Bromley Council's Local Pension Board has voiced concerns regarding the performance of the pension fund's administration, particularly highlighting discrepancies in performance figures and sub-fund underperformance. The discussion took place during the board's meeting on 29 July 2025, where members reviewed the Performance Monitoring Report 2025-26 Year to Date and a report from the Pensions Committee - 28 May 2025.

Pension fund quarterly values since 2002, showing total fund value, cash invested, and investment returns.
Pension fund quarterly values since 2002

To address performance issues with Liberata1, Bromley Council has implemented monthly service review meetings with Liberata Pensions, the Assistant Director of the Pensions Shared Service, and the Assistant Director of Exchequer Services. Additional quality checks are conducted by the Assistant Director of Pensions Shared Service or Head of Corporate Finance and Accounting for tasks such as flexible retirement, payment of death grants, large/complex transfer values, and complex queries. Recommendations are provided to Liberata based on outstanding casework, focusing on clearing failed cases and addressing areas with the highest volume of outstanding work.

The board reviewed Liberata's performance statistics between 1 April 2024 and 31 May 2024. While some areas met the target of 100%, others fell short:

  • General Queries: 100% of queries processed within 10 days.
  • Retirements: 69% to 93% processed within 15 days, against a target of 100%.
  • Transfers In: 89% to 95% processed within 10 days, against a target of 100%.
  • Transfer Values: 73% to 89% processed within 20 days, against a target of 100%.
  • Death Benefits: 93% to 100% processed within 10 days.
  • Refunds: 100% of refunds processed within 10 days.
  • Divorces: 86% to 100% processed within 10 days.
  • Estimates: 100% of estimates processed within 5 days.

Custodian Performance Concerns

Adding to the board's concerns, the Pensions Committee, at its 28 May 2025 meeting, discussed discrepancies in performance figures generated by the custodian compared to those provided by the investment manager. The Senior Advisor: Apex Group Ltd was requested to engage with the custodian and provide a short report to the Pensions Committee during Summer 2025 regarding the performance figures generated by the custodian which had not matched those provided by the investment manager on several occasions. The outcome of the Senior Advisor's engagement with the custodian will be detailed in a forthcoming report to the Pensions Committee.

Risk Management

The board reviewed the Pension Fund Risk Register, which identifies key risks to the fund and outlines control measures. Key risks identified include poor investment performance, actuarial risk, insufficient cash, sub-fund underperformance within the London CIV2, pension contribution issues, cost control, fraud, lack of knowledge and experience among board members, climate change, regulatory changes, mandatory pooling, legal compliance, conflicts of interest, administration officer knowledge and skills, inaccurate employer data, cyber risk, external audit non-performance, pension scams, and operational disasters.

Specific control measures are in place to mitigate these key risks:

  • Poor Investment Performance: Control measures include anticipating long-term returns on a prudent basis, analysing progress at triennial valuations, and diversifying assets.
  • Cyber Risk: Control measures include penetration testing and disaster recovery plans.
  • Climate Change: The risk of climate change impacting the pension fund's investments is addressed by appointing asset managers who consider ESG issues and monitoring the fund actuary's climate report.

Concerns were also raised regarding the performance of the Baillie Gifford Global Equity portfolio managed via the London CIV (LCIV). The portfolio fell -6.8% in the first quarter, noticeably behind the benchmark return of -4.2%. The Performance Monitoring Report 2025-26 Year to Date notes concerns that Baillie Gifford may be holding a larger exposure to US large-cap stocks to lower their active share and risk. Risk control measures in place include monitoring the performance of CIV sub-funds.

The next meeting date will be agreed with Board Members following the meeting. For more information, visit the Bromley Council website.


  1. Liberata is a business process services company contracted by Bromley Council to administer pension services. 

  2. London CIV is the London Collective Investment Vehicle, a collaboration of London local authorities pooling their pension fund assets.