Under our rights within the Freedom of Information Act, we hereby request that you please provide us with any reports provided by the consultant to the TFL Pension Fund about the risks associated with investments in funds managed by BlueCrest Capital Management between 2013 and 2016?

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TfL Ref: FOI-4627-1718

Thank you for your email received on 21 February 2018 asking for information about our Pension Fund.

Your request has been considered in accordance with the requirements of the Freedom of Information Act and our Information Access Policy. I can confirm we do hold some of the information you require. You asked:

Please provide us with any reports provided by the consultant to the TFL Pension Fund about the risks associated with investments in funds managed by BlueCrest Capital Management between 2013 and 2016?

Our most recent documents about our Pension Fund are published here: tflpensionfund.co.uk

We are not obliged to supply you with reports related to risks associated with TfL Pension Fund investments, provided by our consultants, as the information in these reports was provided in confidence and are subject to a statutory exemption to the right of access to information under section 41 (information provided in confidence) and section 43 (commercial interests) of the FOI Act.

The information received from managers and 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. This information 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 statement of investment principles which we make available publically, our managers and other service providers are unlikely 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.

Since section 41 confers an absolute exemption, it is not necessary to consider whether the public interest in maintaining the exemption outweighs the public interest in disclosing the information. Even if section 41 did not confer absolute exemption, there would be no special public interest in disclosure of this information that would justify a breach of confidence in this case.

Section 43 applies because the commercial interests of the provider of the information would be prejudiced if disclosure meant that they were not able to earn an income from it, or similar work, in the future. 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 the public interest in ensuring that we are able to obtain the best value for money outweighs the general public interest in increasing transparency of our processes.

If this is not the information you are looking for, please do not hesitate to contact me.

Please see the attached information sheet for details of your right to appeal.

Yours sincerely,

Melissa Nichols

FOI Case Officer

FOI Case Management Team

General Counsel

Transport for London

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