If a fund uses proxy voting or shareholder or issuer engagement in relation to ESG matters as a principal investment strategy , the fund is required to disclose this in its investment strategies.23 In staff’s view, the disclosure should include the criteria used by the proxy voting or engagement strategy, the goal of the proxy voting or engagement strategy, and the extent of the monitoring process used to assess the success of the proxy voting or engagement strategy.
23 See Footnote 18 above.