Provide an overview of how you ensure that your agreed-upon voting policy is adhered to, giving details of your approach when exceptions to the policy are made.
We use the services of an external service provider to complement our internal research and processes. Each analyst is responsible for voting all proxies for companies under their coverage. These proxies are then sent to a Senior Portfolio Manager for final approval before the votes are cast. The Senior Portfolio Manager challenges the analyst's recommended vote whenever warranted. In cases where LBA decides to submit a vote which goes against its Proxy Voting Policy, this information will be reported to the Compliance Team in an annual Vote Against Policy report.