What Is a Proxy Voting Policy?

Advisers with proxy voting authority are required to adopt policies reasonably designed to ensure votes are cast in clients’ best interests, disclose their voting policies to clients, and maintain records of how proxies were actually voted along with any client requests for that voting history. A common conflict scenario the policy needs to address is voting on matters involving a company the adviser has some other business relationship with — the policy should describe how such conflicts are identified and managed.

Firms that don’t take on proxy voting authority still need to disclose that fact to clients, explaining who retains voting responsibility instead (typically the client directly).