Investment, pooling and stewardship

Investment Pooling in the Local Government Pension Scheme (LGPS)

Investment Pooling within the Local Government Pension Scheme (LGPS) brings together pension funds to invest collectively, while each fund retains local accountability for funding decisions, member benefits, and employer relationships.

Under this model, Norfolk Pension Fund remains responsible for setting its own investment strategies and funding objectives. Our investments are implemented through a shared investment pool. This allows the Fund to benefit from greater scale, strong governance, enhanced investment capability and improved value for money compared to investing independently.

Norfolk Pension Fund to join LGPS Central Pool                                     

Since 2016, Norfolk Pension Fund has participated in the ACCESS LGPS Asset Pool. However, following recent Government Fit for the Future reforms requiring the management of pension fund assets to be delegated to a Financial Conduct Authority (FCA) authorised and regulated investment pool, Norfolk Pension Fund’s Pensions Committee made the decision to become a partner fund within LGPS Central Limited (LGPS Central), one of the six national investment pools established for the LGPS.

LGPS Central is owned by LGPS funds and is responsible for managing and investing assets of about £100 billion on their behalf, representing:

• 14 pension funds
• over 6,000 employers
• around 1.7 million members
  

LGPS Central is regulated by the FCA and works with its partner funds, including Norfolk, to deliver investment strategies.

From April 2026, LGPS Central comprise the following 14 partner funds:

• Cheshire
• Derbyshire
• Gloucestershire
• Hampshire
• Leicestershire
• Norfolk
• Nottinghamshire
• Oxfordshire
• Shropshire
• Staffordshire
• Suffolk
• West Midlands
• Wiltshire
• Worcestershire

This expanded partnership reflects the successful collaboration of funds including those previously part of other pooling arrangements, to meet the Government’s reform requirements.

Governance and How the Pool Operates

Strong governance is at the heart of how LGPS Central operates. In response to the requirements of Fit for the Future, the pool has reviewed its governance framework and updated its legal arrangements including putting in place new management agreements for all partner funds. 

While LGPS Central has met the Government’s Fit for the Future implementation requirements, the pool is operating under transitional governance arrangements.

These arrangements will stay in place until the final governance model is developed and agreed in collaboration with LGPS Central and partner funds, including Norfolk Pension Fund. 

The new governance model will be introduced in Autumn 2026. It will provide a robust and fair governance framework that reflects partner fund feedback and supports effective decision making. 

At the same time, LGPS Central is undertaking a phased transition of assets and services from legacy providers in a careful and sensible way, ensuring risks are managed appropriately and costs represent good value. 

Looking Ahead

Pooling is not just a one-off event but an ongoing process. As a fund, Norfolk Pension Fund continues to work closely with LGPS Central and other partner funds to strengthen collaboration across partner funds and deliver collective investment solutions. 

By combining scale, knowledge and strong oversight, LGPS Central aims to deliver sustainable, long-term value for employers and scheme members throughout the partnership. 

What it means for scheme members and employers?

For scheme members and employers, investment pooling:

• does not change pension benefits or administration
• does not affect the security of the LGPS

The Norfolk Pension Fund continues to act in your best interests, working with LGPS Central to invest assets responsibly and sustainably over the long term.

Climate change

Climate risk is a systemic risk that may have a material financial impact on a pension fund’s assets and liabilities. The Norfolk Pension Fund is committed to understanding and monitoring its exposure to climate related risks. The Fund has therefore introduced reporting on climate related exposures on a six-monthly basis across a number of key metrics and you can read our latest report here.   

Stewardship

The Norfolk Pension Fund is committed to demonstrating good Corporate Governance and Responsibility in its investment strategy. We recognise that as a large investor we have a responsibility to use our shareholder voting rights and support good governance in the companies in which we invest. Our overall investment strategy, including our voting policy, is set out in our Investment Strategy Statement with further information available in the Statement on Divestment/Exclusion & ESG (Environmental, Social & Governance) Aspects of Investment Strategy. 

We are members of the Local Authority Pension Fund Forum (LAPFF). The LAPFF exists to promote the investment interests of local authority pension funds, and to maximise their influence as shareholders whilst promoting corporate social responsibility and high standards of corporate governance amongst the companies in which they invest.

We publish details of our  Investment Holdings annually to coincide with our year-end (31 March). The Norfolk Pension Fund Annual Report and Accounts, published following the completion of the statutory audit in the autumn, includes additional detail and disclosure of our investment transactions.

Norfolk Pension Fund Voting

Norfolk Pension Fund voting is undertaken on our behalf by ISS (Institutional Shareholder Services) in accordance with our bespoke policy. For assets that are held in the ACCESS Pool, voting is undertaken by the Fund Manager in accordance with the ACCESS voting policy and collated by the pools operator Link Fund Solutions Ltd (Link).

We publish a record of our voting activity at company Annual General Meetings (AGMs) where the Norfolk Pension Fund has a holding. From 2019, voting records are supplied by ISS for non-ACCESS pooled assets and Link for all ACCESS pooled assets (add link to voting records on NPF website). The 2025 Q1-Q3 Voting Report can be viewed here and the 2024 Voting Report can be viewed here.    

Prior to 2019, voting records were supplied by ISS for all mandates except the Fidelity equity pooled funds. Details of the Fidelity voting record can be found here.

The voting activity of the Pension Fund is reported to Pensions Committee twice a year in quarters 1 and 3. Pensions Committee papers are available on the Norfolk County Council website.

Engagement

Managers have policies on responsible investment which include the issues on which they engage:

• Baillie Gifford & Co (the investment is made through the ACCESS Pool)
• Capital Group (the investment is made through the ACCESS Pool)
• Fidelity Pensions Management (the investment is made through the ACCESS Pool)
• Mondrian Investment Partners Limited (the investment is made through the ACCESS Pool)
• UBS Asset Management (UK) Ltd

The most recent reports to Pensions Committee are included in the public papers packs on the Pensions Committee page of the Norfolk County Council website which includes a summary of recent engagements.