VanEck intends to vote all proxies in accordance with applicable rules and regulations, and in the best interests of clients without influence by real or apparent conflicts of interest. To assist in its responsibility for voting proxies and the overall voting process, it has engaged an independent third party proxy voting specialist, Glass Lewis & Co., LLC. The services provided by Glass Lewis include indepth research, global issuer analysis, and voting recommendations as well as vote execution, reporting and recordkeeping.
While it is VanEck’s policy to generally follow the Glass Lewis Proxy Guidelines, it retains the right, on any specific proxy, to vote differently from those guidelines, if it believes it is in the best interests of its clients. Any such exceptions will be documented by VanEck and reviewed by its Chief Compliance Officer.
The portfolio manager or analyst covering the security is responsible for making proxy voting decisions.