Investment Policy Document - GMG - Feb 2013

The GMG Lifestyle PlanInvestment Policy Document

February 2013

1. Introduction

1.1 This Investment Policy Document (the “IPD”) has been prepared by the Trustees of the GMG Lifestyle Plan (the “Plan”).

1.2 The IPD sets out the detail of the Plan’s investment arrangements, based on the principles documented in the Statement of Investment Principles (the “SIP”) dated June 2011.

1.3 The Trustees have obtained written professional advice from the Plan’s Investment Consultant in preparing this IPD.

2. Plan Governance

2.1 The Trustees are responsible for the investment of the Plan’s assets. The Trustees take some decisions and delegates the balance within the framework documented in the SIP.

Trustees

2.2 The Trustees will be responsible for:

The overall investment arrangements.

Compliance with legislation and regulation.

Appointing the Investment Consultant.

Establishing, and thereafter reviewing periodically, the SIP and IPD, in consultation with the Investment Consultant and Company as appropriate. Any changes will be documented as a revision as appropriate.

Appointing the Investment Manager.

Seeking a replacement Investment Manager should the incumbent manager not successfully fulfil the role for which he was appointed.

Reviewing the benchmark against which performance is compared on a regular basis.

Meeting the Investment Manager as required and reviewing with them their past actions and future intentions together with the performance against the benchmark/target return.

Providing cashflow information to the Investment Manager.

Reporting annually on the Fund to the beneficiaries of the Plan.

Investment Manager

The GMG Lifestyle Plan: Investment Policy Document February 2013

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2.3 The Investment Manager will be responsible for:

Operating within the agreed guidelines.

Selecting securities within each asset class, subject to any agreed constraints.

Arranging suitable custody for all assets.

Providing the Trustees with weekly valuations.

Providing the Investment Consultant with all the necessary data to enable them to calculate an accurate time-weighted return on the portfolios.

Generating any cash as required by the Trustees.

Attending Trustees meetings from time to time as required.

2.4 The Investment Manager is Legal & General Investment Management (“LGIM”).

Investment Consultant

2.5 The Investment Consultant will be responsible for:

Providing an annual report for the Trustees on the performance of assets held by the Investment Manager.

Assisting the Trustees in their review of the Investment Manager and the benchmark against which performance is compared.

Assisting the Trustees in their review of the fund options that should be made available to members.

Assisting the Trustees in their review of the role of active management within the Plan.

Advising the Trustees of any changes in the Investment Manager's organisation that could affect the interests of the Plan.

Advising the Trustees of any changes in the investment environment that could either present an opportunity or a problem for the Plan.

2.6 The Investment Consultant is Mercer Investment Consulting. The details of the Consultant’s appointment, including the scope of its remit and its fees, are set out in a contract entered into between the Trustees and the Investment Consultant.


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3. Investment Strategy

3.1 To provide for the differing requirements of the investment policy, namely long term growth versus security in the period approaching retirement, the Plan operates three main Funds:-

Long Term Fund - This Fund will be the main vehicle for the members and is designed to provide long term growth ahead of inflation.

Short Term Fund (Bonds) - This Fund is to provide protection against fluctuations in insurance company annuity rates.

Short Term Fund (Cash) - This Fund is to provide capital security for the lump sum at retirement.

3.2 In addition, the Plan offers six stand-alone funds in which members may invest:

UK Equity Fund

Overseas Equity Fund

Ethical Global Equity Fund

Corporate Bond Fund

UK Government Stocks Fund

Index-Linked UK Government Stocks Fund

3.3 Further details about each of these Funds are provided below.

4. Long Term Fund

Investment Approach

4.1 The underlying investments of the Long Term Fund are to be a diversified portfolio of equity holdings, along with an allocation to investment grade sterling denominated securities (corporate bonds), fixed interest and index-linked gilts. Following a review carried out in 2009, the aim was to reduce the proportion of the Fund’s exposure to equities, on a phased monthly basis (subject to meeting prescribed ‘trigger points’ ), from 85% to 70% and to increase the Fund’s exposure to bonds from 15% to 30% (consisting of 20% corporate bonds, 5% fixed interest gilts and 5% index-linked gilts). The change in the Fund’s exposure to equities and bonds was completed in March 2011.

4.2 On a weekly basis, LGIM will review the 70% equity / 30% bond split and if the weightings lie more than 2% away, then LGIM are required to rebalance back towards the central benchmark weighting.

4.3 The Trustees will set the asset distribution of the equity element of the Fund as the "consensus" strategy adopted by the average fund, as measured by BNY Mellon Asset Servicing (a performance measurement company).


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4.4 LGIM will review the distribution of the Scheme’s equity element of the Fund on a quarterly basis and if any of the Scheme’s weightings lies more than 0.5% away from the average distribution indicated by BNY Mellon’s report, LGIM are required to rebalance back towards the central benchmark weighting.

4.5 The Long Term Fund will hold both UK and overseas equities. In order to try and reduce the volatility of the Long Term Fund a proportion of the overseas equity exposure is hedged back into Sterling.

4.6 The allocation to corporate bonds and fixed and index-linked gilts provides further diversification benefits, along with aiming to dampen some of the equity volatility.

4.7 It is recognised that the Long Term Fund may exhibit a high level of volatility and may underperform other asset categorises over possibly prolonged periods.

4.8 The assets will be invested in pooled funds designed specifically to track agreed market indices. The underlying funds, and their respective indices, are set out below:

Fund Benchmark Index

UK Equity Index FTSE All Share 5% Capped

North America Equity Index FTSE All World – Developed North America

North America Equity Index - Hedged FTSE All World – Developed North America –GBP Hedged

Europe (ex UK) Equity Index FTSE All World – Developed Europe (ex UK)

Europe (ex UK) Equity Index - Hedged FTSE All World – Developed Europe (ex UK) – GBP Hedged

Japan Equity Index FTSE All World Japan

Japan Equity Index - Hedged FTSE All World Japan – GBP Hedged

Asia Pacific ex Japan Developed Equity Index

Asia Pacific ex Japan Developed Equity Index - Hedged

FTSE All World – Developed Asia Pacific (ex Japan)

FTSE All World – Developed Asia Pacific (ex Japan) – GBP Hedged

World Emerging Markets Equity Index FTSE All World All Emerging Markets

AAA-AA-A (‘6A’) Corporate All Stocks Index

All Stocks Gilts Index

All Stocks Index-Linked Gilts Index

iBoxx £ Non-Gilts (ex BBB) All Stocks Index

FTSE All Stocks Gilt Index

FTSE Index-Linked Gilts All Stocks Index

Benchmark

4.9 The overall Fund benchmark will be as follows:

70% Composite benchmark calculated by applying the initial asset allocation of the average equity fund, as measured by BNY Mellon Asset Servicing, to the index return achieved in each sector, calculated on a quarterly basis

20% iBoxx £ Non-Gilts (ex BBB) All Stocks Index

5% FTSE All Stocks Gilt Index

5% FTSE Index-Linked Gilts All Stocks Index


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4.10 Within overseas equities, the following are the target percentages for the proportion hedged back into Sterling within each region:

North America 50% Hedged

Europe (ex UK) 50% Hedged

Japan 70% Hedged

Asia Pacific (ex Japan) 30% Hedged

Performance Objective

4.11 The objective is to track the benchmark return as closely as possible. It is expected that the Fund's return will be within 0.5% of the benchmark return on an annual basis.

Reporting

4.12 Weekly valuations will be required.

Administration

4.13 A full custodial and investment administration service, including dividend collection and tax reclamation, is to be provided.

Investment Management Fees

4.14 The fee scale applied is 0.104% to 0.114% per annum, i.e. 10.4 basis points to 11.4 basis points per annum.

5. Short Term Fund (Bonds)

Investment Approach

5.1 The underlying investments of the Short Term Fund are to be investment grade sterling denominated securities (corporate bonds). Insurance company annuity rates are set with reference to the rate of interest available on medium/long term corporate bonds and therefore such holdings of the appropriate duration are to form the majority of the portfolio.

5.2 The assets will be invested in two long-dated corporate bond pooled funds, the AAA Fixed Interest Over 15 Year Fund and the ‘6A’ Corporate Over 15 Year Index Fund, in equal proportions.

Benchmark

5.3 The overall Fund benchmark will be as follows:

50% iBoxx £ Sovereigns & Sub-Sovereigns AAA Fixed Interest Over 15 Year Index

50% iBoxx £ Non-Gilts (ex BBB) Over 15 Year Index


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5.4 The objective for the Fund will be to obtain a return in line with the benchmark.

Reporting


Administration



5.7 The fee scale applied is 0.091% per annum, i.e. 9.1 basis points per annum.

6. Short Term Fund (Cash)

Investment Approach

6.1 The underlying investments are to be short term cash deposits.

6.2 The assets will be invested in the Legal & General Cash Fund.


6.3 The objective is to achieve a return in line with the LIBID 7-Day Money rate.

Reporting



6.5 The fee scale applied is 0.1% per annum, i.e. 10 basis points per annum, for the Cash Fund.

7. UK Equity Fund

Investment Approach

7.1 The assets will be invested in the UK Equity (5% Capped) Passive Fund.


7.2 The objective is to achieve a return in line with the FTSE All Share 5% Capped Index.

Reporting



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Administration




8. Overseas Equity Fund

Investment Approach

8.1 The assets will be invested in pooled funds designed specifically to track agreed market indices. The underlying funds, and their respective indices, are set out below:

Fund Benchmark Index

North America Equity Index FTSE All World – Developed North America

North America Equity Index - Hedged FTSE All World – Developed North America – GBP Hedged

Europe (ex UK) Equity Index FTSE All World – Developed Europe (ex UK)

Europe (ex UK) Equity Index - Hedged FTSE All World – Developed Europe (ex UK) – GBP Hedged

Japan Equity Index FTSE All World Japan

Japan Equity Index - Hedged FTSE All World Japan – GBP Hedged

Asia Pacific ex Japan Developed Equity Index

FTSE All World – Developed Asia Pacific (ex Japan)

Asia Pacific ex Japan Developed Equity Index - Hedged

FTSE All World – Developed Asia Pacific (ex Japan) – GBP Hedged

World Emerging Markets Equity Index FTSE All World Emerging Markets

8.2 The Trustees will set the asset distribution of the Fund as the "consensus" strategy adopted by the average fund, as measured by BNY Mellon Asset Servicing. This will be reviewed from time to time with the help of the Investment Consultant.

8.3 Within overseas equities, the following are target percentages for the proportion hedged back into Sterling within each region:

North America 50% Hedged

Europe (ex UK) 50% Hedged

Japan 70% Hedged

Asia Pacific (ex Japan) 30% Hedged


8.4 The objective is to track the benchmark return as closely as possible. It is expected that the Fund’s return will be within 0.5% of the benchmark return on an annual basis.


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Reporting


Administration



8.7 The fee scale applied is 0.175% to 0.187% per annum, i.e. 17.5 basis points to 18.7 basis points per annum.

9. Ethical Global Equity Fund

Investment Approach

9.1 The assets will be invested in the Ethical Global Equity Index Fund, which is aimed at investors who wish to take account of ethical, environmental or social principles.


9.2 The objective is to achieve a return in line with the FTSE4Good Global Index.

Reporting


Administration



9.5 The fee scale applied is 0.3% per annum, i.e. 30 basis points per annum.

10. Corporate Bond Fund

Investment Approach

10.1 The assets will be invested in the ‘6A’ Corporate Bond All Stocks Index Fund.


10.2 The fund will be expected to achieve a return within 0.5% per annum of the benchmark. The performance will be monitored against the iBoxx £ Non-Gilt (ex BBB) All Stocks Index.

Reporting



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Administration




11. UK Government Stocks Fund

Investment Approach

11.1 The assets will be invested in the All Stocks Gilts Index Fund.


11.2 The objective is to achieve a return in line with the FTSE All Stocks Gilt Index.

Reporting


Administration




12. Index-Linked UK Government Stocks Fund

Investment Approach

12.1 The assets will be invested in the All Stocks Index-Linked Gilts Index Fund.


12.2 The objective is to achieve a return in line with the FTSE Index-Linked Gilts All Stocks Index.

Reporting


Administration



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13. Additional Voluntary Contributions (“AVC”)

13.1 Assets in respect of members’ AVC are invested in Legal & General’s pooled funds.

Documents

Investment Policy Document - GMG - Feb 2013