This report shows public data only. Is this your organisation? If so, login here to view your full report.

Wellington Management Company LLP

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).

The Investment Stewardship Committee oversees all activities related to proxy voting and the integration of Environmental, Social, and Governance (ESG) considerations in the management of client portfolios, and the ESG Research Team reports to the Investment Stewardship Committee quarterly regarding the firm’s proxy voting activities. The committee includes senior-level and experienced professionals from portfolio management, investment research, relationship management, and legal and compliance globally.

16.3. Additional information.[Optional]

While the ESG Research team provides proxy voting recommendations on contentious votes, the portfolio manager for the client account has the authority to decide the final vote in the best interest of client portfolios, absent a material conflict of interest. In addition, there is no “house vote”. Our proxy voting system allows different votes to be submitted for the same security. Our firm is organized as a collection of portfolio teams — each with its own unique investment philosophy, approach, and time horizon. Consistent with this structure, various portfolio managers holding the same securities may arrive at different voting conclusions for their clients’ proxies.

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

LEA 18. Confirmation of votes

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

18.1. Describe your involvement in any projects to improve the voting trail and/or to obtain vote confirmation .

          The firm periodically reviews its position regarding specific proxy issues. In addition, the firm’s Global Proxy Policy and Procedures and Proxy Voting Guidelines are reviewed annually by our Investment Stewardship Committee and updated as necessary. 

Wellington conducts on-site due diligence visits at the offices of Glass Lewis at least annually. We review Glass Lewis’ written compliance policies and procedures on an annual basis. On a weekly and monthly basis, Wellington Management reviews ballot reconciliation reports to ensure that accounts with proxy voting rights are properly set up and that we are properly voting on behalf of our clients. The Proxy Support team has a bi-weekly standing call scheduled with our contacts at Glass Lewis to resolve any outstanding items. Finally, we review proxy voting reports as generated by Glass Lewis’ ViewPoint system to ensure votes cast are properly executed and record kept.

18.2. Additional information. [OPTIONAL]


LEA 19. Securities lending programme

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

19.1. Indicate if your organisation has a securities lending programme.

19.2. Describe why your organisation does not lend securities?

Wellington Management does not offer a securities lending program; however, the firm has no concerns about and would raise no objection to client participation in an appropriately structured securities lending program, on the assumption that it would not impact our portfolio management decisions. In fact, we assume that many of our clients are active in this market, although we are not directly involved.

19.4. Additional information.


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

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]