IMPORTANT INFORMATION RELATING TO THE USE OF THIS TEMPLATE
This report is designed to provide assistance in terms of communicating a report to an employer regarding implementing an auto enrolment scheme utilising the Amber Pension Trust. This report is not intended to include any recommendation to transfer away from an existing Group Pension Scheme. Such transactions should be dealt with on an individual advised level.
Employer Name
Workplace Pension Scheme Report
Date
Prepared by: Adviser
FIRM LOGO
INTRODUCTION
Overview
This report has been prepared following our recent discussions with regards to your business’s current circumstances and objectives in respect of a pension scheme for your employees.
You have approached me because of the auto enrolment legislation which means that you will have to make a workplace pension scheme available for your employees.
What we know about you
This report has been compiled using the information provided by you during our meetings. You should check carefully that the information given is correct and let me know of any errors or omissions as soon as possible.
I would ask that you read this report carefully and check that it matches your business’s objectives and financial position. If you feel there are any inaccuracies, do please contact me to discuss.
YOUR OBJECTIVES AND AUTO ENROLMENT
Your situation
This report is focused solely on your business need to provide your employees with a qualifying workplace pension scheme.
Your business’s circumstances can be summarised as follows;
You are a sole trader/partnership/limited company/limited liability partnership.
The business owners are xxxxx.
You have xx employees.
At our recent meeting, we discussed your new duties as an employer under the auto enrolment legislation. This legislation means that from sometime after April 2014 employers with less than 250 employees will start having to provide a workplace pension scheme that meets qualifying standards set out by the Government. Employers must join eligible employees to the scheme and contribute to it on their behalf.
These new employer duties are designed to encourage more people to save for their retirement.
This report will look at the legislation and how you are wishing to meet its requirements.
Staging date
The Pensions Regulator (TPR) has published detailed guidance on what an employer has to do before at and after their staging date which is the date from which they must comply with the new duties. Before your staging date, as an employer, you will need to
Assess how your workforce will be structured on your staging date to determine what duties you will have for each type of worker.
Assess any existing pension arrangements you have in place for existing employees and whether it can be used as a qualifying workplace pension scheme for them and other employees.
Choose a pension scheme for workers who will be auto enrolled and agree how this will be set up.
Choose a pension scheme for workers who will be given the option to join and agree how this will be set up.
Speak to your payroll provider to obtain your employee data in a usable format.
Decide on your chosen definition of pensionable salary.
Decide on whether to use postponement.
Decide on the level of contributions and whether you want to phase the minimum contribution in.
Communicate the changes to your workforce.
At your staging date you will need to
Inform your workforce about how auto enrolment affects them.
Auto enrol certain workers into your pension scheme and invite other types of workers to join your pension.
After your staging date will have to
Register with TPR no later than five months after your staging date.
Maintain records to show compliance with the employer duties.
Continue to auto enrol certain workers into your pension scheme as they become eligible.
Have an opt in process for other workers.
Ensure the correct contributions are deducted and paid into the pension scheme at the right time.
Manage opt outs, process refunds and re-enrol workers who opt out of your scheme every three years.
Monitor age and earnings regularly as workers can move between the different categories.
Re-register with TPR every three years.
Your staging date has been determined by TPR based on the total number of people included in your firm’s largest PAYE scheme on 1 April 2012. Your staging date is xx xxxxxxxxx 20xx.
Postponement
You can choose to postpone auto enrolment of all or some of your workers for up to three months from your staging date. Your staging date cannot be changed so this will remain the date your auto enrolment duties first apply.
Postponing auto enrolment would allow you more time for assessment and getting your systems in place and to get employee consent to participate in salary exchange if you decided to set up the pension scheme on this basis.
You can also use a postponement period for any workers who become newly eligible for auto enrolment once the scheme is in place. This would then be a period of up to three months from the date that individual worker first became eligible.
If you choose to use postponement you must tell the workers concerned about the deferral period and their rights to opt in.
> DELETE AS APPROPRIATE <
You are have chosen not to postpone auto enrolment.
You have chosen to postpone auto enrolment until XX XXXXXXXXX 20XX. Workers who you postpone auto enrolment for can opt in to the pension scheme during the waiting period.
Compliance
TPR is responsible for ensuring that employers comply with their employer duties. Their focus is on educating and helping employers meet their duties. They do, however, have the option to take action against non-compliant employers, using the following three steps:
1. A compliance notice will be sent to you outlining what must be done to put right any breach within a reasonable timescale.
2. If the breach is not put right TPR may issue a fixed penalty notice. You will be given a minimum of four weeks from the date of the notice to put things right and pay the fixed penalty fine of £400.
3. If you continue to fail to put right the breach then TPR can issue an escalating penalty notice under which the fine will increase daily until you comply. The size of the daily fine is based on the number of people in your PAYE scheme or the number of people affected by unpaid pension contributions. The daily fine for SMEs is
Number of people
Daily rate
1-4 £505-49 £50050-249 £2500
Types of workers
The auto enrolment legislation sets out the employer duties you will have for different types of workers who wholly work or ordinarily work in the UK.
The different types of worker and your employer duties towards them are
Eligible jobholderAged 22 to State Pension Age and earning at least £833 a month (2014/2015)
Eligible jobholders must be auto enrolled into a Qualifying Workplace Pension Scheme. You must make at least the minimum contribution for these workers for as long as they remain an active member of the scheme.
Non eligible jobholder Non eligible jobholders must be offered the opportunity to opt
Aged 16 to 74 and earning at least £481 a month (2014/2015) but don’t meet the criteria for eligible jobholders
into a Qualifying Workplace Pension Scheme. If they choose to join then you must make at least the minimum contribution for as long as they remain an active member of the scheme.
Entitled workerAged 16 to 74 and earning less than £481 a month (2014/2015)
Entitled workers must be offered the opportunity to join a pension scheme. They can make contributions to the pension scheme if they choose. However, there is no requirement for you to make a contribution.
> IF YOU HAVE DONE AN ASSESSMENT OF THE WORKFORCE OR THE EMPLOYER HAS PROVIDED YOU WITH AN ASSESSMENT<
Based on the information you have provided and the eligibility rules you have the following types of workers in your workforce
Type of worker Number in workforceEligible jobholder XXNon eligible jobholder XXEntitled worker XX
Workers can move between the different types as their circumstances change. For that reason you will need to monitor and assess age and earnings for each pay reference period.
Categories of membership
You can consider setting up different categories of membership within your workforce and offering different contribution levels to each, for example, for management and staff.
> DELETE AS APPROPRIATE <
You have chosen to have a single category of membership.
You have chosen to offer different contribution levels, namely
Category Number in workforceEg Management XXXXEg Staff XXXX
Contributions
The auto enrolment rules require a minimum pension contribution to be paid on the qualifying earnings band in any pay reference period.
In 2014/2015 the qualifying earnings band is earnings from £5,772 to £41,865 for a pay reference period of a year. For a monthly pay reference period the qualifying earnings band in 2014/2015 is £481 to £3,489.
Qualifying earnings include salary, overtime, bonuses, commission and statutory payments such as sick and maternity pay.
From October 2018 the standard quality test will be a minimum contribution of 8% of the qualifying earnings band of which at least 3% is paid by the employer. However, the legislation recognises that many employers may find it easier to base contributions on employees’ earnings from their first pound earned. As a result, there are three alternative measurements which will allow the employer to self certify that contributions are meeting the minimum requirements. These are
Earnings definition Minimum total contribution
Minimum employer contribution
Basic pay 9% 4%At least 85% of total pay 8% 3%Total pay 7% 3%
Under all three options, pensionable pay must be at least equal to basic pay over the payment period and earnings must be pensionable from £1 upwards. There is no scope to exclude a tranche of earnings or operate a bottom end pay deduction.
Basic pay includes geographical allowances, but not other allowances, benefits in kind or irregular payments such as commission, overtime or bonus.
Under the 85% of total pay option the total pensionable pay for relevant members must be at least 85% of total pay for all those members but not necessarily for each individual member.
An employer can choose to choose to use all the options if they wish by breaking down their workforce into sub groups within a pension scheme. If they do they will need to provide a certificate for each option which must be in line with guidance provided by the Department for Work and Pensions (DWP).
The minimum contribution levels for each earnings definition can be phased in between your staging date and October 2018. Phasing pension contributions means that all parties intend to increase their contributions over a set period of time until the minimum contribution levels described above are met in October 2018. The minimum phased contributions are
Standard earnings definition
Date Minimum totalcontribution
Minimum employerContribution
Staging date – September 2017 2% 1%October 2018 – September 2018 5% 2%October 2018 onwards 8% 3%
Basic pay
Date Minimum Minimum employer
totalcontribution
Contribution
Staging date – September 2017 3% 2%October 2018 – September 2018 6% 3%October 2018 onwards 9% 4%
85% of total pay
Date Minimum totalcontribution
Minimum employerContribution
Staging date – September 2017 2% 1%October 2018 – September 2018 5% 2%October 2018 onwards 8% 3%
Total pay
Date Minimum totalcontribution
Minimum employerContribution
Staging date – September 2017 2% 1%October 2018 – September 2018 5% 2%October 2018 onwards 7% 3%
For your workforce your contribution requirements are
Category Earnings definition Employer contribution Employee contributionEg Management
Eg Standard X% X%
Eg Staff Eg Basic pay X% X%
You should note that
If you have an existing pension scheme you may need to change your definition of pensionable earnings and base your contributions on qualifying earnings.
You may need to update your employees’ contracts of employment to reflect your chosen definition of pensionable salary for them.
You will need to ensure that your payroll system is updated to calculate contributions based on the chosen definition of pensionable earnings for each employee.
You should check contracts of employment to make sure that they allow for automatic deductions to be taken from earnings.
The thresholds for qualifying earnings are subject to change each year. You may have to update your payroll system each year in line with these changes.
Each time you make a pension contribution you will need to make sure that it meets the minimum requirements as earnings may change.
> DELETE IF ONLY USING THE STANDARD EARNINGS DEFINITION <
You will need to certify every 18 months in line with the guidance provided by the DWP that the contributions to our scheme meet the quality requirements.
Auto enrolment
Pension schemes used for auto enrolment must meet certain standards.
Schemes cannot prevent the employer from auto enrolling, opting in or re-enrolling a worker.
Schemes cannot require a worker to provide information or make a choice in order to remain a member of the scheme.
Schemes must be a qualifying workplace scheme.
Existing schemes must be registered pension schemes.
o An occupational scheme must require the employer to make a contribution and that the total minimum contribution meets the minimum requirement.
o Personal and stakeholder pensions must
have an agreement between the employer and the provider that the employer must eventually make contributions on behalf of the jobholder of at least 3% of qualifying earnings.
Have an agreement between the provider and the jobholder where the jobholder can be required to make up any difference to the total of the definition of pensionable salary chosen.
Allow for the employer to deduct the jobholder’s contributions from pay.
Use one of the specified definitions of pensionable salary.
I have so far reviewed how you wish to meet your employer duties as a part of the auto enrolment legislation; we will now look at you can meet them.
EXISTING WORKPLACE PENSION SCHEME
> USE THIS SECTION WHERE THE EMPLOYER HAS AN EXISTING PENSION ARRANGEMENT <
You currently provide a group money purchase/personal pension/stakeholder with PENSION PROVIDER. Its details are
Product/scheme name – SCHEME REFERENCE
Scheme Name
No. of Scheme member
s
Total Gross Employer
Contribution
Frequency
Total Gross Employee
Contribution
Frequency
Scheme NRD
<INSERT> <INSERT> <£INSERT> <INSERT> <£INSERT> <INSERT> <INSERT>
The default fund is [NAME OF FUND].
The features of the group pension scheme are
Costs – The overall costs of this scheme are
Employer costs
eg, establishment fee, ongoing annual/monthly fees
Member costs eg, AMC, ongoing policy fees
Pension Contribution Insurance Benefit – The current group pension includes Pension Contribution Insurance Benefit. In the event of members being unable to work due to illness or injury for a pre-determined period of time, the insurance company will credit member pots with contributions on their behalf; thereby avoiding the necessity for them to make the plan paid-up due to a lack of affordability.
<INCLUDE IF APPLICABLE>
The employee contributions are presently insured through a Group Income Protection plan which includes pension payment protection. In the event of members being unable to work due to illness or injury for a pre-determined period of time, the insurance company will credit member pots with contributions on their behalf; thereby avoiding the necessity for them to make the plan paid-up due to a lack of affordability.
Life Insurance – The group pension incorporates an element of additional life cover. In the event of a member’s death before their chosen retirement age, their nominated beneficiaries would receive an additional lump sum in addition to a return of the member’s pension fund.
Stakeholder Guarantee - Although the charging structure of this group pension contract is not “stakeholder friendly” in the true sense of the word, the holding company have issued a guarantee to ensure it will not suffer annual charges in excess of a stakeholder pension.
Guaranteed Annuity Rate - This group pension incorporates a guaranteed annuity rate which could
prove valuable when compared to the annuity rates available on the open market at the time of the members taking benefits. However, it is worth bearing in mind that a number of companies place restrictions on the "shape" of benefits the annuity can provide if the guaranteed annuity rate is to be applied. Usually if any other basis is required then current annuity rates will apply. Although a guaranteed annuity rate is obviously an important potential benefit it should still be balanced with the overall scheme pension retirement objectives.
<SELECT RECOMMENDED ACTION>
1. <RETAINED AND USED AS YOUR AUTO ENROLMENT SCHEME>
I recommend this group pension be retained and used as your auto enrolment scheme for the following reasons:
This group pension already meets the minimum qualifying scheme criteria for the auto-enrolment legislation requirements of the business and there is no need to make any changes
This scheme has been certified as a qualifying scheme for auto enrolment purposes New eligible employees can be added at any time. I am satisfied with the performance of this group pension to date Members can transfer in other pensions as well as transfer their funds away which offers flexibility
to the membership A salary sacrifice scheme is in operation for employee contributions and working successfully The charging structure of this group pension is competitive when compared to similar group
pensions available in the market place The group pension provider remains financially strong The group pension provides additional benefits which could prove valuable to members in the
future It offers additional member benefits already such as waiver of contributions, indexation and
premium holidays <INSERT ADDITIONAL REASONS HERE>
2. <RETAIN FOR EXISTING MEMBERS>
I recommend this group pension be retained for existing members for the following reasons:
This group pension already meets the minimum qualifying scheme criteria for existing members and there is no need to make any changes
I am satisfied with the performance of this group pension to date Members can transfer in other pensions as well as transfer their funds away which offers flexibility
to the membership A salary sacrifice scheme is in operation for employee contributions and working successfully The charging structure of this group pension is competitive when compared to similar group
pensions available in the market place The group pension provider remains financially strong The group pension provides additional benefits which could prove valuable to members in the
future It offers additional member benefits already such as waiver of contributions, indexation and
premium holidays
<INSERT ADDITIONAL REASONS HERE>
3. <STOP MAKING CONTRIBUTIONS INTO THE PLAN>
I recommend this group pension be made ‘Paid Up’ for the following reasons:
The existing plan contributions from employer and employee continue to attract charges in excess of more modern plans within the current market place.
The existing plan cannot be used as a qualifying workplace pension scheme for staff who are not already members and you only wish to contribute to a single pension arrangement for all your employees.
The members fund values will all be reduced should a transfer take effect due to the application of exit penalties (this process will require separate, authorised advice).
The members may wish to transfer their pensions separately following the establishment of the new employer pension arrangement. (Any members wishing to take this option are recommended to seek authorised advice.)
PERSONAL AND STAKEHOLDER PENSIONS ONLY: The members may wish to continue making their own contributions into the plan. These would not be deducted from their salaries as at present.
<INSERT ADDITIONAL REASONS HERE>
AUTO ENROLMENT SCHEME RECOMMENDATION
Having considered the options and your objectives I recommend that you set up a qualifying workplace pension scheme using the Amber Pension Trust.
My reasons for this are: [add or delete as necessary]
This scheme will satisfy your responsibilities and the minimum criteria for auto enrolling your employees into a workplace pension in line with auto enrolment legislation.
It provides the opportunity for the business to offer its employees a valuable benefit to build up their own pension fund ahead of your auto enrolment staging date.
It will allow you to set different payment limits for different categories of staff, thereby promoting employee recognition.
It will assist with the retention of your employees that will remain attracted by the pension benefits available through your employment.
The normal retirement age will be set in line with your business objectives, at age 65. However, no penalties would apply should any of your employees decide to retire earlier or later than this date. Under current legislation, individuals can take pension benefits at any time from age 55.
PROVIDER
Having compared the whole of the marketplace/the providers available on my panel, I have recommended the Amber Pension Trust for the following reasons
Amber launched in 2012 to provide investment and pension solutions to the financial adviser market and they provide services to over 2500 advisers in the UK and in excess of 10,000 clients.
The scheme has been developed with auto enrolment legislation in mind.
The scheme is a qualifying workplace pension scheme.
The scheme is easy to establish and uses simple sign up documentation.
The scheme has a dedicated scheme administrator
They provide members with the facility to manage their pensions online, providing access to instant valuations, fund information and other investment analysis tools.
The scheme is established under a Master Trust and makes available to small to medium sized employers the very best practice in investment, administration and governance. The trustees regularly review the scheme’s performance and suitability so that they can ensure that they are doing the best job for you and your employees.
The scheme can interact with your payroll to assess your employees and allow for the correct contribution amounts to be deducted that help ensure you meet your auto enrolment obligations.
What is a master trust?
A master trust is a pension scheme designed for multiple employers under a single trust arrangement, with membership set up and administered separately for each participating employer.
The Amber Pension Trust has an unbundled approach which means the administration is outsourced to a third party, Carey Pensions UK LLP, as are the investment decisions, to Tatton Investment Management.
Under the Amber Pension Trust, scheme governance is delegated to the independent corporate trustees appointed by Amber Financial Investments Ltd which are Carey Pensions Trustees UK Ltd and Amber Trustees Ltd. The independent trustees have the responsibility to monitor the scheme’s investments and administration.
Importantly, they retain complete independence and the power to challenge ongoing investment and administration services.
Charges
Establishment fee
Delete as applicable
£25 per member payable by you at outset. Monthly fee of £3 payable by you for the first year after each member joins the scheme. 75p a month paid from each member’s fund for the whole time the pension remains in force.
Annual management charge
xx% of each member’s fund value each year.
Auto enrolment charges
£250 initial scheme charge.
£1.50 a month for each member subject to a minimum of £75.
This compares to the charges on your existing plans, detailed earlier in the report, and you can see that the new plan is more expensive/lower cost. [If higher cost, clarify why this is considered acceptable]
DEFAULT INVESTMENT FUND
The trustees require a default investment strategy to ensure that it
Is appropriately designed.
Is suitable for the scheme membership.
Adopts the DWP’s best practice guidelines in a cost effective manner.
Taking all this into account, the investment manager, Tatton Investment Management, has chosen as the default investment funds the BlackRock LifePath Target Date funds. The default fund should be set up to target the retirement age of 65 for each member.
These are the only funds available and simplify the employees’ investment decision, by offering a single fund which automatically adjusts exposure to risk relative to the pre-selected retirement (or target) date.
The importance of the default investment has been highlighted in a number of regulatory guidance documents from TPR and the DWP. The documents include TPR’s guidance on selecting a good quality pension scheme for automatic enrolment and DWP’s guidance for offering a default option for defined contribution automatic enrolment pension schemes.
The DWP’s guidance highlights criteria that the default investment fund should meet. It should
Be appropriately named and described.
Take into account the scheme membership risk and retirement profile.
Use an appropriate and diversified asset allocation.
Be affordable.
Include regular design, performance and suitability reviews.
Audit and communicate the conclusions of the regular governance reviews.
The Amber Pension Trust’s default option meets these criteria by including the target date in the funds’ names; switching members to lower risk investments as they approach retirement; using a simply managed yet sophisticated investment strategy that automatically adjusts its allocations as it progresses towards the target maturity date; its costs; ongoing monitoring and rebalancing; and the trustees’ ongoing review of its performance and suitability.
About the default fund
The objective of the BlackRock LifePath target date funds is to provide retirement year funds with an asset allocation that changes over time. Each DC LifePath Fund will automatically adjust its investment
strategy as it progresses towards its maturity date, normally the retirement date of the members. Because exchange rate movements can affect the value of investments that are in foreign currencies, the DC LifePath strategy will use specific instruments to hedge out the majority of the foreign currency exposures.
LifePath takes into account the changes in investors’ needs through their working life. The chart below shows how an investor’s investment mix will change gradually as they get nearer to retirement. The maturity date is the point at the end of phase three at which the asset allocation strategy stops changing and remains in fixed interest stocks and cash.
The funds allocated to Diversified Growth follow a diversified, risk-controlled investment process that aims to achieve
Long-term total return of cash +3.5%, which is what BlackRock expects a global 60% equity/40% bond portfolio to deliver, over a market cycle.
Approximately 40% less risk than the global 60% equity/40% bond portfolio.
Less downside exposure during extreme market conditions.
It invests in a highly diversified mix of asset classes based on target exposures to fundamental economic risk factors. By managing exposure during market extremes, the Fund seeks to deliver risk in line with target while reducing downside risk.
The funds are managed daily by a team of dedicated portfolio managers and strategists who have oversight of the funds’ actual performance and evolution over time.
The investment strategy or ‘glide path’ views risk through its impact on employees’ wealth. It reduces risk gradually at first then accelerates the reduction as retirement approaches and so reduces the investment volatility for individual employees.
MEMBERSHIP & CONTRIBUTIONS
Membership
<SELECT PREFERRED WORDING>
It has been agreed that the recommended group pension will be implemented ahead of your Staging Date as a small to medium size business and membership of the scheme will be strictly in line with the current auto enrolment legislation.
It has been agreed that the recommended group pension will be implemented ahead of your Staging Date as a small to medium size business and membership of the scheme will be as follows,
<INSERT HERE DEFINITION AND / OR RESTRICTION TO MEMBERSHIP>
Contributions
It has been agreed that contributions will be set up in line with the details mentioned earlier in the report.
Salary exchange
Salary exchange is an arrangement which enables your employees to boost their pension contributions. It can also be used to save your business money. Your employee agrees to a reduction in their salary under their contract of employment and in return they receive the benefit of you paying the equivalent amount into their pension.
The contract of employment needs to be varied as the employee is giving up a contractual right to the amount of salary given up.
Contributions you make as an employer into an employee’s pension are not liable for income tax or National Insurance Contributions. If they are paid instead of salary then you can make a saving on National Insurance which you can either retain within the business or be paid into your employees’ pensions to boost their fund. You could choose to divide the saving between the two.
The advantages of salary exchange are
You can offer an improved benefits package for your employees.
You can deduct pension contributions from your tax bill in the same way as salary payments.
National Insurance savings for you if they are not paid into the employees’ pensions
National Insurance savings for your employees allowing them to pay more into their pensions or increase their take home pay.
The drawbacks for your employees who are auto enrolled into the scheme and agree to salary exchange are that it can affect their entitlement to the additional state pension if after the exchange their gross earnings are between £15,100 and £40,040 (in 2014/2015). Salary exchange can also impact on their ability to borrow unless you decide to use the pre exchange earnings as the base earnings for the employees.
If any of your employees who are not eligible to auto enrol into the scheme join the scheme and agree to salary exchange then if their gross earnings after the exchange are less than £5,772 (in 2014/2015) they won’t be eligible for statutory sick pay, statutory maternity, paternity or adoption pay and contribution based employment and support allowance and jobseekers’ allowance. It could also affect the Basic State Pension they receive at State Pension Age.
Salary exchange involves a choice for the employee but the process of auto enrolling employees into a workplace pension scheme cannot involve employees making a choice. This means that salary exchange cannot be a condition in joining a qualifying workplace pension scheme.
There are a number of ways that salary exchange can be implemented without affecting auto enrolment. These include
Offering salary exchange after employees have been enrolled.
Postponing auto enrolment for up to three months and inviting the employees to enter salary exchange during this deferral period.
If you decide to proceed with salary exchange then this can be facilitated using the Amber Pensions Trust.
Expression of wish
I recommend that all members who join the scheme are encouraged to complete an Expression of Wish form. This will ensure the proceeds of their pension, subject to the trustees’ discretion, are paid to their chosen beneficiary.
ADVICE FEES
> DELETE AS APPLICABLE <
We have agreed that you will pay [FIRM NAME] a one off fee of £XXXX in respect of setting up this Qualifying Workplace Pension Scheme.ORWe have agreed that you will pay [FIRM NAME] a fee of £XXXX in respect of setting up this Qualifying Workplace Pension Scheme which you will pay in X instalments of £XXXX.ORWe have agreed that you will pay [FIRM NAME] a one off fee of £XXXX in respect of setting up this Qualifying Workplace Pension Scheme and an ongoing fee of £XXXX a month/year which will cover .... DETAILS OF ONGOING SERVICE
You should note that advice fees and consultancy charges cannot be deducted from the members’ funds in Qualifying Workplace Pension Schemes.
