Our Proxy Voting Guidelines are used to vote the proxies of all holdings in North America, while we utilize the ISS SRI guidelines for international holdings. NEI retains the right to vote proxies and regards the proxies we hold on behalf of our unit holders as significant corporate assets. We make use of external research providers for proxy voting analysis. Our ESG analysts review proxy information and third-party analysis and execute the proxy voting process for our funds. Items on the agenda are individually reviewed and analyzed. The final voting decision is influenced by our guidelines, internal analysis and consideration of how we believe we can best advance corporate governance good practice at each company.
The guidelines are designed to be responsive to a wide range of issues that can be raised in proxy situations. Because we cannot anticipate every proxy item, as well as specific guidelines for certain commonly-arising matters, we have established general principles for assessing proposals. Many proposals require case-by-case vote decision-making. In these situations, we look to our ESG Program criteria and corporate engagement goals for direction.
Our guidelines are oriented to the North American markets to which we are most exposed. Some guidelines are specific to certain focus markets, and we may modify our approach on a case-by-case basis, depending on the level of compliance to local market laws and corporate governance best practices that a company demonstrates.
Because of our strong position on many ESG issues, we frequently vote against the recommendations put forward by company management. However, we see no value in voting against management for its own sake. Where we are able to vote with management because standards of governance are improving, we view that outcome positively.
Our Guidelines are reviewed every two years to determine if an update is required, based on developments in corporate governance or the regulatory landscape. We may publish amendments between full updates.
Our vote notes outline where we have made exception to our guidelines and the rationale for our decision. We collect data to be able to track exceptions, to enable us to determine if our guidelines need to be updated.