Implementation Statement guidance for trustees

PLSA Implementation Statement guidance for trustees


Our guidance and vote reporting templates provide practical support for trustees of both DB and DC/hybrid schemes around the production of their new Implementation Statements, where trustees must disclose how they have followed the objectives and policies set out in their Statement of Investment Principles.

The guidance sets out:

  • What the legislation requires and by when
  • Some high-level ‘general principles’ for implementation statements
  • More detailed possible considerations
  • Specific guidance on voting behaviour
  • Top tips for investment (and responsible investment) communication.

The guidance includes a specific chapter on how to produce clear, effective and meaningful disclosures on voting behaviour in the Implementation Statement. To help trustees take this next step after reading the guidance and gathering the relevant information, we have also produced templates and guidance for asset owners and asset managers. 

The asset owners' voting reporting template and guidance sets out:

  • An overview of the template
  • Where the template ‘fits in’ as part of the trustees’ broader work to scrutinise their managers’ voting behaviour undertaken on their behalf
  • The steps trustees need to take before presenting the template to managers
  • What information trustees will get from the template
  • How to use this information.

The asset managers' version, also available as an Excel file, contains guidance for asset managers on how to fill out the template, which may also be worthwhile for trustees and their advisers to read.

Although the primary purpose of following the guidance should be to ensure voting behaviour is consistent with the trustees’ investment objectives, any significant decisions which are taken by trustees using the structure below could also be used in any descriptions of trustees’ voting behaviour in their Implementation Statements.