November 27, 2019
Dear Sir / Madam
As an asset management firm which uses a proxy voting service as part of our fiduciary duty to investors, we value the service as it allows investors to express their voice collectively on issues of concern to them, without the cost and disruption of waging proxy fights.
We are concerned that this proposal may swing the balance of power towards the companies involved, rather than towards investors.
However, the one point which we do support is that the proxy adviser should engage with the company before issuing their report to investors as we believe that the right of reply is important. However we also have concerns as to how company insiders may treat these advance reviews of reports as such reports would clearly be prices sensitive, confidential information.
Regards
Clem Geraghty
Head of Compliance