KING implements policies and procedures that we believe are reasonably designed to ensure that proxies are voted in the best interest of our clients, in accordance with our fiduciary duties and SEC rule 206(4) under the Investment Advisers Act of 1940. Our authority to vote the proxies of our clients is established by our advisory contracts or comparable documents. Our proxy voting policies also reflect the fiduciary standards and responsibilities for ERISA accounts as established by the Department of Labor Bulletin 94-2, 29 C.F.R. 2509.94-2.

We vote and oversee a large volume of proxies; therefore, the Firm engages a service provider/voting delegate to assist with administrative functions and the mechanics of voting proxies.