Principle	Guidance
Voting policy and disclosure – International (ICGN)	Seek to vote shares held and make informed and independent voting decisions, applying due care, diligence and judgement across portfolio	Develop and publicly disclose clear voting policies. Abstain or vote against management resolutions inconsistent with good corporate governance practices. Disclose actual voting records publicly online and directly to clients. Include voting activity in client and beneficiary reporting Disclose extent of use of proxy research and voting services. Disclose approach to stock lending and voting. Read MoreThis theme appears in principle 5 of the stewardship code.
Disclose stewardship policies – International (ICGN)	Develop and implement stewardship policies	Develop and periodically review stewardship policies. Periodically review stewardship policies. Fiduciary duty cannot be delegated. Incorporate stewardship into investment management agreements. Oversee and monitor asset manager stewardship activities and their consistency with the asset owner's investment beliefs, policies and guidelines. Read MoreThis theme appears in principle 2 of the stewardship code.
Fiduciary duty – International (ICGN)	Review internal governance practices and ability to serve as fiduciaries	Enhance beneficiaries' interests over appropriate time horizon. Have independent unbiased governance structures to advance beneficiary interests. Have an ethics or conduct code that guides investment and fiduciary activities on behalf of their beneficiaries. The II's board is accountable for the investor's stewardship activities and they should provide the proper tone/support for meaningful execution of stewardship duties. Have appropriate capacity and experience to be effective at stewardship. Consider position in investment value chain and call other service providers, such as custodians to account for stewardship. Minimize conflicts of interest Structure fees and compensation to provide appropriate alignment over relevant time horizons. Read MoreThis theme appears in principle 1 of the stewardship code.
Monitor investees – International (ICGN)	Exercise diligence in monitoring holdings and assessing potential investments	Monitor investees to assess individual circumstances, performance and long-term potential Develop risk-based tools to identify and prioritize investees for further analysis Be clear on standards for monitoring investee companies Understand investee corporate governance practices and reporting quality vs. relevant national/international codes. Assess the quality of explanations for relevant corporate governance codes from a 'comply or explain' perspective, and engage with investees on their reasoned judgements. Periodically review monitoring effectiveness and report to beneficiaries. Read MoreThis theme appears in principle 3 of the stewardship code.
Conflicts of interest policy – International (ICGN)	Review internal governance practices and ability to serve as fiduciaries	Enhance beneficiaries' interests over appropriate time horizon. Have independent unbiased governance structures to advance beneficiary interests. Have an ethics or conduct code that guides investment and fiduciary activities on behalf of their beneficiaries. The II's board is accountable for the investor's stewardship activities and they should provide the proper tone/support for meaningful execution of stewardship duties. Have appropriate capacity and experience to be effective at stewardship. Consider position in investment value chain and call other service providers, such as custodians to account for stewardship. Minimize conflicts of interest Structure fees and compensation to provide appropriate alignment over relevant time horizons. Read MoreThis theme appears in principle 1 of the stewardship code.
Report on stewardship to beneficiaries – International (ICGN)	Publicly disclose stewardship policies and activities and report implementation to beneficiaries/clients	Sign the relevant national code (if one exists) and consider ICGN code. Publicly disclose stewardship policies, preferably on website and explain any noncompliance with code Annually review public stewardship disclosure, and review activities vs. national and ICGN codes. Maintain stewardship and voting records for beneficiaries and clients. Disclose to their beneficiaries or clients their key internal governance arrangements in order to be held effectively accountable for exercising stewardship duties on their behalf. Regularly report stewardship activities/performance to clients. Recognize that external review is best practice. Read MoreThis theme appears in principle 7 of the stewardship code.
Regular/effective investee communication – International (ICGN)	Engage with companies and be prepared for escalation and collective engagement	Use risk-based approach to select company for engagement aligned with investment strategy Establish approach to engagement process. Clarify how to escalate, including (a) expressing concerns directly/in a shareholders' meeting/collectively with other investors, (b) making a public statement, (c) submitting shareholder resolutions, (d) speaking at general meetings, (e) nominating board members/convening a shareholders' meeting, (f) seeking governance improvements/damages via legal remedies/arbitration, (g) threatening to exit or exiting the investment Engage with investee management and board. Collaborate with other investors to leverage the minority investors and exert influence. Engage with policymakers on responsible investment and corporate governance. Read MoreThis theme appears in principle 4 of the stewardship code.
Escalation – International (ICGN)	Engage with companies and be prepared for escalation and collective engagement	Use risk-based approach to select company for engagement aligned with investment strategy Establish approach to engagement process. Clarify how to escalate, including (a) expressing concerns directly/in a shareholders' meeting/collectively with other investors, (b) making a public statement, (c) submitting shareholder resolutions, (d) speaking at general meetings, (e) nominating board members/convening a shareholders' meeting, (f) seeking governance improvements/damages via legal remedies/arbitration, (g) threatening to exit or exiting the investment. Engage with investee management and board. Collaborate with other investors to leverage the minority investors and exert influence. Engage with policymakers on responsible investment and corporate governance. Read MoreThis theme appears in principle 4 of the stewardship code.
Collective engagement – International (ICGN)	Engage with companies and be prepared for escalation and collective engagement	Use risk-based approach to select company for engagement aligned with investment strategy Establish approach to engagement process. Clarify how to escalate, including (a) expressing concerns directly/in a shareholders' meeting/collectively with other investors, (b) making a public statement, (c) submitting shareholder resolutions, (d) speaking at general meetings, (e) nominating board members/convening a shareholders' meeting, (f) seeking governance improvements/damages via legal remedies/arbitration, (g) threatening to exit or exiting the investment Engage with investee management and board. Collaborate with other investors to leverage the minority investors and exert influence. Engage with policymakers on responsible investment and corporate governance. Read MoreThis theme appears in principle 4 of the stewardship code.
ESG integration – International (ICGN)	Promote long-term value creation and (material) ESG integration	Understand client and beneficiary objectives and timeframes. Be aware of and promote drivers of investee long-term performance and sustainable value. Be aware of long-term systemic threats and prioritize basic norms and the mitigation of system-level risk. Analyze, monitor, assess and integrate material ESG risks and opportunities. Link ESG and other qualitative factors with strategy, operations and long-term value creation in report. Read MoreThis theme appears in principle 6 of the stewardship code.
Materiality – International (ICGN)	Promote long-term value creation and (material) ESG integration	Understand client and beneficiary objectives and timeframes. Be aware of and promote drivers of investee long-term performance and sustainable value. Be aware of long-term systemic threats and prioritize basic norms and the mitigation of system-level risk. Analyze, monitor, assess and integrate material ESG risks and opportunities. Link ESG and other qualitative factors with strategy, operations and long-term value creation in report. Read MoreThis theme appears in principle 6 of the stewardship code.
Promote long-term value creation – International (ICGN)	Promote long-term value creation and (material) ESG integration	Understand client and beneficiary objectives and timeframes. Be aware of and promote drivers of investee long-term performance and sustainable value. Be aware of long-term systemic threats and prioritize basic norms and the mitigation of system-level risk. Analyze, monitor, assess and integrate material ESG risks and opportunities. Link ESG and other qualitative factors with strategy, operations and long-term value creation in report. Read MoreThis theme appears in principle 6 of the stewardship code.
Work with policymakers and regulators – International (ICGN)	Engage with companies and be prepared for collective engagement	Use risk-based approach to select company for engagement aligned with investment strategy Establish approach to engagement process. Clarify how to escalate. Engage with investee management and board. Collaborate with other investors to leverage the minority investors and exert influence. Engage with policymakers on responsible investment and corporate governance. Read MoreThis theme appears in principle 4 of the stewardship code.
Build capacity to engage effectively – International (ICGN)	Review internal governance practices and ability to serve as fiduciaries	Enhance beneficiaries' interests over appropriate time horizon. Have independent unbiased governance structures to advance beneficiary interests. Have an ethics or conduct code that guides investment and fiduciary activities on behalf of their beneficiaries. The II's board is accountable for the investor's stewardship activities and they should provide the proper tone/support for meaningful execution of stewardship duties. Have appropriate capacity and experience to be effective at stewardship. Consider position in investment value chain and call other service providers, such as custodians to account for stewardship. Minimize conflicts of interest Structure fees and compensation to provide appropriate alignment over relevant time horizons. Read MoreThis theme appears in principle 1 of the stewardship code.
Board/governance and business management – International (ICGN)	Review internal governance practices and ability to serve as fiduciaries	Enhance beneficiaries' interests over appropriate time horizon. Have independent unbiased governance structures to advance beneficiary interests. Have an ethics or conduct code that guides investment and fiduciary activities on behalf of their beneficiaries. The II's board is accountable for the investor's stewardship activities and they should provide the proper tone/support for meaningful execution of stewardship duties. Have appropriate capacity and experience to be effective at stewardship. Consider position in investment value chain and call other service providers, such as custodians to account for stewardship. Minimize conflicts of interest Structure fees and compensation to provide appropriate alignment over relevant time horizons. Read MoreThis theme appears in principle 1 of the stewardship code.
Facilitate remediation – International (ICGN)	Engage with companies and be prepared for escalation and collective engagement	Use risk-based approach to select company for engagement aligned with investment strategy Establish approach to engagement process. Clarify how to escalate, including (a) expressing concerns directly/in a shareholders' meeting/collectively with other investors, (b) making a public statement, (c) submitting shareholder resolutions, (d) speaking at general meetings, (e) nominating board members/convening a shareholders' meeting, (f) seeking governance improvements/damages via legal remedies/arbitration, (g) threatening to exit or exiting the investment Engage with investee management and board. Collaborate with other investors to leverage the minority investors and exert influence. Engage with policymakers on responsible investment and corporate governance. Read MoreThis theme appears in principle 4 of the stewardship code.
Investor internal incentives (compensation) – International (ICGN)	Review internal governance practices and ability to serve as fiduciaries	Enhance beneficiaries' interests over appropriate time horizon. Have independent unbiased governance structures to advance beneficiary interests. Have an ethics or conduct code that guides investment and fiduciary activities on behalf of their beneficiaries. Have appropriate capacity and experience to be effective at stewardship. Consider position in investment value chain and call other service providers, such as custodians to account for stewardship. Minimize conflicts of interest Structure fees and compensation to provide appropriate alignment over relevant time horizons. Read MoreThis theme appears in principle 1 of the stewardship code.
Investor external incentives (mandates) – International (ICGN)	Review internal governance practices and ability to serve as fiduciaries	Enhance beneficiaries' interests over appropriate time horizon. Have independent unbiased governance structures to advance beneficiary interests. Have an ethics or conduct code that guides investment and fiduciary activities on behalf of their beneficiaries. Have appropriate capacity and experience to be effective at stewardship. Consider position in investment value chain and call other service providers, such as custodians to account for stewardship. Minimize conflicts of interest Structure fees and compensation to provide appropriate alignment over relevant time horizons. Read MoreThis theme appears in principle 1 of the stewardship code.
Voting policy and disclosure – OECD	Prevent and mitigate adverse impacts	Prevention approaches: (a) clear RBC requirements in investment mandates, RBC conditions precedent to investments, and due diligence requirements; (b) if have some investee managerial control, insist on investee company due diligence and written commitments to observe RBC standards; (c) screen potential investments for high RBC risk or those which fall under exclusionary policies; (d) where possible invest in ESG indices and use long-term investment strategies that recognize long-term implications of ESG issues; (e) active engagement with investees to improve ESG Adverse impact responses: risk mitigation via (a) contacting investee via letter, email and/or telephone; (b) meeting investee at operational, senior management and/or board level; (c) attendance and speaking at annual GMs; (d) voting; (e) collaborative engagement; (f) engagement with regulators and policymakers on RBC issues; (g) join geographic or issue-specific initiatives that prevent and mitigate adverse impacts in the areas identified Active strategies: (a) reduce holdings, explain why, and increase intensity of engagement; (b) temporary or permanent divestment Passive strategies: redesign investment strategy to avoid investments with severe RBC impacts As part of stewardship, (a) publicly stewardship policy and (b) have a robust stewardship conflicts of interest policy that is publicly disclosed and includes monitoring, clear guidelines on escalation, collective engagement, voting, and reporting Read MoreThis theme appears in principle 2.3 of the stewardship code.
Disclose stewardship policies – OECD	Embed responsible business conduct (RBC) in policies and management systems	Adopt investor policies that are in the interest of shareholders: (a) commit to international RBC standards; (b) for AM, articulate RBC expectations of its workers and business relationships; (c) for AO, include due diligence considerations in relationships with external AMs; (d) describe approach to DD and stakeholder engagement; (e) are informed by expertise; (f) are approved by senior management; and (g) are publicly available Assign RBC performance accountability and establish internal reporting system for fund managers. Adopt systems to manage RBC Integrate RBC matters within investment decision-making. Develop internal controls and set RBC performance targets, info systems, and operational procedures e.g., (a) procedures to track effectiveness of the investment due diligence processes and responses to real and potential adverse impacts; (b) build knowledge base for RBC info record-keeping, activities and decision-making Provide support and resources for due diligence Build in feedback loops between corporate and investment management departments. Read MoreThis theme appears in principle 2.1 of the stewardship code.
Fiduciary duty – OECD	Embed responsible business conduct (RBC) in policies and management systems	Adopt investor policies that are in the interest of shareholders: (a) commit to international RBC standards; (b) for AM, articulate RBC expectations of its workers and business relationships; (c) for AO, include due diligence considerations in relationships with external AMs; (d) describe approach to DD and stakeholder engagement; (e) are informed by expertise; (f) are approved by senior management; and (g) are publicly available Assign RBC performance accountability and establish internal reporting system for fund managers. Adopt systems to manage RBC Integrate RBC matters within investment decision-making. Develop internal controls and set RBC performance targets, info systems, and operational procedures e.g., (a) procedures to track effectiveness of the investment due diligence processes and responses to real and potential adverse impacts; (b) build knowledge base for RBC info record-keeping, activities and decision-making Provide support and resources for due diligence Build in feedback loops between corporate and investment management departments. Read MoreThis theme appears in principle 2.1 of the stewardship code.
Monitor investees – OECD	Identify actual and potential adverse impacts	Integrate RBC risk identification for investments into existing processes Actively screen investment portfolios to identify potential RBC high-risk areas: geography, sectors, products, stages of the supply chain before and after investment Read MoreThis theme appears in principle 2.2 of the stewardship code.
Conflicts of interest policy – OECD	Prevent and mitigate adverse impacts	Prevention approaches: (a) clear RBC requirements in investment mandates, RBC conditions precedent to investments, and due diligence requirements; (b) if have some investee managerial control, insist on investee company due diligence and written commitments to observe RBC standards; (c) screen potential investments for high RBC risk or those which fall under exclusionary policies; (d) where possible invest in ESG indices and use long-term investment strategies that recognize long-term implications of ESG issues; (e) active engagement with investees to improve ESG Adverse impact responses: risk mitigation via (a) contacting investee via letter, email and/or telephone; (b) meeting investee at operational, senior management and/or board level; (c) attendance and speaking at annual GMs; (d) voting; (e) collaborative engagement; (f) engagement with regulators and policymakers on RBC issues; (g) join geographic or issue-specific initiatives that prevent and mitigate adverse impacts in the areas identified Active strategies: (a) reduce holdings, explain why, and increase intensity of engagement; (b) temporary or permanent divestment Passive strategies: redesign investment strategy to avoid investments with severe RBC impacts As part of stewardship, (a) publicly stewardship policy and (b) have a robust stewardship conflicts of interest policy that is publicly disclosed and includes monitoring, clear guidelines on escalation, collective engagement, voting, and reporting Read MoreThis theme appears in principle 2.3 of the stewardship code.
Report on stewardship to beneficiaries (1) – OECD	Tracking and communicating on results	Tracking (a) performance vs. own RBC Policy or other commitments on RBC (e.g., PRI). - Risk identification methodology and general findings of adverse impacts across portfolios. - Monitoring investee companies' efforts to prevent and mitigate identified adverse impacts. Communicating publicly and with stakeholders: (a) RBC policy and implementation, including due diligence approach; (b) engagement record (activities, companies, results); (c) divestment decision; (d) voting records; (e) future RBC plans and targets Read MoreThis theme appears in principle 2.4 of the stewardship code.
Report on stewardship to beneficiaries (2) – OECD	Prevent and mitigate adverse impacts	Prevention approaches: (a) clear RBC requirements in investment mandates, RBC conditions precedent to investments, and due diligence requirements; (b) if have some investee managerial control, insist on investee company due diligence and written commitments to observe RBC standards; (c) screen potential investments for high RBC risk or those which fall under exclusionary policies; (d) where possible invest in ESG indices and use long-term investment strategies that recognize long-term implications of ESG issues; (e) active engagement with investees to improve ESG Adverse impact responses: risk mitigation via (a) contacting investee via letter, email and/or telephone; (b) meeting investee at operational, senior management and/or board level; (c) attendance and speaking at annual GMs; (d) voting; (e) collaborative engagement; (f) engagement with regulators and policymakers on RBC issues; (g) join geographic or issue-specific initiatives that prevent and mitigate adverse impacts in the areas identified Active strategies: (a) reduce holdings, explain why, and increase intensity of engagement; (b) temporary or permanent divestment Passive strategies: redesign investment strategy to avoid investments with severe RBC impacts As part of stewardship, (a) publicly stewardship policy and (b) have a robust stewardship conflicts of interest policy that is publicly disclosed and includes monitoring, clear guidelines on escalation, collective engagement, voting, and reporting Read MoreThis theme appears in principle 2.3 of the stewardship code.
Regular/effective investee communication – OECD	Prevent and mitigate adverse impacts	Prevention approaches: (a) clear RBC requirements in investment mandates, RBC conditions precedent to investments, and due diligence requirements; (b) if have some investee managerial control, insist on investee company due diligence and written commitments to observe RBC standards; (c) screen potential investments for high RBC risk or those which fall under exclusionary policies; (d) where possible invest in ESG indices and use long-term investment strategies that recognize long-term implications of ESG issues; (e) active engagement with investees to improve ESG Adverse impact responses: risk mitigation via (a) contacting investee via letter, email and/or telephone; (b) meeting investee at operational, senior management and/or board level; (c) attendance and speaking at annual GMs; (d) voting; (e) collaborative engagement; (f) engagement with regulators and policymakers on RBC issues; (g) join geographic or issue-specific initiatives that prevent and mitigate adverse impacts in the areas identified Active strategies: (a) reduce holdings, explain why, and increase intensity of engagement; (b) temporary or permanent divestment Passive strategies: redesign investment strategy to avoid investments with severe RBC impacts As part of stewardship, (a) publicly stewardship policy and (b) have a robust stewardship conflicts of interest policy that is publicly disclosed and includes monitoring, clear guidelines on escalation, collective engagement, voting, and reporting Read MoreThis theme appears in principle 2.3 of the stewardship code.
Escalation – OECD	Prevent and mitigate adverse impacts	Prevention approaches: (a) clear RBC requirements in investment mandates, RBC conditions precedent to investments, and due diligence requirements; (b) if have some investee managerial control, insist on investee company due diligence and written commitments to observe RBC standards; (c) screen potential investments for high RBC risk or those which fall under exclusionary policies; (d) where possible invest in ESG indices and use long-term investment strategies that recognize long-term implications of ESG issues; (e) active engagement with investees to improve ESG Adverse impact responses: risk mitigation via (a) contacting investee via letter, email and/or telephone; (b) meeting investee at operational, senior management and/or board level; (c) attendance and speaking at annual GMs; (d) voting; (e) collaborative engagement; (f) engagement with regulators and policymakers on RBC issues; (g) join geographic or issue-specific initiatives that prevent and mitigate adverse impacts in the areas identified Active strategies: (a) reduce holdings, explain why, and increase intensity of engagement; (b) temporary or permanent divestment Passive strategies: redesign investment strategy to avoid investments with severe RBC impacts As part of stewardship, (a) publicly stewardship policy and (b) have a robust stewardship conflicts of interest policy that is publicly disclosed and includes monitoring, clear guidelines on escalation, collective engagement, voting, and reporting Read MoreThis theme appears in principle 2.3 of the stewardship code.
Collective engagement – OECD	Prevent and mitigate adverse impacts	Prevention approaches: (a) clear RBC requirements in investment mandates, RBC conditions precedent to investments, and due diligence requirements; (b) if have some investee managerial control, insist on investee company due diligence and written commitments to observe RBC standards; (c) screen potential investments for high RBC risk or those which fall under exclusionary policies; (d) where possible invest in ESG indices and use long-term investment strategies that recognize long-term implications of ESG issues; (e) active engagement with investees to improve ESG Adverse impact responses: risk mitigation via (a) contacting investee via letter, email and/or telephone; (b) meeting investee at operational, senior management and/or board level; (c) attendance and speaking at annual GMs; (d) voting; (e) collaborative engagement; (f) engagement with regulators and policymakers on RBC issues; (g) join geographic or issue-specific initiatives that prevent and mitigate adverse impacts in the areas identified Active strategies: (a) reduce holdings, explain why, and increase intensity of engagement; (b) temporary or permanent divestment Passive strategies: redesign investment strategy to avoid investments with severe RBC impacts As part of stewardship, (a) publicly stewardship policy and (b) have a robust stewardship conflicts of interest policy that is publicly disclosed and includes monitoring, clear guidelines on escalation, collective engagement, voting, and reporting Read MoreThis theme appears in principle 2.3 of the stewardship code.
ESG integration (1) – OECD	Identify actual and potential adverse impacts	Integrate RBC risk identification for investments into existing processes Actively screen investment portfolios to identify potential RBC high-risk areas: geography, sectors, products, stages of the supply chain before and after investment Read MoreThis theme appears in principle 2.2 of the stewardship code.
ESG integration (2) – OECD	Prevent and mitigate adverse impacts	Prevention approaches: (a) clear RBC requirements in investment mandates, RBC conditions precedent to investments, and due diligence requirements; (b) if have some investee managerial control, insist on investee company due diligence and written commitments to observe RBC standards; (c) screen potential investments for high RBC risk or those which fall under exclusionary policies; (d) where possible invest in ESG indices and use long-term investment strategies that recognize long-term implications of ESG issues; (e) active engagement with investees to improve ESG Adverse impact responses: risk mitigation via (a) contacting investee via letter, email and/or telephone; (b) meeting investee at operational, senior management and/or board level; (c) attendance and speaking at annual GMs; (d) voting; (e) collaborative engagement; (f) engagement with regulators and policymakers on RBC issues; (g) join geographic or issue-specific initiatives that prevent and mitigate adverse impacts in the areas identified Active strategies: (a) reduce holdings, explain why, and increase intensity of engagement; (b) temporary or permanent divestment Passive strategies: redesign investment strategy to avoid investments with severe RBC impacts As part of stewardship, (a) publicly stewardship policy and (b) have a robust stewardship conflicts of interest policy that is publicly disclosed and includes monitoring, clear guidelines on escalation, collective engagement, voting, and reporting Read MoreThis theme appears in principle 2.3 of the stewardship code.
Materiality – OECD	Mitigate actual or potential adverse impacts on investee company by considering the materiality of the issue for the investor.	None. Part of the code, but not part of principles
Promote long-term value creation – OECD	Prevent and mitigate adverse impacts	Prevention approaches: (a) clear RBC requirements in investment mandates, RBC conditions precedent to investments, and due diligence requirements; (b) if have some investee managerial control, insist on investee company due diligence and written commitments to observe RBC standards; (c) screen potential investments for high RBC risk or those which fall under exclusionary policies; (d) where possible invest in ESG indices and use long-term investment strategies that recognize long-term implications of ESG issues; (e) active engagement with investees to improve ESG Adverse impact responses: risk mitigation via (a) contacting investee via letter, email and/or telephone; (b) meeting investee at operational, senior management and/or board level; (c) attendance and speaking at annual GMs; (d) voting; (e) collaborative engagement; (f) engagement with regulators and policymakers on RBC issues; (g) join geographic or issue-specific initiatives that prevent and mitigate adverse impacts in the areas identified Active strategies: (a) reduce holdings, explain why, and increase intensity of engagement; (b) temporary or permanent divestment Passive strategies: redesign investment strategy to avoid investments with severe RBC impacts As part of stewardship, (a) publicly stewardship policy and (b) have a robust stewardship conflicts of interest policy that is publicly disclosed and includes monitoring, clear guidelines on escalation, collective engagement, voting, and reporting Read MoreThis theme appears in principle 2.3 of the stewardship code.
Work with policymakers and regulators – OECD	Prevent and mitigate adverse impacts	Prevention approaches: (a) clear RBC requirements in investment mandates, RBC conditions precedent to investments, and due diligence requirements; (b) if have some investee managerial control, insist on investee company due diligence and written commitments to observe RBC standards; (c) screen potential investments for high RBC risk or those which fall under exclusionary policies; (d) where possible invest in ESG indices and use long-term investment strategies that recognize long-term implications of ESG issues; (e) active engagement with investees to improve ESG Adverse impact responses: risk mitigation via (a) contacting investee via letter, email and/or telephone; (b) meeting investee at operational, senior management and/or board level; (c) attendance and speaking at annual GMs; (d) voting; (e) collaborative engagement; (f) engagement with regulators and policymakers on RBC issues; (g) join geographic or issue-specific initiatives that prevent and mitigate adverse impacts in the areas identified Active strategies: (a) reduce holdings, explain why, and increase intensity of engagement; (b) temporary or permanent divestment Passive strategies: redesign investment strategy to avoid investments with severe RBC impacts As part of stewardship, (a) publicly stewardship policy and (b) have a robust stewardship conflicts of interest policy that is publicly disclosed and includes monitoring, clear guidelines on escalation, collective engagement, voting, and reporting Read MoreThis theme appears in principle 2.3 of the stewardship code.
Build capacity to engage effectively – OECD	Embed responsible business conduct (RBC) in policies and management systems	Adopt investor policies that are in the interest of shareholders: (a) commit to international RBC standards; (b) for AM, articulate RBC expectations of its workers and business relationships; (c) for AO, include due diligence considerations in relationships with external AMs; (d) describe approach to DD and stakeholder engagement; (e) are informed by expertise; (f) are approved by senior management; and (g) are publicly available Assign RBC performance accountability and establish internal reporting system for fund managers. Adopt systems to manage RBC Integrate RBC matters within investment decision-making. Develop internal controls and set RBC performance targets, info systems, and operational procedures e.g., (a) procedures to track effectiveness of the investment due diligence processes and responses to real and potential adverse impacts; (b) build knowledge base for RBC info record-keeping, activities and decision-making Provide support and resources for due diligence Build in feedback loops between corporate and investment management departments. Read MoreThis theme appears in principle 2.1 of the stewardship code.
Board/governance and business management – OECD	Embed responsible business conduct (RBC) in policies and management systems	Adopt investor policies that are in the interest of shareholders: (a) commit to international RBC standards; (b) for AM, articulate RBC expectations of its workers and business relationships; (c) for AO, include due diligence considerations in relationships with external AMs; (d) describe approach to DD and stakeholder engagement; (e) are informed by expertise; (f) are approved by senior management; and (g) are publicly available Assign RBC performance accountability and establish internal reporting system for fund managers. Adopt systems to manage RBC Integrate RBC matters within investment decision-making. Develop internal controls and set RBC performance targets, info systems, and operational procedures e.g., (a) procedures to track effectiveness of the investment due diligence processes and responses to real and potential adverse impacts; (b) build knowledge base for RBC info record-keeping, activities and decision-making Provide support and resources for due diligence Build in feedback loops between corporate and investment management departments. Read MoreThis theme appears in principle 2.1 of the stewardship code.
Facilitate remediation – OECD	Processes to support remediation	Processes to enable remediation include (i) cooperation with judicial or state-based non-judicial mechanisms and (ii) establishment of operational-level grievance mechanisms.This theme appears in principle 2.5 of the stewardship code.
Understand investee stakeholder perspectives – OECD	Embed responsible business conduct (RBC) in policies and management systems	Adopt investor policies that are in the interest of shareholders: (a) commit to international RBC standards; (b) for AM, articulate RBC expectations of its workers and business relationships; (c) for AO, include due diligence considerations in relationships with external AMs; (d) describe approach to DD and stakeholder engagement; (e) are informed by expertise; (f) are approved by senior management; and (g) are publicly available Assign RBC performance accountability and establish internal reporting system for fund managers. Adopt systems to manage RBC Integrate RBC matters within investment decision-making. Develop internal controls and set RBC performance targets, info systems, and operational procedures e.g., (a) procedures to track effectiveness of the investment due diligence processes and responses to real and potential adverse impacts; (b) build knowledge base for RBC info record-keeping, activities and decision-making Provide support and resources for due diligence Build in feedback loops between corporate and investment management departments. Read MoreThis theme appears in principle 2.1 of the stewardship code.
Voting policy and disclosure – European Union	AM: exercise voting rights in a considered way	AMs: have a voting policy that defines how and when to exercise voting rights to the exclusive benefit of clients; the policy should include procedures and measures to prevent/manage conflicts of interest AMs: (a) seek to vote all shares held; (b) evaluate management resolutions separately and abstain from or vote against them if deemed to be in client best interests Read MoreThis theme appears in principle 5 of the stewardship code.
Disclose stewardship policies – European Union	AMs: Have a publicly disclosed engagement policy focused on stewardship or explain why not	Consider differing cultures, legal frameworks, company structures, and investment strategies Stewardship policies should cover methods for: (a) investment integration; (b) monitoring; (c) dialogue with investees; (e) conflicts of interest; (f) insider information; (g) stock lending and recalling lent stock; (h) escalation; (i) collective engagement; (j) voting rights; (k) if applicable, proxy voting/voting advisory services Read MoreThis theme appears in principle 1 of the stewardship code.
Fiduciary duty – European Union	AM: exercise voting rights in a considered way	AMs: have a voting policy that defines how and when to exercise voting rights to the exclusive benefit of clients; the policy should include procedures and measures to prevent/manage conflicts of interest AMs: (a) seek to vote all shares held; (b) evaluate management resolutions separately and abstain from or vote against them if deemed to be in client best interests Read MoreThis theme appears in principle 5 of the stewardship code.
Monitor investees – European Union	AM: Monitor investees	Monitor investees to determine when to have active dialogues with boards/management Seek satisfaction that the investee board, subcommittee structures, and management are effective, and independent director provide adequate oversight Ensure that appropriate members of an investee company's board or management are made aware of any concerns Read MoreThis theme appears in principle 2 of the stewardship code.
Conflicts of interest policy – European Union	AMs: Have a publicly disclosed engagement policy focused on stewardship or explain why not	Consider differing cultures, legal frameworks, company structures, and investment strategies Stewardship policies should cover methods for: (a) investment integration; (b) monitoring; (c) dialogue with investees; (e) conflicts of interest; (f) insider information; (g) stock lending and recalling lent stock; (h) escalation; (i) collective engagement; (j) voting rights; (k) if applicable, proxy voting/voting advisory services Read MoreThis theme appears in principle 1 of the stewardship code.
Report on stewardship to beneficiaries – European Union	AM: disclose implementation and results of stewardship and voting	AM: disclose how stewardship/engagement responsibilities were discharged. Disclose publicly implementation of engagement policy, including general description of voting, voting records in investee companies with significant holdings, explanations of the most significant votes, and the use of proxy voting advisors. Read MoreThis theme appears in principle 6 of the stewardship code.
Regular/effective investee communication – European Union	AM: Monitor investees	Monitor investees to determine when to have active dialogues with boards/management Seek satisfaction that the investee board, subcommittee structures, and management are effective, and independent director provide adequate oversight Ensure that appropriate members of an investee company's board or management are made aware of any concerns Read MoreThis theme appears in principle 2 of the stewardship code.
Escalation – European Union	AM: Establish clear guidelines on when/how to escalate	Set out circumstances for active engagement and periodically assess outcomes: (a) concerns with business strategy/execution; (b) risk management; (c) ESG concerns; (d) corporate governance issues; (e) compliance/culture/ethics; (f) performance and capital structure. Disinvest may be appropriate for active managers. Escalation may comprise: (a) meeting management/board to discuss concerns or (b) expressing concerns through the company's advisers Unilateral or bilateral (2-way) engagement with investee board If boards do not respond constructively, consider further escalation: (a) collective engagement; (b) submitting resolutions at general meetings; (c) voting against proposed resolutions; (d) calling an extraordinary general meeting to propose shareholder action Read MoreThis theme appears in principle 3 of the stewardship code.
Collective engagement – European Union	AM: Consider collective engagement	Collectively engage at times of significant corporate/wider economic stress or when there are significant risks Collective engagement must consider rules on acting in concert AMs must consider market regulations and their own policies on conflicts of interest and insider information In addition to company-related collective engagement, AMs can collectively engage on policy issues at any time Read MoreThis theme appears in principle 4 of the stewardship code.
ESG integration – European Union	Include material environmental and social matters in discussions and, where appropriate, in investment analysis and decisions	None. Part of the code, but not part of principlesThis theme appears in principle 0 of the stewardship code.
Materiality – European Union	Include material environmental and social matters in discussions and, where appropriate, in investment analysis and decisions	None. Part of the code, but not part of principlesThis theme appears in principle 0 of the stewardship code.
Work with policymakers and regulators – European Union	AM: Consider collective engagement	Collectively engage at times of significant corporate/wider economic stress or when there are significant risks Collective engagement must consider rules on acting in concert AMs must consider market regulations and their own policies on conflicts of interest and insider information In addition to company-related collective engagement, AMs can collectively engage on policy issues at any time Read MoreThis theme appears in principle 4 of the stewardship code.
Voting policy and disclosure – Australia	Asset stewardship: describe asset stewardship approach and exercise effective asset stewardship	Encourage investees to meet the highest standards of governance and ethical/professional practices Hold boards and management accountable for failing to maintain acceptable standards. Describe monitoring/engagement approach and connection between monitoring, engagement, proxy voting and investment decision-making. Disclosure should include: (a) monitoring investees on financial and non-financial matters; (b) engagement with company management/the board and escalation in certain instances; (c) ESG considerations and whether they influence decision-making and engagement; (d) proxy voting; (e) collaborative engagement, including involvement with industry groups and associations; (f) principles used for policy advocacy; (g) approach to client engagement, education and communication Read MoreThis theme appears in principle 3 of the stewardship code.
Disclose stewardship policies – Australia	Asset stewardship: describe asset stewardship approach and exercise effective asset stewardship	Encourage investees to meet the highest standards of governance and ethical/professional practices Hold boards and management accountable for failing to maintain acceptable standards. Describe monitoring/engagement approach and connection between monitoring, engagement, proxy voting and investment decision-making. Disclosure should include: (a) monitoring investees on financial and non-financial matters; (b) engagement with company management/the board and escalation in certain instances; (c) ESG considerations and whether they influence decision-making and engagement; (d) proxy voting; (e) collaborative engagement, including involvement with industry groups and associations; (f) principles used for policy advocacy; (g) approach to client engagement, education and communication Read MoreThis theme appears in principle 3 of the stewardship code.
Fiduciary duty – Australia	Organizational and investment approach: clearly state organizational purpose/values and underlying investment philosophy/approach. Be transparent about ownership, structure, internal governance, and key staff experience/competencies.	Disclose to clients purpose, values, and underlying investment philosophy, including: (a) AM features and how directed towards client objectives; (b) how purpose/values aligns with duty to clients; (c) ownership/management/governance; (d) key management and investment personnel; (e) how ensure client assets are managed according to investment strategies and management of conflicts of interest Communicate material changes to these structures/key personnel to clients and updated the disclosure Read MoreThis theme appears in principle 1 of the stewardship code.
Monitor investees – Australia	Asset stewardship: describe asset stewardship approach and exercise effective asset stewardship	Encourage investees to meet the highest standards of governance and ethical/professional practices Hold boards and management accountable for failing to maintain acceptable standards. Describe monitoring/engagement approach and connection between monitoring, engagement, proxy voting and investment decision-making. Disclosure should include: (a) monitoring investees on financial and non-financial matters; (b) engagement with company management/the board and escalation in certain instances; (c) ESG considerations and whether they influence decision-making and engagement; (d) proxy voting; (e) collaborative engagement, including involvement with industry groups and associations; (f) principles used for policy advocacy; (g) approach to client engagement, education and communication Read MoreThis theme appears in principle 3 of the stewardship code.
Conflicts of interest policy (1) – Australia	Internal governance: Publicly disclose policies or provide a clear description of material aspects of internal governance and business management	Have robust internal governance practices: act responsibly/in clients' interests and treat clients fairly Refer in disclosure to other publicly available information Either publicly disclose policies or clearly describe material aspects of approach to managing business activities (naturally excluding proprietary information or IP) Publicly disclose--or explain why not--policies on: ethical conduct and professional practice; personal trading; management of conflicts of interest to ensure client interests take priority; risk management and compliance; error correction; brokerage and commissions; equitable asset valuation and pricing; best execution and trade allocation, remuneration, whistle-blower protection; training and development; complaints and dispute resolution. Read MoreThis theme appears in principle 2 of the stewardship code.
Conflicts of interest policy (2) – Australia	Organizational and investment approach: clearly state organizational purpose/values and underlying investment philosophy/approach. Be transparent about ownership, structure, internal governance, and key staff experience/competencies.	Disclose to clients purpose, values, and underlying investment philosophy, including: (a) AM features and how directed towards client objectives; (b) how purpose/values aligns with duty to clients; (c) ownership/management/governance; (d) key management and investment personnel; (e) how ensure client assets are managed according to investment strategies and management of conflicts of interest Communicate material changes to these structures/key personnel to clients and updated the disclosure Read MoreThis theme appears in principle 1 of the stewardship code.
Report on stewardship to beneficiaries – Australia	Compliance with this standard	Compliance with this standard must be certified annually Full FSC members must provide sign-off on compliance with this Standard. A complete version of the FSC Standard: Principles of Internal Governance and Asset Stewardship document will be required to be published on the Asset Manager website by no later than 1 July 2018. Read MoreThis theme appears in principle 4 of the stewardship code.
Regular/effective investee communication – Australia	Asset stewardship: describe asset stewardship approach and exercise effective asset stewardship	Encourage investees to meet the highest standards of governance and ethical/professional practices Hold boards and management accountable for failing to maintain acceptable standards. Describe monitoring/engagement approach and connection between monitoring, engagement, proxy voting and investment decision-making. Disclosure should include: (a) monitoring investees on financial and non-financial matters; (b) engagement with company management/the board and escalation in certain instances; (c) ESG considerations and whether they influence decision-making and engagement; (d) proxy voting; (e) collaborative engagement, including involvement with industry groups and associations; (f) principles used for policy advocacy; (g) approach to client engagement, education and communication Read MoreThis theme appears in principle 3 of the stewardship code.
Escalation – Australia	Asset stewardship: describe asset stewardship approach and exercise effective asset stewardship	Encourage investees to meet the highest standards of governance and ethical/professional practices Hold boards and management accountable for failing to maintain acceptable standards. Describe monitoring/engagement approach and connection between monitoring, engagement, proxy voting and investment decision-making. Disclosure should include: (a) monitoring investees on financial and non-financial matters; (b) engagement with company management/the board and escalation in certain instances; (c) ESG considerations and whether they influence decision-making and engagement; (d) proxy voting; (e) collaborative engagement, including involvement with industry groups and associations; (f) principles used for policy advocacy; (g) approach to client engagement, education and communication Read MoreThis theme appears in principle 3 of the stewardship code.
Collective engagement – Australia	Asset stewardship: describe asset stewardship approach and exercise effective asset stewardship	Encourage investees to meet the highest standards of governance and ethical/professional practices Hold boards and management accountable for failing to maintain acceptable standards. Describe monitoring/engagement approach and connection between monitoring, engagement, proxy voting and investment decision-making. Disclosure should include: (a) monitoring investees on financial and non-financial matters; (b) engagement with company management/the board and escalation in certain instances; (c) ESG considerations and whether they influence decision-making and engagement; (d) proxy voting; (e) collaborative engagement, including involvement with industry groups and associations; (f) principles used for policy advocacy; (g) approach to client engagement, education and communication Read MoreThis theme appears in principle 3 of the stewardship code.
ESG integration – Australia	Asset stewardship: describe asset stewardship approach and exercise effective asset stewardship	Encourage investees to meet the highest standards of governance and ethical/professional practices Hold boards and management accountable for failing to maintain acceptable standards. Describe monitoring/engagement approach and connection between monitoring, engagement, proxy voting and investment decision-making. Disclosure should include: (a) monitoring investees on financial and non-financial matters; (b) engagement with company management/the board and escalation in certain instances; (c) ESG considerations and whether they influence decision-making and engagement; (d) proxy voting; (e) collaborative engagement, including involvement with industry groups and associations; (f) principles used for policy advocacy; (g) approach to client engagement, education and communication Read MoreThis theme appears in principle 3 of the stewardship code.
Work with policymakers and regulators – Australia	Asset stewardship: describe asset stewardship approach and exercise effective asset stewardship	Encourage investees to meet the highest standards of governance and ethical/professional practices Hold boards and management accountable for failing to maintain acceptable standards. Describe monitoring/engagement approach and connection between monitoring, engagement, proxy voting and investment decision-making. Disclosure should include: (a) monitoring investees on financial and non-financial matters; (b) engagement with company management/the board and escalation in certain instances; (c) ESG considerations and whether they influence decision-making and engagement; (d) proxy voting; (e) collaborative engagement, including involvement with industry groups and associations; (f) principles used for policy advocacy; (g) approach to client engagement, education and communication Read MoreThis theme appears in principle 3 of the stewardship code.
Board/governance and business management – Australia	Internal governance: publicly disclose policies or provide a clear description of material aspects of internal governance and business management	Have robust internal governance practices: act responsibly/in clients' interests and treat clients fairly Refer in disclosure to other publicly available information Either publicly disclose policies or clearly describe material aspects of approach to managing business activities (naturally excluding proprietary information or IP) Publicly disclose--or explain why not--policies on: ethical conduct and professional practice; personal trading; management of conflicts of interest to ensure client interests take priority; risk management and compliance; error correction; brokerage and commissions; equitable asset valuation and pricing; best execution and trade allocation, remuneration, whistle-blower protection; training and development; complaints and dispute resolution. Read MoreThis theme appears in principle 2 of the stewardship code.
Transparency on organizational/investment approach – Australia	Organizational and investment approach: clearly state organizational purpose/values and underlying investment philosophy/approach. Be transparent about ownership, structure, internal governance, and key staff experience/competencies.	Disclose to clients purpose, values, and underlying investment philosophy, including: (a) AM features and how directed towards client objectives; (b) how purpose/values aligns with duty to clients; (c) ownership/management/governance; (d) key management and investment personnel; (e) how ensure client assets are managed according to investment strategies and management of conflicts of interest Communicate material changes to these structures/key personnel to clients and updated the disclosure Read MoreThis theme appears in principle 1 of the stewardship code.
Voting policy and disclosure – Brazil	Be active and diligent with voting: Actively and diligently vote. Report both votes and justification for the non-exercise of voting rights.	Consciously exercise voting rights Exercise political rights with diligence and the behavioral posture to meet fiduciary duty. Not voting should be an exception, duly justified and documented. Actively participate in the shareholder's meetings, justify votes in every matter, and document the internal discussion process and the decisions. Waivers to voting rights should be justified, even if on an aggregate basis Read MoreThis theme appears in principle 5 of the stewardship code.
Disclose stewardship policies (1) – Brazil	Be transparent on stewardship activities: Disclose stewardship activities and approach to progress and disclosure	Announce their adherence to the code Periodically report on activities and developments related to each principle of the code Read MoreThis theme appears in principle 7 of the stewardship code.
Disclose stewardship policies (2) – Brazil	Implement and disclose a stewardship program: Implement stewardship program with clear/objective parameters (i.e., when, how), fiduciary duty	Stewardship is evolutionary and requires long-term planning. Establish stewardship activities to be developed and how these activities will progress. Establish how guidelines for engagement will create value & protect beneficiaries Provide stakeholders with visibility into stewardship. Make its implementation feasible for all stakeholders. Read MoreThis theme appears in principle 1 of the stewardship code.
Fiduciary duty – Brazil	Implement and disclose a stewardship program: Implement stewardship program with clear/objective parameters (i.e., when, how), fiduciary duty	Stewardship is evolutionary and requires long-term planning. Establish stewardship activities to be developed and how these activities will progress. Establish how guidelines for engagement will create value & protect beneficiaries Provide stakeholders with visibility into stewardship. Make its implementation feasible for all stakeholders. Read MoreThis theme appears in principle 1 of the stewardship code.
Monitor investees – Brazil	Monitor the issuers of securities	Define level of engagement outlining if/ when/how engage and adoption of the necessary measures in relation to key issues. Define the progress of II knowledge about key investee issues, e.g., strategy, compensation, policy on the nomination of directors, mapping/monitoring of corporate risks, ESG policies Report engagement activities in internal documents. Read MoreThis theme appears in principle 4 of the stewardship code.
Conflicts of interest policy – Brazil	Implement/disclose mechanisms to manage conflicts of interest: Establish/implement mechanisms to manage conflicts of interest re: stewardship	Conflicts of interest can be (a) between IIs and (i) end beneficiaries (ii) IIs' several business segments, (iii) invested assets and (b) between the end beneficiaries themselves. Indicating the necessary measures so that the interests of their beneficiaries prevail Be able to show that stewardship activities are protected against conflicts of interest Read MoreThis theme appears in principle 2 of the stewardship code.
Report on stewardship to beneficiaries – Brazil	Be transparent on stewardship activities: Disclose stewardship activities and approach to progress and disclosure	Announce their adherence to the code Periodically report on activities and developments related to each principle of the code Read MoreThis theme appears in principle 7 of the stewardship code.
Regular/effective investee communication – Brazil	Monitor the issuers of securities	Define level of engagement outlining if/ when/how engage and adoption of the necessary measures in relation to key issues. Define the progress of II knowledge about key investee issues, e.g., strategy, compensation, policy on the nomination of directors, mapping/monitoring of corporate risks, ESG policies Report engagement activities in internal documents. Read MoreThis theme appears in principle 4 of the stewardship code.
Collective engagement – Brazil	Establish collective engagement criteria: Create collective engagement conditions with other investors when appropriate	In specific cases, collective engagement is most efficient: increases legitimacy of topics and optimizes costs/risks Define when to collectively engage, clarifying role (active vs. passive) Read MoreThis theme appears in principle 6 of the stewardship code.
ESG integration – Brazil	Incorporate ESG factors into investment processes and stewardship activities: Integrate ESG into investment process, evaluating impact on risks and returns and contribution to investee sustainable development	Analyze/monitor ESG factors as part of the evaluation of the risks/opportunities/sustainability of investments (not the final drivers for investment decision) Consider relevant ESG factors as crucial to fiduciary duty, being transparent about how ESG factors will be considered Evaluate investee views on ESG topics Read MoreThis theme appears in principle 3 of the stewardship code.
Voting policy and disclosure – Canada	Adopt and publicly disclose proxy voting guidelines	Seek to vote all of the shares of investee companies. Make informed and independent voting decisions in the clients' best interests (vs. automatically supporting management/the board) and considering company-specific circumstances (vs. ticking the box). Assess third-party advice critically. Establish a process to cast votes consistent with voting policy. Do not borrow/lend shares for voting purposes. Periodic reporting of voting activities should include instances where they will not vote, potential conflicts of interest related to voting (and how to address these), and their approach to stock lending and recalling lent shares for voting purposes. Read MoreThis theme appears in principle 3 of the stewardship code.
Disclose stewardship policies – Canada	Develop, implement, and disclose an approach to stewardship	Integrate a procedure for voting proxies, engaging with companies, outsourcing stewardship activities, reporting to clients, managing potential conflicts of interest, and aligning compensation with stewardship principles. Engage with investee companies by monitoring strategy and risk oversight (including ESG and financial risk), performance, governance framework, and compensation. Regularly monitor outsourced stewardship activities to ensure consistency with stewardship approach. Set out expectations for stewardship activities in mandates between AOs and AMs. Disclose to beneficiaries the internal governance structures and processes for stewardship Report periodically on stewardship activities to beneficiaries. Explain how activities aim to protect long-term sustainable value. Implement mechanisms to deal with conflicts of interest, including identifying and managing them and putting clients first. Establish structures and processes to ensure compensation programs are properly aligned with the goal of enhancing the long term sustainable value of the IIs' assets (including appropriate benchmarks and risk mitigation features). Read MoreThis theme appears in principle 1 of the stewardship code.
Fiduciary duty – Canada	Develop, implement, and disclose an approach to stewardship	Integrate a procedure for voting proxies, engaging with companies, outsourcing stewardship activities, reporting to clients, managing potential conflicts of interest, and aligning compensation with stewardship principles. Engage with investee companies by monitoring strategy and risk oversight (including ESG and financial risk), performance, governance framework, and compensation. Regularly monitor outsourced stewardship activities to ensure consistency with stewardship approach. Set out expectations for stewardship activities in mandates between AOs and AMs. Disclose to beneficiaries the internal governance structures and processes for stewardship Report periodically on stewardship activities to beneficiaries. Explain how activities aim to protect long-term sustainable value. Implement mechanisms to deal with conflicts of interest, including identifying and managing them and putting clients first. Establish structures and processes to ensure compensation programs are properly aligned with the goal of enhancing the long term sustainable value of the IIs' assets (including appropriate benchmarks and risk mitigation features). Read MoreThis theme appears in principle 1 of the stewardship code.
Monitor investees – Canada	Monitor the investee companies	Monitoring may include: (a) reviewing public disclosures; (b) primary and third-party research and analysis on company; (c) sharing research and information with other investors; (d) engagement; and (e) attending or monitoring formal shareholder meetings Establish methodology for identifying companies that require further analysis and engagement (given potential size and passive nature of portfolios). Periodically review monitoring effectiveness and communicate results with clients Read MoreThis theme appears in principle 2 of the stewardship code.
Conflicts of interest policy – Canada	Develop, implement, and disclose an approach to stewardship	Integrate a procedure for voting proxies, engaging with companies, outsourcing stewardship activities, reporting to clients, managing potential conflicts of interest, and aligning compensation with stewardship principles. Engage with investee companies by monitoring strategy and risk oversight (including ESG and financial risk), performance, governance framework, and compensation. Regularly monitor outsourced stewardship activities to ensure consistency with stewardship approach. Set out expectations for stewardship activities in mandates between AOs and AMs. Disclose to beneficiaries the internal governance structures and processes for stewardship Report periodically on stewardship activities to beneficiaries. Explain how activities aim to protect long-term sustainable value. Implement mechanisms to deal with conflicts of interest, including identifying and managing them and putting clients first. Establish structures and processes to ensure compensation programs are properly aligned with the goal of enhancing the long term sustainable value of the IIs' assets (including appropriate benchmarks and risk mitigation features). Read MoreThis theme appears in principle 1 of the stewardship code.
Report on stewardship to beneficiaries – Canada	Adopt and publicly disclose proxy voting guidelines	Seek to vote all of the shares of investee companies. Make informed and independent voting decisions in the clients' best interests (vs. automatically supporting management/the board) and considering company-specific circumstances (vs. ticking the box). Assess third-party advice critically. Establish a process to cast votes consistent with voting policy. Do not borrow/lend shares for voting purposes. Periodic reporting of voting activities should include instances where they will not vote, potential conflicts of interest related to voting (and how to address these), and their approach to stock lending and recalling lent shares for voting purposes. Read MoreThis theme appears in principle 3 of the stewardship code.
Regular/effective investee communication – Canada	Engage with portfolio companies and consider when and how to escalate	Establish the threshold nature (e.g., investment size) and level of concern that will prompt engagement and consider who to engage with (independent directors, management or controlling shareholders). Concerns may include corporate governance (including shareholder rights), board composition/independence, board oversight of strategy/risk (including ESG), and the board's approach to executive compensation. Incorporate the PM and responsible investment professional expertise into engagement activities. Require prior consent to receive material non-public information Consider how/when to escalate if a board is unresponsive, including via voting against (where legally permitted) or withholding votes from directors or voting against management say-on-pay resolutions, speaking at shareholder meetings, making public statements, supporting/submitting shareholder proposals, requisitioning a special shareholder meeting, nominating one or more directors by proxy access where available, or by requisitioning a special, shareholders meeting or submitting a shareholder proposal, seeking governance improvements, including through possible legal remedies. Read MoreThis theme appears in principle 4 of the stewardship code.
Escalation – Canada	Engage with portfolio companies and consider when and how to escalate	Establish the threshold nature (e.g., investment size) and level of concern that will prompt engagement and consider who to engage with (independent directors, management or controlling shareholders). Concerns may include corporate governance (including shareholder rights), board composition/independence, board oversight of strategy/risk (including ESG), and the board's approach to executive compensation. Incorporate the PM and responsible investment professional expertise into engagement activities. Require prior consent to receive material non-public information Consider how/when to escalate if a board is unresponsive, including via voting against (where legally permitted) or withholding votes from directors or voting against management say-on-pay resolutions, speaking at shareholder meetings, making public statements, supporting/submitting shareholder proposals, requisitioning a special shareholder meeting, nominating one or more directors by proxy access where available, or by requisitioning a special, shareholders meeting or submitting a shareholder proposal, seeking governance improvements, including through possible legal remedies. Read MoreThis theme appears in principle 4 of the stewardship code.
Collective engagement – Canada	Collaborate with other IIs where appropriate	Collaborate directly with other investors, domestic or foreign, or indirectly by joining investor associations (e.g. Canadian Coalition for Good Governance). Read MoreThis theme appears in principle 5 of the stewardship code.
ESG integration – Canada	IIs should focus on promoting the creation of long term sustainable value	Focus on a company's long-term success/sustainable value (vs. short-term considerations), including understanding the company's strategy. Understand the risk and opportunities associated with material sustainability factors, including ESG issues, and integrate them into their investment and stewardship activities. Be aware of systemic risks that can affect the investee companies Read MoreThis theme appears in principle 7 of the stewardship code.
Materiality – Canada	IIs should focus on promoting the creation of long term sustainable value	Focus on a company's long-term success/sustainable value (vs. short-term considerations), including understanding the company's strategy. Understand the risk and opportunities associated with material sustainability factors, including ESG issues, and integrate them into their investment and stewardship activities. Be aware of systemic risks that can affect the investee companies Read MoreThis theme appears in principle 7 of the stewardship code.
Promote long-term value creation – Canada	IIs should focus on promoting the creation of long term sustainable value	Focus on a company's long-term success/sustainable value (vs. short-term considerations), including understanding the company's strategy. Understand the risk and opportunities associated with material sustainability factors, including ESG issues, and integrate them into their investment and stewardship activities. Be aware of systemic risks that can affect the investee companies Read MoreThis theme appears in principle 7 of the stewardship code.
Work with policymakers and regulators – Canada	IIs should engage with regulators and other policy makers where appropriate	Ensure policymakers and regulators consider the shareholder perspective when developing new laws and policies Work to improve the existing regulatory environment to protect shareholder rights and improve II ability to fulfill stewardship obligations. Consider when it is appropriate to collaborate with other IIs or through investor organizations like CCGG to increase the effectiveness and efficiency of engaging with policy makers. Read MoreThis theme appears in principle 6 of the stewardship code.
Facilitate remediation – Canada	Engage with portfolio companies and consider when and how to escalate	Establish the threshold nature (e.g., investment size) and level of concern that will prompt engagement and consider who to engage with (independent directors, management or controlling shareholders). Concerns may include corporate governance (including shareholder rights), board composition/independence, board oversight of strategy/risk (including ESG), and the board's approach to executive compensation. Incorporate the PM and responsible investment professional expertise into engagement activities. Require prior consent to receive material non-public information Consider how/when to escalate if a board is unresponsive, including via voting against (where legally permitted) or withholding votes from directors or voting against management say-on-pay resolutions, speaking at shareholder meetings, making public statements, supporting/submitting shareholder proposals, requisitioning a special shareholder meeting, nominating one or more directors by proxy access where available, or by requisitioning a special, shareholders meeting or submitting a shareholder proposal, seeking governance improvements, including through possible legal remedies. Read MoreThis theme appears in principle 4 of the stewardship code.
Investor internal incentives (compensation) – Canada	Develop, implement, and disclose an approach to stewardship	Integrate a procedure for voting proxies, engaging with companies, outsourcing stewardship activities, reporting to clients, managing potential conflicts of interest, and aligning compensation with stewardship principles. Engage with investee companies by monitoring strategy and risk oversight (including ESG and financial risk), performance, governance framework, and compensation. Regularly monitor outsourced stewardship activities to ensure consistency with stewardship approach. Set out expectations for stewardship activities in mandates between AOs and AMs. Disclose to beneficiaries the internal governance structures and processes for stewardship Report periodically on stewardship activities to beneficiaries. Explain how activities aim to protect long-term sustainable value. Implement mechanisms to deal with conflicts of interest, including identifying and managing them and putting clients first. Establish structures and processes to ensure compensation programs are properly aligned with the goal of enhancing the long term sustainable value of the IIs' assets (including appropriate benchmarks and risk mitigation). Read MoreThis theme appears in principle 1 of the stewardship code.
Voting policy and disclosure – Denmark	Voting policy: Adopt a voting policy and be willing to publicly disclose voting	Supporting the board should not be the default position. If unable to achieve a satisfactory outcome through dialogue, consider voting at a general meeting. Consider information the board of intentions and reasons for abstaining from voting or voting against board recommendations. Include the policy for stock lending and recalling lent stock re: voting at general meetings in the voting policy. Read MoreThis theme appears in principle 5 of the stewardship code.
Disclose stewardship policies – Denmark	Engagement Policy: Publicly disclose an engagement policy for investments in shares of companies that are publicly listed in Denmark	Stewardship activities may include monitoring/dialogue with companies, investor collaboration, participation/voting at general meetings, and buy/sell decisions. Engagement should explain how the investor exercises stewardship and how stewardship fits into the investment process. The policy should describe circumstances that affect stewardship: the importance of the principle of proportionality (vs. portfolio allocation); the no of shares held in the relevant company; and an assessment of the need to influence on company operations/strategy based on corporate governance and investment strategy (e.g. active vs. passive) and investment method (e.g. direct vs. synthetic exposures). Regardless of outsourcing to external managers or proxy advisors, ultimate responsibility for stewardship remains with the investor. Disclose use of service providers (voting advisory services), how the service provider is used to engage, and which steps are taken to ensure outsourced activities are carried out in accordance with the engagement policy. Investors may have one engagement policy covering investments in publicly listed companies in and outside Denmark, but should clarify that the policy (also) applies to shares publicly listed in Denmark. The engagement policy may be combined with other policies, guidelines, etc. provided that it is clear that there is an engagement policy. Read MoreThis theme appears in principle 1 of the stewardship code.
Fiduciary duty – Denmark	Conflicts of interest: describe how stewardship conflicts of interest are identified/ managed	Have procedures for the identification and management of conflicts of interest to safeguard interests of clients and beneficiaries. Conflicts of interest with businesses that may be clients, where the business is directly/indirectly represented in the II's management, or when exercising stewardship within a group of companies or in relation to competitors If how conflicts of interest are identified and managed re: stewardship is already publicly available, the engagement policy may simply refer to that Read MoreThis theme appears in principle 6 of the stewardship code.
Monitor investees – Denmark	Monitoring and dialogue: Monitor/engage with the companies in portfolio, taking into account investment strategy and principle of proportionality	Relevant engagement topics may include strategy, performance, risk, capital structure, corporate governance/culture/social responsibility (cf. Section 99 a-b of the Financial Statements Act), and management pay. Consider all material information that the company discloses, e.g., annual semi-annual, and quarterly reports; notices, investor presentations and the company's corporate governance statement (cf. Section 107 b of the Financial Statements Act). If willing to be given insider status in certain situations, indicate that willingness, and explain how the company would act (cf. Principle 1) in the engagement policy. The exchange of inside information and other forms of dialogue between investors and companies must be carried out in accordance with applicable law relating to the disclosure of inside information and equal treatment of investors. Read MoreThis theme appears in principle 2 of the stewardship code.
Conflicts of interest policy – Denmark	Conflicts of interest: describe how stewardship conflicts of interest are identified/managed	Have procedures for the identification and management of conflicts of interest to safeguard interests of clients and beneficiaries. Conflicts of interest with businesses that may be clients, where the business is directly/indirectly represented in the II's management, or when exercising stewardship within a group of companies or in relation to competitors If how conflicts of interest are identified and managed re: stewardship is already publicly available, the engagement policy may simply refer to that Read MoreThis theme appears in principle 6 of the stewardship code.
Report on stewardship to beneficiaries – Denmark	Reporting (including on voting): at least annually	Establish transparency in stewardship reporting via qualitative and quantitative information (without disclosing confidential information). Choose and publicly disclose (via website or annual report) an appropriate summary reporting method. The stewardship report should be based on the engagement policy and mention any deviations from it. The report should disclose voting advisory services (extent of services, suppliers, degree to which the advisor's recommendations have been followed when voting/engaging in dialogue) and any deviations from the voting policy. If the investor discloses stewardship activities, e.g. as part of reporting in accordance with international guidelines or standards, reference can be made to that disclosure. Read MoreThis theme appears in principle 7 of the stewardship code.
Regular/effective investee communication – Denmark	Monitoring and dialogue: Monitor/engage with the companies in portfolio, taking into account investment strategy and principle of proportionality	Relevant engagement topics may include strategy, performance, risk, capital structure, corporate governance/culture/social responsibility (cf. Section 99 a-b of the Financial Statements Act), and management pay. Consider all material information that the company discloses, e.g., annual semi-annual, and quarterly reports; notices, investor presentations and the company's corporate governance statement (cf. Section 107 b of the Financial Statements Act). If willing to be given insider status in certain situations, indicate that willingness, and explain how the company would act (cf. Principle 1) in the engagement policy. The exchange of inside information and other forms of dialogue between investors and companies must be carried out in accordance with applicable law relating to the disclosure of inside information and equal treatment of investors. Read MoreThis theme appears in principle 2 of the stewardship code.
Escalation – Denmark	Escalation: determine how to escalate stewardship beyond regular monitoring/dialogue	Consider whether to escalate via: (a) additional meetings specifically to discuss concerns; (b) meetings with board chair; (c) escalating in collaboration with other investors; (d) presenting/submitting resolutions at general meetings; (e) making public statements, e.g. in advance of general meetings; (f) requesting a general meeting or proposing to change board membership; (g) selling the shares; or (h) adding company to publicly available exclusion list (if sale of shares due to systematic lack of compliance)This theme appears in principle 3 of the stewardship code.
Collective engagement – Denmark	Collaboration with other investors: Describe how they will act collectively to achieve greater effect and impact as part of the engagement policy	Be careful not to act in concert according to the provisions on mandatory takeover bids, if the collaboration with other investors is carried out in connection with the acquisition of shares in the company concerned, as this may trigger being required to make a takeover bid. It is only relevant to consider ESMA's 'White List' if the collaboration with other investors is carried out in connection with acquisition of shares or other kinds of stake building in the company in question. (See ESMA published a 'White List' (November 2013) of activities that investors are able to carry out in collaboration with other investors without triggering mandatory takeover bids.) Read MoreThis theme appears in principle 4 of the stewardship code.
Voting policy and disclosure – Hong Kong	Voting policies	Seek to vote all shares held (even when it's appropriate to vote some shares for and others against a resolution) or disclose to stakeholders why not. Do not automatically support the board 4. lf engagement fails, abstain or vote against relevant resolutions at shareholder meetings. 5. If proxy voting or other voting advisory services is used, consider advice vs. automatically following it. lf engagement fails, abstain or vote against relevant resolutions at shareholder meetings. If proxy voting or other voting advisory services is used, consider advice vs. automatically following it. Read MoreThis theme appears in principle 4 of the stewardship code.
Disclose stewardship policies – Hong Kong	Establish and report to stakeholders stewardship policies	Establish stewardship policies, considering role and scope. Where a company or entity invests its own funds, its stakeholders will its board and potentially its shareholders. If the entity is accountable to the public, stakeholders may also include the public generally. Stakeholders include clients managed by investors (e.g., subadvisors and retirement funds), beneficiaries of funds received from the investor's direct clients, and potentially investors in retail equity-linked notes. Consider reporting via website vs. to stakeholders individually. Where outsourcing, report (a) how ensure ownership is in accordance with the policy, (b) minimum policy requirements for discharging ownership responsibilities, and (c) how/where AMs disclose stewardship policies or include AM information in reports. Disclose ownership responsibility policy and only update the disclosure when the policy changes. Read MoreThis theme appears in principle 1 of the stewardship code.
Fiduciary duty – Hong Kong	Have conflict of interest policy	Act in the interests of client or beneficiaries Have a policy for identifying and managing conflicts of interests that may affect stewardship Read MoreThis theme appears in principle 7 of the stewardship code.
Monitor investees – Hong Kong	lnvestors should monitor and engage with their investee companies	Monitor and engage on strategy, performance, risk, capital structure, corporate governance, etc. Have clear policies on CG principles and practices and on how they will engage with their investee companies if they have concerns about their CG practices. Consider any departures from the CG Coder set out in the Rules Governing the Listing of Securities on the Stock Exchange of Hong Kong Limited (Listing Rules). Encourage investee to have ESG policies. Engage on significant ESG issues with potential impact on goodwill/reputation/performance. When monitoring companies, aim to: (a) keep abreast of the companies' performance and internal/external developments that drive value/risks; (b) ensure that leadership and CG structures/practices are effective; (e) consider reporting quality; and (f) attend shareholder meetings Engagement includes (a) letters to/dialogues with management, (b) using the media, (c) speaking/proposing resolutions/voting at general meetings, (d) selling shares, and (e) in extreme cases, litigation. Ensure that outsourced engagement is compliant with stewardship policies. Engagement should not include seeking inside information, as per Part XIVA of the Securities and Futures Ordinance (Cap. 571) (SFO). Manage communication accordingly. If material nonpublic information is provided, safeguard that information, including via Chinese walls, temporary trading ban, or warning investee of breach. Read MoreThis theme appears in principle 2 of the stewardship code.
Conflicts of interest policy – Hong Kong	Have conflict of interest policy	Act in the interests of client or beneficiaries Have a policy for identifying and managing conflicts of interests that may affect stewardship Read MoreThis theme appears in principle 7 of the stewardship code.
Report on stewardship to beneficiaries – Hong Kong	Report to stakeholders on stewardship	Report annually on stewardship. Report voting (a) company-by-company or (b) degree of compliance with voting policy with details on significant departures. Where investment activities are outsourced, report (a) steps to ensure that AMs compliant with stewardship policy and (b) (i) how/where AMs disclose their periodic stewardship reports or (ii) information provided by AMs. Read MoreThis theme appears in principle 6 of the stewardship code.
Regular/effective investee communication – Hong Kong	lnvestors should monitor and engage with their investee companies	Monitor and engage on strategy, performance, risk, capital structure, corporate governance, etc. Have clear policies on CG principles and practices and on how they will engage with their investee companies if they have concerns about their CG practices. Consider any departures from the CG Coder set out in the Rules Governing the Listing of Securities on the Stock Exchange of Hong Kong Limited (Listing Rules). Encourage investee to have ESG policies. Engage on significant ESG issues with potential impact on goodwill/reputation/performance. When monitoring companies, aim to: (a) keep abreast of the companies' performance and internal/external developments that drive value/risks; (b) ensure that leadership and CG structures/practices are effective; (e) consider reporting quality; and (f) attend shareholder meetings Engagement includes (a) letters to/dialogues with management, (b) using the media, (c) speaking/proposing resolutions/voting at general meetings, (d) selling shares, and (e) in extreme cases, litigation. Ensure that outsourced engagement is compliant with stewardship policies. Engagement should not include seeking inside information, as per Part XIVA of the Securities and Futures Ordinance (Cap. 571) (SFO). Manage communication accordingly. If material nonpublic information is provided, safeguard that information, including via Chinese walls, temporary trading ban, or warning investee of breach. Read MoreThis theme appears in principle 2 of the stewardship code.
Escalation – Hong Kong	Consider and establish clear policies on when to escalate engagement activities	Establish conditions for engagement, regardless of active or passive investment policy, and regularly assess outcomes Engage on concerns on strategy, performance, governance, remuneration or approach to risks, including ESG. lnitial discussions should be confidential. If unsuccessful, consider engagement, including: (a) meeting management or board members specifically to discuss concerns; (b) expressing concerns via company advisers or pre-general meeting public statement; (c) collectively engaging; (d) submitting resolutions and speaking at general meetings; and (e) requisitioning a general meeting and proposing to change board membership. Read MoreThis theme appears in principle 3 of the stewardship code.
Collective engagement – Hong Kong	Act collectively where appropriate	If deemed the most effective way to engage (during times of significant corporate/wider economic stress or with significant risks), collaborateThis theme appears in principle 5 of the stewardship code.
ESG integration – Hong Kong	lnvestors should monitor and engage with their investee companies	Monitor and engage on strategy, performance, risk, capital structure, corporate governance, etc. Have clear policies on CG principles and practices and on how they will engage with their investee companies if they have concerns about their CG practices. Consider any departures from the CG Coder set out in the Rules Governing the Listing of Securities on the Stock Exchange of Hong Kong Limited (Listing Rules). Encourage investee to have ESG policies. Engage on significant ESG issues with potential impact on goodwill/reputation/performance. When monitoring companies, aim to: (a) keep abreast of the companies' performance and internal/external developments that drive value/risks; (b) ensure that leadership and CG structures/practices are effective; (e) consider reporting quality; and (f) attend shareholder meetings Engagement includes (a) letters to/dialogues with management, (b) using the media, (c) speaking/proposing resolutions/voting at general meetings, (d) selling shares, and (e) in extreme cases, litigation. Ensure that outsourced engagement is compliant with stewardship policies. Engagement should not include seeking inside information, as per Part XIVA of the Securities and Futures Ordinance (Cap. 571) (SFO). Manage communication accordingly. If material nonpublic information is provided, safeguard that information, including via Chinese walls, temporary trading ban, or warning investee of breach. Read MoreThis theme appears in principle 2 of the stewardship code.
Facilitate remediation – Hong Kong	lnvestors should monitor and engage with their investee companies	Monitor and engage on strategy, performance, risk, capital structure, corporate governance, etc. Have clear policies on CG principles and practices and on how they will engage with their investee companies if they have concerns about their CG practices. Consider any departures from the CG Coder set out in the Rules Governing the Listing of Securities on the Stock Exchange of Hong Kong Limited (Listing Rules). Encourage investee to have ESG policies. Engage on significant ESG issues with potential impact on goodwill/reputation/performance. When monitoring companies, aim to: (a) keep abreast of the companies' performance and internal/external developments that drive value/risks; (b) ensure that leadership and CG structures/practices are effective; (e) consider reporting quality; and (f) attend shareholder meetings Engagement includes (a) letters to/dialogues with management, (b) using the media, (c) speaking/proposing resolutions/voting at general meetings, (d) selling shares, and (e) in extreme cases, litigation. Ensure that outsourced engagement is compliant with stewardship policies. Engagement should not include seeking inside information, as per Part XIVA of the Securities and Futures Ordinance (Cap. 571) (SFO). Manage communication accordingly. If material nonpublic information is provided, safeguard that information, including via Chinese walls, temporary trading ban, or warning investee of breach. Read MoreThis theme appears in principle 2 of the stewardship code.
Voting policy and disclosure – India	Establish a voting policy and disclose voting activity.	Vote based on judgment of how to promote shareholder value (vs. automatically support management). Disclose voting policy and approach to stock lending and recalling lent stock.This theme appears in principle 6 of the stewardship code.
Disclose stewardship policies – India	Create and publicly disclose a stewardship policy.	Include the following in stewardship policy: stewardship responsibilities and how to fulfill them to enhance wealth of clients; clear threshold for intervention (unless insurer engages in all cases); whether insurer will use external service providers (and if so, that ultimate stewardship responsibilities are the insurer's) Secure board approval for stewardship policy Read MoreThis theme appears in principle 1 of the stewardship code.
Fiduciary duty – India	Create and publicly disclose a stewardship policy.	Include the following in stewardship policy: stewardship responsibilities and how to fulfill them to enhance wealth of clients; clear threshold for intervention (unless insurer engages in all cases); whether insurer will use external service providers (and if so, that ultimate stewardship responsibilities are the insurer's) Secure board approval for stewardship policy Read MoreThis theme appears in principle 1 of the stewardship code.
Monitor investees – India	Monitor investee companies.	Have mechanisms for regular monitoring of investee performance, leadership effectiveness, succession planning, corporate governance, reporting, etc. Consider greater participation via nominating its representatives onto the board. Indicate willingness to do so on stewardship statement and how this could be done. Read MoreThis theme appears in principle 3 of the stewardship code.
Conflicts of interest policy – India	Establish and publicly disclose a conflicts of interest policy re: stewardship.	Maintain and publicly disclose conflicts of interest policy that includes identifying likely conflict of interest and how to manage themThis theme appears in principle 2 of the stewardship code.
Report on stewardship to beneficiaries – India	Report periodically on stewardship activities.	Periodically report to beneficiaries on stewardship activities as part of public disclosures.This theme appears in principle 7 of the stewardship code.
Regular/effective investee communication – India	Have a clear policy on intervention in investee companies.	Determine engagement strategy, including criteria for active intervention. Include regular assessment of intervention in policy. Consider intervention regardless of active or passive investment policy. Intervene if concerned about investee strategy, performance, governance, remuneration or approach to risks (including ESG). First meet confidentially and try to resolve issues constructively. If this fails, escalate according to pre-defined policy. Read MoreThis theme appears in principle 4 of the stewardship code.
Escalation – India	Have a clear policy on intervention in investee companies.	Determine engagement strategy, including criteria for active intervention. Include regular assessment of intervention in policy. Consider intervention regardless of active or passive investment policy. Intervene if concerned about investee strategy, performance, governance, remuneration or approach to risks (including ESG). First meet confidentially and try to resolve issues constructively. If this fails, escalate according to pre-defined policy. Read MoreThis theme appears in principle 4 of the stewardship code.
Collective engagement – India	Have and disclose collective engagement policy.	Collectively engage if most effective. Have a policy to guide actions and extent of engagement.This theme appears in principle 5 of the stewardship code.
ESG integration – India	Have a clear policy on intervention in investee companies.	Determine engagement strategy, including criteria for active intervention. Include regular assessment of intervention in policy. Consider intervention regardless of active or passive investment policy. Intervene if concerned about investee strategy, performance, governance, remuneration or approach to risks (including ESG). First meet confidentially and try to resolve issues constructively. If this fails, escalate according to pre-defined policy. Read MoreThis theme appears in principle 4 of the stewardship code.
Board/governance and business management – India	Create and publicly disclose a stewardship policy.	Include the following in stewardship policy: stewardship responsibilities and how to fulfill them to enhance wealth of clients; clear threshold for intervention (unless insurer engages in all cases); whether insurer will use external service providers (and if so, that ultimate stewardship responsibilities are the insurer's) Secure board approval for stewardship policy Read MoreThis theme appears in principle 1 of the stewardship code.
Voting policy and disclosure – Italy	Exercise voting rights in a considered way.	Have an effective and adequate strategy for voting solely in client/beneficiary interests, including (a) monitor corporate actions; (b) vote in compliance with investment policies Vote uniformly for all shares held of a particular issuer. Abstain or vote no on resolutions not in client interests Consider engaging with investee management before voting no Read MoreThis theme appears in principle 5 of the stewardship code.
Disclose stewardship policies – Italy	Have a publicly disclosed ownership rights policy	Have a documented policy on how to exercise ownership rights on the website that specifies: (a) how to monitor listed investee; (b) how to manage conflicts of interest;[3] (c) how to handle insider information; (d) securities lending and return of loaned securities; (d) intervention strategy; (e) collective engagement approach; (f) voting rights strategy, including via mandate or voting consulting services. If investment managers have external governance issues in mandates, they must comply with the terms of the mandates Read MoreThis theme appears in principle 1 of the stewardship code.
Fiduciary duty (1) – Italy	Establish clear guidelines on when and how to actively intervene	Establish the circumstances that require active intervention. Determine whether/how to communicate any issue/problem with the competent members, including minority members, of the administrative and control bodies. Consider intervening when significant worries regarding the strategy and performance of investee listed issuers, or in regards to their governance or approach to environmental and social issues. Divestment from an investee issuer may also be appropriate. Initial discussions could include: (a) organizing meetings with the management and IR; (b) share worries via issuer's consultants; (c) meeting with competent members of administrative and auditing bodies via a procedure that (i) prevents insider information disclosure and (ii) notifies companies about meeting content/methods. Escalation could include (a) releasing a public declaration before/after GM; (b) presenting solution at shareholder meeting; (c) requesting a GM ensuring no insider information release. Read MoreThis theme appears in principle 3 of the stewardship code.
Fiduciary duty (2) – Italy	Exercise voting rights in a considered way.	Have an effective and adequate strategy for voting solely in client/beneficiary interests, including (a) monitor corporate actions; (b) vote in compliance with investment policies Vote uniformly for all shares held of a particular issuer. Abstain or vote no on resolutions not in client interests Consider engaging with investee management before voting no Read MoreThis theme appears in principle 5 of the stewardship code.
Monitor investees – Italy	Monitor investee companies.	Regularly monitor listed investees. Identifying issues in advance. Identify methods used to monitor financial data and CG issuers. Determine when to create an active dialogue with the respective administrative and/or auditing bodies. Include an adequate number of independent members, including minority members, within investee corporate bodies. Request that investees and their consultants do not provide insider information without prior consent. Read MoreThis theme appears in principle 2 of the stewardship code.
Conflicts of interest policy – Italy	Have a publicly disclosed ownership rights policy	Have a documented policy on how to exercise ownership rights on the website that specifies: (a) how to monitor listed investee; (b) how to manage conflicts of interest (Pursuant to article 25 of the Regulation on the organisation and intermediary procedures providing investment services or collective investment management services and in compliance with the Protocol of Autonomy on management of conflicts of interest); (c) how to handle insider information; (d) securities lending and return of loaned securities; (d) intervention strategy; (e) collective engagement approach; (f) voting rights strategy, including via mandate or voting consulting services. If investment managers have external governance issues in mandates, they must comply with the terms of the mandates Read MoreThis theme appears in principle 1 of the stewardship code.
Report on stewardship to beneficiaries (1) – Italy	Report on stewardship and voting and have policy on external governance disclosure.	Report stewardship strategy and methods and both qualitative and quantitative information Agree with beneficiaries what information to provide (including votes exercised) Do not divulge information that could be counter-productive Read MoreThis theme appears in principle 6 of the stewardship code.
Report on stewardship to beneficiaries (2) – Italy	Establish clear guidelines on when and how to actively intervene	Establish the circumstances that require active intervention. Determine whether/how to communicate any issue/problem with the competent members, including minority members, of the administrative and control bodies. Consider intervening when significant worries regarding the strategy and performance of investee listed issuers, or in regards to their governance or approach to environmental and social issues. Divestment from an investee issuer may also be appropriate. Initial discussions could include: (a) organizing meetings with the management and IR; (b) share worries via issuer's consultants; (c) meeting with competent members of administrative and auditing bodies via a procedure that (i) prevents insider information disclosure and (ii) notifies companies about meeting content/methods. Escalation could include (a) releasing a public declaration before/after GM; (b) presenting solution at shareholder meeting; (c) requesting a GM ensuring no insider information release. Read MoreThis theme appears in principle 3 of the stewardship code.
Regular/effective investee communication – Italy	Establish clear guidelines on when and how to actively intervene	Establish the circumstances that require active intervention. Determine whether/how to communicate any issue/problem with the competent members, including minority members, of the administrative and control bodies. Consider intervening when significant worries regarding the strategy and performance of investee listed issuers, or in regards to their governance or approach to environmental and social issues. Divestment from an investee issuer may also be appropriate. Initial discussions could include: (a) organizing meetings with the management and IR; (b) share worries via issuer's consultants; (c) meeting with competent members of administrative and auditing bodies via a procedure that (i) prevents insider information disclosure and (ii) notifies companies about meeting content/methods. Escalation could include (a) releasing a public declaration before/after GM; (b) presenting solution at shareholder meeting; (c) requesting a GM ensuring no insider information release. Read MoreThis theme appears in principle 3 of the stewardship code.
Escalation – Italy	Establish clear guidelines on when and how to actively intervene	Establish the circumstances that require active intervention. Determine whether/how to communicate any issue/problem with the competent members, including minority members, of the administrative and control bodies. Consider intervening when significant worries regarding the strategy and performance of investee listed issuers, or in regards to their governance or approach to environmental and social issues. Divestment from an investee issuer may also be appropriate. Initial discussions could include: (a) organizing meetings with the management and IR; (b) share worries via issuer's consultants; (c) meeting with competent members of administrative and auditing bodies via a procedure that (i) prevents insider information disclosure and (ii) notifies companies about meeting content/methods. Escalation could include (a) releasing a public declaration before/after GM; (b) presenting solution at shareholder meeting; (c) requesting a GM ensuring no insider information release. Read MoreThis theme appears in principle 3 of the stewardship code.
Collective engagement – Italy	Cooperate with other investors.	Use carry out collective engagement for significant corporate events/issues of public interest, when substantial risks. Consider carrying out monitoring, intervention and engagement action collectively or via participation in the activities of Assogestioni's CG and Investment Managers' Committees (Assogestioni = Italian investment management industry association). Take market regulations and own policies re: conflicts of interest and insider information into account. Read MoreThis theme appears in principle 4 of the stewardship code.
ESG integration – Italy	Establish clear guidelines on when and how to actively intervene	Establish the circumstances that require active intervention. Determine whether/how to communicate any issue/problem with the competent members, including minority members, of the administrative and control bodies. Consider intervening when significant worries regarding the strategy and performance of investee listed issuers, or in regards to their governance or approach to environmental and social issues. Divestment from an investee issuer may also be appropriate. Initial discussions could include: (a) organizing meetings with the management and IR; (b) share worries via issuer's consultants; (c) meeting with competent members of administrative and auditing bodies via a procedure that (i) prevents insider information disclosure and (ii) notifies companies about meeting content/methods. Escalation could include (a) releasing a public declaration before/after GM; (b) presenting solution at shareholder meeting; (c) requesting a GM ensuring no insider information release. Read MoreThis theme appears in principle 3 of the stewardship code.
Voting policy and disclosure – Japan	IIs should have a clear policy on voting (including disclosure)	Seek to vote on all shares held and decide on the vote in light of the results of the monitoring of investee companies and dialogue with them. Have a clear policy on voting and publicly disclose it. The policy should be clearly articulated and should not be comprised only of a mechanical checklist: it should be designed to contribute to sustainable growth of the investee company. Aggregate the voting records into each major kind of proposal, and publicly disclose them (at minimum). Disclose voting records for each investee company on an individual agenda item basis. If there is reason to believe it inappropriate to disclose proactively explain the reason. At the time of their voting records disclosures, it is beneficial to explicitly explain the reasons why they voted for or against an agenda item. There should not be dependence on proxy advisors' recommendations when exercising voting rights, rather votes should be based on the results of the monitoring of the investee companies and dialogue with them. Use of proxy advisors should be disclosed along with voting activities. Proxy advisors should dedicate sufficient management resources to ensure sound judgement in the evaluation of companies and furnish their services appropriately. Principles of the Code apply to proxy advisors, and proxy advisors should disclose their approach to providing the services including the operational structure, the management of conflicts of interest and procedures of developing voting recommendations. Read MoreThis theme appears in principle 5 of the stewardship code.
Disclose stewardship policies – Japan	Have a clear publicly disclosed policy on how to fulfill stewardship responsibilities	Aim to improve long-term returns for clients via constructive engagement based on in-depth knowledge of the companies and their business environment. Have a publicly disclosed stewardship policy that should cover how to define and fulfill responsibility. Engage in stewardship activities directly. Otherwise, instruct AMs to effectively engage on their on their behalf. When selecting AMs, specify stewardship issues and principles, instead of accepting AM's policies without verification Monitor (emphasizing quality vs. no. of company meetings) whether AMs conduct stewardship activities in line policies. Make use of AM self-evaluations Read MoreThis theme appears in principle 1 of the stewardship code.
Fiduciary duty – Japan	Have a clear policy on how to manage conflicts of interest in fulfilling their stewardship responsibilities and publicly disclose it.	Put interests of clients and beneficiaries first in conducting stewardship activities. Manage conflicts of interest (e.g., when voting affects the business group of the II and a beneficiary) Publicly disclose a clear conflict of interest policies. AMs should identify specific conflicts of interest that may affect voting rights or strategic engagement AMs should establish governance structures (e.g., independent board, third-party committee for voting oversight) AM management should strengthen their own governance and manage conflicts of interest Read MoreThis theme appears in principle 2 of the stewardship code.
Monitor investees – Japan	Monitor investee companies to fulfill their stewardship responsibilities with the goal of sustainable growth	Appropriately monitor investees to fulfill stewardship responsibility (and enhance medium- to long-term value and capital efficiency and support sustainable company growth) Monitor investee companies and review monitoring effectiveness Monitor financial and nonfinancial factors: governance, strategy, performance, capital structure, business risks and opportunities (including ESG), and how the companies address them. Use judgement to determine which factors to focus on (based on investment policy and investee companies). Identify at an early stage issues that may result in material loss of investee company value. Read MoreThis theme appears in principle 3 of the stewardship code.
Conflicts of interest policy – Japan	Have a clear policy on how to manage conflicts of interest in fulfilling their stewardship responsibilities and publicly disclose it.	Put interests of clients and beneficiaries first in conducting stewardship activities. Manage conflicts of interest (e.g., when voting affects the business group of the II and a beneficiary) Publicly disclose a clear conflict of interest policies. AMs should identify specific conflicts of interest that may affect voting rights or strategic engagement AMs should establish governance structures (e.g., independent board, third-party committee for voting oversight) AM management should strengthen their own governance and manage conflicts of interest Read MoreThis theme appears in principle 2 of the stewardship code.
Report on stewardship to beneficiaries – Japan	Report periodically on stewardship, including voting responsibilities, to beneficiaries	AMs should report periodically to their direct clients on how they fulfill their stewardship responsibilities through their stewardship activities. AOs should report at least once a year to their beneficiaries on their stewardship policy and on how the policy is implemented. Institutional investors should choose the format and the content of the reports in light of any relevant agreement with the recipients and the recipients' convenience, and the costs associated with the reporting, and should aim to deliver effective and efficient reports. Institutional investors should maintain a clear record of their stewardship activities, including voting activities, to the extent necessary to fulfill their stewardship responsibilities. Read MoreThis theme appears in principle 6 of the stewardship code.
Regular/effective investee communication – Japan	Seek a common understanding with investee companies and to solve problems via constructive engagement	Arrive at a common understanding about the goal of enhancing company medium- to long-term value and capital efficiency and promoting sustainable growth. If identify possible loss in corporate value via monitoring/dialogue, request further dialogue to solve the problem. Because passive management provides limited options to sell investee companies' shares and needs to promote their medium- to long-term increase of corporate value, institutional investors should actively take charge of engagement and voting from a medium- to long-term perspective. Have a clear policy in advance on how they design dialogue with investee companies in various possible situations. Engage with investee companies in collaboration with other institutional investors (collective engagement) as necessary. The 'G20/OECD Principles of Corporate Governance' and the Tokyo Stock Exchange's 'Japan's Corporate Governance Code' set the principle of the equitable treatment of shareholders, which applies to the handling of undisclosed material facts (non-public information). Institutional investors should be aware of these principles and should be discreet in receiving information on undisclosed material facts. Read MoreThis theme appears in principle 4 of the stewardship code.
Collective engagement – Japan	Seek a common understanding with investee companies and to solve problems via constructive engagement	Arrive at a common understanding about the goal of enhancing company medium- to long-term value and capital efficiency and promoting sustainable growth. If identify possible loss in corporate value via monitoring/dialogue, request further dialogue to solve the problem. Because passive management provides limited options to sell investee companies' shares and needs to promote their medium- to long-term increase of corporate value, institutional investors should actively take charge of engagement and voting from a medium- to long-term perspective. Have a clear policy in advance on how they design dialogue with investee companies in various possible situations. Engage with investee companies in collaboration with other institutional investors (collective engagement) as necessary. The 'G20/OECD Principles of Corporate Governance' and the Tokyo Stock Exchange's 'Japan's Corporate Governance Code' set the principle of the equitable treatment of shareholders, which applies to the handling of undisclosed material facts (non-public information). Institutional investors should be aware of these principles and should be discreet in receiving information on undisclosed material facts. Read MoreThis theme appears in principle 4 of the stewardship code.
Promote long-term value creation – Japan	Have a clear publicly disclosed policy on how to fulfill stewardship responsibilities	Aim to improve long-term returns for clients via constructive engagement based on in-depth knowledge of the companies and their business environment. Have a publicly disclosed stewardship policy that should cover how to define and fulfill responsibility. Engage in stewardship activities directly. Otherwise, instruct AMs to effectively engage on their on their behalf. When selecting AMs, specify stewardship issues and principles, instead of accepting AM's policies without verification Monitor (emphasizing quality vs. no. of company meetings) whether AMs conduct stewardship activities in line policies. Make use of AM self-evaluations Read MoreThis theme appears in principle 1 of the stewardship code.
Build capacity to engage effectively – Japan	Have in-depth knowledge of the investee companies, their business environment, and the skills/resources needed for engagement	Develop skills and resources and have the necessary internal structure needed to appropriately engage with the companies and to make proper judgments based on in-depth knowledge of the companies and their business environment. The management of institutional investors should have appropriate capability and experience to effectively fulfill their stewardship responsibilities, and should be constituted independently and without bias, in particular from their affiliated financial groups. The management of institutional investors should also recognize the important role and responsibility they have to stewardship activities such as enhancing dialogue, structure their organizations and develop human resources, and take action on these issues. Exchanging views with other investors and having a forum for the purpose may help institutional investors conduct better engagement with investee companies and make better judgments. Endeavor to improve their policies based on the Code and the quality of their stewardship activities by reviewing at an appropriate timing the status of their implementation of each principle, including guidance. AMs should regularly conduct self-evaluations on the status of their implementation of each principle, including guidance, and disclose the results toward continued improvement of their governance structures, conflicts of interest management, and stewardship activities, etc. Read MoreThis theme appears in principle 7 of the stewardship code.
Board/governance and business management – Japan	Have a clear policy on how to manage conflicts of interest in fulfilling their stewardship responsibilities and publicly disclose it.	Put interests of clients and beneficiaries first in conducting stewardship activities. Manage conflicts of interest (e.g., when voting affects the business group of the II and a beneficiary) Publicly disclose a clear conflict of interest policies. AMs should identify specific conflicts of interest that may affect voting rights or strategic engagement AMs should establish governance structures (e.g., independent board, third-party committee for voting oversight) AM management should strengthen their own governance and manage conflicts of interest Read MoreThis theme appears in principle 2 of the stewardship code.
Voting policy and disclosure – Kenya	Active and informed voting guidelines and practices	Voting shall cover all shares held, and this shall be reflected in the overarching stewardship policy. Develop voting guidelines that (a) reflect the broad principles of the CG, as presented in the Corporate Governance Code; (b) are relevant to shareholder resolutions; (c) guide on the types of governance practices that may justify voting for/against resolutions (director elections and remuneration, approval of financial statements, appointing the auditor, issuing capital, or other corporate actions). Voting guidelines may be separate from the broader stewardship policy and may be more granular and proprietary. Prepare to vote against/abstain from management resolutions that conflict with voting guidelines/good CG practices. Communicate why to investee, ideally before shareholder meeting. Disclosure voting record at least to clients, if not to the public as well. Do not borrow or lend shares for voting purposes. Read MoreThis theme appears in principle 3 of the stewardship code.
Disclose stewardship policies – Kenya	Stewardship and responsible investment policies	Develop and publicly disclose stewardship and responsible investment policy, which should include (a) investment analysis with ESG factors, (b) voting and shareholder meetings, (c) engagement, (d) conflicts of interest, (e) reporting Stewardship policies should be clear, specific, and explicitly endorsed by executive management. Indicate publicly that proprietary elements of the stewardship code exist, but no need to disclose the details. Read MoreThis theme appears in principle 1 of the stewardship code.
Fiduciary duty – Kenya	Focus on sustainability, including ESG	The Ethics and Social Responsibility section of the CG Code focuses on listed company contribution to social outcomes as a dimension of good CG. Accordingly, the Stewardship Code reflects the importance of IIs focusing on these sustainability factors as part of their monitoring of issuer compliance to the CG Code. Call for ethical and responsible investee conduct and build awareness/sensitivity re: long-term stakeholder impact. Focus on ESG factors that create material commercial risk or opportunity as part of fiduciary duty. IIs should act responsibly, both as a matter of ethics and as a way to promote greater systemic health and stability. Factor ESG performance into monitoring/voting/engagement activities. Relevance of ESG factors may depend on II's investment policy and specific investee. Consider advocating for adoption of integrated reporting (to link ESG factors to investee performance drivers). Call for more robust ESG factors and risk disclosure if such disclosure is too limited. Read MoreThis theme appears in principle 6 of the stewardship code.
Monitor investees – Kenya	Monitoring investees	Track investee performance, include internal and external developments. Regularly meet with investee management and directors on financial, strategic and governance matters (can be linked with engagement). Develop an understanding of management leadership and quality of board oversight. Develop an understanding of governance and minority investor rights. Monitor non-compliance with governance codes and assess the quality of explanation of non-compliance. Monitoring of this nature is key to the 'apply or explain' Code of Corporate Governance implementation. Assess financial and operational risks (including ESG) within traditional investment research and analysis. Read MoreThis theme appears in principle 2 of the stewardship code.
Conflicts of interest policy – Kenya	Conflicts of interest	Consider clients and end beneficiaries in the conflicts of interest policy Publicly disclose the conflicts of interest policy, which may be standalone or part of the broader stewardship policy. Avoid or minimize conflicts of interest with Chinese walls and segregation of duties. Take particular care in voting and engagement. Disclose how conflicts of interest are identified and overseen. Otherwise, be prepared to discuss this with clients and regulators. Read MoreThis theme appears in principle 5 of the stewardship code.
Report on stewardship to beneficiaries – Kenya	Public disclosures and client reporting	Confirm annually compliance to each of the seven principles of the Code to the Capital Markets Authority in a public statement on the II and Capital Markets Authority's websites. Systematically record engagement with issuers, investment analysis and voting activity. Disclose key aspects of this stewardship activity in regular client reporting. Publicly disclose key features of engagement activity at least annually. Consider publicly disclosing voting (best practice) External assurance of stewardship activities by an independent auditor is encouraged as best practice. Read MoreThis theme appears in principle 7 of the stewardship code.
Regular/effective investee communication – Kenya	Engagement, escalation and collaboration with other IIs	Engagement is constructive dialogue between IIs and issuers (a) in the form of face-to-face meetings, letters, emails, telephone conversations to various levels of the issuer, including management and the board (b) on any area relevant to investee ability to generate long-term returns, including strategy, risk, shareholder rights, board effectiveness, remuneration, ethics, and corporate responsibility. CG is a key area of engagement, particularly in cases of non-compliance with the Corporate Governance Code. Address engagement prioritization methodology (risk, holding size, etc.). Establish a clear approach for escalation and resolution; potentially including: meeting with board members; public statements; filing resolutions; requisitioning for general meetings; making portfolio decisions about individual holdings. Collectively engage if most effective, including via formal and informal associations Do not seek information that gives you an unfair advantage—engagement should benefit IIs and retail investors. Read MoreThis theme appears in principle 4 of the stewardship code.
Escalation – Kenya	Engagement, escalation and collaboration with other IIs	Engagement is constructive dialogue between IIs and issuers (a) in the form of face-to-face meetings, letters, emails, telephone conversations to various levels of the issuer, including management and the board (b) on any area relevant to investee ability to generate long-term returns, including strategy, risk, shareholder rights, board effectiveness, remuneration, ethics, and corporate responsibility. CG is a key area of engagement, particularly in cases of non-compliance with the Corporate Governance Code. Address engagement prioritization methodology (risk, holding size, etc.). Establish a clear approach for escalation and resolution; potentially including: meeting with board members; public statements; filing resolutions; requisitioning for general meetings; making portfolio decisions about individual holdings. Collectively engage if most effective, including via formal and informal associations Do not seek information that gives you an unfair advantage--engagement should benefit IIs and retail investors. Read MoreThis theme appears in principle 4 of the stewardship code.
Collective engagement – Kenya	Engagement, escalation and collaboration with other IIs	Engagement is constructive dialogue between IIs and issuers (a) in the form of face-to-face meetings, letters, emails, telephone conversations to various levels of the issuer, including management and the board (b) on any area relevant to investee ability to generate long-term returns, including strategy, risk, shareholder rights, board effectiveness, remuneration, ethics, and corporate responsibility. CG is a key area of engagement, particularly in cases of non-compliance with the Corporate Governance Code. Address engagement prioritization methodology (risk, holding size, etc.). Establish a clear approach for escalation and resolution; potentially including: meeting with board members; public statements; filing resolutions; requisitioning for general meetings; making portfolio decisions about individual holdings. Collectively engage if most effective, including via formal and informal associations Do not seek information that gives you an unfair advantage--engagement should benefit IIs and retail investors. Read MoreThis theme appears in principle 4 of the stewardship code.
ESG integration – Kenya	Focus on sustainability, including ESG	The Ethics and Social Responsibility section of the CG Code focuses on listed company contribution to social outcomes as a dimension of good CG. Accordingly, the Stewardship Code reflects the importance of IIs focusing on these sustainability factors as part of their monitoring of issuer compliance to the CG Code. Call for ethical and responsible investee conduct and build awareness/sensitivity re: long-term stakeholder impact. Focus on ESG factors that create material commercial risk or opportunity as part of fiduciary duty. IIs should act responsibly, both as a matter of ethics and as a way to promote greater systemic health and stability. Factor ESG performance into monitoring/voting/engagement activities. Relevance of ESG factors may depend on II's investment policy and specific investee. Consider advocating for adoption of integrated reporting (to link ESG factors to investee performance drivers). Call for more robust ESG factors and risk disclosure if such disclosure is too limited. Read MoreThis theme appears in principle 6 of the stewardship code.
Materiality – Kenya	Focus on sustainability, including ESG	The Ethics and Social Responsibility section of the CG Code focuses on listed company contribution to social outcomes as a dimension of good CG. Accordingly, the Stewardship Code reflects the importance of IIs focusing on these sustainability factors as part of their monitoring of issuer compliance to the CG Code. Call for ethical and responsible investee conduct and build awareness/sensitivity re: long-term stakeholder impact. Focus on ESG factors that create material commercial risk or opportunity as part of fiduciary duty. IIs should act responsibly, both as a matter of ethics and as a way to promote greater systemic health and stability. Factor ESG performance into monitoring/voting/engagement activities. Relevance of ESG factors may depend on II's investment policy and specific investee. Consider advocating for adoption of integrated reporting (to link ESG factors to investee performance drivers). Call for more robust ESG factors and risk disclosure if such disclosure is too limited. Read MoreThis theme appears in principle 6 of the stewardship code.
Understand investee stakeholder perspectives – Kenya	Focus on sustainability, including ESG	The Ethics and Social Responsibility section of the CG Code focuses on listed company contribution to social outcomes as a dimension of good CG. Accordingly, the Stewardship Code reflects the importance of IIs focusing on these sustainability factors as part of their monitoring of issuer compliance to the CG Code. Call for ethical and responsible investee conduct and build awareness/sensitivity re: long-term stakeholder impact. Focus on material ESG factors as part of fiduciary duty. IIs should act responsibly, both as a matter of ethics and as a way to promote greater systemic health and stability. Factor ESG performance into monitoring/voting/engagement activities. Relevance of ESG factors may depend on II's investment policy and specific investee. Consider advocating for adoption of integrated reporting (to link ESG factors to investee performance drivers). Call for more robust ESG factors and risk disclosure if such disclosure is too limited. Read MoreThis theme appears in principle 6 of the stewardship code.
Voting policy and disclosure – Malaysia	Publish voting policy	Exercise voting rights with due care. Disclose their overall voting policy, including procedures. Reach a clear decision for/against each resolution. Inform investee in writing of reasons for voting against or abstaining from any vote at a GM. Inform beneficiaries/clients if decision deviates from policies. Vote on shares held. Set a threshold for active voting. If abstain from voting in specific circumstances (e.g., particular markets, below threshold ownership), disclose to beneficiaries/clients. Disclose voting summary to beneficiaries. Disclose use of proxy voting/other voting advisory services (including scope of services, providers and the extent they follow recommendations). Work with other relevant parties if possible/lawful to remove voting barriers. Intermediary votes should be cast in accordance with beneficial owner wishes. Disclose approach to securities lending and situations where recall lent securities to vote. Read MoreThis theme appears in principle 6 of the stewardship code.
Disclose stewardship policies – Malaysia	Disclose stewardship policies	Stewardship policies should reflect activities along investment chain. Policies should be accessible to investees, beneficiaries, and clients in clear language. If outsourcing stewardship, explain stewardship compliance process for third-party service providers. For AOs: disclose guidelines for AM and other service provider selection. Read MoreThis theme appears in principle 1 of the stewardship code.
Fiduciary duty – Malaysia	Adopt and publicly disclose a robust conflicts of interest policy	Create, maintain and publicly disclose conflict of interest policy with the aim of advancing interests of clients. Inform service providers of the need to disclose conflicts of interest and how they are managed. Have policies on inside information, avoiding market manipulation, preventing corruption, anti-bribery/money laundering, and establishing a Chinese wall. Include in stewardship policies the mechanism for how an II can become involved in investee board/management to support investee long-term change, including managing conflicts of interest Read MoreThis theme appears in principle 4 of the stewardship code.
Monitor investees – Malaysia	Monitor investee companies	Actively monitor investees, including: (a) performance and its value drivers; (b) key risk areas; (c) leadership (board, management); (d) adherence to Malaysian Code on Corporate Governance 2012 (CG Code); (e) quality of company reporting and management discussion & analysis; (f) early signs of significant problems; (g) attending GMs where practicable and voting Consider explanations--or lack thereof--for departures from CG Code. Inform investee board in writing if disagree. Read MoreThis theme appears in principle 2 of the stewardship code.
Conflicts of interest policy – Malaysia	Adopt and publicly disclose a robust conflicts of interest policy	Create, maintain and publicly disclose conflict of interest policy with the aim of advancing interests of clients. Inform service providers of the need to disclose conflicts of interest and how they are managed. Have policies on inside information, avoiding market manipulation, preventing corruption, anti-bribery/money laundering, and establishing a Chinese wall. Include in stewardship policies the mechanism for how an II can become involved in investee board/management to support investee long-term change, including managing conflicts of interest Read MoreThis theme appears in principle 4 of the stewardship code.
Report on stewardship to beneficiaries – Malaysia	Engage investees as appropriate	Develop a clear engagement strategy/process/practices to facilitate more effective engagement. Keep proper engagement records. Report engagement highlights annually via annual report or company website. Engage with investees on concerns with financial/operational performance, governance, or risk management confidentially at first. Have a clear approach if this fails. Express concerns by (a) writing to the board; (b) meeting with board members; (c) engaging jointly with other IIs; (d) submitting resolutions and expressing concerns at GMs; (e) requisitioning a GM (potentially seek to remove poorly performing directors) Read MoreThis theme appears in principle 3 of the stewardship code.
Regular/effective investee communication – Malaysia	Engage investees as appropriate	Develop a clear engagement strategy/process/practices to facilitate more effective engagement. Keep proper engagement records. Report engagement highlights annually via annual report or company website. Engage with investees on concerns with financial/operational performance, governance, or risk management confidentially at first. Have a clear approach if this fails. Express concerns by (a) writing to the board; (b) meeting with board members; (c) engaging jointly with other IIs; (d) submitting resolutions and expressing concerns at GMs; (e) requisitioning a GM (potentially seek to remove poorly performing directors) Read MoreThis theme appears in principle 3 of the stewardship code.
Escalation – Malaysia	Engage investees as appropriate	Develop a clear engagement strategy/process/practices to facilitate more effective engagement. Keep proper engagement records. Report engagement highlights annually via annual report or company website. Engage with investees on concerns with financial/operational performance, governance, or risk management confidentially at first. Have a clear approach if this fails. Express concerns by (a) writing to the board; (b) meeting with board members; (c) engaging jointly with other IIs; (d) submitting resolutions and expressing concerns at GMs; (e) requisitioning a GM (potentially seek to remove poorly performing directors) Read MoreThis theme appears in principle 3 of the stewardship code.
ESG integration – Malaysia	Incorporate CG and sustainability considerations into investment decision processes	Incorporate CG and ESG factors in investment decision-making process. Assess the quality investee disclosures on CG code applications, including: (a) diversity (gender, age, ethnicity) targets and policies; (b) board remuneration and nomination policies/procedures; (c) board quality; (d) financial reporting; (e) risk management and internal controls Develop a policy on ESG integration into investment analysis/activities including: (a) quality of sustainability report (on strategy and operations) or explain lack of report; and (b) disclosure and adherence to any responsible investment codes. ESG factors may include: (a) CG and business ethics; (b) employee benefits and corporate culture; (c) products, customers, supply chain; (d) environmental and social impact Read MoreThis theme appears in principle 5 of the stewardship code.
Board/governance and business management – Malaysia	IIs should be led by capable board and management with appropriate capacity/experience to effectively discharge their stewardship duties.	None. Part of the code, but not part of principlesThis theme appears in principle 0 of the stewardship code.
Voting policy and disclosure (1) – Netherlands	Vote in informed manner. Publicly disclose (a) voting behavior at least annually and (b) voting on Dutch listed companies at least quarterly. If abstain from or vote against management resolution, explain why to management.	No guidance This theme appears in principle 7 of the stewardship code.
Voting policy and disclosure (2) – Netherlands	Publicly disclose voting policy and use of proxy research/voting services. If delegate voting, ensure votes in line with voting policy.	Be well informed about votes. Regularly evaluate that proxy advisors have robust processes, policies and capabilities for quality recommendations This theme appears in principle 10 of the stewardship code.
Voting policy and disclosure (3) – Netherlands	Do not borrow shares solely for voting. Abstain from voting if short position exceeds long position. Recall lent shares before voting registration date if there are controversial resolutions	No guidanceThis theme appears in principle 11 of the stewardship code.
Disclose stewardship policies – Netherlands	Create and publicly disclose stewardship policy on website	Aim to enhance and preserve value of clients/beneficiaries and promote long-term value at investee companies. If delegate stewardship, ensure AM undertaking stewardship via mandate. Publicly disclose certain key elements of this mandate.[5] If invest in mutual or investment funds (not directly in Dutch listed companies), ensure that fund managers have engagement policies in line with Dutch or similar code Read MoreThis theme appears in principle 1 of the stewardship code.
Fiduciary duty – Netherlands	Create and publicly disclose stewardship policy on website	Aim to enhance and preserve value of clients/beneficiaries and promote long-term value at investee companies. If delegate stewardship, ensure AM undertaking stewardship via mandate. Publicly disclose certain key elements of this mandate.[5] If invest in mutual or investment funds (not directly in Dutch listed companies), ensure that fund managers have engagement policies in line with Dutch or similar code Read MoreThis theme appears in principle 1 of the stewardship code.
Monitor investees – Netherlands	Monitor Dutch listed investees on material issues (e.g., business model, strategy, long-term performance/risks/opportunities, capital structure, ESG, and corporate actions)	No guidanceThis theme appears in principle 2 of the stewardship code.
Conflicts of interest policy – Netherlands	Identify/manage/remedy actual/potential conflicts of interest re: Dutch investee engagement and voting. Publicly disclose their conflicts of interest policy re: stewardship.	Be aware of potential conflicts of interest (e.g., offering insurance to investee) or shared board members.This theme appears in principle 6 of the stewardship code.
Regular/effective investee communication – Netherlands	Enter a dialogue, and escalate if dialogue does not resolve issues	Enter into dialogue with Dutch investees. If the dialogue is outside of general meeting, disclose full long and short equity holdings if the investee requests If issues remain unresolved, escalate, which may include: (a) writing to management; (b) meeting with management or other stakeholders; (c) expressing concerns at a general meeting or via public statement; (d) collective engagement; (e) adding to general meeting agenda or calling an extraordinary general meeting; (f) nominating management board members or supervisory directors; (g) taking legal action; (h) selling shares Read MoreThis theme appears in principle 3 of the stewardship code.
Escalation (1) – Netherlands	Enter a dialogue, and escalate if dialogue does not resolve issues	Enter into dialogue with Dutch investees. If the dialogue is outside of general meeting, disclose full long and short equity holdings if the investee requests If issues remain unresolved, escalate, which may include: (a) writing to management; (b) meeting with management or other stakeholders; (c) expressing concerns at a general meeting or via public statement; (d) collective engagement; (e) adding to general meeting agenda or calling an extraordinary general meeting; (f) nominating management board members or supervisory directors; (g) taking legal action; (h) selling shares Read MoreThis theme appears in principle 3 of the stewardship code.
Escalation (2) – Netherlands	Consult management before convening an extraordinary general meeting or tabling a shareholder resolution.	6 of Dutch corporate governance code) 1.6 of Dutch corporate governance code) Read MoreThis theme appears in principle 8 of the stewardship code.
Escalation (3) – Netherlands	If proposing a resolution at a general meeting, be present/represented at the meeting to explain the resolution	5 of Dutch corporate governance code.) 1.5 of Dutch corporate governance code.) Read MoreThis theme appears in principle 9 of the stewardship code.
Collective engagement – Netherlands	Collectively engage where appropriate	Collectively discuss issues of common interest to jointly pursue. Respect regulations/guidelines to avoid use of insider information and acting in concert. Collective engagement may be more cost effective and generate wider/deeper range of analysis. Consider that some issues best discussed one-on-one. Read MoreThis theme appears in principle 4 of the stewardship code.
ESG integration – Netherlands	Monitor Dutch listed investees on material issues (e.g., business model, strategy, long-term performance/risks/opportunities, capital structure, ESG, and corporate actions)	No guidanceThis theme appears in principle 2 of the stewardship code.
Materiality – Netherlands	Monitor Dutch listed investees on material issues (e.g., business model, strategy, long-term performance/risks/opportunities, capital structure, ESG, and corporate actions)	No guidanceThis theme appears in principle 2 of the stewardship code.
Promote long-term value creation – Netherlands	Create and publicly disclose stewardship policy on website	Aim to enhance and preserve value of clients/beneficiaries and promote long-term value at investee companies. If delegate stewardship, ensure AM undertaking stewardship via mandate. Publicly disclose certain key elements of this mandate (As stipulated by Article 3h of the Shareholder Engagement Directive). If invest in mutual or investment funds (not directly in Dutch listed companies), ensure that fund managers have engagement policies in line with Dutch or similar code Read MoreThis theme appears in principle 1 of the stewardship code.
Understand investee stakeholder perspectives – Netherlands	Communicate with relevant Dutch investee stakeholders, e.g., works council and NGOs	Aim to understand stakeholder (e.g., employees, customers, suppliers) aims/motivations before engaging or voting on material issuesThis theme appears in principle 5 of the stewardship code.
Voting policy and disclosure – Singapore	Establish clear voting policies and vote responsibly	Actively seek to participate in investee GMs and vote responsibly and on an informed basis Have a clear view on how to vote proxies and specific policies on voting issues. Vote proxies in the best interests of clients and investees. Maintain voting records and document deviations from voting practices. Have clear policies on communicating voting policies, votes exercised, and records of votes cast. Maintain voting records. Read MoreThis theme appears in principle 5 of the stewardship code.
Disclose stewardship policies – Singapore	Establish and articulate stewardship policies	Clearly state policies on responsibilities on corporate website The policies should explain the methods to ensure that investor complies with its chosen approach to stewardship. The policies should explain rationale for chosen approach to stewardship, how it enhances/protects value for clients, and how it applies to parts of the investment process. Take steps to ensure adherence to chosen stewardship approach. Read MoreThis theme appears in principle 1 of the stewardship code.
Fiduciary duty – Singapore	Establish and articulate stewardship policies	Clearly state policies on responsibilities on corporate website The policies should explain the methods to ensure that investor complies with its chosen approach to stewardship. The policies should explain rationale for chosen approach to stewardship, how it enhances/protects value for clients, and how it applies to parts of the investment process. Take steps to ensure adherence to chosen stewardship approach. Read MoreThis theme appears in principle 1 of the stewardship code.
Monitor investees (1) – Singapore	Actively monitor investee companies.	Establish monitoring process to identify/address financial/nonfinancial issues early. Raise concerns directly with investees and seek to address them. If investees deviate from CG practices, including Singapore's Code of CG, engage, assess the reasons, and take action. When engaging, begin with a confidential discussion and consider escalating in the investee does not respond constructively. Have a policy on escalation of engagement. Read MoreThis theme appears in principle 3 of the stewardship code.
Monitor investees (2) – Singapore	Communicate regularly and effectively with investees	Communicate effectively with investees and ensure mutual understanding/ achievement long-term value creation, capital efficiency, and sustainable growth. Ensure that investee's board and board committee structures are effective, and that independent directors provide adequate oversight. Engage with investee companies on strategy, long-term performance, risk, financials, culture and remuneration, and ESG considerations. Have a policy for managing disclosures of insider information, willingness to be made insiders, and the mechanism of this. Read MoreThis theme appears in principle 2 of the stewardship code.
Conflicts of interest policy – Singapore	Be transparent when managing conflicts of interest.	Have clear written policies on corporate website about identifying/managing conflicts of interest. Policies should emphasize fiduciary duty and acting in clients' interests When conflicts of interest arise, take reasonable steps to prioritize clients' interests. Ask service providers to disclose conflicts of interest and explain how they are managed. Read MoreThis theme appears in principle 4 of the stewardship code.
Report on stewardship to beneficiaries – Singapore	Document and provide relevant updates on stewardship activities.	AOs and AMs should frequently/annually proactively inform clients/investees about their approach to stewardship the extent to which they adhere to their own stewardship policies. Maintain a record of how they carried out stewardship responsibilities. Consider sharing record on website Read MoreThis theme appears in principle 6 of the stewardship code.
Regular/effective investee communication – Singapore	Communicate regularly and effectively with investees	Communicate effectively with investees and ensure mutual understanding/ achievement long-term value creation, capital efficiency, and sustainable growth. Ensure that investee's board and board committee structures are effective, and that independent directors provide adequate oversight. Engage with investee companies on strategy, long-term performance, risk, financials, culture and remuneration, and ESG considerations. Have a policy for managing disclosures of insider information, willingness to be made insiders, and the mechanism of this. Read MoreThis theme appears in principle 2 of the stewardship code.
Escalation – Singapore	Actively monitor investee companies.	Establish monitoring process to identify/address financial/nonfinancial issues early. Raise concerns directly with investees and seek to address them. If investees deviate from CG practices, including Singapore's Code of CG, engage, assess the reasons, and take action. When engaging, begin with a confidential discussion and consider escalating in the investee does not respond constructively. Have a policy on escalation of engagement. Read MoreThis theme appears in principle 3 of the stewardship code.
Collective engagement – Singapore	Be willing to engage responsibly with one another where appropriate.	Collaborating with other investors, subject to disclosure regulations, may be the best way to engage investees. Collective engagement via formal/informal groups may be the most appropriate way to communicate significant risks to investees. Disclose rationale for collective engagement, including the circumstances that prompted it. Read MoreThis theme appears in principle 7 of the stewardship code.
Voting policy and disclosure – South Africa	Accept ownership responsibilities	Develop an ownership policy that includes: a. Guidelines (e.g. King III) to identify sustainability concerns, including ESG, at a company (King III, the third report on Corporate Governance in South Africa, was compiled by the King Committee in response to the emergence of the South African Companies Act 71 of 2008) b. Mechanisms of intervention and engagement with the company and means of escalation if concerns are not resolved c. Voting at shareholder meetings, including decision-making criteria and public disclosure of full voting records Active ownership should apply to passive managers. Implement ownership policy and establish monitoring/compliance process. Ensure that the mandates with third-party service providers address sustainability. Monitor third-parties when outsourcing (ensuring CRISA applies. CRISA=Code for Responsible Investing in South Africa). Introduce and apply controls to prevent receiving insider information (according to Securities Services Act No 36 of 2004) when engaging with companies (in accordance to CRISA guidelines). Read MoreThis theme appears in principle 2 of the stewardship code.
Disclose stewardship policies – South Africa	Be transparent about policies, their implementation, and how CRISA is applied	Regularly engage with stakeholders (e.g., investees and beneficiaries) to identify and understand information requirements and publicly disclose annually on what extent it applies to CRISA. If an II does not apply CRISA or applies it differently, publicly disclose why and alternate measures. Disclose the following policies publicly: (a) incorporation of sustainability (including ESG) into investment analysis and activities; (b) ownership, including voting; (c) conflicts of interest identification/prevention/management Before agreeing to keep voting records confidential, carefully consider that doing so limits engagement Clearly explain how policies were practically monitored and implemented Disclose processes to ensure that service providers apply CRISA and other II requirements Read MoreThis theme appears in principle 5 of the stewardship code.
Fiduciary duty – South Africa	Incorporate sustainability considerations, including ESG, into its investment analysis and activities as part of its fiduciary duty to beneficiaries	Develop a policy to incorporate sustainability (e.g., ESG) into investment analysis as part of the delivery of superior returns to beneficiaries that includes: a. tangible and intangible assets b. The quality of the company's integrated reporting (on long-term sustainability of strategy and operations). If there is no integrated report, ask why c. How the company conducts business based on, for example, targeted II investment strategies, the code of conduct, and the company supply chain Implement policy and establish monitoring/compliance process Read MoreThis theme appears in principle 1 of the stewardship code.
Monitor investees – South Africa	Incorporate sustainability considerations, including ESG, into its investment analysis and activities as part of its fiduciary duty to beneficiaries	Develop a policy to incorporate sustainability (e.g., ESG) into investment analysis as part of the delivery of superior returns to beneficiaries that includes: a. tangible and intangible assets b. The quality of the company's integrated reporting (on long-term sustainability of strategy and operations). If there is no integrated report, ask why c. How the company conducts business based on, for example, targeted II investment strategies, the code of conduct, and the company supply chain Implement policy and establish monitoring/compliance process Read MoreThis theme appears in principle 1 of the stewardship code.
Conflicts of interest policy – South Africa	Recognize manage conflicts of interest	Identify the circumstances that could create conflicts of interest. Develop a policy to prevent and manage them. Implement conflict of interest policy and establish monitoring/compliance processes Read MoreThis theme appears in principle 4 of the stewardship code.
Report on stewardship to beneficiaries – South Africa	Be transparent about policies, their implementation, and how CRISA is applied	Regularly engage with stakeholders (e.g., investees and beneficiaries) to identify and understand information requirements and publicly disclose annually on what extent it applies to CRISA. If an II does not apply CRISA or applies it differently, publicly disclose why and alternate measures. Disclose the following policies publicly: (a) incorporation of sustainability (including ESG) into investment analysis and activities; (b) ownership, including voting; (c) conflicts of interest identification/prevention/management Before agreeing to keep voting records confidential, carefully consider that doing so limits engagement Clearly explain how policies were practically monitored and implemented Disclose processes to ensure that service providers apply CRISA and other II requirements Read MoreThis theme appears in principle 5 of the stewardship code.
Regular/effective investee communication – South Africa	Accept ownership responsibilities	Develop an ownership policy that includes: a. Guidelines (e.g. King III [1]) to identify sustainability concerns, including ESG, at a company b. Mechanisms of intervention and engagement with the company and means of escalation if concerns are not resolved c. Voting at shareholder meetings, including decision-making criteria and public disclosure of full voting records Active ownership should apply to passive managers. Implement ownership policy and establish monitoring/compliance process. Ensure that the mandates with third-party service providers address sustainability. Monitor third-parties when outsourcing (ensuring CRISA applies). Introduce and apply controls to prevent receiving insider information (according to Securities Services Act No 36 of 2004) when engaging with companies (in accordance to CRISA guidelines). Read MoreThis theme appears in principle 2 of the stewardship code.
Escalation – South Africa	Accept ownership responsibilities	Develop an ownership policy that includes: a. Guidelines (e.g. King III [1]) to identify sustainability concerns, including ESG, at a company b. Mechanisms of intervention and engagement with the company and means of escalation if concerns are not resolved c. Voting at shareholder meetings, including decision-making criteria and public disclosure of full voting records Active ownership should apply to passive managers. Implement ownership policy and establish monitoring/compliance process. Ensure that the mandates with third-party service providers address sustainability. Monitor third-parties when outsourcing (ensuring CRISA applies). Introduce and apply controls to prevent receiving insider information (according to Securities Services Act No 36 of 2004) when engaging with companies (in accordance to CRISA guidelines). Read MoreThis theme appears in principle 2 of the stewardship code.
Collective engagement – South Africa	Collaborate to promote CRISA and other standards acceptance/implementation	Work with other shareholders, service providers, regulators, investee companies and beneficiaries to promote CRISA and sound governance acceptance/implementation Be aware of legislative consequences of acting in concert Read MoreThis theme appears in principle 3 of the stewardship code.
ESG integration – South Africa	Incorporate sustainability considerations, including ESG, into its investment analysis and activities as part of its fiduciary duty to beneficiaries	Develop a policy to incorporate sustainability (e.g., ESG) into investment analysis as part of the delivery of superior returns to beneficiaries that includes: a. tangible and intangible assets b. The quality of the company's integrated reporting (on long-term sustainability of strategy and operations). If there is no integrated report, ask why c. How the company conducts business based on, for example, targeted II investment strategies, the code of conduct, and the company supply chain Implement policy and establish monitoring/compliance process Read MoreThis theme appears in principle 1 of the stewardship code.
Work with policymakers and regulators – South Africa	Collaborate to promote CRISA and other standards acceptance/implementation	Work with other shareholders, service providers, regulators, investee companies and beneficiaries to promote CRISA and sound governance acceptance/implementation Be aware of legislative consequences of acting in concert Read MoreThis theme appears in principle 3 of the stewardship code.
Voting policy and disclosure – South Korea	Voting (publicly disclose policy, records, rationales for votes, and activities)	Make an effort to vote on all shares held, and not automatically in favor of management-proposed resolutions. Vote based on sufficient data collection/analysis, in-depth review, and investee dialogue/engagement. Discuss voting decision with beneficiaries when necessary. Build internal resources, organizational structures, and professional capacity for voting. Formulate and publicly disclose voting policy that includes guidelines/procedures/standards (not just mechanical checklist) re: voting activities/records. The voting policy should include policies on preventing conflicts of interest re: voting. Voting policy should provide a different set of detailed standards/guidelines for each type of collective investment vehicle with varying targets and philosophies. Publicly disclose voting results and reasons for votes (so clients and beneficiaries can check). Publicly disclose any use of proxy advisors and service scope, application method, and the extent of their reliance on advisor's recommendations. IIs are responsible for stewardship in voting. Voting policy should include stock lending and recall of lent stock for voting. Read MoreThis theme appears in principle 5 of the stewardship code.
Disclose stewardship policies – South Korea	Formulate and publicly disclose clear stewardship policy	Act in the long-term interest of clients and beneficiaries by using deep understanding of investees and the economic/social/business environment for active communication and shareholder activities. Stewardship should include monitoring, constructive dialogue, and productive proposals. Formulate and publicly disclose stewardship policy that includes principles and guidelines, investment management philosophy, rights and duties, and stewardship organization and procedures Consider position in investment value chain. AOs can directly engage, select competent AMs, and provide AMs with instructions and evaluations. AMs should comply with AO standards and requirements. AOs and AMs should communicate closely. When delegating to external service providers, reflect in the policy (a) how they are selected, monitored, evaluated, and administered and (b) the scope of shareholder activities delegated When managing collective investment vehicles in various asset classes and types that differ in time horizon, investment management philosophy, the 'policy' can reflect differences in the principles, guidelines, procedures, etc. Read MoreThis theme appears in principle 1 of the stewardship code.
Fiduciary duty – South Korea	Formulate and publicly disclose clear stewardship policy	Act in the long-term interest of clients and beneficiaries by using deep understanding of investees and the economic/social/business environment for active communication and shareholder activities. Stewardship should include monitoring, constructive dialogue, and productive proposals. Formulate and publicly disclose stewardship policy that includes principles and guidelines, investment management philosophy, rights and duties, and stewardship organization and procedures Consider position in investment value chain. AOs can directly engage, select competent AMs, and provide AMs with instructions and evaluations. AMs should comply with AO standards and requirements. AOs and AMs should communicate closely. When delegating to external service providers, reflect in the policy (a) how they are selected, monitored, evaluated, and administered and (b) the scope of shareholder activities delegated When managing collective investment vehicles in various asset classes and types that differ in time horizon, investment management philosophy, the 'policy' can reflect differences in the principles, guidelines, procedures, etc. Read MoreThis theme appears in principle 1 of the stewardship code.
Monitor investees – South Korea	Monitor investees companies to enhance and protect their value	Regularly monitor all factors that could all affect value and sustainable growth of investees: capital structures; business performance; corporate governance; business strategy Consider investment policy and internal capacity to determine appropriate scope for monitoring and regularly review effectiveness of monitoring Try to detect material risk factors early and, if confirmed, seek solutions through constructive dialogue Read MoreThis theme appears in principle 3 of the stewardship code.
Conflicts of interest policy – South Korea	Formulate and publicly disclose clear & effective conflicts of interest policy	Review actual conflicts of interest and formulate and publicly disclose a policy that includes principles and guidelines, concrete methods, rights and duties, and procedures to monitor and manage conflicts of interest Managing conflicts of interest can include working with a third-party organization or adopting methods in Korea's Financial Investment Services and Capital Markets Act (2007, amended in 2013) and related regulations. Read MoreThis theme appears in principle 2 of the stewardship code.
Report on stewardship to beneficiaries – South Korea	Report periodically to clients/beneficiaries on voting and stewardship activities.	Keep record of stewardship activities, including voting rights. Regularly report stewardship policy and the implementation policy to clients and beneficiaries at least annually. Where appropriate and agreed by their clients and beneficiaries, disclose shareholder activities on website/annual report. Establish stewardship disclosure scope and standards to facilitate client and beneficiary monitoring. Read MoreThis theme appears in principle 6 of the stewardship code.
Regular/effective investee communication – South Korea	Aim to form a consensus with investees, and where necessary, formulate internal guidelines on stewardship timeline, procedures, and methods	Aim for consensus with investees on financial and non-financial matters If that fails, consider escalation and establish scope, procedure, and standards based on investee circumstances, investment policy, and internal capacity. Avoid use of insider information Read MoreThis theme appears in principle 4 of the stewardship code.
Escalation – South Korea	Aim to form a consensus with investees, and where necessary, formulate internal guidelines on stewardship timeline, procedures, and methods	Aim for consensus with investees on financial and non-financial matters If that fails, consider escalation and establish scope, procedure, and standards based on investee circumstances, investment policy, and internal capacity. Avoid use of insider information Read MoreThis theme appears in principle 4 of the stewardship code.
Materiality – South Korea	Monitor investees companies to enhance and protect their value	Regularly monitor all factors that could all affect value and sustainable growth of investees: capital structures; business performance; corporate governance; business strategy Consider investment policy and internal capacity to determine appropriate scope for monitoring and regularly review effectiveness of monitoring Try to detect material risk factors early and, if confirmed, seek solutions through constructive dialogue Read MoreThis theme appears in principle 3 of the stewardship code.
Build capacity to engage effectively – South Korea	Have the capabilities and expertise required to implement stewardship actively and effectively	Build up capacity and expertise to understand investees and engage in active dialogue and shareholder activities. Design an appropriate organizational structure, inject internal resources, and continually try to develop/improve capacity/expertise. For AO delegating stewardship to AM: oversee AM and pay AM enough to build capacity for dialogue and shareholder activities. Use external services for professional advice on stewardship. Establish forums for discussions, pursuit of mutual interests, and sharing engagement best practices. Read MoreThis theme appears in principle 7 of the stewardship code.
Voting policy and disclosure (1) – Switzerland	Exercise participation rights insofar as appropriate/feasible/in client interests	Exercise participation rights (e.g., entry in share register and exercising voting rights) if the expenditure is justifiable/reasonable to safeguard client interests. Specify the circumstances under which loaned securities are to be recalled for voting. Read MoreThis theme appears in principle 1 of the stewardship code.
Voting policy and disclosure (2) – Switzerland	Assume responsibility for exercising the participation rights	Responsibility for participation rights cannot be delegated to third parties (although assigning exercising voting rights in compliance with the specified criteria can). Select voting rights representatives and proxy advisors with sufficient care, appropriately instruct them, adequately supervise them, and critically assess their recommendations (including for conflicts of interest). Pass on recommendations to companies concerned if there are controversial issues. If possible, avoid/suspend securities lending prior to a general meeting of shareholders if there are any controversial agenda items that are relevant to client interests Read MoreThis theme appears in principle 3 of the stewardship code.
Disclose stewardship policies – Switzerland	Communicate the principles and processes involved in exercising participation rights to clients	Disclose the principles and processes involved in exercising participation rights. Define (a) the principles governing participation and (b) the process for participation rights decisions (in the form of a written policy, which includes coordinating with other investors and proxy/advisor services) Read MoreThis theme appears in principle 4 of the stewardship code.
Fiduciary duty – Switzerland	Consider client interests when exercising participation rights	Participation rights shall be exercised in the interests of clients and with a long-term/sustainable approach (unless the relevant investment guidelines stipulate otherwise). Consider the specific circumstances of each case vs. 'one size fits all' Define how participation rights are exercised. Form opinions via dialogue with companies, and if any controversial issues arise, resolve them by contacting the companies concerned. Exercise participation rights independently of any political criteria or third-party instructions Avoid, try to resolve, and disclose any conflicts of interest Read MoreThis theme appears in principle 2 of the stewardship code.
Report on stewardship to beneficiaries – Switzerland	Disclose how participation rights have been exercised at least annually	Issue a report (i.e., an accountability statement) summarizing the participation rights exercised at least annually) (excluding the disclosure details regarding voting in individual cases). In the accountability statement, disclose use of AMs or proxy advisors, including the structure of these relationships Read MoreThis theme appears in principle 5 of the stewardship code.
Voting policy and disclosure – Taiwan	Establish clear voting policies and disclose voting results	Exercise voting rights based on long-term interests of beneficiaries and investees. Develop and disclose voting policy (more than mechanical checklist) that may include threshold for exercising voting rights based on costs & benefits. Evaluate each motion of a shareholders' meeting before casting votes and communicate in advance with management of company as needed. Define types of motions to support, oppose, or abstain from. Include a statement that an II does not always support management motions. Disclose when adopt proxy advisor voting recommendations. Analyze and disclose votes, potentially in aggregate (e.g., votes cast in favor, against or abstaining from various types of motions made by investees). Read MoreThis theme appears in principle 5 of the stewardship code.
Disclose stewardship policies – Taiwan	Establish and disclose stewardship policies	Have in-depth knowledge of investees and their business environments and how to protect rights of its clients and beneficiaries Develop and publicly disclose stewardship policy Engage in and disclose stewardship activities, emphasizing: frequency, monitoring methods, engagement, shareholder meeting participation, voting. Monitor and measure stewardship activities outsourced to AMs. Manner and frequency of status disclosure of stewardship fulfilment. Read MoreThis theme appears in principle 1 of the stewardship code.
Fiduciary duty – Taiwan	Establish and disclose stewardship policies	Have in-depth knowledge of investees and their business environments and how to protect rights of its clients and beneficiaries Develop and publicly disclose stewardship policy Engage in and disclose stewardship activities, emphasizing: frequency, monitoring methods, engagement, shareholder meeting participation, voting. Monitor and measure stewardship activities outsourced to AMs. Manner and frequency of status disclosure of stewardship fulfilment. Read MoreThis theme appears in principle 1 of the stewardship code.
Monitor investees – Taiwan	Regularly monitor investees	Monitor investees with an emphasis on relevance to long-term values of investee companies. Review monitoring effectiveness and use it as a reference to inform future investment decisions. Determine content, extent, and frequency of monitoring investees with special consideration to purpose of investment, costs, and benefits. Monitor financial and nonfinancial factors: industry profile, risks and opportunities, shareholding structure, operational strategies, business profile, financial position, results of operations, cash flow, stock price, environmental impacts, social issues, and corporate governance. Read MoreThis theme appears in principle 3 of the stewardship code.
Conflicts of interest policy – Taiwan	Establish and disclose conflicts of interest policies	Manage conflicts of interest in the best interest of clients/beneficiaries. Publicly disclose possible conflicts of interest situations and how to manage them. Strengthen governance structures to manage conflicts of interest: training, delegation of duties, information security, firewalls, control mechanisms for detection and monitoring, reasonable remuneration policies, and remedial measures. Have a mechanism to explain to clients causes and handling measures for major incidents of conflicts of interest. Read MoreThis theme appears in principle 2 of the stewardship code.
Report on stewardship to beneficiaries – Taiwan	Periodically disclose status of fulfilment of stewardship responsibilities to clients/beneficiaries	Record stewardship activities to form basis for assessment and improve stewardship policies, actions, and disclosures. Report periodically to beneficiaries on fulfilment of stewardship duties. If there are a large number of clients/beneficiaries, consider disclosing stewardship activities annually on website/reports. Disclosures are advised to include: (a) statement on 'Stewardship Principles for Institutional Investors' and explanations for non-compliance; (b) attendance at shareholders' meetings; (c) voting activities; (d) contact channel for stakeholders to reach a signatory; and (e) other material events (e.g., dialogue and interaction with an investee company or relevant opinions and actions on special events). If delegate stewardship to AMs, measure AM compliance with a stewardship policy and disclose to beneficiaries. Read MoreThis theme appears in principle 6 of the stewardship code.
Regular/effective investee communication – Taiwan	Maintain an appropriate dialogue and interaction with investees	Strengthen corporate governance by understanding management views on material issues and obtaining mutual feedback through engagement. Consider purpose, costs, and benefits of the investment when determining the manner and frequency of engagement with investee. Manner of engagement may include: written or verbal communications, public statements on specific issues, expressing opinions, submitting of motions, and casting votes at shareholders' meetings. Engage with investee companies collectively as necessary. Read MoreThis theme appears in principle 4 of the stewardship code.
Escalation – Taiwan	Maintain an appropriate dialogue and interaction with investees	Strengthen corporate governance by understanding management views on material issues and obtaining mutual feedback through engagement. Consider purpose, costs, and benefits of the investment when determining the manner and frequency of engagement with investee. Manner of engagement may include: written or verbal communications, public statements on specific issues, expressing opinions, submitting of motions, and casting votes at shareholders' meetings. Engage with investee companies collectively as necessary. Read MoreThis theme appears in principle 4 of the stewardship code.
Collective engagement – Taiwan	Maintain an appropriate dialogue and interaction with investees	Strengthen corporate governance by understanding management views on material issues and obtaining mutual feedback through engagement. Consider purpose, costs, and benefits of the investment when determining the manner and frequency of engagement with investee. Manner of engagement may include: written or verbal communications, public statements on specific issues, expressing opinions, submitting of motions, and casting votes at shareholders' meetings. Engage with investee companies collectively as necessary. Read MoreThis theme appears in principle 4 of the stewardship code.
Materiality – Taiwan	Maintain an appropriate dialogue and interaction with investees	Strengthen corporate governance by understanding management views on material issues and obtaining mutual feedback through engagement. Consider purpose, costs, and benefits of the investment when determining the manner and frequency of engagement with investee. Manner of engagement may include: written or verbal communications, public statements on specific issues, expressing opinions, submitting of motions, and casting votes at shareholders' meetings. Engage with investee companies collectively as necessary. Read MoreThis theme appears in principle 4 of the stewardship code.
Investor internal incentives (compensation) – Taiwan	Establish and disclose conflicts of interest policies	Manage conflicts of interest in the best interest of clients/beneficiaries. Publicly disclose possible conflicts of interest situations and how to manage them. Strengthen governance structures to manage conflicts of interest: training, delegation of duties, information security, firewalls, control mechanisms for detection and monitoring, reasonable remuneration policies, and remedial measures. Have a mechanism to explain to clients causes and handling measures for major incidents of conflicts of interest. Read MoreThis theme appears in principle 2 of the stewardship code.
Voting policy and disclosure – Thailand	Have a clear policy on exercising voting rights and disclosure of voting results	Exercise voting rights in each investee company after careful consideration, do not vote based on a mechanical checklist to always support resolutions proposed by investees. Exercise voting rights on matters related to issues unresolved through engagement, and provide in writing reasons for its vote against or abstention to any resolutions proposed by investees. Adopt a voting policy for types of motions which IIs may support, oppose, or abstain from voting, and disclose the number of shares IIs will abstain from voting. Include a statement to clients explaining why the II did not exercise their voting rights in accordance with normal voting policy when needed. Disclose voting activities and important information about the vote, including: conflicts of interest between IIs and investees, differences of opinion between IIs and investees, and transactions involving II's parent company. Disclose the names of proxy advisors or other advisory service providers and statistics of votes exercised using proxy advisors. Disclose approach to stock lending and recalling lent stocks to be used for voting. Read MoreThis theme appears in principle 5 of the stewardship code.
Disclose stewardship policies – Thailand	Adopt a clear written investment governance policy	Adopt a clear and written policy that strengthens governance culture and is approved by the Board of Directors that includes enhanced monitoring of/engagement with investees on material issues Clearly outline the II's role in the investment value chain, with an emphasis on performing its stewardship responsibilities to its clients. Define role and responsibilities of Board of Directors and management. Have a publicly disclosed stewardship policy that covers: conflict of interest management, ongoing monitoring of companies, engagement with companies on key issues, collaboration with other investors, voting policy and results of exercising voting rights, level of compliance with policy, and how IIs apply principles. Require policies on: ESG performance, anti-corruption, management/use of non-public information about investees, prevention of unfair securities trading practices, money laundering, and terrorist financing. Monitor stewardship activities outsourced to AMs to ensure compliance with policies. Read MoreThis theme appears in principle 1 of the stewardship code.
Fiduciary duty – Thailand	Adopt a clear written investment governance policy	Adopt a clear and written policy that strengthens governance culture and is approved by the Board of Directors that includes enhanced monitoring of/engagement with investees on material issues Clearly outline the II's role in the investment value chain, with an emphasis on performing its stewardship responsibilities to its clients. Define role and responsibilities of Board of Directors and management. Have a publicly disclosed stewardship policy that covers: conflict of interest management, ongoing monitoring of companies, engagement with companies on key issues, collaboration with other investors, voting policy and results of exercising voting rights, level of compliance with policy, and how IIs apply principles. Require policies on: ESG performance, anti-corruption, management/use of non-public information about investees, prevention of unfair securities trading practices, money laundering, and terrorist financing. Monitor stewardship activities outsourced to AMs to ensure compliance with policies. Read MoreThis theme appears in principle 1 of the stewardship code.
Monitor investees – Thailand	Make informed investment decisions and engage in active ongoing monitoring of investees	Have procedures in place for monitoring performance of investees and factors relevant to their value. Understand the leadership and corporate governance of investees and their effectiveness. Ensure investees' Boards perform their duties, leading to sustainable growth and durable returns on investment. Take into consideration governance, social responsibility, and environmental effects when making investment decisions. Monitor actively, including: reading related news and research analysis, effective engagement with board of directors and executives, and attending and exercising voting rights at AGMs. Have procedures in place for incidents where investees' failure to comply with principles can impact firm value. IIs should consider companies' explanations or corrective measures as sufficient or insufficient, and enhance monitoring accordingly. Read MoreThis theme appears in principle 3 of the stewardship code.
Conflicts of interest policy (1) – Thailand	Prevent and manage conflicts of interest and prioritize advancing clients' best interests	The board should prevent/minimize/manage conflicts of interest with an organizational culture that emphasizes client interests, capable/knowledgeable staff, and compensation/motivation schemes and evaluation processes that support client long-term interests. Put in place written policies and procedures for managing conflicts of interest. Communicate with and train staff to ensure application of procedures. Develop audit measures for the application of procedures, including an effective whistle-blowing policy. Review the effectiveness of measures and procedures. Communicate conflicts of interest policies to related service providers such as AMs. Read MoreThis theme appears in principle 2 of the stewardship code.
Conflicts of interest policy (2) – Thailand	Prevent and manage conflicts of interest and prioritize advancing clients' best interests	The board should prevent/minimize/manage conflicts of interest with an organizational culture that emphasizes client interests, capable/knowledgeable staff, and compensation/motivation schemes and evaluation processes that support client long-term interests. Put in place written policies and procedures for managing conflicts of interest. Communicate with and train staff to ensure application of procedures. Develop audit measures for the application of procedures, including an effective whistle-blowing policy. Review the effectiveness of measures and procedures. Communicate conflicts of interest policies to related service providers such as AMs. Read MoreThis theme appears in principle 2 of the stewardship code.
Report on stewardship to beneficiaries – Thailand	Regularly disclose the investment governance policy and compliance with the policy	Maintain record-keeping systems and keep records on stewardship activities. Ensure information disclosed to clients and public is accurate. Publicly disclose stewardship code and level of compliance with principles through various channels, including: II's website or annual report. Read MoreThis theme appears in principle 7 of the stewardship code.
Regular/effective investee communication – Thailand	Apply enhanced monitoring of and engagement with investees monitoring is considered insufficient	Adopt an engagement policy for events where regular monitoring measures are deemed insufficient. Engage with investees about investment concerns such as: corporate strategy, performance, risk management, implementation of principles, and approach to ESG principles. Engage confidentially if the issues of concern identified have not been publicly disclosed. Escalate actions if confidential engagement is unsuccessful. Escalating includes: formally notifying the Board and Chairman, disclosing information to the public prior to an AGM, notifying companies' of the IIs voting decision prior to an AGM, requesting that matters of concern be added to AGM agenda. Obtain non-public information when escalating the level of engagement, and implement measures to protect confidentiality of such information to prevent violation of applicable laws. Read MoreThis theme appears in principle 4 of the stewardship code.
Escalation – Thailand	Apply enhanced monitoring of and engagement with investees monitoring is considered insufficient	Adopt an engagement policy for events where regular monitoring measures are deemed insufficient. Engage with investees about investment concerns such as: corporate strategy, performance, risk management, implementation of principles, and approach to ESG principles. Engage confidentially if the issues of concern identified have not been publicly disclosed. Escalate actions if confidential engagement is unsuccessful. Escalating includes: formally notifying the Board and Chairman, disclosing information to the public prior to an AGM, notifying companies' of the IIs voting decision prior to an AGM, requesting that matters of concern be added to AGM agenda. Obtain non-public information when escalating the level of engagement, and implement measures to protect confidentiality of such information to prevent violation of applicable laws. Read MoreThis theme appears in principle 4 of the stewardship code.
Collective engagement – Thailand	Act collectively with other investors and stakeholders as appropriate	Adopt policies and procedures with respect to collective engagement with other investors and stakeholders. The policy should indicate the circumstances in which IIs should seek and participate in collective engagement. Be cautious about voting in collaboration with other investors to ensure compliance with applicable laws and regulations. Read MoreThis theme appears in principle 6 of the stewardship code.
ESG integration – Thailand	Make informed investment decisions and engage in active ongoing monitoring of investees	Have procedures in place for monitoring performance of investees and factors relevant to their value. Understand the leadership and corporate governance of investees and their effectiveness. Ensure investees' Boards perform their duties, leading to sustainable growth and durable returns on investment. Take into consideration governance, social responsibility, and environmental effects when making investment decisions. Monitor actively, including: reading related news and research analysis, effective engagement with board of directors and executives, and attending and exercising voting rights at AGMs. Have procedures in place for incidents where investees' failure to comply with principles can impact firm value. IIs should consider companies' explanations or corrective measures as sufficient or insufficient, and enhance monitoring accordingly. Read MoreThis theme appears in principle 3 of the stewardship code.
Materiality – Thailand	Adopt a clear written investment governance policy	Adopt a clear and written policy that strengthens governance culture and is approved by the Board of Directors that includes enhanced monitoring of/engagement with investees on material issues Clearly outline the II's role in the investment value chain, with an emphasis on performing its stewardship responsibilities to its clients. Define role and responsibilities of Board of Directors and management. Have a publicly disclosed stewardship policy that covers: conflict of interest management, ongoing monitoring of companies, engagement with companies on key issues, collaboration with other investors, voting policy and results of exercising voting rights, level of compliance with policy, and how IIs apply principles. Require policies on: ESG performance, anti-corruption, management/use of non-public information about investees, prevention of unfair securities trading practices, money laundering, and terrorist financing. Monitor stewardship activities outsourced to AMs to ensure compliance with policies. Read MoreThis theme appears in principle 1 of the stewardship code.
Promote long-term value creation – Thailand	Make informed investment decisions and engage in active ongoing monitoring of investees	Have procedures in place for monitoring performance of investees and factors relevant to their value. Understand the leadership and corporate governance of investees and their effectiveness. Ensure investees' Boards perform their duties, leading to sustainable growth and durable returns on investment. Take into consideration governance, social responsibility, and environmental effects when making investment decisions. Monitor actively, including: reading related news and research analysis, effective engagement with board of directors and executives, and attending and exercising voting rights at AGMs. Have procedures in place for incidents where investees' failure to comply with principles can impact firm value. IIs should consider companies' explanations or corrective measures as sufficient or insufficient, and enhance monitoring accordingly. Read MoreThis theme appears in principle 3 of the stewardship code.
Build capacity to engage effectively – Thailand	Prevent and manage conflicts of interest and prioritize advancing clients' best interests	The board should prevent/minimize/manage conflicts of interest with an organizational culture that emphasizes client interests, capable/knowledgeable staff, and compensation/motivation schemes and evaluation processes that support client long-term interests. Put in place written policies and procedures for managing conflicts of interest. Communicate with and train staff to ensure application of procedures. Develop audit measures for the application of procedures, including an effective whistle-blowing policy. Review the effectiveness of measures and procedures. Communicate conflicts of interest policies to related service providers such as AMs. Read MoreThis theme appears in principle 2 of the stewardship code.
Board/governance and business management (1) – Thailand	Regularly disclose the investment governance policy and compliance with the policy	Maintain record-keeping systems and keep records on stewardship activities. Ensure information disclosed to clients and public is accurate. Publicly disclose stewardship code and level of compliance with principles through various channels, including: II's website or annual report. Read MoreThis theme appears in principle 7 of the stewardship code.
Board/governance and business management (2) – Thailand	Prevent and manage conflicts of interest and prioritize advancing clients' best interests	The board should prevent/minimize/manage conflicts of interest with an organizational culture that emphasizes client interests, capable/knowledgeable staff, and compensation/motivation schemes and evaluation processes that support client long-term interests. Put in place written policies and procedures for managing conflicts of interest. Communicate with and train staff to ensure application of procedures. Develop audit measures for the application of procedures, including an effective whistle-blowing policy. Review the effectiveness of measures and procedures. Communicate conflicts of interest policies to related service providers such as AMs. Read MoreThis theme appears in principle 2 of the stewardship code.
Understand investee stakeholder perspectives – Thailand	Act collectively with other investors and stakeholders as appropriate	Adopt policies and procedures with respect to collective engagement with other investors and stakeholders. The policy should indicate the circumstances in which IIs should seek and participate in collective engagement. Be cautious about voting in collaboration with other investors to ensure compliance with applicable laws and regulations. Read MoreThis theme appears in principle 6 of the stewardship code.
Investor internal incentives (compensation) – Thailand	Prevent and manage conflicts of interest and prioritize advancing clients' best interests	The board should prevent/minimize/manage conflicts of interest with an organizational culture that emphasizes client interests, capable/knowledgeable staff, and compensation/motivation schemes and evaluation processes that support client long-term interests. Put in place written policies and procedures for managing conflicts of interest. Communicate with and train staff to ensure application of procedures. Develop audit measures for the application of procedures, including an effective whistle-blowing policy. Review the effectiveness of measures and procedures. Communicate conflicts of interest policies to related service providers such as AMs. Read MoreThis theme appears in principle 2 of the stewardship code.
Voting policy and disclosure – United Kingdom	Actively exercise voting and other ownership rights and responsibilities	Listed equity: disclose proportion of shares voted in the past year; provide a link to voting records; and explain rationale for voting decisions, the extent to which voting was delegated and monitored. Fixed income: explain approach to seeking seeking (a) amendments to terms and conditions in indentures or contracts and access to information provided in trust deeds, (b) impairment rights; and (c) reviewing prospectus and transaction documents. Read MoreThis theme appears in principle 12 of the stewardship code.
Fiduciary duty – United Kingdom	Consider client and beneficiary needs and report on stewardship and investment outcomes	Explain approach to seeking beneficiary/client views and incorporating their needs, time horizons, and stewardship policies and rationale for the chosen approach. Explain type of information communicated and methods and frequency of communication on what was communicated to beneficiaries/clients about stewardship and investment activities and outcomes to meet beneficiary/client needs. If applicable, explain reasons for instances of lack of alignment with clients� stewardship and investment policies. Read MoreThis theme appears in principle 6 of the stewardship code.
Monitor investees – United Kingdom	Monitor and hold managers and service providers accountable	Explain approach to monitoring managers and service providers. Explain actions taken where expectations were not met. Read MoreThis theme appears in principle 8 of the stewardship code.
Conflicts of interest policy – United Kingdom	Manage conflicts of interest and prioritize the best interests of clients and beneficiaries	Disclose conflicts policy and how it was applied to stewardship, citing examples. Read MoreThis theme appears in principle 3 of the stewardship code.
Report on stewardship to beneficiaries (1) – United Kingdom	Consider client and beneficiary needs and report on stewardship and investment outcomes	Explain approach to seeking beneficiary or client views and incorporating their needs, time horizons, and stewardship policies and rationale for the chosen approach. Explain type of information communicated and methods and frequency of communication on what was communicated to beneficiaries/clients about stewardship and investment activities and outcomes to meet beneficiary/client needs. If applicable, explain reasons for instances of lack of alignment with clients� stewardship and investment policies. Read MoreThis theme appears in principle 6 of the stewardship code.
Report on stewardship to beneficiaries (2) – United Kingdom	Align purpose, investment beliefs, strategy, and culture with stewardship	Explain organizational purpose, culture, values, business model, strategy, and investment beliefs. Explain actions taken to ensure that investment beliefs, strategy and culture enable effective stewardship. Describe how purpose and investment beliefs have guided their stewardship, investment strategy and decision-making and assess effectiveness in serving clients and beneficiaries. Read MoreThis theme appears in principle 1 of the stewardship code.
Regular/effective investee communication – United Kingdom	Engage to maintain or enhance the value of assets	Explain expectations for those that engage on their behalf, approach to prioritizing engagement and developing well-informed and precise objectives for engagement, the methods of engagement used, the reasons for the chosen approach, and how engagement differs for funds, assets, and geographies. Describe outcomes of engagement. Read MoreThis theme appears in principle 9 of the stewardship code.
Escalation – United Kingdom	Where necessary, escalate	Explain expectations for managers that escalate on their behalf, approach to prioritizing issues for escalation, examples of escalation and rationale for chosen approach, and how escalation differs for funds, assets or geographies. Describe the outcomes of escalation. Read MoreThis theme appears in principle 11 of the stewardship code.
Collective engagement – United Kingdom	Where necessary, collaboratively engage	Disclose collaborative engagements participated in, why, and the outcomes. Read MoreThis theme appears in principle 10 of the stewardship code.
ESG integration – United Kingdom	Integrate stewardship and investment, including ESG issues and climate change	Explain how integrating stewardship and investment has differed for funds, asset classes, and geographies. If applicable, explain how tenders have included a requirement to integrate stewardship and investment, including material ESG issues. If applicable, describe (a) the processes chosen and (b) the criteria given to service providers to integrate stewardship with investment, including material ESG issues and aligning with investment time horizons of beneficiaries and clients. Describe how information gathered through stewardship has informed acquisition, monitoring and exit decisions, with reference to clients and beneficiaries' best interest. Read MoreThis theme appears in principle 7 of the stewardship code.
Build capacity to engage effectively (1) – United Kingdom		Explain how governance structures and processes enabled oversight and accountability for effective stewardship, the rationale for the chosen approach, and how it may be improved. Explain how stewardship is resourced and how performance management and reward programs incentivize integrating stewardship and investment decisionmaking. Read MoreThis theme appears in principle 2 of the stewardship code.
Build capacity to engage effectively (2) – United Kingdom	Review policies, assure processes, and assess effectiveness	Explain review of stewardship policies to ensure efficacy, any assurance on approach to stewardship, and approach to ensuring fair, balanced, and understandable stewardship reporting. Read MoreThis theme appears in principle 5 of the stewardship code.
Investor internal incentives (compensation) – United Kingdom		Explain how governance structures and processes enabled oversight and accountability for effective stewardship, the rationale for the chosen approach, and how it may be improved. Explain how stewardship is resourced and how performance management and reward programs incentivize integrating stewardship and investment decisionmaking. Read MoreThis theme appears in principle 2 of the stewardship code.
Identify and respond to market-wide and systemic risks – United Kingdom	Identify and respond to market-wide and systemic risks	Explain approach to (a) identifying and responding to market-wide and systemic risks and (b) collaborating with other stakeholders to improve the functioning of financial markets. Explain any roles in relevant industry initiatives and resulting investment alignment. Read MoreThis theme appears in principle 4 of the stewardship code.
Voting policy and disclosure – United States (ISG)	Institutional investors are responsible for proxy voting decisions and should monitor the relevant activities and policies of third parties that advise them on those decisions	If delegation of proxy voting responsibilities to a third party occurs, have an affirmative obligation to evaluate the third party's processes, policies and capabilities to ensure protection of institutional investors and their beneficiaries' long-term interests Ensure that the agent has processes in place to avoid/mitigate conflicts of interest. Read MoreThis theme appears in principle D of the stewardship code.
Disclose stewardship policies – United States (ISG)	Institutional investors should demonstrate how they evaluate corporate governance factors with respect to the companies in which they invest.	Adopt and disclose guidelines that help oversee the corporate governance practices of their portfolio companies. Hold portfolio companies accountable to the Corporate Governance Principles. Help evaluate and engage portfolio companies on corporate governance matters consistent with the long-term interests of beneficiaries. Disclose the proxy voting and general engagement activities undertaken AOs who delegate their corporate governance tasks to their AMs should evaluate how they are executing these responsibilities in line with the AOs investment objectives. Read MoreThis theme appears in principle B of the stewardship code.
Fiduciary duty – United States (ISG)	Institutional investors are accountable to those whose money they invest.	AMs are responsible to their clients, AOs to their beneficiaries. Both Ensure client and/or beneficiary assets are overseen in a responsible manner. Read MoreThis theme appears in principle A of the stewardship code.
Monitor investees – United States (ISG)	Institutional investors should demonstrate how they evaluate corporate governance factors with respect to the companies in which they invest.	Adopt and disclose guidelines that help oversee the corporate governance practices of their portfolio companies. Hold portfolio companies accountable to the Corporate Governance Principles. Help evaluate and engage portfolio companies on corporate governance matters consistent with the long-term interests of beneficiaries. Disclose the proxy voting and general engagement activities undertaken AOs who delegate their corporate governance tasks to their AMs should evaluate how they are executing these responsibilities in line with the AOs investment objectives. Read MoreThis theme appears in principle B of the stewardship code.
Conflicts of interest policy – United States (ISG)	Institutional investors should disclose how they manage potential conflicts of interest that may arise in their proxy voting and engagement activities.	The proxy voting and engagement guidelines of investors should be designed to protect the interests of their clients Have clear procedures that help identify and mitigate potential conflicts of interest that could compromise their ability to put their clients interests first. If delegation of proxy voting responsibilities to AMs occurs, ensure that the AMs have appropriate mechanisms to identify & mitigate potential conflicts of interest. Read MoreThis theme appears in principle C of the stewardship code.
Report on stewardship to beneficiaries – United States (ISG)	Institutional investors should demonstrate how they evaluate corporate governance factors with respect to the companies in which they invest.	Adopt and disclose guidelines that help oversee the corporate governance practices of their portfolio companies. Hold portfolio companies accountable to the Corporate Governance Principles. Help evaluate and engage portfolio companies on corporate governance matters consistent with the long-term interests of beneficiaries. Disclose the proxy voting and general engagement activities undertaken AOs who delegate their corporate governance tasks to their AMs should evaluate how they are executing these responsibilities in line with the AOs investment objectives. Read MoreThis theme appears in principle B of the stewardship code.
Regular/effective investee communication – United States (ISG)	Institutional investors should address and attempt to resolve differences with companies in a constructive and pragmatic manner	Disclose to companies how to contact them regarding voting and engagement. Engage in a manner to build a foundation of trust and common understanding. Clearly communicate their views/concerns with a company's practices on governance-related matters. Identify mutually held objectives and areas of disagreement Disclose what actions they may take if dissatisfied with the outcome of their engagement efforts. Read MoreThis theme appears in principle E of the stewardship code.
Escalation – United States (ISG)	Institutional investors should address and attempt to resolve differences with companies in a constructive and pragmatic manner	Disclose to companies how to contact them regarding voting and engagement. Engage in a manner to build a foundation of trust and common understanding. Clearly communicate their views/concerns with a company's practices on governance-related matters. Identify mutually held objectives and areas of disagreement Disclose what actions they may take if dissatisfied with the outcome of their engagement efforts. Read MoreThis theme appears in principle E of the stewardship code.
Collective engagement – United States (ISG)	Institutional investors should work together, where appropriate, to encourage the adoption and implementation of the Corporate Governance and Stewardship Principles	As corporate governance norms evolve over time, collaborate to ensure that the framework continues to represent their common views on corporate governance best practices. Address common concerns related to CG practices, public policy, shareholder rights by participating, in discussions as members of industry organizations or associations. Read MoreThis theme appears in principle F of the stewardship code.

FCLTGlobal has synthesized 22 stewardship codes to create this interactive tool, which is designed to help asset managers and asset owners navigate the current stewardship landscape. The themes are organized so that the most common appear at the top of the tool.

Note on abbreviations: AO = asset owner; AM = asset manager; II = institutional investor; CG = corporate governance; RBC = responsible business conduct; and GM = general meeting.

Select a country to learn more about their stewardship code, or choose a theme to see which countries address that topic.