Phoenix Life’s exemplary IGC report.

Phoenix is no longer just an insurer of flaked out life insurance companies. It is a powerful financial service brand that includes Standard Life among the companies within its group.

It spends money on good governance and I’m pleased to report that this year it has got extremely good VFM from its IGC. Even though the IGC reports a deterioration of VFM in 2022, the report makes me more rather than less impressed with Phoenix as a whole.

It would take too long to list all the companies Phoenix has taken over in the past 20 years, previous blogs have tried. But in terms of independent governance committees, Phoenix has consolidated into three. You can read the three 2022 reports (published in September 2023) here. For the historians, there sits behind these three , Abbey Life and Old Mutual – both life companies who had their own IGCs.

Independent Governance Committee | About Phoenix Life | Phoenix Life

Independent Governance Committee (IGC) | Guide | Standard Life

Governance of Workplace pensions – ReAssure


With the exception of Old Mutual, all the IGCs (including Abbey Life) are or were chaired by David Hare who regularly churns out over 400 pages of reports, statements and value for money assessments. As the king of the IGCs , David sets the tone and necessarily I have had robustly challenged the direction of the blockbuster IGCs he currently produces.

Other IGC styles are available, Fidelity manage to offer an IGC report in less than 40 pages but the “Phoenix three” are 100 page efforts – well “99” in the case of the final of these three – the “Phoenix Life” IGC.

A word of warning from the IGC chair to Phoenix Life

In his opening remarks, David Hare reproves the management of  Phoenix Life, in a way he doesn’t the management of Standard Life or (even) ReAssure. It’s there on costs and charges.

We have strongly challenged Phoenix on why they view the level of charges being paid by some customers as providing value for money, given  the comparators in the market and the alternative funds they themselves offer. Despite this challenge being made over 12 months ago, and a number of discussions on the topic since then, at the time of writing, the IGC continues to wait for a satisfactory response on this challenge

It’s there on its investigation of communication and engagement

The MyPhoenix App launched for members in October 2022 allowing read-only access to pension information. Whilst we welcome this development, it remains disappointing that members cannot yet make changes to their pensions via the app.

It is a similar story with the MyPhoenix website where 38,686 customers still do not have access to a digital offering and those that do have limited opportunities to transact online.


This warning is included in the assessment, Note the !

This assessment does not give Phoenix’s Life a clear round

I will not challenge this assessment, I give it a green – based on the rest of the report. As I’ve mentioned elsewhere, I don’t think that there need be 6 shades of VFM, VFM comes down to outcomes and member experience. Outcomes are compromised by high charges, members should get an online experience and the Chair considers the VFM tick should be qualified this year. I’ll let it lie and give this assessment a green

A campaigning IGC doing the right things for its consumers

This report may have caught me on a good day, but in reading the detail (and there is a lot of detail), I was reminded that David Hare and his team really know their stuff. Take this admonition on charges relating to the NPI Managed Fund

I was in that fund for many years and paid a 1% fee. Out of that fee came a commission to the IFA (me) and when I came to consolidate , the fund was swapped for an equivalent offering on which I paid a quarter of the charges. Most of the punters in this fund should be able to get out as I did – without exit penalties and get the same deal for less.

If only IFAs were able to get to stranded assets , they would be doing this (albeit at a fee many wouldn’t pay). But for the unadvised punter, the findings of these report should be clear, if you have an old NPI policy with £100K in it , you are probably paying £700 a year to Phoenix Life you shouldn’t be.

Even if it is only Phoenix Life that reads this blog, please be reminded there is a consumer duty to tell the customer these things. This is what the IGC is doing and why there is still a point to IGCs.

And before people think I have reverted to a charges only approach to assessing VFM, I will point out that the Phoenix Life investment defaults are providing value which is why Hare is right to give Phoenix an overall tick in the VFM box

Some customers did not lose money while in a Phoenix default and the worst performing default lost less than 10% real in a year when many were losing twice that.

And while there is the usual carnage among a section of the “pick and mix” individual funds (a  legacy of the days when IFAs put funds on life company platforms), Phoenix is at least getting proper reporting (unlike other life companies).


This is a very good report because it is able to balance the things that Phoenix are doing well against the areas that cause policyholders harm without giving any impression of partiality to the provider’s point of view. I give this report a green for its rigorous approach to improving policyholder value. 

Tone of voice and readability

David Hare writes very well, I must have read over 20 of his IGC reports since they started in 2016. He has the resource of the Phoenix Group behind him and clearly a good team on his committee. The report not only reads well, but at 99 pages, it is stable, I can navigate it, reference sections that matter to me and I hope that professionals will do just this. The report is a great resource for IFAs.

Thankfully, unlike with other IGC reports for Phoenix companies, this one avoids calls to action that read like advertisements for the provider.

There is also a good four page summary – which is handy for the hard of learning

All this is building up to a dreadful revelation. After many years of resisting giving a Hare report a clean bill of health, I finally find myself doing just that. This report gets a green for readability.


About henry tapper

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