SEB IMAB uses the assistance of an external shareholder services provider to handle administrative voting procedures. The Need for Reform. 0 trillion in publicly traded U.
Proxy Voting Procedures. 204-2 of the Code of Federal Regulations in which the rule is published, as amended by this release, and when we refer to ruleor any paragraph of the rule, we are referring to. The following summarizes the FRFA.
· The current proxy advisory firm market is essentially a duopoly consisting of Institutional Shareholder Services Inc. SEB FS is committed to ensure consistent exercise of voting rights associated with shares held in Undertakings for Collective Investment of Transferable Securities (UCITS) and Alternative Investment Funds (AIF), where proxy voting has been delegated to SEB FS. To oversee the proxy-voting process on an ongoing basis, a Proxy Committee has been established for each global location where proxy-voting decisions are made.
Under rule, it is a fraudulent, deceptive, or manipulative act, practice or course of business within the meaning of section 206(4) of the Act for an investment adviser to exercise voting authority with respect to client securities, unless (i) the adviser has adopted and implemented written policies and procedures that are reasonably designed to ensure that the adviser votes proxies in the best interest of its clients, (ii) the adviser describes its proxy voting procedures to its cli. 107-204, § 302, 116 Stat. Thomas Körfgen has been very active in the area of corporate governance since the late 1990s. We understand that based largely on the SEC’s Ruleadopting release and two SEC staff “no-action” letters (withdrawn in ), institutional investors have for some time operated under the belief that they could avoid potential conflicts of interest by voting client proxies in accordance with the recommendations of proxy advisors. Many commenters, including individual investors, fund groups that currently provide proxy voting information to their shareholders, labor unions, and pension and retirement plan trustees, supported the proposals, and in some cases commented that the proposals did not go far enough i. Investment advisers regularly are faced with an array of decisions regarding voting of equity securities on behalf of their clients, whether those clients are individual investors, funds or other institutional investors.
, and 20 international locations in. the maximum value of their investment. (“ISS”), owned by the private equity firm Genstar Capital, and Glass Lewis & Co. Proxy Voting Proxy voting is a key component of TIAA-CREF’s oversight and engagement program.
, and the Commission has submitted the proposed collections of information to the Office of Management and Budget (&92;&92;"OMB&92;&92;") for review in accordance with 44 U. Submit only information that you wish to make publicly available. As set forth in the Proposing Release, new ruleand the amendments to rule 204-2 contain &92;&92;"collection of information&92;&92;" requirements within the meaning of the Paperwork Reduction Act of 1995 (&92;&92;"PRA&92;&92;").
27, ) (adopting Form N-CSR). Proxy advisors engage in activities and have relationships that could affect the objectivity or reliability of their advice. 3507(d) and.
4 See Disclosure of Proxy Voting Policies and Proxy Voting Records by Registered Management Investment Companies, Investment Company Act Release No. Not FDIC Insured • No Bank Guarantee • May Lose Value. We agree that, as noted in the Proposing Release, it would be inconsistent with the goal of ensuring access to fair seb and accurate information if persons whose business is to offer and sell voting advice to large numbers of shareholders, with the expectation that their advice will factor into shareholders’ voting decisions, were beyond the reach of Section 14(a). See full list on federalregister. Each Proxy seb investment management proxy voting seb Committee is composed of a Proxy Administrator (as defined below) and senior officers from among the Investment, Legal, Compliance and Risk Management Departments.
Of the approximately 8,000 comment letters, the overwhelming majority supported the proposals and urged us to adopt the proposed amendments. 80b-2(a)(11)(F), 80b-2(a)(17), 80b-3, 80b-4, 80b-6(4), 80b-6a, 80b-11, unless otherwise noted. Advisers Subject to the Rule2. The titles for the collections of information that we have submitted are: (1) &92;&92;"Form N-1A unde.
The authority citation for Part 275 continues to read in part as follows:Authority: 15 U. corporate equity, representing approximately 18% of all publicly traded U. 20,FR 6082. The Adviser may retain proxy advisory firms to provide services in connection with voting proxies, including, without limitation, to provide information on shareholder meeting dates and proxy materials, translate proxy materials printed in a foreign language, provide research on proxy proposals and voting recommendations in accordance with the voting policies. As noted above, the need for additional transparency has been raised particularly around issues of exec.
77e, 77f, 77g, 77j, 77s(a), and 77z-3, Sections 10(b), 13, 15(d), 23(a), and 36 of the Exchange Act 15 U. Disclose How to Obtain Voting Information4. In most cases, clients give these advisers authority to vote proxies relating to equity securities. In he joined SEB Investment KVG as Head of Equity Fund Management and Quantitative Fund Management. Without a robust. Investment advisers registered with us have discretionary authority to manage trillion of assets on behalf of their clients, including large holdings in equity securities.
Agency: Securities and Exchange CommissionAction: Final ruleSummary: The Commission is adopting a new rule and rule amendments under the Investment Advisers Act of 1940 that address an investment adviser&39;s fiduciary seb investment management proxy voting obligation to its clients when the adviser has authority to vote their proxies. The new rule requires an investment adviser that exercises voting authority over client proxies to adopt policies and procedures reasonably designed to ensure that the adviser votes proxies in the best. Consideration of Promotion of Efficiency, Competition, and Capital FormationVIII. In addition, many institutional investors hist.
Just as investment advisers are required to disclose potential conflicts, whether or not they currently exist, conflicts of interest that may arise for proxy advisors should be disclosed in order for their clients to seb investment management proxy voting assess for themselves the effect and materiality of any actual or potential conflicts of interest with respect to a voting recommendation. The effective date of these amendments is Ap. seb investment management proxy voting corporate equity. Proxy advisors should disclose how they determine that their voting policies and methodologies are consistent seb investment management proxy voting with seb investment management proxy voting the investor’s best interests, including addressing any new or additional empirical studies or evidence on the subject of voting issues and the company’s long-term value. See full list on corpgov. Resolving Conflicts of Interest3. Amending Rule 14a-1(l) to clarify that “solicitation” includes any proxy voting advice that makes a recommendation to a shareholder as to its vote, consent or authorization on a specific matter for which shareholder approval is solicited, and that is furnished by a person who markets its expertise as a provider of such advice, separately from other forms of investment advice, and sells such advice for a fee is consistent with the Commission’s interpretation of the term “solicitation” as it is.
Advisers are thus in a p. We are adopting amendments to rule 204-2 pursuant to the authority set forth in sections 2(4) of the Advisers Act 15 U. We also engage the research and voting services of well-respected independent proxy advisors that share our opinions on many governance topics. 1 Fred Alger Management, LLC Weatherbie Capital, LLC Proxy Voting Policies and Procedures Effective as of Purpose Ruleof the Investment Advisers Act of 1940, as amended (the “Advisers Act”) requires. GSAM Proxy Voting Guidelines Summary The following is a summary of the material GSAM Proxy Voting Guidelines (the “Guidelines”), which form the substantive basis of GSAM’s Policy and Procedures on Proxy Voting for Investment Advisory Clients (the “Policy”). Rule 204-2, RecordkeepingIII. 4 The first section of this document outlines our proxy voting principles.
Neither ISS nor Glass Lewis fully discloses the methodologies used to develop their voting recommendations. Fidelity will vote its proxy on a case-by-case basis in a contested election, taking into seb investment management proxy voting consideration a number seb investment management proxy voting of factors, amongst others: 1. Annually, our Investment Stewardship Committee reviews and sets standards for identifying material conflicts with respect to proxy voting and corporate engagement — including whether a company is a significant client, lender or vendor of the firm — and publishes those to individuals involved in the proxy voting process. Because proxy voting decisions can affect investment outcomes for millions of retail investors, it is vitally important that our proxy voting system is as transparent, accurate and efficient as possible.
Cost-Benefit AnalysisV. The FRFA discusses the need for, and objectives of, the new rule and rule amendments that require certain advisers to adopt proxy voting policies and procedures and ma. The Commission is adopting amendments to Forms N-1A, N-2, N-3, and N-CSR pursuant to authority set forth in Sections 5, 6, 7, 10, 19(a), and 28 of the Securities Act 15 U. 36 The titles for the collections of information are &92;&92;"Proxy Voting by Investment Advisers&92;&92;" and &92;&92;"Books and Records to be Maintained by Investment Advisers. Use of Proxy Advisory Services. The amendments we are adopting will require funds to provide disclosure about how they vote proxies of the portfolio securities they hold. Wellington Management lobal ro Voting uidelines 3 Adopt proxy access We generally support proposals that allow significant and long-term shareholders the right to nominate director candidates on management’s proxy card. Describe Policies and ProceduresB.
Management’s track record and strategic plan for enhancing shareholder value; 2. Effective DateIV. 78j(b), 78m, 78o(d), 78w(a), and 78mm, and Sections 6(c), 8, 24(a), 30, and 38 of the Investment Company Act 15 U. · The Securities and Exchange Commission today voted to adopt amendments to its rules governing proxy solicitations designed to ensure that clients of proxy voting advice businesses have reasonable and timely access to more transparent, accurate and complete information on which to make voting decisions. and regulatory restrictions applicable to the dissemination of information pertaining to Morgan Stanley Investment Management&39;s investment. Today, most retail investors participate in our capital markets through mutual funds and exchange-traded funds that are offered through intermediary broker-dealers and investment advisers. 4% at the end of 1992.
This enormous voting power gives advisers significant ability collectively, and in many cases individually, to affect the outcome of shareholder seb investment management proxy voting votes and influence the governance of corporations. In cooperation with other intermediaries in the value chain – and at the express request of the large international custodian banks – in recent years SEB has worked on optimising the Danish proxy voting process. &92;&92;" The Commission submitted the new collection of information, Proxy Voting by Investment Advisers, to the Office of Management and Budget. Summary of Final Regulatory Flexibility AnalysisVII. Rules 14a-2(B)(9)(I) Conflicts of Interest Disclosures. Voting Client Proxiesb.
ISS, in particular, may have. SEB IMAB has the ambition to attend the annual general meetings of companies in which SEB IMAB represents significant ownership and/or the holding is of significance to the funds’ returns. 80b-b-6(4). 2 See Investment Company Act Release No.
The changes discussed in the Proposing Release are a significant step in the right direction and Business Roundtable appreciates the opportunity to provide our input during this process. The voting of proxies is a pillar of 1832’s active investment management approach, and a key part of the engagement process with security issuers. The Commission is sensitive to the costs and benefits resulting from its rules. Require a fund to file with the Commission and to make available to its shareholders, either on its website or upon request, its record o. Rule 14a‑9 prohibits any proxy solicitation from containing false or misleading statements with respect to any material fact at the time and in the light of the circumstances under which the statements are made.
The Fund adheres to sustainable investment proxy voting guidelines in partnership with a leading global provider. Policies and Proceduresa. The submission of matters for a vote by shareholders typically occurs in connection with a meeting of shareholders, including annual shareholder meetings and special shareholder meetings. It is one of our primary methods of exercising our shareholder rights and influencing the behavior of portfolio companies. Business Roundtable supports exceptions to this proposed rule in the case of persons who provide proxy voting advice in response to a. · The Securities and Exchange Commission today provided guidance to assist investment advisers in fulfilling their proxy voting responsibilities.
In general, matters are put forth for a shareholder vote either by the issuer 8 or by a shareholder or group of shareholders. This Proxy Voting and Governance Policy (“Proxy Voting and Governance Policy” or “Policy”), which outlines our policies for proxy voting and includes a wide range of issues that often appear on proxies, applies to all of AB’s investment management subsidiaries and investment services groups investing on behalf of clients globally. As of September, mutual funds6 held .
That being said, we may vote against a proxy access proposal if it is shareholder-sponsored and it requests that the company. SEB does, as a general rule, not provide proxy voting or other assistance services to shareholders to promote the shareholders’ participation in shareholders&39; meetings where nominee registered financial instruments are subject to Portfolio Management. · The term proxy vote refers to a ballot cast by a single person or firm on behalf of a corporation&39;s shareholder who may not be able to attend a shareholder meeting, or who may not choose to vote on. We agree with the SEC that subjecting proxy advisors to the same antifraud standard as issuers and other persons engaged in soliciting activities is appropriate in the public interest and for the protection of investors. 7 This represents a dramatic increase from only 7.
Overall, Business Roundtable is highly supportive of the SEC’s proposed changes to the rules for proxy voting advice outlined in the Proposing Release. We exercise our right to influence the company, through attending or voting at the companies’ annual general meetings. (“Glass Lewis”), a portfolio company of the Ontario Teachers’ Pension Plan Board and Alberta Investment Management Corp. seb investment management proxy voting We manage single-niche products and full-scale tailored solutions based on our multi-boutique concept: from low risk money market funds to private equity products. · The proxy voting guidelines described below form an important part of 1832&39;s fiduciary duty to maximize the long term value of each Fund for the benefit of its security holders. Guidance Regarding Investment Advisers&39; Proxy Voting Responsibilities and Disclosures on Form N-1A, Form N-2, Form N-3, and Form N-CSR III.
Proposed Amendments. 1 Unless otherwise noted, when we refer to rule 204-2 or any paragraph of the rule, we are referring to. The MFS funds have delegated proxy voting to their investment advisor, MFS Investment Management. An Initial Regulatory Flexibility Analysis (&92;&92;"IRFA&92;&92;") was published in the Proposing Release. 9 Some matters appear regularly and consistently at each annual meeting of shareholders, such as the shareholder vote on whether to ratify the issuer&39;s selection of an outside auditor. Require a management investment company registered under the Investment Company Act of 1940 (&92;&92;"fund&92;&92;") to disclose in its registration statement (and, in the case of a closed-end fund, Form N-CSR) the policies and procedures that it uses to determine how to vote proxies relating to portfolio securities; and 2. Based on the comments, we believe that this will provide funds with sufficient time to make any necessary changes to existing software and internal systems in order to compile proxy voting information in the manner that will be required by new. Proxy advisors should publish their criteria and requirements for evaluating matters subject to a vote.
Founded in Chicago in 1889, Northern Trust has offices in the United States in 19 states and Washington, D. We have also summarized below our comments on areas where we think issuers, investors and our capital markets would benefit from additional Commission action on this topic: 1. In he was appointed to the management board, a position he continued to hold even when Savills Investment Management SEB took over. Paperwork Reduction ActVI. We are adopting rule and form amendments that: 1.
Charles Schwab Investment Management, Inc. For international holdings, voting mainly takes place as proxy voting. For example, the SEC noted that if a proxy advisor were to recommend t. In conclusion, Business Roundtable is encouraged by the Commission’s proposed rulemaking to implement reasonable disclosure and procedural requirements for proxy advisors that avail themselves of certain existing exemptions from the information and filing requirements of the federal proxy rules.
Proxy Voting Policy and Procedures. An investment policy that contemplates activities intended to monitor or influence the management of corporations in which the plan owns stock is consistent with a fiduciary&39;s obligations under ERISA where the responsible fiduciary concludes that there is a reasonable expectation that such monitoring or communication with management, by the plan alone or together with other shareholders, is. 604, and relates to the Commission&39;s rule and form amendments under the Securities Act, the Exchange Act, and the Investment Company Act to require funds to provide disclosure about how they vote proxies of portfolio securities they hold. Therefore, it is important that proxy advisors not omit the disclosure of information underlying the basis of their advice or which would affect its analysis and judgments. Advisers must comply with the new rule and amendments within 180 days after publication. The investment stewardship team can be emailed at Proxy Voting Committee includes Investment Management Professionals who have significant experience in evaluating issues presented by shareholder proposals including those related to environmental matters. OIM’s sustainable voting policy generally references globally recognized sustainability-related initiatives such as the Principles for Responsible Investment seb investment management proxy voting (PRI).
Upon request, ATBIM will provide a copy of the most recent proxy voting record and/or proxy voting policies and procedures to unitholders of the ATBIS Pool Funds. Registered management investment companies must file their first report on Form N-PX not later than Aug, for the twelve-month period beginning J, and ending J. Also by this date, advisers must have provided clients with a description of their policies and procedures, and disclosure of how the clients may obtain information from the advise. As a result, Fidelity generally will vote in support of management of companies in which the funds’ assets are invested. 1 We do not edit personal identifying information, such as names or e-mail addresses, from electronic submissions. Capital Gains Research Bureau, Inc. List of Subjects in 17 CFR Part 275Reporting and recordkeeping requirements, Securities For the reasons set out in the preamble, Title 17, Chapter II of the Code of Federal Regulations is amended as follows:PART 275 — RULES AND REGULATIONS, INVESTMENT ADVISERS ACT OF 19401.
10 Other matters, such as shareholder votes on prop. By this seb investment management proxy voting date, advisers subject to the new rule must have adopted and implemented seb investment management proxy voting the required proxy voting policies and procedures. This disclosure will be. These funds own 70 percent of all public company shares in the United States, and the investment advisers to these funds have a fiduciary duty to vote proxies in the best interest of the funds they advise. No comments were received on the IRFA.
Rule, Proxy Voting1. Under the amendments, a fund will be required to disclose in its registration statement the policies and procedures that it uses to determine how to vote the pr. The Investment Stewardship Committee is composed of senior executives, officers, directors, and members of the portfolio management team and is responsible for administering Dimensional’s proxy voting policy, considering complex proxy voting cases, and overseeing the Investment Stewardship Group. of the Code of Federal Regulations as adopted by this release. Voting rights in foreign companies are primarily exercised through proxy voting. · "We believe proxy voting is a great way to integrate investment stewardship responsibilities with investment management practices," Vanguard Chairman and CEO Tim Buckley said in a news release. As explained in the Proposing Release, certain provisions of the amendments contain &92;&92;"collection of information&92;&92;" requirements within the meaning of the Paperwork Reduction Act of 1995 (&92;&92;"PRA&92;&92;") 44 U.
Active Ownership is the main way we communicate with the companies we invest in. Proxy voting and engagement. We are adopting new rulepursuant to our authority seb investment management proxy voting set forth in sections 206(4) and 211(a) of the Advisers Act 15 U. While investment advisers typically exercise proxy voting authority as part of their discretionary management of client securities, the federal securities laws do not specifically address how advisers must exercise this power. 80b-6(4) and 80b-11(a). 7 In various contexts, and in respect of a wide range of matters submitted to shareholders for a vote, investment advisers that have agreed to take on proxy voting authority are called upon to make voting determinations.
with the Asset Management Group and other internal stakeholders. 80a-6(c), 80a-8, 80a-24(a), 80a-29, and 80a-37. MFS casts all proxy votes in what it believes to be in the best long-term economic interest of its shareholders pursuant to the MFS Proxy Policies and Procedures, which have been approved by the funds&39; boards of Trustees. · The Securities and Exchange Commission (SEC) recently issued additional guidance to investment advisers pertaining to proxy voting, including the fiduciary duty under Ruleof the Investment Advisers Act of 1940 (the Advisers Act), and required disclosures under the Investment Company Act of 1940 (the Investment Company Act).
The Proxy Manager will deal directly with the proxy voting service and, in the case of proxy questions referred by the proxy voting service, will solicit voting recommendations and instructions from the Office of the Trustees, the Chair of the Board Policy and Nominating Committee, and Putnam Management&39;s investment professionals, as appropriate. Northern Trust Corporation (Nasdaq: NTRS) is a leading provider of wealth management, asset servicing, asset management and banking to corporations, institutions, affluent families and individuals. New ruleand seb investment management proxy voting the amendments to rule 204-2 are effective thirty days after publication. 604, regarding ruleand amendments to rule 204-2.
8 Millions of individual American investors, in turn, hold shares of equity mutual funds, relying on these funds -- and the value of the corporate securities in which they invest -- to fund their retirements, their childrens&39; educations, and their othe. 180,interpreting section 206 of the Advise. See full list on sec. The proposed rule includes examples of statements that may be false or misleading, including the use of seb investment management proxy voting standards that materially differ from relevant standards or requirements that the Commission sets or approves. The Commission is adopting new rule 30. The Commission has prepared a Final Regulatory Flexibility Analysis (&92;&92;"FRFA&92;&92;"), in accordance with 5 U. Asset management We manage in excess of 100 billion euro worth of assets, making us one of the largest commercial asset managers in Scandinavia. The Proposing Release generated significant comment and public interest.
A fund will be required to disclose in its registration statement the policies and procedures that it uses to determine how to vote proxies relating to portfolio securities, and to include disclosure about the availability of the fund&39;s proxy voting record. Our investment stewardship team has decades of experience researching, analyzing, and advising on proxy issues. Proxy advisors offer little transparency into their internal standards, procedures, and methodologies. As a result, it is not possible to determine the degree to which any factors, including pressure to conform to the agenda of large clients of the proxy advisors and the demand for proxy advisor consulting services, are driving updates to voting guidelines.
This information is an aggregated summary of the voting records by the Portfolio Advisor and sub-advisors on behalf of the ATBIS Pool Funds for the period J and J. The Commission is sensitive to the costs and benefits imposed by its rules. We believe the proposed amendments will appropriately inform investors of conflicts of interest and of any errors or incomplete information in proxy voting advice, while helping to ensure that proxy advisor voting recommendations do not contain false or misleading information. This Final Regulatory Flexibility Analysis (&92;&92;"FRFA&92;&92;") has been prepared in accordance with 5 U. Voting Where clients of UBS Asset Management have delegated to us the discretion to exercise the voting rights for shares they beneficially own, we have a fiduciary duty to vote such shares in the clients’ best interest and in a manner which achieves the best economic outcome for their investments. Governance Activities 1. New ruleis designed to ensure that advisers that have proxy voting authority vote clients&39; securities in the clients&39; best interest and provide clients with information on how thei.
Pursuant to the Congressional Review seb investment management proxy voting Act,59 the Office of Information and Regulatory Affairs has designated this guidance as not a “major rule,” as defined by 5 U.
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