CHAPTER III

CONFLICT OF INTERESTS

(Article 12(1)(b) and Article 14(1)(d) and (2)(c) of Directive 2009/65/EC)

Strategies for the exercise of voting rights
Article 21
1
Member States shall require management companies to develop adequate and effective strategies for determining when and how voting rights attached to instruments held in the managed portfolios are to be exercised, to the exclusive benefit of the UCITS concerned.
2
The strategy referred to in paragraph 1 shall determine measures and procedures for:
a
monitoring relevant corporate events;
b
ensuring that the exercise of voting rights is in accordance with the investment objectives and policy of the relevant UCITS;
c
preventing or managing any conflicts of interest arising from the exercise of voting rights.
3
A summary description of the strategies referred to in paragraph 1 shall be made available to investors.
Details of the actions taken on the basis of those strategies shall be made available to the unit-holders free of charge and on their request.