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Portrait of Harriet Cleal

Harriet Cleal

Senior Associate

CMS Cameron McKenna Nabarro Olswang LLP
Cannon Place
78 Cannon Street
United Kingdom
Languages English, Spanish

Harriet Cleal is a senior associate in the Pensions Team. She joined CMS as a trainee solicitor in 2014 after studying economics and law, and qualified into the Pensions department after training there for six months. She advises defined benefit and defined contribution clients on a wide range of advisory and contentious matters, as well as on the pensions aspects of corporate transactions. 

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Relevant experience

  • Various energy sector pension clients in relation to the complex rules for ex-public sector schemes, including the Protected Persons requirements and pensions interactions with OfGem's regulatory framework. 
  • A trustee client on the merger of three large defined benefit schemes into a newly established plan.  
  • DC and hybrid schemes in relation to a bulk transfer to a master trust, including on issues arising in relation to gated funds, GMP underpins to DC benefits, protected pension ages, protected tax free cash entitlements and regulatory requirements around default funds. 
  • Trustees and employers on de-risking and liability management exercises such as enhanced transfer value exercises, pension increase exchange exercises, buy-ins and buy-outs.
  • Trustee clients with schemes which have fallen into a PPF assessment period, including advising on transfer to the PPF, a PPF+ buy-out and ongoing technical matters during the assessment period. 
  • A client on a successful defence to an investigation by The Pensions Regulator.
  • Several sets of pension scheme trustees on their transition of administration services to a new provider, including contractual review, member communications and engaging with project managers through each stage of the transition. 
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Memberships & Roles

  • Member, the Association of Pensions Lawyers.
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  • Contributor to the Pensions Law Handbook (15th Edition), Bloomsbury Professional.
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  • 2011 – Law, Cambridge University, Cambridge.
  • 2008 – Economics, Bristol University, Bristol.
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Cli­mate Change
The Act in­serts new sec­tions in­to PA95 provid­ing for reg­u­la­tions re­quir­ing oc­cu­pa­tion­al pen­sion schemes to man­age the ef­fects of cli­mate change as a fin­an­cial risk and to re­port on how they have done so in line with TCFD re­com­mend­a­tions. These new re­quire­ments ini­tially ap­ply from 1 Oc­to­ber 2021 to schemes with £5 bil­lion or more in as­sets (and au­thor­ised mas­ter trusts and CDC schemes). This will then be rolled out to schemes with £1 bil­lion or more in as­sets from 1 Oc­to­ber 2022. Two sets of reg­u­la­tions on cli­mate change gov­ernance and re­port­ing have come in­to force and DWP guid­ance has been pub­lished. TPR has con­sul­ted on its own guid­ance on how it will en­force the new rules. The reg­u­la­tions also provide that trust­ees of schemes in scope must have know­ledge and un­der­stand­ing of the risks and op­por­tun­it­ies for pen­sion schemes arising from cli­mate change. Even those schemes that are not large enough to be sub­ject to man­dat­ory TCFD re­port­ing im­me­di­ately are strongly en­cour­aged by the PCRIG guid­ance to ad­opt ro­bust gov­ernance pro­ced­ures re­lat­ing to cli­mate risk and later move to re­port­ing (in an­ti­cip­a­tion of the re­quire­ments ap­ply­ing to all schemes by 2025).The reg­u­la­tions make clear that the onus is firmly on trust­ees to com­ply with the new re­quire­ments with some guid­ance on how to over­see those as­sist­ing the trust­ees with cli­mate-re­lated gov­ernance. Trust­ees must carry out scen­ario ana­lys­is, ob­tain data, cal­cu­late and use met­rics and meas­ure per­form­ance against trust­ee-set tar­gets “as far as they are able”. This means tak­ing all such steps as are reas­on­able and pro­por­tion­ate in the par­tic­u­lar cir­cum­stances tak­ing in­to ac­count the costs, or likely costs, to the scheme and the time re­quired to be spent by the trust­ees or people act­ing on their be­half. The “as far as they are able” re­quire­ment does not ap­ply to the gov­ernance and re­port­ing part of the re­gime which will be man­dat­ory for schemes in scope (with reg­u­lat­ory fines for non-com­pli­ance).