The Worcestershire Pension Board met on 12 September 2025 to review several key documents and updates related to the management and governance of the Worcestershire Pension Fund. The agenda included discussion of the business plan, risk register, governance and compliance, training, and a forward plan. The board was also scheduled to discuss the pension fund budget forecast and an update from LGPS Central Limited, but the public and press were excluded from these discussions.

Risk Register

The board was asked to review the Worcestershire Pension Fund Risk Register from May 2024. A new risk, WPF 39, had been added to monitor the risk that LGPSC are unable to meet the Government's Fit for Future obligations by 31 March 2026 due to a lack of resource.

The mitigating actions for some risks had been updated:

• WPF07, focusing on 'increasing administrative complexity or failure to comply with the Pensions Regulator', had an update on progress against McCloud remedy¹ and the use of the determination to extend the deadline.
• WPF20, insufficient staff resource or remaining staff not having the skills to do their areas of work, noted that the Head of Pensions Administration was leaving on 2 November 2025, but that business as usual would be maintained during the recruitment period due to focused upskilling over the last 2 years.
• WPF29, 'failure to deliver member communications in line with regulatory requirements', noted that Annual Benefit Statements were delivered via the member portal as default this year with those who had opted out issued a paper version, and that every member received a letter advising how to register or access their ABS.

The risk register had undergone a review to ensure it is appropriate, especially in the current and future pensions landscape, and further reviews were scheduled following proposed training sessions being undertaken by officers in the coming months. A training session with Hymans Robertson Governance and Projects Team (GAP) was scheduled to take place on 30 September, involving members of the GAP team and Officers from the Fund taking part in a risk assessment workshop.

Governance and Compliance Update

The board was asked to review the Worcestershire Pension Fund Good Governance Position Statement and to note the Dashboard Data Match Criteria Policy, Under and Overpayment Policy and the draft Data Improvement Policy.

Senior Fund Officers, namely the Head of Pensions Administration and Head of Pensions Investments, had reviewed the conflicts of interests declared by members from the previous meeting held on the 19 June 2025 to offer reassurances that no declared conflicts exist.

The Ministry of Housing, Communities and Local Government (MHCLG) launched a consultation on the 15 May 2025 to promote 'access and fairness' to its scheme members, and the Fund submitted its response to the consultation ahead of the closing date of 7 August 2025.

The Good Governance Position Statement July 2025 summarised progress on how the council was taking forward the LGPS Scheme Advisory Board's (SAB) Good Governance workstream in preparation for statutory guidance being issued.

Progress in developing mitigating action for five risks was scheduled to be reported:

• WPF 01 Failure of governance arrangements to match up to recommended best practice.
• WPF 04 Not having an established and meaningful Business Plan / Pension Administration Strategy.
• WPF 15 Failure of the actuary to deliver the services contracted.
• WPF 17 Failure of custodian to deliver the services contracted.
• WPF 26 Fraud by staff.

The council had continued with its 2025 cyber security review and had issued cyber security questionnaires and supporting documentation requests to its third-party providers. It had opted to participate in the Cyber Security review of Heywoods conducted by AON, and had arranged a virtual meeting to take place with the administering authorities cyber security specialist to take place on the 22 October.

The Governance Team at Hymans Robertson had been instructed to commence an independent desk top review to assess compliance against TPR expectations of the General Code of Practice, and to undertake a review of the Risk Register and Risk Policy(s) to ensure their relevance.

A documented process of how the Fund manage its third-party providers/suppliers was being produced, including a full review of all existing contracts and arrangements supported by WCC Commercial/Procurement team. A draft policy had been created in respect of appointing third party providers, and had been shared with the WCC procurement team for any recommendations.

The Funds Privacy Notice had been updated to reflect McCloud.

The Draft Dashboard Data Match Policy stated that Worcestershire Pension Fund (WPF) would use a mix of verified and unverified data fields to ensure the highest possibility of matching individuals to their pension records. The following core identity data fields would be securely verified by the Identity service upon a user's request to find their pension via the dashboard:

• First name
• Last name
• Date of birth
• Email address(es)
• Mobile phone number(s)

Unverified information could also be supplied by individuals in order to match pension records, including:

• National Insurance Number
• Previous names (if applicable)
• Addresses

The Draft Under and Overpayment Policy set out the policy on Overpayment and Underpayment of Pension Benefits for Worcestershire Pension Fund, stating that the Fund has established procedures to ensure pension benefits are accurately disbursed to its members, but that in certain circumstances overpayments or underpayments may occur. In such cases, the Fund is obligated to recover any overpaid benefits, regardless of whether the overpayment resulted from administrative errors or other causes, and is committed to rectifying any underpayments as promptly as possible.

The Draft Data Improvement Policy outlined the approach that Worcestershire Pension Fund takes in respect to handling, managing improving and reviewing the data held on behalf of Worcestershire County Council, as the administering Authority.

Training Update

The board was asked to review the Training Update including the Training Policy and Programme and note the Training and Conferences Calendar.

The training delivered since the last Training Update had included the 'Pensions Basics' training session for members of the pension scheme, which had been offered to all active employees, with 7 sessions delivered so far this year (235 attendees), and the pensions team held an away day which included teambuilding activities, a cyber security training session, and updates on current and forthcoming workstreams.

As of 11 August 2025, the following percentage of registrations to the member portal were as follows:

• Active members: 44.45%;
• Deferred Members: 28.46%; and
• Pensioner Members: 30.77%

Following the recent bulk email exercise and the distribution of Deferred Annual Benefit Statements, there had been a significant increase in member portal registrations from 3,908 to 6,967.

Progress in mitigating the four risks since the last quarterly Board / Committee cycle had included Officers participating in various scheme / industry groups / forums to keep up to date on pensions issues.

For new members of the board/Committee a full induction was completed with the Head of Pensions Administration on 31 July 2025, and the Fund had now completed the Training Needs Analysis exercise, with the majority of forms received from Board and Committee members.

All PB/PC members had been issued login details and successfully registered with the LGPS Online Learning Academy (LOLA) to support their knowledge and understanding requirements.

The training team highlighted the upcoming Pensions UK Annual Conference 14-16 October in Manchester.

Senior Fund Officers had been completing the LOLA courses to help support and maintain their knowledge, and Officers attended PLSA webinar– The Pension Schemes Bill – what, why and how (26 June).

Workflow was being re-worked implementing a clearer checking process utilising Altair task flow and system controls, and implementing I-Connect also ensures that the Fund receive monthly data which will ensure data is accurate and up to date direct from the employer/payroll provider.

The Funds 'skills matrix' was being continually updated to ensure that team resilience is monitored, and appropriate training/cross skilling is implemented.

The Fund had invested in implementing apprenticeships for the business support roles and as of 31 August 2025, there were 3 officers enrolled, with one apprentice having successfully completed their qualification and been appointed as a Pensions Assistant.

Business Plan

The board was asked to review the Worcestershire Pension Fund Business Plan as of August 2025. The Business Plan is designed to be a one-stop-reference-shop for everything going on at Worcestershire Pension Fund and in the wider LGPS landscape. The Business Plan had had some amendments to ensure that it is clear in how the structure of Worcestershire Pension Fund supports the delivery of the Fund aims and objectives as detailed within the plan. The work plan for 2024/2025 – 2026/2027 had also been detailed to show what is coming up either as regular or ad hoc deliverables for the Fund and this is split across Administration, Governance, and Investments.

The Fund have delivered Annual Benefit Statements for both Deferred and Active members online for 2025/2026. 99.7% of eligible members were issued an ABS, however 91 members have not received one due to lack of information being received from employers.

Community Housing Group ceased as an active employer on 7 July 2025.

The Fund have been liaising with WCC procurement team and have started the process of gathering information from providers in respect of consultancy services associated with AVCs framework (LOT 2) and Legal services framework 2023 (LOT 5).

The relevant reports through Altair have been completed reviewing membership and in particular the in-scope members impacted by McCloud.

The Team have successfully implemented phase 1 of the ISP implementation working alongside Heywoods over November 2024 to January 2025, and have received approval from the PDP to connect to the eco system on 31 October 2025.

The Administration team have provided membership data so that Hymans Robertson could produce 'Contribution modelling results' for larger employers.

Forward Plan

The board was asked to comment on and approve the Forward Plan, which highlights the key areas that are anticipated to be reported in the future.