Cape Ann's custodian holds all securities for the benefit of the Unitholders in Cape Ann’s various commingled funds. Cape Ann has directed Northern Trust to outsource certain of its proxy processing responsibilities to ISS, a leading provider of proxy voting. ISS provides Cape Ann with meeting notification and ballot delivery services, agenda summaries, detailed agenda content including original source documents, translation services, recordkeeping and custom reports and vote instruction processing services. Meeting notifications are provided according to an agreement in place between the Cape Ann and ISS. Cape Ann does not outsource any part of its proxy voting decision making process to ISS or Northern Trust. Separate arrangements may be in place for the custodians appointed by any permanent separately managed account relationships.
Following receipt of proxy voting materials from ISS, Cape Ann’s administration group prepares a “Proxy Voting Summary Form”. The form includes the details of the number of shares held by a Client and a deadline for the response. If only standard issues are included on the proxy, one authorised person will decide on how to vote the proxy and sign the proxy voting summary form. If material issues are included, enhanced procedures apply. The issue will be discussed with two or more authorised personnel and they will assess the potential impact that the issues may have on the portfolio company, and decide on how to vote the proxy in question. The proxy voting summary form will then be approved and the proxy vote processed.
Cape Ann's proxy voting process is also subject to periodic internal risk monitoring review conducted by the compliance.