Our approach to transparency and sharing information
Each year the trustee shares a large volume of information with our stakeholders and others. We comply with our legal and regulatory duties to provide information. On top of this, we commit significant resources to publish a lot of additional information on a proactive and voluntary basis.
Despite this, we receive many additional requests for further information. These requests come from multiple sources, including our members, employers, and other stakeholders. These requests can consume significant time and resource over and above that which we already commit to sharing information.
We recognise that engaging effectively with our members, employers and other stakeholders is important. Therefore, we’ve created a policy to help us deploy our resources to respond to requests in the best way we can and in line with our roles and responsibilities.
How we respond to information requests
We aim to respond to information requests in a way which is fair, consistent, proportionate and cost-effective. We must also meet our duty of care to our employees. We prioritise getting information of broad interest to a wide range of members, employers and other stakeholders, over generating information that is likely to be of interest or relevance only to smaller groups or individuals.
The types of things we typically consider as part of our decision-making process are set out below:
- The interests of the scheme as a whole and our fiduciary duties, including our duty to protect confidential and/or commercially sensitive information.
- The reason for the information request and whether that is in line with the proper purpose of the scheme as a whole. As part of this, we consider the role, responsibilities and remit of the person or entity making the request. We also consider whether a request is repetitive and/or vexatious.
- Where the information being requested is not readily available and needs to be prepared, we assess the resource/cost of preparing the information and whether it is an appropriate and proportionate allocation of scheme resources. We also consider if it aligns with our value for money obligations. We may choose to impose reasonable cost limits when responding to requests.
We believe it is vital that we operate in an environment where people can think in private, have the freedom to properly explore ideas and engage in full and frank discussion in confidence, and we do not publish copies of our board and committee meeting papers, meeting minutes and/or advice from our advisers.
We take an overall portfolio approach to sharing information about USS’s investments. We will not typically respond to information requests to disclose information about individual investments. But we will be transparent about our portfolio level strategy, asset mix, geographical spread and confirmed sector exclusions by disclosing this type of information periodically on our website.
We consider all information requests on their own merit and reserve the right to apply a different approach in exceptional circumstances.