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TPT Retirement Solutions

PRI reporting framework 2019

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage

New selection options have been added to this indicator. Please review your prefilled responses carefully.

01.1. Indicate if you have an investment policy that covers your responsible investment approach.

01.2. Indicate the components/types and coverage of your policy.

Select all that apply

Policy components/types

Coverage by AUM

01.3. Indicate if the investment policy covers any of the following

01.4. Describe your organisation’s investment principles and overall investment strategy, interpretation of fiduciary (or equivalent) duties,and how they consider ESG factors and real economy impact.

TPT's Investment Beliefs are as below:

1) Assets are held to pay benefits and should be invested taking account of the characteristics of these benefits

2) Risk should only be tolerated to the extent that the Trustee has confidence that the covenant of sponsoring employer(s) is sufficient to meet potential adverse consequences.  

3) Asset allocation is a more important determinant of returns than manager or stock selection.

4) The potential to achieve a higher investment return requires taking higher risk (uncertainty in future returns). 

5) Diversification of risk assets, both within and accross asset classes, reduces the variability of returns, both in absolute terms and relative to liabilities.

6) The real world is complex; judgement and qualitative research are important alongside quantitative analysis.

7) Illiquid assets, that provide sufficient reward to compensate for illiquidity, may be suitable investments. Sufficient liquidity to meet payments, including in stress scenarios, should be maintained.

8) Market opportunities to deliver returns in excess of an index may exist. 

9) Good governance improves the quality of investment decision-making. Transparency is an important enabler for good governance.

10) Responsible investment helps identify and mitigate risks. Responsible investment may also enhance portfolio returns.


01.5. Provide a brief description of the key elements, any variations or exceptions to your investment policy that covers your responsible investment approach. [Optional]

Making the Distinction - Responsible Investment is different to Ethical Investment.   Responsible Investment aims to identify financially materially ESG factors rather than seeking to exclude companies or sector based on moral and/or ethical beliefs. It is a set of top down policies that provide additional guidance to our investment decision making and oversight.  Of course, ethical investment builds on the foundation that our Responsible Investment approach provides, but adopts a negative screening with an accepted sacrifice on performance. 

TPT recognises that its charitable employers may want to align their investments with certain moral beliefs (largely as an exercise in reputational risk management) and has ethical solutions for employers on both the Defined Benefit (DB) and Defined Contribution (DC) side, however our core belief remains that positive engagement with companies remains the best way to gain positive outcomes.

01.6. Additional information [Optional].

I confirm I have read and understood the Accountability tab for SG 01 I confirm I have read and understood the Accountability tab for SG 01

SG 01 CC. Climate risk

01.6 CC. Indicate the climate-related risks and opportunities that have been identified and factored into the investment strategies and products, within the organisation's investment time horizon.

We factor climate-related risks and opportunities into our investment strategy.

The Investment Committee (IC) has formalised a set of principles to guide portfolio construction. These principles include the intention to reduce exposure to equities and to take more illiquidity risk. The principles are based on achieving the IC's risk return objectives and were also informed by its analysis of external risks and the findings of Mercer's climate change portfolio analysis.  In particular, the climate scenario analysis suggests:

  • The intention to reduce reliance on equity markets should reduce climate risk in the portfolio (subject to sector allocations) 
  • The intention to increase illiquidity and exposure to real assets may protect against 'existential risks' and help identify additional sources of return.

The key findings from the portfolio analysis mean that we prioritise the following objectives as part of our committment to manage the risks and opportunities related to climate change:

1. Continue to monitor and manage climate risk equities 

2. Try to quantify climate risk in alternatives

3. Identify & allocate to sustainable investments

The CIO and Investment Team are responsible for implementing the investment strategy, with the day to day investment management activities out-sourced to third-party fund managers.

The CIO and IC are assisted in forming capital market and other investment views (including portfolio composition, manager selection and monitoring of investment managers) by TPT's Portfolio Construction Group. The focus of the group includes amongst many other things, climate related risks and ooprtunities as they relate to TPT's investments.  

01.7 CC. Indicate whether the organisation has assessed the likelihood and impact of these climate risks?

01.8 CC. Indicate the associated timescales linked to these risks and opportunities.

TPT focus on assessing risk with a medium-term horizon, typically around 10 years. It believes that this strikes a good balance between 'longer-term' impacts, and an actionable window. It uses longer time-horizons (10 years +) to consider material systematic risks via the use of scenario analysis. However, it believes these are harder to address through asset allocation in the immediate future.  

01.9 CC. Indicate whether the organisation publicly supports the TCFD?

01.10 CC. Indicate whether there is an organisation-wide strategy in place to identify and manage material climate-related risks and opportunities.


As an asset owner, the most significant climate related risks and opportunities relate to the investments in the growth portfolio.  

Two results stand out from a multi-asset portfolio assessment under a Two Degrees scenario analysis undertaken by Mercer.

1. The negative impact on equities - the analysis indicated a negative impact on developed market global equities under a two degrees scenario of 0.82% negative annual impact on returns over ten years which is potentially material. 

2. Enhanced returns in real assets - The positive impact on returns from infrastructure and real estate, with potential additional returns of 0.76% p.a. and 0.45% p.a. respectively over 10 years to 2025. 


1.12 CC. Indicate the documents and/or communications the organisation uses to publish TCFD disclosures.

SG 02. Publicly available RI policy or guidance documents

New selection options have been added to this indicator. Please review your prefilled responses carefully.

02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.

02.2. Indicate if any of your investment policy components are publicly available. Provide URL and an attachment of the document.

02.3. Additional information [Optional].

TPT's Statement of Investment Principles

SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.3. Additional information. [Optional]

As TPT uses external managers, it is not considered necessary to have a conflicts of interest policy in its investment process. However, members of the Investment Committee are required to declare any personal conflicts of interest before making an investment decision.

SG 04. Identifying incidents occurring within portfolios

04.1. Indicate if your organisation has a process for identifying and managing incidents that occur within portfolio companies.

04.2. Describe your process on managing incidents

We receive notifications directly from our asset managers, from our investment consultant and other third party data providers. Primary responsibility for identifying and managing incidents that occur within portfolio companies sits with our asset managers but the Investment Team's oversight and monitoring role requires us to keep abreast of any developments which would impact the value of our assets and the performance of the portfolios. In the case that we identify incidents we would have a meeting with the fund manager to understand how they are managing the issue. These discussion are fed back to the Investment Committee in formal recommendation made on an investment manager's suitability.