ING Group has announced it has established a Global Voting Policy to govern the exercise of voting rights for all of ING´s client and proprietary assets world-wide. The policy provides the groundwork for ING´s asset management units to adopt a higher profile as institutional investors.
The policy outlines key principles, and is intended to provide a framework for ING´s individual asset management units to draw up more detailed voting procedures that conform with the regulations and standards of the countries in which they operate.
In the Netherlands, ING will make more active use of its voting rights, and from 1 January 2005 ING will begin reporting quarterly on its voting behaviour for both proprietary and client assets, in line with the best practices outlined in the Dutch corporate governance code.
In order to avoid potential conflicts of interest, the voting policy draws a clear distinction between proprietary assets, held for ING´s own account, and assets held on behalf of clients. In terms of client assets, including mutual funds, voting rights will be exercised in the exclusive interest of the clients, without taking into consideration any relationships ING may have with the company involved. For ING´s proprietary assets, votes will be exercised in the interest of ING, taking into consideration all of the different business relationships ING´s units may have with the company.
That means ING´s asset management companies may cast different votes for client assets and proprietary assets respectively. ING maintains Chinese Walls between the management of proprietary assets and client assets, as well as between the various business lines within ING, and the company has procedures in place to address any potential conflicts of interest.
Taking the global policy as a framework, ING´s asset management units will each set up their own procedures for voting proxies, including rule books, voting committees, and back-office support to monitor and record votes cast. ING Investment Management Australia and ING Investment Management Americas currently have such rule books and procedures in place.
In the Netherlands, ING Investment Management has developed procedures to vote on the flagship master funds, which group most of the equity investments held for third-party institutional investors and mutual funds. ING Investment Management is now discussing with its custodian how to bring proxy voting into practice for those funds. For the proprietary Dutch equity portfolio (including the so-called 5% stakes), ING Investment Management will appoint a Voting Committee to determine the votes on a case-by-case basis.
Source: ING Group