To help make sure Ardevora vote client proxies in accordance with this policy and in the best interests of its clients, Ardevora have established a Responsible Investment Committee ("RIC") which, inter alia, is responsible for overseeing the proxy voting process. The RIC meets quarterly and is made up of senior members of staff, including the CEO, Head of Compliance, a representative from Portfolio Management, and an observer from Client Services.
One of the responsibilities of the RIC is to review and approve Ardevora's Proxy Voting policy and associated procedures on a yearly basis. It is usually reviewed during the first quarter of the calendar year before the beginning of the “proxy voting season” and may also be reviewed at other times of the year, as necessary. When reviewing the policy, the RIC will ensure the policy and procedures are designed to allow Ardevora to vote proxies in the best interests of its clients and to maximize the value of the underlying shares being voted on.
Glass Lewis & Co ("Glass Lewis") have been retained by Ardevora as its Proxy Administrator to vote all proxies in line with their proxy voting guidelines, which can be viewed at: www.glasslewis.com/guidelines.