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This comment examines Article 3b of Directive 2007/36/EC, as amended by Directive (EU) 2017/828. This provision sets rules for the transmission of information between shareholders and companies. The effective exercise of shareholder rights in listed companies depends on the efficiency of the transmission of information between companies and shareholders along the chain of intermediaries. This comment explains how this provision ensures such efficient transmission of information. In the communication between companies and shareholders along the holding chain, information may flow along two channels: (a) from the company to the shareholders (this is the ‘top-down channel’), and (b) from the shareholders to the company (the ‘bottom-up channel’). This comment on Article 3b considers both of these transmission channels. Particular attention is given to the analysis of the functioning of the top-down channel, which Article 3b regulates in great detail.

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