States of Jersey investment strategies (FOI)

​​​​​Request 682575247

I am writing to formally request information under the Freedom of Information (Jersey) Law 2011 regarding the States of Jersey's investment funds as outlined in the document titled "States Investment Strategies," presented by the Minister for Treasury and Resources on November 8, 2023.

Specifically, I would like to request the following details for each of the funds, including the Common Investment Fund, mentioned in the document:

Current Asset Allocation: A detailed breakdown of the current asset allocation for each fund, including percentages allocated to equities, fixed income, cash, and alternative investments.

Underlying Asset Managers: A comprehensive list of the underlying asset managers for each fund, including their respective roles and the assets they manage.

Investment Holdings Schedule: A complete schedule of all investment holdings within each fund. This should include direct equities, bonds, funds, and any other relevant assets.

Recent Valuations: The most recent valuations for each investment holding listed in the schedule.

This information is vital for understanding the financial management and investment strategies employed by the States of Jersey. I appreciate your attention to this request and look forward to your prompt response.

Thank you for your assistance.

Response

For clarity, the question has been split into two parts as detailed below: 

1)​

I would like to request the following details for each of the funds, including the Common Investment Fund, mentioned in the document Current Asset Allocation: A detailed breakdown of the current asset allocation for each fund, including percentages allocated to equities, fixed income, cash, and alternative investments.  

The asset allocation for each States Fund invested through the Common Investment Fund is detailed within the Investment Strategy Document published at Gov.je. Please see the link below. Each Fund has an individual strategy which includes a synopsis of the fund purpose, the asset allocation and any specific restrictions applied to that Fund.  

States Assembly | R.185/2024.statesassembly.gov.je

2)

Underlying Asset Managers: A comprehensive list of the underlying asset managers for each fund, including their respective roles and the assets they manage.  

Recent Valuations: The most recent valuations for each investment holding listed in the schedule.  

Underlying asset managers are assigned to specific asset classes, reflecting their individual mandates.  

These asset classes are organized into ‘pools’, in which State Funds hold ‘units’ to align with their individual investment strategies.  

The attached table outlines Manager allocations within Asset Pools and their respective role/style. The total value of each pool as of 31/12/24 is also disclosed.  

Attachment Asset Table.pdf​

Exact allocations to individual managers are considered commercially sensitive and are therefore exempt under Article 33 of the Freedom of Information (FOI) (Jersey) Law 2011.  

• Information can be withheld if disclosure would, or is likely to, prejudice the commercial interests of any person, including the government itself. 
• This includes cases where revealing financial or contractual details could disadvantage the government in negotiations or market positioning. 

Articles applied 

Article 23 - Information accessible to applicant by other means

(1) Information is absolutely exempt information if it is reasonably available to the applicant, otherwise than under this Law, whether or not free of charge.

(2) A scheduled public authority that refuses an application for information on this ground must make reasonable efforts to inform the applicant where the applicant may obtain the information.

Article 33 - Commercial interests

Information is qualified exempt information if –

(a) it constitutes a trade secret; or

(b) its disclosure would, or would be likely to, prejudice the commercial interests of a person (including the scheduled public authority holding the information).

Public Interest Test 

Article 33 (b) is a prejudice-based exemption. That means that in order to engage this exemption there must be a likelihood that disclosure would cause prejudice to the interest that the exemption protects. In addition, this is a qualified exemption and consideration must be given to the public interest in maintaining the exemption. 

It is acknowledged that there could be public interest from a transparency perspective in providing a more detailed breakdown of how much money is invested with each individual investment manager. However, balanced against this is the interest of the investment manager and the potential impact that disclosure of this information might prejudice their commercial interests and their ability to manage their portfolios which are a combination of investments from a significant number of third-party investors. Additionally, knowledge of relative holdings could put Jersey at a disadvantage during manager fee negotiations. 

On balance we have concluded that the impact on the individual investment managers’ commercial interests is greater than the public interest of releasing the individual amounts.