Voting Rights Policy

1. Voting Rights Policy for financial instruments in the portfolio of mutual funds managed by the Company

(a) Criteria for exercising voting rights

Share-related and other rights (such as the right to attend general meetings, voting rights, rights to information) that derive from financial instruments in the portfolios of mutual funds the Company manages are exercised at all times bearing in mind the interests of investors, in line with the investment goals and investment policy of each mutual fund, irrespective of the interests of any company in the Group to which the Company belongs. Rights are exercised in line with the procedures laid down in Company Law as in force from time to time.

 (b) Monitoring of corporate developments

The Company’s Investments Division receives information about upcoming general meetings of the issuers of financial instruments which are in the portfolio of the mutual funds it manages either by via notices in the press or online, or by directly contacting representatives of the issuers of those financial instruments.

 

(c) Way in which voting rights are exercised

The Company’s Board of Directors takes a decision appointing specific Company representatives who will attend the general or special meetings of the issuer of the financial instruments, for instruments in the fund portfolios, and who will vote on behalf of the mutual funds.

In some cases the Company may authorise third parties (such as members of the Board of those companies) to exercise voting rights on its behalf.

 

(d) Decisions relating to how voting rights are to be exercised

 

The Company necessarily participates in meetings and exercises the voting rights deriving from the financial instruments in the portfolio of the mutual funds it manages, provided that the Company’s Managing Director considers that the issues which will be discussed, which the Company will have to vote about, are significant for the Company’s future development, that the voting rights need to be exercised in the interests of unitholders in the mutual fund, and that this is in accordance with the investment policy of the mutual fund it manages.

 

(e) Preventing or managing conflicts of interest arising from the exercise of voting rights

The Company does not exercise voting rights deriving from financial instruments in the portfolios of mutual funds that it manages in the following cases:

  • In the case of a general or other meeting of an issuer who is a member of the same Group that the Company belongs to.
  • In the case of a general or other meeting of an issuer with which the Company or the Group to which the Company belongs, or another company in the Group to which the Company belongs, has close ties.

However, the Company’s Board of Directors may issue a reasoned decision allowing voting rights to be exercised in these cases, provided that the exercise of those rights is dictated by the interests of unitholders in the mutual fund, is in accordance with the investment goal and investment policy of the mutual fund it manages, and that the independence of the decision about how voting rights are exercised vis-a-vis the issuer is ensured.

(f) Provision of information to unitholders

A brief description of this Company policy and any updates to it are made available to unitholders in the funds it manages by posting that information on the Company’s website, www.3kip.gr.

Details about the steps taken based on these strategies are available to unitholders free of charge upon request.

2. Voting Rights Policy for financial instruments in the portfolio of Company clients

 

In the case of portfolios of individual clients managed by the Company, the management contracts the Company signs do not include powers to exercise the voting rights that derive from the financial instruments in the Client’s portfolio, nor, as a matter of principle, does the Company accept any special powers in that regard. However, in exceptional cases where the Company does accept such authorisation:

a) The Investments Manager ensures that voting rights are exercised in line with any instructions given by the client, if such authorisation has been granted to the Company.

b) In the case of carte blanche authorisation, the Company ensures that the decisions it takes are independent of the Group to which it belongs, and that it is in a position to justify its decision in all events.

c) It informs the Compliance Officer to check whether there are any disclosure obligations under Law 3556/2007.