Principle 7

Institutional investors should report periodically on their stewardship and voting activities

We acknowledge that as active managers we need to be accountable for our actions and demonstrate that we vote in a consistent manner based on our principles. Much of our engagement with companies is confidential but we publish case studies of our interaction with companies on less sensitive issues. It is our intention to commence publishing our quarterly stewardship report on the website in due course.

We provide transparency on our voting activity on M&G and Proxy Voting. This is updated on a quarterly basis. It is our intention to commence publishing our voting rationale in due course.

We report quarterly internally on how we discharge our stewardship responsibilities to a number of internal boards (where internal money is managed), obtain independent assurance of our stewardship activity and report to clients on stewardship activities on request.

M&G maintains records of interactions with companies, and we are in the process of implementing a new system for recording general monitoring activities for equity holdings. This is expected to be implemented during 2016. The Information to be retained on this database will include a record of all interactions with companies. Records of specific stewardship activities are currently retained within the Corporate Finance & Stewardship team.

All voting is processed and recorded via an external voting service on which a full record of all voting activity is retained, along with voting rationale.