Getting ready for the Code - Where to start

17 Dec 2021

Welcome to the Muse series Getting ready for the Code, where we are sharing practical tips and tools. This follows round tables in the Autumn with trustees and pension leads from a wide variety of schemes.

The first article in the series is a practical look at gap analysis, to help assess how ready you are for the Code and ORA. After initial Trustee training, this is where many are starting their Code and ORA work.

Why start now?

Few schemes have undertaken much work in preparation yet beyond training and the start of a gap analysis, due to a lack of guidance from TPR on their requirements and taking a proportionate approach.

TPR is encouraging schemes to start with gap analysis. At a recent Q&A session TPR’s David Fairs said “Trustees should think about the draft Code and … put in place a workplan to address it and transition to this over time. New things are not new; in most cases trustees should have been doing them already.”

For many, it will often be a case of rebadging what you are already doing, with fewer notable gaps to fill.

A practical gap analysis tool to use

We’ve put together a practical template based on gap analysis work we’re doing. It includes all key documents and policies Trustees i) should have in place ii) the Code requires, iii) are relevant to the ORA.

It’s set up to help you assess what you already have in place, capture each document’s location and determine actions you might need to take (and when) to fill in any gaps. It can also drive your reporting and assurance the trustee board needs on Code and ORA readiness and identify agreed priority actions.

If you’d like an excel version to work with, please email us at [email protected]

The governance benefits

It’s a good exercise to undertake. Whilst there is an element of compliance, it’s mainly about ensuring good governance: knowing policies are underpinned by processes that work to demonstrate in the ORA.

A reasonable, pragmatic approach to the ORA is to start with what you have, look to rebadge where it makes sense and prioritise work (and any support) on the most important gaps for your own scheme.

Staying in touch

If you’d like to touch base on this, or the Code and any issues you are thinking through, please let us know. We’d also love to hear your views on articles in the series and any areas you’d like us to cover in future editions. Please just email us at [email protected]

We’ll be organising virtual round tables again in 2022 to continue sharing ideas and experience. If you’d like to be included but haven’t attended any of them before, please let us know and we can add you.

Rosanne, Jo, Julia, Damon, Claire and Barry