In 2011 EFAMA produced its ‘Code for external governance’, providing a framework of high-level principles-based set of recommendations (“Principles”) and best practice recommendations to cover the engagement between asset managers and the companies in which they invest. In 2017, following the adoption of the Revision of the Shareholder Rights Directive ‘revised Shareholder Rights Directive’, EF
AMA updated its Code, renaming it the EFAMA Stewardship Code. The revised EFAMA Stewardship Code should be applied on a ‘comply or explain’ basis and aims to be a European reference document, notably for asset managers seeking to comply with the revised Shareholder Rights Directive (in particular article 3g regarding engagement policy). This approach relies upon good judgement rather than prescription. As such, the guidance recognise that the “best” approach for many issues depends on circumstances. The Code is not designed to supersede applicable law and regulations nor national Stewardship Codes or statements.