Policies

Proxy Policy

It is the policy of Platte River Capital LLC (PRC) to monitor corporate actions and vote proxies for securities held in managed accounts when directed to do so by clients. In client accounts directly managed by the Company in which the PRC has not been given authority to take such actions, the client will retain the right and obligation to vote any proxies solicited by or with respect to securities held in their Account, including any shares of mutual funds or assign that right to a third party.

PRC uses the voting guidelines set forth in ISS Policies and Procedures. The Company’s policy is designed to ensure that PRC is voting in the best interests of the client in terms of potential economic return on the client’s investment. Additionally, PRC believes that good corporate governance ultimately results in increased shareholder value. At no time does the Company consider any benefit to PRC or its clients other than the benefits to the owner of the securities being voted. The client may, on any particular proxy, instruct PRC as to the way in which they want to vote on an issue or issues.

PRC has hired ISS to implement its proxy voting process. In such capacity, ISS provides analysis and record keeping for all the proxies PRC votes on behalf of the Company’s clients. PRC has reviewed the guidelines on how ISS votes on particular proposals. In addition, PRC investment managers are generally aware of the proposals that are being submitted. ISS will vote the received proxies in accordance with its guidelines, unless PRC has indicated its intent to override the ISS guidelines basis on the Company’s analysis of that proxy issue.

ISS will receive from PRC a list of the Company’s holdings on a weekly basis. In addition, ISS receives proxy materials from client custodians. ISS reconciles the information received from both PRC and the custodians and communicates any discrepancies to PRC operations personnel for resolution.

A summary of voting records is compiled by ISS and reviewed monthly by PRC’s Chief Compliance Officer. Upon request, PRC will provide clients with information regarding the voting of all or any particular proxies on their behalf. To obtain a copy of the ISS policy guidelines or proxy voting records please contact Ron Gibbs at (303) 292-7385.