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4 November 2021

USS responds to Primary Markets Effectiveness Review consultation

USS is supportive of initiatives that encourage high quality and well-governed companies to come to the UK market. However, we believe that such initiatives should not be at the expense of the integrity and high standards of the listing regime for which London is renowned globally.

  • We recognise that fast-growth technology, e-commerce and science companies may have different corporate and voting structures to more traditional and established industries, but there is no justification - in our view - to dilute the premium listing rules in order to accommodate these companies.
  • We are concerned that any significant dilution of the standards in the listing regime could set a precedent for the UK listing regime in a post-Brexit environment.
  • If the UK embarks on a potential ‘race to the bottom’ as competition increases amongst jurisdictions seeking to attract new listings of tech companies, for example, there is a risk that standards will be further diluted.
  • We call for the retention of the UK’s listing rules on dual class voting structures and free float thresholds and ensure that principle of one-share, one-vote is protected.
  • We raised similar concerns at the time when the listing rules were changed to allow state-owned companies such as Saudi Aramco to list in the premium segment – an event which ultimately did not take place.