Alberta Pensions Administration Corporation...The business plan sets out the priorities for the next...

Alberta Pensions Services Corporation

Business Plan

2014 – 2016

Table of Contents Executive Summary .......................................................................................................................... 3

Accountability Statement ................................................................................................................. 5

Our Commitment .............................................................................................................................. 6

Overview of the Corporation ............................................................................................................ 7

Five-Year Strategic Plan ................................................................................................................... 9

Strategic Priorities and Goals ......................................................................................................... 10

Detailed Business Priorities ............................................................................................................ 12

Performance Measures ................................................................................................................... 17

Proposed Budget ............................................................................................................................. 19

Financial Analysis .......................................................................................................................... 20

Risk Analysis .................................................................................................................................. 21

APS Business Plan 2014 – 2016 of 23

Executive Summary

The business plan sets out the priorities for the next three years commencing January 1, 2014 for Alberta Pensions Services Corporation (APS). Since incorporation in 1995, APS has proudly served Alberta’s public sector pension plans. Our job is to deliver responsive, focused services to clients of specific public sector pension plans, supported by ethical and risk-managed business practices. Current Pension Environment, Challenges and Opportunities The long term sustainability of defined benefit pension plans remains a key issue for many plan sponsors in Canada and around the world. The top issues affecting pension plans include funding, volatile investment returns, low long-term interest rates, increasing life spans and the growth in the dependency ratio resulting from the transition of the baby boomers into retirement. Canada’s pensions system faces two key social challenges: how to address the impact of increased life expectancy and how to increase retirement savings. In Alberta, the issue of public sector pension plan sustainability is anticipated to impact plan design, and APS must be ready to provide the plan administrative services required. Increased life expectancy, along with aging demographics, particularly in the pension plans served by APS, will inevitably increase demands on our services. While volumes increase, our clients will continue to expect timely and quality services. Today’s workforce is comfortable with technology and expects a work environment that is supported by modern applications and processes. They want access to information and tools that support them in their jobs. Our human resource and business policies and practices must be adaptive to attract and retain the kind of employees APS needs to respond to a changing environment. APS’ Plan This business plan works to the goals set out in APS’ Five-Year Strategic Plan, 2012 - 2016. Our business plan is forward-thinking, yet balanced and sustainable. We are shaped not only by external factors such as demographics and economics, but also by the needs and expectations of our shareholder and the trustee of the pension plans, as well as the specific needs of our clients, plan governors and employers. APS is focused on delivering high-quality, timely information and benefit services to our clients. APS embarked on a multi-year effort to modernize our key processes and systems starting in 2012. Over the next three years, APS will complete the modernization. At the end of the period, APS will have substantially increased our operational ability to adapt to change through improved technology, strengthened processing and data integrity, standardization of business processes and an enhanced pension administration policy review framework. Legislative compliance, including privacy, confidentiality and integrity of information, remain critical for APS to achieve its mission. APS is mindful of the financial environment faced by the pension plans. We remain committed to advancing our strategic plan in a manner that demonstrates responsible management of resources. APS is dedicated to building professional excellence and enhancing our clients’ understanding of the value of their participation in public sector pension plans. APS will continue to build its values-based culture and recognizes it holds unique knowledge and capabilities and, by sharing our expertise and professionalism, APS will contribute to strong public sector pension plans in Alberta.


Executive Summary

APS in 2016 Looking forward to 2016, APS is building its technology capacity and offering more web services for our clients and employers. Pensions are complex, but our vision is to make the pension experience easier. Our efforts to progress our operational abilities will further help us achieve our vision of providing timely and quality information to our clients. A client-focused approach to pension services will increase identification with, and understanding of, the benefits of public sector pension plans and, as a result, recognition of plan value will increase.


Accountability Statement

The business plan for the three years commencing January 1, 2014 has been prepared under the direction of, and with full accountability by, the Board of Directors and the President and Chief Executive Officer (CEO) for Alberta Pensions Services Corporation. The Board sets the overall strategic direction for the Corporation by:

• establishing the corporate Mission; and • providing strategic direction to management in the form of governing Ends and

Limitation Policies that deliver the objectives directed by the shareholder and trustee of the pension plans served (the President of Treasury Board and Minister of Finance on behalf of the Government of Alberta).

Using the foundation provided by our Mission and Ends Policies, we continue to deliver on our obligations to pension plans served. Our Ends and Limitation Policies focus the Corporation on risk management and good stewardship, balanced with quality and timely service delivery on behalf of these pension plans. The CEO, with the support of the Corporation, will carry out the Mission and deliver the objectives found in the Ends Policies through the initiatives found in this three-year business plan. Working together, we are committed to success in achieving this plan. [Original signed by:] Al Mondor, FCA

Board Chair


Our Commitment

Since incorporation in 1995, APS has proudly served Alberta’s public sector pension plans. Our primary focus is delivery of services to members and pensioners, supported by participating employers and the governors of specific public sector pension plans. We deliver our mandate through risk-managed, efficient and effective business practices. APS is adapting to an uncertain economic environment and increased service demands. Our clients want reassurance the investment and information entrusted to us is effectively managed and they want improved access to information and services. We must continue to enhance our ability to respond to client inquiries with timely, reliable and high-quality information and deliver services that reflect our corporate value of stewardship. In 2014, we are continuing to dedicate significant efforts and resources to multi-year projects that will substantially increase our operational ability to adapt to change through improved technology, strengthened processing and data integrity, standardization of business processes and an enhanced pension administration policy review framework. The outcome of these substantial efforts will be improvements in the Corporation’s efficiency and effectiveness in delivering services to members and pensioners. We are committed to improving our day-to-day operations. We are continuing to improve the reliability and availability of information with initiatives aimed at making information available online to support our services. We will continue to increase our interactions with employers through information and education initiatives; all aimed at increasing the quality and timeliness of services provided to plan members and pensioners. At APS, we recognize and appreciate that it is through the knowledge and commitment of employees we meet our obligations and achieve success. Therefore, a priority in this business plan is building a values-based culture and on developing and sustaining professional excellence for all our staff. APS continues to drive towards a future that includes shared values, improved technology, strengthened business processes and data integrity. We are excited about leveraging all these new and improved capabilities to deliver high quality and responsive services to our clients. [ Original signed by: ] Karen Adams

President and Chief Executive Officer


Overview of the Corporation

Mission On behalf of the trustee, obligations for risk-managed, efficient and effective pensions services are met; and the needs of plan beneficiaries, employers and plan governors are met at a cost that demonstrates good stewardship of resources. Vision APS is highly valued and trusted to:

• Make the pension experience easier. • Provide clear information and support. • Deliver service with skill and care. • Meet obligations and keep promises. • Demonstrate the value of pension plans.

Guided by shared values, our employees make it possible. Values Every employee at APS shares three common elements:

• Service – make every interaction count. • Quality – what we do, we do well. • Accountability– take responsibility.

Board Policies APS’ business is to provide comprehensive, reliable, timely and cost-effective pension services to meet the following Ends Policies as defined by the Board of Directors:

There is accurate and timely management of pension plan monies in the care or custody of the Corporation. This includes, but is not limited to:

1. Timely, accurate reconciliation, accounting for and reporting of all information and monies received and disbursed from each pension plan.

2. Timely, accurate reporting of matters required for compliance with the Income Tax Act (Canada) and other legislation required to maintain the registration of each pension plan under the Income Tax Act (Canada).

There is accurate and timely management and maintenance of information and records required for the proper administration of each pension plan.

Members, pensioners and beneficiaries receive:

• Timely, accurate information and decision-making support about their entitlements and obligations under each pension plan.

• Correct benefit entitlements when they are due.


Overview of the Corporation

Employers receive appropriate information and support to meet their needs related to pension administration. This includes but is not limited to:

1. Timely remittance, reconciliation, reporting and settlement of member and employer data and contributions.

2. Timely reporting respecting annual and triennial audits submitted to APS for review and reporting.

Plan governors receive accurate and reliable information to support their respective obligations and mandates.

The trustee receives accurate and reliable information and support to fulfill the trustee’s obligations for each pension plan.

Services The services provided by APS include:

• benefit calculations and payments; • member and pensioner communications, education and information support; • employer remittance management and reconciliations; • employer communications, education and information support; • plan governors’ services; • policy development and implementation; • communications design and delivery; • compliance, regulatory and financial reporting for pension plans; and • records maintenance.

Link to Alberta Finance Business Plan The APS link to the Treasury Board and Finance Business Plan 2013-2016 is to Goal 2: “Policy and regulatory oversight for the financial, insurance and pensions sectors that is effective, fair and in the interests of Albertans.”


Five-Year Strategic Plan

We are committed to our Five-Year Strategic Plan, 2012 - 2016. The priorities, activities and performance measures related to our strategic priorities in this business plan are directly related to the three-year milestones found in our Five-Year Strategic Plan.

In three years (2014) In five years (2016)

Self Service • All active plan members and pensioners have access to secure online services

Member Service • Service standards and measures adopted for members and pensioners

• Deliver to established service standards

Employee Engagement

• Employee engagement results improve five points year over year

• Employee engagement Canadian average is achieved

Plan Governors • Service standards and measures adopted for plan governors

• Deliver to established service standards

Pension Administration Simplification

• Reduce pension administration complexity to target

• Reduce pension administration complexity to target

Next Generation • First pension product(s) on new system

• All pension products on new system

Compliance • Reporting standards for legislative compliance adopted and standards met


Strategic Priorities and Goals

STRATEGIC PRIORITY 1: Using a managed service approach, deliver valued pension

services Goals:

• Communicate and engage with clients, employers, plan governors and the trustee to achieve alignment with information and service needs and expectations.

• Develop and implement strategies designed to increase the use of efficient, effective delivery methods.

• Continuously improve policies and processes to meet client, employer, plan governor and trustee needs and expectations.

Business Priorities (2014 – 2016):

S1.1. Develop and adopt standards for services delivered to clients and plan governors.

S1.2. Enhance the service experience for clients and employers. STRATEGIC PRIORITY 2: Build APS’ organizational capabilities in responding and

adapting more effectively to business challenges and ongoing challenges in the external environment

Goals: • Promote a values-based culture to ensure our behaviours, interactions and

decisions are guided by our shared values and in line with achieving our mission.

• Build an organizational culture that increases employees’ readiness to change and adapt.

• Develop initiatives that support the entire employee life cycle of attraction, retention and engagement, development and succession.


S2.1. Build a values-based culture and enhance our readiness for change. S2.2. Support and promote the entire employee life cycle of attraction, retention and

engagement, development and succession.


Strategic Priorities and Goals

STRATEGIC PRIORITY 3: Be adaptable and responsive to opportunities and risks Goals:

• Effectively manage the convergence of policy and process in the implementation of new technology.

• Continue to align APS pension policies and processes for compliance and service efficiencies.


S3.1. Next Generation project: Implement a system that is complete, accurate and unifies pension information.

S3.2. Streamline business processes and policies to improve efficiency and effectiveness, mitigate risk and enhance legislative compliance.

S3.3. Implement changes to the pension administration system and processes to support the Public Sector Pension Plan Sustainability initiative.

STRATEGIC PRIORITY 4: Governance Alignment Goals:

• Deliver on our corporate obligations to the shareholder. • Provide assurance that services are being delivered efficiently, effectively and

in a manner that manages risk. • Demonstrate support of policy initiatives of plan governors and the trustee.


S4.1. Deliver services in compliance with the Mandate and Roles document and Pension Services Agreements, and develop a comprehensive monitoring program to regularly review compliance with these obligations.

S4.2. Review the cost allocation formula and refresh the five-year strategic plan.


Detailed Business Priorities

S1.1. Develop and adopt standards for services delivered to clients and plan governors.

2014 2015 2016 Client Services:

• Service standards and measures adopted for clients.

• Services delivered to adopted service standards for clients (for services on Next Generation platform).

• Services delivered to adopted service standards for clients (for services on Next Generation platform).

Plan Governors:

• Service standards and measures adopted for plan governors.

• Service delivered to adopted service standards and measures for plan governors.

• Re-assess service standards and measures to ensure continued alignment with the plan governors’ needs.

S1.2. Enhance the service experience for clients and employers.

2014 2015 2016 • Continue to enhance capabilities

for clients and employer remote information sessions.

• Continue to enhance capabilities for client and employer online services.

• Review and enhance capabilities for client and employer online services.



S2.1. Build a values-based culture and enhance our readiness for change.

2014 2015 2016 • Communication, training, and alignment of internal processes to support values-based culture. • Define roles and develop job descriptions and team structures.

S2.2. Support and promote the entire employee life cycle of attraction, retention and

engagement, development and succession.

2014 2015 2016 • Continue support of entire employee life cycle.



S3.1 Next Generation project: Implement a system that is complete, accurate and unifies pension information.

2014 2015 2016 • Training completed for

Pensioner Services Delivery Group.

• Training completed for remaining Delivery Groups (Finance and Member Services).

• Go Live – Pension Payroll Delivery.

• Go Live – Finance Delivery.

• Go Live – Member Services Delivery.

S3.2 Streamline business processes and policies to improve efficiency and

effectiveness, mitigate risk and enhance legislative compliance.

2014 2015 2016 Corporate Records:

• Continue implementation of the new taxonomy for Member, Pensioner and Employer information segment records in conjunction with Next Generation project.

• Complete implementation of the new taxonomy for Member, Pensioner and Employer information segment records.

• Continue implementation of the new taxonomy for remaining information segments.

• Continue to establish appropriate information management program foundations including policy framework and training.

• Continue to establish appropriate information management program foundations including policy framework and training.

• Measure effectiveness of information management program foundations through CGSB compliance audit.

Process and Policy Simplification:

• In support of current business operations and in alignment with the Next Generation project, continue implementation of pension policy and business process improvements.



S3.3 Implement changes to the pension administration system and processes to support the Public Sector Pension Plan Sustainability initiative.

2014 2015 2016 • Changes required to the pension

administration system and processes to support the Public Sector Pension Plan Sustainability initiative are identified and implementation plan developed.

• Implementation of the required changes to the pension administration system and processes to support the Public Sector Pension Plan Sustainability initiative.

• Pension administration system and processes support the Public Service Pension Plan Sustainability initiative.



S4.1. Deliver service in compliance with the Mandate and Roles document and Pension Services Agreements and develop a comprehensive monitoring program to regularly review compliance with these obligations.

2014 2015 2016 Governance: • Develop framework to monitor

compliance with the Mandate and Roles document.

• Deliver services in compliance with the Mandate and Roles document for APS, adopted in agreement with the President of Treasury Board and Minister of Finance.

• Adopt, in agreement with the President of Treasury Board and Minister of Finance, a pension services agreement for APS.

• Develop framework to monitor compliance with the Pension Services Agreement.

• Deliver services in compliance with Pension Services Agreement.

S4.2. Review and refresh the cost allocation formula and five-year strategic plan.

2014 2015 2016 Cost Allocation Formula Review: • Annual report on cost allocation

and impact analysis. • Formal review of

cost allocation formula.

• Annual report on cost allocation and impact analysis.

Five-Year Strategic Plan: • Refresh five-year strategic plan.


Performance Measures

Our performance measures are evolving as we focus our attention on being a performance-driven and accountable organization. These key performance measures represent the outcomes and outputs of APS’ day-to-day operating activities as well as the initiatives we are undertaking each year to improve service delivery. We review our measures at least annually to ensure they remain meaningful and relevant to our stakeholders while maintaining a level of continuity that allows us to demonstrate progress against the desired outcomes year over year.

Actual 2013

Target 2014

Target 2015

Target 2016

1. Valued Services Client Satisfaction Client satisfaction is a composite weighted average of the satisfaction that clients (members/members in transition/pensioners with each group weighted equally) have expressed in service and products provided by APS. The target is consistent with satisfaction scores attained in prior years.

Client Satisfaction 86 82 82 82

Employer Engagement Employer Engagement is measured by a composite score based on employer satisfaction and employer compliance with information requirements.

Employer Engagement 88 79 79 79

2. Organizational Capabilities Employee Engagement The Corporation participates in the Queen’s School of Business/AON Hewitt “Best Small and Medium Employers in Canada” survey. Engagement is “a measurable state of emotional and intellectual involvement and commitment of the workforce to organizational success”. APS’ targets for employee engagement are based upon prior year results from the survey and an understanding of APS’ desired placement in relation to comparable organizations.

Employee Engagement 72% 64% 69% Canadian average

Employee Development Employee development is a score based on the percentage of employees who have had performance discussions with their managers and have development plans in place.

Employee Development 97% 96% 98% 98%


Performance Measures

Actual 2013

Target 2014

Target 2015

Target 2016

3. Adaptable and Responsive Risk Management Maturity Risk Management Maturity is measured as the weighted average of APS’ Risk Management Framework Components, including governance, risk identification and assessment, response and control activities, risk and issues monitoring and resolution, and measurement and reporting. The target, a balance of APS’ risk tolerance against cost, was developed by evaluating APS’ current operations and expected changes through automation, better controls and reporting, and improved issues management.

Risk Management Maturity 73% 73% 73% 73% Next Generation Milestones Next Generation is a multi-year project to replace aging technology, improve business process and enhance service delivery. The measure is based on achievement of annual project milestones.

Next Generation Milestones1 Met Met Met N/A

1 The Next Generation project is planned to be completed by end of 2015. Therefore, milestones have not been set for this project in 2016.

Process and Policy Simplification Process and Policy Simplification is a multi-year initiative to identify, prioritize and implement initiatives designed to simplify pension administration. The measure is based on achievement of annual simplification milestones.

Process and Policy Simplification Milestones Met Met Met Met

Reasonable Cost The target for Cost per Member is based upon the CEM Benchmarking Inc. (CEM) methodology for defined benefit pension plan administrators. This benchmark allows for comparison of cost structures against our peers in Canada. The targets were established using the published 2012 peer average total pension administration costs per active member and annuitants and applying the forecasted Alberta Consumer Price Index.

Cost per Member $148 $168 $174 $176


Proposed Budget 2013

Budget 2014 Plan

2015 Plan

2016 Plan

(millions)

OPERATING EXPENSES AND AMORTIZATION

Staff and related expenses $28.4 $30.9 $33.2 $34.7

Contract services 5.6 5.6 4.9 4.0

Materials and supplies 4.9 5.8 6.5 6.0

Data processing and maintenance 1.9 2.5 2.3 2.4

Amortization 2.3 2.5 4.2 6.4

Next generation project - 1.1 0.5 -

APS OPERATING EXPENSES AND AMORTIZATION $43.1 $48.4 $51.6 $53.5

PLAN BOARD EXPENSES

Plan specific 2.1 2.0 1.8 1.8

Plan board secretariat 2.0 2.7 2.9 3.0

PLAN BOARD EXPENSES $4.1 $4.7 $4.7 $4.8

TOTAL OPERATING EXPENSES $47.2 $53.1 $56.3 $58.3

CAPITAL INVESTMENT

Corporate 1.0 1.3 1.4 2.6

Next generation project 14.8 16.9 10.8 -

TOTAL CAPITAL INVESTMENT $15.8 $18.2 $12.2 $2.6

CEM Cost per member $163 $168 $174 $176


Financial Analysis There is a net increase of $5.9 million (12%) in the operating expense budget for 2014 compared to the 2013 budget. Increases are driven primarily by:

1. Anticipated inflationary and rate increases in salary and benefit costs that contribute to the $2.5 million increase in the “Staff and related expenses” category.

2. An increase in the facility lease costs and printing costs related to communications

materials for the phased implementation of the Next Generation project and plan sustainability initiatives in the “Materials and supplies” line item.

3. Additional software maintenance costs related to the implementation of the first of the

phased deliveries for the Next Generation project and increased licensing costs for the existing software applications.

4. Amortization costs of the first delivery of the phased implementation of the Next

Generation project in July 2014. Significant increases in amortization expense related to the project are noted in subsequent years.

5. Operating expenses for the Next Generation project for training related costs that are not

eligible for capital treatment under public sector accounting standards.

6. Plan board secretariat expenses for additional resources to provide board support services. Plan sustainability and governance related initiatives are significant drivers of the increases in the costs for this category.

The total capital investment for 2014 is increasing by $2.4 million from 2013. Ongoing Phase II activities of the Next Generation project accounts for $2.1 million of the increase.


Risk Analysis

The primary objective of the Corporation’s Risk Management Program is to identify, assess, monitor and ensure that appropriate management strategies are in place for known risks. APS annually undertakes a substantive review of its operations and business segments for which we purposely manage risks as part of our day-to-day operations. The following table identifies the business segments and provides the definition of the associated risk as adopted by APS. Our assessment of these risks and the related ongoing management activities will be reported in the APS Annual Risk Management Report for 2014. APS’ Risk Managed Business Segments:

Risk Related to Strategic Priority 1: Deliver Valued Pension Services

Client Responsiveness

Service quality, timeliness, compliance and complaints administration expectations are met to fulfil the Corporation’s reputation as a valued service provider.

Employer Relations

APS provides employers with appropriate information and support to enable them to meet their obligations to submit timely and accurate information to the Corporation, enabling the delivery of quality services to members and pensioners.

Regulatory Compliance

APS complies with statutory and legislative requirements.

Tax Compliance APS complies with applicable federal and provincial tax remittance and reporting requirements, minimizing the Corporation’s exposure to financial and reputational loss.

Processing Integrity

Checks and balances in processing transactions exist to support the accuracy, authorization, completeness, and timeliness of benefits and pension services.

Data Integrity Adequate controls over the accuracy, completeness and quality of client data are instituted and maintained.

Records Management Retention and Integration

All records are captured, retained and disposed of in a timely, accurate and secure manner, ensuring integrity of corporate records and enabling the Corporation to fulfil its Mission and Ends policies.

Plan Fund Accountability

APS has effective management and reporting processes in place to ensure complete and timely accountability of all Plan receipts and disbursements flowing through the APS operations, mitigating the Corporation’s exposure to reputation and financial loss.

Business Planning & Performance Reporting

Realistic and accurate strategic planning, business planning and performance monitoring to support appropriate conclusions, allocations and decisions to achieve the Corporation’s Mission and Ends Policies.

Cost Management Appropriate planning and budgetary controls support the Corporation in meeting cost management expectations.

Availability & Continuity

Availability and continuity of service delivery is maintained in the event of a major interruption or failure to enable on going delivery of its critical services.

Business Interruption

Plans are in place to ameliorate short-term unplanned interruptions in core or support business services to ensure on going operational viability.

System Maintenance

Systems are maintained and tested in an orderly and controlled manner to assure integrity of installed systems.

Information Security

Access to information, data or systems is properly managed, to provide employees with appropriate access privileges to effectively perform their duties and minimize potential compromise of data integrity.

Physical Asset Protection

APS has adequate security measures to protect the Corporation’s physical assets against theft, or unauthorized access.


Risk Analysis

APS’ Risk Managed Business Segments: Legal Liability Exposure to risk of litigation, which may result in financial loss to the Corporation or

damage its reputation, is mitigated.

Communications APS communicates relevant, accurate, and timely information to external stakeholders. Vendor Concentration

Relationships with key service vendors are appropriately managed to minimize unacceptable business interruptions or excessive costs if vendors cease to exist or are unable to maintain a satisfactory level of service.

Risk Related to Strategic Priority 2: Deliver Valued Pension Services

Capability Alignment

APS has the appropriate organizational structure and individual position responsibilities and accountabilities adequately defined and aligned with the Corporation’s business model to support the effective achievement of its Mission and Ends policies.

Employee Performance

APS maintains an adequate performance management system which aligns individual compensation and rewards with expected competencies and goals.

Employee Retention

The Corporation provides a working environment and a compensation and benefits program that supports employee involvement and commitment to organizational success to attract, develop and retain the right people to support and achieve its mission and goals.

Succession Planning and Development

APS maintains adequate levels of training, development and knowledge transfer for key positions in the Corporation.

Health & Safety The Corporation provides a safe and secure work environment that mitigates employees’ exposure to physical harm or workers’ compensation liabilities or other losses.

Risk Related to Strategic Priority 3: Adapt and Respond to Opportunities and Risks

Project Governance

APS has appropriate project governance and oversight to ensure the Next Generation project deliverables and outcomes are realized.

Project Delivery APS has effective processes to deliver projects in a timely and cost-effective manner, enabling the Corporation’s ability to provide quality service.

Change Management

APS is able to plan for and adapt to changing internal and external environments, including the appropriate transition of people, processes and technology, to achieve its Mission and Ends Policies.

Technology Capacity

APS has adequate technology capacity and appropriate platforms to support the Corporation’s business processes and its strategic and operational goals.

Privacy Protection APS complies with legislative requirements to protect the privacy and confidentiality of client and employee data.


Risk Analysis

Risk Related to Strategic Priority 4: Governance Alignment

Corporate Governance

APS has the appropriate business model and governance processes in place, impacting the Corporation’s ability to effectively achieve its Mission and Ends Policies.

Ethics and Fraud Ethics and standards are established, promoted and enforced to prevent and detect employee acts which are considered unethical or fraudulent.

Shareholder Alignment

APS acts in accordance with the letter and spirit of the Unanimous Shareholder Agreement as appropriate to satisfy the needs and expectations of its sole shareholder.

Plan Governors APS has the appropriate service model and accountability structure to effectively manage relationships and provide suitable resources and expertise to plan governors.

External Reporting Due care is taken and evidence exists to support all external reporting and management representations minimizing the Corporation’s exposure to financial penalties, misstatement of financial information or representations and reputational loss.


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