Disclosure Log
Internal Communications Regarding Local Government Pension Scheme (LGPS) Relating to ESG or Net Zero. (FOI/7792)
Message from Nottinghamshire County Council - 17 May 2026
Dear Requester,
Request FOI/7792
Further to your request received on 17th April 2026, I confirm that the Council has now considered your request under the Freedom of Information Act 2000.
Question)
Please could you send me any correspondence:
- Sent since 1/5/2025.
- Between councillors or council officers and the following organisations: Local Government Pension Scheme; Local Authority Pension Fund Forum; Local Government Pension Scheme Advisory Board; LGPS Central.
- That include any of the following terms: “environmental, social, governance”, or “ESG”, or “responsible investment”, or “net zero”.
The authority holds information within the scope of your request. However, we are refusing to disclose this information as it is exempt under section 36(2)(b)(ii) of the Freedom of Information Act 2000.
Section 36(2)(b)(ii) applies where, in the reasonable opinion of a Qualified Person, disclosure of the information would, or would be likely to, inhibit the free and frank exchange of views for the purposes of deliberation.
In this case, the Qualified Person has given their reasonable opinion that disclosure of the requested information would be likely to have such an inhibitive effect. The information consists of internal communications in which officers and advisers exchange candid views, explore options, and debate emerging issues relating to Local Government Pension Scheme (LGPS) investment considerations, including ESG and Net Zero matters.
Public Interest Test
As section 36 is a qualified exemption, we have considered whether the public interest in disclosure outweighs the public interest in maintaining the exemption.
Public interest in favour of disclosure
- Promoting openness and transparency in relation to the management of significant public funds through the LGPS.
- Enabling public scrutiny of how ESG and Net Zero considerations are discussed and balanced against fiduciary and financial responsibilities.
- Supporting informed public debate on environmental, social and governance issues affecting public sector pension schemes.
- Protecting the ability of officers and advisers to engage in open, candid and constructive discussions when developing policy options and providing advice on complex and sensitive LGPS investment matters.
- Avoiding a chilling effect whereby participants may be less willing to express provisional or critical views if internal deliberations are likely to be disclosed.
- Preserving the quality of decision-making by maintaining a safe space for rigorous internal debate prior to decisions being taken.
- Recognising that final decisions, strategies and policies relating to LGPS investments are already published through formal committee reports and governance processes, providing transparency without undermining internal deliberation.
While there is a recognised public interest in transparency and accountability regarding LGPS investment considerations, including ESG and Net Zero issues, we consider that disclosure of the requested internal communications would be likely to inhibit the free and frank exchange of views necessary for effective deliberation.
On balance, the public interest in maintaining the exemption outweighs the public interest in disclosure.
The information is therefore withheld under section 36(2)(b)(ii) of the Freedom of Information Act 2000.
The Pension Fund does publish significant material on the topic on its website.
Details of the Fund’s strategies, including the Investment Strategy Statement, can be found here:
Governance and strategies | Nottinghamshire Pension Fund
This page outlines the Pension Fund"s approach to Responsible Investment:
Responsible Investment | Nottinghamshire Pension Fund
And details of the Fund"s approach to environmental risk are set out here:
Environmental Risk | Nottinghamshire Pension Fund
We hope you find this information useful.
The Council publishes Access to Information requests and responses on its online Disclosure Log. Only requests deemed to be in the public interest will be included and any request included within this log will be de-personalised accordingly.
To view the Council’s Disclosure Log, please visit our website.
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https://www.nottinghamshire.gov.uk/media/4323566/informationgovernanceandinformationrightsprivacynotice.pdf
If you are dissatisfied with the handling of your request, you have the right to ask for an internal review. Requests should be submitted within 40 working days of the date of receipt of the response to your original request and should be addressed to: Complaints and Information Team, Nottinghamshire County Council, County Hall, Loughborough Road, West Bridgford, NOTTINGHAM, NG2 7QP or [email protected].
Please remember to quote the reference number above in any future communications.
If you are not content with the outcome of the internal review, you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at: Information Commissioner’s Office, Wycliffe House, Water Lane, WILMSLOW, SK9 5AF or https://ico.org.uk/make-a-complaint/foi-and-eir-complaints/.
Yours sincerely
Freedom of Information
Complaints and Information Team
Chief Executives Department
Nottinghamshire County Council
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