Compliance: Proxy Policy






Proxy Voting Policy and Procedures

Many Bradley, Foster & Sargent, Inc. clients have requested that we vote proxies on their behalf while other clients prefer to undertake the responsibility themselves. Our Proxy Voting Policy and Procedures documents Bradley, Foster & Sargent, Inc.’s policies and procedures for voting proxies for our clients.

Proxy Voting Policy

Bradley, Foster & Sargent, Inc. strives to vote proxies in a manner which is in the best interest of its clients. In general, this means that we review the proxy material carefully and vote in the manner which, according to our judgment, will be most beneficial to the company’s shareholders. While this often means voting with management, there are instances when it is in the clients’ best interest to vote against management. Generally, the Chief Financial Officer, with the advice and consent of the President, makes the decision on how to vote.

We also have established a Proxy Voting Committee which consists of the President, Chief Financial Officer, and the Senior Operations Officer. In cases where it is difficult to decide, or where possible conflicts of interest occur, the Chief Financial Officer brings the conflict to the attention of the Proxy Voting Committee. Examples of such a conflict might include: where Bradley, Foster & Sargent, Inc. employees have a close, personal relationship with management; where a Bradley, Foster & Sargent, Inc. employee serves on the Board of Directors of the company in question; or where Bradley, Foster & Sargent, Inc. manages pension fund assets for the company in question. Upon thorough review of a proxy in question, the Proxy Voting Committee will decide whether to vote for or against management.

Clients Interested in Voting Proxies

If clients who have given the authority to Bradley, Foster & Sargent, Inc. to vote proxies on their behalf wish to change their approach and vote all proxies themselves, Bradley, Foster & Sargent, Inc. will send, upon the clients’ request, the appropriate documentation to the clients so they can vote proxies themselves.

Disclosure of Proxy Voting Record

Bradley, Foster & Sargent, Inc. is obligated to disclose how it has voted on any particular proxy to any client upon his or her written request. To obtain this information, clients are requested to contact Stephen L. Willcox by mail at Bradley, Foster & Sargent, Inc., CityPlace II, 11th Floor, 185 Asylum Street, Hartford, CT 06103, by email at or by telephone at (860) 241-4626.

Recordkeeping

Bradley, Foster & Sargent, Inc. maintains proxy voting records at its office in Hartford for at least two years and in another facility with reasonable access for an additional three years.

Disclosure of Proxy Voting Policies

Bradley, Foster & Sargent, Inc. discloses its Proxy Voting Policy and Procedures in SEC Form ADV, Part II, Schedule F, Item #1.D.

We may amend our Proxy Voting Policy and Procedures from time to time. As required by law, we will send our current clients any such changes.

       
 
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