DWP consultation on proposed changes to the Investment Regulations – an NAPF response.  It is right that, as principals, pension funds develop an investment policy which includes an understanding of their objectives and risks and also clearly conveys their expectations to their agents with respect to delegated activities such as engagement and voting. We caution however, that a balance needs to be struck between encouraging the right behaviours whilst avoiding introducing measures which risk creating a compliance tick-box exercise with boiler-plate disclosures. It is for this reason that, instead of requiring trustees to comply-or-explain with the Stewardship Code we suggest that a fund’s approach to the stewardship of its investments should be included alongside the proposed disclosures about how it considers financial and non-financial matters.