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London Pensions Fund Authority Pension Fund Investments

Edward Jones made this Freedom of Information request to London Pensions Fund Authority Automatic anti-spam measures are in place for this older request. Please let us know if a further response is expected or if you are having trouble responding.

We're waiting for Edward Jones to read recent responses and update the status.

Dear London Pensions Fund Authority,

I am researching the fossil fuel investments made by UK Local Government Pension Schemes (LGPS) for an upcoming report by UK Divest. On publication, the report is likely to receive substantial interest from press and the elected representatives sitting on pension fund committees across the UK. Therefore can you please ensure the investment data you provide is as accurate as possible as our analysis will be fundamentally informed by it.

To complete this research, I require data on each investment that was held by London Pensions Fund Authority Pension Fund on 31 March 2022, or the nearest possible date:

1. Investment names. Please provide the names of all investments held by the pension fund. For direct investments, please provide the names of individual investments such as specific stocks, bonds, and real estate units. For indirect investments (i.e. those held via a third party), please provide the names of investment vehicles, such as specific mutual funds, exchange traded funds (ETFs) and real estate investment trusts (REITs) and anything else. Note we do not need to know what each indirect investment vehicle invests in as we will determine this in the data analysis.

2. Investment identifiers. For listed investments (i.e. those traded on public exchanges), such as bonds and equities, please provide the International Securities Identifier Number (ISIN). For any investments that do not have an ISIN number, such as some alternative assets, please provide the Legal Entity Identifier (LEI). If an investment does not have an identifier, please provide an explanation.

3. Asset types. The asset type for each investment as reported by the pension fund, such as: real estate, cash, private equity, listed equity, sovereign bonds, corporate bonds etc.

4. Investment managers. The name of the entity which is responsible for the day-to-day management of each investment. For example, this could be the name of the entity which manages a specific investment fund such as Baillie Gifford, Legal & General, UBS etc. Note we do not need to know who is responsible for the overall governance of the LGPS or any pools it might belong to.

5. Investment values. The market value of each investment in pounds sterling (£) on 31 March 2022 or the nearest possible date. And please also give the total value of the pension fund.

We have created a read-only Google Sheet as a template for how we would like the data presented when you answer this request. You can view and download it here: https://docs.google.com/spreadsheets/d/1...

If possible, please use this Google Sheet when answering. Please note there are two tabs - 'summary' and 'data'. Please fill in both tabs. Using the template would help us accurately analyse the data provided.

If you respond promptly and to a satisfactory standard, we will willingly share our analysis with you prior to publication of our report, so you have the chance to comment and benchmark your pension fund against other UK LGPS.

I would like to receive this information in unlocked excel sheets without protected cells (.xls). If you have to password protect the excel sheets, please also provide the password to them. When considering the request for this data in excel format, please refer to Innes v Information Commissioner [2014] EWCA Civ 1086 (i), which allows a requester to express a preference for communication by a particular means, specifically: "an applicant's right to choose to have information provided to him in electronic form extends to a right to choose the software format in which it is embodied." (ii)

Please note:

Many public authorities release their contracts, minutes, and other information of interactions with private vendors in line with the Freedom of Information Act. The exemption for commercial interest under the Act (section 43) is a qualified exemption, which means information can only be withheld if it is in the public's interest. The public have an interest in knowing what the Pension Fund is investing in, the terms of contracts and the minutes of meeting with public authorities, whether or not public money changes hands immediately.

If you are relying on section 41 (the exemption for legal breach of confidence) then I would like to know the following:

* When these confidentiality agreements were agreed
* All correspondence and email in which these confidentiality agreements were discussed
* The precise wording of the confidentiality agreements.

I ask these questions because guidance issued by both the Lord Chancellor (draft guidance on FOI implementation) and the Office of Government Commerce (Model terms and conditions for goods and services) specifically state that public authorities should not enter into these types of agreements; they go directly against the spirit of the laws of disclosure. I would also point to the Information Commissioner's guidance on accepting blanket commercial confidentiality agreements: 'Unless confidentiality clauses are necessary or reasonable, there is a real risk that, in the event of a complaint, the Commissioner would order disclosure in any case.' (iii)

Finally, within the law of confidence there is also a public interest test. Therefore, the information should be disclosed in full. If any parts are redacted, they must be for information that can be proven to be a legal breach of confidence in court, and only then where secrecy can be shown to be in the public interest. These are difficult positions to argue when public money is at stake or where a public authority is offering a private company a monopoly to charge its stakeholders.

I reserve the right to appeal your decision to withhold any information or to charge excessive fees, and understand that under the act, I am entitled to a response within 20 working days. I would be grateful if you could confirm in writing that you have received this request.

Yours faithfully,

Edward Jones

(i) Innes v Information Commissioner [2014] EWCA Civ 1086 http://www.bailii.org/ew/cases/EWCA/Civ/...

(ii) Section 11 FOIA and the Form of a Request
https://panopticonblog.com/2014/08/01/se...

(iii) 'Freedom of Information Awareness Guidance 5: Commercial Interests' Office of the Information Commissioner, Page 10 https://www.humanrightsinitiative.org/pr...

Dear London Pensions Fund Authority,

Since sending my original FOI request over ten days ago, I have not received an acknowledgement from you that you have received it. I have not been allocated a FOI reference number or been told when it will be responded to.

Please can you do the above? I am sending this to just confirm whether or not you received the original FOI request, which can be seen here: https://www.whatdotheyknow.com/request/l...

Yours faithfully,

Edward Jones

LPFA Legal, London Pensions Fund Authority

Dear Edward Jones,

Thank you for your email. Your FOI request was received safely on 20 March 2023 at 17:19. It was recorded on 21 March 2023 and the reference is Mar-23-2. Your request will be actioned and responded to within regulatory timescales.

Yours sincerely

Mark Anderson
Compliance and Regulation Manager
London Pensions Fund Authority
169 Union Street, London SE1 0LL
T: +44 (0)208 142 3574
M: +44
E: [email address]
www.lpfa.org.uk

  

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LPFA Legal, London Pensions Fund Authority

Dear Edward Jones,

To fully respond to this FOI request, under the FOI Act 2000 - Section 10, we would like to request an extension of an additional 20 working days (Extended deadline - Tuesday 16th May 2023), to enable the authority to determine whether or not the balance of the public interest lies in applying an exemption.

We will of course provide the information sooner if we receive clarification before the deadline.

Yours sincerely

Mark Anderson
Head of Compliance, Risk and Pensions
London Pensions Fund Authority
169 Union Street, London SE1 0LL
T: +44 (0)208 142 3574
M: +44
E: [email address]
www.lpfa.org.uk

  

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LPFA Legal, London Pensions Fund Authority

Dear Edward Jones,

I apologise for the delay in responding, but to fully respond to this FOI request, under the FOI Act 2000 - Section 10, we would like to request an extension of an additional 20 working days (Extended deadline - Tuesday 13th June 2023), to enable the authority to determine whether or not the balance of the public interest lies in applying an exemption.

We will of course provide the information sooner if we receive clarification before the deadline.

Mark Anderson
Head of Compliance, Risk and Pensions
London Pensions Fund Authority
169 Union Street, London SE1 0LL
T: +44 (0)208 142 3574
M: +44
E: [email address]
www.lpfa.org.uk

  

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Dear LPFA Legal,

Ref: Mar-23-2

I would like to check the status of my request.

You said: "I apologise for the delay in responding, but to fully respond to this FOI request, under the FOI Act 2000 - Section 10, we would like to request an extension of an additional 20 working days (Extended deadline - Tuesday 13th June 2023), to enable the authority to determine whether or not the balance of the public interest lies in applying an exemption."

We are working on a positive project to promote renewable energy investment and divestment from the stranded assets of fossil fuels. We would very much appreciate your help getting full data as soon as possible.

Yours sincerely,
Edward Jones

LPFA Legal, London Pensions Fund Authority

6 Attachments

Dear Edward Jones,

Thank you for your email and your patience. We asked our Investment manager to gather the information and they have explained that they have been in direct contact with you.

Please see the attached response for the below FOI request.

Attached are spreadsheets which provide the names and ISINs of the assets which make up LPPI Global Equities, LPPI Fixed Income, and LPPI Real Estate. Please note that we do not have the LEIs for the assets which do not have ISINs. Please also find the information in the format you required.

The spreadsheets will provide the weightings you were after and also the information pulled out of the pdf financial statements as you requested.

Regards

Mark Anderson
Head of Compliance, Risk and Pensions
London Pensions Fund Authority
169 Union Street, London SE1 0LL
T: +44 (0)208 142 3574
M: +44
E: [email address]
www.lpfa.org.uk

  

show quoted sections

We don't know whether the most recent response to this request contains information or not – if you are Edward Jones please sign in and let everyone know.