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.
A proxy voting committee oversees the proxy practices of MIM-Americas investment teams. The committee is responsible for approving exceptions to the proxy voting policy as well as providing review of the overall proxy voting policy and oversight of our proxy voting service provider.
Proxy voting decisions are determined at the division level; therefore there is not a firm-wide approach to making proxy voting decisions. The answers to question LEA 12 are based on aggregated responses from multiple investment groups and are not applicable to every independent investment team.