FOI request detail

FOI Request: Transport for London alternative investments

Request ID: FOI-1363-1920
Date published: 20 August 2019

You asked

I am looking for the quarterly cash-flow information of all your private capital investments (private equity funds, venture capital funds, real estate funds, private debt funds, infrastructure funds, natural resource funds, etc.) made *since the inception of the individual investments* in digital format. If the investment reports are not available since inception, the earliest records on hand will suffice. The details per quarter for each investment should ideally include the standard data such as: Investment (Fund) Name; Vintage/Year; Period/Date; Capital Calls; Distributions; Remaining Value/Net Asset Value; Net IRR; Net Multiple. Thank you for your time, it is much appreciated.

We answered

TfL Ref: 1363-1920

Thank you for your request received by Transport for London (TfL) on 6 August 2019 asking for information about TfLs private capital investments.

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.

Apart from our Pension Fund arrangements, TfL does not hold any private capital investments, such as private equity funds, venture capital funds, real estate funds, private debt funds, infrastructure funds and natural resource funds.

Details of TfL’s investment strategy can be found in the Treasury Management Strategy available to the public on the TfL website.

Additionally, Information covering the TfL Pension Fund investments can be found in the Annual Report and Accounts. The most recent report is published on the Fund website: 


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

We currently have 30 investment managers and in a number of 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. There will also be information gathered from meetings and conference calls with the managers. The TfL Pension Fund employees investment consultants and  its own Fund office staff to draw out the relevant information from 100s of documents and contacts 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 and the investment consultants on individual investment holdings (which reflect their various strategies) represent the employment of their own intellectual property (and for which we pay fees for them doing so)  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 in strictest confidence with no reproduction without prior written consent.

Other than what is legally required to be produced in documents such as statutory accounts and other documents which we make available publicly on website:   e.g. the statement of investment principles and the sustainability report, our managers and other service providers do not to agree to any further disclosure as this may 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

Sara Thomas

FOI Case Officer

FOI Case Management Team

General Counsel

Transport for London

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