Publication Scheme
As Border to Coast is wholly owned by our Partner Funds, we are subject to the Freedom of Information Act 2000. As such, we are obliged to make certain types of information regularly available. We have adopted the model publication scheme approved by the Information Commissioner’s Office to ensure we are meeting our obligations. Further information on the Act 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. All documents referenced can be found in our Document Library as “Publication Scheme Documents”. It also outlines how we keep the information up to date and any fees that may be charged for access to the information.
Our Document Library More about Freedom of Information requestsWho we are and what we do
Border to Coast Pensions Partnership is one of the largest pension pools in the UK. One of eight Local Government Pension Scheme (LGPS) pools, we are responsible for the investment of pension assets on behalf of our Partner Funds, our only customers and our only shareholders. In collaboration with our Partner Funds, we design, develop and manage funds which deliver the investment opportunities they need to support their strategic asset allocation decisions.
For detail on our management structure, please see our Governance Charter which is available in our Document Library.
Pages on Our Board and Our Executive provides detail of our Board of Directors and senior management team.
Details on each of our Partner Funds and a link to details of the Partner Fund Joint Committee, which consists of the chairs of each fund pensions committee, can be accessed via the Partner Fund page.
For details on how we make our decisions, we publish our Short Form Board and Board Audit Committee meeting Minutes as part of our publication scheme in the Document Library.
Border to Coast was incorporated on 31 May 2017 and is registered in England and Wales, with registration number 10795539. Our registered office address can be found at 5th Floor, Toronto Square, Leeds, LS1 2HJ. We are an FCA-authorised Alternative Investment Fund Manager (AIFM), reference number 800511.
What we spend and how we spend it
Border to Coast’s expenditure and financing is set out in our Annual Report. We aim to operate on a “not-for-profit” basis by recharging all costs (including corporation tax) to the Partner Funds. Our financial statements are published every year in our Annual Reports.
The EU Capital Requirements Directive requires firms to publish certain information relating to their risk management and capital adequacy, known as Pillar 3 disclosures. Our Pillar 3 report can be accessed in our Document Library. The Tax Strategy, which is approved by the Board, sets out our policy and approach to conducting both our UK corporate and our global investment tax affairs, is also available in our Document Library.
Border to Coast is also subject to the provisions of public procurement under the Public Contracts Regulations 2015 for the procurement of its suppliers.
What our priorities are and how we are doing
Our priorities, and how we are delivering them, can be found in our Annual Reports. Updates on our business activity and investment insights are also provided in the news section of our website.
Our annual Assessment of Value Reports offers a summary of whether our funds and services provide value to our customers, in line with FCA requirements.
As a responsible investor, we incorporate ESG factors into our investment analysis and decision making, enabling long-term sustainable performance for our Partner Funds. A summary of our activity and performance is provided in our range of Stewardship Reports. All reports are published in our Document Library.
How we make decisions
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. Further information about how our business is governed and those matters which are reserved for decision by our Partner Funds are set out in our Governance Charter – which can be found in the Document Library.
Our policies and procedures
Our published policies, including those regarding responsible investment, can be found in the Document Library.
Information governance statement
This policy describes how we manage the data we hold and sets out how we comply with our legal obligations in relation to data. It provides details of who has responsibility for data protection, freedom of information and environmental information requests. It explains how we protect personal data, what information can be accessed, how we make information available and the process we follow when a complaint is made about our response to a request for information.
Conduct risk statement
This policy describes how we identify and mitigate risks relation to conduct which may result in poor outcomes for our customers. It explains our regulatory compliance standards and the behaviours which are expected of all our colleagues.
Gifts and hospitality statement
This policy describes how the approach to providing and receiving gifts and hospitality, including roles and responsibilities relating to approving gifts and hospitality. It explains what gifts and hospitality may be accepted, and which must be refused, to ensure there are no conflicts between official duty and private interests.
Corporate social responsibility statement
Our policy on Corporate Social Responsibility is currently under review as the business continues to mature, having launched its first funds in July 2018. Our approach to Corporate Social Responsibility centres around five key pillars to our business, (1) Customer care, (2) Managing and respecting people, (3) Business processes, (4) the environment, and (5) our community. It will be closely monitored by our Board while under development.
Recruitment and selection statement
Our policy on recruitment and selection describes how we attract candidates for roles at Border to Coast, and the process for deciding who to appoint. While recruiting from a diverse pool of talent, the policy confirms that our recruitment is on the basis of the applicant’s abilities and individual merit, as measured against the criteria for the role. Qualifications, experience and skills will be assessed at the level that is relevant to the role. In addition, alignment to our values is considered when selecting candidates.
Diversity and inclusion
Our policy on diversity and inclusion sets out our commitment to a to a fair and non-discriminatory working environment and values the differences that a diverse workforce brings to the organisation. The policy is clear that we do not discriminate because of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex or sexual orientation. Our culture values meritocracy, openness, fairness and transparency.
Data retention statement
Our policy covers Border to Coast’s requirements for ensuring that all information held by the company and any relevant third parties is held, managed, and destroyed in line with all regulatory and corporate requirements.
Anti-financial crime statement
As a responsible business Border to Coast has an important role in society to deter, detect and report financial crime. The policy explains how Border to Coast protects the business, the customers and colleagues and takes proportionate steps to deter, detect, report any type of financial crime, including money laundering, fraud, sanctions evasion, market abuse, and bribery and corruption.
Lists and registers
How we respond to FoIA requests can be found in our Freedom of Information page, which can be accessed through the link at the bottom of the website. The information is published on a quarterly basis in January, April, July and October each year, starting from January 2022.
Details of our current board members can be found on the Our Board page of this website.
The services we offer
We design, develop, and operate collective investment vehicles to facilitate pooling for our Partner Funds. Border to Coast constructs funds which enable them to set their strategic asset allocations. We currently do not act on behalf of any customer outside of our LGPS Partner Funds.
We operate and publish information on two collective vehicles:
- Authorised Contractual Scheme: We publish investment information about holdings within our Authorised Contractual Scheme (“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.
- Private Markets: We publish holdings information 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.
We publish fund factsheets on a monthly basis for our ACS equity investments where funds have twelve months performance history. These are available in the Document Library or via the Our Investment Funds page. Our News and Insights page hosts information about future launches.
A core set of services supports these investment capabilities including:
- portfolio management: meeting the objectives and risk parameters set out in the funds’ prospectuses and associated documentation, and any Partner Fund agreements;
- asset management services, including arranging custody and administration of assets;
- facilitating asset servicing support;
- investment reporting and accounting information;
- supporting Partner Funds on RI and stewardship; and
- investment advice for Partner Funds.
Please contact us if any of the information sought is not provided.
Accessing and using information
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 Border to Coast Pensions Partnership Ltd 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 DPO@bordertocoast.org.uk.
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