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City of London Pension Fund Investments

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Dear City of London Corporation,

I am researching the fossil fuel investments made by UK Local Government Pension Schemes (LGPS) for an upcoming report by UK Divest. On publication, the report is likely to receive substantial interest from press and the elected representatives sitting on pension fund committees across the UK. Therefore can you please ensure the investment data you provide is as accurate as possible as our analysis will be fundamentally informed by it.

To complete this research, I require data on each investment that was held by The City of London Corporation Pension Fund on 31 March 2022, or the nearest possible date:

1. Investment names. Please provide the names of all investments held by the pension fund. For direct investments, please provide the names of individual investments such as specific stocks, bonds, and real estate units. For indirect investments (i.e. those held via a third party), please provide the names of investment vehicles, such as specific mutual funds, exchange traded funds (ETFs) and real estate investment trusts (REITs) and anything else. Note we do not need to know what each indirect investment vehicle invests in as we will determine this in the data analysis.

2. Investment identifiers. For listed investments (i.e. those traded on public exchanges), such as bonds and equities, please provide the International Securities Identifier Number (ISIN). For any investments that do not have an ISIN number, such as some alternative assets, please provide the Legal Entity Identifier (LEI). If an investment does not have an identifier, please provide an explanation.

3. Asset types. The asset type for each investment as reported by the pension fund, such as: real estate, cash, private equity, listed equity, sovereign bonds, corporate bonds etc.

4. Investment managers. The name of the entity which is responsible for the day-to-day management of each investment. For example, this could be the name of the entity which manages a specific investment fund such as Baillie Gifford, Legal & General, UBS etc. Note we do not need to know who is responsible for the overall governance of the LGPS or any pools it might belong to.

5. Investment values. The market value of each investment in pounds sterling (£) on 31 March 2022 or the nearest possible date. And please also give the total value of the pension fund.

We have created a read-only Google Sheet as a template for how we would like the data presented when you answer this request. You can view and download it here: https://docs.google.com/spreadsheets/d/1...

If possible, please use this Google Sheet when answering. Please note there are two tabs - 'summary' and 'data'. Please fill in both tabs. Using the template would help us accurately analyse the data provided.

If you respond promptly and to a satisfactory standard, we will willingly share our analysis with you prior to publication of our report, so you have the chance to comment and benchmark your pension fund against other UK LGPS.

I would like to receive this information in unlocked excel sheets without protected cells (.xls). If you have to password protect the excel sheets, please also provide the password to them. When considering the request for this data in excel format, please refer to Innes v Information Commissioner [2014] EWCA Civ 1086 (i), which allows a requester to express a preference for communication by a particular means, specifically: "an applicant's right to choose to have information provided to him in electronic form extends to a right to choose the software format in which it is embodied." (ii)

Please note:

Many public authorities release their contracts, minutes, and other information of interactions with private vendors in line with the Freedom of Information Act. The exemption for commercial interest under the Act (section 43) is a qualified exemption, which means information can only be withheld if it is in the public's interest. The public have an interest in knowing what the Pension Fund is investing in, the terms of contracts and the minutes of meeting with public authorities, whether or not public money changes hands immediately.

If you are relying on section 41 (the exemption for legal breach of confidence) then I would like to know the following:

* When these confidentiality agreements were agreed
* All correspondence and email in which these confidentiality agreements were discussed
* The precise wording of the confidentiality agreements.

I ask these questions because guidance issued by both the Lord Chancellor (draft guidance on FOI implementation) and the Office of Government Commerce (Model terms and conditions for goods and services) specifically state that public authorities should not enter into these types of agreements; they go directly against the spirit of the laws of disclosure. I would also point to the Information Commissioner's guidance on accepting blanket commercial confidentiality agreements: 'Unless confidentiality clauses are necessary or reasonable, there is a real risk that, in the event of a complaint, the Commissioner would order disclosure in any case.' (iii)

Finally, within the law of confidence there is also a public interest test. Therefore, the information should be disclosed in full. If any parts are redacted, they must be for information that can be proven to be a legal breach of confidence in court, and only then where secrecy can be shown to be in the public interest. These are difficult positions to argue when public money is at stake or where a public authority is offering a private company a monopoly to charge its stakeholders.

I reserve the right to appeal your decision to withhold any information or to charge excessive fees, and understand that under the act, I am entitled to a response within 20 working days. I would be grateful if you could confirm in writing that you have received this request.

Yours faithfully,

Edward Jones

(i) Innes v Information Commissioner [2014] EWCA Civ 1086 http://www.bailii.org/ew/cases/EWCA/Civ/...

(ii) Section 11 FOIA and the Form of a Request
https://panopticonblog.com/2014/08/01/se...

(iii) 'Freedom of Information Awareness Guidance 5: Commercial Interests' Office of the Information Commissioner, Page 10 https://www.humanrightsinitiative.org/pr...

COL-EB-InformationOfficer, City of London Corporation

Dear Edwards Jones,

FREEDOM OF INFORMATION ACT 2000 (FOIA) - REQUEST FOR INFORMATION

The City of London (CoL) acknowledges receipt of your request for information of 16 March 2023.

Public authorities are required to respond to requests within the statutory timescale of 20 working days beginning from the first working day after they receive a request. The Act does not always require public authorities to disclose the information which they hold.

The FOIA applies to the CoL as a local authority, police authority and port health authority. The CoL is the local and police authority for the "Square Mile", ie the historic City of London, and not for London as a whole. Please see the following page containing a link to a map (City of London - Interactive Mapping), which shows the local authority area covered by the CoL:
https://www.mapping.cityoflondon.gov.uk/...

The CoL does have some functions, including Port Health Authority functions, which extend beyond the City boundary. For further information please see: www.cityoflondon.gov.uk.

Yours sincerely,

Information Officer
Comptroller & City Solicitor's Department
City of London
Tel: 020-7332 1243
www.cityoflondon.gov.uk

show quoted sections

COL-EB-InformationOfficer, City of London Corporation

Dear Edward Jones,

FREEDOM OF INFORMATION ACT 2000 (FOIA) - REQUEST FOR INFORMATION

We write regarding your Freedom of Information request of 16 March 2023 and our acknowledgement also of 16 March 2023.

Although we were hoping to meet the statutory deadline of 14 April 2023, please accept our sincere apologies for this delay. This has been because of the continuously competing pressures of other/statutory duties, the number of other FOIA requests and Data Protection requests that we manage. In addition, the information requested, if it exists, is not held directly by the City itself but by several third parties in diverse locations. These factors are all placing a considerable burden on our resources. Nevertheless, the failure to meet the deadline for your request does not meet our normal standards, since the FOIA came into full force in 2005 we have replied annually to between 93% and 98% of requests within the statutory deadline.

In view of the above, we would like to extend the deadline for responding to you to Friday 28 April 2023, or sooner if possible.

If you have any queries or concerns, please contact us.

If you wish to make a complaint about the way the CoL has managed your enquiry, please make your complaint in writing to email address; [email address]. For a link to the CoL's FOI complaints procedure, please visit the following page: https://www.cityoflondon.gov.uk/footer/f..., at the end of which is located the FOI complaints procedure. If, having used the CoL's FOI Complaints Procedure, you are still dissatisfied, you may request the Information Commissioner to investigate. Please contact: Information Commissioner, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: (01625) 545700. Website: https://ico.org.uk/

Yours sincerely,

Access to Information Network Representative Chamberlain's Department City of London
Tel: 020 7332 1384
Website: https://www.cityoflondon.gov.uk/things-t...

show quoted sections

CHB - FOI, City of London Corporation

Dear Edward Jones,

 

FREEDOM OF INFORMATION ACT 2000 (FOIA) – REQUEST FOR INFORMATION

 

Following your request for information of 16 March 2023 and our
acknowledgment also of 16 March 2023 the City of London (CoL) responds as
follows.

 

The information you have requested can be found at the following link:

 

[1]Draft Pension Fund Annual report 2021/22 | City of London Pension Fund
(cityoflondonpensions.org)

 

If you have any queries or concerns, please contact me.

 

If you wish to make a complaint about the way the CoL has managed your
enquiry, please make your complaint in writing to email address:
[2][email address].

 

For a link to the CoL’s FOI complaints procedure, please visit the
following page: [3]https://www.cityoflondon.gov.uk/footer/f... at the
end of which is located the FOI complaints procedure. If, having used the
CoL’s FOI Complaints Procedure, you are still dissatisfied, you may
request the Information Commissioner to investigate. Please contact:
Information Commissioner, Wycliffe House, Water Lane, Wilmslow, Cheshire,
SK9 5AF. Telephone: (01625) 545700.  Website:

[4]Information Commissioner's Office (ICO)

 

The FOIA applies to the CoL as a local authority, police authority and
port health authority; and to the Guildhall School of Music and Drama
(GSMD), which it manages. Subject to any other statutory provisions
requiring the CoL to disclose information, release of information outside
the scope of the Act is subject to the discretion of the CoL.

 

The CoL holds the copyright in this communication. Its supply does not
give a right to re-use in a way that would infringe that copyright, for
example, by making copies, publishing and issuing copies to the public or
to any other person. Brief extracts of any of the material may be
reproduced under the fair dealing provisions of the Copyright, Designs and
Patents Act 1988 (sections 29 and 30) for the purposes of research for
non-commercial purposes, private study, criticism, review and news
reporting, subject to an acknowledgement of the copyright owner.

 

Yours sincerely

 

Access to Information Network Representative

Chamberlain's Department

City of London

Tel: 020 7332 1384

 

Dear City of London Corporation,

 

I am researching the fossil fuel investments made by UK Local Government
Pension Schemes (LGPS) for an upcoming report by UK Divest. On
publication, the report is likely to receive substantial interest from
press and the elected representatives sitting on pension fund committees
across the UK. Therefore can you please ensure the investment data you
provide is as accurate as possible as our analysis will be fundamentally
informed by it.

 

To complete this research, I require data on each investment that was held
by The City of London Corporation Pension Fund on 31 March 2022, or the
nearest possible date:

 

1. Investment names. Please provide the names of all investments held by
the pension fund. For direct investments, please provide the names of
individual investments such as specific stocks, bonds, and real estate
units. For indirect investments (i.e. those held via a third party),
please provide the names of investment vehicles, such as specific mutual
funds, exchange traded funds (ETFs) and real estate investment trusts
(REITs) and anything else. Note we do not need to know what each indirect
investment vehicle invests in as we will determine this in the data
analysis.

 

2. Investment identifiers. For listed investments (i.e. those traded on
public exchanges), such as bonds and equities, please provide the
International Securities Identifier Number (ISIN). For any investments
that do not have an ISIN number, such as some alternative assets, please
provide the Legal Entity Identifier (LEI). If an investment does not have
an identifier, please provide an explanation.

 

3. Asset types. The asset type for each investment as reported by the
pension fund, such as: real estate, cash, private equity, listed equity,
sovereign bonds, corporate bonds etc.

 

4. Investment managers. The name of the entity which is responsible for
the day-to-day management of each investment. For example, this could be
the name of the entity which manages a specific investment fund such as
Baillie Gifford, Legal & General, UBS etc. Note we do not need to know who
is responsible for the overall governance of the LGPS or any pools it
might belong to.

 

5. Investment values. The market value of each investment in pounds
sterling (£) on 31 March 2022 or the nearest possible date. And please
also give the total value of the pension fund.

 

We have created a read-only Google Sheet as a template for how we would
like the data presented when you answer this request. You can view and
download it here:
[5]https://gbr01.safelinks.protection.outlo...

 

If possible, please use this Google Sheet when answering. Please note
there are two tabs - 'summary' and 'data'. Please fill in both tabs. Using
the template would help us accurately analyse the data provided.

 

If you respond promptly and to a satisfactory standard, we will willingly
share our analysis with you prior to publication of our report, so you
have the chance to comment and benchmark your pension fund against other
UK LGPS.

 

I would like to receive this information in unlocked excel sheets without
protected cells (.xls). If you have to password protect the excel sheets,
please also provide the password to them. When considering the request for
this data in excel format, please refer to Innes v Information
Commissioner [2014] EWCA Civ 1086 (i), which allows a requester to express
a preference for communication by a particular means, specifically: "an
applicant's right to choose to have information provided to him in
electronic form extends to a right to choose the software format in which
it is embodied." (ii)

 

Please note:

 

Many public authorities release their contracts, minutes, and other
information of interactions with private vendors in line with the Freedom
of Information Act. The exemption for commercial interest under the Act
(section 43) is a qualified exemption, which means information can only be
withheld if it is in the public's interest. The public have an interest in
knowing what the Pension Fund is investing in, the terms of contracts and
the minutes of meeting with public authorities, whether or not public
money changes hands immediately.

 

If you are relying on section 41 (the exemption for legal breach of
confidence) then I would like to know the following:

 

* When these confidentiality agreements were agreed

* All correspondence and email in which these confidentiality agreements
were discussed

* The precise wording of the confidentiality agreements.

 

I ask these questions because guidance issued by both the Lord Chancellor
(draft guidance on FOI implementation) and the Office of Government
Commerce (Model terms and conditions for goods and services) specifically
state that public authorities should not enter into these types of
agreements; they go directly against the spirit of the laws of disclosure.
I would also point to the Information Commissioner's guidance on accepting
blanket commercial confidentiality agreements: 'Unless confidentiality
clauses are necessary or reasonable, there is a real risk that, in the
event of a complaint, the Commissioner would order disclosure in any
case.' (iii)

 

Finally, within the law of confidence there is also a public interest
test. Therefore, the information should be disclosed in full. If any parts
are redacted, they must be for information that can be proven to be a
legal breach of confidence in court, and only then where secrecy can be
shown to be in the public interest. These are difficult positions to argue
when public money is at stake or where a public authority is offering a
private company a monopoly to charge its stakeholders.

 

I reserve the right to appeal your decision to withhold any information or
to charge excessive fees, and understand that under the act, I am entitled
to a response within 20 working days. I would be grateful if you could
confirm in writing that you have received this request.

 

Yours faithfully,

 

Edward Jones

 

 

 

THIS E-MAIL AND ANY ATTACHED FILES ARE CONFIDENTIAL AND MAY BE LEGALLY
PRIVILEGED. If you are not the addressee, any disclosure, reproduction,
copying, distribution or other dissemination or use of this communication
is strictly prohibited. If you have received this transmission in error
please notify the sender immediately and then delete this e-mail.
Opinions, advice or facts included in this message are given without any
warranties or intention to enter into a contractual relationship with the
City of London unless specifically indicated otherwise by agreement,
letter or facsimile signed by a City of London authorised signatory. Any
part of this e-mail which is purely personal in nature is not authorised
by the City of London. All e-mail through the City of London's gateway is
potentially the subject of monitoring. All liability for errors and
viruses is excluded. Please note that in so far as the City of London
falls within the scope of the Freedom of Information Act 2000 or the
Environmental Information Regulations 2004, it may need to disclose this
e-mail. Website: http://www.cityoflondon.gov.uk

References

Visible links
1. https://www.cityoflondonpensions.org/res...
2. mailto:[email address]
3. https://www.cityoflondon.gov.uk/footer/f...
4. https://ico.org.uk/
5. https://docs.google.com/spreadsheets/d/1...

Dear Access to Information Network Representative,

You said: "The information you have requested can be found at the following link: Draft Pension Fund Annual report 2021/22 | City of London Pension Fund (cityoflondonpensions.org)"

My response:

The link you provided does not provide the information we requested in the original FOI request. It gives some general data but more precise informations which we requested such as Investment identifiers, Investment vehicles names and investment managers for each holding are not provided.

Please review our request and provide a breakdown of the direct investments and indirect investments vehicles without specifying the holdings names for indirect part. Please provide the holdings data for 31 March 2022 with an extra column providing investment names, values, identifiers and managers plus asset type in the excel spreadsheet format.

Please note that other pension funds have provided requested details for all investments (e.g. Gwynedd Pension Fund https://www.whatdotheyknow.com/request/g...). I can provide many more examples of other pension funds providing all of the requested data on request. The downloadable template spreadsheet we provided in the original FOI request also shows exactly what information we want: https://docs.google.com/spreadsheets/d/1...

Yours sincerely,
Edward Jones

CHB - FOI, City of London Corporation

Dear Edward Jones,

 

FREEDOM OF INFORMATION ACT 2000 (FOIA) - Complaint

 

Firstly please accept our apologies for this further delay in responding
to your query.

 

Following your initial enquiry of 16 March 2023, our acknowledgement also
of 16 March 2023, our FOIA response of 27 April 2023 and your restated
request of 1 May 2023 the CoL responds as follows.

 

The information you request is still available at the following link.

 

[1]https://www.cityoflondonpensions.org/res...

 

To further assist your research, we set out below direct references to
those pages in the published draft accounts which answer your queries.

 

1. Investment names. Please provide the names of all investments held by
the pension fund. For direct investments, please provide the names of
individual investments such as specific stocks, bonds, and real estate
units. For indirect investments (i.e. those held via a third party),
please provide the names of investment vehicles, such as specific mutual
funds, exchange traded funds (ETFs) and real estate investment trusts
(REITs) and anything else. Note we do not need to know what each indirect
investment vehicle invests in as we will determine this in the data
analysis.

There are no investments held falling into these categories. Please refer
to Notes 12,12a,12b and 13 commencing on page 32 of the linked document
which sets out the valuation hierarchy and definitions of each level.

 

2. Investment identifiers. For listed investments (i.e. those traded on
public exchanges), such as bonds and equities, please provide the
International Securities Identifier Number (ISIN). For any investments
that do not have an ISIN number, such as some alternative assets, please
provide the Legal Entity Identifier (LEI). If an investment does not have
an identifier, please provide an explanation.

There are no investments held falling into these categories. Please refer
to Note 13 commencing on page 35 of the linked document which sets out the
valuation hierarchy and definitions of each level.

 

3. Asset types. The asset type for each investment as reported by the
pension fund, such as: real estate, cash, private equity, listed equity,
sovereign bonds, corporate bonds etc.

Please refer to Note 12 on page 32 of the linked document.

 

4. Investment managers. The name of the entity which is responsible for
the day-to-day management of each investment. For example, this could be
the name of the entity which manages a specific investment fund such as
Baillie Gifford, Legal & General, UBS etc. Note we do not need to know who
is responsible for the overall governance of the LGPS or any pools it
might belong to.

Please refer to Note 12(b) on page 34 of the linked document.

 

5. Investment values. The market value of each investment in pounds
sterling (£) on 31 March 2022 or the nearest possible date. And please
also give the total value of the pension fund.

For investment values see question 3 above. Please refer to the Fund
Account and Net Asset Statement set out on Page 24 of the linked document
for the total value of the Pension Fund.

 

We note that the CoL is not required to provide information in a requested
format under the FOIA 2000, where the information has already been made
publicly accessible.

 

If you are still dissatisfied, you may request the Information
Commissioner to investigate. The Information Commissioner is a Crown
appointment, responsible for monitoring compliance with the FOIA. Please
contact: Information Commissioner, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF. Telephone: (01625) 545700. Website: [2]www.ico.org.uk

 

 

Yours sincerely,

 

 

Access to Information Network Representative

Chamberlain's Department

City of London

Tel: 020 7332 1384

Website: [3]www.cityoflondon.gov.uk

 

 

THIS E-MAIL AND ANY ATTACHED FILES ARE CONFIDENTIAL AND MAY BE LEGALLY
PRIVILEGED. If you are not the addressee, any disclosure, reproduction,
copying, distribution or other dissemination or use of this communication
is strictly prohibited. If you have received this transmission in error
please notify the sender immediately and then delete this e-mail.
Opinions, advice or facts included in this message are given without any
warranties or intention to enter into a contractual relationship with the
City of London unless specifically indicated otherwise by agreement,
letter or facsimile signed by a City of London authorised signatory. Any
part of this e-mail which is purely personal in nature is not authorised
by the City of London. All e-mail through the City of London's gateway is
potentially the subject of monitoring. All liability for errors and
viruses is excluded. Please note that in so far as the City of London
falls within the scope of the Freedom of Information Act 2000 or the
Environmental Information Regulations 2004, it may need to disclose this
e-mail. Website: http://www.cityoflondon.gov.uk

References

Visible links
1. https://www.cityoflondonpensions.org/res...
2. http://www.ico.org.uk/
3. http://www.cityoflondon.gov.uk/

Dear CHB - FOI,

Thank you for directing us to relevant sections of the annual report. However the provided information are still insufficient to put together a readable and accurate data set representing your investments.

We understand that the funds you are investing in are as follow:

LCIV Global Alpha Growth Fund* £171,700,000
LCIV MAC Fund £0
LCIV Alternative Credit Fund* £120,200,000
London CIV £200,000
Alternative assets £51,700,000
Artemis Institutional Equity Income Fund* £104,300,000
Aviva Lime Property Fund £32,600,000
C Worldwide Global Equities* £156,600,000
Harris Associates Global Equity Fund* £113,400,000
IFM Global Infrastructure (UK) £51,100,000
Lindsell Train UK Equity Fund £50,900,000
M&G UK Residential Property Fund £36,300,000
M&G Secured Property Income Fund £32,200,000
Liontrust UK Equity Fund £42,000,000
Pyrford Global Total Return Fund* £142,800,000
Ruffer Absolute Return Fund* £114,500,000
Veritas Global Focus Fund* £148,600,000

Can you please confirm that these are all of the funds that the LGPS is investing in and there are no other directly held equities or others?

Can you provide for us the breakdown of the "alternative assets" together with their managers and values as well as identifiers for each holding?

Moving forward, the pooled funds and sub-funds do have ISINs or LEI (in case of private entities), so please could you provide those.

Also any direct holdings you have - please can you break these down into discrete investments with ISIN numbers.

We really need either the ISIN or LEI identifiers for all investments to help us accurately analyse the data and ensure there are no mistakes. Please note that other pension funds have provided both ISINs and LEIs for all investments (e.g. Gwynedd Pension Fund
https://www.whatdotheyknow.com/request/g...
I can provide many more examples of other pension funds providing both LEIs and ISINs on request.

If necessary, if the information is not held by the investment managers, can you request that they (or can you) use this LEI lookup tool (or other tools) to find the identifier information for the investments: https://www.lei-lookup.com/record/ The problem with us using such a tool is that it is easy to make mistakes as many investments have several variations/similar names. So ideally someone who is familiar with the pension funds investments would do this to prevent mistakes and ensure we have the correct identifier for each investment. This would really help us accurately analyse the data provided, and fairly portray to what extent the pension fund invests in fossil fuels.

As an example the "C WorldWide Global Equities Fund" is listed under three different ISIN:
US36087T4940
US36087T4783
US36087T4866
and without your input we are not able to accurately report which one is the correct one.

We are working on a positive project to promote renewable energy investment and divestment from the stranded assets of fossil fuels.

Yours sincerely,
Edward Jones

Dear COL-EB-InformationOfficer,

We still haven't heard back regarding the request for clarification we have send you. Could you please acknowledge the message and advice when can we expect an answer?
https://www.whatdotheyknow.com/request/c...

We are working on a positive project to promote renewable energy investment and divestment from the stranded assets of fossil fuels.

Yours sincerely,
Edward Jones

COL-EB-InformationOfficer, City of London Corporation

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Dear Edward Jones,

Thank you for your email of 31 July 2023, as below and attached.

We can confirm that your request of 16 March 2023 was responded to on 27 April 2023, and your follow up request of 1 May 2023 responded to on 13 June 2023. Please note that your further comments of 24 July 2023, are currently being reviewed and will be responded to in due course.

Yours sincerely,

Information Officer
Comptroller & City Solicitor's Department
City of London
Tel: 020-7332 1243
http://www.cityoflondon.gov.uk/

show quoted sections

CHB - FOI, City of London Corporation

1 Attachment

Dear Edward Jones,

 

FREEDOM OF INFORMATION ACT 2000 (FOIA) - INFORMATION REQUEST

 

Following your further comments of 24 July 2023 and follow up request of
31 July 2023 the City of London (CoL) responds as follows.

 

Can you please confirm that these are all of the funds that the LGPS is
investing in and there are no other directly held equities or others? The
CoL confirms that there are no other LGPS investments.

 

Can you provide for us the breakdown of the "alternative assets" together
with their managers and values as well as identifiers for each holding? 
The information you require is in the attached document. Please note we do
not hold identifier numbers for the alternative assets.

 

Moving forward, the pooled funds and sub-funds do have ISINs or LEI (in
case of private entities), so please could you provide those. The
information you require is in the attached document.

 

Also any direct holdings you have - please can you break these down into
discrete investments with ISIN numbers.  The CoL confirms that there are
no direct holdings.

 

We hope that this response is of assistance. 

 

If you wish to make a complaint about the way the CoL has managed your
enquiry, please make your complaint in writing to email address:
[1][email address] For a link to the CoL’s FOI
complaints procedure, please visit the following page:
[2]www.cityoflondon.gov.uk/Feedback, at the end of which is located the
FOI complaints procedure. If, having used the CoL’s FOI Complaints
Procedure, you are still dissatisfied, you may request the Information
Commissioner to investigate. Please contact: Information Commissioner,
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: 0303
123 1113. Website: [3]http://www.ico.org.uk/. 

 

The FOIA applies to the CoL as a local authority, police authority and
port health authority; and to the Guildhall School of Music and Drama
(GSMD), which it manages. Subject to any other statutory provisions
requiring the CoL to disclose information, release of information outside
the scope of the Act is subject to the discretion of the CoL. 

 

The CoL holds the copyright in this communication. Its supply does not
give a right to re-use in a way that would infringe that copyright, for
example, by making copies, publishing and issuing copies to the public or
to any other person. Brief extracts of any of the material may be
reproduced under the fair dealing provisions of the Copyright, Designs and
Patents Act 1988 (sections 29 and 30) for the purposes of research for
non-commercial purposes, private study, criticism, review and news
reporting, subject to an acknowledgement of the copyright owner. 

 

Yours sincerely, 

 

Access to Information Network Representative

Chamberlain's Department

City of London

Tel: 020 7332 1384

 

Dear CHB - FOI,

 

Thank you for directing us to relevant sections of the annual report.
However the provided information are still insufficient to put together a
readable and accurate data set representing your investments.

 

We understand that the funds you are investing in are as follow:

 

LCIV Global Alpha Growth Fund* £171,700,000

LCIV MAC Fund £0

LCIV Alternative Credit Fund* £120,200,000

London CIV £200,000

Alternative assets £51,700,000

Artemis Institutional Equity Income Fund* £104,300,000

Aviva Lime Property Fund £32,600,000

C Worldwide Global Equities* £156,600,000

Harris Associates Global Equity Fund* £113,400,000

IFM Global Infrastructure (UK) £51,100,000

Lindsell Train UK Equity Fund £50,900,000

M&G UK Residential Property Fund £36,300,000

M&G Secured Property Income Fund £32,200,000

Liontrust UK Equity Fund £42,000,000

Pyrford Global Total Return Fund* £142,800,000

Ruffer Absolute Return Fund* £114,500,000

Veritas Global Focus Fund* £148,600,000

 

Can you please confirm that these are all of the funds that the LGPS is
investing in and there are no other directly held equities or others?

 

Can you provide for us the breakdown of the "alternative assets" together
with their managers and values as well as identifiers for each holding?

 

Moving forward, the pooled funds and sub-funds do have ISINs or LEI (in
case of private entities), so please could you provide those.

 

Also any direct holdings you have - please can you break these down into
discrete investments with ISIN numbers.

 

 

 

 

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