FOI-258-21

Date: 1 October 2021

Summary:

University Investment Portfolio.

 

FOI-258-21

Date of Response:

21 October 2021

Outcome:

Information Withheld In Part

Information Not Held In Part

 

Request: 

  1. What was the total market value of the university’s investment portfolio(s) on the 31st July 2021? If you are going to provide this information through your Annual Accounts/Financial Statements, please provide the specific page number, section and row that the value can be found on. For example, page 28, section 5 “Investments”, line “overall investment value”. 
  2. On the 31st July 2021, were the institution's investment portfolio(s) managed directly by the institution, indirectly by [an] external fund manager(s), or a combination of both?
  3. If the university uses external fund manager(s) to manage investment portfolios, please provide the name of each fund manager used, along with the percentage of the total investment funds that they were managing on the 31st July 2021

Please present this information in this format:  

Fund manager name -- Percentage of total investment funds managed Schroders -- 47% CCLA -- 49% University -- 4% 

       4. If the institution invests directly, please provide the details of companies invested in (by way of all        investment portfolios), including the full names of each company invested in, and the market value invested in each company on the 31st July 2021. Please provide this information in a spreadsheet format.   

Please present this information in this format:  

Fund manager name -- Percentage of total investment funds managed Schroders -- 47% CCLA -- 49% University -- 4% 

       5. If the university holds investments through [an] external fund manager(s), please provide the investment portfolio for that manager on the 31st July 2021, including the market value for each company that forms part of your investment portfolio(s) with them. Please provide this information at a company level in a spreadsheet and/or the format that this information is provided to you by your fund manager(s). For example, see here: https://url6.mailanyone.net/v1/?m=1mWHgn-0005E5-5J&i=57e1b682&c=YvcPsW3sNDO2Wbnt7lVXCdJmBRlE5GjyvfA1jNPtlGi4gwCT0Md4mccUY44Xv-JN3gRhg7HvgSxFt9PDvjJjl0KBztjYOcTg4hdp56_kruSos-oBh-8uNUyJ6eyqFothuiAq5d-yJWQvr19CxijkPr05Rl6w6pvk6XQch92m5YSebFnk59Sb72qq0mTgbRAdI5468qayq9lWcqblLoBrsf5k_wEsLlevVqNs-0BxrBrU-8wFlpACcHxL-D4VBTxx

       6. Does the institution have an ethical investment policy, or similar? If so, please state if it is publicly-available, and provide a web link. 

  If applicable, in response to any of the above information requested, please confirm that the University does not hold this information.  

 

Response:

In accordance with Section 1(1)(a) of the FOIA, I can confirm that the University does hold the requested information in part, as some of the requested information does not exist.  

 I have decided to withhold the requested information, which exists, in full in accordance with Section 21 of the FOIA. 

 

Section 17 of the FOIA provides that: 

 17. Refusal of Request 

17. (1) A public authority which, in relation to any request for information, is to any extent relying on a claim that any provision of Part II relating to the duty to confirm or deny is relevant to the request or on a claim that information is exempt information must, within the time for complying with section 1(1), give the applicant a notice which—

      a. states that fact,

      b. specifies the exemption in question, and

      c. states (if that would not otherwise be apparent) why the exemption applies.

 

 Section 21 of the FOI Act provides that: 

 21. Information accessible to applicant by other means 

 21. (1) Information which is reasonably accessible to the applicant otherwise than under section 1 is exempt information. 

 

(2). For the purposes of subsection (1)-  

(a) Information may be reasonably accessible to the applicant even though it is accessible only on payment; and  

(b) Information is to be taken to be reasonably accessible to the applicant if it is information which the public authority or any other person is obliged by or under any enactment to communicate (otherwise than by making the information available for inspection) to members of the public on request, whether free of charge or on payment.  

 

The FOI Act gives rights of public access to information held by public authorities. The purpose of Section 21 of the FOI Act is to ensure that there is no right of access to information via the Act/FOI process, if it already available to the applicant via another route.  

 

This exemption applies if the requested information is already accessible to you as the Applicant/Requester. This exemption is applied where it is either know that, you already hold the information or it is available to you (with the information already being in the public domain).  

 

When the University is applying this exemption, it has a duty to confirm or deny whether it holds the information and where possible inform you of how you can access the information.  

 

Given that the information is available in the public domain, it is entirely reasonable and appropriate to withhold disclosure of the requested information pertaining to Question 6 of your request, in accordance with Section 21 of the FOI Act.

 

The requested information can be found at:  

 https://www.wlv.ac.uk/staff/media/departments/finance/documents/Ethical-Investments-Policy.pdf

 

Information pertaining to Questions 1 through to 5 cannot be disclosed as the requested information does not exist. Our Finance Directorate have confirmed that the University does not invest funds in the way, outlined within the scope of your request and the University does not work with any fund managers. This decision has been made after all reasonable steps have been taken to locate the referenced requested information. Whilst I acknowledge that it is the principle object of the FOIA to provide public access to documents, I am satisfied that the referenced requested information does not exist.