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CSC Computer Sciences Ltd Pension Scheme (“The Scheme”)

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CSC Computer Sciences Ltd Pension Scheme (“The Scheme”) CSC Computer Sciences Ltd Pension Scheme (“the Scheme”) Chair’s Statement of DC Governance for the period from 1 July 2019 to 30 June 2020 I am pleased to present the Trustee’s statement of governance, covering the period 1 July 2019 to 30 June 2020 for the money purchase benefits in the Scheme. This statement describes how the Trustee seeks to ensure that the Scheme is well-managed and delivers excellent services to members. The statement examines four key areas of the Trustee’s governance, namely: • The investment strategy relating to the Scheme’s default arrangement; • The processing of core financial transactions; • Charges and transaction costs within the Scheme including the pounds and pence illustration of the compounding effect of charges; and • The Trustee’s compliance with the statutory knowledge and understanding requirements. In doing so, we provide the various statutory disclosures required by the Occupational Pension Schemes (Charges and Governance) Regulations 2015. Monitoring the overall quality of the Scheme arrangements is a complex task that the Trustee takes seriously. The Trustee is supported in this process, as well as the day-to-day business of running the Scheme, by Willis Towers Watson (the provider of administration and communications services for the Scheme), Premier Pensions (Scheme Secretary) and Mercer Limited (an independent advisor, covering governance, investment advice and wider Defined Contribution (‘DC’) matters). Post year-end Scheme merger Following the merger of Computer Sciences Corporation and the Enterprise Services business of Hewlett Packard Enterprise, DXC Technology Inc. (the ultimate parent company of the Principal Company), has been examining how the governance arrangements of the group’s pension schemes, including the CSC Computer Sciences Ltd Pension Scheme, can be improved and operating costs reduced. As a consequence of this review, DXC Technology put forward a proposal to the Trustee to merge the CSC Computer Sciences Ltd Pension Scheme into the CSC Computer Sciences Ltd 2005 Pension Scheme. Following careful due diligence and a review of its legal obligations, the Trustee agreed to the proposed merger with all assets, liabilities and responsibilities relating to the CSC Computer Sciences Ltd Pension Scheme transferring to the CSC Computer Sciences Ltd 2005 Pension Scheme. The merger completed on 12 October 2020 with work now underway to wind-up the trust of the CSC Computer Sciences Ltd Pension Scheme. Members of the Defined Contribution Section will see no change to their benefits or current investment arrangements as a consequence of the merger, with the Defined Contribution Section having effectively been ‘lifted and dropped’ into the post-merged Scheme. In addition, the corporate Trustee that governs the Scheme also governs the CSC Computer Sciences Ltd 2005 Pension Scheme so there will be a consistency in the governance approach. The Scheme’s Default investment strategy The Statement of Investment Principles (SIP) The SIP sets out the aims and objectives of the Scheme’s investment strategy. In particular, it covers the Trustee’s investment policy for the Money Purchase assets, including objectives, risk and expected return and the design of the default investment strategy. A copy of the latest agreed SIP dated 16 September 2020 is attached as an appendix. The performance of all the funds, including those underlying the default investment strategy, is reviewed by the Trustee each quarter. The default investment strategy The current default investment strategy is a lifestyle arrangement, which is invested as follows: CSC Multi-Asset Default Fund, which invests Asset allocation during 75% LGIM* Global Equity Fixed Weight 30:70 Index Fund accumulation phase (75% GBP currency hedging for overseas funds) 25% LGIM* Diversified Fund Consolidation phase start 8 years before Target Retirement Age date 75% CSC Diversified Growth Fund (which invests 100% Asset allocation at end of in the LGIM Diversified Fund) and 25% CSC Targeting consolidation phase Cash Fund (which invests 100% in the LGIM Sterling Liquidity Fund) *LGIM = Legal & General Investment Management A formal review of the investment strategy of the default arrangement was undertaken on 15 August 2019. The following formed part of this review: • The performance of the default investment strategy against the objectives and aims contained in the Statement of Investment Principles. • The design of the growth phase and de-risking phase of the default investment strategy. • The at-retirement allocation in the default. • The self-select fund range including the alternative lifestyle strategies that are available to members. • Implementation considerations. Following this review, the Trustee concluded that the arrangements in place remained suitable and no immediate changes would be made. Other investment strategies In addition to the default lifestyle arrangement, members have the option to select from two additional lifestyle strategies, one suitable for a member wishing to target an annuity purchase at retirement and one suitable for a member wishing to use their individual member account to provide one or more cash lump sums. Full details are included in the SIP. Other funds that regulations require to be treated as default arrangements There are four additional funds that are deemed a “default arrangement” due to previous mapping exercises carried out by the Trustee and where members have not subsequently re-affirmed the investment selection. These funds are listed below: • CSC All Shares Adventurous Fund (Active) • CSC Targeting Cash (following a mapping exercise in August 2020) • CSC AVC Multi-Asset Fund (following a mapping exercise in August 2020) • CSC Liquidity AVC Fund (following a mapping exercise in August 2020) Whilst these funds are not part of the Scheme’s default investment strategy, the Trustee administers the fund as technically constituting a default arrangement and in line with the governance requirements that relate to such arrangements, including an annual cap on charges (excluding transaction costs) of 0.75% of assets and the duty to review the fund at least every three years. Processing core financial transactions The Trustee has a specific duty to ensure that core financial transactions in relation to money purchase benefits are processed promptly and accurately. The Pensions Regulator lists core financial transactions as including: • Receipt and investment of contributions • Transfer of member assets into and out of the Scheme • Transfers between different investments within the Scheme • Payments to and in respect of members During the last Scheme year, the Trustee ensured the core financial transactions of the Scheme were processed promptly and accurately by: • Appointing a professional third party administrator, Willis Towers Watson, to undertake all administration and record keeping duties. As part of that model, Willis Towers Watson undertakes a daily reconciliation of all bank transactions. They also have a system of authorised signatories in force to control payments from the Trustee’s bank account. No banking errors were identified for the year in question. • Having an agreement with their administration service provider (Willis Towers Watson) committing them to Scheme specific service level agreements (“SLAs”) and having the service provider report on their performance quarterly against the SLAs above. SLAs relating to core financial transactions included: Event SLA (days) Deaths 5 Retirement Settlements 5 Transfer Out Completion 5 Transfer In Completion 10 Pension Sharing 5 Investment Decision 5 The SLA performance over the year was 81% in Q3 2019, 87% in Q4 2019, 91% in Q1 2020 and 85% in Q2 2020. The Trustee view is that the administration performance was on an improving trend during the year, but the final quarter of the Scheme year (Q2 2020) was impacted by COVID-19 and the need for the administrator to prioritise key financial transactions at the expense of some regular services, such as for handling transfer and retirement enquiries and general correspondence. The administrators have transferred work to a specialist DC team following the Scheme year-end and the Trustee anticipates a return to target service levels during the next Scheme year and will monitor performance closely. • However, the level of member complaints has been low and monthly processes have been completed in a timely and accurate manner. In addition, the administrators have confirmed that no statutory deadlines relating to core financial transactions have been breached. • Ensuring that appropriate internal controls are in place with Willis Towers Watson by receiving and reviewing AAF01/06 audit reports. The latest report for the year to 30 September 2019, which was shared with the Secretary to the Trustee in October 2020, confirmed that the administrator’s description of their control procedures covering their administration and governance activities was fairly presented and that controls were suitably designed. There are 15 instances of control objective exceptions highlighted in the AAF report, 9 which are unique and 6 are in respect of controls that are replicated and applicable across multiple control areas; however, these exceptions were minor and would not be considered to have a direct impact on the Scheme. o A number of the internal controls rely on the administrator and payroll systems in place that perform tasks automatically. In addition, there are a number of manual checks carried out by the administrator;
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