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Wells Fargo Asset Management

PRI reporting framework 2018

Export Public Responses

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


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]