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Legal and regulatory information

Please read the Terms and Conditions below before proceeding to our website.

Alternatively, view the Terms and Conditions in PDF format.

These Terms and Conditions (defined below) set out the terms on which you may make use of our website (the "Site"). For the avoidance of doubt, "use" of the Site includes, without limitation, accessing, browsing, linking to, posting material on or registering to use our Site.

Use of this Site is offered to you on condition of your acceptance, without modification, of the Terms and Conditions (defined below). By using the Site, you confirm that you agree to be bound by these terms and conditions and any additional terms which are set out on the Site including, but not limited to, the Privacy Policy and Cookie Policy as amended by us from time to time (collectively, the "Terms and Conditions").

If you do not accept the Terms and Conditions, then please do not use the Site.

The content of the Site is for information purposes only and does not constitute a sample of units or shares in investment funds.

We may amend the Terms and Conditions, without notice, at any time. Please check this page from time to time to take notice of any changes, as any use of the Site after such amendments have been made shall be treated as signifying your acceptance of the applicable Terms and Conditions at the time you access the Site.

INFORMATION ABOUT US

Throughout the Terms and Conditions, unless expressly stated otherwise, references to "Legal & General", "We" or "Us" shall mean all of the companies mentioned below. The following companies are all authorised and regulated by the Financial Conduct Authority and have their registered office at One Coleman Street, London EC2R 5AA:

  • Legal & General Investment Management Limited ("LGIM"), a company incorporated in England & Wales (Registered No. 2091894) and entered on the Financial Services Register number 119272.LGIM Real Assets (Operator) Limited, a company incorporated in England & Wales (Registered Number 05522016) and entered on the Financial Services Register number 447041.
  • Legal & General (Unit Trust Managers) Limited, a company incorporated in England & Wales (Registered Number 01009418) and entered on the Financial Services Register number 1119273.
  • Legal & General Property Limited, a company incorporated in England and Wales (Registered Number 02091897) and entered on the Financial Services Register number 313282. Please note that while Legal & General Property Limited is regulated by the Financial Conduct Authority, we may conduct certain activities that are unregulated.

The following company is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority:

  • Legal and General Assurance (Pensions Management) Limited ("PMC"), a company incorporated in England & Wales (Registered No. 01006112) and entered on the Financial Services Register number 202202.

Each of these companies is entered on the Financial Services Register which you can verify by visiting the Financial Conduct Authority’s website http://www.fca.org.uk or by contacting the Financial Conduct Authority on 0800 111 6768.

The following company is authorised and regulated by the Central Bank of Ireland:

  • LGIM Managers (Europe) Limited, authorised by the Central Bank of Ireland as a UCITS management company (pursuant to European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations, 2011 (S.I. No. 352 of 2011), as amended) and as an alternative investment fund manager with “top up” permissions which enable the firm to carry out certain additional MiFID investment services (pursuant to the European Union (Alternative Investment Fund Managers) Regulations 2013 (S.I. No. 257 of 2013), as amended). Registered in Ireland with the Companies Registration Office (No. 609677). Registered Office: 70 Sir John Rogerson’s Quay, Dublin, 2, Ireland. Regulated by the Central Bank of Ireland (No. C173733).
  • LGIM Managers (Europe) Limited operates a branch network in the European Economic Area, which is subject to supervision by the Central Bank of Ireland. In Italy, the branch office of LGIM Managers (Europe) Limited is subject to limited supervision by the Commissione Nazionale per le società e la Borsa (“CONSOB”) and is registered with Banca d’Italia (no. 23978.0) with registered office at Piazza della Repubblica 3, Milano 20121, (Companies’ Register no. MI - 2557936). In Germany, the branch office of LGIM Managers (Europe) Limited is subject to limited supervision by the German Federal Financial Supervisory Authority (“BaFin”). In the Netherlands, the branch office of LGIM Managers (Europe) Limited is subject to limited supervision by the Dutch Authority for the Financial Markets (“AFM“) and it is included in the register held by the AFM and registered with the trade register of the Chamber of Commerce under number 74481231. In Sweden, the branch office of LGIM Managers (Europe) Limited is subject to limited supervision by the Swedish Financial Supervisory Authority (“SFSA”).

Details about the extent of our authorisation and regulation are available from us upon request.

The company can be verified by visiting the Central Bank of Ireland’s website www.centralbank.ie The ultimate holding company of all of the above companies is Legal & General Group plc, a company incorporated in England & Wales (Registered No 01417162).

In the United Kingdom and outside the European Economic Area, this Site is issued by Legal & General Investment Management Limited. In the European Economic Area, this Site is issued by LGIM Managers (Europe) Limited.

INTENDED AUDIENCE AND USE OF INFORMATION

 

This Site is not intended for use by all persons in all geographic locations.

 

If you are a retail client who accesses this Site via your advisor, then we are not providing you with financial services under these Terms and Conditions. If you need any more information on the financial services provided to you, please contact your advisor. You will access this Site only for reasons agreed with your advisor and use the Site in an appropriate way, without misusing or abusing any of the content available.

You are not authorised to copy, distribute or otherwise make use of any logo, trademark, copyright material or other intellectual property of Legal & General which appears on the Site, except as expressly permitted in the Terms and Conditions.

The contents of this Site are provided for general information only and do not constitute advice of any kind (including investment, tax or legal) on which you should rely, or a recommendation to buy or sell any product, service or investment.

These Terms and Conditions are in addition to any terms of business which you may have in place with Legal & General as a direct customer ("Direct Terms") and in the event of any conflict between these Terms and Conditions and any Direct Terms, the terms and conditions of the Direct Terms will prevail.

Please note that any services or products offered by Legal & General will be subject to their own terms and conditions, which you must also read.

The services or products referred to or mentioned on this Site are not available to persons in any jurisdiction where Legal & General is not registered or authorised to engage in any investment business or activity requiring registration or authorisation ("Unauthorised Jurisdiction"). Use of this Site in an Unauthorised Jurisdiction is entirely at your own risk. You should seek advice on your position from your professional advisers.

In particular, this Site and its contents are not directed at any person that is resident in the United States ("US person"), and no offer or invitation is made to any US person to acquire or sell any service, product or security referred to. The provision of any information in this Site does not constitute an offer to US persons to purchase securities.

If you choose to access information on this Site, it is your responsibility to comply with applicable local, national or international laws. Specific variations to these Terms and Conditions apply to each jurisdiction in which Legal & General is authorised or registered to engage in investment business or activities, and these variations can be found below. You must comply with these Terms and Conditions, as varied by the applicable terms below, in relation to the jurisdiction in which you are accessing and using the Site.

PROFESSIONAL INVESTMENT ADVISER AND INVESTMENT RISK

You should consult a professional adviser on your particular financial circumstances before taking, or refraining from taking, any action on the basis of the content of our Site, and you should not rely on the material on this Site. Before making an investment, you should read the appropriate fund prospectus (if applicable) or other terms and conditions as may be appropriate and raise any questions you have on this documentation with your professional adviser.

All investments involve a degree of risk. In particular note:

  • Past performance is not a guide to future performance;
  • The value of investments and the income from them may go down as well as up and you may not get back the amount invested; and
  • Where the investment has exposure to overseas assets, changes in exchange rates between currencies may cause the value of the investment and the level of income to rise and fall.

DISCLAIMER AND LIABILITY

This Site is provided "as is" and “as available” and no representations or warranties are given with respect to this Site or its contents (including without limitation warranties of merchantability and fitness for a particular purpose). In addition, Legal & General does not represent or warrant that the information accessible from or via the Site is accurate, complete or current.

To the fullest extent permitted by law, we exclude all conditions, warranties, representations or other terms which may apply to our Site or any content on it, whether express or implied. Your use of the Site and any of its content or features is at your own risk.

In no event shall Legal & General be responsible for any loss or damage of whatever kind arising out of access to or use of or reliance on any information posted on the Site or any information contained in or accessed through the Site.

Legal & General excludes all liability for any loss or damage and whether in tort (including without limitation negligence), contract or otherwise in connection with:

  1. your use of, inability to use, or the results of use of the Site;
  2. your use of or reliance on any content displayed on our Site;
  • any websites linked to the Site or the material on such websites; and
  1. any failure or performance error, omission, interruption, defect, delay in operation or transmission, system failure, unavailability or suspension of the Site, virus, distributed denial-of-service attack or other technologically harmful material that may infect your computer equipment, software, data or other proprietary material on account of your use of the Site or your downloading of any material from the Site or any websites linked to the Site, including, without limitation, loss of profits, loss of income, loss of anticipated savings, loss of revenues, loss of data, loss of goodwill or loss of contracts or business (in each case whether direct or indirect) or for any indirect, economic, consequential or special loss resulting from whatever cause.

Nothing in the Terms and Conditions shall exclude or limit Legal & General's liability for death or personal injury arising from our negligence, for fraud or fraudulent misrepresentation or for any other liability to the extent that such liability cannot be limited and/or excluded by applicable law.

ACCESSING OUR SITE

Our Site is made available free of charge.

We do not guarantee that our Site, or any content on it, will always be available or be uninterrupted. Access to our Site is permitted on a temporary basis. We may suspend, withdraw, discontinue or change all or any part of our Site without notice. We will not be liable to you if for any reason our Site is unavailable at any time or for any period. You are responsible for making all arrangements necessary for you to have access to our Site.

You are also responsible for ensuring that all persons who access our Site through your internet connection are aware of the Terms and Conditions, and that they comply with them.

The hosted service provider is L&G Resources Limited, One Coleman Street, London, EC2R 5AA,  telephone number: 0345 678 0020.

CHANGES TO CONTENT OF THE SITE

Legal & General reserves the right in its absolute discretion at any time and without notice to update, remove, amend or vary any of the content which appears on any page of this Site. However, please note that any of the content on our Site may be out of date at any given time, and we are under no obligation to update it.

USING AND SHARING OUR CONTENT
You may:

  1. view our Site for your personal use on any device that is compatible (including a PC, laptop, smartphone, tablet or other mobile device);
  2. print off one copy and download extracts of any page(s) from our Site solely for your own personal use;
  • draw the attention of others within your organisation to content posted on our Site; and
  1. share links to specific content or information on our Site by using any sharing tools we make available.

If you wish to share the content of our Site with others, we are happy for you to do the following, provided you comply with the terms set out in this section:

  1. publish online, the original headline and a link to the article and the first 100 words of an article ("Article Summary");
  2. forward the original headlines, links and an Article Summary to other individuals.

Other than in accordance with the paragraph above and unless stated on our Site or as indicated by a social sharing icon, you are not permitted to publish, re-transmit, re-distribute or otherwise re-produce any of the content which appears on any page of this Site in any format to anyone else, and you are prohibited from using any such content from the Site in connection with any business or commercial enterprise without obtaining a licence to do so from us or our licensors.

If you wish to re-produce in full any article on the Site, you should contact us directly for authorisation and if granted, we will require you to include an attribution to us when re-producing that article.

Further, you must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.

If you fail to comply with the paragraph above, we reserve the right to immediately terminate your right to link to our Site and to share the content of our Site, your right to use our Site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

LINKING AND POSTING MATERIAL TO OUR SITE

You may link to, or post material to this Site, provided that you do not:

  1. in any manner to imply that Legal & General is endorsing your investment strategies or policies or any statement made by you; or
  2. post or transmit material that is libelous, defamatory, obscene, fraudulent, misleading, harmful, that violates the property rights of others (including without limitation infringing use of any third party's intellectual property rights), that violates the privacy of others, or that is in violation of any applicable laws.

If you post material to our Site, we reserve the right to make editorial adjustments before publishing and reserve the right to remove or block any comments or materials posted to the Site which:

  1. contain profanity or other language likely to cause offence;
  2. break the law or condone or encourage unlawful activity (including, without limitation, breach of any intellectual property right, defamation and contempt of court);
  • are seen to impersonate or falsely claim to be, someone else or represent an organisation;
  1. repeatedly post the same or similar messages, i.e. spamming;
  2. are unrelated to the topic the message is posted under;
  3. include contact details such as phone numbers, postal or email addresses;
  • constitute advertising of products and / or services;
  • contain links to websites deemed to be unsuitable by us; and/or
  1. we do not feel are otherwise suitable or appropriate for the Site.

THIRD PARTY LINKS AND RESOURCE IN OUR SITE

The Site may contain links to third party websites and/or the content of third parties ("Third Party Content"). The Third Party Content has been made available solely for your convenience or information. The Third Party Content should not be interpreted as an endorsement by us and we have no control over such Third Party Content. Accordingly, Legal & General makes no representation, warranty or guarantee with respect to the Third Party Content whatsoever (including, as to its accuracy, completeness, suitability or reliability). If you access or use the Third Party Content, you do so entirely at your own risk. To the extent permitted by law, Legal & General excludes any liability arising from any use or reliance by you on the Third Party Content.

SECURITY

We do not guarantee that our Site will be secure or free from bugs, viruses or other malicious code.

You are responsible for configuring your information technology, computer programs and platforms in order to access our Site. You should use your own virus protection software.

You must not:

  • misuse our Site by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful;
  • attempt to gain unauthorised access to our Site, the server on which our Site is stored or any server, computer or database connected to our Site; or
  • attack our Site via a denial-of-service attack or a distributed denial-of service attack.

We will report any breach of this section to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our Site will cease immediately.

INTELLECTUAL PROPERTY

Legal & General is the owner or licensee of all copyrights and other intellectual property rights in the Site and all material published on this Site. Those works are protected by copyright laws and other intellectual property laws and treaties around the world. All such rights are reserved to Legal & General and its third party licensors.

All trade marks, service marks, company names or logos are the property of their respective rights-holders and no permission is given by Legal & General in respect of the use by you of any such trademarks, service marks, company names and logos and any such use may constitute an infringement of the rights-holders’ intellectual property rights.

All copyright in any indices values and constituents lists which may be published on the Site, from time to time, may belong to a third party licensor. Where such indices feature on the Site, Legal & General has obtained full license from the relevant licensor to use such copyright in the creation of the contents of the Site.

PRIVACY AND COOKIES

Legal & General is committed to protecting your privacy and keeping your personal information secure. Any personal information you supply to Legal & General via this Site will be treated in accordance with the data protection legislation relevant to your jurisdiction. When you use our Site, you consent to Legal & General collecting and using your personal data in the manner described in our Privacy Policy and Cookie Policy.

INVALIDITY

If any part of our Terms and Conditions is determined to be illegal, invalid or otherwise unenforceable (including, without limitation, any provisions in which we exclude or limit our liability to you), then to the extent of such illegality, invalidity or unenforceability, such terms or conditions shall be deleted and severed from the Terms and Conditions and the enforceability of the remaining Terms and Conditions will survive in full force and effect.

COMMUNICATIONS

Applicable laws may require that certain information or communications be in writing. When using the Site, you accept and agree that communication with Legal & General may be electronic. Legal & General may contact you by email or provide you with information by posting notices on this Site. This does not impact your marketing communication preferences. For any contractual purposes, you agree to electronic means of communication and you acknowledge that all contracts, notices, information and other communications that Legal & General sent to you electronically comply with any legal requirements that such communication be in writing. This provision does not affect your statutory rights.

TELEPHONE RECORDING

As required under and/or in accordance with applicable laws, Legal & General will record all telephone and electronic communications and conversations with you that result or may result in the undertaking of transactions in financial instruments on your behalf. Such records will be kept for a period of five years (or up to seven years upon request from the Financial Conduct Authority and/ or the Central Bank of Ireland (or such successor from time to time) or up to ten years to comply with Swiss law) and will be provided to you upon request.

WAIVER

If Legal & General fails at any time to insist upon strict performance of any of your obligations under the Terms and Conditions, or if Legal & General fails to exercise any of its rights or remedies to which Legal & General is entitled under these Terms and Conditions, this shall not constitute a waiver of such rights or remedies and shall not relieve you from compliance with such obligations.

ENTIRE AGREEMENT

The Terms and Conditions set out the whole agreement between you and Legal & General in relation to the use of the Site. Each party acknowledges that in entering into the Terms and Conditions it does not do so on the basis of or in reliance upon any representations, or promises undertakings, warranties or other statements (whether written or oral) of any nature whatsoever except as may be expressly provided in these Terms and Conditions.

LAW AND JURISDICTION

The Terms and Conditions and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws in the applicable jurisdiction.

The parties irrevocably agree that the courts in the applicable jurisdiction shall have exclusive jurisdiction to settle any dispute or claim that arises out of or in connection with the Terms and Conditions or their subject matter or formation (including non-contractual disputes or claims).

LANGUAGE

This agreement is drafted in the English language. If this agreement is translated into any other language, the English

language text shall prevail.

CONTACTING US

Questions, comments and requests are welcomed and should be sent to Web Marketing: Email us

In addition to the terms and conditions above, the following terms apply to the jurisdictions listed above them.

ABU DHABI GLOBAL MARKET, UNITED ARAB EMIRATES

The content provided on this Site is for information purposes only. None of the information, opinion, reports, prospectus or other documents contained or made available on this Site shall be construed as an offer, invitation, solicitation, advice or a recommendation for subscription or purchase by Legal & General to acquire or sell any products or securities referred to in this Site.

The "Telephone Recording" paragraph shall be deleted and replaced with "Legal & General will record all telephone and electronic communications and conversations with you that result or may result in the undertaking of transactions in financial instruments on your behalf. Such records will be kept for a period of five years (or such other period as is required by a relevant regulator or applicable law) and will be provided to you upon request."

We are not licensed or authorised to carry on any regulated activity (as defined by the Financial Services Regulatory Authority) in the Abu Dhabi Global Market.

In the "Law and Jurisdiction" section, the words "applicable jurisdiction" shall be deleted and replaced with "Abu Dhabi Global Market."

AUSTRALIA

To the extent that any services or products on this Site are not used for personal, domestic or household use, then, subject to section 64A of the Australian Consumer Law (Schedule 2 of the Competition and Consumer Act 2010 (Cth)) and section 12EC of the Australian Securities and Investment Commission Act 2001 (Cth), which is not otherwise disclaimed or limited under these Terms and Conditions is restricted to:-

  1. for goods, replacement or repair or the cost of replacement or repair; or
  2. for services, re-supply or the cost of re-supplying the services.

Under the Privacy Act 1988, an investor or any person may request access to the personal information (if any) we or you hold about them.

In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "in force in the state of New South Wales, Australia."

AUSTRIA

LGIM Managers (Europe) Limited ("LGIM Europe") is registered with the Austrian Financial Market Authority ("FMA") to provide cross-border investment services in Austria in accordance with article 34 Directive 2014/65/EU (at the time of notification: Article 31 Directive 2004/39/EC).

Registered Address of LGIM Europe is:

70 Sir John Rogerson’s Quay, Dublin 2, Ireland

LGIM Europe is registered with Companies Registration Office under 609677.

Supervisory Authority: Central Bank of Ireland

VAT Identification Number: IE 3544433VH

You can contact LGIM Europe, as follows:

T: + 44 02031243000

E: webmarketing@lgim.com

The third paragraph ("The contents of this Site...") shall be amended with the following sentence:

Nothing contained herein must be considered as financial analysis nor shall contents of this Site or part of it form the basis of, or be relied on, in connection with any contract or commitment whatsoever.

In the "Disclaimer and Liability" section the last paragraph shall be amended as follows:

Nothing in the Terms and Conditions shall exclude or limit Legal & General's liability for death or personal injury arising from our negligence, for fraud or fraudulent misrepresentation, or blatant gross negligence [krass grobe Fahrlässigkeit] or for any other liability to the extent that such liability cannot be limited and/or excluded by applicable law.

The wording in section "Telephone Recording" shall be read as follows:

"As required under applicable laws, LGIM Europe will record all telephone and electronic communications and conversations with you that result or may result in the execution of transactions in financial instruments on your behalf. LGIM will, however, prior to such recording inform you about it and your data protection rights. Pursuant to art 16 para 7 Directive 2014/65/EU and the applicable laws of England and Wales (implementing Directive 2014/65/EU) such records will be kept for a period of five years (or up to seven years upon request from the Financial Conduct authority (or such successor from time to time)) and will be provided to you upon request.

In the "Law and Jurisdiction" section, the words "in applicable jurisdiction" shall be deleted and replaced with "substantive Austrian law under the exclusion of its conflict of laws rules and the United Nations Convention on Contracts for the International Sale of Goods".

BAHRAIN

This Site and any material or information published thereon has not been approved by the Central Bank of Bahrain which takes no responsibility for its contents. No offer to the public to purchase any financial products or services will be made in the Kingdom of Bahrain and this Site must not be made accessible to or shown to the public generally in Bahrain. The content provided on this Site is for information purposes only. None of the information, opinion, reports, or other documents contained or made available on this Site shall be construed as an offer, invitation, solicitation, advice or a recommendation for subscription or purchase by Legal & General to acquire or sell any products or services.

The "Telephone Recording" paragraph shall be deleted and replaced with "Legal & General will record all telephone and electronic communications and conversations with you that result or may result in the undertaking of transactions in financial instruments on your behalf. Such records will be kept for a period of five years (or such other period as is required by a relevant regulator or applicable law) and will be provided to you upon request."

We are not licensed or authorised to carry on any regulated activity in the Kingdom of Bahrain.

If you do not understand the contents of this Site, you should consult an authorised financial advisor.

In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "of England and Wales."

BELGIUM

LGIM Managers (Europe) Limited has passported its MiFID top up permissions to Belgium on the basis of free provision of services with the Belgian Financial Services and Markets Authority (the “FSMA”). In particular, it is allowed to provide the following services and activities on a cross border basis in Belgium:

  • reception and transmission of orders in relation to one or more financial instruments;
  • portfolio management; and
  • investment advice.

In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "of Belgium."

BRUNEI

The Site and its contents are not directed at any person that is resident in Brunei Darussalam (“Brunei Person”), and no offer is made to any Brunei Person to provide or acquire or sell any investment business service, product or security.

The provision of any information in this Site is for general information only and it does not constitute a recommendation, an offer or invitation to offer to Brunei Person to invest or purchase securities.

CHINA

In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall in each case be deleted and

replaced with "of England and Wales."

By providing personal information in the course of your use of the Site, you expressly consent to the transfer of that information overseas in accordance with the terms of the Privacy Policy.

DENMARK

LGIM Managers (Europe) Limited is registered with the Danish Financial Supervisory Authority to provide cross-border investments services in Denmark in accordance with Article 31 in MiFID-Directive and Danish legislation. In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "of Denmark”.

DUBAI INTERNATIONAL FINANCIAL CENTRE, UNITED ARAB EMIRATES

The content provided on this Site is for information purposes only. None of the information, opinion, reports, or other documents contained or made available on this Site shall be construed as an offer, invitation, solicitation, advice or a recommendation for subscription or purchase by Legal & General to acquire or sell any products or services.

Neither the Dubai International Financial Centre Authority (“DIFCA”) nor the DFSA has any responsibility for reviewing or verifying this Site or information published thereon. Accordingly, neither the DIFCA nor the DFSA has approved this Site or taken any steps to verify the information set out on this Site and has no responsibility for it.The "Telephone Recording" paragraph shall be deleted and replaced with "Legal & General will record all telephone and electronic communications and conversations with you that result or may result in the undertaking of transactions in financial instruments on your behalf. Such records will be kept for a period of five years (or such other period as is required by a relevant regulator or applicable law) and will be provided to you upon request."

We are not licensed or authorised to carry on any regulated activity (as defined by the DFSA) in the Dubai International Financial Centre.

If you do not understand the contents of this Site, you should consult an authorised financial advisor.

In the "Law and Jurisdiction" section, the words "applicable jurisdiction" shall be deleted and replaced with "Dubai International Financial Centre."

EGYPT

This Site is intended for the use of qualified investors only. It is not intended for use by individuals.

The content provided on this Site is for information purposes only. None of the information, opinion, reports, prospectus or other documents contained or made available on this Site shall be construed as an offer, invitation, solicitation, advice or a recommendation for subscription or purchase by Legal & General to acquire or sell any products or securities referred to in this Site.

The "Telephone Recording" paragraph shall be deleted and replaced with "Legal & General will record all telephone and electronic communications and conversations with you that result or may result in the undertaking of transactions in financial instruments on your behalf. Such records will be kept for a period of five years (or such other period as is required by a relevant regulator or applicable law) and will be provided to you upon request."

We are not licensed or authorised to carry on any regulated activity in the Arab Republic of Egypt.

In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "of England and Wales."

FINLAND

In the "Information About Us" section, the following shall be inserted at the end of such section:

"Of the entities listed above as being authorised and regulated by the Financial Conduct Authority, the Prudential Regulation Authority and/or the Central Bank of Ireland, the following have been notified to the Finnish Financial Supervisory Authority and may provide services into Finland:

  • Legal & General Investment Management Limited

Of the entities listed above as being authorised and regulated by the Financial Conduct Authority, the following have not been notified to the Finnish Financial Supervisory Authority and do not offer services into Finland:

  • LGIM Managers (Europe) Limited
  • Legal and General Assurance (Pensions Management) Limited

In the "Using and Sharing Our Content" section, the following shall be inserted at the end of such section: "This provision does not affect your statutory rights."

In the "Privacy and Cookies" section, the following shall be inserted at the end of such section: "You have the right to withdraw your consent at any time, but you may thereafter not make any further use of the Site."

In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "of England and Wales".

FRANCE

All copyright in the indices values and constituents lists which may be published on the Site, from time to time, may belong to a third party licensor including, without limitation, FTSE International Limited ("FTSE"). Legal & General has obtained full license from the relevant licensor to use such copyright in the creation of the contents of the Site.

The FTSE indices used within the Site are calculated by FTSE. FTSE does not sponsor, endorse or promote any Legal & General funds.

"FTSE®", "FT-SE®"; and "Footsie®" are trade marks of the London Stock Exchange Plc and The Financial Times Limited and are used by FTSE under license. "All-Share®", "All-World®" and "FTSE4Good®" are the trade marks of FTSE.

In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "of France".

In the "Information About Us" section the following shall be inserted; LGIM Managers (Europe) Limited ("LGIM Europe") authorised by the Central Bank of Ireland as a UCITS management company (pursuant to European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations, 2011 (S.I. No. 352 of 2011), as amended) and as an alternative investment fund manager with “top up” permissions which enable the firm to carry out certain additional MiFID investment services (pursuant to the European Union (Alternative Investment Fund Managers) Regulations 2013 (S.I. No. 257 of 2013), as amended). Registered in Ireland as a private company limited by shares with the Companies Registration Office (No. 609677). Registered Office: 70 Sir John Rogerson’s Quay, Dublin, 2, Ireland. Regulated by the Central Bank of Ireland (No. C173733) VAT number: IE 3544433VH.

The publication manager is Paul Sweeney, General Counsel. Please direct any queries to: One Coleman Street, London, EC2R 5AA or IB Distribution email.

LGIM Europe is authorized to carry out business in France under a cross-border services passport into France."

In the section "Linking and Posting Material to our Site" the following words shall be inserted; "You shall hold us harmless from any and all claims, injuries, damages, losses or suits including attorney fees, arising out of or in connection with any link and material that you post to this Site."

GERMANY

In the "Information About Us" section, the following wording is inserted;

The Site is operated by LGIM Europe. LGIM Managers (Europe) Limited, authorised by the Central Bank of Ireland as a UCITS management company (pursuant to European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations, 2011 (S.I. No. 352 of 2011), as amended) and as an alternative investment fund manager with “top up” permissions which enable the firm to carry out certain additional MiFID investment services (pursuant to the European Union (Alternative Investment Fund Managers) Regulations 2013 (S.I. No. 257 of 2013), as amended). Registered in Ireland as a private company limited by shares with the Companies Registration Office (No. 609677). Registered Office: 70 Sir John Rogerson’s Quay, Dublin, 2, Ireland. Regulated by the Central Bank of Ireland, N Wall Quay, North Dock, Dublin, D01 F7X3, Ireland (No. C173733). VAT number: IE 3544433VH.

In Germany, the branch office of LGIM Managers (Europe) Limited is at Office 405. Senckenberganlage 10-12, D-60325 Frankfurt am Main, Germany and is subject to limited supervision by the German Federal Financial Supervisory Authority (“BaFin”).

LGIM Europe is represented by: Notices for the attention of: LGIM General Counsel, LGIM Legal, One Coleman Street, London, EC2R 5AA

You can contact LGIM, as follows: Email Web Marketing or + 44 02031243000.
LGIM's monitoring authority is: Central Bank of Ireland

The person responsible for editorial content (sec. 55 (2) rstv) is: LGIM Marketing, One Coleman Street, London, EC2R 5AA, IB Distribution email

In the "Disclaimer and Liability" section the following wording is inserted; "LGIM shall also be liable for any damage in the case of a culpable violation of a material contractual duty or cardinal duty; however, in the event of a violation of a material contractual duty or cardinal duty based on simple negligence, the liability of LGIM shall be limited to the typically foreseeable damage. A “cardinal duty” in the sense of this provision shall be a duty of LGIM whose fulfilment enables the proper performance of the agreement, whose infringement jeopardizes achieving the purpose of the agreement and in whose compliance you may normally trust. Any further-reaching liability on part of LGIM shall be excluded."

In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "German law".

HONG KONG

References to "Legal & General", "We" or "Us" in the Terms and Conditions shall also include Legal & General Investment Management Asia Limited (“LGIM Asia Ltd”), a Licensed Corporation (CE Number: BBB488) regulated by the Hong Kong Securities and Futures Commission ("SFC") to conduct regulated activities of dealing in securities and asset management in Hong Kong. The registered address of LGIM Asia Ltd is Room 902, 9/F, Chinachem Tower, 34-37 Connaught Road, Central, Hong Kong.

The Site has not been reviewed by the SFC By accepting using the Site, you acknowledge and agree that the Site is provided for your use only and that you will not distribute or otherwise make this material available (except as specified in the Terms and Conditions).

In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "of the Hong Kong Special Administrative Region of the People's Republic of China."

In our Privacy Policy, under the "Information we collect" section, the following additional terms apply: We intend to use your personal data in direct marketing and may not do so without your consent.

Any promotional emails that we may periodically send about new products, special offers or other information that we think you may find interesting shall relate to the investment products and/or services offered by Legal & General.

Your personal data may be transferred outside of Hong Kong and/or to a Legal & General group company for the reasons set out in this section.

INDONESIA

You represent and warrant that you are entitled to enter into a binding agreement under the laws of the Republic of Indonesia, in particular to the Terms and Conditions, and that you are at least 21 years old or are married and not under guardianship.

Please be informed that Otoritas Jasa Keuangan (the Indonesian Financial Service Authority) or Bank Indonesia does not declare its approval or disapproval of our services and products offered nor do they guarantee the accuracy or adequacy of its services and products, nor do they supervise the use of our products. Therefore your use of our Site will be purely contractual relationship with us as set out in these Terms and Conditions.

This Site or other related documents and information shall not be considered as an offer to our services and products in investment sector; consequently such documents and information shall not be considered an offer.

Some of the information on this Site may contain projections or other forward-looking statements regarding future events or future financial performance of countries, markets or companies. These statements are only predictions and actual events or results may differ materially. You must make your own assessment of the relevance, accuracy and adequacy of the information contained in this Site and to make such independent investigations as you may consider necessary or appropriate for the purpose of such assessment. Any opinion or estimate contained in this Site is made on a general basis and is not to be relied on by you as advice.

The collection and use of personal data under these Terms and Conditions have been in compliance with the collection and use of personal data under the prevailing laws and regulations in Indonesia.

For the use in Indonesia, these Terms and Conditions are drawn up in both the English and the Indonesian languages, both of which versions are binding on you and us. In the event of any inconsistency between the Indonesian language version and the English language version, to the extent permitted by the prevailing laws and regulations, the English language version will prevail.

IRELAND

LGIM Managers (Europe) Limited is authorised by the Central Bank of Ireland as a UCITS management company (pursuant to European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations, 2011 (S.I. No. 352 of 2011), as amended) and as an alternative investment fund manager with “top up” permissions which enable the firm to carry out certain additional MiFID investment services (pursuant to the European Union (Alternative Investment Fund Managers) Regulations 2013 (S.I. No. 257 of 2013), as amended). Registered in Ireland with the Companies Registration Office (No. 609677). Registered Office: 70 Sir John Rogerson’s Quay, Dublin, 2, Ireland. Regulated by the Central Bank of Ireland (No. C173733).

LGIM Managers (Europe) Limited operates a branch network in the European Economic Area, which is subject to supervision by the Central Bank of Ireland. In Italy, the branch office of LGIM Managers (Europe) Limited is subject to limited supervision by the Commissione Nazionale per le società e la Borsa (“CONSOB”) and is registered with Banca d’Italia (no. 23978.0) with registered office at Piazza della Repubblica 3, Milano 20121, (Companies’ Register no. MI - 2557936). In Germany, the branch office of LGIM Managers (Europe) Limited is subject to limited supervision by the German Federal Financial Supervisory Authority (“BaFin”). In the Netherlands, the branch office of LGIM Managers (Europe) Limited is subject to limited supervision by the Dutch Authority for the Financial Markets (“AFM“) and it is included in the register held by the AFM and registered with the trade register of the Chamber of Commerce under number 74481231.

Details about the extent of our authorisation and regulation are available from us upon request. The company can be verified by visiting the Central Bank of Ireland’s website www.centralbank.ie

ITALY

In the section “Information about us” the definition of “Legal & General” shall include: “LGIM Managers (Europe) Limited, a company incorporated in Ireland (Registered no. 609677) and authorised by the Central Bank of Ireland as a management company pursuant to Directive 2009/65/EC and as an alternative investment fund manager pursuant to Directive 2011/61/EU (Central Bank of Ireland Register no. C173733), as well as its Italian branch, which is situated at Piazza della Repubblica 3, Milano 20121 and is enrolled in the Registry of EU Management Companies and Alternative Investment Funds Managers held by the Bank of Italy pursuant to art. 35 of Legislative Decree no. 58/1998 under no. 23978”.

In the Section “Intended Audience and Use of Information”, the first paragraph shall read as follows: “This Site is intended for the use of both professional and retail clients.”

In addition, the term “professional clients” shall be intended to be referred to Italian resident or domiciled legal entities falling within the definition of “clienti professionali o investitori professionali” set out under Legislative Decree no. 58/1998, as implemented by the Consob Issuers Regulation no. 11971/1999 and the Consob Intermediaries Regulation no. 20307/2018. The term “retail clients” shall be intended to be referred to Italian resident falling within the definition of “clienti al dettaglio o investitori al dettaglio” set out under Legislative Decree no. 58/1998 as amended and implemented by Consob Intermediaries Regulation no.20307/2018 and Consob Intermediaries Regulation no. 20307/2018.

In the “Professional Investment Adviser and Investment Risk” section, the first paragraph shall read as follows: “You should consult a professional adviser on your particular financial circumstances before taking, or refraining from taking, any action on the basis of the content of our Site, and you should not rely on the material on this Site. The funds, services and financial instruments mentioned on this Site are not suitable for all investors. Before making an investment, you should read the appropriate fund prospectus (if applicable) and any other offering documents (e.g. fact sheets, KIID, periodical financial reports, management rules or articles association, annual and half-yearly reports etc.) or other terms and conditions as may be appropriate and raise any questions you have on this documentation with your professional adviser. The content of this document does not constitute an offer or a solicitation of an offer for the subscription of any funds.”

In “Disclaimer and Liability” the following paragraph is added: “The information, opinions, data, and documents contained or described in this Site are solely for information purposes and should not be understood as a substitute of the offering document of the fund or the document relating to the services. Therefore, the information provided on this Site does not constitute a legal, tax or financial opinion, a public offer, a personalized recommendation, or an invitation to purchase or sell financial instruments or to carry out a transaction or undertake a legal commitment. Some of the information and documents available on this Site may be classified as “marketing communication” pursuant to Regulation (EU) 2019/1156.”

The “Law and Jurisdiction” section shall read as follows: “The Terms and Conditions and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of Italy”.

The parties irrevocably agree that the courts in Italy shall have exclusive jurisdiction to settle any dispute or claim that arises out of or in connection with the Terms and Conditions or their subject matter or formation (including non-contractual disputes or claims).

JAPAN

The Site and its contents are not directed at any person that is resident in Japan ("Japanese person"), and no offer or invitation is made to any Japanese person to acquire or sell any service, product or security referred to. The provision of any information in this Site does not constitute an offer to Japanese persons to purchase securities.

In the "Intellectual Property" section the following shall be inserted; "If you post material to the Site, we are deemed to be authorised to use such material on the Site."

In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "of England and Wales."

JORDAN

The content provided on this Site is for information purposes only. None of the information, opinion, reports, prospectus or other documents contained or made available on this Site shall be construed as an offer, invitation, solicitation, advice or a recommendation for subscription or purchase by Legal & General to acquire or sell any products or securities referred to in this Site.

The "Telephone Recording" paragraph shall be deleted and replaced with "Legal & General will record all telephone and electronic communications and conversations with you that result or may result in the undertaking of transactions in financial instruments on your behalf. Such records will be kept for a period of five years (or such other period as is required by a relevant regulator or applicable law) and will be provided to you upon request."

We are not licensed or authorised to carry on any regulated activity in the Hashemite Kingdom of Jordan.

In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "of England and Wales."

KINGDOM OF SAUDI ARABIA

This Site is intended for use only by such persons as are permitted under the Investment Fund Regulations issued by the Saudi Capital Market Authority (“CMA”). It is not intended for use by individuals.

The CMA does not make any representation as to the accuracy or completeness of this Site, and expressly disclaims any liability whatsoever for any loss arising from, or incurred in reliance upon, any part of this Site. Users of the Site should conduct their own due diligence on the accuracy of the information contained on the Site. If you do not understand the contents of this Site you should consult an authorised financial adviser.

Interests in investment funds may only be offered and sold in the Kingdom of Saudi Arabia in accordance with Article 94 of the Investment Funds Regulations issued on December 24, 2006 (the “Regulations”). Article 94(a) of the Regulations states that, if investment fund units are offered to sophisticated investors, as specified in article 74(b) of the regulations, or the minimum amount payable per offeree is not less than Saudi Riyals 1 million or an equivalent amount in another currency, such offer of investment fund units shall be deemed a private placement for the purposes of the Regulations. Investors are informed that article 101 of the Regulations places restrictions on secondary market activity with respect to such investment fund units.

By accessing the Site, the user acknowledges and agrees that this Site has not been approved by the Capital Market Authority or any other authority in the Kingdom of Saudi Arabia, nor has Legal & General or our affiliates received authorisation from, or been licensed by, the Capital Market Authority or any other authority in the Kingdom of Saudi Arabia.

The content provided on this Site is for information purposes only. None of the information, opinion, reports, or other documents contained or made available on this Site shall be construed as an offer, invitation, solicitation, advice or a recommendation for subscription or purchase by Legal & General to acquire or sell any products or services.

The "Telephone Recording" paragraph shall be deleted and replaced with "Legal & General will record all telephone and electronic communications and conversations with you that result or may result in the undertaking of transactions in financial instruments on your behalf. Such records will be kept for a period of five years (or such other period as is required by a relevant regulator or applicable law) and will be provided to you upon request."

In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "of England and Wales."

KUWAIT

This Site should not be made available to the general public in Kuwait. It is not intended for use by individuals.

We have not licensed any of our products or services for offering in Kuwait by the Kuwait Capital Markets Authority or any other relevant Kuwaiti government agency. The offering of interests in investment funds in Kuwait on the basis of a private placement or public offering is, therefore, restricted in accordance with Decree Law No. 31 of 1990 and the implementing regulations thereto (as amended) and Law No. 7 of 2010 and the bylaws thereto (as amended).

No private or public offering of financial products or services is being made in Kuwait, and no agreement relating to the sale of financial products or services will be concluded in Kuwait. No marketing or solicitation or inducement activities are being used to offer or market financial products or financial services in Kuwait.

The content provided on this Site is for information purposes only. None of the information, opinion, reports, or other documents contained or made available on this Site shall be construed as an offer, invitation, solicitation, advice or a recommendation for subscription or purchase by Legal & General to acquire or sell any products or services.

The "Telephone Recording" paragraph shall be deleted and replaced with "Legal & General will record all telephone and electronic communications and conversations with you that result or may result in the undertaking of transactions in financial instruments on your behalf. Such records will be kept for a period of five years (or such other period as is required by a relevant regulator or applicable law) and will be provided to you upon request."

We are not licensed or authorised to carry on any regulated activity in the State of Kuwait.

If you do not understand the contents of this Site, you should consult an authorised financial advisor.

In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "of England and Wales."

LEBANON

The content provided on this Site is for information purposes only. None of the information, opinion, reports, prospectus or other documents contained or made available on this Site shall be construed as an offer, invitation, solicitation, advice or a recommendation for subscription or purchase by Legal & General to acquire or sell any products or securities referred to in this Site.

The "Telephone Recording" paragraph shall be deleted and replaced with "Legal & General will record all telephone and electronic communications and conversations with you that result or may result in the undertaking of transactions in financial instruments on your behalf. Such records will be kept for a period of five years (or such other period as is required by a relevant regulator or applicable law) and will be provided to you upon request."

We are not licensed or authorised to carry on any regulated activity in the Lebanese Republic.

In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "of England and Wales."

LIECHTENSTEIN

The content of the Site is provided for information purposes only and contains advertising. It does not constitute an offer, solicitation or a recommendation to buy or sell securities or financial instruments, nor shall it constitute the basis of any contract, commitment or decision of any kind nor is it to be construed as a prospectus or offering document. It is not intended to be a substitute for the full documentation of the relevant collective investment scheme. The content of the Site does not constitute any personalised assessment or investment recommendation, nor shall any information contained herein be construed as financial, tax or legal advice of any kind.

You should only subscribe to shares in a collective investment scheme after reading the relevant fund documentation such as the fund agreement/articles, the latest prospectus, the basic information sheet and the financial reports (e.g., the latest audited annual report and if need be the subsequent unaudited semi-annual report as well as additional relevant documentation).

In the "Information About Us" section, the following wording is inserted;

The Site is operated by LGIM Europe. LGIM Managers (Europe) Limited, authorised by the Central Bank of Ireland as a UCITS management company (pursuant to European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations, 2011 (S.I. No. 352 of 2011), as amended) and as an alternative investment fund manager with “top up” permissions which enable the firm to carry out certain additional MiFID investment services (pursuant to the European Union (Alternative Investment Fund Managers) Regulations 2013 (S.I. No. 257 of 2013), as amended). Registered in Ireland as a private company limited by shares with the Companies Registration Office (No. 609677). Registered Office: 70 Sir John Rogerson’s Quay, Dublin, 2, Ireland. Regulated by the Central Bank of Ireland, N Wall Quay, North Dock, Dublin, D01 F7X3, Ireland (No. C173733). VAT number: IE 3544433VH.

The registered address of LGIM Europe is:

70 Sir John Rogerson’s Quay, Dublin 2, Ireland

LGIM Europe is registered with Companies Registration Office under 609677.

Supervisory Authority: Central Bank of Ireland

VAT Identification Number: IE 3544433VH

You can contact LGIM Europe, as follows:

T: + 44 02031243000

E: webmarketing@lgim.com

Legal & General Investment Management Limited has passported the provision of crossborder services in line with MiFID II to the Liechtenstein Financial Markets Authority (FMA) on the basis of free provision of services. In particular, it is allowed to provide the following services and activities on a cross border basis in Liechtenstein:

  • reception and transmission of orders in relation to one or more financial instruments;
  • portfolio management; and

 

LUXEMBOURG

In the "Law and Jurisdiction" section, the words “the laws in the applicable jurisdiction” shall be construed as meaning

the Laws of Luxembourg.

MACAU

LGIM and the companies listed in the Section “Information About Us” are not authorized by the Macau Monetary Authority to act as financial institutions and/or provide financial services pursuant to the provisions of Decree-Law No. 32/93/M in the Macau Special Administrative Region of the People’s Republic of China.

MALAYSIA

None of the information, opinion, reports, prospectus or other documents contained or made available on this Site shall be construed as an offer for subscription or purchase, or an invitation to subscribe for or purchase, or a recommendation or solicitation by Legal & General to acquire or sell any products or securities referred to in this Site.

By accepting the Terms and Conditions or otherwise using this Site, you confirm and represent to us that you are a person who comes within one of the categories of persons set out in Part 1 Schedule 6 and 7 of the Capital Markets and Services Act 2007 of Malaysia, as amended from time to time (“CMSA”).

We are not licensed or authorised to carry on any regulated activity (as defined in the CMSA) in Malaysia and none of the information or documents contained or made available on this Site shall be construed as advice of any kind (including financial, investment, tax or legal).

NETHERLANDS

LGIM Managers (Europe) Limited is authorised by the Central Bank of Ireland as a UCITS management company (pursuant to European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations, 2011 (S.I. No. 352 of 2011), as amended) and as an alternative investment fund manager with “top up” permissions which enable the firm to carry out certain additional MiFID investment services (pursuant to the European Union (Alternative Investment Fund Managers) Regulations 2013 (S.I. No. 257 of 2013), as amended). Registered in Ireland with the Companies Registration Office (No. 609677). Registered Office: 70 Sir John Rogerson’s Quay, Dublin, 2, Ireland. Regulated by the Central Bank of Ireland (No. C173733).

In the Netherlands, the branch office of LGIM Managers (Europe) Limited is located at 4th floor, Barbara Strozzilaan 101, 1083 HN Amsterdam and is subject to limited supervision by the Dutch Authority for the Financial Markets (“AFM“) and it is included in the register held by the AFM and registered with the trade register of the Chamber of Commerce under number 74481231.In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "of England and Wales."

NEW ZEALAND

No use by you of the Site shall activate the provisions of any consumer protection laws of New Zealand, including, without limitation, the Consumer Guarantees Act 1993; the Fair Trading Act 1986; and the Credit Contracts and Consumer Finance Act 2003, the operation of which you agree shall hereby be excluded to the fullest extent permitted by law.”

In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "of England and Wales."

The provision of any information in this Site does not constitute an offer of or invitation to subscribe for any financial products to any person in New Zealand, nor does it constitute a ‘regulated offer’ to retail investors within the meaning of the FMCA. The Site is intended for use by persons who are 'wholesale investors' within the meaning of the FMCA only. ‘Wholesale investors’ include:

  • any persons who are required to pay a minimum upfront subscription amount of at least NZ$750,000 each on acceptance of any offer of financial products made to those persons and before the allotment of those financial products; or
  • any persons who are otherwise categorised as 'wholesale investors’ pursuant to the FMCA.

If you are not a ‘wholesale investor’ you shall immediately cease any access to or use of the Site and any services and/or products on the Site.

NORWAY

LGIM Managers (Europe) Limited is registered with the Norwegian Financial Supervisory Authority to provide cross-

border investments services in Norway in accordance with Article 31 in MiFID-Directive and Norwegian legislation.

In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "of Norway”.

OMAN

The information contained on this Site neither constitutes a public offer of securities in the Sultanate of Oman as contemplated by the Law of Commercial Companies (Royal Decree 18/2019) or the Capital Market Law of Oman (Royal Decree 80/98), nor does it constitute an offer to sell, or the solicitation of any offer to buy Non-Omani securities in the Sultanate of Oman as contemplated by Article 139 of the Executive Regulations to the Capital Market Law (issued by Decision No.1/2009). Additionally, this Site is not intended to lead to the conclusion of any contract of whatsoever nature within the territory of the Sultanate of Oman.

Financial products may not be advertised, marketed, distributed or otherwise made available to any person in Oman other than by an entity licensed to market non-Omani securities by the Capital Markets Authority (“CMA”) and then only in accordance with any terms and conditions of such license. No prospectus has been filed with the CMA by us in connection with any of our products. This Site is not intended to lead to any offer or sale of financial products or services of whatsoever nature within the territory of the Sultanate of Oman.

This Site is only being made accessible to a limited number of financially solvent and experienced investors, and may not be reproduced, used for any other purpose or provided to any other person that is not the intended recipient thereof. Users of the Site acknowledge that none of our financial products or services have been licensed by or registered with the CMA.

The content provided on this Site is for information purposes only. None of the information, opinion, reports, or other documents contained or made available on this Site shall be construed as an offer, invitation, solicitation, advice or a recommendation for subscription or purchase by Legal & General to acquire or sell any products or services. Legal & General does not advise persons or entities resident or based in Oman as to the appropriateness of investing in or purchasing or selling securities or other financial products. No information contained on this Site is intended to constitute Omani investment, legal, tax, accounting or other professional advice.

The "Telephone Recording" paragraph shall be deleted and replaced with "Legal & General will record all telephone and electronic communications and conversations with you that result or may result in the undertaking of transactions in financial instruments on your behalf. Such records will be kept for a period of five years (or such other period as is required by a relevant regulator or applicable law) and will be provided to you upon request."

We are not licensed or authorised to carry on any regulated activity in the Sultanate of Oman.

If you do not understand the contents of this Site, you should consult an authorised financial advisor.

In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "of England and Wales."

PALESTINE

The content provided on this Site is for information purposes only. None of the information, opinion, reports, prospectus or other documents contained or made available on this Site shall be construed as an offer, invitation, solicitation, advice or a recommendation for subscription or purchase by Legal & General to acquire or sell any products or securities referred to in this Site.

The "Telephone Recording" paragraph shall be deleted and replaced with "Legal & General will record all telephone and electronic communications and conversations with you that result or may result in the undertaking of transactions in financial instruments on your behalf. Such records will be kept for a period of five years (or such other period as is required by a relevant regulator or applicable law) and will be provided to you upon request."

We are not licensed or authorised to carry on any regulated activity in the State of Palestine.

In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "of England and Wales."

QATAR FINANCIAL CENTRE, QATAR

Nothing on this Site constitutes, is intended to constitute, shall be treated as constituting or shall be deemed to constitute any offer or sale of financial products or services in the State of Qatar or in the Qatar Financial Centre, or the inward marketing of any financial products or an attempt to do business, as a bank, an investment company or otherwise in the State of Qatar or in the Qatar Financial Centre.

This Site and the content thereon have not been approved, registered or licensed by the Qatar Central Bank, the Qatar Financial Centre Regulatory Authority, the Qatar Financial Markets Authority or any other regulator in the State of Qatar or in the Qatar Financial Centre.

Neither this Site nor any information or documents made available through it have been reviewed or approved by the Qatar Financial Centre Regulatory Authority or the Qatar Central Bank.

No transaction will be concluded within the jurisdiction of the State of Qatar or in the Qatar Financial Centre. Recourse against us may be limited or difficult and may have to be pursued in a jurisdiction outside the State of Qatar or the Qatar Financial Centre.

Any distribution of the content of this Site by the recipient to third parties in the State of Qatar or in the Qatar Financial Centre is in breach of the terms hereof is not authorised and shall be at the liability of such recipient.

The content provided on this Site is for information purposes only. None of the information, opinion, reports, or other documents contained or made available on this Site shall be construed as an offer, invitation, solicitation, advice or a recommendation for subscription or purchase by Legal & General to acquire or sell any products or services.

The "Telephone Recording" paragraph shall be deleted and replaced with "Legal & General will record all telephone and electronic communications and conversations with you that result or may result in the undertaking of transactions in financial instruments on your behalf. Such records will be kept for a period of five years (or such other period as is required by a relevant regulator or applicable law) and will be provided to you upon request."

We are not licensed or authorised to carry on any regulated activity in the State of Qatar or in the Qatar Financial Centre.

If you do not understand the contents of this Site, you should consult an authorised financial advisor.

In the "Law and Jurisdiction" section, in the first paragraph the words "applicable jurisdiction" shall be deleted and replaced with "Qatar Financial Centre". In the second paragraph the words "courts in the applicable jurisdiction" shall be deleted and replaced with "Civil and Commercial Court of the Qatar Financial Centre".

SINGAPORE

In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "of the

Republic of Singapore."

SPAIN

LGIM Managers (Europe) Limited is registered with the Spanish Comisión Nacional del Mercado de Valores (Register number 579) as an investment firm of the European Economic Area under the freedom to provide services regime, to provide certain investment services.

In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "of Spain."

The “Telephone Recording” paragraph shall be deleted and replaced with the following paragraph: “As required under applicable laws, Legal & General will record all telephone and electronic communications and conversations with you that result or may result in the undertaking of transactions in financial instruments on your behalf. Such records will be kept for a period of five years (or such other period as is required by a relevant regulator or applicable law) and will be provided to you upon request.

STATE OF QATAR (EXCLUDING THE QATAR FINANCIAL CENTRE)

Access to this Site is intended for the use of professional and qualified investors only. It is not intended for use by individuals.

Nothing on this Site constitutes, is intended to constitute, shall be treated as constituting or shall be deemed to constitute any offer or sale of financial products or services in the State of Qatar, or the inward marketing of any financial products or an attempt to do business, as a bank, an investment company or otherwise in the State of Qatar.

This Site and the content thereon have not been approved, registered or licensed by the Qatar Central Bank, the Qatar Financial Centre Regulatory Authority, the Qatar Financial Markets Authority or any other regulator in the State of Qatar.

Neither this Site nor any information or documents made available through it have been reviewed or approved by the Qatar Financial Centre Regulatory Authority or the Qatar Central Bank.

No transaction will be concluded within the jurisdiction of the State of Qatar. Recourse against us may be limited or difficult and may have to be pursued in a jurisdiction outside the State of Qatar.

Any distribution of the content of this Site by the recipient to third parties in the State of Qatar is in breach of the terms hereof is not authorised and shall be at the liability of such recipient.

The content provided on this Site is for information purposes only. None of the information, opinion, reports, or other documents contained or made available on this Site shall be construed as an offer, invitation, solicitation, advice or a recommendation for subscription or purchase by Legal & General to acquire or sell any products or services.

The "Telephone Recording" paragraph shall be deleted and replaced with "Legal & General will record all telephone and electronic communications and conversations with you that result or may result in the undertaking of transactions in financial instruments on your behalf. Such records will be kept for a period of five years (or such other period as is required by a relevant regulator or applicable law) and will be provided to you upon request."

We are not licensed or authorised to carry on any regulated activity in the State of Qatar.

If you do not understand the contents of this Site, you should consult an authorised financial advisor.

In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "of England and Wales."

SWEDEN

LGIM Managers (Europe) Limited is registered with the Swedish Financial Supervisory Authority to provide cross-border investments services in Sweden in accordance with Article 31 in MiFID-Directive and Swedish legislation. We are located at Nybrogatan 6 Business Center AB, 556698-3531 Box 5855, 102 40 Stockholm.

In the "Law and Jurisdiction" section, the words "in the applicable jurisdiction" shall be deleted and replaced with "of Sweden”.

SWITZERLAND

This Site and all information contained herein is aimed exclusively at persons with their place of residence or registered office in Switzerland and who qualify as qualified investors within the meaning of art. 10 para. 3 and 3ter of the Swiss Collective Investment Schemes Act ("CISA"). Retail clients within the meaning of Article 4 para. 2 of the Swiss Financial Services Act ("FinSA") are not permitted to consult, use or access this Site in any manner. Retail clients should contact their institutional financial adviser for more information about our products.

The content of the Site is provided for information purposes only and contains advertising. It does not constitute an offer, solicitation or a recommendation to buy or sell securities or financial instruments, nor shall it constitute the basis of any contract, commitment or decision of any kind nor is it to be construed as a prospectus or offering document. It is not intended to be a substitute for the full documentation of the relevant collective investment scheme. This content does not constitute any personalised assessment or investment recommendations, nor shall any information contained herein be construed as financial, tax or legal advice of any kind.

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Decline
17 Oct 2024
3 min read

LGIM’s voting intentions for 2024

Our voting intentions at upcoming shareholder meetings, including BHP Group, Darden Restaurants, Apple, Nestle, Woodside Energy, North American and Nordic banks, oil & gas companies, Glencore, Amazon, Chevron, Walmart, Restaurant Brands International, Nippon Steel, Target and Hindalco. 

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Voting allows shareholders to appoint the directors that run a company, approve executive pay, agree climate transition strategies, and encourage better reporting on other environmental and social topics, among others. We believe that holding companies and boards to account for their actions through our voting is a fundamental part of being a good steward of our clients’ assets.  

In our view, transparency of our granular voting policies and how we have voted at companies’ annual and special meetings helps us to drive change, as well as hold ourselves and companies accountable. 

Sometimes, we may choose to declare our vote intention ahead of meetings, to clarify our views to the market, clients and other companies to a particular issue, resolution or outcome. The decision to do so can be undertaken as part of an escalation strategy, where we deem the vote to be particularly contentious, or as part of an engagement programme.  

Over 2024, we will be updating this blog on a regular basis to highlight our vote intentions in advance of certain shareholder meetings. For information about our voting actions and rationales, please visit our dedicated website: VDS Dashboard (issgovernance.com)    

More information about our Investment Stewardship activities, policies and engagement activities  can be found on our website: Investment stewardship & governance | LGIM Institutional    

 

BHP Group Ltd*

Meeting: AGM, 30-10-2024

Summary of resolution:  

Resolution 13 – Approve Climate Transition Action Plan

LGIM’s vote intention: 

For resolution 13 (in line with management recommendation)   

Rationale:  

The mining and diversified metals sector produces minerals that are essential to the energy transition. As such, we believe that long-term, responsible investors, such as LGIM, can support these companies as they decarbonise.  Earlier this year, we published our updated assessment framework for mining companies’ climate transition plans.

We note that BHP has made significant strides in carrying out its core role in the transition in a sustainable manner and has demonstrated this through the substantial alignment of its Climate Transition Action Plan (CTAP) with our framework for assessing mining company transition plans. Therefore, LGIM will be supporting BHP’s CTAP. 

Going forwards, we will assess the disclosure of progress on BHP’s plans for the development of a more targeted methane measurement, management and mitigation strategy, as well as the plans it is executing to support the decarbonisation of steelmaking. We will also continue to engage with BHP to ensure resilience whilst navigating the dynamic market for metallurgical coal.

 

Darden Restaurants, Inc.*

Meeting: AGM, 18-09-2024

Summary of resolution:

Resolution 7 – Comply with World Health Organization Guidelines on Antimicrobial Use Throughout Supply Chains

LGIM’s vote intention: 

For resolution 7 (against management recommendation) 

Rationale:

As a universal owner on behalf of our clients, LGIM is committed to addressing health as a global issue that has, and will increasingly have, cross-sector impacts on our clients’ assets. Antimicrobial resistance (‘AMR’) is a sub-theme of our health theme; we believe it has the potential to become the next pandemic and presents a systemic risk to the global economy. The World Health Organization (‘WHO’) estimates that, if no action is taken, global deaths attributable to AMR could rise to 10 million people a year by 2050, and AMR could reduce GDP by $3.4 trillion each year (source: Antimicrobial resistance: a global threat | UNEP - UN Environment Programme).

This resolution asks the company to comply with WHO uidelines on the use of medically important antimicrobials in food-producing animals throughout its supply chains. Our Health Policy states our expectation that restaurant and fast-food companies should require all their meat suppliers to comply with the WHO guidelines. We expect them to be transparent about their AMR strategy, the actions taken to implement it, and steps taken to monitor implementation. We are therefore supporting this resolution.

For more information about the systemic risk of AMR please see our recent blog post on AMR here and for more information on LGIM’s approach to AMR and our minimum expectations of companies, please see our health policy, here.

 

Hindalco Industries*

Meeting: AGM, 22-08-2024

Summary of resolution:

Resolution 5 – Re-elect Kumar Mangalam Birla as Director

LGIM’s vote intention: 

Against resolution 5 (against management recommendation)

Rationale:

The aluminium sector has a significant role to play in the global transition to net zero, and is one of our 20 ‘climate critical’ sectors captured within our Climate Impact Pledge (‘CIP’). Hindalco Industries has been selected for direct, qualitative engagement within this programme.

Our vote against the re-election of Kumar Mangalam Birla is applied in line with our CIP engagement escalation, whereby we vote against the (re-)election of the Chair of the Board at companies lagging our minimum expectations on climate change. This is the second consecutive year we are applying vote sanctions against the company on this basis.

In addition to our CIP dialogue, as part of our increased focus on demand-side sectors of the economy, we have engaged with Hindalco alongside Nordea Asset Management as part of the IIGCC Net Zero Engagement Initiative since 2022. Having signed the IAI’s initiative (‘International Aluminium Institute’) in 2023, Hindalco have committed to disclosing a transition plan by the end of this year, outlining how they intend to meet their decarbonisation commitments. We acknowledge that in their recently disclosed 2023/24 integrated annual report there are some positive steps , for example their double materiality risk assessment that shows greenhouse gas management as their top risk.

However, disclosure of a forward-looking, coherent and quantified transition plan is still absent from the report, therefore falling short of our expectations. We also note they have pushed back  their short term scope 1 and 2 emission intensity reduction target from 2025 to 2027. Despite three engagement meetings and multiple email exchanges, we are still unclear on a) their plans to develop existing disclosure into a coherent transition plan, b) the process, accountability structures and resources in place to develop it over 2024 and c) timings of a planned disclosure.

We had hoped that shareholders would have been given the opportunity to opine on the adequacy of Hindalco’s transition plan at the upcoming AGM. We therefore feel that, given a lack of response to our expectations and questions, a pre-declaration is appropriate. We hope this further raises the profile of the issue and leads to more constructive dialogue with the company.

 

Target Corporation inc.*

Meeting: AGM, 12 June 2024

Summary of resolution:

Resolution 6 – Establish a Company Compensation Policy of Paying a Living Wage

LGIM’s vote intention: 

For resolution 6 (against management recommendation) 

Rationale:

The living wage is captured within LGIM’s focus on income inequality and human rights. The International Labour Organisation (ILO) in conventions 131 and recommendation 135 sets out that minimum wages should be set at a rate that is adequate for the needs of the worker and their family. In March 2023, the ILO set out its own definition of a living wage: “the wage level that is necessary to afford a decent standard of living for workers and their families, taking into account the country circumstances and calculated for the work performed during the normal hours of work”. Ensuring a worker is paid sufficiently to support themselves and their family to a standard of “human dignity” is also set out in Article 23 of the Universal Declaration of Human Rights.

Wages and benefits paid for standard working should meet at least legal or industry minimum wage standards and always be sufficient to meet basic needs of workers and their families and to provide discretionary income. Yet, according to the ILO in 2019, 630 million workers worldwide (or 19% of all workers worldwide) earn less than they need to escape poverty1 and, according to Oxfam, inequality is resulting in a death every four seconds.2

Closing the living wage gap worldwide could generate an additional $4.56 trillion every year through increased productivity and spending, translating to a more than 4% increase in annual GDP.3 As a diversified investor, increases in GDP may have a positive impact on the value of our portfolios.4

LGIM has been engaging with Target on the topic of living wages for several years. In 2023, we launched our income inequality engagement campaign, which targeted 15 of the largest global food retailers asking them to set out their policy on living wages for workers within their own operations and their supply chain. As one of the largest food retailers in the US, Target is part of this campaign.  While the company has improved its minimum wage, which in 2022 was increased to $15, it does not have a policy on the living wage. Furthermore, comparing their minimum wage of $15 per hour with the living wage for a single person in some locations where they have stores, which range from $18.58 per hour (Lawton, Oklahoma) to $29.87 (San Francisco), their current rate is inadequate for a person to enjoy a decent standard of living. To further understand why a living wage is important, please read two blogs that we have written: one on the material impact of income inequality and another on the importance of paying a living wage.    

Together with Shareholder Commons, which filed this resolution on behalf of Legal & General Investment Management America, we are asking Target to set out its policy on paying living wages to their employees. 

Sources

1. flagship.pdf (tacklinginequality.org) and International Labour Organization (ILO), 2020. World Employment and Social Outlook: Trends 2020

2. Inequality kills | Oxfam International

3. Inequality kills | Oxfam International and Tackling inequality: The need and opportunity for business action, BCTI

4. Labor and Inequality Case Study - The Shareholder Commons

 

Nippon Steel Corporation*

Meeting: AGM, 21 June 2024

Summary of resolution:

  • Resolution 2.1 – Elect Director Hashimoto, Eiji
  • Resolution 6 – Amend Articles to Disclose Greenhouse Gas Emission Reduction Targets Aligned with Goals of Paris Agreement
  • Resolution 7 – Amend Articles to Introduce Executive Compensation System Linked to Greenhouse Gas Emission Reduction Target and Disclose How Compensation Policy Contributes to Achievement of the Target
  • Resolution 8 – Amend Articles to Report on Corporate Climate Lobbying

LGIM’s vote intention: 

  • Against Resolution 2.1 (against management recommendation)
  • For Resolution 6 (against management recommendation)
  • For Resolution 7 (against management recommendation)
  • For Resolution 8 (against management recommendation)

Rationale:

Resolution 2.1

As one of the largest steel producers in the world, Nippon Steel Corporation has a key role to play in the energy transition and, on account of its scale and potential to influence other firms in its sector and supply chain, is a company with which we have engaged with over several years as part of our Climate Impact Pledge (CIP) programme.

As active owners, we are committed to engaging collectively and individually with companies around the world to highlight and improve their climate lobbying accountability, and to escalate this where required. Climate-related lobbying disclosures are a red line for every company covered within our CIP, as demonstrated in our net zero sector guides. Unfortunately, for a second consecutive year, Nippon Steel has not produced disclosures that meet our expectations. As a result, we are voting against the election of Mr. Hashimoto, Representative Director, Chairman & CEO, through Resolution 2.1.

Resolution 6

LGIM is clear in its expectations of Climate Transition Plans that companies should disclose credible, 1.5°C aligned short-, medium- and long-term emission reduction targets covering scope 1, 2 and material scope 3 emissions. The current disclosures published by Nippon Steel do not provide us with confidence that these expectations are met. As a result, we are voting for Resolution 6.

Resolution 7

We are also voting for Resolution 7. We expect companies within sectors that can have a significant effect on climate change to link part of their pay to delivering on their climate mitigation goals. This is because we believe that linking GHG reduction targets to executive pay can act as a motivational incentive for the company to execute on its decarbonisation strategy.

Resolution 8

After two years of intensive individual and collaborative engagement, we have co-filed this shareholder proposal on climate-related lobbying disclosures.

We believe ambitious climate policy is essential to meeting the goal of the Paris Agreement. We need a supportive policy environment to ensure that all sectors of the economy can undergo an orderly transition to net zero emissions by 2050.

As noted in the rational for Resolution 2.1, Nippon Steel failed to meet our expectations related to corporate climate-lobbying disclosures in early 2022 when we first we discussed this issue in depth. As a result, we made it the focus of our engagement with them for 2023, and also expanded our engagement to work collaboratively with other investors to increase our influence.

Despite several meetings with the company on an individual and collaborative basis, the disclosures provided so far have not met our expectations. As such, we co-filed and will be voting for Resolution 8.

Readers can learn more about this resolution by visiting our blog.

More information on all three resolutions can be found here (in English) and here (in Japanese).

 

Restaurant Brands International Inc.*

Meeting: AGM, 6 June 2024

Summary of resolution:

Resolution 7 – Comply with World Health Organization Guidelines on Antimicrobial Use Throughout Supply Chains

LGIM’s vote intention:  For resolution 7 (against management recommendation) 

Rationale:

Antimicrobial resistance (‘AMR’) is a key area of focus within LGIM’s approach to health, and we consider AMR to be a systemic risk.

Resolution 7 asks the company to comply with WHO guidelines on the use of medically important antimicrobials in food-producing animals throughout companies’ supply chains. Our Health Policy states our expectation that companies within the restaurant/out-of-home sector (e.g. fast-food companies) should require all their meat suppliers to comply with the WHO guidelines. We expect them to be transparent about their AMR strategy, the actions taken to implement it, and steps taken to monitor implementation. We are therefore supporting this resolution.

For more information about the systemic risk of AMR, please see our recent blog post on AMR. For more information on LGIM’s minimum expectations, please see our Health Policy.

More information on our Investment Stewardship activities can be found on our website.

 

Walmart inc.*

Meeting: AGM, 5 June 2024

Summary of resolution:

Resolution 7 – Establish a Company Compensation Policy of Paying a Living Wage

LGIM’s vote intention: For resolution 7 (against management recommendation) 

Rationale:

The living wage is captured within LGIM’s focus on income inequality and human rights.  The International Labour Organisation (ILO) in conventions 131 and recommendation 135 sets out that minimum wages should be set at a rate that is adequate for the needs of the worker and their family. In March 2023, the ILO provided its own definition of a living wage: “The wage level that is necessary to afford a decent standard of living for workers and their families, taking into account the country circumstances and calculated for the work performed during the normal hours of work”. Ensuring a worker is paid sufficiently to support themselves and their family to a standard of “human dignity” is also set out in Article 23 of the Universal Declaration of Human Rights.

Wages and benefits paid for standard working should meet at least legal or industry minimum wage standards and always be sufficient to meet the basic needs of workers and their families and to provide discretionary income. Yet, according to the ILO in 2019, 630 million workers worldwide (or 19% of all workers worldwide) earn less than they need to escape poverty1 and, according to Oxfam, inequality is resulting in a death every four seconds.2

Closing the living wage gap worldwide could generate an additional $4.56 trillion every year through increased productivity and spending, translating to a more than 4 percent increase in annual GDP.3 As a diversified investor, increases in GDP may have a positive impact on the value of our portfolios.4

LGIM has been engaging with Walmart on the topic of living wages for several years, and in 2023 we launched our income inequality engagement campaign which targeted 15 of the largest global food retailers asking them to set out their policy on living wages for workers within their own operations and their supply chain. Walmart, as the largest food retailer in the world, is part of this campaign. While the company has improved on some areas of our requests in terms of training opportunities, the company does not have a policy on the living wage, and its minimum wage of $14 per hour for store employees is much less than the living wage, which is around $25 per hour. You can read more about why we want Walmart to pay a living wage in our blog.

Together with Shareholder Commons, which filed this resolution on behalf of Legal & General Investment Management America, we are asking Walmart to set out its policy on paying living wages to its employees. 

Sources

  1. Tackling inequality: An agenda for business action (tacklinginequality.org) and International Labour Organization (ILO), 2020: “World Employment and Social Outlook: Trends 2020
  2. Inequality kills | Oxfam International
  3. Inequality kills | Oxfam International and Tackling inequality: The need and opportunity for business action (tacklinginequality.org)
  4. Labor and Inequality Case Study - The Shareholder Commons

 

Chevron Corporation*

Meeting: AGM, 29 May 2024

Summary of resolutions:

Resolution 5 – Report on Reduced Plastics Demand Impact on Financial Assumptions

Resolution 6 – Commission Third Party Assessment on Company’s Human Rights Policies

LGIM’s vote intentions: 

For resolution 5 (against management recommendation) 

For resolution 6 (against management recommendation) 

Rationale:

These two resolutions sit within LGIM’s ‘Nature’ and ‘People’ themes, specifically relating to the circular economy and human rights. Our support for each reflects our emphasis on the financial materiality of these issues, the company’s room for improvement, and the alignment of these proposals with our expectations of companies as set out in our nature framework and human rights policy.

Regarding Resolution 5, the circular economy is a key component of LGIM's approach to nature, and we believe solving plastic pollution is critical in a ‘just transition’ to net zero and to creating nature-positive economies.

Chevron and Phillips 66 jointly own Chevron Phillips Chemical Co. (CP Chem), one of the top 20 producers of plastic resins bound for single-use applications (4.6 million tons), which results in 1.8 million tons of plastic waste, according to a recent analysis by Minderoo Foundation. Recent reports1 concur that the current rate of expansion of virgin plastic production is unsustainable, and production cuts in plastic use are necessary.

Brands that use resins manufactured by companies like CP Chem are calling for reductions. Coca-Cola Co*, Nestle*, PepsiCo*, Unilever* and Walmart*, members of the Business Coalition for a Global Plastics Treaty, have stated that the top priority of a global plastics treaty should be “reduction of plastic production and use”, focusing on plastics with high leakage rates, short lifespans and made using fossil-based virgin resources.

While we acknowledge the company’s disclosure on this topic within its Climate Risk Report, we believe that additional transparency would allow shareholders to better assess the company’s management of its plastics-related financial risks. We will therefore vote in favour of Resolution 5.

For Resolution 6, we believe companies have the responsibility to respect, manage and mitigate human rights risks. Companies should provide effective remedies to victims of business-related human rights harm. Managing the business elements of human rights within operations and value chains enables companies to establish safeguards to carry out economic activities and to minimise risks and costs.

While Chevron has taken steps to address human rights concerns, including its decision to withdraw from Myanmar in response to escalating human rights violations, questions remain regarding the efficacy of Chevron’s human rights policy and its monitoring practices.2 A third-party assessment would allow shareholders better transparency regarding the effectiveness of the company’s policies and systems in preventing, mitigating and addressing its human rights impacts. We will therefore vote in favour of Resolution 6.

Sources

1. https://www.unep.org/news-and-stories/press-release/comprehensive-assessment-marine-litter-and-plastic-pollution ; https://www.oecd.org/newsroom/plastic-pollution-is-growing-relentlessly-as-waste-management-and-recycling-fall-short.htm    

2. SLAPP-Policy-Brief-2022.pdf (earthrights.org)

 

Amazon.com, Inc.*

Meeting: AGM, 22 May 2024

Summary of resolutions:

Resolution 5 – Shareholder Proposal Requesting an Additional Board Committee to Oversee the Financial Impact of Policy Positions

Resolution 6 – Shareholder Proposal Requesting a Report on Customer Due Diligence

Resolution 8 – Shareholder Proposal Requesting Additional Reporting on Gender/Racial Pay Gaps

Resolution 12 – Shareholder Proposal Requesting Additional Reporting on Freedom of Association

LGIM’s vote intentions: 

Against Resolution 5 (aligned with management recommendation) 

For Resolution 6 (against management recommendation)

For Resolution 8 (against management recommendation) 

For Resolution 12 (against management recommendation) 

Rationale:

Our Investment Stewardship team takes a structured approach to engagement, focused on six global themes. One of these themes, ‘People’, looks at improving human capital across the corporate value chain (among other topics) and it is within this theme that the shareholder proposed resolutions above are particularly relevant.

As one of the largest companies and employers not only within its sector but in the world, we believe that Amazon’s approach to human capital management issues has the potential to drive improvements across both its industry and supply chain. Amazon is also a company that annually receives a large number of shareholder proposals, this year totalling 13 proposals, covering a variety of topics including lobbying, climate and emissions-related disclosures, political contributions, gender and ethnicity-based pay gaps, and freedom of association, some of which we will also be supporting.  

Resolution 5 is an example of a misleading shareholder proposal on social and diversity issues. Having initially published a blog on this topic last year in the context of racial equity audits, we find this proposal, despite the title, is not one that we can support, due to the wording of the supporting statement, which does not align with LGIM’s policies and principles on diversity.

Regarding Resolution 6, we voted in favour of this proposal last year and continue to support this request, as enhanced transparency over material risks to human rights is key to understanding the company’s functions and organisation. While the company has disclosed that they internally review these for their products (RING doorbells and Rekognition) and has utilised appropriate third parties to strengthen their policies in related areas, there remains a need for increased, especially publicly available, transparency on this topic. Despite this, Amazon’s coverage and reporting of risks falls short of our baseline expectations surrounding AI. In particular, we would welcome additional information on the internal education of AI and AI-related risks.

For Resolution 8, the company does disclose according to established mandatory US federal ethnicity and gender reporting standards, but does not publish comprehensive and disaggregated data on their gender and racial pay gaps at a regional level outside of the US or on a global level. Disclosure regarding wage progress within the company at each specific level and what job types and compensation are available at that level would also be welcomed. We consider further reporting would be beneficial to allow the company’s investors to gain transparency on pay gaps and company policies, and any actions taken to remediate and minimise material risks that could arise.

Regarding Resolution 12, the rationale is particularly pertinent as labour rights, including the right to freedom of association, is a key theme for LGIM and one that we continue to engage on with the company. We believe an assessment of the company’s commitments could have a number of benefits, including helping to improve human rights and employee freedoms within the company, to monitor and mitigate potential risks, and to manage and inform broader stakeholder questions on this topic. The right to freedom of association, among other labour rights, is material for this company and we consider there is scope for Amazon to increase their disclosures as a market leader. LGIM generally supports proposals calling for reporting on human rights and labour rights, and corresponding transparency in company strategy.

 

Glencore plc*

Meeting: AGM, 29 May 2024

Summary of resolutions:

Resolution 3 – To re-elect Kalidas Madhavpeddi as a Director

Resolution 12 – 2024-2026 Climate Action Transition Plan

LGIM’s vote intentions: 

Against Resolution 3 (against management recommendation) 

Against Resolution 12 (against management recommendation) 

Rationale:

As one of the largest diversified mining companies in the world, Glencore has a key role to play in the climate transition and, on account of its scale and potential to influence other firms in its sector and supply chain, is a company with which we have engaged with over many years as part of our Climate Impact Pledge programme.

In addition to having voted against the responsible director on several occasions due to the company falling short of our climate change expectations, we have also engaged with the company on their previous Climate Action Transition Plan, and voted against its approval every year it has been put to a shareholder vote. We have previously published our expectation for companies to introduce credible transition plans, consistent with the Paris goals of limiting the global average temperature increase to 1.5°C: please see our blog post, here: Say on Climate: empowering shareholders to drive positive change. Our voting records are publicly available on our dedicated website, here: VDS Dashboard (issgovernance.com) 

Upon review of Glencore’s most recent publications and an assessment against our Climate Impact Pledge sector expectations, we remain concerned that Glencore does not meet our minimum expectation requiring mining companies to disclose whether they plan to increase thermal coal capacity. This is especially concerning, since we filed a shareholder resolution at Glencore last year requesting that the company disclose:

  • How its projected thermal coal production aligns with the Paris Agreement's objective to pursue efforts to limit the global temperature increase to 1.5°C;
  • Details of how the company’s capital expenditure allocated to thermal coal production will align with the disclosure above; and
  • The extent of any inconsistency between the disclosure in the first bullet point above with the IEA Net Zero Scenario timelines for the phase-out of unabated thermal coal for electricity generation in advanced economies and developing economies. 

Furthermore, Glencore now recognises that its own targets ‘are not aligned with the IEA NZE scenario’.

As a result, in line with the application of our vote sanctions under the Climate Impact Pledge, we will be voting against the re-election of Glencore plc Chairman, Kalidas Madhavpeddi (Resolution 3). We will also be voting against the approval of the 2024 – 2026 Climate Action Transition Plan (Resolution 12).

 

Misleading shareholder proposals: oil & gas companies

ConocoPhillips*

Meeting: AGM, 14/05/2024

Resolution 5 – Revisit Pay Incentives for GHG Emission Reductions

Exxon Mobil Corporation*

Meeting: AGM, 29/05/2024

Resolution 4 – Revisit Pay Incentives for GHG Emission Reductions

Chevron Corporation*

Meeting: AGM, 29/05/2024

Resolution 4 – Report on Analyzing the Risks Arising from Voluntary Carbon-Reduction Commitments

Suncor Energy Ine*

Meeting: AGM, 7/05/2024

Resolution 4 – End 2050 Net Zero Pledge

LGIM’s vote intention: Against the above proposals (in line with management recommendation)

Misleading proposals (shareholder resolutions brought with the aim of undermining positive environmental, social and governance behaviours) are a relatively recent phenomenon.

Previously focused predominantly on social-related proposals (as referenced in our previous blog on racial equity audits LGIM Blog: How racial equity audits can tackle corporate inequality) we have seen, in the past couple of years, a number of proposals being tabled at large oil and gas companies, with the aim of reversing progress towards net zero emissions.

Such proposals often appear to be supportive of, for example, the energy transition but, when considered in depth, are actually designed to promote anti-climate change views.

The common narrative of these proposals is to challenge the climate-related commitments set out by these companies, with arguments supported by short-sighted views, and fuelled by interests that run counter to LGIM’s commitments to drive long-term, systemic change, with the aim of protecting our clients’ assets over long-term horizons.

Regarding the remuneration-related proposals above, we additionally would direct readers towards our global corporate governance and responsible investment principles, where we set out our expectations that companies in sectors that can have a significant effect on climate change should link part of their pay to delivering on their climate-mitigation goals. Targets should also be set to create new opportunities that not only improve revenue, but also have a positive impact on climate.

Due to the way that these misleading proposals are often drafted, we believe that investors should add an extra layer of scrutiny when assessing them, in order to ensure that their vote is being directed as intended.

We do not support such proposals and will continue to assess shareholder proposals carefully, and to work with our peers, to identify them.

 

Climate resolutions at North American and Nordic banks

Bank of America*, Goldman Sachs*, Morgan Stanley*, Wells Fargo*, Skandinaviska Enskilda Banken (SEB)*, Nordea Bank*, Danske Bank*, Swedbank*

Meetings: AGMs in April and May 2024

Summary of resolutions:

1) Green finance ratio: requesting disclosure of the ratio of clean energy supply financing as a proportion of fossil-fuel energy finance

2) Calling on the banks to stop financing fossil fuels

3) Requests for climate lobbying transparency

Background and rationale: Given the sector’s importance in enabling the global energy transition, banks have received a significant number of climate-related shareholder proposals ahead of the 2024 AGM season. We continue to consider that decarbonisation of the banking sector and its clients is key to ensuring that the goals of the Paris Agreement are met. Accordingly, we believe our support of many of these resolutions – depending always on the specifics of their drafting language and advisory or binding nature – is warranted.

1) Green finance ratio

LGIM’s vote stance: FOR the resolution (i.e. against management recommendation) – at Bank of America, Goldman Sachs, Morgan Stanley

 LGIM believes that banks and financial institutions have a significant role to play in shifting financing away from ‘brown’ to funding the transition to ‘green’. LGIM expects companies to be undertaking appropriate analysis and reporting on climate change matters, as we consider this issue to be a material risk to companies.

We are therefore supporting these resolutions.

In a positive development, it is worth noting that some of the TARGETED banks have since agreed to provide this disclosure and the proposals were withdrawn; at JPMorgan Chase, Citigroup and Royal Bank of Canada. 

2) Stop financing fossil fuels

LGIM’s vote stance: AGAINST the resolution (i.e. in line with management recommendation) – Skandinaviska Enskilda Banken (SEB), Nordea Bank, Danske Bank, Swedbank

LGIM expects companies to introduce credible transition plans, consistent with the Paris goals of limiting the global average temperature increase to 1.5°C. This includes the disclosure of Scope 1, 2 and material Scope 3 greenhouse gas (GHG) emissions and short-, medium- and long-term GHG emissions reduction targets consistent with the 1.5°C goal.

While we consider the overall principles of the resolution to be broadly supportable, the drafting of these proposals in such broad terms – demanding a climate strategy that seeks to immediately halt new fossil fuel extraction – Is too prescriptive in limiting banks’ activities towards achieving their stated climate goals. Also, this does not consider the nuances in an orderly transition to a net-zero emissions economy.

While LGIM will not support this type of resolution, we will continue to monitor banks’ activities.

3) Lobbying misalignment

LGIM’s vote stance: FOR the resolution (i.e. against management recommendation) – at Bank of America, Goldman Sachs, Wells Fargo, Morgan Stanley

In line with LGIM’s expectations as laid out in our Climate Impact Pledge Sector Guides, we encourage all companies to report their climate lobbying activity in line with the global standard on responsible corporate climate lobbying to ensure that lobbying activities are in line with the climate commitments of the company.

 

Woodside Energy Group Ltd.*

Meeting: AGM, 24/04/2024

Summary of resolutions:

Resolution 2a – Re-elect Richard Goyder as Director

Resolution 6 – Approve Climate Transition Action Plan and 2023 Progress Report

LGIM’s vote intention:  Against resolutions 2a and 6 (against management recommendation) 

Rationale:

The two resolutions are important on account of their subject matter (climate change, which continues to be a core area of focus for LGIM’s Investment Stewardship team), and the climate-related voting history at the company itself. Resolution 2 illustrates our Climate Impact Pledge vote sanctions in action; this is strongly linked to Resolution 6, pertaining to our ongoing efforts to put pressure on companies to construct suitably ambitious and credible transition plans for reaching net zero.

Our vote against the re-election of Richard Goyder (Resolution 2a) is applied in line with our Climate Impact Pledge engagement escalation, whereby we vote against the (re-)election of the Chair of the Board at companies lagging our minimum expectations on climate change; for the oil and gas sector, these are set out in our net-zero sector guide.

This is the second consecutive year in which we are applying voting sanctions against the company, having voted against the re-election of its most senior director, Ian Macfarlane, at the 2023 AGM, given similar concerns.

In the case of Woodside, in addition, we would state that, despite the significant proportion of shareholder votes (49%) against the company’s climate report at their 2022 AGM, as well as the re-election of Ian Macfarlane at the 2023 AGM (34.7%), we note that no material changes have been incorporated in their most recent climate transition plan, which we view as insufficiently robust, both in terms of disclosure and climate-related targets.

This leads us to Resolution 6. Having published our expectations for companies’ climate transition plans in 2022, we reiterate here that LGIM expects companies to introduce credible transition plans, consistent with the goals of the Paris Agreement on climate change to limit the global average temperature increase to 1.5°C.

While we view in a positive light some of the steps that have been taken by Woodside, primarily around methane, and in better aligning executive compensation to climate-related targets, we remain concerned about the insufficiently robust emissions targets, lack of quantifiable disclosure on climate related risks and the quantum of capital to be allocated to low-carbon solutions.

 

Nestlé S.A.*

Meeting: AGM, 18/04/2024

Summary of resolution: Resolution 7 – An Amendment to the Articles of Association regarding sales of healthier and less healthy foods

LGIM’s vote intention:  For resolution 7 (i.e. against management recommendation) 

Rationale:

We believe nutrition is an important topic for investors because it has a significant impact on the health and well-being of individuals, communities and societies. The interconnected challenges of obesity, undernutrition and micronutrient deficiencies is estimated to be 5% of global income, or $3.5 trillion, per annum.[1] Nutrition is therefore one of our global stewardship sub-themes, under the umbrella of Health.

In this shareholder resolution, which we are co-filing with other investors via ShareAction’s Healthy Markets Initiative, we are calling on Nestlé to:

  • Set key performance indicators (KPIs) regarding the absolute and proportional sales figures for food and beverage products according to their healthfulness, as defined by a government-endorsed Nutrient Profiling Model
  • Provide a timebound target to increase the proportion of sales derived from these healthier products

Further information on this resolution and our engagement with Nestlé can be found in our blog post.

We will also vote against item 1.2 (approval of the remuneration report) and item 4.3.1 (Elections of the members of the Compensation Committee – Dick Boer), due to our concerns over executive remuneration, since awards are permitted to vest for below-median relative performance, which therefore fails our ‘pay for performance’ expectations. We applied the same votes to last year’s remuneration report.

 

Apple Inc*

Meeting: AGM, 28-02-2024 

Summary of resolution: Resolution 7 – Report on Use of AI 

LGIM’s vote intention:  For resolution 7 (against management recommendation)   

Rationale:   

As artificial intelligence (AI) becomes increasingly embedded in our society, LGIM believes that it presents opportunities to drive long-term value and has the potential to create significant risks, stemming, for example, from data privacy and security, regulatory compliance and workforce transitions. Importantly, we also view societal trust in AI as a material risk.

Market participants are taking steps to ensure the safe development and deployment of AI, from tech companies disclosing approaches to responsible AI principles, to regulators and policymakers increasing AI-related laws around the globe.

As set out in our current baseline expectations on AI, we believe companies should be assessing and mitigating risks associated with AI and providing transparency to the market on their approach; this applies particularly to those companies that develop AI systems and will shape the way it is used in our economy and society. 

Resolution 7 asks Apple to produce a transparency report on the company’s use of AI in its business operations and disclose any ethical guidelines that the company has adopted regarding the company’s use of AI technology. Apple has announced general plans to further develop its use of generative AI and other AI capabilities; however, the company discloses very little about its approach to managing AI-related risks, nor any principles or guidelines to inform how the company uses AI, putting the company behind its peers and increasing exposure potential regulatory and other risks.

We met with the company to discuss these topics, and it did not commit to increasing transparency and disclosures around AI at this time. Apple is among several companies that have outsized influence on the integration of AI into our economy. In line with our expectations, we believe companies like Apple should be transparent in their uses of AI and their risk management processes; therefore, we will be voting FOR this resolution.  

More information on our Investment Stewardship activities can be found on our website:

Investment stewardship & governance | LGIM Institutional

 

*For illustrative purposes only. Reference to a particular security is on a historic basis and does not mean that the security is currently held or will be held within an LGIM portfolio. The above information does not constitute a recommendation to buy or sell any security.

[1] Global Panel on Agriculture and Food Systems for Nutrition (2016) Technical Brief No.3: The Cost of Malnutrition – Why Policy Action is Urgent. London: Global Panel on Agriculture and Food Systems for Nutrition. Available at: https://glopan.org/sites/default/files/pictures/CostOfMalnutrition.pdf

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