Pension Trustee Code of Conduct

Comply with the Pension Trustee Code of Conduct

Code of Conduct for Members of a Pensions Scheme Governing Body

Read the Complete Code (PDF)

Overview of the Code

CFA Institute encourages pension plans to adopt the voluntary Code of Conduct for Members of a Pension Scheme Governing Body. By adopting the Code, you are establishing an ethical framework for governing board members and showing your commitment to the best interests of pension participants and beneficiaries. The code provides guidance to those individuals overseeing the management of the scheme regarding their individual duties and responsibilities and is not meant to replace the overall policies and procedures established for the governance of the pension scheme. However, to reflect best ethical practice, incorporating the fundamental ethical principles embodied in this code will enhance those policies and procedures.

Who Should Adopt the Pension Trustee Code?

The Pension Trustee Code should be adopted by:

  • Public companies
  • Governmental agencies
  • Unions
  • Pension schemes administrators

Plan participants and beneficiaries should ask their pension scheme managers to comply with the Code.

Ten Fundamental Principles of the Pension Trustee Code

The Code outlines 10 fundamental ethical principles, which are universally applicable regardless of fund type, for pension fund trustees:

  • Act in good faith and in the best interests of the scheme participants and beneficiaries
  • Act with prudence and reasonable care
  • Act with skill, competence, and diligence
  • Maintain independence and objectivity by, among other actions, avoiding conflicts of interest, refraining from self-dealing, and refusing any gift that could reasonably be expected to affect their loyalty
  • Abide by all applicable laws, rules, and regulations, including the terms of the scheme documents
  • Deal fairly, objectively, and impartially with all participants and beneficiaries
  • Take actions that are consistent with the established mission of the scheme and the policies that support that mission
  • Review on a regular basis the efficiency and effectiveness of the scheme's success in meeting its goals, including assessing the performance and actions of scheme service providers, such as investment managers, consultants, and actuaries
  • Maintain confidentiality of scheme, participant, and beneficiary information
  • Communicate with participants, beneficiaries, and supervisory authorities in a timely, accurate, and transparent manner.

Plan participants and beneficiaries should ask their pension scheme managers to comply with the Code.

Why Adopt the Pension Trustee Code?

  • Establishes an ethical framework for governing board members.
  • Shows your commitment to the best interests of pension participants and beneficiaries.

How Do I Comply With the Code?

Compliance with Code is voluntary and consists of adhering to the ten principles of the Code itself.

Why Did CFA Institute Develop This Code?

Because the managing pension schemes has become more complex, we developed the Pension Trustee Code to provide guidance beyond our Code of Ethics and Standards of Professional Conduct.

How Was the Code Developed?

CFA Institute developed the Pension Trustee Code with a multinational coalition that includes:

  • Council of Institutional Investors (United States)
  • Organization for Economic Cooperation and Development
  • National Association of Pension Funds (United Kingdom)
  • Swiss Association of Pension Funds
  • Hong Kong Retirement Schemes Association
  • Dutch Association of Industry-wide Pension Funds

We also asked for public comments from all major global financial markets and stakeholders.