Mellon recognizes its duty to vote proxies in the best interests of its clients. In all cases, the ultimate decision and responsibility for voting shares held for Mellon's clients rests with with Mellon.
The Committee, within which Mellon has a leadership role, developed its Voting Guidelines with the assistance of internal and external research and recommendations provided by third party vendors but without consideration of any BNY Mellon client relationship factors. All proxy voting proposals are reviewed, categorized, analyzed and voted in accordance with the Voting Guidelines. As a Committee member, Mellon participates in the application of detailed, pre-determined proxy voting guidelines (the “Voting Guidelines”) in an objective and consistent manner across client accounts.
The guidelines are reviewed at least annually, but more frequently if necessary, and updated to reflect new issues in the marketplace and any changes in our policies on specific issues. Under the guidelines, voting proposals that can be categorized will be voted accordingly: proposals less easily categorized will be referred to the Committee for a vote discussion and decision. Additionally, the Committee may review any proposal type, company, industry for special scrutiny.