Implementation Statement for the Federated Pension Scheme for Imperial - Covering 1 April 2020 to 31 March 2021

1. Background

The Trustees of the Federated Pension Scheme for Imperial (the “Trustees” and the “Scheme”, respectively), are required to produce a yearly statement to set out how, and the extent to which, the Trustees has followed the Plan’s Statement of Investment Principles (“SIP”) during the previous Plan year, in relation to engagement and voting behaviour during the year, either by or on behalf of the Trustees, or if a proxy voter was used.

This statement should be read in conjunction with the SIP and has been produced in accordance with The Pension Protection Fund (Pensionable Service) and Occupational Pension Schemes (Investment and Disclosure) (Amendment and Modification) Regulations 2018 and the subsequent amendment in The Occupational Pension Schemes (Investment and Disclosure) (Amendment) Regulations 2019.

A copy of the most recent SIP can be found at: https://www.imperial.ac.uk/human-resources/pay-and-pensions/pensions/the-federated-pension-scheme/statement-of-investment-principles/

2. Voting and Engagement

The Trustees are keen that their manager is a signatory of the UK Stewardship Code, which they are.

All of the Trustees’ holdings are within pooled funds and the Trustees have delegated to its investment manager the exercise of voting rights. Therefore, the Trustees are not able to direct how votes are exercised and the Trustees has not directly used proxy voting services over the year.

The Scheme is invested in the following funds:

• LGIM Investment Grade Corporate Bond Over 15 Year Index Fund
• LGIM Under 15 Year Index-Linked Gilts Index Fund
• LGIM Over 5 Year Index-Linked Gilts Index Fund
• LGIM Sterling Liquidity Fund

The Trustees were unable to include voting data for the underlined funds as they are predominantly fixed income and do not hold physical equities.