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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
| Address1 | 228 Oakland Park Avenue |
Address2 |
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| City | Columbus |
State | OH |
Zip Code | 43214 |
Country | USA |
3. Principal place of business (if different than line 2)
| City | London |
State |
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Zip Code | EC4N 4SJ |
Country | GBR |
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5. Senate ID# 401104840-69342
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6. House ID# 440410002
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| TYPE OF REPORT | 8. Year | 2026 |
Q1 (1/1 - 3/31) | Q2 (4/1 - 6/30) | Q3 (7/1 - 9/30) | Q4 (10/1 - 12/31) |
9. Check if this filing amends a previously filed version of this report
| 10. Check if this is a Termination Report | Termination Date |
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11. No Lobbying Issue Activity |
| INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13 | |||||||||
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| 12. Lobbying | 13. Organizations | ||||||||
| INCOME relating to lobbying activities for this reporting period was: | EXPENSE relating to lobbying activities for this reporting period were: | ||||||||
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| Provide a good faith estimate, rounded to the nearest $10,000, of all lobbying related income for the client (including all payments to the registrant by any other entity for lobbying activities on behalf of the client). | 14. REPORTING Check box to indicate expense accounting method. See instructions for description of options. | ||||||||
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Method A.
Reporting amounts using LDA definitions only
Method B. Reporting amounts under section 6033(b)(8) of the Internal Revenue Code Method C. Reporting amounts under section 162(e) of the Internal Revenue Code |
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| Signature | Digitally Signed By: Carol Nolan Drake |
Date | 4/20/2026 2:12:07 PM |
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code FIN
16. Specific lobbying issues
Securities and Exchange Commission-Meetings on 25 March with the SEC on protecting investor and shareholder rights, including voting, 13D-G guidance and the importance of engagement and dialogue between issuers and investors, mandatory arbitration provisions, request for ideas to streamline Reg S-K, how investors use proxy advisors, and a request for public consultations with notice and comment periods under the Administrative Procedures Act.
We discussed accounting and auditing issues with the SEC and PCAOB, including international standard setting, budget, managing risks and appropriate controls, and high-quality auditing/accounting and international standards for investors.
Senate meetings on 25 March with Republican and Democratic policy staff from the Committee on Banking, Housing, and Urban Affairs, Subcommittee on Capital Markets, Committee on Finance, to discuss upcoming Committee hearings, bills such as capital formation, and activity, to support S.3831, the "Enhancing Multi-class Share Disclosure Act" which was introduced in the Senate on February 11, 2026.
Meetings with House and Senator offices on upcoming Committee activities, bills, and investor issues.
House meetings with the Republican and Democratic policy staff from the Committee on Financial Services, Subcommittee on Capital Markets, Committee on the Judiciary, Subcommittee on the Administrative State, Regulatory Reform, and Antitrust to discuss shareholder rights, including shareholder proposals, changes to 13D-G, proxy advisory services, views on materiality and SEC activity, and the need for stability in the US capital market for global investors.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Securities & Exchange Commission (SEC)
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Carol |
Nolan Drake |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
Information Update Page - Complete ONLY where registration information has changed.
20. Client new address
| Address |
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State |
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Zip Code |
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21. Client new principal place of business (if different than line 20)
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State |
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Zip Code |
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Country |
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22. New General description of client’s business or activities
LOBBYIST UPDATE
23. Name of each previously reported individual who is no longer expected to act as a lobbyist for the client
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3 |
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4 |
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ISSUE UPDATE
24. General lobbying issue that no longer pertains
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AFFILIATED ORGANIZATIONS
25. Add the following affiliated organization(s)
Internet Address:
| Name | Address |
Principal Place of Business (city and state or country) |
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26. Name of each previously reported organization that is no longer affiliated with the registrant or client
| 1 | 2 | 3 |
FOREIGN ENTITIES
27. Add the following foreign entities:
| Name | Address |
Principal place of business (city and state or country) |
Amount of contribution for lobbying activities | Ownership percentage in client | ||||||||||
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% | |||||||||||||
28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization
| 1 | 3 | 5 |
| 2 | 4 | 6 |
CONVICTIONS DISCLOSURE
29. Have any of the lobbyists listed on this report been convicted in a Federal or State Court of an offense involving bribery,
extortion, embezzlement, an illegal kickback, tax evasion, fraud, a conflict of interest, making a false statement, perjury, or money laundering?
| Lobbyist Name | Description of Offense(s) |