Companies Act 2014 section 1110H

Engagement policy - asset managers

Section 1110H requires relevant asset managers to develop and publicly disclose an engagement policy describing how they integrate shareholder engagement into their investment activities, and to report annually on how that policy has been implemented.

• Asset managers must develop and publicly disclose an engagement policy, or publicly explain why they have not done so
• The policy must cover how the manager monitors investee companies, exercises voting rights, cooperates with other shareholders, and manages conflicts of interest
• Annual implementation reports must include voting behaviour, significant votes, use of proxy advisors, and voting records at general meetings
• All public disclosures must be made available free of charge on the asset manager's website