Freedom of Information Act (FOIA) Publication Scheme

As London CIV is wholly owned by or on behalf of our public sector LGPS Client Funds, we are subject to the Freedom of Information Act 2000 (FOIA). As such, we are obliged to make certain types of information regularly available. The way in which we publish information is also regulated by the Financial Conduct Authority (FCA) and certain information is confidential to our investors or potential investors which means our Client Funds. Further information on the FOIA and the Information Commissioners model publication scheme can be found here. 

This section of our website outlines the types of information we make available under our Publication Scheme and how individuals may access it. It also outlines how we keep the information up to date and any fees that may be charged for access to the information. Wherever possible we publish information on our website. Individual Local Authorities also publish information on their websites. 

Who we are and what we do

London LGPS CIV Limited is a non-profit, private limited company which uses the trading name London CIV. One of eight national Local Government pools, London CIV oversees the investment of pensions assets on behalf of 32 London Local Authority Local Government Pension Scheme (LGPS) Client Funds. We develop and operate investment funds for our Client Funds to invest into based on their strategic asset allocations.

The constitutional and organisational structure of London CIV is set out in our Corporate Governance Handbook and the details of our Board of Directors can be found here. London CIV is owned in equal shares by our 32 Local Government Pension Scheme Client Funds.

London CIV was incorporated on 17 July 2014 and is registered in England and Wales, with registration number 9136445. Our registered office address is 4^th Floor, 22 Lavington Street, London, SE1 0NZ . London CIV is Authorised and Regulated by the Financial Conduct Authority under the firm reference number 710618.

Our Services

We develop collective investment vehicles to facilitate pooling for our Client Funds. The Client Funds are responsible for setting their pension funds’ strategic asset allocations and determining the amount of investment risk they wish to take with the asset. London CIV then constructs products to enable them to better meet their investment needs. We are authorised only in respect of providing services to professional clients. We currently do not act on behalf of any client outside of our LGPS Client Funds. 

We currently operate three types of collective investment vehicles and provide high level information on these in our Annual Review available on our website. We publish more detailed information on a regular basis to clients as described below. The use of the word “publish” does not necessarily mean it can be made available to the general public.

Authorised Contractual Scheme (“ACS”) – Public Markets: We publish investment information to clients about holdings within our ACS twice a year, at a sub-fund level. The information is for the dealing point prior to 31 March and 30 September each year, subject to a one quarter time lag; the holdings at 31 March are published on, or shortly after, 1 July, and holdings at 30 September are published on, or shortly after, 1 January.

Exempt Unauthorised Unit Trust (“EUUT”) - Private Markets: We publish holdings information to clients for our Private Market investments at 30 June and 31 December each year, subject to a one quarter time lag; information at 30 June will be published on, or shortly after, 1 October and information at 31 December on, or shortly after 1 April. This aligns with the financial year-end of this structure.

Scottish Limited Partnership - Property: this is operated on the basis of a partnership agreement, which currently comprises of the London Fund. London CIV is the Alternative Investment Fund Manager and has delegated day to day investment management to LPPI.  

We publish Fund Factsheets to clients on a quarterly basis for our ACS equity investments where funds have twelve months performance history. We will publish information about future launches in the public news section of our website.

Our priorities and how we are doing

As a customer-owned, customer-focussed organisation, our long-term vision is to make a positive difference to investment outcomes for our Client Funds. Through pooling we will have a stronger voice and, working in partnership with our clients, we will deliver cost effective, innovative and responsible investments, thereby enabling sustainable, risk-adjusted performance over the long-term.

Our priorities and how we are delivering on them can be found in our Annual Review. Updates on our business activity can be found in the ‘News’ section of our website.

We believe businesses that are run sustainably have the potential to provide better risk adjusted returns. As a long-term investor and representative of asset owners, we will hold companies and asset managers to account regarding environmental, societal and governance factors that could impact value. We will incorporate ESG factors into our investment analysis and decision making, enabling long-term sustainable performance for our Client Funds. Our approach is described more fully in the Responsible Investment section of this website. We produce annual reports on how we are meeting our Stewardship and Engagement and Climate Objectives.

Assessment of Value Report

New regulation came into force during 2020 requiring that the governing body of an Authorised Fund Manager, (such as London CIV), must perform an assessment on a given set of criteria detailing whether the funds and services it offers in relation to our ACS are providing value to investors. An annual statement summarising the results of this assessment must be made available to investors. The FCA introduced this regulation to promote a focus on adding value for the customer and to help address weaknesses across the asset management industry regarding customer access to information.

Our Assessment of Value Statement is one element of the information provided to our Client Funds to support their own assessment of our performance in delivering against our core purpose – to make a positive difference to long-term investment outcomes for our Client Funds. We are supportive of any wider initiative that enhances transparency and focus on customers across the asset management industry.

How we make decisions

Most day-to-day decisions are made by the executive management team led by our Chief Executive Officer, but some matters are reserved to the Board of Directors or to the Shareholders for decision. Further information about how our business is governed and those matters which are reserved for decision by our Client Funds are set out in our Governance Handbook.

Our Policies and Procedures

Information on our key policies can be found here.

The ‘Responsible Investment’ section of the website contains our Responsible Investment Policy and our Stewardship and Climate Policies and related outcomes reports and voting guidance.

What we spend and how we spend it

London CIV’s expenditure and financing is set out in our Annual Review. We are a non-profit making organisation and operate according to a budget funded by our shareholders.

London CIV is subject to the provisions of public procurement under the Public Contracts Regulations 2015 for the procurement of its suppliers. However it also qualifies for certain exemptions as it is wholly owned by its client funds and procures investment services. London CIV may engage investment managers without an OJEU procurement. It also simplifies the process of appointing London CIV for Client Funds.

Lists and registers

A full list of our shareholders who are our Client Funds can be found here.

Details of our current board members can be found here.

INFORMATION ABOUT OUR FUNDS

We currently operate three types of collective investment vehicles and provide high level information on these in our Annual Review available on our website. We publish more detailed information on a regular basis to clients as described HERE. The use of the word “publish” does not necessarily mean it can be made available to the general public.

·      Authorised Contractual Scheme (“ACS”) – Public Markets: We publish investment information to clients about holdings within our ACS twice a year, at a sub-fund level. The information is for the dealing point prior to 31 March and 30 September each year, subject to a one quarter time lag; the holdings at 31 March are published on, or shortly after, 1 July, and holdings at 30 September are published on, or shortly after, 1 January.

·      Exempt Unauthorised Unit Trust (“EUUT”) - Private Markets: We publish holdings information to clients for our Private Market investments at 30 June and 31 December each year, subject to a one quarter time lag; information at 30 June will be published on, or shortly after, 1 October and information at 31 December on, or shortly after 1 April. This aligns with the financial year-end of this structure.

·      Scottish Limited Partnership - Property: this is operated on the basis of a partnership agreement, which currently comprises of the London Fund. London CIV is the Alternative Investment Fund Manager and has delegated day to day investment management to LPPI.  

We publish FUND FACTSHEETS to clients on a quarterly basis for our ACS equity investments where funds have twelve months performance history. We will publish information about future launches in the public news section of our website. 

Further information

If the information being sought is not provided in this publication scheme, please contact us using the following details:

Email: FOIrequests@londonciv.org.uk

Telephone: 0208 036 9000

Write to:

FOIA Requests

London CIV

Fourth Floor

22 Lavington Street

London

SE1 0NZ

All requests will be considered in accordance with the Freedom of Information Act 2000.

We will provide most information free of charge. The exceptions will be if a statutory fee applies or if the Act allows a charge, for example for photocopying or postage. We will not comply with a request which exceeds the appropriate limit as set out in The Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004.

Most of the information made available is subject to copyright in accordance with the Copyright, Designs and Patents Act 1988. The copyright owner is London LGPS CIV Limited unless stated otherwise. You are free to use any information supplied for your own non-commercial research or private study purposes. The information may be used for any other purpose allowed by a limitation or exception in copyright law, such as news reporting. However, if you would like to re-use this information for any commercial purpose you must make a formal request to us under the Re-Use of Public Sector Information Regulations 2015 by emailing FOIRequests@londonciv.org.uk