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The comment on Article 3g sheds light on the rationales for imposing duties on institutional shareholders focusing on corporate governance aspects, in particular the crucial role that institutional investors must play to contribute to the long-term viability and to the corporate governance of investee companies. In particular, the comment develops article 3g’s engagement policy duties applicable to institutional investors and asset managers. Furthermore, the comment discusses a series of challenges for national market actors in the light of the lack of familiarity, awareness, and demand for shareholder stewardship that may be characteristic in some countries. Finally, the comment discusses the extent of the transparency requirements according to which institutional investors and asset managers have to disclose information on the engagement practices, which may have a positive impact on the relationship between investors, investee companies, and civil society.

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