“A FTSE 250 Company Secretary would like to understand other companies’ practice in relation to their PLC directors declaring any shareholdings in other companies which are competitors, suppliers or customers.
In particular, if such shareholdings are declared, how frequently does this happen and how are discretionary investment arrangements dealt with, where a director might not normally exercise day to day control over the investments made by his fund manager?”
We touched on this issue a while back and directors did disclose regardless of the size of the holding (to qualify this is small holdings in with our partners, we do not believe it is good practice to hold shares in our competitors).
We do have a conflict of interest policy which is a annual declaration and this is good practice.
contractually, directors are allowed to hold up to 3% in any other listed company without restriction. Holdings of 3% or more must be approved.
a conflict of interest policy requires a declaration once a year.
underpinning all the above is of course a director’s statutory duty to avoid conflict of interests.