LSV has developed internal processes to ensure all ballots have been received by Glass Lewis for voting. This includes daily holdings reconciliation, weekly analysis of ballot receipt for all active accounts and weekly analysis of any holdings gaps. LSV works with Glass Lewis to ensure all eligible votes are cast and new accounts are on-boarded properly. LSV reviews Glass Lewis' SOC 1, or comparable, report to gain assurance that all votes are cast and cast according to policy. In addition, on a semi-annual basis, LSV sends Glass Lewis a questionnaire asking them to confirm that they have policies and procedures in place to monitor conflicts of interest, ensure that their proxy voting recommendations were based on correct and accurate information and that their policies and procedures were reasonably designed to avoid errors.