As an investment company we represent the interests and voting rights of our fund subscribers with respect to stock corporations. We see voting rights as one of shareholders’ most valuable rights. We are therefore aware that the duty assigned to us needs to be performed responsibly.

Our actions are governed by the Code of Conduct issued by the Bundesverband Investment und Asset Management e.V. (BVI – the German Association of Investment Companies) and the German Corporate Governance Code drawn up by the Cromme Commission.

One key aspect of our voting behaviour is our demand for management transparency and timely communication with shareholders. We see this demand as the basis for enabling owners and hence co-owners to understand management’s operational and strategic decisions and hence to objectively assess its investment decisions at all times.

In turn, our aim in publishing these Voting Guidelines is to comply with requirement of transparency that we demand from others. The Guidelines were formulated on the basis of years of practical experience as well as current developments and requirements. They should be seen as a basic framework that can be applied flexibly and are designed to facilitate case-by-case decisions. They are reviewed at regular intervals and adapted to meet new requirements.

We are convinced that business success is reflected in a company’s enterprise value. We see a strong shareholder base that both actively supports and constructively supervises the management as a factor in business success.

Our aim in applying this basic philosophy is to represent the voting rights entrusted to us for the benefit and to the advantage of our fund subscribers, and to promote an active shareholder culture.

Proxy voting responsibilities

We vote in accordance with a uniform, transparent process. All agenda items for general meetings are examined individually and the rules are applied pragmatically and as the situation demands. We involve both a portfolio manager and, in individual cases, a corporate governance officer and senior management in the process in order to ensure we arrive at an objective opinion.

We vote in the case of all German companies and take decisions as necessary in the case of foreign companies. In the case of companies where we cannot vote personally, we entrust the voting rights we represent to professional proxy voting agencies, who vote at our discretion.