Stewardship Code...

It should be appearing sometime soon, and there are few things worth looking out for.

Coverage - first up, what do we mean by 'institutional investors'? Just the asset managers or their clients (pension funds mainly) too? I suspect that some people are worried that if it only applies to managers then things may continue as before, because the clients won't put any pressure on. Secondly, what about companies that advise investors on ownership issues - the voting advisers. Personally I see no good reasons why they (...er... we) shouldn't be subject to the Code given the influence exerted.

Monitoring/enforcement - this is the biggie IMO. Who is going to monitor the application of 'comply and explain' when it comes to the Code? With the Corp Gov Code monitoring is carried out by the market, in the shape of shareholders and their advisers. But who will do the job in this case? Maybe investment consultants? But is there much dosh in it? The FRC talked about adopting the IMA engagement survey, but that doesn't quite fit the bill. Personally I think there isn't a better alternative than the FRC doing it themselves, but I suspect they lack the resource.

Pooled funds - I know several submissions to the consultation raised the issue of client voting in pooled funds. Any kind of statement here from the FRC would be hugely helpful to nudge managers in the right direction.

Voting disclosure - my hobbyhorse obviously, but I find it hard to see how anyone reasonable could conclude that the current 'comply or explain' system is working (because the vast majority of those who don't comply don't explain). So it will be interesting to see if the wording in the Code has been toughened up. I have no expectation that it will have been, but worth looking out for.