USS Submissions to Public Policy Consultations
USS Response to BIS Discussion Paper on Executive Remuneration, November 2011
USS responded to the UK government’s Department of Business Innovation and Skills (BIS) discussion paper on executive remuneration released in September 2011. The submission focused on our view that remuneration should be aligned with the long-term strategy of the company and overseen by an independent remuneration committee with transparent disclosures.
USS response to BIS Discussion Paper on Executive Remuneration Nov 2011
USS Responses to BIS Consultations on the Future of Narrative Reporting
USS responded to two consultations on the future of narrative reporting from the UK’s Department for Business Innovation and Skills - in October 2010 and November 2011. The consultations sought views on the Government’s plans to amend the narrative sections of company reporting, covering areas such as governance, audit, remuneration, strategy and disclosures on environmental and social matters.
USS response BIS Future of Narrative Reporting Consultation Nov 2011
USS Future of Narrative Reporting Consultation response Oct 2011
USS Response to the European Commission Green Paper on EU Corporate Governance Frameworks, July 2011
USS responded to the second EC green paper on the European corporate governance framework in July 2011. The submission focused on effective engagement between issuers and shareholders, and recommendations relating to the effectiveness of boards and remuneration.
USS response to second EC green paper
USS Response to the EC Green Paper on Corporate Governance in Financial Institutions, September 2010
USS submitted a joint response with Railpen Investments to the EC’s consultation on corporate governance in financial institutions and remuneration policies in September 2010. USS welcomed the opportunity to highlight support for the UK’s Walker Review and the UK’s corporate governance ‘comply or explain’ model. We also provided recommendations for the Commission to consider in relation to engagement with issuers, narrative reporting and remuneration.
USS/Railpen response to EC's corporate governance consultation
USS Response to FRC Consultation on revisions to the UK Corporate Governance Code, March 2010
In March 2010, the fund submitted a response to the December 2009 consultation from the Financial Reporting Council regarding the proposed revisions to the UK Corporate Governance Code. The fund was supportive of most of the proposals it called for strengthening of code recommendations on disclosure around board evaluations and appointments, enhanced investor consultation on remuneration and encouraged voting by poll. The fund expressed concern that the proposal to move away from triennial elections to annual director elections could promote short-termism and was unnecessary.
USS submission to the FRC consultation on the Revised Corporate Governance Code, March 10
USS response to FRC Consultation on the development of a UK Stewardship Code, March 2010
In April the fund responded to the Financial Reporting Council (FRC) consultation on the development of a Stewardship Code for Institutional Investors in the UK. The submission encouraged the FRC to promote stretching standards for investor engagement at investee companies. The fund highlighted its commitment to voting including voting at investee companies and the integration of engagement into the investment process and its view that stewardship responsibilities extend beyond UK publicly listed companies.
USS respsonible to the FRC Consultation on a UK Stewardship Code, March 2010
USS Response to Lord Myners Request, February 2010
USS responded to Lord Myners request for information on the fund’s engagement with UK banks in relation to remuneration decisions. USS welcomed the opportunity to outline the funds active engagement in this area and promote the adoption of more sustainable remuneration policies. Please find our full response below.
USS Response to Lord Myners 12 Feb 2010
USS response to 2009 Walker Review
In 2009, USS participated in the UK government HM Treasury led 2009 Walker Review of corporate governance of UK Banking Industry led by Sir David Walker. Before the Walker Review released its initial proposal for reform in July 2009, USS made a formal submission setting out key recommendations relating to remuneration, Board independence and expertise, board effectiveness, accounting standard concerns and other impediments to investors providing robust oversight for companies.
Following the release of draft Walker’s report we responded in August 2009 with a second formal submission offering concrete ideas for implementation of the Principles of Stewardship, remuneration structure, and board independence and expertise. We highlighted difficulties with implementing Walker’s proposed institutional investor MOU, and called instead for greater clarity from the FSA and Takeover Panel over regulations pertaining to “acting in concert” (see below). We also reiterated our concern over the accounting standard framework and emphasised our belief in a one share-one vote model of corporate governance. Our ideas were directly discussed with both Sir David and Lord Myners in private meetings. The final recommendations released by Sir David on 26 November 2009 reflected a number of our proposals.
USS letter to the UK Takeover Panel and Financial Services Authority (FSA) re Acting in Concert, 2009
In August 2009, the Takeover Panel (Practice Statement no. 26) and the FSA responded separately to Sir David Walker’s call for greater clarity on “acting on concert” regulation. While USS welcomed the Takeover Panel statement, the fund had a number of concerns with the FSA’s clarification. In November 2009, USS wrote a letter to the FSA setting out these concerns. USS received support for the letter from other institutional investors including Barclays Global Investors, RAILPEN Investments, F&C Management, Capita International Ltd., Local Authority Pension Fund Forum and Governance for Owners. The FSA responded to say that it recognised our concerns and set out preliminary thoughts on each of the points we raised. The FSA response also confirmed the FSA’s plans to conduct a consultation on the matter with institutional investors in early 2010.
USS Response to Personal Accounts Delivery Authority (PADA) Consultation
In August 2009, USS provided a submission to the PADA consultation ‘Designing an Investment Approach’, May 2009. USS focused its response on the responsible investment aspects of the discussion paper, highlighting the legal advice USS has received about responsible investment and fiduciary duty, the role of collaboration, and advocating the authority allocate internal resources for the implementation of an RI strategy and consider signing up to the Principles for Responsible Investment.