Background
On 20 March 2020, European Union (Shareholders’ Rights) Regulations 2020 (S.I. No. 81/2020) transposed into Irish law EU Directive 2017/828 (SRDII) that amended EU Directive 2007/36 (SRD I). The Shareholders’ Rights Regulations 2020 require asset management companies to develop and publicly disclose an engagement policy that describes how they integrate shareholder engagement in their investment strategy. WWAMD has established this policy in compliance with SRDII requirements. W&W Asset Management Dublin DAC (the “Firm”) is authorised by the Central Bank as an Alternative Investment Fund Manager pursuant to the AIFMD Regulations and as a UCITS Manager pursuant to the UCITS Regulations. The Firm is deemed to be an “asset manager” under SRDII. Investments made in companies which have a registered office in an EU/EEA member state and whose shares are admitted to trading on a regulated market in an EU/EEA member state are in scope for this regulation.
Shareholder Engagement Policy
Under Article 3g of SRD II, asset managers are required to develop and publicly disclose an engagement policy that describes how they integrate shareholder engagement in their investment strategy. This policy should describe how the Firm monitors investee companies on relevant matters including:
- strategy;
- financial and non-financial performance and risk;
- capital structure;
- social and environmental impact and corporate governance;
- conducting dialogue with investee companies;
- exercise of voting rights attached to shares;
- cooperate with other shareholders;
- communicate with relevant stakeholders of the investee companies;
- manage actual and potential conflicts of interests in relation to their engagement.
On an annual basis, each Investment Manager will publicly disclose how their engagement policy has been implemented. Each relevant Investment Manager will make this information available free of charge on their website.
Social and environmental impact and corporate governance
The Firm has adopted an Environmental, Social and Governance Policy in order to drive forward continued development in the area of sustainability, to keep up with the current political, social and regulatory developments, and to reduce reputational risk. The Investment Managers have been notified of this policy and the investment portfolios of the funds are analysed against the criteria contained within it. The Firm is part of W&W Gruppe which is a signatory to the internationally-recognised United Nations Principles for Responsible Investment and also a signatory to the United Nations Principles for Sustainable Insurance. This demonstrates the Group’s commitment to incorporating environmental, social and governance-related issues into their investment business.
Link to UNPRI - https://www.unpri.org/signatory-directory/wandw-gruppe/5775.article
Link to PSI - https://www.unepfi.org/psi/ww-group/
Link to Group ESG Policy - https://www.ww-ag.com/en/about-us/Sustainability
Conflicts of Interest
As mentioned above, the Firm has delegated the investment management of its funds to the Investment Managers. Under the terms of the Investment Manager Agreements in place, all transactions will be carried out at arm’s length and in the best interests of Shareholders. Each Investment Manager has a Conflicts of Interest policy in place which is designed to avoid conflicts of interest and, if they cannot be avoided to identify, manage and monitor conflicts so there is no adverse effect on the interests of the Funds and the Shareholders.
Voting Rights
The Firm’s policy is to always exercise voting rights in the best interests of Shareholders/ Unitholders. This policy is kept under review by the Firm.