Mellon Capital recognizes its duty to vote proxies in the best interests of its clients. In all cases, the ultimate voting decision and responsibility rests with the Member Firms of the PVGC which are accountable to their clients.
The PVGC developed its Voting Guidelines with the assistance of internal and external research and recommendations provided by third party vendors but without consideration of any BNY Mellon client relationship factors. All proxy voting proposals are reviewed, categorized, analyzed and voted in accordance with the Voting Guidelines. As a PVGC member, Mellon Capital participates in the application of detailed, pre-determined proxy voting guidelines (the “Voting Guidelines”) in an objective and consistent manner across client accounts.
The guidelines are reviewed periodically and updated to reflect new issues in the marketplace and any changes in our policies on specific issues. Under the guidelines, voting proposals that can be categorized will be voted accordingly: proposals less easily categorized will be referred to the Committee for a vote discussion and decision. Additionally, the PVGC may review any proposal type, company, industry for special scrutiny.
Lastly, in certain circumstances the PVGC engages an independent fiduciary for voting the proxies issued by BNY Mellon and by any individual fund within The Dreyfus Family of Funds or The BNY Mellon Funds, or to vote proxies issued by other companies.