TPR issues trustee guidance over conflict in Ukraine

The guidance - issued today (4 March) - said that while some UK pension schemes and trustees are already reviewing their exposure risks as a result of the conflict and the wider economic impact, it wanted to set out its expectations for schemes.

The regulator said it expected schemes to be "vigilant" and talk to their advisers about any action they may need to take with regard to scheme investment, risk management or employer covenant exposures.

It said schemes should also take steps to consider any action they may need to take to align with sanctions announced by the UK government.

The regulator said specific areas it expected trustees to consider include:

• Short-term liquidity needs and how those needs might be affected by margin calls and the need to meet short-term member benefit payments
• Whether the employer or sponsor of the scheme has been affected and the impact, if any, on the employer covenant
• The likely impact of these events on your scheme's investments including short and medium-term risks
• The potential heightened risk of cyberattacks in the current environment and whether your cyber safety procedures remain adequate or need further consideration
• The potential for heightened risk of financial crime, including scams, and whether related processes and procedures should be reviewed
• Whether investments remain aligned with the policies and principles set out in your statement of investment principles, including ESG considerations

TPR also noted that trustees may see an increase in concerns, or requests for information, from scheme members and should both prepare for this and be vigilant to the potential for scam activity.

It said schemes should also consider whether to communicate with their members to let them know the steps they are taking to manage risks to the scheme.

In addition, the regulator asked schemes to let it know about any significant issues or challenges that schemes or sponsors are facing as a result of the ongoing conflict in a bid to help it build a clearer picture of the impact on pension schemes.