What are the actions from the Unsatisfactory Performance Procedure?

Level 1

  • Has not met up to three administration targets for a period of 1 month but performance is otherwise satisfactory.

  • One late payment (not of material significance) in the financial year but performance is otherwise satisfactory.

  • Year end return not received within agreed timetable.

Level 1 Action

East Riding Pension Fund (ERPF) will contact the Scheme employer to find out if there are any problems or if they need any help or guidance.

Level 2

  • Has not met more than three administration targets for a period of one month or more.

  • More than one late payment (not of material significance) in the financial year.

  • Year end return not received by the last working day in May following discussion with ERPF.

Level 2 Action

ERPF will contact the Scheme employer to discuss the reason for the unsatisfactory performance and an informal improvement plan is put in place with a suitable deadline for review and improvement.

Letter sent to confirm agreement with the Scheme employer and the next steps of:

  • Improvement notice
  • Administration charge; and
  • Interest for late payment if applicable.

Level 3

  • Informal discussions and action plan have been unsuccessful in resolving the unsatisfactory performance.

Level 3 Action

Where an informal improvement plan has failed to improve the Scheme employer’s performance to a satisfactory level, ERPF will invite the Scheme employer to attend a formal improvement meeting.

A further plan of improvement will be put in place with the Scheme employer.

The details of this agreement will be sent as a formal improvement notice.

Where a Scheme employer declines to discuss performance issues a formal improvement notice will be sent and an administration charge will be made. In addition, interest on late payments will be charged.

Level 4

  • Where a formal improvement notice has been unsuccessful in improving Scheme employer performance.

  • Late payments of material significance.

Level 4 Action

The Scheme employer will be added to the Risk Register.

The Scheme employer will be reported to The Pensions Regulator (tPR).

Report will be passed to the East Riding Pension Fund Local Pension Board (ERPFLPB) and the Pensions Committee.

ERPF will continue to try and work with the Scheme employer to resolve any performance issues.

An administrative charge will be made for all additional work due to unsatisfactory performance.

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