# The Environment Agency Pension Fund (EAPF)

The Environment Agency Pension Fund (EAPF) is a Pension Fund based in Bristol, United Kingdom.

## Overview

- **Organization type:** Pension Fund
- **Headquarters:** Bristol, United Kingdom
- **Region:** Europe
- **Address:** Bristol, United Kingdom
- **Founded:** 2006
- **Assets under management:** $5B–$10B (Altss estimate)
- **Website:** eapf.org.uk

## Regulatory record

- **Reports private funds:** No

## About

The Environment Agency Pension Fund was established in 2006 as the Local Government Pension Scheme (LGPS) fund for employees of the Environment Agency, Natural Resources Wales, and Shared Services Connected Limited. It operates as a funded, defined-benefit scheme overseen by a Pensions Committee chaired by Robert Gould. The fund's sponsoring body is a UK non-departmental public body, giving EAPF a governance structure distinct from council-administered LGPS pools — it sits inside a single-employer framework with tightly controlled trustee representation. The fund's strategy is built around a chunky allocation to real assets and long-return-seeking alternatives, including direct property, renewable infrastructure, timberland, agriculture, and impact-themed private equity. Confirmed holdings include Schroders Greencoat Renewable Income, the Bridges Property Alternative Fund III — a mix spanning UK commercial property, solar, wind assets, global farmland and UK social-impact development. On the private-equity side, EAPF favors buyout strategies with a tilt toward UK and European managers who can demonstrate measurable environmental or social co-benefits, avoiding the pure-alpha fund-of-funds model in favor of curated fund commitments and direct co-investments where scale permits. EAPF manages roughly £4.4 billion in assets as of its most recent annual report. The in-house investment team, led by CIO Graham Cook, executes a climate-first asset allocation that anchors on a 1.5-degree pathway — the fund published a detailed TCFD-aligned climate risk report in 2021 and has committed to net-zero portfolio emissions by 2045. EAPF is a founding member of the Institutional Investors Group on Climate Change (IIGCC) and was an early signatory to the Paris Aligned Investment Initiative, giving it outsized influence in climate-finance circles relative to its actual AUM. In 2020, the fund codified a formal responsible investment policy that screens out pure-play fossil-fuel extraction and sets engagement thresholds for high-impact sectors. What separates EAPF structurally from peer LGPS funds is its refusal to pool assets into the larger Border to Coast or Brunel pooling structures. The fund opted instead to remain a standalone, self-directed investor, retaining full discretion over manager selection, direct-holding negotiation, and activist engagement — a choice that preserves its ability to move fast on niche private-market allocations and maintain a portfolio carbon-intensity profile that would be diluted inside a pooled fund. The succession risk is real: Cook has been the architect of this posture for over a decade, and the fund's strategy is unusually personality-dependent for a public-sector vehicle.

## Sectors

- Real Estate
- Infrastructure
- Private Equity
- Energy Transition & Renewables
- AgriTech & FoodTech
- Private Credit

## People

- Graham Cook — Chief Investment Officer
- Robert Gould — Chair of the Pensions Committee

## Questions

### Who runs investment decisions at EAPF, and what is the governance structure?

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.

### What is EAPF's specific climate target, and how is it measured?

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.

### Does EAPF invest in private equity funds, direct deals, or both?

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.

### How does EAPF gain exposure to natural capital and agriculture?

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.

### What is EAPF's relationship with its sponsoring employer, the Environment Agency?

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.

### Which sectors does EAPF explicitly exclude from its portfolio?

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.

## Related profiles

- [Caisse de Pensions de la Fonction Publique du Canton de Neuchâtel](https://altss.com/profile/caisse-de-pensions-de-la-fonction-publique-du-canton-de-neuch-tel)
- [City of Milwaukee Employes' Retirement System](https://altss.com/profile/city-of-milwaukee-employes-retirement-system-cmers)

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Last updated: 2026-06-03T20:00:00.000Z

Canonical page: https://altss.com/profile/the-environment-agency-pension-fund-eapf

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