Recent changes to the law, which come into effect in October, mean pension fund trustees must demonstrate how they are acting as effective stewards of their assets. An important way to demonstrate this is to disclose how they are using their voting rights to support or sanction corporate behaviour among their investee companies.
Importantly, the new regulations require trustees to disclose not only their own voting behaviour, but also the votes of investment managers acting on their behalf.
To promote consistent and uniform reporting of this information, the PLSA is today publishing two different sets of guidance to accompany the Vote Reporting Templates: one for use by pension schemes; and one for use by their underlying investment managers.
Many managers will need to alter their systems and processes to report voting information to their pension scheme clients in a relevant, consistent and repeatable way and it may take time to do so. Trustees are encouraged to be flexible in their requirements – particularly in the first year – and engage with their managers regarding what is possible.
Providing more consistent vote reporting at a mandate and fund level will mean:
• Trustees will be able to receive the information in the same format for every fund or manager, which will make it easier to disclose this in a consistent and repeatable format;
• Trustees will have information on voting which is more “decision-useful”;
• Trustees will be able to better compare the service and approach provided by different managers;
• Asset managers will be able to use these disclosures to demonstrate their voting approach to prospective clients and how it supports their overall stewardship approach as compared to that of existing retained managers;
• The resource burden on managers will be reduced when it comes to providing voting information to trustees as they will not need to set up different systems and operations for producing different information for different clients; and
• Trustees who are signatories to the UK Stewardship Code will be able to use these disclosures to help meet their reporting requirements.
The Templates are designed to be used as companions to the recently published PLSA Implementation Statement Guidance, which includes a specific chapter on how to produce clear, effective and meaningful disclosures on voting behaviour in trustees’
Implementation Statement.
They ask trustees and investment managers to disclose details around voting policies such as a description of the voting process or use of any proxy voting services; the number of meetings eligible to vote at; the number of votes cast in total; the number of votes cast for, against and abstained; whether the manager voted contrary to the recommendation of any proxy advisor; details of the “most significant” votes cast; and information on how the manager has managed and mitigated any stewardship conflicts.
Guy Opperman, Minister for Pensions and Financial Inclusion, said: “I welcome this first step on the issue of voting. I support the PLSA’s initiative in producing a practical tool to help pension schemes and their asset managers meet their legal obligations on voting.
“Voting by institutional investors is an important way to influence companies’ responses to the great challenges of our time, not least climate change and the pandemic. I therefore encourage and support industry increasing its efficiency and accountability in this area, and look forward to seeing real progress on this issue.”
Richard Butcher, Chairman, PLSA, said: “Stewardship is more important than ever for delivering good retirement outcomes for scheme members. Active ownership has a positive impact on corporate performance and the value of scheme members’ savings.
Clear, consistent and relevant disclosure on voting behaviour is a vital part of delivering value.”
Laura Myers, PLSA Working Group Chair and Policy Board member, said: “Along with the recently published Implementation Statement Guidance, the Vote Reporting Guidance will not only help pension schemes demonstrate to their members how they are effective stewards of their assets it will also result in richer information that improves investment decisions.”
The Vote Reporting Guidance and Templates
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