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Managed Pension Funds Limited

STATEMENT OF COMPLIANCE WITH S172(1) OF THE COMPANIES ACT 2006

The directors have acted in a way that they considered, in good faith to be most likely to promote the success of the Company for the benefit of its members as a whole, and in doing so had regard, amongst other matters, to:

  • the likely consequences of any decision in the long term;
  • the need to foster the Company’s business relationships with suppliers, policyholders and others;
  • the impact of the Company’s operations on the community and the environment;
  • the desirability of the Company maintaining a reputation for high standards of business conduct; and
  • the need to act fairly as between members of the Company.

In order to promote the success of the Company, the Board directs and supervises the Company’s affairs within a framework of effective controls which enable risk to be assessed and managed. The directors set the Company’s objectives and policies and standards ensuring that its obligations to the State Street Group, its policyholders and others are understood and complied with and that it operates high standards of business conduct. Management have an open and ongoing dialogue with the FCA and PRA to discuss regulatory priorities and strategic developments, the outcomes of which are regularly reported to the Board.

The Company has minimal suppliers in the conventional sense as it has outsourced all client facing, investment management and back office services to SSGA. The directors perform regular oversight of these services through review of operational reports, routine meetings with SSGA management and attendance by SSGA representatives at board meetings.

The directors monitor policyholder activity through regular review of financial and other reports on premiums and claims and the performance of the funds in which the policyholders are invested.
During the year the directors have also overseen the implementation of the Consumer Duty regulations across the Group and have received regular reports on how customer outcomes are monitored.

Streamlined Energy and Carbon Reporting (SECR)

The Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 have implemented the United Kingdoms (“UK”) Government’s policy on Streamlined Energy and Carbon Reporting (“SECR”). This new regulation, which came into effect for reporting periods beginning on or after 1 April 2019, require large unquoted companies that have consumed in the UK more than 40,000 kilowatt-hours (“kWh”) of energy in the reporting period to include energy and carbon information within their Directors’ Report.

The Company does not fall into scope of this regulation (as per s465 and s466 of the Companies Act 2006) and has elected not to voluntarily disclose company specific energy and carbon information.
The Financial Stability Board (FSB) created the Task Force on Climate-related Financial Disclosures (TCFD) in 2015 to improve and increase reporting of climate-related financial information. Following the release of the Task Force’s 2023 Status Report, upon request of the FSB, the TCFD has been disbanded.

The Company has a single shareholder, no employees, and given the outsourced nature of its operations, it has no direct impact on the community. Through its emerging risk and material risks reviews, the Board has considered its specific climate risk and additionally the Board has considered the broader environmental impacts of its activity. The Company has engaged closely with SSGA to understand its environmental position. The Company does not consider its physical and transitional climate risks to be material. The Group publishes an annual ESG report: https://www.statestreet.com/us/en/asset-manager/about/our-impact/esg-report.

By order of the Board

04 April 2024