Strathclyde Pension Fund: Review of Admissions
The UNISON Scotland Submission
To the Strathclyde Pension Fund Consultation:
"Review of Admissions Policy"
This paper constitutes UNISON Scotland's
response to the consultation by Strathclyde Pension Fund on
their Review of Admissions Policy.
UNISON is Scotland's largest trade union
representing around 150,000 members working in the public
sector in Scotland, many of whom are members of Strathclyde
UNISON Scotland welcomes the opportunity
to respond to this consultation exercise.
UNISON Scotland is concerned about the pace
of the proposed policy change and the lack of time allowed
The implementation date for the proposed
change is set for 1st January 2005, with the policy
set for approval by the relevant sub-committee of Strathclyde
Pension Fund on 25th November 2004. However the
consultation papers were not circulated until 30th
September 2004 with a deadline for responses set at 1st
November 2004. This allowed barely a month for consultation
for organisations such as UNISON Scotland that would prefer
a longer period to consult their membership on the proposed
Although UNISON Scotland would obviously
be in favour of protecting the long-term viability of Strathclyde
Pension Fund, there is a concern that the case has not been
proven for a change in the admissions policy or that such
a change should proceed at such an urgent pace.
UNISON Scotland is concerned about the impact
the proposed new admissions policy would have on our members
who are currently members of Strathclyde Pension Fund (SPF).
UNISON Scotland would prefer to see some
clarification with regard to the issue of job transfers due
to PPP schemes. The STUC/ Scottish Executive PPP Staffing
Protocol highlights that, where possible, transferred staff
should remain as members of their existing pension scheme
through their new employer gaining admitted body status to
the pension fund.
Although a bond or indemnity is required
for the admission of ‘transferee' bodies , such as PPP schemes,
there is a concern that any funding shortfall not covered
by the bond would fall onto the awarding authority. Also,
as the STUC/ Scottish Executive PPP Staffing Protocol and
Best Value guidance highlight, any new recruits to the PPP
workforce should access the same pension arrangements as transferred
Therefore any council (or other existing
employer) within Strathclyde Pension Fund who awards a contract
or service to another organisation, and where this involves
a transfer of staff, could find themselves not only liable
for pension funding shortfalls of transferred staff but also
for new recruits to the PPP workforce. UNISON Scotland is
concerned that this situation is not clearly highlighted within
the consultation paper.
This could lead to existing SPF employers
refusing to act as a ‘guarantor' for any new organisations
that take over the various public sector functions (i.e. new
housing organisations which take over local authority housing
stock and related staff).
If existing SPF employers refused to act
as ‘guarantors' then there is a danger that existing individual
members of the SPF could lose their entitlement to remain
within the fund. UNISON Scotland would be concerned that staff
who are currently carrying out duties in the public sector
and through staff transfer find themselves employed by another
body would be denied access to the pension fund.
There also seems to be some confusion as
to whether each transfer would require both an indemnity bond
from the new employing body as well as the former employer
to act as ‘guarantor'. UNISON Scotland would prefer for this
issue to be clarified and to know if there are guidelines
in place or being developed to cover this. Without such clear-cut
guidelines there is a concern that current employees of SPF
employers would be unclear of the situation affecting their
entitlement to remain within the pension fund in the event
of their transfer to a new employer.
UNISON Scotland is concerned about not only
the pace of change and the limited consultation period but
also on the actual need for a change to the admissions policy.
The consultation paper does not make the case strongly enough
that such policy change is needed. There is a concern that
existing SPF employers may not be fully aware of the risk
involved in transferring staff while still being held responsible
for any future pension liabilities. UNISON Scotland is also
concerned that there appears to be no definitive guidelines
on how transfers of staff (via PPP or a transfer of a council
function - for instance housing stock transfer) will affect
individual members of the SPF.
For further information please contact:
Matt Smith, Scottish Secretary
14, West Campbell Street,
Glasgow G2 6RX
Tel 0845 355 0845 Fax 0141 342 2835