Stralem & Company Incorporated

Proxy Voting Policy

 

Stralem & Company Incorporated

Proxy Voting Policy

 

Rule 206(4)-6 requires investment advisers who have voting authority with respect to securities held in their clients’ accounts to monitor corporate actions and vote proxies in their client’s interests.  They must also adopt written policies and procedures, make those policies and procedures available to clients and retain certain records with respect to proxy votes cast.

 

Stralem subscribes to a proxy monitor and voting agent service offered by Institutional Shareholder Services, Inc. (“ISS”). ISS provides a proxy analysis with research and a vote recommendation. They also transmit votes, record and generate a voting activity report for Stralem’s clients. Generally, Stralem does not have voting authority with respect to securities held in client accounts. If Stralem were asked to vote proxies on behalf of a client, Stralem will generally vote in accordance with the recommendations of ISS, but Stralem may issue instructions to change a particular vote if Stralem determines that it is in the client’s best interest. Where applicable, Stralem will also consider any specific guidelines designated in writing by a client. Stralem does not consider its own interest as an investment adviser in making proxy voting decisions for clients. If a conflict were to arise between Stralem and client interests with respect to a matter submitted to shareholders, Stralem would refer the matter to ISS and direct that service to vote the proxy in the client’s interest. Stralem will periodically monitor and review the policies of ISS.

 

Stralem will generally vote against any policy that would reduce: the rights of shareholders, shareholder influence over the board of directors and management, the alignment of interests between management and shareholders, or the value of shareholders’ investments.