Pension Trustee Code of Conduct

Establishing an ethical framework for governing board members

Read the Pension Trustee Code of Conduct

View the Code (PDF)


CFA Institute encourages pension plans to adopt the voluntary Code of Conduct for Members of a Pension Scheme Governing Body. By adopting the Code, you are establishing an ethical framework for governing board members and showing your commitment to the best interests of pension participants and beneficiaries.

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

Who Should Adopt?

  • Public companies
  • Governmental agencies
  • Unions
  • Pension schemes administrators

Plan participants and beneficiaries should ask their pension scheme managers to comply with the Code.

What is Covered?

The Code outlines 10 fundamental ethical principles, which are universally applicable regardless of fund type, for pension fund trustees:

  • Act in good faith and in the best interests of the scheme participants and beneficiaries
  • Act with prudence and reasonable care
  • Act with skill, competence, and diligence
  • 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
  • Abide by all applicable laws, rules, and regulations, including the terms of the scheme documents
  • Deal fairly, objectively, and impartially with all participants and beneficiaries
  • Take actions that are consistent with the established mission of the scheme and the policies that support that mission
  • Review on a regular basis the efficiency and effectiveness of the scheme's success in meeting its goals, including assessing the performance and actions of scheme service providers, such as investment managers, consultants, and actuaries
  • Maintain confidentiality of scheme, participant, and beneficiary information
  • Communicate with participants, beneficiaries, and supervisory authorities in a timely, accurate, and transparent manner.

How Can I Comply?

Complying with our Pension Trustee Code is voluntary. We believe that effective self-regulation goes beyond the minimum requirements of the law. It is the most effective and efficient form of market regulation.

Acknowledge your compliance with the Pension Trustee Code (PDF)

How was it Developed?

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

  • 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

We also asked for public comments 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

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