under the Freedom of Information Act 2000, I request a copy of the quarterly public records from most recent of the following information at the partnership level, preferably in Excel or PDF format: 1. Names and vintage years of all private equity, venture capital, mezzanine, distressed, real estate/REIT, debt and infrastructure partnerships in TfL Pension Fund’s portfolio. 2. Commitments made to each partnership. 3. Contributions drawn down since inception. 4. Distributions made to TfL Pension Fund to date by each individual partnership. 5. Net Asset Value of each partnership. 6. Internal rates of return (IRRs) for each partnership. Please note if the IRRs are not net. 7. Investment multiple (TV/PI) for each individual partnership. 8. The dollar amount of “total management fees and costs paid” for each individual partnership. 9. Date as of which all the above data was calculated. 10. Names of all alternative asset partnerships partially and fully sold by TfL Pension Fund, including date of sale. If there are any fees for searching for, reviewing, or copying the records, please inform me before you task the request. If you deny all or any part of this request, please cite each specific exemption you think justifies your refusal to release the information and notify me of appeal procedures available under the law.

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Our ref: FOI-1178-1718/GH

Thank you for your request received by Transport for London (TfL) on 14 August 2017 asking for information about TfL’s Pension Fund.

Your request has been considered under the requirements of the Freedom of Information Act 2000 and our information access policy. I can confirm that we do hold the information you require.

Information covering the TfL Pension Fund investments and investment returns is provided in the Annual Report and Accounts. That for the year-ended 31 March 2017 has recently been published on the Fund website: www.tflpensionfund.co.uk .

Information accessible by other means is exempt from the right of access under s21 of the Freedom of Information Act.

We currently have over 30 investment managers and in some cases a manager operates multiple investment strategies for us. For each we will receive information regarding our investments. This will be at least quarterly, but usually also monthly and sometimes weekly or daily. The TfL Pension Fund employees investment consultants and independent performance advisers and its own Fund office staff to draw out the relevant information from 100s of documents to present this in reports to the Trustees on a quarterly basis and for the annual report and accounts.

In accordance with the FOI Act, we are not obliged to supply some of the information as it is subject to a statutory exemption to the right of access to information under section 43.

In this instance the exemption has been applied as the information received from managers on individual investment holdings (which reflect their various strategies) represent the employment of their own intellectual property (for which we pay fees for them doing so) and is proprietary and confidential in nature, intended for the use of the recipient only. Accordingly, and in line with the confidentiality clause in the relevant legal agreements, we have to take due care and consideration to ensure the content remains held in strictest confidence with no reproduction without prior written consent. For passive holdings, the relevant benchmark indices are provided in the annual accounts. The index represents proprietary information of the issuer and information regarding the holdings which would comprise the index could be obtained from them for a fee. As we only hold units in the relevant passive investment manager accounts, we do not receive any detail regarding the underlying individual share or bond holdings.

Other than what is legally required to be produced in documents such as statutory accounts which we make available publicly, our fund managers and other service providers are unlikely to agree to any further disclosure as this will be likely to give advantage to a competitor or devalue their intellectual property by their not being able to earn an income from it if it is provided free to the general public

The use of this exemption is subject to an assessment of the public interest in relation to the disclosure of the information concerned. We recognise the need for openness and transparency by public authorities, but in this instance we feel that balance lies in favour of withholding the detailed information you have asked for to ensure our service providers are able to trade competitively, as well as avoiding any potential legal challenges to TfL from the suppliers that could arise from disclosure.

If this is not the information you are looking for, or if you are unable to access it for some reason, please do not hesitate to contact me.

If you are not satisfied with this response please see the attached information sheet for details of your right to appeal.

Yours sincerely

Graham Hurt

FOI Case Officer

FOI Case Management Team

General Counsel

Transport for London

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