The Wiltshire Pension Fund Committee met on 9 October 2025 to discuss the triennial valuation of the fund, a new conflicts of interest policy, and a new breach policy, among other items. Representatives from Barnett Waddingham were expected to present the initial results of the 2025 triennial valuation for the Committee's review. The committee was also scheduled to review the forward work plan for the committee.

Triennial Valuation 2025

The committee was scheduled to review the initial results of the 2025 triennial valuation. According to the agenda, representatives from Barnett Waddingham were expected to present the initial results.

A valuation update included in Agenda Supplement 1 noted that the Fund Actuary had provided an initial view of the valuation results at a total Fund level, based on key assumptions.

The liabilities, according to the report, would be discounted at 5.0% per annum, which is the assumed future investment return based on a weighted average of forecast returns for each asset class, in line with the Fund's strategic asset allocation within its investment strategy, with an adjustment for expenses and a margin for prudence. The margin for prudence of 1.1% per annum is based on modelling done by the Fund Actuary, suggesting that the Fund should achieve annual investment returns in excess of 5.0% approximately 75% of the time.

The asset allocation and return assumptions were set out in a table:

The report stated that the discount rate assumption at the 2022 Valuation was 4.1% per annum, and that the increase in the discount rate would have the effect of reducing the liabilities.

The future rate of CPI (Consumer Prices Index) inflation was assumed at 2.7% per annum, the same as at the 2022 Valuation. Salary increases were assumed at 3.7% per annum, compared to 3.2% at the 2022 Valuation, with additional promotional increases. The report noted that the salary increase assumption is not the assumed annual pay award, but takes into account that staff are promoted to more senior roles during their careers, which is particularly relevant to those with pre-2014 service where their pension will be linked in part to their final salary.

The initial results indicated a funding level of 106%, compared to 103% in 2022, largely as a result of the increased discount rate.

The committee was to be asked to approve the proposed assumptions at 31 March 2025, after which the Fund Actuary would proceed in calculating the contribution rates for employers to cover the period from 1 April 2026 to 31 March 2029.

Conflicts of Interest Policy

The committee was scheduled to consider a new Conflicts of Interest Policy. According to the report, the Fund is required to publish a Conflicts of Interest Policy under the new requirements in the Pension Regulators General Code of Practice (GCOP). The policy presented was expected to be more wide-ranging than previous policies, and include how conflicts are managed which arise between the Fund and administering authority.

The key risks that the policy was designed to address included:

• Decision-making - personal interests which could influence decision making leading to outcomes which are not in the best interest of the Fund and its beneficiaries.
• Reputational damage - actual, potential or perceived conflicts of interest can erode trust in the Committee, Board, and/or officers of the Fund.
• Legal and regulatory non-compliance - failing to manage conflicts of interest could potentially result in breaches of the law and regulations.
• Financial mismanagement - conflicts of interest may result in financial mismanagement through poor financial decisions being made.
• Operational inefficiency - conflicts of interest can disrupt operations causing delays in the operational processes of the Fund.

The policy was drafted by Barnet Waddingham as the Fund's retained governance adviser, and reviewed by Jennifer Devine, Head of Wiltshire Pension Fund, and the Fund's senior management team. The Local Pension Board reviewed the policy at their meeting on 11 September 2025, and were content to recommend that the Committee approve it.

Breach Policy

The committee was scheduled to consider a new Breach Policy. According to the report, under the new requirements in the Pension Regulators General Code of Practice (GCOP), there are requirements for Funds to clearly set out who must report breaches, how the Fund makes decisions on whether to report a breach, and how reporting will be done. The policy presented was a redraft of a previous policy, in order to meet the new requirements and ensure full compliance.

The key objectives of the policy were to:

• Ensure compliance with the Fund's legal obligations under the Pensions Act and the Code to report breaches of the law of material significance relevant to the administration of the Fund to TPR.
• Provide guidance to the Officers, Committee and Board members as to how to raise concerns about breaches of law or failures which affect the administration of the Fund and to report materially significant breaches of law to TPR.
• Promote a culture of accountability, integrity, and compliance within the Fund.
• Assist the Fund in meeting its overall strategic goal to deliver an outstanding service to our scheme employers and members.

The policy was drafted by Barnet Waddingham as the Fund's retained governance adviser, and reviewed by Jennifer Devine, and the Fund's senior management team. The Local Pension Board reviewed the policy at their meeting on 11 September 2025, and were content to recommend that the Committee approve it.

Headlines and Monitoring Report

The committee was scheduled to review the Headlines and Monitoring (HAM) Report. The report was intended to provide the committee with information in relation to various standard issues, including:

• Scheme, Regulatory, Legal and Fund Update
• Health Check Dashboard To 30 June 2025
• Administration KPI update including an update of the KPI Improvement Plan
• Risk Register
• Key Financial Controls highlights including budget monitoring
• Audit update SWAP KC actions
• Committee and LPB training

The report from Jennifer Devine summarised key events across the Pension Fund over the last quarter, including:

• Investment performance for the quarter to Jun-25 was +3.1%, slightly behind the combined benchmark for all portfolios of +3.3%. The fund value at the end of Jun-25 was £3.6bn.
• Progress on the actuarial valuation continues.
• The preferred pooling partner for Wiltshire would be LGPS Central, following a rigorous selection process. Officers have now had confirmation that the Fund has been accepted into the pool.
• The admin team have retained their backlog of work at under 100 cases, and are currently meeting a high standard of service, following the introduction of the new Pension Administration Strategy on 1 Sept 2025.
• Annual Benefit Statements were completed on time.
• Current key vacancy in the team is the Fund Governance Manager, which is proving difficult to fill.
• The annual report and accounts have now been graphically designed and published online and were circulated to the Fund's membership as part of the Pension Awareness Week campaign.
• Pension Awareness Week (15-19 Sept 2025) was very successful with a high level of engagement from the Fund's membership.
• Work is continuing with the HR&OD team to deliver a big piece of work which will help develop the team culture and tackle important issues.

The Scheme, Regulatory and Legal Update included the Barnett Waddingham August 2025 LGPS Pulse circular. Key additional strategic Fund updates have been incorporated within the Fund's risk register section of this report.

The Health Check Dashboard provided a snapshot of the Fund's performance against its Business Plan objectives demonstrated by performance against the 7 key measures of success defined in the Business Plan, i.e. Service Delivery KPIs, Investment performance, Funding level, Customer Service Excellence, Internal audit ratings, Cost per member and Staff engagement.

The Risk Register as at August 2025 set out the changes since the risk register was last reviewed by the Committee in July 2025, including:

• Financial management has increased, although is still under the risk appetite, due to challenges and delays in being able to agree an SLA with Wiltshire Council, which is impacting budget monitoring and ability to assess value for money.
• Systems management has increased and is now above risk appetite for this area, due to issues with the member self-service portal.
• Service delivery has decreased in the last month, although is still slightly above risk appetite.
• There have been no changes to the risks in the Investment risk area, as this remains High, with an overall risk score of 17 compared to risk appetite of 12.

The Administration KPIs showed that the Admin KPI picture has improved as all KPIs for the reporting period were 90% or over and the backlog remaining under 100 cases.

The SWAP Audit Update 2025/26 included updates on the standard annual audits, TPR's General Code of Practice, Customer Service Excellence, and Website Accessibility.

The report also noted that as part of the Pension Bill 2025, the Government is proposing to introduce statutory requirements around knowledge and skills for Committee members (currently this is only a legal requirement for LPB members) as well as for senior officers, and that plans were in place to ensure compliance with these requirements.

Committee Forward Work Plan

The committee was scheduled to review the forward work plan for the committee. The plan included items to be discussed at future meetings, such as the TPR General Code of Practice self-assessment, review of the Fund Training Programme, and review of the Investment Strategy Statement.