Laurium Capital,  policy and procedures for voting proxies (“Policy”) applies to securities held in the accounts of clients to whom Laurium provides discretionary investment management services, and for which Laurium Capital has authority to vote proxies. This Policy is reviewed and updated as necessary to address new and evolving proxy voting issues and standards.

Laurium Capital will use its best efforts to vote proxies as part of its authority to manage, acquire and dispose of account assets.

Laurium Capital will vote proxies in a prudent and diligent manner and in the best interests of clients for which Laurium Capital manage assets, consistent with the objective of maximizing long-term investment returns.