Is your ESOG now in place?
As trustees with limited time and competing priorities, it could be easy to leave your Own Risk Assessment (ORA) until it falls due and then have to complete all the work at once. But doing so would create plenty to do and potentially leave problems that can’t be fixed in time for the first ORA. By setting up an ongoing Effective System of Governance (ESOG), you can make your eventual ORA work much less intimidating. Here’s how I do it in practice:
Have a plan
With all successful ideas, there is most likely a plan in place. Here is no different, but instead it’s called a ‘planner’ on this occasion…
Put in place an ESOG ‘planner’. This will ensure that you’ll be able to track completed and upcoming actions against the ESOG requirements. This includes tracking when policies should be reviewed, setting out when certain activities are required so that these can be checked.
Organising this planner effectively (as well as having the discipline to update it regularly) will make the requirements and their varying deadlines much easier to manage as trustees.
Check in regularly & evidence
Pension schemes, particularly those that hold regular meetings, should check in with their ESOG regularly, rather than treating it as something that can be set and checked at the point of an ORA, or even forgotten. Make checking your scheme’s ESOG planner a recognised part of your meeting agenda. Then, you can promptly review policies, take any required actions, making any necessary changes, or adapting to new regulation more manageable and reducing the need for large scale work or wholesale changes later on.
But it’s important that this good discipline is not lost and to also document any actions taken at a regular check-in, rather than simply updating the due-by-date on the planner. This can simply be a table setting out those specific actions taken.
This will help later when your scheme’s ORA is due. With minimal need to re-document all the actions taken since the previous ORA, which can simply point to all the documented evidence along the way. This avoids duplication of work, spreads the work needed to complete your ORA over a long period of time and mitigates the risks of leaving it too late…
Avoiding headaches
But why is it better to have a plan, check in with your ESOG regularly and document any actions you take? Let’s return to our original scenario where your scheme’s ORA is due and little preparatory work has been done. In the best case scenario, your trustee board has been doing the necessary ESOG work. However, without organised documentation you’ll now find this difficult to evidence for your ORA and will create the headache of having to go back through your work to demonstrate what was done and when. All of this could have been done at the same time policies were updated or actions were naturally taken, stopping the last minute rush.
Or worse, some items were missed and there is not enough time to correct those. In this case your ORA will likely report an action plan for your board to work on.
This can be easily avoided by taking the measures above. If planned, executed well and documented appropriately, the small amount of ESOG work you do with each check-in can naturally form your ORA, making it a pain-free process for all involved.
Watch the video below to find out how Vidett can help prepare your ORA:
For further information, please contact Curtis from our Governance team.
