Government of Jersey Common Investment Fund (FOI)

​Request

Dear Sir/Madam,

Greetings. Hope you are well.

Under the Freedom of Information (Jersey) Law 2011, we would like to request below, please:

(States of Jersey Common Investment Fund)

• Performance metrics of all closed-end funds including Private Equity, Venture Capital, Private Debt, Real Estate, Real Assets/Infrastructure funds that you invest in for quarters Q4 2023, Q1 2024 and Q2 2024, including standard data, such as:

a. Commitment 

b. Vintage Year

c. Funded Commitment 

d. Unfunded Commitment 

e. Distributions 

f. Market Value 

g. IRR (Net/Gross)

h. PIC 

i. DPI 

j. RVPI 

k. TVPI 

As per the above legislation could you kindly attempt to provide the information within twenty business days. If you intend to withhold any of this information, could you please utilize redaction processes citing each exemption and detailing your reasoning as to why you believe the harm/prejudice of disclosure outweighs the public interest in transparency.

Thank you—your assistance is very much appreciated.

Response

A

Commitments to managers in 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, including the Common Investment Fund Pool they are constituent Managers of.   

Table.pdf​

B

This information is publicly available in response to a previous Freedom of Information request as linked below. Article 23 of the Freedom of Information (Jersey) Law 2011 has been applied.  

Cash Flow Reports Private Capital Investments (FOI)  

C & D 

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. 

E 

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

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

Opportunities Pool 1. £12m of distributions were made from the Pool over Q4 2023. 

Opportunities Pool 1. £0m of distributions were made from the Pool over Q1 2024. 

Opportunities Pool 1. £14m of distributions were made from the Pool over Q2 2024.  

Opportunities Pool 2. £7.2m of distributions were made from the Pool over Q4 2023. 

Opportunities Pool 2. £0m of distributions were made from the Pool over Q1 2024. 

Opportunities Pool 2. £2.5m of distributions were made from the Pool over Q2 2024.   

Opportunities Pool 3. £0m of distributions were made from the Pool over Q4 2023. 

Opportunities Pool 3. £0m of distributions were made from the Pool over Q1 2024. 

Opportunities Pool 3. £0m of distributions were made from the Pool over Q2 2024.  

F

Net asset value 

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

Details are provided per investment pool, the NAV of which include the managers detailed in question A.  

Opportunities Pool 1. Had a net asset value of £158.6m in Q4 2023. 

Opportunities Pool 1. Had a net asset value of £162.0m in Q1 2024. 

Opportunities Pool 1. Had a net asset value of £150.3m in Q2 2024.   

Opportunities Pool 2. Had a net asset value of £333.1m in Q4 2023. 

Opportunities Pool 2. Had a net asset value of £338.5m in Q1 2024  

Opportunities Pool 2. Had a net asset value of £353.1m in Q2 2024  

Opportunities Pool 3. Had a net asset value of £160.1m in Q4 2023. 

Opportunities Pool 3. Had a net asset value of £160.3m in Q1 2024. 

Opportunities Pool 3. Had a net asset value of £218.5m in Q2 2024. 

G to K  

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

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.

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).

Prejudice / 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. ​