JLT PREMIER PENSIONS DUE DILIGENCE DOCUMENT€¦ · TREATING CUSTOMERS FAIRLY 24 Delivering TCF 25 CONDUCT RISK 27 Taking Responsibility 27 Acting With Rigour 27 Being Transparent

DUE DILIGENCEDOCUMENTJanuary 2018

JLT PREMIER PENSIONS

2 JLT PREMIER PENSIONS

DUE DILIGENCE DOCUMENT 3

CONTENTS

INTRODUCTION 5

Pension Administration 6

Wealth and Investment Management 6

Trustee and Corporate Benefits Consulting 6

Technology Solutions 6

OUR MISSION AND VALUES 7

WHAT WE DO 8

WHO ARE WE 9

GOVERNANCE AND RISK MANAGEMENT

OF OUR OPERATIONS 12

Three Lines of Defence 12

Board and ARC Visibility and Oversight of Our

Operations 13

Forums to Enhance and Oversee Our Operational

Governance 13

External Recognition and Accreditation 14

GENERAL CONTROL ENVIRONMENT 15

Staff Recruitment, Training and Development 15

Performance Management 19

Group Internal Audit and Assessment Programme

19

Disaster Recovery and Business Continuity

Planning 20

Information Security 20

Data Loss Prevention 21

Information Technology 22

Complaints and Incident Management 23

Our Role in Society 23

TREATING CUSTOMERS FAIRLY 24

Delivering TCF 25

CONDUCT RISK 27

Taking Responsibility 27

Acting With Rigour 27

Being Transparent 27

Key Tools For Managing

Conduct Risk 28

JLT PREMIER PENSIONS 30

Financial Strength 30

SSAS 30

SIPP 30

Technical 31

Accounts and Calculations 31

Consultancy (SSAS) 31

Investments 31

Administration Systems 32

Quality Assurance Tool 32

Information Barriers 32

Payment Authorisation 33

THE TRUSTEE BOARD 34

OUR SERVICE CHARTER 35

TYPICAL TURNAROUND TIMES 38


INTRODUCTIONThis document will be of interest to members, trustees and their advisers to whom we supply SIPP and SSAS services as well as prospective clients. We hope this document provides the required reassurance that our self-invested pensions business operates within a strong control environment and with the appropriate checks and balances in place to protect the pension schemes and their members in our care.

JLT Premier Pensions is a trading division of JLT’s UK Employee Benefits (JLT EB) business. JLT EB is a

trading division of Jardine Lloyd Thompson Group PLC (JLT Group) and contains JLT Benefit Solutions

Ltd, the company which includes JLT Premier Pensions. JLT Group is one of the world’s leading

providers of insurance, reinsurance and employee benefits related advice, brokerage and associated

services. JLT Group owns offices in 40 territories, and has over 10,000 employees.

135+COUNTRIES*

10,000+

EMPLOYEES

40+

TERRITORIES

Premier SIPP


EMPL

OYEE BENEFITS

Pension Administration

Providing a range of administration services designed to meet the requirements of pension trustees, corporate sponsors and scheme members, from back-office support to fully outsourced administration. Supplemented with payroll, communication, documentation and technical services.

Trustee and Corporate Benefits Consulting

Integrated risk management services to UK pensions trustees and corporate sponsors, including actuarial, investment and risk transfer consultancy, scheme design, governance and independent trustee services.

Employee health and benefit programmes, medical claims administration, occupational health services and placement of health and risk protection policies.

OUR GLOBAL EMPLOYEE BENEFITS BUSINESSES PROVIDE SERVICES INCLUDING:

CONTRIBUTION TO GROUP REVENUE 2017

OUR BUSINESSES

23%

UK & Ireland

Asia

Australia & New Zealand

Latin America

Canada

Europe, Middle East and Africa

Wealth and Investment Management

Advice and support to high net-worth individuals on financial planning, at-retirement support and life protection requirements. Discretionary management of assets for both high net-worth individuals and company pension schemes, in addition to asset-hosting services.

Technology Solutions

Provider of one of the most widely-used UK pensions administration and fund accounting software platforms to private sector pension schemes.

Providing integrated web solutions for access to information and services and benefits management.

Revenue

£320.2m +7%

2016: £300.4m

Trading Margin

16%

2016: 16%

Underlying Trading Profit

£50.1m +1%

2016: £49.5m

Employees

2,621*

2016: 2,656*

EMPLOYEE BENEFITS 2017

* Excludes employees in shared service operations


OUR MISSION AND VALUESThe values we hold in JLT Employee Benefits are aligned to the Mission and Values of the JLT Group

We are here for our customers, we speak their language, we are “real” and “human”, not a faceless organisation.

PERSONAL

Customers are, and always have been, at the heart of what we do. Our clients can trust us to deliver service excellence and efficiency and solve their problems. It’s easy doing business with us.

CLIENT FOCUSED

We think innovatively every day, but we understand that innovative does not mean disruptive. We find flexible solutions to everyday problems and implement better ways of working for our clients.

INNOVATIVE

Our seven business units allow us to be truly expert at what we do. We have the right resources and the right technologies in the right place.

SPECIALIST

OUR MISSION

OUR VALUES

COLLABORATION

We recognise that our people drive our success.

Our people work together as ‘One JLT’ to share knowledge, solve problems and deliver the best solutions for our clients.

AGILITY

We think fast, move swiftly and act decisively.

Our entrepreneurial drive gives us the freedom to take on new challenges, think creatively and capture opportunities that others cannot.

RIGOUR

We work with integrity and discipline and stand up for what we believe in.

Our work is thorough and our solutions are robust, because it matters to us to do what is right for our clients, our people, our trading partners and our investors.


PENSION AND RETIREMENT SERVICES

HEALTH AND BENEFITS

INVESTMENT SERVICES

WEALTH MANAGEMENT

• Providing services to pension trustees and corporate sponsors

• Actuarial and risk transfer consultancy

• Independent trustee services

• Member communications

• Providing advice on and implementing employee health and benefit programmes

• Placing of health and benefit programmes

• Using JLT's online integrated platform BenPal to manage programmes

• Advising on investment discretionary management of assets for high net-worth individuals and pension schemes

• Offering advice and support to high net-worth individuals on holistic financial planning

• At-retirement support and life protection planning

WHAT WE DO

CREATINGCLIENT VALUE

CREATING CLIENT VALUE

We will seek to achieve the best results for our customers;

CONFIDENCEAND PRIDE

CONFIDENCE AND PRIDE

We approach everything we do with a positive attitude; having confidence in our ability

to do a great job; maintaining the highest standards of integrity and professionalism; and

priding ourselves on our ability to provide the best advice to our clients;

DELIVERINGGREAT RESULTS

DELIVERING GREAT RESULTS

We will always deliver the best results; results that make us a great business to buy from

and a great business to invest in;

BRINGING OUTTHE BESTIN PEOPLE

BRINGING OUT THE BEST IN PEOPLE

We foster an inclusive and non-bureaucratic working atmosphere that values the individual;

we will invest in building our shared skills and capabilities; and we will seek to promote

a true meritocracy that is both fair and results-based. The development of our people is

therefore essential to our on-going success;

INNOVATION

We will have a shared obligation to challenge an opinion or approach if we disagree with it;

and we wish to encourage and reward creativity, innovation and entrepreneurship;

ONE EB

ONE EB

We will seek to act as ‘One Firm’ by sharing knowledge and resources and collaborating

across our business to deliver the best of JLT to all our clients and trading partners.

We achieve this by focussing on what our clients and members need from us.


WHO ARE WE

NATASHA MOSSTechnical Manager

MALCOLM REYNOLDSManaging Director

DARREN BRAMECommercial Risk Director

RICHARD PRIOROperations Director

JESSICA TILEYSSAS Manager

SIMON WASHINGTONSIPP Manager

JIM BRADLEYTechnical Manager

PATRICK EVANSSenior Manager

SIMON PERRYBusiness Development Manager


MALCOLM REYNOLDSManaging Director

RICHARD PRIOROperations Director

DARREN BRAMECommercial Risk Director

PATRICK EVANSSenior Manager

Malcolm has over 25 years’ experience in the pensions industry. He was previously a Director at PricewaterhouseCoopers where he spent 11 years and was responsible for the pensions management consultancy services. Malcolm was also a Director at Profund Systems Limited responsible for Business Development, Professional Services and Company Strategy. His main area of expertise is in large scheme administration outsourcing. He is an Associate of the Chartered Insurance Institute and a Chartered Insurance Practitioner. In his role as Executive Sponsor for the Scheme, he would liaise at Executive Level with key stakeholders and be your ultimate point of escalation.

As JLT’s Head of Self Invested Pensions, Richard oversees all operational aspects of JLT’s SIPP and SSAS business. Richard manages the customer service teams, technical hub and the business development function and has operational responsibility for service delivery, management reporting and controls, business strategy, and resourcing. He has over 30 years’ of experience working in the pensions industry having performed a range of technical and complaints management roles at NPI, Legal & General and Liberata, as well as key relationship and senior operations management roles within Hazell Carr before he joined JLT. Richard is passionate about delivering outstanding customer service and embedding a customer orientated culture, believing that “everything we do as a business should be built around developing a clear understanding of what advisers and their clients require and ensuring that every interaction or transaction is as quick and simple as possible for them”.

Darren has held a number of roles within the fi nancial services industry over the last 28 years, and has been with JLT for the last 17 of those in a number of roles within JLT Employee Benefi ts, most recently as Director, Commercial Finance with the EB Group Finance function.

In 2006 he moved into the EB Administration business as Commercial Risk Director assuming responsibility for JLT Premier Pensions and representing the business on the Administration Executive Board. He is an Associate of the Chartered Institute of Management Accountants (CIMA) and an Associate of the Chartered Institute of Credit Management (CICM). In addition he Chairs the Risk Management Group, the TCF Forum and is the Confl ict of Interest Champion for the Administration Solutions business within the EB Group of companies.

Patrick has been working in the pensions industry for over 30 years with a focus on self-invested pensions. He is a Director of our SIPP and SSAS Trustee Companies. Patrick works closely with the client servicing teams and business development team and provides technical support to our key IFA partners. Within the JLTPP business Patrick’s key roles include managing its technical support team; overseeing that our trustee duties and responsibilities are met; working with Richard Prior on business development opportunities, ensuring the technical integrity of the business is maintained and that we comply with our regulatory responsibilities.


Jessica has been with JLT for 3 years and is responsible for the operational running of the SSAS and Accounts & Calculations teams. The SSAS team has 9 members with an average of 15 years’ experience, whilst the A&C Team has 3 members. Jessica has worked in the financial services industry for 25 years in the following areas, Pensions, Transfers, Audit and Regulated Complaints. Jessica provides financial advisers and members with support and ensures that our targeted SLAs are met.


NATASHA MOSSTechnical Manager

JESSICA TILEYSSAS Manager

JIM BRADLEYTechnical Manager

SIMON WASHINGTONSIPP Manager

Simon has worked in fi nancial services for 32 years, the bulk of which has been spent consulting to the IFA community. This has provided him with a broad understanding of the intermediary landscape and he believes that supporting IFAs to help deliver excellent client outcomes in an increasingly complex market is the most enjoyable function of his role. Simon holds the Diploma in Financial Planning.

Natasha has been working at JLT for over 20 years. She specialises in the actuarial calculations for both SIPP and SSAS. Having previously managed the Accounts & Calculations and SIPP Teams, her knowledge of the product and the business is extensive. Somewhat of a troubleshooter for the department, Natasha turns her attention to helping clients and putting schemes back on track. Her main focus on the Technical Team revolves around how to get money in and out of schemes and the calculations that surround these often complex topics. Natasha is CertPMI level 4 qualifi ed.

Jim has over 30 years’ experience within fi nancial services, 21 years of which have been specifi cally within the SSAS and SIPP sector. His focus within the business is training oversight, technical support and management of the business risk plan. He has a keen interest in both personal and professional development, working closely with the JLT Training Academy and external providers to ensure that all our staff receive the very best opportunities for personal and career development. Jim is a Chartered Insurance Risk Manager and an associate of the Chartered Insurance Institute.

Simon has been with JLT for 5 years and is responsible for the operational running of the SIPP team. Simon manages 15 team members, all with different levels of experience. Simon provides fi nancial advisers and members with support and ensures that our targeted SLAs are met. Simon has worked in the pensions industry since 2008 in a range of areas: administration, managing portfolios, auditing executive pension schemes, completing scheme returns, processing contracting out payments and complex reconciliations, as well as working in a sales support environment prior to joining JLT.


GOVERNANCE AND RISK MANAGEMENT OF OUR OPERATIONSThree lines of defence applied to our operations

1ST LINE OF DEFENCE

These are controls embedded in the business process i.e. internal peer review, quality checks on work

etc. This control is necessarily close to the business operations and therefore benefits from detailed

knowledge of the business operations but lacks independent challenge. These controls are adjusted by

senior management when necessary to reflect changes in the business model, in response to incidents

and the root cause analysis that follows, or in response to patterns identified through monitoring.

2ND LINE OF DEFENCE

JLT’s Group Risk and Compliance (GRC) and Group Compliance Monitoring (GCM) teams work with the

Employee Benefits business to provide scrutiny, monitoring and guidance. Although this brings a level

of independence, there is naturally a reduced level of detailed knowledge of the business operation. We

therefore work closely with our Group colleagues to benefit from the challenge and advice which these

teams offer and to support continuous improvement across our business.

GRC report independently to the Board and Audit and Risk Committee (ARC) – see below – providing

the level of independence appropriate to challenge the business.

The GRC provides guidance and oversight on all matters related to the firm being regulated by the

Financial Conduct Authority (FCA) and further manages the relationship with the FCA.

3RD LINE OF DEFENCE

Our JLT Group Internal Audit (GIA) team provides fully independent challenge to the business operation.

Again, this would not always be with detailed knowledge of the business operation and of course rests

outside the control of the business and cannot be factored into the internal control planning.

Naturally, there are also elements of the firm’s operations that are subject to challenge by independent third

party bodies e.g. external auditors, professional accreditation, client appointed auditors etc. These provide

a valuable challenge to the firm and provide independent evidence that quality assurance measures are

implemented and effective.


BOARD AND ARC VISIBILITY AND OVERSIGHT OF OUR OPERATIONS

JLT EMPLOYEE BENEFITS GROUP

JLT BENEFIT SOLUTIONS LTDBOARDUltimate responsibility for managing risk

1ST LINE OF DEFENCE

2ND LINE OF DEFENCE

3RD LINE OF DEFENCE

GROUP RISK MANAGEMENT JLT MANAGEMENT SERVICES LTD Responsibility for implementing & managing the risk management process

BUSINESS ENTITIES Responsibility for embedding risk management within day to day activities:• Risk Identification• Risk Measurement• Risk Appetite &

Target Risk Rating• Risk Response

GROUP INTERNAL AUDIT JLT MANAGEMENT SERVICES LTDResponsibility for challenging the risk management process & verifying key controls

AUDIT & RISK COMMITTEEResponsibility for ongoing monitoring & review of risk management

The Directors account to the Board of JLT Benefit Solutions Ltd at bi-monthly meetings where the

pension control environment and performance levels are scrutinised by both Executive Directors and

Non-Executive Directors.

Similarly reports are provided to the ARC at their quarterly meetings throughout the year.

FORUMS TO ENHANCE AND OVERSEE OUR OPERATIONAL GOVERNANCE

CHANGE EXECUTIVE

The Change Executive ensures alignment of projects and change initiatives to our client requirements and

to JLT’s strategy and vision. This covers all change initiatives that redefine Employee Benefit systems or

processes and all client projects which require support beyond the core delivery teams.

The responsibilities of the Change Executive include holding project sponsors to account for the delivery of

the benefits against which the project has been approved; overseeing progress across the change portfolio

and ensuring adequate mitigation is in place to address material variances; approving (or rejecting) the

business cases for new projects and setting priorities in the event that resource or funding constraints exist.

RISK EXECUTIVE

The Risk Executive is responsible for the management of risks across the business. It forms part of JLT’s

Group Risk Management Framework and is responsible for implementing an agreed risk management

strategy, governance and control framework (1st line of defence). The Risk Executive reports the key risks

and actions to the ARC highlighting issues for attention; ensures a common approach to risk management

is embedded across the business.


EXTERNAL RECOGNITION AND ACCREDITATIONAll of our JLTEB UK and JLTI Pension Administration offices comply with our Quality Management

System (QMS) and hold ISO 9001:2008 certification, demonstrating an effective QMS with a strong

customer focus. We proactively measure our performance and processes against customer satisfaction,

ensuring that our processes are robust and that our people are technically competent, fostering an

atmosphere of continual improvement.

All offices also comply with the JLT Information Security Management System (ISMS) that meets the

requirements of ISO/IEC 27001:2013. The Bracknell and Edinburgh pension administration and Mumbai

and Pune teams also hold ISO/IEC 27001:2013 certification, and we are looking to extend certification to

include our other UK locations.

Every UK JLT office has been awarded ISO22301 certification, the internationally recognised standard

covering Disaster Recovery (DR) and Business Continuity Planning (BCP).

Our ISO certifications are awarded by the British Standards Institution (BSI).

We complete annual, independently audited AAF 01/06 and ISAE3402 reports on internal controls which

set out the processes and controls adopted and operated within our pension administration offices.

These reports provide reassurance that the pension administration business in scope operates within

a strong control environment with appropriate checks and balances in place to protect the pension

schemes in our care.


GENERAL CONTROL ENVIRONMENT

Staff Recruitment, Training and Development

Information Security

Performance Management

Information Technology Profund CASHFAC Workflow and Electronic Document Management

Group Internal Audit and Assessment Programme

Complaints and Incidents Handling

Disaster Recovery and Business Continuity Planning

Client Control Procedures

The previous section provided an overview of key issues such as governance, risk management framework and operational changes made during the year. In this section we summarise some of the main systems and controls that support the pension administration operation.

STAFF RECRUITMENT TRAINING AND DEVELOPMENTJLT values its staff as their greatest asset. The

development of our colleagues is therefore

essential to our ongoing success. JLT provides

continual learning and development opportunities to

encourage personal and professional advancement.

We recognise and reward colleagues for both

individual and team achievements that contribute

to the success of our business.

This creates a working environment that attracts

and retains the best talent and encourages them to

perform at their best.

RECRUITMENT

Our HR Team works in partnership with the Curve

Group (Recruitment Process Outsource Provider) to

ensure a robust recruitment and selection process

which is reflected in staff performance and a high

retention rate. Roles are advertised internally to

promote internal progression.

The recruitment procedure places strong emphasis

on the assessment of competence, the ability of the

applicant to work as part of a team and their wish to

progress their career and professional development.

DIVERSITY

Working as we do across a wide range of

specialisms, industries, and geographies, we

recognise that having a highly talented and diverse

employee population is key to serving our clients’

diverse needs.

We treat all employees fairly, irrespective of

their gender, race, ethnic origin, disability, age,

nationality, national origin, sexuality, religion or belief,

marital status and social class. We oppose all forms

of unlawful and unfair discrimination.

All employees, whether part time, full time or

temporary, will be treated fairly and equally and

with respect.

Selection for employment, promotion, training or any

other benefit will be on the basis of aptitude and ability.


All employees will be helped and encouraged to

develop their full potential and the talents and

resources of the workforce will be fully utilised to

maximise the efficiency of the organisation.

TRAINING AND DEVELOPMENT

We operate a robust and comprehensive training

and competence regime which actively mirrors the

requirements and expectations of the regulatory

authorities.

We recognise that staff development is a priority if

we want to ensure that our people can progress

with their career and personal growth. We also

recognise that by enhancing our staff’s capabilities

they can utilise their acquired skills when providing

services to our clients.

JLT is committed to providing an environment

through which all staff have access to

opportunities to develop to their full potential and

maximise job performance.

We have a dedicated Talent and Development

function and a JLT Training Academy that is

committed to ensuring that effective training and

development strategies are in place for all staff

within JLT. We have written responsibilities that

set out the goals and responsibilities regarding

training for JLT for our training coordinators, every

member of staff and every line manager.

Every member of staff has a Personal

Development Plan, which is reviewed in annual

appraisals and at regular one-to-ones covering:

• Performance against role (including peer and

self-analysis)

• Technical knowledge (e.g. Annual and Lifetime

Allowances, transitional protections, carry

forward etc)

• Process knowledge (e.g. investment/benefit

calculations)

• Software utilisation/knowledge (e.g. use of

Delta SIPP/SSAS Pro/Microsoft applications)

• Soft skills (e.g. Complaints handling, letter

writing, problem-solving including ‘Root Cause

Analysis’ and ‘Train the Trainer’)

We have found that empowering staff to

take responsibility for their development and

providing them with access to a wide range of

technical, professional and soft skills training

and qualifications gives us a more rounded and

developed employee and increases our rate of

staff satisfaction and retention.

Clients will continue to benefit from our training

regime through highly qualified, experienced and

knowledgeable colleagues who can articulate

the complexity of pensions to clients and their

members. The primary objective of the dedicated

Training Team is to comprehensively support our

colleagues to develop in accordance with their

personal requirements whilst also ensuring they

gain the necessary skills and capabilities required

to deliver our service efficiently and successfully.

Training is delivered in a variety of formats:

• On the job – this is generally recognised

as the most effective approach to training

employees and the achievement of “focussed

experience”. We operate a “buddy” system in

this regard

• Classroom – we offer both internal and

external sessions/courses

• Workwise – this is JLT’s on-line learning portal.

It features literally hundreds of courses and

assessments covering both technical and

soft skills also incorporating a Continued

Professional Development tracker. Workwise

is used in the delivery of our mandatory annual

courses such as Data Protection, Financial

Crime etc

• Talent and Development TV – these are videos

whereby senior executives from within the

group offer guidance on career development

through their own experiences.


PMI / CII QUALIFICATION PATHWAY

The Training Academy are accredited by the

Pensions Management Institute (PMI) to run and

assess several of their qualifications including

the Award in Pension Essentials (a mandatory

minimum level qualification for all staff), and

Certificate in Pension Essentials. We are also

approved trainers of the Certificate in Pension

Calculations. Most recently, we have formulated

a new qualification, the Certificate in Pension

Scheme Member Guidance.

To complement the Training Academy, we have

a detailed professional qualifications study policy

in which we support staff across a wide range of

qualifications. In addition to the full range of PMI

qualifications we also support those offered by the

Chartered Insurance Institute.

Over 50% of our staff at JLT Premier Pensions

have taken advantage of this additional support

in order to further their knowledge and skills. This

has had a tangible impact on their ability to help

and support clients as well as one another.

Customer care training takes place throughout

our business. This covers all points of contact,

whether by telephone, face to face, or in written

correspondence. Although staff are experienced

in their respective fields, training is aimed at

continual consideration of the delivery of our

service from the member’s perspective, effectively

by putting us “in their shoes”. We are a member of

the Institute of Customer Services and the Training

Academy is accredited by them to deliver their

First Impressions course. Part of the customer

care training includes a special section on

“Treating Customers Fairly” to enable our staff to

ensure that they understand and deal with clients

appropriately in the event that they have any

grievance or cause for complaint. The importance

of Treating Customers Fairly is further reinforced

and embedded through a mandatory annual

course and assessment.

Clients benefit from our training regime through

better qualified, confident and experienced staff

who can articulate the often complex world of

pensions to the membership. Our primary objective

is to aid staff members to develop in accordance

with their personal requirements whilst also

ensuring they gain the necessary skill set required

to deliver our service successfully and efficiently.

TRAINING AND COMPETENCY SCHEMES

Our role is also to oversee, guide, monitor,

deliver and report on the various Training and

Competence (T&C) Schemes ensuring that the

firm’s objectives and culture are firmly embedded

and checking that all T&C Schemes are current

in terms of reflecting the requirements of any

appropriate regulator.

We have a responsibility to communicate findings

and actions to Senior Management and to report

to the Board and Audit and Risk Committee (ARC)

as to the status of and adherence to the T&C

schemes highlighting any matters that require

Board or ARC action.

We recommend improvements and changes

to the Schemes to ensure they remain fit for

purpose and support the business of JLT with an

appropriate training and development structure.

WORKWISE

A key element of our training programme and

delivery is the WorkWise e-based learning system

through which we delivery our Annual Mandatory

Regulatory Training modules.

The current programme covers:

• Conflicts of Interest

• Bribery and Corruption

• Information Security

• Financial Crime (Including Money Laundering,

Fraud & Sanctions)

• Conduct Risk & Treating Customers Fairly


• Data Protection Act

• Complaints and Incidents

• MAR & Share Dealing

• Client Data Collection and Useage Policy

REMUNERATION AND BENEFITS

We look to recruit the best and look after them!

We offer a very attractive remuneration and

benefits package. In addition to an above average

salary, we also offer the following:

• annual salary review;

• reward and recognition bonus scheme;

• pension scheme which is funded through

both employee and generous employer

contributions;

• “Choices” is the group’s flexible benefit

scheme that gives employees the opportunity

to tailor a range of benefits to suit their

personal needs. JLT offer a further contribution

to be used in conjunction with generously

discounted benefits and tax concessions;

• life assurance cover, typically up to six times

annual salary;

• private medical insurance;

• annual health check;

• permanent health insurance;

• share awards.

We like to keep healthy and as standard, a range

of fresh fruit and refreshments are also provided.

EMPLOYEE LED ACTION TEAM AND THE BUSINESS PARTNERSHIP FORUM

Each JLT office has an Employee Led Action

Team (ELAT), whose role is to collate questions

and ideas from staff with a view to improving any

element of the business. Whilst these generally

tend to deal with local issues such as office or

process changes, ideas, initiatives have also fed

into the wider group such as our Reward and

Recognition programme.

Complementing this is the Business Partnership

Forum (BPF) which is a partnership between

HR, the Executive and employees. Comprising

22 elected regional representatives, they

represent the views of management and staff –

the overarching aim is to ensure that all views

are represented, ideas developed and agreed

initiatives implemented. Ultimately, this serves to

improve the way we in which we work as well as

our health and well-being.

STAFF TURNOVER

It is accepted that from time to time members of

staff will leave for a variety of reasons. All leavers

are subject to an on-line Exit Questionnaire to

establish the reason for the staff member leaving

and to assist in identifying any issues. Details

of the survey website link are provided to the

employee in the Resignation Acknowledgement

email sent by Human Resources team.

The results of the JLT leaver questionnaire are

provided to the National Human Resources team

on a quarterly basis for analysis.

Staff attrition for JLT Premier Pensions has been

less that 7% p.a. over the last 5 years.


PERFORMANCE MANAGEMENTWe have a formal competency framework which

staff will be placed into in accordance with

discussions held with them and their current grade

and experience. The competency framework will

ensure staff remain competent to carry out the

duties they are asked to perform and develop

them to reach higher levels should staff so wish

to do. There is a formal training and development

plan established for every member of staff by local

management and the JLT Training Academy.

Employees all participate in the bi-annual appraisal

process which looks to assess performance and

career opportunities and future development

needs for progression. Support is also provided

in terms of professional qualifications, continuous

professional development and management and

leadership development.

Performance is formally documented and lodged

within our HR systems. When assessing our

peoples’ performance, a review of both personal

and business objectives is undertaken, against

agreed key indicators and smart measures.

Our focus is typically on the customer, financials,

people and continuous improvement. Since 2015

there has been a strong development in the area

of assessment of ‘Technical and Behavioural

Competencies’ which are now built into appraisals

and the training and competence scheme.

This continual performance measurement

programme, that not only measures our staff

but also supports and rewards our employees,

encourages them to strive to achieve excellence in

everything that we do.

GROUP INTERNAL AUDIT AND ASSESSMENT PROGRAMMEWhen considering Governance and Risk, we

previously commented on the role of Group

Internal Audit (GIA) as a key control in the

monitoring of the business as the ‘Third line of

defence’. Crucially this is an independent Group

function provided by JLT Management Services

Ltd with a remit documented in the Terms of

Reference approved by the Group Audit and Risk

Committee (GARC).

The overarching objective of GIA is to help protect

the assets, reputation and sustainability of the

organisation, and promote an effective internal

control environment. It does this by independently

assessing whether all significant risks are identified

and appropriately reported to the Group Board

(via the GARC), and Employee Benefits Audit &

Risk Committee and Executive Management;

assessing whether they are properly controlled;

and by challenging Executive Management to

improve the effectiveness of governance, risk

management and internal controls.

GIA performs, objectively and independently from

Employee Benefits management, three principal

functions:

• Assessing and reporting on the effectiveness

of the design and operation of the framework

of controls (including risk management) which

enable risk to be managed effectively by first

and second lines of defence.

• Undertaking designated advisory projects for

management, provided they do not threaten

GIA’s actual or perceived independence from

management.

• Investigation and reporting on cases of

suspected financial crime/employee fraud,

as may require independent assessment, in

addition to and/aligned with activities of JLT’s

Risk and Compliance function (‘Second line of

defence’).


The Group Head of Internal Audit (or appointed

representative) is a standing attendee at the

Employee Benefits ARC, where the principal

responsibilities are to:

• Develop and agree the annual programme

of audits/reviews aimed at assessing the

effectiveness of controls to ensure JLT’s

management of key business risks.

• Report findings, conclusions and

recommendations from audit work

undertaken, or other key issues relevant to the

risks inherent in the achievement of Employee

Benefit’s objectives.

• Provide updates on the completion of agreed

management actions arising from previously

reported issues.

Further, GIA supports JLT Employee Benefits

with ISO assessments, which aim to determine

whether the controls and procedures in

place meet the requirements firstly of the ISO

9001:2008 which specifies the requirements

for a quality management system in meeting

customer requirements, and secondly the ISO/

IEC 27001:2013 which specifies requirements for

Information Security Management Systems (ISMS).

DISASTER RECOVERY AND BUSINESS CONTINUITY PLANNINGAn important part of JLT’s overall business strategy

relates to the effective management of risk

with particular reference to Business Continuity

Management (BCM), IT recovery and compliance

with all necessary regulatory requirements.

JLT has a formal BCM Policy, which is sponsored

at Board level and rigorously implemented and

audited. All JLT UK businesses are accredited

under ISO22301:2012.

Each JLT office has a tailored recovery strategy

and Business Continuity Plan. JLT’s plans enable

us, in the event of a major incident, to recover

our business within a timely manner and ensure

we continue our high levels of service to our

customers and clients.

All Business Continuity Plans for each site is subject

to testing in accordance with an agreed timetable.

INFORMATION SECURITYInformation security is very much at the top of

the agenda for the JLT Group Internal Audit

Committee.

An Information Security governance structure

also exists with clear reporting lines and

accountabilities.

For detailed information pertaining to the General

Data Protection Regulation, please refer to our JLT

EB Privacy and Security Statement.

A Group wide Information Security Committee is

in place which includes senior managers and key

Risk and compliance representatives from both

the EB business and Group Compliance function,

as well as representation from Group Data

Protection and Group IT. Its Terms of Reference

are to assess all data held, categorise that data,

effect and maintain group policies and ensure the

relevant business entities implement appropriate

business specific procedures, and have in place

robust controls in order to minimise risk of loss

and/or misuse. The Committee is responsible for

liaison between all of the various stakeholders

within the business. The Information Security

policies of the Group are sponsored by the Group

Finance Director who is directly accountable to the

Group Internal Audit Committee.

JLT Employee Benefits (JLTEB) has both its own

dedicated Data Protection and Information Security

Officers, who are responsible for implementing and

maintaining the previously mentioned procedures

and controls. These procedures and controls

would, as expected, cover matters such as

security, both physical and IT data transfer, clear

desk and confidential waste disposal.


JLTEB has a range of procedures and controls

in place around information security such as

data transfer policies, which when sending data

electronically requires the use of encryption and

file transfer protocols, the monitoring of which is

undertaken by the Data Loss Prevention (DLP)

tool. In addition the use of Removable Storage

Media (RSM) is strictly controlled and system

restrictions only facilitate the use of an encrypted

RSM. The availability of access to external media

such as Hotmail and G-mail is also denied and

e-mail traffic to personal e-mails is also monitored

by the DLP tool. Protocols exist in respect of

what information is allowed to be disclosed both

electronically and by way of telephone.

In addition, a defined incident reporting process

is in place to ensure any breaches of the Data

Protection/Information Security procedures are

identified and handled appropriately, with quarterly

reporting to both senior management and the

Group Audit and Risk committee, where data

protection is a standing agenda item. In addition

management information on the completion of

mandatory training modules is also included

within our Treating Customers Fairly dashboards,

produced by all JLTEB entities, which are standing

agenda items for the statutory Boards.

Data Protection and Information Security

training, which includes tests with a set number

of attempts and a minimum pass mark are

undertaken as part of the induction process

for new employees and annually thereafter.

Monitoring of the completion of the training and

test results is undertaken by the JLTEB Training

and Competency Manager.

DATA LOSS PREVENTION (DLP)JLT processes, stores and transmits significant

amounts of commercially sensitive and personal

data each day. Maintaining the confidentiality,

integrity and availability of this data is paramount

in ensuring that we protect our clients data, we

meet our regulatory responsibilities, prevent

financial sanctions and preserve our reputation.

The DLP software performs an important role in

meeting the above, identifies monitors and protects

confidential data wherever it is stored or used

across networks, storage and end-point systems.

In particular, DLP enables the identified control

deficiencies to be rectified in the following ways:

• Recording data transferred by e-mail or

uploaded to internet domains in circumstances

which contravene JLT policy;

• Recording where data is stored locally on

mobile devices in circumstances which

contravene JLT policy;

• Recording where data is transferred on or

off local drives (i.e. via removable media) in

circumstances which contravene JLT policy.

The DLP is set up with certain parameters that

reflect the JLT information security policy and

flags potential breaches of this policy as they

occur. These potential breaches/incidents are then

assessed internally and dealt with as appropriate.

There is in place a Group DLP steering group

responsible for setting the DLP parameters and

putting in place an effective incident management

framework. There is also a DLP user group

formed of representatives across the JLT Group,

which meets on a monthly basis to discuss

incidents, share best practice and submit where

required improvements to system use and policy.

Both groups are chaired by the JLT Group Data

Protection Officer.

JLT installed the software during 2014 and we

continue to explore, via the above groups, the

various control options it provides. The immediate

facility has been the ability to monitor potential

misuse of data and non-adherence to company

policy on the transmission of data.


INFORMATION TECHNOLOGYThe appropriate use of IT is fundamental to our

business risk strategy. All systems are backed

up and we support the business with on-site

assistance and a Business Support Manager point

of escalation and telephone helplines.

IT Services, along with other core shared and

group services, are delivered through JLT

Management Services Ltd. Management Services

IT (Group IT) is responsible for the delivery of all

JLT’s IT services and this is primarily done through

a number of outsource partners including HCL

Technologies, who provide infrastructure and

other services to JLT.

HCL provide infrastructure and hosting related

services to the JLT Group including desktop,

server, storage, backup, network and telephony

provisioning and support. Datacentre services are

sub-contracted to Sungard via HCL (note that

Sungard have provided a SOC 1 report).

The following IT Controls are managed and

operated by HCL and monitored by JLT

Management Services:

• Physical access to computer networks,

equipment, storage media and program

documentation is restricted to authorised

individuals;

• IT processing is authorised and scheduled

appropriately and exceptions are identified

and resolved in a timely manner;

• The physical IT equipment is maintained in a

controlled environment;

• Data and systems are backed up regularly,

retained offsite and regularly tested for

recoverability;

The Monitoring Controls in place for these items are:

Monthly meetings are held with external parties

to review and monitor the outsourced service and

service levels. This covers the following areas:

• Service availability;

• Incident and problem management;

• Scheduled jobs;

• Data backup and restorations;

• Security and antivirus status.

Business users do not have admin access to

any of the applications. This is restricted to the

Application Support team and HCL Database/

Windows administrators, who do not manage

Business Practices.

The JLT Group takes protecting client data very

seriously. Our group approach to cyber security

requires both a technology and behavioural

approach, given the nature, scale and complexity

of the threats. Our approach therefore includes

adopting industry good practice for IT security

controls, process and policy, supported by

training and awareness.

Our cyber framework is based on ISO 27001 and

the National Institute of Standards and Technology

(NIST) cyber security standards which are endorsed

by UK and US governments. It is also recognised

that insurance is an important component of

managing cyber risk. In the event of an insured

cyber event, JLT’s cyber insurance provides cover

and access to specialist response capabilities e.g.

forensics to supplement our own resources.

There are defined governance processes covering

the Group’s IT relationship with all suppliers and well

defined monitoring and reporting of agreed service

levels and security standards. Formal processes are

in place for all aspects of Service Delivery and these

follow Information Technology Infrastructure Library

(ITIL) v3 best practice – all suppliers are also held to

ITIL v3 best practice standards.

There is a formalised contract between JLT BS

Ltd and JLT Management Services Ltd for the

provision of all shared services.


COMPLAINTS AND INCIDENT HANDLINGDespite robust controls and internal audit evaluation

programmes, we may not meet our own and our

clients’ high expectations all of the time. Meaning it is

important that complaints – or indeed any expression

of dissatisfaction – are dealt with in an appropriate

manner and in line with industry recognised standards

under treating customers fairly (TCF) guidance and in

line with our own Client First values.

The company has a control framework for the

monitoring and management of all complaints

and incidents. This framework provides for all

complaints and incidents to be reviewed weekly by

an experienced panel of qualified staff, identifying

areas where root cause analysis can be used to

establish the causes and direct how we might

learn from such events. This is then monitored to

ensure that the causes have been eliminated and

that any new controls or processes are successfully

implemented across the business.

All complaints are recorded centrally with the

business being supported by experienced staff

in the management of the complaint through the

consumer experience team.

The process is designed – and supported by

the company culture of client first – ensuring

that complaints received in relation to the

service provided by JLT, whether from Trustees,

employers, pension scheme members or third

parties, are dealt with in a professional, fair and

equitable way supporting the TCF principles,

promoting a return to a good consumer

experience of the brand.

OUR ROLE IN SOCIETYJLT takes its role in society very seriously and has

an active Corporate Responsibility programme.

JLT’s approach is coordinated by a Corporate

Responsibility Steering Committee, whose

members include two Executive Directors,

the Head of Investor Relations and the Group

Company Secretary. We also have a Diversity

Committee, which is chaired by the Deputy Group

CEO and which has led a range of activities in

the past year including sponsoring the Lloyd’s

Diversity campaign and the Dive In Festival.

JLT supports the charitable efforts of colleagues

around the Group. We match pound-for-pound

money raised by UK staff in fundraising activities and

all UK staff are entitled to take one Charity Day per

year, when they can spend company time helping a

charity. The Group Charities Committee considers

the many requests we receive from charities

and takes a particular interest in those charities

connected to communities local to our offices.

We are also keen to ensure that we minimise our

environmental impact and we take a number of

steps to reduce our carbon footprint, such as

encouraging the use of video and teleconferencing

facilities where possible, instead of travelling to

face-to-face meetings.

Over the last five years, JLT Premier Pensions have not received any SIPP or SSAS complaints that have been upheld by either FOS or POS


Treating Customers Fairly (TCF) is one of the

central themes by which the Financial Conduct

Authority (FCA) delivers its objectives. Whilst TCF

relates to many of the eleven FCA principles upon

which the Rules and Guidance for businesses

are based, the JLTEB Board has adopted the

following 6 measurable High Level “Core value”

outcomes which are based on FCA research on the

perceptions of fairness from a customer perspective:

OUTCOME 1: Consumers can be confident that they are dealing with firms where the treatment of customers is central to Corporate Culture

• TCF is embedded into the business as a

culture that helps drive and shape our product

design and customer service proposition.

• All product literature is clear and has to pass a

rigorous compliance sign-off process.

• Product fees are clarified clearly on T&C’s and

are applied consistently.

• Wherever possible work is completed in a

timely fashion and the business challenges itself

to meet demanding internal service SLAs.

• All complaints and incidents are logged in line

with JLTs complaint management process

and complaints are dealt with fairly and

consistently. Outcomes trends, complaint

reasons and compensation trends are all

monitored to identify areas for improvement

and to ensure our decision making process

remains consistent. Only appropriately skilled

staff within the business manage complaint

handling, which again ensures a fair and

consistent approach.

• Only appropriately skilled staff are recruited to

the business for any available positions and

a comprehensive training and development

programme is in place. All staff have to

undertake regular testing via JLT’s online

Workwise system and specific technical skills

are assessed every 6 months with weakness

identified to drive training requirements.

OUTCOME 2: Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly

• JLT PP products are only marketed to

qualified/authorised IFAs and not direct

customers. This helps ensure products are

suitable for individual client requirements.

• Complaint levels are monitored regularly

to highlight any potential issues relating to

product suitability or advice.

• JLT PP does not pay any commission or

introduction fees to third parties, to ensure

any advice or product selection is on an

unbiased basis.

• Bonuses for business development

consultants are balanced to ensure that

payments are only triggered if a wide range of

criteria are satisfied, which include complaint

levels relating to new customers, quality of

business as well as new business volumes.

This ensures a focus on quality of business as

well as new business volumes.

TREATING CUSTOMERS FAIRLY


OUTCOME 3: Consumers are provided with clear information and are kept appropriately informed before during and after the point of sale

• All product literature is clear and has to pass a

rigorous compliance sign-off process.

• Comprehensive and compliant pre and post-

sale product documentation is supplied to

clients and their advisers.

• Clients are given the right to cancel within 30

days.

OUTCOME 4: Where consumers receive advice, the advice is suitable and takes account of their circumstances

• JLT PP do not provide advice and this is

highlighted to all prospective clients.

• JLT PP’s strategy and culture is geared

towards working with high quality IFAs that

we build relationships with and who deal with

high net-worth clients and deliver high quality

business.

OUTCOME 5: Consumers are provided with products that perform as firms have led them to expect, and the associated service is of an acceptable standard and as they have been led to expect

• JLT PP endeavour to meet challenging internal

SLAs relating to service standards.

• Only appropriately skilled staff are recruited to

the business for any available positions and

a comprehensive training and development

programme is in place. All staff have to

undertake regular testing via JLT’s online

Workwise system and specific technical skills

are assessed every 6 months with weakness

identified to drive training requirements.

• All complaints and incidents are logged in line

with JLTs complaint management process

and complaints are dealt with fairly and

consistently. Outcomes trends, complaint

reasons and compensation trends are all

monitored to identify areas for improvement

and to ensure our decision making process

remains consistent. Only appropriately skilled

staff within the business manage complaint

handling, which again ensures a fair and

consistent approach.

OUTCOME 6: Consumers do not face unreasonable post sale barriers

• Standard internal SLAs determine strict

turnaround times for TV out work, which are

treated as priority items.

• Transfer out fees are set at fair and reasonable

levels.

• If a client transfers within an annual

administration period a proportion of fees will

be refunded on a pro rata basis.

• JLT PP products are geared to an IFA market

with no marketing to direct customers, which

ensure new business levels are predominantly

driven through an advised route.

DELIVERING TCF JLTEB ensures that TCF remains embedded in the

business through ongoing consideration of the key

cultural drivers for TCF identified by the FCA:

Leadership: Fair treatment of customers is central

to the behaviour and values of all managers, they

communicate messages about the fair treatment

of customers effectively and apply appropriate

controls and monitoring to ensure that the fair

treatment of customers is delivered by their staff.


Strategy: The firm has a clear vision which

supports the fair treatment of customers.

This is reflected within the formulation and

implementation of strategic decisions (including

change management programmes and outsource

arrangements). The firm’s risk appetite reflects

customer considerations.

Decision making: Decision making at all levels

reflects the fair treatment of customers. The firm

uses staff, customer and other external feedback

where appropriate, with timely action. The interests

of customers are properly balanced against those

of shareholders (and other customer groups).

Controls: The firm has controls, including

management information, that aim to ensure and

demonstrate the fair treatment of customers. These

controls are integral to the firm’s risk framework.

Training, recruitment and competence:

Management make positive behaviours and

attitudes to the fair treatment of customers a key

criterion in the selection of staff. They also make

effective training and the maintenance of staff

knowledge, behaviours and values core to the

business. Managers use performance management

to develop their staff in the fair treatment of

customers, identifying and acting on poor

performance and rewarding good performance.

Reward: The firm’s reward framework (including

incentive schemes) throughout the business is

transparent, recognises quality and supports the

fair treatment of customers.

Whilst senior managers are responsible to the FCA

for delivering TCF, it is the responsibility of all staff

to ensure that they themselves treat customers

fairly. All staff are fully empowered to raise any TCF

concerns they have with their business managers,

with the Quality, Risk and Compliance team or with

Senior Management directly.


Conduct Risk is the risk of unfair customer

outcomes arising from the way in which we

conduct ourselves.

The JLT mission of “Client First” is embedded in

the way in which we run our business. It is part of

our strategy to:

• Put our clients first.

• Demonstrate our integrity.

• Align the interests of our clients and our

trading partners.

Our values are cascaded from the most senior

level and everyone at JLT is expected to embrace

the way we manage Conduct Risk by:

TAKING RESPONSIBILITY• Taking responsibility: People at JLT take

personal responsibility. We understand we

all have a role to play in minimising risks for

clients and for JLT. Where we have potential

conflicts of interest we seek to communicate

them to our clients in a transparent manner.

• Acting with Integrity: People at JLT strive to

act with integrity and honesty in their dealing

with clients, trading partners and each other.

We understand that poor individual behaviours

can have a much wider impact on JLT and all

our stakeholders.

• Aligning interests: People at JLT strive to

align their interests with those of their clients

and trading partners. We seek to ensure that

the way our incentives are structured do not

drive poor client outcomes.

ACTING WITH RIGOUR• Respect the rules: People at JLT follow our

internal processes and codes of practice.

We respect the laws, industry codes and

regulations under which we all operate.

• Remain vigilant: People at JLT remain on

the lookout for new sources of risk. We are

alert to our changing competitive, economic,

operating and regulatory environment and the

risks these create for us.

• Take action: People at JLT look to take action

to address issues and mitigate risks. We are

proactive and care that we get to the right result.

‘Rigour’ is central to the management of

Conduct Risk in JLT. All employees receive risk

training which sets out the Group’s position and

expectations for how ‘rigour’ should be applied.

BEING TRANSPARENT• Openness: People at JLT are open and

communicate clearly, sharing information to

help effective risk management.

• Seek Advice: People at JLT escalate issues

or risks rapidly to management. We do not sit

on bad news in the hope it will go away.

• Welcome challenge: People at JLT welcome

challenge and encourage people to come

forward with risks and issues.

CONDUCT RISK


KEY TOOLS FOR MANAGING CONDUCT RISKManagement information and assurance to

support our Conduct Risk framework is provided

by our:

• Placement and claims processes.

• Market security process.

• Risk and control assessment process and risk

reporting.

• Processes and controls to identify and

mitigate potential or actual conflicts of interest.

• Treating Customers Fairly information.

• New product approval process.

• Quality assurance process.

• Complaints handling process.

• Information security and data protection

frameworks.

• Financial crime framework.

• Client money process.

• HR, recruitment, induction, training,

performance management, remuneration and

reward processes.

• Compliance monitoring reviews.


JLT PREMIER PENSIONS

JLT Premier Pensions provide self-invested

pension services for both Small Self-Administered

Schemes (SSAS) and Self Invested Personal

Pensions (SIPP).

FINANCIAL STRENGTHAs part of a global FTSE 250 listed Group, JLT

Premier Pensions benefits from the financial

strength of the JLT Group, which enables the

business to continually invest in its people,

systems, service and product offerings. Whilst

JLT Premier Pensions is profitable in its own

right, the financial strength of the JLT Group

also enables the business to consider strategic

acquisitions and partnerships to ensure

economies of scale and to enhance our overall

proposition. In addition, JLT Premier Pensions

benefits from being able to utilise the full range of

resources available within the wider JLT Group.

For the financial year ending 31st December

2017, the total revenue for the JLT Group

of companies totalled £1.386 billion with an

operating profit of £213.7 million. JLT’s global EB

business contributed revenue of £320.2 million

and a profit of £50.1 million in the same period.

The continued success of JLT Group plc. has

been reflected in the excellent share price

performance with compound annual growth rate

(CAGR) of 12.2% pa over the past 5 years*. The

Group is positioned at 136 in the FTSE 250 (as

at 5th Feb 2018) with a market capitalisation in

excess of £3.0 billion*.

*CAGR and market calculated using data as at 31st Dec 2017

CAPITAL ADEQUACYAs at 30th June 2017 the Tier 1 Capital held

within JLT Benefit Solutions Ltd was significantly in

excess of the minimum amount that the company

is required to hold to satisfy the FCA’s Capital

Adequacy requirements.

SSASThese are trust based UK pension schemes that

are established by employers specifically for their

directors and key staff. They afford the membership

a wide range of investment options as well as

increased control over the running of their scheme.

Particularly, under certain conditions, the member

trustees may choose to invest directly in the

sponsoring or associated employer.

We act in the role of Professional Trustee and

Scheme Administrator, a specific role as defined in

Section 270 of Finance Act 2004.

We currently provide services to approximately

830 schemes.

SIPPThese schemes are a more flexible version of a

traditional UK personal pension and can be a tax

efficient way of saving for retirement. Generally,

the same benefits are available as with any other

personal pension although the member is able

to select from a far broader investment palette

under a SIPP.

As a regulated product, our team ensure that all

schemes operate within the strict guidelines laid

down by Her Majesty’s Revenue and Customs as

well as the Financial Conduct Authority.


In total we have over 2200 SIPPs and servicing

is split out between our Property and Client

Servicing teams.

TECHNICALOur in-house technical team is well respected

within the industry with each member on the team

having well over 20 years’ experience. They are

well placed to offer informed specialist guidance

across a wide range of subjects in both the

accumulation and decumulation phases.

In addition, the team is further supported at Group

level by JLT’s Quality Research Group and

in-house legal team.

ACCOUNTS AND CALCULATIONSOur Accounts and Calculations Team offer a range

of services including:

• Relief at Source in relation to our SIPP book

(subject to external auditing);

• Managed payroll service. This includes setting

up the bespoke payroll scheme for pension

payments, accounting for tax and all statutory

real-time information reporting to HMRC;

• SSAS accounts preparation;

• VAT Registration and Administration (VAT

Return Submission) Service;

• SSAS Tax Return (SA970) service, ensuring

that the pension scheme’s self-administered

Tax Returns are kept up to date and relevant

tax is reclaimed on any investments where

we are provided with the appropriate tax

voucher/certificate;

• Loan interest calculations for both Authorised

Employer Loans (SSAS) and unconnected

Third Party Loans (SSAS and SIPP).

CONSULTANCY (SSAS)The workload associated with running self-

invested pension schemes has increased.

Changes in legislation, the ever increasing

complexity and sophistication of investment

matters coupled with increasing regulatory

attention mean that more so than ever, Trustees

need to keep in sharp focus their responsibilities.

We offer a full consultancy guidance service

covering off such areas as pensions reform,

contributions, benefits, commercial property

investments etc.

INVESTMENTSAlthough current tax legislation allows a wide

range of investments, as trustee and Scheme

Administrator, we have chosen to limit some of

the investment types permitted under our SIPPs

and to a certain extent under our SSASs. This has

primarily been driven by the changing regulatory

environment under which we operate and a

reassessment of the risks.

We have published Investment Mandates for both

SSAS and SIPP. All investments are reviewed to

determine if they fall under standard or non-

standard as broadly defined within the industry.

Non-standard assets held do not currently exceed

3% of total holdings (excluding commercial

property and fixed interest cash deposits).

We carry out due diligence on all investment

providers.

In addition, we carry out extensive due diligence

reviews on all non-standard investments to ensure

that we are:

• understanding the nature of the investment

and its suitability, establishment, aims and exit

provisions;

• ensuring that an investment is genuine and

not a scam, or linked to fraudulent activity;


• carrying out appropriate checks in relation

to fraud, money laundering and pensions

liberation;

• ensuring that an investment is safe/secure

(meaning that custody of assets is through a

reputable arrangement, and any contractual

agreements are correctly drawn-up and legally

enforceable);

• ensuring that an investment can be

independently valued, both at point of

purchase and subsequently;

• ensuring that an investment is not impaired

(for example that previous investors have

received income as expected, or that any

investment providers are credit worthy etc.).

Following direct consultation with the Financial

Conduct Authority, for appropriate persons we

are able to consider investments such as unlisted

shares and unauthorised collective investment

schemes provided they meet with our strict criteria.

ADMINISTRATION SYSTEMSOur SIPP and SSAS administration systems

are provided by Delta Financial Systems Ltd

(Delta). Delta is a privately owned company and

has been providing software to the UK pension

administration market since 1996.

Their two key products SSAS~Pro and SIPP~Pro

have been specifically designed to ensure that

Scheme Administrators can fulfil their legal and

professional responsibilities. It is important to

note that the business rules in this market, as

enforced by HMRC, DWP, tPR and FCA, are not

only complex but have been subject to continuous

change. Delta have consistently demonstrated

their ability to provide rapid system updates as

and when required.

As well as dealing with all administrative processes

associated with the accumulation and decumulation

phases of the pension lifecycle, system functionality

covers regulatory reporting, tax claims, cash

management and banking, investment management,

property management, scheme and customer

invoicing, payroll, work log, illustrations and SIPP Web

on-line functionality.

QUALITY ASSURANCE TOOL The work we complete is checked and verified

through our bespoke Quality Assurance Tool prior to

issue. This affords us a number of benefits such as:

• identification of individual and departmental

training requirements;

• accurate recording of individual and

departmental outcomes to help identify trends;

• accurate recording of individual quality scores

to assess competency;

• understanding the root cause of errors to

identify systems or process enhancement

requirements;

• promote staff accountability for work;

• to ensure that only suitably experienced staff

complete and check certain key processes;

• identification of failures to follow processes;

• identification of failures in the processes;

• prevention of customer detriment.

INFORMATION BARRIERSInformation barriers exist within the wider JLTEB

organisation to ensure JLT Premier Pensions

clients details remain in house and will not be

used for any other sales or marketing activity.


PAYMENT AUTHORISATION All payments are subject to a strict checking and

authorisation process with only senior persons

being approved under our signatory lists A and B (A

containing the most senior and experienced staff).

The authority levels have been set out in the

following table:

Payment Amount Checker 1 Checker 2 Authoriser

Up to £10,000 Group B N/A Group A

Up to £100,000 Group A N/A Deputy Team Leader

Up to £500,000 Group A Deputy Team Leader Team Manager

Up to £1,000,000 Deputy Team Leader Team Manager Tech Manager

Over £1,000,000 Team Manager Tech Manager Exec Manager


KENNY TINDALL Trustee Director

Kenny Tindall is the CEO of the Premier Pension Trustee Companies. He is

an actuary by background and has other wider accountabilities within JLT

including business development, client management for a number of our key

clients and as JLT’s insurance relationships director. Prior to joining JLT, Kenny

was at Aegon where he managed their defined benefit and bulk purchase

annuity businesses.

PATRICK EVANS Trustee Director and Senior Manager

Patrick is our Senior Technical Manager and has been working in the pensions

industry for nearly 30 years with a focus on self-invested pensions. He is a

Director of our SIPP and SSAS Trustee Companies. Patrick works closely

with the client servicing teams and business development team and provides

technical support to our key IFA partners.

Within the JLTPP business Patrick’s key roles include managing its technical

support team; overseeing that our trustee duties and responsibilities are

met; working with the Richard Prior on business development opportunities,

ensuring the technical integrity of the business is maintained and that we

comply with our regulatory responsibilities.

MARK JONES Trustee Director

Mark is the Chief Financial Officer and Deputy Group Finance Director, his role

encompasses three distinct areas: Finance, Quality Compliance and Risk and

Legal and Contracts. Originally a Chartered Accountant he has been with JLT

for over 15 years.

NIGEL MANLEY Trustee Director

Nigel Manley is Chairman of the various Trustee Companies covering both

SIPP and SSAS. Nigel has spent over 35 years in various roles in employee

benefits including as an IFA and more recently being responsible for the day to

day management of the SIPP and SSAS administration operation in Cardiff. His

experience extends to a period as compliance officer for the employee benefits

group of JLT which provides valuable experience in the oversight of the SSAS

and SIPP operation in his current role.

LYNDON JONES Trustee Director

Lyndon Jones is a non-executive Director of JLT’s employee benefits

companies. He is an Actuary by background and is also an independent

trustee of five defined benefit pension schemes. Lyndon had his own actuarial

practice for many years, specialising in providing services to pensions

consultants offering SSAS and SIPP services.

THE TRUSTEE BOARD


OUR SERVICE CHARTERAt JLT, we understand the importance of a swift turnaround and pride ourselves on providing a first class service – accurate, quick, efficient, friendly and of course flexible.

Whilst we’ve set out below our typical SLAs, often

we are dealing with third parties and this can

have an impact on timings. However, our staff

are trained to look ahead and anticipate barriers

and bottlenecks when dealing with transactions

to manage expectations and facilitate as far as

possible the quickest possible resolution.

• We task ourselves with completing at least

95% of all work within 2 days.

• We encourage an open work environment

where work flow processes are continuously

challenged by all.

• We provide dedicated points of contact.

• If you call us, we aim to answer all calls within

10 seconds, there will be no “blind transfers”

and if preferred, we will call you back at the

agreed time.

• We have well trained, friendly, knowledgeable

and caring staff who are identifiable by name,

there when you want them and who are

happy to help.

• We understand that the world of pensions can

be complex and that not everyone we engage

with is an expert; being appreciative of this

fact, we act accordingly.

• On occasions, we may get things wrong

and when we do, you can be assured that

we will do all we can to put matters right.

We understand that customer feedback and

complaints analysis provide opportunities to

make our service even better going forward.

If a customer is not happy then neither are

we. We want to hear about it so that we can

put things right.

• All outgoing emails contain a link to a

Customer Satisfaction Survey, details below.

• Days mean working days and whilst requests

received after 12pm will generally be treated

as having been received at the start of the

next working day, we always try our best

to be flexible and appreciate that often a

transaction may be time sensitive; if this is

the case please be sure to let us know and

we will try our utmost to accommodate.

• Achievement against standards is robustly

monitored not only locally but also at group

level. The chart overleaf, taken from our

internal Administration Solutions Monthly

Dashboard, relates to the year 2017.


99%

98%

98%

98%

98%97%

97% 98% 98%

96%

99%

January March

May

September October

July

December

February April

June

November

August

100%

CUSTOMER SATISFACTION SURVEY RESULTS FOR THE PAST YEAR.

93.2% rated us either Excellent or Good

91%stated that we made it easy for them when handling their query

Percentage of work completed within SLA for Premier Pensions.

The Premier Pensions business continue to complete an average of 98% of work within SLA.


As a niche provider of SIPP and SSAS products for over 30 years, we focus on delivering a personal,

tailored service, placing emphasis on building lasting relationships with clients and their advisers.

“By partnering with JLT PP as our preferred SSAS provider, we ensure we deliver favourable solutions to our clients through an efficient service driven proposition. Invaluable support through complex subjects”.

CHRIS ELLIS

of One Financial Planning

“I have been working with the team at JLT for over 28 years. Growing our fund safely and staying abreast of the complex regulations is paramount for a family run business like ours.

We have always been able to rely on JLT to professionally guide us in this process. ‘A safe pair of hands’ in short”.

NIALL CREIGHTON

The Creighton Trust

“My colleagues and I have used the services of JLT Premier Pensions for many years and have always found them to be efficient, knowledgeable and friendly. They are always ahead of the game and I would not hesitate in recommending them”.

DAVID COX

Mark Jarvis Racing Ltd

“The team at JLT Premier Pensions have been thoroughly efficient and helpful in my dealings with them. My parents and I recently purchased our business premises utilising our SIPPs and I was impressed with their professional and personable approach and particularly the way in which they took control and guided the transaction through to completion, a first class job”.

DAVE GRAY

T B Davies Ltd


TYPICAL TURNAROUND TIMES KEY TASKS

NEW SIPP/SSAS APPLICATIONS

• initial vetting, AML checks and set-up;

• illustrations/feasibility reports;

• bank account set up.

2 DAY

TRANSFERS/ASSIGNMENTS

• in or out cash/in specie per stage.2 DAY

BANKING

• cheques and payments on cleared funds1 DAY

STANDARD INVESTMENTS

• as per our investment mandate.2 DAY

NON-STANDARD INVESTMENTS

• initial vetting and decision.3 DAY

PROPERTY TRANSACTIONS

• all associated work such as purchases, sales,

• leases, developments etc, per stage.

2 DAY

BENEFIT PAYMENTS

• all associated work such as Flexi-access drawdown, capped to flex elections,

Uncrystallised Fund Pension Lump Sums, annuity purchase etc;

• pension payments are generally run on the 1st and 25th of the month

3 DAY

GENERAL ENQUIRIES

• e.g. ad hoc valuations, technical enquiries, requests for information;

• complex enquiries requiring more in depth research.

2 DAY

5 DAY

Whilst we always endeavour to meet these targets it is important to note that:

• we are sometimes impacted by third parties or other factors outside of our control;

• these do not form a part of our contractual obligations;

• we accept no liability as a result of investment price fluctuations during the

investment/disinvestment process.



JLT Employee Benefits. A trading name of JLT Benefit Solutions Ltd. Authorised and regulated by the Financial Conduct Authority. A member of the Jardine Lloyd Thompson Group. Registered Office: The St Botolph Building, 138 Houndsditch, London EC3A 7AW. Registered in England No. 02240496. VAT No. 244 2321 96.

© January 2018 275978

CONTACTS

RICHARD PRIORDirector

+44 (0)29 055 7012

+44 (0)790 092 8104

[email protected]


+44 (0)738 423 2067

[email protected]

JLT Employee Benefits

The St Botolph Building 138 Houndsditch London EC3A 7AWTel +44 (0)20 7528 4000Fax +44 (0)20 7528 4500www.jltgroup.com

Documents

JLT PREMIER PENSIONS DUE DILIGENCE DOCUMENT€¦ · TREATING CUSTOMERS FAIRLY 24 Delivering TCF 25 CONDUCT RISK 27 Taking Responsibility 27 Acting With Rigour 27 Being Transparent