Rule 206(4)-6 - Proxy voting.

If you are an investment adviser registered or required to be registered under Section 203, it is a fraudulent, deceptive, or manipulative act, practice or course of business within the meaning of Section 206(4), for you to exercise voting authority with respect to client securities, unless you:

(a) Adopt and implement written policies and procedures that are reasonably designed to ensure that you vote client securities in the best interest of clients, which procedures must include how you address material conflicts that may arise between your interests and those of your clients;

(b) Disclose to clients how they may obtain information from you about how you voted with respect to their securities; and

(c) Describe to clients your proxy voting policies and procedures and, upon request, furnish a copy of the policies and procedures to the requesting client.

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