Implementation Statement, covering the Scheme Year from 1 May 2021 to 30 April 2022

The Trustee of the Nelson Hurst Group Pension Scheme 4 (the “Scheme”) is required to produce a yearly statement to set out how, and the extent to which, the Trustee has followed the voting and engagement policies in its Statement of Investment Principles (“SIP”) during the Scheme Year. This is provided in Sections 1 and 2 below.

The Statement is also required to include a description of the voting behaviour during the Scheme Year by, and on behalf of, the Trustee (including the most significant votes cast by the Trustee or on their behalf) and state any use of the services of a proxy voter during that year. This is provided in Section 3 below.

1. Introduction

No changes were made to the voting and engagement policies in the SIP during the Scheme Year. The SIP in place as at the Scheme Year end was dated August 2020.

The Trustee has, in its opinion, followed the Scheme’s voting and engagement policies during the Scheme Year, by continuing to delegate to its investment managers the exercise of rights and engagement activities in relation to investments, as well as seeking to appoint managers that have strong stewardship policies and processes.

2. Voting and engagement

As part of its advice on the selection and ongoing review of the investment managers, the Scheme's investment adviser, LCP, incorporates its assessment of the nature and effectiveness of managers’ approaches to voting and engagement.

Should LCP become concerned about the way in which any of the investment managers were undertaking voting and engagement, they would notify the Trustee and suggest a course of action to take, which may include more detailed engagement with a manager to improve its policies or possibly to review the manager. Both LCP and the Trustee were comfortable with the managers that the Scheme invested in over the Scheme Year.

During the Scheme Year the Trustee received quarterly updates on ESG and Stewardship related issues from its investment advisers.

3. Description of voting behaviour during the Scheme Year

The SIP notes that the Scheme’s investments are held in units of pooled funds and one annuity policy. The Trustee therefore does not have any direct voting rights; any voting rights are indirect as they pertain to the underlying investments within the pooled funds and annuity policy. Hence, in effect the Trustee has delegated voting rights to the investment managers of the pooled funds and the annuity provider. The Trustee itself has not used proxy voting services over the Scheme Year.

Throughout the Scheme Year, the Scheme did not invest in any funds or annuity policies that held listed equities or assets with voting opportunities.