Pension Fund Independent Performance Measurement

Staffordshire Pension Fund invests into various asset classes in line with its Strategic Asset Allocation. The total market value of assets of the Pension Fund at 30 September 2025 was £8.28bn. Performance measurement plays a major role in ensuring that the

Pension Fund is governed properly and is meeting expectations in terms of the returns it generates for the level of risk being taken. Governance is strengthened with an independent check on the returns generated and reported by investment managers. Use

of an independent performance manager ensures that the Pension Fund meets its regulatory obligations.

At present there are two large pieces of legislation which will affect the Staffordshire Pension Fund from 1 April 2026:

• 'Fit for the Future'
• Local Government Reorganisation.

On 14 November 2024, the Pensions Investment Review - Interim Report was announced by the Chancellor in her Mansion House speech (Pensions_Investment_Review_interim_report.pdf). For the LGPS, this principally involved the intention to direct all assets to be under asset pool management (including legacy private market assets) by 31 March 2026; to ensure all pools are established FCA regulated entities); for pools to equip themselves to be able to provide strategic asset allocation advice to their partner funds as well as making the implementation decisions;

and for the administering authority to set out the Fund's ambition for local investments. At the same time the Chancellor also announced a further consultation (Local Government Pension Scheme (England and Wales): Fit for the future - GOV.UK).

On 29 May 2025, the government published their final report on the Pensions Review along with the relevant consultation responses. No changes were made to the original major proposals for the LGPS, and the government outlined its intention to legislate to implement the reforms as part of the upcoming Pension Review Bill. The reforms represent a huge change to the way Staffordshire Pension Fund operates, and the Fund will need to work with LGPS Central and Advisers, where necessary, to implement the reforms in short timescales.

There was also acknowledgement that fiduciary oversight services could be used to help funds to oversee their pools, but that this should be procured as collective groups of funds, in conjunction with their pool. Staffordshire Pension Fund is of the opinion that

performance management and monitoring is a key element of its fiduciary duty.

The upshot of the legislation proposed to be in place from 31 March 2026 is that Staffordshire Pension Fund is unsure how long it will need an external performance measurement contract for as this may be provided in some form by LGPS Central. Officers do not expect this to be in place or the procurement planning to be in progress by April 2026 which creates significant uncertainty around the current provision.

A request to keep the same provider would:

• Ensure consistent performance reporting during a period of significant change, without the additional need for resources and duel running
• Allow resources to be allocated to implement the changes required by the Fit for the Future regulations and not diverted to procure a service that may be provided by LGPS Central Ltd (with no need for procurement) in the coming couple of years.
• Ensure Northern Trust continues to provide an independent pricing policy with valuations that match to Staffordshire Pension Fund management reporting.
• Ensure consistent calculation methodology enabling comparison of the performance of assets, managers and mandates on a like for like basis meeting the Fund's fiduciary

duties.

• Provide continuity of service with performance consultants that are part of the relationship management team, who already work closely with key service personnel, and will have a clear overview of the transfer of pooled assets
• Allow access to presentation resources should experts be required to attend meetings and/or provide training.
• Permit NT to day weight contributions and withdrawals in order to arrive at a time weighted return whereas any other provider will need to import data from Northern Trust to provide performance reporting and will likely have to use a weighted average at some

point in the calculation. More accurate output will be received from NT with rates of return that can be tied back to the valuation audit, with the valuation audit and the performance audit having been carried out by NT partners that work closely with each other.

To achieve all of the above with another provider would take a considerable resource and time and investment of Pension Fund officers in the short term for a service that may not be required longer term if it is to be provided by the Pool.

The impact of Local Government Reorganisation on the Pension Fund, which is not yet fully understood, also needs to be considered.