shares. Such disclosure may exclude votes that are insignificant due to the subject matter of the vote or the size of the holding in the company. 2. The information referred to in paragraph 1 be available free of charge on the institutional investor's or asset manager's website. Member States may provide that the information is published, free of charge, through other means that are easily accessible on-line. Where an asset manager on behalf implements the engagement policy, including voting, of an institutional investor, the institutional investor shall make a reference as to where such voting information has been published by the asset manager. 3. Conflicts of interest rules applicable to institutional investors and asset managers, including Article 14 of Directive 2011/61/EU, Article 12(1)(b) and 14(1)(d) of Directive 2009/65/EC and their relevant implementing rules and Article 23 of Directive 2014/65/EU shall also be applicable with regard to engagement activities. Article 3g Investment strategy of institutional investors and arrangements with managers 1. Member States shall ensure that institutional investors disclose publicly the main ▌how their equity investment strategy with the profile and duration of elements of are consistent their liabilities, and how to the medium in particular long-term liabilities, they contribute to long-term performance of their assets▌. 2. an asset manager invests on behalf of an Member States ensure that where institutional investor, either on a discretionary client-by-client basis or through a collective investment undertaking, the institutional investor publicly discloses the following arrangement with the asset manager information regarding its ▌: incentivises the asset manager to align - how the arrangement with the asset manager its investment strategy and decisions with the profile and duration of liabilities the of the institutional investor, in particular long-term liabilities; incentivises the asset manager to make investment decisions based on - how it medium to long-term performance assessments about financial and non-financial and to engage with companies of the investee company investee in order to improve performance their in the medium to long-term;
shares. Such disclosure may exclude votes that are insignificant due to the subject matter of the vote or the size of the holding in the company. 2. The information referred to in paragraph 1 be available free of charge on the institutional investor's or asset manager's website. Member States may provide that the information is published, free of charge, through other means that are easily accessible on-line. Where an asset manager implements the engagement policy, including voting, on behalf of an institutional investor, the institutional investor shall make a reference as to where such voting information has been published by the asset manager. 3. Conflicts of interest rules applicable to institutional investors and asset managers, including Article 14 of Directive 2011/61/EU, Article 12(1)(b) and 14(1)(d) of Directive 2009/65/EC and their relevant implementing rules and Article 23 of Directive 2014/65/EU shall also be applicable with regard to engagement activities. Article 3g Investment strategy of institutional investors and arrangements with managers 1. Member States shall ensure that institutional investors publicly disclose ▌how the main elements of their equity investment strategy are consistent with the profile and duration of their liabilities, in particular long-term liabilities, and how they contribute to the medium to long-term performance of their assets▌. 2. Member States ensure that where an asset manager invests on behalf of an institutional investor, either on a discretionary client-by-client basis or through a collective investment undertaking, the institutional investor publicly discloses the following information regarding its arrangement with the asset manager ▌: - how the arrangement with the asset manager incentivises the asset manager to align its investment strategy and decisions with the profile and duration of the liabilities of the institutional investor, in particular long-term liabilities; - how it incentivises the asset manager to make investment decisions based on assessments about medium to long-term financial and non-financial performance of the investee company and to engage with investee companies in order to improve their performance in the medium to long-term;
SRD_Compromise_Dec_2016.docx