At the Pension Protection Fund, there is a strong commitment to ethical conduct from the board and executive committee who set the tone for the organisation.
As a public corporation with a significant responsibility to our members, we are committed to the 7 Principles of Public Life, which form the basis of the ethical standards expected of public office holders in the UK.
True compliance with policies, process and regulations can only really exist if there is a strong ethical culture where people want to do the right thing
Integrity, one of the seven principles, is also one of our five core values – behaviours which we live by, and expect from every single employee.
Make it more than just box-ticking
Compliance and ethics need each other to exist. True compliance with policies, process and regulations can only really exist if there is a strong ethical culture where people want to do the right thing. Otherwise, there is a danger that compliance can become a dreaded box-ticking exercise.
We have always ensured we are compliant with our various obligations at the PPF; however, responsibility for these were spread across the organisation.
Investment insourcing prompts change
With the insourcing of part of our investment management, and the establishment of a new investment compliance framework, it felt like the right time to formalise all of our compliance activities within one dedicated compliance and ethics function.
This standalone team brings a consistent, best practice approach to compliance through embedding policies, procedures and practices.
A key focus recently has been to lay the groundwork for our in-house trading.
We have also been introducing a set of new policies that affects all teams.
Later on in the year, we will roll out a plan for monitoring and testing across the organisation.
The PPF’s funding strategy: A long-term view
More than a decade after our creation we remain confident of our financial position. In our last published annual report and accounts, we had £3.6bn in reserves, a 115.1 per cent funding ratio, more than £22bn of assets and responsibility for more than 220,000 members.
Ingrain ethics from the top down
None of this work can be successful without a strong ethical culture to support it. It is, therefore, crucial that ethics are ingrained from the top down.
The value to the PPF of having a strong ethical culture is that as well as confirming technical compliance with laws and regulations, we can make sure we are providing the best service to our members and levy payers, and enable our people to feel motivated through doing the right thing.
Dana Grey is head of legal, compliance and ethics at the PPF
