Proxy Voting Information
The Securities and Exchange Commission (the “SEC”) requires mutual funds to adopt proxy voting policies and procedures and to disclose their proxy voting records.
Westcore Funds’ Board of Trustees has delegated to its investment adviser Denver Investments, subject to the supervision of the Board, the authority to vote Fund proxies related to portfolio securities and has directed Denver Investments to follow and apply Denver Investments’ proxy voting policies and procedures when voting such proxies.
Summary of Denver Investments’ Proxy Policy
Denver Investments, relies on a third-party vendor, Institutional Shareholder Services (“ISS”), to research, vote and record all proxy ballots for the security positions we maintain on clients’ behalf and for which we have voting authority. Annually, we fully review ISS’ independence and its Proxy Voting Guidelines. We follow ISS’ General Guidelines on most issues for shareholder vote. However, ISS does offer more customized proxy voting policies, such as Taft-Hartley and Public Fund Advisory which may be selected by clients for an additional fee. Major subcategories within ISS’ guidelines are:
1) Operational Items
2) Board of Directors
3) Proxy Contests
4) Anti-takeover Defenses and Voting Related Issues
5) Mergers and Corporate Restructurings
6) State of Incorporation
7) Capital Structure
8) Executive and Director Compensation
9) Corporate Social Responsibility (CSR) Issues
10) Mutual Fund Proxies
11) Global Proxy Voting Matters
ISS’ Proxy Voting Guidelines may be updated from time to time.
In the rare instance when a portfolio manager or analyst believes that an ISS recommendation would be to the detriment of the firm’s investment clients, we can and will override ISS’ recommendation through a manual vote. If more than one investment team or Wealth Management portfolio manager holds the security, the decision to override should be authorized by a member of each investment team or the Wealth Management portfolio manager. The final authorization to override an ISS recommendation must be approved by the CCO or a member of Denver Investments’ Management Committee other than the individual requesting the override. A written record supporting the decision to override the ISS recommendation will be maintained.
Generally, for stocks traded on foreign exchanges, Denver Investments will exercise its voting authority. However, if we believe that by voting, a client will incur excessive expense or that a lack of liquidity of a stock may be an issue, Denver Investments may not exercise its voting authority after considering all relevant factors.
For any matters subject to proxy vote for mutual funds in which Denver Investments is an affiliated party, Denver Investments will vote on behalf of clients invested in such mutual funds in accordance with ISS recommendations, with no exceptions.
Client information is automatically recorded in ISS’ system for record keeping. ISS provides the necessary reports for the Westcore Funds to prepare its Form N-PX annually. ISS’ complete Domestic and Global Proxy Voting Guidelines are included as Exhibit B to the Statement of Additional Information, which can be obtained free of charge by calling 800.392.CORE (2673) or by visiting www.sec.gov.