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Employer PLOG Meeting 2020
Welcome
Presented by
Dan Harris
Head of Peninsula Pensions
Peninsula Pensions
Administration Update
• Peninsula Pensions Overview and Update
• Performance and Statistics
• Future Developments
Agenda
• Peninsula Pensions was formed in 2013
• Shared Service between Devon and
Somerset County Councils
• 400 employers
• Gloucestershire Fire and Rescue Service
and Avon and Somerset Police
• 199,000 fund members
Peninsula Pensions Overview
Key functions provided include:
• Providing guidance, information and
support to employers and members
• Calculation of pension benefits
• Payment of pensions
• Adherence to HMRC and other regulatory
bodies requirements
During 2018, the service was restructured into three
specialist functions:
• Member Services
• Technical and Compliance
• Employer and Communications
Member Services
• Provide member services for LGPS, Police and
Fire schemes
• Member services teams are now split by employer
with the aim of improving employer focus
• The Police and Fire team are responsible for
processing benefits administered under Service
Level Agreements
Technical and Compliance
• Pensioner Payroll
• Systems Development
• Technical and Training:
• procedure notes and training
• training and accreditation programme for staff
• quality assurance scheme for accredited staff
• technical queries
• administer the Annual Allowance exercise and
other projects
Employer and Communications
• Client management
• Increased engagement, training and support
• Review employer performance data
• Administer the process for admitted bodies and new
employers
• Improve communications with employers and members
• Increase the use of self-service portals and the website
Performance and Statistics
Performance and Statistics
Administration Performance
Performance
• Disclosure regulations
• Internal targets
• Reported quarterly to the DCC/SCC Pension Board
• Reported annually in the Pension Fund Annual Report
and Accounts
• Reports are available on the website
Administration Costs per Member
0.00
5.00
10.00
15.00
20.00
25.00
2016/17 2017/18 2018/19
Co
st (
£)
Peninsula Pensions LGPS Average
Payroll Costs per Pensioner
0.00
1.00
2.00
3.00
4.00
5.00
6.00
2016/17 2017/18 2018/19
Co
st (
£)
Peninsula Pensions LGPS Average
• New website, with enhanced media, support
and guides for employers and fund members
• Enhanced Member Self-Service
• Immediate Payments
• Historic data sign off
• Pension Administration Strategy 2020
• Employer Self-Service
Future Developments
www.peninsulapensions.org.uk
Employer PLOG Meeting 2020
Employer Self Service(ESS)
• What is Employer Self Service?
• How to Sign up and what you can do
• Help resources available
• Common issues using Employer Self Service
Employer Self Service(ESS)
What is Employer Self Service(ESS)
113
56
Have you signed up for Employer Services?
Yes No
33% of people who responded have not signed up
13
7
4
9
3
2
0 5 10 15
DON'T KNOW WHAT IS/OFFERS
DIFFERENT PAYROLL PROVIDES OUR INFORMATION
WON'T LET ME LOGIN/ ACCOUNT DETAILS WRONG
DON'T WAIT IT/TIME CONSUING
PERSONALLY HAVEN'T BUT ONE OF MY TEAM MEMBERS HAVE
REQUESTED ACCOUNT DETAILS
Reasons for not signing up?
• It allows you to view the details that we hold for
individual employees.
• Update information in real-time.
• Set up new starter.
• Perform individual pension estimates
• Notify us of a leaver
What is Employer Self Service?
• To sign up follow the link below
https://employers.peninsulapensions.org.uk/employerservicesweb/login
• Need to be on our contacts list for your organisation to be able to sign
up
How do I sign up?
CARE Pay – Actual pay the member has paid
pension contributions on (April 2014 onwards)
Final salary benefits – Pre April 2014. Final 365 days
pensionable pay.
• Guides and video’s available https://www.peninsulapensions.org.uk/lgps-employer/employer-self-service/
Help with using Employer Self Service(ESS)
Common Issues
• Leavers Forms• Form blank• Notification of a leaver but no form uploaded• Pensionable pay missing for the final salary scheme
where member has pre14 service• Work Activity not completed or information filled in
on the comments section and no new leaver’s form submitted.
• Created when a leaver’s form is incorrect or missing details.
Work Activities Incomplete
Thank you for listening
Data Quality ExerciseProgress Update
• What It Is
• Why We Are Doing It
• How It’s Gone So Far
• Things We Have Learned
• Looking Forward
What It Is (1 of 3)
Collaborative exercise between Peninsula Pensions and all employers
within the pension fund(s)
A historical check of EVERY active member record held by Peninsula
Pensions. Data is sent to the employer to check and amend where
necessary
Combined assault. We will work through the data and correct what we can,
using all current and historic data at our disposal
What It Is (2 of 3)
Once the employer and Peninsula Pensions are happy with the state of the
data, the employer is ‘signed off’
– Signed Off informs the Member Services teams that they no
longer need to query data preceding the sign-off date with
the employer
– One big condition: the employer agrees to submit monthly
interface data, in order to keep the records up to date
What It Is (3 of 3)
Particular areas of interest:
– CARE pay
– Current hours of employment
– Home addresses
– FTE salaries / dates
– Payroll / Job References
Responsibility of the Systems Development Team
Why We Are Doing It (1 of 2)
Increased scrutiny from the Pensions Regulator. Pension boards, actuaries
and auditors all have an interest. Wider cultural concern regarding data
accuracy and how it is treated
Member Self Service. Members can (and do) pick us up on errors on their
records
To minimise the number of employer queries emanating from Peninsula
Pensions (puts strain on employers and delays work completion)
Why We Are Doing It (2 of 2)
Self-awareness. Realisation from some quarters within Peninsula Pensions
that our data quality could / should be improved
– The whole Data Quality thing actually originated from the
Systems Development Team. A growing realisation and
frustration with the constant data fixing / chasing we were
doing; much of it self-inflicted (Peninsula Pensions)
How It’s Gone So Far (1 of 3)
Commenced in February 2019
410 employers on the original list
60 completed the entire process to date
144 are work in progress
How It’s Gone So Far (2 of 3)
Aspens (Queen Elizabeth)
Aspens (King Edward VI)
Babcock
Barnstaple Town Council
Bideford Town Council
Bovey Tracey Town Council
Brixham Town Council
Budleigh Salterton Town Council
Catch 22 MAT
Chulmleigh Academy
Cormac Solutions Ltd
Cranbrook Town Council
Dame Hannah Rogers School
DYS Space Ltd
Exeter College
Exeter Mathematics School
Exeter Royal Academy for Deaf Education
Hayes Road School
Healthwatch
Ilfracombe Town Council
Ivybridge Town Council
Lex Leisure
Millfields Community Economic Development
Trust
Mitie Plc
North Devon Joint Crematorium
Plymouth Dental Social Enterprise
Quadron
Red One Ltd
Sanctuary Housing
Sparkwell Primary Academy
Steiner Academy
Strata
Tarka Housing
Tavistock Town Council
Torbay Economic Development Company
Viridor
Wolseley Community Economic Development Trust
How It’s Gone So Far (3 of 3)
Aster Communities
Axbridge Town Council
Axe Brue Drainage Board
BAM Construct UK
BAM FM (Edwards & Ward)
Churchills (ex Yeovil College)
Dimensions
Exmoor National Park
Frome Town Parish Council
Homes in Sedgemoor
Idverde Ltd
Magna Housing Ltd
Mama Bears Day Nursery
May Gurney
MD Building Services
NSL (ex TDBC)
NSL (ex Mendip)
Parrett Drainage Board
SASP
SCC South West Heritage Trust
South West Audit Partnership
South West Councils
Yarlington Housing Group
Taunton
Bideford
Exeter
Things We Have Learned (1 of 4)
Internal procedure manual constantly being updated. Started at five pages
but already grown to eight
Every employer has been different. Issues with data are not uniform across
the board. Don’t know the depths of any issues until we start looking!
Regular interfacers definitely have an easier time of things
Things We Have Learned (2 of 4)
One month turnaround accurate for the most part, but easily affected by
other factors (e.g. staff absence, end of year, school holidays, priority shifts).
“Never a perfect time”. Communication!
One month has been fine for smaller employers, but may / will need to
change once larger employers get involved
Things We Have Learned (3 of 4)
It is NOT the same as the annual return process (you have to do that as
well!)
– Annual Return is a PASSIVE exercise. Loading one years
worth of data onto member records. Dealing with problems
as they arise
– Data Quality is an ACTIVE exercise. Checking existing data,
some of it going back years (certainly 2014). Looking for
errors. Correcting issues overlooked (caused?) by years of
annual returns
Things We Have Learned (4 of 4)
Initial reaction to the project has been very positive. Cooperation has been
excellent. Many thanks! However…
Encountering an increase in less enthusiastic responses / employers
unaware of the exercise
“Do I really have to do this?” Responsibility to all your employees to ensure
accurate pension benefits
Looking Forward (1 of 1)
Continue working through the list; smaller employers first (but still taking
offers)
Expecting pace to slow once larger employers get involved
Still another year (minimum) of the project to go, but your turn will be
coming…
Fin
Presented by
Dan Harris
Head of Peninsula Pensions
Pensions Administration Strategy
• First introduced in 2008 and now fall under Regulation 59
of the LGPS Regulations 2013.
• Not a legal requirement, but they provide a mechanism to
formulate a service level agreement between the
administering authority and the scheme employers.
• Cover a number of areas including:
• procedures for liaison and communication
• performance standards and expectations for
employers and the administering authority.
• Copy provided to Scheme Employers and Secretary of
State
Pension Administration Strategy
Regulatory Background
• Support the pension fund on behalf of its employing
authorities and the administering authority.
• Promote good working relationships
• Define the roles and responsibilities of the Administering
Authority and the employing authorities under the LGPS
regulations
• Deliver a cost-effective and high quality pensions
administration service
• Improves governance
• The PAS does not override any provision or requirement
of the LGPS regulations nor is it intended to replace the
more extensive commentary provided by the Employers’
Guide and website for day-to-day operations.
Purpose
• Current PAS has been in place since 2015
• Regulation 59 states that the PAS must be kept under
review.
• The review has been undertaken in view of:
• Peninsula Pensions restructure
• Growth in membership
• Increase in demands of scheme members and
employers
• Changes to LGPS regulations
• Advances in technology
• Improvements to performance monitoring
The review
• Draft PAS created by PP - Summer 2019
• Reviewed by Pension Board - Oct 2019
• Reviewed by I&PFC – Nov/Dec 2019
• Consultation with Employers – Dec/Jan 2020
• Sign off by I&PFC – Feb 2020
• Revised Strategy will go live in April 2020
Pensions Administration Strategy Timetable
• Draft PAS circulated to employer in Dec 2019
• Employers invited to review and provide feedback on PAS by 19th January 2020
Consultation with employers
• Feedback collated from employers
• Presented to the Investment and Pension Fund Committee
• Sign off in February 2020
• Go live in April 2020
Next steps…
www.peninsulapensions.org.uk
Communications
And
Development
Emma Davies
Senior Employer Liaison Officer
Communication
Best definition: the process of passing information and understanding from one person to another.”. In
simple words it is a process of transmitting and sharing ideas, opinions, facts, values etc. from one
person to another or one organization to another
Essential to a good working relationship
The service we provide relies on effective communication
Peninsula PensionsPeninsula Pensions Scheme MembersScheme MembersScheme EmployersScheme Employers
How are we doing? Communications survey sent out in December to over 1200
contacts
Questions covered all current platforms:
• Pensions Line
• Peninsula Pensions Website
• Employer Services
• PLOG Meetings
• Training & Workshops
170 responses providing lots of feedback
Communication Survey SummaryPensions Line
Read rate is approximately 35% so how can we improve?
Do you receive the Pensions Line? Yes = 68% No = 32%
Do you have time to read it? Yes = 64% No = 36%
Would ‘Information’ and ‘Actions Required’ sections be helpful? Yes = 97% No = 3%
Would you like it to be issued more regularly? Yes = 10% No = 90%
Communication Survey Summary
Website - www.peninsulapensions.org.uk
13% of respondents were not able to find what they were looking for
66% would be interested in a live chat option
Suggestions for improvements:
One logical place for documentationOne logical place
for documentation
Easier NavigationEasier Navigation
Better Search Engine
Better Search Engine
Clear division of employer area to
members area
Clear division of employer area to
members areaMore user friendly – old and clunky
More user friendly – old and clunky
Needs Modernisation
Needs Modernisation
Communication Survey Summary
Employer Self Service (ESS)
33% not
signed
up for
various
reasons
Communication Survey Summary
ESS
New
Starters
Communication Survey Summary
ESS
Leavers
Communication Survey Summary
Employer Self Service (ESS)
Are the Work Activities working for you? Yes = 58% No = 42%
How can
things be
improved?
Communication Survey Summary
PLOG Meetings
Have you attended any? Yes = 43% No = 57%
Out of 55, only 1
person didn’t find
them useful
73% do not want
them to be held more
regularly
7.11 average score
out of 10 for the
structure & content
Communication Survey Summary
PLOG
Meetings
Communication Survey Summary
Communication Survey
What are we going to do now?...
• Feedback will be passed onto relevant parties to take forward
• Pensions Line – Looking at new design to include Information and Action Required sections
• ESS Leaver process – it’s the best we can get it for now. Seeking feedback from other users
Chasing for InformationNot ideal for either Pensions, Employers or the Members
E&C Team chase for missing forms and data when no reply received from initial request
• 50-80% of working week spent chasing – duplication of work in some cases
• Approx. 250 cases still outstanding resulting End of Year exercise from past years – assumed leavers
from 2016 onwards
• Another 300 ‘new’ cases with us for chasing
• Not true leavers in some cases – members are still employed
• Opt-out forms not submitted at the same time as leaver form
• ESS Work activities not being completed even though revised form uploaded
How can you help?• Submit Leaver forms within the specified timescales (within 1 month of final pay period) and include all
relevant forms/certificates
• Members with nil earnings – if they are still employed, you need to include them on the monthly return
otherwise we will assume they have left
• ESS Leaver Process – Remember it’s a 2 stage process and complete your work activities
• Transfer of payroll providers – it is important that you retain access to historical payroll information in
order to fulfil your responsibilities
• Keep us updated with change of contacts so emails are directed to the correct people – online form on
our website
• Please don’t ignore us – information needed to calculate your members benefits
Our processPast:
Not ideal – chasers sent to employers from many people and
duplicate requests
Present:
Member services and Systems Teams try to obtain
responses before passed to E&C Team
• Inhouse training and templates for requests introduced to
ensure consistency
Referral to E&C Team:
• One list to be shared with employers
• Polite request to respond within the next 10 working days
• Letter will be sent to employee if no response
• Case could be referred to The Pension Regulator (TPR)
The Occupational and Personal Pension
Schemes (Disclosure of Information)
Regulations 2013 sets out strict timeframes
for the provision of pension information.
If timeframes are exceeded, we have to
record cases on our breaches register.
The register is reviewed regularly by Senior
Officers at Peninsula Pensions and
presented to the Devon and Somerset
Pension Boards.
Depending on the severity or frequency of
a breach, it may result in a referral to The
Pension Regulator (TPR)
Development
What did we promise last year?
What are we working on?
11th February 2019
Relaunch of ESS – moved forms to ESS for New Starters and
Amendments
Developed online form to enable Employers to confirm and change:
• Authorised contacts
• IDRP Officer Form
• Delegated contacts
• Payroll provider
June 2019
Moved Leaver Form to ESS (in place since 24th June)
Discretions guidance reviewed and updated on website (Flexible
Retirement Policy Guidance included in guide and policy template)
July 2019
Review IDRP Guidance - revised and new guide updated on website
Feedback from employer survey has given us lots to work with
• Re-design of Pensions Line E-zine
• New Website in development
• Better Employer Guides – less “blurb” and easier to follow
• More video tutorials on the website
• Revised Leaver Form to address errors identified by our First Response Team
• Introduction of Workshops
What are we working on?
New website in development...
Hope to launch by
the Summer
All employers
comments and
suggestions will
be considered
Aiming for easier
navigation and more user friendly
ESS Leaver FormNew version will be in place from 10th February 2020
No major changes - revised to reduce the most common errors:
• Members Address – pre-populated so please check it’s the correct one
• Opt-out forms and Ill health certificates - Form will be rejected if not added to end of Leaver form
• Information for Refunds - Actual pay (CARE) section has been included
• Pensionable Pay for both Final Salary and CARE benefits are now in one section - both to be provided
where necessary
Aim is to reduce number of forms rejected = less work activities for you!
Important Date - 2nd March 2020
All Leavers to be submitted via ESS
No more forms accepted via email
Workshops Timetable 2020
March - ESS Refresher training (Overview of the system and processes you need to follow)
April - Pensionable Pay (will cover Assumed Pensionable Pay, Absences and what you
need to state on pension forms)
May - Employer Responsibilities (to include IDRP Process, what you need to know and
what you need to do)
June - Discretions (explanation of what each one means and what you need to consider)
July - Ill Health Retirement Process
Comms survey raised suggestion of TUPES & Admission Agreements
Thank you for
listening
Any Questions?
Time to
hand over to
Richard
Interfaces / OtherGeneral Update on Systems Team
• Interface Template
• Member Self Service (MSS)
• Annual Returns
• System Team Contacts
Interface Template (1 of 8)
Interface Template (2 of 8)
• Drop-down selection. Locks data entry
to recognised locations and people
• Minimises data entry (i.e. user friendly!)
• Allows employer to check that we hold
correct contact names and emails
• New addition: Payroll month selection
Interface Template (3 of 8)
• Primarily an audit requirement
• Acts as a missing data check (e.g.
Data Submitted is ticked, but sheet is
empty – we will query)
• Works as an employer checklist;
confirm all data has been attached
Interface Template (4 of 8)
• Just getting the names out there /
more easily accessible
• Interface mailbox still the primary
contact
• Contact the named person as much
as possible
Interface Template (5 of 8)
Interface Template (6 of 8)
Notes on dropdown contents
• Payroll provider rather than every employer in the fund(s)
• People who interface (e.g. no CEO’s, headteachers, accountants)
• Not on the list? No email or email was a home address (GDPR); or
• Limited to 4-5 people per location
Interface Template (7 of 8)
Interface submission deadlines
• A set day of the month by which interfaces should arrive
• Primarily an audit requirement
• Reduces risk of slippage. Things working on a tighter / predictable schedule
• Early warning that an employer has issues (e.g. staffing issues, additional training
required, communication breakdown)
Interface Template (8 of 8)
Interface content / formatting / errors
• A new Zero Tolerance to formatting issues, errors, missing data etc.
• Data not provided on the official template, or not completed as per guidance, will
be sent back for correction
• Increasing volume of interfaces means we can no longer justify correcting content
we have previously
New interface will go live in April
Out of 197 923 member records:
– 68 094 have registered with MSS (35%)
• 41% Actives / 40% Pensioners
– 38 315 have actively opted-out (19%)
– 90 704 are yet to do anything (46%)
Continue to pursue the reluctant 46%
Feel free to promote it to your employees! Google “Peninsula Pensions Member Self
Service”
MSS v2.0 due to go live in late February
Member Self Service (MSS) (1 of 1)
Are on the way…
A message will be in February’s edition of Pension Line
Emails will be sent out early March. If you haven’t heard from us by late March, contact us!
No changes to previous years / deadlines (brilliant response last year; genuinely best ever!)
Zero Tolerance (see previous) will apply
Annual Returns (1 of 1)
Systems Team Contacts (1 of 1)
Monthly Interfaces and Annual Return Queries, MSS Registrations
Tom Bird – Devon County Council + Devon fund employers (non-schools)
James Dyche – Devon fund schools
Sophie Downer – Somerset County Council + Somerset fund employers (non-schools)
Steve Bradford – Somerset fund schools, Police Officers, Firefighters
Edward Hipkiss – District, Borough, City, Parish, Town Councils, Police Civilians
Process Overviews, General Enquiries
Richard Tuck
Technical Stuff, Calculation Errors, Systems Team Personnel Issues
Jane Aplin
Fin
What does 2020
have in store?
Transitional Protection issue
Pensions Tax Considerations
Good Governance
ReportThe Pension Regulator Code
amendment
Other amendments
#1 McCloud (& Sargeant) outcomes
What is this?
❖ Transitional protection introduced in 2012 for those closest to retirement age. Under the 2014 CARE scheme a protection was put in place to ensure that protected members would receive a pension that is a least equal to that which would have been received in the Final Salary Scheme.
❖ Case brought to the Employment Tribunal 2016
❖ Court of Appeal decision in 2018 that transitional protection was unlawful found that these protections were unlawful on the grounds of age discrimination and could not be justified - reinforced by Supreme Court process June 2019
Impact on LGPS?
❖ Court of appeal decision impacted on all public sector schemes
❖ Remedy to be agreed
❖ Cost cap / scheme valuations
#1 McCloud (& Sargeant) outcomesCurrent position?❖The LGPS will be treated independently to the rest of the
public sector with regard to the remedy❖The remedy likely to provide an extension to current
underpin offered to Protected members to include other member groups.
❖The remedy will also apply to leavers from 01.04.2014.❖The remedy is not likely to be implemented until the end of
tax year 2020/21.
Potential administrative impact when progressed?❖Data required from Employers to include part-time hours /
service breaks / pre-2014 definition pensionable pay ❖Administrators will need to identify those in scope and adjust
accordingly once final guidance / amendments agreed – will need to revisit calculations, uplift pensions in payment, communicate all of this with affected members
#2 Pensions Tax Consideration (annual allowance)https://lgpsmember.org/more/Videos.php
https://lgpsmember.org/more/Videos.php
What is this? Annual Allowance is the total amount of benefits that you can build up in a pension scheme each year, for tax relief purposes.
Reducing allowance over the years has meant that more members have become subject to a tax charge.
NHS proposal put forward for members to control their pension growth to avoid Annual Allowance charges and assist with the administrative burden.
#2 Pensions Tax Consideration
Max £255k
Now £40k
Impact on LGPS?Local Government Association are able to consider and put forward recommendations to the Scheme Advisory Board for a more flexible approach in LGPS – alternative ideas are: ❖ optional non pensionable pay elements❖ life cover only membership
Potential administrative impact if progressed?❖ reduction in members exceeding the Annual
Allowance and therefore less data required to enable calculations to be performed
❖ amendment to treatment of pay elements
#2 Pensions Tax (annual allowance)
❖ TPR due to consult on merging its 15 codes of practice into a single code
❖ Code of Practice No 14 being incorporated into the new single code
#3 The Pensions Regulator (TPR) Single Modular Code
Impact from administration perspective?
❖ Continue to comply with Code 14 requirements with regards to risks / controls / data / communication
❖ Assess compliance with new singular code (including any additional requirements), and establish how compliance will need to be demonstrated
#3 The Pensions Regulator (TPR) Single Modular Code
#4 Good Governance
❖ Clear statutory governance framework for LGPS
❖ Demonstrate high standard of service delivery for scheme members
❖ Measure and evidence compliance against the proposals set out in Good Governance reports Phase I and Phase II (November 2019)
❖ Phase 3 to follow including draft statutory guidance on governance compliance statements and establishing a set of key performance indicators
Purpose:
Scheme Advisory Board recommendation
Examine effectiveness
Identify enhancements to strengthen governance in LGPS
Recommendations so far:
❖ Ensure conflict of interest policies in place
❖ Develop the knowledge and understanding of key individuals
❖ Document and measure performance/service delivery
❖ Biennial independent governance review
Impact from administration perspective?
❖ Document and evidence compliance for both Good Governance review and TPR requirements / new singular Code
❖ Key areas – continue to work together to adhere to timescales in admin strategy to ensure high level of performance / secure provision of accurate, timely data / provision of training to assist with these areas
#4 Good Governance
Updates from 2019
• Civil partnerships - SI 2019 No 1449 in force 31st
December 2019 introduced survivor pension for opposite-sex civil partnerships (only legislation to be passed)
• National Insurance database - tool to check if a member has pension benefits held elsewhere which may potentially impact on entitlement to death grants - usage extended to include data re transfers, refunds and trivial commutation payments, and tracing lost members
• TPR report September 2019 – relating to governance and administration risks in public service pension schemes, including the 10 local government funds they proactively engaged with between October 2018 and July 2019.
Forfeiture
Exit cap £95k
5 year time limit refunds
Guaranteed Minimum
Pension (GMP) reconciliation
Amendments due / areas outstanding 2020
❖ Delayed due to election❖MHCLG to meet 6 March 2020 to discuss
areas still pending
Hand back to Mark Griffin
The End – Thank you for coming
Please hand your badges in when leaving
Disclaimer• The information contained in these slides are the authors interpretation of the current regulations.
• The information is subject to change due to various factors including, but not limited to, changes
to rules and regulations introduced by the Government Actuary's Department, HMRC and/or the
CLG. Changes can happen at short notice and may be implemented prior to the Council issuing
any future revised documentation.
• Readers should take their own legal / financial advice on the interpretation of any particular piece
of legislation.
• No responsibility whatsoever will be assumed by Peninsula Pensions for any direct or
consequential loss, financial or otherwise, damage or inconvenience, or any other obligation or
liability incurred by readers relying on information contained in these slides.