Voting Right Policy

BENDURA Funds Inc. (BFLI) acts as a management company (UCITS) or as an alternative investment fund manager (AIFM) for the undertakings for collective investment (funds) it manages, which may be invested in domestic and foreign equity securities. In accordance with the European and national requirements, BFLI is obligated to exercise the voting or membership rights and creditors’ rights associated with the investments independently and exclusively in the interests of fund investors.


Safeguarding the interests of fund investors

BFLI exercises the voting or membership rights and creditors' rights associated with the investments of the managed fund assets independently and in such a way that the interests of the fund investors are safeguarded as far as possible; this under the constraint that the exercise of these rights is in accordance with the objectives and the investment policy of the relevant fund.


Principles regarding the exercise of voting or membership rights and creditors' rights

The following principles are observed when exercising voting rights:

  • Voting rights are exercised on a case-by-case basis taking into account whether the exercise of these rights leads to an economic value added for the investor. For instance, it may not be of economic advantage to investors, if BFLI participates in a general meeting for assets of a fund, if the fund only holds an insignificant share of the voting rights.
  • The exercise of voting rights is only considered by BFLI, if the voting rights can have an impact, which is usually not assumed for voting rights of less than 1%. This impact limit is calculated at BFLI level by cumulating all positions from the assets managed by BFLI.
  • In principle, BFLI exercises the voting rights for all transactions itself or delegates this to the depositary. Additionally, a delegation of the exercise of voting rights to a representative is also possible, if the representative explicitly received instructions from BFLI. In order to exercise the voting rights, BFLI may assign these rights to external asset managers or other third parties, but BFLI is not obliged to do so.
  • Voting rights are exercised independently and solely in the interest of the respective funds or their investors.
  • Insofar as the managed funds have the same interests, the voting rights for the relevant assets will be exercised jointly. If the interests of different funds differ, the different interests will be reflected in the voting behaviour of BFLI.


Avoidance of conflicts of interest

BFLI aims to prevent conflicts of interest that result from the exercise of voting rights, or to resolve or mitigate them in the interests of the investors. Whenever the AIFM delegates activities to third parties, the delegation taker (external asset manager, investment advisor, etc.) informs BFLI without being asked and in a timely manner in cases where the delegation taker exercises a function as a management body in a company being an investment of a fund managed by BFLI or where potential conflicts of interests arise. In such cases, BFLI takes special care that only the investors' interests and not the interests of the delegation taker influence the decision.



If you require any further information about voting rights policy, please do not hesitate to contact us.