Disclosure Log
pension fund holdings (FOI/4949)
Message from Nottinghamshire County Council - 08 November 2024
Dear ***** *****
FREEDOM OF INFORMATION ACT 2000 – REQUEST FOR INFORMATION REFERENCE FOI/4949
Thank you for your request for information relating to pension fund holdings:
REQUEST
I would like to request the following details regarding the private market holdings of the pension fund:
A full list of the private markets investments (including but not limited to Venture Capital funds, Private Equity funds, Infrastructure funds, Private Credit funds, Real Estate funds etc) held by the pension fund as of todays date.
On a line by line basis, details of the following: - Date of most recent fund update - Fund manager name - Fund number - Fund vintage (year) - Asset Class (PE/VC/Real Estate etc) - Fund size - Gross IRR % - Net IRR % - MOIC - TVPI - DPI
RESPONSE
Private market assets are not valued on a daily basis. We compile valuations at each quarter end, although the time required by managers to provide quarterly valuations means we use the latest valuation available at date of compilation (adjusted for subsequent cashflow). This is the standard approach for reporting on the valuation of such private market assets.
Our quarterly valuations are provided on the Pension Fund website on a fund by fund basis. Investments | Nottinghamshire Pension Fund. Out most recent available figures are for 30th June 2024. This schedule includes - Date of most recent fund update - Fund manager name - Fund vintage (year) - Asset Class. We do not maintain details of Fund size and most of these funds do not have a Fund number.
We do not publish the Gross or Net IRR, MOIC, TVPI or DPI as this is considered to be exempt information*. Where funds choose to publish this information it can be found on their websites.
*S.43 of the FOIA 2000. While we recognise that there is a public interest in understanding the broad picture in relation to local authority pension schemes, there is also a strong public interest in ensuring that there is trust between the scheme and the funds within it. Disclosure of material which could be interpreted by those funds as a breach of commercial confidentiality would be likely to lead to those funds changing their terms of business or terminating their service with us; there would also be reputational damage to the scheme as a result of it disclosing commercially confidential information. On balance we find that the public interest in maintaining the exemption outweighs the public interest in disclosure. (Note: we restrict this information even in our internal committee reports on the following grounds: By virtue of paragraph 3 of Schedule 12A of the Local Government Act 1972, having regard to the circumstances, on balance, the public interest in disclosing the information does not outweigh the reason for exemption because divulging the information would significantly damage the Council’s commercial position in relation to the funds.)
We trust this now satisfies your request and that you find this information to be helpful.
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]
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/
Please remember to quote the reference number above in any future communications.
Your privacy: we use your personal information such as name and address so that we can comply with our legal obligations to respond to FOI requests. For further details about the use of information about you, please see the information handling privacy notice on our website at https://www.nottinghamshire.gov.uk/media/4323566/informationgovernanceandinformationrightsprivacynotice.pdf
Yours sincerely
Complaints and Information Team
Chief Executives Department
Nottinghamshire County Council
The Council is committed to protecting your privacy and ensuring all personal information is kept confidential and safe. For more details see our general and service specific privacy notices at: https://www.nottinghamshire.gov.uk/global-content/privacy