1. GENERAL PROVISIONS
1.1. This Voting Rights Strategy (hereinafter – Strategy) of UAB “Lords LB Asset Management” (hereinafter – Management Company) shall regulate the procedures and measures of the Management Company designed to ensure that the voting rights of the collective investment undertaking are used solely in the interests of the collective investment undertaking.
2. EXERCISE OF VOTING RIGHTS
2.1. Each manager of the collective investment undertaking managed by the Management Company must monitor communications on events, convened member meetings, agendas of meetings by the companies whose securities are held by the collective investment undertaking managed by him and other information related to the events of the company. This duty shall be carried out by the managers of the collective investment undertaking by periodically reviewing information sources specified in the incorporation documents of the relevant companies and monitoring information online.
2.2. The Management Company shall manage collective investment undertakings in accordance with corporate governance principles and shall seek to ensure that the Voting Rights Strategy is in line with the investment strategy and objectives of the collective investment undertaking. The Management Company shall operate exclusively in the interests of the collective investment undertaking on a fiduciary basis.
2.3. The Management Company shall make every endeavour to represent the interests of the collective investment undertaking at each meeting of members of the company. Depending on the interests of the collective investment undertaking, the representative of the Management Company may either vote or abstain.
3. AVOIDANCE OF CONFLICTS OF INTERESTS
3.1. An employee of the Management Company participating in the adoption of voting decisions during a meeting of members of the company must ensure that neither he nor any associated persons (within the meaning of the Conflict of Interests Procedure of the Management Company) has any conflict of interests which might affect the decision-making.
3.2. If a conflict of interests arises between the employee of the Management Company and collective investment undertaking out of the use of voting rights, the employee of the Management Company must immediately notify thereof the persons responsible for the management of conflicts of interests and the CEO of the Management Company. The CEO may suspend an employee of the Management Company from decision making in relation to the use of the voting right by the collective investment undertaking.
3.3. If a conflict of interests arises in a situation not regulated by this Strategy, the Conflict of Interests Policy of the Management Company shall be followed.
4. FINAL PROVISIONS
4.1. The Strategy shall enter into effect on the date of its approval and may be cancelled or amended only by the decision of the Board of the Management Company.
4.2. The Fund Managers or the CEO shall be responsible for the implementation of this Strategy.
4.3. All employees of the Management Company must acknowledge in writing that they have read this Procedure.