The opinion of the Accountability Council

The Accountability Council’s Assessment of 2022

The Accountability Council (AC) concluded for 2022 that it received a lot of advance information, was updated on policy intentions and decisions, or in the case of advisory rights, on proposed decisions.

The Board largely implemented recommendations made by the AC or these are in progress. With respect to the priorities identified by the AC, we note that progress on the Future Pensions Act (WTP) transition was delayed despite the Board’s pressure on social partners in 2022. However, a detailed version of a draft action plan for the Future Pensions Act transition was published by the end of 2022, identifying all steps to be taken including the associated stakeholders. The management actions mentioned by the fund in its own risk assessment (ERB) were not entirely implemented in 2022. Communications about awarding indexation required constant attention, particularly concerning managing expectations among members and deferred members.

The Accountability Council’s opinion is based on the argumentation expressed in the proposed or final decisions, as well as on the conclusions that the Accountability Council draws from its consultations with the Board and Executive Board, management team, and the Supervisory Board. The Accountability Council also forms its opinion by studying all relevant fund documents and periodic reports as well as the draft and final management report and financial statements. To reach a sound judgement, the Accountability Council uses a review framework developed in 2021.

While the Accountability Council found that the Board’s decisions in 2022 were balanced, it is important for the Accountability Council to gain greater prior insight into how the Board usually makes a choice between various options and scenarios and what frameworks are used as a basis from which to arrive at a final choice in a reasoned manner. A choice that can be explained on this basis may improve acceptance among deferred and current members who would have preferred a different outcome. Such a framework helps to assess how balanced the decision in question is. The information that the Board sends to the Accountability Council in requests for advice is supposed to give the Accountability Council insight into the considerations made by the Board. On the Accountability Council’s insistence, during 2022 the Accountability Council received not only a background paper outlining the request for advice but also the decision document setting out the considerations that the Board would make. The Accountability Council asks to continue working in this way.

Recommendation

Specify the criteria for a balanced consideration of interests, and develop a framework that can be used during decision-making to provide reasoned and documented evidence for balancing considerations. Criteria can also be ranked by degree of priority.
As a standard procedure, send the decision document discussed by the Board, including any appendices, along with the request for advice to the Accountability Council. Make sure that the information is also specific enough to bridge any information gap between the Accountability Council and the other fund bodies.

Summary evaluation

In the AC’s opinion, the policy adopted by the Board and the decisions taken by the Board in 2022 were in the interests of members, deferred members, and pensioners. In taking decisions, the Board explicitly considered the interests of all stakeholders in its decision-making process. When taking important decisions, the AC recommends that more information is made available on how the Board reached a balanced weighing of interests, and on what policy or policy framework and criteria the Board reached its decisions. There should also be more focus in the fund’s communications on explaining the decisions reached and how, when weighing the various interests, the Board made balanced choices for all stakeholders.

Recommendations

The AC is making the following recommendations, based on its findings:

Strategic Developments

Clarify which strategic options are available to PDN after the Future Pensions Act transition, taking the developments at the employer and the affiliated companies into account.

Governance

Evaluate whether the Board’s new working method, introduced in 2022, is performing well.
Although the operational Board members are now the primary contact point for the AC, the AC is committed to continuing the current working method in which the Chairman and other Board members are scheduled to participate in the AC meetings.

Pensions

Continue to provide members and deferred members with clear and accessible insight regarding the extent to which certain policy choices, as well as external developments (interest, life expectancy), can or have influenced the funding level and the possibilities for indexation.

Communication

In communications, do not only focus on communicating the outcomes of decisions taken but also engaging members and deferred members in the Board’s weighing of interests and in the relevant argumentation.

Investments

Continue working on providing easy-to-understand information on sustainability policies relating to investments.

Risk Management

Implement the actions stated in the ERB on time and periodically evaluate whether the timing of the planned actions is still appropriate.
Conduct periodic monitoring of the outsourcing risk in connection with services provided by external parties, particularly DPS.

AC Priorities for 2023

The most important priorities on which the AC aims to focus in 2023 are:

Progress of the Future Pensions Act transition process including specific knowledge acquisition on the AC
Progress of the study regarding the fund’s future vision
The new pension administration agreement, which is to be finalized as of January 1, 2024.