Denver Investment Advisors Proxy Policy

RiskMetrics Group's ISS Governance Services' Domestic Proxy Voting Guidelines

View Vote Records

Denver Investment Advisors LLC, unless otherwise directed by our clients, will make reasonable attempts to research, vote and record all proxy ballots for the security positions we maintain on our clients' behalf. To execute this responsibility to the highest standard, Denver Investment Advisors LLC relies heavily on its subscription to the ISS Proxy Voting system ("VoteX"). ISS (or Institutional Shareholder Services) provides proxy research and recommendations, as well as automated voting and record keeping, and is the world's leader in these services. Although ISS offers other consulting services to companies that it also makes proxy vote recommendations, we review their policies a minimum of once per year and will only use ISS as long as we deem them independent.

We have fully reviewed the ISS Proxy Voting Guidelines and follow their recommendations on most issues brought to a shareholder vote. Subcategories within the guidelines include:

1. Operational Items

2. Board of Directors

3. Proxy Contests

4. Anti-takeover Defenses and Voting Related Issues

5. Mergers and Corporate Restructurings

6. State of Incorporation

7. Capital Structure

8. Executive and Director Compensation

9. Social and Environmental Issues

10. Mutual Fund Proxies

11. Global Proxy Voting Matters

In the rare instance where our portfolio research or security analyst believes that any ISS recommendation would be to the detriment of our investment clients, we can and will override the ISS recommendation through a manual vote. The final authorization to override an ISS recommendation must be approved by the CCO, Executive Manager of Denver Investment Advisors LLC or a member of its Management Committee other than the analyst. A written record supporting the decision to override the ISS recommendation will be maintained.

Special considerations are made for stocks traded on foreign exchanges. Specifically, if voting will block the liquidity of these stocks, Denver Investment Advisors LLC will not exercise its voting rights.

For any matters subject to proxy vote for mutual funds in which Denver Investment Advisors LLC is an affiliated party, Denver Investment Advisors will vote on behalf of clients invested in such mutual funds in accordance with ISS, with no exceptions.

Client information is automatically recorded in "VoteX" for record keeping. For accounts custodied at financial institutions that are not clients of ISS, physical proxy cards are received, marked and returned for voting. Those votes are then manually recorded in the ISS Proxy VoteX system. For client accounts held in an omnibus registration, ballots that are received will be voted, but no records for individual accounts held in omnibus registration are maintained.

Denver Investment Advisors LLC maintains proxy data showing the voting pattern on specific issues -- either for an individual meeting or for all proxies voted within a specified time period, in addition to proxy voting on individual client accounts.

If you have any specific questions or concerns that have not been addressed here, please do not hesitate to contact your portfolio manager. Upon request we have available ISS Proxy Voting Guidelines Summary documentation from the ISS Proxy Voting manual.

Adopted: April 2003
Last Amended: February 2005

You can view RiskMetrics Group's ISS Governance Services' Concise Domestic Proxy Voting Guidelines here. ISS' complete Domestic Proxy Voting Guidelines are included on the Fund's Form N-CSR, which is available on the U.S. Securities and Exchange Commission web site at www.sec.gov.

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