Under obligations arising from the revised Shareholder Rights Directive (EU 2017/828) (“SRD II”), a firm which trades shares on regulated and comparable markets is required to either develop and publicly disclose an engagement policy as prescribed in COBS 2.2B.6R or disclose a clear and reasoned explanation of why it has chosen not to do so.
Moorfield Investment Management Limited (“MIML”) has chosen not to develop an engagement policy that complies with the requirements of the SRD II, as the Firm considers that it has an investment strategy that is not commensurate with the outcomes sought thereunder. Moreover, the Firm ensures that its clients are regularly and routinely apprised of the investment strategies employed by the Firm. As such, it is felt that the Firm’s clients would not expect the Firm to achieve compliance with the core requirements of the SRD II.
MIML concentrates its investments within the UK real estate sector. As the Firm’s strategy focuses on acquiring and managing real estate assets rather than taking equity positions in listed issuers, the nature of its investments does not involve significant engagement with listed issuers in the sense contemplated by SRD II. The Firm does not consider that its clients expect such engagement.
While MIML supports the objectives of the Shareholder Rights Directive II (SRD II), it has concluded that adopting a separate SRD II engagement policy would not be appropriate or practicable, given the real estate focused nature of its investment activities and the absence of conventional shareholdings in listed companies. Accordingly, MIML does not comply with the SRD II requirement to publish an engagement policy.