All intermediaries with clients invested in European securities must offer a service to facilitate the transmission of meeting materials to investors and provide a means for the investor to vote. There are no exceptions.
Are you able to transmit meeting information ‘without delay’?
SRD II requires information to be transmitted in an electronic, machine-readable format ‘without delay’. Intermediaries must transmit meeting information to the investors on the same day the information is received. Voting must also be transmitted ‘without delay’ and markets are defining this as part of their transpositions; intermediaries must be able to support multiple models.
Are you prepared to manage and disclose beneficial owner information along with the vote to the markets?
SRD II requires that intermediaries provide all voting at the underlying shareholder level in the EU and EEA markets. Each market may interpret the disclosure level differently.
Are you prepared to receive and pass pre-meeting confirmations generated by issuers and their agents in markets where electronic voting is submitted?
Intermediaries must pass confirmations provided by the issuers or their agents in an electronic, machine-readable format ‘without delay’.
SRD II requires intermediaries to disclose all investors regardless of OBO designation.
Are you prepared to monitor and manage electronic, machine-readable issuer requests for shareholder disclosure in all EU and EEA markets?
Intermediaries must be able to receive and authenticate requests made by issuing companies in electronic, machine-readable formats. Most markets do not have a central source managing the issuance of disclosure requests, so intermediaries must be able to monitor all markets for the requests.
Are you aware of the timing requirements associated with managing and responding to shareholder disclosure requests?
Intermediaries must provide electronic, machine-readable responses that within the same business day AND the request must be forwarded to any clients that are also intermediaries.
Comply with Confidence
SRD II Implementation is complex. The good news is that many of the same technologies and solutions you already use in North America—e.g., e-delivery, investor mailbox, mobile apps—can help streamline the transition. Plus, Broadridge has the global infrastructure and experience you need to manage every aspect of compliance:
- Agenda distribution
- Voting and vote confirmation
- Shareholder disclosure
For additional insight, visit our SRD II resource page or contact us.