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Columbia Management Investment Advisers, LLC

PRI reporting framework 2017

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage (Not Completed)


SG 02. Publicly available RI policy or guidance documents (Not Completed)


SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

We have a compliance program in place that is intended to identify, mitigate and, in some instances, prevent actual and potential conflicts of interest, as well as to ensure compliance with legal and regulatory requirements and ensure compliance with client investment guidelines and restrictions. Our compliance program includes written policies and procedures that we believe are reasonably designed to prevent violations of applicable law and regulations.

The firm addresses conflicts of interest and how conflicts are managed through multiple policies within its Compliance Program as disclosed in its Form ADV, Part 2A. Additional information about Columbia Management Investment Advisers, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov.

03.3. Additional information. [Optional]

Specific to voting proxies on behalf of clients, we seek to carry out our responsibilities without undue influence from individuals or groups who may have an economic interest in the outcome of a proxy vote, and we have implemented practices reasonably designed to identify potential material conflicts of interest. One way that we seek to address potential material conflicts of interest is through employing predetermined voting guidelines. Alternatively, if we determine that a material conflict of interest exists, we will invoke one or more of the following conflict management practices:

  • causing the proxies to be voted in accordance with the recommendations of an independent third party (which may be our proxy voting administrator or research provider);
  • causing the proxies to be delegated to an independent third party (which may be our proxy voting administrator or research provider); and
  • in unusual cases, with the client's consent and upon ample notice, forwarding the proxies to our clients so that they may vote the proxies directly. For example, with respect to proxies of Ameriprise Financial, Inc., CMIA's parent company, we vote in accordance with the recommendation of an independent third party when we are vested with proxy voting authority. Similarly, with respect to public companies with which we have a substantive relationship, we will vote such proxies following our pre-determined voting guidelines or the recommendations of an independent third party.

CMIA maintains a Proxy Voting Committee (the Committee), whose voting members are portfolio managers and analysts, which is tasked with addressing proxy voting issues for the firm. Members of this committee are prohibited from voting on any proposal for which they have a conflict of interest by reason of a direct relationship with the issuer or other party affected by a given proposal. Persons making recommendations to the Committee or its members are required to disclose to the Committee any relationship with a party making a proposal or other matter known to the person that would create a potential conflict of interest.


SG 04. Identifying incidents occurring within portfolios (Private)


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