Shareholder Rights Directive (SRD II)

SRD II imposes certain disclosure requirements for EU-based asset managers and asset owners on engagement and investment strategies as investors in European Economic Area (“EEA”) companies. This is to enhance the rights of shareholders by imposing certain minimum standards on the exercise of shareholder voting rights at EU listed companies.

Pursuant to SRD II, Raymond James Investment Services (“Raymond James”) must disclose a shareholder engagement policy or provide a clear
and reasoned explanation of why we are not.

Raymond James provides Discretionary Investment Management services to clients using a devolved investment proposition. This allows each Raymond James branch to determine their own investment strategy, which will include aspects of shareholder engagement. As a result, there is no single identifiable engagement policy at the firm level, as the services provided to Raymond James clients are not generally involved active shareholder engagement in respect of those shareholder rights. Information about shareholder engagement can be obtained from respective branches where applicable.

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