Expanding Sustainability Outside of ESG Investments

Sustainability doesn’t just come from green investments. Plan sponsors can also incorporate sustainable practices in their day-to-day work.

As some participants start to request environmental, social and governance (ESG) investments in their workplace plan’s lineup, more employees are also demanding an emphasis on sustainability in general.

A 2016 report by sustainable research company LightSpeed Solutions found many workers believe sustainability is a crucial practice when selecting an employer. This was especially true for Millennial respondents, 90% of whom stated their support for sustainable practices.

Get more!  Sign up for PLANSPONSOR newsletters.

So, as more employees look for sustainability in the workforce, what are some best practices that employers can include to expand their green efforts?

First, consider going paperless, says Ross Bremen, a partner at institutional investing firm NEPC. Swapping paper copies for electronic files or cloud-based alternatives reduces waste while sustaining engagement. Bremen notes that many plan sponsors have already shifted to e-delivery methods.

“As the world has moved to electronic delivery, plan sponsor practices have evolved accordingly,” he says. “Participant communication efforts, for example, have shifted toward electronic messaging and away from paper. We’ve also seen a set of plan sponsors move away from paper more broadly across their primary business lines.”

The effects of the coronavirus pandemic have mitigated the use of paper communications, too. Collaborating app usage skyrocketed as more workforces turned to remote environments and virtual conferencing last year. Now, as workforces open up and more employees return to the office, its likely these communication approaches will stay.  

“With so many committee members, staff members, recordkeeper employees and consultants working from home, nearly all meetings have been held virtually, meaning all materials have been shared electronically with no generation of paper for the meetings themselves or many of the outputs,” Bremen says. “It is too early to tell what will happen as more individuals return to the office, but it seems likely that many of these paperless COVID-19 practices will continue in some capacity.”

Retirement planning notifications will likely move to e-delivery too, especially since the Department of Labor (DOL) published its final electronic disclosure rule last year expanding the ability of plan sponsors to distribute retirement plan disclosures online and via email.

If a plan sponsor needs to use paper, purchasing recycled paper and other recycled office equipment, such as toners and inkjets, can minimize carbon footprints, according to the Society for Human Resource Management (SHRM).  

Other sustainable strategies include applying digital-first elements to plan design, such as by expanding wellness programs to app-based platforms, says Charlie Nelson, vice chairman and chief growth officer at Voya. Similarly to e-delivery, digital engagement discourages the use of paper communications while increasing e-communications. And because an app can be viewed at any time or point through a mobile device, this strategy can raise plan accessibility. 

“Consider how all factors of ESG approaches can be incorporated into a plan,” says Nelson. “Eliminate paper, switch to e-delivery and encourage digital engagement, such as by increasing access to the plan through plan design, and focus on plan governance and including value for the money and administration of the plan.”

IRS Says Lack of Details Is a Common Error in VCP Submissions

Plan sponsors, or their representatives, can refer to an updated IRS webpage to ensure submissions to the voluntary correction program are error-free.

On an updated webpage, the IRS reminds plan sponsors, or their representatives, to make sure their voluntary correction program (VCP) submissions are error-free before submitting them. The agency notes that if a submission has errors, it takes longer to review and delays the issuance of the compliance statement.

The page lists top mistakes found in VCP submissions that plan sponsors can review before completing their work.

Get more!  Sign up for PLANSPONSOR newsletters.

Among the common errors the IRS finds is that “the descriptions of failures weren’t detailed enough or easy to understand,” according to the webpage. The IRS says submissions where the descriptions of operational failures didn’t specify the plan sections not followed or the number of participants affected by the failure were not processed.

Plan sponsors should also make sure the method used to determine the earnings to correct contributions or distributions is clear. And plan sponsors, or their representatives, should include specific proposed changes to administrative procedures, and the proposed changes should address how they will prevent the failure from happening again.

For submissions involving participant loans and Internal Revenue Code (IRC) Section 72(p), copies of loan agreements and amortization schedules for affected participants, as well as a copy of a referenced “loan policy,” should be included.

The IRS recently revealed an examination initiative to ensure that participant loans comply with IRC Section 72(p) rules on maximum loan balances and IRC Section 72(t) repayment rules for early distributions before age 59.5. The IRS says it will verify whether participant loans of retirement plans that hold a high percentage of participant loans to total assets of the trust are being repaid timely if the loan balance remains consistent or increases for more than one year.

Other important items missing from VCP submissions for operational failures include:

  • detailed computations showing how corrective amounts were determined;
  • detailed computations showing how earnings were determined and how they impacted the computation of the corrective amounts;
  • a copy of the plan section (or plan document) in effect during the failure period; and
  • additional documents and explanations for failures being corrected by plan amendment that conform the plan document to the plan’s operations.
The full list of common mistakes in VCP submissions is here.

«