Aviva IGC report – a new perspective?


Something happened at the Aviva IGC and I’m not at all sure why. Inder Dhingra has gone as chair and two of his colleagues have also left to be replaced by Colin Richardson of PTL who is the new chair. Colin has brought with him Gurmukh Hayre and Ian Baynes who are well known in pensions circles. This  leaves Marcia Campbell as the sole woman.

What has resulted is a hugely detailed report that runs to 56 pages but which has no clear focus. Rather than a new focus on VFM, I feel swamped by too much information and a report desperately needing a summary.


Chair’s statements tend to get read, they set the tone. Sadly this Chair’s statement is largely unreadable. I struggled with the syntax and the sense of Colin Richardson’s opening remarks

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Has this statement been proof -read?

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The prose is tortuous and the meaning is really hard to pick out.  Colin doesn’t speak like this so why is his statement so hard to understand.

Above his comments looms a navigation bar which opens out to 14 sections.

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Titles such as “security, data security and wider security” don’t exactly excite you to get to section 10, there is just too much stuff here and I fear that most people will struggle , as I did, to digest this statement.

This is a shame, there is a huge amount of really important work, especially in the ESG and investment sections , much of this looks like corporate reporting lifted directly into the report (in which case it could have better sat in appendices) and much of the comment within the report – which is from the IGC is clear and concise.

There is a good report in here, it’s like a garden overrun by bindweed, it’s fruits are hard to find!

In terms of the report’s capacity to engage members, I give it an amber, it’s worthy but it just doesn’t have the feel of getting read!

Value for money?

In order to claim as it does, to offer a fresh perspective on value for money, we need evidence. I don’t really see much new in here, though I’m encouraged that the good work done in the past on cost transparency is being continued. Legal and General could do with looking at the simplicity of Aviva’s approach to cost transparency in the appendix.

As with other reports this round, the lessons of the NMG report of 2017 are ignored and rather than focus on outcomes, the VFM statements are based on benchmarking of the product against rival products

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This is a marketing survey that simply tells us that Aviva are marketing better. It does not tell us whether Aviva customers are getting commensurately better outcomes. Nor does this table.

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The fresh approach to VFM looks very much like it’s directed at Aviva and its introducers rather than its customers.

In divided policies into currently and non- marketed with a 94:6 split, the IGC suggests that the deficiencies in the non-marketed proposition are relatively unimportant. This is a little disingenuous as the majority of Aviva’s non-marketed products aren’t workplace products and fall outside the scope of the report. It is the non-workplace legacy where most of Aviva’s high-charging products lie. Though the IGCs touched on this legacy in its work with the IPB, it has no remit to report on it here.

So the VFM assessment -which suggests that 94% of Aviva’s book is excellent or very good, is infact a partial assessment of the overall situation at Aviva where the number of “commission” charged products is a lot higher than in the workplace.

Impenetrable analysis

My comparison of the report to a garden overrun with bindweed is most apt in the sections of the report  looking at investment performance. The analysis here is of gross performance on the funds (rather than what members get as a return). The long sections on changes to asset allocation of the many Aviva defaults and the performance and volatility tables are interesting to an investment consultant (and look like they were cut and pasted from a consultant’s report) but they don’t help members understand how they are doing.

Over reliance on external benchmarking

Take this table, which I have spent some time on. I really do not feel any the wiser

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Why not let readers see how Aviva is performing against other providers and what is the point of producing a scatter plot which is quite unreadable (the green triangle is actually under the orange blob).

All this reliance on benchmarking for VFM purposes is a smokescreen, the IGC needs to be looking at the actual outcomes being achieved in its book against those of rival providers and deriving its VFM assessment from what has actually happened.

I suspect they know that, which is why they have stopped subscribing to one of the benchmarking services

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Whatever the purpose of telling policyholders this is beyond me. If benchmarking surveys can’t disclose who they are benchmarking, then something has gone very wrong, This happened with NMG and it appears to have happened again with Redington, this is not a fresh perspective on VFM but a realisation that this kind of VFM assessment is a dead end.

I am no clearer, having spent some time on this report, whether Aviva savers are getting considerably better or worse outcomes than other savers.  Something genuinely new needs to happen here as the current presentation of VFM is unintelligible. For all the information effort and ambition,  I can only give the VFM an amber.


An assessment of the effectiveness of an IGC is linked to the effectiveness of its reporting.  One of the sections of this report contains a table on on-line functionality which is dropped into this report like this.

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Nowhere in the report are we told what “Unisure”, “NGP” and “My money” are – so we can make nothing of the table other than the items of online functionality listed are what’s important to Aviva.

This is not effective communication and me moaning about working out what this table is doing is not an effective use of my or my reader’s time.

I am prepared to accept that the Aviva IGC is doing its job in chivvying Aviva along to reduce capital units for the under 55s, improve lifestyling and improve online functionality but I really don’t get a lot of confidence from this report.

I can only give the IGC an amber rating on its effectiveness; I have little evidence from the report that suggests to me that the IGC committee are as yet in a position to really exert control and change things for the better.


Aviva is a progressive life company that is committed to the workplace pension market and do a lot of good in areas such as ESG and technological advances. Aviva has, of all the major pension insurers, done most to embrace the new technologies. It has remained focussed on auto-enrolment and has had an excellent record of working with employers of all sizes. I personally feel that as an insurer, Aviva is giving value for money to those in its workplace pensions.

But this isn’t a great advert for Aviva’s governance. The IGC seems to be slipping backwards and looks like it could do with a new lease of life. Perhaps it will get it from Colin Richardson’s (chair) next report. I hope so.


About henry tapper

Founder of the Pension PlayPen,, partner of Stella, father of Olly . I am the Pension Plowman
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