EU Shareholder Rights Directive II – UCITS Engagement Policy
Alkeon Capital Management LLC (“Alkeon” or the “Firm”) is the investment manager to the DMS UCITS Platform ICAV Alkeon UCITS Fund (the “Fund”). 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 Fund invests in single-equities, Alkeon has instructed Institutional Shareholder Services (“ISS“) to make voting decisions on behalf of the Fund 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 Fund. 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.