Correspondence with investment consultants & information on managing pension fund climate risk
Dear Flintshire County Council,
Please provide the following information in relation to Flintshire 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 (Flintshire 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 Flintshire 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
Good Morning,
Thank you for your recent request for information.
This request has been allocated reference number: F00021187
The Contact Officer for People & Resources will respond to your request in
line with the Freedom of Information Act 2000. We will respond to your
request as soon as possible and no later than 17/04/2023. In some cases,
however, we may be unable to achieve this deadline. If this occurs, we
will advise you of the likely timescale within which the response will be
provided. We will contact you as soon as possible should we need to
clarify your request.
Should you send any further correspondence about this request, please
include the reference number and either email it to [Flintshire County Council request email],
or post it to Freedom of Information, Flintshire County Council,
Information Governance, County Hall, Mold, Flintshire, CH7 6NB.
Kind regards
Contact Officer
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FOI Contact Officer
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FOI Contact Officer | Swyddog Cyswllt Rhyddid Gwybodaeth
Governance | Llywodraethu
Flintshire County Council | Cyngor Sir y Fflint
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Email | Ebost | [Flintshire County Council request email]
http://www.flintshire.gov.uk | http://www.siryfflint.gov.uk
http://www.twitter.com/flintshirecc | http://www.twitter.com/csyfflint
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Governance Manager, Information Governance Team, Flintshire County
Council, County Hall, Mold, Flintshire CH7 6NB, or
[email address].
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a progress report will be sent within the above timescales.
Requests for an internal review should be addressed to the Council’s
Information Governance Manager at:
Information Governance Team, County Hall, Mold, CH7 6NA
Or by emailing [Flintshire County Council request email]
Please remember to quote your original request’s reference number.
You also have the right to complain to the Information Commissioner. The
Information Commissioner can be contacted at the following address:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF
However, please note that the Commissioner will not normally investigate a
complaint until it has been through our own internal review process.
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fydd y gynulleidfa a fwriadwyd fel y gallwn ystyriwch eich cais. Dylid
anfon y wybodaeth hon at: Rheolwr Llywodraethu Gwybodaeth, Tîm
Llywodraethu Gwybodaeth, Neuadd Y Sir, Yr Wyddgrug, Sir Y Fflint, CH7 6NB,
neu drwy e-bostio [email address].
Os ydych yn anfodlon â’r modd y mae’r Cyngor wedi ymdrin eich cais am
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y Cyngor:
Team Llywodraethu Gwybodaeth, Neuadd y Sir, Yr Wyddgrug, Sir Y Fflint, CH7
6NB
Neu drwy e-bostio [Flintshire County Council request email]
Cofiwch ddyfynnu rhif cyfeirnod eich cais gwreiddiol.
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Cheshire, SK9 5AF
Fodd bynnag, dylech nodi nad yw’r Comisiynydd fel arfer yn ymchwilio i
gwyn nes ei fod wedi bod drwy ein proses adolygu fewnol.
══════════════════════════════════════════════════════════════════════════
Mr Benjamin
In response to your request
Dear Flintshire County Council,
Please provide the following information in relation to Flintshire
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
(Flintshire 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 Flintshire 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.
Response (for Q1)
We are unable
to provide a response to your request as the time required for officers to
locate, retrieve and extract the data from information held would exceed
the appropriate limit under Section 12 of the Freedom of Information Act
2000.
Question 1 of your request would take a considerable amount of officer
time as all the relevant staff would be required to manually search
through their emails and extract those that are relevant to the request.
We are therefore not obliged to provide a response your request as Section
12 of the Freedom of Information Act 2000 is engaged.
In response to the remaining requests I have attached publicly available
documentation used in the production of our first TCFD report to March
2022 which details background data and next steps for the Fund.
Section 17 of the Freedom of Information Act 2000 requires Flintshire
County Council, when refusing to provide such information (because the
information is exempt) to provide you the applicant with a notice
which:
(a) states that fact;
(b) specifies the exemption in question and
(c) states (if that would not otherwise be apparent) why the exemption
applies.
In this instance the relevant exemption is Section 12 of the Freedom of
Information Act. Section 12 of the Freedom of Information Act 2000 makes
provision for public authorities to refuse requests for information where
the cost of dealing with them would exceed the appropriate limit, as
detailed in the Freedom of Information (Fees and Appropriate limit)
Regulations 2004.
The limit for public authorities is set at £450 which amounts to a maximum
of 18 hours of search and retrieval time charged at £25.00 per person per
hour.
The Regulations set out what may be taken into account when public
authorities are estimating whether the appropriate limit has been
exceeded. The costs are limited to those that an authority reasonably
expects to incur in:
· determining whether it holds the information requested
· locating the information or documents containing the information
· retrieving such information or documents
· extracting the information from the document containing it (including
editing or reformatting information)
We believe that this request is now complete. Should any further
information be required regarding this topic, a separate request will need
to be submitted.
If you are dissatisfied with the Council’s handling of your request for
information, you can ask for an internal review within 2 months of the
date of this response. Where your complaint is a complex one it may not be
possible to deal with it within the above timescales. In such a situation
a progress report will be sent within the above timescales.
Requests for an internal review should be addressed to the Council’s
Information Governance Manager at:
Information Governance Team,
County Hall,
Mold,
CH7 6NA
Or by emailing [1][Flintshire County Council request email]
Please remember to quote your original request’s reference number.
You also have the right to complain to the Information Commissioner. The
Information Commissioner can be contacted at the following address:
Information Commissioner’s Office,
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF.
However, please note that the Commissioner will not normally investigate a
complaint until it has been through our own internal review process
Debbie Fielder
____________________________________________________________________________________
Deputy Head | Dirprwy Bennaeth
Clwyd Pension Fund | Cronfa Bensiynau Clwyd
People and Resources | Pobl ac Adnoddau
Flintshire County Council | Cyngor Sir y Fflint
____________________________________________________________________________________
English | Saesneg | 01352 702259
Welsh | Cymraeg | 01267 224923
Mobile | Ffon Symudol | 07388009225
Email | Ebost | [2][email address] /
[3][email address]
Dear Flintshire County Council,
Please pass this on to the person who conducts Freedom of Information reviews.
I am writing to request an internal review of Flintshire County Council's handling of my FOI request 'Correspondence with investment consultants & information on managing pension fund climate risk'.
This request is focussed on the communications of small number of senior public officials and council officers - with no realistic expectation of privacy, when conducting council affairs - using a small number of discreet search terms. As such, I believe the councils time estimates to obtain relevant emails within the scope of this request represent a gross over-exaggeration of the actual time required to conduct a key word search for information shared to and from a select group of external consultant firms (Mercer) - using the search terms "Climate risk" and "climate risk analysis"
I further remind you that ICO guidance is clear that redaction time does not count towards the cost limit.
Should Flintshire need to limit the number of email inbox key word searches ("climate risk"/"climate scenario analysis") to fit this request with applicable cost/time limits, please focus search time on the: (in order of preference, should you have to exclude any based on time/cost):
- Head of Finance
- Chair of Pensions Fund
- Director of Finance
- Head of Procurement
- Wider Pension Fund Committee
- Chief Legal Advisor
Additionally, I am also happy to reduce the applicable search window from 2020 - 2023.
Furthermore it is likely that consultants such as Mercer providing the council information may claim release of the requested information could be prejudicial to commercial interests of the council or the person/consultants supplying it.
As 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)".
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 Flintshire 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 Flintshire to the consultant(s), therefore any attempt to hide behind commercial sensitivity claims could be viewed as a convenient vehicle by which Flintshire could shield the assumptions it makes about the future impacts of climate change on future fund returns from effective public & LGPS member scrutiny.
Release of climate risk information would likely benefit both LGPS scheme members, and local taxpayers, by providing reassurance that the scheme is actively managing climate risks, whilst attempting to lower the funds climate impact.
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 morning,
Thank you for your email regarding an internal review of your Freedom of
Information Request F00021187. Your request has been assigned to the
complaints officer for Governance. with ref number 941.
Should you send any further correspondence about this request, please
include the reference number and either email it to [Flintshire County Council request email],
or post it to Freedom of Information, Flintshire County Council,
Information Governance, County Hall, Mold, Flintshire, CH7 6NB.
Cofion / Regards,
FOI Contact Officer
FOI Contact Officer | Swyddog Cyswllt Rhyddid Gwybodaeth Governance |
Llywodraethu Flintshire County Council | Cyngor Sir y Fflint
Dear Mr Benjamin
I write to you with an update in regards to the internal review you have requested of your recent Freedom of Information Request (F00021187) which has been allocated complaint reference 941.
We are currently in the process of obtaining copies of emails which are relevant to your narrowed search criteria. These emails will then be reviewed by the relevant contact officer.
Your ongoing patience on the matter is much appreciated.
Kind regards,
Leah
____________________________________________________________________________________
Swyddog Cydymffurfiaeth Gwybodaeth | Information Compliance Officer
Gwasanaethau Busnes a Gwybodaeth | Information & Business Services
Llywodraethu | Governance
Cyngor Sir y Fflint | Flintshire County Council
____________________________________________________________________________________
Ffôn | Tel:
English/Saesneg: 01352 702800
Cymraeg/Welsh: 01267 224923
Ebost | Email:
[email address] / [email address]
____________________________________________________________________________________
http://www.flintshire.gov.uk | http://www.siryfflint.gov.uk
http://www.twitter.com/flintshirecc | http://www.twitter.com/csyfflint
______________________________________________________________________________________________________________________________
Log and track your Council enquiries through ‘My Account’ - go to www.flintshire.gov.uk/My-Account for more information and to register.
Cofnodi a thracio eich ymholiadau i’r Cyngor drwy ‘Fy Nghyfrif’ - ymwelwch â www.siryfflint.gov.uk/fy-nghyfrif am ragor o wybodaeth neu os hoffech chi gofrestru.
Dear Mr Benjamin
Further to your Freedom of Information request F21187 and subsequent
request for internal review, I have now concluded my review and my
findings are set out below.
Your request was refused under s12 of the Freedom of Information Act as it
had been determined that the cost of complying with the request would
exceed the appropriate limit for a local authority of £450. This amount
equates to 18 hours of officer time in determining whether the information
is held; locating, retrieving and extracting the information.
You requested emails & correspondence between council employees
(Flintshire 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. An email search was conducted which produced over 2000 pieces of
correspondence.
To review this amount of correspondence to determine if it contained
recorded information on climate risk (rather than merely mentioning it)
and to subsequently extract the relevant information would take in excess
of 18 hours at a conservative estimate of a review of three minutes per
email.
I agree that the s12 exemption has been correctly engaged with regard Q1
of your request. I note relevant documentation has been provided to assist
you with this request.
Your complaint is therefore not upheld.
You have provided a reduced list of officers to review correspondence.
Emails have been extracted and reviewed for recorded information on
climate risk/climate scenario analysis. I can confirm the review has not
produced any emails between the officers listed and the Council’s external
investment consultants relating to this information. This information is
therefore not held.
This concludes the Council’s internal review process and you should now
contact the Information Commissioner’s Office if you remain dissatisfied
and would like a further review to be conducted. Further details can be
found on their website. [1]https://ico.org.uk/make-a-complaint/
Best regards
Deborah
Deborah Sainsbury
____________________________________________________________________________________
Swyddog Diogelu Data|Data Protection Officer
Llywodraethu|Governance
Cyngor Sir y Fflint|Flintshire County Council
____________________________________________________________________________________
Ffôn |Tel :
English / Saesneg : 01352 702178
Cymraeg / Welsh : 01267 224923
Ebost | Email [2][email address]
|[email address]
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