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Welplan Pensions Old Mansion House Eamont Bridge Penrith Cumbria CA10 2BX Welplan Pensions Master Trust Controls Report (Extract Report) in accordance with AAF 02/07 and ISAE 3000 as at 31 August 2015

Welplan Pensions Master Trust Controls Report (Extract Report)

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Page 1: Welplan Pensions Master Trust Controls Report (Extract Report)

Welplan Pensions Old Mansion House Eamont Bridge Penrith Cumbria CA10 2BX

Welplan Pensions Master Trust Controls Report (Extract Report) in accordance with AAF 02/07 and ISAE 3000 as at 31 August 2015

Page 2: Welplan Pensions Master Trust Controls Report (Extract Report)

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Introduction This report is an Extract Report of the Master Trust Controls Report for Welplan Pensions (the Scheme). It highlights the control environment and internal controls for master trust services, and related information technology controls, operating as at 31 August 2015, and reported in our AAF 02/07 Master Trust Controls Report signed 4 November 2015. The Scheme’s Master Trust Controls Report, which contains full details of the Scheme’s control objectives and procedures, will be provided to The Pensions Regulator. Members and participating employers will have details of the Scheme’s controls made available to them. Welplan Pensions Trustee Company Limited, the independent Trustee Board of the Scheme is pleased to present this report setting out the control environment and internal controls for the Scheme’s Master Trust services operating as at 31 August 2015.

Welplan Pensions was formed by the Building and Engineering Services Association (B&ES, previously known as the HVCA), in 1988 as an industry-wide, multi-employer, trust-based occupational pension scheme for employers in the building and engineering services sector. Having subsequently expanded and now delivering to any business sector, this longstanding Master Trust continues to provide cost-effective, simple yet flexible, automatic enrolment and bespoke workplace pension solutions for employers of any size across their entire workforce - directly to employers or through their advisors.

The Scheme’s Administrator, Welplan Ltd, has more than 50 years of experience in providing large scale benefit schemes for a significant number of participating employers and their employees. The Trustee Board of Welplan Pensions, which is independent of both the B&ES and Welplan, works alongside Welplan to govern the provision of good long term member outcomes by establishing quality features such as reviewing investment options, fund performance, performance of service providers, trustee knowledge and understanding, engagement with employers and members, whilst member charges are always kept to a minimum.

Welplan Pensions has been awarded The National Association of Pension Funds (NAPF) Pensions Quality Mark Ready status demonstrating that the Scheme meets best practice standards on governance, charges and communications. The Scheme Administrator has continued to hold ISO 9001:2008 certification since 2008 on the management of its systems and documentation having been subject to regular quality review and, if necessary, improvement.

The Scheme has developed and performed evaluations to ascertain whether the components of internal control are present and functioning. This Master Trust Controls Report has been prepared having regard to the Institute of Chartered Accountants England and Wales (ICAEW) Technical Release 07/14 ‘Assurance Reporting on Master Trusts (Master Trust Supplement to ICAEW AAF 02/07)’ and the Committee of Sponsoring Organisations of the Treadway Commission (COSO) framework. The Trustee Board of Welplan Pensions appointed an ICAEW reporting accountant, Assure UK, to provide independent assurance on the Scheme’s control procedures. A statement on this independent assurance is given by the Reporting Accountants in section 2 of this report.

We are pleased to note that Assure UK had no exceptions to report and have concluded that all controls were suitably designed and described as at 31 August 2015 in line with the AAF 02/07 Master Trust requirements.

It demonstrates the Trustee Board’s intention to deliver fit-for-purpose, easy to administer, well communicated and governed DC pension provision to employers for their employees.

Our control environment and the AAF 02/07 Master Trust control objectives are described in Sections 3 and 5 of this extract report of the Scheme’s Master Trust Controls Report. Chair of the Trustee Board of Welplan Pensions 4 November 2015

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Contents Introduction ............................................................................................................................................. 1

1. Assertion by the Trustee Board of Welplan Pensions............................................................................. 3

2. Report by the Reporting Accountants ................................................................................................... 4

3. Business Overview and Control Environment ........................................................................................ 5

4. Summary of Control Objectives........................................................................................................... 11

5. Control Objectives and Control Procedures ......................................................................................... 14

Disclaimer……………………………………………………………………………………………………………………………………………... 15

If you are receiving this Report in your capacity as a prospective new customer (i.e. post 31 August 2015) of Welplan Pensions then your attention is drawn to the Disclaimer at the back of this Report which outlines the basis on which you have received this Report and the Reporting Accountants’ Assurance Report therein.

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1. Assertion by the Trustee Board of Welplan Pensions As Trustee Directors we are responsible for the identification of control objectives relating to the provision of Master Trust services by Welplan Pensions (Scheme) and the design, implementation and operation of controls to provide reasonable assurance that the control objectives are achieved. In carrying out those responsibilities we have regard not only to the interests of customers but also to those of the owners of the business and the general effectiveness and efficiency of the relevant operations. The accompanying description has been prepared for customers who use the Scheme’s pension administration services and their auditors (who have sufficient understanding to consider the description, along with other information such as knowledge of the controls operated by customers themselves) when assessing the risks of material misstatement of the customers’ financial statements.

We have evaluated the fairness of the description and the design suitability of the Scheme’s controls of Master Trust services having regard to the International Standard on Assurance Engagements (ISAE 3000), issued by the International Auditing and Assurance Standards Board, the Technical Release AAF 02/07 (AAF 02/07), issued by the Institute of Chartered Accountants in England and Wales, and the control objectives for Master Trusts set out the ICAEW Technical Release 07/14, ‘Assurance Reporting on Master Trusts (Master Trust supplement to ICAEW AAF 02/07)’ as described in section 4 of this report.

We confirm that:

A. The accompanying description at section 5 fairly presents the control procedures that relate to the control objectives referred to above for Welplan Pensions’ master trust services as at 31 August 2015. In addition to the control objectives specified in AAF 02/07, the criteria used in making this assertion were that the accompanying description: (i) presents how the services were designed and implemented, including: the types of services provided, including, as appropriate, the nature of transactions processed; the procedures, both automated and manual, by which customer transactions were initiated, recorded and processed; the accounting records and related data that were maintained, reported and corrected as necessary; the means by which the administration systems captured and addressed significant events and conditions, other than customer transactions; the security, availability and recovery characteristics of information technology systems and other aspects of our control environment, risk assessment process, monitoring and information and communication systems, that were relevant to our control activities; and (ii) does not omit or distort information relevant to the scope of the services being described, while acknowledging that the description is prepared to meet the common needs of a broad range of customers and their auditors and may not, therefore, include every aspect of the services that each individual customer may consider important in its own particular environment.

B. The control procedures related to the control objectives stated in the accompanying description were suitably designed as at 31 August 2015. The criteria used in making this assertion were that: (i) the risks that threatened achievement of the control objectives stated in the description were identified; (ii) the specified controls would, if operated as described, provide reasonable assurance that those risks did not prevent the stated control objectives from being achieved; and (iii) the controls were applied as designed, including manual controls which were applied by individuals who have the appropriate competence and authority as at 31 August 2015.

Chair of the Trustee Board of Welplan Pensions Signed on behalf of the Trustee Board of Welplan Pensions 4 November 2015

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2. Report by the Reporting Accountants Reporting accountants’ assurance report on the governance and administration control procedures of Master Trusts to the Trustee Board of Welplan Pensions (Scheme)

On 4 November 2015, Assure UK issued an Assurance Report which had no exceptions in relation to the assertions made by the Trustee Directors of Welplan Pensions that as at 31 August 2015 the Scheme had met the design and description requirements of master trust control objectives for master trusts as set out the ICAEW Technical Release 07/14, ‘Assurance Reporting on master trusts (Master Trust supplement to ICAEW AAF 02/07)’. These master trust control objectives are set out in section 4 of this Extract Report and also in section 4 of the master trust controls report as at 31 August 2015 signed 4 November 2015.

A full copy of the Assure UK Assurance Report and the Welplan Pensions AAF 02/07 master trust controls report (including the Trustee Directors’ section 5 description of the control procedures relating to the control objectives referred to above) can be made available to customers of Welplan Pensions, their auditors and by exception potential customers on acknowledgement of a disclaimer of liability as the Assurance Report was addressed to the Trustee Directors of Welplan Pensions and therefore items of possible interest to other parties may not have been specifically addressed.

To the fullest extent permissible by law, Assure UK makes no warranty or representation that the information in the Assurance Report is appropriate for the interests or purposes of prospective customers, or as to the truth and accuracy of the contents, including without limitation, as to whether the information has changed in any way since the date of the Assurance Report. Therefore the Assurance Report cannot in any way serve as a substitute for enquiries and procedures that prospective customers would (or should) undertake for the purpose of satisfying themselves regarding any matters relating to Scheme’s controls procedures for any matter arising in the Assurance Report.

Assure UK, its directors, employees and agents neither owe nor accept any duty or responsibility to prospective customers or third parties whether in contract or in tort (including, without limitation, negligence and breach of statutory duty) or however so arising. Assure UK shall not be liable, and prospective customers and third parties shall not bring any action, proceeding or claim in respect of any loss damage or expense of whatsoever nature which results from any use prospective customers or third parties choose to make of the Assurance Report, or any reliance they may seek to place on it.

Assure UK Chartered Accountants London 4 November 2015

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3. Business Overview and Control Environment

Business Overview Our Services Welplan Ltd, a wholly-owned subsidiary of the Building & Engineering Services Association, administers pensions and employee benefit schemes for employers in a variety of business sectors from its office in Penrith, Cumbria. With more than 50 years of experience working with customers of all sizes, Welplan has the flexibility to provide bespoke packages to meet the needs of multiple single employers or employer groups.

Welplan Pensions was set up in 1988 as an industry-wide, multi-employer, trust-based occupational pension scheme for employees in the building and engineering services sector. Now offering pension administration to every business sector, this longstanding Master Trust has a strong track record of providing cost-effective, simple yet flexible, automatic enrolment and bespoke workplace pension solutions for employers of any size across their entire workforce - directly to employers or through their advisors. The Scheme currently has approximately 300 participating employers and c 24,000 members of which c 7,000 are deferred.

How Welplan Pensions is structured

The Trustee Directors of Welplan Pensions Trustee Company Limited, the independent Trustee Board of Welplan Pensions, provide robust governance to ensure that decisions on matters such as charges, investment strategy and administration are taken with the best interests of members in mind at all times.

The Trustee Board has appointed Legal and General Assurance (Pensions Management) Limited to manage members’ investment funds in accordance with the Scheme’s Statement of Investment Principles. Professional advisors appointed for investment, legal and financial reporting matters report to the Trustee Board at intervals determined through the Trustee Board’s identification and assessment of risks. The reporting framework for professional advisors and reviewing their services is managed using the Trustee Board’s Resource Planner.

Welplan Ltd (Welplan), the Scheme’s Administrator, carries out the Scheme’s day to day management of data and operations. Having listened to employers’ and members’ views and, with the aim of meeting their expectations regarding simplicity, flexibility and cost-effectiveness, the Trustee Board has overseen Welplan’s deployment of new technology and IT governance to enhance processes and controls over pension administration and communication. This, together with the Trustee Board’s revision of the Scheme’s reporting framework, has enabled employers’ and members’ Scheme experiences to be straightforward and responsive.

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The Trustee Board of Welplan Pensions

Colin Richardson – Trustee Director (Chair) has 26 years in pensions work including actuarial, consultancy and trusteeship. He acts as independent trustee on several DB and DC pension schemes both large and small including 4 DC Master Trusts and also is a member of the Internal Governance Committees for two leading workplace pension providers. Colin chairs the PTL Governance Advisory Arrangement for pension providers which provides governance for 12 further pension providers. He is formerly a Director at KPMG and a partner at Barnett Waddingham with subsequent senior positions at JLT and Buck Consultants. Colin also has advised upon auto-enrolment design and implementation, has significant project management experience relating to pension arrangements and has delivered numerous Trustee training courses and spoken at many pensions industry events. Colin is a former chair of the Association of Consulting Actuaries (ACA) Investment Committee and a former member of the ACA Local Government Committee and NAPF Yorkshire Committee. Bruce Kirton – Trustee Director is the Chief Executive of Welplan Ltd and has been a director-trustee of Welplan Pensions since 1999, firstly as a director of long-standing corporate trustee Welplan Ltd and, since April 2015, as a member of the new independent trustee board. Bruce joined Welplan in 1991 and has extensive trustee experience of trust-based employee benefit schemes, including both defined benefit and defined contribution pension arrangements.

Cedric Sloan – Trustee Director graduated from Liverpool University in 1968 with an honours degree in electrical engineering and was then commissioned in to the Royal Engineers. His Army career of 30 years covered a variety of command and staff appointments across the world. He gained a Masters degree in defence administration from Cranfield University before retiring as a lieutenant colonel to join the Federation of Environmental Trade Associations (FETA) as its Director General. He retired from this second career in 2014 and became an independent trustee for Welplan Pensions in 2015.

Richard Read – Trustee Director has worked in the Building Services Industry for 36 years. Starting as an Indentured Electrical Apprentice and finally retiring as Chief Executive of a major Building Services company. He has continued to put his business and commercial experience to use as a non-executive director of Welplan Ltd. He has also a keen interest in pension issues being a Trustee Director of Welplan Pensions and a Member Nominated Trustee of the Lorne Stewart Pension Scheme.

Andrew Ramsay – Trustee Director has over 10 years of experience in the field of pensions, having held employer nominated and member nominated trustee positions in various schemes. Formerly chief executive of the Chartered Institution of Building Services Engineers and of the Engineering Council, he now practices as a freelance advisor to charities and professional bodies on governance issues. He is a chartered secretary and a chartered engineer.

Gillian McKillop - Secretary to the Trustee Board joined Guardian Royal Exchange in Edinburgh in

1986 with an accountancy degree and began training towards Associateship of the Chartered Insurance Institute (CII). She joined Welplan in 1992 and, whilst managing the administration of a variety of Welplan’s multi-employer pension and employee benefit schemes, qualified as a Fellow of the CII. In her dedicated role as Secretary to the Trustee Board, Gillian draws on 29 years of pensions experience and knowledge to support to the independent Trustee Board, ensuring that reporting from service providers is monitored and developed as necessary and that Board decisions are actioned.

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Welplan Pensions - Senior Management Team

Trustee Board Management and Governance

To enable robust governance standards to be maintained the Trustee Board meets quarterly and holds interim meetings as required from time to time to consider and review on-going projects and to carry out necessary governance matters. The Trustee Board’s Risk Register and Resource Planner are applied and updated at each quarterly meeting as the Trustee Board identify and assess risks in relation to Scheme objectives and plan the ongoing management of these risks.

To monitor internal controls and to evaluate and communicate any internal control deficiencies in a timely manner to the parties responsible for taking corrective action including senior management and directors, the Trustee Board has developed a management reporting framework to be carried out between quarterly meetings. Monthly management information is provided by the Scheme Administration manager to the Secretary to the Trustee Board who assesses the information and reports on it quarterly to the Trustee Board. Where necessary, matters may be escalated by the Secretary to the Trustee Board between quarterly Trustee Board meetings: - to the CEO of Welplan; through to the Trustee Board.

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Staff Policies and Practices (Welplan)

Welplan has a framework of HR policies and guidelines to ensure compliance with legal and ethical requirements and expected company behaviours. Welplan recognises the value of the staff who deliver the Scheme and currently holds the Silver Standard Investors in People award.

Staff are expected to maintain the system and procedural compliance which is integral to the ISO 9001:2008 certification in Quality Management Systems held by Welplan since 2008. Annual external reviews of staff policies and practices are held to maintain certification.

In addition to professional body Continuing Professional Development requirements, Welplan recognises the benefits of providing structured and unstructured opportunities for staff development across the business. There are regular opportunities to participate in Institute of Leadership and Management training and qualifications and a structured process of Personal Development Reviews seeks to identify individual training opportunities. Staff regularly participate in industry briefings and conferences as well as being involved in pensions industry association committees.

As a data intensive business, Welplan recognises its responsibilities in terms of data and financial protection and fully complies with statutory and industry requirements.

Control Environment

Risk Management and Internal Control

Welplan understands the importance of protecting the interests of members and compliance with industry and statutory requirements. ISO 9001:2008 certification ensures that staff recognise the importance of procedures and a consistent approach to data handling to ensure consistent delivery of a high quality service. Regular internal auditing against ISO 9001:2008 requirements ensures that all staff are aware of objectives and responsibilities associated with procedures and controls. Six-monthly meetings are held between the Business Services Manager responsible for ISO 9001:2008 and the Pensions and Employee Benefits Manager in charge of pension administration. The purpose of these meetings is to discuss any trends or patterns arising, to support Welplan’s ethos for continuous improvement and to assess current and new risks. Key points arising from these reviews are reported to Senior Management.

Welplan seeks to obtain formal feedback from members and their employers about the quality of the services provided to them and this information is used to adapt internal controls as necessary.

Regular review of the Trustee Board’s Risk Register aims to identify the need for any changes to procedures and controls. At Welplan, a variety of accounting and internal controls are designed to prevent and detect fraud. These include restricted access to buildings, pension systems and Scheme databases; segregation of duties between pension administration and finance staff; investment and payments authorisation levels; monthly, independently reviewed bank reconciliations; monitoring of contribution receipts; reconciliation of pension system investment records with investment management holdings; data update and amendment controls; review of member-requested transfers out for potential pension liberation fraud. Fraud risk mitigation and associated controls are also considered as part of internal audit reviews.

Welplan has regular dialogue with The Pensions Regulator to provide data and feedback on relevant Scheme control matters and information about the Scheme’s internal control mechanisms.

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Complementary Control Procedures of Customers

It is not feasible for the control objectives relating to pension administration services to be achieved solely by Welplan. For customers to rely on the controls reported at Section 5, each customer is required to evaluate its own internal controls to determine whether:

• member data and contributions are provided as instructed and on a complete, accurate and timely basis;

• changes to individuals authorised to instruct Welplan are communicated in writing and on a timely basis;

• security controls to protect member data are in place; • records are maintained to support location of members Welplan has been unable to trace or

locate; • contingency plans have been developed to ensure that information can be consistently

communicated to Welplan in the event of a system error or other disruption

Business Continuity and Disaster Recovery

Business Continuity and Disaster Recovery Plans (which include testing Business Continuity location facilities) are maintained by Welplan, are tested by regular process walk-throughs and associated reports are provided to the Trustee Board.

Information Security

The Trustee Board understands that the protection of Scheme data is critical and has established appropriate controls to ensure that information security is monitored and reviewed.

When member data is received via email it is contained within encrypted attachments. Data is submitted by participating employers via https secure connections. Enterprise class software provides anti-virus and anti-malware protection which is updated daily. Microsoft tools manage security and other updates to servers and desktop systems. Access to Welplan’s offices, server and data communications rooms and software applications is controlled by a range of electronic and username/password protection managed by Welplan and third party system providers. Access to back-up data is restricted and is stored off-site in secure locations.

Welplan regularly reports to the Trustee Board setting out the Scheme’s security procedures and processes.

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4. Summary of Control Objectives SAFETY OF ASSETS AND RECORDS

Commercial and business risks

1. Discontinuance plans, which address how member assets or entitlements are safeguarded in the event of the master trust or any key service provider failing, are documented, approved and maintained.

Business and disaster recovery

2. Data and systems are backed up regularly, retained offsite and regularly tested for recoverability. Business and information systems recovery plans are documented, approved, tested and maintained. 3. The capacity of an administration system to take on new business is assessed, approved and regularly monitored. 4. New business take-ons are properly established in accordance with the master trust’s rules and contractual arrangements. Data quality and security

5. Member data is complete and accurate and is subject to regular data evaluation. Data transmissions are secure and appropriate measures are implemented to counter the threat from malicious electronic attack. 6. Physical and logical access to computer systems, and member and master trust records and data, is restricted to authorised persons. 7. IT equipment is maintained in a controlled environment and the maintenance and development of systems, applications and software is authorised, tested approved and implemented. Protection of assets

8. Member assets or entitlements are safeguarded from loss, misappropriation and unauthorised use in accordance with a defined policy. 9. Cash is safeguarded and all payments are suitably authorised and controlled. 10. Financial protection available to members in the event of default is assessed and documented, and communicated to employers and members on request. 11. Investment decisions relating to the selection of investments on regulated markets and unregulated investments are researched, authorised and monitored. ASSESSING VALUE

Assessment of value for money

12. A value for money review is undertaken and this review is documented, approved and findings actioned. Communication of costs and charges

13. A complete and accurate list of the types of costs and charges incurred by members and employers is documented, monitored and approved.

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14. Disclosure of information on costs and charges borne by members is provided to employers at the point of selection and is complete and accurate. 15. Disclosure of information to members of costs and charges (rates (%) and amounts (£)) are complete and accurate. ASSESSMENT OF INVESTMENT OPTIONS

Appropriateness of the default strategies

16. The design and ongoing suitability of the default strategies is regularly reviewed and monitored. This review is documented and approved. 17. The performance of the default strategies and funds within the default strategies are regularly reviewed and monitored. This review is documented and approved. Appropriateness of the other investment options (i.e., non-default strategy investment options) 18. The range and risk profile of other investment options are documented, approved and regularly reviewed for suitability. This review is documented. 19. The performance of other investments options is regularly reviewed against relevant investment objectives and (where available) industry benchmarks. This review is documented and approved. Identification of investment objectives and assessment against them

20. A complete and accurate description of all investment options is maintained and approved. 21. A Statement of Investment Principles (SIP) is documented, approved and regularly reviewed. PEOPLE

Conflicts of interest

22. Conflicts of interest are identified, recorded and managed in accordance with a defined policy which is regularly reviewed and approved. Fit and proper trustees

23. Fitness and propriety requirements are recorded and managed in accordance with a defined policy which is regularly reviewed and approved. 24. The fitness and propriety of trustees is regularly reviewed and monitored prior to appointment and thereafter. This review is documented and approved. 25. Trustee skills and knowledge are managed and maintained in accordance with an approved training programme. The training programme is regularly reviewed and updated. GOVERNANCE

Resource planning

26. A plan is maintained and regularly reviewed to ensure that resources are properly allocated.

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Scheme management 27. Roles, responsibilities and duties of all trustees, advisers and service providers are documented, approved and regularly reviewed. 28. Activities undertaken by all scheme advisers and service providers are properly managed and subject to regular performance reviews which are documented and approved. Internal control framework

29. A risk management framework is established to identify, manage and monitor significant operational, financial, regulatory and compliance risks. Core scheme transactions

30. Contributions benefit payments, investment transactions and calculations and related income and expenditure are completely and accurately processed in a timely manner and recorded in the proper period. 31. Contributions are invested in accordance with member instructions or the default policy. 32. Transaction errors are rectified and members are treated fairly as a result of that rectification. Receipt of contributions 33. Late and inaccurate contributions are pursued and resolved.

Retirement process

34. Retirements are managed in accordance with a documented process which is regularly reviewed and approved. 35. Retirement products selected by members are monitored and the range of retirement products made available is reviewed regularly for ongoing suitability. 36. Members are regularly made aware of their investment choices, the importance of reviewing the suitability of their investment choices and that their level of contributions is a key factor in determining the overall size of their pension fund. Communications

37. Scheme communications are accurate, clear and understandable and are produced in accordance with a documented communications plan. The plan is regularly reviewed and monitored. 38. Communications contain information to support the decisions members need to make at retirement.

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5. Control Objectives and Control Procedures This report is an Extract Report of the Master Trust Controls Report for Welplan Pensions (the Scheme). It highlights (at Section 3) the control environment and internal controls for master trust services, and related information technology controls, operating as at 31 August 2015, and reported in our AAF 02/07 Master Trust Controls Report signed 4 November 2015. The Scheme’s Master Trust Controls Report, which contains full details of the Scheme’s control objectives and procedures, will be provided to The Pensions Regulator. Members and participating employers will have details of the Scheme’s controls made available to them.

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Disclaimer Important Notice To be Read in Conjunction with Confidential AAF 02/07 2015 Report on Internal Controls of Welplan Pensions A report on the internal controls for Welplan Pensions (the Scheme) as at 31 August 2015 (“2015 Control Report”) has been prepared by the Trustee Board of the Scheme principally for the purposes of providing information to organisations who were customers at 31 August 2015. The 2015 Control Report is appended to an assurance report on internal controls (the Assurance Report) which was prepared by Assure (UK) Limited (the Reporting Accountants) solely for the Trustee Board of the Scheme (the Trustee Board). Following a request by the Trustee Board, the 2015 Control Report is available for viewing by prospective customers or other third parties subject to the following terms.

The Assurance Report was addressed to the Trustee Board of the Scheme and was prepared in accordance with terms of business set out in Assure (UK) Limited’s engagement letter dated 8 October 2015.

The Assurance Report was not prepared for the benefit of any prospective customers or other third parties and therefore items of possible interest to prospective customers or third parties may not have been specifically addressed.

To the fullest extent permissible by law, Assure (UK) Limited makes no warranty or representation that the information in the Assurance Report is appropriate for the interests or purposes of prospective customers, or as to the truth and accuracy of the contents, including without limitation, as to whether the information has changed in any way since the date of the Assurance Report.

Therefore the Assurance Report cannot in any way serve as a substitute for enquiries and procedures that prospective customers would (or should) undertake for the purpose of satisfying themselves regarding any matters relating to the Scheme’s administration procedures or for any matter arising in the Assurance Report.

Assure (UK) Limited, its directors, employees and agents neither owe nor accept any duty or responsibility to prospective customers or third parties whether in contract or in tort (including, without limitation, negligence and breach of statutory duty) or however so arising. Assure (UK) Limited shall not be liable, and prospective customers and third parties shall not bring any action, proceeding or claim in respect of any loss damage or expense of whatsoever nature which results from any use prospective customers or third parties choose to make of the Assurance Report, or any reliance they may seek to place on it.

The 2015 Control Report and the Assurance Report contained within it are not to be copied in whole or in part in any document and may not be distributed without our prior written permission.

To ensure that prospective customers have a clear understanding of the terms under which the Assurance Report is being provided to them, a copy of this Disclaimer should accompany the Assurance Report.

By accessing this document you agree to accept these terms.