REPUTATION MATTERS FOR PENSION TRUSTEES ISSUE 3 2014
Milestones at RMPP By Gerry Degaute
Smart DC - De-risking the de-risked By Jacqueline Lommen
The Pensions Regulatorâ€™s new objective - a gamechanger By Joanne Livingstone
Risk, the silent killer By Padraig Floyd
Planning for the recovery By Paul Jameson & Nicholas Badman
Plotting the course to port - the MNOPF buy-in By Andrew Waring
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“Risk comes from not knowing what you’re doing” Warren Buffett
Welcome to the third issue of MHP’s Reputation Matters for pension trustees. This edition broadly looks at derisking topics and what trustees should be planning for in 2014 and beyond. Gerry Degaute, previously CEO of Royal Mail Pension Plan, now Independent Trustee for Law Debenture, writes of the key milestones in his 26 year career there, culminating in the transfer to the Government of the RMPP’s historic liabilities and assets in 2012. Jacqueline Lommen, head of pensions at Robeco, looks at the advantages of Smart DC from her experience of all sides of the Dutch pensions industry. How trustees should respond to the change arising from the Pension Regulator’s new objective to minimise any adverse impact on the sustainable growth of an employer is the focus of the piece by Joanne Livingstone, Technical Director at Punter Southall.
Paul Jameson and Nicholas Badman of Penfida Partners anticipate how a sustained period of recovery could impact the behaviour of sponsors and how trustees of UK DB pension schemes can prepare for this. Long-term writer and commentator on pensions, Padraig Floyd, writes a hardhitting piece, describing the insidious effect of risk on pension schemes. And finally Andy Waring, Chief Executive of the Merchant Navy Officers Pension Fund, outlines some of the key lessons for trustees in a case study of their final buy-in in 2012. We hope you enjoy the read. As always we would welcome comments and suggestions on topics that would be of further interest to trustees. Wishing you all a happy and risk-free 2014 Nick Denton and Andy Fleming MHP Communications email@example.com firstname.lastname@example.org
MILEstones at rmpp By Gerry Degaute
I joined the Post Office (the former name of Royal Mail) in 1987. My role was to look after all the financial operations of the two pension schemes, being the Post Office Staff Superannuation Scheme (POSSS) which had recently closed to new members and its successor the Post Office Pension Scheme (POPS). POSSS owned 50% of an investment manager called PosTel, with the other 50% owned by the BT Pension Scheme. PosTel managed the majority of the POSSS assets which were of the order of £3 billion. POPS was in its infancy and it required development and implementation of its investment strategy and investment management arrangements. On 31 March 1995 POSSS sold its interest in PosTel to the BT Pension Scheme and PosTel changed its name to Hermes Investment Management. A key aspect of this deal was establishing investment management arrangements with Hermes. In 2000 with POSSS being a seller of investments and POPS a buyer, the schemes were merged to create the Post Office Pension Plan (POPP) which in due course was renamed the Royal Mail Pension Plan (RMPP) as it is still known today.
In July 2002 I became Chief Executive of RMPP and shortly afterwards took on the running of not only RMPP but also the other collective workplace pension arrangements of Royal Mail. RMPP, however, continued to dominate my time as the pressures of longevity and market conditions took their toll on the funding level. The 2006 valuation was challenging enough, revealing a £3 billion deficit with a 17 year recovery plan, albeit we secured a £1 billion escrow from a combination of the Employer and Government.
Hooper Review In December 2008 I was invited to Westminster to hear Richard Hooper launch his ‘Postal Services Review’ that had been commissioned by the then Labour Government. The Review stated that a package of three things all needed to be done of which one was to resolve the problem of the pension burden so that the Royal Mail could be fit for purpose to operate as a postal services provider. The Review begat the Postal Services Bill which subsequently was withdrawn in the summer of 2009 against a backdrop of credit crunch conditions impacting economies, corporates and markets. The 2009 valuation was work in progress and was undoubtedly going to reveal some very challenging results.
In the summer of 2010 the recently elected Coalition Government commissioned a refresh of the Hooper Review and then published their own Postal Services Bill. Whilst the Bill made its way through the Houses of Parliament, with great relish I supported my Chair of Trustees, Jane Newell, in providing evidence to the Public Bill Committee who gave scrutiny to the Bill. Jane gave a very powerful performance and ensured the Committee was in no doubt how the pensions element of the Bill, if enacted, would provide much greater security to the benefits of some 450,000 members and their dependants against the background of the fragile finances that existed. Meanwhile tPR looked on as our valuation filing revealed a deficit of the order of ÂŁ10 billion with a 38 year recovery plan; tPR required us to make it clear in our various member communications that they had serious concerns.
Largest Pension Fund Transaction The Bill was enacted in the summer of 2011 but that was not the end of the story. In order to implement the provisions of the Postal Services Act it was necessary to gain approval from the respective Commission of the European Union. The requisite approval was granted in late March 2012 which allowed the biggest project I had ever been involved in to move to implementation stage. At one second past midnight on 31 March the vast majority for the responsibility of past service benefits of RMPP transferred to Government together with assets approaching ÂŁ30 billion. Benefit security had been greatly enhanced for the members of RMPP, and tPR, I hope, removed RMPP from its elevated position on their risk register. Having achieved what I believe was the biggest pension fund transaction on the planet I decided to step down from Royal Mail Pensions Trustees at the end of May. After a 4 month break I started my part-time Independent Trustee career with Law Debenture, where I am enjoying life in a highly collegiate environment as part of a team of very knowledgeable, experienced and professional trustees, and I am looking forward to doing my bit to further enhance the governance of pension funds in the UK. Gerry Degaute is an independent trustee director at Law Debenture and was formerly Chief Executive of the Royal Mail Pension Plan.
Smart DC - de-risking the de-risked By Jacqueline Lommen
The trend towards the wider adoption of defined contribution (DC) pension schemes is gathering steam, and with good reason. Many employers are finding that defined benefit (DB) plans are increasingly unaffordable, and they want to take action by shifting pension risks away from their corporate balance sheets. Some de-risking possibilities already exist within the scope of DB of course – such as by transferring risk through buy-out or buy-in agreements with insurers. But this market is becoming saturated, and as the Solvency II Directive approaches, fewer insurers are either able or willing to take on the longevity risk or financial guarantee. Making a shift from DB to DC offers a great alternative to plan sponsors as it completely de-risks both the employer and the pension trust, putting the onus on the employee, who takes on the risk instead. So the question remains: how do you de-risk the de-risked? If employees are to take on the risks, how should we in the financial services industry protect them?
The transition towards DC – an unavoidable trend Let us first take a look at the main drivers for the shift from DB to DC. The introduction of the International Financial Reporting Standards (IFRS) means pension fund commitments (including deficits) must now run through the sponsor’s P&L, and show up as liabilities on the corporate balance sheet. With DC pension plans this is not the case.
Secondly, the European legislation on solvency buffers is affecting pension trusts. The second installment of regulations by the EU’s Institutions for Occupational Retirement Provision Directive (IORP 2) will lay down stricter rules. So, if DB pension promises made to employees and retirees are to be maintained and not cut, funding shortfalls can only be addressed either by greater contributions from employees, or a direct cash injection by the company. As both employers and employees try to save money as they battle recession and austerity, neither solution is particularly palatable, or sustainable, right now.
Smart DC – The Dutch answer to derisking So what to do? How to best solve the massive funding gap in DB schemes that is hampering overall GDP growth and endangering the financial stability of the Dutch economy? The Dutch are developing an innovative and future-proof DC scheme into which past DB rights can be converted. And this is where ‘Smart DC’ comes in. Making DC ‘smart’ basically touches upon three areas to make sure we can both mitigate the risks, and maximize the potential returns, for employees who go down this road.
Firstly, we really can’t expect the man or woman in the street to know what to invest in. It’s one thing to expect someone to take responsibility for planning for their retirement, and quite another to expect them to turn into a fund manager. Smart DC means offering solid default options that don’t leave the employee trying to choose between tens or even hundreds of different funds. At my company, Robeco, over 95% of participants in DC plans choose the default option to leave investing to professionals, so it’s clearly popular. Secondly, ‘Smart DC’ means making sure that asset allocation is aligned with the life cycle of the participant. More risky assets, with higher expected returns, for younger employees, will have a smooth transition over time towards an investment portfolio that aims at protecting the accrued capital as the retirement date is nearing. A smart element comes in when we tailor the asset allocation path for different groups of participants. A supplementary DC pension for high earning white-collar workers obviously needs a different investment portfolio than a basic pension provision for blue collar employees.
Thirdly, ‘smart’ DC solutions should include modern investment techniques. Extensive ALM and LDI expertise from the traditional DB world has been translated into innovative DC life cycling strategies. Our ‘two components’ investment strategy contains just two fundof-funds: a return fund (aiming at high returns) and a matching fund (aiming to minimize risk). Using just two sophisticated investment funds makes it easy to tailor the investment strategy to each corporate client. The other advantage of having only two investment funds is that they fully benefit from economies of scale; there is a low asset management fee. The unavoidable trend away from DB puts pension risks in the hands of individuals. I think pension providers should ensure that these risks are professionally managed. For me, smart DC is the way forward. Jacqueline Lommen is Head of Pensions at Robeco
The Pensions Regulator’s new objective – a gamechanger By Joanne Livingstone
What do Rugby League and pension scheme funding have in common? Last year has meant a change in the rulebook for both, with new interpretations of some of the existing rules and, in particular, changes to the way in which “advantage” is played out. We have seen several potentially significant developments that could strengthen the position of the employer in scheme funding negotiations. Relentless increases in deficits, in spite of large cash injections into defined benefit schemes, led to complaints by some employer organisations that the diversion of such large contributions into schemes was reducing corporate growth. The legislative response has been to give a new objective to the Pensions Regulator (tPR). The draft wording of the new objective requires that, in the exercise of its functions on scheme funding, tPR should “minimise any adverse impact on the sustainable growth of an employer”.
Early signals It remains to be seen whether this wording will pass unchanged through Parliament. Nonetheless, there is already considerable evidence that we are entering a new phase in the tripartite relationships between pension scheme trustees, their sponsoring employers and tPR, which has already shown a softer stance towards employers, following last year’s annual funding statement.
This statement, whilst only applicable to trustees and employers carrying out valuations with dates effective from 22 September 2012, clearly demonstrates a shift away from the supremacy of prudent technical provisions towards a greater focus on integrated risk management, combining understanding of covenant, funding and investment risks. The statement more clearly acknowledges the impact of current market conditions and signals a reversal of the statement made the previous year that basing the discount rate on a higher level of out-performance relative to gilts necessarily means a greater reliance on employer covenant. New rules of engagement will be spelled out over the coming year. So what will be the position of the various parties?
The Pensions Regulator The wording of the new objective has changed to the current version of: “minimising any adverse impact on the sustainable growth” from the original wording included in DWP’s call for evidence: “to consider the long-term affordability of deficit recovery plans to sponsoring employers”. Whilst the final wording may change it is clear that the new objective could, at times, be at odds with tPR’s existing objectives to reduce the risk of compensation being paid from the Pension Protection Fund and to safeguard members’ benefits. Promoting sustainable growth might
in the long term help strengthen the employer covenant, but only if the measures are successful. Given this increased risk to both trustees and the PPF, it is not surprising that tPR is increasing its focus on integrated risk management. Fewer than half the schemes surveyed for tPR’s Seventh Annual Governance Survey said that they fully integrated the management of their scheme risks.
Trustees The legislative requirement to pay heed to the sustainable growth prospects falls on tPR and is not a duty of trustees under the existing scheme funding legislation (nor is it intended to be). However, it is to be expected that the new Code of Practice will seek, in some way, to involve the trustees in considering growth alongside affordability. Faced with requests from sponsoring employers to agree to investment within the business, trustees might conclude that they are being asked to behave more as investors than as bankers, especially if there are no suitable assets for contingent charges and securities. Trustees of the majority of schemes not yet fully integrating their risk management will now need to carry out more work in this regard. They will also need to be able to demonstrate they understand all the risks they are facing, and have made informed decisions on funding that can be justified to tPR at a later date.
Employers Employers will hope that they have a new ally in tPR, thus making the valuation process potentially less painful. Employers will need to consider the business case they wish to present to trustees with regard to support for growth plans and to consider how much they are willing to incentivise the trustees with profit-sharing in the event that the sustainable growth is achieved. However, in order to make it more likely that the trustees can agree to more “employer-friendly” recovery plans, employers will need to play their part in helping to provide the necessary reassurance to trustees that the downside risk is manageable.
Conclusion Overall, we expect the proposed new objective to go against the direction of flow of regulation over the last decade by strengthening the position of the employer when it comes to funding negotiations. Whether or not trustees will find themselves hampered by this game-changing regulatory development, only time will tell. Trustees who respond to tPR’s exhortations to understand the totality of their risks may be better placed to cope with what lies ahead. Joanne Livingstone is Technical Director at Punter Southall
Risk, the silent killer By Pádraig Floyd
Risk is often defined as a situation that exposes one to danger or the possibility of financial loss. Two very good reasons why the general population consider it a bad thing. When left to their own resources, the ‘average’ punter will err on the side of caution. In a group situation, when presented with choices, that punter will select the middle path, believing, like Goldilocks avoiding extremes will get them where they want to go. This behaviour has been welldocumented within occupational pension schemes and you might reasonably argue this is where education comes in. You’d be wrong. There are of course excellent examples of employee communications driving up understanding and engagement with their retirement savings. But for every one of these, there are dozens where even the best intentioned, executed and even resourced projects, have fallen on stony ground. Of course, this was less important in the defined benefit (DB) age, because there were people charged with managing such concepts. That age, though not yet over, is passing. We seem to have accepted we can’t turn pension scheme members into mini-CIOs and this is driving the debate within the investment industry. And well it might, as the industry hasn’t always got it right.
Since the Myners review, pension funds in particular have turned a new leaf, safe in the knowledge “it can never happen again”. I remember hearing that a lot in the middle of the last decade, as schemes were sold – or advised to implement – liability driven investment (LDI) ‘solutions’. This new approach to derisking – at a basic level refusing to take risk in your portfolio that is unrewarded – seems eminently sensible, as does matching assets to liabilities. But it doesn’t hold all the answers – you still have to manage the return seeking assets effectively.
Investment Management Schisms And this is the problem with the investment industry. We’re told we’re all on the same team, yet the schisms that split those adhering to different management dogmas are at times Pythonesque. This results in far too much focus on single propositions as being the panacea, killer app, silver bullet or any other flaccid monicker you choose to apply. It’s not solely the industry’s fault, mind. It’s human nature to look for a single answer, not because there is purity in simplicity, but because we are essentially lazy. Like water, we will take the path of least resistance and if that means placing our faith in Jehovah, Camelot or Mourinho, so be it. In for a penny, in for a pound. Which is fine as long as you’re not gambling with someone else’s money.
With defined contribution (DC) it is someone else’s money – it belongs not to the plan sponsor, but every member of that scheme. DC is supposed to be all about the member, but the old DB mindset hasn’t quite got to grips with the new paradigm.
No Silver Bullet In the last five years, risk has been reappraised and there is confidence we not only know where it is, but how to monitor it and make it work for us. But we are still looking for a single solution to deliver the bulk of the ‘win’. In DB, it has been variously LDI and fiduciary management, which seems to get more than it’s share of coverage. Certain strategies, such as risk parity, balanced risk or total risk have had their moments, but have been rejected because they don’t wrap up enough of the portfolio to make them ‘worthwhile’. In DC, risk was all about getting sued or incurring the wrath of the regulator, as opposed to the structure of the investment strategy. In many cases, there rarely is any investment strategy, with diversified growth funds (DGFs) operating as a de facto bundled derisking tool.
There needs to be a total reappraisal of how we look at risk. DB will be with us for for many decades, because until sponsors can reach the derisking nirvana of buyout, they need to manage it. In DC, risk is managed on the ability to pay, or the ability of the sponsor to buy the right bundled package that will offer members value for money. It’s not enough to pin our hopes on a single solution to do the job, whether that’s DB or DC. That is where we’ve gone wrong in the past. Risk is an ever present and dynamic force within a portfolio, so to think we can manage it with a bolted-on DGF is patent folly. It’s time for sponsors with foresight to stop accepting what they (or their members) can afford and ask what the industry can offer. With prescription on the cards for DC, there is a real danger no investment strategies will ever deliver meaningful income to investors. Padraig Floyd is a freelance journalist and commentator on pensions.
Planning for the recovery
By Paul Jameson & Nicholas Badman
Since the credit crash of 2007-08, and the ensuing sovereign debt crisis and recession across Western Europe, UK DB pension schemes have been grappling with widening funding deficits caused by declining gilt yields and declining asset portfolios. Scheme sponsors were equally affected with declining performance impacting covenant valuations and affordability of scheme funding, combined with risk aversion, promoting deleveraging and cash accumulation. All in all, a perfect storm for trustees and sponsors alike. In recent months, however, we have seen a degree of yield reversion, asset price recovery and signs of a return of confidence and liquidity with an increasing appetite for risk, both from corporates and the providers of capital. If these factors continue, the immediate funding position of schemes on average may well improve, concern over the ability of the sponsor to underpin and contribute to the funding gap may diminish, but a new list of corporate finance issues, born of recovery, may well take their place on trustee agendas alongside funding, asset allocation and scheme management. These new corporate finance issues may include:
Sponsor investment initiatives As performance improves and risk appetites recover, sponsors that restructured and cut costs during the recession may now be looking to invest in and expand their businesses. If successful and aligned with scheme interests, such investment plans
should enhance the sponsor’s ability to support the scheme. However, trustees may well find themselves weighing the benefits of a stronger sponsor and a longer recovery plan. Finding the appropriate balance for the scheme in question will require the trustees and their advisers to have a good understanding of the sponsor’s business, the proposed expansion plans and the risk involved in such investments relative to the sponsor’s overall ability to support the scheme and the degree of risk being taken in the scheme asset portfolio.
Sponsor capital distributions Many sponsors have built substantial cash piles or materially deleveraged during the recent recession. Current market dynamics and increasing risk appetite may lead to higher dividend growth, more special dividends and / or share buybacks to meet market demand and / or for capital rebalancing. Total UK dividend payments (including special dividends) are at a five year high of over £80bn. Trustees will need to consider the impact of such distributions on the sponsor covenant available to the scheme and whether or not to seek an appropriate share of any distribution, having taken account of the appropriate balance between the sponsor’s various stakeholders, the impact on scheme risk and the recovery plan and the relative importance of servicing other sources of capital.
External corporate events Sponsors with inefficient capital structures, management vacuums or in industries in need of consolidation will all find themselves increasingly under the spotlight as the stronger players find ways of exploiting risk and deploying their capital. M&A volumes are increasing: including Vodafone’s $130bn disposal of its shares in Verizon Wireless. M&A deals involving UK companies hit a high of £120bn in Q3 2013 according to Dealogic, only bettered in Q2 2007, the peak of the pre-recession takeover boom. Such corporate transactions can have a material impact on a scheme covenant. Debt financed acquisitions may introduce competing creditors or impact on a scheme’s recourse e.g. where acquisition debt is secured against the sponsor’s assets ahead of the scheme. Schemes may find that a guarantee on which they rely no longer leads to the company holding the value in the Group. The impact can be exacerbated by post-transaction restructuring, with businesses being sold or moved elsewhere in the enlarged group for regulatory, commercial or fiscal reasons.
Many of our trustee clients are moving to accommodate these issues in their planning for the future. Whether considering sponsor investment, potential distribution policy or corporate initiatives, being prepared for such an event rather than waiting for the announcement before acting is optimal. There is often a need to react quickly and once such an initiative is announced, the sponsor’s room for manoeuvre to accommodate the pension agenda may be more limited. Trustees and their advisers can prepare in advance by discussing such issues with the sponsor, scenario analysis and action and/or defence planning where appropriate. In our experience trustee boards who are forward looking and who take the trouble to be prepared for the circumstances that might arise in particular economic and market environments are most likely to optimise the corporate agenda for their members. Paul Jameson & Nicholas Badman work for Penfida Partners, LLP
plotting the course to port - the MNOPF buy-in By Andrew Waring
Buy-in arrangements with insurers, though not always an option for less well funded schemes, hold numerous advantages for pension funds, their members and their sponsoring employers - notably:
funding level of 105% on a gilts basis over 10 years, with controlled derisking along the way. The journey plan set funding targets over a specified timeframe, together with agreed return targets and associated risk levels.
• Members get security of their benefits, which are provided by insurers regulated by the FCA, protected by the FSCS, and which have more stringent capital requirements than pension funds • Employers, in return for a one-off outlay, eliminate the financial burden of funding the pension scheme, along with the various risks associated with scheme sponsorship. • Trustees pass on various responsibilities – such as investment strategy – to the insurer, while retaining oversight of the scheme.
As part of this de-risking, the Fund transacted two successful buy-ins with Lucida, which covered 65% of the Old Section’s pensioner liabilities. During 2011, the Trustees, with expert third party advice, concluded that although good progress had been achieved in the Old Section’s journey plan, further funding from employers would be very difficult to secure, and the decision was taken to explore a further buy-in arrangement, covering the remaining Old Section liabilities, and aimed at ensuring all guaranteed benefits for members of the Old Section were secured. As the Old Section’s ability to raise further funding from sponsoring employers was very limited, any solution would need to cover all risks, including all potential liabilities such as any potential data issues, while also potentially providing a discretionary increase, in addition to the guaranteed benefits. It should also subsequently be able to be converted into a buy-out contract and then a full wind-up.
Established over 75 years ago, the Merchant Navy Officers Pension Fund (MNOPF) is an industry-wide scheme with assets of around £3.8bn and over 50,000 members, but only 900 ‘actives’. The Old Section of the Fund has some 23,000 pensioners and 16,000 deferred members, while the number of sponsoring employers has declined from some 3,500 to around 350 today.
Long-Term Journey Plan To adapt to this new landscape, MNOPF realised it needed to establish a long-term investment strategy which required greater use of specialist managers and alternatives to reduce risk through increased riskdiversity and asset diversification, and the establishment of an effective operational structure. Initially this involved a shift in investment strategy away from equities to fixed income. In 2008 a journey plan for the Old Section was agreed, targeting a
Improving Security Stringent selection criteria were applied to ensure the most appropriate insurance provider was chosen and a thorough validation of any insurance provider’s financial strength was conducted by an independent adviser. The process of selecting and negotiating a contract for buy-in was carried out by the Chief Executive and a dedicated Chairman’s SubCommittee (CSC) on behalf of the Trustee. Towers Watson, MNOPF’s fiduciary manager, advised on the selection process.
Following the selection process, completed in December 2012, the Trustee concluded an agreement with Rothesay Life to purchase an insurance policy for £680 million to cover the half of the members’ liabilities not already secured with Lucida. The insurance policy was written through the purchase of annuities and deferred annuities using the existing assets of the Old Section. The buy-in arrangement was agreed by the scheme trustee after a great deal of research, discussion and due diligence. It not only secured members’ benefits, it made them more secure, as insurers like Rothesay Life are regulated by the FCA, backed by the Financial Services Compensation Scheme, and have much more stringent capital requirements than pension funds. While hundreds of UK pension schemes have passed into the Pension Protection Fund, no insurers providing buy-ins have gone under, and the benefits have been secured in full. The Trustee continues to hold the insurance policies as assets of the fund and the only change affecting members is the enhanced security of their benefits, so the transaction is seamless from a member’s point-of-view.
Importance of Communications MNOPF used a range of communications tools, including nationwide roadshows, letters to members, notice board announcements via their website and media engagement, to communicate these benefits effectively to members. Particular emphasis was placed on security, the seamless nature of transition, continuity of Trustee oversight, and minimum dislocation for members. Historically the Fund relied upon the employers’ association and union for communications, but MNOPF now
adopted a direct approach to ensure fund members were aware of any further changes made to the scheme. This included an updated Fund website, a re-designed Annual Report and the MNOPF Employers Group. The Fund is also building ‘EIE’, an employer information exchange facilitating the confidential online exchange of data between the Fund and its employers. The feedback from the numerous nationwide forums suggests MNOPF members understand the rationale for the buy-in and are in agreement with it. The buy-in has been good news for MNOPF members. Having successfully secured the benefits of all members of the Old Section through insurance arrangements with Lucida and Rothesay, the Trustee is now examining the next logical step of this journey, namely buy-out and wind-up, when expenses for running the fund can then cease.
Key lessons for trustees • Importance of setting strategic objectives and long term journey plan to achieve overall derisking. • A governance structure that allows decisions to be made based on the facts at the time. • Achieving a sufficiently strong funding position at the point of buy-in. • Vital to a successful buy-in process is a strong communications programme, focussing particularly on keeping members well informed. • Strong administration support to achieve successful data-cleansing. • Thorough analysis of all options for buy-in to achieve pricing tension. • Review all potential risks and build into contract. Andrew Waring is CEO of The Merchant Navy Officers Pension Fund
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