In short, no. But it might be a nudge in the right direction (for some pension trustee boards at least).
Why do I say that? Well, the communications and disclosure section in the recently published General Code is not too different from that in the draft and there was very little that was actually new in that.
As I’m writing this, I realise it is most unlike me. I think I may be coming across a bit grumpy. I’m not, it’s just a shame as there was such an opportunity. Where the general code misses a trick is really promoting the value of pension trustees having a communications strategy or policy (which not many have at the moment so may be the nudge needed).
As a communications practitioner, the general principles on page 130 is the most interesting. Let me try and bring it to life…
The general code says:
‘ensure that all communications sent to members are accurate, clear, concise, relevant and in plain English’
Member communications are fascinating (and vital)! Yes, they need to be accurate but that doesn’t mean they need to be complicated, overly-technical and lacking in imagination. While pension trustees may ask, “is this fit for purpose?”, nowhere near enough ask, “is it good?”, “is it engaging?” or “would I want to read it?”
The general code says:
‘consider what additional information or explanation members may need to help them make informed decisions about their benefits’
and
‘regularly inform members of the impact their contributions will have on their overall benefits’
Many trustee boards look at member communications piecemeal. Pension scheme members are actually on a journey – and that’s what a trustee communications strategy should be built around. Tell that journey as a story and you’ll soon see the key points along the way where effective communications are needed to ensure the journey can be travelled smoothly and successfully.
The general code code says:
‘when deciding on the format of communications and information to be published, consider any technology that may be available to them and appropriate for their members’
and
‘consider using various communication methods, including accessible online content, audio, Braille, large font, and languages other than English’
Different people journey differently. Some are fast, others slow. Some like to book online, others still like to speak to another human in a travel agency. Allowing for these differences – ie UNDERSTANDING YOUR AUDIENCE – may be ‘communications 101’ but it is often overlooked. Pension scheme members are not a homogenous lump – please do not treat them as such.
It’s another point for your communications strategy and speaks directly to how pension trustees are allowing for equity, diversity and inclusion (ED&I) in their scheme. It doesn’t need to be expensive.
Digital and hard copy communications can be developed and designed together to minimise cost, websites can be quick and cheap to set up, helpful bite-size videos don’t need expensive production to be effective, training an onsite ‘pension champion’ can involve little more cost than time. If you read a pension lawyer’s briefing about how to ‘go digital’ with member communications, there’s little surprise many trustees are put off. Let me assure you, it isn’t as complicated as it seems – just get help from someone who knows what the steps are!
Trustees can help members help themselves too by signposting to useful accessibility tools. Most web browsers and PDF readers have screen reading/text to speech software included and other free text to speech software is available online. Although large print format would typically incur extra cost, many people who need large print now use magnification functions on screen. What’s most important here is PDFs you provide are directly made and not scanned. Scanned versions do not magnify so well!
The general code says:
‘regularly review member communications, taking account of member feedback, any changes to scheme design and developments in law and this code of practice’
I could have combined this with points further up, but it deserves a slot of its own. How and when you review member communication is another important part of the trustees’ communications strategy/policy. Don’t rely on your administrator’s standard letters and announcements – always review them to decide if they work for your scheme members. Are the key messages you’ve been incorporating in your communications still relevant? Are the calls to action working? Are the formats effective?
Taking account of member feedback is important – but seemingly rarely done. The regulatory regimes in place for defined contribution (DC) master trusts and collective DC schemes (subject to consultation) include the requirement to actively seek member feedback on communications. Could this be the way we’re heading for other pension schemes too? It’d be a good thing – after all, members are the people who are best placed to tell you if your pension communications are working.
If you have any questions, or want to find out more, please get in touch with the author Suzi Lowther.
Please note this article first appeared on Professional Pensions: Will the single code improve member communications?
