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Pension scheme de-risking: a legal perspective February 2017

Contents Welcome to our annual review of the pension scheme de-risking market, with a legal twist. In this edition, we look back at the key market developments and legal issues affecting trustees, sponsors and insurers in 2016, sharing our experience, opinions and expectations for the year ahead. 1

Market review

3

The GKN de-risking journey

4

The Insurance Act 2015 and bulk annuity deals

6

GMP equalisation – a safe harbour at last?

8

The one that got away...

9

Small scheme longevity solutions

11 How we can help you 12 Key contacts We hope this gives you some insight into the legal aspects of a market which is developing rapidly and is of huge importance to pension schemes and insurance companies. If you’d like to know how Pinsent Masons’ specialist de-risking team can help you to achieve your goals in this market, take a look at page 15 and get in touch with the team listed on page 16. During 2016 Pinsent Masons advised trustees,

employers and insurers

on 21 successful de-risking transactions worth over £1.4bn.

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Pinsent Masons | Pension scheme de-risking: a legal perspective

Market review by Rob Tellwright It’s fair to say that 2016 was a year full of surprises. Leicester winning the league. Brexit, Trump, incredible success at the Olympics. We even had a sensible proposal from the DWP on GMP equalisation (as surprises go, they don’t come much bigger than that). So in a year when seemingly anything could happen, what did happen in the pensions de-risking market? A slow start? Well, 2016 was a rather intriguing year, for various reasons. Pension schemes were largely in watching and waiting mode at the start of the year. This was to be expected – the inevitable lull following a flurry of activity towards the end of 2015, when schemes rushed to take advantage of competitive pricing before the disruption brought about by the new Solvency II capital regime. Yet there was still plenty of activity in the wider annuity market – with Rothesay Life and Legal & General acquiring £6bn and £3bn (respectively) of Aegon’s legacy annuity portfolio. So depending on your perspective, it was either a slow start or a bumper first quarter.

“Solvency II has affected the pricing of deals, their structure and their legal terms”

The impact of the new prudential regime was being felt – particularly on the pricing for deferred liabilities. Solvency II has affected the pricing of deals, their structure and their legal terms. Features such as deferred premium structures, future tranches, surrender values and benefit options now have to be carefully considered for compliance with the new regime. Insurers and trustees were also coming to terms with their new legal duties under the Insurance Act 2015, which came into force earlier last year – Matthew de Ferrars looks at this in more detail on page 6. There were some more signs of momentum moving into Q2. Between March and July the ICI Pension Fund – in what is now a timehonoured tradition – was doing its part to keep the market ticking over, as it secured three tranches of liabilities (worth around £1.7bn) with L&G and Scottish Widows. These kind of “phased” transactions are becoming increasingly popular. Brexit Then, of course, along came the Brexit vote – further depressing gilt yields (not to mention 48% of the population). Schemes which had hedged most of their interest rate exposure were left sitting pretty, in relative terms, at least. One or two were even able to take advantage of widening credit spreads in the immediate aftermath of the referendum, transacting quickly to secure a cost saving. For those schemes which were less well-hedged, decent investment returns may have limited some of the damage, but in the round market conditions were not particularly conducive to de-risking. That said, for schemes with a foreign parent, the fall in the value of sterling played a part in keeping buy-ins and buy-outs on the table.

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Keen pricing The ICI Fund continued its de-risking activity with two further deals in September. Scottish Widows pocketed over £1bn in premiums for the two deals it insured, a statement of its intent to gain market share after entering the market in 2015. Last year’s other new entrant, Canada Life, was less conspicuous, although it did complete a £35m buy-in. 2016 seems to have been a relatively quiet year for Aviva, and also for Rothesay Life once it had acquired the majority of the Aegon back-book. Pension Insurance Corporation saw steadier deal volumes, with Just Retirement Partnership seeing an upturn in the second half of the year. During Q4, we saw some particularly keen pricing from certain insurers, including innovative proposals to help trustees who were eager to secure liabilities, but concerned about residual risk issues. For some trustees these issues ultimately discouraged them from transacting – Stephen Scholefield discusses “the ones that got away” on page 12. Other schemes had more success – most notably Rolls Royce’s Vickers Group Pension Scheme, which completed a £1.1bn buy-out with L&G in November. Looking ahead So all in all, the 2016 buy-in and buy-out market was a rather mixed bag, for insurers and pension schemes alike. Pension scheme deal volumes look set to fall some way short of the £10bn level which has been widely proclaimed as the “new norm”. The longevity swap market has also been subdued, albeit with some behind the scenes activity as insurers passed longevity risk to reinsurers, to free up capital under Solvency II. We’ve also had first-hand experience of an innovative solution designed to make this market accessible for a wider range of pension schemes (see page 13). So how is the market likely to shape up in 2017? The consultancies are certainly upbeat about deal volumes picking up again – predicting that a combination of additional capital and diversified investment strategies will help insurers to increase capacity and maintain competitive pricing. It remains to be seen whether pension schemes will reap the benefits of this, or whether legacy annuity deals will soak up the spare capacity (there have been rumblings that Prudential may be considering an amicable separation from its £45bn annuity back book, for example). That’s the supply side – so what about demand? I think most people in the industry expect there will be a continuing and growing demand from trustees and employers for de-risking solutions. Might this begin to slip down the list of priorities – particularly for employers – as their attention increasingly turns towards the impact of Brexit? This seems unlikely, given the threat DB pension risks pose to the health of many corporate groups, but it is a possibility nevertheless. From a legal and regulatory perspective, we expect a more stable environment in 2017, which should (in theory) be conducive to more deals being done. As ever, though, the stability or otherwise of wider economic conditions will be key. So if 2017 is a year of no surprises, this may not be a bad thing for the de-risking market. I expect that Trump, May, and possibly even Mr Ranieri, will have other ideas though...

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Pinsent Masons | Pension scheme de-risking: a legal perspective

The GKN de-risking journey by Howard Ridley You may have picked up in the pension press recently that Pinsent Masons have hit the ground running in 2017 as legal advisers to the GKN Group Pension Scheme on its recent £190 million buy-in deal with the Pension Insurance Corporation (PIC). In fact nearly all of the heavy lifting on this deal was done towards the end of 2016 and it marks just one step amongst many which have been taken by the trustee in order to de-risk this scheme. It is our privilege to work closely with the trustee and its other advisers to help implement each of these steps and identify innovative ways of doing so. The trustee has a long-term strategy to reduce risk as and when suitable opportunities arise, in order to protect the benefits of the scheme’s members. This is to the advantage of the members and also the scheme’s corporate sponsor, GKN, globally recognised as a leading technology business in the aerospace and automotive sectors which is listed on the FTSE 100 and has over 56,000 employees. The scheme has de-risked in various ways but it is the series of phased buy-ins which I want to focus on here. The scheme initially covered around 28,000 pensioner members and some deferred members following the restructuring of GKN’s pension arrangements in September 2012. The objective since then has been to secure pensioner liabilities in stages as and when favourable pricing opportunities have arisen. The first stage took place in March 2014 when the scheme secured £123 million of its pensions in payment by means of a bulk purchase annuity with Rothesay Life. This was the first buy-in deal agreed by Rothesay Life after it acquired MetLife’s £3 billion UK bulk annuity portfolio and it also just followed the acquisition by Blackstone, GIC and MassMutual of a majority stake in Rothesay Life. The next stage was a second bulk purchase annuity with Rothesay Life to secure a further £55 million of pensions in payment. The most recent stage was the recent deal with PIC to insure a further £190 million of pensions in payment. The background to this deal is that the trustee is aiming to wind up the scheme in 2017. These benefits have therefore been secured with PIC with a view to moving to ‘buy out’ shortly i.e. so that PIC issue individual annuity policies to these pensioners and the trustee is released from its obligation to pay the pensions. 3

The Insurance Act 2015 and bulk annuity deals by Matthew de Ferrars The 2015 Insurance Act (2015 Act) introduced from last August what the UK government has described as “the biggest reform to insurance contract law in more than a century”. Bulk annuity contracts have not been immune to its impact, with its treatment being a key area for legal negotiation in a number of our bulk annuity deals over the last two quarters of 2016. So, what has changed? New disclosure duties in non-consumer insurance contracts Previously, insured parties were required to disclose every circumstance that they knew, or ought to have known, which would influence an insurer in fixing a premium or deciding whether to underwrite a risk. This required insured parties to predict, without much guidance, what factors a hypothetical prudent insurer would be influenced by. The same obligation extended to brokers acting on behalf of insured parties. Part 2 of the 2015 Act has created a new ‘duty of fair presentation’ aimed at encouraging active, rather than passive, engagement by insurers as well as clarifying and specifying known or presumed to be known matters. Now, before entering into a contract of insurance, insured parties will be required to disclose either: • every matter which they know, or ought to know, that would influence the judgement of an insurer in deciding whether to insure the risk and on what terms (very similar to the current position); or • sufficient information to put an insurer on notice that it needs to make further enquiries about potentially material circumstances. Insured parties will be considered to have known, or ought to have known: • matters that could be expected to be revealed by a reasonable search of information available to the insured party – for example, information held within an organisation or by a broker; • anything known by a person responsible for their insurance – for example, a broker. Insurers will be considered to have known, or ought to have known: • matters known to individuals who participate on behalf of the insurer in deciding whether to take the risk and on what terms – for example, underwriting teams; • knowledge held by the insurer and readily available to the person deciding whether to take the risk; • matters known by an employee or agent of the insurer and which should reasonably have been passed on to the person deciding whether to take the risk. Remedies for breach of duty of pre-contractual disclosure Previously, an insurer was able to refuse all claims under an insurance contract if the pre-contractual disclosure duty was breached, even if the breach was committed by the broker. The 2015 Act has now introduced a range of proportionate remedies, applicable depending on the scale of the breach and the state of mind of the insurer. These are: • deliberate or reckless breach: the insurer will be able to avoid the contract and keep any premiums; • breach is neither deliberate nor reckless and the insurer would not have entered into the contract: the insurer will be able to avoid the contract but must return any premiums; • breach is neither deliberate nor reckless and the insurer would have entered into the contract on different terms, other than terms relating to premium: the insurer will be able to treat the contract as if those different terms apply – for example, any additional exclusions that would have been imposed; • breach is neither deliberate nor reckless and the insurer would have entered into the contract for a higher premium: the insurer will be able to reduce the cover to which the insured is entitled on a proportionate basis.

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Pinsent Masons | Pension scheme de-risking: a legal perspective

Duty of utmost good faith: consumer and non-consumer contracts Previously, either party could avoid the insurance contract if the other failed to act in accordance with ‘utmost good faith’. Significantly, Part 5 of the 2015 Act has now removed avoidance of contract as a remedy for breach of this duty, and abolished any parts of legislation prescribing this as a remedy. Insurance contracts will still be based on utmost good faith, and clauses and obligations will be interpreted in a way that favours compliance with this duty.

“Both trustees and insurers are still seeking variations to the position under the 2015 Act”

Applying the 2015 Act to bulk annuity contracts Before the 2015 Act it was commonplace for bulk annuity contracts to vary the basic position under insurance law. Trustees were understandably very nervous about unintentionally breaching the duty of utmost good faith and as a consequence being exposed to the insurer’s remedy to avoid the contract (without any return of premium). Whilst the removal of this remedy for a breach of utmost good faith will be of some comfort to trustees, both trustees and insurers are still seeking variations to the position under the 2015 Act. From our experience of recent deals, there have been two main areas of focus: clarifying what is expected of trustees if they are to make their disclosures in accordance with the duty of fair presentation and what remedies should apply where there has been a breach of that duty. Clarifying what a fair presentation requires of trustees A bulk annuity contract is likely to give the insurer certain remedies where the trustees have breached their duty of fair presentation. Therefore trustees will as far as possible seek to pin down what fair presentation requires of them. This may involve limiting it to the matters required to be disclosed by the 2015 Act, making clear the manner of disclosure and the degree to which the matters disclosed must be correct (e.g. material facts must be substantially correct or statements of belief or expectation must be made in good faith). Adapting the 2015 Act remedies In determining the remedies that should apply for a breach of the duty of fair presentation (or a warranty) the starting point should be the nature of the breach. Was it fraudulent, deliberate, reckless or negligent/innocent? But for the breach would the insurer not have entered into the contract on any terms or would it have entered into it on different terms? The bulk annuity contract will then need to state which remedies should apply to these different categories of breach. So, for example, it may still be acceptable to trustees for the insurer to have the remedy under the 2015 Act of avoiding the contract in the case of their deliberate or reckless breach. However, there may then need to be a discussion about whether there should be provision for a cancellation payment in these situations. In the case of innocent breaches of the duty of fair presentation (i.e. breaches which are neither deliberate or reckless) which did not lead to the insurer entering into the contract, it will be necessary to adapt the remedies under the 2015 Act. This is because it is hard to make those remedies work in a bulk annuity context. For example, it is hard to see how this situation could be addressed by the subsequent inclusion of an additional term or exclusion in the contract, as provided in the 2015 Act. One way of addressing this is to include specific remedies in the contract, such as charging an additional premium, reducing the benefits covered by the policy or making a link to the remedies available under the material change clauses. Contracting out of the Insurance Act: consumer and non-consumer contracts Finally, it is important to note that the 2015 Act prevents an insurer from contracting out of its provisions with the effect of placing an insured party in a worse position than they would have been in under the provisions of the Act. Parties to non-consumer insurance contracts can agree less favourable terms than those in the Act, provided that the alternative provisions are clear and unambiguous and sufficient steps are taken to draw them to the attention of the insured party or its agent before the contract is concluded. To the extent that the remedies are varied it will therefore also be necessary to include specific provisions in the contract addressing these requirements.

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GMP equalisation – a safe harbour at last? by Chris Burke The DWP is consulting on a new method it has proposed for equalising GMPs. The method has the potential to offer trustees a safe harbour for equalising GMPs, and there are a number of implications for schemes considering insuring benefits. What is the background? The European Court of Justice ruled that pension benefits must be equal for men and women in respect of service from 17 May 1990. Although there are arguments to the contrary, the general view is that EU law requires any inequality in a scheme’s rules resulting from UK GMP legislation and unequal GMP pension ages (60 for women, 65 for men) to be removed. The government agrees. It believes there is a requirement to equalise even where there is no comparable person of the opposite sex to prove the inequality, although UK legislation currently requires a comparator. In January 2012, the DWP proposed an equalisation method which involved annual benefit adjustments for each member. The pensions industry widely criticised the potential administrative complexity and costs associated with it. The method was withdrawn, and there remained uncertainty regarding how schemes should equalise GMPs. There is also now uncertainty about whether Brexit might remove the need to equalise GMPs altogether. For these reasons, many trustees have postponed deciding whether and how to equalise GMPs if they can. Trustees needing to insure benefits may not have had this luxury. Schemes can be challenged for delaying GMP equalisation. Lloyds Trade Union, for example, has announced plans to test in an Employment Tribunal whether GMPs in the Lloyds Banking Group pension schemes should already have been equalised. What is the DWP’s new method? The DWP’s new method involves a one-off actuarial comparison of (a) the value of benefits accrued in the period that needs to be adjusted for GMP inequalities (17 May 1990 to 5 April 1997) based on the member’s actual sex, and (b) the value the benefits would have if the member had been of the opposite sex. The member is treated as entitled to the higher of these two values. To avoid the unequal requirements hardwired into GMP legislation, the GMP is converted into an ordinary scheme benefit. 9887

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Has the DWP clarified whether Brexit might impact the requirement to equalise GMPs? No. The consultation paper doesn’t mention whether the government might amend UK equality legislation after Brexit to remove any requirement to equalise GMPs. When might the new method be finalised and conversion legislation amended? The consultation ends on 15 January 2017. The DWP aims to publish a response by 9 April 2017. It will then decide whether to go ahead with the method. If it decides to go ahead, the method would be adopted and GMP conversion legislation amended. The DWP intends to issue guidance to clarify some of the details of the GMP conversion process once the legislation has been amended. It’s unlikely the new method and revised conversion legislation will be ready before spring 2018. If the new method is adopted, could trustees continue to postpone GMP equalisation? It would become harder for them to. One of the main justifications for postponing GMP equalisation – the lack of a legally certain method – would most likely have been removed. A government approved method, devised by a group of experts and refined as necessary following consultation, would appear to be a safe harbour for trustees to use. Some trustees might want to delay further in the hope that Brexit will remove the requirement to equalise GMPs altogether. This might be hard to justify, especially if members/trade unions are pressing for action (as the Lloyds Trade Union is). What are the implications for bulk annuity policies? The implications for schemes that are considering, or have already entered into, bulk annuity policies may include the following: • Given the safe harbour and other practical advantages the new method and conversion legislation are likely to offer, trustees who want to equalise GMPs and achieve certainty on a buy-out may wait until the new method is available before insuring (if they can). Buy-out timetables may be adjusted accordingly. • Other trustees may not be able to wait and see if the new method is approved (for example, if they need to wind up their scheme). Trustees in this position are still able to insure benefits on the basis of a GMP equalisation method they believe to be appropriate. The DWP has made clear its latest proposed method is one method it considers appropriate. It will not be the only appropriate method. • Similarly, if trustees are satisfied they have already taken appropriate steps to equalise GMPs and insured benefits accordingly, they are not required to take any further action. The new method should not result in these trustees seeking to revise the terms of existing buy-out policy documentation or adjust benefits. However, schemes which have only transacted a buy-in will need to decide whether they should progress to buy-out on the basis of their existing GMP equalisation method (if they have one), or whether the method should be revisited. • Trustees who use the DWP’s proposed method (if it’s adopted) are less likely to insure against the risk of their equalisation method later being found to be legally invalid (as some trustees who have used their own method currently do). GMP equalisation may therefore become a less contentious issue on residual risk transactions. • The prospect of converting GMPs into ordinary scheme benefits may assist schemes in obtaining more competitive pricing. This is because the benefit structure (particularly around pension increases and revaluation) can be simplified and insurers may find it easier/ more efficient to hedge their exposure to inflation-linked benefits.

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The one that got away... by Stephen Scholefield Depending on your age and inclination, The One That Got Away may be a song by Katy Perry or the story of Franz von Werra, a Luftwaffe pilot shot down over Britain in 1940 who managed to escape back to Berlin. But for those who prefer less derring-do, it’s also the story of schemes which start the buy-out process, but don’t quite make it to the safety of an insurer. Sadly, there is more than one of those. Sometimes this is due to the pricing uncertainty, caused by the risk of scheme benefits turning out to be more than has been paid in practice. Inevitably, the buy-out process requires some due diligence on the scheme’s benefit structure, to ensure that the right benefits are insured and the trustees properly discharged. Given the complexity of many schemes, and the fact that trustees were not always as well advised as they are now, this can uncover all sorts of issues. Our top few from this year’s crop are: Routine calculation errors – for example setting up survivor’s benefits on the wrong basis, incorrectly applying pension increases, etc.

Equalisation problems –sometimes the problem is that the trustees don’t know how equalisation was addressed for a particular group of members, such as on a bulk transfer.

Ongoing salary linkage – some schemes ceased accrual but may not have validly severed the salary link.

Technical contracting-out glitches – for example, buying-out sometimes means that there is an element of ‘fessing up as to whether anti-franking legislation has really been complied with.

One could go on… But the message is clear, some trustees start the process before they are in an ideal shape to do so. They either take the risk of addressing anything that arises as part of the data cleanse (which could mean a higher premium and in some cases the risk of triggering material change provisions) or they pull out of the process if the uncertainty is beyond their tolerance. All of this is easily avoided by doing the work in advance and going to market having first established precisely what needs to be insured. Admittedly, this is not always seen as an attractive offer – it risks uncovering things that trustees would rather not have known about. But if trustees (and their advisers) aren’t sure about the benefits they are paying then they are storing up problems for later, and possibly running risks that they don’t know about. So summon up a bit of derring-do and give it a shot. Naturally, we’d be happy to help. Get in touch if you’d like to know more about our packaged advice for getting trustees ready to buy-out. PS von Werra was killed in a plane crash in 1941.

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Small scheme longevity solutions by Rob Tellwright War and Peace When we talk about innovation in the de-risking market, we tend to think of the biggest and most complex deals. The £X billion all-risks buy-out, building in liability management exercises, a bit of medical underwriting, surrender options, collateralised security structures, and a suite of policy terms that make War and Peace seem like a spot of light reading. But innovation comes in all shapes and sizes, as I found when advising the trustees of a small pension scheme on an innovative longevity swap solution earlier this year.

“Our “tiddler” showed that longevity swaps can be a viable solution for much smaller pension schemes.”

The deal was, by any measure, a tiddler. Brokered by Mercer, fronted by Zurich and with 75% of the longevity risk reinsured with Pacific Re, it covered around 90 named pensioners and future dependants. The total liability for the members covered was just over £50m, making it the smallest ever named-life longevity swap.

Yet this marked a significant step in the evolution of the longevity swap market, which has traditionally been regarded as the domain of the very largest and most sophisticated schemes. Our “tiddler” showed that longevity swaps can be a viable solution for much smaller pension schemes. This is of particular significance at a time when many small schemes have been struggling to find competitive pricing (or, at least, meaningful engagement) from insurers in the buy-in/buy-out market. Great Expectations So what should trustees of small schemes expect from a solution like this? Well, as you might suppose, the trustees’ bargaining position will be relatively modest. They are essentially offered a streamlined solution on a “take it or leave it basis” – there is no real scope to negotiate legal terms, and no great incentive for the insurer to refine its pricing once it falls within a reasonable range. This doesn’t necessarily present a problem, though. There are various ways of testing the “reasonableness” of the price offered, including considering what the trustees would need to pay to hedge the longevity risk in the bulk annuity market, and considering the implied cost of holding the risk in the scheme. On the legal side, the key commercial terms are pre-agreed with the fronting insurer, and presented to the trustees in a heads of terms. If the trustees are comfortable with this, their lawyers will need to review the full suite of legal terms. The terms are designed to include many checks and balances that one would expect to see in a typical (negotiated) longevity swap, although there are inevitably some areas where the balance is tipped in the insurer’s favour. At this point the solution becomes slightly less “streamlined” though – a longevity swap is, by its very nature, a complex financial instrument, resulting in just short of 100 pages of legal terms to digest. This is a key point for trustees to be aware of – they should not mistake the “accessibility” offered by this solution for “simplicity”. It may therefore be appropriate for some trustee training to help the trustees understand the key features of the swap, and understand the key risks flagged by the lawyers in their legal review.

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Paradise Lost One area where the small scheme solution differs from larger longevity swaps is counterparty exposure. Under larger longevity swaps, the party which is “out of the money” is required to post collateral in favour of the other (as well as collateral posted by the trustees in respect of the insurer’s risk premium). This means that if the former party defaults, the latter can step in and take control of the collateral, therefore minimising its counterparty risk. This is simply not viable for small scheme solutions, where the costs of operating a collateral structure are likely to outweigh the benefits. So it falls to the trustees and the insurer to be comfortable with the other’s covenant. For the trustees, this may involve taking some advice on the financial position of the insurer, although the primary focus should be to understand the level of protection afforded by the insurance regulatory regime. The trustees should also appreciate that the longevity swap policy is an illiquid investment, although it does include a framework for the policy to be novated to another insurer if the trustees wish to buy-in or buy-out benefits with such an insurer in the future. Things are a little different for the insurer – it will want a comprehensive understanding of the scheme’s funding position, a termination right if the funding level deteriorates significantly, and a very clear right of recourse to the scheme’s assets in respect of any amounts owed to it. If there is any ambiguity over the insurer’s right of recourse, the insurer may well insist that the scheme’s trust deed is amended to cater for this. So even with a streamlined solution in place, there will be a number of issues for trustees to get comfortable with before executing a longevity swap. But the very fact that this may now be a viable option for some small schemes is a welcome sign of progress in the market.

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Pinsent Masons | Pension scheme de-risking: a legal perspective

How we can help you A specialist team dedicated to advising providers on a full range of pension issues and products – after all, there’s more to life than bulk annuities!

Market-leading team of specialist BPA lawyers, with significant experience of BPA transactions of all shapes and sizes.

How we can help insurers

Developing new products and driving innovation – including medical underwriting, allrisks propositions, defereed premiums, PPF+ buy-outs, surrender and security mechanisms.

Working closely with your deal team, legal, actuarial and pricing functions to steer transactions to a successful conclusion, while ensuring that any legal risks are clearly defined and understood.

Expert support and resourcing for your in-house team, from lawyers who fully understand the issues facing the pension scheme trustees.

Post-transaction support – including dealing with queries from annuitants and dispute resolution.

Refining standard terms and helping you to develop a legal proposition which continues to be competitive in an eveolvong market.

Pinsents supported us on a recent transaction that involved possible all risk transfer, where it was vital we had a team we could trust with the experience required for these types of transactions. We found their team to be professional, well-informed, clear and precise and their support enabled us to understand the possible risks and areas of concern and address them accordingly to successfully conclude the deal. We look forward to working with them on more transactions... Just Retirement 11

Key contacts Matthew de Ferrars Partner Pensions T: +44 (0)20 7667 0189 E: [email protected]

Howard Ridley Partner Pensions T: +44 (0)161 250 0112 E: [email protected]

Stephen Scholefield Partner Pensions T: +44 (0)161 250 0147 E: [email protected]

Mark Baker Legal Director Pensions T: +44 (0)20 7667 0195 E: [email protected]

Robert Tellwright Senior Associate Pensions T: +44 (0)161 250 0200 E: [email protected]

Chris Burke Senior Associate Pensions T: +44 (0)20 7490 6428 E: [email protected]

Pinsent Masons recently advised us on bulk annuity investments which represent an important step in the de-risking journey for two of our schemes. The Pinsents team demonstrated their significant expertise in this area, and they used this expertise to ensure that the key legal issues for the schemes were fully addressed, and that any other legal risks were clearly explained and understood. They worked very closely with our actuarial/investment consultants to secure deals which the trustees could have full confidence in. Their pragmatic approach meant that we were able to transact quickly and efficiently, getting the “right” terms at the best available price. Group Pensions Manager, Renold PLC

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Pinsent Masons LLP is a limited liability partnership, registered in England and Wales (registered number: OC333653) authorised and regulated by the Solicitors Regulation Authority and the appropriate jurisdictions in which it operates. The word “partner”, used in relation to the LLP, refers to a member or an employee or consultant of the LLP, or any firm or equivalent standing. A list of the members of the LLP, and of those non-members who are designated as partners, is available for inspection at our registered office: 30 Crown Place, London, EC2A 4ES, United Kingdom. © Pinsent Masons 2017. 9887

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