Access to and copies of alternative investment portfolio records
FOI reference - FOI-400
Date - 4 August 2025
Request
You have requested the following information:
'Pursuant to the Freedom of Information Act 2000 (“FOIA"), I request access to and copies of alternative investment portfolio records specifically for close-ended:
- Private equity funds
- Debt funds
- Real estate funds
- Infrastructure funds
- Fund of funds
- Hedge funds
(“the Records”) and details of:
- Committed capital
- Invested capital
- Distribution
- Market value
- Net IRR
- MOIC/TVPI
On an individual fund by fund basis with aggregated values since inception for from January 1st, 2024 to today ("the Information").
This request is ongoing, seeking copies of (or access to) all Records as they are filed with Trafalgar House Pension Trust/ updates to the Information as they are filed with the Trafalgar House Pension Trust. I am further requesting that the Records / Information be provided to me in PDF or Excel format, if not maintained on computer files, in the same format as they are / it is currently maintained at the Trafalgar House Pension Trust.'
Response
I confirm that we hold some of the information you have requested. However, this information is exempt from disclosure.
Section 44(1)(a) – restricted information under s82 PA04
As we have been given strong powers to demand documents and other information from trustees, employers and others, those powers are also balanced by restrictions on how we disclose the information provided to us. The type of information you have requested would be ‘restricted information’. Restricted information is defined at section 82(4) of the Pensions Act 2004 (PA04) as:
‘…information obtained by the Regulator in the exercise of its functions which relates to the business or other affairs of any person’.
Under section 82(5) of the PA04 it is a criminal offence to disclose such information except as permitted under that Act.
Whilst the FoIA is based on the presumption of releasing information, section 44(1)(a) of the FoIA provides an absolute exemption to the requirement to disclose any information if its disclosure is prohibited by or under any enactment. In this case, section 82 of the PA04 prohibits disclosure and we are unable to disclose the requested information. This exemption is absolute and does not require a public interest assessment be undertaken.
Duty to provide further assistance
If you haven’t already, we recommend visiting the Trafalgar House Pension Trust website for more information.