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Shareholder Rights Directive

Under EU and FCA rules we are required to provide certain disclosures regarding our UK insurance business, where investment is being made in shares traded on a regulated market. Old Mutual Wealth Life & Pensions Limited (OMWLP) is the product provider for our Collective Investment Bond and Collective Retirement Account, available as part of our platform proposition. Old Mutual Wealth Life Assurance Limited (OMWLA) is the provider of our closed book insurance products.

A. Shareholder engagement policy

Currently OMWLP does not offer the option for customers to purchase shares traded on a regulated market; however, once our Platform Transformation Programme (PTP) is delivered customers will be able to purchase a range of exchange-traded instruments (ETIs) including:

  • Investment Trusts
  • Exchange Traded Funds
  • Exchange Traded Commodities

We are currently developing an engagement policy to set out how we will comply with relevant points from the FCA’s Handbook (in particular SYSC 3.4) after PTP. Our engagement policy will be published on this web page after we introduce the ability to purchase exchange-traded instruments.

B. Investment strategy and arrangements with asset managers

Also under the EU and FCA rules we are required to provide the following public disclosures regarding our arrangements with asset managers:

Considerations Old Mutual Wealth's approach
1. How the arrangement with the asset manager incentivises the asset manager to align its investment strategy and decisions with the profile and duration of the liabilities of the life insurer’s long-term liabilities.

OMWLP does not have any bespoke asset management arrangements in place – all funds available to customers are from the general market and have not been set up exclusively for use by OMWLP.

The same is generally true of OMWLA in that most funds available simply mirror underlying funds from the general market; however, OMWLA does offer a number of bespoke funds managed by Quilter Investors, Invesco and AXA Framlington. Each of these bespoke funds has a mandate in place to ensure the fund is managed in line with customer expectations as set out in the relevant fund objective and investment policy. Old Mutual Wealth conducts monthly monitoring on these mandates to ensure they are adhered to.

2. How that arrangement incentivises the asset manager to make investment decisions based on assessments about medium to long-term financial and non-financial performance of the investee company and to engage with investee companies to improve their performance in the medium to long-term. The asset manager is incentivised to grow the fund value as their sole remuneration is obtained from the annual management charges on any underlying funds in the portfolio.
3. How the method and time-horizon of the evaluation of the asset manager’s performance and the remuneration for asset management services are in line with the profile and duration of the liabilities of the life insurer, in particular, long-term liabilities, and take absolute long-term performance into account.

In addition to the monthly monitoring referred to above, we conduct annual performance reviews of the bespoke funds run for our OMWLA business, to ensure they are being managed in line with the fund objective and investment policy, and to ensure any performance issues are raised and addressed.

The manager’s sole remuneration for any bespoke funds is obtained from the annual management charges on any underlying funds in the portfolio.

4. How the life insurer monitors portfolio turnover costs incurred by the asset manager and how it defines and monitors a targeted portfolio turnover or turnover range. We do not currently monitor portfolio turnover as this is not subject to limits in the mandate and fund agreement with each asset manager.
5. The duration of the arrangement with the asset manager. Our current arrangements with asset managers will continue until such time as the relevant fund agreement and mandate are amended.


The above statements will be reviewed on an annual basis and updated in the event of any material changes.