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Claritas Administração de Recursos LTDA

PRI reporting framework 2019

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(Proxy) voting and shareholder resolutions

LEA 12. Typical approach to (proxy) voting decisions

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

Approach

Based on

12.3. Additional information.[Optional]

Claritas shall exercise the right to vote at general meetings representing the investment funds under its management, which is based on shareholders' and funds' interests with care and diligence required by the circumstances. Accordingly, Claritas will vote in favor of resolutions which will give value to assets that compose the portfolio of the fund.
Procedures Related to Conflicts of Interests
Claritas' performance is based on transparency with clients, ethics, compliance with legislation, and segregation of commercial and operational activities in order to avoid voting
conflicts of interest. If any conflict of interest is verified, Claritas will not exercise the right to vote at general meetings of the companies issuing the assets held by the funds. Exceptionally, Claritas may exercise the right to vote in a situation of a conflict of interest, provided that it gives notice to the shareholders of the content and a brief explanation of the vote.
The management team, under the responsibility of CIO, performs the control and execution of this policy and coordinates the decision, registration, and formalization of exercise voting rights on behalf of funds managed by managers.


LEA 13. Percentage of voting recommendations reviewed (Not Applicable)


LEA 14. Securities lending programme (Private)


LEA 15. Informing companies of the rationale of abstaining/voting against management

15.1. Indicate the proportion of votes where you or the service providers acting on your behalf have raised concerns with companies ahead of voting.

15.3. Additional information. [Optional]


LEA 16. Informing companies of the rationale of abstaining/voting against management

16.1. Indicate the proportion of votes participated in within the reporting year in which, you and/or the service provider(s) acting on your behalf, have communicated to companies the rationale for abstaining or voting against management recommendations.

16.4. Additional information. [Optional]


LEA 17. Percentage of (proxy) votes cast

17.1. 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%)

20 %

Specify the basis on which this percentage is calculated

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

17.3. Additional information. [Optional]


LEA 18. Proportion of ballot items that were for/against/abstentions

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

18.2. 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
55 %
Against (opposing) management recommendations
10 %
Abstentions
35 %
100%

18.3. In cases where your organisation voted against management recommendations, indicate the percentage of companies you have engaged.

18.4. Additional information. [Optional]


LEA 19. Proportion of ballot items that were for/against/abstentions

19.1. Indicate whether your organisation has a formal escalation strategy following unsuccessful voting.

19.3. Additional information. [Optional]


LEA 20. Shareholder resolutions (Private)


LEA 21. Examples of (proxy) voting activities (Not Completed)


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