The UK’s Pensions Regulator, TPR, issued new investment guidance for defined benefit pension schemes at the end of March 2017. A number of changes have been made to the guidance based on stakeholder feedback. The TPR guidance now includes expanded duties on stewardship, sustainability, ESG and voting issues.

The updated DB guidance follows the common principles set out in TPR’s DC investment guidance together with some specific considerations relevant to defined benefit schemes.

Since the Kay Review and the Law Commission’s report on fiduciary duties, there has been a need for clarity about the role of trustees on governance, sustainability and stewardship in general. TPR has brought together a very accessible and manageable framework for DB and DC schemes which we hope will foster and encourage greater understanding between asset owners and managers.

It is clear that the sustainability of pension funds over the long-term is inextricably connected with the sustainability of their investments. The new guidance goes a long way to bringing the connections between the two ever closer. It’s now up to all of us in the industry to help bring this about and we are ready for the challenge.

Key takeaways from the Guidance

  • Trustees need to consider environmental, social and governance factors if they believe they are financially significant.
  • Schemes are encouraged to consider their approach to stewardship, engage more with the stewardship policies of managers and, where appropriate, to follow the principles set out in the Stewardship Code.
  • Trustees should understand the stewardship policies of existing or prospective investment managers, and where appropriate, seek to influence them.
  • Where practicable, agree specific voting criteria with investment managers or consider potential managers’ willingness to abide by your preferred voting criteria when selecting investment managers.
  • Update statements of investment principles to include meaningful policies on long-term sustainability.  This potentially includes risks relating to factors such as climate change, unsustainable business practices, and unsound corporate governance.

Supporting DB Fund Stewardship

Minerva provides a range of services to support DB funds with their investment responsibilities.


Good stewardship includes the exercise of voting rights and assessing material sustainability governance risks inherent in the portfolio. Minerva’s GovernanceWatch services helps with the development of the stewardship components of your SIP, portfolio ESG risk monitoring; vote monitoring and reporting; and trustee training.

AMNT Red Lines Voting

To support DB funds wishing to implement some or all of the Association of Member Nominated Trustee’s Red Line Voting guidance, Minerva has developed the Red Line Monitor service. Trustees can create a bespoke policy for comparing their fund managers’ voting against each of the AMNT’s Red Lines as well as measure the overall impact of the Red Lines against their entire portfolio holdings.

Transition Pathway Initiative

Minerva also supports the implementation of The Transition Pathway Initiative which is focussed on understanding and addressing climate change risk and governance.

For more information about Minerva’s DB Governance & Stewardship solutions please contact us by telephone or email.

Telephone: +44 (0)1376 503500 | Email:

Last Updated: 11 January 2024