERM Framework are: Emerging Risk, Risk Control Processes, Risk & Capital Models, Strategic Risk Management & Risk Culture.

29. A risk management framework is established to identify, manage and monitor significant operational, financial, regulatory and compliance risks.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A

Key risks and Exposures are assessed regularly and reported through Standard Life plc business units and Group Enterprise Risk Management Committees (ERMCs) through to the Risk & Capital Committee (RCC) which is a non-exec committee of the Standard Life plc Board. The ERM Framework is fully documented with the Pensions Internal Control Statement (PICS) which the Board reviewed at the meeting in December 2015. The PICS will be reviewed annually; the next scheduled review is at the Q2 2016 Board meeting.

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4.5.4 Core scheme transactions 30. Contributions benefit payments, investment transactions and calculations and related income and expenditure are completely and accurately processed in a timely manner and recorded in the proper period.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A SLAL operates a number of control processes which are designed to ensure that core financial transactions are processed in line with expectation. High level descriptions of the processes in place are documented in the Pensions Internal Control Statement (PICS) which was reviewed by the board at the meeting in December 2015. This includes procedures in relation to the following areas of administration:¬¬ Contributions are received and allocated accurately and in a timely manner. ¬¬ Authorised switches between investment options and changes to investment instructions are processed accurately and in a timely manner (including Lifestyle profiles). ¬¬ Transfer values are calculated in accordance with policy provisions and are paid on a timely basis. ¬¬ Benefits are calculated on the basis of accurate fund values and are set up and paid on a timely basis. Benefits are terminated correctly and in a timely manner on the basis of valid information. The PICS will be reviewed annually; the next scheduled review is at the Q2 2016 Board meeting. These processes are reviewed regularly to ensure that they remain fit for purpose. In addition, the processes are supported by Standard Life’s automated workflow system which allows for work to be enabled, tracked and managed. A dedicated controls team, within SLAL, actively manages manual payments (including automation failures) and the reporting of missed contributions to the Pensions Regulator. Quality Assuring is also in operation within SLAL to give confidence that the core financial transactions are processed in line with the defined processes and service levels. Information relating to how long core financial transactions take to be processed is detailed in the quarterly MI that is provided to the Board by SLAL. The MI is discussed at the meeting with representatives from SLAL providing commentary on any anomalies that are identified.

The Board have an action in their plans to receive assurance from SLAL on the processing of core financial transactions on an annual basis. At the Board meeting on 2 December 2015 an action was agreed for SLAL to present a paper addressing various aspects of scheme administration. This will include SLAL control procedures relating to how core scheme transactions are completely and accurately processed in a timely manner and recorded in the proper period. The paper will provide the Board with confidence that the controls currently in place are appropriate for Master Trusts. This is scheduled for the Q3 2016 Board meeting.

31. Contributions are invested in accordance with member instructions or the default policy.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A Contribution allocation is fully automated with no manual intervention in terms of buying units. Automated systems are designed to ensure consistent, timely and accurate receipt and allocation to the correct funds of regular and single payments. The Pensions Internal Control Statement, which was reviewed by the Board in their Q4 2015 meeting provides high level summary of the controls that are in place to ensure that:¬¬ Contributions are received and allocated accurately and in a timely manner. ¬¬ Authorised switches between investment options and changes to investment instructions are processed accurately and in a timely manner (including Lifestyle profiles). The PICS will be reviewed annually; the next scheduled review is at the Q2 2016 Board meeting. These processes are reviewed regularly to ensure that they remain fit for purpose. Reconciliations are carried out between Standard Life’s Finance and Customer Operations areas to ensure contributions are accurately recorded.
Members of the Master Trusts are made aware of where their contributions are invested as well as in what proportion through the annual benefit statements that they receive. At the Board meeting on 2 December 2015 an action was agreed for SLAL to present a paper addressing various aspects of scheme administration. This will include SLAL control procedures relating to how contributions are received and allocated accurately and in a timely manner. The paper will provide the Board with confidence that the controls currently in place are appropriate for Master Trusts. This is scheduled for the Q3 2016 Board meeting.

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32. Transaction errors are rectified and members are treated fairly as a result of that rectification.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A Where a financial transaction is not processed promptly business rules are in place to ensure that there is no loss to the member. Allocation of units is backdated to the original date of receipt of the payment/the receipt of supporting information needed to allocate the payment. The Pensions Internal Control Statement, which was reviewed by the Board in their Q4 2015 meeting provides high level summary of the controls that are in place to ensure that any errors are rectified promptly. These include (but not limited to) ¬¬ The SLAL controls team identify automation failures in key processes (such as contribution allocation, Annual Benefit Statements and new business documentation) and manage them through to completion of the original request so that members are treated fairly. ¬¬ All complaints are dealt with by trained complaint handlers within the Customer Relations Department who follow established processes that adhere to the FCA’s DISP rules. ¬¬ Complaints are subject to root cause analysis which is designed to ensure systemic issues are resolved. Any errors/complaints are identified and provided to the Board in the quarterly MI. Complaints are discussed at the Board meeting where SLAL provide context on the cases in question. The PICS will be reviewed annually; the next scheduled review is at the Q2 2016 Board meeting. These processes are reviewed regularly to ensure that they remain fit for purpose. At the Board meeting on 2 December 2015 an action was agreed for SLAL to present a paper addressing various aspects of scheme administration. This will include the processes in place to ensure that any errors are rectified promptly. The paper will provide the Board with confidence that the controls currently in place are appropriate for Master Trusts. This is scheduled for the Q3 2016 Board meeting.

4.5.5 Receipt of contributions 33. Late and inaccurate contributions are pursued and resolved.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A SLAL operates a control process to deal with contributions that are outside of the permitted timescales as communicated by the Pensions Regulator. The Pension Regulator has reviewed the process and no issues were raised as a result. A report detailing outstanding payments is produced automatically on a monthly basis. On production of the report the dedicated team within SLAL take action to assess why payment wasn’t made and to address the payment failure. The team will monitor all cases and where necessary will work with the employers until payment of the outstanding contributions is made. If payment is not received by the latest date possible it will be reported to the Pensions Regulator via their online portal. A communication will be issued to the Board informing them of the payment failure. Information relating to employers of the Master Trusts who have been reported to the Pensions Regulator is included within the suite of management information that is presented to the Board on a quarterly basis. SLAL are introducing a range of tests to help try and monitor inaccurate or insufficient payments, these include:¬¬ Remind the employer of their obligation regarding contribution payments on behalf of the member and certify their accuracy ¬¬ Ask Employees to review the accuracy of contributions amounts received on an annual basis ¬¬ Management information on contributions at scheme level that do not increase over a specific period of time. These have been discussed with TPR who have indicated that they would be appropriate. The Pensions Internal Control Statement, which was reviewed by the Board in their Q4 2015 meeting provides high level summary of the controls that are in place to ensure that:¬¬ Contributions are received in accordance with scheme rules and relevant legislation. ¬¬ Contributions are received and allocated accurately and in a timely manner.

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The PICS will be reviewed annually; the next scheduled review is at the Q2 2016 Board meeting. These processes are reviewed regularly to ensure that they remain fit for purpose. At the Board meeting on 2 December 2015 an action was agreed for SLAL to present a paper addressing various aspects of scheme administration. This will include SLAL control procedures around ensuring contributions are received in accordance with scheme rules and relevant legislation. The paper will provide the Board with confidence that the controls currently in place are appropriate for Master Trusts. This is scheduled for the Q3 2016 Board meeting.

4.5.6 Retirement process 34. Retirements are managed in accordance with a documented process which is regularly reviewed and approved.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A The Board reviewed SLAL’s retirement proposition as part of their induction day in April 2015. The session covered:¬¬ The product solutions offered ¬¬ The investment solutions to support the retirement proposition ¬¬ Member engagement ¬¬ The support provided for members There are documented procedures in place within SLAL to manage all retirements. As part of the procedures:¬¬ Scheme rules and policy provisions are coded within automated systems that have been built and tested to established project management practices. ¬¬ Benefits processes have been developed with oversight by Compliance and Legal departments to ensure legislative requirements are met. ¬¬ A quality assurance framework is in place to give assurance that benefits are processed in line with the defined processes and service levels. At the Board meeting on 2 December 2015 an action was agreed for SLAL to present a paper addressing various aspects of communication. This will include SLAL control procedures relating to the retirement process and associated member communications in the lead up to retirement. The paper will provide the Board with confidence that the controls currently in place are appropriate for Master Trusts. This is scheduled for the Q3 2016 Board meeting.

35. Retirement products selected by members are monitored and the range of retirement products made available is reviewed regularly for ongoing suitability.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A All SLAL’s retirement products are managed in line with the SLAL Conduct Risk Policy, this ensures that all customers are treated with consideration and fairness. The policy sets the standards that all SLAL business units must adhere to in relation to delivering fair outcomes for customers; it also supports SLAL’s “Customer Focus” governing principle. Two of the key intents from the policy are:¬¬ All propositions and services will be designed and reviewed in line with the needs of the identified target customers. ¬¬ SLAL will continually manage propositions and services consistent with their published objectives and communicated expectations and will correct any identified failures in a timely manner. To ensure that SLAL complies with the above intents, each proposition is managed through the Proposition Management Process (PMP) – all PMP deliverables are business as usual activities. As part of the process SLAL undertake a review of each proposition to ensure that the strategic intent of the product still applies and that it is still meeting customer needs, for example:¬¬ Where a customer impacting issue is identified they take such steps considered necessary to address any perceived shortcomings in adherence to the standards and Standard Life’s brand values (easy, responsible, beneficial, predictable); and ¬¬ Where a proposition, procedure or process has been identified as not performing as intended and/or has resulted in customer detriment, the root cause will be identified, appropriate actions taken to resolve and appropriate redress applied to all identified impacted customers. The retirement options available to members are accessed via products outside of the SL DC Master Trust or Stanplan A. As a result of this the Board have no direct responsibility for the retirement products available. The Board do however monitor what members are selecting in order that they can get comfort from the support being provided to members in the lead up to members’ retirement. It also helps to support the investment decisions that the Board make on behalf of the members.

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36. Members are regularly made aware of their investment choices, the importance of reviewing the suitability of their investment choices and that their level of contributions is a key factor in determining the overall size of their pension fund.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A Prior to a member joining the scheme, they are made aware of their investment options via relevant documentation and websites. Key messages are given throughout both the member guides and websites to demonstrate the importance of them regularly reviewing their investment options, and also showing the importance of how their contributions can affect their final pension value. Post joining members receive annual benefit statements which among a number of items state what funds they are invested in, the level of contributions being paid and an estimated pension. Members also have access to a range of online tools which support investment assessment and selection, assessment of different contribution levels and projected benefits. At the Board meeting on 2 December 2015 an action was agreed for SLAL to present a paper addressing various aspects of communication to members. The paper will provide the Board with confidence that the controls currently in place are appropriate for Master Trusts, in terms of communicating key messages. This is scheduled for the Q3 2016 Board meeting. In addition the Board received a presentation on SLAL’s engagement proposition at a training event on 11 January 2016.

4.5.7 Communications 37. Scheme communications are accurate, clear and understandable and are produced in accordance with a documented communications plan. The plan is regularly reviewed and monitored.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A The Board have reviewed the customer engagement strategy that sits across all products as part of their induction event (April 2015). The intention was to showcase SLAL’s complete engagement model and how this can be flexed over the whole population. It included:¬¬ Support at scheme join ¬¬ Ongoing support ¬¬ Digital support ¬¬ Member dashboards ¬¬ Social media As part of the roles and responsibilities agreed by the Board SLAL will provide communications to members and prospective members. Any significant changes to the communications material will be reviewed by the Board. The Board have actions on the Scheme Calendar to review a range of communications including member booklet/guide/annual benefit statements and general communication material. The process for generating all statutory communications is undertaken by SLAL. Individual participating employers have plans in place for communicating to members and the content of specific member communications in the lead up to retirement are set out in detailed “Wake Up Pack” and logic specification process documentation. As part of SLAL’s processes when producing communications all content is reviewed to ensure accuracy, there is an audit trail to support all communication sign offs. At the Board meeting on 2 December 2015 an action was agreed for SLAL to present a paper addressing various aspects of communication to members. This will include detail around the drafting and presentation of communications to members. This paper will provide the Board with confidence that the controls currently in place are appropriate for Master Trusts, in terms of communicating clearly key messages. This is scheduled for the Q3 2016 Board meeting.

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38. Communications contain information to support the decisions members need to make at retirement.

Response ¬¬ Control Objective applicable to both Standard Life DC Master Trust and Stanplan A The scheme specific communications contain general educational content to support members in making decisions at retirement. As well as this, a suite of interactive tools are available online to help members’ gauge the amount they will need for retirement against their current projected retirement pot. As members approach their retirement date SLAL provide staged member communications. A “Wake Up Pack” is provided 6 months prior to retirement and then a “Follow Up Pack” is issued 6 weeks before the member is due to retire. The aim of these packs is to prompt them to consider how they want to take their benefits.

Planning Tools SLAL offer a range of on-line tools to allow members to visualise ¬¬ Their life in retirement ¬¬ Work out how much their pension is likely to be worth ¬¬ Set their own financial goals and see what they need to do to get there (e.g. increasing their contributions, change their investment options). SLAL also offers access to a team of retirement experts that can help members understand their retirement choices to allow them to make an informed decision. At the Board meeting on 2 December 2015 an action was agreed for SLAL to present a paper addressing various aspects of communication to members. This will include detail around the drafting and presentation of communications to members. This paper will provide the Board with confidence that the controls currently in place are appropriate for Master Trusts, in terms of communicating clearly key messages that enable member decision making. This is scheduled for the Q3 2016 Board meeting. In addition the Board received a presentation on SLAL’s retirement proposition at a training event on 12 January 2016.

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Appendix – Letter of Engagement

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