Pension Trustee Code of Conduct

Promoting ethical best practices for pension plan trustees

The Pension Trustee Code of Conduct embodies 10 fundamental principles of ethical best practice for pension plan trustees. Compliance with the Pension Trustee Code of Conduct promotes a standard of professional excellence among a pension plan’s trustees and trust among the plan’s stakeholders. We encourage public and private industry pension plans, including corporations and unions, to adopt the Pension Trustee Code of Conduct.

What is Covered?

The Pension Trustee Code of Conduct outlines 10 fundamental ethical principles that are universally applicable to pension plan trustees:

Act in good faith and in the best interests of the plan participants and beneficiaries.
Act with prudence and reasonable care.
Act with skill, competence, and diligence.
Maintain independence and objectivity by, among other actions, avoiding conflicts of interest, refraining from self-dealing, and refusing any gift that could reasonably be expected to affect their loyalty.
Abide by all applicable laws, rules, and regulations, including the terms of the plan documents.
Deal fairly, objectively, and impartially with all participants and beneficiaries.
Take actions that are consistent with the established mission of the plan and the policies that support that mission.
Review on a regular basis the efficiency and effectiveness of the plan's success in meeting its goals, including assessing the performance and actions of plan service providers, such as investment managers, consultants, and actuaries.
Maintain confidentiality of plan, participant, and beneficiary information.
Communicate with participants, beneficiaries, and supervisory authorities in a timely, accurate, and transparent manner.

How Can a Pension Plan Comply?

Complying with the Pension Trustee Code of Conduct is voluntary. Pension plans that wish to adopt the Pension Trustee Code of Conduct should take the following steps:

Step 1

Compare the CFA Institute Pension Trustee Code of Conduct and Guidance for Compliance to your plan’s existing code of conduct to identify gaps and determine whether the plan’s current governance policies and procedures comply with the Pension Trustee Code of Conduct.

Step 2

Revise or establish policies and procedures as needed to align with the Pension Trustee Code of Conduct.

Step 3

Complete the fillable PDF Pension Plan Compliance Notification Form.

Pension plans must notify CFA Institute when they initially adopt the Pension Trustee Code of Conduct, and on an annual basis thereafter, by submitting the Pension Plan Compliance Notification Form. Annual submissions must be completed by 30 June each year with information as of the most recent 31 December, with the exception of contact information, which must be current as of the submission date.

How was the Pension Trustee Code of Conduct Developed?

CFA Institute developed the Pension Trustee Code of Conduct with a multinational coalition that included:

Council of Institutional Investors (United States)
Organization for Economic Cooperation and Development
National Association of Pension Funds (United Kingdom)
Swiss Association of Pension Funds
Hong Kong Retirement Schemes Association
Dutch Association of Industry-wide Pension Funds
Public comments were also solicited from all major global financial markets and stakeholders.

Pension Trustee Code of Conduct