To the Requester

By email only to: [1][FOI #31615 email]

 

Tçnâ koe,

 

Official information request: RFS 4262550

 

Thank you for your information request to the Far North District Council
(‘Council’), received 16 July 2025. Your request is being considered in
accordance with the provisions of the Local Government Official
Information and Meetings Act 1987 (the ‘LGOIMA’). A response will be
provided to you as soon as reasonably practicable, and no later than 20
working days (as defined in the LGOIMA) after the day on which the request
is received.

 

Please quote our reference RFS 4262550 for any further enquiries in
relation to this request.

 

Thank you for your enquiry.

 

Ngâ mihi,

 
Te Kaunihera o Te Hiku o te Ika  |  Far
North District Council
----------------------------------------

Pokapû Kôrero 24-hâora  |  24-hour
Contact Centre 0800 920 029
[2][IMG] [3][IMG][4]  [5][IMG][6] 
[7][IMG][8]  [9][IMG]

 

References

Visible links
1. mailto:[FOI #31615 email]
2. https://www.fndc.govt.nz/home
3. https://www.facebook.com/FarNorthDistric...
4. FNDC Facebook
https://www.facebook.com/FarNorthDistric...
5. https://nz.linkedin.com/company/far-nort...
6. FNDC LinkedIn
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7. https://www.youtube.com/channel/UCRbGkKa...
8. FNDC YouTube channel
https://www.youtube.com/channel/UCRbGkKa...
9. https://www.instagram.com/farnorth_dc/

Tēnā koe,

 

I am on leave and will get back to you on my return to the office on
Wednesday 20 August 2025.

 

However, if your query is urgent, please contact 0800 920 029.

 

Ngā mihi,

Erica Cooney

 

 

 

 

 

 

 

By email:

[1][email address] (RFS 4262544)

[2][FOI #31615 email] (RFS 4262550)

 

Dear Mr Riley

Official information request: RFS 4262544/ 4262550 - Official Information
request - Information regarding transactions between Ngāpuhi Investment
Fund Ltd and Far North Holdings Limited

We refer to your various requests to Far North Holdings Limited, dated 16
July 2025, for information regarding transactions between Ngāpuhi
Investment Fund Ltd and FNHL (RFS 4262544/ 4262550) attached.  During the
Elections period Council has been receiving a number of complex
information requests which is resulting in some delays in responding
within statutory timeframes.  However, we have reallocated some resource
within our Team to address this and we do apologise for the delay in
responding to you.

As you two requests dated 16 July 2025 are related to the same or similar
subject matter, they have been processed together as one request in
accordance with the Local Government Official Information and Meetings Act
1987 and Council’s responses are as follows:

RFS 4262544 - Information regarding transactions between Ngāpuhi
Investment Fund Ltd and Far North Holdings Limited

The following records for the period 1 January 2022 to 16 July 2025:

1. Board Minutes and Papers: The full, unredacted board minutes, agendas,
and all associated reports or papers for both the Far North Holdings Ltd
board and the Far North Housing Ltd board for all meetings where the
establishment, negotiation, approval, or execution of the 450 Kamo Road LP
and 56 Tawanui Road LP joint ventures with Ngāpuhi Investment Fund Ltd
were discussed.

2. Directors' Interests Register: A complete copy of the FNHL Directors'
Interests Register.

3. Conflict of Interest Management: All records demonstrating how the
conflict of interest arising from Director Sarah Jane Petersen's
concurrent directorship on the board of Ngāpuhi Investment Fund Ltd was
managed in relation to these transactions. This includes, but is not
limited to, any formal declarations of interest recorded in the minutes,
records of her recusal from discussions and voting, and any legal or other
advice sought or received by the board on this matter.

Please find attached the following information provided by FNHL staff:

o The current FNHL Directors' Interests Register dated 15 May 2025
o FNHL’s 2022 Policy on Conflicts of Interest
o All Board Minutes for the period 1 January 2022 to 16 July 2025 in
which the Board considered the establishment, negotiation, approval,
or execution of the 450 Kamo Road LP and 56 Tawanui Road LP joint
ventures with Ngāpuhi Investment Fund.  Items in the Minutes which are
outside the scope of this request have been redacted as such.  The
Minutes that are disclosed relate to the 450 Kamo Road LP and 56
Tawanui Road LP transactions.  There are some minor redactions around
sale price and valuations which are redacted and withheld under
section 7(2)(h) LGOIMA to avoid prejudice or disadvantage, to the
commercial activities of FNHL.

The Minutes disclosed also provide details of how any conflicts of
interest arising for Director Sarah Jane Petersen were managed in this
context.

To undertake a comprehensive search of all potential records held by FNHL
would involve a resource intensive manual search exercise which would
likely involve substantial collation (a ground for refusal under section
17 of the LGLIMA).  In the interests of providing, you with the key
information relevant to your request the attached Minutes are provided. 
If having reviewed the material disclosed, you have additional specific
questions arising, please feel free to submit a further request that we
will endeavour to deal with as efficiently as possible.

 

RFS 4262550 - Information regarding transactions between Ngāpuhi
Investment Fund Ltd and Far North Holdings Limited

The following records for the period 1 January 2022 to 16 July 2025:

1. Board Minutes and Papers: The full, unredacted board minutes, agendas,
and all associated reports or papers for both the Far North Holdings Ltd
board and the Far North Housing Ltd board for all meetings where the
establishment, negotiation, approval, or execution of the sale or transfer
of interests in 69 Marsden Road, Paihia, and 29 Hokianga Harbour Drive,
Opononi to Ngāpuhi Investment Fund Ltd were discussed.

2. Conflict of Interest Management: All records demonstrating how the
conflict of interest arising from Director Sarah Jane Petersen's
concurrent directorship on the board of Ngāpuhi Investment Fund Ltd was
managed in relation to these transactions. This includes, but is not
limited to, any formal declarations of interest recorded in the minutes,
records of her recusal from discussions and voting, and any legal or other
advice sought or received by the board on this matter.

Please find attached the following information provided by FNHL staff:

o The current FNHL Directors' Interests Register dated 15 May 2025
o FNHL’s 2022 Policy on Conflicts of Interest
o All Board Minutes for the period 1 January 2022 to 16 July 2025 in
which the Board considered the establishment, negotiation, approval,
or execution of the sale or transfer of interests in 69 Marsden Road,
Paihia, and 29 Hokianga Harbour Drive, Opononi to Ngāpuhi Investment
Fund Ltd.  Items in the Minutes which are outside the scope of this
request have been redacted as such.  The Minutes that are disclosed
relate to the 69 Marsden Road, Paihia, and 29 Hokianga Harbour Drive,
Opononi transactions.  There are some minor redactions around sale
price and valuations which are redacted and withheld under section
7(2)(h) LGOIMA to avoid prejudice or disadvantage, to the commercial
activities of FNHL.

The Minutes disclosed also provide details of how any conflicts of
interest arising for Director Sarah Jane Petersen were managed in this
context.

To undertake a comprehensive search of all potential records held by FNHL
would involve a resource intensive manual search exercise which would
likely involve substantial collation (a ground for refusal under section
17 of the LGOIMA).  In the interests of providing, you with the key
information relevant to your request the attached Minutes are provided. 
If having reviewed the material disclosed, you have additional specific
questions arising, please feel free to submit a further request that we
will endeavour to deal with as efficiently as possible.

Again, we do apologise for the delay in responding to your requests.  We
are conscious that there are other requests from you that remain
outstanding and can assure you that we are working to provide responses as
soon as possible.  We hope this information is of some assistance in
responding to your request.  You have the right to seek a review of this
decision by the Ombudsman. Information about how to make a complaint is
available at [3]www.ombudsman.parliament.nz  or Freephone 0800 802 602.

Kind regards

 

LGOIMA Team

   
 
 
 
Te Kaunihera o Te Hiku o te Ika  |  Far
North District Council
----------------------------------------

Pokapū Kōrero 24-hāora  |  24-hour
Contact Centre 0800 920 029
[4][IMG] [5][IMG][6]  [7][IMG][8] 
[9][IMG][10]  [11][IMG]

 

 

References

Visible links
1. mailto:[email address]
2. mailto:[FOI #31615 email]
3. http://www.ombudsman.parliament.nz/
4. https://www.fndc.govt.nz/home
5. https://www.facebook.com/FarNorthDistric...
6. https://www.facebook.com/FarNorthDistric...
7. https://nz.linkedin.com/company/far-nort...
8. https://nz.linkedin.com/company/far-nort...
9. https://www.youtube.com/channel/UCRbGkKa...
10. https://www.youtube.com/channel/UCRbGkKa...
11. https://www.instagram.com/farnorth_dc/

To the requester

By email only to: [1][FOI #31615 email]

 

 

Tçnâ koe,

 

Official information request: RFS 4268722

 

Thank you for your information request to the Far North District Council
(‘Council’), received 16 July 2025. Your request is being considered in
accordance with the provisions of the Local Government Official
Information and Meetings Act 1987 (the ‘LGOIMA’). A response will be
provided to you as soon as reasonably practicable, and no later than 20
working days (as defined in the LGOIMA) after the day on which the request
is received.

 

Please quote our reference RFS 4268722 for any further enquiries in
relation to this request.

 

Thank you for your enquiry.

 

Ngâ mihi,

 

LGOIMA Team

   
 
 
 
Te Kaunihera o Te Hiku o te Ika  |  Far
North District Council
----------------------------------------

Pokapû Kôrero 24-hâora  |  24-hour
Contact Centre 0800 920 029
[2][IMG] [3][IMG][4]  [5][IMG][6] 
[7][IMG][8]  [9][IMG]

 

[10]Local Government Elections 2025 - click to find out more

[11]Signature 365 Pixel

 

References

Visible links
1. mailto:[FOI #31615 email]
2. https://www.fndc.govt.nz/home
3. https://www.facebook.com/FarNorthDistric...
4. FNDC Facebook
https://www.facebook.com/FarNorthDistric...
5. https://nz.linkedin.com/company/far-nort...
6. FNDC LinkedIn
https://nz.linkedin.com/company/far-nort...
7. https://www.youtube.com/channel/UCRbGkKa...
8. FNDC YouTube channel
https://www.youtube.com/channel/UCRbGkKa...
9. https://www.instagram.com/farnorth_dc/
10. https://campaigns.signature365.com/au-HF...

By email: [1][FOI #31615 email]

 

Dear Mr Riley

 

Official information request RFS 4268722

 

We refer to your follow up request dated 8 September 2025, for additional
information regarding transactions between Ngāpuhi Investment Fund Ltd and
FNHL. 

 

Your request has been processed in accordance with the Local Government
Official Information and Meetings Act 1987 and Council’s response is as
follows:

1. Was an overall discount provided to Tupu Tonu on the portfolio of
properties that included the interests in 450 Kamo Road LP, 69 Marsden
Road, and 29 Hokianga Harbour Drive?

The commercial negotiations between FNHL and Tupu Tonu initially
contemplated that a discount would be applied to the transactions, subject
to certain requirements being met. However, because the relevant
requirements were not met the discount was not in fact applied.

2. If a discount was provided, please confirm whether the entire financial
value of this discount was applied solely to the sale price of the 69
Marsden Road, Paihia property or another specific property.

N/A – no discount was applied

3. If a discount was provided and not evenly applied to 450 Kamo Road LP,
was this done to ensure that Far North Housing Ltd did not have to record
a loss on the sale of its interest in the 450 Kamo Road LP?

N/A – no discount was applied

4. If the discount was consolidated to a specific property, why was that
property chosen to absorb the entire discount?

N/A – no discount was applied

 

Kind regards

 

LGOIMA Team

   
 
 
 
Te Kaunihera o Te Hiku o te Ika  |  Far
North District Council
----------------------------------------

Pokapū Kōrero 24-hāora  |  24-hour
Contact Centre 0800 920 029
[2][IMG] [3][IMG][4]  [5][IMG][6] 
[7][IMG][8]  [9][IMG]

-----Original Message-----
From: Joshua Riley <[10][FOI #31615 email]>
Sent: Monday, 8 September 2025 4:58 pm
To: Rebecca Rowsell <[11][email address]>
Subject: Re: Official information request: RFS 4262544/ 4262550 - Official
Information request - Information regarding transactions between Ngāpuhi
Investment Fund Ltd and Far North Holdings Lhy

CAUTION: This email originated from outside Far North District Council.
Do not click links or open attachments unless you recognise the sender and
know the content is safe.

Dear LGOIMA Team,

Thank you for your response and the documents provided in relation to my
requests RFS 4262544 and RFS 4262550.

The information you have provided has prompted a need for clarification on
two specific points regarding the portfolio of properties sold to Ngāpuhi
Investment Fund Ltd (Tupu Tonu).

As you will recall, a resolution dated 12 June 2023, provided in your
response, refers to a potential discount: "...if accepted a discount would
be applied to the total sales value of the four properties/interests..."

Further, an email from legal counsel dated 13 June 2023 discusses the
structuring of this discount. It states: "...it is probably logical that
Housing is not asked to bear any (and certainly not the whole) of the
discount given it has purchased recently from Holdings at the same value
so would immediately be recording a loss in respect of that asset."

To clarify how this was executed, I request the following information:

Confirmation of Discount:
1. Was an overall discount provided to Tupu Tonu on the portfolio of
properties that included the interests in 450 Kamo Road LP, 69 Marsden
Road, and 29 Hokianga Harbour Drive?

Allocation of Discount:
1. If a discount was provided, please confirm whether the entire financial
value of this discount was applied solely to the sale price of the 69
Marsden Road, Paihia property or another specific property.
2. If a discount was provided and not evenly applied to 450 Kamo Road LP,
was this done to ensure that Far North Housing Ltd did not have to record
a loss on the sale of its interest in the 450 Kamo Road LP?
3. If the discount was consolidated to a specific property, why was that
property chosen to absorb the entire discount?

-----Original Message-----

By email:

[1][email address] (RFS 4262544)

[2][FOI #31615 email] (RFS 4262550)

Dear Mr Riley

Official information request: RFS 4262544/ 4262550 - Official Information
request - Information regarding transactions between Ngāpuhi Investment
Fund Ltd and Far North Holdings Limited

We refer to your various requests to Far North Holdings Limited, dated 16
July 2025, for information regarding transactions between Ngāpuhi
Investment Fund Ltd and FNHL (RFS 4262544/ 4262550) attached. During the
Elections period Council has been receiving a number of complex
information requests which is resulting in some delays in responding
within statutory timeframes. However, we have reallocated some resource
within our Team to address this and we do apologise for the delay in
responding to you.

As you two requests dated 16 July 2025 are related to the same or similar
subject matter, they have been processed together as one request in
accordance with the Local Government Official Information and Meetings Act
1987 and Council’s responses are as follows:

RFS 4262544 - Information regarding transactions between Ngāpuhi
Investment Fund Ltd and Far North Holdings Limited

The following records for the period 1 January 2022 to 16 July 2025:

1. Board Minutes and Papers: The full, unredacted board minutes, agendas,
and all associated reports or papers for both the Far North Holdings Ltd
board and the Far North Housing Ltd board for all meetings where the
establishment, negotiation, approval, or execution of the 450 Kamo Road LP
and 56 Tawanui Road LP joint ventures with Ngāpuhi Investment Fund Ltd
were discussed.

2. Directors' Interests Register: A complete copy of the FNHL Directors'
Interests Register.

3. Conflict of Interest Management: All records demonstrating how the
conflict of interest arising from Director Sarah Jane Petersen's
concurrent directorship on the board of Ngāpuhi Investment Fund Ltd was
managed in relation to these transactions. This includes, but is not
limited to, any formal declarations of interest recorded in the minutes,
records of her recusal from discussions and voting, and any legal or other
advice sought or received by the board on this matter.

Please find attached the following information provided by FNHL staff:

o The current FNHL Directors' Interests Register dated 15 May 2025 o
FNHL’s 2022 Policy on Conflicts of Interest o All Board Minutes for the
period 1 January 2022 to 16 July 2025 in which the Board considered the
establishment, negotiation, approval, or execution of the 450 Kamo Road LP
and 56 Tawanui Road LP joint ventures with Ngāpuhi Investment Fund. Items
in the Minutes which are outside the scope of this request have been
redacted as such. The Minutes that are disclosed relate to the 450 Kamo
Road LP and 56 Tawanui Road LP transactions. There are some minor
redactions around sale price and valuations which are redacted and
withheld under section 7(2)(h) LGOIMA to avoid prejudice or disadvantage,
to the commercial activities of FNHL.

The Minutes disclosed also provide details of how any conflicts of
interest arising for Director Sarah Jane Petersen were managed in this
context.

To undertake a comprehensive search of all potential records held by FNHL
would involve a resource intensive manual search exercise which would
likely involve substantial collation (a ground for refusal under section
17 of the LGLIMA). In the interests of providing, you with the key
information relevant to your request the attached Minutes are provided.
If having reviewed the material disclosed, you have additional specific
questions arising, please feel free to submit a further request that we
will endeavour to deal with as efficiently as possible.

RFS 4262550 - Information regarding transactions between Ngāpuhi
Investment Fund Ltd and Far North Holdings Limited

The following records for the period 1 January 2022 to 16 July 2025:

1. Board Minutes and Papers: The full, unredacted board minutes, agendas,
and all associated reports or papers for both the Far North Holdings Ltd
board and the Far North Housing Ltd board for all meetings where the
establishment, negotiation, approval, or execution of the sale or transfer
of interests in 69 Marsden Road, Paihia, and 29 Hokianga Harbour Drive,
Opononi to Ngāpuhi Investment Fund Ltd were discussed.

2. Conflict of Interest Management: All records demonstrating how the
conflict of interest arising from Director Sarah Jane Petersen's
concurrent directorship on the board of Ngāpuhi Investment Fund Ltd was
managed in relation to these transactions. This includes, but is not
limited to, any formal declarations of interest recorded in the minutes,
records of her recusal from discussions and voting, and any legal or other
advice sought or received by the board on this matter.

Please find attached the following information provided by FNHL staff:

o The current FNHL Directors' Interests Register dated 15 May 2025 o
FNHL’s 2022 Policy on Conflicts of Interest o All Board Minutes for the
period 1 January 2022 to 16 July 2025 in which the Board considered the
establishment, negotiation, approval, or execution of the sale or transfer
of interests in 69 Marsden Road, Paihia, and 29 Hokianga Harbour Drive,
Opononi to Ngāpuhi Investment Fund Ltd. Items in the Minutes which are
outside the scope of this request have been redacted as such. The Minutes
that are disclosed relate to the 69 Marsden Road, Paihia, and 29 Hokianga
Harbour Drive, Opononi transactions. There are some minor redactions
around sale price and valuations which are redacted and withheld under
section
7(2)(h) LGOIMA to avoid prejudice or disadvantage, to the commercial
activities of FNHL.

The Minutes disclosed also provide details of how any conflicts of
interest arising for Director Sarah Jane Petersen were managed in this
context.

To undertake a comprehensive search of all potential records held by FNHL
would involve a resource intensive manual search exercise which would
likely involve substantial collation (a ground for refusal under section
17 of the LGOIMA). In the interests of providing, you with the key
information relevant to your request the attached Minutes are provided.
If having reviewed the material disclosed, you have additional specific
questions arising, please feel free to submit a further request that we
will endeavour to deal with as efficiently as possible.

Again, we do apologise for the delay in responding to your requests. We
are conscious that there are other requests from you that remain
outstanding and can assure you that we are working to provide responses as
soon as possible. We hope this information is of some assistance in
responding to your request. You have the right to seek a review of this
decision by the Ombudsman. Information about how to make a complaint is
available at [3][12]http://www.ombudsman.parliament.nz/ or Freephone 0800
802 602.

Kind regards

LGOIMA Team

Te Kaunihera o Te Hiku o te Ika | Far North District Council
----------------------------------------

Pokapū Kōrero 24-hāora | 24-hour
Contact Centre 0800 920 029
[4][IMG] [5][IMG][6] [7][IMG][8]
[9][IMG][10] [11][IMG]

References

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2. [14]mailto:[FOI #31615 email]
3. [15]http://www.ombudsman.parliament.nz/
4. [16]https://www.fndc.govt.nz/home
5. [17]https://www.facebook.com/FarNorthDistric...
6. [18]https://www.facebook.com/FarNorthDistric...
7. [19]https://nz.linkedin.com/company/far-nort...
8. [20]https://nz.linkedin.com/company/far-nort...
9. [21]https://www.youtube.com/channel/UCRbGkKa...
10. [22]https://www.youtube.com/channel/UCRbGkKa...
11. [23]https://www.instagram.com/farnorth_dc/

-------------------------------------------------------------------
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[24][FOI #31615 email]

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