CBRE Clarion developed a formal Engagement Policy in 2018, which was used throughout 2019. CBRE Clarion's engagement and proxy voting summary is covered in the CBRE Global Investors Responsible Investment Management Policy as well, which is available on the CBRE Global Investors website.
With regard to third party service providers for engagement, CBRE Clarion are members of GRESB. A minority of our engagement efforts are as members of GRESB in support of GRESB. We conduct the engagment ourselves but encourage companies with which we engage to complete the GRESB assessment because we believe in the assessment, and believe that companies should be paying attention to the issues that are covered in the assessment. Technically, this may be considered collaborative engagement although the letters are CBRE Clarion's own words.
CBRE Clarion subscribes to third-party sources for reference materials and proxy voting administration. Although CBRE Clarion engages a third-party to help administer the voting process, voting elections are determined by the appropriate CBRE Clarion analyst, in accordance with CBRE Clarion guidelines. Guidelines are reviewed and updated manually by CBRE Clarion's Head of ESG and senior portfolio managers. Voting elections ultimately are approved by CBRE Clarion's Head of ESG or designated senior portfolio managers. In the event that there is a vote against internal guidelines, the CBRE Clarion analyst must document the reason for the vote and a designated member of the investment team must approve the vote. CBRE Clarion discloses our proxy voting policy and guidelines on our website.