Shareholder Rights Directive II (“SRD II”)

Shareholder Rights Directive II (“SRD II”)

SRD II (Directive (EU) 2017/828) aims to improve stewardship and corporate governance by asset managers and owners that invest in shares traded on a regulated market in the EEA as well as ‘comparable’ markets situated outside of the EEA.

The Elan Group is made up of a number of entities including Elan Capital Management (London) Ltd (“ECM London”), which is authorised and regulated as an Alternative Investment Fund Manager by the UK Financial Conduct Authority (“FCA”) and Elan Capital Management Oy (“ECM Finland”), which is authorised and regulated as a MiFID investment manager by the Finnish Financial Supervisory Authority (the “FIN-FSA”) (together referred to as “us” or “we”).

Pursuant to the relevant national implementation of Article 3g of SRD II, we are required to:

a)       develop and publicly disclose an engagement policy that meets the requirements of Article 3g; and

b)      publicly disclose on an annual basis how our engagement policy has been implemented in a way that meets the requirements of Article 3g; or

c)       publicly disclose why we have chosen not to comply with these requirements.

We believe firmly in the importance of effective stewardship and long-term decision making, involving transparency of engagement policies between institutional investors and the investee companies. However, we have chosen not to comply with SRD II at this time because our investment strategy does not focus on investing in equity holdings in publicly listed companies. Where such investments are made they form only a very small component of our overall assets under management. In general, any equity exposure is traded via index derivatives only. 

Accordingly, we do not consider it appropriate to adopt a shareholder engagement policy as described by SRD II.  If our investment strategy changes so that the provisions of SRD II become relevant, we will update this disclosure accordingly.

For further information on the Firm’s approach contact:
info@elan-cap.com