Written by Emily Boyd-Nash

The Pensions and Lifetime Savings Association (PLSA) has recently published its Stewardship & Voting Guidelines 2025 ("Guidelines"). These Guidelines offer a framework for trustee voting decisions that aim to promote responsible investment.  

In this article, we discuss some updates and changes introduced in the 2025 edition, building on the information in last year's Guidelines. For a review of last year’s Guidelines, see our analysis here.

 

 

AI

While AI was a key theme in last year's Guidelines, this year the PLSA has provided further insights. The PLSA observed that global governance is falling behind the rapid development of AI technology, which may present challenges in the near future. Additionally, the PLSA noted that some large tech companies have faced scrutiny from ESG-focused shareholders for making redundancies as a result of advancements in AI. The PLSA confirmed in the Guidelines that in 2025, it plans to offer advice to support trustees in voting and exploring how AI impacts their responsibilities and the broader pensions industry. 

 

Dual class shares

PLSA expects to continue to see growth in the number of dual class share structures due to the changes in regulatory requirements that control their use. The PLSA published its concerns relating to the rise in dual class shares in the FCA consultation and has said that the most notable impacts on stewardship are likely to be:

 

  • “The removal of mandatory shareholder votes on significant party transactions.
  • The removal of mandatory shareholder votes on related party transactions.
  • A more permissive approach to listing with dual class share structures.”[1]

 

The PLSA provides a number of recommendations to assist investors working with companies with these share structures whilst minimising risk. 

 

Emerging areas of interest 

PLSA has noted 3 new areas that may begin to see shareholder interest in the next few years: 

  • Maternity and Paternity Pay 
    • Despite women progressing ahead of men in many areas, such as in obtaining a university degree, there is still a point at which the gender pay gap continues to subsist within the workplace. One such instance is the finding that women with children are more likely to be unemployed compared to women without children. This has been attributed to the fact that provision for paternity leave has failed to adequately support men in taking time out of work to raise children. 
    • The PLSA expects this to be an area of interest and for investors to support parental leave policies that support men and women equally. 

 

  • Anti-Microbial Resistance (AMR)
    • The PLSA expects companies in sectors at particular risk to AMR to implement AMR management practices inline with WHO guidelines. 
    • PLSA may introduce voting recommendations on this topic, especially if companies do not commit to introducing policies and management strategies to deal with AMR. 

 

  • Harmful Content and Misinformation 
    • PLSA has suggested that it will consider giving voting recommendations if technology and social media companies do not do more to disclose how they are working to manage harmful content and misinformation. 

 

Burges Salmon is well-placed to advise on all aspects of ESG for pension schemes. If you would like to explore this topic further, please contact Kate Granville Smith.

[1] Pensions and Lifetime Savings Association “Stewardship & Voting Guidelines 2025” (January 2025)