The Pensions Regulator's policy on expenses and other financial arrangements for non-executive members of the Board and Determinations Panel members, and gifts and hospitality policy for board members and Determinations Panel members.
Approved on 21 February 2024.
Policy on expenses and other financial arrangements for non-executive members of the Board and Determinations Panel members
Non-executive members of the Board and members of the Determinations Panel may claim reimbursement of reasonable out-of-pocket expenses incurred in carrying out their duties as office holders in The Pensions Regulator (TPR). Members are requested to bear in mind the public sector, levy funded, nature of TPR’s mandate in deciding on appropriate travel, subsistence and hospitality arrangements, and the importance of perception in these leadership positions. You should note that a parliamentary question could be asked, or a request under the Freedom of Information Act be made, seeking figures for TPR’s Board or Determinations Panel’s expenditure on expenses or hospitality. In line with government policy the cost of alcoholic drinks is not normally reimbursable.
Amounts reimbursed via an expense claim, and those paid directly by TPR, will be published on TPR’s website.
Claimable expenses – travel and subsistence
Best value is most likely to be achieved by using the central TPR arrangements, which are applicable to TPR staff. TPR uses a booking agency for hotels and travel by air and rail, and members are encouraged to use this to enable us to obtain best rates. Bookings can be made by contacting the Corporate Secretariat.
TPR will pay for hotel accommodation if a member would otherwise need to leave home before 7am to make a morning appointment or would return home after 8pm after an evening appointment.
TPR will pay for business travel in attending TPR duties which for non-executives and Determinations Panel members is defined as:
- travel from home to a TPR office and return
- travel from home to other business venues and return
- travel from a TPR office to other business venues and return
Payment for accommodation and travel booked through the agency will be made directly by TPR and will not require an expense claim.
Any overnight expenses incurred which are not allowable within this policy should be settled by members at time of checkout.
If it is not practicable to book travel and accommodation through the agency or members wish to make personal arrangements then members can pay the bill and submit a claim for reimbursement with receipts or used tickets.
Claim period: all expenses should be claimed within three months of being incurred. Claim forms are available from the Corporate Secretariat.
The following expenses are claimable (with valid receipts where appropriate)
Where a cheaper cost can be achieved by non-executives/panel members by another class than the standard rate fares, then this is also covered.
Rail travel: standard class. First class rail is allowed only if it is cheaper than the standard fare.
Travelling in London: payment can be made by Oyster card, debit card or smart phone contactless payment. Travel expense claims must be evidenced by ticket receipt unless payment is made by debit card or smart phone contactless payment and individual fares are less than £5. Oyster cards and contactless cards can be registered online in order to view business travel history statements which can then be used as supporting evidence for a claim.
Air travel: standard fare. Business class is allowed in exceptional circumstances with the Chair’s or Chief Executive Officer's (CEO) prior agreement.
Mileage for use of private car: by requesting to use your private motor vehicle, you are making a legal declaration that you hold a valid licence and the vehicle has an MOT if required and appropriate insurance covering the business journey.
Fines: where using a private or official vehicle incurs a penalty or fine, the cost will be passed to the driver. TPR will not pay any fines in connection with road traffic offences.
Standard rate: 45 pence per mile up to 10,000 miles and 25 pence thereafter (where public transport is not reasonably practicable, or it is more expensive, for example for peak time long distance UK travel).
Public transport rate: 25 pence per mile (where public transport is practicable but your choice is to use your car).
Bicycle travel: you may prefer to use your bicycle for certain business journeys. If so, you must use the most economical routing, taking into account:
- the time spent travelling
- the cost of the journey
- the needs of the business
We will pay 20 pence per mile if you use your bicycle for TPR business.
Taxis: for example when transporting large amounts of papers.
Accommodation
The room rate guidance:
- London £150 per night
- other UK £100 per night
Overseas accommodation
Booking via TPR is possible though you may occasionally be required to settle the hotel bill in total on departure, and then submit an expenses claim for reimbursement. Please note that in these cases, where the booking agency cannot bill for some overseas hotels, they may need to quote your credit card details in order to secure the booking.
With the variability of room rates these are not always achievable but members are requested to adhere to them whenever possible. If you do need to book a hotel, please check whether breakfast is included in the rate. When booking via TPR we will endeavour to book a hotel within the existing policy that includes breakfast. Where this is not possible you may purchase breakfast separately, in line with the subsistence policy, which allows you to claim a maximum of £5.
Subsistence: for an evening meal whilst staying overnight the guidance is up to £25 with receipts.
Incidentals: for example non-alcoholic drinks, snacks, newspapers and personal phone calls up to £5 per night (receipts are required).
Credit card receipts will not be accepted unless accompanied by an itemised bill. If more than one member attends the meal you should detail this and split the bill accordingly. Anything claimed above and beyond the subsistence cap will be reduced on the claim form in line with the policy. You will not necessarily be contacted regarding this.
Staying with relatives
If you choose to stay with friends or relatives instead of in a commercially-run hotel, you can claim the notional cost (the amount you would have paid) of a meal for yourself and the personal incidental (non-essential) expenses allowance. These are as follows:
- £25 per night for the notional cost of a meal for yourself (receipts not required)
- £5 per night for personal incidental expenses (receipts required)
As members of the Determinations Panel are paid a daily rate for work undertaken, TPR will not pay Determinations Panel members for travel time when attending Determinations Panel duties.
Guidance on expenses for meetings when not staying overnight1
The Regulator will reimburse reasonable meal expenses incurred. The following guidance is intended to help members decide on when it might be appropriate to claim:
- breakfast – if TPR business necessitates leaving home before 7am you may claim up to £5 for the cost of breakfast
- lunch – if you are working on TPR business during lunchtime and lunch is not provided you may claim up to £10 for the cost of lunch
- evening meal – if TPR business necessitates you being unable to return home by 8pm you may claim up to £25 with receipts
Where a number of members are attending a meeting each member should normally claim reimbursement for their own subsistence. Alternatively if one member pays for a meal, they may claim on behalf of other members and TPR staff and a list of attendees covered by the claim should be submitted.
Exceptionally, non-executive board members only may claim the full cost of a working meal2 taken with another non-executive board member or a member of TPR staff, at any location, subject to a maximum cost of £15 per person.
Authorisation of meetings
To enable consistent messaging of our communications and to avoid potential conflicts of interest the Chair and/or the CEO should be notified in advance of individual members’ meetings or invitations to speak on behalf of TPR (that is, other than official meetings of the Board, its committees, panel meetings or meetings that are organised by TPR staff, the chair or CEO).
Footnotes for this section
- 1 Primarily when away from home and office, and exceptionally if a meeting is needed near the office or home.
- 2 Excluding alcoholic beverages.
Gifts and hospitality policy for members of the Board (executive and non-executive members) and Determinations Panel members
Acceptance of gifts
It is possible members may be offered gifts in connection with their activities as officers of TPR.
In line with DWP and government our policy for gifts and hospitality applies to TPR members. All offers of gifts however small and whether or not accepted should be reported to the Enterprise Compliance and Complaints team (EC&C).
The following is a summary of the policy. If you are offered a gift please contact the EC&C team for advice on how the policy applies:
- cash should not be accepted
- gifts of value below £25 can usually be accepted as long as they are occasional and not repeated offers
- gifts of value above £100 should not be accepted
- guidance should be sought from the EC&C team in relation to offers of gifts of value between £25 and £100
- gifts should not be accepted personally (giving rise to a tax liability) but on behalf of TPR
Giving hospitality
Where meetings are hosted by or at TPR refreshments and/or a modest lunch as appropriate will usually be provided. A working dinner may be provided for such meetings, particularly if, for example meetings span consecutive days, start early or finish late. The guidelines below for Chair and CEO hospitality are also relevant in this case.
Hospitality is the provision of refreshments or a meal (whether on or off business premises) to guests who are not employees or officers of TPR. It is accepted that it will occasionally be appropriate for the Chair, Panel Chair or board members to offer modest hospitality.
Where hospitality will not be offered, a member acting on behalf of TPR and meeting someone from another organisation over a ‘working meal’, should normally make clear when arranging the event that TPR is not ‘hosting’ it. In this situation the member would claim reimbursement only of their own personal expense.
A board member or the Panel Chair may host a working lunch or dinner with outside bodies on behalf of TPR with the prior agreement of the Chair or the CEO. The cost of a meal will be reimbursed up to a total of no more than £60 per head.
The CEO and Chair when hosting a meeting may offer hospitality up to a total of £60 per head.
The provision of alcoholic drinks at public expense is a very sensitive issue and alcohol may only be provided with the express, prior, written permission of the CEO. They are responsible for ensuring that:
- alcoholic drinks are served only in exceptional circumstances
- a written submission is always produced clearly setting out the business reasons for, and estimated cost of, the provision of alcohol; and
- written approval is provided in advance based upon the written evidence
Only modest amounts of alcohol may be purchased at public expense – a reasonable guide would be no more than two glasses of moderately priced wine with a meal for each attendee. There must be no suggestion of extravagance.
Extra care should be taken to consider the appropriateness of the provision of alcoholic drinks at events where staff may be travelling after the event. TPR must act with responsibility towards its employees; in particular due recognition must be given to the inherent dangers associated with the consumption of alcohol and driving.
The CEO may not further delegate their authority to approve the provision of alcohol.
The CEO should retain a record containing details of the reason for each event – i.e. official entertaining, management conference or internal business function - the number of attendees at each event at which alcohol is provided at public expense and the cost of the alcohol provided for test check or audit.
Receiving hospitality
It is important that members are (and are seen to be) independent. It may be permissible on occasions to accept modest hospitality such as working lunches or other meals when official business is conducted and it is a reasonable means of doing an effective job.
Members should notify the Chair or CEO before accepting hospitality and all offers should be reported to the EC&C team and will be recorded on the register of gifts and hospitality.
For guidance as to whether hospitality should be accepted, please consult the EC&C team.
Gifts and hospitality register
The EC&C team maintains a register of gifts and hospitality offered to board and determinations panel members, with a record of estimated values and whether accepted or not. Quarterly returns are published online.