Voting rights

S.A.I. Atlas Asset Management S.A. has the obligation to establish internal rules and procedures allowing the transmission of orders for the prompt and fair execution of transactions with the financial instruments in the UCITS’ portfolio.

In order to fulfill the obligation of voting in the benefit of UCITS’ portfolio, the Company will adopt the following measures:

a) Monitoring of important events that occur in the portfolio managed;

b) Ensuring that the voting rights are in accordance with the objectives and investment policy established in UCITS’ documents;

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

The voting rights of financial instruments held in UCITS’ portfolios managed shall be exercised by those who are responsible for analysis and placement of financial instruments. Important events that occur in the owned companies, capital increases, dividends, general meetings of shareholders and other changes will be monitored by the department of back office and will be notified to the persons responsible for analysis and placement of financial instruments.

According with Depository contracts we are informed about the decision established by issuer’s decisions in ordinary or extraordinary general meetings. Based on this information and the careful monitoring of back-office employees, persons in charge of analyzing and placing of financial instruments will be informed promptly and can make decisions based on reliable information.

Persons responsible for voting will follow standard procedures established by each issuer and will officially represent our funds in ordinary or extraordinary meetings of issuers by promoting best interests, designed to increase the value of their portfolios.

Voting on behalf of clients will consider the value of holdings in their portfolios, the impact of the vote on short / long term, influence cost / benefit.

A conflict of interest occurs when the Company's interests interfere with the interests of funds administrated. Can be conflict of interest following situations, without limitation to:

a) an issuer is a client of the Company;

b) an issuer for which the Company acts as sponsor, manager, distributor;

c) a relevant person in the issuer has direct relationships with staff in the Company or the Company;

In order to prevent conflicts of interest that may arise when exercising the voting rights, the Company will adopt the following measures:

1. Monitors the persons responsible for analyzing and placing of financial instruments, namely monitoring transactions by them with different issuers that are included in portfolios managed by the Company OPC sites;

2. Identification of possible material or financial benefits that could be pursued by those responsible for analyzing and placing the financial instruments;

Persons responsible for analyzing and placing of financial instruments will exercise voting rights in accordance with the objectives and investment policy mentioned in documents of the funds.

In order to ensure the exercise of voting rights in accordance with the objectives and investment policy of the funds, the Company will adopt the following measures:

a) Complaint officer will inform permanently about changes made in documents of the funds, especially changes in the objectives and investment policy;

b) continuous training of persons responsible for the analysis and placing of financial instruments;

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