4 unchanged sentences
We have one operating segment, investment management and related services.
−Removed: We offer our services and products under our various distinct brand names, including, but not limited to, Franklin ® , Templeton ® , Legg Mason ® , Alcentra ® , Benefit Street Partners ® , Brandywine Global Investment Management ® , Clarion Partners ® , ClearBridge Investments ® , Fiduciary Trust International™, Franklin Bissett ® , Franklin Mutual Series ® , K2 ® , Lexington Partners ® , Martin Currie ® , O’Shaughnessy ® Asset Management, Royce ® Investment Partners and Western Asset Management Company ® .
+Added: We offer our services and products under our various distinct brand names, including, but not limited to, Alcentra ® , Benefit Street Partners ® , Brandywine Global Investment Management ® , Clarion Partners ® , ClearBridge Investments ® , Fiduciary Trust International™, Franklin ® , Franklin Bissett ® , Franklin Mutual Series ® , K2 ® , Legg Mason ® , Lexington Partners ® , Martin Currie ® , O’Shaughnessy ® Asset Management, Royce ® Investment Partners, Templeton ® and Western Asset Management Company ® .
Unless otherwise indicated, our “funds” means the funds offered under our various brand names.
−Removed: We are a global investment management organization with $1,297.4 billion in assets under management (“AUM”) as of September 30, 2022.
−Removed: Our mission is to help people all over the world achieve the most important milestones of their lives through investment management expertise, wealth management and technology solutions.
−Removed: Through our specialist investment managers, we offer investment specialization bringing extensive capabilities across our fixed income, equity, alternative and multi-asset products.
−Removed: For 75 years, we have been committed to providing clients with exceptional investment management services and have developed a globally diversified business, including through strategic acquisitions.
+Added: We are a global investment management organization with approximately $1.4 trillion in assets under management (“AUM”) as of September 30, 2023.
+Added: Our mission is to help clients achieve better outcomes through investment management expertise, wealth management and technology solutions.
+Added: Through our specialist investment managers, we offer specialization on a global scale bringing extensive capabilities in fixed income, equity, alternatives and multi-asset solutions.
+Added: For over 75 years, we have been committed to providing clients with exceptional investment management services and have developed a globally diversified business, including through strategic acquisitions.
We provide our investment management and related services to retail, institutional and high-net-worth investors in jurisdictions worldwide.
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Related services include fund administration, sales and distribution, and shareholder servicing.
−Removed: Our sales and distribution services include distribution-related financial technology.
We may perform services directly or through third parties.
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We continue to focus on the long-term investment performance of our investment products and on providing high quality service to our clients.
−Removed: The business and regulatory environments in which we operate globally remain complex, uncertain and subject to change.
+Added: The global business and regulatory environments in which we operate remain complex, uncertain and subject to change.
We are subject to various laws, rules and regulations globally that impose restrictions, limitations, registration, reporting and disclosure requirements on our business, and add complexity to our global compliance operations.
Incorporated herein by reference is certain financial information about our segment and geographic areas contained in Note 18 – Segment and Geographic Information in the notes to consolidated financial statements in Item 8 of Part II of this Annual Report.
−Removed: Recent Acquisition
−Removed: On November 1, 2022, we acquired BNY Alcentra Group Holdings, Inc.
−Removed: (together with its subsidiaries, “Alcentra”) from The Bank of New York Mellon Corporation.
−Removed: Alcentra is a leading European credit and private debt manager, with global expertise in senior secured loans, high yield bonds, private credit, structured credit, special situations and multi-strategy credit strategies.
−Removed: We expect this acquisition to expand our alternative credit capabilities and presence in Europe, and continue to strengthen the breadth and scale of our alternative asset strategies.
+Added: Recent Developments
+Added: In May 2023, we entered into a definitive agreement to acquire Putnam Investments from Great-West Lifeco., Inc.
+Added: (“Great-West”), a member of the Power Corporation group of companies.
+Added: The Power Corporation group of companies including Great-West are leaders in the global insurance, retirement, asset management and wealth management sectors.
+Added: The acquisition is subject to customary closing conditions and is expected to close in the first quarter of fiscal year 2024.
Company History
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We have added, among others:
−Removed: (i) the Templeton investment firm, known for its global investing strategies and value style of investing, in 1992, (ii) the Franklin Mutual Series investment firm, known for its value-oriented equity funds, in 1996, (iii) the Franklin Bissett investment firm, known for its Canadian fixed income funds and growth-oriented equity funds, in 2000, (iv) the Fiduciary Trust International investment, trust and fiduciary services firm, in 2001, (v) the Benefit Street Partners U.S.
−Removed: alternative credit manager firm, in 2019, (vi) the Athena Capital Advisors investment and wealth management firm, in March 2020, (vii) The Pennsylvania Trust Company investment, trust and fiduciary services firm, in May 2020, (viii) the Legg Mason global investment firm, including certain specialist investment managers, in July 2020, (ix) the O’Shaughnessy Asset Management quantitative asset management firm, in December 2021, and (x) the Lexington Partners global investment firm, known for its alternative asset capabilities, in April 2022.
+Added: (i) the Templeton global investment firm in 1992, (ii) the Franklin Mutual Series investment firm in 1996, (iii) the Franklin Bissett Canadian investment firm in 2000, (iv) the Fiduciary Trust International investment and trust services firm in 2001, (v) the Benefit Street Partners alternative credit management firm in 2019, (vi) the Athena Capital Advisors investment and wealth management firm in March 2020, (vii) The Pennsylvania Trust Company investment and trust services firm in May 2020, (viii) the Legg Mason global investment firm in July 2020, (ix) the O’Shaughnessy Asset Management quantitative asset management firm in December 2021, (x) the Lexington Partners global alternatives investment firm in April 2022, and (xi) the Alcentra alternative credit investment firm in November 2022.
OUR BUSINESS STRUCTURE
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We generally derive our revenues and income from providing investment management and related services to our products and the products we sub-advise.
−Removed: Our investment management fees, which represent a significant portion of our revenues, depend to a large extent on the level and relative mix of our AUM and the types of services provided, which are subject to change.
+Added: Our investment management fees, which represent a majority of our revenues, depend to a large extent on the level and relative mix of our AUM and the types of services provided, which are subject to change.
Our business is conducted through our subsidiaries, including our specialist investment managers.
−Removed: Our specialist investment managers include subsidiaries registered with the U.S.
−Removed: Securities and Exchange Commission (the “SEC”) as investment advisers under the Investment Advisers Act of 1940 (the “Advisers Act”), as well as subsidiaries registered as investment adviser equivalents in jurisdictions including Australia, Brazil, Canada, China, Hong Kong, Ireland, India, Japan, Luxembourg, Malaysia, Mexico, Singapore, Switzerland, South Korea, Commonwealth of The Bahamas, the United Arab Emirates and the United Kingdom (“U.K.”).
−Removed: Our U.S.-registered funds and most of our non-U.S.-registered funds operate as independent companies subject to the supervision and oversight of the funds’ own boards of directors or trustees.
−Removed: Our registered open-end funds, or mutual funds, continuously offer their shares to investors.
−Removed: Our registered closed-end funds issue a set number of shares to investors in a public offering which are traded on a public stock exchange.
−Removed: Our investment managers manage a fund’s portfolio of securities in accordance with the fund’s stated objectives.
−Removed: To support the funds’ operations, our subsidiaries either provide or arrange for the investment and other management, shareholder servicing and administrative services required by the funds.
−Removed: We outsource various administration, technology, transfer agency and other services for our funds to third-party providers.
−Removed: An investor may purchase shares of a mutual fund directly from us or through a broker-dealer, financial adviser, bank or other similar financial intermediary that provides investment advice to the investor, or an investor may purchase shares of a closed-end fund or ETF on the stock exchange where the fund is traded.
−Removed: Financial intermediaries may earn fees and commissions and receive other compensation with respect to fund shares sold to investors.
+Added: Our specialist investment managers include subsidiaries registered with the United States (“U.S.”) Securities and Exchange Commission (the “SEC”) as investment advisers under the Investment Advisers Act of 1940 (the “Advisers Act”), as well as subsidiaries registered as investment adviser equivalents in jurisdictions including Australia, Brazil, Canada, China, Hong Kong, Ireland, India, Japan, Luxembourg, Malaysia, Mexico, Singapore, Switzerland, South Korea, Commonwealth of The Bahamas, the United Arab Emirates and the United Kingdom (“U.K.”).
Our AUM by Asset Class and Product Type
We offer a broad product mix under our fixed income, equity, alternative, multi-asset and cash management asset classes.
−Removed: Our fixed income capabilities include government, municipals, corporate credit, bank loans, securitized, multi-sector, currencies and other investments.
−Removed: Our equity capabilities include value, deep value, core value, blend, growth at a reasonable price (GARP), growth, convertibles, sector, Shariah, smart beta and thematic investments.
+Added: Our fixed income capabilities include government, municipals, corporate credit, bank loans, securitized, multi-sector, and other investments.
+Added: Our equity capabilities include value, deep value, core value, blend, growth and growth at a reasonable price, convertibles, sector, Shariah, smart beta and thematic investments.
Our alternative capabilities include private debt, hedge funds, private equity, real estate and infrastructure investments.
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Our fees for providing investment management services are generally based on a percentage of AUM in the accounts that we advise, the asset classes of the accounts, and the types of services that we provide.
−Removed: AUM by asset class and product type was as follows (primarily based on where product is domiciled):
+Added: AUM by asset class and product type was as follows:
(in billions)
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See “Assets under Management” under Item 7, Management’s Discussion and Analysis of Financial Condition and Results of Operations, of this Annual Report for additional information about our AUM.
−Removed: Broadly speaking, other than
−Removed: AUM changes due to acquisitions, changes in our AUM depend primarily upon two factors:
−Removed: (i) the increase or decrease in the market value of the securities and instruments held in the portfolio of investments, and (ii) the level of net flows.
+Added: Broadly speaking, other than AUM changes due to acquisitions, changes in our AUM depend primarily upon two factors:
+Added: (i) the increase or decrease in the market value of the securities and instruments held in the portfolio of investments, and (ii) the level and direction of net flows.
Changing market conditions and the evolving needs of our clients may cause asset volatility and a shift in our asset mix, potentially resulting in an increase or decrease in our revenues and income depending upon the nature of our AUM and the level of management fees we earn based on our AUM.
−Removed: Our Specialist Investment Managers
+Added: Our Investment Management Related Services and Products
Our specialist investment managers offer diverse perspectives and specialized expertise across asset classes and strategies.
−Removed: Across our business, our specialist investment managers generally focus on a portion of the asset management industry in terms of the types of assets managed (primarily fixed income, equity or alternatives) and each may differ in the types of products and services offered, the investment styles utilized, and the types and geographic locations of its clients.
−Removed: Each typically markets its products and services under its own brand name, with certain distribution functions provided by our corporate distribution subsidiaries.
+Added: Across our business, our specialist investment managers generally focus on a portion of the asset management industry in terms of the types of assets managed and each may differ in the types of products and services offered, the investment styles utilized, and the types and geographic locations of its clients.
+Added: Each typically markets its products and
+Added: services under its own brand name, with certain distribution functions provided by our corporate distribution subsidiaries where applicable.
We have in place revenue sharing arrangements with certain of our specialist investment managers.
Our specialist investment managers include:
−Removed: Benefit Street Partners, Brandywine Global, Clarion Partners, ClearBridge Investments, Fiduciary Trust International, Franklin Equity Group, Franklin Mutual Series, Franklin Templeton Emerging Markets Equity, Franklin Templeton Fixed Income, Franklin Templeton Global Private Equity, Franklin Templeton Investment Solutions, K2 Advisors, Lexington Partners, Martin Currie, O’Shaughnessy Asset Management, Royce Investment Partners, Templeton Global Equity Group, Templeton Global Macro and Western Asset Management.
−Removed: Our Broad Range of Services and Capabilities
−Removed: Investment Management Services
−Removed: Through our specialist investment managers, we offer a broad range of services and capabilities under our fixed income, equity, alternative, multi-asset and cash management asset classes.
−Removed: We also offer diverse strategies across active, smart beta and passive approaches, in a broad range of vehicles.
−Removed: Our investment products are offered globally to retail, institutional and high-net-worth clients, which may include, among others, individual investors, institutional investors, sovereign wealth funds, defined benefit and contribution plans, endowments and charitable foundations, healthcare systems and insurance companies.
+Added: Benefit Street Partners, Brandywine Global, Clarion Partners, ClearBridge Investments, Fiduciary Trust International, Franklin Equity Group, Franklin Income Investors, Franklin Mutual Series, Franklin Templeton Emerging Markets Equity, Franklin Templeton Fixed Income, Franklin Templeton Global Private Equity, Franklin Templeton Investment Solutions, K2 Advisors, Lexington Partners, Martin Currie, O’Shaughnessy Asset Management, Royce Investment Partners, Templeton Global Equity Group, Templeton Global Macro and Western Asset Management.
+Added: Through our specialist investment managers, our investment products are offered globally to retail, institutional and high-net-worth clients, which may include, among others, individual investors, institutional investors, sovereign wealth funds, defined benefit and contribution plans, endowments and charitable foundations, healthcare systems and insurance companies.
Our investment products include mutual funds, closed-end funds, private funds, institutional separate accounts, retail separately managed accounts, and other products.
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We also market and distribute our products through various subsidiaries to institutional investors with separate accounts.
−Removed: A few of our subsidiaries also serve as direct marketing broker-dealers for institutional investors for certain of our private funds, and some of our private funds may utilize third-party placement agents.
Our services also include management of our ETF platforms.
−Removed: Our ETF platforms include smart beta and actively managed ETFs, as well as additional lower fee passive ETF products.
−Removed: ETFs trade like stocks, fluctuate in market value and may trade at prices above or below the ETF’s net asset value.
−Removed: Our specialist investment managers provide investment management services pursuant to agreements in effect with each of our investment products and/or clients, including products for which we provide sub-advisory services.
+Added: Our specialist investment managers provide investment management services pursuant to agreements with each of our investment products and/or clients, including products for which we provide sub-advisory services.
Investment management fees are generally determined as a percentage of AUM pursuant to such contractual arrangements.
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Our services include fundamental investment research and valuation analyses, including original economic, political, industry and company research, and analyses of suppliers, customers and competitors.
−Removed: Our management fee on an account varies with the types of services that we provide for the account, among other things.
−Removed: mutual funds, the board of directors or trustees of each fund and our management personnel regularly review the investment management fee structures for the funds in light of fund performance, the level and range of services provided, industry conditions and other relevant factors.
−Removed: Most of our investment management agreements between our subsidiaries and our U.S.
−Removed: mutual funds must be renewed each year after an initial two-year term, and must be specifically approved at least annually by a vote of each fund’s board of directors or trustees as a whole and separately by a majority of its directors or trustees who are not interested persons of the fund under the Investment Company Act of 1940 (the “Investment Company Act”), or by a vote of the holders of a majority of the fund’s outstanding voting securities.
−Removed: In addition, our U.S.
−Removed: agreements generally may be terminated by either party without penalty after prior written notice.
+Added: Our management fees vary with the types of services that we provide, and fees may at times be waived or voluntarily reduced by the parties, among other things.
+Added: Our investment managers manage a fund’s portfolio of securities in accordance with the fund’s stated objectives.
+Added: To support the funds’ operations, our subsidiaries either provide or arrange for the investment and other management, shareholder servicing and administrative services required by the funds.
+Added: We outsource various administration, technology, transfer agency and other services for our funds to third-party providers.
+Added: An investor may purchase shares of a mutual fund directly from us or through a broker-dealer, financial adviser, bank or other similar financial intermediary that provides investment advice to the investor, or an investor may purchase shares of a closed-end fund or ETF on the stock exchange where the fund is traded.
+Added: Financial intermediaries may earn fees and commissions and receive other compensation with respect to fund shares sold to investors.
+Added: The applicable board of directors or trustees of our funds and our management personnel periodically review the investment management fee structures for the funds in light of fund performance, the level and range of services provided, industry conditions and other relevant factors.
+Added: mutual funds, most of our investment management agreements between our subsidiaries and funds must be renewed each year, and must be approved annually by a vote of each fund’s board of directors or trustees as a whole and separately by a majority of the independent fund directors or trustees under the Investment Company Act of 1940 (the “Investment Company Act”), or by a vote of the holders of a majority of the fund’s outstanding voting securities, and such agreements generally may be terminated by either party without penalty after prior written notice.
mutual funds, private funds, institutional and high-net-worth separate accounts, and the products for which we provide sub-advisory services, are typically subject to various termination rights and/or renewal provisions, which often provide for termination upon relatively short notice with little or no penalty.
−Removed: Investment management fees are at times waived or voluntarily reduced when, for example, a new fund/account is established, and then increased to contractual levels within an established timeline or as net asset values reach certain levels.
Retail Separately Managed Account Programs
Certain of our specialist investment managers provide asset management services to retail separately managed account programs sponsored by various financial institutions.
−Removed: These programs typically allow securities brokers or other financial intermediaries to offer their clients the opportunity to choose from a number of asset management services pursuing different investment strategies provided by one or more investment managers, and generally charge an all-inclusive fee that can cover asset management, trade execution, asset allocation and custodial and administrative services.
−Removed: Alternative Strategies
−Removed: Certain of our specialist investment managers manage alternative investment strategies which provide our clients with alternatives to traditional equity and fixed income products and services.
−Removed: Our alternative products include private credit funds and structured products, business development companies, hedge funds (funds of funds and custom advisory solutions), private equity funds, venture capital funds and real estate funds.
−Removed: These products employ various investment strategies and approaches, including loan origination, collateralized loan obligations, high-yield credit, hedge fund advisory, private equity and infrastructure transactions in emerging markets, global macro, financial technology, consumer loans, direct real estate investments, and custom-tailored investment programs.
−Removed: High-Net-Worth Investment Management, Trust and Custody
−Removed: Through our Fiduciary Trust International group, including its trust company and investment adviser subsidiaries, and through certain other of our subsidiaries, we provide investment management and related services to, among others, high-net-worth individuals and families, family offices, foundations and institutional clients.
+Added: These programs typically allow securities brokers or other financial intermediaries to offer their clients the opportunity to choose from a number of asset management services pursuing different investment strategies provided by one or more investment managers, and generally charge an all-inclusive fee that can cover asset management, asset allocation and custodial and administrative services.
+Added: Alternative Products and Strategies
+Added: Certain of our specialist investment managers manage alternative products and investment strategies which provide our clients with alternatives to traditional equity and fixed income products and services.
+Added: Our alternative products include private credit funds and structured products, business development companies, hedge funds (funds of funds and custom advisory solutions), private equity funds, secondary funds, venture capital funds and real estate funds.
+Added: These products employ various investment strategies and approaches, including loan origination, collateralized loan obligations, high-yield credit, hedge fund advisory, private equity and infrastructure transactions in emerging markets, global macro, consumer loans, direct real estate investments, and custom-tailored investment programs.
+Added: High-Net-Worth Investment Management, Trust and Custody Services
+Added: Through our Fiduciary Trust International related subsidiaries, we provide investment management and related services to, among others, high-net-worth individuals and families, family offices, foundations and institutional clients.
Fiduciary Trust International offers investment management and advisory services across different investment styles and asset classes.
The majority of these client assets are actively managed by individual portfolio managers, while a significant number of clients also seek multi-manager, multi-asset class solutions.
−Removed: Through our trust company subsidiaries, including Fiduciary Trust International, we also may provide separately managed accounts, private funds, and trust, custody and related services, including administration, performance measurement, estate planning and tax planning.
+Added: We also may provide separately managed accounts, private funds, and trust, custody and related services, including administration, performance measurement, estate planning and tax planning.
Sales and Distribution
Our global distribution framework is organized into two groups.
−Removed: Our global advisory services group is responsible for sales, marketing and business development, and maintains a regional distribution model.
−Removed: Our global alliances and new business strategies group oversees our digital wealth management and distribution-related financial technology, joint ventures, seed capital allocations, and direct-to-consumer initiatives.
−Removed: Our groups work closely together to meet the needs of our advisors, clients and investors.
+Added: Our global advisory services group is responsible for sales, marketing and business development and maintains a regional distribution model, with regional teams responsible for driving initiatives in collaboration with global teams.
+Added: Our global alliances and new business strategies group oversees our digital wealth management and distribution-related technology, joint ventures, product governance, seed capital allocations, fund board management, and direct-to-consumer initiatives.
+Added: Our groups work together to meet the needs of our advisors, clients and investors.
There are many sales channels across each region, which may include retail, institutional, private wealth, retirement, insurance, and other specialty sales.
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Our sales and distribution capabilities and related efforts are critical components of our business and may be impacted by global distribution trends and changes within the financial services industry.
−Removed: In the U.S., our corporate distribution subsidiaries generally serve as the principal underwriters and distributors of shares of most of our mutual funds.
+Added: In the U.S., our distribution subsidiaries generally serve as the principal underwriters and distributors of shares of most of our mutual funds.
Outside the U.S., certain of our non-U.S.
2 unchanged sentences
Some of our non-U.S.
−Removed: mutual funds, particularly our Luxembourg and Irish domiciled fund ranges, are distributed globally on a cross-border basis, while others are distributed exclusively in local markets.
+Added: mutual funds, particularly our Luxembourg and Irish domiciled funds, are distributed globally on a cross-border basis, while others are distributed exclusively in local markets.
We earn sales and distribution fees primarily by distributing our mutual funds pursuant to distribution agreements with the funds.
1 unchanged sentence
mutual funds, we offer and sell the fund shares on a continuous basis and pay certain costs associated with selling, marketing and distributing the fund shares, including the costs of developing and producing sales literature, shareholder reports and prospectuses.
−Removed: Our sales and distribution fees primarily consist of upfront sales commissions and ongoing distribution fees.
−Removed: Sales commissions are earned from the sale of certain classes of sponsored funds at the time of purchase and may be reduced or eliminated depending on the amount invested and the type of investor.
−Removed: Therefore, our sales fees generally will change with the overall level of gross sales, the size of individual transactions, and the relative mix of sales between different share classes and types of investors.
−Removed: Our mutual funds generally pay us distribution fees in return for sales, marketing and distribution efforts on their behalf.
+Added: Our sales and distribution fees primarily consist of upfront sales commissions and ongoing distribution fees, which generally will change with the overall level of gross sales, the size of individual transactions, and the relative mix of sales between different asset classes and types of investors.
The majority of our U.S.
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mutual funds.
−Removed: The Rule 12b-1 Plans are established for one-year terms and must be approved annually by a vote of each fund’s board of directors or trustees as a whole and separately by a majority of its directors or trustees who are not interested persons of the fund under the Investment Company Act.
−Removed: The Rule 12b-1 Plans are subject to termination at any time by a majority vote of the disinterested fund directors or trustees or by the particular fund’s shareholders.
−Removed: We pay substantially all of our sales and distribution fees earned as revenues, including fees earned under the Rule 12b-1 Plans, to the financial advisers and other intermediaries that sell our funds on our behalf.
+Added: The Rule 12b-1 Plans are established for one-year terms and must be approved annually by a vote of each fund’s board of directors or trustees as a whole and separately by a majority of the independent fund directors or trustees under the Investment Company Act, and such plans are subject to termination at any time by a majority vote of the independent fund directors or trustees or by the fund’s shareholders.
+Added: We pay the sales and distribution fees earned as revenues to the financial advisers and other intermediaries that sell our funds on our behalf.
The distribution agreements with our U.S.
1 unchanged sentence
These financial intermediaries receive various sales commissions and other fees for services in matching investors with funds whose asset classes match such investors’ goals and risk profiles.
−Removed: The intermediaries also may receive fees for their assistance in explaining the operations of the funds and in servicing and maintaining investors’ accounts, and for reporting and various other distribution services.
+Added: The intermediaries also may receive fees for their assistance in explaining the operations of the funds, and for reporting and various other distribution services.
Other compensation may be offered to the extent not prohibited by federal or state laws or any self-regulatory agency, such as the Financial Industry Regulatory Authority (“FINRA”), applicable to our business.
2 unchanged sentences
Similar arrangements exist with the distribution of our non-U.S.
−Removed: mutual funds where, generally, our subsidiary that distributes the funds receives maintenance fees from the funds and pays commissions and certain other fees to financial advisers, banks and other intermediaries.
+Added: mutual funds where, generally, our subsidiary that distributes the funds receives maintenance fees from the funds and pays certain fees to financial advisers, banks and other intermediaries.
Shareholder Servicing
2 unchanged sentences
Fees for U.S.
−Removed: funds are based on the level of AUM and the number of transactions in shareholder accounts, while outside of the U.S., the fees are based on the level of AUM and/or the number of shareholder accounts.
+Added: funds are based on the level of AUM and applicable transactions in shareholder accounts, while outside of the U.S., the fees are based on the level of AUM and/or the number of shareholder accounts.
We outsource various transfer agency and other services for our funds to third-party providers who serve as a sub-agent or delegate, depending on the jurisdiction.
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We continue to focus on the long-term performance of our investment products, service to clients and extensive marketing activities through our strong broker-dealer and other financial institution distribution network as well as with high-net-worth and institutional clients.
−Removed: The establishment of new investment management firms and continuous development of investment products increases the competition that we face.
+Added: The establishment of new investment management firms and continuous development of investment products
+Added: increases the competition that we face.
Many of our competitors have long-standing and established relationships with broker-dealers, investment advisers and their clients, and some have affiliated brokerage businesses.
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laws, regulations, rules, codes, notices, directives, guidelines, orders, circulars and/or conditions in the various jurisdictions where we operate could result in a wide range of disciplinary actions against us, our subsidiaries and/or our business.
−Removed: Breaches of applicable laws and rules could result in regulatory
−Removed: enforcement, civil liability, criminal liability and/or the imposition of a range of sanctions or orders against us, including, as applicable, monetary damages, injunctions, disgorgements, fines, penalties, cease and desist orders, censures, reprimands, and the revocation, cancellation, suspension or restriction of licenses, registration status or approvals held by us or our business in a jurisdiction or market.
+Added: Breaches of applicable laws and rules could result in regulatory enforcement, civil liability, criminal liability and/or the imposition of a range of sanctions or orders against us, including, as applicable, monetary damages, injunctions, disgorgements, fines, penalties, cease and desist orders, censures, reprimands, and the revocation, cancellation, suspension or restriction of licenses, registration status or approvals held by us or our business in a jurisdiction or market.
In addition, a public regulatory issue can have a negative impact on our reputation, and as a result have indirect impacts on our business or growth.
−Removed: See Item 7, Management’s Discussion and Analysis of Financial Condition and Results of Operations, of this Annual Report, for financial information about our business, including certain regulatory financial impacts disclosed therein.
+Added: See Item 7, Management’s Discussion and Analysis of Financial Condition and Results of Operations, of this Annual Report, for financial information about our business.
Regulatory Framework.
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As we continue to address our legal and regulatory requirements or focus on meeting new or expanded requirements, we may need to expend a substantial amount of additional time, costs and resources.
−Removed: Regulatory reforms may add further complexity to our business and operations and could require us to alter our investment management services and related activities, which could be costly, impede our growth and adversely impact our AUM, revenues and income.
+Added: Regulatory reforms may continue to add further complexity to our business and operations and could require us to alter our investment management services and related activities, which could be costly, impede our growth and adversely impact our AUM, revenues and income.
+Added: Such reforms could significantly increase our reporting, disclosure and compliance obligations.
Certain key regulatory reforms in the U.S.
that impact or relate to our business, and may cause, or continue to cause, us to incur additional obligations, include:
−Removed: Sustainable Investing and ESG .
−Removed: Sustainable investing and ESG have been the focus of increased regulatory scrutiny across jurisdictions.
−Removed: Globally, the International Sustainability Standards Board and applicable disclosure standards impact how national regulators approach these topics.
−Removed: In the U.S., the SEC has proposed rules to require public issuers to provide enhanced disclosure regarding climate-related information in annual reports and registration statements.
+Added: Executive Compensation Clawback Rules .
+Added: In October 2023, we adopted an executive compensation clawback policy in order to comply with new Section 10D and Rule 10D-1 of the Exchange Act, and the listing standards of the NYSE, providing for the repayment or forfeiture of certain excess compensation following an applicable accounting restatement from persons who served as an executive officer of Franklin at any time during the performance period for such incentive-based compensation and who received such compensation during the three fiscal years preceding the date on which Franklin is required to prepare an accounting restatement.
+Added: A copy of the policy is filed as an exhibit to this Annual Report.
+Added: Issuer Share Repurchase Plan Disclosure.
+Added: In May 2023, the SEC adopted final rules requiring additional disclosure of issuer share repurchases, requiring expanded quarterly reporting in tabular format of detailed information regarding share repurchases made by or on behalf of an issuer during the quarter as well as narrative disclosure regarding issuer share repurchase programs and policies.
+Added: The rules also require new quarterly disclosure of whether a U.S.
+Added: issuer has adopted or terminated a Rule 10b5-1 trading plan during the quarter, similar to the required disclosure of the adoption and termination of such plans by an issuer’s directors and officers.
+Added: We will become subject to the new quarterly issuer disclosure requirements in our quarterly report for the fiscal quarter ending December 31, 2023.
+Added: Cybersecurity Disclosure.
+Added: In July 2023, the SEC adopted amendments to its rules to require disclosure regarding cybersecurity risk management, strategy, governance and incident reporting by public companies.
+Added: The SEC’s adopted amendments require public companies to (i) disclose, on a current basis, any cybersecurity incident it deems to be material within four business days on a Form 8-K;
+Added: (ii) describe, on a periodic basis, the company’s processes, if any, for the assessment, identification and management of material risks from cybersecurity threats, as well as whether any risks from cybersecurity threats have materially affected or are reasonably likely to materially affect their business strategy, results of operations or financial condition;
+Added: and (iii) describe, on a periodic basis, the board’s oversight of risks from cybersecurity threats and management’s role in assessing and managing those risks.
+Added: The amendments will require ongoing evaluation and analysis of possible changes in our applicable processes and procedures, including regarding cyber incident response plans and procedures, disclosure analysis framework, risk management processes, and board oversight structure.
+Added: The current disclosure reporting requirements become effective in December 2023, and we will become subject to the annual disclosure requirements in our annual report for the fiscal year ending September 30, 2024.
+Added: Sustainable Investing and ESG, and Climate-Related Disclosure .
+Added: Sustainable investing and ESG continue to be the focus of increased regulatory scrutiny across jurisdictions.
+Added: In the U.S., the SEC has proposed climate disclosure rules to require public issuers to include enhanced disclosure regarding corporate climate-related information in their periodic reports and registration statements.
+Added: Such information would include climate-related risks that are reasonably likely to have a material impact on an issuer’s business or results of operations, as well as certain climate-related financial statement metrics.
+Added: In addition, we expect state laws and regulations regarding these topics to continue to evolve and impose new and additional requirements.
+Added: For example, in October 2023, California enacted a new climate accountability package pursuant to its new Climate Corporate Data Accountability Act that will require annual disclosure of certain greenhouse gas
+Added: emissions and new Climate-Related Financial Risk Act that will require biennial disclosure of certain climate-related financial risks and mitigation measures, each beginning in 2026, subject to applicable implementing regulations and rulemaking that may impact final scope and compliance timing.
Also, the SEC has increased its focus on disclosure and compliance related to ESG strategies of investment advisers and funds.
+Added: Globally, the International Sustainability Standards Board and applicable sustainability disclosure standards impact how national regulators and governance bodies approach these and related topics.
+Added: Privacy and Data Protection.
+Added: There continues to be an increased regulatory and enforcement focus with respect to the protection of individuals’ privacy and personal data around the world, and the ongoing need to secure and ensure only appropriate collection and use of sensitive customer, personnel, and others’ personal data.
+Added: A majority of the jurisdictions where we operate are covered, or we expect will be covered, by stringent privacy and data protection laws and regulations.
+Added: As the regulatory focus on privacy continues to intensify and laws and regulations concerning the management of personal data continue to expand, risks related to the handling of privacy obligations and personal data collection across our business will increase.
+Added: For example, in addition to international data protection and privacy laws and regulations like the EU’s GDPR, we are, and expect to continue to be, subject to and affected by existing, new and evolving country, federal and state laws, regulations and guidance around the world impacting consumer and personnel privacy, including the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and various other U.S.
+Added: state consumer privacy laws that provide for enhanced consumer protections for their residents and impose requirements for the handling, disclosure and deletion of personal information of their residents.
Systemically Important Financial Institutions.
5 unchanged sentences
The FSB may designate certain non-bank financial companies as global systemically important financial institutions (“G-SIFIs”).
−Removed: The FSOC and the FSB, as well as other global regulators, are considering what threats to U.S.
−Removed: and global financial stability, if any, arise from asset management companies and/or the funds that they sponsor or manage, and whether such threats can be mitigated by treating such entities as SIFIs or G-SIFIs and/or subjecting them to additional regulation.
To the extent that we or any of our funds are designated as a SIFI or G-SIFI, such designations would add additional supervision, review, monitoring and/or regulation resulting in increased scrutiny and oversight that could impact our business.
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Regulators continue to review practices and regulations relating to the use of futures, swaps and other derivatives, which could result in further restrictions and limitations on the use of such products.
−Removed: In October 2020, the SEC adopted new rules governing the use of derivatives by certain registered investment companies, including certain mutual funds, designed to address investor protection concerns.
−Removed: As of August 2022, key aspects of the new framework include, among other things, value at risk limits on a fund entering into derivatives transactions, required risk management program, and further fund board oversight, reporting and compliance requirements.
+Added: In October 2020, the SEC adopted new rules governing the use of derivatives by certain registered investment companies, including certain mutual funds, designed to address investor protection concerns, which became effective in August 2022.
+Added: Key aspects of the new framework include, among other things, value at risk limits on a fund entering into derivatives transactions, required risk management program, and further fund board oversight, reporting and compliance requirements.
The EU and other countries have adopted and implemented, or are in the process of adopting or implementing, similar and additional requirements.
−Removed: There is some risk that full mutual recognition may not be achieved between the various regulators, which may cause us to incur duplicate regulation and transaction costs.
−Removed: Money Market Funds .
+Added: There is the risk that full mutual recognition may not be achieved between the various regulators, which may cause us to incur duplicate regulation and transaction costs.
+Added: Private Fund Adviser Reforms.
+Added: In May 2023, the SEC adopted amendments to Form PF, which is the confidential reporting form that investment advisers to private funds file to provide confidential information to the SEC and the FSOC.
+Added: The amendments were adopted largely as proposed and will require (i) current and quarterly reporting by large hedge fund advisers regarding certain events that may indicate stress at a fund or signal broader systemic risk;
+Added: and (ii) enhanced reporting by large private equity advisers to allow the FSOC to monitor systemic risk.
+Added: The amendments also will require large private equity fund advisers to report information on general partner and limited partner clawbacks on an annual basis as well as additional information on their strategies and borrowings as a part of their annual filing.
+Added: The current and quarterly event reporting requirements become effective in November 2023 and the remaining amendments become effective in May 2024.
+Added: In August 2023, the SEC also adopted new rules and amendments that will require advisers to private funds to (i) obtain an annual audit for each private fund;
+Added: (ii) provide investors with quarterly statements regarding private fund performance, fees and expenses;
+Added: and (iii) obtain a fairness or valuation opinion in connection with an adviser-led secondary transaction.
+Added: Compliance with certain aspects of the rules is required effective in September 2024 and with the remaining elements effective in March 2025.
+Added: Money Market Fund Reforms .
The regulatory structure governing U.S.
money market funds was previously reformed to address perceived systemic risks of money market funds relating to fund stability and investor risks, including allowing certain funds to impose liquidity fees and redemption gates under certain circumstances.
−Removed: In addition, regulatory authorities remain focused on whether to implement further reform measures to improve the resiliency of money market funds and the broader short-term funding markets, which, if adopted, could significantly impact the money market fund industry.
−Removed: Privacy and Data Protection.
−Removed: There has been increased regulation with respect to the protection of customer privacy and data, and the need to secure sensitive customer, personnel and others’ information.
−Removed: A majority of the jurisdictions where we operate are covered, or we expect will be covered, by privacy and data protection laws and regulations.
−Removed: As the regulatory focus on privacy continues to intensify and laws and regulations concerning the management of personal data continue to expand, risks related to privacy and data collection within our business will increase.
−Removed: In addition to the EU’s GDPR data protection rules, we also are or may become subject to or affected by additional country, federal and state laws, regulations and guidance impacting consumer privacy, such as the California Consumer Privacy Act (“CCPA”) that provides for enhanced consumer protections for California residents, enforcement authority by the California Attorney General and/or the California Privacy Protection Agency for CCPA violations, and the potential for private litigation, including statutory damages for data security breaches.
−Removed: The EU’s GDPR strengthened and unified data protection rules for individuals within the EU and addresses export of personal data outside the EU.
−Removed: The primary objectives of GDPR are to give citizens control of their personal data and to simplify the regulatory environment for international business by unifying data protection regulation within the EU.
−Removed: Compliance with the stringent data protection rules under GDPR requires ongoing review of our global data processing systems.
−Removed: There are also new laws that have been adopted in recent years, including, for example, Brazil’s Lei Geral de Proteção de Dados with regulatory enforcement as of August 2021, and the California Privacy Rights Act with an effective date of January 1, 2023.
−Removed: SEC Regulation Best Interest.
−Removed: In June 2019, the SEC adopted a package of new rules, amendments and interpretations, including Regulation Best Interest and a new form of relationship summary, designed to enhance investor protections for all retail customers.
−Removed: Since June 2020, such rules, among other things:
−Removed: (i) require broker-dealers to act in the best interest of their retail customers when recommending securities and account types, (ii) raise the broker-dealer standard of conduct beyond existing suitability obligations, and (iii) require broker-dealers and registered investment advisers to provide their retail clients with a new relationship summary disclosure document to inform such clients of the nature of their relationships with the clients’ investment professionals, including a description of services offered, the legal standards of conduct that apply to such services, the fees a client might pay, and conflicts of interest that may exist.
+Added: In July 2023, the SEC adopted
+Added: additional rule and form amendments concerning money market funds registered under the Investment Company Act.
+Added: The amendments are intended to address problems experienced by certain money market funds in connection with the economic shock at the onset of the COVID-19 pandemic.
+Added: The new and amended rules will phase in through October 2024 and will, among other changes, impose increased minimum liquidity requirements, impose mandatory liquidity fees on institutional prime and institutional tax-exempt funds under certain circumstances, eliminate redemption gates, and permit share cancellation measures during periods of negative interest rates.
+Added: In addition, the Form PF was further amended to require additional information regarding the private liquidity funds that an investment manager advises.
+Added: Fund Names Rule Reforms.
+Added: In September 2023, the SEC adopted amendments to the fund “Names Rule” impacting regulated investment funds.
+Added: The Names Rule generally requires a fund to invest at least 80% of the value of its assets in the particular type of investments or industry suggested by the fund's name.
+Added: The amendments expand the applicability of the Names Rule and impacted funds may need to modify their names or alter their investment strategies to comply with the amendments, potentially impacting their portfolios.
+Added: Funds with names that suggest a focus on investments that have particular characteristics, such as “growth,” “value” or thematic terms such as “ESG,” would be required to adopt a policy to invest at least 80% of the fund’s assets in those investments and would be subject to enhanced disclosure and reporting requirements.
+Added: The SEC did not clearly define these terms and instead is allowing fund managers the flexibility to create their own reasonable definitions.
+Added: Compliance with the rules is required effective in December 2025.
and Global Tax Compliance.
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Our international operations are subject to regulatory systems in various jurisdictions, comparable to those covering our operations in the U.S.
−Removed: European Markets and Regulation.
−Removed: In Luxembourg, the Commission de Surveillance du Secteur Financier (“CSSF”) currently regulates our substantial activities in Luxembourg, including our subsidiary Franklin Templeton International Services S.à r.l.
+Added: In Luxembourg, the Commission de Surveillance du Secteur Financier (“CSSF”) regulates our substantial activities in Luxembourg, including our subsidiary Franklin Templeton International Services S.à r.l.
(“FTIS Lux”).
FTIS Lux is licensed as a management company for both the Undertakings for Collective Investment in Transferable Securities Directive (“UCITS”) and alternative investment funds (“AIFs”) and, as such, it manages our Luxembourg-domiciled UCITS and our EU-domiciled AIFs.
−Removed: FTIS Lux’s license also covers certain MiFID (as defined below) investment services, such as discretionary portfolio management, investment advice and reception and transmission of orders in relation to financial instruments.
+Added: FTIS Lux’s license also covers certain investment services, such as discretionary portfolio management, investment advice and reception and transmission of orders in relation to financial instruments.
The CSSF’s rules include capital resource, governance and risk management requirements, business conduct rules, remuneration rules and oversight of systems and controls.
−Removed: Our international funds include two broad ranges of cross-border UCITS that are domiciled in Luxembourg and Ireland, respectively, and thereby subject to regulation by the CSSF and the Central Bank of Ireland.
+Added: Our international funds include two broad ranges of cross-border UCITS that are domiciled in Luxembourg and Ireland, as applicable, and thereby subject to regulation by the CSSF and the Central Bank of Ireland.
Both UCITS are also registered for public sale in many countries around the world, both in the EU and beyond, and thus are also subject to the laws of, and certain supervision by, the governmental authorities of those countries.
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The FCA’s and PRA ’ s rules under that act govern a firm’s capital resources requirements, senior management arrangements, business conduct, interaction with clients, and systems and controls.
−Removed: In addition to the above, certain of our other European subsidiaries and branches, must comply with the pan-European regime established by the EU Markets in Financial Instruments Directive (“MiFID”), which regulates the provision of investment services and conduct of investment activities throughout the European Economic Area (“EEA”).
−Removed: MiFID sets out detailed requirements governing the organization and business conduct of investment firms and regulated markets.
−Removed: It also includes pre- and post-trade transparency requirements for equity markets and extensive transaction reporting requirements.
−Removed: Luxembourg and the U.K.
−Removed: have adopted the MiFID rules into national legislation, as have those other EU member states in which we have a presence.
−Removed: A review of MiFID by the European Commission led to the creation of a replacement directive and regulation (together “MiFID II”) that extend the scope of the original MiFID.
−Removed: Changes apply to pre- and post-trade reporting obligations and there is an expansion of the types of instruments subject to these requirements, such as bonds, structured products and derivatives.
−Removed: A concept of trading venue was created and algorithmic trading is subject to specific regulations.
−Removed: There were also changes to business conduct requirements, including selling practices, intermediary inducements and client categorization, as well as the provision of investment advice and management within the EU by non-EU advisers, including ours.
−Removed: Powers have also been given to EU national regulators to ban certain services and products and to the European Securities and Markets Authority to restrict temporarily certain financial activities within the EU.
+Added: In addition, the EU Markets in Financial Instruments Directive, as revised and expanded in 2018 (“MiFID II”), regulates the provision of investment services and conduct of investment activities throughout the European Economic Area (“EEA”).
+Added: As revised, MiFID II sets out detailed requirements governing the organization and business conduct of investment firms and regulated markets, and includes pre- and post-trade transparency requirements for equity markets and extensive transaction reporting requirements.
+Added: It also includes an expansion of the types of instruments subject to these requirements, such as bonds, structured products and derivatives, and changes to business conduct requirements, including selling practices, intermediary inducements and client categorization.
MiFID II also includes a ban on commission and other payments (“inducements”) to independent advisers and discretionary managers, which has changed the commercial relationships between fund providers and distributors.
Arrangements with non-independent advisers have also been affected, as narrower rules around the requirement that any commission reflect an enhancement of the service to customers come into effect, along with a prescriptive list of permissible non-monetary benefits.
−Removed: The interpretation of the inducements rules has also resulted in major changes to how fund managers finance investment research with many firms, including ours, opting to pay for third-party investment research for client accounts covered by MiFID II.
+Added: The interpretation of the inducements rules has also resulted in major changes to how fund managers finance investment research with many firms, including ours.
The European Market Infrastructure Regulation sets out rules in relation to the central clearing of specified derivatives.
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The EU regulation on packaged retail investment and insurance products (“PRIIPs”) imposed new pre-contractual disclosure requirements under the form of a Key Information Document (“KID”) for the benefit of retail investors when they are considering the purchase of packaged retail investment products or insurance-based products.
−Removed: It requires PRIIP manufacturers to draw up a KID that can be no longer than three pages in length and must be written in simple language.
The EU’s Sustainable Finance Disclosure Regulation (“SFDR”) imposes mandatory ESG disclosure obligations on asset managers and other financial markets participants.
−Removed: It requires all covered firms to disclose how financial products integrate sustainability risks in the investment process, including whether they consider adverse sustainability impacts, and, for those products promoting sustainable objectives, the provision of sustainability-related information.
−Removed: Related amendments to the MiFID, UCITS and AIFMD legislation require that all covered investment managers must consider in their investment process any ESG risks which are likely to have a material impact on the value of the investment, and require investment advisers to inquire as to the investor’s desire for ESG-focused products in their portfolio when assessing suitability.
−Removed: The availability of these sustainability disclosures may impact the investment decisions of European investors.
−Removed: British Exit from the EU (“Brexit”).
−Removed: withdrew from the EU in January 2020, and a post-Brexit U.K./EU trade agreement was approved by the EU in April 2021.
−Removed: While we are continuing to monitor the impact and related developments for our clients from an investment perspective, we believe that Brexit will not have a material impact on the way our firm operates in the U.K.
−Removed: or within the EU.
−Removed: Our long-standing U.K.
−Removed: businesses are expected to continue to provide their services to U.K.
−Removed: and certain non-EU customers.
−Removed: Furthermore, we have regulated subsidiaries and branch offices across continental Europe to manage our EU business.
−Removed: Moreover, our primary cross-border UCITS, the Franklin Templeton Investment Funds Société d’Investissement à Capital Variable, or SICAV, investment fund range, which is the most widely-distributed such range in the world, is based in Luxembourg, and a smaller cross-border UCITS, also distributed throughout the EU and beyond, is based in Ireland.
−Removed: We have separate, U.K.-domiciled fund ranges that are, and will continue to be, distributed mainly in the U.K.
+Added: SFDR requires all covered firms to disclose how financial products integrate sustainability risks in the investment process, including whether they consider adverse sustainability impacts, and, for those products promoting sustainable objectives, the provision of sustainability-related information.
+Added: Related amendments to applicable legislation require that all covered investment managers must consider in their investment process any ESG risks which are likely to have a material impact on the value of the investment, and require investment advisers to inquire as to the investor’s desire for ESG-focused products in their portfolio when assessing suitability.
+Added: The availability of such sustainability disclosure may impact the investment decisions of European investors.
+Added: The EU’s proposal for a Corporate Sustainability Due Diligence Directive (“CSDD”) would impose due diligence obligations requiring companies to identify, and to prevent or at least mitigate, adverse impacts on human rights and the environment, including by their subsidiaries and supply chain partners.
+Added: Obligations would be enforced through administrative sanctions and civil liability, with a defense of having exercised reasonable due diligence.
+Added: The CSDD proposal remains subject to ongoing review and negotiation in the EU.
In Australia, our subsidiaries are subject to various Australian federal and state laws and are regulated by the Australian Securities and Investments Commission (“ASIC”).
2 unchanged sentences
In Canada, our subsidiaries are subject to provincial and territorial laws and are registered with and regulated by provincial and territorial securities regulatory authorities.
−Removed: The mandate of Canadian securities regulatory authorities is generally to protect investors and to foster fair and efficient capital markets.
−Removed: Securities regulatory authorities impose certain requirements on registrants, including a standard of conduct, capital and insurance, record keeping, regulatory financial reporting, conflict of interest management, compliance systems and security holder reporting.
−Removed: In addition, as a federally licensed trust company, our subsidiary Fiduciary Trust Company of Canada is subject to regulation and supervision by the Office of the Superintendent of Financial Institutions and another subsidiary, FTC Investor Services Inc., is a member of and regulated by the Mutual Fund Dealers Association of Canada.
+Added: The mandate of Canadian securities regulatory authorities is generally to protect investors;
+Added: to foster fair, efficient and competitive capital markets;
+Added: to foster capital formation;
+Added: and to contribute to the stability of the financial system and the reduction of systemic risk.
+Added: Securities regulatory authorities impose certain requirements on registrants, including a standard of conduct, capital and insurance, record
+Added: keeping, regulatory financial reporting, conflict of interest management, compliance systems and security holder reporting.
+Added: In addition, one of our Canadian subsidiaries is a federally licensed trust company subject to regulation and supervision by the Office of the Superintendent of Financial Institutions and another subsidiary is a member of and regulated by the Canadian Investment Regulatory Organization.
These regulatory bodies have similar requirements to those of the securities regulatory authorities with a view to ensuring the capital adequacy and sound business practices of the subsidiaries and the appropriate treatment of their clients.
21 unchanged sentences
We have used, registered, and/or applied to register certain trademarks, service marks and trade names to distinguish our sponsored products and services from those of our competitors in the U.S.
−Removed: and in other countries and jurisdictions, including, but not limited to, Franklin ® , Templeton ® , Legg Mason ® , Alcentra ® , Benefit Street Partners ® , Brandywine Global Investment Management ® , Clarion Partners ® , ClearBridge Investments ® , Fiduciary Trust International™, Franklin Bissett ® , Franklin Mutual Series ® , K2 ® , Lexington Partners ® , Martin Currie ® , O’Shaughnessy ® Asset Management, Royce ® Investment Partners and Western Asset Management Company ® .
+Added: and in other countries and jurisdictions, including, but not limited to, Alcentra ® , Benefit Street Partners ® , Brandywine Global Investment Management ® , Clarion Partners ® , ClearBridge Investments ® , Fiduciary Trust International™, Franklin ® , Franklin Bissett ® , Franklin Mutual Series ® , K2 ® , Legg Mason ® , Lexington Partners ® , Martin Currie ® , O’Shaughnessy ® Asset Management, Royce ® Investment Partners, Templeton ® and Western Asset Management Company ® .
Our trademarks, service marks and trade names are important to us and, accordingly, we enforce our trademark, service mark and trade name rights.
3 unchanged sentences
As of September 30, 2023, we employed approximately 9,200 employees and operated offices in over 30 countries.
−Removed: We depend upon our key personnel to manage our business, including our portfolio managers, investment analysts, investment advisers, sales and management personnel and other professionals as well as our executive officers and business unit heads.
+Added: We depend upon our key personnel to manage our business, including our portfolio managers, investment analysts, sales and management personnel and other professionals as well as our executive officers and business unit heads.
Competition for experienced personnel is significant and from time to time we may experience a loss of valuable personnel.
4 unchanged sentences
Our employees have access to a valuable set of equitable and competitive total rewards, which consists of a mix of monetary and non-monetary rewards designed to recognize their time, talents and results.
−Removed: We believe that our ability to attract, develop and cultivate a sense of belonging and retain a diverse, highly skilled workforce is important to our long-term success and that creating and maintaining all aspects of diversity, including backgrounds and perspectives, makes us a better place to work and a more resilient business.
−Removed: To accomplish this, we have developed strategies and initiatives to diversify talent within our organization.
−Removed: We consider an inclusive culture that actively leverages the expertise and perspectives of our diverse workforce an important factor in our ability to deliver innovative and relevant client solutions in a dynamic marketplace.
+Added: Recognizing the importance of diversity, equity, and inclusion (“DEI”) is a priority in our organization.
+Added: We believe that our ability to attract, develop and retain a diverse and highly-skilled workforce is important to our long-term success.
+Added: We have developed DEI strategies and initiatives anchored in our core values.
+Added: To support our DEI efforts, we have allocated dedicated resources for DEI, established a global governance structure, and have established research-based DEI policies and procedures.
+Added: We believe that our commitment to creating and maintaining a diverse workforce, including backgrounds and perspectives, makes us a better place to work and a more resilient business.
+Added: We value an inclusive culture that leverages the expertise and perspectives of our diverse workforce as an important factor in our ability to deliver innovative and relevant client solutions in a dynamic marketplace.
AVAILABLE INFORMATION
4 unchanged sentences
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.