Compliance and Regulation

PROXY VOTING POLICY - 2017

Rule 206(4)-6

In accordance with the requirements of Rule 206(4)-6 under the Investment Advisers Act of 1940 (the “Advisers Act”), Hanson & Doremus Investment Management (“HDIM”) has adopted the following proxy voting policy with respect to those assets for which a client has vested HDIM with discretionary investment management authority (the “assets”).

HDIM’s Policy

Unless the client directs otherwise in writing, HDIM, in conjunction with its engagement of Broadridge Financial Services, Inc. (“Broadridge”) is responsible for voting client proxies.  Broadridge shall vote proxies and other shareholder matters in accordance with the Broadridge Proxy Voting Guidelines. HDIM, in conjunction with the services provided by Broadridge, shall monitor corporate actions of individual issuers and investment companies consistent with HDIM’s fiduciary duty to vote proxies in the best interests of its clients.  With respect to individual issuers, HDIM may be solicited to vote on matters including corporate governance, adoption or amendments to compensation plans (including stock options), and matters involving social issues and corporate responsibility. With respect to investment companies (e.g., mutual funds), HDIM may be solicited to vote on matters including the approval of advisory contracts, distribution plans, and mergers.  HDIM, in conjunction with Broadridge, shall maintain records pertaining to proxy voting as required pursuant to Rule 204-2 (c)(2) under the Advisers Act.  Copies of Rules 206(4)-6 and 204-2(c)(2) are available upon written request. Broadridge on behalf of HDIM shall maintain records pertaining to proxy voting as required pursuant to Rule 204-2 (c)(2) under the Advisers Act.  

Copies of Rules 206(4)-6 and 204-2(c)(2) are available upon written request. In addition, information pertaining to how HDIM, in conjunction with Broadridge, voted on any specific proxy issue is also available upon written request.

Any questions regarding HDIM’s proxy voting policy shall be directed to Eric Hanson, Chief Compliance Officer of HDIM. 

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