Companies Act 2014 section 1110G

Engagement policy - institutional investors

Section 1110G requires relevant institutional investors to develop and publicly disclose an engagement policy describing how they engage with the companies they invest in, or explain why they have chosen not to do so.

• Relevant institutional investors must develop and publish an engagement policy covering shareholder engagement, monitoring of investee companies, voting behaviour, and conflict of interest management — or publicly explain why they have not done so
• Each year, investors must publicly report on how the policy has been implemented, including voting behaviour, significant votes, use of proxy advisors, and how votes were cast at general meetings
• Existing conflict of interest rules under EU directives on alternative investment fund managers, UCITS, and markets in financial instruments also apply to engagement activities
• All public disclosures required under this section must be made available free of charge on the institutional investor's website

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