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 are a small firm with 8 full time employees including our three portfolio managers (two are the owners). We have approximately 30-40 stocks in our portfolio and the portfolio managers vote the proxies therefore they know firsthand about the proxy votes and when making investment decisions. Portfolio Managers examine and analyze all of the proxies and make their best judgment of how to vote. Research analysts give input and recommendations on investments but voting proxies are made by the Portfolio Managers.The Portfolio managers meet daily to discuss updates to the portfolio mix and status of investments. The compliance manager tracks proxies and outcomes.