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Wells Fargo Asset Management

PRI reporting framework 2018

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

(Proxy) voting and shareholder resolutions


LEA 15. Voting policy & approach

New selection options have been added to this indicator. Please review your prefilled responses carefully.

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

15.2. Indicate what your voting policy covers:

other description

          Record retention/proxy oversight process

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


Attach document

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

WellsCap has integrated ESG factors into the proxy processes. WellsCap subscribes to the ISS Standard Guidelines, the ISS Sustainability Guidelines and the ISS Taft Hartley Guidelines. The ISS Sustainability Guidelines are proxy voting guidelines that, on matters of social and environmental importance, seek to reflect a broad consensus of the socially responsible investing community. In addition, ISS’s Sustainability Policy seeks to promote support for recognized global governing bodies encouraging sustainable business practices advocating for stewardship of environment, fair labor practices, non-discrimination, and the protection of human rights.

WellsCap has developed a structure that is designed to ensure that proxy voting is conducted in an appropriate manner, consistent with the clients’ best interest and within the framework of the firm’s Proxy Voting Policy and Procedures. Unless the client specifically reserves the right to vote their own proxies, WellsCap will vote proxies with a goal of maximizing shareholder value as a long-term investor and consistent with the governing laws and investment policies of each portfolio.


LEA 16. Typical approach to (proxy) voting decisions

16.1. Indicate how you typically make your (proxy) voting decisions.


Based on

16.2. 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).

On a weekly basis, WellsCap’s Proxy Voting administrator presents to portfolio managers a list of proxy ballots requiring upcoming votes. In addition to the ballot, the portfolio managers are provided ISS’ voting recommendations. If a portfolio manager has a voting preference it will be honored. If there is no portfolio manager voting preference and a conflict exists between ISS’ Standard and Sustainability recommendations, the conflict will be brought to the PRMA team for further review. If the issue is determined to be material, it is brought to a Proxy Voting committee discussion and a final vote.

Unlike PM-driven vote changes (which can have a split vote across strategies), we allow split voting on ESG issues only when a client has established custom proxy guidelines.

16.3. Additional information.[Optional]

LEA 17. Percentage of voting recommendations reviewed

New selection options have been added to this indicator. Please review your prefilled responses carefully.

17.1. Of the voting recommendations that your service provider made in the reporting year, indicate the percentage reviewed by your organisation, giving reasons.

Percentage of voting recommendations your organisation reviewed

Reasons for review

other description

          Lobbying payments, Political contributions, Election of directors, Executive compensation

17.2. Additional information [Optional]

On a weekly basis, a report is sent to all independent investment teams alerting them of upcoming procy votes. Ultimately all votes are available for investment teams to review. Additionally, teams with FactSet access have the opportunity to pull ISS research and recommendations independently - however these activities are currently not centrally tracked or quantified.

LEA 18. Confirmation of votes (Not Completed)

LEA 19. Securities lending programme (Private)

LEA 20. Informing companies of the rationale of abstaining/voting against management

New selection options have been added to this indicator. Please review your prefilled responses carefully.

20.1. Indicate whether you or the service providers acting on your behalf raise any concerns with companies ahead of voting

          These cases are situational and typically involve where we disagree with management or believe there are facts missing.

20.2. Indicate whether you and/or the service provider(s) acting on your behalf, communicate the rationale to companies, when , you abstain or vote against management recommendations.

20.3. Additional information. [Optional]

Outputs and outcomes

LEA 21. Percentage of (proxy) votes cast

21.1. For listed equities where you and/or your service provider have the mandate to issue (proxy) voting instructions, indicate the percentage of votes cast during the reporting year.

Votes cast (to the nearest 1%)

98 %

Specify the basis on which this percentage is calculated

21.2. Explain your reason(s) for not voting certain holdings

21.3. Additional information. [Optional]

LEA 22. Proportion of ballot items that were for/against/abstentions

22.1. Indicate if you track the voting instructions that you and/or your service provider on your behalf have issued.

22.2. Of the voting instructions that you and/or third parties on your behalf issued, indicate the proportion of ballot items that were:

Voting instructions
Breakdown as percentage of votes cast
For (supporting) management recommendations
91.9 %
Against (opposing) management recommendations
7.9 %
0.2 %

22.3. Describe the actions you take in relation to voting against management recommendations.

          A weekly report is sent to investment teams highlighting vote recommendations that have a vote against management. Further research and discussions expressing concern on votes against management are documented for audit purposes.

22.4. Additional information. [Optional]

LEA 23. Shareholder resolutions (Not Completed)

LEA 24. Examples of (proxy) voting activities (Not Completed)