Scottish Widows’ IGC report – a hard boiled egg

I prefer my eggs a little “runny”.


The Scottish Widow’s Independent Governance Committee Annual Chair’s Report 2020/21 ( is almost a curate’s egg. It shows the IGC taking their job very seriously and it is member-centric. It has a lot of good information within it. On the other hand, it omits a lot of the information that members are interested in, especially about investment performance and it is skimpy at best about the range of charges offered within the various workplace products within the group.

It is a very tricky read as the 48 page PDF is hard to navigate and not an easy online experience. The tone of the document is deliberate and authoritative but at times long sentences make teasing out the points being made, difficult.

I suspect that this IGC is particularly effective in its dealings with its insurer. The sections on governance suggest that the IGC is properly engaging with the sponsoring bank (Lloyds Banking Group) and I’m pleased to see that the IGC is not assuming that claims made by the insurer for the future are going to happen. Take this statement on Scottish Widows well publicized commitment to carbon neutrality within its investment portfolios

The IGC is encouraged by these developments and
the focus the company has placed on responsible
investment this last year, fully integrating responsible
investment and ESG policies across its processes,
but we have asked Scottish Widows to provide more
detail of the underlying steps that are needed to
make the 2030 and 2050 targets happen. It is still
early in the Scottish Widows ESG journey and we
plan to be able to comment more fully in next
year’s report on the quality of these processes as
they start to influence customer outcomes this year.

But if this is a  highly effective IGC that could be showing itself to better effect in its chair statement.

Almost a curate’s egg

The joke in the story of the curate’s egg is that if an egg is excellent in parts but rotten in others, the egg is spoiled and unfit to be eaten.

I’ll stop short of that, this is a report that doesn’t mislead and is fit for purpose. But in its central purpose – giving its readers an understanding of the product’s value for money, it leaves us feeling a little short-changed. The egg is hard boiled and left me wanting something that  engaged my taste buds with some fluidity.

For instance, this year the IGCs have been challenged to explain the charging structures of the various employer schemes run by their insurer in segments – so that employers can work out what segment their scheme falls into and work out if what they are paying looks too high, ok or if they’re getting real value for their staff’s money.

This is the hard-boiled approach from the IGC.

This doesn’t really do the job, the idea is that the IGC publishes information on which employers and savers can make decisions, not just consult with the insurer.

Similarly, when it comes to measuring performance, we hear quite a lot about reorganization of funds and the creation of consistent benchmarks to compare fund performance, but we get no numeric information about how funds have performed either against internal benchmarks or against the competition.

For IGC reports to get read, they need to provide some tasty and engaging numbers which help people work out how their pensions are actually doing. This is what the DWP are getting at with their insistence on net performance reporting and comparators across different types of workplace schemes.

We have nothing in the 48 pages of this report that tells us how the various workplace pension arrangements are delivering relative to other workplace pensions and the proposed new benchmarks (CPI +) are not going to leave employers and savers much wiser.

The report commends Scottish Widows for moving to a more digital approach to member engagement (a necessity in the pandemic) and my experience of Scottish Widow’s support during the early months of the pandemic suggests they were quick to support savers. However, the numbers of users of the Scottish Widows app (10,000) and the views of a key video (900) suggests that the bar is being set pretty low.

In the assessment of value for money, I got the impression that there was a better story ready to get out, but the presentation of VFM felt hard-boiled, there was really very little that engaged me.

Effective yes, engaging no!

.I agree here with the sentiment

For Investment Pathways, it is very difficult to
give a meaningful assessment given they have
only just begun, are difficult for customers to
understand and we can’t assess them against the
competition yet

But this tortuous sentence is typical of the convoluted prose style in much of the document. The word “fluidity” comes back to mind! You can feel the struggle the IGC has had to find meaningful things to say on investment pathways but again you want to hear something that tells you whether they are worth using. If customers find them difficult to understand, what chance is there that they will get used?

These pathways are being promoted on the MaPS website using a charge comparison site, is the IGC aware of Scottish Widows’ ranking on that site and does it consider that simply comparing charges is an appropriate way for savers to take decisions?

Once again, I sense when close reading the text, that the report is holding back from delivering meaningful information and finding itself getting tied up in knots.

An underwhelming document

I come away from my analysis of this IGC report feeling an opportunity has been missed.

The IGC may argue that they were constrained in what they could say and I would agree, it looks to me like the report got bogged down and ended up saying very little at great length.

To add to that, the difficulties I had with navigating the PDF and the often tortuous style, I felt this a frustrating read, not one that I would recommend as I wish I could.

I’d like to see more ambition in future reports, especially when it comes to disclosing scheme level charges and  benchmarking performance.  IGC reports take a great time to write and if the net impact of the report is to create a dull document, you feel an opportunity has been lost. Rather like over-cooking an egg!


For its tone and engagement with its audience , I give this report an orange rating.

For its value for money assessment, I give this report an orange rating

For its effectiveness in its dealings with its insurer, I give the IGC and its report a green rating.

About henry tapper

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