Maxwell Communications Pension Plan Complaint - the ...

The ParliamentaryOmbudsmanMaxwellCommunicationsPension Plan ComplaintHC 455

The ParliamentaryOmbudsmanMaxwell Communications PensionPlan Complaint1st REPORT – SESSION 2004-2005Presented to Parliament Pursuant to Section 10(4)of the Parliamentary Commissioner Act 1967Ordered byThe House of CommonsTo be printed on23 March 2005HC 455 London : The Stationery Office£4.25

ContentsPageForeword by the Parliamentary OmbudsmanivChapter 1Summary 1Chapter 2Full report 2Background 2The complaint 2Key events 2Relevant legislation 3Jurisdiction 3Gathering the evidence 3The Ombudsman’s decisions 4Reasons for the decisions 4Complaint of maladministration by the UnitRecycling of State Scheme Pensions (SSPs)DelayConclusion 7March 2005 • Maxwell Communications Pension Plan Complaintiii

ForewordI am laying before Parliament under section 10(4) of the ParliamentaryCommissioner Act 1967 this report, which contains the results of my Office’sinvestigation into a complaint that the Department of Social Security and,subsequently, the Department for Work and Pensions failed properly to overseeand administer the distribution of money collected from financial institutions forthe benefit of certain Maxwell pensioners; that the Department later unreasonablyrefused to give financial assistance to some of those pensioners; and that theytook too long to reach that decision.The complaint, referred by Mr Mark Oaten MP, was from a member of theMaxwell Communications Pension Plan who complained that the Plan hadreceived too small a share of the £276 million that had been collected and that,by the time the Department decided that they would not assist the Plan further,the Plan's financial position had deteriorated.A recent Early Day Motion on the subject attracted over 100 signatures and, inview of that wider interest, I have decided to issue this report.Ann AbrahamParliamentary OmbudsmanMarch 2005iv • Maxwell Communications Pension Plan Complaint • March 2005

Chapter 1. Summary1. Mr A made three complaints.That the Maxwell Pensions Unit,which had been set up by theDepartment of Social Security (DSS)failed properly to oversee andadminister the distribution of £276million collected from financialinstitutions for the benefit of certainMaxwell pensioners, with the resultthat the Maxwell CommunicationsPension Plan (the Plan), of which heis a member, received an unfairlysmall share.That the Department for Work andPensions (DWP) acted unreasonablyin refusing to give further financialassistance to the Plan. (TheSecretary of State had previouslyagreed to postpone collection ofcertain amounts owed to the NationalInsurance Fund.)That DWP took too long to make thatdecision.2. We found that, while the MaxwellPensions Unit had been part of DSS andexercised some administrative functionson behalf of that Department, albeit atarms length, the distribution of the £276million had not been an administrativefunction of the Department and was,therefore, outside the Ombudsman'sjurisdiction.4. We found that DWP did not takean unreasonably long time to deal withthe Plan’s request for financial assistance.On that basis, we do not consider thattheir handling of the request wasmaladministrative. There were matters ofdetail that had to be sorted out beforethey could consider whether or notfurther Government money should bemade available. Officials needed to ensurethat Ministers had all of the necessaryinformation before asking them to make adecision and, in particular, they had toensure that the implications of thedecision were taken fully into account.Such a significant and politically sensitivedecision could not be taken lightly or veryquickly.5. While we sympathise with thepredicament in which the Plan's membersnow find themselves, we have seen noevidence that it was caused bymaladministration on the part ofDSS/DWP.3. We did not consider that DWPacted unreasonably in refusing financialassistance to the Plan. The Secretary ofState could not implement the Plan'sproposal to 'recycle' payments made tothe National Insurance Fund by otherpension schemes for the benefit of thePlan. The Government had made clear, atthe outset, that it was not obliged to usetaxpayers’ money to make good lossesresulting from the fraudulent misuse ofpension funds. The Secretary of State'ssubsequent refusal to provide financialassistance to the Plan was consistent withthat policy. We cannot question the meritsof decisions taken properly in line withGovernment policy.• Maxwell Communications Pension Plan Complaint • March 2005 1

Chapter 2. Full reportBackground6. In December 1991, after the deathof Robert Maxwell, a shortfall of £450million came to light in Maxwellcompanies’ pension schemes. It wasdiscovered that the schemes were notable to meet in full their future financialcommitments, for example, to pay outemployees’ pensions. In 1995 an out ofcourt settlement, known as the 'MajorSettlement’, was reached, distributing£276 million amongst four separateMaxwell pensions schemes (theSchemes).The complaint7. Mr A complained that the MaxwellPensions Unit (the Unit), set up by theDepartment of Social Security (DSS),failed properly to oversee and administerthe distribution of the Major Settlement,with the result that the MaxwellCommunications Pension Plan (the Plan),of which he is a member, received anunfairly small share of the availablemoney. (The Plan received £44 million,£3 million short of its bid.) Mr Acomplained that the Unit failed toexercise due care and did not ensure thateach of the Schemes constructed their bidon a similar basis.8. complained of delay by DSS, andlater by the Department for Work andPensions (DWP), which took over DSS'sresponsibilities in June 2001, in reachinga decision on a request, made by thePlan's trustees (The Law Debenture TrustCorporation – LDTC), for the Governmentto ‘recycle’ to them £30.5 million of statescheme premiums (SSPs) paid to theGovernment by one of the other Schemes(Scheme X) to have benefited from theMajor Settlement. He said thatdiscussions with DSS and DWP hadcontinued for three and a half years,during which time the Department hadgiven the impression that a positiveconclusion was likely. DWP had eventuallyrefused the request, by which time thefinancial position of the Plan hadworsened considerably. Mr A describedDWP’s decision as petty andunreasonable.Key events9. On 8 June 1992 the Secretary ofState for Social Security made astatement in the House of Commonsabout the plight of the Maxwellpensioners. Among other things, he saidthat he was setting up a ‘special unit in[his] Department' to 'work alongside thetrustees and others seeking to secure thereturn of assets and their equitabledistribution between the schemes.’ Hesaid that the Unit would administer a£2.5 million emergency fund, usingGovernment funds, to help keep pensionsin payment in the short term. Paymentsfrom the emergency fund wererefundable.10. The Maxwell Pensioners Trust (theTrust) was set up on 17 July 1992 tomanage a trust fund to which Cityinstitutions contributed for the benefit ofMaxwell pensioners. The Trust waschaired by Sir John (now Lord) Cuckney.Over the next couple of years the Trustgathered a fund of some £6 million, whichwas distributed by the Trustees. (Theallocation of that money by the Trusteesis not part of the complaint.)11. Although in January 1993 a SocialSecurity Select Committee hadrecommended that Lord Cuckney shouldact as mediator, he was not initiallyinvolved in the attempts to broker out ofcourt settlements between the Schemesand those institutions against which theSchemes had potential legal claims.Instead, that work was taken forward by aHigh Court judge, with a particular interestin mediation, who attempted to broker aseries of deals, known as the GlobalSettlement, in return for the dropping ofall claims against the financial institutionswhich were to be party to the settlement.12. When the Global Settlement talksfoundered in December 1994, LordCuckney was invited – by some of theparties to those talks – to try to take thematter forward. On 19 January 1995 hewas released from his appointment asChairman and Trustee of the Trust. On 24January 1995 Lord Cuckney wrote to therepresentatives of the Schemes, declaringhis position as adviser to the Secretary of2 March 2005 • Maxwell Communications Pension Plan Complaint •

State for Social Security on the Maxwellpensions affair and saying that, with theSecretary of State's support, he hadaccepted an invitation from the partiesinvolved to try to build on the worktowards a Global Settlement. He said thathe was not privy to the details of thenegotiations that had already taken placeor to the papers about those negotiations.He stressed that he did not see his roleas that of a true mediator, rather he coulddo ‘no more than help the parties toreach agreement among themselves.’Over the next few months a settlement,known as the Major Settlement, worth£276 million, was reached.Relevant legislation13. When a pension scheme, whichhad been contracted out of the StateEarnings Related Pension Scheme(SERPS), contracts back into SERPS, thenational insurance contributions thatwould have been payable but for thecontracting out fall due to the NationalInsurance Fund by way of SSPs. Theliability to pay such SSPs is a priority debtand, in normal circumstances, is payablebefore other liabilities, such as those tothe scheme’s beneficiaries. However,Regulation 20 of the Occupational PensionSchemes (Contracting Out) Regulations1984 gives the Secretary of State thepower to postpone the collection of SSPsif he considers that collection would beprejudicial to the interests of thescheme’s members. That power isdiscretionary. (Although those regulationswere revoked with effect from April 1997,regulation 20 remains in effect. 1 )Jurisdiction14. Section 5(1) of the ParliamentaryCommissioner Act 1967 (the Act) limitsthe Ombudsman’s jurisdiction to theinvestigation of ‘action being taken in theexercise of administrative functions’ ofbodies listed in Schedule 2 to the Act.The Ombudsman cannot investigate theactions of a body not listed in Schedule 2,nor can she investigate the actions of aSchedule 2 body other than those takenin exercise of that body’s administrativefunctions. DSS was, and DWP is, listed inSchedule 2 to the Act. The Ombudsmancannot question the contents oflegislation or the merits of governmentpolicy.15. The Trust was a private noncharitabletrust, with its own legalidentity. It was not listed in Schedule 2to the Act and is not, therefore, withinthe Ombudsman's jurisdiction.16. The administrative actions of theSecretary of State for Social Security arewithin the Ombudsman’s jurisdiction. TheTrust Deed recognised the Secretary ofState for Social Security as a ‘specifiedperson’, giving him certain powers, forexample to change the name of the Trust,to amend or add to the schedule definingthe considerations to be taken intoaccount when disbursing funds (Schedule2 of the Trust Deed), and to requirewritten reports. However, the Trusteeshad absolute discretion in thedisbursement of the Trust's funds subjectto the constraints of Schedule 2 of theTrust Deed.Gathering the evidence17. DWP were unable to providepapers in connection with the distributionof the £276 million. They told us thatLord Cuckney’s negotiations to achievethe Major Settlement had beenconfidential, and DSS had not been privyto his discussions or to the mechanics ofthe allocation of the money; they did not,therefore, have any papers to give us.However, they were able to provide somegeneral background information and toanswer some of our questions byspeaking to staff who had been employedin the Unit at the relevant time. Thecomplainant and his representative kindlyprovided some papers but, given thatthey had not been directly involved in theadministration of the Plan, their ability toprovide more detailed information was,understandably, limited. With thecomplainant's permission, we approachedLDTC, who provided a large number ofdocuments at the end of July 2004. Wealso spoke to Lord Cuckney. DWP wereable to answer questions and to providepapers in connection with Mr A’scomplaint about the refusal to providefurther Government funding and the timewhich it took them to reach that decision.18. We have considered, verycarefully, all the evidence that has beenprovided, as well as the representationsmade by Mr A, his representative andLDTC, and the information given by DWPand Lord Cuckney in response to ourenquiries.1 Regulation 77 of the Occupational PensionSchemes (Contracting-out) Regulations 1996• Maxwell Communications Pension Plan Complaint • March 2005 3

The Ombudsman's decisions19. The reasons for not pursuingfurther Mr A’s complaint about the Unit’srole in the allocation of the £276 millionare set out below. We have seen noevidence that DWP actedmaladministratively in refusing financialassistance to the Plan, and do notconsider that they took an unreasonableamount of time to reach that decision.Reasons for the decisionsComplaint of maladministration by theUnit20. Before we could begin aninvestigation of this aspect of Mr A’scomplaint, we had to establish whether, inproviding support to Lord Cuckney’sfacilitation of the Major Settlement, theUnit were carrying out an administrativefunction of a body within theOmbudsman’s jurisdiction. We haveconcluded that they were not.21. From the evidence available to us,we were satisfied that Lord Cuckney wasnot carrying out an administrativefunction on behalf of DSS when heundertook, in January 1995, to try tofacilitate an agreement in the wake of thecollapse of the Global Settlement. Putsimply, although he had the Secretary ofState’s support for accepting theinvitation to act, he was not taking onduties that would otherwise have fallen tothe Secretary of State or to DSS officials.The brokering of an out of courtsettlement between the Schemes and thevarious financial institutions was not anadministrative function of DSS. That putsany complaint about the way in which the£276 million was shared outside theOmbudsman’s jurisdiction.22. Some of the Plan’’s beneficiarieshave said that they feel now that, even ifthe Unit's staff were not – in law –carrying out an administrative function ofDSS, it would be unjust if that enabledDWP to escape liability for what they seeas the unfair allocation of the £276million. However, the question for us wasconfined to whether or not the actionscomplained of were carried out in pursuitof the administrative functions of theDepartment. After very carefulconsideration, we have concluded thatthey were not, and it follows that wecannot intervene in this aspect of Mr A’scomplaint.23. We can see why the Plan’smembers and LDTC may have believedthat the Unit were acting on behalf ofDSS in this matter. Staff within the Unithad been involved in the failed attempt tofacilitate a Global Settlement; they hadworked closely with Lord Cuckney in hisrole as Chairman of the Trust and, inearly 1995, in his attempts to broker theMajor Settlement. On occasions theyspoke directly with LDTC about theprogress of those talks and, on others,they wrote to LDTC on DSS headednotepaper about the progress of LordCuckney’s work. Lord Cuckney sometimesused the Unit's headed notepaper in hiscommunications with LDTC. All that will,understandably, have reinforced theimpression that DSS were involved inallocation of the £276 million. Thatimpression may also have been reinforcedby the fact that some of the Unit's work,for example, the assistance they providedwhen the Schemes ceased to contract outand their members were brought backinto SERPS, was undertaken in pursuit ofDSS’s administrative functions. The Unithad a wider remit than was normal for aGovernment agency and the lines ofaccountability would not have beenimmediately obvious. With hindsight, wethink that DSS ought to have been morecareful to ensure that everyoneunderstood that the work undertaken bythe Unit’s staff in support of LordCuckney’s efforts to facilitate the Majorsettlement was not part of theDepartment’s administrative functions.Their failure to do so merits criticism butit does not bring the issue of theallocation of the £276 million within ourjurisdiction.24. LDTC have already raised withDWP the role played by the Governmentin the Major Settlement, and theParliamentary Under Secretary for Workand Pensions, wrote to them on 14 April2003 about that. She said that the Unithad worked under the guidance of LordCuckney and had been independent ofGovernment. She said that, by providingstaff and accommodation to facilitate LordCuckney’s work and allowing the use ofthe DSS letterhead, the Government hadindicated its support for the resolution ofthe issues, but matters discussedbetween Lord Cuckney, the Unit’s staff,the Trustees of the Schemes and thefinancial institutions had been'confidential and could not be4 March 2005 • Maxwell Communications Pension Plan Complaint •

communicated to the Department orother government bodies’. The Secretaryof State wrote to LDTC about this matteron 26 November 2003. He said that ‘…theMajor Settlement represented a deal,brokered by Lord Cuckney who wasworking independently of Government,assisted in his task by civil servantsworking directly to him.’25. We have not seen any evidence topersuade us that those explanationsmisrepresent what happened or, moreimportantly, that the facilitation of the outof court settlements was anadministrative function of DSS.Recycling of State Scheme Premiums(SSPs)26. Regulation 20 of the OccupationalPension Schemes (Contracting-Out)Regulations 1984 gives the Secretary ofState the power to postpone thecollection of a scheme’s SSPs where heconsiders that collection would beprejudicial to the interests of itsmembers. The Secretary of Stateexercised his discretion to require anotherScheme (Scheme X) to meet its SSPliability once it was in a position to do sowithout prejudice to its own members,and we found nothing amiss in that. Theregulations do not give the Secretary ofState the power to divert the SSPscollected from one scheme to anotherscheme, rather than to the NationalInsurance Fund to which the SSPs areowed. We therefore see nothingmaladministrative in the refusal to‘recycle’ the £30.5 million paid back intothe National Insurance Fund by SchemeX.27. When the Secretary of Stateannounced that he would postponecollection of the four Schemes’ SSPs, hesaid ‘…no government could accept anobligation to use taxpayers’ money tomake good losses resulting from fraud.’He went on to say that he believed theGovernment should ‘…exercise thoseresponsibilities [it has] in ways whichactively assist the pensioners’ position…’and, in that context he had ‘…decided toexercise this discretion, on a scheme byscheme basis….’ We are satisfied that itwas clear from the outset that eachScheme’s position would be consideredindependently of the others’ should any oftheir positions change in the future. Itwas also clear that the Government didnot consider that they should fund arescue package for those pensioners whohad suffered a loss as a result of MrMaxwell’s misappropriation of theirpension funds. The agreement topostpone collection of SSPs did not createa fund of money available to the Schemesthat could be shared or circulatedbetween them, rather it was a series ofseparate agreements to suspendtemporarily debts that would otherwise bepayable as a matter of priority.28. Having said that, we understandthat LDTC used the term ‘recycling’ toencompass not simply the transfer to thePlan of Scheme X’s repaid SSPs but alsosome other funding package which mightenable them to meet in full theirmembers’ expectations. While we canunderstand their disappointment at theGovernment's eventual refusal to givesuch assistance, that is a matter ofGovernment policy, in which we cannotintervene. The matter was considered, onits merits, by Ministers, who decided notto assist; that decision was not anadministrative decision.Delay29. Mr A complains that DWP took toolong to make a decision on LDTC’srequest for financial assistance. It is clearthat the matter was far fromstraightforward, and one on whichMinisters had to decide personally. It wasnot a matter which officials could decideon an administrative basis. While, withhindsight, it would have been better forthe Plan if officials had put the matter toMinisters sooner, we have not seen anyevidence that they were responsible forunreasonable delays.30. From the papers we have seen, itappears that early in 1999 disquiet aboutthe relative positions of the variousSchemes surfaced, and discussions aboutwhether it might be possible to merge theSchemes began. The discussions appearto have been concerned with equalisingthe position of the different Schemes'members, and there was somesuggestion that this would enable SchemeX to divert money, which would otherwisebe used to pay SSPs, to the benefit of thePlan’s members. In May 2000 the notionof ‘pooling’ was discussed at a meeting atwhich DSS were represented. In June2000 a discussion paper, prepared in• Maxwell Communications Pension Plan Complaint • March 2005 5

advance of a meeting at which DSS wererepresented, explored a variety of optionsincluding the technical issues which amerger would raise. The possibility of amerger was discussed again in July andAugust 2000.31. The first mention of ‘recycling’,among the papers we have seen, appearsto have been made at a meeting in July2000 when the notion of a scheme to‘claw back’ SSPs was noted and DSSagreed to ‘…consider further whethermoney clawed back in respect of onescheme could be used to paybeneficiaries’ claims in respect of anotherscheme.’ However, that suggestion was inthe context of the merger proposal, anidea which continued to be pursued forsome months.32. LDTC wrote to DSS on 30 January2001 formally putting forward theproposal to recycle repaid SSPs. Theysaid that they had explored, with theother trustees, ‘… all avenues forlegitimately transferring the surplus in[Scheme X] to the Plan but no way hadbeen found. [Scheme X] must thereforepay this money in settlement of its debtfor [SSPs].’ They went on to say that ‘Ifthe Government were to retain thismoney, it would be inconsistent with theGovernment's public announcement in1992 that it would not take money for[SSPs] ahead of the interests ofpensioners.’ Over the next few months,LDTC continued to discuss the details oftheir proposal with DSS. From thecorrespondence we have seen, officialswere considering whether, and how, anyfunds might be made available to thePlan. We have seen no evidence thatthose officials offered any guarantees;indeed we have seen that they expressedsome caution about the likely outcome.For example, in a letter dated 8 March2001, DSS said that it might be askedwhy, if the Plan was secure on an ongoingbasis, any further support wasneeded. In June 2001, LDTC made a notethat they had spoken to DWP and askedabout the prospect of obtainingGovernment money to buy annuities.They noted that the answer they hadbeen given was that it was ‘poor’.33. On 20 July 2001 DWP wrote toLDTC and said that they did not think thatthe Secretary of State’s 1992announcement would bear theinterpretation that LDTC had suggested.They went on to say, however, that theyhoped that once other negotiations 2 hadbeen completed, they might be in abetter position to assess ‘…whatadditional help, if any [our emphasis],might be available to the Plan…’ and thatthey did not ‘think it appropriate toconsult Ministers on this before thetransfer problem was bottomed out.’34. On that basis, we do not think thatDSS/DWP can be said to haveunreasonably given LDTC false hopeabout the likelihood that the Governmentwould agree to the recycling proposal.When the matter was first raised withthem, it was in the context of a merger ofthe Schemes and, while that option wasbeing pursued, we accept DSS could nothave reached a firm decision. Once it wasclear that a merger was not possible, ittook DSS six months (between Januaryand July 2001) to consider the Plan'sproposal. We do not think that was anunreasonable length of time.35. We have seen among the papers areference by LDTC to an official havingestimated that there was a 90% chanceof further financial assistance but wehave not seen any other evidence thatsuch an estimate was given. The evidencewe have seen suggests that DSS wereopen to exploring ideas with LDTC andsought additional information in order toafford LDTC the opportunity to make thestrongest case that they could. However,throughout the process they also madeclear that they could not make anypromises and that the matter was,ultimately, one for Ministers, not officials.36. Having rejected the idea ofrecycling Scheme X’s SSPs, thecorrespondence turned, in 2002, towhether there were other ways in whichthe Government could provide financialsupport to the Plan. It was not until 1November 2002 that DWP told LDTC thatMinisters had decided that governmentfunding would not be made available. Thepapers show that officials had hoped toput the submission to Ministers sooner,but it was delayed for a number ofreasons, none of which we consider to bemaladministrative. In part, thesubmission was delayed because of theneed to resolve the position of ProjectUniverse. That does not seemunreasonable, given that liability for those6 March 2005 • Maxwell Communications Pension Plan Complaint2 Negotiations in respect of Project Universe - atransfer of people into the Plan, which was inprogress at the time of Maxwell’s death.

(prospective) pensioners had a bearing onthe size of the Plan’s projected deficit.(By DWP’s account, it was not untilDecember 2001 that it was establishedthat the Plan were not liable for ProjectUniverse members. While we have notseen firm evidence of when thatconclusion was reached, it is clear fromthe papers we have seen that it was noearlier than December 2001.)37. The submission also appears tohave been delayed because officialsjudged that it was appropriate to make acomposite submission dealing with anumber of Maxwell related issues, someof which did not involve the Plan, at thesame time. That seems sensible. It wasnot unreasonable, in the circumstances,for officials to want to draw together theissues to enable Ministers to makeproperly informed decisions, which wouldtake full account of any knock-on effectsand any issues of equity of treatment. Wehave seen the submission and aresatisfied that that was a reasonableapproach. Unfortunately, the process didnot proceed as quickly as DWP expected.On several occasions they said that theyhoped soon to be able to make asubmission to Ministers and then foundthat they needed more information. Whilethey might have been more proactive inkeeping LDTC informed about progress,they responded to LDTC’s enquiries andexplained the delays. The submission,dealing with the Plan’s request and theother Maxwell related issues, was put toMinisters on 4 July 2002; that does notseem to us to have been unduly slow.38. Ministers asked for some additionalinformation and for clarification of certainpoints. On 1 November 2002, aftercareful consideration of the submission byMinisters, DWP told LDTC thatGovernment funds would not be given.While we can see that the Plan mighthave preferred to have received adefinitive answer sooner, we have foundno evidence of maladministration causingthe decision to be delayed, nor have weseen evidence to show that officialsmisled LDTC about the prospects ofsuccess. Officials needed to take care toensure that they briefed Ministersproperly and, given the complexity andsignificance of the decisions involved, weare not persuaded that the matter couldhave been dealt with very quickly.Conclusion39. While we sympathise with thepredicament in which the Plan’s membersnow find themselves, we have seen noevidence that it was caused bymaladministration on the part ofDSS/DWP.Printed in the UK by The Stationery Office Limitedon behalf of the Controller of Her Majesty’s Stationery Office177736 03/05 19585 302830• Maxwell Communications Pension Plan Complaint • March 2005 7

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