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ClariVest Asset Management LLC

PRI reporting framework 2018

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).

As a default, proxies are generally voted by ISS in accordance with ISS recommendations. However, ClariVest retains ultimate decision making authority with respect to the voting of Client proxies and reserves the right to override ISS recommendations. 

ClariVest’s investment personnel shall be responsible for making voting decisions with respect to all Client proxies, where a proxy is not voted in accordance with ISS recommendations.  Such decisions shall then be provided to the Operations Manager who will then ensure that such proxy votes are submitted in a timely manner.

16.3. Additional information.[Optional]

LEA 17. Percentage of voting recommendations reviewed (Not Applicable)

LEA 18. Confirmation of votes (Not Completed)

LEA 19. Securities lending programme (Not Completed)

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

          a.	ISS will engage with an issuer if questions arise regarding the information contained in a proxy filing, or other filing related to the agenda / meeting.
b.	ISS will engage with an issuer if additional information is needed ahead of a meeting; only publicly available information will be used in the completion of ISS analyses.
c.	ISS will engage with both Management and Dissidents for all proxy contests.
d.	ISS will engage with an issuer if questions arise regarding the information contained in an analysis, etc.

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.

          a.	All issuers are entitled to a complimentary copy of the ISS benchmark analysis for their upcoming meeting(s) upon request.
b.	For certain indices/markets, ISS will provide a draft copy of the analysis prior to publication to allow for review of the facts presented within the document.

20.3. Additional information. [Optional]