As a foundational principle, PAAO does not require or seek collective decision-making or action with respect to acquiring, holding, disposing and/or voting of securities. Signatories are independent fiduciaries responsible for their own investment and voting decisions and must always act completely independently to set their own strategies, policies and practices based on their own best interests and decision making and the overarching fiduciary duties owed to their clients and beneficiaries for long–term value preservation.
The use of particular tools and guidance, including the scope of participation in PAAO, is at the sole discretion of individual signatories.
PAAO facilitates the exchange of publicly available information, but signatories must avoid the exchange (including one-way disclosure) of non-public, competitively sensitive information, including with other signatories, PAAO itself, and its investor networks. Even the exchange of certain information in the context of collaboration can give the appearance of a potentially unlawful agreement; it is important to avoid exchanging information which might result in, or appear to result in, a breach of corporate or competition law.
Signatories may not claim to represent other signatories or make statements referencing other signatories without their express consent. Any decision by signatories to take action with respect to acquiring, holding, disposing and/or voting of securities shall be at their sole discretion and made in their individual capacities and not on behalf of PAAO, its investor networks or their other signatories or members. Signatories must strictly avoid coordination of strategic behaviour between competitors that impacts or is likely to impact competition.
Signatories which are subject to legal or regulatory regimes which prohibit or restrict the disclosure of sensitive or confidential information or material non-public information (e.g., issuers subject to the EU Market Abuse Regulation) are solely responsible for compliance with their obligations under such regimes, including when determining whether information pertaining to their organisation is subject to public disclosure or other requirements.
PAAO and its investor networks do not provide investment, legal, accounting or tax advice. PAAO and its investor networks do not necessarily endorse or validate the information contained herein.
The terms of engagement, responsibilities, rights and other information contained elsewhere herein are intended to be interpreted in a manner consistent with the foregoing.