Carbon Bubble Risk, Pension Fund Fiduciary Duty & Risks To Local Taxpayers Through LGPS Underfunding and Exposure to Investment Losses in Defined Benefit Schemes

The request was partially successful.

Dear Wirral Metropolitan Borough Council,

The Bank of England, HSBC, Citi Bank, Mercers, and the World Bank are clear that climate change is a major and growing financial issue. Bank of England Governor Mark Carney has said that climate change poses physical, liability and transition risks, which are all increasing.

Therefore, carbon bubble risk is now a clear material financial risk, and it is in the best interests of pension fund members to have regard to and actively manage, financial risks posed by climate change.

Additionally, as the individual ensuring compliance with SIP documents and signing off on the pension fund annual accounts, the s151 officer has a fiduciary duty to local taxpayers - who would ultimately be required to bail out the defined benefit LGPS fund, in the event of significant losses suffered in carbon markets, should the LGPS fund not manage carbon risk prudently.

We are therefore requesting the Pension Fund/ Committee/ Board would set out the appropriate response of the fund to the following questions:

(1) Please provide the two most recent versions of the Statement of Investment Principles (SIP)
(2) Will the fund be reviewing its SIP documents to pursue best practice and review carbon risk management and investment mandates in advance of LGPS pooling? If so when?
(3) Please provide current contract and procurement documents for the Investment Adviser(s) to the Pension Fund Committee.
(4) Please provide current procurement and contract documentation for the external fund manager(s) as set out in investment management agreements.
(5) Please provide a list of compliance breaches identified by the Head of Finance/ s.151 officer and brought to the attention of the Pension Fund Committee, during the last three (3) financial years.
(6) What steps have the Pension Fund Committee and Board taken to address the financial risks posed by climate change?
(7) Since the December 2015 Paris COP agreement, Peabody bankruptcy, and Exxon Mobil downgrade, has the pension fund changed its approach to climate change risks and investment in carbon stocks?
(8) Please provide Pension Fund Committee and Board meeting minutes where climate change, and carbon bubble investment risk was discussed, and minuted 2014 - 2016.
(9) Have you surveyed or formally consulted with your individual members or employers for their views on your ESG policies or practices in the last 10 years?
(10) How much does the fund spend on ESG engagement services and can you give any examples of engagement activities relating to climate change/carbon risk from the last 10 years?

We are asking these questions to understand how/ if UK local authority pensions funds fiduciary duties are being met in regard to climate change related financial risks - and to appraise financial risks to taxpayers in situations where fiduciary duty to manage carbon investment risk has been breached.

Yours faithfully,

Joel M Benjamin

Paterson, Lynette M., Wirral Metropolitan Borough Council

Dear Mr Benjamin,

 

I refer to the request for information contained in your email of 12
December. I consider that some of the queries contained in your request
come within the remit of the Freedom of Information Act 2000, (“ FOIA”)
whilst other queries should be considered under the Environmental
Information Regulations 2004(“EIR”), in that they relate to environmental
information. Environmental information is defined in Regulation 2 (a) (b)
and (c)of the EIR as any information in written, visual, aural, electronic
or any other material form on-

(a)  The state of the elements of the environment, such as air and
atmosphere, water soil, land, landscape and natural sites, including
wetlands, coastal and marine areas, biological diversity and its
components, including genetically modified organisms and the interaction
among these elements;

(b)  factors. Such as substances, energy, noise, radiation or waste,
including radioactive waste, emissions, discharges, and other releases
into the environment, affecting or likely to affect the elements of the
environment referred to in (a);

(c)  measures (including administrative measures), such as policies,
legislation, plans ,programmes, environmental agreements ,and activities
affecting or likely to affect the elements and factors referred to in (a)
and (b) as well as measures or activities designed to protect those
elements.

 

FOIA Queries

The Council requires an extension (under Section 10 (3) of FOIA)  to the
20 working day response time in order to consider the public interest test
in relation to certain qualified exemptions under FOIA in connection
specifically with queries 3 and 4. It would assist the Council if you
could indicate whether there is a particular aspect of the current
contract and procurement documents in queries 3 and 4 , that you would
wish the Council to concentrate on, having regard to the volume of
information held by the Council.

EIR Queries

The Council also seeks to extend the period of 20 working days in which to
respond as provided for in Regulation7 (1) of the EIR, which provides that
the Council as a public authority can extend the period where it
reasonably believes that the complexity and the volume of the information 
requested means that it is impracticable either to comply with the request
within the earlier period or make a decision to refuse to do so.

 

I am therefore writing to inform you that the Council is extending the
period for response in respect of both FOIA and EIR queries  until 17
January next.

 

Yours sincerely,

 

 

Rosemary Lyon,

Solicitor,

Law and Governance

Business Services

Town Hall

Brighton Street

Wallasey

Wirral

CH44 8ED

0151-691-8141

 

 

 

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Dear Paterson, Lynette M.,

Please note a response to this FOIA is now overdue. Please respond ASAP.

Yours sincerely,

Joel M Benjamin

InfoMgr, FinDMT, Wirral Metropolitan Borough Council

Dear Mr Benjamin

As per my email of 3 January 2017, the period for response was extended until 17 January 2017 and is not yet overdue. A response will be issued on 17 January 2017.

Yours sincerely

Lynette Paterson
Senior Information Management Officer
Business Services - Digital

Wallasey Town Hall
Brighton Street
Wallasey
Wirral
CH44 8ED 
Tel: 0151 691 8201
[Wirral Borough Council request email]

show quoted sections

InfoMgr, FinDMT, Wirral Metropolitan Borough Council

1 Attachment

Dear Mr Benjamin,

 

I refer to your email dated 12 December 2016, which contained the
following request for information:-

 

Dear Wirral Metropolitan Borough Council,

 

The Bank of England, HSBC, Citi Bank, Mercers, and the World Bank are
clear that climate change is a major and growing financial issue. Bank of
England Governor Mark Carney has said that climate change poses physical,
liability and transition risks, which are all increasing.

 

Therefore, carbon bubble risk is now a clear material financial risk, and
it is in the best interests of pension fund members to have regard to and
actively manage, financial risks posed by climate change.

 

Additionally, as the individual ensuring compliance with SIP documents and
signing off on the pension fund annual accounts, the s151 officer has a
fiduciary duty to local taxpayers - who would ultimately be required to
bail out the defined benefit LGPS fund, in the event of significant losses
suffered in carbon markets, should the LGPS fund not manage carbon risk
prudently.

 

We are therefore requesting the Pension Fund/ Committee/ Board would set
out the appropriate response of the fund to the following questions:

 

(1) Please provide the two most recent versions of the Statement of
Investment Principles (SIP)

(2) Will the fund be reviewing its SIP documents to pursue best practice
and review carbon risk management and investment mandates in advance of
LGPS pooling? If so when?

(3) Please provide current contract and procurement documents for the
Investment Adviser(s) to the Pension Fund Committee.

(4) Please provide current procurement and contract documentation for the
external fund manager(s) as set out in investment management agreements.

(5) Please provide a list of compliance breaches identified by the Head of
Finance/ s.151 officer and brought to the attention of the Pension Fund
Committee, during the last three (3) financial years.

(6) What steps have the Pension Fund Committee and Board taken to address
the financial risks posed by climate change?

(7) Since the December 2015 Paris COP agreement, Peabody bankruptcy, and
Exxon Mobil downgrade, has the pension fund changed its approach to
climate change risks and investment in carbon stocks?

(8) Please provide Pension Fund Committee and Board meeting minutes where
climate change, and carbon bubble investment risk was discussed, and
minuted 2014 - 2016.

(9) Have you surveyed or formally consulted with your individual members
or employers for their views on your ESG policies or practices in the last
10 years?

(10) How much does the fund spend on ESG engagement services and can you
give any examples of engagement activities relating to climate
change/carbon risk from the last 10 years?

 

We are asking these questions to understand how/ if UK local authority
pensions funds fiduciary duties are being met in regard to climate change
related financial risks - and to appraise financial risks to taxpayers in
situations where fiduciary duty to manage carbon investment risk has been
breached.

 

 

The Council’s response is as follows:-

 

1) Please provide the two most recent versions of the Statement of
Investment Principles (SIP)

 

Merseyside Pension Fund (MPF) publishes its Statement of Investment
Principles (which incorporates its statement of its strategy on
Responsible Investment) on its website:
[1]https://mpfmembers.org.uk/content/statem...

 

(2) Will the fund be reviewing its SIP documents to pursue best practice
and review carbon risk management and investment mandates in advance of
LGPS pooling? If so when?

 

MPF is required by the LGPS Investment Regulations 2016 to publish an
Investment Strategy Statement (ISS) by April 2017, which replaces the
current SIP and covers all aspects of its investment strategy. MPF is
obliged to adhere to LGPS Regulation and Guidance (of the Secretary of
State for Communities & Local Government) in formulating its ISS:
[2]https://www.gov.uk/government/publicatio...

 

As part of its commitment to Responsible Investment, MPF is a longstanding
signatory of the PRI and submits annually to its Reporting & Assessment
Framework: captured within this survey and evaluation of RI implementation
and best practice across the investment industry, is a specific module
covering the requirements, goals and aspirations set out for service
providers and intermediaries (such as investment managers) with respect to
RI. The following link is to the section of the PRI website that hosts
MPF’s 2016 submission to the reporting framework (the relevant module is
entitled ‘Indirect – Manager Selection, Appointment and Monitoring’):
[3]https://reporting.unpri.org/surveys/PRI-...

MPF is currently working on its 2017 submission to the PRI.

 

(3) Please provide current contract and procurement documents for the
Investment Adviser(s) to the Pension Fund Committee.

(4) Please provide current procurement and contract documentation for the
external fund manager(s) as set out in investment management agreements.

I consider that the scope and size of the requested information would
potentially impose a wholly disproportionate burden on the Council.,
having regard to the volume of documentation which would need to be
retrieved and considered. I refer to the case of McInerney v.Information
Commissioner (2015) UKUT 0047 (AAC) which was a decision of the Upper Tier
Tribunal. That case held that a public authority could consider the
request for information vexatious under section 14 of the Freedom of
Information Act 2000, rather than rely on the appropriate limit  and the
cost of complying as provided for in Section 12 of FOIA. However, having
regard to the other information provided in this response, I would be
grateful if you would confirm whether you still wish to proceed with this
part of your request.

 

(5) Please provide a list of compliance breaches identified by the Head of
Finance/ s.151 officer and brought to the attention of the Pension Fund
Committee, during the last three (3) financial years.

 

We are not aware of any compliance breaches, in a context relevant to this
request, that have been reported to the Pensions Committee. However,
regular reporting is presented to the Pensions Committee on the control
and regulatory compliance environment in relation to MPF, and is publicly
available on the Council’s website.

 

(6) What steps have the Pension Fund Committee and Board taken to address
the financial risks posed by climate change?

 

Please see publicly available reports and minutes of the Wirral Council
Pensions Committee (as the governing body of MPF) the cover the
development of MPF policies to address the financial risks posed by
climate change, here:

[4]http://democracy.wirral.gov.uk/ieListDoc...

 

and here,

 

[5]http://democracy.wirral.gov.uk/ieListDoc...

 

 

(7) Since the December 2015 Paris COP agreement, Peabody bankruptcy, and
Exxon Mobil downgrade, has the pension fund changed its approach to
climate change risks and investment in carbon stocks?

 

This is addressed in the public reports referred to in response to q(6).

 

(8) Please provide Pension Fund Committee and Board meeting minutes where
climate change, and carbon bubble investment risk was discussed, and
minuted 2014 - 2016.

 

I consider that the information you have requested is environmental
information under the Environmental Information Regulations 2004, (“EIR”).
Discussions about climate change, and carbon bubble investment risk,
concern the state of the elements of the environment, including air
(Regulation 2 (1) (a)). I consider that the exception contained in
Regulation 12 (5) (e) of the EIR applies to the information requested.
Regulation 12 (5)(e) provides that a public authority may refuse to
disclose information to the extent that its disclosure would adversely
affect the confidentiality of commercial or industrial information where
such confidentiality is provided by law to protect a legitimate economic
interest. I have had regard to the guidance issued by the Information
Commissioner’s Office: “Confidentiality of commercial or industrial
information” regulation 12 (5) (e)0,201205`6 : Version:1.2.

 

I consider that the requested information has the necessary quality of
confidence. The information is not trivial and is not in the public domain
having been considered in exempt session by the Pension Committee /Board.
The confidentiality is provided to protect legitimate economic interests,
namely, that of the Council and investment advisers to the Council, and
disclosure of the information to a member of the public would cause harm
both to the Council and to the advisers. I refer to paragraph 36 of the
ICO guidance:-

“ In addition to the duty to interpret exceptions restrictively, the
implementation guide for the Aarhus Convention (on which the European
Directive and ultimately the EIR were based) gives the following guidance
on legitimate economic interests: “Determine harm. Legitimate economic
interest also implies that the exception may be invoked only if disclosure
would significantly damage the interest in question and assist its
competitors”. I consider that disclosure of the requested information
would significantly damage the interests of the Council in its role as the
pensions authority and also those of the investment advisers providing
advice in confidence to the Council.

 

Public Interest Test

Factors in favour of disclosing the requested  information

o The public interest in disclosure to promote transparency and
accountability of public authorities
o That public money is being used effectively

Factors in favour of maintaining the exception

o Disclosure would undermine the relationship between the Council and
its investment advisers
o Disclosure would adversely affect the Council’s ability to obtain
confidential advice  and prejudice the commercial interests of both
the Council and its investment advisers
o Disclosure would affect the Council’s ability to seek advice in
future, if it were known, that that advice were to be disclosed to a
member of the public.

 

I am satisfied that the public interest in maintaining the exception
outweighs the public interest in disclosing the information.

 

 

(9) Have you surveyed or formally consulted with your individual members
or employers for their views on your ESG policies or practices in the last
10 years?

 

We have not surveyed or formally consulted with Scheme participants in the
manner suggested in the question. However, democratic accountability is
in-built in terms of MPF’s governance arrangements which, in addition to
cross-party representation by Wirral elected councillors (and councillor
representatives from the four other participating local authorities), is
inclusive of employer and member representation (including from the Trades
Unions and from Scheme pensioners).

 

(10) How much does the fund spend on ESG engagement services and can you
give any examples of engagement activities relating to climate
change/carbon risk from the last 10 years?

 

MPF conducts a good deal of its ESG engagement work on a collaborative
basis (principally, through membership of the LAPFF), with other
like-minded investors wherein it believes it can be most effective. A
non-exhaustive list of its membership participations (where often it
participates a leadership role) includes: IIGCC, PRI, LAPFF, UKSIF and
PLSA. The annual membership subscription costs of these organisations can
be found on their respective websites.

 

MPF currently works with PIRC Ltd, who is the Fund’s service provider for
voting and engagement services.  I consider that the exception contained
in Regulation 12 (5) (e) of the EIR also applies to the information
requested concerning how much the fund spends on ESG engagement services
and  that disclosure of the requested information would damage the
interests of the Council in its role as the pensions authority and those
of the service provider. I repeat the public interest arguments referred
to above.

 

Please visit the website of LAPFF for examples of engagement activity
relating to climate change/carbon risk that MPF has participated in,
including in recent times as a co-filer of the ‘Aiming for A’ shareholder
resolutions at, inter alia, BP, Shell, Glencore, Rio Tinto etc.

 

Conclusion

I refer to queries 3 and 4 in respect of which I am seeking further
clarification from you, having regard to the duty to advise and assist.

I  am also refusing  part of your request for information under Regulation
14 of the EIR, relying on the exception contained in Regulation 12 (5)
(e) of the EIR .You have the right to make representations under
Regulation 11 of the 2004 Regulations, which should be sent to Jane
Corrin, Records and Information Manager, Town Hall, Brighton Street,
Wallasey, CH44 8ED, email: [6][email address]. If you are
dissatisfied with this response to your request for information, you have
the right to complain to the Information Commissioner, but would normally
be expected to make representations before complaining to the
Commissioner.

The address is

The Information Commissioner’s Office,

Wycliffe House,

Water Lane,

Wilmslow,

Cheshire SK9 5AF

Tel -0303 123 113

[7]https://ico.org.uk/global/contact-us/

 

 

Yours sincerely,

 

Sent on behalf of

Rosemary Lyon,

Solicitor,

Business Services,

Law and Governance

Town Hall,

Brighton Street

Wallasey

Wirral

CH44 8ED

 

 

[8]LGC Awards15_Winner_MIP

 

This information supplied to you is copyrighted and continues to be
protected by the Copyright, Designs and Patents Act 1988.   You are free
to use it for your own purposes, including any non commercial research you
are doing and for the purposes of news reporting. Any other reuse, for
example commercial publication, would require our specific permission, may
involve licensing and the application of a charge

 

 

 

 

show quoted sections

References

Visible links
1. https://mpfmembers.org.uk/content/statem...
2. https://www.gov.uk/government/publicatio...
3. https://reporting.unpri.org/surveys/PRI-...
4. http://democracy.wirral.gov.uk/ieListDoc...
5. http://democracy.wirral.gov.uk/ieListDoc...
6. blocked::mailto:[email address] mailto:[email address]
mailto:[email address]
7. https://ico.org.uk/global/contact-us/

Dear Wirral Metropolitan Borough Council,

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

I am writing to request an internal review of Wirral Metropolitan Borough Council's handling of my FOI request 'Carbon Bubble Risk, Pension Fund Fiduciary Duty & Risks To Local Taxpayers Through LGPS Underfunding and Exposure to Investment Losses in Defined Benefit Schemes'.

Please conduct an internal review of Wirral Councils response to questions 3, 4 and 8

(3) Please provide current contract and procurement documents for the
Investment Adviser(s) to the Pension Fund Committee.

(4) Please provide current procurement and contract documentation for the
external fund manager(s) as set out in investment management agreements.

(8) Please provide Pension Fund Committee and Board meeting minutes where
climate change, and carbon bubble investment risk was discussed, and
minuted 2014 - 2016.

In its response, Council has implied that a request for contracts that underpin the investments of hundreds of millions of pounds of members funds, and associated taxpayer liabilities - "due to its size and scope" could be considered "vexatious" - yet as the council point, there is both a substantial public interest case in disclosing this information - and a general failure of public authorities such as Wirral to do so.

Council also suggests that obtaining the information could potentially breach the appropriate cost limits applicable under FOIA.

I confirm I wish council to proceed with its response to Questions 3 and 4, however I am happy to refine the request to include EU, US and UK equity mandate contract documentation only. As procurement framework and guidance information is publicly provided, I would have expect council to distinguish between the two items in its response.

With regard to question 8, this question has been asked primarily to determine if the LGPS fund has discharged its fiduciary duty vis a vis carbon/climate risk by a) meeting to discuss the issue, and b) agreeing a strategy to manage it.

By failing to disclose this information, citing spurious commercial sensitivity grounds, Council is shielding the LGPS fund from public scrutiny, that will help to ensure that taxpayer funds are spent prudently, and that taxpayers are not unduly exposed to additional costs, and financial risks, due to failure to adequately consider and plan for the costs and market risk associated with climate change.

If specific elements of the Committee meeting contain commercially sensitive information such as legal advice, council is free to redact those parts of the meeting considered to be commercially sensitive. Under ICO guidelines, such classification should not result in the blanket refusal of entire documents such as meeting minutes or notes, instead the authority should take a line by line approach to withholding or disclosing information.

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

InfoMgr, FinDMT, Wirral Metropolitan Borough Council

2 Attachments

Dear Mr Benjamin

 

I refer to your email of  23 January 2017 which sought the following
information in the form of an internal review of the Council’s response to
your original request, 'Carbon Bubble Risk, Pension Fund Fiduciary Duty &
Risks To Local Taxpayers Through LGPS Underfunding and Exposure to
Investment Losses in Defined Benefit Schemes'.

 

“Please conduct an internal review of Wirral Councils response to
questions 3, 4 and 8

 

(3) Please provide current contract and procurement documents for the
Investment Adviser(s) to the Pension Fund Committee.

(4) Please provide current procurement and contract documentation for the
external fund manager(s) as set out in investment management agreements.

(8) Please provide Pension Fund Committee and Board meeting minutes where
climate change, and carbon bubble investment risk was discussed, and
minuted 2014 - 2016.

 

In its response, Council has implied that a request for contracts that
underpin the investments of hundreds of millions of pounds of members
funds, and associated taxpayer liabilities - "due to its size and scope"
could be considered "vexatious" - yet as the council point, there is both
a substantial public interest case in disclosing this information - and a
general failure of public authorities such as Wirral to do so.

 

Council also suggests that obtaining  the information could potentially
breach the appropriate cost limits applicable under FOIA.

 

I confirm I wish council to proceed with its response to Questions 3 and
4, however I am happy to refine the request to include EU, US and UK
equity mandate contract documentation only. As procurement framework and
guidance information is publicly provided, I would have expect council to
distinguish between the two items in its response.

 

With regard to question 8, this question has been asked primarily to
determine if the LGPS fund has discharged its fiduciary duty vis a vis
carbon/climate risk by a) meeting to discuss the issue, and b) agreeing a
strategy to manage it.

 

By failing to disclose this information, citing spurious commercial
sensitivity grounds, Council is shielding the LGPS fund from public
scrutiny, that will help to ensure that taxpayer funds are spent
prudently, and that taxpayers are not unduly exposed to additional costs,
and financial risks, due to failure to adequately consider and plan for
the costs and market risk associated with climate change.

 

If specific elements of the Committee meeting contain commercially
sensitive information such as legal advice, council is free to redact
those parts of the meeting considered to be commercially sensitive. Under
ICO guidelines, such classification should not result in the blanket
refusal of entire documents such as meeting minutes or notes, instead  the
authority should take a line by line approach to withholding or disclosing
information.”

 

In response to your request for an internal review of the Council’s
handling of your Freedom of Information request, I can confirm that such a
review has now been undertaken by the Senior Investment Manager at
Merseyside Pension Fund and I apologise for the delay in responding.

 

The review finds that there were reasonable grounds, within the scope of
FOIA and related guidance, to deny parts of the earlier request relating
to commercially confidential information; but that, taking into account
the Council’s duty to provide reasonable assistance and the further
clarification of your request, it is possible to provide you with
additional information relevant to your inquiry. With particular reference
to questions 3, 4 and 8:

 

Q3. Investment Advisers:

The role that is stipulated for Merseyside Pension Fund’s Strategic
Investment Adviser (currently, Aon Hewitt), within the contracting
documents, is to be responsible for:

 

•             Providing advice on investment objectives, strategic asset
allocation, benchmark and risk budget (all such advice to be specifically
tailored to the needs of Merseyside Pension Fund and its funding and
investment strategy)

•             Performing Asset/Liability Modelling study following
triennial actuarial valuation

•             Delivering quarterly asset/liability analysis and strategy
‘health-check’ reports

•             Providing a strategic overview of the various asset classes

•             Ad hoc updates on significant market, economic and
regulatory issues

 

As part of the criteria we set to determine the suitability of bidders for
this contract, we weighted the evaluation criteria in favour of providers
who could evidence a comprehensive research process covering all
appropriate strategies and asset classes, inclusive of Responsible
Investment.

 

The Fund makes use of a separate Framework arrangement to access
specialist support for the selection and monitoring of investment
managers. Advisers on that Framework were appointed on the basis of having
demonstrated capability to support the Fund’s assessment of potential
investment managers’ (under consideration for UK & Overseas Equities and
Fixed Income mandates) capacity to work in furtherance of the Fund’s
stated Responsible Investment policies.

 

Q4. External Investment Managers:

Merseyside Pension Fund currently has nine external investment managers
across its UK & Overseas Equities mandates (inclusive of
EU/US/Japan/Asia-Pacific and Emerging Markets & listed in the Annual
Report & Accounts). All of those external investment managers were
appointed after formal consideration of their Responsible Investment
capabilities; & within the contracting documents are contained general
provisions that the mandates are carried out in line with the Fund’s
stated objectives and policies (as stated and as they may evolve). As
such, we are able to work with our external investment managers to support
the Fund’s Responsible Investment work as it adapts: at present, this
includes working with our equity managers to incorporate carbon
foot-printing into their risk reporting. We are examining options around
the design of investment mandates in listed equities that feature a
climate-related constraint that is in line with emerging decarbonisation
strategies.

 

Q8. Pension Committee Minutes

Minutes and papers of the Pension Committee are publicly available and
links to two items within the past 18 months that explicitly address
climate risk have been provided. The Pension Committee delegates detailed
consideration of investment matters to the Fund’s Investment Monitoring
Working Party (minutes of which are considered by Pension Committee, but
are exempt from publication). The IMWP meetings consider Responsible
Investment as a standing agenda item and, following Pension Committee’s
decision to seek the development of options on climate risk (including
decarbonisation plans) updates on progress are made to the IMWP under this
agenda item. While unable to provide you with a full copy of the IMWP
Minutes as reported to Pension Committee, we are mindful of your request
to verify that climate risk is being considered as part of the Fund’s
governance process and so have provided an IMWP agenda page (see
attached).

 

If you remain dissatisfied with the outcome of this internal review, you
have the right to complain directly to the Information Commissioner. The
Information Commissioner can be contacted at:

Information Commissioner’s Office,

Wycliffe House,

Water Lane,

Wilmslow,

Cheshire,

SK9 5AF.

 

[1]https://ico.org.uk/global/contact-us/

 

 

Yours sincerely

 

 

Lynette Paterson

Senior Information Management Officer

Business Services - Digital

 

Treasury Building

Cleveland Street
Birkenhead
Wirral
CH41 6BL

[2]Tel: 0151 691 8201

[3][Wirral Borough Council request email]

 

 

[4]LGC Awards15_Winner_MIP

 

 

This information supplied to you is copyrighted and continues to be
protected by the Copyright, Designs and Patents Act 1988.   You are free
to use it for your own purposes, including any non commercial research you
are doing and for the purposes of news reporting. Any other reuse, for
example commercial publication, would require our specific permission, may
involve licensing and the application of a charge

 

 

 

 

show quoted sections

References

Visible links
1. https://ico.org.uk/global/contact-us/
2. file:///tmp/Tel:0151
3. mailto:[Wirral Borough Council request email]

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