Aviva’s IGC – more effective than its report suggests

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Aviva’s IGC has turned up and you can preview it here (it launches properly Monday)

It’s available as  a PDF  you can download here or you can read a digital version

Having read both, I’d suggest that the PDF works better, the digital version running to 82 screens is very difficult to navigate.

Tone and structure

The IGC Chair Colin Richardson is old school and it shows. Since the only way to get the IGC report is from the Aviva website, the idea of “going online’ is a little old fashioned!

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From the chair statement (final screen)

Of course, if you aren’t online when reading the document, clicking the yellow tab takes you nowhere. This clumsiness makes the tone of the report , a bit of a “Dad-Dance”.

This awkwardness continues in the phrasing of much of the text. In the communications section we are told

There is never an end to making communications clearer

Certainly there is scope to make that communication clearer. Similarly, this description of lifestyle is oddly clumsy. Investing in investments is clumsy and “bonds” leaves us hanging.. should we know what “bonds” are?

For those who are close to retirement the main funds reduce the amount invested in company shares and invest in other types of investments instead like bonds.

I decided to look bonds up in the jargon buster but it didn’t show.  It seems pernickety but I can assure you that if you read 82 pages/screens of this clumsy, inconsistent and old fashioned prose, you know how Hamlet felt when talking with Polonius.

One problem is the repetition. I think I counted six separate sections on Aviva’ s “Customer Transfer Programme”. Similar repetition occurs with references to the removal of charges for the under 55s in legacy and for Aviva’s efforts to integrate ESG.

The other problem is that Colin Richardson, for all his qualities – does not write very well and this puts the report – for all its digital endeavour – a poor read.

I’d also suggest that Aviva tone down the relentless supply of trendy digital images. We could do with some more factual diagrams and a lot less beards.

I’m giving the report an orange for tone and structure which is a shame as it has the highest production values of any report. A case of style being let down by substance.



The report arrived late but this does allow the Chair’s statement to include a thought through statement about Covid19 which spoke with an authenticity that I found touching.

The report includes a statement about Aviva’s Solvency Cover Ratio which at March 17th 2020

was approximately 175% which puts them in a very healthy position. This number does not allow for any increase in insurance claims or changes which may arise as a result of the coronavirus outbreak, and so we will be asking Aviva to keep us informed of any significant changes to this number.

It’s good to see an IGC report that is showing itself concerned with the solvency  issues that policyholders should be concerned with and it’s good to see it using up to date data.

Sadly, the performance figures are all to the end of December and large parts of the report could have done with a “refresh”

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For instance, the section on “identified risk events’ , doesn’t make any mention of whether a pandemic was one of them. Or was it one of the 14 events that were dismissed in 2019?

And I was disappointed to read a section on the AAF only to discover

The report for the year ending 31 December 2019 was not available at the time of writing, but we understand that work is well underway to finalise it.

Frankly an AAF on the post Covid-19 world is hardly the most relevant document to be studying in the middle of the pandemic.

That said, for all the omissions and repetitions, the IGC appears to have really got things done and the resume of what it achieved in 2019 and is setting out to achieve in 2020 are really good. They appear as sections 12 and 13 of the report and could better have been at the front.

There’s a relentless pursuit of improvement and (for once) I don’t mind the overt flattery as Aviva are genuinely ahead of the curve.

There is always much for pension providers to do – even those at the forefront of workplace pensions like Aviva.

The IGC appear to have some clout

Prior to issuing this report, the findings were discussed with Aviva’s Board.

I am giving the IGC a  green for effectiveness, their policyholders have much to thank them for.

Value for money

I am not so keen on Aviva’s value for money assessment. We know that what matters to “savers” is the outcomes of their saving. There is very little in this report about the experienced outcomes Aviva savers are getting. We are told the criteria for the assessment but given no detail of how Aviva stacks up on each and the result of the assessment – that Aviva is giving good value for money – is not grounded in much fact.

I appreciate that the IGC is prepared to take a view on the relative merits of Aviva’s My Future Fund and it’s greener brother My Future Focus Fund.

Our investment section outlines our view that the My Future Focus fund is the more attractive investment solution of the two main defaults taking all matters into consideration – but My Future continues to offer good value.

But there is no proper analysis in the investment section that helps me see why.

Where we are shown the analysis – such as the net promoter scores on the quality of transactions,  it’s hard to know what the calibration of “ambition” means

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I am not clear about this chart either. The service standard is 99/3 where 99% of issues are sorted in 3 days, but this chart seems to show an average time in which issues are resolved being around a week.  Where is the Ambition line here?

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I am also disturbed by some of Colin Richardson’s assertions. For instance

For those of you who don’t benefit from the charge cap, then by definition your charges will be higher.

There is no definition that says that the charge cap means lower charges. Not just are the words wrong but the sentiment is wrong.  Aviva should not be charging more when the charge cap allows them, they should be delivering value for money and the less the money the easier to provide value.

A similar issue relates to the strange section in which the IGC looks at the financial advice given by Aviva representatives on DB transfers. I know a little about contingent charging and I couldn’t make head or tail or this analysis.  We are that Aviva advisers charge customers 2.5% of the assets transferred (capped at £5,000)

The service operates on a non-contingent charging basis, which means once an agreement is signed by the customer, adviser activity is chargeable i.e. the customer will be charged for the personal recommendation whether that is to remain in their DB scheme or to transfer.

A view on whether a transfer is suitable or not is only given when a full analysis of the member’s circumstances, attitude to risk and objectives has been completed. The adviser recommendation is tailored to every member and must pass the ‘clearly’ test (clearly in the member’s best interests).

If following the analysis Aviva cannot offer the best destination outcome, then options will be explained, and the customer will not be charged

I highlight two statement that appear to contradict each other.  Which makes the statement on the 2.5% – very odd

This is an increase in fees over previous years, but the IGC believes it represents good value when compared to charges levied by other firms and independent advisers.

I am not sure if the IGC are really providing a value for money assessment at all. I do not think they are trying to pull the wool over our eyes, I just don’t think they properly understand what they are assessing.

I give the report an orange for its VFM assessment.

Overall view of the IGC’s activities

The IGC Chair Statement is – I suspect – a poor reflection of the IGC’s performance over the year. I suspect that the IGC is doing better than the quality of the report would suggest.

But as the report is so flamboyant in its presentation, I wonder whether it might not be time for the IGC to review my comments and think about member outcomes rather more and the digital glitz a bit less

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About henry tapper

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