France's Financial Markets Authority publishes SPOT findings on asset managers’ voting and shareholder engagement practices

France’s Financial Markets Authority (AMF) has published a synthesis of its SPOT thematic reviews on asset managers’ voting and shareholder engagement policies, reiterating applicable requirements and setting out good and poor practices observed across five firms. The work forms part of the AMF’s sustainable finance supervisory priorities and concludes that practices are broadly satisfactory, while identifying areas for improvement. The reviews covered governance and organisation for voting and engagement, policy design and updates, implementation and monitoring, investor disclosures, and related internal controls across managers with collective AUM ranging from under EUR 1 billion to over EUR 50 billion for 2022 to 2024. On engagement, the AMF highlights as good practice the use of a transparent escalation process aligned with the investment strategy and supported by clear trigger rules. On voting, four of the five firms used external service providers for resolution analysis, tailored voting recommendations, or proxy voting execution, and the AMF notes the high concentration of the proxy advisory market. The AMF encourages firms to document and justify significant and recurring deviations from their voting policies and, where relevant, deviations from provider recommendations that remain consistent with the firm’s policy. For investor reporting, while all firms published voting and engagement policies and annual reports, the AMF found disclosures largely statistical and encouraged more detailed discussion of selected resolutions to evidence ESG engagement, while flagging as poor practice the absence of analysis of how voting and engagement affected portfolio companies’ strategy or governance; it also noted that voted resolutions insufficiently address environmental and social topics.