The Devon Pension Fund places a strong emphasis on the rights and responsibilities that attach to being a shareholder and will play an active role in overseeing the management of the companies in which it invests.
Companies that are well managed with a sustainable business model are more likely to achieve the investment returns that the Fund requires. The Fund will therefore seek to engage in collaboration with LPPI and its fund managers and other partners to promote good management and sustainable business models, and use its votes at company meetings accordingly.

In February 2026 the Fund was re-accredited by the Financial Reporting Council (FRC) as a signatory to the UK Stewardship Code 2020. This follows an assessment of the Fund’s stewardship and engagement policies and activity reported in the Devon Pension Fund Annual Report.
The Code sets high stewardship standards for asset owners and asset managers, and for service providers that support them.
Company Engagement
A breakdown of the number of companies engaged with by Brunel on behalf of the Devon Fund during each quarter over the last year, by region and the type of issues engaged on is shown in the following charts:
Number of Companies Engaged With, By Region

Breakdown of Issues Engaged On

Voting Activity
Voting on the Fund’s equity shares was, for this period, delegated to the Brunel Pension Partnership, and for the Fund’s passive investments to Legal and General Investment Management (LGIM). The Devon Fund requires that Brunel will always seek to exercise its rights as shareholders through voting on all resolutions at company general meetings.
Brunel actively voted the shares held within their funds on behalf of their client funds, including the Devon Pension Fund. For the passive equity allocation Legal and General Investment Management (LGIM) manage the investments and voting on the shares is delegated to them. On significant issues, Brunel may have requested that their shares were to be split out and a different vote made. The votes cast by the Fund’s investment managers during the year in respect of the Devon Fund’s investments are set out in the table below. The passive portfolios managed by LGIM are shown separately from Brunel’s voting on active portfolios.
| Manager | Number of meetings | Number of resolutions | Votes against management recomendations |
|---|---|---|---|
| Brunel Passive Portfolios | 1,074 | 15,178 | 3,459 |
| Brunel Active Portfolios | 886 | 10,322 | 1,728 |
The LGIM passive portfolios included all the companies in the relevant indexes, so there were more meetings and more resolutions to vote on than for the actively managed portfolios. The votes against management recommendations reflected matters where there was concern that the company was not addressing the issue concerned and managing it effectively. The Devon Pension Fund would have expected that these votes against management should be primarily on the priority areas set out in the Fund’s Investment Strategy Statement. An analysis of the issues where votes have been cast against management recommendations is set out below.
Votes Cast Against Management Recommendation by Issue 2022/23


For more details on the Fund’s stewardship and engagement activities in the Pension Fund Annual Report at Important documents – Devon Pension Fund