Transcription
For pension 3.1.411.4.2Phoenix Life LimitedPrinciples and Practices ofFinancial ManagementJanuary 2022
Phoenix Life LimitedPrinciples and Practices of Financial ManagementContentsPageIntroduction and Background1.Introduction32.Background to Principles and Practices ofFinancial Management53.Company Background74.Key Concepts of With-Profits Business18Principles and Practices of Financial Management5.Guiding Principles and Practices256.Principles and Practices – 90% With-Profits Fund327.Principles and Practices – 100% With-Profits Fund708.Principles and Practices – Alba With-Profits Fund1019.Principles and Practices – Britannic With-Profits Fund13210.Principles and Practices – Britannic Industrial Branch Fund17311.Principles and Practices – Phoenix With-Profits Fund20012.Principles and Practices – Scottish Mutual With-Profits Fund23413.Principles and Practices – SPI With-Profits Fund26614.Principles and Practices – SAL With-Profits Fund29815.Principles and Practices – NPI With-Profits Fund337With-Profits Governance Arrangements16.With-Profits Governance Arrangements345Appendices1.Glossary3462.History of Principles and Practices ofFinancial Management for Phoenix Life Limited354PLL PPFMPage 1January 2022
PLL PPFMPage 2January 2022
1.IntroductionThis document sets out the Principles and Practices of Financial Management applied inmanaging the with-profits business of Phoenix Life Limited as at January 2022. Phoenix LifeLimited’s assets are divided between a large long-term business fund and a much smallerShareholder Fund. The long-term business fund is internally segregated into 11 funds: the 90% With-Profits Fund;the 100% With-Profits Fund;the Alba With-Profits Fund;the Britannic With-Profits Fund;the Britannic Industrial Branch Fund;the Phoenix With-Profits Fund;the Scottish Mutual With-Profits Fund;the SPI With-Profits Fund;the SAL With-Profits Fund;the NPI With-Profits Fund; andthe Non-Profit Fund.With-profits business is contained in each of the first 10 funds listed above. The Board isresponsible for managing the with-profits business in most of these funds, including settingbonuses. The With-Profits Committee is responsible for setting investment and bonus policyfor the SPI With-Profits Fund only.The Principles and Practices of Financial Management: is used in the governance of the with-profits business within the with-profits funds ofPhoenix Life Limited by the Board and the With-Profits Committee, with particular regard tothe use of discretion in managing the with-profits funds; and provides information on the possible risks and rewards associated with a with-profits policywithin a particular with-profits fund.The Principles and Practices of Financial Management is prepared in accordance withSection 20.3 of the Conduct of Business Sourcebook which forms part of the Handbookissued by the Financial Conduct Authority (FCA).These Principles and Practices have been drawn up in accordance with the law andregulation as Phoenix Life Limited understands it as at January 2022. Should thisunderstanding prove to have been incorrect, for example as a result of a court or regulatoryruling with retrospective effect, the Principles and Practices will be amended to comply andwill be applied as if they had always been so amended.Section 2 gives more details about the background to Principles and Practices and how andwhen they can be changed. Appendix 2 gives details of changes to this document since1 January 2007.Section 3 provides some background information on Phoenix Life Limited and its with-profitsfunds.Section 4 introduces the key concepts of with-profits business and types of with-profitsbusiness. This information is key to understanding the management of the with-profits funds.Section 5 documents the guiding principles and practices adopted in managing the withprofits business of Phoenix Life Limited. These guiding principles apply to all the with-profitsfunds and in the event of conflict with other principles take priority.Sections 6 to 15 document the principles and practices adopted in each of the with-profitsfunds. Nothing in any of these sections should be inferred as applying to the other with-profitsfunds or the Non-Profit Fund unless explicitly stated.PLL PPFMPage 3January 2022
Section 16 documents the with-profits governance arrangements.A glossary of terms and a summary of abbreviations used in the document are given inAppendix 1. Words that are defined in the glossary appear in italics in the main text.Sections 1 to 4 and 16 of this document and the Appendices are background or explanatorymaterial and therefore neither principles nor practices for the purpose of the FCA rules.None of the contents of this document forms part of, or varies, the terms or conditions of anypolicy under which Phoenix Life Limited is the insurer. In the event of any inconsistencybetween the contents of this document and any policy, the terms and conditions of the policyprevail (except where overridden by a court order).This document is intended to assist knowledgeable observers to understand the way in whichthe with-profits business of the Phoenix Life Limited with-profits funds is conducted and thematerial risks and rewards involved in effecting or maintaining a with-profits policy in a fund.It is not a comprehensive explanation either of the management of the with-profits business ofa fund or of the other funds within Phoenix Life Limited or of every matter which may affectthe business. In addition, no part of the document should be read as a recommendation topolicyholders or potential policyholders or their advisers in relation to the effecting ormaintaining of a with-profits policy. Accordingly, any person considering whether to effect ormaintain a with-profits policy within a fund should seek independent financial advice.When referring to with-profits policies, with-profits business accepted by Phoenix Life Limitedunder reassurance agreements is included for the purposes of determining the amountpayable to the reassuring company. However, the benefits payable to the with-profitspolicyholders of the reassuring company will be governed by the Principles and Practices ofthat company.Statements in this document in relation to the risks and rewards involved in effecting andmaintaining a with-profits policy in a fund are by their nature forward-looking statements thatare subject to a variety of uncertainties. Readers of this document should read such forwardlooking statements in that context.The contents of this document may change as the circumstances of Phoenix Life Limited andthe business environment change. The document may also change to reflect changes madeby Phoenix Life Limited to the management of its with-profits business. Phoenix Life Limitedintends to give notice of some changes as explained in section 2 of this document, otherchanges will be made without notice.Readers of this document should be aware that reading only selected sections or paragraphsin isolation may result in a misleading impression of the way in which the with-profits businessof the funds is conducted and the material risks and rewards involved in effecting andmaintaining a with-profits policy with the funds. The principles set out in this document andtheir associated practices should in particular be read together.Phoenix Life Limited is authorised by the Prudential Regulation Authority (PRA) and regulatedby the FCA and PRA.PLL PPFMPage 4January 2022
2.Background to Principles and Practices of Financial Management2.1Principles and Practices2.1.1The principles: are enduring statements of the overarching standards adopted by Phoenix LifeLimited in managing the with-profits funds; and describe the business model used by Phoenix Life Limited in meeting its dutiesto with-profits policyholders in the funds and in responding to longer-termchanges in the business and economic environment.The principles are divided into guiding principles which apply to all the with-profitsfunds (and are described in section 5) and other principles, which apply to aparticular with-profits fund (and are described in sections 6 to 15).2.1.2The practices set out how the principles are implemented: describe Phoenix Life Limited’s approach to managing the funds and toresponding to changes in the business and economic environment in theshorter-term; and contain sufficient detail to enable a knowledgeable observer to understand thematerial risks and rewards from effecting or maintaining a with-profits policy inthe funds.There are practices associated with each principle and these are set out beloweach principle.2.2Demonstrating Compliance with Principles and Practices2.2.1The Board produces an annual report addressed to with-profits policyholderswithin six months of the financial year end. This report covers Phoenix LifeLimited’s compliance with its Principles and Practices of Financial Managementand significant matters where discretion has been exercised, in particular wheresuch matters relate to the competing or conflicting interests of policyholders andshareholders. Policyholders will normally be advised of the report as part of theirnext annual statement. The report is made available to policyholders on request.2.2.2An annual report for the Board is produced by the With-Profits Actuaries on keyaspects of the discretion exercised in respect of each fund (including theapplication of its Principles and Practices of Financial Management).2.3Amendments to the Principles2.3.1The principles are not expected to change often. However Phoenix Life Limitedmay amend any of the principles at any time. Any change will follow formalconsultation with and take into account the opinions of the Head of ActuarialFunction, the With-Profits Actuary and the With-Profits Committee. Any changesto the principles will be approved by the Board. See also paragraphs 3.5.7 and3.6.7.2.3.2The FCA will be provided with details of any changes.2.3.3Policyholders will normally be provided with three months written notice inadvance of any changes to the principles. The written notice will set out anyproposed changes to the principles.PLL PPFMPage 5January 2022
2.3.4The circumstances and reasons normally leading to such amendments to theprinciples are likely to include: changes in regulations; to improve the management of the with-profits funds; maintaining equity between classes or groups of policyholders; and significant changes in the financial condition of Phoenix Life Limited.2.4Amendments to the Practices2.4.1The practices are expected to change as Phoenix Life Limited’s circumstancesand the business environment change. Any change will follow formal consultationwith and take into account the opinions of the Head of Actuarial Function, theWith-Profits Actuary and the With-Profits Committee. Any material changes to thepractices will be approved by the Board.2.4.2The FCA will be provided with details of any material changes.2.4.3Policyholders will not be provided with any advance notification of changes to thepractices, although they will be informed within a reasonable period after anymaterial changes have been made. This notification will normally be with the nextannual statement2.5Summary of Amendments Made to Phoenix Life Limited’s Principles andPractices of Financial Management2.5.1The Principles and Practices of Financial Management will normally be displayedon the www.phoenixlife.co.uk internet site and the version displayed on theinternet site will normally be updated shortly after any changes have beenimplemented.2.5.2Appendix 2 gives details of amendments previously made to the Principles andPractices of Financial Management since 1 January 2007.2.6With-Profits Governance Arrangements2.6.1The with-profits governance arrangements are described in section 16.PLL PPFMPage 6January 2022
3.Company Background3.1Company History and Group Structure3.1.1Phoenix Life Limited did not contain any with-profits business immediately prior to31 December 2005. The with-profits business that is now contained withinPhoenix Life Limited is as a result of five schemes of transfer. Details of these aregiven in sections 3.2 to 3.6.3.1.2Phoenix Life Limited traces its history back to Lloyds Life Assurance Limited,which was founded in 1971 and was purchased by Royal Insurance in 1985. Itwas subsequently renamed Royal Heritage Life Assurance Limited (RHL).The Royal Insurance Group merged with the Sun Alliance and London InsuranceGroup in 1996, and in 1998 the business of the following companies wastransferred into Royal Heritage Life Assurance Limited: Royal Life (Unit Linked Assurances) Limited Royal Life (Unit Linked Pension Funds) Limited Sun Alliance Linked Insurance Limited Sun Alliance Pensions Limited Property Growth Assurance Company LimitedAt the same time Royal Heritage Life Assurance Limited was renamed Royal &Sun Alliance Linked Insurances Limited (RSALI). As part of the transfers in 1998,the with-profits policies, which existed in Royal Heritage Life Assurance Limited atthe time, were converted to non-profit policies and became entitled to the additionof specified additional benefits at specified dates.Royal & Sun Alliance Linked Insurances Limited closed to new business in 2002,although it has continued to issue policies under options on existing policies,including the acceptance of new members to existing pension arrangements andthe issue of immediate annuities in respect of vesting pensions.On 29 December 2005, Royal & Sun Alliance Limited Insurances Limited wasrenamed Phoenix Life Limited.3.1.3Phoenix Life Limited is now part of Phoenix Group.3.22005 Scheme3.2.1Under the 2005 Scheme, business from the following companies was transferredinto Phoenix Life Limited on 31 December 2005: Phoenix Assurance Limited (PAL) Bradford Insurance Company Limited (Bradford) Swiss Life (UK) PLC (Swiss Life)3.2.2Two new funds were established within Phoenix Life Limited alongside the thenexisting Non-Profit Fund, namely the 90% Fund and the 100% Fund.3.2.3All of the with-profits policies from the Swiss Life OB Fund (apart from the withprofits element of Libra Personal Pension Plans and similar policies) and from theSwiss Life IB fund were transferred to the 90% Fund. Former with-profits policieswhich became non-profit on becoming paid up in the Swiss Life OB Fund and theSwiss Life IB Fund were also transferred to the 90% Fund. All of the with-profitspolicies from PAL, Bradford and the Swiss Life With Profit Fund were transferredinto the 100% Fund. Swiss Life Libra Personal Pension Plans and similar policieswere transferred to the Non-Profit Fund but any investment in Pension With-ProfitsFund units was then internally reassured to the 100% Fund.PLL PPFMPage 7January 2022
3.32006 Scheme3.3.1Under the 2006 Scheme, business from the following companies was transferredinto Phoenix Life Limited on 31 December 2006: 3.3.2Alba Life Limited (Alba)Britannic Assurance plc (BA)Britannic Retirement Solutions LimitedBritannic Unit Linked Assurance Limited (BULA)Century Life plc (Century)Phoenix Life & Pensions Limited (PLP)Four new with-profits funds were created and the 90% Fund was re-named the90% With-Profits Fund and the 100% Fund was re-named the 100% With-ProfitsFund. This resulted in the following seven funds in Phoenix Life Limited: the 90% With-Profits Fund;the 100% With-Profits Fund;the Alba With-Profits Fund;the Britannic With-Profits Fund;the Britannic Industrial Branch Fund;the Phoenix With-Profits Fund; andthe Non-Profit Fund.3.3.3All of the policies from the Ordinary Long Term Fund of Alba Life were transferredto the Alba With-Profits Fund. All of the policies from the Industrial Branch Fund ofBritannic Assurance were transferred to the Britannic Industrial Branch Fund. Allof the policies from the Ordinary Branch With Profits Fund of Britannic Assuranceand the with-profits policies from Century were transferred to the Britannic WithProfits Fund. All of the policies from the With Profits Fund of Britannic Unit LinkedAssurance were transferred to the 90% With-Profits Fund. All of the policies fromthe Phoenix Life & Pensions long-term fund were transferred to the Phoenix WithProfits Fund. Other long-term business from the companies listed in 3.3.1 abovewas transferred to the Non-Profit Fund.3.3.4Under the 2006 Scheme, memorandum accounts were set up in the BritannicWith-Profits Fund and Britannic Industrial Branch Fund, called the WP BufferReserve Account and the IB Buffer Reserve Account, collectively known as theBuffer Reserve. The Buffer Reserve will be available to support the BritannicWith-Profits Fund and Britannic Industrial Branch Fund. This replicates themechanics that existed in Britannic Assurance prior to the 2006 Scheme. Moredetails of how the Buffer Reserve works are given in sections 9 and 10.3.42009 Scheme3.4.1Under the 2009 Scheme, business from the following companies was transferredinto Phoenix Life Limited on 6 February 2009: Scottish Mutual Assurance Limited (SMA) Scottish Provident Limited (SPL)3.4.2Two new funds were established within Phoenix Life Limited alongside the thenexisting six with-profits funds giving: the 90% With-Profits Fund; the 100% With-Profits Fund; the Alba With-Profits Fund;PLL PPFMPage 8January 2022
3.4.3the Britannic With-Profits Fund;the Britannic Industrial Branch Fund;the Phoenix With-Profits Fund;the Scottish Mutual With-Profits Fund;the SPI With-Profits Fund; andthe Non-Profit Fund.Policies in the Scottish Mutual Assurance Limited With Profits Sub-Fund weretransferred into the Scottish Mutual With-Profits Fund. The other long-termbusiness remaining in Scottish Mutual Assurance Limited following the transfer ofthe Pegasus and Self Assurance protection business to the Royal London MutualInsurance Society Limited was transferred into the Non-Profit Fund. Under thepowers of the 2009 Scheme the Non-Profit Fund reassured the former ScottishMutual Assurance Limited Smoothed Investment Fund business to the ScottishMutual With-Profits Fund.Policies in the Scottish Provident Limited SPI Fund were transferred into the SPIWith-Profits Fund. The with-profits policies originally held within the Special Fundwithin Scottish Provident Limited were converted into non-profit policies andtransferred into the SPI With-Profits Fund as part of the 2009 Scheme. The otherlong-term business remaining in Scottish Provident Limited following the transferof the Self Assured protection business to the Royal London Mutual InsuranceSociety Limited was transferred into the Non-Profit Fund.The key powers attributable to the SPI Fund Supervisory Committee wereassumed by the With-Profits Committee under the 2009 Scheme. For the SPIWith-Profits Fund only, the With-Profits Committee has the additional responsibilityfor setting the investment and bonus policy. The With-Profits Committee shallconsist of a majority of Independent With-Profits Committee Members, at least oneof whom shall be an Independent Member as detailed in the 2009 Scheme.3.4.4Any investments in Pension With-Profits Fund units for former Swiss Life LibraPersonal Pensions Plans were internally reassured to the 90% With-Profits Fund.These policies are part of the Non-Profit Fund and previously any investment inPension With-Profits Fund units was internally reassured to the 100% With-ProfitsFund, as described in paragraph 3.2.3.3.4.5The 2009 Scheme includes closure provisions for each of the with-profits fundslisted in 3.4.2. Closure will occur when the statutory liabilities for with-profitsbusiness fall below 10m in the case of the 90% With-Profits Fund and 100%With-Profits Fund or below 50m in all other cases. Closure will only occur withthe prior approval of the regulator. For the Britannic Industrial Branch Fund, onthe closure date all the policies will be transferred to the Britannic With-ProfitsFund and with-profits policies will continue as with-profits. Upon the closure datefor all the other with-profits funds, policies will be transferred to the Non-ProfitFund and with-profits policies will be converted to non-profit with a schedule offuture guaranteed bonus additions.3.4.6In accordance with the 2009 Scheme Phoenix Life Limited may re-allocate anynon-profit policy in any of the with-profits funds of Phoenix Life Limited to the NonProfit Fund provided that: such re-allocation is not contrary to the terms and conditions of the policy; and in the opinion of the Board, having obtained appropriate actuarial advice,assets: with a market value which is fair and equitable (in the context of the risksbeing re-allocated to the Non-Profit Fund in respect of the policy); or with a market value which is consistent with an amount (where such anamount can be calculated) that Phoenix Life Limited would have chargedin consideration of the assumption of the risk in respect of a new policyPLL PPFMPage 9January 2022
which it issued on the same terms as the policy to be re-allocated from therelevant with-profits fund to the Non-Profit Fund (subject to appropriateadjustment to reflect differences in expenses or commission incurred),are being transferred or re-allocated from the relevant with-profits fund to theNon-Profit Fund.In respect of the SPI With-Profits Fund, separate provisions apply in relation to theprovision of non-profit annuities (including non-profit deferred annuities). Forthese, the assets transferred from the SPI With-Profits Fund to the Non-ProfitFund shall be based on the annuity rates being used by Phoenix Life Limited orany other authorised insurer in the Phoenix Group or, if unavailable, on ratesconsistent with those generally available in the market. If the With-Profits Actuaryconsiders that the amount that would be transferred exceeds that which isreasonable based on the rates generally available in the market, then he mayrecommend that the annuity benefit be provided from the SPI With-Profits Fundand the With-Profits Committee shall have the right whether to require that theannuity benefit be provided from the SPI With-Profits Fund or not.3.4.7The 2009 Scheme also includes provisions relating to the workings of the funds,the allocation of tax, the shareholders share of surplus, and investment and bonuspolicy. These have been incorporated into this document.In particular, in relation to the investment policy, the provisions allow that furtherhypothecation of the assets in the with-profits funds may be introduced where thisis considered to be in the best interests of policyholders. For example this mayinvolve the matching of non asset share liabilities more accurately, thehypothecation of different equity (and property) backing ratios to further classes orgroups of policies or through the hypothecation of fixed interest assets by termremaining within asset shares to reduce the volatility of policyholder returns nearmaturity.The Buffer Reserve as described in section 3.3.4 continues under the 2009Scheme.3.4.8As part of the 2009 Scheme, the 200m of subordinated loan notes (debt) thatwas previously issued by Scottish Mutual Assurance Limited was transferred tothe Shareholder Fund.3.4.9This Principles and Practices of Financial Management document was firstproduced as part of the 2006 Scheme. It was based on the documents of thecompanies involved in the 2006 Scheme. Changes were made to the previousdocuments to take account of the 2006 Scheme and related events and to createa consistent style and presentation throughout.3.52011 Scheme3.5.1Under the 2011 Scheme, business from Phoenix & London Assurance Limitedwas transferred into Phoenix Life Limited on 14 February 2011.3.5.2A new fund was established within Phoenix Life Limited alongside the thenexisting eight with-profits funds giving: PLL PPFMthe 90% With-Profits Fund;the 100% With-Profits Fund;the Alba With-Profits Fund;the Britannic With-Profits Fund;the Britannic Industrial Branch Fund;the Phoenix With-Profits Fund;the Scottish Mutual With-Profits Fund;Page 10January 2022
the SPI With-Profits Fund the SAL With-Profits Fund; and the Non-Profit Fund.3.5.3Policies in the Phoenix & London Assurance Limited long-term fund weretransferred into the SAL With-Profits Fund. The SAL With-Profits Fund is anadditional with-profits fund of Phoenix Life Limited for the purposes of the 2009Scheme and except as otherwise provided for in the 2011 Scheme, the PhoenixLife Limited long term fund shall be operated in accordance with the 2009Scheme. In addition, paragraphs 3.4.6 and 3.4.7 shall apply in respect of thePolicies allocated to the SAL With-Profits Fund on the basis that the SAL WithProfits Fund is a with-profits fund of Phoenix Life Limited.3.5.4The 2009 Scheme shall continue in full force and effect.3.5.5The 2011 Scheme includes closure provisions for the SAL With-Profits Fund.Closure will occur when the statutory liabilities for with-profits business fall below 50m. Closure will only occur with the prior approval of the regulator. Uponclosure, policies will be transferred to the Non-Profit Fund and with-profits policieswill be converted to non-profit with a schedule of future guaranteed bonusadditions.3.5.6As part of the 2011 Scheme the Principles and Practices of Financial Managementwas updated. Changes were made to incorporate any changes incorporated intothe 2011 Scheme. If any inadvertent discrepancy arose in the production of theFebruary 2011 version and still remains in this current version, then it will becorrected so as to ensure that the intent of the original Principles and Practices ofFinancial Management document is not affected, but subject to any subsequentintentional changes and updates.3.62012 Scheme3.6.1Under the 2012 Scheme, business from NPI Limited was transferred into PhoenixLife Limited on 31 March 2012.3.6.2A new fund was established within Phoenix Life Limited alongside the thenexisting nine with-profits funds giving: 3.6.3PLL PPFMthe 90% With-Profits Fund;the 100% With-Profits Fund;the Alba With-Profits Fund;the Britannic With-Profits Fund;the Britannic Industrial Branch Fund;the Phoenix With-Profits Fund;the Scottish Mutual With-Profits Fund;the SPI With-Profits Fundthe SAL With-Profits Fund;the NPI With-Profits Fund; andthe Non-Profit Fund.With-profits benefits in respect of policies in the NPI Limited long-term fund weretransferred into the NPI With-Profits Fund. The NPI With-Profits Fund is anadditional with-profits fund of Phoenix Life Limited for the purposes of the 2009Scheme and the 2011 Scheme and except as otherwise provided for in the 2012Scheme, the Phoenix Life Limited long term fund shall be operated in accordancewith the 2009 Scheme and the 2011 Scheme.Page 11January 2022
The 2012 Scheme also includes provisions relating to the workings of the NPIWith-Profits Fund, the allocation of tax, the shareholders share of surplus, andinvestment and bonus policy. These have been incorporated into this document.3.6.4The 2009 Scheme continues in full force and effect.3.6.5The 2011 Scheme continues in full force and effect.3.6.6The 2012 Scheme includes closure provisions for the NPI With-Profits Fund. Thebusiness within the NPI With-Profits Fund is wholly reassured to Phoenix LifeAssurance Limited. If this were to be recaptured then the closure provisions wouldapply. The provisions state that closure will occur when the statutory liabilities forwith-profits business fall below 50m. Closure will only occur with the priorapproval of the regulator. Upon closure, policies will be transferred to the NonProfit Fund and with-profits policies will be converted to non-profit with a scheduleof future guaranteed bonus additions.3.6.7With-profits business is contained in each of the first 10 funds listed in 3.6.2.Sections 6 to 15, which contain the Principles and Practices for each of the withprofits funds, also include more details on the background for each of the withprofits funds and the business included in it.3.6.8As part of the 2012 Scheme the Principles and Practices of Financial Managementwas updated. Changes were made to incorporate any changes incorporated intothe 2012 Scheme. If any inadvertent discrepancy arose in the production of theMarch 2012 version and still remains in this current version, then it will becorrected so as to ensure that the intent of the original Principles and Practices ofFinancial Management document is not affected, but subject to any subsequentintentional changes and updates.3.7Other events3.7.1In 2007, Phoenix Life Limited set up Phoenix Pensions Limited (PPL) as a whollyowned subsidiary. PPL is an asset of the Shareholder Fund of Phoenix LifeLimited. Risks under immediate annuity policies were transferred to PPL. Therisks in PPL were subsequently recaptured in 2011.3.7.2In 2008, the Phoenix Life Limited Non-Profit Fund acquired Scottish MutualInternational (SMI) but subsequently sold SMI in 20153.7.3At the end of 2008, Phoenix & London Assurance Limited (PALAL) recaptured thegroup unitised with-profits pensions business which it had previously reassured tothe 100% With-Profits Fund.3.7.4In 2010, the Phoenix Life Limited Shareholder Fund acquired NPI Limited (NPIL).All the business in NPIL was subsequently transferred into PLL under the 2012Scheme.3.7.5Under the 2012 Scheme the immediate annuity business reassured from NationalProvident Life Limited to NPIL was transferred into the Phoenix Life Limited NonProfit Fund.3.8Capital Policy3.8.1The 2009 Scheme provides for Phoenix Life Limited to maintain a specific capitalpolicy. The capital policy has two main aims: to allow dividends to be paid, or money to be lent to shareholders whilst stillmaintaining a capital buffer and the security of the funds; andPLL PPFMPage 12January 2022
3.8.2to provide a framework for the circumstances in which support will be availableto with with-profits funds.The principle behind the first aim of the capital policy is to seek to ensure
managing the with-profits business of Phoenix Life Limited as at January 2022. Phoenix Life Limited's assets are divided between a large long-term business fund and a much smaller Shareholder Fund. The long-term business fund is internally segregated into 11 funds: the 90% With-Profits Fund; the 100% With-Profits Fund;
