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Northamptonshire Pension Fund Investments

Edward Jones made this Freedom of Information request to North Northamptonshire Council 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.

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Dear North Northamptonshire Council,

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 Northamptonshire County Council Pension Fund on 31 March 2022, or the nearest possible date.

You helpfully provide investment data on the holdings page of the Northamptonshire County Council Pension Fund website (https://pensions.northamptonshire.gov.uk... ).
However, there is a small amount of missing data that we require to complete our research.

When responding please do not just refer us to the holdings page of your website as we have already checked this data.

When you answer this request, please provide the above spreadsheet from your website again, but including the data we request below for 31 March 2022 (2022 Q1):

1. Investment managers. Please provide in a new column with 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.

2. Investment identifiers (ISIN/LEI). You have provided ISIN numbers for some of the listed investments however some of them are missing from the list. For any investments that do not have an ISIN number, such as alternative assets, please provide the Legal Entity Identifier (LEI). If an investment does not have an identifier, please provide an explanation. You currently provide no identifiers for your Alternative Assets (in the ‘Alternative’ tab) and miss out identifiers for some of the investments in the ‘Investment Holdings’ tab.

3. Can you please confirm the total value of the County Council Pension Fund in pounds sterling (£) for 31 March 2022?

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...

Data Requests, North Northamptonshire Council

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confidential. It is intended solely for use by the recipient and others
authorized to receive it. If you are not the recipient, you are hereby
notified that any disclosure, copying, distribution or taking action in
relation of the contents of this information is strictly prohibited and
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Data Requests, North Northamptonshire Council

2 Attachments

Dear Mr Jones

 

Please find attached the council’s response to your recent request for
information.

 

Kind Regards

 

Data requests Team

 

Information Requests

Information Governance Team

North Northamptonshire Council

Bowling Green Road, Kettering, Northants NN15 7QX

T: 0300 126 3000 |

 

Twitter: @NNorthantsC

Facebook: @NorthNorthants

Web: [1]www.northnorthants.gov.uk

 

[2]A picture containing background pattern Description automatically
generated

 

 

 

 

 

 

 

 

──────────────────────────────────────────────────────────────────────────

Any views expressed in this email are those of the individual sender and
are not necessarily those of North Northamptonshire Council unless
explicitly stated.

This email (including any attachments) may contain confidential or
privileged information and is intended solely for the use of the
individual or entity to whom it is addressed. Any confidential, sensitive
or protectively marked material must be handled accordingly.

If you are not the intended recipient you must not disclose, distribute,
copy, print or rely on any of the information contained in the email or
attachments, and all copies must be deleted immediately. If you do receive
this email in error, please notify the sender immediately and note that
confidentiality or privilege is not waived or lost.

North Northamptonshire Council may monitor the contents of emails sent and
received via its network for the purposes of ensuring compliance with
relevant legislation and the Council’s policies and procedures. All such
monitoring will take place in accordance with relevant legislation
including privacy and data protection legislation. For details of how
North Northamptonshire Council uses personal information please see the
Council’s website.

North Northamptonshire Council has scanned this email and attachments for
viruses but does not accept any responsibilities for viruses once this
email has been transmitted. You should therefore carry out your own
anti-virus checks before opening any documents

 

══════════════════════════════════════════════════════════════════════════

Any views expressed in this email are those of the individual sender and
are not necessarily those of North Northamptonshire Council unless
explicitly stated.

This email (including any attachments) may contain confidential or
privileged information and is intended solely for the use of the
individual or entity to whom it is addressed. Any confidential, sensitive
or protectively marked material must be handled accordingly.

If you are not the intended recipient you must not disclose, distribute,
copy, print or rely on any of the information contained in the email or
attachments, and all copies must be deleted immediately. If you do receive
this email in error, please notify the sender immediately and note that
confidentiality or privilege is not waived or lost.

North Northamptonshire Council may monitor the contents of emails sent and
received via its network for the purposes of ensuring compliance with
relevant legislation and the Council’s policies and procedures. All such
monitoring will take place in accordance with relevant legislation
including privacy and data protection legislation. For details of how
North Northamptonshire Council uses personal information please see the
Council’s website.

North Northamptonshire Council has scanned this email and attachments for
viruses but does not accept any responsibilities for viruses once this
email has been transmitted. You should therefore carry out your own
anti-virus checks before opening any documents.

══════════════════════════════════════════════════════════════════════════

Disclaimer

The information contained in this communication from the sender is
confidential. It is intended solely for use by the recipient and others
authorized to receive it. If you are not the recipient, you are hereby
notified that any disclosure, copying, distribution or taking action in
relation of the contents of this information is strictly prohibited and
may be unlawful.

This email has been scanned for viruses and malware, and may have been
automatically archived by Mimecast, a leader in email security and cyber
resilience. Mimecast integrates email defenses with brand protection,
security awareness training, web security, compliance and other essential
capabilities. Mimecast helps protect large and small organizations from
malicious activity, human error and technology failure; and to lead the
movement toward building a more resilient world. To find out more, visit
our website.

References

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1. http://www.northnorthants.gov.uk/

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.