1. Introduction
This Investment Strategy Statement (‘ISS’) has been prepared in accordance with regulation 7 of the Local Government Pension Scheme (Management and Investment of Funds) Regulations 2016 (the ‘Regulations’) and associated guidance. To the extent possible this ISS refers to future pooling arrangements under LPPI; however, elements necessarily relate to the Fund’s historical approach to pooling under Brunel. It reflects strategy changes agreed by the Committee in 2025.
The ISS will be updated by 1st October 2026 in line with the Local Government Pension Scheme (Pooling, Management and Investment of Funds) Regulations 2026 once they pass into law. The ISS will incorporate any changes to the strategy recommended by LPPI.
The purpose of the ISS is to set out:
- The governance arrangements for investments
- APF’s investment beliefs
- APF’s investment objectives and preferences including its approach to Local Investment
- How APF will manage investment related risks
- How APF incorporates responsible investment
- The strategic asset allocation benchmark and ranges to provide flexibility
The ISS is consistent with the Funding Strategy Statement (FSS). An integrated approach ensures the investment strategy supports APF in meeting its regulatory requirements.
Ongoing quarterly and annual monitoring of the strategy enables the APF Committee (the Committee) to take advice as to whether a review is needed at any time.
In preparing the ISS, the Committee has taken advice from Fund Officers and APF’s appointed investment consultant. APF’s Local Pension Board (Board) reviews the ISS for compliance with the regulations.
Investment Governance Framework
APF is administered by Bath & North East Somerset Council, which is legally responsible for APF. The Council delegates its administration responsibility to the Avon Pension Fund Committee, which is its formal decision-making body. Members of the Committee represent a cross section of APF’s stakeholders and therefore a range of views are taken into account when agreeing policy and strategy.
The Committee is supported by a sub-committee, the Investment Panel (the Panel), which considers matters relating to the management and investment of the assets of APF in greater detail. Although the Panel has delegated powers to take decisions on specific issues and makes recommendations to the Committee, setting the strategic asset allocation is the responsibility of the Committee. Operational implementation of strategy is delegated to Officers.
The Funding & Risk Management Group (FRMG) provides a robust and efficient governance framework for the Risk Management Strategies. This Group comprises Fund Officers, Investment and Risk advisors. FRMG has delegated authority for:
- agreeing the operational structures required to meet the strategic objectives determined by the Committee; and
- implementation of the Risk Management Strategies.
The FRMG also monitors the strategies on a monthly basis and reports to the Panel on a quarterly basis.
In addition, the Board has an oversight and scrutiny role to ensure good governance through monitoring of APF’s performance, activity of the Committee and compliance with regulations and statutory duties. The Board’s role is to assist the administering authority to ensure the management of APF is effective and efficient.
Both the Committee and the Board have members and other stakeholder representatives who actively engage with stakeholders to ensure APF is aware of, and can respond effectively to, stakeholder concerns.
APF actively engages with its stakeholders about the investment strategy, providing the opportunity for a wider range of stakeholders to give input as the Committee assesses key strategic considerations.