Questions about CPF 2020 consultations on the ISS/RIP and the FSS
NB both of these two Consultations took place BEFORE March 2020, COVID, and Lockdown, so that cannot be any explanation.
The consultation by CPF for its 100,000 members on a new ISS/RIP (Investment Strategy / Responsible Investment Policy) attracted just 8 responses.
- This consultation was announced by a Press Release on 19 February 2020
- The closing date was 31 March 2020
- All 100,000 CPF members were not informed directly
- CPF do not have email addresses for the 100,000 members.
- The website has no members-only web-based discussion pages, which would also have provided a basis for views for preparing a policy on ESG, divesting and engagement.
- “Latest News” emails had been discontinued at the beginning of 2020.
- CPF could have used the box on March payslips to inform pensioners.
- The March payslip only mentioned the online 2020 Cheshire Chat.
- This consultation was still current
- If it had been listed, more than eight members may have contributed.
- This published draft for comment confirmed a policy of engagement and ruled out divestment, or disinvestment as only CPF refer to it.
- Comments received covered views on fossil fuels, divestments, climate change, ESG investing, the Paris Agreement, and ethical investing.
- CPF accepted only two changes to wording for the final RIP.
- Four people commented on the process and lack of genuine involvemnent.
- A CPF summary of suggestions went on the CPF website in April 2020
- But by then ISS / RIP had been adopted.
Similarly, a consultation on the Funding Strategy Statement by CPF for the 300 employers, attracted just two responses,
- It was emailed to employers on Christmas Eve 24 December 2019
- The closing date was 24 January 2020
- It is unclear if any responses changed the pre-written document.
Both consultations took place before BEFORE March 2020, and the impact of COVID, so we are concerned at both the process and the results:
- Genuine planning or involvement for both consultations was inadequate.
- Both consultations were rushed through by CPF to meet a 1 April 2020 deadline, rather to have any real value.
- Consequently all consultation was a “tick-box”.
- Other views and opinions were not considered given these timescales.
- The lack of response ( 2 out of 300 employers, and 8 out of 100,000 members) must casts doubt on the validity of these new policies.
- It may lead to disputes later.
- We suggest CPF had simply conveniently pre-written both policies.
- These consultations were not on the 2019 or 2020 agenda for the Pension Board