FSA has written to trade associations explaining its support for the proposals in the Walker review on shareholder engagement and clarifying that its rules do not stand in the way of shareholders acting as Walker suggests. In particular, it says:  

  • the market abuse rules do not stop investors engaging collectively with the management of an investee company (although trading on the basis of another's intentions or similar activities could be market abuse);  
  • FSA's rules on disclosure of major shareholdings would not affect shareholders having an ad hoc discussion on a specific issue (although they would apply where investors have agreed on a united long-term strategy); and  
  • FSA does not consider shareholder discussions that happen ad hoc and are to promote good governance principles would be "acting in concert" for the purposes of the Acquisitions Directive.