The Code of Practice for Incentive Exercises 

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2019 Status of the Code

The Code of Good Practice on Incentive Exercises was launched in June 2012 and updated in 2016.  

It has been gratifying to see the Code well received by the industry.  The interest shown in understanding how the Code should be applied in different circumstances through attendance at IE Industry Forums and questions asked of members of the IE Monitoring Board and through our website, has been encouraging.  It is clear that trustees and employers want to comply with the Code, despite its voluntary nature, and we believe that the Code has resulted in better behaviours, better run exercises and less risk of members being disadvantaged.  The Code has come of age.

In 2018, we had to decide whether to keep maintaining the Code into the future, or whether to acknowledge the excellent outcomes for thousands of ordinary people  and leave the Code out there as an example of good practice for all to follow. 

The Code was mentioned in the 2019 Rookes Report into British Steel, as a good basis for future guidance to trustees and employers where members of scheme face important choices.

The Code is now set out on the Pension Regulator's website as an example to trustees and practitioners of what good looks like in the area of incentive exercsies.

For these reasons, we will stand aside from the Code, leave it out there as a source of good practice, but no longer update it.  In future, practitioners and trustees should read and follow the guidance set out by the regulator, which includes refernce to the Code of Good Practice on Incentive Exercises. The IE code is now accessible directly on TPR’s website via the link below:

We are grateful to the representatives of organisations from across the industry, who freely gave their time and expertise to review and produce the Code of Good Practice and to their employers who made it possible. We are also grateful to the many advisers and trustees who adopted the principles of the Code and used them to deliver good outcomes for their scheme members since 2012.




Why a Code?


A Code of Good Practice for Incentive Exercises was introduced in response to industry and government concerns that such exercises could be conducted in a way that disadvantaged pension scheme members.  


The objectives of the Code are to ensure that all incentivised transfer and similar exercises in the future are:

  • done fairly and transparently;

  • communicated in a balanced way and in terms that members can understand;

  • available with appropriate regulated and  qualified independent financial advice that is paid for by the employer;

  • able to achieve high levels of member engagement;

  • provided with regulated access to the independent complaints and compensation process.


The IE Code is now in its 8th year and has been recognised as an important tool in protecting both members of DB scheme and the schemes themselves through good practice on incentive exercises.  

As the Code has "come of age", it will now transfer to the Pensions Regulator, who will include it and its supporting materials, as an example of good practice to be adopted by the industry and used in all such exercises.

This website will close shortly, and the Code can be found on the Pension Regulator's website 

Thanks to all for supporting the Code over the last 8 years.

Sign up as a Supporter of the Principles of the Code


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"The Code of Practice is aimed at improving the protection for pension scheme members involved in incentive exercises and so far appears to have had a positive effect. 


The principles and guidance will ensure that good practice becomes the norm rather than  the exception and will restore confidence in incentive exercises as a legitimate liability management tool.


It is encouraging that so many organisations are supportive of the Code."


Margaret Snowdon OBE, Chair of the Incentive Exercises Monitoring Board