SEBI has, by way of circular dated December 24, 2019, introduced a Stewardship Code (‘Code’) to be followed by all mutual funds and all categories of alternative investment funds, in relation to their investment in listed equities, with effect from April 1, 2020. The Code lays out the following key principles that are required to be followed by the institutional investors: (i) formulation of a comprehensive policy on the discharge of their stewardship responsibilities, which should be publicly disclosed, and periodically reviewed and updated; (ii) formulation of a clear policy on conflict management in connection with fulfilling their stewardship responsibilities, which should be publicly disclosed, (iii) monitoring of investee companies, (iv) formulation of clear policies on intervention in their investee companies as well as for collaboration with other institutional investors where required, to preserve the interests of the ultimate investors, which should be disclosed, (v) formulation of a clear policy on voting and disclosure of voting activity, and (vi) periodic reporting on their stewardship activities.