Value for money for members

The Trustee is required to assess the extent to which member-borne charges and transaction costs for the Scheme Year represent good value for members.

Overall, the Trustee believes that members of the Scheme are receiving good value for the charges and transaction costs that they incur as the assessment showed that members benefited from well-designed default investment strategies and a range of investment options as well as very low charges, amongst other benefits as summarised above.

The Trustee reviews all member-borne charges annually (including transaction costs where available), with the aim of ensuring that members are obtaining value for money given the circumstances of the Scheme. The most recent value for members review took place on 1 July 2022. The assessment was completed taking account of the Pensions Regulator’s Code of Practice No.13 (Governance and administration of occupational trust-based schemes providing money purchase benefits) and accompanying guidance.

There is no legal definition of ‘good value’ which means that determining this is subjective. The Trustee notes that value for money does not necessarily mean the lowest fee, and the overall quality of the benefit received by members was also considered in this assessment. The assessment was undertaken with assistance from the Trustee’s DC advisor and involved a wide assessment of value considering the key elements of the Scheme and agreeing relevant value ratings for each area, in addition to looking at the value attributable to member-borne costs and charges.

Trustees assessment of value relating to member borne charges and transaction costs

The Bank covers the administration and DC fund management charges, therefore the member-borne charges are limited to additional DC fund expenses and transaction costs for the DC funds. which the assessment found compares very favourably to other DC schemes.

The Trustee’s investment advisors have confirmed that the additional expenses paid by members for the DC funds are competitive for the types of fund available to members. Members pay significantly less than members in other schemes as they only pay the additional expenses element for the DC funds. The Trustee also assesses the value of the total charges of the investment options (including charges met by the Bank) and found these to also be very competitive compared to other DC schemes.

In carrying out the value assessment, the Trustee also considered the wider benefits members receive from the Scheme, which include:

  • the oversight and governance of the Trustee, including ensuring the Scheme is compliant with relevant legislation, and holding regular meetings to monitor the Scheme and address any material issues that may impact members;
  • the design of the default arrangements and how this reflects the interests of the membership as a whole;
  • the range of investment options and strategies;
  • the quality of communications delivered to members;
  • the quality of support services such as the Scheme website where members can access DC fund information online; and
  • the efficiency of administration processes and the extent to which the administrator met or exceeded its service level standards.

The following table sets out the summary of how the Trustee has assessed value.





Very Good

Most of the Scheme’s costs are covered by the Bank, with only transaction costs and additional expenses borne by the member. Charges paid by members are therefore extremely competitive when compared to typical fees paid by members in other large DC schemes.

Scheme Administration


The agreed service levels for achieving a task are generally shorter than the standard levels in the market place, and these are achieved in the majority of cases for members with DC benefits. The Trustee reviewed monthly performance reporting on key processes, transactions and complaints. Any issues and anomalies identified were followed up with the administrator for explanation. The Trustee held weekly service meetings as well as monthly meetings with the administrator to review and assess service performance, discuss issues, and progress on project related activity. Any issues identified by the PSE as part of its oversight were raised with the administrators immediately and steps were taken to resolve the issue. From May 2022, Equiniti replaced WTW as the Scheme administrator for members with Hybrid and DB benefits. The move to Equiniti is expected to lead to improvements in the quality of service received by members with Hybrid benefits over the next two to three years. Equiniti’s performance was initially lower than expected but the Trustee continues to over see process improvements in order to ensure this continues to improve.

Scheme Management and Governance

Very Good

The Trustee has a high level of knowledge and engagement in managing the Scheme, resulting from a comprehensive training programme, supported by a strong team in the PSE and access to professional advisors.


Very Good

A wide suite of communication tools and resources are offered to Scheme members which is continually reviewed. New communications and actions were implemented over the Scheme year, including (but not limited to) new pages on Future Focus for new joiners and retirement options, as well as a be spoke mid-career ‘MOT’ including a simple interactive guide and checklist to help members take control of their retirement savings.

At Retirement

Very Good

Throughout 2022, the Trustee worked on a post-retirement solution for Scheme members, which was launched in October 2022. The Trustee implemented a simplified Application form, educational videos on the different ways that members can access their pots and tailored retirement seminars which cover the options members have at retirement, including the post-retirement sign posted solution.

Default arrangement

Very Good

Different defaults are available to different cohorts of members, recognising their different requirements.
The default arrangements were reviewed during the Scheme year as part of the annual performance and strategy review, which took place in June 2022. Based on the outcome of this annual review, the Trustee concluded that the default arrangements have been designed to be in the best interests of the majority of the members invested in them and reflect the demographics of those members. This level of review is performed on an annual basis, with a detailed, formal triennial investment strategy review carried out every three years. The 2023 review is underway, outside of the Scheme year covered by this statement.

Self-select investment range

Very Good

The Scheme offers a good range of DC funds covering all the main asset classes with active and passive options and the option to invest in targeted strategies designed for members who plan to use their DC pension pot to provide a flexible income (e.g. income drawdown), or for annuity purchase or a cash lump sum (reflecting the three broad choices members have at retirement).

Scheme design

Very Good

Employer contributions are generous when compared to the market, with total contribution rates exceeding the industry benchmarks. Quarterly Governance dashboards are provided to the Trustee for review, with a focus on the cost-of-living crisis and rising levels of inflation during this Scheme year, including close monitoring of changes to members’ contributions. The analysis shows that members continue to engage with the Scheme.


There are a small number of members invested in a relatively large number of legacy AVC arrangements. These legacy AVCs only account for a small proportion (less than 0.1%) of the total DC assets within the Scheme and these investment options are no longer open to contributions. Therefore, the Trustee has taken a proportionate approach to reviewing them, compared to the other DC benefits within the Scheme.

The Trustee carries out regular reviews (at least every 3 years) of its legacy AVC arrangements with the last review undertaken during the Scheme Year being on 10 June 2021. This review highlighted no material concerns with the AVC arrangements and confirmed it would be in member’s best interests to remain with these providers rather than be transferred into an alternative arrangement as this would result in a loss of guarantees or high exit charges.

The Trustee continues to close ‘empty’ legacy AVC policies and remove funds with no remaining members as and when these are identified. As members in these AVC arrangements have fewer investment choices and pay higher fees in comparison to the main DC assets, the Trustee will continue to communicate with members to make them aware that they might benefit from moving their AVC assets to funds in the main DC investment platform with Fidelity.

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More information

Default investment strategy 

The Trustee has made available a range of investment funds for members. Each member is responsible for specifying one or more funds for the investment of their account, having regard to their attitude to the risks involved. If a member does not choose an investment option, their account will be invested into the default option applicable to them, which is managed as a “lifecycle” strategy (ie it automatically combines investments in proportions that vary according to the time to retirement age). The lifecycles are 100% invested in equities until twenty years from a member’s target retirement age from which point they transition gradually into less risky assets appropriate to the outcome targeted.

Member Charges 

The Trustee is required to set out the charges incurred by members during the Scheme Year in this Statement. As the sponsoring employer pays the DC investment fund annual management charges, platform expenses and all other administration expenses, the member borne charges are limited to the additional fund expenses incurred by the underlying managers in the day-to-day running of the funds (for example, custodian fees etc), with the exception of some legacy AVCs funds

Illustration of charges and disclosures costs 

The Sponsoring employer currently pays the AMC platform expenses and administration costs. Additional expenses (“AE”) are covered by members and are those costs incurred in the management of the underlying funds which are, by nature, flexible and therefore fall outside of the AMC. The Trustee has provided an illustration of the impact of the charges and costs on members pension pots for the default options and four funds from the Freechoice range.