SRD II, which has been transposed into UK law by the Companies (Shareholders’ Rights to Voting Confirmations) Regulations 2020 (“UK SRD II”), aims to promote effective stewardship and long-term investment decision making, in respect of shares traded on a regulated market. For these purposes a regulated market is a UK Regulated Investment Exchange (or a market outside the United Kingdom which meets comparable requirements and where the financial instruments dealt in are of a quality comparable to those in a regulated market in the United Kingdom). It came into effect on 10 June 2019.

The rules require asset managers, who invest in shares traded on a regulated market detailed above, to:

• publish their shareholder engagement policy (or explain why they don’t have one) – COBS 2.2B.5R.
• make annual public disclosures relating to the implementation of their shareholder engagement policy– COBS 2.2B.5R.
• make disclosures to asset owners, including how their investment strategies contribute to the medium to long term performance of their assets – COBS 2.2B.9R.

Climate Asset Management does not manage investments in shares which are traded on a regulated market and so the SRD II rules do not apply to it. Therefore, we have not developed a shareholder engagement policy and nor are we required to make the disclosures outlined above.