YSRD II aims to improve stewardship and corporate governance by firms including full scope Alternative Investment Fund Managers (“AIFMs”) that invest in shares traded on a regulated market in the European Economic Area (“EEA”) as well as ‘comparable’ markets situated outside of the EEA. Under FCA COBS 2.2.B.5R, we are required to:
On an annual basis, the firm must disclose a general description of voting behaviour, an explanation of the most significant votes and reporting on the use of services of proxy advisors. The disclosure must include how votes have been cast unless they are insignificant due to the subject matter of the vote or to the size of the holding in the company.
Aptior believes firmly in the importance of effective stewardship and long-term decision making, involving transparency of engagement policies between institutional investors and the investee companies.
In the last year, the Funds managed by Aptior have not held equity positions in EEA listed companies above 3% of any investee companies issued share capital and has not participated in any proxy voting. Accordingly, Aptior is deemed to exercise an ‘insignificant’ influence over the management of its investee companies therefore is not engaging in Corporate Governance matters as defined by the SRD II.
Aptior will update this disclosure should there be any significant changes to the size of its equity holdings and/or at least on an annual basis.