Our full policy is contained within our RI policy referenced in SG 02. In brief, we adhere to the following procedure:
- In line with our normal practice, engagement and proxy voting decisions are agreed between the Governance & Responsible Investment team and relevant fund managers, in line with our policies and procedures.
- Where decisions involve a pragmatic application of or deviation from our headline policy and guidelines that is documented and the explanation and rationale recorded.
- I n the event of a controversial issue, that is escalated, initially to the relevant desk heads. The final arbiter in such cases would be Columbia Threadneedle Investments’ Head of Equities, Chief Investment Officer or Investment COO.
- Where issues require escalation, our legal and compliance teams are consulted as appropriate.
- Arrangements and procedures are maintained to monitor potential conflicts of interest and regular reports are submitted to senior management and the compliance team on the operation of these arrangements.
- The overriding test at each stage of this process is that the approach and actions taken must be in the interests of those clients on whose behalf they are being taken and consistent with our TCF (‘treating customers fairly’) obligations.