How to report
We have produced UK Stewardship Code: Advice for October 2021 applications
with information about making a successful application, which may be useful to anyone preparing a report for October 2021 or in 2022.
The Stewardship Code
comprises a set of 12 ‘apply and explain’ Principles for asset managers and asset owners, and a separate set of six Principles for service providers.
The Principles are supported by reporting expectations which indicate the information that organisations should publicly reported to become a signatory.
The Code has four main sections:
- Purpose and Governance
- Investment Approach
- Exercising Rights and Responsibilities
The Report should be a single document structured to give a clear picture of how the organisation has applied the Code in the reporting period. The FRC does not prescribe a single approach so long as the Report explains how the Principles have been applied using the reporting expectations. The report should be a useful and accessible document for clients or beneficiaries as well as the regulator.
Organisations may also include within the same report information relevant to meet other regulatory reporting requirements, such as the Shareholder Rights Directive II (SRD II).
Signatories need to report on all 12 Principles (6 for service providers) and their reporting expectations. In cases where there is a strong reason why a reporting expectation does not apply, applicants should explain this reason.
For some Principles, such as Principles 6, 7, 8, 9, 11 and 12, different reporting expectations apply depending on the role of the organisation. Organisations should choose the reporting expectation most appropriate for their business. It may be necessary in some cases to report on both reporting expectations aimed at asset owners and asset managers.
The Principles and reporting expectations apply to all asset classes and organisations should explain the rights and responsibilities associated with different asset classes and geographies, demonstrating how their approach differed as a result.
Focus on outcomes
The Code has a focus on reporting stewardship activities and outcomes. Prospective signatories should demonstrate how they have practiced stewardship during the reporting period to fulfil their policies and objectives.
Activities identify the actions taken by the organisation during the reporting period to fulfil the Principle, while Outcomes explain the result of the actions taken during the reporting period. Case studies can be a useful tool to meet reporting expectations and describe activity and outcomes, explaining the firm’s approach and its role in the process.
Effective outcome reporting is clear about the progress made against objectives and identifies next steps where appropriate. Fair reporting also identifies areas where objectives have not been met and lessons learned.
Review of Early Reporting
The FRC has published a Review of Early Reporting
to the Stewardship Code. The purpose of the Review is to support prospective signatories in meeting this new reporting requirements. We analysed 21 responsible investment, active ownership and stewardship reports and looked at how well prospective signatories are addressing the higher standards we have set. It highlights expectations for the 12 Principles and provides examples of effective reporting.