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PRI reporting framework 2020

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(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.

The objective of our voting policy is to express an independent opinion through voting, according to the engagement and RI policies of Trecento AM. It can be implemented in a individual or collective way (concerted actions, in accordance with local laws/rules) and in investors' best interest.

The principales and specific guidelines of the voting policy of Trecento AM ensure that the fund managers who vote, based on analysts' recommendations, can rely on an agreed-upon voting policy. The votes are reviewed by the risk controller before submission to verify whether they are compliant with the company policy. As regard topics or resolutions not specified in the voting policy, the fund managers and analysts usually discuss these to formalise an opinion in respect to our RI general approach.

Exceptions to the voting policy can be made by fund managers or the ESG committee, upon recommendations from the analysts.

12.3. Additional information.[Optional]

The potential conflicts of interest that could impact the free exercise of voting rights are strictly managed by the internal conflict management procedure.


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.

15.3. Additional information. [Optional]


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.

16.4. Additional information. [Optional]


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.

Votes cast (to the nearest 1%)

0 %

Specify the basis on which this percentage is calculated

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

In 2019, the voting policy of Trecento AM was to not exercise our voting rights if the managed funds hold less than 3% of the capital of the company.

17.3. Additional information. [Optional]

Our voting policy has been modified in 2020, in accordance with our updated RI approach, to strengthen our voting policy. We plan to exercice our voting rights more often in 2020.


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
0 %
Against (opposing) management recommendations
0 %
Abstentions
100 %
100%

18.4. Additional information. [Optional]


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.

19.2. Indicate the escalation strategies used at your organisation following abstentions and/or votes against management.

19.3. Additional information. [Optional]


LEA 20. Shareholder resolutions

20.1. Indicate whether your organisation, directly or through a service provider, filed or co-filed any ESG shareholder resolutions during the reporting year.

20.7. Additional information. [Optional]


LEA 21. Examples of (proxy) voting activities (Not Completed)


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