Proxy statement redaction is the removal of personal identifiers from a voting circular. Companies Act 2006 s.324 gives every member the right to appoint a proxy, and s.325 requires the notice of meeting to say so. A circular must carry that statutory content, plus whatever the FCA's Listing Rules and DTRs require of a listed issuer — but nothing obliges you to publish a requisitioning member's telephone number. anonym.plus marks each name and contact on your machine.
When this applies
The circular names directors, nominees and the members who requisitioned a resolution, together with their contact details. You trim the personal identifiers the rules do not require before it is lodged and posted.
How anonym.plus handles it
- Open the circular in anonym.plus on your device.
- Local OCR reads scanned resolution letters.
- The tool flags names, contacts, and holdings.
- Keep the disclosure the voting rules require.
- Swap or black out the confirmed identifiers.
- Save the clean circular locally.
What you need to provide
- The circular (PDF, DOCX, or scan).
- An operator (Replace keeps the prose readable).
- Optional allow-list for required disclosures.
PII & financial identifiers detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | nominee A. Coleridge → [NOMINEE] |
| Contact | EMAIL_ADDRESS | ir@example.co.uk → [EMAIL] |
| Contact | PHONE_NUMBER | +44 20 7946 0147 → [PHONE] |
| Money | MONEY | beneficial 2.1% → [HOLDING] |
| Identifiers | UK_NINO | proposer NINO → [NINO] |
| Location | LOCATION | proposer address → [ADDRESS] |
Compliance achieved
- The notice must state the proxy right under CA 2006 s.325, with the appointment right itself in s.324 — keep both intact.
- A resolution requisitioned under CA 2006 s.338 (members holding 5% of the voting rights, or at least 100 members with an average of £100 paid up each) must be circulated; the requisitioners' contact details need not be.
- Meeting and voting information for a listed issuer follows the FCA DTRs and the circular content requirements of the UK Listing Rules.
- Publishing what the Act requires rests on UK GDPR Art. 6(1)(c); anything beyond it does not.
- Offline work keeps the draft circular on your machine until it is issued.
Anonymise proxy statements offline — see plans & start free →
Limitations & cautions
The Companies Act and the DTRs both prescribe content, so keep every item they demand — including the nominee disclosure a member needs to vote. The tool flags named items but cannot judge required content. Have counsel confirm the circular before it is lodged.
Frequently asked questions
Will required holder and nominee disclosures survive the pass?
Yes. Allow-list what the Companies Act and the DTRs require. Only extra personal identifiers, such as a requisitioner's private telephone number, are flagged.
Must a requisitioning member be named?
CA 2006 s.338 obliges the company to circulate the resolution. It does not turn the member's home address or direct line into required content, so those can be removed.
Is the circular uploaded?
No. The app is offline, so it stays on your device until you lodge it.