Goverance Policy

Independent, Impartial Governance Research

High quality voting decisions begin with the right data, in the right format at the right time. When it comes to voting policies there are plenty of choices to be made. Most responsible investors would also agree that “one size doesn’t fit all”. That’s why Manifest isn’t tied to providing just one flavour of research or voting guidance. Nor do we think that non-UK companies should be judged by UK standards.

At the very heart of our research is a detailed understanding of local markets laws, listing rules, regulations and governance codes. Whether you use our bespoke voting recommendations service or stand-alone research reports, Manifest can ensure consistent and relevant global research advice across your entire portfolio.

In the UK, for example, our research builds on the guidelines published by various trade association Investor Protection Committees (IPCs):

  • Association of British Insurers (ABI);
  • Association of Investment Companies (AIC);
  • Institutional Shareholder’s Committee (ISC); and
  • National Association of Pension Funds (NAPF);

NB: All IPC policies are public domain documents and no license is required for their use.

We also factor in the guidelines of major investors such as, for example, Hermes, F&C, Aviva; Universities Superannuation Scheme and RailPen, all of whom make their guidelines publicly available. The views of global investors with public voting policies are also taken into account, whether they are customers or not.

Globally we take account of not just the local equivalents of the UK’s Combined Code, but also supra-national bodies such as OECD and ICGN.

Research Objectivity

Manifest’s research is produced according to in-house procedures consistent with the CFA Institute’s Research Objectivity Standards. This means that per principle 6, Manifest’s analysts will verify facts, policies or disclosures which are unclear from corporate documentation, however they are prohibited from:

a) Sharing with, or communicating to, a subject company, prior to publication, any section of a research report that might communicate the research analyst’s proposed recommendation or rating; and

b) Directly or indirectly promising a subject company or other corporate issuer a favorable report; or

c) Threatening to change reports, recommendations, or price targets.

Equally they will not change their research on the basis of threatening or abusive communications. In the event of a dispute, issuers may refer to our Research Manager or failing that, the CEO.

Voting Confidentiality

Our customers’ voting intentions remain confidential and we will not respond to requests to disclose voting intentions. Nor will this data be resold or otherwise transmitted to any other party, save the authorised vote tabulator for the meeting in question.


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