Spotlight Q&A: Facilitating Regulatory Compliance in an Evolving Landscape

What first led you to develop the General Code Compliance Tracker?

Jay: The UK Pensions Regulator recently introduced a new code of practice, the General Code. It imposes a wide range of obligations on trustees of occupational pension schemes, many of which must be carried out on a regular and ongoing basis. This represents a significant compliance burden for trustees, not just in terms of carrying out the actions required, but also in terms of tracking when actions have been completed and when they are next due. We worked with our Innovation team to identify the technological solution that would best enable us to meet our clients’ needs in this respect.

How does the General Code Compliance Tracker work?

Katherine: The Tracker is web-based and has two key elements. The first is an initial compliance gap analysis tool, which enables trustees to establish to what extent they are currently compliant with the General Code and to identify, prioritize, and track the actions they need to take in order to become fully compliant. The second is an ongoing compliance tracker tool which enables trustees to identify, prioritize and track the actions they need to take going forward, in order to maintain their compliance. A dashboard on the homepage offers at-a-glance compliance status summaries. In addition, the Tracker is set up to automatically calculate and record next-review dates and to send email notifications of upcoming actions. It also includes a document storage facility.

Why should pension scheme trustees use the General Code Compliance Tracker?

Jay: As Katherine outlined, the Tracker allows trustees to track their compliance with the General Code. However, it also enables them to demonstrate their compliance with their regulatory obligations to interested parties, such as the scheme employer, the members, and the Pensions Regulator. Importantly, it is an easy tool for clients to use. It captures the requirements of the General Code in an accessible way, and we obtained client input during its development to ensure that it both met client needs and was user-friendly. The Tracker can also be customized to reflect particular preferences that a client may have.

How has the General Code Compliance Tracker been received?

Katherine: Feedback from trustee clients has been very positive – they especially appreciated the fact the Tracker is web-based, as well as its ease of use. We are also delighted that the Tracker has been recognized in the 2024 Financial Times Innovative Lawyers Europe report. While our focus remains on ensuring the Tracker reflects our clients’ needs, it is great to see the team’s work receive recognition.

How do clients find out more about the General Code Compliance Tracker?

Jay: We are happy to discuss the Tracker with clients and we can offer a virtual demonstration. We would encourage employers to consider sharing this article with the trustees of their pension scheme. While the Tracker has been designed to reflect the obligations that the General Code imposes on pension scheme trustees, our approach can also potentially be applied to other areas; for example, where businesses may be tracking the progress of legislation to ensure compliance. Please do let us know if you would like to discuss this further!