NORTHERN IRELAND LOCAL GOVERNMENT OFFICERS’
SUPERANNUATION COMMITTEE Investment of Contributions Equality Impact Assessment December 2003


Summary
1.
The NILGOSC Equality
Scheme sets out a commitment to expose the investment of contributions to an
equality impact assessment. This
document is the draft impact assessment.
2.
If you have difficulty
reading or understanding this document please contact NILGOSC for an
alternative version at the address shown below.
3
NILGOSC is the Northern
Ireland Local Government Officers’ Superannuation Committee – in other words it
is the government body which administers the Local Government Pension Scheme (LGPS).
4
NILGOSC manages a
pension fund in excess of £2billion by investing in equities, bonds and
property throughout the world. The
means of investing is laid down in the its Statement of Investment Principles
which the Committee is required to have in accordance with the LGPS
legislation. No differential/adverse
impact has been identified on any of the nine groups specified in Section 75 of
the Northern Ireland Act 1998.
5
Comments on the draft
assessment should be made before 31st May 2004 to Jennifer Campbell
who can be contacted as follows:
Post/Person: NILGOSC, Templeton House, 411 Holywood Road, Belfast, BT4 2LP
Phone: 028
9076 8025
Email: info@nilgosc.org.uk
Jennifer
can also discuss other means of consultation to suit your needs.
Further
copies of the Assessment are available from the address above or it can be read
on the internet at www.nilgosc.org.uk/equality.htm
6
NILGOSC will take
account of the feedback from the consultation exercise before changing its
procedures in the light of the impact assessment. Once the consultation exercise is complete it will publish a
final version to all consultees which will include summaries of the comments
received and how they affected the procedures involved.
Contents
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Page |
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1. |
Introduction |
4 |
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2. |
What is NILGOSC? |
4 |
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3. |
The Policies Under Review |
5 |
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4. |
Consideration of Available
Data and Research |
8 |
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5. |
Assessment of Impacts |
8 |
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6. |
Consideration of
Alternatives or Methods of Mitigation |
10 |
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7. |
Formal Consultation |
10 |
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8. |
Policy Decision Following
Consultation Exercise |
11 |
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9. |
Publication of Results |
11 |
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Appendix A |
Statement of Investment
Principles |
12 |
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Appendix B |
Local Government Pension
Scheme (Management and Investment of Funds) Regulations (Northern Ireland)
2000 |
20 |
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Appendix C |
Fair Employment Declaration |
41 |
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Appendix D |
List of individuals and
Bodies to be Consulted |
42 |
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|
If you have difficulty
reading or understanding this document please contact NILGOSC for an
alternative version. |
|||
|
Post/Person: Phone: Email: |
NILGOSC, Templeton
House, 411 Holywood Road, Belfast, BT4 2LP 028 9076 8025 |
||
1.
Introduction
1.1 In April 2000 the Northern Ireland Local Government
Officers’ Superannuation Committee (NILGOSC) published its Equality
Scheme. In the Scheme it set out its
commitment to expose the investment of contributions and matters relating to
the procurement of goods and services to an equality impact assessment in 2003.
1.2 This document assesses the impact of the investment of
contributions on the nine groups specified in Section 75 of the Northern
Ireland Act 1998 with which NILGOSC is committed to have due regard to the need
to promote equality of opportunity.
These groups are:
§
Persons of different
religious belief, political opinion, racial group, age, marital status or
sexual orientation
§
Men and women generally
§
Persons with a
disability and persons without
§
Persons with dependants and
persons without.
In addition, without prejudice to the above
obligation, public authorities must also, in carrying out their functions
relating to Northern Ireland, have regard to the desirability of promoting good
relations between persons of different religious belief, political opinion or
racial group.
2.
What is NILGOSC
2.1 NILGOSC is the pension scheme for the employees of
over 200 public sector organisations in Northern Ireland including the 26
councils, the non-teaching staff of schools, colleges, education and library
boards and the University of Ulster, the Northern Ireland Housing Executive,
Translink, and many housing associations.
2.2 NILGOSC is managed by a Committee appointed by the
Department of the Environment. The
Department also make pension scheme legislation. The staff of NILGOSC undertake the administration of the Scheme
rules as a service to the employers in the Scheme.
3.
The Policies Under Review
§
Statement of Investment
Principles (Sept 2003)
3.1 The NILGOSC pension fund exceeds £2billion in value
and is invested in equities, bonds and property in markets across the world.
3.2 This impact assessment will examine how NILGOSC
implements the policy, concentrating on the areas where discretion is
exercised.
4.
Statement of Investment Principles
A
copy of the policy is attached as an appendix (appendix A) to this document,
the key points are summarised below:
4.1
Introduction
§
Outlines the purpose of the statement, ie to set out the principles
governing decisions regarding the investment of assets of the NI Local
Government Pension Fund.
§
Investment powers of the Committee are set out in the Local Government
Pension Scheme (Management and Investment of Funds) Regulations (Northern
Ireland) 2000.
4.2
Scheme Investment Objective
The Committee aims to invest assets
cautiously and also provide reasonable stability in employer contribution
rates.
Strategy – the planned asset
allocation strategy is detailed in the main policy (see Appendix A), it was
determined with regard to the actuarial characteristics of the Scheme.
4.3
Compliance with
Statutory Funding Target
Funding Target
– funding levels were agreed in March 2001 against the targets specified in the
Regulations, these establish when Employing Authorities will usually be
required to pay additional contributions into the Fund or when contribution
rates are to be revised.
Policy for Maintaining
Funding Level – the Committee has agreed to consider funding levels on an annual
basis, and if it changes significantly the suitability of the investment strategy
will be reviewed.
4.4
Choosing Investments
Process for Choosing Investments
-
4.5
Fund managers are responsible for the day to day management of the
majority of the Funds assets. However,
the Committee retains direct control over some investments, in particular:
AVC’s Past performance, charging structure,
flexibility and the quality of administration were all taken into account when
the Committee selected suitable investment vehicles for members AVC’s. The Fund AVC providers are detailed in the
main policy.
Property The Committee manages the property portfolio. Property advisers and independent
consultants advise the Committee on property and forestry related matters,
management and investments.
Investments Directly
Controlled by the Committee
The Committee will seek
regular written advice regarding review of investments. This will consider the suitability of
investments, the need for diversification and the principles contained in the
Statement. The adviser will have the
knowledge and experience required under Section 36(6) of the Pensions (Northern
Ireland) Order 1995.
Investment Policy
The Committee has defined a
fixed benchmark (reviewed annually) to represent what is deemed best judgement
of what is required to meet the Fund’s liabilities. This means that the Scheme’s assets are invested in a range of
assets including UK and overseas equities and bonds.
Delegation to Fund Managers
There are 4 active fund
managers who are responsible for the selection of individual stocks within each
investment type and 1 passive fund manager who is required to match the chosen
indices within the benchmark.
Socially Responsible
Investment
Active fund managers main
obligation is to act in the best interests of the scheme beneficiaries, however
the Committee has also instructed that they take account of social, ethical and
environmental factors provided that financial obligations are not compromised.
New Investments
Fund managers may bring, to
the Committee new categories for investment that they deem suitable for the
Fund for consideration.
Realisation of Investments
The fund managers will also
bring categories that have become unsuitable for the Fund to the Committee’s
attention.
4.6
Diversification and Risk Controls
Measures have been
implemented to reduce risks associated with making investments, including:
§
Division of assets between fund managers in order to reduce the risks
associated with one fund manager.
§
Investment of the majority of assets in investments which are expected
to exceed price inflation and general salary growth over long periods.
§
To outperform the return on the Total Fund benchmark managers have
discretion to move within specified tolerance levels.
§
An independent global custodian has been assigned to ensure separation
of fund assets from investment managers.
§
Restrictions placed on Manager to limit the risks from each individual
investment and prevent unsuitable investment activity.
§
Fund managers also ensure that suitable internal operating procedures
are in place to control individuals making investments for the Fund.
4.7
Compliance
Frequency of Review
The Committee will review
the Statement of Investment Principles on an annual basis (or sooner if
necessary).
Professional Advice
The Committee employ
professional advisers to assist in the monitoring of the fund managers and in
the review of the investment strategy.
Performance Measurement
Information
The Committee employ a
custodian to independently measure the investment performance of the managers
and property advisers.
CIPFA Pensions Panel
Principles
The Committee states the
extent to which it complies with the ten principles of investment practice set
out by the Chartered Institute of Public Finance and Accountancy.
5.
Consideration of Available Data and Research
The following data was considered in undertaking the
impact assessment:
§
Property information
including detail on property managers and properties owned.
§
The companies
responsible for active fund management (Fund Managers).
§
Allocation of
investments.
6.
Assessment of Impacts
6.1 NILGOSC does not hold information on any of the nine
groups specified in Section 75 of the NI Act in relation to its investments,
fund managers, property advisers or investment consultants. It therefore has no quantitative data to
show adverse impact on any one group.
NILGOSC
does not intend to source such data because the information relating to the
distribution of assets is so diverse, for example, the current investment
allocation is as follows:
|
Investment |
% of assets |
|
UK
Equities
Overseas Equities Fixed Interest gilts Index linked gilts Corporate bonds Property |
36 36 10 4 4 10 |
|
6.2 Fund Manager selection has been carried out in
accordance with Regulation 6 of the Local Government Pension Scheme (Management
and Investment of Funds) Regulations (Northern Ireland) 2000. Investment advisers invite potential fund
managers (from throughout the world) to complete a Request For Proposal (RFP),
completed RFP’s are used to compile a shortlist which is then presented to the
Committee to make a selection. This
impact assessment could not identify any evidence or data to suggest adverse
impact on any one group.
6.3 The Committee rely upon professional fund managers for
the day to day management of the majority of the Fund’s assets. To manage these assets the Committee has a
written statement of the principles governing its decisions about
investments. This statement includes
obligations for socially responsible investment. The Committee’s overriding obligation is to act in the best
interests of the scheme beneficiaries.
Active fund managers have been instructed to take account of social,
ethical and environmental considerations provided the primary financial
obligation is not compromised. To this
end the Committee’s active fund manages will engage with those companies in
which the fund is invested where the social, ethical and environmental policies
fall short of acceptable standards and where this is likely to be detrimental
to the long-term value of the company.
The
aim is to encourage a general increase towards the adoption of industry best
practice in both the standards and the level of commitment to achieving them.
Fund
managers exercise voting rights on investments on behalf of the Committee and
report quarterly to the Committee on the voting activity.
The
Committee does not have the direct ownership of the underlying assets of the
AVC policies or the policy assurance for indexed assets with Legal &
General and therefore the Committee’s policy on socially responsible investment
does not apply to such assets.
6.4 Investments are made throughout the world (with the
exception of property and forestry) although there is limited investment in
Northern Ireland. The Committee manages
the property portfolio and forestry matters taking advise from property
advisers and independent Forestry and Agricultural Business Economic and Rural
Development consultants. Up to 10% of
the Fund is invested in commercial and retail property in Northern Ireland and
Great Britain, forestry and property unit trusts. This impact assessment could not identify any data to suggest
adverse impact on any one group in relation to the NILGOSC property portfolio
or the allocation of investments.
6.5 NILGOSC has never received a complaint based on
failure to provide equal access in relation to the investment of contributions
by reason of any of the 9 groups and has no evidence to show any adverse
impact.
7.
Consideration of Alternatives or methods of
mitigation
7.1 This EQIA did not identify adverse differential
impacts. However, during this
assessment NILGOSC identified one area where a further safeguard could be
implemented to ensure future adverse impacts do not arise. The process for the selection of fund
managers is described in point 6.2 above and factors such as religious belief, political
opinion etc are not relevant to the decision making process. However, in future, and to ensure that
NILGOSC do not deal with an ‘unqualified person’ (as defined by the Fair
Employment and Treatment (NI) Order 1988, those firms being considered for
selection as fund managers will be required to complete a Fair Employment
Declaration to confirm they are not an ‘unqualified person’. A copy of this declaration is attached in
Appendix C
8.
Formal Consultation
8.1 This impact assessment is subject to a formal
consultation exercise. Consultees will
include those individuals and organisations listed in Appendix D of the Committee’s Equality Scheme and amended by
experience.
8.2 The formal consultation exercise will end on 31st
May 2004 thereby allowing 12 weeks for comments to be received.
Many consultees have already indicated how they would like to be consulted, the majority preferring questionnaires or written letter. For those consultees who have not indicated a preference, relevant methods outlined in section 4 of the Committee’s Equality Scheme will be made available. These are:
§
Letter
§
Meetings with the
public, in groups or as individuals
§
Attitude surveys of
service users and potential service users
§
Internet
§
Direct invitation to
groups
NILGOSC
will announce the publication of the draft impact assessment through press
releases and public notices.
8.3 Comments can be made in person, by telephone, by email
or by writing to Jennifer Campbell who can be contacted as follows:
Post/Person: NILGOSC, Templeton House, 411 Holywood Road,
Belfast, BT4 2LP
Email: info@nilgosc.org.uk
9. Policy
Decision Following Consultation Exercise
9.1 This impact assessment is a review of policies and
procedures which are already in operation.
The impact assessment has highlighted the need to change the procedure
in relation to the selection of fund managers, however, no action will be taken
to amend the existing policies and procedures until the consultation exercise
is complete in order that comments received can be taken into account.
10.
Publication of Results
10.1 NILGOSC will publish by the most appropriate method to
those listed in Appendix D and any other organisation representing some or all
of the stakeholders, the outcome of this equality impact assessment and any
monitoring undertaken.
10.2 This material will also be available in printed form
by contacting NILGOSC at Templeton House, 411 Holywood Road, Belfast, BT4 2LP,
telephone number 028 9076 8025.
Alternative formats will be available on request. NILGOSC may inform the general public about
the availability of this material through press releases. It will also inform bodies listed at Annex D
when this material is available.
10.3 The results of impact assessments will be posted on
the NILGOSC website which is http://www.nilgosc.org.uk/equality.htm
10.4 This report on the impact assessment will include:
§
Executive summary
§
Details of the procedures
being assessed
§
Collection of data
§
Key findings
§
Conclusions
Statement of Investment Principles
INTRODUCTION
This statement sets out the principles governing
decisions about the investment of the assets of the Northern Ireland Local
Government Pension Fund (the Fund). The
Northern Ireland Local Government Officers’ Superannuation Committee issues
this statement as the administrators of the Fund, to comply with Regulation 10
of the Local Government Pension Scheme (Management and Investment of Funds)
Regulations (Northern Ireland) 2000 (as amended).
The Committee has obtained written advice on the
content of this statement from Hewitt Bacon & Woodrow Limited, the Fund’s
actuaries and investment consultants.
The Committee has consulted its fund managers about
the content of this statement.
The investment powers of the Committee are set out
in the Local Government Pension Scheme (Management and Investment of Funds)
Regulations (Northern Ireland) 2000, as amended. This statement is consistent
with those powers. Neither the
statement nor the Regulations restrict the Committee’s investment powers by
requiring the consent of a third party.
The Committee aims to invest the assets of the Scheme
prudently to ensure that the benefits promised to members are provided, and to
provide reasonable stability in contribution rates for the employers. In setting investment strategy, the
Committee first considered the lowest risk asset allocation that it could adopt
in relation to the Scheme's liabilities. The asset allocation strategy it has
selected is designed to achieve a higher return than the lowest risk strategy
while maintaining a prudent approach to meeting the Scheme’s liabilities.
STRATEGY
The current planned asset allocation strategy is
set out in the table below, together with the approximate assumptions made
about the real return for each asset class in determining the strategy.
|
Asset Class |
Weighting % |
Real Return % p.a. |
|
|
UK Equities |
36 |
|
5 |
|
Overseas Equities |
36 |
|
5 |
|
Fixed Interest gilts |
10 |
|
2.5 |
|
Index-linked gilts |
4 |
|
2 |
|
Corporate bonds |
4 |
|
3 |
|
Property |
10 |
|
4 |
|
Private equity |
0 |
|
N/a |
The intended
asset allocation strategy was determined with regard to the actuarial
characteristics of the Scheme, in particular the strength of the funding
position and the liability profile. The
Committee considered written advice from their investment advisers when choosing
the Scheme's planned asset allocation strategy. It is the Committee's policy to consider:
§
A full range of asset classes
§
The risks and rewards of a range of alternative asset
allocation strategies
§
The suitability of each asset class
§
The need for appropriate diversification
As at 31 March 2001 the funding level against the
funding target specified in the Regulations (100% of the Fund’s liabilities)
was 121%. A funding level below 100%
usually means that the Employing Authorities will be required to pay additional
contributions into the Fund under Regulation 80 of the Local Government Pension
Scheme Regulations (Northern Ireland) 2002.
A funding level above 100% provides scope for payment of reduced
contribution rates by the Employing Authorities.
Policy for maintaining funding level
Having considered advice from Hewitt, Bacon &
Woodrow, the Committee believes that the Fund’s investment strategy, in
conjunction with the certified levels of future contributions to the Fund, is
consistent with the requirement to return the Fund to 100% funding within
acceptable levels of contribution rate volatility. The funding level will be considered each year and, if it changes
significantly, the suitability of the investment strategy will be reviewed.
CHOOSING INVESTMENTS
The Committee relies on professional fund managers
for the day-to-day management of the majority of the Fund’s assets. However, the Committee retains direct
control over some investments. In
particular, it makes the decisions about property investments and the
investment vehicles used by members for additional voluntary contributions
(AVCs).
For members’ AVCs, the Committee has chosen
suitable investment vehicles taking into account past performance, charging
structure, flexibility and the quality of administration. The Fund’s AVC providers are the Equitable
Life Assurance Society (closed to new members) and the Prudential Assurance Co.
The investment vehicles chosen are With Profits, a Managed Fund, a Building
Society fund and a Lifestyle+ option for Equitable Life and a full range of 26
investment vehicles ranging from the low risk Cash Fund to the higher risk
Global Equity Fund together with 3 Lifestyle funds for the Prudential.
The Committee manages the property portfolio. Up to 10% of the Fund is invested in commercial and retail
property in Northern Ireland and Great Britain, forestry and property unit
trusts.
Mr J W Burgess, FRICS, ACIArb and Colliers CRE
jointly advise the Committee on property matters. They are responsible for
advice on the strategic management of the portfolio, including the purchase and
sale of property, the active management of properties to add value and the
supervision of the day-to-day management of properties. John Clegg Consulting
Ltd, an independent firm of Forestry and Agricultural Business, Economic &
Rural Development Consultants, is also retained to monitor the forestry
investments and advise the Committee on forestry matters. The property advisers are paid an annual
retainer and on a fee basis related to the
value of the assets bought and sold.
Investments directly controlled by the Committee
The Committee’s policy is to review the investments
over which it retains direct control and to obtain written advice regularly and
at least annually. When deciding
whether or not to sell or purchase any new investments the Committee will
obtain written advice.
The written advice will consider the suitability of
the investments, the need for diversification and the principles contained in
this statement. The adviser will have
the knowledge and experience required under section 36(6) of the Pensions
(Northern Ireland) Order 1995.
For assets managed by the fund managers, the
Committee has set a fixed benchmark, which represents the Committee’s best
judgement of what is necessary to meet the Fund’s liabilities. In practice this
means that the Scheme’s assets are invested in a range of assets including UK
and overseas equities and bonds. The
Benchmark is reviewed annually with the Fund’s investment consultants Hewitt,
Bacon & Woodrow.
The active fund managers are:
The managers are responsible for the selection of
individual stocks within each type of investment.
The passive fund manager, Legal & General
Investment Management is responsible for 37% of the Fund and is required to
match the chosen indices within the benchmark.
The Financial Services Authority (FSA) regulates
the fund managers. The Committee has a
signed agreement with each fund manager, which provides for a fee scale on a
basis related to the value of the assets managed. Wellington also has a performance related supplement to their
remuneration.
Socially responsible investment
The Committee’s overriding obligation is to act in the best
interests of the scheme beneficiaries. However the Committee has instructed its
active fund managers to take account of social, ethical and environmental
considerations provided the primary financial obligation is not compromised. To
this end the Committee’s active fund managers will engage with those companies
in which the fund is invested where the social, ethical and environmental
policies fall short of acceptable standards and where this is likely to be
detrimental to the long-term value of the company.
The aim is to encourage a general increase towards
the adoption of industry best practice in both the standards and the level of
commitment to achieving them.
The Fund managers exercise voting rights on
investments on behalf of the Committee and report quarterly to the Committee on
the voting activity.
The Committee does not have the direct ownership of
the underlying assets of the AVC policies or the policy of assurance for
indexed assets with Legal & General, and therefore the Committee’s policy
on socially responsible investment does not apply to such assets.
The Committee has set each fund manager a
performance objective in relation to published indices. The performance objectives as agreed between
the Committee and the fund managers are set out in the fund management
agreements.
Based on past performance, the Committee expects
the long-term return on the majority of investments held by the Fund to exceed
price inflation and general salary growth.
Within the categories of investment permitted by
the Regulations, the fund managers can purchase any new investments as long as
they do not breach the provisions of the fund management agreements. The fund managers will bring to the
Committee’s attention any new category of investment, which in their judgment
has become suitable for the Fund before investing in that category.
The fund managers will bring to the Committee’s
attention any category of investment held by the Fund, which in their judgment
has become unsuitable for the Fund. The
fund manager is not expected to bring to the Committee’s attention individual
investments realised on purely investment grounds.
DIVERSIFICATION AND RISK CONTROLS
The following measures have been implemented to
reduce the risks associated with making investments.
The assets are divided between one passive fund
manager and four specialist active fund managers to gain the benefits of
specialist skills in markets, the predictable and diversified results from
passive management as well as the reduction of the risks associated with one
fund manager having responsibility for all of the Fund’s assets. In addition, this division enables the Committee
to control the overall asset allocation and the level of risk resulting from
the differing approaches, styles and specialisations of each manager. The passive manager maintains the overall
asset allocation within defined ranges.
The majority of the Fund’s liabilities are linked
to inflation and salary growth. The
policy is therefore to invest the majority of the assets in investments, which
are expected to exceed price inflation and general salary growth over long periods.
Range of assets
The Committee has set a Total Fund benchmark. This contains a wide range of assets
suitable for a pension scheme. The
managers have discretion to move away from the benchmark position within specified
tolerance levels to outperform the return on the benchmark. The Committee reviews the distribution of
assets quarterly.
The Committee ensures the separation of custody of
the Fund’s assets from its Investment Managers and its officials by the
employment of its independent global custodian, JPMorgan Chase Bank. The Committee
has signed a global custody agreement with JPMorgan Chase Bank.
The Committee’s solicitors hold the title deeds to
the commercial property and forestry assets.
The Committee’s agreement on the way the portfolio
is managed with each fund manager contains a series of restrictions, which may
be amended from time to time. The
purpose of the restrictions is to limit the risks from each individual
investment and prevent unsuitable investment activity. Each fund manager must comply with these restrictions.
Powers of investment delegated to the fund managers
must be exercised with a view to giving effect to the principles contained in
this statement so far as is reasonably practicable. The manager will also ensure that suitable internal operating
procedures are in place to control individuals making investments for the Fund.
COMPLIANCE
The Committee will review this statement annually
or sooner if there is a change in the policy on any of the areas covered by the
statement. The Committee will consult
with such persons, as it considers appropriate and take written advice when
revising the statement.
The Committee employs Hewitt Bacon & Woodrow
Limited as investment adviser to provide such services as needed to ensure that
the Committee is fully briefed to both take direct decisions and to monitor
those which it delegates. Hewitt Bacon
& Woodrow Limited is paid on either a fixed or variable fee basis according
to the requirements of the Committee for each task.
Performance measurement information
The Committee uses the services of its custodian, JPMorgan
Chase Bank, and Investment Property Databank, (IPD), to independently measure
the investment performance of the managers and property advisers. Each quarter, the Committee monitors the
performance of the combined assets and the performance of each manager’s
portfolio against their target benchmark. Annually the Committee reviews with
its investment advisers, Hewitt, Bacon and Woodrow, each manager’s and the
property advisers’ annual and rolling three year investment performance
together with a review of the Fund’s benchmarks.
CIPFA Pensions Panel Principles
The Committee is required to state the extent to which it
complies with the ten principles of investment practice set out in a document
published in April 2002 by CIPFA, the Chartered Institute of Public Finance and
Accountancy, and called “CIPFA Pension Panel Principles for Investment Decision
Making in the Local Government Pension Scheme in the United Kingdom (Guidance
note issue No 5). The ten principles are as follows:
Myner’s
Principles
Principle Compliance
|
1. Effective Decision Making |
The Committee is not fully compliant with this principle.
(See below). |
|
|
|
|
2. Clear Objectives |
The Committee is compliant with this principle. |
|
|
|
|
3. Focus on Asset Allocation |
The Committee is compliant with this principle. |
|
|
|
|
4. Expert Advice |
The Committee has not yet complied with this principle.
(See below) |
|
|
|
|
5. Explicit Mandate |
The Committee is not fully compliant with this principle.
(See below) |
|
|
|
|
6. Activism |
The Committee is not fully compliant with this principle.
(See below) |
|
|
|
|
7. Appropriate Benchmarks |
The Committee is compliant with this principle. |
|
|
|
|
8.
Performance Measurement |
The Committee is fully compliant with this principle. |
|
|
|
|
9. Transparency |
The Committee is compliant with this principle. |
|
|
|
|
10. Regular Reporting |
The Committee is compliant with this principle. |
The Committee does not comply with these Principles in the
following respects:
Principle
1 – This recommends payment for those
in trustee positions. The Chairman is
currently paid but the remainder of the Committee is not. Any decision on the basis of payment is a
matter for the Department of the Environment.
Principle
4 – This requires contracts for
services for actuarial and investment advice to be open to separate
competition. The Committee has
timetabled the tender for both types of services for completion by 31 March
2004 and will then comply with this Principle.
Principle
5 – This requires that manager
mandates should not be terminated before the expiry of the evaluation timescale
for underperformance alone. The Committee takes a rigorous and long term
approach in the selection and monitoring of investment managers but believes
that it should always have the power to terminate a manager’s services with
immediate effect should this be in the best interest of its beneficiaries.
Principle
6 – This requires the incorporation of
the principle of the US Department of Labor Interpretative Bulletin on
activism. The Committee takes its obligations as shareholders very seriously,
but believes that full compliance with this Bulletin places an unnecessary cost
burden on the Scheme, which would not necessarily be beneficial for the
beneficiaries.
Appendix B
Local Government Pension
Scheme (Management and Investment of Funds) Regulations (Northern Ireland) 2000
Made . .
. . . . .
. 19th May 2000
Coming into operation .
. . . 1st
August 2000
1. Citation and commencement.
2. General definitions.
3. Definition of "investment".
4. Definition of "investment manager".
5. Management of the fund.
6. Choice of investment managers.
7. Terms of appointment of investment managers.
8. Review of investment manager's performance.
9. Use and investment of fund money.
10. Statement of investment principles.
11. Investments under section.11 of the Trustee Investments Act 1961.
12. Restrictions on investments.
Limits on investments.
The Department of the Environment, in exercise of the powers conferred on it by Article 9 of and Schedule 3 to The Superannuation (Northern Ireland) Order 1972(a) and now vested in it(b) and of every other power enabling it in that behalf, and after consultation with the Association of Local Authorities of Northern Ireland, the Northern Ireland Local Government Officers' Superannuation Committee and such representatives of other persons likely to be affected by the regulations as appeared to it to be appropriate, hereby makes the following regulations: -
1. - (1) These Regulations may be cited as the Local Government Pension Scheme (Management and Investment of Funds) Regulations (Northern Ireland) 2000, and shall come into operation on 1st August 2000.
2. In these Regulations -
"the 2000 regulations" means the Local Government Pension Scheme Regulations (Northern Ireland) 2000(c);
"the Committee" has the same meaning as in Schedule A1 to the 2000 regulations;
(a) S.I. 1972/1073 (N.I. 10);
Article 14 was amended by Article 12 of the Pensions (Miscellaneous Provisions)
(Northern Ireland) Order 1990 (S.I. 1990/1509 (N.I. 13))
(b) S.R.& O. (N.I.) 1973 No. 504 Art. 7(1); S.I.
1976/424 (N.I. 6)
(c) S.R. 2000 No. 177
"European authorised institution" and "European institution" have the same meanings as in the Banking Co-ordination (Second Council Directive) Regulations 1992(a);
"FSAVC scheme" is a scheme approved by virtue of section 591(2)(h) of the Income and Corporation Taxes Act 1988(b);
"the fund" means the superannuation fund established under the Local Government (Superannuation) Regulations (Northern Ireland) 1950(c);
"fund money" means money in the fund;
"home-regulated investment business" has the same meaning as in the Banking Co-ordination (Second Council Directive) Regulations 1992;
"limited partner" means a person who is not liable for the debts or obligations of a partnership beyond the amount he contributed at the time he became a partner;
"member"
has the same meaning as in Article 121(1) of The Pensions (Northern Ireland)
Order 1995(d)
"proper advice", in relation to the Committee, means the advice of a person who is reasonably believed by it to be qualified by his ability in and practical experience of financial matters (including any suitable officer of the Committee);
(a) S.I. 1992/3218
(b) 1988 c.1
(c) S.R.& O.(N.I.) 1950
No.103
(d) S.I. 1995/3213 (N.I. 22)
"recognised stock
exchange" has the same meaning as in section 841(1) of the Income and
Corporation Taxes Act 1988;
"relevant institution" means -
(a) the Bank of England,
(b) an institution authorised under Part I of the Banking Act 1987(a) (regulation of deposit-taking business),
(c) a person to whom the restriction on acceptance of deposits in section 3 of that Act does not apply because he is specified in Schedule 2 to that Act (central banks etc.), or
(d) a European authorised institution which has lawfully established a branch in the United Kingdom for the purpose of accepting deposits;
"securities" includes shares, stock and debentures;
“statement of investment principles” means
the statement referred to in regulation 10(1) or any revision of it, as
appropriate.
"stock lending arrangement" means an arrangement such as is mentioned in section 263B of the Taxation of Chargeable Gains Act 1992(b);
"sub-underwriting
contract" means a contract with a person who is underwriting a share issue
to acquire the shares from him if he requires it;
"traded option" means an option quoted on a
recognised stock exchange or on the London International Financial Futures
Exchange;
(a) 1987 c.22
(b) 1992 c.12
"unquoted securities investment partnership" means a partnership for investing in securities which are normally not quoted on a recognised stock exchange when the partnership buys them.
3. - (1) Subject to paragraphs (2) to (9), in these Regulations "investment" and similar expressions have their normal meaning.
(2) The following provisions of this regulation specify things which count as investments for these Regulations, although they might not otherwise do so, and exclude things which might otherwise count.
(3) A contract entered into in the course of dealing in financial futures or traded options is an investment.
(4) An insurance contract is an investment if and only if the contract is made with a person within paragraph (5) for whom making the contract is business within class III or class VII in Schedule 1 to the Insurance Companies Act 1982(a) (linked long term and fund management business).
(5) The persons within this paragraph are –
(a) a person whom that Act permits to carry on such business, and
(b) an insurance company which, because it has its head office in an EEA State (as defined in that Act)(a), is permitted under the law of such a State to carry on insurance business of a similar sort.
(a) 1982 c.50
(6) A stock lending arrangement is an investment if and only if, in respect of it, the conditions in regulations 5.58 and 5.60 of Section L of the Financial Services (Regulated Schemes) Regulations 1991 are complied with, modified as specified in paragraph (7).
(7) The modifications referred to in paragraph (6) are -
(a) for the references in regulation 5.58 to section
129 of the Income and Corporation Taxes Act 1988 substitute a reference to
section 263B of the Taxation of Chargeable Gains Act 1992;
(b) delete paragraphs
1a, 1c(ii) and 2b ;
(c) for the references in both those regulations to the trustee, substitute a reference to the Committee; and
(d) for the reference in paragraph 1c(iii) of regulation 5.58 to Guidance of the Board, substitute a reference to Guidance Release 4/91 issued by the Securities and Investments Board in June 1991.
(8) It is an investment to contribute to a limited partnership in an unquoted securities investment partnership.
(9) A sub-underwriting contract is an investment.
(a)
For the definition of “EEA State” see section 96(1)of the Insurance Companies
Act 1982 (c.50), as amended by S.I.1994/1696, regulation 50(1)(g) and 1996/944,
regulation 4(3)(a)
4. - (1) This regulation describes those persons who count as an "investment manager" for the purposes of these Regulations.
(2) A person is an investment manager if he is authorised under the Financial Services Act 1986(a) to manage the assets of occupational pension schemes.
(3) A person is also an investment manager if he -
(a) does not transact investment business (within the meaning of that Act) from a permanent place of business maintained by him in the United Kingdom;
(b) has a head office situated outside the United Kingdom in a member State;
(c) is recognised by the law of that State as a national of a member State;
(d) is authorised under that law to engage in one or more of the activities specified in Part II of Schedule 1 to the Financial Services Act 1986 (which lists different sorts of investment business); and
(b) is not prevented by that law from managing the assets of occupational pension schemes or assets belonging to another person.
(4) A European institution carrying on home-regulated investment business in the United Kingdom is also an investment manager.
(a) 1986
c.60
5. - (1) This regulation specifies the sums which the Committee must pay or credit to and may pay from the fund.
(2) The Committee must pay or credit to the fund, in addition to any other sum the 2000 regulations specify must be paid or credited to the fund -
(a) the amounts payable by it or paid to it for the credit of the fund by employing authorities under regulations L5 to L7 of the 2000 regulations (employers' contributions),
(b) all members' contributions except
contributions payable under regulation C23 of the 2000 regulations (additional
voluntary contributions),
(c) all income arising during the year from investment of the fund,
(d) all capital money deriving from such investment, and
(e) all additional payments received by it under the 2000 regulations.
(3) Interest under regulations L5 to L7 of the 2000 regulations must be credited and paid to the fund.
(4) Any costs, charges and expenses incurred in
administering the fund may be paid from
it except-
(a) those
incurred in connection with a FSAVC scheme, and
(b) those costs and charges prescribed by regulations made under
Article 21,22 or 38 of the Welfare Reform and Pensions (Northern Ireland Order
1999(a)which the Committee is
enabled to recover by or under any such regulations.
(a) S.I.
1999/3147; see S.R. 2000 No. 142, S.R.
No. 335.
6. - (1) Instead of managing and investing fund money itself, the Committee may appoint one or more investment managers to manage and invest the fund money for it.
(2) The Committee may only appoint an investment manager if it complies with paragraphs (3) to (6).
(3) The Committee must reasonably believe that the investment manager is suitably qualified by his ability in and practical experience of financial matters to make investment decisions for it.
(4) The investment manager must not be an employee of the Committee.
(5) The Committee must be satisfied -
(a) that the fund is managed by an adequate number of investment managers; and
(b) that the value of the fund money to be managed by any one investment manager will not be excessive.
(6) The Committee must have taken proper advice.
7. (1) Investment managers must, if appointed, be appointed on the terms set out in paragraphs (2) to (7).
(2) The Committee must be able to terminate the appointment by not more than one month's notice.
(3) The investment manager must report to the Committee at least once every three months on the action he has taken for it.
(4) The investment manager must comply with all the Committee's instructions.
(5) Subject to paragraph (6) the investment manager in managing the fund must take into account
(a) that fund money must be invested in a wide variety of investments,
(b) the suitability of those types of investment for the fund,
(c) the suitability of any particular investment of that type, and
(d) the Committee’s statement of investment principles;
(6) Paragraph (5)(a) does not apply where the investment manager only manages part of the fund and the terms of his appointment provide that it does not apply.
(7) The investment manager must not make investments which would contravene the Committee’s statement of investment principles, regulation 12 or the Schedule.
(8) In determining the investment manager's terms of appointment, the Committee must take proper advice.
8. - (1) Where the Committee has appointed an investment manager it must keep his performance under review.
(2) At least once every three months the Committee must review the investments the investment manager has made.
(3) Periodically the Committee must consider whether or not to retain the investment manager.
(4) In reviewing an investment manager's decisions and appointment, the Committee must take proper advice -
(a) if regulation 7(5)(a) applies, about the variety of the investments he has made, and
(b) about the suitability of those
investments for the fund generally and as investments of their type.
9. - (1) The Committee must invest any fund money that is not needed immediately to make payments from the fund.
(2) The Committee may vary its investments.
(3) The Committee’s investment policy must be formulated with a view -
(a) to the advisability of investing fund money in a wide variety of investments; and
(b) to the suitability of particular investments and types of investments.
(4) The Committee must obtain proper advice at reasonable intervals about its investments.
(5) The Committee must consider such advice in taking any steps about its investments.
10.- (1) The
Committee must, after consultation with
such persons as it considers appropriate, prepare, maintain and publish a
written statement of the principles governing its decisions about investments.
(2)
The statement must cover its policy on-
(a)
the types of investments to be
held,
(b)
the balance between different types
of investments,
(c)
risk,
(d)
the expected return on investments,
(e)
the realisation of investments,
(f)
the extent (if at all) to which
social, environmental or ethical considerations are taken into account in the
selection, retention and realisation of investments, and
(g)
the exercise of the rights
(including voting rights) attaching to investments, if it has any such policy.
(3)
The first such statement must be published on or before 3rd July
2000.
(4)
The written statement must be revised by the Committee in accordance with any
material change in its policy on the matters referred to in paragraph (2) and
published .
11. - (1) The Committee may invest in any investment made in accordance with a section 11 scheme without any restriction as to quantity.
(2) A "section 11 scheme" is a scheme under section 11 of the Trustee Investments Act 1961(a) (which enables the Treasury to approve schemes for local authorities to invest collectively).
13. - (1) The limits which apply to certain sorts of investments are set out in the Schedule.
(2) The percentages set out in the headings in Part I of the Schedule are the limits on the amount of each description of investment listed under those headings.
(3) The percentages referred to in paragraph (2) are percentages of the total value of all existing investments in the fund before making the investment which is subject to the limit.
(4) The limits set out in the Schedule only apply at the time the investment is made.
(5) The exceptions to the limits are specified in Part
II of the Schedule.
Sealed with the Official Seal of the Department of the Environment on [ ]
(L.S.)
Assistant Secretary
(a) 1961 c.62
SCHEDULE Regulations 7(7) and 12.
LIMITS ON INVESTMENTS
PART I
1% limit
1. Any single sub-underwriting contract.
2% limit
2. All contributions to any single partnership.
5% limit
3. All contributions to partnerships.
10% limit
4. All deposits with a person specified in
paragraph 12 or 13 of Schedule 2 to the Banking Act 1987 and all loans (but see
paragraph 14).
5. All investments in unlisted securities of companies.
6. Any single holding (but see paragraphs 15 and 16).
7. All deposits with any single bank, institution or person (other than the National Savings Bank).
15% limit
8. All sub-underwriting contracts.
25% limit
9.
All investments in
units or other shares of the investments subject to the trusts of unit trust
schemes managed by any one body (but see paragraph 16).
10.
All investments in
open-ended investment companies where the collective investment schemes
constituted by the companies are managed by any one body.
11.
All investments in
units or other shares of the investments subject to the trusts of unit trust
schemes and all investments in open-ended investment companies where the unit
trust schemes and the collective investment schemes constituted by those
companies are managed by any one body (but see paragraph 16).
12.
Any
single insurance contract.
13.
All securities transferred (or agreed to be
transferred) by the Committee under stock lending arrangements.
PART II
EXCEPTIONS TO LIMITS IN PART I
14. The restriction in paragraph 4 does not apply to a Government loan.
15. The restriction in paragraph 6 does not apply if -
(a) the investment is made by an investment manager appointed under regulation 6, and
(b)
the single holding is in units or other shares of the investments subject to
the trusts of any one unit trust scheme.
16.
The
restrictions in paragraphs 6 , 9 and 11 do
not apply -
(a) to any investment falling within
paragraph 1 of Part I (National Savings) or paragraph 1 or 2 of Part II
(interest bearing securities, loans etc.) of Schedule 1 to the Trustee
Investments Act 1961, or
(b) to a deposit with a relevant institution.
PART III
INTERPRETATION OF PARTS I AND II
17. In this Schedule-
"Collective
investment scheme" has the meaning given in section 75 of the Financial
Services Act 1986(a)
"Companies" includes companies established under the law of any territory outside the United Kingdom.
"Government loan" means a loan -
(a) to Her Majesty's Government in the United Kingdom, or
(b) to the Government of the Isle of Man.
(a) 1986 c.60
"Listed securities" means securities quoted on a recognised stock exchange.
"Loan" does not include -
(a) investing money in registered securities to which section 1 of the Stock Transfer Act 1963(a) applies (transfer by stock transfer forms) or in listed securities, or
(b) depositing money with a relevant institution,
and "lent" must be understood in that way.
"Open-ended investment company" means an open-ended investment company as defined in section 75(8) of the Financial Services Act 1986 (b) which is an undertaking for collective investment schemes to which the Council Directive No. 85/611/EEC co-ordinating the laws, regulations and administrative provisions relating to undertakings for collective investment in transferable securities(c), as amended, applies .
"Single holding" means investments -
(a) in securities of, or in loans to or deposits with, any one body,
(b) in units or other shares
of the investments subject to the trust of any one unit trust scheme, or
(c) in transactions involving any one piece of land or other property.
"Unlisted securities" means securities which are not quoted on a recognised stock exchange.
(a) 1963 c.18
(b)1986 c.60
(c) OJ No. L 375,31.12.1985,p.3 –18 as amended by Council Directive
88/220/EEC (OJ No. L100, 19.04.1988, p.31-33).
EXPLANATORY NOTE
(This note is not part of the Regulations)
These Regulations provide for the
management and investment of the superannuation funds managed by the Northern
Ireland Local Government Officers’ Superannuation Committee .The provisions
were formerly dealt with in the Local Government (Superannuation) Regulations
(Northern Ireland) 1992(“the 1992” Regulations”) at regulations P2 and P3. The
1992 Regulations have been consolidated in the Local Government Pension Scheme
Regulations (Northern Ireland) 2000( S.R 177)
The principal amendments are -
(a) the inclusion, as investments, of insurance contracts with persons for whom making an insurance contract is business within class III in Schedule 1 to the Insurance Companies Act 1982 (linked long term business)(regulation 3(4));
(b) the inclusion of sub-underwriting as an investment with a limit on such investment in any single sub-underwriting contract of one per cent of the total value of the fund (regulation 3(9));
(c) a requirement for the Committee to prepare, maintain and publish a written statement of the principles governing its policy on investments of pension fund monies . The statement must cover the same matters as those the trustees of a trust scheme must include in the statement that they are required to prepare under section 35 of the Pensions (Northern Ireland) Order 1995. The statement must also include the Committee’s policy on the extent to which social, environmental and ethical considerations are taken into account (regulation 10); and
(d) the inclusion in the limit of 25 per cent of the total value of the fund of investments in open-ended investment company schemes (regulation 12 and the Schedule).
The Occupational Pension Schemes (Investment)
Regulations (Northern Ireland) 1996 (S.R. 1996/584), which impose restrictions
on the amount of the resources of an occupational pension scheme which may be
invested in employer-related investments, may further restrict or limit
investments of fund moneys. Those Regulations are made under powers conferred
by, amongst others, Article 40 of The Pensions (Northern Ireland) Order 1995
(restrictions on employer-related investments).
The
Financial Services (Regulated Schemes) Regulations 1991 referred to in
regulation 3(6) may be purchased from the Financial Services Authority (FSA),
25, The North Colonnade, Canary Wharf , London E14 5HS.
Amendments
2001 No.61 made 16 February
2001 Coming into operation on 2 April
2001
2001 No. 62 Made 16 February 2001 Coming into operation
2 April 2001.
Appendix C
Northern
Ireland Local Government Officers Superannuation Committee
Fair
Employment and Treatment (Northern Ireland) Order 1988
1.
Section 64 of
the Fair Employment and Treatment (NI) Order 1988 (“the order”) provided inter
alia that a public authority shall not accept an offer to execute any work or
supply any goods or services where the offer is made by an unqualified person
in response to an invitation by the public authority to submit offers. Section 64 also provides that the public
authority shall take such steps as are reasonable to secure that no work is
executed or goods or services supplied for the purposes of such contracts as
are mentioned above by an unqualified person.
2.
An unqualified
person is either an employer, who having been in default if the circumstances
specified under Section 62 (1) of the Order, has been served with a notice by
the Fair Employment Commission stating that he is not qualified for the
purposes of Section 64-66 of the Order or an employer, who, by reason of
connection with an employer on whom has been served a notice to the effect, has
also been served with such a notice.
3.
Mindful of its
obligation under the Order, the Northern Ireland Local Government Officers
Superannuation Committee has decided that it shall be a condition of tendering
that a Contractor shall not be an unqualified person for the purposes of
Sections 64-66 of the Order.
4.
Contractors
are, therefore asked to complete and return the Declaration/Undertaking, with
their quotation/tender, to confirm that they are unqualified persons and to
undertake that no work shall be executed or goods or services supplied by an
unqualified person for the purposes of any contract with the Committee to which
Section 64 of the Order applies.
Declaration/Undertaking
I/We hereby declare that
I am/we are not an unqualified person of the purposes of the Fair Employment
and Treatment (Northern Ireland) Order 1988.
I/We undertake that no work shall be executed or goods or services
supplied by any unqualified person for the purposes of any contract with the
Northern Ireland Local Government Officers Superannuation Committee to which
Section 64 of the Order applies.
Signed: ___________________________________
Duly authorised to
sign
For and Behalf of: ___________________________________
Dated: ___________________________________
Appendix D
List
of Bodies Consulted
NILGOSC
has compiled the following list of consultees for all matters with a special
emphasis on those who are affected by the pension scheme policies.
This
list was subject to consultation in 2000 and amended as a result.
The
list below is not exhaustive and may be amended in the light of experience.
List
of Organisations/Groups to Consult
|
Abbey Christian Brothers |
|
Abode Housing Association Limited |
|
Acorn Integrated Primary School |
|
Agricultural Research Institute of Northern
Ireland |
|
Antrim Borough Council |
|
Aquinas Diocesan Grammar School |
|
Ards Borough Council |
|
Ards Citizens' Advice Bureau |
|
Ark Housing Association Northern Ireland Ltd |
|
Armagh City & District Council |
|
Armagh College of Further Education |
|
Armagh Observatory |
|
Armagh Planetarium |
|
Arts Council of Northern Ireland |
|
Assumption Grammar School |
|
Ballymena Academy |
|
Ballymena Borough Council |
|
Ballymoney Borough Council |
|
Ballynafeigh Housing Association Limited |
|
Banbridge District Council |
|
Bangor Grammar School |
|
Belfast Charitable Society |
|
Belfast City Council |
|
Belfast Community Housing Association Limited |
|
Belfast Education & Library Board |
|
Belfast High School |
|
Belfast Institute of Further and Higher Education |
|
Belfast Royal Academy |
|
Belfast Visitor & Convention Bureau |
|
BIH Housing Association Limited |
|
Bloomfield Collegiate School |
|
Braidside Integrated Primary & Nursery School |
|
Bridge Integrated Primary School |
|
Campbell College |
|
Carrickfergus Borough Council |
|
Castlereagh Borough Council |
|
Castlereagh College of Further and Higher
Education |
|
Causeway Institute of Further and Higher
Education |
|
Cedar Integrated Primary School |
|
Child Care Northern Ireland |
|
Choice Housing Association Limited |
|
Christian Brothers Grammar School |
|
Citybus Limited |
|
Clothing and Industrial Training Services |
|
Coalition on Sexual Orientation |
|
Coleraine Academical Institution |
|
Coleraine Borough Council |
|
Coleraine Harbour Commissioners |
|
Committee on the Administration of Justice |
|
Community Relations Council |
|
Community Relations Council |
|
Connswater Housing Association Ltd |
|
Construction Industry Training Board |
|
Convent Grammar School |
|
Cookstown District Council |
|
Council for Catholic Maintained Schools |
|
Council for the Curriculum,Examinations |
|
Countryside Recreation Northern Ireland |
|
Covenanter Residential Association Limited |
|
Craigavon Borough Council |
|
Dalriada School |
|
Department of the Environment |
|
Derry City Council |
|
Derry Investment Initiative |
|
Derry Visitor and Convention Bureau |
|
Disability Action |
|
Dominican College |
|
Dominican College, Portstewart |
|
Donacloney Housing Association Ltd |
|
Down District Citizens' Advice Bureau |
|
Down District Council |
|
Drumragh Integrated College |
|
Dungannon & South Tyrone Borough Council |
|
East Antrim Institute of Further and Higher
Education |
|
East Down Institute of Further and Higher
Education |
|
East Tyrone College of Further Education |
|
Engineering Training Council (NI) Limited |
|
Enniskillen Integrated Primary School |
|
Enterprise Ulster |
|
Equality Commission |
|
Erne Integrated College |
|
Fermanagh College of Further Education |
|
Fermanagh District Council |
|
Filor Housing Association Limited |
|
Fire Authority for Northern Ireland |
|
Flax Housing Association Limited |
|
Fold Housing Association |
|
Fold Housing Trust |
|
Foyle and Londonderry College |
|
Friends School |
|
General Teaching Council for Northern Ireland |
|
Gingerbread |
|
Glenmona Resource Centre |
|
Gosford Housing Association |
|
Grove Housing Association Limited |
|
Habinteg Housing Association (Ulster) Limited |
|
Hazelwood College |
|
Hazelwood Integrated Primary School |
|
Hearth Housing Association Limited |
|
Help the Aged |
|
Hunterhouse College |
|
Integrated College Dungannon |
|
Jordanstown Schools |
|
Kingdoms of Down Tourism Ltd |
|
Lagan College |
|
Laganside Corporation |
|
Larne Borough Council |
|
Larne Grammar School |
|
Limavady Borough Council |
|
Limavady College of Further and Higher Education |
|
Linen Hall Library |
|
Lisburn City Council |
|
Lisburn Institute of Further and Higher Education |
|
Livestock & Meat Commission for Northern
Ireland |
|
Local Government Staff Commission |
|
Loreto College |
|
Loreto Grammar School |
|
Loughview Integrated Primary School |
|
Lumen Christi College |
|
Magherafelt District Council |
|
Malone College |
|
Methodist College |
|
Mill Strand Integrated Primary School |
|
Millennium Forum |
|
Millennium Integrated Primary School |
|
Mount Lourdes Grammar School |
|
Mourne Heritage Trust |
|
Moyle District Council |
|
New-Bridge Integrated College |
|
Newington Housing Association (1975) Limited |
|
Newry & Mourne District Council |
|
Newry/Kilkeel College of Further Education |
|
Newtownabbey Borough Council |
|
NI Anti-Poverty Network |
|
NI Association for the Care and Resettlement of
Offenders |
|
NI Council for Ethnic Minorities |
|
NILGOSC |
|
NIPSA |
|
North & West Housing Limited |
|
North Coast Integrated College |
|
North Down and Ards Institute of Further and
Higher Education |
|
North Down Borough Council |
|
North East Institute of Further and Higher
Education |
|
North Eastern Education and Library Board |
|
North West Institute of Further and Higher
Education |
|
Northern Ireland Association of Citizens' Advice
Bureaux |
|
Northern Ireland Committee ICTU |
|
Northern Ireland Co-Ownership Housing Association
Limited |
|
Northern Ireland Council for Integrated Education |
|
Northern Ireland Federation of Housing
Associations |
|
Northern Ireland Fishery Harbour Authority |
|
Northern Ireland Hospice |
|
Northern Ireland Hotel and Catering College |
|
Northern Ireland Housing Executive |
|
Northern Ireland Human Rights Commission |
|
Northern Ireland Legal Services Commission |
|
Northern Ireland Local Government Association |
|
Northern Ireland Local Government Officers' Superannuation
Committee |
|
Northern Ireland Railway Company Limited |
|
Northern Ireland Tourist Board |
|
Northern Ireland Transport Holding Company |
|
Oakgrove Integrated College |
|
Oakgrove Integrated Primary School |
|
Oaklee Housing Association |
|
Oakwood Integrated Primary School |
|
Omagh College of Further Education |
|
Omagh District Council |
|
Our Lady & St Patrick's College |
|
Our Lady's Grammar School |
|
Presbyterian Housing Association (NI) Limited |
|
Probation Board for Northern Ireland |
|
Rainey Endowed School |
|
Rathmore Grammar School |
|
RNID NI |
|
Royal Belfast Academical Institution |
|
Royal College of Nursing |
|
Royal School, Armagh |
|
Royal School, Dungannon |
|
Rural Development Council for Northern Ireland |
|
Rural Housing Association |
|
Sacred Heart Grammar School |
|
Saints and Scholars Integrated Primary School |
|
SHAC Housing Association |
|
Shimna Integrated College |
|
Slemish Integrated College |
|
South Eastern Education and Library Board |
|
South Ulster Housing Association Limited |
|
Southern Education and Library Board |
|
Sperrin Integrated College |
|
Spires Integrated Primary School |
|
Sports Council for Northern Ireland |
|
St Columb's College |
|
St Dominic's High School |
|
St Joseph's Adolescent Centre |
|
St Joseph's Grammar School |
|
St Louis Grammar School |
|
St MacNissi's College |
|
St Malachy's College |
|
St Mary's Christian Brothers |
|
St Mary's Grammar School |
|
St Mary's University College |
|
St Matthew's Housing Association Limited |
|
St Michael's College |
|
St Patrick's Academy |
|
St Patricks Grammar School |
|
Staff Commission for Education and Library Boards |
|
Strabane District Council |
|
Strangford College |
|
Stranmillis University College |
|
Strathearn School |
|
Sullivan Upper School |
|
The Official Publications Department |
|
Thornhill College |
|
Ulidia Housing Association Limited |
Ulidia Integrated College
|
|
Ulsterbus Limited |
|
United Dairy Farmers |
|
University of Ulster |
|
Upper Bann Institute of Further and Higher
Education |
|
Victoria College |
|
Wallace High School |
|
West Belfast Economic Forum |
|
Western Education and Library Board |
|
Windmill Integrated Primary School |
|
Woodvale & Shankill Housing Association
Limited |
|
Youth Council for Northern Ireland |
|
Youth Justice Agency For NI |
|
Youthnet |