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University Investment Portfolio Statistics

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To whom it may concern,

This is a request for information through the Freedom of Information Act.

1. What was the total market value of the university’s investment portfolio(s) on the 31st July 2022?

If you are going to provide this information through your Annual Accounts/Financial Statements, please provide the specific page number, section and row that the value can be found on. For example, page 28, section 5 “Investments”, row “total market value.”

For guidance on the number we are seeking, please see this example from the University of Glasgow at ‘Annual Investments’ in cell C1091 here: https://www.gla.ac.uk/myglasgow/sustaina...

2. On the 31st July 2022, were the institution's investment portfolio(s) managed directly by the institution, indirectly by [an] external fund manager(s), or a combination of both?

3. If the university uses external fund manager(s) to manage investment portfolios, please provide the name of each fund manager used, along with the percentage of the total investment funds that they were managing on the 31st July 2022.

Please present this information in this format:

Fund manager name - Percentage of total investment funds managed
Schroders - 47%
CCLA - 49%
University - 4%

4. If the institution invests directly, please provide the details of companies invested in (by way of all investment portfolios), including the full names of each company invested in, and the market value invested in each company on the 31st July 2022. Please provide this information in a spreadsheet format.

5. If the university holds investments through [an] external fund manager(s), please provide a breakdown of the university’s holdings with that investment manager on the 31st July 2022, including the market value for each company that forms part of your investment portfolio(s) with them. Please provide this information at a company level in a spreadsheet and/or the format that this information is provided to you by your fund manager(s).

For example, see the University of Glasgow’s breakdown at ‘Annual Investments’ here: https://www.gla.ac.uk/myglasgow/sustaina...

6. Does the institution have an ethical investment policy, or similar? If so, please state if it is publicly-available, and provide a web link.

If applicable, in response to any of the above information requested, please confirm that the University does not hold this information.

Please confirm receipt of this request and we look forward to hearing back from you within the next 20 working days.

Yours sincerely,

Laura Clayson

InfoRequest, Cardiff University

1 Attachment

Dear Laura,

 

I acknowledge receipt of your received by this office on 2^nd September
2022.

 

Your request will now be dealt with under the Freedom of Information Act
2000 and has been allocated reference FOI22-299 which should be quoted in
all correspondence. We will respond to your request within 20 working days
starting the next working day after receipt, therefore you can expect to
receive a response no later than 30^th September 2022.

 

Where we consider that we will not be able to meet the deadline or if
further time is required to consider the public interest test we will
contact you as soon as possible and give you a revised date for response.

 

In some circumstances a fee may be payable and, if that is the case, we
will let you know. A fees notice will be issued to you, and you will be
required to pay before we will proceed to deal with your request.

Yours sincerely

 

Ian Johnson                                                               
             Ian Johnson  

  Swyddog Cydymffurfiaeth                                    
              Compliance Officer 

  

Swyddfa Ysgrifennydd y Brifysgol    University Secretary’s Office 

Prifysgol Caerdydd    Cardiff University 

42 Park Place      42 Park Place  

Caerdydd    Cardiff 

CF10 3BB    CF210 3BB 
Ffôn: 029 208 79633  Phone: 029 208 79633 

E-bost: [1][email address]  E-mail: [2][email address

     

Rydym yn croesawu gohebiaeth trwy’r We welcome correspondence in Welsh or
Gymraeg neu’r Saesneg. Ni fydd gohebu    English. Corresponding in Welsh will
yn Gymraeg yn creu unrhyw oedi.  not lead to any delay. 

     

Ysgrifennwch ataf yn Gymraeg neu’n Please write to me in Welsh or
Saesneg  English 

   

 

show quoted sections

InfoRequest, Cardiff University

Dear Laura Clayson

I am writing in response to your Freedom of Information request dated 2
September 2022.

For ease of reference, I have reproduced your question(s) below and set
out our corresponding response(s).

1. What was the total market value of the university’s investment
portfolio(s) on the 31st July 2022?

 

If you are going to provide this information through your Annual
Accounts/Financial Statements, please provide the specific page number,
section and row that the value can be found on. For example, page 28,
section 5 “Investments”, row “total market value.”

 

For guidance on the number we are seeking, please see this example from
the University of Glasgow at ‘Annual Investments’ in cell C1091 here:
[1]https://eur03.safelinks.protection.outlo...

 

Under s22 of the Freedom of Information Act 2000 we are not obliged to
provide information that is due for future publication. Cardiff
University’s financial period runs to 31 July each year. The annual
accounts contain information on investments and endowments and other
financial activity. Information for the 2021/22 financial year is due to
be published in December 2022 and will be available to the public on our
website at
[2]https://www.cardiff.ac.uk/public-informa...
We are not aware of any pressing public interest in providing the
information earlier than the expected publication date. We are not aware
of any pressing public interest in providing the information earlier than
the expected publication date and it may interfere with the commercial
interests of the University to do so.  For further information on the
publication date and any charges that may apply please contact the Finance
department.

 

 

2. On the 31st July 2022, were the institution's investment portfolio(s)
managed directly by the institution, indirectly by [an] external fund
manager(s), or a combination of both?

 

The University’s investment portfolios were managed by external Investment
Managers.

 

 

3. If the university uses external fund manager(s) to manage investment
portfolios, please provide the name of each fund manager used, along with
the percentage of the total investment funds that they were managing on
the 31st July 2022.

 

Please present this information in this format:

 

Fund manager name - Percentage of total investment funds managed

 

Schroders  - 47%

 

CCLA - 49%

 

University - 4%

 

As at 31^st July 2022, the University’s total endowment and investment
portfolio was managed by investment managers in the following proportions.

 

Barclays 38%
Rathbones 11%
Sarasin 38%
CCLA 13%

 

 

4. If the institution invests directly, please provide the details of
companies invested in (by way of all investment portfolios), including the
full names of each company invested in, and the market value invested in
each company on the 31st July 2022. Please provide this information in a
spreadsheet format.

We do not hold the information as at 30th September 2022.  As at 31st July
2022 the University had a direct investment in Mobeus IV (Private Equity
Fund), which was less than 1% of the University’s investment
portfolio. This information is not available in spreadsheet format.

 

5. If the university holds investments through [an] external fund
manager(s), please provide a breakdown of the university’s holdings with
that investment manager on the 31st July 2022, including the market value
for each company that forms part of your investment portfolio(s) with
them. Please provide this information at a company level in a spreadsheet
and/or the format that this information is provided to you by your fund
manager(s).

 

For example, see the University of Glasgow’s breakdown at ‘Annual
Investments’ here:
[3]https://eur03.safelinks.protection.outlo...

 

Cardiff University endowment assets and other investments are managed by
external fund managers, who report to the University on the companies
invested in and the market value invested. After due consideration it is
considered that the information is exempt from disclosure by virtue of
Section 43 of the Freedom of Information Act 2000 entitled ‘Commercial
interests’. This section states:

 

43(2) 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 contains data that would give insight into the
University’s activities that would be likely to prejudice its commercial
interests. The University has appointed external fund managers to create a
portfolio of investments which will help the University to raise funds and
remain financially sustainable. If a competitor knew

how University funds were invested, they could use this information to
gain financial advantage without paying for the financial advice as
Cardiff University has done. There is a real and significant risk that
competitors could replicate the University’s investment strategy and
thereby adversely impact on the market value. This would have the effect
of distorting the market and give a clear advantage to competitors who may
not be subject to the FOI Act to exploit that information for their own
competitive gain. The changes to the funding of universities over recent
years has resulted in many institutions considering alternative ways of
securing funding for their core purpose. A robust investment portfolio is
one element of strategic development which will ensure that the University
is able to compete in a competitive market and provide the best experience
for its students.

 

In order to apply, the exemption requires that a public interest be
considered, and this is documented below:

 

Public Interest Test

 

Factors in favour of disclosure

 

Openness and Transparency - It is in the public interest that
University's, as public authorities, are as open and transparent as
possible in the way that they operate and the way in which decisions are
made.

 

Factors in favour of non-disclosure

 

Commercial Interests - It is not in the public interest to disclose
information that would undermine the ability of the University to achieve
the best return on its investments.

Efficiency and effectiveness – It is not in the public interest to
disclose information that would erode the efficiency and effectiveness of
the organisation by eroding its opportunity’s to achieve the best return
on its investments and undermine its ability to use that income for
reinvestment in its public task.

 

Given the above, it is considered that it is in the greater public
interest to withhold the information from disclosure at this time.

 

 

6. Does the institution have an ethical investment policy, or similar? If
so, please state if it is publicly-available, and provide a web link.

The ethical investment policy is available at
[4]Investment_Policy_Statement_May_2018.pdf (cardiff.ac.uk)

I trust this information satisfies your enquiry. Should you feel
dissatisfied with this response or the way in which your request was
handled you can request an Internal Review. This should be made in writing
within 40 working days of the date of this email. Please provide your
unique reference number of your request, information on why you are
dissatisfied and any detail you would like us to consider as part of the
Internal Review process. Email your request to
[5][email address] where it will be forwarded to the Head of
Compliance and Risk who will be responsible for overseeing the review.

If you remain dissatisfied following the outcome of your complaint, you
have the right to apply directly to the Information Commissioner for
consideration. The Information Commissioner can be contacted at the
following address: Information Commissioner's Office, Wycliffe House,
Water Lane, Wilmslow, Cheshire, SK9 5AF.

I would like to take this opportunity to thank you for your interest in
Cardiff University. If you require further assistance please feel free to
contact me.

Kind regards

 

Swyddfa Ysgrifenydd y Brifysgol University Secretary’s Office

Prifysgol Caerdydd Cardiff University

Ebost : [6][email address] Email: [7][email address
 
 
 
The University welcomes
Mae'r Brifysgol yn croesawu correspondence in Welsh or English. 
gohebiaeth yn Gymraeg neu'n Saesneg.  Corresponding in Welsh will not lead
Ni fydd gohebu yn Gymraeg yn creu to any delay.
unrhwy oedi.

 

 

 

 

 

References

Visible links
1. https://eur03.safelinks.protection.outlo...
2. https://www.cardiff.ac.uk/public-informa...
3. https://eur03.safelinks.protection.outlo...
4. https://www.cardiff.ac.uk/__data/assets/...
5. mailto:[email address]
6. mailto:[email address]
7. mailto:[email address]

Dear Cardiff University,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of Cardiff University's handling of my FOI request 'University Investment Portfolio Statistics'.

I would like to please request an internal review on the decision not to disclose market values at the company-level within the university's investment portfolios on the grounds that disclosure of this information would "be likely to prejudice its [the university's] commercial interests."

Other institutions in the sector have willingly disclosed this information to us for analysis this year - and in the previous years that we have undertaken this annual research. Additionally, a number of institutions publish this information on their public-facing websites. This is in spite of the issues you have raised, indicating public interest around the transparency and accountability of public authorities outweighs the arguments for non-disclosure that you highlight.

Please let me know if there is anything more you need from me to support the internal review process.

Please may I remind you that guidance published by the Information Commissioner's Office states internal reviews should ideally take no longer than 20 working days.

Kind Regards,
Laura Clayson

InfoRequest, Cardiff University

Dear Laura Clayson

I acknowledge receipt of your request for an internal review received by this office on 10 November 2022.

Your request has been referred to the Head of Compliance and Risk, who will aim to respond within 20 working days starting the day after receipt. Therefore you can expect to receive a response no later than
8 December 2022.

In some circumstances we may not be able to meet this deadline and if this is likely to be the case we will contact you as soon as possible and give you a revised date for response.

Yours sincerely

show quoted sections

InfoRequest, Cardiff University

1 Attachment

Dear Laura Clayson,

 

Please find attached our response to your request dated 10^th November
2022 for an internal review of our Freedom of Information reply of 28^th
September 2022.

 

Yours sincerely

 

 

 

Swyddfa Ysgrifenydd y Brifysgol University Secretary’s Office

Prifysgol Caerdydd Cardiff University

Ebost : [1][email address] Email: [2][email address
 
 
 
The University welcomes
Mae'r Brifysgol yn croesawu correspondence in Welsh or English. 
gohebiaeth yn Gymraeg neu'n Saesneg.  Corresponding in Welsh will not lead
Ni fydd gohebu yn Gymraeg yn creu to any delay.
unrhwy oedi.

 

 

 

References

Visible links
1. mailto:[email address]
2. mailto:[email address]

InfoRequest, Cardiff University

2 Attachments

Dear Laura,

 

Please find attached a letter in response to your complaint to the ICO
regarding your Freedom of Information request to Cardiff University.

 

Kind regards,

 

 

┌─────────────────────────────┬─┬─────────────────────────────┐
│Gwasanaeth Cais am Wybodaeth │ │Information Request Service, │
│ │ │Compliance & Risk,  │
│Cydymffurfiaeth a Risg  │ │ │
│ │ │University Secretary’s │
│Swyddfa Ysgrifennydd y │ │Office  │
│Brifysgol  │ │ │
├─────────────────────────────┼─┼─────────────────────────────┤
│Prifysgol Caerdydd  │ │Cardiff University  │
├─────────────────────────────┼─┼─────────────────────────────┤
│  │ │  │
├─────────────────────────────┼─┼─────────────────────────────┤
│Ebost: │ │Email: │
│[1][email address] │ │[2][email address] │
│ │ │ │
│  │ │  │
│ │ │ │
│Rydym yn croesawu gohebiaeth │ │We welcome correspondence in │
│trwy’r Gymraeg neu’r Saesneg │ │Welsh or English  │
└─────────────────────────────┴─┴─────────────────────────────┘

 

 

 

References

Visible links
1. mailto:[email address]
2. mailto:[email address]

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