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Pareto Asset Management AS

PRI reporting framework 2020

You are in Direct - Listed Equity Active Ownership » (Proxy) voting and shareholder resolutions

(Proxy) voting and shareholder resolutions

LEA 12. Typical approach to (proxy) voting decisions

12.1. Indicate how you typically make your (proxy) voting decisions.

Approach

Based on

12.2. 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.

Voting requires authorisation/poa from the CIO. In the case of possibly controversial issues, voting would at least be cleared by the CIO and possibly by the CEO or the board.

12.3. Additional information.[Optional]

Voting generally follows a discussion with the CIO or the ethics committee.


LEA 13. Percentage of voting recommendations reviewed (Not Applicable)


LEA 14. Securities lending programme (Private)


LEA 15. Informing companies of the rationale of abstaining/voting against management

15.1. Indicate the proportion of votes participated in within the reporting year in which where you or the service providers acting on your behalf raised concerns with companies ahead of voting.

15.2. Indicate the reasons for raising your concerns with these companies ahead of voting.

15.3. Additional information. [Optional]

We would be doing a poor job if our vote came as a surprise. In general, we would expect it to be cast after preceding dialogue. 


LEA 16. Informing companies of the rationale of abstaining/voting against management

16.1. Indicate the proportion of votes where you, and/or the service provider(s) acting on your behalf, communicated the rationale to companies for abstaining or voting against management recommendations. Indicate this as a percentage out of all eligible votes.

16.2. Indicate the reasons why your organisation would communicate to companies, the rationale for abstaining or voting against management recommendations.

16.3. In cases where your organisation does communicate the rationale for abstaining or voting against management recommendations, indicate whether this rationale is made public.

16.4. Additional information. [Optional]

We have no policy of formally flagging our voting intentions ahead of the vote. On the other hand, it is not precluded. Would be judged on a case-by-case basis.


LEA 17. Percentage of (proxy) votes cast

17.1. For listed equities in which you or your service provider have the mandate to issue (proxy) voting instructions, indicate the percentage of votes cast during the reporting year.

17.2. Explain your reason(s) for not voting on certain holdings

Issues of limited materiality, like approving ok accounts in a small holding. As for administrative impediments, it is sometimes exceedingly cumbersome to vote in foreign countries.

17.3. Additional information. [Optional]

We limit our voting to issues of some presumed importance and do not count all issues on the table.


LEA 18. Proportion of ballot items that were for/against/abstentions

18.1. Indicate whether you track the voting instructions that you or your service provider on your behalf have issued.

18.2. Of the voting instructions that you and/or third parties on your behalf have issued, indicate the proportion of ballot items that were:

Voting instructions
Breakdown as percentage of votes cast
For (supporting) management recommendations
75 %
Against (opposing) management recommendations
25 %
Abstentions
0 %
100%

18.3. In cases where your organisation voted against management recommendations, indicate the percentage of companies which you have engaged.

25

18.4. Additional information. [Optional]

Votes would never be cast without preceding discussions with the portfolio managers, so there is no need to communicate our votes to them. We don't track these votes in terms of percentages, so the above percentages are rough approximations. In cases where we vote against management recommendations, we may nevertheless cast votes in favor of, say, approving the accounts.


LEA 19. Proportion of ballot items that were for/against/abstentions

19.1. Indicate whether your organisation has a formal escalation strategy following unsuccessful voting.

19.3. Additional information. [Optional]

We are not likely to give up after a negative response, but we have no board-approved guidelines for escalation.


LEA 20. Shareholder resolutions (Private)


LEA 21. Examples of (proxy) voting activities (Private)


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