Cash Flow Reports Private Capital Investments (FOI)

​​Request

We are requesting quarterly cash-flow reports from Q4 2023.

Private capital investments include private equity, real estate, natural resources, infrastructure, venture, and private debt funds. Each report would ideally contain these fund attributes: 

1. Investment or fund name and vintage year

2. Period or date of investment performance

3. Net capital calls or contributions

4. Net distributions

5. Net asset value or remaining value

6. Net IRR

7. Net multiple or TVPI

8. Asset allocations breakdown

9. Board meeting and investment committee meeting materials for the last quarter (board packets, manager presentations, meeting minutes)

Response

1.

Investment or fund name and vintage year of managers with which the Government of Jersey invest, deemed to qualify as private capital investments including private equity, real estate, natural resources, infrastructure, venture, and private debt funds are detailed in the attached table. 

Attachment Investment Table.pdf​

2.

The contractual terms with the Managers prevent the disclosure of confidential data including individual performance and positioning data. Article 26 of the Freedom of Information (Jersey) Law 2011 has been applied.

Comingled performance for the investment pools for the period requested, Q4 2023 is below.

• Opportunities Pool 1. Q4 2023 performance 1.85%
• Opportunities Pool 2. Q4 2023 performance 1.71%
  
• Opportunities Pool 3. Q4 2023 performance 1.74%

3. 

On an individual Fund basis, this information is exempt on the grounds of Article 26 and 33 of the Freedom of Information (Jersey) Law 2011. 

Details are provided per investment pool, which include the managers detailed in question 1.

• Opportunities Pool 1. No contributions were made into the Pool over Q4 2023.
• Opportunities Pool 2. £25,000,000 of contributions were made into the Pool over Q4 2023.
• Opportunities Pool 3. £15,000,000 of contributions were made into the Pool over Q4 2023.

4. 

On an individual Fund basis, this information is exempt on the grounds of Article 26 and 33 of the Freedom of Information (Jersey) Law 2011.  

Details are provided per investment pool, which include the managers detailed in question 1.

• Opportunities Pool 1. £12,000,000 of drawdowns were made from the Pool over Q4 2023.
• Opportunities Pool 2. £7,200,000 of drawdowns were made from the Pool over Q4 2023.
• Opportunities Pool 3. No drawdowns were made from the Pool over Q4 2023.

5. 

On an individual Fund basis, this information is exempt on the grounds of Article 26 and 33 of the Freedom of Information (Jersey) Law 2011. 

Details are provided per investment pool, which include the managers detailed in question 1.

• Opportunities Pool 1. Had a net asset value of £158,634,709 in Q4 2023.
• Opportunities Pool 2. Had a net asset value of £333,132,000 in Q4 2023.
• Opportunities Pool 3. Had a net asset value of £160,099,949 in Q4 2023.

6 and 7.  

This information is not held. Article 3 of the Freedom of Information (Jersey) Law 2011 applies. 

8. 

Asset allocations are maintained in the States of Jersey Investment Strategies document, published online, please see the link below. As this information is publicly available, Article 23 of the Freedom of Information (Jersey) Law 2011 has been applied. 

States of Jersey Investment Strategies: Amendment and Presentation to the States​

9. 

The board packs received by the Treasury Advisory Panel include confidential data from underlying investment managers including individual performance, fee terms and positioning data, as well as proprietary data on underlying Fund investment strategy. The contractual terms with individual Managers prevent the disclosure of confidential data.

Article 26 of the Freedom of Information (Jersey) Law 2011 has been applied.

Articles applied

Article 3 - Meaning of “information held by a public authority”

For the purposes of this Law, information is held by a public authority if –

(a)     it is held by the authority, otherwise than on behalf of another person; or

(b)     it is held by another person on behalf of the authority.

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 26 Information supplied in confidence

Information is absolutely exempt information if –

(a) it was obtained by the scheduled public authority from another person (including another public authority); and

(b) the disclosure of the information to the public by the scheduled public authority holding it would constitute a breach of confidence actionable by that or any other person.

The release of detailed information on sourced from individual managers could in principle reveal aspects of portfolio positioning or proprietary strategy, which would be prejudice to the commercial interests of the GoJ. States of Jersey could also be prohibited from accessing certain investment products if Managers determined that GoJ could be accessed a source of otherwise confidential 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. 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.