For the first year we used Glass Lewis’ policy as a template, from which we have adapted our own in-house policy. The polices focuses on: transparency and communications; corporate culture; strategy; financial disciplines, structure and management; stakeholders, environmental and social issues; and governance. They are influenced by following what is considered to be best practice in each country taking into account local guidelines and governance codes.
In most cases, Glass Lewis vote with management. Where Glass Lewis recommend that we vote in line with management, the vote will go through automatically. The Corporate Actions Team create a report for the Stewardship & Responsible Investment Group (SRIG) for any company meeting where the Glass Lewis recommendation is to vote against management. Where they recommend to vote against management, SRIG asses the information, pass it to the relevant direct/ investment trust analyst and/or the Investment Process Committee if necessary for advice prior to the final decision. The SRIG and all investment analysts have access to the Glass Lewis voting platform. All votes will have a deadline of 72 hours before the meeting, to allow time for Glass Lewis to send Broadridge the voting instructions and for Broadridge to then submit the votes. Broadridge carry out the electronic voting instructions.
In keeping with our commitment to the UK Stewardship Code and UN PRI, we are mindful of the need to be transparent in our voting. S&W keep a record of all engagement and voting activity which is updated quarterly and available on our website, we also produce an annual report containing these figures. Where S&W decide to vote against or abstain from voting in favour a management proposal we write to the management explaining our reasons, opening up a dialogue with the company. Where we receive additional information from the company pertaining to any issues raised, we may, if appropriate, amend our vote.