Voting Rights Policy

The Company has set out appropriate and effective strategies to determine when and how voting rights attached to instruments held in the portfolios managed are exercised, to ensure that these rights are only of benefit to the relevant UCITS’s.

The strategy:

• Ensures the monitoring of relevant corporate events
• Prevents or manages any conflict of interest arising from the exercise of voting rights.

All corporate events concerning the exercising of voting rights are communicated by the Central Administrator to all Conducting Officers of VAM.

The following principles will be adhered by VAM for the exercise of the rights of intervention and vote relating to the corporate events related to the financial instruments pertaining to each Sub-Fund of Vector SICAV, in compliance with the Luxembourg law, with the objective to ensure that such rights are exercised in the exclusive interest of the shareholders of any of the Sub-Fund of Vector SICAV:

• VAM will not exercise the voting rights relating to the financial instruments pertaining to any Sub-Fund of Vector SICAV;
• VAM will not delegate the exercise of voting rights;
• VAM will not enter into shareholder agreements providing for block voting or imposing restrictions on transferring shares.

VAM monitors the corporate events linked to the exercise of voting rights, as all corporate events are communicated by the Central Administrator to all Conducting Officers.

The Board needs to approve any change in policy pertaining to the exercise of voting rights.