SRD II aims to improve stewardship and corporate governance by firms, including UK MiFID investment firms 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:
The engagement policy must describe how we:
On an annual basis, we must disclose a general description of voting behaviour, an explanation of the most significant votes and reporting on the use of the services of proxy advisors. The disclosure must include details of 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.
Above Wealth Management LLP has decided that, whilst it supports the aims of SRD II, it has chosen not to comply with the Directive at the present time because it is not at the present time offering portfolio management services to investors and so the requirements are not presently applicable to the Firm.