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West Midlands Pension Fund

PRI reporting framework 2017

You are in Direct - Listed Equity Active Ownership » (Proxy) voting and shareholder resolutions » Overview


LEA 17. Voting policy & approach

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17.1. Indicate whether your organisation has a formal voting policy.

17.2. Indicate what your voting policy covers:

17.3. Attach or provide a URL to your voting policy. [Optional]

17.4. Provide a brief overview of your organization’s approach to (proxy) voting.

The Fund uses the proxy voting agency Pension & Investment Research Consultants (PIRC) and their Corporate Governance Service for analysis of governance issues and executing its proxy voting rights across all markets in which it invests.

The Fund has its own detailed UK Corporate Governance voting guidelines which aim to deal with issues that are either not covered by the UK Corporate Governance Code, require greater emphasis or are specifically left open for shareholders to resolve with company boards.  To ensure a risk-based approach PIRC's Corporate Governance Ratings form a primary underpin to our voting policy.

For the remaining markets in which we invest, we currently endorse the international voting guidelines of PIRC. 

The Fund has an active stock lending policy and procedures to recall stock for particularly material shareholder resolutions.

17.5. Provide an overview of how you ensure your voting policy is adhered to, giving details of your approach when exceptions to the policy are made (if applicable).

Our voting is executed on our behalf by a third party service provider. We cannot analyse every resolution or every report issued on equity securities with voting rights, so we have employed a risk-based procedure to ensure we cover the resolutions attached to the largest positions, largest active positions, and companies with most material ESG risks. Through this analysis we undertake quality checks of the underlying data and determine whether our votes are set to be cast in line with our policies and guidelines. This is used as a representative sample for all our votable shares. We are satisfied with the outcomes of these quality checks and that our voting policies are being successfully applied.