Correspondence with investment consultants & information on managing pension fund climate risk
Dear Essex County Council,
Please provide the following information in relation to Essex 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 (Essex 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 Essex 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
Dear Sir/Madam,
Thank you for your request for information which we will handle under the
Freedom of Information Act 2000.
The Act allows us up to 20 working days (excluding statutory holidays) to
process a valid request for information.
We may be in touch with you should we require any further clarification.
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address is [1]https://secureapps.essex.gov.uk/Freedom_...
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Kind regards
Trevor Anthony-Jones
Information Governance Officer
Your Right To Know
External IG Team
Democracy and Transparency
Corporate and Customer Services
Essex County Council
T: 03330 138989
E: [2][email address]
W: [3]www.essex.gov.uk
Dear Sir/Madam,
Thank you for your request for information. Please find our response to
your request on the accompanying document(s).
I trust that this information satisfies your request. However, should you
require anything further, please contact me and I will endeavour to assist
you further.
if you are not satisfied with your response, please contact me so I can
try to resolve the issue. Alternatively, if you wish to make a complaint,
you can find the details at
[1]https://www.essex.gov.uk/Your-Council/Yo...
If, after following our complaints procedure, you are still not satisfied,
you are entitled to ask the Information Commissioner to review our
decision. You can contact the Information Commissioner at Wycliffe House,
Water Lane, Wilmslow, Cheshire, SK9 5AF; Telephone 0303 123 1113.
Please note that the response and data released to you as part of this
request will be published on the Essex County Council website. The website
address is
[2]https://www.essex.gov.uk/Your-Council/Yo....
All requests will be anonymised and no personal information including
contact details will be disclosed as part of this process.
If you would like to take a short customer satisfaction survey please use
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[3]https://consultations.essex.gov.uk/infor...
Kind Regards
Daniel Cuthbert
Your Right To Know
External IG Team
Democracy and Transparency
Corporate and Customer Services
Essex County Council
T: 03330 134925
E: [4][email address]
W: [5]www.essex.gov.uk
References
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1. https://www.essex.gov.uk/Your-Council/Yo...
2. https://www.essex.gov.uk/Your-Council/Yo...
3. https://consultations.essex.gov.uk/infor...
4. mailto:[email address]
5. http://www.essex.gov.uk/
Dear Essex County Council,
Please pass this on to the person who conducts Freedom of Information reviews.
I am writing to request an internal review of Essex County Council's handling of my FOI request 'Correspondence with investment consultants & information on managing pension fund climate risk'.
Given you cite "commercial sensitivity" concerns on the part of investment consultant Hymans Robertson providing the council with information & advice - 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)"
It is is not explained sufficiently how the accessing communications & documents providing climate risk/ climate scenario analysis constitutes a real commercial risk?
These firms provide scenario modelling & climate risk advice, and therefore, the counterfactual argument is that if their advice is sound, and more widely known, both brand recognition & demand for their services will likely increase. However, competition between firms issuing climate related advice in the absence of regulatory oversight or public scrutiny could likely result in a race to the bottom on standards.
All information within the scope of the request should not be automatically granted the same commercial sensitivity rating, without first considering the risks and benefits of disclosure specific to the information. General email conversations around climate risk management & scenario analysis are unlikely to contain the same extent of intellectual property you suggest as detailed reports or economic models.
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 Essex 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 Essex 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 seen 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, 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 DB 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.
Finally, should you need further assistance in narrowing the search - may I suggest the following:
1) reduce the 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.
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
Good afternoon,
Could you give me the case reference number that applies to the case you want to ask for an Internal Review for please, it usually starts with ECC.
Yours sincerely,
Naomi Hinder
Your Right To Know
Essex County Council
T: 033301 38989
E: [email address]
W: http://www.essex.gov.uk/
Please consider the environment before printing this e-mail
Dear Your Right To Know,
The ref number on your earlier letter is ECC144 65521 03 23
Yours sincerely,
Joel M Benjamin
Good Afternoon,
Your Internal Review Request: ECC14662024 04 23
Thank you for your request to review our handling of your recent request for information reference ECC14465521 03 23, received by us on 21/03/2023.
We will review the handling of your request and respond with our formal decision on the aspects you have asked us to consider within 20 working days.
Please contact me if you would like further advice or assistance about your request, review or your right to access information held by us.
Kind regards,
Information Governance Assistant
Your Right To Know
Essex County Council
Telephone: 033301 38989
E-mail: [email address]
W: http://www.essex.gov.uk/
Good afternoon,
Thank you for your request for an Internal Review. Please find our
response to your request on the accompanying document(s).
If you are not satisfied with this response and wish to make a complaint,
you can find the details at
[1]http://www.essex.gov.uk/customer-service...
If, after following our complaints procedure, you are still not satisfied,
you are entitled to ask the Information Commissioner to review our
decision. You can contact the Information Commissioner at Wycliffe House,
Water Lane, Wilmslow, Cheshire, SK9 5AF; Telephone 0303 123 1113.
Yours sincerely,
Information Governance Assistant
Your Right To Know
Essex County Council
Telephone: 033301 38989
E-mail: [2][email address]
W: [3]www.essex.gov.uk
References
Visible links
1. http://www.essex.gov.uk/customer-service...
2. mailto:[email address]
3. http://www.essex.gov.uk/
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