The Trustee of the HSBC Bank (UK) Pension Scheme has considered the current situation in the Ukraine and has taken investment and legal advice.

The Trustee’s preferred policy position is that, at this time, the Scheme should not invest in Russian domiciled assets. 

The Scheme’s exposure to shares and bonds in Russian domiciled assets is very small (approximately 0.01% of the Scheme’s total assets). 
That exposure is all held within “pooled” investment products where the manager of each product controls its investment strategy and the Trustee cannot give directions to the manager about how the product’s assets are invested.  Nevertheless, the Trustee is engaging with those managers to actively encourage those managers to reflect the Trustee’s policy position as stated above.  At a minimum they will have to comply with relevant sanctions and the Trustee will be asking them to confirm that they are doing so.  The Trustee also expects that those managers will:
- not make any new investments in Russian domiciled assets; and
- use their discretion as to whether to sell existing investments if they conclude that it is appropriate to do so, but bearing in mind that it may not be possible to sell at present.  
The Scheme does not have any exposure to Russian domiciled assets through its investment managers who manage a direct portfolio of assets for the Scheme. In order to ensure that this remains the case, the Trustee is also instructing these managers, in line with its preferred policy position stated above, not to make any such investments until further notice from the Trustee.
The Trustee is keeping this issue under active review as the situation develops.