ANNEX I
DISCLOSURE OF INVESTMENT POLICY BY INVESTMENT FIRMS
INVESTMENT FIRMS DISCLOSURE
Template number | Template code | Name of the template | Legislative reference
| | INVESTMENT POLICY |
1 | IF IP1 | PROPORTION OF VOTING RIGHTS | Regulation (EU) 2019/2033 Art 52(1), point (a)
2 | IF IP2 | VOTING BEHAVIOUR | Regulation (EU) 2019/2033 Art 52(1), point (b)
3 | IF IP3 | PROXY ADVISOR FIRMS | Regulation (EU) 2019/2033 Art 52(1), point (c)
4 | IF IP4 | VOTING GUIDELINES | Regulation (EU) 2019/2033 Art 52(1), point (d)
IF IP1 – TEMPLATE ON PROPORTION OF VOTING RIGHTS
Country | Economic sector | Company name | Company identifier | Proportion of voting rights attached to shares held directly or indirectly as set out in Article 52(2)
a | b | c | d | e
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Please insert additional rows as needed.
IF IP2 – VOTING BEHAVIOUR
IF IP2.01 – TABLE ON THE DESCRIPTION OF VOTING BEHAVIOUR
Row | Item | Value
1 | Number of relevant companies in the scope of disclosure |
2 | Number of general meetings in the scope of disclosure during the past year |
3 | Number of general meetings in the scope of disclosure in which the firm has voted during the past year |
4 | Does the investment firm inform the company of negative votes prior to the general meeting? |
5 | Proportion of in-person votes used by the firm |
6 | Proportion of votes by mail or electronic vote used by the firm |
7 | On a consolidated basis, does the investment firm group possess a policy regarding conflicts of interests between relevant entities of the group? |
8 | If yes, summary of this policy |
IF IP2.02 – TEMPLATE ON VOTING BEHAVIOUR
Row | Item | Number | Percentage
1 | General meetings resolutions: | |
2 | the firm has approved | |
3 | the firm has opposed | |
4 | in which the firm has abstained | |
5 | General meetings in which the firm has opposed at least one resolution | |
IF IP 2.03 – TABLE ON EXPLANATION OF THE VOTES
Row | Item | Value
1 | Departments or roles in the investment firm that take part in deciding a voting position |
2 | Description of the validation process for negative votes |
3 | Number of full time equivalents used to analyse resolutions and examine voting records, excluding external resources such as proxy advisor firms |
4 | Explanation of any material change in the rate of approval |
5 | List of publicly available investment policy documents describing the investment firm’s objectives |
6 | If relevant, certification of the firm’s investment policy |
IF IP 2.04 – TEMPLATE ON VOTING BEHAVIOUR IN RESOLUTIONS BY THEME
Row | Item | Voted for | Voted against | Abstained | Total
1 | Voted resolutions by theme during the past year: | | | |
2 | Board structure | | | |
3 | Executive remuneration | | | |
4 | Auditors | | | |
5 | Environment, social, ethics | | | |
6 | Capital transactions | | | |
7 | External resolutions | | | |
8 | Other | | | |
IF IP 2.05 – TEMPLATE ON THE RATIO OF APPROVED PROPOSALS
Row | Item | Value
1 | Percentage of resolutions put forward by the administrative or management body that are approved by the firm |
2 | Percentage of resolutions put forward by shareholders that are approved by the firm |
IF IP3 – PROXY ADVISOR FIRMS
IF IP 3.01 – TABLE ON THE LIST OF PROXY ADVISOR FIRMS
Name of proxy advisor firm | Identifier of proxy advisor firm | Contract type | Investments associated with the proxy advisor firm | Themes of resolutions in which the proxy firm gave voting recommendations in the past year
a | b | c | d | e
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Please insert additional rows as needed.
IF IP 3.02 – TABLE ON THE LINKS WITH PROXY ADVISOR FIRMS
Name of proxy advisor firm | Identifier of proxy advisor firm | Relevant undertakings with which the proxy advisor firm has links | Type of link | If relevant, policy regarding conflicts of interests with the proxy advisor firm
a | b | c | d | e
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IF IP4 – TABLE ON VOTING GUIDELINES
Voting guidelines regarding the companies the shares of which are held in accordance with Art. 52(2): short general summary and, if needed, links to non-confidential documents
a