EU Shareholder Rights Directive II – Engagement Policy
Alkeon Capital Management LLC (“Alkeon” or the “Firm”) is the investment manager to the DMS UCITS Platform ICAV Alkeon UCITS Fund (“Alkeon UCITS”) and the portfolio manager to the Alkeon Innovation Lux, SCSp SICAV-RAIF (“Alkeon Lux”, and together with Alkeon UCITS, the “Funds”). Under the Shareholder Rights Directive II (the “Directive”), Alkeon is required to make a disclosure about the nature of its commitment to the Directive, or, where it does not commit to the Directive, to provide a clear and reasoned explanation for not doing so. The Directive sets out a number of principles relating to the role of shareholder engagement and the exercise of voting rights in EU listed companies. While Alkeon supports the overall principles of the Directive, Alkeon’s investment strategies involve only minimal activity in scope of the Directive. To the extent that the Funds invest in single-equities, Alkeon has instructed Institutional Shareholder Services (“ISS“) to make voting decisions on behalf of the Funds based on the proxy voting guidelines that ISS provides to the Firm. Alkeon may override ISS’ voting decisions if the Firm deems it in the best interests of the Funds. Therefore Alkeon has determined not to adopt an engagement policy, and to rely instead on the Firm’s existing policies and procedures, including the Firm’s proxy voting policy, conflicts policy and various related procedures already in effect, which are directly responsive to the principles of the Directive and which Alkeon has determined are proportionate to the risks of the business. Alkeon makes such information available to investors and prospective investors, consistent with its obligations under applicable law.
EU Sustainable Finance Disclosure
Under the EU’s Sustainable Finance Disclosure Regulation (“SFDR”), Alkeon must disclose the extent to which it takes into account the EU criteria for sustainability risks in the investment decision making process, and must make a ‘comply or explain’ decision as to whether it considers principal adverse impacts (“PAIs”) of investment decisions on sustainability factors in accordance with a specific regime outlined in SFDR (the “PAI Regime”).
While Alkeon is supportive of ESG initiatives, Alkeon does not currently take into account the EU criteria for environmentally sustainable economic activities in its investment decision making process, as Alkeon believes that taking such criteria into consideration would risk compromising the Funds’ respective investment objectives. Additionally, taking into account the size, nature and scale of Alkeon’s activities, and the fact that Alkeon is not itself established in the EU, Alkeon has decided not to comply with the PAI Regime at this current time.