The General Code – filling the gaps

In the previous blog  in our General Code Corner, we looked at how trustees can develop a strategy for prioritising and filling in any gaps in their policies and procedures. Below, we consider how trustees can bridge those gaps in the most efficient way.

What if we already have a policy or procedure in place?

The good news is that your gap analysis may well have shown that you already have certain documented policies or procedures in place, which only need minor amendments (if any) to bring them in line with the Code or to update them to ensure that they align with what happens in practice.

Equally, you may have recognised that you have policies and procedures which are not documented. These should be used as a starting point for putting together a comprehensive set of formalised documented policies that reflect your current practice.

What if we still have gaps – can we use a template or example policy?

A completed gap analysis should provide valuable insight as to any gaps that need to be filled. Trustees may be eager to ask their advisers for template or example policies to help to plug those gaps as efficiently as possible.

Templates and examples can be useful, but it’s important to make sure that they are used effectively:

• template policies are intended to cover a wide range of schemes and, therefore, are quite generic in nature. As a result, they can be high-level and in a format that isn’t consistent with the scheme’s existing policies. They will often require input from those with knowledge of the scheme to make sure that they are tailored and that they accurately reflect any practical and operational measures currently in place
• example policies may be anonymised copies of policies that have been used by other schemes. As a result, they may be scheme or sponsor specific. Again, this means that tailoring will be required to reflect the relevant scheme’s position (and some elements of the policy may not be applicable to the scheme at all).

Where a policy or procedure (whether documented or not) is already in place, this should be the starting point. Where this is not the case, template or example policies may be a useful starting point, but trustees should be mindful of considering how they should be amended to reflect the particular circumstances of their scheme. Each ESOG will be unique to the scheme to which it relates – demonstrating that the trustees have thought about the relevant requirements in a scheme-specific context is key.

You may find that the final version of the document looks very different or that it reflects a number of sources. That is reasonable, and so is starting with a blank sheet of paper. This is a very practical topic and so it makes sense to approach it in a way that works for the scheme and the gap that is being filled.

Next blog…

The subject of the next post in our General Code Corner series will be a spotlight on the remuneration policy.

Please speak to your usual Sackers contact if you have any queries regarding the issues highlighted above.

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