Cracking the Pensions Regulator's new Code on money purchase benefits

Margaret Costelloe: Hello and welcome to this Gowling WLG Webinar on the Pension Regulator's New DC Code and Guides.

By the end of the session, we hope you will know what these materials cover, why they have been put in place and take away some ideas and practical action points. Today we have Ian Chapman-Curry and Joanne Tibbott presenting. They are both lawyers in the Pensions team here at Gowling WLG with years of experience between them in advising schemes of all shapes and sizes and they are familiar with all aspects of the pensions world. So it's over to Ian and Jo to take you through the nitty-gritty of the new DC Code and Guides.

Ian Chapman-Curry: So, as Mags said, we are going to be covering the new DC Code that was issued in final form in July of this year.

But let us go back right to the fundamentals. Why do we have defined contribution schemes at all? The Regulator has quite specific views on this. It is for members to achieve an adequate income in retirement. And in case you are in any doubt whatsoever, the Regulator goes on to state that this is the ultimate outcome that really does go to the heart of everything that a DC scheme should be offering.

So where does all the focus on DC governance come from? Well, this has not just come out of the blue from nowhere. This has been a long time in development. This is something that has come out through papers, consultations, and workshops. It has involved the Pensions Regulator, the Department for Work and Pensions, the Office of Fair Trading, all kinds of stakeholders, and many people on this call will have been involved with that as well.

So those papers started off with the Pension Regulator setting out six principles, six guiding things that it thought were really crucial in terms of DC governance principles to adopt in the design, set up and the ongoing operation of DC schemes. And then, as if anyone who has read about these can forget there were 31 quality features, 31 things that the Pension Regulator thought that you should do, 31 things that your pension scheme needs to have.

But, ultimately, by the time we get to November 2013, in final form, we get six principles plus 31 quality features coming together in beautiful harmony into just one Code of Practice - Code of Practice number 13 on the Governance and Administration of Occupational Defined Contribution Trust Based Pension Schemes, and that is the Code that we have come to know and love, at least for the last three years.

So why now in 2016 are we revisiting this? Why is the Pension Regulator once again focused on defined contribution? There are a number of reasons, as things basically in the intervening three years have moved on.

One of the key facts is that workplace pension reform automatic enrolment has now been in place for four years and has been a success, so there are literally millions more people saving into workplace pensions, the vast majority of whom are saving into defined contribution schemes. So the combination of contract based personal pensions but, interestingly, a huge number of occupational pension schemes or the multi-employer master trust (the Nest of this world are all examples of that), so these arrangements are literally helping millions more people.

Also the law has changed. The Government recognised that with so many more people saving in workplace pensions and defined contribution arrangements, they have to put in place (or they have to at least think about) charge controls for things that members were required to pay. And that is especially important if they have people who are being enrolled into default funds, so they might just be going in there by inertia, they are not making decisions, they are being automatically enrolled into things.

So it is even more important that there is a good governance framework in place and things like charge controls (which includes things like the cap on member contributions and covers the ban on active member discounts and the ban on member or commission payments).

All this then comes together in terms of the concept of "value for money" and it is something that we are going to come back to. It might be referred to as "value for members" or "value for money" and it is a concept that really does act as a thread through the whole of the DC Code and Guides and really does go to the heart of both the legislative backdrop to this, the policy intention and what the Pension Regulator is saying is important in relation to this.

And then, just to bring all of that together, why is the Pension Regulator trying to put this in as accessible a form as possible? Because it has a statutory obligation, its principles are to promote knowledge and understanding - it wants to get this message across to enable people to understand why DC governance is so important. And with that, we are brought right up to date to 2016 and I'm just going to hand over to Jo who is just going to have a final look at the new Code and Guides.

Joanne Tibbott: Thanks Ian. So the new Code and Guides - as many of you (as trustees or people who advise trustees) know, in April 2015, a huge new raft of legislation and obligations on DC payments came into force, which trustees had to comply with.

The Regulator has finally caught up now and issued its new Code of Practice and supporting Guides which were in force from July this year, so Code of Practice 13 has been updated.

The Code covers six key areas so just to run through those very quickly:

1. The trustee board, how do you go about appointing your chair, specific obligations which apply to master trusts for example;
2. Scheme management skills: how should the trustee board be run?
3. Administration;
4. Investment governance (and I am going to come on to talk a bit about security of assets which is certainly a thing that is exercising a lot of my trustee clients at the moment);
5. Value for members, a very important part of the new governance framework; and
6. Communicating and reporting.

And we will come and look in a bit more detail shortly at the new Guides which covers each of six key areas. And what the Code does is set out standards that the Regulator is expecting trustees of schemes with money purchase benefits to adhere to, and, just moving on, well what is the new Code actually covering?

We are all used to referring to the Code of Practice as the DC Code and we still do that. In actual fact, it goes wider than that so we are not just looking at pure DC schemes, we are looking at schemes to provide money purchase benefits and Ian is going to come on to in a couple of slides' time to actually explain the types of schemes that might be caught by the new Code, because we had had clients within the team who thought "oh, actually these do not apply to us", but actually when you dig a bit deeper, there are certain historical benefits hidden there for which the new requirements actually do apply, so that is an important point which Ian is going to cover.

So what do you actually need to know? Well, as I have mentioned, the Code is in force but a lot of trustees who have been trying to get up to speed with the new DC, it is really important to be familiar with the Code and Guides and a lot of trustees are having them on agendas for trustee meetings that are now taking place after the summer break, focusing on money purchase benefits, six key areas and it sets out the standards that the Regulator does expect of trustees.

The Code is quite short. It is supported by practical guidance which sets out what the Regulator regards as best practice and also it provides example checklists and templates, which are very useful for trustees in working out what they might be communicating to members etc. or how they are going to approach communications.

So as I have said, we have a new Code for a new world, lots more obligations on trustees, but just to recap, the Regulator has intended with the Code that it is going to be much shorter, user friendly, setting out the legal duties and standards of conduct and practice with the six sides supporting the Code, practical guidance and recommending best practice and examples for trustees.

I think they are really helpful documents, they are very easy to read and I would highly recommend that if we have not already done so, have a look through them. If there are any particular areas (such as value for members) that you are grappling with, then the Regulator site really is a good starting point.

So as you can see on the next slide, we have come on quite a long journey, as Ian has said. The Regulator has taken a bit of catching up in terms of when the duties came in and issuing its Code, but I think what is important to bear in mind is, why do we actually care about what the Code says? It is not a statement of the law and there is no actual direct penalty for failing to comply with it.

But, what it is intended to do is to help trustees discharge their legal duties. So if you do not comply with your legal duties, penalties can be imposed under the Pensions Act 1995 and other legislation, so I think it is really important for trustees to bear in mind what the Regulator is saying in these things when they are deciding how to approach value for members and other aspects that are covered in the Code and Guides.

Ian: OK. Thanks for that Jo.

So, we have got the new Code in place. What exactly does the Code cover, and more importantly what do the Guides cover? So the DC Code is split into six sections and there are six Guides that go with each of those six sections. So it is well thought through in the sense of having those things all split up and you can read the section in the DC Code and then go to the relevant Guide which will correspond to that section.

So Guide number 1 is covering the trustee board, that is, looking at the composition of trustees, how you might appoint trustees, and it is also looking at the chair of trustees, a very important role that the Pension Regulator in legislation places a lot of emphasis on.

Number 2 is looking at scheme management skills. And that is everything from being able to understand contracts and the procedures that are in place on delegation and being able to monitor what is actually happening on the scheme in terms of working with providers, and being on top of all of that, which is a good thing.

Number 3 is focused on administration and that is really at the heart of what the Regulator wants to get across. Good administration is one of the key components of ensuring good member outcomes, and if we go back to the first point that I made, the Pension Regulator is focused on good member outcomes because ultimately that is why we have DC schemes, to ensure that members have money that they can retire on.

And that leads nicely on to number 4, which is investment governance, because members will have money to retire on not only from contributions but also on money if returned as a result of investment, so there is a lot of attention on investments and Jo is going to be covering security of assets as one of the key concepts in a lot more detail.

Something that can result in members having less money in retirement is if they are paying a high level of charges or other things, so number 5 is focused on value for members or value for money, ensuring that members get good outcomes because the trustees have thought about whether costs in the scheme represent good value for members.

And finally, number 6 is on communicating and reporting, how do you communicate with your members, how do you convey important information? And this is really important and is one of the things that the Regulator has statutory obligations to do to promote understanding of pensions. But how do you communicate, especially with younger workers in their 20s and 30s, that decisions they make now will have material consequences 30, 40, 50 years in the future? It is a really tough ask and the Regulator is, appropriately enough, asking people to have a think about that.

So that is what is in the Code and the Guides.

Who is the Code going to actually apply to? So the Code applies to occupational trust based pension schemes. It does not apply in the personal pension or contact based world. That has a separate regulatory regime that is overseen by the FCA.

It applies if there are two or more members, and that is members whether they are active, deferred or pensioner - and the most important thing is, as Jo pointed out in terms of the name change for the Code, it applies to schemes that offer money purchase benefits. So that includes AVCs within otherwise defined benefit schemes, so in some ways, the forgotten element of defined contribution, schemes where the bulk of governance time, trustee meeting time has been focused on defined benefits because of much bigger headlines in deficits, being able to afford to cover promises and things like that. But AVCs and the DC pot, the Regulator would argue, also deserves more attention. So that means a much broader range of schemes are going to be subject to the new Code than you might think.

Everyone understands that if you have a pure DC scheme that is an occupational trust based arrangement that the Code is going to apply. It is obviously also going to apply if you have DC sections within schemes that offer mixed benefits or a hybrid scheme as you might know it, but it also crucially is the money purchase AVCs within occupational DB schemes, and also money purchase benefits that have a DB underpin, so you get all these kinds of complexities, and as Jo pointed out, there are also those hidden historical benefits.

We have a few schemes in the team where, because there are historic DC benefits in the scheme, more aspects of the DC Code and the legislative regime underpinning it apply than the trustees at first thought, and it is prompting them to take action as a result.

So one of the things that the Code really focuses on is best practice. It sets out what the legal obligations are, but it also sets out in a lot of detail what the Regulator thinks are examples of best practice and what the Regulator expects trustees to do.

So I have just thought about a few that really just raised my eyebrows when I was reading through it: things like having a data review that has to be carried out at least annually, or having a procedure manual that has quality assurance details, continuity processes and procedures.

Now the Pension Regulator will be at pains to say that trustees need to consider whether that represents value for money and to do things that were appropriate for the type of scheme, but it is the trustees that have to make that decision and it is an important point that one size will not fit all.

The Regulator is not saying this is appropriate for all schemes in all circumstances, instead it is putting the onus very much on trustees and their advisors to think carefully what the membership needs in those particular circumstances.

We are going just to look at other elements of this best practice, things around having sensible low cost things like including the Pension Regulator's scorpion leaflet if you are sending out annual statements, being aware of scams and pension liberation and things around the annual reports, and making sure that you include information about policies in relation to long term sustainability and stewardship of DC assets. And I know that is an issue that people have already raised with us before the webinar, so it is an issue that is interesting people, and also non-financial factors, so things that are very current are being covered.

So, as well as the best practice, the Pension Regulator has also set out a whole range of checklists and examples, and if there is one thing that might encourage you to read the Guides and the Code, it is that the Regulator has provided a whole range of really quite useful things. It might save you time, it might save you money because it has these checklists and examples which can be a really helpful thing if you are going through any of the processes that are shown on screen. So things like the contract review checklist, it is just a really handy headline way of making sure that you thought about all of the things that you might need to think about.

Obviously, I will also be at pains to say it does not replace having appropriate legal advice, but certainly all the help you can get in those things is worthwhile. So that is our overview of the DC Code and some of the elements of it and we are just going to spend the rest of the webinar focusing on some of the main issues that have arisen in practice and obviously we are only a couple of months into the regime so we do not have a huge amount, and one of the first ones is around the appointment of new trustee members.

When I was going through the Code and Guides and setting out all of the steps, it is actually quite an exhaustive list of things and it is also again something that the Pension Regulator is at pains to point out that it will depend on the complexity and the size of the scheme, so all of these things will not necessarily be appropriate for smaller schemes, but having said that, there are elements that again raised eyebrows.

So first of all, it is considering that everyone who is a trustee is fit and proper, not only at the time of appointment but throughout their trusteeship, so that they continue to be fit and proper and that ties in to some of the concepts that are going through on the defined benefit side.

So things around the concept of what is a 21st century trustee, what does trusteeship look like in an age when you have far more professional trustees, or where you have a post BHS and British Steel world where there is a lot more media scrutiny on the role of trustees.

So the Regulator says if you have an identified gap, if someone has resigned or stopped being a trustee, one of the things you should do is do a bit of skilled mapping and see what type of vacancy there is. What skills did the person that is leaving take with them and what do you need to try and replace?

And that is an interesting one in terms of skill mapping, because I have personally advised on a number of schemes where they just do not have the luxury of choice in terms of people who were willing to take the trustee role, so the idea that you could actually collect based on skills, there would be some schemes saying that chance would be a fine thing, but just say that you do get to that stage the Regulator also notes that you are required to conduct references and do background checks and sets out things like checking on Companies House, checking Companies House for records of directorship, bankruptcies, doing conflicts of interest checks and also getting references and even doing criminal record checks.

The Regulator points out that you can rely on what the employer says, and then there is interview testing. The Regulator suggests that you might even be willing to do psychometric testing and then have an induction and training period and then going through of all this when you come back for succession planning. So we are now just going to go over to the first poll.

Margaret: OK, what we are asking here is which of these techniques have you used as part of the appointment of a new trustee? And you can tick as many of these as you like or as few even: interviews, training, induction, skill mapping and psychometric testing. The question should be coming out to you now and we would be interested in your views.

Ian: Thanks, Mags, so hopefully that is appearing on your screen. Are we starting to get responses in?

Margaret: We have got a few in but I would encourage you to participate.

Ian: Yes.

Margaret: So if you keep going guys, press a few buttons. Ah ha. Thanks very much now you're answering. That's fantastic. OK we are doing well. We have got loads of replies now thank you for that.

Ian: People were just being a bit shy.

Margaret: I think so. I think so. OK well can you see the results on your screen there?

Ian: Coming through.

Margaret: Yes fantastic. OK, well an awful lot of you are using interviews and training as you would expect, and induction, but there is not so much psychometric testing going on which I think is quite interesting, Ian.

Ian: Yes, it is not something that I thought many schemes would be doing.

Joanne: No, and it is not something we have seen at all actually, for schemes to have the facility and budget frankly to run those kind of exercises is a tall order, I think, and quite often psychometric testing can sometimes be useful in identifying where a candidate's weaknesses might be.

My own personal view is that having someone in the room, having an interview with people who know what they are looking for, is a sensible way forward.

Ian: Yes, especially as you would be working with those people.

Joanne: Exactly. Yes. OK, so I am just going to talk through briefly the role of the chair in the DC world.

Most schemes that I work with already have a chair of trustees appointed, but what I wanted to explain was that there is now a legal requirement for all money purchase schemes to appoint a chair and what the Regulator is looking for is someone who will run the trustee board in a similar way to a chair of a corporate board would run that board.

Chairs have one additional role, the production of an annual statement, and I will come on to that shortly, but in terms of what the Regulator expects of a chair, well they expect them to be an effective leader as perhaps you might guess, so someone who can have an independent viewpoint, recognised trustee qualities, and have a strategic view, so to have that overview of where the scheme is going and where it might need to be taken in terms of investment governance for example, and someone who can really run the scheme to high standards with a view to getting the best outcome for the members.

In my experience, these days, a lot of chairs are often professional trustees and Ian has already mentioned the Regulator's 21st century trustee governance paper, and I think one of the things they are looking at is whether there should be any standards of entry for professional trustees. A lot of the trustees we already work with are already operating to a very high standard, but how do you measure them against each other and should there be a global standard for that?

So, in terms of the skills that the Regulator expects the trustees to have, well, it is a difficult role to fill but if it is your day job, if you are a professional trustee then you would expect professional trustees to have a lot of these skills already, and I have just listed those on that slide and I think certainly in a lot of the trustee meetings I go to, a lot of trustees are already demonstrating those qualities. But again, it is identifying and making sure that you are having sufficient training, that you are challenging other trustees, you are challenging your advisors and those are all important skills I think in making sure you have a chair who is running a scheme effectively.

And now the additional obligation I mentioned, the chair's annual statement. A lot of you I expect with DC schemes will already have been grappling with this already. So it is a yearly statement included with the scheme's annual report and accounts and I think it is important to bear in mind that it is disclosable to members.

I was at a trustee meeting where I was asked the question of, well, who is the chair spokesman actually for, and whilst it is obviously demonstrating that trustees have complied with their legal duties, I think it is really important to consider what information you are actually putting in that statement which could be useful for members and certainly some schemes are considering, as well as having the statement in the annual report and accounts, providing a summary version in very plain English which can go to members to demonstrate the process that the trustees have gone through in terms of looking at value for members, the charges etc. and I think that could be really useful for the membership.

In terms of when the statement is issued, so the first annual statement for the scheme year ending on or after 5 July last year, that would be when the first statement had to be provided unless the scheme year was after 5 April and before 6 July 2015 in which case it could be rolled over and, what I mean by that, is that shorter period would be included in the statement for the following scheme year.

So I am going to hand over to Ian now who is going to talk to you a bit about value for members and what the Regular expects.

Ian: Yes, and this is something that we could do an entire webinar on its own and a good point to say this is an overview webinar - if there are subjects that you would like us to cover in more detail, then please drop us a line because we would love to talk to you about those things.

Value for members does not mean low cost. That is something that the Regular is very keen to get across. Also value for members is going to be different for different schemes. What the Regulator would like trustees to do is look at their own membership, look at the demographics, the preferences and requirements of members before deciding what value means, and it is also encouraging you to look at this in a holistic sense and looking at the broader elements of good value and looking at things over the longer term, rather than focusing on a snapshot or just in the short-term and thinking about the things that members get the benefit of but they might not necessarily pay for.

Those things are paid for by the employer of, if the cost of certain things are paid for, in a large part, by the amount of money that an employer contributes, it might be that the members are getting a decent value for money in that sense.

We are just getting to have our next poll now, Mags.

Margaret: OK, and this time we are asking: have you discussed the issue of the security of DC assets at a trustee meeting or with your provider or advisors?

You have got one option here guys, it's either yes in detail, yes it has been raised, not yet but it is on the agenda, or no. So if you could press your buttons that would be fantastic.

Ian: Thank you very much. I always feel like the cutting edge of technology with these things which just shows how behind the times pension lawyers can be because these have been around for a long time.

Oh yes, are people coming through now, Mags?

Margaret: Yes. They are coming in, but a few more answers would be just fantastic to give us a really good view.

Ian: I am just aware that we have hit 1.30pm. We are going have about another five minutes. Jo will be speaking on a very interesting issue of security of DC assets but we are aware that we said half an hour so if you do need to ring off, we will be providing the recording and the full transcript, and we will also have time for your questions after Jo has done a bit on security of assets. Have we got the results?

Margaret: Yes we have some good results here coming in now. Can you see that…

Ian: Yes, so…

Margaret: A really good response there guys.

Ian: Really interesting that basically it is something that is on the trustee agenda, that for the overwhelming majority of schemes this is something that has been considered so it is certainly something that is being raised and discussed.

Joanne: Yes, so I am conscious of the time and I am conscious that a lot of you have already said that this is something that you have already raised and are looking at so I just wanted to give you a sort of a summary of the issues and what we think trustees need to be doing if they have not already done it.

So when we are talking about security of assets, we are really talking about how safe are members' DC pots while they are invested and the types of question that leads to is: well what happens if the provider fails, do members get their money, is there any compensation?

And this is not a new area, there is already a requirement of the investment regulations to ensure that when you are making investment decisions they are made in a manner which ensures, amongst other things, the security of the portfolio, but I think in the increased age of auto-enrolment and also closure of DB schemes, and also the Regulator has focused on this in its Code and guidance, it is something trustees are having to engage with.

So, in terms of compensation, well isn't that covered by the Financial Services Compensations Scheme? A lot of trustees perhaps before the Regulator's updated Code thought that actually if it is not DB it probably is covered, but the reality is that generally pension funds cannot claim from the FSCS, and whilst there may be a possibility that trustees can claim if they have long term direct insurance contracts, it is a really complex area that has been untested and whether or not you may be eligible for compensation will very much depend on the arrangement you have with your investment provider, so is it a direct contract with the provider, do you have any kind of platform in place and if so what is the structure of that platform, what is the recourse for the underlying funds, for example?

And that brings me on to what I have identified as three key risk areas in terms of security of DC assets, which I have listed on the slides:

• So, provider or manager default, do you know what would happen in that situation? What is the legal structure of the project you have in place?
• Cross contamination: a lot of big life companies have several business lines so if something happens to the business, could the life business's assets be called upon by another part of the business, so the annuity business for example?
• And finally, as I have previously alluded to: what happens in the case of third party default? Could your platform provider actually access those underlying funds and, if it could, how will it recover from them and up to what amount?

And those are all areas that I think trustees need to bear in mind particularly. I have put an extract from the Code of Practice, I am not proposing to read it out, but the Regulator really is expecting trustees to dig deeper and ask questions and find out and try and establish what protections they have in place, and also communicate the outcomes to members, which in itself is not going to be an easy thing to do.

So just a few things which might be helpful for the trustees. The Guide to investments governance: that provides details of what the Regulator expects and within that document the Regulator refers trustees to the Security of Assets Working Group Guide. Whilst that document is not intended to provide answers to trustees, it certainly does help them formulate the right questions to ask of their providers. So they can go to their investment provider and say, please tell me what protections I have in place, how the platform works, how I can access, how you might be able to access the underlying funds on my behalf and that's the stage, the due diligence stage, which is important for the trustees. And once you have responses to those, is there any risk that the scheme is exposed to and is that risk acceptable and do the trustees need to ask any more questions?

And finally, the Regulator says, well actually you might want to consider, well actually it would be best practice for you to communicate the conclusion of your review and any actions you have taken to members, which of course is not going to be a particularly easy thing to do.

Just as a final point, in terms of actions for trustees, I think one of the things I would say is that this is not something you need to panic about, but I think it is about taking a measured and proportionate approach, so keep a watching brief, ask the right questions, ask your advisors to help you formulate the right questions and review those responses for you.

That is something that should not just happen when you are appointing a new investment provider. So going through a tender process, have you looked at your existing arrangements, when did you last look at them, do you know what contractual arrangements say, what are the protections, who is the contract actually with?

And those are all of the kind of things that would be helpful for the trustees to do and in demonstrating that they have discharged the duties that the Regulator expects of them.

Member communications: that is a really hard one. I have not actually seen any communications yet on security of assets. I am sure a lot of you are working on them with your advisors but I think it is going to be very difficult to balance the need to be providing information in terms of what protections are in place and also setting hares running.

And finally, security of assets: it is not the only piece of the investment governance jigsaw, it is one part and having an overall framework in place that looks at security, what your default fund looks like, what your charges are, are all very important aspects that trustees should be focusing on in the new world of the new DC Code.

And then finally, I was just going to mention what do good member communications look like? This can vary enormously between schemes in terms of the technology you use to push communications out to members, is it letters, is it email, is it apps on phones for example, but I think whatever message you are using (it was second column there) really demonstrates the importance of having clear messages that are relevant to your members and pensions is tricky. Plain English is also going to be really important in trying to increase member engagements.

And I think we are now on to our final poll, Mags?

Margaret: Yes that is right Jo, the last poll today is do you use technology as part of your member communications and, again, you have got a choice of four answers. No, not at all, a bit but we are still mainly paper based, a lot, online, email or by text and finally yes most of our communications are digital.

So if you could give us your answers to those that would be helpful.

Ian:

Perfect, and whilst we are waiting for some responses we will make good use of the time and answer some of your questions.

The first one that we have had in and we have had some great questions, some of them are very interesting and so interesting that we are going to take them offline and give them the attention they deserve - so if we do not cover one that you have asked, we will make sure that we follow up and get you some responses.

But the first one is, is a chair's statement required when you only have AVC benefits in a DB scheme?

Joanne: And the answer to that is no. It is very clear in the Regulator's Guide that you do not have to produce a chair's statement if you have AVCs but again it is being really careful to make sure that the AVCs are actually AVCs and not something else, because we have had a couple of clients that thought that was the case and have been caught out and have been subject to the requirements.

Ian: It is an interesting quirk that where you might have historic DC benefits and the Code will then not just apply in terms of those money purchase benefits, but potentially the whole lot of any money purchase benefits, so it is a difficult one there.

Another question: do you think that new trustees should complete all modules of the trustee toolkit that the Pension Regulator offers within the first six months? So the Pension Regulator said that trustees should have a period of training to get up to scratch within six months, and what do you see with clients using it?

Mixed views on that. It is important to note that it is not fundamentally a requirement and also to look at the skills and training requirements of the individual, so if you had someone who was PMI qualified and trained, then teaching them how to suck eggs by doing the whole of the trustee toolkit might not be relevant and it is a fairly decent time commitment, it does take time to go through it. That said, it is useful, it sets out scenarios that you might not have thought about if you have not taken a trustee role before and also you get your confirmation that you have completed it at the end which might be helpful if you need to demonstrate what you have been doing for TKU.

Joanne: Yes, I think the only thing I would add to that is that I have got trustee clients that say yes you should complete the toolkit within the first six months, but I have got some who provide their own training programme in which case there may be duplication there. And people have got busy day jobs, so it is just working out what works best for your scheme and the context of what you are providing, but I do think it would be a useful tool.

Ian: Yes exactly. OK Mags, what results did we get for the last poll?

Margaret: More than 50%25 of you are using technology a little, but they are mainly still paper based Ian.

Ian: No, that does not surprise me, and again it just goes back to looking at your membership, what is appropriate and also the value for money point because there is no point buying a very expensive piece of visual communication that cannot represent value for money just for the sake of having digital communication. People have been writing letters for centuries for good reason because it is a very good way of conveying information. That said, there are ways of doing things cheaply and over time the mixture of digital communication, that is going to become more common.

So just before we ring off, I just want to highlight a couple of future events that might be of interest. We are one of the panel speakers at the DC Insight Conference on 26 October. You can find out more about that in the resources tab. There is a link through to that that you can register. There is also our All about Age evening event on 4 October which, again, details of that are in the resources tab.

And that is all from us. Mags?

Margaret: OK, so it just remains for me to say thanks for joining us for this webinar on the DC Code and Guides. Just before you go, there is a very short feedback questionnaire and we would really appreciate it if you could take a moment just to fill this in. This helps us to ensure we cover the issues that you are really interested in.

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So finally, thanks to Ian and to Jo and to you guys for making the time to join us today. Thank you.

Ian: Thank you very much.

Joanne: Thanks very much.