Correspondence with investment consultants & information on managing pension fund climate risk
Dear Greenwich Borough Council,
Please provide the following information in relation to Greenwich 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 (Greenwich 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 Greenwich 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 Mr Benjamin
Freedom of Information request: FOI-72330
Thank you for your request dated 20 March 2023
Your request will be answered by 19 April 2023.
If you have any queries about this request, please contact me, quoting the
reference number above.
Yours sincerely,
David White
Head of Information, Safety and Community Services
Directorate of Communities, Environment and Central
Royal Borough of Greenwich
* 3^rd Floor, The Woolwich Centre, 35 Wellington Street, London, SE18
6HQ
8 [1]www.royalgreenwich.gov.uk
ü Please consider the environment before printing this email
Dear Mr Benjamin
Freedom of Information request: FOI-72330
We apologise for the delay in providing the response to your Freedom of
Information request. We do remain committed to responding to your request
and will respond as soon as we are able to do so.
Yours sincerely,
Freedom of Information Officer
Information, Safety and Community Services
Directorate of Communities, Environment and Central
Royal Borough of Greenwich
* The Woolwich Centre, 35 Wellington Street, London SE18 6HQ
8 [1]www.royalgreenwich.gov.uk
ü Please consider the environment before printing this email
From: foi <[Greenwich Borough Council request email]>
Sent: 21 March 2023 09:54
To: 'Joel M Benjamin' <[FOI #962228 email]>
Cc: foi <[Greenwich Borough Council request email]>
Subject: FOI-72330: Freedom of Information request - Correspondence with
investment consultants & information on managing pension fund climate risk
Dear Mr Benjamin
Freedom of Information request: FOI-72330
Thank you for your request dated 20 March 2023
Your request will be answered by 19 April 2023.
If you have any queries about this request, please contact me, quoting the
reference number above.
Yours sincerely,
David White
Head of Information, Safety and Community Services
Directorate of Communities, Environment and Central
Royal Borough of Greenwich
* 3^rd Floor, The Woolwich Centre, 35 Wellington Street, London, SE18
6HQ
8 [2]www.royalgreenwich.gov.uk
ü Please consider the environment before printing this email
Dear Mr Benjamin
Freedom of Information request: FOI-72330
Thank you for your request dated 20 March 2023.
Our response is as follows:
1) Please provide emails & correspondence between council employees
(Greenwich 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
The requested information you have requested is exempt under section 43(2)
of the Freedom of Information Act 2000 which states:
Information is exempt information if its disclosure under this Act would,
or would be likely to, prejudice the commercial interests of any person
(including the public authority holding it).
The information requested is commercially sensitive and would prejudice
the investment consultants commercial interests if we placed the requested
information in the public domain.
The Council’s rationale for this is that the information requested
contains our investment consultants intellectual property and trade
secrets. These have great commercial value and their disclosure into the
public domain would cause them significant harm. As a Council, we take
measures to prevent the dissemination of this information publicly, as it
would be advantageous to their competitors and has the ability to affect
the profitability of the services they offer to their clients.
The requested information requested is commercially sensitive as it is
tailored to our investment consultants clients and their individual
circumstances and needs. If this advice is provided out of context as part
of the request, there is a real concern that individuals and/or third
parties could rely on this advice inappropriately which in turn could
cause them financial loss. Our investment consultants have a legitimate
interest in seeking to control their risk to exposure to claims from
parties who are not their client, and do not want to be in a position
where individuals or third parties believe it is appropriate to rely on
their advice without a full understanding of the circumstances surrounding
it. They also appropriately caveat their advice when it is provided to
clients, and they are not able to appropriately do this if advice is
released into the public domain.
In addition, when providing advice for their clients, our investment
consultants often rely on confidential information provided from third
party sources. As a result, the information may contain confidential
information belonging to third parties, the disclosure of which may be
actionable by those third parties.
The Council has considered the public interest test in favour of
disclosing this information and they are:
The Council considers it should be open and transparent in its
decision-making process.
The Council has considered the public interest test in favour of not
disclosing the requested information. This information is tailored by our
investment consultants to our individual circumstances and needs and
should not be placed in the public domain.
Having considered the public interest test the Council has decided to
withhold the information in accordance with section 43 (2) of the Freedom
of Information Act 2000.
2) Please confirm if specific advice or information on climate risk has
been sought by Greenwich 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")
The fund worked with its investment consultant to develop its net zero
roadmap ([1]here)
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?
Please see our carbon reporting [2]here
ii) Projected gains or losses for the portfolio &/or GDP activity for each
scenario/year assessed
This data is not available as this exercise has not been carried out.
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.
The requested information you have requested is exempt under section 43(2)
of the Freedom of Information Act 2000 which states:
Information is exempt information if its disclosure under this Act would,
or would be likely to, prejudice the commercial interests of any person
(including the public authority holding it).
The information requested is commercially sensitive and would prejudice
the investment consultants commercial interests if we placed the requested
information in the public domain.
The Council’s rationale for this is that the information requested
contains our investment consultants intellectual property and trade
secrets. These have great commercial value and their disclosure into the
public domain would cause them significant harm. As a Council, we take
measures to prevent the dissemination of this information publicly, as it
would be advantageous to their competitors and has the ability to affect
the profitability of the services they offer to their clients.
The requested information requested is commercially sensitive as it is
tailored to our investment consultants clients and their individual
circumstances and needs. If this advice is provided out of context as part
of the request, there is a real concern that individuals and/or third
parties could rely on this advice inappropriately which in turn could
cause them financial loss. The Investment Consultants have a legitimate
interest in seeking to control their risk to exposure to claims from
parties who are not their client, and do not want to be in a position
where individuals or third parties believe it is appropriate to rely on
their advice without a full understanding of the circumstances surrounding
it. They also appropriately caveat their advice when it is provided to
clients, and they are not able to appropriately do this if advice is
released into the public domain.
In addition, when providing advice for their clients, our investment
consultants often rely on confidential information provided from third
party sources. As a result, the information may contain confidential
information belonging to third parties, the disclosure of which may be
actionable by those third parties.
The Council has considered the public interest test in favour of
disclosing this information and they are:
The Council considers it should be open and transparent in its
decision-making process.
The Council has considered the public interest test in favour of not
disclosing the requested information. This information is tailored by our
investment consultants to our individual circumstances and needs and
should not be placed in the public domain.
Having considered the public interest test the Council has decided to
withhold the information in accordance with section 43 (2) of the Freedom
of Information Act 2000.
However, please see our net zero roadmap [3]here
If you have any queries about this correspondence, please contact me,
quoting the reference number above.
If you are not satisfied with our response to your request, you can ask
for an Internal Review. Internal review requests must be submitted within
two months of the date of receipt of the response to your original
request. If you wish to do this, please contact us in writing, setting
out why you are dissatisfied.
If you are not satisfied with the outcome of the Internal Review, you may
apply directly to the Information Commissioner (ICO) for a decision.
Generally, the ICO cannot make a decision unless you have exhausted the
Internal Review procedure provided by the Council. You can contact the ICO
by emailing [4][email address], or by post at Customer Contact,
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
SK9 5AF.
Yours sincerely,
David White
Head of Information, Safety and Community Services
Directorate of Communities, Environment and Central
Royal Borough of Greenwich
* 3^rd Floor, The Woolwich Centre, 35 Wellington Street, London, SE18
6HQ
8 [5]www.royalgreenwich.gov.uk
ü Please consider the environment before printing this email
From: foi <[Greenwich Borough Council request email]>
Sent: 20 April 2023 13:08
To: 'Joel M Benjamin' <[FOI #962228 email]>
Cc: foi <[Greenwich Borough Council request email]>
Subject: FOI-72330: Freedom of Information request - Correspondence with
investment consultants & information on managing pension fund climate risk
Dear Mr Benjamin
Freedom of Information request: FOI-72330
We apologise for the delay in providing the response to your Freedom of
Information request. We do remain committed to responding to your request
and will respond as soon as we are able to do so.
Yours sincerely,
Freedom of Information Officer
Information, Safety and Community Services
Directorate of Communities, Environment and Central
Royal Borough of Greenwich
* The Woolwich Centre, 35 Wellington Street, London SE18 6HQ
8 [6]www.royalgreenwich.gov.uk
ü Please consider the environment before printing this email
From: foi <[7][Greenwich Borough Council request email]>
Sent: 21 March 2023 09:54
To: 'Joel M Benjamin' <[8][FOI #962228 email]>
Cc: foi <[9][Greenwich Borough Council request email]>
Subject: FOI-72330: Freedom of Information request - Correspondence with
investment consultants & information on managing pension fund climate risk
Dear Mr Benjamin
Freedom of Information request: FOI-72330
Thank you for your request dated 20 March 2023
Your request will be answered by 19 April 2023.
If you have any queries about this request, please contact me, quoting the
reference number above.
Yours sincerely,
David White
Head of Information, Safety and Community Services
Directorate of Communities, Environment and Central
Royal Borough of Greenwich
* 3^rd Floor, The Woolwich Centre, 35 Wellington Street, London, SE18
6HQ
8 [10]www.royalgreenwich.gov.uk
ü Please consider the environment before printing this email
Dear Greenwich Borough Council,
Please pass this on to the person who conducts Freedom of Information reviews.
I am writing to request an internal review of Greenwich Borough 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 consultants - 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 not explained sufficiently how accessing communications & documents providing climate risk/ climate scenario analysis constitutes a real commercial risk to the firm?
These firms provide scenario modelling & climate risk advice, and therefore, the counterfactual argument is that if their advice is sound, and more widely circulated, both brand recognition & demand for their services will likely increase. It should also be noted that competition between firms issuing advice in the absence of regulatory oversight or public scrutiny could 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 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 Greenwich 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 Greenwich 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.
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
Dear Mr Benjamin
Freedom of Information request Internal Review: FOI-IR-72330
Thank you for your request for an Internal Review regarding our response
to your Freedom of Information request.
Your request is being dealt with under the terms of the Freedom of
Information Act 2000 and will be answered within twenty working days.
If you have any queries, please contact me, quoting the reference number.
If you are not content with the outcome of the Internal Review, you can
apply directly to the Information Commissioner (ICO) for a decision.
Generally, the ICO cannot make a decision unless you have exhausted the
Internal Review procedure provided by the Council. The Information
Commissioner can be contacted at: The Information Commissioner’s Office,
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Yours sincerely,
David White
Head of Information, Safety and Community Services
Directorate of Communities, Environment and Central
Royal Borough of Greenwich
* 3^rd Floor, The Woolwich Centre, 35 Wellington Street, London, SE18
6HQ
8 [1]www.royalgreenwich.gov.uk
ü Please consider the environment before printing this email
Dear Mr Benjamin
Freedom of Information request Internal Review: FOI-IR-72330
Thank you for your Internal Review request on the handling of your Freedom
of Information request. Please find the outcome attached.
If you are not content with the outcome of the Internal Review, you may
apply directly to the Information Commissioner (ICO) for a decision.
Generally, the ICO cannot make a decision unless you have exhausted the
Internal Review procedure provided by the Council. The Information
Commissioner can be contacted at: The Information Commissioner’s Office,
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Yours sincerely,
David White
Head of Information, Safety and Community Services
Directorate of Communities, Environment & Central
Royal Borough of Greenwich
* 3^rd Floor, The Woolwich Centre, 35 Wellington Street, London, SE18
6HQ
8[1]www.royalgreenwich.gov.uk
ü Please consider the environment before printing this email
From: foi <[Greenwich Borough Council request email]>
Sent: 24 April 2023 14:41
To: 'Joel M Benjamin' <[FOI #962228 email]>
Cc: foi <[Greenwich Borough Council request email]>
Subject: FOI/IR-72330: Internal review of Freedom of Information request -
Correspondence with investment consultants & information on managing
pension fund climate risk
Dear Mr Benjamin
Freedom of Information request Internal Review: FOI-IR-72330
Thank you for your request for an Internal Review regarding our response
to your Freedom of Information request.
Your request is being dealt with under the terms of the Freedom of
Information Act 2000 and will be answered within twenty working days.
If you have any queries, please contact me, quoting the reference number.
If you are not content with the outcome of the Internal Review, you can
apply directly to the Information Commissioner (ICO) for a decision.
Generally, the ICO cannot make a decision unless you have exhausted the
Internal Review procedure provided by the Council. The Information
Commissioner can be contacted at: The Information Commissioner’s Office,
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Yours sincerely,
David White
Head of Information, Safety and Community Services
Directorate of Communities, Environment and Central
Royal Borough of Greenwich
* 3^rd Floor, The Woolwich Centre, 35 Wellington Street, London, SE18
6HQ
8 [2]www.royalgreenwich.gov.uk
ü Please consider the environment before printing this email
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