The document outlines the proxy voting policies and procedures of the Management Company in compliance with Rule 206(4)-6 under the Advisers Act. It describes the role of the Proxy Voting Committee, the use of Institutional Shareholder Services (ISS) for proxy voting recommendations, and the conditions under which the Management Company may override ISS recommendations. It also addresses potential conflicts of interest and the discretion to abstain from voting when deemed in the best interest of an account.
doj/DataSet10/EFTA01384682.pdf
{"title":"Proxy Voting Policies and Procedures","key_people":["Chief Compliance Officer","Chief Operating Officer"],"document_type":"correspondence","document_subtype":"policy document","key_organizations":["Alpha Group Capital","Institutional Shareholder Services (ISS)"],"reference_numbers":["DOC ID- 10746057.132","DB-SDNY-0085100","SDNY_GM_00231284","EFTA01384682"]}