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

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

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

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