Ireland · The traded public limited company
Shareholder identification, transmission of information, engagement policies and proxy advisors
the Companies Act 2014 · sections 1110B to 1110E and 1110G to 1110K
Shareholder identification data may not be kept beyond its storage limit
Identification data carries a storage limit that is easy to breach by inaction. Without prejudice to any longer storage period laid down by European Union law, and subject to section 1110B(6), where a requester holds information obtained under the section, section 1110B(5) governs how long it may be held. A company or intermediary that keeps a shareholder identification file indefinitely has not read the subsection.
The engagement duties sit on investors and advisers rather than on the company, and each of them is a disclosure duty rather than a conduct duty. A relevant institutional investor must develop and publicly disclose an engagement policy in accordance with section 1110G(1), subject to section 1110G(2), and must publicly disclose how the main elements of its equity investment strategy are consistent with the matters section 1110I(1) names. A relevant proxy advisor must publicly disclose the information section 1110K(4)(b) lists, subject to section 1110K(4)(c).
Sections 1110G to 1110K make investors and proxy advisors disclose or explain
Sections 1110B and 1110C govern the identification of shareholders and the transmission of information between the company, intermediaries and shareholders. Sections 1110D and 1110E govern the duties of an intermediary. Where an intermediary provides services to a shareholder in relation to shares, that intermediary must assist the exercise of the shareholder's rights as section 1110D(1) requires.
Sections 1110G to 1110K govern the engagement policy of institutional investors and asset managers, the disclosure of investment strategy, the transparency of asset managers and the transparency of proxy advisors. The obligations are structured as disclose or explain, so an investor that does not engage still has something to publish.
The system generates your ComplianceSME company passport and then walks you through the working files
Working files 141, 142, 143, 144 and 145 of the IE-COMPANY agent toolkit cover this situation. Working file 141 works through identification of shareholders and transmission of information. Working file 142 works through the exercise of shareholder rights through intermediaries. Working file 143 works through the engagement policy of institutional investors and asset managers, and Working file 144 works through investment strategy and asset manager transparency. Working file 145 works through the transparency of proxy advisors.
- Working file 141 · Identification of shareholders and transmission of information
- Working file 142 · Facilitation of the exercise of shareholder rights
- Working file 143 · The engagement policy of institutional investors and asset managers
- Working file 144 · Investment strategy of institutional investors and transparency of asset managers
- Working file 145 · Transparency of proxy advisors
Free, with a free account
The working files above open from your ComplianceSME account at no charge, and so does the rest of the Companies Act 2014 toolkit: 215 working files across the 75 situations a company registered in Ireland can be in. Working file 1 runs first and builds the company passport; after that you open each working file as its situation arises.
A working file runs in Claude. You ask the ComplianceSME connector for it in a dedicated premium seat on the Claude Team plan. It asks one question at a time, then returns the document the Companies Act 2014 names, citing the Act's section at every step. Nothing is downloaded and nothing is installed.
The report stays yours, ready for a bank, an insurer, a customer or an inspector. Your dashboard shows every working file and its state.
Open this working fileComplianceSME tracks the Companies Act 2014 and updates the toolkit on your account through the Compliance Complete account, so that you are never working from a superseded version. Compliance Complete