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.