PIRC is regulated by the Financial Conduct Authority and all employees are required to complete a declaration of interests. Public disclosure of the conflicts of PIRC’s conflict of interest policy is by means of the Stewardship Code Statement and PIRC’s compliance statement with the Best Practice Principles for Providers of Shareholder Voting Research & Analysis, both of which are on the PIRC website.
We recognise that PIRC is in a position of trust and should act at all times in the best long terms interests of its clients. One of our principles of best practice is the disclosure of conflicts of interest. PIRC has taken the business decision that to avoid conflicts of interest, we should not seek to provide services to both issuers and shareowners. Therefore PIRC only provides services to shareowners and does not work for, or consult to, public companies. This means the potential for conflicts of interest rarely arises with regard to the research carried out on client portfolios.
However, we do recognise the potential for conflicts of interest to arise, and PIRC will disclose in reports to voting services clients if it perceives a conflict to exist, for example if PIRC has advised the proponents of a shareholder resolution. Other conflicts of interest may arise through business, financial, personal or other interests. PIRC will generally identify any conflicts that may arise if it is selected to provide services for shareowners. It will then identify if they are manageable and will implement measures taken to avoid the conflict.
PIRC is regulated by the Financial Conduct Authority and all employees are required to complete a declaration of interests. PIRC internally reviews its conflicts of interest policy and has incorporated this into its internal HR manual. Public disclosure of the conflicts of interest policy is by means of the Stewardship Code Statement and PIRC’s compliance statement with the Best Practice Principles for Providers of Shareholder Voting Research & Analysis, both of which are prominently displayed on the PIRC public website.
Engagement services clients are frequently present in engagement meetings, with PIRC staff. In relation to its own staff, PIRC follows the same conflict of interest approach outlined above in respect of each engagement. For clients, in engagement meetings, in practice this is often simply addressed by stating the nature of the connection that may be perceived as a conflict of interest, and if this is acceptable to the company representatives, the meeting can progress. As a matter of course, in engagement meetings, it is clarified that PIRC staff are only there to represent the client’s agenda. PIRC has also worked with one engagement client to establish a code of conduct for them that covers conflicts of interest. Part of the conflict of interest clause contained within this code includes disclosure when they must declare conflicts of interest and in which fora.