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Pension Trustee Code of Conduct

The CFA Institute Pension Trustee Code of Conduct sets the standard for ethical behavior for a pension plan's governing body

Read the CFA Institute Pension Trustee Code of Conduct

Download the Code (PDF)


The Pension Trustee Code of Conduct embodies 10 fundamental principles of ethical best practice for pension plan trustees. Compliance with the Code promotes a standard of professional excellence among a pension plan’s trustees and trust among the plan’s stakeholders. We encourage public and private industry pension plans, including corporations and unions, to adopt the Code.

View the Pension Trustee Code of Conduct Fact Sheet (PDF)

What is Covered?

The Code outlines 10 fundamental ethical principles that are universally applicable to pension plan trustees:

  1. Act in good faith and in the best interests of the plan participants and beneficiaries.
  2. Act with prudence and reasonable care.
  3. Act with skill, competence, and diligence.
  4. Maintain independence and objectivity by, among other actions, avoiding conflicts of interest, refraining from self-dealing, and refusing any gift that could reasonably be expected to affect their loyalty.
  5. Abide by all applicable laws, rules, and regulations, including the terms of the plan documents.
  6. Deal fairly, objectively, and impartially with all participants and beneficiaries.
  7. Take actions that are consistent with the established mission of the plan and the policies that support that mission.
  8. Review on a regular basis the efficiency and effectiveness of the plan's success in meeting its goals, including assessing the performance and actions of plan service providers, such as investment managers, consultants, and actuaries.
  9. Maintain confidentiality of plan, participant, and beneficiary information.
  10. Communicate with participants, beneficiaries, and supervisory authorities in a timely, accurate, and transparent manner.

How Can a Pension Plan Comply?

Complying with the Pension Trustee Code is voluntary. Pension plans that wish to adopt the Code should take the following steps:

  1. Compare the CFA Institute Pension Trustee Code of Conduct and Guidance for Compliance to your plan’s existing code of conduct to identify gaps and determine whether the plan’s current governance policies and procedures comply with the Code.
  2. Revise or establish policies and procedures as needed to align with the Code.
  3. Complete the fillable PDF Pension Plan Compliance Notification Form and send to [email protected].

Pension plans must notify CFA Institute when they initially adopt the Pension Trustee Code of Conduct, and on an annual basis thereafter, by submitting the Pension Plan Compliance Notification Form. Annual submissions must be completed by 30 June each year with information as of the most recent 31 December, with the exception of contact information, which must be current as of the submission date.    

How was the Code Developed?

CFA Institute developed the Pension Trustee Code with a multinational coalition that included:

  • Council of Institutional Investors (United States)
  • Organization for Economic Cooperation and Development
  • National Association of Pension Funds (United Kingdom)
  • Swiss Association of Pension Funds
  • Hong Kong Retirement Schemes Association
  • Dutch Association of Industry-wide Pension Funds

Public comments were also solicited from all major global financial markets and stakeholders.

Translations of the Pension Trustee Code

Dutch: Gedragscode voor leden van het bestuur van een pensioenfonds

German: Verhaltenskodex für Mitglieder eines Leitungsorgans eines Rentensystems