2019 Breckinridge Sustainability Report - Page 31



APPENDIX
SUSTAINABILITY DISCLOSURE TOPICS AND ACCOUNTING METRICS
Topic
Metric
2018 Performance
Incorporation of Environmental, Social Description of proxy voting and investee (Continued from page 27)
and Governance Factors in Asset
engagement policies and procedures
It is our policy to vote the proxies in
Management
the best interest of clients. When
a proxy is received, we will engage
our investment team to review the
proposals and decide on a vote. Should
a material conflict of interest be
identified, Breckinridge may engage a
third-party consultant to recommend
votes on the ballot. The recommended
votes are binding. Proxy voting is
handled internally by our compliance
department.
To address the lack of proxy voting in
fixed income, we have developed a bond
issuer engagement effort that focuses
on direct, strategic conversations with
issuer management teams. We enter the
discussions with three objectives in mind:
1. To gain a better understanding
of the credit and ESG profiles of
bond issuers, the material issues,
opportunities and risks they face;
2. To provide an idea-generation
platform for analysts; and
3. To encourage the transparent
reporting of material ESG issues, as
improved disclosure would enhance
our ESG analysis to the benefit of our
clients.
Business Ethics
Total amount of monetary losses as a
result of legal proceedings associated
with fraud, insider trading, antitrust,
anticompetitive behavior, market
manipulation, malpractice, or other
related financial industry laws or
regulations
Zero
Description of whistleblower policies
and procedures
As part of Breckinridge’s Code
of Ethics and overall compliance
program, employees are encouraged
to report any actual or suspected
violations of applicable laws or
policies, as well as any fraud or illegal
activity involving our business, to the
firm’s chief compliance officer.
(Continued on page 29)
28

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