SRD II Annual Institutional Investor Disclosure PEL 2020
This is a statement of PIMCO Europe Ltd (the “Company”), a company incorporated under the laws of England and Wales which is authorised and regulated by the Financial Conduct Authority (“FCA”). The Company is required to comply with applicable FCA rules transposing aspects of Article 3i of the Shareholder Rights Directive (SRD II) ((EU) 2017/828) (“SRD II”), as it forms part of the domestic law of the UK by virtue of section 3 of the European Union (Withdrawal) Act 2018.
The Company is part of the PIMCO group (the “PIMCO Group”), one of the world’s premier fixed income investment advisors. As of 30 September 2021 the PIMCO Group had overall assets under management of US$ 2.2 trillion. As an investment advisor of primarily fixed income based products, investments in shares form only a small proportion of the PIMCO Group’s overall assets under management.
The below information is provided to assist applicable institutional investors (as defined in Article 2(e) of SRD II) who have an investment management agreement with the Company with their assessment of the implementation of their investment strategy and how such implementation contributes to their medium to long-term performance.
1. Key material medium to long-term risks associated with the investments
The investment management agreement between you and the Company will summarise the specific risks of instruments held within your portfolio.
The PIMCO Group believes in investing in corporations that have demonstrated a sustainable framework for dealing with environmental, social and governance (“ESG”) matters. The PIMCO Group recognises that ESG-related issues are an increasingly critical factor in understanding global economies and has an ESG Investment Policy statement available at https://pim.co/y5eww and publishes an annual report on the PIMCO Group’s ESG activities. The most recent copy of the PIMCO Group’s ESG Investing Report is available at https://pim.co/acln8.
2. Portfolio composition
The Company sends you a monthly MiFID II ex-post costs and charges report, which includes details of the holdings in all instruments within your portfolio.
3. Turnover and turnover costs
The Company sends you a monthly MiFID II ex-post costs and charges report, which includes transaction details of all securities bought and sold over the monthly period.
The Company sends you an annual MiFID II ex-post costs and charges report, which provides transaction costs associated with the turnover of financial instruments within your portfolio.
4. Use of proxy advisors for the purpose of engagement activities
The PIMCO Group has a proxy voting policy that describes its approach to exercising voting rights and other rights attached to shares. The PIMCO Group has engaged Institutional Shareholder Services Inc., a proxy voting advisory firm, to provide research recommendations and vote execution services.
5. Policy on securities lending
The Company does not currently enter into securities lending agreements on your behalf.
6. How we make investment decisions in relation to shares based on the evaluation of medium to long-term performance of the investee company
At PIMCO, we define ESG Integration as the consistent consideration of material ESG factors into our investment research process to enhance our clients’ risk-adjusted returns. Material ESG factors may include but are not limited to: climate change risks, social inequality, shifting consumer preferences, regulatory risks, talent management or misconduct at an issuer, among others. We believe incorporating relevant ESG factors should be part of a robust investment process.
We recognize that ESG factors are increasingly essential inputs when evaluating global economies, markets, industries and business models. Material ESG factors are important considerations when evaluating long-term investment opportunities and risks for all asset classes in both public and private markets. Our commitment to ESG Integration was one of the main drivers that led PIMCO to become a signatory to the UN Principles of Responsible Investment (PRI) in September 2011.
Integrating ESG factors into the evaluation process does not mean that ESG information is the sole or primary consideration for an investment decision; instead, PIMCO’s portfolio managers and analyst teams evaluate and weigh a variety of financial and non-financial factors, which can include ESG considerations, to make investment decisions. By increasing and diversifying the information assessed by the portfolio management team where relevant we believe that we are able to generate a more holistic view of an investment, which we believe will generate opportunities to enhance returns for our clients.
7. Conflicts of interests
The PIMCO Group manages the investments of a large number of clients and therefore potential conflicts of interest may arise in a number of areas. In line with applicable regulatory requirements, the Company has a conflicts of interest policy, which sets out the circumstances, which may constitute actual or potential conflicts of interest and the measures adopted by the Company to manage these conflicts.
18 October 2021