NORTHERN IRELAND LOCAL GOVERNMENT OFFICERS’ SUPERANNUATION COMMITTEE

 
NILGOSC

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

Fax                     028 9076 8790

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

 

 

 

Page

 

1.

Introduction

4

2.

What is NILGOSC?

4

3.

The Policies Under Review

5

4.

Consideration of Available Data and Research

8

5.

Assessment of Impacts

8

6.

Consideration of Alternatives or Methods of Mitigation

10

7.

Formal Consultation

10

8.

Policy Decision Following Consultation Exercise

11

9.

Publication of Results

11

Appendix A

Statement of Investment Principles

12

Appendix B

Local Government Pension Scheme (Management and Investment of Funds) Regulations (Northern Ireland) 2000

 

20

Appendix C

Fair Employment Declaration

41

Appendix D

List of individuals and Bodies to be Consulted

42

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

info@nilgosc.org.uk

 


 

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

         Phone:               028 9076 8025

         Fax                     028 9076 8790

         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

  

Appendix A

 

Statement of Investment Principles

 

INTRODUCTION

 

Purpose of statement

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).

 

Advice

The Committee has obtained written advice on the content of this statement from Hewitt Bacon & Woodrow Limited, the Fund’s actuaries and investment consultants.

 

Consultants

The Committee has consulted its fund managers about the content of this statement.

 

Investment Powers

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.

 

 

SCHEME INVESTMENT OBJECTIVE

 

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

 

 

COMPLIANCE WITH STATUTORY FUNDING TARGET

 

Funding Target

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

 

Process for 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). 

 

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.  

 

Property

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.


 

Investment policy

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.

 

Delegation to fund managers

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.

 

Performance objectives

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. 

 

Expected returns

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.

 

New investments

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. 

 

Realisation of investments

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.

 

Number of managers

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.


 

Risk versus the liabilities

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.

 

Custody

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.

 

Manager restrictions

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.

 

Manager controls

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

 

Frequency of review

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.

 


 

Professional advice

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

 

 


STATUTORY RULES OF NORTHERN IRELAND

 

 


2000 No. 178

 

PENSIONS

 

Local Government Pension Scheme (Management and Investment of Funds) Regulations (Northern Ireland) 2000

 

 Made     .     .     .     .     .     .     .     .             19th May         2000

Coming into operation   .     .     .     .                        1st August       2000

 

ARRANGEMENT OF REGULATIONS

 

Preliminary

1.       Citation and commencement.

2.   General definitions.

3.       Definition of "investment".

4.       Definition of "investment manager".

Management of the  fund

5.       Management of the fund.

6.       Choice of investment managers. 

7.       Terms of appointment of investment managers.

8.       Review of investment manager's performance.


 

Investments

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.

SCHEDULE

 

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: -

 

Preliminary

 

Citation and commencement

 

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.

 

General definitions

 

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.

 

Definition of "investment"

 

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)

 


Definition of "investment manager"

 

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

 


Management of the fund

 

Management of the fund

 

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.

 

 

Choice of investment managers

 

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.

 

Terms of appointment of investment managers

 

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.

 

Review of investment manager's performance

 

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.

 

Investments

 

Use and investment of fund money

 

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.

 
 
Statement of investment principles

 

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 .

 

Investments under section 11 of the Trustee Investments Act 1961

 

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).

 

Restrictions on investments

 

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

 

Fair Employment Declaration

 

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