1. Introduction

This edition of the Statement has been prepared by the Trustees of the Blenheim Estate Pension Scheme in accordance with the requirements of Section 35 of the Pensions Act 1995 (as amended), and Regulation 2 of the Occupational Pension Schemes (Investment) Regulations 2005, and any subsequent additional regulations. 

In preparing this edition the Trustees have taken appropriate written advice from a suitably qualified individual, Simon Jagger FIA, Director of Jagger & Associates Limited. The Trustees have also consulted with the sponsoring employer. This Statement supersedes previous editions, and is consistent with the Scheme’s governing documents.

The Scheme provides defined benefits and is exempt approved although accrual and salary linking ceased with effect from 1 January 2002. There is no formal employer-related investment made by the Trustees, and none is intended. The employer intends to remit all relevant contributions to the Trustees within the relevant timescales. The Scheme is registered with HM Revenue and Customs.

 

2. Delegation of Investment Management

The Trustees use a range of pooled funds provided by Legal & General Investment Management (L&G). The Trustees also use cash products, including the Trustees’ bank account, for managing short-term cash flows.

The details of the investment manager’s appointment, covering the roles of the organisation and its various subsidiaries and associated companies, are covered in an agreement with an effective date of 4 June 2004, and in any legally valid amendments thereof. The provider, where relevant, is suitably authorised under the Financial Services and Markets Act 2000.

The Trustees consider these investment products to be appropriate investments for the Scheme. In deciding to invest in these funds, the Trustees sought advice from their professional advisers as to the products’ suitability. The Trustees will review their decision from time to time with their advisers.

 

3. The Investments Held

Full details of the investment restrictions placed on the manager are contained within the investment agreement mentioned above.

The assets of the Scheme are now held in a range of pooled funds provided by L&G, including two Corporate Bond funds, an Index-Linked Gilt fund, a legacy Property Fund, and a Cash Fund.

The mix of assets is now designed to broadly match the buyout liability profile. If the liability profile is updated for membership movements, the Trustees may switch between different Corporate Bond funds, and between Corporate Bond and Gilt or Index-Linked Gilt funds, without revising the SIP. The Scheme does not currently invest in a Gilt Fund.

The Corporate Bond products invest primarily in sterling denominated corporate bonds with an appropriate term to maturity across a range of issuers. The funds may hold gilts to provide short-term liquidity when needed, but they only amount to a small proportion of the fund. Each fund aims to replicate the relevant iBoxx Sterling Non-Gilts Index.

The Gilt product, when held, is a passively managed fund that tracks the relevant FTSE-A Government Index on a total return basis. This may vary between All-Dated and Long-Dated without triggering a revision of the SIP. 

The Index-Linked Gilt product is currently an actively managed fund that aims to outperform the relevant FTSE-A Government Index on a total return basis. This fund may vary between active and passive, and by its maturity profile without triggering a revision of the SIP. 

The legacy Property holding has the discretion to invest in UK commercial property. The Trustees will realise this holding at the next available opportunity.

The Trustees have placed no additional constraints on the fund manager. The Trustees will keep the allocation of the Scheme’s assets between the funds under review.

 

4. Expected Return on Investments

It is the Trustees’ expectation that the Corporate Bond products funds will produce a return in line with the relevant iBoxx Sterling Non-Gilts Index to within +/- 0.5% p.a. for two years in three.

It is the Trustees’ expectation that the Gilt product, when held, would track the total return of the relevant FT-A Government Index to within +/- 0.25% p.a. for two years in three.

Tracking errors may be revised from time to time, but this statement will not be revised for this in isolation.

It is the Trustees’ expectation that the Index-Linked Gilt product, if index-tracking, would track the total return of the relevant FT-A Government Index to within +/- 0.25% p.a. for two years in three. If held in active format, the Trustees expect the product to outperform the total return of the relevant FT-A Government Index by 0.75% p.a. (gross of fees) on a rolling 3-year basis.

The investment performance of the Scheme is monitored on a quarterly basis through reports from L&G.

 

5. Risk

The Trustees are satisfied that their manager is prudent and professional in their general approach to investment. The products used involve holding units in pooled investment funds that maintain diversified portfolios of underlying assets (e.g. bonds, and units in other funds). This reduces the risk to the Scheme of investing in any specific individual asset. The use of passive funds for some asset classes reduces the risk involved with following a purely active investment strategy.

The products used are viewed as appropriate investment vehicles for the investment strategy of a pension scheme approaching buyout. Risk measurement forms part of the periodic performance monitoring.

 

6. Realisation of Investments

The Trustees' policy is to ensure that the assets invested are sufficiently realisable to enable the Trustees to meet their obligations to provide benefits as they fall due. The Trustees are satisfied that the arrangements in place conform to this policy. The Trustees monitor their net cashflow position, the likely need to realise capital, and hence any effect on asset allocation and the choice of investment funds.

 

7. Additional Voluntary Contributions

The Scheme has only deferred and pensioner members, so no further AVCs are being paid. The existing AVC assets are with Legal & General. The Trustees believe these to be appropriate facilities for this purpose, but note that the choice of funds used rest entirely with the members. 

 

8. Environmental, Social and Governance (ESG) Considerations including Voting and Engagement

In endeavouring to invest in the best financial interests of the beneficiaries, the Trustees have elected to invest in pooled funds and cannot therefore directly influence the environmental, social, and governance policies and practices of the companies in which the pooled funds invest. The Trustees exclude non-financial matters in the selection, retention and realisation of investments.

The Trustees have no formal policy on either ESG or delegation of voting rights.  Instead, they have delegated the responsibility for these matters to their investment manager, who will from time to time report on their current and future actions in these areas. 

The Trustees will consider a manager’s ESG credentials during their appointment process, and will ask for at least an annual written update on the manager’s activity for the products used by the Trustees. The Trustees will include a statement in the annual report to advise members that this has been done.

As the Trustees use pooled funds, their asset manager is not incentivised to align their investment strategy and decisions with the Trustees’ policies, nor are they incentivised to make decisions based on assessments about medium to long-term performance of an issuer of debt or equity, nor to engage with those issuers in order to improve their performance. However, the manager may make such decisions and/or engage of their own accord.

Performance monitoring, manager remuneration and duration of manager appointments are covered elsewhere in this Statement, or in the Trustees’ Annual Report. As the Trustees use pooled funds, there is no targeted portfolio turnover or turnover range.

As the Trustees use pooled funds, they do not need to have an engagement policy in relation to monitoring the capital structure of companies they invest in, or any associated potential conflicts of interest.

The Trustees publish their SIP online for general public access. In addition, the Trustees publish annually online an engagement policy implementation statement that outlines how the various requirements (set out above) have been followed during the year, and describes the voting behaviours of the asset manager on their behalf.

 

9. Compliance

The Trustees will formally review this statement as and when required, and at least every three years, with the assistance of their advisers. A copy of this statement is available for inspection by Scheme members.

This statement has been agreed by the Trustees on 27th March 2023.

Blenheim Estate Pension Scheme: Implementation Statement, covering 1 April 2023 to 31 March 2024

 

1. Introduction

This edition of the Statement has been prepared by the Trustees of the Blenheim Estate Pension Scheme in accordance with the requirements of Section 35 of the Pensions Act 1995 (as amended), and Regulation 2 of the Occupational Pension Schemes (Investment) Regulations 2005, and any subsequent additional regulations. 

In preparing this edition the Trustees have taken appropriate written advice from a suitably qualified individual, Simon Jagger FIA, Director of Jagger & Associates Limited.  The Trustees have also consulted with the sponsoring employer.  This Statement supersedes previous editions, and is consistent with the Scheme’s governing documents.

The Scheme provides defined benefits and is exempt approved although accrual and salary linking ceased with effect from 1 January 2002.  There is no formal employer-related investment made by the Trustees, and none is intended.  The employer intends to remit any relevant contributions to the Trustees within the relevant timescales.  The Scheme is registered with HM Revenue and Customs.

 

2. Delegation of Investment Management

The Trustees use an annuity portfolio provided by Legal & General Assurance Society Limited (LGAS).  The Trustees also use Legal & General Investment Management (L&G) equity and cash products and the Trustees’ bank account, for managing short-term cash flows.

The details of the investment managers’ appointments, covering the roles of the organisations and their various subsidiaries and associated companies, are covered in agreements with an effective date of 4 June 2004 (L&G), and 7 July 2025 (LGAS), and in any legally valid amendments thereof.  The providers, where relevant, are suitably authorised under the Financial Services and Markets Act 2000.

The Trustees consider these investment products to be appropriate investments for the Scheme.  In deciding to invest in these products, the Trustees sought advice from their professional advisers as to the products’ suitability.  The Trustees will review their decision from time to time with their advisers.

 

3. The Investments Held

 Full details of the investment restrictions placed on the managers are contained within the investment agreements mentioned above.  The assets of the Scheme are now held in an annuity portfolio provided by LGAS, an L&G All World Equity index fund and an L&G Cash Fund.  The Trustees have placed no additional constraints on the fund managers.  The Trustees will keep the allocation of the Scheme’s assets under review.

 

4. Expected Return on Investments

Given the use of an annuity portfolio and a Cash fund, this section is no longer applicable for these specific items.  However, for the All World Equity fund, equity products are designed to produce returns in excess of both general salary and price inflation over the long term.  The All World Equity fund is therefore expected to enhance the real value of the Scheme’s assets over the long term, which is a fundamental element of the Trustees’ investment policy.  The All World Equity fund may produce volatile absolute returns over short-term periods. 

The investment objective of the fund is to track the performance of the FTSE All-World Index (less withholding tax where applicable) to within +/- 0.5% per annum for two years out of three.

 

5. Risk

The Trustees are satisfied that their managers are prudent and professional in their general approach to investment.  The equity product used involves holding units in pooled investment funds that maintain diversified portfolios of underlying assets (e.g. shares, and units in other funds).  This reduces the risk to the Scheme of investing in any specific individual asset.  The use of a passive fund reduces the risk involved with following a purely active investment strategy.

 

6. Realisation of Investments

Given the use of a Cash fund, the Trustees are satisfied they can realise investments should the need arise.  They do not expect to need to realise the equity holding.

 

7. Additional Voluntary Contributions

The Scheme has only deferred and pensioner members, so no further AVCs are being paid.  The existing AVC assets are with Legal & General.  The Trustees believe these to be appropriate facilities for this purpose, but note that the choice of funds used rest entirely with the members. 

 

8. Environmental, Social and Governance (ESG) Considerations including Voting and Engagement

Given the use of an annuity portfolio and a Cash fund, this section is no longer applicable for these specific holdings, but it remains applicable for the Equity fund.

In endeavouring to invest in the best financial interests of the beneficiaries, the Trustees have elected to invest in pooled funds and cannot therefore directly influence the environmental, social, and governance policies and practices of the companies in which the pooled funds invest.  The Trustees exclude non-financial matters in the selection, retention and realisation of investments.

The Trustees have no formal policy on either ESG or delegation of voting rights.  Instead, they have delegated the responsibility for these matters to their investment manager, who will from time to time report on their current and future actions in these areas. 

The Trustees will consider a manager’s ESG credentials during their appointment process, and will ask for at least an annual written update on the manager’s activity for the products used by the Trustees.  The Trustees will include a statement in the annual report to advise members that this has been done.

As the Trustees use pooled funds, their asset manager is not incentivised to align their investment strategy and decisions with the Trustees’ policies, nor are they incentivised to make decisions based on assessments about medium to long-term performance of an issuer of equity, nor to engage with those issuers in order to improve their performance.  However, the manager may make such decisions and/or engage of their own accord.

Performance monitoring, manager remuneration and duration of manager appointments are covered elsewhere in this Statement, or in the Trustees’ Annual Report.  As the Trustees use pooled funds, there is no targeted portfolio turnover or turnover range.

As the Trustees use pooled funds, they do not need to have an engagement policy in relation to monitoring the capital structure of companies they invest in, or any associated potential conflicts of interest.

The Trustees publish their SIP online for general public access.  In addition, the Trustees publish annually online an engagement policy implementation statement that outlines how the various requirements (set out above) have been followed during the year, and describes the voting behaviours of the asset manager on their behalf.

 

9. Compliance

The Trustees will formally review this statement as and when required, and at least every three years, with the assistance of their advisers.  A copy of this statement is available for inspection by Scheme members.

 

This statement has been agreed by the Trustees on 21/10/2025

 

Blenheim Estate Pension Scheme: Implementation Statement, covering 1 April 2024 to 31 March 2025