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Dyfed Pension Fund

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Dear Carmarthenshire Council,

Please could you provide a list of the Dyfed Pension Fund's unlisted property fund holdings in an excel spreadsheet. Please provide the full names and net asset valuations as at 30 September 2017, or as at the latest available valuation date.

Yours faithfully,

Tracey Paper

FOIA, Carmarthenshire County Council

Dear Ms. Paper

Thank you for your request for information, which was received on 11th January, 2018, and is being dealt with under the Freedom of Information Act 2000.

We are therefore required to provide a response within 20 working days, which will be on or before 8th February, 2018.

If we require clarification we will also contact you as soon as we can – please note that the timescale for response specified above may be subject to change if this is the case.

In the meantime, please do not hesitate to contact me should you have any queries, remembering to quote the reference number above in any communications.

Yours sincerely

John Tillman
Swyddog Gwybodaeth a Diogelu Data
Tîm Llywodraethu Gwybodaeth a Chwynion
Adran y Prif Weithredwr
Cyngor Sir Gaerfyrddin

Information & Data Protection Officer
Information Governance & Complaints Team
Chief Executive's Department
Carmarthenshire County Council

Mewnol/Internal: 4127
Allanol/External: 01267 224127

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FOIA, Carmarthenshire County Council

1 Attachment

Dear Ms. Paper,
 
Thank you for your request for information, which was received on
11^thJanuary, 2018 and has been dealt with under the Freedom of
Information Act 2000.
 
The specific information you requested was as follows:
 
Please could you provide a list of the Dyfed Pension Fund's unlisted
property fund holdings in an excel spreadsheet. Please provide the full
names and net asset valuations as at 30 September 2017, or as at the
latest available valuation date.
 
In response, please find attached the relevant information held by the
Council.
 
 
Yours sincerely
 
John Tillman
Swyddog Gwybodaeth a Diogelu Data
Tîm Llywodraethu Gwybodaeth a Chwynion
Adran y Prif Weithredwr
Cyngor Sir Gaerfyrddin
 
Information & Data Protection Officer
Information Governance & Complaints Team
Chief Executive's Department
Carmarthenshire County Council
 
Mewnol/Internal: 4127
Allanol/External: 01267 224127
 
 
 
 
 
 
 
 

Dear FOIA,

Many thanks for the information that you have sent through. I note there is reference to "Pooled Property" under the title of "Schroders", please could you expand which unlisted property funds and their corresponding values are within this grouping?

Yours sincerely,

Tracey Paper

FOIA, Carmarthenshire County Council

Dear Ms. Paper

It is the view of Schroders that the disclosure of the identity of investment funds would allow competitors to use the considerable work done by the fund manager for their own purposes, at a substantially reduced cost. Investment management is of course a highly competitive area.

Allowing competitors access to this information would reveal Schroders’ investment strategy, and allow other investment managers to mimic it. This would compromise the fund manager’s market position in the real estate funds market.

I should also add that disclosing information under the Freedom of Information Act has the effect of placing it in the public domain. I am therefore required to disregard who has made the request and consider the effect of publishing the information and making it available to the world at large.

Under Section 43 (2) of the Freedom of Information Act, a public authority may refuse to disclose information if it would, or would likely to, prejudice the commercial interests of any person, including the public authority holding it. Commercial interest can be defined as the ability of any party to participate competitively in a commercial activity, such as tendering for contracts or the provision of goods or services.

On the basis set out above, I do consider that this exemption is engaged.

However, this exemption is subject to a public interest test, which requires me to consider whether the public interest in maintaining the exemption outweighs the public interest in disclosing the information. In doing so, it is important to draw a distinction between what may be of interest to members of the public and what is genuinely in the public interest.

I accept that there is always likely to be a public interest in disclosing information on matters relating to investments made with public funds which assists the public with understanding and evaluating whether the Council is investing wisely and ethically and whether it is achieving value for money.

However, the Council already makes a significant amount of information concerning its investments available. It provides investment information in the Dyfed Pension Fund Annual Report and Accounts which is available on our website. Amongst other things, this document discloses information concerning the market value of the Dyfed Pension Fund and an analysis of investments, including by sector type, and its top holdings.

There is also in my view a stronger, countervailing public interest in allowing the Council to be able to administer pension funds effectively in a competitive market, with a view to implementing an appropriate investment strategy and securing best value for the public purse.

Accordingly, I consider that this exemption should be maintained.

As I am refusing to provide some of the requested information, please consider this email to be a formal notice of refusal as required by Section 17 of the Freedom of Information Act.

Your right of appeal

I appreciate that this is a change to our stance on such requests and if you are unhappy with this decision or the way in which your request has been dealt with, you have the right to make an appeal in the first instance to:

The Head of Administration & Law
Carmarthenshire County Council
County Hall
Carmarthen
SA31 1JP

Email: [email address]

If you remain unhappy with the handling of your request or complaint, you have a right to appeal to the Information Commissioner at:

The Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113
Website: www.ico.gov.uk

There is no charge for making an appeal.

Yours sincerely

John Tillman
Swyddog Gwybodaeth a Diogelu Data
Rheolwr, Tîm Llywodraethu Gwybodaeth a Chwynion
Adran Adfywio a Pholisi
Cyngor Sir Gaerfyrddin

Information & Data Protection Officer
Manager, Information Governance & Complaints Team
Regeneration & Policy Department
Carmarthenshire County Council

Mewnol/Internal: 4127
Allanol/External: 01267 224127

Julie John
Information Officer
Carmarthenshire County Council
 
Tel: (01267) 224498
Internal: 4498

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We don't know whether the most recent response to this request contains information or not – if you are Tracey Paper please sign in and let everyone know.