Brunel Pension Partnership Limited is a public body for the purposes of the Freedom of Information Act 2000 and the Environmental Information Regulations 2004. As such, we are required to adopt a publication scheme, under which we regularly publish certain types of information.

In order to comply with that obligation, we have adopted the model publication scheme approved by the Information Commissioner’s Office, a copy of which can be found here.

This page sets out the information which we are required to publish in accordance with the model scheme.

Who we are and what we do

Brunel Pension Partnership Limited (Brunel) is a company limited by shares, registered in England and Wales (company no. 10429110).

Brunel was formed as part of the LGPS pooling initiative, to act as the pool operator for the Brunel Pension Partnership pool, the members of which are the pension funds of the county councils of Avon, Buckinghamshire, Cornwall, Devon, Dorset, Gloucestershire, Oxfordshire, Somerset, Wiltshire, and the Environment Agency. We act as the discretionary investment manager to our Clients and are authorised by the FCA (reference no. 790168) for the conduct of investment business. Our FCA registration can be found here.

Brunel is based in Bristol. Its registered office address is at 5th Floor, 101 Victoria Street, Bristol, United Kingdom, BS1 6PU.

In terms of governance, we have a board comprising three executives and five non-executives, including a non-executive chair. Details of the board can be found here. We are owned by our Clients in equal shares, each Client holding two shares in our issued share capital.

If you require more detail, please contact us on [email protected]

For Freedom of Information requests, please email [email protected]
(Please note, however, that lists of our holdings are already published on our website, and that we will reply to FOIs requesting names of holdings or related information published on that page by pointing the requester back to Holdings Records.)

What we spend and how we spend it

Our annual budget is funded by our shareholders. We are non-profit making and any surplus generated in a financial year is either returned to shareholders or retained with their consent in order to meet future expenditure.

We are a body subject to procurement regulations. When we enter into contracts, we comply with the Public Contracts Regulations (PCR) if applicable.

What our priorities are and how we are doing

Our priorities are to achieve greater consistency in implementing our Clients’ asset allocation and make savings of £550m on behalf of the Clients by 2036. By the end of the calendar year to September 2018, we had implemented six portfolios with total estimated savings for actual allocations of circa £203m to 2036.

How we make decisions

Most of the day-to-day decisions affecting Brunel are made by the Board. However, certain decisions have been reserved to our shareholders, which therefore require their prior approval before they can be implemented.

More broadly, Brunel’s activities are subject to scrutiny and oversight by the Brunel Oversight Board (BOB), which comprises representatives of our Clients, typically members of their respective Pensions Committees. In addition, our Client Group (CG), comprising officers from our Clients’ pension funds, provide BOB with advice on pensions and investment matters. Neither CG nor BOB are decision-making bodies.

Our policies and procedures

Brunel Asset Management Accord 

Brunel Responsible Investment Policy & approach

Brunel Responsible Stewardship Policy 

Brunel Climate Change Policy & approach

Brunel Conflicts of Interest statement

Brunel Best Execution Policy

Brunel Pillar 3 Disclosure

Annual Public Disclosure 2023

Lists and registers

Find details of our officers here.

Our shareholders are:

  • Avon Pension Fund, Bath and North East Somerset Council, Lewis House, Manvers Street, Bath BA1 1JG
  • Buckinghamshire County Council, Finance, County Hall, Walton Street, Aylesbury, Buckinghamshire HP20 1UD
  • Cornwall Council Pension Fund, Cornwall County Council, New County Hall, Treyew Road, Truro, Cornwall TR1 3AY
  • Devon Pension Fund, Devon County Council, County Hall, Topsham Road, Exeter, Devon EX2 4QD
  • Dorset Pension Fund, Dorset Council, County Hall, Colliton Park, Dorchester, England, DT1 1XJ
  • Environment Agency Pension Fund, Horizon House, Deanery Road Bristol BS1 5AH
  • Gloucestershire Pension Fund, Gloucestershire County Council, LGPS Pension Finance, Shire Hall, Westgate Street, Gloucester GL1 2TG
  • Oxfordshire Pension Fund, Oxfordshire County Council, County Hall, New Road, Oxford, Oxfordshire OX1 1ND
  • Somerset Pension Fund, Somerset County Council, County Hall, Somerset County Council, Taunton, Somerset, United Kingdom TA1 4DY
  • Wiltshire Pension Fund, Wiltshire County Council, County Hall, Trowbridge, Wiltshire BA14 8JD

Our statutory books are available for inspection at our registered office.

The services we offer


We act as the discretionary investment manager of our 10 Clients in accordance with our duties and obligations under applicable regulations. We do not act for any client that is not the administering authority of a UK local government pension scheme and are unable to offer services to any person that is not a professional investor (as defined in the FCA Handbook).

Under applicable regulations, each of our Clients retains responsibility for how they allocate assets within the LGPS funds that they administer. Once they have made their allocations, we offer them a broad range of portfolio options, with the aim of allowing them the flexibility to meet their own investment strategy needs, whilst equipping us to manage risk and generate sustainable, long-term returns. These options currently comprise 24 portfolios across three strategies, namely active equities, passive equities and private markets.

We deliver these strategies in the following ways:

  • Active equity strategy – this is delivered through the TM Brunel Pension Partnership Authorised Contractual Scheme (ACS), which is a form of collective investment scheme approved by the FCA. The ACS is operated for regulatory purposes by Tutman. Tutman have appointed Brunel to act as the investment manager of the ACS and Brunel, in turn, appoints sub-investment managers or invests in regulated collective funds in respect of each sub-fund. The ACS was launched in 2018 and currently offers Clients seven portfolios:
      • UK Equity
      • Low Volatility Global Equity
      • Emerging Markets Equity
      • High Alpha Global Equity
      • Diversifying Returns
      • Smaller Companies Equities
      • Global Sustainable Equity

    The ACS prospectus is available on request.


    • Passive equity strategy – this is delivered through the appointment of Legal & General Investment Management (LGIM) on behalf of our Clients. LGIM are a leading investment management company and were appointed in 2018 as a result of a procurement exercise through the National LGPS Framework operated by Norfolk County Council.
    • Private markets – this is delivered through the selection of leading private markets fund managers on behalf of our Clients. Our Clients then directly invest with the selected fund manager.

    Details of our portfolios can be found here.

    Responsible Investment

    As stated in our Values, at Brunel we believe in making long-term, sustainable investments supported by robust and transparent processes, in accordance with our Responsible Investment Policy and Responsible Stewardship Policy. In collaboration with all our stakeholders we are forging better futures by investing for a world worth living in.

    Our voting records 

    Our engagement records 

    Our policy advocacy 

    Find our media releases and more on our google drive.

    Our most recent news stories.