Correspondence with investment consultants & information on managing pension fund climate risk
Dear Gloucestershire County Council,
Please provide the following information in relation to Gloucestershire 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 (Gloucestershire 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 Gloucestershire 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
Information request
Our reference: 28508165
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Dear Joel Benjamin
Request for Information (Reference: 28508165 )
Thank you for your request for information, received on 22 March 2023.
Request summary: Please provide the following information in relation to
Gloucestershire 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 (Gloucestershire 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 Gloucestershire 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.
We aim to respond to your request no later than midnight on 21 April
2023 (the statutory timescale of 20 working days, starting on the working
day following receipt of your request). We may need to contact you if the
request needs to be clarified; this is to ensure we provide you with the
information you require.
If the information you have requested is held by another public authority,
we will inform you of this so that you can contact them directly.
Gloucestershire County Council is committed to the principles of
information disclosure and will, wherever possible, provide all
information requested. However, some information you have requested may
not be provided to you; this will only be information that can be withheld
by law, and, in most cases, the reason will be explained to you when we
send out any information that can be released. We will also inform you as
soon as possible if we do not hold the information you have requested.
You may find answers to your questions on our frequently asked questions
page -
[1]https://www.gloucestershire.gov.uk/counc...
Our response to your request may be published in our disclosure log, with
your personal details removed. Our new disclosure log can be found on our
website at: [2]www.gloucestershire.gov.uk/foi. In future, you may find
that the answer to your questions about the Council has already been
published.
Yours faithfully
Nicole Barrow
Information Requests Officer
Information Management Service
01452 324000
References
Visible links
1. https://www.gloucestershire.gov.uk/counc...
2. http://www.gloucestershire.gov.uk/foi
Information request
Our reference: 28508165
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Dear Joel Benjamin
Thank you for your request for information received on 22 March 2023 .
Please find attached our response to your request.
Yours faithfully
Carly Doyle
Information Requests Officer | BCS FOI Practitioner
Information Management Service
[1][email address]
NOTE: Please do not edit the subject line when replying to this email.
References
Visible links
1. mailto:[email address]
Dear Gloucestershire County Council,
Please pass this on to the person who conducts Freedom of Information reviews.
I am writing to request an internal review of Gloucestershire County Council's handling of my FOI request 'Correspondence with investment consultants & information on managing pension fund climate risk'.
The request is focussed on a 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 search for information shared to and from a select group of consultant firms - 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 Gloucestershire 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 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 Gloucestershire 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 Gloucestershire to the consultant(s), therefore any attempt to hide behind commercial sensitivity claims could be viewed as a convenient vehicle by which Gloucestershire 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
Information request
Our reference: 28717919
══════════════════════════════════════════════════════════════════════════
Dear Joel Benjamin
Request for Information (Reference: 28717919 )
Thank you for your request for information, received on 6 April 2023.
After reviewing the details of your request, as you have provided
additional clarification and guidance on limiting your request to assist
with enabling a response, this has been considered as a new request under
the Freedom of Information Act.
You have provided clarity on your request as follows:
"Correspondence with investment consultants & information on managing
pension fund climate risk
Should Gloucestershire 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."
We aim to respond to your request no later than midnight on 10 May
2023 (the statutory timescale of 20 working days, starting on the working
day following receipt of your request). We may need to contact you if the
request needs to be clarified; this is to ensure we provide you with the
information you require.
If the information you have requested is held by another public authority,
we will inform you of this so that you can contact them directly.
Gloucestershire County Council is committed to the principles of
information disclosure and will, wherever possible, provide all
information requested. However, some information you have requested may
not be provided to you; this will only be information that can be withheld
by law, and, in most cases, the reason will be explained to you when we
send out any information that can be released. We will also inform you as
soon as possible if we do not hold the information you have requested.
You may find answers to your questions on our frequently asked questions
page -
[1]https://www.gloucestershire.gov.uk/counc...
Our response to your request may be published in our disclosure log, with
your personal details removed. Our new disclosure log can be found on our
website at: [2]www.gloucestershire.gov.uk/foi. In future, you may find
that the answer to your questions about the Council has already been
published.
Yours sincerely,
Nicki Ball
Information Requests Officer
Information Management Service
[3][email address]
01452 324000
References
Visible links
1. https://www.gloucestershire.gov.uk/counc...
2. http://www.gloucestershire.gov.uk/foi
3. mailto:[email address]
Information request
Our reference: 28717919
══════════════════════════════════════════════════════════════════════════
Dear Requestor,
Freedom of Information Act 2000
Thank you for your request received on 6 April 2023 concerning '
Correspondence with investment consultants & information on managing
pension fund climate risk.
Should Gloucestershire 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. .
We are now considering the request but we need more time to process it.
This is because we need to undertake a public interest test . We will now
try to respond to you by 23 May 2023 .
Yours faithfully
Information Requests Officer
Information Management Service - [email address]
01452 324000
Information request
Our reference: 28717919
══════════════════════════════════════════════════════════════════════════
Dear Joel Benjamin
Thank you for your request for information received on 6 April 2023 .
We have performed further searches and after re assessing the information
refined to your second request, we have determined we do not hold the
relevant information.
Please find attached our response to your request.
Yours faithfully
Information Requests Officer
Information Management Service - [email address]
01452 324000
NOTE: Please do not edit the subject line when replying to this email.
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