Correspondence with investment consultants & information on managing pension fund climate risk

Joel M Benjamin made this Freedom of Information request to Aberdeen City Council Automatic anti-spam measures are in place for this older request. Please let us know if a further response is expected or if you are having trouble responding.

The request was partially successful.

Dear Aberdeen City Council,

Please provide the following information in relation to NE Scotland management of pension fund climate risk, & information & advice on same provided by external investment consultants including (but not limited to) Aon, Mercer,  Allenbridge Epic and Hymans Robertson.

1) Please provide emails & correspondence between council employees  (NE Scotland finance function + responsible investment & pension fund mgmt), procurement, elected members (on pension fund committee), scheme members & external investment consultants on climate risk between 2018 and 2023

2) Please confirm if specific advice or information on climate risk has been sought by NE Scotland and received from Mercer, or other investment consultants? - If so please provide copies of this information. (key search terms include "climate risk", "physical risk", "asset allocation" and "fossil fuels")

3) Please provide the following data points in MS Excel format in relation to each external climate risk analyses undertaken on the councils investment portfolio, noting the date/ year + provider of each analysis:

i) Warming scenarios applied, i.e 2degC, 3degC, 4,degC, 5degC, 6degC & year in which it is suggested each warming threshold considered by the scenarios will be reached?

ii) Projected gains or losses for the portfolio &/or GDP activity for each scenario/year assessed

iii) Specifics of any change(s) to asset portfolio allocation recommended by the consultants to reduce the risk of future financial losses and/or to reduce financed emissions across the portfolio.

Yours faithfully,

Joel M Benjamin

Foi Enquiries, Aberdeen City Council

Did you know that the quickest way to make a request for information is to
make your request online? Please visit
[1]https://www.aberdeencity.gov.uk/services...
to make a request.

 

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this email and recommend that you subject any incoming email to your own
virus checking procedures. Unless related to Council business, the
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necessarily constitute those of Aberdeen City Council. Unless we expressly
say otherwise in this email or its attachments, neither this email nor its
attachments create, form part of or vary any contractual or unilateral
obligation. Aberdeen City Council's incoming and outgoing email is subject
to regular monitoring.

References

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Access to Information Team, Aberdeen City Council, Aberdeen City Council

1 Attachment

Reference: FOI-499772898
Date of request: 22/03/2023
Title of request: Managing Climate Risk

Dear Joel M Benjamin,

Thank you for your completing your Freedom of Information Request.

We aim to answer all requests within 20 working days.

You will receive a response via email and an update in [1]your self-serve
account if you have one.

For information about how we handle your request please see our [2]Freedom
of Information privacy notice.

For information about your appeal rights please see [3]Freedom of
Information reviews and appeals.

Kind regards

Access to Information Team
Aberdeen City Council | Customer Development | Customer Experience |
Customer
Marischal College | Broad Street | Aberdeen | AB10 1AB
[4]www.aberdeencity.gov.uk | Twitter: @AberdeenCC |
Facebook.com/AberdeenCC

Your personal data is very important to us. Please refer to [5]information
on why and how we use your data.

IMPORTANT NOTICE: This e-mail (including any attachment to it) is
confidential, protected by copyright and may be privileged. The
information contained in it should be used for its intended purposes only.
If you receive this email in error, notify the sender by reply email,
delete the received email and do not make use of, disclose or copy it.
Whilst we take reasonable precautions to ensure that our emails are free
from viruses, we cannot be responsible for any viruses transmitted with
this email and recommend that you subject any incoming email to your own
virus checking procedures. Unless related to Council business, the
opinions expressed in this email are those of the sender and they do not
necessarily constitute those of Aberdeen City Council. Unless we expressly
say otherwise in this email or its attachments, neither this email nor its
attachments create, form part of or vary any contractual or unilateral
obligation. Aberdeen City Council's incoming and outgoing email is subject
to regular monitoring.

References

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Access to Information Team, Aberdeen City Council, Aberdeen City Council

1 Attachment

Reference: FOI-499772898
Date of request: 21/03/2023
Title of request: Managing Climate Risk
Information request:

Please provide the following information in relation to NE Scotland
management of pension fund climate risk, & information & advice on same
provided by external investment consultants including (but not limited to)
Aon, Mercer,  Allenbridge Epic and Hymans Robertson.

1) Please provide emails & correspondence between council employees  (NE
Scotland finance function + responsible investment & pension fund mgmt),
procurement, elected members (on pension fund committee), scheme members &
external investment consultants on climate risk between 2018 and 2023

 

2) Please confirm if specific advice or information on climate risk has
been sought by NE Scotland and received from Mercer, or other investment
consultants? - If so please provide copies of this information. (key
search terms include "climate risk", "physical risk", "asset allocation"
and "fossil fuels")

 

3) Please provide the following data points in MS Excel format in relation
to each external climate risk analyses undertaken on the councils
investment portfolio, noting the date/ year + provider of each analysis:

i) Warming scenarios applied, i.e 2degC, 3degC, 4,degC, 5degC, 6degC &
year in which it is suggested each warming threshold considered by the
scenarios will be reached?

 

ii) Projected gains or losses for the portfolio &/or GDP activity for each
scenario/year assessed

 

iii) Specifics of any change(s) to asset portfolio allocation recommended
by the consultants to reduce the risk of future financial losses and/or to
reduce financed emissions across the portfolio.

Dear Joel M Benjamin,

Thank you for your information request. We have completed the necessary
search for the information requested. Our response is now detailed below.

Please provide the following information in relation to NE Scotland
management of pension fund climate risk, & information & advice on same
provided by external investment consultants including (but not limited to)
Aon, Mercer,  Allenbridge Epic and Hymans Robertson.

1) Please provide emails & correspondence between council employees (NE
Scotland finance function + responsible investment & pension fund mgmt),
procurement, elected members (on pension fund committee), scheme members &
external investment consultants on climate risk between 2018 and 2023

We are unable to provide you with information on the above requested
emails and correspondence on climate risk between 2018 and 2023 as the
cost of providing it has been calculated as being in excess of the
statutory maximum (£600).

To explain this, the information is not held in a way that can be easily
provided. There would be a minimum of 10 email accounts from NESPF staff
alone to go through, including but not limited to; Upper management,
Investments team and Governance team for the past 5 years. The work
involved in providing the information has been calculated at 5 hours per
email account, which equates to 50 hours, at an estimated minimum cost of
£750 in total.

In order to comply with its obligations under the terms of Section 16 of
the FOISA, we are refusing your request under the terms of Section 12 -
Excessive Cost of Compliance - of the FOISA.

Under our duty to provide advice and assistance, we would be happy to
discuss ways in which you may refine your request, so we can provide some
information of interest to you within the maximum cost limits.. Please do
contact the Access to Information team who will be happy to advise you, if
this is something you would like to pursue.

2) Please confirm if specific advice or information on climate risk has
been sought by NE Scotland and received from Mercer, or other investment
consultants?

- If so please provide copies of this information. (key search terms
include "climate risk", "physical risk", "asset allocation" and "fossil
fuels")

North East Scotland Pension Fund does not have current metrics available,
however we are in the process of preparing for Task Force on
Climate-related Financial Disclosures (TCFD) reporting and this includes
climate scenarios. This information will be based on March 2024 data and
our TCFD report will be posted to the North East Scotland Pension Fund
website in due course.

We are unable to provide you with information on if specific advice or
information on climate risk has been sought by NE Scotland and received
from Mercer, or other investment consultants. In order to comply with its
obligations under the terms of Section 17 of the FOISA, we are informing
you that we do not hold this information.

3) Please provide the following data points in MS Excel format in relation
to each external climate risk analyses undertaken on the councils
investment portfolio, noting the date/ year + provider of each analysis:

i) Warming scenarios applied, i.e 2degC, 3degC, 4,degC, 5degC, 6degC &
year in which it is suggested each warming threshold considered by the
scenarios will be reached?

ii) Projected gains or losses for the portfolio &/or GDP activity for each
scenario/year assessed

iii) Specifics of any change(s) to asset portfolio allocation recommended
by the consultants to reduce the risk of future financial losses and/or to
reduce financed emissions across the portfolio.

Please refer to the response to Question 2 above.

We are unable to provide you with information on the above data points in
relation to each external climate risk analyses undertaken on the councils
investment portfolio. In order to comply with its obligations under the
terms of Section 17 of the FOISA, we are informing you that we do not hold
this information.

We handled your request for information in accordance with the provisions
of the Freedom of Information (Scotland) Act 2002.

If you are dissatisfied with the way we have handled your request or the
content of it, you are entitled to ask for an appeal. You can do this from
your [1]Aberdeen City Council self service account.

For more information on your right to review, please visit [2]Freedom of
Information Review and Appeals.

We hope this helps with your request.

Kind regards

Access to Information Team
Aberdeen City Council | Customer Development | Customer Experience |
Customer
Marischal College | Broad Street | Aberdeen | AB10 1AB
[3]www.aberdeencity.gov.uk | Twitter: @AberdeenCC |
Facebook.com/AberdeenCC

Your personal data is very important to us. Please refer to [4]information
on why and how we use your data.

IMPORTANT NOTICE: This e-mail (including any attachment to it) is
confidential, protected by copyright and may be privileged. The
information contained in it should be used for its intended purposes only.
If you receive this email in error, notify the sender by reply email,
delete the received email and do not make use of, disclose or copy it.
Whilst we take reasonable precautions to ensure that our emails are free
from viruses, we cannot be responsible for any viruses transmitted with
this email and recommend that you subject any incoming email to your own
virus checking procedures. Unless related to Council business, the
opinions expressed in this email are those of the sender and they do not
necessarily constitute those of Aberdeen City Council. Unless we expressly
say otherwise in this email or its attachments, neither this email nor its
attachments create, form part of or vary any contractual or unilateral
obligation. Aberdeen City Council's incoming and outgoing email is subject
to regular monitoring.

References

Visible links
1. https://integration.aberdeencity.gov.uk/...
2. https://www.aberdeencity.gov.uk/services...
3. https://www.aberdeencity.gov.uk /
4. https://www.aberdeencity.gov.uk/your-dat...

Dear Aberdeen City Council,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of Aberdeen City Council's handling of my FOI request 'Correspondence with investment consultants & information on managing pension fund climate risk'.

You have calculated that gathering this information will exceed the cost limit, but I believe that this is a gross overestimation of the resource required, given I am primarily interested in emails from & between the councils advisory consultants - (ISIO?) & key financial & pension fund staff, as well as the chair of the pension committee.

In refusing this request, council states: "this request would incur more than reasonable cost to create (which for local authorities is £600).

In its refusal notice, council has not confirmed the key word search terms used were consistent with the specific key word search terms & named consultancies (i.e. ISIO) set out in my FOI request?

Additionally, the council is expected to give guidance in narrowing requests. In the absence of specific guidance from council, to narrow the scope of the request so as to fit within cost limits, I suggest the following:

1) reduce the key word search terms to "climate risk" and "climate scenario analysis" only

2) Reduce the number of email inboxes to be searched to the following, (in order of preference, should you have to exclude any based on time):

- Head/ Director of the Pension Fund
- Head/ Director of Finance
- Chair of Pensions Fund Committee
- Head of Procurement
- Wider Pension Fund Committee

3) Reduce the applicable search period to 2020-2023 only.

Having found the requested info, it is also likely you will cite "commercial sensitivity" concerns on the part of consultants providing the council with information & advice - you may be aware, ICO guidance states that when applying a commercial sensitivity exemption, an authority "must show that because [the information] is commercially sensitive, disclosure would be, or would be likely to be, prejudicial to the commercial activities of a person (an individual, a company, the public authority itself or any other legal entity)" - prejudice vs contracts is not specifically referenced.

In DoH vs Information Commissioner (EA/2008/0018) - it was held that while some contractual information may be exempted from disclosure, this should not result in the blanket exemption of whole contracts or documents, and any decision to redact or disclose should be taken on a clause by clause, point by point basis.

Please note I have zero interest in obtaining commercial fee or price structure information relating to information, contracted services, or advice the council has sought and received from external third parties - the request is targeted at the communications of senior council staff, with no realistic expectation of privacy when conducting public affairs - in order to better understand how public money is being invested and spent - and how councils responsibilities to manage climate risks, protect the environment, and contribute towards achieving the UK's wider net zero goal are being shaped by external investment consultants.

Procurement framework guidance provided by Aberdeen to the consultant(s) at bidding stage makes clear that any communications or information provided to the council will be subject to FOIA. Additionally, any climate risk assessment advice or modelling undertaken by the consultant(s) is only made possible with information and investment assumptions provided by council to the consultant(s), therefore any attempt to hide behind commercial sensitivity claims could be viewed as a convenient vehicle by which Aberdeen could shield the various assumptions it makes about the future impacts of climate change on future fund returns from effective public & LGPS member scrutiny.

Some examples of climate scenario analysis at other councils show implausibly low future impacts for 4 degrees warming, in a scenario described by climate scientists as "hellish" where society as we know it would cease to function, yet the pension fund assets are only shown to suffer annual losses in the order of ~1%?!

Release of climate risk information would likely benefit both LGPS scheme members, and local taxpayers, by providing scope for wider scrutiny, & reassurance for members that the scheme is actively managing climate risks in line with its fiduciary duty, whilst attempting to lower the funds climate impact.

The information requested pertains to climate risk assessments relating to significant public expenditure - namely, consultancy expenditure and the pension scheme investments of public sector workers - underwritten by the taxpayer, and how those schemes are managed in a way which provides for both a stable income in retirement for members, and either contributes towards achieving a liveable climate for scheme members and wider society, or as is presently the case - further contributes to the ongoing growth in global emissions - driving climate breakdown.

As such, given both the substantial sums of public money being managed, and the schemes investments in large financial, transportation, industrial, agricultural and fossil fuel sector companies driving climate change - there is a legitimate public interest in understanding upon what information and advice scheme funds are being invested, and that such information and climate risk advice, in the absence of any regulatory oversight, is consistent with the latest climate science on expected future global warming, and its likely effects on both the environment, and future pension scheme returns.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/c...

Yours faithfully,

Joel M Benjamin

Foi Enquiries, Aberdeen City Council

Did you know that the quickest way to make a request for information is to
make your request online? Please visit
[1]https://www.aberdeencity.gov.uk/services...
to make a request.

 

IMPORTANT NOTICE: This e-mail (including any attachment to it) is
confidential, protected by copyright and may be privileged. The
information contained in it should be used for its intended purposes only.
If you receive this email in error, notify the sender by reply email,
delete the received email and do not make use of, disclose or copy it.
Whilst we take reasonable precautions to ensure that our emails are free
from viruses, we cannot be responsible for any viruses transmitted with
this email and recommend that you subject any incoming email to your own
virus checking procedures. Unless related to Council business, the
opinions expressed in this email are those of the sender and they do not
necessarily constitute those of Aberdeen City Council. Unless we expressly
say otherwise in this email or its attachments, neither this email nor its
attachments create, form part of or vary any contractual or unilateral
obligation. Aberdeen City Council's incoming and outgoing email is subject
to regular monitoring.

References

Visible links
1. https://www.aberdeencity.gov.uk/services...

Foi Enquiries, Aberdeen City Council

1 Attachment

Dear Joel M Benjamin,

 

Thank you very much for your email 21 April 2023.

 

We are writing to confirm that we will be treating your refined request as
a new request. You will receive an acknowledgement and reference number
shortly.

 

We understand that you a requesting:

 

Please provide the following information in relation to NE Scotland
management of pension fund climate risk, & information & advice on same
provided by external investment consultants including (but not limited to)
Aon, Mercer, Allenbridge Epic and Hymans Robertson.

 

Please provide emails from & between the councils advisory consultants -
(ISIO?) & key financial & pension fund staff, as well as the chair of the
pension committee. To narrow the scope of the request so as to fit within
cost limits, please:

 

1) reduce the key word search terms to "climate risk" and "climate
scenario analysis" only

 

2) Reduce the number of email inboxes to be searched to the following, (in
order of preference, should you have to exclude any based on time):

 

- Head/ Director of the Pension Fund

- Head/ Director of Finance

- Chair of Pensions Fund Committee

- Head of Procurement

- Wider Pension Fund Committee

 

3) Reduce the applicable search period to 2020-2023 only.

 

Please note I have zero interest in obtaining commercial fee or price
structure information relating to information, contracted services, or
advice the council has sought and received from external third parties -
the request is targeted at the communications of senior council staff,
with no realistic expectation of privacy when conducting public affairs -
in order to better understand how public money is being invested and spent
- and how councils responsibilities to manage climate risks, protect the
environment, and contribute towards achieving the UK's wider net zero goal
are being shaped by external investment consultants.

 

Please do let us know if you would like any amendments made to the above.
We will keep your points on commercial interests in mind when answering
your request.

 

Kindest regards

 

Access to Information Team

 

[1]ACC_Crest_for Access to Information Team
mac email
Aberdeen City Council | Access to Information Team |
Customer Feedback |Customer

Marischal College | Business Hub 6 | 1^st Floor  | Broad
Street | Aberdeen | AB10 1AB

 

Dial: 01224 522166

[2]www.aberdeencity.gov.uk | Twitter: @AberdeenCC |
Facebook.com/AberdeenCC

 

IMPORTANT NOTICE: This e-mail (including any attachment to it) is
confidential, protected by copyright and may be privileged. The
information contained in it should be used for its intended purposes only.
If you receive this email in error, notify the sender by reply email,
delete the received email and do not make use of, disclose or copy it.
Whilst we take reasonable precautions to ensure that our emails are free
from viruses, we cannot be responsible for any viruses transmitted with
this email and recommend that you subject any incoming email to your own
virus checking procedures. Unless related to Council business, the
opinions expressed in this email are those of the sender and they do not
necessarily constitute those of Aberdeen City Council. Unless we expressly
say otherwise in this email or its attachments, neither this email nor its
attachments create, form part of or vary any contractual or unilateral
obligation. Aberdeen City Council's incoming and outgoing email is subject
to regular monitoring.

References

Visible links
2. http://www.aberdeencity.gov.uk/

Access to Information Team, Aberdeen City Council, Aberdeen City Council

1 Attachment

Reference: FOI-512124308
Date of request: 02/05/2023
Title of request: Managing Climate Risk

Dear Joel M Benjamin,

Thank you for your completing your Freedom of Information Request.

We aim to answer all requests within 20 working days.

You will receive a response via email and an update in [1]your self-serve
account if you have one.

For information about how we handle your request please see our [2]Freedom
of Information privacy notice.

For information about your appeal rights please see [3]Freedom of
Information reviews and appeals.

Kind regards

Access to Information Team
Aberdeen City Council | Customer Development | Customer Experience |
Customer
Marischal College | Broad Street | Aberdeen | AB10 1AB
[4]www.aberdeencity.gov.uk | Twitter: @AberdeenCC |
Facebook.com/AberdeenCC

Your personal data is very important to us. Please refer to [5]information
on why and how we use your data.

IMPORTANT NOTICE: This e-mail (including any attachment to it) is
confidential, protected by copyright and may be privileged. The
information contained in it should be used for its intended purposes only.
If you receive this email in error, notify the sender by reply email,
delete the received email and do not make use of, disclose or copy it.
Whilst we take reasonable precautions to ensure that our emails are free
from viruses, we cannot be responsible for any viruses transmitted with
this email and recommend that you subject any incoming email to your own
virus checking procedures. Unless related to Council business, the
opinions expressed in this email are those of the sender and they do not
necessarily constitute those of Aberdeen City Council. Unless we expressly
say otherwise in this email or its attachments, neither this email nor its
attachments create, form part of or vary any contractual or unilateral
obligation. Aberdeen City Council's incoming and outgoing email is subject
to regular monitoring.

References

Visible links
1. https://integration.aberdeencity.gov.uk/...
2. https://www.aberdeencity.gov.uk/your-dat...
3. https://www.aberdeencity.gov.uk/services...
4. https://www.aberdeencity.gov.uk /
5. https://www.aberdeencity.gov.uk/your-dat...

Access to Information Team, Aberdeen City Council, Aberdeen City Council

1 Attachment

Reference: FOI-512124308
Date of request: 21/04/2023
Title of request: Managing Climate Risk
Information request:

Please provide the following information in relation to NE Scotland
management of pension fund climate risk, & information & advice on same
provided by external investment consultants including (but not limited to)
Aon, Mercer, Allenbridge Epic and Hymans Robertson.

Please provide emails from & between the councils advisory consultants -
(ISIO?) & key financial & pension fund staff, as well as the chair of the
pension committee. To narrow the scope of the request so as to fit within
cost limits, please:

1) reduce the key word search terms to "climate risk" and "climate
scenario analysis" only

2) Reduce the number of email inboxes to be searched to the following, (in
order of preference, should you have to exclude any based on time):

- Head/ Director of the Pension Fund

- Head/ Director of Finance

- Chair of Pensions Fund Committee

- Head of Procurement

- Wider Pension Fund Committee

3) Reduce the applicable search period to 2020-2023 only.

Please note I have zero interest in obtaining commercial fee or price
structure information relating to information, contracted services, or
advice the council has sought and received from external third parties -
the request is targeted at the communications of senior council staff,
with no realistic expectation of privacy when conducting public affairs -
in order to better understand how public money is being invested and spent
- and how councils responsibilities to manage climate risks, protect the
environment, and contribute towards achieving the UK's wider net zero goal
are being shaped by external investment consultants.

Dear Joel M Benjamin,

Thank you for your information request. Our sincere apologies for the
delay in responding to your request. We have completed the necessary
search for the information requested. Our response is now detailed below.

Please provide the following information in relation to NE Scotland
management of pension fund climate risk, & information & advice on same
provided by external investment consultants including (but not limited to)
Aon, Mercer, Allenbridge Epic and Hymans Robertson.

Under our duty to provide advice and assistance, we would like to advise
that Aberdeen City Council do not have a relationship with Aon,
Allenbridge and Hymans. Mercer provide our actuarial services only. The
only relevant information for this request would relate to ISIO.

Please provide emails from & between the councils advisory consultants -
(ISIO?) & key financial & pension fund staff, as well as the chair of the
pension committee. To narrow the scope of the request so as to fit within
cost limits, please:

1) reduce the key word search terms to "climate risk" and "climate
scenario analysis" only

2) Reduce the number of email inboxes to be searched to the following, (in
order of preference, should you have to exclude any based on time):

3) Reduce the applicable search period to 2020-2023 only.

- Head/ Director of the Pension Fund

Aberdeen City Council’s equivalent to the Head/Director of the Pension
Fund is the Pension Manager. On receipt of your request, a search of the
Pension Manager’s emails was undertaken, using the search terms described
above. The same search was undertaken of the ‘Investments’ email box. We
confirm that we hold emails which include the key words ‘climate risk’ and
‘climate scenario analysis’ for the time period 2020-2023 within these
emails.

Please refer to the attached emails.’ R - Combined Emails from Pension
Manager’. We will email you this attachment separately as the file is too
large to attach on this platform.

Please note that the names and direct contact details of individuals who
are below Chief Officer level have been redacted, as we consider that this
information is exempt under Section 38(1)(b) in conjunction with Section
38(2A)(a) – Personal Information – of the FOISA.

In making this decision Aberdeen City Council considered the following
points:

We are of the opinion that Section 38(1)(b) applies to your request as the
information in question is personal information relating to living
individuals, who can be identified from it.

Further, Section 38(2A)(a) applies, as we consider that disclosure of this
information would be a breach of the first Data Protection Principle (that
personal information must be processed fairly and lawfully). As these
individuals are below Chief Officer level, they would not have an
expectation that this information about them would be disclosed into the
public domain under the FOISA.

Please note that we also hold emails which are considered to be
commercially sensitive. There is one attachment ‘Private RI Report’, in
which we are unable to provide you with information on as it is exempt
from disclosure.  In order to comply with our obligations under the terms
of Section 16 of the FOISA, we hereby give notice that we are refusing
this question under the terms of Section 33 (1) (b) - Commercial Interests
- of the FOISA.

In making this decision we considered the following points:

The attachment contains information on agreements/negotiations and general
communications with Fund Managers, so sharing this information would be
potentially damaging to NESPF’s relationship with Fund Managers and could
give information to our competitors which could impact business severely.

This information is not publicly available, and we do not disclose it. The
Fund Managers do not expect detailed information of how they run their
business to be published in the public domain and to be accessible to
potential business rivals; this would also be the case for the underlying
managers.

We know from our knowledge of the industry and in talking to fund managers
that if we gave out this sort of information we would no longer be able to
invest with the top quartile managers as it’s a very competitive market
and any knowledge a rival obtains could impact business severely. This
could severely damage the Pensions Fund and Aberdeen City Council
reputation and ability to attract quality investors.

This would result in a negative impact on the Fund’s investment return,
which in turn would lead to higher employer contribution rates. We do
regard this as a very likely scenario.

Disclosure of the information would harm the NESPF’s reputation with Fund
Managers and impact our ability to access the top fund managers and
investment opportunities. This would directly impact on the funding
position of the Fund and ultimately the tax payer.

We understand that there is public interest in allowing transparency and
accountable surrounding the investments of the Fund.

However, we are of the view that in this case, the public interest lies in
withholding the information as disclosure would prejudice ACC’s commercial
relationships and future contractual negotiations with suppliers and after
considering all the circumstances of the case, the public interest is best
met by applying Section 33(1)(b).

 

- Head/ Director of Finance

Aberdeen City Council’s equivalent to the Head/Director of Finance is
Jonathan Belford, Chief Officer - Finance. On receipt of your request, a
search of the Finance Chief Officer’s email account was undertaken, using
the search terms described above.

Please find attached, ‘R - Combined Response from Accounting’. We will
email you this attachment separately as the file is too large to attach on
this platform.

Please note that the names and direct contact details of individuals who
are below Chief Officer level have been redacted, as we consider that this
information is exempt under Section 38(1)(b) in conjunction with Section
38(2A)(a) – Personal Information – of the FOISA.

In making this decision Aberdeen City Council considered the following
points:

We are of the opinion that Section 38(1)(b) applies to your request as the
information in question is personal information relating to living
individuals, who can be identified from it.

Further, Section 38(2A)(a) applies, as we consider that disclosure of this
information would be a breach of the first Data Protection Principle (that
personal information must be processed fairly and lawfully). As these
individuals are below Chief Officer level, they would not have an
expectation that this information about them would be disclosed into the
public domain under the FOISA.

- Chair of Pensions Fund Committee

With regards to searching the email inbox of the Chair of the Pensions
Fund Committee:

The Committee Chair (Convenor) is Councillor John Cooke.

Please note that individual elected members are not classed as part of the
local authority under FOISA and as such are not subject to FOI requests
themselves. On this basis, a search of Councillor Cooke’s email inbox was
not undertaken.

However, under our duty to provide advice and assistance, relevant
information held in Councillor Cooke’s emails would also be captured
within NESPF emails. A search undertaken by ACC within relevant NESPF
emails did not show that any relevant correspondence in relation to
Councillor Cooke is held. In addition, we would like to advise that
Councillor Cooke does not deal with the day-to-day running of the Fund and
therefore would not hold relevant information.

We are unable to provide you with the following information in relation to
NE Scotland management of pension fund climate risk and information and
advice on same provided by external investment consultants including (but
not limited to) Aon, Mercer, Allenbridge Epic and Hymans Robertson: emails
from and between the Council’s advisory consultants (ISIO?) and the chair
of the pension committee. In order to comply with its obligations under
the terms of Section 17 of the FOISA, we are informing you that we do not
hold this information.

- Head of Procurement

The Head of Procurement undertook a search of their email account for the
key words requested and no information was held.

We are unable to provide you with the following information in relation to
NE Scotland management of pension fund climate risk and information and
advice on same provided by external investment consultants including (but
not limited to) Aon, Mercer, Allenbridge Epic and Hymans Robertson: emails
from and between the Council’s Head of Procurement. In order to comply
with its obligations under the terms of Section 17 of the FOISA, we are
informing you that we do not hold this information.

- Wider Pension Fund Committee

With regards to searching the email inbox of the Wider Pension Fund
Committee:

The Wider Pension Fund Committee members are all elected members. As
above, individual elected members are not classed as part of the local
authority and as such are not subject to FOI requests, therefore a search
of their individual email inboxes was not undertaken. However, under our
duty to provide advice and assistance, relevant information held in
elected members emails would also be captured within NESPF emails. A
search was undertaken by ACC within relevant NESPF emails and no relevant
correspondence relating to the Wider Pension Fund Committee was found. In
addition, we would like to advise that the Wider Pension Fund Committee
does not deal with the day-to-day running of the Fund and therefore would
not hold relevant information.

Please note I have zero interest in obtaining commercial fee or price
structure information relating to information, contracted services, or
advice the council has sought and received from external third parties -
the request is targeted at the communications of senior council staff,
with no realistic expectation of privacy when conducting public affairs -
in order to better understand how public money is being invested and spent
- and how councils responsibilities to manage climate risks, protect the
environment, and contribute towards achieving the UK's wider net zero goal
are being shaped by external investment consultants.

We handled your request for information in accordance with the provisions
of the Freedom of Information (Scotland) Act 2002.

If you are dissatisfied with the way we have handled your request or the
content of it, you are entitled to ask for an appeal. You can do this from
your [1]Aberdeen City Council self service account.

For more information on your right to review, please visit [2]Freedom of
Information Review and Appeals.

We hope this helps with your request.

Kind regards

Access to Information Team
Aberdeen City Council | Customer Development | Customer Experience |
Customer
Marischal College | Broad Street | Aberdeen | AB10 1AB
[3]www.aberdeencity.gov.uk | Twitter: @AberdeenCC |
Facebook.com/AberdeenCC

Your personal data is very important to us. Please refer to [4]information
on why and how we use your data.

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confidential, protected by copyright and may be privileged. The
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If you receive this email in error, notify the sender by reply email,
delete the received email and do not make use of, disclose or copy it.
Whilst we take reasonable precautions to ensure that our emails are free
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this email and recommend that you subject any incoming email to your own
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obligation. Aberdeen City Council's incoming and outgoing email is subject
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Foi Enquiries, Aberdeen City Council

5 Attachments

Good afternoon Joel,

 

As advised in our response to your request, please find the files noted
attached here.

 

I have also included a copy of our response and your right to request a
Review for reference. Apologies again about the delay in getting this
information to you.

 

If you have any queries, please don’t hesitate to get back to us.

 

Many thanks,

Rebecca

 

[1]ACC_Crest_for Rebecca Finlayson | Access to Information Officer
mac email
Aberdeen City Council | Access to Information Team |
Customer Feedback |Customer

Marischal College | Business Hub 66 | 3^rd Floor | Broad
Street | Aberdeen | AB10 1AB

 

Dial: 01224 522166

[2]www.aberdeencity.gov.uk | Twitter: @AberdeenCC |
Facebook.com/AberdeenCC

 

 

IMPORTANT NOTICE: This e-mail (including any attachment to it) is
confidential, protected by copyright and may be privileged. The
information contained in it should be used for its intended purposes only.
If you receive this email in error, notify the sender by reply email,
delete the received email and do not make use of, disclose or copy it.
Whilst we take reasonable precautions to ensure that our emails are free
from viruses, we cannot be responsible for any viruses transmitted with
this email and recommend that you subject any incoming email to your own
virus checking procedures. Unless related to Council business, the
opinions expressed in this email are those of the sender and they do not
necessarily constitute those of Aberdeen City Council. Unless we expressly
say otherwise in this email or its attachments, neither this email nor its
attachments create, form part of or vary any contractual or unilateral
obligation. Aberdeen City Council's incoming and outgoing email is subject
to regular monitoring.

References

Visible links
2. http://www.aberdeencity.gov.uk/