Annual governance statement for South Mills Ltd Retirement Benefit Scheme (the “Plan”)

1. This governance statement is provided in accordance with The Occupational Pension Schemes (Charges and Governance) Regulations 2015. This governance statement covers the period from 6 April 2022 to 5 April 2023.

2. The law requires trustees to produce an annual governance statement for the Plan to be signed by the chair of the board of trustees – the “Chair’s statement”. The previous trustees did not issue a Chair’s statement within the applicable statutory period although LDTC does not consider it appropriate to incur the cost (which would be met from the assets of the Plan) of now preparing ones relating to earlier periods.

3. On 4 January 2018, The Pensions Regulator appointed Lyons Davidson Trustee Company Limited (“LDTC”) as the trustee of the Plan (“Trustee”) for the purpose of winding it up and securing the benefits of its members. LDTC intends to achieve this as soon as practicable but by no later than 31 January 2024.

4. The Plan entered winding up on 28 June 1990 (the last premium having been paid into the Plan on 31 March 1978). The Pensions Regulator is aware of this having appointed LDTC to specifically wind up the Plan. A detailed value for members assessment is therefore not required. A standard value for members assessment is not being undertaken as there are insufficient funds in the Plan to do so – all members’ benefits fall into the category of a “small pot” payment and as all members are of retirement age, they are being offered a one-off lump sum (small pot) in full and final settlement of their entitlement under the Plan.

5. LDTC has reviewed and assessed systems, processes and controls across the major aspects of the governance of the Plan. We have satisfied ourselves that these are consistent with those set out in The Pensions Regulator’s Code of practice 13 Governance and administration of occupational defined contribution trust-based schemes and with its formal guidance relating to pension schemes.

6. LDTC is now responsible for the investment of the assets of the Plan’s assets and for the conduct of the investment process. Although we shall keep it under review, our present intention is to maintain the existing approach to investment strategy until the formal termination of the trust of the Plan is completed.

7. LDTC is required to assess the extent to which member borne charges and transaction costs represent good value for members. Whilst the payment of fees and expenses exceeds the value of certain members’ benefits, these are the necessary costs in winding-up the scheme and are at a level approved by The Pensions Regulator.

8. Information concerning charges and transaction rates (the expenses of buying and selling investments in the Plan) payable by deduction from members’ retirement benefits is not readily available. Following the termination of the Plan members will become personally responsible for the investment of their entitlements. LDTC does not intend to pursue the issue of charges and transaction costs which will eventually be met by and under the control of members themselves. Similarly, LDTC considers it inappropriate to assess the extent to which the investment options and their effect on retirement benefits under the Plan represent good value compared to available alternatives as members will shortly be in a position to make such an assessment for themselves and control their investment strategy accordingly.

9. There are no records of any financial transactions involving the Plan in the period to which this Chair’s statement relates.

10. LDTC is a professional trustee. The members of its board and its senior personnel all have to meet prescribed standards for their continuing education and professional development. This means LDTC possesses, or has access to, sufficient knowledge and understanding to run the Plan effectively.

Director for and on behalf of
Lyons Davidson Trustee Company Limited

Date: 8 December 2023