Staff acknowledge that there are currently no continuous disclosure requirements relating to a fund’s past shareholder engagement activities.
However, staff encourage all funds that use shareholder engagement as an ESG strategy to provide disclosure about their past shareholder engagement activities on their designated websites, for the same reasons discussed above in relation to the disclosure of past proxy voting records.
In addition, similarly, staff encourage all funds that use shareholder engagement as an ESG strategy to include, as part of the summary of the results of the fund’s operations in the MRFP, disclosure about how the fund’s past shareholder engagements during that period align with the ESG-related investment objectives and/or strategies of the fund.