OUR APPROACH

Establishing and issuing the voting policy

IVOX does not have a self-established voting policy as all voting policies are driven by the client. Some of our clients base their policy on publically available guidelines, such as those of the German Association of Institutional investors (BVI), or the International Corporate Governance Network (ICGN). Upon request we help clients or other institutions to draft their own applicable guidelines.

To protect the anonymity of our clients, we will not publish their proxy voting guidelines nor their identity on our website. In fact our clients have published their policies on their websites.

Establishing and submitting vote recommendations to investors

IVOX uses all sorts of publicly available sources for its analyses to give them a profound basis. If we need further information, we proactively contact issuers to get all information needed. It is important for IVOX to make the analysis process and the resulting recommendations transparent for the users. To grant a high quality and reliability any report is cross checked twice before publication.

All clients are provided with a comprehensive reporting feature (AMF or standard) for all votes cast.

Our analyses are published three weeks in advance of general meetings to ensure the informed execution of voting rights in the cross-border-voting process for our clients.

Communicating with listed companies

A comprehensive set of reliable data and sources of information are essential for IVOX to provide adequate vote recommendations.

If it is necessary IVOX contacts issuers to inquire for additional information. In order to prevent conflicts of interest we only contact companies to receive essential information and not to advise them.

As a timely delivery is vital for the execution of voting rights, we give issuers deadlines to deliver the requested information.

Preventing Conflicts of Interest

As IVOX only uses client guidelines, we do not have a conflict of interest in applying these guidelines.

IVOX always tries to see the specific situation and hence does not only use a simple “formula” to give a recommendation. As previously stated, we justify our recommendations to give investors an overview of the situation.

IVOX only contacts companies proactively, if this is essentially necessary for the high quality of our analyses, to grant our independence and prevent conflicts of interest.

Due to its structure – 100% privately financed – IVOX is deemed an Independent Proxy Advisor.

CODE OF ETHICS

Ethical principles in private and company matters are the backbone of the continued existence and further development of a modern society. They thus also form the basis of conduct in business and of the relations between companies and national economies.

IVOX has passed a Code of Ethics which places its directors and staff under the obligation to commit to ethical conduct. By introducing this Code of Ethics, we intend to fulfil our obligations to our clients and society in a reliable manner.

The Code of Ethics defines various principles, including:

• IVOX operates worldwide in compliance with local and international laws, regulations and standards.
• Nobody may suffer disadvantages from compliance with the IVOX Code of Ethics.
• Staff are continuously informed and trained on issues including ethical matters in their daily work.
• IVOX rejects unethical business practices and operates its business free from corruption and bribery.

The complete IVOX Code of Ethics is available for download here [ PDF ].