Application
The requirements of this chapter apply to the entire Board, but are of particular importance to members of the Governance, Human Resources and Pension Committee (“GHRP Committee”) with respect to their pension administration responsibilities for the “CATSA Pension Plans” or “Plans”:
- Registered Pension Plan – Pension Plan for the Employees of CATSA;
- Supplementary Retirement Plan – Supplementary Retirement Plan for Certain Employees of CATSA; and
- Group Registered Retirement Savings Plan.
Note: Members of the Pension Management Committee (“PMC”) are also subject to the same Standards of Conduct within the Pension Management Committee Code of Conduct and Ethical Behaviour.
Purpose
The conduct of the Board as administrator and sponsor of the CATSA Pension Plans and the conduct of the members of the GHRP Committee and the PMC in fulfilling their delegated administration responsibilities affects the members and beneficiaries of the CATSA Pension Plans who depend on the pensions for their retirement income.
Consequently, as part of a governance best practice, the Standards of Conduct provided in this chapter are intended to work in conjunction with the other Standards of Conduct of this Code in order to provide additional assurance that those individuals who are fulfilling pension administration responsibilities are subject to appropriate ethical standards.
Standards of Conduct
In fulfilling their fiduciary responsibilities with respect to the administration of CATSA’s pension plans, Directors shall:
- Act in good faith and in the best interest of pension plan members and beneficiaries.
For greater certainty, this duty applies with respect to plan administration responsibilities, as opposed to any non-fiduciary activities or decisions the Board members may participate in with respect to CATSA’s role as sponsor of the Plans.
- Act with skill, competence, diligence, prudence and reasonable care expected of an individual with their skills, training or professional accreditation.
- Maintain independence and objectivity by avoiding and disclosing any Conflict of Interest as defined and governed by the requirements relating to Conflict of Interest of this Code.
- Abide by all applicable laws, rules and regulations, including the terms of the pension plan documents.
- Deal fairly, objectively, and impartially with all plan members and beneficiaries.
- Take actions that are consistent with the objectives of the Plans and the Plans’ documents and policies that support those objectives.
- Review on a regular basis the efficiency and effectiveness of the Plans’ success, including assessing the performance and actions of the pension service providers, such as investment managers, consultants and actuaries.
- Maintain confidentiality of pension, plan member, and beneficiary information, other than information that is required or permitted to be disclosed by law, contract or policy.
- Communicate with plan members, beneficiaries, auditors and regulatory authorities in a timely, accurate and transparent manner.