Introduction

Lansdowne Partners Austria GmbH (the “Firm”) is the delegated portfolio manager for Multiflex SICAV – Lansdowne Endowment Fund (the “Fund”). Carne Global Fund Managers (Luxembourg) S.A. is the Management Company (the “ManCo”) for the Fund.

The Shareholder Rights Directive (EU 2017/828) (“SRD II”), implemented in, inter alia, Section 185 Austrian Stock Market Act (Börsegesetz), is a European Union directive, which sets out to strengthen the position of shareholders and to ensure that decisions are made for the long-term stability of a company. Under obligations arising from the SRD II, a firm which trades shares on EU regulated and comparable third country markets, is required to either develop and publicly disclose an engagement policy or disclose an explanation of why it has chosen not to do so. The Firm has elected to disclose its engagement policy as set out below, which is specific to the Fund.

Implementation

The policy details how the Firm approaches shareholder engagement and how it is implemented:

1. The Fund is a UCITS fund of funds strategy whereby the Fund primarily invests in other third-party managed funds. In this context, the shareholder engagement duty for the underlying investments principally falls on the shoulders of the third-party investment managers whose funds the Fund has chosen to invest in.
2. To the extent that the Fund invests in single-equities, Institutional Shareholder Services (“ISS”) proxy voting recommendations will be followed for all positions up to 1% of the shares outstanding.
3. Related to #2 above, for single-equity portfolio positions greater than 1%, the Fund’s portfolio management will review the ISS recommendations and actively decide whether or not to follow those recommendations.

Documentation

The Fund primarily invests in underlying UCITS funds. Direct equity positions are minimal, and voting/engagement is conducted through proxy service providers as described. Proxy voting decisions and engagement activities are documented internally, and any potential conflicts of interest are assessed by the Fund’s portfolio management. Due to the limited scope of direct equity holdings, an annual Shareholder Engagement Report is not produced. This approach is consistent with the proportionality principle under SRD II / Section 185 Austrian Stock Market Act (Börsegesetz).