During our annual review of Clarion's proxy guidelines, CBRE Clarion's Head of ESG, who is the senior investment professional in change of the proxy voting process, will keep track of items from the prior year's proxy season where we may have had to clarify our guidelines, and determine if we want to propose any changes to current guidelines. Additionally, we receive updates from the proxy service providers outlining any changes that they are making to their recommendations for the coming year. The Head of ESG, senior portfolio managers and our CEO discuss CBRE Clarion's stance on those issues, and a determination is made as to whether we will make any changes to CBRE Clarion's guidelines on those particular items. Any changes to CBRE Clarion guidelines are recorded with our service provider. Analysts are informed of the new updates to the guidelines at the beginning of the year.
The voting process is carried out by the individual analyst for that analyst's coverage universe, with oversight from the Head of ESG. An associate from our operations team with responsibility for proxy administration provides the analysts with the third party research reports, as well as an summary of the CBRE Clarion guidelines pertaining to the particular items up for vote. The CBRE Clarion analyst reads through the research as well as the public proxy filing, and votes the items. The CBRE Clarion analyst communicates the vote to the operations associate, and the Head of ESG and senior portfolio managers are copied on all communication. The CBRE Clarion analyst who is voting, plus a designated senior member of the investment team both must sign off on any votes that go against CBRE Clarion's internal guidelines. It is a formal document with the name of the company, the ballot item, the vote, and the reason for going against CBRE Clarion guidelines. The document is maintained by our compliance department.