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Article 36 – Disclosure of conflicts of interest ⬅️ | ➑️ Article 38 – Risk management systems

Article 37 - Strategies for the exercise of voting rights

1.

An AIFM shall develop adequate and effective strategies for determining when and how any voting rights held in the AIF portfolios it manages are to be exercised, to the exclusive benefit of the AIF concerned and its investors.

2.

The strategy referred to in paragraph 1 shall determine measures and procedures for:

(a)

monitoring relevant corporate actions;

(b)

ensuring that the exercise of voting rights is in accordance with the investment objectives and policy of the relevant AIF;

(c)

preventing or managing any conflicts of interest arising from the exercise of voting rights.

3.

A summary description of the strategies and details of the actions taken on the basis of those strategies shall be made available to the investors on their request.