Voting rights policy

In accordance with the CSSF Regulation 10-04 (Article 23) with regards to the management of UCITS and the Commission Delegated Regulation (EU) 231/2013 of 19th December 2013 with regards to the management of AIFs, M&G Luxembourg S.A. (“MAGL”), as a Management Company subject to Chapter 15 of the Law of 17th December 2010 (UCITS Law) and the Law of 12th July 2013 (AIFM Law), applies voting rights on the basis of the following policy.

1. Scope of the Voting Policy

The present policy is applicable to MAGL, its employees, delegates and any operating subsidiaries, or business divisions providing services to the Funds and Segregated Mandates for which MAGL is appointed as manager or investment manager including M&G Real Estate Fund Management S.a.r.l.

As per the Article 23 CSSF Regulation 10-04 and Section 5.5.10 of CSSF Circular 18/698, MAGL develops an adequate and effective policy for determining when and how voting rights attached to instruments held in the portfolios of the managed funds are to be exercised, so that these rights benefit exclusively the fund concerned and its investors.

An investment company that has designated MAGL but has not specifically mandated it to exercise the voting rights attached to the instruments held in its portfolio, must develop its own policy for the exercise of voting rights (Section 5.5.10 of CSSF Circular 18/698).

2. Measures and procedures to exercise voting rights

As required by the CSSF Regulation and Article 37 AIFMD L.2, the above mentioned policy determines measures and procedures for:

a) monitoring relevant corporate events / corporate actions;

b) ensuring that the exercise of voting rights is in accordance with the investment objectives and policy of the relevant fund;

c) preventing or managing any conflicts of interest arising from the exercise of voting rights.

As stated by the CSSF Circular 18/698 Section 5.5.10, it is also acceptable for the MAGL, when establishing its own policy for exercising voting rights, to refer either to the strategies established in this regard by the group to which it belongs or to recognized international standards.

3. Disclosure of the voting rights policy to investors

For UCITS Funds: CSSF Regulation 10-04 & CSSF Circular 18/698 require that a summary description of the policy to be made available to investors by MAGL, free of charge, notably by way of a website.

For AIFs: Article 37 AIFMD L.2 requires that a summary description of this policy and details of the actions taken on the basis of this policy is made available to investors on their request.

Details of the actions taken on the basis of this policy are made available to investors free of charge and upon their request.

4. Reporting in the management information of MAGL

MAGL maintains in an adequate and orderly manner records of its activities and its internal organization. To this end, MAGL puts in place "management information" permitting the follow-up of its activity and that of its delegates.

Finally, it is ensured that this management information is available in Luxembourg and preferably kept in a central database accessible at any time in Luxembourg.