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Second Shareholders' Rights Directive ("SRD
II")
SRD II has been transposed into Irish law by the European
Union (Shareholders' Rights) Regulations 2020 (the
"Regulations"). The Regulations aim to
increase transparency and shareholder engagement in corporate
governance.
The Regulations apply to "relevant institutional
investors" which includes a pension scheme where the
scheme is (i) an occupational pension scheme regulated in Ireland
and (ii) invests directly, or through an asset manager, in shares
traded on an EU regulated market. If a pension scheme meets these
criteria it must publicly disclose an engagement policy, its
investment strategy and any arrangements that it holds with asset
managers. Public disclosure means publishing the information to
make the matter available "free of charge on the website
of the relevant institutional investor".