The Environment Agency Pension Fund (EAPF)

Graham Cook serves as Chief Investment Officer and leads the internal investment team. The Pensions Committee, chaired by Robert Gould, provides fiduciary oversight and approves strategic asset allocation. Unlike pooled LGPS funds, EAPF retains direct investment discretion rather than delegating to a third-party investment pool, giving the internal team full control over manager selection and direct holdings.

EAPF formally applied for and received a dispensation from the UK government's LGPS pooling mandate, arguing that its existing in-house investment capability, specialised climate-aligned portfolio, and cost efficiencies justified remaining a standalone fund. The fund demonstrated that pooling would dilute its ability to maintain a bespoke low-carbon benchmark and would reduce its capacity to negotiate directly with private-market managers on impact terms.

EAPF targets a net-zero portfolio by 2045 with a commitment to halve emissions by 2030 from a 2019 baseline. The fund reports annually under TCFD guidelines and publicly discloses weighted average carbon intensity, fossil-fuel exposure percentages, and scenario analysis against 1.5°C, 2°C, and 3°C pathways. As of its 2023 report, portfolio carbon intensity had fallen 47% since 2019.

EAPF invests primarily through fund commitments to specialist managers in buyout, growth equity, and impact-themed strategies, with a small but growing co-investment capability for direct deals alongside established GPs. The fund avoids broad multi-strategy fund-of-funds in favour of focused commitments to managers who can demonstrate climate and ESG alignment, particularly in UK and European lower-middle-market buyouts.

The fund holds dedicated allocations to global timberland and agriculture through commitments including TIAA CREF Global Agriculture I and Lyme Forest Fund IV. These positions sit inside the broader real-assets bucket and serve dual purposes: inflation-linked return streams and biological carbon sequestration. EAPF views working farmland and managed forestry as structural hedges in a climate-transitioning portfolio.

The Environment Agency is the administering authority and primary employer sponsor of the fund, with Natural Resources Wales and Shared Services Connected Limited as participating employers. The fund operates at arm's length through an independent Pensions Committee, but the sponsorship link influences the fund's investment philosophy: its climate-first mandate aligns with the Environment Agency's core mission of environmental protection, flood defence, and climate adaptation.

Since 2020, EAPF has maintained a formal exclusion policy barring new investment in pure-play fossil-fuel extraction companies and thermal-coal mining. The policy does not constitute a blanket energy-sector divestment but sets de-minimis revenue thresholds for fossil-fuel activities, paired with active engagement requirements for any retained holdings in transition-critical sectors such as utilities and industrials.