Stewardship Policy

Commitment to the UK Stewardship Code

Under Rule 2.2.3R of the Financial Conduct Authority's (FCA) Conduct of Business Sourcebook, Legg Mason Investments (Europe) Limited and Legg Mason Investment Funds Limited (the "Firms") are required to include on this website a disclosure about the nature of their commitment to the UK Financial Reporting Council's Stewardship Code (the "Code") or, where they do not commit to the Code, their alternative investment strategy. The Code is a voluntary code and sets out a number of principles relating to engagement by investors with UK equity issuers. Investors that commit to the Code can either comply with it in full or choose not to comply with aspects of the Code, in which case they are required to explain their non compliance.

The Firms are wholly owned subsidiaries of Legg Mason, Inc. ("Legg Mason") a global asset management company. The most distinctive feature of Legg Mason is its specialised approach to managing money. It houses a selection of prestigious investment management businesses, each operating autonomously and focusing on a distinct segment of the market. The Firms have delegated investment management to some or all of these investment management businesses (and in one case to Shiozumi Asset Management Company Limited, a non Legg Mason owned investment management business in Japan). Accordingly each investment management business pursues different strategies across different asset classes and markets across the globe.

While the Firms generally support the objectives that underlie the Code it is relevant to some but not all aspects of the investment management businesses and hence the Firms’ activities. The approach and policies of the investment management businesses in relation to engagement with issuers and their management are determined by each investment management business. Subject to any requirements that must be complied with, each investment management business takes its own approach to engagement with issuers and their management in all of the jurisdictions in which it invests and, consequently, will have appropriate policies to comply with the Code or similar codes in such jurisdictions.


The Revised Shareholder Rights Directive (“SRD II”) comes into effect on 10th June 2019 and introduces new rules to further promote effective stewardship and long-term investment decision making.

Specifically SRD II imposes requirements on the Firms to develop and publicly disclose information on their engagement policies and investment strategies.

The Firms are reviewing their compliance with the new requirements and considering the approach to take in light of Legg Mason’s distinctive approach to managing money explained above. The Firms will do this in conjunction with the investment management businesses that management of assets has been delegated to.