Under rule 206(4)-6, it is a fraudulent, deceptive, or manipulative act, practice or course of business within the meaning of section 206(4) of the Act for an investment adviser to exercise voting authority with respect to client securities, unless:
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the adviser has adopted and implemented written policies and procedures that are reasonably designed to ensure that the adviser votes proxies in the best interest of its clients |
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the adviser describes its proxy voting procedures to its clients and provides copies on request, and |
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the adviser discloses to clients how they may obtain information on how the adviser voted their proxies. |
When Do These Procedures Apply
Cornerstone will apply these policies and procedures when it has either discretionary authority on an account (and proxy voting has not been otherwise delegated) or when it has specifically agreed in writing with the client to exercise proxy voting authority over the client’s securities.
Voting Client Proxies
Clients can be assured that Cornerstone will be acting in the best economic interests of the client when considering proxy votes; however, the firm will always abide by separate agreements in place with the client, if any, as well as any applicable statutory requirements. Cornerstone has informed all relevant third parties to forward proxies to the firm, and follow-up letters or telephone calls are made, if necessary, to follow-up on this request.
Cornerstone will contact the client upon finding a potential conflict of interest that may exist in voting their proxies. Only after this conflict is disclosed and client consent is received will the firm proceed with casting the vote.
Disclosures
If requested by the client, Cornerstone will fulfill its obligation, under Rule 206 (4)-6 of the Adviser’s Act, and furnish the client with the actual proxy votes cast on their behalf.
If requested by the client, Cornerstone will fulfill its obligation, under Rule 206 (4)-6 of the Adviser’s Act, and furnish the client with a copy of the firm’s full policies and procedures regarding proxy voting.
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