Companies Act 2014 section 1110J

Transparency of asset managers

Section 1110J requires relevant asset managers who invest on behalf of institutional investors to make annual disclosures about how their investment strategy aligns with the arrangement and contributes to the medium to long-term performance of the investor's assets.

• Relevant asset managers must annually disclose to institutional investors how their investment strategy and its implementation comply with the arrangement and contribute to the medium to long-term performance of the investor's assets or funds
• Disclosures must cover key material medium to long-term investment risks, portfolio composition, turnover and turnover costs, the use of proxy advisors, and the asset manager's securities lending policy as it relates to engagement activities
• Asset managers must also disclose whether investment decisions are based on medium to long-term performance of investee companies (including non-financial performance) and any conflicts of interest arising from engagement activities
• If the required information is already publicly available, the asset manager is not required to provide it directly to the institutional investor

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