igc annual statement. - legal & general … · 3 legal & general independent governance...

LEGAL & GENERAL INDEPENDENT GOVERNANCE COMMITTEE

IGC Annual Statement.For the year ending 5 April 2017

2 LEGAL & GENERAL INDEPENDENT GOVERNANCE COMMITTEE

CONTENTS.Introduction

Executive Summary

The audit of charges and benefits in legacy schemes

Value for money

Price

Default investment strategies

Returns

Flexibility

Administration

Communication

Feedback

With Profits ‘value for money’ assessment

Conclusion

IGC members

IGC member profiles

3

4

6

7

7

11

12

13

15

15

16

19

20

21

22


INTRODUCTION.Welcome to the second annual Independent Governance Committee (IGC) statement. I am delighted to be able to share with you the progress the IGC has made since our last report.

The second year has seen Legal & General continuing to invest in its relationship with the IGC and this has resulted in continued improvement in the quality of information provided to us and has driven more informed debate. Legal & General have appointed a relationship manager to co-ordinate IGC activity and to work alongside the IGC’s Pension Scheme Manager, strengthening our interaction with the business.

There have been some changes to the composition of the IGC during this year. Paul Trickett stood down as the Chairman last summer. We are very grateful to Paul for his considerable efforts in representing members’ interests over the initial period of the IGC’s existence.

I took on the role of Chairman on an interim basis having been an independent member of the IGC since it was established. Whilst finalising this report the process to appoint Paul’s successor has concluded and we are delighted to be able to announce that Dermot Courtier will become the new Chairman.

During the year we appointed Dr Ali Toutounchi as an IGC member. Ali was formerly managing director of Global Index Funds at Legal & General Investment Management. Ali’s considerable investment management experience will be of great benefit to the IGC as we look in more detail at investments and investment costs.

Last year we introduced you to the IGC’s Statement of Intent. The statement outlines the IGC’s approach to the assessment of ‘value for money’. The IGC used its Statement of Intent, along with the implementation plan from the audit of charges into older pension schemes (Independent Project Board (IPB) report), as a basis for its 2016 business plan. Details of the progress made against this plan are included later in this report.

In 2016 the IGC also considered the ‘value for money’ offered by Legal & General’s With Profit fund, for members in a workplace pension.

I would like to express my thanks to all those within Legal & General who have assisted the IGC by providing input and also to my colleagues on the Committee, and our support team, for their continued support and commitment.

We will continue to provide you with regular updates on our progress and will communicate to you through our member website, which can be found at www.landg.com/igc

I hope you find this report helpful and we look forward to making further progress over the next 12 months.

Steve Carrodus Interim Chairman of the Legal & General IGC Date: 31 March 2017

http://www.landg.com/igc

4LEGAL & GENERAL INDEPENDENT GOVERNANCE COMMITTEE

EXECUTIVE SUMMARY.

In our second year, the IGC has managed to make further progress; achieved through the quality of Legal & General personnel interacting with the IGC and the enhanced data that has been made available to the committee.

There were some changes to the IGC’s composition, with Steve Carrodus taking on the role of interim Chair, after Paul Trickett stood down. Whilst finalising this report the process to appoint Paul’s successor has concluded and Dermot Courtier will become the new Chairman of the IGC. Dr. Ali Toutounchi became an IGC member, adding considerable investment expertise to the committee.

In this year’s report we have reviewed 3 key areas;-

• Progress against the implementation plan from the audit of charges into older pension schemes (IPB report);

• A ‘value for money assessment’ of Legal & General’s contract based schemes, using the IGC’s Statement of Intent; and

• A With Profits ‘value for money’ assessment.

THE AUDIT OF CHARGES AND BENEFITS IN LEGACY SCHEMES. In its first year IGC agreed an implementation plan with Legal & General, which had a number of positive outcomes that would benefit members. The IGC was made aware that issues were identified during the course of this project resulting in Legal & General being unable to meet the original target for completion. A revised plan was agreed requiring all actions to complete by the end of March 2017.

The original audit identified that 9,000 members were potentially exposed to charges greater than 1% in Legal & General’s newer policies. When combined with actions already taken by employers and schemes whose charges have been restricted under automatic enrolment, the total saving for members will be approximately £0.5 million per annum, once implemented.

For older policies, a charge cap has been applied to all active and former members of workplace pension schemes. This charge cap will ensure that all charges are below 1% a year.


VALUE FOR MONEYThe IGC receives regular management information detailing annual management charges (AMC) and fund management charges (FMC). Progress has been made with transaction costs and charges. The IGC has been provided with an estimation of transaction costs that are payable within the default investment strategies and next year we are looking to gain greater oversight of the full fund range. IGCs are required to assess transaction costs, although there is not yet a regulatory requirement on fund managers to disclose this information in a standard way across the industry. The regulatory requirement for fund managers to fully disclose transaction costs is anticipated to come into effect towards the end of 2017.

On the subject of exit charges, Legal & General has confirmed that they will be implementing changes to meet the FCA rules that come into effect from 31 March 2017. Legal & General will be extending this charge cap to any member meeting the definitions of ‘ill-health’ before age 55 and it will be waived in cases of ‘serious ill-health’. The IGC had hoped that Legal & General would remove all exit charges but this will not be extended beyond the regulatory requirement at this time. Legal & General have committed to keeping this under review.

The IGC has been reviewing all the default investment strategies and the investment performance of all workplace pension plans within our scope. For Legal & General designed default funds Legal & General, together with the IGC, has undertaken a great deal of analysis and considered various alternative solutions and how these might be enhanced. This project is ongoing into 2017 and remains a key area of focus.

The second part of this review centred on bespoke default investment options (those where a specific default has been customised for a pension scheme). A questionnaire was sent to employers that have staged for auto enrolment, to collect details of the employer’s default review process. These responses will be analysed and the IGC will work with Legal & General on defining the appropriate next steps.

The IGC has reviewed what Legal & General are doing on the subject of environmental, social and corporate governance issues. This helps the IGC understand the steps that are taken to protect members’ money and what Legal & General do to engage and vote on poorly governed companies. This has been very useful and we requested that an update was provided to members at the IGC’s annual member forum.

The IGC still firmly believes that members should be able to access their pension savings in any way that is allowed by the regulations. We have reviewed the options available to members and have assessed Legal & General’s drawdown costs compared to their competitors, where such information is publically available.

The IGC considered the suitability of the default investment option in light of the increased range of flexibilities, following the introduction of pension freedoms in April 2015. The IGC believes this has been designed with the best interests of members in mind.

During this period the IGC has visited Legal & General’s administration centres in Hove and Cardiff. These visits are very valuable in increasing the IGC’s awareness of the processes and the level of interaction staff have with scheme members.

There have been some customer service process performance issues during the year but these have been addressed. We were pleased that Legal & General agreed to the IGC publishing their customer service performance levels on our website. The IGC continues to focus on the drawdown processes. Whilst current volumes are low in comparison to the overall membership, it is important that the IGC monitors Legal & General’s ability to respond as demand grows, with a scalable solution.

We are pleased that Legal & General are enhancing their member communications and this remains an area that we are focused on. Communications need to be clear and in a format that is available in a variety of media, if engagement is to be improved.

The IGC has interacted with members in a range of ways during this year; through our first Annual Member Forum, working with other pension providers on a survey which allowed the IGC to compare the views of Legal & General scheme members with those of members of other providers’ schemes and through regular attendance at employer groups that are hosted by Legal & General. We will continue to hear from members in as many ways as we can in 2017.

The IGC concluded that generally members do receive ‘value for money’, having considered all aspects within this report.

WITH PROFITS ‘VALUE FOR MONEY’ ASSESSMENTLegal & General’s With Profits management team attended a number of IGC meetings during 2016 to assist the IGC in making a ‘value for money’ assessment on the With Profits fund.

Based on the information presented to the Committee and the features that apply to this type of arrangement, the IGC believes that the With Profits fund does offer members ‘value for money’. The IGC are keen to see greater transparency in the composition of the With Profits fund charges in 2017.


THE AUDIT OF CHARGES AND BENEFITS IN LEGACY SCHEMES.

In our first statement we provided details on the Office of Fair Trading’s (OFT) report on charges for pension schemes that were established many years ago. This was followed by an audit by the Independent Project Board (IPB) across all insurance-based pension providers in the UK that are or were members of the Association of British Insurers (ABI).

The IGC agreed an implementation plan with Legal & General which had a number of positive outcomes benefiting members. The IGC’s expectations were that all of these actions would be completed by the end of September 2016.

The IGC’s remit spans across two divisions within Legal & General; Workplace Savings and Mature Savings. Workplace Savings administer pension products referred to as the Workplace Pension Plan, Group Personal Pension 2000 (GPP 2000) and Stakeholder. Mature Savings administer the Group Personal Pension Number One (GPP No. 1) product. The type of product that you have can be seen on your policy documents and your member’s booklet.

We were advised that the number of members subject to high charges as at the end of December 2015 stood at approximately 4,500 in schemes administered within Workplace Savings. This was reduced from the original estimate of 9,000 identified during the audit. 9,500 were identified in the Mature Savings division.

For all automatic enrolment qualifying schemes, charges are restricted by the government to no more than 0.75% a year (that is 75p for every £100 in your pot) for the default investment option. For non-qualifying schemes there is no government cap but Legal & General has agreed to take action on any scheme where members are being charged more than 1% a year.

During 2016, further Workplace Savings schemes became qualifying schemes and commission payments in respect of those

schemes were prohibited from April last year. The combination of this and voluntary activity carried out by Legal & General meant that members’ charges were reduced in total by approximately £0.5 million per annum.

The IGC was made aware that issues were identified during the course of this project resulting in Legal & General being unable to meet the original target for completion. Legal & General has implemented an action plan and committed to completing the work by no later than the end of March 2017. Whilst the IGC was disappointed by this delay we are pleased that Legal & General has agreed to backdate the charge reductions to September 2016, in line with their original commitment, to ensure that members are not disadvantaged by this delay.

In December 2016, the Mature Savings business unit implemented a charge cap to all active and former members of workplace pension schemes as agreed in the implementation plan. This cap will ensure that when members take their pension pot in the future, the amount they will receive will not be lower than the amount they would have received if a maximum charge of 1% a year had applied from 18 November 2016.

For With Profits members, the charge cap works in a similar way but the capped charge is averaged across With Profits policyholders. Other adjustments may be made, for example to cover an increase in the cost of guarantees and options, and these are outside the scope of the charge cap. Further details on the With Profits fund can be found on page 19 of this report.

The Mature Savings division has confirmed that applying this charge cap is expected to achieve reductions in charges valued in total at over £4 million.

7 LEGAL & GENERAL INDEPENDENT GOVERNANCE COMMITTEE7 LEGAL & GENERAL INDEPENDENT GOVERNANCE COMMITTEE

VALUE FOR MONEY.The IGC’s main purpose is to act in the interests of members by assessing and raising concerns about ‘value for money’. To do this the IGC needs to assess the quality of the scheme compared to its cost to members.

In our last report we shared our criteria for assessing the ongoing ‘value for money’ for members of workplace pension schemes operated by Legal & General. This focuses on seven key areas:

i. Price (charges) - this will cover any costs that relate to your pension arrangement

ii. Default investment strategies - default funds are the fund in which your pension contributions are invested if you do not make a specific investment choice

iii. Returns on your investment – how your investments perform

iv. Flexibility - members should be able to access their pension savings in any way the regulations allow (subject to pot size)

v. Administration - this will test the level of customer service that you receive and the speed and accuracy of financial transactions

vi. Communications - these should be clear and available in a variety of ways

vii. Feedback - In 2016 we committed to carry out an annual member survey, independently of Legal & General, to gain your views on whether you believe that you are receiving a ‘value for money’ service.

PRICE (CHARGES)Since the last statement, Legal & General has improved its management information on charges levied. This has allowed us to undertake a more informed assessment of whether the products are delivering ‘value for money’ to members and this is reviewed on a quarterly basis.

Annual and fund management charges

Members are charged a percentage of their fund value. For some products this consists of a single charge if the member invests in Legal & General funds (with an additional charge of at least 0.15% for external funds). For others it’s set as two separate components – an annual management charge (AMC) and a separate fund management charge (FMC) that varies, depending on the choice of investment option.

As we mentioned in the previous section, charges for all automatic enrolment qualifying schemes are restricted by the government to a total of no more than 0.75% per annum for the default investment option. Legal & General has also pledged that no auto-enrolled member investing in the current default option will pay more than 0.5%. Furthermore, although there is no government cap on charges for non-qualifying schemes, Legal & General has agreed to take action on any scheme where members are being charged more than 1% a year, to ensure that members’ pots are at or below this charge cap. This 1% charge cap is as defined in the IPB audit of charges and benefits in legacy schemes.

Transaction costs and charges

Transaction costs form part of the total costs of managing an investment fund and are incurred as a result of the buying or selling of assets. Some transaction costs are explicit and some are implicit.

• Explicit costs are known and may include taxes and levies (such as stamp duty reserve tax), broker commissions (fees which are charged in order to buy and sell investments such as equities) and the costs of borrowing or lending securities.

• The draft Financial Conduct Authority (FCA) rules for the disclosure of implicit costs will require the pension provider to calculate and disclose the difference between the price at which the asset is valued immediately before an order is placed and the price at which it is actually traded. In addition to the spread, this aims to capture other less readily identifiable costs such as the impact the trade has on the price of the security when it enters the market. The proposed methodology will not require these implicit costs to be broken down any further.

• Transaction costs incurred within a fund are likely to vary from one year to another. This is because they depend, to a large extent, on the level of trading activity within the fund (in other words, fund turnover) and the market liquidity during the period under consideration; the higher the turnover and/or the lower the market liquidity the higher the transaction costs.

IGCs are required to assess transaction costs, although there is not yet a regulatory requirement on fund managers to disclose this information in a standard way across the industry. The regulatory requirement for fund managers to fully disclose transaction costs is anticipated to come into effect towards the end of 2017. The FCA is consulting on the draft definition and calculation approach for transaction costs and Legal & General has been working with the IGC to provide information in advance of any regulations coming into force.


The concept of transaction costs is not simple but we will try to ensure that these costs and charges are fully available to pension scheme members and are presented meaningfully.

The IGC’s progress to date regarding transaction costs needs to be considered separately for funds that are managed by Legal & General and those which are managed by external managers:

a. Legal & General Funds

The IGC has been kept updated on Legal & General’s project to develop its capability to collate information to meet the regulatory requirements on transaction costs. The project will be delivered in two phases; the first phase will include explicit costs and an estimate of implicit costs for the default investment options for the contract based pension range of products, the second phase will extend the coverage to all available funds. This project cannot be completed until the FCA has published its prescribed methodology for the calculation of transaction costs later this year.

The first phase is expected to deliver towards the end of the first quarter of 2018. In the meantime, Legal & General have applied their own methodology to provide the IGC with an estimation of transaction costs that are incurred within the default investment options for their contract based pension range of products. Legal & General’s methodology uses the average spread for different asset classes to estimate implicit costs; a spread is the difference between the price demanded from buyers and the price offered to sellers in the market.

Whilst Legal & General have been able to directly calculate the explicit transaction costs for these estimates, it should be noted that the implicit transaction costs will carry a degree of approximation.

A summary of the information that Legal & General have provided to the IGC to date is shown on the next page. We will publish the outputs from both phases on our website as soon as they are available.

When you join your pension plan, any contributions that you and/or your employer make will be invested in the default investment option. The default investment option may be determined by Legal & General or chosen for you by your employer.

Where determined by Legal & General, your default investment option will be ascertained by the type of product that you hold and the date that you joined your pension scheme.

Your retirement savings may also have a default ‘lifestyle profile’ which means that as you approach your selected retirement date your savings will be gradually moved to a less volatile portfolio.

The table on page 9 will help you to establish which default investment option and lifestyle profile applies to your retirement savings and, using 2016 as an example, the estimate of the transaction costs incurred in managing your investment.


Product type Worksave Pension Plan

Worksave Pension Plan

Group Stakeholder Plan

Group Stakeholder Plan and Group Personal Pension 2000*

Date of joiningBefore October

2015October 2015

onwardsBefore April

2013April 2013 onwards

Default investment option

Multi Asset Fund Multi Asset Fund UK Equity Index Multi Asset Fund

Lifestyle profileTen year derisking

No lifestyle profile overlay

Ten yearderisking

Ten yearderisking

Lower volatility fund allocation for lifestyle profile

75% L&G Over 15 years Gilts Index Fund

25% L&G Cash Fund

N/A

75% L&G Fixed Interest Fund

25% L&G Cash Fund

75% L&G Over 15 years Gilts Index Fund

25% L&G Cash Fund

Fund name L&G Cash Fund


L&G Cash Fund L&G Cash Fund

Transaction costs

0.001% 0.001% 0.001%

Administration and fund management charges

0.48% 0.50% 0.50%

Transaction Charges

Fund name L&G Multi Asset Fund

L&G Multi Asset Fund

L&G UK Equity Index Fund

L&G Multi Asset Fund

Transaction costs

0.06%** 0.06%** 0.02% 0.06%**


0.50% 0.50% 0.50% 0.50%

Fund nameL&G Over 15 years Gilts Index Fund


L&G Fixed Interest Fund

L&G Over 15 years Gilts Index Fund

Transaction costs

0.02% 0.24% 0.03%


0.47% 0.50% 0.50%

*Note – there was no default investment fund on the GPP2000 product for joiners prior to April 2013. **Costs are estimated and provided on a best endeavours basis by LGIM based in part on their own methodology pending the finalisation of a market standard. A range of costs (0.04% – 0.08%) has been provided for the Multi-Asset Fund as the calculations are sensitive to rapid growth in fund size in the year and the multi layered aspect of the fund structure. In this table we have assumed a mid point of this range (0.06%).


Transaction Charges - 7 years from retirement

Blend allocation 69.2% L&G Multi Asset Fund23.1% L&G

Over 15 years Gilt Index Fund7.7% L&G Cash

Fund

60% L&G UK Equity Index

Fund30% L&G Fixed Interest Fund

10% L&G Cash Fund

69.2% L&G Multi Asset Fund23.1% L&G

Over 15 years Gilt Index Fund

7.7% L&G Cash Fund

Transaction costs 0.05%


0.09% 0.05%


0.49% 0.50% 0.50%




12.7% L&G Cash Fund



15% L&G Cash Fund



12.7% L&G Cash Fund



0.12% 0.04%


0.49% 0.50% 0.50%




17.7% L&G Cash Fund



20% L&G Cash Fund



17.7% L&G Cash Fund



0.15% 0.03%


0.48% 0.50% 0.50%

Where the default investment option has a lifestyle profile we have provided details of the transaction costs that would apply to your retirement savings if you were 3, 5 or 7 years away from your selected retirement date, so that you can understand how these costs are impacted by the gradual movement to alternative funds.

As an example, in the table above, with assumed transaction costs of 0.06%, the L&G Multi Asset Fund indicates that for every £1,000 of investment in this fund, transaction costs of 60p will be incurred, as a result of trading activities judged necessary by the fund manager to achieve fund objectives.


b. External Funds

Legal & General has commenced a project to obtain details of the transaction costs incurred on externally managed investment funds. Legal & General has written to the external investment managers of funds in their contract based pension range of products seeking information on the level of transaction costs, with mixed success.

Legal & General believe that it is unlikely that they will be able to obtain the necessary disclosure on transaction charges from external managers until the first quarter of 2018, once the FCA’s requirements have been formally published. The IGC has asked that Legal & General continue to pursue this.

Exit Charges on Legacy Schemes

In our last report, we made reference to the fact that we still had to reach agreement with Legal & General on the cost to members of taking pensions earlier than planned.

In response to Government direction, the FCA issued rules restricting the level of charges which can be taken from pensions when members take their benefits from age 55. The maximum level of exit charge has been set at 1% and these rules take effect from 31 March 2017. Legal & General has confirmed that they will be implementing changes to meet these rules. In addition, the exit charge cap will be applied to any member meeting the definitions of “ill-health” before age 55 and will be waived in cases of “serious ill-health”.

The IGC’s preference, conveyed to Legal & General, was to have removed exit charges completely by converting unit types subject to an exit penalty to units that simply carry an Annual Management Charge. Legal & General considered the IGC’s request and decided not to extend the charge cap beyond the regulatory requirement at this time.

The IGC are disappointed with Legal & General’s response but welcome their decision to keep their position under review. The IGC note that some other providers have made the decision to remove all exit charges.

Drawdown Charges

The IGC has reviewed the charges in relation to access to drawdown in retirement. Whilst the statutory cap on charges does not apply to drawdown, the IGC is keen to ensure that members continue to receive value once they have started to take their benefits. At Legal & General these remain broadly in line with other providers in the market. We have, however, asked Legal & General to give further consideration to the set up charge levied for flexible drawdown.

DEFAULT INVESTMENT STRATEGIES

The IGC has been reviewing all the default investment strategies and the investment performance of all workplace pension plans within our scope.

The IGC identified that this is a significant piece of work and appointed a sub-committee to undertake some of the more detailed work required as part of the review. The sub-committee was supported in this activity by Legal & General and the IGC’s independent investment adviser; Dean Wetton Advisory Limited.

The review of default investment options was divided into two work streams:

a. Legal & General designed default funds; and

b. bespoke default investment options (those where a specific default has been customised for a pension scheme).

a. Legal & General Designed Default Investment Options

The IGC has undertaken a review of Legal & General’s four default investment options, as outlined in 2a above.

You will be aware that last year the government’s pension freedoms’ initiative provided pension scheme members with much greater flexibility in how they could use their pension pot. Members can draw down a regular or occasional income from their pot, buy a pension annuity (a guaranteed regular income) or withdraw their savings as one or more cash lump sums.

As part of their response to the pension freedoms Legal & General reviewed and changed its primary auto enrolment default for new entrants in 2015. The default is now the LGIM Multi Asset Fund. This default does not automatically assume a particular retirement option will be chosen; three further solutions were introduced for members to select based on their chosen option. We talk about this later on in our report.

All other defaults in the above table were designed at a time when members were expected to purchase an annuity at their selected retirement date. Our independent investment adviser considered each default investment strategy and stated where improvements could be made, particularly to reflect the changing pensions landscape.

There are hundreds of thousands of members invested in Legal & General’s default investments, all at different stages of their investment journey, so changes require careful consideration. The IGC has asked that Legal & General consider carefully planned long term strategic changes that will offer flexibility as member behaviour evolves.


During this year Legal & General, in conjunction with the IGC, has undertaken a great deal of analysis and considered various alternative solutions and how these might be implemented.

This remains a key area of focus in the IGC’s 2017 business plan and further progress will be made throughout the next year.

We are also mindful that the government has just initiated a major review of automatic enrolment policy, including the level and scope of the charge cap on default funds and this will need to be borne in mind when progressing our work this year.

b. Bespoke default investment options

In conjunction with Legal & General’s review of their standard default investment options the IGC has also initiated a review of employer bespoke default funds.

Employers with such schemes have been approached and asked to provide details of their default review process. The aim is to ensure that all schemes with bespoke defaults are regularly reviewed by their employers and advisers. This exercise will continue during 2017.

The responses will be analysed as part of the IGC’s 2017 activity and the IGC will work with Legal & General on defining the appropriate next steps. The IGC anticipate that there will be schemes where an adviser is no longer in place and the default investment option may be unsuitable. Again, the IGC will work with Legal & General and our investment adviser to determine an appropriate response.

RETURNS

The IGC has continued to review the processes adopted by Legal & General to assess whether investment strategies and their performance against objectives are in accordance with member interests.

The formalisation of fund performance data and analysis took longer than the IGC anticipated in its business plan. To date the reporting and analysis of fund performance has been undertaken by Legal & General’s investment team. In order to provide an increased level of independence in the IGC’s oversight, we have agreed with Legal & General that our investment adviser will undertake this function from January 2017.

In the four years since Legal & General started to use the Multi-Asset Fund as part of its default investment strategy, the fund has achieved a return of 7.9% per annum. This covers the period April 2013 to December 2016.

Review of investment funds

In our last report, we mentioned that Legal & General had initiated a project to review their current investment offerings, with the aim of ensuring that the available funds are appropriate and are delivering good member outcomes. Where this was not the case these funds would be closed.

This project reviewed the fund ranges available on the Legal & General investment platform for its workplace personal pensions. The focus was on the actively managed funds reflecting their higher charges and the IGC’s desire to ensure that members were deriving positive benefits from the higher charges paid. The IGC was taken through Legal & General’s quantitative performance assessment, involving the use of a number of risk-adjusted performance metrics, qualitative reviews of funds and fund management groups and regular fund manager interviews.

Additionally, the review concluded that availability of an extensive fund range might result in poorer member outcomes as it made decision making more challenging for members.

As a result, a number of actively managed funds were removed from the investment platform and this impacted approximately 6,500 members. These members were informed of the changes and encouraged to select an alternative fund. In the event of a member not making a selection Legal & General sought advice and selected an appropriate alternative for each fund that was being removed. The funds were closed and switching activity took place in October. Members received communication throughout the process.

Passively managed funds are regularly monitored to ensure that they meet their performance targets. The IGC is still satisfied that these funds are meeting their objectives.

Environmental, social and corporate governance

The IGC has reviewed what Legal & General are doing on the subject of environmental, social and corporate governance (ESG) issues. We wanted to understand the steps that are taken to protect members’ money and what Legal & General do to engage and vote on poorly governed companies. The subjects we covered were:-

• Legal & General’s approach towards active governance;

• How they attempt to raise market standards;

• Company engagement and voting activities;

• Addressing climate change;

• Views on executive remuneration; and

• Legal & General’s current engagement focus.


We also invited Legal & General to the IGC’s annual members forum to present on this subject, so that members could hear about these matters and could ask questions directly on these subjects. Our annual forum is covered in more detail later in this report.

Legal & General undertakes extensive work on ESG issues and you can read more about their activities in their corporate responsibility report.

FLEXIBILITY

In last year’s report the IGC explained that the subject of pension freedoms is outside of the IGC’s scope but we consider it to be a key indicator in delivering ‘value for money’. We want members to be able to access their pension savings in any way allowed by the regulations.

Legal & General hold similar views to the IGC on this subject, although currently it does not offer flexible drawdown to those with pension pots of less than £30,000. Whilst drawdown is not available through some older products, Legal & General has put in place a practical solution which allows members to transfer to a section of the Legal & General Mastertrust Pension Scheme in order to access this benefit. The governance surrounding this arrangement and associated investments is undertaken by the Trustees of the Legal & General Mastertrust.

As reported last year, in response to the IGC’s request for a review of the default investment strategy, Legal & General introduced a new well-structured and appropriate default option. A desirable feature of this new fund is the flexibility it offers to members as they approach retirement. This fund does not automatically assume a particular retirement option will be chosen. Instead, three solutions are made available for members to choose; be that drawdown, an annuity or a cash based solution. The IGC believes this has been designed with the best interests of members in mind.

As these investment solutions do require members to make a choice as they approach retirement, the IGC has looked at the process that Legal & General has in place for notifying members that a choice needs to be made. Members are contacted at appropriate times and the IGC is satisfied that these communications are clear and timely. Currently, these communications only exist in letter format and the IGC would like to see such communications also delivered digitally.

The letters were introduced in August 2016 and the IGC receives regular management information on the actions that are being generated following the issuing of these. It is too early to comment on the impact of these communications but they will continue to be monitored in 2017. Moreover, focus groups on pension freedoms have been held this year and this has been helpful in better understanding member behaviour. Further detail on the focus groups is included under the section titled ‘Communication’.

http://reports.legalandgeneralgroup.com/2015/responsibility/

14 LEGAL & GENERAL INDEPENDENT GOVERNANCE COMMITTEE 14LEGAL & GENERAL INDEPENDENT GOVERNANCE COMMITTEE


ADMINISTRATIONThe quality and timeliness of service that members receive is a key part of the assessment of ‘value for money’. We review the time it takes for Legal & General to respond to member requests, the quality of Legal & General’s servicing and members’ views on the service received.

During the year significant enhancements have been made to the quality of management information on service performance that has been provided to the IGC. The IGC receives updates on service performance on a bi-monthly basis and the IGC’s Pensions Manager receives monthly information covering service performance, volumes, trend analysis and commentary against each process within the IGC’s remit. During 2016 the IGC started to publish service performance statistics on its website on a six monthly basis. This will continue in 2017.

In the first half of the year, the IGC was made aware of some service issues in one part of the Legal & General business in relation to the settlement of pension benefits. The IGC sought a commitment from senior management to address this and the position in the second part of the year was much improved. The IGC will continue to monitor these services.

One particular area of focus for the IGC is drawdown. Post Pensions Freedoms the ability to offer an efficient drawdown service has become increasingly important. Whilst current volumes are low in comparison to the overall membership, it is important that the IGC monitors Legal & General’s ability to respond as demand grows. The IGC is keen to see that full automation is fully in place as soon as possible in order that demand is met as volumes of drawdown requests increase.

In June 2016, the IGC visited the Mature Savings division at the Legal & General Hove office and in January 2017 the IGC visited the Workplace Savings division at Legal & General’s Cardiff office. The IGC received a number of presentations from the Leadership team of each division and spent time listening to customer calls. The IGC was very impressed with the professionalism and enthusiasm of the staff in the contact centres and their focus on providing good customer service.

Legal & General has provided the IGC with the assurance that all transactions are processed in accordance with the contractual terms, ‘backdated’ if necessary to reflect the request or receipt date, ensuring no member is disadvantaged because of any delay.

The IGC receives updates from Legal & General’s Group Internal Audit function and is made aware of any concerns relating to the IGC’s areas of oversight.

The IGC is satisfied that there are no areas of concern in relation to core financial transactions. In 2017, the IGC will seek member views on the time taken to withdraw their funds. Many providers measure themselves against service level metrics that are deemed to be ‘industry standard’ rather than member specific benchmarks. This is not unique to Legal & General but is reflective of the industry. We will share the results.

COMMUNICATION

The IGC stated last year that it had a desire for members to be able to access information and make changes to their pension arrangements using a means of communication of their choosing. In 2016, Legal & General applied mobile optimisation to their Manage Your Account website. This is the site where members can log-on to manage their pension account. Analysis was provided to the IGC on why Legal & General pursued mobile optimisation rather than an app. The IGC is keen to conduct further research into mobile and tablet behaviour in 2017, specifically in relation to the management of financial services.

During 2016 Legal & General completed three major pieces of research with external research agencies. The IGC was informed of each and attended some of the focus groups.


i. Online documents and member engagement

This project sought to understand the likely levels of engagement with online pension benefit statements. This project specifically reviewed:

• The use of different communications channels, devices, mobile apps and websites when dealing with financial services and pensions

• Current methods of engagement with pension communications

• Communications preferences and willingness to engage with pensions digitally

ii. Pension reform research

This research examined the experiences and behaviours of Legal & General workplace pension customers who have accessed their pension pot using the new pension freedoms.

iii. Customer journey user testing

This was a review of the communications the member receives from the point of joining a Workplace scheme. The research tested the new member experience with Legal & General workplace pension customers and asked for feedback on:

• Microsite content and navigation

• Look and feel, length, tone of voice, signposting and clarity of key documents in the journey

• How well members identified with the stages of the journey

• Areas for improvement

The key findings from these pieces of research were presented back to the IGC.

Since the research has been conducted the IGC has been informed of the actions that have been taken:

• Research findings have been utilised in the design of Legal & General’s new member communications

• Legal & General’s online pension benefit statement notifications have been re-written and re-designed to focus on key messages of simplicity, security and ease of use with more informal language

• Legal & General will work with a number of large employers with an objective to increase the number of members who use the online facilities. This will start in the second quarter of 2017

FEEDBACK

In last year’s report we outlined our desire to receive feedback directly from members. In 2016, the IGC committed to putting in place an independent survey and hosting a forum that our members could attend to interact directly with their IGC. Legal & General have also invited the IGC to send a representative to their quarterly employer forums.

IGC Annual Member Forum

In October 2016, the IGC held its first Annual Member Forum. The session was organised and run by the IGC independently of Legal & General and was the first of its kind.

Approximately 70 scheme members attended, receiving updates from the IGC on the IGC’s remit, 2016 progress and presentations on topical issues such as environmental, social and corporate governance matters.

Member feedback from this event was both positive and helpful and IGC would be delighted to hear from members with suggestions for topics for our 2017 event. If you do have any feedback please do email us at: [email protected]


ANNUAL MEMBER SURVEY.

Background

The IGC believes it is very important that it has a mechanism in place to be able to understand what ‘value for money’ means to members. As an IGC, we have a lot of experience in understanding pension matters but we need to be sure that the areas we are progressing are the ones that are important to members.

In our last report, we stated that we would put in place an independent survey in 2016. The IGCs of other pension providers were also very keen to adopt a similar approach. Accordingly, eleven IGCs collaborated in an extensive member survey. The aim of the survey was to develop a common understanding of what members value and how each provider performed against these attributes.

Working with other pension providers allows the IGC to compare the views of Legal & General scheme members with those of members of other providers’ schemes.

The providers who worked together on this were: Aegon, Aviva, Fidelity International, Legal & General, Old Mutual Wealth, Prudential, Royal London, Scottish Widows, Standard Life, Virgin Money and Zurich.

The results were shared with the IGC in January and gave a helpful insight into what matters to members. The IGC would like to thank the 3,138 Legal & General pension scheme members who took part in this survey. It was a much higher response rate than we had anticipated and we received a balanced respondent mix by gender, age and fund size.

What members value

NMG Consultancy was selected to undertake this research, as a specialist survey organisation with an excellent track record of survey and data analytics.

Members were asked to rate a number of attributes on their importance in contributing to value. The attributes that Legal & General members considered to be ‘highly appealing’ in their view of what represents value included:-

• Receiving a good return on money paid into their pension pot;

• The controls and safeguards that are in place to protect members pots;

• Employer contributions being at least equal to that of the member;

• Having a reputable, financially strong pension provider;

• Receiving tax relief on pension contributions;

• Being able to take pension benefits flexibly; and

• Having a guarantee that members will get back at least as much as is paid in.

The views of Legal & General members were very similar to those of the other providers. The value placed on attributes did vary slightly across age, gender and fund value but not significantly.

Awareness and use of the attributes

Members were asked how aware they were of the existence of each of the attributes within their own arrangement. Interestingly, the attributes which scored more highly for awareness were attributes that had featured as less appealing with regard to ‘value for money’.

Satisfaction and ‘value for money’

In terms of overall satisfaction and perception of ‘value for money’, Legal & General’s scores were broadly in line with the rest of the market. However, members with significant fund values scored Legal & General slightly behind the market average for all members with significant fund values. Whilst the range of scores was not wide, nonetheless, the IGC will work with Legal & General to analyse this outcome more closely and consider what can be done that will lead to higher satisfaction ratings by members with higher fund levels, both in absolute terms and against the market.


Legal & General members were most satisfied with the following attributes, where an average rating of seven or above, out of ten, was provided:-

• Being able to take pension benefits flexibly, which had the greatest variance from other providers;

• Being able to easily amend the amount they were paying;

• Having a reputable, financially strong pension provider;

• Having a simple process to transfer old pensions across to Legal & General;

• The option to move to higher risk, higher cost funds;

• Having access to a range of funds; and

• Receiving back as much as had been paid in.

Compared to the market, Legal & General satisfaction ratings were above the median for the flexible options they offer members when it comes to taking their pension benefits and they scored well for providing updates through email. Members’ views on charges were average when compared to other providers.

The IGC has found it interesting to see that the member satisfaction of Legal & General’s provision of access to online tools and calculators, mobile applications and clarity of communications were below the median for the group. All of these are areas that Legal & General are developing and the IGC has been kept updated on progress against these. The IGC are keen that these developments are shared with members as they become available so that they may benefit from them.

The survey results also suggested that some members are not aware of all of the services that are available to them. This data requires further analysis; context may provide an explanation as to why members may not be aware of certain attributes, but we will work with Legal & General to seek improvement in this area.

Conclusion

The IGC is grateful to Legal & General for having supported our participation in this survey and for funding this initiative. The IGC would also like to thank NMG for such a comprehensive exercise, the first of its kind in this industry.

Whilst results may tell us that Legal & General were broadly in line with the market in terms of member satisfaction and ‘value for money’, this is not licence for complacency. We have identified areas that need to be addressed specifically, but we would like to see an absolute improvement in these scores in all areas, not only at Legal & General but across the industry as a whole. However, we believe this has been a positive first step.

The results of this survey were presented to the IGC in late January 2017 and it is important that we now work with Legal & General to agree a plan to try to improve some specific areas and all areas more generally. This will be included in the IGC’s 2017 Business Plan and we will share our progress on our website throughout the year.

The member survey is just one component that is considered when making an overall ‘value for money’ assessment. It is important that the expertise and experience of the IGC are also applied across all factors that impact the ‘value for money’ that members receive. We would like to work with Legal & General and the representatives who manage employer pension schemes to better understand how pension communications can be made more engaging and to consider other methods that can be used to raise awareness.

Quarterly employer groups

Legal & General use the quarterly employer groups to provide employers with updates on regulatory changes, areas of focus and member communications. At each meeting the IGC is invited to update the employers on our progress and hear from employers on areas of potential concern and future areas they would like to see the IGC focus on. This has proved a very useful means of gaining feedback throughout the year and we will continue to attend these meetings in 2017.

In addition, we will also commit to meeting with at least six employers in 2017 to obtain direct feedback from them on their pension arrangements and to better understand how they communicate with their employees.


WITH PROFITS ‘VALUE FOR MONEY’ ASSESSMENT.An assessment of the ‘value for money’ provided by the With Profits fund was undertaken during this period. With Profits policies offer smoothing to even out some of the short-term fluctuations that may be experienced when investing directly in the stock market or other investments and guarantees such as contractual interest.

Legal & General’s With Profits Management team attended a number of IGC meetings during 2016 to assist the IGC in making a ‘value for money’ assessment.

Legal & General’s With Profits fund has around 650,000 customers and £17 billion of assets. Within the fund the IGC has responsibility for 2 products. For Group Personal Pensions there are around 127,000 members and the Personal Pension 2000 product contains around 72,000 members.

This review considered the following areas:-

• Key features - the potential characteristics of the fund that customers value

• Governance and oversight – the framework that is in place

• Charges – whether the costs associated with an investment in With Profits is fair

• Investment and performance

• Communications and feedback – whether customers have access to sufficient information to enable them to make informed decisions

Key features

With Profits policies offer smoothing to even out some of the short term fluctuations that may be experienced when investing directly in the stock market or other investments. Policies also offer guarantees at contractual points (e.g. selected retirement date and death), where the value of the units, including any annual bonus added, will be the minimum amount paid, regardless of the investment performance. Some policies have a minimum guaranteed return.

With Profits policies may also apply Market Value Reductions (MVR). An MVR may be applied to make sure that all policyholders get their fair share of the assets. An MVR is usually applied when investments haven’t performed as well as assumed when setting bonuses.

At the time of publishing this report there are no MVRs applied to the policies within the scope of the IGC.

Governance and oversight

There is a policy to support the key features of the With Profits fund. The Fund has a stated methodology for its bonus practices; supporting some of the underlying guarantees alongside the approach to smoothing.

Legal & General has shared in detail their governance and oversight of the With Profits fund and the IGC is satisfied that they are robust.

Charges

For the purpose of setting bonuses these products are grouped with other pension policies written on the same administration platform. This feature means that the charges are effectively averaged across the wider set of policies implicit in the bonus rates.

The charges cover the following items:

• Monthly plan fees

• Bid-offer spreads applied to premiums

• Transfers to shareholders

• Additional expenses

• Miscellaneous profits & losses

• Investment expenses

In setting bonuses there may be additional charges for guarantees and options. Where these are applied the amount is explicitly stated in customer communications.

The IGC was reassured that the equivalent charge within the With Profits fund is less than 1% over the year. Legal & General stated that they would not expect this figure to vary substantially from year to year.

The IGC would like to better understand the transaction costs and charges within the With Profits fund and Legal & General have confirmed their commitment to helping us achieve this in 2017.

Investments and performance

The underlying investments of the fund provide customers with exposure to a spread of underlying assets whilst maintaining a relative degree of protection through the application of smoothing.

This element of the fund and the governance oversight are evidenced by the mid-year increase to the final bonus rates that was made to reflect the better than expected return on investments over the first part of 2016.

Over 25 years the assets held on behalf of Legal & General’s With Profits members have returned 8.5% per annum and over 10 years the annual return is 5.5%, which is higher than an average balanced managed fund and RPI inflation.


Communications and feedback

A range of customer communications in relation to With Profits investments were shared with the IGC.

The IGC also received a report detailing that customer feedback was last obtained in 2014 regarding the content and format of the bonus declarations and some of the With Profits statements. The IGC were presented with examples of how this feedback was acted upon to simplify customer communications.

The IGC would like to seek further feedback from With Profits members in 2017, given the complex nature of the product.

With Profits ‘value for money’ assessment conclusion

The IGC has considered the above and, based on the information presented to the Committee, believes that, with an equivalent charge of less than 1%, when considered alongside its other features, the With Profits fund can be deemed to offer members ‘value for money’.

In 2017, the IGC wish to see greater transparency in the composition of this equivalent charge. If you do have any feedback on Legal & General’s With Profits policies please do email us at: [email protected].

CONCLUSION

We are pleased that the IGC has been able to make greater progress this year. As mentioned throughout our report, Legal & General has continued to invest in its relationship with the IGC. We have had access to better quality information and this has led to much improved discussion and debate. We have regular reporting now for customer service level performance and have been publishing these results on our website. We have reviewed customer satisfaction scores, investment reports and had sight of monitoring and oversight reviews. The reporting of charges (AMC and FMC) has been enhanced but we do want to make more progress in detailing transaction costs and charges. We have been provided with an estimation of transaction costs that are payable within the default investment strategies and we are looking forward to reviewing these costs across the full fund range.

We have had greater insight into what members think about their pension provision through focus groups and surveys. The IGC have always believed that members should have flexibility to take their pension savings in any way allowed by the regulations and the survey confirmed that this is something that Legal & General members value.

The review of the default investment funds has been an extensive piece of work and this will continue to be a large initiative throughout 2017. The Legal & General default investment options are one aspect of this review but there are also bespoke default arrangements selected by employers with their advisers. We suspect that in some cases the relationship with the adviser is no longer in place. We will work with Legal & General and the IGC’s investment adviser on the management of this.

Having considered all aspects within this report, we have concluded that generally members do receive ‘value for money’.

In 2017, we would like to make further progress on making all charges transparent and we will keep Legal & General’s position on exit charges under review.

We will keep a strong focus on member views and will take action from the output of the member survey. We would like to see further progress on member communications, which we note are being overhauled with the support of external communications specialists. The survey shows that members currently do not know of all the services that are available to them and we want this position to be improved.

This year’s member forum was a success and we will host a further one in November of this year. The IGC will consider how we can reach more members this year and are open to any suggestions that members may have; both on increasing member numbers at the event and topics that members would be interested in hearing about.

Please do feel free to contact us at [email protected] to discuss any IGC related matter.

mailto:igc_members%40lgim.com?subject=


IGC MEMBERSThe IGC has been established to ensure it has sufficient expertise, experience and independence to act in members’ interests. This is assessed annually through an evaluation, with the last one having been completed in December 2016.

This evaluation covers the IGC’s composition, an assessment of how the IGC members view their independence and the independence of each of its members and gives consideration to the diversity of its membership, performance, skills and effectiveness.

Legal & General appointed Odgers Berndtson, an executive search firm, to assist with the search for the new Independent Chair. Odgers Berndtson produced a long list of candidates from which four candidates were identified and invited to attend first round interviews. The Interim IGC Chair was a part of the interview panel. The preferred candidate was invited to meet with Mark Zinkula, Chief

Executive LGIM, and Sarah Aitken, Head of Distribution EMEA. A second interview was then held with the Chairman and an Independent Non-Executive Director of Legal & General Assurance Society Limited (LGAS), prior to a recommendation being made to the LGAS Board.

Following this process Dermot Courtier was appointed as Chairman of the Legal & General IGC on 1 March 2017.

The Independent Members of the IGC have not:

• been employed within the Legal & General Group during the year or the five years preceding their appointment

• had any material business relationship with any company within the Legal & General Group during the year or the three years preceding their appointment, except for being trustees of the Legal & General WorkSave Mastertrust

The combined knowledge and understanding of the IGC, together with the advice that is available to them through their appointed legal advisers (Pinsent Masons) and their independent investment adviser (Dean Wetton Advisory Limited), enables them to fully exercise their responsibilities as IGC members.

The full Terms of Reference for the IGC can be found here.

http://www.legalandgeneral.com/workplacebenefitsResp/igc/terms-of-reference/

http://www.legalandgeneral.com/workplacebenefitsResp/igc/terms-of-reference/

22

IGC MEMBER PROFILES.

STEVE CARRODUS Interim Chairman Independent Member

Steve is a director of Pitmans Trustees Limited.

Steve has worked in corporate pensions and employee benefits since 1973 and has worked for a number of major pension consulting firms including Willis, Sedgwick, Godwins and SBJ. He’s been involved in trusteeship work since 1991.

For much of his career Steve has been advising medium sized pension funds on all areas relating to the setting up and running of pension schemes and in some cases in their closure. More recently Steve has been involved with a number of Master Trusts and another IGC.

Steve has a good understanding of investment issues and uses his experience to ensure that the scheme’s advisers are challenged and their advice is fully understood by all trustees.

Steve served for four years on the council of the Pensions Management Institute and has spoken at a number of technical seminars for clients and on trustee training courses.

DERMOT COURTIER Chairman Independent Member

Dermot was appointed Chairman of the Legal & General Independent Governance Committee with effect from 1 March 2017. Dermot also acts as Chairman of the Legal & General Mastertrust.

Dermot is Head of Group Pensions at Kingfisher plc. as well as Secretary to Kingfisher Pension Trustee Limited (KPTL), which oversees the governance and the running of the Kingfisher Pension scheme (KPS). Since 2007, Dermot in his executive capacity, has overseen KPS’s de-risking programme and the enhancement of DC benefit structures and investment funds. KPS has won numerous awards, in particular for its pioneering financial education programme for DC members.

Dermot has held senior pension roles at Hachette Livre Group, Towers Perrin HR Services (now Willis Towers Watson) and Royal Mail Group. He is a member of the PLSA DC Council.

RACHEL BROUGHAM IGC Member Independent Member

Rachel is a trustee executive at BESTrustees Limited. Rachel is a qualified actuary and has worked in the pensions industry since 1988.

Rachel’s experience includes advising both defined benefit (DB) and defined contribution (DC) trustee boards and the governance committees of various contract-based DC arrangements through which she has built up a detailed knowledge of the regulatory environment.

With Rachel’s previous employer, the global consultant Mercer, she led a number of national initiatives including pension fund governance (both DB and DC) and pensions automatic enrolment.

Rachel is a regular commentator on pension matters through speaking at industry events and contributing articles and comment to the industry press.

Having joined BESTrustees in 2014, Rachel’s appointments include two master trust trustee boards and membership of two independent governance committees.

LEGAL & GENERAL INDEPENDENT GOVERNANCE COMMITTEE


TONY FILBIN IGC Member Tony studied law at Hull University and joined Legal & General in 1979 where he held a number of senior positions rising to Managing Director Workplace Savings.

In Tony’s various roles he was responsible for Legal & General’s suite of retail pension and annuity products including the development and implementation of their award-winning auto-enrolment proposition.

Since leaving Legal & General in 2014, Tony has taken up a number of pension trustee board positions and non-executive director roles.

Tony is a regular speaker at pension conferences and has held committee positions with the Institute of Actuaries and the Pensions Management Institute.

In 2013 Tony was named by Financial News as one of the Top 10 Most Influential People In Pensions.

ALI TOUTOUNCHI IGC Member Ali has over 30 years of experience in investments. He was formerly Managing Director of Legal & General Investment Management’s Global Index Funds, overseeing the management of over £275 billion of assets on behalf of pension funds, institutional and retail investors.

Ali joined Legal & General in 1995 from NatWest Securities. Ali has held senior roles at UBS Asset Management and Wood Mackenzie Stockbrokers. Ali has a first class honours degree in economics and statistics from University College, London, and a PhD in actuarial mathematics from Heriot-Watt University, Edinburgh.


ANDREW FAIRHURST Secretary to the Independent Governance Committee Andrew worked on the launch of the Independent Governance Committee and has been Secretary to the IGC, since its voluntary introduction in 2013. Andrew’s role is to ensure the IGC operates efficiently and effectively to the highest governance standards and ensures that the IGC embraces and is at the forefront of changing governance practice.

Andrew reports through to the independent Chairman of the IGC and he also has an independent non-operational reporting line to Legal & General’s Legal & Governance function.

Andrew has held a number of senior company secretarial roles within Legal & General Group and is a Fellow of the Institute of Chartered Secretaries.

RICHARD ATKINS IGC Pension Scheme Manager Richard was appointed Pension Scheme Manager to the Independent Governance Committee in August 2015.

Richard’s role requires him to assist the IGC to satisfy its regulatory responsibilities, ensuring that pension schemes administered by Legal & General are of the appropriate quality and that ‘value for money’ can be demonstrated to the underlying scheme members.

Richard reports to the independent Chairman of the IGC and he also has an independent non-operational reporting line to the Legal & General Investment Management Risk & Compliance department.

Richard has worked in the pensions industry since 2000 where he has held a variety of senior management roles in both the defined benefit and defined contribution environments.

IGC SUPPORT SERVICES

For WPP schemes: Legal & General (Portfolio Management Services) Limited Registered in England and Wales No. 02457525 Registered office: One Coleman Street, London EC2R 5AA

We are authorised and regulated by the Financial Conduct Authority.

For all other schemes: Legal & General Assurance Society Limited. Registered in England and Wales No. 166055 Registered office: One Coleman Street, London EC2R 5AA

We are authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority.

Q0053900 NON-ASD

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