A member wrote to Aptia, the scheme's administrator, asking two questions: when was the last discretionary increase made to pre‑1997 pension benefits, and did the Trustee intend to make one given the scheme was then 130% funded? Aptia confirmed the last increase was applied in January 2014, at 19.1% on the pre‑1997 element in excess of GMP — and that the Company's position remained that increases would only be provided where legally required.

Following Aptia's response, a formal request was made directly to IGG as Trustee, asking it to circulate a communication to all members with pre‑1997 benefits explaining that no discretionary increase had been applied since January 2014. IGG did not respond promptly; a follow‑up was required. IGG eventually acknowledged the request but indicated it would not circulate the communication.

Following IGG's refusal, a formal complaint was lodged under the Plan's Internal Dispute Resolution Procedure (IDRP), alleging lack of transparency and failure to demonstrate independence from the Company. The complaint was acknowledged by IGG on 13 November 2025.

IGG issued its formal IDRP decision, declining to uphold the complaint. Key points from its response: the Trustee has no unilateral power to award discretionary increases — only the Company can authorise them; the Company's "global practice" is to provide inflation adjustments only where legally required; and the Trustee does not consider it appropriate to use its communication channels to "take a position" on member benefit matters. Notably, IGG's own letter acknowledged that the Participating Employers are "potential beneficiaries under the Plan" — meaning they have a financial interest in how surplus is used alongside members.

Following an email campaign by the HPPA Alliance, a number of MPs wrote to the Pensions Minister on behalf of their constituents regarding discretionary indexation of defined benefit pension schemes. Torsten Bell MP, Minister for Pensions, issued a formal ministerial response that was circulated as a standard reply to multiple MPs. The letter stated:

“Trustees will be in the driving seat in all decision making on surplus release and have a duty to act at all times in the interest of scheme beneficiaries. Employers will have no direct access to surplus funds and trustees are within their rights to request conditions that include the payment of discretionary indexation to members as part of any agreement which leads to the release of surplus to the employer.”

The minister further noted that the Pensions Regulator already expects trustees to consider whether members would benefit from a discretionary increase and whether the scheme has a history of making such awards — and that legislative changes will give trustees of well-funded schemes more scope to agree discretionary increases with employers. This scheme is well-funded. This scheme has a history of making such awards.

Following IGG's IDRP decision, a formal complaint (case reference CAS-153952-T7V1) was submitted to The Pensions Ombudsman, concerning the Trustee's refusal to circulate a member communication on pre-1997 discretionary increases and related concerns about transparency, independence, and engagement with members. Two follow-up emails providing clarification were sent on 12 and 18 December 2025.

A letter was sent to J&J's Chief Executive asking the Company to commit, from April 2026, to resuming discretionary increases on pre‑1997 pension benefits, noting the scheme's strong funding position and the twelve-year gap since the last increase.

The Pensions Ombudsman confirmed the application had been logged and passed to its Assessment Team, with an estimated 8 weeks before the team would make contact to explain next steps.

A response was received from a senior HR manager at Johnson & Johnson on behalf of the Company. It stated: "At this time, there is no intention by the plan sponsor to amend the plan benefits by awarding a discretionary increase in excess of those set out under the Rules." The response added that J&J "remains committed to managing our pension plans in accordance with plan terms and applicable law."

The Pensions Ombudsman wrote again to confirm the complaint will be passed to a Case Assessor, who will assess in detail whether it is something the Ombudsman can investigate. The estimated timescale to allocate the case to a Case Assessor was given as around 15 months. The Association will provide an update once the case progresses.

A further letter was sent to J&J's Chief Executive, signed by Graeme Crawford — a member of the group, with 31 years' service — on behalf of a long list of named former employees, following up on the 13 December 2025 letter and the 4 February 2026 response. It asked the Company to reconsider its position in light of the Credo and the scheme's strong funding position. The letter was acknowledged but did not receive a substantive reply.

Members agreed a constitution and rules and formed The J&J UK Pensioners Voluntary Association (renamed from an earlier working title on 11 June 2026), giving the Network a formal legal structure through which to correspond on members' behalf.

Formal letters were sent to Ross Trustees Services Limited (IGG) as sole trustee, to a senior HR manager at Johnson & Johnson, and to the Managing Directors of a number of J&J Affiliates — setting out the five specific asks summarised in "Where things stand" above. Each letter requested a substantive response within 28 days. These letters followed nine months of good‑faith direct engagement through formal channels before the Association was involved.

The 28-day response window from the 27 May letters closed on 24 June 2026. IGG (Ross Trustees Services Limited) acknowledged receipt of the Association’s letter but did not provide a substantive response by the deadline. Johnson & Johnson has not responded at all. The Association is now considering its next steps.

Following the expiry of the 28-day response window without a substantive reply from either IGG or Johnson & Johnson, the Association submitted a formal complaint to The Pensions Regulator (TPR) concerning the governance of the Johnson & Johnson U.K. Group Retirement Plan. The Association is not in a position to publish the details of that complaint at this stage. It will provide an update when it is able to do so.

IGG (Ross Trustees Services Limited) responded in writing. Key points from that response:

• IGG confirmed the Trustee is “not currently considering any payment of surplus assets to the Participating Employers,” and that no discussions with the Participating Employers have taken place regarding a payment of surplus assets.
• IGG stated its member engagement is provided “where full member engagement is legally required.”
• IGG confirmed it requests discretionary increases from the Company annually and triennially, and that the Company has declined each time, most recently ahead of April 2026.
• On the LinkedIn video presentation by Richard Cousins referenced in the Association’s letter, IGG stated this “was not in relation to Johnson and Johnson or the Plan” and that Mr Cousins “has no involvement with the Plan.” The Association records this denial. It addresses only the video — not the separate, written case study published on IGG’s own website and signed by Grant Suckling, one of this Plan’s own trustee directors, which remains formally unanswered.
• IGG did not address the Association’s request for independent actuarial advice on the cost of providing discretionary increases to pre-1997 members, and declined the Association’s request for a multi-party meeting, indicating the correspondence was “sufficient to answer the points raised.”

At a member's request, their MP wrote to the Rt Hon Pat McFadden MP, Secretary of State for Work and Pensions, seeking clarification on two points ahead of the DWP's surplus flexibilities consultation: first, whether the final regulations will require trustees to demonstrate they have considered whether historic indexation gaps should be addressed for members before any surplus is released to an employer; and second, whether the Government will require meaningful member consultation before a surplus release decision is finalised, rather than notification after the fact.

Separately, another member of the scheme received a reply from their own MP, Euan Stainbank MP, following correspondence on the same issue. Mr Stainbank's letter made a point worth recording: “If Parliament has accepted that pre-1997 indexation protection matters enough to legislate for PPF members, that same logic does not disappear simply because a scheme happens to remain solvent. If anything, a scheme sitting on a substantial and growing surplus… is better placed to fund it than one in distress.” The letter also confirmed that Dame Nia Griffith and Peter Swallow raised the pre-1997 indexation gap during the passage of the Pension Schemes Act 2026, and that ministers acknowledged the gap for non-PPF members without yet committing to close it.

Responding to the 8 July letter, the Minister for Pensions confirmed the Government's position in writing. Key points:

• The Government “recognises that the absence of indexation on pension rights, accrued before April 1997, can erode the value of pensions over time and affect members.”
• The Minister stated he has “met with many of them to ensure that their voice is heard when it comes to policy-making.”
• The Government will not retrospectively mandate pre-1997 indexation on a blanket basis, on the basis that “all recent Governments… have not thought it was appropriate” to add liabilities to schemes this way.
• The letter repeated that the Pensions Regulator “expects trustees to consider whether members would benefit from a discretionary increase, and to take account of any history of making such awards” — and confirmed TPR will issue further guidance on this, including examples such as benefit enhancement, shortly after the Regulations come into force.
• On member involvement, the letter described “member notification” as one of the safeguards attached to any surplus release — not the meaningful, pre-decision consultation the member's letter had specifically asked for.

Separately from the Association's own correspondence, a member of the scheme had written to their own MP on 27 June 2026 about the Pension Schemes Act 2026, asking a direct question: would members be told and asked before money is taken out of their pension scheme, not just told after the decision had already been made? The MP's reply, received on 22 July, confirmed that members “must be notified before payments of surplus to employers are made,” and pointed to trustees' fiduciary duty as a safeguard.

The member has shared this exchange with the Association, with identifying details removed. It illustrates a pattern the Association has seen elsewhere: a reply confirming notification to a question that asked about consultation — two different things. It also illustrates the same fiduciary duty gap set out in our article “A Duty With Almost Nothing to Bite On”: a general duty to act in members' interests provides less reassurance where the trustee has confirmed, in writing, that it holds no discretion over the specific decision that matters most.

Johnson & Johnson responded, on behalf of the Participating Employers, to the Association's letters of 27 May 2026. The response acknowledged receipt, confirmed the Company “will continue to manage the Plan in accordance with its terms and applicable law,” and confirmed that, at this time, there is “no intention to amend the Plan benefits by awarding a discretionary increase in excess of those set out under the Rules of the Plan” — materially the same position previously given by J&J's HR Lead for Northern Europe on 4 February 2026.

The response did not address the Association's specific requests: the multi-party meeting, the pre-1997 indexation disparity, the Statement of Funding Principles, or the amended Rule 19 consent mechanism were not engaged with. The Association records this as a response received, but not one that engages with the substance of the matters raised.

IGG responded further, in reply to the Association's letter of 4 July 2026. Key points from that response:

• IGG confirmed it is “not currently considering any proposal relating to the payment or distribution of surplus assets,” and stated that, accordingly, “there is no requirement at the present time for the Trustee to undertake any consultation with the membership.”
• On the case study raised previously, IGG stated it “does not consider it appropriate to continue to comment on whether any particular pension scheme is, or is not, referenced” in its marketing publications — declining to comment further, rather than repeating or extending the specific denial given on 3 July regarding the LinkedIn video.
• On the Association's request for independent actuarial advice on the cost of pre-1997 increases, IGG stated it will determine what professional advice it requires and obtain it as it considers appropriate.
• The request for a multi-party meeting was declined. IGG stated it does not consider a meeting would assist at this time, that the Association's views have been clearly set out in correspondence, and that they will be “considered alongside any views received from other members and beneficiaries.” IGG added that it “cannot accord any particular status or standing to the views of any individual member or group of members.”
• IGG stated it has “no further comments to make on the matter,” and pointed the Association to the Plan's Internal Dispute Resolution Procedure if dissatisfied.