SHAREHOLDER RIGHTS DIRECTIVE II (“SRD II”)
Sandbar Asset Management LLP (“Sandbar”)
SRD II aims to improve stewardship and corporate governance by firms (including a full scope Alternative Investment Fund Manager) that invest in shares traded on a regulated market in the EEA as well as ‘comparable’ markets situated outside of the EEA. Under FCA COBS 2.2.B.5R, we are required to:
- develop and publicly disclose an engagement policy that meets the requirements of COBS 2.2B.6R; and
- publicly disclose on an annual basis how our engagement policy has been implemented in a way that meets the requirements of COBS 2.2B.7R; or
- publicly disclose why we have chosen not to comply.
The engagement policy must describe how a firm:
- integrates shareholder engagement in its investment strategy;
monitors investee companies on relevant matters, including;
- financial and non-financial performance and risk;
- capital structure; and
- social and environmental impact and corporate governance;
- conducts dialogues with investee companies;
- exercises voting rights and other rights attached to shares;
- co-operates with other shareholders;
- communicates with relevant stakeholders of the investee companies; and
- manages actual and potential conflicts of interest in relation to the firm’s engagement.
On an annual basis, the firm must disclose a general description of voting behavior, an explanation of the most significant votes and reporting on the use of services of proxy advisors. The disclosure must include how votes have been cast unless they are insignificant due to the subject matter of the vote or to the size of the holding in the company.
Sandbar is currently considering whether or not an engagement policy will apply based on the investment strategies pursued by the fund(s) to which we provide investment services.