(a) Funds that use proxy voting as an ESG strategy
Past proxy voting records on websites: An investment fund is required to maintain a proxy voting record40 and make its most recent annual proxy voting record available on its designated website, as well as promptly send it to any securityholder upon request.41 While these requirements only apply to a fund’s most recent annual proxy voting record, staff encourage all funds, particularly ESG Objective Funds and ESG Strategy Funds that use proxy voting in relation to ESG matters as a principal investment strategy, to make all of their annual proxy voting records, including historical records from previous years, available on their designated websites. In staff’s view, such disclosure would provide greater transparency into how the fund’s ESG-focused proxy voting strategy has historically been implemented, and in the case of an ESG Objective Fund, how the fund has historically used proxy voting to meet its ESG-related investment objectives.
MRFP disclosure: Staff encourage all ESG Objective Funds and ESG Strategy Funds that use proxy voting in relation to ESG matters as a principal investment strategy to include, as part of the summary of the results of the fund’s operations in the MRFP, disclosure about how the past proxy voting records during that period align with the ESG-related investment objectives and/or strategies of the fund.
40 Section 10.3 of NI 81-106.
41 Section 10.4 of NI 81-106.