In accordance with the requirements of Rule 206(4)-6 under the Investment Advisers Act of 1940 (the “Advisers Act”), Peregrine Investment Advisors, LLC (“Peregrine”) has adopted the following proxy voting policy with respect to those assets for which a client has vested Peregrine with discretionary investment management authority (the “assets”).
Unless a client directs otherwise, in writing, Peregrine shall be responsible for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, and tender offers. However, the client shall maintain exclusive responsibility for all legal proceedings or other type events pertaining to the assets, including, but not limited to, class action lawsuits. Peregrine and/or the client shall correspondingly instruct each custodian of the assets to forward to Peregrine copies of all proxies and shareholder communications relating to the assets. Absent mitigating circumstances and/or conflicts of interest (to the extent any such circumstance or conflict is presented, if ever, information pertaining to how Peregrine addressed any such circumstance or conflict shall be maintained by Peregrine), it is Peregrine’s general policy to vote proxies consistent with the recommendation of the senior management of the issuer. Peregrine shall monitor corporate actions of individual issuers and investment companies consistent with Peregrine’s fiduciary duty to vote proxies in the best interests of its clients. With respect to individual issuers, Peregrine may be solicited to vote on matters including corporate governance, adoption or amendments to compensation plans (including stock options), and matters involving social issues and corporate responsibility. With respect to investment companies (e.g., mutual funds), Peregrine may be solicited to vote on matters including the approval of advisory contracts, distribution plans, and mergers. Peregrine shall maintain records pertaining to proxy voting as required pursuant to Rule 204-2 (c)(2) under the Advisers Act.
Copies of Rules 206(4)-6 and 204-2(c)(2) are available upon written request. In addition, information pertaining to how Peregrine voted on any specific proxy issue is also available upon written request. Any questions regarding Peregrine’s proxy voting policy shall be directed to Kevin Anthony, Chief Compliance Officer of Peregrine.
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